Case 3:11-cv-00159-TSL -EGJ -LG Document 83 Filed 04/25/11 Page 1 of 3

IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF MISSISSIPPI
JACKSON DIVISION

MISSISSIPPI STATE CONFERENCE OF THE

NATIONAL ASSOCIATION FOR THE
ADVANCEMENT OF COLORED PEOPLE, et al PLAINTIFFS

v. NO. 3:11-cv-159 DPJ FKB

HALEY BARBOUR, et al DEFENDANTS

and

APPORTIONMENT AND ELECTIONS COMMITTEE

OF THE MISSISSIPPI HOUSE OF REPRESENTATIVES, et al INTERVENORS

MISSISSIPPI DEMOCRATIC PARTY EXECUTIVE COMMITTEE’S JOINDER IN

MOTION OF INTERVENOR HOUSE APPORTIONMENT AND ELECTIONS
COMMITTEE TO ADOPT 2011 HOUSE AND SENATE PLANS AS INTERIM PLANS
FOR THE 2011 ELECTION ONLY, TO DEFER ISSUE OF SPECIAL ELECTIONS FOR
THE TIME BEING, AND TO SET A SCHEDULE IN THE FUTURE FOR THE FILING
OF ANY MOTIONS FOR SPECIAL ELECTIONS, AND INCORPORATED
MEMORANDUM OF LAW

Defendant Mississippi Democratic Party Executive Committee (“Democratic Party”)

hereby moves to join in the Motion of Intervenor House Apportionment and Elections

Committee to Adopt 2011 House and Senate Plans as Interim Plans for the 2011 Elections Only,

to Defer Issue of Special Elections for the Time Being, and to Set a Schedule in the Future for

the Filing of any Motions for Special Elections. For the reasons stated in the House

Apportionment and Elections Committee’s Motion, the Democratic Party agrees that the House

and Senate plans should be adopted as an interim court-ordered plan for the 2011 elections only,

that the issue of special elections be deferred for the time being, and that the Court at some point

schedule a deadline in the future for any party to file any motion for special election relief if the
 Case 3:11-cv-00159-TSL -EGJ -LG Document 83 Filed 04/25/11 Page 2 of 3

party believes that any alleged infirmities in the 2011 House or Senate plans justify holding a

special election in 2012.

Respectfully submitted, this the 25th day of April.

MISSISSIPPI DEMOCRATIC PARTY

EXECUTIVE COMMITTEE

By: __/s/ Samuel L. Begley_______________

Samuel L. Begley MSB# 2315
OF COUNSEL:
BEGLEY LAW FIRM, PLLC
Samuel L. Begley
P. O. Box 287
Jackson, MS 39205
(601)969-5545 (Telephone)
(601)969-5547 (Facsimile)
 Case 3:11-cv-00159-TSL -EGJ -LG Document 83 Filed 04/25/11 Page 3 of 3

CERTIFICATE OF SERVICE

I, Samuel L. Begley, hereby certify that on April 25th, 2011, I caused the following documents:

1. MISSISSIPPI DEMOCRATIC PARTY EXECUTIVE COMMITTEE’S JOINDER

IN MOTION OF INTERVENOR HOUSE APPORTIONMENT AND ELECTIONS
COMMITTEE TO ADOPT 2011 HOUSE AND SENATE PLANS AS INTERIM
PLANS FOR THE 2011 ELECTION ONLY, TO DEFER ISSUE OF SPECIAL
ELECTIONS FOR THE TIME BEING, AND TO SET A SCHEDULE IN THE
FUTURE FOR THE FILING OF ANY MOTIONS FOR SPECIAL ELECTIONS,
AND INCORPORATED MEMORANDUM OF LAW

to be filed electronically with the Clerk of Court through ECF, and that ECF will send an e-
notice of the electronic filing to the following:

Carroll Rhodes, Esq. Clay Baldwin, Esq.

crhode@bellsouth.net clay@tru-law.com

Michael B. Wallace, Esq. Charles Stevens Seale, Esq.

mbw@wisecarter.com css@wisecarter.com

Robert B. McDuff, Esq. Cory T. Wilson, Esq.

rbm@mcdufflaw.com cory@wlglegal.com

Harold Pizetta, Esq. Justin L. Matheny, Esq.

hpizz@ago.state.ms.us jmath@ago.state.ms.us

Crystal Martin, Esq. R. Andrew Taggart, Jr.

cmartin@co.hinds.ms.us andy@tru-law.com

Jack L. Wilson, Esq. Stephen Lee Thomas, Esq.

jwilson@babc.com sthomas@babc.com

Robert L. Gibbs, Esq. Matthew W. Allen, Esq.

rgibbs@brunini.com mwallen@brunini.com

John F. Hawkins, Esq.

john@hsglawfirm.net

This 25th day of April, 2011.

___/s/ Samuel L. Begley____________________

Samuel L. Begley