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IN THE UNITED STATES DISTRICI COURT

03327-049

(Inmate Number)

Walter Norton

(Name of Plaintiff)

USP Canaan

PO Box 300

(Address of Plaintift)

Waymart,PA 18472

/ 7

(Case N ber)

COMPLAINT

vs.

Cross Border Initiative Task

Force(CBI), MSP Essex County

Drug Task Force, Nashua Police

(Names of Defendants)

TO BE FILED UNDER

I. Previous Lawsuits

X 42 U.S.C. § 1983 - STATE OFFICIALS

X 28 U.S.C. § 1331 - FEDERAL OFFICIALS

A. If you have filed any other lawsuits in federal court while a prisoner please list the caption

and case number including year, as well as the name of the judicial officer to whom it was

assigned:

NONE

II. Exhaustion of Administrative Remedies

A.. Is there a grievance procedure available at your institution?

X Yes No

B. Have you filed a grievance concerning the facts relating to this complaint?

Yes X No

If your answer is no, explain why not Th i s

in connection with my arrest.

is about officers conduct

C. Is the grievance process completed? Yes X No

Case 1:06-fp-00477 Document 1 Filed 12/21/06 Page 1 of 3
III. Defendants

(In Item A below, place the full name of the defendant in the first blank, his/her official position in

the second blank, and his/her place of employment in the third blank. Use Item B for the names,

positions and places of employment of any additional defendants.)

A. Defendant Special Agent Michael O'Shaughnessy is employed

as Special Agent at Cross Border Initiative -task forc

B. Additional defendants Robert Kew, Glen Coletti, Calice Couchman,

Kevin Frye, James Flaherty, Frank Waterman, Marcos Chavez, Brian

Proulx, Jason Steiner, Terry Hanson, William Canty, Stephen

Gondella, Mark Blanchard, Mark Rivet, Sean Richards, William

Moore.

IV. Statement of Claim

(State here as briefly as possible the facts of your case. Describe how each defendant is involved,

including dates and places. Do not give any legal arguments or cite any cases or statutes. Attach

extra sheets if necessary.)

1. On January 23, 2004 I was arrested by a joint Federal and State

drug task force. During my arrest, as I was lying on the ground,

I was physically assaulted by several memebers of the joint task

force. The assault included punches and kicks to my face as well

as stomping my head into the concrete and several blows to my

b ody. The police used excessive force and brutality and I was

n ever charged with resisting arr e st. Therefore I was in compliance with the orders of the police and did not pose any threat

or danger to the officers.

3.

2

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V. Relief

(State briefly exactly what you want the court to do for you. Make no legal arguments. Cite no

cases or statutes.)

Monetary damages for the sum of 1. 5 million U.S.

dollars for the continued pain and suffering that the physical

abuse has caused as well as the mental anguish and punitive

damages . This abuse has caused me limited movement in my left

hand due to the fact of the officers using excessive force when

applying the zip-ties(plastic hand cuffs). I also suffered severe

headaches because of the constant blows to the head and I also

received a black eye from the brutality.

2.

3.

Signed this 17 day of December 200 6

I declare under penalty of perjury that the foregoing is true and correct.

December'17, 2006

(Date) (Signature of Plaintiff)

3

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