IN THE UNITED STATES DISTRICT COURTFOR THE SOUTHERN DISTRICT OF MISSISSIPPINORTHERN DIVISIONCAMPAIGN FOR SOUTHERNEQUALITY, ET AL. PLAINTIFFS V. CIVIL ACTION NO. 3:14cv818-CWR-LRA PHIL BRYANT, in his official capacityas Governor of the State of Mississippi,ET AL. DEFENDANTS ______________________________________________________________________________ GOVERNOR PHIL BRYANT’S AND ATTORNEY GENERAL JIM HOOD’S RESPONSE IN OPPOSITION TO PLAINTIFFS’ MOTION FORPRELIMINARY INJUNCTION ______________________________________________________________________________ 

Defendants Phil Bryant, in his official capacity as Governor of the State of Mississippi, and Jim Hood, in his official capacity as Mississippi Attorney General,file this Response in Opposition to Plaintiffs’ Motion for Preliminary Injunction[Docket No. 4] and state:1.On October 20, 2014, Plaintiffs, the Campaign for Southern Equality,Rebecca Bickett, Andrea Sanders, Jocelyn Pritchett, and Carla Webb (collectively“the Campaign”) filed this lawsuit seeking declaratory and injunctive relief againstthe Governor, Attorney General (collectively “the State Defendants”), and the HindsCounty Circuit Clerk and claiming Mississippi Code Section 93-1-1(2) and Article14, Section 263A of the Mississippi Constitution violate the Fourteenth Amendmentof the United States Constitution. Complaint, Docket No. 1. Simultaneously, theCampaign filed its instant motion for a preliminary and immediate injunctionconstituting full and final relief on the merits of its claims. Plaintiffs’ Motion,

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Docket No. 4.2.The Campaign’s motion should be denied for failure to satisfy the fournecessary elements for preliminary injunctive relief. No substantial likelihood of success on the merits has been shown, no threat of immediate and irreparableinjury has been proven, the balance of potential harms favors the defendants, andthe requested preliminary injunctive relief would disserve the public’s interest.3.The State Defendants’ opposition is supported by this Response, theirMemorandum of Authorities submitted contemporaneously with this Response, andthe following exhibits affixed hereto:EXHIBIT “1”:Order in

 Walker v. Mississippi

, Civil Action No.3:04cv140-LS (Apr. 11, 2006); andEXHIBIT “2”:Order in

Walker v. Mississippi

, Civil Action No.3:04cv140-LS (July 25, 2006).FOR THESE REASONS, the State Defendants respectfully request that theCourt enter an order denying the motion for preliminary injunction [Docket No. 4]in its entirety.THIS the 10 day of November, 2014.

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Respectfully submitted,PHIL BRYANT, in his official capacity asGovernor of the State of Mississippi, andJIM HOOD, in his official capacity asMississippi Attorney GeneralBY:JIM HOOD, ATTORNEY GENERALBy:S/Justin L. MathenyJustin L. Matheny (Bar No. 100754)Paul E. Barnes (Bar No. 99107)Office of the Mississippi Attorney GeneralP.O. Box 220Jackson, MS 39202Telephone: (601) 359-3680Facsimile: (601) 359-2003

 jmath@ago.state.ms.us pbarn@ago.state.ms.usCounsel for Defendants Phil Bryant, in hisofficial capacity as Governor of the State of Mississippi, and Jim Hood, in his officialcapacity as Mississippi Attorney General

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing document hasbeen filed electronically with the Clerk of Court using the Court’s ECF system andthereby served on all counsel of record who have entered their appearance in thisaction.THIS the 10 day of November, 2014.

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S/Justin L. MathenyJustin L. Matheny -3-

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