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Marquis Aurbach Coffing
Brian R. Hardy, Esq. Nevada Bar No. 10068 Alex K. Callaway, Esq. Nevada Bar No. 15188 10001 Park Run Drive Las Vegas, Nevada 89145 Telephone: (702) 382-0711 Facsimile: (702) 382-5816 bhardy@maclaw.com acallaway@maclaw.com
Attorneys for Plaintiffs/Petitioners
DISTRICT COURT CLARK COUNTY NEVADA
DONALD J. TRUMP FOR PRESIDENT, INC.; the NEVADA REPUBLICAN PARTY, Plaintiff/Petitioners, vs. JOSEPH P. GLORIA, in his official capacity as Registrar of Voters for Clark County, Nevada, Defendant/Respondent. Case No. Dept No.
Special Treatment Requested Election-Related Action COMPLAINT
Plaintiffs/Petitioners Donald J. Trump for President, Inc. and the Nevada Republican Party
(herein “Petitioners”)
, by and through their attorneys or record, allege and complain as follows:
PARTIES
1.
Plaintiffs are and were at all times relevant herein organizations whose members and candidates have a direct interest in the 2020 Election in Nevada. 2.
Defendant JOSEPH P. GLORIA
(the “
Registrar
”)
is and was at all times relevant herein the Registrar of Voters for Clark County, Nevada and is hereby sued in such capacity.
JURISDICTION AND VENUE
3.
This Court possesses jurisdiction over this matter because Clark County, Nevada is the judicial district in which a substantial part of the events or omissions giving rise to the claims set forth herein occurred.
Case Number: A-20-824153-C
Electronically Filed
11/3/2020 2:23 PM
Steven D. Grierson
CLERK OF THE COURT
CASE NO: A-20-824153-C
Department 14
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4.
Venue is proper because a substantial part of the events or omissions giving rise to this dispute occurred in this judicial district. 5.
This Court has jurisdiction to grant declaratory and injunctive relief pursuant to NRS § 30.030 and § 33.010, respectively. 6.
This Court has jurisdiction to grant a writ of mandamus or prohibition pursuant to NRS Chapter 34.
GENERAL ALLEGATIONS
7.
The right to vote in an election is guaranteed by, inter alia, the First Amendment and Fourteenth Amendments of the United States Constitution and 42 U.S.C. § 1971. Plaintiffs have standing to enforce these rights, and all rights asserted herein, on behalf of themselves and/or their members. 8.
Pursuant to NRS 293.273(1) the
“the polls must open at 7 a.m. and close at 7 p.m.”
In a tweet from Nevada Elections (@NVElect is the official Twitter feed of the Elections Division of the Nevada Secretary of State) it affirmed to all Nevadan
’s that the polls would open at 7 a.m.
and close at 7 p.m..
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9.
Unfortunately, about thirty minutes later @NVElect had to inform Clark County
that “several polling locations in the county are experiencing technical problems and have not yet opened.”
10.
The result of these delays has caused availability and access to the polls in certain precincts to be diminished by nearly an hour. 11.
Notably the following precincts were negatively affected by the delays: a.
Burkholder, Lyal Mid. Sch.; b.
Clark County Building Department; c.
Heritage Park Senior Facility; d.
Shadow Ridge High School; e.
Goolsby, Judy And John Elem; f.
Guinn, Kenny C. Mid. Sch.; g.
Sun City Macdonald Ranch Community Ctr.; h.
Bass, John Elem. - 10377 Rancho Destino Rd. i.
Canarelli, Lawrence and Heidi Mid. Sch.;