Ruff v City of Philadelphia - Complaint

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

BRANDON RUFF Plaintiff

vs. THE CITY OF PHILADELPHIA, PHILADELPHIA POLICE OFFICER LONG, BADGE# UNKNOWN POLICE SERGEANT DOE, BADGE# UNKNOWN, PHILADELPHIA POLICE OFFICERS DOES 1-5, BADGE #'S UNKNOWN, individually and as police officers for the City of Philadelphia

Defendants

COMPLAINT

I. JURISDICTION

JURY TRIAL DEMAND

C.A. N0.14-

14 4940

1. This action is brought pursuant to 42 U.S.C. 1331and1343(1),(3),(4) and

the aforementioned statutory provision.

II. PARTIES

2. Plaintiff, Brandon is an adult male who was at all times relevant to its

Complaint, a resident of Philadelphia, Pennsylvania. Mr. Ruff is and was at the time of

the incident, employed as a police officer at the rank of Sergeant for the City of

Philadelphia.

3. Defendant City of Philadelphia is a City of the First Class in the Commonwealth

of Pennsylvania and at all times relevant hereto operated under the color of state law in

creating and maintaining a Police Department, was the employer of all Defendants and

had the responsibility of adopting policies, implementing procedures and practices which

would create an environment whereby citizens would be safe from police abuse.

Case 2:14-cv-04940-TJS Document 1 Filed 08/25/14 Page 1 of 16

4. Defendant Sergeant Doe, Badge number unknown, is and was at all times

relevant to this Complaint, a police officer for Philadelphia Police department and acting

under the color of state law. She is being sued in both her individual and official

capacities.

5. Defendant Philadelphia Police Officer Long, Badge number unknown, is and

was at all times relevant to this Complaint, a police officer for Philadelphia Police

department and acting under the color of state law. She is being sued in both her

individual and official capacities.

6. Defendants Doe 1-5, Badge numbers unknown, are and were at all times relevant

to this Complaint, police officers for Philadelphia Police department and acting under the

color of state law. They are being sued in both their individual and official capacities.

III. FACTS

7. On August 3, 2014 at 6:30 p.m. Plaintiff Sergeant Brandon Ruff, a Philadelphia

Police Officer since 2006 was contacted by a friend who stated that he wanted to tum in

some firearms that he obtained via buying them from individuals in the neighborhood in a

proactive attempt to stop violence. The Plaintiffs friend informed the Plaintiff that he

was creating an organization for that purpose.

8. Plaintiff met with his friend and was handed a bag with three (3) firearms in it

from the rear passenger compartment floor area of his friend's vehicle.

9. At the scene Plaintiff checked the surrendered firearms to make sure there was

no ammunition in the firearms.

10. Plaintiff then drove to the 35th Police District to turn in the firearms.

11. While waiting in the lobby of the 35th District, Defendant Philadelphia Police


Officer Long approached the window and asked how she could help Plaintiff. Plaintiff

responded by informing the Defendant that he was there to ''turn some firearms in".

12. Defendant Long began asking questions about whom the owner of the firearms

was and who the Plaintiff got the firearms from.

13. Plaintiff informed Defendant Long that he obtained the firearms from his friend

to turn in under the "no questions asked" policy initiated by the Defendants.

14. Defendant Long began berating Plaintiff and Plaintiff requested the presence of

a supervisor.

15. Defendant Long slammed the window shut and walked back towards the desk.

No supervisor came out.

16. Another police officer standing there, Defendant Doe # 1 asked Plaintiff where

the firearms were and Plaintiff handed her the bag and told her that the firearms were

already checked for ammunition. Defendant Doe # 1 grabbed the bag and placed it on the

counter and began asking Plaintiff questions about where Plaintiff obtained the firearms.

Plaintiff informed Defendant Doe # 1 of the identity of the person he got the firearms

from. Defendant Doe# 1 demanded to see Plaintiffs I.D. Plaintiff informed her that he

did not have a state l.D. on him but had his work l.D instead.

17. At that time, Plaintiff informed a female police officer who was also standing

there that he had to make a phone call outside because he did not have service inside the

building. Plaintiff then went outside to make the call when suddenly someone shouted

"there he is" and then a voice shout "35 TOM".

18. Defendant Doe # 2 then came from behind Plaintiff and grabbed his right hand

placing Plaintiff's hands behind his back.


19. At this time, approximately 5-7 police officers confronted Plaintiff shouting at

him as Defendant Doe# 2 had him in custody. Plaintiff informed the officers that he was

a 3-6-9 (code for police officer) and that his 1.D. was in his pocket.

20. Defendant Doe# 3 who was standing in front of Plaintiff shouted, "I'll f**king

taze you". Plaintiff told these officers that he had already provided the identity of the

person who gave him the firearms.

21. The police officers continued to shout at Plaintiff while Defendant Doe # 3

placed another Taser against Plaintiffs chest while another officer, Defendant Doe# 4

pressed a Taser against Plaintiffs right rib cage.

22. Plaintiff was then patted down and searched.

23. Upon spotting Plaintiffs registered off duty weapon in a holster on his hip;

Defendant Sergeant Doe stated "Is that a gun on your hip". Plaintiff replied that it was

and Defendant Sergeant Doe stated "why the hell would you come into a police station

with a gun on your hip, where is your permit to carry". Plaintiff informed the Defendant

Sergeant that his l.D. identifying him as a police officer was his permit to carry.

24. Defendants then confiscated Plaintiffs firearm and escorted him to the roll call

room behind the locked door in the lobby.

25. Once inside this room, an officer told him to sit down whereby Plaintiff told

Defendant Doe# 5 "No, I'm upset I don't want to sit down". Defendant Doe# 5 then

began kicking at the back of Plaintiffs legs in an attempt to sweep his legs to make him

fall onto the ground. Plaintiff then sat down.

26. Just prior to sitting down, Defendant Sergeant Doe ordered officers to again

search the Plaintiff. Plaintiff asked why he was being search and asked if he was being


arrested. Defendant Sergeant Doe informed Plaintiff that he was under arrest and being

"locked up for VUF A".

27. Plaintiff was searched and his Municipal Police Officer Education and Training

Commission card and Philadelphia Police l.D. was taken out of his pocket.

28. The officer then handed the l.D.s to Defendant Sergeant Doe and she shouted

"you are a piece off**king sh*t, you are scum, and you are a supervisor. You are a

disgrace to me, this department and the 35th District. You do not belong on this job".

Defendant Sergeant Doe left, came back into the room moments later and threw

Plaintiffs IDs across the room at him along with his cell phone.

29. Defendant Sergeant Doe then informed the Lieutenant on duty that she was

calling Internal Affairs and Night Command because something "has to be done about

this". The time was about 6:45 p.m.

30. Plaintiff contacted his own Lieutenant and informed him of the incident along

with a brief text to his Captain.

31. Plaintiff sat in this room for almost an hour and was then told that Internal

Affairs was sending a team out to investigate. After more than three (3) hours, a

Lieutenant from Internal Affairs came into the room and asked Plaintiff his name and

date of birth. He then left.

32. Plaintiff remained in the room unable to leave for several more hours and at

12:15 a.m., Plaintiff began feeling very weak and ill so he informed an officer in the

room of his condition and requested the officer get the Corporal. The officer informed the

Corporal that Plaintiff was feeling ill and his blood sugar was dropping fast. The

Corporal offered to have him transported to the hospital, but Plaintiff declined.


33. At approx. 1 :00 a.m., two (2) Lieutenants came into the room where Plaintiff

was being held along with another officer who had Plaintiffs firearm in his possession.

Plaintiff was told to sign the property receipt to take custody of his firearm and

ammunition. Plaintiff complied. The two Lieutenants then told him that he had the right

to remain silent and that he was being transferred effective immediately to the DPR unit.

34. Plaintiff inquired why he was being transferred to Differential Police Response

(DPR) and was informed that he was now under investigation.

35. The two investigators then followed Plaintiff home and waited outside while he

retrieved his service weapon and ammunition. Once he relinquished those items to them

he was instructed to sign two (2) documents; one which deemed him powerless as a

police officer and the other acknowledging that he was relinquishing his service weapon

to Internal Affairs pending investigation.

36. On August 4, 2014, Plaintiff admitted himself into the emergency room at

Chestnut Hill Hospital for injuries he sustained during his arrest and detention.

3 7. As a result of this incident Plaintiff suffered two sprained wrists and two

shoulder sprains.

38. On August 4, 2014, Plaintiff was disciplined by being taken off the street and

placed on desk duty on DPR.

39. The foregoing conduct of the Defendants, acting under the color of state law,

was undertaken in concert and conspiracy and as part of an effort to assault, imprison,

unlawfully arrest, unlawful search and seizure, maliciously prosecute, retaliate, prevent

him from engaging in free speech and disciplined Plaintiff from employment and

otherwise deprive Plaintiff of his civil and constitutional rights including Plaintiff's


rights, privileges and immunities under the First, Fourth and Fourteenth Amendments to

the United States Constitution and the laws of the Commonwealth of Pennsylvania.

40. In engaging in free speech as a private citizen regarding matters of public

concern, as described herein, Plaintiff engaged in expression protected by the First

Amendment to the Constitution of the United States. Plaintiffs detention and arrested

was simply a pretext for disciplining Plaintiff as a police officer, in retaliation for his

engaging in protected speech and to prevent him from engaging in such speech in the

future, all of which would have been personally and politically embarrassing to all

Defendants.

41. At no time did Plaintiff commit any offense against the laws of the

Commonwealth of Pennsylvania for which an arrest may be lawfully made. At no time

did Plaintiff strike, attempt to strike or intend to strike any of the Defendant police

officers or any other police officer. At no time did Plaintiff harass, threaten, resist arrest

in any way, commit any illegal acts or engage in any conduct, which in any way justified

the actions of all Defendant police officers.

42. As a direct and proximate result of the Defendants' actions, Plaintiff suffered

serious physical injury, including sprains of both wrists and sprains in both shoulders.

43. As a direct and proximate result of the Defendants' actions, Plaintiff suffered

and continues to suffer serious mental anguish, psychological and emotional distress, and

pain and suffering, some or all of which may be permanent.

44. As a direct and proximate result of the Defendants' actions, Plaintiff has suffered

and continues to suffer damage to his personal, business reputation and loss of

employment.


45. As a direct and proximate result of the Defendants' actions, Plaintiff was

arrested, detained, subjected to physical and verbal abuse without just or probable cause

and retaliated against for engaging in free speech as a private citizen which resulted in his

discipline as a Philadelphia Police Officer.

46. At no time did plaintiff pose a threat to Defendant Does or to others.

47. The actions of Defendants were undertaken in a menacing and arbitrary manner,

designed to cause Plaintiff fear, distress and embarrassment.

48. The acts of Defendants were committed willfully, wantonly, maliciously,

intentionally, outrageously, deliberately and/or by conduct so egregious as to shock the

conscience.

49. The acts and omissions of the undivided Defendants were committed without

cautious regard to due care, and with such wanton and reckless disregard of the

consequences as to show Defendants' indifference to the danger of harm and injury.

50. The individual Defendants conspired to inflict harm on Plaintiff and deprive him

constitutional rights.

51. Defendants made statements to police, the district attorney and others in order to

conceal their unlawful and unconstitutional conduct and in an attempt to deny Plaintiff to

due process.

52. Defendants engaged in the aforesaid conduct for the purpose of violating

Plaintiff's constitutional rights by subjecting him to unreasonable search and seizure,

depriving Plaintiff of property and liberty without due process of law, subjecting Plaintiff

to excessive force, unlawful arrest, malicious prosecution, retaliated against him, and

attempting to deprive Plaintiff to due process.


53. As a direct and proximate result of the Defendants' illegal and unconstitutional

actions, Plaintiff suffered pain, fear, anxiety, embarrassment, loss ofliberty, confinement,

physical injuries, severe emotional trauma, and the loss of the enjoyment of life, all to his

great detriment and loss.

54. As a direct and proximate cause of the Defendants' illegal and unconstitutional

actions, Plaintiff suffered and continues to suffer financial loss, loss of employment and

deprivation of other liberty interests to his great financial detriment and loss.

FIRST CAUSE OF ACTION FEDERAL CIVIL RIGHTS VIOLATIONS

55. The allegations set forth in paragraphs 1-54 inclusive, are incorporated herein as

if fully set forth.

56. As a direct and proximate result of Defendants' above described unlawful and

malicious conduct, committed under the color of state law, and while acting in that

capacity, the Defendants deprived Plaintiff of the equal protection of the laws and

Plaintiffs rights, privileges and immunities under the laws and the Constitution of the

United States. Plaintiffs right to be free from unreasonable searches and seizures, free

from excessive use of force, false arrest, false imprisonment, retaliation, malicious

prosecution to be secure in one's person and property, to access to the Courts, and to due

process and equal protection of the law, all to plaintiffs great detriment and loss. As a

result, Plaintiff suffered grievous harm, in violation of his rights under the laws and

Constitution of the United States in particular the First, Fourth and Fourteenth

Amendments thereof, and 42 U.S.C. 1983.


57. As a direct and proximate result of the acts and omissions of Defendants,

Plaintiff was forced to endure great pain and mental suffering, and was deprived of

physical liberty, all to Plaintiffs great detriment and loss.

58. The City of Philadelphia permitted, encouraged, tolerated, ratified and was

deliberately indifferent to a pattern, practice and custom of:

a. Unjustified, unreasonable and illegal use of process by police officers;

b. Abuse of police powers, including excessive use of force, false arrest,

malicious prosecution, retaliating against individuals for exercising their

constitutional rights, harassment and improper searches;

c. Misrepresenting facts in order to establish probable cause where none

would otherwise exist;

d. Arresting and detaining citizens without probable cause;

e. Psychologically or emotionally unfit persons serving as police officers;

and

f. Failure of police officers to prevent, deter, report or take action against

the unlawful conduct of police officers under such circumstances as

presented herein.

59. Defendant, City of Philadelphia was deliberately indifferent to the need to:

a. Test its officers for emotional and psychological fitness to serve as

police officers;

b. Monitor officers whom it knew or should have known were suffering

from emotional and/or psychological problems that impair their ability to

function as police officers;


c. Train its police officers in the appropriate exercise of police powers;

d. Facilitated, encouraged, tolerated, ratified, and/or was deliberately

indifferent to officers using their status as police officers to have persons

falsely arrested, retaliated against, assaulted and maliciously prosecution

or to achieve ends not reasonably related to their police duties; and

e. Failure to properly train, supervise and discipline officer officers with

regard to such police practices.

60. The City of Philadelphia was deliberately indifferent to the need for more or

different training, supervision, investigation or discipline in the areas of:

a. Use of information in obtaining probable cause;

b. Exercise of police powers;

c. Police officers with emotional or psychological problems;

d. Police officers use of their status as police officers to have persons

fal~ely arrested, assaulted and maliciously prosecution and unlawfully

searched or to achieve ends not reasonably related to their police duties;

and

e. False arrest, malicious prosecution and evidence planting of citizens.

61. The City of Philadelphia failed to properly sanction or discipline officers, who

are aware of and conceal and/or aid and abet violations of constitutional rights of citizens

by other police officers, thereby causing and encouraging police officers, including the

Defendant police officers in this case, to violate the rights of citizens such as Plaintiff.

62. The foregoing acts, omissions, systemic deficiencies and deliberate indifference

to the danger or harm to citizens like the Plaintiff and the need for more or different


training, investigation and discipline are policies and customs of the City of Philadelphia

and have caused police officers, including Defendant police officers in this case, to

believe that they can violate the rights of citizens, with impunity, including the use of

fraud and falsehood and to believe that such conduct would be honestly and properly

investigated, all with the foreseeable result that officers are more likely to violate the

constitutional rights of citizens.

63. The actions of all Defendants, acting under the color of state law and/or in

concert or conspiracy with each other, deprived Plaintiff of his rights, privileges and

immunities under the laws and Constitution of the United States, in particular, the rights

to be secure in one's person and property, to be free from unlawful searches, from false

arrest, retaliation, malicious prosecution and to due process of law.

64. Defendants, City of Philadelphia and the individual named Defendants, acting in

concert and conspiracy with each other, have by the aforementioned actions deprived

Plaintiff of his constitutional and statutory rights.

65. By these actions, all Defendants have deprived Plaintiff of his rights secured by

the First, Fourth and Fourteenth Amendments to the United States Constitution in

violation of 42 U.S.C. 1983.

PUNITIVE DAMAGES

66. Plaintiff re-alleges paragraphs 1-65 of this complaint as though fully set forth

herein.

67. The conduct of the individual Defendants was outrageous, malicious, wanton,

willful, reckless and intentionally designed to inflict harm upon Plaintiff.

68. As a result of the acts of the individual Defendants alleged in the preceding


paragraphs, Plaintiff is entitled to punitive damages as to each cause of action.

JURY DEMAND

69. Plaintiff demands a jury trial as to each Defendant and as to each count.

WHEREFORE, plaintiff requests the following relief:

a. Compensatory damages;

b. Punitive damages;

c. A declaratory judgment that the practices and policies complained of

are unconstitutional;

d. Reasonable attorney's fees and costs; and

e. Such other and further relief as appears reasonable and just.

Isl Michael Pileggi MICHAEL PILEGGI, ESQUIRE 303 Chestnut Street Philadelphia, PA 19106 (215) 627-8516


'.C,,':,;:.,''.~"" '""' '"' IJ ooot,iood hmi" ,~!~!~~~!~~t ~~!~~"~'"of pl~di! ~dioc poporn~ re!! Ow ~"Pt'' ~rovided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the ~urpose of initiating the civil docket sheet. (S!ili INS1JWC110NS ON Nl:X/" PACili OF 1HIS FORM.) . (a) PLAINTIFFS

BRANDON RUFF

(b) County of Residence of First Listed Plaintiff PHILADELPHIA (HXC!iPT IN ll.S. PIA/NT/FF CAS/iS)

( C) Attorneys (Firm Name, Address, and Telephone Numher) rYlichael Pileggi io3 Chestnut Street fhiladelphia, Pa 19106 (2~)~7-8516

DEFENDANTS CITY OF PHILADELPHIA, et al.

County ofResidence ofFirst Listed Defendant PHILADELPHIA (IN ll.S. PIA/N11FF CAS!iS ON/,Y)

NOTE: TN LAND CONDEMNATION CASES, USE THE LOCA TJON OF THE TRACT OF LAND TNVOL VED.

Attorneys (!/"Known)

ii. BASIS OF JURISDl-C.;;:;;IO (l'lacean "X"inOneBoxOnlyJ I U.S. Government ( ~ 3 ederal Question Plaintiff . (ll.S. Uovernmenl Nol a !'arty) III. CITIZENSHIP 0 IN.~L PARTIES (Place an "X" in One BoxJiir Plain111 (Var /)iversily Cas . Only) and One Box for f)~fendanl) PTF DEF PTF DEF Citizen of This St'\ce Ill I Ill I Incorporated or Principal Place 0 4 0 4 \ of Business Jn This State 1

2 U.S. Government Defendant

0 4 Diversity Citizen of Another State 0 2 0 2 Incorporated and Principal Place 0 5 0 5 (!nd1ca/e Citizenship of Parties in //em /II) of Business Jn Another State

Citizen or Subject of a Forei tm Coun trv

0 3 0 3 Foreign Nation

V. NATURE OF SUIT (Place an "X" in One Box Only) I qjl 110 Insurance PERSONAL INJURY PERSONAL INJURY

qjl 120 Marine 0 310 Airplane 0 365 Personal Injury -qjl

1

130 Miller Act 0 315 Airplane Product Product Liability qjl 140 Negotiable Instrument Liability 0 367 Health Care/ qjl 150 Recovery of Overpayment 0 320 Assault, Libel & Pharmaceutical

II & Enforcement of Judgment Slander Personal Injury qjl 151 Medicare Act 0 330 Federal Employers' Product Liability

Student Loans 0 340 Marine Injury Product

0 625 Drug Related Seizure of Property 21 USC 881

0 690 Other

l 152 Recovery of Defaulted Liability 0 368 Asbestos Personal (Excludes Veterans) 0 345 Marine Product Liability , :.:iib"Thf!Jl!,.,.HmHl :: qjll 153 Recovery of Overpayment Liability PERSONAL PROPERTY 0 710 Fair Labor Standards II of Veteran's Benefits 0 350 Motor Vehicle 0 370 Other Fraud Act

qjl 160 Stockholders' Suits 0 355 Motor Vehicle 0 371 Truth in Lending 0 720 Labor/Management ~ 190 Other Contract Product Liability 0 380 Other Personal Relations YI' 195 Contract Product Liability 0 360 Other Personal Property Damage 0 740 Railway Labor Act

1 196 Franchise ;~Injury 0 385 Prope1ty Damage 0 751 Family and Medical sonal Injury - Product Liability Leave Act

[J::::::iifiliiifi{ijijii.Xr:/.::~!1~ij!ldi~ca~l~M~ailo~1r~ac~t1~ce~$f!!illjii]tmJEii.ilmm o 790 Other Labor Litigation I .. :::"":R'~ii,PROPER'JIY:'.I ' ._,, fi,Rlfl..Hi''~"'''' -~.

UNITED STATES DISTRICT COURT 14., {{J. 4 cry lf O NNSYLV ANJA - DESIGN A TJON FORM to be used by counsel to indicate the category of the case for the purpose of

Does this civil action involve a nongovernmental corporate party with any parent corporation and any publicly held co ration owning 10% or more of its stock? YesD No~ (Attach two copies of the Disclosure Statement Form in accordance with Fed.R.Civ.P. 7. l(a))

Does this case involve multidistrict litigation possibilities?

RELATED CASE, IF ANY:

Civil cases are deemed related when yes is answered to any of the following questions:

Yeso No~

I. Is this case related to property included in an earlier numbered suit pending or within one year previously terminated action in this court? YesD No~

2. Does this case involve the same issue of fact or grow out of the same transaction as a prior suit pending or within one year previously terminated action in this court?

YesD Noi;:;i.---3. Does this case involve the validity or infringement of a patent already in suit or any earlier numbered case pending or within one year previously

terminated action in this court? YesD No~ 4. Is this case a second or successive habeas corpus, social security appeal, or prose civil rights case filed by the same individual'?

YesD Nom.----

CIVIL: (Place V in ONE CATEGORY ONLY) A. Federal Question Cases: B. Diversity Jurisdiction Cases: 1. o Indemnity Contract, Marine Contract, and All Other Contracts 1. D Insurance Contract and Other Contracts

2. o FELA 2. D Airplane Personal Injury 3. o Jones Act-Personal Injury 3. D Assault, Defamation 4. o Antitrust 4. D Marine Personal Injury

5. D Motor Vehicle Personal Injury ent Relations 6. D Other Personal Injury (Please specify)

7. D Products Liability

o Habeas C rpus 8. D Products Liability - Asbestos 9. o Secu tes Act(s) Cases 9. D All other Diversity Cases

---10. o Social Security Review Cases (Please specify) 11. o All other Federal Question Cases

(Please specify)--------------------

ARBITRATION CERTIFICATION (Check Appropriate Category)

I, _____________________ , counsel of record do hereby certify: o Pursuant to Local Civil Rule 53.2, Section 3(c)(2), that to the best of my knowledge and belief, the damages recoverable in this civil action case exceed the sum of

$150,000.00 exclusive of interest and costs; o Relief other than monetary damages is sought.

Attorney-at-Law Attorney I.D.# NOTE: A trial de novo will be a trial by jury only ifthere has been compliance with F.R.C.P. 38.

I certify that, to my knowledge, the within case is not related to any case now pending or within one year previously terminated action in this court except as no ed abo .e.

DATE:~ -i6 Attorney l.D.#

CIV. 609 (5/2012)


TJ IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA CASE MANAGEMENT TRACK DESIGNATION FORM

CIVIL ACTION

v .

CJ.TY oP yH-1~Da_pl-\1A1 aA-.t{f; 14 NO. 4940 In accordance with the Civil Justice Expense and Delay Reduction Plan of this court, counsel for plaintiff shall complete a Case Management Track Designation Form in all civil cases at the time of filing the complaint and serve a copy on all defendants. (See 1 :03 of the plan set forth on the reverse side of this form.) In the event that a defendant does not agree with the plaintiff regarding said designation, that defendant shall, with its first appearance, submit to the clerk of court and serve on the plaintiff and all other parties, a Case Management Track Designation Form specifying the track to which that defendant believes the case should be assigned.

SELECT ONE OF THE FOLLOWING CASE MANAGEMENT TRACKS:

(a) Habeas Corpus - Cases brought under 28 U.S.C. 2241 through 2255. ( ) (b) Social Security - Cases requesting review of a decision of the Secretary of Health

and Human Services denying plaintiff Social Security Benefits. ( ) (c) Arbitration- Cases required to be designated for arbitration under Local Civil Rule 53.2. ( ) ( d) Asbestos - Cases involving claims for personal injury or property damage from

exposure to asbestos. ( ) (e) Special Management- Cases that do not fall into tracks (a) through (d) that are

commonly referred to as complex and that need special or intense management by the court. (See reverse side of this form for a detailed explanation of special management cases.)

(f) Standard Management- Cases that do not fall into any one of the other tracks.

Da~ I 21s-~~~Sl/o

Telephone

(Civ. 660) 10/02

Attorney-at-law

"2.t S-

Ruff v City of Philadelphia - Complaint

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Transcript of Ruff v City of Philadelphia - Complaint