Case: Cowen v. Raffensperger

Cowen v. Kemp

Cowen v. Kemp

Cowen v. Kemp

Cowen v. Kemp

Cowen v. Kemp

Cowen v. Kemp

COMPLAINT, filed by Martin Cowen, Allen Buckley, John Monds, Libertarian Party of Georgia, Inc. and Aaron Gilmer; and Summon(s) issued. ( Filing fee $ 400.00 receipt number 113E-7521944.) (Attachments: # 1 Civil Cover Sheet)(eop) Please visit our website at http://www.gand.uscourts.gov/commonly-used-forms to obtain Pretrial Instructions which includes the Consent To Proceed Before U.S. Magistrate form. (Entered: 11/22/2017)

1 Civil Cover Sheet

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Electronic Summons Issued as to Brian P. Kemp. (eop) (Entered: 11/22/2017)

STANDING ORDER REGARDING CIVIL LITIGATION. Signed by Judge Leigh Martin May on 11/30/17. (hfm) (Entered: 11/30/2017)

AFFIDAVIT of Service for summons, complaint and civil cover sheet, as to Brian P. Kemp. (Sells, Bryan) (Entered: 12/18/2017)

AFFIDAVIT of Service for summons, complaint, and civil cover sheet, as to Christopher M. Carr. (Sells, Bryan) (Entered: 12/18/2017)

First Certificate of Interested Persons and Corporate Disclosure Statement by Allen Buckley, Martin Cowen, Aaron Gilmer, Libertarian Party of Georgia, Inc., John Monds identifying Corporate Parent Libertarian National Committee Inc. for Libertarian Party of Georgia, Inc.. (Sells, Bryan) (Entered: 12/18/2017)

Clerks Notation re 6 Certificate of Interested Persons, reviewed and approved by LMM. (rvb)

Clerks Notation for LOA/CIP

MOTION to Dismiss with Brief In Support by Brian P. Kemp. (Attachments: # 1 Brief)(Correia, Cristina) (Entered: 12/28/2017)

1 Brief

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RESPONSE in Opposition re 7 MOTION to Dismiss filed by Allen Buckley, Martin Cowen, Aaron Gilmer, Libertarian Party of Georgia, Inc., John Monds. (Sells, Bryan) (Entered: 01/01/2018)

REPLY BRIEF re 7 MOTION to Dismiss filed by Brian P. Kemp. (Correia, Cristina) (Entered: 01/12/2018)

Submission of 7 MOTION to Dismiss, submitted to District Judge Leigh Martin May. (hfm)

Submission to District Judge

ORDER granting 7 Partial Motion to Dismiss. Plaintiffs' claims for nominal damages against Defendant in his official capacity are DISMISSED for lack of jurisdiction. Signed by Judge Leigh Martin May on 1/25/18. (hfm) (Entered: 01/25/2018)

JOINT PRELIMINARY REPORT AND DISCOVERY PLAN filed by Brian P. Kemp. (Correia, Cristina) (Entered: 01/29/2018)

SCHEDULING ORDER re 11 Joint Preliminary Report and Discovery Plan. Signed by Judge Leigh Martin May on 1/30/18. (hfm) (Entered: 01/30/2018)

CERTIFICATE OF SERVICE of the Plaintiffs' Initial Disclosures by Allen Buckley, Martin Cowen, Aaron Gilmer, Libertarian Party of Georgia, Inc., John Monds.(Sells, Bryan) (Entered: 02/08/2018)

Defendant's ANSWER to 1 COMPLAINT by Brian P. Kemp. Discovery ends on 7/9/2018.(Correia, Cristina) Please visit our website at http://www.gand.uscourts.gov to obtain Pretrial Instructions. (Entered: 02/08/2018)

Initial Disclosures by Brian P. Kemp.(Correia, Cristina) (Entered: 02/08/2018)

CERTIFICATE OF SERVICE of First Set of Interrogatories by Allen Buckley, Martin Cowen, Aaron Gilmer, Libertarian Party of Georgia, Inc., John Monds.(Sells, Bryan) Modified on 3/13/2018 to remove all cap (btql). (Entered: 03/12/2018)

CERTIFICATE OF SERVICE of First Set of Requests for Production by Allen Buckley, Martin Cowen, Aaron Gilmer, Libertarian Party of Georgia, Inc., John Monds.(Sells, Bryan) Modified on 3/13/2018 to remove all cap (btql). (Entered: 03/12/2018)

NOTICE of Appearance by Josiah Benjamin Heidt on behalf of Brian P. Kemp (Heidt, Josiah) (Entered: 03/29/2018)

CERTIFICATE OF SERVICE re Defendant Responses to Plaintiffs First Interrogatories and Defendant Responses to Plaintiffs First Requests for Production by Brian P. Kemp.(Heidt, Josiah) (Entered: 04/19/2018)

CERTIFICATE OF SERVICE of Expert Reports by Allen Buckley, Martin Cowen, Aaron Gilmer, Libertarian Party of Georgia, Inc., John Monds.(Sells, Bryan) (Entered: 04/20/2018)

Consent MOTION for Extension of Time to file rebuttal expert witness reports by Brian P. Kemp. (Attachments: # 1 Text of Proposed Order)(Correia, Cristina) (Entered: 05/11/2018)

CERTIFICATE OF SERVICE Defendant's First Supplemental Response to Plaintiffs' Requests for Production by Brian P. Kemp.(Correia, Cristina) (Entered: 05/11/2018)

ORDER GRANTING 21 Motion for Extension of Time up to and including 5/28/2018 to file Rebuttal Expert Witness Reports. Signed by Judge Leigh Martin May on 5/11/2018. (btql) (Entered: 05/11/2018)

Expert Report of Robert Stein by Brian P. Kemp. (Attachments: # 1 Exhibit Expert Report)(Correia, Cristina) (Entered: 05/28/2018)

1 Exhibit Expert Report

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CERTIFICATE OF SERVICE Defendant's First Set of Interrogatories and First Requests to Produce by Brian P. Kemp.(Correia, Cristina) (Entered: 05/29/2018)

Consent MOTION for Extension of Time to Complete Discovery and related deadlines by Allen Buckley, Martin Cowen, Aaron Gilmer, Libertarian Party of Georgia, Inc., John Monds. (Attachments: # 1 Text of Proposed Order)(Sells, Bryan) (Entered: 06/21/2018)

ORDER GRANTING 26 Motion for Extension of Time to Complete Discovery and related deadlines. Discovery ends on 9/6/2018. Motions for summary judgment due 10/8/2018. Signed by Judge Leigh Martin May on 6/21/2018. (btql) (Entered: 06/21/2018)

Notice for Leave of Absence for the following date(s): July 6, 2018-July 25, 2018, by Cristina Correia. (Correia, Cristina) (Entered: 07/05/2018)

CERTIFICATE OF SERVICE of the plaintiffs' first set of requests for admissions by Allen Buckley, Martin Cowen, Aaron Gilmer, Libertarian Party of Georgia, Inc., John Monds.(Sells, Bryan) (Entered: 08/06/2018)

CERTIFICATE OF SERVICE of the Plaintiffs' First Supplemental Disclosures by Allen Buckley, Martin Cowen, Aaron Gilmer, Libertarian Party of Georgia, Inc., John Monds.(Sells, Bryan) (Entered: 08/15/2018)

CERTIFICATE OF SERVICE of the Plaintiffs' Responses to the Defendant's First Set of Interrogatories by Allen Buckley, Martin Cowen, Aaron Gilmer, Libertarian Party of Georgia, Inc., John Monds.(Sells, Bryan) (Entered: 08/15/2018)

CERTIFICATE OF SERVICE of the Plaintiffs' Responses to the Defendant's First Set of Requests for Production by Allen Buckley, Martin Cowen, Aaron Gilmer, Libertarian Party of Georgia, Inc., John Monds.(Sells, Bryan) (Entered: 08/15/2018)

Consent MOTION for Extension of Time to Complete Discovery by Brian P. Kemp. (Attachments: # 1 Text of Proposed Order)(Correia, Cristina) (Entered: 08/23/2018)

ORDER granting 33 Motion for Extension of Time to Complete Discovery up to and including October 12, 2018 to complete discovery. Motions for summary judgment are due on or before November 12, 2018. Daubert motions and the Pretrial Order are due November 12, 2018 or 30 days after this Court's ruling on any pending motions for summary judgment. Signed by Judge Leigh Martin May on 8/24/18. (hfm) (Entered: 08/24/2018)

CERTIFICATE OF SERVICE for Discovery by Brian P. Kemp.(Correia, Cristina) (Entered: 09/13/2018)

Joint MOTION for Extension of Time to Complete Discovery by Brian P. Kemp. (Attachments: # 1 Text of Proposed Order)(Correia, Cristina) (Entered: 10/09/2018)

ORDER - This matter is before the Court on a Joint Motion for Extension of Time to complete deposition discovery 36 . For good cause shown, the Motion is hereby GRANTED. The parties shall have up to and including November 30, 2018, to complete discovery. Motions for summary judgment are due on or before January 11, 2019. Daubert motions and the Pretrial Order are due January 11, 2019, or 30 days after this Court's ruling on any pending motions for summary judgment. Signed by Judge Leigh Martin May on 10/10/2018. (tcc) (Entered: 10/10/2018)

Joint MOTION for Extension of Time to Complete Discovery by Brian P. Kemp. (Attachments: # 1 Text of Proposed Order)(Correia, Cristina) (Entered: 11/19/2018)

ORDER GRANTING 38 Motion for Extension of Time to Complete Discovery. Discovery ends on 1/30/2019. Motions for summary judgment due 3/1/2019. Daubert motions and the Pretrial Order are due 3/1/2019 or 30 days after the Court's ruling on any pending motions for summary judgment. Signed by Judge Leigh Martin May on 11/19/2018. (btql) (Entered: 11/19/2018)

Joint MOTION for Extension of Time to Complete Discovery by Allen Buckley, Martin Cowen, Aaron Gilmer, Libertarian Party of Georgia, Inc., John Monds. (Attachments: # 1 Text of Proposed Order)(Sells, Bryan) (Entered: 01/10/2019)

ORDER GRANTING 40 Motion for Extension of Time to Complete Discovery. Discovery ends on 3/15/2019. Motions for summary judgment are due 4/15/2019. Daubert motions and the Proposed Pretrial Order due 5/15/2019. The Court will not grant further extensions. Signed by Judge Leigh Martin May on 1/11/2019. (btql) (Entered: 01/11/2019)

CERTIFICATE OF SERVICE of the plaintiffs' second set of interrogatories by Allen Buckley, Martin Cowen, Aaron Gilmer, Libertarian Party of Georgia, Inc., John Monds.(Sells, Bryan) (Entered: 01/25/2019)

CERTIFICATE OF SERVICE of the Plaintiffs' Second Set of Requests for Production of Documents by Allen Buckley, Martin Cowen, Aaron Gilmer, Libertarian Party of Georgia, Inc., John Monds.(Sells, Bryan) (Entered: 02/11/2019)

CERTIFICATE OF SERVICE of the Plaintiffs' Second Set of Requests for Admissions by Allen Buckley, Martin Cowen, Aaron Gilmer, Libertarian Party of Georgia, Inc., John Monds.(Sells, Bryan) (Entered: 02/11/2019)

NOTICE of Appearance by Elizabeth Ahern Monyak on behalf of Brian P. Kemp (Monyak, Elizabeth) (Entered: 02/13/2019)

Consent MOTION for Protective Order by Brian P. Kemp. (Attachments: # 1 Text of Proposed Order Protective Order)(Correia, Cristina) (Entered: 02/14/2019)

CONSENT PROTECTIVE ORDER. Signed by Judge Leigh Martin May on 2/19/2019. (btql) (Entered: 02/19/2019)

Minute Entry for proceedings held before Judge Leigh Martin May: Telephone Conference held on 2/19/2019 at the request of the parties to discuss a dispute that occurred during the deposition of Ted Metz held on February 13, 2019. The Court heard from Plaintiffs' and Defendant's counsel. Plaintiffs' objection to Defendant using party meeting minutes during the deposition of Ted Metz which were not previously disclosed is overruled and does not violate discovery rules. The parties' orally motioned to substitute Brad Raffensperger as the defendant in place of Brian Kemp. The Court GRANTED the parties' motion. The Clerk shall substitute Brad Raffensperger as the defendant in this civil action. The parties shall contact the Court in accordance with the Standing Order if any further discovery issues arise. (Court Reporter Montrell Vann)(btql) (Entered: 02/19/2019)

CERTIFICATE OF SERVICE of the plaintiffs' second supplemental disclosures by Allen Buckley, Martin Cowen, Aaron Gilmer, Libertarian Party of Georgia, Inc., John Monds.(Sells, Bryan) (Entered: 02/19/2019)

CERTIFICATE OF SERVICE Responses to 2nd Interrogatories by Brad Raffensperger.(Correia, Cristina) (Entered: 02/25/2019)

CERTIFICATE OF SERVICE of the plaintiffs' first supplemental responses to the defendant's first set of interrogatories by Allen Buckley, Martin Cowen, Aaron Gilmer, Libertarian Party of Georgia, Inc., John Monds.(Sells, Bryan) (Entered: 02/27/2019)

CERTIFICATE OF SERVICE Defendant's First Supplemental Responses to Plaintiffs' First Set of Interrogatories and Defendant's First Supplemental Responses to Plaintiffs' First Requests to Produce by Brad Raffensperger.(Correia, Cristina) (Entered: 03/01/2019)

CERTIFICATE OF SERVICE Defendant's Second Supplemental Responses to Plaintiffs' First Interrogatories by Brad Raffensperger.(Correia, Cristina) (Entered: 03/04/2019)

Consent MOTION for Extension of Time Take a 30(b)(6) deposition of the Libertarian Party of Georgia. by Brad Raffensperger. (Attachments: # 1 Text of Proposed Order)(Correia, Cristina) (Entered: 03/08/2019)

ORDER GRANTING 54 Motion for Extension of Time through and including 4/5/2019 to complete the Rule 30(b)(6) deposition of Plaintiff, the Libertarian Party. Signed by Judge Leigh Martin May on 3/8/2019. (btql) (Entered: 03/11/2019)

CERTIFICATE OF SERVICE Discovery by Brad Raffensperger.(Correia, Cristina) (Entered: 03/11/2019)

Supplemental Initial Disclosures by Brad Raffensperger.(Correia, Cristina) (Entered: 03/12/2019)

Request for Leave of Absence for the following date(s): 3/18/19, 3/19/19, 3/20/19, 3/21/19, by Bryan Ludington Sells. (Sells, Bryan) (Entered: 03/13/2019)

ORDER ruling on the discovery disputes regarding Plaintiff's deposition of Defendant's 30(b)(6) representative. See order for further details. Signed by Judge Leigh Martin May on 03/14/2019. (rvb) (Entered: 03/14/2019)

CERTIFICATE OF SERVICE Fourth Supplemental Responses to First Interrogatories and Third Supplemental Responses to First Requests for Production by Brad Raffensperger.(Correia, Cristina) (Entered: 03/14/2019)

Joint MOTION for Extension of Time to Complete Discovery until April 15 by Allen Buckley, Martin Cowen, Aaron Gilmer, Libertarian Party of Georgia, Inc., John Monds. (Attachments: # 1 Text of Proposed Order)(Sells, Bryan) (Entered: 03/15/2019)

CERTIFICATE OF SERVICE Amended Notice of Deposition by Brad Raffensperger.(Correia, Cristina) (Entered: 03/15/2019)

ORDER GRANTING 61 Motion for Extension of Time to Complete Discovery. Discovery ends on 4/15/2019. Motions for summary judgment are due on or before 5/15/2019. Daubert motions and the Pretrial Order are due 6/28/2019, or 30 days after this Court's ruling on any pending motions for summary judgment. Signed by Judge Leigh Martin May on 3/15/2019. (btql) (Entered: 03/15/2019)

Certification of Consent to Substitution of Counsel. Cristina Correia replacing attorney Elizabeth Ahern Monyak. (Correia, Cristina) (Entered: 04/01/2019)

Joint MOTION for Extension of Time file motions for summary judgment by Brad Raffensperger. (Attachments: # 1 Exhibit Correspondence from Court Reporter, # 2 Text of Proposed Order)(Correia, Cristina) (Entered: 05/06/2019)

ORDER GRANTING 65 Motion for Extension of Time up to and including 6/5/2019 for parties to file motions for summary judgment. Signed by Judge Leigh Martin May on 5/6/2019. (btql) (Entered: 05/07/2019)

Unopposed MOTION for Leave to File Excess Pages by Allen Buckley, Martin Cowen, Aaron Gilmer, Libertarian Party of Georgia, Inc., John Monds. (Attachments: # 1 Text of Proposed Order)(Sells, Bryan) (Entered: 05/31/2019)

ORDER granting 67 Motion for Leave to File Excess Pages. The page limit for each party's brief in support of its motion for summary judgment shall be 45 pages. Signed by Judge Leigh Martin May on 6/3/2019. (tmf) (Entered: 06/03/2019)

MOTION for Summary Judgment with Brief In Support by Allen Buckley, Martin Cowen, Aaron Gilmer, Libertarian Party of Georgia, Inc., John Monds. (Attachments: # 1 Brief In Support of Plaintiffs' Motion for Summary Judgment, # 2 Statement of Material Facts, # 3 Exhibit Index, # 4 Exhibit 1: Declaration of Jeff Anderson, # 5 Exhibit 2: Declaration of Victor Armendariz, # 6 Exhibit 3: Declaration of Allen Buckley, # 7 Exhibit 4: Declaration of Faye Coffield, # 8 Exhibit 5: Declaration of Martin Cowen, # 9 Exhibit 6: Declaration of Hugh Esco, # 10 Exhibit 7: Declaration of Jay Fisher, # 11 Exhibit 8: Declaration of Aaron Gilmer, # 12 Exhibit 9: Declaration of Ryan Graham, # 13 Exhibit 10: Declaration of Derrick Lee, # 14 Exhibit 11: Declaration of Cynthia McKinney, # 15 Exhibit 12: Declaration of Ted Metz, # 16 Exhibit 13: Declaration of John Monds, # 17 Exhibit 14: Declaration of Eugene Moon, # 18 Exhibit 15: Declaration of Hien Nguyen, # 19 Exhibit 16: Declaration of Wayne Parker, # 20 Exhibit 17: Declaration of Darcy Richardson, # 21 Exhibit 18: Declaration of Nicholas Sarwark, # 22 Exhibit 19: Declaration of Luanne Taylor, # 23 Exhibit 20: Declaration of Don Webb, # 24 Exhibit 21: Declaration of Nathan Wilson, # 25 Exhibit 22: Declaration of Richard WInger, # 26 Exhibit 23: Deposition of Chris Harvey (excerpts), # 27 Exhibit 24: Deposition of Darcy Richardson (excerpts), # 28 Exhibit 25: Deposition of Richard WInger (excerpts), # 29 Exhibit 26: Plaintiffs' (Corrected) First Set of Requests for Admissions, # 30 Exhibit 27: Defendant's Responses to Plaintiffs' Corrected First Requests for Admissions, # 31 Exhibit 28: Plaintiffs' Second Set of Requests for Admissions, # 32 Exhibit 29: Defendant's Responses to Plaintiffs' Second Requests for Admissions, # 33 Exhibit 30: Defendant's Responses to Plaintiffs' First Interrogatores, # 34 Exhibit 31: Defendant's Responses to Plaintiffs' Second Interrogatories, # 35 Exhibit 32: Complaint, # 36 Exhibit 33: Answer, # 37 Exhibit 34: Newspaper Articles, # 38 Exhibit 35: Application for Writ of Mandamus (Dixon v. Poythress), # 39 Exhibit 36: 1982 Atlanta Constitution Article, # 40 Exhibit 37: Election Results 2000-2018 (excerpts), # 41 Exhibit 38 (pt.1): Candidate Materials, # 42 Exhibit 38 (pt. 2): Candidate Materials, # 43 Exhibit 39: 1982 The Militant Article, # 44 Exhibit 40: Petition-Verification Instruction Letters, # 45 Exhibit 41: De La Fuente Petition Sheets and ENET Printouts (redacted version), # 46 Exhibit 42: Green Party of Georgia v. Kemp, Appellant's Briefs (excerpts))(Sells, Bryan) --Please refer to http://www.gand.uscourts.gov to obtain the Notice to Respond to Summary Judgment Motion form contained on the Court's website.-- (Entered: 06/05/2019)

1 Brief In Support of Plaintiffs' Motion for Summary Judgment

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2 Statement of Material Facts

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3 Exhibit Index

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4 Exhibit 1: Declaration of Jeff Anderson

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5 Exhibit 2: Declaration of Victor Armendariz

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6 Exhibit 3: Declaration of Allen Buckley

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7 Exhibit 4: Declaration of Faye Coffield

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8 Exhibit 5: Declaration of Martin Cowen

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9 Exhibit 6: Declaration of Hugh Esco

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10 Exhibit 7: Declaration of Jay Fisher

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11 Exhibit 8: Declaration of Aaron Gilmer

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12 Exhibit 9: Declaration of Ryan Graham

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13 Exhibit 10: Declaration of Derrick Lee

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14 Exhibit 11: Declaration of Cynthia McKinney

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15 Exhibit 12: Declaration of Ted Metz

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16 Exhibit 13: Declaration of John Monds

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17 Exhibit 14: Declaration of Eugene Moon

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18 Exhibit 15: Declaration of Hien Nguyen

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19 Exhibit 16: Declaration of Wayne Parker

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20 Exhibit 17: Declaration of Darcy Richardson

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21 Exhibit 18: Declaration of Nicholas Sarwark

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22 Exhibit 19: Declaration of Luanne Taylor

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23 Exhibit 20: Declaration of Don Webb

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24 Exhibit 21: Declaration of Nathan Wilson

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25 Exhibit 22: Declaration of Richard WInger

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26 Exhibit 23: Deposition of Chris Harvey (excerpts)

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27 Exhibit 24: Deposition of Darcy Richardson (excerpts)

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28 Exhibit 25: Deposition of Richard WInger (excerpts)

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29 Exhibit 26: Plaintiffs' (Corrected) First Set of Requests for Admissions

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30 Exhibit 27: Defendant's Responses to Plaintiffs' Corrected First Reque

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31 Exhibit 28: Plaintiffs' Second Set of Requests for Admissions

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32 Exhibit 29: Defendant's Responses to Plaintiffs' Second Requests for A

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33 Exhibit 30: Defendant's Responses to Plaintiffs' First Interrogatores

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34 Exhibit 31: Defendant's Responses to Plaintiffs' Second Interrogatorie

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35 Exhibit 32: Complaint

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36 Exhibit 33: Answer

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37 Exhibit 34: Newspaper Articles

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38 Exhibit 35: Application for Writ of Mandamus (Dixon v. Poythress)

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39 Exhibit 36: 1982 Atlanta Constitution Article

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40 Exhibit 37: Election Results 2000-2018 (excerpts)

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41 Exhibit 38 (pt.1): Candidate Materials

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42 Exhibit 38 (pt. 2): Candidate Materials

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43 Exhibit 39: 1982 The Militant Article

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44 Exhibit 40: Petition-Verification Instruction Letters

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45 Exhibit 41: De La Fuente Petition Sheets and ENET Printouts (redacted version)

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46 Exhibit 42: Green Party of Georgia v. Kemp, Appellant's Briefs (excerpts)

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NOTICE Of Filing Document Under Seal by Allen Buckley, Martin Cowen, Aaron Gilmer, Libertarian Party of Georgia, Inc., John Monds re 69 MOTION for Summary Judgment Exhibit 41 (Attachments: ATTACHMENT 1 SEALED PURSUANT TO 93 ORDER # 1 Exhibit 41: De La Fuente Petition Sheets and ENET Printouts (unredacted version))(Sells, Bryan) Modified on 7/1/2019 to add sealed text(tmf). (Entered: 06/05/2019)

MOTION for Leave to File Matters Under Seal re: 70 Notice of Filing, by Allen Buckley, Martin Cowen, Aaron Gilmer, Libertarian Party of Georgia, Inc., John Monds. (Attachments: # 1 Text of Proposed Order)(Sells, Bryan) (Entered: 06/05/2019)

NOTICE Of Filing of Deposition Transcript by Allen Buckley, Martin Cowen, Aaron Gilmer, Libertarian Party of Georgia, Inc., John Monds re 69 MOTION for Summary Judgment (Attachments: # 1 Exhibit Deposition of Chris Harvey (04/05/19), # 2 Errata, # 3 Exhibit 1 - Notice of Deposition, # 4 Exhibit 2 - Defendant's Responses to Plaintiffs' First Interrogatories, # 5 Exhibit 3 - Defendant's First Supplemental Responses to Plaintiffs' First Interrogatories, # 6 Exhibit 4 - Defendant's Second Supplemental Responses to Plaintiffs' First Interrogatories, # 7 Exhibit 5 - Defendant's Third Supplemental Responses to Plaintiffs' First Interrogatories, # 8 Exhibit 6 - Table)(Sells, Bryan) (Entered: 06/05/2019)

1 Exhibit Deposition of Chris Harvey (04/05/19)

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2 Errata

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3 Exhibit 1 - Notice of Deposition

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4 Exhibit 2 - Defendant's Responses to Plaintiffs' First Interrogatories

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5 Exhibit 3 - Defendant's First Supplemental Responses to Plaintiffs' Fi

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6 Exhibit 4 - Defendant's Second Supplemental Responses to Plaintiffs' F

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7 Exhibit 5 - Defendant's Third Supplemental Responses to Plaintiffs' Fi

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8 Exhibit 6 - Table

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MOTION for Summary Judgment with Brief In Support by Brad Raffensperger. (Attachments: ---ATTACHMENTS 5 AND 6 SEALED PURSUANT TO 82 ORDER--- # 1 Statement of Material Facts, # 2 Brief, # 3 Exhibit A, Declaration of Chris Harvey, # 4 Exhibit A-1, Projected 2020 Congressional Rep. Signature Requirements, # 5 Exhibit A-2, Letter from Chris Harvey to Martin Cowen, # 6 Exhibit A-3, Letter from Chris Harvey to Aaron Gilmore, # 7 Exhibit A-4, Historical Voter Registration Statistics (1998-Present), # 8 Exhibit A-5, Historical Voter Registration Statistics (1962-1996), # 9 Exhibit B, Plaintiffs' Responses to Defendant's First Set of Interrogatories, # 10 Exhibit C, Ga. AG Op. 1948, # 11 Exhibit D, Depo Excerpts of Plaintiff Libertarian Party of GA deposition, # 12 Exhibit E, Depo Excerpts of Plaintiff Aaron Gilmore, # 13 Exhibit F, Depo Excerpts of Richard Winger Deposition, # 14 Exhibit G, Depo Excerpts of Darcy Richardson Deposition, # 15 Exhibit Report of Dr. Robert Stein)(Correia, Cristina) --Please refer to http://www.gand.uscourts.gov to obtain the Notice to Respond to Summary Judgment Motion form contained on the Court's website.-- Modified on 6/19/2019 to add sealed text(tmf). (Entered: 06/05/2019)

1 Statement of Material Facts

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2 Brief

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3 Exhibit A, Declaration of Chris Harvey

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4 Exhibit A-1, Projected 2020 Congressional Rep. Signature Requirements

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7 Exhibit A-4, Historical Voter Registration Statistics (1998-Present)

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8 Exhibit A-5, Historical Voter Registration Statistics (1962-1996)

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9 Exhibit B, Plaintiffs' Responses to Defendant's First Set of Interroga

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10 Exhibit C, Ga. AG Op. 1948

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11 Exhibit D, Depo Excerpts of Plaintiff Libertarian Party of GA deposition

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12 Exhibit E, Depo Excerpts of Plaintiff Aaron Gilmore

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13 Exhibit F, Depo Excerpts of Richard Winger Deposition

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14 Exhibit G, Depo Excerpts of Darcy Richardson Deposition

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15 Exhibit Report of Dr. Robert Stein

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NOTICE Of Filing by Brad Raffensperger re 73 MOTION for Summary Judgment (Attachments: # 1 Exhibit Exhibit D Deposition of the Libertarian Party of Georgia, # 2 Exhibit Exhibit D-1 By-Laws of the Libertarian Party of Georgia, # 3 Exhibit Exhibit D-2 Libertarian Party of Georgia Membership, # 4 Exhibit Exhibit D-3 Libertarian Party of Georgia Executive Committee Minutes, October 13, 2018, # 5 Exhibit Exhibit D-4 Libertarian Party of Georgia Minutes of 2016 Annual Convention, # 6 Exhibit Exhibit D-5 Libertarian Party of Executive Committee Minutes, January 14, 2019, # 7 Exhibit Exhibit D-6 Libertarian Party of Georgia Executive Committee Minutes, February 11, 2019, # 8 Exhibit Exhibit D-7 Libertarian Party of Georgia Executive Committee Minutes, December 10, 2018, # 9 Exhibit Exhibit D-8 Libertarian Party of Georgia Executive Committee Minutes, November 12, 2018, # 10 Exhibit Exhibit D-9 Libertarian Party of Georgia, Budget Document, # 11 Errata Exhibit D Errata Sheet)(Correia, Cristina) (Entered: 06/06/2019)

NOTICE Of Filing by Brad Raffensperger re 73 MOTION for Summary Judgment (Attachments: ---ATTACHMENTS 1-4 AND 7 SEALED PURSUANT TO 82 ORDER--- # 1 Exhibit Exhibit E Deposition Transcript of Aaron Gilmer, # 2 Exhibit Exhibit E-1 Nomination Petition, # 3 Exhibit Exhibit E-2 Letter from Chris Harvey to Aaron Gilmer, # 4 Exhibit Exhibit E-3 Email from SOS staff to Aaron Gilmer, # 5 Exhibit Exhibit E-4 Email from SOS staff to Aaron Gilmer, # 6 Exhibit Exhibit E-5 Libertarian Party of Georgia Minutes of 2008 Annual Convention, # 7 Exhibit Exhibit E-6 2009 By-Laws of the Libertarian Party of Georgia, # 8 Exhibit Exhibit E-7 Libertarian Party of Georgia Minutes of 2010 Annual Convention, # 9 Exhibit Exhibit E-8 2011 Revised By-Laws of Libertarian Party of Georgia, # 10 Exhibit Exhibit E-9 Libertarian Party of Georgia Minutes of 2012 Annual Convention, # 11 Exhibit Exhibit E-10 Libertarian Party of Georgia Executive Committee Meeting Minutes, June 4, 2012, # 12 Exhibit Exhibit E-11 Libertarian Party of Georgia Minutes of 2013 Annual Convention, # 13 Exhibit Exhibit E-12 Libertarian Party of Georgia Minutes of 2014 Annual Convention, # 14 Exhibit Exhibit E-13 Libertarian Party of Georgia Minutes of 2015 Annual Convention, # 15 Exhibit Exhibit E-14 Libertarian Party of Georgia Minutes of 2016 Annual Convention, # 16 Exhibit Exhibit E-15 Libertarian Party of Georgia Minutes of 2017 Annual Convention, # 17 Exhibit Exhibit E-16 Libertarian Party of Georgia Minutes of 2018 Annual Convention)(Correia, Cristina) Modified on 6/19/2019 to add sealed text (tmf). (Entered: 06/06/2019)

NOTICE Of Filing by Brad Raffensperger re 73 MOTION for Summary Judgment (Attachments: ---ATTACHMENT 2 SEALED PURSUANT TO 82 ORDER--- # 1 Exhibit Exhibit F Deposition Transcript of Richard Winger, # 2 Exhibit Exhibit F Deposition Exhibit 1 Report of Richard Winger, # 3 Errata Errata Sheet)(Correia, Cristina) Modified on 6/19/2019 to add sealed text(tmf). (Entered: 06/06/2019)

1 Exhibit Exhibit F Deposition Transcript of Richard Winger

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2 Exhibit Exhibit F Deposition Exhibit 1 Report of Richard Winger

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3 Errata Errata Sheet

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NOTICE Of Filing by Brad Raffensperger re 73 MOTION for Summary Judgment (Attachments: # 1 Exhibit Exhibit G Deposition of Darcy Richardson, # 2 Exhibit Exhibit G Deposition Exhibit 1 Report of Darcy Richardson, # 3 Exhibit Exhibit G Deposition Exhibit 2 Signature Page of Darcy Richardson's Report, # 4 Errata Errata Sheet)(Correia, Cristina) (Entered: 06/06/2019)

1 Exhibit Exhibit G Deposition of Darcy Richardson

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2 Exhibit Exhibit G Deposition Exhibit 1 Report of Darcy Richardson

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3 Exhibit Exhibit G Deposition Exhibit 2 Signature Page of Darcy Richardson's

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4 Errata Errata Sheet

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Consent MOTION for Leave to File Matters Under Seal re: 76 Notice of Filing, 75 Notice of Filing,,,,,, 73 MOTION for Summary Judgment by Brad Raffensperger. (Attachments: # 1 Text of Proposed Order Proposed Order)(Correia, Cristina) (Entered: 06/17/2019)

Notice for Leave of Absence for the following date(s): June 27, 2019- July 9, 2019 by Cristina Correia. (Correia, Cristina) (Entered: 06/17/2019)

(DUPLICATE ENTRY OF 79 )Notice for Leave of Absence for the following date(s): June 27, 2019- July 9, 2019, by Cristina Correia. (Correia, Cristina) Modified on 6/18/2019 per the attorney's request (sap). (Entered: 06/18/2019)

Consent MOTION for Extension of Time respond to MSJ re: 69 MOTION for Summary Judgment by Brad Raffensperger. (Attachments: # 1 Text of Proposed Order Proposed Order)(Correia, Cristina) (Entered: 06/18/2019)

ORDER granting 78 Consent Motion for Leave to File Matters Under Seal. The Clerk is hereby instructed to seal the following electronic documents (The Court cannot seal individual pages filed in CM/ECF): (1) ECF 73-5; (2) ECF 73-6; (3) ECF 75-1; (4) ECF 75-2; (5) ECF 75-3; (6) ECF 75-4; (7) ECF 75-7; (8) ECF 76-2. Defendant will refile the above documents with all necessary redactions within 14 DAYS. Signed by Judge Leigh Martin May on 6/18/2019. (tmf) (Entered: 06/19/2019)

ORDER granting 81 Consent Motion for Extension of Time to file responses to motions for summary judgment and statements of undisputed material facts. The parties shall have up to and including August 2, 2019, to file their responses. Signed by Judge Leigh Martin May on 6/18/2019. (tmf) (Entered: 06/19/2019)

FILED IN ERROR NOTICE Of Filing by Brad Raffensperger re 75 Notice of Filing (Attachments: # 1 Exhibit Redacted Exhibit E Deposition Transcript of Aaron Gilmer)(Correia, Cristina) Modified on 6/25/2019 to edit text. Talked to atty (bnw). (Entered: 06/25/2019)

NOTICE Of Filing Redacted Exhibits by Brad Raffensperger RE: 73 Motion for Summary Judgment and 75 Notice of Filing (Attachments: # 1 Exhibit Redacted Exhibit E Deposition Transcript of Aaron Gilmer)(Correia, Cristina) Modified on 6/25/2019 to edit text and add document link. (aaq). (Entered: 06/25/2019)

NOTICE Of Filing Redacted Exhibits by Brad Raffensperger RE: 73 Motion for Summary Judgment and 75 Notice of Filing (Attachments: # 1 Exhibit Redacted Exhibit 1 to Gilmer Deposition- Nomination Petition)(Correia, Cristina) Modified on 6/25/2019 to edit text and add document link. (aaq). (Entered: 06/25/2019)

NOTICE Of Filing Redacted Exhibits by Brad Raffensperger Re: 73 Motion for Summary Judgment and 75 Notice of Filing (Attachments: # 1 Exhibit Redacted Exhibit 2 to Aaron Gilmer Deposition)(Correia, Cristina) Modified on 6/25/2019 to edit text and add document link. (aaq). (Entered: 06/25/2019)

NOTICE Of Filing Redacted Exhibits by Brad Raffensperger RE: 73 Motion for Summary Judgment and 75 Notice of Filing (Attachments: # 1 Exhibit Redacted Exhibit 3 to Aaron Gilmer Deposition)(Correia, Cristina) Modified on 6/25/2019 to edit text and add document link. (aaq). (Entered: 06/25/2019)

NOTICE Of Filing Redacted Exhibits by Brad Raffensperger RE: 73 Motion for Summary Judgment and 75 Notice of Filing (Attachments: # 1 Exhibit Redacted Exhibit 6 to Aaron Gilmer Deposition)(Correia, Cristina) Modified on 6/25/2019 to edit text and add document link. (aaq). (Entered: 06/25/2019)

NOTICE Of Filing Redacted Exhibits by Brad Raffensperger RE: 73 Motion for Summary Judgment and 76 Notice of Filing (Attachments: # 1 Exhibit Redacted Exhibit 1 to Richard Winger Deposition)(Correia, Cristina) Modified on 6/25/2019 to edit text and add document link. (aaq). (Entered: 06/25/2019)

NOTICE Of Filing Redacted Exhibits by Brad Raffensperger re 73 MOTION for Summary Judgment (Attachments: # 1 Exhibit Redacted Exhibit A-2 Letter from Chris Harvey to Martin Cowen)(Correia, Cristina) Modified on 6/25/2019 to edit text. (aaq). (Entered: 06/25/2019)

NOTICE Of Filing Redacted Exhibits by Brad Raffensperger RE: 73 Motion for Summary Judgment. (Attachments: # 1 Exhibit Exhibit A-3 Letter from Chris Harvey to Aaron Gilmer)(Correia, Cristina) Modified on 6/25/2019 to edit text. (aaq). (Entered: 06/25/2019)

Submission of the 71 MOTION for Leave to File Matters Under Seal re: 70 Notice of Filing to District Judge Leigh Martin May. (aaq)

Submission to District Judge

ORDER granting 71 Motion for Leave to File Matters Under Seal. The Clerk is hereby DIRECTED to seal Attachment #1 to the plaintiffs' notice of filing of document under seal ECF 70 . Signed by Judge Leigh Martin May on 7/1/2019. (tmf) (Entered: 07/01/2019)

Consent MOTION for Extension of Time MSJ re: 69 MOTION for Summary Judgment by Brad Raffensperger. (Attachments: # 1 Text of Proposed Order Proposed Order)(Correia, Cristina) (Entered: 07/30/2019)