Joint MOTION for Entry of Declaratory Judgment by CITY OF SALEM, VIRGINIA, ALBERTO R. GONZALES, WAN J. KIM. (Attachments: # (1) Text of Proposed Order Consent Judgment and Decree Granting Declaratory Judgment)(Hebert, J.)
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Page 1 Case 1:06-cv-00977-HHK Document6 ~ Filed 06/23/2006 Page1of3
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,
Vv.
ALBERTO R. GONZALES,
Attomey General of the
United States of America:
WAN G, KIM
Assistant Attorney General,
Civil Rights Division, United States
Department of Justice, Washington, DC,
Civil Action No. 1:06-cyv-977
(BME, RJL, HHE)
Three-Judge Court
Defendants.
me em ee eee me Sete SS SiS eT
JOINT MOTION FOR ENTRY OF CONSENT JUDGMENT AND DECREE
The plaintiff City of Salem , Virginia, and the Defendants Alberto R. Gonzales
and Wan G. Kim, through counsel, respectfully move this three-judge Court for entry of
the attached Consent Judgment and Decree. As grounds for this motion, the parties
would show unto this Court the following:
|. This is an action in which the City of Salem seeks a bailout from coverage under
Section 4 of the Voting Rights Act of 1965, as amended, 42 U.S.C. $1973b.
ed
The defendants have consented to the requested bailout and the proposed Consent
Judgment and Decree would grant a bailout to the City of Salem.
3. The proposed Consent Judgment and Decree is quite similar to those that have
been entered by other three-judge courts in declaratory judgment actions broughtPage 2 Case 1:06-cv-00977-HHK Document6 ~ Filed 06/23/2006 Page 2of3
under Section 4 of the Voting Rights Act, as amended, 42 U.S.C. §1973b. See,
e.g., City of Fairfax, v, Reno, C.A. No. 97-2212 (D.D.C. October 21, 1997);
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); City of
Harrisonburg v, Ashcraft, C.A. No, 1:02CV00289 (D.D.C. April 17, 2002).
Greene County v. Ashcroft, C.A. No, 03-1877 (D.D.C. Jan. 19, 2004); and
Augusta County, VA v. Gonzales, C.A. No. 05-1885 (D.D.C. 2005). 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.Page 3 Case 1:06-cv-00977-HHK Document6 Filed 06/23/2006 Page 3of3
Respectfully submitted,
For Plaintiff City of Salem, Virginia
QL asd Web T
. GERALD HEBERT
Attorney at Law
5019 Waple Lane
Alexandria, Va. 22304
(703) 567-5873 (O)
(703) 567-5876 (fax)
DC Bar No. 447676
For the Defendants:
ALBERTO R. GONZALES and
WAN J. KIM:
KENNETH L. WAINSTEIN
United States Attorney
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
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Case 1:06-cv-00977-HHK Document6 ~ Filed 06/23/2006 Page1of3
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,
Vv.
ALBERTO R. GONZALES,
Attomey General of the
United States of America:
WAN G, KIM
Assistant Attorney General,
Civil Rights Division, United States
Department of Justice, Washington, DC,
Civil Action No. 1:06-cyv-977
(BME, RJL, HHE)
Three-Judge Court
Defendants.
me em ee eee me Sete SS SiS eT
JOINT MOTION FOR ENTRY OF CONSENT JUDGMENT AND DECREE
The plaintiff City of Salem , Virginia, and the Defendants Alberto R. Gonzales
and Wan G. Kim, through counsel, respectfully move this three-judge Court for entry of
the attached Consent Judgment and Decree. As grounds for this motion, the parties
would show unto this Court the following:
|. This is an action in which the City of Salem seeks a bailout from coverage under
Section 4 of the Voting Rights Act of 1965, as amended, 42 U.S.C. $1973b.
ed
The defendants have consented to the requested bailout and the proposed Consent
Judgment and Decree would grant a bailout to the City of Salem.
3. The proposed Consent Judgment and Decree is quite similar to those that have
been entered by other three-judge courts in declaratory judgment actions brought
PDF Page 3
Case 1:06-cv-00977-HHK Document6 ~ Filed 06/23/2006 Page 2of3
under Section 4 of the Voting Rights Act, as amended, 42 U.S.C. §1973b. See,
e.g., City of Fairfax, v, Reno, C.A. No. 97-2212 (D.D.C. October 21, 1997);
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); City of
Harrisonburg v, Ashcraft, C.A. No, 1:02CV00289 (D.D.C. April 17, 2002).
Greene County v. Ashcroft, C.A. No, 03-1877 (D.D.C. Jan. 19, 2004); and
Augusta County, VA v. Gonzales, C.A. No. 05-1885 (D.D.C. 2005). 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.
PDF Page 4
Case 1:06-cv-00977-HHK Document6 Filed 06/23/2006 Page 3of3
Respectfully submitted,
For Plaintiff City of Salem, Virginia
QL asd Web T
. GERALD HEBERT
Attorney at Law
5019 Waple Lane
Alexandria, Va. 22304
(703) 567-5873 (O)
(703) 567-5876 (fax)
DC Bar No. 447676
For the Defendants:
ALBERTO R. GONZALES and
WAN J. KIM:
KENNETH L. WAINSTEIN
United States Attorney
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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