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Motion to Intervene - Ex 2 - Proposed Answer

Motion to Intervene - Ex 2 - Proposed Answer

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Published by: The Brennan Center for Justice on Sep 09, 2011
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09/09/2011

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Exhibit 2
 
 
IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF COLUMBIASTATE OF FLORIDA,Plaintiff,v.UNITED STATES OF AMERICA andERIC H. HOLDER, JR.,in his official capacity as Attorney General,Defendants,andNATIONAL COUNCIL OF LA RAZA andLEAGUE OF WOMEN VOTERS OFFLORIDA,Proposed Defendant-Intervenors.No. 1:11-cv-1428-CKK-MG-ESHJudges Kollar-Kotelly, Garland & Huvelle[PROPOSED]
DEFENDANT-INTERVENORS’ ANSWER TO THECOMPLAINT FOR DECLARATORY RELIEF
 Defendant-Intervenors National Council of La Raza and the League of Women Voters of Florida, by their undersigned legal counsel, submit the following Answer in response to theComplaint for Declaratory Relief (“the Complaint”) (ECF No. 1) filed in this matter by the Stateof Florida (“Florida”).1.
 
Defendant-Intervenors admit the allegations in paragraph 1 to the extent that theyidentify the Plaintiff and that the Voting Rights Act (“VRA”) authorizes Florida to bring a claimseeking VRA Section 5 (“Section 5”) preclearance before this Court.2.
 
Defendant-Intervenors admit the allegations in paragraph 2.
 
23.
 
Defendant-Intervenors admit the allegations in paragraph 3, except to the extentthat they suggest that only the United States of America and Attorney General are authorized todefend a Section 5 declaratory judgment action in this Court. Defendant-Intervenors aver thatcitizens and organizations in Section 5 jurisdictions are frequently permitted to intervene asdefendants in Section 5 declaratory judgment actions.4.
 
Defendant-Intervenors deny that the provisions of Chapter 2011-40, Laws of Florida (the “Act”), for which Florida seeks a declaratory judgment in this lawsuit, are effectiveas law in the Florida counties covered by Section 5, and otherwise admit the allegations inparagraph 4.5.
 
Defendant-Intervenors admit the allegations in paragraph 5.6.
 
The allegations in paragraph 6 are statements of law and/or conclusions of law towhich no response is required. If deemed to allege facts, Defendant-Intervenors admit theallegations in paragraph 6.7.
 
Defendant-Intervenors admit the allegations in paragraph 7, except that the datefor determining Section 5 coverage, with regard to voter registration rates in Florida counties in1972, is November 1, 1972.8.
 
The allegations in paragraph 8 are statements of law and/or conclusions of law towhich no response is required. If deemed to allege facts, Defendant-Intervenors admit theallegations in paragraph 8 to the extent that the five Florida counties named in paragraph 6continue to be covered jurisdictions under Section 5.9.
 
The allegations in paragraph 9 are statements of law and/or conclusions of law towhich no response is required. If deemed to allege facts, Defendant-Intervenors admit theallegations in paragraph 9.

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