IN UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF

MISSOURI
JEFFERSON CITY MISSOURI DIVISION

AHMED SALAU,

) Case No. 2:14cv-04309MJW

P. O. BOX 6008,

PRINCETON, WV 24740.

)
Plaintiff, pro se

vs.

)
)

COMPLAINT

JURY TRIAL DEMANDED

CITY OF COLUMBIA,
NORTH 7TH STREET,
COLUMBIA MO 65203.

CITY OF COLUMBIA POLICE

DEPARTMENT,
NORTH 7TH STREET,

COLUMBIA MO 65203

BOB MCDAVID IN HIS

OFFICIAL CAPACITY AS

MAYOR OF COLUMBIA MO
NORTH 7TH STREET,

DefendantS.

COLUMBIA MO 65203.
)
BRIAN LEIBHART
PERSONALLY AND IN HIS

OFFICIAL CAPACITY AS
DETECTIVE OF COLUMBIA
POLICE DEPARTMENT.
NORTH 7TH STREET,
COLUMBIA MO 65203

KEN BURTON PERSONALLY

AND IN HIS OFFICIAL
CAPACITY AS CHIEF OF
POLICE OF COLUMBIA, MO
POLICE DEPARTMENT ,
NORTH 7TH STREET,
COLUMBIA, MO 65203.

STEPHEN MONTICELLI
PERSONALLY AND IN HIS
OFFICIAL CAPACITY AS
ASSISTANT CHIEF OF
POLICE OF COLUMBIA, MO
POLICE DEPARTMENT,
NORTH 7TH STREET,
COLUMBIA, MO 65203.

ERIC WHITE, PERSONALLY

AND IN HIS OFFICIAL
CAPACITY AS SUPERVISOR
FOR COLUMBIA MO POLICE
DEPARTMENT,

NORTH 7TH STREET,

COLUMBIA, MO 65203.

ROGER D ALLEN,
PERSONALLY AND IN HIS
OFFICIAL CAPACITY AS
SUPERVISOR FOR
COLUMBIA MO POLICE
DEPARTMENT, NORTH 7TH
STREET, COLUMBIA MO
65203

STEVEN D KANEASTER,
PERSONALLY AND IN HIS
OFFICIAL CAPACITY AS
POLICE OFFICER FOR CITY
OF COLUMBIA MO POLICE
DEPARTMENT,
NORTH 7TH STREET,
COLUMBIA MO 65203
RUKSTAD, PERSONALLY
AND IN HER OFFICIAL
CAPACITY AS DETECTIVE
FOR CITY OF COLUMBIA
MO POLICE DEPARTMENT,
NORTH 7TH STREET,
COLUMBIA MO 65203

QUINTANA, PERSONALLY
AND IN HIS OFFICIAL
CAPACITY AS POLICE
OFFICER FOR CITY OF
COLUMBIA MO POLICE
DEPARTMENT,
NORTH 7TH STREET,
COLUMBIA MO 65203

MCLANE, PERSONALLY
AND IN HER OFFICIAL
CAPACITY AS DETECTIVE
FOR THE CITY OF
COLUMBIA MO POLICE
DEPARTMENT,
NORTH 7TH STREET,
COLUMBIA, MO 65203.

JOHN DOES 1 10,

PERSONALLY AND IN
THEIR OFFICIAL
CAPACITIES AS ASSISTANT
PROSECUTING ATTORNEYS
FOR THE BOONE COUNTY
PROSECUTING
ATTORNEYS OFFICE,
WALNUT STREET,
COLUMBIA MO 65203

JANE DOES 1 10,

PERSONALLY AND IN
THEIR OFFICIAL
CAPACITIES AS ASSISTANT
PROSECUTING ATTORNEYS
FOR THE BOONE COUNTY
PROSECUTING
ATTORNEYS OFFICE,
WALNUT STREET,
COLUMBIA MO 65203

DANIEL KNIGHT,
PERSONALLY AND IN HIS
OFFICIAL CAPACITY AS
THE PROSECUTING
ATTORNEY OF THE BOONE
COUNTY PROSECUTING
ATTORNEYS OFFICE,
WALNUT STREET,
COLUMBIA MO 65203

TRACY GONZALEZ,
PERSONALLY AND IN HER
OFFICIAL CAPACITY AS
THE ASSISTANT
PROSECUTING ATTORNEY
OF THE BOONE COUNTY
PROSECUTING
ATTORNEYS OFFICE,

WALNUT STREET,
COLUMBIA MO 65203.

JOHNSON, PERSONALLY
AND IN HER OFFICIAL
CAPACITY AS AN
ASSISTANT PROSECUTING
ATTORNEY FOR THE
BOONE COUNTY
PROSECUTING
ATTORNEYS OFFICE,

BOONE COUNTY MISSOURI

PROSECUTING
ATTORNEYS OFFICE,
WALNUT STREET,
COLUMBIA MO 65203.

COMPLAINT

Plaintiff Ahmed Salau, pro se, for his complaint alleges as follows:
NATURE OF THE CAUSE
This is a civil rights action in which the Plaintiff, Ahmed Salau, seeks relief
for the Defendants violation of his rights secured by the Civil Rights Acts of 1866
and 1871, 42 U.S.C 1983 & 1985, of his rights secured by the 4 th, 5th, 13th, 14th
Amendments of the United States Constitution and of his rights under the laws and
Constitution of the State of Missouri.

The Plaintiff seeks damages both compensatory and punitive, affirmative &
equitable relief, special & exemplary damages, an award of costs and attorneys fees
& such other and further relief the Court deems equitable and proper.

The Defendants actions started on/or about October 24 th 2010 and

continues till today and occurred substantially in the Western District of Missouri
such that Missouri substantive laws apply herein.

JURISDICTION AND VENUE

Jurisdiction is conferred upon this Court by 28 U.S.C 1331, 1343(3)
and (4), this being an action seeking redress for the violation of the Plaintiffs
Constitutional and Civil Rights.

Plaintiffs claim for declaratory and injunctive relief is authorized by 28 U.S.C

2201 and 2202 and Rule 57 of the Federal Rules of Civil Procedure.

The Plaintiff further invokes this Courts pendent jurisdiction pursuant to 28

U.S.C 1367 (a) as against all parties that are so related to claims in this action
within the original jurisdiction of this Court that they form part of the same case or
controversy.

The Plaintiff demands a trial by jury on each and every one of his claims as
pled.

Venue is proper for the United District Court for the Western District of
Missouri pursuant to 28 U.S.C 1391 (a), (b) and (c).

THE PARTIES
1. Plaintiff, Ahmed Salau is a natural person and is a resident of
Princeton, West Virginia. Plaintiff majored in chemistry and psychology
and had a minor in women and gender studies. Plaintiff was a research
associate, co-author, co-investigator on a number of ongoing and
completed scientific projects that have been published in peer-reviewed
journals like the American Chemical Society Journal, Journal of
Thermodynamics among others. Plaintiff also had another job as a
nursing assistant at a nursing home and as a customer service agent at a
restaurant. Plaintiff was also involved and/or is a member of numerous
groups on campus including but not limited to STOP TRAFFIC, BAPTIST
STUDENT UNION, ON THE ROCK, AUTISM SPEAKS, PSI CHI, THE
FOOD BANK, Foundation for the International Medical Relief of Children
(FIMRC),among others. Plaintiff is also the Founder, President and Chief
Executive Officer of PARIS Angels a mentoring program for at-risk
youth. The Plaintiff is also the recipient of numerous scholarships for
academic achievement including the McNair National Research
scholarship, Judy C Johnston Chemistry Prize, Mary R Futch Humanities
Prize, etc. The Plaintiff is an African-American permanent resident of the
United States, and was at all times relevant herein a resident of the City of
Columbia Mo, County of Boone and State of Missouri.

2.

Defendant, City of Columbia is a municipal entity created and

authorized under the laws of the State of Missouri. It is authorized by
law to maintain a police department which acts as its agent in the area
of law enforcement and for which it is ultimately responsible. The
Defendant City of Columbia Missouri assumes the risks incidental to
the maintenance of a Police force and the employment of Police

officers as said risk attaches to the public consumption of the services

provided by the City of Columbia, Missouri Police Department.
3.

Defendant City of Columbia Police Department is a municipal entity

created and authorized under the laws of the State of Missouri. It is
authorized by law to carry out all police functions for the Defendant
City of Columbia, Missouri and assumes the risks incidental to the
maintenance of its police force and the employment and supervision
of police officers.

4.

Defendant Bob McDavid is a natural person and the Mayor of

Columbia, Missouri with his primary business activities conducted in
Columbia, Missouri and assumes supervisory authorities over the
actions of the Defendants City of Columbia, Missouri, Defendant City of
Columbia Missouri Police Department, Defendant City of Columbia
Missouri Police officers and Defendants City of Columbia Missouri
Police Detectives.

5.

Defendant Brain Leibhart is a natural person, a resident of Columbia,

Missouri, and was a detective of the Columbia Police Department and
was at all times relevant herein an officer, employee, and agent of the
Defendants City of Columbia, Missouri and he is sued individually and
in his official capacity.

6.

Defendant Ken Burton is a natural person, a resident of Columbia,

Missouri, and is the Chief of Police for the City of Columbia, Missouri
and is responsible for and the Chief architect of the policies, practices
and customs of the City of Columbia Police Department as well as
responsible for the hiring, screening, training, retention, supervision,
discipline, counselling and control of the Police officers & detectives
under his command. He is sued individually and in his official capacity.

7.

Defendant Stephen Monticelli is a natural person, a resident of

Harrisonburg, Virginia, and was the Assistant Chief of Police for the
City of Columbia, Missouri and was responsible for the hiring,
screening, training, retention, supervision, discipline, counselling and
control of the police officers & detectives under his command. He is
sued individually and in his official capacity.

8.

Defendant Eric White is a natural person, a resident of Columbia,

Missouri, and is a Supervisor of Defendant Steven Kaneaster and
directly responsible for Defendant Kaneasters actions as a city of
Columbia Missouri Police officer. He is sued individually and in his
official capacity.

9.

Defendant Roger Allen is a natural person, a resident of Columbia

Missouri and is a Supervisor of Defendant Brian Leibhart and directly
responsible for Defendant Leibharts actions as a city of Columbia
Missouri Detective. He is sued individually and in his official capacity.

10.

Defendant Steven Kaneaster is a natural person and a resident of

Columbia Missouri, and was a detective of the Columbia Police
Department and was at all times relevant herein an officer, employee,
and agent of the Defendant City of Columbia, Missouri and he is sued
individually and in his official capacity.

11.

Defendant Rukstad is a natural person and a resident of Columbia

Missouri and was a detective of the Columbia Police Department and
was at all times relevant herein an officer, employee and agent of the
Defendant City of Columbia, Missouri and he is sued individually and
in his official capacity.

12.

Defendant Thomas Quintana is a natural person and a resident of

Columbia Missouri and was a police officer of the Columbia Missouri

Police Department and was at all times relevant herein an officer,

employee and agent of the Defendant City of Columbia Missouri and
he is sued individually and in his official capacity.
13.

Defendant McLane is a natural person and a resident of Columbia

Missouri and was a detective of the Columbia Police Department and
was at all times relevant here in an officer, employee and agent of the
Defendant City of Columbia Missouri and she is sued individually and
in his official capacity.

14.

Defendant Boone County Prosecuting Attorneys Office is a municipal

entity created and authorized under the laws of the State of Missouri
to investigate and prosecute criminal conduct within the County of
Boone, Missouri and the City of Columbia Missouri and assumes the
risks incidental to the employment, training and supervision of her
assistant prosecuting attorneys. The office is sued in her official
capacity.

15.

Defendant Boone County Prosecuting Attorney Daniel R. Knight is and

was at all times relevant herein the Prosecuting Attorney of the
County of Boone and is responsible for and the chief architect of the
policies, practices and customs of the Boone county Prosecuting
attorneys office as well as responsible for the hiring, screening,
training, retention, supervision, discipline, counselling and control of
the assistant prosecuting attorneys who work in his office. He is sued
individually and in his official capacity.

16.

Defendant Assistant Prosecuting Attorney Tracy Gonzalez is a natural

person, a resident of Columbia Missouri and was at all times relevant
herein, an officer, employee and an agent of the Boone County

Missouri Prosecuting Attorneys Office. She is sued individually and in

her official capacity.
17.

Defendant Assistant Prosecuting Attorney Johnson is a natural person,

a resident of Columbia Missouri and was at all times relevant herein
an officer, employee, and an agent of the Boone County Missouri
Prosecuting Attorneys Office. She is sued individually and in her
official capacity.

18.

Defendants John Does 1 -10 are natural persons and residents of

Columbia Missouri, are assistant Prosecuting Attorneys for the Boone
County Missouri Prosecuting Attorneys office and were at all times
relevant herein officers, employees, and agents of the Boone County
Missouri Prosecuting Attorneys Office. They are sued individually and
in their official capacities.

19.

Defendants Jane Does 1 10 are natural persons, residents of

Columbia Missouri, and are assistant Prosecuting attorneys for the
Boone County Missouri Prosecuting Attorneys office and were at all
times relevant herein officers, employees, and agents of the Boone
County Missouri Prosecuting Attorneys Office. They are sued,
individually and in their official capacities.

20.

At all times relevant herein, the individual defendants herein were

acting under color of State law in the Course and scope of their duties
and functions as agents, servants, employees and officers of either the
City of Columbia Missouri Police Department, and or the Boone
County Missouri Prosecuting Attorneys office and otherwise
performed and engaged in conduct incidental to the performance of
their lawful functions in the course of their duties. They were acting
for and on behalf of the City of Columbia police Department and the

Boone County Missouri Prosecuting Attorneys Office at all times

relevant herein with the power and authority vested in them as
officers, agents and employees of City of Columbia Missouri Police
Department and Boone County Prosecuting Attorneys office and
incidental to the lawful pursuit of their duties as officers, employees
and agents of the City of Columbia Missouri Police Department and the
Boone County Prosecuting Attorneys office.

STATEMENT OF FACTS
21.

On October 24th 2010, Plaintiff Ahmed Salau was 26 years old and
lived at 2607 east wood Drive, Apt 41, Columbia, Missouri with his
roommates Diane Leslie Kaster & Randall Gene Williams and his
girlfriend Constance Suzanne Agregaard.

22.

Around 9pm, Defendants McLane and Kaneaster came to the Plaintiffs

employment place Columba Manor Care Center and arrested him.

23.

When the Plaintiff asked the Defendants what he was under arrest for,
they simply told him they could not tell him and transported him to
the Columbia Police Department.

24.

Around 10pm on 10/24/10, the Plaintiff is placed in holding at the

Columbia Police Department and left unattended for over three hours.

25.

Around 1:00am, October 25th 2010, Defendant Leibhart begins to

question the Plaintiff, after the Plaintiff asserts his Miranda rights, the
Defendant Leibhart continues to question the Plaintiff until the
Plaintiffs sister who is an attorney Olakemi Salau, calls repeated to
the Police Department to stop the questioning and allow her access to
the Plaintiff.

26.

Around 3:00am, October 25th 2010, Defendant Leibhart released the

Plaintiff from Police questioning and custody.

27.

The Plaintiff repeatedly warns the Defendant Leibhart that he was in

an extremely selective Air Force Select program and to make sure he
properly investigated the matter and to not ruin his life with a rape
charge.

28.

On Monday October 25th 2010, the Plaintiff hires David Tyson Smith to
represent him and Attorney Smith cancels a meeting previously
scheduled with Defendant leibhart.

29.

On Tuesday, October 26th, 2010, the Defendants Leibhart and Mclane

came to the Plaintiffs apartment to interview him, which request was
denied,

30.

On Wednesday October 27th, 2010, Defendant Leibhart submitted a

falsified probable cause statement for a warrant which was reviewed
by Defendant Gonzalesz and Defendant Knight and subsequently
authorized without any scintilla of evidence.

31.

On Friday, October 29th 2010, the Plaintiff writes a detailed letter to

the Defendants City of Columbia Missouri, City of Columbia Missouri
Police Department, Bob McDavid, Tracy Gonzalez, Johnson, Leibhart,
and Ken Burton professing his actual innocence and providing proof
by way of pictures, insurance receipts, bills & phone records all to no
avail.

32.

On the same day, he is arrested by Defendant Leibhart and Quintana

and taken to the Boone County Jail for processing.

33.

The Plaintiffs arrest was not just as a result of sloppy police or

investigative work done by the Defendants but was a deliberate act
undertaken by the Defendants pursuant to the policies, practices, and
customs of the Defendants City of Columbia Missouri, City of Columbia
Police Department, and Boone County Missouri Prosecuting
Attorneys Office, and were undertaken in a manner and method
designed to exploit Plaintiffs lack of financial resources, the Plaintiffs
race, ethnicity, and nationality and the Plaintiff.

34.

The Plaintiff had previously informed the Defendants of the presence

of numerous witnesses who could testify to the consensual
relationship between the Plaintiff and Constance Agregaard his Air
Force Recruiters, His Managers at work, his attorney friend Olayinka
Hamza, and his roommates.

35.

Nonetheless, even after the Defendants Leibhart & McLane

interviewed Sgt. Dobrow the Plaintiffs Air Force Recruiter, and
became aware of the consensual nature of the relationship, the
Defendants Knight, Gonzalez, and Boone County Prosecuting
Attorneys office still continued to prosecute the Plaintiff.

36.

In fact, the Defendants knew at the time of the arrest that the Plaintiff
& Constance Agregaard were in fact in a consensual relationship but
deliberately failed to explore that facet of the case.

37.

The failure of the Defendants to declare the Plaintiffs actual innocence

was not simply the result of sloppy investigative work; it
demonstrates a deliberate intent on the part of the Defendants to
cover up the Plaintiffs innocence because it would have completely
undermined the integrity of the prosecution of the Plaintiff; a
prosecution which both the prosecuting attorney and Police Officer
Defendants were heavily invested in both because of the extreme
amount of public attention to the prosecution and for the benefit of
their careers.

38.

As of May 11th 2011, the Plaintiff had been prosecuted for more than
seven months for a charge of forcible rape. Plaintiff had lost out on
income, familial and social interaction, education and loss of good
name.

39.

Throughout his confinement, the Plaintiff has consistently denied

forcibly raping his girlfriend.

40.

In November 2010, the Defendants Knight, Burton, Monticelli, White,

Allen, Gonzalez, Boone County Prosecuting Attorneys Office, City of

Columbia Police Department were provided with explicit still video

images showing no rape in fact occurred.
41.

The Defendants deliberately ignored the evidence and continued to

request continuance after continuance and prosecuting the matter In
bad faith.

42.

Sometime in 2010 or 2011, the alleged victim recanted her statement

and the Defendants still failed to declare the Plaintiffs actual
innocence.

43.

The Defendants obtained statements from Leslie Diane Kaster &

Randall Gene Williams that were favorable to the Plaintiff but falsified
their notes to align the statements with their malicious intent.

44.

The Defendant police officers, detectives and prosecuting attorneys

knew or should have known at the time, and, on information and
belief, concealed from the Plaintiffs and his Defense Counsel and from
the Public as well, that at the time they had misrepresented the
statements of Kaster & Williams: they had information about the
actual innocence of the Plaintiff.

45.

The Defendants knew the Plaintiff was being actually recruited for an
elite Air Force program Yet they deliberately ignored these facts in
favor of a speedy and politically expedient accusation that the Plaintiff
allegedly raped his girlfriend.

46.

In addition to their efforts to suppress the truth at the time of the

prosecution, the Defendants here continued to actively conspire to
propound the belief that the Plaintiff was actually and was in fact
complicit in the crimes he was charged with notwithstanding his
exoneration by the Court, the physical evidence showing the
relationship was consensual, the recantation of Constance Aregaard,
and the statement of Plaintiffs Air Force Recruiter Sgt Jeffrey Dobrow;
and the Defendants engaged in misconduct in the course of their
investigation and prosecution of the Plaintiff.

47.

The Defendants illegal arrest, confinement and imprisonment,

malicious prosecution without probable cause, with the attendant
suppression of exoneratory and exculpatory evidence, the coercion
and manufacture and intentional misrepresentation of knowingly
false evidence, and the deception of the Missouri Courts concerning
this evidence, constituted an unconstitutional seizure of the Plaintiff,
and was effectuated without due process of law, in violation of the 4 th
& 14th Amendment of the United States Constitution and proximately
caused and directly caused the Plaintiffs grievous and permanent
injury including more than 7 months of imprisonment, and the
attendant loss of freedom, companionship, and income, mental and
physical pain, suffering, anguish, fear, and humiliation and defamation
of character & reputation which caused by the Plaintiffs public
branding as a rapist.

48.

The conduct of the Defendants in maliciously prosecuting and

conspiring to cover up the truth about what happened at 2607 Est
wood Drive in 2010 and in subsequently ratifying this wrongful
conduct in 2012, proximately caused the Plaintiff serious an
permanent physical and emotional injury, pain and suffering, mental
anguish, humiliation and embarrassment.

49.

The conduct of The Defendants has irreparably injured the Plaintiff.

CLAIMS FOR RELIEF
FIRST CLAIM FOR RELIEF

(VIOLATION OF RIGHTS SECURED BY 42 U.S.C 1981 AND THE

THIRTEENTH AMENDMENT OF THE UNITED STATES CONSTITUTION)

50.

Plaintiff repeats and re-alleges the allegations set forth in paragraphs

1 to 50 as if fully set forth at length herein.

51.

The conduct and actions of the Defendants acting under color of State
law, in subjecting the Plaintiff who is African American to malicious
prosecution and a conspiracy to cover up the truth was motivated by
racial animus and done intentionally, maliciously and/or with a
reckless disregard for the natural and probable consequence of their
acts, was done without lawful justification, and was designed to and
did cause specific and serious bodily, mental and emotional harm, pain
and suffering in violation of the Plaintiffs Constitutional rights as
guaranteed under 42 U.S.C 1981 and the 4th and 13th Amendment of
the United States Constitution.

52.

Defendants actions forever paint the Plaintiff in a bad light, forever

damage his business, educational and social prospects and curtail his
associations forever and have severely damaged the Plaintiff both
emotionally, physically, socially, and fiscally.

53.

Plaintiff has been and is forever damaged by Defendants tortious

misconduct.
SECOND CLAIM FOR RELIEF
(VIOLATION OF RIGHTS SECUIRED BY 42 U.S.C 1983 AND THE

14TH AMENDMENT TO THE UNITED STATES CONSTITUTION FOR ASSUALTING

AND DETAINING THE PLAINTIFF)
54.

Plaintiff repeats and re-alleges the allegations set forth in paragraphs

1 to 55 as if fully set forth at length herein.

55.

The conduct and actions of the Defendants acting under color of state
law, in subjecting the Plaintiff who is African American to malicious
prosecution and a conspiracy to cover up the truth was motivated by
racial animus, was done intentionally, maliciously and/or with a
reckless disregard for the natural and probable consequence of their
acts, was done without lawful justification, and was designed to and
did cause specific and serious bodily , mental, and emotional harm,
pain and suffering in violation of the Plaintiffs Constitutionally
guaranteed rights under 2 U.S.C 1983, and the 4th & 14th
Amendments to the United States Constitution.

56.

Defendants actions forever paint the Plaintiff in a bad light, forever

damage his business, educational and social prospects and curtail his
associations forever and have severely damaged the Plaintiff both
emotionally, physically, socially, and fiscally.

57.

Plaintiff has been and is forever damaged by Defendants tortious

misconduct.

THIRD CLAIM FOR RELIEF

(VIOLATION OF RIGHTS SECURED BY 42 U.S.C 1983 & 1985 &
THE 14TH AMENDMENT OF THE UNITED STATES CONSTITUTION.)

58.

Plaintiff repeats and re-alleges the allegations set forth in paragraphs

1 to 59 as if fully set forth at length herein.

59.

Defendants Bob McDavid, Ken Burton, Stephen Monticelli, Brian

Leibhart, Steven Kaneaster, Thomas Quintana, Eric White, Roger Allen,
Rukstad, McLane, with other investigative, supervisory, and

concerned personnel, together and under color of State law, reached

an understanding, engaged in a course of conduct, and otherwise
conspired among and between themselves to deprive the Plaintiff of
his Constitutional rights, and did deprive Plaintiff of said right,
including the right to be free from unreasonable arrest and from
wrongful confinement, imprisonment, and from malicious
prosecution, and their right to access the Courts as protected by the
1st, 4th, & 14th Amendment of the United States constitution and 42
U.S.C 1983 because said actions were done with the knowledge &
purpose of depriving Plaintiff who is African American of the equal
protection of the laws and /or of equal privileges and immunities
under the law, and with racial animus towards the Plaintiff, they also
deprived Plaintiff of the right to equal protection of the laws under the
14th Amendment, 42 U.S.C 1983 &1985.
60.

In furtherance of this conspiracy or conspiracies, the Defendants

named above, together with their unsued co-conspirators committed
the overt acts set forth in the facts set forth above, including but not
limited to the wrongful arrest, imprisonment and prosecution of
Plaintiff; the manufacture by the methods articulated above of
knowingly false inculpatory evidence against the Plaintiff; the
suppression of exoneratory & exculpatory evidence, including but not
limited to the Sgt. Dobrow interviews, the Kaster & Wiliiams
interview,; wither at the time it was received or after it became known
that there was not scientific or physical evidence that linked the
Plaintiff to the crime alleged; the physical abuse and psychological
coercion of the Plaintiff in an attempt to compel him to make false
inculpatory statements; and the presentation of these known
misstatements, knowingly false and incomplete evidence to

prosecutors, judges; & the filing of false and incomplete statements &
reports.
61.

Said conspiracies and overt acts are continuing in nature, and caused
Plaintiffs constitutional injuries, pain, suffering, fear, mental anguish,
incarceration , imprisonment, humiliation, defamation of character
and reputation, and loss of freedom, companionship, and income as
set forth more fully above.

62.

Defendants actions forever paint the Plaintiff in a bad light, forever

damage his business, educational and social prospects and curtail his
associations forever and have severely damaged the Plaintiff both
emotionally, physically, socially, and fiscally.

63.

Plaintiff has been and is forever damaged by Defendants tortious

misconduct.

FOURTH CLAIM FOR RELIEF

(42 U.S.C 1983 MONELL CLAIM AGAINST THE CITY OF COLUMBIA
MISSOURI)
64.

Plaintiff repeats and re-alleges the allegations set forth in paragraphs

1 to 65 as if fully set forth at length herein.

65.

Defendant Ken Burton as Chief of Police for City of Columbia, Missouri

is by operation of State law and as a matter of fact, the final decision
maker for Columbia, Mo with regard to the investigation, arrest,
custodial and administrative acts, omissions, and decisions which he
made or participated in as alleged above.

66.

In 2012, 2013, 2014, the Defendant Burton and his co-defendant

Police Officers & detectives have continued to make statements to
other entities alleging that the Plaintiff is in fact not innocent of the
crime he was exonerated of.

67.

In so doing, Defendant Burton and co-defendant police officers,

detectives ratified and condoned the wrongdoing that took place.

68.

These acts by Defendant Burton directly and proximately caused the

Constitutional injuries to the Plaintiff and are directly chargeable to
the Defendant City of Columbia Missouri because of Defendant
Burtons status as final decision maker for the City with regard to
matters involving City of Columbia Police Department.

69.

Additionally and/or alternatively, on information and belief, the City

of Columbia Missouri through its Police Department and Police
Detectives including Defendant Stephen Monticelli had in effect both
before and at the time of the events alleged in this complaint, several
inter-related de facto policies, practices and customs, including inter
alia:
a.

A policy, practice and custom of suppressing, destroying or

otherwise secreting from criminal Defendants exculpatory or

exoneratory evidence; and
b,

A policy, practice and custom of failing to properly train or

supervise officers on the proper techniques of investigating serious

crimes, particularly where African American and foreign born
residents were involved or to properly discipline officers who violate
the Constitution or otherwise transgress the rights of criminal
suspects during their investigations.
70.

These interrelated policies, practices and customs separately and/or

together were implemented with deliberate indifference, and were a
direct and proximate cause of the Plaintiffs Constitutional injuries as
set forth above.

71.

Defendants actions forever paint the Plaintiff in a bad light, forever

damage his business, educational and social prospects and curtail his
associations forever and have severely damaged the Plaintiff both
emotionally, physically, socially, and fiscally.

72.

Plaintiff has been and is forever damaged by Defendants tortious

misconduct.
FIFTH CLAIM FOR RELIEF

(42 U.S.C 1983 MONELL CLAIM AGAINST THE BOONE COUNTY

PROSECUTING ATTORNEYS OFFICE)
73.

Plaintiff repeats and re-alleges the allegations set forth in paragraphs

1 to 73 as if fully set forth at length herein.

74.

The Boone County Prosecuting Attorneys Office itself also had in

effect, both before and at the time of the events alleged in this
complaint, several inter-related defacto policies, practices and
customs, including interalia:
a.

A policy, practice and custom of suppressing, destroying or

otherwise secreting from criminal Defendants exculpatory or

exoneratory evidence; and
b.

A policy, practice and customs of failing to properly train or

supervise Assistant prosecuting attorneys and investigators in the

proper techniques of investigating serious crimes, particularly where
African-American and foreign-born residents are involved or to
properly discipline officers and investigators who violate the
Constitution or law or otherwise transgress the rights of criminal
suspects during their investigations.
75.

These interrelated policies, practices and customs, separately and/or

together, were implemented with deliberate indifference, and were a

direct and proximate cause of the Plaintiffs Constitutional injuries as

set forth above.
76.

Defendants actions forever paint the Plaintiff in a bad light, forever

damage his business, educational and social prospects and curtail his
associations forever and have severely damaged the Plaintiff both
emotionally, physically, socially, and fiscally.

77.

Plaintiff has been and is forever damaged by Defendants tortious

misconduct.
SIXTH CLAIM FOR RELIEF
(VIOLATION OF RIGHTS UNDER STATE LAW)

78.

Plaintiff repeats and re-alleges the allegations set forth in paragraphs

1 to 78 as if fully set forth at length herein.

79.

By The actions described above, each and all of the Defendants jointly
and severally have committed the following wrongful acts against the
Plaintiff which are tortious under the laws of the State of Missouri.
a. Malicious Prosecution
b. Conspiracy to cover-up
c. Negligence in causing the injuries to the Plaintiff
d. Intentional infliction of emotional distress upon the Plaintiff in that
the Defendants intended to and did cause the Plaintiff severe
emotional distress, and the Defendants acts were outrageous in
the extreme and utterly unacceptable in a civilized society.
e. Negligent hiring, screening, retention, supervision and training of
Defendant Police Officers by Defendants City of Columbia Missouri
and City of Columbia Missouri Police Department.
f. Negligent hiring, screening, retention, supervision and training of
Defendant Assistant Prosecuting Attorneys by Defendant Boone
County Prosecuting Attorneys Office, Defendant Dan Knight and

the Defendant City of Columbia Missouri and Defendant City of

Columbia Missouri Police Department.
g. Conspiracy by the Defendants to commit all of the above acts;
h. Violation of rights otherwise guaranteed to the plaintiff under the
laws and constitutions of the State of Missouri.
80.

The foregoing acts and conduct of the Defendants were the direct and
proximate cause of injury and damage to the Plaintiffs and violated his
statutory and common law rights as guaranteed him the laws and
constitution of the State of Missouri.

81.

Defendants actions forever paint the Plaintiff in a bad light, forever

damage his business, educational and social prospects and curtail his
associations forever and have severely damaged the Plaintiff both
emotionally, physically, socially, and fiscally.

82. Plaintiff has been and is forever damaged by Defendants tortious

misconduct.
SEVENTH CLAIM FOR RELIEF
(RESPONDEAT SUPERIOR CLAIM AGAINST THE CITY OF COLUMBIA MISSOUIR AND
THE BOONE COUNTY PROSECUTING ATTORNEYS OFFICE)
83.

Plaintiff repeats and re-alleges the allegations set forth in paragraphs

1 to 83 as if fully set forth at length herein.

84.

The Defendants were at all times relevant to this Court, employees,

and agents of either the City of Columbia Missouri or the Boone
County Prosecuting Attorneys Office. Each of the Defendants was
acting within the scope of his or her employment and their acts and
omissions as alleged above, are therefore directly chargeable to their
respective employers under State law under the doctrine of
Respondeat Superior.

85.

Defendants actions forever paint the Plaintiff in a bad light, forever

damage his business, educational and social prospects and curtail his
associations forever and have severely damaged the Plaintiff both
emotionally, physically, socially, and fiscally.

86. Plaintiff has been and is forever damaged by Defendants tortious

misconduct.
WHEREFORE, THE PLAINTIFF DEMANDS THE FOLLOWING RELIEF JOINTLY AND
SEVERALLY AGAINST ALL OF THE DEFENDANTS:
A. COMPENSATORY, SPECIAL, EXEMPLARY ACTUAL AND PUNITIVE
DAMAGES FOR THE PLAINTIFF IN THE AMOUNT OF $10,000,000.00
B. THE CONVENING AND EMPANELLING OF A JURY TO CONSIDER THE
MERITS OF THE CLAIMS HEREIN;
C. A COURT ORDER PURSUANT TO 42 U.S.C 1988 THAT THE
PLAINTIFF IS ENTITLED TO THE COSTS INVOLVED IN MAINTAINING
THIS ACTION AND ATTORNEYS FEES;
D. SUCH OTHER & FURTHER RELIEF AS THIS COURT MAY DEEM
APPROPRIATE AND EQUITABLE, INCLUDING INJUNCTIVE,
DECLARATORY RELIEF AS MAY BE REQUIRED IN THE INTEREST OF
JUSTICE.
Respectfully submitted,
___________________________
Ahmed Salau
Plaintiff Pro Se
P O Box 6008
Princeton, WV 24740
Phone) 5403151147 Fax) 5403016034 ahmed@ahmedsalau.com
Dated Princeton, West Virginia November 27th, 2014.