-Caveat Lector-
Text of NAACP Florida Law Suit, filed 1/10/01, pt. 2
(continued)
C. Wrongful Purging of Voters from Official Lists of
Eligible Voters
61. Pursuant to state and federal law, Defendants Harris,
Roberts and the Supervisors of Elections are charged with
administering and maintaining the state's overall list
maintenance programs and the state's central voter file.
Both state and federal law establish the manner in which the
voter registration information must be maintained and the
circumstances in which individuals may be purged from the
voter rolls.
62. Defendant Roberts contracted with Defendant DBT to
compare information in the state's central voter file with
information available in other computer databases and
prepare a list of registered voters who were ineligible to
vote. Upon information and belief, in the course of
carrying out this contract, Defendant DBT wrongfully
identified qualified voters as ineligible to vote and
communicated that incorrect information to Defendants.
63. Upon information and belief, Defendants Harris, Roberts
and DBT determined the matching and other criteria and
sources of information for creating the lists of ineligible
voters to be forwarded to county supervisors under Fla.
Stat. Ann. =A7 98.0975. Upon information and belief,
Defendants Harris, Roberts and DBT have failed to exercise
appropriate diligence and care to ensure and to verify the
reliability and accuracy of the list of ineligible voters
that was forwarded to each county supervisor pursuant to the
state list maintenance program mandated by Fla. Stat. Ann. =A7
98.0975.
64. Upon information and belief, prior to the November 7,
2000 general election, Defendants Harris and Roberts failed
to require that all county supervisors adopt effective
measures to ensure accurate purging of the names of
registered voters on the lists provided by the state, and to
prevent county election supervisors from purging voters
without verifying the information provided in the lists.
Upon information and belief, Defendants Harris and Roberts
failed to ensure that county supervisors would be able to
verify in a timely manner the lists of ineligible voters
provided by the state, and to determine whether the
information provided by the state was accurate.
65. Upon information and belief, prior to the November 7,
2000 general election, Defendant county supervisors adopted
widely varying approaches to purging the names of registered
voters based on the lists provided by the state. Upon
information and belief, many Defendant county supervisors
failed to verify at all or to verify adequately the
information provided by the state, and, as a result,
wrongfully purged numerous voters from their official lists
of registered voters.
66. Upon information and belief, Defendants Harris and
Roberts have failed to provide, require, or enforce uniform
standards, and have failed to provide adequate time or
resources for county supervisors to verify the lists of
ineligible voters that the state forwards to the counties so
as to ensure that eligible voters are not wrongly purged
from the official lists of registered voters.
67. Upon information and belief, Defendants' administration
of the voter roll purging process required by state and
federal law had a disproportionate adverse impact on black
voters and resulted in a larger percentage of black voters
than white voters being wrongly removed from the official
lists of registered voters.
68. Plaintiff WILLIE STEEN has been a properly registered
voter living in Hillsborough County, Florida since he was
honorably discharged from the military in 1993. He has
lived at his current address since December 1999. On
November 7, 2000, Mr. Steen went to vote for the first time.
When he arrived at his polling place, he was told that he
could not vote because he had a felony conviction. Mr.
Steen has never been arrested or convicted of any crime.
Mr. Steen was improperly denied the right to vote.
69. Plaintiff WALLACE MCDONALD is a properly registered
voter residing in Hillsborough County, Florida. In June
2000 he received a letter from the Hillsborough County
Supervisor of Elections informing him that he would be
removed from the voter rolls because of a prior felony
conviction. Mr. McDonald responded in writing, informing
the Supervisor that he has not been convicted of a felony.
He also engaged an attorney to search the court records in
Hillsborough County. His attorney found no record of a
felony conviction. Upon information and belief, although
Mr. McDonald's attorney brought this to the attention of the
Supervisor of Elections, the Supervisor nevertheless refused
to reinstate Mr. McDonald as a registered voter. Mr.
McDonald does not have a felony conviction and was
improperly denied the right to vote.
70. Plaintiff JERMAINE TERRY is a properly registered voter
living in Hillsborough County, Florida. On November 7,
2000, Mr. Terry was told by Hillsborough County voting
officials at the polls that he had been purged from the
voter roll, and he was not allowed to vote. There is no
valid basis upon which Mr. Terry could have been purged from
the voter rolls. On information and belief, records of the
Supervisor of Elections of Hillsborough County indicated
simply that he was deleted from the rolls pursuant to the
National Voter Registration Act. Such deletion was not
proper under state or federal law. As a result of this
violation, Mr. Terry was improperly denied the right to
vote.
71. Plaintiff LORINE WALDEN has been a registered voter
since the 1960s. About one week prior to the November 7,
2000 general election, she went in person to check the
status of her registration. The employee at the Supervisor
of Elections office checked something on a computer and then
informed her that she was not in the system and that she
would not be allowed to vote in the general election this
year. There is no valid basis upon which Ms. Walden could
have been purged from the voter rolls. Because the clerk
specifically informed her that she could not vote in this
election, Ms. Walden did not try to vote on November 7,
2000, and was effectively and improperly denied the right to
vote.
72. Plaintiff EMERY TIMBERLAKE is a properly registered
voter living in Volusia County. Mr. Timberlake requested
an absentee ballot for the November 7, 2000 election. He
never received a ballot or any other response from the
Supervisor of Elections. On November 7, 2000, Mr.
Timberlake went to his polling place to vote. Mr.
Timberlake gave his voter registration card and driver's
license to the clerk. The clerk reviewed the voter roll and
told him that he was not on it and that he could not vote.
No further information or assistance was offered to Mr.
Timberlake at that time. There is no valid basis upon which
Mr. Timberlake could have been purged from the voter rolls.
On information and belief, the Supervisor of Elections
removed Mr. Timberlake from the rolls in 1999 based on an
alleged duplicate registration in Alabama. Mr. Timberlake
has never lived in or registered to vote in Alabama. Mr.
Timberlake was improperly denied the right to vote.
73. Plaintiff VALERIE BUFORD-WELLS is a properly registered
voter residing in Broward County. On November 7, 2000, Ms.
Buford-Wells went to her assigned precinct and presented her
voter registration card and driver's license to the precinct
official. The official informed her that her name was not
on the list of registered voters. The precinct official
tried to call the Broward County Supervisor of Elections
office but the line was busy. There is no valid basis upon
which Ms. Buford-Wells could have been purged from the voter
rolls. Ms. Buford-Wells was improperly denied the right to
vote.
D. Failure to Timely and Correctly Process Voter
Registration Applications or Address Information
74. Under state and federal law, Florida residents can
register to vote or update a registration in person at their
county Supervisor of Elections offices or at a number of
other state agencies, including the Department of Highway
Safety and Motor Vehicles and social services offices, or by
mailing a completed application to the Supervisors of
Elections office. Fla. Stat. Ann. =A7=A7 97.053 et seq. Under
Florida law, a valid initial voter registration application
submitted by mail and bearing a clear postmark is effective
as of the date of the postmark. Fla. Stat. Ann. =A7
97.053(4). If there is no postmark, or if the postmark is
unclear, the registration is effective as of the date of
receipt, unless it is received within 5 days after the
closing of the books for an election, in which case the
effective date of the applicant's registration is the book-
closing date.
75. Upon information and belief, Defendants Harris and
Roberts have failed to provide, require, or enforce uniform
standards and procedures for the timely, accurate and proper
processing of voter registration applications and the
registration of voters. On information and belief,
Defendants Election Supervisors of Hillsborough, Leon,
Orange, Broward, and Duval Counties failed or refused to
process many new voter registration applications that were
submitted to them prior to the deadline imposed by state
law.
76. Plaintiff MICHELLE FLOYD submitted a completed voter
registration application to the Leon County Supervisor of
Elections around September 2000. On
November 7, 2000 she went to vote at her local polling site
at the Florida A&M University Grand Ballroom. Ms. Floyd was
listed on the precinct register, but instead of being given
a ballot, she was referred to a clerk at another table. The
clerk reviewed Ms. Floyd's identification, but then told her
she could not vote and she would have to call someone else.
Ms. Floyd was never permitted to vote on November 7.
Shortly after the election, Ms. Floyd received her voter
registration card in the mail. The card listed her
registration date as September 5, 2000 and her polling site
as the Grand Ballroom, where she went to vote in November.
Ms. Floyd was improperly denied the right to vote on
November 7, 2000.
77. Plaintiff CONSUELO MARIA GRAHAM lives with her father
in Orange County, Florida. In September 2000, Ms. Graham
completed a voter registration application request on-line.
On approximately October 3, 2000, she received a voter
registration application in the mail for her signature. She
signed the application and submitted it to the Orange County
Supervisor of Elections. As of October 9, 2000, she had not
received a voter registration card, so Ms. Graham completed
another voter registration application, which was submitted
to the Supervisor of Elections on or before October 10,
2000, the deadline for voter registration for the November
election. On November 7, 2000, Ms. Graham went to the
polling site where her father voted in order to cast her
ballot. She was told that she was not on the precinct
register and she was not allowed to vote. At no time did
any poll worker offer to call to inquire as to her
eligibility to vote. Ms. Graham was improperly denied the
right to vote on November 7, 2000.
78. Plaintiff SHERRY EDWARDS is a resident of Hillsborough
County, Florida. When Ms. Edwards was at the Department of
Highway Safety and Motor Vehicles office in September 2000
obtaining a Florida driver's license, she registered to
vote. Ms. Edwards never received a response from the
Hillsborough County Supervisor of Elections regarding her
voter registration application. On November 6, 2000, she
contacted the Supervisor of Elections office to inquire
about where to vote. She was informed that she was not a
registered voter and would not be permitted to vote in the
fall general election. On November 7, 2000, Ms. Edwards
went to her local polling site to vote. She was not listed
on the voter roll and was not allowed to vote. Ms. Edwards
was improperly denied the right to vote.
79. Plaintiff KANDY WELLS completed a voter registration
application in 2000 that was personally delivered by Mrs.
Wells' father to the Hillsborough County Supervisor of
Elections office on October 9, 2000. Mrs. Wells did not
receive a voter registration card prior to election day.
She believed that her registration application had not been
processed since she had not received anything from the
Supervisor of Elections, and accordingly, she did not vote
on November 7, 2000. On December 7, 2000, Mrs. Wells
received a new voter registration card in the mail. The
card indicates that it was issued on November 20, 2000. Mrs.
Wells was improperly denied registration effective for the
November 2000 general election.
80. Plaintiff JOANNA CLARK is a resident of Broward County,
Florida who has been registered to vote in Broward County
since approximately 1995. In or about October 1999, Ms.
Clark moved within the County, from Pompano Beach to Fort
Lauderdale. In or about April 2000, Ms. Clark completed a
voter's registration change of address form at the
Department of Children and Family Services Office in Broward
County. Ms. Clark had not received a new voter registration
card, so she submitted another change of address form
approximately two weeks prior to the November 7, 2000
election. On November 7, 2000, she went to her former
polling place at Pompano Beach Middle School. A precinct
official informed her that she was not on the voter list.
Clark indicated that she had moved to Fort Lauderdale. The
official told her that she had to find somewhere in Fort
Lauderdale to vote but stated that she did not know the
location of her new polling place and had no way of finding
out. Clark noticed her name on the voter list and pointed
it out to the precinct official. The official replied that
she could not allow Clark to vote because that would be
considered a felony and she could have Clark arrested.
Clark was improperly denied the right to vote in the
November 7, 2000 general election.
81. Plaintiff JANICE KELLY is a resident of Duval County,
Florida where she has been a registered voter since
approximately 1994. After her initial registration in Duval
County, Ms. Kelly moved to a new address within the county.
When she moved, Ms. Kelly obtained a new driver's license.
In 1998, Ms. Kelly went to vote at her old polling site, as
she had never received information about the correct polling
site based on her new address. She was permitted to vote at
her old polling place and she told the poll workers there
that she had moved, and provided them with her new address.
Ms. Kelly never received a new voter registration card or
information regarding a new polling site. On November 7,
2000, Ms. Kelly went to vote at her old polling site. There
was no voting at that site and there were no signs directing
voters to another location. Ms. Kelly then drove to a fire
station where she had seen voters lined up earlier in the
day, and there she was told that she had to go to a church
down the road to vote. Ms. Kelly rushed to the church,
arriving just before 7:00 p.m., but she was told that she
could not vote because the polls were closed. Ms. Kelly was
improperly denied the right to vote.
82. The failure of Defendants Harris and Roberts to provide
for and ensure the proper and timely processing of voter
registrations and address changes and the failure of
Defendants Hillsborough, Leon, Orange, Broward, and Duval
county election supervisors to properly and timely process
voter registration applications and voters' change of
address information submitted before the close of
registration for the 2000 general election violates state
and federal law and denied Plaintiffs listed in paragraphs
76-81 above the right to vote.
E. Improper Procedures for Change of Residence and Unequal
Access to Inactive List
83. Defendants Harris and Roberts and Defendants Election
Supervisors in Broward, Hillsborough, and Miami-Dade
Counties, among others, failed to comply with the National
Voter Registration Act in conducting a program to verify
changes of residence by voters and to remove voters
ineligible to vote within their respective jurisdictions
because of changes of residence. The manner in which
registration rolls and eligible voter lists were maintained
by these Defendants for the November 2000 general election
denied or abridged the rights of black voters within these
jurisdictions to participate in the election on the same
basis as other voters.
84. Upon information and belief, qualified black voters in
Florida were improperly denied the right to vote as a result
of the practices complained of herein in disproportionately
greater numbers than white voters, despite the fact that
they were properly registered and included in the category
of eligible voters according to the records of the
Supervisor of Elections for their respective counties.
85. Under Defendants' address change verification and voter
removal program that was in effect for the 2000 general
election, certain registered voters were placed on an
"inactive" list and were not included on their respective
voting precincts' lists of voters on Election Day.
Although such voters remained registered voters, Defendants
did not require that the names of voters on the "inactive"
list be kept at the polling place and in most precincts they
were not available. As a result, an "inactive" voter was
only able to vote if an official at the polling place
contacted the central county office, which in most cases
could be done only by telephone, to confirm the elector's
eligibility to vote. Defendants failed to provide or
maintain adequate telephone capacity in Supervisors'
offices. As a result, many of the telephone lines were busy
for long periods of time on election day and were still busy
as of 7 p.m, the poll closing time. The status of large
numbers of voters who had been placed on an "inactive" list
could not be verified and, consequently, these individuals
were denied the right to vote.
86. Defendants' address change verification and voter
removal program, as described above, and in particular the
failure to maintain information about voters on an
"inactive" list at polling places, effectively removed
persons from the official eligible voter list in violation
of state and federal law.
87. On information and belief, in Hillsborough County, ten
precincts were provided with laptop computers to enable poll
workers to directly access the county files of eligible
voters (including voters on an "inactive" list) without
having to call a central county telephone number. On
information and belief, none of the county's majority black
precincts received a laptop computer.
88. On information and belief, in Miami-Dade County, laptop
computers were available in eighteen precincts, but only one
majority-black precinct was equipped with a laptop computer
on election day to enable poll workers to directly access
information concerning eligible voters (including voters on
an "inactive" list).
89. This unequal access to the inactive list resulted in
disproportionately greater numbers of black voters being
wrongfully denied the right to vote, and effectively
resulted in those voters being purged in a manner contrary
to state and federal statutory provisions for voter list
maintenance.
90. Plaintiff PLACIDE DOSSOUS moved from Dade to Broward
County in September 1999, and in July 2000 notified the
Department of Highway Safety and Motor Vehicles of his new
address when he changed his drivers' license. Mr. Dossous
never received a new voter registration card. On November
7, 2000, Mr. Dossous first went to his previous polling
place at the Korean Presbyterian Church in Dade County in an
effort to find out where he should vote. The clerk told him
that he was not on the voter list. The clerk could not get
through to the Supervisor of Elections because of busy phone
lines and therefore provided no assistance to Mr. Dossous in
determining where he should vote. Mr. Dossous returned home
where he later received a telephone call from someone urging
him to vote. He explained that he had already tried to
vote. The caller told Mr. Dossous that she had found his
name in the Sheridan Vocational School voter list, in
Broward County. Mr. Dossous went to the Sheridan Vocational
School, where a clerk informed him that he was not on the
voter list. Mr. Dossous waited for two hours while a
polling official tried to telephone the Supervisor of
Elections, but never got through. Mr. Dossous finally left
his name and telephone number for poll officials to call
when they reached the Supervisor of Elections. He never
received a call. Mr. Dossous was improperly denied the
right to vote in the November 7, 2000 general election.
91. Plaintiff RONDRICK ROSE is a properly registered voter
residing in Hillsborough County, Florida. In December 1999,
Plaintiff Rose moved from one address to another within
Hillsborough County. He changed his address with the
Department of Highway Safety and Motor Vehicles and the
United States Postal Service. On November 7, 2000, he went
to the polling site for his new address and presented
identification. Mr. Rose was not listed on the precinct
register and he was instructed to complete an affirmation
form, which he did, and he was then told that a poll worker
would have to call to verify his eligibility to vote. On
information and belief, Mr. Rose was listed in the county
database as an "inactive" voter. Mr. Rose waited for
approximately two hours, while a poll worker called to
confirm his registration. The phone line was continuously
busy and the worker was not able to get through to anyone at
the Supervisor of Elections office. Mr. Rose was improperly
denied the right to vote.
National Voter Registration Act
92. The National Voter Registration Act ("NVRA"), 42 U.S.C.
=A7 1973gg et seq., requires the Defendants to properly and
timely process voter registration applications and changes
of address, to timely notify applicants of the disposition
of their applications, to carry out voter deletions and
transfers to inactive status in a particular manner and to
permit voters who have moved within the same political
subdivision to vote even if they have not updated their
registration to indicate their new address.
93. Pursuant to 42 U.S.C. =A7 1973gg-9(b), Plaintiffs have
notified Defendant Harris of the various violations of the
NVRA that have occurred and requested that they be corrected
as provided by statute. A copy of this letter is attached
hereto as Attachment A. Plaintiffs anticipate amending the
complaint to seek redress for these NVRA violations should
Defendants fail or refuse to correct them.
Equitable Relief
94. Plaintiffs have no adequate remedy at law for such
deprivation of their rights, privileges and immunities.
CLAIMS FOR RELIEF
COUNT I
(Fourteenth Amendment Equal Protection and Due Process
Clauses)
95. Plaintiffs hereby reallege and incorporate by reference
paragraphs 1 through 94 above.
96. Defendants Harris and Roberts have maintained and
administered non-uniform methods and practices of
administering elections and counting ballots in violation of
the Equal Protection and Due Process Clauses of the
Fourteenth Amendment of the United States Constitution and
42 U.S.C. =A7 1983.
COUNT II
(Section 2 of the Voting Rights Act of 1965)
97. Plaintiffs hereby reallege and incorporate by
reference paragraphs 1 through 94 above.
98. Defendant Leahy's methods of administering the November
7, 2000 general election denied black voters an equal
opportunity to participate in the Presidential election in
violation of Section 2 of the Voting Rights Act of 1965, as
amended, 42 U.S.C. =A7 1973.
99. Defendants Harris, Roberts, DBT, Leahy, Oliphant
(through her predecessor Carroll), and Iorio's actions in
failing to adopt and implement uniform standards of
reliability and accuracy for voting machines or systems that
may be selected or utilized by county supervisors of
elections, and procedures connected with their use; in the
purging of voters from official lists of eligible voters;
and in their maintenance and administration of "inactive"
lists and the unequal availability of access to those lists
denied black voters an equal opportunity to participate in
the Presidential election in violation of Section 2 of the
Voting Rights Act of 1965, as amended, 42 U.S.C. =A7 1973.
COUNT III
(42 U.S.C. =A7 1983)
100. Plaintiffs hereby reallege and incorporate by
reference paragraphs 1 through 94 above.
101. All Defendants, acting under color of state law, have
deprived Plaintiffs of the rights, privileges, and
immunities secured to them under the Fourteenth Amendment to
the United States Constitution, the National Voter
Registration Act, and 42 U.S.C. =A7 1983 to participate in the
electoral process.
COUNT IV
(Civil Rights Acts of 1957 & 1960)
102. Plaintiffs hereby reallege and incorporate by
reference paragraphs 1 through 94 above.
103. All Defendants, by their actions as described in
this Complaint, have, acting under color of law, applied
different standards, practices or procedures in determining
whether some voters were qualified to vote than were applied
to other voters within the same county who have been found
by State officials to be qualified to vote and denied
individuals the right to vote because of immaterial errors
and omissions in registration and ballot applications, in
violation of 42 U.S.C. =A7=A7 1971(a)(2)(A) and 1971(a)(2)(B).
COUNT V
( Fla. Stat. =A7 104.0515)
104. Plaintiffs hereby reallege and incorporate by
reference paragraphs 1 through 94 above.
105. Defendants, by their actions described in this
Complaint, have applied prerequisites to voting, employed
certain voting methods, and administered elections using
standards, practices and procedures in a manner which
results in denial or abridgement of the rights of citizens
in Florida to vote on account of race or color in violation
of Florida Statutes =A7104.0515.
PRAYER FOR RELIEF
WHEREFORE, Plaintiffs request that this Court enter
judgment in their favor:
(1) Certifying, for the purposes of declaratory and
injunctive relief, a class of all black citizens of the
State of Florida eligible to vote, who were registered
voters or who took timely and appropriate steps to register
as voters, who sought to vote in the November 7, 2000
general election, and who were denied the opportunity to
vote or were denied an equal opportunity to vote and have
their votes counted in that election, by the actions,
policies and practices of the Defendants, in violation of
the Fourteenth Amendment of the United States Constitution,
Section 2 of the Voting Rights Act of 1965, codified at 42
U.S.C. =A7 1973 et seq., the Civil Rights Acts of 1957 and
1960, codified at 42 U.S.C. =A7 1971(a)(1), 1971(a)(2)(A) and
1971(a)(2)(B), 42 U.S.C. =A7 1983, and/or the Florida Voting
Rights Act, Fla. Stat. Ann. =A7 104.0515;
(2) Declaring that Defendants' use of "punch-card" voting
machines or systems, other unreliable voting systems, and
procedures connected with their use; failure to process
timely voter registration applications; wrongful purge of
qualified voters; failure to have complete and accurate
voter lists at the polls and effective election day
procedures; and failure to allow voters who have moved
within the county to vote; caused the Plaintiffs and members
of the Plaintiff class to be treated differently than
similarly situated white voters, and denied them fundamental
fairness and an equal opportunity to participate in the
electoral process in the November 2000 general election, all
in violation of the law as set forth in the claims for
relief;
(3) Enjoining Defendants immediately to discontinue the use
of prerequisites to voting, certain voting methods, and
administering elections using standards, practices and
procedures in a manner which results in denial or
abridgement of the rights of citizens in Florida to vote on
account of race or color, or in a manner that otherwise
violates federal or state law, including, but not limited
to, requiring Defendants to do the following:
a. To decertify all "punch-card" voting methods and other
unreliable voting methods as acceptable voting methods under
Florida law;
b. To adopt standards and implement training designed to
insure that voting systems and procedures at polling places
within their jurisdiction are equal, accurate and reliable,
and are uniformly administered;
c. To maintain any list of inactive voters at polling places
as part of the official list of eligible voters and as
accessible to precinct officials as are the active lists;
d. To provide a mechanism for persons whose names do not
appear on the list of registered voters at the polling place
to vote in as timely a fashion as those whose names do
appear on the list, subject to challenge if they are shown
not to be qualified to vote;
e. To accurately determine and restore to appropriate status
all persons wrongfully purged based on the DBT list and all
other persons purged in violation of state and federal law;
f. To discontinue all voter purges of the voter registration
rolls until the development of procedures to ensure uniform,
non-discriminatory application of the law;
g. To prohibit the removal of the name of any person from
the official voter registration lists on account of death,
felony conviction or adjudication of mental incapacity based
on information that has not been verified and determined to
be a correct match for that person;
h. To complete all purges not later than 90 days before any
election;
i. To extend, by at least four years, the time that voters
identified as those who may have moved, who did not vote in
November 2000, remain on the inactive list before they are
purged, to remedy the situation of inactive list voters who
were denied the right to vote in the November 2000 election;
j. To develop and implement training for all personnel
involved in the administration of the electoral process to
ensure compliance with this order and all laws related to
the non-discriminatory operation of the political process;
k. To provide equitable, accurate equipment, facilities and
resources for the administration of the electoral process
statewide, including, but not limited to, the technology
to facilitate verification of voter registration in all
polling sites; and,
l. To affirmatively notify voters of their rights at polling
places, by posted notice or otherwise, including their
rights to assistance, to correct their ballots if they
believe they have made an error, to alternative
identification procedures if they do not have a photo
identification and to vote even if they have changed
address, including the steps to follow to assert these
rights;
(4) Appointing, pursuant to Section 3(a) of the Voting
Rights Act, 42 U.S.C. =A7 1973a, federal examiners in each of
the Defendant counties for the next ten years;
(5) Retaining jurisdiction of this case, pursuant to
Section 3(c) of the Voting Rights Act, 42 U.S.C. =A7 1973a;
(6) Awarding Plaintiffs their costs and disbursements
associated with the filing and maintenance of this action,
including an award of reasonable attorneys' fees pursuant to
42 U.S.C. =A7=A7 1973l and 1988; and
(7) Awarding such other equitable and further relief as the
Court deems just and proper.
DATED this 10th day of January, 2001.
Respectfully submitted,
Dennis Hayes, Esq.
Angela Ciccolo, Esq.
Bruce Gear, Esq.
NAACP Legal Department
4805 Mount Hope Drive, Fifth Floor
Baltimore, MD 212153297
Facsimile: 410/358-9350
LAW OFFICES
WILLIAMS & ASSOCIATES, P.A.
Brickell BayView Centre, Suite 1830
80 S.W. Eighth Street
Miami, FL 33130
Facsimile: 305/379-4541
By: THOMASINA H. WILLIAMS
FLORIDA BAR NO. 629227
Barbara Arnwine, Esq.
Thomas J. Henderson, Esq.
Edward Still, Esq.
Anita Hodgkiss, Esq.
Lori Outzs Borgen, Esq.
Lawyers' Committee for Civil Rights Under Law
1401 New York Avenue, NW, Suite 400
Washington, DC 200052124
Telephone: 202/662-8600 or 888/299-5227
Facsimile: 202/783-5130
Elaine R. Jones, Esq.
Director-Counsel
Theodore M. Shaw, Esq.
Norman Chachkin, Esq.
Jacqueline A. Berrien, Esq.
NAACP Legal Defense & Educational Fund, Inc.
99 Hudson Street, Suite 1600
New York, NY 10013
Telephone: 212/965-2200
Facsimile: 212/226-7592
Todd A. Cox, Esq.
NAACP Legal Defense & Educational Fund, Inc.
1444 Eye Street, NW, 10th Floor
Washington, DC 20005
Telephone: 202/682-1300
Facsimile: 202/682-1312
Laughlin McDonald, Esq.
ACLU Voting Rights Project
2725 Harris Tower
233 Peachtree Street NE
Atlanta, GA 30303
Telephone: 404/523-2721
Facsimile: 404/653-0331
From the website of the ACLU of Florida
3000 Biscayne Blvd. Suite 215
Miami, FL 33137 (305) 576-2336
<A HREF="http://www.ctrl.org/">www.ctrl.org</A>
DECLARATION & DISCLAIMER
==========
CTRL is a discussion & informational exchange list. Proselytizing propagandic
screeds are unwelcomed. Substance�not soap-boxing�please! These are
sordid matters and 'conspiracy theory'�with its many half-truths, mis-
directions and outright frauds�is used politically by different groups with
major and minor effects spread throughout the spectrum of time and thought.
That being said, CTRLgives no endorsement to the validity of posts, and
always suggests to readers; be wary of what you read. CTRL gives no
credence to Holocaust denial and nazi's need not apply.
Let us please be civil and as always, Caveat Lector.
========================================================================
Archives Available at:
http://peach.ease.lsoft.com/archives/ctrl.html
<A HREF="http://peach.ease.lsoft.com/archives/ctrl.html">Archives of
[EMAIL PROTECTED]</A>
http:[EMAIL PROTECTED]/
<A HREF="http:[EMAIL PROTECTED]/">ctrl</A>
========================================================================
To subscribe to Conspiracy Theory Research List[CTRL] send email:
SUBSCRIBE CTRL [to:] [EMAIL PROTECTED]
To UNsubscribe to Conspiracy Theory Research List[CTRL] send email:
SIGNOFF CTRL [to:] [EMAIL PROTECTED]
Om
