Romulus Police Chief Dickerson lawsuit.pdf - MLive.com

2:13-cv-10771-JAC-MKM Doc # 1 Filed 02/25/13 Pg 1 of 18 Pg ID 1KEVIN PAUL LADACH,Vs.Plaintiff,UNITED STATES DISTRICT COURTFOR THE EASTERN DISTRICT OF MICHIGANSOUTHERN DIVISIONCITY OF ROMULUS, a Municipal Corporation,d/b/a City of Romulus Police Department, andCHIEF ROBERT DICKERSON, in his official and individualcapacity, and CAPTAIN DERRAN SHELBY, in his official andindividual capacity,_________________________________________/JOEL B. SKLAR P38338Attorney for Plaintiff615 Griswold, Suite 1116Detroit, MI 48226313-963-4529Joelb79@hotmail.com_________________________________________/COMPLAINT AND JURY DEMANDPlaintiff Kevin Paul Ladach files this Complaint and Jury Demand against DefendantsCity of Romulus d/b/a City of Romulus Police Department, Defendant City of Romulus PoliceDepartment Chief Robert Dickerson and City of Romulus Police Chief Captain Derran Shelbyand says:1. This lawsuit arises out of Defendants’ retaliation against Plaintiff in violation ofPlaintiff’s First Amendment free speech rights, his reports of suspected unlawfulactivity to law enforcement and the Michigan Attorney General’s Office and hisrefusal to commit a crime and destroy evidence of criminal conduct by a fellowpolice officer or engage in a cover-up of criminal conduct by a fellow officerwhich violated a citizen’s Fourth Amendment rights.

2:13-cv-10771-JAC-MKM Doc # 1 Filed 02/25/13 Pg 2 of 18 Pg ID 22. Plaintiff Kevin Ladach is a member of the City of Romulus Police Departmentand transacts business in Wayne County, Michigan which is located in thisDistrict.3. Defendant City of Romulus is a Michigan municipal corporation which operatesthe City of Romulus Police Department which transacts business in WayneCounty, Michigan and is located in this District.4. Defendant Robert Dickerson is an employee of the City of Romulus d/b/a City ofRomulus Police Department and the Chief of Police for the City of RomulusPolice Department which transacts business in Wayne County, Michigan and islocated in this District. Defendant Dickerson is being sued in his official andindividual capacity.5. Defendant Derran Shelby is an employee of the City of Romulus d/b/a City ofRomulus Police Department and a Captain of the City of Romulus PoliceDepartment which transacts business in Wayne County, Michigan and is locatedin this District. Defendant Shelby is being sued in his official and individualcapacity.6. When the events alleged in this Complaint occurred, the individual Defendantswere violating Plaintiff’s clearly established constitutional rights and their actionswere clearly unreasonable. As such, the individual Defendants are not entitled tothe defense of qualified immunity.7. Defendant City of Romulus d/b/a City of Romulus Police Department cannotavail itself of governmental immunity pursuant to its intentional actions takenagainst Plaintiff as such are intentional torts and immunity against said

2:13-cv-10771-JAC-MKM Doc # 1 Filed 02/25/13 Pg 3 of 18 Pg ID 3governmental agency have been waived pursuant to the Whistleblower ProtectionAct, being MCL 15.361. In addition, sovereign immunity does not apply tomunicipalities such as the City of Romulus d/b/a City of Romulus PoliceDepartment.8. The individually named Defendants are each being sued in their individualcapacity as well as in their official capacities.9. The acts, transactions and events which give rise to this action all occurred in theCity of Romulus, Wayne County, Michigan which is located in this District.10. This Court has jurisdiction over Plaintiff’s federal and state claims pursuant to 42USC § 1983, 28 USC § 1331, 28 USC § 1367 and the amount in controversyexceeds the jurisdictional limits of this court, exclusive of costs, fees and interest.COMMON FACTUAL ALLEGATIONS11. In September of 1999, Plaintiff was hired by Defendant City of Romulus d/b/aCity of Romulus Police Department as a civilian dispatcher.12. Sometime in 2003, Defendant City of Romulus d/b/a City of Romulus PoliceDepartment sponsored Plaintiff’s entry into the Police Academy.13. From 2003 through February 2009, Plaintiff worked as a patrolman on road patrolfor Defendant City of Romulus d/b/a City of Romulus Police Department.14. Sometime in 2009, due to Plaintiff’s exemplary performance and qualifications,he was assigned to the Detective Bureau of Defendant City of Romulus d/b/a Cityof Romulus Police Department.15. Sometime in July of 2011, due to Plaintiff’s exemplary performance andqualifications, he was promoted to the position of Sergeant.

2:13-cv-10771-JAC-MKM Doc # 1 Filed 02/25/13 Pg 4 of 18 Pg ID 416. From July of 2011 to December of 2011, Plaintiff worked as a Sergeant inuniform on road patrol.17. In December of 2011, a new position was created by Defendant City of Romulusd/b/a the City of Romulus Police Department, which combined the duties of therecord bureau sergeant and the detective sergeant, who would work under theauthority of Defendant Captain Shelby.18. Based on his qualifications and exemplary performance, Plaintiff was selected forthis position which also included operation of the property/evidence room.19. In July of 2012, Plaintiff wrote a memo to the Defendants Shelby and Dickersoninforming them that he could not perform all of the duties assigned at a standardacceptable to Plaintiff. Plaintiff, therefore, asked that the position be reposted forother interested sergeants and, if no other sergeants applied or were interested inthe position, that Defendants Captain Shelby and Chief Dickerson considerreorganization by assigning some of Plaintiff’s duties to others.20. Defendant Dickerson informed Plaintiff that he thought Captain Shelby was goingto assist Plaintiff in the performance of his duties, which Shelby did not, and thatthe Chief never expected all of the responsibilities of the Records Bureau to behandled by Plaintiff alone.21. Defendant Dickerson asked Plaintiff to rescind the letter suggestingreorganization, which Plaintiff did, in exchange for Defendant Dickerson’spromise to assist Plaintiff with his duties.22. At this meeting, Defendant Dickerson told Plaintiff that he could return to roadpatrol if he wanted but that Dickerson preferred that Plaintiff stay in the Detective

2:13-cv-10771-JAC-MKM Doc # 1 Filed 02/25/13 Pg 5 of 18 Pg ID 5Bureau. Plaintiff informed Chief Dickerson that he did not want to return to roadpatrol.23. Plaintiff’s duties in the record bureau included the processing of requests madepursuant to the Freedom of Information Act (FOIA) being MCL 15.231 et seq.24. Since December of 2011 when Plaintiff assumed the supervision of the recordsbureau, all FOIA requests came directly to Plaintiff for his review and response.25. These duties included the downloading, and preservation of, patrol car video andpolice station video.26. On August 1, 2012, Plaintiff learned that an incident had occurred on themidnight shift in which a City of Romulus police officer allegedly struck ahandcuffed prisoner.27. Plaintiff heard Defendant Chief Dickerson in the open hallway talking to anunidentified person in which Defendant Dickerson admitted that he had spoken tothe victim, that the victim had requested a copy of the surveillance video tape andthat Defendant Chief denied the victim’s request.28. The general practice of the Romulus Police Department is to safeguard andmaintain a copy of all patrol car and surveillance videos for a period of 30 daysfrom the date of their making after which date the surveillance video isautomatically deleted from the Department’s computers and irretrievably lost.29. After hearing of the alleged criminal assault of a handcuffed prisoner by a City ofRomulus police officer, that the victim had requested a copy of the video and thatChief Dickerson informed the victim that he would not be given the video,

2:13-cv-10771-JAC-MKM Doc # 1 Filed 02/25/13 Pg 6 of 18 Pg ID 6Plaintiff downloaded and saved the video of the incident on the Romulus PoliceDepartment computer.30. Defendant Captain Shelby knew that the video existed because he had personallyviewed the video when it was played in Plaintiff’s office.31. On September 21, 2012, a FOIA request was faxed to the Romulus PoliceDepartment by attorney Michael Rataj which concerned the assault of thehandcuffed prisoner, including, among other things, a request for any and allcopies of the video. (Rataj correspondence, Ex. A.)32. On September 24, 2012, Plaintiff received the FOIA request.33. Pursuant to his job duties, Plaintiff prepared a FOIA response letter and requestedall documents/videos, making all of the appropriate exemptions and redactions asprovided in the statute.34. Plaintiff then presented the FOIA packet for Defendant Dickerson’s review.35. When Defendant Dickerson asked what the packet involved, Plaintiff respondedthat the materials involved “the punch” described above.36. Shortly after Plaintiff had spoken with Defendant Dickerson, Defendant CaptainShelby came to Plaintiff’s office and summoned him to meet in DefendantDickerson’s office.37. Once in Defendant Chief Dickerson’s office, Defendant Dickerson asked Plaintiff“Why do we have this?” referring to the video tape which captured the assault ofthe handcuffed prisoner.38. Plaintiff responded that he “had saved it” referring to the video which had beendigitally downloaded on Plaintiff’s department issued computer.

2:13-cv-10771-JAC-MKM Doc # 1 Filed 02/25/13 Pg 7 of 18 Pg ID 739. Defendant Chief Dickerson responded that he thought the video was only savedfor 30 days and asked Plaintiff why he had saved this particular video.40. Plaintiff explained to Defendant Chief Dickerson that plaintiff had saved thevideo because (1) he had a duty as a FOIA coordinator to preserve any requesteddocuments [here the victim had orally requested the video from DefendantDickerson well within the 30 days of the incident] and not allow their destructionto avoid their release and (2) he expected an investigation of the incident to becompleted and (3) the existence of the video would be of obvious importance tosuch investigation as it constituted actual video evidence of the incident.41. Defendant Dickerson stated that “I didn’t know that this [the video] was inexistence, I guess I’ll have to start an investigation now. Well actually I do havean investigation. I gave him [the victim] a complaint packet. I’m waiting for himto return it to complete the investigation.” This struck Plaintiff as odd since anyinvestigation should have commenced immediately after Defendant Dickersonlearned that a citizen had accused a City of Romulus Police Officer of assaultinghim while he was handcuffed and in the custody and control of the City ofRomulus Police Department.42. Plaintiff told Defendant Dickerson that if there was an open investigation, whichwas news to Plaintiff, that would qualify as an exemption under FOIA, but sincethe video was in existence, the City of Romulus Police Department was, inPlaintiff’s opinion as the FOIA Coordinator, delaying the inevitable and that thevideo would have to be released at some point.

2:13-cv-10771-JAC-MKM Doc # 1 Filed 02/25/13 Pg 8 of 18 Pg ID 843. Defendant Chief Dickerson then said “I’m not giving this video out so someattorney can help this guy fill out his complaint packet.” Plaintiff knew that thereason stated by Defendant Chief Dickerson was not a qualifying exemptionunder FOIA.44. Defendant Chief Dickerson then asked Defendant Captain Shelby if he had seenthe video to which Defendant Shelby replied “It ain’t pretty.”45. Defendant Dickerson instructed Plaintiff to complete a time extension request forthe FOIA response so that he could have City of Romulus attorney, BarrySeifman, review the FOIA. Plaintiff left the packet with Defendant ChiefDickerson.46. On Tuesday, October 2, 2012, there was a rumor that the officer who punched thehandcuffed prisoner had been disciplined on October 1, 2012, some two monthsafter the alleged assault.47. On Wednesday, October 3, 2012, Plaintiff learned from another officer of a memofrom Defendant Dickerson’s secretary which stated that Lt. Josh Monte was beingpromoted to Captain and that his duties included performing work at the recordsbureau.48. On October 4, 2012, Defendant Chief Dickerson came to Plaintiff’s office, askedPlaintiff’s office mate, Detective Tommy Westhoff, to leave the office so he couldspeak with Plaintiff privately. This had never happened before.49. Defendant Chief Dickerson then proceeded to discuss the above referenced FOIArequest with Plaintiff and instructed Plaintiff to make specified changes in the

2:13-cv-10771-JAC-MKM Doc # 1 Filed 02/25/13 Pg 9 of 18 Pg ID 9FOIA response and asked the whereabouts of any discs that contained the videoor depiction of “the punch.”50. Plaintiff told Defendant Chief Dickerson that two discs existed; one disc that wascontained in the FOIA packet previously provided the Chief and the second wasin the FOIA file cabinet in the records bureau.51. Plaintiff also informed Defendant Chief Dickerson that the video (in digitalformat) was also downloaded on Plaintiff’s City of Romulus computer and a USBdrive.52. Defendant Chief Dickerson then instructed Plaintiff to delete the (digital) videocopy from his computer and USB drive and to turn over any discs of the incidentto Defendant Chief Dickerson and that they would be turned over to City ofRomulus attorney Seifman.53. Plaintiff replied that he understood the Chief’s order.54. Later on October 4, 2012, Defendant Captain Shelby came to Plaintiff’s officeand said “What’s wrong Sergeant. I know you’re unhappy.”55. Plaintiff replied that he was not happy being part of any kind of cover up.56. Defendant Shelby stated “I don’t think there is any kind of cover up” in spite ofthe fact that Defendant Dickerson had not commenced a timely investigation ofthe alleged assault, had denied the victim citizen’s verbal request for the video ofthe alleged assault, had informed Plaintiff that Defendant Dickerson did not wantto give the video to the citizen victim so that he could utilize the services of anattorney to complete the complaint packet and had ordered Plaintiff to destroyevidence of the alleged assault.

2:13-cv-10771-JAC-MKM Doc # 1 Filed 02/25/13 Pg 10 of 18 Pg ID 1057. Plaintiff replied that “The whole thing stinks. The only reason anything was donehere is just because of a FOIA request. I don’t want [the officer] to be in anytrouble, but this thing happened two months ago. Something should have beendone a long time ago.”58. Defendant Shelby replied that the officer involved in the incident wanted theentire incident to go away too and further advised Plaintiff that there was apossibility of a criminal investigation concerning the assault of the handcuffedprisoner.59. In addition, as the FOIA coordinator, Plaintiff had never before been asked orinstructed to turn video evidence over to the City of Romulus attorney and alsobelieved that turning over such evidence would break the chain of custody.60. Plaintiff was troubled by Defendant Dickerson’s order to destroy materialevidence of a possible criminal conduct and decided to report his suspicions of acover-up of possible criminal conduct to the Michigan Attorney General’s Office.61. On October 5, 2012, Plaintiff contacted the Michigan Attorney General’s Officeto report his suspicions of illegal activity (i.e., the assault of the handcuffedprisoner) and a possible cover up of a crime committed by an officer of the Cityof Romulus Police Department.62. On October 8, 2012, Plaintiff informed Defendants Dickerson and Shelby that hehad contacted the Michigan Attorney General’s Office to report his suspicions ofillegal activity and that he had made a copy of the surveillance video of theassault of the handcuffed officer which was also provided to the AttorneyGeneral’s Office.

2:13-cv-10771-JAC-MKM Doc # 1 Filed 02/25/13 Pg 11 of 18 Pg ID 1163. On October 8, 2012, Defendant Chief Dickerson told Plaintiff that he wished hehad kept the issue in-house rather than going to the Attorney General’s Office.64. Defendant Captain Shelby informed Plaintiff that since Captain Monte had takenover the record bureau duties that Plaintiff would be expected to handle moreduties in the Detective Bureau, including case assignments, payroll andsupervisory duties.65. On October 9, 2012, Captain Shelby provided Plaintiff with a copy of the revisedFOIA response letter and asked Plaintiff if he wanted his name included as thesignatory of the letter to which Plaintiff responded that he did not.66. On December 5, 2012, Plaintiff spoke with Carol Mayerich of the City ofRomulus Human Resources Department and told her that Defendants ChiefDickerson and Captain Shelby had created a hostile work environment for him.67. On December 7, 2012, Ms. Mayerich met with Plaintiff and Defendant ChiefDickerson. Defendant Chief Dickerson told Ms. Mayerich that he was “leery” ofPlaintiff remaining in the Detective Bureau and the property room because of“trust issues”, presumably referring to Plaintiff’s refusal to destroy evidence asordered by Defendant Chief Dickerson.68. At this meeting, Defendant Chief Dickerson also lauded Plaintiff’s work in theDetective Bureau, how Plaintiff had been a “great employee”, that he could counton Plaintiff always getting the job done but that that had changed since the timeperiod when the City of Romulus Police Department had received the FOIArequest concerning the video tape of the assault by a police officer on a

2:13-cv-10771-JAC-MKM Doc # 1 Filed 02/25/13 Pg 12 of 18 Pg ID 12handcuffed prisoner and when Defendants learned of Plaintiff’s complaints to theAttorney General’s Office.69. At the conclusion of the meeting, Ms. Mayerich asked Plaintiff if he wanted to betransferred to road patrol.70. In response, Plaintiff stated that he did not want to be transferred to road patroland that he only wanted to be able to do his job without being picked on or lied to.71. On January 9, 2013, Plaintiff discovered that Defendant Shelby had been paid fordays which Plaintiff suspected that Defendant Captain Shelby had not worked.72. Specifically, Plaintiff noted that the payroll records indicated that DefendantShelby was paid “D-8” for December 27, 2012 and December 28, 2012.73. Plaintiff had worked those exact shifts and had not seen Defendant Shelby atwork.74. On January 9, 2013, Plaintiff reported his suspicions that Defendant CaptainShelby was being paid for work not performed directly to Defendant ChiefDickerson.75. On January 9, 2013, Lt. Czernik came to Plaintiff at approximately 4:00 pm andtold him that he was to meet with Defendant Chief Dickerson at 4:30 pm. Plaintiffexpected the meeting to be about the payroll discrepancy concerning DefendantCaptain Shelby.76. Defendant Chief Dickerson, Captain John Leacher and Lt. Czernik (Plaintiff’sUnion representative) attended a meeting in Captain Leacher’s office.77. At the time, Defendant Dickerson passed out a memo and stated “This is notdiscipline.”

2:13-cv-10771-JAC-MKM Doc # 1 Filed 02/25/13 Pg 13 of 18 Pg ID 1378. At the meeting, Plaintiff was presented with a memo directed to HumanResources Director Carol Mayerich concerning Plaintiff’s report of payrolldiscrepancies related to Defendant Captain Shelby.79. The memo further stated:Also, as discussed with you and my Executive Command Staff over thepast few weeks of my intention of eliminating the Detective Sergeantsposition from the Investigative Services Bureau and transferring theposition back to the Afternoon Shift-Uniformed Patrol OperationsDivision effective February 1, 2013, is going to be effective immediately.By delaying the transfer any further, will only worsen the already poorcommunication and working relationship of the Captain and the Sergeant.80. Consequently, Plaintiff was relieved of his duties in the Detective Bureau and wastransferred to being a road patrol supervisor, a position far different from that ofthe Detective Bureau.81. Removal from the Detective Sergeant position to Sergeant for road patrol meantthat Plaintiff would lose his 5% pay raise over patrol Sergeants, lose the title“Detective” and the benefits and privileges commensurate therewith, no longerhave an assigned city vehicle which he could take home, would no longer haveuse of the city issued cell phone, would no longer be able to work the day shift,would no longer have weekends and holidays off with pay and lost the privilegeof scheduling his own overtime to keep up with his assigned duties and lost accessto many parts of the building in which Plaintiff worked.82. The past practice of the City of Romulus Police Department is to provideemployees two week notice of any schedule change and to also allow officers tokeep their department issued cell phones for a period of time. Plaintiff did notreceive this notice.

2:13-cv-10771-JAC-MKM Doc # 1 Filed 02/25/13 Pg 14 of 18 Pg ID 1483. On January 9, 2013, at approximately 1630 hours, Plaintiff was transferred fromthe day shift and ordered to work the January 10, 2013 afternoon road patrol shiftstarting at 1430 hours. Plaintiff’s department issued cell phone was alsoimmediately confiscated. The immediate confiscation of his cell phone alsodeviated from the Department’s past practice.84. Plaintiff was also excluded from meetings with Defendants Chief Dickerson andShelby and had his authority undermined by them.85. Since Plaintiff’s refusal to destroy evidence of suspected criminal activity, hisreports of suspected illegal activity to the City of Romulus Police Department andthe Attorney General’s Office and the exercise of his free speech rights Plaintiffhas suffered the adverse employment actions set forth in paragraphs 81-84 above.COUNT I:VIOLATION OF PLAINTIFF’S FIRST AMENDMENT FREE SPEECH RIGHTSPURSUANT TO 42 USC § 198386. Plaintiff re-alleges word for word the allegations set forth in paragraphs 1 through85 above.87. Plaintiff spoke out as a citizen on matters of substantial public concern when hecontacted the Attorney General’s Office to report his suspicion that Defendantswere engaged in a cover-up of an assault by a police officer of a handcuffed,defenseless prisoner and his concern that Defendants intended to destroy materialevidence of such assault.88. Plaintiff also spoke out as a citizen on matters of substantial concern when hereported to the City of Romulus Human Resources Department that he believedthat Defendant Captain Shelby had received pay for time he did not work.

2:13-cv-10771-JAC-MKM Doc # 1 Filed 02/25/13 Pg 15 of 18 Pg ID 1589. Defendants knew of Plaintiff’s protected speech because he told them of it.90. Upon learning of Plaintiff’s protected speech, Defendants retaliated againstPlaintiff when they eliminated his position in the Detective Bureau and deprivedhim of the benefits commensurate with such position, wrongly disciplined himand created a hostile work environment for him because he exercised his FirstAmendment free speech rights on matters of public concern.91. Defendants’ retaliatory actions were intentional and malicious.92. Defendants’ retaliatory actions were of the kind that would likely chill a personfrom exercising their free speech rights guaranteed by the First Amendment.93. As a direct and proximate result of Defendants’ violation of Plaintiff’s FirstAmendment free speech rights, Plaintiff suffered economic damages as set forthabove and non-economic injuries including, but not limited to, lost wages, loss ofprofessional opportunities, emotional distress, anxiety, depression, fear and othercompensable injuries.ACCORDINGLY, Plaintiff asks this Court to enter a judgment in his favor and againstDefendants, jointly and severally, in an amount in excess of the jurisdictional limit of this Court,as well as compensatory, exemplary and punitive damages, attorney fees, costs and interest andall other legal and equitable relief, including injunctive relief to prohibit any further acts ofretaliations and reinstatement to his former position as well as all other relief as provided under42 USC §§1983, 1985 and 1988.COUNT II:VIOLATION OF THE MICHIGAN WHISTLEBLOWER PROTECTION ACT94. Plaintiff re-alleges word for word paragraphs 1 through 93.

2:13-cv-10771-JAC-MKM Doc # 1 Filed 02/25/13 Pg 16 of 18 Pg ID 1695. Defendants are Plaintiff’s employer for purposes of Michigan’s WhistleblowerProtection Act, being MCL 15.361, et seq.96. Plaintiff is an employee covered by the Michigan Whistleblower Protect Act.97. When Plaintiff reported his suspicions of illegal activity to the local lawenforcement and the Michigan Attorney General’s Office as described above, hewas engaged in protected activity under the Michigan Whistleblower ProtectionAct.98. Defendants had actual knowledge of Plaintiff’s protected activity.99. After Defendants knew that Plaintiff had reported, or was about to report, hissuspicions of illegal activity to various public bodies, Defendants retaliatedagainst Plaintiff by eliminating his position in the Detective Bureau, transferringhim to another shift and taking other adverse employment actions againstPlaintiff.100. A causal connection exists between Plaintiff protected activity and Defendants’adverse employment actions taken against him. (See 81-84.)101. As a direct and proximate result of Defendants’ violation of the WhistleblowerProtection Act, Plaintiff suffered economic and non-economic injuries including,but not limited to, lost wages, loss of professional opportunities, emotionaldistress, anxiety, depression, fear and other compensable injuries.ACCORDINGLY, Plaintiff asks this Court to enter a judgment in his favor and againstDefendants in excess of the jurisdictional limit of this Court, including costs, attorney fees andinterest and all other legal and equitable relief including injunctive relief prohibiting Defendantsfrom further retaliatory conduct against Plaintiff and reinstatement as provided under theMichigan Whistleblower Protection Act.

2:13-cv-10771-JAC-MKM Doc # 1 Filed 02/25/13 Pg 17 of 18 Pg ID 17COUNT III:VIOLATION OF MICHIGAN PUBLIC POLICY102. Plaintiff re-alleges word for word paragraphs 1 through 101.103. Plaintiff refused to commit a crime in the course of his employment, to wit: todestroy material evidence of an officer assaulting a handcuffed prisoner asinstructed by Defendant Chief Dickerson.104. Michigan public policy provides that an employer may not retaliate or take anyadverse employment action against an employee who refuses to commit a crimein the course of his employment.105. Defendant City of Romulus d/b/a City of Romulus Police Department eliminatedPlaintiff’s position in the Detective Bureau and took other adverse employmentaction against him because he refused to commit a crime in the course of hisemployment, to wit: he refused to conspire in a cover-up and destroy evidence ofcriminal conduct by a co-employee as instructed by Defendant Chief Dickerson.(See, 81-84.)106. As a direct and proximate result of Defendants’ violation of Michigan publicpolicy, Plaintiff suffered economic and non-economic injuries including, but notlimited to, lost wages, loss of professional opportunities, emotional distress,anxiety, depression, fear and other compensable injuries.ACCORDINGLY, Plaintiff asks this Court to enter judgment in Plaintiff’s favor inexcess of the jurisdictional limit of the Court, including attorney’s fees, costs and interest, andprovide Plaintiff with all legal and equitable relief to which he may be entitled, includinginjunctive relief against any further acts of retaliation by Defendants and reinstatement.

2:13-cv-10771-JAC-MKM Doc # 1 Filed 02/25/13 Pg 18 of 18 Pg ID 18Dated: February 25, 2013___/s/ Joel B. Sklar______________JOEL B. SKLAR P38338Attorney for Plaintiff615 Griswold, Suite 1116Detroit, MI 48226313-963-4529Joelb79@hotmail.comJURY DEMANDPlaintiff demands a jury trial of this cause.__/s/ Joel B. Sklar_______________JOEL B. SKLAR P38338Attorney for Plaintiff615 Griswold, Suite 1116Detroit, MI 48226313-963-4529Joelb79@hotmail.comDated: February 25, 2013