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WARDEN 2012 PROPOSED SECOND AMENDED COMPLAINT AGAINST TUCSON CITY OFFICIALS FOR CONSPIRACY AND MALICIOUS PROSECUTION

WARDEN 2012 PROPOSED SECOND AMENDED COMPLAINT AGAINST TUCSON CITY OFFICIALS FOR CONSPIRACY AND MALICIOUS PROSECUTION

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Published by Roy Warden
Tucson Community Political Activist Roy Warden Files a Proposed Second Amended Complaint Against Tucson City Officials, Charging Conspiracy and Malicious Prosecution. "I'm Going to Show the American Public Just How to Hold Their Public Officials Accountable," Warden Says.
Tucson Community Political Activist Roy Warden Files a Proposed Second Amended Complaint Against Tucson City Officials, Charging Conspiracy and Malicious Prosecution. "I'm Going to Show the American Public Just How to Hold Their Public Officials Accountable," Warden Says.

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Published by: Roy Warden on Aug 13, 2012
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02/24/2014

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Roy Warden, Publisher
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Common Sense II
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1015 West Prince Road
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#131-182
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Tucson Arizona 85705
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roywarden@hotmail.com
678
UNITED STATES DISTRICT COURT
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DISTRICT OF ARIZONA
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ROY WARDEN,Plaintiff,
 IN FORMAPAUPERIS 
 VsRICHARD MIRANDA, individually andn his official capacity as Chief of theTucson Police Department; MICHAELRANKIN, individually and in his officialcapacity as Tucson City Attorney; PA-RICIA MERHOFF, individually and inher official capacity as Chief ProsecutingAttorney for the City of Tucson; ALANMERRITT, individually and in his officialcapacity as Assistant Prosecuting Attorneyfor the City of Tucson; KATHLEEN RO-BINSON, individually and in her officialapacity as Assistant Chief of the TucsonPolice Department; KATHRYN DOR-MAND, individually and in her officialapacity as Officer of the Tucson PoliceDepartment; YOEL FRIEDMAN, indivi-dually and in his capacity as Officer of theTucson Police Department; FLORES,ndividually and in his capacity as Officerof the Tucson Police Department;KUGLER, individually and in his capacityas Officer of the Tucson PoliceDepartment; THE CITY OF TUCSON;THE TUCSON POLICE DEPARTMENT,a legal entity of the City of Tucson, andDOES 1-100,Defendants.))))))))))))))))))))))))))))))))))))CIV-11-0460-TUC-CKJ-(BPV)(PROPOSED) SECOND AMEN-DED COMPLAINT FOR INJUNC-TIVE AND DECLARATORY RE-LIEF AND COMPENSATORYAND EXEMPLARY DAMAGESFOR NEGLIGENT AND INTEN-TIONAL VIOLATIONS OF TITLE42 U.S.C. §1983, AND TITLE 42U.S.C. §1985THE HON. CINDY K. JORGENSONAND BERNARDO P. VELASCO
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COMES NOW the Plaintiff Roy Warden, with his (Proposed)
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Second Amended Complaint for Injunctive and Declaratory Relief, and
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Damages, against the Defendants, named and unnamed above, and as
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grounds therefore alleges:
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I. INTRODUCTION
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1.
 
This is an action pursuant to the Civil Rights Act of 1871, 42 U.S.C.
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§1983, 42 U.S.C. §1985 and 28 U.S.C. § 1343, seeking redress for
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the negligent and intentional deprivation of the Plaintiff’s constitu-
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tional rights. Venue is proper in the 9
th
District of Arizona, as all of 
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the acts complained of occurred in Pima County Arizona.
 
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II. JURISDICTION
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2.
 
This Court has jurisdiction over this action under 28 U.S.C. §
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1343(a)(3) for negligent and intentional violations of constitutional
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rights as provided by 42 U.S.C. §1983 and 42 U.S.C. §1985. The
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Plaintiff seeks injunctive relief, declaratory relief and monetary
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damages—including exemplary damages—as well as attorney fees
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and costs pursuant to 42 U.S.C. §1988.
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3.
 
The Plaintiff seeks redress for violation of the Plaintiff’s rights to
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speech, press, petition and assembly under the First Amendment of 
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the Constitution of the United States, the Plaintiff’s right to be free
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of illegal seizures under the Fourth Amendment of the Constitution
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of the United States, the Plaintiff’s right to be free from unlawful
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seizure, malicious prosecution and imprisonment as provided for by
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the Fourth and Fourteenth Amendments of the Constitution of the
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United States, and the Plaintiff’s right to due process of law as
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guaranteed by the Fourth and Fourteenth Amendments of the
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Constitution of the United States.
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III. REQUEST FOR JURY TRIAL
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4.
 
Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Plain-
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tiff requests a trial by jury.
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IV. IDENTITY OF THE PARTIES
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5.
 
Plaintiff Roy Warden, writer and publisher of political newsletters
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Common Sense II, CS II Press, Arizona Common Sense and
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Director of the Tucson Weekly Public Forum, is a citizen of the
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United States and was a resident of Pima County Arizona at all
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times relevant to this complaint.
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6.
 
Defendant Richard Miranda was employed by the City of Tucson,
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and acted individually and in his official capacity as Chief of the
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Tucson Police Department, under color of state law, regulations,
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customs and policies at all times relevant herein. Defendant
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Miranda is sued in his individual and official capacities.
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7.
 
Defendant Michael Rankin was employed by the City of Tucson,
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and acted individually and in his official capacity as Tucson City
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Attorney, under color of state law, regulations, customs and policies
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at all times relevant herein. Defendant Rankin is sued in his indi-
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vidual and official capacities.
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8.
 
Defendant Patricia Merhoff was employed by the City of Tucson,
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and acted individually and in her official capacity as Chief Prosecu-
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ting Attorney for the City of Tucson, under color of state law, regu-
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lations, customs and policies at all times relevant herein. Defendant
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Merhoff is sued in her individual and official capacities.
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9.
 
Defendant Alan Merritt was employed by the City of Tucson, and
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acted individually and in his official capacity as Assistant Prose-
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cutor for the City of Tucson, under color of state law, regulations,
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customs and policies at all times relevant herein. Defendant Merritt
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is sued in his individual and official capacities.
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10.
 
Defendant Kathleen Robinson was employed by the City of Tucson,
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and acted individually and in her official capacity as Assistant Chief 
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