DOCSLIB.ORG

PILF Amicus Brief

Total Page：16

File Type：pdf, Size：1020Kb

Download full-text PDF Read full-text

Load more

Nos. 19-251, 19-255 IN THE Supreme Court of the United States AMERICANS FOR PROSPERITY FOUNDATION, Petitioner, v. XAVIER BECERRA, IN HIS OFFICIAL CAPACITY AS THE ATTORNEY GENERAL OF CALIFORNIA, Respondent. THOMAS MORE LAW CENTER, Petitioner, v. XAVIER BECERRA, IN HIS OFFICIAL CAPACITY AS THE ATTORNEY GENERAL OF CALIFORNIA, Respondent. On Writs of Certiorari to the United States Court of Appeals for the Ninth Circuit Brief of the Public Interest Legal Foundation and Foundation for Michigan Freedom as Amici Curiae in Support of Petitioners J. CHRISTIAN ADAMS KAYLAN PHILLIPS Counsel of Record PUBLIC INTEREST LEGAL FOUNDATION 32 E. Washington St., Ste. 1675 Indianapolis, IN 46204 (317) 203-5599 [email protected] (Additional Counsel Inside Cover) ERIC E. DOSTER DOSTER LAW OFFICES, PLLC 2145 Commons Parkway Okemos, MI 48864 (517) 977-0147 [email protected] i Table of Contents Table of Authorities ................................................. ii Interests of Amici Curiae ......................................... 1 Summary of the Argument ...................................... 3 Argument ................................................................. 4 I. Compelled Disclosure Is Antithetical to the Foundational Principles of the United States ................................................. 4 II. The Recent History Demonstrates that Donor Disclosure Is a Tool that Has Been Used to Engage in Personal Attacks ............. 6 A. National Organization for Mar- riage’s Leaked Tax Document ............ 6 B. IRS Targeting Scandal........................ 8 C. Friends of Abe ..................................... 8 D. League of United Latin American Citizens v. Public Interest Legal Foundation .......................................... 9 E. Chick-fil-A ......................................... 11 F. U.S. Virgin Islands Subpoena .......... 11 III. Donor Disclosure Is Also Used to Engage in Personal Attacks in the Election Con- text ............................................................... 12 A. California’s Proposition 8 ................. 12 B. Will & Grace...................................... 14 C. Representative Joaquin Castro ........ 15 D. Michigan Chamber of Commerce ..... 16 E. SoulCycle ........................................... 17 Conclusion .............................................................. 18 ii Table of Authorities Cases Citizens United v. FEC, 558 U.S. 310 (2010) ...................................... 12-14 Doe v. Reed, 561 U.S. 186 (2010) ........................................... 13 League of Latin American Citizens v. Public Interest Legal Foundation, No. 1:18-cv-00423 (E.D. Va. April 12, 2018) ..... 10 McIntyre v. Ohio Elections Comm’n, 514 U.S. 334, 357 (1995) .................................... 5 NAACP v. Ala. ex rel. Patterson, 357 U.S. 449 (1958) .......................................... 4-6 National Org. for Marriage, Inc. v. United States, 24 F. Supp. 3d 518 (E.D. Va. 2014) ..................... 7 True the Vote, Inc. v. IRS, 831 F.3d 551 (D.C. Cir. 2016) ............................. 8 Constitutions and Statutes Cal. Const. Art. I § 7.5 ........................................... 12 Cal. Govt. Code Ann. § 84211(f) ............................. 12 Other Authorities Brief Summary of the Ballot Proposal................... 16 iii Caitlin O’Kane, Debra Messing demands attendee list for Beverly Hills Trump fundraiser, president hits back, CBS News (Sept. 2, 2019) ................. 14-15 CEI, First Amendment Fight: CEI’s Climate Change Subpoena (April 5, 2017) ....................................... 11 Debra Messing (DebraMessing) ............................. 14 Fredreka Schouten, Rep. Joaquin Castro tweets names, employers of Trump donors in San Antonio, CNN (Aug. 7, 2019) ................................................ 15 Kate Taylor, For Chick-fil-A, impact trumps ‘any po- litical or cultural war’ when it comes to controversial donations, Business Insider (May 15, 2019) ......... 11 Kelly Phillips Erb, IRS Targeting Scandal: Citizens United, Lois Lerner And The $20M Tax Saga That Won’t Go Away (June 24, 2016) ............................... 8 Matt Kempner, Chick-fil-A, criticized for its charita- ble giving, narrows donations, The Atlanta Journal- Constitution (Nov. 23, 2019) ................................. 11 Michael Cieply and Nicholas Confessore, Leaning Right in Hollywood, Under a Lens, The New York Times (Jan. 22, 2014) ............................................... 9 Michelle Ye Hee Lee, Trump’s critics are targeting his donors, sparking fears of a backlash against dis- closure, Washington Post (Sept. 10, 2019) ............ 15 iv Nolan Finley, Finley: Left turns to terroristic tactics to silence critics, The Detroit News (July 11, 2018) ........................................................ 16 NOM, National Organization for Marriage Demands a Federal Investigation of the Human Rights Cam- paign and the Internal Revenue Service (April 5, 2012) ...................................................................... 6-7 Pew Research Center, Mobile Fact Sheet (June 12, 2019) ....................................................................... 14 Rani Molla, One Trump fundraiser was all it took to slash SoulCycle’s attendance, Vox (Sept. 5, 2019) ........................................................ 17 Sam Levine and Spenser Mestel, ‘Just like propa- ganda’: the three men enabling Trump’s voter fraud lies, The Guardian (Oct. 26, 2020) ........................... 1 Ted Johnson, Friends of Abe: Hollywood’s Comfort Zone for Industry Conservatives Winds Down, Varie- ty (April 27, 2016) ................................................. 8-9 Testimony of J. Christian Adams, U.S. House Sub- committee on the Constitution, Civil Rights and Civil Liberties (Sept. 10, 2019) ........................... 9-10 The Federalist No. 1 ............................................. 4-5 Thomas M. Messner, The Price of Prop 8, Heritage Foundation Backgrounder, No. 2328 (Oct. 22, 2009) ................................................................. 13 v Thomas Paine, COMMON SENSE, Introduction ......... 5 Transcript of Motion Hearing, League of Latin Amer- ican Citizens v. Public Interest Legal Foundation (May 24, 2019) ........................................................ 10 Trish Loughran, THE REPUBLIC IN PRINT: PRINT CULTURE IN THE AGE OF U.S. NATION BUILDING (2007) ........................................................................ 5 1 INTERESTS OF AMICI CURIAE1 The Public Interest Legal Foundation, Inc., (the “Foundation”) is a nonpartisan, public interest organ- ization incorporated and based in Indianapolis, Indi- ana. The Foundation’s mission is to promote the in- tegrity of elections nationwide through research, edu- cation, remedial programs, and litigation. The Foun- dation also seeks to ensure that voter qualification laws and election administration procedures are fol- lowed. Specifically, the Foundation seeks to ensure that the nation’s voter rolls are accurate and current, working with election administrators nationwide and educating the public about the same. The Foundation and individuals publicly associated with it are often targeted by the media and special interest groups with voracious attacks on their work. See Sam Levine and Spenser Mestel, ‘Just like propaganda’: the three men enabling Trump’s voter fraud lies, The Guardian (Oct. 26, 2020). The Foundation has terminated fund- raising in California due to California’s insistence on forcing the production of unredacted donor infor- mation. The Foundation has serious concerns about how the state will use and safeguard its donors infor- mation from abusive behavior. 1 No counsel for a party authored this brief in whole or in part, nor did any person or entity, other than amici curiae and their counsel, make a monetary contribution intended to fund the preparation or submission of this brief. Petitioners in both 19- 251 and 19-255 issued blanket consents to the filing of amicus curiae briefs. Respondent was notified and consented to the fil- ing of this brief. 2 The Foundation for Michigan Freedom is a non- profit, nonpartisan organization recognized by the In- ternal Revenue Service as tax-exempt pursuant to Section 501(c)(3) of the Internal Revenue Code. A core mission of the Foundation for Michigan Freedom is to undertake legal research projects in the public inter- est and to provide legal support in litigation designed to present positions on behalf of the public at-large on matters of public interest. In particular, the Founda- tion for Michigan Freedom is dedicated to the promo- tion and protection of the democratic process, includ- ing the right of all citizens to participate and enter the marketplace of ideas. As a nonprofit, nonpartisan or- ganization, the Foundation for Michigan Freedom recognizes that the First Amendment protects citi- zens from government interference of our right to pe- tition, criticize, and speak openly and freely on mat- ters of public policy. The ability to do so anonymously and without fear of retribution is a key principle of that right and one that should be protected for all viewpoints, regardless of whether one agrees with the particular speaker. Both amici have a substantial interest in the res- olution of this matter as they are 501(c)(3) charitable organizations reliant on funding from generous do- nors. California’s attempt to coerce the disclosure of charitable donors implicates serious constitutional concerns and chills the speech of amici. 3 SUMMARY OF ARGUMENT
Recommended publications
  • Peloton Interactive $6,245 - X Greater Coverage

    Peloton Interactive $6,245 - X Greater Coverage

    PTON - Short Overvalued With Competition Accelerating March 17, 2020 Hedgeye Retail Brian McGough Jeremy McLean © Hedgeye Risk Management LLC © Hedgeye© HedgeyeRisk ManagementRisk Management LLC. LLC. Legal DISCLAIMER Hedgeye Risk Management, LLC (“Hedgeye”) is a registered investment advisor, registered with the State of Connecticut. Hedgeye is not a broker dealer and does not provide investment advice to individuals. This research does not constitute an offer to sell, or a solicitation of an offer to buy any security or investment vehicle. This research is presented without regard for individual investment preferences or risk parameters; it is general information and does not constitute specific investment advice, nor does it constitute or contain any legal or tax opinions. This presentation is based on information from sources believed to be reliable. Hedgeye is not responsible for errors, inaccuracies or omissions of information. The opinions and conclusions contained in this report are those of the individual expressing those opinions or conclusion and are intended solely for the use of Hedgeye’s clients and subscribers, and the authorized recipients of the content. In reaching its own opinions and conclusions, Hedgeye and its employees have relied upon research conducted by Hedgeye’s employees, which is based upon sources considered credible and reliable within the industry. Neither Hedgeye, nor its employees nor any individual expressing opinions, conclusions or data are responsible for the validity or authenticity of the information upon which it has relied. TERMS OF USE This report is protected by United States and foreign copyright laws and is intended solely for the use of its authorized recipient.
  • The State of the Right to Vote After the 2012 Election

    The State of the Right to Vote After the 2012 Election

    S. HRG. 112–794 THE STATE OF THE RIGHT TO VOTE AFTER THE 2012 ELECTION HEARING BEFORE THE COMMITTEE ON THE JUDICIARY UNITED STATES SENATE ONE HUNDRED TWELFTH CONGRESS SECOND SESSION DECEMBER 19, 2012 Serial No. J–112–96 Printed for the use of the Committee on the Judiciary ( U.S. GOVERNMENT PRINTING OFFICE 81–713 PDF WASHINGTON : 2013 For sale by the Superintendent of Documents, U.S. Government Printing Office Internet: bookstore.gpo.gov Phone: toll free (866) 512–1800; DC area (202) 512–1800 Fax: (202) 512–2104 Mail: Stop IDCC, Washington, DC 20402–0001 COMMITTEE ON THE JUDICIARY PATRICK J. LEAHY, Vermont, Chairman HERB KOHL, Wisconsin CHUCK GRASSLEY, Iowa DIANNE FEINSTEIN, California ORRIN G. HATCH, Utah CHUCK SCHUMER, New York JON KYL, Arizona DICK DURBIN, Illinois JEFF SESSIONS, Alabama SHELDON WHITEHOUSE, Rhode Island LINDSEY GRAHAM, South Carolina AMY KLOBUCHAR, Minnesota JOHN CORNYN, Texas AL FRANKEN, Minnesota MICHAEL S. LEE, Utah CHRISTOPHER A. COONS, Delaware TOM COBURN, Oklahoma RICHARD BLUMENTHAL, Connecticut BRUCE A. COHEN, Chief Counsel and Staff Director KOLAN DAVIS, Republican Chief Counsel and Staff Director (II) C O N T E N T S STATEMENTS OF COMMITTEE MEMBERS Page Coons, Hon. Christopher A., a U.S. Senator from the State of Delaware ........... 6 Durbin, Hon. Dick, a U.S. Senator from the State of Illinois .............................. 4 Grassley, Hon. Chuck, a U.S. Senator from the State of Iowa ............................ 3 Leahy, Hon. Patrick J., a U.S. Senator from the State of Vermont .................... 1 prepared statement .......................................................................................... 178 Whitehouse, Hon. Sheldon, a U.S. Senator from the State of Rhode Island .....
  • Move to Be Well: the Global Economy of Physical Activity

    Move to Be Well: the Global Economy of Physical Activity

    Move to be Well: Mindful Movement The Global Economy of Equipment & Supplies Physical Activity Technology Fitness Sports & Active Apparel & Recreation Footwear OCTOBER 2019 Move to be Well: The Global Economy of Physical Activity OCTOBER 2019 Copyright © 2019 by the Global Wellness Institute Quotation of, citation from, and reference to any of the data, findings, and research methodology from this report must be credited to “Global Wellness Institute, Move to be Well: The Global Economy of Physical Activity, October 2019.” For more information, please contact [email protected] or visit www.globalwellnessinstitute.org. CONTENTS Executive Summary i Full Report 1 I. Physical Inactivity: A Rising Global Crisis 3 Physical activity is essential to health, and yet, collectively we have become 3 more inactive. How did we become so inactive? 4 Physical activity versus fitness: A privilege, a choice, or a right? 5 II. Understanding the Economy of Physical Activity 7 Defining physical activity 7 The evolution of recreational and leisure physical activity 9 The economy of physical activity 12 What does this study measure? 14 III. The Global Physical Activity Economy 21 Physical activity global market 21 Recreational physical activities 25 • Sports and active recreation 29 • Fitness 34 • Mindful movement 41 Enabling sectors 48 • Technology 49 • Equipment and supplies 55 • Apparel and footwear 56 Physical activity market projections 57 IV. Closing Physical Activity Gaps and Expanding Markets 61 Physical activity barriers and motivations 61 Business innovations and public initiatives to overcome barriers 63 • Mitigating time constraints and increasing convenience 63 • Making physical activity a daily habit 65 • Making physical activity fun and appealing 69 • Enabling movement in all physical conditions 73 • Embedding physical activity in the built environment 75 • Making physical activity affordable and accessible to everyone 76 V.
  • Overcoming the Unprecedented

    Overcoming the Unprecedented

    A REPORT FROM THE SOUTHERN POVERTY LAW CENTER OVERCOMING THE UNPRECEDENTED Southern Voters’ Battle Against Voter Suppression, Intimidation, and a Virus Supporters of restoring voting rights to people with felony convictions march to an early voting precinct in Fort Lauderdale, Fla., on Oct. 24, 2020. The Florida Rights Restoration Coalition led marches to the polls in dozens of counties. OVERCOMING THE UNPRECEDENTED Southern Voters’ Battle Against Voter Suppression, Intimidation, and a Virus ABOUT THE SOUTHERN POVERTY LAW CENTER The Southern Poverty Law Center is a catalyst for racial justice in the South and beyond, working in partnership with communities to dismantle white supremacy, strengthen intersectional movements, and advance the human rights of all people. www.splcenter.org © 2021 SOUTHERN POVERTY LAW CENTER Contents Executive Summary 4 Election Administration 6 Investing in a New South: Vote Your Voice 12 Felony Disenfranchisement and Rights Restoration 15 Election Disinformation and Voter Intimidation 19 Election Day 2020 and Protecting the Vote 22 Errors and Undercounts in the 2020 Census 27 Looking Ahead: Legislative Reform Imperative 32 Endnotes 37 Credits and Acknowledgments 40 SPLCENTER.ORG SOUTHERN POVERTY LAW CENTER 3 Executive Summary Long before anyone in the United States had should not have to navigate an outdated system or heard the term “COVID-19,” voting rights activ- jump through unnecessary bureaucratic hoops to ists were gearing up for what was certain to be exercise their most fundamental right. a tumultuous and high-profile election cycle in America made it through the 2020 election 2020. The stakes were high, and the vitriol and cycle, but not unscathed.
  • 1 Written Testimony of Chiraag Bains Director of Legal Strategies Dēmos

    1 Written Testimony of Chiraag Bains Director of Legal Strategies Dēmos

    Written Testimony of Chiraag Bains Director of Legal Strategies Dēmos Hearing: “For the People: Our American Democracy” Committee on House Administration U.S. House of Representatives Longworth House Office Building Room 1310 February 14, 2019 I. INTRODUCTION Thank you, Chairperson Lofgren, Ranking Member Davis, and all members of the Committee, for the opportunity to testify in support of H.R. 1, the For the People Act—the boldest and most comprehensive proposal to strengthen our democracy since the aftermath of Watergate. My name is Chiraag Bains, and I am Director of Legal Strategies for Dēmos. Dēmos is a public policy and advocacy organization working for an America where we all have an equal say in our democracy and an equal chance in our economy. Our name—meaning “the people”—is the root word of democracy, and it reminds us that, in America, the true source of our greatness is the diversity of our people. We at Dēmos stand in strong support of the For the People Act, a visionary bill that can transform our democracy by addressing the deep political, racial, and economic inequalities that hold us back. The bill would strengthen voting rights by expanding access to the polls, modernizing voter registration, requiring independent redistricting, and protecting voters from aggressive purging— including by correcting the Supreme Court’s wrongheaded 5-4 decision in Dēmos’ case against Ohio’s use-it-or-lose-it system, Husted v. A. Philip Randolph Institute. It would commit to restoring the full protections of the Voting Rights Act, the evisceration of which in Shelby v.
  • In the United States Patent and Trademark Office Before the Trademark Trial and Appeal Board

    In the United States Patent and Trademark Office Before the Trademark Trial and Appeal Board

    IN THE UNITED STATES PATENT AND TRADEMARK OFFICE BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD Peloton Interactive, Inc., ) Cancellation No. ) Petitioner, ) ) PETITION TO PARTIALLY v. ) CANCEL REGISTRATION ) Mad Dogg Athletics, Inc., ) ) Registration No. 2003922 Respondent. ) Mark: SPINNING ) Class: 28 INTRODUCTION 1. Petitioner Peloton Interactive, Inc. (“Peloton”) respectfully requests the partial cancellation of Registration No. 2003922 (the “’922 Registration”) for the term SPINNING owned by Respondent Mad Dogg Athletics, Inc. (“Mad Dogg”). The terms SPIN and SPINNING are generic, and Mad Dogg should be barred from continuing to abusively enforce its improper trademark rights across the spinning industry. 2. For many years, countless fitness industry participants, including Peloton, have received baseless cease-and-desist letters from Mad Dogg and its lawyers threatening expensive litigation if all uses of the terms SPIN and SPINNING are not halted. Indeed, Mad Dogg’s founder, John Baudhuin, publicly admits that Mad Dogg spends “hundreds of thousands of dollars a year” policing its purported trademarks and chasing down infringers. As detailed below, even bloggers and journalists have received cease-and-desist letters from Mad Dogg baselessly seeking to halt their use of the terms SPIN and SPINNING. US-DOCS\121232232.1 3. But Mad Dogg’s expensive efforts cannot stem the tide. Spin class and spin bike are part of the fitness lexicon. Even five minutes of simple Google searching reveal that everyone in the world—other than Mad Dogg—understands that “spin” and “spinning” are generic terms to describe a type of exercise bike and associated in-studio class. As detailed below, countless publications review “spin/spinning classes” and “spin/spinning bikes” provided by a wide variety of different companies including Peloton, SoulCycle, Flywheel, NordicTrack and others.
  • Voting Challenges 2010

    Voting Challenges 2010

    Voting Challenges 2010 1 A decade after Florida 2000 2006: Threats from new vote suppressive laws and policies 2008: Voter registration biggest threat; voting machine progress It is now a full decade since the Florida election fiasco of 2000, and our voting system still does not work as it should. In 2006, we saw a new wave of voter suppression laws and practices across the country that affected millions of eligible voters—especially minority, low-income, student, and older voters. For a presentation on challenges and developments relating to the 2006 elections, see http://www.brennancenter.org/content/resource/cast_out_new_voter_suppression_strategi es_2006_and_beyond. In 2008, the biggest obstacle to the franchise was problems with the voter registration system. For a presentation on challenges and developments relating to the 2008 elections, see http://www.brennancenter.org/content/resource/challenges_to_the_vote_2008. (All of the Brennan Center’s annual presentations on voting are available here: http://www.brennancenter.org/content/resource/annual_trends_in_voting_rights.) Today, we will discuss the biggest voting challenges in 2010 that create a risk of large- scale voter disenfranchisement. 2 Voting problems can affect election outcomes How many votes make the difference? NV Senate .7% LA 4th District 350 FL Governor .7% VA 5th District 727 CO Senate 1% MN Senate 225 OR Governor 1.3% MO Presiden 3,903 0 4 8 12162024283236404448 Polling % 0 200 400 600 800 1,000 1,200 1,400 1,600 2010 Close Races 2008 Close Races (Source: Real Clear Politics average (Source: election returns) polling data) Voting matters: it’s a fundamental right. It also matters because lost votes can affect election outcomes.
  • Soulcycle: Could They Bring a Wind of Change to the Fitness Industry?

    Soulcycle: Could They Bring a Wind of Change to the Fitness Industry?

    This material is exclusively prepared for Ringle Customers Material for your English session SoulCycle: Could they bring a wind of change to the fitness industry? 0 본 자료는 저작권 법에 의해 보호되는 저작물로, Ringle 사에 저작권이 존재합니다. 해당 자료에 대한 무단 복제/배포를 금하며, 해당 자료로 수익을 얻거나 이에 상응하는 혜택을 누릴 시 Ringle 과 사전 협의가 없는 경우 고소/고발 조치 될 수 있습니다. This material is exclusively prepared for Ringle Customers [Summary in English] I. SoulCycle Creating a New Life Style SoulCycle has turned spinning, once thought of as a boring exercise, into a social phenomenon. • SoulCycle has become a highly successful franchise. As of 2018, there are 82 studios in major cities across the US. The co-founders – Ruth Zuckerman, Julie Rice and Elizabeth Cutler – established SoulCycle with the goal of creating a new lifestyle brand. Specifically, the co-founders sought to energize and motivate people to spin by offering a workout environment that was focused. They wanted to be more than a simple health and fitness club by inspiring people to buy-in to the spinning lifestyle. • Prior to co-founding SoulCycle, Julie Rice had moved to NYC from LA and was missing the after-work hikes and jogs that she had enjoyed on the West Coast. She wanted to hang out, talk and have fun while working out, but she couldn't find opportunities in NYC like she had in LA. • Similarly, Elizabeth Cutler had moved to NYC from Colorado before the creation of SoulCycle. Cutler had difficulty finding the type of good exercise sessions she wanted, and her post-birth weight gains made her hesitant to go to an ordinary fitness center.
  • Emma Barry's Cycling Takeaways One Sizedoes Not

    Emma Barry's Cycling Takeaways One Sizedoes Not

    No. 8 - 10.2019 EMMA BARRY’S CYCLING TAKEAWAYS 15 THOUGHT-PROVOKING INSIGHTS INTO THE AT-HOME BOOM HI-TECH, HI-TOUCH AT THE PURE GROUP Members will stay with you for your people, says CEO Colin Grant THE APPLIANCE OF SCIENCE How Les Mills tests its new cycling programmes in the lab ONE SIZE DOES NOT FIT ALL A segmented offering has boosted cycling class occupancy at Nuffield THE ONLINE MAGAZINE FOR ALL INDOOR CYCLINGOctober LOVERS 2019 RIDE HIGH 1 34 CONTENT & CONTRIBUTIONS Have a great indoor cycling story you’d like to share? From studio successes to new innovations – and everything in between – we’d love to hear about it. Do you know of any super- 04 18 star cycling instructors? We’d love to tell their stories, so please introduce us! And if there are any other topics you think we should cover in Ride High, please let us know. All ideas are welcome – 12 40 [email protected] 26 COLIN GRANT THE APPLIANCE OF SCIENCE 04 Immersive, gamified cycling; sleep as the next wellbeing trend; and the launch of an in-club bou- 26 Les Mills uses science to road-test its cycling programmes. Bryce Hastings, Les Mills’ head of re- tique concept. The founder and CEO of Asia’s Pure Group talks to Kate Cracknell search, talks us through some of the company’s extensive studies in the field of indoor cycling CYCLING TAKEAWAYS THE DIGME TOUR 12 In the second of a two-part series exploring the boom in at-home indoor cycling, global fitness 34 Harnessing the appeal of cycling Grand Tours for engaging themed classes – that’s just one of bou- industry observer Emma Barry shares 15 thought-provoking insights into current trends – and the tique operator Digme Fitness’ eye-catching strategies.
  • 1 February 15, 2017 Dionne Hardy FOIA Officer Office of Management

    1 February 15, 2017 Dionne Hardy FOIA Officer Office of Management

    February 15, 2017 Dionne Hardy Nelson D. Hermilla FOIA Officer Chief, FOIA/PA Branch Office of Management and Budget Civil Rights Division Room 9026, 725 17th Street, NW Department of Justice Washington, DC 20503 BICN Bldg., Room 3234 [email protected] 950 Pennsylvania Avenue NW Washington, DC 20530 Melissa Golden [email protected] Lead Paralegal and FOIA Specialist Office of Legal Counsel Kevin Krebs Department of Justice Assistant Director, FOIA/Privacy Unit Room 5511, 950 Pennsylvania Avenue NW Executive Office for U.S. Attorneys Washington, DC 20530 Department of Justice [email protected] Room 7300, 600 E St. NW Washington, DC 20530 Laurie Day, Chief, Initial Request Staff Office of Information Policy Department of Justice Suite 11050, 1425 New York Avenue NW Via mail, email, and online request form Washington, DC 20530 Re: Request Under Freedom of Information Act (Fee Waiver/Limitation Requested) To Whom It May Concern: The Campaign Legal Center submits this Freedom of Information Act (“FOIA”) request (the “Request”) for records pertaining to the Department of Justice and Office of Management and Budget’s writings and communications regarding President Trump’s allegations of widespread voter fraud, his proposal for “a major investigation into VOTER FRAUD, including those registered to vote in two states, those who are illegal and …. even, those who registered to vote who are dead (and many for a long time)”, and his proposals to “strengthen up voter procedures.”1 Background During the 2016 presidential campaign, Mr. Trump suggested that the election would be “rigged,” that “cheating” could steal the election, and that our elections are marred by 2 3 widespread fraud.
  • \\SBS2011\Company\PUBLIC\TTV Montana\00 District Court\02

    \\SBS2011\Company\PUBLIC\TTV Montana\00 District Court\02

    Case 6:20-cv-00067-DLC Document 3 Filed 09/09/20 Page 1 of 37 Emily Jones [email protected] JONES LAW FIRM 2101 Broadwater Ave. P.O. Box 22537 Billings, MT 59104 Telephone: 406/384-7990 Local Counsel for Plaintiffs James Bopp, Jr. (IN #2838-84)* [email protected] Richard E. Coleson (IN #11527-70)* [email protected] Courtney Turner Milbank (IN #32178-29)* [email protected] Angela Stuedemann (IA #69956)* [email protected] True the Vote, Inc., Voters’ Rights Initiative THE BOPP LAW FIRM, PC 1 South Sixth St. Terre Haute, IN 47807-3510 Telephone: 812/232-2434 *Pro hac vice application forthcoming Lead Counsel for Plaintiffs IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MONTANA HELENA DIVISION Joe Lamm, Ravalli County Republican Central Committee, Jeff Wagner, Case No.: ___________________ Sylvia Wagner, Fiona Nave, Brent Nave, Plaintiffs, Plaintiffs’ Preliminary- v. Injunction Memorandum Stephen Bullock, in his official capacity as Governor of Montana; Corey Stapleton, in his official capacity as Secretary of State of Montana, Defendants. Pls.’ Prel. Inj. Mem. Case 6:20-cv-00067-DLC Document 3 Filed 09/09/20 Page 2 of 37 Table of Contents Introduction .......................................................1 Facts.............................................................1 A. Montana’s safe system of in-person with no-excuse-absentee voting complies with Phase 2 reopening rules, obviating any justification for the Plan.....................................................1 B. As a matter of law, mailed ballots pose the greater fraud risk...........3 C. A sudden flood of mailed ballots poses serious risks to the right to vote. 4 D. Voters are irreparably harmed by the Plan..........................8 Standing..........................................................9 Argument........................................................14 I.
  • Global Wellness Industry Outlook 2019

    Global Wellness Industry Outlook 2019

    Global Wellness Industry Outlook 2019 © Redwood Advisors 2018 Table of Contents Introduction......................................................................................................2 Market Overview..........................................................................................3-4 Key Segments................................................................................................5-9 Customer Overview.................................................................................10-11 Key Insights...............................................................................................12-27 Traditional wellness segments still dominate the market.....................13-15 Wellness has hit a tipping point............................................................16-19 Engagement has surfaced as the key challenge...................................20-22 Personalization has become critical.....................................................23-24 The age of wellness data has begun....................................................25-27 Key Takeaways...............................................................................................28 Company Spotlights................................................................................29-33 About Redwood Advisors............................................................................34 Sources........................................................................................................35-36 1 Introduction Health and wellness have entered