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An exception to the rule of absolute testimonial immunity exists for 'complaining witnesses.' Cervantes v. Jones, 188 F.3d 805, 809 (7th Cir. 1999). A complaining witness is one 'who actively instigated or encouraged the prosecution of the plaintiff.' Curtis, 48 F.3d at 286. The determination of who qualifies as a complaining witness is highly fact-specific and best not resolved on a motion to dismiss. Cervantes, 188 F.3d at 810; Ienco, 286 F.3d at 1000 n.9 (declining to decide on appeal fact-intensive issue of whether complaining witness exception applies).
