Professional Documents
Culture Documents
EASTERNDISTRICT
RASOULJOUMAAH,anindividualGAYLE
JOUMAAH,anindividualAMJADSABER,
anindividualYOUSRAJALAL,anindividual
andSAMSTIRESHOP,aMichiganCorporation,
Plaintiffs,
vs.
CaseNo.
Honorable:
DETECTIVEJAMESMCMAHON,
Inhisindividualandofficialcapacity
DETECTIVEMICHAELSTOUT,
Inhisindividualandofficialcapacity
ANNEMOISE,ChiefofPoliceHamtramck,
Inherindividualandofficialcapacity
THECITYOFHAMTRAMCK
THECITYOFHIGHLANDPARKand
THE MICHIGAN AUTO THEFT PREVENTION
AUTHORITY(ATPA)aprivateentity
JointlyandSeverally,
Defendants.
______________________________________________________________________________
STEVENA.HANEY,SR.(P63947)
HaneyLawGroup,PLLC
AttorneyforPlaintiffs
811SouthBlvd.,Suite210
RochesterHills,MI48037
(517)614.2304
steve@haneygroup.net
MuneebM.Ahmad,Esq(P70391)
S.HussainAkbar,Esq(P67967)
AHMAD&AKBARLAW,PLLC
AttorneysforPlaintiff
900WilshireDrive,Suite202
Troy,Michigan48084
Tel:(248)5192313
Fax:(248)5192399
______________________________________________________________________________
COMPLAINTANDJURYDEMAND
NOW COME
, Plaintiffs, Rasoul Sam Joumaah, an individual Gayle Joumaah, an
individual Amjad Saber, an individual Yousra Jalal, an individual and Sams Tire Shop, a
Michigan Corporation, through their attorneys, Steven A. Haney, Sr. of the Haney Law Group,
PLLC, and Muneeb M. Ahmad and Syed Hussain Akbar, of Ahmad & Akbar Law, PLLC, and
statefortheirComplaint
asfollows:
THEPARTIES
1.
residentoftheStateofMichigan,intheCountyofWayne.
3.
residentoftheStateofMichigan,intheCountyofWayneandthewifeofPlaintiffR.Joumaah.
4.
oftheStateofMichigan,intheCountyofWayneandthefatherofPlaintiffR.Joumaah.
5.
theStateofMichigan,intheCountyofWayneandthemotherofPlaintiffR.Joumaah.
6.
police officer with the Hamtramck Police Departmentandisdomiciled inthe State ofMichigan.
DefendantStoutisbeingsuedinhisindividualandofficialcapacity.
7.
Chief of Police of the City of Hamtramck and domiciled in the State of Michigan. Defendant
Moiseisbeingsuedinherindividualandofficialcapacity.
8.
is a police officer with the Highland Park Police Department and is domiciled in the State of
Michigan.DefendantMcMahonisbeingsuedinhisindividualandofficialcapacity.
10.
municipal corporation, and is organized and existing under the laws of the State of Michigan,
with its principal offices located at 12050 Woodward Blvd., Highland Park, Michigan. All
current and former employees identified herein as Defendants are being named in their
individual and official capacities. [Collectively Defendant Hamtramck and Defendant Highland
ParkshallbehereinafterreferredtoasDefendantCities.]
11.
Defendant MATPA], is a administered by the Miichigan State Police, and is organized and
existing under the laws of the State of Michigan, with its principal offices located at 333 South
GrandAvenue,Lansing,Michigan48909.
12.
insurance industryandisasupervisoryagencyfortheC.O.B.R.AAutoTheftTaskForce,aswell
as for Defendants McMahon and Stout. Defendant MATPA utilizes a $1 per policy insurance
premium for the purpose of funding and supporting the actions andconductofitsgrantees,of
which includes the C.O.B.R.A auto theft task force, as well as MATPA Wayne County
Prosecutor Dennis Doherty. Given its supervisory role and relationship to the C.O.B.R.A
Taskforce and Defendants McMahon and Stout, Defendant MATPA is vicariously liable for
Defendant McMahon, Stout and Moises actions or lack thereof. [Defendants Stout, Moise,
McMahonandMATPAshallhereinaftercollectivelybereferredtoasDefendantOfficers.]
JURISDICTIONANDVENUE
13.
attorneyfees.
15.
VenueisproperinthisJudicialDistrictunder28U.S.C.1391.
FACTUALBACKGROUND
16.
husband, as well as his father, Plaintiff Amjed Saber, and his mother, Plaintiff Yousra Jalal, at
theirresidencelocatedat7830NormileStreetinDearborn,Michigan,CountyofWayne,Stateof
Michigan.
18.
Upon information and belief, Defendant James McMahon, a Detective with the
Highland Park Police Department, is a police officer and member of a multijurisdictional auto
theft task force named C.O.B.R.A. This task force is funded by the Auto Theft Prevention
Authority, which receives $1 premiums on auto policies throughout the state to grant fund
specialized auto theft teams and prosecutors. ThedelegatedWayneCountyMATPAProsecutor
is WayneCountyAssistantProsecutingAttorneyDennis Doherty,who isnotedtohavereviewed
thesearchwarrantsatissueinthiscase.
19.
Upon information and belief, Defendant Michael Stout, a Detective with the
Hamtramck City Police Department, is a police officer and also a member of the
multijurisdictionalC.O.B.R.AautothefttaskforcewithhispartnerDefendantMcMahon.
20.
Hamtramck, was at all times the Supervising authority with personal knowledge as to the
conduct and allegations of misconduct and racial discrimination of her subordinate Defendant
Stout. Defendant Moise woefully failed to engage in any appropriate steps in addressing the
illegal conduct of City of Hamtramck police officer Defendant Stout, for which she had a duty,
and in fact violated that duty when she was observed to be conspiring anddirectlybenefitingin
the illegal conduct and abuse of power by DefendantStoutandhispartnerDefendantMcMahon
(SeeEx.AJohnDoev.DetectiveMcMahonet.alparagraph90).
21.
At all times relevant, Defendants McMahon, Stout and Moise, as officers acting
constitutionalandcivilrightsofthecitizensofthemunicipalitiesinwhichtheypoliced.
22.
corporation, organized and existing under the laws of the State of Michigan, with its principal
office located at 3401 Evaline, Hamtramck, Michigan, at all times employed both Defendant
Stout and Defendant Moise and owed a duty to the citizensandcommunityofallmunicipalities
in which they policed, to adequately train or supervise its employees so as to ensure that,
Defendant Stout and Defendant Moise,wouldnotintentionallyand/ornegligentlyandrecklessly
abuse their police power under the color or authority of law by engaging actions that would
violate the clearly established constitutional and civil rights of citizens of any municipality in
2
whichtheseDefendantspoliced.
23.
corporation, organized and existing under the laws of the State of Michigan, with its principal
office located at 12050 Woodward Blvd., Highland Park, Michigan, at all times employed
Highland Park Detective James McMahon and owed a dutytothecitizensandcommunityofall
municipalities in which they policed, to adequately train or supervise its employee so as to
ensure that, Defendant McMahon, would not intentionally and/or negligently and recklessly
abuse hispolicepowerunderthecolororauthorityoflawbyengagingactionsthat would violate
the clearly established constitutional and civil rights of citizens of any municipality inwhichhe
3
policed.
24.
th
th
Poev. Haydon
, 853 F.2d 418,425(6
Cir. 1988)seealso
Graweyv.Drury
,567F.3d302, 309 (6
Cir.2009)see
also
Pearsonv.Callahan
,555U.S.223(2009)
2
th
Ellisexrel.Pendergrassv.ClevelandMun.Sch.Dist.
,455F.3d690,700(6
Cir.2006)
3
th
Ellisexrel.Pendergrassv.ClevelandMun.Sch.Dist.
,455F.3d690,700(6
Cir.2006)
1
McMahonandStout.
25.
Upon information and belief, on or about the date of August 15th, 2015, a John
Doe informant agreed to assist Defendants McMahon and Stout (C.O.B.R.A Task Force) in an
investigationofPlaintiffSamsTireShopanditsprincipalownerPlaintiffR.Joumaah.
26.
Upon information and belief, that during the initial briefing of the investigation,
Defendants McMahon and Stout advised the confidential informant that they were targeting
Sams Tire Shop because they wanted to rid the Hamtramck community of
these fucking
Arabs.
(SeeEx.AJohnDoev.DetectiveMcMahonet.alparagraph
22).
27.
Upon information and belief, that during this initial August 2015 briefing,
wewanttogetridofSamand
everybody like him.
(See Ex. A John Doe v. Detective McMahon et. al paragraph 23)
.
The reference to getting rid of
th
Ellisexrel.Pendergrassv.ClevelandMun.Sch.Dist.
,455F.3d690,700(6
Cir.2006)
28.
Upon information and belief, that during the course of the investigation and
towel heads
,
rag heads
,
sand niggers
and
camel jockeys
.
(See Ex.A
JohnDoev.DetectiveMcMahonet.alparagraphs3643)
.
29.
That or about the latter part of August 2015, the confidential informant solicited
the purchase of marijuana from Plaintiff R. Joumaah, but was refused, as Plaintiff R. Joumaah
informed the confidential informant he was not a drug, or gun dealer, and couldnotprovidethe
confidential informant with either
(See Ex. A John Doe v. Detective McMahon et. al
paragraph90).
31.
Upon information and belief, that on or about the month of September 2015,
Defendants McMahon and Stout advised the confidential informant to further ingratiate himself
with Plaintiff R. Joumaahandinformhimthatforonedollarpertire,hecoulddisposeoftireson
behalf of Plaintiff Sams Tire Shop.
(See Ex. A John Doe v. Detective McMahon et. al
paragraph27).
32.
his company, Plaintiff Sams Tire Shop, Defendant McMahon rented a UHaul truck for the
confidential informant, as well as a secured unmarked police van, which was then used to
illegally dump the tires in the City of Detroit. Defendants McMahon and Stout selected to
illegally dump the tiresinDetroitbyvirtueofDefendantStouttellingtheconfidentialinformant,
an African American male,
you must be out of your nigger mind if you think we are dumping
those tires in Hamtramck.
(See Ex. A John Doe v. Detective McMahon et. al paragraph
3032).
33.
Upon information and belief, that while illegally dumping the tiresfromPlaintiff
Sams Tire Shop in the city of Detroit, Defendants McMahon and Stout acted as lookouts and
escorts and were armed while the confidential informant was illegally dumping the tires from
Plaintiff Sams Tire Shop in Detroit.
(See Ex. A John Doe v. Detective McMahon et. al
paragraph29).
34.
Upon information and belief, that on or about October 6th, 2015, Defendant
McMahon prepared a falsified Search Warrant and Affidavit, attesting under oath that probable
cause existed alleging Plaintiff R. Joummahs involvementincrimesassociatedwithconducting
a continuing criminal enterprise (CCE), insurance fraud, conspiracy to commit insurance fraud
and using a computer to commit a felony
(See Ex. B October 6th, 2015 Search Warrant
andAffidavit)
.
35.
That pursuant to the October 6th, 2015 Search Warrant and Affidavit, Defendant
Insurance Agency, in the City of Detroit, County of Wayne 7830 Normile Street, singlefamily
residence of Plaintiffs R. Joumaah, G. Joumaah and their parents, Plaintiffs Amjad Saber and
YousraJamal.
(SeeEx.BOctober6th,2015SearchWarrantandAffidavit)
.
36.
That pursuant to the October 6th, 2015 Search Warrant and Affidavit, Defendant
McMahon allegedprobablecauseofsuchcriminalactivitynecessitatedtheseizureattheareasto
besearchedofsubstantialpersonalandbusinessproperty.
37.
That despite what fabricated information was sworn to in the October 6th, 2015
Search Warrant and Affidavit, which included such entirely irrelevant information as vehicle
sales, when Plaintiff R. Joumaah sells no vehicles, upon execution of the Search Warrant,
Detective McMahon advised Plaintiff R. Joumaah, owner of Plaintiff Sams Tire Shop, the
factual basis for the raid was predicated upon allegations that Plaintiff R. Joumaah, and his
father, Plaintiff Saber, somehow assisted and conspired with the same illegal tire dumpingJohn
Doe confidential informant for the purchase of a falsified insurance policy from an insurance
agency somewhere in Dearborn, Michigan.
(See Ex. C Witness Affidavit of Rasoul
Joumaah).
38.
That at no point in time did Plaintiff R. Joumaah ever have any contact with the
That on October6th,2015,basedonthisblatantlyfalsifiedcriminalinvestigation,
10
cash, ripped panels and cabinets off walls, overturned furniture and summarily seized such
personal effects as Plaintiff R. Joumaahs mothers (Plaintiff Yousra Jamal) jewelry box and
family immigration records, as wellasPlaintiffR.Joumaahspassport,greencardandhiswifes
(Plaintiff Gayle Joumaah)birthcertificate,marriagelicenseandnumerousvehicletitles. Despite
numerous requests of both Defendants McMahon and Stout, none of the seized property was
ever returned to any of the rightful Plaintiffs possession.
(See Ex. C Witness Affidavit of
RasoulJoumaah).
40.
During this October 6th, 2015 raid at the Plaintiffs Dearborn residence, the
Immediately following the October 6th, 2015 raid, at approximately 4:00 p.m.,
11
Amjed Saber, were ever criminally charged with any wrongdoing and at no point was a
civil in rem forfeiture proceeding ever initiated by the Wayne CountyProsecutorsOffice.
Despite repeated demands, at the time of this Federal Complaint, all Plaintiffs to this action
remaindeprivedoftheircashandpersonalpropertystolenbytheseDefendantpoliceofficersand
Defendantmunicipalities.
(SeeEx.CWitnessAffidavitofRasoulJoumaah).
43.
That DefendantsMcMahonandStoutknowinglyfalsifiedevidenceandfabricated
Upon informationandbelief,DefendantCityofHamtramck,kneworshouldhave
known that Defendant Stout was engaging in conduct that violated the clearly established
constitutionalcivilrightsofthecitizensandcommunityofallmunicipalitiesinwhichhepoliced,
as Defendant Hamtramck knew or should have known that that Defendant Stout previously
engaged in a pattern of practice or conduct of filing false police reports, false affidavits,
obtaining search warrants based on false or incomplete information,andfalselyarrestingpeople
ofArabicdescentorotherminorityethnicities.
45.
Upon informationandbelief,DefendantCityofHamtramck,kneworshouldhave
known that Defendant Stout and Moise acted in concert andconspiredtoengageinconduct that
violated the clearly established constitutional civil rights of the citizens and community of all
municipalities in which they policed, as Defendant Hamtramckkneworshouldhaveknownthat
12
that Defendants Stout and Moise previously engaged in a patternofpractice orconduct offiling
false police reports, false affidavits, obtaining search warrants based on false or incomplete
information,andfalselyarrestingpeopleofArabicdescentorotherminorityethnicities.
46.
Upon information and belief, Defendant Highland Park, knew or should have
known that Defendant McMahon Stout was engaging in conduct that violated the clearly
established constitutional civil rights of the citizens and community of all municipalities in
which he policed, as Defendant Highland knew or should have knownthatthatDefendantStout
previously engaged in a pattern of practice or conduct of filing false police reports, false
affidavits, obtaining search warrants based on false or incomplete information, and falsely
arrestingpeopleofArabicdescentorotherminorityethnicities.
48.
Upon information and belief, Defendant MATPA, knew or should have known
13
that Defendants McMahon and Stout, both of whom belong to the C.O.B.R.A. task force, for
which Defendant MATPA is charged with administering and managing and supervising, were
engaging in conduct that violated the clearlyestablishedconstitutionalcivilrightsofthecitizens
and community of all municipalities in which they policed, as Defendant MATPA knew or
should have known that that Defendants McMahon and Stout previouslyengagedinapatternof
practice or conduct of filingfalsepolicereports,falseaffidavits,obtainingsearchwarrantsbased
on false or incomplete information, and falsely arresting people of Arabic descent or other
minorityethnicities.
50.
declaratory judgment that Defendants Hamtramck, Highland Park and MATPA have a policy,
custom, or practice of acquiescence in, inadequate training of or supervision regarding
unconstitutional conduct of its officers in general, and Defendants McMahon and Stout in
particular, to wit: their failure to investigate in good faith, their falsification of evidenceagainst
an accused or others, and conduct amounting to unlawful search and seizure, false arrest, false
imprisonment without probable cause, as well as cruel and unusual punishment, failure to
disclose exculpatory evidence or material, all, thereby depriving Plaintiffs of their clearly
established constitutional rights and liberties as guaranteed under the Constitution and laws of
14
theUnitedStates.
COUNTIFEDERALCLAIM
VIOLATIONOFTHEFEDERALCIVILRIGHTSACTOF1871
42U.S.C1983FOURTHANDFOURTEENTHAMENDMENTVIOLATIONSFALSE
ARREST,FALSEIMPRISONMENT,ANDUNREASONABLESEARCHANDSEIZURE
ASTODEFENDANTOFFICERS
52.
Plaintiffs incorporate by reference the foregoing paragraphs as though fully set
forth,herein.
53.
Officersviolatedincludethefollowing:
a. their rights to liberty protected in a substantive component of the due process
clause of the Fourteenth Amendment which includes personal safety, privacy,
liberty,andfreedomfromcaptivity
b. their rights to free and equal treatment guaranteed and protected by the Equal
ProtectionclauseoftheFourteenthAmendmentand
c. the right to be secure in his person, papers and effects against unreasonable
searchesandseizuresundertheFourthAmendment.
54.
Defendant Officers acting under color and authority of law, violated Plaintiffs
above referenced clearly established Constitutionally protected rights, when despite thefactthat
there was no evidence or probable cause to demonstrate that Plaintiffs had committed, or were
committing, anycrime,fabricatedsuchinformationandwrongfullydetained Plaintiffs,depriving
them of their freedom, freedom of movement, and subjecting them to a wrongful and
unreasonablesearchandseizure.
55.
15
The search conducted on Plaintiffs persons and property was without their
consent.
57.
Defendant Officers, acting under color and authority of law, violated Plaintiffs
above referenced clearly established Constitutionally protected rights, when despite thefactthat
there was no evidence or probable cause to demonstrate that Plaintiffs had committed, or were
committing, any crime, they handcuffed, arrested, and unlawfully searched, and unlawfully
imprisonedPlaintiffsR.JoumaahandSaber,resultingintheirincarceration.
58.
Defendant Officers, acting under color and authority of law, violated Plaintiffs
above referenced clearly established Constitutionally protected rights, when despite thefactthat
there was no evidence or probable cause to demonstrate that Plaintiffs had committed, or were
committing, any crime, on October 6, 2015, basedonablatantlyfalsifiedcriminalinvestigation,
they imprisoned Plaintiffs R. Joumaah and Saber in the Hamtramck City Jail, and then
subsequently three days later released them from custody with no explanationastothebasisfor
16
theirfalsearrestorfalseimprisonment.
(SeeEx.CWitnessAffidavitofRasoulJoumaah).
59.
Neither Plaintiff R. Joumaah, nor his father, Plaintiff A. Saber, were ever
criminally charged with any wrongdoing and at no point was any civil in rem forfeiture
proceedingeverinitiatedbytheWayneCountyProsecutorsOffice.
60.
residence, and arrested Plaintiffs R. Joumaah and Saber, Defendant Officers were acting in an
administrativeorpolicecapacity.
62.
motivatedbecauseofPlaintiffsethnicity,nationaloriginand/orreligiousbackground.
63.
PlaintiffsaremembersofaprotectedclassasdefinedbyStateandFederallaws.
64.
Plaintiffs were also denied equal protection of the law because of their ethnicity,
Upon information and belief, Defendant MATPA, knew or should have known
that Defendants McMahon and Stout, both of whom belong to the C.O.B.R.A. task force, for
which Defendant MATPA is charged with administering and managing and supervising, were
engaging in conduct that violated the clearlyestablishedconstitutionalcivilrightsofthecitizens
17
and community of all municipalities in which they policed, as Defendant MATPA knew or
should have known that that Defendants McMahon and Stout previouslyengagedinapatternof
practice or conduct of filingfalsepolicereports,falseaffidavits,obtainingsearchwarrantsbased
on false or incomplete information, and falsely arresting people of Arabic descent or other
minorityethnicities.
66.
but are not limited to awarding grants to law enforcement agencies and prosecutors offices,
whichDefendantMATPAkneworshouldhaveknown:
a.
hire and employ police personnel who are suspected or known to have
conspired with other individuals and entities in order to deprive individuals of their
clearlyestablishedconstitutionallyprotectedcivilrights
b.
hire and employ police personnel who are suspected or known to have
falselyarrestindividualswithoutprobablecause
c.
hire and employ police personnel who are suspected or known to have
detainandfalselyimprisonindividualsagainsttheirwill,andwithoutprobablecause
d.
hire and employ police personnel who are suspected or known to have
withhold and/or suppress evidence from individuals or defendants that is favorable to
them
e.
hire and employ police personnel who are suspected or known to have
conspire with other individuals andentitiesinordertodepriveindividualsoftheirclearly
establishedConstitutionallyprotectedcivilrights
f.
Inadequately train, supervise and discipline police personnel, whom the
18
law enforcement agencies knew or should have known to falsely arrest individuals
withoutprobablecause
g.
Inadequately train, supervise and discipline police personnel, whom the
law enforcement agencies knew or should have known to detain and falsely imprison
individualsagainsttheirwill,andwithoutprobablecause
h.
Inadequately train, supervise and discipline police personnel, whom the
law enforcement agencies knew or should have known to withhold and/or suppress
evidencefromindividualsordefendantsthatisfavorabletothem
i.
Fail to train police personnel properly on arrest management and
applicable law, where such failure amounted to deliberate indifference to the rights of
personswithwhomthepolicecomeintocontact
j.
Fail to adequately investigate citizens complaintsastopolicemisconduct
andpursueproperremedialmeasuresand
k.
Otheractsandomissionswhichwillbedeterminedduringdiscovery
68.
through its failure to take corrective action, or its tacit authorization, toleration, ratification,
permission, or acquiescence created a defacto policy of deliberate indifference to the clearly
established constitutional rights of individuals by (1) failed to implement or enforce policies
regarding unconstitutional conduct, including ethnic harassment, violation of Constitutional
rights, and false imprisonment by failing to properly investigate such conductafterbeingputon
notice of facts in support of a claim that unconstitutional acts occurred and (2) failing to have
adequateproceduresinplacetoinvestigateandtrainagainstpolicemisconduct.
69.
superviseanddisciplinepolicepersonnelincluding,DefendantsMcMahonandStout,aswelland
others, was known to Defendant MATPA as highly likely and probable to cause violations of
constitutionalrightsofmembersofthepublicinparticularPlaintiffherein.
19
70.
MATPAisvicariouslyliablefortheactionsofDefendantsStoutandMcMahon.
71.
Defendant Officers policies, customs, and practices were carried out with
andseverallyliableunder42U.S.C.1983.
73.
sufferedlossoflibertyincarcerationandimprisonment.
74.
thousandsofdollarsincashandproperty.
75.
damages including but not limited to: embarrassment, indignation, anxiety, mental anguish,
nightmares, emotional distress, discomfort, pain, loss of weight, humiliation, outrage, shame,
fear, loss of income, damage to their professional reputation, damage to their reputation in the
community, denial of constitutional rights, and other injuries, damages or consequences related
totheincidentandDefendantOfficersunlawfulconduct.
WHEREFORE, Plaintiff respectfully requests declaratory relief from this Honorable
Court as outlined above, and further requests judgment against Defendant Officers, jointly and
severally, for compensatory damages for whatever amount the jury finds necessary, and further
20
demands judgment against Defendants, jointly and severally, for punitive damages in whatever
amount the jury finds necessary, in addition to all costs, interest, and actual attorney fees
pursuant to 42 U.S.C. 1988, and such other relief as this Honorable Court deems just, and
equitableunderthecircumstances.
76.
COUNTIIFEDERALCLAIM
42U.S.C.1983MONELLCLAIM
(AGAINSTDEFENDANTCITIESONLY)
77.
Upon informationandbelief,DefendantCityofHamtramck,kneworshouldhave
forth.
known that Defendant Stout was engaging in conduct that violated the clearly established
constitutionalcivilrightsofthecitizensandcommunityofallmunicipalitiesinwhichhepoliced,
as Defendant Hamtramck knew or should have known that that Defendant Stout previously
engaged in a pattern of practice or conduct of filing false police reports, false affidavits,
fabricating evidence, obtaining search warrants based on false or incomplete information, and
falselyarrestingpeopletargetingthoseofArabicdescent,orotherminorityethnicities.
78.
Upon informationandbelief,DefendantCityofHamtramck,kneworshouldhave
known that Defendant Stout and Moise acted in concert andconspiredtoengageinconduct that
violated the clearly established constitutional civil rights of the citizens and community of all
municipalities in which they policed, as Defendant Hamtramckkneworshouldhaveknownthat
that Defendants Stout and Moise previously engaged in a patternofpractice orconduct offiling
false police reports, false affidavits, obtaining search warrants based on false or incomplete
information,andfalselyarrestingpeopleofArabicdescentorotherminorityethnicities.
21
79.
Upon information and belief, Defendant Highland Park, knew or should have
known that Defendant McMahon Stout was engaging in conduct that violated the clearly
established constitutional civil rights of the citizens and community of all municipalities in
which he policed, as Defendant Highland knew or should have knownthatthatDefendantStout
previously engaged in a pattern of practice or conduct of filing false police reports, false
affidavits, fabricating evidence, obtaining search warrants based on false or incomplete
information,andfalselyarrestingpeopleofArabicdescentorotherminorityethnicities.
81.
At all times material to this complaint, Defendant Cities by and through their
police departments, pursued de facto policies, practices and customs that were a direct and
proximate cause of the unconstitutional arrest and unreasonable search and seizure of Plaintiffs
and the other deprivations of Constitutional rights alleged herein, including the Fourth and
22
FourteenthAmendmentsoftheConstitution.
83.
Upon information and belief, Defendant Cities systemic deficiencies include but
arenotlimitedto:
a.
Hiring and/or retaining as police personnel whom the aforementioned
Defendants knew or should have knowntoconspirewithotherindividualsandentitiesin
order to deprive individuals of their clearly established constitutionally protected civil
rights
b.
Hiring and/or retaining as police personnel, whom the aforementioned
Defendants knew or should have known to falsely arrest individuals without probable
cause
c.
Hiring and/or retaining as police personnel, whom the aforementioned
Defendantsknew orshould haveknowntodetainandfalselyimprisonindividualsagainst
theirwill,andwithoutprobablecause
d.
Hiring and/or retaining as police personnel, whom the aforementioned
Defendant knew or should have known to withhold and/or suppress evidence from
individualsordefendantsthatisfavorabletothem
e.
Inadequately training, supervising and disciplining police personnel,
whom the aforementionedDefendantskneworshouldhaveknowntoconspirewithother
individuals and entities in order to deprive individuals of their clearly established
Constitutionallyprotectedcivilrights
f.
Inadequately training, supervising and disciplining police personnel,
whom the aforementioned Defendants knew or should have known to falsely arrest
individualswithoutprobablecause
g.
Inadequately training, supervising and disciplining personnel, whom the
23
aforementioned Defendants knew or should have known to detain and falsely imprison
individualsagainsttheirwill,andwithoutprobablecause
h.
Inadequately training, supervising and disciplining personnel, whom the
aforementioned Defendant knew or should have known to withhold and/or suppress
evidencefromindividualsordefendantsthatisfavorabletothem
i.
Failing to train police personnel properly on arrest management and
applicable law, where such failure amounted to deliberate indifference to the rights of
personswithwhomthepolicecomeintocontact
j.
Failing to adequately investigate citizens complaints as to police
misconductandpursueproperremedialmeasuresand
k.
Otheractsandomissionswhichwillbedeterminedduringdiscovery.
85.
The municipal policymakers of Defendant Cites have (1) failed to enforce
departmental policies regarding, inter alia, the duties of apublicsafetyofficer,abuseofprocess,
and conformance to laws (2) have acquiesced in or ratified unconstitutional conduct, including
ethnic harassment, violation of Constitutional rights, and false imprisonment, by failing to
properly investigate such conduct after being put on notice of facts in support of a claim that
unconstitutional acts occurredand (3)failingtohaveadequateproceduresinplacetoinvestigate
andtrainagainstpolicemisconduct.
86.
supervise and discipline the Defendants McMahon and Stout and others, was known to
Defendant Cities as highly likely and probable to cause violations of constitutional rights of
membersofthepublicinparticularPlaintiffherein.
87.
Asaresultoftheirconductdescribedabove,Defendantsare,also,jointlyand
severallyliableunder42U.S.C.1983.
88.
24
oflibertyincarcerationandimprisonment.
89.
dollarsincashandproperty.
90.
damages including but not limited to: embarrassment, indignation, anxiety, mental anguish,
nightmares, emotional distress, discomfort, pain, loss of weight, humiliation, outrage, shame,
fear, loss of income, damage to their professional reputation, damage to their reputation in the
community, denial of constitutional rights, and other injuries, damages or consequences related
totheincidentandDefendantsunlawfulconduct.
WHEREFORE, Plaintiff respectfully requests declaratory relief from this Honorable
Court as outlined above, and further requests judgment against all Defendants, jointly and
severally, for compensatory damages for whatever amount the jury finds necessary, and further
demands judgment against all Defendants, jointly and severally, for punitive damages in
whatever amount the jury finds necessary, in addition to all costs, interest, and actual attorney
fees pursuant to 42 U.S.C. 1988, and such otherrelief asthisHonorableCourtdeemsjust,and
equitableunderthecircumstances.
91.
COUNTIIIFEDERALCLAIM
VIOLATIONSOF42U.S.C.1985
AGAINSTALLDEFENDANTS
forth,herein.
92.
and intimidation of their entitled equal protection of the laws and from enjoying and exercising
25
their entitled rights and privileges, including but not limited to, their right to be secure in their
persons,papersandeffectsagainstunreasonablesearchesandseizures,includingbeingsubjected
totheuseofexcessiveforce.
93.
nationaloriginand/orreligiousbackground.
94.
PlaintiffsaremembersofaprotectedclassasdefinedbyStateandFederallaws.
95.
nationalorigin.
96.
incident that took place as described in this complaint, by preparing untimely, false and
inaccuratepolicereports,tocoverupwhatactuallytookplace.
97.
indirectly, prevented Plaintiffs from enjoying and exercising their rights and privilegesafforded
tothemundertheFourthandFourteenthAmendments.
98.
privilegesofcitizensoftheUnitedStatesandwereinjuredintheirpersonsandproperty.
99.
Defendantsareliableunder42U.S.C.1985(3).
100.
oflibertyincarcerationandimprisonment.
101.
dollarsincashandproperty.
102.
26
damages including but not limited to: embarrassment, indignation, anxiety, mental anguish,
nightmares, emotional distress, discomfort, pain, loss of weight, humiliation, outrage, shame,
fear, loss of income, damage to their professional reputation, damage to their reputation in the
community, denial of constitutional rights, and other injuries, damages or consequences related
totheincidentandDefendantsunlawfulconduct.
WHEREFORE, Plaintiff respectfully requests declaratory relief from this Honorable
Court as outlined above, and further requests judgment against all Defendants, jointly and
severally, for compensatory damages for whatever amount the jury finds necessary, and further
demands judgment against all Defendants, jointly and severally, for punitive damages in
whatever amount the jury finds necessary, in addition to all costs, interest, and actual attorney
fees pursuant to 42 U.S.C. 1988, and such otherrelief asthisHonorableCourtdeemsjust,and
equitableunderthecircumstances.
103.
COUNTIVSTATECLAIM
ETHNICINTIMIDATIONUNDERMCLA750.147b
ASTODEFENDANTOFFICERS
forth,herein.
104.
That this Court has jurisdiction over the allegations contained inthiscountunder
Under MCLA 750.147b, a person is liable for ethnic intimidation if that person
maliciously and with specific intent to intimidate or harass another because of that persons
27
Upon information and belief, Defendant Officers maliciously and with specific
intent caused physical contact with Plaintiffs for no other reason than those based on their
articulatedracialhatredtowardsArabs.
107.
theirethnicity,nationaloriginand/orreligiousbackground.
108.
Plaintiffs personal property, which included ransacking Plaintiffs store and home as further
discussed above and plead as to particularity as to time, placeandmannerbytheaccompanying
witnessAffidavits..
109.
forethnicintimidation.
110.
Defendant Officers are also liable for three times the actual damages pursuant to
MCLA750.147(b)(3)(a)andcostsandattorneysfeesforengaginginethnicintimidation.
111.
sufferedlossoflibertyincarcerationandimprisonment.
112.
thousandsofdollarsincashandproperty.
113.
damages including but not limited to: embarrassment, indignation, anxiety, mental anguish,
nightmares, emotional distress, discomfort, pain, loss of weight, humiliation, outrage, shame,
28
fear, loss of income, damage to their professional reputation, damage to their reputation in the
community, denial of constitutional rights, and other injuries, damages or consequences related
totheincidentandDefendantOfficersunlawfulconduct.
WHEREFORE, Plaintiff respectfully requests declaratory relief from this Honorable
Court as outlined above, and further requests judgment against all Defendants, jointly and
severally, for compensatory damages for whatever amount the jury finds necessary, and further
demands judgment against all Defendants, jointly and severally, for punitive damages in
whatever amount the jury finds necessary, in addition to all costs, interest, and actual attorney
fees pursuant to 42 U.S.C. 1988, and such otherrelief asthisHonorableCourtdeemsjust,and
equitableunderthecircumstances.
114.
COUNTVSTATECLAIM
FALSEARREST
ASTODEFEDANTOFFICERS
setforthherein.
115.
That this Court has jurisdiction over the allegations contained inthiscountunder
wrongfully, and without Plaintiffs consent and against his will, caused his arrest and deprived
Plaintiffs of their liberty, plead with particularity as to time, place and manner through the
accompanyingwitnessAffidavits.
29
117.
thefactualallegationsassetforthandoutlinedabove,asthoughfullysetforthherein.
118.
As a corroborating act to falsely arrest Plaintiffs, despite the fact that Defendant
This false arrest was malicious, willful, wanton, and demonstrated a reckless
disregard for Plaintiffs rights and was motivated by unmitigated racial hatred and a desire to
rid
theHamtramckcommunityofArabs..
120.
sufferedlossoflibertyincarcerationandfalseimprisonmentandwrongfulincarceration.
121.
AsaresultofDefendantOfficersillegalactions,Plaintiffssuffered lossoftens of
thousandsofdollarsincashandproperty.
122.
damages including but not limited to: embarrassment, indignation, anxiety, mental anguish,
nightmares, emotional distress, discomfort, pain, loss of weight, humiliation, outrage, shame,
fear, loss of income, damage to their professional reputation, damage to their reputation in the
community, denial of constitutional rights, and other injuries, damages or consequences related
totheincidentandDefendantOfficersunlawfulconduct.
WHEREFORE, Plaintiff respectfully requests declaratory relief from this Honorable
Court as outlined above, and further requests judgment against all Defendants, jointly and
severally, for compensatory damages for whatever amount the jury finds necessary, and further
30
demands judgment against all Defendants, jointly and severally, for punitive damages in
whatever amount the jury finds necessary, in addition to all costs, interest, and actual attorney
fees, and such other relief as this Honorable Court deems just, and equitable under the
circumstances.
123.
COUNTVISTATECLAIM
FALSEIMPRISONMENT
ASTODEFEDANTOFFICERS
forth,herein.
124.
That this Court has jurisdiction over the allegations contained inthiscountunder
becauseofPlaintiffsethnicity,nationaloriginand/orreligiousbackground.
127.
personallibertyandfreedomofmovement.
128.
ofHamtramckJailforfour(4)dayswithoutcharge.
129.
TheimprisonmentandrestraintswereagainstPlaintiffswill.
31
130.
physical force and the deprivation of Plaintiffs liberty and freedom was intentional, unlawful
and unprivileged and motivated solely based on articulated racial hatred towards
ArabAmericans..
131.
ofmovementbeingunreasonable,thecontinueddetentionwasexcessiveandunreasonable.
132.
sufferedlossoflibertyincarcerationandimprisonment.
133.
thousandsofdollarsincashandproperty.
134.
damages including but not limited to: embarrassment, indignation, anxiety, mental anguish,
nightmares, emotional distress, discomfort, pain, loss of weight, humiliation, outrage, shame,
fear, loss of income, damage to their professional reputation, damage to their reputation in the
community, denial of constitutional rights, and other injuries, damages or consequences related
totheincidentandDefendantOfficersunlawfulconduct.
WHEREFORE, Plaintiff respectfully requests declaratory relief from this Honorable
Court as outlined above, and further requests judgment against all Defendants, jointly and
severally, for compensatory damages for whatever amount the jury finds necessary, and further
demands judgment against all Defendants, jointly and severally, for punitive damages in
whatever amount the jury finds necessary, in addition to all costs, interest, and actual attorney
fees, and such other relief as this Honorable Court deems just, and equitable under the
32
circumstances.
135.
COUNTVIISTATECLAIM
ASSAULTANDBATTERY
ASTODEFENDANTOFFICERS
forth,herein.
136.
That this Court has jurisdiction over the allegations contained inthiscountunder
onPlaintiffsasfurtherdiscussedabove.
138.
Plaintiffsconsentasfurtherdiscussedabove.
139.
sufferedlossoflibertyincarcerationandimprisonment.
140.
thousandsofdollarsincashandproperty.
141.
damages including but not limited to: embarrassment, indignation, anxiety, mental anguish,
nightmares, emotional distress, discomfort, pain, loss of weight, humiliation, outrage, shame,
fear, loss of income, damage to their professional reputation, damage to their reputation in the
community, denial of constitutional rights, and other injuries, damages or consequences related
33
totheincidentandDefendantOfficersunlawfulconduct.
WHEREFORE, Plaintiff respectfully requests declaratory relief from this Honorable
Court as outlined above, and further requests judgment against all Defendants, jointly and
severally, for compensatory damages for whatever amount the jury finds necessary, and further
demands judgment against all Defendants, jointly and severally, for punitive damages in
whatever amount the jury finds necessary, in addition to all costs, interest, and actual attorney
fees, and such other relief as this Honorable Court deems just, and equitable under the
circumstances.
142.
COUNTVIIISTATECLAIM
GROSSNEGLIGENCEOFDEFENDANTOFFICERS
forth,herein.
143.
That this Court has jurisdiction over the allegations contained inthiscountunder
Plaintiffs injuries and damages, was grossly negligent because it was so reckless that it
demonstratedasubstantiallackofconcernforwhetherPlaintiffswouldbeinjured.
145.
arrest and detention, and Defendant Officers actions were perpetrated without having any
physical evidence or any probable cause that Plaintiff had committed, or was committing any
crime.
34
146.
Defendant Officers are also liable for plaintiffs injuries and damages under
MCLA691.1407(2).
147.
oflibertyincarcerationandimprisonment.
148.
thousandsofdollarsincashandproperty.
149.
damages including but not limited to: embarrassment, indignation, anxiety, mental anguish,
nightmares, emotional distress, discomfort, pain, loss of weight, humiliation, outrage, shame,
fear, loss of income, damage to their professional reputation, damage to their reputation in the
community, denial of constitutional rights, and other injuries, damages or consequences related
totheincidentandDefendantOfficersunlawfulconduct.
WHEREFORE, Plaintiff respectfully requests declaratory relief from this Honorable
Court as outlined above, and further requests judgment against all Defendants, jointly and
severally, for compensatory damages for whatever amount the jury finds necessary, and further
demands judgment against all Defendants, jointly and severally, for punitive damages in
whatever amount the jury finds necessary, in addition to all costs, interest, and actual attorney
fees, and such other relief as this Honorable Court deems just, and equitable under the
circumstances
35
150.
COUNTIXSTATELAWCLAIM
ABUSEOFPROCESS
ASTODEFENDANTOFFICERS
setforthherein.
151.
That this Court has jurisdiction over the allegations contained inthiscountunder
ulterior motives or personal reasons for the purpose of causing: Vexation Harassment Ethnic
and religious intimidation and suggested genocide Damage to Plaintiffs personal reputation
Damage to Plaintiffs community reputation andto enrichthemselvesthroughinappropriateuse
of State forfeiture laws Plaintiff to be unlawfully arrested and detained against his will and
Plaintifftobedeprivedofhisconstitutionallyprotectedrightsoffreedomandliberty.
153.
specifically realleges the factual allegations as set forth and outlined above, as though fullyset
forthherein.
154.
The allegations and misuse of the criminal investigatory process was improper
since Defendant Officers knew, or should have known, that the allegations and testimony
regarding Plaintiffs alleged actions were false and was falsified due to their articulated racial
hatredtowardsArabAmericans..
155.
36
false and fabricated allegations that initiated the criminal investigations, and as a direct and
proximate result of the conduct ofDefendantOfficers,referredtomorefullyabove,PlaintiffsR.
JoumaahandSabersufferedlossoflibertyincarcerationandimprisonment.
156.
thousandsofdollarsincashandpropertystolenfromtheirresidence.
157.
damages including but not limited to: embarrassment, indignation, anxiety, mental anguish,
nightmares, emotional distress, discomfort, pain, loss of weight, humiliation, outrage, shame,
fear, loss of income, damage to their professional reputation, damage to their reputation in the
community, denial of constitutional rights, and other injuries, damages or consequences related
totheincidentandDefendantOfficersunlawfulconduct.
WHEREFORE, Plaintiff respectfully requests declaratory relief from this Honorable
Court as outlined above, and further requests judgment against all Defendants, jointly and
severally, for compensatory damages for whatever amount the jury finds necessary, and further
demands judgment against all Defendants, jointly and severally, for punitive damages in
whatever amount the jury finds necessary, in addition to all costs, interest, and actual attorney
fees, and such other relief as this Honorable Court deems just, and equitable under the
circumstances
158.
COUNTXSTATECLAIM
CONCERTOFACTION
ASTODEFENDANTOFFICERS
setforthherein.
37
159.
That this Court has jurisdiction over the allegations contained inthiscountunder
intent to, and for the illegal or unlawful purpose of depriving Plaintiffs of their clearly
established constitutionally protected civil rights, as outlined above, by express or implied
agreement.
161.
to the generic similarity of such activities as produced and promoted by these Defendant
Officers.
162.
specifically reallege the factual allegations as set forth and outlined above, as though fully set
forthherein.
163.
the Defendant Officers, acted in concert to have Plaintiffs arrested without probable cause and
arrestedbasedonknowinglyfalsifiedandfabricatedevidence.
164.
38
outlined above, Plaintiffs Constitutionally protected rights were violated when Plaintiffs were
unlawfully subjected to an illegal search and seizure, wrongfully arrested, and wrongfully
imprisonedtherebydeprivingthemoftheirfreedomofmovement.
166.
sufferedlossoflibertyincarcerationandimprisonment.
167.
thousandsofdollarsincashandproperty.
168.
allofhisdamages.
WHEREFORE, Plaintiff respectfully requests declaratory relief from this Honorable
Court as outlined above, and further requests judgment against all Defendants, jointly and
severally, for compensatory damages for whatever amount the jury finds necessary, and further
demands judgment against all Defendants, jointly and severally, for punitive damages in
whatever amount the jury finds necessary, in addition to all costs, interest, and actual attorney
fees, and such other relief as this Honorable Court deems just, and equitable under the
circumstances. Due totheconcertofactionamongallofthevariousDefendants,eachisliableto
Plaintiff for these damages even if there was no direct relation to the activity conducted by that
particularDefendant.
39
169.
COUNTXISTATECLAIM
CIVILCONSPIRACY
ASTOALLDEFENDANTS
setforthherein.
170.
That this Court has jurisdiction over the allegations contained inthiscountunder
and for the illegal or unlawful purpose of depriving Plaintiffs of their clearly established
constitutionallyprotectedcivilrights,asoutlinedabove,byexpressorimpliedagreement.
172.
Plaintiff may not be able to identify all of the activities of Defendants due to the
genericsimilarityofsuchactivitiesasproducedandpromotedbytheseDefendants.
173.
specifically reallege the factual allegations as set forth and outlined above, as though fully set
forthherein.
174.
Defendants,conspiredtogethertohavePlaintiffsarrestedwithoutprobablecause.
175.
Defendants, conspired together to wrongfully arrest and imprison Plaintiffs against their will,
thereby depriving Plaintiffs of their clearly established constitutionally protected rights and
liberties.
40
176.
oflibertyincarcerationandimprisonment.
178.
dollarsincashandproperty.
179.
Defendants are jointly, severally and/or alternatively liable to Plaintiff for all of
hisdamages.
WHEREFORE, Plaintiff respectfully requests declaratory relief from this Honorable
Court as outlined above, and further requests judgment against all Defendants, jointly and
severally, for compensatory damages for whatever amount the jury finds necessary, and further
demands judgment against all Defendants, jointly and severally, for punitive damages in
whatever amount the jury finds necessary, in addition to all costs, interest, and actual attorney
fees, and such other relief as this Honorable Court deems just, and equitable under the
circumstances. Due totheconcertofactionamongallofthevariousDefendants,eachisliableto
Plaintiff for these damages even if there was no direct relation to the activity conducted by that
particularDefendant.
180.
COUNTXIISTATECLAIM
STATUTORYCONVERSION
ASTOALLDEFENDANTS
41
setforthherein.
181.
That this Court has jurisdiction over the allegations contained inthiscountunder
employees unlawfully accessed Plaintiffs residence and business and removed Plaintiffs
personal property, business property, and other items under the authorityofanallegedwarrant,
unlawfully obtained without having any physical evidence or any probable cause that Plaintiff
hadcommitted,orwascommittinganycrime.
183.
havebeensubjecttotheallegedwarrant.
184.
42
asserted dominion over all of the items found in Plaintiffs residence and business regardlessof
whowastheactualowner.
186.
dollarsincashandproperty.
187.
statutoryconversionunderMCL600.2919a.
WHEREFORE, Plaintiff respectfully requests declaratory relief from this Honorable
Court as outlined above, and further requests judgment against all Defendants, jointly and
severally, for compensatory damages for whatever amount the jury finds necessary, and further
demands judgment against all Defendants, jointly and severally, for punitive damages in
whatever amount the jury finds necessary, in addition to all costs, interest, and actual attorney
fees, and such other relief as this Honorable Court deems just, and equitable under the
circumstances.
188.
COUNTXIIISTATECLAIM
COMMONLAWCONVERSION
ASTOALLDEFENDANTS
setforthherein.
189.
That this Court has jurisdiction over the allegations contained inthiscountunder
43
employees unlawfully accessed Plaintiffs residence and business and removed Plaintiffs
personal property, business property, and other items under the authorityofanallegedwarrant,
unlawfully obtained without having any physical evidence or any probable cause that Plaintiff
hadcommitted,orwascommittinganycrime.
191.
propertywhichshouldnothavebeensubjecttotheallegedwarrant.
192.
asserted dominion over all of the items found in Plaintiffs residence and business regardlessof
whowastheactualowner.
194.
dollarsincashandproperty.
195.
44
commonlaw.
196.
property.
WHEREFORE, Plaintiff respectfully requests declaratory relief from this Honorable
Court as outlined above, and further requests judgment against all Defendants, jointly and
severally, for compensatory damages for whatever amount the jury finds necessary, and further
demands judgment against all Defendants, jointly and severally, for punitive damages in
whatever amount the jury finds necessary, in addition to all costs, interest, and actual attorney
fees, and such other relief as this Honorable Court deems just, and equitable under the
circumstances.
COUNTXIVSTATECLAIM
FRAUDANDMISREPRESENTATIONBYDEFENDANTOFFICERS
That this Court has jurisdiction over the allegations contained inthiscountunder
Plaintiff'slegalrights.
200.
DefendantOfficersrepresentationstoPlaintiffswerefalse.
Thomav.TracyMotorSales,Inc
, 360 Mich434,104N.W.2d360(1960)
RoheScientificCorp. V. NationalBank
of Detroit
, 133 Mich.App. 462, 350 N.W.2d 280
on rehg135Mich. App 777, 355 N.W2d 883 (1984)
Miller v.
Green,
37MichApp132,194N.W.2d491(1971).
5
45
201.
shouldhaveknown,thattheirrepresentationswerefalse,ormadetherepresentationsrecklessly.
202.
Defendant Officers made the representations to Plaintiffs with the intention that
Plaintiffsrelyonthem.
203.
astosufferinjuryanddetriment.
WHEREFORE, Plaintiff respectfully requests declaratory relief from this Honorable
Court as outlined above, and further requests judgment against all Defendants, jointly and
severally, for compensatory damages for whatever amount the jury finds necessary, and further
demands judgment against all Defendants, jointly and severally, for punitive damages in
whatever amount the jury finds necessary, in addition to all costs, interest, and actual attorney
fees, and such other relief as this Honorable Court deems just, and equitable under the
circumstances.
Respectfullysubmitted,
_/s/StevenA.Haney____________
StevenA.Haney(P63947)
HaneyLawGroup,PLLC
AttorneyforPlaintiffs
811SouthBlvd.,Suite210
RochesterHills,Michigan48037
517.614.2304
steve@haneygroup.net
_/s/MuneebAhmad
____________
MuneebM.Ahmad,Esq(P70391)
S.HussainAkbar,Esq(P67967)
AHMAD&AKBARLAW,PLLC
AttorneysforPlaintiff
900WilshireDrive,Suite202
Troy,Michigan48084
Tel:(248)5192313
46
Fax:(248)5192399
May18,2016
UNITEDSTATESFEDERALCOURT
EASTERNDISTRICT
RASOULJOUMAAH,anindividualGAYLE
JOUMAAH,anindividualAMJADSABER,
anindividualYOUSRAJALAL,anindividual
andSAMSTIRESHOP,aMichiganCorporation,
Plaintiffs,
CaseNo.
Honorable:
vs.
DETECTIVEJAMESMCMAHON,
Inhisindividualandofficialcapacity
DETECTIVEMICHAELSTOUT,
Inhisindividualandofficialcapacity
ANNEMOISE,ChiefofPoliceHamtramck,
Inherindividualandofficialcapacity
THECITYOFHAMTRAMCK
THECITYOFHIGHLANDPARKand
THE MICHIGAN AUTO THEFT PREVENTION
AUTHORITY(ATPA)aprivateentity
JointlyandSeverally,
Defendants.
______________________________________________________________________________
STEVENA.HANEY,SR.(P63947)
HaneyLawGroup,PLLC
AttorneyforPlaintiffs
811SouthBlvd.,Suite210
RochesterHills,MI48037
(517)614.2304
steve@haneygroup.net
MuneebM.Ahmad,Esq(P70391)
S.HussainAkbar,Esq(P67967)
AHMAD&AKBARLAW,PLLC
AttorneysforPlaintiff
900WilshireDrive,Suite202
Troy,Michigan48084
Tel:(248)5192313
Fax:(248)5192399
47
______________________________________________________________________________
DEMANDFORJURYTRIAL
NOW COME
, Plaintiffs, Rasoul Sam Joumaah, an individual Gayle Joumaah, an
individual Amjad Saber, an individual Yousra Jalal, an individual and Sams Tire Shop, a
Michigan Corporation, through their attorneys, Steven A. Haney, Sr. of the Haney Law Group,
PLLC, and Muneeb M. Ahmad and Syed Hussain Akbar, of Ahmad & Akbar Law, PLLC, and
herebydemandsaTrialbyJuryoftheabovereferencedcauseofaction
Respectfullysubmitted,
_/s/StevenA.Haney____________
StevenA.Haney(P63947)
HaneyLawGroup,PLLC
AttorneyforPlaintiffs
811SouthBlvd.,Suite210
RochesterHills,Michigan48037
517.614.2304
steve@haneygroup.net
_/s/MuneebAhmad
____________
MuneebM.Ahmad,Esq(P70391)
S.HussainAkbar,Esq(P67967)
AHMAD&AKBARLAW,PLLC
AttorneysforPlaintiff
900WilshireDrive,Suite202
Troy,Michigan48084
Tel:(248)5192313
Fax:(248)5192399
May18,2016
48