Law for admitted December 2005 "strike" participation (b) Denial of Plaintiff's TaylorLaw Complaint # U-28203 by P.E.R.B. against the Authority, 2008. Plaintiff is, andwas for the preceding eight (8) years, a Train Operator and Transport WorkersUnion Local 100 Union Member. For most of that time Plaintiff was and is a ShopSteward (recognized by Authority by Stipulation) and/or Active Member of saidUnion.

VENUE(3)

As to proper venue, plaintiff resides in New York County and AuthorityHeadquarters is/are in New York County.

KLU KLUX KLAN V. NOTRE DAME(4)

Plaintiff has no evidence and will neither include or request any evidence viadiscovery regarding past, present or prospective active member status by relevantState Actors as a Kleagle (see Senator Robert Byrd), Kloreroe, Klabee, Kludd,Kligrapp, etc. of The Knights of The Invisible Empire (K.K.K.). Petitioner holds nointerest in denying said State Actors their First Amendment rights and con

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rmssworn pledge to uphold and defend the Constitution against all enemies, foreignand domestic.

"Monsieur l'abbé, je déteste ce que vous écrivez, mais je donnerai ma vie pour que vous puissiez continuer à écrire" Voltaire

. Petitioners ethnicity isIrish-American and a con

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rmed/practicing (Roman) Catholic, and additionally thegrandson of immigrants and the son of a former seminarian. The signi

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cantmajority of TWU members covered by the Taylor Law are, upon information andbelief, of African-American and/or Caribbean-American or immigrant and/or otherimmigrant status or race and/or Jewish, Catholic (Irish etc,) ethnicity and/or religion

historically and legally discriminated against (see

Dred Scott v. Sandford, 60 U.S.(How. 19) 393 (1857)

Plessy v. Ferguson, 163 U.S. 537 (1896)).

This fact isknown to defendants. While not disputing Defendant State Actor's right to be or notto be active members of The Invisible Empire, it is Defendants passing, upholding,enforcing the discriminatory and unconstitutional Taylor Law, which has the sameoutcome as the philosophy of the Klan, that is unlawful. The Klan is Anti-Union,Anti-Catholic, Anti-African-American, Anti-Immigrant, Anti-Semitic, etc.. Defendantsongoing unconstitutional banning of "strike"/speech, violations of Freedom ofAssembly, Disparate Treatment/Impact, Excessive/Ruinous Fines, lack of DueProcess, no Jury Trial, Unequal Protection, forced work without valid currentcontract, compared to identically/similarly situated fellow employees not covered byTaylor Law are unlawful. Plaintiff, upon information and belief, has no standing toquestion constitutionality of Taylor Law vis-à-vis non MTA Departments, agenciesand or Authorities, but may solicit Amicus Curiae status by same by leave of Court.

Dred Scott v. Sandford, 60 U.S. (How. 19) 393 (1857)

(5) Plaintiff, never having been convicted of a crime, is covered by the ThirteenthAmendment to the United States Constitution, as well as, upon information andbelief, virtually all or all colleagues under Taylor Law writ. Petitioner contends thatthe Taylor Law's requirement that Local 100 work without a contract and during a"strike" constitute "involuntary servitude" by de

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nition. No contract no work.(6) Petitioner contends that the attempted and/or actual prior restraint of "strike","work to rule" "work slowdown" and/or other job actions constitute prima faciaviolations of the First Amendment to the United States Constitution. In addition,