MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFFS' MOTION ...

outsiders trying to achieve ballot access for the real primary because, as discussed above,these candidates cannot count on receiving enough delegates on the towns’ endorsedslates. See, e.g.. Caplan Decl. at 6; Campbell Decl. at 10-11; Fixary Decl. at 10.For candidates in hard-fought open seat races, running delegate primaries is oftenstrategically necessary to assure the support of a core group of delegates. See ByrnesDecl. at 5; Rapoport Decl. at 26; Nielsen Decl. at 10-11. It is a burdensome processthat requires challengers to petition for ballot access and then to run in an election just toget on the real primary ballot.To challenge a town committee’s slate, the candidate must first name a slate ofregistered party members who are willing to publicly oppose their party’s leadership byserving as “challenge” delegates. See Campbell Decl. at 12. Thus, just to get a chanceto run in the pre-primary, which in turn gives the candidate a chance to run in the realprimary, which, in turn, puts the candidate on the general election ballot, the candidatemust find 10, 15, 20, or more delegates in a given town who are willing to identifythemselves as opponents of the incumbent and the party leadership. See id. In sometowns, a challenge will be seen as so disloyal that it is difficult for candidates to findparty members willing to take on the town committee. Id. See also Caplan Decl. at 10.Publicly serving as a challenge delegate is far more confrontational than signing or evencirculating a petition. At the very least, recruiting delegates is an additional burden for achallenger candidate who is seeking only to have an opportunity to run in a primary.Once the candidate has a challenge slate lined up, the candidate must collectpetition signatures of 5% of the town’s registered party members in order to qualify theslate for the “delegate primary” – the pre-primary primary where the challenge slate runs10