TBE Exhibit 1

Case 3:13-cv-00678-REP-LO-AD Document 256-1 Filed 10/07/15 Page 1 of 9 PageID# 5789

1. Remediation of the
violation

2. Compactness

3. Contiguity

4. Equalization

5. 2012 Plan

6. Preservation of
political divisions

Comparison Chart for All Plans

Plaintiffs
Racial considerations were
prominent in the
promulgation of this plan.

TBE A
Advantage
Racial considerations were TBE Plan A
considered as one of many
factors.

TBE B
Advantage
Racial considerations were TBE Plan A
considered as one of many
factors.

Substantial efforts to avoid Substantial efforts to avoid TBE Plan A

tendrils and promontories tendrils and promontories
were made outside of the were made.
3rd District.

Substantial efforts to avoid TBE Plan B

tendrils and promontories
were made statewide.

The 3rd District is divided Contiguity by road

into three separate
achieved.
landmasses accessible only
by boat or by traveling
through other districts.

Contiguity by road
achieved.

Sufficient.
All of Hampton Roads has
been moved out of the 2nd
District, and all of Norfolk
has been moved out of the
3rd District. The 4th
District now reaches into
Richmond City.

TBE Plan A

Sufficient.
Equivalent
Strong attempts have been TBE Plan A
made to preserve the
existing plan.

This map makes substantial Preserves perfect political Plaintiffs

efforts to preserve County division at the Precinct but
and City political divisions. not County and City levels.

TBE Plan B

Sufficient.
Equivalent
Strong attempts have been Plaintiffs
made to preserve the
existing plan.

Preserves perfect political Equivalent

division at the Precinct but
not County and City levels
statwide.

TBE Exhibit 1

Case 3:13-cv-00678-REP-LO-AD Document 256-1 Filed 10/07/15 Page 2 of 9 PageID# 5790

Comparison Chart for All Plans

Congressional Republicans TBE A

1 and 2 ["CR's"]

1. Remediation of the
violation

2. Compactness

3. Contiguity

4. Equalization
5. 2012 Plan

6. Preservation of
political divisions

Advantage

TBE B

Advantage

CR's maintained a
majority/minority 3rd
District with a BVAP of
slightly above 50%.
Substantial efforts to avoid
tendrils and promontories
were made outside of the
3rd District and 2nd
District.
The 3rd District appears to
be divided into three
separate landmasses
accessable only by boat or
by traveling through other
districts. The 2nd District
appears to be contiguous
only by connecting the
OCean View Precinct in
Norfolk to the Phoebus
Precinct in Hampton.

Racial considerations were Slight advantage Racial considerations were Slight

considered as one of many TBE Plan A
considered as one of many advantage
factors.
factors.
TBE Plan B

Sufficient.
Strong attempts have been
made to preserve the most
recent plan.
These maps makes
substantial efforts to
preserve County and City
political divisions.

Sufficient.
Equivalent
Strong attempts have been CR's
made to preserve the
existing plan.
Preserves perfect political Equivalent
division at the Precinct but
not County and City levels.

Substantial efforts to avoid TBE Plan A

tendrils and promontories
were made.

Substantial efforts to avoid TBE Plan B

tendrils and promontories
were made statewide.

Contiguity by road
achieved.

Contiguity by road
achieved.

TBE Plan A

TBE Plan B

Sufficient.
Equivalent
Strong attempts have been CR's
made to preserve the
existing plan.
Preserves perfect political Equivalent
division at the Precinct but
not County and City levels
statwide.

TBE Exhibit 1

Case 3:13-cv-00678-REP-LO-AD Document 256-1 Filed 10/07/15 Page 3 of 9 PageID# 5791

1. Remediation of the
violation

2. Compactness

3. Contiguity

4. Equalization
5. 2012 Plan

6. Preservation of
political divisions

Comparison Chart for All Plans

Governor
Racial considerations were
prominent in the
promulgation of this plan.

TBE A
Advantage
Racial considerations were TBE Plan A
considered as one of many
factors.

TBE B
Advantage
Racial considerations were TBE Plan B
considered as one of many
factors.

Tendrils and promontories Substantial efforts to avoid TBE Plan A

are prevalent in the 1st
tendrils and promontories
District, 3rd District, 5th
were made.
District, 8th District, 10th
District, and 11th District.
The separations of
precincts is severe in the
areas where the 8th and
the 10th Districts meet.

Substantial efforts to avoid TBE Plan B

tendrils and promontories
were made statewide.

Serious deficiencies in the

2nd District. The 2nd
District can no longer be
traveled via road as the
bridge connecting Norfolk
to Hampton has been cut
out of the 2nd District.

Contiguity by road
achieved.

Contiguity by road
achieved.

Sufficient.
Vague attempts have been
made to preserve the most
recent plan.
This map makes a
reasonable effort to
preseve County and City
political divisions.

Sufficient.
Equivalent
Strong attempts have been TBE Plan A
made to preserve the
existing plan.
Preserves perfect political TBE Plan A
division at the Precinct but
not County and City levels.

TBE Plan A

TBE Plan B

Sufficient.
Equivalent
Strong attempts have been TBE Plan B
made to preserve the
existing plan.
Preserves perfect political TBE Plan B
division at the Precinct but
not County and City levels
statwide.

TBE Exhibit 1

Case 3:13-cv-00678-REP-LO-AD Document 256-1 Filed 10/07/15 Page 4 of 9 PageID# 5792

1. Remediation of the
violation

2. Compactness

3. Contiguity

4. Equalization
5. 2012 Plan

6. Preservation of
political divisions

Comparison Chart for All Plans

NAACP
Racial considerations were
prominent in the
promulgation of this plan.

TBE A
Advantage
Racial considerations were TBE Plan A
considered as one of many
factors.

TBE B
Advantage
Racial considerations were TBE Plan B
considered as one of many
factors.

Tendrils and promontories Substantial efforts to avoid TBE Plan A

are prevalent in the 2nd
tendrils and promontories
District and 4th District.
were made.

Substantial efforts to avoid TBE Plan B

tendrils and promontories
were made statewide.

Serious deficiencies in the

2nd District. The 2nd
District can no longer be
traveled via road as the
bridge connecting Norfolk
to Hampton has been cut
out of the 2nd District.

Contiguity by road
achieved.

Contiguity by road
achieved.

Sufficient.
Vague attempts have been
made to preserve the most
recent plan.
This map makes a
reasonable effort to
preseve County and City
political divisions.

Sufficient.
Equivalent
Strong attempts have been TBE Plan A
made to preserve the
existing plan.
Preserves perfect political Equivalent
division at the Precinct but
not County and City levels.

TBE Plan A

TBE Plan B

Sufficient.
Equivalent
Strong attempts have been TBE Plan B
made to preserve the
existing plan.
Preserves perfect political Equivalent
division at the Precinct but
not County and City levels
statwide.

TBE Exhibit 1

Case 3:13-cv-00678-REP-LO-AD Document 256-1 Filed 10/07/15 Page 5 of 9 PageID# 5793

1. Remediation of the
violation

2. Compactness

3. Contiguity

4. Equalization
5. 2012 Plan

6. Preservation of
political divisions

Comparison Chart for All Plans

Richmond First ["R1"]

The 3rd District is
substantially different, but
it is preserved as a
majority/minority district.

TBE A
Advantage
Racial considerations were Equivalent
considered as one of many
factors.

TBE B
Advantage
Racial considerations were Equivalent
considered as one of many
factors.

Tendrils and promontories

are found in the Norfolk
area of the 3rd District.
The 4th District is
separated by the
Cheseapeake bay and
contains portions of three
peninsulas.
The 4th District on this map
is roughly equivalent to the
2nd District on other maps.
Parts of the 4th are
connected by the
Cheseapeake Bay with no
road access except through
multiple other districts.

Substantial efforts to avoid TBE Plan A

tendrils and promontories
were made.

Substantial efforts to avoid TBE Plan B

tendrils and promontories
were made statewide.

Contiguity by road
achieved.

Contiguity by road
achieved.

Sufficient.
No attempt has been made
to preserve elements of
the existing plan.

Sufficient.
Equivalent
Strong attempts have been TBE Plan A
made to preserve the
existing plan.

TBE Plan A

This map makes a strong

Preserves perfect political R1
effort to preseve County
division at the Precinct but
and City political divisions. not County and City levels.

TBE Plan B

Sufficient.
Equivalent
Strong attempts have been TBE Plan B
made to preserve the
existing plan.
Preserves perfect political Equivalent
division at the Precinct but
not County and City levels
statwide.

TBE Exhibit 1

Case 3:13-cv-00678-REP-LO-AD Document 256-1 Filed 10/07/15 Page 6 of 9 PageID# 5794

1. Remediation of the
violation

2. Compactness

Comparison Chart for All Plans

Sen. Petersen ["SP"]

The data for this
redistricting competition
plan is no longer readily
available online. The 3rd
District is said to be a
majority/minority district.

TBE A
Advantage
Racial considerations were Unknown
considered as one of many
factors.

TBE B
Advantage
Racial considerations were Unknown
considered as one of many
factors.

Tendrils and promontories Substantial efforts to avoid TBE Plan A

in the 6th District. The 1st tendrils and promontories
District is made up of
were made.
portions of four separate
peninsulas. Aside from the
contiguity problems which
also are compactness
issues for the 3rd District
the neck leading from the
heart of the 3rd up into
Richmond is a severe
gerrymander. At its
narrowest point the neck
reaches approximately
1800 feet in width.

Substantial efforts to avoid TBE Plan B

tendrils and promontories
were made statewide.

TBE Exhibit 1
Continued.

3. Contiguity

4. Equalization
5. 2012 Plan

6. Preservation of
political divisions

Case 3:13-cv-00678-REP-LO-AD Document 256-1 Filed 10/07/15 Page 7 of 9 PageID# 5795

Comparison Chart for All Plans

Sen. Petersen ["SP"]

TBE A
Serious deficiencies in the Contiguity by road
3rd District. The 3rd would achieved.
be made up of four
unconnected land masses
were it not for a bridge
that makes up the border
of a precinct coming from
Isle of Wight County over
to Newport News. The
areas of Portsmouth and
areas of Norfolk in the 3rd
Distict are neither
connected to the
remainder of the 3rd
District nor to each other.

Sufficient.
No attempt has been made
to preserve elements of
the existing plan.

Advantage
TBE Plan A

TBE B
Contiguity by road
achieved.

Advantage
TBE Plan B

Sufficient.
Equivalent
Strong attempts have been TBE Plan A
made to preserve the
existing plan.

Sufficient.
Equivalent
Strong attempts have been TBE Plan B
made to preserve the
existing plan.

This map makes some

Preserves perfect political TBE Plan A
effort to preseve County
division at the Precinct but
and City political divisions. not County and City levels.

Preserves perfect political Equivalent

division at the Precinct but
not County and City levels
statwide.

TBE Exhibit 1

Case 3:13-cv-00678-REP-LO-AD Document 256-1 Filed 10/07/15 Page 8 of 9 PageID# 5796

1. Remediation of the
violation

Comparison Chart for All Plans

Donald Garrett ["DG"]

No attempt was made to
consider race in any
manner.
Districts are Compact.

TBE A
Advantage
Racial considerations were TBE Plan A
considered as one of many
factors.
Substantial efforts to avoid DG
tendrils and promontories
were made.

TBE B
Advantage
Racial considerations were TBE Plan B
considered as one of many
factors.
Substantial efforts to avoid DG
tendrils and promontories
were made statewide.

Contiguity is preserved.

Contiguity by road
achieved.
Sufficient.

Contiguity by road
achieved.
Sufficient.

2. Compactness

3. Contiguity

4. Equalization

5. 2012 Plan

6. Preservation of
political divisions

DG

Although prefectly
TBE Plan A
equalized, this plan
eliminates the direct
connection to a
constitutency when a plan
normally divides a state
into separate congressional
districts.
No attempt has been made Strong attempts have been TBE Plan A
to preserve elements of
made to preserve the
the existing plan.
existing plan.
This map preserves all
political divisions.

Preserves perfect political DG

division at the Precinct but
not County and City levels.

DG
TBE Plan B

Strong attempts have been TBE Plan B

made to preserve the
existing plan.
Preserves perfect political DG
division at the Precinct but
not County and City levels
statwide.

TBE Exhibit 1

Case 3:13-cv-00678-REP-LO-AD Document 256-1 Filed 10/07/15 Page 9 of 9 PageID# 5797

1. Remediation of the
violation

2. Compactness

3. Contiguity

4. Equalization
5. 2012 Plan

6. Preservation of
political divisions

Comparison Chart for All Plans

Jacob Rapoport ["JR"]

Racial considerations were
prominent in the
promulgation of this plan.

TBE A
Advantage
Racial considerations were TBE Plan A
considered as one of many
factors.

TBE B
Advantage
Racial considerations were TBE Plan B
considered as one of many
factors.

Districts are fairly compact. Substantial efforts to avoid TBE Plan A

There are tendrils and
tendrils and promontories
promontories in the 3rd
were made.
District and 2nd District in
the lower area of the
James River.

Substantial efforts to avoid TBE Plan B

tendrils and promontories
were made statewide.

Contiguity is an issue in a Contiguity by road

portion of the 3rd District. achieved.
There is a portion of
Newport News that is not
connected to any other
part of the District.

Contiguity by road
achieved.

Sufficient.
Some attempt has been
made to preserve elements
of the existing plan.

TBE Plan A

TBE Plan B

Sufficient.
Equivalent
Strong attempts have been TBE Plan A
made to preserve the
existing plan.

Sufficient.
TBE Plan B
Strong attempts have been TBE Plan B
made to preserve the
existing plan.

This map makes some

Preserves perfect political TBE Plan A
effort to preseve County
division at the Precinct but
and City political divisions. not County and City levels.

Preserves perfect political TBE Plan B

division at the Precinct but
not County and City levels
statwide.