Case 1:21-cv-00761 Document 1 Filed 03/15/21 USDC Colorado Page 1 of 17

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLORADO

Civil Action No.:_____________________

SAMMIE LEON LAWRENCE IV,
Plaintiff,
v.
CITY OF BOULDER, COLORADO, a municipality; and
WAYLON LOLOTAI, in his individual capacity,
Defendants.

COMPLAINT AND JURY DEMAND

Plaintiff Sammie Leon Lawrence IV, through his counsel, Darren O’Connor of DARREN

O’CONNOR, LLC, and Daniel D. Williams of HUTCHINSON, BLACK AND COOK, LLC,

file this Complaint and Jury Demand and aver as follows:

INTRODUCTION

1. This is an action that goes to the heart of the United States Constitution: a citizen’s

right to freedom of speech and to be free of unreasonable seizures. It arises from a City of Boulder

police officer violently arresting an African-American man when he lawfully and respectfully

exercised his right to film the police officer questioning people in a public park.

2. Mr. Lawrence was present at Mapleton Ballfields in Boulder, Colorado on April

10, 2019, when he noticed Boulder Police Department (hereafter “BPD”) Officer Waylon Lolotai

speaking to several of Mr. Lawrence’s friends whom Mr. Lawrence knew at the time to be
 Case 1:21-cv-00761 Document 1 Filed 03/15/21 USDC Colorado Page 2 of 17

experiencing homelessness. Mr. Lawrence purposefully, slowly, and calmly approached the scene

and began to observe from a distance of approximately ten feet from Officer Lolotai. 1

3. Mr. Lawrence was holding a walking aid at the time that he uses because of a

seizure disorder. Officer Lolotai unlawfully ordered Mr. Lawrence to “put the stick down and

back up,” to which Mr. Lawrence replied that he was observing and that he was “not putting down

my walking aid sir.” Throughout the encounter, Mr. Lawrence repeatedly and respectfully shared

that he needed his walking aid, that he had a disability, that he had a seizure disorder, and that he

was lawfully observing and recording BPD’s questioning of his friends.

4. Mr. Lawrence consistently maintained a calm demeanor, made no sudden motions,

and gave no reason for concern. He openly used his phone to video record the encounter from his

present location, still approximately ten feet away from Officer Lolotai. Officer Lolotai apparently

did not want his conduct to be recorded from a distance where he could be clearly heard and

observed. Officer Lolotai again demanded, without legal justification, “You will back up.” Mr.

Lawrence refused.

5. Mr. Lawrence again explained that he was at a safe distance to observe, was

concerned about his friends being harassed, and that he had a right to observe the interaction as a

citizen. Officer Lolotai at one point told Mr. Lawrence he could sit at a seating area 20 feet or more

away, a distance from which Mr. Lawrence would have been unable to hear and properly observe

Officer Lolotai’s conduct.

1 Boulder Revised Code § 5-5-3, Obstructing a Police Officer or Firefighter, requires a person to
move no more than eight feet away from an officer upon command. Mr. Lawrence avers he was
more than eight feet away from Officer Lolotai at all times when the latter ordered Mr. Lawrence
to back up.

2
 Case 1:21-cv-00761 Document 1 Filed 03/15/21 USDC Colorado Page 3 of 17

6. Officer Lolotai, displeased that a citizen was exercising his lawful right to observe

and record police conduct, threatened that if Mr. Lawrence did not leave, he would be arrested.

True to his word, when backup arrived, Officer Lolotai effected a violent illegal arrest of Mr.

Lawrence, and ultimately booked him into the Boulder County Jail.

7. Officer Lolotai has a history of a short temper, the use of – and actually exalting –

unreasonable force, and use of arrests for obstruction or resisting arrest to cover his unjustified

actions. On information and belief, Officer Lolotai’s history of excessive force was well known

to BPD at the time of Mr. Lawrence’s arrest. Officer Lolotai’s arrest of Mr. Lawrence was

particularly outrageous because Mr. Lawrence calmly communicated his need for a wa lking aid

due to his disability and his intention merely to observe BPD’s conduct. The bodycam footage of

the incident makes clear Mr. Lawrence never obstructed Officer Lolotai in any way.

8. Despite this clear evidence captured on video, the City of Boulder ratified and

endorsed Officer Lolotai’s outrageous behavior, which has been Officer Lolotai’s trademark since

the City hired him while he was under investigation for unreasonable use of force when still

employed as a Denver Sheriff’s Department deputy.

PARTIES

9. Plaintiff Sammie Leon Lawrence IV was at all times a resident of and domiciled in

Boulder, Colorado.

10. Defendant City of Boulder, Colorado (hereafter “Boulder”) is a home -rule

municipality in Boulder County, Colorado.

3
 Case 1:21-cv-00761 Document 1 Filed 03/15/21 USDC Colorado Page 4 of 17

11. Defendant Waylon Lolotai was, at the time of the incident subject to this Complaint,

a police officer who at all times with respect to the conduct alleged herein acted under color of

state law as a police officer with the BPD.

JURISDICTION AND VENUE

12. This action arises under the Constitution and laws of the United States and is

brought pursuant to 42 U.S.C. §§ 1983 and 1988. Jurisdiction is conferred on this Court pursuant

to 28 U.S.C. § 1331.

13. Venue is proper in the District of Colorado pursuant to 28 U.S.C. § 1391(b). All of

the events alleged herein occurred in Boulder, Colorado, and all of the parties were residents of

the State of Colorado at the time of the events giving rise to this Complaint.

FACTUAL ALLEGATIONS

A. Mr. Lawrence Is Violently Arrested by Defendants for Exercising His Rights.

14. Mr. Lawrence is a soft spoken young African-American man and a member of the

National Association for the Advancement of Colored People in Boulder County (hereafter

“NAACP”).

15. On April 5, 2019, at Mapleton Ballfields public park, Mr. Lawrence calmly and

slowly approached a group of people he knew to be experiencing homelessness as Officer Lolotai

began to question them. He did so with the intent to observe Officer Lolotai as he questioned them.

16. Mr. Lawrence was at all times ten feet or more from Officer Lolotai.

17. Mr. Lawrence stood nearly motionless as he observed the scene.

4
 Case 1:21-cv-00761 Document 1 Filed 03/15/21 USDC Colorado Page 5 of 17

18. Nonetheless, Officer Lolotai quickly told Mr. Lawrence to back up, then to “put the

stick down and back up,” to which Mr. Lawrence replied that he was just observing the police

encounter, and that he needed his walking aid in light of his disability.

19. Mr. Lawrence consistently maintained a calm demeanor, made no sudden motions,

and gave no reason for concern.

20. Mr. Lawrence took out his phone, expressed his intention to film the encounter, and

shared with Officer Lolotai that he “was observing at a safe distance away from you.” Officer

Lolotai responded, “No you’re not, you will back up.” Mr. Lawrence further explained that he was

at a safe distance to observe his friends being harassed, and stated he had a right to observe the

interaction as a citizen.

21. Officer Lolotai at one point told Mr. Lawrence he could sit at a seating area visibly

20 feet or more away, a distance from which Mr. Lawrence would have been unable to hear and

properly observe Officer Lolotai’s actions.

22. Mr. Lawrence never threatened Officer Lolotai in any manner whatsoever. He did

not interfere with Officer Lolotai’s efforts and only spoke when spoken to.

23. Despite all of this, Officer Lolotai threatened Mr. Lawrence, telling him “I’m gonna

tell you again or you're going to jail for obstruction.”

24. Mr. Lawrence responded that he was “not obstructing anything” and that he was

“very firmly aware” of his rights. Officer Lolotai responded, “Nope, you need to move farther

away, and you’re holding a weapon.” Mr. Lawrence again informed Officer Lolotai that he was

not holding a weapon -- he was holding his walking aid.

5
 Case 1:21-cv-00761 Document 1 Filed 03/15/21 USDC Colorado Page 6 of 17

25. When another officer arrived, Mr. Lawrence shared that he would gladly step back

if the officer needed to approach the people sitting on the ground that Officer Lolotai had been

questioning. That, of course, would have kept Mr. Lawrence more than eight feet away from the

police officers, as required by municipal ordinance. See supra n.1.

26. Notwithstanding that Mr. Lawrence was fully complying with the law and had

stated explicitly that he would continue to comply with the law, shortly thereafter, Officer Lolotai

advanced on Mr. Lawrence and violently arrested him.

27. The arrest deprived Mr. Lawrence of his walking aid, of his First Amendment right

to video the police officers in the park, and of his liberty.

28. Though other officers--upon information and belief three other officers--were

present at the time of the arrest, Officer Lolotai effected the arrest alone. This fact, among others,

makes clear that Officer Lolotai had no fear of Mr. Lawrence’s potential use of his walking aid as

a weapon.

29. Officer Lolotai knocked Mr. Lawrence’s walking aid away and then took Mr.

Lawrence to the ground and handcuffed him. Mr. Lawrence, even when Officer Lolotai used

violent and unreasonable force to unlawfully arrest him, never used his walking aid in any

threatening or even defensive manner.

30. Mr. Lawrence suffered injuries, which included visible scrapes and abrasions to his

legs, as a result of Officer Lolotai’s violent arrest. Medical personnel were called to the scene of

the arrest and Mr. Lawrence was later taken to the hospital before he was taken to the jail. Mr.

Lawrence was booked into the jail and eventually released on the same day.

6
 Case 1:21-cv-00761 Document 1 Filed 03/15/21 USDC Colorado Page 7 of 17

B. Mr. Lawrence Is Subject to Bogus Criminal Charges.

31. On information and belief, Defendants worked with the Boulder County District

Attorney’s Office to level bogus charges against Mr. Lawrence so as to justify his false arrest.

32. Specifically, Mr. Lawrence was charged with obstruction of a peace officer in

violation of C.R.S. § 18-8-104(1)(a) and resisting arrest in violation of C.R.S. § 18-8-103.

33. Mr. Lawrence secured legal representation from a prominent Denver civil rights

law firm, which filed numerous motions challenging the legality of Defendants’ conduct.

34. In approximately November 2019, the parties agreed that rather than have the

Boulder District Attorney’s Office continue its prosecution, Mr. Lawrence would agree to a

diversion program with minimal requirements and the criminal case would be dismissed.

35. Less than four months later, by order dated March 23, 2020, the charges against

Mr. Lawrence were dropped.

C. Boulder Conducts a Whitewash Internal Investigation.

36. After members of the public and Mr. Lawrence himself spoke out against this

unlawful and violent arrest at Boulder City Council meetings, Boulder’s City Council requested a

third-party investigation. The investigation was not of the legality of the arrest itself, however.

The investigation was reportedly “to determine whether the [police] department followed

procedures properly when deciding not to open an internal affairs investigation” regarding Mr.

Lawrence’s arrest. 2

2Shannon Allobaugh, Special Counsel’s Independent Review of the April 5, 2019 Police
Incident, BOULDER POLICE (Jun. 25, 2019),
https://www.boulderpdapp.com/news/c/0/i/35082146/special-counsels-independent-review-april-
5-2019-police-incident.

7
 Case 1:21-cv-00761 Document 1 Filed 03/15/21 USDC Colorado Page 8 of 17

37. The investigators did not speak to Mr. Lawrence, despite the fact that he had legal

representation and wished to speak to the investigators.

38. Instead, the investigators whitewashed the incident, and relied, upon information

and belief, only upon information BPD provided.

39. The investigation concluded, inter alia, that BPD’s decision not to open an

investigation was consistent with Boulder’s policies and practices. 3

40. The BPD accepted and adopted the investigation’s results, and on information and

belief, concluded that Officer Lolotai’s actions complied with relevant BPD policies. In so doing,

BPD’s chief policymakers ratified Officer Lolotai’s specific unconstitutional actions, as well as

the reasons for those actions, as official City of Boulder policy.

D. The City of Boulder Knew of and Condoned Officer Lolotai’s Pattern of Wrongful
Conduct.

41. Officer Lolotai has a checkered past well known to BPD well before his illegal

arrest of Mr. Lawrence.

42. Officer Lolotai was under investigation for inappropriate use of force as a Denver

Sheriff’s Department deputy when BPD hired him. At the time, on information and belief BPD

knew of the ongoing investigation of then-Deputy Lolotai, but hired him approximately a month

after he resigned from the Denver Sheriff’s Department in June 2016. Officer Lolotai is reported

to have “quit[] as a Denver deputy before he could be disciplined.”4

3 Id.
4Michael Roberts, Controversial Past of Boulder Cop and Ex-Footballer Sued for Shoving
Woman, WESTWORD (May 29, 2019), https://www.westword.com/news/controversial-past-of-
waylon-lolotai-boulder-cop-and-ex-footballer-sued-for-shoving-woman-11354481.
8
 Case 1:21-cv-00761 Document 1 Filed 03/15/21 USDC Colorado Page 9 of 17

43. Upon information and belief, BPD, with knowledge of the investigation, chose not

to provide any remedial training after it hired Officer Lolotai, and thus ratified his use of force. 5

44. After joining the BPD, Officer Lolotai’s pattern of excessive force continued.

45. For example, On August 26, 2018, Officer Lolotai arrested Michele Rodriguez

while she was attempting to call a supervisor with the BPD. Officer Lolotai and other members of

the BPD contacted Ms. Rodriguez and other individuals sitting outdoors, claiming there was an

open alcohol container. Video footage of Officer Lolotai’s encounter rev eals that Ms. Rodriguez

was seated with no open alcohol containers in her vicinity. Officer Lolotai unlawfully ordered Ms.

Rodriguez to sit down, and Ms. Rodriguez asked why she needed to sit down if she was not under

arrest. Officer Lolotai told Ms. Rodriquez she was being detained. Ms. Rodriguez asked Officer

Lolotai why she was being detained, and repeatedly asked Officer Lolotai to call his sergeant.

When Officer Lolotai refused to call his sergeant, Ms. Rodriguez pulled out her cell phone and

said “I’m going to call 911. Is that alright?” Ms. Rodriguez was unlawfully told “No, we’re already

here.” Ms. Rodriguez told Officer Lolotai “I need protection from you guys,” and attempted to dial

on her phone while she remained seated. Officer Lolotai then told Ms. Rodriguez, “that’s it, you’re

going to jail,” slapped the phone out of her hands, and grabbed her by the arms. Officer Lolotai

and his colleague forced Ms. Rodriguez to the ground and forced her into handcuffs as she

continued to ask to call 911, continued to ask, “why are you doing this to me?” and told the officers

they were hurting her arms with the force they were using. To justify the arrest, Officer Lolotai

falsely charged Ms. Rodriguez with obstructing a peace officer and resisting arrest.

5 Id.

9
 Case 1:21-cv-00761 Document 1 Filed 03/15/21 USDC Colorado Page 10 of 17

46. The BPD failed to discipline, train, or adequately supervise Officer Lolotai after

this incident.

47. In addition to participating in excessive force, Officer Lolotai actually promotes it

on social media. Officer Lolotai made a series of social media posts called “Use of Force Fridays”

which celebrated instances of police brutality against civilians. The Boulder Police Department

placed Officer Lolotai on administrative leave when members of the public created an online video

that displayed Officer Lolotai’s more egregious activities in which he celebrated law enforcement

personnel’s use of force, available online at https://www.youtube.com/watch?v=hN8t-wzh93c.

Officer Lolotai’s social media “account’s own comments celebrate images of force, such as an

officer pepper spraying a photojournalist in the face at close range.” 6

48. An internal investigation determined Officer Lolotai’s social media activity

violated BPD policy, but BPD allowed Officer Lolotai to resign before he faced any discipline as

a result of his online activities.

49. Notwithstanding this pattern of abusive conduct, City of Boulder leadership has

doggedly defended Officer Lolotai, ratifying his wrongful conduct as official BPD policy. For

example, Boulder City Attorney Tom Carr has repeatedly made public defenses of Officer Lolotai,

such as statements that he is “an excellent officer who does a great job,” while Council Member

Mary Young described Mr. Lawrence’s speaking tearfully to Council about his arrest as “quite a

bit of theater.”

6Shay Castle, Boulder police officer under investigation for social media posts, BOULDER BEAT
(Aug. 7, 2020), https://boulderbeat.news/2020/08/07/boulder-police-lolotai-paid-leave-social-
media/.

10
 Case 1:21-cv-00761 Document 1 Filed 03/15/21 USDC Colorado Page 11 of 17

50. In addition to the above statements in support of Officer Lolotai’s violent actions

in the community, Boulder Chief of Police Maris Herold, upon Officer Lolotai’s resignation, also

made a supportive public statement about Officer Lolotai, sharing that “I believe Officer Lolotai

is a skilled police officer who has the potential to make a positive difference in policing, . . . I wish

him the best as he seeks new employment.” 7

E. The City of Boulder Has a Policy and Custom of Disregarding the Rights of
Citizens During Police Encounters.

51. The City of Boulder has a widespread practice amounting to a custom and policy

of unlawfully arresting and applying excessive force to persons for questioning the directions of

police officers, refusing to comply with voluntary interview requests, recording officers’ conduct,

and otherwise exercising their First Amendment Rights.

52. The City of Boulder has failed adequately to train its police officers in the

appropriate way to respond to persons who question the unlawful directions of police officers,

refuse to comply with requests to stop recording or observing police activities, an d otherwise

exercise their First Amendment Rights, including but not limited to failure to train BPD officers

in appropriate ways to deescalate conflict.

53. The City of Boulder’s policies, customs, and practices in failing properly to train

and supervise its employees are a proximate cause of the violations of Plaintiff’s constitutional

rights alleged in this Complaint.

7 Brooklyn Dance, Boulder police officer Waylon Lolotai leaves department, DAILY CAMERA
(Sep. 10, 2020), https://www.dailycamera.com/2020/09/10/boulder-police-officer-waylon-
lolotai-leaves-department/.

11
 Case 1:21-cv-00761 Document 1 Filed 03/15/21 USDC Colorado Page 12 of 17

54. The City of Boulder maintains or has maintained other internal policies that

encourage its police officers to make bogus arrests. For example, the City of Boulder currently

has or has had a policy of rewarding BPD officers with favorable annual performance evaluations

if the officers make more arrests, with no assessment as to whether those arrests are proper, and

punishing officers with unfavorable performance reviews if they make fewer arrests. That policy

tacitly encourages officers to make false arrests.

55. The City of Boulder ratified the actions of Officer Lolotai in this case in violation

of Mr. Lawrence’s rights when the highest policy making officials for the City of Boulder reviewed

those actions and determined that they were consistent with BPD policy and training.

56. The City of Boulder has been put on notice multiple times in the last several years

of its illegal policy and custom of unlawfully arresting and applying excessive force to persons for

questioning the unlawful directions of police officers, recording officers’ conduct, and otherwise

exercising their First Amendment Rights. It remains deliberately indifferent to its police of ficers’

routine violation of persons’ First and Fourth Amendment rights as described in this Complaint.

57. In addition to the incidents above, for example, on December 28, 2018, a BPD

officer unlawfully arrested Jedon Kerr, applying excessive force during the arrest although Mr.

Kerr was complying with the commands given to him. The arresting BPD officer shoved his knee

into Mr. Kerr’s back until Mr. Kerr screamed in pain. The unlawful arrest was in retaliation for

recording outside of the Boulder County Jail and refusing to provide identification upon request

to a BPD officer. Mr. Kerr was booked into the jail, but then released with no charges filed.

F. The Boulder Police Department’s Own Policies Recognize the Right to Film In
Public.

12
 Case 1:21-cv-00761 Document 1 Filed 03/15/21 USDC Colorado Page 13 of 17

58. The Boulder Police Department Policies & Procedures Manual General Order 103-

1(C) states that “[n]ews media representatives are allowed access to public locations from which

they may take photographs or recordings.” By recording Officer Lolotai at Mapleton Ballfields,

Mr. Lawrence was news gathering, in a public forum, information of concern to the public.

Because the Boulder Police Department’s policies explicitly provide media access to public spaces

to record and photograph, Officer Lolotai had actual knowledge of Mr. Lawre nce’s First

Amendment right to film him as he executed his public duties.

59. Further, the City of Boulder’s own obstruction ordinance limits an officer from

lawfully ordering an observer such as Mr. Lawrence any further away than eight feet from the

officer. Supra n.1.

FIRST CLAIM FOR RELIEF

42 U.S.C. § 1983 – First Amendment Free Speech
(Plaintiff Lawrence Against Both Defendants)

60. Plaintiff incorporates here by reference all of the preceding paragraphs.

61. At all times relevant to this Complaint, Defendant Lolotai was acting under color

of law.

62. Mr. Lawrence lawfully exercised his First Amendment right to video record the

police in a public forum at a public park.

63. Defendant Lolotai’s unlawful arrest of Mr. Lawrence and unreasonable use of force

against Mr. Lawrence were motivated by and in retaliation for Mr. Lawrence exercising his First

Amendment rights.

13
 Case 1:21-cv-00761 Document 1 Filed 03/15/21 USDC Colorado Page 14 of 17

64. Defendant Lolotai’s arrest of Mr. Lawrence and unreasonable use of force against

Mr. Lawrence would deter a person of ordinary firmness from engaging in similar expressive

activity.

65. At the time Defendant Lolotai arrested Mr. Lawrence, Defendants had no probable

cause to make the arrest.

66. Defendant Lolotai’s conduct violated clearly established rights belonging to Mr.

Lawrence of which reasonable persons in Defendant Lolotai’s position knew or should have

known.

67. Defendant Lolotai engaged in this conduct intentionally, knowingly, willfully,

wantonly, maliciously, and in reckless disregard of Plaintiffs’ constitutional rights.

68. Defendant Lolotai acted pursuant to the custom, policy, or practice of Defendant

City of Boulder, which condones, tolerates, and ratifies unreasonable use of force by its law

enforcement officers against those exercising First Amendment rights.

69. Defendant City of Boulder was aware of repeated unlawful arrests and

unreasonable use of force by Defendant Lolotai specifically, and by its law enforcement officers

generally, against those exercising First Amendment rights, and failed to properly train or

discipline its employees for such retaliation.

70. Defendant City of Boulder knew, or should have known, that their employees

would use unreasonable force and unlawful arrests against those exercising First Amendment

rights, violating their constitutional rights.

14
 Case 1:21-cv-00761 Document 1 Filed 03/15/21 USDC Colorado Page 15 of 17

71. Defendant City of Boulder’s policies, customs, or practices condoning its

employees’ unlawful arrests and unreasonable use of force were the moving force and proximate

cause of the violation to Mr. Lawrence’s constitutional rights.

72. Defendants’ unlawful arrest and use of unreasonable force caused injuries to Mr.

Lawrence in amounts to be proved at trial.

SECOND CLAIM FOR RELIEF

42 U.S.C. § 1983 – Fourth Amendment Unlawful Arrest
(Plaintiff Lawrence Against Both Defendants)

73. Plaintiff incorporates here by reference all of the preceding paragraphs.

74. At all times relevant to this Complaint, Defendant was acting under color of law.

75. Mr. Lawrence was arrested without probable cause for his arrest or any other valid

legal basis for his arrest.

76. Defendant Lolotai did not at any time have a reasonable basis for believing Mr.

Lawrence would use force or in any way obstruct, impair, or hinder Defendant’s enforcement of

the law.

77. Defendant Lolotai did not at any time have a warrant authorizing any search,

seizure, or detention of Mr. Lawrence’s body or belongings.

78. At the time when Defendant Lolotai arrested Mr. Lawrence without probable cause,

Mr. Lawrence had a clearly established constitutional right under the Fourth Amendment to the

United States Constitution to be secure in his person from unreasonable searches and seizures.

79. Defendant Lolotai acted pursuant to the custom, policy, or practice of Defendant

City of Boulder, which condones, tolerates, and ratifies its employees’ continued arrests lacking

in probable cause.

15
 Case 1:21-cv-00761 Document 1 Filed 03/15/21 USDC Colorado Page 16 of 17

80. Defendant City of Boulder was aware of widespread continued arrests, which lack

probable cause, as detailed above, and failed to properly train or discipline its employees in

response to these arrests.

81. Defendant City of Boulder knew, or should have known, that their employees

would continue to effectuate arrests that lack probable cause.

82. Defendant City of Boulder’s policies, customs, and practices condoning its

employees’ continued arrests, which lack probable cause, were the moving force and proximate

cause of the violation to Mr. Lawrence’s constitutional rights.

83. Defendant Lolotai engaged in this conduct intentionally, knowingly, willfully,

wantonly, maliciously, and in reckless disregard of Mr. Lawrence’s constitutional rights.

84. Defendants’ unlawful arrest of Mr. Lawrence caused injury to him in amounts to

be proved at trial.

PRAYER FOR RELIEF

Plaintiff Sammie Leon Lawrence IV prays for judgment to enter in his favor, and an award

of all of the relief as allowed by law and equity, including but not limited to:

a. Actual economic damages including but not limited to for medical bills;

b. Compensatory damages for past and future pecuniary and non-pecuniary losses,

emotional pain, suffering, inconvenience, mental anguish, loss of enjoyment of

life, and other non-pecuniary losses;

c. Punitive damages for all claims as allowed by law in an amount to be

determined at trial;

d. Pre-judgment and post-judgment interest at the highest lawful rate;

16
Case 1:21-cv-00761 Document 1 Filed 03/15/21 USDC Colorado Page 17 of 17

e. Attorney’s fees and costs; and

f. Such other relief as justice so requires.

JURY DEMAND

Plaintiff demands a trial by jury on all issues so triable.

Dated this 15 th day of March, 2021.

__s/ Darren O’Connor______________

Darren O’Connor
Darren O’Connor, LLC
4450 Arapahoe Avenue, Suite 100
Boulder, CO 80303
Telephone: (720) 961-3869
DOLawLLC@gmail.com

___s/ Daniel D. Williams___________

Daniel D. Williams
Hutchinson Black and Cook, LLC
921 Walnut Street, Suite 200
Boulder, CO 80302
Telephone: (303) 442-6514
Facsimile: (303) 442-6493
williams@hbcboulder.com

Attorneys for Plaintiff

17