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Super at ey: aes Ey af — r thea Mb riylie FAVS TENA es ee: wre Por Ce, Deemer MM Mer) Reed BE eee eet ae lee . Pala e. oy) 2g a. i ! | { t { 1}! 39.Each of the defendants, their agents: and employees and or es ee 2) those acting in concert with them participated in and/or coreni.t 3! ti caused and/or promoted the conduct set forth below under the | . 4 color and pretense of federal, state and local law, to wit, the- 1 : Sse statutes, ordinances, rules, yeguiations, rulings, customs, wFet ee the District of Columbia, the 50 states, particularly the State; ef California, the City and County of Los Angeles and/or “their | 40-At all times material herein, each of the defendants, th agents and employees and those acting in concert with them specifically intended to and did unlawfully, wilfully, knowingl: | corruptly, maliciously, discriminatorily, arbitrarily, and if bad faith abrogate, usurp and misuse the power, authority, offi: resources and jurisdiction of the government of the United Stat: the District of Columbia, the 50 States, particularly the State : of California, the City and County of Los Angeles, and/or their 18], departments, agencies and offices. 19) 41.At all times material herein, the defendants, their agen 20' and employees and those acting in concert with them acted palpa! 21 and Manifestly outside their lawful jurisdiction and discretion 2 the lawful scope of their authority and their lawful line of ¥ | 23}, duty. | 42.fach of the defendants, their agents and employees and ; 25 those acting in concert with them participated in and/or commit. 26" caused and/or promoted the conduct set forth below in the Centr: 27 jj. Wistrict of California or knew or reasonably should naverforesel ) 28 | that said conduct would take place or cause.effects upon plain: t ; ; 23! t¢fFfs in the Central District of California. * i i 30). 43.Beginning on or about May 20, 1974 and continuing throug) i] ‘ . 1 31 the present, defendants and each of them, and their agents, 321) / . a _ tty or aig ee Jans on ay ee est) oo: ee ae