UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF NEW … · 2020-06-22 · NORTHERN DISTRICT OF...

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UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF NEW YORK

AMERICAN PATRIOT EXPRESS, FLORENCE SHERMAN, DAVE VANSCOY, and E.S. a minor, by and through E.S.’s next friend Florence Sherman,

Plaintiffs,

vs. Civil Action No.: 1:20-cv-672 (LEK/CFH) Verified Complaint

THE CITY OF GLENS FALLS, NEW YORK, DANIEL HALL in his official capacity as Mayor of Glens Falls, ANTHONY LYDON in his official capacity as Police Chief of Glens Falls, and ROBERT CURTIS in his Official capacity as the Clerk of the City of Glens Falls,

Defendants.

VERIFIED COMPLAINT

FOR A VERIFIED COMPLAINT, THE PLAINTIFFS ALLEGE:

Introduction

1. The members of the American Patriot Express simply want to exercise their First

Amendment right to peacefully associate, assemble, and speak in the City of Glens

Falls (“the City” or “glens Falls”)—however, the City, through the enactment of City

Code § 87, has unconstitutionally abridged these rights.

2. Exhibit A attached to this Complaint is a true and accurate copy of City Code § 87.

3. City Code § 87 requires people to petition the City Clerk for a permit for “any public

assembly, parade or other event involving more than 25 individuals.”

Case 1:20-cv-00672-LEK-CFH Document 1 Filed 06/16/20 of 22

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4. City Code § 87 gives the City Clerk up to twenty-eight days to issue the necessary

permit.

5. City Code § 87’s permitting requirement applies to every square inch of public space

in the City, every minute of every day, and to every gathering of twenty-five people

for any “event.” 1

6. Those who gather without a permit are subject to a fine.

7. City Code § 87 violates the First Amendment on a number of grounds—it is

unconstitutionally vague, it is unconstitutionally overbroad, it unconstitutionally

censors speech based upon its content, and it unconstitutionally grants the City

Clerk limitless discretion through the permitting process.

8. Plaintiffs asked the City not to pass § 87.

9. The New York Civil Liberty Union advised defendants that it would not support §

87.

10. Nevertheless, the City passed Code § 87 and filed it with the New York Secretary

of State.

11. Now, the American Patriot Express is faced with a dilemma—exercise its First

Amendment rights and risk the penalty for violating an unconstitutional statute or

engage in self-censorship. Presented with this unenviable chhoice, the American

Patriot Express, together with the individual plaintiffs in the caption above, seek

relief from this Court. Plaintiffs ask the Court to enjoin the enforcement of Glens

Falls City Code § 87 and to declare Glens Falls City Code § 87 unconstitutional.

1 Public space is defined as “Any place to which the public has unrestricted access, but ‘public place’ shall not mean the interior floor space or any building or any space covered by part of a building’s permanent roof.” City Code § 87-2 (c).


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Jurisdiction & Venue

12. Plaintiffs bring a civil rights action pursuant to 42 U.S.C. § 1983 and § 1988 for

deprivations of plaintiffs’ rights guaranteed by the First, Second, and Fourteenth

Amendments to the United States Constitution.

13. Jurisdiction is conferred on this Court by 28 U.S.C. §§ 1343(a)(3), 1343(a)(4) and by

42 U.S.C. § 1988, which provides for original jurisdiction in the Court of all suits

brought pursuant to 42 U.S.C. § 1983.

14. Jurisdiction is conferred on this Court by 28 U.S.C. § 1331 because the cause of

action arises under the Constitution and laws of the United States.

15. Venue properly lies in the Northern District of New York pursuant to 28 U.S.C.

§ 1391(b)(1&2) because a substantial part of events giving rise to these claims

occurred in this judicial district.

PARTIES

16. The American Patriot Express (“American Patriots”) is an unincorporated association

founded and run by plaintiffs Florence Sherman and Dave Vanscoy and its principal

place of business is located in Washington County, New York.

17. Dave Vanscoy is the President of the American Patriot Express; he resides in

Saratoga County, New York and has previously assembled in the City of Glens Falls

with the American Patriots in groups larger than twenty-five people to engage in

political speech on the sidewalks and other public spaces of Glens Falls.

18. Mr. Vanscoy has not assembled to engage in political speech since Glens Falls

adopted City Code § 87 because he fears that the City will enforce City Code § 87 in

a discriminatory manner.


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19. He has censored his own speech and that of the American Patriots because of City

Code § 87.

20. Florence “Fe” Sherman resides in Warren County, New York and has previously

assembled in the City of Glens Falls with the American Patriots in groups larger than

twenty-five people to engage in political speech on the sidewalks and other public

spaces of Glens Falls.

21. Ms. Sherman has not assembled to engage in political speech since Glens Falls

adopted City Code § 87 because she fears that the City will enforce City Code § 87

in a discriminatory manner.

22. Ms. Sherman has censored her own speech and that of the American Patriots because

of Code § 87.

23. E.S. is a minor and resides in Warren County, New York. E.S. has not assembled

to engage in political speech since Glens Falls adopted Code § 87 because she fears

that the City will enforce City Code § 87 in a discriminatory manner and because

City Code § 87 prohibits minors (people under the age of 18) from receiving a

demonstration permit from the City.

24. Defendant City of Glens Falls is a political subdivision of the State of New York.

25. Defendant Daniel Hall is the Mayor of Glens Falls and is being sued in his official

capacity so that he will be subject to the injunctive relief that plaintiffs have requested

herein.

26. Defendant Anthony Lydon is the Police Chief of Glens Falls and is being sued in his

official capacity so that he will be subject to the injunctive relief that plaintiffs have

requested herein.


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27. Defendant Robert Curtis is the City Clerk of Glens Falls and is being sued in his

official capacity so that he will be subject to the injunctive relief that plaintiffs have

requested herein.

FACTS

AMERICAN PATRIOT EXPRESS FORMED

28. In Glens Falls, for years, political left leaning groups and individuals demonstrated

and protested without opposition.

29. In June 2019, Ms. Sherman and Mr. Vanscoy formed the American Patriots to offer

a counter viewpoint.

30. Upon its creation, the American Patriots adopted the following mission statement:

American Patriots Express was founded in Glens Falls, NY, in June of 2019, by a small group of patriots who are tired of being bullied into silence by the progressive left. Its mission is to organize peaceful demonstrations for like-minded individuals who support America First policies, championed by President Donald J. Trump, and those who wish to see our Constitutional rights preserved from government overreach. Through organizing these demonstrations, American Patriots Express seeks to encourage others to exercise their First Amendment rights by setting aside the fear to stand and be vocal about their convictions. American Patriots Express does not condone violence, or any form of hate at group events. American Patriots Express does not discriminate against race, sex, religion, sexual preference or political affiliation.

31. The American Patriots has no formal structure.

32. When the American Patriots planned a political rally in the City of Glens Falls to

exercise political speech, they communicated through social media and by word of

mouth.


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33. Some people would indicate that they planned to attend the rally; but not all of the

people who said they were coming to the rally would show-up.

34. Many people would just come at the rally without having previously indicating

they would attend.

35. Consequently, when the American Patriots have a political rally in Glens Falls,

Ms. Sherman has no idea whether a few people or a few dozen people will

assemble and participate.

36. In addition to holding rallies, the American Patriots have engaged in counter

protest.

37. Counter protesting is one of the main objectives of the American Patriots.

38. The impetus for counter protests stems from protest held by the opponents of

Congresswoman Elise Stefanik and/or President Donald Trump outside of or near

Congresswoman Stefanik’s office in Glens Falls.

39. The American Patriots believed these protesters against the President and the

Congresswoman were communicating to the public with lies, disinformation, and

dishonest slogans.

40. When the American Patriots learned of leftist demonstrations, they would, via

social media, rally individuals to form a counter demonstration.

41. When the American Patriots would become aware that opponents of

Congresswoman Stefanik or President Trump intended to demonstrate in the City

of Glens Falls, Ms. Sherman would use Facebook to organize a counter protest.

42. These counter protests were done on short notice (a day or so).


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43. These short-notice counter demonstrations are important to the American Patriots

because they believe it is the best way to let the people of Glens Falls know that

the leftist demonstrators were not fully representative of the community and that,

in fact, many people support President Trump and Congresswoman Stefanik.

44. As with other political rallies the American Patriots planned, the counter protests

were organized via Facebook and word of mouth.

45. In addition to those who would learn of the counter demonstrations by Facebook or

word of mouth, passers-by often stopped and joined.

46. For example, on at least one occasion, a 78-year-old veteran passed by and stood

with the American Patriots to express his support of the President and opposition

to the leftist group.

47. This was not unusual, and plaintiffs estimate that, on average, three to five people

passing by the counter protest would respond to the American Patriots’ message

and join them then and there.

48. The counter protest size would vary depending on the time of day and the day of

the week.

49. Consequently, plaintiffs would have no idea how many people would participate in

a counter protest.

The Origins of Code Section 87

50. This turn of events where other people expressed a different viewpoint from the

leftist orthodoxy at leftist demonstrations was intolerable to the leftist.


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51. So, the political left leaning groups and individuals began to lobby (as was their

right) the Glens Falls City Mayor and City Council to pass a law that would

hamper opposition to their political message.

52. The City obliged.

53. The City adopted a law whereby the City Clerk would have to permit “any public

assembly, parade or other event involving more than 25 individuals.” City Code §

87.

54. City Code § 87 applies to every square inch of the City’s “public space”, every

minute of every day, and to every gathering of 25 people for “any public assembly,

parade or other event involving more than 25 individuals.”

55. Under City Code § 87, the City Clerk may delay the granting of a permit for up to

twenty-eight (28) days for any reason or no reason at all. City Code § 87-4 (A).2

56. This unbridled discretion allows the Clerk to effectively silence spontaneous or

impromptu demonstrations and counter protests by simply waiting to grant a

permit until the moment has passed.

Code Section 87 Chills Plaintiffs’ Speech

57. As previously alleged, Plaintiffs have not assembled to engage in political speech

since Glens Falls adopted City Code § 87 because they fear that the City will enforce

City Code § 87 in a discriminatory manner.

58. Since § 87 was enacted, plaintiffs have desired to peacefully exercise their rights

of speech, assembly and association, but have not because they fear the imposition

2 City Code § 87-4 (A), in relevant part, provides “in all cases decisions whether to grant or deny the application will be delivered within 14 days of application, unless, upon written notice to the applicant, a further 14-day extension is necessary.”


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of sanctions under § 87, because they fear that will have a permit effectively

denied by delay, and because they fear that they will be outright denied a permit.

59. If any of these well-founded fears materialized, it would bring the American

Patriots in disrepute and cause support from the community to wane.

60. The mere enactment of § 87 already has had that effect.

61. Many members and supporters of the American Patriots have told Ms. Sherman

that they are afraid of being fined if they attend a rally or counter protest organized

by Ms. Sherman and the American Patriots.

62. Section § 87 has depressed and inhibited the association between friends and

supports of the American Patriots and plaintiffs.

63. Section § 87 has chilled plaintiffs right to free speech and assembly.

64. Plaintiffs have engaged in self-censorship.

65. A recent example is illustrative of this point.

66. On or about June 3, 2020, Ms. Sherman learned that someone (Marissa Ray, as she

learned later) was organizing a Black Lives Matter (“BLM”) protest in the City of

Glens Falls on June 5, 2020.

67. Ms. Ray had informed the City that she expected about five hundred (500) people

to protest.

68. Plaintiffs would have organized a counter protest but feared that the City would

either delay or deny their application for a permit, thus subjecting them and their

fellow counter protesters to fines.

69. But for City Code § 87, plaintiffs would have organized and conducted a counter

protest on June 5, 2020.


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70. In fact, Ms. Sherman had prepared signs specific to the counter demonstration—

“BLM Protesters: Can we agree that All Lives Matter.”

71. The City Clerk never issued a permit to Ms. Ray nor anyone else on behalf of the

BLM protest.

72. The Ms. Ray’s BLM protest was held anyways and more than twenty-five (25)

people attended.

73. The BLM protesters had flags and signs supported by poles; these support poles

violated the material and size limitations contained in City code § 87.

74. Upon information and belief, the City cite any person at the BLM protest for

violating City Code § 87.

75. Code § 87 requires those who hold a demonstration to be responsible for the

cleanup cost.

76. When the BLM protest ended, the protesters left behind debris that required

taxpayer funds and resources to clean up.

77. Upon information and belief, the City has not and will not impose such costs upon

the organizers of the BLM protest.

78. Now, having lost the opportunity to counter protest, plaintiffs would like to hold a

rally in support of the police.

79. This rally would include advocacy to elect men and women who support the

police.

80. This rally would specifically include plaintiffs holding signs in support of

President Trump’s and Congresswoman Stefanik’s re-election.


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81. Plaintiffs believe that more than twenty-five (25) people will be present at the

rally.

82. The rally is time sensitive because plaintiffs want to send an important message to

police at a time when they and their reputation is under attack.

83. Plaintiffs fear that the City would either delay or deny their permit, thus subjecting

them and their fellow police supporters to fines.

84. Instead of subjecting themselves to an unconstitutional permit scheme, they seek

the help of this Court.

85. Plaintiffs ask the Court to grant them a temporary restraining order so that they can

march as soon as possible.

86. Plaintiffs also seek from the Court a preliminary injunction.

FIRST CAUSE OF ACTION

87. Plaintiffs repeat and reallege all the preceding paragraphs of this complaint as if fully

set forth herein.

88. Glens Falls Code § 87 violates plaintiffs’ First Amendment rights of free speech and

free association.

SECOND CAUSE OF ACTION

89. Plaintiffs repeat and reallege all the preceding paragraphs of this complaint as if fully

set forth herein.

90. Plaintiff E.S. is 17 years old.

91. She would like to organize a demonstration in the City of Glens Falls with others

her age to express her political views on the 2020 election.


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92. City Code § 87 prohibits minors (people under the age of 18) from receiving a

demonstration permit from the City.

WHEREFORE, plaintiffs ask this Court (1) to declare Glens Falls City Code § 87

unconstitutional; (2) to award each plaintiff $1.00 in nominal damages; (3) to enjoin

defendants from enforcing Glens Falls City Code § 87; (4) to award plaintiff Florence

Sherman compensatory damages in an amount to be determined at trial, (5) to award

plaintiffs the cost of prosecuting this action together with attorney fees pursuant to 42

U.S.C. §1988, and (6) to grant other and different relief that the Court, in the exercise of

its wisdom and discretion, deems just and proper.

Submitted on this 16th day of June 2020,

/s/_Thomas Marcelle Thomas Marcelle (Bar Roll No. 102117) Adam Giangreco (Bar Roll No. 517518) Marcelle and Giangreco Counsel for Plaintiffs 99 Pine Street, Suite 204 Albany, New York 12207 Email: [email protected]

On this 16th day of June, 2020, Florence Sherman, pursuant to 28 U.S.C. §1746, declares

that she has read the foregoing and the same is true to her own knowledge, except as to

matters therein stated to be alleged on information and belief, and as to those matters, she

believes them to be true.

/s/__Florence Sherman__ Florence Sherman

On this 16th day of June, 2020, Dave Vanscoy, pursuant to 28 U.S.C. §1746, declares that

he has read the foregoing and the same is true to his own knowledge, except as to matters


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therein stated to be alleged on information and belief, and as to those matters, he believes

them to be true.

/s/_Dave Vanscoy_ Dave Vanscoy


EXHIBIT A


RESOLUTION NO. -2020 GLENS FALLS COMMON COUNCIL WHEREAS, the Common Council of the City of Glens Falls recognizes that certain adjustments to its regulations must be made from time to time in order to preserve the public health, safety and welfare of its residents, and WHEREAS, the right to peacefully assemble and demonstrate is protected by the First Amendment of the United States Constitution; however, these constitutional privileges are not unlimited as it pertains to maintaining public safety. The City of Glens Falls may impose reasonable time, place and manner restrictions, NOW, THEREFORE, the Common Council of the City of Glens Falls does hereby (i) accept and approve the content and form of the Local Law attached hereto as Exhibit “A”, (ii) schedule a Public Hearing on Tuesday, February 11, 2020 at 7:20 p.m. in the Common Council Chambers, 3rd floor, City Hall, 42 Ridge, Glens Falls, NY 12801 with respect to such proposed Local Law prior to the confirmation of the final passage of such Local Law at the next meeting of the Common Council or the next regularly scheduled meeting of the Common Council held as soon after publication has herein directed as the Charter of the City of Glens Falls or the laws of the State of New York will allow and (iii) authorize the Clerk of the City of Glens Falls to take all actions necessary to publish notice of the Local Law utilizing the form of notice attached hereto as Exhibit “B”.


Final Revision 01/25/2020 @ 10:15 a.m. Exhibit “A” PROPOSED LOCAL LAW NO. 2-2020 A LOCAL LAW TO AMEND THE CODE OF THE CITY OF GLENS FALLS BY ADDING A NEW CHAPTER, CHAPTER 87, DEMONSTRATIONS. Be it enacted by the City of Glens Falls of the County of Warren as follows: The Code of the City of Glens Falls is hereby amended by adding a new Chapter, Chapter 87, Demonstrations. ARTICLE 1 § 87-1 Legislative findings; intent and purpose; authority.

A. The right to peacefully assemble and demonstrate is afforded to all persons and is protected by the First Amendment of the United States Constitution and the New York State Constitution, Article I, Section 8 and 9. These constitutional privileges are not, however, unlimited as it pertains to public safety, health and welfare.

B. The City of Glens Falls is authorized to impose reasonable time, place and manner restrictions on demonstrations.

C. This chapter shall be known and may be cited as “Chapter 87, Demonstrations.” § 87-2 Compliance with other provisions; definitions; construal of provisions.

A. Demonstration. For the purpose of this chapter, a “demonstration” shall mean a pre-planned gathering of 25 or more persons who are invited or organized by an organizer to convene for the purpose of a public exhibition including a procession, parade, protest, picket, march or rally on public property.

B. No person, corporation, partnership or other entity shall hold or cause to be held any demonstration without first filing a permit where required by this chapter.

C. The following definitions shall apply to this chapter: CITY The City of Glens Falls, New York. CITY CLERK The City Clerk of the City of Glens Falls, New York. PARADE Any procession of any kind on a public street in the City of Glens Falls that is intended to attract public attention and that does not comply with normal traffic regulations and control. PUBLIC PLACE Any place to which the public has unrestricted access, but “public place” shall not mean the interior floor space or any building or any space covered by part of a building’s permanent roof. SIGNS Any display, as defined in the City Code, Chapter 180, Signs.

D. Nothing in this chapter shall be construed so as to limit any of the provisions of the New York State Building and Fire Codes or to limit provisions of State Building and Fire Codes and/or New York State Penal Code.


§87-3 Prohibited items or activities

A. The following items or activities are prohibited except for use by law enforcement: 1. Alcoholic beverages. Alcoholic beverages in any open container cannot be carried or

possessed by participants of the demonstration. 2. Explosives, fireworks or pyrotechnics. No person shall carry or possess any kind or mixture of

explosives, fireworks or pyrotechnics. 3. Masks. Being masked or in any manner disguised by unusual or unnatural attire or facial

alteration. 4. Fencing material. Materials commonly used for fencing on property, or a safety zone

including barricades and which could be used to obstruct governmental administration shall not be carried or possessed unless placed at a demonstration site by governmental agencies to control demonstration participants and continue to allow free access to sidewalks or other public places as allowed by statute, law, code or ordinance. Fencing and barricade shall not be used to hang signs or other materials. Nothing shall be used to impede visibility on either side of the barriers.

5. Flammable or combustible liquids or gases. 6. Gas masks. Gas masks or similar devices designed to filter air breathed and protect the

respiratory tract and face against the irritating, noxious or poisonous gases cannot be carried, possessed or worn.

7. Injury, physical. No demonstration shall cause physical injury to persons or property, whether public or private.

8. Interference with emergency services. The demonstration will not unduly interfere with proper fire and police protection or emergency services.

9. Noxious materials. No person shall carry any container which contains any drug or other substance capable of generating offensive, noxious or suffocating fumes, gases or vapors, or capable of immobilizing a person.

10. Plastic or metal pipe. It is unlawful to carry or possess any length of plastic pipe more than ¼ inch thick. Any metal pipe, metal angle iron, box steel, flat steel or similar plastic material is not permitted.

11. Projectile launchers. Projectile launchers or other devices commonly used for the purpose of launching, hurling, or throwing any object, liquid, material or substance cannot be carried or possessed.

12. Sidewalks (blocking). No person or group of persons and/or objects shall block any lawful use of a public sidewalk or any ingress to or egress from any building by standing within eight feet of said doorway or entrance or any driveway to any building.

13. Signs. As defined in the City Code, Chapter 180, Signs. 14. Sirens or air horns. No person shall use, carry or possess any hand carried or vehicle-

mounted siren or air horn. 15. Traffic (blocking). No person(s) and/or objects shall block or otherwise interfere with

highway, road or rail traffic to include ingress to or egress from a building or onto property. 16. Wood or wood products. No person shall carry or possess any length of lumber, wood or

wood lath unless the wood object is blunted at both ends, is ¼ inch or less in thickness and two inches or less in width or, if not generally rectangular in shape, does not exceed ¾ inch at its thickest.


17. Firearms are prohibited, except for those displayed by participants in the Memorial Day parade and those used by active duty law enforcement personnel.

18. The use of drones for any activity referenced in this chapter is prohibited. 19. There shall be no Demonstrations conducted in the public areas known as Centennial Circle

and the Civil War Monument within five feet of the roadway. 20. The distance between demonstrators and counter demonstrators shall not be less than

eight feet. §87-4. Application for Permits

A. Application for a demonstration permit shall be made to the City Clerk on the forms provided by the City Clerk, and shall be required for any public assembly, parade or other event involving more than 25 individuals. Application for permits will be processed in order of receipt and in all cases decisions whether to grant or deny the application will be delivered within 14 days of application, unless, upon written notice to the applicant, a further 14-day extension is necessary.

B. Grounds for Denial. To the extent permitted by law, the City may deny an application for permit if the applicant or the person on whose behalf the application for permit was made has on prior occasions made material misrepresentations regarding the nature or scope of an event or activity previously permitted or has violated the terms of prior permits issued to or on behalf of the applicant. The City may also deny an application for permit on any of the following grounds: 1. The application for permit (including any required attachments and submissions) is not fully

completed and executed. 2. The application for permit contains a material falsehood or misrepresentation. 3. The applicant is legally incompetent to contract or to sue and be sued. 4. The applicant or the person on whose behalf the application for permit was made has on

prior occasions damaged City property and has not paid in full for such damage or has other outstanding and unpaid debts to the City.

5. A fully executed prior application for permit for the same time and place has been received, and a permit has been or will be granted to a prior applicant authorizing uses or activities which do not reasonably permit multiple occupancy of the particular location or part thereof.

6. The use or activity intended by the applicant would conflict with previously planned programs organized and conducted by the City and previously scheduled for the same time and place.

7. The use or activity intended by the applicant would present an unreasonable danger to the health or safety of the applicant, of employees of the City or of the public.

8. The use or activity intended by the applicant is prohibited by law or by the City Code and ordinances of the City.

C. Should the City deny the application, the City will clearly state, in writing, what the grounds for denial are, and, if possible to cure the defect, the City will clearly state in writing how that cure could be procured. Should the applicant resubmit an altered application the City will make a decision on the reformed application within 7 days.


D. Should the City deny the application on the basis of a prior reservation of the space and time of the requested demonstration, the City will make an alternate location recommendation.

E. An unsuccessful applicant may appeal the denial to the Mayor, in writing, within 7 days of receipt of the denial. The Mayor will have 7 days from receipt of the written appeal to make a decision. If the Mayor affirms the permit denial, the applicant may seek judicial review in state court.

F. Demonstration Permit Application. Permit to demonstrate is attached to this Local Law as Exhibit “C.”

§87-5. Fees There shall be no fee charged for a demonstration permit. §87-6. Responsibility for cleanup The Department of Public Works Superintendent shall have the authority, in situations where it is determined that the proposed demonstration is of such magnitude or character that it will generate an excessive or extraordinary amount of debris upon the public ways, to require an agreement from the applicant stating that the applicant shall be responsible for the costs of cleanup of the public ways after the demonstration. The superintendent may enter into an agreement with the applicant as may be necessary for this purpose. §87-7. Penalties for offenses; when effective.

A. Any person or other legal entity who violates any of the provisions of this local law shall be guilty of an offense and shall be subject to the following penalties:

I. A fine not to exceed $250.00. II. Such other penalties afforded by law.

The Police Department shall have the authority to enforce the provisions of this chapter and to Issue appearance tickets for violations thereof.

B. This chapter shall take effect upon local law filing with the NYS Secretary of State.


EXHIBIT “B” FORM OF NOTICE PLEASE TAKE NOTICE that the Glens Falls Common Council will hold a Public Hearing on Tuesday, February 11, 2020 at 7:20 p.m. in the Common Council Chambers, City Hall, 42 Ridge Street, Glens Falls, County of Warren, State of New York, concerning a Local Law described below: Any resident of the City of Glens Falls is entitled to be heard upon this Proposed Local Law at such Public Hearing. Copies of said Proposed Local Law are available for review at the City Clerk’s Office, City Hall, 42 Ridge Street, Glens Falls, New York. The purpose of the Public Hearing is to confirm passage of a Local Law to amend the Code of the City of Glens Falls by adding a new Chapter, Chapter 87, Demonstrations. Robert A. Curtis City Clerk City of Glens Falls 42 Ridge Street Glens Falls, NY 12801


Exhibit “C” Demonstration Permit

CITY OF GLENS FALLS DEMONSTRATION PERMIT APPLICATION

I, ________________________________, residing at_______________________________________ Hereby declare my intent to conduct a public demonstration at the following public place(s): Date(s): ____________________________________________________________________________ Time(s): ____________________________________________________________________________ Name of Organization (if applicable): _____________________________________________________ Approximate # of persons expected to participate: __________________________________________ Applicant’s phone number: ____________________________________________________________ The applicant agrees that the organization/individual will be responsible for cleanup or costs related to the cleanup of the public ways after the demonstration. I have read Chapter 87 of the City Code entitled “Demonstrations” and I agree to abide by its requirements. Date: ______________________ ___________________________________ Applicant’s Name (please print) ____________________________________ Signature of Applicant


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Case 1:20-cv-00672-LEK-CFH Document 1-1 Filed 06/16/20 Page 1 of 2

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UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF NEW … · 2020-06-22 · NORTHERN DISTRICT OF...

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