UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS, Dr. SHIVA AYYADURAI Plaintiff, v. WILLIAM FRANCIS GALVIN, MICHELLE K. TASSINARI, DEBRA O’MALLEY, AMY COHEN, NATIONAL ASSOCIATION OF STATE ELECTION DIRECTORS, TWITTER, INC., all in their individual capacities, and WILLIAM FRANCIS GALVIN, in his official capacity as Secretary of State for Massachusetts, Defendants. CASE No. 1:20-CV-11889-MLW

 

https://drive.google.com/file/d/1kQPRqPZl6nZ-kzr1m5cWQtIuzYkP6I1r/view?usp=sharing

VERIFIED COMPLAINT & JURY DEMAND

Introduction 

This is a Complaint to redress the Commonwealth of Massachusetts' repeated violations of Plaintiff Dr. Shiva Ayyadurai's civil rights guaranteed by the First Amendment to the United States Constitution and Article 16 of the Declaration of Rights of the Constitution of the Commonwealth of Massachusetts.

COUNT I 

Violations of the Freedom of Speech or Expression 

COUNT II 

Violations of the Right to Freedom of the Press 

COUNT III 

Violations of the Freedom to Petition the Government 

COUNT IV 

Violations of the Freedom to Peaceably Assemble 

COUNT V 

Violations of the Right to Freedom of the Press and Freedom of Speech Guaranteed by Article 16 ofthe Declaration ofRights of the Massachusetts Constitution 

PRAYER FOR RELIEF 

WHEREFORE, the Plaintiff demands that Judgment be entered against the Defendant to compensate the Plaintiff for damages, and so that justice might be upheld as the Defendant violated the Plaintiffs Constitutionally-Guaranteed Rights, applicable to such parties, and order that the following damages be awarded: 

a. Damages for Loss of Liberty; 

b. Compensatory Damages; 

c. Punitive Damages; 

d. Attorney's fees; 

e. Court costs; 

f. Pre- and post-judgment interest; 

g. Injunctive relief; or 

h. Any such other relief as this Honorable Court might deem appropriate and equitable. 

Temporarv Restraining Order 

In addition to the relief requested above, the Plaintiff requests that this Court issue a Temporary Restraining Order, restraining the Defendant from again bidding Twitter to remove, ban, or otherwise silence the Plaintiff at least until the results of the race for the U.S. Senate are announced-likely by November 4, 2020, the day after election day. 

A restraining order is necessary because: 

The Plaintiff has a substantial likelihood of success on the merits of the case, since the Office of the Secretary of the Commonwealth has admitted it silenced the Plaintiff. 

Absent an injunction, the Plaintiff would suffer an irremediable loss of rights during his campaign for the U.S. Senate. While the Plaintiff has already lost essential time and means to campaign during his race for the 2020 U.S. Senate seat, the Plaintiff would incur even more losses if the Defendant were permitted to continue to violate the Plaintiff's constitutionally-guaranteed rights; and 

Granting this restraining order will serve the public interest, as it will preserve the public's ability to hear political speech and consider a public petition. 

Granting this restraining order will no prejudice the Defendant-as no harm may come to the government being preventing from silencing peaceful political speech. 

Oct 20, 2020 COMPLAINT (Galvin) against All Defendants Filing fee: $ 400, receipt number 0101-8471903 (Fee Status: Filing Fee paid), filed by Shiva Ayyadurai.(Casieri, Daniel) (Main Document 1 replaced on 10/20/2020) (Kelly, Danielle). (Additional attachment(s) added on 10/20/2020: # 1 Civil Cover Sheet, # 2 Category Form) (Kelly, Danielle). (Entered: 10/20/2020)

Main Doc­ument Complaint

Attach­ment 1 Civil Cover Sheet

Attach­ment 2 Category Form

   

https://drive.google.com/file/d/1N7LofT9qU1lsSaHdegSWvctbmANiGTOR/view?usp=sharing

AMENDED VERIFIED COMPLAINT
Nov 6, 2020 AMENDED COMPLAINT against William Francis Galvin, filed by Shiva Ayyadurai. (Attachments: # 1 Exhibit)(Ayyadurai, Shiva) (Entered: 11/06/2020)
Main Doc­ument Amended Complaint

Attach­ment 1 Exhibit

  https://drive.google.com/file/d/1KuH8MQ0RYOxs9QEedKJEuUvtAw9HVZzK/view?usp=sharing 

[PROPOSED] SECOND AMENDED VERIFIED COMPLAINT
Apr 6, 2021 AMENDED COMPLAINT PROPOSED SECOND AMENDED COMPLAINT against All Defendants, filed by Shiva Ayyadurai.(Ayyadurai, Shiva) (Entered: 04/06/2021)

Main Doc­ument Amended Complaint

 

May 20, 2021 Motion Hearing

   

https://drive.google.com/file/d/13zDyEhmlIik3PS6r3b-3EVpM1Ylm4IdI/view?usp=sharing

SUPPLEMENTAL MEMORANDUM
REGARDING THE ELECTIONS INTERFERENCE OPERATIONS PLAYBOOK
FOR STATE AND LOCAL OFFICIALS
THAT ESTABLISHED THE INFRASTRUCTURE, PROCESSES & PROTOCOLS
DESIGNED BY TASSINARI, COHEN, NASED, TWITTER LEGAL ET AL
IN CAMBRIDGE, MA
FOR SURVEILLANCE & REPORTING OF “THREATS” VIA
THE TWITTER TRUSTED PARTNERSHIP
AND TWITTER PARTNER SUPPORT PORTAL (PSP) PROGRAM

May 21, 2021 DECLARATION Re Influence Operations Playbook by Shiva Ayyadurai. (Attachments: # 1 Exhibit Amy Cohen Testimony, # 2 Exhibit Election Incident Coordination Guide, # 3 Exhibit Election Cybersecurity Playbook, # 4 Exhibit Election-Influence-Operations-Playbook-Part1, # 5 Exhibit Election-Influence-Operations-Playbook-Part2)(Ayyadurai, Shiva) (Entered: 05/21/2021)

Main Doc­ument Declaration

Attach­ment 1 Exhibit Amy Cohen Testimony

Attach­ment 2 Exhibit Election Incident Coordination Guide

Attach­ment 3 Exhibit Election Cybersecurity Playbook

Attach­ment 4 Exhibit Election-Influence-Operations-Playbook-Part1

Attach­ment 5 Exhibit Election-Influence-Operations-Playbook-Part2

REFERENCE:
Ayyadurai v. Galvin (1:20-cv-11889)
District Court, D. Massachusetts

Last Updated: May 25, 2021, 5:15 p.m. EDT

Assigned To: Mark Lawrence Wolf

Date Filed: Oct. 20, 2020

Date of Last Known Filing: May 21, 2021

Cause: 42:1983 Civil Rights Act

Nature of Suit: 440 Civil Rights: Other

Jury Demand: Plaintiff

Jurisdiction Type: U.S. Government Defendant