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We are writing on behalf of our clients, the Chicago Board of Election Commissioners and
Marisel A. Hernandez in her official capacity as Chairwoman of said Board (“CBEC”), for their
response to appellants’ petition for writ of certiorari, which was extended to August 29, 2018, by
order of court. The appellants are challenging, inter alia, federal and state laws governing the
voting rights of United States citizens who move to certain United States territories.
Pursuant to state statute, the CBEC is responsible for the management and administration
of elections in the City of Chicago. The CBEC does not create policy, but follows federal and
state law pertaining to elections, as interpreted from time to time by the courts, to ensure a
transparent, impartial and accurate election system. As such, CBEC has given notice to the Illinois
Attorney General of the appellants’ petition for writ of certiorari. As set forth in Illinois Supreme
Court Rule 19(c), the purpose of the notice provides the Attorney General “with the opportunity,
but not the obligation, to intervene in the cause or proceeding.” Illinois statute provides that the
Illinois Attorney General has the duty to appear for and represent the people of the State of Illinois
before the supreme court in all cases in which the State or the people of the State are interested.
15 ILCS 205/4: Duties of the Attorney General. The Illinois Attorney General has declined to
appear as the State of Illinois is not a named party in this proceeding.
To be clear, the CBEC takes no position on appellants’ petition for writ of certiorari.
However, if the court should require additional information, we will provide such information as
promptly as possible.
Respectfully,
REITER BURNS LLP
Attorneys for Chicago Board of Election
Commissioners
s/ Terrence M. Burns
Terrence M. Burns
Daniel M. Noland
Attorneys for Petitioners Luis Segovia, Jose Attorney for Karen Kinney in her official
Antonio Torres, Pamela Lynn Colon, Anthony capacity as Rock Island County Clerk
Bunten, and Lavonne Wise Patricia Castro
Geoffrey M. Wyatt Rock Island State's Attorney Office
Skadden, Arps, Slate, Meagher & Flom, LLP 210 15th Street
1440 New York Avenue, N.W. Rock Island, IL 61201
Washington, DC 20005 309-558-3232
202-371-7008 castrop@co.rock-island.il.us
geoffrey.wyatt@skadden.com