2Plaintiffs, DANNY DONOHUE, as President of the Civil Service EmployeesAssociation, Inc., Local 1000, AFSCME, AFL-CIO; the CIVIL SERVICE EMPLOYEESASSOCIATION, INC., LOCAL 1000, AFSCME, AFL-CIO (hereinafter “CSEA”); JOHNDELLIO; MICHAEL BOULERIS; MAUREEN ALONZO, and MARCOS DIAMANTATOS, by their attorneys, Steven A. Crain and Daren J. Rylewicz (Aaron E. Kaplan, Miguel G. Ortizand Jennifer C. Zegarelli of counsel), as and for a Complaint, respectfully set forth as follows:
NATURE OF PROCEEDING
This is a civil rights class action, brought by Plaintiffs Danny Donohue, CSEA,John Dellio, Michael Bouleris, Maureen Alonzo and Marcos Diamantatos on behalf of themselves and all other similarly situated New York State Thruway Authority (“ThruwayAuthority”) CSEA represented employees, arising from Defendants’ termination of employment,demotion and forced retirement of approximately 60 CSEA represented Thruway Authorityemployees. This action seeks declaratory relief and damages brought pursuant to the UnitedStates Constitution and 42 U.S.C. §1983 to redress Defendants’ intentional violation of Plaintiffs’ constitutional rights to freedom of speech, freedom of association, due process andequal protection of the law under the First, Fifth and Fourteenth Amendments to the UnitedStates Constitution, along with violations of Article I, §17 of the New York State Constitution.
This Court has jurisdiction over this action pursuant to 28 U.S.C. §§1331 (federalquestion jurisdiction) and 1343(a) (civil rights jurisdiction) because this action is filed to obtainrelief for the deprivation, under color of state law, of the rights of citizens of the United Statessecured by the United States Constitution and federal law pursuant to 42 U.S.C. §1983. This