Wherefore, the Plaintiff, Dorian Williams demands damages from the Defendants, City of
Chicago, James Turney, Michael Birmingham, Shawn Monroe, Michelle Reed, and other

unnamed Chicago police officers, in the amount of $1,000,000.00 plus costs and attorneys fees.

Keith L. Young

333 West Wacker Drive
Suite 500

Chicago, Illinois 60606
(312) 807 - 4777


COUNT 3 - INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

7.

8.

. Plaintiff realleges paragraph 1 of Count 1.
. Plaintiff realleges paragraph 2 of Count f.
. Plaintiff realleges paragraph 3 of Count 1.
. Plaintiff realleges paragraph 4 of Count 1.
. Plaintiff realleges paragraph 5 of Count 1.
. Plaintiff realleges paragraph 6 of Count 1.

. That the acts of the Defendants caused the Plaintiff to suffer severe emotional distress.

COUNT 4 - VIOLATION OF CIVIL RIGHTS

. Plaintiff realleges paragraph 1 of Count 1.
. Plaintiff realleges paragraph 2 of Count |.
. Plaintiff realleges paragraph 3 of Count 1.
. Plaintiff realleges paragraph 4 of Count 1.
. Plaintiff realleges paragraph 5 of Count 1.

. Plaintiff realleges paragraph 6 of Count 1.

Plaintiff realleges paragraph 7 of Count 1.

Plaintiff had a right under 42 U.S.C 1983 and the Constitution of the United States of

America to be free from unreasonable searches and seizures and a reasonable expectation of

privacy.

9.

That the acts of the Defendants violated the Plaintiff's rights under 42 U.S.C. 1983

and the Constitution of the United States of America.


UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION v

we

DORIAN WILLIAMS, ) JUN 0 2 2008 May » 920 9
Plaintiff, ) Ai ea G
) Chee ge. Done,
v. ) 03. ©3227 ois Oe
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CITY OF CHICAGO, JAMES TURNEY, ) ¢ us (AM to
MICHAEL BIRMINGHAM, )
SHAWN MONROE, and MICHELLE REED, )
Defendants )

NOTICE OF FILING AND CERTIFICATE OF SERVICE

To: Arnold H. Park
Assistant Corporation Counsel
30 North LaSalle Street
Suite 900
Chicago, Illinois 60602

Please take notice that I have filed this day with the Clerk of the above Court Plaintiff's
First Amended Complaint at Law, a copy of which is attached hereto and herewith served upon
you.

Thereby certify that I have caused a true and correct copy of the above and foregoing
Notice of Filing and Plaintiff's Amended Complaint at Law to be sent via mail to the person in
the foregoing Notice at the address therein shown on May 29, 2003.

Aa ZF
Keith L. Young

333 West Wacker Drive
Suite 500

Chicago, Illinois 60606
(312) 807 - 4777


UNITED STATES DISTRICT COURT F
NORTHERN DISTRICT OF ILLINOIS f I .E 'B)
EASTERN DIVISION
May 24
: mF o 2 2003 fr
poss vant } 9 2008 aug CEARL WY. Dog °
» gun a2? Me Wb bao Set
V. ) 03 C3227 ms
)
CITY OF CHICAGO, JAMES TURNEY, ) HONORABLE
MICHAEL BIRMINGHAM, SHAWN MONROE, ) —- RONALD A. GUZMAN
and MICHELLE REED, )
Defendants )

FIRST AMENDED COMPLAINT AT LAW

Now comes the Plaintiff, Dorian Williams, by her attorney, Keith L. Young, and
complaining of the Defendants, City of Chicago, James Turney, Michael Birmingham, Shawn
Monroe, and Michelle Reed states as follows:

JURISDICTION

This is a lawsuit for violation of the rights of the Plaintiff, Dorian Williams under 42
U.S.C. 1983 and the Constitution of the United States of America and for common law battery,
false imprisonment, and intentional infliction of emotional distress. It was originally filed in the
Circuit Court of Cook County Illinois and entitled Dorian Williams v. City of Chicago, a
municipal corporation, 03 L 5256. It was removed to this court by notice of removal filed on
May 14, 2003.

COUNT 1 - BATTERY

1. That on May 29, 2002, the Plaintiff, Dorian Williams was present at a public
basketball court located at 56" and Emerald in the City of Chicago, County of Cook, and State of
Tllinois.

2. That on May 29, 2002, the Defendants, James Turney, Michael Birmingham, Shawn



Monroe, and Michelle Reed were police officers employed by the Defendant, City of Chicago.

3. That at all times relevant hereto, the Defendants, James Tumey, Michael Birmingham,
Shawn Monroe, and Michelle Reed were acting both individually and as agents, servants, and
employees of the Defendant, City of Chicago.

4. That at all times relevant hereto, the Defendants, James Turney, Michael Birmingham,
Shawn Monroe, and Michelle Reed were acting under color of law.

5. That the Defendants and other unnamed Chicago police officers, intentionally touched
the Plaintiff, Dorian Williams about her body and limbs and forced her to pull down her pants
and underwear without her consent or permission.

6. That the Defendants lacked probable cause to believe that the Plaintiff had committed
a crime.

7. That the Plaintiff was not arrested and no criminal charges were brought against her.

8. That the acts of the Defendants constitute battery.

COUNT 2 - FALSE IMPRISONMENT

1, Plaintiff realleges paragraph 1 of Count 1.

2. Plaintiff realleges paragraph 2 of Count 1.

3. Plaintiff realleges paragraph 3 of Count 1.

4. Plaintiff realleges paragraph 4 of Count 1.

5. Plaintiff realleges paragraph 5 of Count 1.

6. Plaintiff realleges paragraph 6 of Count 1

7. That at all times mentioned, the Defendants intended to restrain the Plaintiff.

8. That the acts of the Defendants constitute false imprisonment.