1 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WISCONSIN WILLIAM WHITFORD, et al., Plaintiffs, v. No. 15-cv-421-jdp BEVERLY R. GILL, et al., Defendants; and THE WISCONSIN STATE ASSEMBLY, Intervenor-Defendant. PLAINTIFFS’ RULE 26(A)(3) PRETRIAL DISCLOSURES Pursuant to Rule 26(a)(3) of the Federal Rules of Civil Procedure and the Order entered on February 1, 2019, dkt. 248, Plaintiffs William Whitford, et al., hereby make the following disclosures: I. RULE 26(a)(3)(A)(i): IDENTIFICATION OF WITNESSES A. Witnesses Plaintiffs Expect to Present Plaintiffs expect to call the following witnesses to testify at trial: 1. Jowei Chen, Ph.D. 2. Kenneth Mayer, Ph.D. 3. Adam Foltz 4. Tad Ottman 5. Peter Barca 6. Dr. Brittany Keyes 7. Sandy Pasch Case: 3:15-cv-00421-jdp Document #: 301 Filed: 06/14/19 Page 1 of 6
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PLAINTIFFS’ RULE 26(A)(3) PRETRIAL DISCLOSURES RULE 26(a ... · 15-cv-421-jdp 1 Plaintiffs’ Deposition Designations Plaintiffs reserve the right to amend, supplement, or withdraw
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1
IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WISCONSIN
WILLIAM WHITFORD, et al.,
Plaintiffs,
v. No. 15-cv-421-jdp BEVERLY R. GILL, et al.,
Defendants; and
THE WISCONSIN STATE ASSEMBLY,
Intervenor-Defendant.
PLAINTIFFS’ RULE 26(A)(3) PRETRIAL DISCLOSURES
Pursuant to Rule 26(a)(3) of the Federal Rules of Civil Procedure and the Order entered
on February 1, 2019, dkt. 248, Plaintiffs William Whitford, et al., hereby make the following
disclosures:
I. RULE 26(a)(3)(A)(i): IDENTIFICATION OF WITNESSES
A. Witnesses Plaintiffs Expect to Present
Plaintiffs expect to call the following witnesses to testify at trial:
5. Any custodian of records necessary to authenticate documents.
II. RULE 26(a)(3)(A)(ii): DEPOSITION DESIGNATIONS
Plaintiffs submit the designations of deposition testimony taken during discovery in the
above-captioned matter, as set out in Exhibit 1 to this document.1
Plaintiffs expressly incorporate by reference the deposition designations submitted in
conjunction with the trial on May 24-27, 2016, dkt. 129, which are already part of the record.
III. RULE 26(a)(3)(A)(iii): IDENTIFICATION OF EXHIBITS
Plaintiffs expect to offer or may offer if the need arises the exhibits and/or documents as set
out in Exhibit 2 to this document.
Plaintiffs expressly incorporate by reference the exhibits admitted in evidence at the trial in
this case on May 24-27, 2016, dkts. 146 and 172, which are already part of the record.
Plaintiffs reserve the right to:
1. Use any exhibits listed by Defendants.
2. Use all exhibits, papers, records, and writings provided by Defendants to Plaintiffs in this
case and/or attached to pleadings, papers, motions or other filings in this case.
3. Use all exhibits, papers, records, or writings attached to, filed with, or referenced in
Plaintiffs’ prior filings in this case.
4. Use all expert witness reports, reliance material, and other materials generated in
preparation for trial of this lawsuit.
5. Use any newly discovered evidence, records, reports, and exhibits.
1 Contemporaneously with these Rule 26(a)(3) disclosures, Plaintiffs are filing Plaintiffs’ Motion to Admit in Evidence Testimony by Deposition Designations of Any Plaintiff Who Does Not Testify Live at Trial, under Fed. R. Civ. P. 1, 32(a)(4)(E), and 16(c)(2)(L)..
7. Offer demonstrative exhibits and exhibits that will be offered for purposes of
impeachment only.
8. Plaintiffs reserve any and all objections to any and all exhibits listed by Defendants.
Dated: June 14, 2019 Respectfully submitted,
/s/ Ruth M. Greenwood Ruth M. Greenwood Annabelle E. Harless CAMPAIGN LEGAL CENTER 73 W. Monroe St., Ste. 302 Chicago, IL 60603 (312) 561-5508 [email protected][email protected] /s/ Douglas M. Poland Douglas M. Poland State Bar No. 1055189 Alison E. Stites State Bar. No. 1104819 RATHJE WOODWARD LLC 10 East Doty St., Ste. 507 Madison, WI 53703 (608) 960-7430 [email protected] /s/ Nicholas O. Stephanopoulos Nicholas O. Stephanopoulos UNIVERSITY OF CHICAGO LAW SCHOOL 1111 E. 60th St. Chicago, IL 60637 (773) 702-4226 [email protected] /s/ Mark P. Gaber Mark P. Gaber J. Gerald Hebert Danielle M. Lang CAMPAIGN LEGAL CENTER 1101 14th St. NW, Ste. 400 Washington, DC 20005
87:10 **NOTE: by agreement of the parties, the third-party names referenced in these designations are treated as AEO by the parties, subject to ¶16 of the Stipulated Protective Order (dkt. 262-1); dkt. 255-4.
93:7 **NOTE: by agreement of the parties, the third-party names referenced in these designations are treated as AEO by the parties, subject to ¶16 of the Stipulated Protectiver Order (dkt. 262-1); dkt. 255-4.
Lanterman 2018 3TB Hard Drive (produced physically to the parties)
Exhibit 1258Whitford v. Gill Matched Text Files
Exhibit 1259 Foltz000149_assembly.txt
Exhibit 1260
Map1.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1261
Map10.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1262
Map11.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Map12.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1264
Map13.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1265
Map14.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1266
Map15.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Map16.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1268
Map17.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1269
Map18.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1270
Map19.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Map2.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1272
Map20.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1273
Map21.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1274
Map22.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Map23.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1276
Map24.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1277
Map25.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1278
Map26.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Map27.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1280
Map28.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1281
Map29.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1282
Map3.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Map30.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1284
Map31.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1285
Map32.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1286
Map33.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Map34.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1288
Map35.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1289
Map36.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1290
Map37.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Map38.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1292
Map39.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1293
Map4.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1294
Map40.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Map41.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1296
Map42.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1297
Map43.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1298
Map45.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Map46.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1300
Map47.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1301
Map48.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1302
Map49.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Map5.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1304
Map50.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1305
Map51.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1306
Map52.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Map53.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1308
Map54.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1309
Map55.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1310
Map56.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Map57.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1312
Map58.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19:;Tr. Ex. 1430)
Exhibit 1313
Map59.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1314
Map6.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19:;Tr. Ex. 1430)
Map60.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1316
Map61.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1317
Map62.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1318
Map63.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Map64.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1320
Map65.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1321
Map66.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1322
Map67.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Map68.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1324
Map69.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1325
Map7.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1326
Map70.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Map71.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1328
Map72.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1329
Map73.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1330
Map74.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Map75.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1332
Map76.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1333
Map77.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1334
Map78.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Map79.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1336
Map8.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1337
Map80.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1338
Map81.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Map82.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1340
Map83.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1341
Map84.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1342
Map85.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Map9.txt (from Adam Foltz Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
map 1.txt (from Tad Ottman Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1395
map 2.txt (from Tad Ottman Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1396
map 3.txt (from Tad Ottman Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
map 8.txt (from Tad Ottman Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1398
map 10.txt (from Tad Ottman Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1399
map 11.txt (from Tad Ottman Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1400
map 12.txt (from Tad Ottman Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
map 13.txt (from Tad Ottman Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1402
map 14.txt (from Tad Ottman Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1403
map 15.txt (from Tad Ottman Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1404
map 16.txt (from Tad Ottman Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
map 17.txt (from Tad Ottman Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1406
map 18.txt (from Tad Ottman Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1407
map 19.txt (from Tad Ottman Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1408
map 20.txt (from Tad Ottman Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
map 21.txt (from Tad Ottman Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1410
map 22.txt (from Tad Ottman Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1411
map 23.txt (from Tad Ottman Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1412
map 24.txt (from Tad Ottman Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
map 25.txt (from Tad Ottman Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1414
map 26.txt (from Tad Ottman Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1415
map 27.txt (from Tad Ottman Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1416
map 28.txt (from Tad Ottman Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
map 29.txt (from Tad Ottman Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1418
map 30.txt (from Tad Ottman Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1419
map 31.txt (from Tad Ottman Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1420
map 32.txt (from Tad Ottman Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
map 33.txt (from Tad Ottman Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1422
map 34.txt (from Tad Ottman Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1423
map 35.txt (from Tad Ottman Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1424
map 36.txt (from Tad Ottman Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
map 37.txt (from Tad Ottman Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19:;Tr. Ex. 1430)
Exhibit 1426
map 38.txt (from Tad Ottman Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1427
map 39.txt (from Tad Ottman Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
Exhibit 1428
map 44.txt (from Tad Ottman Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430)
map 48.txt (from Tad Ottman Electronic Files: Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19; Tr. Ex. 1430))
Exhibit 1430
Handrick, Foltz and Ottman Supplemental Document Production 01.10.2012 (disc that was Exhibit 7 at Deposition of Adam Foltz, 06.06.19)
Exhibit 1431
Handrick 12-20-11 Exhibit No. 3 (disc that was Tr. Ex. 3 in Baldus )
Exhibit 1432Kenneth Mayer Report- 15 October 2018
Exhibit 1433Kenneth Mayer Rebuttal Report-22 January 2019
Exhibit 1434Jowei Chen Report-15 May 2019
Exhibit 1435
Jowei Chen Response Report Revised-15 May 2019
Exhibit 1436Jowei Chen Errata-15 May 2019
Exhibit 1437
Sean Trende Deposition-14 January 2019-Ex. 1-Subpoena
Exhibit 1438
Sean Trende Deposition-14 January 2019-Ex. 2-Responsive Documents
Exhibit 1439
Sean Trende Deposition-14 January 2019-Ex. 3-Contract with State for Professional Services
Alan I Abramowitz & Steven Webster, The rise of negative partisanship and the nationalization of elections in the 21st century, 41 Electoral Studies, 12-22 (2016)
Exhibit 1593
Stephen Ansolabehere et al, Old Voters, New Voters and the Personal Vote: Using Redistricting to Measure the Incumbency Advantage, 44(1) American Journal of Political Science, 17-34 (2000)
Exhibit 1594
Stephen Ansolabehere & James M. Snyder, Jr., The Effects of Redistricting on Incumbents, 11(4) Election Law Journal, 490-501 (2012)
Exhibit 1595
Pamela Ban et al, Challenger Quality and the Incumbency Advantage, 41 Legislative Studies Quarterly, 153-179 (2016)
Exhibit 1596
Michael Barber, Donation Motivations: Testing Theories of Access and Ideology, 69(1) Political Research Quarterly, 148-159 (2016)
Exhibit 1597
Bruce E. Cain, Assessing the Partisan Effects of Redistricting, 79(2) The American Political Science Review, 320-333 (1985)
Brandice Canes-Wrone et al, Out of Step, out of Office: Electoral Accountability and House Members' Voting, 96(1) The American Political Science Review, 127-140 (2002)
Exhibit 1599
Thomas M. Carsey & William D. Berry, What's a losing party to do? The calculus of contesting state legislative elections, 160 Public Choice, 251-273 (2014)
Exhibit 1600
Caughey et al, Partisan Gerrymandering and the Political Process: Effects on Roll-Call Voting and State Policies, 16(4) Election Law Journal, 453-469 (2017)
Exhibit 1601
Jowei Chen, The Impact of Political Geography on Wisconsin Redistricting: An Analysis of Wisconsin's Act 43 Assembly Districting Plan, 16(4) Election Law Journal, 1-10 (2017)
Exhibit 1602
Maria Chikina et al, Assessing significance in a Markov chain without mixing, 114(11) PNAS, 2860-2864 (2017)
Exhibit 1603
Gary Cox & Eric Magar, How Much is Majority Status in the U.S. Congress Worth? 93(2) American Political Science Review, 299-309 (1999)
Scott W. Desposato and John R. Peetrocik, The Variable Incumbency Advantage: New Voters, Redistricting, and the Personal Vote, 47(1) American Journal of Political Science, 18-32 (2003)
Exhibit 1605
Nicholas Eubank & Jonathan Rodden, Who is my Neighbor? The Spatial Efficiency of Partisanship, February 21, 2019, available at http://www.nickeubank.com/eubankrodden_spatialefficiency/
Exhibit 1606
Richard Forgette et al, Do Redistricting Principles and Practices Affect U.S. State Legislative Electoral Competition? 9(2) State Politics and Policy Quarterly, 151-175 (2009)
Exhibit 1607
Andrew Gelman & Gary King, Estimating the Electoral Consequences of Legislative Redistricting, 85(410) Journal of the American Statistical Association, 274-282 (1990)
Exhibit 1608
Andrew Gelman & Gary King, A Unified Method of Evaluating Electoral Systems and Redistricting Plans, 38(2) American Journal of Political Science, 514-554 (1994)
Amihai Glazer et al, Partisan Incumbency Effects of 1970s Congressional Redistricting, 31(3) American Journal of Political Science, 680-707 (1987)
Exhibit 1610
Bernard Grofman & Gary King, The Future of Partisan Symmetry as a Judicial Test for Partisan Gerrymandering after LULAC v, Perry, 6(1) Election Law Journal, 2-35 (2007)
Exhibit 1611
Danny Hayes & Seth C. McKee, The Participatory Effects of Redistricting, 53(4) American Journal of Political Science, 1006-1023 (2009)
Exhibit 1612
Gregory Herschlag et al, Evaluating Partisan Gerrymandering in Wisconsin, Sept. 17, 2017, available at https://arxiv.org/abs/1709.01596
Exhibit 1613
Robert E. Hogan, Campaign War Chests and Challenger Emergence in State Legislative Elections, 54(4) Political Research Quarterly, 815-830 (2001)
Exhibit 1614
Robert E. Hogan, Challenger Emergence, Incumbent Success, and Electoral Accountability in State Legislative Elections, 66(4) The Journal of Politics, 1283-1303 (2004)
Kosuke Imai et al, Unpacking the Black Box of Causality: Learning about Causal Mechanisms from Experimental and Observational Studies, 105(4) The American Political Science Review, 765-789 (2011)
Exhibit 1616
Simon Jackman, The Predictive Power of Uniform Swing, PS Symposium, 317-321 (April, 2014)
Exhibit 1617
Gary C. Jacobson, It's Nothing Personal: The Decline of the Incumbency Advantage in US House Elections, 77(3) The Journal of Politics, 861-873 (2015).
Exhibit 1618
Georgia Kernell, Giving Order to Districts: Estimating Voter Distributions with National Election Returns, 17(3) Political Analysis, 215-235 (2009)
Exhibit 1619
Matthew S. Levendusky et al, Measuring District-Level Partisanship with Implications for the Analysis of U.S. Elections, 70(3) The Journal of Politics, 736-753 (2008)
Exhibit 1620
Michael P. McDonald, Drawing the Line on District Competition, 39(1) PS: Political Science and Politics, 91-94 (2006)
Exhibit 1621
Michael P. McDonald, Presidential Vote within State Legislative Districts, 14(2) State Politics and Policy Quarterly, 196-204 (2014)
Joel A. Thompson et al, A Sacred Cow or Just a Lot of Bull? Party and PAC Money in State Legislative Elections, Political Research Quarterly 223-237 (1993)
Exhibit 1630
Devin Caughey & Christopher Warshaw, The Dynamics of State Policy Liberalism, 1936-2014, 60(4) American Journal of Political Science, 899-913 (2016)
Exhibit 1631
Timothy Werner & Kenneth R. Mayer, Public Election Funding, Competition, and Candidate Gender, PSOnline 661-667 (October, 2007)
Exhibit 1632
Jonathan Winburn & Michael W. Wagneer, Redistricting's Influence on Political Information, Turnout, and Voting Behavior, 63(2) Political Research Quarterly, 373-386 (2010)