,:
1 .aw Office of JOE C. HOPKINS
OE C. HOPKINS - BarNo. 105850
2 541 North Lake Avenue
ksadena, California 91104
3 :el: [626] 398-1194
kc (6261 798-3282
4
5 ,aw OffIce of John E. Sweeney
OHN E. SWEENEY - Bar No. 116285
6 `ORTASHA R. MOORE - Bar No, 201986
115 South BeverIy Drive, Suite 305
7 Beverly Hills, California 902 12
:el: [310) 277-9595
8 bx: [310] 277-0177
p ItForneys for Plaintiffs
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: -.; I UNITED STATES DISTRICT
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...I14 DONOVAN JAC IKSON, a yinor, gog$ fj~Sbj$).~+-.----
15 bh,*..,I.. h;cl ,-w..n
uddian ad litem
k%$%~~i="O~Y CHAVIS, indkidually, j
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Plaintiffs, 1
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SNIPPETS:
violation of the 197 1 Civil Rights Enforcement Act, as amended, includiq 42 U.S. C.
California and hresently resides in Los Angeles County.
11 DONOVAN JACKSON, and is the duly appointed guardian ad litem of DONOVAN
19 and BIJAN DARVISH are an INGLEWOOD police officers.
24 and is the public employer of the deputy sheriffs named as defendants in this action.
26 as unknown other named defendants, Plaintiffs will amend this complaint to allege
injuries and damages by reason of negligence, careless, deliberately indifferent,
otherwise causing the incident, conditions and circumstances hereinafter set forth, or
22 at the intersection of Century Boulevard and Freeman, in Inglewood, Cd ifomia.
26 Los Angeles County Sheriffs deputies, sued herein as unknown named Mendants,
violently assaulted plaintiff COBY CHAVIS,
At all times mentioned herein, defendants INGLEWOOD and COUNTY employed the individual
Said defendants provided thleir individual defendant employees and agents with official
I them, separately and in concert, acted under color and pretense of law, under color of the
Each of the individual defendants here, separately and t in concert, deprived plaintiff of
21)y COUNTY's and/or INGLEWOOD's deliberate indifference to the maintenance,
officers' unjustifiable assault and battery of DONOVAN JACKSON,!mnd COBY
14 known of the fact that these acts, omissions, decisions, practices, customs a:ld policies,
21 color of state law andresultedin a violation ofplaintiff s constitutional rig11
* Fourteenth Amendments to the United States Constitution,
24 From the incident as described herein, in an amount to be determined according to
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