II. NATURE OF CLAIM(S)
Plaintiffs claim that passage and enforcement of the aforementioned legislation:
A. violates their fundamental constitutional rights to lawfully possess, keep, bear and
use firearms for self-defense and other lawful purposes;
B. violates their constitutional rights to privacy;
C. impermissibly interferes with and infringes upon their fundamental constitutional
rights to travel both intra-state and inter-state with lawfully possessed firearms;
D. unconstitutionally criminalizes and bans the possession of certain firearms,
ammunition and large capacity feeding devices that were legally possessed prior by plaintiffs prior
to the legislation’s passage and enforcement, and in which the plaintiff’s had a cognizable property
3interest. The outright criminalization and ban of these firearms, ammunition and large capacity
feeding devices amounts to a deprivation and taking of them by the State of New York under color
of law and without due process or just compensation. As such, passage and enforcement of the NY
SAFE Act effectuates an unconstitutional taking of private property under the Fifth and Fourteenth
Amendments to the U.S. Constitution;
E. unlawfully and unconstitutionally imposes restrictions on the ability of the plaintiffs
to conduct business on both inter-state and intra-state levels with the designers of, manufacturers of,
sellers of, distributors of, and purchasers of certain firearms, ammunition, and large capacity
feeding devices, all in violation of the Commerce Clause of the U.S. Constitution;
F. deprives the plaintiffs of life, liberty and/or property without due process of law, in
violation of the Fourteenth Amendment of the U.S. Constitution;
G. deprives the plaintiffs of the equal protection of the laws, in violation of the
Fourteenth Amendment of the U.S. Constitution;
H. was passed and is being continuously enforced with the ongoing tortious intent to
harass, harm, impede, interfere with, disrupt, interrupt, and/or destroy the present and future
business and commercial activities of those plaintiffs who engage in the design of, manufacture of,
distribution of, sale of, possession of, and/or training in the safe and lawful use of firearms,
ammunition, and/or large capacity feeding devices; and
I. the legislation is impermissibly vague and overbroad.
III. ITEMS OF DAMAGE / INJURIES SUSTAINED
A. Violation of rights guaranteed to the plaintiffs by the U.S. Constitution and the New
York Sate Constitution.
B. Deprivation of property rights and property values.
4
C. Interference with business relations, business activities, and business contracts
relating to the design of, manufacture of, distribution of, sale of, possession of, and/or training in
the safe and lawful firearms, ammunition, and/or large capacity feeding devices.
IV. AMOUNT OF DAMAGES TO WHICH PLAINTIFFS ARE ENTITLED
Plaintiffs are not seeking monetary damages. Plaintiffs are seeking injunctive relief against
the ongoing enforcement of the NYS SAFE Act, and declaratory relief the NYS SAFE Act is
unconstitutional.

Originally Posted By BANDITOZ71:
In on one.

Originally Posted By Falcon09: