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SE orp aty oF Sct ae tae epee a os Go Er ees che rae hep SP AS Reh 45 ‘RAN ee NAP: ~~ “ o wee yep ten r e eene sea tere eee RAE TEES AEN ARLY 2 A SWB AE doe BERT TER ae RET Revere wn & WwW W o wow mH 10 31 42 43 14 15 16 17 18 19 20 21 22 32}! Plainciffs hereby demand a trial by jury. - a a nn ~ a ts at reves sw ae ae eet ne wie ee O orn 73. Defendants and each of them did act with flagrant, wanton, and malicious disregard for the xights of the Plaintifis and in doing @id deprive and-deny the plaintiffs of theix consti- ‘tutional rights under the Firs t, Fourth, Fifth, Sixth, Eighth, Ninth, Tenth, and Fourteenth Amendments all to plaintiftst aanage | ina sum not capable at ‘this time of being fully calculated, but not less than $15,000,000 and further entitling plaintiffs to punitive and exemplary damages of $15,000,000. PRAYER FOR ROLIEP WHEREFORE, the plaintifis pray for judgment as follows: . 2. Phat defendants be summoned to appear and answer’. herein and that plaintiffs have jndoment for their camazes, costs | of suit and each other and further relief as they may show . themselves justiy entitled to receive. : 2. For a declaration that the defendants engaged in the conduct alleged in this complaint against the plaintiffs, | and: that. such conduct was and is unlavful and unconstitutional. 7 3. For a permanent injunction restraining the defen- dants, their agents, employees, successors, privies and all . pevsons acting in concert with them, from engaging in any way - “in the conduct set forth in this complaint or conduct similar theréto against either of the plaintiffs. DATED: January 5, 1976. Respectfully submitted, MARK ROSENBAUM FRED OKRAND JILE JAKES. MARY ELLEN GALE VIRGINIA SLOAN LEONARD I. WEINGLASS RUTH ASTLE Attorneys for Plaintiffs, EMILY HARRIS and WILLIAM HARRIS a a el ls a et + 4 eee amet stefan mt ee re een By: HARK ROSENBAUN kee excatause 24. ° °