38.  In or around May, 2016, Donald J. Trump (“Trump”) became the presumptive  nominee of the Republican Party for President of the United States, by virtue of amassing the  number of pledged delegates around the United States and territories, to secure the nomination at  the Republican National Convention.   39.  Trump’s presidential campaign team, working in conjunction with local Republican  Party members in the San Francisco Bay Area, organized a Trump campaign rally to take place on  June 2, 2016, at the McEnery Convention Center in San Jose, California.   40.  Upon learning of the planned Trump Rally, several organizations, including Silicon  Valley Rising and the South Bay Labor Council began to organize and promote a “Dump the  Trump” counter-rally and protest, scheduled for the same day, and organized to take place outside  the McEnery Convention Center.   41.  Liccardo, the mayor of San Jose, is a registered Democrat and an outspoken critic of  Trump.   42.  Just prior to the Trump Rally, and in accordance with its policies, the San Jose  Police Department shut down the streets surrounding the convention center to vehicle and  pedestrian traffic.    43.  In a public statement before the Trump Rally, Police Chief Garcia stated, “we will  do everything possible to protect the First Amendment, those attending our Community, and our  Officers.”   44.  Despite this representation, Defendants not only failed to protect those attending the  Trump Rally, but created the danger that ultimately harmed the class members and deprived them  of their constitutional and statutory rights.   San Jose Police Direct Rally Attendees into the Mob of Violent Protesters   46.  Outside this exit, a police line directed the Trump supporters to turn north and to  proceed along Market Street, into the crowd of violent anti-Trump protesters.    47.  The police also actively prevented the Trump Rally attendees from proceeding south  along Market Street, away from the anti-Trump protesters, or from leaving the convention center  through alternative exits.    48.  As detailed below, the class members were chased and subjected to violence,  harassment, and intimidation on the basis of their real or perceived political affiliations, and several  were beaten, victimized by theft, had objects such as bottles and eggs thrown at them by the  protesters in full view of hundreds of police officers. Protesters also hurled insults, accused the  class members of being racists, and held signs reading, “We need socialism” and “A vote for  Trump is a vote for fascism,” while others waved Mexican flags. At least one individual was seen  burning an American flag, and another burning a hat displaying Trump’s “Make America Great”  campaign slogan.   49.  The violence continued to escalate, until dozens of fights had broken out amongst  the crowd, leaving many class members bruised and bloodied.   The City Defendants Fail to Protect Class Members from the Dangers They Created   50.  The City Defendants instructed and directed the police officers and other City  employees not to intervene in the many brutal attacks made against the Trump Rally attendees, or  otherwise failed properly to train the police officers to protect against the same.   51.  Instead of stopping the attacks, and as a result of the direction of the City Defendants,  several officers and other city personnel, including members of the San Jose Fire Department, refused  to respond to pleas for help from several of the Trump supporters. These refusals were made despite  the fact that the San Jose police officers were armed and, in many cases, wearing riot gear, and were  often mere feet away from ongoing acts of physical violence.   53.  The San Jose Police Department failed to declare the demonstration an unlawful  assembly until a full thirty minutes or more of violent altercations had ensued, following the  conclusion of the Trump Rally.   54.  It was not until approximately one hour after the Trump Rally’s conclusion that police  brought out megaphones and told demonstrators to leave or face arrest.    55.  Very shortly after these events, Liccardo used the situation as a platform to express  his personal political views, and cast blame on Trump for the violence, stating publicly:  San Jose police officers performed admirably and professionally to  contain acts of violence and protect individuals’ rights to assemble,  protest, and express their political views. While it’s a sad statement  about our political discourse that Mr. Trump has focused on stirring  antagonism instead of offering real solutions to our nation’s challenges,  there is absolutely no place for violence against people who are simply  exercising their rights to participate in the political process.   56.  On information and belief, the City Defendants acted with discriminatory animus  against the class members, based upon the real or perceived political affiliations of the class members,  intending to prevent, or with reckless disregard that their conduct would so prevent, the class members  from supporting the candidate of their choice, and to discourage others from doing the same.   57.  In so doing, the City Defendants violated the class members’ constitutional and  statutory rights to free speech, peaceful assembly, and due process.   58.  The Plaintiffs and class members were subjected to the violent acts of approximately  four hundred anti-Trump protesters, without police intervention, because the City Defendants  required the class members to exit the Trump Rally directly into the mob located a block away, in  furtherance of the City Defendants’ own political objectives and biases. The individual stories and  claims of the Plaintiffs are set forth below.  Hernandez and Haines-Scrodin Are Repeatedly Struck in the Face   59.  Hernandez and Haines-Scrodin attended the Trump Rally, exited the east-northeast exit  of the McEnery Convention Center, and were directed by the San Jose police to walk through the  anti-Trump protesters, rather than being allowed to turn south, in the direction of safety.   61.  The anti-Trump protester also yelled racial slurs at Hernandez and Haines-Scrodin.   62.  Hernandez suffered a broken nose, abrasions, and other severe bodily injuries as a  result of the attack, as well as severe emotional distress.   63.  Haines-Scrodin also suffered bodily injuries and severe emotional distress as a result  of the attack.   64.  Despite the San Jose police being in close proximity to this attack, the San Jose police  did not intervene or offer their assistance, and failed to do so at the direction of the City Defendants.  Frank and Nathan Velasquez Are Assaulted; Nathan Is Struck by Anthony Yi   65.  Frank Velasquez and his son, Nathan Velasquez, attended the Trump Rally and  exited the east-northeast exit of the convention center.   66.  After being directed by the San Jose police to walk through the anti-Trump protest,  rather than to the south, Anthony Yi, an anti-Trump protester, took Nathan Velasquez’s hat, which  Nathan had been wearing.    67.  After running approximately twenty-five yards, however, Yi slipped and fell near the  intersection of San Carlos Street and Almaden Boulevard.   68.  As Yi had taken more than one hat from the Trump supporters, Frank Velasquez  picked one up to determine whether this hat was the one taken from Nathan.   69.  Nathan then tried to help Yi get back on his feet, as well as determine whether either of  the other hats were the hat that Yi had taken from him.   70.  As Yi stood up, Yi struck Nathan in the head with his fist, causing Nathan severe  bodily harm, including a concussion, and severe emotional distress.    71.  Yi also possessed a knife at this time, but dropped the knife on the ground during the  altercation.   72.  Immediately following the attack, Nathan was pursued by a reporter who asked  Nathan Velasquez several questions pertaining to the events that just occurred.   74.  Shortly thereafter, Nathan and his father moved quickly back to the police line,  which was about one hundred yards away from the location of the original attack on the corner of  San Carlos Street and Almaden Boulevard, and were pursued by Yi and five or six other protesters.   75.  After explaining the situation to the police, Frank and his son were permitted to  stand in vicinity of the police, where they hoped that the violent attacks against them would not  continue.   76.  Nathan Velasquez has been unable to work due to his injuries and the emotional  distress caused by Yi’s conduct. Frank Velasquez has also suffered emotional distress arising from  these events, which have negatively affected his ability to manage the affairs of his San Jose based  business, particularly as his customers, employees, and vendors have witnessed an unclear  narrative of these events on national news, as well as witnessing police standing by and doing  nothing to prevent the assaults.  Protesters Taunt, Chase, Corner, and Throw Eggs at Casey   77.  Casey, who was wearing a Trump jersey that she purchased on her way into the  convention center, decided to the leave the Trump Rally about an hour after arriving, and was met  with the same police line, which refused to intervene between the protesters and those departing the  Trump Rally, and which directed her into the waiting, violent mob.   78.  As she walked away from the police line, however, Casey began to feel uncomfortable  due to the chants and taunts being shouted at her by the crowd of protesters.   79.  Two protesters, one wearing a green shirt and the other wearing a black and white  mask, approached Casey, raised their middle fingers in her direction, and began yelling, “Fuck  Trump!”   80.  As Casey continued to make her way through the protest, the crowd began to follow  and throw objects at her.    82.  Bystanders inside the Marriot began yelling to let her inside as the protesters continued  to surround and throw objects at Casey, including approximately seven eggs, a tomato, and a bottle of  water, while others spat at her. She was struck in the head by at least one egg that smashed upon  impact.   83.  The crowd continued to yell “Fuck Trump” as they attacked her, while she remained  trapped between the large crowd of violent protesters and the closed Marriot doors.   84.  Eventually, the Marriot guards opened the doors and allowed Casey to escape the mob.   85.  Despite the police officers being nearby, and having directed Casey into the violent  mob in the first place, the police did not take any action to come to Casey’s aid.  I.P. Is Assaulted and Denied Assistance by the San Jose Fire Department   86.  I.P., a fourteen-year-old minor, attended the Trump Rally with his father, Craig  Parsons.   87.  After the rally concluded, I.P. and his father exited the east-northeast exit of the  McEnery Convention Center, where a line of police officers prevented I.P. and his father from  turning right, to safety. Instead, I.P. and his father were directed by police to turn left, into the anti- Trump protesters.    88.  Thereafter, I.P. was struck in the back of his head, twice, by H.A., without warning,  and without seeing the attacker approaching.   89.  At this time, members of the crowd began repeatedly shouting, “Kill him!”   90.  I.P. then ran towards a nearby San Jose Fire Department vehicle while being chased  by a mob of anti-Trump protesters, and asked for the Fire Department employees’ assistance.    91.  The San Jose Fire Department refused to offer I.P., a minor, any assistance, despite  his pleas for help and the imminent danger.   92.  Shortly after being denied help, I.P. was chased by protesters and S.M. tackled I.P.  to the ground.   93.  Still, the San Jose Police and Fire Departments, which were present in large numbers  in the vicinity, failed to come to I.P.’s aid.   95.  I.P.’s father, Craig Parsons, saw I.P. cross the skirmish line, approached the police,  told them that I.P. was his son, and requested to cross the skirmish line to be with I.P., a recent  victim of several violent attacks.   96.  The police denied Craig Parsons’ request.  Zambetti Is Beaten with a Bag of Rocks   97.  Zambetti also attended the Trump Rally, left through the east-northeast exit and was  directed by the San Jose police to walk through the anti-Trump protest, rather than through  alternative, safe routes.   98.  Shortly after following the directions of the police, Zambetti was hit in the head by  an individual with a bag containing hard objects, which Zambetti believes to have been rocks.    Assault  (By Barbara Arigoni against DOES 36-38)  299.  Arigoni incorporates by reference all allegations in the preceding paragraphs as if fully  set forth herein.  300.  DOES 36-38 intentionally, willfully, wantonly, and maliciously threatened to harmfully  and offensively touch Arigoni, and to inflict severe bodily injury, in a manner so as to cause Arigoni  to reasonably believe she was about to be harmed.  301.  In light of DOES 36-38s’ violent demeanor and conduct surrounding these events,  including but not limited to pulling Arigoni’s hair and breaking her glasses, a reasonable person in  Argioni’s situation would have been offended by the threatened, violent touching.  302.  At no time did Arigoni consent to DOES 36-38s’ threatened conduct.  303.  As a direct and proximate result of DOES 36-38s’ threatening conduct, coupled with  the present ability to carry out such threats, Arigoni felt imminent apprehension of such contact, and  she therefore suffered severe emotional distress and other injuries to her person, in an amount to be  shown according to proof.   304.  As a direct and proximate result of DOES 36-38s’ conduct, Arigoni was harmed in an  amount according to proof at trial.  305.  Arigoni is informed and believes and alleges thereon that such acts directed towards her  were malicious and belligerent, and the acts were done with a conscious disregard of Arigoni’s right to  be free from such tortious and criminal behavior, such as to constitute oppression, fraud, or malice  pursuant to California Civil Code § 3294, entitling Arigoni to punitive damages, in addition to  compensatory damages, in an amount appropriate to punish and set examples of DOES 36-38.  Plaintiffs Attend Donald Trump Rally  