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Interveners Opp to Cert Petition

Interveners Opp to Cert Petition

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THE COURT APPEALS MARYLAND 

September Term, 2012 
No.34 
JOHN DOE, al., Petitioners, 
MARYLAND STATE BOARD ELECTIONS, al., 
Respondents. 

RESPONDENT MDPETITIONS.COM'S ANSWER OPPOSITION PETITION FOR WRIT CERTIORARI 
John Doe, al. Maryland State Board Elections, al. 
Circuit Court Anne Arundel County, Case No. 02-C-11-163050 Filed August 2011 
The Honorable Ronald Silkworth 
Paul Orfanedes Chris Fedeli 
JUDICIAL WATCH, INC. 
425 Third Street, S.W., Ste. 800 Washington, 20024 
Tel: (202) 646-5172 
Fax: (202) 646-5199 
Email: porfanedes@judicialwatch.org cfedeli@judicialwatch.org 
Attorneys for Respondent MdPetitions. com 
TABLE CONTENTS 

RESPONDENT MDPETITIONS.COM'S ANSWER OPPOSITION PETITION FOR WRIT CER TIORARL .....
...........................

....... .............................. AND ARD REVIEW
.......... ............................................................................................... 

INTRODUCTION............................................................... .......................................................... 

COUNTERSTATEMENT THE CASE ..................... ..........................................................4 

ARGUMENT OPPOSITION THE PETITION ............................................................6 	
Review Not Necessary Secure Uniformity ofDecision ...........................7 

II. Special Circumstances Render Desirable and the 
the Public Interest That the Circuit Court's Decision 
Reviewed ................................................ ................................................................ 	
Petitioners failed support their claims below .... ............................... 	
Petitioners' assertion that Senate Bill 167 directly 
mandates and requires spending increases wrong
........................... 
Petitioners' other arguments for granting review are without merit ........ ........... ................ ............ ........................................... 

CONCLUSION
................................. ......................... ................................................................. 

CERTIFICAIB SERVICE

.................................................................................................. 

TABLE AUTHORITIES 
Cases 
Dorsey 
Petrott, 178 Md. 230 (1940) ... .... ... ....................... .......... ......... ....................... 

Jones 

State, 357 Md. 408 (2000) ............................. 
...... ............... ........................ ......... .......
Kelly lvfarylanders for Sports Sanity, Inc., 310 Md. (1987) ............................................ 

Vanhook 
Merchants Mutual Ins. Md. App. (1974).. ................................................... 

Constitutional and Rules 
Md. 
Const., art. XVI,  passim............................................................ ............................................ 

2009 Laws Maryland, ch. 487,  ............................................................................................ 

2010 Laws Maryland, ch. 484,  ......................................... ....... ............. ....................: .......... 

2011 Laws Maryland, ch. 497,  ............................................................................................ 

Md. 
Code Ann., Cts. Jud. Proc. 12-305 1..... ................... ..................... .... .... ......................... 

Md. Code Ann., Educ.  16-305 .............................................................................................. 11, 

Md. 
Rule 8-303(d) 1........................................................................................................................ 

RESPONDENT MDPETITIONS.COM'S ANSWER OPPOSITION PETITION FOR WRIT CERTIORARI 
Respondent MdPetitions.com ("MdPetitions.com"), counsel and pursuant Md. Rule 8-303(d), respectfully submits this Answer Opposition the Petition for Writ Certiorari ("the Petition") filed Petitioners John Doe, al. (''Petitioners"). 
STANDARD REVIEW 
The granting writ certiorari appropriate where doing necessary secure uniformity decision where the legal question presents special circumstances making certiorari desirable and the public interest. Jones State, 357 Md. 408, 418 (2000), citing Md. Code Ann., Cts. Jud. Proc. 12-305. 
INTRODUCTION 
Petitioners, who were the plaintiffs below, ask this Court review decision the Circuit Court for Anne Arundel County (the "Circuit Court") granting summary judgment favor ofMdPetitions.com, the Maryland State Board Election, the State Administrator Elections, and the Secretary ofState. the Circuit Court, Petitioners had sought reverse the State Board Election's certification that Senate Bill 167 -which had been enacted the General Assembly during its 2011 session and was signed the Governor May 10, 2011 --was subject referendum the November 2012 election. Senate Bill 167 changes Maryland existing tuition policy make certain unlawfully present aliens eligible for in-state tuition Maryland's community colleges and public universities. 
Petitioners' sole legal argument the Circuit Court was that Senate Bill 167 was "appropriation" for "maintaining State government" and therefore was subject 
exception the people's right referendum set forth Article XVI, Section the 
Maryland Constitution. After reviewing the clear and unambiguous text Senate Bill 
167 and applying this Court's well-established precedent defining the term 
"appropriation" under Article XVI, Section the Circuit Court found that Senate Bill 
167 was policy bill, not "appropriation," and therefore was not subject the 
exception. Consequently, the Circuit Court rejected Petitioners' attempt deprive 
Maryland's voters the opportunity vote whether Senate Bill 167 should become 
law. 
Review the Circuit Court's ruling not necessary secure uniformity 
decision. Petitioners not even appear argue much. fact, Petitioners raise what 
they assert question first impression aking the Court reconsider its 
longstanding precedent under Article XVI, Section Since least early 1940, the Court has held that bill enacted the General Assembly "appropriation" for 
purposes the Article XVI, Section its "primary object authorize the 
withdrawal from the state treasury certain sum money for specified public 
objective purpose which such sum applied." Kelly Marylanders for 
Sports Sanity, Inc., 310 Md. 437, 459 (1987) (quoting Dorsey Petrott, 178 Md. 230, 
245 (1940)). Petitioners seek expand this definition include bills that "directly 

12. Far from seeking secure uniformity decision, Petitioners seek expand the 
exception the people's right referendum Article XVI, Section new and 
potentially enormous categories legislation, thereby substantially diminishing the 
constitutional rights Maryland voters. 
Nor are any special circumstances present that render desirable and the public 
interest that the Circuit Court's ruling reviewed. anything, the opposite true. 
First, the Circuit Court reached the merits Petitioners' sole legal argument despite the 
complete absence any affidavits other factual evidence submitted Petitioners 
support their summary judgment motion opposition Respondents' cross-
motions. Petitioners' claims the Circuit Court suffered from fundamental failure 
proof: They would not have prevailed even the Circuit Court had defined the term 
"appropriation" the expansive and unprecedented manner Petitioners advocate. 
Second, the entire premise behind Petitioners' request that the Court reconsider its longstanding precedent erroneous. Petitioners base their request the assertion that 
Senate Bill 167 directly mandates and requires future spending increases amounts "to determined" future Budget Bills. Nothing Senate Bill 167 directly even 
indirectly mandates requires that future Governors and future General Assemblies 
provide any particular level state support community colleges future fiscal years. 
Consequently, even the Court were hold that bill that "directly mandates and 
requires" increase future spending constitutes "appropriation" for purpose the 
exception, Petitioners still would not entitled any relief because Senate Bill 167 

standing precedent and redefined the term "appropriation" the expansive way 
Petitioners advocate. Accordingly, special circumstances make desirable and the 
public interest that this Court review the Circuit Court's ruling, which was nothing more 
than garden variety application this Court's longstanding precedent 
quintessential policy choice enacted the General Assembly and signed the 
Governor. anything, the public interest requires that Petitioners' failed legal challenge 
the State Board Election's certification comes end now, without farther litigation, that the parties and the voters Maryland can focus the upcoming referendum. 
The State Board Elections determined that MdPetition.com had satisfied all the 
requirements for submitting Senate Bill 167 referendwn and certified the provision for 
placement the November 2012 ballot. The Circuit Com1 reviewed that determination 
and found that was correct. Further litigation will only distract from the referendum 
process. time for Maryland's voters have their say. 
COUNTERSTATEMENT THE CASE 
Petitioners' statement the case fails fully describe the nature the legislation 
and proceedings issue, brief counterstatement order. 2011, the Maryland General Assembly enacted Senate Bill 167, sometimes 
referred the "Maryland Dream Act." Amended Complaint for Declaratory and 
Injunctive Relief ("Amend. Compl.") at, This new tuition policy would make certain 
unlawfully present aliens eligible for reduced, in-state tuition Maryland's sixteen 
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enacted part annual budget bill supplemental appropriation bill. Intervener's 
Statement Grounds and Authorities Opposition Plaintiffs' Motion for Summary Judgment and Support oflntervener's Cross-Motion Dismiss and/or for Summary Judgment ("MdPetitions.com's Mem.") Nor was referred either the Senates Budget and Taxation Committee the House Delegate's Appropriations Committee, which are the committees that consider proposed education appropriations. Id. Rather, was referred the Senate's Education, Health, and Environmental Affairs Committee and the House Delegates' Ways and Means Committee, which are committees that consider proposed general laws and policy questions, not appropriations. Id. 
MdPetitions.com organized and led the petition drive place Senate Bill 167 the November 2012 ballot. Amend. Compl.  33. Throughout May and June 2011, MdPetitions.com collected total 132,071 signatures support the petition. Id. 34-36. The State Board Elections ultimately verified and validated 108,923 those signatures --nearly twice the amount required-and certified that Senate Bill 167 would placed the November 2012 ballot. Id. 136. Petitioners then commenced this lawsuit prevent the voters tvlaryland from deciding for themselves whether Senate Bill 167 should become law. the petition sponsor, MdPetitions.com sought and was granted pennission intervene Petitioners' lawsuit. The parties subsequently filed cross-motions for summary judgment pursuant mutually agreed-upon scheduling. See September 22, 2011 Scheduling Order. Petitioners, however, failed submit any evidence whatsoever suppmt their 

judgment motion opposition tv1dPetition.com's cross-
motion the cross-motion Defendants. See, e.g., MdPetitions.com's Mem. 3-4; 
Intervener's Reply Plaintiffs' Opposition Cross-Motion Dismiss and/or for 
Summary Judgment ("MdPetitions.com's Reply") and Petitioners failed submit much single affidavit from one the the named plaintiffs attesting who they were, how they claimed aggrieved, whether they were registered vote Maryland, even what their interest was the the new policy. Id. February 17, 2012, the Circuit Court issued Memorandum Opinion and Order granting summary judgment favor ofMdPetitions.com, the Maryland State Board Election, the State Administrator Elections, and the Secretary State. Petitioners now seek further review from this Court. 
ARGUMENT OPPOSITION THE PETITION 
Petitioners ask the Court grant certiorari decide whether statute that "directly mandates and requires increase future appropriations" "appropriation" for purposes the referendum exception the people's right referendum. Petition see also id. 12. Review the Circuit Court's ruling not necessary secure uniformity the law because the Circuit Court's ruling was firmly rooted this Court's precedent. Petitioners' attempt drastically and expansively redefine the term "appropriation," not the Circuit Court's ruling, that odds with longstanding precedent. Nor are there any special circumstances that render desirable and the public interest that the Circuit Court's ruling reviewed. Indeed, this case wholly unsuited for reconsidering this Court's longstanding precedent defining the term 
"appropriation" because the question presented for review Petitioners irrelevant 
the outcome this litigation, not moot. Review Not Secure Decision. 
The law defining the term "appropriation" for purposes the exception the people's right referendum well-established. act the General Assembly "appropriation" for purposes the exception its "primary object authorize the withdrawal from the state treasury certain sum money for specified public object purpose which such sum applied." Kelly, 310 Md. 459 (quoting Dorsey, 178 Md. 245. general law does not constitute "appropriation" for purposes the exception even contains incidental provision for the appropriation public funds. Id. (citing Dorsey, 147 Md. 251 
Petitioners not appear argue that the Circuit Court deviated from this well-established definition ruling that Senate Bill 167 general law, not "appropriation." The question whether Senate Bill 167 general law appropriation simple one that can answered merely reviewing the bill itself. Consequently, Petitioners re-cast the question presented for review whether this Court should essentially rewrite the Maryland Constitution exclude from the people's right referendum not only revenue raising and spending bills, but also bills that
"directly mandate[] and require[] increase future appropriations.Petition see bears noting that Petitioners' current formulation the legal question presented for review differs substantially from the question they presented, least initially, the Circuit Court. their summary judgment papers, Petitioners expressly denied any claim that Senate Bill 167 must considered pari materia with any other statute, future otherwise, order constitute "appropriation." Memorandum Law Support Plaintiffs' Motion for Summary Judgment ("The issue here whether [Senate Bill 167] itselfis 'law making any appropriation' within the meaning the Referendum 
also id. 12. Multiple times, Petitioners observe that the Court has "never addressed" 
this question. Id. (the "question has never been directly addressed"), (the "Court 
has never addressed the question ... "), and (this "an issue :first impression for this 
Court."). has never been addressed because this Court has never defined the term 
"appropriation" Petitioners do. What Petitioners are seeking enormous expansion the exception order prevent Maryland voters from overturning unpopular 
legislation the ballot box. Far from demonstrating that review necessary secure 
uniformity decision, Petitioners ask this Court grant review that they may 
advocate for drastic expansion the exception the people's right referendum. 
Review not warranted under such circumstances. 
II. Special Circumstances Render Desirable and the Public Interest that the Circuit Court's Decision Reviewed. 
Nor have Petitioners demonstrated the existence any "special circumstances" 
that make desirable and the public interest that the Circuit Court's decision 
reviewed. This case wholly unsuited for litigating the unprecedented expansion the 
exception the people's right referendum that Petitioners advocate. This because, 
not only did Petitioners fail present any evidence support their motion for 
summary judgment opposition the cross-motions ofMdPetitions.com and 
Defendants, but Petitioners also are just plain wrong when they assert that Senate Bill 
167 "directly mandates and requires'' increases future appropriations. does such 
thing. 
Exception --not whether [Senate Bill 167] integral part package with some other law that appropriation measure.") (emphasis original). Petitioners failed support their claims below. axiomatic that, summary judgment, party must support its contentions 
placing before the court facts that would admissible into evidence trial. Vanhook 
Merchants Mutual Ins. Co., Md. App. 22, (1974). also axiomatic that "facts 
alleged pleadings are not, that means alone, before the court facts for summary 
judgment purposes." Id. 27. Petitioners had ample opportunity place evidence 
before the Circuit Court demonstrating that they were entitled summary judgment 
matter law. They failed so. 
For instance, Petitioners never offered any affidavits other evidence supporting 
their factual contention that Plaintiff "John Doe" ever graduated from Maryland high 
school, had any plans attend community college Maryland, could satisfy any 
the eligibility requirements Senate Bill 167.2 MdPetitions.com's Mem. 3-4; 
MdPctitions.com's Reply and Nor did Petitioners submit any affidavits 
other evidence from Casa Maryland support their factual contention that Casa 
Maryland would "aggrieved" any way Senate Bill 167 did not become law. Id. 
While Petitioners alleged their pleadings that Casa Maryland would have raise 
and expend additional funds provide social services unlawfully present aliens 
Senate Bill 167 did not become law, they failed present any evidence whatsoever 
support this allegation. Id. Similarly, Petitioners also failed present any affidavits 
other evidence support Petitioner's factual contention that the "registered voter 
Plaintiff"John Doe" the sole remaining anonymous plaintiff now that Plaintiff 
"Jane Doe" has been removed from the lawsuit. Petition n.2. 
plaintiffs" were actually who they claimed be, were registered vote Maryland, and 
had been injured some fashion were least sufficiently "interested" Senate Bill 
167 seek declaratory judgment. Id. Such facts obviously were material 
Petitioners' claims, yet Petitioners either neglected were unable submit any 
evidence support these simple contentions despite ample opportunity so. 
Consequently, Petitioners failed demonstrate that they were entitled any relief all. 
Given this fundamental failure proof, Petitioners could not have prevailed 
their claims matter what definition the term "appropriation" applied. The 
question presented for review moot. There reason for this Court grant review consider the drastic and unprecedented limitation the people's right referendum 
advocated Petitioners when the answer will make difference the outcome. 	Petitioners' assertion that Senate Bill 167 directly mandates and requires spending increases wrong. 
Petitioners' argument that the term "appropriation," used Article XVI, 
Section should redefined include legislative enactments that "directly mandate[] 
and require[]" increases "future appropriations" premised the contention that 
Senate Bill 167 enactment that somehow mandates future spending. Petition 
and ("Thus, the law directly requires and mandates increase the amounts 
appropriated for community colleges ... future fiscal years.") (emphasis original). 
Petitioners' contention wrong. Consequently, the Court need not grant review 
consider whether the term "appropriation" includes bills that "directly mandate[] and 
require[]" increases "future appropriations" because Senate Bill 167 not such bill. 
State funding for community colleges Maryland based upon statutory 
formula known the Senator John Cade Funding Fommla ("the Cade Formula"). 
Regardless Senate Bill 167, the Governor and the General Assembly will continue free they always have been decide how much state funding provide community colleges Budget Bills for future fiscal years. full examination the Cade Formula shows why this the case. 
The Cade formula not the automatic mechanical trigger Petitioners claim is. 
Under the Cade Formula, the State provides funding community colleges based percentage the funding that chooses provide designated public four-year institutions higher education per "full-time equivalent student." See Md. Code Ann., Educ.  16-3 05( way example, given year the Governor and the General Assembly choose provide $100 funding for each full-time equivalent student four-year institution and set the Cade Formula 20% for that year, then the State would provide $20 funding for each full-time equivalent student community college for that same year. Id. Thus, rather than the mandated amount that Petitioners claim, the Cade Formula requires that the Governor and the General Assembly first select the level fllllding that the State chooses provide the four-year institutions, then select the percentage that amount that the State chooses provide the community colleges "full-time equivalent student" basis. 
Historically, the Governor and the General Assembly have adopted schedule that 
sets forth Cade Fonnula percentages for multiple years, then revised those percentages 
substantially, based upon the State's financial condition and priorities. Md. Code Ann., 
Educ. 16-305 note (Effect Amendments). For example, before 2009, the Cade formula percentage for Piscal Year 2013 had been set 30%. Id.; see also 2009 Laws Maryland, ch. 487,  2009, was reduced 27%. Id. 2010 was reduced and 2011, was reduced 19%. Id.; see also 2010 Laws Maryland, ch. 484,  2011 Laws Maryland, ch. 497,  Not only the Cade Formula percentages 
change substantially even after they have been set, but the legislature can eliminate them 
entirely any given year. For example, enacting the Budget Reconciliation and 
Financing Act 2010, the Governor and the General Assembly abandoned percentage 
fonnula altogether and instead set state funding for community colleges flat amount 
for both Fiscal Year 2011 and Fiscal Year 2012. 2010 Laws Maryland, ch. 484,  
Clearly, nothing Senate Bill 167 "directly mandates and requires" any particular level state funding for community colleges future fiscal years. more full-time students seek attend community college future years and the State wishes keep its support for community colleges the same level prior years, the Governor and the General Assembly retain the discretion regardless the policy change made Senate Bill 167. the State wishes reduce its support for commWlity colleges future years, may regardless Senate Bill 167 well, and the community colleges may seek make the difference raising tuition and/or obtaining greater support from the county counties the community colleges serve. Contrary Petitioners' argument, the Governor retains discretion request state funding for 
community colleges whatever level she believes appropriate, and the General 
Assembly retains the discretion adopt reduce the Governor's request. Senate Bill 
167 does not directly indirectly mandate require any particular level state 
spending community colleges. 
Indeed, the Circuit Court expressly found that, regardless the enactment 
Senate Bill 167, state funding for community colleges remains dependent number 
variables, including the discretion the Governor and the General Assembly: 
Assuming, arguendo, that the Court does fact need consider [Senate Bill 167 and the Cade Formula] together, future appropriation would dependent number variables, including there being increase eligible students, the Cade Formula remaining unaltered the General Assembly Governor, and any alteration the appropriation the General Assembly before the Budget Bill passed. 
Memorandum (emphasis added). Petitioners' counsel acknowledged this fact 
well when stated oral argument that the Governor's annual Budget Bill "can 
subject later adjustment the --downward the General Assembly." Transcript 
Proceedings 20. Counsel continued," ... obviously, the budget bill can adjusted 
the General Assembly, the --that's exactly what they did with the Cade funding formula 
last year and believe the year before." Id. 20-21. 
Accordingly, even additional students qualify for in-state tuition result Senate Bill 167, the Governor and the General Assembly still retain the discretion 
raise, lower, maintain previous levels the amount financial support the State they did the Circuit Court, Petitioners again cite line the Fiscal Note for Senate Bill 167 stating that the bill "affects mandated appropriation." Petition (emphasis omitted). Obviously, whether bill "affects" mandated appropriation substantially different from whether bill "is" mandated appropriation. Moreover, state funding for community colleges only "mandated" the extent that set formula, this instance, the Cade Funding Formula. The Governor and the General Assembly retain the discretion decide which inputs into that formula disregard the formula entirely, Petitioners' counsel acknowledged. 
provides community colleges future years. Senate Bill 167 does not "directly 
require[] mandate[] increase the amounts appropriated for the community 
colleges" otherwise "directly result[] increased expenditures the State for support community colleges." Petition and (emphasis omitted). 
Because nothing Senate Bill mandates requires increased state spending 
for community colleges future years, the question Petitioners ask this Cowt address 
--whether bill that "directly mandates and requires increase future appropriations" constitutes appropriation for purposes the exception the people's right 
referendum --is irrelevant. Petitioners still could not prevail their legal claims even 
the Court reconsidered its long standing precedent and redefined the term "appropriation" the expansive way Petitioners advocate. Not only "special circumstances" exist 
that make desirable and the public interest that this Court review the Circuit Court's 
ruling, but any such review would futile. 	Petitioners' other arguments for granting review are without merit. 
Petitioners raise handful other arguments for granting review, none which 
have merit. Petitioners claim that the Court should grant review "clarify" the scope 
the referendum exception applied measures regulating the raising revenue. 
Petition 17-18. the oral argument the parties' cross-motions for summary 
judgment, however, Petitioners conceded that Senate Bill 167 was not revenue raising 
provision: 
[By Mr. Sandler] The issue whether --this --nobody arguing this has anything with raising revenue, the question here what type spending bill non-referable under Article XVI. 
Transcript Proceedings 15. The Circuit Court expressly noted this concession its 
ruling, "Plaintiffs conceded that [Senate Bill 167] does not raise revenue ... The Court 
will therefore focus its analysis whether [Senate Bill 167] spending measure 
within the meaning the Appropriation Exception." Memorandum Opinion 10, n.7. 
Granting review clarify the scope the exception applied revenue raising measures neither necessary nor appropriate because Petitioners have already conceded 
that Senate Bill 167 not revenue raising measure. The issue moot. 
Finally, Petitioners also argue that the Court should grant review because allowing referendum Senate Bill 167 will harm the students whom the policy intended 
benefit and disrupt the operation government. While the students who might benefit 
from Senate Bill 167 obviously are likely prefer that the policy change take effect, that 
preference alone does not warrant granting review, especially where, here, other 
factors weigh heavily against granting review. There simply disruption the 
operation of"government." While community colleges and public universities obviously 
are not "government," but instead are publicly supported institutions, these institutions 
undoubtedly will continue function just they had functioned before the policy change and just they have functioried ever since they came into existence. Petitioners 
make claim that these publicly supported institutions will receive less state financial 
support Senate Bill 167 does not become law. Their claim dismption the 
operation "government" chimera. 
CONCLUSION 
For all the foregoing reasons, Respondent MdPetitions.com respectfully requests that the Petition denied. Dated: April 2012 Respectfully submitted, 

INC. 
Md. Bar No. 9112190026 
Chris Fedeli 
Md. Bar No. 0012120179 
425 Third Street, W., Suite 800 
Washington, 20024 
Tel: (202) 646-5172 
Fax: (202) 646-5199 
Email: porfanedes@judicialwatch.org cfedeli@judicialwatch.org 
Attorneys for Respondent Md.Petitions.com 
CERTIFICATE SERVICE hereby certify that this 2"d day April, 2012, caused true and correct copy the foregoing RESPONDENT MDPETITIONS.COM'S ANSWER OPPOSITION PETITION FOR WRIT CERTIORARI served, via email and first-class U.S. 
mail, postage prepaid, the following: 
Elizabeth Getman Joseph Sandler 
SANDLER, REIFF, YOUNG LAMB, .C. 1025 Vermont Avenue, N.W., Suite 300 Washington, 20005 
Brett Marston 
Michael Harris 
Patricio Grane 
Laura Cofer Taylor Margarita Sanchez ARNOLD PORTER 555 Twelfth Street, N.W. Washington, 20004 
Matthew Fad 
Jeffrey Darsie 
Assistant Attorney Generals 
Beatrice Nunez-Bellamy Attorney 
OFFICE THE ATTORNEY GENERAL 
200 St. Paul Place, 20th Floor