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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

STATE OF FLORIDA, Plaintiff, v. UNITED STATES OF AMERICA and ERIC H. HOLDER, JR., in his official capacity as Attorney General, Defendants, and NATIONAL COUNCIL OF LA RAZA Raul Yzaguirre Building 1126 16th Street, NW, Suite 600 Washington, DC 20036-4845, and LEAGUE OF WOMEN VOTERS OF FLORIDA 540 Beverly Court Tallahassee, FL 32301-2506 Proposed DefendantIntervenors. No. 1:11-cv-1428-CKK-MG-ESH Judges Kollar-Kotelly, Garland & Huvelle

APPLICANTS MOTION TO INTERVENE AS DEFENDANTS Pursuant to Fed. R. Civ. P. 24, National Council of La Raza and the League of Women Voters of Florida (Applicants) respectfully move to intervene in this case as party defendants. Pursuant to Local Civil Rule 7(j), a copy of the Complaint (ECF No. 1), which sets forth the claims for which intervention is sought, is attached as Exhibit 1. Applicants proposed Answer to that Complaint is attached at Exhibit 2.

For the reasons set forth in the accompanying memorandum, Applicants are entitled to intervention as of right under Fed. R. Civ. P. 24(a); in the alternative, this Court should permit Applicants to intervene permissively under Fed. R. Civ. P. 24(b). Pursuant to Local Civil Rule 7(m), the undersigned states that Applicants have conferred with Plaintiffs attorneys, who advised that they oppose intervention, either as of right or permissively, by Applicants. Counsel for the Applicants also conferred with Defendants attorneys, who advised that they do not oppose permissive intervention. Dated: September 9, 2011 Respectfully submitted, /s/ Mark A. Posner . Jon Greenbaum (D.C. Bar No. 489887) Mark A. Posner (D.C. Bar No. 457833) LAWYERS COMMITTEE FOR CIVIL RIGHTS UNDER LAW 1401 New York Avenue, NW, Suite 400 Washington, D.C. 20005 (202) 662-8389 (phone) (202) 628-2858 (fax) mposner@lawyerscommittee.org /s/ Lee Rowland______________ Wendy Weiser (Pro Hac Vice to be sought) Lee Rowland (Pro Hac Vice to be sought) THE BRENNAN CENTER FOR JUSTICE AT NYU LAW SCHOOL 161 Avenue of the Americas, Floor 12 New York, NY 10013-1205 (646) 292-8310 (phone) (212) 463-7308 (fax) Lee.Rowland@nyu.edu

/s/ Daniel C. Schwartz_______ Daniel C. Schwartz (D.C. Bar No. 017749) Rodney F. Page (D.C. Bar No. 037994) Alec W. Farr (D.C. Bar No. 440046) Daniel T. OConnor (D.C. Bar No. 975165) Ian L. Barlow (D.C. Bar No. 998500) BRYAN CAVE LLP 1155 F Street, NW, Suite 700 Washington, D.C. 20004 (202) 508-6000 (phone) (202) 508-6200 (fax) dcschwartz@bryancave.com CERTIFICATE OF SERVICE I certify that on September 9, 2011, I filed and served the foregoing Motion to Intervene (including Exhibits 1 and 2 thereto), a supporting memorandum (including Exhibit A thereto), a proposed order, a Local Civil Rule 7.1 certificate, notices of appearance, and motions for admission pro hac vice by emailing PDF copies of the same to the Clerks Office (dcd_cmecf@dcd.uscourts.gov) and the following counsel: Daniel Nordby (daniel.nordby@dos.myflorida.com) Ashley Davis (ashley.davis@dos.myflorida.com) Florida Department of State Elise S. Shore (elise.shore@usdoj.gov) John A. Russ (john.russ@usdoj.gov) U.S. Department of Justice, Civil Rights Division, Voting Section Estelle H. Rogers (erogers@projectvote.org) Project Vote Arthur B. Spitzer (art@aclu-nca.org) American Civil Liberties Union of the Nations Capital M. Laughlin McDonald (Lmcdonald@aclu.org) American Civil Liberties Union Foundation, Inc. Randall Marshall (Rmarshall@aclufl.org) American Civil Liberties Union Foundation of Florida, Inc. /s/ Daniel T. OConnor___________