Plaintiffs,

eoe i nst

THE CITY OF NEWARK/

JOHI\I DOE 1- 1 0

1n.=rnoq ]-rainrr fir-1- i.l_ inrrq\

\-rqfrrvu vvrrrY !!v9r9rvuv/

LAW OFFICES OF

o'KEKE & ASSOGIATES, P.C.

ONE GATEWAY CENTER, SUITE 2600

NEWT{RK, NJ, 07102

PHONE: (973\ 799-8592

i:"ir?'-::Ti'i: --xGEORGE RAMIREZ,

JOSi]UA RUI Z

: IINITED STATES DISTRICT COI,RT

: DISTRICT OF NEW JERSEY

Defendant (s)

CASE No. :

CIVIL ACTION

COMPI.AINT

PLAINTIFFS DEI'{A}ID

TRIAL BY JURY

TAKE NOTICE, the Plainti ffs, George Ramirez and Joshua

Prri z ]roro] t\qral rrv-*Jy appear in this action by their attorney, Adanna U -

Tlrrr^r,rna I 'i F.scr - of f he Law Of f ices of O' keke & Associates, P. C. , vYvY'Jrrqf I I DJ\1 . 

, 

v! ur.

and demands that al-I papers be served upon her, dL the address

be1cw, in this matter.

Plaintiffs, George Ramirez and Joshua Ruiz, by therr

etl_ quuvLLLvf orne\/ Adanna U. Ugwonali, Esq., of the Law Offices of O'keke

, 

L

& Associates, compiaining of the defendants, The City of Newark,

and unknown police officers collectively referred to as the

Defendants, upon information and bel-ief alleges as fol-l-ows:

NATURE OF THE ACTION

This is an actron at law to redress the deprivation o f

rights secured to the plaintiffs under color of statute,

oroinance, regulation, custom, and or to redress the

deprivation of rights, privileges, and immunities secured

to the plaintiffs by the Fourth, Fifth and Fourteenth

Amendments to the Constitution of the United States, and b y

Ti1le 42 U. S. C. S 1983 land S 19851 , Iand arising under the

Iaw and statutes of the State of New Jerseyl .

Page I

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This rs an action to further seek compensation for the

serious and permanent personal in;uries sustained by the

ptaintiff, as a result of the negligence of the defendants,

perpecraced whrle said defendant police officers were i n

the process of illegally and unlawfully arresting

pla int i ff .

JT'RISDICTION

The jurisdiction of this Court is invoked under 28 U'S'C'

51343 ( 3 ) , 

this being an action author tzed' by law to redress

rhc rlenri rrztion of rights secured under color of state and

ul rv vv,y! r v r

city 1aw, Statute, ordinance ' regulation, custom and usage

of a right, Privi lege and immunity secured to the

nt a i nr i ffs by the Fourteenth Amendment to the Constitution

.v'*

of the Unrted States. Jurisdiction of this court exist's

pursuant to 42 USC S1 983 and under the Fourth, Fifth, and

Fourteenth Amendments to the United States Constitution.

All causes of actj-on not relying exclusively on the

aforementroned federal causes of action as a basis of this

Court's jurisdiction are based on the Court's supplemental

;urisdiction pursuant to 28 U.S.C. S1367 to hear state law

Causes of action. The events, parties , Lransactions, and

inj uries that form the basis of plaintiff' s federal claims

are ioentical to the events, parties, transactions, and

inj uries that form the basis of plaintiff' s claims under

app,licable State and CitV laws.

As the deprivation of rights complained of herej-n occurred

within the District of New Jersey, venue is proper in this

district pursuant to 28 U. S. C. SS1391 (b) and (c) .

PARTIES

Plaintiffs reside in Newark,

of the State of New Jersev.

De f- endant s John Doe and Jane

police officers for the CitY

of state law. TheY are being

and official capacitv.

New JerseY and are residents

municipality in the

Doe 1 though 10 are unknown

of Newark, acting under color

sued in both their individual

The Defendant, City o f Newa r k i s

PageZ

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State of New

Of f -Lcers .

,Torqorr :nd omt)l orrs \JgrJs)/ qIls vrlrl/+vJv the De fendant s Po I i ce

1 0

FACTUAI, ALLEGATIONS

COMMON TO ATL CAUSES OF ACTION

On or about June 3, 2OOg, dL approximatefy 4:00PM'

defendants Police Officers, employed with the Newark City

police Department and assigned to the Arh Precinct, without

probable cause and/or justification, arrested the

pla inti ffs near or about Montcla ir Avenue near Parker

Street, in Newark, New Jersey, located in Essex County'

said Arrest was made with no reason and with the sole

intent of intimidati.g, harassl-ng and assaulting the

plainti ffs .

prior to and after effecting the illegal arrest against the

plaintiff. Plaintiffs were in a vehicle on their way t o

pick up a mutual friend. As they proceeded on Mont clair

Arranrra naa r parker Street i-n Newark, New Jersey def endant

f1 V CIIL.Ig ITEA

officers swarmed ptaintiffs' vehicle with guns drawn ' A s

nt a i nf i ffs exited the vehicle Plaintiffs were grabbed

vrq!rr9r! ! v

witfrout probable cause by def endant of f icers ' sl-ammed o n

the ground and placed in handcuffs.

During the entire ordeal, plaintiffs repeatedly enquired a s

.t- o rrhrr f herz were he'i n,^r h:rassed, dssaulted and arrested but

L\-' yvlry u1-tcy vYg! I vvJrrY rrs! s

fhev recei ved no response. Plaintiffs were then taken t o

2"c precinct on 1 Lincoln Avenue in Newark and placed rn a

cel- I f or several- hours without being booked. That

notwithstanding being told by the ptaintiffs that they were

not the perperrarors that the defendant off icers were

looking for, the defendant officers continued with the

unl-awful arrest of the plaintif f . Thereaf ter Plaintif f s

were transported to the Newark Central Booking on Green

Street in Newark where they were held for four to five days

bef'ore they were brought before a 1udge. Approximately

thirteen ( 1 3 ) months Iater, plaintiffs were released and

the matter dismissed by the Superior Court of New Jersey.

Plaintiffs had and still have no knowledge of why they were

arrested or beaten up so badly by the defendant officers.

That during the entire ordeal, ptaintiffs were never read

their Miranda rights, were denied the right to request for

an attorney and/or cal-} any person to inform them of their

arr.est.

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1 1

T 2

1 3

L 4

1 5

L 6

I 1

1 B

That while in the custody of the Essex County Department o f

Corrections plainti f f s were unl-awf uIly assaulted by one o f

the inmates. Plaintiff George Ramirez was hit upon the

head violently and repeatedly by an inmate, said iniuries

were given required medical attention thereafter.

That even though the defendant police officers knew, o r

should have known based on the facts that no crime had been

r-ommi tterl - they stiIl proceeded to unlawfully arrest,

vvlrurl+ u uvv,

imprison I assault and incarcerate plaintiffs I ust t o

intimidate plainti ffs .

That at no time prior to and/or during the arrest was any

investigation conducted by the defendant officers t o

j ustify the arrest of the plaintiffs .

On JuIy J, 2OLO, the ptaintiffs served the City of Newark

with a Notice of Clarm.

At no time did ptaintiffs commj-t any offense against the

Iaws of City of Newark and or State of New Jersey for which

an arrest may be lawfully made. At no time drd the

nl a i nf i ffs commit any illegal acts , oT engage in any

,v -*

conduct which in any way lustified the brutal and unlawful

actions of the police.

As a drrect

trlrint'iff<

_yrqrrruf ! ! v

i nnl,.rl'i nrr rrrv ! sv!rJY

ni chj-m:roq

r r r Y 

r r ulllq L v r f

-n^nf -',''=L

vvvvrv srrY\

and proximate result of defendants' actrons ,

suf f ered and cont j-nues to suf f er inj uries,

but not limited to emotional distress,

panic attacks, mental anguish and unwarranted

bouts some or all of which may be permanent.

1 9

The unlawful arrest of plainti ffs, plaintiffs' wrongful

imprisonment because of defendants' knowledge of a lack o f

any legitimate cause or j ustification, were intentional,

mal icious , reckles s and in bad faith -

As a direct and proximate result of defendants' actions,

plaintiffs suffered and continue to suffer, mental- anguish,

renei- .i i- .i rre ^c-,nhn'l arri e aI and emOtionaf drStf eSS t

!vrrveref vv l-n]ury, psycnoro9rc

and physical pain and suffering' some or aIl of which may

1^^ -^^rt. J!/g yE rrrrarrsl

As a direct and proximate result of their unlawful

detention I assault, confinement, Plaintiffs have Iived i n

ter:ror of their attack, they continues to suffer from

nightmares / are fearful of going outside and when they see

Page 4

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2 I

2 0

2 2

i_hc nolir:e, they suffers various emotional attacks, i n

ulrv

:clcl'i t'i on - f herz hawe been unable to function normally which qvv-L uIvlIt errvJ

h:rre r-:ttsefl a Severe strain and breakdown in their personal

rru v v vqqJv\

relationships, in and outside of their respective homes'

As a direct and proximate result of defendant' s actions '

pla inti ffs were arrested and detained without j ust o r

probable cause.

As a direct and proximate result of defendants' act:-ons'

plaintiffs were deprived of rights, privileges and

immunities under the Fourth and Fourteenth Amendments to

the united states constitution and the laws of the city o f

Newark and the State of Newark.

Defendant City of Newark, as a matter of policy and

practice, has with deliberate indifference failed t o

nr.,ncrt rz sanctlon or disciptine police officers including

Ir!vIrv!rJ

the defendants in this case, for violations of the

constitutional rights of citizens, thereby causing police

officers including defendants in this case, to engage i n

unlawful conduct.

2 4

2 3 Defendant Citv of Newark, a s a matter of Policy and

practl-ce, has with deliberate indif f erence f ailed t o

sanction or discipline police officers including the

defendants in this Case, who are aware of and subsequently

conceal violations of the constitutional rights of citizens

by other police officers thereby causing and encouraging

police officers including defendants in this case, t o

engage in unlawful conduct.

The actlons of defendants, acting under color of State law,

r-ler,rirrecl nl:infiffs of their rights, privileges and \-tUF'!f vvV yt-rrrer!!v

immunities under the Iaws and Constitution of the United

states; in particular, the rights tc be secure in his

neY.sr)nancjnr-ner|rz-tobefreefromtheeXCessiveuseof

IJU! JVrr qrrv 

-yr vyv! u j I v v

force and from malicious prosecution, abuse of procesS, and

the right to due process.

By these actions, defendants have deprived plaintiffs o f

riqhts secured by the Fourth, Fifth, and Fourteenth

Amendments to the United States Constitution, in violation

aF A) T'T e a

\JI -Z- \J r rJ r v Section 1983

A written claim was filed upon the City of Newark, and

at Ieast six-months have elapsed since the service of the

2 5

2 6

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Notice of ctaim the claim has been neglected

21 . Thi:; action has been conmenced withrn one

days after the happening of the event upon

i a ]-r.r<od rJ vguvu.

AS A FIRST CAUSE OF ACTION:

42 U. S. C Section 1983-asainst

Plaintiffs hereby restates

complaint, dS though fullY set

Defendants Officers

or refused.

'A.r :nri ninofrr

y cal- aII\,t rrrrrv u i

which the clarm

f Lv v !

r1.-.i -

LIII> 2 B

2 9

pa r agraPhs

forth below

3 0

By detaining and imprisoning Pl-aintif f s, without

-,.of.i€ia-+--inn- nrohable cause or reaSonable Suspicion,

J |1D t-II-LUAL-L\-,/rrt Y.l-\-/L/(J

using excessi-ve force, and assaulting him, the Defendants'

offir-ers- ctenr.i rzecl Plaintiffs of rights, remedies/

\-/!!f VV!Jt svl/!!vv.+

nri rzi I er-res, and immunities guaranteed to every crtrzen o r

,y!rvf!vYuul

the United States, In violation of 42 U . S . C. Section 1 9B 3 ,

i nr-l rrr-li nr^r - but not limited to, rights guaranteed by the

f f lvf uvrrrv 

,

Fourth and Fourteenth Amendments of the United States

Constitution.

In addition, the Defendants officers conspired among

themsel-ves to deprive pfaintiffs of their constitutlonal

rights secured by 42 U. S . C. Section 1 98 3, and by the Fourth

and Fourteenth Amendments to United States Constitution,

and took numerous overt steps in furtherance of Such

-onsnirar:v- as set forth above. vvrruyr! qvJ | 4 v

The Defendants Officers acted under pretense and color o f

state law and in their indiviCual and official capacities

and within the scope of their respective employment a s

Newark Police Department Officers. Said acts by the

Defendants Officers were beyond the scope of their

j ur isdiction, without authority of l-aw' and in abuse o f

their powers, and said Defendants acted willfully,

kn.,tnrincrlrz. and with the Specific intent to deprive the r\rrv vY LLtY L 

J ,

Plaintrffs of their constrtutional- rights secured by 4 2

U . S . C. Section 1 98 3, and by the Fourth and Fourteenth

Amendments to the United States Constitution.

As a direct and proximate resul-t of the misconduct and

abuse of authority detailed above, Plaintiffs sustained the

damages herein before stated.

3 1

3 2

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3 3

3 4

3 5

3 6

AS A SECOND CAUSE OF ACTION:

New Jersev State Constitution, Art. 1 Section 1

plarntif f s hereby restate paragraph 1-31 of this compl-aint,

as though fully set forth below

Rrr r-lef : i n-i -^ :nA i'.nri son i no Plaintif f S, withOut prObable -Dy \.{ELd'III-LIlV all\.r -LItLy!-l-rvrrfrrY r

CauSe or reaSonable Suspicion, USrng excessive force, and

---.a,.rf-i-^ him- fhe Officers Defendants deprived Plaintiffs d)>dtl-L LIl19 rt-L]Ll.7 Lrrs \

nf r.irrh*- q romo4ioq rrrirri lcr-reo :nd irnmrrni.l- ies otlaI anteed L.J,!CILLE\.r-LEJTyr-LVIle9cDrcllI\,.-I.ILLJ'LLLIfl!U!vv

to every citi zer\ of the State of New Jersey by Article 1-,

Section 1 of the New Jersev Constitution '

In addition, the Defendants officers conspired among

themselves to deprive plaintiffs of their constitutional

rights secured by Article I, Section 1 of the New Jersey

Constitution, and took numerous overt steps in furtherance

of such conspiracy, ds set forth above.

The Defendants Officers acted under pretense and color o f

state law and. in their individual and official capacities

and within the scope of their respective employment a s

Newark Police Department Officers. Said acts by the

Defendants Officers were beyond the scope of their

j urisdiction, without authority of law, and in abuse o f

their powers, and said Defendants acted willfully,

knnrnli Jlrrv vY LLLY nei.l L rr- and with the specific intent to deprive the

I I

Plaintiffs of their constrtutional- rights secured b y

Article I, Section 1 of the New Jersey Constitution.

Defendants, their officers, attorneys, agents ' servants and

^-^ I

srlLv-L\., vsE- were responsibl-e f or Plaintif f s t deprivation o f

their state constitutional rights, Defendant City, d s

employer of each of the Officer Defendants, is responsible

for their wronqdoing under the doctrine of respondeat

superr-or.

As a direct and proximate result of the misconduct and

abuse of authority detailed above, plaintiffs sustained the

damaqes herein-before alleqed.

AS A THIRD CAUSE OF ACTION:

3 1

3 B

Assault and Battery--all Defendants

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3 9

4 0

4 2

A ?

A '

A J

4 6

plaintiffs hereby restaLes paragraph 7-31 o f

complaint, ds though futly set forth below

l-lrry.i nrv 1- hi - nari r-rrl I-lL.tI Jl19 LLrr> |.-iE! -L\.tu7

T^Tra\y1 r^rfrrl I rr ---1rrl J-arl

wr l,ll9]- t-lJ- -Ly d>Da\1 r LE\J7

f 1^; ^

LTl-LD

the Plaintiffs were unlawfully and

harassed, detained/ and threatened '

4 7

In physically assaulting, detainitg, handcuffrnq,

threateni^g, slammrng and intimidating plaintiffs ' the

Defendants Officers, acting in their capacities as Newark

PoI i-ce Department Of f icers, and within the scope of their

omntorrmenf - each commi-tted a willful, unlawful,

vrLLI/ .! v 

J 

rLtv r r e t

unwarranted, and intentional assault and battery upon

plaintiffs.

As a direct and proximate result of the misconduct and

abuse of authority detained above, Plaintiffs sustained the

damaqes hereinbefore stated.

AS A FOURTH CAUSE OF ACTrO!:

Fal-se Arrest and False Imprisonrnent--aIl defendants

Plaintiffs hereby restates paragraph I-40 of this

compl-aint, dS though fully set f orth bel-ow

The Defendants offi-cers wrongfully and illega11y detained,

and imprisoned the Plaintiffs.

The wrongful arrest and imprisonment of the Plaintiffs were

carrted. out without a valid warrant, without Plaintiffs'

-r)n sent - and without probable cause or reasonable vvrrvvrret

suspicion.

At alt relevant times, the Officers Defendants acted

forcibly in apprehenditg, detailing, and imprisoning the

Plainti ffs .

4 4

4 1 Thrnrrrrhnrrf f lIL vuYllVU U fhic Urf f J neriocl . the Plaintiffs

I/u! 

f vv,

r^lr^f)Trrrfrrl 

'l 

rz :nd t,ni''-+'i €'i -hl rz 

wrUr1!!u-L-L)/ detained, r dllLr t.lllJ l-t) L-L!rar-/-Ly

I i her1-rz- enr^l i mnri soned. -l-If/gL -I 

, 

qIfV II!L}/! auvrr

we re unl- awf uI I Y ,

rjcnri uvI/ rrecl of his

A Q o r

f U At l- of the foregoing occurred without any fault

nrr\\7n,^.:f inn -n 1_he neft Of the PIaintiffS.

vI \,/ v \-/\r'o, L l-\-/rl L/11 ulf u y q

49 . Defendants, their officers, agents / servants / and employees

Page 8

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5 0

raTAy^6: rFqr^)onsible f or plaintif f s t detention and imprisonment

vYv!\-

rt'rinrr t-h-i - ^orinrt nf time. Defendant City of Newark, a s Llurirrv LIr-LD y=r-'v\r ",-.,^:::'"'..,^tll^=.i"- 

- 

.i 'bre for employer of the Officers Defendants, is responsr

therr wrongdoing under the

The Defendants Officers acted with a knowing, wiIlful '

,.rrnf nn grOSSIy f eCkleSS, unlaWfUl, UnreaSOnabIe/

WctlIt,uIll

unconscionable, and ftagrant disregard of the Plaintiffs'

ri r-rhf s - nri rr.i I or^res - welf are/ and weIl-being and are guilty

! ryiIU\) t -LJr f v !f vYuu I

of ,.crrccri orrq ancl oross misconduct toward Plaintif f s .

v! vY!vY!vqu srrv

As a direct and proximate result of the misconduct and

abuse of authority detailed above, Plaintiffs sustained the

damases herein-before stated.

AS FOR A FrFTH CAUSE OF ACtroN:

Intentional- Infliction of Emotional Distress-all Defendants

5 1

5 2

5 3

The Plaintiffs hereby restates paragraph

compl-aint, dS though futly set f orth bel-ow '

The Defendants officers engaged in extreme

conduct, intentionally and recklessly

emotional distress to plaintiffs.

Pl-aintiffs' emotional

qrrv :nr-l nrr^lfessional lrfe .y- "

:nr-rrri qrrY q! sh ur r whi-ch were

malicious detention

Officers.

distress has damaged

because of the severe

inflicted through

and impri sonment b Y

I - lt, (, I

+l.-.; -

LII-L >

and outrageous

r-:rrsi vq sv rrrYno severe

.t- hei r raersonal- uIIvf ! .Y-'

*^^+-'l ^-i1-y It[t'rr Lo -L ya J - and

deliberate and

the Defendants

tr,4

5 5 Defendants, their officers, agents servants/ and employees

sible for the intentional infl-iction o fvYv!v !vvI,

emctional distress suffered by the Plaintiffs at the hands

of the Defendants Officers and security guards, defendant

ei.l-rz nf Ner^rerk- ^s emnlnrrer of the Officers, is responsible V-LLy \-/J- l\gVYq-1-J\, sJ vrtll/rvJv!

for their wrongdoing under the doctrine of respondeat

qrlY1 ari n r vsF/v

As a direct and proximate result of the misconduct' and

abuse of authority detailed above, Plaintiffs sustained the

damages herein-before stated.

5 6

AS A SIXTH CAUSE OF ACTION:

Page 9

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5 9

5 1

5 B

6 I

Negligent and Retentron

defendant Citv of Newark.

o f Emplorrment Services-against

Plaintiffs hereby restates paragraph

/-nmvr'l linf -- rl'.4'.nl-r frrIIrz qef uulltll-Ld,-LlIL, dJ Ll.LULr9rr fOfth beiOW. !urr-Ly !)su

1-56 of this

Upon information and belief, defendant City of Newark,

through the NEWARK PD, owed a duty of care to plaintiffs t o

prevent che phys rcal and rnental abuse sustained b y

plainti ffs .

rrrrnn i nfn.mation and belief , defendant City of Newark,

wF/vrr -LlrJ- \,/-L

through the NEWARK PD owed a duty of care to plaintiffs

because und.er the Same or simil-ar circumstances a

reasonable, prudent and careful person should have

:n+- in-i n:f^d that an injury to plaintiffs or to those In a o'lr LJ\-rIJa LE\

like situation would probablv result from this conduct'

Upon information and bel:-ef , def endant City of Newark, knew

or shoul-d have known through the exercise of reasonable

diligence that the Officers Defendants were not prudent and

were potentially dangerous.

Tlnon .i n f or:mation and belief , def endant City of Newark,

vf/vr

"Lgligence 

in hiring and retaining the officers Defendants

proximatefy caused Plaintiff's injuries.

Upon 1nformation and belief , because of the defendant's

City of Newark, negligent hiring and retention of the

aforementioned Officers Defendants, Plaintiffs incurred

signif icant and lasting injurj-es.

WHEREFORE, Plaintiffs respectfully

against the Defendants as follows:

ra.rlroqj- irrdt^tmenf ! cYL.rsJ u J 

qvYrtrvrr u

On the First Cause of Action against all the defendants,

compensatory and punitive damages in an amount to be

determined at triaI, and reasonable attorneys' fees and

costs under 42 U. S. C. Section t98B;

Cn the Second Cause of Action I against aII Defendants /

-r^lmnensatorrr d:macres in an amount to be determined a t

\-\-/ILLI/glrJ(l UV! J 

verLLqYvv

tri aI, and punitive damages against the officers Defendants

in an amount to be determined at trial;

De fendant s ,

Page 10

5 0

5 2

On the Third Cause of Action, :rr:inq1- qYsrrrv e

-l-l

Case 2:11-cv-01150-SDW-LDW Document 1 Filed 03/01/11 Page 10 of 11 PageID: 10
compensatory damages in an amount to be determined at

triaI, punitive damages against the Of f icers Def endants l-n

an amount to be determined at trial;

4 . On the Fourth Cause of Action , against all- Def endants,

compensatory damages in an amount to be determined a t

trial, punitive damages against the Officers Defendants i n

an amount to be determined at trial;

5 . On the Fifth Cause of Action , against aIl Defendants,

compensatory damages rn an amount to be determined a t

tri;rI, punitive damages against the Officers Defendants i n

an ;rmount to be determined at trial-;

6. On the Sixth Cause of Action , dgdinst the City of Newark,

compensatory damages rn an amount to be determined at

+-'i -'l . --..1

LJ- -L(aJ- r AIIL,t

j. Sucir other and further relief as this Court may deem

necessarv in the interest of j ustice .

Dated: March I, 20II

Newark, New Jersey

RespectfullY Submitted

O' keke & Associates, P. C .

.1 l : 1l lt ;i\

vl,l,lat,,.; L v.JL\-*

By:

One GatewaY Center, Ste. 2600

Newark, New JerseY 01I02

TeI. No.: (913) 199-8592

Page l1

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