Case 1:20-cv-03325-AT Document 43 Filed 05/05/20 Page 10 of 30 and (2) hold the presidential primary. The Court concludes, therefore, that Plaintiffs and Plaintiff-Intervenors have standing to bring this case. See Coal. for a Progressive New York v. Colon, 722 F. Supp. 990, 993 (S.D.N.Y. 1989) (“[A] candidate for Democratic Party nomination in the race for the 11th District Council seat, and . . . his campaign manager [who is also] a registered voter seeking to cast a primary ballot supporting [candidate’s] nomination, both possess the requisite standing to challenge [candidate’s] removal from the primary ballot.”). Defendants argue that Delegate Plaintiffs lack standing because “the Democratic [p]residential [p]rimary election would not actually have determined whether they would, in fact, serve as delegates” to the Convention. Def. Opp. at 12. It is true that the primary election does not, by itself, determine who will serve as delegates to the Convention. But the primary is a key component of the delegate selection process. Under current rules, a pledged delegate must be on the primary ballot in order to be eligible to compete for a slot at the Convention. See Delegate Selection Plan § II(A)(3) (“[A]ll pledged delegates and alternates shall be allocated among the [p]residential [c]andidates in proportion to the votes such [c]andidates receive in the [p]rimary.”). New York’s Democratic presidential primary is a head-to-head contest between candidates seeking the nomination of the Democratic Party. Brehm Decl. ¶ 32. In other words, voters are presented with a ballot that asks them to select their preferred candidate for the presidential nomination. But those votes do not lead directly to the selection of a nominee. Id. Instead, the primary votes are tallied and provided to the New York Democratic Party; then, through a complicated mathematical formula, the state Party determines how many delegates committed to each candidate should be sent to the Convention. Id. In essence, if a given 10

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