Perry v. Judd et al
Filing
30
AMENDED COMPLAINT against Kimberly Bowers, Charles Judd, Pat Mullins, Don Palmer, filed by Rick Perry. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G)(Bagnell, Edward)
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
RICHMOND DIVISION
THE HONORABLE RICK PERRY,
Plaintiff,
NEWT GINGRICH, JON HUNTSMAN,
JR., and RICK SANTORUM
Intervernor-Plaintiffs
v.
CHARLES JUDD, KIMBERLY
BOWERS, and DON PALMER,
members of the Virginia Board of
Elections, in their official capacities, and
PAT MULLINS, in his official capacity
as Chairman of the Republican Party of
Virginia,
Defendants.
§
§
§
§
§
§
§
§
§
§
§
§
§
§
§
§
§
§
§
§
Civil No. 3:11-CV-856
FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE
RELIEF
Pursuant to Federal Rule of Civil Procedure 15(a)(1)(A), The Honorable Rick Perry
files this First Amended Complaint and complains against Defendants as follows:
INTRODUCTION
1.
Plaintiff Rick Perry is a candidate for the office of President of the United
States. The dispute between Plaintiff and Defendant members of the Virginia State Board of
Elections (the “Board”) arises from Plaintiff’s efforts to qualify for the March 6, 2012
Republican Primary election ballot.
-1-
2.
The Board, based on information and belief, has developed, adopted and
implemented the use of a form for collecting petition signatures that it has failed to preclear
pursuant to Section 5 of the Voting Rights Act of 1965. 42 U.S.C. § 1973c.
3.
The Board adopted and implemented ballot access requirements on May 25,
2011. Based upon information and belief, the Board did not preclear the use of these ballot
access requirements and has implemented those requirements statewide.
4.
Defendant Mullins published a letter outlining ballot access requirements
which also was not precleared but implemented statewide.
5.
Defendant Mullins failed to certify Plaintiff for the March 6, 2012 Republican
Primary ballot because Plaintiff did not submit a requisite number of signatures, as required
by Defendant Mullins, even though VA. CODE ANN. § 24.2-545 B makes the submission of
signatures discretionary, rather than a mandatory requirement for ballot access in the
presidential primary.
6.
Additionally, Plaintiff was unable to obtain the requisite number of signatures
from qualified voters, as required by Defendant Mullins, to qualify for the Republican Party
presidential primary ballot because of the Board’s further requirement that all petition
circulators be an eligible or registered qualified voter in Virginia.
7.
This additional requirement that petition circulators be either eligible or
registered qualified voters in Virginia violates Plaintiff’s freedoms of speech and
association protected by the First and Fourteenth Amendments to the United States
Constitution. By enforcing the petition signature collection requirements in connection with
Plaintiff’s candidacy, Defendants have violated the rights of Plaintiff to engage in protected
speech and association activities under the United States Constitution.
-2-
8.
Because Plaintiff seeks access to the March 6, 2012 Republican Party primary
ballot, because the deadline for printing those ballots is quickly approaching, because it is
highly unlikely that the Board will obtain preclearance of the petition gathering form, and
because Plaintiff has no adequate remedy at law, this Complaint seeks declaratory and
injunctive relief in the form of preliminary and permanent injunctions.
JURISDICTION AND VENUE
9.
This Court has jurisdiction pursuant to 28 U.S.C. §§ 1331, 1343, 1357, and
2284; and pursuant to 42. U.S.C. §§ 1973c, 1973j(f). Plaintiff’s action for declaratory and
injunctive relief is authorized by 28 U.S.C. §§ 2201, 2202, and 2284, as well as by Federal
Rules of Civil Procedure 57 and 65.
10.
Venue is proper in this district, and in the Richmond Division, because
Defendants are residents of or have their official offices in the Eastern District of Virginia, in
the City of Richmond. 28 U.S.C. § 1391(b)(1); E.D. Va. R. 3(C).
11.
Plaintiff requests a three-judge court be convened to hear this cause pursuant to
28 U.S.C. § 2284 and 42 U.S.C. § 1973c.
PARTIES
12.
Plaintiff Rick Perry is a resident and Governor of the State of Texas. Governor
Perry satisfies all the requirements of Article II, Section 1, clause 5 of the United States
Constitution and is otherwise eligible and qualified to serve as President of the United States.
13.
Intervenor Plaintiff Newt Gingrich is a resident of the Commonwealth of
Virginia and former Speaker of the United States House of Representatives from the State of
Georgia. Speaker Gingrich satisfies all the requirements of Article II, Section 1, clause 5 of
-3-
the United States Constitution and is otherwise eligible and qualified to serve as President of
the United States.
14.
Intervenor Plaintiff Jon Huntsman, Jr. is a resident and former Governor of the
State of Utah. Governor Huntsman satisfies all the requirements of Article II, Section 1,
clause 5 of the United States Constitution and is otherwise eligible and qualified to serve as
President of the United States.
15.
Intervernor Plaintiff Rick Santorum is a resident of the Commonwealth of
Virginia and former U.S. Senator for the Commonwealth of Pennsylvania. Senator Santorum
Huntsman satisfies all the requirements of Article II, Section 1, clause 5 of the United States
Constitution and is otherwise eligible and qualified to serve as President of the United States.
16.
As officers and members of the Virginia State Board of Elections (State
Board), Defendants Charles Judd (Chairman), Kimberly Bowers (Vice-Chair), and Don
Palmer (Secretary) have authority to make rules and regulations, issue instructions, and
provide information consistent with the election laws, including VA. CODE ANN. § 24.2-545
B, to the county and city electoral boards and registrars to promote the proper administration
of election laws. VA. CODE ANN. § 24.2-103.
17.
As Chairman of the Republican Party of Virginia (the “Party”), Defendant Pat
Mullins, in his official capacity Chairman of the Party, is responsible for certifying to the
State Board all candidates who meet the statutory requirements for placement on the ballot.
VA. CODE ANN. § 24.2-545 B. The State Party is one of only two parties recognized in
Virginia as a political party. Va. Code Ann. § 24.2-101.
-4-
STATUTORY SCHEME
18.
In Virginia, a candidate seeking the nomination of a national political party for
the Office of President of the United States must complete a Consent/Declaration Form. VA.
CODE ANN. § 24.2-545 B. See Exhibit A.
19.
A candidate “may” then file petitions with the Board signed by at least 10,000
qualified voters, including at least 400 qualified voters from each congressional district in the
Commonwealth, who attest that they intend to participate in the primary of the same political
party as the candidate for whom the petitions are filed. VA. CODE ANN. § 24.2-545 B.
20.
If a candidate files signature petitions from at least 10,000 qualified voters,
then based upon the official form prescribed by the Board, such petition signatures must be
collected after July 1, 2011 by a registered voter or someone eligible to vote in Virginia who
signs and in the petition in the presence of a notary. See Exhibit B.
21.
In that event, the petitions must be filed by the primary filing deadline. VA.
CODE ANN. § 24.2-545 B. Here that deadline was Thursday, December 22, 2011. VA. CODE
ANN.§ 24.2-544 B.
22.
The State Board then turns the petitions over to the State Party. VA. CODE
ANN.§ 24.2-544 B.
23.
By the statutory deadline, the State Party certifies to the State Board the
candidates who are qualified to appear on the presidential primary ballot. Va. Code Ann. §§
24.2.-527 and 24.2-544 B.
The deadline for the Republican presidential primary was
Tuesday, December 27, 2011 by 5:00 PM.
24.
The State Board conducts a drawing of candidate names for placement on the
presidential primary ballot. VA. CODE ANN. § 24.2-545 C.
-5-
FACTS
25.
The Commonwealth of Virginia is covered by the Civil Rights Act of 1965, as
amended, (the “Act”)1 and must comply with certain procedures under the Act. 42. U.S.C. §
1973c.
Among the Act’s provisions is the Section 5 preclearance requirement, which
requires states covered by the Act to obtain federal approval of any state enactment which
alters the election laws or the jurisdiction, no matter how minor the change. Georgia v.
United States, 411 U.S. 526 (1973).
26.
On or about May 25 2011, the Board adopted “Deadlines, Duties and Ballot
Access Requirements” for the March 6, 2012 Presidential Primary Election (see Exhibit C)
and a form for the collection of petition signatures to be used by candidates for Office of
President of the United States. See Exhibit B.
27.
Based upon information and belief, the Board has not obtained preclearance of
the deadlines, duties and ballot access requirements or the form for the collection of petition
signatures to be used by candidates for the Office of President of the United States pursuant to
section 5 of the Voting Rights Act of 1965 and has implemented the use of them throughout
the Commonwealth.
28.
On or about May 2011, Defendant Mullins adopted guidelines to be used by
him for certifying Republican Presidential and Senatorial primary candidates which mirrored
the statutory scheme above in part but also created a safe-harbor for candidates that submitted
at least 15,000 signatures of registered voters on valid petitions statewide and had at least 600
1
Fourteen counties (Amherst, Augusta, Botetourt, Essex, Frederick, Greene, Middlesex, Page, Pulaski,
Roanoke, Rockingham, Shenandoah, Washington and Warren) and four independent cities (Fairfax,
Harrisonburg, Salem and Winchester) are excluded from coverage by the Act.
-6-
signatures of registered voters on valid petitions from each of the 11 Congressional Districts.
See Exhibit D
29.
Based on information and belief, Defendant Mullins and the Republican Party
of Virginia have not obtained preclearance of the guidelines or safe harbor provisions
pursuant to section 5 of the Voting Rights Act of 1965 and have implemented this change in
procedure throughout the Commonwealth.
30.
Plaintiff declared himself a candidate for the Office of President of the United
States on August 13, 2011.
31.
On August 15, 2011, Plaintiff filed his Statement of Candidacy with the
Federal Elections Commission. See Exhibit E.
32.
On October 31, 2011, Plaintiff signed and affirmed, in the presence of a notary,
his Declaration of Candidacy for the Commonwealth of Virginia. See Exhibit F.
33.
On December 22, 2011, Plaintiff submitted to the Board over 6,000 petition
signatures from qualified Virginia voters.
34.
On December 23, 2011, Defendant Mullins made a preliminary determination
and publically announced that Plaintiff had not submitted enough petition signatures, as
required by Defendant Mullins, and would not certify Plaintiff for placement on the
presidential primary ballot, even though the signature petition component in VA. CODE ANN. §
24.2-545 B is permissive and not mandatory. See Exhibit G. Defendants have thus misapplied
VA. CODE ANN. § 24.2-545 B.
35.
Additionally, Virginia’s requirement for petition circulators to be either
eligible or registered qualified voters in the state imposes a severe burden on Plaintiffs’
-7-
freedoms of speech and association because it substantially limits the number of eligible
petition circulators.
36.
Virginia’s requirement for petition circulators to be either eligible or registered
qualified voters in the state is a severe burden on Plaintiff’s freedoms of speech and
association because it prohibits an otherwise qualified candidate for the Office of President of
the United States from circulating his own candidate petitions.
37.
Virginia’s requirement for petition circulators to be either eligible or registered
qualified voters in the state prohibited Plaintiff from recruiting petition circulators who live
outside the Commonwealth of Virginia to circulate petitions on his behalf.
38.
Plaintiffs have no adequate remedy at law.
COUNT 1
SUBMISSION OF PETITION SIGNATURES IS DISCRETIONARY
39.
Plaintiffs re-allege and incorporate by reference all of the allegations contained
in all of the preceding paragraphs.
40.
The plain language of VA. CODE ANN. § 24.2-545 B makes the submission of
signature petitions permissive and not mandatory, as stated by Defendant Mullins, as a means
of gaining access to the presidential primary ballot for the Commonwealth of Virginia.
Specifically, the statute states:
Any person seeking the nomination of the national political party for
the office of President of the United States, or any group organized in
this Commonwealth on behalf of, and with the consent of such person,
may file with the State Board petitions signed by at least 10,000
qualified voters, including at least 400 qualified voters from each
congressional district in the Commonwealth, who attest that they intend
to participate in the primary of the same political party as the candidate
for whom the petitions are filed. Such petitions shall be filed with the
State Board by the primary filing deadline. Such petitions shall be filed
with the State Board by the primary filing deadline. The petitions shall
-8-
be on a form prescribed by the State Board and shall be sealed in one or
more containers to which is attached a written statement giving the
name of the presidential candidate and the number of signatures on the
petitions contained in the containers. Such person or group shall also
attach a list of the names of persons who would be elected delegates
and alternate delegates to the political party's national convention if the
person wins the primary and the party has determined that its delegates
will be selected pursuant to the primary. The slate of delegates and
alternates shall comply with the rules of the national and state party.
The State Board shall transmit the material so filed to the state
chairman of the party of the candidate immediately after the primary
filing deadline. The sealed containers containing the petitions for a
candidate may be opened only by the state chairman of the party of the
candidate. The state chairman of the party shall, by the deadline set by
the State Board, furnish to the State Board the names of all candidates
who have satisfied the requirements of this section. Whenever only one
candidate for a party's nomination for President of the United States has
met the requirements to have his name on the ballot, he will be declared
the winner and no presidential primary for that party will be held.
VA. CODE ANN. § 24.2-545 B (emphasis added).
41.
In Zinone v. Lee’s Crossing Homeowner’s Association, et al., 714 S.E.2d 922
(Va. S. Ct. 2011), the Virginia Supreme Court held that when the General Assembly of the
Commonwealth uses permissive “may” language in a statute and then uses “shall” language in
the same statute to address a similar subject, it must be presumed that the difference in the
choice of language was intentional. As the Virginia Supreme Court explained:
‘We look to the plain meaning of the statutory language, and presume
that the legislature chose, with care, the words it used when it enacted
the relevant statute.’ Moreover, when the General Assembly has used
specific language in one instance, but omits that language and when
addressing a similar subject elsewhere in the Code, we must presume
that that the difference in the choice of language was intentional.” Id. at
925.
42.
As applied here to VA. CODE ANN. § 24.2-545 B, a careful reading of the
statute shows that the General Assembly used, and “chose with care,” permissive “may”
language in describing the signature component. The General Assembly then used mandatory
-9-
“shall” language in specifying the form and substance of any signature petitions, if filed. In
short, this shows that the General Assembly intended to make the signature petition
component in VA. CODE ANN. § 24.2-545 B discretionary on the part of a candidate for the
presidential primary, and not mandatory as directed by Defendants. There is no basis for
Defendants to impose a different standard than the General Assembly did in VA. CODE ANN. §
24.2-545 B.
The Defendants’ refusal to certify Plaintiff for the March 6, 2012 Republican
Primary ballot is therefore based on a misapplication of VA. CODE ANN. § 24.2-545 B and
must be vacated by this Court.
COUNT 2
DEFENDANTS HAVE NOT PRECLEARED THE BALLOT ACCESS SCHEME
ADOPTED IN MAY 2011
43.
Plaintiff re-alleges and incorporates by reference all of the allegations
contained in paragraphs 1 through 38 above.
44.
Assuming arguendo, and without waiving any other arguments, that petition
signatures are required by a candidate for Office of the President of the United States to gain
access to the Republican Party primary ballot, the statute in question requires them to “…be
on a form prescribed by the …Board….” VA. CODE ANN. § 24.2-545 B.
45.
The form promulgated by the Board for use by the candidates for the Office of
President of the United States cannot be administered because it has not been precleared
pursuant to Section 5 of the Voting Rights Act of 1965, as amended. 42 U.S.C. § 1973c.
46.
Because the form has not been precleared, Plaintiff is entitled to a Temporary
Restraining Order and Preliminary Injunction prohibiting the implementation and use of the
unprecleared form for this election. Plaintiff is further entitle to have this Court, acting as a
single judge, to establish a remedy for the unprecleared use of the form as means of denying
- 10 -
Plaintiff access to the march 6, 2012 Republican Party primary ballot.
28 U.S.C. §
2284(b)(3).
47.
Plaintiff requests that, pursuant to 28 U.S.C. § 2284 and 42 U.S.C § 1973c, a
three-judge court be convened to hear this cause.
COUNT 3
THE REQUIREMENT THAT PETITION CIRCULATORS BE
VIRGINIA RESIDENTS IS UNCONSTITUTIONAL
48.
Plaintiff re-alleges and incorporates by reference all of the allegations
contained in paragraphs 1 through 38 above.
49.
In Buckley v. American Constitutional Law Foundation, 525 U.S. 182 (1999)
(“ACLF”), the Supreme Court held that a Colorado law requiring all petition circulators to be
registered Colorado voters violated the First Amendment to the United States Constitution.2
The Court held that the restriction imposed severe burdens on core political speech, id. at 192,
was subject to strict scrutiny, id. at 192 n.12, and that the state’s interests were not sufficient
to justify the burdens, id. at 192.
50.
Applying the ACLF standard, numerous courts have ruled that state- or district-
residency requirements violate the First Amendment. See Yes on Term Limits, Inc. v. Savage,
550 F.3d 1023 (10th Cir. 2008) (state-residency requirement); Nader v. Brewer, 531 F.3d
1028 (9th Cir. 2008) (same); Nader v. Blackwell, 545 F.3d 459 (6th Cir. 2008) (same);
Chandler v. City of Arvada, 292 F.3d 1236 (10th Cir. 2002) (city-residency requirement);
Lerman v. Bd. of Elections in the City of New York, 232 F.3d 135 (2d Cir. 2000) (district2
The American Constitutional Law Foundation did not challenge Colorado’s residency requirement
because the registration requirement also required a circulator to reside in Colorado. ACLF, 525 U.S.
at 189 n.3. Virginia’s requirement is more restrictive than the Colorado provision. In Virginia, not
only must the circulator be a qualified voter (i.e., a Virginia resident), but he must also be eligible to
vote for the candidate for whom he is circulating the petition.
- 11 -
residency requirement); Krislov v. Rednour, 226 F.3d 851 (7th Cir. 2000) (state- and districtresidency requirements); Bogaert v. Land, 572 F. Supp. 883 (W.D. Mich. 2008) (districtresidency requirement); Frami v. Ponto, 255 F. Supp. 2d 962 (W.D. Wis. 2003) (same);
Morrill v. Weaver, 224 F. Supp. 2d 882 (E.D. Penn. 2002) (same).
51.
VIRGINIA CODE § 24.2-545 B’s requirement for petition circulators to be either
eligible or registered qualified voters in the state violates freedoms of speech and association
protected by the First and Fourteenth Amendments to the United States Constitution.
52.
Virginia’s unconstitutional requirement for petition circulators to be either
eligible or registered qualified voters in the state prohibited Plaintiff from recruiting other
petition circulators and obtaining the necessary petition signature for ballot access.
COUNT 4
THE 10,000 SIGNATURE REQUIREMENT IS UNCONSTITUTIONAL
53.
Plaintiff re-alleges and incorporates by reference all of the allegations
contained in paragraphs 1 through 38 above.
54.
Virginia’s requirement that a presidential primary candidate collect signatures
from 10,000 qualified voters, including at least 400 qualified voters from each congressional
district in the Commonwealth, who attest that they intend to participate in the primary of the
same political party as the candidate for whom the petitions are signed and filed violates
freedoms of speech and association protected by the First and Fourteenth Amendments to the
United States Constitution.
PRAYER FOR RELIEF
Based on each and all of the grounds set forth above, Plaintiff respectfully prays that
the Court grant and issue the following relief:
- 12 -
1.
Issue declaratory relief that the permissive “may” language in VA. CODE ANN.
§ 24.2-545 B makes the signature petition component in the statute discretionary;
2.
Vacate Defendants’ refusal to certify Plaintiff for the March 6, 2012
Republican Primary ballot because such refusal is based on a misapplication of VA. CODE
ANN. § 24.2-545 B;
3.
Issue a temporary restraining order, preliminary and permanent injunctions
enjoining the Defendants, their agents, employees, and those persons acting in concert with
them, from enforcing or giving any effect to the form promulgated by the Board for use by
candidates for collecting petition signatures for the Office of President of the United States;
4.
Issue declaratory relief that the requirement for petition circulators to be either
eligible or registered qualified voters in the state provision contained in VA. CODE ANN. §
24.2-545 B is facially unconstitutional and/or as applied to Plaintiffs and facially;
5.
Issue preliminary and permanent injunctive relief enjoining Defendants, and all
successors in office, from enforcing the requirement for petition circulators to be either
eligible or registered qualified voters in the state;
6.
Issue preliminary and permanent mandatory injunctive relief compelling
Defendants to certify Plaintiff as a candidate for the Republican Party presidential primary
ballot;
7.
Award reasonable costs and attorneys’ fees, incurred as a consequence of
Plaintiff’s efforts to safeguard his constitutionally protected rights, pursuant to 42 U.S.C. §
1988, 42 U.S.C. § 1973l(e), and any other statute or authority; and
- 13 -
8.
Issue any other relief this Court in its discretion deems just and appropriate.
Date: January 5, 2012
Respectfully Submitted,
THE HONORABLE RICK PERRY
____
/s/ _________________ ___ _
Hugh M. Fain, III (VSB No. 26494)
Email: hfain@spottsfain.com
M. F. Connell Mullins, Jr. (VSB No. 47213)
Email: cmullins@spottsfain.com
Edward Everett Bagnell, Jr. (VSB No. 74647)
Email: ebagnell@spottsfain.com
SPOTTS FAIN PC
411 East Franklin Street, Suite 600
Richmond, Virginia 23219
Telephone: (804) 697-2000
Facsimile: (804) 697-2100
Joseph M. Nixon (Pro hac vice application pending)
Email: jnixon@bmpllp.com
James E. (“Trey”) Trainor, III (Pro hac vice to be
filed)
Martin D. Beirne (Pro hac vice application pending)
BEIRNE, MAYNARD & PARSONS, L.L.P.
1300 Post Oak Boulevard, Suite 2500
Houston, TX 77056
Telephone: (713) 623-0887
Facsimile: (713) 960-1527
ATTORNEYS FOR PLAINTIFF
THE HONORABLE RICK PERRY
- 14 -
CERTIFICATE OF SERVICE
I hereby certify that on January 5, 2012, I will electronically file the foregoing
document with the Clerk of the Court using the CM/ECF System, which will then send a
notification of such filing (NEF) to all counsel of record:
E. Duncan Getchell, Jr.
Wesley G. Russell
Office of the Attorney General
900 East Main Street
Richmond, Virginia 23219
Telephone: (804) 786-2436
dgetchell@oag.state.va.us
wrussell@oag.state.va.us
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
1245 Pinetree Road
Alton, Virginia 24520
Telephone: (434) 822-7700
Counsel for Charles Judd, Kimberly Bowers
and Don Palmer, members of the Virginia
State Board of Elections, in their official
capacity
Lee Elton Goodman
LeClairRyan, A Professional Corporation
1701 Pennsylvania Ave NW
Suite 1045
Washington, DC 20006
lee.goodman@leclairryan.com
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: (804) 343-5091
Facsimile: (804) 783-7655
Charles.sims@leclairryan.com
Counsel for Patrick Mullins,
Chairman of the Republican Party of
Virginia
J. Christian Adams (VSB No. 42543)
Election Law Center, PLLC
300 N. Washington St., Suite 405
Alexandria, VA 22314
Telephone: (703) 963-8611
Facsimile: (703) 740-1773
adams@electionlawcenter.com
Counsel for Newt Gingrich, Jon Huntsman,
Jr.
and Rick Santorum
Stefan C. Passantino
J. Randolph Evans
Benjamin P. Keane
McKenna Long & Aldridge, LLP
1900 K St. NW
Washington, DC 20009
Telephone: (202) 496-7500
Facsimile: (202) 496-7756
Counsel for Newt Gingrich
- 15 -
Craig Engle
Arnet Fox LLP
1050 Connecticut Avenue, NW
Washington, DC 20036-5339
Telephone: (202) 857-6000
Facsimile: (202) 857-6395
Counsel for Jon Huntsman, Jr.
Cleta Mitchell
Foley & Lardner LLP
3000 K Street, N.W., Suite 600
Washington, DC 20007-5109
Telephone: (202) 672-5300
Facsimile: (202) 672-5399
Counsel for Rick Santorum
____
/s/ _________________ ___ _
Edward Everett Bagnell, Jr. (VSB No. 74647)
Email: ebagnell@spottsfain.com
SPOTTS FAIN PC
411 East Franklin Street, Suite 600
Richmond, Virginia 23219
Telephone: (804) 697-2000
Facsimile: (804) 697-2100
- 16 -
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?