Case 3:22-cv-00211-SDD-SDJ Document 386 05/24/24 Page 1 of 3
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`UNITED STATES DISTRICT COURT
`MIDDLE DISTRICT OF LOUISIANA
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`PRESS ROBINSON, EDGAR CAGE,
`DOROTHY NAIRNE, EDWIN RENE
`SOULE, ALICE WASHINGTON, CLEE
`EARNEST LOWE, DAVANTE LEWIS,
`MARTHA DAVIS, AMBROSE SIMS,
`NATIONAL ASSOCIATION FOR THE
`ADVANCEMENT OF COLORED PEOPLE
`(“NAACP”) LOUISIANA STATE
`CONFERENCE, AND POWER COALITION
`FOR EQUITY AND JUSTICE,
` Plaintiffs,
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`v.
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`NANCY LANDRY, in her official capacity as
`Secretary of State for Louisiana,
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`Defendant.
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`Civil Action No. 3:22-cv-00211-SDD-RLB
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`EDWARD GALMON, SR., CIARA HART,
`NORRIS HENDERSON, TRAMELLE
`HOWARD,
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` Plaintiffs,
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`v.
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`NANCY LANDRY, in her official capacity as
`Secretary of State for Louisiana,
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` Defendant.
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` Civil Action No. 3:22-cv-00214-SDD-RLB
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`UNOPPOSED MOTION TO WITHDRAW GALMON PLAINTIFFS’ MOTION TO
`RECONSIDER DISMISSAL RULING AND TO SCHEDULE REMEDIAL
`PROCEEDINGS
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`Case 3:22-cv-00211-SDD-SDJ Document 386 05/24/24 Page 2 of 3
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`Edward Galmon, Sr., Ciara Hart, Norris Henderson, and Tramelle Howard (“Galmon
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`Plaintiffs”) respectfully move to withdraw their Motion to Reconsider Dismissal Ruling and to
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`Schedule Remedial Proceedings, ECF No. 372 (“Motion to Reconsider”).
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`This Court found in its Court’s April 25, 2024, ruling granting Defendants’ Motion to
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`Dismiss, ECF No. 371 (“Ruling”), that Plaintiffs’ injury was rendered moot by the Legislature’s
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`enactment of Senate Bill 8 (“S.B. 8”), a remedial congressional districting plan that cured
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`Plaintiffs’ injury by creating the second Black-opportunity district that Section 2 requires. See
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`Ruling at 8 (holding that, “with the state’s enactment of S.B. 8, there is currently no injury-in-
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`fact”). Plaintiffs originally opposed Defendants’ motion to dismiss based on the Callais lawsuit in
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`the Western District, where plaintiffs sought to enjoin S.B. 8 for the 2024 election. Galmon Pls.’
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`Opp’n to Mot. to Dismiss at 5, ECF No. 358 (“Plaintiffs fear that their voting rights will be denied
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`in the 2024 elections, which remain several months away.”); see also id. at 8–9 (arguing that
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`dismissal would “compound the irreparable harm that Plaintiffs already suffered in 2022 when
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`they voted in districts drawn in violation of Section 2, which is precisely what the Callais plaintiffs
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`have asked a sister court to order for 2024”). On May 1, Galmon Plaintiffs moved this Court to
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`reconsider that dismissal because, on April 30, the Western District of Louisiana permanently
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`enjoined S.B. 8, depriving Plaintiffs of their remedy and reanimating their injury. See Inj. &
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`Reasons for J., Callais v. Landry, No. 3:24-cv-00122-DCJ-CES-RRS (W.D. La. Apr. 30, 2024),
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`ECF No. 198 (“Inj.”).
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`On May 15, however, the Supreme Court stayed the Western District’s injunction pending
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`appeal, see Opinion, Robinson v. Callais, No. 23A994 and Landry v. Callais, No. 23A1002, 601
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`U.S. ___ (2024), which guarantees that S.B. 8 will remain in place—at the very least—for the
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`2024 congressional election. In line with this Court’s Ruling, the implementation of S.B. 8 and the
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`Case 3:22-cv-00211-SDD-SDJ Document 386 05/24/24 Page 3 of 3
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`guarantee that H.B. 1 will not be used in the 2024 congressional election remedies Plaintiffs’
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`injury. Ruling at 8. Therefore, Galmon Plaintiffs move to withdraw their Motion to Reconsider.
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`This motion is unopposed. Counsel for Galmon Plaintiffs requested and obtained consent
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`for the withdrawal of their Motion to Reconsider Dismissal Ruling and to Schedule Remedial
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`Proceedings from all parties.
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`Date: May 24, 2024
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`Respectfully submitted,
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`J. E. Cullens, Jr.
`Andrée Matherne Cullens
`S. Layne Lee
`WALTERS, THOMAS, CULLENS, LLC
`12345 Perkins Road, Bldg. One
`Baton Rouge, LA 70810
`(225) 236-3636
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`By: /s/Abha Khanna
`Abha Khanna (admitted pro hac vice)
`ELIAS LAW GROUP LLP
`1700 Seventh Ave. Suite 2100
`Seattle, Washington 98101
`(206) 656-0177
`akhanna@elias.law
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`Lalitha Madduri (admitted pro hac vice)
`Jacob D. Shelly (admitted pro hac vice)
`Daniel Cohen (admitted pro hac vice)
`Qizhou Ge (admitted pro hac vice)
`ELIAS LAW GROUP LLP
`250 Massachusetts Ave, NW Suite 400
`Washington, D.C. 20001
`(202) 968-4490
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`Counsel for Galmon Plaintiffs
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