On December 31, 2020 a
Motion-Secondary
was filed
involving a dispute between
Collins Joe E Iii,
and
County Of Los Angeles,
Logan Dean C,
Waters Maxine,
for Other Complaint (non-tort/non-complex) (General Jurisdiction)
in the District Court of Los Angeles County.
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Electronically FILED by Superior Court of California, County of Los Angeles on 08/13/2021 09:58 AM Sherri R. Carter, Executive Officer/Clerk of Court, by A. Miro,Deputy Clerk
1 Brian K. Stewart, Esq. (State Bar No. 126412)
Taylor J. Pohle, Esq. (State Bar No. 299794)
2 COLLINS + COLLINS LLP
3 790 E. Colorado Boulevard, Suite 600
Pasadena, CA 91101
4 (626) 243-1100 – FAX (626) 243-1111
Email: bstewart@ccllp.law Exempt from payment of filing fee
5 Email: tpohle@ccllp.law pursuant to Gov. Code § 6103
6 Attorneys for Defendants
7 DEAN C. LOGAN AND COUNTY OF LOS ANGELES
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 COUNTY OF LOS ANGELES — CENTRAL DISTRICT
10
11 JOE E. COLLINS III, CASE NO. 20STCV49928
[Assigned to Hon. Malcolm Mackey, Dept. 55]
12 Plaintiffs,
REPLY IN SUPPORT OF DEMURRER OF
13 vs. DEFENDANTS REGISTRAR-RECORDER /
14 COUNTY CLERK DEAN C. LOGAN AND THE
DEAN C. LOGAN, in his official capacity as COUNTY OF LOS ANGELES TO THE
15 Registrar of Voters for the County of Los COMPLAINT OF JOE E. COLLINS III
Angeles; MAXINE WATERS, an individual;
16 COUNTY OF LOS ANGELES, a Date: August 20, 2021
governmental entity; DOES 1 to 50, Time: 8:30 AM
17
Inclusive, Dept.: 55
18 Judge: Hon. Malcolm Mackey
Defendants.
19 Complaint Filed: 12/31/2020
Trial Date: None
20
21
I. INTRODUCTION
22
The factual allegations in the Complaint do not provide this Court any basis on which to
23
reasonably infer that Plaintiff could prove the Defendants’ alleged technical violations of the
24
Elections Code changed the results of the Subject Election. The Opposition makes no argument as
25
to how the alleged failure to verify signatures resulted in Congresswoman Maxine Waters receiving
26
over 120,000 more votes than Plaintiff. The Opposition makes no argument as to how the alleged
27
failure to include language on ballots unrelated to any congressional race resulted in Congresswoman
28
Maxine Waters receiving over 120,000 more votes than Plaintiff. Instead, the Opposition argues that
23110 – REPLY ISO DEMURRER
790 E. Colorado Boulevard
Suite 600 1
Pasadena, CA 91101
Phone (626) 243-1100
Fax (626) 243-1111
REPLY IN SUPPORT OF DEMURRER TO COMPLAINT OF JOE E. COLLINS III
Document Filed Date
August 13, 2021
Case Filing Date
December 31, 2020
Category
Other Complaint (non-tort/non-complex) (General Jurisdiction)
Status
Court-Ordered Dismissal - Other (Other) 09/16/2021
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Electronically FILED by Superior Court of California, County of Los Angeles on 08/13/2021 09:58 AM Sherri R. Carter, Executive Officer/Clerk of Court, by A. Miro,Deputy Clerk 1 Brian K. Stewart, Esq. (State Bar No. 126412) Taylor J. Pohle, Esq. (State Bar No. 299794) 2 COLLINS + COLLINS LLP 3 790 E. Colorado Boulevard, Suite 600 Pasadena, CA 91101 4 (626) 243-1100 – FAX (626) 243-1111 Email: bstewart@ccllp.law Exempt from payment of filing fee 5 Email: tpohle@ccllp.law pursuant to Gov. Code § 6103 6 Attorneys for Defendants 7 DEAN C. LOGAN AND COUNTY OF LOS ANGELES 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF LOS ANGELES — CENTRAL DISTRICT 10 11 JOE E. COLLINS III, CASE NO. 20STCV49928 [Assigned to Hon. Malcolm Mackey, Dept. 55] 12 Plaintiffs, REPLY IN SUPPORT OF DEMURRER OF 13 vs. DEFENDANTS REGISTRAR-RECORDER / 14 COUNTY CLERK DEAN C. LOGAN AND THE DEAN C. LOGAN, in his official capacity as COUNTY OF LOS ANGELES TO THE 15 Registrar of Voters for the County of Los COMPLAINT OF JOE E. COLLINS III Angeles; MAXINE WATERS, an individual; 16 COUNTY OF LOS ANGELES, a Date: August 20, 2021 governmental entity; DOES 1 to 50, Time: 8:30 AM 17 Inclusive, Dept.: 55 18 Judge: Hon. Malcolm Mackey Defendants. 19 Complaint Filed: 12/31/2020 Trial Date: None 20 21 I. INTRODUCTION 22 The factual allegations in the Complaint do not provide this Court any basis on which to 23 reasonably infer that Plaintiff could prove the Defendants’ alleged technical violations of the 24 Elections Code changed the results of the Subject Election. The Opposition makes no argument as 25 to how the alleged failure to verify signatures resulted in Congresswoman Maxine Waters receiving 26 over 120,000 more votes than Plaintiff. The Opposition makes no argument as to how the alleged 27 failure to include language on ballots unrelated to any congressional race resulted in Congresswoman 28 Maxine Waters receiving over 120,000 more votes than Plaintiff. Instead, the Opposition argues that 23110 – REPLY ISO DEMURRER 790 E. Colorado Boulevard Suite 600 1 Pasadena, CA 91101 Phone (626) 243-1100 Fax (626) 243-1111 REPLY IN SUPPORT OF DEMURRER TO COMPLAINT OF JOE E. COLLINS III