UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF MICHIGAN 

SOUTHERN DIVISION 

RUSSELL MARCILIS II, FELICIA MARCILIS, 

JASMINE MARCILIS, RUSSELL MARCILIS I, 

and MARIE MARCILIS, 

 Plaintiffs, 

v. CASE NO: 2:09-cv-11624 

 HON: LAWRENCE P. ZATKOFF 

 MAG. VIRGINIA M. MORGAN 

REDFORD TOWNSHIP, BRIAN JONES, ERIC WOODALL, 

ERIC GILLMAN, JOHN BUTLER, KEVIN JEZIOROWSKI, 

WILLIAM HAND, BRAD BOYLE, DAVE LIVINGSTON, 

CHRIS RICHARDSON, and OTHER UNNAMED OFFICERS, in their individual 

and official capacities, 

 Defendants. 

_______________________________________________________________________/ 

CHRISTOPHER TRAINOR & ASSOCIATES CUMMINGS, McCLOREY, DAVIS 

CHRISTOPHER J. TRAINOR (P42449) & ACHO, P.L.C. 

SHAWN C. CABOT (P64021) JEFFREY R. CLARK, (P33074) 

Attorneys for Plaintiffs ANNE M. McLAUGHLIN (P40455) 

9750 Highland Road Attorneys for Defendants 

White Lake, MI 48386 33900 Schoolcraft Road 

(248) 886-8650 Livonia, MI 48150 

Shawn.cabot@cjtrainor.com (734) 261-2400 

_______________________________________________________________________/ 

SECOND AMENDED COMPLAINT AND JURY DEMAND

 NOW COME Plaintiffs, by and through their attorneys, CHRISTOPHER 

TRAINOR & ASSOCIATES, and for their Second Amended Complaint against the 

above-named Defendants state as follows: 

1. At the time of the incidents giving rise to this Complaint, Plaintiffs Russell II, 

Felicia, and Jasmine were residents of Clinton Township, County of Macomb, 

State of Michigan. 

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2. At the time of the incidents giving rise to this Complaint, Plaintiffs Russell I 

and Marie were residents of the City of Detroit, County of Wayne, State of 

Michigan. 

3. Defendant Redford Township is a municipal corporation and governmental 

subdivision organized and existing under the laws of the State of Michigan. 

4. The individually-named Defendants Jones, Woodall, Gillman, Butler, 

Jeziorowski, and Hand are and/or were police officers employed by the 

Redford Township Police Department and were acting under color of law and 

within the course and scope of their employment at all times mentioned 

herein. 

5. That Defendant Richardson was and/or is a police officer employed by the 

City of Detroit Police Department and was acting under color of law and 

within the course and scope of his employment at all times mentioned herein. 

6. That Defendants Boyle and Livingston were and/or are officers employed by 

the United States Drug Enforcement Administration and were acting under 

color of law and within the course and scope of their employment at all times 

mentioned herein. 

7. At all times mentioned herein, Defendants were acting in their individual and 

official capacities. 

8. All relevant events giving rise to this lawsuit occurred in the Counties of 

Wayne and Macomb. 

9. Jurisdiction is vested in this Court pursuant to 28 U.S.C. § 1331 [federal 

question], 28 U.S.C. § 1343 [civil rights]. 

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10. That this lawsuit arises out of Defendants’ violations of Plaintiffs’ federal 

constitutional rights as secured by the Fourth and Fourteenth Amendments to 

the United States Constitution and consequently, Plaintiffs have viable claims 

for damages under 42 U.S.C. § 1983. 

11. This Court also has supplemental jurisdiction over Plaintiffs’ state law claims. 

12. That the amount in controversy exceeds Seventy-Five Thousand Dollars 

($75,000.00) not including interest, costs, and attorney fees. 

FACTS

13. Plaintiffs reallege and incorporate by reference each and every paragraph of 

this Complaint as though fully set forth herein. 

14. On May 2, 2007, Defendants executed a baseless and facially invalid search 

warrant for the following two addresses: (1) 5966 Manistique, which is 

located in the City of Detroit and (2) 17268 Suffield Drive, which is located in 

Clinton Township. 

Illegal Raid at 5966 Manistique

15. Plaintiffs Russell I, Marie, and Jasmine were present at the Manistique 

address when the illegal search occurred. 

16. Defendants failed to “knock and announce” and instead kicked in the door and 

rushed into the home with their guns drawn and were ready to shoot. 

17. No reasonable officer could have found exigent circumstances to justify 

noncompliance with the knock and announce rule. 

18. At the time of the raid, Plaintiff Russell I had just been released from the 

hospital after sustaining second degree burns over 60% of his body and had 

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bandages covering his body which were clearly visible to anyone who looked 

at him. 

19. It was obvious to any person looking at Plaintiff Russell I, that he suffered 

from a serious and painful medical condition, requiring that he be treated 

gently and with care. 

20. Despite Plaintiff Russell I’s obviously fragile physical condition, Defendants 

forcefully grabbed him and threw him to the floor with their guns pointed 

directly at him. 

21. Plaintiffs Marie and Jasmine were also told not to move and had guns pointed 

at them during the approximately thirty (30) minute raid. 

22. Defendants then told Plaintiff Jasmine that she was being sent to college on 

“crack money” and that her parents were like the criminals “Bonnie & Clyde.” 

23. Defendants illegally searched the house and ultimately stole a box of insulin 

medication and related supplies from the basement, which were never 

returned. 

24. Upon information and belief, no illegal items were found in the home. 

25. Within a month after Defendants’ unlawful and illegal actions occurred, 

Plaintiff Marie (who suffered from diabetes and cancer) suffered a stroke. 

Illegal Raid at 17268 Suffield

26. Plaintiffs Russell II and Felicia were present at the Suffield address when the 

illegal raid occurred. 

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27. Defendants failed to “knock and announce” and instead kicked in the door and 

rushed into the home, even though there were no exigent circumstances 

preventing Defendants from “knocking and announcing.” 

28. No reasonable officer could have found exigent circumstances to justify 

noncompliance with the knock and announce rule. 

29. With guns drawn on them, Defendants ordered Plaintiffs to the floor. 

30. During the illegal raid, Defendants tore up the home, broke doors, broke 

locks, and otherwise made a mess of the home. 

31. Defendants also tore out insulation from the ceiling and the attic and tore apart 

the furnace. 

32. During the illegal search, Plaintiffs Russell II and Felicia were detained and 

Russell II was asked if his name was “Black” to which he said “No.” 

33. When Plaintiff Russell II said he was not “Black,” Defendants then began to 

question him as to whether he knew anyone named “Black,” to which Plaintiff 

Russell II responded that he did not. 

34. Defendant Jones then asked Plaintiff Russell II where the 15 “keys” (kilos) of 

cocaine and the $300,000.00 in cash was located, to which Plaintiff Russell II 

said he had no knowledge of such items. 

35. Defendant Jones repeatedly threatened Plaintiff Russell II and told him not to 

get a lawyer, because of he did, Defendant Jones would ensure that no one 

would help Plaintiff Russell II. 

36. Plaintiffs Russell II and Felicia were forced to the Redford Township Police 

Department even though they were not charged with a single crime. 

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37. Plaintiff Russell II was illegally detained for approximately five (5) days and 

Plaintiff Felicia was illegally detained for one (1) day without being allowed 

to make a telephone call or contact an attorney. 

38. The Search Warrants used to search the above-referenced addresses were 

facially invalid, overly broad and generic, and not based on recent and/or 

credible information. 

39. During the searches of the addresses listed above, Defendants exceeded the 

scope of the Search Warrant and unlawfully confiscated Plaintiffs’ personal 

property. 

40. For example, Defendants illegally seized a 1997 Cadillac and other vehicles, 

along with various pieces of jewelry, a wedding ring, cameras, handheld 

electronic video games (play stations), cellular telephones, and other items not 

listed in the Search Warrants. Some of these items still have not been 

returned to Plaintiffs. 

41. The Search Warrants were general and nonspecific and permitted Defendants 

to take “any items obtained through the sale of controlled substances” and 

“valuables derived from the sale of controlled substances.” 

42. Defendants clearly exceeded the scope of the Search Warrants and took 

personal property they should not have taken. 

43. Upon information and belief, details regarding the Confidential Informant’s 

(“CI”) criminal history, and use by law enforcement, as well as his/her 

success/failure rates, were not made known to the magistrate. 

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44. Defendants falsely arrested and imprisoned Plaintiffs by illegally restricting 

their freedom of movement and by holding them at gunpoint and detaining 

them at the Redford Township Police Department. 

45. That Defendants seized Plaintiffs’ property without legal cause or purpose. 

46. Plaintiffs suffered injuries and damages as a result of Defendants’ intentional, 

reckless, egregious, and otherwise unlawful acts. 

47. After spending approximately five (5) days at the Redford Police Department, 

Plaintiff Russell II was released and no charges were brought against him. 

48. Subsequent to the May 2nd raid and his release, Plaintiff Russell II requested 

that Defendants return all of his property which was illegally taken. 

49. Plaintiff Russell II repeatedly complained to the Redford Township Police 

Department about the illegal seizure of the personal property and the illegal 

searches Defendants had conducted. 

50. Plaintiff Russell II hired an attorney to assist with the return of his wife’s 

wedding ring which Defendants refused to return without any justification 

whatsoever. 

51. Once Plaintiff Russell II began to pressure Defendants and hired an attorney 

to have his wife’s wedding ring returned, Defendants retaliated against him 

and filed bogus federal criminal charges against him. 

52. On November 8, 2007, Defendant Woodall was responsible for initiating a 

frivolous and retaliatory criminal complaint against Plaintiff Russell II in the 

United States District Court for the Eastern District of Michigan (Case No. 

07-30517). 

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53. An arrest warrant was subsequently issued against Plaintiff Russell II on 

December 18, 2007. 

54. However, on January 8, 2008, the United States of America filed a Motion to 

Dismiss the Complaint Without Prejudice because at the time the Complaint 

was filed, (1) there was not sufficient evidence to establish guilt beyond a 

reasonable doubt; (2) a full and complete investigation had not been 

conducted; and (3) there was doubt as to whether a criminal prosecution was 

in the public interest. 

55. On January 9, 2008, the criminal complaint against Plaintiff Russell II was 

dismissed without prejudice. 

56. Defendants still have not returned the wedding ring they illegally seized on 

May 2, 2007. 

57. As a result of Defendants’ intentional and unlawful acts, Plaintiffs suffered 

injuries and damages. 

COUNT I

VIOLATION OF THE FOURTH AMENDMENT

42 U.S.C. § 1983—EXCESSIVE FORCE

58. Plaintiffs reallege and incorporate by reference each and every paragraph of 

this Complaint as though fully set forth herein. 

59. The individually-named Defendants were at all times mentioned herein acting 

under color of law and within the course and scope of the employment. 

60. As a result of the conduct complained of herein, Plaintiffs suffered a 

deprivation of clearly established rights protected and secured by the Fourth 

and Fourteenth Amendments to the United States Constitution and by other 

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laws, including but not limited to, the right to be free from a deprivation of 

liberty, property, bodily security and integrity without due process of law, and 

the right to be free from unreasonable searches and seizures. 

61. Defendants violated Plaintiffs’ clearly established and federally protected 

rights by using excessive and unreasonable force against Plaintiffs and/or 

failed to intervene and stop the excessive and/or unreasonable use of force. 

62. Defendants’ acts were at all times intentional, objectively unreasonable, 

reckless, and/or grossly negligent, which was in violation of Plaintiffs’ clearly 

established rights under the Fourth and Fourteenth Amendments to the United 

States Constitution. 

63. As a result of Defendants’ violation/deprivation of Plaintiffs’ constitutional 

rights, Plaintiffs have a viable claim for compensatory and punitive damages 

pursuant to 42 U.S.C. § 1983, together with costs, interest, and attorney fees 

pursuant to 42 U.S.C. § 1988. 

COUNT II

VIOLATION OF THE FOURTH AMENDMENT

42 U.S.C. § 1983—ILLEGAL SEARCH AND SEIZURE

64. Plaintiffs reallege and incorporate by reference each and every paragraph of 

this Complaint as though fully set forth herein. 

65. That the Fourth Amendment to the United States Constitution establishes that 

Plaintiffs have the right to be free from the deprivation of life, liberty, and 

bodily security without due process of law and to be free from unreasonable 

searches and seizures and excessive force. 

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66. At all material times, Defendants acted under color of law and unreasonably 

when they violated Plaintiffs’ Fourth Amendment rights when they falsely 

arrested and falsely detained Plaintiffs without probable cause or exigent 

circumstances. 

67. At all material times, Defendants acted under color of law and unreasonably 

when they violated Plaintiffs’ Fourth Amendment rights when they executed a 

facially invalid Search Warrant and/or blatantly exceeded the scope of it. 

68. Defendants violated Plaintiffs’ rights when they took property which 

exceeded the scope of the Search Warrant, some of which has never been 

returned. 

69. Defendants acted unreasonably and failed in their duties when they falsely 

arrested/detained/seized Plaintiffs without considering the totality of the 

circumstances. 

70. Defendants acted under color of law and are not entitled to qualified immunity 

because they violated Plaintiffs’ clearly established Fourth Amendment right 

to be free from unreasonable searches and seizures. 

71. Defendants’ illegal and unconstitutional acts were the direct and proximate 

cause of Plaintiffs’ deprivation of their constitutional rights. 

72. Due to Defendants’ actions, Plaintiffs’ Fourth Amendment rights were 

violated and pursuant to 42 U.S.C. § 1983, Plaintiffs respectfully requests this 

Honorable Court to award exemplary, compensatory, and punitive damages 

plus costs, interest, and attorney fees as set forth in 42 U.S.C. § 1988. 

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COUNT III

VIOLATION OF THE FOURTH AMENDMENT

42 U.S.C. § 1983 MALICIOUS PROSECUTION

73. Plaintiffs reallege and incorporate by reference each and every paragraph of 

this Complaint as though fully set forth herein. 

74. At all material times herein, Defendants charged Plaintiff Russell II with 

bogus crimes and instituted criminal proceedings against him which 

concluded in his favor. 

75. As stated above, Defendants had no actual knowledge or probable cause to 

believe that the charges brought against Plaintiff Russell II would succeed and 

acted unreasonably when they initiated a malicious prosecution of Plaintiff 

Russell II in which the charges were dismissed. 

76. Defendants failed to properly and thoroughly investigate, they manufactured 

probable cause, lied, and wrongfully initiated criminal proceedings against 

Plaintiff Russell II. 

77. Defendants were the initiators of Plaintiff Russell II’s wrongful prosecution 

by unlawfully arresting him and charging him with bogus crimes, thereby 

causing damages. 

78. Defendants knew that they falsely and recklessly built a case against Plaintiff 

Russell II and this exemplified their callous indifference to his life and liberty. 

79. Defendants’ actions were the direct and proximate cause of Plaintiff Russell 

II’s malicious prosecution, which is violative of his Fourth Amendment rights. 

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80. Pursuant to 42 U.S.C. § 1983, Plaintiffs respectfully request that this Court 

award Plaintiff exemplary, compensatory, and punitive damages, plus costs, 

interest, and attorney fees as set forth in 42 U.S.C. § 1988. 

COUNT IV

42 U.S.C. § 1983

VIOLATION OF THE FIRST AMENDMENT 

81. Plaintiffs reallege and incorporate by reference each and every paragraph of 

this Complaint as though fully set forth herein. 

82. At all material times herein, Defendants were acting under color of law, 

within the course and scope of their employment, in both their individual and 

official capacities, and owed Plaintiffs the duty to avoid a violation of their 

constitutionally guaranteed civil rights. 

83. 42 U.S.C. § 1983 imposes civil liability against a person who acts under the 

color of state law to deprive another of the rights, privileges, or immunities 

secured by the Constitution and other laws. 

84. The First Amendment to the United States Constitution protects a citizen’s 

right to free speech. 

85. Plaintiff Russell II repeatedly complained about the illegal seizure of his 

property members of the Redford Township Police Department. 

86. Plaintiff Russell II repeatedly complained that Defendants had no right to take 

his personal property, especially the wedding ring. 

87. Plaintiff Russell II’s complaints about Defendants violating his civil rights and 

breaking the law were matters of public concern. 

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88. At the time Plaintiff Russell II made such complaints to the Redford 

Township Police Department about the illegal search and seizure of his 

property, he was engaged in activity protected by the First Amendment of the 

United States Constitution. 

89. As a result of Plaintiff Russell II’s protected speech, a bogus criminal 

complaint was filed against him; the complaint was ultimately dismissed. 

90. Defendants would not have taken adverse actions against Plaintiff Russell II 

had he not exercised his constitutionally protected right to speak with regard 

to issues of public concern. 

91. Defendants’ conduct was designed to silence Plaintiff Russell II and prevent 

further complaints concerning speech of public concern in which such conduct 

would chill and prevent an ordinary person from continuing in the exercise of 

speech. 

92. Defendants’ conduct violated Plaintiff Russell II’s constitutional rights and 

the individual Defendants are not entitled to qualified immunity with regard to 

their unlawful actions. 

93. That as the direct and proximate cause of Defendants’ actions, Plaintiff 

Russell II suffered and continues to suffer injuries and damages. 

94. As a result of the unlawful conduct complained of herein, Plaintiffs suffered a 

deprivation of clearly established rights protected and secured by the First and 

Fourteenth Amendments to the United States Constitution and by other laws, 

including the right to free speech and the right to be free from retaliation for 

exercising the right to free speech. 

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95. As a further result of Defendants’ deliberate and intentional acts in violating 

Plaintiffs’ constitutional rights, they have a viable claim for compensatory and 

punitive damages pursuant to 42 U.S.C. § 1983, together with costs, interest, 

and attorney fees pursuant to 42 U.S.C. § 1988. 

COUNT V

VIOLATION OF THE FOURTH AMENDMENT

42 U.S.C. § 1983—FAILURE TO KNOCK AND ANNOUNCE

96. Plaintiffs reallege and incorporate by reference each and every paragraph of 

this Complaint as though fully set forth herein. 

97. That the Fourth Amendment to the United States Constitution establishes that 

Plaintiffs have the right to be free from the deprivation of life, liberty, and 

bodily security without due process of law and to be free from unreasonable 

searches. 

98. At all material times, Defendants acted under color of law and unreasonably 

when they violated Plaintiffs’ Fourth Amendment rights and illegally entered 

Plaintiffs’ homes without knocking or announcing their presence or allowing 

any reasonable time for Plaintiffs to respond. 

99. Defendants were under the statutory obligation to knock and announce their 

presence pursuant to Mich. Comp. Laws § 780.656. 

100. Defendants acted unreasonably and failed in their duty to act lawfully when 

they illegally entered Plaintiffs’ homes without knocking or announcing their 

presence and purpose, and to give Plaintiffs a reasonable amount of time to 

respond. 

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101. Defendants acted under color law and are not entitled to qualified immunity 

because they violated Plaintiffs’ clearly established Fourth Amendment rights. 

102. Defendants’ illegal acts were the direct and proximate cause of Plaintiffs’ 

deprivation of their Fourth Amendment rights. 

103. Due to Defendants’ actions, Plaintiffs’ Fourth Amendment rights were 

violated and pursuant to 42 U.S.C. § 1983, Plaintiffs respectfully request this 

Honorable Court to award exemplary, compensatory, and punitive damages 

plus costs, interest, and attorney fees as set forth in 42 U.S.C. § 1988. 

COUNT VI

REDFORD TOWNSHIP CONSTITUTIONAL VIOLATIONS

104. Plaintiffs reallege and incorporate by reference each and every paragraph of 

this Complaint as though fully set forth herein. 

105. Defendant Redford Township acted recklessly and/or with deliberate 

indifference when it practiced and/or permitted customs, policies, and/or 

practices that resulted in constitutional violations to Plaintiffs. 

106. That these customs, policies, and/or practices included but were not limited to 

the following: 

a. Failing to train and/or supervise its officers so as to prevent violations 

of citizens’ constitutional rights; 

b. Failing to supervise, review, and/or discipline officers; 

c. Failing to supervise, review, and/or discipline police officers whom 

the Township of Redford knew or should have known were violating 

or were prone to violate citizens’ constitutional rights, thereby 

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permitting and/or encouraging its police officers to engage in illegal 

conduct; 

d. Failing to control and/or discipline police officers known to harass, 

intimidate, and/or abuse citizens; 

e. Failing to train and/or supervise police officers regarding the legal 

execution of search warrants; 

f. Failing to train police officers and/or failing to institute 

policies/procedures regarding falsification of evidence; 

g. Failing to train and/or supervise its police officers regarding the use of 

excessive force; 

h. Having a custom, policy, and/or practice of falsely arresting and/or 

illegally detaining citizens. 

107. Defendants’ conduct was so reckless as to demonstrate a substantial lack of 

concern for whether an injury resulted. 

108. Defendants’ deliberately indifferent acts and/or omissions were the direct and 

proximate cause of Plaintiffs’ injuries and damages. 

109. Plaintiffs have a viable claim for compensatory and punitive damages 

pursuant to 42 U.S.C. § 1983, together with costs, interest, and attorney fees 

pursuant to 42 U.S.C. § 1988. 

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WHEREFORE, Plaintiffs respectfully request that this Honorable Court enter an 

award in their favor and against Defendants in an amount in excess of Seventy-Five 

Thousand Dollars ($75,000.00) exclusive of costs, interest, and attorney fees. 

 Respectfully Submitted, 

 CHRISTOPHER TRAINOR & ASSOCIATES 

 By: s/ Shawn C. Cabot

 CHRISTOPHER J. TRAINOR (P42449) 

 SHAWN C. CABOT 

 Attorney for Plaintiffs 

 9750 Highland Road 

 White Lake, MI 48386 

 (248) 886-8650 

 shawn.cabot@cjtrainor.com

Dated: October 26, 2009 

CJT/scc 

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UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF MICHIGAN 

SOUTHERN DIVISION 

RUSSELL MARCILIS II, FELICIA MARCILIS, 

JASMINE MARCILIS, RUSSELL MARCILIS I, 

and MARIE MARCILIS, 

 Plaintiffs, 

v. CASE NO: 2:09-cv-11624 

 HON: LAWRENCE P. ZATKOFF 

 MAG. VIRGINIA M. MORGAN 

REDFORD TOWNSHIP, BRIAN JONES, ERIC WOODALL, 

ERIC GILLMAN, JOHN BUTLER, KEVIN JEZIOROWSKI, 

WILLIAM HAND, BRAD BOYLE, DAVE LIVINGSTON, 

CHRIS RICHARDSON, and OTHER UNNAMED OFFICERS, in their individual 

and official capacities, 

 Defendants. 

_______________________________________________________________________/ 

CHRISTOPHER TRAINOR & ASSOCIATES CUMMINGS, McCLOREY, DAVIS 

CHRISTOPHER J. TRAINOR (P42449) & ACHO, P.L.C. 

SHAWN C. CABOT (P64021) JEFFREY R. CLARK, (P33074) 

Attorneys for Plaintiffs ANNE M. McLAUGHLIN (P40455) 

9750 Highland Road Attorneys for Defendants 

White Lake, MI 48386 33900 Schoolcraft Road 

(248) 886-8650 Livonia, MI 48150 

Shawn.cabot@cjtrainor.com (734) 261-2400 

_______________________________________________________________________/ 

DEMAND FOR TRIAL BY JURY

 

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NOW COME Plaintiffs, by and through their attorneys, CHRISTOPHER 

TRAINOR & ASSOCIATES, and hereby demand a trial by jury for the above-captioned 

matter. 

 Respectfully Submitted, 

 CHRISTOPHER TRAINOR & ASSOCIATES 

 By: s/ Shawn C. Cabot

 CHRISTOPHER J. TRAINOR (P42449) 

 SHAWN C. CABOT (P64021) 

 Attorney for Plaintiffs 

 9750 Highland Road 

 White Lake, MI 48386 

 (248) 886-8650 

 shawn.cabot@cjtrainor.com

Dated: October 26, 2009 

CJT/scc

PROOF OF SERVICE

I hereby certify that on October 26, 2009, I electronically filed the foregoing paper with the Clerk of the Court using 

the ECF system which will send notification of such filing to the following: Jeffrey R. Clark, and Anne M. 

McLaughlin and I hereby certify that I have mailed by United States Postal Service the paper to the following nonECF participants: None. 

s/ Shawn C. Cabot (P64021) 

Christopher Trainor & Associates 

9750 Highland Road 

White Lake, MI 48386 

(248) 886-8650 

shawn.cabot@cjtrainor.com

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