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1. _JURIS DICTION _ AQ. THe JURISDICTION OF THIS COURT 1S INVOKED UNDER | Tirrte 28 U. S. C. 1343: 2U.8. C.1985 (1, 2, 3): AmTicLres , ONE FOUR ,SEVEN, EIGHT AND THE FouRTEENTH AMENDMENT OF THE Bitt or RIGHTS, THE AMOUNT IN CONTROVERSY EX CEEDS THE SUM OF FIFTY THOUSAND (50,000.00) votrars » EXCLUSIVE @F INTEREST AND COSTs, B). CONCURRING JURISDICTION I§S INVOKED UNDER ARTICLE I1! OF THE UNITED Sratres Constitution: Titre 18 uv. gs. co 2520 and 11 28 Us. S.C. 1331: 1332 ano 2 U. S.C. 1981 & 1983, edn ee ah te al 11. Crass ASTION A)e Viratt CARTER BRINGS THIS ACTION ON HIS OWN BEHALF AS : A VOTER AND ON BEHALF OF ALL REGISTERED VOTERS OF COLOR AND/OR PERS@®NS IN THE UNiITEO STATES StmtLaRLy SITUATED, PURSUANT te Rute 235 oF Feoe Re Civ. Pro.w- THE PREREQUISITES AND CONDITIONS OF THAT RULE AS SET OUT IN sup-seotion (a) (es) (1): (8) (2) ano (w) (3) HAVE BEEN SATISFIED. B). THERE ARE GOMMON QUESTIONS OF LAW ANO FACT AFFECTING THE RIGHTS OF SUCH PERSONS TO BE FREE FROM VIOLATION OF THEIR ConsTUTUTIONAL AND STATUTORY Cirvin Reentrs BY PERSONS ACTING IN- A CONSPIRACY TO VIOLATE SAID RIGHTS ( AS SET OUT MORE FULLY IN SECTION IV speLtow 0. THE NUMBER OF PLAINTIFFS IS SO NUMEROUS AS TO MAKE !§T EMPRACTICAL TO BRING THEM ALL BEFORE THIS CouRT. THE CLAIMS OF THE PLAINTIFFS ARE TYPICAL OF CLASS as 1S THE RELIEF REQUESTED AGAINST DEFENDANTS. THE PROSECUTION OF SEPERATE ACTIONS BY SNOSVIDUAL MEMBERS OF THE CRASS WOULD CREATE A RISK OF = . (1) INCONSISTENT OR VARYING ADJUDICATIONS WITH ¢ RESPECT TO {tNDIVIDUAL MEMBERS OF THe CLASS, OR (2) AduuDAcATIONS WITH RESPECT TO INDIVIDUAL MEMBERS. @F THE CLASS WHICH WOULD AS A PRACTICAL MATTERS BE OISPOSITIVE OF THE INTEREST OF THE MEMBERS NOT PARTIES. Cc). FURTHERMORE, THE DEFENDANTS, BY THEIR ACTION, WH,GH Is |} tS THE BASIS OF THIS SUIT, HAVE ACTED ON GROUNDS APPLICABLE TO THE CRASS AS A WHOLE, ANDO THEREFORE, CLASS = WIDE RELIEF 1S PROPER, st