DARNELL HICKS VS FLOYD BRADFORD, III, ET AL.

Plaintiff Darnell Hicks, by and through his counsel files this Complaint individually against the Defendants.

1. On September 12, 2020 , a manhunt was on for an individual who ambushed two Los Angeles County Sheriff's Deputies outside of the Metro Blue Line station in Compton. Meanwhile, DOES 1-5, presumed to be government officials, accessed California's Department of Justice computer systems (either directly or through an ancillary service provider) and retrieved Plaintiff Darnell Hicks' ("Mr. Hicks") confidential and private California DMV records, including his drivers license, drivers license number, photograph, address, date of birth, digital thumbprint, signature, and other biographical data (collectively "PII"). DOES 1-5 shared Mr. Hicks' DMV Records with other government individuals and members of the public ("DOES 6-100") who were not authorized to access or possess Mr. Hicks' DMV Records. Thereafter, DOES 1-100 shared Mr. Hick's PII, including on Facebook and Twitter, coupled with false statements that Mr. Hicks was wanted for attempting to murder the deputies. The following day, these false and defamatory statements along with Mr. Hicks' PII reached millions of social media users. Mr. Hicks received a number of racial charged death threats and feared for his life. In order to protect Mr. Hicks, the Los Angeles County Sheriff's Department had to issue public statements that he was not the suspect.

2. Jurisdiction is proper under Code of Civil Procedure section 410.10 and Article 4 of the California Constitution. Venue is proper under Code of Civil Procedure sections 393 and 395 because all of the Defendants live or do business in the County of Los Angeles, where the incidents occurred.

3. A proper and timely tort claim was presented to the State of California on behalf of Mr. Hicks, pursuant to Government Code section 910 et seq., and this action was thereafter timely filed on 9/13/21, in the United States District Court for the

Central District of California, Case No. 2-21-cv- -DMG-GJS, within all applicable statutes of limitation. On 4/4/24, Judge Dolly M. Gee issued a minute order granting Defendant Bradford's motion to dismiss, without prejudice to Mr. Hick's ability to refile this action in state court. Judge Gee's judgment was entered on 4/5/24. While this case was in Federal Court, the statute of limitations regarding Mr. Hicks' state law claims was tolled. (28 U.S.C. 1367 (a).)

4. At all relevant times, Plaintiff Darnell Hicks ("Plaintiff" or "Mr. Hicks") was a resident of Los Angeles County, California. Mr. Hicks brings these claims as a Private Attorney General, to vindicate not only his rights, but others' civil rights of great importance.

5. Defendant Floyd Bradford III ("BRADFORD") is an individual and resides in Los Angeles County, California.

6. Defendant Elizabeth Strump ("STRUMP"), is an individual and resides in San Bernardino County, California.

7. The true names and capacities of Defendants named herein as DOES 1- 100, inclusive, whether individual, employees, contractors, corporate, associate, government officials, government entities, government contractors, business entities, or otherwise, are unknown to Plaintiff who therefore sues such Defendants by such fictitious names. Plaintiff is informed and believes that some of the DOE defendants are state and local government officials and employees, who at all times relevant were acting under color of the law and within the scope and course of their employment. Said government officials and employees are sued in their individual and official capacities. Plaintiff is informed and believes that some of the DOE defendants were employed by or contractors of business entities that have a contractual relationship with presently unknown state and local government entities, divisions, departments, or agencies. At all times relevant, said employees and contractors were working within the scope and course of their employment or contractual relationships. Plaintiff will