May 15, 2013 in front of the
Place, Defendant employed Nicole Rizzi,identifying
to participate in the protest and hand out fliers.11.
was, a peaceful, lawful protest. On information and belief, MPD had no reason to believeany illegal activity would take place at the May 15, 2013 protest, and in fact no illegalactivity took place at the May 15, 2013 protest.12.
store at 1120 Connecticut Avenue, Defendant employed Nicole Rizzi, identifying herself
was, a peaceful, lawful protest. On information and belief, MPD had no reason to believeany illegal activity would take place at the June 29, 2013 protest, and in fact no illegalactivity took place at the June 29, 2013 protest.14.
District of Columbia.
protesters by carrying banners, handing out flyers, chanting, and otherwise participatingin the protest.15.
Under the District of Columbia Police Investigations Concerning FirstAmendment Activities Act of 2004,
any undercover activities shall be authorized asrequired by § 5-
-333.10. Under D.C. Code § 5-333.07,
investigation or preliminaryinquiry after written approval and authorization is obtained from the Chief of Police or