Federal Lawsuit Filed by Charles Towns' Family
Federal Lawsuit Filed by Charles Towns' Family
23 Defendants.
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KNOX (FIRST AMENDED) COMPLAINT FOR DAMAGES
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1 Plaintiffs allege:
2 INTRODUCTION.
3 1. This civil rights action seeks compensatory and punitive damages
4 from Defendants for violating various civil rights under the United States
5 Constitution and state law in connection with the fatal use force on the
6 PLAINTIFFS.
7 PARTIES
8 2. BARSHA KNOX, at all relevant times is a Black female and
9 resident of Pasadena, California, and is the natural mother of Plaintiff CARLOS
10 TOWNS and Minor, “CT2”.
11 3. CARLOS TOWNS, at all relevant times is a Black male and resident
12 of Pasadena, California.
13 4. “CT2” A Black male Minor who sues through his Guardian ad Litem
14 and maternal aunt, FIONA BELL.
15 5. Defendant, RALPH PALACIOS, a White male1, at all relevant times
16 was and is a sworn police officer at the PASADENA POLICE DEPARTMENT
17 who was acting under color of law within the course and scope of his duties as a
18 peace officer at the Pasadena Police Department (“PPD”) when he used excessive
19 force on PLAINTIFF TOWNS and would have battered PLAINTIFF KNOX,
20 but-for the swift intervention of Pasadena PD rookie officer TAISYN
21 CRUTCHFIELD, a Black woman.
22 6. Defendant, SGT. BLANCHARD, at all relevant times was and is a
23 White male and supervisor at the Pasadena Police Department who was acting
24 under color of law within the course and scope of his duties as a peace officer and
25 supervisor for the Pasadena Police Department (“PPD”) with the complete
26 authority and ratification of his principal, Defendant CITY, when he stood by and
27 failed to intervene in the unnecessary use of force on Plaintiff TOWNS and assault
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1
Possibly Latino.
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KNOX (FIRST AMENDED) COMPLAINT FOR DAMAGES
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1 consent of CITY.
2 13. At all times mentioned herein, each and every CITY defendant was
3 the agent of each and every other CITY defendant and had the legal duty to
4 oversee and supervise the hiring, conduct and employment of each and every CITY
5 defendant.
6 14. The true names of defendants DOES 1 - 10, inclusive, are unknown to
7 Plaintiffs, who therefore sue these defendants by such fictitious names.
8 Plaintiffs will seek leave to amend this complaint to show the true names and
9 capacities of these defendants when they have been ascertained. Each of the
10 fictitious named defendants is responsible in some manner for the conduct and
11 liabilities alleged herein.
12 15. In May 2023, Plaintiffs filed comprehensive and timely claim for
13 damages with CITY pursuant to applicable sections of the California Government
14 Code.
15 JURISDICTION AND VENUE
16 16. This civil action is brought for the redress of alleged deprivations of
17 constitutional rights as protected by 42 U.S.C. §§ 1983, 1985, 1986, 1988, and the
18 Fourth and Fourteenth Amendments of the United States Constitution. Jurisdiction
19 is founded on 28 U.S.C. §§ 1331, 1343, and 1367.
20 17. Venue is proper in this Court under 28 U.S.C. § 1391(b), because
21 Defendants reside in, and all incidents, events, and occurrences giving rise to this
22 action occurred in, the County of Los Angeles, California.
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KNOX (FIRST AMENDED) COMPLAINT FOR DAMAGES
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KNOX (FIRST AMENDED) COMPLAINT FOR DAMAGES
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1 STATEMENT OF FACTS
2 20. A few weeks later, on or about February 20, 2023, at approx. 2AM
3 while PLAINTIFFS, were standing outside their home near the Pasadena Police
4 station at the corner of Walnut and Marengo Ave. in the City of Pasadena.
5 Unfortunately for the Plaintiffs, they were in their feelings over the loss of Mr.
6 Towns and caught the eye of an officer believed to be Jared BLEDSOE. Officer
7 Bledsoe made contact with the three Plaintiffs and was conversing with them when
8 Defendant PALACIOS suddenly ran over from the police department and
9 aggressively took hold of Plaintiff TOWNS. PALACIOS violently face-planted
10 unarmed Plaintiff TOWNS in the flower planter and handcuffed him causing pain
11 and bruising. Ms. KNOX observed her son being hurt so she protested and tried to
12 intervene. PALACIOS yelled at her and she was handcuffed by an unknown
13 White female. KNOX feared for the life of her children and she recognized
14 PALACIOS from the El Sereno Ave. shooting where he was rude and aggressive
15 there as well. She told PALACIOS words to the effect that "you should not be on
16 the street because you are too aggressive", to which he responded that she should
17 respect "his officers". Although PALACIOS has only been at the Pasadena Police
18 Department a couple of years, and although Defendant Sgt. BLANCHARD was
19 on scene, PALACIOS assumed control. PALACIOS continued to yell at the
20 handcuffed Barsha KNOX and suddenly approached her coming within 1-2 feet
21 and causing her to have an apprehension of an imminent, unlawful and harmful
22 touching. But to Plaintiff KNOX' relief, Black female rookie officer TAISYN
23 CRUTCHFIELD swiftly intervened, and moved between PALACIOS and
24 KNOX, thereby protecting KNOX from the assaulting PALACIOS. Defendant
25 PALACIOS was guided away from KNOX by CRUTCHFIELD and that
26 situation was de-escalated. But PALACIOS responded by violently pushing the
27 CRUTCHFIELD and yelling "Don't fucking touch me!" or words to that effect.
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KNOX (FIRST AMENDED) COMPLAINT FOR DAMAGES
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1 21. Both officers were ordered away from the scene by Defendant Sgt.
2 BLANCHARD who watched PALACIOS face-plant TOWNS but failed to
3 intervene, as required by law.
4 22. DEFENDANTS did not transport the PLAINTIFFS to jail, nor were
5 they cited for any violation. PLAINTIFFS believe that neither a Use of Force
6 report nor any other report was written. PLAINTIFFS were not given any forms
7 after being battered, handcuffed and placed in patrol units.
8 23. Defendant Officer PALACIOS, BLANCHARD and Lt. KIRBY
9 then conspired to terminate probationary officer /college track star (100-meter
10 national title holder) / educated Black female and holder of a Masters' degree in
11 Criminology from a UC school because she fulfilled her Constitutional obligation
12 to protect PLAINTIFFS as required by law. Defendants (excluding Chief
13 HARRIS) waited until the only other Black female at the department, Lt.
14 GORDON, was no longer over the Internal Affairs Department to put rookie
15 TAISYN CRUTCHFIELD on administrative leave for intervening.
16 CRUTCHFIELD is believed to have been put on leave sometime in
17 April, just before she would have completed probation in May, causing her
18 probation to be extended and overtly signaling to everyone in the Department that:
19 -she will soon be terminated, and
20 -this is what happens to anyone who does not back "Blue"3 whether the
21 actions of the officer is wrong or right.
22 Defendants PALACIOS, BLANCHARD, and KIRBY then engaged in
23 specific actions amounting to witness-tampering by causing witness
24 CRUTCHFIELD to be subjected to an internal affairs investigation and placed on
25 administrative leave rendering her unable to speak about the excessive force.
26 Witness CRUTCHFIELD, daughter of Pasadena Sports Hall of Famer, Tony
27 Crutchfield, Sr., has approx. 100,000 Instagram followers. If Defendants treat this
28 high-profile Black female in this manner, one need only image how they treat the
3
“Thin Blue line” aka Code of Silence in law enforcement.
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KNOX (FIRST AMENDED) COMPLAINT FOR DAMAGES
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1 average Black citizen in Northwest Pasadena. As a patrol officer, this is how Lt.
2 KIRBY (now IA Supervisor) treated Black folks:
3 -In 2009, the CITY settled a lawsuit against KIRBY, Keith GOMEZ
4 and others in which KIRBY was sued for violently throwing an unarmed
5 elderly Black female to the ground and beating up her three teenaged
6 children on El Sereno Ave. The mother and teens were then repeatedly
7 subjected to pretext stops used as a method to harass them afterwards.
8 (Miller v. City of Pasadena, Case #05-cv-7467 R-PJW). The mother said:
9 I tried to complain about the treatment of [my son], but
10 instead of answering any questions Officer KIRBY shoved
me to the ground. Sgt. GOODMAN also pushed me, as racial slurs,
11 such as “Nigger” was used, I feel that [my son] and I were
12 mistreated, threatened and abused because of race. [Dkt 86]
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14 -In 2009, the CITY settled a lawsuit in which KIRBY and others were sued
15 after KIRBY deceived a Superior Court judge with trumped-up Field
16 Interrogation (FI) cards to get a search warrant and serving said search
17 warrant at the wrong address. When unarmed Black male resident
18 questioned the police presence, KIRBY and Keith GOMEZ beat him up in
19 front of his children as the kids cried and said, “stop hitting my Daddy”.
20 The resident, Damien Esteem, was not arrested or cited at the scene after
21 being face-planted into the cement. It was not until he made a personnel
22 complaint on KIRBY, GOMEZ and others that the CITY filed charges
23 against him for 148 PC. Said charge was later dismissed. (Esteem v. City
24 of Pasadena, Case# 04-662 GHK (MANx).
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KNOX (FIRST AMENDED) COMPLAINT FOR DAMAGES
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1 The harsh reality that should cause Defendant CHIEF EUGENE HARRIS
2 to stop burying his head in the sand and clear out the management level of
3 suspected White Supremacists, is the fact that the Department allows non-Black
4 officers to kill, beat-up and harass Black folks through “pretext stops” and trumped
5 up “field-interrogation” cards, but punishes or fires Black officers for very
6 minor infractions or in this case, a heroic effort that preserved life and/ or limb.
7 Recent incidents more meritorious of examination of Pasadena IA have gone
8 unaddressed:
9 24. In July, 2020, Pasadena Police Sergeant Michael GLIGORIJEVIC,
10 a 20-year veteran of the department, fled from a CHP officer on foot in the Santa
11 Clarita area while he was off duty. The sergeant was quietly offered diversion by
12 embattled former District Attorney Jackie Lacey rather than face prosecution on
13 allegations of resisting arrest, driving under the influence, child endangerment and
14 leaving his weapon unattended in a vehicle. The California Highway Patrol
15 provided Sgt. GLIGORIJEVIC with a date to appear in court recommending all
16 of the alleged offenses be charged, but he was ultimately only charged with one
17 misdemeanor count of resisting arrest. He never actually entered a plea to the
18 charge and it was dismissed after he completed six months of diversion. 4
19 25. Former CHIEF PEREZ and the Defendant CITY did not discipline
20 Sgt. Michael GLIGORIJEVIC, who was captured on video committing the afore-
21 mentioned crimes, or Lt. Shawn DAWKINS who was also at the scene with CHP.
22 Former Chief JOHN PEREZ had the benefit of having a video which depicted
23 GLIGORIJEVIC and DAWKINS committing actual crimes and he failed to put
24 either of them on administrative leave for one single day, but witness
25 CRUTCHFIELD, who is tantamount to a whistle-blowers, has seemingly been on
26 leave for months now.
27 (https://www.facebook.com/TheConversation.Live/videos/724956018914441)
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By Brennon Dixson Pasadena Star-News Published March 25, 2022 at 10:41 a.m. updated June
1, 2022 at 1:34 p.m.
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KNOX (FIRST AMENDED) COMPLAINT FOR DAMAGES
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"Police Officer wakes up paralyzed, marries from hospital bed" Source: Today Show August 4,
2016 9:48 AM PDT.
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KNOX (FIRST AMENDED) COMPLAINT FOR DAMAGES
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KNOX (FIRST AMENDED) COMPLAINT FOR DAMAGES
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KNOX (FIRST AMENDED) COMPLAINT FOR DAMAGES
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1 not be punished in any way for inflicting serious bodily injury or killing people of
2 color. Top brass at the Pasadena Police Department have a long history of refusing
3 to discipline officers for excessive for on people of color, especially when they are
4 Non-Black officers7.
5 41. As customary with the Pasadena Police Department, Defendant CITY,
6 Chief and Chiefs before him have never been disciplined for the use of excessive
7 force on people of color.
8 42. For some time prior to February 2023 (and continuing to the present
9 date) the Defendant CITY, deprived PLAINTIFFS of the rights and liberties
10 secured to them by the Fourth and Fourteenth Amendments to the United States
11 Constitution, in that, said defendants and their supervising and managerial
12 employees, agents, and representatives, acting with gross negligence and with
13 reckless and deliberate indifference to the rights and liberties of the public in
14 general, and PLAINTIFFS, and of persons in their class, situation and comparable
15 position in particular, knowingly maintained, enforced and applied an official
16 recognized custom, policy, and practice of:
17 (a) Employing and retaining as police officers and other personnel, including
18 the Officer Defendants, DOES 1- 5, at all times material herein knew or reasonably
19 should have known had dangerous propensities for abusing their authority and for
20 mistreating citizens by failing to follow written CITY police department’s policies,
21 including the use of excessive force;
22 (b) Of inadequately supervising, training, controlling, assigning, and
23 disciplining CITY officers, and other personnel, including the Officer Defendants,
24 who Defendant CITY knew or in the exercise of reasonable care should have
25 known had the aforementioned propensities and character traits, including the
26 propensity for violence and the use of excessive force;
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Specifically in the case of the killing of Leroy Barnes, Kendrec McDade and Anthony
28 McClain. In all three of those instances the CITY engaged the services of Michael Gennaco to
evaluate the actions of the officers involved yet failing on each account to implement his
recommendations.
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KNOX (FIRST AMENDED) COMPLAINT FOR DAMAGES
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KNOX (FIRST AMENDED) COMPLAINT FOR DAMAGES
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KNOX (FIRST AMENDED) COMPLAINT FOR DAMAGES
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1 but later charged him criminally when he made a personnel complaint for
2 excessive force. The criminal charges were dismissed and Mr. Esteem accepted a
3 monetary
4 settlement to dismiss his excessive force lawsuit for the scratches to his face. In the
5 Esteem matter CHRISTOPHER KIRBY presented false and unreliable
6 information, namely, unreliable field interview cards to a Superior Court
7 Magistrate Judge and caused a search warrant to issue at 3057 N. Glen Ave.
8 Altadena, CA 91001, without legal cause and sufficient information on
9 the intended target: “Daniel Brown”. Further, Officer KIRBY knew or should have
10 known that Daniel Brown did not live at the above location on the date of entry.
11 On or about October 9, 2003, the defendant officers, there, forcibly and illegally
12 entered the plaintiffs’ residence without providing “knock and notice”. Officers
13 smashed a window and entered the bedroom of 15 year-old female, clad only in
14 pajamas, and chased the child with their guns drawn as she ran, screaming for her
15 mother. KIRBY, KEITH GOMEZ and others pointed handguns at women and
16 children who posed no threat and who were clearly not the male adult target they
17 had the search warrant for. The child was handcuffed for approx. 30 minutes.
18 46. In March 2012, unarmed Black teenager KENDREC McDADE was
19 fatally shot by Defendant Officers Jeffrey NEWLEN and Matthew GRIFFIN,
20 which left him bleeding out asking “why did they shoot me?” before dying. Griffin
21 and Newlen failed to perform CPR or first aid and even hit him with a patrol car
22 after shooting him. The District Attorney’s Office immediately rubberstamped the
23 statements of the officers with little or no investigations and ignored independent
24 counsel Michael Gennaco’s early indications that the Pasadena PD had failed to
25 implement the recommendations offered in the Barnes Report after the fatal 2009
26 officer involved shooting (“OIS”) of Leroy Barnes.
27 47. In September 2016, Officers Aaron VILLACANA and others tased
28 and choked unarmed and mentally unavailable Reginald THOMAS to death after
he called police for help. When asked under deposition testimony about the cold-
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KNOX (FIRST AMENDED) COMPLAINT FOR DAMAGES
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1 blooded murder, all Defendant Officers, including VILLACANA pled the 5th and
2 refused to answer questions for fear that they would be criminally implicated.
3
4 Aaron VILLACANA was a paramedic but refused to administer potentially life-
5 saving medical assistance to Mr. Thomas. The CITY did not discipline
6 VILLACANA but they allowed him to continue being a field training officer
7 (“FTO”) and simply paid out on the wrongful death lawsuit (Lindsey et. al v. City
8 of Pasadena et. al. Case # 16-8602). The Defendant CITY also allowed Officers
9 Jeffrey NEWLEN and Matthew GRIFFIN to train officer Edwin
10 DUMAGUINDIN and Ryan MULROONEY after they killed unarmed teenager
11 Kendrec McDADE by shooting him eight times and then running him over with a
12 patrol car afterwards. Before dying at the hospital, Kendrec asked a paramedic,
13 “Why did they shoot me?
14 In August 2020, Officers Edwin DUMAGUINDIN and his partner, Ryan
15 MULROONEY initiated a pretext car stop on a car Anthony McClain was a
16 passenger in. While MULROONEY spoke with the driver on the sidewalk,
17 DUMAGUINDIN, (in a move that would later be criticized by police consultant
18 Michael Gennaco) ordered Anthony McClain out of the vehicle. Mr. McClain ran
19 and was shot twice in the back by DUMAGUINDIN. The CITY settled part of
20 that wrongful death lawsuit for over $8 million dollars in payments to Mr.
21 McClain’s children and most recently, his father. The final portion of the lawsuit
22 involving McClain’s putative mother/ grandmother is still pending in federal
23 district court (Irene Bailey et. al. v. City of Pasadena et. al. Case. No. 22-cv-
24 05752-FMO-MAR).
25 48. Defendants, together with various other officials, whether named or
26 unnamed, had either actual or constructive knowledge of the deficient policies,
27 practices and customs alleged in the paragraphs above. Despite having knowledge
28 as stated above these defendants condoned, tolerated and through actions and
inactions thereby ratified such policies. Said defendants also acted with deliberate
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KNOX (FIRST AMENDED) COMPLAINT FOR DAMAGES
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8 FOURTH CLAIM FOR RELIEF
Battery
9 (Cal. Govt. Code § 820 and California Common Law)
10 (Against the Defendant PALACIOS & Does 1-10)
11
59. Plaintiffs repeat and re-allege each and every allegation in paragraphs
12
above in this Complaint with the same force and effect as if fully set forth herein.
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60. Defendant Officer PALACIOS, while working as police officer was
14
acting within the course and scope of his employment with the CITY, intentionally
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face-planted Plaintiff CARLOS TOWNS by shoving him face forward into a
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planter without cause, thereby using unreasonable and excessive force against him.
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PALACIOS also assaulted and falsely imprisoned BARSHA KNOX and minor
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“CT2”.
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61. As a result of the actions of Defendant Officers actions, the plaintiffs
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suffered pain and humiliation. There was no legal justification for using force
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against PLAINTIFFS, and their use of force while carrying out their duties as
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officers for the CITY was an unreasonable and non-privileged use of force.
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62. The CITY is vicariously liable for the wrongful acts of Defendants
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and DOE OFFICERS pursuant to section 815.2(a) of the California Government
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Code, which provides that a public entity is liable for the injuries caused by its
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employees within the scope of the employment if the employee’s act would subject
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him or her to liability.
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KNOX (FIRST AMENDED) COMPLAINT FOR DAMAGES
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FIFTH CLAIM FOR RELIEF
9 Negligence
10 (Cal. Govt. Code § 820 and California Common Law)
11 63. Plaintiffs repeat and re-allege each and every allegation in paragraphs
12 above in this Complaint with the same force and effect as if fully set forth herein.
13 64. The actions and inactions of the Defendants, were negligent and
14 reckless, including but not limited to:
15 (a) the failure to properly and adequately assess the need to detain, arrest,
16 and use force on Plaintiffs;
17 (b) the negligent tactics and handling of the situation,
18 (c) the negligent detention, arrest, and use of force,
19 (d) negligent infliction of emotional distress; and
20 (e) the negligent handling of evidence and witnesses.
21 65. Specifically, CHIEF and unknown supervisors at the Pasadena Police
22 Department had a duty to instruct and institute policies and procedures and as a
23 direct result of their failure and as a proximate result of defendants’ conduct as
24 alleged above, and other undiscovered negligent conduct, PLAINTIFFS were
25 caused pain and suffering. Also, as a direct and proximate result of defendants’
26 conduct as alleged above, Plaintiffs suffered extreme and severe mental anguish
27 and pain and have been injured in mind and body.
28 66. CITY is vicariously liable for the wrongful acts of the Officer
Defendants pursuant to section 815.2 of the California Government Code, which
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KNOX (FIRST AMENDED) COMPLAINT FOR DAMAGES
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1 provides that a public entity is liable for the injuries caused by its employees
2 within the scope of the employment if the employee’s act would subject him or her
3 to liability.
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9 SIXTH CAUSE OF ACTION
10 (Violation of the BANE Act Cal. Civil Code § 52.1)
11 (By All Plaintiffs against PALACIOS and Does 1-10)
12 67. Plaintiffs repeat and re-allege each and every allegation in paragraphs
13 above this Complaint with the same force and effect as if fully set forth herein.
14 68. California Civil Code, Section 52.1 (the Bane Act), prohibits any
15 person from using violent acts or threatening to commit violent acts in retaliation
16 against another person for exercising that person’s constitutional rights.
17 69. On information and belief, Defendant Officers and DOE OFFICERS,
18 inclusive, while working for the CITY and acting within the course and scope of
19 their duties, intentionally committed and attempted to commit acts of violence
20 against by integrally participating in the above violence.
21 70. The conduct of Defendants was a substantial factor in causing
22 Plaintiffs’ harms, losses, injuries, and damages.
23 71. CITY is vicariously liable for the wrongful acts of Defendants and
24 DOE OFFICERS, inclusive, pursuant to section 815.2(a) of the California
25 Government Code, which provides that a public entity is liable for the injuries
26 caused by its employees within the scope of the employment if the employee’s act
27 would subject him or her to liability.
28 72. The conduct of Defendants was malicious, wanton, oppressive, and
accomplished with a conscious disregard for PLAINTIFFS’s and Plaintiffs’ rights,
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KNOX (FIRST AMENDED) COMPLAINT FOR DAMAGES
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KNOX (FIRST AMENDED) COMPLAINT FOR DAMAGES
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1 79. For such further other relief as the Court may deem just, proper, and
2 appropriate.
3
4 DATED: 6/9/23 LAW OFFICES OF CAREE HARPER
5 /S/ Caree Harper
6 Attorneys for PLAINTIFFS
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DEMAND FOR JURY TRIAL
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12 All Plaintiffs demand a jury trial.
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LAW OFFICES OF CAREE HARPER
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15 /S/ Caree Harper
16 Attorneys for PLAINTIFFS
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KNOX (FIRST AMENDED) COMPLAINT FOR DAMAGES