2929 North Central Avenue, Suite 2100 LAWYERS COMMITTEE FOR

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1 David B. Rosenbaum, No. 001 Ezra D. Rosenberg (pro hac vice drosenbaum@omlaw.com application pending) OSBORN MALEDON, P.A. erosenberg@lawyerscommitttee.org North Central Avenue, Suite 0 LAWYERS COMMITTEE FOR Phoenix, Arizona 0- CIVIL RIGHTS UNDER LAW Telephone: New York Avenue NW No. 00 Facsimile: Washington, D.C. 000 Telephone: Facsimile: 0..0 Matthew P. Kanny, No. 010 mkanny@manatt.com John W. McGuinness (pro hac vice application pending) jmcguinness@manatt.com MANATT, PHELPS & PHILLIPS, LLP W. Olympic Blvd. Los Angeles, CA 00 Telephone:..000 Facsimile:.. (Additional counsel listed on signature page) Attorneys for Plaintiffs IN THE SUPERIOR COURT OF THE STATE OF ARIZONA JULIANA HUERENA, et al., v. IN AND FOR THE COUNTY OF MARICOPA Plaintiffs, MICHELE REAGAN, in her official capacity as Arizona Secretary of State, et al., Defendants. Case No. CV PLAINTIFFS APPLICATION AND MEMORANDUM IN SUPPORT OF PRELIMINARY INJUNCTION (Expedited Consideration Requested) (Assigned to the Hon. Hugh Hegyi)

2 I. INTRODUCTION This motion for emergency relief is brought to prevent Defendants, the Arizona Secretary of State, the Maricopa County Recorder, the Maricopa County Board of Supervisors ( Board of Supervisors ) and the members of the Maricopa County Board of Supervisors, from continuing to impair Plaintiffs and the other eligible Maricopa County residents fundamental constitutional right to a free and equal election and statutory right to vote. Absent this Court s immediate intervention, Defendants will continue to violate these rights and effectively disenfranchise thousands of eligible Maricopa County voters in future elections, including in the rapidly approaching August 0 party primaries. As alleged in the Complaint and demonstrated herein, the Defendants have, through a pattern of gross mismanagement, wanton disregard of their duties under Arizona law, and flawed decisions, created unendurable wait times for thousands of Maricopa County voters, many of whom were forced to leave polling places without casting a ballot in the March, 0 Presidential Preference Election ( PPE ). Specifically, Defendant Michele Reagan, in her official capacity as the Arizona Secretary of State, is responsible for supervising, conducting, and providing regulations and guidelines for statewide elections. In direct contravention of Arizona statute, Reagan failed to establish the maximum wait time for the March 0 PPE and formulate a plan for reducing wait times. Defendant Helen Purcell, in her official capacity as the Maricopa County Recorder, is responsible for conducting elections in Maricopa County. However, leading up to the March 0 PPE, she proposed a drastic reduction of the number of polling places in Maricopa County to 0 voting centers for nearly 1. million eligible Maricopa County voters, down from the 0 polling places operated in the 00 PPE, and polling places operated in the 0 PPE, which lacked a Democratic contest, also in violation of Arizona statute. And while Defendant Board of Supervisors, comprised of Defendants Denny Barney, Steve Chucri, Andy Kunasek, Clint Hickman, and Steve Gallardo, is obligated under Arizona law to designate a reasonable and adequate number of polling places 1

3 in PPEs and primary elections, prior to the March 0 PPE, it approved Purcell s grossly inadequate number of only 0 polling places. The massive errors, whether intentional or merely thoughtless, created havoc in the March 0 PPE. Plaintiff Juliana Huerena waited in line for approximately four and a half hours in 0-degree weather before finally casting her ballot. Countless others, including Plaintiff Monica Cooper, could not endure such long waits for a variety of reasons, including for example, family or work responsibilities, or physical limitations, and were thus effectively denied the right to vote. These mistakes were so egregious, and the harm so severe, that judicial intervention is necessary to protect the Plaintiffs and other Maricopa County voters from a repeat catastrophe. As demonstrated below, Plaintiffs are overwhelmingly likely to succeed on the merits of their claims that Defendants violated Arizona constitutional and statutory law. Defendants themselves admitted following the March 0 PPE that operating only 0 voting places was woefully inadequate and there is no evidence that Defendants have rectified the problem by developing an adequate plan for upcoming elections. Plaintiffs will be irreparably harmed if the requested injunction is not issued. Plaintiffs thus seek by this motion an order that the Court will exercise supervision over all upcoming elections, including the August 0 party primaries, and require that Defendants submit to the Court, adequately in advance of those elections, a comprehensive plan to manage future elections to avoid the delays and disenfranchisement that plagued the March 0 PPE. Given Defendants past derelictions of duties with respect to election planning, such a safeguard is necessary to ensure the adequacy of the plan. And this plan can be provided without significant burden to the Defendants. II. FACTUAL BACKGROUND A. THE VOTING RIGHTS ACT OF 1 MANDATING PRECLEARANCE OF POLLING PLACE PLANS. Maricopa County s election procedures had long been subject to approval by the Department of Justice ( DOJ ) under the Voting Rights Act of 1 ( VRA ). Section of

4 the VRA prevents certain jurisdictions with a history of racial discrimination from implementing changes that affect voting unless and until the jurisdiction demonstrates to federal authorities that the change will not have the purpose or effect of abridging or denying the right to vote on account of race, color or membership in a language minority group. See U.S.C. 01. Under the coverage formula contained in Section of the VRA, Maricopa County was a covered jurisdiction. On June, 0, in Shelby County, Alabama v. Holder, S. Ct. (0), the United States Supreme Court held Section of the VRA unconstitutional, and thus its coverage formula could no longer be used as a basis for subjecting jurisdictions, including Maricopa County, to preclearance requirements. Accordingly, Maricopa County was not required to submit its plan to reduce the number of polling stations for the 0 PPE to the DOJ for preclearance. B. DEFENDANTS DRASTICALLY REDUCE THE NUMBER OF POLLING PLACES IN MARICOPA COUNTY. According to the U.S. Census Bureau, Maricopa County is the fourth-most populous county in the United States. 1 As of July 0, the County had an estimated population of,,, and comprised 1% of Arizona s total population. No longer required to pre-clear electoral changes with the DOJ, in advance of the March 0 PPE Maricopa County s Recorder, Purcell, proposed a reduction of the number of polling places in Maricopa County to 0 voting centers. The Board of Supervisors unanimously approved the plan on February, 0. In comparison, in 00, a year in which both major parties had multiple candidates competing for nominations, Maricopa 1 See U.S. Census Quickfacts for Maricopa County, Arizona, ( Public records, such as these, are admissible as hearsay exceptions, unless they display a lack of trustworthiness. State v. Gillies, Ariz.,, 1 P.d, (1).) Id. See Maricopa County Board of Supervisors Meeting (Feb., 0), NDA (discussion begins in accompanying video at the -minute mark). Id.

5 County operated 0 polling places. And in 0, when there was no contest for the Democratic nomination due to the incumbency of President Obama, Maricopa County operated polling places. As demonstrated below, during the March 0 PPE, Maricopa County operated one polling place for every 1, eligible voters, compared to the average of all other Arizona counties, which operated one polling place for approximately every 1,00 voters. Number of Voters Per Polling Location in Arizona by County County Total Eligible Voters # of Polling Locations Voters Per Polling Location Maricopa 1,,1 0 1, Yuma,, Yavapai,00, Cochise, 1, Pima,0 0,1 Coconino, 1, Graham,0 1, Santa Cruz, 1, Pinal,1 1,1 Gila, 0 1,10 Greenlee,01 1, Navajo, 1,1 Apache, 1 La Paz, (Declaration of Shane Ham ( Ham Decl. ), Ex. C (emphasis added).) C. THE DRASTIC REDUCTION IN POLLING PLACES FOR THE MARCH 0 PPE CAUSED WAIT TIMES IN EXCESS OF FIVE HOURS AND EFFECTIVELY DISENFRANCHISED COUNTLESS ELIGIBLE VOTERS. On March, 0, the day of Arizona s PPE, numerous eligible voters in Maricopa waited in line in excess of five hours to cast a ballot. Some voters in line did not vote until after midnight i.e., five hours after when polls were scheduled to close. (Id., Ex. D.) In majority-minority South Phoenix, the last ballot was cast at : a.m. (Id..) In total, five Arizona House Elections Committee Hearing (Mar., 0), (1-minute mark). Id.

6 polling places stayed open past midnight while twenty of the sixty locations remained open until after :00 p.m. (Id., Ex. E.) Many voters, including Plaintiff Cooper, could not endure such long waits and were denied the right to vote. As a woman with physical disabilities, Ms. Cooper went to great lengths to arrange her paratransit ride to the polling station. (Declaration of Monica Cooper ( Cooper Decl. ).) To schedule a paratransit pickup, she had to reserve a paratransit ride days to weeks in advance and had to be ready to leave within five minutes of the paratransit arriving to pick her up, lest she risk being left behind. (Id..) On March, Ms. Cooper successfully made it to her polling station and took her place in line. (Id..) But the station had no places for her to sit and rest without losing her place in line thus exacerbating the strain already on her legs. (Id..) Ms. Cooper was eager to cast her ballot, but by the time she reached a polling machine after two hours of waiting in line, the paratransit had arrived and she had to leave without voting. (Id..) She felt angered that she was unable to cast her vote, yet remains hopeful that she will be free to exercise her right to vote in the next election. (Id..) Plaintiff Huerena has been voting in Maricopa County for nearly ten years and has never seen waiting lines as long as those she witnessed on March. (Declaration of Juliana Huerena ( Huerena Decl. ).) When she arrived at the polling location at :00 p.m., the line to vote had already wrapped around to the other side of the building. (Id..) Watching as other voters gave up and left the polling location without casting their ballots, Ms. Huerena kept her place in line and waited outside for nearly four hours in 0-degree weather before entering the voting facility. (Id..) Once inside, it took Ms. Huerena another thirty minutes before she could cast her ballot. (Id..) By the time she left, Ms. Huerena had already spent, in total, four and a half hours waiting to cast her ballot. (Id..) Adding fuel to the fire, by the end of the day, over,000 provisional ballots The Cooper Declaration is attached to the Ham Decl. as Exhibit A. The Huerena Declaration is attached to the Ham Decl. as Exhibit B.

7 1 1 0 comprising approximately 1.% of all votes were cast. (Ham Decl.., Ex. F.) Given the confusion over whether independents could vote in the PPE, and as a result of voters not being properly informed, over 1,000 independents cast provisional ballots that ultimately were not counted. (Id.) Maricopa County estimated that it takes a minimum of five minutes per voter to issue a provisional ballot. (Id., Ex. G.) With approximately,000 provisional ballots cast, pollworkers spent approximately,000 hours processing provisional voters on Election Day. (Id., Ex. G.) D. CONTINUED VOTING ISSUES POST MARCH 0 PPE AND THE UPCOMING MARICOPA COUNTY ELECTIONS, INCLUDING THE AUGUST 0 PARTY PRIMARIES. Unfortunately, the events of the March PPE reflect a pattern of serious legal errors by Defendants that undermine Arizonans right to vote. Soon after the PPE fiasco, a Spanish-language version of early ballots mailed to 1. million Maricopa County voters for the May, 0 special election mistakenly repeated the title of Proposition (a proposal concerning education funding) as the title for Proposition (a proposal to change pensions of police and firefighters). In addition, Reagan simply failed to send publicity pamphlets describing the initiatives on the May, 0 special election ballot, outlining the pro and con arguments, and showing voters where they can cast their ballots, to 00,000 households. Party primaries are scheduled to occur in Arizona on August 0, 0. Eight of Arizona s nine congressional districts (all but the Second District) are located in whole or in 1 This is not unusual. In the 00 election, approximately 0,000 provisional ballots were cast, amounting to.% of all ballots cast on election day. See See (video interview of Purcell discussing the error). See special-election-will-not-be-postponed. (video interview of Arizona s Attorney General, Mark Brnovich, finding that Defendant Reagan did indeed violate Arizona law ). See 0 Election Information, Arizona Secretary of State,

8 part in Maricopa County. Three of those districts the First, Fifth, and Sixth will feature contested primaries by both major parties, while the other five will feature a contested primary by one major party. In addition, the primary will feature a contested fourcandidate U.S. Senate Primary for the Republican nomination and numerous contests for the Arizona legislature. III. A. STANDARDS ON THIS MOTION. ARGUMENT Courts should issue an injunction when the party applying for one is entitled to the relief demanded, and such relief or any part thereof requires the restraint of some act prejudicial to the applicant. A.R.S A party is entitled to a preliminary injunction when it establishes 1) A strong likelihood that [the party] will succeed at trial on the merits; ) The possibility of irreparable injury to [the party] not remediable by damages if the requested relief is not granted; ) A balance of hardships favors [the party seeking an injunction]; and ) Public policy favors the injunction. Shoen v. Shoen, Ariz.,, 0 P.d, (Ct. App. 10). The critical element in this analysis is the relative hardship to the parties. Id. (citing Justice v. Nat l Collegiate Athletic Ass n, F. Supp., (D. Ariz. 1)). Because relative hardship is the most critical element, a party seeking an injunction may establish either 1) probable success on the merits and the possibility of irreparable injury; or ) the presence of serious questions and the balance of hardships tip sharply in [the moving party s] favor. Shoen, Ariz. at (emphasis added). That is, [t]he greater and less reparable the harm, the less the showing of a strong likelihood of success on the merits need be. Conversely, if the likelihood of success on the merits is weak, the showing of irreparable harm must be stronger. Smith v. Arizona Citizens Clean Elections Comm n, Ariz. 0,, P.d, 1 (00). Here, the See Primary Candidates, Arizona Secretary of State, Id. Id. Although the United States Supreme Court eliminated the sliding scale analysis of the elements of a preliminary injunction in the federal courts in Winter v. Natural

9 elements are easily met. B. PLAINTIFFS ARE LIKELY TO SUCCEED ON THE MERITS OF THEIR CLAIMS. 1. Defendant Board of Supervisors Failed to Designate a Reasonable and Adequate Number of Polling Places Under A.R.S. -(A). Under Arizona law, [n]ot less than twenty days before a presidential preference election, the board of supervisors shall designate a reasonable and adequate number of polling places where the election shall be held. Ariz. Rev. Stat. -(A). The Board of Supervisors is required to determine the number of places according to the number of active registered voters as of January 1 of the year of the presidential preference election. A.R.S. -(B). Despite these clear mandates, and facing a large voter turnout for a hotly contested presidential primary, the Board of Supervisors approved Purcell s decision to grossly reduce the number of polling places to 0, down from the 0 polling places that were operated in 00 and polling places that were operated in the 0 PPE, when there was no Democratic contest. For the 0 PPE, the County operated only one polling place for every 1, eligible voters, while other counties in the state operated polling places for an approximate average of every 1,00 voters. As a result, countless voters, including Plaintiff Huerena, waited in line at certain locations for more than four hours. Countless other voters, including Plaintiff Cooper, were effectively denied the right to vote at all by the exceedingly long wait times. Public outrage ensued, and Purcell admitted that she and the County erred. (Ham Decl., Ex. I.) We certainly made bad decisions, and having only 0 polling places... [w]e were obviously wrong that s my fault. (Id.) At a special session of the Arizona House of Representatives Election Committee Hearing on March, Purcell added, I am deeply sorry. It was my responsibility to put this election on in Maricopa County and we obviously made some mistakes. When asked about the mismanagement, Purcell stated, I Resources Defense Council, Inc., U.S. (00), Arizona state courts ha[ve] continued to employ the Shoen standard since Winter was decided. IB Prop. Holdings, LLC v. Rancho Del Mar Apartments Ltd. P ship, Ariz. 1,, P.d, (Ct. App. 0).

10 made a giant mistake. (Id.) In approving Purcell s admittedly unreasonable number of polling places, the Board of Supervisors failed to designate a reasonable and adequate number of polling places in violation of A.R.S. -(A). Given this evidence, and Defendants admissions regarding the inadequacy of the number of polling places, Plaintiffs are likely to prevail on this claim.. Defendant Secretary of State Failed to Provide for a Maximum Allowable Wait Time or an Effective Wait Time Reduction Method as Required by A.R.S. -(J), or Adhere to the Provisions of the Instructions and Procedures Manual Created under A.R.S. -. Under Arizona law, [e]xcept as otherwise provided [], the presidential preference election shall be conducted and canvassed in the same manner as prescribed in this title for the primary election held pursuant to -01. All provisions of other laws that govern elections and that are not in conflict with this article apply to a presidential preference election.... A.R.S. -1(C). Thus, barring any specific conflicting dictates pertaining to PPEs, the rest of the election code is applicable. None of the provisions discussed in this section conflict with the provisions of -01, and, therefore, apply to PPEs. For example, there is no provision in the presidential preference section of the A.R.S. addressing voter wait times. Therefore, A.R.S. -(J), which requires the Secretary of State to provide through the instructions and procedures manual adopted pursuant to - the maximum allowable wait time for any election that is subject to -0, applies to PPEs. A.R.S. -(J). According to the Elections Procedure Manual issued by the Secretary of State in 0, [t]he maximum allowable wait time for any election that is subject to ARS -0 is one hour. 1 Here, the fact that wait times exceeded four or five Ariz. Rev. Stat. -(C) provides that [e]ach county with two hundred thousand or more active registered voters shall determine the number of polling places for the presidential preference election by using no more than one-half of the number of precincts as of January 1 of the year of the presidential preference election. This provision serves as an effective ceiling on the number of polling places a county can operate for a PPE. There are precincts in Maricopa County. (See note, supra) Thus, by law, the County can have up to polling places for a PPE. 1 Arizona Secretary of State, State of Arizona Elections Procedures Manual, Rev. 0, at (emphasis added).

11 hours suggests that Plaintiffs will succeed in showing that the Secretary of State failed to establish a maximum wait time for the March 0 PPE, in violation of -(J). In addition, the Secretary of State is also required to provide for a method to reduce voter wait times for PPEs. A.R.S. -(J) provides that the method shall consider at least all of the following for primary and general elections in each precinct: 1. The number of ballots voted in the prior primary and general elections.. The number of registered voters who voted early in the prior primary and general elections.. The number of registered voters and the number of registered voters who cast an early ballot for the current primary or general election.. The number of election board members and clerks and the number of rosters that will reduce voter wait time at the polls. A.R.S. -(J). 1 Reagan failed to formulate any such plan or method to ensure that voter waiting time did not exceed one hour. As a result, countless eligible Maricopa County voters, including Plaintiff Huerena, waited in line for hours in order to cast a vote (Huerena Decl. ), and others, such as Plaintiff Cooper, were effectively deprived of the right to vote altogether. (Cooper Decl..) At a press conference on March, 0, Reagan apologized to voters who were frustrated or angry, and admitted that she knew Purcell had recommended using only 0 polling places. She added that she certainly wish[ed] that we had said, you should consider ninety, you should consider one hundred [polling places]. (Ham Decl., Ex. I.) Reagan s failure to formulate a plan to reduce voter wait times in connection with the March 0 PPE, despite knowing that 0 polling locations would be inadequate, is a clear violation of A.R.S. -(J). Accordingly, Plaintiffs are likely to prevail on these claims. 0 1 The Elections Procedure Manual also instructs local election officials to make their best efforts to project the turnout at each polling place prior to the election in order to reduce wait times. (Procedures Manual at.) 0 In the Complaint, Plaintiffs also allege that Defendants did not effectively respond to Election Day requests from election marshals for assistance in wait time reduction, in violation of A.R.S. -(B), on information and belief because discovery will be necessary to determine what requests were made to Purcell on March.

12 Defendants Failed to Provide for Free and Equal Elections in Violation of Ariz. Const. art. II, 1. Arizona Constitution, Article, Section 1, provides that [a]ll elections shall be free and equal, and no power, civil or military, shall at any time interfere to prevent the free exercise of the right of suffrage. Ariz. Const. art II, 1. In Chavez v. Brewer, Ariz. 0, 1, P.d, 0 (Ct. App. 00), the Court of Appeals interpreted Section 1 s free and equal guarantee. While acknowledging that there had been no Arizona case interpreting what protections the framers intended by that guarantee, the court noted that other states with similar constitutional provisions have generally interpreted a free and equal election as one in which a voter is not prevented from casting a ballot by intimidation or threat of violence, or any other influence that would deter the voter from exercising free will. Id. at 1 (emphasis added). The court supported its decision by reference to a Kentucky Court of Appeal holding that no election can be free and equal... if any substantial number of persons entitled to vote are denied the right to do so. Id. (quoting Wallbrecht v. Ingram, Ky. (1)). Here, as a direct result of Purcell s decision to operate only 0 polling places, the Board of Supervisors decision to approve that plan, and Reagan s failure to formulate any plan or method to ensure that voter waiting time did not exceed one hour, countless voters, including Plaintiff Cooper, were effectively denied the right to vote. Plaintiff Cooper, who is physically disabled, was forced to wait in the long lines caused by Defendants faulty election plan and ultimately was unable to vote. (Cooper Decl. -.) Other voters likewise gave up after waiting in line for hours and were deprived of their rights to vote. (Huerena Decl..) Because Maricopa voters, unlike eligible voters in other Arizona counties, were impeded from voting in the March 0 PPE as a result of the drastic reduction in the number of Maricopa County polling locations, they were denied their constitutional right to a free and equal election. Similarly, as a direct result of Defendants acts and omissions, countless voters, including Plaintiff Huerena, waited on long lines for hours before being able to cast their

13 votes. (Huerena Decl..) Numerous courts have held that longer voting lines are a deterrent to voting. See, e.g., Ohio Org. Collaborative v. Husted, No. :-CV-10, 0 WL 00, at * (S.D. Ohio May, 0) (issuing injunction barring elimination of early voting because it may result in longer lines at the polls, thereby increasing the burdens... and deterring voting, where wait times exceeded thirty minutes); Nat l Ass n for Advancement of Colored People State Conference of Penn. v. Cortes, 1 F. Supp. d, (E.D. Pa. 00) (granting injunction and holding there can come a point when the burden of standing in a queue ceases to be an inconvenience or annoyance and becomes a constitutional violation because it, in effect, denies a person the right to exercise his or her franchise ); Crawford v. Marion County Election Board, U.S. 11 (00) ( [n]othing deters voting so much as long lines at the polls ). Under Chavez, such a voting deterrent is a violation of Plaintiffs and other voters constitutional right to a free and equal election. As demonstrated above, Defendants themselves have admitted to being directly responsible for impeding the Maricopa County voters right to vote. (E.g., Ham Decl., Ex. I.) By deterring, and in numerous cases denying Maricopa County residents from voting in the March 0 PPE, Defendants violated Plaintiffs and other voters right to a free and equal election. Chavez, Ariz. at 1. Given the foregoing, Plaintiffs are likely to succeed on the merits of this claim, as well. C. PLAINTIFFS WILL SUFFER IRREPARABLE HARM ABSENT AN INJUNCTION. Plaintiffs are seeking to ensure that they, and the other eligible Maricopa County voters, are not impeded from exercising a right that the Supreme Court has consistently declared a fundamental political right, preservative of all rights the right to vote. See Dunn v. Blumstein, 0 U.S. 0, (1); Kramer v. Union Free Sch. Dist. No., U.S. 1, (1); Reynolds v. Sims, U.S., (1). No right is more precious in a free country than that of having a voice in the election of those who make the laws under which, as good citizens, we must live. Other rights, even the most basic, are illusory if the right to vote is undermined. Wesberry v. Sanders, U.S. 1, (1). Given Defendants past derelictions of duties with respect to election planning, which have resulted

14 in the functional disenfranchisement of countless residents, Plaintiffs will be irreparably harmed absent an injunction exercising supervision over all upcoming elections, including the August 0 party primaries. The only way to prevent these residents from being injured again as a result of Defendants acts and omissions, is to require, adequately in advance of those elections, that Defendants provide a comprehensive plan to the Court and an opportunity to comment on it. While Plaintiffs have demonstrated a strong likelihood of succeeding on the merits, even if Plaintiffs did not make that showing, a preliminary injunction should still issue given the serious nature of the irreparable harm. Smith, Ariz. at. The harm that Plaintiffs face disenfranchisement is acknowledged as the sine qua non of irreparable harm under a preliminary injunction analysis. See, e.g., Cortes, 1 F. Supp. d at (finding irreparable harm where [i]f relief [was] refused, there [was] a real danger that many voters... will have their constitutional right to vote unduly burdened ); Bay Cty. Democratic Party v. Land, F. Supp. d 0, (E.D. Mich. 00) ( deprivation of an eligible voter s right to have his or her vote counted constitutes irreparable harm ); Obama for America v. Husted, F.d, (th Cir. 0) ( [a] restriction on the fundamental right to vote therefore constitutes irreparable injury ). D. A BALANCING OF THE EQUITIES TIPS SHARPLY IN PLAINTIFFS FAVOR. It is impossible to imagine what harm to Defendants could justify impeding, or functionally preventing, an eligible and registered voter from casting a vote. But that is effectively what Defendants have done. Defendants already are obligated to provide for the free exercise of the right to vote under Arizona constitutional and statutory law, and, therefore, the injunction would pose no additional burden on them. And Defendants will be only minimally burdened by submitting a proposal to the Court in advance of the elections, starting with the August 0 primary election, to effectuate those obligations by specifying measures that will be taken to reduce and manage wait times. After all, in the decades that Section of the Voting Rights Act was operative, Defendants had to submit any changes in election procedure to the DOJ for preclearance. Meanwhile the burden that will be imposed

15 1 on Plaintiffs and, indeed, all eligible voters whose right to vote would continue to be impeded in future elections would be unacceptably severe. 1 See Cortes, 1 F. Supp. d at (holding that when balancing the harm to plaintiffs whose right to vote is endangered against election entity s burden of addressing issues, plaintiffs clearly prevail ). Accordingly, the balance of equities weighs heavily in Plaintiffs favor. E. THE PUBLIC INTEREST STRONGLY FAVORS AN INJUNCTION. The public interest weighs strongly in favor of protecting eligible voters ability to vote. As the Cortes court held in issuing a preliminary injunction in that voting rights case, [t]he right to vote is at the foundation of our constitutional form of government. Ultimately, all our freedoms depend on it. Protection of this right under the circumstances presented here is without question in the public interest. Cortes, 1 F. Supp. d at. There is simply no public interest in denying or impeding an eligible citizen s right to vote. Rather, the public interest favors permitting as many qualified voters to vote as possible. Husted, F.d at. This factor weighs heavily in favor of a preliminary injunction. IV. CONCLUSION For these reasons, Plaintiffs respectfully request that the Court enter an order providing for Court supervision over all upcoming elections, including the August 0, 0 party primary election. In particular, the injunction should require that: 1 (a) Defendants, led by the County Recorder and Secretary of State, create a 0 1 comprehensive Election Administration Plan ( EAP ) to reduce wait times for the August 0, 0 primary election and the November, 0 general election. The Board of Supervisors shall vote to approve each EAP prior to its submission to the Court. The EAP shall include, at a minimum: 1. The number of polling sites to be used during the election and a detailed explanation for how this number was determined, 1 Waiting four or five hours to vote on August 0 will present additional burdens that waiting in March did not. The average high temperature on August 0 in Phoenix is. degrees. (See Forcing people to wait four hours or more outdoors in such conditions could result in serious health consequences.

16 A plan for addressing contingencies in the event of lines longer than 0 minutes at any polling place,. A plan for efficiently allowing voters to cast provisional ballots, and for the County to process all valid ballots,. A plan for Election Day communications which shall address the specifics of how the office of the County Recorder will communicate with the Secretary of State, the media, the public, and pollworkers, how each of these entities will communicate with the County Recorder, and how issues will be addressed when they arise,. Contingencies for (i) absence or early departure of pollworkers, and (ii) shortages or failures of equipment, and. Measures that will be taken to inform eligible voters how and where to vote and other efforts made to publicize the election. Under the EAP, eligible voters shall receive via U.S. mail materials identifying each polling place where they may vote no later than 0 days before the election. (b) The EAP shall be submitted to the Court for approval no later than thirty days in advance of the August 0, 0 primary and forty-five days in advance of the November, 0 general election. RESPECTFULLY SUBMITTED this th day of July, 0.

17 OSBORN MALEDON, P.A. By David Rosenbaum Shane Ham North Central Avenue, 1st Floor Phoenix, Arizona 0- MANATT, PHELPS & PHILLIPS, LLP By Matthew P. Kanny John W. McGuinness Christopher A. Rheinheimer Andrew C. Case Eric B. Chen W. Olympic Blvd. Los Angeles, CA 00 LAWYERS COMMITTEE FOR CIVIL RIGHTS UNDER LAW By Ezra D. Rosenberg Brandan B. Downes 01 New York Avenue NW No. 00 Washington DC 000 Attorneys for Plaintiffs

18 ADDITIONAL COUNSEL FOR PLAINTIFFS Shane M. Ham, No. 0 Brendan B. Downes (pro hac vice sham@omlaw.com application pending) OSBORN MALEDON, P.A. bdownes@lawyerscommittee.org North Central Avenue, Suite 0 LAWYERS COMMITTEE FOR Phoenix, Arizona 0- CIVIL RIGHTS UNDER LAW Telephone: New York Avenue NW No. 0 Facsimile: Washington, D.C. 000 Telephone: Facsimile: 0..0 Andrew C. Case, No. 00 (pending reactivation) acase@manatt.com Christopher A. Rheinheimer (pro hac vice application pending) crheinheimer@manatt.com Eric B. Chen (pro hac vice application pending) echen@manatt.com MANATT, PHELPS & PHILLIPS, LLP W. Olympic Blvd. Los Angeles, CA 00 Telephone:..000 Facsimile:..

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