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Judicial Watch • Motion for Intervention (U.S. v. North Carolina Board of Elections and Kim Starch (1:13 CV 861))

Motion for Intervention (U.S. v. North Carolina Board of Elections and Kim Starch (1:13 CV 861))

Motion for Intervention (U.S. v. North Carolina Board of Elections and Kim Starch (1:13 CV 861))

Page 1: Motion for Intervention (U.S. v. North Carolina Board of Elections and Kim Starch (1:13 CV 861))

Category:Legal Document

Number of Pages:3

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.
1:13cv861 (TDS-JEP)
MOTION FOR INTERVENTION CHRISTINA KELLEY
GALLEGOS-MERRILL AND JUDICIAL WATCH, INC.
Proposed Defendant-Intervenors Christina Gallegos-Merrill, and Judicial
Watch, Inc., behalf its members and its own behalf (collectively with Merrill,
the Intervenors and through Counsel, respectfully move this Court, pursuant
Fed. Civ. 24(a)(2) and (b), for entry Order granting the Intervenors 
motion for intervention. support this motion, the Intervenors have filed
memorandum law support, and have attached proposed answer intervention, the
declarations Christina Gallegos-Merrill and Thomas Fitton, and proposed order.
For the reasons set forth the memorandum law and accompanying declarations, the Intervenors respectfully request that their motion granted. The current
defendants, and through counsel, have communicated the Intervenors that
they not oppose this motion.
Case 1:13-cv-00861-TDS-JEP Document Filed 12/10/13 Page
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
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 Filed 12/10/13 Page
CERTIFICATE SERVICE hereby certify that this 10th day December, 2013, transmitted the
foregoing document the named parties emails means electronic filing
pursuant the ECF system.
/s/ Gene Johnson
Gene Johnson
Case 1:13-cv-00861-TDS-JEP Document Filed 12/10/13 Page