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Bob Friedman,
on behalf of himself and
other Persons similarly situated
Plaintiff,
Vs.
Senator Cam Ward,
Senator J.T. Jabo Waggoner,
Senator Quinton T. Ross,
Representative Alan Baker,
Representative Jimmy Martin,
Representative Chris England
and Secretary of State John S.
Merrill,
Defendants.
________________________________
CLASS ACTION COMPLAINT FOR INJUNCTIVE, DECLARATORY AND
OTHER RELIEF
Comes now the Plaintiff, Bob Friedman ("Plaintiff"), on
behalf of himself and a class of persons similarly
situated, and by way of this Complaint against Defendants
Senator Cam Ward, Senator J.T. Jabo Waggoner, Senator
Quinton T. Ross, Representative Alan Baker, Representative
Jimmy Martin, and Representative Chris England and states
as follows:
INTRODUCTION
1.
fact that the Alabama Legislature, when passing Act 2015226, violated Art. IV, 71.01 of the Alabama Constitution
(alternatively known as Amendment No. 448 The Budget
Isolation Amendment).
3.
5.
effective on
DEFENDANTS
13. Defendants, Senator Cam Ward, Senator J.T. Jabo
Waggoner, Senator Quinton T. Ross, Representative Alan
Baker, Representative Jimmy Martin, and Representative
Chris England are members of the Conference Committee that
approved SB7, Act 2016-430.
14. Defendant John S. Merrill is the Secretary of
State Plaintiff asks to be enjoined in publishing Amendment
14 in the Voter Pamphlet (Exhibit C) which this complaint
alleges to be unconstitutional.
C, which provides:
Any resolution authorized by this amendment and
adopted before November 8, 2016, which conforms to this
paragraph, as amended, is ratified, approved,
validated, and confirmed and the application of any
such resolution is effective from the date of original
adoption.
17.
The
37.
the
courts are not open, in fact, and that persons who get a
remedy adverse to unconstitutional Legislative acts do not
have a remedy by due process of law; nor
their
assurance that
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