"Plaintiff is informed and believes that at about the time defendant Officer Martinez inflicted the second drive-stun Taser shot to plaintiff Roland Haas' lower back, defendant Officer Inman, with great and excessive force, wrenched plaintiff Roland Haas' left arm behind his back in such a manner as to cause plaintiff to suffer a shoulder sprain and great pain in his left shoulder and arm, and proceeded to place a handcuff on plaintiff's left wrist."
While he was stunned, facedown and handcuffed, Haas says, "Sgt. Brian Williams again ordered Officer Martinez to inflict a third drive-stun Taser shot to plaintiff Roland Haas' body. At that time, defendant Officer Martinez did inflict a third drive-stun Taser shot to plaintiff Roland Haas' lower back causing plaintiff to suffer additional great bodily injury and severe pain and to scream as a result of such pain.
"Plaintiff is informed and believes that while the Police Officers continued to maintain control over plaintiff Roland Haas and hold plaintiff face down on the floor and while plaintiff Roland Haas' left wrist was secured in a handcuff and held behind his back, defendant Sgt. Brian Williams or one of the other Police Officers ordered defendant Scott Blasser or one of the other EMS Paramedics to inject plaintiff Roland Haas with a tranquilizer. At that time and without plaintiff Roland Haas' consent and despite plaintiff Roland Haas' specific statement that he was refusing medical assistance and treatment, defendant Scott Blasser and/or one of the other EM paramedics, with the use of a hypodermic syringe inflicted an unauthorized 5 mg intramuscular injection of the potent Food and Drug Administration regulated drug Midazolam (Versed) on plaintiff Roland Haas.
"Plaintiff is informed and believes that the drug Midazolam (Versed) is a highly potent Food and Drug Administration regulated drug in the benzodiazepine class which is typically used for inducing sedation and amnesia before authorized surgeries are performed on hospital patients.
"After attaching, restraining and seizing plaintiff Roland Haas, and after he had been subjected to no fewer than 3 drive-stun Taser shots and an unconsented-to injection of a potent tranquilizer and after he had been placed in handcuffs behind his back, such that plaintiff Roland Haas was fully restrained and under the control of the Police Officers, the police officers placed shackles on plaintiff Roland Haas' ankles, thereby rendering him hobbled.
"After plaintiff Roland Haas had been tackled, restrained, seized, handcuffed, drive-stun Tasered three times, injected with a tranquilizer, and hobbled, the police officers and EMS paramedics forced plaintiff Roland Haas onto an ambulance gurney, placed additional restraints upon his body and placed him inside an ambulance in order to transport plaintiff to Barton Memorial Hospital. Thereafter, the EMS paramedics, accompanied by Officer Inman, transported plaintiff Roland Haas about 100 feet by ambulance to the Barton Memorial Hospital Emergency Room.
"Plaintiff Roland Haas remained restrained and seized by the police officers at the Barton Memorial Hospital Emergency Room while being examined by nurses and doctors at the hospital until such time that he was discharged by a doctor at the hospital. It took the medical staff at Barton Memorial Hospital no more than about 13 minutes from the time plaintiff was brought to the Emergency Room to discharge him."
But it still wasn't over. Haas says police forced him to stay there "to await an evaluation by a representative from the El Dorado County Department of Mental Health." He says the mental health worker determined that he was not "in any way a danger to himself or others," and cleared him to go.
In a final irony, Haas says, he had to return to the hospital that night because of the pain he suffered from the police beating.
He says the hospital diagnosed him with "a left shoulder sprain, pain, an abrasion to his left wrist, and several wounds to his lower back, all of which were the result of having been attacked, restrained and Tasered by the police officers while at the Under the Magic Pine Tree pre-school."
Haas adds: "During the period of time that the police officers were attacking, restraining and seizing plaintiff Roland Haas and had him pinned face down to the floor and under their control and were subjecting him to repeated drive-stun Taser shots and an unconsented tranquilizer injection, plaintiff Roland Haas on multiple occasions asked the police officers why they were doing this to plaintiff and at no time did any of the police officers advise plaintiff as to why he was being attacked by the police officers and subjected to repeated drive-stun Taser shots and an unconsented-to injection of a tranquilizer.
"At no time relevant herein did any of the police officers advise plaintiff Roland Haas that he was under arrest, that he had committed a crime, that he was under any sort of investigation, that he was endangering others, or that any of the conduct weapon, and in fact, at such time, plaintiff Roland Haas was unarmed and did not possess any weapon of any sort and the defendants were fully aware of this.
Haas seeks medical costs - including the $1,500 ambulance ride across the street - and punitive damages for excessive force, constitutional and civil rights violations, depriving him of the right to refuse medical treatment, municipal/supervisory liability, medical malpractice, assault and battery, medical battery, and false imprisonment.
He is represented by Edward Rizzuto, with Stewart Humpherys Mollin & Griffith, of Chico.
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