Case 3:11-cv-00159-CWR -FKB Document 54 Filed 04/08/11 Page 1 of 2

IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF MISSISSIPPI
JACKSON DIVISION

MISSISSIPPI STATE CONFERENCE OF THE PLAINTIFFS

NATIONAL ASSOCIATION FOR THE ADVANCEMENT OF
COLORED PEOPLE, THOMAS PLUNKETT, ROD WOULLARD,
and HOLLIS WATKINS, on behalf of themselves and all
others similarly situated

VS. CIVIL ACTION NO. 3:11CV- 00159-CWR-FKB

HALEY BARBOUR, in his official capacity as Governor of

The State of Mississippi, JIM HOOD, in his official capacity as
Attorney General of the State of Mississippi, and DELBERT HOSEMANN,
in his official capacity as Secretary of State of the State of Mississippi,
as members of the State Board of Election Commissioners;
THE MISSISSIPPI REPUBLICAN PARTY EXECUTIVE COMMITTEE;
THE MISSISSIPPI DEMOCRATIC PARTY EXECUTIVE COMMITTEE;
and CONNIE COCHRAN, in her official capacity as Chairman of the
Hinds County, Mississippi Board of Election Commissioners, on behalf of
Herself and all others similarly situated DEFENDANTS

and

APPORTIONMENT AND ELECTIONS COMMITTEE

OF THE MISSISSIPPI HOUSE OF REPRESENTATIVES INTERVENOR

RESPONSE OF COCHRAN TO SECRETARY OF STATE’S MOTION TO DISMISS

COMES NOW Defendant, Connie Cochran, in her official capacity as Chairman of the

Hinds County, Mississippi Board of Election Commissioners, on behalf of herself and all others

similarly situated, and responds to the Motion to Dismiss filed by Secretary of State Hoseman as

follows:

1. There exists sufficient facts and law in the record to enable the Court, in its

discretion, to render a decision on the Motion to Dismiss without further comment from this

Defendant. Defendant Cochran has no objection to a decision by the Court based upon the

pleadings filed by other parties to this action.

THIS the 8th day of April, 2011.

 Case 3:11-cv-00159-CWR -FKB Document 54 Filed 04/08/11 Page 2 of 2

Respectfully submitted,

CONNIE COCHRAN, IN HER OFFICIAL

CAPACITY AS CHAIRMAN OF THE
HINDS COUNTY, MISSISSIPPI BOARD
OF ELECTION COMMISSIONERS

By: /s/ Crystal Wise Martin_________

Crystal Wise Martin MSB#10860

Crystal Wise Martin

Board Attorney
Hinds County Board of Supervisors
P.O. Box 686
Jackson, Mississippi 39205-0686
Telephone: (601) 968-6797
Facsimile: (601) 968-6794
Email: cmartin@co.hinds.ms.us

CERTIFICATE OF SERVICE AND MAILING

I, Crystal W. Martin, hereby certify that I have this day filed electronically with the Clerk

of Court through CM/ECF system which will send notification of such filing to counsel of record

for all the following parties:

Carroll Edward Rhodes Samuel L. Begley

crhode@bellsouth.net sbegley@bellsouth.net

Jack L. Wilson Robert L. Gibbs

jwilson@babc.com rgibbs@brunini.com

Stephen Lee Thomas Michael B. Wallace

sthomas@babc.com mbw@wisecarter.com

Matthew W. Allen Robert B. McDuff

mwallen@brunini.com rbm@mcdufflaw.com

Charles Stevens Seale John F. Hawkins

css@wisecarter.com john@hsglawfirm.net

THIS the 8th day of April, 2011.

/s/Crystal Wise Martin

Crystal Wise Martin MSB#10860