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UNITED STATES DISTRICT COURT

DISTRICT OF CONNECTICUT

LOURDES NEGRON :

VS. : CIVIL ACTION NO.

MICHAEL ORTIZ : APRIL 21, 2008

C O M P L A I N T

1. This is an action to redress the deprivation of rights secured to the

plaintiff by the Constitution and laws of the United States and the State of

Connecticut.

2. Jurisdiction of this court is invoked under the provisions of Sections

1331, 1343(3) and 1367(a) of Title 28 and Sections 1983 and 1988 of Title 42 of

the United States Code.

3. The plaintiff is an adult citizen of the United States who resides in New

Haven, Connecticut.

4. During all times mentioned in this action, the defendant was an officer

in the New Haven Police Department acting in his official capacity. He is sued,

however, only in his individual capacity.

5. During all times mentioned in this Complaint, the defendant was acting

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under color of law, that is, under color of the constitution, statutes, laws, rules,

regulations, customs and usages of the State of Connecticut.

6. On June 4, 2005, in the vicinity of Grand Avenue and Poplar Street in

the City of New Haven, at approximately 2:53 in the afternoon, the plaintiff with

many other citizens was participating in a Puerto Rico Day parade on Grand

Avenue.

7. At said time and place the defendant arrested the plaintiff for sounding

the horn of her vehicle, as many were doing in the parade.

8. In the course of his said arrest of the plaintiff, the defendant viciously

kicked, struck and hit her, particularly kicking her in the area of her legs and feet

despite the fact that she had only two months earlier undergone major surgery to

correct bilateral congenital foot deformities and at the time the defendant

assaulted her she was status post right and left triple arthrodesis.

9. The defendant thereafter violently took the plaintiff into physical

custody, handcuffing her so tightly that she suffered brusing to her arms and

wrists.

10.. As a result, the plaintiff suffered great pain, physical injury, fear and

emotional distress.

11. In the manner described above, the defendant inflicted unreasonable

force upon the plaintiff in violation of the Fourth Amendment to the United States

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Constitution as enforced through Sections 1983 and 1988 of Title 42 of the

United States Code.

WHEREFORE, the plaintiff claims judgment against the defendant for

compensatory damages, punitive damages, attorney fees and costs.

The plaintiff claims trial by jury.

THE PLAINTIFF

BY:JOHN R. WILLIAMS (ct00215)51 Elm StreetNew Haven, CT 06510203.562.9931

Fax: 203.776.9494jrw@johnrwilliams.comHer Attorney

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