candy
Inactive
162.
High-ranking Boulder Police officials believed to be among the unknown Boulder Police co-conspirators, as a matter of custom, policy and practice, have allowed members of the Boulder Police Department, including Defendant Thomas and the unknown Boulder Police co-conspirators, to leak confidential law enforcement information to the media and to allow for personal use of confidential law enforcement information by Boulder Police officers and officials in conjunction with seminars, presentations and various publications.
163.
High-ranking Boulder Police officials believed to be among the unknown Boulder Police co-conspirators were fully aware that Defendant Thomas and the unknown Boulder Police co-conspirators intended to utilize confidential law enforcement information in order to publish a book about the JonBenét Ramsey murder investigation while the investigation was still active and no charges had been filed against any individual in connection with the crime.
164.
In furtherance of the Boulder Police conspiracy, high-ranking Boulder Police officials, who are members of the unknown Boulder Police co-conspirators, deliberately and consciously took no administrative or legal action in an effort to prevent Defendant Thomas from illegally utilizing confidential law enforcement information in the books.
165.
In publishing his libelous book, Defendant Thomas and the unknown Boulder Police co-conspirators acted under color of state law and abused their status as a law enforcement officers by substantially contributing to an unlawful and unconstitutional "trial-by-media in the court of public opinion" of Plaintiffs John and Patsy Ramsey, individuals not charged with any crimes, who have been deprived by Defendant Thomas and the unknown Boulder Police co-conspirators of fundamental constitutional protections in criminal prosecutions, including the priceless right to a presumption of innocence.
166.
As a direct and proximate result of the Boulder Police conspiracy to deprive them of their constitutional rights of privacy, due process and equal protection of the laws, Plaintiffs John and Patsy Ramsey have suffered and continue to suffer damage to their reputations, incurred attorneys' fees and expenses in defending civil litigation and have suffered and continue to suffer severe mental anguish and emotional trauma in connection with the deprivation of the their constitutional rights under the Fifth, Ninth and Fourteenth Amendments to the Constitution of the United States and protected by 42 U.S.C. § 1983.
167.
The acts and/or omissions of Defendant Thomas and the unknown Boulder Police co-conspirators were committed under color of state or local law.
168.
In violation of 42 U.S.C. § 1983, the acts and/or omissions of Defendant Thomas and the unknown Boulder Police co-conspirators under color of state law, deprived Plaintiffs John and Patsy Ramsey of their rights, privileges, and immunities under the laws and Constitution of the United States, including the right of privacy, the right to due process and the right to equal protection of the laws secured by the Fifth, Ninth and Fourteenth Amendments to the United States Constitution.
169.
Defendant Thomas and the unknown Boulder Police co-conspirators acted with deliberate indifference to the constitutional rights of Plaintiffs John and Patsy Ramsey.
170.
Pursuant to 42 U.S.C. § 1988, Plaintiffs John and Patsy Ramsey are entitled to recover reasonable attorney fees as the result of the violations of 42 U.S.C. § 1983 by Defendant Thomas and the unknown Boulder Police co-conspirators as set forth herein.
WHEREFORE, Plaintiffs, John Ramsey and Patsy Ramsey, demand:
(a) That judgment be entered against Defendants, Steve Thomas and Unknown Officials of the Boulder, Colorado Police Department, including, but not limited to, Officer John Doe 1, Officer John Doe 2, Officer John Doe 3 and Officer Jane Doe, on Count Four of this Complaint for compensatory damages in an amount not less than Five Million Dollars ($5,000,000.00);
(b) That judgment be entered against Defendants, Steve Thomas and Unknown Officials of the Boulder, Colorado Police Department, including, but not limited to, Officer John Doe 1, Officer John Doe 2, Officer John Doe 3 and Officer Jane Doe, on Count Four of this Complaint for punitive damages in an amount not less than Ten Million Dollars ($10,000,000.00) to punish and penalize said Defendants and deter said Defendants from repeating their unlawful conduct;
(c) That judgment be entered against Defendants, Steve Thomas and Unknown Officials of the Boulder, Colorado Police Department, including, but not limited to, Officer John Doe 1, Officer John Doe 2, Officer John Doe 3 and Officer Jane Doe, on Count Four of this Complaint for attorneys' fees and expenses in an amount shown to be reasonable and just by the evidence; and
(d) That all costs of this action be assessed against said Defendants.
TRIAL BY JURY DEMANDED ON COUNT FOUR.
L. LIN WOOD, P.C.
High-ranking Boulder Police officials believed to be among the unknown Boulder Police co-conspirators, as a matter of custom, policy and practice, have allowed members of the Boulder Police Department, including Defendant Thomas and the unknown Boulder Police co-conspirators, to leak confidential law enforcement information to the media and to allow for personal use of confidential law enforcement information by Boulder Police officers and officials in conjunction with seminars, presentations and various publications.
163.
High-ranking Boulder Police officials believed to be among the unknown Boulder Police co-conspirators were fully aware that Defendant Thomas and the unknown Boulder Police co-conspirators intended to utilize confidential law enforcement information in order to publish a book about the JonBenét Ramsey murder investigation while the investigation was still active and no charges had been filed against any individual in connection with the crime.
164.
In furtherance of the Boulder Police conspiracy, high-ranking Boulder Police officials, who are members of the unknown Boulder Police co-conspirators, deliberately and consciously took no administrative or legal action in an effort to prevent Defendant Thomas from illegally utilizing confidential law enforcement information in the books.
165.
In publishing his libelous book, Defendant Thomas and the unknown Boulder Police co-conspirators acted under color of state law and abused their status as a law enforcement officers by substantially contributing to an unlawful and unconstitutional "trial-by-media in the court of public opinion" of Plaintiffs John and Patsy Ramsey, individuals not charged with any crimes, who have been deprived by Defendant Thomas and the unknown Boulder Police co-conspirators of fundamental constitutional protections in criminal prosecutions, including the priceless right to a presumption of innocence.
166.
As a direct and proximate result of the Boulder Police conspiracy to deprive them of their constitutional rights of privacy, due process and equal protection of the laws, Plaintiffs John and Patsy Ramsey have suffered and continue to suffer damage to their reputations, incurred attorneys' fees and expenses in defending civil litigation and have suffered and continue to suffer severe mental anguish and emotional trauma in connection with the deprivation of the their constitutional rights under the Fifth, Ninth and Fourteenth Amendments to the Constitution of the United States and protected by 42 U.S.C. § 1983.
167.
The acts and/or omissions of Defendant Thomas and the unknown Boulder Police co-conspirators were committed under color of state or local law.
168.
In violation of 42 U.S.C. § 1983, the acts and/or omissions of Defendant Thomas and the unknown Boulder Police co-conspirators under color of state law, deprived Plaintiffs John and Patsy Ramsey of their rights, privileges, and immunities under the laws and Constitution of the United States, including the right of privacy, the right to due process and the right to equal protection of the laws secured by the Fifth, Ninth and Fourteenth Amendments to the United States Constitution.
169.
Defendant Thomas and the unknown Boulder Police co-conspirators acted with deliberate indifference to the constitutional rights of Plaintiffs John and Patsy Ramsey.
170.
Pursuant to 42 U.S.C. § 1988, Plaintiffs John and Patsy Ramsey are entitled to recover reasonable attorney fees as the result of the violations of 42 U.S.C. § 1983 by Defendant Thomas and the unknown Boulder Police co-conspirators as set forth herein.
WHEREFORE, Plaintiffs, John Ramsey and Patsy Ramsey, demand:
(a) That judgment be entered against Defendants, Steve Thomas and Unknown Officials of the Boulder, Colorado Police Department, including, but not limited to, Officer John Doe 1, Officer John Doe 2, Officer John Doe 3 and Officer Jane Doe, on Count Four of this Complaint for compensatory damages in an amount not less than Five Million Dollars ($5,000,000.00);
(b) That judgment be entered against Defendants, Steve Thomas and Unknown Officials of the Boulder, Colorado Police Department, including, but not limited to, Officer John Doe 1, Officer John Doe 2, Officer John Doe 3 and Officer Jane Doe, on Count Four of this Complaint for punitive damages in an amount not less than Ten Million Dollars ($10,000,000.00) to punish and penalize said Defendants and deter said Defendants from repeating their unlawful conduct;
(c) That judgment be entered against Defendants, Steve Thomas and Unknown Officials of the Boulder, Colorado Police Department, including, but not limited to, Officer John Doe 1, Officer John Doe 2, Officer John Doe 3 and Officer Jane Doe, on Count Four of this Complaint for attorneys' fees and expenses in an amount shown to be reasonable and just by the evidence; and
(d) That all costs of this action be assessed against said Defendants.
TRIAL BY JURY DEMANDED ON COUNT FOUR.
L. LIN WOOD, P.C.