Jeffrey S. Jackson
PO Box 3174
Liverpool, NY 13089
315-454-2616
Jeffreysjackson1987@gmail.com
Plaintiff in pro per
IN THE SUPREME COURT OF THE STATE OF NEW YORK
IN AND FOR THE COUNTY OF ONONDAGA
JEFFREY S. JACKSON,
Plaintiff,
vs.
DEPUTY JOHN DOE, DEPUTY MIKE
MAGUET, JEFF MOSS, MARK MONICA,
MIACHEL R. BLOOMBERG, ONONDAGA
COUNTY SHERIFF’S DEPARTMENT STF
SERVICES CORPORATION
Defendants.
Case No.: SU-2020-005022
SUPPLEMENTAL PLEADING
PLAINTIFF’S ORIGINAL COMPLAINT
NOW COMES Jeffrey Jackson, Plaintiff, complaining of Defendants, Deputy John Doe,
Deputy Mike Maguet, Jeff Moss, Mark Monica, Michael R. Bloomberg, Onondaga, County
Sheriff’s Department, Stf Services Corporation and for cause would show the Honorable Court
as follows:
I. NATURE OF THE ACTION
1. This is an action brought by the Plaintiff against the Defendants, for false arrest,
malicious prosecution, abuse of process, false arrest, deprivation of rights and privileges
protected under the U.S Constitution, and unlawful search and seizure and the consequential
impact of deprivation of employment, loss of consortium, damage to reputation and being denied
of economic opportunity by the government under New York Penal Law § 135, 42 US 1985;
1985.109, and 42 US 1981. Bringing additional actions under the 2 nd , 4 th , 6 th , 8 th, and 14 th
amendments. This action is brought against of the each named defendants for direct and
vicarious liability in their personal capacity, official capacity, and supervisory capacities.
2. The Plaintiff thus brings this action for injunctive relief, declaratory judgment,
and money damages to remedy discrimination based on disability, discrimination on the basis
protected class, false arrest, malicious prosecution, abuse of process, conspiracy of rights, first
amendment retaliation, party-of-one discrimination, retaliation by employer and constructive
discharge in the terms, conditions, and privileges of Employment, and Lawful United States
Citizenship in violation of United States 34 U.S.C. § 12601,. et seq. and 42 U.S.C. § 12131 and
Americans with Disabilities Act of 1990 42 U.S.C. 12117(1) and section 794a(a)(1) of title 29,
or section 791 or title 29 and the Civil Rights Act of 1964 section 706 or 717
II. PARTIES
3. Plaintiff Jeffrey Jackson is a male adult of sound mind and a resident of the
County of Onondaga, State of New York.
4. Defendant The Bureau of National Affairs Inc. & STF Services Corp is a
registered corporation under the virtue of the laws of the state of New York. The preceding
defendant also has a place of business located at 1801 South Bell Street. Arlington, VA 22202.
5. Defendant The Bureau of National Affairs Inc. & STF Services Corp is an
employer within the meaning of U.S. Code Title 29 § 152 (2) and employs supervisors with the
meaning of U.S. Code Title 29 § 152.
6. Defendants Deputy John Doe, Deputy Mike Maguet, Jeff Moss, Mark Monica,
Michael Onondaga, County Sheriff’s Department, and STF Services Corporation aided and
abetted Defendant The Bureau of National Affairs Inc. & STF Services Corp to perpetrate the
heinous acts against the Plaintiff.
III. JURISDICTION AND VENUE
7. Jurisdiction exists in this Court pursuant to N.Y. Const. Art. VI § 7(a) which
provides in relevant part as follows: “The supreme court shall have general original jurisdiction
in law and equity and the appellate jurisdiction herein provided.”
8. Consolidated Laws of New York § 140-B also states: “The general jurisdiction in
law and equity which the supreme court possesses under the provisions of the constitution
includes all the jurisdiction which was possessed and exercised by the supreme court of the
colony of New York at any time, and by the court of chancery in England on the fourth day of
July, seventeen hundred seventy-six, with the exceptions, additions and limitations created and
imposed by the constitution and laws of the state.”
9. Venue is proper in this Court because the causes of action described herein took
place within the County of Onondaga.
IV. FACTS
10. Defendant THE BUREAU OF NATIONAL AFFAIRS INC. & STF SERVICES
CORP is a registered corporation under the virtue of the laws of the state of New York.
11. Defendant THE BUREAU OF NATIONAL AFFAIRS INC. & STF SERVICES
CORP & BLOOMBERG LP unconstitutionally allowed policies that violated the 4th amendment
and 14 amendments of the PLAINTIFF.
12. Defendant MICHEAL R. BLOOMBERG & BLOOMBERG LP in his capacity as
mayor of NYC advocated and passed legislation allowing unlawful detention in violation of the
4 th Amendment
13. Defendant MICHEAL R. BLOOMBERG & BLOOMBERG LP supported and
passed legislation called “Stop and Frisk” policy that is in violation of the 4 th amendment of the
UNITED STATES
14. Defendant MICHEAL R. BLOOMBERG & BLOOMBERG LP made statements
in support of and advocating for police officers to detain individuals unlawfully in violation of
the 4 th Amendment
15. Defendant MICHEAL R. BLOOMBERG & BLOOMBERG LP has lost at least
one cases wherein he was a party in litigation and unsuccessfully defended himself against
Monell Liability
16. Defendant MICHEAL R. BLOOMBERG & BLOOMBERG LP and his
subsidiaries own the dissolved NYS Corporation STF Services Corp., which was formerly
located in East Syracuse, NY
17. Defendant THE BUREAU OF NATIONAL AFFAIRS INC. & STF SERVICES
CORP has a place of business located at 1801 South Bell Street. Arlington, VA 22202.
18. Defendant THE BUREAU OF NATIONAL AFFAIRS INC. & STF SERVICES
CORP is an employer within the meaning of U.S. Code Title 29 § 152 (2). The term employer
includes any person acting as an agent of an employer, directly, or indirectly
19. Defendant THE BUREAU OF NATIONAL AFFAIRS INC. & STF SERVICES
CORP employs supervisors within the meaning of U.S. Code Title 29 § 152 (11). The term
supervisor means any individual having authority, in the interest of the employer, to hire,
transfer, suspend, lay off, recall promote etc…”
20. The DEFENDANT THE BUREAU OF NATIONAL AFFAIRS INC. & STF
SERVICES CORP had reason to believe that supervisors who were in violation of civil rights of
other individuals not contained herein the complaint.
21. THE BUREAU OF NATIONAL AFFAIRS INC. & STF SERVICES CORP did
not take action to rectify the situation causing imminent danger for individuals in their custody.
22. The PLAINTIFF was arrested in his home by ONONDAGA COUNTY
SHERIFF’s DEPARTMENT on information provided by an ex-coworker employed by an
agency owned by THE BUREAU OF NATIONAL AFFAIRS INC. & STF SERVICES CORP &
& BLOOMBERG LP, PLAINTIFFS employer.
23. The DEFENDANT ONONDAGA COUNTY SHERIFF’s DEPARTMENT
violated the plaintiffs sixth (6th) amendment right and his second (8th) amendment rights
24. The DEFENDANT ONONDAGA COUNTY SHERIFF’s DEPARTMENT failed
to bring a speedy trial which resulted in the forfeiture of the ability of the PLAINTIFF to
exercise his second (2 nd ) amendment right
25. The DEFENDANT ONONDAGA COUNTY SHERIFF’s DEPARTMENT forced
the sale of the weapon and did not allow the PLAINTIFF any opportunity to retain the firearm in
violation of the PLAINTIFFs second (2 nd ) and sixth (6 th ) amendment rights
26. The DEFENDANT ONONDAGA COUNTY SHERIFF EUGENE and
SHERIFF’s DEPARTMENT called, harassed, and filed frivolous police reports dating back to
the year 2013. In 2013, DEPUTY SHANNON REYES harassed the PLAINTIFF over the phone
while he lived in Oneida County.
27. The PLAINTIFF expressed frustration following being escorted off property and
being spit on while at STF Services Corp. The PLAINTIFF filed a complaint with the agents of
THE BUREAU OF NATIONAL AFFAIRS INC. & STF SERVICES CORP and
requested accommodations and understanding while the PLAINTIFF attended Alcoholics
Anonymous.
28. The PLAINTIFF was put on a performance review in 2017 because he made a
complaint about hostile behavior and sexual behavior put on by DEFENDANT supervisors and
senior members of the DEFENDANT corporation
29. The PLAINTIFF was denied access to his bonus check in February of 2017. The
Human Resources and Payroll Department told him “His Check Was in Mail,” while others
received their cheques on time.
30. The PLAINTIFF was threatened by a director MARK MONICA employed by
agency owned by THE BUREAU OF NATIONAL AFFAIRS INC. & STF SERVICES CORP,
which he would be hit by a bus.
31. The PLAINTIFF was arrested in connection to complaint filed by an agent of an
agency owned by THE BUREAU OF NATIONAL AFFAIRS INC. & STF SERVICES CORP
The corporation, parents, owners, and successors have a pattern of violating 4 th & 14 th
amendment rights of individuals under their direction and control.
32. The PLAINTIFF, following actions lodged with the EEOC and DHR was sent an
unmarked check from STF Services in April of 2019, which he was never provided any details
on. It could only be construed as that “Check Was in Mail” payment.
33. The PLAINTIFF, in August 2019 prior to the arrest was contacted by JEFF
MOSS of THE BUREAU OF NATIONAL AFFAIRS INC. & STF SERVICES CORP via his
LinkedIn account. The PLAINTIFF erroneously construed it as a truce and accepted the
connection request. Soon thereafter, when the plaintiff woke up JEFF MOSS had unfriended
him and attempted to block him.
34. PLAINTIFF was arrested in his home in violation of the fourth amendment. The
arrest was contrived in a retaliatory action by an agent of the agency owned by THE BUREAU
OF NATIONAL AFFAIRS INC. & STF SERVICES CORP The PLAINTIFF was unlawfully
arrested without a warrant by ONONDAGA COUNTY SHERIFF DEPARTMENT inside his
confines of the four walls of his home.
35. The PLAINTIFF was targeted and subjected to a hostile work environment and/or
adverse treatment because he had knowledge and information regarding the ongoing harassment
of employees supervised by agents of the agency owned by THE BUREAU OF NATIONAL
AFFAIRS INC. & STF SERVICES CORP
36. The PLAINTIFF was unlawfully targeted under 42 U.S. Code § 12131 and 29
U.S.C. § 794.
37. The PLAINTIFF had his fourth amendment violated during an in-home arrest
that took place without a warrant.
38. The PLAINTIFF at no-time from April 2019 to august of 2019 was subject of an
arrest warrant.
39. The PLAINTIFF was home and unable to hear any indication of police or sheriff
office when the officer knocked on the door
separate occasions without warrants.
40. The PLAINTIFF owned the home and the sole benefit of the lease at all times
when his home was entered.
41. At no time during any arrest was there a search warrant, bench warrant, or arrest
warrant for the plaintiff.
V. CAUSES OF ACTION
a. Violation of 42 U.S.C. § 1983
42. To prevail on a Section 1983 claim against a municipal entity, a plaintiff must
show: "(1) actions taken under color of law; (2) deprivation of a constitutional or statutory right;
(3) causation; (4) damages; and (5) that an official policy of the municipality caused the
constitutional injury." Roe v. City of Waterbury, 542 F.3d 31, see also Connick, — U.S. —, 131
S. Ct. at 1359 ("Plaintiffs who seek to impose liability on local governments under Section 1983
must prove that 'action pursuant to official municipal policy' caused their injury." (quoting
Monell, 436 U.S. at 691, 98 S. Ct. 2018)); Humphries, 562 U.S. 29, 131 S. Ct. at 452 ("[A]
municipality may be held liable when execution of a government's policy or custom . . . inflicts
the injury."
43. The Court liberally construes the Complaint to alleged, pursuant to Section 1983,
that Defendants violated Plaintiff's Fourth Amendment rights in three respects: 1) by entering his
house; 2) by arresting him without a warrant; and 3) by using excessive force during the arrest.
44. "In order to state a cause of action under 42 U.S.C. § 1983, a plaintiff must allege
that some person acting under color of state law deprived him of a federal right." Washington v.
James, 782 F.2d 1134, 1138 (2d Cir.1986); Morse v. Fitzgerald, 10-CV-6306 CJS (W.D.N.Y.
Mar. 22, 2013)
b. False Arrest
45. Under New York law, to establish a cause of action alleging false arrest and false
imprisonment, the plaintiff must show that (1) the defendant intended to confine him, (2) the
plaintiff was conscious of the confinement, (3) the plaintiff did not consent to the confinement,
and (4) the confinement was not otherwise privileged (see, Broughton v. State of New York, 37
N.Y.2d 451, 456, cert denied sub nom. Schanbarger v. Kellogg, 423 U.S. 929; Straton v. Orange
County Dept. of Social Servs., 217 A.D.2d 576).
46. "The elements of a cause of action alleging false imprisonment or false arrest are
'that the defendant intended to confine the plaintiff, that the plaintiff was conscious of the
confinement and did not consent to the confinement, and that the confinement was not otherwise
privileged' " (Smith v. Village of Freeport Police Dept., 181 AD3d 625, 626 [2020],
quoting Martinez v City of Schenectady, 97 NY2d 78, 85 [2001]). "[A]n act of confinement is
privileged if it stems from a lawful arrest supported by probable cause" (De Lourdes Torres v
Jones, 26 NY3d 742, 759 [2016]). Thus, "[t]he existence of probable cause constitutes a
complete defense to a cause of action alleging false arrest" (Macareno v City of New York, 187
AD 3d 1164, 1166 [2020] [internal quotation marks omitted]). " 'The existence or absence of
probable cause becomes a question of law to be decided by the court only where there is no real
dispute as to the facts or the proper inferences to be drawn surrounding the arrest' " (id. at 1166,
quoting MacDonald v Town of Greenburgh, 112 AD 3d 586, 586-587 [2013]).
47. Plaintiff did not intend to be confined by Defendants who had neither probable
cause nor a warrant in order to confine Plaintiff. The lack of probable cause or a warrant means
that the confinement was not privileged.
c. Malicious Prosecution
48. The tort of malicious prosecution protects the personal interest of freedom from
unjustifiable litigation (Prosser, Torts [4th ed], § 119; False imprisonment; liability of private
citizen for false arrest by officer, Ann., 21 ALR2d 643). The essence of malicious prosecution is
the perversion of proper legal procedures. Thus, it has been held that some sort of prior judicial
proceeding is the sine qua non of a cause of action in malicious prosecution (Al Raschid v News
Syndicate Co., 265 N.Y. 1).
49. Such a judicial proceeding may be either an evaluation by a Magistrate of an
affidavit supporting an arrest warrant application, or an arraignment or an indictment by a Grand
Jury.
50. The elements of the tort of malicious prosecution are: (1) the commencement or
continuation of a criminal proceeding by the defendant against the plaintiff, (2) the termination
of the proceeding in favor of the accused, (3) the absence of probable cause for the criminal
proceeding and (4) actual malice (Prosser, Torts [4th ed], § 119).
51. Where the plaintiff institutes a malicious prosecution action he must plead the
lack of probable cause (Malicious Prosecution — Probable Cause, Ann., 14 ALR2d 264). A
contrary rule would be against public policy as tending to discourage prosecutions for crime or
the vindication of civil rights. Despite the clear and fundamental differences between malicious
prosecution and false imprisonment, the concepts are easily intermingled in the arrest situation.
52. The distinction between false imprisonment and malicious prosecution in the area
of arrest depends on whether or not the arrest was made pursuant to a warrant. As noted in the
Restatement, 2d, an unlawful detention gives rise to a cause of action for false imprisonment
"except where the confinement was by arrest under a valid process issued by a court having
jurisdiction" (Restatement, 2d, Torts, § 35, comment a; Prosser, Torts [4th ed], § 11).
53. When an unlawful arrest has been effected by a warrant an appropriate form of
action is malicious prosecution. This distinction is critical not only because it affects the
allegations and proof but also because it brings the prima facie rule into operation.
d. Slander and Defamation
54. Defamation has long been recognized to arise from "the making of a false
statement which tends to "expose the plaintiff to public contempt, ridicule, aversion or disgrace,
or induce an evil opinion of him in the minds of right-thinking persons, and to deprive him of
their friendly intercourse in society"'" (Foster v Churchill, 87 NY2d 744, 751, quoting Rinaldi v
Holt, Rinehart & Winston, 42 NY2d 369, 379, cert denied 434 US 969, quoting Sydney v
MacFadden Newspaper Publ. Corp., 242 NY 208, 211-212).
55. The elements are a false statement, published without privilege or authorization to
a third party, constituting fault as judged by, at a minimum, a negligence standard, and it must
either cause special harm or constitute defamation per se (Restatement [Second] of Torts § 558).
56. CPLR 3016 (a) requires that in a defamation action, "the particular words
complained of * * * be set forth in the complaint." The complaint also must allege the time,
place and manner of the false statement and specify to whom it was made (Arsenault v
Forquer, 197 AD2d 554; Vardi v Mutual Life Ins. Co., 136 AD2d 453).
57. The sheriff’s deputy who arrested me was informed by Amanda Barry that the
Plaintiff was a stalker. That the Plaintiff had a history of stalking and that the Plaintiff was
stalking her at her work. She further went on to post on social media that that the Plaintiff had a
history of stalking. That the brokerage that the Plaintiff was hired at knew the Plaintiff stalked
people and hired me and continued to allow me to work there even though the Plaintiff stalked
her.
58. All of the preceding information is untrue because the Plaintiff had never met her
or followed her in person. Not only did she post this, but she intended to damage my position as
a real estate agent. She intended to have the Plaintiff fired by the real estate agency. She also
intended to damage the Plaintiff’s economic situation by using this lie to make the Plaintiff lose
the job. As a result of this the Plaintiff lost several thousand dollars the Plaintiff had invested into
his career as a real estate agent and future potential income as a real estate agent.
59. Jeff Moss (a Defendant) also made statements that were untrue on his report,
claiming that the Plaintiff had mental issues and that the Plaintiff has always been a trouble
maker. All of those were unfounded and baseless. He had no proof of any of those statements
and he only intended to get the Plaintiff arrested as a retaliation. He told multiple people at STF,
the Onondaga Sheriff and counsel for Bureau of National Affairs and Bloomberg LP that the
Plaintiff had serious mental issues and the Plaintiff suffers from mental issues and he has mental
problems.
60. None of the preceding were founded and all were baseless and he had no proof.
Resultantly, the Plaintiff was fired from his management job at Intuit Inc, and was forced to
move out of his home to supplement the loss of income. The statement was only meant to cause
the arrest, cause issues with background check and to cause him hardship and anguish. This was
a retaliation and payback for my complaints to the DHOR EEOC federal courts and 2nd circuit.
61. The false statements also resulted in the sheriff searching the brokerage
headquarters of Howard Hanna in Camillus NY. The sheriff had a non-felony warrant that was
not specific in its terms of places to be searched. The result was the sheriff going to the
brokerage. Confronting management at the real estate brokerage. Also going to the Plaintiff’s
home to search there without a specific warrant stating the exact places to be searched.
62. Further, these false statements led multiple people to call him a stalker. Numerous
people unfriendliness on social media Facebook. The Plaintiff was also charged with stalking
and harassment, based off the false and malicious statements. This is despite the Plaintiff not
being guilty of the alleged crimes stated on Facebook or of the statements made to sheriff and it
was all a lie which was only meant to get me arrested cause hardship and anguish in my life.
63. Not only but to cause anger, revile, revulsion scorn and contempt of my person by
the other members of my community, his brokerage and friends and even family members. The
defamatory and slanderous statements made thus caused the Plaintiff a lot of damage that merits
his compensation in form of damages.
e. Violation of 42 U.S.C. § 1985(3) – Depriving persons of rights or privileges
64. If two or more persons in any State or Territory conspire or go in disguise on the
highway or on the premises of another, for the purpose of depriving, either directly or
indirectly, any person or class of persons of the equal protection of the laws, or of equal
privileges and immunities under the laws and if one or more persons engaged therein do, or
cause to be done, any act in furtherance of the object of such conspiracy, whereby another is
injured in his person or property, or deprived of having and exercising any right or privilege of a
citizen of the United States, the party so injured or deprived may have an action for the recovery
of damages occasioned by such injury or deprivation, against any one or more of the
conspirators.
65. [ 42 U.S.C. § 1985]- "In order to make out a Section 1985(3) claim, the plaintiff
must allege and prove four elements: (1) a conspiracy; (2) for the purpose of depriving, either
directly or indirectly, any person or class of persons of the equal protection of the laws, or of
equal privileges and immunities under the laws; and (3) an act in furtherance of the conspiracy;
(4) whereby a person is either injured in his person or property or deprived of any right or
privilege of a citizen of the United States.
f. Failure to Train and Inadequate Training
66. "[A] claim of inadequate training will trigger municipal liability only where 'the
failure to train amounts to deliberate indifference to the rights' of those with whom municipal
employees will come into contact." Walker v. City of New York, 974 F.2d 293, 297 (2d Cir.
1992) (quoting City of Canton v. Harris, 489 U.S. 378, 388 (1989)).
67. The deliberate indifference standard is stringent and requires "proof that a
municipal actor disregarded a known or obvious consequence of his action." Connick v.
Thompson, 563 U.S. 51, 61 (2011). The test for liability for a failure to train employees requires
a showing that: (1) the defendant knows to a moral certainty that her employees will confront a
given situation; (2) the situation either presents the employee with a difficult choice of the sort
that training, or supervision will make less difficult or that there is a history of employees
mishandling the situation; and (3) the wrong choice by the city employee will frequently cause
the deprivation of a citizen's constitutional rights. Molina v. City of Elmira, 12-CV-6310 EAW
(W.D.N.Y. Apr. 13, 2015)].
VI. PRAYER FOR RELIEF
WHEREFORE, the Plaintiff respectfully requests this Honorable Court to grant the
following reliefs:
a. Grant PLAINTIFF declaratory judgment that the acts, policies, practices, and
procedures complained of herein violated Plaintiff’s rights as secured by the New York City
Administrative Code, § 8-101, and the New York State Executive Law § 296 and such other
statutes that provide protection against discrimination; A declaration that the Plaintiff is eligible
for unemployment benefits from the Defendants;
b. Grant PLAINTIFF preliminary and permanent injunctions, prohibiting the
DEFENDANTS, their agents, successors, employees, and those acting in concert with them and
at their direction from engaging in any of the practices set forth above and any other practice
shown to be unlawful or retaliatory or discriminatory on the basis of sex and age with respect to
compensation, terms, conditions and privileges of employment or from continuing or
maintaining a policy, practice, custom or usage of denying, abridging, withholding, conditioning,
limiting or otherwise interfering with the rights of PLAINTIFF to enjoy equal employment
opportunities secured by law; Award the Plaintiff punitive damages, pre and post judgment
interests, costs of this suit and attorney fees as allowed by law;
c. Compensatory damages for emotional pain and suffering, mental anguish,
humiliation, loss of reputation and opportunity to be granted loans and grants from the
government.
d. Liquidated damages in an amount to awarded at trial;
e. Punitive damages in an amount to be awarded at trial;
f. Attorney’s fees, costs and disbursements;
g. Interest; and
h. Such additional relief to PLAINTIFF as the Honorable Court deems necessary
and proper.
Respectfully Submitted,
______________________________
Jeffrey Jackson
315-454-2616
Jeffreysjackson1987@gmail.com
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