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IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS

DEMETRICK PENNIE a Natural Person and Resident of Texas, and Sergeant in the Dallas Police Department, on behalf of himself and other law enforcement officers deceased or alive similarly situated and LARRY KLAYMAN, a Natural Person and Resident of Florida, on behalf of himself and other law enforcement officers deceased or alive similarly situated Plaintiffs, v. LOUIS FARRAKHAN, a Natural Person, and Minister and Leader of Nation of Islam 7351 South Stony Island Avenue Chicago, Illinois 60649 and NATION OF ISLAM 7351 South Stony Island Ave. Chicago, IL, 60649 and REVEREND AL SHARPTON, a Natural Person, and founder and President of the National Action Network 106 W. 145th Street Harlem, New York 10039 and NATIONAL ACTION NETWORK, 106 W. 145

th

Street Harlem, NY, 10039

AMENDED COMPLAINT

Civil Action No. 3:16-cv-02010

Case 3:16-cv-02010-L Document 16 Filed 09/16/16 Page 1 of 66 PageID 239

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and BLACK LIVES MATTER, a Nationwide organization and RASHAD TURNER a Natural Person, and leader of the Black Lives Matter movement and OPAL TOMETI, a Natural Person, and co-founder and leader of the Black Lives Matter movement and #blackLivesMatter network and PATRISSE CULLORS, a Natural Person, and co-founder and leader of the Black Lives Matter movement and #blackLivesMatter network and ALICIA GARZA, a Natural Person, and co-founder and leader of the Black Lives Matter movement and #blackLivesMatter network and DERAY MCKESSON a Natural Person, and leader of the Black Lives Matter movement and JOHNETTA ELZIE a Natural Person and leader of the Black Lives Matter movement and


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NEW BLACK PANTHERS PARTY Washington, DC and MALIK ZULU SHABAZZ a Natural Person, and leader of the New Black Panther Party and GEORGE SOROS a Natural Person and financier of the Black Lives Matter movement and BARACK HUSSEIN OBAMA, acting as President of the United States of America 1600 Pennsylvania Avenue Washington, D.C. 20500 and ERIC HOLDER, a Natural Person, and former Attorney General of the United States of America Covington & Burling LLP One City Center 850 Tenth Street, NW Washington, DC 20001-4956 and HILLARY CLINTON, a Natural Person, and former Secretary of State of the United States of America, and a resident of New York Defendants.

AMENDED COMPLAINT
