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In the United States District Court for the Western District of Wisconsin

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In the United States District Court for the Western District of Wisconsin Case: 3:20-cv-00249-wmc Document #: 230 Filed: 06/26/20 Page 1 of 5 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WISCONSIN DEMOCRATIC NATIONAL COMMITTEE and DEMOCRATIC PARTY OF WISCONSIN, Plaintiffs, v. 20-cv-249-wmc MARGE BOSTELMANN, JULIE M. GLANCEY, ANN S. JACOBS, DEAN KNUDSON, ROBERT F. SPINDELL, JR. and MARK L. THOMSEN, Defendants, and REPUBLICAN NATIONAL COMMITTEE and REPUBLICAN PARTY OF WISCONSIN, Intervening Defendants. ______________________________________________________________________________ SYLVIA GEAR, MALEKEH K. HAKAMI, PATRICIA GINTER, CLAIRE WHELAN, WISCONSIN ALLIANCE FOR RETIRED AMERICANS and LEAGUE OF WOMEN VOTERS OF WISCONSIN, Plaintiffs, v. Case No. 20-cv-278-wmc MARGE BOSTELMANN, JULIE M. GLANCEY, ANN S. JACOBS, DEAN KNUDSON, ROBERT F. SPINDELL, JR., MARK L. THOMSEN, and MEAGAN WOLFE, Defendants. ______________________________________________________________________________ Case: 3:20-cv-00249-wmc Document #: 230 Filed: 06/26/20 Page 2 of 5 REVEREND GREG LEWIS, SOULS TO THE POLLS, VOCES DE LA FRONTERA, BLACK LEADERS ORGANIZING FOR COMMUNITIES, AMERICAN FEDERATION OF TEACHERS LOCAL, 212, AFL-CIO, SEIU WISCONSIN STATE COUNCIL, and LEAGUE OF WOMEN VOTERS OF WISCONSIN, Plaintiffs, v. Case No. 20-cv-284-wmc MARGE BOSTELMANN, JULIE M. GLANCEY, ANN S. JACOBS, DEAN KNUDSON, ROBERT F. SPINDELL, JR., MARK L. THOMSEN, and MEAGAN WOLFE, Defendants. JOINT STIPULATION REGARDING PENDING MOTIONS REGARDING GEAR PLAINTIFFS’ COMPLAINT AND FIRST AMENDED COMPLAINT Counsel for the Gear Plaintiffs and the Wisconsin Elections Commission (“WEC” or “Commission”) Defendants in Case No. 20-cv-278 met and conferred by Zoom call on June 25, 2020 in an effort to resolve certain pending disputes in anticipation of Monday’s status conference, to narrow issues in dispute, and to expedite the Court’s resolution of the substantive issues posed by the Gear action. Subsequently, the Gear Plaintiffs and the WEC Defendants agreed to enter into the following joint stipulation: 1. The WEC Defendants do not object to the Gear Plaintiffs’ filing of the attached proposed First Amended Complaint. See Exhibit A. The WEC Defendants expressly do not endorse the proposed First Amended Complaint in any way and reserve the right to answer or otherwise plead in response to the proposed First Amended Complaint. 2. The proposed First Amended Complaint attached as Exhibit A differs in very limited respects from the proposed First Amended Complaint attached to the Gear Plaintiffs’ 2 Case: 3:20-cv-00249-wmc Document #: 230 Filed: 06/26/20 Page 3 of 5 Motion for Leave to Add and Drop Plaintiffs, dkt. 148-1. As is shown in the redline version attached as Exhibit B to this Stipulation, the Gear Plaintiffs seek to: (a) add an additional form of relief that will permit certain voters to electronically access and download a mail- in absentee ballot, reducing the administrative burden on municipal clerks’ offices in sending replacement mail-in absentee ballots; (b) correct an error with respect to Plaintiff Gregg Jozwik; and (c) correct some non-substantive typographical errors. As compared to the proposed First Amended Complaint attached to the Gear Plaintiffs’ Motion for Leave to Add and Drop Plaintiffs, dkt. 148-1, no parties or causes of action have been added or dropped. 3. The Gear Plaintiffs and the WEC Defendants have agreed to abandon their respective positions with respect to the pending motion to dismiss the Gear Plaintiffs’ original Complaint, as set forth in the WEC Defendants’ motion to dismiss, dkt. 141, and the Gear Plaintiffs’ opposition brief, dkt. 155. These parties cannot stipulate to dismissal without prejudice and with leave to file the proposed First Amended Complaint, however; only this Court can grant that because the proposed First Amended Complaint seeks to add new plaintiffs and drop current plaintiffs, see Fed. R. Civ. P. 21, dkt. 148. However, the parties agree in principle that the First Amended Complaint attached as Exhibit A should become the operative complaint in this action, and they jointly request either that the Court resolve the pending motion to dismiss to permit that outcome, or, alternatively, that the Court permit the WEC Defendants to withdraw their motion to dismiss the Gear Plaintiffs’ original complaint, and grant the Gear Plaintiffs leave to file the First Amended Complaint attached as Exhibit A. 4. Finally, the Gear Plaintiffs and the Intervenor-Defendants Wisconsin Legislature, Republican National Committee, and Republican Party of Wisconsin (“the Intervenor- 3 Case: 3:20-cv-00249-wmc Document #: 230 Filed: 06/26/20 Page 4 of 5 Defendants”) met and conferred today via email. Having reviewed the attached proposed First Amended Complaint, the Intervenor-Defendants do not oppose its filing. However, like the WEC Defendants, the Intervenor-Defendants explicitly reserve the right to answer or otherwise plead in response to the Gear Plaintiffs’ First Amended Complaint. Dated: June 26, 2020 Respectfully submitted, /s/ Jon Sherman Jon Sherman* D.C. Bar No. 998271 Michelle Kanter Cohen* D.C. Bar No. 989164 Cecilia Aguilera* D.C. Bar No. 1617884 FAIR ELECTIONS CENTER 1825 K St. NW, Ste. 450 Washington, D.C. 20006 (202) 331-0114 (telephone) [email protected] [email protected] [email protected] Douglas M. Poland State Bar No. 1055189 David P. Hollander, State Bar No. 1107233 RATHJE WOODWARD LLC 10 E Doty Street, Suite 507 Madison, WI 53703 (608) 960-7430 (telephone) (608) 960-7460 (facsimile) [email protected] [email protected] Attorneys for Plaintiffs in Case No. 20-cv-278-wmc *Admitted to the U.S. District Court for the Western District of Wisconsin Dated: June 26, 2020 LAWTON & CATES, S.C. Electronically signed by Dixon R. Gahnz Dixon R. Gahnz, SBN: 1024367 4 Case: 3:20-cv-00249-wmc Document #: 230 Filed: 06/26/20 Page 5 of 5 Daniel S. Lenz, SBN: 1082058 Daniel P. Bach, SBN: 1005751 Terrence M. Polich, SBN: 1031375 345 W. Washington Avenue, Suite 201 P.O. Box 2965 Madison, WI 53701-2965 Phone: (608) 282-6200 Fax: (608) 282-6252 [email protected] [email protected] [email protected] [email protected] 5 Case: 3:20-cv-00249-wmc Document #: 230-1 Filed: 06/26/20 Page 1 of 80 EXHIBIT A Case: 3:20-cv-00249-wmc Document #: 230-1 Filed: 06/26/20 Page 2 of 80 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WISCONSIN DEMOCRATIC NATIONAL COMMITTEE and DEMOCRATIC PARTY OF WISCONSIN, Plaintiffs, v. Case No. 20-cv-249-wmc MARGE BOSTELMANN, JULIE M. GLANCEY, ANN S. JACOBS, DEAN KNUDSON, ROBERT F. SPINDELL, JR. and MARK L. THOMSEN, Defendants, and REPUBLICAN NATIONAL COMMITTEE and REPUBLICAN PARTY OF WISCONSIN, Intervening Defendants. ______________________________________________________________________________ SYLVIA GEAR, CLAIRE WHELAN, WISCONSIN ALLIANCE FOR RETIRED AMERICANS, LEAGUE OF WOMEN VOTERS OF WISCONSIN, KATHERINE KOHLBECK, DIANE FERGOT, GARY FERGOT, BONIBET BAHR OLSAN, SHEILA JOZWIK, and GREGG JOZWIK, Plaintiffs, v. Case No. 20-cv-278-wmc MARGE BOSTELMANN, JULIE M. GLANCEY, ANN S. JACOBS, DEAN KNUDSON, ROBERT F. SPINDELL, JR., MARK L. THOMSEN, and MEAGAN WOLFE, Defendants. ______________________________________________________________________________ REVEREND GREG LEWIS, SOULS TO THE POLLS, VOCES DE LA FRONTERA, BLACK LEADERS Case: 3:20-cv-00249-wmc Document #: 230-1 Filed: 06/26/20 Page 3 of 80 ORGANIZING FOR COMMUNITIES, AMERICAN FEDERATION OF TEACHERS LOCAL, 212, AFL-CIO, SEIU WISCONSIN STATE COUNCIL, and LEAGUE OF WOMEN VOTERS OF WISCONSIN, Plaintiffs, v. Case No. 20-cv-284-wmc MARGE BOSTELMANN, JULIE M. GLANCEY, ANN S. JACOBS, DEAN KNUDSON, ROBERT F. SPINDELL, JR., MARK L. THOMSEN, and MEAGAN WOLFE, Defendants. GEAR, ET AL. V. BOSTELMANN, ET AL., CASE NO. 20-CV-278, PLAINTIFFS’ FIRST AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF Plaintiffs Katherine Kohlbeck, Diane Fergot, Gary Fergot, Bonibet Bahr Olsan, Sheila Jozwik, Gregg Jozwik, Claire Whelan, Sylvia Gear, League of Women Voters of Wisconsin (“LWVWI”), and Wisconsin Alliance for Retired Americans (“Wisconsin Alliance”) (collectively, “Plaintiffs”) seek declaratory and injunctive relief as follows: NATURE OF ACTION 1. The COVID-19 pandemic presents an unprecedented challenge to our nation, threatening millions of Americans’ lives and livelihoods and severely straining health care systems, the economy, and all levels and branches of government. It is wreaking havoc across all sectors and causing massive disruptions in election administration during this presidential election year. 2. COVID-19’s high transmission rate and lethality pose a severe risk to in-person voters, particularly those in at-risk groups identified by the Centers for Disease Control and Prevention (“CDC”). The pandemic has already resulted in massive withdrawals by volunteer poll 2 Case: 3:20-cv-00249-wmc Document #: 230-1 Filed: 06/26/20 Page 4 of 80 workers who justifiably fear contracting the disease and the widespread closure of voting sites throughout Wisconsin. In the April 7, 2020 election, only five of the usual 180 polling places in Milwaukee were open.1 In Green Bay, just two of the usual 31 were operational.2 3. The threat of contracting COVID-19, particularly in confined spaces like polling sites and the long lines of voters who waited for their turn to access them on April 7, along with the precipitous reduction in election administration resources for in-person voting both on and before Election Day, have forced a seismic shift towards mail-in absentee
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