| Case 3:16-cv-30186-KAR Document1 Filed 12/06/16 Page 4of 9she was Case 3:16-cv-30186-KAR Document1 Filed 12/06/16 Page Sof936. Another basketball team staff member, Hogans, was outside the room by the door. Upon information and belief, Roe had called Hogans. 37. MBB had no way to extricate herself from the situation; three large men surrounded her and blocked the exit. 38. Before this incident, Roe had told about the use of banned substances by team members; domestic violence by certain staff members against family members; incidents of infidelity and quashing of potential criminal complaints against unidentified team members. 39. After the incident, Kellogg called a meeting of the entire staff and told them that nothing would be permitted to get out. 40. At all times pertinent to this complaint, Kellogg was the head coach of the UMass at Amherst basketball team. 41. At all times pertinent to this complaint, Ree, Chatman and Hogans were coaching staff members of the UMass at Amherst basketball team. COUNT I. (42 U.S.C. 1983) 42. TER repeats and realleges the averments contained in paragraphs 1 through 41 as if fully set forth herein. De Case 3:16-cv-30186-KAR Documenti Filed 12/06/16 Page Géof943. At all times pertinent to this complaint, Roe, Chatman, Hogans and Kellogg were acting under color of State law to deprive 9BMJof her civil rights guaranteed by the First and Fourth Amendments to the Constitution of the United States. 44, During the incident of December 7, 2013, Roe, Chatman and Hogans refused to let MBM out of an of they to which they had access as members of the coaching staff of the UMass at Amherst men’s basketball team. 45. The University of Massachusetts is a public university funded by the Commonwealth and operating under the laws of the Commonwealth. 46. oe, Chatman and Hogans refused to allow to leave because they intended to and did prevent her from disclosing information of public interest concerning the men’s basketball team, its players and its staff. 47, Kellogg encouraged and pi icipated in a cover-up of t concerning the incident with the intention of preventin: from disclosing information of public inter: the men's basketball team, its players and its staff. 48. Roe, Chatman and Hogans pursued their goal of dissuading BBM from disclosing information about the 5 basketball team by detaining her and her son in an a (Case 3:16-cv-30186-KAR Document Filed 12/06/16 Page 7 of 9Case 316-cv-30186-KAR Document Filed 1206/16 Page 7 of 9 office in a public building to which they had access use under esler of State law. 49. The suppression of speech about info public interest and the unlawful detention of MBMMn a public building by those in control of the premises deprived i and Fourth Amendments to the United States Constitution civil rights guaranteed by the First violation o £42 U.S.C. 1983. 50. The actions of the defendants as set forth above in paragraphs 42 to 49 causedMMMMMgreat fear for herself and her sony reasonable apprehension that she would be subjected to another incident of domestic violence without any way te protect herself: and great trepidation that the defendants would continue to target her to prevent her from disclosing inf ation of great interest to the public COUNT IT. (G.L. ¢. 12, §11H and $111) $1. BEM repeats and realleges the averments contained in paragraphs 1 through 41, paragraphs 44 through 48 and paragraph 50 as if fully set forth herein. 52. The suppression of speech about info: ion of public lawful detention of IM in a public building by those in control of the premises interest and the u a Case 3:16-cv-30186-KAR Document1 Filed 12/06/16 Page B of 9a Case 216-cv-30186KAR Document Filed 1206/16 Page 8 of 9 deprived BE of and Fourth Amendwents the United States Con nade applicable to the States by bh Amendment 2 Fourteen of the United States Constitution, and quar: teed by Articles 14 and 16 of the Declaration of Rights to the Constitution of the Commonwealth. deprived Qo ber right liberty and her right to £ 53. The defenda speech through ¢ threats, intimidation and coercion all as aforesaid. pears averments contained realleges t! in paragraphs 1 through 41, paragraphs 44 paragraph set forth herein 55. At all times pertine: is complaint, Roe, Chat ed EE co ene tognent of ED ves yntew becuse BEB cnsuccesstunty « take her son with her when she attempted to leave, ntentiona! and Hogans 56. Their eo: + especially mpted to leave and to 57. At all times pertinent to this complaint, SD was conscious that she was being confined against her will and despite her protests. nfinenent injured MMMM as set forth in paragraph 50, above. 58. The « LS Case 316-cv-30186-KAR Document Filed 12/06/16 Page 9 of 9Case 3:16-cv-30186-KAR Document1 Filed 1296/16 Page 9o! 9 wuzrerors, EBD Gemands judgment against ne defendants, in such amount as the c jeems further asks the court for ther and rther relief as the court may deem just. JURY DEMAND. HE cecands a tr triable,