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Brief of (ACORN unit) Project Vote as Amicus Curiae in Support of Appellant Amy Adele Busefink

Brief of (ACORN unit) Project Vote as Amicus Curiae in Support of Appellant Amy Adele Busefink

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Published by Matthew Vadum
This legal document is called Brief of Project Vote as Amicus Curiae in Support of Appellant Amy Adele Busefink, dated July 8, 2011. Busefink, an employee of Project Vote, the unit of ACORN that Barack Obama worked for in 1992, was convicted in early 2011 of "compensation for registration of voters," which is a species of voter fraud under Nevada law. Project Vote filed this brief in support of Busefink's appeal. The court file may be viewed online at http://tinyurl.com/8a8bngl Oral arguments in the appeal before the Supreme Court of Nevada were completed June 14, 2012 and as of today, July 11, 2012, a decision was pending.

Matthew Vadum (matthewvadum.com) is the author of Subversion Inc.: How Obama's ACORN Red Shirts are Still Terrorizing and Ripping Off American Taxpayers (WND Books, 2011)
This legal document is called Brief of Project Vote as Amicus Curiae in Support of Appellant Amy Adele Busefink, dated July 8, 2011. Busefink, an employee of Project Vote, the unit of ACORN that Barack Obama worked for in 1992, was convicted in early 2011 of "compensation for registration of voters," which is a species of voter fraud under Nevada law. Project Vote filed this brief in support of Busefink's appeal. The court file may be viewed online at http://tinyurl.com/8a8bngl Oral arguments in the appeal before the Supreme Court of Nevada were completed June 14, 2012 and as of today, July 11, 2012, a decision was pending.

Matthew Vadum (matthewvadum.com) is the author of Subversion Inc.: How Obama's ACORN Red Shirts are Still Terrorizing and Ripping Off American Taxpayers (WND Books, 2011)

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Published by: Matthew Vadum on Jul 11, 2012
Copyright:Public Domain

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FILED
JUL 0 8 2011
TRACIE K. LINDEMAN
U41 • SUMBAR
t -
IIEPU
BY
AMY ADELE BUSEFINK
Appellant,
))))
)
)
)
))
S.C. Case No. 57579
.
STATE OF NEVADARespondent.
David 0. Stewart
D.C. Bar # 336339 (appearing
pro hac vice
underNevada Supreme Court Rule 42, motion pending)Ropes & Gray LLPOne Metro Center700 12th Street, NW, Suite 900Washington, DC 20005-3948(202) 508-4610Allen LichtensteinNV Bar #39923315 East Russell Road #222Las Vegas, NV 89120-3459(702)433 2666Counsel for Amicus Project Vote
IN THE SUPREME COURT OF THE STATE OF NEVADA
BRIEF OF PROJECT VOTE AS AMICUS CURIAE IN SUPPORT OF APPELLANTAMY ADELE BUSEFINK AND REVERSAL OF HER CONVICTIONBEFORE THE EIGHT JUDICIAL DISTRICT COURT
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L40-
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Docket 57579 Document 2011-19127
 
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TABLE OF CONTENTS
Statement of Identity and Interest
1
Facts
1
Argument
 
A. N.R.S. 293.805 does not apply to productivity bonuses paid to hourly
workers.
 
B. N.R.S. 293.805 does not apply to registration canvassing
 
C.As applied to Ms. Busefink, N.R.S. 239.805 is unconstitutionally vagueand impermissibly chills political speech about voter registration
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D.
The trial court's application of N.R.S. 293.805 impermissibly stifles
political speech based on content
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Conclusion
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TABLE OF AUTHORITIES
Page(s)
CASES
Chanos v. State,
181 P.3d 675 (Nev. 2008)
 
Citizens United v. Fed. Election Comm 'n,
130 S. Ct. 876 (2010)
11, 12, 13
Connally v. Gen. Constr. Co.,
269 U.S. 385 (1926)
11
Crawford v. Marion County Election Bd.,
553 U.S. 181 (2008)
 
Gross v. FBL Fin. Servs.,
129 S. Ct. 2343 (2009)
 
Independence Inst. v. Buescher,
718 F. Supp. 2d 1257 (D. Colo. 2010)
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Leocal v. Ashcroft,
543 U.S. 1 (2004)
 
Meyer v. Grant,
486 U.S. 414 (1988)
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Moore v. State,
126 P.3d 508 (Nev. 2006)
, 9
Nev. Comm 'n on Ethics v. Carrigan,
2011 U.S. LEXIS 4379 (U.S. June 13, 2011)
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Skilling v. United States,
130 S. Ct. 2896 (2010)
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State v. Catanio,
102 P.3d 588 (2004)
 
United States v. McGoff,
831 F.2d 1071 (D.C. Cir. 1987)
 
United States v. Playboy Entm't Grp.,
529 U.S. 803 (2000)
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STATUTES
42 U.S.C. § 1973gg (2011)
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42 U.S.C. § 15483 (2008)
, 9, 10
N.R.S. 293.055 (2008)
 
N.R.S. 293.090 (2008)
 
N.R.S. 293.457 (1960) (repealed 1993)
 
N.R.S. 293.505 (2008)
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