1 00:00:00,000 --> 00:00:01,000 Okay. 2 00:00:01,000 --> 00:00:02,000 Yeah. 3 00:00:02,000 --> 00:00:03,000 Yeah. 4 00:00:03,000 --> 00:00:04,000 Okay. 5 00:00:04,000 --> 00:00:05,000 Good morning everyone. 6 00:00:05,000 --> 00:00:06,000 I'm Ed. 7 00:00:06,000 --> 00:00:07,000 I'm Ed. 8 00:00:07,000 --> 00:00:08,000 I'm Dr. 24 Marshall. 9 00:00:08,000 --> 00:00:09,000 This is a few minutes. 10 00:00:09,000 --> 00:00:10,000 I'm going to talk about, please be sure. 11 00:00:10,000 --> 00:00:11,000 Okay. 12 00:00:11,000 --> 00:00:12,000 All right. 13 00:00:12,000 --> 00:00:13,000 I'm sorry. 14 00:00:13,000 --> 00:00:14,000 I'm sorry. 15 00:00:14,000 --> 00:00:15,000 I'm sorry. 16 00:00:15,000 --> 00:00:16,000 I'm sorry. 17 00:00:16,000 --> 00:00:17,000 I'm sorry. 18 00:00:17,000 --> 00:00:18,000 I'm sorry. 19 00:00:18,000 --> 00:00:19,000 I'm sorry. 20 00:00:19,000 --> 00:00:20,000 I'm sorry. 21 00:00:20,000 --> 00:00:21,000 I'm sorry. 22 00:00:21,000 --> 00:00:22,000 I'm sorry. 23 00:00:22,000 --> 00:00:23,000 I'm sorry. 24 00:00:23,000 --> 00:00:24,000 I'm sorry. 25 00:00:24,000 --> 00:00:25,000 I'm sorry. 26 00:00:25,000 --> 00:00:26,000 I'm sorry. 27 00:00:26,000 --> 00:00:27,000 I'm sorry. 28 00:00:27,000 --> 00:00:28,000 I'm sorry. 29 00:00:29,000 --> 00:00:30,000 I'm sorry. 30 00:00:30,000 --> 00:00:31,000 I'm sorry. 31 00:00:31,000 --> 00:00:32,000 I'm sorry. 32 00:00:32,000 --> 00:00:33,000 I'm sorry. 33 00:00:33,000 --> 00:00:34,000 I'm sorry. 34 00:00:34,000 --> 00:00:35,000 I'm sorry. 35 00:00:35,000 --> 00:00:36,000 I'm sorry. 36 00:00:36,000 --> 00:00:37,000 I'm sorry. 37 00:00:37,000 --> 00:00:38,000 I'm sorry. 38 00:00:38,000 --> 00:00:39,000 I'm sorry. 39 00:00:39,000 --> 00:00:40,000 I'm sorry. 40 00:00:40,000 --> 00:00:41,000 I'm sorry. 41 00:00:41,000 --> 00:00:42,000 I'm sorry. 42 00:00:42,000 --> 00:00:43,000 I'm sorry. 43 00:00:43,000 --> 00:00:44,000 I'm sorry. 44 00:00:44,000 --> 00:00:45,000 I'm sorry. 45 00:00:45,000 --> 00:00:46,000 I'm sorry. 46 00:00:46,000 --> 00:00:47,000 I'm sorry. 47 00:00:47,000 --> 00:00:48,000 I'm sorry. 48 00:00:48,000 --> 00:00:49,000 I'm sorry. 49 00:00:49,000 --> 00:00:50,000 I'm sorry. 50 00:00:50,000 --> 00:00:51,000 I'm sorry. 51 00:00:51,000 --> 00:00:52,000 I'm sorry. 52 00:00:52,000 --> 00:00:53,000 I'm sorry. 53 00:00:53,000 --> 00:00:54,000 I'm sorry. 54 00:00:54,000 --> 00:00:55,000 I'm sorry. 55 00:00:55,000 --> 00:00:56,000 I'm sorry. 56 00:00:57,000 --> 00:00:58,000 I'm sorry. 57 00:00:58,000 --> 00:00:59,000 I'm sorry. 58 00:00:59,000 --> 00:01:00,000 I'm sorry. 59 00:01:00,000 --> 00:01:01,000 I'm sorry. 60 00:01:01,000 --> 00:01:02,000 I'm sorry. 61 00:01:02,000 --> 00:01:03,000 I'm sorry. 62 00:01:03,000 --> 00:01:04,000 I'm sorry. 63 00:01:04,000 --> 00:01:05,000 I'm sorry. 64 00:01:05,000 --> 00:01:06,000 I'm sorry. 65 00:01:06,000 --> 00:01:07,000 I'm sorry. 66 00:01:07,000 --> 00:01:08,000 I'm sorry. 67 00:01:08,000 --> 00:01:09,000 I'm sorry. 68 00:01:09,000 --> 00:01:10,000 I'm sorry. 69 00:01:10,000 --> 00:01:11,000 I'm sorry. 70 00:01:11,000 --> 00:01:12,000 I'm sorry. 71 00:01:12,000 --> 00:01:13,000 I'm sorry. 72 00:01:13,000 --> 00:01:14,000 I'm sorry. 73 00:01:14,000 --> 00:01:15,000 I'm sorry. 74 00:01:15,000 --> 00:01:16,000 I'm sorry. 75 00:01:16,000 --> 00:01:17,000 I'm sorry. 76 00:01:17,000 --> 00:01:18,000 I'm sorry. 77 00:01:18,000 --> 00:01:19,000 I'm sorry. 78 00:01:19,000 --> 00:01:20,000 I'm sorry. 79 00:01:20,000 --> 00:01:21,000 I'm sorry. 80 00:01:21,000 --> 00:01:22,000 I'm sorry. 81 00:01:22,000 --> 00:01:23,000 I'm sorry. 82 00:01:23,000 --> 00:01:24,000 I'm sorry. 83 00:01:25,000 --> 00:01:26,000 I'm sorry. 84 00:01:26,000 --> 00:01:27,000 I'm sorry. 85 00:01:27,000 --> 00:01:28,000 I'm sorry. 86 00:01:28,000 --> 00:01:29,000 I'm sorry. 87 00:01:29,000 --> 00:01:30,000 I'm sorry. 88 00:01:30,000 --> 00:01:31,000 I'm sorry. 89 00:01:31,000 --> 00:01:32,000 I'm sorry. 90 00:01:32,000 --> 00:01:33,000 I'm sorry. 91 00:01:33,000 --> 00:01:34,000 I'm sorry. 92 00:01:34,000 --> 00:01:35,000 I'm sorry. 93 00:01:35,000 --> 00:01:36,000 I'm sorry. 94 00:01:36,000 --> 00:01:37,000 I'm sorry. 95 00:01:37,000 --> 00:01:38,000 I'm sorry. 96 00:01:38,000 --> 00:01:39,000 I'm sorry. 97 00:01:39,000 --> 00:01:40,000 I'm sorry. 98 00:01:40,000 --> 00:01:41,000 I'm sorry. 99 00:01:41,000 --> 00:01:42,000 I'm sorry. 100 00:01:42,000 --> 00:01:43,000 I'm sorry. 101 00:01:43,000 --> 00:01:44,000 I'm sorry. 102 00:01:44,000 --> 00:01:45,000 I'm sorry. 103 00:01:45,000 --> 00:01:46,000 I'm sorry. 104 00:01:46,000 --> 00:01:47,000 I'm sorry. 105 00:01:47,000 --> 00:01:48,000 I'm sorry. 106 00:01:48,000 --> 00:01:49,000 I'm sorry. 107 00:01:49,000 --> 00:01:50,000 I'm sorry. 108 00:01:50,000 --> 00:01:51,000 I'm sorry. 109 00:01:51,000 --> 00:01:52,000 I'm sorry. 110 00:01:53,000 --> 00:01:54,000 I'm sorry. 111 00:01:54,000 --> 00:01:55,000 I'm sorry. 112 00:01:55,000 --> 00:01:56,000 I'm sorry. 113 00:01:56,000 --> 00:01:57,000 I'm sorry. 114 00:01:57,000 --> 00:01:58,000 I'm sorry. 115 00:01:58,000 --> 00:01:59,000 I'm sorry. 116 00:01:59,000 --> 00:02:00,000 I'm sorry. 117 00:02:00,000 --> 00:02:01,000 I'm sorry. 118 00:02:01,000 --> 00:02:02,000 I'm sorry. 119 00:02:02,000 --> 00:02:03,000 I'm sorry. 120 00:02:03,000 --> 00:02:04,000 I'm sorry. 121 00:02:04,000 --> 00:02:05,000 I'm sorry. 122 00:02:05,000 --> 00:02:06,000 I'm sorry. 123 00:02:06,000 --> 00:02:07,000 I'm sorry. 124 00:02:07,000 --> 00:02:08,000 I'm sorry. 125 00:02:08,000 --> 00:02:09,000 I'm sorry. 126 00:02:09,000 --> 00:02:10,000 I'm sorry. 127 00:02:10,000 --> 00:02:11,000 I'm sorry. 128 00:02:11,000 --> 00:02:12,000 I'm sorry. 129 00:02:12,000 --> 00:02:13,000 I'm sorry. 130 00:02:13,000 --> 00:02:14,000 I'm sorry. 131 00:02:14,000 --> 00:02:15,000 I'm sorry. 132 00:02:15,000 --> 00:02:16,000 I'm sorry. 133 00:02:16,000 --> 00:02:17,000 I'm sorry. 134 00:02:17,000 --> 00:02:18,000 I'm sorry. 135 00:02:18,000 --> 00:02:19,000 I'm sorry. 136 00:02:19,000 --> 00:02:20,000 I'm sorry. 137 00:02:21,000 --> 00:02:22,000 I'm sorry. 138 00:02:22,000 --> 00:02:23,000 I'm sorry. 139 00:02:23,000 --> 00:02:24,000 I'm sorry. 140 00:02:24,000 --> 00:02:25,000 I'm sorry. 141 00:02:25,000 --> 00:02:26,000 I'm sorry. 142 00:02:26,000 --> 00:02:27,000 I'm sorry. 143 00:02:27,000 --> 00:02:28,000 I'm sorry. 144 00:02:28,000 --> 00:02:29,000 I'm sorry. 145 00:02:29,000 --> 00:02:30,000 I'm sorry. 146 00:02:30,000 --> 00:02:31,000 I'm sorry. 147 00:02:31,000 --> 00:02:32,000 I'm sorry. 148 00:02:32,000 --> 00:02:33,000 I'm sorry. 149 00:02:33,000 --> 00:02:34,000 I'm sorry. 150 00:02:34,000 --> 00:02:35,000 I'm sorry. 151 00:02:35,000 --> 00:02:36,000 I'm sorry. 152 00:02:36,000 --> 00:02:37,000 I'm sorry. 153 00:02:37,000 --> 00:02:38,000 I'm sorry. 154 00:02:38,000 --> 00:02:39,000 I'm sorry. 155 00:02:39,000 --> 00:02:40,000 I'm sorry. 156 00:02:40,000 --> 00:02:41,000 I'm sorry. 157 00:02:41,000 --> 00:02:42,000 I'm sorry. 158 00:02:42,000 --> 00:02:43,000 I'm sorry. 159 00:02:43,000 --> 00:02:44,000 I'm sorry. 160 00:02:44,000 --> 00:02:45,000 I'm sorry. 161 00:02:45,000 --> 00:02:46,000 I'm sorry. 162 00:02:46,000 --> 00:02:47,000 I'm sorry. 163 00:02:47,000 --> 00:02:48,000 I'm sorry. 164 00:02:49,000 --> 00:02:50,000 I'm sorry. 165 00:02:50,000 --> 00:02:51,000 I'm sorry. 166 00:02:51,000 --> 00:02:52,000 I'm sorry. 167 00:02:52,000 --> 00:02:53,000 I'm sorry. 168 00:02:53,000 --> 00:02:54,000 I'm sorry. 169 00:02:54,000 --> 00:02:55,000 I'm sorry. 170 00:02:55,000 --> 00:02:56,000 I'm sorry. 171 00:02:56,000 --> 00:02:57,000 I'm sorry. 172 00:02:57,000 --> 00:02:58,000 I'm sorry. 173 00:02:58,000 --> 00:02:59,000 I'm sorry. 174 00:02:59,000 --> 00:03:00,000 I'm sorry. 175 00:03:00,000 --> 00:03:01,000 I'm sorry. 176 00:03:01,000 --> 00:03:02,000 I'm sorry. 177 00:03:02,000 --> 00:03:03,000 I'm sorry. 178 00:03:03,000 --> 00:03:04,000 I'm sorry. 179 00:03:04,000 --> 00:03:05,000 I'm sorry. 180 00:03:05,000 --> 00:03:06,000 I'm sorry. 181 00:03:06,000 --> 00:03:07,000 I'm sorry. 182 00:03:07,000 --> 00:03:08,000 I'm sorry. 183 00:03:08,000 --> 00:03:09,000 I'm sorry. 184 00:03:09,000 --> 00:03:10,000 I'm sorry. 185 00:03:10,000 --> 00:03:11,000 I'm sorry. 186 00:03:11,000 --> 00:03:12,000 I'm sorry. 187 00:03:12,000 --> 00:03:13,000 I'm sorry. 188 00:03:13,000 --> 00:03:14,000 I'm sorry. 189 00:03:14,000 --> 00:03:15,000 I'm sorry. 190 00:03:15,000 --> 00:03:16,000 I'm sorry. 191 00:03:17,000 --> 00:03:18,000 I'm sorry. 192 00:03:18,000 --> 00:03:19,000 I'm sorry. 193 00:03:19,000 --> 00:03:20,000 I'm sorry. 194 00:03:20,000 --> 00:03:21,000 I'm sorry. 195 00:03:21,000 --> 00:03:22,000 I'm sorry. 196 00:03:22,000 --> 00:03:23,000 I'm sorry. 197 00:03:23,000 --> 00:03:24,000 I'm sorry. 198 00:03:24,000 --> 00:03:25,000 I'm sorry. 199 00:03:25,000 --> 00:03:26,000 I'm sorry. 200 00:03:26,000 --> 00:03:27,000 I'm sorry. 201 00:03:27,000 --> 00:03:28,000 I'm sorry. 202 00:03:28,000 --> 00:03:29,000 I'm sorry. 203 00:03:29,000 --> 00:03:30,000 I'm sorry. 204 00:03:30,000 --> 00:03:31,000 I'm sorry. 205 00:03:31,000 --> 00:03:32,000 I'm sorry. 206 00:03:32,000 --> 00:03:33,000 I'm sorry. 207 00:03:33,000 --> 00:03:34,000 I'm sorry. 208 00:03:34,000 --> 00:03:35,000 I'm sorry. 209 00:03:35,000 --> 00:03:36,000 I'm sorry. 210 00:03:36,000 --> 00:03:37,000 I'm sorry. 211 00:03:37,000 --> 00:03:38,000 I'm sorry. 212 00:03:38,000 --> 00:03:39,000 I'm sorry. 213 00:03:39,000 --> 00:03:40,000 I'm sorry. 214 00:03:40,000 --> 00:03:41,000 I'm sorry. 215 00:03:41,000 --> 00:03:42,000 I'm sorry. 216 00:03:42,000 --> 00:03:43,000 I'm sorry. 217 00:03:43,000 --> 00:03:44,000 I'm sorry. 218 00:03:45,000 --> 00:03:46,000 I'm sorry. 219 00:03:46,000 --> 00:03:47,000 I'm sorry. 220 00:03:47,000 --> 00:03:48,000 I'm sorry. 221 00:03:48,000 --> 00:03:49,000 I'm sorry. 222 00:03:49,000 --> 00:03:50,000 I'm sorry. 223 00:03:50,000 --> 00:03:51,000 I'm sorry. 224 00:03:51,000 --> 00:03:52,000 I'm sorry. 225 00:03:52,000 --> 00:03:53,000 I'm sorry. 226 00:03:53,000 --> 00:03:54,000 I'm sorry. 227 00:03:54,000 --> 00:03:55,000 I'm sorry. 228 00:03:55,000 --> 00:03:56,000 I'm sorry. 229 00:03:56,000 --> 00:03:57,000 I'm sorry. 230 00:03:57,000 --> 00:03:58,000 I'm sorry. 231 00:03:58,000 --> 00:03:59,000 I'm sorry. 232 00:03:59,000 --> 00:04:00,000 I'm sorry. 233 00:04:00,000 --> 00:04:01,000 I'm sorry. 234 00:04:01,000 --> 00:04:02,000 I'm sorry. 235 00:04:02,000 --> 00:04:03,000 I'm sorry. 236 00:04:03,000 --> 00:04:04,000 I'm sorry. 237 00:04:04,000 --> 00:04:05,000 I'm sorry. 238 00:04:05,000 --> 00:04:06,000 I'm sorry. 239 00:04:06,000 --> 00:04:07,000 I'm sorry. 240 00:04:07,000 --> 00:04:08,000 I'm sorry. 241 00:04:08,000 --> 00:04:09,000 I'm sorry. 242 00:04:09,000 --> 00:04:10,000 I'm sorry. 243 00:04:10,000 --> 00:04:11,000 I'm sorry. 244 00:04:11,000 --> 00:04:12,000 I'm sorry. 245 00:04:12,000 --> 00:04:13,000 I'm sorry. 246 00:04:13,000 --> 00:04:14,000 I'm sorry. 247 00:04:14,000 --> 00:04:15,000 I'm sorry. 248 00:04:15,000 --> 00:04:16,000 I'm sorry. 249 00:04:16,000 --> 00:04:17,000 I'm sorry. 250 00:04:17,000 --> 00:04:18,000 I'm sorry. 251 00:04:18,000 --> 00:04:19,000 I'm sorry. 252 00:04:19,000 --> 00:04:20,000 I'm sorry. 253 00:04:20,000 --> 00:04:21,000 I'm sorry. 254 00:04:21,000 --> 00:04:22,000 I'm sorry. 255 00:04:22,000 --> 00:04:23,000 I'm sorry. 256 00:04:23,000 --> 00:04:24,000 I'm sorry. 257 00:04:24,000 --> 00:04:25,000 I'm sorry. 258 00:04:25,000 --> 00:04:26,000 I'm sorry. 259 00:04:26,000 --> 00:04:27,000 I'm sorry. 260 00:04:27,000 --> 00:04:28,000 I'm sorry. 261 00:04:28,000 --> 00:04:29,000 I'm sorry. 262 00:04:29,000 --> 00:04:30,000 I'm sorry. 263 00:04:30,000 --> 00:04:31,000 I'm sorry. 264 00:04:31,000 --> 00:04:32,000 I'm sorry. 265 00:04:32,000 --> 00:04:33,000 I'm sorry. 266 00:04:33,000 --> 00:04:34,000 I'm sorry. 267 00:04:34,000 --> 00:04:35,000 I'm sorry. 268 00:04:35,000 --> 00:04:36,000 I'm sorry. 269 00:04:36,000 --> 00:04:37,000 I'm sorry. 270 00:04:37,000 --> 00:04:38,000 I'm sorry. 271 00:04:38,000 --> 00:04:39,000 I'm sorry. 272 00:04:39,000 --> 00:04:40,000 I'm sorry. 273 00:04:40,000 --> 00:04:41,000 I'm sorry. 274 00:04:41,000 --> 00:04:42,000 I'm sorry. 275 00:04:42,000 --> 00:04:43,000 I'm sorry. 276 00:04:43,000 --> 00:04:44,000 I'm sorry. 277 00:04:44,000 --> 00:04:45,000 I'm sorry. 278 00:04:45,000 --> 00:04:46,000 I'm sorry. 279 00:04:46,000 --> 00:04:47,000 I'm sorry. 280 00:04:47,000 --> 00:04:48,000 I'm sorry. 281 00:04:48,000 --> 00:04:49,000 I'm sorry. 282 00:04:49,000 --> 00:04:50,000 I'm sorry. 283 00:04:50,000 --> 00:04:51,000 I'm sorry. 284 00:04:51,000 --> 00:04:52,000 I'm sorry. 285 00:04:52,000 --> 00:04:53,000 I'm sorry. 286 00:04:53,000 --> 00:04:54,000 I'm sorry. 287 00:04:54,000 --> 00:04:55,000 I'm sorry. 288 00:04:55,000 --> 00:04:56,000 I'm sorry. 289 00:04:56,000 --> 00:04:57,000 I'm sorry. 290 00:04:57,000 --> 00:04:58,000 I'm sorry. 291 00:04:58,000 --> 00:04:59,000 I'm sorry. 292 00:04:59,000 --> 00:05:00,000 I'm sorry. 293 00:05:00,000 --> 00:05:01,000 I'm sorry. 294 00:05:01,000 --> 00:05:02,000 I'm sorry. 295 00:05:02,000 --> 00:05:03,000 I'm sorry. 296 00:05:03,000 --> 00:05:04,000 I'm sorry. 297 00:05:04,000 --> 00:05:05,000 I'm sorry. 298 00:05:05,000 --> 00:05:06,000 I'm sorry. 299 00:05:06,000 --> 00:05:07,000 I'm sorry. 300 00:05:07,000 --> 00:05:08,000 I'm sorry. 301 00:05:08,000 --> 00:05:09,000 I'm sorry. 302 00:05:09,000 --> 00:05:10,000 I'm sorry. 303 00:05:10,000 --> 00:05:11,000 I'm sorry. 304 00:05:11,000 --> 00:05:12,000 I'm sorry. 305 00:05:12,000 --> 00:05:13,000 I'm sorry. 306 00:05:13,000 --> 00:05:14,000 I'm sorry. 307 00:05:14,000 --> 00:05:15,000 I'm sorry. 308 00:05:15,000 --> 00:05:16,000 I'm sorry. 309 00:05:16,000 --> 00:05:17,000 I'm sorry. 310 00:05:17,000 --> 00:05:18,000 I'm sorry. 311 00:05:18,000 --> 00:05:19,000 I'm sorry. 312 00:05:19,000 --> 00:05:20,000 I'm sorry. 313 00:05:20,000 --> 00:05:21,000 I'm sorry. 314 00:05:21,000 --> 00:05:22,000 I'm sorry. 315 00:05:22,000 --> 00:05:23,000 I'm sorry. 316 00:05:23,000 --> 00:05:24,000 I'm sorry. 317 00:05:24,000 --> 00:05:25,000 I'm sorry. 318 00:05:25,000 --> 00:05:26,000 I'm sorry. 319 00:05:26,000 --> 00:05:27,000 I'm sorry. 320 00:05:27,000 --> 00:05:28,000 I'm sorry. 321 00:05:28,000 --> 00:05:29,000 I'm sorry. 322 00:05:29,000 --> 00:05:30,000 I'm sorry. 323 00:05:30,000 --> 00:05:31,000 I'm sorry. 324 00:05:31,000 --> 00:05:32,000 I'm sorry. 325 00:05:32,000 --> 00:05:33,000 I'm sorry. 326 00:05:33,000 --> 00:05:34,000 I'm sorry. 327 00:05:34,000 --> 00:05:35,000 I'm sorry. 328 00:05:35,000 --> 00:05:36,000 I'm sorry. 329 00:05:36,000 --> 00:05:37,000 I'm sorry. 330 00:05:37,000 --> 00:05:38,000 I'm sorry. 331 00:05:38,000 --> 00:05:39,000 I'm sorry. 332 00:05:39,000 --> 00:05:40,000 I'm sorry. 333 00:05:40,000 --> 00:05:41,000 I'm sorry. 334 00:05:41,000 --> 00:05:42,000 I'm sorry. 335 00:05:42,000 --> 00:05:43,000 I'm sorry. 336 00:05:43,000 --> 00:05:44,000 I'm sorry. 337 00:05:44,000 --> 00:05:45,000 I'm sorry. 338 00:05:45,000 --> 00:05:46,000 I'm sorry. 339 00:05:46,000 --> 00:05:47,000 I'm sorry. 340 00:05:47,000 --> 00:05:48,000 I'm sorry. 341 00:05:48,000 --> 00:05:49,000 I'm sorry. 342 00:05:49,000 --> 00:05:50,000 I'm sorry. 343 00:05:50,000 --> 00:05:51,000 I'm sorry. 344 00:05:51,000 --> 00:05:52,000 I'm sorry. 345 00:05:52,000 --> 00:05:53,000 I'm sorry. 346 00:05:53,000 --> 00:05:54,000 I'm sorry. 347 00:05:54,000 --> 00:05:55,000 I'm sorry. 348 00:05:55,000 --> 00:05:56,000 I'm sorry. 349 00:05:56,000 --> 00:05:57,000 I'm sorry. 350 00:05:57,000 --> 00:05:58,000 I'm sorry. 351 00:05:58,000 --> 00:05:59,000 I'm sorry. 352 00:05:59,000 --> 00:06:00,000 I'm sorry. 353 00:06:00,000 --> 00:06:01,000 I'm sorry. 354 00:06:01,000 --> 00:06:02,000 I'm sorry. 355 00:06:02,000 --> 00:06:03,000 I'm sorry. 356 00:06:03,000 --> 00:06:04,000 I'm sorry. 357 00:06:04,000 --> 00:06:05,000 I'm sorry. 358 00:06:05,000 --> 00:06:06,000 I'm sorry. 359 00:06:06,000 --> 00:06:07,000 I'm sorry. 360 00:06:07,000 --> 00:06:08,000 I'm sorry. 361 00:06:08,000 --> 00:06:09,000 I'm sorry. 362 00:06:09,000 --> 00:06:10,000 I'm sorry. 363 00:06:10,000 --> 00:06:11,000 I'm sorry. 364 00:06:11,000 --> 00:06:12,000 I'm sorry. 365 00:06:12,000 --> 00:06:13,000 I'm sorry. 366 00:06:13,000 --> 00:06:14,000 I'm sorry. 367 00:06:14,000 --> 00:06:15,000 I'm sorry. 368 00:06:15,000 --> 00:06:16,000 I'm sorry. 369 00:06:16,000 --> 00:06:17,000 I'm sorry. 370 00:06:17,000 --> 00:06:18,000 I'm sorry. 371 00:06:18,000 --> 00:06:19,000 I'm sorry. 372 00:06:19,000 --> 00:06:20,000 I'm sorry. 373 00:06:20,000 --> 00:06:21,000 I'm sorry. 374 00:06:21,000 --> 00:06:22,000 I'm sorry. 375 00:06:22,000 --> 00:06:23,000 I'm sorry. 376 00:06:23,000 --> 00:06:24,000 I'm sorry. 377 00:06:24,000 --> 00:06:25,000 I'm sorry. 378 00:06:25,000 --> 00:06:26,000 I'm sorry. 379 00:06:26,000 --> 00:06:27,000 I'm sorry. 380 00:06:27,000 --> 00:06:28,000 I'm sorry. 381 00:06:28,000 --> 00:06:29,000 I'm sorry. 382 00:06:29,000 --> 00:06:30,000 I'm sorry. 383 00:06:30,000 --> 00:06:31,000 I'm sorry. 384 00:06:31,000 --> 00:06:32,000 I'm sorry. 385 00:06:32,000 --> 00:06:33,000 I'm sorry. 386 00:06:33,000 --> 00:06:34,000 I'm sorry. 387 00:06:34,000 --> 00:06:35,000 I'm sorry. 388 00:06:35,000 --> 00:06:36,000 I'm sorry. 389 00:06:36,000 --> 00:06:37,000 I'm sorry. 390 00:06:37,000 --> 00:06:38,000 I'm sorry. 391 00:06:38,000 --> 00:06:39,000 I'm sorry. 392 00:06:39,000 --> 00:06:40,000 I'm sorry. 393 00:06:40,000 --> 00:06:41,000 I'm sorry. 394 00:06:41,000 --> 00:06:42,000 I'm sorry. 395 00:06:42,000 --> 00:06:43,000 I'm sorry. 396 00:06:43,000 --> 00:06:44,000 I'm sorry. 397 00:06:44,000 --> 00:06:45,000 I'm sorry. 398 00:06:45,000 --> 00:06:46,000 I'm sorry. 399 00:06:46,000 --> 00:06:47,000 I'm sorry. 400 00:06:47,000 --> 00:06:48,000 I'm sorry. 401 00:06:48,000 --> 00:06:49,000 I'm sorry. 402 00:06:49,000 --> 00:06:50,000 I'm sorry. 403 00:06:50,000 --> 00:06:51,000 I'm sorry. 404 00:06:51,000 --> 00:06:52,000 I'm sorry. 405 00:06:52,000 --> 00:06:53,000 I'm sorry. 406 00:06:53,000 --> 00:06:54,000 I'm sorry. 407 00:06:54,000 --> 00:06:55,000 I'm sorry. 408 00:06:56,000 --> 00:06:57,000 I'm sorry. 409 00:06:57,000 --> 00:06:58,000 I'm sorry. 410 00:06:58,000 --> 00:06:59,000 I'm sorry. 411 00:06:59,000 --> 00:07:00,000 I'm sorry. 412 00:07:00,000 --> 00:07:01,000 I'm sorry. 413 00:07:01,000 --> 00:07:02,000 I'm sorry. 414 00:07:02,000 --> 00:07:03,000 I'm sorry. 415 00:07:03,000 --> 00:07:04,000 I'm sorry. 416 00:07:04,000 --> 00:07:05,000 I'm sorry. 417 00:07:05,000 --> 00:07:06,000 I'm sorry. 418 00:07:06,000 --> 00:07:07,000 I'm sorry. 419 00:07:07,000 --> 00:07:08,000 I'm sorry. 420 00:07:08,000 --> 00:07:09,000 I'm sorry. 421 00:07:09,000 --> 00:07:10,000 I'm sorry. 422 00:07:10,000 --> 00:07:11,000 I'm sorry. 423 00:07:11,000 --> 00:07:12,000 I'm sorry. 424 00:07:12,000 --> 00:07:13,000 I'm sorry. 425 00:07:13,000 --> 00:07:14,000 I'm sorry. 426 00:07:14,000 --> 00:07:15,000 I'm sorry. 427 00:07:15,000 --> 00:07:16,000 I'm sorry. 428 00:07:16,000 --> 00:07:17,000 I'm sorry. 429 00:07:17,000 --> 00:07:18,000 I'm sorry. 430 00:07:18,000 --> 00:07:19,000 I'm sorry. 431 00:07:19,000 --> 00:07:20,000 I'm sorry. 432 00:07:20,000 --> 00:07:21,000 I'm sorry. 433 00:07:21,000 --> 00:07:22,000 I'm sorry. 434 00:07:22,000 --> 00:07:23,000 I'm sorry. 435 00:07:24,000 --> 00:07:25,000 I'm sorry. 436 00:07:25,000 --> 00:07:26,000 I'm sorry. 437 00:07:26,000 --> 00:07:27,000 I'm sorry. 438 00:07:27,000 --> 00:07:28,000 I'm sorry. 439 00:07:28,000 --> 00:07:29,000 I'm sorry. 440 00:07:29,000 --> 00:07:30,000 I'm sorry. 441 00:07:30,000 --> 00:07:31,000 I'm sorry. 442 00:07:31,000 --> 00:07:32,000 I'm sorry. 443 00:07:32,000 --> 00:07:33,000 I'm sorry. 444 00:07:33,000 --> 00:07:34,000 I'm sorry. 445 00:07:34,000 --> 00:07:35,000 I'm sorry. 446 00:07:35,000 --> 00:07:36,000 I'm sorry. 447 00:07:36,000 --> 00:07:37,000 I'm sorry. 448 00:07:37,000 --> 00:07:38,000 I'm sorry. 449 00:07:38,000 --> 00:07:39,000 I'm sorry. 450 00:07:39,000 --> 00:07:40,000 I'm sorry. 451 00:07:40,000 --> 00:07:41,000 I'm sorry. 452 00:07:41,000 --> 00:07:42,000 I'm sorry. 453 00:07:42,000 --> 00:07:43,000 I'm sorry. 454 00:07:43,000 --> 00:07:44,000 I'm sorry. 455 00:07:44,000 --> 00:07:45,000 I'm sorry. 456 00:07:45,000 --> 00:07:46,000 I'm sorry. 457 00:07:46,000 --> 00:07:47,000 I'm sorry. 458 00:07:47,000 --> 00:07:48,000 I'm sorry. 459 00:07:48,000 --> 00:07:49,000 I'm sorry. 460 00:07:49,000 --> 00:07:50,000 I'm sorry. 461 00:07:50,000 --> 00:07:51,000 I'm sorry. 462 00:07:52,000 --> 00:07:53,000 I'm sorry. 463 00:07:53,000 --> 00:07:54,000 I'm sorry. 464 00:07:54,000 --> 00:07:55,000 I'm sorry. 465 00:07:55,000 --> 00:07:56,000 I'm sorry. 466 00:07:56,000 --> 00:07:57,000 I'm sorry. 467 00:07:57,000 --> 00:07:58,000 I'm sorry. 468 00:07:58,000 --> 00:07:59,000 I'm sorry. 469 00:07:59,000 --> 00:08:00,000 I'm sorry. 470 00:08:00,000 --> 00:08:01,000 I'm sorry. 471 00:08:01,000 --> 00:08:02,000 I'm sorry. 472 00:08:02,000 --> 00:08:03,000 I'm sorry. 473 00:08:03,000 --> 00:08:04,000 I'm sorry. 474 00:08:04,000 --> 00:08:05,000 I'm sorry. 475 00:08:05,000 --> 00:08:06,000 I'm sorry. 476 00:08:06,000 --> 00:08:07,000 I'm sorry. 477 00:08:07,000 --> 00:08:08,000 I'm sorry. 478 00:08:08,000 --> 00:08:09,000 I'm sorry. 479 00:08:09,000 --> 00:08:10,000 I'm sorry. 480 00:08:10,000 --> 00:08:11,000 I'm sorry. 481 00:08:11,000 --> 00:08:12,000 I'm sorry. 482 00:08:12,000 --> 00:08:13,000 I'm sorry. 483 00:08:13,000 --> 00:08:14,000 I'm sorry. 484 00:08:14,000 --> 00:08:15,000 I'm sorry. 485 00:08:15,000 --> 00:08:16,000 I'm sorry. 486 00:08:16,000 --> 00:08:17,000 I'm sorry. 487 00:08:17,000 --> 00:08:18,000 I'm sorry. 488 00:08:18,000 --> 00:08:19,000 I'm sorry. 489 00:08:20,000 --> 00:08:21,000 I'm sorry. 490 00:08:21,000 --> 00:08:22,000 I'm sorry. 491 00:08:22,000 --> 00:08:23,000 I'm sorry. 492 00:08:23,000 --> 00:08:24,000 I'm sorry. 493 00:08:24,000 --> 00:08:25,000 I'm sorry. 494 00:08:25,000 --> 00:08:26,000 I'm sorry. 495 00:08:26,000 --> 00:08:27,000 I'm sorry. 496 00:08:27,000 --> 00:08:28,000 I'm sorry. 497 00:08:28,000 --> 00:08:29,000 I'm sorry. 498 00:08:29,000 --> 00:08:30,000 I'm sorry. 499 00:08:30,000 --> 00:08:31,000 I'm sorry. 500 00:08:31,000 --> 00:08:32,000 I'm sorry. 501 00:08:32,000 --> 00:08:33,000 I'm sorry. 502 00:08:33,000 --> 00:08:34,000 I'm sorry. 503 00:08:34,000 --> 00:08:35,000 I'm sorry. 504 00:08:35,000 --> 00:08:36,000 I'm sorry. 505 00:08:36,000 --> 00:08:37,000 I'm sorry. 506 00:08:37,000 --> 00:08:38,000 I'm sorry. 507 00:08:38,000 --> 00:08:39,000 I'm sorry. 508 00:08:39,000 --> 00:08:40,000 I'm sorry. 509 00:08:40,000 --> 00:08:41,000 I'm sorry. 510 00:08:41,000 --> 00:08:42,000 I'm sorry. 511 00:08:42,000 --> 00:08:43,000 I'm sorry. 512 00:08:43,000 --> 00:08:44,000 I'm sorry. 513 00:08:44,000 --> 00:08:45,000 I'm sorry. 514 00:08:45,000 --> 00:08:46,000 I'm sorry. 515 00:08:46,000 --> 00:08:47,000 I'm sorry. 516 00:08:48,000 --> 00:08:49,000 I'm sorry. 517 00:08:49,000 --> 00:08:50,000 I'm sorry. 518 00:08:50,000 --> 00:08:51,000 I'm sorry. 519 00:08:51,000 --> 00:08:52,000 I'm sorry. 520 00:08:52,000 --> 00:08:53,000 I'm sorry. 521 00:08:53,000 --> 00:08:54,000 I'm sorry. 522 00:08:54,000 --> 00:08:55,000 I'm sorry. 523 00:08:55,000 --> 00:08:56,000 I'm sorry. 524 00:08:56,000 --> 00:08:57,000 I'm sorry. 525 00:08:57,000 --> 00:08:58,000 I'm sorry. 526 00:08:58,000 --> 00:08:59,000 I'm sorry. 527 00:08:59,000 --> 00:09:00,000 I'm sorry. 528 00:09:00,000 --> 00:09:01,000 I'm sorry. 529 00:09:01,000 --> 00:09:02,000 I'm sorry. 530 00:09:02,000 --> 00:09:03,000 I'm sorry. 531 00:09:03,000 --> 00:09:04,000 I'm sorry. 532 00:09:04,000 --> 00:09:05,000 I'm sorry. 533 00:09:05,000 --> 00:09:06,000 I'm sorry. 534 00:09:06,000 --> 00:09:07,000 I'm sorry. 535 00:09:07,000 --> 00:09:08,000 I'm sorry. 536 00:09:08,000 --> 00:09:09,000 I'm sorry. 537 00:09:09,000 --> 00:09:10,000 I'm sorry. 538 00:09:10,000 --> 00:09:11,000 I'm sorry. 539 00:09:11,000 --> 00:09:12,000 I'm sorry. 540 00:09:12,000 --> 00:09:13,000 I'm sorry. 541 00:09:13,000 --> 00:09:14,000 I'm sorry. 542 00:09:14,000 --> 00:09:15,000 I'm sorry. 543 00:09:16,000 --> 00:09:17,000 I'm sorry. 544 00:09:17,000 --> 00:09:18,000 I'm sorry. 545 00:09:18,000 --> 00:09:19,000 I'm sorry. 546 00:09:19,000 --> 00:09:20,000 I'm sorry. 547 00:09:20,000 --> 00:09:21,000 I'm sorry. 548 00:09:21,000 --> 00:09:22,000 I'm sorry. 549 00:09:22,000 --> 00:09:23,000 I'm sorry. 550 00:09:23,000 --> 00:09:24,000 I'm sorry. 551 00:09:24,000 --> 00:09:25,000 I'm sorry. 552 00:09:25,000 --> 00:09:26,000 I'm sorry. 553 00:09:26,000 --> 00:09:27,000 I'm sorry. 554 00:09:27,000 --> 00:09:28,000 I'm sorry. 555 00:09:28,000 --> 00:09:29,000 I'm sorry. 556 00:09:29,000 --> 00:09:30,000 I'm sorry. 557 00:09:30,000 --> 00:09:31,000 I'm sorry. 558 00:09:31,000 --> 00:09:32,000 I'm sorry. 559 00:09:32,000 --> 00:09:33,000 I'm sorry. 560 00:09:33,000 --> 00:09:34,000 I'm sorry. 561 00:09:34,000 --> 00:09:35,000 I'm sorry. 562 00:09:35,000 --> 00:09:36,000 I'm sorry. 563 00:09:36,000 --> 00:09:37,000 I'm sorry. 564 00:09:37,000 --> 00:09:38,000 I'm sorry. 565 00:09:38,000 --> 00:09:39,000 I'm sorry. 566 00:09:39,000 --> 00:09:40,000 I'm sorry. 567 00:09:40,000 --> 00:09:41,000 I'm sorry. 568 00:09:41,000 --> 00:09:42,000 I'm sorry. 569 00:09:42,000 --> 00:09:43,000 I'm sorry. 570 00:09:44,000 --> 00:09:45,000 I'm sorry. 571 00:09:45,000 --> 00:09:46,000 I'm sorry. 572 00:09:46,000 --> 00:09:47,000 I'm sorry. 573 00:09:47,000 --> 00:09:48,000 I'm sorry. 574 00:09:48,000 --> 00:09:49,000 I'm sorry. 575 00:09:49,000 --> 00:09:50,000 I'm sorry. 576 00:09:50,000 --> 00:09:51,000 I'm sorry. 577 00:09:51,000 --> 00:09:52,000 I'm sorry. 578 00:09:52,000 --> 00:09:53,000 I'm sorry. 579 00:09:53,000 --> 00:09:54,000 I'm sorry. 580 00:09:54,000 --> 00:09:55,000 I'm sorry. 581 00:09:55,000 --> 00:09:56,000 I'm sorry. 582 00:09:56,000 --> 00:09:57,000 I'm sorry. 583 00:09:57,000 --> 00:09:58,000 I'm sorry. 584 00:09:58,000 --> 00:09:59,000 I'm sorry. 585 00:09:59,000 --> 00:10:00,000 I'm sorry. 586 00:10:00,000 --> 00:10:01,000 I'm sorry. 587 00:10:01,000 --> 00:10:02,000 I'm sorry. 588 00:10:02,000 --> 00:10:03,000 I'm sorry. 589 00:10:03,000 --> 00:10:04,000 I'm sorry. 590 00:10:04,000 --> 00:10:05,000 I'm sorry. 591 00:10:05,000 --> 00:10:06,000 I'm sorry. 592 00:10:06,000 --> 00:10:07,000 I'm sorry. 593 00:10:07,000 --> 00:10:08,000 I'm sorry. 594 00:10:08,000 --> 00:10:09,000 I'm sorry. 595 00:10:09,000 --> 00:10:10,000 I'm sorry. 596 00:10:10,000 --> 00:10:11,000 I'm sorry. 597 00:10:12,000 --> 00:10:13,000 I'm sorry. 598 00:10:13,000 --> 00:10:14,000 I'm sorry. 599 00:10:14,000 --> 00:10:15,000 I'm sorry. 600 00:10:15,000 --> 00:10:16,000 I'm sorry. 601 00:10:16,000 --> 00:10:17,000 I'm sorry. 602 00:10:17,000 --> 00:10:18,000 I'm sorry. 603 00:10:18,000 --> 00:10:19,000 I'm sorry. 604 00:10:19,000 --> 00:10:20,000 I'm sorry. 605 00:10:20,000 --> 00:10:21,000 I'm sorry. 606 00:10:21,000 --> 00:10:22,000 I'm sorry. 607 00:10:22,000 --> 00:10:23,000 I'm sorry. 608 00:10:23,000 --> 00:10:24,000 I'm sorry. 609 00:10:24,000 --> 00:10:25,000 I'm sorry. 610 00:10:25,000 --> 00:10:26,000 I'm sorry. 611 00:10:26,000 --> 00:10:27,000 I'm sorry. 612 00:10:27,000 --> 00:10:28,000 I'm sorry. 613 00:10:28,000 --> 00:10:29,000 I'm sorry. 614 00:10:29,000 --> 00:10:30,000 I'm sorry. 615 00:10:30,000 --> 00:10:31,000 I'm sorry. 616 00:10:31,000 --> 00:10:32,000 I'm sorry. 617 00:10:32,000 --> 00:10:33,000 I'm sorry. 618 00:10:33,000 --> 00:10:34,000 I'm sorry. 619 00:10:34,000 --> 00:10:35,000 I'm sorry. 620 00:10:35,000 --> 00:10:36,000 I'm sorry. 621 00:10:36,000 --> 00:10:37,000 I'm sorry. 622 00:10:37,000 --> 00:10:38,000 I'm sorry. 623 00:10:38,000 --> 00:10:39,000 I'm sorry. 624 00:10:40,000 --> 00:10:41,000 I'm sorry. 625 00:10:41,000 --> 00:10:42,000 I'm sorry. 626 00:10:42,000 --> 00:10:43,000 I'm sorry. 627 00:10:43,000 --> 00:10:44,000 I'm sorry. 628 00:10:44,000 --> 00:10:45,000 I'm sorry. 629 00:10:45,000 --> 00:10:46,000 I'm sorry. 630 00:10:46,000 --> 00:10:47,000 I'm sorry. 631 00:10:47,000 --> 00:10:48,000 I'm sorry. 632 00:10:48,000 --> 00:10:49,000 I'm sorry. 633 00:10:49,000 --> 00:10:50,000 I'm sorry. 634 00:10:50,000 --> 00:10:51,000 I'm sorry. 635 00:10:51,000 --> 00:10:52,000 I'm sorry. 636 00:10:52,000 --> 00:10:53,000 I'm sorry. 637 00:10:53,000 --> 00:10:54,000 I'm sorry. 638 00:10:54,000 --> 00:10:55,000 I'm sorry. 639 00:10:55,000 --> 00:10:56,000 I'm sorry. 640 00:10:56,000 --> 00:10:57,000 I'm sorry. 641 00:10:57,000 --> 00:10:58,000 I'm sorry. 642 00:10:58,000 --> 00:10:59,000 I'm sorry. 643 00:10:59,000 --> 00:11:00,000 I'm sorry. 644 00:11:00,000 --> 00:11:01,000 I'm sorry. 645 00:11:01,000 --> 00:11:02,000 I'm sorry. 646 00:11:02,000 --> 00:11:03,000 I'm sorry. 647 00:11:03,000 --> 00:11:04,000 I'm sorry. 648 00:11:04,000 --> 00:11:05,000 I'm sorry. 649 00:11:05,000 --> 00:11:06,000 I'm sorry. 650 00:11:06,000 --> 00:11:07,000 I'm sorry. 651 00:11:07,000 --> 00:11:08,000 I'm sorry. 652 00:11:08,000 --> 00:11:09,000 I'm sorry. 653 00:11:09,000 --> 00:11:10,000 I'm sorry. 654 00:11:10,000 --> 00:11:11,000 I'm sorry. 655 00:11:11,000 --> 00:11:12,000 I'm sorry. 656 00:11:12,000 --> 00:11:13,000 I'm sorry. 657 00:11:13,000 --> 00:11:14,000 I'm sorry. 658 00:11:14,000 --> 00:11:15,000 I'm sorry. 659 00:11:15,000 --> 00:11:16,000 I'm sorry. 660 00:11:16,000 --> 00:11:17,000 I'm sorry. 661 00:11:17,000 --> 00:11:18,000 I'm sorry. 662 00:11:18,000 --> 00:11:19,000 I'm sorry. 663 00:11:19,000 --> 00:11:20,000 I'm sorry. 664 00:11:20,000 --> 00:11:21,000 I'm sorry. 665 00:11:21,000 --> 00:11:22,000 I'm sorry. 666 00:11:22,000 --> 00:11:23,000 I'm sorry. 667 00:11:23,000 --> 00:11:24,000 I'm sorry. 668 00:11:24,000 --> 00:11:25,000 I'm sorry. 669 00:11:25,000 --> 00:11:26,000 I'm sorry. 670 00:11:26,000 --> 00:11:27,000 I'm sorry. 671 00:11:27,000 --> 00:11:28,000 I'm sorry. 672 00:11:28,000 --> 00:11:29,000 I'm sorry. 673 00:11:29,000 --> 00:11:30,000 I'm sorry. 674 00:11:30,000 --> 00:11:31,000 I'm sorry. 675 00:11:31,000 --> 00:11:32,000 I'm sorry. 676 00:11:32,000 --> 00:11:33,000 I'm sorry. 677 00:11:33,000 --> 00:11:34,000 I'm sorry. 678 00:11:35,000 --> 00:11:36,000 I'm sorry. 679 00:11:36,000 --> 00:11:37,000 I'm sorry. 680 00:11:37,000 --> 00:11:38,000 I'm sorry. 681 00:11:38,000 --> 00:11:39,000 I'm sorry. 682 00:11:39,000 --> 00:11:40,000 I'm sorry. 683 00:11:40,000 --> 00:11:41,000 I'm sorry. 684 00:11:41,000 --> 00:11:42,000 I'm sorry. 685 00:11:42,000 --> 00:11:43,000 I'm sorry. 686 00:11:43,000 --> 00:11:44,000 I'm sorry. 687 00:11:44,000 --> 00:11:45,000 I'm sorry. 688 00:11:45,000 --> 00:11:46,000 I'm sorry. 689 00:11:46,000 --> 00:11:47,000 I'm sorry. 690 00:11:47,000 --> 00:11:48,000 I'm sorry. 691 00:11:48,000 --> 00:11:49,000 I'm sorry. 692 00:11:49,000 --> 00:11:50,000 I'm sorry. 693 00:11:50,000 --> 00:11:51,000 I'm sorry. 694 00:11:51,000 --> 00:11:52,000 I'm sorry. 695 00:11:52,000 --> 00:11:53,000 I'm sorry. 696 00:11:53,000 --> 00:11:54,000 I'm sorry. 697 00:11:54,000 --> 00:11:55,000 I'm sorry. 698 00:11:55,000 --> 00:11:56,000 I'm sorry. 699 00:11:56,000 --> 00:11:57,000 I'm sorry. 700 00:11:57,000 --> 00:11:58,000 I'm sorry. 701 00:11:58,000 --> 00:11:59,000 I'm sorry. 702 00:11:59,000 --> 00:12:00,000 I'm sorry. 703 00:12:00,000 --> 00:12:01,000 I'm sorry. 704 00:12:01,000 --> 00:12:02,000 I'm sorry. 705 00:12:03,000 --> 00:12:10,000 All rise. 706 00:12:10,000 --> 00:12:11,000 Carry, carry. 707 00:12:11,000 --> 00:12:17,000 The Wisconsin Supreme Court is now in session. 708 00:12:17,000 --> 00:12:21,000 The Honorable Chief Justice Joe Kerarski Psajte. 709 00:12:21,000 --> 00:12:22,000 Your silence is s layered. 710 00:12:22,000 --> 00:12:23,000 Good morning everybody. 711 00:12:23,000 --> 00:12:25,000 Go ahead and have a seat. 712 00:12:25,000 --> 00:12:41,500 I just want to go through a couple of administrative things before we start today. 713 00:12:41,500 --> 00:12:52,080 Number one, Justice Dowd is having a speaker issue, not to get too personal. 714 00:12:52,080 --> 00:12:58,400 So we've turned the volume up on the sound system, I think it's, I hope it's loud enough. 715 00:12:58,400 --> 00:13:01,640 Will you just be really mindful of that when you're at the podium and you're speaking 716 00:13:01,640 --> 00:13:07,440 into the speaker, and if we can't hear you, I might just stop you and say, please raise 717 00:13:07,440 --> 00:13:13,000 the volume a little bit, or as I would say to my kids, use your inside scream. 718 00:13:13,000 --> 00:13:20,920 The second thing, as it relates to timing, there's a number of you that are arguing on 719 00:13:20,920 --> 00:13:25,840 this side of the table, especially, I want to make sure that everyone gets their questions 720 00:13:25,840 --> 00:13:31,480 answered, and that you have a chance to answer those questions without feeling unduly rushed. 721 00:13:31,480 --> 00:13:38,480 So we'll use the lights as guide posts, but we won't have strict adherence to them with 722 00:13:38,480 --> 00:13:42,000 in reason. 723 00:13:42,000 --> 00:13:47,920 Having said that, we may go over the time, I'm going to be mindful of what time it is 724 00:13:47,920 --> 00:13:53,240 on the clock, and take breaks, I want to try to mitigate misery in this room as much 725 00:13:53,240 --> 00:13:55,960 as possible for everyone involved. 726 00:13:55,960 --> 00:13:59,520 So if I stop you in the middle, I'm going to try to stop anyone in the middle of a point 727 00:13:59,520 --> 00:14:03,600 or an argument, but it's possible that it might stop you in the middle of your argument 728 00:14:03,600 --> 00:14:08,680 depending on where we are, I'm just letting you know that ahead of time, just because 729 00:14:08,680 --> 00:14:14,720 I want to be able to try to keep it pretty close to 90 minutes. 730 00:14:14,720 --> 00:14:20,280 I think that is all I have preliminarily, so the first case that we have today is Elizabeth 731 00:14:20,280 --> 00:14:32,960 Bothelld versus the Wisconsin Elections Commission, and may I please have the appearances? 732 00:14:32,960 --> 00:14:38,080 And I believe you're appearing pro-hoc-viche, yes, okay, welcome to the Wisconsin State 733 00:14:38,080 --> 00:14:40,880 Bar for the purposes of today's hearing. 734 00:14:40,880 --> 00:15:06,160 Good morning, and this is what I have for timing, at least according to my sheet, is 735 00:15:06,160 --> 00:15:14,840 25 minutes, followed by 10, 10, 10, and then back to you for five, all right, oh, we are 736 00:15:14,840 --> 00:15:24,480 ready when you are. 737 00:15:24,480 --> 00:15:25,480 Thank you, Your Honors. 738 00:15:25,480 --> 00:15:28,680 Good morning, Madam Chief Justice, and may it please the court. 739 00:15:28,680 --> 00:15:33,520 Wisconsin's congressional map was adopted based on the methodology that this court has 740 00:15:33,520 --> 00:15:35,360 since overruled. 741 00:15:35,360 --> 00:15:37,840 The map is therefore unlawful. 742 00:15:37,840 --> 00:15:43,600 The Bothelld plaintiff's separation of powers claim rests on three basic pillars that have 743 00:15:43,600 --> 00:15:47,000 already been established by this court. 744 00:15:47,000 --> 00:15:52,600 One, the map was adopted pursuant to a least change mandate. 745 00:15:52,600 --> 00:15:58,480 This court said so in Johnson 2, where it selected the map because it quote, most complies 746 00:15:58,480 --> 00:16:01,440 with our least change directive. 747 00:16:01,800 --> 00:16:06,880 Two, least change is no longer good law. 748 00:16:06,880 --> 00:16:12,320 This court said so in Clark, where it explained that least change is incompatible with the 749 00:16:12,320 --> 00:16:19,440 judiciary's institutional obligations of neutrality and independence and expressly overruled 750 00:16:19,440 --> 00:16:24,720 any portions of Johnson that mandate a least change approach. 751 00:16:24,720 --> 00:16:30,960 And three, this court has the power to right this wrong. 752 00:16:30,960 --> 00:16:37,640 It itself rejected virtually identical procedural obstacles and objections that interveners 753 00:16:37,640 --> 00:16:44,400 advance here and confirmed that this court can and should require a lawful replacement 754 00:16:44,400 --> 00:16:47,880 for an unlawful court-drawn map going forward. 755 00:16:47,880 --> 00:16:51,920 Council, I want to take you from Johnson 2 to Johnson 1, okay? 756 00:16:51,920 --> 00:16:56,000 Are you asking us to overturn Johnson 1? 757 00:16:56,000 --> 00:17:01,520 I believe this court has already overruled the basis of Johnson 1, the least changed 758 00:17:01,520 --> 00:17:07,360 map that was the direction from Johnson 1, and it also overturned the map that was drawn 759 00:17:07,360 --> 00:17:08,360 pursuant to that. 760 00:17:08,360 --> 00:17:12,720 I think by the logic, because it overturned the logic of the least changed map, we are 761 00:17:12,720 --> 00:17:17,240 now asking the court to finish that job and actually apply that to the ongoing injunction 762 00:17:17,240 --> 00:17:18,920 that applies for congressional districts. 763 00:17:18,920 --> 00:17:24,120 So some of us might think maybe Johnson 1 was only addressed in part. 764 00:17:24,600 --> 00:17:29,720 Do you want to go on with that argument and tell us why you think it's already been overturned? 765 00:17:29,720 --> 00:17:34,400 I mean, I think what this court did not mince any words in Clark when it said, we are here 766 00:17:34,400 --> 00:17:41,400 by overruling any portion of Johnson 1, 2, or 3, that mandates a least change approach. 767 00:17:41,400 --> 00:17:48,400 So there was nothing ambiguous about what it was doing when it talked about wherever you 768 00:17:48,400 --> 00:17:55,560 find least change, whether it was mandated in Johnson 1 or adhered to in Johnson 2. 769 00:17:55,560 --> 00:17:57,520 All of that has been overruled by this court. 770 00:17:57,520 --> 00:18:02,360 So now the question is where you have just a single least change map left standing. 771 00:18:02,360 --> 00:18:06,720 There's only one least change map left standing in Wisconsin. 772 00:18:06,720 --> 00:18:07,720 Are we going with that map? 773 00:18:07,720 --> 00:18:09,560 Is essentially resting on legal quicksand. 774 00:18:09,560 --> 00:18:13,360 Let me push on that, Council. 775 00:18:13,360 --> 00:18:15,160 So that's not what Clark said. 776 00:18:15,160 --> 00:18:19,280 Clark did not say that least change could not be applied, right? 777 00:18:19,280 --> 00:18:20,400 Would you agree with that? 778 00:18:20,400 --> 00:18:24,720 Clark said that least change could be considered as part of traditional districting criteria, 779 00:18:24,720 --> 00:18:29,760 but it could not be the mandate that overarches or drives the drawing of the map. 780 00:18:29,760 --> 00:18:34,480 The court said it was overruled to the extent it was mandated as the methodology. 781 00:18:34,480 --> 00:18:39,720 Did not say that least change was always an impermissible methodology, isn't that right? 782 00:18:39,720 --> 00:18:40,720 Correct, Your Honor. 783 00:18:40,720 --> 00:18:48,560 That means that the holding in Johnson 1 is still good, that doesn't disturb that at 784 00:18:48,560 --> 00:18:49,560 all. 785 00:18:49,560 --> 00:18:55,040 There's nothing about Clark that overturned the use of least change as methodology. 786 00:18:55,040 --> 00:18:57,280 Clark just doesn't control that. 787 00:18:57,280 --> 00:19:02,280 It's true that this court decided it was going to adopt a different remedial program for 788 00:19:02,280 --> 00:19:07,680 a new map in Clark if it ever got there, which it never did, but it didn't disturb the use 789 00:19:07,680 --> 00:19:10,560 of it or say that that was somehow illegal. 790 00:19:10,560 --> 00:19:14,520 That's a different argument you're making here today than was addressed in Clark, wouldn't 791 00:19:14,520 --> 00:19:15,520 you say? 792 00:19:15,520 --> 00:19:20,520 I believe that this court actually did explain why least change was not just wrong in principle 793 00:19:20,520 --> 00:19:22,840 or policy, but wrong as a matter of law. 794 00:19:22,840 --> 00:19:28,000 So let me talk a little bit about you frame your argument as a purely separation of powers 795 00:19:28,000 --> 00:19:29,000 argument. 796 00:19:29,000 --> 00:19:35,560 Would you agree that the United States Constitution gives the power to the legislature to draft 797 00:19:35,560 --> 00:19:37,360 congressional districts? 798 00:19:37,360 --> 00:19:38,360 It does. 799 00:19:38,360 --> 00:19:42,400 It primarily gives that power to the legislative branches and to the political process, but 800 00:19:42,400 --> 00:19:46,440 the political process failed this decade and has not been able to produce an inactive 801 00:19:46,440 --> 00:19:47,440 map. 802 00:19:47,440 --> 00:19:49,640 I understand that, right? 803 00:19:49,640 --> 00:19:56,800 But your argument is premised on the idea that in order to vindicate the separation 804 00:19:56,800 --> 00:20:04,680 of powers, the judiciary needs to take for itself the power that has been constitutionally 805 00:20:04,680 --> 00:20:09,640 given to the legislature, because when we did least change, as you acknowledge, we 806 00:20:09,640 --> 00:20:16,240 were deferring to the last democratically enacted maps that were put into law, right? 807 00:20:16,240 --> 00:20:21,440 So they were based on the 2011 maps, which were passed by the legislature, signed by 808 00:20:21,440 --> 00:20:22,440 the governor. 809 00:20:22,440 --> 00:20:23,440 They're in the statute books. 810 00:20:23,440 --> 00:20:24,840 In fact, they're still there. 811 00:20:24,840 --> 00:20:26,320 They were still enacted law. 812 00:20:26,320 --> 00:20:30,880 In this court said, we're going to defer to the policy judgments of the legislature. 813 00:20:30,880 --> 00:20:33,840 We're not going to put our own policy judgments there. 814 00:20:33,840 --> 00:20:37,160 Which the United States Constitution says that's the legislature's prerogative to do 815 00:20:37,160 --> 00:20:38,160 that. 816 00:20:38,160 --> 00:20:42,200 And you're saying it's a violation of the separation of powers for this court to not 817 00:20:42,200 --> 00:20:46,320 take that power for itself, but to defer to the legislature? 818 00:20:46,320 --> 00:20:49,840 That is quite a creative argument to me. 819 00:20:49,840 --> 00:20:53,760 In your honor, it's only in creative in the sense that this court has already made that 820 00:20:53,760 --> 00:20:55,320 argument in Clark. 821 00:20:55,320 --> 00:20:58,240 So two points in response to your question, your honor. 822 00:20:58,240 --> 00:21:01,400 One is the court did not take any redistricting power here. 823 00:21:01,400 --> 00:21:07,360 The redistricting power was given, was assigned to this court because the political process 824 00:21:07,360 --> 00:21:08,360 failed. 825 00:21:08,360 --> 00:21:10,560 This court had no choice but to engage in judicial redistricting. 826 00:21:10,560 --> 00:21:18,080 Your argument is that when this court deferred to the decision of the legislature, that it 827 00:21:18,080 --> 00:21:25,640 violated the separation of powers, when the Constitution gives those powers to the legislature 828 00:21:25,640 --> 00:21:27,480 in the first instance. 829 00:21:27,480 --> 00:21:30,840 And your honor, my argument is that Clark has already made that holding. 830 00:21:30,880 --> 00:21:35,480 So when this court, in all of this court's debate about the least changed principle and 831 00:21:35,480 --> 00:21:40,200 the consideration of partisan effects, the conversation has stemmed around, has centered 832 00:21:40,200 --> 00:21:46,600 on what is the judiciary's role in redistricting, vis-a-vis the other political branches. 833 00:21:46,600 --> 00:21:52,120 And in Johnson One, the court specifically invoked separation of powers to justify the 834 00:21:52,120 --> 00:21:57,800 least changed approach and argue that it was necessary to preserve the institutional legitimacy 835 00:21:57,800 --> 00:21:58,960 of the court. 836 00:21:59,000 --> 00:22:04,840 In Justice Dallas, Dallas, dissent in Johnson One, the dissent also argued against least 837 00:22:04,840 --> 00:22:10,800 change, again using the terms of separation of powers, saying that this court cannot start 838 00:22:10,800 --> 00:22:16,400 with the prior maps and maintain judicial neutrality consistent with our role as a nonpartisan 839 00:22:16,400 --> 00:22:17,720 institution. 840 00:22:17,720 --> 00:22:22,560 So when Clark came in and talked about, well, now what is given, what we've now, what the 841 00:22:22,560 --> 00:22:28,840 court ruled in Clark, what is the court's role in redistricting when it is, when the 842 00:22:28,880 --> 00:22:33,320 task falls to it, and Clark made very clear, and if the court will allow, if I can just 843 00:22:33,320 --> 00:22:38,800 quote from paragraph 71 of Clark, it speaks in the terms of separation of powers. 844 00:22:38,800 --> 00:22:44,920 It bears repeating that courts can and should hold themselves to a different standard than 845 00:22:44,920 --> 00:22:49,520 the legislature regarding the partisanship of remedial maps. 846 00:22:49,520 --> 00:22:55,480 As a politically neutral and independent institution, we will take care to avoid selecting remedial 847 00:22:55,480 --> 00:22:59,760 maps designed to advantage one political party over another. 848 00:22:59,760 --> 00:23:07,240 Importantly, however, it is not possible to remain neutral and independent by failing 849 00:23:07,240 --> 00:23:11,440 to consider partisan impact entirely. 850 00:23:11,440 --> 00:23:17,280 By the very terms of Clark that I just read your honor, it was not possible for this court 851 00:23:17,280 --> 00:23:24,120 to abide by the judiciary's twin duties of neutrality and independence by applying least 852 00:23:24,120 --> 00:23:29,960 change and adopting all the partisan effects of the previous map and not considering its 853 00:23:29,960 --> 00:23:31,600 own role in redistricting. 854 00:23:31,600 --> 00:23:35,760 So least change, do you think least change is always problematic? 855 00:23:35,760 --> 00:23:39,880 So for example, let's say you weren't here challenging the congressional maps, but you 856 00:23:39,880 --> 00:23:47,560 were here challenging the legislative districts that have now been recently enacted into law. 857 00:23:47,560 --> 00:23:53,400 So if we applied least change to that, we would defer to the recently enacted maps that were 858 00:23:53,400 --> 00:23:56,080 signed into law. 859 00:23:56,080 --> 00:23:59,320 When passed by the Republican legislature, signed by the Democratic governor, lots of 860 00:23:59,320 --> 00:24:03,520 fighting, obviously this court got in the middle of all that with Clark. 861 00:24:03,520 --> 00:24:09,320 But your argument would, that would be unconstitutional to simply defer to the policy choices of the 862 00:24:09,320 --> 00:24:14,200 legislature and signed by the governor with regard to legislative maps. 863 00:24:14,200 --> 00:24:19,600 Well, our argument is that blind deference is unconstitutional and in contrary to the 864 00:24:19,600 --> 00:24:20,600 principles in Clark. 865 00:24:20,760 --> 00:24:24,760 In the example that your honor mentioned, where there is actually a legislative enactment 866 00:24:24,760 --> 00:24:28,880 to consider and defer to, courts have often held in the redistricting context that you 867 00:24:28,880 --> 00:24:33,640 can defer to the policy choices of the legislature to the extent they don't otherwise violate 868 00:24:33,640 --> 00:24:34,640 the law. 869 00:24:34,640 --> 00:24:39,040 Now here, there was no policy choice of the legislature in effect. 870 00:24:39,040 --> 00:24:43,920 The old map had expired, everybody came into this court and agreed that it was no longer 871 00:24:43,920 --> 00:24:47,960 operative law and the question was, what is there left to defer to? 872 00:24:47,960 --> 00:24:51,720 Well, that's not, the maps don't expire. 873 00:24:51,720 --> 00:24:56,440 It was declared unconstitutional to the extent it was no longer reflecting proportion of 874 00:24:56,440 --> 00:24:59,920 population, which United States mandate is required. 875 00:24:59,920 --> 00:25:03,320 The Wisconsin Constitution says nothing about congressional redistricting. 876 00:25:03,320 --> 00:25:05,560 It's still law, it's still in the books, it didn't go away. 877 00:25:05,560 --> 00:25:10,200 The only thing we were trying to do was remedy a constitutional wrong, which was simply proportional 878 00:25:10,200 --> 00:25:11,280 representation. 879 00:25:11,280 --> 00:25:15,040 The maps, there was no, there's no expiration date on the law. 880 00:25:15,040 --> 00:25:19,960 I mean, as a matter of federal constitutional law, that map could not remain in effect going 881 00:25:19,960 --> 00:25:20,960 forward. 882 00:25:20,960 --> 00:25:24,360 There was a constitutional sunset and every party that came into this court acknowledged 883 00:25:24,360 --> 00:25:25,360 that. 884 00:25:25,360 --> 00:25:30,600 And when this court remedied the mal apportionment violation, our argument is that per the discussion 885 00:25:30,600 --> 00:25:35,360 in Clark and per the holding in Clark, it ended up creating a brand new legal violation 886 00:25:35,360 --> 00:25:41,240 by really veering outside the judicial lane of neutrality and independence by adhering 887 00:25:41,240 --> 00:25:45,640 to a previous legislature's policy views and failing to consider the part as an impact 888 00:25:45,640 --> 00:25:46,640 of its own decision. 889 00:25:46,640 --> 00:25:47,640 So, Council, I'm going to talk. 890 00:25:47,640 --> 00:25:48,640 I was going to- 891 00:25:48,640 --> 00:25:50,640 It's just to take it or instill going? 892 00:25:50,640 --> 00:25:52,640 No, but I was going to- 893 00:25:52,640 --> 00:25:53,640 Okay. 894 00:25:53,640 --> 00:25:54,640 Council, I have a question. 895 00:25:54,640 --> 00:25:59,080 I'm going to pull you back to Johnson One, okay? 896 00:25:59,080 --> 00:26:03,240 And I think that there's clearly a difference of opinion as to whether or not Johnson One 897 00:26:03,240 --> 00:26:05,440 has been overruled. 898 00:26:05,440 --> 00:26:11,040 Let's assume for the sake of this argument right now that it has not. 899 00:26:11,040 --> 00:26:16,840 Are you asking us then to overrule Johnson One regarding partisan gerrymandering? 900 00:26:16,840 --> 00:26:19,280 Yes or no? 901 00:26:19,280 --> 00:26:23,720 So I want to make very clear, Your Honor, that we have two claims before this court. 902 00:26:23,720 --> 00:26:24,720 We know. 903 00:26:24,720 --> 00:26:27,720 So, claimed on is the separation of powers claim, which I think we've been talking about here. 904 00:26:27,720 --> 00:26:33,160 And when I talk about overruling what Clark has overruled in Johnson, it's expressly overruled 905 00:26:33,160 --> 00:26:36,000 the least changed principle in Johnson about how to remedy the- 906 00:26:36,000 --> 00:26:37,600 Let's talk about the partisan gerrymandering claim. 907 00:26:37,600 --> 00:26:41,960 So the question about the partisan gerrymandering claim, which is our alternative claim. 908 00:26:41,960 --> 00:26:46,520 Our argument there is that there was never actually a holding in Johnson One about partisan 909 00:26:46,520 --> 00:26:50,000 gerrymandering saying that it is or is not just dishable. 910 00:26:50,000 --> 00:26:54,480 And that is because there was no partisan gerrymandering claim before Johnson One. 911 00:26:54,480 --> 00:26:59,120 While the court does, I believe in paragraph eight of Johnson One, say that it is not a 912 00:26:59,120 --> 00:27:04,720 cognizable claim, that portion of Johnson One garnered only three votes from this court 913 00:27:04,720 --> 00:27:06,840 and was not a majority opinion. 914 00:27:06,840 --> 00:27:11,680 The only majority opinion from this court on the issue of partisan gerrymandering was 915 00:27:11,680 --> 00:27:16,760 in Clark when the court specifically said that partisan gerrymandering remains an important 916 00:27:16,760 --> 00:27:19,720 and unresolved issue of Wisconsin law. 917 00:27:19,720 --> 00:27:24,680 And it specifically said it was not deciding whether or not such claims were just dishable. 918 00:27:24,680 --> 00:27:28,920 So there is nothing- I don't believe there's anything in Johnson to overturn and to the 919 00:27:28,920 --> 00:27:33,600 extent that there was, Clark has already done it by making the- this court's holding clear. 920 00:27:34,000 --> 00:27:42,800 All right, well, I'm looking at the congressman's brief, specifically pages 42, 43, 44. 921 00:27:42,800 --> 00:27:51,520 When I look at page 43, the second full paragraph, it talks about that it's unsurprising that 922 00:27:51,520 --> 00:27:56,760 nothing in this court's precedent establishes judicially manageable standards to adjudicate 923 00:27:56,760 --> 00:28:00,040 the plaintiffs' partisan gerrymandering claims. 924 00:28:00,040 --> 00:28:03,480 And then some pretty compelling arguments are made. 925 00:28:03,480 --> 00:28:05,280 Can you please respond to those? 926 00:28:05,280 --> 00:28:09,080 So there's kind of two issues when it comes to partisan gerrymandering. 927 00:28:09,080 --> 00:28:11,680 One is has this court already kind of closed the door on it? 928 00:28:11,680 --> 00:28:13,160 Our answer to that is no. 929 00:28:13,160 --> 00:28:14,560 This court's answer to that is no. 930 00:28:14,560 --> 00:28:17,000 And Clark had said it was an unresolved legal issue. 931 00:28:17,000 --> 00:28:21,400 And then the next question is, well, now that it is unresolved, how should we resolve it? 932 00:28:21,400 --> 00:28:25,080 Is it a legally cognizable claim that has judicially manageable standards? 933 00:28:25,080 --> 00:28:27,960 And our answer to that is absolutely yes. 934 00:28:27,960 --> 00:28:32,600 The fact that the Supreme Court, the US Supreme Court, has said that it's not just 935 00:28:32,600 --> 00:28:36,120 a considerable under federal law, does not make, undeclate that it's not just a 936 00:28:36,120 --> 00:28:37,320 considerable under state law. 937 00:28:37,320 --> 00:28:41,480 Ten other state courts have found partisan gerrymandering just a considerable under 938 00:28:41,480 --> 00:28:46,120 constitutional provisions, very similar to the ones that we rely upon here in Wisconsin. 939 00:28:46,120 --> 00:28:50,920 There's no reason why Wisconsin could not adopt that, any one of those models that 940 00:28:50,920 --> 00:28:55,280 the other state courts have adopted, to make sure that it is protecting what is in Wisconsin 941 00:28:55,280 --> 00:29:01,040 a far more robust right to democratic self-governance than is provided in the US Constitution. 942 00:29:01,040 --> 00:29:04,880 Do those other states have the same constitutional language? 943 00:29:04,880 --> 00:29:05,880 Many of them do, Your Honor. 944 00:29:05,880 --> 00:29:10,640 For instance, in states like, sorry, in a case like Pennsylvania and North Carolina, 945 00:29:10,640 --> 00:29:15,720 they had what we called free and equal elections clauses, which are very similar to the provisions 946 00:29:15,720 --> 00:29:18,360 that we cite here, specifically the free government clause. 947 00:29:18,360 --> 00:29:23,120 And in other states, such as New Mexico or Alaska, they rely on their state equal protection 948 00:29:23,120 --> 00:29:24,120 clauses. 949 00:29:24,120 --> 00:29:30,320 And here, in Article 1 of the Wisconsin Constitution, we're looking at Section 1, 3, 4, and 22, 950 00:29:30,320 --> 00:29:34,840 equal protection, free speech, free association, and free government provisions. 951 00:29:34,840 --> 00:29:41,320 All of these provide independent and combined bases to find this fundamental principle 952 00:29:41,320 --> 00:29:43,080 of democratic self-governance. 953 00:29:43,080 --> 00:29:47,080 And all of them provide a basis to say that partisan gerrymandering is antithetical to 954 00:29:47,080 --> 00:29:48,640 those fundamental principles. 955 00:29:48,640 --> 00:29:53,440 So going back to that, then do you conceive of Article 1, Section 1 of the Wisconsin 956 00:29:53,440 --> 00:29:57,520 Constitution as an equal protection provision? 957 00:29:57,600 --> 00:29:58,600 I do, Your Honor. 958 00:29:58,600 --> 00:30:03,360 I think we've been viewing the idea that the citizens are entitled to equal treatment 959 00:30:03,360 --> 00:30:07,560 under the law and cannot be arbitrarily treated based on their viewpoint, based on their 960 00:30:07,560 --> 00:30:12,720 residence, and that's how we are envisioning this claim as well, in addition to the free. 961 00:30:12,720 --> 00:30:15,800 Do we then need to consider tiers of scrutiny? 962 00:30:15,800 --> 00:30:20,800 I believe under this courts, so look, there are many ways that this court can, yes, so 963 00:30:20,800 --> 00:30:24,520 if this court is going to conceive of this solely as an equal protection violation, then 964 00:30:24,560 --> 00:30:27,480 you're going to have to think about what are the appropriate tiers of scrutiny. 965 00:30:27,480 --> 00:30:31,200 But then again, but here again, there are many models for how to do this. 966 00:30:31,200 --> 00:30:35,720 Justice Kagan's dissent in Rucho, which was then the same model was followed in states 967 00:30:35,720 --> 00:30:40,760 like New Mexico and Alaska, where she basically provides a fundamental equal protection analysis. 968 00:30:40,760 --> 00:30:46,440 Let's look at predominance when it comes to partisan vote dilution, the predominant 969 00:30:46,440 --> 00:30:52,360 purpose, was that in fact the effect of the map, and is there any legislative justification 970 00:30:52,400 --> 00:30:57,640 outside of sheer partisan dominance that would justify the configuration of these districts? 971 00:30:57,640 --> 00:31:00,560 Is that the test that you're asking us to adopt? 972 00:31:00,560 --> 00:31:05,720 So we are not pressing one specific test, we believe that this court has at its disposal, 973 00:31:05,720 --> 00:31:08,320 the opportunity to look at any different, any model that it wants. 974 00:31:08,320 --> 00:31:12,360 We have specifically pointed to the model from Pennsylvania, which is more of a traditional 975 00:31:12,360 --> 00:31:17,880 subordination test and effects based test, but that is not the only way to map onto this 976 00:31:17,880 --> 00:31:21,800 claim, you can do it based on the one that's in New Mexico, based on the one that's in 977 00:31:21,800 --> 00:31:22,800 Justice Kagan's dissent. 978 00:31:22,800 --> 00:31:26,640 What are you recommending that we do? 979 00:31:26,640 --> 00:31:30,760 What we have recommended in our papers is the test that's provided in Pennsylvania. 980 00:31:30,760 --> 00:31:36,400 We think that's the most clear, it's a traditional subordination test, the extent to which traditional 981 00:31:36,400 --> 00:31:40,960 districting principles have been subordinated to partisan advantage and partisan gain. 982 00:31:40,960 --> 00:31:45,600 And the court has many in Pennsylvania, outlines a number of tools that courts can use as 983 00:31:45,600 --> 00:31:49,840 both direct and circumstantial evidence to decide whether or not, essentially, the way 984 00:31:50,000 --> 00:31:55,720 the map is drawn, stacks the deck in favor of one party or another to an extreme degree, 985 00:31:55,720 --> 00:31:59,880 such that the decision is essentially made before a single ballot has been cast. 986 00:31:59,880 --> 00:32:08,480 So if I'm understanding that method, are you only looking at a single map, or are as opposed 987 00:32:08,480 --> 00:32:13,920 to if I think about Justice Kagan's dissent in Rucho, where she's talking about looking 988 00:32:13,920 --> 00:32:18,080 at, I think she uses an example of a thousand maps and looking at where they are on the 989 00:32:18,080 --> 00:32:19,080 curve. 990 00:32:19,080 --> 00:32:24,400 I'm not quite understanding if you adopt the punch of, if you're asking us to adopt the 991 00:32:24,400 --> 00:32:27,360 Pennsylvania model, if we adopt that model, what does that look like exactly? 992 00:32:27,360 --> 00:32:32,320 Are we just looking at the one map that is in front of us, or is it, are we comparing 993 00:32:32,320 --> 00:32:33,560 it to other maps? 994 00:32:33,560 --> 00:32:34,560 So absolutely, your honor. 995 00:32:34,560 --> 00:32:37,680 So what, obviously, there's only one map in front of the court when it comes to what 996 00:32:37,680 --> 00:32:43,160 we are ch- how we can prove that, how somebody can prove a partisan gerrymandering claim. 997 00:32:43,160 --> 00:32:45,640 There are many different evidentiary ways to do that. 998 00:32:45,640 --> 00:32:51,000 One of those that's typically used in partisan gerrymandering claims is this, the simulations 999 00:32:51,000 --> 00:32:52,000 approach, right? 1000 00:32:52,000 --> 00:32:57,040 The, using multiple maps to show, would this ever have occurred based on the political, 1001 00:32:57,040 --> 00:33:01,960 natural political geography of the state, or was there some undue partisan intent that 1002 00:33:01,960 --> 00:33:05,640 really was skewing the map, well, I understand that, but if I understand the Pennsylvania 1003 00:33:05,640 --> 00:33:10,880 model, you're looking at the map that is created, and you're saying, has it been, has the, 1004 00:33:11,840 --> 00:33:15,920 if you're rank ordering, why you, why you created the map you did, is it subordinate 1005 00:33:15,920 --> 00:33:18,640 to the constitutional requirements, or is it not? 1006 00:33:18,640 --> 00:33:23,280 I'm asking, are you just looking at that one map, and at those requirements as it relates 1007 00:33:23,280 --> 00:33:24,280 to that one map? 1008 00:33:24,280 --> 00:33:27,800 I understand that you can look at a thousand maps, I understand you can look, we could 1009 00:33:27,800 --> 00:33:33,680 look at more than that, right, easily, today, but, but I'm not, I just want to make sure 1010 00:33:33,680 --> 00:33:38,640 I understand how you envision that process, how that process, if we adopted it, would 1011 00:33:38,640 --> 00:33:41,920 work in the trial court in this case. 1012 00:33:41,920 --> 00:33:45,240 So I think the way it would work following the Pennsylvania model, which, by the way, 1013 00:33:45,240 --> 00:33:48,960 is spelled out really chapter and verse in that, in that opinion, is that the court would 1014 00:33:48,960 --> 00:33:55,200 essentially look at the traditional districting criteria, the, the objective, political geography 1015 00:33:55,200 --> 00:34:01,360 of the state, and ask, to what extent do the district lines veer from the traditional 1016 00:34:01,360 --> 00:34:06,040 districting, just subordinate those, those traditional districting principles in service 1017 00:34:06,040 --> 00:34:07,760 of some partisan advantage? 1018 00:34:07,760 --> 00:34:12,040 And the way you answer that question is by looking at evidence from computer simulation 1019 00:34:12,040 --> 00:34:16,680 maps, looking at statistics like the efficiency gap that shows wasted votes. 1020 00:34:16,680 --> 00:34:20,880 There are a number of models at the Supreme Court in Pennsylvania recognized that are 1021 00:34:20,880 --> 00:34:24,600 able to provide that evidence, so we know what we're looking for when we're looking 1022 00:34:24,600 --> 00:34:25,600 at this one map. 1023 00:34:25,600 --> 00:34:33,320 Why are you advocating for that instead of the intent, effects, and causation test that 1024 00:34:33,320 --> 00:34:36,760 Justice Kagan talked about in her Rucho descent? 1025 00:34:36,760 --> 00:34:41,520 So Your Honor, I don't want to overstate our advocacy for one model over another. 1026 00:34:41,520 --> 00:34:46,600 At this point, our number one, well, our number one argument is that this court can strike 1027 00:34:46,600 --> 00:34:51,440 down this map as a matter of law based on the law it's already drafted in Clark. 1028 00:34:51,440 --> 00:34:55,440 But if the court decides to go down the partisan gerrymandering route, our argument there 1029 00:34:55,440 --> 00:34:59,760 is that that is actually, that is not, that is a traditional route that many states have 1030 00:34:59,760 --> 00:35:00,760 followed. 1031 00:35:00,760 --> 00:35:04,280 And this court can choose whatever it deems to be the best test that it sounds fit. 1032 00:35:04,280 --> 00:35:08,120 So I've suggested the Pennsylvania one, I believe that the way that model has worked 1033 00:35:08,120 --> 00:35:09,880 out is very clear. 1034 00:35:09,880 --> 00:35:13,800 But the one that is provided by Justice Kagan's descent and has been used in states like New 1035 00:35:13,800 --> 00:35:19,160 Mexico is equally justishable, it is standard that is easily comprehended by courts and 1036 00:35:19,160 --> 00:35:20,920 applied by courts at all levels. 1037 00:35:20,920 --> 00:35:29,400 Yeah, I don't want to overstate the importance to us of figuring out which path we should 1038 00:35:29,400 --> 00:35:32,160 take in order to get this right. 1039 00:35:32,160 --> 00:35:38,720 So, Council, can I pull you, are you, I'm sorry, are you? 1040 00:35:38,720 --> 00:35:39,720 I was just musing. 1041 00:35:39,720 --> 00:35:44,840 You were just musing, okay, that's what we do periodically, you'll notice. 1042 00:35:44,840 --> 00:35:51,520 I would like to get back to the concept of justishability, say that 20 times fast. 1043 00:35:51,520 --> 00:35:56,440 And look at our constitution, what our constitution says. 1044 00:35:56,440 --> 00:36:03,280 When you look at Article 1, Section 1, that people are sovereign, that government has 1045 00:36:03,280 --> 00:36:09,600 no power except through the consent of the governed. 1046 00:36:09,600 --> 00:36:17,960 And we are interested as a state court in looking at these maps as whether they present 1047 00:36:17,960 --> 00:36:25,560 a constitutional harm to these principles of self-representation, of sovereignty of the 1048 00:36:25,560 --> 00:36:30,880 people of the state of Wisconsin, which is some through lines throughout our constitution, 1049 00:36:30,880 --> 00:36:37,720 some beautiful constitution with very rich words and it makes very clear that the people 1050 00:36:37,720 --> 00:36:41,920 have the power, not the politicians, it is the people. 1051 00:36:41,920 --> 00:36:49,240 So when we're looking at justishability, why we are so focused on what test do we apply, 1052 00:36:49,240 --> 00:36:54,520 assuming it's cognizable, right, assuming this claim, and you're saying it is because 1053 00:36:54,520 --> 00:36:59,520 of these provisions in our state constitution, so we have equal protection. 1054 00:36:59,520 --> 00:37:01,600 We have inherent rights. 1055 00:37:01,600 --> 00:37:08,800 We have free speech, the right to assembly, this court has a role in remedying wrongs. 1056 00:37:08,800 --> 00:37:11,640 So what else are we looking at in terms of a test? 1057 00:37:11,640 --> 00:37:16,500 So we have, you've identified, there's these different tests out there, 10 states have 1058 00:37:16,500 --> 00:37:19,000 adopted some form of these tests. 1059 00:37:19,000 --> 00:37:23,500 We certainly want to make sure the test is manageable. 1060 00:37:23,500 --> 00:37:30,060 We want to make sure it's neutral, but what other guidance do you suggest this court 1061 00:37:30,060 --> 00:37:37,140 looked you when we are measuring whether this map presents a constitutional harm? 1062 00:37:37,140 --> 00:37:41,620 I believe your honor, and I appreciate exactly what you said, I agree that the Wisconsin 1063 00:37:41,620 --> 00:37:46,740 constitution makes no mistake that democratic self-governance is the very foundation. 1064 00:37:46,740 --> 00:37:52,740 And so there is a wrong under with the Wisconsin constitution that requires a remedy if the 1065 00:37:52,740 --> 00:37:55,860 court decides to go down the part, it's a gerrymandering approach. 1066 00:37:55,860 --> 00:38:00,740 When it comes to what the test can be, like I said, we have advocated for the Pennsylvania 1067 00:38:00,740 --> 00:38:05,660 approach, which we believe is actually the most straightforward and easily easy to administer, 1068 00:38:05,660 --> 00:38:09,900 but I'm not trying to dissuade the court from what I think is also a straightforward and 1069 00:38:09,900 --> 00:38:10,900 easy to administer. 1070 00:38:10,900 --> 00:38:15,260 Well, let me ask you about that, because if you look at New Mexico, which I would say 1071 00:38:15,260 --> 00:38:23,380 has some very similar provisions on the sovereignty of the people on the government having to 1072 00:38:23,380 --> 00:38:30,260 have the consent of the governed, they also apply a causation piece. 1073 00:38:30,260 --> 00:38:37,260 And that is because we recognize, I don't think anybody on this panel would say, nobody 1074 00:38:37,260 --> 00:38:44,660 would dispute, the state has an important constitutional role in redistricting. 1075 00:38:44,660 --> 00:38:50,740 And so, isn't it, shouldn't it, wouldn't it be prudent of us to not just apply intent 1076 00:38:50,740 --> 00:38:56,020 effects, but then to give the state the opportunity to present, if there is a legitimate interest 1077 00:38:56,020 --> 00:39:00,980 that perhaps we're not thinking of, because that recognizes that the state does have important 1078 00:39:00,980 --> 00:39:02,820 role in redistricting. 1079 00:39:02,820 --> 00:39:06,320 I agree with that, Your Honor, and I think this Court's equal protection jurisprudence 1080 00:39:06,320 --> 00:39:09,980 makes clear that the question would then be posed to the state, is there a legitimate 1081 00:39:09,980 --> 00:39:14,180 interest that justifies this deviation? 1082 00:39:14,180 --> 00:39:18,580 And I think actually under either test that this Court adopts, the state would be given 1083 00:39:18,580 --> 00:39:24,260 that opportunity to prove that no, no, what you're seeing from the data and from the evidence 1084 00:39:24,260 --> 00:39:29,340 is not the result of partisan gamesmanship, but is actually the result of some other legitimate 1085 00:39:29,340 --> 00:39:30,340 criteria. 1086 00:39:30,340 --> 00:39:32,140 I believe that the state would have that ability. 1087 00:39:32,140 --> 00:39:37,060 I don't think that the, I think either of these tests are difficult for plaintiffs to 1088 00:39:37,100 --> 00:39:42,980 prove intentionally difficult, but I think ultimately manageable for the Court to decide 1089 00:39:42,980 --> 00:39:47,340 to make sure that it's not just striking down maps willy-nilly, but is actually applying 1090 00:39:47,340 --> 00:39:49,940 chapter and verse exactly what the rules are. 1091 00:39:49,940 --> 00:39:57,420 I have just one more question on this issue, and that is, do we not use in judging this, 1092 00:39:57,420 --> 00:40:02,580 just disability, do we not use the same data that the map makers used? 1093 00:40:03,060 --> 00:40:05,420 I mean, is that why it's quantifiable? 1094 00:40:05,420 --> 00:40:11,860 Because map makers are able to distill down to the household and predict what is, what 1095 00:40:11,860 --> 00:40:17,380 is the, we don't have party registration here, but what is the likely affiliation here? 1096 00:40:17,380 --> 00:40:23,980 And so does it make it quantifiable in this context because we have the data now that 1097 00:40:23,980 --> 00:40:29,700 we didn't have, our founders didn't have, even our grandfathers, did not have the data 1098 00:40:29,700 --> 00:40:32,100 that we have now to make these determinations? 1099 00:40:32,140 --> 00:40:36,700 I think certainly the tools that are available to courts to be able to discern what has happened. 1100 00:40:36,700 --> 00:40:40,300 And these tools that are available to map drawers to discern, to figure out how to 1101 00:40:40,300 --> 00:40:44,700 greet the effects that they want are far more sophisticated, which is all the, all the more 1102 00:40:44,700 --> 00:40:50,780 reason why this Court said in Clark that this Court cannot afford to blind itself to those 1103 00:40:50,780 --> 00:40:55,020 very true realities that lawmakers are aware of when they are drawing maps. 1104 00:40:55,020 --> 00:40:59,900 When a court is drawing maps, it too needs to deal with the entire political demographic 1105 00:40:59,940 --> 00:41:04,220 factual, census-based reality to make sure that it's drawing maps that are fair and 1106 00:41:04,220 --> 00:41:05,620 constitutional for Wisconsin voters. 1107 00:41:05,620 --> 00:41:08,860 So you can tell we're trying to pull you across the line here because these cases are 1108 00:41:08,860 --> 00:41:11,020 complicated, right? 1109 00:41:11,020 --> 00:41:16,260 And if we find them to be just dishable, we need to be advising the three judges. 1110 00:41:16,260 --> 00:41:17,420 That should be. 1111 00:41:17,420 --> 00:41:21,980 So can you clearly tell us why you think the Pennsylvania test is straightforward? 1112 00:41:21,980 --> 00:41:25,740 We believe the Pennsylvania straight is test is straightforward because it looks, it does 1113 00:41:25,780 --> 00:41:30,900 not delve into the hearts and minds of the map drawers and deciding which map drawers 1114 00:41:30,900 --> 00:41:32,060 are most at issue. 1115 00:41:32,060 --> 00:41:36,660 It looks at the actual effects of the map itself to decide whether the maps abordinates 1116 00:41:36,660 --> 00:41:40,980 traditional constitutional principles to partisan advantage. 1117 00:41:40,980 --> 00:41:42,460 Can it be explained? 1118 00:41:42,460 --> 00:41:45,980 Can the deviations from traditional principles be explained by anything other than sheer 1119 00:41:45,980 --> 00:41:48,740 partisan gamesmanship? 1120 00:41:48,740 --> 00:41:53,580 So looking, I think, at the effects test that the Pennsylvania Court emphasizes is perhaps 1121 00:41:53,580 --> 00:41:58,860 the, I would say, you know, the most straightforward way of determining this. 1122 00:41:58,860 --> 00:42:02,940 But again, I don't think that the Court needs to shy away from looking at intent. 1123 00:42:02,940 --> 00:42:05,180 This is the kind of stuff that courts do all the time. 1124 00:42:05,180 --> 00:42:08,260 If it wanted to, probably, a more intent or causation-based approach. 1125 00:42:08,260 --> 00:42:09,260 Okay. 1126 00:42:09,260 --> 00:42:13,260 I want to take you through some procedural things here. 1127 00:42:13,260 --> 00:42:17,620 So let's say we were to find your claims just dishable. 1128 00:42:17,620 --> 00:42:21,020 I just want to go through kind of what that looks like. 1129 00:42:21,020 --> 00:42:25,500 How do you get from there to a new map? 1130 00:42:25,500 --> 00:42:26,500 Thank you, Your Honor. 1131 00:42:26,500 --> 00:42:31,660 So I'm just going to reiterate that, you know, so option number one is to strike down the 1132 00:42:31,660 --> 00:42:35,660 map as a matter of law, because it's already been struck down as a matter of principle. 1133 00:42:35,660 --> 00:42:37,300 Let's go to option number two. 1134 00:42:37,300 --> 00:42:42,460 Option number two is to decide that Wisconsin's Constitution bars partisan gerrymandering 1135 00:42:42,460 --> 00:42:45,820 and develop a stand and announce a standard that says, this is. 1136 00:42:45,820 --> 00:42:48,620 And I'm going to qualify you, not just bars partisan gerrymandering. 1137 00:42:48,620 --> 00:42:51,380 Isn't there some extreme partisan gerrymandering? 1138 00:42:51,380 --> 00:42:53,020 Isn't that what we're really talking about? 1139 00:42:53,020 --> 00:42:59,940 I mean, you set it already that it's basically taking away, it's making a decision before 1140 00:42:59,940 --> 00:43:02,660 the election has even begun for the people in the district. 1141 00:43:02,660 --> 00:43:03,660 Exactly, Your Honor. 1142 00:43:03,660 --> 00:43:06,380 I'm using the word part of the gerrymandering as a shorthand for what courts have often 1143 00:43:06,380 --> 00:43:11,620 referred to as an extreme partisan gerrymander that is essentially an outlier and not explainable 1144 00:43:11,620 --> 00:43:13,060 by any other criteria. 1145 00:43:13,060 --> 00:43:14,060 Okay. 1146 00:43:14,060 --> 00:43:15,860 So we find that and then what? 1147 00:43:15,860 --> 00:43:20,260 And I think that this court has already discussed, I think it adopts the model that 1148 00:43:20,260 --> 00:43:24,340 it deems to be most fit for determining what is a partisan gerrymander. 1149 00:43:24,340 --> 00:43:28,380 And then I think it would need to remand back to the panel for a fact-finding, because 1150 00:43:28,380 --> 00:43:33,340 as this court has already emphasized in Clark, that it is a very fact-intensive question. 1151 00:43:33,340 --> 00:43:39,420 And in your view, the circuit court then has the ability to grant a clearatory judgment 1152 00:43:39,420 --> 00:43:43,820 as to whether or not these maps actually meet the tests that we set forth. 1153 00:43:43,820 --> 00:43:44,820 Absolutely, Your Honor. 1154 00:43:44,820 --> 00:43:48,500 And of course, this court can make very clear what the authority is of the circuit court. 1155 00:43:48,500 --> 00:43:51,940 But the whole design of this three-judge panel was essentially to be able to do this 1156 00:43:51,940 --> 00:43:56,180 kind of work to sit and adjudicate facts that are about redistricting maps and make 1157 00:43:56,180 --> 00:43:58,860 the proper judgments for Wisconsin voters going forward. 1158 00:43:58,860 --> 00:43:59,860 Okay. 1159 00:43:59,860 --> 00:44:00,860 And then what? 1160 00:44:00,860 --> 00:44:06,820 Let's say the circuit court says these maps are an extreme partisan gerrymander according 1161 00:44:06,820 --> 00:44:09,100 to the tests set forth, then what? 1162 00:44:09,100 --> 00:44:12,980 Then I think there's a remedial process and that's not dissimilar to the remedial process 1163 00:44:12,980 --> 00:44:14,740 that this court has already laid out. 1164 00:44:14,740 --> 00:44:17,900 So you foresee us doing that remedial process? 1165 00:44:17,900 --> 00:44:21,140 I think the district, I think the panel could do that remedial process as well. 1166 00:44:21,140 --> 00:44:24,420 I think there's a little bit of a question depending on how the appeals work. 1167 00:44:24,420 --> 00:44:27,980 There might be an appeal of the liability order before it gets to a remedy. 1168 00:44:27,980 --> 00:44:32,900 But ideally, we would say that any of this should have, all of this is judicial, just 1169 00:44:32,900 --> 00:44:36,820 dishable within the panel and can all be reviewed by this court on appeal after that. 1170 00:44:36,820 --> 00:44:42,780 Even though that's our order, aren't we the ones that would need to overturn our injunction 1171 00:44:42,780 --> 00:44:47,100 and or order that discussed the previous maps? 1172 00:44:47,100 --> 00:44:50,980 I think I don't think that's exclusively the case, Your Honor, certainly on instruction 1173 00:44:50,980 --> 00:44:52,180 from this court. 1174 00:44:52,180 --> 00:44:56,140 The panel could have the authority to revisit that injunction. 1175 00:44:56,140 --> 00:45:00,700 And ultimately, our argument on both separation of powers and partisan gerrymandering is that 1176 00:45:00,700 --> 00:45:06,940 the panel had the sitting today, the panel had the job to look at this court's most recent 1177 00:45:06,940 --> 00:45:07,940 precedent. 1178 00:45:07,940 --> 00:45:10,900 In our first separation powers argument, that most recent precedent is Clark. 1179 00:45:10,900 --> 00:45:12,300 They had to apply Clark. 1180 00:45:12,300 --> 00:45:15,980 If this court were to decide that partisan gerrymandering is dishable, that would be 1181 00:45:15,980 --> 00:45:17,580 this most recent precedent. 1182 00:45:17,580 --> 00:45:21,300 So whether it's applying it to a map that was adopted by the legislature or adopted by 1183 00:45:21,300 --> 00:45:26,060 the court, the lower court's job is to apply this court's binding precedent. 1184 00:45:26,060 --> 00:45:31,100 And before we would adopt any map, the legislature would get a chance to also draw a map. 1185 00:45:31,100 --> 00:45:35,180 It is their purview unless they cannot do it or unless there's an unconstitutional violation 1186 00:45:35,180 --> 00:45:36,860 with their map, correct? 1187 00:45:36,860 --> 00:45:37,860 Absolutely, Your Honor. 1188 00:45:37,860 --> 00:45:38,860 And I want to make very clear. 1189 00:45:38,860 --> 00:45:39,860 There's nothing. 1190 00:45:39,860 --> 00:45:46,140 There has been nothing preventing the legislative process from enacting a map since 2020, since 1191 00:45:46,140 --> 00:45:47,140 2021. 1192 00:45:47,140 --> 00:45:51,620 The legislature can and should adopt a map if it feels like it, that that's something 1193 00:45:51,620 --> 00:45:53,980 it has the political capability to do. 1194 00:45:53,980 --> 00:45:56,300 And nothing of this court is tying this hands. 1195 00:45:56,300 --> 00:46:01,420 In Johnson, the court specifically said that this map shall remain in place until the legislature 1196 00:46:01,420 --> 00:46:05,380 adopts a new map or a court holds otherwise. 1197 00:46:05,380 --> 00:46:08,820 Until number one happens, we are asking this court to hold otherwise. 1198 00:46:08,900 --> 00:46:13,980 Just a quick question to kind of add the facts to your arguments. 1199 00:46:13,980 --> 00:46:20,180 The map that is in place is a map that Governor Ebers proposed, right? 1200 00:46:20,180 --> 00:46:24,900 The map that is in place is a map that was, the Governor Evers proposed pursuant to the 1201 00:46:24,900 --> 00:46:27,380 least changed mandate that was in Johnson 1. 1202 00:46:27,380 --> 00:46:33,220 So all of the participants in the Johnson litigation were limited to a single map and 1203 00:46:33,220 --> 00:46:36,860 it was, they were told in advance that it would be judged based on that single criterion. 1204 00:46:36,860 --> 00:46:44,300 So what about Governor Evers' map is an extreme partisan gerrymander? 1205 00:46:44,300 --> 00:46:50,060 So your Honor, Governor Evers' map is essentially following the dictates of this court. 1206 00:46:50,060 --> 00:46:56,660 It is the least changed map that is 95% identical to the 2011 map that this court cemented in 1207 00:46:56,660 --> 00:46:59,060 place pursuant to that least changed mandate. 1208 00:46:59,060 --> 00:47:04,580 So by calling it Governor Evers' map, your partisan gerrymander? 1209 00:47:04,580 --> 00:47:09,780 Our position is that the 2011 map was a gerrymander and it was calcified in place pursuant 1210 00:47:09,780 --> 00:47:11,780 to this court's least changed mandate. 1211 00:47:11,780 --> 00:47:13,820 Then that's a different question. 1212 00:47:13,820 --> 00:47:17,940 That 2011 is almost 15 years ago, right? 1213 00:47:17,940 --> 00:47:19,460 So why now? 1214 00:47:19,460 --> 00:47:22,260 Why isn't this barred by latches? 1215 00:47:22,260 --> 00:47:26,660 Your Honor, for the partisan gerrymandering claim is not barred by latches because it's 1216 00:47:26,660 --> 00:47:28,940 seeking only prospective relief. 1217 00:47:28,940 --> 00:47:36,100 The idea that the state of Wisconsin is prohibited from righting or wrong just because that 1218 00:47:36,100 --> 00:47:40,900 wrong has existed for a number of years is antithetical to the entire latches doctrine. 1219 00:47:40,900 --> 00:47:44,260 By that same logic, you know, Brown v. Board of Ed would have been latched out because 1220 00:47:44,260 --> 00:47:47,260 it was already sitting in decades' worth of segregation. 1221 00:47:47,260 --> 00:47:48,260 The different issue. 1222 00:47:48,260 --> 00:47:56,100 But has Wisconsin ever had a map that meets the criteria that you outlined today? 1223 00:47:56,100 --> 00:48:01,340 Even that partisan bodies have drawn the maps under the Constitution. 1224 00:48:01,340 --> 00:48:05,580 Since the Constitution, that provision's been in existence. 1225 00:48:05,580 --> 00:48:08,060 Has Wisconsin ever had a partisan gerrymandered map? 1226 00:48:08,060 --> 00:48:11,620 Have we ever had a map that's good under your criteria? 1227 00:48:11,620 --> 00:48:15,420 Your Honor, I've not evaluated every map, congressional map that's been adopted. 1228 00:48:15,420 --> 00:48:20,300 I know many maps have been adopted by courts not pursuant to at least change criteria. 1229 00:48:20,300 --> 00:48:21,300 As we saw, I'm Jensen. 1230 00:48:21,300 --> 00:48:25,180 We've seen in Prosser that the reports have said we actually do need to look at the partisan 1231 00:48:25,180 --> 00:48:29,420 effects of our map to make sure that we are applying traditional districting principles. 1232 00:48:29,420 --> 00:48:32,780 So I have no reason to believe that any of those maps would be unlawful. 1233 00:48:32,780 --> 00:48:36,900 We are only talking about the one map we have in place today, which was built pursuant 1234 00:48:36,900 --> 00:48:40,260 to a least change principle that has since been debunked. 1235 00:48:40,260 --> 00:48:48,060 Council, whose intent are we looking at if we were to apply a test that had an intent 1236 00:48:48,060 --> 00:48:49,660 element to it? 1237 00:48:49,660 --> 00:48:50,660 Yeah. 1238 00:48:50,660 --> 00:48:54,300 It's a little tricky in this one, Your Honors, as normally you look at the map drawers intent. 1239 00:48:54,300 --> 00:48:58,380 And here, when it comes to the most recent intent, that intent from this court was laid 1240 00:48:58,380 --> 00:48:59,380 bare. 1241 00:48:59,380 --> 00:49:06,180 The intent was to adopt the intent, the effects, and everything as possible from the 2011 map. 1242 00:49:06,180 --> 00:49:11,660 So the court can look at the judicial record to know that the intent was to adopt the intent 1243 00:49:11,660 --> 00:49:16,020 of 2011, and we even have a judicial record on the 2011 maps as well. 1244 00:49:16,020 --> 00:49:19,580 So in the baldest case, for instance, there is evidence and there is argument about what 1245 00:49:19,580 --> 00:49:21,260 exactly was that intent. 1246 00:49:21,260 --> 00:49:22,620 You want to tell us that? 1247 00:49:22,780 --> 00:49:23,780 Go ahead, Jessica. 1248 00:49:23,780 --> 00:49:24,780 Thank you. 1249 00:49:24,780 --> 00:49:29,540 I'd like to return to the question of remedy because it sounded to me like you were saying 1250 00:49:29,540 --> 00:49:37,540 a few minutes ago that we could somehow deputize that three-judge panel to overturn an order 1251 00:49:37,540 --> 00:49:40,260 by this court. 1252 00:49:40,260 --> 00:49:49,540 And that seems premature to me at a minimum until there is a factual record showing a 1253 00:49:49,580 --> 00:49:51,260 partisan gerrymandering. 1254 00:49:51,260 --> 00:49:59,020 It seems to me premature for this court to do anything of that nature and also quite unprecedented. 1255 00:49:59,020 --> 00:50:02,780 The respondents make some of those arguments in their briefs. 1256 00:50:02,780 --> 00:50:09,780 So can you walk me through how it is you believe the circuit court versus this court could 1257 00:50:09,780 --> 00:50:13,460 adopt a remedy of a different map than is currently in place? 1258 00:50:13,460 --> 00:50:19,260 So I believe that the circuit court has the obligation to abide by this court's precedent. 1259 00:50:19,260 --> 00:50:20,260 So when it comes to our separation- 1260 00:50:20,260 --> 00:50:23,340 Not just precedent, but it is a judgment. 1261 00:50:23,340 --> 00:50:24,340 And this court- 1262 00:50:24,340 --> 00:50:25,340 It is. 1263 00:50:25,340 --> 00:50:30,420 And in Johnson too, this court said that the map would stay in place until legislative 1264 00:50:30,420 --> 00:50:33,180 enactment or a court says otherwise. 1265 00:50:33,180 --> 00:50:36,860 Wisconsin has since adopted an entire judicial process through this three-judge panel that 1266 00:50:36,860 --> 00:50:42,140 is essentially intended to adjudicate these kinds of redistricting challenges. 1267 00:50:42,140 --> 00:50:48,580 If for instance we were here in 2032 and there was a three-judge panel case that was designed 1268 00:50:48,580 --> 00:50:54,540 by Wisconsin law to handle redistricting matters, I don't think we would say, well 1269 00:50:54,540 --> 00:51:03,060 that three-judge court has no power to enjoin the now old 2022 map in light of new law. 1270 00:51:03,060 --> 00:51:08,980 Of course, whatever the court's authority is, it is to apply the governing law from 1271 00:51:08,980 --> 00:51:11,820 this court to the judgment before it. 1272 00:51:11,820 --> 00:51:17,420 So I do think that the lower court always has the, not just the authority, but the obligation 1273 00:51:17,420 --> 00:51:20,740 to follow this court's precedent, which makes this an easy answer when it comes to 1274 00:51:20,740 --> 00:51:26,020 the separation of powers claim, in the partisan gerrymandering context, if this court's precedent 1275 00:51:26,020 --> 00:51:31,900 who tells the district, tells the circuit court that partisan gerrymandering is unlawful 1276 00:51:31,900 --> 00:51:37,540 and it needs to be adjudicated to make sure, to determine whether or not this challenged 1277 00:51:37,540 --> 00:51:41,580 map fails under that standard, then I think the court just needs to follow, the lower 1278 00:51:41,580 --> 00:51:44,260 court would just need to follow this court's precedent in order to do that. 1279 00:51:44,260 --> 00:51:45,260 I don't think it would be acting beyond- 1280 00:51:45,980 --> 00:51:52,220 So in other words, that language in, I think it's in Johnson 2, that says until a court 1281 00:51:52,220 --> 00:52:01,300 says otherwise, something to that effect, you believe you interpret that language as allowing 1282 00:52:01,300 --> 00:52:08,220 a lower court, a three-judge panel in the circuit court, to, based on a finding of a 1283 00:52:08,300 --> 00:52:14,340 constitutional violation, set those maps aside and adopt new maps. 1284 00:52:14,340 --> 00:52:20,860 By some process that we'll probably ask you further about, but, so that's where you find 1285 00:52:20,860 --> 00:52:28,660 that authority is in that language in Johnson 2, saying that until a court otherwise decides. 1286 00:52:28,660 --> 00:52:31,580 I think that language in Johnson 2 recognizes the authority. 1287 00:52:31,580 --> 00:52:34,300 I don't think that's the solely the source of the authority. 1288 00:52:34,300 --> 00:52:37,740 The source of the authority is from a long line of precedent starting with Cook v Cook, 1289 00:52:37,740 --> 00:52:43,420 which basically says that the lower court has an obligation to apply the most recent 1290 00:52:43,420 --> 00:52:45,180 binding precedent of this court. 1291 00:52:45,180 --> 00:52:49,900 If the most recent binding precedent of this court is that our own injunctions can be 1292 00:52:49,900 --> 00:52:54,180 reviewed according to a partisan gerrymandering standard, then the lower court has an obligation 1293 00:52:54,180 --> 00:52:56,300 to abide by that rule and adjudicate under that rule. 1294 00:52:56,300 --> 00:52:58,940 So that's something you're asking us to hold. 1295 00:52:58,940 --> 00:53:02,380 In the alternative to our initial claim, your honor, which is that we are asking you to 1296 00:53:02,380 --> 00:53:06,940 hold that this map already violates Wisconsin law as articulated in Clark, so that the 1297 00:53:06,940 --> 00:53:10,580 lower court does not need to go back and make any liability determinations. 1298 00:53:10,580 --> 00:53:13,220 This court has the ability to enjoin it on its own. 1299 00:53:13,220 --> 00:53:18,300 No, but I think Justice Crawford is asking you a very specific question about the holding 1300 00:53:18,300 --> 00:53:21,420 and you just use language about the injunction. 1301 00:53:21,420 --> 00:53:26,220 Are you asking that to be part of our holding to be that specific? 1302 00:53:26,220 --> 00:53:30,380 Are you just set aside the separation of powers argument? 1303 00:53:30,380 --> 00:53:34,580 If you're talking about an extreme partisan gerrymandering, that's your argument and 1304 00:53:34,620 --> 00:53:39,660 that violates the Wisconsin Constitution, and if we agree with you and if that is our 1305 00:53:39,660 --> 00:53:46,100 holding, is that enough or do we need to say more about the injunction that is in place 1306 00:53:46,100 --> 00:53:47,940 in this case? 1307 00:53:47,940 --> 00:53:53,540 Because the or a court otherwise directs, are you saying that's us directing it here 1308 00:53:53,540 --> 00:53:58,380 or which court is otherwise directing or is it the three judge panel? 1309 00:53:58,380 --> 00:54:01,740 I think it could be either your honor and specifically if this court were to determine 1310 00:54:02,740 --> 00:54:07,620 that part is in extreme partisan gerrymandering is cognizable under Wisconsin law, it could 1311 00:54:07,620 --> 00:54:13,620 then it remand to the lower court with instructions to evaluate this map, this injunction from 1312 00:54:13,620 --> 00:54:16,380 this court, under those principles. 1313 00:54:16,380 --> 00:54:19,500 And with that instruction, the court would have no other choice but to do that. 1314 00:54:19,500 --> 00:54:24,700 Okay, so what is a little narrow as it relates to this case, I understand what you're saying. 1315 00:54:24,700 --> 00:54:31,700 But what about Governor Evers map is, what about Governor Evers map is an extreme? 1316 00:54:31,740 --> 00:54:32,740 Partisan gerrymandering. 1317 00:54:32,740 --> 00:54:36,620 I want to be careful your honor about calling it Governor Evers map. 1318 00:54:36,620 --> 00:54:41,580 Governor Evers and actually advocated for a people's commission process that produced 1319 00:54:41,580 --> 00:54:42,580 a different map. 1320 00:54:42,580 --> 00:54:47,260 The court accepted the map that he submitted, so you can call it what you would like, today 1321 00:54:47,260 --> 00:54:50,460 I'm calling it Governor Evers map that the court adopted. 1322 00:54:50,460 --> 00:54:52,380 So let's start with that. 1323 00:54:52,380 --> 00:54:57,900 What about that map requires this court to act because it is an extreme partisan gerry 1324 00:54:57,900 --> 00:54:58,900 matter? 1325 00:54:58,900 --> 00:55:05,660 This map calcifies 95% in place the 2011 map that we believe is an extreme partisan gerry 1326 00:55:05,660 --> 00:55:06,660 mander. 1327 00:55:06,660 --> 00:55:10,580 Of course, on the posture that we have before this motion to dismiss, we don't have the 1328 00:55:10,580 --> 00:55:16,580 fact finding to be able to say this is the exact demonstrable evidence of that. 1329 00:55:16,580 --> 00:55:22,460 But in our complaint, we allege that that map that is from 2011 and then we cemented in 1330 00:55:22,460 --> 00:55:28,460 place from this court in Johnson to order is one of the most partisan skewed map in the 1331 00:55:28,460 --> 00:55:31,140 country under a variety of objective metrics. 1332 00:55:31,140 --> 00:55:37,820 So Council, it seems to me that your separation of powers argument is putting the cart before 1333 00:55:37,820 --> 00:55:40,700 the horse a bit. 1334 00:55:40,700 --> 00:55:46,540 It seems to be premised on an assumption that the maps that were adopted by this court were 1335 00:55:46,540 --> 00:55:49,500 in fact an extreme partisan gerry mander. 1336 00:55:49,500 --> 00:55:55,100 Doesn't that have to be proven first before that hurdle presents itself? 1337 00:55:55,100 --> 00:55:56,100 Not at all your honor. 1338 00:55:56,100 --> 00:55:57,820 And so tell, walk me through that. 1339 00:55:57,900 --> 00:56:03,380 So the separation of powers claim does not at all rest on whether or not the previous 1340 00:56:03,380 --> 00:56:09,580 map was right or wrong or an extreme partisan gerry mander or anything else. 1341 00:56:09,580 --> 00:56:16,180 The separation of powers claim, which I think is outlined, I think in 70 and 71 of the court 1342 00:56:16,180 --> 00:56:21,740 explains when the judiciary is charged with redistricting. 1343 00:56:21,740 --> 00:56:25,180 It needs to engage in a certain process. 1344 00:56:25,180 --> 00:56:31,320 And that process cannot include blind deference to a previous map. 1345 00:56:31,320 --> 00:56:37,580 It has to include consideration of the partisan effects of its map because the court is taking 1346 00:56:37,580 --> 00:56:40,380 ownership of its role in redistricting. 1347 00:56:40,380 --> 00:56:46,340 So this idea that the court can just kind of close its eyes and hold its nose and do 1348 00:56:46,340 --> 00:56:47,940 whatever the legislature did previously. 1349 00:56:47,940 --> 00:56:52,220 Let me just interrupt a moment because it seems to me that what the court was considering 1350 00:56:52,220 --> 00:57:01,460 there was a more prophylactic concern of avoiding a constitutional violation and not saying 1351 00:57:01,460 --> 00:57:04,700 there was a constitutional violation. 1352 00:57:04,700 --> 00:57:07,060 Am I incorrect in viewing it that way? 1353 00:57:07,060 --> 00:57:11,860 I mean, I think that the concern that this court expressed in Clark about least change 1354 00:57:11,860 --> 00:57:15,300 sounded in principles of separation of powers. 1355 00:57:15,380 --> 00:57:23,260 Like I said, specifically the court said, it is not possible to remain neutral and independent 1356 00:57:23,260 --> 00:57:26,420 by failing to consider partisan impact entirely. 1357 00:57:26,420 --> 00:57:32,060 And by definition, that means that it was not possible for this court to remain neutral 1358 00:57:32,060 --> 00:57:37,460 independent as it was its responsibility, whether the separation of powers, when it used that 1359 00:57:37,460 --> 00:57:38,940 approach in Johnson. 1360 00:57:38,940 --> 00:57:43,980 So I think it's prophylactic in the sense that, yes, it's what should be done. 1361 00:57:43,980 --> 00:57:49,400 And it maps on to what is our claim for prospective relief going forward. 1362 00:57:49,400 --> 00:57:54,420 If it is not possible for the court to abide by its twin obligations of neutrality and 1363 00:57:54,420 --> 00:57:59,460 independence by adopting a least change that doesn't look at partisan impact, that means 1364 00:57:59,460 --> 00:58:00,740 it was not possible. 1365 00:58:00,740 --> 00:58:05,580 And we are all living under that map going forward for 2026 and 2028 and 2030. 1366 00:58:05,580 --> 00:58:13,740 I'm going to follow up on a couple of questions that Justice Dalit asked you. 1367 00:58:13,740 --> 00:58:22,740 If you walked you through and you laid out three steps essentially, I guess maybe, yeah, 1368 00:58:22,740 --> 00:58:29,220 starting with if we found the map, if we ruled that an unconstitutional extreme gerrymanders 1369 00:58:29,220 --> 00:58:35,540 just dishable, we would adopt a map for what that means, excuse me, we would adopt a test, 1370 00:58:35,540 --> 00:58:37,460 a model of maps on the brain. 1371 00:58:37,460 --> 00:58:44,980 We would adopt a model for what that meant exactly, we would remand it for fact finding. 1372 00:58:44,980 --> 00:58:48,020 And then the fact finders would do what they would do and then we talked a little bit about 1373 00:58:48,020 --> 00:58:54,820 remedy, which could be the fourth thing. 1374 00:58:54,820 --> 00:58:58,500 We have two cases in front of us. 1375 00:58:58,500 --> 00:59:09,500 Your friends are very patiently sitting in the front row behind you. 1376 00:59:09,500 --> 00:59:11,140 What should we do about that? 1377 00:59:11,140 --> 00:59:22,780 What if we also find that there is an anti-competitive claim that that also violates the Wisconsin 1378 00:59:22,780 --> 00:59:23,780 Constitution? 1379 00:59:23,780 --> 00:59:29,780 We have three, we have two, three judge panels. 1380 00:59:29,780 --> 00:59:39,340 I assume that they are also going to come up here and say if you find that this is dishable, 1381 00:59:39,340 --> 00:59:43,660 you adopt a model, I don't want to take any of your argument away, you'll come up and 1382 00:59:43,660 --> 00:59:46,940 then do this, you'll remand it back for fact finding. 1383 00:59:46,940 --> 00:59:54,580 Are we going to have two different panels, six different judges having these hearings 1384 00:59:54,580 --> 00:59:58,340 coming up with who knows how many different maps? 1385 00:59:58,340 --> 00:59:59,980 Can you help me think through?