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(collectively “Defendants”) in their individual and official capacities where applicable, and in support allege as follows:

I. INTRODUCTION AND NATURE OF THE ACTION

1.

This is a class action complaint for damages and equitable relief arising out of the threats, severe bodily injury and/or deaths, future deaths, emotional harm, and imminent fears of death and/or serious bodily harm resulting from Black Lives Matter leaders, former Attorney General Eric Holder, President Barack Hussein Obama, Minister Louis Farrakhan and Reverend Al Sharpton. Those Defendants have repeatedly incited their supporters and others to engage in threats of and attacks to cause serious bodily injury or death upon police offic ers, Jews, and Caucasians. Thus, Defendants, each and every one of them, jointly and severally, conspiring and/or acting in concert either expressly or otherwise, are inciting and causing serious bodily injury or death to police officers and other law enforcement persons of all races and ethnicities, Jews, and Caucasians. 2.

This is a civil action for the deprivation of the Plaintiff and other members of the class herein of their civil rights, conspiracy a gainst the Plaintiff’s and other members of the class herein civil rights and obstruction of justice to prevent the enforcement of civil rights,

Bivens

relief, assault, and intentional infliction of emotional distress resulting from the incitement of violent attacks that have led to the murders of, and have caused serious bodily injuries to, police officers of all races ethnicities, Jews, and Caucasians. 3.

Directing, provoking and even inciting angry crowds to violence is illegal, as illuminated by the U.S. Supreme Court in

Brandenburg v. Ohio

, 395 U.S. 444 (1969).