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 RON REYNOWS EDDIE ROD1UG1WZ 1:21CVO9O RP JAS MINE OROCKEflT ALMA I. AJJLEN ANA-MARIA RAMOS BARBARA GERVIN-HAWKINS TERRYMEZA RJY LOPEZ SHAWN THIFRY GINAHINOJOSA

Plaint

V.

WAYNE ABBOTT, , 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, . 2. i(s) Plaintiff .Senfrnnia Thonpson'is .aesi& fan'is Texas. (b) Piaintifl, 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, 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, is a resi&M of 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, 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, is a resident of Harris County, Texas.

(b) Plaintiff, Trey MartinezFischeris aresidentof Bexar County, Texas.

(c) Plaintiff, 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. Grant P1intflTa a1aiidpunitive damages, and

Such other nd fui*her I ad&ttonat ztematwe az$ ecw1abk relief as may to the Cowt to whith they iva be tjt. Case 1:21-cv-00690-RP Document 1 Filed 08/06/21 Page 7 of 7

SPE FULLY SUBMITTED,

THE C 0 IONY WAS1NGTON LAW FIRM ATTORNE PLAINTIFFS SBOT# 20901000 P.O. BOX 3(16 BASTROP, TEXAS

OF COUNSEL, EGUREN & DICKSON 1018 PRESTON AVENUE -SEVENTH FLOOR , TEXAS 77CO2 (713) 223-5959 Telephone (713) 223-9231 Facsimile [email protected] Case 1:21-cv-00690-RP Document 1-1 Filed 08/06/21 Page 1 of 2

JS 44 (Rev. 06/17) CIVIL COVER SHEET The iS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NE/CT PAGE OF THIS FORM) I. (a) PLAINTIFFS DEFENDANTS Senfronia Thompson et a! Abbott et a!

(b) County of Residence of First Listed Plaintiff County of Residence of First Listed Defendant (EXCEPT IN U.S. PLAINTIFF CASES) (IN US. PLAINTIFF CASES ONLY) NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE TRACT OF LAND INVOLVED.

(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known) i:21CV0690 RP

II. BASIS OF JURISDICTION (Place an "X" in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an "X" in One Box far Plaintff (For Diversity Cases Only) and One Boxfor Defendant) ci I U.S. Government 3 Federal Question PTF DEF PTF DEF Plaintiff (U.S. Government Not a Party) Citizen of This State ci 1 ci I Incorporated or Principal Place ci 4 ci 4 of Business In This State

ci 2 U.S.Govermnent ci 4 Diversity CitizenofAnotherState ci 2 ci 2 lncorporatedandPrincipalPlace ci 5 ci 5 Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State

Citizen or Subject of a ci 3 ci 3 Foreign Nation ci 6 ci 6 Foreign Country Code Descrintionc IV NATIJRF. OF SIJIT ipi,,,',o, "y" ,,,,',,,' R,-(Thh,} Clinic here fcir Nature of Suit CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES I ci 110 Insurance PERSONAL INJURY PERSONAL INJURY ci 625 Drug Related Seizure ci 422 Appeal 28 USC 158 ci 375 False Claims Act USC ci 120 Marine ci 310 Airplane ci 365 Personal Injury . of Property 21 USC 881 ci 423 Withdrawal ci 376 Qui Tam (31 ci 130 Miller Act ci 315 Airplane Product Product Liability ci 690 Other 28 USC 157 3729(a)) ci 140 Negotiable Instrument Liability ci 367 Health Card ci 400 State Reapportionment ci 150 Recovery of Overpayment ci 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS ci 410 Antitrust & Enforcement ofiudgment Slander Personal Injury ci 820 Copyrights ci 430 Banks and Banking ci 151 Medicare Act ci 330 Federal Employers' Product Liability ci 830 Patent ci 450 Commerce ci 152 Recovery of Defaulted Liability ci 368 Asbestos Personal ci 835 Patent - Abbreviated ci 460 Deportation Student Loans ci 340 Marine Injury Product New Drug Application ci 470 Racketeer Influenced and (Excludes Veterant) ci 345 Marine Product Liability ci 840 Trademaui Corrupt Organizations ci 153 Recovery of Overpayment Liability PERSONAL PROPERTY LABOR SOCIAL SECURITY ci 480 Consumer Credit of Veteran's Benefits ci 350 Motor Vehicle ci 370 Other Fraud 0 710 Fair Labor Standards ci 861 HIA (139513) ci 490 Cable/Sat TV ci 160 Stockholders' Suits ci 355 Motor Vehicle ci 371 Truth in Lending Act ci 862 Black Lung (923) ci 850 Securities/Comsnodities/ ci 190 Other Contract Product Liability ci 380 Other Personal ci 720 Labor/Management ci 863 DIWC/DIWW (405(g)) Exchange ci 195 Contract Product Liability ci 360 Other Personal Property Damage Relations ci 864 SSID Title XVI ci 890 Other Statutory Actions ci 196 Franchise Injury ci 385 Property Damage ci 740 Railway Labor Act ci 865 RSI (405(g)) ci 891 Agricultural Acts 893 Environmental Matters ci 362 Personal Injury - Product Liability ci 751 Family and Medical ci Medical Malpractice Leave Act ci 895 Freedom of Information TAX 5UITS Act I REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS ci 790 Other Labor Litigation FEDERAL ci 210 Land Condemnation X440 Other Civil Rights Habeas Corpus: ci 791 Employee Retirement ci 870 Taxes (U.S. Plaintiff ci 896 Arbitration ci 220 Foreclosure 0 441 Voting ci 463 Alien Detainee Income Security Act or Defendant) ci 899 Administrative Procedure ci 230 Rent Lease & Ejectment ci 442 Employment ci 510 Motions to Vacate ci 871 IRSThird Party Act/Review or Appeal of ci 240 Torts to Land ci 443 Housing/ Sentence 26 USC 7609 Agency Decision ci 245 Tort Product Liability Accommodations ci 530 General ci 950 Constitutionality of ci 290 Alt Other Real Property ci 445 Amer. w/Disabilities - ci 535 Death Penalty IMMIGRATION State Statutes Employment Other: ci 462 Naturalization Application 0 446 Amer. w/Disabilities - ci 540 Mandamus & Other ci 465 Other Immigration Other ci 550 Civil Rights Actions ci 448 Education ci 555 Prison Condition ci 560 Civil Detainee - Conditions of Confinement

V. ORIGIN (Place an "X" in One Box Only) I Original ci 2 Removed from ci 3 Remanded from 4 Reinstated or ci 5 Transferred from 0 6 Multidistrict ci 8 Multidistrict Proceeding State Court Appellate Court Reopened Another District Litigation - Litigation - (specfy) Transfer Direct File Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity): 42:1983 Civil Rights Act VI. CAUSE OF ACTION Brief description of cause:

VII. REQUESTED IN CHECK IF THIS IS A CLASS ACTION DEMAND $ CHECK YES only if demanded in complaint: COMPLAINT: UNDER RULE 23, F.R.Cv.P. JURY DEMAND: Yes ciNo VIII. RELATED CASE(S) (See instructions): IF ATY JUDGE ______DOCKET NUMBER DATE SIGNATURE OF ATFORNEY OF RECORD

FOR OFf

RECEIPT # AMOUNT $402.00 APPLYING IFP JUDGE Pitman MAG. JUDGE Case 1:21-cv-00690-RP Document 1-1 Filed 08/06/21 Page 2 of 2

DUPLICATE

Court Name: TEXAS WESTERN

Division: 1 Receipt Number: 100040238 Cashier ID: ciames Transaction Date: 08/06/2021 Payer Name: CRAIG A. WASHINGTON

CIVIL FILING FEE- NON-PRISONER For: CRAIG A. WASHINGTON Amount: $402.00

PAPER CHECK Check/Money Order Num: 260 Amt Tendered: $402.00

Total Due: $402.00 Total Tendered: $402.00 Change Amt: $0.00

ET AL V. 1 :21-CV-690-RP; THOMPSON ABBOTT El AL; CIVIL FILING FEE