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1:21CVO9O RP JON ROSENTHAL JAS MINE Orockeflt MARY ANN PEREZ ALMA I

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1:21CVO9O RP JON ROSENTHAL JAS MINE Orockeflt MARY ANN PEREZ ALMA I Case 1:21-cv-00690-RP Document 1 Filed 08/06/21 Page 1 of 7 22i iM SENFRONIA THOMPSON TRE-YMARTINEZ FISCHER GENE WIJ VIKKI GOODWIN RON REYNOWS EDDIE ROD1UG1WZ 1:21CVO9O RP JON ROSENTHAL JAS MINE OROCKEflT MARY ANN PEREZ ALMA I. AJJLEN CHRISTINA MORALES NICOLE COLLIER CELIA ISRAEL ANA-MARIA RAMOS BARBARA GERVIN-HAWKINS TERRYMEZA DONNA HOWARD JARVIS JOHNSON RJY LOPEZ SHAWN THIFRY ELIZABETH CAMPOS GINAHINOJOSA Plaint V. WAYNE ABBOTT, DADE PHELAN, AND JAMES WNTfl. Defendants cIs4PLATNT TO TIW hONORABLE JUL)GE AND MiRY: Case 1:21-cv-00690-RP Document 1 Filed 08/06/21 Page 2 of 7 L INTRODUCTION: and White have enbarked upon a course a. iNaintiffs will show that 'Ddendants Abbut;Pheian, of the of conductwhich'isintendedto'violate -State andFederal' Constitutional Rights under the First, Fifth, Plasntiffs and the classes of citizens they represent by denying rights and Fourteenth Amendments to the U.S. Constitution because of or white, (a) Race, in that certain Plaintiffs are either black every (l) Creed, in that certain Thitti have expressed. a faith or belief that eligible citizen'has-therightto-vote, melanin in (c) Color, in that certain Plaintiffs are distinguishahie hased upon the their kin, and born in (d) Natural origin, in that certain Plaintiffs are descendants of persons other countries. County, Texas. 2. i(s) Plaintiff .Senfrnnia Thonpson'is .aesi& fan'is Texas. (b) Piaintifl, Trey Martinez Fischer is a. resident of Bexar County, (c) Piaintifi Gene Wn is a resident of Hirns County, Texas. (d) NaintilT VikkiGoociwin is a resident of Travis Count Texas. (e) Plaintiff, Ron Reynolds is a resident. of Fort Bead County, Texas. (f) Piaintiff, 'Eddie Rodriguez is a resident of Travis County, Texas. Texas. (g) Plaintiff, Jon1Rosenthai is a resident of Harris County, Texas. (h) iaintit, Jasmine Crockett is a resident Of Travis County, () Plaintiff, 'Mary AunPe'rezis a resident .of'Harris County, Texas. Texas. (j) PLaintiff, Alma A. AlIen is a resident of Haths County, Texas. (k) Plaintiff, Christina Moraks is a resident o Harris County, Texas. (1) Plaintiff, Nicole Collier is a resident of Tarrant County, (m) Plaintiff, Celia Jsrael is a resident of Travis Co y, Texas.. (a) Plaintiff, Ana-Maria Ram,s is 5 resident of Tarrant County, Texas.. Case 1:21-cv-00690-RP Document 1 Filed 08/06/21 Page 3 of 7 (o) Plaintift, Barbara Gervin-Hawkins is a resident of Bexar County, Texas. (p) Plaintiff, Terry Meza is a resi&M of Dallas County, Texas. (q) Piaiiniff Thnna Howardis a resident off Travis County, Texas. (1) PlWnti(T, Jarvis khnsoii is a resident of R'arris Corinty, Texas. (s) Plaintiff, Ray Lopez is a resident of Bexar County, Texas. (t PiainthTfl, S1ra ThietTy is a resident of Harris County, Texas. (u) i!laintiff, Bizabeth Canpos is resident of Bexar County, Texas, and (v) Plaintiff, Gina Hiuojosa is a resident of Travis County, Texas. 3. Plaintiffs re victims of a discriminatory scheme to violate their Constitutional Right to Assemble to redress grievances; speak; vote; travel,, persuade members of th Congyess of the United States to help support them in their quest to obtain and maintain all of the rights guaranteed to them and their constituents and the class they represent. AlT because of their protected status. 4. This suit arises out of deiTherate acts of stat discrimination, as welT as discriminatory policies, customs, and practices, perpetrated by Defendants against Plaintiffs and the putative class, that have disparately impacted 'all persons of each individual Plaintiffs status group. The claims in this suit also Include damages resulting from actions taken against Plaintiffs because of their status. 5. Defendants collectivelyactedin concert-withoneanotherundercoloroflawlo cause-the iraun and damages alleged'ie 'this suit Defendants' conduct violates 'the iights protected in 42U.S.C.198i and Plaintiffs' First Amendment right to petition government because Defendants' pervasive, systematic, and widespread acts custom and practices of status discrimination are continuing against putative class members. Plaintiffs Include a request for class certification on behalf of others similarly situated. Some Plaintiffs also individually complain about retaliatory acts, threats, arid attempts at coercion reiatig to the exerdise of their First Amendment rights whiCh are enforceable under 42U.S.C.1983. 'Ii. PARTIES 6. (a) Plaintiff, Senfronia Thompson is a resident of Harris County, Texas. (b) Plaintiff, Trey MartinezFischeris aresidentof Bexar County, Texas. (c) Plaintiff, Gene Wu is a resident of Harris County, Texas. PlaIntiff, Vikki Goodwin i's a resident of Travis County, Texas. Case 1:21-cv-00690-RP Document 1 Filed 08/06/21 Page 4 of 7 County, Texas. (e) Plaintiff. Ron Reynolds is a resident of Fort Bend Travis County, Texas. (ly Plainti Mdi Rodrinez is aesittent of County, Texas. (g) Plaintiff, Jon osenthal is a resident ofHarris Texas, (h) Plaintiff. Yasaine Crockett is a resident of Travis County, Texas. (i) Piaintift Mary Ann Perez is a resident of Harris County, County, Texas. (j) Plaintiff, Alma A. Allenis aresident of Harris i) Plaintiff, Cbristina Morales is a resident of Harris County, Texas. County, ']exas. (1) P'laintiff NicóleCóllieiis a residt of Tarraut Texas. (m) Plaintiff, Celia Israel is a resident of Travis County, County, Texas. (n) Plaintiff, Ana-Mária Ramos is a resident o Tarrani County, Texas. (o) Plaintiff, Barbara Gervin-Hawkins is a resident of Bexar Texas. (p) Plaintiff, Terry Meza is aresidnt of Da1is Coiint, County, Texas. (q) P1ainti1l, Donna Howaftt is a resident of Travis Texas. (r) Plaintiff, Jarvis Johnson is a resident of Harris County, (s) itiRayLopez is a resident of exar County, Texas. Texas. (t) Plaintiff, .Sliawa Thierryis aesident of Maths County, County, Texas. (u) Plaintiff, Elizabeth Campos is a resident of Bexar Texas. (v) PIairititi Gina Hino,osa is a resident of Travis County, servant and:the di-e1cted Governor of the 7. Defendant, Gregory Wayne AbbOtt is a public Texas. -Service of processis -State of Texas, a-resident of Texaswho livesin TravisCounty, required. ly-elected Member of the Texas House of 8. Defendt, Dade Phelan is 'a pub ic servant 'and d is resident of Texas who lives Representatives who was elected Speaker of The House and a in iferson omity, Texas. Service of process is required. of the Texas House of Defenda, James W is a public servant and duly-elected Member 9. -Service al process-is Representative, a-resident of Texas-who lives-in TylerCounty, Texas. eqaired. Case 1:21-cv-00690-RP Document 1 Filed 08/06/21 Page 5 of 7 111. JURISDICTION AND VENUE 10. This action arises under Title 42 of the U.S. Oxk, Sections 1343, 1983, 1985 and 1988 and thisCourthasjurisdictiomoftheactiomunder Title 28 of theUS:Code,.Sections 1331, 1332 and 1343. 11. At all times pertinent to this complaint, the Defendant Giegory Wayne Abbott, was the Governor of Tbe State of Texas the Defendant Dade Pheran. was a Member of the Texas. House of Representative, and Speaker of The House of Representatives, and Defendant James White was a Member of the Texas House o Representative, andin ding the acts and? things hereinafter set forth, said Defendants were actin in their respectIve capacities as stated,-under color of-State Law. 12. Plaintiffs, and the classes they represent are thite, black, Asian, Hispanic, gay, and all .stthscribe to-the creed hind belief that.alt.citizens iA4io are otherwise eligible should be allowed to register and vote in all elections. 13. Defendants, individually and collectively, have embaiked upon -a course of action, scheme, conspiracy, and course o1 conduct, by-public statements and otherwiseto attemptto deny, coerce, threaten, mtnnidate and prevent Plamtiffs and The members of the classes Plaintiffs (1) the right to vote in all elections, (2) the right to peacefully assemble to redress their grievances, (3) the right to speak publicly about the exercise of their constitutional rights, (4) the right of association,, (5) the right to security of person, and -(6-) -therightto-freedonrfromarrest, exceptuponprobable cause, supportedby oath or affimation. 14. Plaintiffs allege that -in doing the acts and-things complained of, the Defendants were conspirator engaged in a scheme and conspiracy designed and intended to deny and deprive them of rights guaranteed to them under the Constitution and laws of the United States and -particularly those--herein above enumerated. F5. Plaintiffs allege-that, asadirect consequence andresultaftheacts ofDefendantsherein above contpithied of,Plaintif&have-beendeprived of iibeity for substantial periods of-time, suffered much anxiety and distress- over the separation from their families, and much discomfort and embarrassment and their reputations impaired,. and have lost much time from their homes and the companionship and care of their families and have been required to spend substantial sums of money ancloi lime traveling to and flom the Stale of Texas to persuade Congress to pass laws to ameliorate the harm done and redress their grievances. Wherefore, Plaintiffs cithii.damages of the Deferalatts il% the amount of Five Dollars ($5.00) in actual damages to themselves and the classes they tepn- nt and Ten Dollars ($10 00) in punitive damages to themselves and the classes they represent. Case 1:21-cv-00690-RP Document 1 Filed 08/06/21 Page 6 of 7 6c Nai'ntiffs a}Iege that because of the foregoing it was necessary to' obtain, seek, and ptoy 1eornseio seek redtess tmcler the CiiF R Atrn, Fees Act. MYE Ot LWJ Wherefore, Plaintiffs pray lhatthis Honorable Court 1. Mvanee reainig*r. 3. Order a Heaing onthëir reqiest kr a Temporary 'Injunction 4. Grant Temporary injunction after hear.ig evidence on the Mtion. En$oin the fendants from doing any act w'h àes or vioies thntiWs Cons( iona) Right& 6. Grant Pthnffs reasona&e attorney fees, 7.
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