Statements of Material Fact
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA
ROY FERRAND, LUTHER SCOTT, JR., CIVIL ACTION NO. 2:11-cv-00926 and LOUISIANA STATE CONFERENCE LMA – JCW
OF THE NAACP, for themselves and all other persons similarly situated
v.
TOM SCHEDLER, in his official capacity as the Louisiana Secretary of State, RUTH
JOHNSON, in her official capacity as
Secretary of the Louisiana Department of
Children & Family Services, and BRUCE
D. GREENSTEIN, in his official capacity as Secretary of the Louisiana Department of Health & Hospitals
DEFENDANT JOHNSON’S STATEMENT OF MATERIAL FACTS WHICH PRESENT GENUINE ISSUES IN
OPPOSITION TO PLAINTIFFS’ MOTION FOR PARTIAL SUMMARY JUDGMENT
Defendant, Ruth Johnson, in her official capacity as Secretary of the Department of Children and Family Services, hereinafter referred to as “Secretary Johnson” or “Defendant Johnson”, pursuant to Local Rule 56.2, submits this statement of genuine issues in opposition to Plaintiffs’ Motion for Partial Summary Judgment (R. Doc. 112 and 112-1). Items 1 through 101 below correspond to the alleged facts presented in Plaintiffs’ Statement of Uncontested Material Facts (R. Doc. 112-1). Defendant Johnson asserts that there exist genuine issues of material fact in opposition to Plaintiffs’ Motion for Partial Summary Judgment.
1. Defendant Johnson agrees that the National Voter Registration Act (“NVRA”) is codified at 42 U.S.C. § 1973gg, et seq.; however, the codification of the NVRA is not at issue and it is a statement of law, not material fact.
2. Defendant Johnson agrees that in enacting the NVRA, Congress found the following; but the same is not a statement of material fact and Plaintiffs are simply citing a statement of law:
(1) the right of citizens of the United States to vote is a fundamental right;
(2) it is the duty of the Federal, State, and local governments to promote the exercise of that right; and
(3)
EASTERN DISTRICT OF LOUISIANA
ROY FERRAND, LUTHER SCOTT, JR., CIVIL ACTION NO. 2:11-cv-00926 and LOUISIANA STATE CONFERENCE LMA – JCW
OF THE NAACP, for themselves and all other persons similarly situated
v.
TOM SCHEDLER, in his official capacity as the Louisiana Secretary of State, RUTH
JOHNSON, in her official capacity as
Secretary of the Louisiana Department of
Children & Family Services, and BRUCE
D. GREENSTEIN, in his official capacity as Secretary of the Louisiana Department of Health & Hospitals
DEFENDANT JOHNSON’S STATEMENT OF MATERIAL FACTS WHICH PRESENT GENUINE ISSUES IN
OPPOSITION TO PLAINTIFFS’ MOTION FOR PARTIAL SUMMARY JUDGMENT
Defendant, Ruth Johnson, in her official capacity as Secretary of the Department of Children and Family Services, hereinafter referred to as “Secretary Johnson” or “Defendant Johnson”, pursuant to Local Rule 56.2, submits this statement of genuine issues in opposition to Plaintiffs’ Motion for Partial Summary Judgment (R. Doc. 112 and 112-1). Items 1 through 101 below correspond to the alleged facts presented in Plaintiffs’ Statement of Uncontested Material Facts (R. Doc. 112-1). Defendant Johnson asserts that there exist genuine issues of material fact in opposition to Plaintiffs’ Motion for Partial Summary Judgment.
1. Defendant Johnson agrees that the National Voter Registration Act (“NVRA”) is codified at 42 U.S.C. § 1973gg, et seq.; however, the codification of the NVRA is not at issue and it is a statement of law, not material fact.
2. Defendant Johnson agrees that in enacting the NVRA, Congress found the following; but the same is not a statement of material fact and Plaintiffs are simply citing a statement of law:
(1) the right of citizens of the United States to vote is a fundamental right;
(2) it is the duty of the Federal, State, and local governments to promote the exercise of that right; and
(3)