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Motion for Addtional Relief

Motion for Addtional Relief

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USDOJ No determination cop out Ike Brown
USDOJ No determination cop out Ike Brown

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Published by: electionlawcentercom on Jul 14, 2010
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10/25/2012

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IN THE UNITED STATES DISTRICT COURTFOR THE SOUTHERN DISTRICT OF MISSISSIPPIEASTERN DIVISIONUNITED STATES OF AMERICA, ))Plaintiff,))v.) CIVIL ACTION NO. 4:05-cv-33 (TSL/LRA))IKE BROWN, et al.,))Defendants. ))
UNITED STATES’ MOTION FOR ADDITIONAL RELIEFAGAINST DEFENDANTS IKE BROWN AND THE NOXUBEE COUNTYDEMOCRATIC EXECUTIVE COMMITTEE
Plaintiff United States of America respectfully moves this Court to enter additional relief,pursuant to this Court’s June 29, 2007 Memorandum Opinion and Order and its August 27, 2007Remedial Order. The United States requests that the Court order the following additional relief:1.Defendant Brown and Defendant Noxubee County Democratic ExecutiveCommittee (“NDEC”), their agents, employees, contractors, successors, and all other personsrepresenting the interests of the Defendants should be enjoined from implementing their “Motionto close Democratic Primary,” submitted by Defendants to the Attorney General for preclearanceunder Section 5 of the Voting Rights Act. (A copy of the Defendants’ submission of the “Motionto close Democratic Primary” is annexed hereto as Exhibit A. A copy of the response letter of the Attorney General is annexed as Exhibit B. Also annexed hereto as Exhibit C is a true andcorrect copy of the Declaration of Scott Boyd, executed July 9, 2010, with Attachment A.)2.While this Remedial Order is in effect, any further efforts to seek preclearanceunder Section 5 of the Voting Rights Act for voting changes to be implemented in the
Case 4:05-cv-00033-TSL-LRA Document 287 Filed 07/13/10 Page 1 of 4
 
Democratic Party primary and runoff elections in Noxubee County must be submitted throughthe Referee-Administrator, since “all electoral duties of the Chairman of the Noxubee CountyDemocratic Executive Committee and the Noxubee County Democratic Executive Committeeshall be executed by the Referee-Administrator, with advice and assistance from the NoxubeeCounty Democratic Executive Committee as he deems appropriate.”
United States v. Ike Brown
,2007 WL 2461965, *1 ¶ 4 (S.D. Miss.).3.The terms of the Court’s original Remedial Order, as well as any amendments tothat Remedial Order, should be extended until November 20, 2013.4.The arguments and legal authority supporting the United States’ motion are setforth in the accompanying United States’ Memorandum of Law in Support of its Motion forAdditional Relief Against Defendants Ike Brown and the Noxubee County DemocraticExecutive Committee.2
Case 4:05-cv-00033-TSL-LRA Document 287 Filed 07/13/10 Page 2 of 4
 
DON BURKHALTERActing United States AttorneySouthern District of MississippiRespectfully Submitted,THOMAS E. PEREZAssistant Attorney GeneralCivil Rights Division
/s/ Joshua L. Rogers
_______________________________T. CHRISTIAN HERREN JRROBERT POPPERJOSHUA L. ROGERSAttorneys, Voting SectionCivil Rights DivisionU.S. Department of JusticeRoom 7255 - NWB950 Pennsylvania Ave. NWWashington, D.C. 20530 joshua.rogers@usdoj.govTel: (202) 514-8201Fax: (202) 307-3961Date: July 13, 20103
Case 4:05-cv-00033-TSL-LRA Document 287 Filed 07/13/10 Page 3 of 4

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