IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF OHIO

WESTERN DIVISION

Ohio A. Philip Randolph Institute, et al.,

Plaintiffs,

vs.

Ryan Smith, Speaker of the Ohio House of 

Representatives, et al.,

Defendants.

Case No.: 1:18-cv-00357-TSB

Judge Timothy S. Black

Judge Karen Nelson Moore

Judge Michael H. Watson

Magistrate Judge Karen L Litkovitz

MOTION OF REPUBLICAN CONGRESSIONAL DELEGATION,

OHIO VOTERS, AND REPUBLICAN PARTY ORGANIZATIONS TO INTERVENE

Applicants for Intervention Steve Chabot, Brad Wenstrup, Jim Jordan, Bob Latta, Bill Johnson, 

Bob Gibbs, Warren Davidson, Michael Turner, Dave Joyce, and Steve Stivers (together, the 

“Member Intervenor Applicants”) are duly elected representatives of the U.S. House of 

Representatives, members of the Republican Party, and represent the challenged districts. 

Applicants for Intervention, the Republican Party of Cuyahoga County (“RPCC”) and the Franklin 

County Republican Party (“FCRP”), are county political parties duly authorized and existing 

under Ohio law (the “Party Intervenor Applicants”). Finally, applicants for Intervention Robert 

F. Bodi, Charles Drake, Roy Palmer III, and Nathan Aichele (the “Voter Intervenor Applicants” 

and, collectively with the Member Intervenor Applicants and Party Intervenor Applicants, the 

“Intervenor Applicants”) are registered voters who reside in Ohio congressional districts 

challenged in this litigation. The Intervenor Applicants’ personal and organizational interests and 

rights will be directly impacted by the outcome of this case. For this reason and the reasons stated 

in the accompanying Memorandum, the Intervenor Applicants respectfully move this Court, 

pursuant to Fed. R. Civ. P. 24(a), for intervention as a matter of right; or, in the alternative, pursuant 
to Fed. R. Civ. P. 24(b), for permissive intervention in this case to protect their right to vote and 

personal interests. Pursuant to Fed. R. Civ. P. 24(c), the Intervenor Applicants attach their 

proposed Answer to the Second Amended Complaint as their responsive pleading.

Prior to filing this motion, the Intervenor Applicants contacted counsel for the existing 

Defendants in this case. Those Defendants have represented to the undersigned that they consent 

to the intervention of the Intervenor Applicants in this action. 

WHEREFORE, for the foregoing reasons, the Intervenor Applicants respectfully request that 

this Court grant this motion, permit their intervention, and accept their Answer for filing. 

Dated: July 20, 2018 Respectfully submitted,

BAKERHOSTETLER LLP

/s/ Patrick T. Lewis

Patrick T. Lewis (0078314)

Trial Attorney

Email: plewis@bakerlaw.com

127 Public Square, Suite 2000

Cleveland, OH 44114-1214

(216) 621-0200 / Fax (216) 696-0740 

Robert J. Tucker (0082205)

Email: rtucker@bakerlaw.com

200 Civic Center Drive, Suite 1200

Columbus, OH 43215-4138

(614) 228-1541 / Fax (614) 462-2616

Katherine L. McKnight(*)

Email: kmcknight@bakerlaw.com

Richard B. Raile(*)

Email: rraile@bakerlaw.com

Washington Square, Suite 1100

1050 Connecticut Avenue, N.W.

Washington, DC 20036-5403

(202) 861-1500 / Fax (202) 861-1783

(*) pro hac vice motions to be filed

Counsel for Intervenor Applicants
CERTIFICATE OF SERVICE

I hereby certify that on July 20, 2018, a true and correct copy of the foregoing was filed 

via the Court’s CM/ECF system and served via electronic filing upon all counsel of record in this 

case. 

/s/ Patrick T. Lewis

Patrick T. Lewis (0078314)

Counsel for Intervenor Applicants