Gusman v. New York Times Company Document 1: Complaint

Louisiana Eastern District Court
Case No. 2:18-cv-06689
Filed July 13, 2018

COMPLAINT with jury demand against All Defendants (Filing fee $ 400 receipt number 053L-7001255) filed by Marlin N. Gusman. (Attachments: # 1 Civil Cover Sheet)Attorney Blake J. Arcuri added to party Marlin N. Gusman(pty:pla).(Arcuri, Blake)

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Page 1 UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA
MARLIN N. GUSMAN
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IN HIS OFFICIAL CAPACITY AS
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THE SHERIFF OF THE PARISH
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OF ORLEANS
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CIVIL ACTION NO.:
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VERSUS
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JUDGE
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THE NEW YORK TIMES COMPANY,
JONAH M.KESSEL,TAIGE JENSEN,
LEAH VARJACQUES,JAPHET
WEEKS,AND RODNEY ROUSSELL
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MAGISTRATE
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COMPLAINT
NOW INTO COURT, through undersigned counsel comes plaintiff, MARLIN N.
GUSMAN, in his official capacity as the Sheriff of the Parish of Orleans, who respectfully
represents as follows:
JURISDICTION
1.
Jurisdiction exists in this Honorable Court pursuant to 28 U.S.C. § 1332 and the
Constitution and laws of the United States of America; defendants specifically and purposefully
targeted residents and a political subdivision of the State of Louisiana, with full knowledge and
intent that the effects of their actions would be felt in the State of Louisiana, and therefore
purposefully availed themselves of the jurisdiction of this Honorable Court. See, e.g. Calder v.
Jones,465 U.S. 783, 104 S.Ct. 1482, 79 L. Ed. 2d 804(1984). Plaintiffs aver that their damages
exceed the jurisdictional threshold of$75,000 xonder 28 U.S.C. § 1332.
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