1 2 3 4 5 Mary R. O’Grady, 011434 Joseph N. Roth, 025725 Joshua D. Bendor, 031908 OSBORN MALEDON, P.A. 2929 North Central Avenue, Suite 2100 Phoenix, Arizona 85012-2793 (602) 640-9000 mogrady@omlaw.com jroth@omlaw.com jbendor@omlaw.com 6 Attorneys for Plaintiff 7 8 IN THE SUPERIOR COURT OF THE STATE OF ARIZONA 9 IN AND FOR THE COUNTY OF MARICOPA 10 RASEAN CLAYTON, 11 Plaintiff, 12 vs. 13 KANYE WEST, et al., 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Defendants. Case No. CV2020-010553 REPLY IN SUPPORT OF APPLICATION FOR INJUNCTION (Assigned to the Honorable Scott McCoy) 1 Although Defendants string various and sometimes contradictory arguments 2 together to confuse the issues here, there is no dispute that Kanye West and his 3 putative presidential electors told petition signers that they were signing petitions for 4 independent candidates, using the process set out in Arizona law for independent 5 candidates, when they were, in fact, not independent candidates. The bottom line of 6 Defendants’ Response is that the law—which allows only persons “who are not 7 registered members” of a recognized political party to use § 16-341’s nomination 8 petition procedures—should not apply to them. West is wrong, the law is clear, and 9 the Court should forbid West and his putative electors from appearing on the ballot. 10 11 12 West’s various arguments to escape § 16-341’s text are flawed for several reasons explained below, but two stick out: First, West now contends (at 7, 9-10) that his putative electors are eligible 13 under § 16-341 because, on August 31 and September 1, they re-registered as having 14 “no party preference.” See Opp. Exs. B-L. The legislature anticipated and prohibits 15 this shell game: “A candidate for partisan public office shall be continuously 16 registered with the political party of which the person desires to be a candidate 17 beginning no later than the date of the first petition signatures on the candidate’s 18 petition through the date of the general election at which the person is a candidate.” 19 A.R.S. § 16-311(A). The first petitions were signed before August 31. West’s 20 electors’ late registration does not defeat Plaintiff’s claims. 21 Second, West contends (at 11-12) that, if applied to West and his electors as 22 written, § 16-341 imposes an unconstitutional burden. But, in a case that is directly 23 on point, the United States Supreme Court rejected West’s argument. See Storer v. 24 Brown, 415 U.S. 724 (1974). In Storer, the Court had “no hesitation” upholding a 25 substantively identical (though much more restrictive) ballot-access “requirement that 26 the independent candidate not have been affiliated with a political party for a year 27 before the primary.” Id. at 732-33. The restriction serves a “compelling” state 28 interest and “outweigh[s] the interest the candidate and his supporters may have in 1 1 making a late rather than an early decision to seek an independent ballot status.” Id. 2 at 736. West’s constitutional arguments fail. 3 I. 4 5 6 The putative electors are not qualified to be on the ballot. A. The putative elector candidates are not qualified to be nominated via nomination petition under § 16-341. As explained in the Application, 10 of 11 of West’s candidates for the office of 7 presidential elector cannot be nominated via nomination petition under § 16-341 8 because they are not candidates who are “not registered members” of a recognized 9 political party. Section 16-341(A) states who may use the procedures in that section, 10 and West’s putative electors do not qualify. West argues that even if unqualified 11 when the petitions were being gathered, the electors are qualified now because, two 12 days ago, they “reregistered as independents” (at 7, 9-10). This argument fails. 13 The putative electors’ post-lawsuit re-registration may change their registration 14 going forward but it does not qualify them retroactively to seek nomination signatures 15 as independents when they were not independents. The law requires candidates 16 gathering petitions to maintain their registration from the first petition signature 17 through the election: 18 20 A candidate for partisan public office shall be continuously registered with the political party of which the person desires to be a candidate beginning no later than the date of the first petition signature on the candidate’s petition through the date of the general election at which the person is a candidate. 21 A.R.S. § 16-311(A) (emphasis added). Under this provision, the putative electors 22 have disqualified themselves. 19 23 First, most of the putative electors (10/11) were registered as Republican on 24 “the date of the first petition signature.” They changed two or three days ago, after 25 this lawsuit was filed and after most of the signatures were gathered. 26 Second, the office of presidential elector is unquestionably a “partisan public 27 office.” The petitions West circulated told petition-signers they were signing to 28 “nominate” the eleven individuals “as candidates for the office of Presidential 2 1 Elector.” See Compl. Ex. B; Reply Ex. A. See also A.R.S. § 16-311(E) (listing 2 “office of presidential elector” along with other public offices); A.R.S. § 16-341(C), 3 (G), (J) (same). Indeed, on the general ballot, Arizona law requires this office to be 4 the very first one listed in the “Partisan Ballot” section of the ballot: “Partisan 5 Ballot . . . At the head of each column shall be printed in the following order the 6 names of candidates for: 1. Presidential electors . . . .” A.R.S. § 16-502(B) 7 (emphasis added). 8 Accordingly, the putative electors were not qualified under § 16-341(A) to 9 circulate nomination petitions when their petitions were first signed and § 16-311(A) 10 prevents their litigation-driven re-registration from changing that retroactively. This 11 is not “hypertechnical,” (Opp. at 1), it is precisely the kind of gaming the legislature 12 intended to prevent. See 2017 Ariz. Sess. Laws Ch. 161 § 1 (S.B. 1200, 1st Reg. 13 Sess.), Feb. 16, 2017 Sen. Judiciary Comm., at 15:20-26:00, (Rep. Kavanagh: bill 14 intended to correct “gaming” of the system and “prevent people from getting around 15 the law”), available at 16 http://azleg.granicus.com/MediaPlayer.php?view_id=13&clip_id=18787. Such 17 provisions promote the “integrity of the various routes to the ballot,” Storer, 415 U.S. 18 at 733, and “Arizona’s asserted interests in preventing voter confusion, ballot 19 overcrowding, and frivolous candidacies.” Ariz. Libertarian Party v. Hobbs, 925 F.3d 20 1085, 1093 (9th Cir. 2019). 21 22 23 B. The putative electors’ petitions are also invalid because no “statement of interest” has been filed. West concedes that no statement of interest has been filed. Instead, West 24 contends (at 8-9) that the requirement does not apply to candidates for the office of 25 presidential elector because it also does not apply to “Candidates for president or vice 26 president of the United States.” A.R.S. § 16-341(I)(3). 27 28 This argument fights the text: § 16-341(I)(1)-(3) exempts specific offices from the “statement of interest” requirement, including “candidates for president or vice 3 1 president of the United States.” Any other “person who may be a candidate for office 2 pursuant to this section” must file the statement and any petitions signed beforehand 3 “are invalid.” Id. A “candidate for office of presidential elector” is not a “candidate 4 for president.” Although West argues that the two are melded into one for this 5 purpose, if the legislature intended to also exempt the elector candidates, it would 6 have said so. It knew how: Section 16-341 references that office by name eleven 7 times. See A.R.S. § 16-341(C), (G), (J). West also argues (at 8) that his putative electors must be treated the same as 8 9 electors of recognized parties, who do not file statements of interest. But those 10 electors are not “nominated” via nomination petitions through A.R.S. § 16-341; they 11 are appointed by the chairperson of the recognized party’s state committee through 12 A.R.S. § 16-344. By the plain terms of the statute, the requirement to file a statement 13 of interest (which informs possible signers about the person’s candidacy) does not 14 apply to them. See A.R.S. § 16-341(I) (“a person who may be a candidate for office 15 pursuant to this section shall file a statement of interest”). West’s putative electors 16 were required to file that statement. West cites (at 8-9) a Secretary of State publication as evidence that the 17 18 statement is not required because the statement is not included in a list of required 19 documents. The Court should put little weight on this. The quoted portion is from an 20 unofficial “Candidate Guide,” not the Procedures Manual, which is approved by the 21 Governor and the Attorney General. It is only the Manual that has the force of law 22 under A.R.S. § 16-452. See also A.R.S. § 12-910(E) (court decides questions of 23 interpretation “without deference to” agency determinations). 24 II. 25 Kanye West is not eligible under § 16-341. Chapter 3 of Title 16 of the Arizona Revised States is entitled “Nominating 26 Procedures.” As its name indicates, this chapter provides the procedures for political 27 candidates to be nominated for the ballot. The main method is the party primary. See, 28 e.g., A.R.S. § 16-301, -302. Article 5, which is entitled “Nomination Other Than By 4 1 Primary,” provides a limited set of alternative routes: nomination petitions (§ 16-341), 2 delegate conventions (§ 16-342); filling vacancies caused by death, incapacity, or 3 withdrawal of the candidate (§ 16-343); and appointment of presidential electors by the 4 state chairmen of qualified political parties (§ 16-344). 5 Kanye West is seeking to be nominated under § 16-341. This section allows 6 independent or minor party candidates – i.e., candidates who had no primary available to 7 them – to be nominated if they gather enough valid signatures. But West is not an 8 independent candidate. He is a registered Republican. He therefore cannot qualify for 9 the ballot under § 16-341, which is for independent or minor party candidates. 10 West concedes that he is a registered Republican and that he is seeking 11 nomination under § 16-341. These difficult facts cause him to make an argument that is 12 fundamentally inconsistent: he claims to be “ELIGIBLE UNDER A.R.S. 16-341(A),” 13 but also that “the Court cannot apply the requirements of A.R.S. § 16-341(A).” See 14 Opp. 3, 6. He cannot have it both ways. 15 16 A. The location of West’s Republican registration is irrelevant. West claims (at 4) that his registration as a Republican in Wyoming does not 17 matter because he is not a member of the “Arizona Republican Party.” But this 18 interpretation would allow any Republican or Democrat from anywhere in the country 19 (other than Arizona) to be nominated as an Independent under § 16-341. And that is 20 contrary to the statute’s clear meaning and the structure of Arizona’s statutes regulating 21 nomination procedures. 22 Moreover, West sets up an impossible test. Arizona’s voter registration forms do 23 not offer a voter the choice to register as a member of the “Arizona Republican Party.” 24 Instead, the voter registration form allows a voter to register as a “Republican.” See 25 Arizona Voter Registration Form, 26 https://azsos.gov/sites/default/files/2019_az_voter_registration_form.pdf; Compl. Ex. D, 27 E (showing filled-out registration forms). Similarly, West is not registered as a 28 “Wyoming Republican.” Instead, he is registered as a “Republican.” See Compl. Ex. C. 5 1 West concedes (at 4) that Section 16-341 prevents candidates “who had the 2 opportunity to appear on the ballot as representatives of their own parties . . . but did not 3 seek that nomination of their party from circumventing the parties’ nominating process.” 4 West asserts, without any support, that this purpose is limited to Arizona candidates and 5 Arizona parties. But he provides no reason why Arizona has any less interest in 6 preventing circumvention by presidential candidates. West is a Republican. He chose 7 not to seek his parties’ nomination in the presidential preference election. See A.R.S. 8 § 16-241. Having made that choice, he cannot be nominated as an independent. 9 10 B. Republicans (and Democrats) cannot use § 16-341. West next argues (at 5) that the limitation in § 16-341 does not apply to him 11 because the Republican Party is not a recognized party in Arizona. But Arizona law 12 provides several routes for parties to obtain recognition, see A.R.S. § 16-802, -803, -804, 13 and § 16-341’s general reference to recognized parties plainly encompasses parties 14 recognized through any of these routes. See also Browne v. Bayless, 202 Ariz. 405, 407, 15 ¶ 5 (2002) (referring to the category of “recognized political parties” and citing A.R.S. 16 § 16-804, the route by which the Republican Party is recognized). 17 More importantly, West’s argument makes no sense and has been rejected by the 18 Supreme Court. Apparently, West believes that the major parties – the Republicans and 19 Democrats – are not “recognized,” and so the nomination procedures of § 16-341 are 20 available to them, but not to members of minor parties. That is obviously contrary to the 21 purpose of § 16-341 and the structure of the nominating statutes. And it is directly 22 contradicted by the Supreme Court’s statement, regarding § 16-341, that “Republicans, 23 Democrats, Libertarians, and various other qualified party politicians cannot use the 24 nominating procedure other than by primary election. See A.R.S. § 16–341(A) and (B)..” 25 Clifton v. Decillis, 187 Ariz. 112, 115 (1996). 26 27 28 6 1 C. 2 3 West’s statement to the Federal Election Commission that he is running for President as a member of the “Birthday Party” does not change the fact that he is a registered Republican. A “registered” Republican or Democrat cannot be nominated by petition under 4 § 16-341(A). The statutory analysis turns on “registration,” an easily discernible fact – 5 nothing else is relevant. A Republican cannot be nominated by petition merely by 6 telling someone he is really an independent. 7 West points the Court to a filing he submitted to the Federal Election 8 Commission listing his party as “BDY,” which apparently stands for the “Birthday 9 Party.” Opp. Ex. A. But § 16-341 does not care about what West tells the Federal 10 Election Commission, or anyone else, about his party affiliation. It cares only about his 11 registration. And it is an uncontested fact that West is a registered Republican. 12 13 14 D. Section 16-341(A) applies to presidential candidates and West’s contrary claim would defeat his attempt to be nominated under § 341(A). West also argues that § 16-341(A) does not apply to him. But if that were true, 15 then he could not seek the nomination under § 16-341(A). Section 16-341(A) is the 16 gateway to the nomination by petition procedures in the rest of § 16-341. If, as West 17 contends (at 6), “the Court cannot apply the requirements of A.R.S. § 16-341(A) to 18 independent Presidential nominees,” then the Court cannot make the nomination 19 procedures of § 16-341 available to them, either. 20 West does accurately note one problem with the statute. The statute makes 21 nomination by petition available only to a “qualified elector.” Id. Other statutes state 22 that a qualified elector must be an Arizona resident. See A.R.S. §§ 16-101, -121. For 23 most public offices in Arizona, limiting § 16-341 to Arizona residents is not a problem, 24 because only Arizonans may be governor, attorney general, etc. But a non-Arizonan can 25 be president, and it would be problematic to allow presidential candidates from Arizona 26 to be nominated by petition while foreclosing that option to non-residents. 27 28 The right solution is not to use the statutory definition of “qualified electors” when interpreting § 16-341(A) in the context of presidential candidates. This does the 7 1 least violence to the statute, because the term “qualified elector” is not central to § 16- 2 341. And it allows the statute to apply to presidential candidates, consistent with the rest 3 of the statute. See A.R.S. § 16-341(G) (referring twice to “the presidential candidate”). 4 By contrast, West proffers an interpretation that creates more problems than it 5 solves. He argues that subsection A should not apply to presidential candidates. But 6 there is no statutory basis for this argument, which is contrary to subsection G’s 7 reference to “presidential candidates” and the decisions from the Arizona Supreme Court 8 and the Ninth Circuit applying the statute in the context of presidential candidates. See 9 Nader v. Brewer, 531 F.3d 1028 (9th Cir. 2008); Browne v. Bayless, 202 Ariz. 405 10 (2002). West also suggests that applying § 16-341 to him would result in an 11 impermissible extra-territorial effect, but there is nothing extra-territorial about Arizona 12 regulating the methods for candidates to appear on its ballots. Ultimately, the Court does not need to resolve this statutory conundrum. If 13 14 subsection A does not apply, then it does not permit West to “be nominated as a 15 candidate for public office otherwise than by primary election.” A.R.S. § 16-341(A). 16 Thus, the Court need only recognize that West’s argument cannot save his candidacy. 1 17 III. 18 The United States Supreme Court has already rejected West’s constitutional arguments. West makes two interrelated constitutional claims that, if applied to West, 19 20 § 16-341 impermissibly burdens constitutional rights by imposing too high a hurdle 21 for independent candidates to access the ballot. These arguments are meritless and 22 are foreclosed by longstanding, on-point and binding precedent. To decide constitutional challenges to ballot-access restrictions, courts apply 23 24 the Anderson-Burdick balancing framework. See Ariz. Libertarian Party, 925 F.3d at 25 1 26 27 28 West cannot dispute that he is a candidate – that is how he has repeatedly represented himself to Arizona’s elections officials. See Reply Ex. B (9/2/2020 letter describing West “as a candidate for President of the United States”); Reply Ex. C at 1 (8/18/2020 letter signed as “Kanye West[,] Candidate for President of the United States”), 2 (West’s Nomination Paper, stating he is a “candidate for the office of President”). 8 1 1085 (discussing Anderson v. Celebrezze, 460 U.S. 780 (1983) and Burdick v. 2 Takushi, 504 U.S. 428 (1992)). The framework is a “‘sliding scale’—the more severe 3 the burden imposed, the more exacting our scrutiny; the less severe, the more relaxed 4 our scrutiny.” Ariz. Libertarian Party, 925 F.3d at 1085 (citation omitted). 5 Aside from generally describing some of this caselaw, West does not apply the 6 framework to the ballot-access regulation at issue here or explain why the state’s 7 interest is outweighed by West’s interest in a last-minute access to the ballot. Any 8 such effort would be futile because the Supreme Court foreclosed the claims in Storer 9 v. Brown, 415 U.S. 724. Although West does not cite the case, it is decisive. 10 In Storer, the Court held that a state could impose a “requirement that the 11 independent candidate not have been affiliated with a political party for a year before 12 the primary.” 415 U.S. at 733. The state had a compelling interest in “maintaining 13 the integrity of the various routes to the ballot,” and “involves no discrimination 14 against independents.” Id. The law helped prevent “independent candidacies 15 prompted by short-range political goals, pique or personal quarrel,” and imposed a 16 “substantial barrier to a party fielding an ‘independent’ candidate to capture and bleed 17 off votes in the general election that might well go to another party.” Id. at 735. 18 These compelling state interests easily outweighed the “interest the candidate and his 19 supporters may have in making a late rather than an early decision to seek 20 independent ballot status.” Id. The state did not have to invite late-stage chaos 21 “merely in the interest of particular candidates and their supporters having 22 instantaneous access to the ballot.” Id. 23 West cannot overcome Storer. The burden on the candidate there (a one-year 24 restriction on switching registration) is substantially more restrictive than Arizona 25 imposes. Potential candidates can change party all they want, so long as they change 26 their registration by the date they begin collecting petition signatures and leave it 27 alone until election day. A.R.S. § 16-311(A). And Arizona’s interest is no less 28 significant than the one that the Court found “compelling” in Storer. See Ariz. 9 1 Libertarian Party, 925 F.3d at 1093 (“Arizona’s asserted interests in preventing voter 2 confusion, ballot overcrowding, and frivolous candidacies are important interests” and 3 justified burdens on third-party ballot access). West’s “interest” in “having 4 instantaneous access to the ballot” does not come close to matching the state’s interest 5 in the integrity and stability of its political system. See Storer, 415 U.S. at 736. 6 There is also no question that Storer remains good law. It is a precursor to and 7 foundation for the Anderson-Burdick framework. See, e.g., Burdick, 504 U.S. at 433, 8 437 (quoting approvingly from Storer); Anderson, 460 U.S. at 788, 789, 802-03 9 (same, including that “[o]ur evaluation of [the state’s] interest is guided by” Storer 10 and another case). Modern cases frequently consult Storer in deciding ballot-access 11 challengers. See Ariz. Libertarian Party, 925 F.3d at 1091-93. 12 Campbell v. Hull, 73 F. Supp. 2d 1081 (D. Ariz. 1999), does not help West. In 13 that case, the court applied the Anderson-Burdick framework to assess aspects of a 14 prior version of § 16-341. After examining the burdens imposed, the court struck 15 down “the requirement that signors of nomination petitions not be members of 16 qualified political parties.” Id. at 1093. The Court noted that no other state imposed 17 such a restriction, and that numerous cases had held that voters could not be forced to 18 “change their party affiliation in order to nominate independents.” Id. at 1090, 1091. 19 The restriction imposed “severe” burdens: it dramatically shrunk the pool of voters 20 who could sign nomination petitions (excluding 86% of the electorate) and made it 21 substantially more difficult and costly to obtain signatures. 22 West’s argument is nothing like Campbell. There is not extensive case law 23 striking down similar restrictions (to the contrary, there is Storer and other cases 24 affirming limits on ballot access, such as Arizona Libertarian Party), and there is no 25 limit on the pool of the electorate who could sign a valid petition. The only burden is 26 a very modest one: change your registration before seeking out petition signatures. 27 The fact that the putative electors managed to re-register within two days of this 28 lawsuit shows how modest this burden is. 10 Finally, West argues (at 12-13) that § 16-341 may not constitutionally force the 1 2 putative electors to change their registration in order to support West. This 3 transparent effort to cram West’s case into the Campbell v. Hull box is not persuasive. 4 The restriction at issue here is a modest limit on becoming a candidate for office 5 printed on the ballot (as in Storer), not a voter supporting a candidate (as in 6 Campbell). Of course, states impose all kinds of limits on a candidate for the office of 7 presidential electors that would not be imposed on a regular voter. See A.R.S. § 16- 8 212(B)-(C) (requiring presidential electors to cast electoral college votes for 9 candidates with highest number of votes, and removing elector from office if she fails 10 to do so); Chiafolo v. Washington, 140 S. Ct. 2316, 2324 (2020) (state may force 11 presidential elector to vote in electoral college as required, “on pain of penalty”). 12 IV. 13 West’s miscellaneous arguments fail. West also argues that the timing of this lawsuit deprived him of due process, 14 complaining that Plaintiff should have sued him earlier. But he cites no case rejecting 15 an election challenge on this theory, and it is his last-minute attempt to get on the 16 ballot that prompted this emergency challenge. West registered his first circulator on 17 August 24, 2020, just 15 days before the ballot printing deadlines. Plaintiff responded 18 promptly, suing on August 31, a week after that first registration. Thus if laches 19 applies, it applies to his belated challenge to the constitutionality of A.R.S. § 16-341, 20 not Plaintiff’s timely defense of Arizona’s election laws. 21 Finally, West complains that Plaintiff named each county board of supervisors 22 as a whole, rather than the individual members. But the statute says to name the 23 “board of supervisors,” not individual members. A.R.S. § 16-351(C). 24 25 CONCLUSION The Court should grant the application for injunctive relief and (1) enjoin the 26 Secretary of State from accepting West’s signatures, and (2) enjoin the county 27 defendants from including West and his putative electors on the ballot. 28 11 1 DATED this 3rd day of September, 2020. 2 OSBORN MALEDON, P.A. 3 4 7 /s/ Joseph N. Roth Mary R. O’Grady Joseph N. Roth Joshua D. Bendor 2929 North Central Ave., Suite 2100 Phoenix, Arizona 85012-2793 8 Attorneys for Plaintiff 5 6 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 This document was electronically filed and copy served via eFiling system this 3rd day of September, 2020 on: The Honorable Scott McCoy Maricopa County Superior Court Timothy LaSota tim@timlasota.com Timothy J. Berg Keith Miller tberg@fclaw.com kmiller@fclaw.com Attorneys for West, Anglin, Whitehead, Quale, Wallace-Sassarini, Gilbert, Tuck, Vrabel and Renberg Kara Karlson Kara.Karlson@azag.gov Dustin Romney Dustin.Romney@azag.gov Bo Dul bdul@azsos.gov Attorneys for KATIE HOBBS, in her official capacity as the Secretary of State of Arizona Joe Young JYoung@apachelaw.net 26 27 Attorney for APACHE COUNTY Defendants 28 12 1 2 Brit Hanson BHanson@cochise.az.gov 3 C. Roberts CRoberts@cochise.az.gov 4 Attorney for COCHISE COUNTY Defendants 5 6 7 8 Rose Winkeler rwinkeler@coconino.az.gov M. Byrnes mbyrnes@coconino.az.gov Attorney for COCONINO COUNTY Defendants 9 10 Jeff Dalton jdalton@gilacountyaz.gov 11 12 13 14 15 Attorney for GILA COUNTY Defendants Kenny Angle kanglegca@gmail.com S. Bennett sbennett@graham.az.gov 16 Attorney for GRAHAM COUNTY Defendants 17 Jeremy Ford jford@greenlee.az.gov 18 19 Attorney for GREENLEE COUNTY Defendants 20 21 Ryan Dooley rdooley@lapazcountyaz.org 22 Attorney for LA PAZ COUNTY Defendants 23 24 25 26 Joseph E. La Rue Andrea Cummings laruej@mcao.maricopa.gov cumminga@mcao.maricopa.gov Attorney for MARICOPA COUNTY Defendants 27 28 13 1 2 Ryan Esplin Ryan.Esplin@mohavecounty.us 3 Attorney for MOHAVE COUNTY Defendants 4 5 Jason Moore Jason.Moore@navajocountyaz.gov 6 Attorney for NAVAJO COUNTY Defendants 7 8 Daniel Jurkowitz Daniel.Jurkowitz@pcao.pima.gov 9 Attorney for PIMA COUNTY Defendants 10 11 12 Craig Cameron craig.cameron@pinal.gov Chris Keller Chris.Keller@pinal.gov 15 Scott Johnson scott.m.johnson@pinal.gov Allen Quist allen.quist@pinal.gov 16 Attorney for PINAL COUNTY Defendants 17 Kimberly J. Hunley khunley@santacruzcountyaz.gov G. Silva gsilva@santacruzcountyaz.gov 13 14 18 19 20 Attorney for SANTA CRUZ COUNTY Defendants 21 22 23 24 25 Matthew Black Matthew.Black@yavapai.us ycao@yavapai.us Thomas Stoxen Thomas.Stoxen@yavapai.us Attorney for YAVAPAI COUNTY Defendants 26 27 28 14 1 2 3 William Kerekes Bill.Kerekes@yumacountyaz.gov Attorney for YUMA COUNTY Defendants 4 5 /s/ Brenda Wendt 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 15