UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION CHRISTOPHER J. SQUITIERI, JOHN HORNING AND ANTHONY PEARN, Plaintits, SSeS ve Case No. PASCO COUNTY SHERIFF, CHRISTOPHER NOCCO; COLONEL JEFFERY HARRINGTON; MAJOR JEFFERY PEAKE, MAJOR CRIMES UNIT; LARRY KRAUS, DIRECTOR OF INTELLIGENCE LEAD POLICING UNIT; MAJOR KENNETH GREGORY, MAJOR OF PATROL OPERATIONS; CAPTAIN SHARON FOSHEY, DIRECTOR OF PASCO HERNANDO POLICE ACADEMY; SERGEANT JAMES BROWNING; ‘SERGEANT RICHARD JONES; ‘SERGEANT MARC ERICKSON; CORPORAL JENNIE JONES, COORDINATOR OF PASCO HERNANDO POLICE ACADEMY; INSPECTOR JENNIFER CHRISTENSEN; HUMAN RESOURCES DIRECTOR TAFFINI REED; INVESTIGATOR TIMOTHY ROY; HUMAN RESOURCES MANAGER MELISSA HITE; HUMAN RESOURCES SPECAILEST CHRISTOPHER BENNETT; Defendants. EE EERE Eeeeeeeeeeeeeeeeeeeee eee COMPLAINT AND DEMAND FOR JURY TRIAL Plaintiffs, CHRISTOPHER J. SQUITIERI (hereinafter “SQUITIERI”), ANTHONY PEARN (hereinafter “PEARN”) and JOHN HORNING (hereinafter “HORNING”), by and through their undersigned attorney, files this Complaint and Demand for Jury Trial, individually and on behalf of a class, bringing this action against Defendants, PASCO COUNTY SHERIFF, CHRISTOPHER NOCCO (hereinafter “NOCCO"}; Colonel JEFFERY HARRINGTON (hereinafter “HARRINGTON”); Major JEFF PEAKE (hereinafter “PEAKE”, Major of crimes unit; LARRY KRAUS (hereinafter Page 1 of 68“KRAUSE"), Director of Intelligence Lead Policing Unit; Major KENNETH GREGORY (hereinafter “GREGORY”, Major of patrol operations; Captain SHARON FOSHEY (hereinafter “FOSHEY”), Director of Pasco Hernando Police Academy; Sergeant JAMES BROWNING (hereinafter BROWNING”); Sergeant RICHARD JONES (hereinafter “ SGT. JONES”); Sergeant MARC ERICKSON (hereinafter “ERICKSON”); Corporal JENNIE JONES {hereinafter “CORP. JONES”), Coordinator of Pasco Hernando Police Academy; Inspector JENNIFER CHRISTENSEN (hereinafter “CHRISTENSON"); Human Resources Director TAFFINI REED (hereinafter “REED”); Investigator TIMOTHY ROY (hereinafter “ROY”); Human Resources Manager MELISSA HITE (hereinafter Human Resources Specialist CHRISTOPHER BENNETT (hereinafter “BENNETT”); and alleges upon facts and belief as follows: 1, SUMMARY OF CLAIMS This is a civil RICO claim which requires Plaintiffs to demonstrate that the defendant has engaged in a “pattern” of misconduct (called “racketeering” under the RICO statutes). “Pattern of racketeering activity” requires at least two acts of racketeering activity committed within ten years of each other. The civil ac defined in 18 U.S.C.A. § 1964 (c}: “Any person injured in his business or property by reason of a violation of section 1962 of this chapter may . .. recover threefold the damages he sustains and the cost of the suit, including a reasonable attorney's, fee ....” Section 1962 has four subparts and generally prohibits the use of income obtained from a pattern of racketeering activity or through collection of an unlawful debt to purchase, establish, operate, or participate in the affairs of any enterprise in interstate or foreign Page 2 of 68commerce. Florida’s RICO Act mirrors the federal RICO Act. To be convicted for a violation of the state RICO Act, the defendant must have been arrested because he or she was associated with an enterprise, he or she directly or indirectly was part of the enterprise as evidenced by participating in a minimum of two acts of racketeering activity and at least two of the acts of racketeering activities had commonalities. Potential commonalities include the same or similar victims, co-conspirators, methods of commission, intent, results or other characteristics that established 2 pattern. In this particular case, there are three (3) Plaintiffs and five (5) confidential informants, all of whom civil violations that constitute civil RICO claims against the defendants. The plaintiffs’ individual experiences of intimidation, coercion, extortion and other unethical behavior by their supervisors at the Pasco Sheriff's Department well documented in the body of the Complaint. The five confidential informants provide supporting evidence of the patterns of abuse of power, intimidation, and coercion to perform unethical activities at the behest of superiors that are similar to the narratives of the three Plaintiffs. Taken together, the Plaintiffs and confidential informants provide a picture of the Pasco Sheriff’s Department that is criminal, unethical, and a criminal enterprise. This pattern of behavior reflects an attitude on the part of the Defendant's that they as law enforcement officers are above the law and immune from scrutiny or the most innocuous criticism. The Plaintiffs and confidential informants demonstrate what life is like when anyone decides to. contradict or simply not follow the edicts of the highest officials within the Pasco Sheriff's Page 3 of 68