Motion to Substitute Party (1)

Buckley, et al. v. New Hampshire Republican State Committee, et al., 04-E-0328 (Hillsborough, North, Nov. 28, 2006)

In response to the respondents' challenge to the standing of individual petitioners Buckley, Clemons, John and Jane Doe, the petitioners move to substitute the Manchester City Democratic Committee ("MCDC") as a party plaintiff for Buckley and Clemons, respectively. The petitioners assert that the respondents would suffer no prejudice as a result of a substitution because there would be no new facts, no new causes of action, and no surprise concerning the trial. In addition, the petitioners note that Buckley. MCDC's chairperson during the 2002 election, has already been deposed in this case. The NHRSC, RNC, and NRSC, joined by Tobin, object to the proposed substitution, arguing that the respondents would suffer prejudice as a result of such a substitution at this stage in the litigation.
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