Aldred V City of Pittsburgh, PAWD 19-cv-00838 (12 July 2019) Doc 1, COMPLAINT With 4 Enclosures

Case 2:19-cv-00838-DSC Document 1 Filed 07/12/19 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF PENNSYLVANIA
ROBERT ALDRED, an individual ) CIVIL DIVISION

Plaintiff, )
v. ) No.
)
CITY OF PITTSBURGH, ACTING CHIEF )
OF POLICE REGINA McDONALD, ) Judge
OFFICER MICHAEL SOROCZAK, )
OFFICER JOSHUA MATTHEWS, and )
OFFICER LOGAN HANLEY. ) JURY TRIAL DEMANDED
Defendants.
NOTICE OF REMOVAL
1. Defendants Officer Michael Soroczak, Officer Joshua Matthews and Officer Logan
Haley file this Notice to Remove the above action to the United States District Court for the Western
District Court pursuant to 28 U.S.C. §§ 1441(a) and 1446.
2. Plaintiff’s initial Complaint named the City, (former) Acting Chief McDonald
(“Chief McDonald”), and ten “John Doe” defendants. The above action was commenced in the
Court of Common Pleas of Allegheny County, Pennsylvania under case number GD No.: 19-
001728. While Plaintiff’s first Complaint mentioned §1983 claims in certain paragraphs it was
unclear whether any claims were constitutional. Defendants City of Pittsburgh (“City”) and Acting
Chief McDonald accepted service of Plaintiff’s initial complaint in this action on approximately
March 13, 2019. No service was executed or accepted on behalf of any “John Doe” defendant.
3. On June 21, 2019, Plaintiff filed an Amended Complaint, changing his claims.
Plaintiff’s Amended Complaint removed claims against all “John Doe” defendants and, instead,
made claims against, the City, Acting Chief McDonald, and Defendants Officer Michael Soroczak,
Officer Joshua Matthews, and Officer Logan Haley. All three newly named Defendant Officers
accepted service between June 21, 2019, and July 9, 2019.
1
4. Pursuant to § 1446 a copy of all processes, pleadings, and orders are attached as
Exhibits A – C.
5. Plaintiff’s Amended Complaint alleges violations of Plaintiff’s Fourth Amendment
rights. The Plaintiff’s alleged federal Fourth Amendment claims are brought pursuant to 42 U.S.C.
§§1983.
6. According to 28 U.S.C. § 1331, this Court has jurisdiction because Plaintiff’s
claims are made pursuant to federal law.
7. According to 28 U.S.C. §§ 118(c) and 1441(a) the Western District is the proper
district for removal.
8. All above Officer Defendants, as well as Defendant City of Pittsburgh and Acting
Chief McDonald, consent to removal pursuant to 28 U.S.C. § 1446.
9. As later-served Defendants, Officers Michael Soroczak, Joshua Matthews and
Logan Haley each have the right to remove within thirty days of acceptance of service. See Delalla
v. Hanover Ins., 660 F.3d 180, 186 (3d Cir. 2011)(Given that § 1446(a) explicitly affirms the
possibility of multiple notices of removal, the only reasonable reading of § 1446(b) is that the
subsection applies individually to each notice of removal that might potentially be filed
by each removing ‘defendant.’ To hold otherwise would create tension between subsections (a) and
(b)). Furthermore, Acting Chief McDonald and the City are not “precluded from joining” in the
defendant officers instant notice because the two elected not to file a notice of removal. Id. at 188.
10. This action may therefore proceed in this court pursuant to 28 U.S.C. §§ 1441(a)
and 1446.
11. Defendants City of Pittsburgh and Defendant Officers demand a jury trial.
Respectfully submitted,
2
/s/ Julie E. Koren

Julie E. Koren (Pa. ID 309642)
Assistant City Solicitor
313 City-County Building, 414 Grant St.
Pittsburgh, PA 15219
Julie.Koren@pittsburghpa.gov
Counsel for Defendants
3
EXHIBIT A
Case 2:19-cv-00838-DSC Document 1-1 Filed 07/12/19 Page 1 of 49
IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY,

PENNSYLVANIA
ROBERT ALDRED, an individual CIVIL DIVISION
Plaintiff, GD No.: 19-1728
v. COMPLAINT IN CNIL ACTION
CITY OF PITTSBURGH, ACTING CHIEF OF

POLICE REGINA McDONALD, OFFICER
JOHN DOE #1, OFFICER JOHN DOE #2,
OFFICER JOHN DOE # 3, OFFICER JOI-IN 11
DOE #4, OFFICER JOHN DOE #5, N r
OFFICER JOHN DOE #6, OFFICER JOHN m
DOE #7, OFFICER JOHN DOE #8, OFFICER .C:-
o
JOHN DOE # 9, & OFFICER JOHN DOE N
Cl
#10.
JURY TRIAL DEMANDED
Defendants.
I certify that this filing complies with : Filed on behalf of Plaintiff:

the provisions of the Public Access
Policy of the Unified Judicial System of : ROBERT ALDRED
Pennsylvania: Case Records of the : Counsel of Record for this Party:
Appellate and Trial Courts that require
filing confidential information and : Todd J. Hollis, Esquire
documents differently than : Todd J. Hollis Law
non-confidential information and : Pa. I.D. No. 72510
~~~g~
TOddl~~'
: The Pittsburgher
: 428 Forbes Avenue, Suite 505
: Pittsburgh PA 15219-1603
Attorney For Plaintiff : (412) 434.0252
: (412) 434.0256 Facsimile
: toddjhollis@gmaiI.com
"'
Todd J. !-Iollis, .E.sil.
~")

PENNSYLVANIA

Plaintiff, GO No.: 19-1728
v. COMPLAINT IN CIVIL ACTION

OFFICER JOHN DOE # 3, OFFICER JOHN
DOE #4, OFFICER JOHN DOE #5,
OFFICER JOHN DOE #6, OFFICER JOHN
DOE #7, OFFICER JOHN DOE #8, OFFICER
JOHN DOE # 9, & OFFICER JOHN DOE #10.
Defendants.
JURY TRIAL DEMANDED
NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the claims set forth in
the following pages, you must take action within twenty (20) days after this complaint
and notice are served, by entering a written appearance personally or by attorney and
filing in writing with the court your defenses or objections to the claims set forth against
you. You are warned that if you fail to do so the case may proceed without you and a
judgment may be entered against you by the court without further notice for any money
claimed in the complaint or for any claim or relief requested by the plaintiff. You may
lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU

DO NOT HA VE A LAWYER OR CANNOT AFFORD A LAWYER, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE
YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE

ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY
OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO
FEE.
LAWYER REFERRAL SERVICES
ALLEGHENY COUNTY BAR ASSOCIATION
920 CITY-COUNTY BUILDING
PITTSBURGH, PA 15219
PHONE: 412-261-0518

PENNSYLVANIA
v.
JURY TRIAL DEMANDED

JOHN DOE # 9, & OFFICER JOHN DOE
#10.
Defendants.
COMPLAINT IN CIVIL ACfION
AND NOW comes the Plaintiff, Robert Aldred, by and through his attorney, Todd Jonathan
Hollis, Esquire, of Todd J. Hollis Law, and claims damages of the Defendants City of Pittsburgh,
Acting Chief of Police Regina McDonald, Officer John Doe #1, Officer Jolm Doe #2, Officer Jolm
Doe #3, Officer Jolm Doe #4, Officer John Doe #5, Officer Jolm Doe #6, Officer John Doe #7 Officer
Jolm Doe #8 Officer Jolm Doe #9 Officer Jolm Doe #10, upon a cause of action whereof the
following are statements:
PARTIES
1. The Plaintiff, Robert Aldred ("Mr. Aldred), is an adult individual who resides in
Pittsburgh, County of Allegheny, Commonwealth of Pennsylvania.

2. Defendant City of Pittsburgh CCity"), is a municipality within the
Commonwealth of Pennsylvania, with a prin.cipal place of business located at 414 Grant
Street, Pittsburgh, PelU1sylvania 15219, whicl) at all times relevant hereto, was authorized
to and did operate and maintain a police department. Defendant City of Pittsburgh was
acting by and through its duly authorized agents, employees and/ or assigns, who were
then and there acting within the course and scope of their employment under the color of
state law and in Olccordance with the custom, policies and practices of the City of
Pittsburgh.
3. Defendant Regina McDonald, was at all times relevant hereto, the acting Chief of
Police of the City of Pittsburgh Bureau of Police. She is sued in her individuOlI cOlpOlcity.
This defendant, at all times relevant hereto, had the day-to-day responsibility to ensure thOlt
City of Pittsburgh police officers were properly trained, supervised, and disciplined, and
also, Olt all times relevant hereto.
4. Defendants John Doe one through ten (1-10) are adult individuals residing in the
City of Pittsburgh, who at all times relevant hereto, were employed as City of Pittsburgh
police officers and who with respect to the events alleged herein, were acting under the
color of state law and in accordance with the custom practices and/ or policies of the City of
Pi ttsburgh.
STATEMENT OF JURISDICTION AND VENUE
5. This Court has jurisdiction over the state based claims the Plaintiffs bring, and
venue is proper because the Plaintiff resides in Allegheny County.

6. Plaintiff, Mr. Aldred, i.s informed and believes, and thereon alleges, that each of the
Defendants sued herein was negligently, wrongfully, and otherwise responsible in some
manner for the events and happenings as hereinafter described, and proximately caused
injuries and damages to Mr. Aldred. Further, Pittsburgh Police and one or more Doe
Defendants were, at all material times, responsible for the hiring, training, supervision, and
diScipline of the individual Defendants, Does 1-10.
7. Plaintiff, Mr. Aldred, is informed and believes, and thereon alleges, that each of the
individually named Defendants was at all material times an agent, servant, employee, partner,
joint venturer, co-conspirator, and/ or alter ego of the remaining Defendants, and in doing the
things herein alleged, was acting within the course and scope of that relationship. Mr. Aldred
is further inionned and believes, and thereon alleges, that each of the Defendants herein gave
consent, aid, and assistance to each of the remaining Defendants, and ratified and/ or
authorized the acts or omissions of each Defendant as alleged herein, except as may be
hereinafter otherwise specifically alleged.
8. At all material times, each Defendant was jointly engaged in tortuous activity, and
was an integral participant to the events and violations of rights described herein, resulting in
the deprivation of Plaintiff's constitutional rights and other harm.
9. At all material times, each Defendant acted under color of the laws, statutes,
ordinances, and regulations of the Commonwealth of Pennsylvania.
STATEMENT OF FACTS
BACKGROUND OF THE ATTACK
10. The matters complained of herein occurred on Friday, June 23, 2017, the morning of
Saturday, June 24,2017, at Mr. Aldred's home, located in the Mount Washington area of
Pittsburgh at 496 Norton Street, Pittsburgh Pennsylvania 15211.
11. Mr. Aldred lawfully rents his home pursuant to a written lease agreement. Mr.
Aldred has one roommate, Jason Chebatoris, who was not home when Does 1-10 first entered
their home. Chebatoris returned to the home after Does 1-10 had handcuffed and detained Mr.
Aldred on their front porch.
12. On June 24, 2017, Mr. Aldred's screen door was broken.
13. Following the incident complained of herein, Mr. Aldred learned that an anonymous
neighbor called the Pittsburgh Police to report that they suspected a burglary was taking place
at his home.
PLAINTIFF'S MEDICAL BACKGROUND
14. Mr. Aldred is legally blind, and also suffers from chronic post-traumatic stress
disorder, severe anxiety, lucid dreams and nightmares, Bipolar Disorder, and Borderline
Personality Disorder, among other ailments.
15. Mr. Aldred regularly takes various prescription medications, pursuant to his doctor's
orders, to b·eat the above-mentioned ailments and disorders.
16. On June 24, 2017, Mr. Aldred was transitioning to a new prescription medication to
treat his ailments and disorders, under his doctor's supervision.
17. Mr. Aldred believes that his adjustment to this new prescription medications further
hindered his perception, including his ability to understand and react to what was going on
inside of his home on the night of June 24, 2017.
THE ATTACK
18. On Friday, June 24, 2017, around 11 o'clock p.m., Mr. Aldred finished working as a
waiter at a restaurant located in downtown Pittsburgh. Mr. Aldred and two friends went to a
lounge, also located in downtown Pittsburgh.
19. Around 12:30 a.m., Mr. Aldred went back to his apartment in Mount Washington.
20. Upon returning home, Mr. Aldred noticed that his screen door was broken. His front
door, which was located behind the screen, was intact. Mr. Aldred was not bothered by the
broken screen door.
21. Mr. Aldred entered his home, and went to bed.
22. Mr. Aldred's bedroom encompasses the entire third floor of the house.
23. The second story of the house contains a common living area, and a second bedroom
where his roommate, Jason Chebatoris, lives. Chebatoris was not home at the time that Mr.
Aldred went to bed.
bed.
24. While Mr. Aldred was asleep in his bedroom on thc third story of his home, John Does
1-10, and one German Shepherd canine officer, entered his bedroom.
25.}ohn Does 1-10 each used a flashlight to gain a clear view of the inside of Mr. Aldred's
homc.
armounce their
26. Mr. Aldred did not hear John Does 1-10 enter his home, knock, or announce
presence. He first noticed Jolm Does 1-10 and the canine officer when they entered his third-floor
bedroom with their flashlights.
27. Mr. Aldred woke up, but was naturally confused about what was happening, and why
anyone was in his bedroom.
28. Mr. Aldred is legally blind, and receives various prescription medications.
29. Mr. Aldred was not armed, was sleeping in his own bedroom, and
ilnd naked.
30. Does 1-10 dragged him out of his bed, and on to the floor of his bedroom.
31. Mr. Aldred did not resist, attempt to flee, or make any
<lny threatening statements
srntements or
actions towards Does 1-10.
32. Mr. Aldred did not and does not have any outstanding warrants for his arrest.
33. None of the Defendants, Does 1-10, had either reasonable suspicion or probable cause
to believe that Mr. Aldred had committed a serious or violent crime, or that
thilt he was about to
flee. Mr. Aldred had nothing in his hands,
flee. h<lnds, which were clearly visible, was neither fleeing nor
resisting, and posed no immediate threat to Defendants Does 1-10, nor anyone else.
34. Despite this, and without warning, Defendants Does 1-10 unleashed the canine
officer on Mr. Aldred and allowed and encouraged the canine to attack Mr. Aldred.
35. Pursuant to Does 1-10's

1-10'5 conduct, the German Shepherd ran at Mr.
Mr. Aldred, who was
laying naked on the floor of his bedroom.
36. Mr. Aldred instinctively raised his right forearm in front of his face to shield it from
the dog's vicious attack.
37. The canine sunk his teeth all the way down into Mr. Aldred's right forearm, causing
him excruciating pain.
38. The canine continued to bite Mr. Aldred all over his right forearm and his outer right
thigh.
39. Mr. Aldred sustained noticeable SCqrs on his right arm and thigh area. The scars are
Iikely to be permanen t.
40. Mr. Aldred was bleeding profusely.
4]. Mr. Aldred asked John Does 1-10 what they were doing in his house.
42. Mr. Aldred repeatedly told Does 1-10 that he lived at the house.
43. Mr. Aldred begged Does 1-10 to stop the dog from attacking him.
44. In response, Does 1-10 placed handcuffs on Mr. Aldred behind his back, as he was on
his stomach, naked on his bedroom floor.
45. Mr. Aldred repeated to John 1-10 that he lived at the house, and asked them to stop the
dog from attacking him.
46. Does 1-10 responded that they needed to do more questioning.
47. Does 1-10 pulled Mr. Aldred off the floor and onto his feet, and walked him downstairs
to the second story of his house.
48. One of the officers grabbed a pair of track pants from the second-floor bedroom and
put them on Mr. Aldred, then continued walking him downstairs to the first floor.
49. Does 1-10 took the Plaintiff outside of his home and sat him on a couch on the front
porch.
50. Mr. Aldred was hysterical, and was crying and still bleeding profusely.
51. Mr. Aldred continued to tell John Does 1-10 that he lived at the house.
52. Does 1-10 nonetheless detained Mr. Aldred, and left him handcuffed on his couch on
his front porch, while they interrogated him without reason.
53. Numerous neighbors witnessed Does 1-10 intelTogate Mr. Aldred while he was in
handcuffs on his own front porch.
54. Around 2:00 o'clock a.m., Mr. Aldred's roommate, Jason Chebatoris, arrived home.
55. Chebatoris approached the front porch where Does 1-10 had detained Mr. Aldred, and
asked what had happened to his roommate.
56. Chebatoris told Does 1-10 that he lived at the home with Mr. Aldred.
57. Chebatoris showed Does 1-10 his driver's license, which contained the address of the
residence where the events complained of herein took place.
58. One of the Officers took Chebatoris to the side of the front porch to question him
separately.
59. Mr. Aldred told Does 1-10 that he had a medical condition that required attention.
60. One of the officers motioned for the other officers to leave the front porch. The officer
put on plastic gloves, and then approached Mr. Aldred and removed his handcuffs.
61. The Officer asked Mr. Aldred if he thought he needed to go to a hospital.
62. Mr. Aldred told the Officer that he absolutely needed to go to an emergency room
because he was still bleeding profusely and in excruciating pain from the attack.
•
63. An ambulance arrived while Chebatoris was being questioned by police in a separate
area.
'64. Mr. Aldred was able to walk himself into the back of the ambulance and sit on the
paramedic's ledge as he was transported to the room.
65. Mr. Aldred was taken to UPMC Mercy Emergency Room for treatment.
66. Mr. Aldred was prescribed antibiotics and painkillers for the severe cuts he suffered
from the dog attack.
67. Physicians wrapped the Plaintiff's right arm in gauze to contain the bleeding.
68. Mr. Aldred's treating physician ordered X-Rays of his right arm to be taken, to
determine if the deep dog bite had damaged his bone.
69. While being treated at UPMC Mercy Emergency Room, Mr. Aldred was visibly shaken
and hysterical due to the entire ordeal.
70. UPMC Mercy staff told the Plaintiff that he needed to calm down, but he was unable
remain calm due to the brutal attack.
71. Mr. Aldred was discharged around 8 o'clock a.m. on Saturday, June 24, 2017.
72. Mr. Aldred was still in pain, and so he went to Allegheny General hospital later that
day, June 24, 2017, and again the following day, June 25, 2017.
73. Plaintiff was not charged with any crimes, and was not given any citations or
paperwork regarding the incident.
74. At all times during Mr. Aldred's contact with Defendants, he behaved peacefully
and lawfully. Plaintiff never possessed or displayed any weapon, nor did he threaten anyone
in any way. Further, Plaintiff never resisted a lawful order and never attempted to escape.
75. Defendants lacked probable cause to believe Plaintiff had committed any crime.
76. The force used by Defendants Does 1-10 against Mr. Aldred was unjustified and
objectively unreasonable under the circumstances.
77. At all material times, Defendants' seizure of Mr. Aldred was done without probable
cause, reasonable sllspicion, or other legal right; lasted an excessive amount of time; and was
conducted unreasonably.
78. Alternatively, or concurrently, Defendants' own excessive and unreasonable actions

created the situation in which Does 1-10 decided to unlawfully seize and lise force against Mr.
Aldred, and caused an escalation of events leading to the unlawful seizure and use of force
against, and injury to, Mr. Aldred.
79. At all material times, and alternatively, the actions and omissions of each defendant
were intentional, wanton and/ or willful, conscience shocking, reckless, malicious, deliberately
indifferent to Mr. Aldred's rights, done with actual malice, grossly negligent, negligent, and
objectively unreasonable.
80. Mr. Aldred required medical h·eatment

h'eatment for his injuries caused by Defendants, and
Plaintiff has incurred medical bills.
81. As a direct and proximate result of each Defendant's acts and/or omissions as set
forth above, Plaintiff sustained the following injuries and damages, past and future, among
others: significant physical injuries requiring medical treatment, including but not limited to
multiple bites, puncture wounds, soft tissue injuries, cuts and lacerations; pain and suffering,
including emotional distress; medical expenses; violation of constitutional rights; all damages
U.s.c. §§ 1983, and as otherwise allowed under
and penalties recoverable under 42 U.S.c.
Pennsylvania
Permsylvania and United States statutes, codes, and common law.
82. Does 1-10 stood by and did nothing to order or restrain the dog from biting Mr.
Aldred.
Aldred.
83. Does 1-10 failed to give a command for the dog to stop biting Mr.
Mr. Aldred's arm.
84.
84. Although they were with Does 1-5, or close by him at all times, Does 5-10 failed to
intervene to stop them from allowing the dog to bite Aldred. Moreover, Officers Does 5-10
acted in concert with Does 1-5 in allowing the dog to bite Aldred.
Aldred .
85. At all times relevant to the facts set forth in this Complaint, Mr. Aldred was acting in
the exercise of due care for his own safety, welfare, and well being from harm.
COUNT I
NEGLIGENCE
Plaintiff, Robert Aldred, an individual

v.
v.
Defendants, The City of Pittsburgh
86. The averments set forth in paragraphs numbered one (1) through (85) are
incorporated by reference thereto as if more fully set forth herein.
87. The Defendant s Does 1-10, who was at all relevant times on June 23 and 24,201.7
were employed by the City of Pittsburgh, and on duty in the course of their employment,
owed a reasonable duty of care to Plaintiff in searching the home of the Plaintiff, especially
during the evening hours while the Plaintiff was asleep.
88. Does 1-10 failed to use reasonable care in the search of PlaiJ~tiff's home, as described
above, and thereby breached his duty to the Plaintiff which caused the injuries, as described
above, to the Plaintiffs.
89. At the time of the injuries to the Plaintiffs, Does 1-10 were the authorized employee,
agent, or servant of the City of Pittsburgh Police, and was acting in the course of employment
or otherwise, for the City of Pittsburgh. Accordingly, under the doctrine of respondeat superior
the City is liable to Plaintiff for the negligent acts of Does 1-10.
90. In addition, the City of Pittsburgh breached the duty of care it owed to the Plaintiff by
employing the Defendant Does 1-10 as its employees, agents, or servants and entrusting
Defendant Does 1-10 with the responsibility of safely searching for suspects, or aSSisting with
the search of the suspects, with a police dog. The Defendant Does 1-10 were not qualified to
perform this duty.
91. The Defendant City of Pittsburgh further breached its duty of care it owed to
Plaintiffs by failing to h'ain and/or supervise or properly train and/or supervise Does 1-10 in
searching for suspects, especially with the use of a police dog in connection with the Pittsburgh
Police.
92. As a direct and proximate result of the dog attacks on the Plaintiffs, as described
above, the Plaintiffs suffered and continue to suffer severe injuries of the mind and body, have
incurred medical expenses, permanent scarring, and have lost wages. Accordingly, the
Commonweal th is liable to the Plaintiffs.
COUNT II
VICARIOUS LIABILITY

v.
94. The Plaintiff asserts that under the broadest principles of vicarious liability the
Defendants the City of Pittsburgh is legally responsible for all of the acts herein alleged against
its employees, and Does 1-10 respectively, and perhaps others, committed within the scope of
their employment, who at all pertinent times were acting as officers of the law under color of
law within the scope of their employment.
95. Accordingly, under the principles of vicarious liability, as discussed in the

dissenting opinion of Board of Commissioners of Bryan County v. Brown, 520 U.s. 397 (1997),
the Defendants Barnstable County Sheriff's Office and Town of Falmouth are vicariously liable
for the acts, respectively of Defendants Does 1-10 for their violation of the Plaintiffs' civil and
constitutional rights.
96. The Plaintiffs bring this allegation as a good faith reservation of their right to seek a
change the law in this regard as set forth in Monnell v. Department of Social Services of the City
of New York, 436 U.S. 658 (1978).
WHEREFORE, Plaintiff requests judgment against the Defendant City of

Pittsburgh for compensatory damages and for punitive damages including costs of this
action, and all other relief the Court deems appropriate under the circumstances.
COUNT III
ASSAULT
Robert Aldred, an individual
v.
Defendants, Does 1-10, individually
98. Defendants intended to cause and did cause Mr. Aldred to suffer reasonable
apprehenSion of an immediate harmful contact.
WHEREFORE, Plaintiff requests judgment against the Defendants Does 1-
10, jointly and severally, for compensatory damages and for punitive damages
including costs of this action, and all other relief the Court deems appropriate under
the circumstances.
COUNT IV
BATTERY
v.
100. Defendants Pittsburgh Police, a municipal entity, and Does 1-10, individuals,
were in fact the aggressors, agitators and culprits harassing Mr. Aldred.
101. Defendants Pittsburgh Police., a municipal entity, and Does 1-10, individuals
intended to cause, and did in fact cause harmful contact upon Mr. Aldred's person.
102. Mr. Aldred did not consent to the Defendants' acts.
103. As a direct and proximate result of Defendants' conduct, Mr. Aldred suffered
extreme mental anguish, physical pain and humiliation.
104. As a direct and proximate result of Defendants' conduct, Mr. Aldred was
unnecessarily handcuffed and confined at his lawful home. Accordingly, Mr. Aldred is
entitled to compensatory damages in an amount to be determined by proof at trial.
105. Defendants' acts were done knowingly, willfully, and with malicious intent, and
Mr. Aldred is entitled to punitive damages in an amount to be determined by proof at trial.
WHEREFORE, Plaintiff demands judgment be entered against Defendants,
Does 1-10, in an amount in excess of the arbitration limits against the Defendants, 1-10,
for compensatory damages and for punitive damages including costs of this action, and
all other relief the Court deems appropriate under the circumstances.
COUNT V
INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

v.
107. When Defendant Officer Cummings, Defendant Officer Eisen, and Defendant
Deputy Sheriff Martin undertook the actions or when they failed to act, as described above,
they knew or should have known that emotional dish·ess was the likely result of their conduct.
108. Defendant Officer Cummings, Defendant Officer Eisen, and Ddendant Deputy
Sheriff Martin's actions and failure to act, as described above, were extreme and outrageous,
were beyond all possible bounds of decency, and were utterly intolerable in a civilized
community. The Defendants caused the Plaintiffs to sustain emotional distress so severe that no
reasonable person could be expected to endure it.
109. As a result of the conduct of the Defendants, tllerefore, the Plaintiff has suffered
and continues to suffer extreme emotional distress and anxiety. Consequently, the Defendants
are liable to the Plaintiffs for infliction of emotional distress.
COUNT VI
FALSE ARREST

v.
Defendants, City of PittsbUl"gh,
and Does 1-10, individually
111. The Plaintiff was illegally without a warrant or probable cause and detained in
his home by Defendants Does 1-10.
112. The detention of the Plaintiff was is unlawful.
113. The wrongful conduct of Does 1-10 is within Scope of their employment with the
City.
1]4. The actions or conduct of Does 1-"10 is the kind of conduct the City expects its'
officers to perform. The City has granted the officers broad authority and power.
115. Does 1-10's conduct was intentional and done in the service of its' duty to its
employer the City of Pittsburgh.
116. The force used by agents Does 1-10 was not expected by the City. Arresting the
Plaintiff in his home using lethal and dangerous weapons when he committed no crime is
unreasonable, wanton and reckless.
117. As a result of the conduct of the Defendants, therefore, the Plaintiff has suffered
are liable to the Plaintiffs for False Arrest.
WHEREFORE, Plaintiff requests judgment against the Defendants City of

Pittsburgh and Does 1-10, jointly and severally, for compensatory damages and for
punitive damages including costs of this action, and all other relief the Court deems
appropriate under the circumstances.
COUNT VII
FALSE IMPRISONMENT

v.
Defendants, City of Pittsburgh,
119. The Detention of the Plaintiff by John Does 1-10 was willful.
120. The Plaintiff did not consent to his detention by Does 1-10.
121. The detention by John Does 1-10 was unlawful.
are liable to the Plaintiffs for False Imprisonment.
City of Pittsburgh and Does 1-10, in an amount in excess of the arbitration limits against
the Defendants, 1-10, for compensatory damages and for punitive damages including
costs of this action, and all other relief the Court deems appropriate under the
circumstances.
COUNT VIII
VIOLATION OF PENNSYLVANIA GENERAL LAWS

3 P.S. section 459-101 to 1205, 3 P.S. section 501,531 to 532,
34 Pa.C.S.A. sections 2381 to 2386, and 34 Pa.e.S.A.
sections 2941 to 2945

v.
12'1. By his actions, described above, Does 1-10 were at all relevant times a keeper of the
police dog 01' another police dog.
125. At all relevant times, the Plaintiffs were not trespassing, teasing, tormenting or
abusing Does 1-10 or any police dog when Does 1-10, by their actions, caused the police dog to
bite the Plaintiff.
126. Plaintiff sustained serious physical and emotional injuries when the police canine
bit him while the police was under the keeper-ship of Defendants Does 1-10 on or about June
23-24, 2017.
127. At alll'elevant times, Does 1-10 assumed custody, management and control of the
police dog. By his status as a keeper of the dog, therefore, Does 1-10 are liable to the Plaintiff
for his injuries.
128. Defendants Does 1-10 may be entitled to indemnification for any exposure to
liability under the Pennsylvania Dog Bite Statutes but not immunity.
129. Accordingly, the Plaintiffs are entitled to relief under 3 P.S. section 459-101 to 1205,
:3 !'S. section 51H, 53'( to 532, 34 Pa.C.S.A. sections 2381 to 2386, and 34 P~.C.S.A. sections 2941
to 2945 (the "Dog Bite Statute") against Defendant Does 1-10.
PRA YERS FOR RELIEF
WHEREFORE, the Plaintiff Robert Aldred respectfully request that this Honorable
Court: Order judgment in Plaintiffs' favor in such a monetary amount as will fully compensate
each of lhem for their losses to the greatest extent allowed by law. Order sllch punitive
damages as are allowed by law. Order payment of interest, costs and attorneys fees. Order
such further relief as this Court deems fair and just.
TODD ]. HOLLIS LA W
~s2)Tod1:;:Esquire
Supreme Court 1.0. No. 72510
The Pittsburgher
428 Forbes Avenue, Suite 505
Phone: (412) 434.0252
Fax: (412) 434.0256
Email: toddjhollis@gmail.com
Dated: March 12, 2019

OocuSign Envelope 10: BAC59B92-D669-42A7-B01B-2FSBA66444JF
VERIFICATION
I verify that the I;,cts set forth in this Complaint are true and correct to the best or
my in/'onmltion and belief. I understand that Ili/se statements herein are made subject to
(he penalties or 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities.
10/12/2017
Date: _ _ _ _ _ _ __
'(lIOI!SM0t51l4JD_
Mr. Robert Aldred

PENNSYLV ANIA
Plaintiff, GO No.: 19·1728
CITY OF PITISBURGH, ACTING CHIEF OF . ., ""

,
i:Q=
POLICE REGINA McDONALD, OFFICER :;,;
1 •
JOHN DOE #1, OFFICER JOHN DOE #2, -:1' 11
OFFICER JOHN DOE # 3, OFFICER JOHN N r-
DOE #4, OFFICER JOHN DOE #5, III
OFFICER JOHN DOE #6, OFFICER JOHN "
~.
.c- 0
DOE #7, OFFICER JOHN DOE #8, OFFICER N
0
#10.
JURY TRIAL DEMANDED
Defendants.
I certify that this filing complies with : Filed on behalf of Plaintiff:

Policy of the Unified Judicial System of : ROBERT ALDRED
Pennsylvania: Case Records of the : Counsel of Record for tIlis Party:
Appellate and Trial Courts that require
filing confidential information and : Todd J. Hollis, Esquire
documents differently than : Todd J. Hollis Law
non-confidential information and : Pa. l.D. No. 72510
~R~
LHi:
Todd E~. -.
: The Pittsburgher
: 428 Forbes Avenue, Suite 505
: Pittsburgh PA 15219·1603
Attorney For Plaintiff : (412) 434.0252
Notice to Plead: : (412) 434.0256 Facsimile

You are hereby notified to file a written
: toddjhollis@gmail.com
response to the enclosed COMPLAINT IN
CIVIL ACTION within twenty (20) days from
servic~ ~a judgment may be entered
agains . ~ ~ ...:>
Todd J. Hollis, Esa. )

PENNSYLVANIA
ROBERT ALDRED, an individual CMLDMSION

JOHN DOE #1, OFFICER JOHN DOE #2, .
DOE #7, OFFICER JOHN DOE #8, OFFIC)::R
JOHN DOE # 9, & OFFICER JOHN DOE #10.
JURY TRIAL DEMANDED

Defendants.
NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the claims set forth in
the following pages, you must take action within twenty (20) days after this complaint
and notice are served, by entering a written appearance personally or by attorney and
filing in writing with the court your defenses or objections to the claims set forth against
you. You are warned that if you fail to do so the case may proceed without you and a
judgment may be entered against you by the court without further notice for any money
claimed in the complaint or for any claim or relief requested by the plaintiff. You may
lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU

DO NOT HAVE A LAWYER OR CANNOT AFFORD A LAWYER, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE
YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE

ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY
OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO
FEE.
LAWYER REFERRAL SERVICES
ALLEGHENY COUNTY BAR ASSOCIATION
...
920 CITY-COUNTY BUILDING
PITTSBURGH, PA 15219
PHONE: 412-261-0518

PENNSYLVANIA
Plaintiff, GO No.: 19-1728
v.
JURY TRIAL DEMANDED
JOHN OOE #1, OFFICER JOHN OOE #2,
OFFICER JOHN DOE # 3, OFFICER JOtIN
#10.
Defendants.
COMPLAINT IN CNIL ACTION
AND NOW comes the Plaintiff, Robert Aldred, by and through his attorney, Todd Jonathan
Hollis, Esquire, of Todd J. Hollis Law, and claims damages of the Defendants City of Pittsburgh,
Acting Chief of Police Regina McDonald, Officer John Doe #1, Officer Jolm Doe #2, Officer John
Doe #3, Officer John Doe #4, Officer John Doe #5, Officer John Doe #6, Officer John Doe #7 Officer
John Doe #8 Officer Jolm Doe #9 Officer John Doe #10, upon a cause of action whereof the
following are statements:
PARTIES
1. The Plaintiff, Robert Aldred ("Mr. Aldred), is an adult individual who resides in
Pittsburgh, County of Allegheny, Commonwealth of Pennsylvania.

2. Defendant City of Pittsburgh ("Ci~"), is a municipality within the
Commonwealth of Pennsylvania, with a principal place of business located at 414 Grant
Street, Pittsburgh, Pennsylvania 15219, which at all times relevant hereto, was authorized
to and did operate and maintain a police department. Defendant City of Pittsburgh was
acting by and through its duly authorized agents, employees and/ or assigns, who were
then and there acting within the course and scope of their employment under the color of
state law and in accordance with the custom, policies and practices of the City of
Pittsburgh.
3. Defendant Regina McDonald, was at all times relevant hereto, the acting Chief of
Police of the City of Pittsburgh Bureau of Police. She is sued in her individual capacity.
This defendant, at all times relevant hereto, had the day-to-day responsibility to ensure that
City of Pittsburgh police officers were properly trained, supervised, and disciplined, and
also, at all times relevant hereto.
4. Defendants John Doe one through ten (1-10) are adult individuals residing in the
City of Pittsburgh, who at all times relevant hereto, were employed as City of Pittsburgh
police officers and who with respect to the events alleged herein, were acting under the
color of state law and in accordance with the custom practices and/ or policies of the City of
Pittsburgh.
STATEMENT OF JURISDICTION AND VENUE
5. This Court has jurisdiction over the state based claims the Plaintiffs bring, and
venue is proper because the Plaintiff-resides :in Allegheny County.

Defendants sued herein was negligently, wrongfully, and otherwise responsible in some
manner for the events and happenings as hereinafter described, and proximately caused
injuries and damages to Mr. Aldred. Further, Pittsburgh Police and one or more Doe
Defendants were, at all material times, respO!l5ible for the hiring, training, supervision, and
discipline of the individual Defendants, Does 1-10.
individually named Defendants was· at all material times an agent, servant, employee, partner,
joint venturer, co-conspirator, and/ or alter ego of the remaining Defendants, and in doing the
things herein alleged, was acting within the course and scope of that relationship. Mr. Aldred
is further informed and believes, and thereon alleges, that each of the Defendants herein gave
consent, aid, and assistance to each of the remaining Defendants, and ratified and/ or
authorized the acts or omissions of each Def~ndant as alleged herein, except as may be
hereinafter otherwise specifically alleged.
8. At all material times, each Defendant was jointly engaged in tortuous activity, and
was an integral participant to the events and violations of rights described herein, resulting in
the deprivation of Plaintiff's constitutional rights and other harm.
9. At all material times, each Defendant acted under color of the laws, statutes,
ordinances, and regulations of the Commonwealth of Pennsylvania.
STATEMENT OF FACTS
BACKGROUND OF THE ATTACK
10. The matters complained of herein occurred on Friday, June 23, 2017, the morning of
Saturday, June 24, 2017, at Mr. Aldred's home, located in the Mount Washington area of
Pittsburgh at 496 Norton Street, Pitt~burgh Pennsylvania 15211.
11. Mr. Aldred lawfully rents his home pursuant to a written lease agreement. Mr.
Aldred has one roommate, Jason Chebatoris, who was not home when Does 1-10 first entered
their home. Chebatoris returned to the home after Does 1-10 had handcuffed and detained Mr.
Aldred on their front porch.
12. On June 24,2017, Mr. Aldred's screen door was broken.

13. Following the incident complained of herein, Mr. Aldred learned that an anonymous
neighbor called the Pittsburgh Police to report that they suspected a burglary was taking place
at his home.
PLAINTIFF'S MEDICAL BACKGROUND
14. Mr. Aldred is legally blind, and also suffers from chronic post-traumatic stress
disorder, severe anxiety, lucid dreams and nightmares, Bipolar Disorder, and Borderline
Personality Disorder, among other ailments.·
15. Mr. Aldred regularly takes various prescription medications, pursuant to his doctor's
orders, to treat the above:mentioned ailments and disorders.
16. On June 24, 2017, Mr. Aldred was transitioning to a new prescription medication to
treat his ailments and disorders, under his doctor's supervision.
17. Mr. Aldred believes that his adjustment to this new prescription medications further
hindered his perception, including his ability to understand and react to what was going on
inside of his home on the night of June 24, 2017.
THE ATTACK
18. On Friday, June 24, 2017, around 11 o'clock p.m., Mr. Aldred finished working as a
waiter at a restaurant located in downtown Pittsburgh. Mr. Aldred and two friends went to a
lounge, also located in downtown Pittsburgh.
19. Around 12:30 a.m., Mr. Aldred went back to his apartment in Mount Washington.
20. Upon returning home, Mr. Aldred noticed that his screen door was broken. His front
door, which was located behind the screen, was intact. Mr. Aldred was not bothered by the
broken screen door. .
21. Mr. Aldred entered his home, and went to bed.
22. Mr. Aldred's bedroom encompasses the entire third floor of the house.
23. The second story of the house contains a common living area, and a second bedroom
where his roommate, Jason Chebatoris, lives. Chebatoris was not home at the time that Mr.
Aldred went to bed.
24. While Mr. Aldred was asleep in his bedroom on the third story of his home, John Does
1-10, and one German Shepherd canine officer, entered his bedroom.
25. John Does 1-10 each used a flashlight to gain a clear view of the inside of Mr. Aldred's
home.
26. Mr. Aldred did not hear John Does 1-10 enter his h'ome, knock, or announce their
presence. He first noticed John Does 1-10 and the canine officer when they entered his third-floor
bedroom with their flashlights.
27. Mr. Aldred woke up, but was naturally confused about what was happening, and why
anyone was in his bedroom.
28. Mr. Aldred is legally blind, and receives various prescription medications.
29. Mr. Aldred was not armed, was sleeping in his own bedroom, and naked.
30. Does 1-10 dragged him out of his b~d, and on to the floor of his bedroom.
31. Mr. Aldred did not resist, attempt to flee, or make any threatening statements or
actions towards Does 1-10.
32. Mr. Aldred did not and does not have any outstanding warrants for his arrest.
33. None of the Defendants, Does 1-10, had either reasonable suspicion or probable cause
to believe that Mr. Aldred had committed a serious or violent crime, or that he was about to
flee. Mr. Aldred had nothing in his hands, which were clearly visible, was neither fleeing nor
resisting, and posed no immediate threat to Defendants Does 1-10, nor anyone else.
34. Despite this, and without warning, Defendants Does 1-10 unleashed the canine
officer on Mr. Aldred and allowed and encouraged the canine to attack Mr. Aldred.
35. Pursuant to Does 1-10's conduct, the German Shepherd ran at Mr. Aldred, who was
laying naked on the floor of his bedroom.
36. Mr. Aldred instinctively raised his right forearm in front of his face to shield it from
the dog's vicious attack.
37. The canine sunk his teeth all the way down into Mr. Aldred's right forearm, causing
him excruciating pain.
38. The canine continued to bite Mr. Aldred all over his right forearm and his outer right
thigh.
39. Mr. Aldred sustained noticeable scars on his right arm and thigh area. The scars are
likely to be permanent.
40. Mr. Aldred was bleeding profusely.
41. Mr. Aldred asked John Does 1-10 what they were doing in his house.
42. Mr. Aldred repeatedly told Does 1,10 that he lived at the house.
43. Mr. Aldred begged Does 1-10 to stop the dog from attacking him.
44. In response, Does 1-10 placed handcuffs on Mr. Aldred behind his back, as he was on
his stomach, naked on his bedroom floor.
45. Mr. Aldred repeated to John 1-10 that he lived at the house, and asked them to stop the
dog from attacking him.
46. Does 1-10 responded that they needed to do more questioning.
47. Does 1-10 pulled Mr. Aldred off the floor and onto his feet, and walked him downstairs
to the second story of his house.
48. One of the officers grabbed a pair of track pants from the second-floor bedroom and
put them on Mr. Aldred, then continued walking him downstairs to the first floor.
49. Does 1-10 took the Plaintiff outside of his home and sat him on a couch on the front
porch.
50. Mr. Aldred was hysterical, and was crying and still bleeding profusely.
51. Mr. Aldred continued to tell John Does 1-10 that he lived at the house.
52. Does 1-10 nonetheless detained Mr. Aldred, and left him handcuffed on his couch on
his front porch, while they interrogated him without reason.
53. Numerous neighbors witnessed Does 1-10 interrogate Mr. Aldred while he was in
handcuffs on his own front porch.
54. Around 2:00 o'dock a.m., Mr. Aldred's roommate, Jason Chebatoris, arrived home.
55. Chebatoris approached the front porch where Does 1-10 had detained Mr. Aldred, and
asked what had happened to his roommate.
56. Chebatoris told Does 1-10 that he lived at the home with Mr. Aldred.
57. Chebatoris showed Does 1-10 his driver's license, which contained the address of the
residence where the events complained of herein took place.
58. One of the Officers took Chebatoris to the side of the front porch to question him
separately.
59. Mr. Aldred told Does 1-10 that he had a medical condition that required attention.
60. One of the officers motioned for the other officers to leave the front porch. The officer
put on plastic gloves, and then approached Mr. Aldred and removed his handcuffs.
61. The Officer asked Mr. Aldred if he thought he needed to go to a hospital.
62. Mr. Aldred told the Officer that he absolutely needed to go to an emergency room
because he was still bleeding profusely and in excruciating pain from the attack.
63. An ambulance arrived while Chebatoris was being questioned by police in a separate
area.
64. Mr. Aldred was able to walk himself into the back of the ambulance and sit on the
paramedic's ledge as he was transported to the room.
65. Mr. Aldred was taken to UPMC Mercy Emergency Room for treatment.
66. Mr. Aldred was prescribed antibiotics and painkillers for the severe cuts he suffered
from the dog attack.
67. Physicians wrapped the Plaintiff's right arm in gauze to contain the bleeding.
68. Mr. Aldred's treating physician ordered X-Rays of his right arm to be taken, to
determine if the deep dog bite had damaged his bone.
69. While being treated at UPMC Mercy Emergency Room, Mr. Aldred was visibly shaken
and hysterical due to the entire ordeal.
70. UPMC Mercy staff told the Plaintiff that he needed to calm down, but he was unable
remain calm due to the brutal attack.
71. Mr. Aldred was discharged around 8 o'clock a.m. on Saturday, June 24, 2017.
72. Mr. Aldred was still in pain, and so he went to Allegheny General hospital later that
day, June 24, 2017, and again the following day, June 25, 2017.
73. Plaintiff was not charged with any crimes, and was not given any citations or
paperwork regarding the incident.
74. At all times during Mr. Aldred's contact with Defendants, he behaved peacefully
and lawfully. Plaintiff never possessed or displayed any weapon, nor did he threaten anyone
in any way. Further, Plaintiff never resisted a lawful order and never attempted to escape.
75. Defendants lacked probable cause to believe Plaintiff had committed any crime.
76. The force used by Defendants Does 1-10 against Mr. Aldred was unjustified and
objectively unreasonable under the circumstances.
77. At all material times, Defendants' seizure of Mr. Aldred was done without probable
cause, reasonable suspicion, or other legal right; lasted an excessive amount of time; and was
conducted unreasonably.
78. Alternatively, or concurrently, Defendants' own excessive and unreasonable actions

created the situation in which Does 1-10 decided to unlawfully seize and use force against Mr.
Aldred, and caused an escalation of events leading to the unlawful seizure and use of force
against, and injury to, Mr. Aldred.
79. At all material times, and alternatively, the actions and omissions of each defendant
were intentional, wanton and/ or willful, conscience shocking, reckless, malicious, deliberately
indifferent to Mr. Aldred's rights, done with actual malice, grossly negligent, negligent, and
objectively unreasonable.
80. Mr. Aldred required medical treatment for his injuries caused by Defendants, and
Plaintiff has incurred medical bills.
81. As a direct and proximate result of each Defendant's acts and/ or omissions as set
forth above, Plaintiff sustained the f!JlIowing injuries and damages, past and future, among
others: significant physical injuries requiring medical treatment, including but not limited to
multiple bites, puncture wounds, soft tissue injuries, cuts and lacerations; pain and suffering,
includingemotional distress; medical expenses; violation of constitutional rights; all damages
and penalties recoverable under 42 U.S.c. §§ 1983, and as otherwise allowed under
Pennsylvania and United States statutes, codes, and common law.
82. Does 1-10 stood by and did nothing to order or restrain the dog from biting Mr.
Aldred.
83. Does 1-10 failed to give a command for the dog to stop biting Mr. Aldred's arm.
84. Although they were with Does 1-5, or close by him at all times, Does 5-10 failed to
intervene to stop them from allowing the dog to bite Aldred. Moreover, Officers Does 5-10
acted in concert with Does 1-5 in allowing the dog to bite Aldred.
85. At all times relevant to the facts set forth in this Complaint, Mr. Aldred was acting in
the exercise of due care for his own safety, welfare, and well being from harm.
COUNT I
NEGLIGENCE

v.
87. The Defendant s Does 1-10, who was at all relevant times on June 23 and 24, 2017
were employed by the City of Pittsburgh, and on duty in the course of their employment,
owed a reasonable duty of care to Plaintiff in searching the home of the Plaintiff, especially
during the evening hours while the Plaintiff was asleep.
88. Does 1-10 failed to use reasonable care in the search of Plaintiff's home, as described
above, and thereby breached his duty to the Plaintiff which caused the injuries, as described
above, to the Plaintiffs.
89. At the time of the injuries to the Plaintiffs, Does 1-10 were the authorized employee,
agent, or servant of the City of Pittsburgh Police, and was acting in the course of employment
or otherwise, for the City of Pittsburgh. Accordingly, under the doctrine of respondeat superior
the City is liable to Plaintiff for the negligent acts of Does 1-10.
90. In addition, the City of Pittsburgh "breached the duty of care it owed to the Plaintiff by
employing the Defendant Does 1-10 as its employees, agents, or servants and entrusting
Defendant Does 1-10 with the responsibility of safely searching for suspects, or assisting with
the search of the suspects, with a police dog. The Defendant Does 1-10 were not qualified to
perform this duty.
91. The Defendant City of Pit~burgh further breached its duty of care it owed to
Plaintiffs by failing to train and/ or supervise or properly train and/ or supervise Does 1-10 in
searching for suspects, especially with the use of a police dog in connection with the Pittsburgh
Police.
92. As a direct, and proximate result of the dog attacks on the Plaintiffs, as described
above, the Plaintiffs suffered and continue to suffer severe injuries of the mind and body, have
incurred medical expenses, permanent scarring, and have lost wages. Accordingly, the
Commonweal th is liable to the Plaintiffs.
COUNT II
VICARIOUS LIABILITY

v.
94. The Plaintiff asserts that under the broadest principles of vicarious liability the
Defendants the City of Pittsburgh is legally responsible for all of the acts herein alleged against
its employees, and Does 1-10 respectively, ~d perhaps others, committed within the scope of
their employment, who at all pertinent times were acting as officers of the law under color of
law within the scope of their employment.
95. Accordingly, under the principles of vicarious liability, as discussed in the

dissenting opinion of Board of Commissioners of Bryan County v. Brown, 520 U.s. 397 (1997),
the Defendants Barnstable County Sheriff's Office and Town of Falmouth are vicariously liable
for the acts, respectively of Defendants Does 1-10 for their violation of the Plaintiffs' civil and
constitutional rights.
96. The Plaintiffs bring this allegation as a good faith reservation of their right to seek a
change the law in this regard as set forth in Monnell v. Department of Social Services of the City
of New York, 436 U.s. 658 (1978).
WHEREFORE,. Plaintiff requests judgment against the Defendant City of

Pittsburgh for compensatory damages and for punitive damages including costs of this
action, and all other relief the Court deems appropriate under the circumstances.
COUNT III
ASSAULT
v.
98. Defendants intended to cause and did cause Mr. Aldred to suffer reasonable
apprehension of an immediate harmful contact.
WHEREFORE, Plaintiff requests judgment against the Defendants Does l-

ID, jointly and severally, for compensatory damages and for punitive damages
including costs of this action, and all other relief the Court deems appropriate under
the circumstances.
COUNT IV
BATTERY
v.
incorporated by reference thereto as if mor~ fully set forth herein.
100. Defendants Pittsburgh Police, a municipal entity, and Does 1-10, individuals,
were in fact the aggressors, agitators and culprits harassing Mr: Aldred.
101. Defendants Pittsburgh Police., a municipal entity, and Does 1-10, individuals
intended to cause, and did in fact cause harmful contact upon Mr. Aldred's person.
102. Mr. Aldred did not consent to the Defendants' acts.
103. As a direct and proximate result of Defendants' conduct, Mr. Aldred suffered
extreme mental anguish, physical pain and humiliation.
104. As a direct and proximate result of Defendants' conduct, Mr. Aldred was
unnecessarily handcuffed and confined at his lawful home. Accordingly, Mr. Aldred is
entitled to compensatory damages in an amount to be determined by proof at trial.
105. Defendants' acts were done knowingly, willfully, and with malicious intent, and
Mr. Aldred is entitled to punitive damages in an amount to be determined by proof at trial.
COUNT V
INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

v.
107. When Defendant Officer Cummings, Defendant Officer Eisen, and Defendant
Deputy Sheriff Martin undertook the actions or when they failed to act, as described above,
they knew or should have known that emotional distress was the likely result of their conduct.
108. Defendant Officer Cummings, Defendant Officer Eisen, and Defendant Deputy
Sheriff Martin's actions and failure tb act, as described above, were extreme and outrageous,
were beyond all pOSSible bounds of decency, and were utterly intolerable in a civilized
community. The Defendants caused .the Plaintiffs to sustain emotional distress so severe that no
reasonable person could be expected to endure it.
109. As a result of the conduct of the Oefendants, therefore, the Plaintiff has suffered
and continues to suffer extreme emotional distress and anxiety. Consequently, tlle Defendants
are liable to the Plaintiffs for infliction of emotional distress.
Does 1-10, in an amount in excess of the arb;itration limits against the Defendants, 1-10,
COUNT VI
FALSE ARREST

v.
111. The Plaintiff was illegally without a warrant or probable cause and detained in
his home by Defendants Does 1-10.
112. The detention of the Plaintiff was is unlawful.
113. The wrongful conduct of Does 1-10 is within Scope of their employment with the
City.
114. The actions or conduct of Does 1-10 is the kind of conduct the City expects its'
officers to perform. The City has granted the officers broad authority and power.
115. Doesl-10's conduct was intentional and done in the service of its' duty to its
employer the City of Pittsburgh..
'.
116. The force used by agents Does 1-10 was not expected by the City. Arresting the
Plaintiff in his home using lethal and dangerous weapons when he committed no crime is
unreasonable, wanton and reckless.
are liable to the Plaintiffs for False Arrest.
WHEREFORE, Plaintiff requests judgment against the Defendants City of

Pittsburgh and Does 1-10, jointly and severally, for compensatory damages and for
punitive damages including costs of this action, and all other relief the Court deems
appropriate under the circumstances.
COUNT VII
FALSE IMPRISONMENT

v.
119. The Detention of the Plaintiff by John Does 1-10 was willful.
120. The Plaintiff did not consent to his detention by Does 1-10.
121. The detention by John Does 1-10 was unlawful.
122. As a result of the conduCt of the Defendants, therefore, the Plaintiff has suffered
are liable to the Plaintiffs for False Imprisonment.
City of Pittsburgh and Does 1-10, in an amount in excess of the arbitration limits against
the Defendants, 1-10, for compensatory damages and for punitive damages including
costs of this action, and all other relief the Court deems appropriate under the
circumstances.
COUNT VIII
VIOLATION OF PENNSYLVANIA GENERAL LAWS

3 P.S. section 459-101 to 1205, 3 P.S. section 501, 531 to 532,
34 Pa.C.S.A. sections 2381 to 2386, and 34 Pa.C.S.A.
sections 2941 to 2945

v.
124. By his actions, described above, Does 1-10 were at all relevant times a keeper of the
police dog or another police dog.
125. At all relevant times, the Plaintiffs were not trespassing, teasing, tormenting or
abusing Does 1-10 or any police dog when Does 1-10, by their actions, caused the police dog to
bi te the Plaintiff.
126. Plaintiff sustained serious physical and emotional injuries when the police canine
bit him while the police was under the keeper-ship of Defendants Does 1-10 on or about June
23-24, 2017.
127. At all relevant times, Does 1-10 assumed custody, management and control of the
police dog. By his status as a keeper of the dog, therefore, Does 1-10 are liable to the Plaintiff
for his injuries.
128. Defendants Does 1-10 may be e~titled to indemnification for any exposure to
liability under the Pennsylvania Dog Bite Statutes but not immunity.
129. Accordingly, the Plaintiffs are entitled to relief under 3 P.S. section 459-101 to 1205,
3 P.S. section 501, 531 to 532, 34 Pa.C.S.A. sections 2381 to 2386, and 34 Pa.C.S.A. sections 2941
to 2945 (the "Dog Bite Statute") against Defendant Does 1-10.
PRAYERS FOR RELIEF
WHEREFORE, the Plaintiff Robert Aldred respectfully request that this Honorable
Court: Order judgment in Plaintiffs' favor in such a monetary amount as will fully compensate
each of them for their losses to the greatest extent allowed by law. Order such punitive
damages as are allowed by law. Order payment of interest, costs and attorneys fees. Order
such further relief as this Court deems fair and just.
TODD J. HOLLIS LAW
~~Q~
TO<rn~\.sqUire
Supreme Court 1.0. No. 72510
The Pittsburgher
Phone: (412) 434.0252
Fax: (412) 434.0256
Email: toddjhollis@gmail.com
Dated: March 12,2019

o.ocuSign Envelope 10: BAC59B92·0669-42A7-8018·2F5BA664443F
VERI FICATlON
I verify that the facts set forth in this Complaint are true and correct to the best of
my information and belief. I understand that false statements herein are made subject to
the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities.
10/12/2017
Date: _ _ _ _ _ _ __
Mr. Robert Aldred
...
IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
HS c" _
Plaintiff, No. GO 19-1728
v. Code:
CITY OF PITTSBURGH, ACTING CI-IIEF Issue No.:

OF POLICE REGINA MCDONALD,
OFFICER JOHN DOE #1, OFFICER JOI-IN PRAECIPE FOR APPEARANCE
DOE #7, OFFICER JOI-IN DOE #8, OFFICER
JOI-IN DOE #9, & OFFICER JOI·IN DOE 1110.
Defendants.
Filed on behalf of Defendants

CITY OF PITrSBURGH and ACTING CHIEF OF
POLICE REGINA MCDONALD
,,>
0
9::;::-'-c. Counsel of Record for this Party:
..
C'J 0:.: (""r_
0 -
:;::
<:::> -== -..
":...) (n:.
IJ': . Julie E. Koren
W ~ , ''':.\ , Assistant City Solicitor
--.l .. . -'._ ,
1.1) , ~I
.' : '~ . ,..

Pa. !.D. 11309642
LL 0:: ,.. -"-; ;.:.
CL.
0::: t-_::_ !.L,
Yvonne S. Hilton
e-. r. -._.--
City Solicitor
l.Lj (-.::. :-t
t:'..J
Pa. l.D. 1174582
City of Pittsburgh
Department of Law
Firm 11046
313 City-County Building

414 Grant Street
(412) 255-2032
julie.koren@pittsburghpa.gov
.JURY TRIAL DEMANDED
I ...
ROBERT ALDRED, an individual, CIVIL DIVISION
Plaintiff, No. GO 19-1728
v. Code:
CITY OF PITTSBURGH, ACTING CI-IIEF Issue No.:

OF POLICE REGINA MCDONALD,
DOE #8, OFFICER JOHN DOE #9, &
OFFICER JOHN DOE #10.
Defendants.
PRAECIPE FOR APPEARANCE
TO: Michael McGeever, Director of Court Records
Sir:
Kindly enter the appearance of Julie E. Koren, Assistant City Solicitor and Yvonne S.
Hilton, City Solicitor, on behalf of the Defendants City of Pittsburgh and Acting Chief of Police
Regina McDonald in the above-referenced matter.
J lie E. Koren
ssistant City Solicitor
lsi Yvonne S. Hillon

City Solicitor
.•
,
CERTIFICATE OF COMPLIANCE
I certify that this filing complies with the provisions of the Public Access Policy of the
Unified Judicial System ofPennsylvania: Case Records of the Appel/ate and Trial Courts that
require filing confidential information and documents differently than non-confidential
information and documents.
Submitted
Signature: ~!,M>~-1JL!.l'&!"-----
Name: JU'
~~-----------
Attorney No. (if applicable): 309642
Rev. 09/2017
GD 19-1728
.,
CERTIFICATE OF SERVICE
I hereby certify that on April 15, 2019, a true and correct copy of the within Praecipe for
Appearance was delivered first class mail, postage prepaid, to:
Todd J. Hollis, Esquire

Todd J. Hollis Law
The Pittsburgher
Pittsburgh PA 15219-1603
(Coul/sel/or Plail/tiff)
1
A istant City Solicitor

Plaintiff,
v. GD No.:19-001728
CITY OF PI'ITSBURGH, ACTING CHIEF
OF POLICE REGINA McDONALD,
OFFICER JOHN DOE #1, OFFICER JOHN Code:
DOE #2, OFFICER JOHN DOE # 3,
OFFICER JOHN DOE #7, OFFICER JOHN PRAECIPE TO REINSTATE COMPLAINT
DOE #8, OFFICER JOHN DOE # 9, &
OFFICER JOHN DOE #10.
Defendants.
I certifY that this filing complies with Filed on behalf of Plaintiff:

Policy of the Unified Judicial System of ROBERT ALDRED
Pennsylvania: Case Records of the
Appellate and Trial Courts that require Counsel of Record for this Party:
filing confidential information and
documents differently than Todd J. Hollis, Esquire
non-confidential information and Pa. 1.0. No. 72510
~'--Cl
Todd~ sq.
) Todd J. Hollis Law
The Pittsburgher
Attorney intiff Pittsburgh PA 15219-1603
(412) 434.0252
(412) 434.0256 Facsimile
toddjholliS@grnail.com
a
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Plaintiff, )
v. ) GDNo.:19-001728
CITY OF PITTSBURGH, ACTING )
CHIEF OF POLICE REGINA )
McDONALD, OFFICER JOHN DOE )
#1, OFFICER JOHN DOE #2, )
OFFICER JOHN DOE # 3, OFFICER )
JOHN DOE #4, OFFICER JOHN DOE)
#5, OFFICER JOHN DOE #6, )
OFFICER JOHN DOE #7, OFFICER )
JOHN DOE #8, OFFICER JOHN DOE )
# 9, & OFFICER JOHN DOE # 10. )
Defendants. ) JURY TRIAL DEMANDED
PRAECIPE TO REINSTATE COMPLAINT
To the Department of Court Records:
Kindly reinstate the Complaint in the above captioned matter.
By:_~~t;:S;;~=~L
Couns
The Pittsburg er
Pittsburgh, Pennsylvania 15219
412.434.0252
412.434.0256
Date: June 20, 2019 toddjhollis@gmail.com
· " " ,.

PENNSYL VANIA
ROBERT ALDRED, an individual CIVIL ACTION
Plaintiff, GD No.:19-001728
,
v. PLAINTIFF'S CONSENTEQ.:MQTIO~
G1 ~ c:= - fi1LI
FOR LEAVE TO AMEND C::0.1fPLA®:T
:z: 'Tl -' Z ~ .... r.::o
m~ ::-, N
Z:... c
CITY OF PITTSBURGH, ACTING CHIEF OF -C;=c
n~;.rJ
0 0 -\ :E::o
POLICE REGINA McDONALD, OFFICER ~< ;::: :z
"'. _ r:;
MICHAEL SOROCZAK, OFFICER JOSHUA -I v ") {" -
MATTHEWS and OFFICER LOGAN HANLEY. ,.'" ;:: W

IJ!)
JURY TRIAL DEMANDED
Defendants.
QRDER OF THE COURT
AND NOW, this Vdayof ~ 2019, upon consideration of the foregoing Motion, it is
hereby ORDERED and DECREED that the Plaintiffs Consented Motion For Leave To Amend
Complaint is GRANTED.
/-_.=....:'--_ _ _ _~J.
.,
RO ERT ALDRED, an individual CIVIL DIVISION

Plaintiff,
v. GD No.:19-001728
CI OF PITISBURGH et al
Defendants. Code:
I C~iiY that this filing complies with Filed on behalf of Plaintiff:

the rovisions of the Public Access
Poli y of the Unified Judicial System of ROBERT ALDRED
Pe sylvimia: Case Records of the
Appellate and Trial Courts that require Counsel of Record for this Party:
fi lin~ confidential information and
documents differently than Todd J. Hollis, Esquire
non1confidential information and Pa. J.D. No. 72510
cllments.
Todd J. Hollis Law
The Pittsburgher
Pittsburgh PA 15219-1603
(412) 434.0252
(412) 434.0256 Facsimile
toddjholliS@gmail.com
aI :C Ud 8- lnr 6IUZ
q::{"U.:J
.1 •

Plaintiff, )
v. )' GD No.:19-001728
)
CITY OF PITTSBURGH et al )
Defendants. )
)
)
)
)
),
)
)
) JURY TRIAL DEMANDED
To the Department of Court Records:
Kindly reinstate the Complaint in the above captioned matter.
B.
Counsel to Plai
The Pitts urg er
Pittsburgh, Pennsylvania 15219
412.434.0252
412.434.0256
Date: July 8, 2019 toddjhollis@gmail.com
Detail of Plaintiff's various claims under Pennsylvania Exhibit B
Law
3 P.S. Section 459-101 to 1205 – This Allegation includes the entirety of what is known and
cited as the Pennsylvania “Dog Law”
3 P.S. Section 501: Loss of livestock from rabies caused by bite of dog
3 P.S. Section 531: Dogs worrying or accustomed to worry sheep
3 P.S. Section 532: How damages recovered
34 Pa. C.S.A. sections 2381: Dogs pursuing, injuring or killing games or wildlife
34 Pa. C.S.A. sections 2382: Training dogs on Small Game
34 Pa. C.S.A. sections 2383: Dogs pursuing, injuring or killing big game
34 Pa. C.S.A. sections 2384: Declaring dogs public nuisances
34 Pa. C.S.A. sections 2385: Destruction of dogs declared public nuisances
34 Pa. C.S.A. sections 2386: Penalties
34 Pa. C.S.A. Section 2941: Dog training areas
34 Pa. C.S.A. Section 2942: Special retriever training areas
34 Pa. C.S.A. Section 2943: Field dog trials
34 Pa. C.S.A. Section 2944: Field dog trials for retrievers
34 Pa. C.S.A. Section 2945: Fox chasing

JS 44 (Rev. 12/12)
CIVIL COVER SHEET
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)
I. (a) PLAINTIFFS DEFENDANTS

ROBERT ALDRED, an individual CITY OF PITTSBURGH, ACTING CHIEF OF POLICE REGINA
McDONALD, OFFICER MICHAEL SOROCZAK, OFFICER JOSHUA
MATTHEWS, and OFFICER LOGAN HANLEY
(b) County of Residence of First Listed Plaintiff Allegheny County of Residence of First Listed Defendant Allegheny
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.
(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)
Todd J. Hollis, Esq.; Todd J. Hollis Law Julie E. Koren, Esq., City of Pittsburgh Dept. of Law
The Pittsburgher/428 Forbes Ave., Suite 505 414 Grant Street. 3rd Fl.
Pittsburgh, PA 15219-1603 Pittsburgh, PA 15219
II. BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff
(For Diversity Cases Only) and One Box for Defendant)
’ 1 U.S. Government ’ 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State ’ 1 ’ 1 Incorporated or Principal Place ’ 4 ’ 4
of Business In This State
’ 2 U.S. Government ’ 4 Diversity Citizen of Another State ’ 2 ’ 2 Incorporated and Principal Place ’ 5 ’ 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State
Citizen or Subject of a ’ 3 ’ 3 Foreign Nation ’ 6 ’ 6

Foreign Country
IV. NATURE OF SUIT (Place an “X” in One Box Only)
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
’ 110 Insurance PERSONAL INJURY PERSONAL INJURY ’ 625 Drug Related Seizure ’ 422 Appeal 28 USC 158 ’ 375 False Claims Act
’ 120 Marine ’ 310 Airplane ’ 365 Personal Injury - of Property 21 USC 881 ’ 423 Withdrawal ’ 400 State Reapportionment
’ 130 Miller Act ’ 315 Airplane Product Product Liability ’ 690 Other 28 USC 157 ’ 410 Antitrust
’ 140 Negotiable Instrument Liability ’ 367 Health Care/ ’ 430 Banks and Banking
’ 150 Recovery of Overpayment ’ 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS ’ 450 Commerce
& Enforcement of Judgment Slander Personal Injury ’ 820 Copyrights ’ 460 Deportation
’ 151 Medicare Act ’ 330 Federal Employers’ Product Liability ’ 830 Patent ’ 470 Racketeer Influenced and
’ 152 Recovery of Defaulted Liability ’ 368 Asbestos Personal ’ 840 Trademark Corrupt Organizations
Student Loans ’ 340 Marine Injury Product ’ 480 Consumer Credit
(Excludes Veterans) ’ 345 Marine Product Liability LABOR SOCIAL SECURITY ’ 490 Cable/Sat TV
’ 153 Recovery of Overpayment Liability PERSONAL PROPERTY ’ 710 Fair Labor Standards ’ 861 HIA (1395ff) ’ 850 Securities/Commodities/
of Veteran’s Benefits ’ 350 Motor Vehicle ’ 370 Other Fraud Act ’ 862 Black Lung (923) Exchange
’ 160 Stockholders’ Suits ’ 355 Motor Vehicle ’ 371 Truth in Lending ’ 720 Labor/Management ’ 863 DIWC/DIWW (405(g)) ’ 890 Other Statutory Actions
’ 190 Other Contract Product Liability ’ 380 Other Personal Relations ’ 864 SSID Title XVI ’ 891 Agricultural Acts
’ 195 Contract Product Liability ’ 360 Other Personal Property Damage ’ 740 Railway Labor Act ’ 865 RSI (405(g)) ’ 893 Environmental Matters
’ 196 Franchise Injury ’ 385 Property Damage ’ 751 Family and Medical ’ 895 Freedom of Information
’ 362 Personal Injury - Product Liability Leave Act Act
Medical Malpractice ’ 790 Other Labor Litigation ’ 896 Arbitration
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS ’ 791 Employee Retirement FEDERAL TAX SUITS ’ 899 Administrative Procedure
’ 210 Land Condemnation ’ 440 Other Civil Rights Habeas Corpus: Income Security Act ’ 870 Taxes (U.S. Plaintiff Act/Review or Appeal of
’ 220 Foreclosure ’ 441 Voting ’ 463 Alien Detainee or Defendant) Agency Decision
’ 230 Rent Lease & Ejectment ’ 442 Employment ’ 510 Motions to Vacate ’ 871 IRS—Third Party ’ 950 Constitutionality of
’ 240 Torts to Land ’ 443 Housing/ Sentence 26 USC 7609 State Statutes
’ 245 Tort Product Liability Accommodations ’ 530 General
’ 290 All Other Real Property ’ 445 Amer. w/Disabilities - ’ 535 Death Penalty IMMIGRATION
Employment Other: ’ 462 Naturalization Application
’ 446 Amer. w/Disabilities - ’ 540 Mandamus & Other ’ 465 Other Immigration
Other ’ 550 Civil Rights Actions
’ 448 Education ’ 555 Prison Condition
’ 560 Civil Detainee -
Conditions of
Confinement
V. ORIGIN (Place an “X” in One Box Only)
’ 1 Original ’ 2 Removed from ’ 3 Remanded from ’ 4 Reinstated or ’ 5 Transferred from ’ 6 Multidistrict
Proceeding State Court Appellate Court Reopened Another District Litigation
(specify)
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
42 U.S.C. §§1983
VI. CAUSE OF ACTION Brief description of cause:
Claims alleging that officers and municipality violated Plaintiff's alleged 4th Amendment rights with use of force.
VII. REQUESTED IN ’ CHECK IF THIS IS A CLASS ACTION DEMAND $ CHECK YES only if demanded in complaint:
COMPLAINT: UNDER RULE 23, F.R.Cv.P. JURY DEMAND: ’ Yes ’ No
VIII. RELATED CASE(S)
(See instructions):
IF ANY JUDGE DOCKET NUMBER
DATE SIGNATURE OF ATTORNEY OF RECORD
07/12/2019 /s/ Julie E. Koren
FOR OFFICE USE ONLY
RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE
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JS 44AREVISED June, 2009

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA
THIS CASE DESIGNATION SHEET MUST BE COMPLETED
PART A
This case belongs on the ( Erie Johnstown Pittsburgh) calendar.
1. ERIE CALENDAR - If
cause of action arose in the counties of Crawford, Elk, Erie,
Forest, McKean. Venang or Warren, OR any plaintiff or defendant resides in one of said
counties.
2. JOHNSTOWN CALENDAR - If cause of action arose in the counties of Bedford, Blair,
Cambria, Clearfield or Somerset OR any plaintiff or defendant resides in one of
said counties.
3. Complete if on ERIE CALENDAR: I certify that the cause of action arose in

County and that the resides in County.
4. Complete if on JOHNSTOWN CALENDAR: I certify that the cause of action arose in

County and that the resides in County.
PART B (You are to check ONE of the following)

1. This case is related to Number . Short Caption .
2. This case is not related to a pending or terminated case.
DEFINlTIONS OF RELATED CASES:

CIVIL: Civil cases are deemed related when a case filed relates to property included in
another suit or involves the same issues of fact or it grows out of the same transactions
as another suit or involves the validity or infringement of a patent involved in another
suit EMINENT DOMAIN: Cases in contiguous closely located groups and in common ownership
groups which will lend themselves to consolidation for trial shall be deemed related.
HABEAS CORPUS & CIVIL RIGHTS: All habeas corpus petitions filed by the same individual
shall be deemed related. All pro se Civil Rights actions by the same individual shall be
deemed related.
PARTC
I. CIVIL CATEGORY (Select the applicable category).
1. Antitrust and Securities Act Cases
2. Labor-Management Relations
3. Habeas corpus
4. Civil Rights
5. Patent, Copyright, and Trademark
6. Eminent Domain
7. All other federal question cases
8. All personal and property damage tort cases, including maritime, FELA,
Jones Act, Motor vehicle, products liability, assault, defamation, malicious
prosecution, and false arrest
9. Insurance indemnity, contract and other diversity cases.
10. Government Collection Cases (shall include HEW Student Loans (Education),
V A 0verpayment, Overpayment of Social Security, Enlistment
Overpayment (Army, Navy, etc.), HUD Loans, GAO Loans (Misc. Types),
Mortgage Foreclosures, SBA Loans, Civil Penalties and Coal Mine
Penalty and Reclamation Fees.)
I certify that to the best of my knowledge the entries on this Case Designation
Sheet are true and correct
/s/ Julie E. Koren
Date: 7/11/2019
ATTORNEY AT LAW
NOTE: ALL SECTIONS OF BOTH )2506 MUST BE COMPLETED BEFORE CASE CAN BE PROCESSED.
JS 44 Reverse (Rev. 12/12) Case 2:19-cv-00838-DSC Document 1-4 Filed 07/12/19 Page 3 of 3
INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44
Authority For Civil Cover Sheet
The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as
required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is
required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of
Court for each civil complaint filed. The attorney filing a case should complete the form as follows:
I.(a) Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, use
only the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency and
then the official, giving both name and title.
(b) County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at the
time of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In land
condemnation cases, the county of residence of the "defendant" is the location of the tract of land involved.)
(c) Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an attachment, noting
in this section "(see attachment)".
II. Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.Cv.P., which requires that jurisdictions be shown in pleadings. Place an "X"
in one of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below.
United States plaintiff. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here.
United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies, place an "X" in this box.
Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendment
to the Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiff or defendant code takes
precedence, and box 1 or 2 should be marked.
Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked, the
citizenship of the different parties must be checked. (See Section III below; NOTE: federal question actions take precedence over diversity
cases.)
III. Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if diversity of citizenship was indicated above. Mark this
section for each principal party.
IV. Nature of Suit. Place an "X" in the appropriate box. If the nature of suit cannot be determined, be sure the cause of action, in Section VI below, is
sufficient to enable the deputy clerk or the statistical clerk(s) in the Administrative Office to determine the nature of suit. If the cause fits more than
one nature of suit, select the most definitive.
V. Origin. Place an "X" in one of the six boxes.

Original Proceedings. (1) Cases which originate in the United States district courts.
Removed from State Court. (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U.S.C., Section 1441.
When the petition for removal is granted, check this box.
Remanded from Appellate Court. (3) Check this box for cases remanded to the district court for further action. Use the date of remand as the filing
date.
Reinstated or Reopened. (4) Check this box for cases reinstated or reopened in the district court. Use the reopening date as the filing date.
Transferred from Another District. (5) For cases transferred under Title 28 U.S.C. Section 1404(a). Do not use this for within district transfers or
multidistrict litigation transfers.
Multidistrict Litigation. (6) Check this box when a multidistrict case is transferred into the district under authority of Title 28 U.S.C. Section 1407.
When this box is checked, do not check (5) above.
VI. Cause of Action. Report the civil statute directly related to the cause of action and give a brief description of the cause. Do not cite jurisdictional
statutes unless diversity. Example: U.S. Civil Statute: 47 USC 553 Brief Description: Unauthorized reception of cable service
VII. Requested in Complaint. Class Action. Place an "X" in this box if you are filing a class action under Rule 23, F.R.Cv.P.
Demand. In this space enter the actual dollar amount being demanded or indicate other demand, such as a preliminary injunction.
Jury Demand. Check the appropriate box to indicate whether or not a jury is being demanded.
VIII. Related Cases. This section of the JS 44 is used to reference related pending cases, if any. If there are related pending cases, insert the docket
numbers and the corresponding judge names for such cases.
Date and Attorney Signature. Date and sign the civil cover sheet.

Aldred V City of Pittsburgh, PAWD 19-cv-00838 (12 July 2019) Doc 1, COMPLAINT With 4 Enclosures

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Case 2:19-cv-00838-DSC Document 1 Filed 07/12/19 Page 1 of 3

IN THE UNITED STATES DISTRICT COURT

ROBERT ALDRED, an individual ) CIVIL DIVISION

District Court pursuant to 28 U.S.C. §§ 1441(a) and 1446.

accepted service between June 21, 2019, and July 9, 2019.

5. Plaintiff’s Amended Complaint alleges violations of Plaintiff’s Fourth Amendment

6. According to 28 U.S.C. § 1331, this Court has jurisdiction because Plaintiff’s

claims are made pursuant to federal law.

district for removal.

Chief McDonald, consent to removal pursuant to 28 U.S.C. § 1446.

9. As later-served Defendants, Officers Michael Soroczak, Joshua Matthews and

/s/ Julie E. Koren

IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY,

ROBERT ALDRED, an individual CIVIL DIVISION

Plaintiff, GD No.: 19-1728

v. COMPLAINT IN CNIL ACTION

CITY OF PITTSBURGH, ACTING CHIEF OF

I certify that this filing complies with : Filed on behalf of Plaintiff:

: (412) 434.0256 Facsimile

IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY,

ROBERT ALDRED, an individual CIVIL DIVISION

CITY OF PITTSBURGH, ACTING CHIEF OF

YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU

IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE

IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY,

ROBERT ALDRED, an individual CIVIL DIVISION

Plaintiff, GD No.: 19-1728

JURY TRIAL DEMANDED

COMPLAINT IN CIVIL ACfION

Pittsburgh, County of Allegheny, Commonwealth of Pennsylvania.

2. Defendant City of Pittsburgh CCity"), is a municipality within the

Commonwealth of Pennsylvania, with a prin.cipal place of business located at 414 Grant

also, Olt all times relevant hereto.

STATEMENT OF JURISDICTION AND VENUE

venue is proper because the Plaintiff resides in Allegheny County.

PLAINTIFF'S MEDICAL BACKGROUND

21. Mr. Aldred entered his home, and went to bed.

35. Pursuant to Does 1-10's

40. Mr. Aldred was bleeding profusely.

46. Does 1-10 responded that they needed to do more questioning.

61. The Officer asked Mr. Aldred if he thought he needed to go to a hospital.

78. Alternatively, or concurrently, Defendants' own excessive and unreasonable actions

80. Mr. Aldred required medical h·eatment

Plaintiff, Robert Aldred, an individual

Plaintiff, Robert Aldred, an individual

95. Accordingly, under the principles of vicarious liability, as discussed in the

WHEREFORE, Plaintiff requests judgment against the Defendant City of

102. Mr. Aldred did not consent to the Defendants' acts.

WHEREFORE, Plaintiff demands judgment be entered against Defendants,

Robert Aldred, an individual

WHEREFORE, Plaintiff demands judgment be entered against Defendants,

Robert Aldred, an individual

112. The detention of the Plaintiff was is unlawful.

WHEREFORE, Plaintiff requests judgment against the Defendants City of

Robert Aldred, an individual

121. The detention by John Does 1-10 was unlawful.

WHEREFORE, Plaintiff demands judgment be entered against Defendants,

VIOLATION OF PENNSYLVANIA GENERAL LAWS

Robert Aldred, an individual

PRA YERS FOR RELIEF

Dated: March 12, 2019

IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY,

ROBERT ALDRED, an individual CIVIL DIVISION