Fourteenth Amendment and resulted in an unconstitutional deprivation of the Plaintiffs’ liberty and property interests. 5.
The Plaintiffs bring this action to recover for injuries caused by the Defendants’
conduct and seek injunctive relief, treble damages, costs of suit and reasonable attorneys’ fees arising from the Defendants’ violation of the Civil Rights Act (42 U.S.C. §§ 1983, 1985(3)) and the Racketeer Influenced and Corrupt Organizations Act (18 U.S.C. § 1962(b)–(d)). II. 6.
JURISDICTION AND VENUE
This Court has jurisdiction over this matter pursuant to Title 28, United States
Code, Sections 1331 and 1343(3). 7.
Venue is proper in this District pursuant to Title 28, United States Code, Section
1391 because all of the acts committed by the Defendants for which the Plaintiffs claim relief occurred within the Eastern District of Wisconsin. 8.
This Court has personal jurisdiction over each Defendant because each
Defendant: (a) is a citizen of this District; (b) transacted business in this District; (c) had substantial contacts with this District; and/or (d) engaged in a conspiracy that was directed at and had a direct, foreseeable, and intended effect of causing injury to the business or property of persons residing or doing business in this District. III.
PARTIES
A. PLAINTIFFS 9.
Plaintiff Thomas J. Holmes (“Holmes”), Individually and d/b/a Park 6 Bar, LLC,
resides in the County of Milwaukee, State of Wisconsin. Holmes owned and operated the Park 6 Bar in Racine, Wisconsin, from 2008 to 2012. Holmes is black.
4 Case 2:14-cv-00208 Filed 02/25/14 Page 4 of 50 Document 1