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SIDLEY AUSTIN BROWN & WOOD LLP 1501 K STREET, N.W. WASHINGTON, D.C. 20005 TELEPHONE 202 736 8000 FACSIMILE 202 736 8711 www.sidley.com
WRITER'S DIRECT NUMBER
WRITER'S E-MAIL
ADDRESS
September 21, 2004
Garland Pinkston Jr., Clerk Re: Citizens Committee for the D.C. Video Lottery Terminal Initiative v. District of Columbia Board of Elections and Ethics and Ronald L. Drake, et al., D.C. No. 04-AA-957 Dear Mr. Pinkston: Enclosed for filing and circulation to the panel in the referenced expedited appeal is an original and three copies of a letter seeking leave to respond to the Board of Elections and Ethics' "Clarification Memorandum Opinion" on Thursday, September 23, 2004.I would appreciate it if you would make sure the enclosed letter is circulated to the panel as promptly as possible this morning.
Very truly yours, GWJ:gwj
cc: Kenneth J. McGhie (By telecopy) SIDLEY AUSTIN BROWN & WOOD LLP 1501 K STREET, N.W. WASHINGTON, D.C. 20005 TELEPHONE 202 736 8000 FACSIMILE 202 736 8711 www.sidley.com
WRITER'S DIRECT NUMBER
WRITER'S E-MAIL
ADDRESS
September 21, 2004
The Honorable Michael W. Farrell Re: Citizens Committee for the D.C. Video Lottery Terminal Initiative v. District of Columbia Board of Elections and Ethics and Ronald L. Drake, et al., D.C. No. 04-AA-957 Dear Judges Farrell, Ruiz, and Newman: Yesterday, the Board of Elections and Ethics responded to the two simple questions posed in the Court's Order of September 13, 2004 with an 18 page "Clarification Memorandum Opinion." As Petitioner noted in its September 19, 2004 letter to the Court, however, there is no evidence in the record or any defensible rationale that can support the Board's decision to exclude all of the thousands of signatures of registered voters collected by all circulators associated with the Stars & Stripes organization -- especially those circulators identified in Sections C.2 and D of Attachment A to the Board's clarification opinion. As Attachment A to the Board's opinion confirms, unless the signatures collected by circulators as to whom the Board has no evidence of individual wrongdoing are excluded, Initiative 68 satisfies the requirements for inclusion on the November 2004 ballot. Petitioner respectfully requests leave to file a memorandum no later than close of business on Thursday, September 23, 2004, explaining in detail why the Board's most recent attempt to defend its refusal to count thousands of signatures of registered voters fails and why the Board should be ordered to include Initiative 68 on the November ballot, subject to completion of the statutory random sampling procedure. Very truly yours, GWJ:gwj cc: Kenneth J. McGhie (By telecopy) George W. Jones, Jr. |
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