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Motion

Motion

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Published by Matt Dixon
Motion
Motion

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Published by: Matt Dixon on May 30, 2013
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05/30/2013

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IN THE CIRCUIT COURT OF THE SECOND JUDICIAL CIRCUIT,IN AND FOR LEON COUNTY, FLORIDA
RENE ROMO, an individual; BENJAMINWEAVER, an individual; WILLIAMEVERETT WARINNER; an individual;JESSICA BARRETT, an individual; JUNEKEENER, an individual; RICHARDQUINN BOYLAN, an individual; and BONITA AGAN, an individual,Plaintiffs, CASE NO: 2012-CA-00412v.KEN DETZNER, in his official capacity asFlorida Secretary of State, and PAMBONDI, in her official capacity asAttorney General of the State of Florida,Defendants.THE LEAGUE OF WOMEN VOTERS OFFLORIDA, et al.Plaintiffs,v. CASE NO: 2012-CA-00490KEN DETZNER, in his official capacity asFlorida Secretary of State; THE FLORIDASENATE; MICHAEL HARIDOPOLOS, inhis official capacity as President of theFlorida Senate; THE FLORIDA HOUSEOF REPRESENTATIVES; and DEANCANNON, in his official capacity asSpeaker of the Florida House of Representatives,Defendants.
NON-PARTIES PAT BAINTER, MATT MITCHELL,MICHAEL SHEEHAN, AND DATA TARGETING, INC.’SMOTION FOR PROTECTIVE ORDER, REQUEST FORIN CAMERA REVIEW AND PRIVILEGE LOG
 
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 Non-parties Pat Bainter, Matt Mitchell, Michael Sheehan, and DataTargeting, Inc. (collectively “Non-parties”), by and through undersigned counseland pursuant to Rules 1.280 and 1.410, Fla. R. Civ. P., U.S. Const. Amend. I, and Art. I, Sec. 23, Fla. Const., move this Court for a protective order, request an incamera review, and provide a privilege log. In support thereof, Non-parties state:
BACKGROUND AND FACTS
 Non-party Pat Bainter is the owner and president of Data Targeting, Inc., a political affairs consulting firm based in Gainesville, Florida. Data Targetingoffers a comprehensive suite of consulting services to various entities whoseinterests and operations are likewise politically oriented, including but not limited to prospective candidates, elected officials, associations and interests groups, political advisors, media organizations, and various corporations and businesses.Guided by decades of research and analysis, Data Targeting assists these entitieswith general campaign strategy, candidate consulting, issue and opinion polling,electorate and public relations, research and record identification, data analysis and mapping, graphic design, direct mail production, and other contracted services.Data Targeting’s consulting operation is rooted in a proprietary foundation of database management, opposition research, and strategic analysis of politicaltrends, electoral demographics, voter performance, and other stakeholder data sets.
 
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Because it is a political consultancy, Data Targeting routinely engages in business communication to and from private and elected individuals regarding arange of issues of public importance. Data Targeting has been and continues to provide services to members of the Florida Legislature for matters whollyunrelated to redistricting or issues raised in this case. Data Targeting employs asmall team of approximately 10 staff, including Pat Bainter, Matt Mitchell, and Michael Sheehan. Data Targeting and its three employees identified above are Non-parties to the proceedings; they seek protection from the intrusive,unconstitutional, burdensome and wholly irrelevant discovery in this case.In 2012, the Florida Legislature enacted redistricting plans
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, pursuant to itsconstitutional duties under Article III, Section 16, of the Florida Constitution. Byits own reports, the Florida Legislature based its decisions regarding district lineson an “open, interactive, and inclusive redistricting process”:
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On February 10, the Attorney General petitioned the Florida Supreme Court todetermine the validity of house and senate districts enacted in Senate JointResolution 1176. The Court's March 9 opinion determined that the house plan wasvalid, but that 8 of 40 senate districts were not valid. After the Legislature revised the senate plan during an extraordinary apportionment session, the AttorneyGeneral petitioned the Supreme Court to determine the validity of the revised senate districts in Senate Joint Resolution 2-B. The Court's April 27 opiniondetermined that the revised senate plan was valid. Congressional and state houseredistricting plans were submitted to the United States Department of Justice for  preclearance on March 13, and the revised state senate plan was submitted onMarch 30. The Department of Justice's April 30 letter stated no objection to thenew maps.The Florida Senate, Legal Submissions,http://www.flsenate.gov/Session/Redistricting/Legal (last visited Feb. 28, 2013).

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