28.  Plaintiffs Laila Ibrahim and Gehad Elsayed are both Muslim women who wear  religious head coverings called hijabs—headscarves covering the ears, hair, and neck of the  woman, but not the face—as an expression of their sincerely held religious beliefs.    29.  Their beliefs are grounded in the Quran, Sunnah, and the Hadith.    31.  To a Muslim woman, the veil becomes inextricably a part of herself: a form of her  person and her being. To remove the veil from a women outside of her family is to debase her— violating not just her religion but her dignity.    32.  The veil is worn at all times outside the presence of a Muslim woman’s family  including, but not limited to, for photographs seen on government-issued IDs such as driver’s  licenses and passport photos.   The NYPD Photographic Unit Standard Operating Procedures   33.  NYPD Photographic Unit Photography Standard Operating Procedures version 1.1  (“Photo Unit SOP”) governs the format for all post-arrest-processing photography at both the  precincts and central booking.   34.  Section 8 of the Photo Unit SOP provides direction for taking the front facing  photograph. The photographer is directed to instruct the arrestee that the head must be straight.  The prisoner should be facing and looking into the camera. Both eyes must be opened in a normal  manner without squinting. The mouth should be closed unless injury or deformity prevents the  mouth from closing. Long hair must be brushed or pushed away from the eyes and front of the  face, which should be expressionless.    36.  Nowhere does the Photo Unit SOP require the removal of religious head coverings.  Instead, that policy emphasizes the importance of an unobstructed view of the face and ears for  photographs taken at a precinct or central booking.    37.  Upon information and belief, these photographs are then saved in the NYPD Photo  Manager database and are shared with other law enforcement databases, making the photograph  of arrestees without their religious head coverings visible to anyone with access to the databases— indefinitely.  Searches at Police Facilities   38.  After arrival at the precinct and central booking, all arrestees are subjected to a  custodial search.   39.  Though all women are to be searched by a female officer, upon information and  belief, because all non-strip searches are conducted in the same processing space, male police  officers and/or male detainees are often present during the searches of Muslim women.     40.  For example, in Patrol Guide Procedure No. 208-05, the NYPD provides “[u]pon  arrival at precinct of arrest or other Department facility, the arresting officer (if he/she is of the  same sex as prisoner) or another designated member of the same sex as the prisoner, shall conduct  a thorough search of the subject’s person and clothing to ensure the safety of all persons within  the facility and to remove weapons, contraband, and evidence not recovered by the frisk.”   41.  Thereafter, the arrestee is taken back to the arrest processing section to continue the  process with male officers.     43.  The NYPD’s written policy, (hereinafter jointly referred to as the “NYPD’s  Religious Head Covering Arrest Policy”), has two distinct stages with respect to photographing  arrestees: at the precinct while processing the initial arrest (the “Identification Photograph”); and  a second time while at central booking (the “Booking Photograph”).    44.  For years prior to 2015, the NYPD’s Religious Head Covering Arrest Policy  provided a discretionary policy for the removal of religious head coverings for photographs taken  during post-arrest-processing at both the precinct and at central booking.   45.  At both locations, the arresting officer would search them, enter the arrestee’s  pedigree information, take their photograph, and place them in a holding cell with other arrestees.   46.  In 2015, the NYPD issued Interim Order 29 (hereinafter referred to as “IO 29”),  which revised the NYPD’s policy as it related to the Booking Photograph, targeted arrestees who  refused to remove their religious head coverings, providing them the option to take the Booking  Photograph at the Mass Arrest Processing Center (MAPC) located at One Police Plaza in  Manhattan regardless of the borough of their initial arrest.    47.  After the 2015 change, arrestees still must remove their religious head coverings  for photographs taken at central booking, without same gender photographers or private rooms, or  be transported to the MAPC.   49.  IO 29 left undisturbed the policy and practice of requiring all persons to remove  their religious head covering for the “booking photo.”  At all central booking facilities throughout  the City of New York, all individuals who wear religious head coverings are required to remove  their head covering for a photograph even after a search.     50.  IO 29 acknowledges that arrestees requesting a religious accommodation afforded  thereunder will experience “delay due to operation requirements incumbent in using MAPC,” that  is, an arrestee’s post arrest processing and arraignment could be delayed if MAPC is closed at the  time of their processing.    51.  IO 29, and the subsequent revised Patrol Guide Sections P.G. 208-03 and P.G. 208- 07, theoretically eliminated all photographing of objecting arrestees in the Court Sections and only  “accommodates” objecting arrestees at MAPC.    52.  Transporting an arrestee to MAPC can substantially increase the processing time  of an arrestee, adding hours and, in some instances, days to their arrest processing.   The NYPD’s Practice is Inconsistently Applied and Discretionary   53.  The NYPD continues an ad-hoc practice of requiring the removal of religious head  coverings for post-arrest processing photographs at both the precincts and at central booking.   54.  The NYPD’s alleged policy allows officers at the Identification Photograph to use  individual discretion as to whether or not they would allow a Muslim woman to keep her hijab on  during an Identification Photograph.   56.  For example, Plaintiff Elsayed, on only one occasion, was permitted to keep her  hijab on during the Identification Photograph. Both Plaintiffs were not provided the MAPC  accommodation for their Booking Photograph, and were both forced to unveil.   57.  Upon information and belief, NYPD officers have complete discretion when  deciding whether or not the religious head covering must be removed.   Prior Experiences of Plaintiff Gehad Elsayed   58.  Ms. Elsayed is an observant Muslim woman who wears the hijab, covering her hair  and neck as part of her religious obligations. Pursuant to her religious beliefs, Ms. Elsayed does  not show her hair to men who are not part of her immediate family.   59.  At all times relevant to the Complaint, including the present, Ms. Elsayed is  employed at a car dealership.   60.  Her position requires her to deal with customers and she is frequently in  communication with the NYPD when certain incidents with customers escalate.    61.  Ms. Elsayed has been arrested on three prior occasions, in 2012, 2014, and 2017.     62.  In June of 2012, Ms. Elsayed was required to remove her hijab while being  photographed at the 62nd Precinct and at Central Booking.   63.  At the Precinct, Ms. Elsayed requested that a female officer take her fingerprints,  as physical contact with men who are not in her immediate family is against her religious beliefs.  This request was denied and a male officer moved her hands during the fingerprinting process.   64.  Ms. Elsayed was photographed by a female officer in a private room.   66.  While at Central Booking Ms. Elsayed endured the laughs of male officers and  sexual comments by male detainees who referred specifically to the fact that her hair was exposed.   67.  In April of 2014, Ms. Elsayed was permitted to wear her hijab for the Identification  Photograph, but was again forced to remove her hijab during the Booking Photograph.    68.  Ms. Elsayed endured the extreme shame of being seen by men outside of her family  without her hijab. As a result of her multiple experiences, she fears further interactions with the  police, believing that they will once again force her to remove her hijab in violation of her religious  beliefs  Experience of Plaintiff Gehad Elsayed on March 14, 2018   69.  On March 14, 2018 at approximately 9:50 a.m., Ms. Elsayed was arrested for  allegedly driving with a suspended license.    70.  Ms. Elsayed was taken to the 72nd Precinct in Brooklyn for post arrest processing,  which included fingerprinting and photographing. Plaintiff was permitted to keep her hijab for the  Identification Photograph.   71.  At approximately 8:30 p.m., Ms. Elsayed was transported to Brooklyn Court  Section for further post arrest processing.    72.  While waiting in a holding cell with other female arrestees, Ms. Elsayed was called  by NYPD Officer JD1 to stand in front of a camera that was stationed in the center of the holding  area.    73.  This took place in the presence of seven male officers, a male photographer, and  approximately twelve to fifteen male detainees who could all see her from where they were in the  room.    75.  Ms. Elsayed told Officer JD1, as she had told prior officers and photographers  during her prior arrests, that it was against her religious convictions to remove her hijab in the  presence of men who were not members of her immediate family.    76.  Officer JD1 insisted Ms. Elsayed remove her hijab and preceded to mock her  request with three other male officers, all watching Ms. Elsayed struggle to maintain control of a  central religious belief.    77.  At no point did Officer JD1 inform Ms. Elsayed that she could be taken to MAPC  for a booking photograph taken in a private room.   78.  The male officers ridiculed Ms. Elsayed for wanting to keep on her hijab and one  officer mocked her saying “this is not the place to ask for any favors.”    79.  Humiliated, panicked, and overwhelmed, Ms. Elsayed continued to plead with the  photographer and the officer to keep her hijab on.    80.  As the orders to remove her hijab continued, another officer approached Ms.  Elsayed and told her to “cut out the crying and take that thing off.”    81.  With all eyes on her, Ms. Elsayed reluctantly and slowly slid her hijab to her  shoulders.    82.  The photographer began to take the photograph and Officer JD1 ordered that Ms.  Elsayed remove her hijab completely.    83.  Ms. Elsayed complied, and her photograph was taken as she held her hijab in her  hands.    85.  Ms. Elsayed asked Officer JD1 to hide her photograph so it would not be visible to  everyone. However, these photographs are available indefinitely to anyone with access to the  Photo Manager database within the NYPD, as well as all persons involved in post-arrest processing  and prosecution.   Experience of Plaintiff Laila Ibrahim   86.  Ms. Ibrahim is a stay-at-home mother of three and has been wearing the hijab for  twenty years. She was born in Egypt and became a U.S. citizen in 2016. She has been married for  14 years.    87.  On or about May 5, 2018, at approximately 1:00 A.M., New York Police  Department (“NYPD”) Officer Brodie (Shield No. 28113) and Officer John Doe 2 (“JD2”) entered  Plaintiff Laila Ibrahim’s apartment while she was asleep.   88.  The officers were responding to a call placed by Ms. Ibrahim’s husband over a  dispute.   89.  Ms. Ibrahim, who speaks limited English, was awoken by her son and told that  police officers wanted to talk to her.   90.  Officers Brodie and JD2 asked Ms. Ibrahim if she had ripped up her husband’s  shirts during the dispute.   91.  Ms. Ibrahim showed the officers the old, ripped up clothing and explained that the  shirts were old and stained, and that she intended to throw them out prior to the dispute.    93.  Mr. Ibrahim did not intend to press charges, but the officers insisted that they still  had to arrest Ms. Ibrahim, against Mr. Ibrahim’s wishes and without his request.   94.  Officer Brodie and JD2 called for another unit and two more officers, John Doe 3  (“JD3”) and John Doe 4 (“JD4”), arrived to the scene.   95.  The four officers took Ms. Ibrahim into custody and brought her down three flights  of stairs, holding her by her upper arms while her wrists were in tightly fastened handcuffs.   96.  Officers JD3 and JD4 placed Ms. Ibrahim in a patrol car and took her to 114th  precinct located at 34-16 Astoria Blvd. South, Astoria, NY 11103.   97.  Ms. Ibrahim was placed in a holding cell.   98.  Ms. Ibrahim requested a translator several times, but Officer Brodie demanded that  she shut up and stop crying, and that no translator would be provided.  