Case: Washington Election Integrity Coalition United v. Fell

Washington state trial court

NOTICE OF REMOVAL from Snohomish County Superior Court, case number 21-2-04302-31; (Receipt # AWAWDC-7276459) Attorney Lyndsey Marie Downs added to party Garth Fell(pty:dft), Attorney Lyndsey Marie Downs added to party Snohomish County(pty:dft), filed by Garth Fell, Snohomish County. (Attachments: # 1 Summons - State Court Exhibit SCSC Docket 2, # 2 Complaint - State Court Exhibit SCSC Docket 3, # 3 Civil Cover Sheet)(Downs, Lyndsey) Modified on 10/5/2021. Corrected descriptions of Attachments 1 and 2 to more accurately reflect documents filed. (ST) (Entered: 10/04/2021)

1 Exhibit SCSC Docket 2

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2 Exhibit SCSC Docket 3

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3 Exhibit Civil Cover Sheet

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AFFIDAVIT of of Notice to Snohomish County Superior Court and to Plaintiffs of Notice of Removal re 1 Notice of Removal, filed by Defendants Garth Fell, Snohomish County (Downs, Lyndsey) (Entered: 10/04/2021)

VERIFICATION OF STATE COURT RECORDS re 1 Notice of Removal, by Defendants Garth Fell, Snohomish County (Downs, Lyndsey) (Entered: 10/05/2021)

Proposed MOTION to Intervene Attorney Reina A Almon-Griffin added to party Washington State Democratic Central Committee(pty:intvd), filed by Intervenor Defendant Washington State Democratic Central Committee. Oral Argument Requested. (Attachments: # 1 Proposed Order, # 2 Exhibit A (Answer), # 3 Exhibit B (Declaration), # 4 Exhibit C (Dismiss)) Noting Date 10/22/2021, (Almon-Griffin, Reina) (Entered: 10/06/2021)

LETTER from Clerk re receipt of case from Snohomish County Superior Court and advising of WAWD case number and judge assignment. (CDA)cc all pro se plaintiffs via US Mail (Entered: 10/06/2021)

Notice of Filing Deficiency re 1 Notice of Removal,,. ***Action Required*** Notice of Removal - Jury Demand Improperly Submitted, Notice of Related Cases Omitted.See attached letter for more information and instructions. Notice of Related Case must be filed by 10/12/2021. (CDA)cc all plaintiffs via US Mail (Entered: 10/06/2021)

Judge David W. Christel added. (CDA)

Add and Terminate Judges

NOTICE of Related Case(s) 3:21-cv-05726-RAJ; 3:21-cv-05746, by Defendants Garth Fell, Snohomish County. (Downs, Lyndsey) (Entered: 10/08/2021)

MINUTE ORDER REASSIGNING CASE. Case reassigned to Judge Richard A. Jones for all further proceedings (related case 3:21-cv-5726-RAJ). Magistrate Judge David W. Christel no longer assigned to case, by Clerk, Ravi Subramanian. (cc: Pro Se Plaintiffs) (KEB) Modified on 10/13/2021. (KEB) (Entered: 10/13/2021)

MOTION to Strike Notice of Removal, or Alternatively, to Sever Claims, filed by Plaintiff Washington Election Integrity Coalition United (filed pro se). (Attachments: # 1 Proposed Order)(MW) (Entered: 10/14/2021)

1 Proposed Order

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NOTICE of Joinder JOINING 9 MOTION to Strike Notice of Removal, or Alternatively, to Sever Claims, by Plaintiffs Diana Barker, Lonny Bartholomew, John Beitz, Rita Beitz, Annette Blandino, Mary Lou Burns, Arthur Coday, Jr, William Cook, Lisa Cummings, Diane DeJong, Joshua A DeJong, Luke Determan, Melissa Eller, Roy Fuller, Jeremy Johnson, Karol Jones, Bob Kaldor, James Maclin, Jane Maclin, Russell Ostlund, Thomas J Prettyman, Jamie Renninger, Randy Tendering. (MW) (Entered: 10/14/2021)

STANDING ORDER for Civil Cases Assigned to Judge Richard A. Jones. (cc: Plaintiffs via USPS) (VE) (Entered: 10/15/2021)

MINUTE ORDER entered upon the authority of Judge Richard A. Jones. Plaintiff Washington Election Integrity Coalition United appears pro se in this matter. Local Rule 83.2(b)(4) requires that business entities other than sole proprietorships be represented by counsel. The Court directs Plaintiff Washington Election Integrity Coalition United to obtain counsel and that counsel shall make an appearance no later than 11/12/2021. (cc: Plaintiffs via USPS) (VE) (Entered: 10/15/2021)

MINUTE ORDER entered upon the authority of Judge Richard A. Jones. The local rules require that business entities other than sole proprietorships be represented by counsel. Accordingly, Plaintiff Washington Election Integrity Coalition United's pro se 9 MOTION to Strike Notice of Removal, or Alternatively, Sever Claims Under 28 U.S.C. ยง 1441(c)(2) is STRICKEN. (cc: Plaintiffs via USPS) (VE) (Entered: 10/15/2021)

NOTICE of Appearance by attorney Virginia Pearson Shogren on behalf of Plaintiff Washington Election Integrity Coalition United. (Shogren, Virginia) (Entered: 10/17/2021)

RESPONSE, by Plaintiff Washington Election Integrity Coalition United, to 4 Proposed MOTION to Intervene Attorney Reina A Almon-Griffin added to party Washington State Democratic Central Committee(pty:intvd). (Shogren, Virginia) (Entered: 10/20/2021)

NOTICE TO THE PARTIES: The Court acknowledges the requirements of FRCP 16(b), but finds good cause to defer entry of an initial case scheduling order pending its ruling on 4 MOTION to Intervene, filed by Intervenor Defendant Washington State Democratic Central Committee. (cc: Pro Se Plaintiffs via USPS) (VE)

Notice-Other

MOTION to Dismiss Pursuant to FRCP 12(b), filed by Defendants Garth Fell, Snohomish County. (Attachments: # 1 Proposed Order) Noting Date 11/12/2021, (Downs, Lyndsey) (Entered: 10/21/2021)

1 Proposed Order

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DECLARATION of Compliance with Court's Standing Order Re. Meet and Confer filed by Defendants Garth Fell, Snohomish County re 16 MOTION to Dismiss Pursuant to FRCP 12(b) (Downs, Lyndsey) (Entered: 10/21/2021)

Snohomish County Defendants' ANSWER to Complaint (Notice of Removal) re: 1 Notice of Removal,, by Garth Fell, Snohomish County.(Downs, Lyndsey) (Entered: 10/21/2021)

MOTION to Remand, filed by Plaintiff Washington Election Integrity Coalition United. (Attachments: # 1 Exhibit, # 2 Proposed Order) Noting Date 11/19/2021, (Shogren, Virginia) (Entered: 10/22/2021)

REPLY, filed by Intervenor Defendant Washington State Democratic Central Committee, TO RESPONSE to 4 Proposed MOTION to Intervene Attorney Reina A Almon-Griffin added to party Washington State Democratic Central Committee(pty:intvd) (Hamilton, Kevin) (Entered: 10/22/2021)

Attorney Kevin J Hamilton, Amanda J Beane, and Nitika Arora added for Washington State Democratic Central Committee added; per 4 Proposed MOTION to Intervene . (SR)

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CORPORATE DISCLOSURE STATEMENT indicating no Corporate Parents and/or Affiliates. Filed pursuant to Fed.R.Civ.P 7.1. Filed by Washington State Democratic Central Committee (Hamilton, Kevin) (Entered: 10/27/2021)

RESPONSE, by Defendants Garth Fell, Snohomish County, to 19 MOTION to Remand . (Downs, Lyndsey) (Entered: 11/05/2021)

RESPONSE, by Plaintiff Washington Election Integrity Coalition United, to 16 MOTION to Dismiss Pursuant to FRCP 12(b). (Attachments: # 1 Declaration, # 2 Joinder)(Shogren, Virginia) (Entered: 11/08/2021)

1 Declaration

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2 Joinder

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REPLY, filed by Defendants Garth Fell, Snohomish County, TO RESPONSE to 16 MOTION to Dismiss Pursuant to FRCP 12(b) (Downs, Lyndsey) (Entered: 11/12/2021)

REPLY, filed by Plaintiff Washington Election Integrity Coalition United, TO RESPONSE to 19 MOTION to Remand (Shogren, Virginia) (Entered: 11/19/2021)

MOTION to Dismiss Pursuant to FRCP 56, filed by Defendants Garth Fell, Snohomish County. (Attachments: # 1 Proposed Order) Noting Date 1/14/2022, (Downs, Lyndsey) (Entered: 12/07/2021)

1 Proposed Order

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DECLARATION of Snohomish County Public Records Officer Cecilia Wilson filed by Defendants Garth Fell, Snohomish County re 26 MOTION to Dismiss Pursuant to FRCP 56 (Downs, Lyndsey) (Entered: 12/07/2021)

DECLARATION of Evan Perez filed by Defendants Garth Fell, Snohomish County re 26 MOTION to Dismiss Pursuant to FRCP 56 (Downs, Lyndsey) (Entered: 12/07/2021)

DECLARATION of Snohomish County Auditor Garth Fell filed by Defendants Garth Fell, Snohomish County re 26 MOTION to Dismiss Pursuant to FRCP 56 (Downs, Lyndsey) (Entered: 12/07/2021)

DECLARATION of Lyndsey M. Downs (w/ Exhs. A & B) filed by Defendants Garth Fell, Snohomish County re 26 MOTION to Dismiss Pursuant to FRCP 56 (Downs, Lyndsey) (Entered: 12/07/2021)

MINUTE ORDER (text only) authorized by Judge Richard A. Jones. Case reassigned to Judge Lauren King. Judge Richard A. Jones no longer assigned to the case. (cc: Pro Se Plaintiffs via USPS) (VE)

Case Assigned/Reassigned to Judge

ORDER REGARDING 28 U.S.C. ยง 455(b)(2) AND CANON 3(C)(1)(B) OF THE CODE OF CONDUCT FOR UNITED STATES JUDGES by Judge Lauren King. (cc: Pro Se Plaintiffs via USPS) (NAW) (Entered: 12/30/2021)

NOTICE OF WITHDRAWAL OF COUNSEL: Attorney Nitika Arora for Intervenor Defendant Washington State Democratic Central Committee. (Almon-Griffin, Reina) (Entered: 01/05/2022)

CERTIFICATE OF SERVICE by Defendants Garth Fell, Snohomish County re 31 LK Order re 28 USC 455 (FORM) (Downs, Lyndsey) (Entered: 01/06/2022)

RESPONSE, by Plaintiff Washington Election Integrity Coalition United, to 26 MOTION to Dismiss Pursuant to FRCP 56. (Shogren, Virginia) (Entered: 01/10/2022)

DECLARATION of Tamborine Borrelli filed by Plaintiff Washington Election Integrity Coalition United re 26 MOTION to Dismiss Pursuant to FRCP 56 (Shogren, Virginia) (Entered: 01/10/2022)

REPLY, filed by Defendants Garth Fell, Snohomish County, TO RESPONSE to 26 MOTION to Dismiss Pursuant to FRCP 56 (Downs, Lyndsey) (Entered: 01/14/2022)

NOTICE of Supplemental Authority re 26 MOTION to Dismiss Pursuant to FRCP 56 by Defendants Garth Fell, Snohomish County (Downs, Lyndsey) (Entered: 04/07/2022)

NOTICE of Supplemental Authority re 4 Proposed MOTION to Intervene Attorney Reina A Almon-Griffin added to party Washington State Democratic Central Committee(pty:intvd) by Intervenor Defendant Washington State Democratic Central Committee (Almon-Griffin, Reina) (Entered: 05/03/2022)

NOTICE of Supplemental Authority re 4 Proposed MOTION to Intervene Attorney Reina A Almon-Griffin added to party Washington State Democratic Central Committee(pty:intvd) by Intervenor Defendant Washington State Democratic Central Committee (Attachments: # 1 Exhibit A-D)(Almon-Griffin, Reina) (Entered: 06/30/2022)

ORDER Requesting Supplemental Briefing re Remand. The parties are directed to review Scott v. Polo v. Innovations Int'l. Inc., 833 F.3d 1193 (9th Cir. 2016) and Britton v. Cnty. of Santa Cruz, No. 19-CV-04263-LHK, 2020 WL 4197609 (N.D. Cal. July 22, 2020), and are ordered to file supplemental briefs of up to three pages each addressing whether the parties will stipulate to remand of this matter. The briefs must be filed no later than August 15, 2022. Signed by Judge Lauren King. (MW)

SUPPLEMENT Briefing Re Remand by Plaintiff Washington Election Integrity Coalition United (Shogren, Virginia) (Entered: 08/15/2022)

SUPPLEMENT re 40 Order, from Court Requesting Suppl. Brief re. Remand by Defendants Garth Fell, Snohomish County (Downs, Lyndsey) (Entered: 08/15/2022)

ORDER: The Court DENIES WEICU's motion to remand, Dkt. No. 19 , and GRANTS Defendants' motion to dismiss Plaintiffs' claims, Dkt. No. 16 , without prejudice. The Court further DISMISSES WEICU's PRA claim and DENIES Defendants& #039; motion for summary judgment on that claim, Dkt. No. 26 , as moot. The Washington State Democratic Central Committees Motion to Intervene, Dkt. No. 4 , is also DENIED as moot. Signed by Judge Lauren King. (LH) Modified on 9/30/2022 to indicate mail-out to pro se plaintiffs (LH).

Judgment by Court

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