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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO
ALWIN CAMACHO-MORALES
Plaintiff
v. HÉCTOR PESQUERA; EMILIO DÍAZ COLON; JOSÉ FIGUEROA SANCHA; JOSÉ LUIS RIVERA DÍAZ; COL. LEOVIGILDO VÁZQUEZ; COL. REYNALDO BERMÚDEZ; 1LT. JOSÉ RIVERA ALICEA; 2LT. DIGNO CARTAGENA; YADIRA RIVERA PABÓN; GUILLERMO SOMOZA COLOMBANI; ALL IN THEIR PERSONAL AND OFFICIAL CAPACITIES; COMMONWEALTH OF PUERTO RICO; INSURANCE COMPANY ABC, JOHN DOE, RICHARD ROE, AND DAVID DOE,
Defendants
Civil No. _________(___)
Civil Rights Violations
Jury Trial Requested
VERIFIED COMPLAINT
TO THE HONORABLE COURT: COMES NOW the Plaintiff ALWIN CAMACHO-MORALES (or the
“Plaintiff”), through the undersigned attorney, and respectfully states, alleges
and prays as follows:
I. JURISDICTION
I.1. Jurisdiction is invoked under 42 U.S.C. Section 1983. This civil
action arises under the First and Fourteenth Amendment of the U.S.
Constitution and laws of the United States of America.
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I.2. Supplemental jurisdiction is invoked under 28 U.S.C. sec. 1367 for
the cause of action invoked under the Constitution and laws of the
Commonwealth of Puerto Rico.
I.3. Venue is appropriate in this Court pursuant to 28 U.S.C. sec.
1391, as this action is brought in the judicial district in which the unlawful
actions against Plaintiff occurred.
II. THE PARTIES
II.1. The Plaintiff, Alwin Camacho-Morales, is a United States citizen,
resident of the State of Florida and was a public-career employee until July 11,
2011, working at the Puerto Rico Police Department (“PRPD”) as an agent.
II.2. Co-defendant Commonwealth of Puerto Rico is a duly constituted
governmental entity with the authority to be sued. The Commonwealth is at
present, or has been at times relevant, the employer of Plaintiff and all
Defendants. It is sued only for declaratory, injunctive and back-front pay-
monetary relief.
II.3. Co-defendant Guillermo Somoza is the current Secretary of Justice
(Puerto Rico’s Attorney General) and direct supervisor of the Puerto Rico Police
Chief. He is sued in his individual and official capacities for declaratory,
injunctive and back-front pay-monetary relief.
II.4. Co-defendant Héctor Pesquera is the current Puerto Rico Police
Chief. He is sued in his individual and official capacities for declaratory,
injunctive and back-front pay-monetary relief.
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II.5. Co-defendant Emilio Díaz Colón, was the Puerto Rico Police Chief
until March 29, 2012. He is sued in his individual and official capacities for
declaratory, injunctive and back-front pay-monetary relief.
II.6. Co-defendant José Figueroa Sancha was the Puerto Rico Police
Chief and Deputy Special Agent-in-Charge of the FBI San Juan Field Office. He
had personal knowledge of the facts that are base for the present complaint.
Furthermore, he has personal knowledge of the undercover labor performed by
Plaintiff before being appointed PRPD Chief because he was the second in
command of the local FBI office. He is sued in his individual and official
capacities for declaratory, injunctive and back-front pay-monetary relief.
II.7. Co-defendant José Luis Rivera Díaz, is the current Associated
Chief serving as the second in command of the Police Department. Has serves
as interim chief on two occasions. He has personal knowledge of the facts that
are the base for the present complaint. He is sued in his individual and official
capacities for declaratory, injunctive and back-front pay-monetary relief.
II.8. Co-Defendant Leovigildo Vázquez is the current Chief of Field
Operation for the PRPD. He has personal knowledge of the facts that are the
base for the present complaint. He holds the rank of Colonel, which is the
highest rank an officer can achieve. He is sued in his individual and official
capacities for declaratory, injunctive and back-front pay-monetary relief.
II.9. Co-Defendant Reinaldo Bermúdez is the current Chief of Strategies
Operations for the PRPD. He has personal knowledge of the facts that are the
base for the present complaint. He holds the rank of Colonel, which is the
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highest rank an officer can achieve. He is sued in his individual and official
capacities for declaratory, injunctive and back-front pay-monetary relief.
II.10. José Rivera Alicea is the current Director of the Strategic
Operations Division. He has personal knowledge of the facts that are the base
for the present complaint. He holds the rank of First Lieutenant, which is a
supervisory/management position. He is sued in his individual and official
capacities for declaratory, injunctive and back-front pay-monetary relief.
II.11. Co-Defendant Digno Cartagena is the FBI Task Force coordinator,
who serves as a liaison officer between the PRPD and the FBI. He has personal
knowledge of the facts that are the base for the present complaint. He holds the
rank of Second Lieutenant, which is a supervisory/management position. He is
sued in his individual and official capacities for declaratory, injunctive and
back-front pay-monetary relief.
II.12. Co-Defendant Yadira Rivera Pabón is a civilian employed by the
Puerto Rico Police Department as the Director of Human Resources. She is
sued in his individual and official capacities for declaratory, injunctive and
back-front pay-monetary relief.
II.13. Co-Defendant Insurance Company ABC has a policy in favor of the
Commonwealth of Puerto Rico, which covers claim contingencies such as that
posed by the instant case.
II.14. Co-Defendants John Doe, Richard Roe, and David Doe are
unidentified defendants that could be substituted during discovery proceedings
pursuant to the Federal Rules of Civil Procedure.
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III. PLEADINGS
III.1. This is a civil action filed by Alwin Camacho-Morales, a former
career employee of the Commonwealth of Puerto Rico working at the Puerto
Rico Police Department (“PRPD”) as an agent, alleging that following his work
as undercover agent under the supervision of the Federal Bureau of
Investigation (“FBI”) during “Operation Guard Shack” (or “OGS”) where dozens
of police officers were arrested on corruption charges, he was fired under
retaliation for his denouncements of matters of public concern.
III.2. Plaintiff commenced his service in the PRPD on June 26, 1996.
III.3. During the years as a law enforcement officer Plaintiff has held
various positions including work as an undercover agent and as a member of
the Tactical Operations Unit where he served at the Puerto Rico Telephone
Company (“PRTC”) and Vieques’ protests.
III.4. In sum, Plaintiff has had an exemplary career serving wherever he
was needed for more than fifteen years.
III.5. During the spring of 2008, an agent from the Puerto Rico Special
Investigations Bureau (“Negociado Especial de Investigaciones” in Spanish;
hereinafter “SIB”) visited Plaintiff at the CompUSA store in Guaynabo where
Plaintiff worked part-time as a Loss-Prevention Manager.
III.6. The SIB agent asked Plaintiff if he knew about illegal activities
taken by fellow police officers at the PRPD.
III.7. The SIB agent added that an investigation was underway and
asked Plaintiff if he was interested to work undercover as a “corrupt” officer.
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III.8. During that meeting, the SIB agent was accompanied by another
officer, who Plaintiff later learned that was FBI Special Agent Norman
Quilichini.
III.9. At that moment Plaintiff did not provide an answer. It was not
until a few days later that Plaintiff accepted.
III.10. Plaintiff was brief on the activities to be performed, which were
relating to corruption investigation within the PRPD.
III.11. Within days Plaintiff commenced his undercover work posing as a
corrupt official offering fellow cops large sums money on behalf of local drug-
traffickers in exchange for transporting the drug to another location within the
island of Puerto Rico.
III.12. For the following two years Plaintiff was virtually living a double
life. Working his regular 8-hour shift as a police officer and his part-time job at
CompUSA, in addition to his undercover work, which could easily take him an
additional 8 to 10 hours a day, plus weekends.
III.13. As a result, for eighteen months Plaintiff performed dozens of
undercover drug transactions with active police officers.
III.14. All the transactions were recorded and conducted under the
supervision of FBI agents. The evidence obtained as product of his undercover
labor was determinant for a magistrate to issue more than one hundred arrest-
warrants.
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III.15. Consequently, on October 9, 2010 the FBI executed the arrests
warrants during what it called Operation Guard Shack, the biggest anti-
corruption operation in the Bureau’s history.
III.16. Plaintiff later learned that the very next day he was
administratively transferred from the Bayamón Precinct to the Police Academy
in Gurabo, for no apparent reason, but for retaliation of Plaintiff’s
denouncements as a special undercover agent, which involved a great matter of
public concern.
III.17. This transfer was done in a continuous retaliation against Plaintiff
and as a mitigation mechanism in order to avoid Plaintiff to expose more
corrupt officer from Bayamón. In sum, the PRPD and Defendants in order to
cover the corruption in progress, retaliated against Plaintiff by his
denouncements of matters of public concern.
III.18. On a press conference the next day, the Puerto Rico Police Chief
Co-Defendant José Figueroa-Sancha, publicly declared that he had knowledge
of the investigation, since it started two years earlier when he was serving as
the Deputy Special Agent-in-Charge at the FBI San Juan Field Office. He
added that he knew about the work being done by Plaintiff and the other
undercover agents.
III.19. Furthermore, in that same press conference held at the Fortaleza
Governor Luis Fortuño stated that he was also being kept informed of the
developments of the investigation.
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III.20. The Governor emphatically indicated that the PRPD officers who
conducted the undercover work are real heroes, acknowledging that it was
them who deserved the biggest credit and gratitude.
III.21. For security reasons days before the arrests were made the FBI
Special Agent responsible for supervising the undercover activities ordered
Plaintiff and his family to a hotel at an undisclosed location.
III.22. Plaintiff and his family remained in such location for a period of
seven weeks.
III.23. Due to Plaintiff sudden disappearance, he was fired from
CompUSA, he later had to explain the situation to the general manager and
after a tumultuous process he has re-hired.
III.24. Upon returning to Puerto Rico, Plaintiff was ordered by the FBI no
to stay at his house because there were confirmed death threats against him
and his family.
III.25. Consequently, he moved to his mother’s house because he had no
other place to go. Thus, endangering his mother and brother’s lives.
III.26. In April, 2011 Plaintiff in a clear retaliation by his denouncements
of great public concern that led to corruption indictments in United States
District Court for the District of Puerto Rico, he was assigned by Defendants
to the PRPD General Headquarter (“HQ”) on Roosevelt Avenue in Hato Rey.
III.27. Although Plaintiff begged Lieutenant Digno Cartagena and Special
Agent Norman Quilichini to intervene in order for him not to be assigned to
HQ, due to the fact that there were officers that were recorded as part of the
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undercover work but were not charged, and therefore they knew about
Plaintiff’s identity and undercover work, Defendants in retaliation ordered his
transfer to Hato Rey.
III.28. Furthermore, on February 14, 2011, FBI-SAIC Luis Fraticelli sent
a letter to PRPD Chief Figueroa-Sancha requesting Plaintiff and two other
agents to be transfer permanently the Joint Operations Division, which works
as part of a Task-Force with the FBI and other federal law enforcement
agencies. Nevertheless, the Plaintiff was ordered to report to the PRPD HQ.
III.29. Instead of being recognized and received as a hero, Plaintiff
obtained nothing but insulting and disrespectful actions from his superiors,
Co-Defendants José Luis Rivera Díaz, Col. Leovigildo Vázquez, Col. Reynaldo
Bermúdez, 1Lt. José Rivera Alicea, 2Lt. Digno Cartagena, as well as from
various high-ranking officers.
III.30. The insults and derogatory comments in retaliation by Co-
Defendants José Luis Rivera Díaz, Col. Leovigildo Vázquez, Col. Reynaldo
Bermúdez, 1Lt. José Rivera Alicea, 2Lt. Digno Cartagena, created a severe
hostile environment for Plaintiff to the point that he did not feel welcomed at
his place of work.
III.31. Plaintiff received information from his former FBI contact agent
concerning confirmed threats against him and his family.
III.32. Consequently, Plaintiff proceeded to meet with Captain Rivera to
inform this serious situation and to obtain approval for more drastic security
measures.
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III.33. On May 12, 2011 two other PRPD agents who also worked
undercover in Operation Guard Shack denounced their situation on a radio
talk show hosted by Carlos Díaz Olivo and Luis Pabón Roca broadcasted by
WKAQ 580 AM. Due to these denouncements, the general public knew about
matters of public concern that involved high-ranking officials and regular
officials in corruption within the PRPD, situation that was denounced by
Plaintiff who was subjected to systematic retaliation that led to his dismissal.
III.34. The next day Co-Defendant José Figueroa-Sancha who at the time
was the PRPD Chief admitted to El Vocero newspaper that there had been
administrative failures on behalf of the PRPD.
III.35. The article added that upon listening to the allegation on radio
Figueroa-Sancha met with Co-Defendants Digno Cartagena and Reinaldo
Bermúdez to order them to take the necessary actions.
III.36. However, no corrective action was taken by them or any other
officer, despite of the fact that all Co-Defendants knew about the critic-
situation. On one occasion, at a meeting with the FBI Deputy SAIC Special
Agent Carlos Cases, Plaintiff was informed that an achievement letter as well as
a recommendation for promotion was personally handed to the PRPD for the
heroic labor. Nevertheless, all Co-Defendants acted in a continuous retaliation
against Plaintiff despite of his heroic labor, which finally led to his dismissal.
III.37. On June 6, 2011, Plaintiff was informed by two FBI Agents (who
are unidentified here for security reasons, and if required by the United States
District Court for the District of Puerto Rico, their names can be disclosed
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under seal) that the arrested officers who were at the Metropolitan Detention
Center in Guaynabo had contacted active duty police officers to request them
to find and kill Plaintiff.
III.38. Then FBI Special Agent X (who is unidentified here for security
reasons, and if required by the United States District Court for the District of
Puerto Rico, their names can be disclosed under seal) called Plaintiff to inform
him that they had recordings of the incarcerated officers stating that they had
knowledge where Plaintiff’s mother lived.
III.39. This situation created a delicate health condition to Plaintiff’s
mother who was already under extreme pressure and nervous state. Not to
mention Plaintiff’s state of mind knowing that they had intention of killing his
mother and brother. All Co-Defendants in retaliation did nothing for the
unexpected and horrible to happen against Plaintiff and his family.
III.40. As a matter of fact, the Co-Defendant Guillermo Somoza
Colombani and Co-Defendant José Figueroa Sancha, as well as the other two
PRPD Superintendents, (Co-Defendants Héctor Pesquera and Emilio Díaz
Colón); are responsible of providing security guards-escort to Plaintiff, and they
refused to do so, placing Plaintiff in life danger in retaliation for his
denouncements of public concern.
III.41. During his appointment at PRPD HQ, Plaintiff was in numerous
occasions told that he would meet personally with the Police Chief, however it
never happened.
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III.42. This exact situation also happened to the other two undercover
agents who participated in Operation Guardian Shack.
III.43. The extreme hostile work environment by continuous retaliation
against Plaintiff by his public concern denouncements, the lack of protection,
and the entire situation in general caused by each Co-Defendant personally,
forced Plaintiff to draft a resignation letter and send it to José Figueroa-
Sancha, the PRPD Chief.
III.44. Plaintiff’s resignation letter was presented on June 8, 2011, and
it’s effective date would be June 28, 2011.
III.45. However, on June 27, 2011 Plaintiff requested his resignation to be
revoked.
III.46. Plaintiff’s revocation request was granted on July 6, 2011 by Co-
Defendant Col. Reinaldo Bermúdez. Thus, Plaintiff’s belief is that he continued
working at the force as to July 6, 2011.
III.47. Surprisingly, although his revocation was granted, Plaintiff was
still removed from the system. Evidence of this is a July 11, 2011 letter signed
by Co-Defendant Lt. Cartagena which states that Co-Defendant Ms. Yadira
Rivera Pabón, Director of Human Resources, proceeded to keep Plaintiff’s
resignation effective retroactively June 28, 2011, because she had not received
an answer from the PRDPD Chief.
III.47. In other words, Co-Defendant Ms. Yadira Rivera Pabón, motu
proprio decided not to grant Plaintiff’s revocation letter (although it was
approved by Co-Defendant Col. Bermúdez), and to make his resignation
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effective retroactively on June 28, 2011 based on the fact that the PRPD Chief
had not signed his resignation letter.
III.48. This seems contradictory, illegal and in clear retaliation to
Plaintiff’s disclosure of matters of public concern, since Co-Defendant Ms.
Yadira Rivera Pabón is a civilian who cannot overturn decisions taken by high-
ranking officers.
III.49. Furthermore, it must be noted that Plaintiff also made an
administrative complaint against Co-Defendant Noel Reyes by his retaliation
actions of cutting Plaintiff’s labor hours by his disclosure of matters of public
concern, reason that also led to the final dismissal of Plaintiff, despite of the
fact that he revoked his previous resignation.
III.50. In addition, Plaintiff was not afforded of his right to a pre-
termination hearing prior to his dismissal by Co-Defendants, despite of the fact
that he was a career employee, in a clear violation to his due process rights
secured by the Fourteenth Amendment of the U.S. Constitution.
III.51. Suffice is to say that the U.S. Department of Justice issued a
Report regarding the PRPD on September 5, 2011, which discloses all the
corruption within said entity, situation that was previously disclosed in part by
the Plaintiff, who was continuously harassed and subjected to systematic
retaliation by each Co-Defendant personally, that led to his dismissal.
III.52. Lastly, but not least, all this situation was personally known by the
current Secretary of Justice, Guillermo Somoza Colombani, who with his
ineptitude, inaction and acting under color of state law, condoned, acquiesced
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and affirmed the retaliatory actions against Plaintiff, by not protecting Plaintiff,
and by his denouncements of matters of public concern, in a clear violation to
Plaintiff’s First Amendment Rights protected speech under federal and state
law.
IV. FIRST CAUSE OF ACTION VIOLATION OF FIRST AMENDMENT (FREE SPEECH)
IV.1. Plaintiff repeats and incorporates all the allegations contained thus
far as if set forth fully herein.
IV.2. The aforementioned evidences that the defendants, under the color
of law of their respective positions, have unconstitutionally violated the
Plaintiff’s right to free speech, in that they seek to punish them for speaking
out against each one of the Co-Defendants. The denouncement is a matter of
great public concern and their prosecution of the ongoing administration
challenged Plaintiff until his resignation, later revoked by himself, and
thereafter in another retaliation he was fired.
IV.3. Plaintiff was unceasingly harassed, stripped of his functions,
subjected to unnecessary, discriminatory and excessive disciplinary
proceedings as well as preclusion from promotions and continued employment
in a clear retaliation of his denouncements of public concern matters, in a clear
violation to his First Amendment Rights.
IV.4. As a result of the Defendants’ unconstitutional and illegal conduct,
Plaintiff has had his constitutional rights violated and this has caused
irreparable and continuing harm, emotionally, economically in the amount of
no less than $3,000,000.00 each. In addition, the Plaintiff prays for
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preliminary and permanent injunctive relief for reinstatement, in the form of
monies lost and any applicable benefits, immediate reinstatement and
prohibiting defendants from taking additional adverse employment actions
because of his public statements.
IV.5. Also, the Defendants act towards Plaintiff warrants the imposition
of punitive damages, the award of attorneys’ fees and costs.
V. SECOND CAUSE OF ACTION VIOLATION TO DUE PROCESS
V.1. Plaintiff repeats and incorporates all the allegations contained thus
far as set forth fully herein.
V.2. Plaintiff was not afforded of his right to a pre-termination hearing
prior to his dismissal by Co-Defendants, despite of the fact that he was a career
employee, in a clear violation to his due process rights secured by the
Fourteenth Amendment of the U.S. Constitution.
V.3. In addition, the Plaintiff prays for preliminary and permanent
injunctive relief for reinstatement, in the form of monies lost and any
applicable benefits, immediate reinstatement and prohibiting defendants from
taking additional adverse employment actions because of his public statements
and by the clear violation of Plaintiff’s due process rights under the Fourteenth
Amendment of the U.S. Constitution.
VI. THIRD CAUSE OF ACTION LAWS OF PUERTO RICO
Protection Against Employer Reprisal, Act No. 115 of December 20, 1991 29 P.R. Laws Ann. §194
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VI.1. Plaintiff repeats and incorporates all the allegations contained thus
far as set forth fully herein.
VI.2. The aforementioned facts demonstrate that each of the Defendants,
as the Plaintiff’s employer and/or supervisors, while under color of law of their
respective positions, have willfully and/or with deliberate indifference violated
the Commonwealth of Puerto Rico’s Statute Law No. 115 of December 20, 1991
known as the Protection Against Employer Reprisal statute, (29 P.R. Laws Ann.
§194)
VI.3. As a result of the Defendants’ free speech First Amendment and
retaliation violation, Plaintiff was discriminated in his employment, and said
actions have caused irreparable and continuing harm, emotionally,
economically and in their civil rights, in the amount of no less than
$1,000,000.00 each. In addition, the Plaintiff prays for preliminary and
permanent injunctive relief prohibiting Defendants from affecting his
employment because of his public expressions against the Defendants illegal
actions.
VI.4. Also, the Defendants act towards the Plaintiff warrants the
imposition of double damages, the award of attorneys’ fees and costs.
VII. THIRD CAUSE OF ACTION LAWS AND CONSTITUTION OF PUERTO RICO
VII.1. Plaintiff repeats and incorporates all the allegations contained thus
far as set forth fully herein. The foregoing evidence that the Defendants, under
color of law of their respective positions, have willfully and/or with deliberate
indifference violated the Plaintiff’s rights under the Constitution and laws of the
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Commonwealth of Puerto Rico, specifically Sections 1, 4, 6 and 7 of Article II of
the Constitution of Puerto Rico; and the Public Service Personnel laws of
Puerto Rico; Act No. 184, of August 3, 2004, as amended, PR Laws Ann. Tit. 3;
and Articles 1802 and 1803 of the Civil Code § 5141 and 5142 of Title 31; and
Law 100 of June 26, 1956.
VII.2. As a result of the Defendants’ unconstitutional and illegal conduct,
Plaintiff has been discriminatorily treated in his employment, and caused
irreparable and continuing harm, emotionally, economically and in his civil
rights, in the amount of no less than $1,000,000.00 each. In addition, Plaintiff
prays for preliminary and permanent injunctive relief prohibiting Defendants
from affecting their employment.
VIII. JURY DEMAND
VIII.1. Trial by Jury is requested in all causes of action.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff respectfully prays that the Court:
1. Find that the Defendants have violated Plaintiff’s rights under the
First and Fourteenth Amendment of the United States Constitution; as well as
under the laws and Constitution of the Commonwealth of Puerto Rico and
enter declaratory judgment to that effect;
2. Grant preliminary and permanent injunction prohibiting,
restraining and enjoining the Defendants, agents or anyone acting in concert
with them or pursuant to their orders, or their successors in any representative
capacity from violating any Constitutional and statutory rights of the Plaintiff;
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3. Award damages to Plaintiff in an amount no less than
$5,000,000.00 each for pain and suffering and other damages suffered as a
result of the Defendants’ unconstitutional conduct;
4. Award punitive damages to Plaintiff in an amount in such amount
as may be deemed appropriate;
5. Award pre judgment and post judgment interest;
6. Award Plaintiff attorneys’ fees and costs pursuant to 42 U.S.C. §
1988;
7. Grant Plaintiff back and front pay, and/or reinstatement;
8. Award such other and further relief as may be deemed just and
proper.
RESPECTFULLY SUBMITTED.
In San Juan, Puerto Rico, this 2nd day of July, 2012.
NOTICE OF ELECTRONIC FILING
IT IS HEREBY CERTIFIED: That on this date I electronically filed the
foregoing with the Clerk of the Court using the CM/ECF system, which will
send notification of such filing to all attorneys of record.
COUNSEL FOR PLAINTIFF
VALENZUELA-ALVARADO, LLC MCS Plaza 255 Ponce de León Avenue Suite 825 San Juan, Puerto Rico 00917-1942 Tel. (787) 365-9401 Fax: (787) 756-4053 www.va-lex.com
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S/José Enrico Valenzuela-Alvarado
JOSÉ ENRICO VALENZUELA-ALVARADO USDC-PR 220104 E-mails: [email protected] [email protected] [email protected]
STATEMENT UNDER PENALTY OF PERJURY AS PER 18 USCA §1746(2)
I, ALWIN CAMACHO-MORALES, declare under penalty of perjury that I
have examined the Verified Complaint prepared in the instant matter and understand
and attest, to the best of my knowledge, that the same is true and correct as to the
general facts and those particular facts to my case. That I have had the benefit of
having the document translated to me and I am satisfied with the same.
S/Alwin Camacho-Morales
ALWIN CAMACHO-MORALES
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