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*. fb ap J 4 £. The compilation of information concerning them i inte dossiers maintained within the files of governmental ‘ departinents, agencies, and offices, and the use of said infor- te ees *| | mation for purposes unrelated to legitimate governmental 4 functions; i _ . ‘ Gi ~ -- ‘gs The implementation of counetyaiteaa is 72 lige >. | 7 programs against plaintiffs, including but not 'aintesd to of e gi FEI Cointclpro programs. : oo “sl 66. The conéuct described in Paragraphs 43 throligh 65 has 10} irreparably injured the plaintiffs in that it has deprived them oz au] rights secured to them by theBnited States Constitution and the ‘tall laws of the United States.4 4s 7 13] 67.by ‘virtue of said eepabct je because the defendants 14 promoted, encouraged, ordered, ‘Solicited, condoned, and ratifie Si . Se, 151 said conduct, the agents and employées/of the United States. “yell government, of local Police Departments, and of local District 7 Attorney Officcs have been led to belicve that they may enges : sel in said conduct “against Plaintiffs with impunity and without fear ; wo! of arrest, proséeution, conviction, @iscipline, or other unfevor- | oo! able consequences. S “Sy - 21 ; 68.Unless this court declares that such conduct is unlawful | and restrains the defendants, their agents, employees, successors, m=privies, and all persons acting in concert with them, from engagis: Re Promoting, soliciting er conspiring to cormit such conduct Re, ca conduct against the plaintiffs, they will continua to 26 |: _ Sugiersingediate and irreparable: injuries for which they have no 27 adequate’ remedy at law. . 69.The plaintiffs are informed and believe that the allegations contained in paragraphs 39 through 68 are true, and 30" they make said allegations on the basis of said information 31|| and belicEe. | - mo et aye ee eee eet 6. oe oma ngenn= SEE 6 eee = eli er - oe eee e ye — . — ae