Case Document 1-2 Filed 05/29/20 Page 1 of 18 \1lmar?\T (ASE DIRH I .mtulm?i .tt i; Ru?ui?ll-It l\ \l li?k .tmtt th? llt:( ll?t?l ?Us ?2 i I I (I. m/um. In?lt Kcitm?. as thuucd Rule - (Ill/(M, . . . lit JJEFFXDAX 1? CASE m: Bettat?:tcl Humsmt. c: til . . m'i D37t'lJJill l\ \ntlt'c Bonaparte n' xx It i 1? r.\i xii i D) an uttornct: - I '5 ii. Cild?. linq. 5 Charles Street. Suite 1900 Baltimore 3120] -- l\ \l lttR\L\ ?5 l.tt um my 5x0 l?H) (ASL 33 as 3X0 Utes. ('ase il?known OF hours 5 . I TYPE .4159. (.tt?tgmul jAdminislmtitc Appeal ?3 Appeal l.\t\ttng( use: 0" (axe. skip Ca? (?Jtcuon Subcazcgon scum: - do to CASE: CATEGDRY-SUBCATEGORY (Check mtg/m.) ?55m; 0 PUBLIC LAW 3 .?Tud Assault .1th Baths} produci?l mam? Allornq \l'tfg'nzjl 1 Benti Forl?czturt Dcp-tsitiut: \Wtc. . I Ectul Rights jDist Ct .\l:tt Ann-.21 Amuse I o>>e>>ton -- a - - Brena on 0250 {pentth .[lanl 0d? On. Financzu. h- - - a? Gran~1un Pun} . lulsc Di} . Grimm: Domain 3 m: a ?and gum? 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CM on Hal 388m lucitm ?bdmm' "3 mom?) 3 Return worm}; theme; 53.9 3 Admin (?onszruclim Rush: .\tt0me\ '3 [3 Debt Tcnam Hojding 0? c, l?cd} Attachment lsx'uancc 3 Speci?c ?and Issuance Structured settlements I'Rev. H4 2017?; Page 1 01.3 Case Document 1-2 Filed 05/29/20 Page 2 of 18 I II UR RHJEF ((?lwck that :l?u t; granting 3 "mum at Pram-"h \ltz?tvi't I ?l?l?h?JRk?ltl M.ch . . 11.1Lnlk?l Lump? Spunk I?cr'brmuncc ttv[15? 0 I.le Ch [wamlnmu'm rll-l n?n' \Hbi) 1 Italian a?rdrt 1 Judgment 30?ncr?hip0fpropcm jt tum t\ ngh' Urdu Oparmmn 1 "Mic-1m H'dcr ?Vftl?n?ihcm ?V?rl?u? ?mun?. 3 O?l? 1 cc\ jpmducllon of Records 3Quarantmc lsolanon ()t?dcr Reinslalcmenl of .w I mud/1 u' liahl'lia' than; mark one This is an admission and mu nut lwt- tm-d tor an} pttmosc other than {rack .tssxenmeatt. 1; F'h?m} Is conceded I: not but not senoulx tn I DAMAGES (Do not include AttorneV's Fees. Interest. or Court Costs) 3 ?0.000 - 830.000 3 SI (Mg; 51:10pm Bills Wage 1.035 3 f?ropct?t} {linden RESOLUTION INFORMATION i 1 . 1h!) for a'ci'cn'al to an ADR process under Md. Rulc (Check ail that applt . \Icmatmn ?cult-men: (?mit?crc?irc 3Y0 1; -\rhilr.tlim DY-cs OX0 D. Neural Ewltmuon ONO SPECIAL REQUIREMENTS 3 HI: \?pokcn Language Interpreter is needed. check here and attach form (0000? It?wu rcqutrc an accommodation for .t disabilizy under :h-c American: with Dma'ohitic.? Au?. check here and attach form CC-DC-049 LENGTH OF TRIAL the tax'u'plmn of'Bultimore omztj.? and Balzimore Cizjt'. please ?ll in the animated (IF (Case will be n'acked according/)7 a i 2 Of 01' leis 3 days ot'tfiul [hut- I 03." ?fmal time More than 3 day ot'trial time 0 3 day ut?trial time Bl SINESS AND TECHNOLOGY CASE MANAGEMENT PROGRAM For all jm'isdicriom. and Tt?t'Itrzuiogj' (ruck Rm't? i?J-A?fm 1? amm?r dupiivuh' qfcompluin! um! ufriw {rat-k.? .?wfuat 3 Expedited- I'riul within 7 months of 3 Standard - Trial withm [Il?lltt'k .tt? Defendant's response Defendant's rcxponac RELIEF REQL 1:51 IRCV. 04 2m 7) Page I of Case Document 1-2 Filed 05/29/20 Page 3 of 18 TECHNOLOGICAL CASE PROGRAM RPOSIEJ Ul' I ll ISMIW H) 4W unfit" ln. Km. . mm. .. .Hc? (bl/{t uniIW'mm and hock who?ltt?r .m it '1 hpcditcd - Trial ?llth months of 3 Standard - Trial muniln n: Defendant"~ Defendant's reaponic .IRE HLHG TIV BALTIMORE CITY. OR 8. IL TIJIORE THE 4PPROPRH TE BOX BELOW FOR BALTIMORE CITY (CHECK ONLY ONE) I Trial hO to .20 day: from IitniICk'. mam-ix :l-S?hn-?I Trial 210 days from first t'n :l-Standatc Trial 360 days from ?rst atisncr. 0 0 an Scheduling order enzcred by indix ?dunl judge. Asbestos >cltedultng order. Lead Paint Fill in: Birth Datc planintt ux bale Foreclmurcc .xclicduling order. limit-cltuttrci scheduling ordcr. COURT FOR BALTIMORE COUNTY \pcditcd Attachment Before Judgment. Declaratory Judgment: Simple). (Trial Date-9U days) Adxninistratiw Appeals. District Court Appeals and Jury Trinl Praycrx Guardianship. Injunction. Mandamus. Standard Condemnation. Confesst Judgments (Vacatedt. Contract. ?Trial Date-240 daysi Related Cases. Fraud and Intentational Motor Tmt. Other Personal Injury. Workers' Compensation 2153:. Extended Standard Asbestos. Lender Liability. Professional Malpractice. Serious Motor ion 0: tTrial Date-345 dayst Personal Injury Cases (medical and wage loss cxjacrt and out-ot-state witnesses (parties). and trial ot?t'wc or more days). State Insolvency. Compim Class Actions, Designated Io\ic Tort, Vluior Contracts. t'l'rial Date-450 days! Product Liabilities. Other Complex Cases. 4 .1 30:0 Dam Signature 20.VIICltacl (ilaas. tit]. "m - Baltimore MD 2120] ity State Zip Code CC-DCH-IIOZ (Rex. 20l?t Pagc 3 of} Case Document 1-2 Filed 05/29/20 Page 4 of 18 um 56H Ridge Driw hitc \lanlt. \lzti'}land 2 I62 Plaintiff IN THE S. HARRISON MARYLAND Police (.?ommissimer Baltimore Police Department FOR BALTIMORE 00] E. Fayette Street Baltimore. \laryland 21202 And Case No; a JAMES (EILLIS Deput) Police (?ommissioner Of?ce of Legal Affairs Baltimore Police Department 60] E. Fayette Street Baltimore. Maryland 21202 .\nd MARTIN BARTVESS Major Baltimore Police Department 601 E. Fa) ette Street Baltimore. Mainland 21202 And POOLE Lieutenant Baltimore Police Department 60] E. Fayette Street Baltimore, Maryland 21202 A nd LEACH Case Document 1-2 Filed 05/29/20 Page 5 of 18 I icutcnant Baltimore Police Department Mil IL. Fa} ctte Street Baltimore. \Ianland 2l202 Defendants a i. a. at it it COMPLAINT DEMAND FOR JL RY TRIAL CONN-.8 plaintiff. .\ndre Bonaparte (hereinafter "Plaintiff'l. b} and through his undersigned counsel and pursuant to Fed. R. Cit. P. 8 and Mar, land la?. IlL?lCl?} files this Complaint for Reliefand sues defendants. Commissioner Michael S. Harrison larrison"). Deput) Police Commissioner James Gillis Major Martin Bartness ("Bartness"). Lieutenant Michael Poole (?Poole?). and Lieutenant l?rict kt I each in their personal and of?cial capacities for money damages and iniunctit relief and for reasons state the following: AND JURISDICTION l. all times relevant herein. Plaintiff was a higth decorated and respected police commander of the Baltimore Police Department (hereinafter having achieved the ?nal rank of Deputy Police Commissioner. 2. At all times relex ant herein. defendant Harrison was emplo} ed by the 131?!) as the police commissioner ofBaltimore and was responsible for the operation and management ofthe BPD. 3. At all times relevant herein. defendant Gillis. no? deput} police commissioner. as empIO} ed the BPD as the chiefofstaff for defendant Harrison and assisted. as ell as implemented and carried out. the operation and management of th.? BPD. Case Document 1-2 Filed 05/29/20 Page 6 of 18 4 \t all times relevant herein. defendants Rartness. Poole. and I each new police commanders of the BPD and served as middle and upper management police Administrator: on defendant Harrison's administration and were responsible tor assisting Harrison in the operation and management ofthe BID. 5. all times relevant herein. Harrison. Gillis. Poole. and leach teollectn cl) ?Defendants'l ere \vorking and on dut}. Defendants. as detailed bClO?. .ietetl with actual malice ?hit the intent to make Plaintiff unemplovahle. as vvell to humiliate. embarrass. and cause Plaintiff economic and non-economic distress. 0. Pursuant to the Annotated Code of Maryland. Courts 8; Judicial Proceedings Article. Section 5-304. notice of the facts giving rise to this Complaint as properl} served upon the Cit) Solicitor of Baltimore. Venue andjurisdietion are proper as the facts giving rise hereto occurred. and the Defendants~ regularl} conduct business in. Baltimore Cit}. FACTS COMMON TO ALL Plaintiff. Andre Bonaparte. hereby incorporates and re-alleges paragraphs 1 through 6 in this facts section as if full} set forth in its entirety. 7. Plaintiff vvas hired by BPD on October 7. 1987 as a police officer trainee. He served as a police of?cer and police commander in various units and capacities until his initial retirement as Deput} Major on September I. 2008. 3. Plaintiff retired in good standing in 2008 and was afforded all of the privileges and bene?ts of retirement such as. but not limited to. re -emplo_\ ment vvith the BPD and other law enforcement agencies. a clean Maryland Police 'l?raining Commission Case Document 1-2 Filed 05/29/20 Page 7 of 18 t?enilication. an abtlm to maintain a Maryland handgun pennit. and eligibility to rceehe .i federal handgun permit hen the la? took etlect. On January ZUIK. Plaintitl returned to tlte BPD from retirement as one of No Police t?ommissmners under former Police Commissioner Daml DcSottsa thereinafter He sen ed in that role until his termination on March 30. 2019. 10. Prior to his retirement. honm er. PlaintilTinitiated disciplinary action against a subordinate police commander as part ofhis duties as .1 BPD commander in October 2018. in retaliation. the subordinate police commander initiated a bogus internal complaint against Plaintiff. Both actions ?ere referred for im estigation for potential disciplinary action. 11. Betneen Janan and March of 2019. allies of the subordinate police commander disciplined by Piaintiff? namer Banness. Poole. and Leach devised a plan to damage the reputation of Plaintiff. Based on information and belief. with the consent and knowledge of Gillis. Banness. Poole, and Leach located an expunged domestic incident involving Plaintiff and his wife. Without court order and/or other lawful authorization. Banness. Poole. and Leach published Plaintiff expunged file and?or information to the public on social media and other media forums. 13. On March 22. 2019. despite being aware that Plaintiff had an open unresoit- ed intemal investigation and despite being informed and-?or aware that the pending internal investigation against Plaintiff would be rendered frivolous and unfounded. Harrison. ?ilh the help. planning and implementation ofGillis and Chief Legal Counsel Daniel Beck. disciplined Plainti?'and terminated him from the BPD without affording him the Due Process guaranteed b) the Fourteenth Amendment to the Case Document 1-2 Filed 05/29/20 Page 8 of 18 \tatest and ~\rtic e .t section lo-l ltbl. ofthe Public Local lam of llalttmore (?ity ?high is state statute guaranteeing Plaintiffa hearing prior to be being tenntnated lot discipline. lissentially. Harrison. t'nllis. and based on infomtation and belief. Chief I otmsel Heck. collectiwl) conspired to tamish Plaintiffs employ ability as detailed di?me. \tithout gi\ ing Plaintilf an opportunity to clear ltis name and or defend against the t'rivolou and ttnfounded intental im cstigation lodged against hint. Harrison. nh the urging and assistance ofUillis and Chief Legal Counsel Beck. terminated Plaintiff as though it ?as an at-uill termination knowing it \tould have tlte effect of a tenntnatton for cause - i.e. discipline - because Plaintiff had an open internal imestigation at tlte titnc oftennination that he was prc\ented front contesting. 15. After being infomted that he was terminated from the BPD. Plaintiff requested that he be allowed to use his accumulated compensatory leave time'days to extend the date of his temtination so that he could hax'e time to ?le paperwork to initiate his second retirement. Chief Legal Counsel Beck. at the urging ofllarrison and Gillis. called Plaintiffon March 26. 2019 and denied Plaintiffs request. Plaintiffs medical eneftts for himself and his family were temtinated on March 30. 2010. Plaintiff ?as forced to file his second retirement from the BPD. l6. Plaintiffsubsequently requested a letter of good standing from the BPD so that he could apply for his Maryland and federal LEOSA handgun permits. He also requested the letter of good standing so that he could apply for other lau enforcement positions. Plaintiff was denied a letter of good standing. He was informed that despite never being offered a hearing and despite being told that the open intemal imestigation Case Document 1-2 Filed 05/29/20 Page 9 of 18 \mnid lx- tendered unfounded. his separation from the BPD ?to not in good standing because he ?at terminated by Harrison. ?ith the help and of(iillis and (?hief egal ('ounxel lteek. \slule an open internal investigation was pending. l7. Knouing that Plaintiffs tennination \touid be regarded and or l1d\ the effect of being a temtination for cause and or discipline. Defendants actions described abo\ has caused Plaintiff irreparable harm to his reputation and ability to gain la? enforcement emplo; ment. l8. Defendants actions haxe endangered Plaintiff and his family by depth mg him the ability to acquire a Maryland and federal LEOSA handgun pemiit protect against criminal suspects desiring to retaliate against Plaintiff for enforcement actions taken \thile Plaintiff as a swom police of?cer. Defendants actions have also permanently deprived Plaintiff an opportunity to gain law enforcement employment andfor further certification by the Mary land Police Training Commission. COUNT (Violation of Federal Constitutional Rights - 42 1983) Plaintiff. Andre Bonaparte. hereby incorporates and realleges paragraphs 1 through 19:5 iffuliy set forth in this Count I. 20. Plaintiff further states that Defendants violated his constitutional rights guaranteed under the Fourteenth Amendment to the United States Constitution ?hen they committed acts described in ayemients 1 through 19. 21. Further supporting this count is the fact that the frivolous internal investigation against Plaintiff by the subordinate police commander as. based on infomtation and belief. encouraged. engineered. and implemented by Bartness. Poole. Case Document 1-2 Filed 05/29/20 Page 10 of 18 and I each tilt the consent and approval ot'llam'son. Liillis. and Chief Legal Back. ?a The frivolous intemal investigation against Plaintilfinv oly ed fabricated allegations of racial discrimination \yltich negatnely affects Plaintiffs employnhility as .1 la? enforcement e\ccuu\e and or eonunander. Defendants intentionally denied Plaintiff a name clearing hearing knovving he had an open internal investigation because they deliberately devised a plan to end Plaintiffs ability to gain a la? enforcement job. 33. Defendants knevv that pursuant to Sections 1104.01.00 cl .wq. of the Code ofMary land Regulations (hereinafter Plaintiff would be unemployable by any Maryland lau enforcement agency when they temtinated Plaintiff \vilh an open internal investigation because CONLXR required that Plaintiffs certi?cation and or by the Maryland Police Training Commission be flagged as having left a police agency in bad standing. 24. Pursuant to COMAR, all Maryland law enforcement agencies are required to conduct a review of former police applicant?s prior employment and/or disciplinary ?les. Defendants knew that Plaintiff would be prohibited from being hired as a om police executive. commander. and or police of?cer under .\'laryland lavv if they temtinated Plaintitfuhile he had an open intemal investigation. 25. Defendants terminated Plaintiff with the express intent to end his lau enforcement career. Even knovving that Plaintiff was guaranteed a heating under Article 4, Section 16-] lib) ofthe Public Local Laws of Baltimore City to defend himselt?against termination that was disciplinary in nature and?or had the effect of being tcmtinated for Case Document 1-2 Filed 05/29/20 Page 11 of 18 reasons. Defendants deliberately dismissed Platintiffin a matuter that rendered him unable to saw his law career with andlor elsewhere. 26. Defendants denied Plaintiff Due Process when they terminated Plaintiffin the manner described abm e. Harrison and Gillis also violated Plaintiffs constitutional rights hen they tcnninatcd and or caused and-or contributed to Plaintiffs termination and treated him different based on its race. 38. When Harrison and Uillis had Chiefl egal Counsel Beck contact Plaintiff to deny Plaintiffs request to use compensatory leave time days accumulated during his service as Deputy Police Commissioner. they issued the denial knowing that they afforded Caucasian Commanders former Lieutenant Colonel Bauer by way of example - an opportunity to use compensatory leave time?days to extend termination and "or retirement dates. hief.\latt Jablow. by way of further example. was also allowed to use compensatory leaye time 'day to extend his termination and/or retirement and'or resignation from the BPD. 29. Plaintiffs temtination Defendants. by their respective actions in causing front the BPD. deliberately and intentionally caused Plaintiff signi?cant economic and non-economic damages. including. but not limited to emotional distress. 30. As a direct and proximate result of Defendants actions. Plaintili'has suffered and will continue to suffer great embarrassment. humiliation. and loss of economic and employment opportunities. WHEREFOKE plaintitf. Andre Bonaparte. demandsjudgment in excess of Seventy-Five Thousand Dollars in compensatory damages. punitite Case Document 1-2 Filed 05/29/20 Page 12 of 18 damages in an amount to be determined it} atur}. Plus imt?rcst and costs. against Helmdanh tor \1olattng his federal constitutional rights guaranteed under the l?ouneentlt ofthe l'nited States Constitution. ll (Defamation) Plaintiff. \ndre Bonaparte. hereb) incorporates and re-alleges paragraphs 1 through 30 as if full) set forth in this Count II: 3 l. Plaintiff further states that based on information and belief. Defendants conspired it'n one another and assisted one another hen each acted in concert to release false and fabricated information to the public attd'or Plaintiffs perspectite law enforcement emplo_\ ers that Plaintiff was engaged in misconduct and unemployablc as a police executit'e. commander. and 'or police of?cer. 32. Based on information and belief. Bartness. Poole. and Leach. with the consent and assistance of Gillis and Chief Legal Counsel Beck. released Plaintiffs expunged domestic incident ?le on social media and other media forums \tith the purpose to humiliate. embarrass. and damage the professional reputation of Plaintiff. 33. Harrison. with the assistance and urging of Gillis and Chief Legal Counsel Beck. terminated and'or caused Plaintiff to be terminated with an open intemal ititestigation for the express purpose to publish defamatoq infonnation about Plaintiff to perspective la? enforcement employers. Defendants knew that by terminating Plaintiff with an open internal investigation. state OMAR regulations required that his Mar} land Police Training Commission certification be negatively ?agged. They further idle? aha: under the same COMAR regulations. perspective law enforcement emplo) ers ould. and were required by Maryland law. to inspect Plaintiffs employment and disciplittar} t?t?tes. - A Case Document 1-2 Filed 05/29/20 Page 13 of 18 Defendants that by not affording PlaintitTan opportunity to fight the internal investigation. the bogus and unfounded allegations lodged against him \tnuld remmn uncontested fem er and Plaintiff \muld suffer life-long humiliation. embarrassment. and disqualification from further la? enforcement opportunities. ?4 Defendants actions were motivated by actual malice. hate. ill ?in and Mill ex il intentions deliberater designed to intlict harm upon the Plaintiff. )Rh plaintiff. Andre Bonaparte. demands judgment in excess of smenty-Fiyc l?housand Dollars (371000.00) in compensatory damages. punitiye damages in an amount to be determined by plus interest and costs. against Defendants for Defamation. Ill (Invasion of Privacy - False Light and Intrusion L'pon Seclusion) Plaintiff. Andre Bonaparte. hereby incorporates and re-alleges paragraphs 1 through 34 as if fully set forth in this Count 111. 35. Plaintiff further states that Defendants conspired \yith one another and assisted one another when each acted in concert to release false and expunged information to the public and/or perspective law enforcement agencies that Plaintiff was engaged in misconduct as described in avemtevtts through 34. 36. Said releases of information to the public and perspective law enforcement agencies were deliberate and highly offensive to Plaintiff and placed the Plaintiff in a negative and false light. Defendants had actual knowledge of the falsity and unfounded nature ofthe aliegations lodged against Plaintiff. and said communicates. especiaily the unearthing of expunged domestic allegations, were made in a manner which \yould have been highly offensive to any reasonable prudent person similarly Situated. Case Document 1-2 Filed 05/29/20 Page 14 of 18 Defendants actions ?ere motixated by actual malice. hate. ill will and ?uh 0 ll intentions deliberately designed to in?ict harm upon the Plaintiff. ll plaintill?. .\ttdre Bonaparte. demands in excess of Sex enty ?l housand Dollars in compensatory damages. punitiye damages in an amount to he detcmtined by ajury. plus interest and costs. against Defertdants for lm asion of Privacy - False Light and lntrusiott L'pon Seclusion. IV (Interference with Economic Relationship) Plaintiff. Andre Bonaparte. hereby incorporates and re-alleges paragraphs 1 through 37 as if fully set forth in this Count IV. 38. Plaintiff further states that Defendants conspired with one another and engaged in a course of conduct. as mentioned in ayerments I through 37. to deliberately and purposefully interfere with and cause financial loss to Plaintiffs lawful business and economic rights without any justi?able cause or right: 39. Speci?cally. as described in averments I through 37. Defendants willfully and intentionally denied and/or caused the denial ofPlaintift's compensatory leai request as a result of racial animus with the express purpose to cause financial harm and economic loss to Plaintiff. 40. Additionally. Defendants willfully and intentionally temtinated and or caused and?or contributed to Plaintiffs termination as described above with the express purpose to cause ?nancial harm and economic loss to Plaintiff. Tltey kneu that terminating Plaintiff in the above described manner \yould cause Plaintitf to be rejected from any further law enforcement opportunities the state of Maryland due to AR regulations. Case Document 1-2 Filed 05/29/20 Page 15 of 18 l. a direct and proximate result ofDefendants intentional acts as described in .oennents I through l?laintitflost numerous and important Ian enlorcement ioh opportunities because ot?hjs inabilit} to appl}. Defendants denied Plaintiff a letter of good standing from the BPD b} using tlteir ovvn engineered tenninanon of l?laintit'fvvhile he had an open internal investigation. 43. Defendants actions vvere motivated b) actual malice. ill vvill. hatred. and evil intentions ?ill: the express purpose to in?ict harm on the Plaintiff. plaintitT. Andre Bonaparte. demandsjudgment in excess of Seventy-Five Thousand Dollars (375.000.00) in compensatory damages. punitiv damages in an amount to be determined by ajur}. plus interest and costs. against Defendants for Interference vtith Economic Relationships. (Article 24 of the Maryland Declaration of Rights) Plaintiff. Andre Bonaparte. hereby incorporates and re-alleges paragraphs I through 42 as if fully set forth in this Count V. 43. Plaintiff further states that Defendants violated his state constitutional rights guaranteed under the .\'Iaryland Declaration ofRights vvlten they terminated and'or caused and. or contributed to the termination of plaintiffs employment vvitit the BPD in the manner described in avemtents 1 through 42 without Due Process and in violation of state statutory iatv. namely Article 4. Section 16-] 1(b) of the Public local Lavvs of Baltimore it). 44. Defendants deprived Plaintiff of ltis liberty interest in protecting his gUOd name and reputation for employment. Defendants denied Plaintiffl)ue Process of law Case Document 1-2 Filed 05/29/20 Page 16 of 18 hen the\ tailed to afl?ord Plainti??a name clearing hearing and or .1 ltt?JrlHEJ E'lilf??t?lt'x?d under state lavv. 45 Defendants acted m'th actual malice. irate. ill ?ill and ev il intentions with the express purpose to in?ict hann upon the Plaintiti'. Defendants actions \vere madc mtli a total disregard for Plaintiffs personal libert) and constitutional rights. ll .RFFORE plaintiff. Andre Bonaparte. demands judgment in excess of ive Thousand Dollars in compensatory damages. punitive damages in an amount to be detemtined by ajur}: plus interest and costs. against Defendants for iolating his constitutional rights guaranteed under Article 24 of the Mar} land Declaration of Rights. VI (Intentional Infliction of Emotional Distress) Plaintiff. Andre Bonaparte. hereby incorporates and realleges paragraphs 1 through 45 as if fully set forth in this Count 46. Plaintiff further states that he suffered and still suffers severe and persistent emotional distress as a result of the illegal and malicious actions perpetrated b} Defendants described in averments 1 through 45. Defendants actions described in avennents 1 through 45 were speci?cail} directed at the Plaintiff ?in the express purpose to cause the Plaintiff severe emotional distress. Defendants effectively made Plaintiff unemployable b} terminating him \xith an open internal investigation without Due Process as guaranteed b} state lavv and the L?nited States Constitution. 47. Defendants actions did cause Plaintiff to suffer a severely disabling emotional response tie. a depression. among other things) which required intervention and/or consultation. Case Document 1-2 Filed 05/29/20 Page 17 of 18 48. Defendant: acted utth actual malice. hate. ili will. and ith e\ i' put-pow ith the intent to nurse Plaintiff hann. Defendants actions ere committed with a total distegartl for l?lnintitt's \vellbetng. \VllERl plaintiff. \ndre Bonaparte. demandsjudgment itt excess of Seventy -l he lhousand Dollars (575.000.00i in compensatory damages. punitive damages in an amount to be detennined by ajury. plus interest and costs. against Detendmu: for for intentional lt?liliCli-Jn ofEmo:ional Distress. (301 NT VII (Negligence) l?laintitf. Andre Bonaparte. hereby incorporates and re-alleges paragraphs through l9 as if fully set forth in this Count \711. Plaintiff further States. in the altemative. that Defendants acted negligently hen they terminated Plaintiffs employment with the BPD in the manner described above in paragraphs 1 through 19. 50. Defendants terminated Plaintitfwith an open internal investigation and denied him an opportunity to defend against the frivolous and unfounded internal investigation prior to termination. 51. Delettdan:s actions deprived Plaintiff an opportunity to have and or resume his law enforcement career. Their actions further denied Plaintiff an opportunity to obtain a state and federal handgun pemtit and denied Plaintiffan opportunity to retire from the BPD in good standing with all the benefits and privileges that come from retirement. 52. Defendants acted with actual malice, hate. ill will and evil intentions with the express purpose to inflict harm upon Plaintiff. Case Document 1-2 Filed 05/29/20 Page 18 of 18 HFRHORI: plaintill?. Andre Bonaparte. demands iudgment in ewes: of Sexem} -Fi\'e lhousund Dollars (875.000.00) in compensatory damages. punitive damages in an amount to be delemiined by a My. plus interest and costs. against Defendants for negligence. Respectfully submitted. A v' Michael E. Glass. Esq. 9106200098 The Michael Glass Law Firm 201 N. Charles Street. Suite 1900 Baltimore. MD 21201 (4l0) 779-060; (410) 814-4604 molass timelasslauxcom Attornet?for Plaimi? FOR JURY TRIAL Plaintiff. Andre Bonaparte. respectfully requests a Jury Trial on all counts in this Complaint. .?Aichacl Glass