ô9
-
9l
iF
õl
:+
::
I
*i3-
I Td6Õ
F
I Hì:q
i rq -ôl
"./
f
oe
Ps
Q
t
>4.¿¿
'- I ) b.'e
Tl
jÊ
UDI
Êä
ô
1
2
a
J
4
5
67
8
9
10
11
t2
13
t4
15
16
t7
18
t9
20
2l
22
23
24
2526
27
28
ç
o
Brett W.
Johnsort
(#021527)Colin
P.
Ahler
(#023879)Andrew
M.
Sniègowski (#031664)Lindsay
Short
(#034125)SNELÉ
&
WILMER
L.L.P.
One
Arizona
CenterE-
T
asnl
Attorneys
for
400
E.
Van
Buren,Suire
1900
Phoenix,
Arizona
85004-2202
602.3
82.6000
w
w.com
ffs
IN
THE
SUPERIOR
COURT
OF
THE
STATE
OF
ARIZONA
IN
AND
FOR
THE COUNTY
OF
MAzuCOPA
MARIC OPA
C
OLTNTY
REPUBLICANPARTY, APACHE
COLTNTY
REPUBLIÇAN PARTY,
NAVAJO
COUNTY REPUBLICAN PARTY,
ANd
YUMA
COUNTY REPUBLICANPARTY,Plaintiffs,
No.
VERIFIED COMPLAINT
FOR
INJUNCTIVE
AND DECLARATORY
RELIEF
V
MICHELE
REAGAN,
in
her
official
caoacitv
as
Arizona
Secretary
of
State;
BÖIsoÑ
J.
WAUNEKA,
inhis
off,rcialcaoacitv
as
Apache County
Recorder;
oÀvtÚ w.
STEVENS, in his
official
SW
1
I
.
l'¡ r ---
9l
F
trt
;+
É
I
n"3-
>
Igi:s
. I ^ _ :ótJv9:ó
co
t Èv+s
'--'1
I
f
b.'a
aJ
I
ç¿
Ê
I
õË
UDI
ÊË
.
z
o
2
a
J
4
5
67
I
910
11
t2
13
t4
15
t6t7
18
t9
20
2l
22
23
24
25
262728
official
caþacitv
as
Pima County Recorder;
VIRGINIÀ
ROSS,
in
her
official
capacity
as
Pinal
Countv
Recorder;
SUZANNE
SAINZ,
in
herbfficial
capacity-a
Santa
Cruz
Countv
Recorder;
LESLIE M.HOFFMAÑ,
in
her
official
capacity
as
Yavaoai
Countv
Recorder;
ROBYNSTAiLWORT-H
POUQUETTE, in
her
official
capacity
as
Yuma
CountY
Recorder,Defendants.The
Maricopa County
Republican Party,
Apache County
Republican
Party,
Navajo
County Republican Party,
and
Yuma County Republican Party (collectively,
the'oCountyparties,,
or
"Plaintiffs")
bring this
action
for
declaratory,
injunctive,
and mandamus
relief
and
hereby alleges
as
follows:
INTRODUCTION
1.
A
uniform
and
impartial
adherence
to
the
law
is
vital
to
public
confidence
in
the
Arizona
electoral
system and
its
outcomes.
By
implementing
and
enforcing
disparate
deadlines
by
which
Arizona voters
may
rehabilitate
an
early
ballot
deemed faciallydeficient,
the
State,s 15
County
Recorders
(the
"County
Recorders" or "Defendants")
are
undermining
the
constitutional
guarantee
that
all
Arizonans
are
entitled
to
cast
a
ballot
on
equal
terms, irrespective
of
their
geographic
location
within
the
state.
This
Court
should
require
all
County
Recorders to
enforce
an
equivalent deadline to ensure that
Arizona
voters
across
the
state
receive an
equal
opportunity
to
vote
in
the
November
6,2018
general
election.
JURISDI
CTIO
AND
NUE
2.
This Court
has
jurisdiction
and
venue pursuant
to article
6, section
14
of
the
ArizonaConstitution
and A.R.S.
$
12-123.
3.
A
justiciable
controversy
exists
because,
without
Court
intervention,
the
County Recorders
stand
to violate
under
color
of
state
law
the
rights of Plaintiffs
under the
U.S.
Constitution,
the
Arizona Constitution,
and
Arizonastatutes,
and
Plaintiffs
will
sufferimmediate
and
irreparable
injury
and loss
of rights'
2
I
2
a
J
4
5
67
8
9
10
11
t2
13
t4
15
oo
I
2
9l
5R
L: ¡ lqr
Jl
I
-iå_
5ls ã;x
tr
tËì;3
.'i oe
gg
<J
|
ÞVij
'--.,
I
s
si8
cJ
I
ç.e
c
I
oö
UDI
EÉ
3
o
t6
T7
18
t9
20
2t
22
23
24
25
2627
28
This Court
has
personal
jurisdiction
over
Defendants.
PARTIES
5.
The
County
Parties are
county
political
committees that works
to
ensure
thatelections
in Maricopa,
Apache,
Navajo,
and
Yuma
Counties, respectively,
are
conducted
in
a
free
and
open manner;
seek
to
assist
and
facilitate
the electoral
success
of
its
candidates;
and
work to
protect the
fundamental constitutional
right
to
vote
of
its
members and
allArizonans
and
to
promote their participation
in
the
political
process.
The
County
Parties
have
a
direct,
personal, and substantial interest
in this litigation
because
its
members
vote
in the
State, and
the
manner
in
which
elections
are administered determines whether
the
ballots legally
cast
by
the
members
of
the
County
Parties
are
counted
or
diluted,
nullif,red,
or
cancelled.
6.
Defendant
Secretary
of
State
Michele
Reagan is
the
chief
elections
officer in
the
state,
and is
responsible
for
supervising and
issuing directives
concerning the conduct
of all
elections
in
the
state. A.R.S.
ç
16-142.
7
.
Edison
J.
Wauneka
is
the
duly
elected
Apache County
Recorder
and is
named
as
a
defendant
in
this
action solely
in
his
official
capacity.
B.
David W.
Stevens is
the
duly
elected
Cochise County Recorder
and
is named
as
a
defendant
in
this
action solely
in his
official
capacity'
g.
patty
Hansen is the
duly
elected Coconino County Recorder
and is named
as
a
defendant
in
this
action solely in
her
official
capacity.
10.
Sadie Jo
Bingham
is the
duly
elected
Gila
County
Recorder
and
is
named
as
a
defendant
in this action solely
in her
official
capacity
'
1
l.
Wendy
John is the
duly
elected Graham
County
Recorder
and
is
named
as
a
defendant
in this action solely in
her
official
capacity.
lZ.
Berta
Manuzis
the
duly
elected Greenlee
County Recorder
and
is named
as a
defendant
in this action solely in
her
official
capacity'
13.
Shelly Baker
is the
duly
elected
La
Paz
County
Recorder and is
named
as
a
defendant
in this action solely in
her
official
capacity'
4
a
J