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AL unlawfully. wilfully, knowingly; corruptly, maliciously, ‘discriminatorily,. arbitarily, ana in bad’ faith. and without probable, reasonable or ‘any ‘legitimate. cause ‘therefor ‘committe: aided: and abetted,’ caused, ordérea, authorized, financed, “solicited, encouraged, "approved: ‘consented: to, otherwise Promoted, with specific intent: ‘to. do 80, the conduct ‘condoned and/oz ‘set forth. above’ in Paragraphs 39 through’ 6a, among: others. « - PHERD-CAUSE-OF-AcTIO 74. This is a cause of action to redress neglect ‘and. refusal “4. ol} to prevent a conspiracy to deprive the plaintiffs of their “rights‘e secured to “then by the’ Constitution, including the equa: protection © of the laws. and equal privileges and inmunities under: the laws, and by: the ‘laws of the United States, and ‘to. prevent the deprivation of such rights... 75. This cause Of action is| authorized” by, the First, Fourth. Fifth, ‘Sixth, Eighth, “Ninth, Tenth: ‘and Fourteenth Amendments & to. the United States Constitution, by. 42 U.S.C. 88 1983, 2985, a 1986 and 1988, and by 18 U. Ss. Cc. 5s 2510- -20_ oy _16:The plaintifts reallege, and incorporate. e by. ‘this xeferenc as if fully ‘set forth herein, each and every allegation contair. Vj) in: Paragraphs | 39. ‘through 68 of, the First Cause of: Action: ané pe: S| hn - =o graphs: 30 through 73 of ‘the. Second: Causa of Action, (he defendants: each. had- fnowledge of: said, ‘Bonepiwaey ans a one aw each had the auty and the power, | to prevent or aid in Preventing ot 25] abla ween, ana acts ‘that were: ‘the objects. of the’ ‘eonspiracy. oa ~ 785 ‘Said defendants. “and. each of ety s enoh natn WA oy nog ts ; ‘wt 4 _— ran eee Soe. Meitreriiy | ‘and in \ bad faith p negieéted and retused to (Prevent-< a EN Tay Sey Nee Melee an