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Submitted at Anaheim City Council mee4inft
» z-cv-u'zb1-uar-bH uocumeni L4 rnea i zizun1 rage i y or zt rage iu #:266
charges; emotional distress and the loss of enjoyment of life,: for which Plaintiff is
`entitled to compensatory damageslas provided by law and subject to proof at trial.
32. Plaintiff is informed and believes and upon such information and belief
alleges that by reason of the foregoing, including his willful and intentional
misconduct, Defendant Sanders acted with reckless or callous disregard, and with
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,
Right of Assembly and Right to Due Process, with malice and oppression, and with
the intention of thereby depriving Plaintiff of his legal and constitutional rights or
otherwise causing injury; for which Sanders is liable to Plaintiff for an award of
punitive and exemplary damages
SECOND CLAIM FOR RELIEF
Violations of First Fifth, and Fourteenth Amendments and Article Section
2 of the California Constitution Regarding Enforcement of. Unconstitutional
"Rules of Decorum"
33. The foregoing allegations in Paragraphs 1 through 32 are incorporated into
the Second Claim for Relief as though fully set forth herein
34. The Rules of Decorum and their enforcement violate the First Amendment
because they contain provisions which constitute impermissible prior restraints on
speech. The terms are vague and lack adequate standards or guidelines for
enforcement. City officials have unbridled discretion to enforce these Rules. The
acts complained of herein were directed towards intimidating Plaintiff from the
lawful exercise of his constitutional rights.
35. The failure to enact laws and rules that give reasonable notice activities
subject to criminal penalties and the failure to adopt precise standards and
COMPLAINT
42 U.S.C. §1983
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