Go-Go in Prince George's County

Case 8:14-cv-01592-DKC Document 1 Filed 05/15/14 Page 1 of 14
FILED
US. D!STRICTCOURT
DiSTRICT OF Hf,HYLAND
20\~ MAY IS AM 10: 21

UNITED STATESDISTRICTCOURT
r'L"""'" L"'r.'c'c
L..l"\f\ ':;- n lvL
I
FORTHE DISTRICTOF MARYLAND

AT BA.LTlt'IORE .
J
FOURTH CIRCUIT
BY ..__ __
. .OEPUT'T
PETITION FORSUIT IN EQUITY

(pursuant to 42,USC, 1983-1985)
A CLASSACTION PETITION
(pursuant to applicable rules, regulations, and laws governing a class of people residing
In different areas of the State of Maryland)
CLASS PETITIONERS; (and others similarly situated) SUIT IN EQITY;PETITIONERS

SEEKS$10,000,000.00 FROM
LAFAYETTE WILLIAMSON NAMED DEFENDANT IN HIS/
HER OFFICIALAND INDIVIDUAL
LOU SMALLS
JURY DEMAND
BRIAN LOGAN
JAMES RORIE CIVIL ACTION NO. 1> t: c, II-I-/$I;J..
DAN RICHARDSON
Vs.
DEFENDANTS;
PRINCE GEORGES COUNTY OF MARYLAND, et al;

Executive Office of District 7, Prince Georges County
Prince Georges County, Maryland
RUSH ERN BAKER, EXECUTIVE OFFICE

OFFICE OF THE EXECUTIVE OFFICER FOR DISTRICT 7
PRINCE GEORGES COUNTY, MARYLAND
NOTE; THE BELOW LISTED PERSONS, ARE MEMBERS OF
THE LEGISLATIVE COUNCIL, WHOM, TO THE KNOWLEDGE
OF THE ABOVE LISTED CLASS MEMBERS, ARE THOSE PERSONS
KNOWN TO AIDE, ABET, ASSIST AND CONSPIRED WITH OTHERS
KNOWN AND UNKNOWN TO SAID CLASS MEMBERS, TO PREPARE
AND INSTITUTE WITHOUT THE FULL KNOWLEDGE AND SUPPORT
OF MEMBERS OF THE TARGETED CLASS GROUP OF PEOPLE, NAMELY
THE BLACK RACE AND CULTURE OF THE STATE OF MARYLAND, SEEKING
UNCONSTITUTIONALLY, TO DEPRIVE AND TO ERADICATE AND DEMOLISH
AND TO FULLY DESTROY THE ONLY CULTURE KNOWN TO THIS CLASS OF AND
RACE OF BLACK PEOPLE HERE IN AMERICA AND THE STATE OF MARYLAND; THEY
ARE LISTED AS FOLLOWS, LED BY ONE; KAREN TOLES.

EXECUTIVE LEGISLATIVE COUNCIL OF DISTRICT 7

COUNCIL MEMBER KAREN TOLES (principle)
OFFICE OF THE EXECUTIVE COUNCIL
COUNCIL MEMBER FRANKLIN

COUNCIL MENBER PATIERSON

COUNCIL MEMBER TURNER

COUNCIL MEMBER JOHNSON

COUNIL MEMBER LEHMAN

COUNCIL MEMBE~ LAMPOS

PRINGEORGES COUNTY, MARYLAND
COUNCIL MEMBER OLSON

CHIEF POLICE
OFFICE OF THE CHIEF OF POLICE
DISTRICT 7
LEGISLATION BILL NO. CB-18-2011

EXECUTIVE OFFICE OF THE CHIEF EXECUTIVE
DEFENDANTS.
3
JURISDICTIONAL VENUE
THIS HONORABLE COURT HAS JURISDICTIONAL VENUE TO HEAR THIS CASE PURSUANT TO 42, U.S.c.
1983 AND 1985, AND ALL OTHER APPLICABLE FEDERAL RULES AND REGULATIONS GOVERNING THIS
COURT UNDER THE JURISDITION OF THE FOURTH CIRCUIT FOR THE STATE OF MARYLAND.
PETITONERS:
LAFAYETTE WILLIAMSON, IS A CLASS MEMBER OF THIS ACTION WHOM WERE INJURED IN HIS PERSONS
BY THE INTRODUCTION AND EXECUTIONING OF BILL CB-18-2011, THROUGH THE DIRECT ACTIONS OF
NEGLECT BY KAREN TOLES AND MEMBERS OF THE EXECUTIVE COUNCIL AND THE CHIEF OF POLICE OF
DISTRICT NUMBER 7, IN THEIR RESTRICTING THE CULTURE OF MY RACE, COLOR AND CULTURE BY
REFUSING TO ALLOW ME THE FREEDOMS OF EXERCISE, FREEDOMS OF SPEECH, FREEDOMS OF LIBERTY
IN MY CHOOSING TO DANCE IN A LEGAL PUBLIC OR PRIVATE PLACE OF MY CHOICE, BECAUSE OF MY
RACE, CREED, COLOR, AND CULTURE. I HAVE SUFFERED PAINS, PENALTIES, AND UNDUE ANGUISH AND
STRESS BECAUSE OFTHESE ILLEGAL ACTIONS.
BRIAN l O'G A l\.J
IS A CLASS MEMBER OF THIS ACTION WHOM WERE INJURED IN HIS PERSONS BY THE DIRECT ACTIONS
OF THE INTRODUCION AND EXECUTIONS OF BILL-CB-18-2011, THROUGH THE DIRECT ACTIONS AND
NEGLECT BY KAREN TOLES AND MEMBERS OF THE EXECUTIVE COUNCIL AND THE CHIEF OF POLICE OF
DISTRICT 7, IN THEIR COMPROMISED EFFORTS RESTRICTING THE CULTURE OF MY RACE, COLOR AND
CULTURE BY REFUSING TO ALLOW ME THE FREEDOMS OF EXERCISE, FREEDOMS OF SPEECH,FREEDOMS
OF LIBERTY IN MY CHOOSING TO DANCE IN A LEGAL PUBLIC SPACE OR PRIVATE PLACE OF MY CHOICE,
BECAUSE OF MY RACE, CREED, COLOR AND CULTURE. I HAVE SUFFERED STRAIN, PAIN, UNDUE
PENALTIES, ANGUISH, AND UNNESESSARY STRESS BECAUSE OF THESE ILLEGAL ACTIONS.
LOO~lU'~I\S
IS A CLASS MEMBER OF THIS ACTION WHOM WERE INJURED IN PERSON BY THE DIRECT ACTION OF
ARBITRARY ACTIONS OF THE INTRODUCTIONS AND EXECUTIONS OF BILL-CB-18-2011, THROUGH THE
DIRECT ACTIONS AND NEGLECT OF KAREN TOLES AND MEMBERS OF THE EXECUTIVE COUNCIL OF
PRINCE GEORGES COUNCIL AND THE CHIEF OF POLICE OF DISTRICT 7, ALL IN COMPROMISED EFFORTS
TO DEPRIVE AND RESTRICT THE CULTURE OF MY RACE, COLOR, AND CULTURE BY REFUSING TO ALLOW
4
ME THE FREEDOMS OF EXERCISE, FREEDOMS OF SPEECH, FREEDOMS OF LIBERTY IN MU CHOOSING TO
DANCE IN ANY LEGAL PUBLIC PLACE OR PRIVATE PLACE OF MY CHOICE OR TO LEGALLY VOTE ON THE
BILL CB-18-2011, BECAUSE OF MY RACE, CREED, COLOR AND CULTURE, ALL FOR THEIR SELFISH GAIN,
AND POLITICAL RISE AND PERSONAL GAIN. I HAVE SUFF.ERED UNDUE STRAIN, FINACIAL
STRESS, PENALTIES, AND ANGUISH BECAUSE OF THESE ILLEGAL PRACTICES.
PETITIONERS SIGNATURES;
3.
4.
DEFENDANTS;
PRINCE GEORGES COUNTY , DISTRICT 7 et aL;

IS NAMED ASA DEFENDANT IN THE INSTANT CAUSE BECAUSE IT IS THE DISTRICT WHICH
HOUSE THE BODY OF LEGISLATIVE BODY WHICH DISCRIMINATES AGAINST A SELECTED PEOPLE
OR PERSONS
RUSHERN BAKER ,IS NAMED AS A DEFENDANT IN THE INSTANT CASE BECAUSE RUSHERN BAKER
IS THE EXECUTIVE OFFICER OF DISTRICT 7 AND SIGNATURED INTO EFFECT THE ILLEGAL DISCRIMINATE
LEGISLATION WHICH DISCRIMINATES AGAINST A PERSON OR GROUP OF PEOPLE BECAUSE OF HIS/HER
RACE, CREED, COLOR, AND CULTURE, FOR PERSONAL, POlllTICAL AND FINANCIAL GAINS WITHOUT
ALLOWING THE FULL DISTRICT 7 RESIDENTS AND CITIZENS OF PRINCE GEORGES COUNTY THE
OPPORTUNITY TO BE FULLY INFORMED OF PENDING LEGISLATION AND VOTING OBLIGATIONS, AND DID
ACT IN COHERTS WITH EACH OF THE NAMED DEFENDANTS TO DEPRIVE THEM INDIVIDUALLY AND AS A
SELECTIVE BODY OF CITIZENS, OF HIS/HER CONSTITUTIONAL RIGHTS AND PROTECTIONS, ACTING IN
BOTH, OFFICE OF THE CHIEF EXECUTIVE, AND INDIVIDUAL CAPACITY; OTHERS SIMILARILY SITUATED
HAS SUFFERED FROM THESE ADVERSE ACTIONS EFFECTUATED BY AND THROUGH THE ILLEGAL EFFORTS
BY RUsHERN BAKER;
KAREN TOLES, IS NAMED AS THE PRINCIPLE DEFENDANT IN THE INSTANT CASE BECAUSE KAREN TOlES
is THE INSTiGATOR OF THE INSTRUMENTATION OF ILLEGAL ACTION AND DISCRIMINATORY DISREGARDS
FOR THE BLACK RACE AND CULTURE OF THE BLACK RACE, ATTEMPTING TO DEPRIVE THIS PARTICULAR
RAtE OF PEOPLE, AND PERSONS WITH PAST COMPLETED CRIMINAL BEHAVIOUR, FROM THE RIGHT OF
FREEDOMS OF EXPRESSIONS, FREEDOMS OF SPEECH, AND THE RIGHT TO VOTE AND BE FULLY
INFORMED OFTHEIR RIGHTS UNDER THE CONSTITUTION OF THE UNITED STATES OF AMERICA, AND DID
ACT IN CONCERT WITH EACH OF THE NAMED DEFENDANTS HEREIN TO DEPRIVE EACH NAMED
PETITIONER HEREIN AND OTHERS SIMILARILY SITUATED TO DEPRIVE THEM OF PROTECTED
CONSTITUTIONAL RIGHTS;
COUNCIL MEMBER FRANKLIN IS NAMED AS A DEFENDANT IN THE INSTANT CASE BECAUSE COUNCIL
MEMBER FRANKLIN ACTED IN CONCERTS WITH EACH OF THE NAMED DEFENDANTS IN THE INSTANT
CASE OF HIS/HER CONSTITUTIONAL AND STATE PROTECTED RIGHS TO BE FULLY INFORMED OF PENDING
LEGISLATION, THE RIGHT TO VOTE, THE RIGHT FOR FREEDOMS OF EXPRESSION, FREEDOM OF EXERCISE, .
AND THE RIGHT OF PEOPLE OF PARTICLAR COLOR, RACE, AND CULTURE TO ENGAGE THE FULL
PROTECTIONS OF THE UNITED STATES CONSTITUTION OF THESE UNITED STATES OF AMERICA;
COUNCIL MEMBER PATTERSON IS NAMED AS A DEFENDANT IN THE INSTANT CASE BECAUSE COUNCIL
MEMBER PAmRSON DID ACT IN CONCERTS WITH EACH OF THE NAMED DEFENDANTS IN THE INSTANT
CASE TO DEPRIVE EACH OF THE NAMED PETITIONERS IN THIS CASE, AND OTHERS SIMILARILY SITUATED,
OF THE RIGHTS OF FREEDOMS OF EXERCISE, FREEDOMS OF EXPRESSIONS, FREEDOMS OF VOTING
RIGHTS, THE RIGHT TO BE FULLY INFORMED OF PENDING LEGISLATION ADVERSLY EFFECTING A
PARTICULAR PERSON AND OR A GROUP OR BODY OF PEOPLE OF A PARTICULAR RACE, CREED, COLOR
AND CULTURE, AND PROTECTIONS OF THE UNITED STATES CONSTITUTION;
COUNCIL MEMBER TURNER IS NAMED AS A DEFENDANT IN THE INSTANT CASE BECAUSE COUNCIL
MEMBER TURNER DID SO ACT IN CONCERTS, WITH FULL KNOWLEDGE OF THEIR INTENT TO DEPRIVE A
CERTAIN AND PARTICULAR PERSON, AND OR A PARTICULAR GROUP OF PEOPLE OF HIS/HER FULL
PROTECTIONS OF THE UNITED STATES CONSTITUTION AND STATE AND OR COUNTY RULES AND
REGULATIONS, AS THESE DID APPLY TO AND CAUSE TO INJURE THE ENTIRE BODY OF NAMED
PETITIONERS AND OTHERS SIMILARILY SITUATED;
CONCIL MEMBER JOHNSON IS DULY NAMED AS A DEFENDANT IN THIS CLASS ACTION SUIT IN EQUITY
AGAINST THE ENTIRE SYSTEM OF LEGISLATORS IN THE DISTRICT 7 OF PRINCE GEORGES COUNTY,
MARYLAND BECAUSE COUNCIL MEMBER JOHNSON DID ,WITH KNOWLEDGE AND FORETHOUGHT,
ACTED TO DEPRIVE A PARTICULAR PERSON AND OR A PARTICULAR BODY AND OR GROUP OF PEOPLE OF
HIS/HER RIGHTS TO THE FULL PROTECTIONS OF THE UNITED STATES CONSTITUTION AND RULES AND
REGULATIONS OF THE STATE OF MARYLAND, DISTRICT 7 OF PRINCE GEORGES COUNTY THEREIN, AND
OTHERS SIMILARILY SITUATED, OF HIS/HER RIGHTS TO DANCE AND EXPRESS HIM OR HERSELF, IN THE
UNITED STATES ACCORDINGLY TO HIS/HER CULTURE, COLOR, CREED, OR RELIGIOUS PERSUATION;
COUNCIL MEMBER LEHAM IS NAMED AS A DEFENDANT IN THE INSTANT CASE BECAUSE, WITH FULL
KNOWLEGDE AND INTENT TO DEPRIVE EACH OF THE NAMED PETITIONERS, AND OTHERS SIMILARILY
SITUATED, OF RIGHTS PROTECTED AND SECRED UNDER THE UNITED STATES CONSTITUTION, AND
CERTAIN RULES AND REGULATIONS OF DISTRICT 7 , PRINCE GEORGES COUNTY, MARYLAND, AND
SUBJECTED NAMED PETITIONERS AND OTHERS SIMILARILY SITUATED, TO UNDUE HARM, PENALTY,
PAINS AND SUFFERINGS, INJURING THEM IN SUCH AN ATROCIOUS MANNER, THAT LED TO THE FILING
OF SEVERAL PETITIONS TO THIS HONORABLE CORT; NAMELY, THIS DEFENDANT AND CO-DEFENDANTS,
SUBJECTED THESE PETITIONERS TO REASONS TO BELITILE HIS/HER CULTURE OF DANCE
COMMUNICATIONS, FREEDOM OF EXERCISE, FREEDOM OF SPEECH, AND MANY OTHERS, SLEEP IS A
CONSTANT DISTANT FREEDOM, ETC.;
COUNCIL MEMBER CAMPOS, A DEFENDANT NAMED HEREIN, ACTED IN CONCERTS WITH EACH OF THE
DEFENDANTS TO DEPRIVE EACH OF THE NAMED PETITIONERS, AND OTHERS SIMILARILY SITUATED, OF
CERTAIN RIGHTS AND IMMUNITIES PROTECTED BY THE UNITED STATES CONSTilTUTION AND MANY
RIGHTS, RULES, AND REGULATIONS, FOR PERSON GAIN AND POLITICAL REASONS BENEFICIAL TO HIM
AND OTHERS IN CONCERTS WITH THE LEGISLATIVE BODY FOR DISTRICn IN PRINCE GEORGES COUNTY,
MARYLAND. THE CULTURE OF THE BLACK RACE AND THE VOTING ISSUEES ARE INTEREST HERE IN
INFAMOUS AGENTS IN THIS INJURY;
COUNCIL MEMBER OLSON IS NAMED AS A DEFENDANT IN THE INSTANT CAUSE BECAUSE THIS
DEFENDANT AIDED AN ABETIED THE NAMED BODY OF LEGISLATORS IN DEPRIVING THE NAMED
PETITIONERS AND OTHERS SIMILARILY SITUATED TO ACTS WHICH DEFAMED THE INDIVIDUALITY OF
EACH AND THE ENTIRE BLACK CULTURE, COLOR, RACE, CREED, AND BELIEFS IN DANCE CULTURE,
FREEDOMS OF EXPRESSION, FREEDOMS OF SPEECH, AND FREEDOMS OF LIFE, LIBERTY, AND PURSUIT
OF HAPPINESS IN RELIANCE UPON THE UNITED STATES CONSTITUTION AND RULES AND REGULATIONS
OF THE DISTRICT 7 OF PRINCE GEORGES COUNTY, MARYLAND.
THE CHIEF OF POLICE FOR DISTRICT 7 , PRINCE GEORGES COUNTY, MARYLAND, IS CERTAINLY A
DEFENDDANT IN THE INSTANT CASE. THIS CHIEF IS RESPONSIBLE FOR THE SAFETY, PROTECTION, AND
SECURITY OF ALL PEOPLE RESIDING, VISITING, AND PASSING THROUGH THE DISTRICT 7 OF PRINCE
GEORGES COUNTY, MARYLAND, YET THIS DEFENDANT IN COHERTS WITH MALICE, CONSPIRED WITH
OTHER DEFENDANTS IN THIS CASE, ESPECIALLY WITH KAREN TOLES, TO DEPRIVE THE ENTIRE BLACE
CULTURE AND THE BLACK RACE OF PEOPLE AND THOSE PREVIOUSLY CONVICTED BUT PAID HIS/HER
OBLIGATIONS TO THE PEOPLE, OFTHE BLACK CULTURE OF DANCING. DANCING IS THE ONLY FORM OF
COMMUNICATIONS EXPRESSED BY THE ENTIRE BLACCK RACE OF PEOPLE IN ACCOMPANY OF MUSIC TO
ISSURETHATTHEIR CULTURE THROUGH EXISTENCE IN AN FORIEGH LAND, WAS INTACT, SINCE
LANGUAGE AND READING WERE DENIED TO THEM, SOME UNTO THIS VERY DAY. THE FREEDOMS OF
SPEECH, EXPRESSIONS, EXERCISE, AND LIBERTY IN PURSUIT OF HAPPINESS, THOUGH LIMITED TO THIS
CULTURE OF PEOPLE, WERE PRECIOUS LIFE SKILLS INHERITED BYTHE BLACK RACE AND FOR THIS
SELECTED BODY OF DEFENDANTS TO SUBJECT THESE PETITIONERS TO SUCH AN INJURY, WAS
DELIBERATE, CALOUS, AND WITHOUT REGARD NOR RESPECT FOR THE CONSTITUTION OF THESE
UNITED STATES OF AMERICA. THIS DEFENDANT DENIED CERTAIN POLICE PROTECTIONS TO THESE
PETITIONERS AND ACTED IN A PERSONAL MANNER AFAR FROM OFFICIAL DUTIES IN THE PERFORMANCE
OF SUCH ATROCOUSITIES;
LEGISLATIVE BILL NO. CB-18-2011 SHOULD BE NAMED AS THE ELEMENT OF HATE DIRECTED AGAINST AN
ENTIRE RACE OF PEOPLE SIMILARILY SITUATED IN DISTRICT 7, PRINCE GEORGES COUNTY, MARYLAND,
AND OTHERS SIMILRILY SITUATED, TO DEMEAN, DEPRIVE, AND BELITTLE EACH OF THE NAMED
PETITIONERS AND OTHERS SIMILARILY SITUATED, OF CERTAIN CONSTITUTIONAL PROTECTIONS,
FREEDOM OF EXPRESSION, FREEDOM OF EXERCISE, FREEDOMS OF LIBERTIES IN PRSUIT OF HAPPINESS
AND SPEECH, EXTREMELY INJUOUS TO THESE PETITIONERS AND OTHERS SIMILARILY SITUATED.
STATEMENT OF PETITIONERS CASE, AND OTHERS SIMILARILY SITUATED
OPENING STATEMENT
HOW CAN THE INSTANT DEFENDERS NOT INSTITUTE THESE SAME TYPE OF RESTRICTIONS AGAINST
AGENCIES WERE CERTAIN VIOLENT ATROCITIES ARE KNOWN TO THE WORLD TO HAVE CAPTIVATED THE
ESSENCE OF VIOLENCE, SUCH AS PUBLIC SCHOOL SHOOTINGS, MILITARY BASES, PUBLIC
TRANSPORTATION AREAS, ON OUR SCHOOL BUSES, AND NOT TO MENTION THAT PRINCE GEORGES
COUNTY POLICE DEPARTMENTS HAVE BEEN UNDER CONSTANT REVIEW BYTHE UNITED STATES
DEPARTMENT OF JUSTICE FOR IT'S INVOLVEMENT WITH POLICE BRUTALITY AND CRUELTY TO
INMATES ...YET NO SUCH BILL EXIST IN PRINCE GEORGES COUNTY TO CU~TAIL THIS VIOLENCE, YET THE
DEFENDANTS IN THE INSTANT CASE PUTS" DANCING ON TRIAL, A NATION IMPRISONED ...MAY GOD
HAVE MERCY!"
CASE IN SUMMARY
ON OR ABOUT JUNE 21 , 2011, KAREN TOLES, IN CONCERTS WITH RUSHERN BAKER, CHIEF OF POLICE OF
DISTRICT 7 OF PRINCE GEORGES COUNTY, MARYLAND, MEMBERS OF THE LEGISLATIVE BODY FOR
DISTRICT 7, COMPRISING OF COUNCIl MEMBER FRANKLIN, COUNCIL MEMBER PATTERSON, CONCIL
MEMBER TURNER, COUNCIL MEMBER JOHNSON, COUNCIL MEMBER LEHMAN, COUNCIL MEMBER
CAMPOS, COUNCIL MEMBER OLSON, AND OTHERS UNKNOWN AND UNNAMED BY THESE PETITIONERS,
DID COME TOGETHER AND CONSPIRED TO DEPRIVE THE ENTIRE BLACK RACE, AND PARTICULARLY
THOSE SIMILARILY LOCATED WITH THE DISTRICT7, BUT TO EFFECT THE ENTIRE PRINCE GEORGES
COUNTY, MARYLAND, AND FOR FAR GREATER REACHING EFFECT,OF THE VERY ESSENCE OF THE BLACK
CULTURE WITH THE INTRODUCTION OF BILL-CB-18-2011.
THIS BILL, CB-18-2011 DEPRIVES THE ENTIRE BLACK RACE WITHIN THE PRINCE GEORGES COUNTY ,
MARYLAND, FROM EXERCISING THE FREEDOM OF EXPRRESSION THROUGH DANCE, THE FREEDOM OF
SPEECH THROUGH DANCE, THE FREEDOM OF LIBERTY AND FREEDOMS TO PURSUE HAPPINESS AS A
BLACK RACE ONCE DENIED THE RIGHT TO FREEDOM OF SPEECH, DENIED THE RIGHT TO READ ,WRITE,
AND COMMUNICATE, THUS, THE CULTURE OF DANCING WAS THE ONLY MEANS OF COMMUNICATION,
THEIR MUSIC WAS THE ONLY MEANS OF SPEECH THROUGH THIS COMMUICATION, YAT THIS ATROCIOUS
BILL CB-18-2011 WAS INTRODUCED WITHOUT THE FULL KNOWLEDGE AND PARTICIPATION BY AN OR
FOM ANY OF THE NAMED PETITIONERS. THIS BILL RESTRICTED THE RIGHTS OF EXOFFENDERS TO FULL
EXPRESS THE RIGHT TO BE FREE FROM OBLIGATIONS TO CRIMES COMPLETED IN SERVICE AND
SERVITUDE TO THE COMMUNITY AND SOCIETY IT OFFENDED, TO BE ABLE TO AFFORD HIM/HERSELF
WITH THE OPPORTUNITY TO HAVE LIBERTY TO PURSUE A LIFE OF HAPPINESS WITH HIS/HER FAMILY, OR
JUST PLAIN SEL ASSURANCE THAT FREEDOM PREVAILS AFTER AN AFFRONT TO SOCIETY. THIS BILL, CB-
18-2011, MALICIOUSLY INTRODUCED, WITH MALICE AND FORETHOUGHT TO DEMEAN, DETRACT FROM
THE GOOD STANDING IN CULTURE WITH AN EXISTING SOCIETY OF COMMON FOlK, TO ABOLISH A
CULTURE OF DANCING, GRANDFATHERED INTO EXISTENCE BECAUSE OF DENIALS OF EDUCATION,
LANGAGE BARRIERS, FREEDOMS OF EXPRESSION, FREEDOMS OF EXERCISE, FREEDOM TO EXERCISE THE
DEMOCRACY OF ONE VOTE PER PERSON, TO CHALLENGE AND LEGISLATION, TO DEBATE ANY SUCH
INTRODUCED LEGISLATION" TO DESTROY AN ENTIRE RACE OF IT'S INHERITED CULTURE, TO DENY A
PEOPLE, A PERSON, AND A PARTICULAR BODY AND A PARTICULAR GROUP OF PEOPLE, OF THE RIGHT TO
DANCE.
DANCING HAS NEVER CAUSED A KILLING IN A DERROGATORY SENSE, DANCING HAS NEVER CAUSE ANY
PERSON TO DRING AN ILLLEGAL SUBSTANCE, DANCING HAS NEVER CAUSE A SHOOTER TO ENTER A
SCHOOL CLASS ROOM AND BEGAN SHOOTING AND KILLING INNOCENT CHILDREN, DANCING HAS NEVER.
CAUSED A SHOOTER TO ENTER A MILITARY ESTABLISHMENT TO KILL AND HARM INNOCENT PEOPLE,
DANCING HAS NEVER CAUSE ANY ONE TO ENTER A METRO STATION TO HARM, MUG, RAPE, OR
DESTROY PROPERTY, DANCING HAS NEVER CAUSED ONE TO ENTER A LIQUOR ESTABLISHMENT TO
PURCHASE ALCOHOL, IS ALWAYS ASSOCIATED WITH ONE LONE CULTURE, THAT CULTURE STANDS
ALONE AS MUSIC, DANCING IS CUSTOMARY ASSOCIATED WITH THE BLACK CULTURE, DANCING HAS
NEVER BEEN ON TRIAL IN ANY COURT ROOM IN AMERICA, DANCING EVEN ASSOCIATE ITSELF AND
CUSTOM WITH EVERY MEMBER OF THIS UNITED STATES OF AMERICA, DANCING IS ADDRESSED WITH
EVERY OCCASION OF CELEBRATION EXISTING IN AMERICA, SO WHY DENOUNCE THE, ART OF DANCING
AS IT EXIST WITHIN THE VERY ESSENCE AND CULTURE OF APARTICULAR RACE OF PEOPLE, AND RESTRICT
DEMEAN A PARTICULAR PERSON, OR PERSONS, SUCH AS THESE INDIVIDUAL PETITIONERS. HEREIN.

DANCING HAS DESTROYED SADDNESS, DANCING HAS DESTROYED SELF PITY, DANCING HAS DESTROYED
lOW SELF ESTEEM, DANCING HAS DESTROYED BEING ON THE STREETS WITH THE WRONG CROWD, BUT
NEVER HAS DANCING BEEN ACCUSED OF VIOLENCE. DANCING HAS KEPT A WHOLE BODY OF SLAVES,
TAKEN AFAR FROM THEIR NATIVE HOME LAND, BEING GIVEN THE RIGHT TO ASSEMBLY, BUT NOT TO
TALK, READ OR WRITE ..WE COULD DANCE! DANCING IS "GRAND-FATHERED INTO OUR CULTURE" AND
CHARACTERIZES OUR MEANS TO COMMUNICATE, EXPRESS AND SPEAKS TO OUR VERY
EXISTENCLHOW CAN DANCE HALLS BE DENIED?
THE NAMED DEFENDANTS IN THIS PETITION MERELY DEMONSTRATES THE INSTillED HATRED AND
DISLIKE FOR THE BLACK CULTURE. WITH INTENT TO DENY THE FREEDOMS OF ASSEMBLY, EXPRESSIONS,
SPEECH, EXERCISE, AND THE FREEDOM TO PURSUIT THEIR INDIVIDUAL HAPPINESS IN FAME AND
FORTUNE, THEY INSTITUTE CHANGES IN THE LAW WHICH WOULD GREATLY DENY THESE RIGHTS,
PRIVilEGES, IMMUNITIES AND CONSTITUTIONAL PROTECTIONS.
THE INTRODUCTION OF Bill CB-18-2011 DENIED THESE PETITIONERS THE RIGHT TO DELIBERATE,
DISCUSS, MEDIATE, AND MORE IMPORTANTLY, TO VOTE UPON THE INGREDIENTS AS WRITIEN IN THIS
BilL. THE CONDITIONS, EFFECTS, SAFETY FEATURES, HEALTH HAZARDS, AND THE FUll PRO'S AND
CON'S OF THE ENTIRE EFFECT OF THIS Bill, THIS WAS NOT UNDERTAKEN BYTHIS BODY OF lEGISLATURE
WHOM SUPPOSSEDlY, REPRESENT THE FUll POPULATION OF DISTRICT 7 IN PRINCE GEORGES COUNTY.
THE DEFENDANTS IN THIS INSTANT CASE, AS THEY PREPARED AND INTRODUCED SUCH AN III GOTIEN
MEASURE, "WEll KNEW, OR SHOULD HAVE KNOWN" , THAT SUCH A lEGISLATION AS IT, WAS AND
REMAINS" FRUITS FROM A POISONOUS TREE" AND COULD NOT SURVIVE IN A COURT OF LAW!
THIS Bill ONLY EXIST TO DESTROY A CULTURE, DENY A PARTICULAR GROUP OF PEOPLE, AND DENY ANY
PERSON COMPLETING HIS/HER DEBT TO SOCIETY, THE TRUE EXPERIENCE OF FREEDOM. THEY HAD All
INTENTIONS TO DENY THIS PARTICULAR GROUP OF PETITIONERS THEIR INHERITED RIGHTS, AND THEY
GATHERED IN COHESIONS WITH ONE THE OTHER TO DISCONNECT THIS CULTURE FROM IT'S RACE OF
PEOPLE. THIS Bill, CB-18-2011, CHAllENGE THE" FORCE OF LAW" AND INPUNES THE INTEGRITY OF
THIS COURT IF IT IS AllOWED TO STAND ...SUCH AN ATROCITY TO All MANKIND, "A NATION
IMPRISONED ...MAY GOD HAVE MERCY! "
PETITIONER'S CLOSING STATEMENT
WHEREAS, BECAUSE THESE PETITIONERS, AND OTHERS SIMilARLY SITUATED, HAS PRESENTED A PRIMA
FACIE SHOWING OF RACIAL PREJUDICE, AND DESCRIMINATION AND THE DENIALS OF PROTECTED
CONSTITUTIONAL RIGHTS, THAT THIS SUIT IN EQUITY SHOULD BE AllOWED TO CONTINUE AND
PROCEED UNTIL A DULY SELECTED PANEL OF JURY PEERS COULD DETERMINE THE FULL MERITS AND
CONCLUSIONS OF LAW AND FACT S IN THIS CASE
JURY DEMAND
TEN MILLION DOLLAR SUIT IN EQUITY
WHEREAS, BECAUSE THESE PITIONERS ARE ENTITLED TO A SUIT IN EQUITY AND DAMAGES THEREFROM
, PURSUANT TO 42, USC, 1983, WHERE AN INJURED PARTY MAY SUE FOR INJURY, THE NAMED
PETITIONERS HEREIN, AND OTHERS SO SIMILARILY SSITUATED, REQUEST THAT EACH NAMED
DEFENDANT BE SUED IN HIS/HER OFFICIAL AND INDEPENDENTLY IN HIS/HER INDIVIDUAL CAPACITY,
AND FURTHER, FOR COMPENSATORY DAMAGES IN EACH OF THE NAMED DEFENDANTS IN HIS/HER
OFFICIAL CAPACITY, FOR INJURY CAUSING TRAUMATIC STRESS, AND FINANCIAL STRAIN, EACH
INDIVIDUAL DEFENDANT IS REQUESTED TO PAY THE AMOUNT OF TEN MILLION DOLLARS;
AND FURTHER, FOR COMPENSATORY DAMAGES, AND IN EACH OF THE DEFENDANTS IN HIS/HER
INDIVIDUAL CAPACITY, EACH NAMED DEFENDANT, INDIVIDUALLY, FOR INJURY CAUSING TRAUMATIC
STRESS, AND FINANCIAL STRAIN, EACH NAMED DEFENDANT IS REQUESTED TO PAY THE AMOUNT OF
TEN MilLION DOLLARS;
FURTHER, FOR PUNITIVE DAMAGES, EACH INDIVIDUAL DEFENDANT NAMED IN HIS/HER OFFICIAL
CAPACITY, IS BEING SUED FOR CAUSING EMOTIONAL STRESS, FINANCIAL STRAIN, AND TRAUMATIC
INDIFERENCE TO INDIVIDUAL PETITIONERS WHOM INJURY WAS CAUSED SOLELY UPON THE PREMISES
THAT SUCH A PETITIONER, IN HIS/HER OFFICIAL AND OR INDIVIDUl CATEGORY EITHER BECAUSE HE/SHE
HAS OR HAD COMPLETED HIS/HER DEBT TO SOCIETY FOR ANY CRIME COMITTED, THAT HE/SHE LATER
WERE DENIED CERTAIN EMPLOYMENT BENEFITS ENJOYED BY OTHER HUMANS AS PROTECTED UNDER
THE UNITED STATES CONSTITUTION, EACH OF THE NAMED DEFENDANTS HEREIN, BE REQUESTED TO
PAY THE AMOUNT OF TEN MILLION DOLLARS TO EACH OF THE NAMED PETITIONERS PERTAINING
THERETO;
FURTHER, FOR PUNITIVE DAMAGES, EACH INDIVIDUAL NAMED DEFENDANT HEREIN IN HIS/HER
OFFICIAL CAPACITY
, IS BEING SUED FOR CAUSING EMOTIONAL STRESS, TRAUMATIC INDIFFERENCE, AND FINANCIAL STRAIN,
IS HEREIN REQUESTED TO PAY THE AMOUNT OF TEN MILLION DOLLARS;
FURTHER, THE NAMED DEFENDANTS IN THIS ENTIRE SUIT IN EQUITY AND ANY AND All SUCH PENDING
LEGAL ACTIONS IN RELATIONS TO THIS ACTION, BE ORDERED TO PAY FOR ANY AND ALL ATTORNEY FEES,
AND ANY AND ALL COST OF COURT PROCEEDINGS,
AND FURTHER, PETITIONERS SEEKS TO HAVE THE ENTIRE BILL CB-18-2011, BE HELD IN ABEYENCE UNTIL
SUCH TIMES AS THE ENTIRE MATTER IN THE CAUSE PRESENTED BY AND FROM THESE PETITIONERS,
UNTIL SUCH TIMES AS TO ALLOW THE ENTIRE CITIZEN POPULATION OF DISTRICT 7 HAD BEEN FULLY
AWEAR OF IT'S FULL EFFECTS AND CONTENT TO THE BLACK POPULATION OF DISTRICT 7 AND THE
ENTIRE POPULATION OF RESIDENTS RESIDING IN DISTRICT 7 BE AFFORDED THE OPPORTUNITY TO VOTE
UPON THE FULL RAMIFICATIONS AND THE TURE IMPLICATIONS TO WHICH BILL CB-18-2011
REPRESENTS IN PRINCE GEORGES COUNTY, MARYLAND,
AND FURTHER, ANY OTHER SUCH SANCTIONS TO WHICH THIS COURT MAY DEEM APPROPRIATE AND
PRACTICAL, IT IS SO MOVED, SET FORTH AND PRAYED FOR.
CLASS PETITIONERS,
LAFAYETTE WILLIAMSON
BRIAN LOGAN
LOU SMALLS
OTHERS SIMILARILY SITUATED

CERTIFICATE OF SERVICE
WE, THE UNDERSIGNED CLASS PETITIONERS, UNDER PENALTY OF PEJURY, DO SO CERTIFY THAT WE
ARE CITIZENS OF THESE UNITED STATES OF AMERICA, THAT WE ARE TAX PAYING LAW ABIDING
CITIZENS OF THE STATE OF MARYLAND, WITH CLEAN HANDS, AND WE DECLARE AS SUCH, THAT WE
BELIEVE THAT WE ARE ENTITLED TO THE REDRESS AND RELIEF WE SEEK SETFORTH AND PRAYED FOR
HEREIN; AND FURTHER, THAT WE HAVE CAUSED TO BE DELIVERED, THE ORIGINAL TO THE CLERK OF
THIS COURT, AFTER PAYING FILING COST, AND FURTHER, THAT WE HAVE CAUSED TO DELIVER, VIA U.s.
POSTAGE, POSTAGE FIRST PREPAID, A COPY TO EACH OF THE NAMED DEFENDANTS, AT HIS/HER
BUSINESS ADDRESS, AS THE LAST KNOWN ADDRESS OF CONTACT KNOWN TO THESE PETITIONERS,
(SUCH BEING/OR KNOWN TO BE, IN THE PUBLIC REGISTAR FOR LOCAL DISTRICT 7
BEING SO CERTIFIED AS A TRUE BILL, ON THIS DAy OF May, 2014.
CLASS PETITIONERS; ( and others similarly situated)
LAFAYETIE WILLIAMSON JAMES RORIE
BRIAN LOGAN
DAN RICHARDSON
LOU SMALLS
Case 8:14-cv-01592-DKC Document 1-1 Filed 05/15/14 Page 1 of 13
i I
1
DR-3
. I
COUNTY COUNCIL OF PRINCE GEORGE'S COUNTY, MARYLAND
i
2011 Legislative Session '
Bill No. CB-18-2011
Chapter No. 9
Proposed and Presented by Council Member Toles I

!
Irltroduced by Council Members Toles, Franklin, Patterson, Turner;, Johnson, Lelunap,
, I
Campos and Olson i
Date of Introduction June 21, 2011
EMERGENCY BILL
I AN EMERGENCY ACT conceming I
2 Dance Halls I
. I
3 For the purpose of amending County regulations concerning dance hall, premises, oW(l.ers,
i
4 lessors, operators, managers, promoters and patrons, establishing licerjse requirements, ~etting
5 penalties for violators, declaring specific legislative intent to establish ;reasonable and Uliiform
6 laws to reduce the number of violent crimes that occur as a result of events at dance hallf and to
7 promote the health, safety, and welfare of the citizens and residents of:Prince George's <j:ounty
i
8 and declaring that a public emergency exists affecting the public health, safety, and welJ1are.
BY repealing and reenacting with amendments:
I
9
10 SUBTITLE 5. BUSINESSES AND LICENSES;
,
II Sections 5-197, 5-198, 5-199, 5-200, 5-200.01,
12 5-200.02,5-200.03, and 5-200.04,
13 The Prince George's County Code
14 (2007 Edition, 20 I0 Supplement).
15 BY adding:
16 SUBTITLE 5. BUSINESSES AND LICENSES.
17 Section 5-196.01,
18 The Prince George's County Code
19 (2007 Edition, 2010 Supplement).
!
20 SECTION I. BE IT ENACTED by the County Council of Prince George's Count~,
21 Maryland, that Sections 5-197, 5-198, 5-199, 5-200,5-200.01,5-200.02,5-200.03, and ~-200.04
CB-18-20111(DR-3)
. I
I ofthe Prince George's County Code be and the same are hereby repealed and reenacted ith the
2 following amendments: I,
3 SUBTITLE 5. BUSINESSES AND LICENSES.
4 DIVISION 14. PUBLIC DANCES. I
5 Sec. 5-197. Definitions. '
6 (a) The following words, as used in this Division, shall for the ptirpose ofthis Divition,
. !
7 have the meanings respectively ascribed to them in this Section:
8 ill Administrative Board shall mean the entit that conducts an administrati e
9 hearin com rised of the Director of Environmental Resources or their ,desi nee the Chi f of
10 Police or their designee, and the Chief ofthe Fire/EMS Department or {heir designee.
II , [(I)] ill [Dance hall shall be construed to mean any road h6use, restaurant,
12 I lunchroom, cafe, inn, hotel, or club for profit where public dancing is permitted,]
• Adult ance
13 I hall shall be construed to mean any road house, restaurant, lunchroom, :cafe, inn, hotel,
I
14 I ni htclub club or an establishment or remises for ersons twen -one ears of a e or ,lder
15 I where public dancing is permitted for profit. An owner, lessor, operator, manager, promJter or
,
16 ! licensee of an adult dance hall rna not allow an individual who is under the a e of twen -one
17 ears on the remises for which the ermit is issued, unless the individual is em 10 ed b or is
18 an immediate family member of the owner, lessor, operator, manager, womoter or licens e.
19 I [(2)] ill Director shall mean the Director of Environmental Resources or the
20 i Director's designee, unless otherwise specified.

21 ill Police De artment shall mean the Prince Geor ent.
22 ill Police Chief shall mean the Chief of the Prince George1s County Police
23 Department.
24 @ Police Officer shall mean a sworn member of the Prine!: Geor e's Count Police
25 Department.
26 [(3)] ill Private club shall mean an establishment proviclil1g facilities for
27
28
29
entertainment or recreation for only bona fide members and guests, and. not operated for , rofit
nor generally open to the public.

[(4)] l]} Promoter
•
shall mean a person or a business that n~akes arrangemen
1 for
30 events for or not for profit.
2
CB-18-2011 (DR-3)
I
1 !
,
[(5)] i2l Public dance shall mean an event to which the general public is invit~d,
- '
2 I with or without an admission fee, at which live or recorded music is pla1ed; attendees arel
3 i allowed or encouraged to dance; and the purpose or goal of the event is ito make a profit ftr the
t
4 Ilessee, operator, manager, licensee, holder, owner, [or] promoter erso~ in char e or edon in
I
5 iapparent charge of the event. A public dance is not a benefit performance as defined und r
i i
6 I Subtitle 5, Division 2, of this Code, :
7 ! [(6)] Q..Ql Public nuisance shall be construed to mean anything that endangers ife or
8 ihealth, obstructs the quiet enjoyment and reasonable use of the property of persons in a p icular
: - I
9 iarea, ' !
10 i [(7)] J1D. Teen Dance Hall shall be construed to mean any road house, restaur~nt,
: ' I
II I lunchroom, cafe inn hoteL ni htclub club or an establishment or remises for ersons huder
,
12 ! twen -one ears of a e where ublic danein is ermitted for rofit. An owner lessor erator
13 romoter or licensee of a teen dance hall ma not allow an individual who is
14 hteen ears on the remises for which the ermit is issued unless the individua is
,
i
15 I employed by or is an immediate family member of the owner, lessor, oPerator, manager,

16 -I romoter or licensee. A teen dance hall rna not serve alcohol nor allow ersons to brin alcohol
17 I onto the premises or into the venue.

I
18 I Sec. 5-198. License required; fee; and insurance.
19 : (a) It is 'unlawful for any person to maintain or operate a dance hall without first 0 taining
: . .
20 i a license from the Department of Environmental Resources. It is unlaWful to operate a p blic

I ' !
21 I dance in any place other than a licensed adult dance hall or teen dance hall. I
22 I [(b) The nonrefundable license fee shall be Two Hundred Dollars; ($200.00) per yet.]
! . i
23 fCc)](Q} The nonrefundable license fee for adult dance halls shall be One Thousan<!l
I - I
24 I Dollars ($1,000.00) per year. The nonrefundable license fee for teen dance halls shall bd One
I I
25 i Thousand Dollars ($1,000.00) per year. The County Council finds that the license fee !
I
26 I established for adult dance halls and teen dance halls in this ordinance is based on the esJimated
27 I cost of implementation, administration, and enforcement of the licensing program. The ldult
, - I
28 dance hall and teen dance hall license shall be applied for armually. i
29 [(d)] if} The Count Police De artrnent shall conduct back roun.d investi ations fall
30 persons seeking to obtain an initial license or renewal license to maint~in

, or operate an Jiult
I
31 dance hall or teen dance hall. An application shall be denied if personS seeking to obtai~ a
I.
3
)
CB-18-201 (DR-3)
1 license have been convicted of a felony, violating any Federal or State laws relating to 0
2 involving moral turpitude, or crimes involving financial misrepresentatIons.

3 i @ No license issued under this Division shall be transferred or assi ned to an
! ..
4 I other than the person and or establishment to whom it was issued. .
5 I W The Director of the Department of Environmental Resources,' before issuing orj
6 i renewing a license, shall require documentation of bodily injury liability insurance, prop rty
7 I damage liability insurance, or the equivalent self-insurance. The applicant shall provide broof of
8 I insurance rior to the issuance of a license. Said bodil in' liabilit ;insurance ro e
9 I dama e liabili insurance or the e uivalent self-insurance shall be cohunensurate with e

i
10 ! mandatory minimum required by law for the establishment.
.1
II ill If durin the eriod for which a license is issued there is an :
12 information furnished by the licensee to the Department of Environmemtal Resources un er
13 Section 5-198 or Section 5-199 of this Division such chan e shall be full
14 communicated b the licensee to the Director of Environmental Resources in wrilin wi .n 30
15 I calendar da s of the chan e the Director of Environmental Res urces

,
16 ! for that purpose,
17 Sec. 5-199. License application.
18 (a) Before any license shall be granted under the provisions of this Division, appli ations
19 shall be made in writing to the Department of Environmental ResourceS on fonns prOVidjd by
20 the Department of Environmental Resources. Copies shall be transmitted by the Depart ent of
21 Environmental Resources to the Police Department and the FirelEMS Department, I

22 (b) Before any application for an initial license or renewal shall be granted for a pr~posed .
23 ! adult dance hall or teen dance hall to be located inside of or within one_half mile of the 1
24 I boundaries of an incorporated municipality, the Director of the De art:ment of Environm ntal
25 I, Resources or their designee shall notify the governing body ofthe municipality of the pe
.
ding
26 i application within fourteen (14) days of receipt of the application. The municipality shal have
27 I forty-five (45) calendar days for review, comment, and to hold a public hearing at the op ion of
28 I the m~icipality, If the proposed adult dance hall or teen dance halllie.s within a municj'. ality
29 I and is also within one-half mile of one or more other municipalities, the public hearing ay only
30 I be held by the municipality within which the proposed adult dance hali or teen dance hal is
31 ilocated, with notice given t<Yanyaffected municipality. If the proposed adult dance hall ~r teen
! ]
4
CB-18-2011 (DR-3)
1 ! dance hall is to be located within an Wlincorporated area, but is within one-half mile of t
2 ! more municipalities, the affected mWlicipalities may hold a joint public hearing at their 0 tion.
i
3 i The municipality(ies) may recommend denial ofthe license after conducting a public he ing,
i '
4 ! upon a finding that the grant of the license would ose a threat to the eace and safet of he
5 ! surrounding area or adversely affect the public health, safety, or welfare. If the mWlicipJity(ies)
6 I recommends denial, such license shall not be granted. The cost of any public hearing he11 by a
7 I municipality shall be borne by the applicant. 1
8 I W Before an a lication for an initial license or renewal shall be 'anted for a r osed
9 I adult dance hall or teen dance hall, the applicant shall not be in violation of any licensing
I .
10 I provision of the Prince George's County Code. 1I
11 @ Before an a lication for an initial license or renewal shall be ranted for a r osed
12 adult dance hall or teen dance hall a securi Ian shall be submitted for review and a r val of
13 ,the Department of Environmental Resources, the Police Department and the FirelEMS
,
14 IDe artment. A securit Ian shall be em 10 ed on the ro e owned ,or in control ofb the
15 licensee owner lessor 0 erator romoter erson in char e or a erson in a arent char e of
16 the establishment and/or the ro e . The Count a roved securit Ian shall be em 1 ed at
17 all times when the premises are used as an adult dance hall or teen dance hall.
18 Security Plan shall mean a document prepared Wlder the direction of the applicant hich
19 I minimally
,
includes but is not limited to:
20 I A Ian for 0 erable and recordable ce
21 I cameras.
22 I (2) A parking plan. I
i
23 (3) A vehicular traffic flow management plan. J

24 (4) A lighting plan for the establishment and premises to include the parking ot(s)
25 and all other omons of the remises within 1 000 feet of an adult danGe hall or teen dan e hall.
26 5 A life safet and evacuation Ian re ared b a certified fire rotection en ineer
27 if the calculated occupant load exceeds two hWldred and fifty persons. i
28 6 A staffin Ian for services rovided which includes securit

29 responsibilities.
30 includes but is not limited to
31 the adult dance hall or a teen dance hall.
5
CB-18-2011 (DR-3)
I ! ill State or Coun certified rivate securi officers wearin uniforms and bearin an
2 lidentification card or sworn off duty police officers shall patrol the premises to include th outer
3 I erimeter of an adult dance hall and teen dance hall coverin areas such' as arkin lots add areas
4 within 1000 feet of the establishment. Public safe officers shall be
5 Iany time during an event to ensure Code compliance.

6 i ill Any party, includin owners lessors 0 erators romoters or ersons in char e for
7
8
9
Ihavin a arent authori of an adult dance hall or teen dance hall u on bein issued a v' lation
shall have the right to request an administrative hearing comprised of the Director of the
Department of Environmental Resources or their designee, the Chief o~the Police Depart
l ent or
10 Itheir desi ee and the Fire/EMS De artment or their desi nee the Administrative Board within
II ! 72 hours of the violation issuance. The De artment of Environmental Resources the Pol ce
I
12 I De artment and the FirelEMS De artment shall be authorized to tern 0raril or
13 ! sus end or revoke a license u on issuance of a violation endin an administrative head

I
14 I an .udicial a eal. An
! .
15 I Administrative Board shall have the ri ht to a eal to the Circuit Court, The enforcemen
16 I shall continue or terminate according to the determination of the Administrative Board.
17 I 19} The De artment of Environmental Services the Police De artment and the Fir
18 I Department shall establish policies, rules, and procedures to implement this ordinance.
19 iNotwithstandin Sections 5-200 b c d e and and 5-200.01 ~hen the De artm nt of
20 I Environmental Resources, the Police Department or the FirelEMS Department determine that a
21 I violation of Section 5-200 or Section 5-200.01 has occurred with res ect to the use of an
22 buildin structure or land or there is a failure to obtain a use and occu anc ermit or
23 use and occu anc ermit has been issued or it is bein used for another
24 ordinance has been violated, the Director of the De artment of Environmental Resources or their
25 i desi
I
nee the Chief of the Police De artment or their desi ee or the Chief of the Fire/E S
26 iDe artment or their desi ee is authorized to sus end or revoke a license. The Director the
27 I De artment of Environmental Resources or their desi ee the Chief of the Police De ent or
28 I their desi ee and the Chief of the Fire/EMS De artment or their desi . ee are authorize to
29 direct the Department of Environmental Resources, the Police Department or the
30 FirelEmer enc Medical Services De artment, res ectivel to issue a written violation otice
31 I directing that the violation cease and that all activities in the building, structure, and on t eland
I . I
. 6 I,
CB-18-2011 (DR-3)
i
1 ! cease endin before the Administrative Board in accordance. with Section 5-2 0 and
i
2 15-200.Dl.
I
3 !
!
au The Director of Environmental Resources or their desi ee the Chief of the Po ice
4 I De artment or their desi nee or the Chief of the Fire/EMS De artment or their desi ee hall
5 I provide the written violation notice, issued pursuant to Section 5-200 and/or
,
6 i 5-200.01 to one or more of the followin : the licensee owner lessor 0 erators romo ers or
7 i ersons in char e of or in a arent char e of an adult dance hall or teen dance hall. In th event
8 I that no erson or no erson re resentin entities set forth in this Section are resent or an
i
9 I erson or an erson re resentin entities set forth in this Section flees when the activit
10 activities take lace and the written violation notice is bein issued the written violation
11 shall be osted on the buildin , structure or on the land in which or u on which the activi or
12 activities took lace directin that the violation cease and that all activities in the buildin
13 1 structure, or on the land cease pending a hearing before the Administrative Board. Posti g of the
14 issued written notice shall be deemed to be constructive notice to the licensee owner les or
15 operators, promoters, or persons in charge of an adult dance hall or teen dance hall.
16 I; ill For violations of Section 5-200 and/or 5-200.01, the licensee, owner, lessor,
.
operators,
i
17 I promoters, or persons in charge or in apparent charge of an adult dance hall or teen dand hall
,
18 I rna re uest an administrative hearin in writin within 72 hours of the violation notice efore
19 Ithe Administrative Board, The Administrative Board shall commence an administrative hearing
. I
20 IIwithin two days following receipt of the request for a hearing, I
'
21 I ill The Administrative Board shall provide a hearing on the record, II
22 i 00 Theenforcement action of the Department of Environmental Resources, the Po ice

23
24
25
I Department
iladmmlstratlve
I
,.
ill
or the Fire/EMS Department shall not be stayed during the pendency of the ~
. hearmg,
.
The Administrative Board shall render a decision on the enforcement action wi
l in two
26 Ida s after the conclusion of the hearin on the record. The decision shall include findin
27 fact whether there is a use and occu anc ermit' whether there was a use and occu
28 that was used for another ose' whether there is a threat to the ublic health safe
29 welfare' and whether the activi constitutes a continuin threat to the .ublic health, safe
30 welfare,
7
\
,
CB-18-2011 (DR-3)
1
. . I
1 (m) The Administrative Board may reverse. modify or remand the decision of the I
2 'De artment of Environmental Resources Police De artment or the Fit~/EMS De artme
3 i respectively. only if the decision of the Department of Environmental Resources. the Poli e
i
4 , Depmtment or the Fire/Emergency Medical Services Department. respectively. is clearly I
5 • erroneous. or arbitrary and capricious. or unsuppOlted by any substantial evidence:

6 . illl The enforcement action of the Department of Environmental Resources, the Po ice
7 ! De artment or the Fire/EMS De artment res ectivel shall terminate or continue accorb to
8 the determination of the Administrative Board. Any party aggrieved by a decision of the
9 Administrative Board rna a eal the decision to the Circuit COUlt for Prince Geor e's
10 Mar land. The a eal shall roceed in accordance with the

II : Rilles of Procedure.
12 . Sec. 5-200. Denial, suspension, revocation.
13 (a) The Director of Environmental Resources in consultation with the Police De ent
14 i and the Fire/EMS Department. as appropriate. shall have the authority to deny, suspend, r
15 , revoke any application or license under the provisions of this Division and upon a violati~n of
16 this Division. . I
j
17 : (b) [No license shall be denied, suspended, or revoked without the] The Director df
18 , Environmental Re~ourc~s or their deSign~e, in cons~ltation with the Chief of th~ poli~e
19 ; De artment or then desl nee and the Chief of the Flre/EMS De artment or then desl n e as
20 ! appropriate, [first notifying] shall notify in writing, the applicant or licensee, and provid ng the
21 reasons for said denial, suspension, or revocation. The written notice shall be served by elivery
22 of said notice to all parties by registered or certified mail.

23 (c) Any party aggrieved by a decision or action of the Director of Environmental
24 Resources with respect to approval, denial, suspension, or revocation of an application 0 license
25 ! shall have the right to appeal any such decision to the Board of Appeals for Prince Geor1e's
26 : County within ten (10) calendar days after the date of such decision. If the license is for or
27 : exists on, premises located inside or within one-half mile of a mu~icipality, the muhicip lity
28 : shall automatically be a party to any related proceeding and administrative hearing and +ve the
29 ! right to appeal therefrom. Additionally, the Board of A eals for Prince Geor e's Coun shall
30 : notify, in writing, all
, , adjacent property owners and any person who has filed a written c mplaint
31 . against the applicant or licensee.
8
,
'
) CB-18-201
I (DR-3)
(d) In addition to the provisions of Section 5-200,01, the Director ofEnvironmenJ

2 Resources in consultation with the Police De artment and Fire/EMS De altment as a 0 riate
3 shall have the authority to deny, suspend, or revoke a license if it is determined that exer ise of
4 the license proximately causes, gives rise, or substantially contributes tp a situation wher in the
5 quiet enjoyment or use of property of persons in the vicinity ofthe [d~ce hall] adult dan e hall
6 : or teen dance hall is unreasonably obstructed or interfered with by arri~ing or departing atrons
7 : of the [dance hall] adult dance hall or teen dance hall so as to constitute a continuing pub ic
8 nuisance or a repeated disturbance to the public peace,

9 ~ Notwithstanding Sections 5-200(b)(c) and Cd).the Department of Environment,
i .
10 i Resources the Police De artment and the Fire/EMS De artment shall have the ri ht to e all
11 immediate and necess action to cease and desist the 0 eration of ani adult dance hall a d a
12 teen dance hall when an activi is found to ose a threat to the eace and health safet d
13 welfare of the ublic. Immediate and necessar action b the De artment of Environme tal
14 Resources the Police De artment the FirelEMS De artment shall include but is not Ii 'ted to:
15
16 occu ants of the buildin structure alld land' and adlockin the buildin structure an land.
17 The Department of Environmental Resources, the Police Department, and the FirelEMS
18 De artment shall be authorized to tern oraril or ermanentl close an establishment u suant to
19 Section 5-200 e endin an administrative hearin b the Administrative Board and an 'udicial
20 appeal.
21 Sec. 5-200.01. Violations.
22 (a) It shall be considered to be a violation of this Division if:
23 (I) Dancing is permitted between the hours of2 A.M. and 11 A.M., or in viola 'on of
24 Section 5- 198.
25 (2) The Prince George's Health Department finds that noise levels emanating from a
26 dance hall are in excess of 50dBA at the property line between the ad11ltdance hall or te n dance
27 hall and adjoining residential zone, or 62dBA at the property line between the dance hall and
28 adjoining commercial zone, using a Type 2 or better sound level meter in accordance wi the
29 i definitions and measurement procedures as prescribed by the Maryland State Environm tal
30 Health Administration Regulation 10.03.45, titled "Rules and Regulations Governing th Control
I!
9
CB-18-201 (DR-3)
I of Noise Pollution in the State of Maryland, " provided that measurements may be condu ted on
2 properties adjoining dance halls as well as at the property line.
3 (3) [An] A licensee. owner. lessor. operator, promoter, [orlperson in charge r
4 person in apparent charge of [a] an adult dance hall or a teen dance hall permits any diso, derly
5 conduct or allows a public nuisance to exist on his property. I
6 (4) A private club holds public dances as evidenced by advertising to attract the
7 general public for an admission fee and the private club is not a nonpr0fit organization i1
8 possession of a valid County benefit performance permit issued under the requirements df
9 Subtitle 5, Division 2, of this Code.
10 ill An A licensee owner lessor 0 erson in char e or a erson
11 in a arent char e of an adult dance hall or a teen dance hall that ermits an activi ro ibited
12 by the security plan.

13 @ An A licensee. owner
14 in a arent char e of an adult dance hall or a teen dance hall that ermits an activi that
15 threat to the health, safety and welfare of the public. . j
16 ill [An] A licensee. owner. lessor, operator, promoter, a person in charge, 0 a
17 person in apparent charge of an adult dance hall or a teen dance hall operates an adult dahce hall
i
18 or teen dance hall without the required license. I
19 Sec. 5-200.02. Compliance with applicable regulation. . I
20 No license shall be issued or renewed for anadillt dance hall or ateen dance hall u1til
21 applicable sanitary, building code, housing code, fire prevention, zoning, business licensIng,
22 security plan and safety regulations of Prince George's County are met. . i
23 Sec. 5-200.03. Additional rules and regulations.
24 The Department of Environmental Resources the Police De artment and the Fire MS
25 Department may hereby establish any additional rules and regulations in order to enforcli the
26 provisions of this Division.
27 Sec. 5-200.04. Enforcement and penalty. I,
28 (a) Any person who is a licensee, and/or owns, leases, operates, is in charge of or t
29 apparent charge of an adult dance hall or teen dance hall, or promotes ~ facility or event teqUired
30 to be licensed under this Division without first having obtained a public dance license shall be
31 i d~", ,oil" of. mi,d"n=" ~d,oponronvi'ti;,,,,,"'b, mbj", " • fm, 00' '" i'~d
10 I
CB-18-201 (DR-3)
1 One Thousand Dollars ($1,000.00) or incarceration up to six (6) months in jail, or both s ch fine
2 . and imprisonment.
3 (b) In lieu ofa violation notice, the Director of the Department of Environmental
4 Resources, his designees, or any sworn County police officer or Fire/EMS officer may is ue a
5 citation pursuant to Subtitle 28, Division 3, to any person who is a licensee. and/or owns, leases,
6 operates, is in charge or in apparent charge or promotes any event or facility in violation f this
7 Division. The citation shall serve as notification to the person that he has committed a ci il
8 violation and must pay to the County a monetary fine, subject to the decision of the I
9 Administrative Board and his right to trial under Section 28-257 of the County Code. I
10 (c) The person issued the civil citation shall be subject to a monetary fine ofFive ~undred
. I
11 Dollars ($500.00) for each violation of this Division. . I
12 (d) Each day a violation continues is deemed a separate offense and is subject to ad I
13 additional citation and fine.
14 ~ A licensee, owner, lessor, operator, promoter, a person in charge, or a pbrson in
15 a arent char e of an adult dance hall or a teen dance hall found to have violated an ovision
of this Act shall be fined u to 1 000.00 or rna be sentenced to not more than six 6 nths of
16
17 . imprisonment, or both such fine and imprisonment.
18 [(e)] ill In addition to the other remedies provided herein, the County Attorney, 0 behalf
19 of the County, may institute an injunction, mandamus, or other appropriate action or pro eeding
20 to enforce the provisions of this Division. .
21 SECTION 2. BE IT ENACTED by the County Council of Prince George's countyl
22 Maryland that Section 5-196.01 of the Prince George's County Code be and the same is 1ereby
23 added:
24 Sec. 5-196.01. Legislative Intent.
25 . ill The ose and intent of this Ie islation is to re ulate dance hall remises 1ic nsee
26 owner, lessor, operator:manager, promoter and patron by establishing license reguiremeJts and
27 enalties for violators b re ealin and reenactin with amendments relevant rovisions f the
28 Count Code to establish reasonable and uniform laws to romote the health safet , and welfare
29 : of the citizens and residents of the Count and to revent or control detrimental effects u on
30 • neighboring properties and existing and proposed land uses in the general area. I
31 Gil The provisions of this law are in response to violent crimes taking place in or iJ close
11
I
CB-18-20l (DR-3)
1 proximity to adult dance halls or teen dance halls throughout the County.
2 .cu The rovisions of the Prince Geor e's Count Code have neither the ur ose dor effect
3 of imposing a limitation or restriction on legal conduct.

4 SECTION 3. BE IT FURTHER ENACTED that the provisions 6fthis Act are her by
5 declared to be severable; and, in the event that any section, subsection; paragraph, subp agraph,
6 sentence, clause, phrase, or word of this Act is declared invalid or unc<:mstitutional by a ouct of
7 competent jurisdiction, such invalidity or unconstitutionality shall not affect the remaini g
8 words, phrases, clauses, sentences, subparagraphs, paragraphs, subsec~ions, or sections this
9 Act, since the same would have been enacted without the incorporation in this Act of an such
10 invalid or unconstitutional word, p1u'ase, clause, sentence, subparagraph, subsection, or ~ction.

11 SECTION 4. BE IT FURTHER ENACTED that in accordance with the provisions of
12 Section 317 of the Charter, the County Council hereby declares that a public emergency xists
13 affecting the public health, safety, and welfare; said emergency being the provisions oft is law
14 are in response to violent crimes and the increase in violent crimes, including but not li ited to
15 assaults and homicides, taking place in or in close proximity to adult dance halls and tee dance
16 halls throughout the County; the purpose and intent of this legislation is to regulate danc hall
17 premises, licensees, owners, lessors, operators, managers, promoters and patrons by esta lishing
18 license requirements and penalties for violators by repealing and reenapting with amend I ents
19 relevant provisions of the County Code to establish reasonable and uni.form laws to pron}ote the
20 'health, safety, and welfare of the citizens and residents of the County and to prevent or c.rntrol
21 detrimental effycts upon neighboring properties and existing and proposed land uses in e
22 general area.
23 SECTION 5. BE IT FURTHER ENACTED that this Act shall taike effect on the d te it
24 becomes law.
25
12
Case 8:14-cv-01592-DKC Document 1-1 Filed 05/15/14 Page 13 .of 13 ,
,
,
)
CB-18-20111 (DR-3)
I Adopted this ~ day of July ,2011, by an affinnative vote of two-thirds of

I
2 the members ofthe full County Council.
COUNTY COUNCIL OF PRINCE
GEORGE'S COUNTY, MARYLAND
BY: ~oo&AL;;;:1~QA-
Ingrid Mlf\;rner '
Chair
ATTEST:
J~,;~Y:~r
Clerk of the Council
APPROVED:
DATE: 7/0;//0;0// BY:~~

17 Rus ern L. Baker, III
County Executive
KEY:
Underscoring indicates language added to existing law.
[Brackets] indicate language deleted from existing law.
Asterisks *** indicate intervening existing Code provisions that remain unchanged.
13
) )
Prince George's County Council

Agenda Item Summary
Meeting Date: 7/1912011

Refe,'ence No.: CB-O 18.20 II
Draft No.: 3
Proposer(s): Toles
Sponsor(s): Toles, Franklin, Patterson, Turner, Johnson, Lehman, Campos, Olson
Item Title: An Emergency Act of amending County regulations concerning dance hall premi es, owners,
lessors, operators, managers, promoters and patrons, establishjng license require ents, setting
penalties for violators, declaring specific legislative intent to establish reasonable and unifonn
laws to reduce the number of violent crimes that occur as a result of events at da ce halls and
to promote the health, safety, and welfare of the citizens and residents of Prince eorge' s
County and declaring that a public emergency exists affecting: the public health, ~afety, and
welfare. I
Drafter: Kathleen H. Canning, Legislative Officer

Resource Personnel: Dwayne B. Mingo,District 7
LEGISLATIVE HISTORY:
Date Presented: 5/17/2011 Executive Action: ,7/:P/2011 S
Committee Referral: 5/1712011 - PSFM Effective Date: 7/21/2011
Committee Action: 6/15/2011 - FAV(A)
Date Introduced: 6/21/2011

Public Hearing: 7/1912011 - 10:00 AM
Council Action (1) 7/19/2011 - ENACTED

Council Votes: WC:-, MRF:A, AH:-, LJ:A, ML:A, EO:A, OP:A, IT:A, KT:A
Pass/Fail: P
Remarks:
AFFECTED CODE SECTIONS:

05-196.01,05-197,05-198,05-199,05-200, 05-200.01, 05-200.02, 05-200.04
COMMITTEE REPORTS:
Public Safety and Fiscal Management D te 6/15/2011
I
I
!
Page 2 (
CB-1Jlil-~011(Draft 3)
REPORT: Committee Vote: Favorable as Amended: 4-0, (In favor: Council Members Campos, Franklin, Patterson,
and Toles)
This bill broadens the scope of adult dance halls and teen dance halls violation and increases the penaltie while
making a clear destination between the licensing and operation of both dance halls. Adult dance halls ar~open for
individuals 21 years of age and older and permit alcohol to be served. Teen dance halls are open for indi iduals
between ages 18-21 and no alcohol is petmitted. It also requires background investigations, provide for t e issuance
of written violation notices, expedited administrative hearings and detennination within three to seven da s after the
written notice is issued. Also, this legislation will give the County the authority to take immediate and n cessary
action including but not limited to entering the establishment, securing, and removing the occupants andjadlocking
the building or stlUcture where the activity is found to pose a threat to the health, safety, and welfare of ie public.
During the PSFM Committee worksession the legislation was amended by adding the following ProViSiOlls:
1. On page 3, lines 17-19, increase the licensing applications fee from $300 to $1,000 per year.
2. On page 3, lines 29-30, provides that an adult dance hall license or a teen dance hall license cannot be ansferred
or assigned. .
3. On page 4, lines 1-6, requires the licensee to provide bodily il\iury liability insurance, property damage liability
insurance, or the equivalent self-insurance. .
4. On page 5, lines 12-13, security surveillance cameras are required as part of the security plan.
5. On page 10, lines 27-30, provides for criminal penalties of fines up to $1,000 or up to six months impr sonment or
both.
The Acting Chief of Police Mark Magaw and Assistant State's Attomey C. T. Wilson expressed their su port for this
legislation. They stated that this bill will ensure the safety of County residents without discouraging busi esses from
operating in the County and will greatly enhance the ability of the police to protect the citizens from viol nt crimes.
According to data received by the Office of Audits and Investigations from the Department of Environm ntal
Resources there are currently five premises licensed and 79 licenses that expired over:the past years. Th re could be
additional cost incurred for background checks on 'applicants, reviews of the security plans, inspections a d
enforcement of the regulation. These additional costs cannot be detennined at this time.
The enactment ofCB-I8-2011 should have a positive fiscal impact on the County, however; if the additi1nal cost
occurs it would reduce the revenues.
I
BACKGROUND INFORMA nON/FISCAL IMPACT:
(Includes reason for proposal, as well as any unique statutory requirements)
The purpose and intent of this legislation is to establish reasonable and unifonn laws to regulate adult da ce halls and
teen dance halls and to reduce the number of violent crimes that occur as a result of events occurring at a ult dance
halls and teen dance halls or in close proximity to adult dance halls or teen dance halls throughout the C~ nty. The
. purpose and intent of this legislation is also to promote the health, safety, and welfare of the citizens and 'esidents of
the County and to prevent or control detrimental effects upon neighboring properties and existing and pr posed land
uses in the general area. The provisions of the Prince George's County Code have neither the purpose ngr effect of
imposing a limitation or restriction on legal conduct. I
i
6/21/2011: CB-18-20Il (DR-2) was amended on the floor prior to introduction; (DR-3) was introduced. I ' _
CODE INDEX TOPICS: !

_________________________ I:! _
INCLUSION FILES:
JS 44 (Rev. 12/12)
CIVIL COVER SHEET
The JS 44 civil cover sheet and the infonnation contained herein neither replace nor supplement the filing and service ofpleading;s or other papers as required by law except as
provided by local rules of court. This foml, approved by the Judicial Conferen.ce of the United States in September 1974, is reqUired for the use of the Clerk of Court for the
purpose 9f initiating the civil docket sheet. (SEE INSI'RUCTIONS ON NEXT PAGE OF THIS FORM) .
I. (a) PLAINTIFFS, 'L { "

M~ 'l5tfE W-+. I7UY1?PV7 f.1I1L
(b) County of Residence of First Listed Plaintiff
(EXCEPT IN u.s. PLAINTIFF CASES)
County of Residence of First LiSted Defendant rp~
~/
f\
(IN u.s.
PLAINT!FFCASESONLY8~ ~. 0 .
NO'IE: IN LAND CONDEMNATION CASES, USE THE L
THE TRACT OF LAND INVOLVED,' ~
ION o~/' -~0 /':;.
;.;c<>"
(c) Attorneys (Firm Name, Addros,\', and Te!ephone NUrT/bel') Attorneys (lfKnown) <9).. /, ~ /.
'''""("', <0.'10'/
/J> /' ..,/
, ~'<':"<\
--;.. c.r '-",~
);c"'O
\ <::>', . 'r', C/
,,:., ~ ?-?
'/' --;."T --;o/A
IT. BASIS OF JURISDICTION (place an "X" In One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES.(Pla~;;C:,<'::)fO,"" '~' "Platn/it
(For DiversllY Cases Only) \
and On~Qx,fi}r Defe I
01 U.S. Government ~'QUestiOll PTF DEF 0.....
('L',' PTF DEF
P!ainliff (U,s. GOl'crnmeni Nol a ParfJ1 Citizen ofThis State 0 1 0 I Incorporated or
Princip~Jace 0 4 0 4
of Business In This Staf:?
02 U.S. Govcmment o J.
Defendant
4 Diversity Citizen of Anotller State o 2 0 ,2 hlCOlJlOratedand Principal Place o 5 . 0 5
(Indicole Cilizenship OfParlles In Item llJ) ofBusinC"ssIn Anoth~r State
Citizen or Subject Ofa o o 3 Foreign Nation o 6 0.6

Forti Conn
IV NATURE OF SUIT (ploce an 'X" in One Box'Only)
:f0!\':*,~~'ro:.e
. /$JffiW(W ImlFJPoE~ @IDf.E!IR'S~,@a'~
o 1 10 Insurance PERSONAL INJURY PERSONAL INJURY o 625 Dreg Related Seizure o 421 Appeal 28 USC 158 o 375 False.claims Act
o 120Mllfine o310 Airplane o 365 Personal Injury .• of Property 21 USC 881 o 423 Withdrawal . o 400 State Reapportionment
o J30MilierAct o315 Airpllllle Prod\lCt Product Liability 0690 Other 28 USC 157 o 410 Antitrust
o 140 Negotiable Instrument Liabili\)' o 367 Health Carel o 430 Banks and BBnking
O. 150 R~covel)' of Overpayment o320 Assault, Lib~ & Pllamlaccutica! 19» R.ffi<YImi Jif1.R$ o 450 Commerce
& EliforcerncntofJudgment Slander o
0 o
Personal InjulY 820 CopyrigHts o 460 Deportation
151 Medicare Act 330 Federal EmpI-oyers' Product LiabiliW o 830 Patent o 470 Racketeer Influenced and
-
0 152 Recovery of Defaulted Liability o 368 Asbestos Personal o 840 Trademark COlTupt Organizations
Student Loans o340 Marine Injwy Product o 480 Consumer Credit
(E--.::cludesVeterans) o345 Marine Product Liability MJO'R -.snr o 490 Cable/Sat TV
0 153 RecoveJ)' of Overpayment Liability .PERSONAL PROPERTY 0710 Fair Labor"Standards o 861 RIA (1395ff) o 850 Securities/Commodities!
ofVeteral)'S Benefits o 350 Motor Vellicle o 370 Other Fraud Act o 862 Black Lung (923) . Exchange
o 160 Stockholders' Suits 0355 Motor'Vehicle 0371 TlUthinLending o 720 Lahorflv:{allagement d 863 rirwClDlww (405'{g)) tI 890 Other StatutO!)' Actions
o 190 Other Contract Product Liability o 380 Other Personal Relations o 864 ssmTitleXVI 0 891 Agricultural Acts
o 195 Contract Product Lillbility o 360 Other Personal PropClty Damage o 740 Railway LaBor Act d 865. RSI (405(g)) 0 893 Enviromnental Matters
o 196Franchise Injury o 385 PropClty :pamage o 751 Family tllld Medical 0 895 Fl'cedom oflnfomlatioll
o 362 Personal Injuty. Product Liability Leave Act Act
Medical Maloractice o 790 Other Labor Litigation 0 896 Arbitration
&<@.j~::l1iE~'l£p-R'01~ lr. Ii! ' l~' llS0:~ l»1!IITllu)"N's"¥ 0791 EmployeeRetirement DltR1A~tm:m~ 0 899 Administrative Procedure
o 210LandCondemnatioll ~O Other Civil Rights Hnbe.as Corpus: Income Security Act o 870 Taxes (U.S. Plaintiff ActJReview or':ll.ppeal of
o 220 Foreclosure 0441 Voting . o 463 AliC!lDetainee or Defendant) Agency Decision
o 230 Rent Lease & Ejectment o 442 Employment o 510 Motions to Vacate o &71IRS-Tllird Party 0 950 Constitutionality of
o 240TOltstoLand o 443 Housiug! Sentence .26 USC 7609 State Statutes
o 245 Tort Product Liability Accommodations o 530 Geueral
o 290 All Other Real Properly o ~45 Amer. wfDisabilities- o 535 Death Pena!,ty _WWGll'>'lr"@_
Employment Othen o 462 Naturalization.Applicati.on
o 446 Amer, wfDisabilities- o 540 Mandamus & Other o 465 .Other Immigration
Oth~ o 550 Civil Rights Actions
o 44B'Education o 555 Prison Condition
o 560 Civil Detainee.
Conditions of
,
Confinement
V. ORIGIN (Plar:eon "X"inOneBoxOnly)

~ Original 0 2 Removed from o 3 Remanded from a.4 Reinstated or a 5 Transferred from a 6 Mtlltidistrict
Proceeding State Court Appellate Court Reopened Another District Litigation
(tipecify) .
Cite the U.S. Civil Statute under which you are filing (Do nllt cite jurisdidiollil/ stdtute.f Imle.fS diversi1.y):
VI. CAUSE OF ACTION ~B;:r"je'r d"'e"sc"r"jp::(j:Coo:CoC:;r"c:Cau:Cs"e:-, ----..:..--~-----------~--------------
VII. REQUESTED IN o CHECKIF TIllS IS A CLASS ACTION DEMANDS CHECK YES only if demanded in complaint:
COMPLAINT: UNDER RULE 23, F.R.Cv.P. . .nJRYDEMAND: 0 Yes 0 No
VlII. RELATED CASE(S)
(See instnlclions):
IF ANY DOCKET NUMBER
. RECEIPT # AMOUNT APPL YJNG IFP JUDGE MAG.nJDGE

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF MARYLAND
LAFAYETTE WILLIAMSON, et al. )

)
Plaintiff, )
)
vs. ) Case No.: 14-cv-01592-DKC
)
PRINCE GEORGE’S COUNTY, MARYLAND )
)
Defendants. )
___________________________________________
MOTION TO DISMISS
Defendant Karen Toles, by and through her undersigned counsel and pursuant to
Fed. R. Civ. P. 12(b)(5) and Local Rule 105, respectfully moves to dismiss Plaintiffs’ Complaint
for insufficiency of service. In support thereof, Toles offers the following:
1. On May 15, 2014, Plaintiffs, pro se, filed a class action lawsuit against Prince George’s
County Council member Karen Toles, other County officials and the County alleging constitutional
violations related to Prince George’s County’s regulation of dance halls. See ECF No. 1. Simultaneously,
Plaintiffs filed a Petition for Stay of Execution and Temporary Restraining Order as well as a Motion for
Injunctive Relief related to the dance hall regulation. See ECF No. 2.
2. On May 16, 2014, Plaintiffs sent the above pleadings and motions via certified mail to
Toles in care of Mary Budd. See Exhibit 1, Copy of Plaintiffs’ Mailing Envelope.
3. This Court should dismiss Plaintiffs’ petitions and additional filings for insufficient
service of process. Fed. R. Civ. P. 12(b)(5).
4. To be effective, Plaintiffs must serve the Complaint with a summons. See Fed. R.
Civ. P. 4(c). In the instant matter, the Clerk of Court has not yet issued a summons because the
Court has not issued an order authorizing issuance. See Fed. R. Civ. P. 4(b) and Standing Order
2012-04. Thus, Plaintiffs’ mailing of their Complaint without the summons was improper and
premature. Given Plaintiffs’ improper service upon Toles, Plaintiffs’ Complaint should be
dismissed against Toles.
5. Notwithstanding Plaintiffs’ ineffective service, Plaintiffs’ service upon Mary
Budd does not constitute proper service upon Toles. See, Fed. R. Civ. P. 4(e) and Md. Rule 2-
124. According to the federal and state rules governing service, Plaintiffs were required, to
either serve Toles personally or deliver a copy to an agent authorized by appointment or by law
to receive process. Id. In this instance, Budd was not authorized by appointment or law to
receive process. As such, Plaintiffs’ service is not effective.
6. In the event Plaintiffs effectuate proper service according to the rules, Toles reserves
the right to raise additional defenses.
Respectfully submitted,
M. ANDREE GREEN
COUNTY ATTORNEY
WILLIAM A. SNODDY
DEPUTY COUNTY ATTORNEY
__/s___________________________
Stephanie D. Kinder, Fed Bar No. 26303
Associate County Attorney
Prince George’s County Government
Office of Law – Room 5121
14741 Governor Oden Bowie Drive
Upper Marlboro, Maryland 20772
(301) 952-5239 voice
(301) 952-3071 facsimile
Attorney for Defendant Karen Toles
CERTIFICATE OF SERVICE
I hereby certify that on the 2ND day of June, 2014, a copy of the foregoing Motion to
Dismiss was served via US Mail, first class postage prepaid, upon the following:
Lafayett Williamson Brian Logan
Lou Smalls James Rorie
Dan Richardson
_/s_______________________
Stephanie D. Kinder
IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF MARYLAND
LAFAYETTE WILLIAMSON, et al. )

)
Plaintiff, )
)
vs. ) Case No.: 14-cv-01592-DKC
)
PRINCE GEORGE’S COUNTY, MARYLAND )
)
Defendants. )
___________________________________________
ORDER
UPON CONSIDERATION of Karen Toles’ Motion to Dismiss, and any opposition thereto, it is
this _____ day of __________________, 2014, by the United States District Court for the District of
Maryland
ORDERED that the motion be and the same hereby is GRANTED.
_____________________
Judge

Go-Go in Prince George&#39;s County

Încărcat de

Informații document

Drepturi de autor

Formate disponibile

Partajați acest document

Partajați sau inserați document

Opțiuni de partajare

Vi se pare util acest document?

Este necorespunzător acest conținut?

Drepturi de autor:

Formate disponibile

Go-Go in Prince George&#39;s County

Încărcat de

Drepturi de autor:

Formate disponibile

Case 8:14-cv-01592-DKC Document 1 Filed 05/15/14 Page 1 of 14

20\~ MAY IS AM 10: 21

FORTHE DISTRICTOF MARYLAND

PETITION FORSUIT IN EQUITY

CLASS PETITIONERS; (and others similarly situated) SUIT IN EQITY;PETITIONERS

JAMES RORIE CIVIL ACTION NO. 1> t: c, II-I-/$I;J..

PRINCE GEORGES COUNTY OF MARYLAND, et al;

RUSH ERN BAKER, EXECUTIVE OFFICE

NOTE; THE BELOW LISTED PERSONS, ARE MEMBERS OF

THE LEGISLATIVE COUNCIL, WHOM, TO THE KNOWLEDGE

OF THE ABOVE LISTED CLASS MEMBERS, ARE THOSE PERSONS

KNOWN TO AIDE, ABET, ASSIST AND CONSPIRED WITH OTHERS

KNOWN AND UNKNOWN TO SAID CLASS MEMBERS, TO PREPARE

AND INSTITUTE WITHOUT THE FULL KNOWLEDGE AND SUPPORT

OF MEMBERS OF THE TARGETED CLASS GROUP OF PEOPLE, NAMELY

THE BLACK RACE AND CULTURE OF THE STATE OF MARYLAND, SEEKING

UNCONSTITUTIONALLY, TO DEPRIVE AND TO ERADICATE AND DEMOLISH

ARE LISTED AS FOLLOWS, LED BY ONE; KAREN TOLES.

EXECUTIVE LEGISLATIVE COUNCIL OF DISTRICT 7

COUNCIL MEMBER FRANKLIN

COUNCIL MENBER PATIERSON

COUNCIL MEMBER TURNER

COUNCIL MEMBER JOHNSON

COUNIL MEMBER LEHMAN

COUNCIL MEMBE~ LAMPOS

COUNCIL MEMBER OLSON

LEGISLATION BILL NO. CB-18-2011

BRIAN l O'G A l\.J

ARBITRARY ACTIONS OF THE INTRODUCTIONS AND EXECUTIONS OF BILL-CB-18-2011, THROUGH THE

ME THE FREEDOMS OF EXERCISE, FREEDOMS OF SPEECH, FREEDOMS OF LIBERTY IN MU CHOOSING TO

STRESS, PENALTIES, AND ANGUISH BECAUSE OF THESE ILLEGAL PRACTICES.

PRINCE GEORGES COUNTY , DISTRICT 7 et aL;

STATEMENT OF PETITIONERS CASE, AND OTHERS SIMILARILY SITUATED

DEMEAN A PARTICULAR PERSON, OR PERSONS, SUCH AS THESE INDIVIDUAL PETITIONERS. HEREIN.

PETITIONER'S CLOSING STATEMENT

TEN MILLION DOLLAR SUIT IN EQUITY

OTHERS SIMILARILY SITUATED

BEING SO CERTIFIED AS A TRUE BILL, ON THIS DAy OF May, 2014.

CLASS PETITIONERS; ( and others similarly situated)

LAFAYETIE WILLIAMSON JAMES RORIE

Bill No. CB-18-2011

Proposed and Presented by Council Member Toles I

7 have the meanings respectively ascribed to them in this Section:

20 i Director's designee, unless otherwise specified.

nor generally open to the public.

13 romoter or licensee of a teen dance hall ma not allow an individual who is

15 I employed by or is an immediate family member of the owner, lessor, oPerator, manager,

17 I onto the premises or into the venue.

20 i a license from the Department of Environmental Resources. It is unlaWful to operate a p blic

30 persons seeking to obtain an initial license or renewal license to maint~in

2 involving moral turpitude, or crimes involving financial misrepresentatIons.

9 I dama e liabili insurance or the e uivalent self-insurance shall be cohunensurate with e

15 I calendar da s of the chan e the Director of Environmental Res urces

19 shall be made in writing to the Department of Environmental ResourceS on fonns prOVidjd by

21 Environmental Resources to the Police Department and the FirelEMS Department, I

23 (3) A vehicular traffic flow management plan. J

28 6 A staffin Ian for services rovided which includes securit

4 within 1000 feet of the establishment. Public safe officers shall be

5 Iany time during an event to ensure Code compliance.

13 ! sus end or revoke a license u on issuance of a violation endin an administrative head

29 direct the Department of Environmental Resources, the Police Department or the

22 i 00 Theenforcement action of the Department of Environmental Resources, the Po ice

5 • erroneous. or arbitrary and capricious. or unsuppOlted by any substantial evidence:

10 Mar land. The a eal shall roceed in accordance with the

Go-Go in Prince George's County

Go-Go in Prince George's County