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WARDEN v. MIRANDA, RANKIN, CITY OF TUCSON, ET AL, 2011

WARDEN v. MIRANDA, RANKIN, CITY OF TUCSON, ET AL, 2011

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Published by Roy Warden
Tucson Activist Roy Warden's 2011 Federal Lawsuit Alleges High Level Tucson City Officials Have Conspired to Deny First Amendment Rights For More Than a Decade
Tucson Activist Roy Warden's 2011 Federal Lawsuit Alleges High Level Tucson City Officials Have Conspired to Deny First Amendment Rights For More Than a Decade

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Published by: Roy Warden on Nov 21, 2011
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01/29/2013

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 1
Roy Warden, Publisher
1
Common Sense II
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1015 West Prince Road
3
#131-182
4
Tucson Arizona 85705
5
roywarden@hotmail.com
67
UNITED STATES DISTRICT COURT
8
DISTRICT OF ARIZONA
910
ROY WARDEN,Plaintiff,
 IN FORMAPAUPERIS
 VsRICHARD MIRANDA, individually and inhis official capacity as Chief of the TucsonPolice Department; MICHAEL RANKIN,individually and in his capacity as TucsonCity Attorney; KATHLEEN ROBINSON,individually and in her official capacity asAssistant Chief of the Tucson PoliceDepartment; DORMAND, individually andin her capacity as Officer of the TucsonPolice Department; FRIEDMAN, indivi-dually and in his capacity as Officer of theTucson Police Department; FLORES,individually and in his capacity as Officerof the Tucson Police Department;KUGLER, individually and in his capacityas Officer of the Tucson Police Depart-ment; THE CITY OF TUCSON; THETUCSON POLICE DEPARTMENT, alegal entity of the City of Tucson, andDOES 1-100,Defendants.)))))))))))))))))))))))))))))))Case No. CIV 11-460 TUC BPVFIRST AMENDED COMPLAINT FORINJUNCTIVE AND DECLARATORYRELIEF AND COMPENSATORY ANDEXEMPLARY DAMAGES FOR NEG-LIGENT AND INTENTIONAL VIOLA-TIONS OF TITLE 42 U.S.C. §1983AND TITLE 42 U.S.C. §1985
11
COMES NOW the Plaintiff Roy Warden, with his Complaint for
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Injunctive and Declaratory Relief, and Damages, against the Defendants,
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named and unnamed above, and as grounds therefore alleges:
141516
 
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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 and imprisonment as provided for by the Fourth and Four-
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teenth Amendments of the Constitution of the United States, and the
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Plaintiff’s right to due process of law as guaranteed by the Fourth
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and Fourteenth Amendments of the Constitution of the United
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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.
262728
 
 3
IV. IDENTITY OF THE PARTIES
1
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
4
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 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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of the Tucson Police Department, under color of state law, regula-
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tions, customs and policies at all times relevant herein. Defendant
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Robinson is sued in her individual and official capacities.
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9.
 
Defendant Dormand was employed by the City of Tucson, and
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acted individually and in her official capacity as Officer 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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Dormand is sued in her individual and official capacities.
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10.
 
Defendant Friedman was employed by the City of Tucson, and
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acted individually and in his official capacity as Officer of the
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