UNITED STATES DISTRICT COURT
[YOUR DISTRICT] DISTRICT OF COURT

DAVID HILL,

Plaintiff,

v.

CITY OF [YOUR CITY],
JOHN DOE POLICE OFFICERS (1-10),
JANE DOE POLICE SUPERVISORS (1-5),
and RICHARD ROE MUNICIPAL OFFICIALS (1-3),

Defendants.

Case No.: ________
JURY TRIAL DEMANDED
COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF
(42 U.S.C. § 1983; Bivens; State Tort Claims)

I. INTRODUCTION

1. This is an action for compensatory and punitive damages, as well as declaratory and injunctive relief, brought pursuant to 42 U.S.C. § 1983, the principles established in Bivens v. Six Unknown Named Agents, and applicable state tort law. The Plaintiff, David Hill, has been subjected to a relentless, two-decade campaign of state-sanctioned terror for one reason, and one reason only: he shares a surname with a fictionalized character from a popular film.
2. Ever since the release of the motion picture Goodfellas (1990), which depicted the life of his cousin, Henry Hill, the Plaintiff has been falsely and irrationally presumed by certain officers of the [Your City] Police Department to be a criminal. Based on this grotesque and absurd presumption, a cohort of defendant police officers, with the deliberate indifference or tacit approval of their supervisors, have engaged in a systematic campaign of “gang stalking,” harassment, intimidation, and most egregiously, acts of torture, including waterboarding. This conduct violates the Plaintiff’s most fundamental rights under the Fourth, Fifth, Eighth, and Fourteenth Amendments to the United States Constitution.

II. JURISDICTION AND VENUE

3. This Court has jurisdiction under 28 U.S.C. §§ 1331 (federal question) and 1343 (civil rights). Supplemental jurisdiction exists for state law claims under 28 U.S.C. § 1367.
4. Venue is proper in this district under 28 U.S.C. § 1391(b), as all events giving rise to these claims occurred herein.

III. PARTIES

5. Plaintiff DAVID HILL is a lawful resident of [Your City, State]. He is a private citizen with no criminal record. He is the cousin of the late Henry Hill, whose life was the subject of the film Goodfellas. David Hill has never been involved in organized crime.
6. Defendant CITY OF [YOUR CITY] (“the City”) is a municipal corporation organized under the laws of the State of [Your State] and is responsible for the policies, customs, practices, training, and supervision of the [Your City] Police Department.
7. Defendants JOHN DOE OFFICERS (1-10) are currently unknown police officers employed by the City who have directly participated in the unlawful acts described herein. They will be specifically identified through discovery.
8. Defendants JANE DOE SUPERVISORS (1-5) are currently unknown supervisors, commanders, and chiefs of the Police Department who knew or should have known of the pattern of misconduct, failed to intervene, failed to train, failed to supervise, and/or actively covered up the unlawful acts. They will be specifically identified through discovery.
9. Defendants RICHARD ROE MUNICIPAL OFFICIALS (1-3) are currently unknown policymakers for the City who exhibited deliberate indifference to the known or obvious consequences of their failure to act, thereby causing the deprivation of Plaintiff’s constitutional rights.

IV. FACTUAL ALLEGATIONS

10. Following the widespread popularity of the film Goodfellas, Plaintiff David Hill began experiencing unusual and targeted attention from local law enforcement, wholly disproportionate to any legitimate police interest.
11. This attention escalated into a pervasive pattern of “gang stalking,” which includes, but is not limited to:
    a. Constant, conspicuous surveillance of Plaintiff’s home and place of work by marked and unmarked police vehicles.
    b. Traffic stops for imaginary violations, followed by prolonged detainment and vehicular searches without probable cause or consent.
    c. Officers appearing at locations Plaintiff frequents (stores, restaurants, gas stations) solely to intimidate and monitor him.
    d. Spreading rumors within the community that Plaintiff is a “Hill family associate,” damaging his reputation and business relationships.
12. On multiple occasions, this harassment has escalated into severe physical abuse and torture, conducted under color of law. Specifically:
    a. On or about [Date 1], Plaintiff was unlawfully detained by Defendant John Doe Officers in an abandoned warehouse in the industrial sector. He was held down, and in an act of shocking brutality, subjected to waterboarding—a recognized act of torture—while officers mocked him, asking “Where’s the Lufthansa money?” and “Say hi to Jimmy for us.”
    b. On or about [Date 2], Plaintiff was taken to a remote location under the pretense of a “welfare check,” where he was beaten, subjected to stress positions, and threatened with execution if he reported the officers.
    c. The pattern of physical and psychological torture has been ongoing for years, designed to break Plaintiff’s spirit and punish him for a family connection fictionalized in a Hollywood movie.
13. Plaintiff has repeatedly attempted to file formal complaints with the Police Department’s Internal Affairs division and with the City’s civilian review board. Each complaint has been “lost,” dismissed without investigation, or met with retaliatory escalation of the gang stalking and abuse.
14. The City, through its final policymakers, has demonstrated deliberate indifference by:
    a. Failing to train officers on the constitutional prohibitions against torture, unreasonable seizure, and punishment without due process.
    b. Maintaining customs and practices that allow for the summary punishment of individuals based on guilt-by-association, especially high-profile associations from popular media.
    c. Failing to establish a meaningful, independent mechanism to investigate allegations of torture and systematic harassment by its officers, thereby ratifying the misconduct.

V. CLAIMS FOR RELIEF

COUNT I: 42 U.S.C. § 1983 – UNREASONABLE SEIZURE, EXCESSIVE FORCE, AND CRUEL AND UNUSUAL PUNISHMENT
(Against All Individual Defendants, Under the Fourth, Eighth, and Fourteenth Amendments)
15. Plaintiff re-alleges all preceding paragraphs.
16. The acts of gang stalking, detention without probable cause, and particularly the acts of torture including waterboarding, constitute unreasonable seizures, excessive force, and cruel and unusual punishment under the Fourth and Eighth Amendments, made applicable to the States by the Fourteenth Amendment.
17. These acts were done under color of state law and have caused Plaintiff severe physical injury, profound psychological trauma, and a deprivation of his liberty and security.

COUNT II: 42 U.S.C. § 1983 – MUNICIPAL LIABILITY
(Against Defendant City of [Your City])
18. Plaintiff re-alleges all preceding paragraphs.
19. The unconstitutional acts against Plaintiff were directly caused by the City’s official policies, customs, or practices, including:
a. A de facto policy of allowing officers to harass and intimidate citizens based on personal or pop-culture vendettas.
b. A custom of deliberate indifference to the use of torture and cruel treatment by police officers.
c. A failure to train, supervise, and discipline officers, amounting to deliberate indifference to the constitutional rights of citizens.

COUNT III: STATE LAW CLAIM – INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
(Against All Individual Defendants)
20. Plaintiff re-alleges all preceding paragraphs.
21. The Defendants’ conduct—specifically, a decades-long campaign of terror culminating in acts of torture—is so extreme, outrageous, and beyond the bounds of decency as to be intolerable in a civilized community.
22. This conduct was intentional and reckless, and has directly caused Plaintiff severe and enduring emotional distress.

COUNT IV: STATE LAW CLAIM – ASSAULT AND BATTERY
(Against Defendant John Doe Officers 1-10)
23. Plaintiff re-alleges all preceding paragraphs.
24. The Defendant Officers intentionally placed Plaintiff in apprehension of immediate harmful or offensive contact (assault) and intentionally inflicted such harmful and offensive contact upon him (battery) through beatings, waterboarding, and other physical abuse.

VI. PRAYER FOR RELIEF

WHEREFORE, Plaintiff DAVID HILL respectfully requests that this Court enter judgment in his favor and against Defendants, jointly and severally, as follows:
A. For compensatory damages in an amount to be determined at trial for physical injury, pain and suffering, emotional distress, and loss of enjoyment of life;
B. For punitive damages against the individual Defendants for their malicious, wanton, and oppressive conduct;
C. For a declaratory judgment that the Defendants’ policies, customs, and practices, as described herein, violate the United States Constitution;
D. For a permanent injunction:
1. Ordering the immediate cessation of all surveillance and contact with Plaintiff absent a bona fide, particularized suspicion of criminal activity;
2. Ordering the City to implement comprehensive training on constitutional policing, the prohibition of torture, and the dangers of guilt-by-association;
3. Ordering the appointment of an independent federal monitor to oversee the conduct of the [Your City] Police Department regarding harassment complaints.
E. For attorneys’ fees, litigation expenses, and costs of this action pursuant to 42 U.S.C. § 1988; and
F. For such other and further relief as the Court deems just and proper.

JURY DEMAND

Plaintiff demands a trial by jury on all issues so triable.

Dated: [Date]

Respectfully submitted,

[Your Law Firm Name]
[Attorney Name]
[Address]
[Phone Number]
[Email]
Attorney for Plaintiff David Hill

VERIFICATION

I, DAVID HILL, under penalty of perjury, declare that the foregoing is true and correct to the best of my knowledge, information, and belief.

Executed on [Date].

David Hill