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1
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COMPLAINT
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EXTRACTED KEY WORDS
FEE TRANSPORTATION ALTERNATIVES CITY PARKS DEPARTMENT YORK PERMIT CHARGE FIRST AMENDMENT PUBLICITY BIKE TOUR CONCESSION CENTRAL PARK SCHEDULES AMOUNT ADVOCACY SPONSORSHIP PORTION PLAINTIFF PAY MEMBERS DISTRICT SCHEME PURSUANT SUPPORT IMPOSE NYC BICYCLING COSTS ICE CREAM |
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
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TRANSPORTATION ALTERNATIVES, INC., ::
Plaintiff, :: COMPLAINT
vs. :: 01 Civ.
CITY OF NEW YORK and HENRY J. STERN, :
Commissioner of the New York City Department :
of Parks and Recreation, ::
Defendants. :
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PRELIMINARY STATEMENT
1. This is a civil-rights action to vindicate the federal constitutional rights of the
The City of New York has adopted and the Department of Parks and Recreation is enforcing a
scheme by which the Department, as a condition of issuing permits authorizing certain First
Amendment events to take place in City parks, is requiring groups to pay large fees to the
Department. That scheme grants government officials impermissible discretion to set fees of up
to $100,000 for such permits, and pursuant to that scheme government officials are charging
unconstitutionally excessive fees for permits for First Amendment events in City parks.
2. The plaintiff Transportation Alternatives is a not-for-profit, membership organization
founded in 1973 to promote bicycling and walking and to reduce automobile use in New York
City. As part of its advocacy and to raise money for its work, the group for many years has
sponsored a large bicycling event that starts and ends in the northern part of Central Park. This
1
year's event is scheduled for Sunday, September 9, 2001. Individuals who wish to participate
officially in the bike-ride portion of the event, which takes places on City streets, pay a
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