Complaint : Complaint, And Complain Of Defendants

922 WordsFeb 1, 20164 Pages
COMPLAINT COME NOW plaintiff Richard David Lopez by and through undersigned counsel, and complain of Defendants as follows: PARTIES 1. Plaintiff Richard Lopez is an individual currently living in Atlanta, Georgia, within the Northern District of California. 2. Defendant City of San Diego held the swap meet plaintiff was prohibited from attending. Located at 9449 Friars Rd, San Diego, CA 92108 within the southern district of California. JURISDICTION AND VENUE 3. Plaintiff Richard Lopez brings this action, on his own behalf. This court has subject matter jurisdiction over this action pursuant to 28 U.S.C. 1331 for civil actions arising under the Constitution, laws, or treaties of the United States and 28 U.S.C. 1332 due to a complete diversity of citizenship between Plaintiff and Defendant and the amount in controversy exceeds $75,000, exclusive of interest and costs. 4. Venue is proper pursuant to 28 U.S.C 1391 in that substantial part of the even giving rise to the claim occurred in the Southern District of California. FACTUAL ALLEGATION 5. Plaintiff Richard Lopez is a private gun dealer from Atlanta, Georgia. 6. Plaintiff has a vender agreement with City of San Diego for duration of five years form January 2015 to December 2019 in connection to having a booth in Qualcomm stadium; however one year into the agreement on January 11th, 2015 he received a letter stating that he can no longer have a booth at the swap meet due to a gun

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