CITY OF NEW YORK, DANIEL PANTALEO, Individually, JOSEPH TORRES, Individually, IGNAZIO CONCA, Individually, STEVEN LOPEZ, Individually, CHRISTIAN CATALDO, Individually, and JOHN and

UNITED STATES DISTRICT COURTEASTERN DISTRICT OF NEW YORK

DARREN COLLINS and TOMMY RICE,

against-

-X

Plaintiffs,

CITY OF NEW YORK, DANIEL PANTALEO, Individually,JOSEPH TORRES, Individually, IGNAZIO CONCA, Individually,STEVEN LOPEZ, Individually, CHRISTIAN CATALDO,Individually, and JOHN and JANE DOE 1 throughlO, Individually,(the names John and Jane Doe being fictitious, as the true names arepresently unknown),

Defendants.

-X

AMENDEDCOMPLAINT

13 CV 3534(ENV) (JO)

Jury Trial Demanded

Plaintiffs DARREN COLLINS and TOMMY RICE, by their attorneys, Leventhal &

Klein, LLP, complaining of the defendants, respectfully allege as follows:

Preliminary Statement

1. Plaintiffs bring this action for compensatory damages, punitive damages and

attorneys' fees pursuant to 42 U.S.C. 1983 and 1988 for violations of their civil rights, as saidrights are secured by said statutes and the Constitution of the United. Plaintiffs also assert

supplemental state law claims.

JURISDICTION

2. This action is brought pursuant to 42 U.S.C. 1981, 1983 and 1988, the Fourthand Fourteenth Amendments to the United States Constitution. Plaintiffs assert supplemental

state law claims pursuant to common law and the New York State Constitution.

Case 1:13-cv-03534-ENV-JO Document 16 Filed 11/04/13 Page 1 of 25 PageID #: 68

CITY OF NEW YORK, DANIEL PANTALEO, Individually, JOSEPH TORRES, Individually, IGNAZIO CONCA, Individually, STEVEN LOPEZ, Individually, CHRISTIAN CATALDO, Individually, and JOHN and

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