Price v. City of N.Y. 15 Civ. 5871 (KPF) (S.D.N.Y. Jun. 25, 2018) rate within the 28th Precinct" and to prevent her "from publically criticizing the 28th Precinct." (Id. at ¶¶ 106-07). Pierre-Louis, who at the time was the Commissioner of the Mayor's Office to Combat Domestic Violence, ordered Brooks to block Plaintiff from @NYCagainstabuse. (Id. at ¶¶ 121, 124). Plaintiff had a similar experience with the Twitter account for the New York City Mayor's Office to Combat Domestic Violence, @NYCagainstabuse, and its administrator, Selvena Brooks. Near the end of 2014, Plaintiff used her Twitter account to post the following responses to tweets from @NYCagainstabuse: Plaintiff also had interactions with a Twitter account named @RPLNYC, which was moderated by Pierre-Louis. Plaintiff contends that PierreLouis identified herself on the account as the Commissioner of the Mayor's Office to Combat Domestic Violence and used the account to "disseminate official information during that time that she was Commissioner." (FAC ¶¶ 126-28). She adds that Pierre-Louis "gained followers and credibility by naming her official title on her @RPLNYC [T]witter account and disseminating official information and offering her editorial opinion of that information in her capacity as Commissioner for the NYC Mayor's Office to Combat Domestic Violence." (Id. at ¶ 129). @NYCAGAINSTABUSE @NYPD28Pct victims be wary of the 2-8: their "Help" put me on #Rikers & my abuser walked chn.ge/11fKJZd #JAILSACTION *** @NYCagainstabuse Many more women could have benefitted from services at a FJC [Family Justice Center] but were barred because they were falsely labeled "fabricators." 9 *** @NYCagainstabuse where do we go when wrongly dubbed as "fabricators" by #MYNYPD & @manhattanda & denied entrance to Family Justice Centers? 8 (FAC ¶ 114). On the same day as Plaintiff's final tweet to @NYCagainstabuse, Brooks blocked Plaintiff's Twitter account from accessing the official account of the Mayor's Office to Combat Domestic Violence, leading to the same limitations as those concerning the @NYPD28Pct account. (Id. at ¶¶ 115-19). Plaintiff surmises that Brooks blocked her in retaliation for her criticism of the City's domestic violence assistance rates and to prevent further public criticism of the Mayor's Office to Combat Domestic Violence. (Id. at ¶¶ 120-23). Plaintiff also asserts that Rose *8 Plaintiff alleges that in October 2014, Pierre-Louis blocked her from viewing and posting replies to the @RPLNYC Twitter account. (FAC ¶ 131). While Plaintiff does not specifically allege the facts and circumstances that *9 preceded her being blocked from the @RPLNYC account, she contends that Pierre-Louis blocked her in retaliation for "her criticism of the domestic violence community's response to her secondary victimization by the criminal justice system" and "to mitigate fears that other victims may harbor when [ ] turning to authorities for help if they learned of [Plaintiff's] fate when she attempted to do so." (Id. at ¶¶ 136-37). In addition to accusing Obe, Brooks, and PierreLouis of blocking her from viewing Twitter accounts that they administer, Plaintiff also asserts that the City itself is responsible. She alleges that even though the City's official, written social media policies "are explicit that people are not to be blocked on Social Media based on viewpoint, the City has a practice and custom of blocking unfavorable comments on social media[,]" as 4

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