COMPLAINT FOR INJUNCTIVE AND DECLARATORY RELIEF: IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA MIAMI DIVISION DONALD J. TRUMP, the Forty-Fifth President of the United States, ELIZABETH ALBERT, KIYAN AND BOBBY MICHAEL, AND JENNIFER HORTON, INDIVIDUALLY AND ON BEHALF OF THE CLASS, Plaintiffs, v. FACEBOOK, INC., and MARK ZUCKERBERG, Defendants.

 

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IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

DONALD J. TRUMP, the Forty-Fifth President of the United States, ELIZABETH ALBERT, KIYAN AND BOBBY MICHAEL, AND JENNIFER HORTON, INDIVIDUALLY AND ON BEHALF OF THE CLASS, Plaintiffs,

v.

FACEBOOK, INC., and MARK ZUCKERBERG,Defendants.

CLASS ACTION

COMPLAINT FOR: FIRST AMENDMENT VIOLATION

JURY TRIAL REQUESTED

COMPLAINT FOR INJUNCTIVE AND DECLARATORY RELIEF

COUNT ONE

VIOLATION OF THE FIRST AMENDMENT TO THE U.S. CONSTITUTION

COUNT TWO

DECLARATORY JUDGEMENT OF UNCONSTITUTIONALITY OF SECTION

230 AND THE COMMUNICATIONS DECENCY ACT

CLASS ACTION ALLEGATIONS

 

PRAYER FOR RELIEF

WHEREFORE, Plaintiff Donald J. Trump and the Class respectfully request that the Court enter an Order certifying this case as a class action, appointing Plaintiff as Class Representative and appointing Plaintiff’s counsel as Lead Class Counsel and that the Court Order, adjudge, and decree in favor of Plaintiff and the Class against the Defendants for:

A. An award of Compensatory and Punitive damages to the Plaintiff and the Class in an amount to be determined at trial;

B. An injunction and declaratory judgment ordering Facebook immediately to reinstate Plaintiff and Putative Class Members to their Facebook accounts;

C. An injunction and declaratory judgment ordering Facebook to remove its warning labels and misclassification of all content of the Plaintiff and the Class and to desist from any further warnings or classifications;

D. Adjudgment declaring Sections 230(c)(1) and (c)(2) of the Communications Decency Act of 1996 unconstitutional;

E. An award of attorneys’ fees and costs to Plaintiff and the Class in an amount to be determined at trial; and

F. An award of punitive damages to Plaintiff and the Class in an amount to be determined at trial.

G. An award of such other and further relief as the Court may deem just and proper.

Date: July 7, 2021