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HEARNAP — Part 30
Page 425
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SECOND CAUSE OF ACTION cu ed
70.This is a cause of action to redress a conspiracy and/or
conspiracies to deprive the plaintiffs of rights, privileges, and
immunities, including the equal protection of the laws and Jequal :
privileges and immunities under the laws, secured to them by the.
Constitution and laws of the United States.
7).This cause of action is authorized by the Pirst, Fourth,
Fifth, Sixth, Eighth, Ninth, Tenth and Fourteenth Amendments to
the Constitution of the United States, by 42 U.S.C. $$°1983,
1985 and 1988 and by 18 U.S.C. §5 2510-20. . .
72.During the period from on oz about Mey 20, 1974 to ene
present in the City and County of Los Angeles, in San Francisco,
in Sacramento, the defendants and each of them, and their agents
and employees and those acting in concert with then, whose. ny.
identities are presently unknown to plaintiffs, did unlawfully).
wilfully, knowingly, corruptly, maliciously, discriminatorily,
arbitrarily and in bad faith, combine, conspire, confederate and
agree, together and with each other, to deprive the plaintiffs
an@ each of them of the xights, privileges and imnunities secureée
to them by the Constitution of the United States including the
First, Fourth, Fifth, Sixth, Eighth, Ninth, Tenth and Fourteenth
Amendments thereto, and by the laws of the United States, inclu, |
wis
we
ding 18 U.S.C. §§ 2510-20, and of the equal protection of the
laws and equal privileges and immunities unger the laws, by means”
of the conduct and for the purposes described above in’ paragraphs |
with |
39 through 68, herein incorporated,all/the specific intent to
do soa.
73.As part of and in furtherance of said conspiracy, and
an 4
for the specifically intended purpose and with the effect of
achieving its objects, one or more of said defendants, their
agents and employees and those acting in concert with them,
acting separately an@ in concert in the City and County of Los
i
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