COCKRUM et al v. DONALD J. TRUMP FOR PRESIDENT, INC. et al

Filing 34

Unopposed MOTION for Leave to File Brief of Amici Curiae by CAMPAIGN LEGAL CENTER, Theodore M. Shaw (Attachments: # 1 Exhibit Brief of Amici Curiae, # 2 Text of Proposed Order, # 3 Exhibit LCvR 7.1 Certificate)(Smith, Paul)

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

ROY COCKRUM; SCOTT COMER; and,
ERIC SCHOENBERG,
Plaintiffs,
v.
DONALD J. TRUMP FOR PRESIDENT,
INC.; and ROGER STONE,
Defendants.

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Civil Action No. 1:17-CV-1370-ESH

UNOPPOSED MOTION OF CAMPAIGN LEGAL CENTER AND PROFESSOR
THEODORE M. SHAW FOR LEAVE TO FILE BRIEF AS AMICI CURIAE IN
OPPOSITION TO DEFENDANTS’ MOTIONS TO DISMISS PLAINTIFFS’ FIRST
AMENDED COMPLAINT
Pursuant to LCvR 7(o), Campaign Legal Center and Professor Theodore M. Shaw, through
undersigned counsel, respectfully move for leave to file the accompanying brief as amici curiae in
opposition to the defendants’ motions to dismiss Plaintiffs’ First Amended Complaint.
Amicus curiae, Campaign Legal Center (CLC), is a nonpartisan nonprofit organization
that has been working for fifteen years to advance democracy through law. Amicus CLC has
litigated many voting rights cases in federal courts, including as arguing counsel for the plaintiffs
in the recent United States Supreme Court case, Gill v. Whitford, No. 16-1161, as counsel for
plaintiffs in Veasey v. Abbott, 830 F.3d 216 (5th Cir. 2016) (challenging Texas's photo ID law),
and as counsel for plaintiffs in LULAC v. Reagan, No. 2:17-cv-04102 (D. Ariz. 2017)
(challenging Arizona's dual registration system). CLC has filed amicus curiae briefs in every
major voting rights case before the Supreme Court in recent years including Cooper v. Harris,
137 S. Ct. 1455 (2017), Evenwel v. Abbott, 136 S. Ct. 1120 (2016), and Shelby County v. Holder,
133 S. Ct. 2612 (2013).
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Amicus curiae, Professor Theodore M. Shaw, is the Julius L. Chambers Distinguished
Professor of Law at the University of North Carolina School of Law, where he teaches courses on
the equal protection clause of the Fourteenth Amendment, and the civil rights statutes from the
Reconstruction era. Professor Shaw was the fifth Director-Counsel and President of the NAACP
Legal Defense and Educational Fund, Inc. (“LDF”), for which he worked in various capacities
over the span of twenty-six years. He has litigated education, employment, voting rights, housing,
police misconduct, capital punishment, and other civil rights cases in trial and appellate courts,
and before the United States Supreme Court. From 1982 until 1987, he litigated education,
housing, and capital punishment cases, and directed LDF’s education litigation docket. In 1987,
under the direction of LDF's third Director-Counsel, Julius Chambers, Mr. Shaw relocated to Los
Angeles to establish LDF’s Western Regional Office. In 1990, Mr. Shaw left LDF to join the
faculty of the University of Michigan Law School. In 1993, Mr. Shaw returned to LDF as
Associate Director-Counsel, and in 2004, he became LDF’s fifth Director-Counsel. Mr. Shaw’s
legal career began as a Trial Attorney in the Honors Program of the United States Department of
Justice, Civil Rights Division in Washington, D.C., where he worked from 1979 until 1982.
CLC and Professor Shaw seek leave to file a brief as amici curiae because this case directly
implicates issues of fundamental concern to them. Amici have a demonstrated interest in the
protection of civil rights and the health of our representative democracy, and thus the interpretation
and application of 42 U.S.C. § 1985(3) to conduct that intimidates people from offering their
support or advocacy of candidates for federal office or injures people on account of such support
or advocacy.

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Amici believe that their brief may be of assistance to the Court by identifying and concisely
discussing critical legal issues that are central to the case and by highlighting the potential
consequences of the theories advanced by the Defendants.
CONCLUSION
For the foregoing reasons, the movants respectfully request that their motion for leave to
file a brief as amici curiae be granted, and that the Court order that the accompanying brief be filed
in this case.
Dated this 8th day of December 2017.
Respectfully submitted,

/s/ Paul M. Smith
Paul M. Smith, DC Bar No. 358870
CAMPAIGN LEGAL CENTER
1411 K Street, NW, Suite 1400
Washington, D.C. 20005
Tel.: [phone]
Ruth M. Greenwood (pro hac vice pending)
CAMPAIGN LEGAL CENTER
73 W Monroe St, Suite 322
Chicago, IL 60603
Tel.: [phone]
Counsel for Amici Curiae

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CERTIFICATE OF SERVICE
I hereby certify that on December 8, 2017, I electronically filed the foregoing Motion with
supporting Brief and Proposed Order with the Clerk of the Court of the U.S. District Court of the
District of Columbia by using the CM/ECF system, which will accomplish electronic notice and
service for all counsel of record.
/s/ Paul M. Smith
Paul M. Smith
CAMPAIGN LEGAL CENTER
1411 K Street, NW, Suite 1400
Washington, D.C. 20005
Tel.: [phone]
Dated: December 8, 2017

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