Joint MOTION for Entry of Declaratory Judgment by BOTETOURT COUNTY, VIRGINIA, ALBERTO R. GONZALES, WAN J. KIM. (Attachments: # 1 Text of Proposed Order Consent Judgment and Decree)(Hebert, J.) (Entered: 08/11/2006)
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Page 1 Case 1:06-cv-01052-RMC Document6 ~~ Filed 08/11/2006 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT FOR THE
DISTRICT OF COLUMBIA
BOTETOURT COUNTY, VIRGINIA,
a political subdivision of the
Commonwealth of Virginia,
Plaintiff,
V.
)
)
)
)
)
)
)
)
ALBERTO R. GONZALES, )
Attorney General of the ) Civil Action No.
United States of America, )
WAN J. KIM, )
Assistant Attorney General, )
Civil Rights Division, United States )
Department of Justice, Washington, DC, )
)
)
)
1:06CV-01052 (KLH), RMC, JR)
(three-judge court)
Defendants.
JOINT MOTION FOR ENTRY OF CONSENT JUDGMENT AND DECREE
The plaintiff Botetourt County, Virginia, and the Defendants Alberto R. Gonzales and
Wan J. Kim, through counsel, respectfully move this three-judge Court for entry of the
attached Consent Judgment and Decree.
The enclosed Consent Judgment and Decree is similar to those that have been
entered by three-judge courts in other declaratory judgment actions brought under
Section 4 of the Voting Rights Act, as amended, 42 U.S.C. §1973b. See, e.g., Augusta
County, VA v. Gonzales, C.A. No. 05-1885 (D.D.C. November 30, 2005); Greene
County, Va. v. Ashcroft, C.A. No. 03-1887 (January 19, 2004); Roanoke County, VA v.
Reno, C.A. No. 00-1949 (D.D.C. January 24, 2001); City of Winchester, VA v. Ashcroft,
C.A. No. 00-3073 (D.D.C. May 31, 2001); and City of Fairfax, v. Reno, C.A. No. 97-Page 2 Case 1:06-cv-01052-RMC Document6 ~~ Filed 08/11/2006 Page 2of2
No. 97-2212 (D.D.C. October 21, 1997). As in those actions, this motion is based on the
Stipulation of Facts which is being filed simultaneously herewith.
WHEREFORE, Plaintiff and Defendants respectfully pray that this joint motion
be granted.
For the Plaintiff Botetourt County, Virginia
Attorney at Law
5019 Waple Lane
Alexandria, Va. 22304
(703) 567-5873 (O)
(703) 567-5876 (fax)
DC Bar No. 447676
C) J. GERALD HEBERT
For the Defendants Alberto R. Gonzales
and Wan J. Kim:
KENNETH L. WAINSTEIN
United States Attorney
WA MWA
OHN TANNER
CHRISTY A. McCORMICK
Attorneys, Voting Section
Civil Rights Division
United States Department of Justice
Room 7254 - NWB
950 Pennsylvania Ave., N.W.
Washington, DC 20530
(202) 514-2386
PDF Page 1
PlainSite Cover Page
PDF Page 2
Case 1:06-cv-01052-RMC Document6 ~~ Filed 08/11/2006 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT FOR THE
DISTRICT OF COLUMBIA
BOTETOURT COUNTY, VIRGINIA,
a political subdivision of the
Commonwealth of Virginia,
Plaintiff,
V.
)
)
)
)
)
)
)
)
ALBERTO R. GONZALES, )
Attorney General of the ) Civil Action No.
United States of America, )
WAN J. KIM, )
Assistant Attorney General, )
Civil Rights Division, United States )
Department of Justice, Washington, DC, )
)
)
)
1:06CV-01052 (KLH), RMC, JR)
(three-judge court)
Defendants.
JOINT MOTION FOR ENTRY OF CONSENT JUDGMENT AND DECREE
The plaintiff Botetourt County, Virginia, and the Defendants Alberto R. Gonzales and
Wan J. Kim, through counsel, respectfully move this three-judge Court for entry of the
attached Consent Judgment and Decree.
The enclosed Consent Judgment and Decree is similar to those that have been
entered by three-judge courts in other declaratory judgment actions brought under
Section 4 of the Voting Rights Act, as amended, 42 U.S.C. §1973b. See, e.g., Augusta
County, VA v. Gonzales, C.A. No. 05-1885 (D.D.C. November 30, 2005); Greene
County, Va. v. Ashcroft, C.A. No. 03-1887 (January 19, 2004); Roanoke County, VA v.
Reno, C.A. No. 00-1949 (D.D.C. January 24, 2001); City of Winchester, VA v. Ashcroft,
C.A. No. 00-3073 (D.D.C. May 31, 2001); and City of Fairfax, v. Reno, C.A. No. 97-
PDF Page 3
Case 1:06-cv-01052-RMC Document6 ~~ Filed 08/11/2006 Page 2of2
No. 97-2212 (D.D.C. October 21, 1997). As in those actions, this motion is based on the
Stipulation of Facts which is being filed simultaneously herewith.
WHEREFORE, Plaintiff and Defendants respectfully pray that this joint motion
be granted.
For the Plaintiff Botetourt County, Virginia
Attorney at Law
5019 Waple Lane
Alexandria, Va. 22304
(703) 567-5873 (O)
(703) 567-5876 (fax)
DC Bar No. 447676
C) J. GERALD HEBERT
For the Defendants Alberto R. Gonzales
and Wan J. Kim:
KENNETH L. WAINSTEIN
United States Attorney
WA MWA
OHN TANNER
CHRISTY A. McCORMICK
Attorneys, Voting Section
Civil Rights Division
United States Department of Justice
Room 7254 - NWB
950 Pennsylvania Ave., N.W.
Washington, DC 20530
(202) 514-2386
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