489 F.Supp.3d 719, 2020 WL 5757453

Stanford-MIT Healthy Elections Project

COMPLAINT against Frank LaRose ( Filing fee $ 400 paid - receipt number: 0648-7583343), filed by League of Women Voters of Ohio, Carolyn E. Campbell, George W. Mangeni, Ohio A. Philip Randolph Institute. [ELECTION ISSUE(S) CITED] (Attachments: # 1 Civil Cover Sheet, # 2 Summons Form) (Levenson, Freda) (Entered: 07/31/2020)

1 Civil Cover Sheet

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2 Summons Form

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Corporate Disclosure Statement by Plaintiff League of Women Voters of Ohio. (Levenson, Freda) Modified filer on 8/3/2020 (ew). (Entered: 07/31/2020)

Corporate Disclosure Statement by Plaintiff A. Philip Randolph Institute of Ohio. (Levenson, Freda) Modified filer on 8/3/2020 (ew). (Entered: 07/31/2020)

MOTION for Leave to Appear Pro Hac Vice (Filing fee of $200 paid, receipt number 0648-7583586) of Joshua Picker by Plaintiffs Carolyn E. Campbell, League of Women Voters of Ohio, George W. Mangeni, Ohio A. Philip Randolph Institute. (Attachments: # 1 Certificate of Good Standing) (Levenson, Freda) (Entered: 07/31/2020)

1 Certificate of Good Standing

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MOTION for Leave to Appear Pro Hac Vice (Filing fee of $200 paid, receipt number 0648-7583694) of C. William Phillips by Plaintiffs Carolyn E. Campbell, League of Women Voters of Ohio, George W. Mangeni, Ohio A. Philip Randolph Institute. (Attachments: # 1 Certificate of Good Standing) (Levenson, Freda) (Entered: 07/31/2020)

1 Certificate of Good Standing

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MOTION for Leave to Appear Pro Hac Vice (Filing fee of $200 paid, receipt number 0648-7583709) of Jeremy Patashnik by Plaintiffs Carolyn E. Campbell, League of Women Voters of Ohio, George W. Mangeni, Ohio A. Philip Randolph Institute. (Attachments: # 1 Certificate of Good Standing) (Levenson, Freda) (Entered: 07/31/2020)

1 Certificate of Good Standing

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MOTION for Leave to Appear Pro Hac Vice (Filing fee of $200 paid, receipt number 0648-7583732) of Katherine Onyshko by Plaintiffs Carolyn E. Campbell, League of Women Voters of Ohio, George W. Mangeni, Ohio A. Philip Randolph Institute. (Attachments: # 1 Certificate of Good Standing) (Levenson, Freda) (Entered: 07/31/2020)

1 Certificate of Good Standing

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Summons Issued as to Frank LaRose. (ew) (Entered: 08/03/2020)

NOTATION ORDER granting 4, 5, 6, and 7 Motions for Leave to Appear Pro Hac Vice of Joshua Picker, C. William Phillips, Jeremy Patashnik, and Katherine Onyshko. By Magistrate Judge Kimberly A. Jolson on 8/3/2020. (ew) (Entered: 08/03/2020)

Order on Motion for Leave to Appear Pro Hac Vice AND Order on Motion for Leave to Appear Pro Hac Vice AND Order on Motion for Leave to Appear Pro Hac Vice AND Order on Motion for Leave to Appear Pro Hac Vice

NOTICE of Appearance by Julie M Pfeiffer for Defendant Frank LaRose (Pfeiffer, Julie) (Entered: 08/07/2020)

NOTICE of Appearance by Brandi R. Laser Seskes for Defendant Frank LaRose (Laser Seskes, Brandi) (Entered: 08/07/2020)

NOTICE of Appearance by Ann Yackshaw for Defendant Frank LaRose (Yackshaw, Ann) (Entered: 08/10/2020)

ACKNOWLEDGMENT OF SERVICE: Unknown document received by Frank LaRose on 8/6/2020. (ew) (Entered: 08/11/2020)

Unopposed MOTION for Leave to File Excess Pages by Plaintiffs A. Philip Randolph Institute of Ohio, Carolyn E. Campbell, League of Women Voters of Ohio, George W. Mangeni. (Attachments: # 1 Text of Proposed Order Granting Leave to Exceed Page Limitation) (Levenson, Freda) (Entered: 08/13/2020)

1 Text of Proposed Order Granting Leave to Exceed Page Limitation

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ANSWER to 1 Complaint, filed by Frank LaRose. (Pfeiffer, Julie) (Entered: 08/14/2020)

NOTICE of Appearance by M. Ryan Harmanis for Intervenor Defendants Republican National Committee, National Republican Congressional Committee, Ohio Republican Party, Donald J. Trump for President, Inc. (Harmanis, M.) (Entered: 08/17/2020)

Corporate Disclosure Statement by Intervenor Defendants Donald J. Trump for President, Inc., National Republican Congressional Committee, Ohio Republican Party, Republican National Committee. (Harmanis, M.) (Entered: 08/17/2020)

MOTION to Intervene by Intervenor Defendants Donald J. Trump for President, Inc., National Republican Congressional Committee, Ohio Republican Party, Republican National Committee. (Attachments: # 1 Exhibit Proposed Answer) (Harmanis, M.) (Entered: 08/17/2020)

1 Exhibit Proposed Answer

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ORDER granting 14 Motion for Leave to File Excess Pages. Signed by Judge Michael H. Watson on 8/19/20. (jk) (Entered: 08/19/2020)

MOTION for Leave to Appear Pro Hac Vice (Filing fee of $200 paid, receipt number 0648-7615554) of John M. Gore by Movants Donald J. Trump for President, Inc., National Republican Congressional Committee, Ohio Republican Party, Republican National Committee. (Attachments: # 1 Exhibit Certificate of Good Standing) (Harmanis, M.) (Entered: 08/19/2020)

1 Exhibit Certificate of Good Standing

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MOTION for Leave to Appear Pro Hac Vice (Filing fee of $200 paid, receipt number 0648-7615752) of E. Stewart Crosland by Movants Donald J. Trump for President, Inc., National Republican Congressional Committee, Ohio Republican Party, Republican National Committee. (Attachments: # 1 Exhibit Certificate of Good Standing) (Harmanis, M.) (Entered: 08/19/2020)

1 Exhibit Certificate of Good Standing

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MOTION for Leave to Appear Pro Hac Vice (Filing fee of $600 paid, receipt number 0648-7616156) of Dale E. Ho, T. Alora Thomas, and Jonathan Topaz by Plaintiffs A. Philip Randolph Institute of Ohio, Carolyn E. Campbell, League of Women Voters of Ohio, George W. Mangeni. (Attachments: # 1 Ho Certificate of Good Standing, # 2 Thomas Certificate of Good Standing, # 3 Topaz Certificate of Good Standing) (Levenson, Freda) (Entered: 08/19/2020)

1 Ho Certificate of Good Standing

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2 Thomas Certificate of Good Standing

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3 Topaz Certificate of Good Standing

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NOTATION ORDER granting 20, 21, and 22 Motions for Leave to Appear Pro Hac Vice of John M. Gore, E. Stewart Crosland, Dale E. Ho, T. Alora Thomas, and Jonathan Topaz. Signed by Magistrate Judge Kimberly A. Jolson on 8/20/2020. (ew) (Entered: 08/20/2020)

Order on Motion for Leave to Appear Pro Hac Vice AND Order on Motion for Leave to Appear Pro Hac Vice AND Order on Motion for Leave to Appear Pro Hac Vice

MOTION for Preliminary Injunction by Plaintiffs A. Philip Randolph Institute of Ohio, Carolyn E. Campbell, League of Women Voters of Ohio, George W. Mangeni. (Attachments: # 1 Declaration of Jeremy Patashnik, # 2 Declaration of Jen Miller, # 3 Declaration of Andre Washington, # 4 Declaration of Carolyn Campbell, # 5 Declaration of George Mangeni, # 6 Declaration of Linton A. Mohammed, # 7 Report of Daniel D. McCool, # 8 Report of Alexander Street) (Levenson, Freda) (Entered: 08/24/2020)

1 Declaration of Jeremy Patashnik

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2 Declaration of Jen Miller

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3 Declaration of Andre Washington

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4 Declaration of Carolyn Campbell

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5 Declaration of George Mangeni

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6 Declaration of Linton A. Mohammed

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7 Report of Daniel D. McCool

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8 Report of Alexander Street

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AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF against Frank LaRose, filed by George W. Mangeni, A. Philip Randolph Institute of Ohio, Carolyn E. Campbell, League of Women Voters of Ohio. (Levenson, Freda) (Entered: 08/24/2020)

Notice of Hearing

NOTICE of Hearing - Telephone Status Conference set for 8/31/2020 at 2:00 p.m. before Judge Michael H. Watson. (jk)

NOTICE of Appearance by David J. Carey for Plaintiffs A. Philip Randolph Institute of Ohio, Carolyn E. Campbell, League of Women Voters of Ohio, George W. Mangeni (Carey, David) (Entered: 08/31/2020)

Telephone Conference

Minute Entry for proceedings held before Judge Michael H. Watson: Telephone Conference held on 8/31/2020. (Court Reporter: Lahana DuFour) (jk)

ORDER issued memorializing the 8/31/20 Telephone Conference. Signed by Judge Michael H. Watson on 8/31/20. (sem) (Entered: 08/31/2020)

Set Motion and R&R Deadlines/Hearings

Set/Reset Deadlines as to 18 MOTION to Intervene . Response now due by 8/31/2020 Reply now due by 9/3/2020. (sem)

Set/Reset Deadlines as to 24 MOTION for Preliminary Injunction . Response now due by 9/11/2020 Reply now due by 9/14/2020. (sem)

MOTION for Leave to Appear Pro Hac Vice (Filing fee of $200 paid, receipt number 0648-7633996) of Pooja Chaudhuri by Plaintiffs A. Philip Randolph Institute of Ohio, Carolyn E. Campbell, League of Women Voters of Ohio, George W. Mangeni. (Attachments: # 1 Certificate of Good Standing) (Levenson, Freda) (Entered: 08/31/2020)

MOTION for Leave to Appear Pro Hac Vice (Filing fee of $200 paid, receipt number 0648-7634016) of Ezra D. Rosenberg by Plaintiffs A. Philip Randolph Institute of Ohio, Carolyn E. Campbell, League of Women Voters of Ohio, George W. Mangeni. (Attachments: # 1 Certificate of Good Standing) (Levenson, Freda) (Entered: 08/31/2020)

RESPONSE to Motion re 18 MOTION to Intervene filed by Plaintiffs A. Philip Randolph Institute of Ohio, Carolyn E. Campbell, League of Women Voters of Ohio, George W. Mangeni. (Levenson, Freda) (Entered: 08/31/2020)

NOTATION ORDER granting 28 and 29 Motions for Leave to Appear Pro Hac Vice of Pooja Chaudhuri and Ezra D. Rosenberg. By Magistrate Judge Kimberly A. Jolson on 9/1/2020. (ew) (Entered: 09/01/2020)

NOTICE of Appearance by Lidia C. Mowad for Defendant Frank LaRose (Mowad, Lidia) (Entered: 09/01/2020)

Order on Motion for Leave to Appear Pro Hac Vice AND Order on Motion for Leave to Appear Pro Hac Vice

REPLY to Response to Motion re 18 MOTION to Intervene filed by Movants Donald J. Trump for President, Inc., National Republican Congressional Committee, Ohio Republican Party, Republican National Committee. (Harmanis, M.) (Entered: 09/03/2020)

NOTICE of Appearance by Edward Carter for Movants Donald J. Trump for President, Inc., National Republican Congressional Committee, Ohio Republican Party, Republican National Committee (Carter, Edward) (Entered: 09/03/2020)

OPINION and ORDER granting 18 Motion to Intervene. Signed by Judge Michael H. Watson on 9/4/2020. (jk) (Entered: 09/04/2020)

ANSWER to 1 Complaint filed by Donald J. Trump for President, Inc., National Republican Congressional Committee, Ohio Republican Party, Republican National Committee. (jk) (Entered: 09/04/2020)

Notice of Hearing

NOTICE of Hearing - Telephone Status Conference set for 9/9/2020 at 3:00 p.m. before Judge Michael H. Watson. (jk)

ANSWER to 25 Amended Complaint filed by Frank LaRose. (Pfeiffer, Julie) (Entered: 09/08/2020)

ANSWER to 25 Amended Complaint filed by Donald J. Trump for President, Inc., National Republican Congressional Committee, Ohio Republican Party, Republican National Committee. (Harmanis, M.) (Entered: 09/08/2020)

NOTICE of Appearance by Joseph Zelasko for Intervenor Defendants Donald J. Trump for President, Inc., National Republican Congressional Committee, Ohio Republican Party, Republican National Committee (Zelasko, Joseph) (Entered: 09/09/2020)

Telephone Conference

Minute Entry for proceedings held before Judge Michael H. Watson: Telephone Conference held on 9/9/2020. (Court Reporter: Lahana DuFour) (jk)

NOTICE by Defendant Frank LaRose of Filing Deposition Transcripts (Attachments: # 1 Exhibit Washington, Andre-Transcript and Exhs., # 2 Exhibit Campbell, Carolyn-Transcript and Exhs. -Redacted, # 3 Exhibit Mangeni, George-Transcript and Exhs.,- Redacted, # 4 Exhibit Miller, Jennifer-Transcript, # 5 Exhibit Street, Dr. Alex-Transcript and Exh.) (Pfeiffer, Julie) (Entered: 09/11/2020)

1 Exhibit Washington, Andre-Transcript and Exhs.

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2 Exhibit Campbell, Carolyn-Transcript and Exhs. -Redacted

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3 Exhibit Mangeni, George-Transcript and Exhs.,- Redacted

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4 Exhibit Miller, Jennifer-Transcript

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5 Exhibit Street, Dr. Alex-Transcript and Exh.

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RESPONSE in Opposition re 24 MOTION for Preliminary Injunction filed by Defendant Frank LaRose. (Attachments: # 1 Exhibit A, Ohio Gen. Code 4785-138 Senate Bill 2 (88th GA), # 2 Exhibit B, Declaration of Amanda Grandjean, # 3 Exhibit C, Declaration of David Payne, # 4 Exhibit D, Declaration of Brian Cleary, # 5 Exhibit E, NEOCH v. Husted Trial Tr. Vol. II, # 6 Exhibit F, NEOCH v. Husted Trial Tr. Vol. VI, # 7 Exhibit G, NEOCH v. Husted Trial Tr. Vol. IV, # 8 Exhibit H, NEOCH v. Husted Trial Tr. Vol. X) (Pfeiffer, Julie) (Entered: 09/12/2020)

1 Exhibit A, Ohio Gen. Code 4785-138 Senate Bill 2 (88th GA)

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2 Exhibit B, Declaration of Amanda Grandjean

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3 Exhibit C, Declaration of David Payne

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4 Exhibit D, Declaration of Brian Cleary

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5 Exhibit E, NEOCH v. Husted Trial Tr. Vol. II

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6 Exhibit F, NEOCH v. Husted Trial Tr. Vol. VI

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7 Exhibit G, NEOCH v. Husted Trial Tr. Vol. IV

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8 Exhibit H, NEOCH v. Husted Trial Tr. Vol. X

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NOTICE by Defendant Frank LaRose of filing corrected exhibit (44-7) (Attachments: # 1 Exhibit G, NEOCH v. Husted Trial Tr. Vol. IV (Corrected)) (Pfeiffer, Julie) (Entered: 09/12/2020)

1 Exhibit G, NEOCH v. Husted Trial Tr. Vol. IV (Corrected)

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MOTION to Exclude Expert Reports And Testimony Of Daniel McCool, Alexander Street And Linton Mohammed by Defendant Frank LaRose. (Pfeiffer, Julie) (Entered: 09/12/2020)

RESPONSE in Opposition re 24 MOTION for Preliminary Injunction filed by Intervenor Defendants Donald J. Trump for President, Inc., National Republican Congressional Committee, Ohio Republican Party, Republican National Committee. (Harmanis, M.) (Entered: 09/12/2020)

Unopposed MOTION for Leave to File Excess Pages by Plaintiffs A. Philip Randolph Institute of Ohio, Carolyn E. Campbell, League of Women Voters of Ohio, George W. Mangeni. (Attachments: # 1 Text of Proposed Order) (Levenson, Freda) (Entered: 09/14/2020)

MOTION for Leave to Appear Pro Hac Vice (Filing fee of $200 paid, receipt number 0648-7654501) of John F. Nelson by Plaintiffs A. Philip Randolph Institute of Ohio, Carolyn E. Campbell, League of Women Voters of Ohio, George W. Mangeni. (Attachments: # 1 Certificate of Good Standing) (Levenson, Freda) (Entered: 09/14/2020)

NOTATION ORDER granting 46 Motion for Leave to Appear Pro Hac Vice of John F. Nelson. By Magistrate Judge Kimberly A. Jolson on 9/15/2020. (ew) (Entered: 09/15/2020)

ORDER granting 45 Motion for Leave to File Excess Pages. Signed by Judge Michael H. Watson on 9/15/2020. (jk) (Entered: 09/15/2020)

RESPONSE in Opposition re 43 MOTION to Exclude Expert Reports And Testimony Of Daniel McCool, Alexander Street And Linton Mohammed filed by Plaintiffs A. Philip Randolph Institute of Ohio, Carolyn E. Campbell, League of Women Voters of Ohio, George W. Mangeni. (Levenson, Freda) (Entered: 09/15/2020)

REPLY to Response to Motion re 24 MOTION for Preliminary Injunction filed by Plaintiffs A. Philip Randolph Institute of Ohio, Carolyn E. Campbell, League of Women Voters of Ohio, George W. Mangeni. (Attachments: # 1 Declaration of Carolyn Campbell) (Levenson, Freda) (Entered: 09/15/2020)

1 Declaration of Carolyn Campbell

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Order on Motion for Leave to Appear Pro Hac Vice

REPLY to Response to Motion re 43 MOTION to Exclude Expert Reports And Testimony Of Daniel McCool, Alexander Street And Linton Mohammed filed by Defendant Frank LaRose. (Pfeiffer, Julie) (Entered: 09/21/2020)

NOTICE by Defendant Frank LaRose of Supplemental Authority (Attachments: # 1 Exhibit A, Thompson v. DeWine - September 16 2020, # 2 Exhibit B, Thompson v. DeWine - order to publish opinion) (Pfeiffer, Julie) (Entered: 09/22/2020)

1 Exhibit A, Thompson v. DeWine - September 16 2020

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2 Exhibit B, Thompson v. DeWine - order to publish opinion

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OPINION and ORDER denying 24 Plaintiffs' Motion for Preliminary Injunction. Signed by Judge Michael H. Watson on 9/27/2020. (jk) (Entered: 09/27/2020)

MOTION to Withdraw as Attorney by Defendant Frank LaRose. (Laser Seskes, Brandi) (Entered: 01/13/2021)

NOTATION ORDER - For good cause shown, Brandi Laser Seske's Motion to Withdraw as Counsel for Secretary of State (Doc. 54 ) is GRANTED. The clerk shall terminate her as counsel for Defendant on the docket. Assistant Attorneys General Julie M. Pfeiffer and Ann Yackshaw remain as lead and trial counsel for Defendant Secretary of State. Signed by Magistrate Judge Kimberly A. Jolson on 1/15/21. (jr) (Entered: 01/15/2021)

Order on Motion to Withdraw as Attorney

NOTICE of Hearing: Pretrial Conference set for 2/18/2021 10:15 AM in Teleconference before Magistrate Judge Kimberly A. Jolson. (jr) (Entered: 02/03/2021)

RULE 26(f) REPORT by Plaintiffs A. Philip Randolph Institute of Ohio, Carolyn E. Campbell, League of Women Voters of Ohio, George W. Mangeni. (Levenson, Freda) (Entered: 02/11/2021)

NOTICE of Substitution of Counsel - Edward Carter substituting for Ryan Harmanis as Trial Attorney as to Intervenor Defendants Donald J. Trump for President, Inc., National Republican Congressional Committee, Ohio Republican Party, Republican National Committee. (Carter, Edward) (Entered: 02/17/2021)

Minute Entry for proceedings held before Magistrate Judge Kimberly A. Jolson: Initial Pretrial Conference held on 2/18/2021. (jr)

PRELIMINARY PRETRIAL ORDER: Joinder of Parties due by 3/3/2021. Motions to Amend due by 3/3/2021. Initial Disclosures due by 2/26/2021. Discovery due by 6/30/2021. Clawback Agreement Deadline due by 3/1/2021. Dispositive motions due by 7/30/2021. Primary Expert due by 5/14/2021. Rebuttal Expert due by 6/15/2021. Settlement Demand due by 3/1/2021. Defendant will respond no laterthan two weeks after Plaintiffs' demand. Signed by Magistrate Judge Kimberly A. Jolson on February 19, 2021. (jlk) (Entered: 02/18/2021)

1 - Terminate Deadlines and Hearings AND Pretrial Conference - Initial

Proposed Stipulated Protective Order by Defendant Frank LaRose. (Pfeiffer, Julie) Modified text on 3/3/2021 (ew). (Entered: 03/02/2021)

STIPULATED PROTECTIVE ORDER. Signed by Magistrate Judge Kimberly A. Jolson on 3/3/2021. (daf) (Entered: 03/03/2021)

NOTICE by Plaintiffs A. Philip Randolph Institute of Ohio, Carolyn E. Campbell, League of Women Voters of Ohio, George W. Mangeni Withdrawal as Counsel of Jeremy Patashnik (Levenson, Freda) (Entered: 03/12/2021)

STIPULATION of Dismissal without Prejudice by Plaintiffs A. Philip Randolph Institute of Ohio, Carolyn E. Campbell, League of Women Voters of Ohio, George W. Mangeni. (Levenson, Freda) (Entered: 05/20/2021)

***Civil Case Terminated. (jk)

Terminate Civil Case