Pro Se 15 (Rev.

12/16) Complaint for Violation of Civil Rights (Non–Prisoner)

UNITED STATES DISTRICT COURT

for the
SOUTHERN Districtof
__________ District of__________
NEVADA_________

__________
__________ Division
Division

YOUSEF ELAMRI KADMIRI

) Case No.
) (to be filled in by the Clerk’s Office)
)
Plaintiff(s)
(Write the full name of each plaintiff who is filing this complaint.
)
) Jury Trial: (check one) ✔
’ Yes ’ No
If the names of all the plaintiffs cannot fit in the space above,
please write “see attached” in the space and attach an additional )
page with the full list of names.) )
-v- )
MGM GRAND RESORTS INTL., )
HENDERSON POLICE DEPARTMENT, SAN )
BERNARDIO POLICE DEPARTMENT, MONROVIA )
SHERIFFS DEPARTMENT, ALHAMBRA POLICE )
DEPARTMENT, JOHN DOE 1-30, AND JANE DOE 1-5.
Defendant(s) )
(Write the full name of each defendant who is being sued. If the )
names of all the defendants cannot fit in the space above, please )
write “see attached” in the space and attach an additional page
with the full list of names. Do not include addresses here.)

COMPLAINT FOR VIOLATION OF CIVIL RIGHTS

(Non-Prisoner Complaint)

NOTICE

Federal Rules of Civil Procedure 5.2 addresses the privacy and security concerns resulting from public access to
electronic court files. Under this rule, papers filed with the court should not contain: an individual’s full social
security number or full birth date; the full name of a person known to be a minor; or a complete financial account
number. A filing may include only: the last four digits of a social security number; the year of an individual’s
birth; a minor’s initials; and the last four digits of a financial account number.

Except as noted in this form, plaintiff need not send exhibits, affidavits, grievance or witness statements, or any
other materials to the Clerk’s Office with this complaint.

In order for your complaint to be filed, it must be accompanied by the filing fee or an application to proceed in
forma pauperis.

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Pro Se 15 (Rev. 12/16) Complaint for Violation of Civil Rights (Non–Prisoner)

I. The Parties to This Complaint

A. The Plaintiff(s)

Provide the information below for each plaintiff named in the complaint. Attach additional pages if
needed.
Name YOUSEF ELAMRI KADMIRI
Address 2701 KINGCLAVEN DRIVE,
HENDERSON NV 89044
City State Zip Code
County CLARK COUNTY , NEVADA
Telephone Number 702-480-8718
E-Mail Address KADMIRIJOEY@GMAIL.COM

B. The Defendant(s)

Provide the information below for each defendant named in the complaint, whether the defendant is an
individual, a government agency, an organization, or a corporation. For an individual defendant,
include the person’s job or title (if known) and check whether you are bringing this complaint against
them in their individual capacity or official capacity, or both. Attach additional pages if needed.

Defendant No. 1
Name
Job or Title (if known) MGM GRAND RESORTS INTERNATIONAL
Address CASINO AND HOTEL SERVICES
LAS VEGAS NV 89119
City State Zip Code
County CLARK COUNTY NEVADA
Telephone Number UKN
E-Mail Address (if known) UKN

✔ Individual capacity
’ ’ Official capacity

Defendant No. 2
Name HENDERSON POLICE DEPARTMENT
Job or Title (if known) CITY POLICE AGENCY IN HENDERSON, NEVADA
Address WATER STREET
HENDERSON NV 89044
City State Zip Code
County CLARK COUNTY
Telephone Number UKN
E-Mail Address (if known) UKN

’ Individual capacity ’ Official capacity

✔

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Pro Se 15 (Rev. 12/16) Complaint for Violation of Civil Rights (Non–Prisoner)

Defendant No. 3
Name
Job or Title (if known) SAN BERNARDINO POLICE DEPARTMENT
Address CITY POLICE DEPARTMENT / LAW ENFORCEMENT AGENCY
SAN BERNARDINO CA
City State Zip Code
County SAN BERNARDINO
Telephone Number UKN
E-Mail Address (if known) UKN

’ Individual capacity ’ Official capacity

✔

Defendant No. 4
Name MONROVIA SHERIFFS OFFICE AND ALHABRA POLICE DEPARTMENT
Job or Title (if known) POLICE/ LAW ENFORCEMENT AGENCY
Address UKN
MONROVIA CA
City State Zip Code
County LA COUNTY
Telephone Number UKN
E-Mail Address (if known) UKN

’ Individual capacity ✔
’ Official capacity

II. Basis for Jurisdiction

Under 42 U.S.C. § 1983, you may sue state or local officials for the “deprivation of any rights, privileges, or
immunities secured by the Constitution and [federal laws].” Under Bivens v. Six Unknown Named Agents of
Federal Bureau of Narcotics, 403 U.S. 388 (1971), you may sue federal officials for the violation of certain
constitutional rights.

A. Are you bringing suit against (check all that apply):

’ Federal officials (a Bivens claim)

✔
’ State or local officials (a § 1983 claim)

B. Section 1983 allows claims alleging the “deprivation of any rights, privileges, or immunities secured by
the Constitution and [federal laws].” 42 U.S.C. § 1983. If you are suing under section 1983, what
federal constitutional or statutory right(s) do you claim is/are being violated by state or local officials?
LOCAL OFFICIALS, AND STATE OFFICIALS

C. Plaintiffs suing under Bivens may only recover for the violation of certain constitutional rights. If you
are suing under Bivens, what constitutional right(s) do you claim is/are being violated by federal
officials?

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Pro Se 15 (Rev. 12/16) Complaint for Violation of Civil Rights (Non–Prisoner)

D. Section 1983 allows defendants to be found liable only when they have acted “under color of any
statute, ordinance, regulation, custom, or usage, of any State or Territory or the District of Columbia.”
42 U.S.C. § 1983. If you are suing under section 1983, explain how each defendant acted under color
of state or local law. If you are suing under Bivens, explain how each defendant acted under color of
federal law. Attach additional pages if needed.
EACH INDIVIDUAL WITH EXCEPTION TO MGM GRAND INTERNATIONAL THE DEFENDANTS
ACTED AS POLICE WITH THE HELP OF THOSE ACTING AS POLICE AGENTS.

III. Statement of Claim

State as briefly as possible the facts of your case. Describe how each defendant was personally involved in the
alleged wrongful action, along with the dates and locations of all relevant events. You may wish to include
further details such as the names of other persons involved in the events giving rise to your claims. Do not cite
any cases or statutes. If more than one claim is asserted, number each claim and write a short and plain
statement of each claim in a separate paragraph. Attach additional pages if needed.

A. Where did the events giving rise to your claim(s) occur?

HENDERSON, NEVADA ; MOROVIA COUNTY; CALIFORNIA ; ALHAMBRA POLICE DEPARTMENT
CALIFORNIA. SAN BERNARDINO, CALIFORNIA .
SPECIAL NOTATION AND ADDED EMPHYSIS TO SAN BERNARDINO AND HENDERSON POLICE
DEPARTMENT FOR ABSOLUTELY MALICIOUS INTENT AND ARBITRARY AND CAPRACIOUS
BEHVIORS IN THE COMMISION OF FACILITATION , AIDING , AND AMBETTING FELONIOUS
CONDUCT.
B. What date and approximate time did the events giving rise to your claim(s) occur?
ANYWHERE BETWEEN THE DATES OF FOR DEFENDANT HENDERSON CITY POLICE IT WAS
EVERYDAY SINCE FEBRUARY 2, 2022 TO

C. What are the facts underlying your claim(s)? (For example: What happened to you? Who did what?
Was anyone else involved? Who else saw what happened?)
IN AND FROM DATES DATING BACK TO THE ORIGINATION OF VIOLATION OF RIGHTS IT BEGAN
AS A CRIMINAL CASE IN WHICH WAS MALICIOUSLY BROUGHT UPON MYSELF THE MOST
HANUS AND ARBITRARY AND CAPRACIOUS CASE HUMILIATING ME , AND TARNISHING MY
NAME FOR INFAMY . ESSENTIALLY I THE PLAINTIFF USED TO BE AN ADULT MODEL AND
UNFORTUNATLY DECIDED TO GET SIGNED ON WITH SPI ENTERTAINMENT A SUB
CONTRACTED ENTERTAINING COMPANY IN WHICH THERE WERE LOTS OF DRUGS, ALCOHOL,
AND PARTYING . UNFORTUNATELY ON THE PLAINTIFFS FIRST GUEST ACT WHERE HED GET A
FEW MINUTES IN THE LIMELIGHT TO SEE WHETER OR NOT HE WAS WORTHY KINDA THING
(MY SPECULATION).
INSTEAD IT GOT DIRTY QUICK AND A SCENE THAT WAS INVITING AND FRIENDLY TURNED TO
A BRUTAL ATTACK AND BEATDOWN OF MY SELF (THE PLAINTIFF) IN ALMOST DYING IN MY
FIGHT AGAINST MY BRUTAL ATTACKERS I REACHED FOR A GUN ON ONE OF MY ATTACKERS
WAIST . ESSSENTIALLLY IN DOING SO THE FIREARM WENT OFF. I WAS ABLE TO LOOK UP AND
SEE A CAMERA WAS BASICALLY THERE IN THE DIRECTION I WAS SITTING BEING DRAGGED
AND BEATEN VIOLENTLY AND BRUTALLY TO THE POINT THE RESPONDING OFFICERS HAD TO
SEND THE PLAINTIFF TO THE HOSPITAL FOR TREATMENT OF MY BADLY WOUNDED BODY. I
WAS COMPLETELY CONFUSED AND IN SHOCK TO FIND MYSELF BEING ARRESTED FOR A
CRIME WHEN I WAS THE VICTIM. I FILED MANY COMPLAINTS AND DOCUMENTATION
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EXPLAINING THAT I WAS A VICTIM OF A CRIME UNDER NEVADA REVISED STATUE 200.200 IN
WHICH I WAS IGNORED AND CHARGED WITH A VARIETY OF CRIMINAL OFFENSES IN WHICH I
DID NOT COMMIT. WHEN I WENT TO COURT. THE STATE FILED DEMURR MOTIONS FRIVILOUS
Pro Se 15 (Rev. 12/16) Complaint for Violation of Civil Rights (Non–Prisoner)

IV. Injuries

If you sustained injuries related to the events alleged above, describe your injuries and state what medical
treatment, if any, you required and did or did not receive.

V. Relief

State briefly what you want the court to do for you. Make no legal arguments. Do not cite any cases or statutes.
If requesting money damages, include the amounts of any actual damages and/or punitive damages claimed for
the acts alleged. Explain the basis for these claims.

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Pro Se 15 (Rev. 12/16) Complaint for Violation of Civil Rights (Non–Prisoner)

VI. Certification and Closing

Under Federal Rule of Civil Procedure 11, by signing below, I certify to the best of my knowledge, information,
and belief that this complaint: (1) is not being presented for an improper purpose, such as to harass, cause
unnecessary delay, or needlessly increase the cost of litigation; (2) is supported by existing law or by a
nonfrivolous argument for extending, modifying, or reversing existing law; (3) the factual contentions have
evidentiary support or, if specifically so identified, will likely have evidentiary support after a reasonable
opportunity for further investigation or discovery; and (4) the complaint otherwise complies with the
requirements of Rule 11.

A. For Parties Without an Attorney

I agree to provide the Clerk’s Office with any changes to my address where case–related papers may be
served. I understand that my failure to keep a current address on file with the Clerk’s Office may result
in the dismissal of my case.

Date of signing:

Signature of Plaintiff
Printed Name of Plaintiff

B. For Attorneys

Date of signing:

Signature of Attorney
Printed Name of Attorney
Bar Number
Name of Law Firm
Address

City State Zip Code

Telephone Number
E-mail Address

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