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Designation of Contents of Reproduced Record

This document designates the contents to be included in the reproduced record for an appeal to the Supreme Court of Pennsylvania. It lists docket entries, pleadings filed in the Commonwealth Court, and a brief statement of five issues to be presented on appeal. Specifically, it challenges the Commonwealth Court's ruling that the claims were moot, that certain laws applied to the constitutional claims, and that one challenge was waived. It seeks review of whether the court erred in its holdings.

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374 views

Designation of Contents of Reproduced Record

This document designates the contents to be included in the reproduced record for an appeal to the Supreme Court of Pennsylvania. It lists docket entries, pleadings filed in the Commonwealth Court, and a brief statement of five issues to be presented on appeal. Specifically, it challenges the Commonwealth Court's ruling that the claims were moot, that certain laws applied to the constitutional claims, and that one challenge was waived. It seeks review of whether the court erred in its holdings.

Uploaded by

AI
Copyright
© © All Rights Reserved
Available Formats
Download as PDF, TXT or read online on Scribd
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Received 10/22/2021 12:22:06 PM Supreme Court Middle District

IN THE SUPREME COURT OF PENNSYLVANIA


MIDDLE DISTRICT
______________________
No. 56 MAP 2021
______________________

ANDREW IOANNIDIS,
Appellant,

v.

TOM WOLF, in his official capacity as Governor of the Commonwealth of Pennsylvania, and
VERONICA DEGRAFFENREID, in her official capacity as Acting Secretary of the
Commonwealth of Pennsylvania,
Appellees.
______________________________

On Appeal from the July 8, 2021 Order by the Commonwealth Court of Pennsylvania,
No. 635 M.D. 2020, Dismissing Petitioner’s Amended Petition for Review as Moot
___________________________

APPELLANT’S
DESIGNATION OF CONTENTS OF REPRODUCED RECORD
__________________________

Andrew Ioannidis (Pa. I.D. No. 326060)


457 Pleasant View Road
New Cumberland, Pennsylvania 17070
Phone: (908) 268-7571
E-Mail: [email protected]
Petitioner & Appellant
I. DESIGNATION OF CONTENTS OF THE REPRODUCED RECORD
Appellant intends to include the following materials in the Reproduced Record:
Docket Entries
1. List of relevant docket entries from the Commonwealth Court of Pennsylvania.
Pleadings
2. Amended Petition for Review in the Nature of a Petition and Complaint in Equity
– January 19, 2021.

3. Executive Respondents’ Application for Summary Relief in the Form of a Motion


to Dismiss Amended Petition for Review as Moot – February 19, 2021.

4. Executive Respondents’ Memorandum of Law in Support of Application for


Summary Relief in the Form of a Motion to Dismiss Amended Petition for
Review as Moot – February 19, 2021.

5. Petitioner’s Answer and Brief in Opposition to Respondents’ Preliminary


Objections and Application for Summary Relief in the Form of a Motion to
Dismiss – May 2, 2021.

6. Reply Brief in Further Support of Executive Respondents’ Motion to Dismiss for


Mootness and in Support of Executive Respondents’ Preliminary Objections to
Amended Petition for Review – May 14, 2021.

7. Memorandum Opinion and Order – July 8, 2021.

8. Application for Reconsideration and Re-Argument En Banc – July 18, 2021.

9. Executive Respondents’ Answer to Petitioner’s Application for Reconsideration


and Reargument En Banc – July 22, 2021.

II. BRIEF STATEMENT OF THE ISSUES TO BE PRESENTED FOR REVIEW

1. Whether the Court erred by holding that Petitioner’s claims are moot and

granting Respondents’ Application for Summary Relief in the Form of a Motion to Dismiss

as Moot.
2. Whether the Court erred by holding that Pennsylvania’s Declaratory

Relief Act and Election Code apply to Constitutional Equal Protection, Substantive Due

Process, and First Amendment claims.

3. Whether the Court erred by holding that Pennsylvania’s Election Code

applies to mootness exception doctrines.

4. Whether the Court erred by holding that Petitioner’s challenges to the

Electoral Count Act of 1887, as amended, are waived.

5. Whether the Court erred by holding that Petitioner’s Constitutional rights

are effectively meaningless.

Respectfully submitted,
By: /s/ Andrew Ioannidis
457 Pleasant View Road
New Cumberland, Pennsylvania 17070
908-268-7571
Pa. I.D. No. 326060
Petitioner/Appellant
Dated: October 22, 2021.
CERTIFICATE OF COMPLIANCE

I certify that this filing complies with the provisions of the Case Records Public Access

Policy of the Unified Judicial System of Pennsylvania that require filing confidential information

and documents differently than non-confidential information and documents.

Respectfully submitted,
By: /s/ Andrew Ioannidis
457 Pleasant View Road
New Cumberland, Pennsylvania 17070
908-268-7571
Pa. I.D. No. 326060
Petitioner/Appellant
Dated: October 22, 2021.
CERTIFICATE OF SERVICE

I certify that I caused a true and correct copy of this Designation of Contents of

Reproduced Record to be served upon the following persons by electronic service through the

Court’s PACFile system and by E-Mail:

Tom Wolf and Veronica Degraffenreid


c/o Karen Romano, Stephen Moniak, Keli Neary, and Sean Kirkpatrick
Office of the Attorney General
Litigation Section
th
15 Floor, Strawberry Square
Harrisburg, PA 17120
[email protected]
[email protected]
[email protected]
[email protected]

Respectfully submitted,
By: /s/ Andrew Ioannidis
457 Pleasant View Road
New Cumberland, Pennsylvania 17070
908-268-7571
Pa. I.D. No. 326060
Petitioner/Appellant
Dated: October 22, 2021.

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