Perry v. Judd et al

Filing 29

Letter. (Attachments: # 1 Letter Letter to Court consenting to representation by plaintiff interven.)(Adams, John)

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
RICHMOND DIVISION

THE HONORABLE NEWT GINGRICH, THE
HONORABLE JON HUNTSMAN, JR.,
and THE HONORABLE RICK SANTORUM
Proposed Plaintiffs-Intervenors,
Civil No. 3:11-CV-856
vs.
CHARLES JUDD, KIMBERLY
BOWERS, and DON PALMER, members
of the Virginia State Board of Elections, in
their official capacities, and PAT MULLINS,
in his official capacity as Chairman of the
Republican Party of Virginia,
Defendants.
__________________________________________/

CONSENT LETTER OF PARTIES TO LEGAL REPRESENTATION
To the Honorable Court:
In an Order dated January 4, 2012, this Court requested Counsel for Plaintiffs in
Intervention, J. Christian Adams to file either a signed consent form from the General Counsel
for the Plaintiffs in Intervention, or in the alternative, an explanation as to why no conflict of
interest exists in this representation.
The signed consent executed by the general counsels for Plaintiffs in Intervention is
included as an attachment to this pleading.
Further, by way of explanation, the parties here have uniform interests. In particular the
parties have uniform interests in the remedy sought in this case - being added to the ballot in the
2012 Virginia Republican Primary. While the parties may indeed be seeking the same office, all

are in uniform agreement on the central issue in this case, that they should be added to the ballot.
Remaining mindful of any conflict which may arise, and the associated professional obligations,
the narrow issues now before this court do not create adverse interests between intervening
plaintiffs precluding representation. Moreover, the issue before this court, and the uniform
remedy sought, does not now materially limit representation of any intervening plaintiff as
compared to the interests of another intervening plaintiff. Counsel for the intervening parties
have considered carefully the implications of this representation and have concluded, as have I,
that the narrow issues before this court do not, in fact, create a conflict between intervening
plaintiffs on the matters which are the subject of this intervention.
Respectfully submitted,

________/S/_______________
J. Christian Adams
Election Law Center, PLLC
300 N. Washington St., Suite 405
Alexandria, VA 22314
Tel: [phone]
Fax: [phone]
[e-mail]
Virginia Bar #42543

Stefan C. Passantino
J. Randolph Evans
Benjamin P. Keane
McKenna Long & Aldridge, LLP
1900 K St. NW
Washington, DC 20009
Tel: [phone]
Fax: [phone]
ATTORNEYS FOR
PLAINTIFF-INTERVENOR NEWT
GINGRICH
Pro Hac Vice applications to be filed

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Craig Engle
Arent Fox LLP
1050 Connecticut Avenue, NW
Washington, DC 20036-5339
Tel: [phone]
Fax: [phone]
ATTORNEY FOR
PLAINTIFF-INTERVENOR JON
HUNTSMAN, JR.
Pro Hac Vice application to be filed

Cleta Mitchell
Foley & Lardner LLP
3000 K Street, N.W.
Suite 600
Washington, DC 20007-5109
Tel: [phone]
Fax: [phone]
ATTORNEY FOR
PLAINTIFF-INTERVENOR RICK
SANTORUM
Pro Hac Vice application to be filed

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CERTIFICATE OF SERVICE
I hereby certify that on the 4th day of January, 2012, I have electronically filed the foregoing
with the Clerk of Court using the CM/ECF system, which will then send a notification of such filing
(NEF) to the following:

Hugh M. Fain, III (VSB No. 26494)
Email: [e-mail]
M. F. Connell Mullins, Jr. (VSB No. 47213)
Email: [e-mail]
Edward Everett Bagnell, Jr. (VSB No. 74647)
Email: [e-mail]
SPOTTS FAIN PC
411 East Franklin Street, Suite 600
Richmond, Virginia 23219
Telephone: [phone]
Facsimile: [phone]
Counsel for The Honorable Rick Perry
Joseph M. Nixon (Admitted pro hac vice)
Email: [e-mail]
James E. (“Trey”) Trainor, III (Admitted pro hac vice)
Martin D. Beirne (Admitted pro hac vice)
Email: [e-mail]
BEIRNE, MAYNARD & PARSONS, L.L.P.
1300 Post Oak Boulevard, Suite 2500
Houston, TX 77056
Telephone: [phone]
Facsimile: [phone]
Counsel for The Honorable Rick Perry
E. Duncan Getchell, Jr.
Wesley G. Russell
Office of the Attorney General
900 East Main Street
Richmond, Virginia 23219
Telephone [phone]
[e-mail]
[e-mail]
Counsel for Charles Judd, Kimberly Bowers
and Don Palmer, members of the Virginia
State Board of Elections, in their official capacity
Joseph N. Lief
Virginia International Raceway
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1245 Pinetree Road
Alton, Virginia 24520
Telephone: [phone]
Counsel for Charles Judd, Kimberly Bowers
and Don Palmer, members of the Virginia
State Board of Elections, in their official capacity

Lee Elton Goodman
[e-mail]
LeClairRyan, A Professional Corporation
1701 Pennsylvania Ave NW
Suite 1045
Washington, DC 20006
Counsel for Pat Mullins,
in his official capacity as
Chairman of the Republican Party of Virginia.
Charles M. Sims (VSB No. 35845)
LeClairRyan, A Professional Corporation
Riverfront Plaza, East Tower
951 East Byrd Street, Eighth Floor
Richmond, Virginia 23219
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Counsel for Patrick Mullins,
Chairman of the Republican Party of Virginia
Respectfully submitted this 4th day of January, 2012.

_________ /S/_____________
J. Christian Adams
Virginia Bar #42543
Election Law Center, PLLC
300 N. Washington St., Suite 405
Alexandria, VA 22314
Tel: [phone]
Fax: [phone]
[e-mail]

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