United States District Court for the Middle District of Pennsylvania
IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA : JACOB CORMAN, in his official : capacity as Majority Leader of the : No. Pennsylvania Senate, MICHAEL : : (filed electronically) FOLMER, in his official capacity as : Chairman of the Pennsylvania Senate : State Government Committee, LOU : THREE JUDGE COURT BARLETTA, RYAN COSTELLO, : REQUESTED PURSUANT TO MIKE KELLY, TOM MARINO, SCOTT : 28 U.S.C. § 2284(a) PERRY, KEITH ROTHFUS, LLOYD : : SMUCKER, and GLENN THOMPSON, : : Plaintiffs, : : v. : : : ROBERT TORRES, in his official : capacity as Acting Secretary of the : Commonwealth, and JONATHAN M. : MARKS, in his official capacity as : Commissioner of the Bureau of : Commissions, Elections, and Legislation, : : : Defendants. : : VERIFIED COMPLAINT Plaintiffs Jacob Corman, Michael Folmer (the “State Plainiffs”), Lou Barletta, Ryan Costello, Mike Kelly, Tom Marino, Scott Perry, Keith Rothfus, Lloyd Smucker and Glenn Thompson (the “Federal Plaintiffs”) (collectively, the “Plaintiffs”), by and through their undersigned counsel, bring this Verified Complaint for Injunctive relief against Defendants Robert Torres, Acting Secretary of the Commonwealth, and Jonathan M. Marks, Commissioner of the Bureau of Commissions, Elections, and Legislation (collectively, the “Defendants”), and in support thereof aver as follows: I. PRELIMINARY STATEMENT 1. This is an action concerning, inter alia, the Pennsylvania Supreme Court’s striking of a validly-enacted congressional districting plan and issuance of a substitute plan, each action in direct violation of the Elections Clause of the United States Constitution (the “Elections Clause”). 2. The Elections Clause provides, in relevant part, that “[t]he Times, Places and Manner” of holding congressional elections “shall be prescribed in each State by the Legislature thereof[,]”or by an act of Congress.
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