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HEARNAP — Part 26
Page 148
148 / 500
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unlawfully, wilfully, knowingly, corruptly, maliciously,
discrininatorily, arbitarily, and in bad faith and without
prgbable, reasonable or any legitimate cause therefor conmitted,
aided and abetted, caused, ordered, authoriZedstinanced,
solicited, encouraged, approved, consented “ te. Gondon and/or *
othervise ‘promoted, with specific intent to adiso, Fhepgopiduct
set forth above in paragraphs 39 through 68, among others.
Ne £7
THIRD CAUSE OF ACTION
onaow oOo ww f& & NM
74.This is a cause of action to redress neglect and refusal
to prevent a conspiracy tofeptiye the plaintiffs of their
rights secured to them uf the Constitution, including the equal
protection of the laws andNeguit privileges and immunitics
‘ta
under the laws, and by the Laws not “the United States, and to. |
prevent the deprivation of such Bat. |
75.This cause of action is authorized by the First, Fourth, H
Fifth, Sixths Eighth, Ninth, Tenth and Fourteenth Anenaments
to the United States Cofistitution, by 42 U.S.C. $5 1983, 1985, |
1986 and 1988, ad by, 1B U.S.C. §§ 2510-20
76.7 cne plaintifes veeliese and incorporate by this veference, |
as if fully set forth herein, each and every allegation containe? |
in paragraphs 39 through 68 of the First Cause of Acticn and cane
“Z2) axaphs 70 through 73 of the Second Cause of Action. | }
ies “297. The defendants each had knowledge of said conspiracy ina
Reach had the duty and the rover to prevent or aid in preventing |
~. ., |
” 98.'Said defendants and each of them, each unlawfully, wil- |
fully, knowingly, corruptly, maliciously, diseriminetorily,
arbitrarily and in bad faith neglected and refused to prevent cr,
} aid in preventing the comission of said wrongs and acts.
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