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> O ' . unlawfully, wilfully, knowingly, corruptly, maliciously, ae wed 2} discriminatorily, arbitarily, and in bad Zaith and without. aps 3 probable, reasonable or any legitimate cause therefor committed, | ob ; 4{) aided and abetted, caused, ordered, authoxvized, financed, ot - ae solicited, encouraged, approved, consented to, condoned ‘and/or: ‘§i otherwise promoted, with specific intent to do so, the conduct 7\| set forth above in paragraphs 39 through 68, among others. 8 THIRD CAUSE_OF_ ACTION re) 74.This is a cause of action to redress neglect and refusal 10! to prevent a conspiracy to deprive the plaintiffs of their "| xights secured to them by the Constitution, including the equal : Heo 12;} protection of the laws and equal privileges and immunities RT 13} under the laws, and by the laws of the United States, and to _ 44j| prevent the deprivation of such rights. 15 75.This cause of action is authorized by the First, Fourth, agl| Fifth, Sixth, Eighth, Ninth, Tenth and Fourteenth Amendments 17 te the United States Constitution, by 42 U.S.C. SS 1983, 1985, 48l| 1986 and 1988, and by 18 U.S.C. -€§ 2510-20 oe - 19 -76,The plaintiffs reallege and incorporate by this reference, | 20}) as if fully set forth herein, each and every allegation nt 21] in paragxaphs 39 through. $8 of the First Cause of Action and pare! 22|| graphs 70 through 73 of the Second Cause of Action. 23 77.The defendants each had knowledge of said conspiracy and 24\| each had the duty and the power to prevent or aid in preventin 25|, said wrongs and acts that were the objects of the conspiracy. 26 78.Said defendants and each of them, each unlawfully, wil- 27]| fully, knowingly, corruptly, maliciously, aiscriminatorily, 28|| arbitrarily and in bad faith neglected and refused to prevent or Eo SB 23h aid in preventing the commission of said wrongs and acts. 324 ee r mond et EBLE