The following excerpt is from Kerman v. City of NY, 261 F.3d 229 (2nd Cir. 2001):
has an interest protected by the First Amendment, (ii) the defendants' actions were motivated by or substantially caused by the plaintiff's exercise of that right and (iii) the defendants' actions chilled the exercise of those rights. Connell v. Signoracci, 153 F.3d 74, 79 (2d Cir. 1998) (citations omitted).
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