3. Plaintiff is also a photographer for Independent Media; 4. Plaintiff is a political activist, demonstrator and one of the administrator of the facebook group called “

Liste du SPVM”;

5.

“Liste du SPVM”

is a facebook group which advises citizens on how to make complaints against police officers; 6. Plaintiff does not have a criminal report and has never engaged in any violent behavior; 7. Defendant Alexandre Viau is a police officer employed by the City and is involved in many of the incidents involving Plaintiff, it is not alleged that he is the sole perpetrator but that his presence was very frequent; 8. The City of Montreal is the employer and is jointly and severally responsible for the employees actions; 9. Plaintiff reserves the rights to add o ther police officers participating in the events mentioned below; THE FACTS 10. Since May 2012, Plaintiff has been repeatedly and systematically ticketed, removed from events, arrested and detained for her political activism by the Montreal police; 11. As soon as Plaintiff participates in any po litical or large social event, Plaintiff is systematically singled out, targeted and sanctioned; 12. The Plai ntiff has experienced the fol lowing sanc tions for her polit ical activism; A. On May 13

th

, 2012, Plaintiff was charged by a horse belonging to the riot police and slightly injured; B. On May 19

th