Earlier today, I filed several items with the US District Court for the Eastern District of Virginia. Included in the documents are:
- A motion to amend my original complaint, to add St. Gabriel’s Massachusetts and the Episcopal Diocese of Massachusetts to the lawsuit.
- To add two additional torts to the complaint based on Virginia state law: Common law conspiracy and statutory conspiracy.
- A memorandum of law in opposition to the defendants’ motion to dismiss. At issue is their claim that Section 1983 actions don’t reach private actors. However, it is well-established that when they act in conjunction with a state actor, like the City of Alexandria, they become liable under Section 1983.
Motions court is set for late May in the matter.
Meanwhile, I am in the process of filing a motion for an injunction against perjuring priest Bob Malm, given that he or someone else at his IP address continues their illegal efforts to access my website. More on that shortly.