1437 Bannock St . Denver , Colorado 80202 - Brennan Center for ...

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Declare that Clerk Johnson may send mail ballots to voters under UMOVA, includingthose who are designated as “inactive-failed to vote”, only upon receipt of an application fromthe voter; andEnter an order enjoining Clerk Johnson from sending mail ballot to electors who aredesignated as “inactive-failed vote” and from mailing ballots to voters under UMOVA who havefailed to submit an application.JOHN W. SUTHERSAttorney General/s/Maurice G. KnaizerMAURICE G. KNAIZER, 05264*Deputy Attorney GeneralLEEANN MORRILL, 38742*Public OfficialsState Services SectionAttorneys for Plaintiff*Counsel of Record36
CERTIFICATE OF SERVICEThis is to certify that I have duly served the within BRIEF IN SUPPORT OFSECRETARY’S CROSS-MOTION FOR SUMMARY JUDGMENT AND INOPPOSITION TO DEFENDANT JOHNSON’S MOTION FOR SUMMARY JUDGMENTupon all parties herein by LexisNexis File and Serve or by email this 7th day of December,2012, as follows:Victoria J. OrtegaStephen HahnAssistant City Attorney201 West Colfax Avenue, Dept. 1207Denver, CO 80202-5332Daniel C. KogovsekPueblo County AttorneyPeter S. BloodAssistant County Attorney215 West 10th StreetPueblo, CO 81003J. Lee GrayHolland & Hart, LLP6380 S. Fiddlers Green Circle, Suite 500Greenwood Village, CO 80111Myrna Perez (PerezM@exchange.law.nyu.edu)Jonathan Brater (braterj@exchange.law.nyu.edu)Brennan Center for Justice161 Avenue of the Americas, 12th floorNew York, NY 10013/s/ Debbie Bendell, Paralegal37
Page 1 and 2: DISTRICT COURT, CITY AND COUNTY OF
Page 3 and 4: • Clerk Johnson contests the Secr
Page 5 and 6: 11. The fact that the form included
Page 7 and 8: 26. The Secretary does not dispute
Page 9 and 10: Colo. Const. art. XX, § 6(d).The p
Page 11 and 12: Code. Section 1-1-107(1)(a)-(c), C.
Page 13 and 14: county. Absent evidence of State Bo
Page 15 and 16: federal law “includes not only a
Page 17 and 18: County Commissioners v. Fifty-first
Page 19 and 20: Election officials must mail a vote
Page 21 and 22: Electors who are designated as “i
Page 23 and 24: voter information card to a registe
Page 25 and 26: the history of election laws plainl
Page 27 and 28: stated, “‘An inference drawn fr
Page 29 and 30: ules because Denver has adopted the
Page 31 and 32: THE SECRETARY IS ENTITLED TO AN INJ
Page 33 and 34: purging procedure and in our view i
Page 35: You go back to the legislature. You
Page 39 and 40: :.INTERROGATORY N0.1: Identify the
Page 41 and 42: (.electors would be mailed ballots
Page 43 and 44: INTERROGATORY NO.lO: Describe all c
Page 45 and 46: INTERROGATORY N0.12: State the date
Page 47 and 48: I, Judd Choate, hereby certify that
Page 49 and 50: I. Hilary Rudy, hereby certify that
Page 51 and 52: I, Ben Schier, hereby certify that
Page 53 and 54: 1742EFILED DocumentEFILED CO Denver
Page 55 and 56: 1744 Elections Cb. 374PRECINCT BOUN
Page 57 and 58: a political subdivision must use a
Page 59 and 60: 1 the genClal election. In the cass
Page 61 and 62: s1 eligible eleetot. except an elec
Page 63 and 64: SECTION L In Colorado Revised Statu
Page 65 and 66: t;nr·'•1'I~ .,2345678910II121314
Page 67 and 68: STATE OFCOLORADODepartment of State
Page 69 and 70: MAY NOT HAVE ACCESS TO CONFIDENTIAL
Page 71 and 72: must complete a VOTER ASSISTANCE FO
Page 73 and 74: Amendments to Rule 12.4.l(b)(2):New
Page 75 and 76: WITH THE DEADLINES IN SECTION 1-8.3
Page 77 and 78: 26.13.2 THE COUNTY CLERK. AND RECOR
Page 79 and 80: (L)(M)A VALID VETERAN IDENTIFICATIO
Page 81 and 82: (C)REQUESTING NEW LOGS OR REPORTS T
Page 83 and 84: 41.68.2 The CANVASS BOARD MUST USE
Page 85 and 86: 42.1 1 .2 If the designated electio
Page 87 and 88:
STATE OFCOLORADODepartment of State
Page 89 and 90:
inactive - failed to vote electors
Page 91 and 92:
4. Section l-8-115(5)(d), C.RS., (2
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