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DISTRICT OF COLUMBIA COURT OF APPEALS ANTHONY A. WILLIAMS, Petitioner v. ) No. 02-AA-854 DISTRICT OF COLUMBIA BOARD OF ELECTIONS AND ETHICS, Respondent and DOROTHY A. BRIZILL, SHAUN SNYDER, GARY IMHOFF, AND MARK SIBLEY, Intervenors INTERVENORS' OPPOSITION TO PETITIONER'S EMERGENCY PETITION FOR REVIEW(Table of Contents, Table of Authorities, and Record Cites Added) Ronald L.Drake TABLE OF CONTENTSTABLE OF AUTHORITIES
VI. CONCLUSION TABLE OF AUTHORITIESCASESAllen v. District of Columbia, CA No. 00-0591-RCL (D.D.C.
January 26, 2001) REFERENCES3 Blackstone I. THE BOARD'S FINDINGSIn its July 29, 2002, Memorandum Opinion and Order, (hereinafter ORDER), the District of Columbia Board of Elections and Ethics found widespread obstruction and pollution of the nominating process as it pertains to nominating petition sheets circulated by Scott Bishop, Sr., Scott Bishop, Jr., and Crystal Bishop. As a result, the Board determined that Mayor Anthony A. Williams did not have the requisite number of signatures for ballot access as a Democratic Party candidate for Mayor of the District of Columbia. ORDER, at 17. II. ISSUEThe issue presented to this Court by the petition by Anthony A. Williams is straightforward and precise. It may be stated as follows:
Mayor Williams has the effrontery to ask this Court to find that a false affidavit has the same efficacy as a true one in the petition process. Furthermore, he asks this Court either to overturn or ignore the factual finding of the Board of Elections that sufficient evidence had been presented to them to establish that the Bishops had a pattern and practice of submitting false petition affidavits1. As a result of these, he petitions this Court to require the Board to allow him to benefit from the false affidavits that he submitted, even when the Board is aware of them, and to place his name on the September 10, 2002, Democratic Party primary ballot as a reward for submitting petition forms validated by false affidavits. III. BACKGROUNDOn July 3, 2002, Mayor Anthony A. Williams (petitioner), submitted 512 pages of nominating petitions, containing a total of 10,102 signatures. See District of Columbia Board of Elections and Ethics (Board) July 29, 2002 Memorandum Opinion and Order (Order), at 2. Of those 512 pages, 345 pages (67%) were circulated by Scott Bishop, Sr., Scott Bishop, Jr., or Crystal Bishop. Id. On July 15, 2002, Dorothy Brizill, Gary Imhoff, Shaun Snyder, and Mark Sibley, third-party intervenors herein, filed a joint challenge to the Mayor's nominating petitions. They contended that approximately 9,250 of the Mayor's petition signatures were defective under the terms at the statute and regulations. Id. These challenges were filed under DCMR Title 3, Elections and Ethics, Section 410.3(c), which requires a challenger to state for each challenge to an individual signature, "The name(s), if legible, sheet and line number(s) of any challenged signature(s) and the basis for the challenge(s). . . ." Additionally, Snyder and Sibley submitted a challenge to all petition sheets signed as circulators by Scott Bishop, Sr., Scott Bishop, Jr., and Crystal Bishop. This general challenge to petition sheets that cannot be subsumed under or stated by signature-by-signature challenges is called for under Section 410.3(d), which calls for "A clear and concise statement of any other facts which are alleged to constitute a petition defect." Under this section, Snyder and Sibley asked the Board of Elections and Ethics "to consider rejecting all petition sheets submitted by the Bishops," and submitted a statement of such additional facts regarding the Bishops. Among other defects in the petitions, Snyder and Sibley noted the prevalence of obvious forgeries on the majority of petition pages submitted by the Bishops. They also noted that the pages signed by Scott Bishop, Jr., indicated that he had collected a total of 540 signatures in one 24-hour period.2 That is an average of one petition signature collected every 2.66 minutes, for the entire 24 hour period. It allows for no time off for meals, rest, sleep, or other personal needs. It allows for no break in the steady stream of foot traffic, as that stream paused, discussed the Mayor's qualifications, being persuaded, signing, and then giving way to the next person standing in that endless line of 540 persons. It also assumes that 540 people were persuaded consecutively to sign the petitions and that the circulator had to spend no time speaking with other voters who were not persuaded and who did not sign the petitions. Further, it did not allow any time for debate with those persons who require more than 2.66 minutes to be persuaded. It also did not take into account the amount of time necessary for persons to print their full names, addresses, the current date, and then to sign the petition.3 The Court, drawing on its own life experiences in this city, can make its own determination of the reasonableness of the Mayor's position. IV. MAYOR WILLIAMS CONCEDED ILLEGALITY BY PETITION CIRCULATORSMayor Williams announced in his response to the challenge that there is an "atmosphere surrounding this Nominating Petition." ADM RECORD (Respondent's Brief), at page 3. The atmosphere to which the Mayor referred was one of massive election fraud, such as has never before been seen in this city. The Mayor asserted to the Board before the administrative hearing commenced that "we do not defend forgeries." He then announced that he would not defend 2154 (approximately 4,240 purported signatures) of the 512 pages of petitions that had been submitted at his behest on his behalf by his own campaign for a place of honor on the Democratic Party ballot for mayor. TR., at July 22, pages 4-5. The Mayor also conceded that there was a question of "whether there were improprieties in the collection of signatures beyond those needed for his nomination." ADM RECORD, at page 4. The Mayor did not elucidate how such non-defense and concession somehow was expiation enough for the atmosphere surrounding his own nominating petition. Mayor Williams has called on the Board to investigate the Mayor's own campaign, his own campaign workers, his petition circulators, and the officials of his election campaign, and to mete out to wrongdoers such punishment as they are due. ADM RECORD, at pages 2, 4. Mayor Williams' campaign co-chair, Gwendolyn Hemphill, stated that mistakes were made. TR., at July 26, 162. The question this Court must now decide is whether Mayor Williams may reap the benefit of that wrongdoing, while leaving the wrongdoers to their own fates. V. ARGUMENTA. Standard of ReviewThe petitioner cites In re Haworth, 258 A.2d 447, 448-449, (D.C. 1969), as supporting his position as to the standard of review. The petitioner errs. Haworth is inapposite to the petitioner's argument. That case makes clear that the Court is not to undertake an independent evaluation of the evidence, if the Board's findings are supported by substantial evidence. Haworth also recognizes that when the Board defines and applies its own regulations, then the Court must apply the reasonableness standard.5 The Court cannot substitute a different judgment for reasonable Board action. Id. The intervenors request the Court to adhere to those foregoing standards in its review of the Board's decision. In so doing, it will find that there is substantial evidence to support the Board's decision. It will also find that, given the Board's finding of widespread obstruction and pollution of the nominating process as it pertains to nominating petition sheets circulated by the Bishops on behalf of the petitioner, the Board's action was supported by substantial evidence, and its application of its own regulations was reasonable. B. The Board's Decision Was Within the Board's Lawful AuthorityThe petitioner implies, but does not state, that the Board may not review the validity of the signatures on a nominating petition, even in the face of pervasive fraud. The petitioner errs. The very purpose of the statute and regulations is to regulate the petition process so as to deter fraud and diminish corruption, such as even the petitioner admits occurred here. Buckley v. American Constitutional Law Foundation, Inc., 525 U.S. 182, 204-205, 119 S.Ct. 636 (l999). The District has a legitimate interest in preventing election fraud. Orange v, Board of Elections and Ethics, 629 A.2d 575, 579. An administrative agency, such as the Board, has wide discretion when implementing legislation pursuant to statute. Mitchell v. District of Columbia, 741 A.2d l049, 1055 (D.C.App. 1999). The Mayor elevates form over substance in his argument that a completed affidavit, although false, must be accepted as presumptively valid. In fact, Citizens Against Legalized Gambling v. District of Columbia Board of Elections and Ethics, 501 F.Supp 786, 790-791, cited by the Mayor, but inapposite to his argument, addresses that very issue, as follows: To deny the persons who signed these petitions the chance to have those signatures count — solely because of misconduct of others that does not cast doubt on the signatures themselves [emphasis added] — would force this court to stand on form rather than substance. And therein lies the answer. It is the very misconduct of the Bishops on behalf of the petitioner that does cast doubt on the signatures themselves. The Mayor abandoned 215 pages of petitions, the majority of them signed by the Bishops as circulators. That very abandonment, done as a result of the misconduct of the Bishops, does cast doubt on the signatures themselves. One of the petitioner's own campaign workers, Mr. Franklin Wilds, testified that his signature was forged as the circulator on seventeen petitions submitted by the Mayor. TR., at July 24, 483-496. Another of the petitioner's own circulators, Ms. Ann Lewis, testified that her signature was forged as the circulator on fourteen petitions submitted by the Mayor. She further testified that at the behest of a Williams campaign worker she had signed another nominating petition as circulator, even though she had not collected or witnessed the voters' signatures on that sheet. TR., at July 26, 29, 43-47. To compound the damage, the petitioner then constructed a perjury trap for Ms. Lewis. At the Board hearing on Wednesday, July 24, after hearing the Board chairman discuss the purpose and intent of the circulator's affidavit, Ms. Lewis came forward and asked to be allowed to testify because she then believed that she may have done something wrong. TR., at July 24, 252-253. The petitioner then had a declaration prepared, presented to, and signed by Ms. Lewis, in which she declared that she had circulated and witnessed all the petition sheets that bore her true signature. When she testified to the Board on Friday, July 26, Ms. Lewis informed the board of the one petition sheet that she had not witnessed, but had signed as circulator at the behest of the Williams campaign. In her examination on behalf of the petitioner, she was presented with the declaration that the petitioner had prepared for her signature; she was walked directly into the perjury trap; and the petitioner slammed it shut. TR., at July 26, 51-68. On cross-examination by the intervenors, Ms. Lewis testified that she did had not have counsel when presented by the Williams campaign with that declaration, and that she did not understand the contents of that declaration. TR., at July 26, 71. Now Ms. Lewis faces a possible referral to the US attorney for prosecution, as a direct result of the perjury trap set for her by or on the petitioner's behalf. A critical ingredient of the electorate's ability to vote effectively is choice among the candidates with demonstrated support. Lawrence v. Board of Elections and Ethics, 611 A.2d 529, 532 (D.C.App. 1992), No right is more precious in a free country than that of having a voice in the election of those who make the laws under which, as good citizens, we must live. Other rights, even the most basic, are illusory if the right to vote is undermined. To the extent that a citizen's right to vote is debased, he is that much less a citizen. It is a fundamental political right because it is preservative of all rights. Kamins v. Board of Elections for the District of Columbia, 324 A.2d 187, 191 (D.C.App. 1974). But the intentional use of invalid signatures on a nominating petition constitutes a fraud on the entire democratic process and warrants the strongest possible condemnation. Board of Elections v, Democratic Central Committee, 300 A.2d 725, 727 (D.C.App. 1973). By injecting massive fraud into the process, petitioner has diminished that critical ingredient. He has hampered the electorate's ability to vote effectively for its choice among the candidates with demonstrated support. And therein lies further support for the Board's decision to bar the Mayor from the Democratic Party ballot because of the unreliability of the circulators' affidavits. C. The Board's Order Is Consistent with the LawThe petitioner asserts that the Board's Order completely reverses the normal evidentiary burdens and rules. The petitioner errs. The petitioner complains that the Board placed more reliance on newspaper articles than on the Bishops' circulator affidavits. The petitioner then complains that no evidence was adduced from which the Board could have determined that (1) the Bishops' assertion of the Fifth Amendment privilege supported an inference of invalidity as to the Bishops' circulator affidavits, and (2) that the Bishops affidavits were without credibility. The petitioner asks the Court to ignore the fact that the Bishops submitted 167 nominating petition sheets replete with forgeries. ORDER, at 16. The petitioner asks the Court to ignore the fact that he was unwilling to defend 215 petition pages, most of which were signed by the Bishops. The petitioner asks the Court to ignore the fact that someone in his campaign forged the names of Mr. Franklin Wilds and Ms. Ann Lewis and others as circulators on fraudulent petitions. TR., at July 24, 483-496.
The petitioner asserts that he did not introduce various newspaper articles into the record. The petitioner errs. At the July 22, 2002 pre-hearing conference, the petitioner introduced into the record three newspaper articles and a radio interview tape in an attempt to establish bias on the part of the Board's Chairman, the General Counsel for the Office of Campaign Finance, and the spokesman for the Board. ORDER, at pages 8-10. The articles complained of include statements against interest attributed to the Bishops and to Ms. Lewis. They recount forgeries and false affidavits. ORDER, at pages 9. In this instance, the petitioner is urging an erroneous evidentiary standard, hearsay, that does not apply in administrative proceedings. In like manner, during the hearing the petitioner sought to change the standard of proof from "preponderance" to "clear and convincing." TR., at pages July 24, 192, 196, 199-202. In both instances, had the Board acceded to the petitioner's interpretation of the law, it would have been plain error on its face. But the Board did not rest its decision on the newspaper articles only. Rather, the Board subpoenaed Mr. Wilds, a Williams campaign petition circulator, who told the Board that his signature was forged on seventeen petition sheets. TR., at pages July 24, 483-496. Mr. Wilds also told the Board that additional names, including the name of the petitioner's mother, were placed on a petition sheet that he had circulated and turned into the campaign by someone unknown to him, after he had signed the circulator affidavit. TR., at pages July 24, 473-474. The Board subpoenaed Ms. Wanda Alston, a Williams campaign petition circulator. She also testified that signers' names were added to a petition sheet after she had signed as the circulator and turned in the sheets to the Williams campaign. TR, at pages July 25, 17-19. The Board also subpoenaed Ms. Ann Lewis, a Williams campaign petition circulator. She testified that her signature was forged on fourteen petition sheets. She acknowledged that, at the direction of Mr. Robert Yeldell, she signed as a circulator a nominating petition she did not circulate. TR., at July 26, 29, 43-47. The petitioner did not challenge any of this testimony, other than with the unwitting declaration signed by Ms. Lewis. Surely, both this uncontroverted testimony, along with the petitioner's odious action in obtaining the declaration from an unsuspecting Ms. Lewis, all tend to show that the facts stated in the newspaper articles were true and accurate. But the declaration shows something else. It shows an apparent cover-up effort, even during the course of the Board's hearing, possibly in the very Board Hearing Room. Thwarted at every turn by petitioner's conduct, the Board turned to the evidence least likely to have been polluted by the petitioner, the interviews of the Bishops detailed in the newspaper articles. The petitioner made no effort to refute the facts stated in the newspaper articles, other than its odious action in obtaining the declaration, and objecting to the Board's use of the articles as evidence, after introducing it as evidence himself. Further, Ms. Crystal Bishop was placed beyond the Board's reach when she was hospitalized by her social worker for 72 hours during the course of the Board's three days hearing, after having attended the first day of the hearing. TR., at July 26, 226-7, 247-8. If the Board were operating under strict rules of evidence, then the hearsay exception for the unavailability of the declarant clearly would have made the newspaper articles admissible in court. See, Fed.R.Evid. 804(a)(4). Further, during the course of the hearing, the Board received a note from an attendee at the hearing that Ms. Bishop had been present on Wednesday, July 24th, and that she left after being talked with by a senior Democratic Party official. TR., at July 25, 62. Under the relaxed evidentiary standard in effect in administrative proceedings, there can be no issue as to the admissibility.
The petitioner asserts that the Board drew a legally improper and irrational inference from the invocation of the Fifth Amendment by Scott Bishop, Sr., and Scott Bishop, Jr. The petitioner errs. The petitioner acknowledges that a negative inference can be drawn against a party who asserts the Fifth Amendment. Petitioner then complains that the Board drew its inference based on the assertion of the privilege by two witnesses. When intervenors sought to invoke the missing witness rule, petitioner vociferously opposed it, and the Board rejected the request. TR., at July 26, 220-25, 245. However, the petitioner now complains about being "effectively hit with a missing witness' presumption." The missing witness rule was and remains a proper evidentiary tool here, where the testimony of persons directly associated with the petitioner was placed beyond the Board's reach. Moreover, one of those witnesses, Mr. Bishop, Sr., is an employee of the petitioner's campaign, on paid leave, and was so at the time that he asserted the privilege. TR., at July 26, 20. Further, when intervenors requested that the petitioner, as the employer of Mr. Bishop, Sr., request Mr. Bishop to testify, the petitioner failed to do so. TR., at July 26, 20, 246. Where, as here, the petitioner had it peculiarly within his power to produce witnesses whose testimony would elucidate the transaction, the fact that he did not do so creates the presumption that the testimony, if produced, would be unfavorable to him. The rule should be invoked. 2 McCormick on Evidence, Fourth Edition (1992), Sec. 264; 2 Wigmore, Evidence (3d Fd.) 7 Sec. 285; Bufco Corp. v. National Labor Relations Board, 147 F.Brd, 964 (D.C.Cir. 1998); Allen V. District of Columbia, CA No. 00-059l-RCL (D.D.C. January 26, 2001) , at 5. The petitioner also complains that the Board apparently drew a negative inference against the petitioner based on the nonappearance of the hospitalized Crystal Bishop. However, the circumstances surrounding her appearance at the first's day's hearing, and her subsequent placement beyond the Board's reach, is for the Court to ponder. When intervenors requested permission to make an offer of proof, petitioner again thwarted that effort with objections. The offer of proof that would have preserved the record for this Court as to what evidence the intervenors sought to adduce from the two Mr. Bishops was precluded by the petitioner's objections. TR., at July 26, 219-223. Now this Court is adversely impacted by the absence of that proffered evidence. The petitioner complains that the intervenors could have "called a newspaper reporter to testify about what the Bishops said or did not say." Petitioner knows that the Board requested a Washington Post reporter to take the stand to testify about what the Bishops said or did not say. TR., at July 26, 237. Petitioner also knows that the reporter not only failed and/or refused to take the stand, but that the Board was informed that the reporter would not testify, and had removed herself from the hearing room to avoid testifying. TR., at July 26, 237. The petitioner complains that the intervenors did not call an expert witness to try to establish that there were forgeries. What petitioner does not tell the Court is that the petitioner called its own handwriting expert. TR., at pages July 25, 31-132. Petitioner used unvouched for, unauthenicated exemplars, written on a blank sheet of paper, the provenance of which was not proven. TR., at pages July 25, 67-70. Petitioner also obtained copies of sensitive personal documents, including Mr. Bishop, Sr.'s Social Security card, driver's license and another unspecified identification card, from the legal counsel for Scott Bishop, Sr.6 TR., at page July 25, 53-57. Even with all of that, petitioner's expert witness indicated that in many instances in his experience, he would have to concede that he could not state with the necessary degree of certainty that a signature was a forgery. TR., at pages July 25, 95-97. Of what possible value, then, would such an expert have been to the Board, at $1600.00 per day? TR., at July 25, 120.
The petitioner asserts that the Board disenfranchised 2235 qualified, registered electors. The petitioner errs. The petitioner appears to acknowledge that a negative inference was in fact created by the Bishops' assertion of their right against self-incrimination. However, the petitioner then asserts that the will of the voters is paramount and should be preserved inviolate.7 But who thwarted the petition process? Who gathered and then refused to defend literally thousands of fraudulent signatures? How can the will of the voters remain paramount and be preserved inviolate in the face of lawlessness, fraud, and forgery? How can the will of the voters be protected when a candidate is willing to set a perjury trap for his own workers, and then spring it, as happened here? TR., at pages July 26, 51-68. How can the will of the voters remain inviolate, when they sign petitions where their signatures are commingled with frauds and forgeries? Who is it in this dispute that is holding the will of the voters paramount and inviolate? Is it the petitioner, whose campaign organization engaged in wholesale election fraud, and who still seeks to benefit from that fraud, or is it the Board of Elections and Ethics and the intervenors, who seek only to preserve the integrity of the election process?
The petitioner asserts that the Board's rejection of his nominating petition was not a proper remedy. The petitioner errs. The Court will remember that while this matter was before the Board, the petitioner acknowledged that the petitioner called on the Board to investigate his petition circulators, and to punish his own petition circulators. However, even now, petitioner insists that he is entitled to the product of that criminal activity. The most that the petitioner is willing to concede is that mistakes were made. TR., at July 26, 162. Even now before this Court, petitioner continues to urge criminal prosecution of his own people, but then seeks to claim the rewards of their crimes for himself. The process has now been so tainted and polluted with criminal conduct that there can be no assurance that any one of the petitions signed by the Bishops has any authenticity or validity. The petitioner has himself admitted the Bishops' wrongdoing. With such a completely polluted pool of petitions, can the petitioner tell this Court with any degree of assurance which, if any, of the Bishops' remaining petitions are valid, and which are false? Since the petitioner cannot do so, how can the petitioner ask this Court to overturn the factual determination of the Board of Elections and Ethics? Such action by the Court would ratify the travesty that has been perpetrated on this City by the petitioner. Not only has the petitioner abandoned his own supporters, he now asks this Court to abandon its common sense and allow him to benefit as a de facto receiver of stolen goods. That is to say, the signatures on the fraudulent petitions are like stolen property, stolen from the voters of this city. As long as the possibility remains that those fraudulent petitions may be relied on to place Mayor Williams on the Democratic Party primary ballot, the stench of this fiasco will not subside. It will only worsen. The petitioner is asking this Court to find that, while there has been a wrong committed, the Board of Elections and Ethics can take no remedy. But that is contrary to the law. Where there is a wrong, there must be a remedy. It is a settled and invariable principle, that every right, when withheld, must have a remedy, and every injury its proper redress. See, Marbury v. Madison, 1 Cranch 137, 147 (1803). The very essence of civil liberty certainly consists in the right of every individual to claim the protection of the law, whenever he receives an injury. It is a general and indisputable rule, that where there is a legal right, there is also a legal remedy by suit or action at law, whenever that right is invaded. Id., at 163, citing 3 Blackstone, pages 23, 109. Were any ordinary citizen to have benefited from the commission of crimes by his subordinates, such as the petitioner seeks to benefit, that citizen would now be facing indictment. As Justice Jackson said in his dissent in Federal Crop Insurance Corporation v. Merrill, 332 U.S. 280, 68 S.Ct. 1, 5 (1947): It is very well to say that those who deal with the Government should turn square corners. but there is no reason why the square corners should constitute a one-way street. Misconduct such as occurred here was addressed by our Supreme Court more that a century ago in another matter. The majesty of that pronouncement still rings true today, especially given the misconduct here. There the Court said: No man in this country is so high that he is above the law. No officer of the law may set that law at defiance with impunity. All the officers of the government, from the highest to the lowest, are creatures of the law and are bound to obey it. It is the only supreme power in our system of government, and every man who by accepting office participates in its functions is only the more strongly bound to submit to that supremacy, and to observe the limitations which it imposes upon the exercise of the authority which it gives. United States v. Lee, 106 U.S. 196, 220 (1882) The petitioner is not so high that he is above the law. He may not set that law at defiance with impunity. As a high officer of this government, he is a creature of the law, and he is bound to obey it. By accepting his high position, he became all the more strongly bound to submit to that supremacy. He must observe the limitations which the law imposes upon the exercise of the authority which it gives. VI. CONCLUSIONFor all the foregoing reasons the intervenors urge the Court to uphold the Order of the District of Columbia Board of Elections and Ethics, and deny Mayor Williams access to the ballot as a candidate for the Democratic Party nomination in the September 10, 2002, Mayoral Primary Election. Respectfully submitted, Ronald L. Drake 1. See Fed.R.Evid. 404 and 406. 2. Counsel for Mr. Bishop, Sr., reported to the Board that Ms. Crystal Bishop had been hospitalized by her social worker for 72 hours. TR., at June 26, pages 226-7, 247-8. Thus, she was unavailable to testify. 3. Ms. Gwendolyn Hemphill, the Williams campaign co-chair, testified that she had no responsibility for the petitions, and that her co-chair, Mr. Max Berry, was often out of the city. TR., at pages July 26, 158-160, 169-170. Mr. Charles Duncan, the senior Williams campaign consultant, testified that he was paid $10,000.00 per month for his expertise, but that he had little or no authority in the campaign, and no authority or responsibility for the nominating petition process. TR., at pages July 24, 291, 279. Both testified that Mr. Bishop, Sr., was in charge of the circulating, gathering, safeguarding, and checking and verifying the nominating petitions. TR., at pages July 24, 281-283; July 26, 177. 4. The count of 215 pages was that given by the Respondent. The count by the Board of Elections of the actual page numbers ceded was 214 pages. At the prehearing on July 22, 2002, the Respondent withdrew his concession regarding one page, reducing the final count of conceded pages to either 214 or 213 pages. 5. D.C. Code §1-1001.08(o)(2). 6. The petitioner's ability to obtain such sensitive documents from Mr. Bishop, Sr., places in further doubt the petitioner's assertion that he had no control over Mr. Bishop, Sr. This is all the more justification for applying the missing witness rule. 7. At the petitioner's July 30, 2002, 1:00 p.m. press conference, held to announce this appeal, one of the petitioner's speakers urged the crowd to "pack the Court" and to "make clear that the will of the people will prevail." |
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