anthony cowell (ac6348)

attorney at law

200 pope ave.

hamilton, nj 08619

phone (609)838-7992

attorney for plaintiffs

MELVIN RIVERA, EDISON SOTO, U.S. DISTRICT COURT 

EDNA RIVERA, CARLOS RIVERA, DISTRICT OF NEW JERSEY

MELISSA CORTES and MCF (a minor) CIVIL ACTION NO. 

and MCM (a minor),

TANYA ACEVEDO and TAM (a minor), 

GRICEL RIVERA and GRM (a minor), and COMPLAINT

DENISE BERRIOS and DBF (a minor),

 Plaintiffs, 

 v.

CITY OF TRENTON, 

DETECTIVE PEDRO PEREZ,

POLICE OFFICER MIGUEL A. ACOSTA,

POLICE OFFICER DARYL D. BERRY, 

DETECTIVE NOEL SANTIAGO,

DETECTIVE TARA STEFANO,

SERGEANT KOLODZIEJ,

DETECTIVE S. JOHNSON,

IRVING BRADLEY, JR.,

DOUGLAS H. PALMER,

and John Doe, a POLICE OFFICER

for the CITY OF TRENTON,

 Defendants. 

 

NATURE OF ACTION AND JURISDICTION

1. This is a civil action for damages brought pursuant to the 

United States Constitution and 42 U.S.C. § 1983 resulting from 

deprivations, under color of law, of the plaintiffs’ rights 

under the Fourth, Fifth, Sixth and Eighth Amendments to the 

United States Constitution.

1 ANTHONY COWELL, ATTORNEY AT LAW

ATTORNEY FOR THE PLAINTIFFS

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2. This Court has jurisdiction over these claims pursuant to 

Article III, Section 1 of the United States Constitution and 

28 U.S.C. §§ 1331, 1332 and 1343. This Court also has pendent 

jurisdiction to decide the intentional tort claims against the 

individual police officer defendants. The amount in 

controversy exceeds $10,000.00 excluding interest and costs.

3. A timely notice of claim was filed with the defendant City of 

Trenton.

4. Venue is properly established in this judicial district 

pursuant to 28 U.S.C. § 1391(B).

PARTIES

PLAINTIFF

5. Melvin Rivera is a citizen of the United States and a resident 

of the State of New Jersey.

6. Edison Soto is a citizen of the United States and a resident 

of the State of New Jersey.

7. Edna Rivera is a citizen of the United States and a resident 

of the State of New Jersey.

8. Carlos Rivera is a citizen of the United States and a resident 

of the State of New Jersey.

9. Melissa Cortes is a citizen of the United States and a 

resident of the State of New Jersey.

2 ANTHONY COWELL, ATTORNEY AT LAW

ATTORNEY FOR THE PLAINTIFFS

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10.MCF is a minor and the natural born child of Melissa Cortes. 

MCF is a citizen of the United States and a resident of the 

State of New Jersey.

11.MCM is a minor and the natural born child of Melissa Cortes. 

MCM is a citizen of the United States and a resident of the 

State of New Jersey.

12.Tanya Acevedo is a citizen of the United States and a 

resident of the State of New Jersey.

13.TAM is a minor and the natural born child of Tanya Acevedo. 

TAM is a citizen of the United States and a resident of the 

State of New Jersey.

14.Gricel Rivera is a citizen of the United States and a 

resident of the State of New Jersey.

15.GRM is a minor and the natural born child of Gricel Rivera. 

GRM is a citizen of the United States and a resident of the 

State of New Jersey.

16.Denise Berrios is a citizen of the United States and a 

resident of the State of New Jersey.

17.DBF is a minor and the natural born child of Denise Berrios. 

DBF is a citizen of the United States and a resident of the 

State of New Jersey. 

3 ANTHONY COWELL, ATTORNEY AT LAW

ATTORNEY FOR THE PLAINTIFFS

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DEFENDANT

18.The City of Trenton was at all times relevant to this lawsuit 

a governmental entity subject to suit, and was responsible for 

creating and implementing policies and practices that violated 

the federal and common law rights of the plaintiffs.

19.Detective Pedro Perez was at all times relevant to this 

lawsuit a police detective with the Trenton Police Department. 

The acts of Perez, which are the subject of this lawsuit, were 

outside the scope of his employment and constituted criminal, 

fraudulent, willful and malicious conduct. Upon information 

and belief, Perez is a citizen of the United States and a 

resident of the State of New Jersey.

20.Police Officer Miguel A. Acosta was at all times relevant to 

this lawsuit a police officer with the Trenton Police 

Department. The acts of Acosta, which are the subject of this 

lawsuit, were outside the scope of his employment and 

constituted criminal, fraudulent, willful and malicious 

conduct. Upon information and belief, Acosta is a citizen of 

the United States and a resident of the State of New Jersey.

21.Police Officer Daryl D. Berry was at all times relevant to 

this lawsuit a police officer with the Trenton Police 

Department. The acts of Berry, which are the subject of this 

lawsuit, were outside the scope of his employment and 

4 ANTHONY COWELL, ATTORNEY AT LAW

ATTORNEY FOR THE PLAINTIFFS

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constituted criminal, fraudulent, willful and malicious 

conduct. Upon information and belief, Berry is a citizen of 

the United States and a resident of the State of New Jersey.

22.Detective Noel Santiago was at all times relevant to this 

lawsuit a police detective with the Trenton Police Department. 

The acts of Santiago, which are the subject of this lawsuit, 

were outside the scope of his employment and constituted 

criminal, fraudulent, willful and malicious conduct. Upon 

information and belief, Santiago is a citizen of the United 

States and a resident of the State of New Jersey.

23.Detective Tara Stefano was at all times relevant to this 

lawsuit a police detective with the Trenton Police Department. 

The acts of Stefano, which are the subject of this lawsuit, 

were outside the scope of her employment and constituted 

criminal, fraudulent, willful and malicious conduct. Upon 

information and belief, Stefano is a citizen of the United 

States and a resident of the State of New Jersey.

24.Sergeant Kolodziej was at all times relevant to this lawsuit 

a police sergeant with the Trenton Police Department. The 

acts of Kolodziej, which are the subject of this lawsuit, were 

outside the scope of his employment and constituted criminal, 

fraudulent, willful and malicious conduct. Upon information 

5 ANTHONY COWELL, ATTORNEY AT LAW

ATTORNEY FOR THE PLAINTIFFS

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and belief, Kolodziej is a citizen of the United States and a 

resident of the State of New Jersey.

25.Detective S. Johnson was at all times relevant to this 

lawsuit a police detective with the Trenton Police Department. 

The acts of Johnson, which are the subject of this lawsuit, 

were outside the scope of his employment and constituted 

criminal, fraudulent, willful and malicious conduct. Upon 

information and belief, Johnson is a citizen of the United 

States and a resident of the State of New Jersey.

26.Irving Bradley, Jr. was at all times relevant to this lawsuit 

the Police Director of the Trenton Police Department. He was 

responsible for the recruitment, hiring, training, 

supervising, discipline, control and conduct of the 

aforementioned defendants. He was charged with promulgating 

the orders, rules, instructions, regulations, procedures, 

customs and policies of the Trenton Police Department, 

including but not limited to the laws concerning arrest, 

search, seizure and the appropriate use of force. He adopted, 

approved and permitted customs and practices that led to the 

deprivation of the plaintiffs’ civil rights. Bradley was 

responsible for setting the policies, practices and customs 

regarding investigations to identify and correct police 

misconduct of the kind alleged in this action. Bradley failed 

6 ANTHONY COWELL, ATTORNEY AT LAW

ATTORNEY FOR THE PLAINTIFFS

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to properly investigate the complaints alleging that the 

defendants had committed misconduct. Upon information and 

belief, Bradley is a citizen of the United States and a 

resident of the State of New Jersey.

27.Mayor Douglas H. Palmer was, at all times relevant to this 

lawsuit, the chief executive officer of the defendant City of 

Trenton. As such, Palmer was responsible for ensuring that 

the actions undertaken by the aforementioned defendants were 

consistent with law. At all times relevant to this lawsuit, 

Palmer had the power, right and duty to control the manner in 

which the aforementioned defendants carried out the objectives 

of their employment and to see that all orders, rules and 

regulations promulgated for the Trenton Police Department were 

consistent with law. Palmer permitted an environment in the 

Trenton Police Department that permitted the misconduct 

complained of herein, and a culture whereby defendants were 

permitted to violate plaintiffs’ civil rights with impunity. 

FACTS

28.On or about June 13, 2009, the plaintiffs were attending a 

baby shower at 295 Third St. in Trenton, New Jersey. The 

plaintiffs conducted themselves in an appropriate manner and 

in compliance with all laws and ordinances.

7 ANTHONY COWELL, ATTORNEY AT LAW

ATTORNEY FOR THE PLAINTIFFS

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29.Some of the plaintiffs, including Melissa Cortes and her 

minor children, Tanya Acevedo and her minor child, Carlos 

Rivera, Denise Berrios and her minor child, Edna Rivera and 

Edison Soto were inside the residence at 295 Third St.

30.Plaintiffs Carlos Rivera, Melissa Cortes and her minor 

children reside at 295 Third St.

31.At approximately 11:15 p.m., Carlos Rivera was sitting in the 

kitchen of his home. Melissa Cortes advised him that members 

of the Trenton Police Department, in uniform and under color 

of law, were raiding the house and were beating Edison Soto. 

Edison Soto can identify these defendants by sight.

32.Carlos Rivera entered the living room, where he witnessed two 

male police officers choking Edison Soto and punching him in 

the stomach. Carlos Rivera can identify these officers by 

sight.

33.Carlos Rivera also witnessed two female police officers, 

joined by another male police officer, hitting his mother, 

Edna Rivera, who was situated next to the stairs on the floor. 

The officers kicked Edna Rivera and used OC spray on her. 

Carlos Rivera can identify these officers by sight.

34.Carlos Rivera shouted to the defendant officers, “Why are you 

in my house beating and spraying my family with mace?”

8 ANTHONY COWELL, ATTORNEY AT LAW

ATTORNEY FOR THE PLAINTIFFS

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35.Another officer arrested Carlos Rivera, without probable 

cause and without a warrant, and pushed him up against the 

living room wall and put him in a choke hold while another 

officer punched him in the face. Another officer joined in 

and pulled Carlos Rivera’s hair. These officers also sprayed 

Carlos Rivera with OC spray. Carlos Rivera can identify these 

defendants by sight.

36.The defendant officers sprayed OC spray on Melissa Cortes and 

her minor children. Melissa Cortes can identify these 

defendants by sight.

37.The defendant officers used OC spray on Denise Berrios and 

her minor child. Denise Berrios can identify these defendants 

by sight.

38.The defendant officers used OC spray on Tanya Acevedo and her 

minor child. Tanya Acevedo can identify these defendants by 

sight.

39.The defendant officers used OC spray on Gricel Rivera and her 

minor child. Gricel Rivera can identify these defendants by 

sight.

40.The defendant officers beat Carlos Rivera as he attempted to 

protect the children from the beating and OC spray used upon 

them by the officers.

9 ANTHONY COWELL, ATTORNEY AT LAW

ATTORNEY FOR THE PLAINTIFFS

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41.The defendant officers arrested the adult plaintiffs and 

dragged them outside in handcuffs.

42.Once outside, the defendant officers continued to beat the 

adult plaintiffs while they were in handcuffs, and in the 

presence of the minor plaintiffs.

43.Outside the house, the defendant officers slammed Gricel 

Rivera’s head against a car.

44.Carlos Rivera advised the defendant officers that he suffers 

from asthma. In response, the defendant officers shot Carlos 

Rivera in the face with OC spray.

45.The defendant officers pushed Denise Berrios out of the 

residence. She tried to return to the home when she heard her 

her minor child, a plaintiff in this matter, cry out that the 

police were beating her. 

46.Denise Berrios tried to pull her minor daughter out a window. 

She advised the defendant officers that children were in the 

house and were being beaten and maced by the defendant 

officers. At this time, the minor child of Denise Berrios 

collapsed from being beaten and sprayed with OC spray by the 

defendant officers.

47.Defendant Stefano arrested Denise Berrios, pulled her hair, 

and said, “Bitch, now you’re going to jail!”

10 ANTHONY COWELL, ATTORNEY AT LAW

ATTORNEY FOR THE PLAINTIFFS

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48.Another defendant officer assaulted Denise Berrios by 

grabbing her hair, twisting her arm, and slamming her head 

against a wall.

49.Defendant Stefano addressed the adult female plaintiffs as 

“Spics” and “Puerto Rican bitches.”

50.While Denise Berrios and her minor daughter were handcuffed 

and secured in the police car, a defendant female officer 

pulled grabbed hanks of hair from them and shook their heads 

from left to right, causing pain and suffering.

51.Denise Berrios and her minor daughter suffered physical and 

emotional injuries as a result of the conduct of the 

aforementioned defendants.

52.Edna Rivera was inside the residence when the defendant 

officers raided the home. She observed the defendant officers 

choking and macing Edison Soto, and shouting, “Where are the 

drugs?” She then observed the defendant officers rush into 

the house and spray mace everywhere, including on the 

children, and beating everyone in their path.

53.Neither drugs nor contraband was were recovered in the house.

54.No drugs or contraband were found in the possession of the 

plaintiffs.

55.Edna Rivera tried to protect her grandchildren when the 

defendant officers grabbed her and threw her to the ground. 

11 ANTHONY COWELL, ATTORNEY AT LAW

ATTORNEY FOR THE PLAINTIFFS

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Edna Rivera screamed, “Stop, stop, these are my grandkids!” 

Defendants smashed her face against the ground and maced her 

in the face. She could not breathe.

56.The defendants transported Edna Rivera to headquarters, where 

she collapsed.

57.Edna Rivera suffered physical and mental injuries as a result 

of the conduct of the aforementioned defendants. 

58.Across the street from the residence, Melvin Rivera observed 

the defendant officers beating and macing his family. The 

children were screaming in pain from being beaten and maced. 

Melvin Rivera observed the officers slam an eight year old 

child onto the sidewalk.

59.Melvin Rivera advised defendant Perez, “Please stop, this is 

just a baby shower, stop beating and macing my family! These 

are just children and pregnant women!”

60.Defendant Perez responded, “Shut the fuck up or you’ll get 

arrested, too.” Melvin Rivera replied, “But there’s no reason 

for you to arrest me. I’m trying to tell you that the 

children are in danger, they are being maced and stomped on by 

the officers!”

61.Perez grabbed Melvin Rivera and arrested him while other 

officers stomped him to the ground, and kicked him in the 

head.

12 ANTHONY COWELL, ATTORNEY AT LAW

ATTORNEY FOR THE PLAINTIFFS

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62.In the presence of the children, an African American officer, 

also a defendant, pointed a shotgun at Melvin Rivera and 

Edison Soto who, at the time, were restrained in handcuffs.

63.Melvin Rivera suffered physical and mental injuries as a 

result of the conduct of the aforementioned defendants.

64.Melvin Rivera can identify these defendants by sight.

65.Melissa Cortes explained to the defendants that this was her 

home, and stated, “Why have you invaded my home and beat and 

maced my family!”

66.The defendants responded, “This is not Puerto Rico, we don’t 

owe you an explanation.”

67.A female defendant pushed Melissa Cortes on top of a fish 

tank. Another defendant grabbed Melissa Cortes’s minor child, 

and slammed him against the wall repeatedly.

68.A female defendant grabbed Melissa Cortes’s minor daughter, 

and slammed her face into the steps.

69.Another defendant ground his boot into the face of the minor 

child of Tanya Acevedo, in order to keep him on the ground. 

The minor child is two years of age.

70.Defendants then ripped the house apart in an apparent search 

for contraband. No contraband was recovered.

71.Defendants grabbed Tanya Acevedo and slammed her against the 

wall, pulled her hair and maced her. Defendants slammed her 

13 ANTHONY COWELL, ATTORNEY AT LAW

ATTORNEY FOR THE PLAINTIFFS

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on the couch, on top of several sleeping children, while 

spraying OC spray on her and the children.

72.She stated, “Please stop, why are you macing the children?” 

A defendant responded, “I don’t give a fuck, bitch.” Another 

defendant stepped on her minor child’s face with his boot. 

The minor child gasped for air as the officer again maced the 

child, blocking the child’s airway with his boot.

73.The minor child had been strapped into his car seat and had 

been sleeping when the officers raided the home.

74.Defendants arrested Tanya Acevedo, and placed her in the rear 

of a police vehicle. She screamed, “What about my child?” 

Defendant Stefano replied, “Shut up, bitch,” and OC sprayed 

her in the face, despite the fact that she was secured and in 

handcuffs in the back of the police car.

75.At the police station, Tanya Acevedo expressed her concern 

for her mother, Edna Rivera. Defendant Stefano responded, “I 

don’t give a fuck.” Another defendant told her, “Shut the 

fuck up, because I beat bitches, too.”

76.Tanya Acevedo suffered physical and mental injuries as a 

result of the conduct of the aforementioned defendants.

77.The aforementioned plaintiffs filed written complaints with 

the Trenton Police Department. No investigation was 

14 ANTHONY COWELL, ATTORNEY AT LAW

ATTORNEY FOR THE PLAINTIFFS

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undertaken. The Trenton Police Department never interviewed 

plaintiffs. 

78.The defendants City of Trenton, the Mayor, and the Police 

Director, through their failure to train the police officer 

defendants in the proper use of force and the law of arrest, 

search and seizure, their failure to supervise the defendant 

officers, and their failure to investigate the plaintiffs’ 

complaints, have established a policy and custom of allowing, 

condoning and not prosecuting the illegal acts of the 

defendant police officers which resulted in violations of the 

rights of the plaintiffs.

79.The police officer defendants, through their direct action in 

assaulting, falsely arresting, holding and charging 

plaintiffs, violated their rights under the Fourth, Fifth, 

Sixth and Eighty Amendments to the United States Constitution 

and under the common law of the State of New Jersey. 

COUNT ONE

79.The preceding paragraphs are adopted and incorporated by 

reference.

80.Acting under color of law and the authority of the City of 

Trenton, the defendant police officers intentionally and with 

complete and deliberate indifference for the plaintiffs’ 

rights:

15 ANTHONY COWELL, ATTORNEY AT LAW

ATTORNEY FOR THE PLAINTIFFS

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a. used a degree of force that was unreasonable and 

unwarranted under the circumstances;

b. effected searches, seizures and arrests without reasonable 

suspicion, probable cause and in the absence of exigency;

c. subjected the plaintiffs to punishment without the benefit 

of a trial;

d. Deprived the plaintiffs of their liberty by subjecting them 

to unwarranted and unreasonable restraints on their persons 

without due process in violation of their rights under the 

Fourth and Fifth Amendments.

81.Defendants City of Trenton, the Police Director and the 

Mayor, under color of law, caused the plaintiffs to be 

deprived of their constitutional rights including but not 

limited to the Fourth, Fifth, Sixth and Eighth Amendments by:

a. failing to supervise the training and conduct of defendant 

police officers;

b. failing to enforce the Constitution of the United States 

concerning the use of force by members of the Trenton 

Police Department;

c. failing to enforce the Constitution of the United States 

concerning the law of arrest, search and seizure; 

d. promulgating and issuing a police manual that was violative 

of the plaintiffs’ rights and/or was not followed by the 

16 ANTHONY COWELL, ATTORNEY AT LAW

ATTORNEY FOR THE PLAINTIFFS

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Trenton Police Department, resulting in the plaintiffs’ 

injuries.

82.The plaintiffs’ injuries and deprivations of constitutional 

rights were caused by defendant police director’s:

a. inadequate supervision of the training and conduct of the 

Trenton Police Department;

b. failure to enforce the plaintiffs’ rights under the Fourth, 

Fifth, Sixth and Eighth Amendments of the Constitution of 

the United States;

c. issuance of vague, confusing, and contradictory policies 

concerning the use of force that violated the plaintiffs’ 

rights under the Fourth, Fifth, Sixth and Eighth Amendments 

of the United States Constitution.

d. under color of law, authorized, permitted, and tolerated 

the custom and practice of the unconstitutional and 

excessive use of force by members of the Trenton Police 

Department and, in particular by defendant police officers, 

by failing:

i. to appoint, promote, train and supervise members of the 

Trenton Police Department to prevent the violations 

complained of herein;

ii.to ensure the fair and evenhanded application of the 

law;

17 ANTHONY COWELL, ATTORNEY AT LAW

ATTORNEY FOR THE PLAINTIFFS

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iii.to protect the plaintiffs’ rights pursuant to the 

Fourth, Fifth, Sixth and Eighth Amendments;

iv.to promulgate procedures and policies for the use of 

force and OC spray that were consistent with the Forth, 

Fifth, Sixth, and Eighth Amendments of the Constitution; 

and

v. to address, investigate and eliminate the policy and 

custom of using unreasonable and excessive force by the 

Trenton Police Department and the police officer 

defendants, which failure to act thereby affirmed the 

deprivation of the plaintiffs’ rights under the Fourth, 

Fifth, Sixth and Eighth Amendments; and

vi.investigate the plaintiffs’ complaints.

83.The plaintiffs’ injuries and deprivations of constitutional 

rights were caused by The City of Trenton’s and the Mayor’s 

failure to implement the protections of the Fourth, Fifth, 

Sixth and Eighth Amendments and by their failure to properly 

train, supervise, and discipline the police officer defendants 

regarding their violations of the plaintiffs’ rights in this 

case.

84.The City of Trenton, the Mayor, and the police director 

permitted and condoned a culture of lawlessness within the 

Trenton Police Department, which included the failure to 

18 ANTHONY COWELL, ATTORNEY AT LAW

ATTORNEY FOR THE PLAINTIFFS

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investigate the plaintiffs’ complaints concerning the police 

officer defendants. This culture of lawlessness encouraged 

the conduct alleged above, resulting in harm to the 

plaintiffs.

COUNT TWO

85.The preceding paragraphs are adopted and incorporated by 

reference.

86.Defendant police officers, in using unreasonable and 

excessive force against the plaintiffs, acted in an extreme 

and outrageous manner, intentionally and with reckless 

disregard for the plaintiffs’ welfare, inflicted severe 

emotional distress on the plaintiffs.

COUNT THREE

87.The preceding paragraphs are adopted and incorporated by 

reference.

88.Defendant police officers’ actions constituted aggravated 

assault.

89.At the time of the aggravated assault, defendant police 

officers were wearing their uniforms, were armed with 

handguns, and were acting under color of law.

90.In committing the aggravated assault against the plaintiffs, 

defendant police officers abused the authority granted to them 

by the City of Trenton.

19 ANTHONY COWELL, ATTORNEY AT LAW

ATTORNEY FOR THE PLAINTIFFS

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91.Defendant police officers caused physical and emotional 

injuries to the plaintiffs, and are liable to the plaintiffs 

for their conduct.

COUNT FOUR

92.The preceding paragraphs are adopted and incorporated by 

reference. 

93.Defendant police officers unlawfully detained plaintiffs 

against their will, without probable cause. At the time of 

the detention, defendant police officers were in uniform, 

armed with handguns, and were acting under color of law.

94.Defendant police officers restrained and detained plaintiffs 

without reasonable suspicion and/or probable cause, and 

therefore falsely imprisoned them.

95.Defendant police officers caused physical and emotional 

injuries to the plaintiffs, and are liable to the plaintiffs 

for their conduct.

PRAYER FOR RELIEF 

 WHEREFORE, the plaintiffs pray that this Court:

A. Award the plaintiffs compensatory damages in an amount not 

less than $1,000,000.00, jointly and severally against the 

defendants for the matters alleged in this Complaint;

20 ANTHONY COWELL, ATTORNEY AT LAW

ATTORNEY FOR THE PLAINTIFFS

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B. Award punitive damages in an amount determined by the Court to 

be just and proper in order to deter the conduct complained of 

herein;

C. Award reasonable costs and attorneys fees;

D. Enjoin and restrain the defendants from their pattern, 

practice, custom and policy of violating the rights of the 

citizens of the City of Trenton; and

E. Grant such other and further relief as the Court deems just 

and proper.

DEMAND FOR TRIAL BY JURY

 The plaintiffs hereby demand a trial by jury in this action 

for all issues so triable.

Dated: Anthony Cowell

 Attorney for the Plaintiffs

 

 

21 ANTHONY COWELL, ATTORNEY AT LAW

ATTORNEY FOR THE PLAINTIFFS

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