FILED DATE: 7/13/2018 8:38 AM 2016L010029 IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT, LAW DIVISION LAWRENCE CROSBY, Plaintiff, v. CITY OF EVANSTON, a Municipal Corporation, SEAN O'BRIEN, BRIAN HICKS, ANTHONY CORREA, and IVAN REZA, in their individual capacities, Defendants. COMPLAINT NOW COMES, the plaintiff, LAWRENCE CROSBY, by and through his attomeys, ‘Timothy J. Touhy and E. Steven Yonover, and for his complaint at law as against the abov: named defendants, states as follows: Parties 1. The plaintiff, LAWRENCE CROSBY, is an individual who and at all times material hereto, was a resident of Cook County, State of Illinois. At the times mentioned herein, LAWRENCE CROSBY was an engineering student in the Northwestem University PhD program in material science and engineering. 2. Defendant CITY OF EVANSTON is a municipal entity which employs or employed the Defendant Officers, SEAN O'BRIEN, BRIAN HICKS, ANTHONY CORREA and IVAN REZA. 3. The defendant Sean O'BRIEN was a police officer for the City of Evanston and at all times material hereto, was a duly appointed police officer of the City of Evanston, acting in hisFILED DATE: 7/13/2018 8:38 AM 2016L010029 individual capacity as an employce’and agent of the City of Evanston and a duly authorized conservator of the peace under the authority of 65 ILCS 5/11-1-2. 4. The defendant BRIAN HICKS was a police officer for the City of Evanston and at all times material hereto, was a duly appointed police officer of the City of Evanston, acting in his individual capacity as an employee and agent of the City of Evanston and a duly authorized ‘conservator of the peace under the authority of 65 ILCS 5/11-1-2 5. The defendant ANTHONY CORREA was a poli officer for the City of Evanston and at all times material hereto, was a duly appointed police officer of the City of Evanston, acting in his individual capacity as an employee and agent of the City of Evanston and a duly authorized conservator of the peace under the authority of 65 ILCS 5/11-1-2. 6. The defendant [VAN REZA was a police officer for the City of Evanston and at all times material hereto, was a duly appointed police officer of the City of Evanston, acting in his individual capacity as an employee and agent of the City of Evanston and a duly authorized conservator of the peace under the authority of 65 ILCS 5/11-1-2. Allegations Common to All Counts 7, At the time and date aforesaid, and prior to the time that defendants stopped plaintiff, the plaintiff was not in violation of any of the ordinances of Evanston, the statutes of the State of Ulinois, or the statutes of the United States. 8. At approximately 7 PM on October 10, 2015 one or more of the defendants received a radio transmission of a suspected stolen vehicle. O"BRIEN, HICKS, and CORREA activated the emergency lights and sirens on their police cars and stopped the vehicle being driven by CROSBY at 1509 Ridge Evanston, Illinois.FILED DATE: 7/13/2018 8:38 AM 2016L010029 9. Upon being stopped by defendants, CROSBY exited his vehicle and raised his hands, One or more of the defendant police officers immediately rushed CROSBY, tackling CROSBY to the ground and striking CROSBY with multiple blows. At no time before the police tackled him did CROSBY pose a risk of great bodily harm to any person nor was CROSBY refusing to comply with instructions from any police officer, attempting to resist, escape or defeat the investigation by the police. 10. Mr. Crosby informed the police that, “My name is Lawrence A. Crosby. I'm a student at Northwesterm University in the department of material contract engineering. 1 purchased this vehicle January 23, 2015 from Libertyville Chevrolet. | have all the evidence.” When asked by a police officer who the car was registered to, Mr. Crosby stated, “Myself.” 11. Within minutes of stopping CROSBY but afier the defendant police officers had used force against CROSBY, one or more of the defendants determined that CROSBY was the registered and lawful owner of the vehicle and that the vehicle was not stolen, ane police officer stating that he verified that the car was owned by CROSBY. 12. At the time that the defendants determined that CROSBY was the registered and lawful owner of the vehicle there was no probable cause to detain or arrest CROSBY for possession or thefl of his own automobile. 13. Upon learning that there was no probable cause to detain, interrogate or arrest the plaintiff relating to the ownership or use of CROSBY’s vehicle, one or more of the defendants handeuffed CROSBY, took him into custody and transported CROSBY to the Evanston Police Department.