General (6)t;ase z i z-cv-u /zbl-uz5r-z5h uocumeni L4 r-nea i uzun z rage i u or « rage iu #:;ej3
70mitted at Anaheim City Council meetin
Item#
1 charges;I emotional distress and the loss of enjoyment of life, for which Plaintiff is
2 entitled to compensatory damages�as provided by law and subject to proof at trial.
32. Plaintiff is informed and believes and upon such information and belief
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alleges that by reason of the foregoing, including his willful and intentional
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6 misconduct, Defendant Sanders acted with reckless or callous disregard, and with
7 deliberate indifference, for Plaintiffs constitutional rights, with an evil motive or
intent to censor Plaintiff and prevent him from exercising his Right to Free Speech,
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9 Right of Assembly and Right to Due Process, with malice and oppression, and with
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the intention of thereby depriving Plaintiff of his legal and constitutional rights or
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otherwise causing injury; for which Sanders is liable to Plaintiff for an award of
12 punitive and exemplary damages
13 SECOND CLAIM FOR RELIEF
14 Violations of First, Fifth and Fo rteenth Amendments and Article Section
15 2 of the California Constitution, Regarding Enforcement of _Unconstitutional
"Rules of Decorum"
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33. The foregoing allegations in Paragraphs 1 through 32 are incorporated into
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the Second Claim for Relief as though fully set forth herein
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19 34. The Rules of Decorum and their enforcement violate the First Amendment
20 because they contain provisions which constitute impermissible prior restraints on
21 speech. The terms are vague and lack adequate standards or guidelines for
22 enforcement. City officials have unbridled discretion to enforce these Rules. The
23 acts complained of herein were directed towards intimidating Plaintiff from the
24 lawful exercise of his constitutional rights.
25 35. The failure to enact laws and rules that give reasonable notice activities
26 subject to criminal penalties and the failure to adopt precise standards and
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28
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COMPLAINT 42 U.S.C. § 1983 �