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Judicial Watch • Feldman v. Bowser House Amicus DC budget 01967

Feldman v. Bowser House Amicus DC budget 01967

Feldman v. Bowser House Amicus DC budget 01967

Page 1: Feldman v. Bowser House Amicus DC budget 01967

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Date Created:March 31, 2016

Date Uploaded to the Library:April 04, 2016

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Case 1:15-cv-01967-EGS Document Filed 03/31/16 Page THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT COLUMBIA
__________________________________________
CLARICE FELDMAN,
Plaintiff,
Case No. 15-cv-01967-EGS
MURIEL BOWSER, her official capacity Mayor the District Columbia, al.,
Defendants.
__________________________________________)
UNOPPOSED MOTION THE BIPARTISAN LEGAL ADVISORY GROUP THE U.S. HOUSE REPRESENTATIVES FOR LEAVE FILE
MEMORANDUM AMICUS CURIAE
The Bipartisan Legal Advisory Group the U.S. House Representatives House
respectfully moves for leave file amicus curiae the attached memorandum which urges the
Court deny defendants motions dismiss,1 and reach the merits plaintiff claim that
the District Columbia Local Budget Autonomy Act 2012, D.C. Law 19-321 (publ. D.C.
Register Feb. 15, 2013) Local Budget Act unlawful. See Compl. for Declaratory
Injunctive Relief, Count One (Nov. 2015) (ECF No. 1). the event the Court determines
reach the merits plaintiff claim, anticipate that the House, that time, will seek leave
file second memorandum amicus curiae, urging the Court declare the Local Budget Act
invalid and enjoin its implementation.
The Bipartisan Group consisting the Honorable Paul Ryan, Speaker; the
Honorable Kevin McCarthy, Majority Leader; the Honorable Steve Scalise, Majority Whip; the
Honorable Nancy Pelosi, Democratic Leader; and the Honorable Steny Hoyer, Democratic
See Def. Muriel Bowser Mot. Dismiss (Feb. 2016) (ECF No. 10); Def. Jeffrey
Dewitt Mot. Dismiss (Feb. 2016) (ECF No. 9).
Case 1:15-cv-01967-EGS Document Filed 03/31/16 Page
Whip speaks for, and articulates the institutional position of, the House all litigation
matters. Rule II.8(b), Rules the House Representatives, 114th Cong., available
http://clerk.house.gov/legislative/house-rules.pdf.
The House has significant institutional interest the outcome this case because the
legal questions regarding budget autonomy for the District Columbia which questions are
central this dispute directly implicate Congress institutional powers, both with respect
federal appropriations generally, see U.S. Const. art. cl. money shall drawn
from the Treasury, but Consequence Appropriations made Law and with respect the District particular, see id. art. cl. (Congress shall have power [t]o exercise
exclusive Legislation all Cases whatsoever, over such District (not exceeding ten Miles
square) may become the Seat the Government the United States
The House previously has appeared amicus curiae related litigation concerning the
Local Budget Act itself,2 well numerous cases, both this Court,3 and other courts
around the country.4 While the Bipartisan Group seeks consensus whenever possible, it, like the
See Mem. the [House] Amicus Curiae, Council the Dist. Columbia Gray, No.
1:14-cv-00655 (D.D.C. May 2014) (ECF No. 32); Br. the [House] Amicus Curiae
Supporting Affirmance, Council the Dist. Columbia Gray, No. 14-7067 (D.C. Cir. Aug. 2014) (ECF No. 1506742); Mem. the [House] Amicus Curiae, Council the Dist.
Columbia Bowser, No. 2014 002371 (D.C. Super. Ct. Nov. 30, 2015).
See, e.g., Search The Rayburn House Office Bldg. Room No. 2113, 432 Supp.
100, 105 (D.D.C. 2006), rev sub nom., United States Rayburn House Office Bldg., 497 F.3d
654 (D.C. Cir. 2007); Byrd Raines, 956 Supp. 25, (D.D.C. 1997); United States Rose,
790 Supp. 340, 340 (D.D.C. 1992); United States Eichman, 731 Supp. 1123, 1127 n.6
(D.D.C. 1990); Webster Sun Co., 561 Supp. 1184, 1185 (D.D.C. 1983).
See, e.g., Br. Amici Curiae the [House] 225 Individual Members the U.S. House
Representatives Supp. Resp ts, Bank Markazi Peterson, No. 14-770 (S. Ct. Dec. 23,
2015); Br. Amicus Curiae the [House] Supp. Pet Renzi United States, No. 11-557 (S.
Ct. Dec. 2011); Br. the [House] Amicus Curiae, United States Renzi, No. 13-10588
(9th Cir. Apr. 18, 2014); Br. Amicus Curiae the [House] Supp. Appellant, United States Rainey, No. 13-30770 (5th Cir. Dec. 10, 2013); Br. the [House] Amicus Curiae
(Continued
Case 1:15-cv-01967-EGS Document Filed 03/31/16 Page
institution for which speaks, functions majoritarian basis when consensus cannot
achieved.5 March 30, 2016, conferred with Michael Bekesha, counsel for plaintiff Feldman,
who advised that his client consents the House participation here amicus. March 31,
2016, conferred with Richard Bress, counsel for defendant Bowser, and Andrew
Saindon, counsel for defendant DeWitt, both whom advised that their clients also not
object the relief sought. Proposed Order attached and oral argument not requested.
Respectfully submitted,
/s/ Kerry Kircher
KERRY KIRCHER
General Counsel (D.C. Bar No. 386816)
WILLIAM PITTARD
Deputy General Counsel (D.C. Bar No. 482949)
TODD TATELMAN (VA Bar No. 66008)
Senior Assistant Counsel
ELENI ROUMEL (SC Bar No. 75763)
Assistant Counsel
ISAAC ROSENBERG (D.C. Bar No. 998900)
Assistant Counsel
KIMBERLY HAMM (D.C. Bar No. 1020989)
Assistant Counsel
Supporting Affirmance, Cause Action Nat Archives Records Admin., No. 13-5127 (D.C.
Cir. Nov. 25, 2013); Br. the [House] Amicus Curiae Supporting Affirmance United
States Verrusio, No. 11-3080 (D.C. Cir. Feb. 2013). this case, the Democratic Leader and Democratic Whip oppose the filing the attached
memorandum.
Case 1:15-cv-01967-EGS Document Filed 03/31/16 Page
OFFICE GENERAL COUNSEL,
U.S. HOUSE REPRESENTATIVES
219 Cannon House Office Building
Washington, D.C. 20515
(202) 225-9700 (telephone)
(202) 226-1360 (facsimile)
Counsel for the Bipartisan Legal Advisory Group,
U.S. House Representatives
March 31, 2016
Case 1:15-cv-01967-EGS Document Filed 03/31/16 Page
CERTIFICATE SERVICE certify that March 31, 2016, filed and served the foregoing Unopposed Motion
the Bipartisan Legal Advisory Group the U.S. House Representatives for Leave File
Memorandum Amicus Curiae via the CM/ECF system the U.S. District Court for the
District Columbia, which understand served copy all parties for whom counsel has
entered appearance operation the Court CM/ECF system
/s/ Sarah Clouse
Sarah Clouse
Case 1:15-cv-01967-EGS Document 18-1 Filed 03/31/16 Page THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT COLUMBIA
__________________________________________
CLARICE FELDMAN,
Plaintiff,
Case No. 15-cv-01967-EGS
MURIEL BOWSER, her official capacity Mayor the District Columbia, al.,
Defendants.
__________________________________________)
MEMORANDUM THE BIPARTISAN LEGAL ADVISORY GROUP THE U.S. HOUSE REPRESENTATIVES AMICUS CURIAE
The Bipartisan Legal Advisory Group the U.S. House Representatives House
respectfully urges the Court deny defendants motions dismiss,1 and reach the merits
plaintiff claim that the District Columbia Local Budget Autonomy Act 2012, D.C. Law
19-321 (publ. D.C. Register Feb. 15, 2013) Local Budget Act invalid. See Compl. for
Declaratory Injunctive Relief, Count One (Nov. 2015) (ECF No. 1).
INTRODUCTION the Court aware, 1973, the exercise its exclusive Legislati[ve] authority
over the District Columbia, U.S. Const. art. cl. 17, Congress delegated the District
certain home rule authority way the District Columbia Self-Government and
Governmental Reorganization Act, Pub. No. 93-198, Stat. 774 (Dec. 24, 1973), codified
amended D.C. Code 1-201.01 1-207.71 (2016) Home Rule Act doing so,
Congress specifically reserved for itself plenary authority over the District spending, including
See Def. Muriel Bowser Mot. Dismiss (Feb. 2016) (ECF No. 10) Mayor Motion
Def. Jeffrey Dewitt Mot. Dismiss (Feb. 2016) (ECF No. CFO Motion
Case 1:15-cv-01967-EGS Document 18-1 Filed 03/31/16 Page
its spending locally-derived funds. See Home Rule Act 446 (stating, prior purported
amendment Local Budget Act, that [n]o amount may obligated expended any
officer employee the District Columbia government unless such amount has been
approved Act Congress, and then only according such Act. Because the
Appropriations Clause mandates that [n]o Money shall drawn from the Treasury, but
Consequence Appropriations made Law, U.S. Const. art. cl. the District
authority obligate and spend funds, including locally-derived funds, depends entirely the
annual enactment Congress legislation appropriating such funds. See, e.g., United States
MacCollom, 426 U.S. 317, 321 (1976) [T]he expenditure public funds proper only when
authorized Congress (emphasis added).
The Local Budget Act purports change these constitutional and statutory mandates by, particular, replacing Congress affirmative role legislating regarding the local portion
the [District annual budget with passive role which the District may expend locallyderived funds the absence any affirmative congressional action. D.C. Law 19-321, 2(e). other words, the Local Budget Act turns the Appropriations Clause upside down, and
inconsistent with Congress plenary authority over all District appropriations. The only
constitutionally permissible manner which the District may achieve budget autonomy with
respect locally-derived funds for Congress convey that authority the District way
the normal legislative process and Congress has not yet done that. effort prevent this Court from reaching the merits Ms. Feldman challenge
the validity the Local Budget Act, both defendants have moved dismiss. The Mayor says
Ms. Feldman lacks standing, the case moot, the Court lacks subject matter jurisdiction, and the
Court should abstain from reaching the merits. See Mayor Mot. 6-11, 12-16, 16-17, 17-23.
Case 1:15-cv-01967-EGS Document 18-1 Filed 03/31/16 Page
For his part, the District Chief Financial Officer CFO has moved dismiss only
standing and abstention grounds. See CFO Mot. 9-14, 14-16.
While the House agrees with Ms. Feldman that she has standing, that her claim not
moot, and that this Court has jurisdiction, see Pl. Opp Defs. Mots. Dismiss 9-13, 13,
17-20 (Mar. 2016) (ECF No. 15), the House does not write separately regarding those issues.
The House does write separately support Ms. Feldman contention that this Court should
reach the merits her claim and should not abstain. See id. 13-17.
ARGUMENT their zeal circumvent the one constitutionally-mandated process for achieving local
budget autonomy, and secure some judicial stamp approval the Local Budget Act, the
organs the District government have litigated manner that best can described
something less than fully adversarial. particular, the CFO, alone and concert with Mayor
Gray prior Mayor Bowser election, repeatedly has chosen litigation options which suggest
that his ultimate aim was not win the case advancing all available colorable arguments (the
role fully adversarial defendant), but rather secure decision the merits case
which only the organs the District government were parties. Indeed, explain more
detail below, soon local court had been persuaded bless the Local Budget Act, the
Superior Court did recently, see Omnibus Order, Council the Dist. Columbia, al.
DeWitt, No. 2014 2371 (D.C. Super. Ct. Mar. 18, 2016) Omnibus Order the CFO
immediately abandoned the field, thereby precluding appeal. April 17, 2014, the District Council sued the District Mayor and the District CFO the District Superior Court what District Delegate Eleanor Holmes Norton candidly
described friendly lawsuit. See Press Release, Delegate Norton Statement D.C.
Case 1:15-cv-01967-EGS Document 18-1 Filed 03/31/16 Page
Council Lawsuit Budget Autonomy Referendum (Apr. 17, 2014), available
http://norton.house.gov/media-center/press-releases/norton-statement-on-dc-council-lawsuit-onbudget-autonomy-referendum [T]here should mistaking the Council action for the
usual adversarial lawsuit. Today action friendly litigation the Court aware, that action was removed this Court, and this Court
determined that the Local Budget Act was unlawful. See Council the Dist. Columbia
Gray, Supp. 134, 155-56 (D.D.C. 2014), vacated sub nom. Council the Dist.
Columbia Bowser, No. 14-7067, 2015 3450417 (D.C. Cir. May 27, 2015). the course the litigation before this Court, the CFO and Mayor Gray never raised any jurisdictional
arguments, such lack standing the part the Council lack ripeness,
notwithstanding the availability them those arguments. See, e.g., Mem. the [House] Amicus Curiae n.5 (D.D.C. May 2014) (ECF No. 32) House Amicus appeal, the CFO and Mayor Gray again declined raise jurisdictional arguments,
even though the D.C. Circuit invited them raise standing arguments. See Order, Council the
Dist. Columbia Gray, No. 14-7067 (D.C. Cir. Oct. 10, 2014) (ECF No. 1516602) [C]ounsel should prepared address oral argument whether the Council the District
Columbia has Article III standing maintain this action. Instead, the CFO and Mayor Gray
took the highly unusual step filing supplemental brief support the Council standing,
insisting that the Court must decide this case the merits. Suppl. Br. for Appellees Mayor
Vincent Gray [CFO] Jeffrey DeWitt Council the Dist. Columbia Gray, No. 147067 (D.C. Cir. Oct. 15, 2014) (ECF No. 1517115). Subsequently, after the Council appeal had been fully briefed and argued, newlyelected Mayor Bowser switched sides. See Def. Muriel Bowser Resp. the Court Feb. 20,
Case 1:15-cv-01967-EGS Document 18-1 Filed 03/31/16 Page
2015 Order Unopposed Mot. for Leave File Suggestion Mootness Mot. Dismiss,
Council the Dist. Columbia Gray, No. 14-7067 (D.C. Cir. March 16, 2015) (ECF No.
1542578). She then suggested that the appeal was moot because there longer live
controversy between the Council and the Mayor. Id. The CFO still defendant-appellee
and purportedly party whose position was adverse that the Council below and appeal
did not contest Mayor Bowser suggestion mootness. See Resp. [CFO] Jeffrey Dewitt Mayor Muriel Bowser Suggestion Mootness Mot. Dismiss, Council the Dist.
Columbia Gray, No. 14-7067 (D.C. Cir. April 2015) (ECF No. 1546072). about the same time, the CFO actively joined with the Council and Mayor Bowser oppose the intervention Ms. Feldman the plaintiff this action whose intervention, had been permitted, certainly would have eliminated any possible questions about mootness and
the propriety the appeal proceeding. See Joint Opp Clarice Feldman Mot. Intervene,
Council the Dist. Columbia Gray, No. 14-7067 (D.C. Cir. April 15, 2015) (ECF No.
1547398). Subsequently, the D.C. Circuit dismissed the appeal with opinion and
explanation. See Order, Council the Dist. Columbia Bowser, No. 14-7067, 2015
3450417 (D.C. Cir. May 27, 2015) (ECF No. 1554308). Thereafter, the case was remanded
the District Superior Court where, once again, the CFO pointedly declined raise any
jurisdictional arguments, such lack standing and/or lack ripeness, even though those
arguments again were available him. See, e.g., UMC Dev., LLC Dist. Columbia, 120
A.3d 37, (D.C. 2015) Although the District Columbia courts were created under Article the U.S. Constitution, generally adhere the case and controversy requirement Article
III, and look federal standing jurisprudence when considering the issue plaintiff
Case 1:15-cv-01967-EGS Document 18-1 Filed 03/31/16 Page
standing. Dist. Columbia Craig, 930 A.2d 946, 967 (D.C. 2007) (dismissing claim
ripeness grounds). Finally, noted above, the Superior Court, without argument, put its stamp
approval the Local Budget Act March 18, 2016. See Omnibus Order. Within hours that
ruling, the CFO the sole defendant, the party whose position supposedly was adverse that
the Council and Mayor Bowser, and the sole party with right appeal announced that
would not appeal. See Press Release, STATEMENT CHIEF FINANCIAL OFFICER JEFFREY DEWITT the SUPERIOR COURT DECISION the BUDGET AUTONOMY ACT (Mar.
18, 2016), attached Ex. see also Press Release, Attorney General Racine Says Will Not
Seek Appeal Budget Autonomy Act Decision (Mar. 22, 2016), attached Ex. B.2
The Superior Court ruling badly flawed. While detailed critique that ruling must
await briefing the merits this case, the House here notes two its more glaring analytical
flaws. First, the Superior Court manufactured out whole cloth ambiguity around the word
existing 603(a) the Home Rule Act. See Omnibus Order 30. While 303 the
Home Rule Act permits the District amend certain portions its Charter, see D.C. Code 1203.03, 303(d) that Act prohibits the District from using that amendment procedure
enact any law affect any law with respect limitations specified section[] 603.
Id. 1-203.03(d). Section 603 the Act, which concerns the District borrowing and spending
authority, states clearly that the Home Rule Act shall [not] construed making any change existing law, regulation basic procedure and practice relating the respective roles the
Congress, [and] the President, the preparation, review, submission, examination,
authorization, and appropriation the total budget the District Columbia government. Id.
1-206.03(a). The plain import these provisions, this Court has noted, that 603(a)]
prevents changes the role Congress and the President with respect six areas related the
District budget preparation, review, submission, examination, authorization, and
appropriation. Gray, Supp. 147. The Superior Court, however, took those perfectly
straightforward statutory provisions and manufactured ambiguity: The use the word
existing suggests that 603(a) implication, does not preclude future efforts amend
the District budgetary process. Omnibus Order (emphasis added). That construction
603(a) facially nonsensical. enacting legislation that precluded the District from
amending its Charter with respect the respective roles the Congress, [and] the
President the preparation, review, submission, examination, authorization and
appropriation the total budget, Congress could not possibly logically have intended
permit the District amend its Charter rewrite those arrangements soon the ink was dry the Home Rule Act, which exactly what the Superior Court effectively concluded.
(Continued
Case 1:15-cv-01967-EGS Document 18-1 Filed 03/31/16 Page
The Local Budget Act naked and unabashed effort strip Congress powers vested Article the Constitution, and circumvent the constitutionally-prescribed legislative
process that the District and its supporters previously and repeatedly have acknowledged the
one constitutionally-appropriate way proceed. See House Amicus 11-15. such, the
validity the Local Budget Act should decided independent federal court
proceeding that truly and fully adversarial, and which the jurisdiction the Court
clear. This such case, while the Superior Court proceeding was not. And nothing evinces
this lack full adversity more clearly than the CFO hasty exit from the Superior Court
proceeding within hours that Court issuance its March ruling.
For all these reasons, the House urges this Court not abstain; deny defendants
motions dismiss; and proceed address the merits Ms. Feldman claim. This will
ensure that the Local Budget Act will considered proceeding that fully not just
somewhat adversarial; proceeding which someone other than organ the District
government will party; and proceeding which further review, should that become
appropriate, will available party other than organ the District government.
Second, the Superior Court misconstrued the Home Rule Act creation the D.C. General
Fund when implied that that Fund constituted permanent appropriation Congress the
District locally-derived revenue. See id. 36-37 the General Fund merely contains
financial resources derived from local revenues, the Government the District Columbia
able spend its local revenues held the General Fund without triggering the Anti-Deficiency
Act. There such thing implied appropriation any kind, let alone implied
permanent appropriation. See, e.g., U.S.C. 1301(d) law may construed make
appropriation out the Treasury only the law specifically states that appropriation
made General Accountability Office, Principles Federal Appropriations Law 2-16
(3d ed. 2004) [T]he rule that the making appropriation must expressly stated. see
also Gray, Supp. 153 [T]he weight authority, and the text the statute itself,
suggests that the creation the D.C. General Fund did not constitute permanent
appropriation.
Case 1:15-cv-01967-EGS Document 18-1 Filed 03/31/16 Page
Respectfully submitted,
/s/ Kerry Kircher
KERRY KIRCHER
General Counsel (D.C. Bar No. 386816)
WILLIAM PITTARD
Deputy General Counsel (D.C. Bar No. 482949)
TODD TATELMAN (VA Bar No. 66008)
Senior Assistant Counsel
ELENI ROUMEL (SC Bar No. 75763)
Assistant Counsel
ISAAC ROSENBERG (D.C. Bar No. 998900)
Assistant Counsel
KIMBERLY HAMM (D.C. Bar No. 1020989)
Assistant Counsel
OFFICE GENERAL COUNSEL
U.S. HOUSE REPRESENTATIVES
219 Cannon House Office Building
Washington, D.C. 20515
(202) 225-9700 (telephone)
(202) 226-1360 (facsimile)
Counsel for the Bipartisan Legal Advisory Group,
U.S. House Representatives
March 31, 2016
Case 1:15-cv-01967-EGS Document 18-1 Filed 03/31/16 Page THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT COLUMBIA
__________________________________________
CLARICE FELDMAN,
Plaintiff,
MURIEL BOWSER, her official capacity Mayor the District Columbia, al.,
Defendants.
__________________________________________)
Case No. 15-cv-01967-EGS
EXHIBIT
Case 1:15-cv-01967-EGS Document 18-1 Filed 03/31/16 Page
GOVERNMENT THE DISTRICT COLUMBIA
OFFICE THE CHIEF FINANCIAL OFFICER
OFFICE TAX AND REVENUE
FOR IMMEDIATE RELEASE
March 18, 2016
CONTACT: David Umansky
(202) 641-6024 (202) 255-9895
STATEMENT CHIEF FINANCIAL OFFICER JEFFREY DEWITT the
SUPERIOR COURT DECISION the BUDGET AUTONOMY ACT
There have been considerable differences opinion about budget autonomy for the
District. Judges, District officials, lawyers advocating for every point view, community
organizations and individual citizens all had different positions the legality the
Budget Autonomy Act. the District Chief Financial Officer, require clarity all financial matters order protect the District financial integrity. For this reason, needed definitive ruling
from the court this matter.
Now that have received direction from Superior Court, the city can develop its
budget independently and not Federal agency.
This ruling will benefit the District many ways, including eliminating the rating
agencies concerns about the impact Federal shutdowns and the historical delays
the Federal budget process. look forward working with the Mayor and Council make this new process efficient
and effective.
Case 1:15-cv-01967-EGS Document 18-1 Filed 03/31/16 Page THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT COLUMBIA
__________________________________________
CLARICE FELDMAN,
Plaintiff,
MURIEL BOWSER, her official capacity Mayor the District Columbia, al.,
Defendants.
__________________________________________)
Case No. 15-cv-01967-EGS
EXHIBIT
Case 1:15-cv-01967-EGS Document 18-1 Filed 03/31/16 Page
GOVERNMENT THE DISTRICT COLUMBIA
OFFICE THE ATTORNEY GENERAL
oag.dc.gov
FOR IMMEDIATE RELEASE: Tuesday, March 22, 2016
Contact:
Rob Marus, Communications Director: (202) 724-5646; robert.marus@dc.gov
Andrew Phifer, Public Affairs Specialist: (202) 741-7652; andrew.phifer@dc.gov
Attorney General Racine Says Will Not Seek Appeal Budget
Autonomy Act Decision
WASHINGTON, Attorney General Karl Racine today issued the below statement D.C. Superior
Court Judge Brian Holeman March decision upholding the legality the District Budget Autonomy Act:
Throughout this litigation, all interested parties the Mayor, the Council, the Chief Financial Officer, and
the Office the Attorney General have shared the ultimate goal gaining budget autonomy for the
District, but disagreed the legal means for achieving that goal. The Superior Court the District
Columbia has now ruled that the Budget Autonomy Act legal. Given the CFO decision not appeal, the
Office the Attorney General will not seek appellate review the Superior Court decision this case.
###
Connect with online:
oag.dc.gov Facebook Twitter Instagram YouTube
Case 1:15-cv-01967-EGS Document 18-2 Filed 03/31/16 Page THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT COLUMBIA
__________________________________________
CLARICE FELDMAN,
Plaintiff,
Case No. 15-cv-01967-EGS
MURIEL BOWSER, her official capacity Mayor the District Columbia, al.,
Defendants.
__________________________________________)
[PROPOSED] ORDER
UPON CONSIDERATION the Unopposed Motion the Bipartisan Legal Advisory
Group the U.S. House Representatives for Leave File Memorandum Amicus Curiae Motion and the entire record herein, the Court this _______ day ______________,
2016 ORDERED
That the Motion GRANTED. further ORDERED
That the Clerk forthwith shall DOCKET the Memorandum the Bipartisan Legal
Advisory Group the U.S. House Representatives Amicus Curiae, submitted with the
Motion.
_____________________________________
HONORABLE EMMET SULLIVAN,
United States District Judge
Copies to:
Kerry Kircher, General Counsel
OFFICE GENERAL COUNSEL
U.S. HOUSE REPRESENTATIVES
219 Cannon House Office Building
Washington, D.C. 20515
Counsel for the Bipartisan Legal Advisory Group, U.S. House Representatives
Case 1:15-cv-01967-EGS Document 18-2 Filed 03/31/16 Page
Michael Bekesha, Esq.
JUDICIAL WATCH, INC.
425 Third Street, S.W.
Suite 800
Washington, D.C. 20024
Counsel for Plaintiff Clarice Feldman
Andrew Saindon, Sr. Assistant Attorney General
D.C. OFFICE ATTORNEY GENERAL
441 4th Street, N.W.
Sixth Floor South
Washington, D.C. 20001
Counsel the Honorable Jeffrey DeWitt, Chief Financial Officer the District Columbia
Richard Bress, Esq.
LATHAM WATKINS LLP
555 Eleventh Street, N.W.
Suite 1000
Washington, D.C. 20004
Counsel for Defendant the Honorable Muriel Bowser, Mayor the District Columbia