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					 1 Paul F. Eckstein (#001822)
   Michael S. Mandell (#019193)
 2 BROWN & BAIN, P.A.
   2901 North Central Avenue
 3 Post Office Box 400

 4 Phoenix, Arizona 85001-0400
   (602) 351-8000
 5
   John P. Frank (#000740)
 6 Richard A. Halloran (#013858)
   Joshua Grabel (#018373)
 7 LEWIS AND ROCA, LLP
   40 North Central Avenue
 8 Phoenix, Arizona 85004-5529
   (602) 262-5311
 9
   Aaron Kizer (#004577)
10
   LAW OFFICES OF AARON KIZER, PLC
11 411 North Central Avenue
   Suite 520
12 Phoenix, Arizona 85004-2133
   (602) 253-2523
13
     Attorneys for Plaintiffs
14

15                              ARIZONA SUPERIOR COURT
16                                 MARICOPA COUNTY
17
     ARIZONA MINORITY COALITION FOR
18   FAIR REDISTRICTING, an unincorporated
     association; STATE SENATOR RAMON             No. ______________________
19   VALADEZ; STATE SENATOR PETER RIOS;
     STATE REPRESENTATIVE CARLOS
20   AVELAR; STATE REPRESENTATIVE                            COMPLAINT
     JAMES SEDILLO; MARICOPA COUNTY
21   SUPERVISOR MARY ROSE GARRIDO
     WILCOX; ESTHER LUMM; VIRGINIA                   (Special Action; Mandamus;
22   RIVERA; LOS ABOGADOS, an Arizona             Declaratory Relief; Injunctive Relief)
     corporation,
23
                                   Plaintiffs,
24                       v.
25   ARIZONA INDEPENDENT REDISTRICTING
     COMMISSION, a state agency; STEVE LYNN,
26   in his official capacity as Chairman and a


                                                                   3a0a4feb-8c57-41f4-adfe-4708d77bafbb.doc
 1   Commissioner of the Independent Redistricting
     Commission; ANDREA MINKOFF in her
 2   official capacity as Vice-Chairman and a
     Commissioner of the Independent Redistricting
 3   Commission; DANIEL ELDER in his official
     capacity as a Commissioner of the Independent
 4   Redistricting Commission; JOSHUA HALL in
     his official capacity as a Commissioner of the
 5   Independent Redistricting Commission; JAMES
     HUNTWORK in his official capacity as a
 6   Commissioner of the Independent Redistricting
     Commission; BETSEY BAYLESS, in her
 7   official capacity as Secretary of State for the
     State of Arizona,
 8
                                       Defendants.
 9

10          For their Complaint, the Plaintiffs hereby allege as follows:
11          1.     Plaintiff Arizona Minority Coalition for Fair Redistricting (“the Coalition”) is
12   an organization of individuals from across the state of Arizona. They share the goal of
13   creating the maximum number of state legislative districts that (1) are politically
14   competitive, and (2) protect the voting rights of minorities.
15          2.     Plaintiff Ramon Valadez is a qualified elector in Arizona, and a State Senator
16   representing current legislative district 10 in Tucson, Arizona.
17          3.     Plaintiff Peter Rios is a qualified elector in Arizona and a State Senator
18   representing current legislative district 7, which encompasses parts of Maricopa, Pinal and
19   Gila Counties.
20          4.     Plaintiff Carlos Avelar is a qualified elector in Arizona and a State
21   Representative representing current legislative district 23 in Phoenix, Arizona.
22          5.     Plaintiff James Sedillo is a qualified elector in Arizona, and a State
23   Representative    representing current legislative district 2, which encompasses parts of
24   Coconino, Navajo, Yavapai, and Mohave Counties.
25          6.     Plaintiff Mary Rose Garrido Wilcox is a qualified elector in Arizona, and a
26   County Supervisor in Maricopa County.

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 1          7.     Plaintiff Esther Lumm is a qualified elector in Arizona,, a resident of Maricopa
 2   County and she represents the Arizona Hispanic Community Forum.
 3          8.     Plaintiff Virginia Rivera is a qualified elector in Arizona, a resident of Pinal
 4   County and she represents the Pinal County Hispanic Community Forum.
 5          9.     Plaintiff Los Abogados is an Arizona corporation representing the interests of
 6   Hispanic attorneys, judges, law professors, law students and the general Hispanic community
 7   throughout Arizona.
 8          10.Defendant Arizona Independent Redistricting Commission is a public body of this                           Formatted: Bullets and Numbering


 9   State created by the passage of Proposition 106 in the 2000 general election. Defendants
10   Steve Lynn, Andrea Minkoff, Joshua Hall, Daniel Elder and James Huntwork are public
11   officers of this State and are named in their official capacities as Commissioners of the
12   Independent Redistricting Commission.          The Commissioners are hereinafter collectively
13   referred to as (“the Commission”). The office of the Commission is located at 1400 West
14   Washington, Suite B10, in Maricopa County, Arizona.
15          10.                                                                                                          Formatted: Bullets and Numbering


16          11.    Defendant Betsey Bayless is the Arizona Secretary of State (“the Secretary of
17   State”), a public officer of this State and is named as Defendant in this action in her official
18   capacity. The office of the Secretary of State is located at 1700 West Washington, in
19   Maricopa County, Arizona. The Secretary of State is the public officer responsible for the
20   conduct of legislative elections in Arizona.
21          12.    This Court has jurisdiction over this action pursuant to Article VI, § 14 of the
22   Arizona Constitution and A.R.S. § 12-123.
23                                    GENERAL ALLEGATIONS

24          13.    In November 2000, Arizona voters approved State Proposition 106,
25   establishing the Independent Redistricting Commission.           A copy of the text of the
26   Proposition is attached hereto as Exhibit A..

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 1          14.    Arizona voters were informed by a number of sources that the passage of
 2   Proposition 106 would stop political gerrymandering, create a fairer process of redistricting
 3   and significantly increase political party competitiveness among Arizona’s legislative
 4   districts. All of the statements advocating for Proposition 106 cited these factors as the
 5   reason for their support for the Proposition.
 6          15.    As a number of Republican public officials stated at the time: “By transferring
 7   redistricting responsibility from self-interested politicians to an independent citizen’s panel,
 8   [Proposition 106] will generate more competition, more accountability and better
 9   government for all Arizonans.”
10          16.    As a result of the overwhelming support for Proposition 106, Article IV, Part 2,
11   Section 1 was added to the Arizona Constitution (“the Competitive Redistricting Clause”).
12   The Competitive Redistricting Clause required the creation of the Commission and required
13   that the Commission establish new Arizona legislative and congressional district boundaries
14   for elections occurring from November 2002 through 2010 based on the principleals outlined
15   in the Competitive Redistricting Clause.
16          17.    In establishing these boundaries, the Competitive Redistricting Clause requires
17   the Commission to initially draw proposed districts and equal population “in a grid like
18   pattern across the state.”    ARIZ. CONST. art. IV, part 2, §1(14).           It then requires the
19   Commission to adjust the initial grid boundaries to ensure that:
20                 A.     Districts shall comply with the United States
21                        Constitution and the United States voting rights act;

22                 B.     Congressional districts shall have equal population to the
                          extent practicable, and state legislative districts shall have
23                        equal population to the extent practicable;
24                 C.     Districts shall be geographically compact and contiguous
                          to the extent practicable;
25
                   D.     District boundaries shall respect communities of interest
26                        to the extent practicable;

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 1                  E.        To the extent practicable, district lines shall use visible
                              geographic features, city, town and county boundaries,
 2                            and undivided census tracts;
 3                  F.        To the extent practicable, competitive districts should be
                              favored where to do so would create no significant
 4                            detriment to the other goals.
 5   Id. (emphasis added).
 6          18.     The Commission adopted the initial grid maps, based solely on equal
 7   population determinations, on June 7, 2001.
 8          19.     Over the next two months, the Commission held several public meetings in
 9   which the public was invited to comment on the redistricting efforts of the Commission
10   throughout the state of Arizona.
11          20.     After receiving public comment on the initial grid map, the Commission held
12   several meetings from August 7, 2001 through August 17, 2001, to make adjustments to the
13   legislative districts.
14          21.     The Commission adopted a draft final map on August 17, 2001.
15          22.     Between August 7 and August 17, the Commission made substantial changes
16   to the existing legislative districts from the initial grid map. During these meetings, the
17   Commission had very limited data regarding the competitiveness of the potential districts.
18   Upon information and belief, the only data the Commission had was the political party
19   registration in certain districts, even though the Competitive Redistricting Clause specifically
20   required it to consider increasing competitiveness statewide.
21          23.     Further, evenEven though the Commission had the political party registration
22   numbers available, the majority of the Commission rejected a proposal to direct the
23   Commission’s redistricting consultants to consider minimizing party registration differences
24   in adjusting district boundaries to increase competitiveness. While this would not have
25   guaranteed an increase in the competitiveness of the proposed legislative districts, it would
26   have at least allowed the Commission’s redistricting consultants to try and adjust the district

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 1   boundaries to increase the likelihood of creating more competitive districts without
 2   significantly impacting the other redistricting goals. Instead, theThe Commission decided
 3   not to take this simple step to fulfill its constitutionally required duties and instead created
 4   the draftdistricts in its final draft map without any consideration of competitiveness.
 5          24.    The Commission continued to disregard the mandate of the Competitive
 6   Redistricting Clause and Arizona’s voters to increase the competitiveness of Arizona’s
 7   legislative districts throughout the redistricting process. For example, when the Commission
 8   adjusted the district boundaries based on considerations for the Voting Rights Act of 1965 or
 9   “Communities of Interest,” it never considered the effect that those changes might have on
10   the competitiveness of each district. In the end, the Commission failed to comply with the
11   constitutional mandate to create competitive legislative districts where it was possible to do
12   so. while those changes were being made. Moreover, the Commission failed to undertake
13   even a cursory analysis regarding the competitiveness of the districts. For example, when
14   the Commission adjusted the district boundaries based on considerations for the Voting
15   Rights Act or “Communities of Interest,” it never considered the effect that the changes
16   might have on the competitiveness of each district while those changes were being made.
17   Moreover, the Commission failed to give even a cursory analysis to considerations regarding                         Formatted


18   competitiveness before adopting significant boundary adjustments or accepting entirely new
19   maps of districts.
20          25.    The Commission approved its final legislative map on October 14, 2001,
21   certified it to the Secretary of State on November 3, 2001, and submitted it to the Department
22   of Justice as required by the Voting Rights Act of 1965 on January 24, 2002.
23          26.    As a result of the Commission’s failure to consider competitiveness in
24   preparing the legislative districts, it ended up decreasing the number of competitive districts
25   within the state. As the legislative districts currently exist, nine (9) of them qualify as
26   competitive for purposes of electing a candidate of either major political party. Under the

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 1   Commission’s proposed plan, only six (6) are competitive. See cChart outliningcomparing
 2   the competitiveness of each district in the Commission’s Adopted Map, the Coalition II
 3   Revised Map and the existing Legislative Districts attached as Exhibit A and incorporated
 4   herein. In other words, even though it was required by the Competitive Redistricting Clause
 5   to increase competitiveness in legislative districts, the Commission decreased the number of
 6   competitive legislative districts statewide by thirty-three percent (33%).
 7          27.    Further, evenEven when alternative legislative redistricting plans were
 8   presented to the Commission that considered all of the constitutional criteria set forth in
 9   Proposition 106, including competitiveness, the Commission did not give these plans serious
10   consideration. For example, the legislative redistricting plans submitted by the Coalition
11   (“the Coalition II plan”) accomplishes all of the goals approved by the Arizona voters in
12   November 2000 and codified in the Competitive Redistricting Clause better than the
13   Commission’s plan does but was not given serious consideration..                See Exhibit B (the
14   Coalition II plan) attached hereto and incorporated herein.
15          28.    Further, afterAfter slight modifications, the Coalition II Revised plan
16   (“Coalition II Revised plan”) not only retains the number of competitive districts that exist in
17   Arizona’s current legislative districts, it also significantly lowers the deviation in district
18   population statewide in comparison to the Commission’s plan without creating a significant
19   detriment to the other factors outlinedgoals set forth in the Arizona Constitution. SeeA
20   compact computer disk containing the details of the Coalition II Revised plan is included and
21   incorporated herein as Exhibit C B and will be filed with the Court and served on the parties
22   but not filed with the clerk of the court(the Coalition II Revised plan).
23          29.    The Commission’s failure to consider the Coalition II plan was done despite
24   the fact that evidence provided to the Commission by its own expert, Dr. Michael P.
25   McDonald, showed that the Coalition II plan was far more competitive than the adopted
26

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 1   plan.   Dr. McDonald’s evidence was based on his use of a sophisticatedsophisticated
 2   competitive analysis software entitled “Judge It.”
 3           30.   A comparison of the Coalition II revisedRevised plan with the plan adopted by
 4   the Commission clearly demonstrates that the Coalition II revisedRevised plan not only
 5   creates more competitive legislative districts, but it also protects the voting rights of
 6   minorities and complies with all of the requirements of the Voting Rights Act of 1965. For
 7   example, both plans create nine majority-minority districts, seven of which contain majority
 8   voting age minority populations. In addition, the Coalition II revisedRevised plan creates a
 9   total of ten districts with an overall minority voting age population of more than forty
10   percent (40%) of the district’s population while the Commission’s plan creates only nine
11   districts with similar voting age population percentages.
12           31.   The Coalition II plan considers all of the redistricting goals set forth in the
13   Arizona Constitution. By failing to adopt the Coalition II plan or a similar plan that at least
14   maintains the current nine competitive legislative districts and comply with all of the other
15   constitutional criteria, the Commission failed to perform its constitutional duties perform its
16   constitutional duties.
17           32.   Had the Commission done the constitutionally required analysis regarding the
18   competitiveness of the legislative map, it could have easily created the districts outlined in
19   the Coalition II revisedRevised plan, which either meet or beat the Commission’s map when
20   considering all of the criteria set forth in the Competitive Redistricting Clause.
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 1                                            COUNT ONE
 2                                    (Mandamus, Special Action)
 3          33.    The Plaintiffs incorporate the allegations set forth in the foregoing paragraphs
 4   of this Complaint as if fully set forth herein.
 5          34.    Pursuant to the Competitive Redistricting Clause, the Commission was
 6   required to consider competitiveness in drafting the boundaries for legislative districts.
 7          35.    The Commission failed to consider competitiveness in drafting the boundaries
 8   for legislative districts, despite the fact that it could do so without causing significant
 9   detriment to the other goals set forth in the Competitive Redistricting Clause, as it was
10   required to do by the Arizona Constitution.
11          36.    As a result of the Commission’s failure to properly consider competitiveness,
12   in drafting the boundaries, Arizona’s legislative map will see a decrease from its current
13   composition of nine (9) competitive districts to six (6) competitive districts if the
14   Commission’s map is approved. Plaintiffs have no plain, adequate and speedy remedy at law
15   to compelforce the Commission to comply with the Arizona Constitution.                     Therefore, the
16   Plaintiffs request this Court to issue a Writ of Mandamus pursuant to A.R.S. § 12-2021 to
17   require the Commission fulfill its constitutionally mandated duties.
18          37.    Further, theThe Plaintiffs request that they be awarded attorneys fees pursuant
19   to A.R.S. § 12-2030.
20                                            COUNT TWO
21                                         (Declaratory Relief)
22          38.    Plaintiffs incorporate the allegations set forth in the foregoing paragraphs of
23   this Complaint as if fully set forth herein.
24          39.    Plaintiffs request a declaration that the Commission’s legislative map is in
25   violation of its the Commission’s constitutionally required duties.
26

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 1          40.      Plaintiffs further request a declaration that the Commission’s legislative map
 2   cannot be certified by the Secretary of State as valid for any elections to the Arizona
 3   Legislature.
 4          41.      Plaintiffs further request a declaration that the Commission’s legislative map
 5   cannot be adopted or enacted for any legislative elections beginning in 2002 because it does
 6   not comply with the Competitive Redistricting Clause.
 7                                           COUNT THREE
 8                                           (Injunctive Relief)

 9          42.      Plaintiffs incorporate the foregoing allegations of this Complaint as if fully set
10   forth herein.
11          43.      The Commission has failed to fulfill its duty to increase the competitiveness of
12   Arizona’s legislative districts as required by the Competitive Redistricting Clause.
13          44.      Plaintiffs request an injunction requiring the Commission to adopt the
14   Coalition II Revised plan as the appropriate map for Arizona’s legislative districts.
15          45.      In the alternative, Plaintiffs request an injunction requiring the Commission to
16   adopt a legislative map that gives appropriate consideration to competitiveness and, at a
17   minimum, maintains the status quo with regard to competitive districts.
18          46.      Plaintiffs request an injunction prohibiting the Secretary of State from
19   accepting and approving the Commission’s legislative map and conducting any legislative
20   elections pursuant to that map.
21

22          WHEREFORE, Plaintiffs pray for judgment as follows:
23          A.       An order of Mandamus compelling the Commission to adopt a map that
24   conforms with the requirements of the Competitive Redistricting Clause of the Arizona
25   Constitution and increases the competitiveness of Arizona’s legislative districts;
26

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 1          B.     A declaration that:    (1) the Commission failed to appropriately consider
 2   competitiveness, as required by the Competitive Redistricting Clause, in creating its
 3   proposed legislative districts; (2) the Commission’s legislative map does not comply with the
 4   Competitive Redistricting Clause’s mandate that competitiveness be considered in creating
 5   Arizona’s legislative districts; and (3) that the Commission should either adopt the Coalition
 6   II Revised plan or fashion a new map after considering all of the factors set forth in the
 7   Arizona Constitution;
 8          C.     Granting a preliminary and permanent injunction enjoining the Arizona
 9   Secretary of State from implementing the legislative district map created and certified by the
10   Commission for use in the 2002 through 2010 election cycles;
11          D.     Issuing an injunction that orders the Commission to either certify the Coalition
12   II Revised plan or, immediately provide another, more competitive plan, that can be certified
13   to the Secretary of State as the legislative district map to be used in the 2002 through 2010
14   election cycles;
15          E.     Awarding Plaintiffs’ attorneys’ fees incurred in this action under A.R.S.
16   12-2030;
17          F.     Awarding Plaintiffs such other and further relief as may be appropriate.
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 1   Dated: March 6, 2002.
 2                              LAW OFFICES OF AARON KIZER, LLP
                                   Aaron Kizer
 3
                                LEWIS AND ROCA, LLP
 4                                 John P. Frank
                                   Richard A. Halloran
 5                                 Joshua Grabel
 6                              and
 7                              BROWN & BAIN, P.A.
 8

 9                              By _______________________________
                                    Paul F. Eckstein
10                                  Michael S. Mandell
11                              Attorneys for Plaintiffs
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 1                                         VERIFICATION
 2   STATE OF ARIZONA            )
                                 ) ss.
 3   County of Maricopa          )
 4           Supervisor Mary Rose Garrido Wilcox, one of the Plaintiffs in the foregoing action,
 5
     being first duly sworn, deposes and says that she has read the foregoing Complaint and she
 6
     knows the contents therein to be true to the best of her knowledge, except as to those matters
 7

 8   therein stated upon information and belief, and as to such matters, she believes them to be

 9   true.
10

11
                                               ____________________________________
12                                                   Mary Rose Garrido Wilcox
13
                                                     Maricopa County Supervisor

14           SUBSCRIBED AND SWORN to before me this ______ day of March, 2002.
15

16                                             ____________________________________
                                                          Notary Public
17
     My commission expires:
18

19   ___________________
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 1                                         VERIFICATION
 2   STATE OF ARIZONA            )
                                 ) ss.
 3   County of Maricopa          )
 4          Senator Peter Rios, one of the Plaintiffs in the foregoing action, being first duly
 5   sworn, deposes and says that he has read the foregoing Complaint and he knows the contents
 6
     therein to be true to the best of his knowledge, except as to those matters therein stated upon
 7
     information and belief, and as to such matters, he believes them to be true.
 8

 9

10                                              ____________________________________
11                                                    Peter Rios
                                                      Arizona State Senator
12
            SUBSCRIBED AND SWORN to before me this ______ day of March, 2002.
13

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                                                ____________________________________
15                                                         Notary Public
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     My commission expires:
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     ___________________
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 1                                         VERIFICATION
 2   STATE OF ARIZONA            )
                                 ) ss.
 3   County of Maricopa          )
 4          Senator Ramon Valadez, one of the Plaintiffs in the foregoing action, being first duly
 5   sworn, deposes and says that he has read the foregoing Complaint and he knows the contents
 6
     therein to be true to the best of his knowledge, except as to those matters therein stated upon
 7
     information and belief, and as to such matters, he believes them to be true.
 8

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10                                             ____________________________________
11                                                   Ramon Valadez
                                                     Arizona State Senator
12
            SUBSCRIBED AND SWORN to before me this ______ day of March, 2002.
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                                               ____________________________________
15                                                        Notary Public
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     My commission expires:
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     ___________________
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 1                                         VERIFICATION
 2   STATE OF ARIZONA            )
                                 ) ss.
 3   County of Maricopa          )
 4          Representative Carlos Avelar, one of the Plaintiffs in the foregoing action, being first
 5   duly sworn, deposes and says that he has read the foregoing Complaint and he knows the
 6
     contents therein to be true to the best of his knowledge, except as to those matters therein
 7
     stated upon information and belief, and as to such matters, he believes them to be true.
 8

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10                                             ____________________________________
11                                                   Carlos Avelar
                                                     Arizona State Representative
12
            SUBSCRIBED AND SWORN to before me this ______ day of March, 2002.
13

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                                               ____________________________________
15                                                        Notary Public
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     My commission expires:
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     ___________________
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 1                                         VERIFICATION
 2   STATE OF ARIZONA            )
                                 ) ss.
 3   County of Maricopa          )
 4          Representative James Sedillo, one of the Plaintiffs in the foregoing action, being first
 5   duly sworn, deposes and says that he has read the foregoing Complaint and he knows the
 6
     contents therein to be true to the best of his knowledge, except as to those matters therein
 7
     stated upon information and belief, and as to such matters, he believes them to be true.
 8

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10                                             ____________________________________
11                                                   James Sedillo
                                                     Arizona State Representative
12
            SUBSCRIBED AND SWORN to before me this ______ day of March, 2002.
13

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                                               ____________________________________
15                                                        Notary Public
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     My commission expires:
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     ___________________
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 1                                         VERIFICATION
 2   STATE OF ARIZONA            )
                                 ) ss.
 3   County of Maricopa          )
 4          Esther Lumm, one of the Plaintiffs in the foregoing action, being first duly sworn,
 5   deposes and says that she has read the foregoing Complaint and she knows the contents
 6
     therein to be true to the best of her knowledge, except as to those matters therein stated upon
 7
     information and belief, and as to such matters, she believes them to be true.
 8

 9

10                                             ____________________________________
11                                                   Esther Lumm

12          SUBSCRIBED AND SWORN to before me this ______ day of March, 2002.
13

14                                             ____________________________________
                                                          Notary Public
15

16   My commission expires:

17   ___________________
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 1                                         VERIFICATION
 2   STATE OF ARIZONA            )
                                 ) ss.
 3   County of Maricopa          )
 4          Virginia Rivera, one of the Plaintiffs in the foregoing action, being first duly sworn,
 5   deposes and says that she has read the foregoing Complaint and she knows the contents
 6
     therein to be true to the best of her knowledge, except as to those matters therein stated upon
 7
     information and belief, and as to such matters, she believes them to be true.
 8

 9

10                                             ____________________________________
11                                                   Virginia Rivera

12          SUBSCRIBED AND SWORN to before me this ______ day of March, 2002.
13

14                                             ____________________________________
                                                          Notary Public
15

16   My commission expires:

17   ___________________
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 1                                         VERIFICATION
 2   STATE OF ARIZONA            )
                                 ) ss.
 3   County of Maricopa          )
 4          Mary Rose Garrido Wilcox, hereby affirms the following:
 5          I am the chairperson of the Arizona Minority Coalition for Fair Redistricting, (“the
 6
     Coalition”) which is the plaintiff in the above referenced action. I have reviewed the
 7
     Complaint; I am authorized to verify the contents thereof on the Coalition’s behalf, and
 8

 9   know the contents stated therein to be true, except as to those matters therein stated upon
10   information and belief, and as to such matters, which I believe to be true.
11

12
                                               ____________________________________
13
                                                     Mary Rose Garrido Wilcox
14                                                   Chairperson
                                                     Arizona Minority Coalition for Fair
15                                                      Redistricting
16
            SUBSCRIBED AND SWORN to before me this ______ day of March, 2002.
17

18
                                               ____________________________________
19                                                        Notary Public
20   My commission expires:
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     ___________________
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                                                  -
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 1                                         VERIFICATION
 2   STATE OF ARIZONA              )
                                   ) ss.
 3   County of Maricopa            )
 4          _________________, hereby affirms the following:
 5          I am the _________ of Los Abogados, an Arizona corporation and the plaintiff in the
 6
     above referenced action. I have reviewed the Complaint; I am authorized to verify the
 7
     contents thereof on behalf of Los Abogados, and know the contents stated therein to be true,
 8

 9   except as to those matters therein stated upon information and belief, and as to such matters,
10   which I believe to be true.
11

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                                               ____________________________________
13
                                                     Alex Navidad                                                       Formatted

14                                                   Los Abogados Board Member
15          SUBSCRIBED AND SWORN to before me this ______ day of March, 2002.
16

17                                             ____________________________________
                                                          Notary Public
18

19   My commission expires:
20   ___________________
21

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                                                                         -   3a0a4feb-8c57-41f4-adfe-4708d77bafbb.doc

				
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