Case 3:11-cv-00123-TCB Document 263 Filed 07/17/15 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT FOR THE
NORTHERN DISTRICT OF GEORGIA
NEWNAN DIVISION
GEORGIA STATE CONFERENCE OF THE
NAACP, et al.
,
Plaintiffs, v.
FAYETTE COUNTY BOARD OF
CIVIL ACTION NO. 3:11-
CV-00123-TCB
COMMISSIONERS, et al.
,
Defendants.
PLAINTIFFS’ MOTION FOR PRELIMINARY INJUNCTION
OR, IN THE ALTERNATIVE, FOR FURTHER RELIEF
Pursuant to Rule 65 of the Federal Rules of Civil Procedure,
Plaintiffs, Georgia State Conference of the NAACP, Fayette County Branch of the NAACP, Henry Adams, Terence Clark, Alice Jones, John E. Jones,
Daniel (“Dan”) L. Lowry, Ali Abdur-Rahman, Aisha Abdur-Rahman, Lelia
Richardson, Elverta Williams, and Bonnie Lee Wright (collectively,
“Plaintiffs”), move for a preliminary injunction: (1) enjoining the Fayette
County Board of Commissioners (“BOC”) and its individual members in their official capacities, the Fayette County Board of Elections and Voter
Registration (“Board of Elections”), and Tom Sawyer, Department Head of the Board of Elections, in his official capacity (collectively, “County
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Case 3:11-cv-00123-TCB Document 263 Filed 07/17/15 Page 2 of 4
Defendants”), from qualifying candidates and conducting the special election and any special election runoff for County Commissioner Post 5 under at-large voting; (2) ordering County Defendants to qualify candidates and conduct the special election and any special election runoff in a manner consistent with this Court’s Order of February 18, 2014, Doc. 179, as supplemented by this Court’s Order of February 21, 2014, Doc. 181; and (3) ordering such additional relief as the interests of justice may require.
For the reasons more fully set forth in the accompanying
Memorandum of Law, the criteria for the issuance of this preliminary injunction is satisfied here. First , given this Court’s summary judgment decision and the Eleventh Circuit’s ruling, there is a substantial likelihood that Plaintiffs will succeed on the merits of their claim against County
Defendants at trial. Second , Plaintiffs will suffer irreparable harm in the absence of the preliminary injunction. Third , the balance of the equities clearly weighs in favor of a preliminary injunction. Fourth , the preliminary injunction will serve the public interest.
Accordingly, Plaintiffs respectfully request that this Court enter the preliminary injunction and order any such relief as it deems appropriate.
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Case 3:11-cv-00123-TCB Document 263 Filed 07/17/15 Page 3 of 4
Dated: July 17, 2015 Respectfully submitted,
/s/ Leah C. Aden
Leah C. Aden*
Christopher Kemmitt*
Natasha M. Korgaonkar*
Deuel Ross*
Victorien Wu*
NAACP LEGAL DEFENSE
AND EDUCATIONAL FUND, INC.
40 Rector Street, 5th Floor
New York, NY 10006
(212) 965-2200
(212) 229-7592 (fax) laden@naacpldf.org
* Admitted Pro Hac Vice
Neil Bradley
Georgia Bar No. 075125
3276 Wynn Drive
Avondale Estates, GA 30002
(404) 298-5052 neil.bradley.ga@gmail.com
Attorneys for Plaintiffs
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Case 3:11-cv-00123-TCB Document 263 Filed 07/17/15 Page 4 of 4
CERTIFICATE OF SERVICE
I hereby certify that on July 17, 2015, I electronically filed Plaintiffs’
Motion for Preliminary Injunction or, in the Alternative, for Further Relief on behalf of Plaintiffs with the Clerk of Court using the CM/ECF system, which will automatically send email notification of such filing to all attorneys of record registered with the ECF system as required by this
Court’s Rules.
/s/ Leah C. Aden
LEAH C. ADEN
NAACP LEGAL DEFENSE
AND EDUCATIONAL FUND, INC.
40 Rector Street, 5th Floor
New York, NY 10006
(212) 965-2200
(212) 229-7592 (fax)
Attorney for Plaintiffs
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