Professional Documents
Culture Documents
1 Page 1 of 8
MARKO LAW, PLC, and for their Complaint against the above-named
1
Case 2:18-cv-12063-GAD-RSW ECF No. 1 filed 07/02/18 PageID.2 Page 2 of 8
law claims.
of the events giving rise to this cause of action occurred in the Eastern District of
Michigan.
PARTIES
2
Case 2:18-cv-12063-GAD-RSW ECF No. 1 filed 07/02/18 PageID.3 Page 3 of 8
8. The transactions and occurrences giving rise to this action took place
in Oakland County, Michigan, which is located in the Eastern District in the State
of Michigan.
jurisdictional requirement.
FACTUAL ALLEGATIONS
11. Plaintiff Serenity, at all times relevant to this Complaint, was a third-
grade student at Webb Elementary School, located in the Hazel Park School
classroom.
slammed the door closed on Serenity’s finger with such force that her finger was
nearly severed.
COUNT I
VIOLATION OF THE FOURTH AMENDMENT
RIGHT TO BE FREE FROM UNREASONABLE PUBLIC SEIZURES
3
Case 2:18-cv-12063-GAD-RSW ECF No. 1 filed 07/02/18 PageID.4 Page 4 of 8
unreasonable seizure.
standing in front of the doorway to prevent her from exiting, when Serenity was
physically unable to free herself from this captivity, was an unreasonable seizure in
COUNT II
VIOLATION OF THE FOURTEENTH AMENDMENT
RIGHT TO PERSONAL SECURITY AND BODILY INTEGRITY
4
Case 2:18-cv-12063-GAD-RSW ECF No. 1 filed 07/02/18 PageID.5 Page 5 of 8
Amendment right to personal security and bodily integrity and is not reasonably
violations.
27. Defendant Daley’s act of moving Serenity into a room, isolating her
COUNT IV
GROSS NEGLIGENCE
5
Case 2:18-cv-12063-GAD-RSW ECF No. 1 filed 07/02/18 PageID.6 Page 6 of 8
31. That the negligent acts of Defendants, as outlined above, are an actual
alleged.
DAMAGES
omissions, Plaintiff suffered the following injuries and damages including, but not
limited to:
b. Mental anguish;
c. Emotional distress;
d. Severe anxiety;
f. Medical treatment;
6
Case 2:18-cv-12063-GAD-RSW ECF No. 1 filed 07/02/18 PageID.7 Page 7 of 8
litigation.
Respectfully submitted,
/s/Jonathan R. Marko
Jonathan R. Marko (P72450)
Counsel for Plaintiff
Marko Law, PLC
645 Griswold Street, Suite 4100
Detroit, Michigan 48226
(313) 965-5555
7
Case 2:18-cv-12063-GAD-RSW ECF No. 1 filed 07/02/18 PageID.8 Page 8 of 8
JURY DEMAND
Respectfully submitted,
/s/Jonathan R. Marko
Jonathan R. Marko (P72450)
Counsel for Plaintiff
Marko Law, PLC
645 Griswold Street, Suite 4100
Detroit, Michigan 48226
(313) 965-5555
CERTIFICATE OF SERVICE