IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

Transcription

1 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION JOSE MORALES, on behalf of himself and those similarly situated; NATIONAL ASSOCIATION FOR THE ADVANCEMENT OF COLORED PEOPLE (NAACP, as an organization; GEORGIA ASSOCIATION OF LATINO ELECTED OFFICIALS (GALEO, as an organization; THE CENTER FOR PAN ASIAN COMMUNITY SERVICES (CPACS, as an Organization, Plaintiffs, CIVIL ACTION NO. 1:08-CV-3172 v. Three-Judge Court (SFB, JTC, WSD KAREN HANDEL, in her official capacity as Georgia Secretary of State, Defendant. JOINT MOTION TO EXTEND THE DISCOVERY PERIOD FOR AN ADDITIONAL NINETY DAYS COME NOW Plaintiffs Jose Morales, the National Association for the Advancement of Colored People (NAACP, the Georgia Association of Latino Elected Officials (GALEO, and the Center for Pan Asian Community Services (CPACS, and Defendant Karen Handel, by and through their counsel of record, and respectfully move the Court to extend

2 the discovery period in this action for an additional ninety days, through and including June 25, In support of their motion, the parties state that on February 5, 2009, Plaintiff Morales filed a Motion to Amend the Complaint to add additional Plaintiffs. [Doc. 49]. On that same date, Plaintiff served the Defendant with his First Interrogatories and Request for Production of Documents. [Doc. 48]. On March 10, 2009, the Court granted Plaintiff s unopposed motion to amend the Complaint. [Doc. 54]. In further support of their motion, counsel for Defendant states that the Defendant s submission for Section 5 preclearance related to this case is still under consideration by the Department of Justice. The Department of Justice requested additional information from the Secretary of State on December 15, Due to the heavy load of business of the Secretary of State s Office following the November general election and the December run-off election, the Secretary of State s office requested an extension of time to respond to the Department of Justice s request for additional information. The Secretary of State s response is now due on Friday, March 13, A proposed Order is attached for the Court s consideration.

3 s/ Elise Sandra Shore Elise Sandra Shore Attorney for Plaintiffs State Bar No Mexican American Legal Defense and Education Fund (MALDEF 34 Peachtree St. NW Suite #2500 Atlanta, GA ( s/ Julia B. Anderson Julia B. Anderson Attorney for Defendant State Bar No Georgia Department of Law 40 Capitol Square, SW Atlanta, Georgia ( fax: (

4 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION JOSE MORALES, et al. Plaintiffs, CIVIL ACTION NO. 1:08-CV-3172 v. Three-Judge Court (SFB, JTC, WSD KAREN HANDEL, in her official capacity as Georgia Secretary of State, Defendant. O R D E R This matter is now before the Court for consideration of the parties Joint Motion to Extend the Discovery Period for an Additional Ninety Days. For good cause shown, that motion is hereby GRANTED. The discovery period is hereby EXTENDED through and including June 25, It is so ORDERED, this day of, JACK T. CAMP United States District Judge

5 CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day electronically filed the within and foregoing JOINT MOTION TO EXTEND THE DISCOVERY PERIOD FOR AN ADDITIONAL NINETY DAYS with the Clerk of Court using the CM/ECF system, which will send notification of such filing to all parties to this matter via electronic notification or otherwise: Elise Sandra Shore Mexican American Legal Defense and Educational Fund 34 Peachtree St. NW, Suite # 2500 Atlanta, GA eshore@maldef.org Laughlin McDonald Neil Bradley Meredith Bell-Platts ACLU VOTING RIGHTS PROJECT 230 Peachtree Street, NW Suite 1440 Atlanta, GA lmcdonald@aclu.org nbradley@aclu.org mbell@aclu.org Brian Spears Law Office of Brian Spears 1126 Ponce de Leon Ave., NE Atlanta, GA bspears@mindspring.com

6 Jon Greenbaum Robert A. Kengle Mark A. Posner Lawyers Committee for Civil Rights Under Law 1401 New York Avenue, NW Suite 400 Washington DC Christopher Coates Thomas Christian Herren, Jr U.S. Department of Justice-Civil Civil Division 950 Pennsylvania Avenue, N.W. Room 7254 NWB Washington, DC This 10th day of March /s/ Julia B. Anderson JULIA B. ANDERSON Senior Assistant Attorney General