Perry v. Judd et al

Filing 52

MOTION for Leave to File Amicus Brief by American Civil Liberties Union of Virginia, Inc.. (Attachments: # 1 Amicus brief)(Glenberg, Rebecca)

IN THE UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF VIRGINIA
Richmond Division
THE HONORABLE RICK PERRY,
Plaintiff,
and
THE HONORABLE NEWT GINGRICH,
THE HONORABLE JON HUNTSMAN, JR.,
and THE HONORABLE RICK
SANTORUM,
Intervenors,
v.
CHARLES JUDD, Member of the Virginia
State Board of Elections, in his official
capacity, et al.,
Defendants.

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Civil Action No. 3:11-CV-856

MOTION OF AMERICAN CIVIL LIBERTIES UNION OF VIRGINIA, INC.,
FOR LEAVE TO FILE AMICUS BRIEF

The American Civil Liberties Union of Virginia, Inc., by counsel, respectfully requests
the Court for leave to file a brief amicus curiae in support of the plaintiffs’ motion for a
preliminary injunction. In support of this motion, amicus states as follows:
1.

The American Civil Liberties Union of Virginia (ACLU of Virginia) is an affiliate

of the American Civil Liberties Union, the nation’s oldest organization dedicated to protecting
civil liberties. Among the ACLU of Virginia’s top priorities are the right to vote and the right to
free speech, both of which are implicated by this case.

2.

The ACLU of Virginia appears frequently in this Court and other federal and state

courts in Virginia, both as amicus and as direct counsel, in cases affecting the civil and
constitutional rights of Virginia residents.
3.

Amicus seeks to file a brief in support of plaintiffs’ motion for preliminary

injunction on the following issue: Whether Virginia’s residency requirement for circulators of
petitions for a candidate’s access to the primary ballot violates the First Amendment to the
United States Constitution.
4.

Amicus respectfully suggests that its expertise in the matter of First Amendment

rights will be helpful to the Court in its consideration of the plaintiffs’ request for a preliminary
injunction.
For the foregoing reasons, amicus respectfully requests that the Court grant its motion for
leave to file a brief amicus curiae.
Respectfully submitted,
AMERICAN CIVIL LIBERTIES UNION OF VIRGINIA, INC.

/s/
Rebecca K. Glenberg (VSB No. 44099)
American Civil Liberties Union of
Virginia Foundation, Inc.
530 E. Main Street, Suite 310
Richmond, Virginia 23219
[phone]
[phone] (fax)
[e-mail]

CERTIFICATE OF SERVICE
I hereby certify that on this 10th day of January, 2012, I filed a true and correct copy of
the foregoing with the Clerk of Court using the CM/ECF system, which will automatically serve
an electronic copy on the following:
Hugh McCoy Fain, III
Edward Everett Bagnell , Jr
Maurice Francis Mullins
Spotts Fain PC
411 E Franklin St
PO Box 1555
Richmond, VA 23218-1555
[e-mail]
[e-mail]
[e-mail]
James Edwin Trainor , III
Joseph Michael Nixon
Martin Douglas Beirne
Beirne Maynard & Parsons LLP
1300 Post Oak Blvd. 25th Fl
Houston, TX 77056
[e-mail]
[e-mail]
[e-mail]

Earle Duncan Getchell , Jr.
Wesley Glenn Russell , Jr.
Office of the Attorney General
900 E Main St
Richmond, VA 23219
[e-mail]
[e-mail]
Charles Michael Sims
LeClairRyan, PC
PO Box 2499
Richmond, VA 23218-2499
[e-mail]
John Christian Adams
Election Law Center PLLC
300 N Washington St, Suite 405
Alexandria, VA 22314
[e-mail]

/s/
Rebecca K. Glenberg (VSB No. 44099)
American Civil Liberties Union of Virginia
Foundation, Inc.
530 E. Main St., Suite 310
Richmond, Virginia 23219
[phone]
[phone] (fax)
[e-mail]