Level the Playing Field et al v. Federal Election CommissionMOTION for Order for Leave to File Amicus BriefD.D.C.June 15, 2016UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA LEVEL THE PLAYING FIELD, et al., No. 1:15-cv-01397 (TSC) Plaintiffs, vs. FEDERAL ELECTION COMMISSION, Defendants. MOTION OF SAM HUSSEINI TO PARTICIPATE AS AMICUS CURIAE Sam Husseini respectfully moves for leave to file a brief as amicus curiae in support of Plaintiffs Level the Playing Field, Peter Ackerman, Green Party of the United States, and the Libertarian National Committee, Inc. As grounds for this motion, amicus would show unto the Court that: 1. Sam Husseini*, the amicus, has been a media analysts and journalist for 25 years. He is employed by the Institute for Public Accuracy, 501(c)(3) non-profit organization incorporated in California. He files this in his personal capacity. He has previous worked for Fairness & Accuracy In Reporting. He is a graduate of Carnegie Mellon University in Applied Math, graduating in 1987. His interest is in fostering openness in the electoral system and ensuring accuracy in the reporting of polling results to better reflect the views of the general public. In his capacity as communications director at the Institute for Public Accuracy, he has studied various voting systems as well as how polling is conducted. He has founded the website VotePact.org which AMICUS CURIAE BRIEF OF SAM HUSSEIN! IN SUPPORT OF PLAINTIFFS' MOTION FOR SUMMARY JUDGMENT Case 1:15-cv-01397-TSC Document 49 Filed 06/15/16 Page 1 of 3 encourages people (would-be Democrat and Republican voters) to pair up and in effect simulate rank choice voting. *Husseini uses the pen/journalistic name of Sam Husseini; his legal name, however, is Samuel Hennessy. 2. Pursuant to LCvR 7.l(A), amicus states that it has no parent, subsidiary, or affiliated entities (corporate or otherwise) that have issued stock or debt securities to the public; no publicly held entity (corporate or otherwise) owns 10% or more of its stock; and has nothing to report under LCvR 7.l(A)(l)(a). 3. Pursuant to LCvR 7(m), counsel for amicus consulted with counsel for the parties about their consent to the filing of the attached memorandum. Counsel for both plaintiff and defendant consented to the participation of amicus. Wherefore, amicus movant respectfully requests that the Court grant leave to file a brief as amicus curiae in support of Plaintiffs. Sam Husseini does not request the opportunity to participate in oral argument. DATED: June 15, 2016 Respectfully submitted, Is/ Ann C. Wilcox Ann C. Wilcox DC Bar #421908 3607 14th Street, NW Washington, DC 20010 202-441-3 265 Annl Wilcox@ gmail.com AMICUS CURIAE BRIEF OF SAM HUSSEIN! IN SUPPORT OF PLAINTIFFS' MOTION FOR SUMMARY JUDGMENT Case 1:15-cv-01397-TSC Document 49 Filed 06/15/16 Page 2 of 3 CERTIFICATE OF SERVICE I hereby certify that on June 15, 2016, I electronically filed the foregoing motion with supporting brief of Amicus Curiae in support of Plaintiffs' Motion for Summary Judgment with the Clerk of the Court of the U.S. District Court of the District of Columbia by using the CMIECF system, which will accomplish electronic notice and service for all counsel of record. sl Ann C. Wilcox Ann C. Wilcox AMICUS CURIAE BRIEF OF SAM HUSSEIN! IN SUPPORT OF PLAINTIFFS' MOTION FOR SUMMARY JUDGMENT Case 1:15-cv-01397-TSC Document 49 Filed 06/15/16 Page 3 of 3
