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6:09-cv-01022-HFF Date Filed 04/16/2009 Entry Number 1 Page 18 of 19 B. That this Court render a Declaratory Judgment declaring S.C. Code Sections 7-5-420, 7-5-610, 7-11-30, 7-13-15, 7-15-320, and 7-15-395 unconstitutional under the United States Constitution, on their face and as applied to the Plaintiffs, and declaring that the Defendant, Defendant’s officers, agents, employees and all other persons acting in active concert with him, unlawfully obstructed the Plaintiffs from exercising the Plaintiffs’ constitutionally protected rights; C. That this Court issue Preliminary and Permanent Injunctions, and that this Court render a Declaratory Judgment declaring that the Defendant, Defendant’s officers, agents, employees and all other persons acting in active concert with him, immediately comply with the provisions of S.C. Code Section 7- 9-40 that membership in a political party in through the club in the voting precinct set forth in their respective registration records, and no person may vote in any primary except in the club of the voting precinct; D. That this Court adjudge, decree and declare the rights and other legal relations with the subject matter <strong>here</strong> in controversy, in order that such declaration shall have the force and effect of final judgment; E. That this Court retain jurisdiction of this matter for purpose of enforcing this Court’s order; F. That this Court award Plaintiffs the reasonable costs, fees and expenses of this action in accordance with 42 U.S.C. § 1988; - 18 -
6:09-cv-01022-HFF Date Filed 04/16/2009 Entry Number 1 Page 19 of 19 G. That this Court grant such other and further relief as this Court deems equitable and just under the circumstances. Dated: April 16, 2009 Respectfully Submitted, By: /s/ Samuel D. Harms Samuel D. Harms, III, Esq. District of South Carolina Bar No. 7406 HARMS LAW FIRM, P.A. 33 Market Point Drive Greenville, SC 29607 t: (864) 277-0102 f: (864) 527-0427 Attorney for the Plaintiffs - 19 -
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