May Day Jay Day...May 6, 2006 Hartford Ct Bushnell Park

Hello Cannabis.com,

Captain Joint, High Times Freedom Fighter here, putting out the call to the troops, ... marijuana troops that is,

we are in the process of organizing a rally for May 6 in Bushnell Park, Hartford Ct. Freedom Rally for the legalization of marijuana. We could use the help of the Cannabis.com members to make this happen. People are needed to promote, help organize, spread the word, and come. People interested in helping can contact me at [email protected]

An Announcement for this event will be in the marijuana article in this Sunday's Hartford Courant 3/26/06... watch for it!

Any help you can send our way would be helpful, we are way under funded and are doing this in conjunction with the global marijuana march international.

On a lighter note, I have just filed the following paperwork in New Haven Federal court and this rally also will be a forum for discussion on this issue. We also are having some local politicians and LEAP.CC officers to speak...

Thank You,
David C*J Bunn
a/k/a
Captain Joint
Freedom Fighter, High Times

In March of 2003 the Holland Police, State Police, and a Task force
busted
in my doors and woke my family up with guns in their faces, My son woke
up with
6 guns in his face. Females were made to stand in front of all male
officers
before being allowed to get dressed. Guns were put to the dogs head in
front
of my grandson, then 2 years old, a door was slammed against a crib
with a 6
month old sleeping in it. The family was handcuffed and was not allowed
to
use the toilet. ALL CHARGES FROM THIS RAID WERE DROPPED AUGUST 16,
2005. The
police have refused to return our money and property. The reason all
charges
were dropped was because I was in the hospital on all three dates the
police
claimed they bought marijuana from me at my kitchen table at home. Here
is the
document being filed in Federal court today, any questions call me at
860
313 8020, and ask for CJ


UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT


DAVID BUNN; JUDITH BUNN; CHRISTENA : CIVIL DOCKET NO.
DODGE; DANIEL COLLINS; JAMIE DODGE; :
COUGAR JOHN BUNN; PHOENIX DODGE :
per proxima amici CHRISTENA DODGE; :
JUSTICE DODGE per proxima amici :
CHRISTENA DODGE, :
PLAINTIFFS, :
:
:
CHIEF KEVIN GLEASON; OFFICER :
KENNETH FITZGERALD; AGENT SCOTT E. :
HALEY, HOLLAND POLICE OFFICER JOHN :
DOE 1; HOLLAND POLICE OFFICER JOHN :
DOE 2; HOLLAND POLICE OFFICER JOHN :
DOE 3; HOLLAND POLICE OFFICER JOHN :
DOE 4; HOLLAND POLICE OFFICER JOHN :
DOE 5; HOLLAND POLICE OFFICER JOHN :
DOE 6; EASTERN HAMPDEN TASK FORCE :
AGENT JOHN DOE 1; EASTERN HAMPDEN :
TASK FORCE AGENT JOHN DOE 2; EASTERN :
HAMPDEN TASK FORCE AGENT JOHN DOE 3:
EASTER HAMPDEN TASK FORCE AGENT :
JOHN DOE 4; EASTERN HAMPDEN TASK :
FORCE AGENT JOHN DOE 5, in their official :
and individual capacities, :
DEFENDANTS. :

COMPLAINT

PRELIMINARY STATEMENT
1. This action is brought by plaintiffs against defendants, who acting
under
color of state law, charter, ordinance, regulation, custom or usage,
have
unlawfully violated the plaintiffsâ?? civil and due process rights
by falsely
arresting and imprisoning, retaliating against them and intentionally
inflicting
emotional distress upon the plaintiffs in violation of their civil
rights.
NATURE OF ACTION
2. This action arises under Title 42 U.S.C. §§ 1983, and 1988; the
First,
Fourth and Fourteenth Amendments to the United States Constitution and
state
common law.
JURISDICTION
3. This court's jurisdiction is invoked pursuant to Title 28 U.S.C.
§1331,
§1343, §1657, §2201 and §2202; and the aforementioned constitutional
provisions. Plaintiffs further invoke the pendent jurisdiction of this
court to hear
and decide claims arising under state law. The amount in controversy
exceeds
Fifteen Thousand Dollars ($15,000.00), excluding interests and costs.
PARTIES
At all relevant times, the plaintiff, JUDITH BUNN, was a resident of
the
State of Connecticut and was a citizen of the United State of America.
At all relevant times, the plaintiff, DAVID BUNN, a.k.a. â??C.J.
BUNNâ?�, was a
resident of the State of Massachusetts and was a citizen of the United
State
of America.
6. At all relevant times, the plaintiff, CHRISTENA DODGE, was a
resident of
the State of Massachusetts and was a citizen of the United State of
America.
7. At all relevant times, the plaintiff, JAMIE DODGE, was a resident of
the
State of Massachusetts and was a citizen of the United State of
America.
8. At all relevant times, the plaintiff, PHOEONIX DODGE, was a minor,
and
resident of the State of Massachusetts and was a citizen of the United
State of
America.
9. At all relevant times the plaintiff, JUSTICE DODGE, was a minor, and
resident of the State of Massachusetts and was a citizen of the United
State of
America.
10. At all relevant times, the plaintiff, DANIEL COLLINS, was a
resident of
the State of Massachusetts and was a citizen of the United State of
America.
11. At all relevant times, the defendant, CHIEF KEVIN GLEASON, was a
resident of the State of Massachusetts and a citizen of the United
States of
America, and was the Chief of Police of the Holland Police Department
in Holland
Massachusetts and is sued in his individual and official capacity.
At all relevant times, the defendant, OFFICER KENNETH FITZGERALD, was a
resident of the State of Massachusetts and a citizen of the United
States of
America, and was an officer of the Holland Police Department in
Holland,
Massachusetts and is sued in his individual and official capacity.
At all relevant times, the defendants, HOLLAND POLICE OFFICERS JOHN DOE
1,
2, 3, 4, 5, 6 were residents of the State of Massachusetts and were
officers of
the Holland Police Department in Holland, Massachusetts and are sued in
their individual and official capacities.
At all relevant times, the defendant, AGENT SCOTT E. HALEY, was a
resident
of the State of Massachusetts and a citizen of the United States of
America,
and was an Agent for the Palmer Police Department, in Palmer
Massachusetts,
and is sued in his individual and official capacity.
At all relevant times, the defendants, EASTERN HAMPDEN TASK FORCE
AGENTS
JOHN DOE 1, 2, 3, 4, 5, were residents of the State of Massachusetts and
were
Agents for the Eastern Hampden Task Force, in Palmer Massachusetts, and
are
sued in their individual and official capacities.
FACTS
David and Judith Bunn are married and at all relevant times, lived at
The
Property, Holland Massachusetts (hereinafter, â??The
Propertyâ?�).
Christena Dodge is the daughter of David and Judith Bunn and at all
relevant
times, lived at The Property with her husband Jamie Dodge and their two
minor children Phoenix Dodge and Justice Dodge.
Daniel Collins, is the son of Judith Bunn and at all relevant times,
lived
at The Property.
David Bunn, Judith Bunn, Daniel Collins, Christena Dodge, Jamie Dodge
and
Cougar John Bunn are activists for the legalization of marijuana for
medical
purposes.
David Bunn and Judith Bunn have participated in protests and have been
featured in magazines and newspaper articles that are in favor of the
legalization
of marijuana, and were on the Board of Directors for a pro-marijuana
group
called Mass/Cann.
David Bunn has a legal prescription for the use of marijuana for
medicinal
purposes.
On March 25, 2003, Defendant, Scott Haley, Lead Agent Eastern Hampden
County
Narcotic Task Force, filed an application for a search warrant and
signed an
affidavit in support of the application and a search warrant was
issued.
The search warrant sought to search the property at The Property, where
the
plaintiffs, were living.
The search warrant stated that defendant, Chief Gleason,
â??reported that the
Holland Police Department had been receiving information that a David
Bunn
whom lives with his family on Maybrook Road in that town was selling
marijuana
from the house.â?�
The search warrant referenced that David Bunn is an activist for the
legalization of marijuana is actively involved in public protests for
the
legalization of marijuana. Copies of newspaper articles in which David
Bunn was
interviewed were attached to the warrant.
Defendant, Haley, represented that he and Defendant Gleason recruited a
confidential informant and that the confidential informant reported to
(1) buying
marijuana from David Bunn, at the property at The Property; (2)
witnessing
the sale of marijuana at The Property; (3) knowing about David
Bunnâ??s
political activism; and (4) making controlled buys of marijuana from
David Bunn on
February 25, 2003, March 14, 2003, and March 23-25, 2003.
The warrant contains the following false and misleading representations
which were made knowingly and intentionally by defendants, Gleason and
Haley:
(a) The warrant describes a vehicle of the Bunn family vehicle that is
incorrect;
(b) The warrant sets forth the date of the controlled buy made by the
confidential informant on a date that the plaintiff, David Bunn, was in
the
hospital for a surgery;
(c) The Defendant, Haley, represented in the warrant that the
confidential
informant was inside the house at The Property and made three
controlled buys
from David Bunn, the last being 48 hours prior to the execution of the
search warrant, but David Bunn was in the hospital during the 48 hours
prior to
the execution of the warrant, and David Bunn was in the hospital from
March 20,
2003 through March 25, 2000. On March 25, 2003, David Bunn had major
surgery. David Bunn remained in the Harrington Memorial Hospital for
several days
after the surgery;
(d) The Defendant, Haley, represented in the warrant that the
confidential
informant made a controlled buy from David Bunn on February 25, 2003,
but
David and Judith Bunn were in Maine from February 22, 2003, through
February 25,
2003, on which date David Bunn went to the emergency room at the
Harrington
Memorial Hospital;
(e) The Defendant, Haley, represented in the warrant that the
confidential
information made a controlled buy from David Bunn on March 14, 2003,
but
David Bunn was at Harrington Memorial Hospital on such date, as he was
extremely
ill. During the times in which David Bunn was not in the hospital, he
was
sick in bed due to his severe illness;
(f) The Defendant, Haley, states that Chief Gleason and he recruited a
confidential informant together which is false;
(g) The search warrant states that the third controlled buy was made
within
48 hours of the writing of the search warrant, the search warrant was
written
and signed on March 25, 2003, however, in response to a Motion for
Discovery
in the criminal case, the defendants responded that the third buy was
made
on March 28, 2003, between 5:00 p.m. and 7:00 p.m. The search of the
house
occurred on March 27, 2003;
(h) The search warrant refers to a confidential informant, who does
not
exist and was fabricated by Haley and Gleason.
On March 27, 2003, the Holland Police Department in conjunction with
the
Eastern Hampden County Drug Task Force, (hereinafter, â??Task
Forceâ?�), executed
the search warrant (hereinafter, â??The Raidâ?�) at The
Property.
David Bunn and Judith Bunn were not home when the search warrant was
executed. David Bunn was in the hospital and Judith Bunn was visiting
David Bunn in
the hospital.
Present at The Property during The Raid was Christena Dodge, her
husband,
Jamie Dodge, and their children, Phoenix Dodge, who was two years old,
and
Justice Dodge who was six months old. Also home at the time of The Raid
was
Daniel Collins, age nineteen.
Cougar John Bunn, who was age fifteen, was living in the house at the
time
of The Raid but was at school during the time of The Raid.
On the morning of The Raid, approximately fifteen Task Force Agents,
including Agents John Doe 1, 2, 3, 4, 5 and Holland Police Officers
John Doe 1, 2,
3, 4, 5, 6, sergeants broke in the door of The Property. Two
Massachusetts
State Police were also present at the Property.
During The Raid, Jamie Dodge was woken up by an Agent pointing a gun in
his
face and screaming at him. In his bedroom, there were three other
officers
yelling at him. As soon as he got up out of bed he was handcuffed and
brought
into the kitchen where his wife and children were being held by other
officers.
During The Raid, the defendants, Officers and Agents yelled at the
infants
and pointed a gun to the childrenâ??s dogâ??s head and
threatened to shoot the
dog in front of the children. When the children were crying and
screaming, the
Officers and Agents yelled at Christena to quiet the children but when
given
a toy, a defendant Officer grabbed it from the child.
During The Raid, the defendant Officers and Agents, repeatedly yelled
and
swore at Christena Dodge, Jamie Dodge and Daniel Collins and destroyed
many of
the possessions and furniture in the house.
The defendants, Officers and Agents repeatedly swore, criticized and
made
fun of the plaintiffs while they were in handcuffs.
The defendants, Officers and Agents, made fun of Christena
Dodgeâ??s metal hip
and disability.
During the raid, the defendants, Officer and Agents, tracked mud, dirt
and
dog feces throughout the house from the outside.
David Bunn, who was the target of the raid, was in the hospital
recovering
from surgery, when he learned of the raid. David Bunn was so upset and
concerned for his family he attempted to leave the hospital and
disconnected
himself from his IV and life support.
As a result of the illegal raid, Christena Dodge and Judith Bunn were
charged with one count each of Massachusetts General Statutes c.94C
Section 34,
Possession of Marijuana Class D. The criminal charges were dismissed
in August,
2005.
No charges were ever filed against David Bunn, although he remains a
suspect
and his criminal case is considered still open.
Following the raid, the plaintiffs have been repeatedly, as follows:
(a) On March 28, 2003, the day after the raid, a complaint was made to
the
Holland Board of Health and the Department of Social Services, stating
that
the toilets in the house did not work dog feces had been found in the
house.
On that day, Sally Blais, a member of the Holland Board of Health,
Holland
Police Officer Pillsbury, and the Town engineer, went to the Property
and
checked the toilets (that all worked) and took a picture of the septic
tank.
(b) On March 29, 2003, a false complaint was made that the Bunnâ??s
dog,
killed a cat in the neighborhood and at approximately, 8:00 p.m. that
night,
several Holland police officers and two Police SUVâ??s arrived at
the property to
investigate the incident.
On January 9, 10, 2006, Defendant, Chief Gleason, threatened the
plaintiff,
Judith Bunn, that he as the Chief would be re-filing the charges
against her
and Christena and filing the charges against David Bunn.
(d) On January 29, 2006, Daniel Collins, was harassed by a Holland
Officer,
Badge #: 553, when he was pulled over for speeding in Holland,
Massachusetts, while Collins was driving in a vehicle registered to
Judith Bunn, a
sobriety test was given without probable cause, which came back
negative, Collins
was searched for weapons without probable cause. The Officer
repeatedly
questioned Collins about his relation to Judith and David Bunn and
whether he lived
at The Property and made comments about the notoriety of the property,
and
his parents.
(e) From the date that the criminal charges against the plaintiffs
were
dismissed, through the present, Judith Bunn and David Bunn, have made
repeated
requests to Chief Gleason for the return of the property that was
illegally
seized during the raid, which is valued at atleast $5,000.00, as well
as
$850.00 in cash. In response to the Bunnâ??s requests, Chief
Gleason has ignored the
requests, denied the requests, and has threatened the Bunns with
refiling
charges against the family. Gleason also told Judith Bunn not to
contact him
further and that he would not respond to her requests. This denial of
the
property by Gleason occurred even after the Bunns provided Gleason with
a Release
of the Property from the State Prosecutors.
CAUSES OF ACTION
FIRST COUNT : VIOLATION OF DAVID BUNN, JUDITH A. BUNN, DANIEL
COLLINSâ??,
CHRISTENA DODGE AND JAMIE DODGEâ??S FOURTH AMENDMENT RIGHTS
(UNLAWFUL SEARCH AND
SEIZURE), PURSUANT TO 42 U.S.C. § 1983, AS TO ALL DEFENDANTS.

Paragraphs1 through 42 are hereby incorporated into this the First
Count,
as if set forth in their entirety herein.
The affidavits submitted in support of Haleyâ??s application for a
search
warrant contained deliberate and material omissions of fact that render
the
warrant unconstitutional for lack of the necessary probable cause.
The statements contained in the warrant were false and were made
knowingly
and intentionally, and with reckless disregard for the truth, and the
false
statements were necessary to the finding of probable cause.
If the affidavit's false material were to be set to one side, the
affidavit's remaining content is insufficient to establish probable
cause.
The warrant contained inaccuracies or omissions if because (1) the
claimed
inaccuracies or omissions were the result of the affiant's deliberate
falsehood or reckless disregard for the truth; and (2) the alleged
falsehoods or
omissions were necessary to the judge's probable cause finding.
After putting aside the erroneous information and material omissions,
there
does not remain a residue of independent and lawful information
sufficient to
support probable cause.
The defendants, Haley and Gleason, violated the plaintiffsâ??,
Judith Bunn,
David Bunn, Christena Bunn, Jamie Bunn, Cougar John Bunn, Fourth
Amendment
rights as follows:
(a) The defendants, each and all of them, failed to secure to the
plaintiff,
unlawfully deprived the plaintiff, or caused the plaintiff to be
unlawfully
deprived of rights secured to them by the United States Constitution
and by
Title 42 United States Code § 1983, et . seq.;
(b) The defendants unreasonably applied for and secured a search
warrant for
without legal cause or factual grounds, in violation of the Fourth
Amendments of the United States Constitution;
(c) The defendants unlawfully searched and seized, the plaintiffs
against
their will, in violation of the Fourth Amendment of the United States
Constitution;
The defendants unlawfully intentionally ignored evidence and
misrepresented
evidence in order to secure a search arrest warrant for the property in
which
the plaintiffs were residing, without legal cause or factual grounds;
in
violation of the Fourth Amendment of the United States Constitution;

(e) The defendants conspired and drafted a search warrant affidavit
that
contained false and misleading information, omitted material facts,
failed to
provide exculpatory evidence and included misrepresentations of evidence
in
order to falsely secure a search warrant for the plaintiffs, without
legal cause
or factual grounds; in violation of the Fourth Amendment of the United
States Constitution.
51. As a result of the violation of the plaintiffsâ?? civil rights,
as
aforesaid, the plaintiffs were caused to suffer the following injuries,
but this
claim is not limited to the following injuries, some or all of which
are likely
to be permanent in nature:
(a) Loss of dignity, humiliation, and severe emotional pain and
suffering;
(b) loss of privacy within the sanctity of their home;
(c) anxiety, fear, and trauma, associated with being falsely
arrested
and/or searched;
(d) lost income;
(e) damage to their name and reputation; and
(f) loss and damage to property.


SECOND COUNT: VIOLATION OF JUDITH A. BUNN AND CHRISTENA DODGEâ??S
FOURTH
AMENDMENT RIGHTS (FALSE ARREST), PURSUANT TO 42 U.S.C. § 1983, AS TO
ALL
DEFENDANTS.

52. Paragraphs 1 through 51 are hereby incorporated into this the
Second
Count, as if set forth in their entirety herein.
The affidavits submitted in support of Haleyâ??s application for a
search
warrant which produced evidence that lead to the arrest of Dodge and
Bunn,
contained deliberate and material omissions of fact that render the
warrant
unconstitutional for lack of the necessary probable cause.
The statements contained in the warrant, were false and were made
knowingly
and intentionally, and with reckless disregard for the truth, and the
false
statements were necessary to the finding of probable cause.
If the affidavit's false material were to be set to one side, the
affidavit's remaining content is insufficient to establish probable
cause to search the
property and seize the property, which lead to the arrest of Dodge and
Bunn.
The warrant contained inaccuracies or omissions if because (1) the
claimed
inaccuracies or omissions were the result of the affiant's deliberate
falsehood or reckless disregard for the truth; and (2) the alleged
falsehoods or
omissions were necessary to the judge's probable cause finding.
After putting aside the erroneous information and material omissions,
there
does not remain a residue of independent and lawful information
sufficient to
support probable cause for the search which produced evidence that lead
to
the arrest of Dodge and Bunn.
The defendants, Haley and Gleason, violated Bunn and Dodgeâ??s,
Fourth
Amendment rights as follows:
(a) The defendants, each and all of them, failed to secure to the
plaintiff,
unlawfully deprived the plaintiff, or caused the plaintiff to be
unlawfully
deprived of rights secured to them by the United States Constitution
and by
Title 42 United States Code § 1983, et . seq.;
(b) The defendants unreasonably applied for and secured a search
warrant for
without legal cause or factual grounds, which produced evidence that
lead
to the arrest of Dodge and Bunn, in violation of the Fourth Amendments
of the
United States Constitution;
(c) The defendants unlawfully searched and seized, the plaintiffs
against
their will, in violation of the Fourth Amendment of the United States
Constitution, which lead to the false arrest of the plaintiffs;
(d) The defendants unlawfully intentionally ignored evidence and
misrepresented evidence in order to secure a search arrest warrant for
the property in
which the plaintiffs were residing, without legal cause or factual
grounds; in
violation of the Fourth Amendment of the United States Constitution;
(e) The defendants conspired and drafted a search warrant affidavit
that
contained false and misleading information, omitted material facts,
failed to
provide exculpatory evidence and included misrepresentations of evidence
in
order to falsely secure a search warrant for the plaintiffs, without
legal cause
or factual grounds, which produced evidence that lead to the arrest of
Dodge
and Bunn, in violation of the Fourth Amendments of the United States
Constitution;
The plaintiffs Bunn and Dodge were falsely arrested as their arrest
was
based upon an illegal search and seizure and there was not probable
cause to
arrest Bunn and Dodge.
59. As a result of the violation of the plaintiffsâ?? civil rights,
as
aforesaid, the plaintiffs were caused to suffer the following injuries,
but this
claim is not limited to the following injuries, some or all of which
are likely
to be permanent in nature:
(a) Loss of dignity, humiliation, and severe emotional pain and
suffering;
loss of privacy within the sanctity of their home;


(c) anxiety, fear, and trauma, associated with being falsely
arrested
and/or searched;
(d) lost income;
(e) damage to their name and reputation; and
(f) loss and damage to property.
THIRD COUNT: VIOLATION OF DANIEL COLLINS, CHRISTENA DODGE AND JAMIE
DODGEâ??S
FOURTH AMENDMENT RIGHTS (EXCESSIVE FORCE BEYOND THE SCOPE OF THE SEARCH
WARRANT), PURSUANT TO 42 U.S.C. § 1983, AS TO ALL DEFENDANTS.

60. Paragraphs 1 through 59 are hereby incorporated into this the Third
Count, as if set forth in their entirety herein.
Collins and the Dodge family were forcefully and violently handcuffed
for
over and hour and a half and were not allowed to attend to the minor
children
in the house during the illegal search and seizure of their property
and the
defendants used excessive force beyond the scope of the search warrant,
in
violation of the plaintiffsâ?? Fourth Amendment Rights.
As a result of the violation of the plaintiffsâ?? civil rights, as
aforesaid,
the plaintiffs were caused to suffer the following injuries, but this
claim
is not limited to the following injuries, some or all of which are
likely to
be permanent in nature:
(a) Loss of dignity, humiliation, and severe emotional pain and
suffering;
(b) loss of privacy within the sanctity of their home;
(c) anxiety, fear, and trauma, associated with being falsely
arrested
and/or searched;
(d) lost income;
(e) damage to their name and reputation; and
(f) loss and damage to property.

FOURTH COUNT: VIOLATION OF DAVID BUNN, JUDITH BUNN, CHRISTENA DODGE
AND
JAMIE DODGE AS TO DEFENDANTS, GLEASON AND HALEY.

Paragraphs 1 through 62 are hereby incorporated into this the Fourth
Count,
as if set forth in their entirety herein.
The defendants, each and all of them, failed to secure to the
plaintiffs,
unlawfully deprived the plaintiffs, or caused the plaintiffâ??s to
be unlawfully
deprived of rights secured to them by the First Amendment of United
States
Constitution and by Title 42 United States Code § 1983, et . seq., as
follows
(a) The defendants retaliated against the Bunnâ??s for their public
speech by:
(1) falsely searching and seizing their property ; (2) falsely
arresting
Judith Bunn and the Bunnâ??s daughter Christena; (3) threatening
and harassing
the Bunnsâ?? children and grandchildren: Daniel Collins, Christena
Dodge, Jamie
Dodge, Cougar John Bunn, Phoenix Dodge and Justice Dodge; and (4)
refusing to
return the seized property that was taken as a result of the illegal
search
and seizure;
(b) the plaintiffs participated in speech that is protected by the
First
Amendment regarding the legalization of marijuana, in that the
plaintiffs were
involved in protests and were featured in newspaper articles and
magazine
articles where the plaintiffs provided interviews speaking out on the
need for
the legalization of marijuana, and were active members of and on the
Board of
Directors of a pro-marijuana activist group;
(c) the defendants' conduct was motivated by or substantially caused
by the
plaintiffsâ?? exercise of free speech, in that, the defendants were
aware of
the plaintiffsâ?? public speech and activism and attached copies of
newspaper
articles in which the plaintiffs were featured to the application for
the
search warrant.
Each of the above named Individual Defendants participated in this
misconduct, were aware of their corrupt and illegal activity and their
blatant
disregard of the plaintiffsâ?? constitutional and civil rights.
As a result of the violation of the plaintiffsâ?? civil rights, as
aforesaid,
the plaintiffs were caused to suffer the following injuries, but this
claim
is not limited to the following injuries, some or all of which are
likely to
be permanent in nature:
(a) Loss of dignity, humiliation, and severe emotional pain and
suffering;
(b) loss of privacy within the sanctity of their home;
(c) anxiety, fear, and trauma, associated with being falsely
arrested
and/or searched;
(d) lost income;
(e) damage to their name and reputation; and
(f) loss and damage to property.
FIFTH COUNT: VIOLATION OF ALL OF THE PLAINTIFFSâ?? FOURTEENTH
AMENDMENT
SUBSTANTIVE DUE PROCESS RIGHTS AS TO ALL OF THE DEFENDANTS.

Paragraphs 1 through 66 are hereby incorporated into this the Fifth
Count,
as if set forth in their entirety herein.
During all times relevant to this complaint, the defendants violated
plaintiffsâ?? constitutional rights by depriving them of liberty
without due process
of law by carrying out a pattern of outrageous conduct including, but
not
limited to: (a) yelling, swearing and threatening the plaintiffs during
the raid;
(b) putting a gun the minor childrenâ??s dogâ??s head in front
of the children
and threatening to shoot the dog; (c) breaking down every door in the
plaintiffsâ?? house, pointing guns at the plaintiffsâ?? heads,
terrifying the minor
children; destroying property; (d) insulting, laughing and swearing at
the
plaintiffs, including criticizing Christena Dodgeâ??s disability;
(e) denying the
plaintiffs the ability to use the bathroom after over an hour of
sitting
handcuffed in pajamas in their own kitchen; (f) forcing the females in
the house to
stand naked (as they were sleeping when the agents and officers
arrived) in
front of numerous male agents and officers with guns pointed at them
before
allowing them to dress.
During all times relevant to this complaint, the plaintiff was
subjected to
continual and progressive harassment and intimidation by the
defendants, all
in violation of the plaintiff's constitutional rights.
The defendants, each and all of them, failed to secure to the
plaintiff,
unlawfully deprived the plaintiff, or caused the plaintiff to be
unlawfully
deprived of rights secured to him by the United States Constitution
pursuant
Title 42 U.S.C. § 1983, et seq. by their promotion and acquiescence of
the
aforementioned activities.
The actions of the defendants were and are extreme and outrageous,
shocking
to the sensibilities of any reasonable person and will continue
unabated
unless strictly prohibited by the court.
Defendant's actions are in violation of the aforementioned
constitutional
and statutory provisions and entitle the Plaintiff to immediate
injunctive
relief pursuant to the aforementioned jurisdictional statutes and
constitutional
protection.

As a result of the violation of the plaintiffsâ?? civil rights, as
aforesaid,
the plaintiffs were caused to suffer the following injuries, but this
claim is
not limited to the following injuries, some or all of which are likely
to be
permanent in nature:
(a) Loss of dignity, humiliation, and severe emotional pain and
suffering;
(b) loss of privacy within the sanctity of their home;
(c) anxiety, fear, and trauma, associated with being falsely
arrested
and/or searched;
(d) lost income;
(e) damage to their name and reputation; and
(f) loss and damage to property.
SIXTH COUNT: INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS BY ALL
PLAINTIFFS
AGAINST ALL DEFENDANTS.

Paragraphs 1 through 73 are hereby incorporated into this the Sixth
Count,
as if set forth in their entirety herein.
The defendants, intended to inflict severe emotional distress upon the
plaintiffs, and knew or should have known at all times that their acts
or
omissions as alleged herein would result in severe emotional distress
to the
plaintiffs.


The acts and omissions of the defendants were extreme, outrageous and
dangerous.
As a direct and proximate result of said acts or omissions, the
plaintiff
suffered emotional distress.
The plaintiff claims damages.
WHEREFORE, the plaintiffs claims judgment against the defendants as
follows:
(1) Compensatory money damages;
(2) Punitive damages as provided by 42 U.S.C. §§ 1983, and other
applicable law;
(3) Attorney's fees and costs as provided by 42 U.S.C. §§ 1988, and
other
applicable law;
(4) Lost and future lost wages; and
(5) Such other relief in law or equity as the Court may deem
appropriate.
(6) A Jury trial is requested.

PLAINTIFFS,
By: ______________________
Erin I. Oâ??Neil-Baker
The Law Office of Erin I. Oâ??Neil-Baker
41A New London Turnpike
Glastonbury, CT 06033
Fed. ct#: 23073
Tel: 860-466-4278
Fax: 860-466-4279
[email protected]_ (mailto:[email protected])

sorry my bday is may 6, im turning 15, but i'm very farmiliar with Hartford, too bad..

yo im down if i can get my ass to hartford, and all bring all my boys!:thumbsup: