barber response to tro 111014

8/10/2019 Barber Response to Tro 111014

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criteria

required

to

obtain

this extraordinary

relief,

especially

here

whete such

relief

would:

(l)

interfere with

the statutory

duties

and discretion

of

the

Pima County

Director

of Elections,

and

(2)

more

importantly,

would

improperly

elevate

what are,

at most,

technical

requirements

placed

on

election

day

poll workers over

the

true

object of

elections

under

Arizona

l1-((6

ascertain

a

free expression

of

the will

of

the

voters.

Territory

v.

Bd.

of

Sup'rs

of Mohave

Cnly.,2

ti2.248,

252-53,

12 P . 130,

732

(1557).

As a

result,

and detailed

further

below,

Plaintiff

s

request

for a

TRO, and

indeed,

her request

for

special

action

relief

in

its entirety,

must

be denied.

Factual

Background

At

the

heart of

Plaintiffs

complaint

and

request

for a

TRO is an

extremely

close

Congressional

election.

At

last check,

the

unofficial

margin

between

Republican

Martha

McSally

and

incumbent

Democratic

Congressman

Ron Barber

was 341

votes.

I

Provisional

ballot

verification

by

the Pima

County Recorder

(the Recorder )

has

ended, and

the

Pima

County

Director

of

Elections

(the

Director )

will

begin counting

those

ballots

(and

others)

today.

On November

8,

2074,

the

Republican

Party l}y'rartha

Mcsally

for

Congress

campaign

( McSally ) lodged

a

challenge

with the

Recorder

requesting

that

she

cease

the

process

of

verifying

provisional ballots

which

bear

the signature

of

the voter,

but

do not

also have

a

signature

of a

poll

worker

on the

provisional ballot

envelope.2

The

Campaign

unclerstands

that

several

hundred

ballots

may fall

into

this category,

and that

the

poll

workers

did

not

sign

provisional ballot

envelopes

in

most

precincts,

but

most notably,

Pima County

precincts

53,57,

58,80 100,113,and216.

In a series of emails

with Mcsally's

counsel, the

Recorder

indicated that

her

oflice

would

not stop

the verification

process as to this

category

of

provisional ballots.3

The

filing

of the

rizona Secretary

of

State's

Office, Unofficial

Election

Results,

available

at

c

WebOl/

See

E-mail

from

Eric Spencer

as

Exhibit

A

to

Pirna County

Recorder

F.

Ann

Roddguez,

Nov.

9,

2014,9;

47 AM

[attached

hereto

.See

E-mail from

Deputy

Pima

County

Recorder Chris

Roads

to

Eric

Spencer,

Nov

9,201410:05

AM

fsee

Exhibit

Al

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complaint

for

special

action

and request

for

TRO in this

case

followed.

Argumcnt

Just

one day

after

voters

all over

Arizonawent

to the

polls, and

when

confronted

with

the

reality of

another

close

election

in

Arizona's

Second

Congressional

District,

Martha

McSally

issued

a statement

explaining

that

while

the

democratic

process can be

slower

than

we want

at

times,

it's

critical

to make

sure

all

Arizonans

have

their

voices

heard,

and that

her

carnpaign

intendfed]

to make

sure

that

every

vote

is counted. 4

But the f,rling

of

this actiou

(by

McSally's

campaign

counsel,

no

less) evidences

that

Plaintiff

is

among

Mcsally's

supporters

who

do

not

agree.

Plaintiff

seeks

to invalidate

potentially several

hundred

on which

poll

workers,

for

whatever

reason, did

not sign

provisional ballot

envelopes.

This,

at best,

is the

very

definition

of

a technical

enor

in the

complicated

election

process, and

Plaintiffls

requested

relief

would

work

only

to

punish voters, who

otherwise

complied

with

all election

law

and

voting

requirements,

for

a

mistake

they did

not

make.

But

more fundamentally,

it

is not

an

error

at all because

the

signing

of

a provisional

ballot

envelope

by

a

poll

worker

is not

a

mandatory requirement

irnposed

by

Arizona's

comprehensive

statutory

scheme

governing

elections.

As a

result,

Plaintiff s

request is

as

misguided

as

it

is

political,

and

should

be

denied.

I.

PLAINTIFF

CANNOT

ESTAIILISH

ANY OF

THE

FOUR

CRITERIA

FOR

TI-IE

ENTRY

OF

A TEMPOIIARY

RESTRAINING

ORDER

Plaintiff

cannot

demonstrate

that he

is entitled

to

a TRO that

would

prevent Pima

County

from verifying

and

counting

the

ballots

in

question.

A

party

seeking

a

TRO-like

one seeking

a

preliminary injunction-must

establish

four

traditional

equitable

criteria :

1)

A strong

likelihood

that

he will

succeed at

trial

on the

merits;

2)

The

possibility of irreparable

injury

to

him not

remediable

by

dmages

if

the

requested

relief

is not

granted;

4

availqble

at

Bill

Hess

httu://www.

tng

in tabulating

CDS

race,

Siena

Vista

Flerald

Q''lov.

6,2014),

content/bill-hess/20

1

,

Slow

d.com/

a

J-

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3)

A

balance

of

hardships

favors

himself;

and

4) Public

policy favors the

injunction.

Shoenv.

Shoen,16l

riz.58,

63,

804 P.2d

787,792

(Ct.

App.

1990)

(citations

omitted).

A

court

applying this

standard

may apply

a sliding

scale,

under which

the

moving

pafty

may

establish

either

1)

probable

success

on the

merits

and

the

possibility

of

irreparable

injury;

or

2)

the

presence

of

serious

questions

and

[that]

'the

balance

of

hardships

tip[s]

sharply '

in

its

favor.

Smithv.

Ariz.

Citizens Clean

Elections Comm'n,212

Ari2.407,410-11

T

10,

l32P3d

lIB7,

1190-91

(2006).

Whatever the

standard,

Plaintiff cannot

prevail.

A. Plaintiff

Will

Not Succeed

on the Merits.

Plaintiff

cannot

(and

will

not) succeed

at a

trial

on the

merits

of

this action

because

his

claim

will fail as

a

matter

of

law

for

at least four separate reasons.

First, it is clear

from the

plain

language

of

the controlling statute

governing

the handling,

processing,

and

counting

of

provisional

ballots

that:

(1)

the

signature

of a

poll worker on a

provisional

ballot envelope

is not

required,

and

(2)

even

if a signature

were

required,

its

absence

would not

work

to invalidate a

voter's

otherwise-clear

expression

of her intent.

See

Bither

v.

Country

Mut. Ins. Co.,226 Ariz. 198,

200

T

8,245

P.3d 883, 885

(App.

2010)

( The

best

indication

of

legislative intent

is the

plain language of the statute. )

(citation omitted).

Indeed,

all

that the slatute contemplates

is that the

provisional

ballot,

once

voted,

be

placed

into an

envelope

and

then

verified

by election

officials

through a specilc

procedure:

On

completion

of

the

hllot,

the electiott

officil sltall

remove

tlte

bllot

stub,

sltll

place

the

bullot

in

a

provisionul ballot

envelope

and

shall deposit the envelope

in

the

ballot

box. Within ten

calendar days after a

general

election that

includes an

election

for

a

federal office

and

within

five business

days after any other

election

or

no

later than

the

time

at

which challenged

early

voting ballots are

resolved, the

signature

shall be compared

to the

precinct

signature

roster

of

the former

precinct where the voter was registered.

If

the

voter's name is not signed on

the roster and if there

is no

indication

that

the

voter voted an early

ballot, the

provisional

ballot

envelope

shall

be

opened and

the ballot sliall be counted.

If

there is

information

showing

the

person

did

vote, the

provisional

ballot

shall remain

unopened and

shall not

be counted. When

provisional

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ballots are

conf,rrmed

for

counting, the

county recorder shall

use the

information

supplied

on

the

provisional

ballot

envelope

to

correct

the

address

record

ofthe

voter.

A.R.S.

$

16-584(D)

(emphasis

added). And,

in

the

absence

of

eitl-rer

a

statutory

requirement or

statutory disqualification

of

a

ballot

on

these

grounds,

it is

not the

role

of the

judiciary

to

create

them. Cf Fish v.

Redeker,2 Ariz.

App.602,606,411

P.zd

40,44

(1966)

( This

Court

is

reluctant to deprive a successful

candidate

of the fruits of

an election

unless such

penalty

is

speciJiclly

setforth

by

statute. )

(emphasis added).

Second, Plaintiff

points

to

the following

language

in the

Arizona

Secretary

of

State's

Elections

Manual

(the

Manual ),s

which describes

the process

of handling

provisional

ballots:

'lhe

voter and the election

official

sign the

provisional

ballot

form See

Manual

aI

152.

Although

the Manual

does contain

this

language,

it

is not

cast

in a mandatory

form.

But

even if

it

were,

it

would be

trumped

by

a

later

provision

of

the Manual,

which

provides

that

provisional

ballots

shttll

be counteil'if:

(1)

the

registration

of the

voter is verified

and

the

voter is

eligible

to

vote in the

precinct,

and'

(2)

the

voter's signature

does

not

appear

on any on

any other

signature

roster

for that

election, and'

(3)

there is

no

record

that the

voter voted early

for

that

election.

,Se Manual at

185

(emphasis

added). And, the affidavit

on

the

provisional

ballot

envelope

is

sufficient

if

the

voter signs

it and

if

the signature

matches the signature

on the

voter's

registration

.

Id.

at

162.

Thus, even

if

the

language

relied

on

by

Plaintiff were mandatory

(which

it is not), it

cannot supersede

the statute

(A.R.S.

$

16-584) and the

Manual at

page

185,

particularly

considering

Arizona's

policy

under

which

votes

are

counted

absent

a

substantive

irregularity.

At

worst, there

is

an internal inconsistency

between two

provisions

of

the

Manual

and

the

authorizing

statute,

which

must be resolved in

favor of

the statute

and

the

provision

of

the

Manual

that is

virtually

identical to the

statute.

As

a

result,

the

signature

of a

poll

worker

(or

lack thereof)

has

notlting to do

witli the

validity

of

a

provisional

ballot

when

the scheme

prescribed

by the Manual

is

considered

in

its

S e e http

:

l

l

www,

azsos.

gov/election/Electronic

Voting

S

ystern/manual. pdf

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entirety

(as

it must).

Grant

v. Bd. of

Regents

of Universities & State

Colleges of

Ariz.,

133 Ariz.

527,

529,

652 P.2d 1374,

1376

(I9SZ) ( statutory

construction

requires that the

provisions of

a

statute be

read

and

construed in context

with

the

related

provisions

and

in light

of

its

place

in

the

statutory scheme ).

Above all, the

Manual says nothing

about

the disqualification

of

provisional

ballots

that lack the signature of

a

poll

worker

on the

envelope,

which is hardly surprising

given

that

'in

counting

the ballots, the determination

of the intent of

the

vs[s1 -11t

a

poll

worker's

technical compliance with the

Manual- is

the

question

of

primary

importance.

White

v.

De

Arman, 89

Ariz.

327, 328,

362 P.2d

122,

122

(1961) (citation

omitted)

Third, to the extent that

Arizona law

requires

that

poll

workers sign

provisional

ballot

envelopes, their failure

to

do so

is

a

technicality

that

cannot

work

to

deprive a voter

of

the

opportunity to make their voice

heard,

and

the

candidates

for whom they

voted the benefit

of their

support. Territory v.

Bd.

of Sup'rs

of Mohave

Cnty.,2 Ariz.248,252-53,

12P.730,732

(1887)

( It

is the object

of

elections to ascertain

a free expression

of

the

will

of the voters,

and no mere

irregularity

can

be

considered,

unless

it

be shown that the result

has

been affected

by

such

irregularity. );

Findley

v.

Sorenson,35

Ari2.265,269,276 P. 843, 844

(1929)

( honest

mistakes

or

mere

omissions

on

the

part

of the election offrcers, or irregularities in directory

matters,

even

though

gross,

if not fraudulent, will not

void an election,

unless they

affect the result, or at

least

render it uncedain. ).

Importantly,

the

most

recent Atizona authority

on

point

makes clear that votes

and

elections

will

be

voided only

in

the

case

of

substantive irregulaties, hardly the

case presented

here. Miller v.

Picacho Peak

School

District, 179 Ariz. 178,877 P.2d277

(1994).

In Miller,

voters in a school district

contested

the

results

of a

budget

override election

because

school

district employees had

been

closely

involved with the distribution and collection

of absentee

ballots, in

violation of

A.R.S. 16-542(B) which required that only electors may

possess

[absentee]

ballots. Id. at 178,

877 P.2d

at 277

. The

Supreme Courl held that

the

school

district

employees

had

violated

the

express

terms

of

a

non-technical statute,

that the

absentee

ballots in

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would

be

void as a

matter of

administrative

law.

Though

the

Manual

is

a

binding adrninistrative

rule,

A.R.S .

16-452,

but

like all

other

rules, it

should

not

be

inconsistent

with

or contrary

to

the

provisions

of a statute,

particularly the

statute

it seeks to

effectuate.

Ferguson

v. Arizona

Dep't

of

Econ.

Sec.,

722

Ariz.

290,292, 594

P.2d 544,546

(App.

1979).

To

construe

this

section

of

the

Manual

as

requiring

the disqualification

of ballots

based

on an honest

and innocent

poll

worker

error when

no

disqualification

mandate

is set

forth

in

the

authorizing

statute

(A.R.S.

$

l6-584(D))

would

be

inconsistent with the statutory

scheme,

and

undermine

a

strong

Arizona

policy

of

ensuring

that

elections ascertain

a

free

expression

of

the will

of

the

voters.

Territory,2

Ariz.

at

252-53,

12P. at732; see /so

Discussion at

p.

5,

supr

B.

Plaintiff Wilt

Not Suffer

Irreparable

Harm if Relief

is

Not Granted.

Beyond

Plaintiffls

inability

to demonstrate

that he

will

succeed

on the

rnerits at

trial, he

also cannot

establish that he

would

sustain

irreparable

harm

absent

the

entry

of

a

TRO.

If

the

provisional

ballots

at

issue here

are

counted and

ultimately affect

the

outcome

of the

election,

Plaintiff

clearly

has

a

statutory

remedy through

an

election

contest

brought

pursuant

to

A.R.S.

$

16-672. That statute

clearly

provides

that

any

elector

may contest the

election of

any

person

declared

elected to a state

offrce for, among other things, the counting

of

illegal votes. A.R.S,

16-672(^)(4).

That

is

precisely

the

procedure

followed in

Mille. Because

the

legislature

has

plovided

Plaintiff with

an adequate

remedy

at

law

that

is not

yet

ripe, he

will

not sustain

irreparable injury

if

he

does not obtain

its requested

TRO.

C.

The

Balance of

l{ardships

Favors the

Non-Moving Parfy.

In weighing

the

balance of

hardships,

there

is no

doubt thal

a

TRO

preventing elections

officials

from

oounting

the disputed

provisional

ballots

would

harm the Carnpaign

and

those

who

potentially

cast

ballots in

Congressman

Barber's favor. Among

other things,

granting

Plaintiff

his

requested relief

rnay

ultimately deny

the

Campaign

its

right to an automatic recount.

This

could

occur if

not counting

the

disputed

provisional

ballots would bring the

spread between

the

candidates to

greater

than

one-tenth of one

percent,

the

trigger for

such a recount

under Arizona

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law.

,See A.R.S.

$

16-661.

In contrast,

the Plaintiff and

his

efforts

to invalidate

those ballots

would

not be

adversely affected

by

the denial

of

its

requested

TRO.

D.

The Public Interest

Favors the

Counting

of

All

Ballots.

Above

all,

the

public

interest

does

not favor

punishing

voters for a mistake

they

did

not

make,

or

casting aside

several hundred

otherwise-valid

provisional

ballots as

a

result

of

an

invented

technicality that has no basis

in Arizona law.

To

the

contrary,

those

ballots

must le

counted

consistent with

the constitutional significance

of

the

act of

participation

in the

political

process.

See Burdiclc

v.

Takushi, 504

U.S.

428,

433

(It

is

beyond

cavil

that

voting

is

of

the

most

fundamental

significance under our

constitutional structure. )

(citation

and

internal

quotation

marks

omitted);

Wesberry v. Sanders,376

U.S. l,17

(1964)

( No

right is

more

precious

in

a

ee

country than that

of

having

a

voice

in

the election

of those

who

make

the laws

under

which, as

good

citizens, we

must live. Other rights,

even the

most

basic,

are

illusory

if

the

right to

vote

is

undermined. ). The Court should not interfere with the

process

of counting all valid ballots

and

permitting

elections

officials to fulfill their

statutory

duties to

perform

a

full

canvass

of

the

votes

that can later be certified

by

the Board of Supervisors.

Conclusion

For the

foregoing

reasons, the Campaign respectfully request

that

the

Court

deny

Plaintifls

request

for a temporary restraining

order

in this

matter.

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11/16


12/16


13/16

Gaona,

D.

Andrew

(Perkins

Coie)

From:

Sent:

To:

F. Ann Rodriguez

Sunday,

November

09,2014

1l-:45 AM

Spencer,

Eric; Chris J

Roads; [email protected];

Barr, Daniel

(Perkins

Coie);

Gaona,

D. Andrew

(Perkins

Coie)

Recorder-admin;

[email protected];

[email protected]'gov;

Tweeten,

Carlie; Jenkins,

Amanda;

[email protected];

Chris

Straub

RE:

Challenge to

Provisional

Ballot Forms

With

Missing

Election

Official

Signature

Cc

Subject:

Eric,

I

believe we have already

answered

you

on this

matterfully.

I

believe the emails crossed

that Mr.

Roads

sent

and

then

we received this email.

We

are

proceeding

as

planned

and explained

in other emails

I

have already

given

the

attorneys

that

are

here representing

both

candidates

the below

report verbally on

our

progress

for

Provisional

Ballots at approximately

11:30

a.m,

Completed

first

checks done

9,254

Completed 2nd checl


14/16

Fric l-1.

Spencer

Snell &

Wilmer

L.L.P.

One

Arizona

Center

Phoenix,

Arizona

B5OO4-2202

Office: 602.382.6573

[email protected]

www.swlaw.com/eric_spencer

n:li

,\iilntut

Denver, Las Vegas, Los Angeles, Los Cabos, Orange

County, Phoenix, Reno, Salt Lake City, Tucson

From:

Spencer, Eric

Sentr Sunday, November 09,2014 10:21 AM

To:

'Chris

J

Roads';

F.

Ann Rodriguez; [email protected]

Cc: Recorder-admin;

[email protected]; [email protected];

Tweeten,

Carlie; Jenkins, Amanda;

[email protected]

Subject:

RE:

Challenge

to

Provisional

Ballot

Forms

With Missing Election Official Signature

Importance:

High

Mr. Roads,

Thank

you

for

your

response.

However,

I

do

not

believe

that

your

response

directly

addressed

the

issues

raised in

our

cha

llenge.

First, I

would

like

to

clarify

the

response

time horizon.

The

campaign

merely asked for confirmation within

30

minutes

that the

recorder's office

and elections

department

intended to implement

the

requested

protective

measures.

The

campaign certainly did not expect the identification, collection and embargo

process

to be

completed

within

30

minutes

Second,

the

campaign dd not request

that

a//

provisional

ballot

processng

cease

altogether,

s

your

response appears

to assume. With

respect

to the

recorder's

office, the

campaign

requested:

1.

That

any/ulure

provisional

ballot found with a missing signature be rejected

as

unverified,

and set aside

pending

a

legal

review.

This universe could end up being

quite

small.

2.

That

the

recorder's

office,

n

conjunction

with

political

party

observers, conduct

a

review of

previously-verified

provisional

ballots

before those ballots

are

transmitted to the

elections

department.

This

strikes

me as a

very

reasonable

and limited

request

that

will not impede

your

office's statutory

processing

deadlines. Once

the

ballots in

question

are

segregated,

which again

-

could

be a

quite

limited

universe

-

the

parties

can

make

a

final

legal determination.

To confirm,

the campaign is not requesting thatthe recorder's office

cease

processingvalid provisional

ballots.

ln

light

of

these clarifications, and

in

order

to

preclude

the

parties

from

having to

unnecessarily

seek

special action

relief

in Superior

Court,

please

confirm

whether

the recorder's

will implement

these

targeted

protectve

measures,,

Very

truly

yours,

Eric

Spencer

Erc

H.

Spencer

2


15/16

Snell &

Wilmer

L.L.P.

One

Arizona

Center

Phoenix,

Arizona 85004-2202

Office: 602.382.6573

[email protected]

www.swlaw.com/eric-spencer

Snrll

\ilrnt

Denver,

Las

Vegas,

Los

Angeles,

Los

Cabos,

Orange

County,

Phoenix,

Reno,

Salt

Lake City,

Tucson

From: Chris J

Roads

l-mailto:Chris.Roa

l

Sent: Sunday,

November

09,

2014 10:05

AM

To:

Spencer, Eric;

F,

Ann Rodriguez; [email protected]

Cc: Recorder-admin;

Mary,Martinson@pima,gov;

Daniel,[email protected];

Tweeten,

Carlie;

Jenkins,

Amanda;

[email protected]

Subject:

RE:

Challenge

to

Provisional

Ballot

Forms With

Missing

Election Official

Signature

Mr. Spencer,

ln response

to

your

challenge,

the Pima County

Recorder's

Office

will

not stop

processing the

provisional

ballots. Whetherornotthepoll

workersignedtheprovisional

isclearlyidentifiablefromasmpleexaminationofthe

provisional

ballot

form

whether or not the

provisional is

processed

by the

Recorder's

Office. Therefore

our

processing

has

no bearing

as to

your

challenge.

ln

other words,

the fact that

we

processed

the

provisional form

will

not

impact

your

abilityto

proceed

with

your challenge.

The Recorder's Office

is

under

a

statutory

deadline

to

complete

processing

the

provisional

ballots

and

we

will

continue to

proceed toward meeting that

deadline.

Please

note

that

your

extremely

short deadlines

for

responses

are unreasonable.

Under

Arizona

law we

have

a

reasonable

time to respond to

public records requests

and

other

matters.

A

deadline

of

less

than 30

minutes

is far

less

than

reasonable.

Both

candidates

have attorneys

on site in our office

observing

our

processes

and

tracking the

work

we are doing

Chris

Roads

Chief

Deputy Recorder/Registrar

of Voters

Pima

County

Recorder's Office

From

:

Spencer,

Eric

Imailto:

[email protected]]

Sent:

Sunday, November

9,20L4 9:47

AM

To:

F.

Ann Rodriguez;

[email protected]

Cc: Recorder-admin;

Marv.Martinson@pima,gov;

[email protected];

Tweeten,

Carlie; Jenkins,

Amanda;

[email protected]

Subject:

Challenge

to Provisional

Ballot

Forms

With Missing

Election Official

Signature

Importance: High

Ms. Rodriguez and

Mr.

Nelson,

The

Republican

Party/McSally

for Congress campaign

(collectively

the

campaign ) formally

challenges

the validity

of

all

provisional

ballots

that have

a

provisional

ballot

form

with

a missing

election

official

signature.

3


16/16

Page

152 of

the Secretary of State's

Election Procedures

Manual

states

that,

priorto voting a

provisional

ballot:

An

election official or

voter completes

a

provisional

ballot

form.

The

voter and

the election

official

sien the

provisional

ballot

form.

After

voting the

ballot, [t]he

voter

will

return the

sealed envelope

to

the election

official,

who

will verify the envelope

s

properly

filled

out,

signed and

sealed.

/d.

Accordingly,

the campaign

respectfully

requests the

following immediate

relief:

The recorder's

office instruct

staff

to

not

verify any

provisional

ballots

with a

missing

election

official

signature

on

the

provisional

ballot

form;

The

recorder's

office

cease

transmitting any

prevously-verified

provisional

ballots

to

the

elections

department,

pending

a

review of

the

provisional

ballot forms

for

missing

election official

signatures;

The elections department

cease

processing any

provisional

ballots

ortransmtting any

provisional

ballots

for

counting,

pending

a

review of

the

provisional

ballot forms

for

missing election

official signatures;

and

The recorder's office

and elections

department

collect

and embargo any

provisional

ballots

that

contain

a

provisional

ballot

form

with missing

election official

signatures,

pending

a final

legal

review and

determination

in

conjunction

with

the County

Attorney's office.

Given

the exigency

of ths

matter,

please

confirm

by

1-0:L5

a.m.

that the recorder's office

and

elections

department

will

immediately

implement these

prophylactic

procedures.

Very

truly

yours,

Eric

Spencer

Eric H.

Spencer

Snell &

Wilmer

L.L.P.

One Arizona Center

Phoenix, Arizona

85004-2202

Office: 602.382.6573

[email protected]

www.swlaw.com/eric-spencer

tnsll

c\Siilnrr

Denver, Las

Vegas, Los

Angeles,

Los Cabos,

Orange

County,

Phoenix,

Reno,

Salt

Lake City,

Tucson

a

4

barber response to tro 111014

Documents