Flagg v. Detroit, City of et al

Filing 32

Flagg v. Detroit, City of et al

Doc. 32

UNITED STATES OF AMERICA IN THE DISTRICT COURT FOR THE EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION
ERNST FLAGG, as Next Friend of JONATHAN BOND, a minor,
Plaintiff,

Case No.: 05-CV-74253 Hon. Gerald Rosen
-vs-

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CITY OF DETROIT, a municipal corporation; DETROIT POLICE CHIEF ELLA BULLY-CUMMINGS; DEPUTY DETROIT POLICE CHIEF CARA BEST; JOHN DOE POLICE OFFICERS 1 - 20; ASST. DEPUTY POLICE CHIEF HAROLD CURETON; COMMANDER CRAIG SCHWARTZ; POLICE LT. BILLY JACKSON;

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MAYORKWAMM. KILPATRICK, CHRSTIN BEATTY, jointly and severally
Defendants.

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Norman Yatooma & Associates, P.c.
By: Norman A. Yatooma (P54746) By: Robert S. Zawideh (P43787) Attorneys for Plaintiffs 219 Elm Street Birmingham, Michigan 48009 [phone]

City of Detroit Law Department
By: John A. Schapka (P3673 1)

Attorneys for Defendants 1650 First National Building Detroit, Michigan 48226 [phone]

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PLAINTIFF'S MOTION FOR LEAVE TO FILE SECOND AMENDED COMPLAINT
PLAITIFF ERNST FLAGG, as Next Friend of JONATHAN BOND, a minor, by his
undersigned counsel, NORMAN Y ATOOMA & ASSOCIATES, P.C., moves under Federal

Rule of Civil Procedure 15(a) to amend his First Amended Complaint entered with this court

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September 22, 2006, to reinstate as Defendants certain parties who were named in the original
Complaint, and to otherwise clarify his claims as follows:

1. On December 19, 2007 counsel for Plaintiff and Defendant conferred via telephone,
wherein Plaintiff s counsel requested Defendants' counsel's assent to the relief requested herein.

Plaintiff s counsel explained the nature of the relief requested; however, concurrence was not
obtained.

2. This Court should grant the motion, because the principles of justice strongly support the
amendment, and the exceptions justifying denial of the motion are absent.

3. Plaintiff Jonathan Bond, through his next friend Ernest Flagg, commenced this suit in this
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Court on November 7, 2005, alleging that the Defendant City of

Detroit and several individuals -

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- including Detroit Mayor Kwame Kilpatrick, his former chief of staff Christine Beatty, the
current and former Detroit police chiefs, certain unknown Detroit police offcers, and Michigan

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attorney general Mike Cox -- violated Plaintiffs federal constitutional right of access to the
courts and conspired among themselves to commit this constitutional violation by inadequately

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investigating the April 30, 2003 death of Plaintiffs mother, Tamara Greene, and concealing
material evidence concerning this incident. Ms. Greene died from gunshot wounds after several
shots were fired into her vehicle.
4. In accordance with an order of

this Court entered on or about August 31, 2006, granting

in part and denying in part a Motion to Dismiss brought by several defendants, Plaintiff fied a
First Amended Complaint in this Court on or about September 21,2006.

5. Ms. Greene purportedly performed as an exotic dancer at a widely-rumored party at the

Detroit mayor's offcial residence, the Manoogian Mansion, about six months before she was

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murdered in a drive-by shooting that occurred in front of her home on Roselawn in the City of
Detroit.

6. Tamara Bond-Greene was the mother of plaintiff JONATHAN BOND, a 14-year-old
minor child.

7. Tamara Bond-Greene was a licensed exotic dancer and employed in various clubs in the

City of Detroit and by private parties. Ms. Greene performed under the stage name of
"Strawberry" .

8. It has been widely reported in the local media that, sometime in the fall of 2002, a wild
party occurred at the Manoogian Mansion. i It was rumored that Defendant Kilpatrick attended
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this party,2 as well as several of his close friends, certain Detroit Police Offcers, and nude exotic

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dancers, including Tamara Bond Greene. According to various accounts, it is alleged that
Defendant Kilpatrick's wife, Carlita Kilpatrick arrived at the party unexpectedly, and assaulted
one or more of the dancers.

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9. On information and belief, that night, following the alleged attack by Mrs. Kilpatrick,

Defendant Kwame Kilpatrick's security detail, known as the Executive Protection Unit, or

"EPU", escorted, transported, or otherwise accompanied the injured dancer to the emergency
room of a local hospitaL.

10. On information and belief, at least one Emergency Medical Technician ("EMT") reported

to the media that, on or about the time of the alleged Manoogian party, individuals who appeared

to be members of the EPU brought in an injured woman for treatment and arranged for all
EMT's to be removed from the emergency room.

1 The Manoogian Mansion is the traditional residence of Detroit and his or her family. the Mayor of the City of 2 On information and belief, Defendant Kilpatrck and his family had not as yet moved into the Manoogian Mansion,

as it was undergoing renovations at the time.

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1 1. On or about the time of the alleged party, and at all relevant times thereafter, Harold
Nelthrope ("Nelthrope") was a detective in the EPU before he was transferred.

12. Beginning in March of 2003, Nelthrope reported allegations of illegal conduct and
misconduct by fellow EPU offcers and by Detroit Mayor Kwame Kilpatrick and his wife to the
police department's Professional Accountability Bureau. These allegations included claims that
close friends of

Defendant Kwame Kilpatrick on EPU were claiming overtime pay to which they

were not entitled, and drinking on the job; there were also allegations that Carlita Kilpatrick

assaulted one or more of the dancers at the alleged party at the Manoogian Mansion in the fall of
2002, and that there were efforts to cover up these crimes.
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13. Gary Brown, the deputy chief of the Professional Accountability Bureau, summarized
these allegations in a 5-page memorandum dated April

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24 and April 30, 2003, (attached hereto as

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Exhibit A) and authorized a preliminary investigation into these allegations.

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14. According to Brown, "(t)he most serious allegation made by Offcer Nelthrope is that

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Mrs. Carlita Kilpatrick was involved in a physical altercation with a female dancer, causing
bodily injury requiring medical attention. If this allegation is proven to be fact, the potential for

assault charges to be fied against Mrs. Carlita Kilpatrick as well as potential obstruction of
justice charges and or misconduct in offce charges against anyone found to have collected and
destroyed activity logs will warrant national headlines and severely damage the political future
of

Mayor Kilpatrick."

15. Brown prepared another memorandum regarding Nelthrope's allegations. See
Memorandum dated May 6, 2003, attached hereto as Exhibit B. In that memorandum, Brown
stated that Nelthrope made a point of saying that he was wearing a bulletproof vest because "he
didn't trust many police offcers."

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16. These memoranda were given to then police chief, Jerry Oliver, and then passed along to

Defendant Christine Beatty, the mayor's Chief of Staff or to others in Defendant Kilpatrick's

offce.
17. On information and belief, on or about this time Defendant Christine Beatty, the Mayor's

Chief of Staff, without having conducted any investigation to support the claim, reported to
Defendant Kilpatrick that Brown was conducting an unauthorized investigation, and that he
needed to be removed from his department.

18. Former Police Chief Oliver, Defendant Mayor Kilpatrick, Defendant Beatty and other
City offcials had a meeting regarding Brown's investigation. Following that meeting,

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Defendant Kilpatrick decided to terminate Brown, a decorated, well-respected twenty-year
member of the Detroit Police Department.
19. Approximately two days after the May 6, 2003 memorandum was submitted to former

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Chief Oliver, Brown was discharged from his position as deputy chief of the Professional
Accountability Bureau.

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20. On information and belief, Defendant Mayor Kwame Kilpatrick fired Deputy Police
Chief Gary Brown shortly after he submitted the May 6, 2003 memorandum to former Chief

Oliver to avoid further investigation into the allegations of the "wild party," or that his wife,
Carlita Kilpatrick, assaulted an exotic dancer at that party.

21. Further, members of Defendant Kwame Kilpatrick's offce then identified Nelthrope as
being the source of the allegations of misconduct to the media, and the mayor publicly called

Nelthrope a liar. See Deposition of Defendant Kwame Kilpatrick, pp. 60-62, attached hereto in
its entirety as Exhibit C. Nelthrope was likewise terminated from his employment.

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22. Approximately one month after Det. Nelthrope first began reporting allegations of

misconduct to internal affairs, and around the time that Deputy Chief Brown was authoring his

two memos to former chief Oliver, on April 30, 2003, at approximately 3:40 a.m., Tamara
Greene was murdered in a drive-by shooting that occurred in front of her home on Roselawn in
the City of Detroit, while she sat behind the wheel of

her automobile with a friend who sat in the

front passenger seat. The passenger survived the shooting.

23. On information and belief, twelve .40 caliber shell casings were found at Ms. Green's
murder scene. Witnesses reported that the shooter left the scene in a "white trailblazer."

24. On information and belief, .40 caliber Glocks, Model 22, are standard issue weapons for
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members of the Detroit Police Department.

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25. On information and belief, the Detroit Police Department, Homicide Section, was
assigned to investigate the murder of Tamara Greene.
26. On information and belief, Lt. Al Bowman of the Detroit Homicide section of

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the Detroit

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Police Department was a detective investigating Greene's homicide assigned to 'Squad 8.'

27. Sgt. Marian Stevenson, a former homicide investigator who worked under Lt. Bowman,

was also assigned to the Tamara Greene murder investigation. Sgt. Stevenson concluded that
someone ordered Greene's murder. The basis for her belief was that (1) Greene was shot first,
and (2) that Greene's passenger was able to exit the vehicle, and (3) an eyewitness reported that

the shooter's vehicle turned around after shooting Greene and had the opportunity to shoot the
passenger as well, but did not.

28. According to Sgt. Stevenson, someone erased her case notes on the Tamara Greene
murder investigation from her police department computer hard drive, and her zip storage fies

disappeared from a locked cabinet inside the police department.

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29. Sgt. Stevenson did not report the theft to her superiors out of

fear for her safety.

30. According to Sgt. Stevenson, she and her colleagues in the Homicide Section were
concerned that they may lose their jobs if

they continued to investigate the case.

31. On information and belief, in the course of his investigation, regarding the identity of the

shooter, Lt. Al Bowman concluded that "given the number of rounds fired with that one
individual with that one gun, it was presumed it could have been someone in law enforcement."
32. On information and belief, Lt. Bowman gave the information directly to Defendant Police
Chief

Ella Bully-Cummings.

33. On information and belief, Lt. Bowman was called into a meeting with Defendants,
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Police Chief Ella Bully-Cummings, Assistant Chief of

Police Harold Cureton, Commander Craig

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Schwartz, and Lt. Billy Jackson, and was directed by them to cease investigating Greene's

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homicide and to "put the fie away".

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34. On information and belief, Lt. Bowman did not cease the investigation as ordered by
Police Chief Bully Cummings, Assistant Chief of Police Harold Cureton, Commander Craig
Schwartz, and Lt. Billy Jackson

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35. On information and belief, Defendant Cara Best, Bowman's supervisor ordered Bowman

to be transferred out of homicide ultimately because of his investigating of Greene's homicide.

He was then transferred to the 2nd Precinct, to a different position and placed on the midnight
shift.
36. The Greene homicide fie was seized from the homicide section and locked away in the

offce of Lieutenant Billy Jackson immediately after Lt. Al Bowman was transferred out of the

Homicide Section. See page 7 of 15 of transcript of telephone call between Michigan State
Police D. Sgt Mark Krebs and Lt. Al Bowman, attached hereto as Exhibit D.

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37. On information and belief, when Lt. Bowman asked his immediate supervisor why he

was moved to the overnight shift, Bowman was told, "I guess you've been asking too many
questions about the Strawberry case."

38. On information and belief, these Defendants either directly or indirectly through their
agents erased the case notes of the Greene investigation that Lt. Al Bowman and Sgt. Stevenson
collected and maintained on their computers at the Detroit Police Department.

39. That Defendant, Ella Bully-Cummings ordered the Greene homicide fie to be placed in
the Cold Case fie after only one year, contrary to the Detroit Police Department standard policy
and/or practice of waiting two years before designating a homicide fie as a "cold case". See
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page 8 of 15 of transcript of telephone call between Michigan State Police D. Sgt Mark Krebs
and Lt. Al Bowman, attached hereto as Exhibit D.

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40. At all relevant times, once Tamara Greene's murder fie was transferred to Cold Case, it
would have been under the control of Sgt. Godbow of

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the Detroit Police Department.

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41. On information and belief, Sgt. Godbow as head of the Cold Case section of the

Homicide division, has control over this investigation despite the rumors that a family member
of Sgt. Godbow was once romantically involved with the decedent, Tamara Greene.

42. Lt. Alvin Bowman, and more recently former Detective Harold Nelthrope and former
Deputy Chief Gary Brown of the Detroit Police Department were successful in convincing two

different Wayne County juries that several of these defendants retaliated against them for
investigations that involved or were related to Ms. Greene's death

43. The amendment is not futile, since it asserts its claims with greater specificity and
reasserts claims against Defendant Mayor K wame Kilpatrick and former Chief of Staff Christine

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Beatty for their role in retaliating against those that investigated the allegations that related to
wrongdoing that may involved Ms. Greene.

44. Dilatory motive and bad faith are absent, because discovery is ongoing and the court has

only recently scheduled a Rule 26(f) conference for the purpose of addressing, among other
things, the need for additional amendment of the pleadings.

WHEREFORE, PLAINTIFF respectfully requests this Court to grant his motion and
permit him to fie and serve his Second Amended Complaint.
Respectfully Submitted,

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Dated: December 18, 2007

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/s/ Robert S. Zawideh Norman Yatooma & Associates, P. C. By: Norman A. Yatooma (P54746) By: Robert S. Zawideh (P43787) Attorneys for Plaintiff 219 Elm Street Birmingham, Michigan 48009 [phone]
zawideh(£normanyatooma. com

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BRIEF IN SUPPORT OF MOTION TO AMEND COMPLAINT
T ABLE OF CONTENTS

T ABLE OF CONTENTS.......................................................................................................... 10

is SUES PRESENTED.............................................................................................................. 1 1

CONTROLLING AUTHORITIES............................................................................................ 12

ARGUMNT......................................................................................................................... ..13
UNDER FEDERAL RULE OF CIVIL PROCEDURE 15 AND FOMAN V. DA vis, THE

COURT SHOULD GRANT PLAINTIFF LEAVE TO FILE A SECOND AMENDED
COMPLAINT TO ADD MAYOR KW AME KILPATRICK AND HIS FORMER CHIEF OF STAFF CHRISTINE BEATTY AS DEFENDANTS FOR THEIR PARTICIPATION

IN THE RETALIATION AND INTIMIDATION OF FORMER DET. HAROLD

~ NELTHROPE AND FORMER DEPUTY CHIEF GARY BROWN BECAUSE THEY
iff WERE INCLUDED IN THE ORIGINAL PLEADING, PLAINTIFF IS ASSERTING ”.

~ THE SAME COUNTS AS IN THE FIRST AMENDED COMPLAINT, AND IS ~ ESSENTIALLY SUBMITTING THE SAME CLAIMS AGAINST ALL OF THE
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ISSUES PRESENTED

WHTHER, UNER FEDERAL RULE OF CIVIL PROCEDUR 15 AN FOMAN V DA vis,

THE COURT SHOULD GRAT PLAITIFF LEAVE TO FILE A SECOND AMNDED COMPLAIT TO ADD MAYOR KW AM KILPATRICK AN HIS FORMR CHIEF OF
STAFF CHRISTIN BEATTY AS DEFENDANTS FOR THEIR PARTICIPATION IN THE RETALIATION AND INTIMIDATION OF FORMR DET. HAROLD NELTHROPE AND FORMR DEPUTY CHIEF GARY BROWN BECAUSE THEY WERE INCLUDED IN THE ORIGINAL PLEADING, PLAITIFF IS ASSERTING THE SAM COUNTS AS IN THE

FIRST AMNDED COMPLAIT, AN IS ESSENTIALLY SUBMITTING THE SAM CLAIMS AGAIST ALL OF THE APPROPRIATE DEFENDANTS WITH GREATER
SPECIFICITY.

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CONTROLLING AUTHORITIES
Federal Cases

Adams v. Gould, 739 F.2d 858, 863 (3rd Cir. 1984) ...................................................................14

Allard Enterprises, Inc. v. Advanced Programming Resources, Inc., 249 F.3d 564, 571 n.l (6th Cir. 2001)........................................................................................................................ ...... 13
Duggins v. Steak 'Shake, Inc., 195 F.3d 828, 834 (6th Cir. 1999) ...............................................13

Inge v. Rock Financzal Corp, 388 F.3d 930, 937 (6th Cir. 2004) ................................................13
Tefft v. Seward, 689 F.2d 637, 640 n.2 (6th Cir. 1982) ...............................................................13

Rules

Fed. R. Civ. P. 15(a)................................................................................................................. 13

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ARGUMNT
UNDER FEDERAL RULE OF CIVIL PROCEDURE 15 AND FOMAN V. DA vis, THE COURT SHOULD GRANT PLAINTIFF LEAVE TO FILE A SECOND AMENDED COMPLAINT TO ADD MAYOR KW AME KILPATRICK AND HIS FORMER CHIEF OF STAFF CHRISTINE BEATTY AS DEFENDANTS FOR THEIR PARTICIPATION

IN THE RETALIATION AND INTIMIDATION OF FORMER DET. HAROLD NELTHROPE AND FORMER DEPUTY CHIEF GARY BROWN BECAUSE THEY
WERE INCLUDED IN THE ORIGINAL PLEADING, PLAINTIFF IS ASSERTING THE SAME COUNTS AS IN THE FIRST AMENDED COMPLAINT, AND IS ESSENTIALLY

SUBMITTING THE SAME CLAIMS AGAINST ALL OF THE APPROPRIA TE
DEFENDANTS WITH GREATER SPECIFICITY.
When a party requests leave to amend his pleading, "leave shall be freely given when
justice so requires." Fed. R. Civ. P. 15(a); accord, Foman v. Davis, 371 U.S. 178, 182, 83 S. Ct.
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227, 9 L. Ed. 2d 222 (1962); Inge v. Rock Financial Corp, 388 F.3d 930, 937 (6th Cir. 2004).

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Only certain specific reasons, like bad faith, dilatory motive, undue delay, futility, or repeated
failure to cure deficiencies by earlier permitted amendments can justify denial of leave to amend.

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Foman, 371 U.S. 178, 182, Allard Enterprises, Inc. v. Advanced Programming Resources, Inc.,

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249 F.3d 564, 571 n.l (6th Cir. 2001); Duggins v. Steak 'n Shake, Inc., 195 F.3d 828, 834 (6th
Cir. 1999).

The Sixth Circuit has read and evaluated the dilatory motive, undue delay, and prejudice

factors together: "(DJelay by itself is not (aJ suffcient reason to deny a motion to amend. Notice

and substantial prejudice to the opposing party are critical factors in determining whether
an amendment should be granted." Wade v. Knoxvile Utilities Ed, 259 F.3d 452,458-459 (6th
Cir. 2001); accord, Morse v. McWhorter, 290 F.3d 795, 800 (6th Cir. 2002); Tefft v. Seward, 689

F.2d 637, 640 n.2 (6th Cir. 1982) (emphasis added). "At some point, however, delay will become

'undue,' placing an unwarranted burden on the court, or will become 'prejudicial,' placing an
unfair burden on the opposing party.'" Morse, 290 F.3d 795, 800, quoting Adams v. Gould, 739

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F.2d 858, 863 (3rd Cir. 1984). Thus, a party cannot ordinarily "wait until the discovery date has

passed(,) and a motion for summary disposition has been fied on the basis of claims asserted in

the original complaint before introducing entirely different legal theories in an amendment."

Priddy v. Edelman, 883 F.2d 438, 446 (6th Cir. 1989). Nonetheless, "where 'the amended
claim was obviously one of the objects of discovery and related closely to the original
claim,'" the Rule 15 and Foman liberal amendment standards are controllng. Tokio Marine

& Fire Ins. Co., Ltd v. Employers Ins. of Wasau, 786 F.2d 101, 103 (2d Cir. 1986); see also,
Miler v. American Heavy Lift Shipping, 231 F.3d 242, 249 (6th Cir. 2000) (Where amendment

"amplifies," clarifies, adds, or specifies facts, if not "entirely different 'operative facts, ", the
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preceding standards are controlling.)

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Application of the above principles strongly supports granting leave to amend. Because
purposeful delay and procedural "fencing" and "gamesmanship" are absent, dilatory motive and
bad faith are nonexistent. Indeed the proposed Second Amended Complaint relates closely to the

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Original and First Amended Complaint and merely amplifies, clarifies, adds, and specific facts

that support the claims that have previously been plead; it also reasserts claims against Mayor

Kwame Kilpatrick and his former Chief of Staff Christine Beatty, who were named as
Defendants in the original complaint, for their role in retaliating against those that investigated

the allegations that related to wrongdoing that may involved Ms. Greene. In light of the recent

verdict by a Wayne County jury finding that Brown and N elthrope were retaliated against for
their investigation of events that may have involved Ms. Greene, it is especially important to

include them in this action in order to grant complete relief to the Plaintiff.

Prejudice is also nonexistent in this action. The Rule 26(f) conference has not even been
held as of the date of

this motion, and is currently scheduled for the first week in January, 2008.

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One of the issues to be addressed at the conference is the need for additional amendments to the
pleadings and the amount of discovery that remains to be done. There is much discovery that

remains to be done, as to date, none of the parties have exchanged discovery or conducted

depositions in this matter. Indeed, to avoid prejudice to the Defendants, it would be to
everyone's advantage should the court grant this motion at the start of

this discovery process.

Futility is also absent from this situation as the proposed Second Amended Complaint
adheres to this court's Order of August 31, 2006, which required Plaintiffs amended complaint

to include allegations which, if proven, would establish the unavailability of an effective and

meaningful state-court remedy. The Second Amended Complaint outlines in great detail the
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unavailability of any effective or meaningful state-court remedy. Further, as required by the
court's August 31, 2006 order, the Second Amended Complaint identifies relief that is

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recoverable here but is not otherwise available in some other suit that may yet be brought; it
specifically states that as a result of the Defendant's actions, individually or in concert or
conspiracy with one another; any state court action became time-barred and that the claims

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alleged in the Second Amended Complaint are the only remaining vehicle Plaintiff has to
vindicate his trampled on civil rights.

WHEREFORE, PLAINTIFF respectfully requests this Court to grant his motion and
permit him to fie and serve his Second Amended Complaint.
Respectfully Submitted,

Dated: December 19, 2007

Isl Robert S. Zawideh
Norman Yatooma & Associates, P. C. By: Norman A. Yatooma (P54746) By: Robert S. Zawideh (P43787) Attorneys for Plaintiff 219 Elm Street Birmingham, Michigan 48009

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[phone]
zawideh(£normanyatooma. com

CERTIFICA TE OF SERVICE
I certify that I caused a true and correct copy of:

Plaintiffs Motion For Leave to File Second Amended Complaint, Brief in Support of
Motion, Exhibits, List of

Exhibits, and this Certificate of Service to be served upon::

City of Detroit Law Department
By: John A. Schapka (P3673 1)

Attorneys for Defendants 1650 First National Building Detroit, Michigan 48226 [phone]
schaj (£law. ci. detroit.

mi. us

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by ECF fiing on December 19, 2007.
Isl Rvan D. Bobel Norman Yatooma & Associates, P. C. By: Norman A. Yatooma (P54746) By: Robert S. Zawideh (P43787)

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Attorneys for Plaintiff 219 Elm Street Birmingham, Michigan 48009 [phone]
bobel(£normanyatooma. com

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