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1 Motion for Leave to File Brief of Amici Curiae Election Cybersecurity Experts and Voting Rights Organizations in Support of Plaintiff's Motion for Preliminary Injunction and to File an Extended Memorandum [i] (2020)

handle is hein.brennan/bcjmlfl0001 and id is 1 raw text is: Franklin County Ohio Clerk of Courts of the Common Pleas- 2020 Aug 14 4:34 PM-20CV004997


                       THE  COURT   OF COMMON PLEAS
                          FRANKLIN   COUNTY,   OHIO

OHIO  DEMOCRATIC PARTY, ET AL.,         Case No: 20 CV 4997

            Plaintiffs,

V.                                      Judge: Stephen L. McIntosh

FRANK   LAROSE,  IN HIS OFFICIAL
CAPACITY AS OHIO SECRETARY OF STATE,

            Defendant.




                         MOTION   FOR  LEAVE  TO FILE
        BRIEF OF AMICI  CURIAE   ELECTION   CYBERSECURITY EXPERTS
                    AND  VOTING  RIGHTS   ORGANIZATIONS
    IN SUPPORT   OF PLAINTIFF'S  MOTION   FOR  PRELIMINARY INJUNCTION
                 AND  TO FILE  AN EXTENDED MEMORANDUM

      Proposed amici Dr. Dan Wallach, Dr. Juan E. Gilbert, Dr. J. Alex Halderman, Dr. Poorvi

L. Vora, Dr. Edward W. Felten, Dr. Douglas Jones, Dr. Ronald Rivest, and Dr. Matt Blaze

(together, the Cybersecurity Amici), in conjunction with proposed amici The Brennan Center

for Justice at New York University School of Law (the Brennan Center), the American Civil

Liberties Union of Ohio Foundation (ACLU of Ohio), and Northeast Ohio Voter Advocates

(NOVA)  (the Brennan Center, the ACLU of Ohio, and NOVA together are the Voting Rights

Organization Amici), move for leave to file the attached proposed amicus curiae brief. In

support of this motion, the Amici state as follows:

      1.    Cybersecurity Amici are a group of leading election security experts who have

advanced the security and integrity of election systems nationwide. Election officials regularly

rely on their research and knowledge to identify and address vulnerabilities in voting machines,

registration databases, and other election infrastructure. In response to challenges brought on by

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