Case: 3:15-cv-00421-bbc Document #: 116-5 Filed: 05/02/16 Page 1 of 26
-Sound like everyone is prepared to take the risk of the districts as they are. I'll let Keith
know and we should all focus on defending this map as is.
Thanks again Tad for pulling together figures.
--**TAD & ADAM : Did you confirm that every one of the 'non-contiguous' items fall
within the Wisconsin approved exception? Just want to make sure you've looked at
each one.
Jim
James R. Troupis
Troupis Law Office LLC
jrtroupis@troupislawofflCe.com
ph. 608-807-4096
This email and any attachments thereto may contain private, confidential and privileged
material for the sole use of the intended recipient. Any review, copying, or distribution of
this email (or any attachments thereto) by others is strictly prohibited. If you are not the
intended reCipient, please contact the sender immediately and permanently delete the
original and any copies of this email and any attachments thereto.
From: tottman [mailto:tottman@gmail.coml
Sent: Sunday. July 17. 2011 4:35 PM
To: Taffora. Raymond P (22244)
Cc: jrtroupis@troupislawoffice.com; adamfoltz@gmail.com; McLeod, Eric M (22257)
Subject: Re: Wisconsin Hispanic Districts
For discussion and analysis purposes I have attempted to recreate the Democracy
Campaign's map in the attachment I first attempted to faithfully recreate what they had
produced, but it appeared to be dramatically underpopulated and improperly balanced
Produced 10/1612012 (34 Total Emails)
EVANS 0026
Case: 3:15-cv-00421-bbc Document #: 116-5 Filed: 05/02/16 Page 2 of 26
between the districts. I added a couple of wards so that population was no more than
0.8% off and slightly altered the districts boundaries to provide a better balance. The
respective HVAPs are noted on the map.
It appears that they simply worked off the present map and then added and subtracted a
few wards. I've included the present district outline as an overlay.
The court map created districts with HVAP's of AD 8 at 58.34%, AD 9 at 22.94%, and
SO 3 at approximately 28.5%.
I agree that we should stick to the previously discussed plan for passage on Tuesday.
The only outstanding issue that remains is the amendment to change "shall" to "may" in
S8 150 (page 20; line 4). I have had that amendment drafted as a simple amendment
to the bill.
On Sun, Jul17, 2011 at 3:51 PM, Taffora, Raymond P (22244)
<rptaffora@michaelbestcom> wrote:
All:
We have our maps as recommended by the Senate Committee. No further amendments
are necessary. Its too late now for further amendments as concerns the Hispanic
districts.
Ray
From: Jim Troupis [mailto:jrtroupis@troupislawoffice.com]
Sent Sunday, July 17, 2011 02:53 PM
To: tottman <tottman@gmail.com>
Cc: adam foltz <adamfoltz@gmail.com>; Mcleod, Eric M (22257); Taffora, Raymond P
(22244)
Subject: RE: Wisconsin Hispanic Districts
Tad & ALL,
I just did a long email, but I think it got lost. Sorry if I am repeating myself. I just spent an
hour on the phone with Keith G and we have a number of issues we need to address
Produced 1011612012 (34 Total Emails)
EVANS 0027
Case: 3:15-cv-00421-bbc Document #: 116-5 Filed: 05/02/16 Page 3 of 26
today. Do not send things related to these requests directly to Keith as from here on I
expect he will be a witness, and will be deposed and this may become public. When I
get the numbers I can talk with him, rather than email.
1.) As I had speculated, the citizenship numbers are important. Can you overlay the
ACS citizenship data. (American Community Survey)? I've asked Keith to talk today to
Clark Benson, who worked with us the last time, to see if he can overlay that data, in the
event we can not, onto the 2002 and the 60/54 districts.
2.) Can you provide the data again on the 2002 Hispanic district drawn by the court and
compare it to the 60/54 & Senate district? This would be important to any decision to
change anything further as obviously that district elected Hispanic representatives. I
know I've had that, but could not locate it this afternoon.
3.} The problem here is that Keith believes that no matter how you draw the district,
there is not an Hispanic majority district when you consider turnout, but by the same
token there is no history at all of racially polarized voting . So, as a consequence he
believes he can testify in support of a 60/54 and he is more comfortable with that than
the 57/57.
4.) Compactness: Can you run the compactness score for the 60/54 configuration
districts 7, 8. 9 and compare that to the rest of the map? Would like to see what comes
.
5 .} WISconsin Democracy Campaign: Attached is the only alternative out there-the
Wisconsin Democracy Campaign. Keith thinks this looks like our map. I'm not sure.
Could you do your best to reconstruct it and then let us know what the numbers look
like?
Sorry to bother you on a Sunday. but as they say this could be the 'ball game'. We want
to make sure we have all we need to make the appropriate decision. If you can get this
to us today or at the latest very early tomorrow morning, we can then talk and make
then decide what if anything to do.
Thanks Tad.
Jim
James R. Troupis
Produced 101J612012 (34 Total EmaHs)
EVANS 0028
Case: 3:15-cv-00421-bbc Document #: 116-5 Filed: 05/02/16 Page 4 of 26
Troupis Law Office LLC
jrtroupis@troupislawoffice.com
ph. 608-807-4096
This email and any attachments thereto may contain private, confidential and privileged
material for the sale use of the intended recipient. Any review, copying, or distribution of
this email (or any attachments thereto) by others is strictly prohibited. If you are not the
intended recipient, please contact the sender immediately and permanently delete the
original and any copies of this email and any attachments thereto.
From: tottman (mailto:tottman@qmail.coml
Sent: Sunday, July 17, 2011 11 :40 AM
To: Keith Gaddie
Cc: adam foltz; Jim Troupis; McLeod, Eric M (22257); Taffora, Raymond P (22244)
Subject: Wisconsin Hispanic Districts
Keith,
Jim Troupis asked that I have you take a look at the amendment that was adopted in
committee on the hispanic districts. Here is the link to the interactive maps:
http://leqis.wisconsin.govlltsbJredistrictlnglbills.htm
Amendment 2 was the configuration that was adopted. The HVAP in AD 8 is 60.5 %
and in AD 9 it is 54%. The incumbent lives in AD 8 and AD 9 is open under all
alternatives.
There was testimony by 2 different hispanic groups in favor of the configuration in
amendment 2. No one that I'm aware of testified in favor of either the bill configuration
(AD 8 HVAP 57.2%, AD 9 HVAP 57.2%) or in favor of amendment 1 (AD 8 HVAP 64%,
AD 9 HVAP 50%).
Produced ]0/16/2012 (34 Total Emails)
EVANS 0029
Case: 3:15-cv-00421-bbc Document #: 116-5 Filed: 05/02/16 Page 5 of 26
Jim was gong to call you later today to get your thoughts if you have a chance to take a
look at the amendment.
Thanks,
Tad Ottman
Unless otherwise expressly indicated, if this email, or any attachment
hereto, contains advice concerning any federal tax issue or
SUbmission, please be advised that the advice was not intended or
wricten to be used, and that it cannot be used, for the purpose of
avoiding federal tax penalties.
The information contained in this communication may be confidential,
is intended only for the use of the recipient(s) named above, and may
be legally privileged. If the reader of this message is not the
intended recipient, you are hereby notified "that any dissemination,
distribution, or copying of this communication, or any of its
contents, is strictly prohibited. If you have received this
communication in error, please return i t to the sender immediately and
delete the original message and any copy of it from your computer
system. If you have any
concerning this message, please
contact the sender.
Produced 10/1612012 (34 Total Emails)
EVANS 0030
Case: 3:15-cv-00421-bbc Document #: 116-5 Filed: 05/02/16 Page 6 of 26
To:
Jim TroupisUrtroupis@lroupislawoffice.com)
Cc:
Taifora, Raymond P (22244)[rptaffora@michaelbest.cOm);
adamfollz@gmail.com[adamfoltz@gmaiLcom); McLeod. Eric M (22257)[EMMcleod@michaelbesl.com)
From:
tottman
Sent
Mon 7/1812011 1:56:33 AM
Subject: Re: Wisconsin Hispanic Districts
The software we use generates a report of all non-contiguous areas that require
individual examination. Adam and I have each examined these areas multiple times
and found no discontiguous areas that didn't fall within the law. We'll take another pass
through the map tomorrow to confirm .
On Sun, Jul17, 2011 at 7:46PM, Jim Troupis <jrtroupis@troupislawoffice.com> wrote:
All,
To be clear for everyone, evaluating everything now and understanding what weare
in for is a critical exercise. Obviously the maps will be tested very seriously in court,
and equally obvious is that we can predict at this point some of those challenges.
We all appreCiate that there has been an enormous amount of work that has gone
into this, and that the choices were made based on the best information we have
had at the time.
Also, in the event the recalls are successful for the Democrats there will be a
limitless war chest, I assume, to pay experts and attorneys on the other side so
everyone's analysis will be tested at every tum. (Not that they don't already have
that war chest in place ....)
--As we discussed throughout,a key litigation strategy was to have the 3 assembly
districts encompass virtually all the area in question so that a Court, even if it is
concerned about percentages, can simply correct those districts within the senate
district. In 1981 in the Illinois that was our strategy-we were the plaintiffs seeking
only to help one representative-and the Supreme Court of JlJinois took that option (a
win for the party, but no change to the balance of the map).
-The citizenship issue is being played out in the Carolina's already, as well as
Florida. We will need to know that information and have a very clear idea of how to
approach it.
-The USDOJ is certainly gOing to look at the Wisconsin maps starting with their
passage. It will not be surprising if AG Holder brings some type of action because
Obama's Presidency could hang in the balance of how Wisconsin votes. This next
week 1'1\ try to get the legal arguments that are playing out on this and other issues
from counsel around the country so we can be better prepared when they come
here, as well. 1'1\ try to circulate something later in July.
Produced 1011612012 (34 Total Emails)
EVANS 0031
Case: 3:15-cv-00421-bbc Document #: 116-5 Filed: 05/02/16 Page 7 of 26
-- One benefit of having Keith on Board is that he has been and continues to be
involved in other parts of the country. That provides needed insight.
-TAD-thank you for the numbers. It looks like they went to the 65/50 (poorly) map.
It also looks like the Hispanic community was able to elect a representative at a
lower HVAP than the proposed maps, so that certainly works against any challenge
premised on electability. Tomorrow, could you look-up the blue book numbers for the
elections immediately following the Court map and show the totals in primaries and
general for the Hispanic District. We should continue to build the case with real
elections, to the extent we can . Also, we will want to collect the data on any
Aldermanic and/or Supervisory districts in Milwaukee that had a Hispanic sumame
candidate in the past 10 years.·We can then compare those results against the
HVAP for those districts. Again, I am assuming those elections will show no
particular animus against Hispanic candidates and show election of Hispanic
candidates in areas where there were significantly lower % than the two Assembly
districts of the map.
-Sound like everyone is prepared to take the risk of the districts as they are. I'll let
Keith know and we should all focus on defending this map as is.
Thanks again Tad for pulling together figures.
- **TAD & ADAM: Did you confirm that every one of the 'non-contiguous' items fall
within the Wisconsin approved exception? Just want to make sure you've looked at
each one.
Jim
James R. Troupis
Troupis Law Office LLC
jrtroupis@troupislawoffice.com
ph. 608-807-4096
Produced 1011612012 (34 Total Emails)
EVANS 0032
Case: 3:15-cv-00421-bbc Document #: 116-5 Filed: 05/02/16 Page 8 of 26
This email and any attachments thereto may contain private, confidential and
privileged material for the sole use of the intended recipient. Any review, copying, or
distribution of this email (or any attachments thereto) by others is strictly prohibited.
If you are not the intended recipient, please contact the sender immediately and
permanently delete the original and any copies of this email and any attachments
thereto.
From: tottman [mailto:tottman@gmail.com]
Sent: Sunday, July 17,20114:35 PM
To: Taffora, Raymond P (22244)
Cc: jrtroupis@troupislawoffice.com; adamfoltz@gmail.com; McLeod, Eric M (22257)
Subject: Re: Wisconsin Hispanic Districts
For discussion and analysis purposes I have attempted to recreate the Democracy
Campaign's map in the attachment. I first attempted to faithfully recreate what they
had produced, but it appeared to be dramatically underpopulated and improperly
balanced between the districts. I added a couple of wards so that population was no
more than 0.8% off and slightly altered the districts boundaries to provide a better
balance. The respective HVAPs are noted on the map.
It appears that they simply worked off the present map and then added and
subtracted a few wards. I've included the present district outline as an overlay.
The court map created districts with HVAP's of AD 8 at 58.34%, AD 9 at 22.94%,
and SO 3 at approximately 28.5%.
I agree that we should stick to the previously discussed plan for passage on
Tuesday.
The only outstanding issue that remains is the amendment to change "shall" to
-may" in S8 150 (page 20, line 4). I have had that amendment drafted as a simple
amendment to the bill.
On Sun, Jul17, 2011 at 3:51 PM, Taffora, Raymond P (22244)
<rptaffora@michaelbest.com> wrote:
Produced 10/1612012 (34 Total Emails)
EVANS 0033
Case: 3:15-cv-00421-bbc Document #: 116-5 Filed: 05/02/16 Page 9 of 26
All:
We have our maps as recommended by the Senate Committee. No further
amendments are necessary. Its too late now for further amendments as concerns
the Hispanic districts.
Ray
From: Jim Troupis [mailto:jrtroupis@troupislawoffice.coml
Sent Sunday, July 17, 2011 02:53 PM
To: tottman <tottman@gmail.com>
Cc: adam foltz <adamfoltz@gmail.com>; Mcleod, Eric M (22257); Taffora,
Raymond P (22244)
Subject: RE: WISconsin Hispanic Districts
Tad & ALL,
I just did a long email, but I think it got lost Sorry if I am repeating myself. I just spent
an hour on the phone with Keith G.and we have a nlimber of issues we need to
address today. Do not send things related to these requests directly to Keith as from
here on I expect he will be a witness, and will be.deposed and this may become
public. When I get the numbers I can talk with him, rather than email.
1.) As I had speculated, the citizenship numbers are important Can you overlay the
ACS citizenship data. (American Community Survey)? I've asked Keith to talk today
to Clark Benson, who worked with us the last time, to see if he can overlay that data,
.
in the event we cannot, onto the 2002 and the 60154 districts.
2.) Can you provide the data again on the 2002 Hispanic district drawn by the court
and compare it to the 60/54 & Senate district? This would be important to any
decision to change anything further as obviously that district elected Hispanic
representatives. I know I've had that, but could not locate it this afternoon.
3.) The problem here is that Keith believes that no matter how you draw the district,
there is not an Hispanic majority district when you consider turnout, but by the same
token there is no history at all of racially polarized voting. So, as a consequence he
believes he can testify in support of a 60/54 and he is more comfortable with that
than the 57/57.
4.) Compactness: Can you run the compactness score for the 60/54 configuration
districts 7, 8, 9 and compare that to the rest of the map? Would like to see what
comes of it.
Produced 10/1612012 (34 Total Emails)
EVANS 0034
Case: 3:15-cv-00421-bbc Document #: 116-5 Filed: 05/02/16 Page 10 of 26
5.) Wisconsin Democracy Campaign: Attached is the only alternative out there-the
Wisconsin Democracy Campaign. Keith thinks this looks like our map. I'm not sure.
Could you do your best to reconstruct it and then let us know what the numbers look
like?
Sorry to bother you on a Sunday, but as they say this could be the 'ball game'. We
want to make sure we have all we need to make the appropriate decision . If you can
get this to us today or at the latest very early tomorrow morning, we can then talk
and make then decide what if anything to do.
Tt!anks Tad.
Jim
James R. Troupis
Troupis Law Office LLC
jrtroupis@troupislawoffice.com
ph. 608-807-4096
This email and any attachments thereto may contain private, confidential and
privileged material for the sale ,use of the intended recipient. Any review, copying, or
distribution ofthis email (or any attachments thereto) by others is strictly prohibited.
If you are not the intended
please contact the sender immediately and
permanently delete the original and any copies of this email and any attachments
thereto.
From: tottman [mailto:tottman@gmaiLcoml
Sent: Sunday, July 17, 201111:40 AM
To: Keith Gaddie
Cc: adam foltz; Jim Troupis; McLeod, Eric M (22257); Tartora, Raymond P (22244)
Subject: Wisconsin Hispanic Districts
Produced 1011612012 (34 Total Emails)
EVANS 0035
Case: 3:15-cv-00421-bbc Document #: 116-5 Filed: 05/02/16 Page 11 of 26
Keith,
Jim Troupis asked that I have you take a look at the amendment that was adopted in
committee on the hispanic districts. Here is the link to the interactive maps:
http://legis.wisconsin.goviltsb/redistrictingibills.htm
Amendment 2 was the configuration that was adopted. The HVAP in AD 8 is 60.5 %
and in AD 9 it is 54%. The incumbent lives in AD 8 and AD 9 is open under all
alternatives.
There was testimony by 2 different hispanic groups in favor of the conflQuration in
amendment 2. No one that I'm aware of testified in favor of either the bill
configuration (AD 8 HVAP 57.2%, AD 9 HVAP 57.2%) or in favor of amendment 1
(AD 8 HVAP 64%, AD 9 HVAP 50%).
Jim was gong to call you later today to get your thoughts if you have a chance to
take a look at the amendment
Thanks,
Tad Ottman
..........
..........
•• , ••••• * ••• * •• *.* ••• •••••••••••
Unless otherwise expressly indicated, if this email, or any attachment
hereto, contains advice concerning any federal tax issue or
submission, please be advised that the advice was not intended or
written to be used, and that it cannot be used, for the purpose of
avoiding federal tax penalties.
The information contained in this communication may be confidential,
is intended only for the use of the recipient(s) named above, and may
be legally privileged. If the reader of this message is not the
ill t ended re c ipient, you are her e by notiIied that any d is semi natioll,
dis t r i bution, or c opying of this c ommunicati o n, o r any o f i ts
c o nten t s, is s trictly pro hibited.
If yo u have re ceived thi s
commun i c at ion in error, please return it t o t he s ender immediately and
Produced 1011612012 (34 Total Emails)
EVANS 0036
Case: 3:15-cv-00421-bbc Document #: 116-5 Filed: 05/02/16 Page 12 of 26
delete the original message and any copy of it from your computer
s ystem.
If you have any question s concerninq this message, please
con tact t he sender.
Produced 10/16/2012 (34 Total Emails)
EVANS 0037
Case: 3:15-cv-00421-bbc Document #: 116-5 Filed: 05/02/16 Page 13 of 26
To:
tottman[tottman@gmaiJ.com]: Taffora, Raymond P (22244)[rptaffora@michaelbesl.com]
Cc:
adamfollz@gmail.com[adamfoltz@gmail.com): McLeod, Eric M
(22257j[EMMcleod@michaelbesl.com]
From:
Jim Troupis
Sent:
Mon 7/1812011 12:46:55 AM
Subject RE: Wisconsin Hispanic Districts
All,
To be clear for everyone, evaluating everything now and understanding what we are in
for is a critical exercise. Obviously the maps will be tested very seriously in court, and
equally obvious is that we can predict at this point some of those challenges. We all
appreciate that there has been an enormous amount of work that has gone into this,
and that the choices were made based on the best information we have had at the time.
Also, in the event the recalls are successful for the Democrats there will be a limitless
war chest, I·assume, to pay experts.and attorneys on the other side so everyone's
analysis will be tested at every turn. (Not that they don't already have that war chest in
place .. .. )
-As we discussed throughout, a key litigation strategy was to have the 3 assembly
districts encompass virtually all the area in question so that a Court, even if it is
concerned about percentages, can simply correct those districts within the senate
district. In 1981 in the Illinois that was our strategy-we were the plaintiffs seeking only
to help one representative-and the Supreme Court of Illinois took that option (a win for
the party, but no change to the balance of the map).
--The citizenship issue is being played out in the Carolina'S already, as well as Florida.
We will need to know that information and have a very clear idea of how to approach it.
- The USDQJ is certainly going to look at the Wisconsin maps starting with their
passage. It will not be surprising if AG Holder brings some type of action because
Obama's Presidency could hang in the balance of how Wisconsin votes. This next week
I'll try to get the legal arguments that are playing out on this and other issues from
counsel around the country so we can be better prepared when they come here, as
well. I'll try to circulate something later in July.
- One benefit of having Keith on Board is that he has been and continues to be involved
in other parts of the country. That provides needed inSight.
--TAD-thank you for the numbers. It looks like they went to the 65/50 (poorly) map. It
also looks like the Hispanic community was able to elect a representative at a lower
HVAP than the proposed maps, so that certainly works against any challenge premised
on electability. Tomorrow, could you look-up the blue book numbers for the. elections
immediately following the Court map and show the totals in primaries and general for
the Hispanic District. We should continue to build the case with real elections, to the
Produced 10/16/2012 (34 Total Emails)
EVANS 0038
Case: 3:15-cv-00421-bbc Document #: 116-5 Filed: 05/02/16 Page 14 of 26
extent we can. Also, we will want to collect the data on any Aldennanic and/or
Supervisory districts in Milwaukee that had a Hispanic surname candidate in the past 10
years. We can then compare those results against the HVAP for those districts. Again, I
am assuming those elections will show no particular animus against Hispanic
candidates and show election of Hispanic candidates in areas where there were
significantly lower % than the two Assembly districts of the map.
--Sound like everyone is prepared to take the risk of the districts as they are. I'll let Keith
know and we should all focus on defending this map as is.
Thanks again Tad for pulling together figures.
-"TAD & ADAM: Did you confinn that every one of the 'non-contiguous' items fall
within the Wisconsin approved exception? Just want to make sure you've looked at
each one.
Jim
James R. Troupis
Troupis Law Office LLC
jrtroupis@troupislawoffice.com
ph. 608-807-4096
This email and any attachments thereto may contain private, confidential and privileged
material for the sale use of the intended recipient. Any review, copying, or distribution of
this email (or any attachments thereto) by others is strictly prohibited. If you are not the
intended recipient, please contact the sender immediately and pennanently delete the
original and any copies of this email and any attachments thereto.
From: tottman [mailto:tottman@gmail.com]
Sent: Sunday, July 17, 2011 4:35 PM
To: Taffora, Raymond P (22244)
Produced 10/1612012 (34 Total Emails)
EVANS 0039
Case: 3:15-cv-00421-bbc Document #: 116-5 Filed: 05/02/16 Page 15 of 26
Cc: jrtroupis@troupislawoffice.com ; adamfoltz@gmail.com ; McLeod, Eric M (22257)
Subject: Re: Wisconsin Hispanic Districts
For discussion and analysis purposes I have attempted to recreate the Democracy
Campaign's map in the attachment. I first attempted to faithfully recreate what they had
produced, but it appeared to be dramatically underpopulated and improperly balanced
between the districts. I added a couple of wards so that population was no more than
0.8% off and slightly altered the districts boundaries to provide a better balance. The
respective HVAPs are noted on the map.
It appears that they simply worked off the present map and then added and subtracted a
few wards. I've included the present district outline as an overlay.
The court map created districts with HVAP's of AD 8 at 58.34%, AD 9 at 22.94%, and
SD 3 at approximately 28.5%.
I agree that we should stick to the previously discussed plan for passage on Tuesday.
The only outstanding issue that remains is the amendment to change "shaD" to "may" in
S8 150 (page 20, line 4). I have had that amendment drafted as a simple amendment
to the bill.
On Sun, Ju117, 2011 at 3:51 PM, Taffora, Raymond P (22244)
<rptaffora@michaelbest.com> wrote:
All:
We have our maps as recommended by the Senate Committee. No further amendments
are necessary. Its too late now for further amendments as concerns the Hispanic
districts.
Ray
From: Jim Troupis [mailto:jrtroupis@troupislawoffice.com]
Sent: Sunday, July 17, 2011 02:53 PM
To: tottman <tottman@gmail.com>
Cc: adam foltz <adamfoltz@gmail.com>; McLeod, Eric M (22257); Taffora, Raymond P
Produced 10/1612012 (34 Total Emails)
EVANS 0040
Case: 3:15-cv-00421-bbc Document #: 116-5 Filed: 05/02/16 Page 16 of 26
(22244)
Subject: RE: Wisconsin Hispanic Districts
Tad & ALL,
I just did a long email, but I think it got lost. Sorry if I am repeating myself. I just spent an
hour on the phone with Keith G and we have a number of issues we need to address
today. Do not send things related to these requests directly to Keith as from here on I
expect he will be a witness, and will be deposed and this may become public. When I
get the numbers I can talk with him, rather than email.
1.) As I had speculated, the Citizenship numbers are important. Can you overlay the
ACS citizenship data. (American Community Survey)? I've asked Keith to talk today to
Clark Benson, who worked with us the last time, to see if he can overlay that data, in the
event we can not, onto the 2002 and the 60/54 districts.
2.) Can you provide the data again on the 2002 Hispanic district drawn by the court and
compare it to the 60/54 & Senate district? This would be important to any decision to
change anything further as obviously that district elected Hispanic representatives. I
know I've had that, but could not locate it this afternoon.
3.} The problem here is that Keith believes that no matter how you draw the district,
there is not an Hispanic majority district when you consider turnout, but by the same
token there is no history at all of racially polarized voting. So, as a consequence he
believes he can testify in support of a 60/54 and he is more comfortable with that than
the 57/57.
4.) Compactness: Can you run the compactness score for the 60/54 configuration
districts 7, 8, 9 and compare that to the rest of the map? Would like to see what comes
of it.
5.) Wisconsin Democracy Campaign: Attached is the only alternative out there-the
Wisconsin Democracy Campaign. Keith thinks this looks like our map. I'm not sure.
Could you do your best to reconstruct it and then let us know what the numbers look
like?
Sorry to bother you on a Sunday, but as they say this could be the 'ball game'. We want
to make sure we have all we need to make the appropriate decision. If you can get this
to us today or at the latest very early tomorrow morning, we can then talk and make
then decide what if anything to do.
Thanks Tad.
Produced 10/16/2012 (34 Total Emails)
EVANS 0041
Case: 3:15-cv-00421-bbc Document #: 116-5 Filed: 05/02/16 Page 17 of 26
Jim
James R. Troupis
Troupis Law Office LLC
jrtroupis@troupislawoffice.com
ph. 608-8074096
This email and any attachments thereto may contain private, confidential and privileged
material for the sole use of the intended recipient. Any review, copying, or distribution of
this email (or any attachments thereto) by others is strictly prohibited. If you are not the
intended recipient, please contact the sender immediately and permanently delete the
original and any copies of this email and any attachments thereto.
From: tottman [mailto:tottman@gmail.coml
Sent: Sunday, July 17, 2011 11 :40 AM
To: Keith Gaddie
Cc: adam foltz; Jim Troupis; Mcleod, Eric M (22257); Taffora, Raymond P (22244)
Subject: Wisconsin Hispanic Districts
Keith,
Jim Troupis asked that I have you take a look at the amendment that was adopted in
comm ittee on the hispanic districts. Here is the link to the interactive maps:
http://iegis.wisconsin.govlltsb/redistrictinglbills.htm
Amendment 2 was the configuration that was adopted. The HVAP in AD 8 is 60.5 %
and in AD 9 it is 54% . The incumbent lives in AD 8 and AD 9 is open under all
alternatives.
Produced 10/16/2012 (34 Total Emails)
EVANS 0042
Case: 3:15-cv-00421-bbc Document #: 116-5 Filed: 05/02/16 Page 18 of 26
There was testimony by 2 different hispanic groups in favor of the configuration in
amendment 2. No one that I'm aware of testified in favor of either the bill configuration
1 (AD 8 HVAP 64%,
(AD 8 HVAP 57.2%, AD 9 HVAP 57.2%) or in favor of
AD 9 HVAP 50%).
Jim was gong to call you later today to get your thoughts if you have a chance to take a
look at the amendment.
Thanks,
Tad Ottman
••..•..............•.•........•.•••..•.•..••....••..••••.•••....•
Unless otherwise expres sly i ndicated, if this email, or any attachment
here to, c ontains advi ce concerning any federal tax issue or
submission, please be advised that the advice was not intended or
written to be used. and that it c annot be used, for the purpose of
avoiding federal tax penalties.
The information contained in this communication may be
is intended only for the use of· the recipient (s) named above, and may
be legally privileged.
If the reader of this message is not· the
intended recipient, you are hereby notified that any dissemination,
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c ontents, is str i ctly prohibited. If you have rece i ved t his
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c o ntact the sender.
Produced] 0/16/2012 (34 Total Emails)
EVANS 0043
Case: 3:15-cv-00421-bbc Document #: 116-5 Filed: 05/02/16 Page 19 of 26
,
To:
Tartora, Raymond P (22244)[rptaffora@rrichaelbesl.com]
Cc:
jrtroupiS@troupisJawoflice .com[jrtroupis@troupislawolfice.com);
adamfoltz@gmaU.com(adamfollz@gmail.com); Mcleod, Eric M (22257)[EMMcleod@michaelbest.com]
From:
tottman
Sent
Sun 7117120119:35:20 PM
Subject: Re: WISconsin Hispanic Districts
democracy campaign configuration. pdf
For discussion and analysis purposes I have attempted to recreate the Democracy
Campaign's map in the attachment. I first attempted to faithfully recreate what they had
produced, but it appeared to be dramatically underpopulated and improperly balanced
between the districts. I added a couple of wards so that population was no more than
0.8% off and slightly altered the districts boundaries to provide a better balance. The
respective HVAPs are noted on the map.
It appears that they simply worked dffthe present map and then added and subtracted a
few wards. I've included the present district outline as an overlay.
The court map created districts with HVAP's of AD 8 at 58.34%, AD 9 at 22.94%, and
SO 3 at approximately 28.5%.
I agree that we should stick to the previously discussed plan for passage on Tuesday.
The only outstanding issue that remains is the amendment to change "shall" to "may· in
S8 150 (page 20, line 4). I have had that amendment drafted as a simple amendment
to the bill.
On Sun, Jul17, 2011 at 3:51 PM, Taffora, Raymond P (22244)
<rptaffora@michaelbest.com> wrote:
All:
We have our maps as recommended by the Senate Committee. No further
amendments are necessary. Its too late now for further amendments as concems
the Hispanic districts.
Ray
From: Jim Troupis [mailto:jrtroupis@troupislawoffice.coml
Sent: Sunday, July 17, 2011 02:53 PM
To: tottman <tottman@gmail.com>
Cc: adam foltz <adamfoltz@gmail.com>; McLeod , Eric M (22257); Taffora,
Raymond P ,(22244)
Subject: RE: Wisconsin Hispanic Districts
J)roduccd 10116/2012 (34 Total Emails)
EVANS 0044
Case: 3:15-cv-00421-bbc Document #: 116-5 Filed: 05/02/16 Page 20 of 26
Tad & ALL,
I just did a long email, but I think it got lost. Sorry if I am repeating myself. I just spent
an hour on the phone with Keith G and we have a number of issues we need to
address today. Do not send things related to these requests directly to Keith as from
here on I expect he will be a witness, and will be deposed and this may become
public. When I get the numbers I can talk with him, rather than email.
1.) As I had speculated, the citizenship numbers are important. Can you overlay the
ACS citizenship data. (American Community Survey)? I've asked Keith to talk today
to Clark Benson, who worked with us the last time, t.o see if he can overlay that data,
in the event we can not, onto the 2002 and the 60/54 districts.
2.) Can you provide the data again on the 2002 Hispanic district drawn by the court
and compare it to the 60/54 & Senate district? This would be important to any
decision to change anything further as obviously that district elected Hispanic
representatives. I know I've had that, but could not locate it this afternoon.
3.) The problem here is that Keith believes that no matter how you draw the district,
there is not an Hispanic majority district when you consider turnout, but by the same
token there is no history at all of racially polarized voting. So, as a consequence he
believes he can testify in support of a 60/54 and he is more comfortable with that
than the 57/57 .
4.) Compactness: can you run the compactness score for the 60/54 configuration
districts 7, 8, 9 and compare thalto the rest of the map? Would like to see what
comes of it.
5.) Wisconsin Democracy Campaign: Attached is the only alternative out there-the
Wisconsin Democracy Campaign. Keith thinks this looks like our map. I'm not sure.
Could you do your best to reconstruct it and then let us know what the numbers look
like?
Sorry to bother you on a Sunday, but as ttiey say this could be the 'ball game'. We
want to make sure we have all we need to make the appropriate decision. If you can
get this to us today or at the latest very early.tomorrow morning, we can then talk
and make then decide what if anything to do.
Thanks Tad.
Produced 10/J6/20J2 (34 Total Emails)
EVANS 0045
Case: 3:15-cv-00421-bbc Document #: 116-5 Filed: 05/02/16 Page 21 of 26
Jim
James R. Troupis
Troupis Law Office LLC
jrtroupis@troupislawoffice.com
ph. 608-807-4096
This email and any attachments thereto may contain private, confidential and
privileged material for the sale use of the intended recipient. Any review, copying, or
distribution of this email (or any attachments thereto) by others is strictly prohibited .
If you are not the intended recipient, please contact the sender immediately and
permanently delete the original and any copies of this email and any attachments
thereto.
From: totbnan [mailto:tottman@gmail.coml
Sent: Sunday, July 17, 201111:40 AM
To: Keith Gaddie
Cc: adam foltz; Jim Troupis; McLeod, Eric M (22257); Taftora, Raymond P (22244)
Subject: Wisconsin Hispanic Districts
Keith,
Jim Troupis asked that I have you take a look at the amendment that was adopted in
committee on the hispanic districts. Here is the link to the interactive maps:
http://legis.wisconsin .govlltsb/redistricting/bills.htm
Amendment 2 was the configuration that was adopted. The HVAP in AD 8 is 60.5 %
and in AD 9 it is 54%. The incumbent lives in AD 8 and AD 9 is open under all
alternatives.
Produced 10/1612012 (34 Total Emails)
EVANS 0046
Case: 3:15-cv-00421-bbc Document #: 116-5 Filed: 05/02/16 Page 22 of 26
There was testimony by 2 different hispanic groups in favor of the configuration in
amendment 2. No one that I'm aware of testified in favor of either the bill
configuration (AD 8 HVAP 57.2%, AD 9 HVAP 57.2%) or in favor of amendment 1
(AD 8 HVAP 64%, AD 9 HVAP 50%).
Jim was gong to call you later today to get your thoughts if you have a chance to
take a look at the amendment.
Thanks,
Tad
Ottman
••••••••••••••••••••• A •••••••••••••••••
•••••••••••••• •••••••••••
Unless otherwise expressly indicated, if this email, or any attachment
hereto, contains advice concerning any federal tax issue or
submission, please be advised that the advice was not intended or
written to· be used, and that it cannot be used, for the purpose of
avoiding federal tax penalties.
The information contained in this communication may be confidential,
is intended only for the use of the recipient(s) named above, and may
legally privileged. If the reader of' this message is not the
intended recipient, you are hereby notified that any dissemination.
distribution, or copying of this communication, or any of its
contents, is strictly prohibited. If you have received this
communication in error, please return it to the sender immediately and
delete the original message and any copy of it from your computer
system. If you have any questions concerning this message, please
contact the sender.
Produced 10/1612012 (34 Total Emails)
EVANS 0047
Case: 3:15-cv-00421-bbc Document #: 116-5 Filed: 05/02/16 Page 23 of 26
Democracy Campaign Configuration
#Tamara Qigsby
#l.aon Young
'ilt
65.40/0 HVAP
West Ails
Gleendale
Franklin
Produced ]0/]612012 (34 Total Emails)
oak Creek
EVANS 0048
Case: 3:15-cv-00421-bbc Document #: 116-5 Filed: 05/02/16 Page 24 of 26
To:
'jrtroupis@troupislawoffice.com'Drtroupis@troupislawoffice.com);
'tottman@gmail.com'(tottman@gmail.com)
Cc:
'adamfoltz@gmail.com'(adamfollZ@gmaiLcom); McLeod, Eric M
(22257 )(EMMdeod@michaelbeslcom]
From:
Taffora. Raymond P (22244)
Sent
Sun 7/1712011 8:51:43 PM
Subject: Re: Wisconsin Hispanic Districts
All:
We have our maps as recommended by the Senate Committee. No further amendments
are necessary. Its too late now for further amendments as concerns the Hispanic
districts.
Ray
From: Jim Troupis
Sent: Sunday, July 17, 201102:53 PM
To: tottman <tottman@gmail.com>
Cc: adam foltz <adamfoltz@gmail.com>; Mcleod, Eric M (22257); Taffora, Raymond P
(22244)
Subject: RE: Wisconsin Hispanic Districts
Tad & ALL,
I just did a long email, but I think it got lost Sorry if I am repeating myself. I just spent an
hour on the phone with Keith G and we have a number of issues we need to address
today. Do not send things related to these requests directly to Keith as from here on I
expect he will be a witness, and will be deposed and this may become public. When I
get the numbers I can talk with him, rather than email.
1.) As I had speculated, the citizenship numbers are important. Can you overlay the
ACS citizenship data. (American Community Survey)? I've asked Keith to talk today to
Clark Benson, who worked with us the last time, to see if he can overlay that data, in the
event we can not, onto the 2002 and the 60/54 districts.
2.) Can you provide the data again on the 2002 Hispanic district drawn by the court and
compare it to the 60/54 & Senate district? This would be important to any decision to
change anything further as obviously that district elected Hispanic representatives. I
know I've had that, but could not locate it this afternoon.
3.) The problem here is that Keith believes that no matter how you draw the district,
there is not an Hispanic majority district when you consider turnout, but by the same
token there is no history at all of racially polarized voting. So, as a consequence he
believes he can testify in support of a 60/54 and he is more comfortable with that than
Produced 10116/2012 (34 Total Emails)
EVANS 0049
Case: 3:15-cv-00421-bbc Document #: 116-5 Filed: 05/02/16 Page 25 of 26
the 57/57.
4.) Compactness: Can you run the compactness score for the 60/54 configuration
districts 7, 8, 9 and compare that to the rest of the map? Would like to see what comes
of it.
5.) Wisconsin Democracy Campaign: Attached is the only alternative out there-the
Wisconsin Democracy Campaign. Keith thinks this looks like our map. I'm not sure.
Could you do your best to reconstruct it and then let us know what the numbers look
like?
Sorry to bother you on a Sunday, but as they say this could be the 'ball game'. We want
to make sure we have all we need to make the appropriate decision. If you can get this
to us today or at the latest very earty tomorrow morning, we can then talk and make
then decide what if anything to do.
Thanks Tad.
Jim
James R. Troupis
Troupis Law Office LLC
jrtroupis@troupislawoffice.com
ph. 608-807-4096
This email and any attachments thereto may contain private, confidential and privileged
material for the sole use of the intended recipient. Any review, copying, or distribution of
this email (or any attachments thereto) by others is strictly prohibited. If you are not the
intended reCipient, please contact the sender immediately and
delete the
original and any copies of this email and any attachments thereto.
From: tottman [mailto:toUman@gmail.coml
Sent: Sunday, July 17, 201111:40 AM
To: Keith Gaddie
Produced 10/16/2012 (34 Total Emails)
EVANS 0050
Case: 3:15-cv-00421-bbc Document #: 116-5 Filed: 05/02/16 Page 26 of 26
Cc: adam foltz; Jim Troupis; McLeod, Eric M (22257); Taffora, Raymond P (22244)
Subject:
Hispanic Districts
Keith,
Jim Troupis asked that I have you take a look at the amendment that was adopted in
committee on the hispanic districts. Here is the link to the interactive maps:
http://legis.wisconsin.govlltsbiredistricting/bills.htm
Amendment 2 was the configuration that was adopted. The HVAP in AD B is 60.5 %
and in AD 9 it is 54%. The incumbent lives in AD 8 and AD 9 is open under all
alternatives.
There was testimony by 2 different hispanic groups in favor of the configuration in
amendment 2. No one that I'm aware of testified in favor of either the bill configuration
(AD 8 HVAP 57.2%, AD 9 HVAP 57.2%) or in favor of amendment 1 (AD B HVAP 64%,
AD 9 HVAP 50%).
Jim was gong to call you later today to get your thoughts if you have a chance to take a
look at the amendment.
Thanks,
Tad Ottman
Produced 10/1612012 (34 Total Emails)
EVANS 0051