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STEPHEN DEAN,
PLAINTIFF
V.
OFFICER RYAN HOFFMAN,
OFFICER CHILES,
OFFICER GRIMES,
OFFICER WYLAN,
OFFICER D. NEY,
LT. JOHN DOE,
SGT. JOHN DOE,
ALL DEFENDANTS ARE SUED IN
THEIR INDIVIDUAL AND OFFICIAL
CAPACITIES,
DEFENDANTS
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
99-7507 CIVIL TERM
ORDER OF COURT
AND NOW, this day of December, 1999, plaintiff may proceed
in forma pauperis without paying the filing fee with the Prothonotary or a service fee for
the Sheriff. The Sheriff shall serve the complaint against defendants.
By the Court,
Stephen Dean
D-K6081
Al 635
10745, Route 18
Albion, PA 16475-002
Edgar B. B"y, J.
-. ,rrjd-
is-U/-99
RKS
saa
. . I.
DEC 17 1999PP
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
STEPHEN DEAN,
PLAINTIFF,
-against-
OFFICER RYAN HOFFMAN,
OFFICER CHILES,
OFFICER GRIMES,
OFFICER WYLAN,
OFFICER D.NEY,
LT. JOHN DOE
SGT. JOHN DOE,
all Defendants are sued
in their individual
and official capacities.
DEFENDANTS
No. -99 -707
et;0
MOTION TO PROCEED IN FORMA PAUPERIS
PURSUANT TO 42 Pa. R. Civil Procedure
Rule 240
1. I am the Plaintiff in the above matter and because of
my financial condition am unable to pay fees and costs of
litigating this action.
2. I am unable to obtain funds from anyone, including my
family and associates, to pay the costs of litigation.
3. I represent that the information below relating to my
ability to pay the fees and costs is true and correct:
a) Name: Stephen Dean, Plaintiff
Address: S.C.I. Albion
10745 Route 18
City/State: Albion Pa 16475
SSN-
b) Employer:
None.
Only income is prison wages of .
Work as a Janitor on my housing
Gross monthly pay 22.80 a month.
K
c) Other income within the past twelve months:
I do not own or have any business interest.
I am not self-employed .
Interest: None
Dividends:None
Pension & Annuities: None
Social Security Benefits: None.
Support Payments: None
Disability Payments: None.
Unemployment: None.
Workman Comp.: None.
Public Assistance: None
Other: None.
d) Other Contributions to Household Support: None
Wife: None.
Contribution from or to children: None.
I do not have any living children.
My mother and father are now deceased:
e) Property owned:
w„
Cash: None.
Checking account: None.
Savings account: None.
C/D's None.
Real Estate (including Home): None.
Stocks and Bonds: None
Other: None.
f) Person dependent on my support: None.
I have no family to depend on my support.
g) Debts and obligations:
Plaintiff owes Fines,Costs and Restitution.
4. I understand that I have a continuing obligation to inform
the court of my improvement in my financial circumstances which
would permit me to pay the cost incurred herein.
5. I verify that the statements made in this motion to
Proceed In Forma Pauperis are true and correct. I understand
that the false statements herein are made subject to penalties
of 18 Pa C.S. § 4904, relating to unsworn falsification to
authorities.
Dated:,. l _
P over Pro
Se.
(
r'
DEC 17 1999 (Do
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA
CIVIL DIVISION
STEPHEN DEAN,
PLAINTIFF,
-against-
OFFICER RYAN HOFFMAN,
OFFICER CHILES,
OFFICER GRIMES,
OFFICER WYLAN,
OFFICER D.NEY,
LT. JOHN DOE
SGT. JOHN DOE,
all Defendants are sued
in their individual
and official capacities.
DEFENDANTS
MOTION TO PROCEED IN FORMA PAUPERIS
PURSUANT TO 42 Pa. R. Civil Procedure
Rule 240
No._.
1. I am the Plaintiff in the above matter and because costs of
my financial condition am unable to pay fees and litigating this action.
2. I am unable to obtain funds from anyone, including my
family and associates, to pay the costs of litigation.
3. I represent that the information below relating to my
ability to pay the fees and costs is true and correct:
a) Name: Stephen Dean, Plaintiff
Address: S.C.I. Albion
10745 Route 18
City/State: Albion Pa 16475
SSN-
b) Employer:
None.
Only income is prison wages of .19,r an [four.
Work as a Janitor on my housing unit.
Gross monthly pay 22.80 a month.
c) Other income within the past twelve months:
I do not own or have any business interest.
I am not self-employed .
Interest: None
Dividends:None
Pension & Annuities: None
Social Security Benefits: None.
Support Payments: None
Disability Payments: None.
Unemployment: None.
Workman Comp.: None.
Public Assistance: None
Other: None.
d) Other Contributions to Household Support: None
Wife: None.
Contribution from or to children: None.
I do not have any living children.
My mother and father are now deceased:
e) Property owned:
Cash: None.
Checking account: None.
Savings account: None.
C/D's None.
Real Estate (including Home): None.
Stocks and Bonds: None
Other: None.
f) Person dependent on my support: None.
I have no family to depend on my support.
g) Debts and obligations:
Plaintiff owes Fines,Costs and Restitution.
4. I understand that I have a continuing obligation to inform
the Court of my improvement in my financial circumstances which
would permit me to pay the cost incurred herein.
5. I verify that the statements made in this motion to
Proceed In Forma Pauperis are true and correct. I understand
that the false statements herein are made subject to penalties
of 18 Pa C.S. § 4904, relating to unsworn falsification to
authorities.
Dated:
P itioner Pro
Se.
Y
Qr
F.
Cl.
V1 1 N -3
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DEC 171999th
iN :IIS wURT Cr CD.?:1•iJ;1 PLEAS OF CU,'173EaLAND COU:iTY, P•r"4NSYLVA-.-,IA
CIVIL DIVISION
STE?HEN
)
OFFICER CHILES, 0
OFF 7 ER ifYL",.:, J
LT. JOIN'." D'JL, J
JVi. JQ.Iii .DOE, J
all Defendants are sued )
3n- JY i.a21 CaEaClticb. )
DEFENDANTS J
NOTICE TO DEFLNO
i?L?,? •': i
-dgalnui.-
'rc THE ABOVE DEFFI-MALITS:
No. g 9 . Z?02 61tf:D
You have b•a,-n su_d in court. if you wish to da_-and against
' 'tn:: Clali:l5 Sv?t forth in the following pages you IIIUSt Ca,- dCti00
within twenty (20) says after this Complaint any Notice are
s=-yoU, by entariay 3 written appearance i:ersoualiy or by
2ttOrn-?y and filing ::l th the Court your defenses or objections
to the claims sat forth against you. You are warned that if
,ou fail to do so, the case may proceed without you and a
juuy.nent ;;;ay be entered against you by ti:e Courc without further
l:o;;ica for any ,:lon•=_y claim-ad in the Complaint or for an;? other
' Clam or L.iiaf ra?y U.T.3tf-" :jj' t!1(. Plaintiff. 20U 1:%lf 10:;-a money
cr ;:rt:._rL•y or other rights important to you.
T HL O-r '1Dc SET :0,11!ii .3 i:Lli%] i0 FIND i7ilERE YOU CAii VE'P LEGAL NLLP.
YCiJ TF.nB S7ilZS PAPER TO -LCiit2 LAWYl;? AT O."ICR. IF YOU
DO NOT 3a1w. A fi,wYEic OR CANNOT AFr^ORD ONE, GO TO OR Tr,LEP40cJE
Court Administrator
Laulor:, R•_fa^ral 3zrvico
ycl: Fl Cul„borlard County Courtnouz;3
Carlisle Pa 17013
L:7
IN THE COURT OF COd,10N PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
,
ST N EA. ,
Plaintiff,
-against-
CIVIL DIVIS.CON
OFFICER RYAN HOFFMAN,
OFFICER CHILES,
OFFICER GRIDIES,
OFFICER WYLAN,
OFFICER D, NEG,
LT. JOHN DOE AP1D,
SERGEANT JOHN DOE, (both
LT, n Sgt will be na; ied
upon discovery of their names)
Defendants are sued in
both their
individual and of?icial
capacities.
DEFENDANTS.
1
I
I
No.
Complaint
+Y" riiea oy Stephen Dean, a state prisoner,
for monetary damages and other relief. Plaintiff is alleging
Excessive Use Of Force and denial of medical care and confinement
in segregation. The Plaintiff also alleges the torts of assault
and battery and negligence.
PARTIES.
1. The Plaintiff, Stephen Dean, was incarcerated at S.C.I.
Camp Hill during the events described in this compliant.
2. Defendant Officer Ryan Hoffman , is a correctional officer
employed at S.C.I. Camp Hill, he is sued both in his official
and individual capacities.
3. Defendant Officer Chiles is
at S a correctional officer empoyed
.C.I. Camp Hill and he is
indi v idual capacities sued in both his official and
.
4. Defendant Officer Grimes is a correctional officer
employed at S,C.I. Camp Hill and he is sued in both his official
and individual capacities.
5. Defendant officer Wylan a correctional officer employed
at S.C.I. Ca,up Nil he is sued in both his official and individual
capacities.
6. Defendant officer D. Neg is a correctional officer at
S.C.I. Carp Hill and he is sued in both his official and
individual capacities.
7. Defendant officer Writ is a correctional officer employed
at S.C.I. Camp Nil and he is sued in both his official and
individual capacities.
B.Defendant Lt. John Doe is a correctional officer employed
at S.C.I. Camp Hill in charge of Administrative Segregation
Unit at S- C.1. Camp Hill he is sued in both his official and
individual capacities.( His name is presently unknown to
plaintiff.)
9. Def:andant Sgt. John Doe is a correctional officer second
in command in the Administrative Segregation Unit at S.C.I.
Camp Hill and he is sued in both his official and individual
capacities.
10. All Defendant have acted, and continue to act under color
of state law at all times relevant to this complaint.
FACTS:
11. on or about November 11, 1457, Stephen Dean, (harain
after called Plaintiff), was removed from the general population
at S.C.I. Camp Hill and placed in Restricted Housing Unit for
Threatening an employee or their family with bodily harm.
12. Defendant Hoffman wrote a misconduct stating Plaintiff
said he was
going to bust the Co`s Head like d Fuckin '-.ppla. Defendant
Hoffman continued on with his count and after completing his
count he wrote the Plaintiff a misconduct for caking tha
s tataten t.
13. Plaintiff states that the misconduct is not true and
that it was over the use of the telephone.
14. Plaintiff states that he requested to use the telephone
and he informed Defendant Hoffman that it was top tiers time
for telephone calls and Plaintiff then ask Defendant Hoffman
if he could make his call at approximately 7:45 P.M. and was
instructed to have a seat.
15• At approximataiy
Hoffman ana
k 7:50 Plaintiff went to De.'•ordant
as
if ha
Hoffman an^
ril
st
d " could use the telephone and Defendant
,.
y
aa
Plaintiff
the
Go to
your Fuckin cell and
lock it up"
n ;.rant to
lc."ed
his
-
If his C CU Without to
=th.r
argament and
-
in his ce
::! ll.
16. After the 9: P.M. Count Defendant Hoffman came to the
Plai`tif:% call and, requested his Idertific.ation card and
plaintiff -7tsr, cri,y
he wanted his Id card and :'Defendant F:offn:an
maid i'll find souething and walked away.
17. P.90 ro:a:aaIa Iv 9:30 P.M. Several officers cI,aa to
Pla.iatiffs ce1.1 and said stand and face the %;all an he was
cuffed and lead t•o the Restricted Housing Unit (Herein after
callr_d P,H(1) .
la. While being escorted to the R:?U ona of the office;:s stated
you are 35 feet fro,", death.
19.
door wh Upon
et
it arrival at the RHU Plaintiff was standing at the
,
insida tha was oPen
d--or and ed by Def3ndant Griaas who pulled Plaintiff
sl
-
d
choking
iiim
>,hil= a.
nme
him a ainst t
;till han,3cuff d behi
d hi
??b
,
officer
stated that n
s
ack
you are on my turf now and you do and
the
h
say, w
at I
20- Plaintiff was then ordered to remove
o'c` he '=TCV- his clothing Defendant crimes
and hit the Plaintif!: across hi.o bacl: and head
officers started to beat the Plaintiff until
Plaintiff was then dragged to cell 11-12 wN
in the cell and left bleeding on the floor,
his clothing and
to a Night Stick
and other unknown
he past cut and
ra he was thrown
21. On or about Ncv-amber 22, 1997 Plaintiff received another
misconduct for refusing to obey a direct order this misconduct
was for yelling for help to call a nurse but Defendant Chiles
and Defendant Vey refused to call a nurse for medical treatment.
22. Plaintiff was yelling
officers because l:a nesdau help several
came to Plaintiff's
he did
t cell and told Plaintiff that if
no
shut the fuck ui; ha
and Cet
ondat Lt
John D wcald receive anoti
,..r a z:;
bating
-
oe took
another ass kicki
i his mattress and said ne-t time
ng
s in order .
23- On or about December 11, 1797 plaintiff nmceive;; anot!or
misconduct and Defaadants Ney and Defendant (•7ylan was trying
to Prcvo:;a Plaintiff into ar. argument because th--y n=eeded to
kick some as3 for training na::t weak since plaint would not
fall for their 'Nays of doing things they wrote a ;aisconduct,
3
24. Throughout ttl:! course of the aforemantioned incidents
the Date,-'Cants H.]_'frian, Chiles, Grime, Wylan, Ney, U.Doe,
and Sgt. Doe 'iid conmit Aggravated Assault, Negligence, and
Nogligence of duty in that:
a) The Defendants did attempt to cause and did
intentionally, knowingly, and recklessly, under circumstances
manifesting .:areaa irdifferenca to thz value of hum-an lifa
Wile:, they a.at Plaintiff until he rasszd out.
b) The Defendants did intentionally, knowingly, and
recklessly tlgg as a cznumcn ozactice a beating to control innatez
w*ho are sent to ch -:Z';" and Pailing to i!:v2sti;ot: t::e matter
of the misconduct.
c) Ta•z Defendants -lid intentionally and knowingly conspire
to beat inmat:aa upon their arrival to th_ PHU.
u) Tara De!andan is aid intentionally , knowingly, have total
disrega rd for a human life in failing to go by the DOC Rules
on use of forgo.
e) ?b? J?fe_d..nts did irtantionally and knowingly cisragard
caZlio]y 5::r a! zdical help t -a negligonca plaoad the Plaintiff's
llf? in :inns!- by juzt throwing hi:a in a cell.
25. The aforementioned acts took place in cumberland county,
Pennsylvdnia.
26. Oeft l]:ia itB Lt. Doe and Sgt. Doe failed to intervene in
the i;+atiag and seeking radlical treat:ient for the Plaintiff
thereby failing to fulfill their professional responsibility
for the aafaty of the Plaintiff in that:
a) The Defendants co!amitted thz assault upon the Plaintiff
thereby in violation of 18 Pa. C.S. §
27. As a result of the aforementioned actions of the
Defendants the Plaintiff, Stephen Dean was injured in the
following, respect:
a) Tn%a ?lai!itifr now sufi_rs from physical meatal probleans.
b) Plair.titr suftars with IIeadacne aad vision rzoolaais.
3b. As a direct result of the Defendants actions, the
Plaintiff has incurred and suffered the folio-wing:
a) Compi_cc loss of wages.
b) Prmuncnt and L•ettpc_srl physical pain and suffaring,
and the mental anguiz] the Plaintiff will continue to suffer
indefinately.?
Ci7 1
29. Ths acts of the Defendants as aforementioned have
inflicted :_,rious m ntal and physical anguish upon the Plaintiff.
These acts a_--a claar violations of the laces governing this
Commonwealth and t:7 United States Constitution and in such
F. nature that +_ <;s tha adardincy of punitive damages against
the Dafandaat in tha amount of Tivehundred Thousand Dollars
($500,000) and compe+:satory damages in the amount of one million
dollar (s1S00,OCj) fr„r., each Defendant.
S• KER FOR:3, Ease,4 upon the forgoing complaint the Plaintiff prays
this Honorable Ccurc will enter a judgment against all the
Defendants in 'loth for punitiva and ccc:..?n:;atcry dar: Gres.
Resgectful_y subadtt_3
'i 2 Z I? C N T - O N
i Stephan Dean, do hereby verify that the statements
contained in the cc;iolaint are true and correct to the best
of my knosledge, information and belief.
Thes> stat=pants are maw= _=ubject to th=- penalties set forth
in title 10 Pa C.S.A 24904 relating to unsworn falsification
to authorities.
o d 4 Johnson.Pro Se
5
V-E-R-I-F-C-A-T-I-0-N
I Stephen Dean, this 4th day of December 1999, hereby verify
that the statements contained in the above entitled complaint
are true and correct to the best of my knowledge, information
and belief.
These statements are made subject to the penalties set forth
in title 18 Pa C.S.A. § 4904 relating to unsworn falsification
to orities '.
Sr hen Dean Pro Se
L
H- :
'
.n -yo
DEG 1 7 1999 P
IV `:MZ :.vURT Cr' i 0.'-`:i•1?c1 PLEAS OF CU213ERLAND COUNTY, PSYNSYLVArlIA
-againat-01 7 . 7
O??ICER CFILES,
O?F ICS,." V - . i:IL•"
.J'
OFFICER iYY' ^
LT. TJIit! DO::,
all Daf?-ndants ar_e sued
in tneir ltnl J-1; IdLa is
3.1u JZf icagy Cit?.Lo
?..?1r? lYT-
l
TO THE ABOVE DEFF_1DA[iTS:
CIVIL DIV1JIUui
)
)
)
i
I
0
0
No. 99- Z-0 Mj
)
)
)
)
)
)
)
TRUE COPY FROM, RECORD
in Tes>;O.mony whorM, i Kara unto set my Dana
NO'T"E TO DEi Zi1;D and the $% of sari Ccut at Cariiskr, Pa.
Thi e? 19?
r?rclncri :?? v
You hac::a b•-ari yu_d in court. if you wish to de_en1 a-
?ainst
ciaillz s,t fvit}I In }rile following pages you must to r°_ action
'within twenty (20) days after this Complaint and Notice are
so-vedr by entarin- a :written a
attoraay and fil r ng r.t!th the Court your pc rsorlaliy or by
Your oefen es or objections
to tha clallls s_t forth acainst you. You are warned that if
you fail to do so, the case may proceed without you and a
ju;;yment c:ay be eritorad against you by tie Court without further
totica fec non-ay claimad in
the Gcmplainc or for any other
claim or r_liaf ra.;ua,ted :;y the Plaint ifc. You say laso money
ar ;'rcu=rty or ott::r rights important to you.
'1CiJ u`-iOULD Tiki E THIS PAPER TO TOUR LAWYE?. AT ONCF;. IF YOU
Dv NOT -iA V = A LAc4YZ R OR CANNOT AFFORD ONE, GO TO OR T)MEPHONE
PHn 0•r 'IC, SET F O ZPi} 33L06 10 F 114D -,)HIRE YOU CAN GET LEGAL iiELP.
Court Administrator
La+yocz H-.f.rral 3_tvic--
4t}1 F1 Cur.:borland Ccuaty Courtnouso
Carlisle Pa 17013
. i.3/.s
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
#ZN D
Plaintiff,
-against-
CIVIL DIVISION
OFFICER RYAN HOFFMAN,
OFFICER CftILES,
OFFICER GRIMES,
OFFICER WYLAN,
OFFICER D, NEG,
LT. JOHN DOE AND,
SERGEANT JOHN DOE, (both
LT.& Sgt will be named
upon discovery of their names)
Defendants are sued in
both their
individual and official
capacities,
D-FENDANTS.
I
I
I
No.
Complaint
This is a civil filed by Stephen Dean, a state prisoner,
for monetary damages and other relief. Plaintiff is alleging
Excessive Use of Force and denial of medical care and confinement
in segregation. The Plaintiff also alleges the torts of assault
and battery and negligence.
PARTIES:
1. The Plaintiff, Stephen Dean, was incarcerated at S.C.I.
Camp Hill during the events described in this compliant.
2. Defendant Officer Ryan Hoffman , is a correctional officer
employed at S.C.I. Camp Hill, he is sued both in his official
and individual capacities,
3. Defendant Officer Chiles is a correctional officer empoyed
at S.C.I. Camp Hill and he is sued in both his official and
individual capacities.
4. Defendant Officer Grimes is a correctional officer
employed at S.C.I. Camp Hill and he is sued in both his official
and indiviaual capacities.
5. Defendant officer Wylan a correctional officer employed
at S.C.I. Camp Hil he is sued in both his official and individual
capacities.
6. Defendant officer D. Neg is a correctional officer at
S.C.I. Ca:p 9111 and he is sued in both his official and
individual capacities.
7. Defendant officer Writ is a correctional officer employed
at S.C.I. Camp Hit and he is sued in both his official and
individual capacities.
B.Defendant Lt. John Doe is a correctional officer employed
at S.C.I. Camp Hill in charge of Administrative Segregation
Unit at S.C.I. Camp Hill he is sued in both his official and
individual capacities.( His name is presently unknown to
plaintiff.)
9. Defendant Sgt. John Doe is a correctional officer second
in command in the Administrative Segregation Unit at S.C.I.
Camo Hill and he is sued in both his official and individual
capacities.
10. All Defendant have acted, and continue to act under color
of state law at all times relevant to this complaint.
FACTS:
11. On or about November 11, 1997, Stephen Dean, (harein
after called Plaintiff), was removed from the general population
at S.C.I. Camp Hill and placed in Restricted Housing Unit for
Threatening an employee or their family with bodily harm.
12. Defendant F_offman wrote a misconduct stating Plaintiff
said he was
going to bust the CU`s Head like d Euckiit Fppl.e. Defendant
Hoffman continued on with his count and after completing his
count he wrote the Plaintiff a misconduct for making the
s tat. ten t.
13. Plaintiff states that the misconduct is not true and
that it was over the use of the telephone.
14. Piaintiff states that he requested to use the telephone
and he informed Defendant Hoffman that it was top tiers time
for telephone calls and Plaintiff then ask Defendant Hoffman
if he could make his call at approximately 7:45 P.M. and was
instructed to have a seat.
7
- err - = :... ari: o t: ??.'M"??
Ho=flan At :app_oxi:uataly 7:50 ^-. 1. Plaintiff v; r_t to Defendant
z, ask if :la could use the telephone and Defendant
Hoffman an .rily static: " Go to your Fuckin cell and lock it up"
Plaintiff than want to his cell without xuxthaa argument and
his solf in his cell.
16. Attar the 9: P.M. Count Defendant Hoffman came to the
plairltifV'& call and. requested his L_ aa-,.`?
Plaintiff a. ifioation card and
x wiy he canted his Id card and :?efendant •r'offman
Said i'll fire son:e*_hing and walked away.
17. PPorovi.natal_v 9:30 P.PI. Several o_ficers capa to
Plaintiffs call and said stand and face the wall and he was
cuffec an•1 lead &,,) the Restricted Housing Unit (Herein after
called Pffu).
id. tdhila being escorted to the :?U one of the offices stated
you are 35 feet from daath.
19. Upon arrival at the RHU Plaintiff was standing at the
door when, it was opined bl- Defsndant Gri,,,e, who dulled Plaintiff
in5i.'..^. tta d--Or and 3ii3.iL-1a,' tint against the g.3.te and stilted
choking hirl ;,his : ila still han cuffad behind his bac2: and the
OJUicer stated that you are on my turf now and you do what I
say.
20. Plaintiff was then ordered to remove
Once ho his clothing and
r-movo his
and hit the Plaintif clothing Defendant crinlas
f to a Night Stick.
officers started to acroaz his back and hzad
beat the Plaintiff and other unknown
Plaintiff was then until
dragged to cell I-12 whe ha
re past cut and
h
in the cell and left
bleeding on the floor. e was thrown
21 • On or about November 22, 1997 plaintiff racaived another
misconduct for refusing to obay a direct order this misconduct
was for yelling for help to call a nurse but Defendant Chiles
and Defendant vey refused to call a nurse for medical treatment.
22. Plaintiff was yelling tecausa he neadou help several
officers came to Plaintiff's cell and told Plaintiff that if
he did not shut tn,a fucR up h-a would receive aloha: ass baltiag
and Oefondat Lt.John Doe took his ,nattrass and said neat t!..qa
anotner ass kicking is in order.
25, On or about December 11, 1597 lainti_f
:
ml:i CClnd UL't a[iG Ddf2nddnts ^ racr_ivC& anotllcr
lay and De..endaczt Wvlan was trying
to prcvolcn Plaintiff into an argument because th,ay needed to
kick some a33 for training n9-,:t weak since plaint would not
fall for their ways of doing things they wrote a ;:lisconduct.
3
24_ Throughout the: course of th.'_ aforementioned incidents
tha L'efc,:uants Chiles, Grimes, Wylan, Ney, Lt.Doe,
and Sgt. :oa did conmit Aggravated Assault, Negligence, and
Dlogligence of duty in t8at:
i) The Defendants did attempt to cause and did
intentior.:Ally, knowingly, and recklessly, under circumstances
manifesting ::::tress indiffereaca to thn value cf human life
WhB." tl:ey a. t Plaintiff until he passad oLi:.
b) The Defendants did intentionally, knowingly, and
recklessly li3B .i•s a .:mlmon ;practice a beating to control irl,uatez
Who :ire Sent to cite -1-3 and failing to invastiga:;a t::e ;natter
of they Ira S:cOl;f%`: L't.
c) Zia Defendants 1d intentionally and knowingly conspire
to beat inmatas upon their arrival to the F.HC'.
c?) lira Da_endan*_s did intentionally, knowingly, 'lava total
disreyarcl for a human life in failing to go by the DOC Rules
on use of force.
e) ^be Jaffa _dantu die intentionally and knowingly u' 'orC
i g
-n ril
calliai x-ad.ic_l help t h,2 a_gligenca pla:.ed the Plaintiff's
1±'? in dan ,a_ by ju t throwing hies is a ti ll.
25. The aforementioned acts took place in cumberland county,
Pennsylvdn-La.
sV. Dvf i;ti:i?id is [i Lt. 3oa and Sgt. Dove failed to inte'rvane in
the 1;-aatiag and Eeoking maeical treataent for the Plaintiff
thereby failing to fulfill their professional responsibility
for thr. uafaty of the Plaintiff in that:
a) The Defendants committed tha assault upon the Plaintiff
thereby in violation of 18 2a. C.S. y
27. As a result of tha aforementioned actions of the
Defendants the Plaintiff, Stephen Dean was injured in the
following rasooct:
a) Tile ?laintiff now suffers from physical meacai problems.
b) Plaintlft suttars with neadacne and vision proolems.
28. As a direct result of the Defendants actions, the
Plaintiff haS• incurred and suffered the following:
a) Cora?latc loss of wages.
b) Pe_ral:enl• anti ter,•porary physical pain and suffering,
Ind the illeatal anguisii the Plaintiff will continue to suffer
indefinately.
.? 1
29. -rh•: acts of the Defendants as a fora.nention,6 have
inflictSe s:irious ra ntal and physical anguish upon the Plaintiff.
These acts a_e ciaa:. violations of the laws governing this
Co,L.unonwealth and the Unite,'. States Constitution arid in such
.
e.•i7ature ti:,_t r:::j;:4?-s the awardinc: of punltive damages against
th= Defendant in"
n th3 amount of Fivehundred Thousand Dollars
($500,000) and eonparsatory damagas in tha amount of one million
dollar (iiv"00 0;•^
..) fr.;m sac:, DeEanda:,t.
'''f ?? u-'•?? Based upon the forgoing complaint the Plaintiff prays
this 3onorable Courc will enter a judgment against all the
Defendants in for =unitiva and ccr.:.-,sn:,atcry damafies.
Rsgectfaliy saba;itta.d
Dat_d•
C T I 0 N
1 Stephan Dean, do hereby verify that the statements
contained in the ccraolaint are true and correct to the best
of my knoaladge, information and belief.
Theca stat_nants ar3 mane -'ubject to the panalties set forth
_n Title 1d Pa C.S.A -S9904 relating to unworn falsification
5
®NS...?n,.wM' rwr. a mow..
to authoriti,-a.
V-E-R-I-F-C-A-T-I-0-N
I Stephen Dean, this 4th day of December 1999, hereby verify
that the statements contained in the above entitled complaint
are true and correct to the best of my knowledge, information
and belief.
These statements are made subject to the penalties set forth
in title 18 Pa C.S.A_ § 4904 relating to unsworn falsification
to thorities.
S hen Dea Pro Se
P_c-