UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS WACO DIVISON LATINOS FOR TRUMP, BLACKS FOR TRUMP, JOSHUA MACIAS, M.S., B.G., J.B., J.J., Plaintiffs. v. PETE SESSIONS, MITCH McCONNELL, NANCY PELOSI, MARK ZUCKERBERG, CHUCK SCHUMER, ALEXANDRIA OCASIO-CORTEZ, BRAD RAFFENSPERGER, ALL MEMBERS OF THE 117TH U.S. CONGRESS, et al., Defendants. CIVIL ACTION NO. 6:21-CV-43

Latinos for Trump v. Sessions (6:21-cv-00043)
District Court, W.D. Texas

Assigned To: Alan D. Albright

Referred To: Jeffrey C. Manske

Date Filed: Jan. 18, 2021

Date of Last Known Filing: Feb. 19, 2021

Cause: 42:1983 Civil Rights Act

Nature of Suit: 441 Civil Rights: Voting

Jury Demand: Plaintiff

Jurisdiction Type: Diversity

COMPLAINT AND APPLICATION FOR INJUNCTIVE RELIEF ( Filing fee $ 402 receipt number 0542-14386818). No Summons requested at this time, filed by Latinos for Trump. (Attachments: # 1 Exhibit 1 - List of State Governors and Secretaries of State, # 2 Exhibit 2 - Cain Declaration 20210118, # 3 Exhibit 3 - Global Risk Analysis: Special Report, # 4 Exhibit 4-1, # 5 Exhibit 4-2, # 6 Exhibit 4-3, # 7 Exhibit 4-4, # 8 Exhibit 4-5, # 9 Exhibit 4-6, # 10 Exhibit 4-7, # 11 Exhibit 4-8, # 12 Exhibit 4-9, # 13 Exhibit 4-10, # 14 Exhibit 4-11, # 15 Exhibit 4-12, # 16 Exhibit 4-13, # 17 Exhibit 4-14, # 18 Exhibit 4-15, # 19 Exhibit 4-16, # 20 Exhibit 4-17, # 21 Exhibit 4-18, # 22 Exhibit 4-19, # 23 Exhibit 4-20, # 24 Exhibit 4-21, # 25 Exhibit 4-22, # 26 Exhibit 4-23, # 27 Exhibit 4-24, # 28 Exhibit 4-25)(Davis, Paul) (Entered: 01/18/2021)
January 18, 2021

Main Doc­ument Complaint

Attach­ment 1 Exhibit 1 - List of State Governors and Secretaries of State

Attach­ment 2 Exhibit 2 - Cain Declaration 20210118

Attach­ment 3 Exhibit 3 - Global Risk Analysis: Special Report

Attach­ment 4 Exhibit 4-1

Attach­ment 5 Exhibit 4-2

Attach­ment 6 Exhibit 4-3

Attach­ment 7 Exhibit 4-4

Attach­ment 8 Exhibit 4-5

Attach­ment 9 Exhibit 4-6

Attach­ment 10 Exhibit 4-7

Attach­ment 11 Exhibit 4-8

Attach­ment 12 Exhibit 4-9

Attach­ment 13 Exhibit 4-10

Attach­ment 14 Exhibit 4-11

Attach­ment 15 Exhibit 4-12

Attach­ment 16 Exhibit 4-13

Attach­ment 17 Exhibit 4-14

Attach­ment 18 Exhibit 4-15

Attach­ment 19 Exhibit 4-16

Attach­ment 20 Exhibit 4-17

Attach­ment 21 Exhibit 4-18

Attach­ment 23 Exhibit 4-20

Attach­ment 24 Exhibit 4-21

Attach­ment 25 Exhibit 4-22

Attach­ment 26 Exhibit 4-23

Attach­ment 27 Exhibit 4-24

Attach­ment 28 Exhibit 4-25

MOTION for Temporary Restraining Order by Latinos for Trump. (Attachments: # 1 Affidavit Declaration of Joshua Macias, # 2 Exhibit Expert Report of Steve Vanderbol, # 3 Exhibit CV of Steve Vanderbol, # 4 Proposed Order Proposed Temporary Restraining Order)(Davis, Paul) (Entered: 01/19/2021) January 19, 2021

Main Doc­ument Temporary Restraining Order

Attach­ment 1 Affidavit Declaration of Joshua Macias

Attach­ment 2 Exhibit Expert Report of Steve Vanderbol

Attach­ment 3 Exhibit CV of Steve Vanderbol

Attach­ment 4 Proposed Order Proposed Temporary Restraining Order

Amended MOTION for Temporary Restraining Order Oral Hearing Requested by Latinos for Trump. (Attachments: # 1 Exhibit A - Global Risk Analysis: Special Report:, # 2 Exhibit B - CV of J.S. Vanderbol III, # 3 Exhibit C - Full Text of HAVA with Highlights, # 4 Exhibit D - Second Declaration of Joshua Macias, # 5 Exhibit E - Virginia Voter Registrationa Application, # 6 Exhibit F - Expressvote Screenshot, # 7 Exhibit G - Declaration of J.J., # 8 Exhibit H - Ballotopedia, Voting in Alabama, # 9 Proposed Order Proposed Temporary Restraining Order)(Davis, Paul) (Entered: 01/21/2021)
January 21, 2021

Main Doc­ument Temporary Restraining Order

Attach­ment 1 Exhibit A - Global Risk Analysis: Special Report:

Attach­ment 2 Exhibit B - CV of J.S. Vanderbol III

Attach­ment 3 Exhibit C - Full Text of HAVA with Highlights

Attach­ment 4 Exhibit D - Second Declaration of Joshua Macias

Attach­ment 5 Exhibit E - Virginia Voter Registrationa Application

Attach­ment 6 Exhibit F - Expressvote Screenshot

Attach­ment 7 Exhibit G - Declaration of J.J.

Attach­ment 8 Exhibit H - Ballotopedia, Voting in Alabama

Attach­ment 9 Proposed Order Proposed Temporary Restraining Order

AMENDED COMPLAINT First Amended Class Action Complaint and Application for Injunctive Relief against All Defendants amending, filed by Blacks for Trump, J.J., B.G., Joshua Macias, Latinos for Trump, M.S., J.B.. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5)(Davis, Paul) (Entered: 02/10/2021)
February 10, 2021

Main Doc­ument Amended Complaint

Attach­ment 1 Exhibit 1

Attach­ment 2 Exhibit 2

Attach­ment 3 Exhibit 3

Attach­ment 4 Exhibit 4

Attach­ment 5 Exhibit 5

AMENDED COMPLAINT SECOND AMENDED CLASS ACTION COMPLAINT AND APPLICATION FOR INJUNCTIVE RELIEF against All Defendants amending 12 Amended Complaint,., filed by Blacks for Trump, J.J., B.G., Joshua Macias, Latinos for Trump, M.S., J.B.. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5)(Davis, Paul) (Entered: 02/16/2021)
February 16, 2021

Main Doc­ument Amended Complaint

Attach­ment 1 Exhibit 1

Attach­ment 2 Exhibit 2

Attach­ment 3 Exhibit 3

Attach­ment 4 Exhibit 4

Attach­ment 5 Exhibit 5

https://drive.google.com/file/d/1fCxnMkbVnn0aNY1QF7bicb9bunn3Hz-m/view?usp=sharing

PLAINTIFFS’ SECOND AMENDED CLASS ACTION COMPLAINT AND APPLICATION FOR INJUNCTIVE RELIEF
UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF TEXAS
WACO DIVISON
LATINOS FOR TRUMP, BLACKS FOR TRUMP, JOSHUA MACIAS, M.S., B.G., J.B., J.J., Plaintiffs.
v.
PETE SESSIONS, MITCH McCONNELL, NANCY PELOSI, MARK ZUCKERBERG, CHUCK SCHUMER, ALEXANDRIA OCASIO-CORTEZ, BRAD RAFFENSPERGER, ALL MEMBERS OF THE 117TH U.S. CONGRESS, et al., Defendants.
CIVIL ACTION NO. 6:21-CV-43
JURY TRIAL REQUESTED

This Lawsuit is about how both state and federal officials acted together as both “Democrats” and “Republicans” and as part of a “well-funded cabal”1 and “conspiracy”2 with various private persons, including persons in the news media, social media, and technology industry, high net worth individuals, and others, to willfully deprive the American People of their “most precious” and fundamental right: the right to the “Republican Form of Government” guaranteed by Article IV, Section 4 (the “Guarantee Clause”) of the Constitution of the United States and other fundamental civil rights.

 CAUSES OF ACTION

COUNT ONE – Conspiracy and conduct to deprive of constitutional rights related to suffrage and the right to a republican form of government under 42 U.S.C. § 1983.

COUNT TWO – Conspiracy and conduct to deprive of First Amendment rights and retaliate for the free exercise thereof under 42 U.S.C. § 1983.

 COUNT THREE Conspiracy to interfere with constitutional rights under 42 U.S.C. § 1985.

 COUNT FOUR - Action for neglect to prevent under 42 U.S.C. § 1986.

 COUNT FIVE - Bivens claim for conspiracy and/or conduct to deprive of constitutional rights related to suffrage and the right to a republican form of government

 COUNT SIX - Bivens claim for conspiracy and/or conduct to deprive of First Amendment rights.

 COUNT SEVEN – Deprivation of equal rights under the law pursuant to 42 U.S.C. § 1981.

 PRAYER FOR RELIEF

WHEREFORE, Plaintiffs, upon jury trial of this matter, plead for judgment against Defendants for the following:

a. Permanent injunctive relief in the form of a new federal election for both Congress and the President and Vice President.

b. Permanent injunctive relief forever restraining Defendants from participating in any action relating to the process of electing public officials, other than casting their own lawful vote as a citizen of the United States, or at least restraining Defendants from such participation in the new federal election to be ordered after trial on the merits,

c. Permanent injunctive relief forever restraining Defendants from violating Plaintiffs constitutional rights described herein,

d. General Damages in an amount to be determined at the time of trial;

e. Punitive Damages in an amount to be determined at the time of trial;

f. Reasonable attorneys fees’ and costs of suit; g. Prejudgment and postjudgment interest.

And all other general and special relief, whether at law or in equity as the Court may deem necessary or proper to which the Plaintiffs may be justly entitled.