Beruflich Dokumente
Kultur Dokumente
State Representatives Sidney Bondurant, Becky Currie, and Mary Ann Stevens (the
“Representatives”) hereby respectfully reurge and amend their motion before this Court for leave
to intervene in this action as a matter of right, pursuant to Fed. R. Civ. P. 24(a)(2). Alternatively,
the Representatives move for leave to intervene by permission, pursuant to Fed. R. Civ. P.
24(b)(1)(b). In support of their motion, the Representatives further show the following:
Mississippi and a duly elected member of the Mississippi State House of Representatives, having
served continuously in that body since 2004. State Representative Becky Currie is a qualified
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elector of Lincoln County, Mississippi and a duly elected member of the Mississippi State House
of Representatives, having served continuously in that body since 2008. State Representative
Mary Ann Stevens is a qualified elector of Holmes County, Mississippi and a duly elected
member of the Mississippi State House of Representatives, having served continuously in that
2. The Representatives seek leave to intervene in this case in order to protect their
interests and the interests of other citizens of the State of Mississippi similarly situated with
respect to the adoption of a 2011 House Redistricting Plan and Map, considered in various
resolutions during the 2011 Regular Session of the Mississippi Legislature. On information and
belief, various parties in the above action have requested the Court to appoint an expert to
develop a Redistricting Plan and Map, including a motion filed by the Mississippi Republican
Party Executive Committee [Docket 67] and separate memorandum filed by Governor Haley
Barbour as recently as today, April 21, 2011 [Docket 70]. Other parties have urged the Court to
adopt a purported “approved” House Plan as a remedy in this action; the Representatives oppose
adoption or use of any of the maps that passed the House of Representatives but failed in the
Senate. Voters who are also elected officials affected by the case have standing to intervene in a
redistricting lawsuit. See League of United Latin American Citizens Council No. 4434 v.
3. The Representatives also seek leave to intervene to protect their interests and the
interests of other citizens of the State of Mississippi similarly situated with respect to the timely
conducting of the State of Mississippi’s legislative elections in 2011. The Representatives thus
have an interest in the subject matter of this action, and are so situated that disposing of this
action will as a practical matter impair or impede their ability to protect their interests, and the
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interests of other citizens similarly situated, which are not being asserted or adequately pursued
4. The Mississippi Legislature adjourned finally, or sine die, from the 2011 Regular
Session on Thursday, April 7, 2011. As of that date, both the State Senate and the State House of
negotiations. Not until the sine die adjournment on April 7 was it apparent that the Legislature
would not be able to adopt a joint resolution of redistricting as required by Sec. 254 of the
Mississippi Constitution of 1890 during the 2011 Regular Session. Moreover, while negotiations
have proceeded between House and Senate members out of Session to work out an acceptable
Redistricting Plan and Map, only this week has it become apparent that various parties here are
requesting that this Court develop a map. Because of these developments, intervention by the
5. The Representatives respectfully request that this Court allow them to intervene in
this case to protect their interests and the interests of other citizens similarly situated. The
Representatives have claims or defenses that share common questions of law and fact with this
action, and they are particularly similarly situated as the other Intervenors who have been
allowed to intervene by this Court. Specifically, the Representatives seek to join the Motion to
Dismiss filed by Secretary of State Delbert Hosemann as their responsive pleading to the
6. Pursuant to L.U.Civ.R. 7(b)(8), the movants request that the Court expedite the
hearing of this motion, in order to allow the Representatives’ full participation in the proceedings
on the docket of this Court. Because of the straightforward nature of the relief requested herein,
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the Representatives further request leave from the Court not to file a separate memorandum in
with counsel for the other parties in this case to determine whether any oppose this motion to
intervene, but responses from some counsel have yet to be received. As a result, counsel is not
Currie, and Mary Ann Stevens respectfully request that this Court grant his motion to intervene
as of right, or, alternatively, by permission, and that consideration of this matter be expedited in
Respectfully submitted,
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CERTIFICATE OF SERVICE
I, Cory T. Wilson, do hereby certify that I have this date electronically filed the foregoing
Motion to Intervene with the Clerk of the court using the ECF system which sent notification of