COMPLAINT; Case No. _________
Attorney at Law, P.S.3002 Colby Avenue, Suite 306Everett, Washington 98201(425) 605-477412345678910111213141516171819202122232425
AFDI exercises its right to freedom of speech and promotes its objectives by,
, purchasing advertising space on transit authority property in major cities throughoutthe United States, including Seattle, Washington. AFDI purchases these advertisements toexpress its message on current events and public issues, particularly including issues involvingglobal terrorism (hereinafter referred to as “AFDI’s advertising campaign”).9.
Plaintiff Pamela Geller is the president of AFDI, and she engages in protected speech through AFDI’s activities, including AFDI’s advertising campaign.10.
Plaintiff Robert Spencer is the vice president of AFDI, and he engages in protected speech through AFDI’s activities, including AFDI’s advertising campaign.
Defendant King County is a municipal corporation. In the performance of itsgovernmental duties, Defendant King County operates a public transit system (King CountyMetro Transit), which includes more than 1,400 buses.12.
As a governmental agency, Defendant is mandated to comply with the First and Fourteenth Amendments to the United States Constitution and 42 U.S.C. § 1983.
STATEMENT OF FACTS
Defendant leases space on the exterior of its buses for use as advertising space.14.
Defendant accepts noncommercial and commercial advertisements for displayon its advertising space.15.
Defendant accepts noncommercial public service, public issue, and politicalissue advertisements, including advertisements on controversial issues, for display on itsadvertising space.16.
Defendant has leased its advertising space for political and social commentaryadvertisements covering a broad spectrum of political views and ideas.
Case 2:13-cv-01804 Document 1 Filed 10/07/13 Page 3 of 12