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

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14; Byrnes Decl. at 5. In short, it is like running in a real election except that it is acampaign just to get a chance to qualify to run a real primary – which would then give thecandidate a chance to run in the general election. See Rapoport Decl. at 26 (noting that$60,000 was spent in one town’s delegate primary for U.S. House seat).The voting public in these towns rarely understands what they are being asked todo. See Haave Decl. at 14. Many voters are confused about why they are being askedto vote in a primary in May when Connecticut’s real primaries are held in September.Campbell Decl. at 17; Caplan Decl. at 14; Fixary Decl. at 13; Carey Decl. at 14. This confusion makes it difficult for candidates to build support and to develop aclear message. In addition, challenger candidates often have trouble raising money to runthese delegate primaries in part because donors don’t understand what they are butmostly because donors are reluctant to support a candidate who has not even achievedballot status. See Haave Decl. at 13; Carey Decl. at 13.Finally, the delegate primary – like a candidate election – is a winner take allelection. A challenger slate that runs a competitive race suggesting significant supportbut not over 50% will get nothing. See Caplan Decl. at 13 (noting strong delegateprimary showings but no delegates). See also Campbell Decl. at 19-20 .In short, candidates who are not party favorites must mount, run, and win actualcampaigns just to get a chance to run in a real primary while candidates in Connecticut’ssingle-town districts and almost every other state in the country must simply petition toget onto the primary ballot.12

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