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Senator Edward Kennedy — Part 25
Page 85
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consecutive years; that during these eighteen (18) years routinely
and systemically denied, plaintiff a hearing, despite assertedly
overwhelming documentary evidence... ." Plaintiff’s Complaint,
p. 10. Plaintiff believes that all named defendants, over 225 in
number, conspired together to deprive plaintiff of his
constitutional rights. "Conspiracy allegations must, contain
sufficient specificity and factual support to suggest a neeting of
the minds. It is incumbent upon plaintiff to allege with at least
‘some degree of particularity overt acts which defendants engaged in
‘which were reasonably related to the promotion of the claimed
conspiracy." o'Dell_v. McSpadden, 780 F. Supp. 639, 645 (E.D. Mo.
1991), aff'd, 994 F,2a 843, cert. denied, 114 S. Ct. 260 (citations
onitted). .
__ Based upon the above discussion, the allegations of
plaintiff’s complaint are insufficient to suggest a conspiracy.
Plaintiff's complaint, states, in the most vague and general terms,
that, defendants engaged _,in.a conspiracy to deprive plaintiff of his
constitutional rights. Nowhere in his seven amended complaints
‘does plaintiff suggest facts ‘which would support a meeting of the
minds or any overt acts performed by defendants in furtherance of
“ee
the alleged conspiracy.? Therefore, plaintiff has not met his
x 1 ww
burden of proof and his complaint should be dismissed. See @€-.gG.,
Deck vy. Leftridge, 771 F.2d 1168, 1170 (8th Cir. 1985).
uaz. 2 For example,.as to three of the named defendants plaintiff -
states, "(t]hat Defendant, Moore did conspired with First American
‘Title Insurance Co., Gundaker Realty Co., and other persons to and
dia Extorted money from Plaintiff, its wife and children without
jotice ‘or hearing to the Plaintiff". (sic).
: - 9
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