DISTRICT COURT, BOULDER COUNTY,COLORADO1777 Sixth StreetBoulder, CO 80206_______________________________________
ROB SMOKE;TIMOTHY TIPTON;JACK BRANSON;KATHERINE CUMMINS;EVAN RAVITZ;TOM CUMMINSPlaintiffs,v.UNIVERSITY OF COLORADO;Defendant.______________________________________
Attorneys for Plaintiffs:Robert J. Corry, Jr. #32705Travis B. Simpson #43858600 Seventeenth StreetSuite 2800 South TowerDenver, Colorado 80202303-634-2244 Telephone720-420-9084 FacsimileRobert.Corry@comcast.netwww.RobCorry.com
COURT USE ONLY
_____________________Case No: 2012CV_____
EXPEDITED HEARINGRESPECTFULLYREQUESTED
VERIFIED COMPLAINT AND APPLICATION FOR PRELIMINARYINJUNCTION AND DECLARATORY RELIEF
Plaintiffs, through undersigned counsel, hereby petition this Court for aPreliminary Injunction, and Declaratory and Equitable Relief, related to the University of
Colorado’s closing of the campus and Norlin
Quad on April 20, 2012 and intent to chargepeople with criminal violations for entering either campus or Norlin Quad, actions thatare designed to shut down the 420 Free Speech Protest, and that will impair
Plaintiffs’
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constitutional rights of Free Speech and Association, and that will cause irreparable harmand create a potentially dangerous and unsafe situation on campus, and as grounds stateas follows:
Parties
1. Plaintiff Rob Smoke is an individual, not a CU student, who wishes toparticipate in and exercise his constitutional rights of Free Speech and Free Associationon the CU Boulder campus on April 20, 2012 and use other campus facilities generallyopen to the public. Mr. Smoke has attended approximately six previous 420 Protests atCU, and in 2006 served on the City of Boulder Human Rights Commission which made
inquiry into CU’s stance against the 420 Protest by posting photos of students online and
offering rewards to students who became paid informants against 420 Protestparticipants.2. Plaintiff Timothy Tipton is an individual, not a CU student, who wishes toparticipate in and exercise his constitutional rights of Free Speech and Free Associationon the CU Boulder campus on April 20, 2012 and use other campus facilities normallyopen to the public. Mr. Tipton has attended approximately ten previous 420 Protests atCU, wishes to attend this year without receiving a citation, ticket, or arrest. He hasspoken in public assemblies at CU about marijuana policy.3. Plaintiff Jack Branson is an individual, not a CU student, who wishes toparticipate in and exercise his constitutional rights of Free Speech and Free Associationon the CU Boulder campus on April 20, 2012 and use other campus facilities normallyopen to the public. Mr. Branson is HIV-positive and suffers from numerous debilitating
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medical conditions. He has attended numerous previous 420 Protests at CU, wishes toattend this year without receiving a citation, ticket, or arrest, which he fears would harmhis condition which is exacerbated through stress.4. Plaintiff Katherine Cummins is an individual, not a CU student, whowishes to participate in and exercise her constitutional rights of Free Speech and FreeAssociation on the CU Boulder campus on April 20, 2012. She plans to attend her first420 Protest this year as a peaceful observer and use other campus services normally opento the general public. She fears an enhanced police presence could threaten the safety of herself and others.5. Plaintiff Evan Ravitz is an individual, not a CU student, who wishes toparticipate in and exercise his constitutional rights of Free Speech and Free Associationon the CU Boulder campus on April 20, 2012 and use other campus facilities normallyopen to the public. He has participated in past 420 Protests, and while there engaged inpolitical and associational activities such as gathering names for political activismpurposes.6. Plaintiff Tom Cummins is an individual, not a CU student, who wishes toparticipate in and exercise his constitutional rights of Free Speech and Free Associationon the CU Boulder campus on April 20, 2012 and use other campus facilities normallyopen to the general public. Mr. Cummins is a 65-year old retired grandfather who wishesto attend this year without receiving a citation, ticket, or arrest and fears that theblockades and enhanced police presence may threaten his safety.7. Defendant University of Colorado
(“CU”)
is a state governmental entity
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