/* The Malfeasance of St. Louis County: The County or the Klan? */

Monday, April 22, 2013

The County or the Klan?


b.      Defendants’ Motion Refers to No Facts Stated in the Pleadings
In addition to the wholesale fabrication of events, Defendants’ Motion studiously avoids addressing any of the factual allegations stated in the pleadings; nonetheless, they manage to admit to a state-created danger, and a “special relationship” with the Firm in performance of a “public function” which is “required by statute,” and the attendant assumption of liability under Monell; as well as establishing Bealmear’s liability in the racketeering predicate acts of extortion under color of official right pursuant to 18 U.S.C. § 1951, and violent crime in aid of racketeering pursuant to 18 U.S.C. § 1959.

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