Case 1:19-Cv-02673-VEC Document 35 Filed 01/03/20 Page 1 of 28
Case 1:19-cv-02673-VEC Document 35 Filed 01/03/20 Page 1 of 28 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ------------------------------------------------------------x TERRON BELLE, WILLIAM RIOS, RICHMOND APPIAH, EDISON QUITO, BONACIO CRESPI, JAMEEL LANG, and LUIS RIOS, on Behalf of Themselves and a Class of Others Similarly Situated, 19 cv 2673 (VEC) Plaintiffs, FIRST AMENDED CLASS -against- COMPLAINT THE CITY OF NEW YORK, NEW YORK CITY POLICE OFFICERS “JOHN DOE” 1-50, JURY TRIAL DEMANDED in their individual and official capacities, Defendants. --------------------------------------------------------------x I. PRELIMINARY STATEMENT 1. This action, brought by seven New Yorkers on behalf of a class of similarly situated people, challenges the New York City Police Department’s (“NYPD”) unconstitutional practice of detaining people for the purpose of conducting searches of NYPD internal and external databases (hereinafter “NYPD records search”) for records related to the person detained, including but not limited to warrants, investigation cards (hereinafter “I-cards”), orders of protection, arrest records, suspected gang affiliations, and suspected matches to open cases through predictive policing tools without individualized reasonable suspicion. 2. By exploiting surveillance technology, the NYPD has replaced traditional—and largely discredited—police practices such as stop and frisk with invasive digital searches Case 1:19-cv-02673-VEC Document 35 Filed 01/03/20 Page 2 of 28 that rely on surveillance systems to provide a detailed snapshot of people’s lives, from daily movements to financial footprints. 3. In order to conduct these unconstitutional searches, the NYPD utilizes systems, including the Domain Awareness System (“DAS”) the Z FINEST system, and the Criminal Group Database, that aggregate warrant and summons information and a wide range of other data.
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