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Judicial Watch • Answer in Intervention of Defendant – Intervenors Chistina K. Gallegos-Merrill and Judicial Watch (U.S. v. North Carolina Board of Elections and Kim Starch (1:13 CV 861))

Answer in Intervention of Defendant – Intervenors Chistina K. Gallegos-Merrill and Judicial Watch (U.S. v. North Carolina Board of Elections and Kim Starch (1:13 CV 861))

Answer in Intervention of Defendant – Intervenors Chistina K. Gallegos-Merrill and Judicial Watch (U.S. v. North Carolina Board of Elections and Kim Starch (1:13 CV 861))

Page 1: Answer in Intervention of Defendant – Intervenors Chistina K. Gallegos-Merrill and Judicial Wa...

Category:Legal Document

Number of Pages:21

Date Created:December 10, 2013

Date Uploaded to the Library:December 11, 2013

Tags:U.S. v. North Carolina BOE and Kim Starch, North Carolina, election integrity project


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THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT NORTH CAROLINA
UNITED STATES AMERICA,
Plaintiff,
THE STATE NORTH CAROLINA; THE
NORTH CAROLINA STATE BOARD
ELECTIONS; and KIM STRACH, her official
capacity Executive Director the North Carolina
State Board Elections,
Defendants.
No. 1:13cv861
ANSWER INTERVENTION
DEFENDANT-INTERVENORS CHRISTINA
GALLEGOS-MERRILL AND JUDICIAL WATCH, INC.
Judicial Watch, Inc. and Christina Kelley Gallegos-Merrill DefendantIntervenors for their answer the complaint, state follows.
FIRST DEFENSE
Defendant-Intervenors answer the specific allegations plaintiff complaint
follows:
Plaintiff allegation that this action was filed enforce voting rights argumentative and represents legal conclusion which response required.
Defendant-Intervenors admit that the Attorney General the United States has filed this
complaint and that the cited statutes speak for themselves. all other respects,
Defendant-Intervenors deny the allegations paragraph
Case 1:13-cv-00861-TDS-JEP Document 26-1 Filed 12/10/13 Page
Defendant-Intervenors admit that that House Bill 589 (2013)
589 was signed Governor McCrory August 12, 2013 and designated
Session Law S.L. 2013-381, and that 589 speaks for itself. all other
respects, Defendant-Intervenors deny the allegations paragraph
 JURISDICTION AND VENUE
Defendant-Intervenors admit that the cited statutes speak for themselves
and that the Court has authority issue declaratory and injunctive relief. all
other respects, Defendant-Intervenors deny the allegations paragraph
Defendant-Intervenors consent venue this judicial district.
Defendant-Intervenors admit that the cited statutes speak for themselves. all other
respects, Defendant-Intervenors deny the allegations paragraph
 PARTIES
The allegations this paragraph are argument are legal
conclusory allegations which response required. the extent response required, Defendant-Intervenors admit that the cited statute speaks for itself. all
other respects, Defendant-Intervenors deny the allegations paragraph
Defendant-Intervenors admit the allegations paragraph
Defendant-Intervenors admit the allegations paragraph
Defendant-Intervenors admit that Kim Strach the Executive
Director the North Carolina State Board Elections and that she has been sued
her official capacity. all other respects, Defendant-Intervenors deny the allegations 
Case 1:13-cv-00861-TDS-JEP Document 26-1 Filed 12/10/13 Page paragraph
 ALLEGATIONS
The State North Carolina
Defendant-Intervenors admit that the 2010 census and its report
regarding the total population North Carolina and the population race are matters public record. all other respects, Defendant-Intervenors deny the allegations
paragraph
10.
Defendant-Intervenors admit that the 2010 census and its report regarding
the voting age population North Carolina and the voting age population race
are matters public record. all other respects, Defendant-Intervenors deny the
allegations paragraph 10.
11.
Defendant-Intervenors admit that information published the American
Community Survey speaks for itself. all other respects, Defendant-Intervenors deny
the allegations paragraph 11.
12.
Defendant-Intervenors admit that information published the North
Carolina State Board Elections SBOE matter public record and speaks
for itself. all other respects, Defendant-Intervenors deny the allegations paragraph
12.
13.
Defendant-Intervenors admit that the race persons registered voters
and the race individuals who have actually voted are matters public record and
speak for themselves. all other respects, Defendant-Intervenors deny the allegations 
Case 1:13-cv-00861-TDS-JEP Document 26-1 Filed 12/10/13 Page paragraph 13.
14.
Defendant-Intervenors admit that information published the American
Community Survey matter public record and speaks for itself. all other
respects, Defendant-Intervenors deny the allegations paragraph 14.
15.
Defendant-Intervenors admit that information published the American
Community Survey matter public record and speaks for itself. all other
respects, Defendant-Intervenors deny the allegations paragraph 15.
16.
Defendant-Intervenors admit that information published the American
Community Survey matter public record and speaks for itself. all other
respects, Defendant-Intervenors deny the allegations paragraph 16.
17.
Defendant-Intervenors admit that information published the American
Community Survey matter public record and speaks for itself. all other
respects, Defendant-Intervenors deny the allegations paragraph 17.
 The State North Carolina History Discrimination 
18.
Defendant-Intervenors admit that the cases cited this paragraph
speak for themselves. all other respects, Defendant-Intervenors deny the allegations paragraph 18.
19.
Defendant-Intervenors admit that the cited statutes, regulations, and
case speak for themselves. all other respects, Defendant-Intervenors deny the
allegations paragraph 19.
20.
 
The allegations this paragraph are argument are legal 
Case 1:13-cv-00861-TDS-JEP Document 26-1 Filed 12/10/13 Page
conclusory allegations which response required. the extent response required, Defendant-Intervenors admit that the cited statute speaks for itself. all
other respects, Defendant-Intervenors deny the allegations paragraph 20.
21.
Defendant-Intervenors are without knowledge information sufficient
form belief about the allegations paragraph 21.
22.
Defendant-Intervenors are without knowledge information sufficient
form belief about the truth the allegations paragraph 22.
 Provisions 589 
23.
Defendant-Intervenors admit that the provisions 589 speak for
themselves. all other respects, Defendant-Intervenors deny the allegations
paragraph 23.
24.
Early Voting 
Defendant-Intervenors are without knowledge information sufficient
form belief about plaintiff definition early voting, term that neither term art nor term defined North Carolina election statutes. Defendant-Intervenors
admit that North Carolina formerly granted county boards election the discretion
schedule one-stop absentee voting for many days and that the legislation that
gave this authority county boards election speaks for itself. all other
respects, Defendant-Intervenors deny the allegations paragraph 24.
25.
Defendant-Intervenors are without knowledge information sufficient
form belief about plaintiff definition early voting, term that neither term 
Case 1:13-cv-00861-TDS-JEP Document 26-1 Filed 12/10/13 Page art nor term defined North Carolina election statutes. Defendant-Intervenors
admit that the provisions 589 speak for themselves. all other respects,
Defendant-Intervenors deny the allegations paragraph 25.
26.
Defendant-Intervenors admit that the terms 589 speak for
themselves. all other respects, Defendant-Intervenors deny the allegations
paragraph 26.
27.
Defendant-Intervenors admit that the number and race voters are
matters public record and speak for themselves. all other respects, DefendantIntervenors deny the allegations paragraph 27.
28.
Defendant-Intervenors admit that the number voters who cast one-stop
ballots during the 2008, 2010, and 2012 general elections matter public
record. all other respects, Defendant-Intervenors deny the allegations paragraph
28.
Defendant-Intervenors are without knowledge information sufficient
29.
form belief about plaintiff definition early voting, term that neither term art nor term defined North Carolina election statutes. Defendant-Intervenors
admit that the number and race registered voters and voters who voted during each
day one-stop absentee voting the 2008 and 2012 general elections are matters
public record. all other respects, Defendant-Intervenors deny the allegations
paragraph 29.
30.
 
Defendant-Intervenors are without knowledge information sufficient 
Case 1:13-cv-00861-TDS-JEP Document 26-1 Filed 12/10/13 Page
form belief about plaintiff definition early voting, term that neither term art nor term defined North Carolina election statutes. Defendant-Intervenors
admit that the number and race voters and voters who voted during each day
one-stop absentee voting the 2012 general election are matters public record.
all other respects, Defendant-Intervenors deny the allegations paragraph 30.
31.
Defendant-Intervenors are without knowledge information sufficient
form belief about the truth allegations related voting Florida during the
2012 general election. all other respects, Defendant-Intervenors deny the allegations paragraph 31.
32.
Defendant-Intervenors are without knowledge information sufficient
form belief about the truth the allegations paragraph 32.
33.
Defendant-Intervenors admit that testimony, statements, evidence
presented during the legislature consideration 589 speaks for itself. all
other respects, Defendant-Intervenors deny the allegations paragraph 33.
34.
Defendant-Intervenors admit that any memoranda prepared the
former executive director the SBOE speaks for itself. all other respects,
Defendant-Intervenors deny the allegations paragraph 34.
35.
Same-Day Registration 
Defendant-Intervenors admit that the effective date for Same-Day
Registration SDR matter public record and that the provisions the
legislation allowing SDR speak for themselves. all other respects, Defendant- 
Case 1:13-cv-00861-TDS-JEP Document 26-1 Filed 12/10/13 Page
Intervenors deny the allegations paragraph 35.
36.
Defendant-Intervenors admit that the provisions 589 speak for
themselves. all other respects, Defendant-Intervenors deny the allegations
paragraph 36.
37.
This paragraph includes legal conclusion which response
required. the extent that response required, Defendant-Intervenors admit that the
number and race voters who used SDR are matters public record. all other
respects, Defendant-Intervenors deny the allegations paragraph 37.
38.
Defendant-Intervenors admit that the number and race voters who used
SDR during the 2008 and 2012 general elections are matters public record. all
other respects, Defendant-Intervenors deny the allegations paragraph 38.
39.
Out Precinct Provisional Ballots 
Defendant-Intervenors admit that the legislation that permitted voters
cast out-of-precinct ballots speaks for itself and that the effective date that
legislation matter public record. all other respects, Defendant-Intervenors
deny the allegations paragraph 39.
40.
Defendant-Intervenors admit that the provisions 589 regarding
out-of-precinct ballots speak for themselves. all other respects, DefendantIntervenors deny the allegations paragraph 40.
41.
Defendant-Intervenors admit that the cited statute speaks for itself. all
other respects, Defendant-Intervenors deny the allegations paragraph 41. 
Case 1:13-cv-00861-TDS-JEP Document 26-1 Filed 12/10/13 Page
42.
Defendant-Intervenors deny the allegations paragraph 42.
43.
Voter Photo Identification 
Defendant-Intervenors admit that state and federal statutes registration
requirements speak for themselves. all other respects, Defendant-Intervenors deny
the allegations paragraph 43.
44.
Defendant-Intervenors admit that the provisions 589 speak for
themselves. all other respects, Defendant-Intervenors deny the allegations
paragraph 44.
45.
Defendant-Intervenors admit that the provisions 589 speak for
themselves. all other respects, Defendant-Intervenors deny the allegations
paragraph 45.
46.
Defendant-Intervenors admit that the provisions 589 speak for
themselves. all other respects, Defendant-Intervenors deny the allegations
paragraph 46.
47.
Defendant-Intervenors admit that the provisions 589 speak for
themselves. all other respects, Defendant-Intervenors deny the allegations
paragraph 47.
48.
Defendant-Intervenors are without knowledge information sufficient
form belief about the allegations paragraph 48.
49.
Defendant-Intervenors admit that the April 2013 report issued the
SBOE speaks for itself and that the report was published before 589 was 
Case 1:13-cv-00861-TDS-JEP Document 26-1 Filed 12/10/13 Page
ratified the General Assembly. all other respects, Defendant-Intervenors deny
the allegations paragraph 49.
50.
Defendant-Intervenors admit that the report issued the SBOE speaks
for itself. all other respects, Defendant-Intervenors deny the allegations paragraph
50.
 Legislative History and Enactment 589 
51.
Defendant-Intervenors admit the allegations paragraph 51.
52.
Defendant-Intervenors admit that public hearings were held March
12, 2013, and April 10, 2013, and that testimony during those hearings speaks for
itself. all other respects, Defendant-Intervenors deny the allegations paragraph 52.
53.
Defendant-Intervenors admit that any amendments offered 589 and
any vote House members any amendment are matters public record. all
other respects, Defendant-Intervenors deny the allegations paragraph 53.
54.
Defendant-Intervenors admit that 589 was passed the House
April 24, 2013, and that the votes, partisan affiliation, and race members the
General Assembly who voted amendments the bill, committee reports,
readings the bill may matters public record. all other respects, DefendantIntervenors deny the allegations paragraph 54.
55.
Defendant-Intervenors admit that the version 589 passed the
House April 24, 2013, speaks for itself. all other respects, DefendantIntervenors deny the allegations paragraph 55. 
Case 1:13-cv-00861-TDS-JEP Document 26-1 Filed 12/10/13 Page
56.
Defendant-Intervenors admit that the version 589 passed the
House April 24, 2013, speaks for itself. all other respects, DefendantIntervenors deny the allegations paragraph 56.
57.
Defendant-Intervenors admit the allegations paragraph 57.
58.
Defendant-Intervenors admit that the opinion the United States
Supreme Court Shelby County Holder speaks for itself. all other respects,
Defendant-Intervenors deny the allegations paragraph 58.
59.
Defendant-Intervenors admit that the committee substitute offered and
adopted, amended, the Senate speaks for itself. all other respects,
Defendant-Intervenors deny the allegations paragraph 59.
60.
Defendant-Intervenors admit that the committee substitute offered and
adopted, amended, the Senate speaks for itself. all other respects,
Defendant-Intervenors deny the allegations paragraph 60.
61.
Defendant-Intervenors admit that non-privileged, public statements
members the General Assembly during public hearings, committee meetings,
the floor either chamber speak for themselves and are matters public record. all other respects, Defendant-Intervenors deny the allegations paragraph 61.
62.
Defendant-Intervenors admit that non-privileged, public statements
members the General Assembly during public hearings, committee meetings,
the floor either chamber speak for themselves and are matters public record. all other respects, Defendant-Intervenors deny the allegations paragraph 62. 
Case 1:13-cv-00861-TDS-JEP Document 26-1 Filed 12/10/13 Page
63.
Defendant-Intervenors admit that votes, partisan affiliation, and race
members the General Assembly who voted amendments the bill, committee
reports, readings the bill concurrence with the bill may matters public
record and speak for themselves. all other respects, Defendant-Intervenors deny the
allegations paragraph 63.
64.
Defendant-Intervenors admit that votes, political affiliation, and race
members the General Assembly who voted amendments the bill, committee
reports, readings the bill concurrence with the bill may matters public
record and speak for themselves. all other respects, Defendant-Intervenors deny the
allegations paragraph 64.
65.
Defendant-Intervenors admit that prior bills proposed the Senate
speak for themselves. all other respects, Defendant-Intervenors deny the allegations paragraph 65.
66.
Defendant-Intervenors admit that 589, amended, was passed
the House July 25, 2013, ratified July 26, 2013, presented the Governor
July 29, 2013, and signed the Governor August 12, 2013. all other respects,
Defendant-Intervenors deny the allegations paragraph 66.
67.
Defendant-Intervenors admit that statements the North Carolina
Attorney General speak for themselves. all other respects, Defendant-Intervenors
deny the allegations paragraph 67. 
Case 1:13-cv-00861-TDS-JEP Document 26-1 Filed 12/10/13 Page
 Implementation 589 Will Have Discriminatory Result 
68.
Defendant-Intervenors deny the allegations paragraph 68.
69.
Defendant-Intervenors deny the allegations paragraph 69.
70.
The allegations this paragraph are argumentative are legal
conclusory allegations which response required. the extent response
required, Defendant-Intervenors are without knowledge information sufficient
form belief about plaintiff definition early voting, term that neither term art nor term defined North Carolina election statutes. Defendant-Intervenors
admit that the number and race voters who have used one-stop absentee voting the
2008 and 2012 general elections are matters public record. all other respects,
Defendant-Intervenors deny the allegations paragraph 70.
71.
Defendant-Intervenors deny the allegations paragraph 71.
72.
The allegations this paragraph are argumentative are legal
conclusory allegations which response required. the extent response
required, Defendant-Intervenors are without knowledge information sufficient
form belief about plaintiff definition early voting, term that neither term art nor term defined North Carolina election statutes. Defendant-Intervenors
admit that the number and race voters who used SDR one-stop absentee voting
are matter public record. all other respects, Defendant-Intervenors deny the
allegations paragraph 72.
73.
 
The allegations this paragraph are argumentative are legal 
Case 1:13-cv-00861-TDS-JEP Document 26-1 Filed 12/10/13 Page
conclusory allegations which response required. the extent response
required, Defendant-Intervenors admit that the number and race voters who cast
out precinct ballots matter public record. all other respects, DefendantIntervenors deny the allegations paragraph 73.
74.
Defendant-Intervenors deny the allegations paragraph 74.
75.
Defendant-Intervenors deny the allegations paragraph 75.
76.
Defendant-Intervenors deny the allegations paragraph 76.
77.
Defendant-Intervenors admit that amendments offered during the
legislative process speak for themselves. all other respects, Defendant-Intervenors
deny the allegations paragraph 77.
78.
Defendant-Intervenors deny the allegations paragraph 78.
79.
Defendant-Intervenors incorporate reference their responses
paragraphs 18-22. Defendant-Intervenors admit that past court decisions the area
voting rights speak for themselves. all other respects, Defendant-Intervenors deny
the allegations paragraph and all its subparts.
 Passage 589 was Motivated Discriminatory Purpose 
80.
Defendant-Intervenors deny the allegations paragraph 80.
81.
Defendant-Intervenors admit that the legislation adopted 2005 speaks
for itself. all other respects, Defendant-Intervenors deny the allegations paragraph
81.
82.
 
Defendant-Intervenors deny the allegations paragraph 82. 
Case 1:13-cv-00861-TDS-JEP Document 26-1 Filed 12/10/13 Page
83.
Defendant-Intervenors deny the allegations paragraph 83.
84.
Defendant-Intervenors deny the allegations paragraph 84.
85.
Defendant-Intervenors admit that the number and race voters during
the 2008 and 2012 general election are matters public record and that the enacted
legislation and the decision Shelby County Holder speak for themselves. all
other respects, Defendant-Intervenors deny the allegations paragraph 85.
86.
Defendant-Intervenors admit that the Chairman the Senate Rules
Committee stated that the decision Shelby County clarified the applicable legal
standards. all other respects, Defendant-Intervenors deny the allegations
paragraph 86.
87.
Defendant-Intervenors admit that the legislative record speaks for itself. all other respects, Defendant-Intervenors deny the allegations paragraph 87.
88.
Defendant-Intervenors admit that amendments offered during the
legislative process speak for themselves. all other respects, Defendant-Intervenors
deny the allegations paragraph 88.
89.
Defendant-Intervenors deny the allegations paragraph 89.
90.
Defendant-Intervenors admit that decisions North Carolina courts that
address the presence racially polarized voting North Carolina speak for
themselves. all other respects, Defendant-Intervenors deny the allegations
paragraph 90.
91.
 
Defendant-Intervenors deny the allegations paragraph 91. 
Case 1:13-cv-00861-TDS-JEP Document 26-1 Filed 12/10/13 Page
92.
Defendant-Intervenors deny the allegations paragraph 92.
 The Need for Section 3(c) Relief 
93.
Defendant-Intervenors deny the allegations paragraph 93.
94.
Defendant-Intervenors deny the allegations paragraph 94.
 CAUSE ACTION
Section the Voting Rights Act 
95.
Defendant-Intervenors reallege and incorporate reference their
responses paragraphs 1-94.
96.
Defendant-Intervenors admit that the cited statute speaks for itself. all
other respects, Defendant-Intervenors deny the allegations paragraph 96.
97.
Defendant-Intervenors deny the allegations paragraph 97.
98.
Defendant-Intervenors deny the allegations paragraph 98.
99.
Defendant-Intervenors deny the allegations paragraph 99.
100.
Defendant-Intervenors deny the allegations paragraph 100.
SECOND DEFENSE
Any allegations paragraphs 1-100 the complaint not specifically admitted
are denied.
THIRD DEFENSE
The Attorney General the United States has standing assert claims
under the Fourteenth Fifteenth Amendments the plaintiff may not press
claim which only aggrieved person may press. 
Case 1:13-cv-00861-TDS-JEP Document 26-1 Filed 12/10/13 Page
FOURTH DEFENSE
Plaintiff discriminatory result claim for relief under Section the Voting
Rights Act fails state claim upon which relief can granted and should
dismissed, pursuant Rule 12(b)(6), Fed. Civ. prove discriminatory result
claim under Section the Voting Rights Act, plaintiff required prove that
enforcement the challenged provisions 589 causally related actual,
racially discriminatory result harming the voting rights African Americans.
relevant and material proof whether the enforcement the challenged provisions 589 will actually cause racially discriminatory result harming African American
voters presently available. Further, such evidence will become available until
sufficient number elections have been held which these challenged procedures are
enforced. Therefore, present plaintiff claims are not ripe for adjudication required Article III the Constitution the United States.
FIFTH DEFENSE
Plaintiff discriminatory purpose claims for relief under the Fourteenth and
Fifteenth Amendments and under Sections and 3(c) the Voting Rights Act fail
state claim upon which relief can granted and should dismissed, pursuant Rule
12(b)(6), Fed. Civ. prove discriminatory intent claim under the Fourteenth and
Fifteenth Amendments and under Sections and 3(c) the Voting Rights Act, plaintiff required prove that enforcement the challenged provisions 589 causally
related actual, minimis, racially discriminatory effect harming the voting rights 
Case 1:13-cv-00861-TDS-JEP Document 26-1 Filed 12/10/13 Page African Americans. relevant and material proof whether the enforcement the
challenged provisions House Bill 589 will, fact, have actual racially
discriminatory effect harming African American voters presently available. Further, such evidence will become available until sufficient number elections have been
held which these challenged procedures are enforced. Therefore, present plaintiff
claims are not ripe for adjudication required Article III the Constitution the
United States.
SIXTH DEFENSE the event that the required showing causal connection between the
challenged provisions 589 and actual, racially discriminatory result effect
harming the voting rights African Americans, described the Fourth and Fifth
Defenses, not made plaintiff, any remedy provided plaintiff would violate the
Equal Protection rights Defendant-Intervenors.
SEVENTH DEFENSE
Plaintiff claim for relief under Section 3(c) the Voting Rights Act fails
state claim upon which relief can granted and should dismissed, pursuant
Rule 12(b)(6), Fed. Civ. P., that plaintiff has not alleged violation the
Fourteenth Fifteenth Amendments the Constitution the United States for the
reasons set forth the Fifth Defense.
EIGHTH DEFENSE
Plaintiff claim for relief under Section 3(c) the Voting Rights Act fails 
Case 1:13-cv-00861-TDS-JEP Document 26-1 Filed 12/10/13 Page
state claim upon which relief can granted and should dismissed, pursuant
Rule 12(b)(6), Fed. Civ. P., that relies, part, upon North Carolina past
history racial discrimination against African American voters. Under the ruling
Shelby County Holder, reliance upon past acts racial discrimination that are
unrelated current conditions cannot constitutionally serve any longer basis for the
federal government intrusion into State administration its own elections under the
Voting Right Act.
NINTH DEFENSE
Plaintiff claims for relief under the Fourteenth and Fifteenth Amendments and
under Sections and 3(c) the Voting Rights Act fail state claim upon which relief
can granted and should dismissed, pursuant Rule 12(b)(6), Fed. Civ. P., the
extent that this complaint seeks rely upon any factual assertion concerning, obtain
any relief for, voters who are members language minority group, defined the
Voting Rights Act. See Complaint the United States, Prayer for Relief, pp. 30-31.
This complaint contains factual allegations that any the challenged voting practices
discriminate against persons the basis their membership language minority
group. The allegations are limited those concerning alleged racial discrimination
against African American voters. Therefore, the proof this case and the relief, any
granted, should limited African American voters. 
Case 1:13-cv-00861-TDS-JEP Document 26-1 Filed 12/10/13 Page
WHEREFORE, Defendant-Intervenors move the court:
that plaintiff complaint dismissed with prejudice and that judgment
entered for the Defendant-Intervenors all claims;
that Defendant-Intervenors awarded their attorneys fees and costs; and
that Defendant-Intervenors awarded such other and further relief the
Court may deem just and proper.
Respectfully submitted this 10th day December, 2013.
JOHNSON LAW FIRM, P.A.
By:
/s/ Gene Johnson
Gene Johnson
State Bar No. 15917
P.O. Box 1288
Arden, North Carolina 28704
Telephone: (828) 650-0859
Facsimile: (828) 650-0913
Email: gbj@johnsonlawnc.com
Robert Popper
New York Bar No. 2357275
JUDICIAL WATCH, INC.
425 Third Street,
Washington, D.C. 20024
Telephone: (202) 646-5173
Facsimile: (202) 646-5199
Email: rpopper@judicialwatch.org
(appearing pursuant Local Rule
83.1(d)) Christopher Coates
South Carolina Bar No. 80853
LAW OFFICE CHRISTOPHER COATES
934 Compass Point
Charleston, South Carolina 29412 
Case 1:13-cv-00861-TDS-JEP Document 26-1 Filed 12/10/13 Page
Telephone:(843) 609-7080
Email: curriecoates@gmail.com
(appearing pursuant Local Rule
83.1(d))
Attorneys for Defendant-Intervenors
Christina Gallegos-Merrill and
Judicial Watch, Inc. 
Case 1:13-cv-00861-TDS-JEP Document 26-1 Filed 12/10/13 Page



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