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Your Name

c/o 9125 Your Street Las Vegas, Nevada

FOR THE

TH$ U.S. DISTRICT COURT NORTHERN DISTRICT OF YOUR STATE EASTERN DIVISION

Your Name Plaintiff, vs. OFFICER B. UCKWHEAT Their Office Address Their City, State Zip & THE CITY OF THEIR CITY Their Office Address Their City, State zip & OFFICER O. BONEHEAD Their Address Their City, State Zip & TOW TRUCK DRIVER TTD Office Address TTD City, State Zip & TOW TRUCK COMPANY TTD Office Address TTD City, State Zip Defendants
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CASE NO. JUDGE: COMPLAINT FOR DAMAGES CIVIL RIGHTS VIOLATIONS

TRIAL BY JURY Demanded Herein

INTRODUCTION & OPENING STATEMEMT This is an action brought by Plaintiff against State Officials acting under the color of Law and other Parties related to a TOW TRUCK COMPANY for civil rights violations involving wrongful arrest, grand theft, criminal trespass, and wrongful detention. At all times relevant herein the Defendants, including State Officials and certain Private Parties acting under the color of Law and outside the scope of their jurisdiction and authority, willfully caused Plaintiff a damage and physical injury, and in so doing, violated clearly established law, as those laws apply to Plaintiff's rights protected under the Constitution, particularly under the 4th, 5th, 6th or7th, 8th, 9th, and 14th Amendments. Be it known, each of the state officials herein have sworn an "oath of office" in regards. to their duties and therefore each of their acts under "color" of state law is in direct violation of their oath of office and equates to CRIMINAL CONSPIRACY under section 1985. Defendant Judge's actions are tantamount to nothing less than CRIMINAL TREASON against the united States Constitution and the People of the United States.

I.

JURISDICTION and VENUE

1.

Plaintiff brings this action pursuant to sections 1983, 1985, 1986, and 1988, and invokes the
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jurisdiction of this court pursuant to Title 28 USC Section 1343 (A) (3) (4), Section 1331, and pursuant to the 14th Amendment, Title 42 USC Section. 1983, and the Civil Rights Act of 1870. At all times relevant, all of the causes of action were committed within the geographical jurisdiction of this court.
II. PARTIES

2.

Plaintiff, Your Name, herein after "Name", at all times relevant herein, lived in the city of

Your City, in Your State. Name has lived in the Your State area since ?.

3. Defendant Officer B. UCKWHEAT, W.P.D. #19, herein after "Pitts", at all times relevant to this complaint, was acting as a State employed, compensated, enriched , and rewarded Police Officer for the municipality of Willoughby in the State of Your State. individually and in his official capacity. 4. Defendant City of Willoughby, herein after "City", at all times relevant to this complaint, Pitts is being sued

was, and is, a municipal corporation of the State of Your State, responsible for compensating, enriching, rewarding, and making policy for Defendants Police Officers, Judge Name, and John Does. City is being sued as a person. 5. Defendant Magistrate Dale E. Judge Name, herein after "Judge Name" at all times relevant to this complaint, was acting as a duly elected official and was employed, compensated,- enriched, and rewarded performing his duties as a magistrate. Judge Name is being sued individually and in his official capacity.

III FACTS

12. 20.

YOUR AFFIDAVIT OF FACTS HERE...PROPERLY NUMBERED. As a proximate and direct result of the actions of defendants herein, Name rights were

knowingly violated in direct violation of clearly established Federal law.

21. At all times herein, the defendants were acting under color of state law. 22. All of the Defendants, at all times related herein, acted wantonly, recklessly, willfully and maliciously, and "in concert" with additional state officers showing a deliberate indifference towards Name and Name rights protected, and guaranteed, by the Constitution, with the direct intent and sole purpose of injuring, humiliating, vexing, oppressing, and causing mental anguish to Name. As a direct and/or proximate result of Defendants actions, Name is seeking an additional $50,000.00 per day for punitive damages.

FEDERAL CAUSES OF ACTION

23. All allegations set forth in paragraphs 1 through incorporated herein by reference. As and for a first cause of Action 24. Upon information and belief, the Defendant City, being sued as a "person" maintains a pattern and practice of depriving liberty and property, and causing damage without probable cause or proper foundation as secured by the Constitution as demonstrated by the deprivation of Name' rights. As and for a second cause of Action 25. Upon information and . belief, the Defendant City failed and/or neglected to properly train and supervise its employees, and especially its police officers and municipal judges, with respect to individual rights as protected by the Constitution as made evident by the several severe abuse(s) and damage(s) sustained by Name.

As and for a third cause of Action 26. At all time relevant, all defendants, especially Pitts, Johnson, and Judge Name, were acting within the scope of their presumed duties as employees of Defendant City when depriving Name of his rights , liberty, and freedom from unprovoked attacks, unlawful arrest, denial of effective assistance of counsel, and medical treatment, and other violations of clearly established laws protected by the 4th, 5th, 7th, and 14th amendments. 27. Name has been forced to suffer physical and emotional cruel and unusual punishment, in

direct violation of the Eighth Amendment, by combined unreasonable actions of Defendants John Does as shown above and it is unreasonable that any jailor would not have known that to physically torture a prisoner by not allowing him to sleep, shower, receive reasonable allocations of sufficient food, or receive medical treatment. would be a violation of his rights.

50.

Defendant City is liable under the Doctrine of Respondent Superior for the acts of their

employees committed within the scope of their employee duties, but outside the scope of their discretion in a long train of abuses which is a custom, policy, or practice to violate clearly established law. WHEREFORE Name demands judgment against the defendants, jointly and severally, as follows: a. as compensatory damages, the sum of $850,000.00; b. as punitive damages, the sum of $850,000.00; c. all costs and disbursements of this action; d. all attorney's fees incurred in prosecuting this action pursuant to 42 U.S.C. 1988; e. the right to amend this complaint as warranted by further evidence and fact finding; f .. and other such further relief as to the Court seems proper.

TRIAL BY JURY IS HEREBY DEMANDED'

Respectfully submitted,

Your Name c/o 9125 Your Street non-domestic Las Vegas, Nevada

VERIFICATION

State of Nevada County of Clark

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I, Your Name, Name in the attached Complain for Damages, does affirm by his signature hereon, the facts and allege therein and further affirm said facts and allegations to be true and correct to the best of my knowledge and belief so help me God.

Your Name c/o 9125 Your Street non-domestic Las Vegas, Nevada

as witnessed by:

date

date

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