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v : ee mie eee of California rights guaranteed to such persons by the Constitution of the United States of America; the history of the most shocking, horvendous, and flagrant censbitutional violetions as well as vhe ignoriasg of and disregard for human rights and decency by the Defendants 2 1. 6. nota ate has required Wederal Court intervention in the past, has required legislative investigations, and hes earned for the State of California a reputation of the ssost scandalous nature in the field of penal correction; the discriminatory, oporessive,; and unconstitutional pattern of @onduct by the persons referred to within this paragraph continues up to the present time, and unless the relief asked for herein is granted, it shall continue into the future, to the irreparable harm of plaintiffs. . 13 From almost the moment of the death of John ¥. Mills, defendants have engaged end are continuing to engage, in a systematic pattern of conduct, separately and together, which is calculated to and which does deprive the plaintiffs of rights, privilezes and immunities secured by the Constitu- tion and laws cf the United States of America, and in parti- cular said conduct deprives plaintiffs, in the criminal case . (/ pending against them, of the effective assistance of counsel, the right to eonfront witnesses arzinst them and obtain witnesses in thelr behalf, fair triei, due process of law, equal protection of law, and freedem from _tonds of slavery; unless the relief requested herein is granted, plaintiffs shell irreparably suffer loss and destruction of these rights, privileges and immunities referred to herein. -5-