Sunday, January 28, 2018

AMENDED COMPLAINT FOR DAMAGES [42 U.S.C. § 1983 – Retaliation for Exercise of First Amendment Rights; Request for Injunctive Relief] JURY TRIAL DEMANDED, STACY LININGER, Plaintiff, v. RONALD PFLEGER, CITY OF CARMEL, DEAN FLIPPO, District Attorney of Monterey County California, and DOES 1-50, Defendants. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORIA

ABSTRACT: On January 22, 2018, Steven J. Andre, Attorney for Plaintiff, STACY LININGER, submitted AMENDED COMPLAINT FOR DAMAGES [42 U.S.C. § 1983 – Retaliation for Exercise of First Amendment Rights; Request for Injunctive Relief], STACY LININGER, Plaintiff, v. RONALD PFLEGER, CITY OF CARMEL, DEAN FLIPPO, District Attorney of Monterey County California, and DOES 1-50, Defendants. Case No. 5:17-CV-03385-SVK, UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA.
FIRST CLAIM FOR RELIEF 42 U.S.C. § 1983 – Retaliation in Violation of the First Amendment (Against Defendant RONALD PFLEGER)
SECOND CLAIM FOR RELIEF 42 U.S.C. § 1983 - Against City of Carmel
THIRD CLAIM FOR RELIEF 42 U.S.C. § 1983; Violation of the First and Fourth Amendments - Malicious Prosecution of Plaintiff’s Protected Activity as a Basis for Injunctive Relief Against Defendant Dean Flippo, District Attorney of Monterey County
DEMAND FOR RELIEF

Plaintiff respectfully requests that this court:
a. assert jurisdiction over this matter;
b. award compensatory and punitive damages to Plaintiff as to defendants City of Carmel and Ronald Pfleger, in an amount to be proved at trial;
c. grant appropriate injunctive or other prospective relief as to defendant Dean Flippo, District Attorney of Monterey County, against the prosecution of persons for the exercise of their constitutional rights.
d. award Plaintiff her costs and attorneys' fees pursuant to 42 U.S.C. § 1988; and
e. grant or award such other relief that this Court deems just and proper.
The AMENDED COMPLAINT FOR DAMAGES [42 U.S.C. § 1983 – Retaliation for Exercise of First Amendment Rights; Request for Injunctive Relief] document copy is embedded. 
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA

STACY LININGER, Plaintiff, v. RONALD PFLEGER, CITY OF CARMEL, DEAN FLIPPO, District Attorney of Monterey County California, and DOES 1-50, Defendants.
Case No. 5:17-CV-03385-SVK
AMENDED COMPLAINT FOR DAMAGES
[42 U.S.C. § 1983 – Retaliation for Exercise of First Amendment Rights; Request for Injunctive Relief]
JURY TRIAL DEMANDED

Filed 1/22/18united sta

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