WAYNE TURNER,            )
                         )
     Plaintiff,	         )
                         )
    v.                   )   Civil Action No. 0006077-98
                         )   Calendar 9
DISTRICT OF COLUMBIA     )   Judge Ellen Segal Huvelle
BOARD OF ELECTIONS       )   Next event:
    AND ETHICS           )   Initial Conference
                         )   November 13, 1998
    Defendant.           )

Pursuant to D.C. Code section 1-1320(e)(1), the Board hereby moves this Court to hear this matter on an expedited basis.

1. On August 11, 1998 all affected parties consented to

the relief sought.

2.The factual predicate and legal authority for this Motion are set out in the accompanying Memorandum of

Point Authorities.

WHEREFORE, This Court should grant the consent motion to hear this matter on an expedited basis.

RESPECTFULLY SUBMITTED,

(signed)
Kenneth McGhie #385313
General Counsel
D.C. Board of Elections & Ethics
One Judiciary Square
441 4th Street, #270
Washington, D.C. 20001
Telephone (202)727-2194

WAYNE TURNER,            )
                         )
     Plaintiff,	         )
                         )
    v.                   )   Civil Action No. 0006077-98
                         )   Calendar 9
DISTRICT OF COLUMBIA     )   Judge Ellen Segal Huvelle
BOARD OF ELECTIONS       )   Next event:
    AND ETHICS           )   Initial Conference
                         )   November 13, 1998
    Defendant.           )

Expedition in this matter is required by statute pursuant to D.C. Code section 1-1320(1) which states, in relevant part:

"If the Board refuses to accept an initiative or referendum petition when submitted to it, the person or persons submitting such petition may apply, within 10 days after the Board's refusal to accept such petition, to the Superior Court of the District of Columbia for a writ in the nature of mandamus to compel the Board to accept such petition. The Superior Court of the District of Columbia shall expedite the consideration of the matter..." (Emphasis added.)

In addition, an expedited decision as to whether to include Initiative Measure No. 59 on the November 3, 1998 General Election ballot is necessary in order to facilitate the actual printing of the election ballot.

The ballots are being produced by Sequoia Pacific Systems Corporation of Exeter, California under contract with the Board, at a cost of approximately $200,000. (Inclusion of an initiative measure could increase the cost by $30,000.) Production of the ballots involve artwork, plate work, printing, finishing, stitching, labeling, ID punching, packing and shipping, all according to the Board's commitment to the finalized ballot content.

Once printed, it is crucial that the ballots arrive at the Board sufficiently far in advance of the election to meet deadlines for election worker training, computer testing of the ballot tabulation system, ballot inspection and packing of polling place ballots, and issuance of absentee ballots to voters by mail.

The Board's deadline for finalization of the ballot in order to accomplish the above mentioned steps is September 17, 1998.

Wherefore, in light of the foregoing, Defendant's Motion To Expedite should be granted.

Dated: August 19, 1998

1) D.C. Code section 1-l320(l)

2) D.C. Code section 1-1320(h)(3)

3) D.C. Code section 1-1320(h)(2)(B)

4) Inherent Authority of the Court

I hereby certify that a copy of the foregoing Motion to Expedite was hand delivered this 19th day of August, 1998 to:

Matthew S. Watson, Esq.
1701 Q Street, N.W.
Washington, D.C. 20009

Alisa A. Wilkins
Gaffney & Schember, P.C.
1666 Connecticut Ave., N.W.
Suite 225
Washington, D.C. 20009