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ion of the United States of America; the history of the most shosking, horrendous, and flagrant constitutionai violations as well as the ignorius of and disregard for human has required Federal Court intervention in the past, has required legislative investigations, and hss earned for the State of California a reputation of the zost scandalous nature in the field of penal correction; the discriminatory oppressive, and unconstitutional pattern of eonduct by the. persons referred to within this paragraph continues up to the present time, and unless the relief asked for herein is granted, it shall continue into the future, to the irreparable. harm of plaintiffs. 15 From almost the moment of the death of John y. Mills, defendants have engaged and are continuing to engage, in a systematic pattern of conduct, separately and tcgethor, which is calculated to and which does deprive the plaintiffs Of rights, privileges and immunities secured by the Constitu- ind in parti tion and laws cf the United States of America, cular said conduct deprives plaintiffs, in the criminal case pending against them, of the effective assistance of counsel Witnesses in thelr behalf, fair triai, due process of law, equal protection of law, and freedcm from bonds of slavery; unless the relief requested herein is granted, plaintiffs shall irreparably suffer loss and destruction of these rights, privileges and imnunities referred to herein.