Case Document 1 Filed 04/30/20 Page 1 of 17 PageID 1 Pro Se 14 (Rev, 12.?16) Complaint for Violation of Civil Rights (Prisoner) UNITED STATES DISTRICT COURT for the MAME Districtof ?hid/:1 [Ei?d?d? Division ?53! he ix: Stir man/at Plaintgf?s) (PI/rite thefin?! name ofeach plaintijfwno is?i?ing this compim'nt. Ifthc names ofalt' (In: plainti??s cannot ?t in the space abut-e, please write "see attached in rhespace and attach an additional page with titejirl! It's! of names.) I Fl Manama; l. L. De??ndann?s) (Write name ofeach defendant who is being sued. bathe names of rd! the de?na?ants cannotfit in the Space above, please write "see attached in the space and attach an additional page with {befall list ofnames. Do not include addresses here.) Case No. (u 7.0 g? Old-L" W) (to be?t?i?ea' in by the Clerk '5 ij?ice) CONIPLAINT FOR VIOLATION OF CIVIL RIGHTS (Prisoner Complaint) Federal Rules of Civil Procedure 5.2 addresses the privacy and security concerns resulting from public access to electronic court ?les. Under this rule, papers ?led with the court should not contain: an individual?s full social security number or full birth date; the full name of a person known to be a minor; or a complete ?nancial account number. A ?ling may include only: the last four digits of a social security number; the year of an individual?s birth; a minor?s initials; and the last four digits ofa ?nancial account number. Except as noted in this form, plaintiff need not send exhibits, af?davits, grievance or witness statements, or any other materials to the Clerk?s Of?ce with this complaint. In order for your complaint to be ?led, it must be accompanied by the ?ling fee or an application to proceed in forma paupen's. NOTICE Page 1 of II Case Document 1 Filed 04/30/20 Page 2 of 17 PageID 2 Pro Se 14 (Rev. 12/16) Complaint for Violation of Civil Rights (Prisoner) I. The Parties to This Complaint A. The Plain?ff(s) Provide the information below for each plaintiff named in the complaint. Attach additional pages if needed. . 1 Name Zia tone time All other names by which I you have been known: ID Number Current Institution [Bf?dgfd (?mid-l 33-? Address (21:00 Cap?? 11? Afid_ . (mega 32512.1 City State Zip Code B. The Defendant(s) Provide the information below for each defendant named in the complaint, whether the defendant is an individual, a government agency, an organization, or a corporation. Make sure that the defendant(s) listed below are identical to those contained in the above caption. For an individual defendant, include the person?s job or title ({fknown) and check whether you are bringing this complaint against them in their individual capacity or of?cial capacity, or both. Attach additional pages if needed. Defendant No. 1 Name Nd (A INCH Job orTitle (aft-now) Shani-Iii Etcuhkci C(hm?r?cl Shield Number Employer Address Eduard Carmel 3 5+8er nl? Home ?100 pactL ave Trtusuiuc. LL 32,130 City State Zip Corie Mlndividual capacity m/Of?cial capacity Defendant No. 2 Name Job Title Shield Number Employer Address 011' State Zip Code El Individual capacity Of?cial capacity PageZof ll Case Document 1 Filed 04/30/20 Page 3 of 17 PageID 3 1P?cllnang 2 who (0155 rum/? Lt?iouwc, 6. MW 3% 46/7,: l. 63/ 12% Jade WE: AP (309$ 0" PW 3: q, Secm R. 51/7 - Jo. ?awm?w Davon 1E. (mo ?5 Case Document 1 Filed 04/30/20 Page 4 of 17 PageID 4 Pro Se l-?l (Rev. i2il6) Complaint for Violation ofCix-?i! Rights (Prisoner) II. Defendant No. 3 Name Job or Title Shield Number Employer Address ca;- EI Individual capacity Defendant No. 4 Name State El Of?cial capacity Zip ode Job 01? Title (Jknou'a) Shield Number Employer Address City Individual capacity Basis for Jurisdiction Stare El Of?cial capacity Zip Code Under 42 U.S.C. 1983, you may sue state or local officials for the ?deprivation of any rights, privileges, or immunities secured by the Constitution and [federal laws]." Under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 US. 388 (I 971), you may sue federal officials for the Violation of certain constitutional rights. A. Are you bringing suit against (check at! that apply): Federal officials (a Bivens claim) lg/State or local of?cials (a 1983 claim) B. Section 1983 allows claims alleging the ?deprivation of any rights, privileges, or immunities secured by the Constitution and [federal laws]." 42 U.S.C. 1983. lfyou are suing under section 1983, what federal constitutional or statutory right(s) do you claim is/are being violated by state or local of?cials? +h ilmc'ntl manl- C. Plaintiffs suing under Bit-?ens may only recover for the violation of certain constitutional rights. If you are suing under Sirens, what constitutional right(s) do you claim is/are being violated by federal officials? Fag-:3 of ll Pro Se l-i (Rev. 12/l6) Complaint for Violation of Civil Rights (Prisoner) Case Document 1 Filed 04/30/20 Page 5 of 17 PagelD 5 Section 1983 allows defendants to be found liable only when they have acted ?under color of any statute, ordinance, regulation, custom, or usage, of any State or Territory or the District of Columbia.? 42 U.S.C. 1983. If you are suing under section 1983, explain how each defendant acted under color of state or local law. If you are suing under explain how each defendant acted under color of federal law. Attach additional pages if needed. 'DijiCtaanl United Siam Consti?ruitm liCDc guanine; Prisoner Status Indie El El CI ate whether you are a prisoner or other confined person as follows (check ail that apply): Pretrial detainee Civilly committed detainee Immigration detainee Convicted and sentenced state prisoner Convicted and sentenced federal prisoner Other {explain} Statement ofClaim State as briefly as possible the facts of your case. Describe how each defendant was personally involved in the alleged wrongful action, along with the dates and locations of all relevant events. You may wish to include further details such as the names of other persons involved in the events giving rise to your claims. Do not cite any cases or statutes. If more than one claim is asserted, number each claim and write a short and plain statement of each claim in a separate paragraph. Attach additional pages if needed. A. If the events giving rise to your claim arose outside an institution, describe where and when they arose. 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Stuart and Streaj clot: i0 HM m?ihh?eldi?fi 04? iwtpot?raol (QCUEHL "midin inimmaiim, Comicl?l?i ilnXitJrlilj. itat oi? dealln (loo to inhuman coruilions VI. Relief State brie?y what you want the court to do for you. Make no legal arguments. Do not cite any cases or statutes. If requesting money damages, include the amounts of any actual damages and/or punitive damages Claimed for the acts alleged. Explain the basis for these claims. Federal investigation 09 ldruiclalions. 'l?umiive damages as the Court deems Just and pm?? 13:1ch of 11 Case Document 1 Filed 04/30/20 Page 12 of 17 PageID 12 Pro Se 14 (Rev. 1315} Complaint for Violation ol'Civil Rights (Prisoner) VII. Exhaustion of Administrative Remedies Administrative Procedures The Prison Litigation Reform Act 42 U.S.C. l997e(a): requires that action shall be brought with reSpect to prison conditions under section 1983 of this title, or any other Federal law, by a prisoner con?ned in any jail, prison,? or other correctional facility until such administrative remedies as are available are exhausted.? Administrative remedies are also known as grievance procedures. Your case may be dismissed if you have not exhausted your administrative remedies. A. CS Did ur claim[s) arise while you were con?ned in a jail, pIiSOn, or other correctional facility? d: EINO If yes, name the jail, prison, or other correctional facility where you were confined at the time of the events giving rise to your claim(s). 3313110? A Certain) jail Does the jail, prison, or other correctional facility where your claim(s) arose have a grievance procedure? Yes I: No [i Do not know Does the grievance procedure at the jail, prison, or other correctional facility where your claim(s) arose cover me or all of your claims? Yes El No El Do notknow If yes, which c1aim(s)? Sec grounds 1-4 (minimal) Page60f ll Case Document 1 Filed 04/30/20 Page 13 of 17 PageID 13 Pro Se 14 {Rev 12/16} Complaint for Violation of Civil Rights (Prisoner) D. Did you ?le a grievance in thejail, prison, or other correctional facility where your claim(s) arose concerning the facts relating to this complaint? '1 Ifno, did you tile a grievance about the events described in this complaint at any otherjail, prison, or other correctional facilitygrievance: I. Where did you ?le the grievance? um. I 2. What did you claim in your grievance? l' 3. What was the result, if any? I 4. What steps, ifany, did you take to appeal that decision? Is the grievance process completed? If not, explain why not. {Describe all efforts to appeal to the highest level oft/:9 grievance process.) NIH Page 7 of 11 Case Document 1 Filed 04/30/20 Page 14 of 17 PageID 14 Pro Se [4 (Rev. [2/16) Complaint for Violation of Civil Rights (Prisoner) Ifyou did not file a grievance: I. If there are any reasons why you did not ?le a grievance, state them here: Tin/tr (anathema and Retaliahm bur Siaii 2. Ifyou did not ?le a grievance but you did inform of?cials of your claim, state who you informed, when and how, and their re5ponse, if any: lamina am other im?na?tCS ?lhqu guard tilting tit?) Please set forth any additional information that is relevant to the exhaustion of your administrative remedies. Grm'uancc PYOCcdurt. i5 unreliable at BCJ and lCSUlliS ih Yettl?ro?j ?ChonS lala Sign (Note: You may attach as exhibits to this complaint any documents related to the exhaustion of your administrative remedies.) Previous Lawsuits The ?three strikes rule? bars a prisoner from bringing a civil action or an appeal in federal court without paying the ?ling fee if that prisoner has ?on three or more prior occasions, while incarcerated or detained in any facility, brought an action or appeal in a court of the United States that was dismissed on the grounds that it is frivolous, malicious, or fails to state a claim upon which relief may be granted, unless the prisoner is under imminent danger ofserious physical injury.? 28 U.S.C. 1915(g). To the best of your knowledge, have you had a case dismissed based on this ?three strikes rule?? If yes, state which court dismissed your case, when this occurred, and attach a copy of the order if possible. Page 3 of ll Case Document 1 Filed 04/30/20 Page 15 of 17 PageID 15 Pro Se 14(Rev. 12/16) Complaint for Violation ot?Civil Rights (Prisoner) A. Have you ?led other lawsuits in state or federal court dealing with the same facts involved in this action? El Yes g/No B. If your answer to A is yes, describe each lawsuit by answering questions I through 7 below. is more than one [mt-suit, describe the additional lawsuits 0t? anotlret?pnge, using the samefommt.) 1. Parties to the previous lawsuit v' Plaintiffts) I Defendant(s) 2. Court (if federal court, name the district; l'fstate com-t, name the county and State) We M/n Docket or index number Lu 4. Name of Judge assigned to your case I Approximate date of ?ling lawsuit p: 6. Is the case still pending? Yes No lfno, give the approximate date ofdisposition. jV/? 7. What was the result of the case? (For exan'tple: this the case dismissed? Was judgment entered in yourfmror? Hits the case appealed?) C. Have you ?led other lawsuits in state or federal court otherwise relating to the conditions of your imprisonment? Pagc9of ll Case Document 1 Filed 04/30/20 Page 16 of 17 PageID 16 Pro Se 14 (Rev. 12/16] Complaint for Violation ofCivil Rights (Prisoner) m/Yes D. If your answer to is yes, describe each lawsuit by answering questions 1 through '7 below. (Ifthere is more than one lawsuit, describe the additional lawsuits on anotlterpage, using the samefommt.) 1. Parties to the previous lawsuit Plaintif?s) :Fl MCUC Defendant(s) 64-310 ?art? 21 Court (if federal court, name the disn'ict; court, name the county and State) Ix) . . l\ . Baa) Cour/mot Honda 3. Docket or index number Don't 4. Name ofJudge assigned to your case Don?: imam) 5. Approximate date of?ling lawsuit ZOli 6. Isth case still pending? [?ies If no, give the approximate date of disposition 7. What was the result of the case? (For example: l-Vas the case diwzt?ssed? entered in yam-favor? Was the case. appealed?) Still Pied-{nag Page 10 of ll Case Document 1 Filed 04/30/20 Page 17 of 17 PageID 17 Pro Sc 14 (Rev. Complaint for Violation ofCivil Rights (Prisoner) 1X. Certi?cation and Closing Under Federal Rule of Civil Procedure 11, by signing below, I certify to the best oftny knowledge, information, and belief that this complaint: (1) is not being presented for an improper purpose, such as to harass, cause unnecessary delay, or needlessly increase the cost of litigation; (2) is supported by existing law or by a nonfrivolous argument for extending, modifying, or reversing existing law; (3) the factual contentions have evidentiary support or, if speci?cally so identified, will likely have evidentiary support after a reasonable opportunity for further investigation or discovery; and (4) the complaint otherwise complies with the requirements of Rule 1 1. A. For Parties Without an Attorney 1 agree to provide the Clerk?s Of?ce with any changes to my address where case?related papers may be served. I understand that my failure to keep a current address on ?le with the Clerk?s Of?ce may result in the dismissal of my case. Date of signing: 4/ 26/2020 Signature ofPlaintiff Printed Name of Plaintiff :El M010 Prison Identification Ll?i?cs Prison Address QQO (13W Irma it 11212;; City State Zip ode B. For Attorneys Date of signing: Signature of Attorney Printed Name of Attorney Bar Number Name of Law Firm Address it}! State Zip Code Telephone Number E-mail Address Page llof ll