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WARDEN v WALKUP, KOZACHIK, MIRANDA, RANKIN, RIOJAS, THE CITY OF TUCSON, ETC FIRST AMENDED COMPLAINT

WARDEN v WALKUP, KOZACHIK, MIRANDA, RANKIN, RIOJAS, THE CITY OF TUCSON, ETC FIRST AMENDED COMPLAINT

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Published by Roy Warden
WARDEN SERVES LAWSUIT CHALLENGING TUCSON'S "CIVILITY ACCORD" ALLEGING CONSPIRACY TO VIOLATE CONSTITUTIONAL RIGHTS
WARDEN SERVES LAWSUIT CHALLENGING TUCSON'S "CIVILITY ACCORD" ALLEGING CONSPIRACY TO VIOLATE CONSTITUTIONAL RIGHTS

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Published by: Roy Warden on Aug 22, 2013
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08/24/2013

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Roy Warden, Publisher
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 Arizona Common Sense
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3700 S. Calle Polar
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Tucson Arizona 85730
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roywarden@hotmail.com
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UNITED STATES DISTRICT COURT
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DISTRICT OF ARIZONA 
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ROY WARDEN,Plaintiff,
In Pro Se
 VsBOB WALKUP, individually and inhis official capacity as Tucson CityMayor; STEVE KOZACHIK, indivi-dually and in his official capacity asTucson City Councilman; RICHARDMIRANDA, individually and in hisofficial capacity as Tucson City Man-ager; MIKE RANKIN, individuallyand in his official capacity as TucsonCity Attorney; ANTONIO RIOJAS,individually and in his official capa-city as Tucson City Court Judge;ROBERTO VILLASENOR, indivi-dually and in his official capacity asChief of the Tucson Police Depart-ment; KATHLEEN ROBINSON, in-dividually and in her official capa-city as Assistant Chief of Police; TPDOfficer Couch, individually and inhis official capacity as Officer of theTucson City Police Department;THE CITY OF TUCSON; and DOES1-100,Defendants.))))))))))))))))))))))))))))))))))Case No. CIV 13-283 TUC DCBFIRST AMENDED COMPLAINTFOR INJUNCTIVE AND DECLAR- ATORY RELIEF, AND COMPEN-SATORY AND EXEMPLARY DAM- AGES FOR NEGLIGENT AND IN-TENTIONAL VIOLATIONS OF TI-TLE 42 U.S.C. §1983, AND TITLE42 U.S.C. §1985
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COMES NOW the Plaintiff Roy Warden, with his Complaint
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for Injunctive and Declaratory Relief, and Damages,
 
against the
 
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 2
Defendants, named and unnamed above, and as grounds therefore
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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
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U.S.C. §1983, 42 U.S.C. §1985 and 28 U.S.C. § 1343, seeking
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redress for the negligent and intentional deprivation of the
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Plaintiff’s constitutional rights. Venue is proper in the 9
th
 
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District of Arizona, as all of the acts complained of occurred in
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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 constitu-
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tional rights as provided by 42 U.S.C. §1983 and 42 U.S.C.
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§1985. The Plaintiff seeks injunctive relief, declaratory relief 
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and monetary damages—including exemplary damages—as
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well as attorney fees and costs pursuant to 42 U.S.C. §1988.
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3.
 
The Plaintiff seeks redress for violation of the Plaintiff’s
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rights to speech, press, petition and assembly under the First
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 Amendment of the Constitution of the United States, the
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Plaintiff’s right to be free of illegal seizures under the Fourth
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 Amendment of the Constitution of the United States, the
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Plaintiff’s right to be free from unlawful seizure, malicious
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prosecution and imprisonment as provided for by the Fourth
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and Fourteenth Amendments of the Constitution of the
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United States, and the Plaintiff’s right to due process of law
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as guaranteed by the Fourth and Fourteenth Amendments of 
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the 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,
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Plaintiff requests a trial by jury.
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IV. IDENTITY OF THE PARTIES
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5.
 
Plaintiff Roy Warden, community activist, writer and publish-
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er of political newsletters Common Sense II, CS II Press,
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 Arizona Common Sense and Director of the Tucson Weekly
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Public Forum, is a citizen of the United States and was a
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resident of Pima County Arizona at all times relevant to this
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complaint.
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6.
 
Defendant Bob Walkup was employed by the City of Tucson,
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and acted individually and in his official capacity as Tucson
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City Mayor, under color of state law, regulations, customs and
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policies at all times relevant herein. Defendant Walkup is
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sued in his individual and official capacities.
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7.
 
Defendant Steve Kozachik is employed by the City of Tucson,
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and acted individually and in his official capacity as Council-
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man for the City of Tucson, under color of state law, regula-
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tions, customs and policies at all times relevant herein.
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Defendant Kozachik is sued in his individual and official
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capacities.
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8.
 
Defendant Richard Miranda is employed by the City of 
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Tucson, and acted individually and in his official capacity as
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City Manager of the City of Tucson, under color of state law,
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regulations, customs and policies at all times relevant herein.
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Defendant Miranda is sued in his individual and official
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capacities.
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