1

IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF NORTH CAROLINA
CHARLOTTE DIVISION
3:14-cv-00213-RJC-DCK

GENERAL SYNOD OF THE UNITED CHURCH )
OF CHRIST; REVEREND JOSEPH HOFFMAN; )
REVEREND NANCY ELLETT ALLISON; )
REVEREND NATHAN KING; REVEREND )
NANCY KRAFT; RABBI JONATHAN )
FREIRICH; REVEREND ROBIN TANNER; )
REVEREND MARK WARD; REVEREND DR. )
NANCY E. PETTY; KAY DIANE ANSLEY; )
CATHERINE ―CATHY‖ McGAUGHEY; )
ELIZABETH ―LISA‖ CLONINGER; )
KATHLEEN SMITH; SHAUNA BRAGAN; )
STACY MALONEY; CATHY FRY; JOANNE )
MARINARO; JOEL BLADY; JEFFREY ADDY; )
BETTY MACK; and CAROL TAYLOR; )
)
Plaintiffs, )
) RESPONSE TO MOTION FOR
) PRELIMINARY INJUNCTION
v. )
)
ROY COOPER, ATTORNEY GENERAL OF )
NORTH CAROLINA; DREW REISINGER, )
REGISTER OF DEEDS FOR BUNCOMBE )
COUNTY; WAYNE NIXON, REGISTER OF )
DEEDS FOR CABARRUS COUNTY; TONIA )
HAMPTON, REGISTER OF DEEDS FOR )
McDOWELL COUNTY; J. DAVID )
GRANBERRY, REGISTER OF DEEDS FOR )
MECKLENBURG COUNTY; LAURA M. )
RIDDICK, REGISTER OF DEEDS FOR WAKE )
COUNTY; RONALD L. MOORE, BUNCOMBE )
COUNTY DISTRICT ATTORNEY; ROXANN )
VANEEKHOVEN, CABARRUS COUNTY )
DISTRICT ATTORNEY; BRADLEY )
GREENWAY, McDOWELL COUNTY )
DISTRICT ATTORNEY; ANDREW MURRAY, )
MECKLENBURG COUNTY DISTRICT )
ATTORNEY; and NED MANGUM, WAKE )
COUNTY DISTRICT ATTORNEY; )
)
Defendants. )
Case 3:14-cv-00213-RJC-DCK Document 58 Filed 06/10/14 Page 1 of 15
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NOW COMES defendant Laura M. Riddick, Register of Deeds of Wake County
[hereinafter ―Riddick‖], through undersigned counsel, and pursuant to LCvR 7.1(E), and hereby
responds to the plaintiffs’ motion for preliminary injunction [DE 3], and says as follows:
Preliminary Statement of Position
Defendant Laura M. Riddick has been sued in her official capacity as Register of Deeds
of Wake County. Wake County is the capital county of North Carolina and the second largest
county by population. Mrs. Riddick initially desires to note that it is her belief and position that
this lawsuit raises issues that are beyond the scope of the duties and role of the Register of Deeds
in this state. The office of the Register of Deeds is created by Chapter 161 of the North Carolina
General Statutes. The Registers of Deed’s duties and responsibilities as elected officials are
specifically enumerated in that chapter. While those duties are ministerial in nature, the duties
performed are an indispensible and vital part of all North Carolina record keeping processes.
These duties include registration of legal instruments, public records, and vital records as well as
real estate document registration and indexing. The ―ministerial duty‖ which brings the Register
of Deeds in this dispute is the statutory duty that the Register of Deeds issue marriage licenses.
The Register of Deeds does not set state policy or advocate for political, economic or
social issues one way or the other. The Register of Deeds is to perform the duties of that office
impartially, neutrally and in compliance with then existing law. Therefore, defendant Riddick
takes no position on the policy considerations raised by this lawsuit. She does assert a legal
position, and this position has at its foundation the idea that the issue of whether North Carolina
should permit issuance of same gender marriage licenses is a question for the legislature, the
state or federal courts or the people – or a combination of either or all. It is not a question for the
one hundred different Registers of Deeds in this state. Therefore, no response of this party in this
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litigation should be interpreted as a policy position on any issue raised herein. Indeed this
defendant does not propound any political or social position for or against same gender marriage
by way of any response to this lawsuit.
Finally, Defendant Riddick does believe strongly in two (2) guiding principles. The first
principle is that the Registers of Deeds are not the proper parties to a constitutional challenge to
North Carolina’s Marriage laws. The second principle is that she and her staff will continue to
faithfully execute the law as it is and, if changed definitively by the courts, the legislature or the
people - that she and her staff faithfully execute the law as it will be once the legal or political
process, or both, has concluded. If plaintiffs are successful in this motion or the litigation
ultimately, Defendant Riddick advises the Court that it would be preferable to have some
flexibility in timing to allow for technical, administrative and software changes to allow for a
smooth transition in the marriage licensing process.
Defendant Riddick can and does promise the courts and the citizens that wherever the
process ends and whatever the outcome, she will, in conformity with her oath and baring
allegiance to her statutory duties, faithfully carry out and uphold the law.
RESPONSE TO PLAINTIFFS’ MOTION FOR PRELIMINARY INJUNCTION
Defendant Riddick, responding to the legal arguments raised by the plaintiffs’ Motion for
Preliminary Injunction pursuant to Fed .R. Civ. P. 65(a) , says as follows:
a. The plaintiffs have not made a showing that it is “clear” that they are likely to prevail
on the merits.

A preliminary injunction is ―an extraordinary remedy ... which is to be applied only in
limited circumstances which clearly demand it.‖ Direx Israel, Ltd. v. Breakthrough Med. Corp.,
952 F.2d 802, 811 (4th Cir.1991) The traditional purpose of a preliminary injunction is to
―protect the status quo and to prevent irreparable harm during the pendency of a lawsuit
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ultimately to preserve the court's ability to render a meaningful judgment on the merits.‖ In re
Microsoft Corp. Antitrust Litig., 333 F.3d 517, 525 (4th Cir.2003). Before a court may enter a
preliminary injunction, a plaintiff ―must establish [1] that he is likely to succeed on the merits,
[2] that he is likely to suffer irreparable harm in the absence of preliminary relief, [3] that the
balance of equities tips in his favor, and [4] that an injunction is in the public interest.‖ WV Ass'n
of Club Owners & Fraternal Servs., Inc. v. Musgrave, 553 F.3d 292, 298 (4th Cir.2009) (quoting
Winter v. Natural Res. Def. Council, Inc., 555 U.S. 7, 129 S.Ct. 365, 172 L.Ed.2d 249 (2008)).
The burden is on the party seeking a preliminary injunction to demonstrate by a ―clear showing‖
that she is entitled to such relief. See, e.g., The Real Truth About Obama, Inc. v. Fed. Election
Comm'n, 575 F.3d 342, 345–46 (4th Cir.2009).
A preliminary injunction is an extraordinary remedy never awarded as of right. Munaf,
553 U.S., at 689-690, 128 S.Ct., at 2218–2219. In each case, courts ―must balance the competing
claims of injury and must consider the effect on each party of the granting or withholding of the
requested relief.‖ Amoco Production Co., 480 U.S., at 542, 107 S.Ct. 1396. ―In exercising their
sound discretion, courts of equity should pay particular regard for the public consequences in
employing the extraordinary remedy of injunction.‖ Romero–Barcelo, 456 U.S., at 312, 102
S.Ct. 1798.
By this motion, plaintiffs do not seek to preserve the status quo. They seek a mandatory
injunction, rather than a prohibitory injunction and the effect of a mandatory injunction upon the
relief sought would be tantamount to partial victory on the merits of the lawsuit. The Fourth
Circuit has held that the authority of the district court to issue a preliminary injunction, especially
a mandatory one should be sparingly exercised. Mandatory preliminary injunctions do not
preserve the status quo and normally should be granted only in those circumstances when the
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exigencies of the situation demand such relief. Wetzel v. Edwards, 635 F.2d 283, 286 (4th Cir.
1980). Furthermore, the Fourth Circuit has reiterated that a preliminary injunction may not be
availed of to secure a piecemeal trial. Wetzel v. Edwards, 635 F.2d 283, 286-87 (4th Cir. 1980)
citing Meiselman v. Paramount Film Distributing Corp., 180 F.2d 94, 96 (4th Cir. 1950)
Are plaintiffs likely to prevail on the merits? We contend that an answer to that question
necessary to warrant injunctive relief is not clear given the fast moving, shifting jurisprudential
landscape in the area of constitutional challenges to state laws proscribing same gender
marriages. There has been much litigation in a short period of time on this issue nationwide and
in North Carolina. In their Memorandum in support of the Motion for Preliminary Injunction, the
plaintiffs have divided the likelihood argument into the four categories corresponding to the
Counts in their complaint. In response, we will divide these into two groups, the First
Amendment claims and the Fourteenth Amendment claims. Against this legal backdrop, we
restate the three (3) ―sets‖ of plaintiffs in this litigation.
The first set of plaintiffs consists of a ―religious denomination‖ whose teachings embrace
the relief sought in the complaint. The second set of plaintiffs consists of ministers and clergy
who teach and believe in the principles underlying the relief sought in the complaint. The third
set of plaintiffs consists of same sex couples who wish to marry in the state of North Carolina.
[DE 1, ¶¶ 4 (a), (b) and (c). The relief sought is a declaratory ruling that North Carolina
marriage laws prohibiting same gender marriage be declared unconstitutional and that defendants
be enjoined from adherence or enforcement of the laws.
Plaintiffs characterize North Carolina marriage laws as having three (3) components that
they contend ―create the constitutional issues in this case.‖ These components are 1) laws that
limit marriage to only heterosexual couples; 2) laws that ―deputize‖ ordained ministers to
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solemnize marriages through religious ceremonies to give the marriage a legal effect; and 3) laws
that restrict the ―religious practices‖ of ministers because the minister must have a license issued
by the Register of Deeds, and the ministers in this case desire to solemnize marriages for which a
license is prohibited by law.
i. First Amendment Claims
Plaintiffs’ claims in Count I and Count II of the complaint present a novel
legal challenge to state marriage laws prohibiting same gender marriage. Plaintiffs seek a
declaration that these laws violate the plaintiffs’ right to free exercise of religion by making it a
crime for ministers to perform and solemnize same gender marriage and by restricting the
plaintiffs’ right of expressive association by deputizing clergy to perform opposite sex marriages
but threatening sanctions for solemnizing same gender marriage. Plaintiffs cite no authority on
point for these propositions of law and our research has revealed no reported cases on first
amendment challenges based on First Amendment religion claims to state marriage laws.
1

Free Exercise
Plaintiff first argue that it is clear that they are likely to prevail on the issues that North
Carolina marriage laws infringe on the right to free exercise of religion. Plaintiffs cite the recent
U.S. Supreme Court case of Hosanna-Tabor Evangelical Lutheran Church & Sch. v. E.E.O.C.,
132 S. Ct. 694, 706-07, 181 L. Ed. 2d 650 (2012) for the proposition that the free exercise clause
prohibits the government from ―interfering with an internal church decision that affects the faith
and mission of the church itself.‖ That holding stems from the case of Employment Div., Dept. of
Human Resources of Ore. v. Smith, 494 U.S. 872, 110 S.Ct. 1595, 108 L.Ed.2d 876 (1990). In

1
The Eight Circuit has addressed a Nebraska constitutional amendment prohibiting same gender marriage
or recognition of out of state same gender marriage, reversing the district court and holding that the
Nebraska amendment did not violate the First Amendment right to associate and participate in the
political process. Citizens for Equal Protection v. Bruning, 455 F. 3d 856 (8
th
Cir. 2006)
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Hosanna-Tabor the Supreme Court upheld the ―ministerial exception‖ and barred a claim by the
EEOC and a ―called‖ church minister seeking to sue the church for retaliation because the
minister threatened to bring an American with Disabilities Act action against the church. Chief
Justice Roberts, writing for the Court, seem to narrow the scope of that case when he concluded
the opinion by saying
The case before us is an employment discrimination suit brought on behalf of a minister,
challenging her church's decision to fire her. Today we hold only that the ministerial
exception bars such a suit.[ ] The interest of society in the enforcement of employment
discrimination statutes is undoubtedly important. But so too is the interest of religious
groups in choosing who will preach their beliefs, teach their faith, and carry out their
mission. When a minister who has been fired sues her church alleging that her
termination was discriminatory, the First Amendment has struck the balance for us. The
church must be free to choose those who will guide it on its way. Hosanna-Tabor
Evangelical Lutheran Church & Sch. v. E.E.O.C., 132 S. Ct. 694, 710, 181 L. Ed. 2d 650
(2012)
It is true that the U.S. Supreme Court has long recognized that the Religion Clauses
protect a private sphere within which religious bodies are free to govern themselves in
accordance with their own beliefs. The Constitution guarantees religious bodies ―independence
from secular control or manipulation—in short, power to decide for themselves, free from state
interference, matters of church government as well as those of faith and doctrine.‖ Kedroff v.
Saint Nicholas Cathedral of Russian Orthodox Church in North America, 344 U.S. 94, 116, 73
S.Ct. 143, 97 L.Ed. 120 (1952).‖ However, when religious beliefs run afoul of state laws
criminalizing certain actions, the free exercise argument has given way. For example, in the
Employment Div., Dept. of Human Resources of Ore. v. Smith case, the Supreme Court rejected a
free exercise claim by members of a Native American church who were fired and denied
unemployment benefits for misconduct because they had ingested peyote during a religious ritual
on their church.
2
The Supreme Court held that the ―right of free exercise does not relieve an

2
At that time, peyote was defined as an illegal controlled substance in Oregon.
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individual of the obligation to comply with a valid and neutral law of general applicability on the
ground that the law proscribes (or prescribes) conduct that his religion prescribes (or
proscribes).‖ Id., at 879, 110 S.Ct. 1595.
Plaintiffs contend in the motion for preliminary injunction that the marriage laws in
North Carolina are not neutral because ―of their impact on religious practice.‖ However, federal
jurisprudence on the issue of neutrality of a statute would not support this assertion. ―If the
object of a law is to infringe upon or restrict practices because of their religious motivation, the
law is not neutral.‖ Church of the Lukumi Babalu Aye, Inc. v. City of Hialeah, 508 U.S. 520, 533,
113 S. Ct. 2217, 2227, 124 L. Ed. 2d 472 (1993). Thus, it would seem that to prevail on this
issue, plaintiffs would, at this premature stage, have to show that the ―object‖ of marriage laws in
this state are to restrict ordained clergy from solemnizing marriage through religious ceremonies
to give legal effect to the marriage as required by N.G.G.S. § 51.1. We do not believe such
showing can be made at this time.
In an effort to paint this hot button political issue as a religious one, Plaintiffs point to the
debate over Amendment One as being ―rife with evidence of . . . imposition of majority views on
those who express different religious beliefs.‖ Interestingly, the various quotes on page nineteen
(19) of the memorandum in support of the injunction all reflect statements made by 1) members
of the North Carolina General Assembly who are 2) all Republicans and who 3) made these
statements in support of Amendment One before the election. Whatever side one is on the issue
of same gender marriage, it is clear from the context that these quotes were made in the throes of
a contentious political debate, not a religious debate. It is also important to note that such
―religious‖ underpinnings are attributable to the statutes which plaintiffs challenge, only
Amendment One, a referendum subject to a statewide vote of the voters of North Carolina.
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Expressive Association
Plaintiffs contend that it is clear that there is a likelihood of prevailing on the claim that
the marriage laws of North Carolina infringe upon their rights of religious expressive association.
The United States Supreme Court has held that implicit in the right to engage in activities
protected by the First Amendment is ―a corresponding right to associate with others in pursuit of
a wide variety of political, social, economic, educational, religious, and cultural ends.‖ Roberts v.
United States Jaycees, 468 U.S. 609, 622, 104 S.Ct. 3244, 82 L.Ed.2d 462 (1984). This right is
crucial in preventing the majority from imposing its views on groups that would rather express
other, perhaps unpopular, ideas. Boy Scouts of Am. v. Dale, 530 U.S. 640, 647-48, 120 S. Ct.
2446, 2451, 147 L. Ed. 2d 554 (2000).
3
Assuming for purposes of this motion that the various
sets of plaintiffs’ beliefs are indeed expressive association, their likelihood of prevailing on this
claim must assume that a proscription on performing a state recognized marriage ceremony of a
same-sex couple prohibits plaintiffs from associating with others in pursuit of their expression
and transmission of a system of values. It does not. It does prohibit their participation in marriage
ceremonies that have been licensed by the State of North Carolina.
Even assuming that the plaintiffs’ contention is true, the inquiry then becomes this - Is it
clear that such a prohibition ―significantly burdens‖ plaintiffs’ right of expression on this issue?
Perhaps plaintiffs may be able to prove that it does at some point, or perhaps they will not.
However, such a contention at this early stage is tenuous. A marriage ceremony is not the only
means for plaintiffs to associate or express their religious, social or political views on this or any
other issue. The prohibition is upon what they concede is, at least in part, a legal proceeding. The
plaintiffs will have the opportunity to have the Court set associational interest in freedom of

3
Boy Scouts of America is cited by plaintiffs but this case is not analogous to the facts of the case sub
judice. Boy Scouts involved force inclusion of persons with differing views of an organization.
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expression ―on one side of the scale and the State’s interest‖ in its marriage laws on the other.
See Boy Scouts of Am. v. Dale, 530 U.S. at 659. However, at this point it is too early for the
Court to balance those issues.
ii. Equal Protection and Due Process Claims
On May 28, 2014 several defendants filed Motions to Stay this action pending
the United States Court of Appeals for the Fourth Circuit’s decision in the case of Bostic vs.
Schaefer, et al, No. 14-1167. [DE Nos. 44 & 47] The Bostic case addresses the same issues as
plaintiff seeks to raise in this action and would present an identical legal analysis as it relates to
plaintiffs’ claims under due process and equal protection. The reasoning offered for the motions
to stay are equally applicable in response to the preliminary injunction as it relates to the
plaintiffs’ claims under equal protection and due process and to that extent, we reincorporate
those arguments herein. As stated in our earlier motion to stay, the issues raised in Bostic are
now being considered by a court with binding precedential authority over the several districts
within its circuit. As we noted then, there is every reason to believe that a decision will come
from the Fourth Circuit without delay because appeal in Bostic was heard on an unprecedented
expedited basis.
b. Plaintiffs seek a mandatory injunction which is unworkable and likely to lead to
confusion and unnecessary legal wrangling in light of the impending decision in the
Fourth Circuit Court of Appeals’ case Bostic v. Schafer, No. 14-1167.

There have been many relevant developments in other Courts across the country which
could have an influence on this litigation. First, the U.S. Supreme Court stayed enforcement of
an injunction similar to the one sought by plaintiffs in this case on January 6, 2014. Also, on
May 13, 2014, the United States Court of Appeals for the Fourth Circuit heard oral arguments in
the case of Bostic vs. Schaefer, et al, No. 14-1167. The Bostic case addresses the exact same
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issues as plaintiff seeks to raise in this action dealing with equal protection and due process
issues applies to very similar statutes and state constitutional provisions prohibiting same gender
marriage. Bostic, and this lawsuit, both come on the heels of the United States Supreme Court’s
decision in United States v. Windsor, ___ U.S. ___, 133 S. Ct. 2675, 186 L.Ed 2d 808 (2013).
Both lawsuits present some of the same legal issues. Both challenge the constitutionality of state
laws which prohibit same gender marriages. A third development is that the Tenth Circuit United
States Court of Appeal heard oral arguments on similar cases on April 10, 2017 (challenge to
Utah’s state marriage laws) and April 17, 2014 (challenge to Oklahoma’s state marriage laws).
In addition to the issues raised in our memorandum in support of the Motion to Stay we
continue to believe that restraint is warranted at this juncture given the fact that all parties are
fully aware that a decision is pending in the Circuit Court with precedential authority which
embraces this jurisdiction and in other circuits. We believe the fact that virtually identical issues
are under consideration by the Fourth Circuit counsels against any type of mandatory injunctive
order in this case at this time.
One needs look no further than Utah for the immense confusion which can follow a
preliminary injunction in a case involving this issue. On December 20, 2013 a United States
District Court issued a ruling enjoining the State of Utah from enforcing statutory and
constitutional laws prohibiting same-sex marriages. Kitchen v. Herbert, 2:13-cv-217-RJS, 2013
WL 6834634 (D. Utah Dec. 23, 2013). The State of Utah failed to request a stay in the event the
Court ruled against their position, and the Court did not stay enforcement of its ruling sua sponte.
Thereafter, the State of Utah sought a stay with the District Court which was denied. The State
sought a stay from the Tenth Circuit Court of Appeals which was denied.
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The State of Utah then sought a stay from the United States Supreme Court on December
31, 2013. The United States Supreme Court granted Utah’s application for a stay of the district
Court’s injunction on January 6, 2014 by Order dated that same day. The Order simply stated:
The application for stay presented to Justice Sotomayor and by her
referred to the Court is granted. The permanent injunction issued
by the United States District Court for the District of Utah, case no.
2:13-cv-217, on December 20, 2013, is stayed pending final
disposition of the appeal by the United States Court of Appeals for
the Tenth Circuit.
By the time The United States Supreme Court’s Order had been entered, the State of Utah had
issued over 1,300 marriage licenses to same-sex couples from December 23, 2013 to January 6,
2014. The Supreme Court Stay did not address the status of those marriages licensed and
solemnized during the period between the trial court ruling and the U S Supreme Court stay.
Predictably, confusion ensued concerning the retroactive effect or lack of effect to be given the
stay order and the status of marriages performed between December 23, 2013 and January 6,
2014 seemed to be in legal limbo.
4

Since then, there have been other developments at the appellate level concerning
injunctive relief and stays regarding this issue. On May 15, 2014, the Ninth Circuit Court of
Appeals, as in the Utah case, stayed enforcement of an injunction striking Idaho’s marriage laws
prohibiting same sex marriage. On June 4, 2014, the United States Supreme Court declined to
stay a ruling in Oregon issued on May 19, 2014 striking down Oregon’s marriage laws on equal
protection and due process grounds. Geiger v. Kitzhaber, No. 6-13-cv-1834-MC, USDC Oregon
(May 19, 2014). However, the procedural posture of that case is vastly different than the Utah
case and this case. In the Oregon case, the State of Oregon sided with the plaintiffs and agreed to

4
On May 19, 2014 the US District Court for Utah ruled in Evans vs State of Utah, 2:14-cv-55-DAK that the State
of Utah was required to recognize those marriages solemnized between December 23, 2013 to January 6, 2014. The
effect of this ruling and whether it will be subject to a stay is unclear as the time for filings post ruling motions has
not expired as of the date of this filing.
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immediately implement the ruling. Thereafter, a private group calling itself the ―National
Organization for Marriage‖ [―NOM‖] sought to intervene to oppose and appeal the ruling at the
last minute (the motion to intervene was filed forty-eight (48) hours before the case was set to be
heard.) Not surprisingly, this motion was denied. NOM thereafter sought a stay with the United
States Court of Appeals for the Ninth Circuit and then from the U.S. Supreme Court.
It is Order denying the application, the U.S. Supreme Court order read simply ―The
application for stay presented to Justice Kennedy and by him referred to the Court is denied.‖ It
did not refer to a preliminary injunction like the Utah stay. The difference between the cases is
that in the Oregon case, 1) the requested stay came from someone who was not a party to the
litigation and 2) the ‖appeal‖ was on the issue of intervention. Thus, regardless of how NOM
couched the request to the Supreme Court, the inquiry should have been whether the
implementation of the District Court’s ruling denying NOM’s intervention should be stayed.
In the case sub judice, plaintiffs seek a preliminary injunction on 1) an issue that has been
argued before the Fourth Circuit and 2) seeks an injunction of the exact nature that was stayed by
the full United States Supreme Court after referral by Justice Sotomayor in the Utah case. It is
unclear what compelling difference plaintiffs can point to in this case that would justify
inconsistent rulings by the United States Supreme Court on the wisdom of a stay on any
preliminary injunction in a case with nearly identical issues and absolutely identical relief
sought. We therefore respectfully urge this Court to decline plaintiffs’ invitation to enter a
preliminary injunction.
CONCLUSION
WHEREFORE, Laura M. Riddick, Register of Deeds of Wake County respectfully prays
the Court deny Plaintiffs’ Motion for Preliminary Injunction; in the event the Court is inclined to
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issue an injunction, she prays that ample time be given to allow compliance with whatever
directive the Court issues; and for such other relief as to the Court may seem just and proper.
Respectfully submitted this the 10
th
day of June 2014.
By: /s/ Scott W. Warren_________________
Scott W. Warren
E-mail: swarren@wakegov.com
State Bar No. 14349
By: /s/ Roger A. Askew_________________
Roger A. Askew
E-mail: Roger.Askew@wakegov.com
State Bar No. 18081

WAKE COUNTY ATTORNEY’S OFFICE
Post Office Box 550
Raleigh, North Carolina 27602
Phone: (919) 856-5500
Fax: (919) 856-5504


























Case 3:14-cv-00213-RJC-DCK Document 58 Filed 06/10/14 Page 14 of 15
15

IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF NORTH CAROLINA
CHARLOTTE DIVISION
3:14-cv-00213-RJC-DCK

GENERAL SYNOD OF THE UNITED CHURCH )
OF CHRIST; et al; )
)
Plaintiffs, )
)
v. ) Certificate of Filing and Service
)
)
ROY COOPER, ATTORNEY GENERAL OF )
NORTH CAROLINA; DREW REISINGER, )
REGISTER OF DEEDS FOR BUNCOMBE )
COUNTY; et al )
Defendants. )

I hereby certify that on June 10, 2014 pursuant to Fed. R. Civ. P. 5(b) and LCvR 5.3, I
electronically filed the foregoing RESPONSE TO MOTION FOR PRELIMINARY
INJUNCTION with the Clerk of Court utilizing the CM/ECF system of the United States District
Court for the Western District of North Carolina that will send electronic notification of such
filing to all registered users who have appeared herein via CM/ECF.



This the 10
th
day of June 2014.
By: /s/ Roger A. Askew
Roger A. Askew
Office of the Wake County Attorney
Post Office Box 550
Raleigh, North Carolina 27602
Phone: (919) 856-5500
Fax: (919) 856-5504
Case 3:14-cv-00213-RJC-DCK Document 58 Filed 06/10/14 Page 15 of 15

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