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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA MIAMI DIVISION Case No: 12-21024-CIV-MARTINEZ-MCALILEY DARIO D. VASQUEZ, Plaintiff, v. CITY OF MIAMI BEACH, et al., Defendants. __________________________________/ AMENDED COMPLAINT Plaintiff, Dario Vasquez (Vasquez), by and through undersigned counsel, and files this Amended Complaint and sues Defendants City of Miami Beach and Phillip Elmore, and alleges as follows: JURISDICTIONAL STATEMENT AND PARTIES 1. This is an action for damages arising out of one or more violations of federal and

state law, and is brought pursuant to 42 U.S.C. 1983 and 1988 and the Fourth Amendment to the United States Constitution. 2. This Court has jurisdiction over this action pursuant to the provisions of 28 U.S.C.

1331 and 1343 in that this is an action to redress violations of Plaintiffs federally protected Constitutional rights. Jurisdiction over the state law claims is founded upon the supplemental jurisdiction of this Court, 28 U.S.C. 1367. 3. At all times material hereto, Plaintiff, Vasquez, is and was a permanent legal

resident of the United States, and a resident of Broward County, Florida, and is otherwise sui juris.

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4.

Defendant, Phillip Elmore (Elmore) was at all times relevant acting under color

of state law as an active and duly appointed Miami Beach police officer, and in such capacity, as the agent, servant, and employee of Defendant, City of Miami Beach. 5. Defendant, City of Miami Beach (City), is a political subdivision of the State of

Florida, a Florida municipal corporation, and at all times material hereto, acted through its agents, employees, and servants, including Defendant Elmore. 6. The acts and practices constituting the violations alleged below have all occurred

within the City of Miami Beach, which is properly within the jurisdiction of the United States District Court in and for the Southern District of Florida. Venue in the Southern District of Florida, Miami Division, is proper because the incident which is the subject of this lawsuit occurred in Miami-Dade County, Florida and Defendant City is located in this venue. See 28 U.S.C. 1391(b)(1) and 1391(b)(2). 7. Plaintiff has complied with all conditions precedent to the filing of this lawsuit

pursuant to Section 768.28, Florida Statutes; all applicable notices have been provided to Defendants. 8. Plaintiff has retained Law Offices of Douglas J. Jeffrey, P.A. and Fuentes &

Berrio, LLP to represent his interests in prosecuting this action, and said law firms are entitled to their reasonable attorneys fees and costs incurred in connection therewith. STATEMENT OF FACTS 9. At all times material hereto, the subject incident arises out of Defendant Elmores

brutal battery and assault of Plaintiff Vasquez resulting in serious personal injuries to said Plaintiff which occurred in or about the 7300 block of Collins Avenue, Miami Beach, Florida. 10. Specifically, on or about February 4, 2008, at approximately 7:42 p.m., the

Plaintiff was situated at the 7300 block of Collins Avenue in Miami Beach, Florida. 2

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11.

Plaintiff, a 68-year old Hispanic male, was awaiting the arrival of his

transportation which had been pre-arranged, and said individuals had just arrived to pick up the Plaintiff to take him home for the evening when Defendant Elmore arrived at the scene. 12. At said time and place, Defendant Elmore, an officer of the Defendant City,

approached the Plaintiff alleging that the Plaintiff had engaged in the public consumption of alcohol. The individuals who had arrived to take the Plaintiff home informed Defendant Elmore that they were prepared to take him home at that time; Defendant Elmore refused, and instead proceeded to arrest the Plaintiff for the alleged violation of City Municipal Code Section 70.87. Plaintiff was informed that he was under arrest for public consumption of alcohol, i.e., a nonviolent offense. 13. The Plaintiff did not resist arrest, and peacefully agreed to submit to the arrest, at

which time Defendant Elmore placed the Plaintiff in handcuffs. Plaintiff entered the police vehicle, without resistance or any confrontation or commotion, and said Plaintiff was already in restraints upon entering the vehicle. Defendant Elmore proceeded to drive away from the point of arrest in the police vehicle, stating that he would be taking the Plaintiff to the police station. 14. At the time the Plaintiff had entered said police vehicle, Plaintiff was not in an

injured state, and did not have any markings about his face or signs of having been in any confrontation or physical altercation of any kind. The individuals who had come to pick-up the Plaintiff witnessed the arrest as well as the overall physical appearance of the Plaintiff, and further, witnessed that the Plaintiff was in restraints and made no effort to resist arrest. Said individuals also witnessed that the Plaintiff did not exhibit any physical manifestations of having been injured at the time he entered the police vehicle. 15. Be that as it may, the Defendant Elmore did not take Plaintiff directly to the

police station for Defendant City. Instead, without provocation or legal justification, Defendant 3

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Elmore took the Plaintiff to a secluded alleyway within Miami Beach (at an unknown address) next to a dumpster, outside the presence of any known witnesses. Elmore then took the Plaintiff outside the police vehicle, and while the Plaintiff was still wearing the restraints, Elmore proceeded to savagely beat the Plaintiff with his bare fists about the Plaintiffs face, shoulder, and body, and kicking said Plaintiff, for a time period of an unknown duration believed to be in excess of ten minutes (Plaintiff is unsure as to the exact amount of time which lapsed, as it seemed like an eternity to the Plaintiff). 16. Plaintiff was crying and begging Defendant Elmore to stop beating him, to no

avail. Moreover, another MBPD officer and who also is an agent, servant and employee of Defendant City, whose identity is currently unknown to the Plaintiff, watched the savage beating and failed to intervene to prevent Defendant Elmore from violating the constitutional rights of the Plaintiff, notwithstanding that law enforcement officers have an affirmative duty to intervene when the officer is aware of constitutional violations in said officers presence and must take reasonable steps to protect the victim of another officers use of excessive force. 17. Said unidentified MBPD officer failed to prevent excessive force from being

committed against Plaintiff when he had a reasonable opportunity to do so. 18. Following the vicious beating of the Plaintiff, Defendant Elmore brought the

Plaintiff to the Defendant City police station, and Plaintiff showed serious signs of physical altercation about his face and body, especially his swollen and beaten in face, and Plaintiff was in an obvious state of constant pain and suffering. He was held in a cell at MBPD until approximately midnight or 1 a.m. Then Plaintiff was taken to a Miami-Dade County jail. He was placed in the cell, and then given a medical injection in or about the buttocks area. 19. A female guard was calling out names but Plaintiff could not stand up. The

female guard then said something to the effect that Plaintiff should be taken immediately to an 4

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emergency room. Male guards then assisted Plaintiff in walking over to Jackson Memorial Hospital. At that time, an unidentified police officer stated that charges against the Plaintiff were dropped. However, a doctor viewed Plaintiff and stated that Plaintiff could not go home, at which time Plaintiff was admitted and stayed admitted at Jackson Memorial Hospital for various days before he was released. 20. Upon information and belief, Defendant Elmore stated that Plaintiff had fallen

which is not only inconsistent with the fact that Plaintiff was beaten by Elmore, but inconsistent with the physical appearance of the Plaintiffs face which looked like it had been used as a punching bag by a professional fighter, including blackened eye. 21. Plaintiff sought immediate medical attention at Jackson Memorial Hospital, which

revealed not only that his face had been severely beaten, but that he had three fractured ribs, a ruptured right rotator cuff which required surgery and which was subsequently operated on, and head and neck injuries due to the subject incident. 22. As a result of the subject incident, the Plaintiff experienced severe pain and

suffering due to his physical injuries, including mental anguish, mental and emotional suffering, embarrassment, shame, and humiliation, as well as damages to his constitutional rights due to the unreasonable seizure of his person and the use of excessive, unreasonable and unjustified force against him. Additional Facts Surrounding Liability 23. Miami Beach Police Department (MBPD) is an administrative subdivision of

Defendant City. Defendant City, acting through its Mayor, City Commission and City Manager, is the ultimate policymaking authority for all officially-adopted policies and procedures implemented by employees of MBPD, including Defendant Elmore. Further, it is the entity

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legally responsible for the hiring, retention, supervision, and training of employees of the MBPD, as well as administering any discipline to said employees. 24. On information and belief, the City Manager delegated to the Chief of Police of

the MBPD the authority to develop, direct, and implement policies for all sworn law enforcement officers, compiled in part in the Miami Beach Police Standard Operating Procedures Manual, which set forth purported guidelines controlling the interaction between MBPD law enforcement officers (including Defendant Elmore) and the general public. 25. Defendant City has been placed on notice that there is a pervasive and systemic

pattern, custom and practice within MBPD to use excessive force by rendering vicious beatings to members of the general public even those who do not resist arrest, including innocent bystanders and those accused of minor criminal infractions -- and to make great efforts to use such excessive force outside the view of third-party witnesses, and frequently while the person detained is subdued, restrained, or otherwise still in handcuffs. False police reports are rendered, and charges are initially pursued against the victims of these unconstitutional beatings but then later are dropped in an effort to intimidate the victims. Finally, the investigations into such allegations of excessive force are almost always a virtual whitewash, as MBPD officers are rarely if ever punished for such conduct even when investigations reveal conduct that requires immediate action to be undertaken against the officer(s) involved to prevent such occurrences in the future. 26. Specifically, the notice to the City of the unconstitutional conduct of its officers

and employees has occurred through notices of intent to sue, lawsuits, internal affairs investigations, and media reports. 27. Thus, Defendant City, and Defendant Elmore, are also on notice of the fact a

systemic and pervasive pattern and practice of excessive force exists within the MBPD and that 6

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members of the citizenry are the victims of excessive force committed by police officers of the Defendant City in violation of the Fourth Amendment. Defendant City police officers are allowed and indeed encouraged to commit excessive force with impunity knowing that no discipline, much less meaningful discipline, will follow for acts of excessive force. Such illegal conduct is ratified and condoned by the Defendant City. 28. Defendant Elmore is comfortable in the knowledge that any acts of excessive

force that he commits will not result in discipline by the Defendant City even when the act of excessive force occurs within MBPD. Thus, the lack of discipline for excessive force allowed Defendant Elmore to commit excessive force against the Plaintiff because Defendant Elmore knew that there would be no official reprisals for his actions against Plaintiff. 29. In fact, this is not Defendant Elmores first time being accused of constitutional

violations for having used excessive force on a member of the general public while serving as a MBPD police officer for Defendant City, and where an internal affairs whitewash resulted in no discipline to Defendant Elmore: a. IA 2008-028; Mr. Johnny Weeks (Weeks) was with a friend who was involved in an altercation at Fat Tuesdays nightclub. Weeks escorted his friend out of the bar to avoid an escalation of the incident. Officers Elmore and Dominguez approached them. One of the males said something that infuriated the officers. Officer Elmore began bouncing like a bouncer and punched a citizen named Johnny Hudson (Hudson) in the face who fell to the ground. While on the ground Officer Elmore kicked Hudson. Weeks pulled out his cell phone and took a picture of the incident. The bouncers from Fat Tuesdays then told Officer Elmore that Weeks had a photo. Officer Elmore then punched Weeks. Officer Elmore then kicked Weeks. Both Weeks and Hudson were handcuffed and seated on the ground. The manager Fat Tuesdays subsequently arrived on the scene and informed the officers that neither Weeks nor Hudson caused a problem in the club. Weeks and Hudson were then released. Two witnesses saw the beating of Weeks and Hudson and a certain Lissette Luna (Luna) videoed the incident with her camera. Officer Elmore discovered Luna was videoing and took her camera. The camera was never returned to her. Luna and 7

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her boyfriend testified about the beating of Weeks and Hudson, and the theft of Lunas camera. Nonetheless, no officer was disciplined for the beating of Weeks or Hudson; and b. IA 2009-008; Serrano was on City bus and wanted to pay the fare with pennies. The bus driver called the police and officer Elmore of MBPD responded. Officer Elmore confronted Serrano, pulled him by his shirt, kicked him in the stomach area, threw him onto the floor of the bus and sprayed him with a chemical agent. Serrano was allowed to leave and later stumbled into a store where he was assisted by management with decontamination. Later, Officer Elmore lied to fellow officers indicating he did not know who sprayed Serrano. Despite physical evidence of excessive force, witnesses and fabrications to fellow officers, Officer Elmore was not disciplined for excessive force. 30. Upon information and belief, the discovery phase of this litigation will further

reveal other instances where Defendant Elmore has engaged in excessive force only to receive no discipline for his actions. 31. In addition to the above-described acts, the Defendant City is on notice through

the clear actions of excessive force committed against the Plaintiff in this action. Further, the Defendant City is on notice of excessive force being committed against the citizenry by the MBPD through some of the following specific acts: a. IA 2007-032; Juan Da Pena was attending a concert. While at the concert Da Pena had a heated verbal exchange with MBPD officer Mercado. A witness to the event saw the punch and the punch was not denied by the officer. Yet Internal Affairs cleared the officer and he was not disciplined. b. IA 2007-045; Michael Bruce was walking with a friend and was stopped unlawfully by Officer Moraga of MBPD. They were ordered to sit on the curb. Officer Mitat of MBPD arrived and ordered Bruce to stand up. Bruce was having difficulty standing due to the handcuffs and the position of his feet. Bruce stumbled backwards as he was rising and

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Officer Mitat immediately took him to the ground. Officer Moraga ran over and began punching him repeatedly on his face and head. Though the abuse was witnessed, no officer involved was disciplined. c. IA 2008-008; Milton Rodriguez was walking with his family when he was approached by a man and asked if he wanted to buy marijuana. Rodriguez declined and continued walking with his family. Undercover MBPD officers later approached the Rodriguez family and drew their weapons on Rodriguez. Rodriguez asked the reason for the stop and he was tased by Det. Reina of MBPD. Rodriguez was tased twice and hit his head on the pavement. He was taken to the MBPD station where he was hit in the face with a police radio by Det. Reina. Though he had injuries consistent with his statement and his family testified that he had injuries that were not the result of what occurred at the scene, no officers involved were disciplined. d. IA 2005-004; While being transported to jail, Damian Osorio was tased by Officer Armatrading of MBPD. The investigation by Internal Affairs found that Officer Armatrading used the taser on Osorio four times as an intimidation technique. Though the investigation found that Officer Armatrading violated policy by not providing appropriate aid after the tasing took place; there was no discipline for the tasing itself. e. IA 2005-007; Daniel Oppenheim was ejected from a club and called MBPD for assistance. Sergeant Rojo arrived and threatened Oppenheim into not making a complaint. Oppenheim was then arrested and once at the MBPD holding facility he was kicked by Officer Smith of MBPD in the back of his legs and groin. Oppenheim produced photographs of injuries but the involved officers received no discipline. f. IA 2005-014; MBPD officer Sunday Garcia filed an excessive force report against Officer Douglas Simon. Officer Garcia reported seeing Officer Simon walk over to a 9

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handcuffed suspect named Angel Melendez and place his foot on the left side of Melendezs face and then twist his foot back and forth causing blood to emit form Melendezs face. Then Officer Simon had Melendez stand up and he hit Melendez in the groin area with his asp. Officer Simon then put his asp on Melendezs neck by the carotid area and applied pressure to his neck by grabbing Melendezs hair and forcing the asp on Melendezs neck. Officer Simon then slammed Melendezs head on a marked police vehicle three times. The IA investigation confirmed the injuries to Melendez as being consistent with the described injuries. Yet, even with the other officers damaging eyewitness testimony the excessive force allegation was exonerated and no discipline was received for beating Melendez. g. IA 2009-036; Officer Anastasi was captured on MBPD video surveillance kicking a handcuffed prisoner named Glen Deason, two times in the face/head area. The reports written by Officer Anastasi were not consistent with the facts seen on the video. Officer Anastasi was allowed to retire and was not disciplined for this incident. h. IA Case No. 2008-013; While walking on Miami Beach, Michael Minian and Ishmael Castillo noticed a bike patrol of MBPD officers passing by. Castillo yelled, F___ the police. The police returned, handcuffed Castillo and dared Castillo to repeat what he had just said. Castillo was then punched in the side and back for approximately 45 seconds. Minian stated to the officers that they did not have to do that to Castillo. Minian was then grabbed by the neck, slammed to the ground, and handcuffed. Both Minian and Castillo were then taken to the MBPD station. Upon arrival Castillo was taken out of the car and beaten again inside of the parking garage. While being escorted into the station Minian was punched in the jaw and stomach. Castillo was taken to a cell and asked to spread his legs and an MBPD officer kicked him in the testicles. He was then hit by two officers. Each time that he fell, the officers would stand him up and hit him again. Castillo decided to stay down to stop 10

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the beating from progressing further. Another officer asked him to spread his legs again and attempted to kick him in the testicles a second time. Both men were charged with disorderly conduct and the matters were dismissed in criminal court. Though both men showed

physical evidence of being beaten in their arrest photographs, the officers involved received no discipline. i. IA 2008-036; Cedel Thomassin was placed under arrest by Officer Martineau. Officer Martineau punched Thomassin five times in the face for no reason causing Thomassin to receive facial lacerations and a broken nose. None of the injuries were documented on any police report. Thomassin had to be taken to Ward D at Jackson

Memorial Hospital to be accepted by the Corrections Department. The visit to Ward D was also not documented on any police paperwork. Despite the facial abrasions and the broken nose, the Internal Affairs investigation found the excessive force to be unsubstantiated and no officer was disciplined for the beating of Thomassin. j. IA 2008-029; Ian Cooley was stopped by Officer Doty for speeding. Cooley questioned the stop and Officer Doty placed him under arrest. Two civilian witnesses

testified to Internal Affairs that they saw Officer Doty punching Cooley in the head and back for no apparent reason. Once at the MBPD, Cooley was escorted to the holding area where Officer Doty screamed obscenities. She, along with two officers, struck him in the head approximately 30 to 40 times. Upon release Cooley went to Mt. Sinai where he was diagnosed with a ruptured eardrum. No officers received discipline. k. IA 2007-026; Keith Thompson, a Sergeant in the United States Army, observed Miami Beach Police Officers Jose Reina and Albert Estraviz committing excessive force against an individual. Sergeant Thompson spoke to the officers and informed them that the subject was repeatedly saying that he could not breathe. Thompson was attempting to take 11

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pictures of the excessive force with his cell phone. Thompson was ordered to step back and he complied. As he was leaving the area Detective Reina pushed him up against the wall and began choking him. Thompson indicated to the police officer that he could not breathe. Thompson identified himself as military personnel and Detective Reina applied more pressure to his throat. Thompson displayed physical injuries consistent with him being beaten by the police including bruising on his neck. Thompson was falsely charged with Disorderly Intoxication and Resisting an Officer with Violence. These charges were dropped by the State Attorneys Office. However, Internal Affairs even with the medical corroboration indicating Sergeant Thompson was choked found all allegations of excessive force to be unsubstantiated and cleared the officers. l. IA 2008-026; Santos Ordonez works as a manager at the Gallery Dj vu on South Beach. Ordonez entered after hours, which set off the alarm. The owner called and Ordonez let the owner know that he was in the store and the alarm company was called and told it was a false alarm. Police responded and saw Ordonez in the store and wanted him to open the door. Ordonez did not open the door and MBPD entered through the rear of the gallery. Ordonez was taken to the ground and tased five times in the back. He was also hit in the face so hard that he was in and out of consciousness. Despite a video which shows Ordonez being tased five times and being kicked in the groin, no officers were disciplined for excessive force. m. IA 04-012; John Gibson was arrested for Disorderly Intoxication. He made comments while at the holding facility at MBPD that angered Detention Officer Booker Abercrumbie. Officer Abercrumbie moved Gibson from a populated cell to one where no other prisoners were present. Officer Abercrumbie then sprayed chemical agents in Gibsons face and also repeatedly punched him in the face. 12 The Internal Affairs investigation

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concluded that Gibson was in fact injured in the detention facility noted the lacerations on Gibsons face and confirmed that he was sprayed with the chemical agent. However, no officer was disciplined for battering Gibson. n. IA 2009-013; Steven Gomez was on the beach and became involved in a verbal altercation with other males. Officers responded as Gomez was walking away from the scene. City officer Chambers grabbed Gomezs arm. Unaware that it was an officer that grabbed his arm, Gomez pulled away. Other officers arrived, threw Gomez in the sand and held him down. One officer sat on Gomezs head while he was face down in the sand and the juvenile was unable to breathe. He struggled up and was punched in the face. He went into a fetal position and was punched several more times and then handcuffed. The incident was filmed by another male and the file was presented to the Internal Affairs department. The juvenile was lacerated and was diagnosed at JMH with a fracture orbital bone. All criminal charges were dropped by the State Attorneys Office. Despite a number of

witnesses that testified to the beating, and the video evidence of it, no officers were disciplined for the beating of Gomez. o. In February 2003, MBPD officer Varon drove an SUV on the beach in a manner sufficiently reckless to constitute vehicular homicide, causing the death of a teenaged sunbather and permanent disfigurement of her sister; the investigation was insufficient and no charges were ever brought against the officer. p. In September 2003, MBPD officer Rice-Jackson was issuing a ticket to a married couple walking their dog in a public park for an unknown reason, and when the woman asked for Rice-Jacksons identification, she was assaulted without cause. MBPD officer Serrano then participated in the incident, at which time both victims were handcuffed, beaten and arrested. The MBPD officers filed a false report claiming self-defense. On information and 13

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belief, neither officer has received any disciplinary measures of the offense. q. In November 2003, MBPD officer Dominguez drove a city vehicle in a reckless manner, causing an accident that severely injured four persons on two motorcycles; the investigation into this matter was at best, decidedly lacking. r. In November 2003, MBPD Lt. E. Yero disobeyed orders from a City of Miami superior during a joint law enforcement exercise, specifically the policing of the FTAArelated demonstrations on Biscayne Blvd. in Miami, and Lt. Yero wrongfully permitted the discharge of tear gas to disperse a gathering of hundreds of persons involved in First Amendment-protected activity. Lt. Yero further permitted officers under his command to utilize other chemical agents and batons on unarmed demonstrators; on information and belief, neither Lt. Yero nor any of the officers under his command ever faced any disciplinary actions for their roles in the FTAA, despite sworn testimony in federal lawsuits, from numerous Miami police officials, relating to the misconduct. s. In early 2004, police were called to the residence of MBPD Sgt. Berrian, who had engaged in acts of domestic violence against his wife, who had a bleeding lip and bruises on her head; the investigation was minimal and no discipline was found to have been imposed upon this officer, and there is no record of anger management classes or other minimal activity to address this problem. t. In February 2004, MBPD officers Rabelo, Garcia and McCue entered into a private apartment without consent, assaulting the resident, thereby engaging in violations of the Fourth Amendment protections against warrantless entry without probable cause and against excessive force. After an inadequate investigation, the IA Unit cleared the officers of the wrongdoing. u. In February 2004, a young man ran from MBPD officers; when he was grabbed 14

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and subdued, the MBPD officers, including K. Millan, proceeded to kick the arrestee in the body and face numerous times, in violation of the Fourth Amendment. The IA Unit ruled the incident as unsubstantiated. v. In May 2004, a woman was parking her vehicle with a valet, and was in the vicinity of MBPD officers E. Cruz and G. Gutierrez, one of the officers asked the woman to move, and this request led to a physical assault by the officer and numerous racial slurs, witnessed by bystanders. After investigation, the IA Unit inappropriately dismissed the excessive force claim and imposed minimal punishment for the racial slur. w. In August 2004, a man was stopped by MBPD officer Nolan during a traffic stop, and without justification the man was physically assaulted, by a punch to his face delivered by the officer without cause. The IA Unit ruled the incident as unfounded, essentially declaring that the assertion was a total fabrication. x. In November 2004, MBPD officers E. Cruz, G. Gutierrez and J. Periera were working off duty at a night club, at which time the victim was leaving the club, but apparently not fast enough for the officers. The victim was knocked to the ground, brutally beaten causing facial injuries including a fractured nose, and tasered without justification. The officers arrested the victim and falsely charged him with felony-level crimes including battery on a police officer. The testimony of independent witnesses caused the State Attorneys Office to dismiss all charges. The victim filed a complaint with the IA Unit, which in typical fashion only sustained a portion of the charges; despite past charges, on information and belief the officers were not discharged from the MBPD despite their falsification of the arrest report and the savage beating of this victim. y. In January 2005, an emotionally-disturbed person (EDP), entered into the private bathroom of a public house, causing the bartender to summon police. MBPD officers 15

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in plainclothes, M. Muley, M. Schoenfeld and C. Pfrogner responded. Officers Muley and Schoenfeld burst into the bathroom with guns drawn and startled the EDP, who, believing that a robbery or such was occurring fled down the hallway, at which time officer Muley gave chase and shot the unarmed EDP multiple times. Despite the obvious Fourth Amendment violation(s), on information and belief the officers have never been disciplined. z. Case No. 1:11CV23195: On January 5, 2008, MBPD officers E. Figueroa and R. Azicri beat two plaintiffs repeatedly, while said individuals were in restraints and in police custody, for refusing to hand over video taken of a traffic stop. The physical abuse included repeated kicks to the groin and stomach area of one plaintiff and beating one plaintiff in the head with a book. Upon information and belief, the officers involved were never disciplined for their conduct. aa. In April 2005, a woman was involved in an altercation, and sought assistance from MBPD officers L. Corps and D. Gotsis. The officers decided to arrest this woman, and they handcuffed her and used excessive force in dealing with her. The victim filed an IA complaint, and the findings of the IA Unit were that the officers did not engage in excessive force, but did have inaccuracies in their report; the more serious charge was deemed as unfounded while the less serious charge was upheld, despite the evidence supporting all charges against the officers. bb. In June 2005, a young man had a brief encounter with MBPD officer R. Lawrence, which resulted in the victim being grabbed by the throat without justification. Following a complaint to the IA Unit, the complaint was deemed as unsubstantiated. cc. Case No. 1:02CV20800: On January 29, 2001, Davis was subjected to a traffic stop by the MBPD. Davis was approached by officer Acosta who had his gun drawn and placed the barrel of the gun to the side of Daviss head. Thereafter, Davis was violently 16

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thrown to the ground, physically abused, and handcuffed. All actions taken by the officers were done without reasonable cause that Davis posed a threat or danger to the officers or the public. Davis believes these actions were done to him because of his race. dd. In February 2006, an off-duty City of Miami police officer was picking up his children when he was assaulted. The officer held the assailants at bay until the MBPD arrived, at which time the Miami officer was struck in the neck, had a gun placed to his head, and MBPD officer D. Bates applied a taser for good measure. Following the complaint, the IA Unit exonerated the MBPD officers of excessive force, while agreeing that Officer Bates failed to file a use of force report. ee. In July 2006, a person encountered several officers, and after a brief verbal exchange, MBPD officer E. Perez threw a punch into the victims face. Following an IA complaint, the IA Unit declared the charge to be unsubstantiated. ff. Case No. 1:10-cv-24155: On or about August 23, 2007, Casey was arrested by Police Officer Macias and another officer at approximately 3:00 a.m. at the 2100 block of Washington Avenue, Miami Beach without probable cause. Defendant Macias used

unreasonable force in handcuffing Casey and placing her into his police car. Then, Officer Macias drove Casey to a dark alley and dragged her out of his car. Officer Macias proceeded to fondle Caseys breasts and put his hands down her pants. Further, Macias again used unreasonable force to put Casey back into the patrol car and force his tongue down her throat as he rubbed her thighs with his hands. The charges against Casey were dropped and she brought an action against Macias and the City. gg. Case No. 1:10-cv-23139: Feliciano was at her home in Miami Beach on the evening of September 2, 2006 with her three minor children and her domestic partner. She heard a knock around 9 p.m., and her eldest son answered the door. Officers Acosta, Dohler, 17

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and Dozier were at the door and informed Feliciano that they had received an anonymous tip that persons inside the house were selling drugs. After refuting the allegation and refusing consent for the officers to come into the residence, the Officers informed Feliciano that they did not need a search warrant and warned that her children can be taken from her because she had a religious candle lit by the window. When her boyfriend came out of a room the Officers pushed Feliciano aside and rushed him. Then, one of the Officers held Felicianos arms behind her back and repeatedly slammed her abdomen violently into the wooden side arm of a couch. Feliciano begged the Officer to stop because she was 3 months pregnant but the Officer ignored her and continued to violently slam her abdomen and face into the wooden side arm of the couch. The next day, Feliciano checked into the emergency room at a hospital, where an examination confirmed she was having a miscarriage. An obstetrical medical procedure was performed to remove the remainder of her unborn child. hh. Case No. 1:12-cv-20575: On or about February 16, 2008, while Duquesne was handcuffed in the backseat of a MBPD car he was punched in the face by MBPD officers Muley, Archer, and Maher. Officer Maher then drove Duquesne to the MBPD where he was beaten again on multiple occasions by Muley and Archer. Although, he reported the beatings to a Spanish-speaking officer, the officer did nothing and once the Spanish-speaking officer left Duquesnes presence, the beatings continued. Duquesne was taken to Jackson Memorial Hospital with multiple injuries including a swollen eye, busted lip, and blood on multiple spots of his face. He was charged with Battery on Law Enforcement, Possession of Cocaine, Resisting without Violence, and Drinking in Public and jailed for 340 days. Upon the second day of his trial, the MBPD officers failed to appear and testify against Duquesne and all charges were dropped. ii. Case No. 1:11CV22051: On June 14, 2009, Samer Shehada and Husien Shehada 18

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(Decedent) walked down Washington Avenue and purchased cigarettes. As they walked they heard a loud voice yell commands. Shehada and Decedent turned towards the commands and saw MBPD officer Tavss pointing a firearm towards them. They raised their arms in supplication to the officer demonstrating to him and any other officers present that they were unarmed and posed no threat to the officers. Within two seconds of hearing the command, Tavss shot at Decedent three times, and one of those shots were fatal. Thereafter, Samer was arrested and detained. The estate of the Decedent and his brother Samer Shehada brought an action against the MBPD and the officer individually. jj. Melissa Plata v. City of Miami Beach, et al: In November 2003, Plata was on her way to Miami International University (MIU) in order to register for classes. She approached MBPD officer Ortivero to ask him if he could contact her former boyfriend who also was a MBPD officer. Officer Ortivero ignored her inquiry so she left while muttering her dissatisfaction under her breath. MBPD officer Ortivero then rushed and slashed toward her left forearm with handcuffs. Plata wears a prosthetic device as a result from a car accident and the twisting motion of her prosthetic by the officer caused Plata a great deal of pain and she released the device. Then, Plata was taken to the ground by officer Ortivero causing her jaw to hit the cement and drove his knee and forearm into Platas back and neck area. Thereafter, she was arrested and brought to the MBPD where she was slapped in the face by officer Ortivero, strip searched in the view of other the officers, and thrown naked into a jail cell for twenty to thirty minute. During her 24 hour detention, she was never fed nor given any water. Her case was dismissed against her and she was given back all her personal items except for her prosthetic device which she was told was lost. 32. Upon information and belief, the discovery phase of this litigation will further

reveal many other instances where Defendant City, by and through the MBPD and its officers 19

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and employees, has allowed, condoned, encouraged, and otherwise engaged in excessive force only to fail to discipline for such actions, much less properly supervise and train to prevent further abuses. 33. As a result of Defendants conduct, as described above, Plaintiff has suffered

serious physical injuries, mental anguish, shame, humiliation, and other damages as set forth below. COUNT I 42 U.S.C. 1983 EXCESSIVE FORCE (AGAINST DEFENDANT PHILIP ELMORE) 34. Plaintiff, Dario D. Vasquez, re-alleges and re-avers each and every allegation set

forth in Paragraphs 1 through 33 as if set forth fully herein, and further states as follows: 35. This cause of action is brought by Plaintiff against Defendant Elmore for his use

of excessive force under color of law which deprived Plaintiff of his constitutionally protected rights under the Fourth Amendment to the United States Constitution. 36. At all times material, Plaintiff had the constitutional right to be free from the use

of excessive force against his person and to be free from unlawful searches and seizures. 37. Defendant Elmore violated 42 U.S.C. 1983 by inflicting serious personal injury

upon Plaintiff that was grossly disproportionate to the force necessary to arrest Plaintiff in violation of his rights under the Fourth Amendment to the United States Constitution. 38. Defendant Elmore, while acting in his capacity as a police officer for Defendant

City and under the color of law, did intentionally use excessive force by repeatedly striking Plaintiff during his detention, and while Plaintiff was in restraints and not resisting his arrest. 39. Defendant Elmore, while acting in his capacity as a police officer for Defendant

City and under the color of law, did intentionally engage in an unlawful search and seizure by his conduct toward the Plaintiff.

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40.

The force utilized by Defendant Elmore was sadistically and maliciously applied

for the very purpose of causing harm to the Plaintiff, and more than a de minimis injury resulted therefrom. 41. As a direct and proximate result of the illegal acts of Defendant Elmore, Plaintiff

has been damaged, including but not limited to loss of income and future earning capacity, as well as permanent physical injuries which were caused, activated or otherwise aggravated by the subject incident, and Plaintiff shall further incur medical losses and impairments in the future. 42. As a direct and proximate result of the illegal acts of Defendant Elmore, Plaintiff

has in the past and will in the future undergo painful and extensive medical care and treatment, including but not limited to right shoulder arthroscopic rotator cuff repair, and has in the past incurred and will in the future incur medical bills and expenses attendant to his aforesaid injuries. 43. As a direct and proximate result of the illegal acts of Defendant Elmore, Plaintiff

has in the past and will in the future suffer great pain and suffering, both physical and mental anguish, as well as shame, humiliation, and the loss of capacity for the enjoyment of life. WHEREFORE, Plaintiff demands the following relief against Defendant Elmore: a. An award of compensatory damages; b. An award of punitive damages; c. An award of attorneys fees and costs pursuant to 42 U.S.C. 1988; and d. An award of such other and further relief the Court deems just and appropriate. COUNT II 42 U.S.C. 1983 EXCESSIVE FORCE (AGAINST DEFENDANT CITY) 44. Plaintiff, Dario D. Vasquez, re-alleges and re-avers each and every allegation set

forth in Paragraphs 1 through 33 as if set forth fully herein, and further states as follows:

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45.

This cause of action is brought by Plaintiff against Defendant City for deprivation

by its agent, servant, and employee, namely Defendant Elmore, of constitutional rights within the meaning of 42 U.S.C. 1983 in violation of the Fourth Amendment to the United States Constitution. 46. Defendant Elmore was acting under the color of law, as authorized agent of

Defendant City, while arresting Plaintiff in the furtherance of his duties. 47. The unidentified MBPD was acting under color of law, as authorized agent of

Defendant City, when he had a reasonable opportunity to intervene, yet failed to intervene and protect the Plaintiff from Defendant Elmores illegal acts which were committed in his presence. 48. The constitutional deprivation was caused by Defendant Citys numerous areas of

deliberate indifference as outlined in Paragraphs 1 through 33 above, including: a. Custom of condoning, allowing, and encouraging numerous instances of illegal excessive force and police brutality without punishing its police officers, including Defendant Elmore. The above-mentioned actions were not isolated incidents. Defendant City has a history of exonerating officers for allegedly using excessive force against its citizens, including Defendant Elmore. Officers within the MBPD are secure in knowing that a reported incident (if the incident gets reported by and MBPD officers at all as many incidents are intentionally covered up with the assistance and acquiescence of multiple MBPD officers) will not result in an meaningful disciplinary proceeding or punishment, even when presented with video evidence, the testimony of independent witnesses, or even the testimony of fellow MBPD officers. Defendant City condones an officers action even when other nonpolice witnesses have complained that force used was excessive. Prior to 22

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February 4, 2008, Defendant City permitted and tolerated the practice of unjustified and unreasonable uses of excessive force by its officers under the color of law. Subsequent to February 4, 2008, Defendant City continued to permit and tolerate incidents of excessive force establishing excessive force as an unwritten custom and practice of MBPD. This established MBPD custom and practice caused injury to the Plaintiff herein when he became a victim of excessive force on February 4, 2008. 49. Moreover, at all times material hereto, Defendant City was responsible for

implementing the rules and regulations in regard to hiring, retaining, screening, training, supervising, controlling, disciplining and assigning MBPD police officers to their duties in the City of Miami Beach. 50. Defendant City was deliberately indifferent in that it either expressly or impliedly

acknowledged and assented to the failure to hire, retain, screen, train, supervise, control, discipline, and otherwise assign employees of Defendant working as MBPD officers, including but not limited to Defendant Elmore, for dangerous propensities, lack of training and skill, and other identifiable characteristics making said MBPD officers unfit to perform their lawful duties. 51. Defendant City was deliberately indifferent to the rights of the public, including

the Plaintiff, in that it failed to determine whether members of the MBPD, including Defendant Elmore, posed a threat to the public as a result of their propensity to commit unlawful acts and to engage in violent activity, including acts of excessive force. 52. Defendant City, through its deliberate indifference, failed to ensure that MBPD

officers, including Defendant Elmore, did not violate the constitutional and statutory rights of citizens of the State of Florida, including the Plaintiff, while said MBPD officers were acting under color of state law for Defendant City. 23

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53.

The deliberate indifference of Defendant City exhibited a reckless, wanton, and

callous disregard for the rights of persons, including the Plaintiff, who might be brutally assaulted, injured, battered or otherwise maimed for life by MBPD officers, including Defendant Elmore, who were inadequately trained, supervised, and disciplined. 54. Defendant City was deliberately indifferent in the selection, retaining, training,

and supervising of Defendant Elmore, as a MBPD officer in that Defendant City: (a) hired and retained Defendant Elmore when Defendant City knew, or in the exercise of reasonable care should have known, of the disposition of Defendant Elmore to engage in such unlawful conduct including excessive force and the unlawful conduct complained of herein; (b) failed to remove Defendant Elmore from his position of authority as MBPD officer despite the fact it knew or should have known of the disposition of Defendant Elmore to engage in such unlawful conduct including excessive force and the unlawful conduct complained of herein; (c) failed to take any meaningful disciplinary action against Defendant Elmore despite the fact it knew or should have known of the disposition of Defendant Elmore to engage in such unlawful conduct including excessive force and the unlawful conduct complained of herein; and (d) failed to protect members of the general public, including the Plaintiff, despite the fact it knew or should have known of the disposition of Defendant Elmore to engage in such unlawful conduct including excessive force and the unlawful conduct complained of herein. 55. Additionally, the cited misconduct represents a pattern, custom and practice in

which members of the public were savagely beaten, injured, and otherwise endangered by the intentional and reckless misconduct of MBPD officers, and that deliberate indifference was widespread as to the use of excessive force, illegal behavior, and widespread incompetence throughout Defendant City including the MBPD. This pattern, custom, and practice includes not only the failure to identify and discipline the unlawful and excessive use of force and seizures by 24

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MBPD personnel, but additionally, the failure to re-train, supervise, or otherwise remove MBPD officers who engage in such unlawful conduct as the de facto policy and custom of Defendant City to tolerate, encourage, and even protect such acts by MBPD officers. 56. There existed a strong likelihood, rather than a mere possibility, that the

Defendant Citys customs, policies, and procedures would result in a constitutional violation like the violation suffered by the Plaintiff. 57. Defendant City and its city policy makers were aware or should have been aware

of the need for different policy and training. 58. Further, Defendant Citys training program was clearly inadequate and likely to

give rise to constitutional violations, such as a clearly inadequate training for MPBD police officers in the constitutional limits on the use of excessive force. 59. Moreover, Defendant Citys policy and training program as to use of excessive

force has so often led to violations of constitutional rights similar to those suffered by the Plaintiff that the need for further training must have been (and should have been) plainly obvious to the Defendant Citys policy makers. 60. The deliberate indifference of the Defendant City violated the constitutional rights

of its citizenry, including the Plaintiff, for which 42 U.S.C. 1983 provides the appropriate remedies as requested herein. 61. As a direct and proximate result of the illegal acts of Defendant Elmore, while

Defendant Elmore was an agent, servant, and employee of Defendant City, and the unconstitutional policies, customs and practices of Defendant City, Plaintiff has been damaged, including but not limited to loss of income and future earning capacity, as well as permanent physical injuries which were caused, activated or otherwise aggravated by the subject incident, and Plaintiff shall further incur medical losses and impairments in the future. 25

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62.

As a direct and proximate result of the illegal acts of Defendant Elmore, while

Defendant Elmore was an agent, servant, and employee of Defendant City, and the unconstitutional policies, customs and practices of Defendant City, Plaintiff has in the past and will in the future undergo painful and extensive medical care and treatment, including but not limited to right shoulder arthroscopic rotator cuff repair, and has in the past incurred and will in the future incur medical bills and expenses attendant to his aforesaid injuries. 63. As a direct and proximate result of the illegal acts of Defendant Elmore, while

Defendant Elmore was an agent, servant, and employee of Defendant City, and the unconstitutional policies, customs and practices of Defendant City, Plaintiff has in the past and will in the future suffer great pain and suffering, both physical and mental anguish, as well as shame, humiliation, and the loss of capacity for the enjoyment of life. WHEREFORE, Plaintiff demands the following relief against Defendant City: a. An award of compensatory damages; b. An award of punitive damages; c. An award of attorneys fees and costs pursuant to 42 U.S.C. 1988; and d. An award of such other and further relief the Court deems just and appropriate. COUNT III STATE TORT OF BATTERY (AGAINST DEFENDANT PHILIP ELMORE) 64. Plaintiff, Dario D. Vasquez, re-alleges and re-avers each and every allegation set

forth in Paragraphs 1 through 33 as if set forth fully herein, and further states as follows 65. On February 4, 2008, Plaintiff was arrested by Defendant Elmore who did

unlawfully batter, touch, and strike Plaintiff without his consent and against his will.

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66.

As a direct and proximate result of said acts of Defendant Elmore, Plaintiff has

been damaged, including but not limited to loss of income and future earning capacity, as well as permanent physical injuries which were caused, activated or otherwise aggravated by the subject incident, and Plaintiff shall further incur medical losses and impairments in the future. 67. As a direct and proximate result of said acts of Defendant Elmore, Plaintiff has in

the past and will in the future undergo painful and extensive medical care and treatment, including but not limited to right shoulder arthroscopic rotator cuff repair, and has in the past incurred and will in the future incur medical bills and expenses attendant to his aforesaid injuries. 68. As a direct and proximate result of said acts of Defendant Elmore, Plaintiff has in

the past and will in the future suffer great pain and suffering, both physical and mental anguish, as well as shame, humiliation, and the loss of capacity for the enjoyment of life. WHEREFORE, Plaintiff demands compensatory damages against Defendant Elmore; for his personal injuries; pain and suffering; past, present, and future medical expenses; mental anguish; loss of earning capacity; and loss of capacity to enjoy life; as well as his costs, and all other relief the Court deems just and proper. COUNT IV STATE TORT OF BATTERY (AGAINST DEFENDANT CITY) 69. Plaintiff, Dario D. Vasquez, re-alleges and re-avers each and every allegation set

forth in Paragraphs 1 through 33 as if set forth fully herein, and further states as follows 70. On February 4, 2008, Plaintiff was arrested by Defendant Elmore who did

unlawfully batter, touch, and strike Plaintiff without his consent and against his will. 71. Defendant Elmore was acting in the course and scope of his duties as an agent,

servant, and employee of Defendant City.

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72.

As a direct and proximate result of said acts of Defendant Elmore, for which

Defendant City is responsible, Plaintiff has been damaged, including but not limited to loss of income and future earning capacity, as well as permanent physical injuries which were caused, activated or otherwise aggravated by the subject incident, and Plaintiff shall further incur medical losses and impairments in the future. 73. As a direct and proximate result of said acts of Defendant Elmore, for which

Defendant City is responsible, Plaintiff has in the past and will in the future undergo painful and extensive medical care and treatment, including but not limited to right shoulder arthroscopic rotator cuff repair, and has in the past incurred and will in the future incur medical bills and expenses attendant to his aforesaid injuries. 74. As a direct and proximate result of said acts of Defendant Elmore, for which

Defendant City is responsible, Plaintiff has in the past and will in the future suffer great pain and suffering, both physical and mental anguish, as well as shame, humiliation, and the loss of capacity for the enjoyment of life. WHEREFORE, Plaintiff demands compensatory damages against Defendant City; for his personal injuries; pain and suffering; past, present, and future medical expenses; mental anguish; loss of earning capacity; and loss of capacity to enjoy life; as well as his costs, and all other relief the Court deems just and proper. DEMAND FOR JURY TRIAL Plaintiff demands a trial by jury of all issues so triable under the law.

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CERTIFICATE OF SERVICE WE HEREBY CERTIFY that on May 29, 2012, we electronically filed the foregoing document with the Clerk of the Court using CM/ECF. We also certify that the foregoing document is being served this day on all counsel of record identified on the attached Service List in the manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those counsel or parties who are not authorized to receive electronically Notices of Electronic Filing. Respectfully submitted, LAW OFFICES OF DOUGLAS J. JEFFREY, P.A. Attorneys for Plaintiff 6625 Miami Lakes Drive East, Suite 379 Miami Lakes, Florida 33014 Tel: 305.828.4744 Fax: 305.828.4718 Email: dj@jeffreylawfirm.com By: s/ Douglas J. Jeffrey, Esq. DOUGLAS J. JEFFREY Fla. Bar No. 149527

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SERVICE LIST Dario D. Vasquez v. CITY OF MIAMI BEACH, et al. Case No: 12-21024-CIV-MARTINEZ-MCALILEY

Jose Smith, City Attorney City of Miami Beach 1700 Convention Center Drive 4th Floor Legal Department Miami Beach, Florida 33139 Email: robertrosenwald@miamibeachfl.gov Telephone: (305) 673-7470 Facsimile: (305) 673-7002 Counsel for City, Gonzalez, Bower, and Noriega

Joshua M. Entin, Esq. ROSEN, SWITKES & ENTIN, P.L. 407 Lincoln Road, PH SE Miami Beach, FL 33139 Email: JEntin@rosenandswitkes.com Telephone: (305) 534-4757 Facsimile: (305) 538-5504 Counsel for Phillip Elmore

Jose A. Fuentes, Esq. Fuentes & Berrio, LLP 709 East Hillsboro Boulevard Deerfield Beach, Florida 33441 Email: jose@fuentesberrio.com Telephone: (954) 752-1110 Facsimile: (954) 794-1212 Co-Counsel for Plaintiff

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