DONNA LOU and DAREN PARSA, on Their Own ) NUMBER: Behalf and on Behalf of Their Deceased Minor Child, ) E.P
Case 2:21-cv-00080 Document 1 Filed 01/14/21 Page 1 of 80 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA __________________________________________ ) DONNA LOU and DAREN PARSA, on their own ) NUMBER: behalf and on behalf of their deceased minor child, ) E.P. ) SECTION: Plaintiffs, ) v. ) JUDGE: ) SHERIFF JOSEPH P. LOPINTO, III, CHAD ) MAGISTRATE: PITFIELD, RYAN VAUGHT, STEVEN ) MEHRTENS, SHANNON GUIDRY, NICK ) CIVIL RIGHTS UNDER 42 U.S.C. §§ 1983, VEGA, MANUEL ESTRADA, MYRON ) 1988; AMERICANS WITH DISABILITIES GAUDET, JOHN DOES 1-3, VICTORY REAL ) ACT, 42 U.S.C. §§ 12131, 12132; AND ESTATE INVESTMENTS LA, LLC and ) SECTION 504, REHABILITATION ACT, 29 WESTGATE INVESTORS NO LLC D/B/A ) U.S.C. § 794. WESTGATE SHOPPING CENTER, ABC ) INSURANCE COMPANY, and XYZ ) INSURANCE COMPANY, ) ) Defendants. COMPLAINT COME NOW the Plaintiffs, by and though the undersigned counsel and for cause of action against the Defendants, both jointly and severally, would respectfully state as follows: I. INTRODUCTION 1. This case involves the tragic death of a 16-year-old severely autistic child, (E.P.), while in the custody and care of deputies with the Jefferson Parish Sheriff’s Office (JPSO) in the parking lot of the Westgate Shopping Center in Metairie, La. on January 19, 2020. 2. E.P. was the only child of Donna Lou and Daren Parsa, both of whom were present when he died before their eyes. He was held down in a prone position, on his stomach, handcuffed, shackled, arms and legs held down, head, shoulder and neck encircled by the arm of a deputy, with JPSO deputies applying their own body weight as a restraint, while he was suffering from an acute 1 Case 2:21-cv-00080 Document 1 Filed 01/14/21 Page 2 of 80 sensory episode or “outburst” related to and caused by his severe autism.
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