Gear Plaintiffs’ List of Witnesses for Cross-Examination and Exhibits and Designation of Counsel

Summary

Gear Plaintiffs' List of Witnesses for Cross-Examination and Exhibits and Designation of Counsel for an April 1, 2020 hearing on their motion for temporary restraining order and preliminary injunction. It was filed in the United States District Court for the Western District of Wisconsin in Democratic National Committee, et al. v. Marge Bostelmann, et al. The filing responds to an order about the April 1, 2020 videoconference hearing. It designates Jon Sherman and Michelle Kanter Cohen of Fair Elections Center as the two attorneys who will participate, and states that Jon Sherman will cross-examine Meagan Wolfe and present oral argument for the Gear Plaintiffs. The related cases are numbered 20-cv-249, 20-cv-278 and 20-cv-284.

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“Gear Plaintiffs’ List of Witnesses for Cross-Examination and Exhibits and Designation of Counsel.” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-wiwd-45522-165-0-24dca156ba/, SHA-256 f4fa54c786acde24bc99e36c55ed3974698157657bbee531d32a25e5f56ea3ab.

Full text

IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF WISCONSIN

DEMOCRATIC NATIONAL COMMITTEE, et al.

Plaintiffs,

v. No. 20-cv-249

MARGE BOSTELMANN, et al.

Defendants,

and

REPUBLICAN NATIONAL COMMITTEE, et al.

Intervening Defendants

SYLVIA GEAR, et al.

Plaintiffs,

v. No. 20-cv-278

MARGE BOSTELMANN, et al.

Defendants,

REVERAND GREG LEWIS, et al.

Plaintiffs,

MARGE BOSTELMANN, et al. No. 20-cv-284

Defendants,

GEAR PLAINTIFFS’ LIST OF WITNESSES FOR CROSS-EXAMINATION AND
EXHIBITS AND DESIGNATION OF COUNSEL FOR APRIL 1, 2020 HEARING ON
THEIR MOTION FOR TEMPORARY RESTRAINING ORDER AND PRELIMINARY
INJUNCTION

In response to this Court’s Order regarding the April 1, 2020 videoconference hearing on

the Gear Plaintiffs’ motion for temporary restraining order and preliminary injunction, Plaintiffs

submit the following:

(1) Plaintiffs designate Jon Sherman and Michelle Kanter Cohen of Fair Elections

Center as the two attorneys who will participate in the hearing. Jon Sherman will cross-examine

Meagan Wolfe and present oral argument for the Gear Plaintiffs.

(2) Plaintiffs’ counsel hereby identify the following witness they will cross-examine at

the hearing before the Court scheduled for April 1, 2020:

Meagan Wolfe
Administrator, Wisconsin Elections Commission
Counsel:
Dixon R. Gahnz
Terrence M. Polich
Daniel S. Lenz
Daniel P. Bach
Lawton & Cates, S.C.
P.O. Box 2965
Madison, WI 53701-2965
(608) 282-6200
(608) 282-6252 (Facsimile)
dlenz@lawtoncates.com

Defendants and Intervenor-Defendants Republican National Committee and Republican

Party of Wisconsin did not request to cross-examine any of the declarants whose declarations were

submitted in support of Plaintiffs’ Motion for a Temporary Restraining Order and Preliminary

Injunction.

(3) Plaintiffs hereby designate the following exhibits for use in oral argument and/or

in cross-examination of Defendant Meagan Wolfe:

a. Attached as Exhibit 51 is the Wisconsin Election Commission, Absentee Witness

Signature Requirement Guidance,” (March 29, 2020) (Exhibit W to Supplemental

Declaration of Cecilia Aguilera In Support of Plaintiffs’ Motion for a Temporary

Restraining Order and Preliminary Injunction), also available at

https://elections.wi.gov/sites/elections.wi.gov/files/2020-

03/Absentee%20Witness%20Guidance_0.pdf (last visited Mar. 30, 2020).

b. Attached as Exhibit 52 is Wisconsin Elections Commission’s Form EL-122

(Wisconsin Official absentee ballot application and certificate), available at

https://elections.wi.gov/forms/el-122.

c. Attached as Exhibit 53 is Wisconsin Emergency Order #12, issued by Gov. Tony

Evers and Secretary of Health Services Andrea Palm on March 24, 2020, available

at https://evers.wi.gov/Documents/COVID19/EMO12-SaferAtHome.pdf.

d. Attached to this Declaration as Exhibit 54 is a true and correct copy of Table S2501

from the U.S. Census Bureau’s 2013-17 American Community Survey 5-Year

Estimates.

e. Attached to this Declaration as Exhibit 55 is a true and correct copy of the CDC’s

webpage providing information about how COVID-19 spreads, available at

https://www.cdc.gov/coronavirus/2019-ncov/prevent-getting-sick/how-covid-

spreads.html?CDC_AA_refVal=https%3A%2F%2Fwww.cdc.gov%2Fcoronavirus

%2F2019-ncov%2Fprepare%2Ftransmission.html.

DATE: April 1, 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
jsherman@fairelectionscenter.org
mkantercohen@fairelectionscenter.org
caguilera@fairelectionscenter.org
(202) 331-0114

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
Phone: 608-960-7430
Fax: 608-960-7460
dpoland@rathjewoodward.com
dhollander@rathjewoodward.com

Counsel for Plaintiffs

*Admitted to the U.S. District Court for the
Western District of Wisconsin

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Our copy: gov.uscourts.wiwd.45522.165.0.pdf
Original: archive.org