Carlsbad Police Brutality Complaint

Case 3:15-cv-02007-DMS-BGS Document 6 Filed 10/02/15 Page 1 of 15
GERAGOS & GERAGOS
A PROFESSIONAL CORPORATION
LAWYERS
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HISTORIC ENGINE CO. NO. 28

644 South Figueroa Street
Los Angeles, California 90017-3411
Telephone (213) 625-3900
Facsimile (213) 232-3255
Geragos@Geragos.com
MARK J. GERAGOS SBN 108325

BEN J. MEISELAS
SBN 277412
Attorneys for Plaintiffs CINDY HAHN
AND BRANDON HAHN
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF CALIFORNIA
GERAGOS & GERAGOS, APC

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CINDY MICHELLE HAHN, individual;

BRANDON HAHN, an individual,
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Case No. 3:15-CV-02007-DMS-BGS

FIRST AMENDED COMPLAINT
FOR DAMAGES:
Plaintiffs,
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vs.
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1. VIOLATION OF CIVIL
RIGHTS (42 USC 1983);
2. VIOLATION OF CIVIL
RIGHTS - MONELL;
3. VIOLATION OF CIVIL CODE
52.1;
4. NEGLIGENCE;
5. BATTERY
6. LOSS OF CONSORTIUM
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CITY OF CARLSBAD; OFFICER J.

KNISLEY; OFFICER KENYATTE
VALENTINE; OFFICER KARCHES;
CORPORAL GALANOS; OFFICER
SEAPKER; and DOES 1 through 50,
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Defendants.
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DEMAND FOR JURY TRIAL
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FACTUAL BACKGROUND
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1.
Plaintiffs Cindy Hahn and her husband Brandon Hahn are compelled to
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bring this First Amended Complaint (FAC) because the Defendants, the City of
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Carlsbad and the Defendant Police Officers, argue that the allegations pled against
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them previously in the Original Complaint were uncertain and vague. This, despite
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the fact that Defendants have previously been confronted with video evidence of the
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Defendant Police Officers brutally beating and attacking the unarmed and defenseless
40 year old Ms. Hahn in front of her 11 year old and 7 year old children, as they were
leaving the birthday party of a friend. Since Defendants are apparently incapable of
recognizing their videotaped misconduct, Plaintiff provides additional specificity in
response to Defendants feigned ignorance:
2.
The facts and conduct giving rise to the FAC occurred on July 31, 2013.
3.
The senseless act of egregious police brutality and unlawful conduct by
Defendants was in retaliation for Ms. Hahn calling a civilian police hotline moments
before she was beat, to complain that a Carlsbad Police Officer, Officer Kenyatte

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Valentine appeared mentally unstable.

4.
Ms. Hahn, the daughter of a reserve police officer herself, asked Officer
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Valentine why he was standing in front of a vehicle and doing nothing while the
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vehicles alarm sounded.
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business. Ms. Hahn complained of this conduct to the nonemergency police hotline
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since she felt harassed and intimidated by Officer Valentine. Attached hereto as
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Exhibit A is true and correct copy of the iPhone snapshot of the phone call made
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by Ms. Hahn to the nonemergency Carlsbad Police hotline.
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5.
Officer Valentine responded: mind your f******
After Ms. Hahn complained, and she got in the car to drive home, Officer
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Valentine followed Ms. Hahn in his police vehicle and immediately pulled her over on
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the pretextual grounds that the driver of the vehicle had a seatbelt violation (the driver
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was not cited for any purpose). Officer Valentine had Ms. Hahn exit the vehicle and
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began attacking her in front of her children who were in the back seat of the car.
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While she was being beaten and pummeled, Ms. Hahn was crying out for help.
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6.
Shortly thereafter, another Carlsbad patrol vehicle arrived at a high and
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reckless rate of speed, traveling in reverse. Rather than help Ms. Hahn or extract
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Officer Valentine who was straddling on top of Ms. Hahn, Carlsbad Police Officer
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Knisley got out of the vehicle and escalated the situation by joining in the attack on
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Ms. Hahn. Officer Knisley began punching Ms. Hahn with a closed fist to the face
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7.
Ms. Hahn was transported to the emergency room where she was
diagnosed with head and brain contusions and subsequently diagnosed with a
concussion based on the Defendant Police Officers violence. Ms. Hahn suffers
permanent memory loss and brain trauma as well as other physical and emotional
injuries from the beating.
until she was limp on the floor. Ms. Hahns clothes were almost ripped off.
8.
To cover up their malicious and wanton conduct not realizing the brutal
attack on Ms. Hahn was caught on tape the Defendant City of Carlsbad and the
Defendant Police Officers fabricated police reports which led to Ms. Hahn being
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charged with felony violations of Penal Code Section 69 Felony Resisting Arrest,
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as well as Penal Code Section 243(c) (2) Felony Battery on a Peace Officer with
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Injury. Attached hereto as Exhibit B is a true and correct copy of the Felony
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Criminal Complaint.
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9.
The false and fraudulently prepared and submitted police reports with
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the support and assistance of the Sergeant of the Carlsbad Police Department portray
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Ms. Hahn as a dangerous individual engaging in criminal conduct in the presence of
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police officers fearing for their safety. The video of the incident flatly contradicted
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these accounts
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10.
As Ms. Hahn suffered through her physical and emotional injuries from
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the attack, her damages were compounded as she was compelled to endure a sordid
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ordeal for her freedom as the Defendant Police Officer attackers lied under oath in the
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criminal proceeding about what actually took place. The charges pending against Ms.
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Hahn exposed her to State prison and a strike conviction. The criminal case against
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Ms. Hahn lasted approximately 2 years.
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11.
All criminal counts against Ms. Hahn were dismissed when the District
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Attorneys Office was confronted with video evidence showing that the Police
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Officers had lied in their reports and testimony. The video shows the police brutally
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beating Ms. Hahn. The felony criminal case against Ms. Hahn was dismissed on July
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19, 2015.
12.
Pursuant to California Government Code Section 945.3, Ms. Hahns civil
claims for damages against the Defendants were stayed and tolled during the period in
which she was maliciously prosecuted by Defendants. This tolling period was from
July 31, 2013 through July 19, 2015.
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13.
The video of the brutal assault on Ms. Hahn can be viewed at the
following link: https://www.youtube.com/watch?v=yLeGnJzRO5U

THE PARTIES
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14.
Plaintiff Cindy Hahn, at all relevant times, was a resident of Los Angeles
County, California.
15.
Plaintiff Brandon Hahn, at all relevant times, was a resident of Los
Angeles County, California.

16.
At all times herein mentioned, the City of Carlsbad (the City), was a
governmental entity organized and existing under the laws of the State of California.
17.
At all times herein mentioned, J. Knisley (Knisley) was a law
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enforcement officer employed by the City of Carlsbad Police Department and acting
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in the course and scope of his employment and acting under the color of law.
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At all times herein mentioned, Kenyatte Valentine (Valentine) was a
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law enforcement officer employed by the City of Carlsbad Police Department and
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acting in the course and scope of his employment and acting under the color of law.
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At all times herein mentioned, Officer Karches (Karches) was a law
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At all times herein mentioned, Corporal Galanos (Galanos) was a law
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At all times herein mentioned, Officer Seapker (Seapker) was a law
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22.
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named herein as DOES 1 through 50, inclusive, and therefore sues said Defendants by
such fictitious names. Plaintiff will seek leave of court to amend this Complaint to
allege the true names and capacities of said Defendants when the same are
ascertained. Plaintiff is informed and believes and thereon alleges that each of the
aforesaid fictitiously named Defendants is responsible in some manner for the
happenings and occurrences hereinafter alleged, and the Plaintiffs damages and
injuries as herein alleged were caused by the conduct of said Defendants.

23.

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Plaintiff is unaware of the true names and capacities of the Defendants
Specifically, Plaintiff alleges that Does 1 through 50 were law
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enforcement officers acting under color of law. It is further alleged that Does 1
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through 50 were acting in the course and scope of their employment at all relevant
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times.
JURISDICTION AND VENUE
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24.
This Court has jurisdiction over the entire action by virtue of the fact that
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this is a civil action wherein the matter in controversy, exclusive of interest and costs,
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exceeds the jurisdictional minimum of the Court. Jurisdiction is conferred upon this
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Court by Section 1983, Title 42, United States Code. Concurrent jurisdiction was
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granted to this court under Williams vs. Horvath (1976) 16 Cal.3d 834, 837. Also, this
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Court has jurisdiction to award damages pursuant to Article VI, Section 10 of the
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California Constitution.
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25.
On September 10, 2015, Defendants removed this matter to the United
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States District Court, Southern District of California on the grounds of Federal
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Question jurisdiction.
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26.
On January 13, 2014 Plaintiffs Cindy Hahn and Brandon Hahn timely
submitted claims under California Government Code Section 910 within 6 months
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from the date of incident of July 31, 2013.1

27.

Pursuant to California Government Code Section 945.3, the claims by
Ms. Hahn were tolled during the period she was being maliciously criminally
prosecuted which concluded on July 19, 2015 when the District Attorney dismissed all
criminal counts.
28.
The State law claims of Brandon Hahn for loss of consortium have not
expired based on, among the reasons, the fact that the injury sustained was continuing
through the malicious prosecution period at which point Brandon Hahns claim
ripened on July 19, 2015. Further, Defendants engaged in a fraudulent scheme and
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practice from the date of the incident through the date of dismissal of the felony
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criminal charges, by submitting false police reports and giving perjurious testimony in
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connection with that act to portray Ms. Hahn as a criminal to the community.
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FIRST CAUSE OF ACTION
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Violation of Civil Rights
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(42 U.S.C. 1983)
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Plaintiff against Defendants Knisley, Valentine, Karches, Galanos,
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Seapker and Does 1 through 5

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Plaintiff realleges and incorporates by reference each and every
allegation contained in the preceding paragraphs as if fully set forth herein.

30.
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At all times material to this Complaint, Defendants were acting under
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color of the law in violating Plaintiffs constitutional rights as herein alleged under the
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Fourth Amendment to the Constitution of the United States. The Fourth Amendment
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is made applicable to the States pursuant to 42 U.S.C. 1983.
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Plaintiffs minor children John Doe (11 years old at time of incident) and Jane Doe (7 years
old) similarly submitted Government Tort Claims pursuant to Section 910 on January 13,
2014. The claims relate to negligent infliction of emotional distress based on witnessing the
Defendant Police Officers attack their mother in their presence. As minors, John and Jane
Does claims have been tolled on account of their age. John and Jane Doe intend to join this
action by and through their proposed guardian ad litem Cindy Hahn subject to the Courts
approval.
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Defendants Knisley and Valentine deprived Plaintiff of rights, privileges,
and immunities secured to her by the Fourth Amendment to the Constitution of the
United States by, inter alia, subjecting Plaintiff to excessive, unreasonable and
unnecessary force when Plaintiff was struck in the face with a closed fist on multiple
occasions and restrained by way of a knee to Plaintiffs head and neck.
31.
32.
Defendants Knisley, Valentine, Karches, Galanos, Seapker, and Does 1-5
deprived Plaintiff of rights, privileges, and immunities secured to her by the Fourth
Amendment to the Constitution of the United States by, inter alia, subjecting Plaintiff
to an unlawful search and seizure of her person, causing her to be arrested for a
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violation of Penal Code 243(c)(1) and Penal Code 148(a)(1), conspiring to deprive
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Plaintiff of her constitutionally protected rights, submitting reports with material
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omissions, providing falsehoods to secure an arrest and the filing of criminal charges
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and continued prosecution which was dismissed.
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33.
The Defendants and each of them directly participated and/or aided and
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abetted in the assault, battery, and excessive force against Ms. Hahn in the presence of
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her children and/or engaged in efforts to cover up said conduct by providing false
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testimony, preparing or authorizing or approving false police reports, and/or aiding
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and abetting in the preparation, authorization or approval of false police reports to
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maliciously prosecute Ms. Hahn for felony criminal charges. Each of the named
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Defendants is a co-conspirator and/or and aider and abettor in the conduct designed to
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physically and emotionally harm Ms. Hahn through the brutal physical assault caught
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on videotape and to cover up the conduct of Officer Valentine and Officer Knisley
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through the common scheme to submit false reports leading to felony charges against
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Ms. Hahn which were ultimately dismissed.
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Further, Corporal Galanos asserted his presence during the assault on Ms.
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Hahn to block and prevent those who were witnessing the assault to help and render
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aid. Corporal Galanos attempted to block and conceal the other police officers as they
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brutally beat Ms. Hahn.

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which was made without probable cause and also a seizure which was fraught with
false information to secure the seizure, as alleged herein.

36.
Plaintiff has a constitutional right to be free from the use of excessive
force by law enforcement officers. The conduct and actions of Officers Knisley and
Valentine resulted in Plaintiff sustaining injuries to her face, abdomen, chest and
memory, all of which required medical attention. No use of force against her person
was necessary or reasonable. Plaintiff has a constitutional right to be free from
malicious prosecution based on the submission of false reports.
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Plaintiff has a constitutional right to be free from an unreasonable seizure
35.
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37.
Due to the conduct of Defendants, and each of them, Plaintiff has
suffered general damages and special damages, all in a sum to be proved at trial.
38.
Due to the conduct of Defendants, and each of them, Plaintiff has been
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required to incur attorneys' fees and will continue to incur attorneys' fees, all to
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Plaintiffs damage in a sum to be proved at trial and recoverable pursuant to 42 U.S.C.
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1988.
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39.
The individual defendants acted with a conscious disregard of Plaintiffs
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rights conferred upon her by Section 1983, Title 42 of the United States Code, the
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Fourth Amendment to the United States Constitution and California Civil Code
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Section 3333, by intentional causing her injury and arresting her without probably
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cause. Defendants, and each of them, had an interest in seeing Plaintiff charged with
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criminal conduct to detract from Defendants Knisley and Valentines excessive and
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unnecessary force. Such conduct constitutes malice, oppression and/or fraud under
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California Civil Code Section 3294, entitling Plaintiff to punitive damages against the
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individual Defendants in an amount suitable to punish and set an example of said
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Defendants.
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SECOND CAUSE OF ACTION
Violation of Civil Rights- Monell
Plaintiff against the City of Carlsbad and Does 6 through 15
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Plaintiff realleges and incorporates by reference the allegations contained
in the preceding paragraphs of this complaint, as though fully set forth herein.
41.
Defendants, the City of Carlsbad and Does 6 through 15, knowingly, with
gross negligence, and in deliberate indifference to the Constitutional rights of citizens,
maintain and permit an official policy and custom of permitting the occurrence of the
types of wrongs set forth hereinabove and hereafter.
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42.
Plaintiff has a constitutional interest pursuant to the Fourth and
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Fourteenth Amendments to the United States Constitution to be free from an arrest
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without probable cause and incarceration and criminal charges based upon the Citys
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policies of allowing arrests without probable cause. These policies and customs
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include, but are not limited to, the deliberately indifferent training of its law
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enforcement officers in making lawful arrests.
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include the express and/or tacit encouragement of arrests without probable cause, the
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ratification of police misconduct, and the failure to conduct adequate investigations of
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police misconduct such that future violations do not occur.
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43.
These policies and customs also
Specifically, Plaintiff alleges that the City of Carlsbad has an actual
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custom or policy of promoting the conduct by the Defendants in this action against
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Ms. Hahn.
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individuals who complain against Carlsbad Police Officers. Here, Ms. Hahn called
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the official nonemergency hotline for the Carlsbad Police Department to complain
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about an officer cursing at her and her children. She was thereafter followed by the
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same Police Officer in her car, pulled over for a bogus traffic violation (for which
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there were never any citations issued) and then physically assaulted. The way the
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assault of Ms. Hahn was carried out evidences a systematic custom and practice for
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engaging in this type of unlawful excessive force conduct against individuals by the
Specifically, the custom and practice is one of retaliation against
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Department. Specifically, the video depicts one Police Officer standing in a guard
position as if in formation to block off the public and attempt to conceal the
beating of Ms. Hahn. The assault on Ms. Hahn does not appear random and isolated
among the Carlsbad Police Department as the assaulters are carrying out the assault in
a manner that utilizes official formations and positions to conceal the beating.
Further, evidence of a broader custom and practice of depriving individuals of their
constitutional rights is demonstrated through the fact that there are multiple Defendant
Police Officers who had a part in this assault, either directly through the actual battery
and assault of Ms. Hahn, through the failure to take any action and to attempt to
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conceal the beating as it was taking place, and through the processing and/or
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approving of false police reports which fabricated facts that led to felony charges
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against Ms. Hahn. The false police reports were approved at the Sergeant level with
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reckless disregard for the rights of Ms. Hahn. Upon information and belief, the
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systemic deconstruction of the truth to cover up for Carlsbad Police Officers who
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engage in excessive force is systemic, is engrained in the culture of the Carlsbad
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Police Department, and has been carried out in numerous other instances other than
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this action.
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44.
Upon information and belief, the Defendant Officers in this action have
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been involved in numerous other acts of misconduct and excessive force in other
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instances, in which the Carlsbad Police Department has taken similar efforts to cover-
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up and to frame the victim by ginning up false felony charges.
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45.
Upon information and belief, the custom and practice of permitting and
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tolerating unlawful excessive force against the public as in the case of Ms. Hahn is
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rampant within the Carlsbad Police Department, is learned and taught in officer
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training academy, and the conduct is covered up at a systematic and systematic level
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at the highest levels of the Carlsbad Police Department by instructing Officers to
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prepare false police reports that lead to criminal charges against innocent victims such
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as Ms. Hahn.
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and policies were the moving force behind the violations of Plaintiffs rights. Based
upon the principles set forth in Monell v. New York County Dept. of Social Services,
the County and Does 6 through 15 are liable for all of the injuries sustained by
Plaintiff as set forth above.

47.
In acting as alleged herein, the County and Does 6 through 15, and each
of them, caused Plaintiff general and special damages, in an amount to be determined
at the time of trial.

Plaintiff is informed and believes, and thereon alleges, that the customs
46.
48.
Due to the conduct of the County and Does 6 through 15, and each of
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them, Plaintiff has been required to incur attorneys' fees and will continue to incur
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attorneys' fees, all to Plaintiffs damage in a sum to be proved at trial and recoverable
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pursuant to Title 42, Section 1988 of the United States Code.
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THIRD CAUSE OF ACTION
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Violation of California Civil Code 52.1 et. seq.
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Plaintiff against all Defendants
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49.
50.
Defendants were acting within the scope of their duties as City of
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Carlsbad Police Officers. Pursuant to California Government Code Section 815.2,
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the City is liable for the acts, omissions, and conduct of its employees, including
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Defendants Knisley, Valentine, Karches, Galanos, Seapker, and Does 1 through 20
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herein, whose tortious conduct, was the cause in the damages and injuries to Plaintiff.
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51.
The conduct of Defendants constituted interference by threats,
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intimidation, or coercion, or attempted interference, with the exercise of enjoyment by
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Plaintiffs rights secured by the Constitution of laws of the United States, or secured by
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the Constitution or laws of the State of California, including interference with their
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right to be secure in her person and free from the use of excessive force under the
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Fourth and Fourteenth Amendments and California Constitution, Article 1, Section 13

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as well as California Civil Code Section 43, and the right of protection from bodily
restraint and harm.

As a direct cause of Defendants conduct, Plaintiffs rights pursuant to
California Civil Code Section 52.1 were violated, causing injuries and damages in an
amount to be proved at the time of trial.
52.
53.
Due to the conduct of Defendants, and each of them, Plaintiff has been
required to incur attorneys' fees and will continue to incur attorneys' fees. Pursuant to
California Civil Code Section 52.1, Plaintiff is entitled to recover said fees.
FOURTH CAUSE OF ACTION
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NEGLIGENCE
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Plaintiff Against all Defendants
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54.
55.
Defendants Knisley, Valentine, Karches, Galanos, and Seapker had a
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duty of care not to use excessive force on Ms. Hahn to effectuate an arrest.
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Defendants Knisley, Valentine, Karches, Galanos, and Seapker breached these duties
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when they caused Ms. Hahn to be struck in the face multiple times and restrained by
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way of a knee to Plaintiffs head and neck.
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56.
As a proximate and direct cause of Defendants Knisley, Valentine,
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Karches, Galanos, and Seapkers breaches, Ms. Hahn was arrested, incarcerated, and
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charged with criminal counts.
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57.
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the time of trial.
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58.
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Ms. Hahn sustained injuries and damages in an amount to be proven at
The City is liable for the acts, omissions and conduct of its employees
pursuant to California Government Code Section 815.2.
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FIFTH CAUSE OF ACTION
BATTERY
Plaintiff Against Defendants Valentine, Knisley and the City of Carlsbad
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in the preceding paragraphs of this Complaint, as though fully set forth herein.
60.
Defendant Valentine and Knisleys use of force on Plaintiff, and
specifically striking Plaintiff in the face with a closed fist, constituted a battery on
Plaintiff as the conduct was unwanted and unnecessary.
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59.
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61.
The City is liable for the acts, omissions and conduct of its employees
pursuant to California Government Code 815.2.

62.
As a direct cause of Defendant Knisleys conduct, Plaintiff sustained
general and special damages, in an amount to be proved at the time of trial.

63.
Defendant Knisleys conduct was done so with conscious disregard of
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Plaintiffs rights and safety, constituting malice, oppression and/or fraud under
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California Civil Code Section 3294, entitling Plaintiff to punitive damages against
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Defendant Knisley in an amount suitable to punish and set an example of said
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Defendant.
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SIXTH CAUSE OF ACTION
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LOSS OF CONSORTIUM
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Brandon Hahn Against All Defendants
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64.
Plaintiffs incorporate all proceeding paragraphs herein by reference.
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65.
As a direct consequence of the injuries sustained by Ms. Hahn because of
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the conduct of the police officers described herein, Mr. Hahn has been deprived of the
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normal companionship, company, affection, regard, assistance, comfort, relations, and
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emotional stability of his wife Ms. Hahn.
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66.
These physical and emotional consequences of the injuries have
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negatively impacted the quality of and caused undue hardship to the marriage
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relationship. Mr. Hahn continues to be denied the full enjoyment of his marital
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relationship.
67.
The date of injury for Mr. Hahn was continuing from the date his wife
was attacked through the malicious prosecution period which ended July 19, 2015.
The injuries to Mr. Hahn were compounded by the submission of fraudulent reports
by the Defendant Police Officers attempting to portray his wife as a violent criminal.
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68.
Mr. Hahn suffered special and general damages in an amount to be
proven at trial
PRAYER FOR RELIEF

WHEREFORE, Plaintiffs prays for judgment as follows:
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1.
For general damages in an amount to be determined by proof at trial;
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2.
For special damages in an amount to be determined by proof at trial;
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3.
For punitive and exemplary damages against the individual defendants
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where applicable;
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4.
For costs of suit;
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5.
For reasonable attorneys fees and costs as provided by statute; and
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6.
For such other and further relief as the Court deems just and proper.
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DATED: October 2, 2015
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By: /s/_MARK J. GERAGOS_______

MARK J. GERAGOS
Attorneys for Plaintiffs
CINDY HAHN and BRANDON
HAHN
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DEMAND FOR JURY TRIAL
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Plaintiffs Cindy Hahn and Brandon Hahn hereby demand a jury trial.
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DATED: October 2, 2015
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By: /s/_MARK J. GERAGOS_______

MARK J. GERAGOS
Attorneys for Plaintiffs
CINDY HAHN and BRANDON
HAHN
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Carlsbad Police Brutality Complaint

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Case 3:15-cv-02007-DMS-BGS Document 6 Filed 10/02/15 Page 1 of 15

GERAGOS & GERAGOS

HISTORIC ENGINE CO. NO. 28

MARK J. GERAGOS SBN 108325

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF CALIFORNIA

GERAGOS & GERAGOS, APC

HISTORIC ENGINE CO. NO. 28

CINDY MICHELLE HAHN, individual;

Case No. 3:15-CV-02007-DMS-BGS

CITY OF CARLSBAD; OFFICER J.

DEMAND FOR JURY TRIAL

FIRST AMENDED COMPLAINT

Case 3:15-cv-02007-DMS-BGS Document 6 Filed 10/02/15 Page 2 of 15

recognizing their videotaped misconduct, Plaintiff provides additional specificity in

response to Defendants feigned ignorance:

The senseless act of egregious police brutality and unlawful conduct by

GERAGOS & GERAGOS, APC

HISTORIC ENGINE CO. NO. 28

Valentine appeared mentally unstable.

vehicles alarm sounded.

by Ms. Hahn to the nonemergency Carlsbad Police hotline.

Officer Valentine responded: mind your f******

Shortly thereafter, another Carlsbad patrol vehicle arrived at a high and

FIRST AMENDED COMPLAINT

Case 3:15-cv-02007-DMS-BGS Document 6 Filed 10/02/15 Page 3 of 15

HISTORIC ENGINE CO. NO. 28

injuries from the beating.

GERAGOS & GERAGOS, APC

Ms. Hahn as a dangerous individual engaging in criminal conduct in the presence of

Ms. Hahn lasted approximately 2 years.

FIRST AMENDED COMPLAINT

Case 3:15-cv-02007-DMS-BGS Document 6 Filed 10/02/15 Page 4 of 15

Pursuant to California Government Code Section 945.3, Ms. Hahns civil

July 31, 2013 through July 19, 2015.

following link: https://www.youtube.com/watch?v=yLeGnJzRO5U

GERAGOS & GERAGOS, APC

HISTORIC ENGINE CO. NO. 28

Plaintiff Brandon Hahn, at all relevant times, was a resident of Los

Angeles County, California.

At all times herein mentioned, J. Knisley (Knisley) was a law

At all times herein mentioned, Kenyatte Valentine (Valentine) was a

At all times herein mentioned, Officer Karches (Karches) was a law

At all times herein mentioned, Corporal Galanos (Galanos) was a law

At all times herein mentioned, Officer Seapker (Seapker) was a law

FIRST AMENDED COMPLAINT

Case 3:15-cv-02007-DMS-BGS Document 6 Filed 10/02/15 Page 5 of 15

aforesaid fictitiously named Defendants is responsible in some manner for the

injuries as herein alleged were caused by the conduct of said Defendants.

HISTORIC ENGINE CO. NO. 28

Plaintiff is unaware of the true names and capacities of the Defendants

Specifically, Plaintiff alleges that Does 1 through 50 were law

On September 10, 2015, Defendants removed this matter to the United

States District Court, Southern District of California on the grounds of Federal

FIRST AMENDED COMPLAINT

Case 3:15-cv-02007-DMS-BGS Document 6 Filed 10/02/15 Page 6 of 15

from the date of incident of July 31, 2013.1

GERAGOS & GERAGOS, APC

HISTORIC ENGINE CO. NO. 28

Pursuant to California Government Code Section 945.3, the claims by

FIRST CAUSE OF ACTION

Violation of Civil Rights

(42 U.S.C. 1983)

Plaintiff against Defendants Knisley, Valentine, Karches, Galanos,