No. 17A-909. Supreme Court of the United States

Transcription

1 No. 17A-909 IN THE Supreme Court of the United States MICHAEL C. TURZAI, IN HIS CAPACITY AS SPEAKER OF THE PENNSYLVANIA HOUSE OF REPRESENTATIVES, AND JOSEPH B. SCARNATI III, IN HIS CAPACITY AS PENNSYLVANIA SENATE PRESIDENT PRO TEMPORE, vs. Applicants, LEAGUE OF WOMEN VOTERS OF PENNSYLVANIA, et al., On Application for a Stay of the Judgment of the Supreme Court of Pennsylvania Respondents. MOTION OF DICK THORNBURGH AND BILL MCCOLLUM FOR LEAVE TO FILE AMICUS BRIEF IN SUPPORT OF EMERGENCY APPLICATION FOR STAY ON 8½ x11 PAPER DAVID R. FINE (Counsel of Record) H. WOODRUFF TURNER DAVID G. KLABER MARK A. RUSH K&L GATES LLP 17 North Second St., 18th Fl. (717) Counsel for Amici Curiae

2 Amici Curiae Dick Thornburgh and Bill McCollum respectfully move for leave of Court to file their proposed brief of amici curiae in support of the application for stay on 8½ x 11 paper. On March 2, 2018, Messrs. Thornburgh and McCollum filed a motion for leave to file a brief of amici curiae in support of the pending application for a stay. Because of the time-sensitive nature of this matter, including the applicants request that the Court treat their application as an emergency request and Justice Alito s request that the respondents file an answer by March 5, 2018, Messrs. Thornburgh and McCollum believed it important to file their motion and attached, proposed brief as soon as possible and in a timeframe that did not allow for printing as provided in U.S. Supreme Ct. R Accordingly, Amici Curiae Messrs. Thornburgh and McCollum respectfully request that the Court grant them leave to file their proposed brief of amici curiae in support of the application for stay on 8½ x 11 paper. Respectfully submitted, March 5, 2018 DAVID R. FINE (Counsel of Record) H. WOODRUFF TURNER DAVID G. KLABER MARK A. RUSH K&L GATES LLP 17 North Second St., 18th Fl. (717) Counsel for Amici Curiae

3 PROOF OF SERVICE I hereby certify on this 5th day of March, 2018, I served a copy of the attached motion for leave on the following by the means identified: Alex Michael Lacey alacey@cohenlaw.com Pittsburgh, PA Alice Birmingham Mitinger amitinger@cohenlaw.com Pittsburgh, PA Benjamin David Geffen bgeffen@pilcop.org 1709 Benjamin Franklin Parkway, 2nd Floor Carolyn Batz McGee cmcgee@c-wlaw.com Claudia De Palma cdp@hangley.com Phone: David P. Gersch david.gersch@apks.com Arnold & Porter Kaye Scholer LLP 601 Massachusetts Ave, NW Washington, DC Clifford B. Levine clevine@cohenlaw.com Pittsburgh, PA Ian Blythe Everhart ieverhart@pa.gov 306 North Office Building Harrisburg, PA 17120

4 Jason Raymond McLean Washington Rd. #700 Karl Stewart Myers Stradley Ronon Stevens and Young, LLP 2005 Market Street, Suite 2600 Kathleen A. Gallagher Pittsburgh, PA Kathleen Marie Kotula Room 306 North Office Building 401 North Street Harrisburg, PA Lawrence J. Tabas Centre Square West, 34th Floor 1500 Market Street Philadelphia, PA Mark Alan Aronchick Mary M. McKenzie Benjamin Franklin Parkway Michael Churchill Ben Franklin Pkwy. 2fl Michele D. Hangley Hangley Aronchick Segal Pudlin & Schiller

5 Rebecca Lee Warren Centre Square West, 34th Floor 1500 Market Street Philadelphia, PA Russell David Giancola Cipriani & Werner, PC Thomas Paul Howell Market Street, 17th Floor Representing: Respondent Thomas W. Wolf Timothy Eugene Gates Department of State, Office of Chief Counsel 306 North Office Building Harrisburg, PA Jason Torchinsky 45 North Hill Dr. Suite 100 Warrenton, VA David R. Fine