CASE NO. A12-0920 STATE OF MINNESOTA. IN SUPREME COURT LEAGUE OF WOMEN VOTERS MINNESOTA, ef al., Petitioners, vs. MARK RITCHIE, In his capacity as Secretary of State of the State of Minnesota, Respondent, ADDENDUM TO AMICUS CURIAE BRIEF OF AARP SUPPORTING PETITIONERSDavid P. Gerseh* Witold J. Walezak Amold & Porter LLP Attomey ID No, 62976 555 Twelfth Street, NW ACLU of Pennsylvania Washington, DC 20004-1206 313 Atwood Street * Not admitted in Pennsylvania, Pittsburgh, PA 15213 admitted in the District of Columbia. Pro hae vice motion to be filed. Jennifer R. Clarke Marian K. Schneider ‘Attomey ID No, 49836 ‘Attomey ID No. 50337 Public Interest Law Center of Philadelphia Advancement Project 1709 Benjamin Franklin Parkway, 2nd Floor ‘1220 L Street, NW, Suite 850 Philadelphia, PA 19103, Washington, DC 20005 Counsel for Petitioners; Additional Counsel Appear on Signature Page IN THE COMMONWEALTH COURT OF PENNSYLVANIA Viviete Applewhite; Wilola Shinholster Lee; Grover Freeland; Gloria Cutting; Nadine Marsh; Dorothy Barksdale; Bea Bookler; Joyce Block; Henrietta Kay Dickerson; Devra Mirel (“Asher”) Schor: the League of ‘Women Voters of Pennsylvania; National Association for the Advancement of Colored People, Pennsylvania State Conference; Homeless Advocacy Project, Petitioners, Docket No. ‘The Commonwealth of Pennsylvania; Thomas W. Corbett, im his capacity as Govemor; Carol Aichele, in her capacity as Secretary of the Commonwealth, Respondents. PETITION FOR R} ADDRESSED TO THE COURT'S ORIGINAL JURISDICTION 1. SUMMARY OF THE LAWSUIT 1. This lawsuit seeks to protect the fundamental right to vote guaranteed by the Pennsylvania Constitution, Under Act 18 (“the Photo ID Law”), signed into law on March 14, 2012 by Respondent Governor Thomas Corbet, large numbers of registered voters in. EXHIBIT 1Pennsylvania will not have their votes counted on November 6, 2012 because they will be unable to present acceptable photo identification (“ID") as required by the Photo ID Law. The Commonwealth estimates that 80,000-90,000 Pennsylvanians will need to obtain a new photo ID to vote on Novernber 6, 2012. Other estimates suggest the number may be far greater. Many otherwise qualified voters will face great difficulty or be unable to obtain the necessary ID and will therefore be disenfranchised in the upcoming general election and future elections. As a result, far from protecting the integrity of Pennsylvania elections, the Photo ID Law lead to elections that are no longer free and equal. Jn contrast to the phantom claims of in-person voter fraud raised by the Commonwealth to justify the Photo 1D Law — proponents of the law have failed to produce evidence of single instance of in-person voter fraud in Pennsylvania — Petitioners include real- life examples of long-time voters who will be disenfranchised by the Photo ID Law: people like Viviette Applewhite, who marched for civil rights with Dr. Martin Luther King, Jr, and who has tried unsuccessfully for many years to obtain a photo ID; people like Wilola Shinkolster Lee, Gloria Cuttino and Dorothy Barkdale, African-American women born in the Jim Crow South who do not have acceptable photo ID and who have been advised by their respective birth states that there is no record of their birth; people like Grover Freeland, who was drafted and served in the Army but who has had his request for a birth certificate denied by the state of New York and ‘whose Veteran ID card is not acceptable for voting under the Photo ID Law; and people like ‘Nadine Marsh, who has never driven a car and has been told by the Commonwealth of Pennsylvania that it does not have a record of her birth that she needs in order to obtain a Photo to vote,