Case 2:16-cv-02514-RFB-NJK Document 68 Filed 11/07/16 Page 1 of 3

Bradley S. Schrager (Nevada Bar # 10217)

Don Springmeyer (Nevada Bar # 1021)
WOLF, RIFKIN, SHAPIRO,
SCHULMAN & RABKIN, LLP
3556 East Russell Road
Las Vegas, NV 89120
(702) 341-5200
Fax #: (702) 341-5300
BSchrager@wrslawyers.com
DSpringmeyer@wrslawyers.com
Attorneys for Plaintiff Nevada State Democratic Party

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF NEVADA

NEVADA STATE DEMOCRATIC PARTY,

Plaintiff,
v.

Case No. 2:16-cv-02514-RFB-NJK

NEVADA REPUBLICAN PARTY, DONALD

J. TRUMP FOR PRESIDENT, INC., ROGER J.
STONE, JR., and STOP THE STEAL INC.,

[PROPOSED] ORDER AND OPINION

Defendants.

This matter comes before the Court on Plaintiffs Motion for a Temporary Restraining
Order and/or Preliminary Injunction. For the reasons set forth below, the Motion is GRANTED.
Plaintiff Nevada State Democratic Party brings this action under Section 2 of the Ku
Klux Klan Act of 1871, 42 U.S.C. 1985(3), and Section 11(b) of the Voting Rights Act of
1965, 52 U.S.C. 10307(b). Plaintiff moves to temporarily restrain and preliminarily enjoin
Defendants from (a) advancing their conspiracy to intimidate, threaten, harass, or coerce voters;
(b) actually intimidating, threatening, harassing, or coercingor attempting to intimidate,

Case 2:16-cv-02514-RFB-NJK Document 68 Filed 11/07/16 Page 2 of 3

threaten, harass, or coercevoters; (c) violating Nevada law with respect to poll-watching
activities; and (d) engaging in any other conduct contributing to the intimidation, harassment, or
coercion of voters.
Having considered all of the materials and argument that have been submitted in this
matter, including Plaintiffs Complaint and Memorandum of Law, IT IS HEREBY ORDERED
THAT, effective immediately and extending until 11:59 p.m., November 8, 2016, or until voting
in the 2016 Presidential Election is complete, Defendantsas well as their officers, agents,
servants, employees, and attorneys, and those persons who are in active concert or participation
with themare RESTRAINED AND ENJOINED from engaging in any voter intimidation
activity, including but not limited to:
a. Blocking the entrance to the polling place;
b. Direct confrontation or questioning of voters, or asking voters for
documentation when none is required;
c. Disrupting voting lines inside or outside of the polling place;
d. Disseminating false or misleading election information;
e. Photographing or videotaping voters to intimidate them;
f. Confronting, hovering, or, within 100 feet from the entrance of the polling
place, directly speaking to voters on the subject of marking that voters
ballot;
g. Challenging voters except by a registered voter of the precinct based upon
personal knowledge and by sworn affidavit, on the ground that the voter is
not the person entitled to vote as claimed, or has already voted in the
election;

Case 2:16-cv-02514-RFB-NJK Document 68 Filed 11/07/16 Page 3 of 3

h. Verbal or physical confrontation of voters by persons dressed in officiallooking uniforms;

i. Violence or using the threat of violence to interfere with a persons right
to vote.
IT IS FURTHER ORDERED THAT Defendants Stone and Stop the Steal shall abide
byand shall distribute to all Stop the Steal volunteers in Nevadathe guidelines that
Defendants have proposed in the Declaration of Roger J. Stone in Support of Defendants Roger
J. Stone and Stop the Steals Opposition to Motion for Temporary Restraining Order and/or
Preliminary Injunction (Doc. No. 60), at 3, including that all volunteers for Stop the Steal are
RESTRAINED AND ENJOINED from engaging in any of the activities described in the section
entitled You Must Not.
IT IS FURTHER ORDERED THAT Defendants shall show cause as to why a
Preliminary and/or Permanent Injunction should not issue restraining and enjoining them from
engaging in the conduct described above.
IT IS FURTHER ORDERED THAT this Order and Opinion be publicized to all law
enforcement and elections officials in advance of Election Day.

Defendants shall bear

reasonable costs of publication.

SO ORDERED.
_________________________________
Hon. Richard Franklin Boulware II, U.S.D.J.
Dated: _______________