Some loose implementation of where I would start. The hooks 'comment_form_default_fields', 'comment_form_defaults', and the 'comment_form_{location}' hooks look promising. Line 1569 of comment-template.php is doing the fields, and line 1575 is doing the main field, you might be able to “trick” wordpress into putting the comment field up top…but all that seems like it would take a lot of tinkering and time to get perfect, CSS is probably the best way to go about this unfortunately.
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