◆ SpookStack

fener ee aga PP pe em ie Le ae ated jn furhe Wk maemo ot ~ wate “eoeomeneminen fave wie SERUM D fe: Pop mete "gy |! The compilation of information concerning them 7 | into dossiers maintained within the files of governmental : . 3 departments, agencies, and offices, and the use of said infor~ : ali ation for purposes unrelated to legitimate governmental ‘oe -| functions; — — _— 6 g. The implementation of Counterintelligence 7l| programs against plaintiffs, including but not limited to the al FBI Cointelpro programs. . . 9} 66.The conduct described in paragraphs 43 through 65 has 10 irreparably injured the plaintiffs in that it has deprived them of nf xights secured to them by the United States Constitution and the 3 ~ 42) laws of the United States. +h 67.By virtue of said conduct, and because the defendants solicited, condoned, promoted, encouraged, ordered, and ratified 14 t] 151; said conduct, the agents and employees of the United States el government, of local Police Departments, and of local District m7) Attorney Of fices have been led to believe that they may engage rel jn said conduct against plaintifis with impunity ana without fear 19) of arrest, prosccution, conviction, discipline, or other unfavor- 290 able consequences. ai} » 68-Unless this Court declares that such conduct is unlawful and restrains the defendants, their agents, employees, successors, ae and all persons acting in concert with them, from engag% 22 23; privies, 24° in, 25) promoting, soliciting or conspiring to commit such conduct + or similar conduct against the plaintiffs, they will continue to 26! suffer immediate and irreparable injuries for which they have no 2} adequate remedy at law. oe | 69.The plaintiffs are informed end believe that the 29} allegations contained in - paragraphs 39 through 68 are true, and* - aol] they make said allegations on the basis of said information 31|) and belief. 32 / cece epee ek et ea timmy aps metry HARGIS TS Tas 21.