Case Document 1 Filed 05/08/18 Page 1 of 32 PageID: 1 CIVIL COVER SHEET .1844 (Rev. The .18 44 civil cover sheet and the information contained herein neither ngri?tsluep?ement the ?111 cc and service of pleedin orothorpspersaa uired by law, except as provided local. rules of court. This form. a by the Judicial Con nited States in eptember 1974, is requr purpose initiating the civil docket sheet. ONNEXTPAGE OF THIS POM) I. PLAINTIFFS DEFENDANTS KHASEEM GREENE ELIZABETH POLICE DEPARTMENT. et als. County ofReaidence ofFirst Listed Plainti?' UNION (EXCEPTIN UES. PLAINTIFF CASES) Attomeys (Firm Name. Address. and Telephone Number} Schiller McMahon. LLC 123 South Avenue East. West?eld, New Jersey 07090 Attorneys ??t?ncwi} County of Residence of First Listed Defendant UNION U.S. PLAINTIFF CASES ONLY) LAND CONDEMNATION CASES, USE THE LOCATION OF THE TRACT OF LAND INVOLVED. II. BASIS OF JURISDICTION (Piece an pr" in One Box Gaby U.S. Government Plainti?' 1 El 2 U.S. Government Detendant It 3 Federal Question (U.S. Government Not a Party) U4 Diversity (Indicate Citizenship of Parties in Item 111) IV. NATURE OF SUIT Preteens 'T'tnottesex- CITIZENSHIP 0F PRINCIPAL PARTIES (Place on in One Boa-for eternity (For Diver-star Cases Dob!) Citizen of This State 11' Citizen of Another State E1 Citizen or Subject ofa :1 Ft I'I-Itil'n andOneBnir?rDefendmtofBusinesaInTlriaState ForeignNatim 6 El 6 Click here for: Nature of Suit Code . - .i-ri I. EELHALI HI ne'l'il'l 110 Insrn'ance PERSONAL INJURY PERSONAL INJURY 625 Drug Related Seinu'e El 422 Appeal 28 USC 158 El 375 False Claims Act 0 120 Marine El 310 Airplane El 365 Personal Injury - ofProperty 21 USC 881 El 423 Withdrawal El 376 Qui Tam (31 USC 130 Miller Act 315 Airplane Product Product Liability :1 690 Other 28 USC 15'}r 3729(0) a 140 Negotiable liability in 367 Health Care! I: 400 State Reapportionment El 150Recoveryof0verpayrnent El 320 Assault, Libel a Pharmaceutical :1 410 Antitrust at Enfa'cenrent ofJudsmant Slander Personal Injury 0 820 Copyrights El 430 Banks and Banking in 151 Medicare Act 330 Federal Product :30 Patent 450 Commerce :1 152RecoveryofDe?ulted Liability L'l 368mm E1835Patant-Abbrevisted D460quntation Student Loarls 340 Marine itn'nty Product New Drug Application at 470 Racketeer In?uenced and (Excludes Veterans) E1 345 Marine Product Liability :1 840 Corrupt annotations to 153 Recovery ovaer'payment Liability PERSONAL PROPERTY I 1.th nit m. ilLt-Hll'i a 430 Consumer Credit of Veteran's Bene?ts El 350 Motor Vehicle El 370 Other Fraud 710 Fair Labor Standards El 861 HIA (1395?) 490 CableISat TV El 160 Stockholders' Suits El 355 Motor Vehicle El 371 ?nd: in Lending Act El 862 Black Lung (923) El 850 Sean?itiealCornrnoditiesi CI 190 Other Contract Product Liability El 380 Other Personal 720 stori'Management El 863 DIWCIDIWW (405(8)) Exchange El 195 Contract Product Liability El 360 Other Personal Property Damage Relations El 864 881D Title XVI El 890 Other Statutory Actions El 196 Franchise Injury El 385 Propu'ty Barrage 740 Railway Labor Act 865 R81 (405(9)) 891 Agricultural Acts ProductLiability DTSIFarnilyandMedical D893EnviromrentalMlters Medics! LeaveAct jut til H'i't. I it It. I it I'i-lii'il Hi.? PM it Mlle-'- El 790 OtherLabor Litigation tr. rm; Ht ITl-i' Act El 210 [and Continuation I440 Other Civil Rights l-Ialreas Corpus: CI 791 Employee Retirement 870 Taxes (U.S. Plaintiff 896 Arbitration El 220 Foreclosure El 44] Voting CI 463 Alien Detainee Income Secrsity Act or Defendant) 899 Administrative Procedure in 230RentLease&Ejeotment U442En1ployrnent 510MotionstoVacate a BTlIRs?TbirdParty Acti'Reviewra'Appealof 240 rot-teno Land in 445 Hauling! Semence 26 use 7609 El 245 Test Product Liability Accornnrodatitars 530 General El 950 Constitutionality of El 290 All Other Real Property El 445 Arner. ?Disabilities - 535 Death Penalty I'rl lrlII'JIh State Statutes Ermioyment Other: 462 Naturalization Application E1446Arner.waisabilities- U540Mandanurs&0tber E14650ther1nunisration Othe- 550 Civil Rights Actions El 448 Educatita?t 555 Prison Condition :1 560 Civil Detainee - Conditionsof Con?nernurt V. ORIGIN (Piece on in One sex on? Kl Original El 2 Removed from El 3 Remanded from El 4 Reinstated or Cl 5 Transferred ?-om El 6 Multidistrict El 8 Multidistl'ict Proceeding State Court Appellate Court Reopened Another District Litigation - Litigation - - Transfer Direct Frle Cite?r?g?. C1511 Statute under which you are ?ling (Domdk?ui?c?mdm In? W: 42 198 at am. vr. CAUSE OF ACTION BM mm, mm: Civil Rights Action against Elizabeth Police Department and Union County Prosecutors Of?ce VII. REQUESTED IN El CHECK IF THIS is A CLASS ACTION DEMAND 5 CHECK YES only if demanded in complaint: COMPLAINT: UNDER RULE 23. RECEP- JURY DEMAND: 3 Yes ElNo RELATED 11" ANY Mmmw' JUDGE DOCKET NUMBER DATE SIGNATURE oref?- lye} 317+ I . 0508/2018 ref xi" 1: RECEIPT ii AMOUNT n- 1'va JUDGE MAG. JUDGE Case Document 1 Filed 05/08/18 Page 2 Of 32 PageID: 2 Joshua F. McMahon, Esq. NJAID 043282005 Schiller McMahon LLC 123 South Avenue East West?eld, New Jersey 07090 P: (908) 233?4840 F: (908) 935-0822 Attorneys for Plaintiff, Khaseem Greene UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY KHASEEM GREENE, Plaintiff, V. CIVIL ACTION NO. ELIZABETH POLICE ALFONSO JAMES UNION COUNTY PATRICIA STEPHEN DEBORAH MARK DOES 1 through 10, Defendants. Case Document 1 Filed 05/08/18 Page 3 of 32 PageID: 3 TABLE OF CONTENTS NATURE OF ACTION 1 JURISDICTION AND VENUE 3 PARTIES 4 1. The Plaintiff 4 2. The Defendants 4 1. The Police Defendants 4 2. The Union County Prosecutor Defendants 4 FACTUAL ALLEGATIONS 5 A. All Star Cafe Shooting Initial Investigation B. Sanders Interrogation Police Defendants Initial Concealmenthabrication of Evidence C. Colon and Prosecutor Defendants Present Manufactured, Fabricated Evidence to Grand Jury; Prosecutor Defendants Defame Plaintiff; Plaintiff cut by Chiefs D. Plaintiff Retains New Counsel; Motions for a Probable Cause Hearing, Dismissal of the Indictment, Speedy Trial and to Compel the Production of Discovery are Immediately Filed on Behalf of Plaintiff E. Prosecutor?s Of?ce Changes their ?Theory of the Case?, Ultimately Dismissing Indictment FIRST CAUSE OF ACTION: DEPRIVATION OF CIVIL RIGHTS IN VIOLATION OF 42 U.S.C. 1983 16 SECOND CAUSE OF ACTION: DEPRIVATION OF EQUAL PROTECTION OF THE LAW IN VIOLATION OF 42 1981 17 THIRD CAUSE OF ACTION: CONSPIRACY TO VIOLATE CIVIL RIGHTS IN VIOLATION OF 42 U.S.C. 1985 18 Case Document 1 Filed 05/08/18 Page 4 of 32 PageID: 4 FOURTH CAUSE OF ACTION: FAILURE TO PREVENT CIVIL RIGHTS VIOLATIONS IN VIOLATION OF 42 1986 18 FIFTH CAUSE OF ACTION: NEGLIGENT SCREENING, HIRING, TRAINING, SUPERVISING AND RETENTION OF DANGEROUS EMPLOYEES IN VIOLATION OF 42 1983 19 SIXTH CAUSE OF ACTION: VIOLATION OF NEW JERSEY CIVIL RIGHTS ACT IN VIOLATION OF et seq 19 SEVENTH CAUSE OF ACTION: EIGHTH CAUSE OF ACTION: ABUSE OF PROCESS .. 21 NINTH CAUSE OF ACTION: FALSE ARREST AND IMPRISONMENT 21 TENTH CAUSE OF ACTION: MALICIOUS CONSPIRACY TO COMMIT MALICIOUS ELEVENTH CAUSE OF ACTION: NEGLIGENCE 22 TWELTH CAUSE OF ACTION: INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS 23 THIRTEENTH CAUSE OF ACTION: DEFAMATION PER SE 23 FOURTEENTH CAUSE OF ACTION: VICARIOUS LIABILITY 24 PRAYER FOR RELIEF 25 JURY DEMAND 27 Case Document 1 Filed 05/08/18 Page 5 of 32 PageID: 5 mm Plaintiff, KHASEEM GREENE, by and through his attorneys, Schiller McMahon LLC, by way of this Complaint and Jury Demand, seeks compensatory damages, punitive damages, injunctive relief, attorneys? fees, and costs of suit from Defendants, and alleges as follows: NATURE OF ACTION 1. This is a civil action for damages and injunctive relief arising from one of the most chilling episodes of police and prosecutorial misconduct in modern New Jersey history, which resulted in criminal charges brought and maintained against Plaintiff for several months, including Plaintiff being incarcerated for a period of time, before being dismissed. 2. The most decorated Defensive Player in Rutgers football history, including being Rutgers ?rst and only two-time Big East Defensive Player of the Year, Plaintiff was drafted in 2013 by the Chicago Bears of the National Football League (NFL) following his 2012 ESPN, Associated Press and Walter Camp All-American season at Rutgers. Prior to enrolling at Rutgers, Khaseem was a star at Elizabeth High School and known by many as the ?Pride of Elizabeth?, the City where he was born and raised. 3. From January 4, 2017 to July 17, 2007, Defendants, individually and in concert, maliciously conspired to bring a charge of Unlawful Possession of a Weapon-Firearm against Plaintiff. Defendants knew that this charge was completely and utterly unsupported by probable cause, and a total fabrication contradicted by physical evidence, documentary evidence, other witnesses, and even the former co-Defendant. In their rush to accuse Plaintiff, a highly-respected man within his community and professional athlete with zero criminal history, Defendants will?illy ignored and were deliberately indifferent to overwhelming evidence of Plaintiff?s actual Case Document 1 Filed 05/08/18 Page 6 of 32 PageID: 6 innocence whilst simultaneously manufacturing and fabricating false evidence in order to charge Plaintiff with a crime he did not commit. 4. Defendants made, individually and/or in concert with others, demonstrably false statements to obtain complaint-warrants and then, repeating and reiterating those demonstrably false statements under oath, an indictment. Similarly, Defendants conspired to conceal exculpatory evidence in order to charge and convict the Plainti?' on ?facts? they knew to be untrue. Defendants? actions evidenced a reckless and callous disregard for and deliberate indifference to Plaintiff?s constitutional rights and Defendants? responsibilities to the criminal justice system. 5. As a result of Defendants? actions, Plaintiff has suffered deprivaticns of the rights guaranteed to him under 42 U.S.C. 1983 and 1988, and the Fourth and Fourteenth Amendment to the United States Constitution; the New Jersey Civil Rights Act, N.J.S.A. 10:6?1, et seq., and Article I of the New Jersey State Constitution; he has suffered economic, emotional, and physical harm; he has suffered irreparable harm to his reputation; and he has incurred thousands of dollars in legal fees defending himself against a criminal prosecution that the Defendants fabricated and knew was baseless. 6. Moreover, because the Defendants' policies, customs, practices, and supervisory misconduct raises a substantial risk of irreparable injury to other persons in the City of Elizabeth, Plaintiff seeks the entry of an Order and Permanent Injunction, as set forth in the Prayer for Relief below, to protect all persons and to prevent such misconduct from ever happening again. Case Document 1 Filed 05/08/18 Page 7 of 32 PageID: 7 JURISDICTION AND VENUE STATEMENT 7. This is an action for damages arising out of one or more violations of federal and state law, and is brought pursuant to 42 U.S.C. 1981, 1983, 1985 and 1986, and the Fourth and Fourteenth Amendment to the United States Constitution; and, the New Jersey Civil Rights Act, N.J.S.A. 10:6?1, et seq., and Article I of the New Jersey State Constitution. 8. This Court has jurisdiction over this action pursuant to the provisions of 28 U.S.C. 1331 and 1343 in that this is an action to redress, among other things, violations of Plaintiffs federally protected Constitutional rights. Jurisdiction over the state law claims is founded upon the supplemental jurisdiction of this Court, pursuant to 28 U.S.C. 1367. 9. The acts and practices constituting the violations alleged below have all occurred within the State of New Jersey, which is properly within the jurisdiction of the United States District Coru't in and for the District of New Jersey. Venue in the District of New Jersey, Newark Division, is proper because the incident which is the subject of this lawsuit occurred in the State of New Jersey and Defendants are located in this venue. See 28 U.S.C. 1391(b)(1) and 1 391 10. This action has been commenced within the statute of limitations for all Federal and pendent State causes of action. 1 1 . Plaintiff has complied with all conditions precedent to the ?ling of this lawsuit pursuant to Title 59, New Jersey Statutes; all applicable notices have been provided to Defendants. 12. Defendants were at all times relevant acting under color of state law as active and duly appointed EPD police of?cers and/or assistant prosecutors, and in such capacity, as the agents, servants, and employees of Defendant EPD and/or Defendant UCPO. 13. Plaintiff has retained Schiller McMahon LLC to represent his interests in prosecuting Case Document 1 Filed 05/08/18 Page 8 of 32 PageID: 8 this action, and said law ?rm is entitled to their reasonable attorneys? fees and costs incurred in connection therewith. PARTIES 14. At all relevant times hereto, Plaintiff KHASEEM GREENE (?Plaintiff?) was an individual residing in the city of Elizabeth, County of Union, State of New Jersey. 15. At all times relevant hereto, Defendant ELIZABETH POLICE DEPARTMENT was a municipal subdivision and arm of the City located at 1 Police Plaza, Elizabeth, NJ 07201. 16. Defendant ALF ONSO COLON (?Colon?) was at all times relevant herein employed by Defendant EPD. Colon was the assigned investigator responsible for investigating the All Star Cafe shooting. He is sued in both his individual and of?cial capacity. 17. Defendant JAMES SZPOND (?Szpond?) was at all times relevant herein employed by Defendant EPD. Szpond assisted Colon with the investigation. He is sued in both his individual and of?cial capacity. 18. At all relevant times hereto, UNION COUNTY OFFICE was an office organized pursuant to the laws of the State of New Jersey, with a principal place of business at 32 Rahway Avenue, Elizabeth, New Jersey. 19. Defendant PATRICIA CRONIN (?Cronin?) was at all times relevant herein employed by Defendant UCPO. Cronin was assigned to the EPD and responsible for advising and supervising criminal investigations. She is sued in both her individual and of?cial capacity. 20. Defendant STEPHEN KAISER (?Kaiser?) was at all times relevant herein employed by Defendant UCPO as an Assistant Prosecutor. He is sued in both his individual and of?cial capacity. Case Document 1 Filed 05/08/18 Page 9 of 32 PageID: 9 21. Defendant DEBORAH WHITE (?White?) was at all times relevant herein employed by Defendant UCPO. White was Kaiser?s supervisor and re?ised to dismiss charges despite acknowledging a lack of probable cause. She is sued in both her individual and of?cial capacity. 22. Defendant MARK SPIVEY (?Spivey?) was at all times relevant herein employed by Defendant UCPO as the Director of Communication for Defendant Prosecutor?s Of?ce. He is sued in both his individual and official capacity. 23. Defendants DOES 1 through 10 are gender?neutral, ?ctitious individuals meant to represent af?liates, associates, andlor agents of the EPD and/or UCPO who have been involved in the conduct that gives rise to this Complaint, but are heretofore unknown to Plaintiff at the present time. As these defendants are identi?ed, Plaintiff shall amend the Complaint to include their known identities. 24. The Defendants may be referred to as ?Defendants? in the aggregate. Colon and Szpond may be collectively referred to as ?Police Defendants,? and Cronin, Kaiser, White and Spivey may be collectively referred to as ?Prosecutor Defendants?. 25. In addition to being sued individually, said defendants are being sued and judgment sought against them jointly and severally. FACTUAL ALLEGATIONS A. All Star Caf? Shooting Initial Investigation 26. On or about December 3, 2016, a shooting was reported to EPD in the area of South Park Street and Third Street in Elizabeth in the vicinity of All Star Cafe. Multiple gunshots were ?red into a crowd of people, and several shots impacted a taxi cab in the vicinity. 27. Around this time, EPD Of?cers Mooney (?Mooney?) and Haverty (?Haverty?) were Case Document 1 Filed 05/08/18 Page 10 of 32 PageID: 10 on patrol in the area of the ZOO-block of Magnolia Avenue, when they encountered a dark colored SUV and attempted to stop same. Their efforts to execute a motor vehicle stop failed and the pursuit was terminated. It was later discovered that said vehicle was registered to a romantic af?liate of Jason Sanders (?Sanders?), who was later arrested and remains under indictment for the shooting at All Star Caf?. Sanders, according to EPD, has at least twenty-one (21) arrests, six (6) felony convictions, and one (1) violation of probation for offenses including gun traf?cking, assault, reckless endangerment, kidnapping, robbery, weapons, aggravated assault and narcotics. 28. Upon information and belief, Sanders was the driver of said dark colored SUV and was in the process of escaping his apprehension for the shooting he had just committed. 29. On or about December 3, 2016, following their aborted pursuit, Mooney and Haverty responded to All Star Caf? and established a crime scene. At said time, Mooney and Haverty were able to meet with All Star Caf? employee Jorge Santos. Santos displayed video from several surveillance cameras outside the establishment for Mooney and Haverty. Mooney?s Investigation Report states that the ?video showed the shooting suspect exiting All Star Cafe at 03:53 on their cameras and proceed to walk to the S. Park Str. Side of the building before he starts shooting.? Notably, Mooney and Haverty describe one (I) suspect and make zero mention of any actor appearing to hand any object, let alone a gun, to Sanders. 30. On December 5, 2016, along the route said vehicle eluded law enforcement, Port Authority Police recovered a gun which was later con?rmed through ballistics testing to be the weapon ?red at All Star Caf?. 31. On or about December 6, 2016, video ?-om All Star Cafe was recovered and taken into custody. Case Document 1 Filed 05/08/18 Page 11 of 32 PageID: 11 32. On or about December 19, 2016, a concerned citizen identi?ed the shooter on the All Star Cafe video as ?Big and, ultimately, Jason Sanders to EPD Detective Carmine Gianetta. 33. On or about December 20, 2016, EPD Sergeant Rodney Dorilus also identi?ed the shooter on the video as Jason Sanders, who he knew from prior encounters. 34. On or about December 20, 2016, Colon conferred with Prosecutor Defendant Cronin regarding the investigation. 35. On or about December 21, 2016, EPD Of?cer Paul Tillotson created a ?Wanted Person? ?yer for Sanders to be arrested, and, in same, no mention of a second actor or suspect is mentioned, nor does anyone allege that anyone passed Sanders any object, let alone a gun. 36. On or about December 23, 2016, Cronin approved aggravated assault with a deadly weapon; unlawful possession of a weapon; possession of a weapon for an unlawful purpose; and certain possessions (prior convicted felon) not to possess weapons (handgun) against Sanders. 37. On December 30, 2016, Sanders was arrested on the aforementioned charges in Jersey City, New Jersey. Sanders was observed by an off-duty EPD of?cer who noti?ed Jersey City Police Department. B. Sanders Interrogation Police Defendants Initial Concealment/Fabrication of Evidence 38. On or about December 30, 2016, Colon, with the assistance of Szpond, conducted a video interview of Sanders. According to Colon?s supplemental investigation report summarizing the interview, Colon wrote that ?Sanders also stated that the gun he (Sanders) used in the shooting was giving (sic) to him by Khaseem Greene.? This marks the ?rst time that Khaseem Greene?s name was ever mentioned in the investigation. 39. At or near the conclusion of the very same interview, Sanders, who repeatedly lied Case Document 1 Filed 05/08/18 Page 12 of 32 PageID: 12 throughout his interview and admitted to same, is asked whether the information he provided regarding Plaintiff was true. Sanders told the police that he ?lied,? and the police, instead of following-up, told Sanders ?you can recant at another time. Not tonight.? 40. Upon information and belief, not a single member of EPD in a single report indicated that a person handed an object, let alone a gun, to Sanders, save Colon, who states same in his supplemental report only interviewing Sanders. 41. On or about January 4, 2017, Colon conferred with Cronin regarding the status of the investigation and ?advised her of the case [sic] new details.? According to Colon?s supplemental investigation report, Cronin approved bringing charges against Plaintiff ?[a]fter reviewing the new details of the 42. On or about January 4, 2017, Colon prepared a Complaint-Warrant (also known as wherein Colon, with Cronin?s approval and/or instruction, made two blatantly false statements to manufacture evidence to create probable cause against Plaintiff. 43. Speci?cally, Colon and/or Cronin knowingly and intentionally or with a reckless disregard for the truth stated that Plaintiff ?was observed on surveillance video handing over a handgun? to Sanders, which is categorically false, and that Sanders ?admit[ed] that [Plaintiff] handed him the handgun,? which is also false because, in the very same statement the self-admitted liar and multi-convicted felon (Sanders), also admitted that he ?lied? when he claimed Plaintiff handed him a gun. These two manufactured falsehoods and no other evidence were listed by Colon as his only basis to charge Plaintiff. 44. Notably, in his December 22, 2016, Af?davit of Probable Cause used to obtain a Complaint-Warrant against Sanders, Colon never once mentions either a second suspect and/or anyone handing Sanders a ?rearm. Case Document 1 Filed 05/08/18 Page 13 of 32 PageID: 13 45. On or about January 4, 2017, Colon purports to contact Elizabeth Municipal Court Administrator Margaret Gonzalez to approve an arrest warrant for Unlawful Possession of a Weapon against Plaintiff. The information conveyed by Colon to Gonzalez, and the manner (telephonically, in writing, visual demonstration of evidence) it was transmitted, remains unknown, as the Complaint-Warrant purportedly prepared by Colon and provided in criminal discovery possessed neither a probable cause determination nor a judicial signature, but did contain the two (2) fabricated, manufactured falsehoods elucidated above. 46. On or about January 5, 2017, Plaintiff responded to EPD with his attorney. Despite being advised that Greene would not be speaking and Plaintiff turning himself in with counsel present, Colon separated Plaintiff ?om his attorney and brought him into an interrogation room where Colon sought to take a statement from a represented person. This was done on video. 47. On or about January 31, 2017, Colon closed the case pending Grand Jury. C. Colon and Prosecutor Defendants Present Manufactured, Fabricated Evidence to Grand Jury; Prosecutor Defendants Defame Plaintiff, Lying to Press; Plaintiff cut by Chiefs 48. On or about May 9, 2017, Kaiser, along with White and/or on White?s orders, presented manufactured, fabricated evidence to the Grand Jury, to wit, the aforementioned two (2) lies described above, in order to obtain an indictment against Plaintiff. Because the Prosecutor Defendants presented infonnation to the Grand Jury that was manufactured, fabricated and false, they, individually and/or in concert with Police Defendants, suborned perjury before the Grand Jury in order to obtain an indictment against Plaintiff. 49. During the Grand Jury presentment, Prosecutor Defendants neither played the surveillance video for the Grand Jury, nor did they play the Sanders video statement. Instead, they solicited the two (2) lies delineated in this complaint ?'om Colon. 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