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

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e granted.CONCLUSIONFor all the foregoing reason, Plaintiffs’ motion for a preliminary injunction shouldDated: March __, 2002Respectfully submitted,_______________________William M. BlossJacobs, Grudberg, Belt & Dow, PC350 Orange StreetPO Box 606New Haven, CT 06503-0606(203)772-3100Elizabeth DanielBRENNAN CENTER FOR JUSTICEat New York University School of Law161 Avenue of the AmericasNew York, NY 10013(212) 998-6730Visiting Attorney40
Page 1 and 2: UNITED STATES DISTRICT COURTDISTRIC
Page 4 and 5: TABLE OF AUTHORITIESAnderson v. Cel
Page 6 and 7: a grueling, months-long process tha
Page 8 and 9: single-town state house districts w
Page 10 and 11: state’s 151 Assembly seats. 5In t
Page 12 and 13: of delegates, which takes place, by
Page 14 and 15: outsiders trying to achieve ballot
Page 16 and 17: 14; Byrnes Decl. at 5. In short, i
Page 18 and 19: Decl. at 10-11; Rapoport Decl. at
Page 20 and 21: in multi-town districts, out of a t
Page 22 and 23: for delegate slates, is more burden
Page 24 and 25: Rapoport Decl. at 15. Notably, the
Page 26 and 27: I. THE BALANCE OF HARMS TIPS OVERWH
Page 28 and 29: primary ballot access while multi-t
Page 30 and 31: activities. See Statement of the Fa
Page 32 and 33: Not one state has legally-mandated
Page 34 and 35: McLoughlin Decl. at Exhibit C. But,
Page 36 and 37: 2. Connecticut’s unique and uniqu
Page 38 and 39: In addition, the court’s assessme
Page 40 and 41: In contrast to the court in Tansley
Page 42 and 43: The classification at issue here -

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

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