Supreme Court of Pennsylvania Middle District 159 MM 2017 LE
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1 Received 2/15/2018 7:47:45 PM Supreme Court Middle District Filed 2/15/2018 7:47:00 PM Supreme Court Middle District 159 MM 2017 IN THE Supreme Court of Pennsylvania Middle District 159 MM 2017 LE LEAGUE OF WOMEN VOTERS OF PENNSYLVANIA, ET AL., Petitioners, v. THE COMMONWEALTH OF PENNSYLVANIA, ET AL., Respondents. On Appeal from the Commonwealth Court of Pennsylvania at No. 261 MD 2017 APPLICATION FOR LEAVE TO FILE AN AMICUS BRIEF IN RESPONSE TO THE CONGRESSIONAL MAP PROPOSED BY PRESIDENT PRO TEMPORE JOSEPH B. SCARNATI, III AND SPEAKER MICHAEL C. TURZAI BY AMICUS BRIEF BY AMICUS CURIAE CONCERNED CITIZENS FOR DEMOCRACY BRIAN A. GORDON (I.D. NO ) GORDON & ASHWORTH, P.C. 1 Belmont Avenue, Suite 519 (610) Counsel for Amicus Curiae Concerned Citizens for Democracy 1
2 Amicus Curiae Concerned Citizens for Democracy respectfully requests leave to file a second amicus brief in this matter. Concerned Citizens for Democracy (CCFD) is a think-tank composed of lawyers, computer scientists, and engineers dedicated to developing non-partisan, judicially-manageable standards for redistricting in Pennsylvania. 1 This brief responds to the Proposed Congressional Map and Brief filed by Senate President Pro Tempore Joseph B. Scarnati and the Speaker of the House Michael C. Turzai on February 9, 2018 and adds new ideas and insights about redistricting process not previously presented to the Court. We believe this brief will aid the Court and the parties by: (1) Demonstrating how the Court s criteria for redistricting can be applied to detect and reject more subtle forms of gerrymandering as demonstrated by the proposed Scarnati-Turzai Map. (2) Demonstrating how the Court s criteria for redistricting can be applied to remedy a partisan Congressional map. 1 CCFD is a non-profit unincorporated association organized under the laws of Pennsylvania pursuant to 15 P.S et seq. Since February of 2017, CCFD has been studying the same criteria for Congressional redistricting recognized by this Court on January 22, A similar set of criteria, based on Article II, Section 16 of the Pa Constitution was presented by CCFD s expert Anne Hanna in the matter of Agre v. Wolf, USDC EDPA No
3 (3) Explaining the importance of strictly applying the Court s criteria for redistricting in order to maintain a judicially manageable standard to evaluate proposed maps. We appreciate the opportunity to contribute to this important topic. The health of our democracy depends on the successful resolution of this issue. Respectfully submitted, /s/ Brian A. Gordon Brian A. Gordon Gordon & Ashworth, P.C. 1 Belmont Ave., Suite 519 (610) Attorney for Concerned Citizens for Democracy 3
4 CERTIFICATE OF SERVICE I, the undersigned, certify that a true and correct copy of the foregoing Analysis of the Proposed Remedial Map by Legislative Respondents by Amicus Curiae Concerned Citizens for Democracy was served upon all counsel of record, via electronic service, on this date. February 15, 2018 /s/ Brian A. Gordon BRIAN A. GORDON (I.D. NO ) GORDON & ASHWORTH, P.C. 1 Belmont Avenue, Suite 519 (610) Counsel for Amicus Curiae Concerned Citizens for Democracy 4
5 Received 2/15/2018 7:47:45 PM Supreme Court Middle District GORDON & ASHWORTH, PC GSB Building, Suite 519 One Belmont Avenue Tel: (610) Fax: (610) Filed 2/15/2018 7:47:00 PM Supreme Court Middle District 159 MM 2017 Brian A. Gordon Member PA and NJ Bars February 15, 2018 Supreme Court of Pennsylvania Middle District 601 Commonwealth Ave., Suite 4500 Harrisburg, PA Via electronic filing through PACfile Re: League of Women Voters, et al. v. Commonwealth of PA, et al. Supreme Court of Pennsylvania - Middle District 159 MM 2017 LE and 261 MD 2071 Dear Justices: I am pleased to enclose an Application for Leave to File a Brief on Behalf of Amicus Curiae Concerned Citizens for Democracy. The brief responds to the proposed map and brief submitted by Senate President Pro Tempore Scarnati and Speaker of the House Turzai on February 9, This brief also addresses the feasibility and importance of strictly adhering to the Court s neutral redistricting criteria and the subordination of other policies and objectives to those criteria. Fifteen copies of this Petition and Brief will be separately mailed to the Clerk of the Court. Thank you for your careful attention to this important matter. Yours sincerely, /s/ Brian A. Gordon
6 Brian A. Gordon Cc: All Counsel through PACER electronic filing
Supreme Court of Pennsylvania Middle District 159 MM 2017 LE
IN THE Supreme Court of Pennsylvania Middle District 159 MM 2017 LE LEAGUE OF WOMEN VOTERS OF PENNSYLVANIA, ET AL., Petitioners, v. THE COMMONWEALTH OF PENNSYLVANIA, ET AL., Respondents. On Appeal from
In the Supreme Court of Pennsylvania Middle District
Received 2/4/2018 9:16:44 PM Supreme Court Middle District In the Supreme Court of Pennsylvania Middle District No. 159 MM 2017 LEAGUE OF WOMEN VOTERS OF PENNSYLVANIA et al., Petitioners, v. Filed 2/4/2018
Supreme Court of Pennsylvania Middle District 159 MM 2017 LE
FILED 2/19/2018 Supreme Court Middle District IN THE Supreme Court of Pennsylvania Middle District 159 MM 2017 LE LEAGUE OF WOMEN VOTERS OF PENNSYLVANIA, CARMEN FEBO SAN MIGUEL,JAMES SOLOMON, JOHN GREINER,
Case 2:17-cv MMB Document 21 Filed 11/16/17 Page 1 of 4 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA
Case 217-cv-05137-MMB Document 21 Filed 11/16/17 Page 1 of 4 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA LEAGUE OF WOMEN VOTERS OF PENNSYLVANIA, et al., Plaintiffs, v.
Supreme Court of Pennsylvania Middle District 159 MM 2017 LE
Received 2/4/2018 2:49:25 PM Supreme Court Middle District Filed 2/4/2018 2:49:00 PM Supreme Court Middle District 159 MM 2017 IN THE Supreme Court of Pennsylvania Middle District 159 MM 2017 LE LEAGUE
Case 2:17-cv MMB Document 148 Filed 11/29/17 Page 1 of 10 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA
Case 2:17-cv-04392-MMB Document 148 Filed 11/29/17 Page 1 of 10 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA Louis Agre, William Ewing, ) Floyd Montgomery, Joy Montgomery,
[PROPOSED] ORDER. LEAGUE OF WOMEN VOTERS OF PENNSYLVANIA, et al., Petitioners, COMMONWEALTH OF
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Received 8/10/2017 5:23:57 PM Commonwealth Court of Pennsylvania Filed 8/10/2017 5:23:00 PM Commonwealth Court of Pennsylvania 261 MD 2017 IN THE COMMONWEALTH COURT OF PENNSYLVANIA LEAGUE OF WOMEN VOTERS
[PROPOSED] ORDER IN THE COMMONWEALTH COURT OF PENNSYLVANIA. League of Women Voters of Pennsylvania, et al., ) Petitioners, )
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Received 12/10/2017 11:43:42 AM Commonwealth Court of Pennsylvania Filed 12/10/2017 11:43:00 AM Commonwealth Court of Pennsylvania 261 Mu 2017 IN THE COMMONWEALTH COURT OF PENNSYLVANIA League of Women
IN THE COMMONWEALTH COURT OF PENNSYLVANIA
Received 9/8/2017 1:54:41 PM Commonwealth Court of Pennsylvania Filed 9/8/2017 1:54:00 PM Commonwealth Court of Pennsylvania 261 MD 2017 IN THE COMMONWEALTH COURT OF PENNSYLVANIA League of Women Voters
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[J-1-2018] IN THE SUPREME COURT OF PENNSYLVANIA MIDDLE DISTRICT LEAGUE OF WOMEN VOTERS OF PENNSYLVANIA, CARMEN FEBO SAN MIGUEL, JAMES SOLOMON, JOHN GREINER, JOHN CAPOWSKI, GRETCHEN BRANDT, THOMAS RENTSCHLER,
TESTIMONY BY BRIAN A. GORDON ON BEHALF OF CONCERNED CITIZENS FOR DEMOCRACY A METHODOLOGY FOR REDISTRICTING TO END PARTISAN GERRYMANDERING
BEFORE THE SENATE STATE GOVERNMENT COMMITTEE OF THE COMMONWEALTH OF PENNSYLVANIA REVISED FOR APRIL 24, 2018 HEARING TESTIMONY BY BRIAN A. GORDON ON BEHALF OF CONCERNED CITIZENS FOR DEMOCRACY A METHODOLOGY
IN THE COMMONWEALTH COURT OF PENNSYLVANIA
Received 9/12/2017 10:09:38 PM Commonwealth Court of Pennsylvania Filed 9/12/2017 10:09:00 PM Commonwealth Court of Pennsylvania 261 MD 2017 IN THE COMMONWEALTH COURT OF PENNSYLVANIA League of Women Voters
IN THE COMMONWEALTH COURT OF PENNSYLVANIA
Received 9/28/2017 9:57:38 PM Commonwealth Court of Pennsylvania Filed 9/28/2017 9:57:00 PM Commonwealth Court of Pennsylvania 261 MD 2017 IN THE COMMONWEALTH COURT OF PENNSYLVANIA League of Women Voters
UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA
Case 118-cv-00443-CCC-KAJ-JBS Document 99 Filed 03/05/18 Page 1 of 10 UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA JACOB CORMAN, in his official capacity as Majority Leader of the
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Received 8/23/2017 13748 PM Commonwealth Court of Pennsylvania Filed 8/23/2017 13700 PM Commonwealth Court of Pennsylvania 261 MD 2017 IN THE COMMONWEALTH COURT OF PENNSYLVANIA LEAGUE OF WOMEN VOTERS OF
Received 12/11/2017 1:09:09 AM Commonwealth Court of Pennsylvania. Petitioners, ) Respondents. ) PROPOSED ORDER
Received 12/11/2017 1:09:09 AM Commonwealth Court of Pennsylvania Filed 12/11/2017 1:09:00 AM Commonwealth Court of Pennsylvania 261 MD 2017 IN THE COMMONWEALTH COURT OF PENNSYLVANIA League of Women Voters
IN THE COMMONWEALTH COURT OF PENNSYLVANIA
Received 9/7/2017 4:06:58 PM Commonwealth Court of Pennsylvania IN THE COMMONWEALTH COURT OF PENNSYLVANIA League of Women Voters of Pennsylvania, et al., Petitioners, No. 261 MD 2017 v. The Commonwealth
IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA
Case 118-cv-00443-CCC-KAJ-JBS Document 38 Filed 02/27/18 Page 1 of 17 IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA JACOB CORMAN, et al., Plaintiffs, v. ROBERT TORRES, et
IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA
Case 1:18-cv-00443-CCC-KAJ-JBS Document 79 Filed 03/02/18 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA JACOB CORMAN, et al., : : Plaintiffs, : : v. : : ROBERT
IN THE COMMONWEALTH COURT OF PENNSYLVANIA
Received 11/20/2017 3:22:10 PM Commonwealth Court of Pennsylvania David P. Gersch 601 Massachusetts Ave., NW Washington, DC 20001-3743 Mary M. McKenzie Attorney ID No. 47434 PUBLIC INTEREST LAW CENTER
IN THE COMMONWEALTH COURT OF PENNSYLVANIA
Received 8/18/2017 112212 AM Commonwealth Court of Pennsylvania IN THE COMMONWEALTH COURT OF PENNSYLVANIA League of Women Voters of Pennsylvania, et al, No. 261 MD 2017 Petitioners, v. Electronically Filed
No. 17A909. In The Supreme Court of the United States
No. 17A909 In The Supreme Court of the United States Michael C. Turzai, in his capacity as Speaker of the Pennsylvania House of Representatives, and Joseph B. Scarnati III, in his capacity as Pennsylvania
IN THE COMMONWEALTH COURT OF PENNSYLVANIA
Received 8/9/2017 5:16:16 PM Commonwealth Court of Pennsylvania Filed 8/9/2017 5:16:00 PM Commonwealth Court of Pennsylvania 261 MD 2017 IN THE COMMONWEALTH COURT OF PENNSYLVANIA BLANK ROME LLP Brian S.
BEFORE THE SUPREME COURT OF PENNSYLVANIA MIDDLE DISTRICT
BEFORE THE SUPREME COURT OF PENNSYLVANIA MIDDLE DISTRICT JOSH SHAPIRO, LESLIE RICHARDS, DAYLIN LEACH, SAMUEL ADENBAUM, : IRA TACKEL, MARCEL GROEN, HARVEY : GLICKMAN, and DAVID DORMONT : No. Petitioners,
In the Supreme Court of the United States
No. 17A909 In the Supreme Court of the United States Michael C. Turzai, in his capacity as Speaker of the Pennsylvania House of Representatives, and Joseph B. Scarnati III, in his capacity as Pennsylvania
Case 2:17-cv MMB Document Filed 12/06/17 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA
Case 217-cv-04392-MMB Document 185-1 Filed 12/06/17 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA Louis Agre et al., Plaintiffs, v. Thomas W. Wolf et al., Defendants.
IN THE COMMONWEALTH COURT OF PENNSYLVANIA
Received 9/19/2018 3:57:40 PM Commonwealth Court of Pennsylvania IN THE COMMONWEALTH COURT OF PENNSYLVANIA William Penn School District; Panther Valley School District; The School District of Lancaster;
No. 17A795. In The Supreme Court of the United States
No. 17A795 In The Supreme Court of the United States Michael C. Turzai, in his capacity as Speaker of the Pennsylvania House of Representatives, et al., Applicants, v. League of Women Voters of Pennsylvania,
IN THE COMMONWEALTH COURT OF PENNSYLVANIA. [NAME OF PETITIONER] Petitioner. COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF PUBLIC WELFARE, Respondent
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[SEE PA. R.A.P. (42 PA. C.S.A.) 1501, et. seq. Judicial Review of Governmental Determinations and also 121 124, Relating to Form of Documents and number of copies. IN THE COMMONWEALTH COURT OF PENNSYLVANIA
Received 8/9/2017 5:16:16 PM Commonwealth Court of Pennsylvania. Filed 8/9/2017 5:16:00 PM Commonwealth Court of Pennsylvania 261 MD 2017
Received 8/9/2017 5:16:16 PM Commonwealth Court of Pennsylvania IN THE COMMONWEALTH COURT OF PENNSYLVANIA BLANK ROME LLP Brian S. Paszamant (PA ID # 78410) Jason A. Snyderman (PA ID # 80239) John P. Wixted
Docket Number: P
Via Electronic Filing Rosemary Chiavetta, Secretary Pennsylvania Public Utility Commission P.O. Box 3265 Harrisburg, PA 17105-3265 May 1, 2018 Voice: 610.430.8000 Fax: 610.692.6210 vpompo@lambmcerlane.com
IN THE COMMONWEALTH COURT OF PENNSYLVANIA
Received 12/18/2017 8:56:41 AM Commonwealth Court of Pennsylvania Mark A. Aronchick (ID No. 20261) Michele D. Hangley (ID No. 82779) Claudia De Palma (ID No. 320136) Ashton R. Lattimore (pro hac vice)
PRELIMINARY STATEMENT
Received 9/19/2018 6:07:25 PM Commonwealth Court of Pennsylvania Filed 9/19/2018 6:07:00 PM Commonwealth Court of Pennsylvania 587 MD 2014 IN THE COMMONWEALTH COURT OF PENNSYLVANIA WILLIAM PENN SCHOOL
In the Supreme Court of Pennsylvania Middle District
Received 2/9/2018 9:51:03 PM Supreme Court Middle District In the Supreme Court of Pennsylvania Middle District Filed 2/9/2018 9:51:00 PM Supreme Court Middle District 159 MM 2017 No. 159 MM 2017 LEAGUE
Case 2:17-cv MMB Document 34-2 Filed 04/26/18 Page 1 of 9 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA
Case 217-cv-05137-MMB Document 34-2 Filed 04/26/18 Page 1 of 9 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA LEAGUE OF WOMEN VOTERS OF PENNSYLVANIA, et al., Plaintiffs, v.
AMICUS CURIAE BRIEF OF PHILIP P. KALODNER IN SUPPORT OF NEITHER PARTY
No. 18-422 In the Supreme Court of the United States ROBERT A. RUCHO, et al Appellants v. COMMON CAUSE, et al Appellees On Appeal from the United States District Court for the Middle District of North
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COMMONWEALTH OF PENNSYLVANIA PENNSYLVANIA PUBLIC UTILITY COMMISSION P.O. BOX 3265, HARRISBURG, PA 17105-3265 IN REPLY PLEASE REFER TO OUR FILE Secretary Rosemary Chiavetta Pennsylvania Public Utility Commission
IN THE COMMONWEALTH COURT OF PENNSYLVANIA
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IN THE COMMONWEALTH COURT OF PENNSYLVANIA
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IN THE COMMONWEALTH COURT OF PENNSYLVANIA No. 587 MD 2014 WILLIAM PENN SCHOOL DISTRICT, et al., Petitioners, v. PENNSYLVANIA DEPARTMENT OF EDUCATION, et al., Respondents. SUPPLEMENTAL BRIEF ON EXECUTIVE
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Received 12/7/2017 1:58:11 PM Commonwealth Court of Pennsylvania Filed 12/7/2017 1:58:00 PM Commonwealth Court of Pennsylvania 261 MD 2017 BLANK ROME LLP Brian S. Paszamant (PA ID # 78410) Jason A. Snyderman
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Arneson and the Senate Majority Caucus s Application for Summary Relief.
Received 06/10/2015 Filed 06/10/2015 35 MD 2015 IN THE COMMONWEALTH COURT OF PENNSYLVANIA ERIK ARNESON, individually and in his official capacity as Executive Director of the Office of Open Records; and
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IN THE COMMONWEALTH COURT OF PENNSYLVANIA
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IN THE COMMONWEALTH COURT OF PENNSYLVANIA
Received 12/10/2017 11:37:44 AM Commonwealth Court of Pennsylvania Filed 12/10/2017 11:37:00 AM Commonwealth Court of Pennsylvania 261 MD 2017 IN THE COMMONWEALTH COURT OF PENNSYLVANIA League of Women
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IN THE COMMONWEALTH COURT OF PENNSYLVANIA
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IN THE COMMONWEALTH COURT OF PENNSYLVANIA Matthew J. Brouillette and Rep. James Christiana and Benjamin Lewis, Petitioners v. : No. 410 M.D. 2017 Heard: December 12, 2017 Thomas Wolf, Governor and Joseph
Supreme Court of Pennsylvania
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IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA. No.
IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA JACOB CORMAN, in his official capacity as Majority Leader of the Pennsylvania Senate, MICHAEL FOLMER, in his official capacity
IN UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA
IN UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA HARRIS, et al., Plaintiffs 1CV-11-2228 v. (JONES) CORBETT, et al. Defendants Electronically Filed PLAINTIFFS MOTION FOR EMERGENCY
THE COMMONWEALTH OF PENNSYLVANIA, et al., PROPOSED REMEDIAL PLAN. LEAGUE OF WOMEN VOTERS OF PENNSYLVANIA, et al., Petitioners,
FILED 2/22/2018 Supreme Court Middle District IN THE SUPREME COURT OF PENNSYLVANIA NO. 159 MM 2017 LEAGUE OF WOMEN VOTERS OF PENNSYLVANIA, et al., Petitioners, v. THE COMMONWEALTH OF PENNSYLVANIA, et al.,
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