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15; : 16 | oa - 18! 19° 20 22. aac 21. ‘in, promoting, soliciting or conspining to comm t such ‘conduct adequate remedy at law. : —— a : . . ? . - e cee . at . me . .. . . - Pa ‘ - . t . 7 . . . - Se ee . 4 : roy : soos . . ’ Soe Ee 2 . "ot . : . . f. _ The compilation of information concerning them -into dossiers maintained within the files of governmental ‘departments, agencies, and offices, and the use of sald infor- mation for purposes unrelated to legitimate governmental - €unctions; g. The implementation of Counterintelligerice:: -Brograms against plaintiffs, including but not Limited | ‘to the z. PBI-Cointelpro-prograns: 66 The conduct described ‘in paragraphs: 43 “through 65 has oe irreparably injured the plaintifés’ in that it has deprived the: rights: secured - -to then by the United States Constitution and th! laws of the United States. 67 -By virtue of Said conduct, and because the defendant promoted, encouraged, ordered, solicited, condoned, and ratific said conduct, the “agents and employees of the ‘United States government, of local ‘Police Departments, and of local District Attorney Offices ‘have been led to believe that they may engas:<! in said conduct against. Plaintiffs with impunity and without fe! of. arrest, Prosecution, conviction, diseipline, Ox: other. unfavo able _consequences. . 68. Unless. this Court declares, thét such conduct: is unlaw? and restrains the. defendants, their agents, employees, suecgs77 a go privies,. “and all persons. ‘acting in concert with then, from enge or similar ‘conduct against the plaintifés, they will continue t suffer. inmediate and irréparable’ injuries for which they have r a = vee - so .. 2 — eg = “ seep. 69. The plaintifss, ‘are. inzorned ang believe that. the “gblesations : contained | “in ‘paragraphs 39, through 68. are ‘trye.an Ma they make said allegations ‘on the, basis’ ‘Of said information end tania ret ne a eet es e i Patt hecathasneeeint, eked - . inte - « - * . ree Re eles? ba