CLASS ACTION COMPLAINT: IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO JENNIFER L. COOPER, EUGENE DIXON, FRANCIS J. CIZMAR, ANNA PENNALA, KATHLEEN DAAVETTILA, CYNTHIA BRUNELL, KARYN CHOPJIAN, AND ABBIE HELMINEN, INDIVIDUALLY, AND ON BEHALF OF ALL OTHERS SIMILARLY SITUATED, Plaintiffs, v. US DOMINION, INC., DOMINION VOTING SYSTEMS, INC., and DOMINION VOTING SYSTEMS CORPORATION, Defendants.

 

 

https://drive.google.com/file/d/1H_XH1910-aW66-G7ryBpZWxbad3KLia_/view?usp=sharing 

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO
JENNIFER L. COOPER, EUGENE DIXON, FRANCIS J. CIZMAR, ANNA PENNALA, KATHLEEN DAAVETTILA, CYNTHIA BRUNELL, KARYN CHOPJIAN, AND ABBIE HELMINEN, INDIVIDUALLY, AND ON BEHALF OF ALL OTHERS SIMILARLY SITUATED, Plaintiffs,
v.
US DOMINION, INC., DOMINION VOTING SYSTEMS, INC., and DOMINION VOTING SYSTEMS CORPORATION, Defendants.
Case Number 1:21-cv-02672
JURY TRAIL DEMANDED
CLASS ACTION COMPLAINT

This is a class action lawsuit brought by ordinary Americans whose rights under the First Amendment to participate in the public debate regarding election integrity and security have been infringed by US Dominion, Inc., Dominion Voting Systems, Inc., and Dominion Voting Systems Corporation (collectively, “Dominion,” the “Dominion entities,” or “Defendants”) through their campaign to intimidate Americans by waging and threatening to wage Lawsuit Warfare (“Lawfare”) against anyone that speaks about anything negatively related to Dominion’s possible role in election integrity and security.

CAUSES OF ACTION 

 
COUNT I:
VIOLATIONS OF THE RACKETEER INFLUENCED AND CORRUPT ORGANIZATION ACT, 18 U.S.C. § 1962

COUNT II:
42 U.S.C. § 1983 DEPRIVATION OF
EQUAL PROTECTION BY DOMINION’S STATE-ACTION

COUNT III:
42 U.S.C. § 1983 DEPRIVATION OF FIRST AMENDMENT BY DOMINION’S STATE-ACTION

COUNT IV:
CIVIL CONSPIRACY

PRAYER FOR RELIEF

WHEREFORE, Plaintiffs ask that Defendants be cited to answer and appear herein and that, after trial or other hearing on the merits, Plaintiffs and the Class have and recover against the Defendants, jointly and severally, the relief requested herein, together with all writs and processes necessary to the enforcement of same, and all other relief to which they may show themselves justly entitled, including but not limited to:

a. Actual and special damages as allowed by law, in an amount to be proven at trial, including but not limited to the following:
i. Damages to be determined by the trier of fact suffered as a result of the deprivation of their rights under the First Amendment to the U.S. Constitution; together with,

b. Three times actual damages for violations of 18 U.S.C. §1962;

c. Punitive damages as allowed by law, in an amount to be determined by the trier of fact;

d. Reasonable and necessary attorney’s fees, as allowed by law; and,

e. Costs of suit.

DATED: September 30, 2021

Respectfully submitted,

ROBERT MCGUIRE LAW FIRM