Clerk of the Superior Court

*** Electronically Filed ***

M. Bouise, Deputy
11/10/2020 9:04:39 AM
Filing ID 12202762
1
2
649 North Fourth Avenue, First Floor
3 Phoenix, Arizona 85003
4 (602) 382-4078
Kory Langhofer, Ariz. Bar No. 024722
5
kory@statecraftlaw.com
6 Thomas Basile, Ariz. Bar. No. 031150
tom@statecraftlaw.com
7
Attorneys for Petitioners
8
9 IN THE SUPERIOR COURT FOR THE STATE OF ARIZONA
10 IN AND FOR THE COUNTY OF MARICOPA
11 DONALD J. TRUMP FOR PRESIDENT, No. CV2020-014248
INC., et al.,
12 MOTION FOR ENTRY OF ORDER
Plaintiffs, PROTECTING CONFIDENTIAL
13 INFORMATION
v.
14 (Expedited Consideration Requested)
KATIE HOBBS, et al.,
15 (Before the Hon. Daniel Kiley)
Defendants, and
16
ARIZONA DEMOCRATIC PARTY,
17
Intervenor.
18

19 Pursuant to Arizona Rule of Civil Procedure 26(c), Plaintiffs move for entry of an
20 order to protect confidential and personally identifying information contained in the parties’
21 proposed exhibits. Pursuant to the Court’s order, the parties in this expedited election
22 challenge will imminently exchange copies of their proposed exhibits, including video
23 footage from inside a polling place (including voted ballots) and voluminous declarations
24 containing personally identifying information (i.e., names, addresses, full dates of birth,
25 partial SSNs, and signatures). Entry of a protective order, as well as an order sealing the
26 records when admitted into evidence, will allow full access to critically important
27
28
1
 1 evidentiary materials, while ensuring that the privacy of individual voters and witnesses is
2 appropriately safeguarded.
3 The County defendants object to this filing. Undersigned counsel has asked the
4 County defendants to explain the basis for that objection so that their concerns might be
5 accommodated, but counsel for the County defendants declined to offer a specific
6 explanation and said instead that the County would explain the basis for its objection in a
7 subsequent filing.
8 Given the imminent disclosure deadline and the urgent need to protect confidential
9 information and avoid identity theft for the hundreds of declarants in this matter, the
10 plaintiffs respectfully request an expedited hearing to resolve this issue.
11
12 RESPECTFULLY SUBMITTED this 10th day of November, 2020.
13
STATECRAFT PLLC
14
15 By: /s/ Kory Langhofer
Kory Langhofer
16 Thomas Basile
649 North Fourth Avenue, First Floor
17 Phoenix, Arizona 85003

18 Attorneys for Plaintiffs

19
20
21
22
23
24
25
26
27
28
2