IN THE UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF FLORIDA

GAINESVILLE DIVISION

KIRK NIELSEN et al.,

Plaintiffs, CONSOLIDATED CASES

Case No. 4:20-cv-00236-RH-MJF

v.

RON DESANTIS, in his official as

Governor of the State of Florida, et al.,

Defendants.

__________________________________/

PLAINTIFF -INTERVENORS’ MOTION FOR LEAVE TO FILE A 

SUPPLEMENTAL TRIAL BRIEF

COMES NOW, Intervenors, DEBORAH C. GRUBB, DOUGLAS E. HALL, 

CARL F. MCCOY, JAMES K. KRACHT, DOLOR GINCHEREAU, and the 

FLORIDA COUNCIL OF THE BLIND, by and through the undersigned counsel, 

respectfully requests this Court leave to file a Supplemental Trial Brief addressing 

the Secretary of States interim approval of Democracy Live OmniBallot, and in 

support states as follows:

Pursuant to the Pretrial Order [DE-573] – “The defendant Supervisors of 

Elections may file by 7/17/2020 a supplemental trial brief addressing the Secretary 

of States interim approval of Democracy Live OmniBallot”.

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Nielsen, et al v. DeSantis et al

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Disability Independence Group, Inc. * 2990 Southwest 35th Avenue * Miami, Florida 33133

As stated, many of the issues in the Grubb Plaintiff’s would like to address in 

Supplemental Trial Brief is how the Secretary of States interim approval of 

Democracy Live OmniBallot as well, including the burdens of proof of the 

respective parties herein. 

WHEREFORE, intervenors, DEBORAH C. GRUBB, DOUGLAS E. 

HALL, CARL F. MCCOY, JAMES K. KRACHT, DOLOR GINCHEREAU, and 

the FLORIDA COUNCIL OF THE BLIND, INC. respectfully request that this court 

grant leave to file a Supplemental Trial Brief addressing the Secretary of States 

interim approval of Democracy Live OmniBallot, and for further relief as is just and 

equitable. 

Respectfully Submitted on this 16th day of July 2020.

By: s/ Matthew W. Dietz _____

Matthew W. Dietz, Esq.

Florida Bar No. 84905

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Disability Independence Group, Inc. * 2990 Southwest 35th Avenue * Miami, Florida 33133

CERTIFICATION OF WORD COUNT

I HEREBY CERTIFY, pursuant to Northern District of Florida Local Rule 

7.1(F), that this motion contains approximately 187 words.

By: s/ Matthew W. Dietz _____

Matthew W. Dietz, Esq.

Florida Bar No. 84905

CERTIFICATE OF COMPLIANCE

Pursuant to Local Rule 7.1(B), the attorney for the moving party made an 

attempt in good faith to resolve the issue through a meaningful conference with all 

of the counsel in attendance at a conference of all of the parties, and the attorneys 

for the defendants could not state whether they do not oppose to the relief requested 

herein. 

By: s/ Matthew W. Dietz _____

Matthew W. Dietz, Esq.

Florida Bar No. 84905

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Nielsen, et al v. DeSantis et al

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Disability Independence Group, Inc. * 2990 Southwest 35th Avenue * Miami, Florida 33133

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on July 16, 2020, I electronically filed the 

foregoing with the Clerk of the Court by using the CM/ECF system which will send 

notice of electronic filing to all parties and counsel of record in the herewith service 

list, or in some other authorized manner for those counsel or parties who are not 

authorized to receive notices electronically.

By: s/ Matthew W. Dietz 

MATTHEW W. DIETZ, ESQ.

Florida Bar No.: 00849

DISABILITY INDEPENDENCE GROUP, INC.

2990 Southwest 35th Avenue

Miami, Florida 33133

Tel: (305) 669-2822

Fax: (305) 442-4181

Mdietz@justDIGit.org

aa@justdigit.org

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