Perry v. Judd et al

Filing 97

Consent MOTION to Dismiss by Jon Huntsman, Rick Santorum. (Attachments: # 1 Proposed Order)(Adams, John)

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
RICHMOND DIVISION
THE HONORABLE RICK PERRY,
Plaintiff,
v.
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.

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Civil No. 3:11-cv-856

MOTION TO DISMISS
OF PLAINTIFF INTERVENORS RICK SANTORUM AND JON HUNTSMAN

Plaintiff-Intervenors, Jon Huntsman and Rick Santorum, by counsel, pursuant to Federal
Rule of Civil Procedure 41(a)(2) hereby move to dismiss their claims in the above styled action.
As set forth in the Certificate of Conference appended hereto, Counsel for PlaintiffIntervenors Jon Huntsman and Rick Santorum have contacted counsel for all parties and all
consent to the dismissal of Plaintiff-Intervenors Jon Huntsman and Rick Santorum from this
action.
WHEREFORE, Plaintiff-Intervenors respectfully pray that the Court grant this Motion,
and dismiss Plaintiff-Intervenors Jon Huntsman and Rick Santorum from this action, with this
matter to otherwise remain pending for further adjudication and resolution of the claims of the
Plaintiff-Intervenor Newt Gingrich.

January 27, 2012

Respectfully Submitted,
The Hon. Jon Huntsman
The Hon. Rick Santorum

________/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

CERTIFICATE OF CONFERENCE
Counsel for all parties has been contacted regarding this motion and all have consented to
the dismissal of Jon Huntsman and Rick Santorum from this action.
/s/ J. Christian Adams
J. Christian Adams

CERTIFICATE OF SERVICE
I hereby certify that on January 27, 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

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Richmond, Virginia 23219
Telephone: [phone]
[e-mail]
[e-mail]
Counsel for Defendants 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: [phone]
Counsel for Defendants 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
[e-mail]
Counsel for Defendant 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 Defendant Pat Mullins, in his official capacity as Chairman of the Republican Party
of Virginia

Hugh M. Fain, III (VSB No. 26494)
M. F. Connell Mullins, Jr. (VSB No. 47213)
Edward Everett Bagnell, Jr. (VSB No. 74647)
Spotts Fain PC
411 East Franklin Street, Suite 600
Richmond, Virginia 23219
Telephone: [phone]

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Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]
Email: [e-mail]
Counsel for Plaintiff Rick Perry

Joseph M. Nixon
James E. (“Trey”) Trainor, III
Martin D. Beirne
Beirne, Maynard & Parsons, L.L.P.
1300 Post Oak Boulevard, Suite 2500
Houston, TX 77056
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Counsel for Plaintiff Rick Perry

________/S/_______________
J. Christian Adams
Election Law Center, PLLC
300 N. Washington St., Suite 405
Alexandria, VA 22314
Tel: [phone]
Fax: [phone]
[e-mail]
Attorney for Plaintiff-Intervenors
Jon Huntsman and Rick Santorum

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