‘VERIFIED COMPLAINT OF VOCES DE LA FRONTERA AND CHRISTINE NEUMANN ORTIZ ALLEGING VIOLATIONS OF ARTICLE IV, § 10 OF THE WISCONSIN CONSTITUTION AND THE OP! MEETINGS STATUTE, §§ 19.96 AND 19.97, WIS.STATS. ATTACHMENTS A. Declaration of Eric M. McLeod B. Adam Foltz Talking Points Memo C. 17 Secrecy Agreements of individual Senators D. 58 Secrecy Agreements of individual Representatives E, 58 Memorandums from Adam Folz to each individual Representative who signed secrecy agreementsUNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN ALVIN BALDUS, et al., Plaintifis, v. Civil Action No. 11-CV-562 MEMBERS OF THE WISCONSIN GOVERNMENT ACCOUNTABILITY BOARD, et al., Defendants. DECLARATION OF ERIC M. McLEOD I, Eric M. McLeod, hereby state and declare as follows, under penalty of perjury pursuant to 28 U.S.C. §1746. 1. 1am an attorney and a partner with the Law Firm of Michael Best & Friedrich, the attomeys for the Wisconsin State Senate, by its Majority Leader Scott L. Fitzgerald and the Wisconsin State Assembly by its Speaker Jeff Fitzgerald. I make this affidavit based on my personal knowledge and in support of non-parties Wisconsin State Senate and Wisconsin State Assembly’s Motion to Quash the Subpoena Issued to Joe Handrick. Attached hereto as Exhibit 1 is a true and correct copy of the subpoena issued by plaintiffs to Joe Handrick. 3, The Wisconsin State Senate, by its Majority Leader Scott Fitzgerald and the Wisconsin State Assembly, by its Speaker Jeff Fitzgerald, through this law firm retained Mr. Handrick as a consulting expert in the Wisconsin redistricting process in anticipation of litigation, In this capacity, Mr. Handrick provided consulting services in connection with Case 2:11-cv-00562-JPS-DPW-RMD Filed 11/30/11 Page 1of2 Document 64‘Michael Best & Friedrich’s representation of and provision of legal advice to the State Senate and State Assembly. 4, I declare under penalty of perjury that the foregoing is true and correct. Dated this 30th day of November, 2011. Js/ Eric M. McLeod Eric M. MeLeod cn9er2-0001L0ss8556.1 2 Case 2:11-cv-00562-JPS-DPW-RMD Filed 11/30/11 Page 2of2 Document 64General Talking Points + General Map Goals ‘© Highest priority is achieving equal population © Must properly draw minority districts ‘| "Minorities must be given the opportunity to elect the candidate of their choosing © Compact and contiguous + Timeline and process © 3 separate bills will be introduced * Congressional Map, Legislative Map, Process/Venue Change (0 Senate Plans to introduce the bill late next week. © Floor action by the middle of the month ‘© Assembly will wait and see for the legislative map This isa placeholder map. If the Senate comes back in the majority, we may come back and adjust. Public comments on this map may be different than what you hear in this room. Ignore the public comments. © Confidentiality © Previously signed agreement applies to this meeting (© Public comment will lead to depositions and being called to the witness standPRIVILEGED ATTORNEY-CLIENT COMMUNICATION Confidentiality and Nondisclosure Related to Reapportionment Michael Best & Friedrich LLP ("MB&F") is currently engaged to represent the Wisconsin State Senate, by its Majority Leader Scott L. Fitzgerald (‘Senate’) in connection with matters relating to the reapportionment of the Wisconsin Senate, Assembly and Congressional Districts arising out of the 2010 census (the "Representation’). In connection with the Representation we have instructed certain individuals, working at our direction, to meet with certain members of the Senate for the purpose of discussing mé ‘scope of the Representation. Such discussions shall be Conducted for . ing MBEF in rendering legal advice to the Senate and, therefore, are subject to the attomey-cient and attorney work product privileges. Consistent with those privileges, such discussions are and shall remain confidential This letter will confirm our understanding that such discussions are and shall remain confidenti ocios comments aa Wve any questions regarding the foregoing, please feel free to raise those questions with me. Othenwise, in order to confirm the foregoing understanding, please sign on the line indicated below. Sincerely, MICHAEL BEST & FRIEDRICH LLP Eric M, McLeod APPROVED AND AGREED UPON: Date, 5/10 [i 2011. Sa (020472-000119030774.1PRIVILEGED ATTORNEY-CLIENT COMMUNICATION Confidentiality and Nondisclosure Related to Reapportionment Michael Best & Friedrich LLP ("MB&F) is currently engaged to represent the Wisconsin State Senate, by its Majority Leader Scott L. Fitzgerald ("Senate") in connection with matters relating to the reapportionment of the Wisconsin Senate, Assembly and Congressional Districts arising out of the 2010 census (the *Representation’). In connection with the Representation we have instructed certain individuals, working at our direction, to meet with certain members of the Senate for the purpose of discussing matters within the scope of the Representation. Such discussions shall be Conducted for the sole purpose of assisting MB&F in rendering legal advice to the Senate and, therefore, are subject to the attomey-client and attomey work product privileges. Consistent with those privileges, such discussions are and shall remain confidential. This letter will confirm our understanding that such discussions are and shall remain confidential land that you agree not to disclose the fact andlor contents of such discussions or any draft documents within your possession related to the subject of the Representation with persons outside of the privilege. if you have any questions regarding the foregoing, please feel free to raise those questions with me. Otherwise, in order to confirm the foregoing understanding, please sign on the line indicated below. Sincerely, as IEDRICH LLP Eric M. McLeod APPROVED AND AGREED UPON: eb Date: S-¥ 2011. Senator (25472-000110030774.1PRIVILEGED ATTORNEY-CLIENT COMMUNICATION Confidentiality and Nondisclosure Related to Reapportionment Michael Best & Friedrich LLP (‘MB&F" is currently engaged to represent the Wisco Senate, by its Majority Leader Scott L. Fitzgerald (‘Senate’) in connection with matters rel the reapportionment of the Wisconsin Senate, Assembly and Congressional Districts arising out of the 2010 census (the "Representation’). In connection with the Representation we have instructed certain individuals, working at our direction, to meet with certain members of the Senate for the purpose of discussing matters within the scope of the Representation. Such discussions shall be conducted for the sole purpose of assisting MBBF in rendering legal advice to the Senate and, therefore, are subject to the attomey-client and attomey work product privileges. Consistent with those privileges, such discussions are and shall remain confidential. This letter will confirm our understanding that such discussions are and shail remain confidential land that you agree not to disclose the fact andlor contents of such discussions or any draft documents within your possession related to the subject of the Representation with persons ‘outside of the privilege. If you have any questions regarding the foregoing, please feel free to raise those questions with me. Otherwise, in order to confirm the foregoing understanding, please sign on the line indicated below. Sincerely, MICHAEL BEST & FRIEDRICH LLP Date:_, , 2011. (029472-000119030774.1PRIVILEGED ATTORNEY-CLIENT COMMUNICATION Confidentiality and Nondisclosure Related to Reapportionment Michael Best & Friedrich LLP ((MB&F") is curently engaged to represent the Wisconsin State Senate, by its Majority Leader Scott L. Fitzgerald (‘Senate") in connection with matters relating to the reapportionment of the Wisconsin Senate, Assembly and Congressional Districts arising out of the 2010 census (the “Representation’). In connection with the Representation we have instructed certain individuals, working at our direction, to meet with certain members of the Senate for the Purpose of discussing matters within the scope of the Representation. Such discussions shall be Conducted for the sole purpose of assisting MB&F in rendering legal advice to the Senate and, therefore, are subject to the attomey-client and attomey work product privileges. Consistent with those privileges, such discussions are and shall remain confidential. ‘This letter will confirm our understanding that such discussions are and shall remain confidential and that you agree not to disclose the fact andior contents of such discussions or any draft documents within your possession related to the subject of the Representation with persons Outside of the privilege. if you have any questions regarding the foregoing, please feel free to raise those questions with me: Otherwise, in order to confirm the foregoing understanding, please sign on the line indicated below. Sincerely, MICHAE! TT & FRIEDRICH LLP cg Mirth Eric M. McLeod APPROVED AND AGREED UPON: . Date__ J -3-¢+ , 2011. Senator (020472-000119030774.1