South Boston Allied War Veterans Council v. The City of Boston et alMOTION for Temporary Restraining Order and Injunctive ReliefD. Mass.March 14, 2016UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS Civil Action No: Plaintiffs V. THE CITY OF BOSTON and POLICE COMMISSIONER WILLIAM B. EVANS, In his official capacity, and MARTIN J. WALSH, MAYOR OF CITY OF BOSTON, In his official capacity. Defendants r.o • B o SOUTH BOSTON ALLIED WAR VETERANS COUNCIL - " "n 3 m 1 n MOTION FOR TEMPORARY RESTRAINING ORDER AND INJUNCTIVE RELIEF The PlaintifiFSouth Boston AUied War Veterans Council respectfully requests that this Honorable Court issue, pursuant to F.R.C.P. Rule 65, a temporary restraining order, ordering the City of Boston to issue to the Plaintiffs a Parade Permit that will enable them to conduct their parade on the traditional parade route in South Boston. For the last 20 years, the Plaintiffs have organized and conducted a St. Patrick's / Evacuation Day Parade over the same streets that are depicted in the map attached as Exhibit J. The detailed iteration of the streets used by the parade are listed in their Application for a Parade Permit for their 2016 Parade, scheduled for March 20*^ 2016, Exhibit K. Due to snow accumulation in 2015, the Parade route was shortened as depicted on the map attached as E«xhibit L. Case 1:16-cv-10519-RGS Document 5 Filed 03/14/16 Page 1 of 2 The Boston Department of Transportation issued a Parade Permit to the Plaintiffs for their 2016 Parade, but modified the Parade route to conform with the shortened Parade route last year. The basis for the shortened Parade route was stated as "BTD has modified the requested parade routes for all parades in the neighborhood of South Boston on Sunday, March 20, 2016 to mitigate public safety and congestion concerns." Exhibit M. Also, Martin J. Walsh Mayor of Boston, has pubHcly stated that the change was made due to public safety and to save money. For the above reasons, and the fact that the Plaintiffs wUl suffer irreparable harm to their fundamental rights of free expression, right to assemble, right of association and assembly, protected by the First and Fourteenth Amendments to the United States Constitution, as their time to communicate their values and messages have been cut in half, and they will lose the opportunity to share their values and messages with the spectators. Dated: March 14^, 2016 submitted, Chester Darhhg, BBO 114320 Attorney for me Plaintiffs 9 Mayflower Dr. Andover, MA 01810 978-475-2520 e-mail:chesterdarling@comcast.net Case 1:16-cv-10519-RGS Document 5 Filed 03/14/16 Page 2 of 2
