Added Travis Mundy's personnel file obtained through FOIA as exhibit D showing six prior complaints for excessive force and racial profiling. Added Sharon Puit's emails coordinating with Elliot as exhibit E. Added her statistical analysis of security screenings as exhibit F23 incidents. 92% detention rate when Travis was on duty.
0% for white attorneys during same periods. Added the video of Travis's parking garage threat as exhibit G. Added everything, every incident, every violation, every piece of evidence she'd been collecting for 6 months. The final complaint was 104 pages.
Caption: Camille Booker V. Durham County, Travis Mundy, Sharon Puit, Elliot Chandler, and John Does 1-10. Causes of action 42 U.S.C. Section 1983 denial of access to courts 18 U.S.C.
Section 242 deprivation of rights under color of law North Carolina general statute 143-422.3 discriminatory enforcement Brady violation withholding exculpatory evidence judicial misconduct failure to recuse despite conflict Prayer for relief. Compensatory damages, $150,000. Punitive damages, $500,000. Injunctive relief requiring policy reforms at Durham County Justice Center.
Appointment of independent monitor for courthouse security practices. Mandatory anti-bias training for all courthouse staff. Attorneys fees and costs. Any other relief the court deems just and proper.
She read it one final time. Then she sent it to Marcus. His response came at 2:00 a.m. This is the most thorough civil rights complaint I've seen in 15 years of practice. File it.
March 7th, three days after oral arguments, Camille walked into the Durham County Justice Center one final time. Travis Mundy was at security. He saw her coming and his expression hardened into something familiar, anticipatory, ready to make her day difficult again. Secondary, she held up a document.
Officer Mundy, this is a copy of a federal civil rights complaint I'm filing this morning in the U.S. District Court for the Middle District of North Carolina. You're named as a defendant. You'll be served formally within 72 hours. I'm providing you this courtesy copy now.
Travis's face went blank. He took the document automatically. Started reading. This also names the Durham County Sheriff's Office, the clerk of courts, and several John Doe defendants.
I'm identifying you specifically because of your pattern of discriminatory security screenings documented over the past 6 months. Travis looked up. What? 23 incidents.
Statistical analysis attached as exhibit F. Video evidence of your parking garage threat attached as exhibit G. I suggest you contact your union representative and retain legal counsel. She walked past him to the metal detector.
It beeped. She stopped waiting. Travis just stared at the complaint in his hands. Didn't move.
Officer Mundy, the detector. He looked up like he'd forgotten she was there. Waved her through without a word. She rode the elevator to the second floor.
Sharon Puit was at the clerk's counter. Camille approached and placed an identical copy of the complaint on the counter. Ms. Puit. This is a courtesy copy of a federal civil rights complaint I'm filing this morning.
You're named as a defendant for coordinating with opposing counsel to obstruct my filings and deny my client access to the courts. You'll be served formally within 72 hours. Sharon's hands trembled as she picked up the document, started reading. Her face went white.
This is you can't. I can and I have. The complaint includes emails you sent to Elliot Chandler discussing ways to delay my filings. Those emails were produced during discovery.
They're now part of the federal record. Sharon's mouth opened, closed, opened again. No words came out. I need to file this in the federal courthouse, which is across town.
But I wanted you to know first. Professional courtesy. Camille turned and walked away. Behind her, she heard Sharon's voice high and panicked.
Get me, Robert. Get me, Robert. Now.
Outside, Professor Washington was waiting in his car. He'd driven with her for safety. How'd it go? Travis looked like he'd been hit by a truck.
Sharon looked like she might faint. Good. Let's go file this thing.
The federal courthouse was different from Durham County. Bigger, newer, more professional. The security guards were US marshals, not local officers. They were polite, efficient, thorough.
Camille passed through security in 90 seconds. The clerk's office for the U.S. District Court was on the second floor. She walked up to the counter and presented the original complaint, plus four copies, filing a new civil rights action. The clerk, a middle-aged woman with reading glasses on a chain, took the documents and scanned the caption.
Her eyebrows rose. This is against Durham County. Yes, ma'am. And several individual defendants.
Yes, ma'am. The clerk read the first few pages, stamped each copy with the filing date and time, assigned a case number, handed Camille her copies. You'll need to serve all defendants within 90 days. The court will assign a judge within 48 hours.
Good luck. Thank you.
Outside, Camille stood on the courthouse steps and called Marcus Chen. It's filed. Case number. She read it off.
1:25-CV-000142. I'm pulling it up now. Looking at the docket. Okay, I see it.
Camille Booker versus Durham County et al. Filed March 7th, 2025 at 10:47 a.m. He paused. This is really happening. This is really happening.
You ready for what comes next? What comes next? They're going to fight back. Hard motion to dismiss.
Discovery battles. Depositions where they try to break you down. Settlement offers designed to make you go away quietly. This could take years.