timur andiric
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Timur AndiricTRANSCRIPT
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UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
TIMUR ANDIRIC : CIVIL ACTION NO.: 3:12CV1437
VS. :
JOSH KYLE : OCTOBER 9, 2012
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 and a resident of
the State of Connecticut.
4. The defendant is a police officer in the City of New Haven, who was
acting as such at the time of the events hereinafter described. 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. Shortly after midnight on February 26, 2012, as the plaintiff was leaving
a restaurant known as Terminal 110 located in the Food Terminal Plaza at 240
Sargent Drive in the City of New Haven, the defendant seized the plaintiff, threw
him down a flight of stairs, punched him, kicked him, and shot an electronic
Taser dart into his body.
7. There was no justification or excuse for the aforesaid brutality.
8. The defendant thereafter arrested the plaintiff, falsely accused him of
Interfering with a Police Officer, and wrote and filed a false police report intended
to cover up his own wrongdoing and violation of the plaintiff’s rights.
9. As a consequence of the aforesaid brutal assault, the plaintiff suffered
a broken nose, temporary loss of consciousness, an open head laceration,
bruising and contusions, causing him pain and emotional distress and requiring
medical treatment.
10. In the manner described above, the defendant subjected the plaintiff
to unreasonable force in the course of an arrest, in violation of the Fourth
Amendment to the United States Constitution as enforced through Sections 1983
and 1988 of Title 42 of the United States Code.
WHEREFORE, the plaintiff claims judgment for compensatory damages,
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punitive damages, attorney fees and costs.
THE PLAINTIFF
BY: /s/ JOHN R. WILLIAMS (ct00215)51 Elm StreetNew Haven, CT 06510203.562.9931Fax: [email protected] His Attorney
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