Case 2:19-cv-13638-DML-MJH ECF No. 17 filed 02/10/20 PageID.316 Page 1 of 23 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION PUBLIC INTEREST LEGAL Case No. 19-13638 FOUNDATION, Hon. David M. Lawson Mag, Judge Michael J. Plaintiff, Hluchaniuk v JANICE M. WINFREY, in her official Capacity as Detroit City Clerk, and GEORGE AZZOUZ, in his official capacity as Director Of Elections for the City of Detroit, Defendants. DICKINSON WRIGHT PLLC CITY OF DETROIT LAW DEPARTMENT By: Robert L. Ayers (P75396) By: ERIC B. GAABO (P39213)
[email protected] [email protected] 300 S. Main Street, Suit 300 Attorneys for Defendants Ann Arbor, MI 48104 Coleman A. Young Municipal Center (734) 623-1672 2 Woodward Avenue, 5th Floor Attorneys for Plaintiff Detroit, MI 48226 (313) 237-3052 PUBLIC INTEREST LEGAL FOUNDATION By: Kaylan L. Phillips
[email protected] 32 E. Washington St., Suite 1675 Indianapolis, IN 46204 (317) 203-5599 Attorneys for Plaintiff DEFENDANTS’ FIRST AMENDED ANSWER AND AFFIRMATIVE DEFENSES TO COMPLAINT ANSWER TO COMPLAINT Defendants, Janice M. Winfrey, in her official capacity as Detroit City Clerk, and George Azzouz, in his official capacity as Detroit Director of Elections, 1 K:\DOCS\LIT\GAABE\A41000\ANSWER\EG6057.WPD Case 2:19-cv-13638-DML-MJH ECF No. 17 filed 02/10/20 PageID.317 Page 2 of 23 answer the Complaint filed by Plaintiff, Public Interest Legal Foundation (PILF”), as follows: JURISDICTION AND VENUE 1. Defendants admit the allegations contained in paragraph 1. 2. In response to paragraph 2, Defendants deny that many of the events or omissions alleged by Plaintiff in its Complaint occurred, because this is untrue.