Price v. City of N.Y. 15 Civ. 5871 (KPF) (S.D.N.Y. Jun. 25, 2018) Midtown North police station to file a complaint, Lieutenant Nicholas Corrado refused "to take [her] report about the assault." (FAC ¶¶ 62-65). Unsatisfied, Plaintiff requested to speak with a commanding officer, and Corrado responded by ordering her to leave the station. Plaintiff refused to leave and insisted that the NYPD take her report. (Id. at ¶¶ 66-68). Corrado, assisted by Officer Iselaine Guichardo Hermene Gildo Cruz, "physically pulled [Plaintiff] out of her seat," put handcuffs on her, and detained her inside the station until an ambulance arrived to take her to Bellevue Hospital Center for involuntary observation. (Id. at ¶¶ 69-73). Cruz stayed with Plaintiff during the ambulance ride to Bellevue, and inside of the hospital, she was joined by Officer John Staines in continuing to detain Plaintiff for about an hour. (Id. at ¶¶ 74-77). At the direction of hospital staff, Cruz and Staines removed Plaintiff's handcuffs; they subsequently left the building. (Id. at ¶¶ 78-79). After about two hours of observation by hospital staff, Plaintiff was released from Bellevue. Plaintiff asserts that Corrado, Cruz, and Staines had no reason to believe that she was a risk of harm to herself or others, or that she required immediate mental health treatment. (Id. at ¶¶ 80-83). 7 6 Plaintiff continued to advocate for herself and to complain to City officials about the NYPD's refusal to protect her from Powell or to investigate her allegations of abuse. One way in which she did so was by lodging publicly *6 viewable complaints directed at several of the City's official Twitter accounts. For instance, she interacted with the official Twitter feed for the NYPD's 28th Precinct, which feed has a Twitter handle, or username, of @NYPD28Pct. That account was administered by NYPD Inspector Olufunmilo F. Obe. (FAC ¶¶ 91-95). The 28th Precinct's Twitter page includes a hyperlink to the City's official Social Media Policy and "does not otherwise limit the purpose or topic of the @NYPD28Pct Account," beyond the restrictions set forth in that policy. (Id. at ¶¶ 96-97).4 4 Plaintiff notes that according to a report from Harvard University's Berkman Klein Center for Internet & Society, the City encouraged NYPD commanders to create official Twitter accounts "to increase interaction with the communities in which police officers work every day" and "to share information about community events, encourage community members to attend public meetings, and document NYPD's service work in communities." (FAC ¶ 99 & Ex. B at 18). In October 2014, Plaintiff began following the @NYPD28Pct account, and she would occasionally post public responses to the account. (FAC ¶¶ 101-02). For instance, on October 14, 2014, Plaintiff posted two responses to the @NYPD28Pct account. The first response read: @NYPD28Pct @sffny ATTN Insp OBE: link 4 #DomesticViolence prevention leads to a JEWELRY MALL. Your selection is nice ow.ly/CdI1G. (Id. at ¶ 102). On the same day, Plaintiff posted the following reply to another tweet by the @NYPD28Pct account: @NYPD28Pct @sffny nice selection INSP OBE! Any extra time to respond to the letter I sent 2 your precinct about #DV? (Id.). Shortly thereafter, "Obe blocked [Plaintiff] from the @NYPD28Pct Account without notifying [Plaintiff] or providing reasons for blocking her." (Id. at ¶ 103). *7 As a result of being "blocked" by Obe, Plaintiff could not — and still cannot — use her own Twitter account to view tweets from @NYPD28Pct, respond to any tweet published by @NYPD28Pct, or view any other person's responses to tweets by @NYPD28Pct. (FAC ¶¶ 104-05). Plaintiff alleges that Obe blocked her from the @NYPD28Pct account in retaliation "for her criticism of the domestic violence assistance 3

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