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_.? oo. ee en ee a ee eo tatect Ls ee eS ton r wee a ees ae a -. SECOND CAUSE OF ACTION | 70. This is a cause of action to redress a conspiracy ani’ conspiracies to deprive the plaintitts of rights, privileges an immunities, including the equal protection of the ‘laws. and equ: ‘privileges and immunities undex the laws, secured to ‘them by *h | Constitution. and laws of the ‘Unitea States. ae — 7 71. This. cause of action is authorized by the First, Fourt Fifth, Sixth, Eighth, Ninth, Tenth and Fourteenth Amendments to the. Constitution of the ‘United States, by 42 U. s. Cc. ‘SS 1983, 1985 and 1988 ana by 18 U. S.C. $s 2510- -20.. ; . _ -72.During the period from On or about May. 20, 1974 to the present in the City and County of Los Angeles, in: San Franciscc. in Sacramento, the defendants and each of ‘them, and thaie dex and employees and those acting in concert” with them, vnose identities are presently unknown to plaintiffs, did unlawfully, wilfully, knowingly +. corruptly, maliciously, discriminatorily, arbitrarily and in bad faith, combine, conspire, confederate an -agree, together and with each other, to deprive the. plaintiffs and each of them of ‘the ‘xights, ‘privileges and imaunities secur ; to” them by the Constitution of the’ United States including the | Firsts: Fourth, Fifth, Sixth, Eighth, Ninth, Tenth. and Fourteent Amendments thereto, and by the laws of the United States,’ inch. ding 18 U.S.C. §§ 2510- 20, _and of’ the équal protection of ‘the laws :and equal privileges and immunities under the Laws by. mee i of the conduct and for the purposes: describea above ain ‘paragrer with. 39 _ through 68, ° herein incorporated, al1/the: specific intent t 73, As part of. and in furtherance of. said. conspiracy; “and ee tne speci ficallyintended “purpose and, with, the. effect of achieving its: objects, ‘one or nore. of: said defendants, their . agents and employees aid. those acting in goncert: with ‘then; © | acting, Separately: and, in. concert: ain ‘the city ‘ana ‘County of Los = elsewhere, ©