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Page 1 IN THE UNITED STATES DISTRICT COURT FOR THE
DISTRICT OF COLUMBIA
CITY OF SALEM, VIRGINIA,
a political subdivision of the
Commonwealth of Virginia,
114 North Broad Street
City of Salem, Virginia 24153
)
)
)
)
)
)
Plaintiff,
)
)
v.
)
)
ALBERTO R. GONZALES,
)
Attorney General of the
)
United States of America;
)
WAN J. KIM,
)
Assistant Attorney General,
)
Civil Rights Division, United States
)
Department of Justice, Washington, DC,
)
)
Defendants.
)
____________________________________)
Civil Action No.
Three-Judge Court Requested
UNOPPOSED MOTION TO CONVENE THREE-JUDGE COURT
Plaintiff City of Salem respectfully moves this Court for entry of an order
requesting the convening of a three-judge court. As grounds for this motion, plaintiff
would show unto the Court that:
1. Plaintiff City of Salem has filed this action pursuant to Section 4 of the
Voting Rights Act of 1965, as amended, 42 U.S.C. §1973b. Plaintiff’s
action seeks a declaratory judgment from this Court granting the City an
exemption from the special remedial provisions of the Voting Rights Act.
2. A three-judge court is required under Section 4 of the Voting Rights Act:
“A district court of three-judges shall be convened to hear and determine
the action.” See 42 U.S.C. §1973b.Page 2 3. Counsel for the defendants was contacted prior to the filing of the
complaint and this motion. The defendants do not oppose the convening
of a three-judge court or entry of the enclosed order.
4. A proposed order is respectfully submitted for the Court’s consideration.
WHEREFORE, plaintiff respectfully prays that this Court will grant this motion
and enter the attached order requiring the clerk of this Court to notify the Chief Judge of
the United States Court of Appeals for the D.C. Circuit that a three-judge court is
required to hear and determine this action.
Respectfully submitted,
/s/ J. Gerald Hebert___
J. GERALD HEBERT
Attorney at Law
J. Gerald Hebert, PC
5019 Waple Lane
Alexandria, Va. 22304
(703) 567-5873 (O)
(703) 567-5876 (fax)
DC Bar No. 447676
Email: jghebert@comcast.net
PDF Page 1
PlainSite Cover Page
PDF Page 2
Case 1:06-cv-00977-HHK
Document 2
Filed 05/25/2006
Page 1 of 2
IN THE UNITED STATES DISTRICT COURT FOR THE
DISTRICT OF COLUMBIA
CITY OF SALEM, VIRGINIA,
a political subdivision of the
Commonwealth of Virginia,
114 North Broad Street
City of Salem, Virginia 24153
)
)
)
)
)
)
Plaintiff,
)
)
v.
)
)
ALBERTO R. GONZALES,
)
Attorney General of the
)
United States of America;
)
WAN J. KIM,
)
Assistant Attorney General,
)
Civil Rights Division, United States
)
Department of Justice, Washington, DC,
)
)
Defendants.
)
____________________________________)
Civil Action No.
Three-Judge Court Requested
UNOPPOSED MOTION TO CONVENE THREE-JUDGE COURT
Plaintiff City of Salem respectfully moves this Court for entry of an order
requesting the convening of a three-judge court. As grounds for this motion, plaintiff
would show unto the Court that:
1. Plaintiff City of Salem has filed this action pursuant to Section 4 of the
Voting Rights Act of 1965, as amended, 42 U.S.C. §1973b. Plaintiff’s
action seeks a declaratory judgment from this Court granting the City an
exemption from the special remedial provisions of the Voting Rights Act.
2. A three-judge court is required under Section 4 of the Voting Rights Act:
“A district court of three-judges shall be convened to hear and determine
the action.” See 42 U.S.C. §1973b.
PDF Page 3
Case 1:06-cv-00977-HHK
Document 2
Filed 05/25/2006
Page 2 of 2
3. Counsel for the defendants was contacted prior to the filing of the
complaint and this motion. The defendants do not oppose the convening
of a three-judge court or entry of the enclosed order.
4. A proposed order is respectfully submitted for the Court’s consideration.
WHEREFORE, plaintiff respectfully prays that this Court will grant this motion
and enter the attached order requiring the clerk of this Court to notify the Chief Judge of
the United States Court of Appeals for the D.C. Circuit that a three-judge court is
required to hear and determine this action.
Respectfully submitted,
/s/ J. Gerald Hebert___
J. GERALD HEBERT
Attorney at Law
J. Gerald Hebert, PC
5019 Waple Lane
Alexandria, Va. 22304
(703) 567-5873 (O)
(703) 567-5876 (fax)
DC Bar No. 447676
Email: jghebert@comcast.net
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