Case 1:23-cv-03192 Document 1 Filed 10/25/23 Page 1 of 52

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

RADCLIFFE MANYAN, SR.,

as next of kin and as the Co-Personal
Representative of the Estate of Maurica
Alex Manyan
4720 Quimby Avenue,
Beltsville, MD 20705

SHERENE MANYAN,
as next of kin and as the Co-Personal
Representative of the Estate of Maurica
Alex Manyan
4720 Quimby Avenue,
Beltsville, MD 20705
CIVIL ACTION NO.:
TO THE USE OF DAVID BARRINGTON
HARRIS, JR.
Next Friend and Father of Son D.M., next of
kin
2442 Martin Luther King, Jr., SE, Apt. 517
Washington, DC 20020-5816

Plaintiffs,

v.

DISTRICT OF COLUMBIA
a municipal corporation
441 Fourth Street, NW
Washington, D.C. 20001
Serve on:
MAYOR MURIEL BOWSER
Office of Mayor
1600 Pennsylvania Avenue, NW
Washington, D.C. 20001
Designee:

OFFICE OF THE ATTORNEY GENERAL

Brian Schwalb
District of Columbia
441 Fourth Street, NW
Washington, D.C. 20001

and
 Case 1:23-cv-03192 Document 1 Filed 10/25/23 Page 2 of 52

JESSE PORTER, JR.

1217 Upshur St., NE,
Washington, DC, 20017-3831

and

PORTER CONSULTING AND EXPERT

TACTICAL TRAINING, LLC
1200 G Street NW, Suite 800
Washington, DC, 20005
Serve On:
Jesse Porter, Jr.
1217 Upshur St., NE,
Washington, DC, 20017-3831

600 Ava Circle NE

Washington, District of Columbia, 20017

and

ANTHONY MICKENS
3310 Croffut Pl SE
Washington, DC 20019

and

BYRON PURNELL
5002 Hayes Street, Northeast
Washington, DC 20019

Defendants.

COMPLAINT AND DEMAND FOR JURY TRIAL

Plaintiffs, RADCLIFFE MANYAN and SHERENE MANYAN, individually and in their

capacity as the co-personal representatives of the Estate of Maurica Alex Manyan, and David

Harris, as father and next friend of D.M., file this action under the Survival Act of the District of

Columbia, codified as D.C. Code § 12-101 for claims of wrongful death, negligence, gross

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negligence and related claims arising out of the August 4, 2022 shooting death of their daughter,

Officer Maurica Alex Manyan.

INTRODUCTION

1. This is an action for money damages brought under the of the District of Columbia, the

Constitution of the United States, and various applicable federal laws against the named

defendants in this action.

2. These claims arise out of the unlawful and tortious actions of Jesse Porter, Jr., Anthony

Mickens, various members of the Metropolitan Police Department; and, ranking officials

of the government of the District of Columbia.

3. It is alleged that Jesse Porter, Jr., individually and as a representative of his company, Porter

Consulting and Expert Tactical Training LLC and as an agent of the District of Columbia,

Anthony Mickens (former Special Police Officer with the District of Columbia Public

Library) and Byron Purnell (Metropolitan Police Department, Sgt.), sued in their individual

and official capacities, while engaged in an employment contract with the District of

Columbia and at the behest and sanctioning of the District of Columbia Public Library

Special Police Force and for the benefit of the District of Columbia, fatally shot Maurica

Manyan after the completion of an ASP baton training session, unreasonably and

unlawfully seizing her and thereby violating her rights protected by the United States

Constitution as well as the laws of the District of Columbia and federal statutes.

4. It is further alleged that the Defendant, District of Columbia, despite having a substantial

history of complaints against its permitting live and loaded firearm(s) and ammunition in

training sessions and failing to provide adequate security and adequate security measures

at the Anacostia Library, located at 1800 Good Hope Road, Southeast, Washington,

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District of Columbia (Anacostia Neighborhood Library) where Mr. Porter was permitted

to carry a live and loaded firearm(s) (a handgun) against the laws of the District of

Columbia prohibiting live and loaded firearm(s) in the Library/ building/training sessions;

whereupon Defendant Porter fatally shot Maurica Manyan.

5. It is further alleged that the District of Columbia failed to implement measures to ensure

persons were not permitted access to the Anacostia Library with firearm(s), ammunition,

or weapons of any sort and maintained a pattern and practice, over the objections of special

police officers subjected to training, of actually allowing trainers to keep on their person

live and loaded firearm(s) and ammunition in the training building.

6. It is further alleged that the District of Columbia promulgated and maintained a policy and

had a well-known common practice of permitting police officers and former police officers,

including Jesse Porter, Jr., to carry handguns, ammunition, and weapons in training

sessions (despite the laws of the District of Columbia prohibiting same); and also, that

policy included the carrying of handguns, ammunition, and weapons past library security

and into the Anacostia Library demonstrating a deliberate indifference to the life and safety

of its library patrons, including Ms. Manyan. This well-known practice and policy created

a state of danger for Ms. Manyan at all relevant times and was officially adopted and

promulgated by police officers and high-level officials in the District of Columbia.

7. It is further alleged that the Defendant, District of Columbia, by and through the Mayor of

the District of Columbia failed to properly train, supervise and otherwise enforce District

of Columbia laws and Library Special Police Department policies or Metropolitan Police

Department Policies and investigate/follow-up public complaints of malfeasance from

other citizens of the District of Columbia prior to and after the incident complained of in

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this case. The District of Columbia is categorized as a local government and is responsible

for the actions of Defendants, their agents, contractors, servants and/or employees, and is

a fully operational government. At all times relevant herein, these Defendants were

responsible for the actions and omissions of their police officers with respect to the events

detailed herein. These Defendants are responsible for the events descried herein because

they did not have adequate practices and procedures for monitoring, planning, conducting

and communicating with other agencies with respect to firearm(s) free training exercises

with regard to protecting officers and trainees and assessing and communicating with other

law enforcement agencies regarding training exercises, including their location and the

prohibition on having live and loaded weapons at training exercises.

PRE-SUIT REQUIREMENTS

8. Plaintiffs have satisfied the requirements of the Federal Tort Claims Act; D.C. Code § 12-

309; by serving a proper notice of claim upon the District of Columbia within six months

of the complained of incident; and again, on or about September 7, 2023. Additionally, a

report was written within the regular course of business, documenting this incident by a

Metropolitan Police Department officer. It was made public on or about August 5, 2022.

9. Plaintiffs have satisfied any pre-suit requirement to file their claim with the appropriate

federal agency under 28 U.S.C. § 2675 on or about September 7, 2023 prior to bringing

this action in the United States District Court for the District of Columbia.

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JURISDICTION AND VENUE

10. Jurisdiction is proper under 28 U.S.C. § 1331, §1343 and 42 U.S.C. §§ 1983, 1985, and

1988; as well as pursuant to D.C. Code § 11-921; and the 4th and 5th Amendments to the

United States Constitution.

11. Venue is proper in the United States District Court for the District of Columbia under 28

U.S.C. § 1391 in that Defendants reside in the District of Columbia and all Defendant

Officers worked in the District of Columbia at the time of the events alleged herein; their

employer, the District of Columbia, Anacostia Neighborhood Library and Porter

Consulting and Expert Tactical Training LLC, are also located in the District of Columbia.

The actions complained of occurred in the District of Columbia.

PARTIES

12. At all times relevant hereto, Plaintiffs Radcliffe Manyan, Sr., and Sherene Manyan, are the

natural father and mother (respectively) of Maurica Manyan, a former District of Columbia

Public Library Special Police Officer shot and killed by Jesse Porter, Jr. Plaintiffs Radcliffe

Manyan, Sr. and Sherene Manyan suffered emotional distress, physical injury, loss of

reputation, loss of filial relationships, suffered loss of support and companionship, and will

continue to suffer financial hardship with the loss of their daughter, upon whom they were

financially dependent. Plaintiffs bring the following action in their individual capacity and

in their capacity as personal representatives of the Estate of Maurica Manyan; and who bring

this action under the District of Columbia Survival Act, D.C. Code § 12–101 and under the

District of Columbia Wrongful Death Act, D.C. Code § 16-2701. Both Radcliffe Manyan Sr.

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and Sherene Manyan received maintenance and assistance from Maurica Manyan and would

have continued receiving maintenance and assistance had she lived.

13. At all times relevant hereto, Plaintiff D.M., a minor child, is the natural and biological son of

Maurica Manyan (deceased). Plaintiff D.M. suffered emotional distress, physical injury, loss

of reputation, loss of filial relationships, suffered loss of support and companionship, and will

continue to suffer financial hardship with the loss of his mother, upon whom he was

financially dependent. Plaintiff brings this action in his individual capacity through his

biological father, David Barrington Harris, Jr., Next Friend and Father of D.M., pursuant to

the District of Columbia Wrongful Death Act, as a primary beneficiary, D.C. Code § 16–

2701. Minor child D.M. received maintenance and assistance from Maurica Manyan and

would have expected to continue receiving maintenance and assistance had she lived.

14. At all times Defendants District of Columbia is a municipal corporation; of which the District

of Columbia Public Library is a sub-agency; it, along with Mayor MURIEL BOWSER and

the office of Mayor, are the entities that contracted with Jesse Porter, Jr. and Porter Consulting

and Expert Tactical Training LLC continuing a policy and practice of permitting armed

persons in the Anacostia Neighborhood Library, in violation of D.C. statute and local laws

and in training sessions despite being aware of prior complaints of the danger posed to trainees

permitting persons to enter the Library armed with firearm(s) and ammunition as well as prior

complaints of permitting trainers to conduct training session while carrying a live and loaded

firearm(s) and ammunition on their body. Their duties included the supervision, discipline

and training of Defendants Jesse Porter, Anthony Mickens, Byron Purnell, and other sworn

members of MPD and D.C. Public Library Police Force at the time of the events described

herein. Their responses to the reports of illegal and tortious activities of armed persons

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entering the Anacostia Neighborhood Library and complaints of persons being armed with

live and loaded firearm(s) and ammunitions at police training events was so inadequate or

nonexistent as to constitute deliberate indifference to or tacit authorization of the alleged

offensive practices. There was an affirmative causal link between the Defendants’ inactions

and Maurica Manyan’s fatal injuries and constitutional deprivations. Finally, the District of

Columbia controls, hires, fires, and directs the decision-making members of the Metropolitan

Police Department and the District of Columbia Public Library Special Police in the activities

complained of in this complaint. At all times, Defendant Douglas Morency worked as the

public safety director for the District of Columbia Public Library System; a 36-member police

force; having six police cruisers, and for which officers patrol 26 library branches throughout

the District of Columbia. Morency’s duties included the supervision of Defendants Porter,

Mickens, Purnell and other special police officers at the time of the events described herein.

To establish and implement safety responses to reports of illegal and tortious activities of

armed persons entering the Anacostia Neighborhood Library. Morency’s response to

complaints of persons being armed with live and loaded firearm(s) and ammunitions at police

training events was so inadequate or nonexistent as to constitute deliberate indifference to or

tacit authorization of the alleged offensive practices. There was an affirmative causal link

between the Defendants inactions and Maurica Manyan’s fatal injuries and constitutional

deprivations. Finally, Morency controls, hires, fires, and directs the decision-making

members of the public library system as to safety of the various library locations and all

patrons within and the Public Library Special Police in the activities complained of in this

complaint.

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15. At all times Defendant Jesse Porter, Jr. (“Porter”), the shooter, and Porter Consulting and

Expert Tactical Training LLC contracted with co-defendant District of Columbia and acted at

the behest of the District of Columbia when he fatally shot Marica Manyan upon being

permitted to enter and remain at the Anacostia Neighborhood Library armed with a loaded

firearm(s).

16. At all times, Defendant Anthony Mickens (“Mickens”) and Byron Purnell (“Purnell”) worked

with Porter on the day he fatally shot Ms. Manyan. Defendants Mickens and Purnell were

also sworn members of the Metropolitan Police Department (“MPD”) and/or the DC Public

Library (“DCPL”) Special Police at all relevant times and had a statutory obligation to “to

make arrests for offenses committed in their presence, D.C. Code § 5-115.03, and are in that

sense considered to ‘be always on duty, ‘” see District of Columbia v. Coleman, 667 A.2d

811, 818 n.11 (D.C. 1995). Both Mickens and Purnell acted as assistants to co-defendant,

Porter, and were regularly in close contact with Porter since the beginning of his work

relationship, which started at the MPD. Mickens and Porter were both expert, veteran trainers

and sworn members of a police agency. Public Records indicate that Mickens as of 2018 was

a special police officer with the District of Columbia Public Library. Both Purnell and

Mickens had a duty to stop Porter’s carrying of a live and loaded firearm(s) open and

notoriously before, during, and after the training session, but breached that duty by allowing

Porter to enter the library with a loaded firearm(s) which had no use at the training. Therefore,

there was no legitimate basis to allow a loaded firearm into the library.

FACTUAL BACKGROUND AND STATEMENT OF FACTS

I. THE DEFENDANTS’ PERMITTING UNLAWFUL WEAPONS INTO

DISTRICT OF COLUMBIA PUBLIC LIBRARIES AND TRAINING
SESSIONS IS A PART OF A WIDESPREAD AND WELL-KNOWN

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PATTERN AND PRACTICE OF ILLEGAL/DANGEROUS CONDUCT

SPANNING YEARS

17. The District of Columbia and all other defendants have known or should have known for years

that officers and former police officers given broad authority as sworn or former sworn

members of the Metropolitan Police Department and other special police agencies in the

District of Columbia engaged in a pattern or practice of illegal activities such as the ones

alleged in this complaint.

18. Despite actual or constructive knowledge of this pattern or practice, the District of Columbia

condoned misconduct committed by these persons by ignoring widespread abuses. Rather

than discontinuing the practice of entering public buildings, such as the Anacostia

Neighborhood Library, armed with firearm(s) and ammunition and other various weapons or

instituting meaningful reforms and supervision after numerous allegations and scandals, the

District of Columbia merely ignored the abuses periodically. And while the specific names

of the officers and former officers committing said abuse changed throughout the years, their

officers’ misconduct remained the same.

19. The conduct of the Defendant officers and former officers was at all times incidental to the

performance of the duties that the employer, be they employee or independent contractor,

entrusted to said defendants and was within the scope of their employment, and for the benefit

of their employers District of Columbia, the District of Columbia Public Library and/or the

Metropolitan Police Department. Furthermore, the other Defendants benefited from the

actions of the Defendants here.

20. Public records reflect that the District of Columbia library public safety department’s training

and development coordinator left in July of 2022.

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21. The public library contracted with Defendant Porter shortly thereafter. Porter was selected,

hired and paid to train the library police. The D.C. Public Library specifically hired Porter

Consulting and Expert Tactical Training LLC because of Porter’s training as a former

Metropolitan Police Officer.

22. Porter’s contract agreement with the Public Library, dated June 30, outlined specific training

Porter agreed to provide. It listed classes in use of force, de-escalation, the use of extendible

batons and handcuffing techniques. The contract did not provide for live and loaded

firearm(s) and ammunition training.

23. The contract also did not require Porter to adhere to the building policy prohibiting live and

loaded firearm(s) and ammunition on the building grounds or in the training session.

24. Prior to allowing Defendants to carry into and conduct training sessions with live and loaded

firearm(s) and ammunition, numerous complaints were made to personnel within the District

of Columbia Public Library agency with decision making authority, as well as to the

Washington D.C. Metropolitan Police Department with decision making authority, the

dangerous practice of having live and loaded firearm(s) and ammunition in training sessions.

Specifically:

a. On or about August 2020, Tiffany Hedgepeth complained specifically about the

dangerous practice of allowing live and loaded firearm(s), ammunition and other
deadly weapons in training sessions, such as the practice of Defendant Porter’s
carrying into and during a training session his loaded firearm(s) as complained of in
this complaint.

b. Prior to the incidents complained of in this Complaint Ancel Carter also complained
of the widespread and common practice of the District of Columbia’s permitting live
and loaded firearm(s) and ammunition in training sessions.

c. Prior to the incidents complained of in this Complaint Bonita Simpkons also

complained of the practice of permitting live and loaded firearm(s) and ammunition
in training sessions and into buildings for which it was prohibited by D.C. law to carry
live and loaded firearm(s) and ammunition into.

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d. Prior to the incidents complained of in this Complaint, the District of Columbia was
on specific notice of other recent, and locally well-publicized, cases of trainees being
shot during or after training session, by trainers, using live and loaded weapons
(firearm(s) and ammunition).

See https://www.nbcwashington.com/news/local/police-trainee-shot-in-maryland-
files-lawsuit/1964555/.

e. Prior to the incident complained of in this Complaint the District of Columbia Public
Library special police force was aware of well-publicized recent examples of the
dangers to police officer trainees where trainers were armed in training sessions, yet
continued a pattern and practice of permitting trainers to train with live and loaded
weapons on their person.

25. The District of Columbia was thus, on notice from at least the year 2020 of the potential for

abuse associated with allowing or permitting weapons, firearm(s), and ammunition inside the

Anacostia Neighborhood Library and live and loaded firearm(s) in police training sessions.

26. Around the same time, allegations surfaced regarding weapons inside the public libraries and

the District of Columbia’s practice and policy to permit sworn members and former sworn

members of local police agencies entrance into the public libraries armed with firearm(s),

ammunition and other weapons.

27. Despite being on specific notice of misconduct that plagued the public libraries and training

sessions, the District of Columbia continued to permit live and loaded firearm(s) and

ammunition in training sessions and failed to have and/or enforce a policy prohibiting same;

continued to permit the unauthorized access to the public libraries and failed to properly train

and establish policies prohibiting access to the public libraries by sworn members of the

District of Columbia Police agencies; established a pattern and practice of allowing armed

persons into the public libraries; continued a practice of allowing un-insured persons and

businesses such as Porter Consulting and Expert Tactical Training LLC to conduct training

sessions inside the public libraries, armed with firearm(s) and ammunition; and, continued a

pattern and practice in allowing persons armed with firearm(s) and ammunition, discovered

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inside the public libraries to remain in said library, creating a specific danger for persons like

Maurica Manyan and demonstrating a reckless disregard for the safety of Maurica Manyan.

28. Further, despite being on notice of the particular dangers of constitutional depravations to

trainees and other persons in the zone of danger, Defendants District of Columbia failed to

train the involved sworn members of the MPD and the Public Library Special Police Force

on the following:

a. Storing one’s live and loaded firearm(s) (weapon) in a safe place outside of the
training building before entering the building or entering the training space;

b. when to secure your own and verify that no person has a live and loaded firearm(s)
and ammunition in a training space;

c. prohibiting police officers and former police officers from having live and loaded
firearm(s) and ammunition in the public library;

d. when to report the use of or presence of live and loaded firearm(s) and ammunition
in the training space or building prohibiting same;

e. prohibiting police officers and former police officers from having live and loaded
firearm(s) and ammunition in a training room/space or training session;

f. the necessity of promptly stripping Porter or any police officer/former police officer
of his/her live and loaded firearm(s) and ammunition upon observing same upon
entering the public library, before, during and after baton training;

g. the necessity of immediately effectuating an arrest when a misdemeanor occurs in

their presence;

h. the necessity of and when to verify no police officer or trainer has a live and loaded
firearm(s) or ammunition inside a training session or the building for which training
is to occur;

i. The necessity of having a no-live and loaded firearm(s) and ammunition policy
posted and communicated to all persons participating in a training session;

j. When to report the pointing of a training gun at a trainee;

k. How to report the pointing of a training gun at a trainee;

l. The prohibition against pointing a live and loaded firearm(s) at any person; even in
jest; and

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m. The inherent dangers of pointing a live and loaded firearm(s) at any person at any
time.

29. In or about June 2022, the District of Columbia contracted with Porter Consulting and Expert

Tactical Training LLC, through its owner/operator and agent Jesse Porter, Jr., requiring Porter

to conduct ASP baton training for District of Columbia Public Library Special Police Officers,

including Maurica Manyan.

30. Said contract did not have a clause prohibiting Porter and his employees from entering the

training location, Anacostia Neighborhood Library, armed with firearm(s) and ammunition.

31. Said contract did not require Jesse Porter, Jr., his agents, assigns and employees to

check/secure their live and loaded weapons before entering the Anacostia Neighborhood

Library.

32. Said contract permitted Jesse Porter, Jr. to enter and remain on the Anacostia Neighborhood

Library armed with firearm(s) and ammunition throughout the duration of the subject training

and after its conclusion.

33. In sum, for many years before the Defendants illegally and fatally shot Maurica Manyan, the

District of Columbia knew of the illegal acts regularly committed by its police units, former

police officers and contractors regarding use of the public libraries armed with weapons as

well as the dangerous practice of conducting training sessions while armed with live and

loaded firearm(s) and ammunition.

II. DISTRICT OF COLUMBIA, ANTHONY MICKENS AND BYRON

PURNELL KNOWLINGLY ALLOWED DEFENDANTS JESSE PORTER,
JR., AND PORTER CONSULTING AND EXPERT TACTICAL TRAINING
LLC TO CONTINUE THE PATTERN OF ILLEGAL CONDUCT

34. The D.C. Public Library is an independent city agency that has its own police department.

Officers, who are licensed to be armed, are responsible for public safety at library locations,

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35. Much like members of the aforementioned police forces or other patrons of the District of

Columbia Public Libraries, Defendants Porter, Mickens and Purnell were current members or

former members of local District of Columbia police agencies, with broad authority to roam

the city ostensibly and enter District of Columbia buildings armed with weapons, including

firearm(s) and ammunition.

36. Although the District of Columbia was put on notice to conduct internal investigations into

complaints of inadequate safety measures for trainees in training sessions and the multiple

requests to prohibit armed persons from entering training buildings and training sessions, and

thus had ample opportunity to correct the complained of unlawful and dangerous behavior, it

failed to provide the necessary oversight, discipline, or training to ensure that the defendants

in this case did not engage in the same pattern of dangerous misconduct.

37. Nevertheless, on August 4, 2022, Porter was permitted to, against the unambiguous

prohibition of live and loaded weapons in the Anacostia Neighborhood Library, carry and

maintain his weapon with live and loaded ammunition into the library during ASP Baton

training and to maintain said weapon on his hip openly and notoriously after training was

concluded.

38. Further, against unambiguous prohibitions of live and loaded weapons in the Anacostia

Neighborhood Library, co-defendants Mickens and Purnell, having a statutory obligation to

“make arrests for offenses committed in their presence, D.C. Code § 5-115.03, and are in that

sense considered to ‘be always on duty, ‘” see District of Columbia v. Coleman, 667 A.2d

811, 818 n.11 (D.C. 1995), permitted Defendant Porter to carry his live and loaded firearm(s)

open and notoriously into the Anacostia Neighborhood Library before the training session,

during the training session and after the training session ended. Mickens and Purnell made

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no effort to arrest Porter or command Porter to remove his live and loaded firearm(s) from his

hip; the room; and/or even the building continuing the pattern and practice of permitting law

enforcement and former law enforcement to continue the pattern of illegal conduct.

39. As a result and direct consequence of Defendants’ actions, what began as a normal day for

25-year old D.C. Public Library, Special Police Officer, Maurica Manyan ended with

Manyan dying from a gunshot wound to the chest, on the floor of the Anacostia

Neighborhood Library.

40. On August 4, 2022, Manyan was fatally shot after ASP Baton and Handcuff Technique

Training was over and all participants and trainers took off their protective gear; cleaned

up their equipment and materials; completed final paperwork, when one of her trainers,

Porter, aimed his loaded Glock 26, 9mm pistol at Manyan’s chest, depressed the trigger

and shot Manyan as she posed for a picture with her fellow officers, effectuating an

unconstitutional seizure of her body under Amendment 4 to the United States Constitution.

41. Porter, a retired 25-year veteran of the Metropolitan Police Department is the owner of

Porter Consulting and Expert Tactical Training LLC, a Washington D.C. limited liability

company operated by Porter. Porter and his company were contracted to provide ASP

Baton training to Manyan and her 3 fellow co-workers.

42. Porter was not licensed to provide firearm(s) training in the District of Columbia.

43. Porter was joined by Byron Purnell, an active-duty MPD sergeant hired in 1996, and a

former co-worker of Porter.

44. Purnell was employed with Porter Consulting and Expert Tactical Training LLC for nearly

one year at the time of the shooting. Purnell actively participated in the training with Porter

and was described by witnesses as a “second trainer.”

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45. In addition to the affirmative duty to arrest Porter, Purnell at all relevant times had a duty

to report any unlawful conduct observed by him to the local police agencies; including, but

not limited to the use and carrying of handguns and firearm(s) inside the premises by Porter.

46. The highest ranking DCPL officer on scene was lead officer Anthony Mickens.

47. Mickens was also duty bound to arrest Porter and report unlawful conduct occurring inside

the Anacostia Neighborhood Library, at all relevant times was the subject of prior

complaints of corruption and theft and has been accused of misconduct and policy

violations in connection with a pending wrongful termination lawsuit filed by another

DCPL SPO.

48. The August 4, 2022 ASP Baton training was scheduled to begin at 8:00 a.m. on the lower

floor of the Anacostia Neighborhood Public Library.

49. The lower-level library entrance is only accessible with a DCPL identification swipe card.

The second-floor public entrance is generally staffed with an armed officer.

50. The training was being monitored via CCTV by a DCPL Supervisory Officer.

51. Porter entered the Anacostia Neighborhood Library with a loaded firearm(s); holstered an

unconcealed on his hip upon arrival. The Glock pistol was clearly visible on Porter’s right

hip, as he was dressed with his shirt tucked into his pants.

52. During the morning training session, the Special Police Officers reviewed a presentation

but did not participate in physical training.

53. The group began an interactive portion of the training where Maurica Manyan was the first

person that Porter called on to read something from a PowerPoint presentation that was

being projected to the class.

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54. Porter, visibly irritated, expressed that Maurica Manyan was reading “too slow for his

liking” and announced to Mickens in front of the class that the next time he should bring a

“white helmet” for Manyan.

55. Porter’s comments violated DCPL’s harassment policy in the presence of Lead Officer

Mickens, who took no action against Porter and who voiced no objection to the repeated

violations of the DCPL harassment policy.

56. Later, Porter asked Maurica Manyan a question to which she responded with what Porter

viewed as the wrong answer. In response, Porter pointed his orange training gun at Manyan

while stating, “bang, bang, wrong answer” before he simulated shooting her. This conduct,

observed by Mickens violated DCPL Library Behavior Policy and DCPL’s harassment

policy, who once again, took no action against Porter.

57. After the lunch break, the SPO’s re-dressed in their equipment, which included bullet proof

vests and began stretching.

58. Porter led the physical component of the training, which involved the SPOs being partnered

in pairs and practicing baton techniques on a large sandbag. The training progressed to

handcuffing techniques and the SPOs began to apply the techniques modeled earlier that

day.

59. Upon the conclusion of all training, all of the SPOs removed their bulletproof vests,

removed their training equipment and any other protective gear, sat down for a moment

and completed paperwork.

60. After doing so, the SPOs, Porter and Purnell, began to move toward the front of the room

to pose for a picture. Anthony Mickens was the individual tasked with taking the photo.

Porter asked that a photo be taken with his phone, in addition to Mickens’s phone.

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61. Maurica Manyan apparently forgot to put her mask on and reached to grab her mask.

Manyan never left the formation during this period of time. Shortly after, she began fixing

her hair. Porter commented, “Oh, Lord, come on Rihanna.”

62. At approximately 3:30 pm, Porter stepped out of the line for posing for the photograph,

turned, withdrew his loaded firearm(s), aimed at Mauica Manyan’s chest and depressed the

trigger of his weapon; shooting Manyan at close range in her chest, as she stood shoulder-

to-shoulder between her classmates, still posing for a photograph.

63. All classmates, standing to the immediate left and right of Manyan and in the zone of

danger, stood terrified and shocked from the fear of being shot next and not knowing

whether Porter would continue to shoot them as well. Each then disbursed.

64. Manyan collapsed in agony and was heard crying and moaning from the pain and suffering

from just being shot in the chest at close range.

65. Within hours of the shooting, District of Columbia Library Public Safety Director, Douglas

Morency, resigned from his position, publicly announcing said resignation.

66. When asked at a press conference why Porter would be in baton training with a live and

loaded weapon, DC Police Chief Robert Contee responded, “[i]t is not good practice to do

that.”

67. DC Code § 7–2509.07 prohibits any person holding a license to carry a pistol from bringing

such a weapon into “a building or office occupied by the District of Columbia, its agencies

or instrumentalities.”

68. While the Law Enforcement Officers Safety Act (LEOSA) affords qualified active and

retired law enforcement officers the privilege to carry a concealed firearm(s) in the District

of Columbia, explicitly written into the statute are several areas considered off-limits to

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those carrying under LEOSA, including restrictions imposed on state or local government

property, installations, and buildings.

69. Certainly, Mickens and Purnell, an active MPD sergeant were sworn to enforce the laws

governing the District of Columbia and should have stopped Porter from entering and

remaining in the library with a loaded, unconcealed weapon for more than four (4) hours,

but consistent with their practice of permitting sworn members and formerly sworn

members of local agencies to enter said buildings unlawfully armed, they failed to do so.

70. These District employees, and potentially others, negligently permitted Porter to

unlawfully carry a firearm(s) in a public library in a gross disregard for the safety of

Manyan, her co-workers and innocent civilians.

71. A potential whistleblower and former SPO officer, Hedgepeth advised that she and other

employees complained to their superior officers about policy violations related to gun

safety at SPO trainings, within the two (2) years preceding Manyan’s death. A DCPL

Sergeant voiced opposition to the decision to hire Porter but stated her supervisors ignored

her opposition allegedly because Porter was thousands of dollars cheaper.

72. Porter and/or Porter Consulting and Expert Tactical Training LLC did not maintain general

liability insurance on the date of the shooting.

73. Pursuant to Section 202(b) of the District of Columbia Procurement Practices Act of 1985

(PPA), effective February 21, 1986 (DC Law 6-85; DC Official Code §2-302.02(b)); and

Chapter 27 of Title 27 of the DC Municipal Regulations, the purpose of the contract

insurance requirement policy is to establish a process for:

a. Determining the amount and type of insurance to be required in procurement

contracts; and

b. Standardizing insurance clauses and minimizing risk to the District.

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74. Notwithstanding the foregoing, DCPL and/or the D.C. Office of Risk Management

contracted with Porter and his company without verifying the minimum insurance

coverage, in violation its own policies, which is negligence per se, and without ensuring

Porter and his employees had a contractual clause prohibiting the bringing of live and

loaded firearm(s) into the building in which training was to take place. The District of

Columbia and DCPL also failed to include a contractual prohibition on the use of live and

loaded firearm(s) and ammunition in and after the training sessions, despite multiple prior

complaints of danger to the safety of training participants such actions entail.

75. Maurica Manyan succumbed to her injuries on August 4, 2022, leaving behind her

biological son, father and mother; all of whom she was the financial caregiver for and all

of whom suffered and continue to suffer severe emotional distress as a result of their loss.

76. After being shot, Maurica Manyan could be heard moaning and crying in pain and agony

from her gunshot wound.

77. Maurica Manyan suffered conscious pain and suffering immediately after being shot, she

was aware of her impending death and suffered until her last breath.

78. On or about August 25, 2023, Porter entered a valid guilty plea to and was found guilty of

involuntary manslaughter for the shooting death of Maurica Manyan in the District of

Columbia Superior Court and having been charged by a grand jury of murder in the second

degree.

79. Porter announced in open court a plea of guilty to involuntary manslaughter because he

was in fact guilty of the shooting death of Maurica Manyan on August 4, 2022.

80. All events were captured on CCTV and provided an opportunity for any observing police

officer or personnel to intervene in the unlawful and unsafe actions of Porter and his

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colleagues in carrying, brandishing, and shooting his live and loaded handgun at Maurica

Manyan.

81. Maurica Manyan did not cause or contribute to her fatal injuries, nor did she have an

opportunity to avoid same.

COUNT I – VIOLATION OF 4TH AMENDMENT TO THE UNITED STATES

CONSTITUTION

82. Plaintiffs incorporate as if fully stated herein all of the allegations contained in preceding

paragraphs.

83. "The right of the people to be secure in their person's houses, papers, and effect, against

unreasonable searches and seizures, shall not be violated and no warrants shall issue but

upon probable cause. Supported by oath or affirmation and particularly describing the

places to be searched and the persons or things to be seized." Amendment 4, Constitution

of the United States.

84. Defendant Porter’s actions, were at all times, as an agent of the District of Columbia

instigated by and dependent upon the exercise of the District of Columbia’s governmental

authority. Porter at all relevant times engaged in a function traditionally exclusively

reserved to the State, the training of police officers; and, at all times relevant, the

government acted jointly with Jesse Porter, Jr. in his actions complained of in this suit.

85. At all relevant times the District of Columbia exercised coercive power and control over

the behavior of Porter in directing him when, where, and how to train its trainees as well

as encouraging overtly the practice of carrying a live and loaded weapon into the training

session endangering Maurica Manyan and her co-trainees.

86. Defendant Porter, Purnell and Mickens with gross negligence (wantonly, willfully, and/or

maliciously) alternatively intentionally, with reckless disregard for human life and

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established protected 4th Amendment Rights against unlawful seizure, and without

justification assaulted, battered, and detained, and/or otherwise participated in the unlawful

and unjustifiable assault, battery and detention of the plaintiff, Maurica Manyan

(deceased), in terminating her freedom of movement by intentionally depressing the trigger

of his live and loaded firearm(s) while aiming it at her (shooting her, the use of physical

force and show of authority), in violation of her rights and privileges and immunities under

the United States Constitution, Amendment 4.

87. Defendant District of Columbia allowed these actions to occur as a result of its actions or

omissions, patterns and practices and its policymakers having intentionally adopted the

unconstitutional policy that caused the damages in question in this case; namely, permitting

live and loaded weapons, including firearm(s) and ammunition into governmental

buildings during training sessions and its pattern and practice of allowing police officers

and former police officers into federal public library buildings armed with live and loaded

firearm(s) and ammunition.

88. Defendants’ actions in assaulting and battering and or detaining the plaintiff under the

circumstances described herein constituted an unreasonable seizure of the plaintiff and the

use of force upon the plaintiff by defendant Porter was excessive and unreasonable.

89. At all times described herein, Defendants Porter, Purnell and Mickens acted under color

and pretense of law, and under color of statutes, customs and usages of the District of

Columbia and for the benefit of and at the behest of the District of Columbia.

90. The conduct of the defendants as described herein deprived the plaintiff of the rights

privileges and immunities guaranteed to her under amendment 4 to the United States

Constitution.

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91. As a result of all defendants’ actions, the plaintiff suffered physical and non-physical injury

and the unjustifiable loss of her freedom life and liberty.

92. The Plaintiffs’ injuries and damages are due solely to and by reason of the negligent and

or grossly negligent and or malicious and or willful and or reckless and or unreasonable

and or intentional and or ill-willed and or wanton and or grossly negligent acts and or

omissions of all defendants, directly and or indirectly without any negligence or want of

due care on the part of plaintiff contributing thereto.

93. Plaintiffs Radcliffe Manyan and Sherene Manyan claim under the Survival Act damages

for Maurica Manyan’s conscious pain and suffering and future earnings the Estate of

Maurica Manyan would have earned had she not died.

94. Plaintiffs D.M., Radcliffe Manyan and Sherene Manyan claim under the Wrongful Death

Act maintenance and assistance each would have received had Maurica Manyan not been

killed as well as the value of services Maurica Manyan would have provided had she live

and loaded as well as the cost of reasonable burial expenses.

WHEREFORE, Plaintiffs RADCLIFFE MANYAN and SHERENE MANYAN, individually and

in their capacity as the co-personal representatives of the Estate of Maurica Alex Manyan, and

David Harris, as father and next friend of D.M., demand Thirty Million Dollars ($30,000,000.00)

in compensatory damages from Defendants District of Columbia, Jesse Porter, Jr. and Porter

Consulting and Expert Tactical Training, LLC., Anthony Mickens, and Byron Purnell in their

individual capacity, jointly and/or severally, and Twenty Million Dollars ($20,000,000.00) in

punitive damages from Jesse Porter, Jr. and Porter Consulting and Expert Tactical Training, LLC.,

Anthony Mickens, and Byron Purnell; reasonable attorney’s fees pursuant to 42 USC sec. 1988,

costs and such other and further relief to which Plaintiffs may be entitled.

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COUNT II – VIOLATION OF 5TH AMENDMENT TO THE UNITED STATES

CONSTITUTION

95. Plaintiffs incorporate as if fully stated herein all of the allegations contained in preceding

paragraphs.

96. “The Fifth Amendment protects individuals from the deprivation of “life, liberty, or

property without due process of law.” Amendment 5, Constitution of the United States.

97. Defendant Porter’s behavior/actions were at all times as an agent of the District of

Columbia, instigated by and dependent upon the exercise of the District of Columbia’s

governmental authority. Porter at all relevant times engaged in a function traditionally

exclusively reserved to the State, the training of police officers; and, at all times relevant

the government acted jointly with Jesse Porter, Jr. in his actions complained of in this suit.

98. At all relevant times, the District of Columbia exercised coercive power and control over

the behavior of Porter in directing him when, where, how to train its trainees, as well as

encouraging overtly the practice of carrying a live and loaded weapon into the training

session endangering Maurica Manyan.

99. Defendant Porter maliciously, intentionally, carelessly recklessly with gross negligence

wantonly, willfully, wrongfully, and unreasonably, with reckless disregard for human life;

and without justification shot Maurica Manyan depriving her of life without due process

of law.

100. Defendant District of Columbia allowed these actions to occur as a result of its actions

accepted practice of permitting armed persons to conduct and be in training sessions with

live and loaded firearm(s) and ammunition, despite complaints from special police officers

as to the danger said common practice exposed Plaintiff Maurica Manyan to.

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101. Defendant Porter’s conducting a training session with a live and loaded firearm(s), open

and notoriously, and exposing Maurica Manyan to her fatal injury was a direct result of the

District of Columbia’s official custom, practice, or policy of permitting armed trainers in a

training building, and that caused the alleged constitutional violation.

102. Further, the hiring of and permitting of Porter to conduct training with a live and loaded

firearm(s) was a course pursued by the District of Columbia as evinced in its decision to

contract with co-defendant Porter from the sudden departure of the Public Library Public

Safety education and training head.

103. At all times described herein, the defendants acted under color and pretense of law, and

under color of statutes, customs and usages of the District of Columbia, and as agents for

the District of Columbia and for the benefit of and at the behest of the District of Columbia.

104. The conduct of the defendants as described herein deprived the plaintiff of the rights

privileges and immunities guaranteed to her under amendments 4 and 5 to the United States

Constitution.

105. As a result of the defendants’ actions, the plaintiff suffered physical and non-physical

injury and the unjustifiable loss of her freedom life and liberty.

106. All of the Plaintiffs’ injuries and damages are due solely by reason of the negligent and or

grossly negligent and or malicious and or willful and or reckless and or unreasonable and

or intentional and or ill willed and or wanton and or grossly negligent acts and or omissions

of defendants, directly and or indirectly without any negligence or want of due care on the

part of plaintiff contributing thereto.

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107. Plaintiffs Radcliffe Manyan and Sherene Manyan bring this claim under the Survival Act,

as personal representatives of the Estate of Maurica Manyan for her conscious pain and

suffering and future earnings Maurica Manyan would have earned had she not died.

108. Plaintiffs Radcliffe Manyan and Sherene Manyan as personal representatives of the Estate

of Maurica Manyan bring this action under the Wrongful Death Act on behalf of D.H.,

Radcliffe Manyan and Sherene Manyan, next of kin, for maintenance and assistance each

would have received had Maurica Manyan not been killed as well as the value of services

Maurica Manyan would have provided had she live and loaded as well as the cost of

reasonable burial expenses.

WHEREFORE, Plaintiffs RADCLIFFE MANYAN and SHERENE MANYAN, individually

and in their capacity as the co-personal representatives of the Estate of Maurica Alex Manyan,

and David Harris, as father and next friend of D.M., claim Thirty Million Dollars

($30,000,000.00) in compensatory damages and Twenty Million Dollars ($20,000,000.00) in

punitive damages from Defendants District of Columbia, Jesse Porter, Jr., Porter Consulting

and Expert Tactical Training, LLC., Anthony Mickens, and Byron Purnell, jointly and/or

severally, and reasonable attorney’s fees pursuant to 42 USC sec. 1988, costs and such other

and further relief to which Plaintiffs may be entitled

COUNT III - BATTERY

109. Plaintiffs incorporate as if fully stated herein all of the allegations contained in preceding

paragraphs.

110. Defendant Porter’s behavior was, at all times as an agent for the District of Columbia,

instigated by and dependent upon the exercise of the District of Columbia’s governmental

authority and under the color of that authority. Porter at all relevant times engaged in a

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function traditionally exclusively reserved to the State, the training of police officers, and,

at all times relevant, the government acted jointly with Jesse Porter, Jr. in his actions

complained of in this suit.

111. At all relevant times, the District of Columbia exercised coercive power and control over

the behavior of Porter in directing him when, where, and how to train its trainees as well

as encouraging overtly the practice of carrying a live and loaded weapon into the training

session endangering Maurica Manyan.

112. Defendants’ Conduct as described here in was undertaken deliberately with actual malice

and constituted an intentional offensive and non-consensual touching of plaintiff.

113. As a result of the aforesaid acts and conduct of the defendants the plaintiff was caused to

suffer physical and nonphysical injury; sustain economic damages for the cost of medical

treatment; sustained non-economic damages for the pain suffering anguish fear fright

humiliation inconvenience and embarrassment for the totality of events that she was forced

to endure and was in other ways damaged; was caused to suffer death.

114. Plaintiffs Radcliffe Manyan and Sherene Manyan bring this claim under the Survival Act,

as personal representatives of the Estate of Maurica Manyan for her conscious pain and

suffering and future earnings Maurica Manyan would have earned had she not died.

115. Plaintiffs Radcliffe Manyan and Sherene Manyan as personal representatives of the Estate

of Maurica Manyan bring this action under the Wrongful Death Act on behalf of D.H.,

Radcliffe Manyan and Sherene Manyan, next of kin, for maintenance and assistance each

would have received had Maurica Manyan not been killed as well as the value of services

Maurica Manyan would have provided had she live and loaded as well as the cost of

reasonable burial expenses.

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WHEREFORE, Plaintiffs RADCLIFFE MANYAN and SHERENE MANYAN, individually and

in their capacity as the co-personal representatives of the Estate of Maurica Alex Manyan, and

David Harris, as father and next friend of D.M., claim Thirty Million Dollars ($30,000,000.00) in

compensatory damages and Twenty Million Dollars ($20,000,000.00) in punitive damages from

Defendants District of Columbia, Jesse Porter, Jr., and Porter Consulting and Expert Tactical

Training, LLC., Anthony Mickens, and Byron Purnell, in their individual capacities, jointly and/or

severally; reasonable attorneys’ fees and such other and further relief to which Plaintiffs may be

entitled.

COUNT IV - INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

116. Plaintiffs incorporate as if fully stated herein all of the allegations contained in preceding

paragraphs.

117. Defendant Porter’s behavior was, at all times as an agent for the District of Columbia,

instigated by and dependent upon the exercise of the District of Columbia’s governmental

authority. Porter at all relevant times engaged in a function traditionally exclusively

reserved to the State, the training of police officers; and, at all times relevant the

government acted jointly with Jesse Porter, Jr. in his actions complained of in this suit.

118. At all relevant times, the District of Columbia exercised coercive power and control over

the behavior of Porter in directing him when, where, how to train its trainees as well as

encouraging overtly the practice of carrying a live and loaded weapon into the training

session endangering Maurica Manyan.

119. Defendant Porter’s Conduct was intentional or reckless and caused plaintiff to suffer severe

emotional distress upon the realization that she was shot in the chest and was dying.

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120. Defendant Porter’s conduct was extreme and outrageous in shooting an unarmed person,

Ms. Manyan, after a training session concluded and after she had taken off her protective

gear and was merely posing for a photograph; that such conduct is beyond all possible

bounds of decency, and to be regarded as atrocious, and utterly intolerable in a civilized

community.

121. Defendants Anthony Mickens and Byron Purnell were acting within the scope of their

employment as sworn members of the Metropolitan Police Department, the District of

Columbia Public Library Special Police Force and for the benefit of the District of

Columbia at all relevant times in observing and assisting Porter’s conducting a training

session with a live and loaded weapon on his person. Further, both Mickens and Byron as

sworn law enforcement officers had an obligation to stop Porter from conducting the

subject training with a live and loaded firearm(s) and ammunition, yet failed to do so.

122. Defendant District of Columbia’s actions in maintaining a policy and practice of permitting

trainers to conduct training sessions with live and loaded firearm(s) and ammunition and

failing to require a prohibition of live and loaded weapons in training session after multiple

complaints of the danger and unsafe environment created by its practice and policy of

allowing police officers and former police officers to maintain their live and loaded

weapons in training sessions and training buildings is extreme and outrageous.

123. Defendants’ caused Plaintiff to suffer severe emotional distress as was observed by all

witnesses to her shooting; and evinced by her grasping for air, grabbing her chest in

disbelief, and struggling to breathe.

124. All of plaintiffs’ claims are due solely to and by reason of defendants intentional or reckless

conduct.

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125. Plaintiffs Radcliffe Manyan, Sherene Manyan and D.M. claim relief as the biological

father, mother and son (respectively) of Maurica Manyan; for whom each suffered and

continue to suffer severe emotional distress, severe mental anguish, loss of society and

comfort caused by the loss of Maurica Manyan, including but not limited severe

depression, inability to sleep without nightmares, thoughts of suicide, emotional

breakdowns, post-traumatic stress disorder, bed-wetting, anxiety, loss of appetite, and

severe anger as a direct result of the extreme and outrageous conduct of all defendants.

126. Plaintiffs Radcliffe Manyan and Sherene Manyan bring this claim under the Survival Act,

as personal representatives of the Estate of Maurica Manyan for her conscious pain and

suffering and future earnings Maurica Manyan would have earned had she not died.

127. Plaintiffs Radcliffe Manyan and Sherene Manyan as personal representatives of the Estate

of Maurica Manyan bring this action under the Wrongful Death Act on behalf of D.H.,

Radcliffe Manyan and Sherene Manyan, next of kin, for maintenance and assistance each

would have received had Maurica Manyan not been killed as well as the value of services

Maurica Manyan would have provided had she live and loaded as well as the cost of

reasonable burial expenses.

WHEREFORE, Plaintiffs RADCLIFFE MANYAN and SHERENE MANYAN, individually and

in their capacity as the co-personal representatives of the Estate of Maurica Alex Manyan, and

David Harris, Jr., as father and next friend of D.M., claim Thirty Million Dollars ($30,000,000.00)

in compensatory damages and Twenty Million Dollars ($20,000,000.00) in punitive damages from

Defendants District of Columbia, Jesse Porter, Jr., and Porter Consulting and Expert Tactical

Training, LLC., Anthony Mickens, and Byron Purnell, in their individual capacity, jointly and/or

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severally; and for reasonable attorneys’ fees, and such other and further relief to which Plaintiffs

may be entitled.

COUNT V – NEGLIGENCE/GROSS NEGLIGENCE

128. Plaintiffs incorporate as if fully stated herein all of the allegations contained in preceding

paragraphs.

129. Defendant Porter’s behavior was, at all times as an agent for the District of Columbia,

instigated by and dependent upon the exercise of the District of Columbia’s governmental

authority. Porter at all relevant times engaged in a function traditionally exclusively

reserved to the State, the training of police officers; and, at all times relevant the

government acted jointly with Jesse Porter, Jr. in his actions complained of in this suit.

130. At all relevant times the District of Columbia exercised coercive power and control over the

behavior of Porter in directing him when, where, how to train its trainees as well as

encouraging overtly the practice of carrying a live and loaded weapon into the training

session endangering Maurica Manyan.

131. Defendants’ actions constituted a wanton and reckless disregard of human life with a

disregard of the consequences that might ensue as a result of their acts; their actions further

constituted an indifference to the duly established right of the decedent and others to be

free from unreasonable seizures.

132. All defendants had a duty not to expose the decedent to unreasonable danger and harm and

not to disregard her well established constitutional right under The United States

Constitution, Amendment 4 and Amendment 5.

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133. Defendants Mickens and Purnell had a duty to enforce D.C. law prohibiting live and loaded

firearm(s) and ammunition inside the Anacostia Neighborhood Library at all relevant

times.

134. Defendant District of Columbia had a duty to enforce D.C. law prohibiting trainers from

having and carrying into training buildings live and loaded firearm(s) and ammunition at

any time, including after the completion of a training session.

135. All defendants breached their respective duty owed to Plaintiff as a person in the Anacostia

Neighborhood Library and person who was participating in a training session prior to being

shot by Defendant Porter by:

a. Continuing a practice of allowing firearm(s) and ammunition inside training

sessions despite complaints against that dangerous practice at least 2 years prior to
the shooting death of Maurica Manyan;

b. Failing to strip Porter of his live and loaded firearm(s) and ammunition upon seeing
him enter the Anacostia Library carrying it open and notoriously;

c. Failing to have a policy requiring all trainers to check their live and loaded weapons
(firearm(s) and ammunition) prior to entering a training at the start of a training
session, during every break in a training session and/or after a training session; and

d. Failing to have a posted written prohibition against live and loaded firearm(s) and
ammunition in the training room in the Anacostia Library.

136. As a direct and proximate result of the negligence of each and all of the defendants, plaintiff

Maurica Manyan was shot in the chest, suffered traumatic emotional distress, bodily injury,

bodily harm, pain and suffering, anguish and death; violating her 4th and 5th Amendment

rights under the United States Constitution.

137. Plaintiffs Radcliffe Manyan, Sherene Manyan and D.M. claim relief as the biological

father, mother and son (respectively) of Maurica Manyan; for whom each suffered and

continue to suffer severe emotional distress, severe mental anguish, loss of society and

comfort caused by the loss of Maurica Manyan, including but not limited severe

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depression, inability to sleep without nightmares, thoughts of suicide, emotional

breakdowns, post-traumatic stress disorder, bed-wetting, anxiety, loss of appetite, and

severe anger as a direct result of the extreme and outrageous conduct of all defendants.

138. Plaintiffs Radcliffe Manyan and Sherene Manyan bring this claim under the Survival Act,

as personal representatives of the Estate of Maurica Manyan for her conscious pain and

suffering and future earnings Maurica Manyan would have earned had she not died.

139. Plaintiffs Radcliffe Manyan and Sherene Manyan as personal representatives of the Estate

of Maurica Manyan bring this action under the Wrongful Death Act on behalf of D.H.,

Radcliffe Manyan and Sherene Manyan, next of kin, for maintenance and assistance each

would have received had Maurica Manyan not been killed as well as the value of services

Maurica Manyan would have provided had she live and loaded as well as the cost of

reasonable burial expenses.

WHEREFORE, Plaintiffs RADCLIFFE MANYAN and SHERENE MANYAN, individually and

in their capacity as the co-personal representatives of the Estate of Maurica Alex Manyan, and

David Harris, Jr., as father and next friend of D.M., claim Thirty Million Dollars ($30,000,000.00)

in compensatory damages from Defendants District of Columbia, Jesse Porter, Jr., and Porter

Consulting and Expert Tactical Training, LLC., Anthony Mickens, and Byron Purnell, in their

individual capacity, jointly and/or severally, and such other and further relief to which Plaintiffs

may be entitled including costs and reasonable attorneys’ fees.

COUNT VI - NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS

140. Plaintiffs incorporate as if fully stated herein all of the allegations contained in all

paragraphs.

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141. All defendants’ behavior was, at all times were as agents of the District of Columbia,

instigated by and dependent upon the exercise of the District of Columbia’s governmental

authority. Porter at all relevant times engaged in a function traditionally exclusively

reserved to the State, the training of police officers; and, at all times relevant the

government acted jointly with Jesse Porter, Jr. in his actions complained of in this suit.

142. At all relevant times the District of Columbia exercised coercive power and control over

the behavior of Porter in directing him when, where, and how to train its trainees as well

as encouraging overtly the practice of carrying a live and loaded weapon into the training

session endangering Maurica Manyan.

143. Defendant Porter’s conduct was reckless and a breach of his duty owed to all Plaintiffs to

not expose them to unnecessary danger or harm; caused plaintiffs to suffer severe

emotional distress upon the realization that Manyan, their daughter and mother, was shot

in the chest and was dying; and, that Manyan’s colleagues were standing to the immediate

right and left of Manyan, in the zone of danger, at the time of the shooting; Defendants

knew or should have known that Plaintiffs would be contacted and informed of Maurica

Manyan’s death and that such call would constitute a physical impact upon their person,

that Plaintiffs would shortly thereafter view Manyan’s dead body for identification and

other purposes (they did), and that Plaintiffs would eventually view the video of the death

(which they have), all of which constitute placing Plaintiffs in the zone of danger and

constituting physical impacts.

144. Defendants’ conduct was negligent in shooting an unarmed person, Maurica Manyan, after

a training session after she had taken off her protective gear and was merely posing for a

photograph.

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145. Defendants Mickens and Purnell were acting within the scope of their employment as

sworn members of the Metropolitan Police Department and the DC Public Library Special

Police Force and for the benefit of the District of Columbia at all relevant times in

observing and assisting Porter’s conducting a training session with a live and loaded

weapon on his person. Further, both Mickens and Byron as sworn law enforcement officers

had an obligation to stop Porter from conducting the subject training with a live and loaded

firearm(s) and ammunition.

146. Defendant District of Columbia’s actions in maintaining a policy and practice of permitting

trainers to conduct training sessions with live and loaded firearm(s) and ammunition and

failing to require a prohibition of live and loaded weapons in training session after multiple

complaints of the danger and unsafe environment created by its practice and policy of

allowing police officers and former police officers to maintain their live and loaded

weapons in training sessions and training buildings is extreme and outrageous.

147. Defendants’ caused Plaintiff to suffer severe emotional distress as was observed by all

witnesses to her shooting; and evinced by her grasping for air, grabbing her chest in

disbelief, and struggling to breathe.

148. All of plaintiffs’ claims are due solely to and by reason of defendants’ negligent and

reckless conduct.

149. On 8/25/2023, Jesse Porter entered a valid guilty plea to and was found guilty of

involuntary manslaughter for the shooting death of Maurica Manyan.

150. Plaintiffs Radcliffe Manyan, Sherene Manyan and D.M. claim relief as the biological father,

mother and son (respectively) of Maurica Manyan; for whom each bore and continue to

bear severe emotional distress, severe mental anguish, loss of society and comfort caused

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by the loss of Maurica Manyan as a result of the extreme and outrageous conduct of all

defendants.

151. Plaintiffs Radcliffe Manyan and Sherene Manyan bring this claim under the common law

tort of negligent infliction of emotional distress, as personal representatives of the Estate

of Maurica Manyan for her conscious pain and suffering and future earnings Maurica

Manyan would have earned had she not died.

152. Plaintiffs Radcliffe Manyan and Sherene Manyan as personal representatives of the Estate

of Maurica Manyan bring this action under the Wrongful Death Act on behalf of D.H.,

Radcliffe Manyan and Sherene Manyan, next of kin, for maintenance and assistance each

would have received had Maurica Manyan not been killed as well as the value of services

Maurica Manyan would have provided had she live and loaded as well as the cost of

reasonable burial expenses.

153. Maurica Manyan’s co-trainees suffered and continue to suffer severe emotional distress at

the time of the shooting and continue to suffer severe emotional distress as a result of

standing shoulder-to-shoulder of Maurica Manyan at the time of her shooting death.

Maurica Manyan’s co-trainees’ were caused to be in danger of physical injury and feared

for their own respective safety as a result of defendants’ actions.

WHEREFORE, Plaintiffs RADCLIFFE MANYAN and SHERENE MANYAN, individually and

in their capacity as the co-personal representatives of the Estate of Maurica Alex Manyan, and

David Harris, Jr., as father and next friend of D.M., claim Thirty Million Dollars ($30,000,000.00)

in compensatory damages from Defendants District of Columbia, Jesse Porter, Jr., and Porter

Consulting and Expert Tactical Training, LLC., Anthony Mickens, and Byron Purnell, in their

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individual capacity, jointly and severally; attorneys’ fees and such other and further relief to which

Plaintiffs may be entitled.

COUNT VII - 42 USC SEC. 1983 (EXCESSIVE FORCE RESULTING FROM

INADEQUATE TRAINING, SUPERVISION AND DISCIPLINE)

154. Plaintiffs incorporate as if fully stated herein all of the allegations contained in preceding

paragraphs.

155. At all times herein, Defendants were acting under color of law, cover of statutes,

ordinances, regulations and customs and usages of the laws of the District of Columbia and

as employees and agents the District of Columbia and as such constituted a violation of

Title 42 USC, sec. 1983. At all relevant times Defendants actions implemented and

executed a policy statement and decision officially adopted and promulgated by the District

of Columbia to permit live and loaded firearm(s) and ammunition in training sessions; and,

to allow firearm(s) and ammunition in government buildings, in violation of D.C. Code §

7-2509.07.

156. Defendant Porter’s behavior was, at all times, instigated by and dependent upon the

exercise of the District of Columbia’s governmental authority.

157. Defendants Mickens and Purnell at all times were deemed to be “on duty” as employees of

the District of Columbia and sworn members of the MPD and D.C. Public Library Special

Police Force when they assisted Porter, Jr. in conducting baton training sessions with

Porter’s wearing open and notoriously his live and loaded firearm(s) and ammunition on

his waist for the entire day.

158. At all relevant times the District of Columbia exercised coercive power and control over

the behavior of Porter in directing him when, where, and how to train its trainees; as well

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as the District of Columbia’s overtly accepted practice of carrying live and loaded

firearm(s) into training session endangering the trainees, including Maurica Manyan.

159. As a direct and proximate consequence of the District of Columbia’s grossly inadequate

training, supervision and discipline of its officers regarding live and loaded firearm(s) in

training sessions and live and loaded firearm(s) in buildings were prohibited by D.C. code,

the Defendants deprived Plaintiff Maurica Manyan of the following clearly established

rights under the Fourth and Fifth Amendments of the United States Constitution;

a. The right to be free from excessive and unreasonable force and seizure;

b. the right to be free from deprivation of life and liberty without due process of law;

c. the right to be free from summary punishment.

160. The Constitutional depravations to Maurica Manyan are a direct result of the official

custom, practice, or policy of the District of Columbia permitting live and loaded firearm(s)

and ammunition in training sessions and in the Anacostia Neighborhood Library that

caused the noted constitutional violation.

161. Manyan was deprived of her constitutional rights, and that this deprivation was also caused

by the single municipal decision to permit Porter into the D.C. Public Library with live and

loaded firearm(s) and ammunition and conduct a training session with said live and loaded

firearm(s) and ammunition, reflecting a deliberate indifference to the risk that a violation

of a particular constitutional or statutory right will follow the decision, as it did here.

162. Plaintiffs Radcliffe Manyan and Sherene Manyan bring this claim under the Survival Act,

as personal representatives of the Estate of Maurica Manyan for her conscious pain and

suffering and future earnings Maurica Manyan would have earned had she not died.

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163. Plaintiffs Radcliffe Manyan and Sherene Manyan as personal representatives of the Estate

of Maurica Manyan bring this action under the Wrongful Death Act on behalf of D.H.,

Radcliffe Manyan and Sherene Manyan, next of kin, for maintenance and assistance each

would have received had Maurica Manyan not been killed as well as the value of services

Maurica Manyan would have provided had she live and loaded as well as the cost of

reasonable burial expenses.

WHEREFORE, Plaintiffs RADCLIFFE MANYAN and SHERENE MANYAN, individually and

in their capacity as the co-personal representatives of the Estate of Maurica Alex Manyan, and

David Harris, Jr., as father and next friend of D.M., claim Thirty Million Dollars ($30,000,000.00)

in compensatory damages from Defendants District of Columbia, Jesse Porter, Jr., and Porter

Consulting and Expert Tactical Training, LLC., jointly and severally; and, Twenty Million Dollars

($20,000,000.00) in punitive damages from Defendants Jesse Porter, Jr., and Porter Consulting

and Expert Tactical Training, LLC.; reasonable attorneys’ fees pursuant to 42 USC sec. 1988, costs

and such other and further relief to which Plaintiffs may be entitled.

COUNT VIII - 42 USC SEC. 1983 (FAILURE TO TRAIN, CUSTOM AND POLICY OF
INDIFFERENCE UNDER MONELL)

164. Plaintiffs incorporate as if fully stated herein all of the allegations contained in preceding

paragraphs.

165. Defendant Porters behavior was, at all times as an agent for the District of Columbia,

instigated by and dependent upon the exercise of the District of Columbia’s governmental

authority.

166. At all relevant times the District of Columbia exercised coercive power and control over

the behavior of Porter in directing him when, where, how to train its trainees as well as

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encouraging overtly the practice of carrying a live and loaded weapon into the training

session endangering Maurica Manyan.

167. The conduct of defendant District of Columbia and District of Columbia Public Library

Public Safety director, Douglas Morency, in failing to properly train Porter, Mickens and

Purnell, and other police officers, including high ranking, command level, and or/ veteran

training officers on checking one’s live and loaded firearm(s) before entering the public

library; on checking one’s live and loaded firearm(s) before, during and after a training

session; on verifying whether a co-trainer was armed with a live and loaded firearm(s) and

ammunition, anytime while in the public library; and, on the necessity of arresting violators

of D.C. law prohibiting live and loaded firearm(s) in the training building caused Plaintiff

Maurica Manyan to be deprived of her rights, privileges and or immunities secured by the

Constitution and the laws of this land, including Amendments 4 and 5 of the United States

Constitution.

168. At all times herein, Defendants were acting under color of law, cover of statutes,

ordinances, regulations and customs and usages of the laws of the District of Columbia and

at the behest of the District of Columbia and for the benefit of the District of Columbia,

when Porter, Purnell and Mickens along with other Public Library special police officers

permitted Porter to enter the training building armed with a live and loaded handgun open

and notoriously, maintain possession of said handgun throughout and after baton training,

and refused to strip Porter of his live and loaded weapon at any time, consistent with the

District of Columbia’s practice of permitting Porter and other trainers in training sessions

to remain armed and dangerous despite numerous specific complaints of said practice

within two years prior to the fatal injury of Marica Manyan by Jesse Porter, Jr.

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169. As a direct and proximate consequence of the conduct alleged herein, the Defendants

deprived Plaintiff Maurica Manyan of the following clearly established rights under the

Fourth, and Fifth Amendments of the United States Constitution:

a. The right to be free from excessive and unreasonable force and seizure;

b. the right to be free from deprivation of life and liberty without due process of law;

c. the right to be free from summary punishment.

170. The Constitutional depravations to Maurica Manyan are a direct result of the official

custom, practice, and policy of the District of Columbia permitting live and loaded

firearm(s) and ammunition in training sessions and in the Anacostia Neighborhood Library;

and also, as a direct result of the District of Columbia’s failure to train or the inadequate

training of the involved sworn members of the MPD and the Public Library Special Police

Force on:

a. Securing one’s live and loaded firearm(s) (weapon) in a safe place outside the
training building before entering the building or entering the training space;
b. when to secure your own and verify that no person has a live and loaded firearm(s)
and ammunition in a training space;
c. prohibiting police officers and former police officers from having live and loaded
firearm(s) and ammunition in the public library;
d. when to report the use of or presence of live and loaded firearm(s) and ammunition
in the training space or building prohibiting same;
e. prohibiting police officers and former police officers from having live and loaded
firearm(s) and ammunition in a training room/space or training session;
f. the necessity of promptly stripping Porter or any police officer/former police officer
of his/her live and loaded firearm(s) and ammunition upon observing same upon
entering the public library, before, during and after baton training;
g. the necessity of immediately effectuating an arrest when a misdemeanor occurs in
their presence;
h. the necessity of and when to verify no police officer or trainer has a live and loaded
firearm(s) or ammunition inside a training session or the building for which training
is to occur;
i. The necessity of having a no-live and loaded firearm(s) and ammunition policy
posted and communicated to all persons participating in a training session;
j. When to report the pointing of a training gun at a trainee;
k. How to report the pointing of a training gun at a trainee;

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l. The prohibition against pointing a live and loaded firearm(s) at any person; even in
jest.
m. The inherent dangers of pointing a live and loaded firearm(s) at any person at any
time.

Demonstrating a reckless disregard for Manyan’s rights protected under the 4th and 5th

Amendment to the United States Constitution.

171. Plaintiffs Radcliffe Manyan and Sherene Manyan bring this claim under the Survival Act,

as personal representatives of the Estate of Maurica Manyan for her conscious pain and

suffering and future earnings Maurica Manyan would have earned had she not died.

172. Plaintiffs Radcliffe Manyan and Sherene Manyan as personal representatives of the Estate

of Maurica Manyan bring this action under the Wrongful Death Act on behalf of D.H.,

Radcliffe Manyan and Sherene Manyan, next of kin, for maintenance and assistance each

would have received had Maurica Manyan not been killed as well as the value of services

Maurica Manyan would have provided had she live and loaded as well as the cost of

reasonable burial expenses.

WHEREFORE, Plaintiffs RADCLIFFE MANYAN and SHERENE MANYAN, individually and

in their capacity as the co-personal representatives of the Estate of Maurica Alex Manyan, and

David Harris, Jr., as father and next friend of D.M., claim Thirty Million Dollars ($30,000,000.00)

in compensatory damages from Defendants District of Columbia, Jesse Porter, Jr., and Porter

Consulting and Expert Tactical Training, LLC., jointly and severally; and, Twenty Million Dollars

($20,000,000.00) in punitive damages from Defendants Jesse Porter, Jr., and Porter Consulting

and Expert Tactical Training, LLC., and the District of Columbia; reasonable attorney’s fees

pursuant to 42 USC sec. 1988, costs and such other and further relief to which Plaintiffs may be

entitled.

COUNT IX - GROSS NEGLIGENCE

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173. Plaintiffs incorporate as if fully stated herein all of the allegations contained in all

paragraphs.

174. All defendants’ behavior was, at all times were as agents of the District of Columbia,

instigated by and dependent upon the exercise of the District of Columbia’s governmental

authority. Porter at all relevant times engaged in a function traditionally exclusively

reserved to the State, the training of police officers; and, at all times relevant the

government acted jointly with Jesse Porter, Jr. in his actions complained of in this suit.

175. Under District of Columbia law, gross negligence “requires such an extreme deviation from

the ordinary standard of care as to support a finding of wanton, willful, and reckless

disregard or conscious indifference for the rights and safety of others.” District of

Columbia v. Walker, 689 A.2d 40, 44 (D.C. 1997); see also District of Columbia v.

Hawkins, 782 A.2d 293, 300 (D.C. 2001).

176. At all relevant times the District of Columbia exercised coercive power and control over

the behavior of Porter in directing him when, where, and how to train its trainees as well

as encouraging overtly the practice of carrying a live and loaded and loaded weapon into

the training session endangering Maurica Manyan (without the policy and practice of

allowing live and loaded and loaded weapons into buildings and without Porter bringing

the live and loaded and loaded weapon into the building pursuant to it, Manyan would not

have been harmed).

177. Defendant Porter’s conduct was wanton, willful, and/or malicious and a breach of its duty

owed to all Plaintiffs to not expose them to unnecessary danger or harm; caused plaintiffs

to suffer severe emotional distress upon the realization that Manyan, their daughter and

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mother, was shot in the chest and was dying; and, that Manyan’s colleagues were standing

to the immediate right and left of Manyan, in the zone of danger, at the time of the shooting.

178. Defendants’ conduct was wanton, willful, and/or malicious in shooting an unarmed person,

Ms. Manyan, after a training session after she had taken off her protective gear and was

merely posing for a photograph.

179. Defendants Anthony Mickens and Byron Purnell were acting within the scope of their

employment as sworn members of the Metropolitan Police Department and the DC Public

Library Special Police Force and for the benefit of the District of Columbia at all relevant

times in observing and assisting Porter’s conducting a training session with a live and

loaded and loaded weapon on his person. Further, both Mickens and Byron as sworn law

enforcement officers had an obligation to stop Porter from conducting the subject training

with a live and loaded firearm(s) and ammunition.

180. Defendant District of Columbia’s actions in maintaining a policy and practice of permitting

trainers to conduct training sessions with live and loaded firearm(s) and ammunition and

failing to require a prohibition of live and loaded weapons in training session after multiple

complaints of the danger and unsafe environment created by its practice and policy of

allowing police officers and former police officers to maintain their live and loaded

weapons in training sessions and training buildings is extreme and outrageous.

181. Defendants’ caused Plaintiff to suffer severe emotional distress as was observed by all

witnesses to her shooting; and evinced by her grasping for air, grabbing her chest in

disbelief, and struggling to breathe.

182. All of plaintiffs’ claims are due solely to and by reason of defendants’ negligent and

reckless conduct.

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183. On 8/25/2023 Jesse Porter entered a valid guilty plea to and was found guilty of involuntary

manslaughter for the shooting death of Maurica Manyan.

184. Plaintiffs Radcliffe Manyan, Sherene Manyan and D.M. claim relief as the biological father,

mother and son (respectively) of Maurica Manyan; for whom each bore and continue to

bear severe emotional distress, severe mental anguish, loss of society and comfort caused

by the loss of Maurica Manyan as a result of the extreme and outrageous conduct of all

defendants.

185. Plaintiffs Radcliffe Manyan and Sherene Manyan bring this claim as personal representatives

of the Estate of Maurica Manyan for her conscious pain and suffering and future earnings

Maurica Manyan would have earned had she not died.

186. Plaintiffs Radcliffe Manyan and Sherene Manyan as personal representatives of the Estate

of Maurica Manyan bring this action under the Wrongful Death Act on behalf of D.H.,

Radcliffe Manyan and Sherene Manyan, next of kin, for maintenance and assistance each

would have received had Maurica Manyan not been killed as well as the value of services

Maurica Manyan would have provided had she live and loaded as well as the cost of

reasonable burial expenses.

187. Maurica Manyan’s co-trainees suffered and continue to suffer severe emotional distress at

the time of the shooting and continue to suffer severe emotional distress as a result of

standing shoulder-to-shoulder of Maurica Manyan at the time of her shooting death.

Maurica Manyan’s co-trainees’ were caused to be in danger of physical injury and feared

for their own respective safety as a result of defendants’ actions.

WHEREFORE, Plaintiffs RADCLIFFE MANYAN and SHERENE MANYAN, individually and

in their capacity as the co-personal representatives of the Estate of Maurica Alex Manyan, and

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David Harris, Jr., as father and next friend of D.M., claim Thirty Million Dollars ($30,000,000.00)

in compensatory damages from Defendants District of Columbia, Jesse Porter, Jr., and Porter

Consulting and Expert Tactical Training, LLC., Anthony Mickens, and Byron Purnell, in their

individual capacity, jointly and severally; attorneys’ fees and such other and further relief to which

Plaintiffs may be entitled.

COUNT X - TORTIOUS INTERFERENCE WITH A DEAD BODY

188. Plaintiffs incorporate as if fully stated herein all of the allegations contained in all

paragraphs.

189. All defendants’ behavior was, at all times were as agents of the District of Columbia,

instigated by and dependent upon the exercise of the District of Columbia’s governmental

authority. Porter at all relevant times engaged in a function traditionally exclusively

reserved to the State, the training of police officers; and, at all times relevant the

government acted jointly with Jesse Porter, Jr. in his actions complained of in this suit.

190. Under District of Columbia law, tortious interference with a dead body consists of denying

close family members the right to view and have access to the decedent’s body, whether

the acts were intentional, grossly negligent, or merely negligent.

191. At all relevant times the District of Columbia refused the Plaintiffs access to the dead body

of Maurica Manyan, even though access to the body was requested.

192. Defendants’ conduct was intentional, grossly negligent, or merely negligent and a breach

of its duty owed to all Plaintiffs to not expose them to unnecessary danger or harm; caused

plaintiffs to suffer severe emotional distress upon the realization that they had no access to

Manyan’s body, their daughter and mother, was shot in the chest and was dying.

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193. Plaintiffs Radcliffe Manyan, Sherene Manyan and D.M. claim relief as the biological

father, mother and son (respectively) of Maurica Manyan; for whom each bore and

continue to bear severe emotional distress, severe mental anguish, loss of society and

comfort caused by the loss of Maurica Manyan as a result of the extreme and outrageous

conduct of all defendants.

194. Plaintiffs Radcliffe Manyan and Sherene Manyan bring this claim as personal

representatives of the Estate of Maurica Manyan for her conscious pain and suffering and

future earnings Maurica Manyan would have earned had she not died.

195. Maurica Manyan’s co-trainees suffered and continue to suffer severe emotional distress at

the time of the shooting and continue to suffer severe emotional distress as a result of

standing shoulder-to-shoulder of Maurica Manyan at the time of her shooting death.

Maurica Manyan’s co-trainees’ were caused to be in danger of physical injury and feared

for their own respective safety as a result of defendants’ actions.

WHEREFORE, Plaintiffs RADCLIFFE MANYAN and SHERENE MANYAN, individually and

in their capacity as the co-personal representatives of the Estate of Maurica Alex Manyan, and

David Harris, Jr., as father and next friend of D.M., claim Thirty Million Dollars ($30,000,000.00)

in compensatory damages and Twenty Million Dollars ($20,000,000.00) in punitive damages from

Defendant District of Columbia; attorneys’ fees and such other and further relief to which Plaintiffs

may be entitled.

Respectfully submitted,

________________________________
Chelsea Lewis, Bar ID: 229547
Lewis Law
8201 Peters Road, Ste. 1000
Plantation, Florida 33324
954-869-8456(o)

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1-888-388-7360 (f)
[email protected]
Secondary E-Mails:
[email protected]
Attorneys for Plaintiff

___________________________
A. Dwight Pettit, Bar ID: 945402
Law Office of A. Dwight Pettit, P.A.
3606 Liberty Heights Avenue
Baltimore, Maryland 21215
410-542-5400 (0)
410-664-7520 (f)
[email protected]
Attorney for Plaintiff

______________________________
Latoya Francis-Williams, Bar ID: MD0203
Law Office of Latoya A. Francis-Williams, LLC
P.O Box 451
Randallstown, Maryland 21133
410-356-4691 (o)
443-548-4588 (f)
[email protected]
Attorney for Plaintiff

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THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

RADCLIFFE MANYAN, SR.,

as next of kin and as the Co-Personal
Representative of the Estate of Maurica
Alex Manyan
4720 Quimby Avenue,
Beltsville, MD 20705

SHERENE MANYAN,
as next of kin and as the Co-Personal
Representative of the Estate of Maurica
Alex Manyan
4720 Quimby Avenue,
Beltsville, MD 20705
CIVIL ACTION NO.:
TO THE USE OF DAVID BARRINGTON
HARRIS, JR.
Next Friend and Father of Son D.M., next of
kin
2442 Martin Luther King, Jr., SE, Apt. 517
Washington, DC 20020-5816

Plaintiffs,

v.

DISTRICT OF COLUMBIA
a municipal corporation
441 Fourth Street, NW
Washington, D.C. 20001
Serve on:
MAYOR MURIEL BOWSER
Office of Mayor
1600 Pennsylvania Avenue, NW
Washington, D.C. 20001
Designee:

OFFICE OF THE ATTORNEY GENERAL

Brian Schwalb
District of Columbia
441 Fourth Street, NW
Washington, D.C. 20001

and

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JESSE PORTER, JR.

1217 Upshur St., NE,
Washington, DC, 20017-3831

and

PORTER CONSULTING AND EXPERT

TACTICAL TRAINING LLC
1200 G Street NW, Suite 800
Washington, DC, 20005
Serve On:
Jesse Porter, Jr.
1217 Upshur St., NE,
Washington, DC, 20017-3831

600 Ava Circle NE

Washington, District of Columbia, 20017

and

ANTHONY MICKENS
3310 Croffut Pl SE
Washington, DC 20019

and

BYRON PURNELL
5002 Hayes Street, Northeast
Washington, DC 20019

Defendants.

DEMAND FOR JURY TRIAL

Plaintiffs demand a trial by jury on all issues and all counts of this Complaint so triable as

a matter of right.

Dated: October 25, 2023

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Respectfully submitted,

________________________________
Chelsea Lewis, Bar ID. 229547
Lewis Law
8201 Peters Road, Ste. 1000
Plantation, Florida 33324
954-869-8456 (o)
1-888-388-7360 (f)
[email protected]
Secondary E-Mails:
[email protected]
Attorney for Plaintiffs

___________________________
A. Dwight Pettit, Bar ID. 045402
Law Office of A. Dwight Pettit, P.A.
3606 Liberty Heights Avenue
Baltimore, Maryland 21215
410-542-5400 (0)
410-664-7520 (f)
[email protected]
Attorney for Plaintiff

______________________________
Latoya Francis-Williams, Bar ID MD0203
Law Office of Latoya A. Francis-Williams, LLC
P.O Box 451
Randallstown, Maryland 21133
410-356-4691 (o)
443-548-4588 (f)
[email protected]
Attorney for Plaintiff

52