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HEARNAP — Part 26
Page 147
147 / 500
eked RE eee
* cp
ws
| : oo ' SECOND CAUSES OF ACTION
Sa OF ACTION
70. This is a cause of action to redress a conspirecy and/or
3 ‘conspiracies to deprive the Plaintiffs of rights, Privileges and
*H immunities, including the equal protection 4
£.the laws ané equal.
5 privileges and inmunities under the laws » them by the
fend ,
7 71. This cause of action is authorized bythe, rirst, Fourth,
iF Sy : ,
el Fifth, Sixth, Eighth, Ninth, Tenth ana Pourteonthaashcnenta to .
9 the Constitution of the United States, by 42 U.S.¢c. ss 1983,
f 2985 and 1986 and by 18 U.S.C. §§ 2510-20.” -t
iH 72. During the rceg eSen or about Nay 20, 1974 to the ,
ff sy
12:
present in the City and
Suny BE Los Angeles, in San Francisco, |
13 in Sacramento, the defendants, and ach of thea, and their agents
ss
| and employees and those acting if.concert with then, ‘whose
|
aa identities are presently unknown to ‘plaintiffs, aid unlawfully, |
6) wilfully, knowingly, cor ruptly, maliciously, discriminatorily, |
v7 arbitrarily"na in bad faith, combine, conspire, confederate ang
iid agree, tosetngg Ung vith each other, to deprive the plaintiffs
sae and each of thei of the, tights, privileges end immunities seeurce
“201
to them by the Constitution of the United States including the
23
First, Fourth, Fifth, Sixth, Eighth, Ninth, Tenth and Fourteenth
Amendments thereto, and by the laws of the United States, inclu- -
aws and equal privileges and immunities under the laws, by means
: SS
conduct and for the purposes described above in par
with
herein incorporated,all/the specific intent to
agraphs
7
28 73.As part of and in “furtherance of said conspiracy, and -
i for the specifically intended purpose and with the effect of |
| achieving its objects, one or more of said @efendants, ‘their
sl agents and: employees ‘and those acting in concert with them!
32 acting Separately and in concert in the City and County of Los
33
Angeles in San Francisco, in. Sacramento, and elsevhere,
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