Newest court filing against Fieldsworks, Chris Gallaway, and Zachary Reider, worst canvass director in the world and: Why aren't these guys in jail?

I think its the white privilege thing again. Because I'm pretty certain that as a black man I would be in jail for doing the same thing.

Clearly, Fieldworks and Zachary Reider, probably under the instruction of Chris Gallaway or other managers (Need discovery to pin that down absolutely...) clearly broke the State of Pennsylvania's rule against quotas for voter registration forms. What's worse they used that standard in a discriminatory way by making sure that blacks had to reach a higher quota. Anyway, here's the latest court filing where I don't mention any of that stuff but its still annoying.

Brief Response to Defendant's Sept. 26th Statement

1. I think I described their statement of Sept. 26th as being "weak tea" to opposing council and I stand by this.

2. But I do want to offer a very brief response. So here's a few points:

3.  I kind of wish I had been granted the original extension that I asked for. I'm answering this within 35 days because the defendant's statements are part of dispositive motion. But I still would like more time. I feel this affects my case in a very negative way. For example the deadline for responding to this brief and the brief in the other case on the exact same day. Or today. Not fair.

4. All of the problems that Defendants complain about can be solved with an amended complaint. This is where I use the specific examples of what I meant in the original complaint in the following response briefs in the amended complaint. I can also make sure that I clearly state what Section 1981 does but I assumed since yinz guys were lawyers that you already knew. I just need an afternoon or two to do that. Would gladly do it if necessary.

5. Or the court could use the "common sense' instruction that its supposed to use in 12 b 6 cases and assume that the Defendants already understand what they have to rebut, by now (such as direct testimony that Zachary Reider is a racist by five black persons and possibly one white employee as well.) and we can simply move on to discovery. I think I used the phrase "obscenely obtuse" in another legal document. That would be the case here if there was a demand for an amended complaint but I could still write one. Might take two afternoons who knows. They know by now what has to be rebutted.

6. Its clear that Zachary Reider is an employer or proxy of an employer which means that he's the kind of guy that has to abide by Section 1981. Or I was fired by a ghost. Some kind of imaginary being. There were no other managers at Fieldworks at the time.

7. I don't have to prove a prima facie case at this stage. See the appeals court decision Sandra Connelly v. Lane Construction Corporation:

It is thus worth reiterating that, at least for purposes of pleading sufficiency, a complaint need not establish a prima facie case in order to survive a motion to dismiss.6 A prima facie case is “an evidentiary standard, not a pleading requirement,” Swierkiewicz v. Sorema, N.A., 534 U.S. 506, 510 (2002), and hence is “not a proper measure of whether a complaint fails to state a claim.” Fowler v. UPMC Shadyside, 578 F.3d 203, 213 (3d Cir. 2009)

8. We may ask for a hearing so that these issues can be ironed out.

Respectfully submitted,

Philip Shropshire

Signature

10-31-18

Certificate of Service

I have mailed out this statement on Oct. 31st, 2018 to the court by way of UPS. I will email a copy of this statement to opposing counsel in the next day or two.