Page:Wood v. Raffensperger (1 20-cv-04651-SDG) (2020) Opinion and Order.pdf/4

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without the taint of the procedures described in the Litigation Settlement.[1]

For Count III, Wood requests an order, declaration, and/or injunction requiring Defendants to perform a myriad of activities, including ordering a second recount prior to the certification of the election results and permitting monitors designated by the Republican Party to have special access to observe all election activity.[2]

On November 17, 2020, Wood filed an emergency motion for a temporary restraining order.[3] Two sets of parties subsequently sought permission to intervene as defendants (collectively, the Intervenors): (1) the Democratic Party of Georgia, Inc. (DPG), DSCC, and DCCC; and (2) the Georgia State Conference of the NAACP (Georgia NAACP) and Georgia Coalition for the People’s Agenda (GCPA).[4] On November 19, Defendants and Intervenors filed separate responses in opposition to Wood’s motion for a temporary restraining order.[5] The Court held oral argument on Wood’s motion the same day. At the conclusion of the oral


  1. E.g., ECF 5, ¶¶ 81–83, 93–95. The Litigation Settlement—also referred to as the Settlement Agreement—is discussed infra in Section I.b.
  2. ECF 5, ¶ 106.
  3. ECF 6.
  4. ECF 8; ECF 22.
  5. ECF 31; ECF 34; ECF 39.