|
Case 3:16-cv-30186-KAR Document1 Filed 12/06/16 Page 4of 9she was
Case 3:16-cv-30186-KAR Document1 Filed 12/06/16 Page Sof936. Another basketball team staff member, Hogans, was
outside the room by the door. Upon information and
belief, Roe had called Hogans.
37. MBB had no way to extricate herself from the
situation; three large men surrounded her and blocked the
exit.
38. Before this incident, Roe had told about the
use of banned substances by team members; domestic
violence by certain staff members against family members;
incidents of infidelity and quashing of potential
criminal complaints against unidentified team members.
39. After the incident, Kellogg called a meeting of the
entire staff and told them that nothing would be
permitted to get out.
40. At all times pertinent to this complaint, Kellogg was
the head coach of the UMass at Amherst basketball team.
41. At all times pertinent to this complaint, Ree, Chatman
and Hogans were coaching staff members of the UMass at
Amherst basketball team.
COUNT I.
(42 U.S.C. 1983)
42. TER repeats and realleges the averments contained
in paragraphs 1 through 41 as if fully set forth herein.
De
Case 3:16-cv-30186-KAR Documenti Filed 12/06/16 Page Géof943. At all times pertinent to this complaint, Roe,
Chatman, Hogans and Kellogg were acting under color of
State law to deprive 9BMJof her civil rights
guaranteed by the First and Fourth Amendments to the
Constitution of the United States.
44, During the incident of December 7, 2013, Roe, Chatman
and Hogans refused to let MBM out of an of they
to which they had access as members of the coaching staff
of the UMass at Amherst men’s basketball team.
45. The University of Massachusetts is a public university
funded by the Commonwealth and operating under the laws
of the Commonwealth.
46. oe, Chatman and Hogans refused to allow to
leave because they intended to and did prevent her from
disclosing information of public interest concerning the
men’s basketball team, its players and its staff.
47, Kellogg encouraged and pi
icipated in a cover-up of
t concerning
the incident with the intention of preventin:
from disclosing information of public inter:
the men's basketball team, its players and its staff.
48. Roe, Chatman and Hogans pursued their goal of
dissuading BBM from disclosing information about the
5 basketball team by detaining her and her son in an
a
(Case 3:16-cv-30186-KAR Document Filed 12/06/16 Page 7 of 9Case 316-cv-30186-KAR Document Filed 1206/16 Page 7 of 9
office in a public building to which they had access
use under esler of State law.
49. The suppression of speech about info
public
interest and the unlawful detention of MBMMn a
public building by those in control of the premises
deprived i
and Fourth Amendments to the United States Constitution
civil rights guaranteed by the First
violation o
£42 U.S.C. 1983.
50. The actions of the defendants as set forth above in
paragraphs 42 to 49 causedMMMMMgreat fear for herself
and her sony reasonable apprehension that she would be
subjected to another incident of domestic violence
without any way te protect herself: and great trepidation
that the defendants would continue to target her to
prevent her from disclosing inf
ation of great interest
to the public
COUNT IT.
(G.L. ¢. 12, §11H and $111)
$1. BEM repeats and realleges the averments contained
in paragraphs 1 through 41, paragraphs 44 through 48 and
paragraph 50 as if fully set forth herein.
52. The suppression of speech about info:
ion of public
lawful detention of IM in a
public building by those in control of the premises
interest and the u
a
Case 3:16-cv-30186-KAR Document1 Filed 12/06/16 Page B of 9a
Case 216-cv-30186KAR Document Filed 1206/16 Page 8 of 9
deprived BE of
and Fourth Amendwents
the United States Con
nade applicable to the States by bh Amendment
2 Fourteen
of the United States Constitution, and quar:
teed by
Articles 14 and 16 of the Declaration of Rights to the
Constitution of the Commonwealth.
deprived Qo ber right
liberty and her right to £
53. The defenda
speech through ¢
threats, intimidation and coercion all as aforesaid.
pears averments contained
realleges t!
in paragraphs 1 through 41, paragraphs 44
paragraph set forth herein
55. At all times pertine: is complaint, Roe, Chat
ed EE co ene
tognent of ED ves yntew
becuse BEB cnsuccesstunty «
take her son with her when she attempted to leave,
ntentiona!
and Hogans
56. Their eo:
+ especially
mpted to leave and to
57. At all times pertinent to this complaint, SD was
conscious that she was being confined against her will
and despite her protests.
nfinenent injured MMMM as set forth in
paragraph 50, above.
58. The «
LS
Case 316-cv-30186-KAR Document Filed 12/06/16 Page 9 of 9Case 3:16-cv-30186-KAR Document1 Filed 1296/16 Page 9o! 9
wuzrerors, EBD Gemands judgment against
ne defendants,
in such amount as the c
jeems
further asks the court for ther and
rther relief as
the court may deem just.
JURY DEMAND.
HE cecands a tr
triable,