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oy Sameer nea ee RAS er hee it le tar SS ek i ee ee re + —y Braden tH) Parra’ A a fw Sere th tee <n? vy 39.Each of the defendants, their agents and employees and aes ‘git those acting in concert with then participatéd in and/or . gommitte ae 3 caused and/or promoted the conduct set forth below ‘under the ‘i color and pretense of federal, state and local law, to atte 5|| statutes, ordinances, rules, regulations, rulings, customs, 6) usages, practices, policies and/or authority of the United States “git of California, the City and County of Los Angeles and/or their © 7h the District of Columbia, the 50 states, particularly the State 9|| departments, agencies, and offices. o 10 ( 40.At all times material herein, each of the defendants, th 11l| agents and employees and those acting in concert with them ah Ve: | 12|' specifically intended to and did unlawfully, wilfully, knowingly 13| ali 15|| resources and jurisdiction of the government of the United States,: corruptly, maliciously, @iscriminatorily, arbitrarily, ané in bad faith abrogate, usurp and misuse the power, authority, offices, 16!| the District of Columbia, the 50 states, particularly the State’ all of California, the City and County of Los Angeles, and/or their” 18|| departments, agencies and offices. , . 19 41.At all times material herein, the defendants, their agents 20|| and employees and those acting in concert with them acted palpably. 21}, and manifestly outside their lawful jurisdiction and discretion, 22|| the fawful scope of their authority and their lawful line of 23|| duty. , : , a ur we tah 4 42.-Each of the defendants, their agents and employees and- ' 25|| those acting in concert with them participated in and/or committed, 26 caused and/or promoted the conduct set forth below in the Central 27|' pistrict of California or knew or reasonably should have foreseen i 28 || that said conduct would take place or cause effects upon plain-~ i tiffs in the Central District of California. zo 43.Beginning on or about May 20, 1974 and continuing! through 1 31! the present, defendants and each of them, and their agents, 8. Gn a ne ee ae ere emer rms a ey er a TH eter SS mT ie Se rere ee ee cn ne a TN A I TE ee