This civil rights action is brought to remedy defendants', individually and in their official capacity, unlawful activity, practices and policies 1) of suppressing plaintiff's First Amendment Rights regarding the reporting of criminal matters and matters of public concern; 2) conspiring with others to suppress plaintiff's First Amendment Rights regarding the reporting of criminal matters of public concern; 3) violations under Monell; and retaliatory actions against Plaintiff for exercising his First Amendment Rights. Plaintiff seeks general, compensatory, statutory damages, injunctive relief, prejudgement interest, costs, and attorney's fees and other appropriate remedies resulting from the defendants' unlawful and tortious conduct as alleged herein.
Jurisdiction and Venue
1. This action is brought pursuant to the First (1st) and Fourteenth (14th) Amendments to the U.S. Constitution, 42 U.S.C. Sections 1983, 1985 and 1988, and the Cal.Labor Code Section 1102.5 (whistleblower statutes). This Court has personal jurisdiction over defendants because they are residents of and/or doing business in the State of California, County of Los Angeles. The amount in controversy exceeds $75,000 exclusive of interest and costs. Plaintiff's California state law claim is brought pursuant to 28 U.S.C. section 1367.
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