DEFENDANTS’ AFFIDAVITS PROVES PURPOSE OF DELAY AND UNDENIABLE VIOLATIONS OF THE PLAINTIFFS CONSTITUTIONAL RIGHTS UNDER COLOR OF LAW 1. DEFENDANT TONY LOVELL’S AFFIDAVIT PROVES PURPOSE OF DELAY: 2. The Town of Loxley has NO IMMUNITY for the lack of training of their police namely Defendant Tony Lovell. Tony Lovell uses the Plaintiffs’ SPEECH, PEACEABLE ASSEMBLY, and RELIGION to bring before the court in his affidavit stating that he found the Plaintiffs free religious literature (the Plaintiffs’ ministry tract and a flyer with the Plaintiffs’ religious expression freedom of speech Bible language and also redress from governmental oppression are Defendant Lovell’s Exhibits) on his door. According to Defendant Tony Lovell affidavit is undeniable evidence that the Defendant is not properly trained to know that the distribution of free literature from door-to-door is not illegal which is also a Constitutional violation of the Plaintiffs’ civil rights: “Project 80’s Inc. v. City of Pocatello, 942 F.2d 635, 638 (9th Cir. 1991) (court rejected city’s proffered reason for banning door-to-door solicitation due to the lack of evidence that such activity led to an appreciable level of crime)”; 3. Even though Defendant Tony Lovell does not want the Plaintiffs to distribute literature door-to-door (including Defendant Tony Lovell’s door), the Supreme Court has held that these activities are not unconstitutional. Watchtower Bible & Tract Society of New York v. Village of Stratton, (2002 …
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