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1 Case :-cv-0-pa-jc Document Filed 0 Page of Page ID #: TOMLINSON & PRINCE, L.L.P. Timothy P. Prince, Esq. SBN North D Street, Suite 0 Mailing Address: P.O. Box San Bernardino, CA 0 (0-00 (0-0 - Facsimile Attorneys for Plaintiff, SAMUEL H. CLAUDER UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA EASTERN DIVISION SAMUEL HERSHEL CLAUDER, Plaintiff, vs. COUNTY OF SAN BERNARDINO, et al., Defendants. CASE NO. :-CV- PA (Jcx AMENDED COMPLAINT FOR DAMAGES FOR VIOLATION OF CONSTITUTIONAL RIGHTS [ U.S.C. ]. First Amendment Retaliation and Conspiracy;. Violation of Fourth and Fourteenth Amendment Right Malicious Prosecution;. Municipal Liability Monell [JURY TRIAL DEMANDED] JURISDICTION AND PARTIES. This is an action for money damages brought by Plaintiff Samuel Hershel Clauder ( Clauder pursuant to U.S.C. and, and the First and Fourteenth Amendments to the United States Constitution. This court has jurisdiction over this case under its federal question jurisdiction pursuant to U.S.C. and.. As the incidents complained of in this action occurred in the County of San Bernardino, State of California, within the territorial jurisdiction of this court, venue for Violation of Constitutional Rights

2 Case :-cv-0-pa-jc Document Filed 0 Page of Page ID #: properly lies in this court pursuant to U.S.C. (b(.. Clauder seeks recovery of damages from the County of San Bernardino (County, former San Bernardino County Sheriff Gary Penrod, an individual, ( Penrod, former Sheriff Deputy Michael Pelkey, an individual, ( Pelkey, Does through, current or former employees of San Bernardino County, and Does through.. Defendants DOES through, inclusive, committed some or all of the wrongful actions (and constitutional violations complained of in this action, and/or are otherwise responsible for and liable to plaintiff for the acts complained of in this action, but their identities are, and remain, unknown to plaintiff, who will amend this Complaint to add and to show the actual names of said DOE defendants when so ascertained by plaintiff.. Plaintiff Clauder is a natural person, who, at all times complained of in this action, resided in the County of San Bernardino, State of California. FACTS RELEVANT TO ALL CLAIMS. On February, 0, the County filed false charges of felony possession of child pornography against Samuel Hershel Clauder (San Bernardino Superior Court Case No. FSB00.. Clauder spent fifty (0 days in jail relating to said charges.. Three ( years and seven ( months later, on September,, the charges were dismissed.. On December,, the Court made a finding of factual innocence pursuant to California Penal Code.. No appeal was taken from the court s finding of factual innocence.. The child pornography was found on a laptop computer which was taken from the home occupied by Clauder s estranged wife and son.. The County Sheriff seized the computer from Clauder s estranged wife months after Clauder permanently left the home due to a restraining order issued as part of their divorce. for Violation of Constitutional Rights

3 Case :-cv-0-pa-jc Document Filed 0 Page of Page ID #:. The computer was used by the Clauder family and had multiple user identities. The evidence was downloaded on the computer under the identity of Clauder s son, who was then Administrator of the computer, months after Samuel Clauder was arrested and taken from the house on April, 0, pursuant to the false domestic violence charges which were later dismissed.. Although Clauder s estranged wife and son claimed that nobody had used the computer after Clauder left the house, in fact more than 0,000 system hours had been logged, including daily use from May to July 0.. The County performed polygraphs of Clauder's estranged wife and son which they failed to pass.. At all times the County knew that the only evidence supporting their prosecution hinged on the credibility of Clauder s estranged wife, who lacked understanding of computers, and that the couple was involved in a contentious divorce.. Because the nature of the alleged crime carried social opprobrium but not present danger of violence, coupled with the known propensity for fabrication by those engaged in bitter divorces, the need to investigate potentially exculpatory evidence before making an arrest for proceeding with a criminal prosecution should have been evident to any reasonable peace officer. See Merriman v. Walton, F.d, (th Cir., cert. denied, U.S. 0, S.Ct., L.Ed.d (.. Although both subjects failed to pass polygraph exams, Sheriff Deputy Pelkey continued to refer to Clauder s estranged wife and son as supporting "witnesses" while hiding the fact that no evidence supported the charges.. This, and many other facts were revealed in the audiotaped confession of Clauder's son of September,, a copy of which was not provided to Clauder until late December.. The County did not question or interview Clauder's son nor any other supporting witness after the failed polygraph examination until his son s confession three and one-half (-/ years after filing the reckless and falsified charges. for Violation of Constitutional Rights

4 Case :-cv-0-pa-jc Document Filed 0 Page of Page ID #:. The false charges were instigated by Deputy Pelkey of the Twin Peaks Sheriff Station at the direction of, and with the approval of, Penrod. Pelkey and Penrod harbored personal animosity towards Clauder because of Clauder's investigative journalistic reporting, political consultancy and his reports of official misconduct made to the Sheriff s Department against Pelkey's colleagues assigned to the Twin Peaks Sheriff Station.. In 0 and 0, as a member of the media, Clauder uncovered falsified evidence made by the Sheriff s Department sergeant in charge of investigating the Aaron Plante rape case to cover up the location of the crime. When the charges were dismissed, Clauder wrote reports and criticized the Sheriff's mishandling of the case to local, state and federal authorities, resulting in an investigation into the Sheriff's Department and extensive negative publicity.. Clauder s actions as an investigative journalist angered Penrod and deputies assigned to the Twin Peaks Sheriff s Station, who considered Clauder an enemy of the Sheriff.. Clauder subsequently lodged a complaint alleging official misconduct with the Sheriff s Department against the sergeant.. The Sheriff s Department ultimately sustained Clauder s complaint and imposed administrative punishment against the Sergeant which included demotion in rank and transfer to another assignment.. The false charges were also instigated and perpetuated by Penrod and the other defendants because of their personal animosity and desire to discredit Clauder as a result of Clauder's reports of official misconduct and corruption made to the Federal Bureau of Investigation five days before the felony charges were filed.. FBI policy precludes investigating or pursuing complaints made by persons with pending felony charges.. Clauder reported allegations that Sergeant Randy Beavers County computer was seized and found to have child pornography, that Beavers seduced a for Violation of Constitutional Rights

5 Case :-cv-0-pa-jc Document Filed 0 Page of Page ID #: fifteen-year-old girl and that Penrod knew of these allegations and failed to act on them because Penrod was having an affair with Randy Beavers wife. Randy Beavers wife, Cindy Beavers, served under Penrod as the Sheriff s Public Information Officer. Clauder also reported the retaliation by Penrod and County for Clauder s internal affairs complaints as set forth above. Clauder also reported Penrod and County s pattern of retaliation against those who expressed dissent.. Unbeknownst to Clauder, the FBI had an established relationship of cooperation and information sharing with Penrod and County, particularly with regard to political investigations. Five days after Clauder s report, Penrod, Pelkey and County caused the false charges to be filed against Clauder, who was active politically and was a congressional staff member.. The first Deputy District Attorney assigned to prosecute Clauder told Clauder's defense attorney it was a "poor case which shouldn't have been filed." 0. However, the case was filed and prosecuted for three years and seven months under the supervision and at the direction of District Attorney Michael Ramos.. Ramos directed his subordinates to file charges and pursue the case without any supporting evidence because of a political vendetta involving his campaign manager.. David Ellis, the campaign manager for Ramos' re-election campaign, and Clauder were on opposite sides of a long-term, major political battle to determine the use of the El Toro Marine Base in Orange County. Ellis and Clauder had several extremely contentious personal conflicts during the ten years of this campaign, involving statements to the press and to the voters. When the voters decided the base should be a park instead of an airport, Ellis lost the opportunity to reap as much as $0 million in profit as a contractor.. "We finally have Clauder where we want him," Ellis stated to more than one person in.. The fraudulent charges were pursued, filed and prosecuted in flagrant violation of Clauder's civil rights by politically and personally motivated law enforcement for Violation of Constitutional Rights

6 Case :-cv-0-pa-jc Document Filed 0 Page of Page ID #:0 officers, Penrod and Pelkey, and by County prosecutors to make Clauder a national scandal, placing his life in danger during the 0 days he spent in jail, in general circulation, facing the constant threat of death if the prisoners found out he was accused of child pornography, and costing him the best job of his career, ruining his name and reputation and intentionally causing him extreme and severe mental and emotional distress. FIRST CLAIM FOR RELIEF U.S.C. SECTION [Against All Defendants] FIRST AMENDMENT RETALIATION AND CONSPIRACY. Plaintiff realleges and incorporates by reference herein paragraphs -0 of this Complaint.. Defendants retaliated against Clauder for filing and publishing reports criticizing the Sheriff's mishandling of the Aaron Plante case.. Defendants and Michael Ramos conspired with and were improperly influenced by Ramos campaign manager David Ellis to retaliate against Clauder for his political advocacy and consultancy relating to the El Toro Marine Base.. Defendants Pelkey, Penrod and Does - retaliated against Clauder as a result of his investigative journalistic reporting, political consultancy and his complaints of official misconduct made to the Sheriff s Department pursuant to Penal Code... The retaliation took the form of pursuing for four years obviously false and fraudulent charges and prosecution against Clauder of felony child pornography, one of the most hated and vilified crimes. 0. The above named Defendants conspired with one another and with District Attorney Ramos to do the above listed acts knowing that Clauder, as any citizen, had the clearly established right under the First Amendment of the United States Constitution to criticize as well as the statutory right under California Penal Code. to report for Violation of Constitutional Rights

7 Case :-cv-0-pa-jc Document Filed 0 Page of Page ID #: official misconduct by public employees of the Sheriff's Department and to participate in the political process.. Defendants actions violated Clauder s First Amendment right to freedom of speech regarding matters of public concern. Clauder would not have been subjected to Defendants actions over the course of four years but for reporting, filing and publishing his criticism and political advocacy. As a proximate result of Defendants actions, Clauder suffered special damages in the form of lost income, loss of employee benefits, including a paid medical plan in an amount to be proven at trial.. As a proximate result of Defendants actions, Clauder suffered general damages including loss of reputation and emotional distress, the value of which will be proven at trial.. The acts and omissions of each Defendant set forth in this complaint (except Defendant San Bernardino County were done by each Defendant knowingly, intentionally and maliciously and for the purpose of harassment, oppression and infliction of injury upon Plaintiff, and in reckless, wanton and callous disregard of Plaintiff s safety, security and civil rights; and by reason thereof, Plaintiff claims exemplary and punitive damages from each Defendant (except San Bernardino County in a sum to be determined at the time of trial. SECOND CLAIM FOR RELIEF U.S.C. SECTION [Against All Defendants] VIOLATION OF FOURTH AND FOURTEENTH AMENDMENT RIGHT - MALICIOUS PROSECUTION. Plaintiff realleges and incorporates by reference herein paragraphs - of this Complaint. for Violation of Constitutional Rights

8 Case :-cv-0-pa-jc Document Filed 0 Page of Page ID #:. As shown above, Defendants falsely, fraudulently and without any evidence prosecuted Clauder on a felony charge of violation of child pornography.. At the preliminary hearing, Defendants presented false evidence about the existence of a password and whether others could access Clauder s profile on the computer. They knew of the falsity or acted in reckless disregard of the truth by presenting testimony that Clauder s identity was password protected and that he could have downloaded the child pornography.. The lack of a password on Clauder s profile, the accessibility and history of the computer indicating it had been used extensively after Clauder left the house and the fact that Clauder himself was the only one who lacked access to the computer were readily available and obvious facts that were known to Defendants and concealed or recklessly ignored.. Also as shown above, Defendants knew that Clauder could not have committed a violation of Cal. Penal Code., and, nonetheless, authored fraudulent and baseless police reports about the charges, falsely and maliciously accusing plaintiff of various acts. 0. Said police reports authored, directed and/or approved by Pelkey, Penrod and DOES through, inclusive, also contained material misrepresentations of facts and material omission of facts upon which the San Bernardino County District Attorney's Office relied, in large part, in deciding to file and to maintain the criminal prosecution of the plaintiff.. Moreover, the San Bernardino County District Attorney's Office also filed and prosecuted the above-referenced criminal action against the plaintiff because of political pressure exerted by Defendants Penrod and Pelkey and by David Ellis upon the San Bernardino County District Attorney's Office, including those Deputy District Attorneys who participated in filing and prosecuting said above-referenced criminal action against the plaintiffs, and pursuant to the policies of said District Attorney's Office, created by San Bernardino County District Attorney Michael Ramos and his for Violation of Constitutional Rights

9 Case :-cv-0-pa-jc Document Filed 0 Page of Page ID #: predecessors, to file and pursue, guilty or not, criminal action against his political adversaries.. Moreover, said criminal action against Clauder was terminated in his favor, in a manner inconsistent with guilt; by the dismissal of said case and subsequent finding of factual innocence.. Moreover, as shown above, none of said defendant officers had probable cause to believe that Clauder committed a crime.. Moreover, said criminal action was procured by said defendants with malice.. Moreover, as California does not provide for any remedy for an aggrieved malicious prosecution victim to sue a public employee for the filing and/or procurement of a baseless criminal action, pursuant to Parratt v. Taylor, U.S. (, the actions of said defendants constituted a violation of the Fourth, Ninth and Fourteenth Amendments to the United States Constitution.. As a direct and proximate result of the actions of defendants, as complained of herein, Plaintiff: was substantially physically, mentally and emotionally injured, incurred medical and psychological costs, bills and expenses, suffered loss of earnings and earning capacity, incurred other special and general damages and expenses, including attorney's fees and associated costs; all in an amount to be proven at trial.. The actions of defendants as complained of herein, were committed maliciously, oppressively and/or in reckless disregard of plaintiff's constitutional rights, sufficient for an award of punitive / exemplary damages against all defendants, save for defendant County, in an amount to be proven at trial. for Violation of Constitutional Rights

10 Case :-cv-0-pa-jc Document Filed 0 Page of Page ID #: THIRD CLAIM FOR RELIEF U.S.C. SECTION [Against Defendant County of San Bernardino] MUNICIPAL LIABILITY MONELL. Plaintiff realleges and incorporates by reference herein paragraphs - of this Complaint.. At all times relevant to this lawsuit, Penrod, District Attorney Ramos and/or Does - were the policymaking officials of the County of San Bernardino, as that term applies to municipal liability under U.S.C.. 0. Prior to September,, County developed and maintained policies or customs exhibiting deliberate indifference to the constitutional rights of persons in San Bernardino County which caused the violations of Plaintiff s rights.. It was the policy and/or custom of San Bernardino County Sheriff Department to inadequately and improperly screen potential employees, to promote employees who had demonstrated disregard for the rights of those policed by the San Bernardino County Sheriff Department and who were disinclined to properly and thoroughly investigate complaints of police misconduct. As a result, acts of misconduct by San Bernardino County Sheriff Department personnel were tolerated by San Bernardino County Sheriff officials.. It was the policy and/or custom of San Bernardino County to inadequately supervise and train its police officers, including the Defendant officers, thereby failing to adequately discourage further constitutional violations on the part of its Sheriff officers.. Defendants failed to provide adequate training and supervision with respect to the effect of contemplated or active divorce proceedings and estrangement on intrafamily accusations, motivation of witnesses to lie, the need to corroborate evidence, and the handling and evaluation of computer evidence and child pornography cases.. As a result of the above described policies and customs, San Bernardino County Sheriff officers, including the Defendant officers, believed that their actions for Violation of Constitutional Rights

11 Case :-cv-0-pa-jc Document Filed 0 Page of Page ID #: would not be properly monitored by those senior to them and that misconduct would not be properly investigated or sanctioned, but would be tolerated.. A code of silence was fostered and encouraged to exist within the San Bernardino County Sheriff Department which served to insulate officers from accountability for their actions.. The above described policies and customs demonstrated a deliberate indifference on the part of policymakers of the County of San Bernardino to the constitutional rights of persons within San Bernardino County, and was the cause of the violations of Plaintiff s rights alleged herein.. It was the policy and/or custom of San Bernardino County to inadequately supervise and train its deputy district attorneys, thereby failing to adequately discourage further constitutional violations on the part of its prosecutors.. Said prosecutors lacked training on the need to scrutinize reports from witnesses engaged in divorce proceedings, assure that witnesses have been interviewed promptly and thoroughly, promptly verify the foundation of electronic evidence of child pornography and who had possession and access to the computer and to the identity on the computer under which it was downloaded.. County s district attorneys also lacked training on prosecution of crimes carrying social opprobrium, and the irreversible damage that is caused by filing charges prior to a careful review of the evidence and investigation of potentially exculpatory evidence. 0. County s district attorneys also lacked training and supervision on the handling of cases with complaining witnesses engaged in bitter divorces with known propensity for fabrication.. As a proximate result of Defendants actions, Clauder suffered special damages in the form of lost income, loss of earning capacity, loss of employee benefits, including a paid medical plan in an amount to be proven at trial. for Violation of Constitutional Rights

12 Case :-cv-0-pa-jc Document Filed 0 Page of Page ID #:. As a proximate result of Defendants actions, Clauder suffered general damages including loss of reputation and emotional distress, the value of which will be proven at trial. WHEREFORE, plaintiff prays for judgment as follows: a For a judgment against all defendants for compensatory damages in an amount in to be proven at trial; b For a judgment against all defendants, save defendant County, for punitive damages in an amount to be proven at trial; c For an award of reasonable attorney's fees and costs; d For a trial by jury; and e For such other and further relief as this honorable court deems just and equitable. DATED: June, TOMLINSON & PRINCE, L.L.P. by: Timothy P. Prince Attorneys for Plaintiff SAMUEL H. CLAUDER Plaintiff demands a trial by jury. DATED: June, DEMAND FOR JURY TRIAL TOMLINSON & PRINCE, L.L.P. by: Timothy P. Prince Attorneys for Plaintiff SAMUEL H. CLAUDER for Violation of Constitutional Rights

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