db STATE OF MICHIGAN IN THE CIRCUIT COURT FOR THE COUNTY OF WAYNE JOHN DOE Plaintiff, Case Now: cK vs. Hon: DETECTIVE MCMAHON, 16-004457- DETECTIVE MICHAEL STOUT, FILED IN MY OFFI CHIEF OF POLICE ANNE MOISE, WAYNE COUNTY CLE THE CITY OF HAMTRAMCK, AND THE CITY OF HIGHLAND PARK. Defendants. 4/8/2016 8:15:58 CATHY M. GARRE BISBIKIS LAW, PLLC By: Marco Bisbikis (P79478) Attomeys for Plaintiff 150 N. Main Street Plymouth, MI 48150 Phone: (734) 459-4040 Fax: (734) 454-4814 Email: marcobisbikis@gmail.com VERIFIED COMPLAINT A civil action between some but not all of these parties arising out of the transaction or occurrence alleged in the complaint has been previously filed in the US District Court for the Eastern District of Michigan, where it was given docket no. 16-10747 and was assigned to Judge ‘Tamow. The action is no longer pending. ‘Now comes the Plaintiff John Doe, by his attorney, Marco Bisbikis, and complains to this Honorable Court as follows:Plaintiff is a resident of the County of Wayne, State of Michigan. Defendant Detective McMahon is an individual and is a resident of the State of Michigan; he is currently employed as a detective of the Highland Park Police Department Defendant Detective Stout is an individual and is a resident of the State of Michigan; he is currently employed as a detective of the Hamtramck Police Department. Defendant Chief of Police Anne Moise is an individual and is a resident of the State of Michigan; She is currently employed as the Chief of Police of the Hamtramck Police Department. Defendant City of Hamtramck is a municipal corporation, organized and existing under the laws of the State of Michigan, with its principal office located at 3401 Evaline; all current and former employees identified herein as defendants are being named in their individual and official capacities. Defendant City of Highland Park is a municipal corporation, organized and existing under the laws of the State of Michigan, with its principal office located at 12050 Woodward; all current and former employees identified herein as defendants are being named in their individual and official capacities. Plaintiff is a registered federal confidential informant with the U.S. Department of Justice and has been a part of several undercover operations, for purposes of security Plaintiff has filed this complaint as John Doe.10. Ww 12, 139 14. That in the summer of 2015, Detective McMahon promised Plaintiff a 5% compensation of all monies seized if Plaintiff would work as a confidential informant. ‘That in the summer of 2015, Detective Stout promised Plaintiff a 5% compensation of all monies seized if Plaintiff would work as a confidential informant. ‘That in the summer of 2015, Police Chief Anne Moise confirmed Detective Stout's promise to Plaintiff for a 5% compensation of all monies seized and also stated that monies would be paid from the “CI Fund” if Plaintiff would work as a confidential informant. ‘That Detectives McMahon and Stout, as well as Chief of Police Anne Moise, continued to make representations and promises to Plaintiff throughout his work as a Confidential Informant. ‘That these representations were made to induce Plaintiff to keep working as a Confidential Informant. ‘That Plaintiff continued to do work based on these representations, and would not have continued to work but for the representations made. ‘That in the first week of July 2015 Plaintiff began assisting police in their investigation of a dealership on 8 mile and Ryan in Detroit, ‘That Plaintiff was instructed by Detectives Stout and McMahon to pose as purchaser of fake insurance and that Plaintiff did so twice.16. 7. 19, 20. 21 24. That in the second week of July 2015, police raided the dealership and seized sixty-three (63) vehicles and $6000-$8000 cash, ‘That Plaintiff witnessed an officer place the $6000-$8000 into his pocket. ‘That the sixty-three (63) vehicles were redeemed for $1000 each for a total of $63,000. ‘That Plaintiff was not compensated for his services for this raid. That the information regarding the seizure was communicated to Plaintiff as the events were unfolding. ‘That in August of 2015 Plaintiff assisted police in their investigation of “Sam's Tire” in Hamtramck. That Plaintiff was told by Detectives Stout and McMahon that they wanted to rid the community of “these fucking A-rabs.” ‘That Detectives Stout and McMahon stated “We want to get rid of Sam and everybody like him.” ‘That Plaintiff was instructed to pose as a purchaser of marijuana and guns and that Plaintiff did as instructed. That the owners of Sam’s Tire refused to sell marijuana to Plaintiff and that Plaintiff was subsequently instructed by Detectives Stout and McMahon to ingratiate himself to the owners of Sam's Tire.26. 21. 30. 31 32, 34, That the owners of Sam’s Tire told Plaintiff that they had tires that needed to be disposed of and that they would be able to sell Plaintiff drugs and guns if he would do so. ‘That Plaintiff was instructed by Detectives Stout and McMahon to dump the tires for a fee and instructed Plaintiff to tell the owners of Sam's Tire that they would dump the tires for one (1) dollar per tire ‘That Plaintiff began to dump tires using a U-Haul Truck and made many trips to dump the tires and did not finish that day. ‘That Detectives Stout and McMahon acted as lookouts and escorts for this process and were armed and watching the Plaintiff. ‘That the $150 deposit for the U-Haul truck was paid by Detective McMahon. ‘That Plaintiff returned a subsequent day in an unmarked police van provided by Detectives Stout and MeMahon to continue to dump tires. ‘That Detective Stout told Plaintiff that “You must be out of your nigger mind if you think we are dumping those tires in Hamtramck. ‘That Detect -s Stout and MeMahon had Plaintiff follow them to Detroit and had ‘them dump the tires there. ‘That Detectives Stout and McMahon acted as lookouts and escorts for this process and were armed and watching Plaintiff.36. 37. 38. 40. AL 42. 44. 45. 46. That during the course of his assistance in the investigation, Plaintiff conversed with Detectives Stout and McMahon and that racial and ethnic slurs were used in every conversation, That Detective Stout used the words “sand niggers” at least twice. ‘That Detective Stout used the words “fucking A-rabs” at least ten times in one sitting, and twenty timeS total. ‘That Detective Stout used the words “towel heads” four to five times. ‘That Detective Stout used the words “camel jockeys” twice. ‘That Detective Stout used the word “nigger” at least twice. ‘That Detective McMahon used the words “camel jockeys” once. ‘That Detective McMahon used the word “nigger” once. ‘That Detective McMahon used the words “fucking A-rabs” ten to fifteen times. That Pl ‘ff approached Detectives Stout and McMahon and objected to the use of racial slurs and abusive treatment ‘That in response to Plaintiff's objections, Detective McMahon told Plaintiff that “a little ‘nigger’ never hurt anybody.” That in August of 2015 the police raided the house of one of the owners of Sam's Tire and seized $30,000.41. 48. 49, 50. 51. 33. 34, 5S. 56. ‘That the information regarding the seizure was communicated to Plaintiff as the events were unfolding, ‘That Plaintiff was not compensated for his services for this raid. That in August of 2015 Plaintiff assisted police in their investigation of an insurance agent in Dearborn ‘That through information provided by Plaintiff, the police raided the office of the agent in August 2015 and seized $7000-$8000, ‘That Plaintiff was not compensated for his services for this raid. ‘That Plaintiff contacted Chief of Police Anne Moise to ask about compensation and to report the racial and ethnic slurs. That Chief of Police Anne Moise told Plaintiff that she would “take care of it.” That Plaintiff told Vince Wade of the FBI about the racial and ethnic slurs. ‘That shortly after these reports, Detectives McMahon and Stout approached Plaintiff at his residence in an unmarked police truck. That Detectives McMahon and Stout were brandishing their weapons and told Plaintiff, “we don’t give a fuck if you call our bosses, we aren’t scared of any FBI, and now you are really going to wait for your money.” COUNT 1 - BREACH OF CONTRACT AS TO CITY OF HIGHLAND PARK AND.37. 58. 59. 60. 61 62. CITY OF HAMTRAMCK Paragraphs One through Fifty-Six are incorporated herein by reference. Defendants City of Highland Park and City of Hamtramck via their authorized officials McMahon and Stout, respectively, did enter into an agreement with Plaintiff, whereby Plaintiff furnished confidential informant services in consideration for the payment of a 5% commission on all proceeds realized via property seizures and/or forfeitures in which Plaintiff acted as a confidential informant or “cooperating individual”. Despite said agreement, which was contractual in nature, and in breach thereof, said cities neglected, failed and/or refused to compensate Plaintiff despite the fact that his services resulted in the realization of at least $109,000.00 in proceeds. Asa direct and proximate result of said breach, Plaintiff has been damaged by the failure of the Defendant cities to pay commissions as agreed upon. COUNT Il - PROMISSORY ESTOPPEL Paragraphs One through Sixty are incorporated herein by reference. The agents of the Defendant cities of Hamtramck and Highland Park made promises to Plaintiff that was clear and definite to pay a 5% commission for proceeds of property seizures and/or forfeitures resulting from Plaintiff's efforts as a confidential informant.64, 65. 66. 67. 68. 69. 70, n n2. ‘When the promise was made, said Defendant cities knew or should have expected that this promise would induce the Plaintiff to take action. ‘That Plaintiff did take some action in reliance of the promise, including the conduct pled above. ‘That Plai Tf was damaged as a result of his reliance. COUNT Hl - QUANTUM MERUIT Paragraphs One through Sixty-Six are incorporated herein by reference. Defendants City of Highland Park and City of Hamtramck received benefits as a direct result of Plaintiff's conduct as a confidential informant, An inequity results to Plaintiff because of the retention of the benefit by said municipal Defendants. ‘The law implies a contract herein to prevent unjust or inequitable enrichment at Plaintiff's expense. COUNTY CONSTRUCTIVE FRAUD Paragraph One through Seventy are incorporated herein by reference. ‘The Defendants City of Hamtramck and City of Highland Park have received windfall unmerited benefits by effectuating property seizures, forfeiture proceedings, and realizing well over $100,000.0¢ proceeds without remitting any compensation to Plaintiff, despite their promises.74, 75, 76. 71. 78. 79. 80. A relationship of trust and confidence existed between the police department of said municipalities, on one hand, and Plaintiff, on the second hand. As a direct result of such constructive fraud Plaintiff has been damaged. COUNT V - MISREPRESENTATION/FRAUD Paragraphs One through Seventy-Four are incorporated herein by reference, Material misrepresentations were made to Plaintiff regarding the intent of the Defendants City of Hamtramek and City of Highland Park to pay for confidential informant services rendered. Said representations include statements made by Detective McMahon as set forth at Paragraph Eight herein, Detective Stout at Paragraph Nine herein, and Chief of Police Anne Moise at Paragraph Ten, When said police officials made such representations, each knew the representation was false, or was made recklessly, without any knowledge by such Defendants of the truth of each such representation and as a positive assertion. ‘The Defendants made such assertions on behalf of the respective municipal Defendants with the intention that Plaintiff act on it. ‘The Plaintiff relied upon the representations and acted on those statements by initiating and continuing to provide confidential informant services on behalf of the municipal defendants.81. 82. 83. 84. 85, 86. 87. 88. 89. Plaintiff suffered damages as a result of having acted in reliance on the representations, including loss of benefit of the bargain, reliance damages, embarrassment and humiliation, emotional distress, and exemplary damages. COUNT VI - INNOCENT MISREPRESE! TION Paragraphs One through Eighty-One are incorporated herein by reference ‘That the representations of Detective McMahon, Detective Stout, and Chief of Police Anne Moise pled at Paragraphs Eight through Ten, above, were made in conjunction with the making of contractual agreements with respect to Plaintiff, on one hand, and the Defendant municipalities, on the second hand. ‘That said representations of the aforesaid police officials were false. ‘The Plaintiff acted and relied on such representations in furnishing confidential informant services. Plaintiff sustained damages as a result of such representations. Plaintiff's loss benefitted the Defendants. COUNT VI - EQUITABLE ACCOUNTING Paragraphs One through Eighty-Seven are incorporated herein by reference. Plaintiff, by virtue of his commission compensation agreement with Defendants, stood in a relationship in which he relied that Defendants would faithfully account and safeguard all property seized due to his efforts and remit his commission percentage in a fair and prompt manner.90. During the confidential information relationship, police officials involved in seizures were believed to have converted seized property to their personal use and offered seized property to others without due process and did not safeguard seized properties in accordance with prudent procedures, including: (A) Chief Moise having and keeping a box in her office containing tens of thousands of dollars: (B) an officer during the 8 Mile - Ryan raid shoving thousands of dollars into his pocket; (C) police personnel converting televisions for their own personal use; (D) offering seized property to non-police personnel without due process. 91. Plaintiff'is apprehensive that seized property is not being properly recorded and stored and disclosed in an honest manner, and therefore requests that the Defendants provide an accounting for all property seized traceable to Plaintiff's efforts as a confidential informant so his commission may be calculated properly and remitted to him, COUNT VIII - VIOLATION OF FEDERAL CIVIL RIGHTS ACT OF 1871 (42 USC 1983) 92, Paragraphs One through Ninety-One are incorporated herein by reference. 93. That Defendants, acting under color of state law, intentionally deprived Plaintiff:94. (A) of his rights guaranteed under the Equal Protection Clause of the 14th Amendment by committing the acts of discrimination on account of color and race by virtue of conduct pled supra herein; (B) of his rights guaranteed under the Due Process Clause of the 14th Amendment by failing to initiate appropriate remedial measures, but acting with deliberate indifference after learning of ongoing acts of discrimination, abuse, and derogatory name calling against Plaintiff including retaliation; (©) of his liberty interest under the Due Process Clause to be free of harassment and retaliatory conduct due to his exercise of his constitutional rights and his race/color; ‘Asa direct and proximate result of such violations, Plaintiff has sustained all injury and damage pled supra herein. 95. (A) Defendants’ conduct herein was motivated by an evil intent and involves reckless or callous indifference to the rights of others, thus entitling Plaintiff herein to an award of punitive damages. ‘That Defendants engaged in activity that was arbitrary and conscience shocking (A) Defendants impelled perpetration of criminal activity; tire dumping, trespass, and the defrauding of Plaintiff. (i) that Defendants were still acting under color of state law despite their criminal activity;(ii) that Defendants exercised power possessed by virtue of state law and ible only because they were clothed with the authority of state (iii) That such actions may result in liability even if the defendants abused the position given to them by the state. (B) That Defendants engaged in the targeting of protected individuals with arbitrary and capricious investigations; (C) That Defendants exposed the Plaintiff to a hostile environment through the use of ethnic slurs that were profane, including slurs against Muslims, African- Americans, Arabs, and Middle Eastern peoples. 96. That Defendants City of Hamtramck and City of Highland Park failed to train its employees, and the failure to train amounted to deliberate indifference and an ‘obvious need for such training, and the failure to train resulted in the employees making wrong decisions. 97. That as a direct result of such deliberate indifference and misconduct, Plaintiff sustained all injury and damages pled, supra herein COUNT IX - VIOLATION OF ELLIOT-LARSEN CIVIL RIGHTS ACT 98. Paragraphs One through Ninety-Six are incorporated herein by reference. 99. _Plaintiff'as an African-American, is a protected individual under MCR 37.2102 of the Elliott-Larsen Civil Rights Act (“ELCRA”) due to his ethnicity/race:100, 101. 102 national origin and associati Plaintiff is also protected in his association with Muslims; his stepmother and sisters are in fact Muslim ‘That Defendant City of Hamtramck did, as a provider of a public service under MCL 37.2202, violate Plaintiff's rights thereunder because of religion, race, color and/or national origin and as a provider of public services. denied Plaintiff the full and equal enjoyment of public services because of religion, race, color, and/or 1n with such protected groups in the following ways: (A) deliberate indifference via Defendant Chief of Police Anne Moise, who due to unlawful bias failed to adequately investigate Plaintiff"s claims of discrimination and derogatory name calling; (B) unwelcome harassment via Defendant Detective Stout who made adverse references to Plaintiff's Aftican-American identity and treated him in a demeaning and abusive manner during his work with Detective Stout as a confidential informant; (a) unwelcome retaliatory harassment via Detective Stout after Plaintiff's complaint to Chief of Police Anne Moise of racial slurs and abusive ‘treatment; (b) unwelcome retaliatory harassment via Detective Stout after Plaintiff's complaint to Chief of Police Anne Moise that he was not being paid; ‘That Defendant City of Highland Park did, as a provider of a public service under MCL 37.2202, violate Plaintiff's rights thereunder because of religion, race, color103 104, 105. and/or national origin and as a provider of public services, denied Plaintiff the full and equal enjoyment of public services because of religion, race, color, and/or national origin and association with such protected groups in the following ways: (A) unwelcome harassment via Defendant Detective McMahon who made adverse references to Plaintiff's African-American identity and treated him in a demeaning and abusive manner during his work with Detective McMahon as a confidential informant; (a) unwelcome retaliatory harassment via Detective McMahon after Plaintiff's complaint of racial slurs and abusive treatment to a supervisor at the Highland Park Police Department: (b) unwelcome retaliatory harassment via Detective McMahon after Plaintiff's complaint to a supervisor at the Highland Park Police Department that he was not being paid; Prompt notice of such violations of ELCRA was given to supervisory personnel at the Hamtramck Police Department, namely Chief of Police Anne Moise as set forth elsewhere in this pleading, with no remedial action being taken; Prompt notice of such violations of ELCRA was given to supervisory personnel at the Highland Park Police Department, as set forth elsewhere in this pleading, with no remedial action being taken; Asa direct and proximate result of said violations, Plaintiff has sustained emotional distress, embarrassment, and has felt humiliation and mental anguish.Wherefore Plaintiff, John Doe, respectfully requests this Honorable Court enter judgment on his behalf as follows: (A) Alll general and special damages in excess of $25,000; (B) require Defendants to prepare an accounting of all property seized and proceeds derived from the efforts of Plaintiff as a confidential informant; (C) taxable costs and interest; (D) attorney's fees under the Elliot Larsen Civil Rights Act and 42 U.S.C. 1988 (E) any other relief deemed just and equitable. Respectfully submitted: sl Marco Bisbikis, Mareo Bisbikis (P79478) Attomey for Plaintiff Date: 04/06/2016I verified and declare that the statements above are true to the best of my information, knowledge, and belief. Dated: Y- b- Lh Isl. Le bith Doe i Plaintiff Respectfully submitted: Dated: 7 GClAbIb —” ZZ BISBIKIS LAW PLLC Mareo Bisbikis, Esq. (P79478) Attorney for Plaintiff STATE OF MICHIGAN) WAYNE COUNTY) onthis LC aay or_ ts 1 | 20.1 \¢ before me, A Notary Public, in and for said County, personally appeared John Doe, before me known to be the same person described in and who executed the foregoing Complaint and who acknowledged the same to be his free act and deed, and that the same is true on his knowledge, except to those matters therein stated to be on information and belief, and he believes the same to be true. G Isl. Hee Pree C Ge Notary public, State of Michigan, County of )\urgy irae! My commission expires‘! f TSK Seana voor Eo ence ‘Acting nba County of cee ”STATE OF MICHIGAN CASE NO. ‘THIRD JUDICIAL CIRCUIT ‘SUMMONS AND COMPLAINT 16-004487-CK WAYNE COUNTY. Hoon. Muriel Hughes 2 Woodward Ave, Detroit MI 48226 Cour Telephone No 315-2242, Plainttt Defendant Doe, John y Hamtramck, Cty OF Plaintf's Attorney Defendant's Attorney Marco Michael Bisbikis, P-79478 150 N Main St Plymouth, M1 48170-1236 [SUMMONS] NOTICE TO THE DEFENDANT: In the name ofthe people ofthe State of Michigan you are notified 1. You ae being sued. 2. YOU HAVE 21 DAYS after receiving this summons to file a written answer with the caurt and serve a copy on the other party or take other lawful action with the court (28 days ifyou were served by mail or you were served outside this state). (MCR 2.111[C)) 3. yeu do nat enswer or take other action within the time allowed, judgment may be entered against you forthe relief demanded inthe complaint. Issued This summons expires ‘Court clerk 4872016 7182016 File & Serve Tyler "This summons is invalid unless served on or before its expiration date. This document mis be sealed bythe sel ofthe court, COMPLAINT] Instruction: The following is information that is required 0 be inthe caption of every complaint and is to be completed ‘by the plaintiff. Actual allegations and the claim for relief must be stated on additional complaint pages and attacled to this form, Citi is «business case in which all or part ofthe action includes a business or commercial dispute under MCL 600.8035, Fanlly Division Cases, There is no other pending or resolved action within the jurisdiction ofthe family division ofthe eiruit court involving the family or family members ofthe parties An action within the jurisdiction ofthe family division of the circuit court involving he family or amily members ofthe partes has ‘been previously filed in Court Theaction —[Jremains (J isnolonger pending. The docket number and the judge assigned to the action are Docket no. Tage Barna, General Civil Cases [El There is no other pending or resolved civil action arse out of the same transaction or occurrence as alleged inthe complaint. Can civil action between these parties or other parties arising out of the transaction or occurrence alleged in the complaint has been previously filed in Cour. Theaction J remains [_] isnolonger pending. The docket number andthe judge assigned to the action ae: Docket no. Tage Barno, VENUE Plaintiff) residence include eit, township, or village) Defendant(s) residence (include city, township, or village) Detroit Place where action arose or business conducted Wayne County Hamtramck Date Signature oF atiomey/plaintift I you require special accommodations to use the court because ofa disability r if you require foreign language interpreter to help you fully participate in court proceedings, please contact the court immediately to make arrangements. MC 01 (5/15) SUMMONS AND COMPLAINT MCR 2.102(B3(1), MCR 2.104, MCR 2.105, MCR 2.107, MCR 2.1 1(C\2N8)(0) MCR 32064)‘STATE OF MICHIGAN CASE NO. ‘THIRD JUDICIAL CIRCUIT SUMMONS AND COMPLAINT. 16-004457-CK WAYNE COUNTY Hon, Muriel Hughes 2 Woodward Ave, Dewoit MI 48226 Cour Telephone No. 313.2242 Plainsitt Defendant Doe, John v Highland Park, City of Plaintfr's Attorney Defendant's Attorney Marco Michael Bisbikis, -79478 150 N Main St Plymouth, MI 48170-1236 SUMMONS] NOTICE TO THE DEFENDANT: In the name ofthe people ofthe State of Michigan you are notified 1. You are being sued, 2. YOU HAVE 21 DAYS aller receiving this summons to file a written answer withthe court and seve a copy on the other party ‘or fake other lawful action withthe court (28 days if you were served by mail or you were served outside this state). (MCR 2.111{C)) 3. Ifyou do not answer or take other action within the time allowed, judgment may be entered against you forthe relief demanded in the complain. Trsued “This summons expires Court clerk 4/8016 7182016 File & Serve Tyler "This summons is invalid unless seved on o before its expiration date. Tis document must be sealed bythe sel ofthe court [COMPLAINT] Instruction: The folowing is information that is required 0 be inthe caption of every complaint and is to be completed ‘y the plaintiff. Actual allegations and the claim for relief must be stated on additional complaint pages and attached to this form. ithisis business case in which all or part ofthe action includes a business or commercial dispute under MCL. 600.8035, D1 There is no other pending or resolved action within the jurisdiction ofthe family division ofthe circuit court involving the family o Family members ofthe parties, D1An action within the jurisdiction ofthe family division of the eircuit court involving the family or family members ofthe partes has ‘been previously filed in Court. Theaction CJremains (J isnolonger pending. The docket number and the judge assigned tothe action are: Docket no. Tadge Barna, General Civil Cases [x] There is no other pending or resolved civil action arse out ofthe same transaction or occurrence as alleged in the complaint Dan eivi action between these parties or other parties arising out of the transaction or occurence alleged in the complain has been previously fled in Court The action CJ remains] isnolonger pending. The docket amber andthe judge assigned to the action are: Docket no. Tedge Barna. VENUE, [ Plaintiffs) residence include city, township, or village) Defendants) residence include city, township, oF vi Detroit Highland Park Place where action arose or business conducted Wayne County Dawe Signature of atomey/plainttt ( [MCI (5/15) SUMMONS AND COMPLAINT MCR 2102(BX11), MCR 2.104, MCR 2.105, MCR 2.107, MER 2.1 13¢CV2Xe (0) MCR 3.206)STATE OF MICHIGAN CASE NO, ‘THIRD JUDICIAL CIRCUIT SUMMONS AND COMPLAINT 16.004487-CK WAYNE COUNTY Hon. Muriel Hughes 2 Woodward Ave, Detroit MI 44226 Court Telephone No. 315-2242 Plainctt Defendant Doe, John y Mahon, Detective Plaintif?'s Attorney Defendant's Attorney Marco Michae! Bisbikis, P-79478 150 N Main St Plymouth, MI 48170-1236 | l SUMMONS] NOTICE TO THE DEFENDANT: In the name of the people ofthe State of Michigan you are notified You are being sued 2. YOUHAVI or take oth 'E.21 DAYS after eceiving this summons f file a written answer with the court and serve a copy on the other party er lawful action with the court (28 days ifyou were served by mail or you were served outside this state). (MCR 2.111[C) 3. Ifyou do not answer or take other action within the time allowed, judgment may be entered against you for the reli demanded in the complaint. Tesued “This summons expires Court clerk 4182016 7182016 File & Serve Tyler "This summons i invalid unless served on o before its expiration date. This document must be scale bythe sel ofthe cour. COMPLAINT] Instruction: The folowing is information hat is required to be inthe caption of every complaint and ist be completed ‘by the plaintiff. Actual allegations and the claim for relief must be stated on additional complaint pages and attached to this form. itis is a business casein which all or part ofthe action includes a business or commercial dispute under MCL 600.8035, Family Division Cases, Di Thereis no other pending or resolved action within the jurisdiction of the family division of the cireuit court involving the family or family members ofthe parties, An action within the jurisdiction of the family division ofthe circuit court involving the family o family members of the parties has been previously filed in Court ‘reaction J remains [J isnotonger pending. The docket number andthe judge assigned to the action are: Docket no, Tudge Barre, General Civil Cases [2X There is no other pending or resolved civil action arse out ofthe same transaction or accurrence as alleged inthe complaint an civil ation between these parties or other partis arising out of the transaction or occurtence alleged in the complaint has been previously filed in Coun, Theaction — [) remains Di isno longer pending. The docket number and the judge assigned to the action are: Docket na Tage Bar no, ‘VENUE Plaintiffs) residence Gnclude city, township, or vil Defendant(s) residence (include ety, township, or village) nil resides ( ¥. ip, oF village) iG) ‘ v. i, or village Hamtramck Place where action arose or business conducted Wayne County Date Signature of atomeyiplaintitr [you requite special accommodations to use the court because of a disability or if you requice a foreign language interpreter to ‘help you fully participate in court proceedings, please contact the court iamediately to make arrangements, MC 01 (5/15) SUMMONS AND COMPLAINT MCR 2.102(8)(11), MCR 210, MCR 2.105, MCR 2.107, MCR 2.113(CX2=).b}. MCR 3206(A)STATE OF MICHIGAN CASE NO. ‘THIRD JUDICIAL CIRCUIT ‘SUMMONS AND COMPLAINT. 16-004457-CK WAYNE COUNTY. Hon. Muriel Hughes 2 Woodward Ave, Dewoit MI 48226 ‘Cour Telephone No, 315-2042 Plainctt Defendant Doe, John 3 Moise, Chief Anne Plaintf?'s Attorney Defendant's Attorney Marco Michael Bisbikis, P-79478 130 N Main St Plymouth, MI 48170-1236 SUMMONS) NOTICE TO THE DEFENDANT: In the name of the people ofthe State of Michigan you are notified: I. You are being sued. 2. YOU HAVE 21 DAYS after receiving this summons to flea written answer with the court and serve a copy on the other party or take other lawful ation with the court (28 days ifyou were served by mail or you were served outside this state). (MCR 2.111[C) 3. Ifyou do not answer or take other action within the time allowed, judgment may be entered against you forthe relief demanded inthe complaint. Tesued “This summons expires ‘Cour clerk 4/82016 182016 File & Serve Tyler ‘This summons is ivaiduntess served on or before its expiration date, This document mis be sealed by the el ofthe court COMPLAINT] Instruction: The following is information that is required to be in the caption of every complaint and is to be completed ‘by the plain. Actual allegations and the claim for relief must be stated on additional complaint pages and attached to this form. itisis a business casein which all or part ofthe action includes a business or commercial dispute tnder MCL 600.8035, Family Division Cases, There is no other pending or resolved action within the jurisdiction ofthe family division of the iret court involving the family o Family embers ofthe partis. An action within the jurisdiction ofthe family division ofthe cireuit court involving the family or family members ofthe partes has been previously filed in Coun. Theaction [CJ remains] isnolonger pending. The docket number and the judge assigned to the ation are Docket no. Tadge Barna, General Civil Cases i) There is no other pending or resolved civil action arse out ofthe same transaction or occurrence as alleged in the complaint. Tan civil action between these parties or other parties arising out ofthe transaction or occurrence alleged in the complaint has been previously fied in Court ‘Theaction J remains [J isnotonger pending. ‘The docket number and the judge assigned the action are: Docket na, Tudae Bare. VENUE Plaintiff) residence include city, township, or village) Defendant(s) residence (include city, township, or village) Detroit Hamtramck Place where action arose or business conducted Wayne County Date Signature of atomey/plaintitt Ifyou require special accommodations to use the court because of a disability ori you require foreign language interpreter to help you fally participate in court proceedings, please contact the court immediately to make arrangement, MCI (5/15) SUMMONS AND COMPLAINT MCR 2 162(8)(11), MCR 2.104, MCR 2.105, MCR 2.107, MCR 2.113(C\2)@)(8), MCR 3.206(4)‘STATE OF MICHIGAN ‘CASENO. THIRD JUDICIAL CIRCUIT ‘SUMMONS AND COMPLAINT 16-004457-CK WAYNE COUNTY Hon. Muriel Hughes 2 Woodward Ave, Detroit MI 48226, Cour Telephone No, 315-224-2, Plainttt Defendant Dee, John . Stout, Detective Michael Plaintft's Attorney Defendant's Attorney Marco Michae! Bisbikis, P-79478 150 N Main St Plymouth, MI 48170-1236 SUMMONS] NOTICE TO THE DEFENDANT: In the name of the people ofthe State of Michigan you ae notified: [You are being sued. 2. YOU HAVE 21 DAYS aller receiving this summons to fllea written answer with the court and serve a copy on the other party or take other lawful action with the court (28 days ifyou were served by mail or you were served outside this sate). (MCR 2.111(C}) 3. If'youdo not answer of take other action within the time allowed, judgment may be entered against you forte relief demanded inthe complaint. Tesued “This summons expires Cour clerk 482015 71 82016 File & Serve Tyler ‘This summons is inal unless served on o before its expiration date. This document must be scale bythe el ofthe cout. COMPLAINT] Instruction: The folowing is information that is required to be inthe caption of every complaint and isto be completed ‘y the plaintiff. Actual allegations and the claim for relief must be stated on additional complaint pages and attached to this form. otis is a business case in which all or part ofthe action includes a business or commercial dispute under MCL 600.8035, Family Division Cases, Di There is no other pending or resolved action within the jurisdiction ofthe family division of the cireuit eourt involving the family or Family ‘members ofthe parties. An action within the jurisdiction ofthe family division ofthe circuit cout involving the Family or family members of the parties has been previously filed in Court ‘Theaction [J remains] iso longer pending. ‘The docket number andthe judge assigned to the action are: Dosket na Tudge Barna, General Civil Cases iithere is no other pending or resolved civil action arise out ofthe same transaction or accurrence as alleged in the complaint. Dan civil action between these parties or other partis arising out ofthe transaction or accurtence alleged in the complaint has been previously filed in Court. ‘Theaction CJ remains] ismotonger pending. The docket number andthe judge assigned to the action ae: Docket no Judge Barna. VENUE Pains) residence Glide iy, township, or village) Defendant(s) residence include city, township, or village) Detroit Hamtramck Place where action arose or business conducted Wayne County Date Signature of avomey/plaintt you require special accommodations to use the court because ofa disability or if you requie a foreign language interpreter to help you fully paticipae in court proceedings, please contact the cout immediately to make arrangements. MC 01 (3/15) SUMMONS AND COMPLAINT MCR 2102811), MCR 2.104, MCR 2.108, MCR 2.107, MER 2.113(C\2Xa}(0), MCR 3.206)