Case: 1:19-cv-07020 Document #: 1 Filed: 10/24/19 Page 1 of 11 PageID #:1 Pro Se I (Rev. 1716) Cormlaint tin a Civil Case UNrrBn Srerns Drsrrucr CoURT for the Northern District of lllinois Eastem Division :19-cv-07020 Judge Manish S. Shah Uagsfae Judge Sidney l- Sclrenkier 1 Adrian Rangel Plaintifls) name of each plaintiffwho is filing this complaint. If the names of all the plaintiffs cannotfit in the space abote, please wite "see altached" in the space and attach an additional page with theJull list ol'names.) (Write the full JuryTrial: ftheckone) @V". trNo r FIL ED Twitter Foundation Vrjaya Gadde Defendant(s) ocl 2 4 2019 (Write thefull name of each defendant who is being sued. If the names ofall the defendants cannotfit in the space above, please write "see attached" in lhe space and attach an additionol poge with thefull list of names.) THOMAS G. BRUTON CLERK, U.S. DISTRICT COURT COMPLAINT FOR A CIVI CASE The Parties to This Complaint A. The Plaintiff(s) Provide the information below for each plaintiffnamed in the complaint. Attach additional pages if needed. Name Adrian Rangel Street Address P.O. Box 1191 City and County Lake State and Zip Code lllinois 60M7 Telephone Number 312-696-9889 E-mail Address ad riangran gel @yahoo. Zurich ( Lake County ) com The Defendant(s) Provide the information below for each defendant named in the complaint, whether the defendant is an individual, a govemment agency, an otganzation, or a corporation. For an individual defendant, include the person's job or title (J know). Attach additional pages if needed. Page I of 5 Case: 1:19-cv-07020 Document #: 1 Filed: 10/24/19 Page 2 of 11 PageID #:1 Pro Se I (Rev. l?16) Comlaint lbr a Civil Case DefendantNo. I Name Viiaya Gadde Job or TitJe ftf known) Chief Executive Street Address 1355 Market St., Ste 900 City and County San Francisco ( San Mateo County State and Zip Code cA 94103 Telephone Number 4'.t5-222-%70 fficer ) E-mail Address (dknown) DefendantNo.2 Name Twitter Foundation Job or Title fifknown) Street Address 1355 Market St. Ste.900 City and County San Francisco ( San Mateo County State and ZipCode cA 94103 Telephone Number 415-222-9670 E-mail Address ) (if btown) DefendantNo.3 Name Job or Title fif lonwn) Street Address City and County State and Zip Code Telephone Nurnber E-mail Address (if known) DefendantNo.4 Name Job or Title fif known) Street Ad&ess City and Corurty State and ZipCode Telephone Number E-mail Address (if btovn) Page2 of 5 Case: 1:19-cv-07020 Document #: 1 Filed: 10/24/19 Page 3 of 11 PageID #:1 Pro Se II. I Basis for Jurisdiction Federal courts are courts of limited jurisdiction (limited power). Generally, only two types of cases can be heard in federal court: cases involving a federal question and cases involving diversity ofcitizenship ofthe parties. Under 28 U.S.C. $ 1331, a case arising under the United States Constitution or federal laws or treaties is a federal question case. Under 28 U.S.C. $ 1332, a case in which a citizen of one State sues a citizen of another State or nation and the amount at stake is more than $75,000 is a diversity of citizenship case. In a diversity of citizenship case, no defendant may be a citizen of the same State as any plaintiff. What is the basis for federal court iurisdiction? nrederal (check all that applv) Diversity of citizenship question Fill out the paragraphs in this section that apply to this A. If case. the Basis for Jurisdiction Is a Federal Question List the specific federal statutes, federal treaties, and/or provisions of the United States Constitution that are at issue in this case. B. If l. the Basis for Jurisdiction Is Diversity of Citizenship The Plaintiff(s) z. If the plaintiffis an individual The plaintiff, (namQ Adn€n Rangel State b. of lllinois (name1 If the plaintiffis Theplainliff, , is a citizen of the a corporation , is incorporated 1name1 under the laws of the State of fuame) and has its principal place of business in the State of fuame) (lf more than one plaintiffis named in the complaint, attach an additional page providing the same information for each additional plaintilf.) 2. The Defendant(s) a. Ifthe defendant is an individual The defendant, (name) Vijaya the State of fuame) Califomia Gadde , is a citizen Or is a citizen of of (foreign nation) Page 3 of 5 Case: 1:19-cv-07020 Document #: 1 Filed: 10/24/19 Page 4 of 11 PageID #:1 Pro Se v. I (Rev. 12116) Complaint tbr a Civil Case Certification and Closing Under Federal Rule of Civil Procedure I l, by signing below, I certiff to the best of my knowledge, information, and belief that this complaint: (l) is not being presented for an improper purpose, such as to harass, cause uurecessary delay, or needlessly increase the cost of litigation; (2) is supported by existing law or by a nonfrivolous argument for extending, modi$ing, or reversing existing law; (3) the factual contentions have evidentiary support or, if specifically so identified, will likely have evidantiary support after a reasonable opportturity for firther investigation or discovery; and (4) the complaint otherwise complies with the requirements of Rule 11. A. For Parties Without an Attorney I agree to provide the Clerk's Office with any changes to my address where case-related papers may be served. I understand that my failure to keep a current address on file with the Clerk's Office may result in the dismissal of my case. /0. uil, ?6/ I Date of signing: Signature of Plaintiff Printed Name of B. Plaintiff For Attorneys Date of signing: Signature of Attorney Printed Name of Attorney Bar Number Name of Law Firm Street Address State and ZipCode Telephone Number E-mail Address Page 5 of 5 Case: 1:19-cv-07020 Document #: 1 Filed: 10/24/19 Page 5 of 11 PageID #:1 Pro Se I (Rev. 12116) Conplaint lbr a Civil Case b. Ifthe defendant is a corporation , is incorporated under The defendant, (name) Twitter Foundation the laws of the State of (name) Califomia , and has its principal place of business in the State of fuame) Califomia Or is incorporated under the laws of (foreign nation) and has its principal place of business in (nanel (If more than one defendant is named in the cotnplaint, attaeh an additional page providing the same informatio n for each additional defendant.) 3. The Amount in Controversy The amount in controversy-the a:nount the plaintitf claims the det-endant owes or the amount at stake-is more than $75,000, not counting interest and costs of court, because (etplain): $1,000,000,000.00 ( One Billion Dollars ) for violation of Adrian Rangel's constitutional rights as outlined in both Seclion lll Statement of Claim and in Section lV Relief of this document. III. Statement of Claim Write a short and plain statement of the claim. Do not make legal arguments. State as briefly as possible the facts showing that each plaintiffis entitled to the damages or other relief sought. State how each defendant was involved and what each defendant did that caused the plaintiff harrn or violated the plaintiffs rights, including the dates and places of that involvement or conduct. If more than one claim is asserted, number each claim and write a short and plain statement of each claim in a separate paxagraph. Attach additional pages if needed. The case involves an incident which took place on September 7, 2019 online via Twiiter ( Twitter Foundation ), a cyber gathering, where United States citizens gather to exchange ideas both freely and candidly. The ideas and comments range in topic from the mundane to the comical, Quite frequently the topics tum to state, local and federal topics. ( continued on attached 6 page separate sheet Titled Statement of Claim continuation in rv. entiBty ) Relief State briefly and precisely what damages or other relief the plaintiffasks the court to order. Do not make legal arguments. Include any basis for claiming that the wrongs alleged are continuing at the present time. Include the amounts of any actual damages claimed for the acts alleged and the basis for these amounts. Include any punitive or exemplary damages claimed, the amounts, and the reasons you claim you are entitled to achral or punitive money damages. Plaintiff contends that Twitter Foundation and Vijaya Gadde violated Adrian Rangel's constitutional rights to freedom of speech, freedom of expression, freedom of religion, freedom of assembly, freedom from unlaMul seizure, due process, substantive due pnocess and equal protection rights of the United States Constitution. For the above violations of Plaintiff Adrian Rangel's constitutional rights by the Defendants Twitter Foundation and Vijaya Gadd ( both officially and unofficially), Plaintiff is asking this Court to award, jointly and or severally, the Plaintiff $100,000,000.00 compensatory and $900,000,000.00 in exemplary damages for the above violations of Adrian Rangel's constitutional rights and for intentional and negligent infliction of emotional distress upon the Plaintiff. Page 4 of 5 Case: 1:19-cv-07020 Document #: 1 Filed: 10/24/19 Page 6 of 11 PageID #:1 Adrian Rangel v. Twitter Foundation et al Statement of Claim I continuation in entirety ) This case involves an incident which took place on September 7,2019 via online Twitter ( Twitter Foundation ), a cyber gathering, where United States citizens and others come together to exchange ideas both freely and candidly. The ideas and comments exchanged range in topics from the mundane to the comical. Quite frequently, the topics turn to state, local and federal governmental concerns. Because the topics often touch on matters of serious concern regarding taxpayer money, the rhetoric can occasionally get fiery. At other times the topics touch on ideas affecting United States citizens'way of life and the direction of United States domestic policy. The comment " HANG THEM ALL " by the Plaintiff prompted Defendants Twitter Foundation and Vijaya Gadde to suspend Adrian Rangel's Twitter account - religiouserpico. Plaintiff contends that by suspending Plaintiff's account religiouserpico Defendants Twitter Foundation and Vijaya Gadde violated Adrian Rangel's constitutional rights to ( (1) freedom of speech, (2) freedom of expression, (3) freedom of religion, (4) freedom of assembly, (5) freedom against unlawful seizure, (6) due process, (7) substantive due process and (8) equal protection of the United States Constitution: Page 1 of 6 Case: 1:19-cv-07020 Document #: 1 Filed: 10/24/19 Page 7 of 11 PageID #:1 Adrian Ra lv, Twitter Foundation et al Freedom of Speech Responding to another Twitter post, Plaintiff posted or tweeted " HANG THEM ALL" whereupon Twitter immediately suspended Adrian Rangel's Twitter account named - religiouserpico. Adrian Rangel contends that his response " HANG THEM ALL" was rhetorical, vague and deliberately ambiguous aS to the " them " he had referenced in the phrase " HANG THEM ALL' . ln addition, Plaintiff contends that his " HANG THEM ALL" response / tweet produced no action, was not imminent, nor was likely to occur. lt iS important to note that the Plaintiff is not a member of any extremist group. As such, Plaintiff contends that Twitter Foundation and Vijaya Gadde violated his constitutional rights to Freedom of Speech by immediately suspending his Twitter religiouserpico account for Plaintiff's tweet of " HANG THEM ALL" il. . Freedom of Expression Similarly, Plaintiff contends that his post / tweet' HANG THEM ALL" was rhetorical, very Chicagoan in vernacular, vague and deliberately ambiguous as to the " them " Plaintiff referenced. Again, Plaintiff contends that his " HANG THEM ALL" tweet produced no action, was not imminent, nor was likely to occur. As such, Plaintiff contends that Defendants Twitter Foundation and Vijaya Gadde violated his constitutional rights to Freedom of Expression by immediately suspending his Twitter religiouserpico account for Plaintiff's use of the expression " HANG THEM ALL" Page 2 of 5 . Case: 1:19-cv-07020 Document #: 1 Filed: 10/24/19 Page 8 of 11 PageID #:1 Adrian Ra ilt. I v. Twitter Foundation et al Freedom of Religion Before the Defendants suspended Plaintiff's account, Plaintiff used Twitter to proclaim his religious beliefs to the public of being a Born Again King James Bible Only Christian. Plaintiff included the being Born Again King James Bible Only Christian in his Twitter profile. ln addition, Plaintiff followed and was followed by a number of people on Twitter - one group being people of likeminded religious beliefs. Tangentially, Plaintiff contends that President Donald J Trump was nothing short of miraculously elected by God into the Presidency; most specifically because of Donald Trump's victory in light of the tremendous media, political and social resistance to his election to the Presidency of the United States. Plaintiff used Twitter to support what Plaintiff contends is Donald J Trump's nothing shorl of miraculous election to the Presidency.As such, Plaintiff's religious beliefs are intertwined with Plaintiff's support of Donald J Trump as President of the United States of America. Plaintiff contends that Defendants Twitter Foundation and Vijaya Gadde violated Plaintiff's constitutional rights to Freedom of Religion by immediately suspending his Twitter religiouserpico account for Plaintiff's use of the phrase ,,HANG lv. THEM ALL". Freedom of Assembly Plaintiff contends that Twitter / Twitter Foundation have evolved past a mere online presence to comprise groupings of like-minded individuals who exchange a myriad of thoughts and expressions from the mundane to the Page 3 of 5 Case: 1:19-cv-07020 Document #: 1 Filed: 10/24/19 Page 9 of 11 PageID #:1 I v. Twitter Foundation et al comical to the social to the political to the economic to the religious to the global etc. Because Plaintiff used Twitter to communicate exchanges with individuals of like-minded religious and political beliefs, Plaintiff contends that Defendants Twitter Foundation and Vijaya Gadde violated his constitutional rights to Freedom of Assembly by suspending Plaintiff's religiouserpico account for Plaintiff's use of the phrase 'HANG THEM ALL'. V. Freedom against unlawful seizure Plaintiff used Twitter to express and propose his religious, political, social and moral beliefs etc to influence America to his way of thinking. As such, Plaintiff used Twitter to memorialize, catalogue and save many of his thoughts, ideas and philosophies. Plaintiff contends that by suspending his religiouserpico account Defendants Twitter Foundation and Vijaya Gadde constructively seized Plaintiff's online records to his tweets or Twitter communications in suspending and denying access to Plaintiff to his Twitter records / communications. ln so doing, Plaintiff contends that Twitter violated Plaintiff's constitutional rights against unlawful seizure - specifically Plaintiff's online Twitter tweets, vl. Due Process Violations Plaintiff contends that Defendants Twitter Foundation and Vijaya Gadde violated his constitutional due process rights in that Twitter immediately suspended Plaintiff's religiouserpico account before holding or giving the Plaintiff any kind of hearing. Twitter's Appeal process resulted in a denial of Page 4 of 5 Case: 1:19-cv-07020 Document #: 1 Filed: 10/24/19 Page 10 of 11 PageID #:1 Adrian Rangel v. Twitter Foundation et al Plaintiff's Appealwith little or no explanation by Defendants Twitter Foundation and Vijaya Gadde for the continued suspension of Plaintiff's religiouserpico Twitter account, Vll. Substantive Due Process Violations Plaintiff contends that Defendants Twitter Foundation and Vijaya Gadde violated his constitutional substantive due process rights because Twitter immediately suspended Plaintiff's religiouserpico account before holding or giving the Plaintiff any kind of hearing. Even Twittef s Appealprocess resulted in a deniat of Ptaintiff's Appeatwith little or no explanation by Defendants Twitter Foundation and Vijaya Gadde for the continued suspension of Plaintiff's relig iouserpico accou nt. Vlll. Equal Protection Violation Plaintiff contends that Twitter Foundation, a California Nonprofit Corporation, and Twitter CEO Vijaya Gadde, a California citizen are both inside of United States legal jurisdiction and as such subject to the laws of the United States Constitution. Plaintiff further contends that Defendants Twitter Foundation and Vijaya Gadde have illegally embarked upon an illegal circumvention of the United States Constitution in attempting to impose on United States citizens the legal cultures of foreign countries i.e. lndia, China, Russia, Germany, United Kingdom etc. Many of these foreign countries were once or still are considered third world countries because of their former or present totalitarian subjugation or colonizing regimes. As such, Plaintiff contends that Plaintiff's Page 5 of 6 Case: 1:19-cv-07020 Document #: 1 Filed: 10/24/19 Page 11 of 11 PageID #:1 Adrian Rangel v. Twitter Foundation et al rights to equal protection by the laws of the United States Constitution have been violated by Defendants Twitter Foundation and Vijaya Gadde's misguided application of a global and European Union type legal culture / philosophy in addressing United States citizens - in this specific case upon the Plaintiff for Plaintiff's use of the phrase "HANG THEM ALL". Relief Sought For the above violations of Plaintiff Adrian Rangel's constitutional rights by the Defendants Twitter Foundation and Vijaya Gadde ( in both her official and unofficial capacity ), Plaintiff is asking this Court to award the Plaintiff both jointly and or severally $100,000,000.00 compensatory and $900,000,000.00 exemplary in damages for the above violations of Plaintiff Adrian Rangel's constitutional rights and for intentional and negligent infliction of emotional distress upon the Plaintiff for Plaintiff's use of the phrase ..HANG THEM ALL'. Dated lo, z'1. sis""d go f 4 l(Q-{f PRo sE Printed: Adrian Rangel POB 1 191 Lake Zurich, lL 60047 312-696-9889 Page 6 of 5