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At the United States District Court for the Eastern District of New York Long Island Courthouse 100

Federal Plaza Central Islip, NY 11722-4438 on the ___ day of ____________ UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK ---------------------------------------X _______________________________[name], Plaintiff[s], -againstCOMPLAINT

COUNTY OF SUFFOLK, OFFICER , AND SERGEANT _________________________, BOTH OF THE SUFFOLK COUNTY PARK POLICE Defendants. ---------------------------------------X Now then comes plaintiffs Attorney ______________________________________of address: for Plaintiff _________________________________________, an individual citizen residing at _______________________________________________________ 1. Plaintiff ________________________________________ is a Candidate for , in the District. 2. As a precondition to having a place on the ballot he must gather 3500 signatures from registered voters. 3. Defendants are a. The COUNTY OF SUFFOLK, H. Lee Dennison Building, Veterans Memorial Highway, Happauge, NY 11788 and b. Officer _______________________, and c. Sergeant _____________________________, both of the Suffolk County Park Police. 4. Jurisdiction is under sections 1983 and 1988 of the Civil Rights Act, violations of civil rights pursuant to 42 U.S.C. 1983, the First and Fourteenth Amendments to the Constitution of the United States - the Right to Petition; and is a Federal question. 5. Jurisdiction is also under the following statutes: 6. United States Code, Title 18. Crimes and Criminal Procedure, Chapter 29Elections and Political Activities, Sections: 7. 595 - Whoever, being a person employed in any administrative position... 8. 241 - Conspiracy, 9. 245 - Federally protected activities 10. 42 U.S.C. Section 1985. Conspiracy to interfere with civil rights (3) Depriving persons of rights or privileges 11. 42 U.S.C. Section 1988 (b) Attorney's fees

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42 U.S.C. Section 2000b-2. Personal suits for relief against discrimination in public facilities. At approximately [time & date]_____________, officer of the Suffolk County Park Police approached me while I was petitioning. He asked me what I was doing, and I told him that I was running for , and that I was asking voters if they would sign my ballot access petition. He told me that wasnt allowed, and I assured him both the Constitution of the United States, as well as State and Federal Civil and Criminal laws assured that I could, and I attempted to show him the paper I printed out from here http://rochesterlp.net/documents/Petition-Federal-Civil-Rights-Law.pdf Further facts:

. 15. The Above constitute violations of Plaintiffs Civil Rights. Wherefore: 1) Defendants should be immediately preliminarily enjoined from further engaging in attempts to stop any independent petitioner from petitioning on Suffolk County Property. 2) Defendants should be permanently enjoined from further engaging in attempts to stop any independent petitioner from gathering signatures on any Independent Nominating Petition on Suffolk County Property. In addition, Defendant Suffolk Countys Board of Elections should be enjoined to place the Plaintiff on the Ballot as a remedy for interfering with his Petitions. Judgment should be entered for Plaintiff in the amount of Ten- thousand ($10,000.00) Dollars, together with the maximum interest allowed by law, in remedy of: the Civil Rights Intentional Tort. Judgment should be entered for Plaintiff in the amount of Ten- thousand ($10,000.00) Dollars, together with the maximum interest allowed by law, in remedy of: the common law tort of assault, in that defendants placed the Plaintiff in reasonable apprehension of the harmful and offensive contact attending the threatened false arrest. Judgment should be entered by the Court for legal fees pursuant to Title 42 U.S.C. 1988. signed: address: for Plaintiff
2 page sample - before filing at Court: Adjust all margins to 1"; doublespace all text. D:\CGarvey\C\Cantwell v. Suffolk\Complaint-Sample.wpd

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