Skip to content

Judicial Watch • 28 Motion for Intervention of Judicial Watch Inc and True the Vote Memorandum of Support And Request to Expedite

28 Motion for Intervention of Judicial Watch Inc and True the Vote Memorandum of Support And Request to Expedite

28 Motion for Intervention of Judicial Watch Inc and True the Vote Memorandum of Support And Request to Expedite

Page 1: 28 Motion for Intervention of Judicial Watch Inc and True the Vote Memorandum of Support And Request...

Category:General

Number of Pages:23

Date Created:June 26, 2012

Date Uploaded to the Library:February 20, 2014

Tags:Admitted, Intervener, interveners, proposed, voter, paragraph, defendants, section, defendant, Florida, watch, plaintiff, State, judicial, states, court, ICE, CIA


File Scanned for Malware

Donate now to keep these documents public!

  • demand_answers

See Generated Text   ˅

Autogenerated text from PDF

THE UNITED STATES DISTRICT COURT 
FOR THE NORTHERN DISTRICT FLORIDA 
TALLAHASSEE DIVISION THE UNITED STATES AMERICA, Plaintiff, Case No. 4:12cv285-RH/CAS STATE FLORIDA and KEN DETZNER, Secretary State, his official capacity, 
Defendants. 
______________________________________ 

MOTION FOR INTERVENTION JUDICIAL WATCH, INC. AND 
TRUE THE VOTE; MEMORANDUM SUPPORT; 
AND REQUEST EXPEDITE
 
Judicial Watch, Inc., and True the Vote (collectively Proposed 
Interveners) respectfully move this Court for leave intervene pursuant 
Federal Rule Civil Procedure 24(a) and (b).1 grounds therefore, Proposed 
Interveners state follows: INTRODUCTION. this case, Plaintiff asks the Court enjoin the State Florida from 
continuing its efforts maintain the accuracy its voter rolls required 
Section the National Voter Registration Act 1993 (NVRA), U.S.C.  
#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3; proposed Answer Intervention attached hereto Exhibit 
1973gg-6. Plaintiff seeks this relief the grounds that the State Floridas list maintenance efforts are too close time the August 14, 2012 primary and therefore are prohibited NVRA. Proposed Interveners respectfully submit that Plaintiff wrong. 
Proposed Interveners seek enter this lawsuit order demonstrate that, not only are the State Floridas list maintenance activities valid, proper, and timely, but that they also are required under federal law. Intervention will ensure that the organizational interests Proposed Intervener True the Vote and the rights and interest the members Proposed Intervener Judicial Watch, Inc., are adequately protected and preserved. 

II. BACKGROUND. 
Plaintiff filed its Complaint June 12, 2012. its Complaint, Plaintiff alleges that the State Florida violating the NVRA and asks for injunction preventing what Plaintiff characterizes the systemic removal registered voters within days all elections for Federal office pursuant certain database matching procedures. Named defendants Plaintiffs Complaint are the State Florida and Florida Secretary State Ken Detzner, his official capacity. June 15, 2012, Plaintiff filed Motion for Temporary Restraining Order requesting that the Court temporarily halt the State Floridas list maintenance efforts  allegedly preserve the status quo  even though Plaintiff cannot identify single Florida voter who has actually been removed from the voter registration rolls. order dated June 19, 2012, the Court directed Defendants file their response Plaintiffs Motion for Temporary Restraining Order before June 25, 2012. 

III. PROPOSED INTERVENERS. 
Judicial Watch, Inc. (Judicial Watch), non-profit organization that seeks promote integrity, transparency, and accountability government and fidelity the rule law. Judicial Watch seeks intervene this action behalf its members who are registered vote the State Florida. 
True the Vote non-profit organization that seeks restore truth, faith, and integrity local, state, and federal elections. True the Vote seeks intervene this action its individual, organizational capacity. Proposed Intervener Judicial Watch. 
Judicial Watch membership organization. person becomes member making financial contribution, any amount, Judicial Watch.  Members financial contributions are far the single most important source income Judicial Watch and provide the means for financing the activities the organization. direct benefit its members, Judicial Watch regularly files lawsuits and involves itself litigation against government agencies and government officials federal and state courts across the United States. Judicial Watchs litigation efforts form integral part its public interest mission.  Furthermore, Judicial Watchs litigation provide means for the organizations members advance their collective views and protect their collective interests promoting integrity, transparency, and accountability government and fidelity the rule law. 
Judicial Watch has least 18,728 members the State Florida.  Each these members made least one financial contribution Proposed Intervener Judicial Watch over the past two years, and thus helped finance the activities the organization during this time period. least some Judicial Watchs 18,728 members the State Florida are registered vote the State. These members have substantial interest the accuracy and currency official lists eligible voters the State Florida, the accuracy and currency these lists directly affects their right vote. 
Consistent with its mission and order protect the rights and interests its registered voter members, Judicial Watch engaged ongoing legal effort ensure states and counties are performing their voter roll list maintenance requirements under federal law.2 Also this year, Judicial Watch (along with
#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3; See 2012 Election Integrity Project: Judicial Watch Announces Legal Campaign Force Clean Voter Registration Rolls, Feb. 2012, available http://www.judicialwatch.org/projects/2012-election-integrity-project/; see also Lise Olsen, Conservative watchdog group questions counties with too many voters, Houston 
plaintiff True the Vote) filed federal lawsuit against the State Indiana for 
failure comply with voter list maintenance provisions the NVRA,3 and filed 
brief supporting the list maintenance efforts the State Tennessee after they 
were sued former Congressman.4 part this effort, Judicial Watch sent letter inquiry the State 
Florida earlier this year ensure was complying with Section the NVRA.5 
The State Florida responded providing evidence that was least 
#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3; 
Chronicle, April 2012, available http://www.chron.com/news/houstontexas/article/Conservative-watchdog-group-questions-counties-3467513.php; see also Sean O'Donogue, Commission responds threatened lawsuit, Lincoln Journal, March 2012, available http://lincolnjournalinc.com/commission-responds-to-threatenedlawsuit-p8065-1.htm. 
#3; Watchdog group sues Indiana over voter rolls, Indianapolis Star, Jun. 11, 2012, available http://www.indystar.com/article/20120611/NEWS05/206110354/Watchdoggroup-sues-Indiana-over-voter-rolls. Judicial Watch and Allied Educational Foundation Submit Amicus Curiae Brief Support Tennessees Attempt Remove Ineligible Voters from Voter Registration Lists, June 13, 2012, available http://www.judicialwatch.org/press-room/pressreleases/judicial-watch-and-allied-educational-foundation-submit-amicus-curiae-brief-insupport-of-tennessees-attempt-to-remove-ineligible-voters-from-voter-registration-lists2/.  Letter from Thomas Fitton Kurt Browning and Gisela Salas, February 2012, available http://www.scribd.com/JWatchDC/d/96425229-Florida-Inquiry-Letter-NVRA-FINAL. 
attempting comply with its Section obligations.6  The relief now sought Plaintiff would therefore undo the work that Judicial Watch has undertaken the State Florida and would cause direct injury members Judicial Watch who are registered vote Florida. Preventing the State Florida from conducting the challenged list maintenance efforts will undermine the confidence that Judicial Watchs registered voter members have the integrity the electoral process and the effectiveness their vote. Plaintiff were succeed stopping the challenged list maintenance efforts, Judicial Watchs registered voter members may have their votes cancelled out diluted unlawful ballots cast the names unlawfully present aliens. least 473 members Judicial Watch who are registered vote Florida have communicated directly with Judicial Watch and requested that take action protect their interests from Plaintiffs misguided efforts stop the State Floridas list maintenance efforts. unlikely that any individual Judicial Watch member would have the ability the resources take action protect their individual interests absent collective action Judicial Watch. 
#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;  Letter from Maria Matthews Thomas Fitton, April 2012, available http://www.scribd.com/JWatchDC/d/96425227-Florida-SoS-Letter-Re-NVRA. Proposed Intervener True the Vote. integral part its public interest mission ensure the integrity the nations electoral system,7 Proposed Intervener True the Vote obtains and examines official lists eligible voters and other voter registration data from states, counties, and localities across the United States, including the State Florida, carry out its various programs.  For one such program, Proposed Intervener True the Vote reviews and analyzes official lists eligible voters and other voter registration data order verify that such lists and data are accurate and current possible. 
Specifically, True the Vote uses trained volunteers review official lists eligible voters and voter registration data and compare these lists and data other publically available data identify possible inaccuracies and deficiencies.  Registrations that appear duplicates registrations persons who are deceased, have relocated, otherwise are ineligible vote particular jurisdiction are flagged and citizen complaints are filed with the appropriate elections officials. This particular program among the largest, not the largest, all True the Votes various programs and also integral part True the Votes public interest mission. The program builds and supplements, but 
#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3; 
cannot duplicate replace, the list maintenance programs that States are required perform under federal voter registration laws. 
True the Vote has recruited and trained volunteers analyze and verify the accuracy and currency official lists eligible voters and other voter registration data for the State Florida for the November 2012 election and plans recruit and train additional volunteers for this effort.  True the Votes efforts analyze and verify the accuracy and currency official lists eligible voters and other voter registration data, including official lists and other voter registration data the State Florida, are dependent substantial part States fulfilling their voter list maintenance obligations under federal voter registration laws. order protect its organizational interests this regard, earlier this month True the Vote (along with co-plaintiff Judicial Watch) filed federal lawsuit against the State Indiana for failure comply with voter list maintenance provisions the NVRA.8 States are prevented from conducting voter list maintenance programs, then not only are the lists and voter registration data obtained and examined True the Vote inaccurate and unreliable, but True the Vote not able use its limited resources make official lists eligible voters and other voter 
#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3;#3; State sued over 2010 voter rolls, Indianapolis Star, Jun. 12, 2012, available http://www.indystar.com/article/20120612/LOCAL/206120328/State-sued-over-2010voter-rolls. 
registration data accurate and current possible.  Instead, True the Vote can only hope make for small part the States voter list maintenance efforts. successful, Plaintiffs attempt stop the challenged list maintenance efforts will impair the ability True the Vote carry out its public interest mission. True the Vote will not able complete its work ensuring high degree accuracy and currency the official lists eligible voters and other voter registration data the State Florida the State Florida prevented from carrying out the challenged list maintenance effort.  Accordingly, Plaintiff succeeds, True the Vote will injured because its ability carry out public interest mission will impaired. 
IV. 	PROPOSED INTERVENERS ARE ENTITLED INTERVENE MATTER RIGHT. 
The U.S. Court Appeals for the Eleventh Circuit (Eleventh Circuit) has held that Rule should liberally construed with all doubts resolved favor the proposed intervenor.  Tweedle State Farm Fire Cas. Co., 527 F.3d 664, 671 (11th Cir. 2008); see also Meek Metropolitan Dade County, Florida, 985 F.2d 1471, 1478 (11th Cir. 1993) (Any doubt concerning the propriety allowing intervention should resolved favor the proposed interveners because allows the court resolve all related disputes single action.). Allowing parties intervene serves the interests judicial efficiency, since intervention allows courts resolve related disputes single action. See 
Federal Savings and Loan Falls Chase Special Taxing Dist., 983 F.2d 211, 216 (11th Cir. 1993). intervene matter right, Proposed Interveners must show that (1) their request intervene timely; (2) they have protectable interest the subject the action; (3) they are situated that the disposition the action may impede impair their ability protect those interests; and (4) their interests may not represented adequately the existing parties the suit. See e.g. Sierra Club, Inc. Leavitt, 488 F.3d 904, 910 (11th Cir. 2007).  Proposed Interveners easily meet these criteria. Intervention Timely. 
Plaintiff filed its Complaint June 12, 2012 and its Motion for Temporary Restraining Order June 15, 2012. This motion intervene being submitted only two weeks after Plaintiff initiated this action.  Accordingly, there delay and hence prejudice the existing parties. Georgia U.S. Army Corps Engineers, 302 F.3d 1242, 1260 (11th Cir. 2002) (intervention request filed after six months was timely); Chiles Thornburgh, 865 F.2d 1197, 1213 (11th Cir. 1989) (seven month delay not untimely).  However, Proposed Interveners would prejudiced they are not allowed intervene, they would left without reasonable opportunity protect their interests. Walker The Jim Dandy Company, 747 F.2d 1360, 1365 (11th Cir. 1984). See True the Vote Mission Statement, available http://truethevote.org/about/. Proposed Interveners Have Direct and Protectable Interest. Florida unable ensure its voter rolls are accurate pursuant federal law, Judicial Watchs registered voter members confidence the integrity the election process will undermined and True the Votes attempts make the voter rolls the State Florida accurate and current possible will impaired. 
The organizational injury True the Vote may suffer direct and protectable: independent basis for organizational standing exists when defendants conduct makes difficult impossible for the organization fulfill one its essential purposes goals. See Charles Wesley Educ. Found., Inc. Cox, 408 F.3d 1353-54 (11th Cir. 2005) (an organization conducting voter registration has protected interest under the NVRA having individuals registers processed properly and states actions negatively impacting that interest confer standing the organization bring suit its own 
behalf). Common Cause Colorado, Buescher, 750 Supp.2d 1259, 1269 (D. Colo. 2010). Furthermore, organization has standing sue its own behalf illegal acts impair its ability engage its projects forcing the organization divert resources counteract those illegal acts. Florida State Conference NAACP Browning, 522 1153, 1165 (11th Cir. 2008), citing Havens Coleman, 455 363, 379 (1982).   
Judicial Watch may intervene behalf its members protect their voting rights and interests because such action core Judicial Watchs public interest mission. Florida State Conference NAACP, 522 F.3d 1161.  The injury Judicial Watch members confidence the integrity Floridas federal election direct and protectable: [P]ublic confidence the integrity the electoral process has independent significance, because encourages citizen participation the democratic process. the Carter-Baker Report observed, the electoral system cannot inspire public confidence safeguards exist deter detect fraud confirm the identity voters. Crawford, Marion County Election Bd., 553 U.S. 181, 197 (2008). 
Furthermore, Judicial Watchs members also have direct and protectable interest ensuring their votes are not diluted result Plaintiffs actions: 
Further, the injury here alleged, not the States failure count any 
one persons vote, but the higher probability that vote not being 
counted result the voting systems used, i.e., vote dilution. 
That injury both provable and traceable Defendants actions 
given the facts alleged. Vote dilution directly related voting, 
the most basic political rights, sufficiently concrete and 
specific. Black McGuffage, 209 Supp. 889, 895 (ND Ill. March 29, 2002) quoting FEC Akins, 524 U.S. 11, (1998). 	The Disposition This Case Will Directly Affect Proposed Interveners. described above Sections III and IV.B., unfavorable disposition this action will directly harm True the Vote and the registered voter members Judicial Watch. Especially light the proximity the November 2012 election, adverse Court ruling will have direct impact True the Vote and the registered voter members Judicial Watch, and Proposed Interveners therefore have direct, substantial and legally protected interest the subject matter this litigation. Georgia U.S. Army Corps, 302 F.3d 1250. 	Adequacy Representation. 
The burden under this prong has been described minimal, party seeking intervene needs show only that representation his interest may inadequate. Clark Putnam County, 168 F.3d 458, 461 (11th Cir. 1999), quoting Trbovich United Mine Workers, 404 U.S. 528, 538 n.10 (1972). this case, Defendants have interest ensuring that the State Florida complying with Section the NVRA, while Proposed Interveners have interest ensuring they can satisfy their public interest mission make voter rolls accurate possible, the case True the Vote, and ensuring their members have confidence the legitimacy the November 2012 election, the case Judicial Watch. #3; THE ALTERNATIVE, PERMISSIVE INTERVENTION SHOULD GRANTED. 
Fed. Civ. 24(b)(1) governs permissive intervention and provides: timely motion, the Court may permit anyone intervene who: 
(A) given conditional right intervene federal statute; 

(B)
 has claim defense that shares with the main action 
common question law fact. the Eleventh Circuit has declared, Permissive intervention under Fed. Civ. Proc. 24(b) appropriate where partys claim defense and the main action have question law fact common and the intervention will not unduly prejudice delay the adjudication the rights the original parties. Georgia Army Corps, 302 F.3d 1250, citing Walker Jim Dandy, 747 F.2d 1365. demonstrated above, this test satisfied here. 
Rule 24(b)(3) also requires the Court consider whether permissive intervention will cause undue delay prejudice the adjudication the rights the existing parties. described above, this instance prejudice delay will result from intervention. Proposed Interveners intend comply with briefing schedule already place this matter, and their participation will not affect the scheduling this case any way.  Thus, minimum, Proposed Interveners respectfully request that they granted permissive intervention. 

VI. 	PROPOSED INTERVENERS REQUEST EXPEDITED CONSIDERATION THIS MOTION. 
Proposed Interveners respectfully request expedited consideration this motion. Proposed Interveners seek ensure their interests are presented and preserved timely fashion and, this end, request that the Court consider their motion the same time that considers Plaintiffs Motion for Temporary Restraining Order. Proposed Interveners also request that this Court set the following expedited briefing schedule for their motion:  opposition memoranda, any, filed later than p.m. July 2012. 

VII. CERTIFICATION PURSUANT LOCAL RULE 7.1(B). 
The undersigned counsel certify that Counsel for Defendants have indicated that Defendants not oppose the relief sought herein. addition, undersigned counsel certify that they have attempted reach counsel for Plaintiff and left messages informing them this motion, however, counsel have not yet obtained consent. 

VIII. CONCLUSION. 

For the forgoing reasons, Proposed Interveners respectfully request that this Court grant them leave intervene this action. Dated: June 26, 2012 Respectfully submitted, 
Paul Orfanedes 
       Paul Orfanedes Petition for Admission Filed        Chris Fedeli Petition for Admission Pending
       JUDICIAL WATCH, INC.       425 Third Street S.W., Ste. 800        Washington, 20024        Tel: (202) 646-5172        Fax: (202) 646-5199 Email:        porfanedes@judicialwatch.org        cfedeli@judicialwatch.org 

/s/ Christopher Lunny 
       Christopher Lunny        Fla. Bar No. 0008982       Harry Thomas Fla. Bar No. 195097 
RADEY THOMAS YON CLARK 301 South Bronough Street Suite 200 Tallahassee, 32301 Tel: (850) 425-6654  Fax: (850) 425-6694        Email: clunny@radeylaw.com#3;      hthomas@radeylaw.com
       Attorneys for Proposed        Interveners Counsel: Christian Adams Election Law Center, PLLC 300 Washington Street, Ste. 405 Alexandria, 22314 
Exhibit THE UNITED STATES DISTRICT COURT
 FOR THE NORTHERN DISTRICT FLORIDA
 TALLAHASSEE DIVISION THE UNITED STATES AMERICA, Plaintiff,) Case No. 4:12cv285-RH/CAS
 STATE FLORIDA and KEN DETZNER,
 Secretary State, his official capacity,
 Defendants,
 and
 JUDICIAL WATCH, INC., behalf
 certain its members, and TRUE THE VOTE, its individual, corporate capacity,
 Defendant-Interveners.)
 ______________________________________
 

ANSWER DEFENDANT-INTERVENERS JUDICIAL WATCH, INC. AND TRUE THE VOTE 
Defendant-Interveners Judicial Watch, Inc. and True the Vote 
(Interveners) hereby submit this Answer the above-captioned case and state follows: 

ANSWER Admitted. Defendant-Interveners admit that the United States has brought action. The remainder this paragraph consists conclusions law and response required. 

JURISDICTION AND VENUE 
Admitted. 
Admitted. 

PARTIES 
This paragraph contains conclusions law, which require response. The remainder this paragraph admitted. 
This paragraph contains conclusions law, which require response. The remainder this paragraph admitted. Admitted. 

CAUSE ACTION 
The allegations this paragraph are admitted the extent they contain factual allegations.  This paragraph also characterizes federal statute, the National Voter Registration Act (NVRA), U.S.C.  1973-gg seq. Defendant-Interveners deny that characterization. 
Admitted. 

10. 
Admitted.  

11. 
Defendant-Interveners admits that this paragraph contains partial quotation the NVRA. This paragraph also characterizes federal statute, the NVRA, which speaks for itself.  Defendant-Interveners deny the characterizations the NVRA contained this paragraph.  The remainder this paragraph contains conclusions law, which require response. 

12. 
Admitted. 

13. 
Admitted. 

14. 
Admitted. 

15. 
Admitted. 

16. 
Defendant-Interveners lack sufficient information admit deny the specific allegations this paragraph, and therefore deny them. the extent that this paragraph alleges that Defendants have been engaged undertaking ensure Floridas voter registration rolls are accurate and contain the names eligible voters required Section the NVRA and other federal laws, admitted.   

17. 
Defendant-Interveners deny that this paragraph contains quotations from power point document entitled Processing Ineligible Registered VoterNon-Immigrants.  Rather, this paragraph contains quotations from April 2012 document entitled Processing Ineligible Registered Voters-Non-Immigrants.  Plaintiffs inaccurate quotation the title this document, both punctuation 

and grammar, slightly alters the meaning the document non-insignificant way.  Defendant-Interveners also deny this paragraph contains accurate quote from page the referenced document. this instance, Plaintiff replaced lower case letter with upper case letter the word if and changed possessive noun non-possessive noun without identifying those alterations the Court. the extent that this paragraph alleges that Defendants distributed document assist Floridas local election offices complying with their obligation ensure local voter registration rolls are accurate and contain the names eligible voters required the NVRA and other federal laws, admitted.  Defendant-Interveners lack sufficient information admit deny the remaining specific allegations this paragraph, and therefore deny them. 

18. 
Defendant-Interveners admit that this paragraph contains mostly accurate partial quotations from Exhibit Plaintiffs Complaint, document dated May 13, 2012 entitled List Maintenance Categories and Procedures. Defendant-Interveners lack sufficient information admit deny the remaining specific allegations this paragraph, and therefore deny them. the extent that this paragraph alleges that Defendants distributed document assist Floridas local election offices complying with their obligation ensure local voter registration rolls are accurate and contain the names eligible voters required the NVRA and other federal laws, admitted.   

19. Denied. 

20. 
Defendant-Interveners lack sufficient information admit deny the specific allegations this paragraph, and therefore deny them.  

21. Admitted. 

22. 
This entire paragraph characterizes document that speaks for itself, and therefore requires response.  

23. 
This entire paragraph characterizes document that speaks for itself, and therefore requires response.   

24. 
Defendant-Interveners lack sufficient information admit deny the specific allegations this paragraph, and therefore deny them.  

25. 
Denied, except the extent this paragraph contains conclusion law, which case response required. 

26. Denied. 

27. Denied. Dated: June 26, 2012 Respectfully submitted, 
Paul Orfanedes  
Paul Orfanedes Petition for Admission Filed Chris Fedeli Petition for Admission Pending 
JUDICIAL WATCH, INC. 425 Third Street S.W., Ste. 800 Washington, 20024 Tel: (202) 646-5172 Fax: (202) 646-5199 Email: porfanedes@judicialwatch.org cfedeli@judicialwatch.org 

/s/ Christopher Lunny     
Christopher Lunny Fla. Bar No. 0008982 Harry Thomas Fla. Bar No. 195097 
RADEY THOMAS YON CLARK 301 South Bronough Street Suite 200 Tallahassee, 32301 Tel: (850) 425-6654 Fax: (850) 425-6694 Email: clunny@radeylaw.com hthomas@radeylaw.com 
Attorneys for Proposed Interveners Counsel: Christian Adams Election Law Center, PLLC 300 Washington Street, Ste. 405 Alexandria, 22314