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Kathleen E. Brody (Bar No. 026331)

Darrell L. Hill (Bar No. 030424)

American Civil Liberties Union of Arizona

3707 North 7th Street, Suite 235

Phoenix, AZ 85014

Tel.: (602) 650-1854

kbrody@acluaz.org

dhill@acluaz.org

Theresa J. Lee* (NY Bar No. 5022769)

American Civil Liberties Union Foundation 

125 Broad Street, 18th Floor

New York, NY 10004 

Tel.: (212) 549-2500

tlee@aclu.org

Attorneys for Third Party Movant

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF ARIZONA

_________________________________

)

League of United Latin American )

Citizens Arizona; Arizona Students’ )

Association, )

)

Plaintiffs, )

)

v. )

)

Michele Reagan, in her official )

capacity as Secretary of State of Arizona;)

Adrian Fontes, in his official )

capacity as Maricopa County Recorder )

)

Defendants. )

_________________________________)

No. 2:17-cv-04102-DGC

NOTICE TO COURT REGARDING 

MOTION TO COMPEL 

COMPLIANCE WITH CONSENT 

DECREE

Third party Movant Luis Cisneros submits this Notice to update the Court that his ballot 

appears to have been “accepted” for counting. On November 13, 2018, at approximately 11:15 

a.m. Mountain Time, counsel for Mr. Cisneros continued their practice of checking the status of 

Case 2:17-cv-04102-DGC Document 45 Filed 11/13/18 Page 1 of 3
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his ballot on the website for the Pima County Recorder. Though certain of the dates on the 

website were inaccurate based on Mr. Cisneros experience submitting his ballot, the website 

indicated that his ballot had been “transferred to the Elections Department to be counted in batch 

Y2, on 11/12/2018.” Upon checking the status of Mr. Cisneros’s ballot on the Secretary of 

State’s website, leaving aside the inaccurate date of return of his ballot, the status of the ballot 

was listed as “Accepted.”

If these designations mean that his ballot will be counted, Mr. Cisneros no longer seeks 

such an order with respect to his ballot. Mr. Cisneros still seeks for his date of registration to be 

deemed to have occurred on October 8, 2018, pursuant to the Consent Decree, to the extent it 

has not been. Mr. Cisneros continues to note that his experience indicates that many other 

voters may have faced similar barriers to their registration and vote in violation of the Consent 

Decree.

November 13, 2018 Respectfully submitted,

/s Kathleen E. Brody

Theresa J. Lee* (N.Y. Bar No. 5022769)

American Civil Liberties Union Foundation 

125 Broad Street, 18th Floor

New York, NY 10004 

Tel.: (212) 549-2500

tlee@aclu.org

* pro hac vice forthcoming

Kathleen E. Brody (Bar No. 026331)

Darrell L. Hill (Bar No. 030424)

American Civil Liberties Union of Arizona

3707 North 7th Street, Suite 235

Phoenix, AZ 85014

Tel.: (602) 650-1854

kbrody@acluaz.org

dhill@acluaz.org

Attorneys for Third Party Movant

Case 2:17-cv-04102-DGC Document 45 Filed 11/13/18 Page 2 of 3
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CERTIFICATE OF SERVICE

I, Kathy Brody, hereby certify that this Motion for Leave to Appear 

Telephonically with the Consent Decree was served upon all counsel of record in this 

case via ECF. 

/s/ Kathy Brody

Attorney for Third Party Movant

Luis Cisneros

Case 2:17-cv-04102-DGC Document 45 Filed 11/13/18 Page 3 of 3