UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF OHIO

EASTERN DIVISION

JOSHUA BRADLEY, JUDGE:

PLAINTIFF, CASE NUMBER:

vs.

THE CITY OF CLEVELAND HEIGHTS

40 SEVERANCE CIRCLE, CLEVELAND HEIGHTS, OHIO 44118

&

OFFICER B.P.O. MICHAEL Laurello

(IN HIS OFFICIAL AND INDIVIDUAL CAPACITIES)
C/O CLEVELAND HEIGHTS POLICE DEPARTMENT/
40 SEVERANCE CIRCLE, CLEVELAND HEIGHTS, OHIO 44118

&

OFFICER LEWIS E. ALVIS

(IN HIS OFFICIAL AND INDIVIDUAL CAPACITIES)
C/O CLEVELAND HEIGHTS POLICE DEPARTMENT/
40 SEVERANCE CIRCLE, CLEVELAND HEIGHTS, OHIO 44118

DEFENDANTS, COMPLAINT WITH JURY DEMAND

PRELIMINARY STATEMENT

1. The plaintiff brings this action on his own behalf and on behalf of all African American
males who have suffered personal injury due to police officials acting with excessive
force and malicious purposes. The allegations made in this complaint are indicative of
the serious and prevalent problems with the CITY OF CLEVELAND HEIGHTS’ entire
system. The Plaintiff has suffered from an exacerbation to a prolonged serious medical
condition that the defendants were duly informed of. The acts/omissions of the
defendants as described herein this complaint were manifestly outside the scope of the
employee’s employment or official responsibilities. Plaintiff brings this civil rights and
state law action to secure fair compensation and to help end the violence perpetrated
by Cleveland Heights police officers against unarmed African American Males of the
community.
 JURISDICTION

2. Jurisdiction over claims brought under the Civil Rights Act of 1871 is conferred on this
court by 28 U.S.C. 51331, 1343 (3) (4)
3. This court has personal jurisdiction over the defendants and venue is proper in this
court under 28 U.S.C. 1391 because the events giving rise to Plaintiffs’ claims took place
within the court’s jurisdiction.

PARTIES

4. Plaintiff JOSHUA BRADLEY is a citizen of the UNITED STATES, who was injured while in
the city of Cleveland heights custody on 12/19/18.
5. Defendant CITY OF CLEVELAND HEIGHTS is a municipal corporation under OHIO
CONSTITUTION ART XVII and a “person” subject to suit within the meaning of 42 U.S.C.
1983. It is vested with the supervision of the CITY OF CLEVELAND HEIGHTS POLICE
DEPARTMENT.
6. Defendant OFFICER B.P.O. MICHAEL Laurello is a Cleveland Heights Police officer. At all
relevant times, he was in uniform, and acting under color of state law and in his capacity
as a Cleveland Heights Police Officer. He works in Cleveland Heights, Ohio and remains
an active member of the Cleveland Heights Police Department.
7. Defendant OFFICER LEWIS E. ALVIS is a Cleveland Heights Police officer. At all relevant
times, he was in uniform, and acting under color of state law and in his capacity as a
Cleveland Heights Police Officer. He works in Cleveland Heights, Ohio and remains an
active member of the Cleveland Heights Police Department

Venue
8. Venue is proper in this district based on 28 U.S.C 1391(b), as defendants are residents of
this district and the acts of occurrences giving rise to these claims occurred in this
district.

STATEMENT OF FACTS
9. The plaintiff and his passenger were driving on Lee road and turned on Monticello Road,
Cleveland Heights, Ohio, and proceeded to head northeast.
10. Defendants Cleveland heights police officer B.P.O. MICHAEL Laurello was driving on
Monticello Road, Cleveland Heights, Ohio, heading Northwest.
11. The plaintiff and Defendants Cleveland heights police officer B.P.O. MICHAEL Laurello
both locked eyes.
12. Defendants Cleveland heights police officer B.P.O. MICHAEL Laurello immediately
turned on his police siren and did a U-turn.
13. The plaintiff alleges that Defendant Cleveland heights police officer B.P.O. MICHAEL
Laurello turned on his police siren due to a bias against the plaintiff.
14. The plaintiff alleges that the Defendant Cleveland heights police officer B.P.O. MICHAEL
Laurello knew and/or knew of the plaintiff thru previous Cleveland Heights police
proceedings.
15. The plaintiff alleges that Defendant Cleveland heights police officer B.P.O. MICHAEL
Laurello turned on his police siren after personally identifying who the plaintiff was.
16. The plaintiff was pulled over by defendant Cleveland heights police officer B.P.O.
MICHAEL Laurello on 12/19/18 for allegedly not having a license plate light.
17. Defendants Officer B.P.O. MICHAEL Laurello & OFFICER LEWIS E. ALVIS, told plaintiff,
joshua bradley, he was being stopped for not having a license plate light, The plaintiff
was not the owner of the alleged car, and under all information and belief, the plaintiff
alleges that the license plate light was functioning properly on the night of the incident.
18. Defendants Officer B.P.O. MICHAEL Laurello & OFFICER LEWIS E. ALVIS never showed
the plaintiff, or the plaintiff’s passenger in the passenger seat (the owner of the vehicle)
the alleged non-functioning license plate light. (Witness #1)
19. Defendants Cleveland heights police officer B.P.O. MICHAEL Laurello, and defendant
OFFICER LEWIS E. ALVIS told the plaintiff he was being pulled over for not having a
license plate light.
20. The plaintiff was immediately remanded by defendant Cleveland heights police officer
B.P.O. MICHAEL Laurello, due to a warrant issued by the Solon Police department.
21. The plaintiff arrived at 26100 Chagrin Blvd Beachwood Ohio, 44122, and was willing and
compliant on being transferred to the neighboring city. (Solon, Ohio)
22. The plaintiff informed the defendant Cleveland heights police officer B.P.O. MICHAEL
Laurello and the solon police officers about the nerve damage to his thumbs and hands.
23. The plaintiff was compliant and posed no threat to the Cleveland heights officers and
the solon police officers.
24. At no point did plaintiff, joshua bradley, resist arrest.
25. While in the vicinity of the Solon Police OFFICER JOSEPH RANDAZZO, the plaintiff asked
the defendant Cleveland heights police officer B.P.O. MICHAEL Laurello and defendant
OFFICER LEWIS E. ALVIS to be gentle with the tightness of the handcuffs because of the
severe injuries to the nerves in his hands.
26. The plaintiff was transferred into Solon Police custody at or around 11:30pm in the
vicinity of 26100 Chagrin Blvd Beachwood Ohio, 44122.
27. Defendant Cleveland heights police officer B.P.O. MICHAEL Laurello officer and the
Solon police Officer both issued and allowed their handcuffs to be placed on the
plaintiff’s wrist and forearm, both pairs of handcuffs were left on the plaintiff’s wrist and
forearm at the same time for about one to two whole minutes.
28. The police officers laughed as the plaintiff screamed in pain and begged for both pairs of
handcuffs to be removed.
29. The plaintiff was put in a severe amount of pain due to the tightness of both the
handcuffs on his wrist and forearm.
30. The plaintiff micturated a little bit on himself, Due to the initial sharp pain of the second
pair of handcuffs.
31. The plaintiff screamed in distress and demanded to know, what was the cause of such
excessive force.
32. The police officers stated that putting two pairs of handcuffs on a transferring pre-trial
detainee is procedure.
33. The plaintiff asked Solon Police OFFICER JOSEPH RANDAZZO to be taken to the hospital.
34. Solon Police OFFICER JOSEPH RANDAZZO ignored the plaintiff’s pleas for medical
treatment as they drove to the Solon Detention Facility.
35. The Plaintiff arrived at the Solon Detention Facility in a severe amount of pain.
36. The Plaintiff demanded that the solon detention supervisor take pictures of the injuries
that he received.
37. The plaintiff requested to be taken to the emergency room because of the severe wrist,
forearm and nerve pain.
38. Solon Police OFFICER SGT. THOMAS LESNER ignored the plaintiff’s pleas for medical
treatment, and suggested he fill out a medical request form.
39. The Plaintiff requested a medical request form.
40. Solon DETENTION OFFICER MANDEEP SAINI stated that he would give the plaintiff a
medical request form once he was processed and safely in his cell.
41. The Plaintiff begged and pleaded DETENTION OFFICER MANDEEP SAINI for the medical
complaint form as he was escorted to his cell.
42. Solon DETENTION OFFICER MANDEEP SAINI raised his voice, issued threats and
demanded that the plaintiff get in the cell of the Solon Detention Facility.
43. The plaintiff Never received a medical complaint form from Solon DETENTION OFFICER
MANDEEP SAINI
44. The Plaintiff pushed emergency telecom button repeatedly, to reach Solon officer
STACEY SZCZUDLO.
45. The Plaintiff Demanded a medical complaint form from Solon officer STACEY SZCZUDLO
46. After Countless Requests, Solon Officer STACEY SZCZUDLO walked to the plaintiff’s cell
at or around 2am on 12/20/18 cell and Handed the plaintiff a medical complaint form
and a pen and stood in the door and told the plaintiff “hurry up and fill out the medical
complaint form because I don’t trust you with my pen!”.
47. The Plaintiff had a hard time Writing out the medical complaint form but, it said that he
was requesting immediate medical attention because his hand, wrist and forearm were
in a severe amount of pain.
48. The Plaintiff Requested to be taken to the Hospital the next morning, after he woke up.
49. The Solon DETENTION OFFICER MANDEEP SAINI ignored the plaintiff’s pleas for Medical
Treatment.
50. The Plaintiff requested for a grievance form to follow up on the medical complaint form.
51. The plaintiff filed a grievance form on 12/20/18 at the Solon Detention Facility.
52. The Plaintiff Demanded to be taken to the emergency room because he was in a severe
amount of pain.
53. The Solon Detention Officers ignored the plaintiff’s pleas for Medical Treatment.
54. The Plaintiff was released on a Personal Bond at 12:30pm on 12/20/18.
55. The plaintiff left the Solon Detention Facility in a Severe amount of pain.
56. The Plaintiff ran across the street to the St. Vincent charity hospital emergency room
where, he received the medical treatment he desperately needed.
 57. The Plaintiff was diagnosed with a severe aggravation to a preexisting injury. (The
injuries on the plaintiffs left and right hands were exacerbated due to the excessive
force by the Defendant OFFICER B.P.O. MICHAEL Laurello.
58. The plaintiff received the proper medical treatment after being released from the
custody of the Solon Detention Facility.
59. The Plaintiff was diagnosed with an Exacerbation to a previous injury on his left hand
and right hand after being released from Solon Detention Facility.
60. The plaintiff has been referred to see a neurologist, an Orthopedic surgeon, and a
doctor in internal medicine.
61. As a direct and proximate result of The Defendant Officer B.P.O. MICHAEL Laurello and
Defendant OFFICER LEWIS E. ALVIS’ intentional acts and/or malicious acts, the plaintiff
sustained severe mental and physical pain and suffering and injury in an amount to be
determined at trial.
62. The plaintiff is entitled to compensatory damages for the harms inflicted upon him, and
he is entitled to punitive damages for the unconscionable conduct he was forced to
endure at the hands of Defendants Officer B.P.O. MICHAEL Laurello and Defendant
OFFICER LEWIS E. ALVIS.
63. As a direct and proximate result of The Defendants Officer B.P.O. MICHAEL Laurello and
Defendant OFFICER LEWIS E. ALVIS’ intentional and/or malicious acts, the plaintiff
sustained severe mental and physical pain and suffering and injury in an amount to be
determined at trial.

CLAIM 1
Fourth Amendment Violation Under 42 U.S.C. 1983 against Defendant Officer B.P.O. MICHAEL
Laurello IN HIS OFFICIAL AND PERSONAL CAPACITY FOR EXCESSIVE FORCE TO an INJURED PRE-
TRIAL DETAINEE, ON BEHALF OF THE PLAINTIFF

64. Plaintiff incorporates all previous allegations by reference

65. Defendants have, under color of law, deprived the Plaintiff, joshua Bradley of rights,
privileges, and immunities secured to him by the Fourth and Fourteenth amendments
to the united states constitution including the right to be free from unreasonable
searches and seizures without probable cause, the right to be free of and from the use
of excessive force, and the right to adequate medical care while in custody.
66. Defendant Officer B.P.O. MICHAEL Laurello failed to follow procedure regarding the
transporting of a pretrial detainee. The plaintiff was forced to endure excessive force,
due to Defendant Officer B.P.O. MICHAEL Laurello’s malicious acts upon a pretrial
detainee.
67. Defendant Officer B.P.O. MICHAEL Laurello’s actions led to physical and emotional
damage to the plaintiff.
68. As a direct and proximate result of Defendant Officer B.P.O. MICHAEL Laurello ‘s
unlawful conduct, The Plaintiff suffered and will continue to suffer economic and non-
economic damages for which the defendant is liable, including, but not limited to
mental, emotional, and physical pain suffering.
69. The plaintiff is entitled to punitive damages based on the defendant’s egregious
conduct.
70. In addition to the Plaintiffs compensatory and punitive damages, defendants are also
liable for attorneys’ fees and costs, witness fees, expert fees, and any additional legal or
equitable relief that this court deems appropriate.

CLAIM 2
42 U.S.C 1983 CLAIM- MALICIOUS PROSECUTION AGAINST DEFENDANTS Officer B.P.O.
MICHAEL Laurello & OFFICER LEWIS E. ALVIS

71. All Paragraphs contained in this complaint are incorporated as if fully rewritten
herein.
72. Defendant Cleveland heights police officer B.P.O. MICHAEL Laurello and defendant
OFFICER LEWIS E. ALVIS’s actions, as alleged in the proceeding paragraphs, were
performed under color of law and deprived plaintiff of federally protected rights, in
violation of Title 42 U.S.C 1983
73. Defendant Cleveland heights police officer B.P.O. MICHAEL Laurello and defendant
OFFICER LEWIS E. ALVIS accused plaintiff, joshua bradley, of criminal activity knowing
those accusations to be without genuine probable cause.
74. Defendant Cleveland heights police officer B.P.O. MICHAEL Laurello and defendant
OFFICER LEWIS E. ALVIS instigated, influenced, or participated in the decision to
prosecute plaintiff knowing there was no probable cause for criminal prosecution.
75. Defendant Cleveland heights police officer B.P.O. MICHAEL Laurello and defendant
OFFICER LEWIS E. ALVIS also engaged in conduct, including but not limited to making
statements to supervisors, prosecutors, which continued the judicial proceedings
against the plaintiff without probable cause.
76. Defendant Cleveland heights police officer B.P.O. MICHAEL Laurello and defendant
OFFICER LEWIS E. ALVIS deliberately engaged in arbitrary and conscience-shocking
conduct that contravened fundamental canons of decency and fairness and violated
plaintiff’s substantive due process rights and in violation of the due process clause, and
the fourteenth and fourth amendments to the united states constitution.
77. As a direct and proximate cause of defendant Cleveland heights police officer B.P.O.
MICHAEL Laurello and defendant OFFICER LEWIS E. ALVIS misconduct, Plaintiff suffered
and continues to suffer injury and damages as set forth in the complaint.
 CLAIM 3
OHIO LAW- MALICIOUS PROSECUTION AGAINST DEFENDANTS Officer B.P.O. MICHAEL Laurello
& OFFICER LEWIS E. ALVIS

78. All Paragraphs contained in this complaint are incorporated as if fully rewritten
herein.
79. In the manner described more fully above Defendant Cleveland heights police officer
B.P.O. MICHAEL Laurello and defendant OFFICER LEWIS E. ALVIS, acting maliciously,
instituted, participated in, and/or continued the prosecution of plaintiff without
probable cause.
80. As a consequence of the criminal prosecution, plaintiff was unlawfully detained and
subject to excessive force and deprived of liberty.
81. Defendant Cleveland heights police officer B.P.O. MICHAEL Laurello and defendant
OFFICER LEWIS E. ALVIS committed these actions intentionally, maliciously, culpably,
and/or in a willful, wanton, or reckless manner, and in reckless disregard to plaintiff’s
rights.
82. Defendant Cleveland heights police officer B.P.O. MICHAEL Laurello and defendant
OFFICER LEWIS E. ALVIS acted and were under color of law and within the scope of their
employment when they took these actions

CLAIM 4
42 U.S.C 1983 CLAIM- MONELL CLAIM AGAINST DEFENDANT CITY OF CLEVELAND HEIGHTS

83. All paragraphs contained in this complaint are incorporated as if fully rewritten
herein.
84. Defendant Cleveland heights police officer B.P.O. MICHAEL Laurello and defendant
OFFICER LEWIS E. ALVIS’, as alleged above, were taken pursuant to one or more
interrelated de facto policies (even if not official written edicts), practices and/or
customs of civil rights violations and unconstitutional practices of the city of Cleveland
heights and its police department.
85. The city of Cleveland heights, at all times relevant herein, approved, authorized, and
acquiesced in the unlawful and unconstitutional conduct of its respective employees
and/or agents and consequently is directly liable for the acts of those agents, pursuant
to 42 U.S.C. 1983.
86. Though the facts and circumstances surrounding plaintiff’s arrest clearly demonstrate
that the Defendant Cleveland heights police officer B.P.O. MICHAEL Laurello and
defendant OFFICER LEWIS E. ALVIS’ actions were unreasonable and unlawful upon
information and belief, the city of Cleveland heights has failed to effectively investigate
or impose and discipline on Defendant Cleveland heights police officer B.P.O. MICHAEL
Laurello and defendant OFFICER LEWIS E. ALVIS’ for their illegal behavior.
87. At all times material to this complaint, the defendant city of Cleveland heights and its
police department had interrelated de facto policies, practices, and customs which
included, inter alia:
 a. The failure to properly hire, train, supervise, discipline, transfer, monitor,
counsel and/or otherwise control city of Cleveland heights police officers who
engaged in unjustified use of excessive force and unreasonable fore, unlawful
searches and seizures and malicious prosecution;
b. The police code of silence;
c. The encouragement of excessive and unreasonable force, and unlawful
searches and seizures, and malicious prosecution;
d. The failure to properly investigate use of excessive and unreasonable force,
unlawful searches and seizures, and malicious prosecution against civilians,
particularly African Americans, by the city of Cleveland heights police officers;
and
e. The failure to properly discipline, supervise, monitor, counsel, and otherwise
control city of Cleveland heights police officers who engage in unjustified use
of excessive and unreasonable force, unlawful searches and seizures, or
malicious prosecution.
88. These customs/practices/patterns are the moving force behind the conduct of
Defendant Cleveland heights police officer B.P.O. MICHAEL Laurello and defendant
OFFICER LEWIS E. ALVIS in searching, seizing, unlawfully detaining, prosecuting and
physically injuring the plaintiff, Joshua Bradley.
89. The policy, practice and custom of police code of silence results in police officers
refusing to report instances of police misconduct of which they are aware, including
unlawful searches, seizures, detainments, assaults and batteries, and prosecution,
despite their obligation to do so, and also includes police officers either remaining
silent or giving false and misleading information during official investigations in order
to protect themselves or fellow officers from internal discipline, civil liability, or
criminal charges in cases where they or their fellow officers have engaged in
misconduct.
90. The de facto policies, practices and customs of failing to hire, train, supervise,
monitor, discipline, transfer, counsel and/or control police misconduct and the code of
silence are interrelated and exacerbate the effects of each other, institutionalize
police lying, and immunize police officers from discipline.
91. That the unconstitutional actions of Defendant Cleveland heights police officer B.P.O.
MICHAEL Laurello and defendant OFFICER LEWIS E. ALVIS were part and parcel of a
widespread municipal policy, practice, and/or custom is further established by the
involvement in, and ratification of, these acts by municipal supervisors and policy
makers, as well as by a wide range of other police officials, officers and divisions of the
department.
92. The policies, practices, and/or customs alleged in this complaint, separately and
together, are the proximate cause of the injury to plaintiff as defendants had good
reason to believe that their misconduct would not be revealed or reported by fellow
officers or supervisors, and that they were immune from disciplinary action, thereby
protecting them from consequences of their unconstitutional conduct.
93. But for the belief that they would be protected both by fellow officers and the city of
Cleveland heights from serious consequences, Defendant Cleveland heights police
 officer B.P.O. MICHAEL Laurello and defendant OFFICER LEWIS E. ALVIS would not have
engaged in the conduct that resulted in the injuries to the plaintiff, joshua bradley.
94. The interrelated policies, practices, and customs, individually and together, were
maintained and implemented with deliberate indifference and encouraged both
Defendant Cleveland heights police officer B.P.O. MICHAEL Laurello and defendant
OFFICER LEWIS E. ALVIS to violate plaintiff’s constitutional rights, and therefore were
the moving force behind and to the violations of the plaintiff’s rights.

CLAIM 5
OHIO LAW- NEGLIGENCE- WILLINGFUL, AND/OR RECKLESS CONDUCT AGAINST Defendant
Officer B.P.O. MICHAEL Laurello and Defendant OFFICER LEWIS E. ALVIS

95. All Paragraphs contained in this complaint are incorporated as if fully rewritten
herein.
96. DEFENDANTS Officer B.P.O. MICHAEL Laurello & OFFICER LEWIS E. ALVIS failed to
exercise due care, and acted in a willful, and wanton, and/or reckless manner while
engaged in police functions and activities, including but not limited to unreasonable
search and seizure and Malicious prosecution against the plaintiff, joshua Bradley.
97. DEFENDANTS Officer B.P.O. MICHAEL Laurello & OFFICER LEWIS E. ALVIS are not
entitled to the immunities set forth in O.R.C 2744.01 et seq.
98. As a direct and proximate cause of DEFENDANTS Officer B.P.O. MICHAEL Laurello &
OFFICER LEWIS E. ALVIS misconduct, plaintiff suffered and continues to suffer injury and
damages as set forth in this complaint.

CLAIM 6
OHIO LAW- ABUSE OF PROCESS AGAINST Defendants Officer B.P.O. MICHAEL Laurello
& OFFICER LEWIS E. ALVIS

99. All paragraphs contained in this complaint are incorporated as if fully rewritten
herein.
100. Defendants Officer B.P.O. MICHAEL Laurello & OFFICER LEWIS E. ALVIS, while
acting under the color of law, by instituting a legal proceeding, did so in attempt to
accomplish an ulterior purpose for which it was not designed and that proceeding has
been perverted to attempt to accomplish an ulterior purpose for which it was not
designed, and direct damage has resulted from the wrongful use of process.
101. Defendants Officer B.P.O. MICHAEL Laurello & OFFICER LEWIS E. ALVIS, abuse
of process constitutes a deprivation of the plaintiff’s right to process.
102. Defendants Officer B.P.O. MICHAEL Laurello & OFFICER LEWIS E. ALVIS, told
plaintiff, joshua bradley, he was being stopped for not having a license plate light, The
plaintiff was not the owner of the alleged car, and under all information and belief, the
plaintiff alleges that the license plate light was functioning properly on the night of the
incident.
103. As a direct, proximate and foreseeable result of defendants Officer B.P.O.
MICHAEL Laurello & OFFICER LEWIS E. ALVIS’ actions, the plaintiff, Joshua Bradley,
suffered and continues to suffer injuries and damages as set forth in this complaint.

CLAIM 7
INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS AGAINST DEFENDANTS Officer
B.P.O. MICHAEL Laurello & OFFICER LEWIS E. ALVIS, ON BEHALF OF THE PLAINTIFF

104. Plaintiff incorporates all previous allegations by reference.

105. In conducting themselves as they did, The DEFENDANTS Officer B.P.O.
MICHAEL Laurello & OFFICER LEWIS E. ALVIS either intended to cause emotional
distress or knew or should have known that the actions taken would result in serious
emotional distress and cruel and unusual punishment to the plaintiff.
106. The DEFENDANTS Officer B.P.O. MICHAEL Laurello & OFFICER LEWIS E. ALVIS ‘s
conduct in forcing the plaintiff to endure cruel and unusual punishment. The
DEFENDANTS Officer B.P.O. MICHAEL Laurello & OFFICER LEWIS E. ALVIS’S conduct was
extreme and outrageous. It went beyond all possible bounds of human decency and
such that it could be considered intolerable in civilized society.
107. As a direct and proximate result of The DEFENDANTS Officer B.P.O. MICHAEL
Laurello & OFFICER LEWIS E. ALVIS’s unlawful conduct, the plaintiff, has suffered and
will continue to suffer mental anguish so serious and of such a nature that no
reasonable person could be expected to endure it and for The DEFENDANTS Officer
B.P.O. MICHAEL Laurello & OFFICER LEWIS E. ALVIS are liable.
108. The plaintiff is entitled to punitive damages based on The DEFENDANTS Officer
B.P.O. MICHAEL Laurello & OFFICER LEWIS E. ALVIS’s egregious conduct.

CLAIM 8
NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS against DEFENDANTS Officer B.P.O.
MICHAEL Laurello & OFFICER LEWIS E. ALVIS, ON BEHALF OF THE PLAINTIFF

109. Plaintiff incorporates all previous allegations by reference.

110. Plaintiff was subjected to cruel and unusual punishment and prolonged physical
pain and suffering at the hands of The DEFENDANTS Officer B.P.O. MICHAEL Laurello &
OFFICER LEWIS E. ALVIS. As a direct and proximate result, The DEFENDANTS Officer
B.P.O. MICHAEL Laurello & OFFICER LEWIS E. ALVIS’s unlawful conduct, The Plaintiff has
suffered and will continue to suffer serious mental anguish for which The DEFENDANTS
Officer B.P.O. MICHAEL Laurello & OFFICER LEWIS E. ALVIS are liable.
 CLAIM 9
Eighth Amendment Violation Under 42 U.S.C. 1983 against DEFENDANTS Officer B.P.O.
MICHAEL Laurello & OFFICER LEWIS E. ALVIS IN their OFFICIAL AND PERSONAL CAPACITY
FOR CRUEL AND UNUSUAL PUNISHMENT, ON BEHALF OF THE PLAINTIFF

111.Plaintiff incorporates all previous allegations by reference.

112.Plaintiff was subjected to cruel and unusual punishment and prolonged physical pain and
suffering at the hands of The DEFENDANTS Officer B.P.O. MICHAEL Laurello & OFFICER
LEWIS E. ALVIS. As a direct and proximate result, The DEFENDANTS Officer B.P.O. MICHAEL
Laurello & OFFICER LEWIS E. ALVIS’s unlawful conduct, The Plaintiff has suffered and will
continue to suffer serious mental anguish for which The DEFENDANTS Officer B.P.O.
MICHAEL Laurello & OFFICER LEWIS E. ALVIS are liable.
113.The DEFENDANTS Officer B.P.O. MICHAEL Laurello & OFFICER LEWIS E. ALVIS ‘s conduct in
forcing the plaintiff to endure cruel and unusual punishment. The DEFENDANTS Officer
B.P.O. MICHAEL Laurello & OFFICER LEWIS E. ALVIS’s conduct was extreme and outrageous.
It went beyond all possible bounds of human decency and such that it could be considered
intolerable in civilized society.
114.In conducting themselves as they did, The DEFENDANTS Officer B.P.O. MICHAEL Laurello &
OFFICER LEWIS E. ALVIS intended to cause emotional distress and/or knew or should have
known that the actions taken would result in serious emotional distress and cruel and
unusual punishment to the plaintiff.
 PRAYER FOR RELIEF
For the reasons stated above, the plaintiff, Joshua Bradley, respectfully requests the
following relief from the court:
1. Declare that The Defendants’ acts and conduct constitute violations of the
fourth amendment of the United States Constitution, as well as of 42 U.S.C.
1983;
2. Enter a declaratory judgment on behalf of the Plaintiff that the defendant’s
policies, pattern of practices, customs, lack of supervision, failure to train, acts,
and omissions, described herein, constituted a violation of the OHIO STATE LAW
3. Enter judgement in the plaintiff’s favor on all claims for relief;
4. Award full compensatory damages including, but not limited to, damages for
pain and suffering, mental anguish, emotional distress, cruel and unusual
punishment, and inconvenience that the plaintiff, Joshua Bradley, has suffered
and is reasonably certain to suffer in the future;
5. Award punitive and exemplary damages for the individual defendant’s
egregious, willingful, and malicious conduct;
6. Permanently enjoin and prohibit Defendants from interfering with Plaintiff’s
constitutional rights. Specifically, to enjoin defendants from:
a. Retaliating against Plaintiff or his family for bringing this lawsuit; and
b. Subjecting Plaintiff to excessive force in the future.
7. Order Defendants to pay punitive damages and other exemplary damages
based on 42 U.S.C 1983 claims;
8. Order Defendants to pay Plaintiff’s attorneys’ fees and costs as authorized by
42 U.S.C 1988; pre-judgement interest and any other relief deemed necessary
and proper;
9. For leave to amend Complaint to include a claim for punitive damages under
state law; and
10. Grant all other additional relief to which Plaintiff may be entitled.

JOSHUA BRADLEY September 8th, 2019