CLIP was launched by City Councilwoman Joan Krajewski in April 2002 as "a campaign to target 'quality of life' code violations, such as graffiti, vandalism, and property neglect, as part of a broader policy agenda known as the Neighborhood Transformation Initiative (NTI)," Tengood says in his complaint.
"The NTI was an aggressive plan to combat blight in distressed Philadelphia neighborhoods."
Using city-owned tools, cameras and vehicles, code-enforcement officials entered least six homes "over the course of several years" without consent and proceeded to "systematically" steal valuables, Tengood says.
"Once inside the homes, the conspirators systematically stole items of value from the premises. In the most egregious instances City trucks were actually driven to the target homes and their contents removed en masse: televisions; dining room furniture sets; floor safes; silver flatware settings; clothing; family heirlooms; and several large gun collections," the complaint states, citing the Grand Jury report.
"The scheme was comprehensive in scope and specifically designed to intimidate, rob, and/or extort money and property from select residents of the northeast section of the City," Tengood says.
And as if plundering the homes were not enough, the cooked-up violations "were served together with fraudulent or inflated bills for municipal services deemed necessary to remedy the violations," according to Tengood's complaint.
He claims the scheme was a cooperative effort among multiple city departments and "sub-departments," including the Mayor's Office of Community Services, the Solicitor's Office, the Department of Licenses & Inspections and the Department of Streets.
Perpetrators ranged "from lower level inspectors, to program managers, and up through to the executive tier," Tengood claims.
"The corruption of [chief CLIP code enforcer] Sicinski began in or about February 2004 when he first used his position as a CLIP inspector to gain entry to a private residence and to steal personal property," Tengood says.
The resident of the home reported to police that his briefcase and the $900 inside it went missing immediately after Sicinski was inside the house, according to the complaint.
"Following an inquiry by detectives ... it was determined that Sicinski did in fact have ... [the man's] briefcase," the complaint states. "Sicinski claimed he had found the briefcase in the trash outside an abandoned building near 1313 Unruh Street - however, photographs that were taken on the say of the theft to do depict any such trash surrounding the property.
"Some time after the briefcase theft Sicinski began formulating a plan to expand upon the basic modus operandi he established at 1313 Unruh Street. He set out to recruit other CLIP inspectors and crew members to help him identify and target additional victims throughout the Northeast. It was Sicinski's intention, through coercion and enticement, to compromise the integrity of Elia, among others, and thereby secure her participation in a more comprehensive scheme involving various illegal activities, including extortion, theft, and the illicit acquisition and sale of firearms, all built upon the Unruh model." (Citation to Grand Jury report omitted.)
The complaint continues: "Upon information and belief, Sicinski, [Roseanne] Elia, and other CLIP employees thus began developing a profile to serve as the basis for selecting targets of their scheme. Sicinski and Elia compiled this profile based on their prior work in the field as CLIP inspectors, having become familiar with numerous homes and their residents throughout the Northeast.
"Sicinski and Elia (and later [Martin] Higgins) began devoting additional time and resources (including but not limited to City owned vehicles, cameras, and tools) to travel throughout the Northeast with the specific purpose of conducting supplemental observations of particular properties/residents in order to hone in on ideal targets for the scheme. These observations were carried out with impunity, under the convenient guise of performing their day-to-day responsibilities as CLIP employees.
"Their accumulated experience and observations enabled them to develop an ideal profile for the types of people and properties on which to focus their scheme, namely: (1) elderly and/or disabled persons, preferably living alone; (2) at addresses situated within a roughly sixteen square mile (16 mile2) section of the Northeast bounded by Red Lion Road to the North and Bridge Street to the South, and between Interstate 95 to the East and Algon Avenue to the West; (3) with an apparent quantity of personal possessions kept in their homes. See Map incorporated herein and attached hereto as Exhibit 'C'.
"One additional target was identified at an address outside of the aforementioned geographic area at 2911 Boudinot Street. The owner of that property, Mr. John Owens, nevertheless fit the target profile in all other respects.
"After identifying their targets Sicinski and/or Elia would go the property and conduct a more detailed assessment, relying on undocumented, fabricated or exaggerated code violations to convince the inhabitants to permit them to inspect the perimeter of the property or enter inside the home. Once inside, Sicinski and/or Elia would go through the property and identify items of value, taking note of their exact location in and around the house.
"In instances where they were restricted, for whatever reason, to the outside areas of the property they would survey the inside of the house and its contents through the house's windows.
"Sicinski and/or Elia would then communicate the intelligence they gathered to CLIP clean-up crew members who would return (with or without Sicinski and/or Elia) to the property shortly thereafter, to seize the items. Seizure was effected based on the flawed rationale that removal of the items was necessary to remedy the code violations that Sicinski and or Elia had fabricated in the first place.
"The seized items were then divided amongst the conspirators to be sold for cash or kept for personal use."
Tengood sued the City of Philadelphia for violations of civil rights and federal racketeering law, malicious prosecution, negligence, conversion, invasion of privacy and trespass.
He also sued under the Americans with Disabilities Act, claiming the city targeted him because it believed he was a hoarder suffering from obsessive-compulsive disorder.
Also named as defendants, individually and in their official capacity, are Thomas Conway, as CLIP co-director; Rycharde Sicinski, as CLIP's chief code enforcer; Martin Higgins, as CLIP inspector; Roseanne Elia, as CLIP inspector; and Beverly Penn, as a deputy chief solicitor.
Tengood is represented by Joshua Upin with TKS Legal Services in Philadelphia.
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