U.S. District Court Western District of Virginia (Lynchburg) CIVIL DOCKET FOR CASE #: 6:20-cv-00024-NKM-RSB

League of Women Voters of Virginia et al v. Virginia State Board of Elections et al Assigned to: Senior Judge Norman K. Moon Referred to: Magistrate Judge Robert S. Ballou Cause: 42:1983 Civil Rights Act

Date Filed: 04/17/2020 Jury Demand: None Nature of Suit: 441 Civil Rights: Voting Jurisdiction: Federal Question

Plaintiff

League of Women Voters of Virginia

represented by Adriel Cepeda Derieux American Civil Liberties Union Foundation, Inc. 125 Broad Street New York, NY 10004-2400 212-549-2500 Email: acepedaderieux@aclu.org LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Dale Edwin Ho American Civil Liberties Union Foundation, Inc. 125 Broad Street New York, NY 10004-2400 212-549-2500 Email: dho@aclu.org LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Davin McKay Rosborough American Civil Liberties Union Foundation, Inc. 125 Broad Street New York, NY 10004-2400 212-549-2613 Email: drosborough@aclu.org LEAD ATTORNEY ATTORNEY TO BE NOTICED

Eden Brooke Heilman American Civil Liberties Union of

Plaintiff Katherine D. Crowley

Virginia Foundation 701 E. Franklin St., Suite 1412 Richmond, VA 23219 804-523-2152 Fax: 804-649-2733 Email: eheilman@acluva.org LEAD ATTORNEY ATTORNEY TO BE NOTICED
Sophia Lin Lakin American Civil Liberties Union Foundation, Inc. 125 Broad Street New York, NY 10004-2400 212-549-2500 Email: slakin@aclu.org LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Theresa Jeane Lee American Civil Liberties Union Foundation, Inc. 125 Broad Street New York, NY 10004-2400 212-549-2500 Email: tlee@aclu.org LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Vishal Mahendra Agraharkar American Civil Liberties Union of Virginia Foundation 701 E. Franklin St., Suite 1412 Richmond, VA 23219 804-523-2151 Fax: 804-649-2733 Email: vagraharkar@acluva.org LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Adriel Cepeda Derieux (See above for address) LEAD ATTORNEY

Plaintiff
Erikka Goff TERMINATED: 06/19/2020

PRO HAC VICE ATTORNEY TO BE NOTICED
Dale Edwin Ho (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Davin McKay Rosborough (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Eden Brooke Heilman (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Sophia Lin Lakin (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Theresa Jeane Lee (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Vishal Mahendra Agraharkar (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Adriel Cepeda Derieux (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Dale Edwin Ho (See above for address) LEAD ATTORNEY

Plaintiff Seijra Toogood

PRO HAC VICE ATTORNEY TO BE NOTICED
Davin McKay Rosborough (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Eden Brooke Heilman (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Sophia Lin Lakin (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Theresa Jeane Lee (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Vishal Mahendra Agraharkar (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Adriel Cepeda Derieux (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Dale Edwin Ho (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Davin McKay Rosborough (See above for address) LEAD ATTORNEY

Plaintiff Tracy Safran

ATTORNEY TO BE NOTICED
Eden Brooke Heilman (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Sophia Lin Lakin (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Theresa Jeane Lee (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Vishal Mahendra Agraharkar (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Adriel Cepeda Derieux (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Dale Edwin Ho (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Davin McKay Rosborough (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Eden Brooke Heilman (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Plaintiff Carol D. Peterson

Sophia Lin Lakin (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Theresa Jeane Lee (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Vishal Mahendra Agraharkar (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Adriel Cepeda Derieux (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Dale Edwin Ho (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Davin McKay Rosborough (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Eden Brooke Heilman (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Sophia Lin Lakin (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Plaintiff Gayle Hardy

Theresa Jeane Lee (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Vishal Mahendra Agraharkar (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Adriel Cepeda Derieux (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Dale Edwin Ho (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Davin McKay Rosborough (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Eden Brooke Heilman (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Sophia Lin Lakin (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Theresa Jeane Lee (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

V. Movant Sheila DeLappe Ferguson TERMINATED: 04/29/2020

Vishal Mahendra Agraharkar (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bradley Phipps Marrs Marrs & Henry 7202 Glen Forest Drive, Suite 300 Richmond, VA 23226 804-662-5716 Fax: 804-662-5712 Email: bmarrs@marrs-henry.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Courtney Turner Milbank The Bopp Law Firm, PC 1 South Sixth Street Terre Haute, IN 47807 812-232-2434 Fax: 812-235-3685 Email: cmilbank@bopplaw.com LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
James Bopp , Jr. The Bopp Law Firm, PC 1 South Sixth Street Terre Haute, IN 47807 812-232-2434 Fax: 812-235-3685 Email: jboppjr@aol.com LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Patrick Cullen Henry , II Marrs & Henry 7202 Glen Forest Drive, Suite 307 Richmond, VA 23226 804-662-5715

Movant Sandy Burchett TERMINATED: 04/29/2020
Movant Diane Crickenberger TERMINATED: 04/29/2020

Fax: 804-662-5712 Email: phenry@marrs-henry.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bradley Phipps Marrs (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Courtney Turner Milbank (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
James Bopp , Jr. (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Patrick Cullen Henry , II (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Bradley Phipps Marrs (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Courtney Turner Milbank (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
James Bopp , Jr. (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Patrick Cullen Henry , II

Movant
Vincent E. Falter TERMINATED: 04/29/2020

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Christopher Michael Marston CHRISTOPHER M. MARSTON, ATTORNEY-AT-LAW P.O. BOX 26141 ALEXANDRIA, VA 22313 571-482-7690 Fax: 703-997-2549 Email: chris.marston@gmail.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
E. Mark Braden Baker & Hostetler LLP 1050 Connecticut Avenue, NW, Suite 1100 Washington, DC 20036 202-861-1500 Fax: 202-861-1738 LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Patrick Thomas Lewis Baker & Hostetler LLP 127 Public Square, Suite 2000 Cleveland, OH 44114-1214 216-861-7096 Fax: 216-696-0740 Email: plewis@bakerlaw.com LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Richard Bryan Raile Baker & Hostetler LLP 1050 Connecticut Avenue, NW, Suite 1100 Washington, DC 20036 202-861-1711 Fax: 202-861-1783 Email: rraile@bakerlaw.com

Movant Mildred H. Scott TERMINATED: 04/29/2020
Movant Thomas N. Turner, Jr. TERMINATED: 04/29/2020

LEAD ATTORNEY ATTORNEY TO BE NOTICED
Trevor Marshall Stanley Baker & Hostetler LLP 1050 Connecticut Avenue, NW, Suite 1100 Washington, DC 20036 202-861-1551 Email: tstanley@bakerlaw.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Christopher Michael Marston (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
E. Mark Braden (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Patrick Thomas Lewis (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Richard Bryan Raile (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Trevor Marshall Stanley (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Christopher Michael Marston (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

V. Defendant Virginia State Board of Elections

E. Mark Braden (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Patrick Thomas Lewis (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Richard Bryan Raile (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Trevor Marshall Stanley (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Carol Louise Lewis Office of the Attorney General of Virginia - Richmond 202 North Ninth Street Richmond, VA 23219 804-692-0558 Fax: 804-786-2650 Email: clewis@oag.state.va.us LEAD ATTORNEY ATTORNEY TO BE NOTICED
Michelle Shane Kallen Office of the Attorney General of Virginia - Richmond 202 North Ninth Street Richmond, VA 23219 8040-786-2071 Fax: 8004-371-0200 Email: mkallen@oag.state.va.us LEAD ATTORNEY ATTORNEY TO BE NOTICED

Defendant Robert H. Brink in their official capacities as Chairman, Vice-Chair, and Secretary of the Virginia State Board of Elections, respectively
Defendant John O'Bannon in their official capacities as Chairman, Vice-Chair, and Secretary of the Virginia State Board of Elections, respectively

Calvin Cameron Brown Office of the Attorney General Richmond 202 North Ninth Street Richmond, VA 23219 804-486-4933 Fax: 804-371-2087 Email: cbrown@oag.state.va.us ATTORNEY TO BE NOTICED
Heather Hays Lockerman Office of the Attorney General Financial Law and Government Support Section 202 North Ninth Street Richmond, VA 23219 804-786-0067 Fax: 804-517-6147 Email: hlockerman@oag.state.va.us ATTORNEY TO BE NOTICED
represented by Carol Louise Lewis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Michelle Shane Kallen (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Calvin Cameron Brown (See above for address) ATTORNEY TO BE NOTICED
Heather Hays Lockerman (See above for address) ATTORNEY TO BE NOTICED
represented by Carol Louise Lewis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Defendant Jamilah D. LeCruise in their official capacities as Chairman, Vice-Chair, and Secretary of the Virginia State Board of Elections, respectively
Defendant Christopher E. Piper in his official capacity as Commissioner of the Virginia Department of Elections

Michelle Shane Kallen (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Calvin Cameron Brown (See above for address) ATTORNEY TO BE NOTICED
Heather Hays Lockerman (See above for address) ATTORNEY TO BE NOTICED
represented by Carol Louise Lewis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Michelle Shane Kallen (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Calvin Cameron Brown (See above for address) ATTORNEY TO BE NOTICED
Heather Hays Lockerman (See above for address) ATTORNEY TO BE NOTICED
represented by Carol Louise Lewis (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Michelle Shane Kallen (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Calvin Cameron Brown (See above for address) ATTORNEY TO BE NOTICED

V. Intervenor Defendant Republican Party of Virginia, Inc.
Amicus PILF

Heather Hays Lockerman (See above for address) ATTORNEY TO BE NOTICED
represented by Christopher Michael Marston (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
E. Mark Braden (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Patrick Thomas Lewis (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Richard Bryan Raile (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Trevor Marshall Stanley (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Graven Winslow Craig CraigWilliams, PLC P.O. BOX 68 LOUISA, VA 23093 540-967-9900 Fax: 540-967-3567 Email: graven@callnow.law LEAD ATTORNEY ATTORNEY TO BE NOTICED
John Christian Adams

Amicus The Honest Elections Project
Amicus Landmark Legal Foundation

Public Interest Legal Foundation 1555 King Street, Suite 200 Alexandria, VA 22314 703-963-8611 Email: adams@publicinterestlegal.org LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Jonathan P. Lienhard Holtzman Vogel Josefiak Torchinsky PLLC 45 North Hill Drive, Suite 100 Warrenton, VA 20186 540-341-8808 Fax: 540-341-8461 Email: jlienhard@hvjt.law LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Graven Winslow Craig (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
John Christian Adams (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Date Filed 04/17/2020
04/17/2020 04/17/2020

# Docket Text
1 COMPLAINT FOR INJUNCTIVE AND DECLARATORY RELIEF against Virginia State Board of Elections, Robert H. Brink, John O'Bannon, Jamilah D. LeCruise, and Christopher E. Piper (Filing & Administrative fee $400.00, Receipt No. 0423-3372777), filed by League of Women Voters of Virginia, Katherine D. Crowley, Erikka Goff, and Seijra Toogood. (Attachment: # 1 Civil Cover Sheet)(ca)
2 Positive Corporate Disclosure Statement by League of Women Voters of Virginia identifying Corporate Parent League of Women Voters of the US for League of Women Voters of Virginia. (ca)
3 Negative Corporate Disclosure Statement by Katherine D. Crowley. (ca)

04/17/2020 04/17/2020 04/17/2020
04/17/2020 04/17/2020 04/17/2020 04/17/2020 04/20/2020
04/20/2020

4 Negative Corporate Disclosure Statement by Erikka Goff. (ca)
5 Negative Corporate Disclosure Statement by Seijra Toogood. (ca)
6 Electronic Summonses Issued as to Virginia State Board of Elections, Robert H. Brink, John O'Bannon, Jamilah D. LeCruise, and Christopher E. Piper. NOTICE TO COUNSEL: Please print copies of the electronically issued summons for each defendant as necessary to effectuate service under Fed. R. Civ. P. 4. (Attachments: # 1 Electronic Summons Issued to Robert H. Brink, # 2 Electronic Summons Issued to John O'Bannon, # 3 Electronic Summons Issued to Jamilah D. LeCruise, # 4 Electronic Summons Issued to Christopher E. Piper)(ca)
7 MOTION for Dale Ho to Appear Pro Hac Vice. Filing fee $ 100, receipt number 0423-3373629. by Katherine D. Crowley, Erikka Goff, League of Women Voters of Virginia, Seijra Toogood. (Attachments: # 1 Exhibit, # 2 Text of Proposed Order)(Agraharkar, Vishal)
8 MOTION for Adriel I. Cepeda Derieux to Appear Pro Hac Vice. Filing fee $ 100, receipt number 0423-3373630. by Katherine D. Crowley, Erikka Goff, League of Women Voters of Virginia, Seijra Toogood. (Attachments: # 1 Exhibit, # 2 Text of Proposed Order)(Agraharkar, Vishal)
9 MOTION for Sophia Lakin to Appear Pro Hac Vice. Filing fee $ 100, receipt number 0423-3373631. by Katherine D. Crowley, Erikka Goff, League of Women Voters of Virginia, Seijra Toogood. (Attachments: # 1 Exhibit, # 2 Text of Proposed Order)(Agraharkar, Vishal)
10 MOTION for Theresa Lee to Appear Pro Hac Vice. Filing fee $ 100, receipt number 0423-3373632. by Katherine D. Crowley, Erikka Goff, League of Women Voters of Virginia, Seijra Toogood. (Attachments: # 1 Exhibit, # 2 Text of Proposed Order)(Agraharkar, Vishal)
11 Oral ORDER REFERRING MOTIONS: 7 MOTION for Dale Ho to Appear Pro Hac Vice; 8 MOTION for Adriel I. Cepeda Derieux to Appear Pro Hac Vice; 9 MOTION for Sophia Lakin to Appear Pro Hac Vice; and 10 MOTION for Theresa Lee to Appear Pro Hac Vice. Motions referred to Robert S. Ballou. Entered by Senior Judge Norman K. Moon on April 20, 2020. This Notice of Electronic Filing is the Official ORDER for this entry. No document is attached.(ca)
12 ORDER granting 7 MOTION to Appear Pro Hac Vice Attorney Dale Ho for Katherine D. Crowley, Erikka Goff, League of Women Voters of Virginia and Seijra Toogood added. Signed by Magistrate Judge Robert S. Ballou on 4/20/2020. (al)

04/20/2020 04/20/2020 04/20/2020 04/21/2020 04/21/2020
04/21/2020 04/22/2020 04/23/2020 04/23/2020 04/23/2020 04/23/2020

13 ORDER granting 8 MOTION to Appear Pro Hac Vice Attorney Adriel I. Cepeda Derieux for Katherine D. Crowley, Erikka Goff, League of Women Voters of Virginia, and for Seijra Toogood added. Signed by Magistrate Judge Robert S. Ballou on 4/20/2020. (al)
14 ORDER granting 9 MOTION to Appear Pro Hac Vice Attorney Sophia Lakin for Katherine D. Crowley, Erikka Goff, League of Women Voters of Virginia, and for Seijra Toogood added. Signed by Magistrate Judge Robert S. Ballou on 4/20/2020. (al)
15 ORDER granting 10 MOTION to Appear Pro Hac Vice Attorney Theresa Lee for Katherine D. Crowley, Erikka Goff, League of Women Voters of Virginia, and for Seijra Toogood added. Signed by Magistrate Judge Robert S. Ballou on 4/20/2020. (al)
16 MOTION for Preliminary Injunction by Katherine D. Crowley, Erikka Goff, League of Women Voters of Virginia, Seijra Toogood. (Agraharkar, Vishal)
17 Brief / Memorandum in Support re 16 MOTION for Preliminary Injunction . filed by Katherine D. Crowley, Erikka Goff, League of Women Voters of Virginia, Seijra Toogood. (Attachments: # 1 Exhibit A - Reingold Declaration, # 2 Exhibit B - Iles Declaration, # 3 Exhibit C - Rosborough Declaration, # 4 Exhibit D Goff Declaration, # 5 Exhibit E - Toogood Declaration, # 6 Exhibit F - Wake Declaration)(Agraharkar, Vishal)
18 MOTION to Expedite Briefing Schedule on Plaintiffs' Motion for Preliminary Injunction by Katherine D. Crowley, Erikka Goff, League of Women Voters of Virginia, Seijra Toogood. (Agraharkar, Vishal)
19 NOTICE of Appearance by Carol Louise Lewis on behalf of All Defendants (Lewis, Carol)
20 NOTICE of Hearing: (CR) (No Interpreter requested) Telephonic Status Conference set for April 24, 2020 at 2:00 PM in Lynchburg before Senior Judge Norman K. Moon. (Parties will receive dial-in instructions by email.)(ca)
21 NOTICE of Appearance by Heather Hays Lockerman on behalf of All Defendants (Lockerman, Heather)
22 First MOTION to Intervene by Sheila DeLappe Ferguson, Sandy Burchett, Diane Crickenberger. (Attachments: # 1 Exhibit Proposed Answer & Crossclaim, # 2 Text of Proposed Order Proposed Order)(Henry, Patrick)
23 Brief / Memorandum in Support re 22 First MOTION to Intervene . filed by Sandy Burchett, Diane Crickenberger, Sheila DeLappe Ferguson. (Henry, Patrick)

04/23/2020 04/23/2020 04/24/2020 04/24/2020
04/24/2020 04/24/2020 04/24/2020 04/24/2020
04/27/2020 04/27/2020

24 MOTION for James Bopp, Jr. to Appear Pro Hac Vice. Filing fee $ 100, receipt number 0423-3379751. by Sandy Burchett, Diane Crickenberger, Sheila DeLappe Ferguson. (Attachments: # 1 Exhibit Bopp Certification of Compliance, # 2 Text of Proposed Order Proposed Order)(Henry, Patrick)
25 MOTION for Courtney Turner Milbank to Appear Pro Hac Vice. Filing fee $ 100, receipt number 0423-3379781. by Sandy Burchett, Diane Crickenberger, Sheila DeLappe Ferguson. (Attachments: # 1 Exhibit Certificate of Compliance, # 2 Text of Proposed Order Proposed Order)(Henry, Patrick)
26 NOTICE of Appearance by Michelle Shane Kallen on behalf of All Defendants (Kallen, Michelle)
27 Oral ORDER REFERRING MOTIONS: 24 MOTION for James Bopp, Jr. to Appear Pro Hac Vice; and 25 MOTION for Courtney Turner Milbank to Appear Pro Hac Vice. Motions referred to Robert S. Ballou. Entered by Senior Judge Norman K. Moon on April 24, 2020. This Notice of Electronic Filing is the Official ORDER for this entry. No document is attached.(ca)
28 MOTION to Intervene by Republican Party of Virginia, Inc., Vincent E. Falter, Mildred H. Scott, Thomas N. Turner, Jr.. (Attachments: # 1 Exhibit A, # 2 Exhibit B (Proposed Order))(Marston, Christopher)
29 Brief / Memorandum in Support re 28 MOTION to Intervene . filed by Vincent E. Falter, Republican Party of Virginia, Inc., Mildred H. Scott, Thomas N. Turner, Jr.. (Marston, Christopher)
30 Minute Entry for telephone conference held before Senior Judge Norman K. Moon: Status Conference held on 4/24/2020. (Court Reporter: Mary Butenschoen) (al)
31 ORDER granting 18 Motion to Expedite Briefing Schedule. The Court hereby ORDERS the briefing schedule set forth herein be strictly adhered to. The parties are directed to confer with Scheduling Clerk Carmen Amos as soon as is feasible in order to schedule a hearing on Plaintiff's Motion for Preliminary Injunction, Dkt. 16, which is to be held on an agreed-upon time on May 4, 2020. Signed by Senior Judge Norman K. Moon on April 24, 2020. (ca)
32 ORDER granting 24 MOTION to Appear Pro Hac Vice. Attorney James Bopp, Jr. for Sandy Burchett, Diane Crickenberger, and Sheila DeLappe Ferguson added. Signed by Magistrate Judge Robert S. Ballou on April 27, 2020. (ca)
33 ORDER granting 25 MOTION to Appear Pro Hac Vice. Attorney Courtney Turner Milbank for Sandy Burchett, Diane Crickenberger, and Sheila DeLappe Ferguson added. Signed by Magistrate Judge Robert S. Ballou on April 27, 2020. (ca)

04/27/2020 04/27/2020 04/27/2020 04/28/2020 04/28/2020
04/28/2020 04/28/2020 04/28/2020 04/28/2020

34 NOTICE of Hearing on Motion 16 MOTION for Preliminary Injunction : (CR) (No Interpreter requested) TELEPHONIC Motion Hearing set for May 4, 2020 at 10:00 AM in Lynchburg before Senior Judge Norman K. Moon. (Parties to receive dial-in instructions via email.)(ca)

35 Joint MOTION to Approve Consent Judgment (Partial Consent Judgment and Decree) by Katherine D. Crowley, Erikka Goff, League of Women Voters of Virginia, Seijra Toogood. (Attachments: # 1 Exhibit A - proposed Partial Consent Judgment and Decree)(Rosborough, Davin)

Joint Brief / Memorandum in Support re 35 Joint MOTION to

36

Approve Consent Judgment (Partial Consent Judgment and

Decree) . filed by Katherine D. Crowley, Erikka Goff, League of

Women Voters of Virginia, Seijra Toogood. (Rosborough, Davin)

First Brief / Memorandum in Opposition re 17 Brief / Memorandum

37

in Support, 16 MOTION for Preliminary Injunction . filed by Sandy

Burchett, Diane Crickenberger, Sheila DeLappe Ferguson. (Henry,

Patrick)

38 MOTION for Leave to File Responsive Brief, re 35 Joint MOTION to Approve Consent Judgment (Partial Consent Judgment and Decree) seeking permission of Court to file brief in opposition by a date certain filed by Sandy Burchett, Diane Crickenberger, Sheila DeLappe Ferguson. (Attachment: # 1 Text of Proposed Order)(Henry, Patrick) Modified on 4/28/2020 - Docket text was modified to reflect the correct docket entry. (ca)

39 NOTICE of Hearing: (CR) (No Interpreter requested) TELEPHONIC Status Conference set for April 29, 2020 at 4:00 PM in Lynchburg before Senior Judge Norman K. Moon. (Parties to receive dial-in instructions by email.) (ca)

40 Brief / Memorandum in Opposition re 28 MOTION to Intervene , 22 First MOTION to Intervene . filed by Katherine D. Crowley, Erikka Goff, League of Women Voters of Virginia, Seijra Toogood. (Attachments: # 1 Exhibit A - Veasey v. Perry Order Denying Intervention, # 2 Exhibit B - United States v. Florida Order Denying Intervention)(Rosborough, Davin)

41 SECOND Expedited Briefing Order. This second expedited briefing schedule replaces the first expedited briefing schedule, Dkt. 31 , in full. Signed by Senior Judge Norman K. Moon on April 28, 2020. (ca)

42 MOTION for Patrick T. Lewis to Appear Pro Hac Vice. Filing fee $ 100, receipt number 0423-3382282. by Vincent E. Falter, Republican Party of Virginia, Inc., Mildred H. Scott, Thomas N. Turner, Jr..

04/28/2020 04/28/2020
04/28/2020
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(Attachments: # 1 Exhibit Attorney Certificate, # 2 Text of Proposed Order Proposed Order)(Marston, Christopher)
43 MOTION for E. Mark Braden to Appear Pro Hac Vice. Filing fee $ 100, receipt number 0423-3382298. by Vincent E. Falter, Republican Party of Virginia, Inc., Mildred H. Scott, Thomas N. Turner, Jr.. (Attachments: # 1 Exhibit Attorney Certificate, # 2 Text of Proposed Order Proposed Order)(Marston, Christopher)
44 Brief / Memorandum in Opposition re 16 MOTION for Preliminary Injunction . filed by Vincent E. Falter, Republican Party of Virginia, Inc., Mildred H. Scott, Thomas N. Turner, Jr.. (Attachments: # 1 Exhibit A - Declaration of Mildred H. Scott, # 2 Exhibit B Declaratin of Thomas N. Turner, Jr.)(Marston, Christopher) (Attachment 2 replaced on 4/28/2020) (ca). Modified on 4/28/2020 - Replaced deficient pdf document with corrected pdf document. (ca)
45 ORDER granting 38 Motion for Leave to File Responsive Brief filed by Sandy Burchett, Diane Crickenberger, and Sheila DeLappe Ferguson. The proposed intervenors shall submit their response in accordance with 41 the Second Expedited Briefing Order, which was issued on this date. Signed by Senior Judge Norman K. Moon on April 28, 2020. (ca)
46 Amicus Curiae APPEARANCE entered by Graven Winslow Craig on behalf of League of Women Voters of Virginia (Attachments: # 1 Supplement, # 2 Exhibit, # 3 Exhibit)(Craig, Graven)
47 MOTION for Leave to File Amici Curiae Brief by Graven Winslow Craig on behalf of PILF and Landmark Legal Foundation. (Craig, Graven) Modified on 4/28/2020 - Docket text was modified to reflect the correct docket entry. (ca)
48 BRIEF / MEMORANDUM IN OPPOSITION filed by PILF and Landmark Legal Foundation as Amici Curiae entered by Graven Winslow Craig. (Attachments: # 1 Exhibit, # 2 Exhibit)(Craig, Graven) Modified on 4/28/2020 - Docket text was modified to reflect the correct docket entry. (ca)
49 Brief / Memorandum in Opposition re 28 MOTION to Intervene , 22 First MOTION to Intervene . filed by Robert H. Brink, Jamilah D. LeCruise, John O'Bannon, Christopher E. Piper, Virginia State Board of Elections. (Lewis, Carol)
50 First MOTION for Leave to File Brief of Amicus Curiae by The Honest Elections Project. (Attachments: # 1 Exhibit, # 2 Exhibit)(Lienhard, Jonathan)
51 NOTICE of Appearance by Jonathan P. Lienhard on behalf of The Honest Elections Project (Lienhard, Jonathan)

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04/30/2020
04/30/2020 04/30/2020 05/01/2020
05/01/2020

52 ORDER granting 47 Motion for Leave to File Amici Curiae Brief; granting 50 First Motion for Leave to File Brief of Amicus Curiae. Signed by Senior Judge Norman K. Moon on April 29, 2020. (ca)

53 Reply re 40 Brief / Memorandum in Opposition, 49 Brief / Memorandum in Opposition, 22 First MOTION to Intervene , 23 Brief / Memorandum in Support . filed by Sandy Burchett, Diane Crickenberger, Sheila DeLappe Ferguson. (Henry, Patrick)

54 REPLY to Response to Motion re 28 MOTION to Intervene . filed by Vincent E. Falter, Republican Party of Virginia, Inc., Mildred H. Scott, Thomas N. Turner, Jr.. (Marston, Christopher)

55 ORDER denying 22 First Motion to Intervene by Sheila DeLappe Ferguson, Sandy Burchett, and Diane Crickenberger. Signed by Senior Judge Norman K. Moon on April 29, 2020. (ca)

Minute Entry for telephone conference held before Senior Judge

56

Norman K. Moon: Status Conference held on 4/29/2020. (Court

Reporter: Judy Webb) (al)

ORDER granting in part and denying in part 28 Motion to Intervene

57

by Republican Party of Virginia, Inc., Vincent E. Falter, Mildred H.

Scott, and Thomas N. Turner, Jr. The motion with respect to RPV is

hereby GRANTED; and the motion with respect to Falter, Scott, and

Turner is hereby DENIED. Signed by Senior Judge Norman K.

Moon on April 29, 2020. (ca)

Brief / Memorandum in Opposition re 35 Joint MOTION to Approve

58

Consent Judgment (Partial Consent Judgment and Decree) . filed by

Republican Party of Virginia, Inc.. (Attachments: # 1 Declaration in

Support of Authenticity of Exhibits, # 2 Exhibit A, # 3 Exhibit B,

# 4 Exhibit C)(Marston, Christopher)

MEMORANDUM OPINION re 55 Order. Signed by Senior Judge

59

Norman K. Moon on April 30, 2020. (ca)

60

MEMORANDUM OPINION re 57 Order. Signed by Senior

Judge Norman K. Moon on April 30, 2020. (ca)

61 Reply re 16 MOTION for Preliminary Injunction . filed by Katherine D. Crowley, Erikka Goff, League of Women Voters of Virginia, Seijra Toogood. (Attachments: # 1 Exhibit A - 7th Cong. Dist. Repub. Comm. Verified Complaint, # 2 Exhibit B - RPV Unopposed Mot and Consent Order to Extend Temp Injunction, # 3 Exhibit C Order in Paher v Cegavske)(Rosborough, Davin)

Reply re 35 Joint MOTION to Approve Consent Judgment (Partial

62

Consent Judgment and Decree) . filed by Katherine D. Crowley,

Erikka Goff, League of Women Voters of Virginia, Seijra Toogood.

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05/04/2020 05/04/2020 05/05/2020
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(Attachments: # 1 Exhibit A - ACLU of VA Apr. 15 Ltr to VBOE)(Rosborough, Davin)

63 Proposed Findings of Fact by Republican Party of Virginia, Inc..(Marston, Christopher)

64 Reply in Support of 35 Joint Motion for Entry of Partial Consent Judgment and Decree, ISO Consent Decree filed by Robert H. Brink, Jamilah D. LeCruise, John O'Bannon, Christopher E. Piper, Virginia State Board of Elections. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F)(Kallen, Michelle) (Attachment 1 replaced on 5/1/2020) (ca). Modified on 5/1/2020 - Replaced deficient pdf document with corrected pdf document - Doc. 64-1 (Exhibit A). (ca)

65 NOTICE by Republican Party of Virginia, Inc. re 62

, 64 , 58

of Additional Authority (Attachments: # 1 Exhibit Apr. 14 2020 Order, Seventh Cong. Dist. Repub. Cmte.)(Marston, Christopher)

66 Minute Entry for telephone hearing held before Senior Judge Norman K. Moon: Motion Hearing held on 5/4/2020 re 16 MOTION for Preliminary Injunction filed by Katherine D. Crowley, Seijra Toogood, Erikka Goff, League of Women Voters of Virginia. (Court Reporter: Judy Webb) (al)

67 ORAL ORDER REFERRING MOTIONS: 42 MOTION for Patrick T. Lewis to Appear Pro Hac Vice; and 43 MOTION for E. Mark Braden to Appear Pro Hac Vice. Motions referred to Robert S. Ballou. Entered by Senior Judge Norman K. Moon on May 5, 2020. This Notice of Electronic Filing is the Official ORDER for this entry. No document is attached.(ca)

68 ORDER granting 35 Joint Motion to Approve Consent Judgment. The proposed Partial Consent Judgment and Decree is APPROVED, which shall be attached to, and incorporated in, this Order. Signed by Senior Judge Norman K. Moon on 5/5/2020. (al)

MEMORANDUM OPINION re: 68 Order. Signed by Senior Judge

69

Norman K. Moon on 5/5/2020. (al)

70 ORDER granting 42 MOTION to Appear Pro Hac Vice. Attorney Patrick T. Lewis for Republican Party of Virginia, Inc., Vincent E. Falter, Mildred H. Scott, and Thomas N. Turner, Jr. added. Signed by Magistrate Judge Robert S. Ballou on May 11, 2020. (ca)

71 ORDER granting 43 MOTION to Appear Pro Hac Vice. Attorney E. Mark Braden for Republican Party of Virginia, Inc., Vincent E. Falter, Mildred H. Scott, and Thomas N. Turner, Jr. added. Signed by Magistrate Judge Robert S. Ballou on May 11, 2020. (ca)

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06/15/2020 06/19/2020
06/19/2020

72 ANSWER to Complaint 1 Complaint, by Robert H. Brink, Jamilah D. LeCruise, John O'Bannon, Christopher E. Piper, Virginia State Board of Elections.(Lockerman, Heather)

73 NOTICE by Katherine D. Crowley, Erikka Goff, League of Women Voters of Virginia, Seijra Toogood re 16 Withdrawal of Preliminary Injunction Motion (Rosborough, Davin)

74 PRETRIAL ORDER (CASE REFERRED to Magistrate Judge Robert S. Ballou as set forth herein). Signed by Senior Judge Norman K. Moon on 5/14/2020. (al)

75 NOTICE of Appearance by Calvin Cameron Brown on behalf of Robert H. Brink, Jamilah D. LeCruise, John O'Bannon, Christopher E. Piper, Virginia State Board of Elections (Brown, Calvin)

76 NOTICE of Hearing: (CR) (No Interpreter requested) - Bench Trial set for May 19 - 21, 2021 at 9:30 AM in Lynchburg before Senior Judge Norman K. Moon. Counsel must contact the Clerk's Office no later than five (5) business days before the scheduled trial date for your technology needs. (ca)

77 Rule 26(f) Agreed Written Plan by Plaintiffs Katherine D. Crowley, Erikka Goff, League of Women Voters of Virginia, Seijra Toogood (Rosborough, Davin)

MOTION Drop Plaintiff Erikka Goff as a Party under FRCP 21 by

78

Katherine D. Crowley, Erikka Goff, League of Women Voters of

Virginia, Seijra Toogood. Motions referred to Judge Robert S.

Ballou. (Attachments: # 1 Exhibit A - Amended Complaint)(Agraharkar, Vishal)

79 Brief / Memorandum in Support re 78 MOTION Drop Plaintiff Erikka Goff as a Party under FRCP 21 . filed by Katherine D. Crowley, Erikka Goff, League of Women Voters of Virginia, Seijra Toogood. (Agraharkar, Vishal)

80 ORDER granting 78 Motion to Drop Plaintiff Erikka Goff as a Party Under Fed. R. Civ. P. 21. Erikka Goff shall be removed as a Plaintiff in this lawsuit. Plaintiffs are further granted leave, pursuant to Fed. R. Civ. P. 15(a)(2), to file an Amended Complaint removing Ms. Goff and her claims. Signed by Magistrate Judge Robert S. Ballou on June 19, 2020. (ca)

AMENDED COMPLAINT FOR INJUNCTIVE AND

81

DECLARATORY RELIEF against Virginia State Board of

Elections, Robert H. Brink, John O'Bannon, Jamilah D. LeCruise,

and Christopher E. Piper, filed by League of Women Voters of

Virginia, Katherine D. Crowley, and Seijra Toogood.(ca)

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07/24/2020 07/24/2020 07/24/2020

82 MOTION for Leave to File Second Amended Complaint by Katherine D. Crowley, League of Women Voters of Virginia, Seijra Toogood. Motions referred to Judge Robert S. Ballou. (Attachments: # 1 Exhibit A - proposed Second Amended Complaint)(Rosborough, Davin)

83 ORDER granting 82 Motion for Leave to File Second Amended Complaint. Signed by Magistrate Judge Robert S. Ballou on 7/17/2020. (ams)

SECOND AMENDED COMPLAINT against Robert H. Brink,

84

Jamilah D. LeCruise, John O'Bannon, Christopher E. Piper, Virginia

State Board of Elections, filed by League of Women Voters of

Virginia, Katherine D. Crowley, Seijra Toogood, Tracy Safran, Carol

D. Peterson, Gayle Hardy.(ams)

85 Consent MOTION for Leave to File Excess Pages for Briefing related to Forthcoming Motion for Preliminary Injunction by Katherine D. Crowley, Gayle Hardy, League of Women Voters of Virginia, Carol D. Peterson, Tracy Safran, Seijra Toogood. Motions referred to Judge Robert S. Ballou. (Attachments: # 1 Text of Proposed Order Proposed Order)(Agraharkar, Vishal)

86 Brief / Memorandum in Support re 85 Consent MOTION for Leave to File Excess Pages for Briefing related to Forthcoming Motion for Preliminary Injunction . filed by Katherine D. Crowley, Gayle Hardy, League of Women Voters of Virginia, Carol D. Peterson, Tracy Safran, Seijra Toogood. (Agraharkar, Vishal)

MOTION for Preliminary Injunction by Katherine D. Crowley,

87

Gayle Hardy, League of Women Voters of Virginia, Carol D.

Peterson, Tracy Safran, Seijra Toogood. (Rosborough, Davin)

88

Brief / Memorandum in Support re 87 MOTION for Preliminary

Injunction . filed by Katherine D. Crowley, Gayle Hardy, League of

Women Voters of Virginia, Carol D. Peterson, Tracy Safran, Seijra

Toogood. (Attachments: # 1 Exhibit A - Declaration of Arthur

Reingold, # 2 Exhibit B - Declaration of John Holbein, # 3 Exhibit C

- Declaration of Carol D. Petersen, # 4 Exhibit D - Declaration of

Davin Rosborough, # 5 Exhibit E - Declaration of Rosanna

Bencoach, # 6 Exhibit F - Declaration of Stephanie Iles, # 7 Exhibit

G - Declaration of Seijra Toogood, # 8 Exhibit H - Declaration of

Katherine Crowley, # 9 Exhibit I - Declaration of Gayle Hardy,

# 10 Exhibit J - Declaration of Tracy Safran, # 11 Exhibit K -

Declaration of Debora Wake, # 12 Exhibit L - Declaration of Patricia

McGrady, # 13 Exhibit M - Declaration of Jerome Weingart,

# 14 Exhibit N - Declaration of Karen Kallay, # 15 Exhibit O -

Declaration of Joan Porte, # 16 Exhibit P - Declaration of Carole

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07/31/2020 08/05/2020 08/05/2020
08/05/2020
08/06/2020 08/07/2020

Garrison, # 17 Exhibit Q - Declaration of Laura Lawson, # 18 Exhibit R - Declaration of Eva DeCourcey)(Rosborough, Davin)

ORDER granting 85 Consent Motion for Leave to File Excess Pages.

89

Signed by Magistrate Judge Robert S. Ballou on July 27, 2020. (ca)

90 Minute Entry for proceedings held before Magistrate Judge Robert S. Ballou: Telephone Conference held on 7/29/2020. (lg)

91 ANSWER to 84 Amended Complaint, by Robert H. Brink, Jamilah D. LeCruise, John O'Bannon, Christopher E. Piper, Virginia State Board of Elections.(Lockerman, Heather)

92 NOTICE of TELEPHONIC Hearing on Motion 87 MOTION for Preliminary Injunction (CR) - Telephonic Motion Hearing set for August 14, 2020 at 10:00 AM in Lynchburg before Senior Judge Norman K. Moon. (Parties will receive dial-in instructions via email prior to the hearing)(ca)

93 ANSWER to 84 Amended Complaint, by Republican Party of Virginia, Inc..(Marston, Christopher)

94 Order Setting Expedited Briefing Schedule re 87 MOTION for Preliminary Injunction. Signed by Magistrate Judge Robert S. Ballou on August 5, 2020. (ca)

MOTION to Approve Consent Judgment by Katherine D. Crowley,

95

Gayle Hardy, League of Women Voters of Virginia, Carol D.

Peterson, Tracy Safran, Seijra Toogood. (Attachments: # 1

Exhibit A - proposed Partial Consent Judgment and Decree)(Rosborough, Davin)

96 Joint Brief / Memorandum in Support re 95 MOTION to Approve Consent Judgment . filed by Katherine D. Crowley, Gayle Hardy, League of Women Voters of Virginia, Carol D. Peterson, Tracy Safran, Seijra Toogood. (Attachments: # 1 Exhibit A - RPV fundraising email, # 2 Exhibit B - RPV Tweet re Lawsuit)(Rosborough, Davin)

97 Joint MOTION to Expedite Consent Decree Briefing Schedule by Katherine D. Crowley, Gayle Hardy, League of Women Voters of Virginia, Carol D. Peterson, Tracy Safran, Seijra Toogood. Motions referred to Judge Robert S. Ballou. (Rosborough, Davin)

ORDER granting 97 Joint Motion to Expedite Consent Decree

98

Briefing Schedule. The briefing schedule supersedes that which was

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issued by Order of the Court on August 5, 2020, Dkt. 94 . Signed by Senior Judge Norman K. Moon on 8/7/2020. (al)

99 Brief / Memorandum in Opposition re 87

MOTION for

Preliminary Injunction , 95 MOTION to Approve Consent Judgment . filed by Republican Party of Virginia, Inc.. (Attachments: # 1 Exhibit Strach Declaration)(Marston, Christopher)
100 Reply re 95 MOTION to Approve Consent Judgment [Joint Reply]. filed by Katherine D. Crowley, Gayle Hardy, League of Women Voters of Virginia, Carol D. Peterson, Tracy Safran, Seijra Toogood. (Rosborough, Davin)
101 Minute Entry for telephonic Motions hearing held before Senior Judge Norman K. Moon: Motions Hearing held on 8/14/2020 re 87

MOTION for Preliminary Injunction filed by Gayle Hardy, Katherine D. Crowley, Tracy Safran, Carol D. Peterson, Seijra

Toogood, League of Women Voters of Virginia, 95 MOTION to Approve Consent Judgment filed by Gayle Hardy, Katherine D. Crowley, Tracy Safran, Carol D. Peterson, Seijra Toogood, League of Women Voters of Virginia. (Court Reporter: Donna Prather) (al)
102 Reply re 87 MOTION for Preliminary Injunction . filed by Katherine D. Crowley, Gayle Hardy, League of Women Voters of Virginia, Carol D. Peterson, Tracy Safran, Seijra Toogood. (Attachments: # 1 Declaration in Support of Davin Rosborough and attached exhibits)(Rosborough, Davin)
103 Proposed Findings of Fact by Katherine D. Crowley, Gayle Hardy, League of Women Voters of Virginia, Carol D. Peterson, Republican Party of Virginia, Inc., Tracy Safran, Seijra Toogood.(Rosborough, Davin)
104 Proposed Findings of Fact by Katherine D. Crowley, Gayle Hardy, League of Women Voters of Virginia, Carol D. Peterson, Tracy Safran, Seijra Toogood.(Rosborough, Davin)
105 Proposed Findings of Fact by Republican Party of Virginia, Inc.. (Attachments: # 1 Exhibit Governor's Press Release, # 2 Exhibit Governor's Budget Amendment)(Marston, Christopher)
106 Proposed Findings of Fact by Robert H. Brink, Jamilah D. LeCruise, John O'Bannon, Christopher E. Piper, Virginia State Board of Elections.(Brown, Calvin)

08/20/2020
08/20/2020 08/21/2020 08/21/2020

107 Order to Respond re 95 MOTION to Approve Consent Judgment . The Plaintiffs and State Defendants in this case are hereby ORDERED to file a joint memorandum to clarify whether their proposed partial consent decree, Dkt. 95-1, is intended to apply to only the November 3, 2020 General Election, to the exclusion of the Special Elections and statewide ballot measures appearing on the ballot on that date. Responses due by 8/21/2020Signed by Senior Judge Norman K. Moon on 8/20/2020. (al)

108 Brief/Memorandum in Support of Consent Decree Addendum. filed by Katherine D. Crowley, Gayle Hardy, League of Women Voters of Virginia, Carol D. Peterson, Tracy Safran, Seijra Toogood. (Attachments: # 1 Exhibit A - Addendum to Proposed Partial Consent Judgment and Decree)(Rosborough, Davin)

MEMORANDUM OPINION. Signed by Senior Judge Norman K.

109

Moon on August 21, 2020. (ca)

110

ORDER GRANTING 95 Motion to Approve Consent

Judgment, and APPROVING the proposed Partial Consent Judgment

and Decree (Dkt. 95-1), as supplemented by Plaintiffs and State

Defendants' Addendum to the Proposed Partial Consent Judgment

and Decree (Dkt. 108-1). Signed by Senior Judge Norman K. Moon

on August 21, 2020. (Attachments: # 1 Partial Consent

09/02/2020

Judgment and Decree, # 2 Addendum to Partial Consent Judgment and Decree) (ca)
111 NOTICE by Katherine D. Crowley, Gayle Hardy, League of Women Voters of Virginia, Carol D. Peterson, Tracy Safran, Seijra Toogood

re 87 Withdrawal of Motion for Preliminary Injunction (Rosborough, Davin)

 </s> Case 6:20-cv-00024-NKM Document 1 Filed 04/17/20 Page 1 of 34 Pageid#: 1

UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA
Lynchburg Division

4/17/2020

LEAGUE OF WOMEN VOTERS OF

VIRGINIA;

KATHERINE

D.

CROWLEY; ERIKKA GOFF; and

SEIJRA TOOGOOD,

Plaintiffs,

v.

VIRGINIA STATE BOARD OF ELECTIONS; ROBERT H. BRINK, JOHN O’BANNON, and JAMILAH D. LECRUISE, in their official capacities as Chairman, Vice-Chair, and Secretary of the Virginia State Board of Elections, respectively; and CHRISTOPHER E. PIPER, in his official capacity as Commissioner of the Virginia Department of Elections,

Defendants.

Case No.: 6:20CV00024
COMPLAINT FOR INJUNCTIVE AND DECLARATORY RELIEF

1. Virginia Attorney General Mark Herring recently said that “[f]ree and fair elections are at the core of our democracy and no Virginian should have to choose between their health and exercising their right to vote.”1 Plaintiffs League of Women Voters of Virginia, Katherine Crowley, Seijra Toogood, and Erikka Goff agree. Yet Virginia’s requirement that each voter submitting a mail absentee ballot have another individual witness and sign their ballot

1 Press Release, Ralph Northam, Governor of Virginia, Governor Northam Announces Plans to Postpone Upcoming Virginia Elections in Response to COVID-19 (Apr. 8, 2020), https://www.governor.virginia.gov/newsroom/allreleases/2020/april/headline-855995-en.html.

Case 6:20-cv-00024-NKM Document 1 Filed 04/17/20 Page 2 of 34 Pageid#: 2
envelope does exactly that: presents tens of thousands of Virginia voters like Plaintiffs with the Hobson’s choice of either risking their health to vote or not voting at all.
2. Plaintiffs therefore bring this action challenging the constitutionality of Virginia’s witness requirement on absentee ballots to preserve their and many other Virginians’ fundamental right to vote in the midst of the pandemic of a respiratory disease known as the coronavirus disease 2019 (“COVID-19”), caused by the spread of a novel coronavirus, SARSCoV-2. Without relief, the extreme burden the witness requirement places on voters in the current environment far outweighs any marginal benefit to the Commonwealth in retaining it.
3. The “United States is now the ‘epicenter’ of the global pandemic and has far more confirmed COVID-19 cases than any other nation.”2 The Centers for Disease Control and Prevention (“CDC”) and the Virginia Department of Health have both urged people to avoid coming within six feet of individuals with whom they do not reside, as a key to both slowing the spread of the virus and keeping individuals healthy. As such, Governor Ralph Northam has ordered that all Virginians remain at home except for the basic necessities through at least June 10, 2020.3
4. In the midst of this crisis and especially during a stay-at-home mandate, Virginia’s requirement that every individual filling out an absentee ballot find another adult to witness their filling out of the ballot and sign on their ballot envelope alongside the voter’s own signed attestation amounts to an unconstitutional burden on the right to vote. This is certainly true for
2 General Order No. 2020-11, In re: Court Operations Under the Exigent Circumstances Created by the Outbreak of Coronavirus Disease (COVID-19): Temporary Policy for Remote Proceedings and Public Access to Such Proceedings (hereinafter “In re Court Operations”), Case No. 2:20mc7 (E.D. Va. Apr. 6, 2020). 3 See Va. Executive Order No. 2020-55, https://www.governor.virginia.gov/media/governorvirginiagov/executiveactions/EO-55-Temporary-Stay-at-Home-Order-Due-to-Novel-Coronavirus-(COVID-19).pdf
2

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Virginia’s federal office primaries in June, and will likely be true for voting in the November general election as well.
5. The COVID-19 outbreak means that the witness requirement will disenfranchise many thousands of Virginians like the individual Plaintiffs who cannot risk contact with other individuals to vote in person or obtain a witness signature on their absentee ballot. Over a quarter of Virginians age 18 and over live by themselves, and almost a third of Virginians over 65 years of age—one of the groups most vulnerable to COVID-19—live alone.4 And the impact of this requirement will also fall more heavily on Virginians with disabilities and African Americans, who both live alone in larger percentages than the population as a whole.5
6. The witness requirement mostly directly and disproportionately harms African Americans during the COVID-19 pandemic, though, because they face greater rates of severe health complications and death from COVID-19. Virginia’s history of voting-related discrimination against African Americans, as well as continuing discrimination in areas such as education, employment, and health, interacts with the witness requirement to hinder their ability to participate effectively in the political process in violation of Section 2 of the Voting Rights Act.
7. Over half a million Virginians cast ballots in the June 2018 Democratic and Republican primaries, and over 3.98 million Virginians cast ballots in the November 2016 general election. The Virginians who live alone and would have otherwise voted in the upcoming elections but will not, or those whose absentee ballots will be rejected, will therefore likely
4 2018 Current Population Survey, U.S. Census Bureau, statistics accessed by using the Census Bureau Current Population Survey Table Creator tool at https://www.census.gov/cps/data/cpstablecreator.html. 5 Id.
3

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number in the tens of thousands, if not hundreds of thousands, given the likely explosion of voting by mail this year.
8. The witness requirement is not worth this massive disenfranchisement of Virginia voters and its disproportionate harm to elderly voters, African American voters, and voters with disabilities. While election integrity is an important interest, the witness requirement does very little if anything—and it is certainly not narrowly tailored—to serve this interest in light of the many other provisions of Virginia law that safeguard absentee voting and penalize those who abuse the process. The fact that Virginia is one of only 11 states that require an individual submitting an absentee ballot to have a witness sign their ballot envelope further underscores the requirement’s lack of necessity. Regardless, whatever additional marginal benefits the witness requirement may offer, such benefit is greatly outweighed by the risk of disenfranchisement. The lack of an opportunity to cure a missing witness signature further compounds the burden.
9. Plaintiffs therefore ask that the Court enjoin Virginia’s absentee witness requirement and declare it unconstitutional and in violation of Section 2 of the Voting Rights Act for this year’s elections.
PARTIES 10. Plaintiff Katherine D. Crowley is a resident of Lexington, Virginia, where she is a registered voter. She has been a Virginia registered voter for many years and has consistently voted in both state and federal elections. She lives in Virginia’s Sixth congressional district, where there is no congressional primary this year, but she intends to vote in the November 2020 general election. 11. Because of the COVID-19 outbreak, Ms. Crowley does not feel safe voting in person for the November election if COVID-19 community transmission persists or recurs
4

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during that time frame. She would request an absentee ballot, but she lives by herself and does not feel safe finding an individual to witness and sign her absentee ballot envelope so she will not be able to vote in the November election or have her vote counted if the witness requirement remains in place. This is because she not only intends to follow any stay-at-home order if in place and practice social distancing if needed, but also because she has a previous medical diagnosis that she is concerned may put her at a higher risk for contracting COVID-19 and facing heightened medical consequences if she does. If the witness requirement is lifted, she will vote by absentee ballot in the November general election should COVID-19 transmission present a risk to her health at that point.
12. Plaintiff Seijra Toogood is a resident of Fairfax, Virginia, where she is a registered voter. She has been a Virginia registered voter for many years and has consistently voted in both state and federal elections. She lives in Virginia’s Eleventh congressional district and would like to vote in the June 23, 2020 primary election being held for that district.
13. Because of the COVID-19 outbreak, Ms. Toogood does not feel safe voting in person during the race. She has requested an absentee ballot, but she lives by herself and does not feel safe finding an individual to witness and sign her absentee ballot envelope so she will not be able to vote in the June primary or have her vote counted if the witness requirement remains in place. This is because she is not only following the Governor’s stay-at-home order and practicing social distancing, but also because she has underlying heart and respiratory issues that put her at a higher risk for contracting COVID-19 and facing serious medical consequences if she does. Similarly, if COVID-19 community transmission either persists or resurges around the time of the November general election, she will not be able to vote or have her vote counted if the witness requirement remains in place. If the witness requirement is lifted, she will vote by
5

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absentee ballot in the June primary, as well as in the November general election should COVID19 transmission present a risk to her health at that point. As an African-American Virginian, Ms. Toogood is also aware of the ongoing history of voting, economic, and health discrimination against African Americans in Virginia, and believes the witness requirement perpetuates and worsens this discrimination.
14. Plaintiff Erikka Goff is a resident of Scottsville, Virginia, where she is a registered voter. She has been a registered voter since she was old enough to vote and has consistently voted in both state and federal elections. Ms. Goff generally votes in person but because of the COVID-19 outbreak, Ms. Goff sought an absentee ballot to vote by mail in her local Scottsville Town Election currently set to be held on May 5, 2020.6 Ms. Goff received her ballot on March 27, 2020, at which point she realized that she would not be able to complete the witness signature requirement without violating social distancing guidelines that she had been following for several weeks. On March 30—the same day Governor Northam held a press conference announcing a stay-at-home order—she raised her concerns regarding the witness signature requirement to her local registrar, who suggested she call the Department of Elections. Ms. Goff requested a callback on the automated phone system of the Department of Elections but has not heard back.
15. Because of the COVID-19 outbreak, Ms. Goff does not feel safe voting in person during the May or June elections. She has an absentee ballot for the May election and intends to vote an absentee ballot by mail in the Democratic primary for the Fifth congressional district in
6 On April 8, 2020, Governor Northam requested that the General Assembly move the May 5, 2020 elections to coincide with the November 3, 2020 General Election date. As of the filing of this complaint, the General Assembly has not acted upon this request and absentee balloting is currently continuing for the May 5 election.
6

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June, but she lives by herself and does not feel safe finding an individual to witness and sign her absentee ballot envelope. As a result, she will not be able to vote in either the May or June elections or have her votes counted if the witness signature requirement remains in place. This is because she is following the Governor’s stay-at-home order and practicing social distancing to avoid putting herself at risk of developing COVID-19 and facing serious medical consequences if she does. Similarly, if COVID-19 community transmission either persists or resurges around the time of the November general election, she will not be able to vote or have her vote counted if the witness signature requirement remains in place. If the witness signature requirement is lifted, she will vote by absentee ballot in the June primary (and May primary if held), as well as in the November general election should COVID-19 transmission present a risk to her health at that point.
16. Plaintiff League of Women Voters of Virginia (“the League”) is a nonprofit, nonpartisan membership organization that was founded in 1920. Its principal address is 1011 E. Main Street, Ste. 214A, Richmond, VA 23219.
17. The League works to encourage informed and active participation in government and influence public policy through education and advocacy. The League supports full voting and representational rights for all eligible Commonwealth citizens and promotes policies that encourage voter participation. The League has nearly 2,000 members across Virginia, some of whom live alone and are vulnerable to becoming severely ill from COVID-19 because they are elderly and/or have underlying health conditions. Certain of these members will seek to vote absentee in upcoming elections but will be unable to comply with the witness requirement without placing their own health at risk.
7

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18. The League regularly conducts voter registration and get-out-the-vote activities for thousands of voters across the state, and in recent weeks it has been advocating through letters and calls to state officials for expanded use of voting by mail, absentee voting by mail and elimination of the witness requirement in order to better protect the health of voters and poll workers during the COVID-19 outbreak. The League anticipates that it will have to divert additional resources from its regular activities to advocate for lifting the requirement and to conduct outreach to its members and the voters they serve to ensure they understand and can find ways to comply with the requirements if possible.
19. Defendant Virginia State Board of Elections (the “Board”) is the regulatory authority authorized to make rules and regulations that, consistent with election laws, govern the work of local electoral boards, general registrars, and officers of election in properly administering elections in Virginia. Through the Department of Elections, it is also responsible for supervising and coordinating the work of the county and city electoral boards and registrars to ensure uniformity in their practices, as well as ensuring that electoral boards and general registrars are properly trained to carry out their duties. The Board also prescribes forms for voter registration and elections. See Va. Code § 24.2-103(a); Va. Code § 24.2-105. The Board sets standards that “tightly regulate[]” the “form of ballots used in Virginia elections.” Marcellus v. State Bd. of Elections, 849 F.3d 169, 172 (4th Cir. 2017).
20. Defendant Robert H. Brink is the Chairman of the Virginia Board of Elections. As Chairman, he is responsible for presiding over Board meetings and performing the functions of a presiding officer. As a member of the Board, he is also one of three individuals responsible for the actions of the Board. 1 Va. Admin. Code 20-20-30. He is sued in his official capacity.
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21. Defendant John O’Bannon is the Vice-Chair of the Virginia Board of Elections. As Vice-Chair, he is responsible for performing the Board Chairman’s duties in the Chairman’s absence. As a member of the Board, he is also one of three individuals responsible for the actions of the Board. 1 Va. Admin. Code 20-20-30. He is sued in his official capacity.
22. Defendant Jamilah D. Lecruise is the Secretary of the Virginia Board of Elections. As Secretary, she is “authorized to do all things necessary to the proper execution of the law creating and governing the board and in the performance of the duties imposed upon it” so long as they are not such as they can only be performed “by the board in its corporate capacity.” 1 Va. Admin. Code 20-20-30. She also has the “authority to conduct the board’s administrative and programmatic operations and to discharge the board’s duties consistent with specific delegations of authority.” 1 Va. Admin. Code 20-20-60. As a member of the Board, she is also one of three individuals responsible for the actions of the Board. She is sued in her official capacity.
23. Defendant Christopher E. Piper is the Commissioner of the Virginia Department of Elections (the “Department”). The Department conducts the Board’s administrative and programmatic activities and discharges the Board’s duties within its delegated authority. The Department is also responsible for administering and maintaining the Commonwealth’s voter registration system and overseeing registered voter list maintenance, and for providing electronic applications for voter registration and absentee ballots. As Commissioner, Defendant Piper is responsible for overseeing the day-to-day operations of the Department. He also has powers “to designate alternative methods and procedures to handle” absentee applications and ballots “in the case of an emergency that will not allow sufficient time for the distribution and handling of absentee ballot applications and absentee ballots . . . for qualified voters who are unable to vote in person because of the emergency.” Va. Code § 24.2-713. He is sued in his official capacity.
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JURSIDICTION AND VENUE 24. This action arises under the First and Fourteenth Amendments to the U.S. Constitution as well as Section 2 of the Voting Rights Act, and is brought under 42 U.S.C. §§ 1983 and 1988 and authorized under 52 U.S.C. § 10302 to seek injunctive and declaratory relief for violations of constitutional and statutory rights under color of state law. This Court therefore has subject matter jurisdiction under 28 U.S.C. §§ 1331 and 1343. 25. This Court has personal jurisdiction over Defendants because each is either a state agency or sued in their official capacity as a state official, and the violations complained of concern their conduct in such capacities. 26. Declaratory relief is authorized by 28 U.S.C. §§ 2201 and 2202. 27. Venue in the Western District of Virginia is proper based on 28 U.S.C. § 1391(b)(2) because a substantial part of the events that gave rise to Plaintiffs’ claims occurred or will occur there, including concerning Plaintiffs Crowley (City of Lexington) and Goff (Albemarle County) who reside there.
FACTS Transmission of COVID-19 and Public Health Guidelines
28. The novel coronavirus, SARS-CoV-2, is the virus that causes COVID-19, a deadly disease that is now a global pandemic.7
7 Betsy McKay et al., Coronavirus Declared Pandemic by World Health Organization, WALL ST. J. (Mar. 11, 2020, 11:59 PM), https://www.wsj.com/articles/u-s-coronavirus-cases-top-1-000-11583917794.
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29. According to the CDC, this coronavirus spreads aggressively and asymptomatic people can spread it.8 All age groups have contracted the disease.9 There is no vaccine, and there is no cure.
30. As of early April, the United States led the world in the total number of COVID19 cases, surpassing even China and Italy before spread of the virus has even peaked. As many as 240,000 people in the United States may die from COVID-19 during the current outbreak, even accounting for existing governmental and public health interventions.10
31. The World Health Organization (“WHO”) estimates that approximately 20 percent of those infected by SARS-CoV-2 require hospitalization.11 This is because COVID-19 can severely damage lung tissue, cause a permanent loss of respiratory capacity, and also damage tissues in the kidney, heart, and liver.12
32. Despite some initial comparisons to seasonal influenza, estimates from early March put the fatality rate for people infected with COVID-19 at approximately ten times higher than even a severe flu season, including in countries with advanced health care systems.13
8 Centers for Disease Control and Prevention, How Coronavirus Spreads, https://www.cdc.gov/coronavirus/2019ncov/prevent-getting-sick/how-covid-spreads.html (last visited Apr. 15, 2020). 9 Robert Verity, PhD., et al., Estimates of the Severity of Coronavirus Disease 2019: A Model-Based Analysis, Lancet Infec Dis (March 30, 2020), 6. 10 Rick Noack, et al., White House Task Force Projects 100,000 to 240,000 Deaths in U.S., Even With Mitigation Efforts, WASH. POST (April 1, 2020, 12:02 am), https://www.washingtonpost.com/world/2020/03/31/coronaviruslatest-news/. 11 World Health Organization, Q&A on Coronaviruses (COVID-19), “Should I Worry About COVID-19?,” https://www.who.int/news-room/q-a-detail/q-a-coronaviruses. 12 Centers for Disease Control and Prevention, Interim Clinical Guidance for Management of Patients with Confirmed Coronavirus Disease (COVID-19), https://www.cdc.gov/coronavirus/2019-ncov/hcp/clinical-guidancemanagement-patients.html (last visited Apr. 15, 2020). 13 Betsy McKay, Coronavirus vs. Flu Which Virus is Deadlier, WALL ST. J. (Mar. 10, 2020, 12:49 PM), https://www.wsj.com/articles/coronavirus-vs-flu-which-virus-is-deadlier-11583856879.
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33. While people of all ages have contracted and died from COVID-19, it is particularly fatal for older individuals. Preliminary reports based on WHO data show a 3.6% mortality rate for individuals between 60-69 years old, an 8% mortality rate for those 70-79 years old, and a 14.8% mortality rate for those who are 80 years old or older.14 COVID-19 also poses greater risks for people with preexisting heart and respiratory conditions, individuals with compromised immune systems, and those with many other conditions.15
34. The effects of the pandemic on social life will last well into the summer of 2020, if not much longer. While there is some reason to believe that transmission may taper somewhat in the summer months, experts have indicated that COVID-19 “will face less immunity and thus transmit more readily even outside of the winter season,” and that season changes are “unlikely to stop transmission.”16 Further, even those who develop an immune response to the virus after an infection are not necessarily safe from reinfection, as we do not yet have sufficient data about how long immunity to the virus will last.17 This week, Dr. Anthony Fauci, head of the National
14 Centers for Disease Control and Prevention, Interim Clinical Guidance for Management of Patients with Confirmed Coronavirus Disease (COVID-19), https://www.cdc.gov/coronavirus/2019-ncov/hcp/clinical-guidancemanagement-patients.html (last visited Apr. 15, 2020). 15 Centers for Disease Control and Prevention, Groups at Higher Risk of Severe Illness, https://www.cdc.gov/coronavirus/2019-ncov/need-extra-precautions/groups-at-higher-risk.html (last visited Apr. 15, 2020). 16 Marc Lipsitch, DPhil, Professor of Epidemiology and Director, Center for Communicable Disease Dynamics, Harvard T.H. Chan School of Public Health, Seasonality of SARS-CoV-2: Will COVID-19 go away on its own in warmer weather?, https://ccdd.hsph.harvard.edu/will-covid-19-go-away-on-its-own-in-warmer-weather/. 17 Apoorva Mandavilli and Katie Thomas, Will an Antibody Test Allow Us to Go Back to School or Work?, N.Y. TIMES (Apr. 11, 2020), https://www.nytimes.com/2020/04/10/health/coronavirus-antibody-test.html
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Institute of Allergy and Infectious Diseases, said that he “can’t guarantee” in-person voting will be safe in November, because of a potential resurgence of COVID-19 in the fall.18
35. Because there is no vaccine, social distancing measures, including maintaining at least six feet of space between people (as well as consistent hygiene practices), are the only known effective measures for protecting against transmission of COVID-19.19 The CDC has issued guidance informing individuals to avoid public gatherings until at least May 15, 2020.
36. For this reason, the CDC has issued specific guidelines concerning voting during the COVID-19 pandemic. Among other things, it recommends that states “[e]ncourage voters to use voting methods that minimize direct contact with other people and reduce crowd size at polling stations” including “mail-in methods of voting if allowed in the jurisdiction.”20
37. These recommendations make sense, given the relative risks of voting in person during the pandemic versus voting by mail. There is no evidence that SARS-CoV-2 can be spread through the mail, and the U.S. Postal Service has further changed their policies to “eliminate the requirement that customers sign our Mobile Delivery Devices for delivery” and
18 Jason Silverstein, Fauci says he “can’t guarantee” in-person voting in November will be safe, CBSNews.com (Apr. 13, 2020), https://www.cbsnews.com/news/coronavirus-fauci-says-he-cant-guarantee-in-person-voting-innovember-will-be-safe/?ftag=CNM-00-10aac3a. 19 Johns Hopkins University, Coronavirus, Social Distancing and Self-Quarantine, https://www.hopkinsmedicine.org/health/conditions-and-diseases/coronavirus/coronavirus-social-distancing-andself-quarantine (last visited Apr. 15, 2020); Declaration of Dr. Jonathan Louis Golob at ¶ 8, ECF No. 5, Dawson v. Asher, 2:20-cv-00409-JLRMAT (W.D. Wash. Mar. 16, 2020). 20 Centers for Disease Control & Prevention, Recommendations for Election Polling Locations: Interim guidance to prevent spread of coronavirus disease 2019 (COVID-19) (updated Mar. 27, 2020), https://www.cdc.gov/coronavirus/2019-ncov/community/election-polling-locations.html.
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now require the customer “to step back a safe distance or close the screen door/door so that they may leave the item in the mail receptacle or appropriate location by the customer door.”21
38. In contrast, the risks of interpersonal interaction while voting have already borne
out unfortunate results. In Illinois, a person who worked at a Chicago polling place during the March 17 primary died from COVID-19,22 while another tested positive after voting in person.23
And during Florida’s recent primary, two Broward County poll workers tested positive for
COVID-19, one of whom was handling driver’s licenses as part of the identification verification process.24
39. In Milwaukee and Green Bay, Wisconsin, voters experienced multi-hour waits
and lines stretching blocks upon blocks because government officials there were unable to create a viable vote-by-mail process for all voters.25 These are the opposite of constitutionally
21 United States Postal Service. USPS Statement on Coronavirus (Apr. 2, 2020), https://about.usps.com/newsroom/statements/usps-statement-on-coronavirus.htm (citing guidance from World Health Organization, CDC, and Surgeon General) 22 Mary Ann Ahern, Poll Worker at Chicago Voting Site Dies of Coronavirus, Election Officials Say, NBC CHICAGO (Apr. 13, 2020, 10:59 AM), https://www.nbcchicago.com/news/local/chicago-politics/poll-worker-at-chicagovoting-site-dies-of-coronavirus-election-officials-say/2255072/. 23 Gov. Pritzker Encourages Illinoisans to Vote by Mail After In-Person Voter Tests Positive for Coronavirus, NBC CHICAGO (Apr. 12, 2020, 6:07 PM), https://www.nbcchicago.com/news/local/gov-pritzker-encourages-illinoisansto-vote-by-mail-in-upcoming-general-election/2254687/.. 24 Anthony Man, Two Broward poll workers, including one who handled voters’ driver licenses, test positive for coronavirus, S. FLA. SUN SENTINEL (Mar. 26, 2020), https://www.sun-sentinel.com/coronavirus/fl-ne-browardelections-poll-workers-coronavirus-20200326-wmgy775dvjc5jis2oagxlpmule-story.html. 25 Parker Schorr, Wisconsin’s pandemic election: Long waits, face masks as voters go to polls, THE CAP TIMES (Apr. 8, 2020), https://madison.com/ct/news/local/govt-and-politics/wisconsin-s-pandemic-election-long-waits-facemasks-as-voters-go-to-polls/article_bfd2c391-f390-5364-8c14-a88b548fe017.html; Benjamin Swasey, Wisconsin Vote Ends As Trump Blames Governor For Long Lines, NPR (Apr. 7, 2020 12:23 PM), https://www.npr.org/2020/04/07/828835153/long-lines-masks-and-plexiglas-barriers-greet-wisconsin-voters-atpolls.
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appropriate conditions called for in an infectious disease pandemic.26 Virginia must not emulate them. COVID-19 in Virginia
40. Virginia faces a steadily rising number of COVID-19 cases. As of March 31, the Virginia Department of Health (“VDH”) was reporting “widespread community transmission across the state.”27 And as of April 16, VDH reported 6,889 COVID-19 diagnoses in Virginia, resulting in 1,114 hospitalizations and 208 deaths.28 Moreover, as of late March, “Virginia’s fatality rate, based on the number of known cases, is relatively higher than many other states” and “insufficiency of current testing suggests the likelihood that COVID-19 is substantially more widespread in Virginia than it appears from the official numbers.”29 Tragically, one of the nation’s deadliest COVID-19 outbreaks appears to have occurred at an assisted living center in Richmond, where at least 45 residents have died and around 80 percent have been diagnosed as positive.30
41. VDH has “urge[d] all Virginians to stay home and practice social distancing. If you have to go out for critical things like grocery shopping or medical care, stay at least 6 feet
26 Devi Shastri, In-person voting was likely a ‘disaster’ for Wisconsin’s efforts to flatten coronavirus curve, national experts say, MILWAUKEE JOURNAL SENTINEL (Apr. 8, 4:51 PM), https://www.jsonline.com/story/news/politics/elections/2020/04/08/coronavirus-wisconsin-election-likely-hurteffort-flatten-curve/2961718001/. 27 Va. Dep’t of Health, COVID-19 Cases in Virginia, http://www.vdh.virginia.gov/coronavirus/ (last visited Apr. 16, 2020). 28 Id. 29 In re Extension to Modifications of Ct. Operations: S. to Gen. Orders 2020-02 and 2020-03, No. 2:20MC7, 2020 WL 1441770, at *1 (E.D. Va. Mar. 24, 2020). 30 Danielle Ivory, et al., N.Y. TIMES, Coronavirus Outbreak at Virginia Nursing Home Spirals Out of Control as 45 Die (Apr. 14, 2020), https://www.nytimes.com/2020/04/14/us/coronavirus-nursing-homes.html.
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away from others.”31 It has also adopted “Guiding Principles for Community Mitigation Strategies” based on similar CDC guidance. Among these principles are considering “all aspects of a community that might be impacted, including populations most vulnerable to severe illness and those that may be more impacted socially or economically, and select appropriate actions,” and identifying “ways to ensure the safety and social well-being of groups that may be especially impacted by mitigation strategies, including individuals at increased risk for severe illness.”32
42. Since early March, Governor Northam has also taken a series of increasingly aggressive actions in response to the growing threat posed by the virus, including an emergency declaration and numerous executive orders.
43. Notably, on March 12, 2020, invoking his statutory and Virginia constitutional authority, Governor Northam declared a State of Emergency for Virginia “to continue to prepare and coordinate our response to the potential spread of COVID-19, a communicable disease of public health threat.”33
44. On March 13, he closed all Virginia K-12 schools for a minimum of two weeks, and eventually extended that order for the remainder of the academic year.34
31 Id. 32 Virginia Department of Health, Schools, Workplaces & Community Locations, http://www.vdh.virginia.gov/coronavirus/schools-workplaces-community-locations/ (last visited Apr. 15, 2020). 33 Va. Exec. Order No. 2020-51 (Mar. 12, 2020), https://www.governor.virginia.gov/media/governorvirginiagov/governor-of-virginia/pdf/eo/EO-51-Declaration-of-aState-of-Emergency-Due-to-Novel-Coronavirus-(COVID-19).pdf. 34 Press Release, Ralph Northam, Governor of Virginia, Governor Northam Orders All Virginia K-12 Schools Closed for Minimum of Two Weeks (Mar. 13, 2020), https://www.governor.virginia.gov/newsroom/allreleases/2020/march/headline-854442-en.html; Press Release, Ralph Northam, Governor of Virginia, Governor Northam Orders Statewide Closure of Certain Non-Essential Businesses, K-12 Schools (Mar. 23, 2020), https://www.governor.virginia.gov/newsroom/all-releases/2020/march/headline-855292-en.html.
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45. Governor Northam advised on March 17 that Virginians “with chronic health conditions or aged 65 or older should self-quarantine,” and ordered all DMV offices closed.35 He also requested and the Supreme Court of Virginia granted a suspension of “non-emergency court proceedings in all district and circuit courts” absent specific exceptions through April 6, and extended and tolled non-exempted court deadlines for 21 days.36
46. On March 23, Governor Northam ordered all non-essential businesses closed until at least April 23 and banned public gatherings of more than 10 people.37
47. On March 30, Governor Northam issued a statewide “Stay at Home” order to last at least until June 10, directing all Virginians to stay at home except under extremely limited circumstances. He added: “We are in a public health crisis, and we need everyone to take this seriously and act responsibly. Our message to Virginians is clear: stay home. We know this virus spreads primarily through human-to-human contact, and that’s why it’s so important that people follow this order and practice social distancing.”38
35 Press Release, Ralph Northam, Governor of Virginia, Governor Northam Announces New Measures to Combat COVID-19 and Support Impacted Virginians (Mar. 17, 2020), https://www.governor.virginia.gov/newsroom/allreleases/2020/march/headline-854487-en.html. 36 Id. 37 Press Release, Ralph Northam, Governor of Virginia, Governor Northam Orders Statewide Closure of Certain Non-Essential Businesses, K-12 Schools (Mar. 23, 2020), https://www.governor.virginia.gov/newsroom/allreleases/2020/march/headline-855292-en.html. 38 Va. Exec. Order No. 2020-55 (Mar. 30, 2020), https://www.governor.virginia.gov/media/governorvirginiagov/executive-actions/EO-55-Temporary-Stay-at-HomeOrder-Due-to-Novel-Coronavirus-(COVID-19).pdf; Press Release, Ralph Northam, Governor of Virginia, Governor Northam Issues Statewide Stay at Home Order (Mar. 30, 2020), https://www.governor.virginia.gov/newsroom/allreleases/2020/march/headline-855702-en.html (emphasis added).
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48. Virginia received a Major Disaster Declaration from the federal government on April 2.39
49. Just this week, researchers at the University of Virginia projected that COVID-19 cases in Virginia may not peak until mid-August.40
50. Faced with local elections in some parts of Virginia scheduled for May, and a primary for federal races in June, both the Governor and Elections Department have begun to take some steps in recognition of the dual priorities of public health and representative government.
51. For one, the Virginia Department of Elections has issued guidance that all registered Virginia voters may vote absentee by mail in the June primary (and May elections if they go forward) due to the COVID-19 outbreak by selecting reason “2A My disability or illness” on the ballot application.41 Defendants have further encouraged Virginians to use this option, with the Department of Elections “encourag[ing] voters to protect their health during COVID-19 outbreak,” and noting that absentee voting for the upcoming elections “is strongly encouraged.”42
39 Press Release, Ralph Northam, Governor of Virginia, Virginia Receives Major Disaster Declaration from Federal Government for COVID-19 (Apr. 2, 2020), https://www.governor.virginia.gov/newsroom/allreleases/2020/april/headline-855921-en.html. 40 Mel Leonor & Justin Mattingly, UVA researchers project mid-August peak for new COVID-19 cases in Virginia, RICHMOND TIMES DISPATCH (Apr. 13, 2020), https://www.richmond.com/special-report/coronavirus/uvaresearchers-project-mid-august-peak-for-new-covid-19-cases-in-virginia/article_c4e2c008-1617-52d8-ad08706abfb3d696.html. 41 Va. Dep’t of Elections (@vaELECT), Twitter (Mar. 23, 2020, 8:34 AM), https://twitter.com/vaELECT/status/1242067184521748480; Va. Dep’t of Elections, Absentee Ballots, https://www.elections.virginia.gov/casting-a-ballot/absentee-voting/. 42 Va. Dep’t of Elections, Absentee Ballots, https://www.elections.virginia.gov/casting-a-ballot/absentee-voting/ (last visited Apr. 15, 2020).
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52. On April 8, Governor Northam exercised his statutory authority to move the June primary elections from June 9, 2020, to June 23, 2020, and requested that General Assembly move the May General Election and all special elections scheduled for May 5, 2020 to the November 3, 2020 General Election. He took these actions “to further mitigate the spread of COVID-19,” and for purposes of “protecting the health and safety of Virginians during this pandemic and ensuring our citizens can make their voices heard in a safe, fair, and uniform manner.”43
53. This Court has taken similar steps in light of the pandemic. For example, on March 24, the Court extended its restriction on in-person court proceedings to “any criminal, civil and bankruptcy proceedings on or before May 2, 2020.”44 COVID-19’s Impact on African American Virginians in Light of Ongoing and Historical Discrimination
54. Nationally, the COVID-19 epidemic has had a particularly devastating effect in African-American communities. A recent analysis—one of the first attempts to examine the racial disparities of COVID-19 cases and deaths nationwide—found that, in areas where the demographic data has been publicly shared by government officials, African-Americans have made up 42% of people who have died from COVID-19, despite accounting for roughly only 21% of the total population in these areas.45
ress Release, Ralph Northam, Governor of Virginia, Governor Northam Announces Plans to Postpone Upcoming Virginia Elections in Response to COVID-19 (Apr. 8, 2020), https://www.governor.virginia.gov/newsroom/allreleases/2020/april/headline-855995-en.html. 44 Am. Standing Order No. 2020-5, In re: Court Operations Under the Exigent Circumstances Created by COVID19 (W.D. Va. Mar. 24, 2020). 45 Kat Stafford, et al., Outcry over racial data grows as virus slams black Americans, ASSOCIATED PRESS, (Apr. 8, 2020), https://apnews.com/71d952faad4a2a5d14441534f7230c7c?fbclid=IwAR1plunY_qfeA2KrSUPA1TuJobAwQh53a_Qlkf5dw0dWjz-iz85GA1FOt4.
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55. Virginia fits this trend, witnessing racially disparate patterns of serious illness and
mortality due to COVID-19. “African Americans constitute approximately 20% of Virginia’s population, but make up about 30% of the total number of reported positive cases in Virginia.”46
Public health experts believe that these statistics likely understate the racially disparate effect of
COVID-19 in African-American communities in Virginia. For example, Dr. Robert Winn, the
Director of the Massey Cancer Center at Virginia Commonwealth University, estimates that “[i]n
some cases,” African Americans are “three to six times more [likely to be infected by the COVID-19 virus] than their white counterparts.”47
56. Courtney Cogburn, an associate professor at the Columbia University School of
Social Work, noted that “[t]here are patterns at this intersection of race and socioeconomic status
that make it very clear this is just not a story about poverty.” That is, racial disparities in serious
illness and death due to COVID-19 are inextricably linked to a long history and ongoing patterns
of racial discrimination against African Americans:
A history of systemic racism and inequity in access to health care and economic opportunity has made many African Americans far more vulnerable to the virus. Black adults suffer from higher rates of obesity, diabetes and asthma, which make them more susceptible, and also are more likely to be uninsured. They also often report that medical professionals take their ailments less seriously when they seek treatment.48
46 Nana-Séntuo Bonsu, Disproportionate numbers appearing in African American COVID-19 cases in Virginia; doctor explains, WKTR (Apr. 10, 2020), https://www.wtkr.com/news/disproportionate-numbers-appearing-inafrican-african-covid-19-cases-in-virginia-doctor-explains; see also Elizabeth Thomas & Dr. Nancy A. Anoruo, Coronavirus is disproportionately killing the black community. Here’s what experts say can be done about it, ABC NEWS (Apr. 9, 2020), https://abcnews.go.com/Politics/coronavirus-disproportionately-killing-black-communityexperts/story?id=70011986. 47 Matthew Fultz, African Americans 3 to 6 times more likely to get COVID-19, expert says, WTVR (last updated Apr. 13, 2020), https://www.wtvr.com/news/coronavirus/african-americans-3-to-6-times-more-likely-to-get-covid19-expert-says. 48 See supra n. 44 (Stafford, et al.).
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57. Virginia has long experienced patterns of racial discrimination in health and socioeconomic life patterns that render African-American Virginians at greater risk of severe health complications from COVID-19. As Governor Northam has acknowledged,
We know that long-standing racial inequities in things like access to health care, education, and economic opportunities lead to differences in underlying health conditions. The existence of such inequities is one reason why communities of color, including African American people, are more likely to have some of the underlying health conditions that put them at greater risk with COVID-19.49 58. Similarly, Virginia Health Commissioner Norman Oliver has acknowledged that racial inequalities render African-American Virginians particularly vulnerable to COVID-19, noting that lack of access to health care in African-American communities contributes “to much higher disease burden, with twice the rate of diabetes, hypertension, obesity,” resulting in “underlying problems [that] then place these folks at higher risk of mortality from COVID-19.” Health Commissioner Oliver further noted that African Americans in Virginia more frequently “tend to be concentrated in the essential industries and are working,” with “less social distancing . . . and less opportunity for teleworking.”50 And Dr. Winn of VCU has noted that, in comparison to their white counterparts, African American Virginians lack access to healthcare and information, suffer from underlying health conditions, and are more likely to hold “essential jobs” and cannot work from home.51 59. Virginia has a long history of racial discrimination in a wide range of areas in socioeconomic life, including in voting.
49 Neal Augenstein, Virginia governor seeks more data on how COVID-19 affects minorities, WTOP (Apr. 9, 2020), https://wtop.com/virginia/2020/04/virginia-governor-seeks-more-data-on-how-covid-19-affects-minorities/. 50 Id. 51 See supra n. 46 (Fultz).
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Virginia’s Absentee Voting Process and Witness Requirement 60. Virginia law sets out certain categories of individuals who may vote by mail
ballot, known in Virginia as absentee voting. These categories include people absent from the jurisdiction on Election Day including students, service members on active duty, a person with a disability unable to vote in person because of “disability, illness, or pregnancy,” people prevented from voting on Election Day due to religious observance, and several other categories. Va. Code § 24.2-700.
61. During the 2020 legislative session, the Virginia General Assembly passed and the Governor signed a number of voting reforms, including an expansion of absentee voting to make all registered voters eligible to use this process without an excuse.52 This takes effect July 1, 2020.
62. Nonetheless, as previously noted, the Department of Elections has published informal guidance on their website providing that voters may apply for and submit an absentee ballot for the May and June elections by choosing reason “2A My disability or illness” due to COVID-19.
63. On June 23, 2020, Virginia will hold Democratic and Republican primaries for federal offices. Republicans have a statewide primary for a U.S. Senate seat as well as primaries in Virginia’s Second and Third congressional districts. Meanwhile, Democrats have primaries for House races in the First, Fourth, Fifth, and Eleventh congressional districts.
52 See 2020 Va. H.B. 1, available at https://lis.virginia.gov/cgi-bin/legp604.exe?201+ful+HB1ER; Press Release, Officer of the Governor, “Governor Northam Signs Sweeping New Laws to Expand Access to Voting” (Apr. 12, 2020), https://www.governor.virginia.gov/newsroom/all-releases/2020/april/headline-856055-en.html.
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64. Absentee ballot applications submitted by mail for these races must be received by the appropriate registrar no later than June 16 at 5 PM. Va. Code § 24.2-701(B)(2). Completed absentee ballots must be returned to the registrar by the close of polls on Election Day. Va. Code § 24.2-709.
65. Individuals may request an absentee ballot online or by sending in a mail request, among other methods. When applying, individuals must sign the application “subject to felony penalties for making false statements” that the “facts contained in the application are true and correct” and that they “will not vote in the election at any other place in Virginia or in any other state.” Va. Code § 24.2-701(B)(1). An exception exists for individuals who cannot sign due to disability, in which case “a person assisting the applicant will note this fact on the applicant signature line and provide his signature, name, and address.” Id.
66. When a registrar receives an absentee ballot application and verifies that the individual properly competed the application and that they are a registered voter in the jurisdiction, the registrar mails to the individual the following items:
a. A sealed envelope containing the unmarked ballot; b. An envelope for resealing the marked ballot on which is printed a “Statement
of Voter,” as well as spaces for the voter to sign and date and for a witness to sign. The “Statement of Voter” informs voters, among other things, that their signature certifies “subject to felony penalties for making false statements,” their name, legal residence, that they received the ballot after requesting it, that they opened the ballot envelope “in the presence of the witness” but without assistance, that they sealed the ballot in the envelope, and that they “have not voted and will not vote in this election at any other time or place”;
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c. “A properly addressed envelope for the return of the ballot to the general registrar by mail or by the applicant in person”; and
d. “Printed instructions for completing the ballot and statement on the envelope and returning the ballot.” Va. Code § 24.2-706.
67. As noted by the instructions, when voters receive their mailed absentee ballots, they “shall, in the presence of a witness, (i) open the sealed envelope marked ‘ballot within’ and (ii) mark and refold the ballot . . . without assistance and without” indicating how they marked the ballot. Va. Code § 24.2-707(A).
68. Once voters fill out their ballots, they “shall (a) enclose the ballot in the envelope provided for that purpose, (b) seal the envelope, (c) fill in and sign the statement printed on the back of the envelope in the presence of a witness, who shall sign the same envelope, (d) enclose the ballot envelope and any required assistance form within the envelope directed to the general registrar, and (e) seal that envelope and mail it to the office of the general registrar or deliver it personally to the general registrar.” Id.
69. When the absentee ballot process counting begins, election officers examine each absentee ballot envelope to determine whether to accept the ballot for counting. The relevant statute provides that an absentee ballot may not be rejected on the basis that the voter failed to provide a middle name, middle initial, or the date, Va. Code § 24.2-711, but is silent as to whether an absentee ballot may or must be rejected if the voter failed to provide any of the other parts of the absentee ballot envelope, such as the witness signature.
70. However, under regulations promulgated by the Board, the lack of a witness signature on the absentee ballot envelope is an omission that is “always material” and that renders the ballot invalid. 1 Va. Admin. Code 20-70-20(B).
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71. By contrast, absentee ballots that do contain a witness signature are not rendered invalid if the witness signature is illegible, even though there is no requirement that the witness print their name or otherwise identify themselves anywhere on the ballot envelope.
72. Virginia statutes and regulations provide no process by which voters may correct any errors on their absentee ballot envelopes after they are mailed to the general registrar, and in practice, all absentee ballots lacking a witness signature are rejected as a matter of course without any effort to verify whether the absentee ballot came from the intended voter. Voters whose ballots are rejected because of a lack of a witness signature do not learn of this until after the election, when the electoral board “send[s] a written explanation of the reason for rejection of an absentee ballot to the voter whose absentee ballot is rejected within 90 days of the date on which the ballot is rejected.” Va. Code § 24.2-711.1(B). Virginia’s witness requirement will deny large numbers of Virginians the right to vote yet provides only marginal benefits for election integrity
73. As just noted, election officials currently have no discretion under the regulations promulgated by the Board as to whether to count an unwitnessed absentee ballot—they must reject such a ballot and are only obligated to inform the voter as such within 90 days after the ballot rejection.
74. Yet in the current pandemic, individuals living alone and not isolating with a potential witness in accordance with Executive Orders No. 53 and 55 have no safe means to have an individual witness and sign their ballot envelope. Under the Governor’s orders, individuals should maintain at least six feet of distance from others with whom they do not live. These orders also reflect the consensus of doctors and public health officials.
75. Older Virginians and those with certain preexisting medical conditions face even more grave risks by interacting with another individual to obtain a witness signature. But
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because COVID-19 can strike and kill individuals of any age and those without preexisting conditions, any individual living alone faces a real risk by seeking someone to witness their ballot.
76. Enforcing the witness requirement in an environment in which COVID-19 is still being transmitted will likely prevent thousands of eligible Virginians from casting ballots.
77. As of March 31, 2020, Virginia had over 5.73 million registered voters. In the June 2018 Democratic and Republican primaries, over 541,000 Virginians cast ballots. And in the November 2016 general election, over 3.98 million Virginians cast ballots. While many of these individuals voted in-person, the combination of the COVID-19 outbreak, the loosening of absentee voting excuse requirements, and the examples from states like Wisconsin—where absentee ballot requests were five times higher in this year’s primary than in the 2016 primary53—indicate that voting by mail will explode in Virginia this year.
78. According to 2018 Current Population Survey (“CPS”) statistics from the Census Bureau,54 25.3% of Virginians age 18 and older live alone. Assuming similar numbers in the 2020 June primaries, over 136,000 Virginians will face the choice of either risking their health by voting in person or finding a witness for their absentee ballots, or not voting at all. For the
53 Compare Absentee Ballot Report - April 7, 2020 Spring Election and Presidential Preference Primary, Wisc. Election Comm’n, https://elections.wi.gov/node/6833 (reporting over 1.28 million absentee ballots requested for April 7, 2020 primary) with Riley Vetterkind, Absentee ballot requests in Wisconsin already exceed number in recent spring elections, WISC. STATE JOURNAL (Mar. 18, 2020), https://madison.com/wsj/news/local/govt-andpolitics/absentee-ballot-requests-in-wisconsin-already-exceed-number-in-recent-spring-elections/article_dfb34fc56aa8-5428-90c3-26c3f82a1d70.html (noting that just under 250,000 absentee ballots were requested for spring 2016 Wisconsin primary). 54 2018 Current Population Survey, U.S. Census Bureau, statistics accessed by using the Census Bureau Current Population Survey Table Creator tool at https://www.census.gov/cps/data/cpstablecreator.html..
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general election, over a million Virginians will fall into this category. Like the individual Plaintiffs, many of them will be forced to risk their (and others’) health in order to vote.
79. To make matters worse, this burden on the right to vote will fall more heavily upon certain groups—older Virginians, Virginians with disabilities, and African American Virginians, among others.
80. Approximately 33% of Virginians age 65 and older live alone compared to 25.3% of the general population. 37.2% of Virginians 18 and older with a disability live alone and 44% of Virginians aged 65 and older with a disability live alone. 31% of African American Virginians 18 and older live alone versus only 24.7% of white Virginians 18 and older.
81. As noted above, older individuals already face higher rates of infection and death from COVID-19, further magnifying its impact. And the CDC has found that “some people with disabilities might be at a higher risk of infection or severe illness because of their underlying medical conditions.”55
82. Recent evidence also revealed racial disparities in the impact of COVID-19— disparities that will also likely transfer to burdens on voting. While Virginia is not yet fully collecting COVID-19 data by race, both Maryland and North Carolina have released data showing that African Americans face higher rates of both infection and death from COVID-19 than the population as a whole.56
55 Centers for Disease Control and Prevention, People Who Need Extra Precautions: People with Disabilities, https://www.cdc.gov/coronavirus/2019-ncov/need-extra-precautions/people-with-disabilities.html (last visited Apr. 15, 2020). 56 North Carolina Department of Health and Human Services, COVID-19 Cases in North Carolina By Race, https://www.ncdhhs.gov/divisions/public-health/covid19/covid-19-nc-case-count#by-race/ethnicity (last visited Apr. 15, 2020); Fenit Nirappil et al., Record set for single-day covid-19 deaths in D.C., Maryland and Virginia at 53; black residents hit hardest, WASH POST (Apr. 9, 2020, 3:47 PM), https://www.washingtonpost.com/local/covid-19-
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83. Virginia’s witness requirement will therefore likely prevent tens of thousands of Virginians who might otherwise cast absentee ballots from doing so this year, with a disproportionate impact on older Virginians, Virginians with a disability, and African American Virginians.
84. The witness requirement is particularly burdensome for African Americans in Virginia, who, as noted, are more likely to live alone and thus will be more likely to risk exposure to COVID-19 in the course of obtaining a witness signature. African Americans in Virginia continue to bear the effects of discrimination in areas such as education, employment, and health, which hinder their ability to participate effectively in the political process. It is precisely because of these patterns that African Americans in Virginia face particularly severe health risks from COVID-19 exposure. In these circumstances, the witness requirement interacts with these conditions to deny African Americans in Virginia an equal opportunity to participate in the political process.
85. While protecting election integrity and preventing improper use of absentee ballots certainly are valid governmental interests, maintaining the witness requirement during this pandemic fails to even serve this interest, let alone present a narrowly tailored method of doing so. And to the extent it does serve these or any other governmental interests, it is substantially outweighed by its massive burden on Virginia voters and other Virginia procedures that serve the same interests.
86. The witness requirement is not Virginia’s sole method of policing the integrity of absentee ballots—far from it. Indeed, only 10 other states even contain such a requirement in
deaths-hit-new-high-in-dc-maryland-and-virginia-at-53-black-residents-hit-hardest/2020/04/09/cc85cd14-77b311ea-b6ff-597f170df8f8_story.html.
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their state laws yet the states without this requirement still have absentee balloting systems not undermined by fraud.57
87. Meanwhile, Virginia has several other mechanisms to both confirm the legitimacy of the absentee ballot cast and disincentivize fraudulent use of absentee ballots.
88. For one, the general registrar maintains a list of voters who applied for and returned absentee ballots, and that list is attested to by the secretary of the electoral board and delivered to the chief officer of election for each precinct. Absentee ballots are only accepted “from voters whose names appear on the attested list.” Va. Code § 24.2-710.
89. Most directly, voters themselves must attest under penalty of perjury their identity, residence, and that they did not double vote when they sign their ballot envelope. Va. Code § 24.2-706.
90. Any individual who double votes or otherwise improperly uses an absentee ballot faces severe criminal penalties for violating their attestation: “Any person who intentionally (i) votes more than once in the same election . . . is guilty of a Class 6 felony.” Va. Code § 24.21004(B).
91. Additionally, any “willfully false material statement or entry made by any person in any statement, form, or report required by this title shall constitute the crime of election fraud and be punishable as a Class 5 felony.” Va. Code § 24.2-1016.
57 See Chart, “Verifying Authenticity of Absentee/Mailed Ballots,” Voting Outside the Polling Place: Absentee, AllMail and other Voting at Home Options, Nat’l Conf. of State Legislatures (Apr. 3, 2020), https://www.ncsl.org/research/elections-and-campaigns/absentee-and-early-voting.aspx.
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92. And “[a]ny person attempting to vote by fraudulently signing the name of a qualified voter shall be guilty of forgery and shall be guilty of a Class 4 felony.” Va. Code § 24.2-1012.
93. In light of these attestation and verification requirements and criminal penalties associated with misusing absentee ballots, the additional step of requiring a witness signature adds little on top of these safeguards. And while instances of fraud are rare, an individual determined to break these laws and risk the penalties can just as easily forge the signature of another individual as they can falsely attest when they sign their own name. Indeed, the witness requirement has little if any practical utility for election integrity because Virginia law does not require witnesses to identify themselves by printing their name or providing any other information and Board regulations instruct election officials to accept ballots even where the witness signature is illegible.
94. The burden on the voting rights of the many thousands of Virginians, including Plaintiffs, who will be prevented from either casting their ballots safely or having them counted by retaining the witness requirement far outweighs any upside of the requirement, if any.
CLAIMS FOR RELIEF COUNT I
Violation of the Fundamental Right to Vote 42 U.S.C. § 1983, First and Fourteenth Amendments to the U.S. Constitution 95. Eligible individuals have a fundamental right to vote under the First and Fourteenth Amendments of the United States Constitution. Under the First and Fourteenth Amendments, a court considering a challenge to a state election law must carefully balance the character and magnitude of the injury to the rights that the plaintiff seeks to vindicate against the
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justifications put forward for the burdens imposed by the rule. See Burdick v. Takushi, 504 U.S. 428, 434 (1992); Anderson v. Celebrezze, 460 U.S. 780, 789 (1983).
96. In light of the COVID-19 pandemic, Virginia’s witness requirement and its enforcement severely and unreasonably burdens the fundamental right to vote of Virginia voters. This requirement will likely prevent thousands of eligible Virginians from casting ballots, with particularly heavy burdens on older Virginians, Virginians with disabilities, and African American Virginians.
97. And while Virginia has a general interest in election integrity, the witness requirement does very little to advance this interest in light of the substantial other protections against fraudulent submission of ballots, let alone providing a narrowly tailored way to address this potential issue. Whatever interests the witness requirement may serve pales in comparison to the substantial burden on voters during the COVID-19 pandemic.
98. Therefore, Defendants, acting under color of state law, have and will continue to deprive Plaintiffs of rights secured to them by the First and Fourteenth Amendments to the United States Constitution— namely, the fundamental right to vote—and protected by 42 U.S.C. § 1983 by enforcing the witness requirement.
COUNT II Violations of Section 2 of the Voting Rights Act, 52 U.S.C. § 10301 99. Section 2 of the Voting Rights Act provides in part that “[n]o voting qualification or prerequisite to voting or standard, practice, or procedure shall be imposed or applied by any State . . . in a manner which results in a denial or abridgement of the right of any citizen of the United States to vote on account of race or color.” 52 U.S.C. § 10301(a).
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100. The “essence of a [Section] 2 claim is that a certain electoral law, practice, or structure interacts with social and historical conditions to cause an inequality in the opportunities enjoyed by black and white voters to elect their preferred representatives.” League of Women Voters of N.C. v. North Carolina, 769 F.3d 224, 238–39 (4th Cir. 2014) (internal quotation marks and citation omitted). “[A] Section 2 vote-denial claim consists of two elements:
First, the challenged standard, practice, or procedure must impose a discriminatory burden on members of a protected class, meaning that members of the protected class have less opportunity than other members of the electorate to participate in the political process and to elect representatives of their choice. Second, that burden must in part be caused by or linked to social and historical conditions that have or currently produce discrimination against members of the protected class. Id. at 240 (internal quotation marks and citations omitted). 101. The witness requirement, if not declared illegal and enjoined, will materially burden the right to vote, and will have an adverse and disparate impact on African-American voters in Virginia. African Americans in Virginia are more likely to suffer from severe health complications and to die from COVID-19, and are therefore more significantly burdened by the witness requirement. 102. This disparate burden resulting from the witness requirement is directly linked to social and historical conditions. Virginia has a long history of voting-related discrimination. African Americans in Virginia continue to suffer from discrimination in areas such as education, employment, and health, which hinders their ability to participate effectively in the political process. In particular, these discriminatory patterns render African Americans more vulnerable to COVID-19, such that the witness requirement is particularly burdensome for them as a group relative to other voters.
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103. Under the totality of the circumstances, the witness requirement interacts with these social and historical conditions to abridge and deny African Americans in Virginia the right to vote. As a result of the witness requirement, African Americans in Virginia will have less opportunity than other members of the electorate to participate in the political process and to elect representatives of their choice.
RELIEF REQUESTED WHEREFORE, Plaintiffs respectfully requests that this Court: A. Declare that Virginia’s enforcement of the witness requirement (as stated in Va. Code
§ 24.2-706 and § 24.2-707 and as interpreted by 1 Va. Admin. Code 20-70-20(B)) while emergency orders by Virginia or federal authorities regarding COVID-19 transmission are in effect and/or while public health officials continue to recommend social distancing practices due to risk of community transmission of COVID-19 violates the fundamental right to vote under First and Fourteenth Amendments to United States Constitution as well as Section 2 of the Voting Rights Act; B. Issue a preliminary and permanent injunction that orders relief including:
1. Prohibiting Defendants from enforcing the witness requirement (as stated in Va. Code § 24.2-706 and § 24.2-707 and as interpreted by 1 Va. Admin. Code 20-70-20(B)) for all voters, especially for voters at risk of health complications arising from COVID-19 exposure, while emergency orders concerning COVID-19 are in place and/or while public health officials continue to recommend social distancing practices due to risk of community transmission of COVID-19;
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2. Ordering Defendants to issue guidance instructing city and county election officials to count otherwise validly cast absentee ballots that are missing a witness signature for Virginia’s primary and general elections in 2020; and
3. Ordering Defendants to conduct a public information campaign informing Virginia voters about the elimination of this requirement, in coordination with city and county election officials;
C. Award Plaintiffs attorneys’ fees in this action; D. Award Plaintiffs their costs of suit; and E. Grant such other and further relief as this Court deems just and proper in the circumstances.

Dated: April 17, 2020
Davin M. Rosborough (VSB # 85935)* Dale E. Ho** Sophia Lin Lakin** Theresa J. Lee** Adriel I. Cepeda-Derieux** American Civil Liberties Union Foundation 125 Broad Street, 18th Floor New York, NY 10004 Tel.: (212) 549-2500 drosborough@aclu.org dho@aclu.org slakin@aclu.org tlee@aclu.org acepedaderieux@aclu.org

Respectfully submitted,
/s/ Vishal Agraharkar__ Vishal Agraharkar (VSB #93265) Eden Heilman (VSB #93554) AMERICAN CIVIL LIBERTIES UNION FOUNDATION OF VIRGINIA, INC. 701 E. Franklin Street, Suite 1412 Richmond, Virginia 23219 Phone: (804) 644-8080 Fax: (804) 649-2733 vagraharkar@acluva.org eheilman@acluva.org
Attorneys for Plaintiffs
* Currently Associate Status with Virginia Bar; Application for reinstatement to active status pending **Not admitted in W.D. Va.; Motion for admission pro hac vice to be filed
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UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA
Lynchburg Division

LEAGUE OF WOMEN VOTERS OF

VIRGINIA;

KATHERINE

D.

CROWLEY; ERIKKA GOFF; and

SEIJRA TOOGOOD,

Plaintiffs,

v.

VIRGINIA STATE BOARD OF ELECTIONS; ROBERT H. BRINK, JOHN O’BANNON, and JAMILAH D. LECRUISE, in their official capacities as Chairman, Vice-Chair, and Secretary of the Virginia State Board of Elections, respectively; and CHRISTOPHER E. PIPER, in his official capacity as Commissioner of the Virginia Department of Elections,

Defendants.

Case No. 6:20-cv-00024-NKM

PLAINTIFFS’ MOTION FOR PRELIMINARY INJUNCTION Plaintiffs League of Women Voters of Virginia (the “League”), Katherine D. Crowley, Erikka Goff, and Seijra Toogood, respectfully move for a preliminary injunction under Federal Rule of Civil Procedure 65(a). They do so to prevent thousands of Virginia voters, including Plaintiffs and League members, from facing disenfranchisement in Virginia’s June 23 primary and any other elections affected by the spread of COVID-19 due to Virginia’s absentee ballot witness requirement. This rule mandates that absentee mail ballot voters have another individual witness the voter opening their ballot envelope and have that witness sign the ballot envelope, as stated in Va. Code § 24.2-706 and § 24.2-707 and as interpreted by 1 Va. Admin. Code 20-70-

Case 6:20-cv-00024-NKM Document 16 Filed 04/21/20 Page 2 of 4 Pageid#: 83
20(B). In support of their motion, Plaintiffs rely upon the accompanying Brief in Support of Plaintiffs’ Motion for a Preliminary Injunction, and the attached declarations and exhibits.
Plaintiffs are likely to succeed on the merits of their claim that Virginia’s witness requirement unconstitutionally burdens their right to vote in light of the COVID-19 outbreak. Because approximately one-quarter of Virginians of voting age live alone, the witness requirement means that these individuals must either break social distancing protocols and risk their health to vote, or face disenfranchisement—a burden that falls particularly hard on Virginia’s senior citizens, people with disabilities, and African Americans. And the witness requirement offers little, if any, benefit to the Commonwealth’s election integrity interests in light of the myriad other election integrity laws and procedures in place and the ineffectiveness of the requirement. Without preliminary relief, Plaintiffs and many thousands of other Virginia voters will face the irreparable harm of disenfranchisement. The balance of the equities and the public interest also favor granting a preliminary injunction, as doing so would support both the right of all eligible Virginians to vote and public health.
Plaintiffs therefore seek a preliminary injunction: (1) Prohibiting Defendants from enforcing the witness requirement (as stated in Va. Code § 24.2-706 and § 24.2-707 and as interpreted by 1 Va. Admin. Code 20-70-20(B)) for all Virginia voters for the June 23 primaries and for any and all subsequent elections in Virginia until such time as in-person interactions required by compliance with the witness requirement no longer pose a risk to public health and personal safety; (2) Ordering Defendants to issue guidance instructing city and county election officials to count otherwise validly cast absentee ballots that are missing a witness signature for Virginia’s June 23 primary elections; and (3) Ordering Defendants to conduct a public information campaign informing Virginia voters about the elimination of this requirement, in coordination with city and county election officials.
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Dated: April 21, 2020
Davin M. Rosborough (VSB # 85935)* Dale E. Ho** Sophia Lin Lakin** Theresa J. Lee** Adriel I. Cepeda-Derieux** American Civil Liberties Union Foundation 125 Broad Street, 18th Floor New York, NY 10004 Tel.: (212) 549-2500 drosborough@aclu.org dho@aclu.org slakin@aclu.org tlee@aclu.org acepedaderieux@aclu.org

Respectfully submitted,
/s/ Vishal Agraharkar_______________ Vishal Agraharkar (VSB #93265) Eden Heilman (VSB #93554) AMERICAN CIVIL LIBERTIES UNION FOUNDATION OF AMERICA, INC. 701 E. Franklin Street, Suite 1412 Richmond, Virginia 23219 Phone: (804) 644-8080 Fax: (804) 649-2733 vagraharkar@acluva.org eheilman@acluva.org

Attorneys for Plaintiffs
* Currently Associate Status with Virginia Bar; Application for reinstatement to active status pending ** Admitted pro hac vice

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CERTIFICATE OF SERVICE I certify that on April 21, 2020, I served a copy of the foregoing Plaintiffs’ Motion for a Preliminary Injunction on Counsel for Defendants via e-mail, as agreed to by Defendants’ Counsel in writing per Federal Rule of Civil Procedure 5(b)(2)(E).
/s/ Vishal Agraharkar_______________ Vishal Agraharkar (VSB #93265) AMERICAN CIVIL LIBERTIES UNION FOUNDATION OF AMERICA, INC. 701 E. Franklin Street, Suite 1412 Richmond, Virginia 23219 Phone: (804) 644-8080 Fax: (804) 649-2733 vagraharkar@acluva.org Counsel for Plaintiffs
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UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA
Lynchburg Division

LEAGUE OF WOMEN VOTERS OF

VIRGINIA;

KATHERINE

D.

CROWLEY; ERIKKA GOFF; and

SEIJRA TOOGOOD,

Plaintiffs,

v.

VIRGINIA STATE BOARD OF ELECTIONS; ROBERT H. BRINK, JOHN O’BANNON, and JAMILAH D. LECRUISE, in their official capacities as Chairman, Vice-Chair, and Secretary of the Virginia State Board of Elections, respectively; and CHRISTOPHER E. PIPER, in his official capacity as Commissioner of the Virginia Department of Elections,

Defendants.

Case No. 6:20-cv-00024-NKM

BRIEF IN SUPPORT OF PLAINTIFFS’ MOTION FOR PRELIMINARY INJUNCTION

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TABLE OF CONTENTS
TABLE OF AUTHORITIES ...................................................................................................... iii INTRODUCTION......................................................................................................................... 1 FACTUAL BACKGROUND ....................................................................................................... 3
A. The COVID-19 Pandemic.............................................................................................. 3 B. Public Health Guidance Regarding COVID-19 ............................................................. 5 C. The Effect and Consequences of COVID-19 in Virginia .............................................. 7 D. Virginia’s Upcoming Elections...................................................................................... 9 E. Virginia’s Absentee Ballot Process and the Challenged Witness Requirement........... 10 F. Virginia’s Laws Supporting Absentee Voting Election Integrity................................. 13 G. The Public Health and Disenfranchisement Consequences of Virginia’s Absentee
Witness Requirement During Significant COVID-19 Transmission.......................... 14 H. Injuries and Irreparable Harm to Plaintiffs .................................................................. 15 ARGUMENT............................................................................................................................... 17 I. Plaintiffs are likely to prevail on the merits because the First and Fourteenth
Amendments require Virginia to eliminate the absentee witness requirement under the present circumstances. .................................................................................. 17 A. The absentee witness requirement merits at least heightened scrutiny because it will
disenfranchise thousands of voters during the June primary while worsening a public health crisis……………………..……………………..………...18 1. The absentee witness requirement will severely burden many thousands of
Virginia voters in the June primary…………………………..………………….19 2. For the thousands of Virginia voters who live alone—especially older individuals,
African Americans, and voters with disabilities—the witness requirement means disenfranchisement or jeopardizing one’s health…………………………..…….23 B. The absentee witness requirement’s burden on voters far outweighs its minimal-tononexistent promotion of election integrity……………...…………………………..26 II. A preliminary injunction is necessary to prevent irreparable harm to Plaintiffs’ constitutional rights....................................................................................................... 30 III. The balance of equities and the public interest support injunctive relief...................... 34 CONCLUSION ........................................................................................................................... 35
ii

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TABLE OF AUTHORITIES
Cases Action NC v. Stranch,
216 F. Supp. 3d 597 (M.D.N.C. 2016) ..................................................................................... 32 Am. Life League, Inc. v. Reno,
47 F.3d 642 (4th Cir. 1995) ...................................................................................................... 29 Anderson v. Celebrezze,
460 U.S. 780, 788 (1983).......................................................................................................... 17 Burdick v. Takushi,
504 U.S. 428 (1992).................................................................................................................. 17 Common Cause Georgia v. Kemp,
347 F. Supp. 3d 1270 (N.D. Ga. 2018) ..................................................................................... 32 Common Cause Indiana v. Lawson,
327 F. Supp. 3d 1139 (S.D. Ind. 2018) ..................................................................................... 32 Crawford v. Marion Cty. Election Bd.,
553 U.S. 181 (2008)............................................................................................................ 18, 26 Di Biase v. SPX Corp.,
872 F.3d 224 (4th Cir. 2017) .................................................................................................... 17 Diretto v. Country Inn & Suites by Carlson,
No. 1:16CV1037 (JCC/IDD), 2016 WL 4400498 (E.D. Va. Aug. 18, 2016) .......................... 34 Esshaki v. Whitmer,
No. 2:20-CV-10831-TGB (E.D. Mich. Apr. 20, 2020) ............................................................ 19 Faulkner v. Va. Dep’t of Elections,
No. CL 20-1546 (Va. Cir. Ct. Mar. 25, 2020) .......................................................................... 19 Fla. Democratic Party v. Scott,
215 F. Supp. 3d 125 (N.D. Fla. 2016)................................................................................. 23, 31 Forest Hills Early Learning Ctr., Inc. v. Lukhard,
728 F.2d 230 (4th Cir. 1984) .................................................................................................... 29 Frank v. Walker,
819 F.3d 384 (7th Cir. 2016) .................................................................................................... 18 Fusaro v. Cogan,
930 F.3d 241 (4th Cir. 2019) .................................................................................................... 18 Giovani Carandola, Ltd. v. Bason,
303 F.3d 507 (4th Cir. 2002) .................................................................................................... 34 Givens v. Mountain Valley Pipeline, LLC,
140 S. Ct. 300 (2019) ................................................................................................................ 30
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Case 6:20-cv-00024-NKM Document 17 Filed 04/21/20 Page 4 of 46 Pageid#: 89
Ind. State Conf. of the NAACP v. Lawson, 326 F. Supp. 3d 646 (S.D. Ind. 2018) ....................................................................................... 33
League of Women Voters of Mo. v. Ashcroft, 336 F. Supp. 3d 998 (W.D. Mo. 2018) ..................................................................................... 33
League of Women Voters of Fla. v. Browning, 863 F. Supp. 2d 1155 (N.D. Fla. 2012)..................................................................................... 33
League of Women Voters of N.C. v. North Carolina, 769 F.3d 224 (4th Cir. 2014) ........................................................................................ 31, 33, 34
League of Women Voters of U.S. v. Newby, 838 F.3d 1 (D.C. Cir. 2016) ...................................................................................................... 32
McLaughlin v. N.C. Bd. of Elections, 65 F.3d 1215 (4th Cir. 1995) .................................................................................................... 18
Metro. Reg’l Info. Sys., Inc. v. Am. Home Realty Network, Inc., 722 F.3d 591 (4th Cir. 2013) .................................................................................................... 17
Mountain Valley Pipeline, LLC v. 6.56 Acres of Land, Owned by Sandra Townes Powell, 915 F.3d 197 (4th Cir. 2019) .................................................................................................... 30
N.C. State Conf. of NAACP v. Cooper, No. 1:18CV1034, 2019 WL 7372980 (M.D.N.C. Dec. 31, 2019)............................................ 32
Norman v. Reed, 502 U.S. 279 (1992).................................................................................................................. 26
Northeast Ohio Coalition for the Homeless v. Husted, 837 F.3d 612 (6th Cir. 2016) .................................................................................................... 26
One Wisconsin Inst., Inc. v. Thomsen, 198 F. Supp. 3d 896 (W.D. Wis. 2016) ........................................................................ 18, 26-27
Tex. Democratic Party v. DeBeauvoir, No. D1-GN-001610 (Travis Cty. Dist. Ct. Apr. 17, 2020) ....................................................... 33
Pashby v. Delia, 709 F.3d 307 (4th Cir. 2013) .................................................................................................... 34
Price v. N.Y. State Bd. of Elections, 540 F.3d 101 (2d Cir. 2008)................................................................................................ 23, 26
Reynolds v. Sims, 377 U.S. 533 (1964).................................................................................................................. 31
Smith v. Potter, 187 F. Supp. 2d 93 (S.D.N.Y. 2001)......................................................................................... 30
Thakker v. Doll, No. 1:20-CV-480, 2020 WL 167156 (M.D. Pa. Mar. 31, 2020) .............................................. 31
Tolman v. Doe, 988 F. Supp. 582 (E.D. Va. 1997) ............................................................................................ 30
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Case 6:20-cv-00024-NKM Document 17 Filed 04/21/20 Page 5 of 46 Pageid#: 90
United States v. Cecil, 836 F.2d 1431 (4th Cir. 1988) .................................................................................................. 17
Wesberry v. Sanders, 376 U.S. 1 (1964)...................................................................................................................... 31
Statutes and Regulations 1 Va. Admin. Code 20-70-20(B) ................................................................................ 25, 27, 28, 35 17 R.I. Gen. Laws § 17-20-23………………………………………………………………..13, 28 Ala. Code § 17-9-30(b) .......................................................................................................... 13, 28 Ala. Code § 17-11-7 ………………………………………………………………………..13, 28 Ala. Code § 17-11-10………………………………………………………………………...13, 28 Alaska Stat. § 15.20.030……………………………………………………………………..13, 28 La. Stat. Ann. § 18:1306(2)(a) ………………………………………………………………13, 28 Miss. Code Ann. § 23-15-627………………………………………………………………..13, 28 Miss. Code Ann. § 23-15-635………………………………………………………………..13, 28 Miss. Code Ann. § 23-15-633………………………………………………………………..13, 28 Mo. Rev. Stat. § 115.279………………………………………………………………….....13, 28 Mo. Rev. Stat. § 115.283…………………………………………………………………… 13, 28 Mo. Rev. Stat. § 115.295…………………………………………………………………….13, 28 N.C. Gen. Stat. § 163-231……………………………………………………………………13, 28 Okla. Stat. tit. 26, § 14-108…………………………………………………………………..13, 28 S.C. Code Ann. § 7-15-220…………………………………………………………………..13, 28 S.C. Code Ann. § 7-15-230…………………………………………………………………..13, 28 Va. Code § 24.2-1004(B)........................................................................................................ 13, 28 Va. Code § 24.2-1012 ............................................................................................................. 13, 28 Va. Code § 24.2-1016 ............................................................................................................. 13, 28 Va. Code § 24.2-701(B)(1) ..................................................................................................... 10, 11 Va. Code § 24.2-706 ................................................................................................... 11, 13, 28, 35 Va. Code § 24.2-707 ......................................................................................................... 11, 28, 35 Va. Code § 24.2-709 ..................................................................................................................... 10 Va. Code § 24.2-710 ............................................................................................................... 13, 28 Va. Code § 24.2-711 ..................................................................................................................... 12 Va. Code § 24.2-711.1(B)....................................................................................................... 12, 25 Va. Code § 24.2-713 ..................................................................................................................... 10 Wis. Stat. § 6.87(4)(b)(1) ……………………………………………………………………13, 28
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Other Authorities Alex Seitz-Wald, 7 Wisconsin coronavirus infections linked to election day, health official says,
NBC News, Apr. 21, 2020, https://www.nbcnews.com/politics/2020-election/7-wisconsinvirus-cases-linked-person-voting-n1188606............................................................................... 7 Anthony Man, Two Broward poll workers, including one who handled voters’ driver licenses, test positive for coronavirus, South Florida Sun Sentinel, Mar. 26, 2020, https://www.sunsentinel.com/coronavirus/fl-ne-broward-elections-poll-workers-coronavirus-20200326wmgy775dvjc5jis2oagxlpmule-story.html ................................................................................. 7 Betsy McKay et al., Coronavirus Declared Pandemic by World Health Organization, Wall Street Journal, Mar. 11, 2020, https://www.wsj.com/articles/u-s-coronavirus-cases-top-1-00011583917794............................................................................................................................... 3 Betsy McKay, Coronavirus vs. Flu Which Virus is Deadlier, Wall Street Journal, Mar. 10, 2020, https://www.wsj.com/articles/coronavirus-vs-flu-which-virus-is-deadlier11583856879............................................................................................................................... 4 CDC COVID-19 Response Team, Severe Outcomes Among Patients with Coronavirus Disease 2019 (COVID-19)—United States, February 12 – March 16, 2020, CDC.gov, https://www.cdc.gov/mmwr/volumes/69/wr/mm6912e2.htm (last updated Mar. 26, 2020)...... 5 Centers for Disease Control and Prevention, Groups at Higher Risk of Severe Illness, https://www.cdc.gov/coronavirus/2019-ncov/need-extra-precautions/groups-at-higherrisk.html (last visited Apr. 15, 2020) .......................................................................................... 5 Centers for Disease Control and Prevention, How COVID-19 Spreads, https://www.cdc.gov/coronavirus/2019-ncov/prevent-getting-sick/how-covid-spreads.html (last visited Apr. 6, 2020) ........................................................................................................... 3 Centers for Disease Control and Prevention, Recommendations for Election Polling Locations: Interim guidance to prevent spread of coronavirus disease 2019 (COVID-19), https://www.cdc.gov/coronavirus/2019-ncov/community/election-polling-locations.html (last updated Mar. 27, 2020) ....................................................................................................... 6 Chart, “Verifying Authenticity of Absentee/Mailed Ballots,” Voting Outside the Polling Place: Absentee, All-Mail and other Voting at Home Options, Nat’l Conf. of State Legislatures (Apr. 3, 2020), https://www.ncsl.org/research/elections-and-campaigns/absentee-and-earlyvoting.aspx ................................................................................................................................ 13 Devi Shastri, In-person voting was likely a ‘disaster’ for Wisconsin’s efforts to flatten coronavirus curve, national experts say, Milwaukee Journal Sentinel, Apr. 8, 2020, https://www.jsonline.com/story/news/politics/elections/2020/04/08/coronavirus-wisconsinelection-likely-hurt-effort-flatten-curve/2961718001/ ............................................................... 7 Elizabeth Cohen, Experts tell White House coronavirus can spread through talking or even just breathing, CNN, Apr. 4, 2020, https://www.cnn.com/2020/04/02/health/aerosol-coronavirus-spread-white-houseletter/index.html .......................................................................................................................... 4 General Order No. 2020-11, In re: Court Operations Under the Exigent Circumstances Created by the Outbreak of Coronavirus Disease (COVID-19): Temporary Policy for Remote Proceedings and Public Access to Such Proceedings, Case No. 2:20mc7 (E.D. Va. Apr. 6, 2020)............................................................................................................... 3
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Johns Hopkins University, Coronavirus, Social Distancing and Self-Quarantine, https://www.hopkinsmedicine.org/health/conditions-and-diseases/coronavirus/coronavirussocial-distancing-and-self-quarantine (last visited Apr. 15, 2020) ............................................. 5
Jordan Musra, Voter Turnout Rates Among All Voting Age and Major Racial and Ethnic Groups Were Higher Than in 2014, U.S. Census Bureau (Apr. 23, 2019), https://www.census.gov/library/stories/2019/04/behind-2018-united-states-midterm-electionturnout.html............................................................................................................................... 20
Kat Stafford, et al., Outcry over racial data grows as virus slams black Americans, Associated Press, Apr. 8, 2020, https://apnews.com/71d952faad4a2a5d14441534f7230c7c?fbclid=IwAR1plunY_ qfeA2KrSUPA1TuJobAwQh53a_Qlkf5dw0dWjz-iz85GA1FOt4........................................... 15
Marc Lipsitch, DPhil, Professor of Epidemiology and Director, Center for Communicable Disease Dynamics, Harvard T.H. Chan School of Public Health, Seasonality of SARS-CoV-2: Will COVID-19 go away on its own in warmer weather?, https://ccdd.hsph.harvard.edu/will-covid-19-go-away-on-its-own-in-warmer-weather/............ 9
Mary Ann Ahern, Poll Worker at Chicago Voting Site Dies of Coronavirus, Election Officials Say, NBC Chicago, Apr. 13, 2020, https://www.nbcchicago.com/news/local/chicagopolitics/poll-worker-at-chicago-voting-site-dies-of-coronavirus-election-officialssay/2255072/ ............................................................................................................................... 6
Mel Leonor & Justin Mattingly, UVA researchers project mid-August peak for new COVID-19 cases in Virginia,............................................................................................... 9, 33
Nana-Séntuo Bonsu, Disproportionate numbers appearing in African American COVID-19 cases in Virginia, octor explains, WKTR, Apr. 10, 2020, https://www.wtkr.com/news/disproportionate-numbers-appearing-inafrican-africancovid-19-cases-in-virginia-doctor-explains. ............................................................................. 15
Neal Augenstein, Virginia governor seeks more data on how COVID-19 affects minorities, WTOP, Apr. 9, 2020, ................................................................................................................ 15
NBC Chicago, Gov. Pritzker Encourages Illinoisans to Vote by Mail After In-Person Voter Tests Positive for Coronavirus, Apr. 12, 2020, https://www.nbcchicago.com/news/local/gov-pritzker-encourages-illinoisans-to-voteby-mail-in-upcoming-general-election/2254687/ ....................................................................... 7
Parker Schorr, Wisconsin’s pandemic election: Long waits, face masks as voters go to polls, The Capital Times, Apr. 8, 2020, https://madison.com/ct/news/local/govt-andpolitics/wisconsin-s-pandemic-election-long-waits-facemasks-as-voters-go-topolls/article_bfd2c391-f390-5364-8c14-a88b548fe017.html ................................................... 20
Pew Center on States, Election Administration by the Numbers An Analysis of Available Datasets and How to Use Them, Feb. 2012, https://www.pewtrusts.org/~/media/legacy/uploadedfiles/pcs_assets/2012/ pewelectionsbythenumberspdf.pdf ........................................................................................... 20
Press Release, Ralph Northam, Governor of Virginia, Governor Northam Announces New Measures to Combat COVID-19 and Support Impacted Virginians (Mar. 17, 2020), https://www.governor.virginia.gov/newsroom/all-releases/2020/march/headline-854487en.html ........................................................................................................................................ 8
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Press Release, Ralph Northam, Governor of Virginia, Governor Northam Announces Plans to Postpone Upcoming Virginia Elections in Response to COVID-19 (Apr. 8, 2020), https://www.governor.virginia.gov/newsroom/all-releases/2020/april/headline-855995 -en.html ..................................................................................................................................... 10
Press Release, Ralph Northam, Governor of Virginia, Governor Northam Issues Statewide Stay at Home Order (Mar. 30, 2020), https://www.governor.virginia.gov/newsroom/allreleases/2020/march/headline-855702-en.html .......................................................................... 8
Press Release, Ralph Northam, Governor of Virginia, Governor Northam Orders All Virginia K-12 Schools Closed for Minimum of Two Weeks (Mar. 13, 2020), https://www.governor.virginia.gov/newsroom/all-releases/2020/march/headline-854442en.html ........................................................................................................................................ 8
Press Release, Ralph Northam, Governor of Virginia, Governor Northam Orders Statewide Closure of Certain Non-Essential Businesses, K-12 Schools (Mar. 23, 2020), https://www.governor.virginia.gov/newsroom/all-releases/2020/march/headline-855292en.html ........................................................................................................................................ 8
Press Release, Ralph Northam, Governor of Virginia, Virginia Receives Major Disaster Declaration from Federal Government for COVID-19 (Apr. 2, 2020), https://www.governor.virginia.gov/newsroom/all-releases/2020/april/headline-855921 -en.html ....................................................................................................................................... 8
Press Release, United States Postal Service, USPS Statement on Coronavirus (Apr. 2, 2020), https://about.usps.com/newsroom/statements/usps-statement-on-coronavirus.htm (citing guidance from World Health Organization, CDC, and Surgeon General) ................................. 6
Rick Noack, et al., White House Task Force Projects 100,000 to 240,000 Deaths in U.S., Even With Mitigation Efforts, Washington Post, Apr. 1, 2020, https://www.washingtonpost.com/world/2020/03/31/coronavirus-latest-news/......................... 4
Riley Vetterkind, Absentee ballot requests in Wisconsin already exceed number in recent spring elections, Wisconsin State Journal, Mar. 18, 2020, https://madison.com/wsj/news/local/govt-and-politics/absentee-ballot-requests-inwisconsin-already-exceed-number-in-recent-spring-elections/article_dfb34fc5-6aa8-542890c3-26c3f82a1d70.html .......................................................................................................... 21
Rudy Mehrbani, Heritage Fraud Database: An Assessment, The Brennan Center, Sept. 8, 2017, https://www.brennancenter.org/our-work/research-reports/heritage-frauddatabase-assessment.................................................................................................................. 29
The Heritage Foundation, Election Fraud Cases, https://www.heritage.org/voterfraud/search?state=VA (last visited Apr. 21, 2020) ................ 29
Va. Dep’t of Elections, Absentee Ballots, https://www.elections.virginia.gov/casting-aballot/absentee-voting/ (last visited Apr. 15, 2020)............................................................ 11, 22
Va. Dep’t of Elections, Certified Candidates in Ballot Order for June 9 Primary Elections, https://www.elections.virginia.gov/media/castyourballot/candidatelist/June-2020-PrimaryCandidates-List-(3).pdf (last visited Apr. 19, 2020)................................................................. 10
Va. Dep’t of Elections, November General Elections: 1976 – Present, https://www.elections.virginia.gov/resultsreports/registrationturnout-statistics/ (last visited Apr. 21, 2020................................................................................................................. 29
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Va. Dep’t of Elections, Registration Statistics and Polling Places, https://www.elections.virginia.gov/resultsreports/registration-statistics/ (last visited Apr. 18, 2020) ..................................................................................................................... 14, 21
Va. Dep’t of Health, COVID-19 Cases in Virginia, http://www.vdh.virginia.gov/coronavirus/ (last visited Apr. 21, 2020) ......................................................................................................... 9
Va. Dep’t of Health, Schools, Workplaces & Community Locations, http://www.vdh.virginia.gov/coronavirus/schools-workplaces-community-locations/ (last visited Apr. 15, 2020) ................................................................................................... 6, 34
Va. Exec. Order No. 2020-51 (Mar. 12, 2020), https://www.governor.virginia.gov/media/governorvirginiagov/governor-ofvirginia/pdf/eo/EO-51-Declaration-of-a-State-of-Emergency-Due-to-NovelCoronavirus-(COVID-19).pdf .................................................................................................... 8
Va. Exec. Order No. 2020-55 (Mar. 30, 2020) ..................................................................... 1, 9, 30 Wisc. Election Comm’n, Absentee Ballot Report - April 7, 2020 Spring Election and
Presidential Preference Primary, https://elections.wi.gov/node/6833 ...................................... 21 World Health Organization, Q&A on Coronaviruses (COVID-19), “Should I Worry About
COVID-19?,” https://www.who.int/news-room/q-a-detail/q-a-coronaviruses (last visited Apr. 16, 2020) ......................................................................................................... 4 Worldometer, Age, Sex, Existing Conditions of COVID-19 Cases and Deaths Chart, https://www.worldometers.info/coronavirus/coronavirus-age-sex-demographics/ .................... 5
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INTRODUCTION COVID-19 has upended our lives in ways few of us could have predicted just weeks ago. But individuals must maintain their fundamental right to vote in these extraordinary times. This case concerns a requirement that threatens thousands of Virginians’ right to vote during this pandemic—Virginia’s witness requirement for absentee ballots, the rule that voters submitting mail ballots must have another individual observe them open their ballot envelope, and then sign as a witness on the voter’s envelope. In normal times, the witness requirement was an ineffectual policy, but perhaps only a minor-to-moderate burden on the right to vote. During the pandemic, however, it will force thousands of voters to choose between disenfranchisement and placing their health at grave risk. Indeed, approximately one-quarter of Virginians of voting age—more than one million people, including individual Plaintiffs and some members of the League of Women Voters of Virginia (the “League”)—live by themselves. The witness requirement will require them to do precisely the opposite of what the Commonwealth has demanded in the current public health emergency. The Governor has ordered the closure of all schools and non-essential businesses, and has issued a statewide “Stay at Home” order,1 advising all Virginians to minimize “human-to-human contact” and to “practice social distancing” in light of the ongoing “public health crisis.”2 But the witness requirement will require many thousands of Virginia voters to flout that order, and venture from the safety of their homes in search of another adult willing to come in close enough
1 Va. Exec. Order No. 2020-55 (Mar. 30, 2020), https://www.governor.virginia.gov/media/governorvirginiagov/executive-actions/EO-55-Temporary-Stay-at-HomeOrder-Due-to-Novel-Coronavirus-(COVID-19).pdf. 2 Press Release, Ralph Northam, Governor of Virginia, Governor Northam Issues Statewide Stay at Home Order (Mar. 30, 2020), https://www.governor.virginia.gov/newsroom/all-releases/2020/march/headline-855702-en.html.
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physical proximity to witness and sign their absentee ballots. As explained by Plaintiffs’ expert Dr. Arthur Reingold—Head of Epidemiology and Biostatistics at the University of California at Berkeley—such person-to-person interaction carries substantial risks of exposure to and/or transmission of COVID-19.
Plaintiffs are thus likely to succeed on their claim that the witness requirement unconstitutionally burdens the fundamental right to vote. Without a preliminary injunction, thousands of Virginia voters—including individual Plaintiffs Goff and Toogood and a number of League members—will be forced to choose between accepting disenfranchisement or violating the social distancing rules that the Commonwealth itself has determined are critical to preserving public health. That amounts to a severe burden on the right to vote, meriting at least heightened, if not strict, scrutiny, which the witness requirement cannot survive. The witness requirement does little if anything to serve the government interest of election integrity, let alone in an appropriately tailored manner to justify the impending and irreparable harm that it will wreak on Virginia voters. It imposes an undue burden on the right to vote and is therefore unconstitutional.
Finally, the balance of the equities and the public interest also support a preliminary injunction, which will both vindicate the dual public interests of ensuring all qualified voters can vote in June and protecting public health with little if any burden on Defendants. This Court must evaluate the witness requirement in light of the present and impending circumstances that Plaintiffs and other Virginia voters face. Without relief, thousands of Virginia voters will be forced to risk their health in order to vote—or simply not have their voices heard at all. Plaintiffs therefore request the Court grant a preliminary injunction against the witness requirement for the June 23 primary, and for any and all subsequent elections in Virginia until such time as in-person
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interactions required by compliance with the witness requirement no longer pose a risk to public health and personal safety.
FACTUAL BACKGROUND A. The COVID-19 Pandemic
The “United States is now the ‘epicenter’ of the global [COVID-19] pandemic and has far more confirmed COVID-19 cases than any other nation.”3 As Plaintiffs’ expert Dr. Arthur Reingold explains in his testimony, the novel coronavirus, SARS-CoV-2, causes individuals to contract COVID-19, a disease that is now a global pandemic.4 Declaration of Dr. Arthur Reingold ¶ 7 (attached as Ex. A). Dr. Reingold is a medical doctor, a public health expert in the area of infectious diseases and epidemiology, and the Division Head of Epidemiology and Biostatistics at the University of California, Berkeley, School of Public Health. Reingold Decl. ¶¶ 1, 3. He spent eight years at the Centers for Disease Control and Prevention (“CDC”), has directed or co-directed the CDC-funded California Emerging Infections Program for more than 25 years, and was previously the President of both the Society for Epidemiologic Research and the American Epidemiological Society. Id. ¶ 1.
COVID-19 spreads mainly from person-to-person through close contact with one another and through respiratory droplets when an infected person coughs or sneezes.5 Medical experts are continuing to learn more about the ease with which the COVID-19 spreads, including
3 General Order No. 2020-11, In re: Court Operations Under the Exigent Circumstances Created by the Outbreak of Coronavirus Disease (COVID-19): Temporary Policy for Remote Proceedings and Public Access to Such Proceedings, Case No. 2:20mc7 (E.D. Va. Apr. 6, 2020). 4 Betsy McKay et al., Coronavirus Declared Pandemic by World Health Organization, Wall Street Journal, Mar. 11, 2020, https://www.wsj.com/articles/u-s-coronavirus-cases-top-1-000-11583917794. 5 Centers for Disease Control and Prevention, How COVID-19 Spreads, https://www.cdc.gov/coronavirus/2019ncov/prevent-getting-sick/how-covid-spreads.html (last visited Apr. 6, 2020).
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whether it is “aerosolized, such that tiny droplets containing the virus remain in the air and can
be inhaled by others who come into contact with that air.” Reingold Decl. ¶ 8. 6 Recent studies
also indicate that people infected with the virus may transmit it to others even without showing
symptoms themselves.7
COVID-19 can cause severe consequences, including long-term illness and death.
Reingold Decl. ¶ 7. The World Health Organization (WHO) estimates that approximately 20 percent of those infected by COVID-19 require hospitalization.8 Estimates from early March put
the fatality rate for people infected with COVID-19 at approximately ten times higher than influenza even in a severe season and including in countries with advanced health care systems.9
Top scientists recently estimated that COVID-19 could kill between 100,000 and 240,000
Americans, with an even higher number possible if Americans do not follow strict social
distancing guidelines.10 COVID-19 threatens to infect any individual no matter their age. Reingold Decl. ¶ 7.11
Between February 1 and March 16, 2020, 55% of reported cases in the United States occurred in
6 See also Elizabeth Cohen, Experts tell White House coronavirus can spread through talking or even just breathing, CNN, Apr. 4, 2020, https://www.cnn.com/2020/04/02/health/aerosol-coronavirus-spread-white-houseletter/index.html. 7 See, e.g., Centers for Disease Control and Prevention, How COVID-19 Spreads, https://www.cdc.gov/coronavirus/2019-ncov/prevent-getting-sick/how-covid-spreads.html (last visited Apr. 6, 2020). 8 World Health Organization, Q&A on Coronaviruses (COVID-19), “Should I Worry About COVID-19?,” https://www.who.int/news-room/q-a-detail/q-a-coronaviruses (last visited Apr. 16, 2020). 9 Betsy McKay, Coronavirus vs. Flu Which Virus is Deadlier, Wall Street Journal, Mar. 10, 2020, https://www.wsj.com/articles/coronavirus-vs-flu-which-virus-is-deadlier-11583856879. 10 See, e.g., Rick Noack et al., White House Task Force Projects 100,000 to 240,000 Deaths in U.S., Even With Mitigation Efforts, Washington Post, Apr. 1, 2020, https://www.washingtonpost.com/world/2020/03/31/coronaviruslatest-news/. 11 See also CDC COVID-19 Response Team, Severe Outcomes Among Patients with Coronavirus Disease 2019 (COVID-19)—United States, February 12 – March 16, 2020, CDC.gov, https://www.cdc.gov/mmwr/volumes/69/wr/mm6912e2.htm (last updated Mar. 26, 2020).
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people between the ages of 20-64.12 As of March 16, 20 percent of those hospitalized due to COVID-19 in the United States were between the ages of 20 and 44.13
While people of all ages have contracted and died from COVID-19, it is particularly fatal
for older individuals. Reingold Decl. ¶ 7. Preliminary reports based on WHO data show a 3.6%
mortality rate for individuals between 60-69 years old, an 8% mortality rate for those 70-79 years old, and a 14.8% mortality rate for those who are 80 years old or older.14 COVID-19 also poses
greater risks for people with preexisting heart and respiratory conditions including asthma,
individuals with compromised immune systems, and those with many other conditions. Reingold Decl. ¶ 7.15
B. Public Health Guidance Regarding COVID-19
Because no vaccine currently exists and will likely not for at least another year, at least
for the public at large, Reingold Decl. ¶ 13, public health experts have explained that social
distancing measures including maintaining at least six feet of space between people (as well as
consistent hygiene practices) are the only known effective measures for protecting against transmission of COVID-19, id. ¶ 10.16 Accordingly, the Virginia Department of Health (“VDH”)
12 CDC COVID-19 Response Team, Severe Outcomes Among Patients with Coronavirus Disease 2019 (COVID19)—United States, February 12 – March 16, 2020, CDC.gov, https://www.cdc.gov/mmwr/volumes/69/wr/mm6912e2.htm (last updated Mar. 26, 2020). 13 Id. 14 Worldometer, Age, Sex, Existing Conditions of COVID-19 Cases and Deaths Chart, https://www.worldometers.info/coronavirus/coronavirus-age-sex-demographics/ (data analysis based on WHO China Joint Mission Report and Chinese CCDC report published in the Chinese Journal of Epidemiology) (last visited Apr. 16, 2020). 15 See also Centers for Disease Control and Prevention, Groups at Higher Risk of Severe Illness, https://www.cdc.gov/coronavirus/2019-ncov/need-extra-precautions/groups-at-higher-risk.html (last visited Apr. 15, 2020). 16 See also Johns Hopkins University, Coronavirus, Social Distancing and Self-Quarantine, https://www.hopkinsmedicine.org/health/conditions-and-diseases/coronavirus/coronavirus-social-distancing-andself-quarantine (last visited Apr. 15, 2020).
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has “urge[d] all Virginians to stay home and practice social distancing” and to “stay at least 6 feet away from others” if going out.17 VDH’s “Guiding Principles for Community Mitigation Strategies” also require considering “all aspects of a community that might be impacted, including populations most vulnerable to severe illness and those that may be more impacted socially or economically.”18
The CDC has also issued guidelines concerning voting during the COVID-19 pandemic. Among other things, it recommends that states “[e]ncourage voters to use voting methods that minimize direct contact with other people and reduce crowd size at polling stations” including “mail-in methods of voting if allowed in the jurisdiction.”19 This is because there is no evidence that SARS-COV-2—the virus that causes COVID-19—is being spread through the mail.20 Medical consequences from substantial in-person voting are beginning to emerge after recent primaries. In Chicago, a March 17 primary worker died from COVID-19, prompting officials to send letters notifying voters, poll workers, field investigators, and cartage companies who were present at the same polling site. 21 At least one other person in Chicago recently tested positive
17 Id. 18 Va. Dep’t of Health, Schools, Workplaces & Community Locations, http://www.vdh.virginia.gov/coronavirus/schools-workplaces-community-locations/ (last visited Apr. 15, 2020). 19 Centers for Disease Control and Prevention, Recommendations for Election Polling Locations: Interim guidance to prevent spread of coronavirus disease 2019 (COVID-19), https://www.cdc.gov/coronavirus/2019ncov/community/election-polling-locations.html (last updated Mar. 27, 2020). 20 Press Release, United States Postal Service, USPS Statement on Coronavirus (Apr. 2, 2020), https://about.usps.com/newsroom/statements/usps-statement-on-coronavirus.htm (citing guidance from World Health Organization, CDC, and Surgeon General). 21 Mary Ann Ahern, Poll Worker at Chicago Voting Site Dies of Coronavirus, Election Officials Say, NBC Chicago, Apr. 13, 2020, https://www.nbcchicago.com/news/local/chicago-politics/poll-worker-at-chicago-voting-site-dies-ofcoronavirus-election-officials-say/2255072/.
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for COVID-19 after voting in person as well.22 In Florida, two Broward County poll workers
tested positive for COVID-19, one of whom was handling driver’s licenses as part of the identification verification process.23 And numerous experts—including Wisconsin’s Secretary of
Health Services—predicted that the lines at polling places on primary day due to many
Wisconsinites being unable to timely vote absentee would increase case total and “would result in more deaths.”24 And as Dr. Reingold testifies, evidence from Milwaukee health authorities
that Milwaukee has already identified seven COVID-19 cases linked to people voting in-person
April 7 further confirms the personal and public health risks associated with in-person voting. Reingold Decl. ¶ 17.25
C. The Effect and Consequences of COVID-19 in Virginia In response to the pandemic, Governor Northam declared a State of Emergency for
Virginia “to continue to prepare and coordinate our response to the potential spread of COVID19.”26 On March 13, he closed all Virginia K-12 schools for two weeks, and has now extended
22 NBC Chicago, Gov. Pritzker Encourages Illinoisans to Vote by Mail After In-Person Voter Tests Positive for Coronavirus, Apr. 12, 2020, https://www.nbcchicago.com/news/local/gov-pritzker-encourages-illinoisans-to-voteby-mail-in-upcoming-general-election/2254687/. 23 Anthony Man, Two Broward poll workers, including one who handled voters’ driver licenses, test positive for coronavirus, South Florida Sun Sentinel, Mar. 26, 2020, https://www.sun-sentinel.com/coronavirus/fl-ne-browardelections-poll-workers-coronavirus-20200326-wmgy775dvjc5jis2oagxlpmule-story.html. 24 Devi Shastri, In-person voting was likely a ‘disaster’ for Wisconsin’s efforts to flatten coronavirus curve, national experts say, Milwaukee Journal Sentinel, Apr. 8, 2020, https://www.jsonline.com/story/news/politics/elections/2020/04/08/coronavirus-wisconsin-election-likely-hurteffort-flatten-curve/2961718001/. 25 See also Alex Seitz-Wald, 7 Wisconsin coronavirus infections linked to election day, health official says, NBC News, Apr. 21, 2020, https://www.nbcnews.com/politics/2020-election/7-wisconsin-virus-cases-linked-personvoting-n1188606. 26 Va. Exec. Order No. 2020-51 (Mar. 12, 2020), https://www.governor.virginia.gov/media/governorvirginiagov/governor-of-virginia/pdf/eo/EO-51-Declaration-of-aState-of-Emergency-Due-to-Novel-Coronavirus-(COVID-19).pdf.
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that order for the remainder of the academic year.27 The Governor advised on March 17 that
Virginians “with chronic health conditions or aged 65 or older should self-quarantine,” and ordered all DMV offices closed.28 On March 23, Gov. Northam ordered all non-essential businesses closed until at least April 23 and banned public gatherings of more than 10 people.29
On March 30, Gov. Northam issued a statewide “Stay at Home” order to last until June
10, directing all Virginians to stay at home except under extremely limited circumstances. He
added: “We are in a public health crisis, and we need everyone to take this seriously and act
responsibly. Our message to Virginians is clear: stay home. We know this virus spreads
primarily through human-to-human contact, and that’s why it’s so important that people follow this order and practice social distancing.”30 Virginia received a Major Disaster Declaration from the federal government on April 2.31
27 Press Release, Ralph Northam, Governor of Virginia, Governor Northam Orders All Virginia K-12 Schools Closed for Minimum of Two Weeks (Mar. 13, 2020), https://www.governor.virginia.gov/newsroom/allreleases/2020/march/headline-854442-en.html; Press Release, Ralph Northam, Governor of Virginia, Governor Northam Orders Statewide Closure of Certain Non-Essential Businesses, K-12 Schools (Mar. 23, 2020), https://www.governor.virginia.gov/newsroom/all-releases/2020/march/headline-855292-en.html. 28 Press Release, Ralph Northam, Governor of Virginia, Governor Northam Announces New Measures to Combat COVID-19 and Support Impacted Virginians (Mar. 17, 2020), https://www.governor.virginia.gov/newsroom/allreleases/2020/march/headline-854487-en.html. 29 Press Release, Ralph Northam, Governor of Virginia, Governor Northam Orders Statewide Closure of Certain Non-Essential Businesses, K-12 Schools (Mar. 23, 2020), https://www.governor.virginia.gov/newsroom/allreleases/2020/march/headline-855292-en.html. 30 Va. Exec. Order No. 2020-55 (Mar. 30, 2020), https://www.governor.virginia.gov/media/governorvirginiagov/executive-actions/EO-55-Temporary-Stay-at-HomeOrder-Due-to-Novel-Coronavirus-(COVID-19).pdf; Press Release, Ralph Northam, Governor of Virginia, Governor Northam Issues Statewide Stay at Home Order (Mar. 30, 2020), https://www.governor.virginia.gov/newsroom/allreleases/2020/march/headline-855702-en.html (emphasis added). 31 Press Release, Ralph Northam, Governor of Virginia, Virginia Receives Major Disaster Declaration from Federal Government for COVID-19 (Apr. 2, 2020), https://www.governor.virginia.gov/newsroom/allreleases/2020/april/headline-855921-en.html.
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On March 31, 2020, the Virginia Department of Health (VDH) reported “widespread community transmission across the state.”32 And as of April 21, VDH reported over 9,600 COVID-19 diagnoses in Virginia, resulting in 1,581 hospitalizations and 324 deaths.33 The evidence suggests that community transmission of COVID-19 in Virginia and elsewhere will persist for at least the next several months as season changes are “unlikely to stop transmission.”34 As Dr. Reingold testifies, “transmission of the virus will continue through the population until the development and widespread use of a vaccine and/or herd immunity.” Reingold Decl. ¶ 12. And because certain other coronaviruses like SARS and MERS-CoV “do not appear to demonstrate seasonality of infection” and because the “current virus has circulated widely in countries currently in their hot seasons,” these points “suggest that transmission of and infection with the virus may not be affected by the weather.” Id. In Virginia, researchers from the University of Virginia project mid-August as the most likely peak for COVID-19 in the Commonwealth.35
D. Virginia’s Upcoming Elections Virginia originally had elections for many local races for scheduled for May 5, and a
primary for federal races on June 9, but Governor Northam recently moved the June primary elections to June 23, 2020, and requested that the General Assembly move the May elections to
32 Va. Dep’t of Health, COVID-19 Cases in Virginia, http://www.vdh.virginia.gov/coronavirus/ (last visited Apr. 21, 2020). 33 Id. 34 Marc Lipsitch, DPhil, Professor of Epidemiology and Director, Center for Communicable Disease Dynamics, Harvard T.H. Chan School of Public Health, Seasonality of SARS-CoV-2: Will COVID-19 go away on its own in warmer weather?, https://ccdd.hsph.harvard.edu/will-covid-19-go-away-on-its-own-in-warmer-weather/. 35 Mel Leonor & Justin Mattingly, UVA researchers project mid-August peak for new COVID-19 cases in Virginia, Richmond Times Dispatch, Apr. 13, 2020, https://www.richmond.com/special-report/coronavirus/uvaresearchersproject-mid-august-peak-for-new-covid-19-cases-in-virginia/article_c4e2c008-1617-52d8-ad08-706abfb3d696.html.
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November. He took these actions “to further mitigate the spread of COVID-19” and for purposes of “protecting the health and safety of Virginians during this pandemic and ensuring our citizens can make their voices heard in a safe, fair, and uniform manner.”36
Virginia is holding both Democratic and Republican primaries on June 23. For Democrats, there are primary elections for Congress in Virginia’s First, Fourth, Fifth, and Eleventh districts as well as for local offices in Arlington County and Manassas and Manassas Park cities.37 For Republicans, there are primary elections for Congress in Virginia’s Second and Third districts, as well as a statewide primary for U.S. Senate.38 Absentee ballot applications submitted by mail for these races must be received by the appropriate registrar no later than June 16 at 5 PM. Va. Code § 24.2-701(B)(2). Completed absentee ballots must be returned to the registrar by the close of polls on Election Day. Va. Code § 24.2-709.
E. Virginia’s Absentee Ballot Process and the Challenged Witness Requirement Governor Northam recently signed legislation eliminating the requirement of having an
“excuse” in order to vote by mail absentee ballot. Though this no-excuse absentee rule will not take effect until after the June primary, the Department of Elections has stated that Virginia registered voters may apply for and submit an absentee ballot for the June election by choosing reason “2A My disability or illness” due to COVID-19. The Department has “encourage[d] voters to protect their health during COVID-19 outbreak,” and has noted on its website that
36 Press Release, Ralph Northam, Governor of Virginia, Governor Northam Announces Plans to Postpone Upcoming Virginia Elections in Response to COVID-19 (Apr. 8, 2020), https://www.governor.virginia.gov/newsroom/allreleases/2020/april/headline-855995-en.html. 37 Va. Dep’t of Elections, Certified Candidates in Ballot Order for June 9 Primary Elections, https://www.elections.virginia.gov/media/castyourballot/candidatelist/June-2020-Primary-Candidates-List-(3).pdf (last visited Apr. 19, 2020). 38 Id.
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absentee voting for the upcoming elections “is strongly encouraged.”39 Although the Commissioner also has “authority to designate alternative methods and procedures to handle [absentee] applications and ballots” in emergency situations, Va. Code § 24.2-713, he has not exercised this power beyond offering the above interpretation of the disability/illness exception.
Individuals may request an absentee ballot online or by sending in a mail request.40 They must sign the application “subject to felony penalties for making false statements” that the “facts contained in the application are true and correct” and they “will not vote in the election at any other place in Virginia or in any other state.” Va. Code § 24.2-701(B)(1).41
When a registrar receives an absentee ballot application and verifies that the individual properly completed the application and is a registered voter in the jurisdiction, the registrar mails to the individual:
• A sealed envelope containing the unmarked ballot; • An envelope for resealing the marked ballot with a “Statement of Voter,” and spaces
for the voter to sign and date and for a witness to sign. The “Statement of Voter” informs voters, among other things, that their signature certifies “subject to felony penalties for making false statements,” their name, legal residence, that they received the ballot after requesting it, that they opened the ballot envelope “in the presence of the witness” but without assistance, that they sealed the ballot in the envelope, and that they “have not voted and will not vote in this election at any other time or place”; • A pre-addressed envelope to mail the ballot to the general registrar; and • Instructions for completing the ballot and envelope statement and returning the ballot.
39 Va. Dep’t of Elections, Absentee Ballots, https://www.elections.virginia.gov/casting-a-ballot/absentee-voting/ (last visited Apr. 15, 2020). 40 Id. 41 An exception exists for individuals who cannot sign due to disability, in which case “a person assisting the applicant will note this fact on the applicant signature line and provide his signature, name, and address.” Id.
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Va. Code § 24.2-706(B). When voters receive their absentee ballots, they “shall, in the presence of a witness, (i) open the sealed envelope marked ‘ballot within’ and (ii) mark and refold the ballot . . . without assistance and without” indicating how they marked the ballot. Va. Code § 24.2-707(A). Once voters mark their ballots, they must seal the ballot in its envelope, “fill in and sign the statement printed on the back of the envelope in the presence of a witness, who shall sign the same envelope,” and enclose the ballot envelope in another envelope and mail or deliver it to the general registrar. Id.
When the absentee ballot process counting begins, election officers examine each absentee ballot envelope to determine whether to accept the ballot for counting. Va. Code § 24.2711 provides that the voter’s failure to provide a middle name, middle initial, or the date shall not be grounds for rejecting the ballot, but is silent as to other requirements including the witness signature. Regulations promulgated by the Board, however, state that the lack of a witness signature on the envelope of the absentee ballot is an omission that is “always material” and such ballots “shall be rendered invalid,” 1 Va. Admin. Code 20-70-20(B). These same regulations also state that the illegibility of the witness signature shall not be grounds for rejecting the ballot, even though there is no requirement to identify the witness. Id.
Virginia statutes and regulations provide no process by which voters may correct any errors on their absentee ballot envelopes after they are mailed to the general registrar, and in practice all absentee ballots lacking a witness signature are rejected as a matter of course without any effort to verify whether the absentee ballot came from the intended voter. Declaration of Stephanie Iles ¶ 8 (attached as Ex. B). Voters whose ballots are rejected because of a lack of a witness signature do not learn of this until after the election, when the electoral board “sends[s] a written explanation of the reason for rejection of an absentee ballot to the voter whose absentee
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ballot is rejected within 90 days of the date on which the ballot is rejected.” Va. Code § 24.2711.1(B).
F. Virginia’s Laws Supporting Absentee Voting Election Integrity Virginia has a number of different laws designed to ensure the integrity of absentee
balloting procedures, but is only one of eleven states with a witness or notarization requirement.42 For one, Virginia registrars maintain a list of voters who applied for and returned absentee ballots, and that list is attested to by the secretary of the electoral board and delivered to the chief officer of election for each precinct. Absentee ballots are only accepted “from voters whose names appear on the attested list.” Va. Code § 24.2-710. And voters themselves must attest under penalty of perjury their identity, residence, and that they did not double vote when they sign their ballot envelope. Va. Code § 24.2-706.
Virginia also has several criminal provisions aimed at discouraging misuse of absentee ballots. A person who “intentionally votes more than once in the same election” commits a Class 6 felony. Va. Code § 24.2-1004(B). Similarly, any “willfully false material statement or entry made by any person” on any ballot constitutes “the crime of election fraud and be punishable as a Class 5 felony.” Va. Code § 24.2-1016. And any person “attempting to vote by fraudulently signing the name of a qualified voter shall be guilty of forgery and shall be guilty of a Class 4 felony.” Va. Code § 24.2-1012.
42 See Chart, “Verifying Authenticity of Absentee/Mailed Ballots,” Voting Outside the Polling Place: Absentee, AllMail and other Voting at Home Options, Nat’l Conf. of State Legislatures (Apr. 3, 2020), https://www.ncsl.org/research/elections-and-campaigns/absentee-and-early-voting.aspx; cf. Ala. Code §§ 17-930(b), 17-11-7, 17-11-10; Alaska Stat. § 15.20.030; La. Stat. Ann. § 18:1306(2)(a); Miss. Code Ann. §§ 23-15-627, 23-15-635, 23-15-633; Mo. Rev. Stat. §§ 115.279, 115.283, 115.295; N.C. Gen. Stat. § 163-231; Okla. Stat. tit. 26, § 14-108; 17 R.I. Gen. Laws § 17-20-23; S.C. Code Ann. §§ 7-15- 220, 7-15-230; Wis. Stat. § 6.87(4)(b)(1).
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G. The Public Health and Disenfranchisement Consequences of Virginia’s Absentee Witness Requirement During Significant COVID-19 Transmission According to Dr. Reingold, for “individuals without another person able to witness in
their household, the requirement that they have someone witness their absentee ballot would place them at increased risk of exposure to and/or transmission of COVID-19.” Reingold Decl. ¶ 17. This is because coming “in close enough proximity to witness their ballot would place them at increased risk of infection,” and “would be particularly risky for those who are at a greater risk of complications and death from COVID-19.” Id. And for public health purposes, “to prevent increasing the scope of the outbreak of COVID-19, we must assume that anyone could be infected and infect another person.” Id. ¶ 11.
In terms of how many Virginians of voting age live by themselves, as of 2018, Census Bureau figures identify that 25.3% of Virginians 18 and older live alone, while 33% of Virginians 65 and older live alone. Ex. A to Declaration of Davin Rosborough (attached as Ex. C) (data table from 2018 Current Population Survey). For Virginians with a disability who are 18 and older, 37.2% live alone, with 44% of those 65 and older living by themselves. Id. And 31% of African-American Virginians 18 and older live alone, much higher than the state average. Id. Assuming these numbers apply roughly evenly across Virginia’s 5.73 million registered voters,43 this means that more than 1.4 million Virginia voters likely live alone. In Virginia’s June 2018 primary, more than 541,000 Virginians cast ballots,44 meaning that more than 135,000 of these absentee voters likely lived alone.
43 Va. Dep’t of Elections, Registration Statistics and Polling Places, https://www.elections.virginia.gov/resultsreports/registration-statistics/ (last visited Apr. 18, 2020). 44 See Exs. B, C to Rosborough Decl. (turnout data from Va. Dep’t of Elections for June 2018 primaries).
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Not only do African Americans live alone in larger percentages, but as Governor Northam has acknowledged, racial inequities make African-American Virginians “more likely to have some of the underlying health conditions that put them at greater risk with COVID-19.”45 In states where the demographic data is available, African-Americans have made up 42% of people who have died from COVID-19, despite accounting for roughly only 21% of the total population in these areas.46 In Virginia, the available data shows that African Americans constitute approximately 20% of Virginia’s population, but make up about 30% of the total number of reported positive cases.”47
In the City of Norfolk, which is holding municipal elections on May 5 if not rescheduled by the General Assembly, Stephanie Iles, Director of Elections and General Registrar for the City of Norfolk, has already noticed a number of absentee ballots without a witness signature, including one with a handwritten note from the voter saying they were unable to get a witness because they are complying with the Governor’s stay at home and social distancing order. Iles Decl. ¶¶ 6–7. And her office has taken calls from other voters concerned about this issue. Id. ¶ 7.
H. Injuries and Irreparable Harm to Plaintiffs Individual Plaintiffs Erikka Goff and Seijra Toogood are Virginia registered voters who
consistently vote in Virginia elections and wish to vote in the upcoming June 23 primary for their respective congressional districts. Declaration of Erikka Goff ¶¶ 3–4 (attached as Ex. D);
45 Neal Augenstein, Virginia governor seeks more data on how COVID-19 affects minorities, WTOP, Apr. 9, 2020, https://wtop.com/virginia/2020/04/virginia-governor-seeks-more-data-on-how-covid-19-affects-minorities/. 46 Kat Stafford, et al., Outcry over racial data grows as virus slams black Americans, Associated Press, Apr. 8, 2020, https://apnews.com/71d952faad4a2a5d14441534f7230c7c?fbclid=IwAR1plunY_qfeA2KrSUPA1TuJobAwQh53a_ Qlkf5dw0dWjz-iz85GA1FOt4. 47 Nana-Séntuo Bonsu, Disproportionate numbers appearing in African American COVID-19 cases in Virginia; doctor explains, WKTR, Apr. 10, 2020, https://www.wtkr.com/news/disproportionate-numbers-appearing-inafricanafrican-covid-19-cases-in-virginia-doctor-explains.
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Declaration of Seijra Toogood ¶¶ 1, 3 (attached as Ex. E). Following the recommendations of public health officials and the Virginia Department of Elections, both wish to vote by absentee ballot because of the risk of COVID-19 transmission from voting in person. Goff Decl. ¶ 10; Toogood Decl. ¶ 8. Both live by themselves, however, and will have to violate social distancing guidelines to have their absentee ballots witnessed or counted. Goff Decl. ¶¶ 5, 8; Toogood Decl. ¶¶ 4, 8. Because of the risk of COVID-19 transmission, both Plaintiffs will be disenfranchised in the June primary if the witness requirement remains in place because they will not risk their health to break social distancing guidelines. Goff Decl. ¶ 9; Toogood Decl. ¶ 9. This is particularly true for Plaintiff Toogood, who believes she runs a higher risk for COVID-19 complications due to her asthma and underlying heart condition. Toogood Decl. ¶¶ 5–6.
Plaintiff League of Women Voters of Virginia has a mission of encouraging informed and active participation in government, and influencing public policy through education and advocacy. Declaration of Debora Wake ¶ 2 (attached as Ex. F). The League has nearly 2,000 members across Virginia. Id. Some of these members, like Pat McGrady, Anne Claar, and Joan Porte, live alone and like the individual Plaintiffs, they wish to preserve their health by voting in the June primary by absentee ballot but will be unable to do so without violating social distancing guidelines to have their ballot witnessed. Id. ¶ 7. This is a particular risk of certain of these League members, who are older than 60 years old and/or have underlying health conditions that put them at greater risk for serious injury or death from COVID-19. Id. The League has spoken with Virginia voters who are not League members but find themselves in the same position—they live alone and will be disenfranchised in the June primary if the witness requirement remains in place. Id. ¶ 8.
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Dealing with the implications of witness requirement has also caused, and will continue to cause, the League to divert resources from other core activities such as voter registration, voter education, and voter mobilization activities to advocating against the witness requirement. Id. ¶ 9. It will also have to divert these resources to try to educate voters about the witness requirement should it remain in place, rather than “other critical activities including registering voters without being able to conduct in-person registration drives and educating voters about the many new laws passed by the 2020 General Assembly.” Id.
ARGUMENT A movant merits a preliminary injunction by showing (1) a likelihood of success on the merits, (2) likelihood of suffering irreparable harm, (3) the balance of hardships favor them, and (4) the injunction serves the public interest. Metro. Reg’l Info. Sys., Inc. v. Am. Home Realty Network, Inc., 722 F.3d 591, 595 (4th Cir. 2013) (citing Winter v. Nat. Res. Def. Council, Inc., 555 U.S. 7, 20 (2008)). Here, each factor decisively favors Plaintiffs. In evaluating the burdens on voters, the Court may and should “take judicial notice of official government reports and statistics” including election and voter registration statistics and public health reports from government agencies such as the CDC and VDH. United States v. Cecil, 836 F.2d 1431, 1452 (4th Cir. 1988) (internal citations omitted). I. Plaintiffs are likely to prevail on the merits because the First and Fourteenth Amendments require Virginia to eliminate the absentee witness requirement under the present circumstances. Plaintiffs “need not establish a ‘certainty of success,’” but they must “make a clear showing” they are likely to succeed. Di Biase v. SPX Corp., 872 F.3d 224, 230 (4th Cir. 2017). Here, Plaintiffs are highly likely to succeed on their claim because the First and Fourteenth Amendments do not permit a state to deprive tens of thousands of its qualified citizens of the
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right to vote or to have their vote counted by maintaining a witness requirement that runs counter to public health guidance and does little, if anything, to promote election integrity.
As the Supreme Court set forth in Anderson v. Celebrezze and Burdick v. Takushi, any government burden on the right to vote must be balanced against an important government interest. Burdick v. Takushi, 504 U.S. 428, 434 (1992) (citing Anderson v. Celebrezze, 460 U.S. 780, 788 (1983)). The Fourth Circuit describes the Anderson-Burdick framework as follows:
When facing any constitutional challenge to a state’s election laws, a court must first determine whether protected rights are severely burdened. If so, strict scrutiny applies. If not, the court must balance the character and magnitude of the burdens imposed against the extent to which the regulations advance the state’s interests in ensuring that “order, rather than chaos, is to accompany the democratic processes.” Fusaro v. Cogan, 930 F.3d 241, 257–58 (4th Cir. 2019) (quoting McLaughlin v. N.C. Bd. of Elections, 65 F.3d 1215, 1221 (4th Cir. 1995)). A. The absentee witness requirement merits at least heightened scrutiny because it will disenfranchise thousands of voters during the June primary while worsening a public health crisis. Under the first step of the Anderson-Burdick inquiry, the Court must assess whether, in the midst of the COVID-19 pandemic, requiring that Virginians either: (1) appear in-person at the polls, or (2) find another adult to witness and sign their absentee ballot envelope, severely or at least significantly burdens the right to vote. In considering the burdens imposed, the Court considers both the reach of the burden and the severity of the burden on the individuals it reaches. See Crawford v. Marion Cty. Election Bd., 553 U.S. 181, 198–99 (2008); see also One Wisconsin Inst., Inc. v. Thomsen, 198 F. Supp. 3d 896, 930 (W.D. Wis. 2016), order enforced, 351 F. Supp. 3d 1160 (W.D. Wis. 2019) (“the court must focus on the burdens that the challenged provisions place on eligible voters who cannot comply . . . .”) The fact that a majority of voters “are able to comply . . . does not mean that the burdens that these laws impose are
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constitutionally insignificant.” One Wisconsin, 198 F. Supp. 3d at 930. Because the “right to vote is personal,” an Anderson-Burdick claim “is not defeated by the fact that 99% of other people can” easily exercise the franchise despite the challenged provision. Frank v. Walker, 819 F.3d 384, 386 (7th Cir. 2016).
Here, the witness requirement will force, at a minimum, many thousands of voters who live alone to choose between putting themselves and others in serious physical jeopardy and forfeiting their fundamental right to vote in the June 23 primary, making the burden extreme both in its reach and in its depth. The Court should apply at least heightened, if not strict, scrutiny to this requirement because of its devastating effects on the franchise while COVID-19 ravages our communities.
As the state Circuit Court in Richmond recently found in applying strict scrutiny and striking down a candidate signature requirement, while under “normal circumstances” the requirement was a “a light burden,” the “circumstances as they exist in the Commonwealth of Virginia . . . are not normal right now.” Faulkner v. Va. Dep’t of Elections, No. CL 20-1546, Slip Op. at 2 (Va. Cir. Ct. Mar. 25, 2020) (attached as Ex. D to Rosborough Decl.); see also Esshaki v. Whitmer, No. 2:20-CV-10831-TGB, 2020 WL 1910154, at *1 (E.D. Mich. Apr. 20, 2020) (noting that “these are not normal times” in halving the number of candidate petition signatures required after Michigan “insist[ed] on enforcing the signature-gathering requirements as if its Stay-at-Home Order responding to the ongoing pandemic had no impact on the rights of candidates and the people who may wish to vote for them”).
1. The absentee witness requirement will severely burden many thousands of Virginia voters in the June primary.
In terms of its breadth, Virginia’s absentee witness requirement has the potential to disenfranchise up to a quarter of the electorate at worst and many thousands of voters at best.
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Even in normal, non-pandemic circumstances, Virginia’s witness requirement has caused election officials to reject the ballots of hundreds of voters. According to data from an Election Assistance Commission Survey, in the 2018 general election, at least 583 Virginia voters had their absentee ballots rejected for lack of a witness signature—a number that may still be a significant undercount given the inconsistency of local data collection required for this survey.48 See Ex. E to Rosborough Decl. (data from 2018 Election Administration and Voting Survey). But in that election, only 7.1% of voters voted by methods other than in-person on Election Day.49 Due to the COVID-19 pandemic, Virginia making absentee voting available to all Virginians for the June primary by use of the illness/disability excuse, and the Department of Elections encouraging vote by mail, absentee voting percentages should skyrocket for the June 23 primary. Even in Wisconsin, whose April 7 primary was beset by confusion and where thousands of individuals who did not receive their absentee ballots on time and were forced to wait in long lines at the polls,50 absentee ballot requests were five times higher in this year’s primary than in the 2016 primary.51 Under the present circumstances, the witness requirement will disenfranchise many thousands more voters than in 2018.
48 See, e.g., Pew Center on States, Election Administration by the Numbers An Analysis of Available Datasets and How to Use Them, Feb. 2012, https://www.pewtrusts.org/~/media/legacy/uploadedfiles/pcs_assets/2012/pewelectionsbythenumberspdf.pdf. 49 See Jordan Musra, Voter Turnout Rates Among All Voting Age and Major Racial and Ethnic Groups Were Higher Than in 2014, U.S. Census Bureau (Apr. 23, 2019), https://www.census.gov/library/stories/2019/04/behind-2018united-states-midterm-election-turnout.html. 50 Parker Schorr, Wisconsin’s pandemic election: Long waits, face masks as voters go to polls, The Capital Times, Apr. 8, 2020, https://madison.com/ct/news/local/govt-and-politics/wisconsin-s-pandemic-election-long-waitsfacemasks-as-voters-go-to-polls/article_bfd2c391-f390-5364-8c14-a88b548fe017.html; Benjamin Swasey, Wisconsin Vote Ends As Trump Blames Governor For Long Lines, NPR, Apr. 7, 2020, https://www.npr.org/2020/04/07/828835153/long-lines-masks-and-plexiglas-barriers-greet-wisconsin-voters-atpolls. 51 Compare Wisc. Election Comm’n, Absentee Ballot Report - April 7, 2020 Spring Election and Presidential Preference Primary, https://elections.wi.gov/node/6833 (reporting over 1.28 million absentee ballots requested for
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The most relevant group of people to consider are Virginia registered voters who live on their own. Because of the ongoing COVID-19 pandemic, many of these Virginians cannot obtain the necessary witness signature for their ballot envelopes without exposing themselves and others to a significant risk of infection for COVID-19. As Dr. Reingold explains, “[r]equiring individuals to have someone they are not otherwise being exposed to come into close enough proximity to witness their ballot would place them at increased risk of infection.” Reingold Decl. ¶ 17. This risk is even greater for those over 65, who “are at the greatest risk of severe cases, long-term impairment, and death.” Id. ¶ 17. Similarly, those with “with immunologic conditions” and “other pre-existing conditions” including, like Plaintiff Toogood, certain heart conditions and lung diseases like asthma, “are at high risk of a life-threatening COVID-19 illness.” Id. ¶ 17; Toogood Decl. ¶¶ 5–6. And African Americans are also contracting COVID-19 and dying in much higher percentages than the population as a whole, meaning the witness requirement particularly impacts African-American Virginians.
The number of Virginians who will be forced to either brave the polls or break social distancing guidelines to have someone witness and sign their ballot envelope are striking. As of 2018, 25.3% of Virginians 18 and older lived alone. Ex. A to Rosborough Decl. Applying that percentage to Virginia’s 5.73 million registered voters, 52 one can expect that well over 1.4 million Virginia voters live alone. Even focusing on the June primary alone and relying on statistics from Virginia’s June 2018 primary, this data suggests that more than 100,000 Virginia
April 7, 2020 primary) with Riley Vetterkind, Absentee ballot requests in Wisconsin already exceed number in recent spring elections, Wisconsin State Journal, Mar. 18, 2020, https://madison.com/wsj/news/local/govt-andpolitics/absentee-ballot-requests-in-wisconsin-already-exceed-number-in-recent-spring-elections/article_dfb34fc56aa8-5428-90c3-26c3f82a1d70.html (noting that just under 250,000 absentee ballots were requested for the spring 2016 Wisconsin primary). 52 Va. Dep’t of Elections, Registration Statistics and Polling Places, https://www.elections.virginia.gov/resultsreports/registration-statistics/ (last visited Apr. 18, 2020).
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voters will be severely burdened by the witness requirement in the upcoming primary. In the June 2018 primary—when no-excuse absentee voting was not yet permitted in Virginia—more than 541,000 Virginians cast ballots;53 if we apply the percentage of all Virginia adults who live alone to this figure, it would suggest that more than 135,000 absentee voters in the 2018 primary lived alone. And that figure likely understates the impact of the witness requirement in this year’s primary, given that any Virginia registered voter may vote an absentee ballot for the June election under the “disability or illness” excuse, and the Department of Elections is “strongly encourag[ing]” Virginians to vote by mail.54 Indeed, Wisconsin’s experience in its primary earlier this month—in which five times as many voters requested absentee ballots than had done so in 201655—suggests that Virginia will likewise see an unprecedented surge in absentee ballots. Any reasonable estimate suggests that the witness requirement will force tens of thousands—if not hundreds of thousands—of Virginians to risk their health to vote in the June primary.
To make matters worse, the affected voters will disproportionately be members of populations at heightened risk of severe health complications from COVID-19 exposure. According to data from the U.S. Census Bureau, 25.3% of all Virginians 18 and older live alone. Within that group, however, the percentage of those who live alone rises to 31% among African Americans; 33% among those who are 65 or older; 37.2% of those with a disability; and 44% of those with a disability who are 65 or older. Ex. A to Rosborough Decl.
Evidence from the Plaintiffs and Stephanie Iles, Director of Elections and General Registrar for the City of Norfolk, further shows the broad, disenfranchising sweep of the witness
53 See Exs. B, C to the Rosborough Decl. (turnout data from Va. Dep’t of Elections for June 2018 primaries). 54 Va. Dep’t of Elections, Absentee Ballots, https://www.elections.virginia.gov/casting-a-ballot/absentee-voting/ (last visited Apr. 15, 2020). 55 See supra note 51.
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requirement. The individual Plaintiffs live alone, and cannot both follow public health advice and government orders to isolate and socially distance and have their vote by absentee ballot counted. Goff Decl. ¶¶ 5, 8; Toogood Decl. ¶¶ 4, 8. Because of this, they will be disenfranchised in June should the witness requirement stand. Goff Decl. ¶ 9; Toogood Decl. ¶ 9. Similarly, the League has numerous members who live alone and will be in the same predicament. Wake Decl. ¶ 7.
In Norfolk, the largest municipality with a May election (which now may be postponed until November), Director Iles has been seeing steady evidence of this problem as absentee ballots have begun rolling in for the May election. Iles Decl. ¶¶ 6–7, 11. The very first absentee ballot her office received had a missing witness signature and a handwritten note saying the individual was unable to get a witness to sign because they were complying with the Governor’s stay at home and social distancing order. Id. ¶ 6. Since then, she has received a number of other absentee ballots without a witness signature with the election still several weeks out. Id. ¶ 7. She expects that if the witness requirement stays in place and COVID-19 still is affecting Virginia, the witness requirement “will result in a disproportionate number of absentee ballots being rejected for not meeting the witness signature requirement as compared with past elections.” Id. ¶ 11.
The broad sweep of the witness requirement’s burden alone merits heightened, if not strict, scrutiny, and reveals the unconstitutional burden Virginia voters will face if it remains in place.
2. For the thousands of Virginia voters who live alone—especially older individuals, African Americans, and voters with disabilities—the witness requirement means disenfranchisement or jeopardizing one’s health.
Forcing people to face disenfranchisement or put their health on the line in order to cast a valid ballot imposes a severe burden on the right to vote. See, e.g., Price v. N.Y. State Bd. of
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Elections, 540 F.3d 101, 107 n.8 (2d Cir. 2008) (noting that for “voters who are . . . housebound” the burden of a lack of absentee voting opportunity “could be quite significant”); see also Fla. Democratic Party v. Scott, 215 F. Supp. 3d 1250, 1257 (N.D. Fla. 2016) (holding that Florida’s voter registration deadline unconstitutionally burdened the right to vote in light of Hurricane Matthew where the disaster “foreclosed the only methods of registering to vote” during the final week of Florida’s voter registration window). That is precisely why the witness requirement not only casts a wide burden, but a deep one as well. And the way the requirement is carried out in Virginia ensures disenfranchisement for those who do not follow it. Once a ballot is received without a witness signature, it is not counted and no opportunity to cure is given. Iles Decl. ¶ 8. The voter only learns of their disenfranchisement when it is too late. So not only will the witness requirement burden thousands of Virginians for the June primary, but it will result in full disenfranchisement for those it burdens and who cannot risk their health.
Many thousands of Virginia voters live by themselves and will be unable to vote without undertaking serious risks to their health and, collectively, to public health. At a time when the Governor has ordered the closure of all schools and non-essential businesses, and issued a statewide “Stay at Home” order directing Virginians to minimize “human-to-human contact” and to “practice social distancing,” the witness requirement will force tens or even hundreds of thousands of Virginians to venture from their homes to meet with another adult to witness and sign their absentee ballots. This is precisely the opposite of what the Commonwealth has demanded that people do to protect their health and safety.
Having someone come “in close enough proximity to witness [an individual’s] ballot would place them at increased risk of infection,” Reingold Decl. ¶ 17. Public health experts instruct that individuals should “assume that anyone could be infected and infect another
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person.” Id. ¶ 11. For these quarter of Virginians that live alone—which include disproportionately higher percentages of groups at higher risk for serious COVID-19 cases and death including senior citizens and African Americans56—the many individuals like Plaintiffs and some League members who cannot or will not risk their health to vote in person or find a witness will not have their vote counted in the June primary. The consequences are particularly high and will result in greater rates of disenfranchisement for older and African-American Virginians, as having their absentee ballot witnessed and signed “would be particularly risky for those who are at a greater risk of complications and death from COVID-19.” Reingold Decl. ¶ 17.
Further, for those individuals who decide to submit their absentee ballot in spite of not having a witness, there is no discretion left to local officials about whether to accept the ballot. See 1 Va. Admin. Code 20-70-20(B); Iles Decl. ¶ 8. Nor is there any opportunity to cure the issue once the ballot is mailed or submitted as voters are not informed that their ballot is rejected until after the election when the electoral board “sends[s] a written explanation of the reason for rejection of an absentee ballot to the voter whose absentee ballot is rejected within 90 days of the date on which the ballot is rejected.” Va. Code § 24.2-711.1(B). This matches the experience of Norfolk Director of Elections Iles, who explains that once a ballot comes into her office, it is considered cast, so if it is missing something material like a witness signature, it is rejected without a chance to cure. Iles Decl. ¶ 8.
Therefore, the witness requirement’s burden for the June primary in light of continued COVID-19 transmission will not only be widespread, but also severe for the voters affected.
56 See supra Factual Background § G.
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B. The absentee witness requirement’s burden on voters far outweighs its minimal-tononexistent promotion of election integrity. Even “[s]light” burdens on the fundamental right to vote must still “be justified by
relevant and legitimate state interests ‘sufficiently weighty to justify the limitation.’” Crawford, 553 U.S. at 191 (quoting Norman v. Reed, 502 U.S. 279, 288–89 (1992)). As such, even in situations of minimal burdens, a court must still “actually weigh the burdens imposed on the plaintiff against the precise interests put forward by the State,” and take into account “the extent to which those interests make it necessary to burden the plaintiff’s rights,” unlike traditional rational basis review. Price, 540 F.3d at 108–09 (internal citations and quotation marks omitted). As explained above, the witness requirement imposes a severe burden on voters who are living alone and are social distancing during the COVID-19 pandemic, such that at least heightened, if not strict, scrutiny should apply. But even if the Court were to find that the witness requirement places a lesser burden on Virginia voters, that burden would still outweigh any benefits of the witness requirement. Two recent cases are instructive.
In Northeast Ohio Coalition for the Homeless v. Husted, 837 F.3d 612, 632 (6th Cir. 2016), the Sixth Circuit affirmed the district court’s decision to strike down Ohio’s law rejecting absentee ballot envelopes that had technical errors in the birthdate or address field. It explained that although “the burden is small for most voters, . . . none of the precise interests put forward by Ohio,” including a generalized interest in “[c]ombatting voter fraud perpetrated by mail,” was sufficient to overcome that burden. Id. Because Ohio’s interest was justified by only “the ‘rare’ instances where a fraudster manages to swipe the ballot of a registered absentee voter, forge the signature, and return the ballot” with the individual’s identifying information, a burden on even a small number of voters was enough to render the law unconstitutional. Id.
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Similarly, in One Wisconsin, a district court held that the elimination of a portion of Wisconsin’s early voting period was only a moderate burden because those voters still had other opportunities to early vote and “can vote using mail-in absentee voting or vote on election day.” 198 F. Supp. 3d at 933. Despite this, the Court held that the rollback violated the fundamental right to vote because the state’s asserted interests “do not justify the moderate burdens that the challenged provisions impose.” Id. at 934.
Here, as discussed above, the burdens are far greater than either One Wisconsin or Northeast Ohio Coalition and require at least heightened scrutiny. Like the Virginia Circuit Court in Richmond recently found in granting a preliminary injunction against a candidate signature requirement, the law “is not narrowly tailored to advance” government interests because “it does not provide for emergency circumstances, like those that currently exist.” Faulkner, No. CL 20-1546, Slip Op. at 3. But like One Wisconsin or Northeast Ohio Coalition, the witness requirement cannot survive even under a less stringent standard of review because it does not actually serve the important government interest of election integrity, and that interest is sufficiently protected by other laws. In fact, the witness requirement is likely the least effective one of several laws designed to promote election integrity in the absentee process.
For one, a witness signature adds very little to nothing to other election integrity procedures for absentee ballots. While the presence of the witness signature is mandatory and the lack of one causes the ballot’s rejection, the illegibility of the witness signature does not result in ballot rejection. See 1 Va. Admin. Code 20-70-20(B). Therefore, while election officials check for the presence of a signature on the witness line, it offers nothing to those officials’ verification or authentication procedures. See Iles Decl. ¶ 9. Indeed, the South Carolina Election Commission recently declared that the state’s similar witness requirement offers “no benefit” to election
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officials, because officials “have no ability to verify the witness’s signature.”57 This is likely why 39 states and the District of Columbia have rejected witness requirements, except for the narrow category of voters who require assistance filling out their ballots.58
More importantly, Virginia has other ways to ensure the integrity of the absentee voting process. Absentee ballot envelopes must contain several other pieces of identifying information about the voters themselves—such as their first and last name, house number, street name or rural route address, city, and zip code—the omission of any of which results in their vote being rejected. 1 Va. Admin. Code 20-70-20(B)(2)-(5). Voters must also attest under penalty of perjury that they are who they say they are, they live where they say they live, and that they did not double vote when they sign their ballot envelope. See Va. Code § 24.2-706; 1 Va. Admin. Code 20-70-20(B)(6). Virginia registrars also maintain a list of voters who applied for and returned absentee ballots, and absentee ballots are only accepted from voters whose names appear on that list. Va. Code § 24.2-710. Further, Virginia laws make it a felony to intentionally double vote, Va. Code § 24.2-1004(B), make a “willfully false material statement” on a ballot, Va. Code § 24.2-1016, or forge another person’s name, Va. Code § 24.2-1012.
The witness requirement provides no additional benefit to election integrity beyond these significant protections. Manipulating the absentee voting process already requires being able to provide all the identifying information needed for a ballot application and then ballot, and the willingness to fraudulently sign under penalty of perjury that someone else’s ballot is their own.
57 Ltr. to Gov. Henry McMaster at 3, South Carolina Election Commission (March 30, 2020) (attached as Ex. F to the Rosborough Decl.). 58 Cf. Ala. Code §§ 17-9-30(b), 17-11-7, 17-11-10; Alaska Stat. § 15.20.030; La. Stat. Ann. § 18:1306(2)(a); Miss. Code Ann. §§ 23-15-627, 23-15-635, 23-15-633; Mo. Rev. Stat. §§ 115.279, 115.283, 115.295; N.C. Gen. Stat. § 163-231; Okla. Stat. tit. 26, § 14-108; 17 R.I. Gen. Laws § 17-20-23; S.C. Code Ann. §§ 7-15- 220, 7-15-230; Va. Code §§ 24.2-706, 707; Wis. Stat. § 6.87(4)(b)1.
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For the rare individual willing and able to do so, the witness requirement is unlikely to serve as an additional deterrent or check.
And what little evidence exists of attempts to manipulate the absentee process in Virginia suggests that such occurrences are exceedingly rare. Even a database from the Heritage Foundation—which nonpartisan, independent researchers have called “grossly exaggerated and devoid of context”59—has identified only two cases of election fraud in Virginia concerning absentee voting in the past 13 years.60 During the same time period, almost 33 million voters cast their ballots in Virginia elections.61 Thus, these statistics would lead to a total voting fraud incidence related to absentee balloting of approximately .00000006 percent over votes cast in Virginia over the past thirteen years.
Far from serving an important government interest, the witness requirement in fact undermines the government’s compelling interest in protecting public health during the COVID19 pandemic. See, e.g., Am. Life League, Inc. v. Reno, 47 F.3d 642, 656 (4th Cir. 1995) (upholding law because it serves the “sufficiently compelling governmental interest[]” of “protect[ing] public health”); Forest Hills Early Learning Ctr., Inc. v. Lukhard, 728 F.2d 230, 241 (4th Cir. 1984) (recognizing the government’s “compelling state interest arising from [a] substantial threat to public health . . . .”). In order to slow the spread of COVID-19 and protect public health, Governor Northam ordered people to stay in their homes unless absolutely
59 Rudy Mehrbani, Heritage Fraud Database: An Assessment, The Brennan Center, Sept. 8, 2017, https://www.brennancenter.org/our-work/research-reports/heritage-fraud-database-assessment. 60 The Heritage Foundation, Election Fraud Cases, https://www.heritage.org/voterfraud/search?state=VA (last visited Apr. 21, 2020). 61 See Va. Dep’t of Elections, November General Elections: 1976 – Present, https://www.elections.virginia.gov/resultsreports/registrationturnout-statistics/ (last visited Apr. 21, 2020).
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necessary.62 The Governor’s order is consistent with guidance from both the CDC and the Virginia Department of Health—entities whose views on such matters are entitled to some degree of deference. See, e.g., Tolman v. Doe, 988 F. Supp. 582, 586 (E.D. Va. 1997) (explaining that the CDC’s “views are relied upon by the medical profession as authoritative” and that “the CDC is the type of public medical health officials to which courts should defer”); Smith v. Potter, 187 F. Supp. 2d 93, 97 (S.D.N.Y. 2001) (same).
The witness requirement requires people who live by themselves to leave their homes or invite people into them in order to cast a valid ballot, at significant risk not only to their own health and that of their witnesses, but to public health. Because the witness requirement offers little if any benefit to election integrity, even were the burden of the requirement not so massive, those burdens would still outweigh any governmental benefit and make the provision unconstitutional during community transmission of COVID-19. II. A preliminary injunction is necessary to prevent irreparable harm to Plaintiffs’
constitutional rights. Irreparable harm requires a movant to “make a clear showing that it will suffer harm that is neither remote nor speculative, but actual and imminent. Additionally, the harm must be irreparable, meaning that it cannot be fully rectified by the final judgment after trial.” Mountain Valley Pipeline, LLC v. 6.56 Acres of Land, Owned by Sandra Townes Powell, 915 F.3d 197, 216 (4th Cir. 2019) (citations and internal quotation marks omitted), cert. denied sub nom. Givens v. Mountain Valley Pipeline, LLC, 140 S. Ct. 300 (2019).
62 Va. Exec. Order No. 2020-55 (Mar. 30, 2020), https://www.governor.virginia.gov/media/governorvirginiagov/executive-actions/EO-55-Temporary-Stay-at-HomeOrder-Due-to-Novel-Coronavirus-(COVID-19).pdf.
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“Courts routinely deem restrictions on fundamental voting rights irreparable injury.” League of Women Voters of N.C. v. North Carolina (“LWVNC”), 769 F.3d 224, 247 (4th Cir. 2014) (collecting cases). This is partly because “the right of suffrage is a fundamental matter in a free and democratic society.” Reynolds v. Sims, 377 U.S. 533, 561–62 (1964); accord Wesberry v. Sanders, 376 U.S. 1, 17 (1964) (“No right is more precious in a free country than that of having a voice in the election of those who make the laws under which, as good citizens, we must live.”). And it is partly also because “once the election occurs, there can be no do-over and no redress,” so the injury to “voters is real and completely irreparable if nothing is done to enjoin [the challenged] law.” LWVNC, 769 F.3d at 247; see also Fla. Democratic Party, 215 F. Supp. 3d at 1258 (voting rights cases are not situations “where failing to grant the requested relief would be a mere inconvenience to Plaintiff and its members”—an election “isn’t golf: there are no mulligans.”).
Here, both individual Plaintiffs and League members wish to vote by absentee ballot to protect their health. On the one hand, these individuals face disenfranchisement if they cast an absentee mail ballot without a witness signature. On the other, they face an unconscionable risk to their health if they are compelled to either satisfy the witness requirements for absentee voting or vote in person at the polls. As noted above, disenfranchisement certainly causes irreparable harm, and of course there “can be no injury more irreparable” than “serious, lasting illness or death.” Thakker v. Doll, No. 1:20-CV-480, 2020 WL 1671563, at *4 (M.D. Pa. Mar. 31, 2020); see also id. at *7 (noting that “courts have even specifically held that COVID-19 constitutes an irreparable harm that supports the grant of a TRO” and citing cases). A preliminary injunction provides the only effective means for protecting Plaintiffs’ and many other Virginians’ constitutional rights to vote in the June primary without asking them to seriously risk their
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health. For Plaintiffs Goff and Toogood, as with as multiple League members, they will be disenfranchised in the June primary without a preliminary injunction. Goff Decl. ¶ 9; Toogood Decl. ¶ 9.
The League also faces irreparable harm as an organization in several respects. For one, a voting rights organization is “irreparably harmed when the right to vote is wrongfully denied or abridged—whether belonging to its membership or the electorate at large.” N.C. State Conf. of NAACP v. Cooper, No. 1:18CV1034, 2019 WL 7372980, at *24 (M.D.N.C. Dec. 31, 2019); see also Common Cause Georgia v. Kemp, 347 F. Supp. 3d 1270, 1295 (N.D. Ga. 2018) (finding plaintiff organization’s harm “to its organizational interests is coterminous with the harms suffered by its citizen members”); Common Cause Indiana v. Lawson, 327 F. Supp. 3d 1139, 1154 (S.D. Ind. 2018), aff’d, 937 F.3d 944 (7th Cir. 2019) (accepting that organization faced irreparable harm based on such harm to its members and the state electorate at large).
Additionally, the witness requirement harms the League’s mission of ensuring that all qualified Virginians are registered to vote and participate in the democratic process, because it “impairs the organization’s programs, making it more difficult to carry out its mission.” Action NC v. Stranch, 216 F. Supp. 3d 597, 642 (M.D.N.C. 2016); see also League of Women Voters of U.S. v. Newby, 838 F.3d 1, 9 (D.C. Cir. 2016) (noting irreparable harm based on legal barriers that “ma[de] it more difficult for [the organization] to accomplish their primary mission of registering voters”). Further, the League has begun and will need to continue diverting its limited resources from other efforts including registering voters and educating them about changes to Virginia’s elections law by its need to focus on lobbying the Commonwealth to fix the witness requirement and attempting to educate Virginians about the witness requirement. Wake Decl. ¶ 9. These lost opportunities are irreparable harm, because “when a plaintiff loses an opportunity
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to register a voter, the opportunity is gone forever.” League of Women Voters of Fla. v. Browning, 863 F. Supp. 2d 1155, 1167 (N.D. Fla. 2012); see also LWVNC, 769 F.3d at 247; League of Women Voters of Mo. v. Ashcroft, 336 F. Supp. 3d 998, 1005 (W.D. Mo. 2018); Ind. State Conf. of the NAACP v. Lawson, 326 F. Supp. 3d 646, 662–63 (S.D. Ind. 2018); Action NC, 216 F. Supp. 3d at 642–43.
Finally, the harm to Plaintiffs is not only irreparable, but imminent. With the primary approaching on June 23, all of the evidence points toward continuing community transmission through that period. As Dr. Reingold testified, it is unlikely that herd immunity will develop this year and without it, “we can expect that COVID-19 will continue to transmit widely” and the evidence from transmission in hot countries and other similar viruses “suggest that transmission of and infection with the virus may not be affected by the weather.” Reingold Decl. ¶¶ 14, 16; see also Tex. Democratic Party v. DeBeauvoir, No. D1-GN-001610 (Travis Cty. Dist. Ct. Apr. 17, 2020) (finding irreparable harm if all Texas voters cannot vote by mail and noting a high “risk of transmission of COVID-19” for Texas’s “July 14, 2020 Run-Off election and all subsequent elections for this year”) (Ex. G to Rosborough Decl.). And researchers from the University of Virginia just issued projections pointing to mid-August as the most likely peak for COVID-19 cases in Virginia, well past the primary.63
Because the evidence points to continuing and perhaps increasing transmission in Virginia well into June and beyond, the irreparable injuries faced by Plaintiffs are imminent and merit immediate relief.
63 Mel Leonor & Justin Mattingly, UVA researchers project mid-August peak for new COVID-19 cases in Virginia, Richmond Times Dispatch, Apr. 13, 2020, https://www.richmond.com/special-report/coronavirus/uvaresearchersproject-mid-august-peak-for-new-covid-19-cases-in-virginia/article_c4e2c008-1617-52d8-ad08-706abfb3d696.html.
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III. The balance of equities and the public interest support injunctive relief. The “public interest . . . favors permitting as many qualified voters to vote as possible.”
LWVNC, 769 F.3d at 247–48 (citations and internal quotation marks omitted). A “state is in no way harmed by the issuance of a preliminary injunction which prevents the state from enforcing restrictions likely to be found unconstitutional. If anything, the system is improved by such an injunction.” Giovani Carandola, Ltd. v. Bason, 303 F.3d 507, 521 (4th Cir. 2002) (citation and internal quotation marks omitted). After all, “upholding constitutional rights surely serves the public interest,” of which the State is the custodian. Id.
Additionally, enjoining the witness rule promotes “the public interest in . . . safeguarding public health.” Pashby v. Delia, 709 F.3d 307, 331 (4th Cir. 2013) (holding that “the public interest in this case lies with safeguarding public health”); Diretto v. Country Inn & Suites by Carlson, No. 1:16CV1037 (JCC/IDD), 2016 WL 4400498, at *4 (E.D. Va. Aug. 18, 2016) (“The public interest is clearly in remedying dangerous or unhealthy situations and preventing the further spread of disease.”). The Commonwealth recognizes this, with VDH urging “all Virginians to stay home and practice social distancing” and to “stay at least 6 feet away from others” if going out,64 and noting that “all aspects of a community that might be impacted, including populations most vulnerable to severe illness and those that may be more impacted socially or economically,” must be considered in adapting to COVID-19.65 Enjoining the witness rule will allow Virginians to continue to observe VDH guidelines to protect public health as well
64 Id. 65 Va. Dep’t of Health, Schools, Workplaces & Community Locations, http://www.vdh.virginia.gov/coronavirus/schools-workplaces-community-locations/ (last visited Apr. 15, 2020).
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as avoid a situation where those “most vulnerable to severe illness” bear the burdens of disenfranchisement or risk public health and their own.
Conversely, no important State interest will be compromised by a preliminary injunction authorizing all Virginia registered voters to cast absentee ballots without having to satisfy ineffectual witness requirements in the middle of a pandemic. As already discussed, Virginia already has a raft of other electoral integrity provisions to protect absentee voting, and the witness requirement provides an ineffectual method of doing so in any event. Rather, such an order would vindicate the public interests of promoting both public health and access to the franchise.
CONCLUSION For the foregoing reasons, Plaintiffs seek a preliminary injunction: (1) prohibiting Defendants from enforcing the witness requirement (as stated in Va. Code § 24.2-706 and § 24.2-707 and as interpreted by 1 Va. Admin. Code 20-70-20(B)) for all Virginia voters for the June 23 primaries and for any and all subsequent elections in Virginia until such time as inperson interactions required by compliance with the witness requirement no longer pose a risk to public health and personal safety; (2) ordering Defendants to issue guidance instructing city and county election officials to count otherwise validly cast absentee ballots that are missing a witness signature for Virginia’s June 23 primary elections; and (3) ordering Defendants to conduct a public information campaign informing Virginia voters about the elimination of this requirement, in coordination with city and county election officials.
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Dated: April 21, 2020
Davin M. Rosborough (VSB # 85935)* Dale E. Ho** Sophia Lin Lakin** Theresa J. Lee** Adriel I. Cepeda-Derieux** American Civil Liberties Union Foundation 125 Broad Street, 18th Floor New York, NY 10004 Tel.: (212) 549-2500 drosborough@aclu.org dho@aclu.org slakin@aclu.org tlee@aclu.org acepedaderieux@aclu.org

Respectfully submitted,
/s/ Vishal Agraharkar_______________ Vishal Agraharkar (VSB #93265) Eden Heilman (VSB #93554) AMERICAN CIVIL LIBERTIES UNION FOUNDATION OF AMERICA, INC. 701 E. Franklin Street, Suite 1412 Richmond, Virginia 23219 Phone: (804) 644-8080 Fax: (804) 649-2733 vagraharkar@acluva.org eheilman@acluva.org

Attorneys for Plaintiffs
* Currently Associate Status with Virginia Bar; Application for reinstatement to active status pending **Admitted pro hac vice

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CERTIFICATE OF SERVICE I certify that on April 21, 2020, I served a copy of the foregoing Brief in Support of Plaintiffs’ Motion for a Preliminary Injunction and attached exhibits on Counsel for Defendants via e-mail, as agreed to by Defendants’ Counsel in writing per Federal Rule of Civil Procedure 5(b)(2)(E).
/s/ Vishal Agraharkar_______________ Vishal Agraharkar (VSB #93265) AMERICAN CIVIL LIBERTIES UNION FOUNDATION OF AMERICA, INC. 701 E. Franklin Street, Suite 1412 Richmond, Virginia 23219 Phone: (804) 644-8080 Fax: (804) 649-2733 vagraharkar@acluva.org Counsel for Plaintiffs
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UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA

LEAGUE OF WOMEN VOTERS OF VIRGINIA et al.,
Plaintiffs,
v.
VIRGINIA STATE BOARD OF ELECTIONS et al.,
Defendants.

Case No.: 20-cv-00024

DECLARATION OF DR. ARTHUR L. REINGOLD Pursuant to 28 U.S.C. § 1746, I hereby declare as follows: 1. I am the Division Head of Epidemiology and Biostatistics at the University of California, Berkeley, School of Public Health. I have worked on the prevention and control of infectious diseases in both the United States, including eight years at the US Centers for Disease Control and Prevention (“CDC”), and with numerous developing countries around the world for over forty years. Since its inception in 1994, I have directed or co-directed the CDC-funded California Emerging Infections Program. I am a member of the Society for Epidemiologic Research and the American Epidemiological Society; an elected Fellow of the Infectious Disease Society of America and of the American Association for the Advancement of Science; and an elected member of the Institute of Medicine of the National Academy of Sciences. I was previously the President of both the Society for Epidemiologic Research and the American Epidemiological Society. I have served on the editorial boards of the journals: American Journal of Epidemiology, Epidemiology, and Global Public Health. 2. I received my A.B. in biology from the University of Chicago in 1970, and my

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M.D. from the University of Chicago in 1976. Among other things, I completed a residency in internal medicine and a preventative medicine residency with the CDC.
3. My career in public health has been in the area of infectious diseases and epidemiology. Following my positions at the CDC (1979–87), I joined the faculty of the School of Public Health at Berkeley as a Professor of Epidemiology (1987–present), the faculty of the Department of Epidemiology and Biostatistics at the University of California, San Francisco (“UCSF”) (1989–present), and as a Clinical Professor in the Department of Medicine at UCSF (1991–present). From 1990–94, I was the Head of the Epidemiology Program, Department of Biomedical and Environmental Health Sciences, University of California, Berkeley; from 1994– 2000, I was the Head of the Division of Public Health Biology and Epidemiology, University of California, Berkeley; from 2000–18, I was the Head of the Division of Epidemiology, School of Public Health, University of California, Berkeley; from 2018 continuing through the present, I am the Head of the Division of Epidemiology and Biostatistics, School of Public Health University of California, Berkeley.
4. My research focuses on emerging and re-emerging infections in the United States and in developing countries; vaccine-preventable diseases in the United States and in developing countries; and disease surveillance, outbreak detection, and outbreak response.
5. Attached and incorporated by reference to this declaration is a copy of my curriculum vitae. (Attached here as Exhibit A).
6. I am currently collaborating on research concerning SARS-CoV-2 and its incidence, and serving on SARS-CoV-2 advisory groups for multiple organizations, including UC Berkeley, the University of California system, and the City and County of San Francisco, among others.
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7. SARS-CoV-2 is a novel coronavirus that causes Coronavirus Disease 2019 (COVID-19). The virus is a respiratory virus with patients typically presenting with acute respiratory signs and symptoms, which can escalate in some patients to respiratory failure and other serious, life-threatening complications. The most common symptoms are fever, cough, and shortness of breath. Other identified symptoms include muscle aches, headaches, chest pain, diarrhea, coughing up blood, sputum production, runny nose, nausea, vomiting, sore throat, confusion, lack of senses of taste and smell, and anorexia. Due to the respiratory impacts of the disease, individuals may need to be put on oxygen, and in severe cases, patients may need to be intubated and put on a ventilator. People of every age can and have contracted COVID-19, including severe cases, but geriatric patients are at the greatest risk of severe cases, long-term impairment, and death. Likewise, those with immunologic conditions and with other preexisting conditions, such as hypertension, certain heart conditions, lung diseases (e.g., asthma, COPD), diabetes mellitus, obesity, and chronic kidney disease, are at high risk of a lifethreatening COVID-19 illness.
8. SARS-CoV-2 is readily spread through respiratory transmission. All people are susceptible to and capable of getting COVID-19 because of the ease with which it spreads. The virus is spread through droplet transmission; that is, when an infected individual speaks, coughs, sneezes, and the like, they expel droplets which can transmit the virus to others in their proximity. Though not yet determined, scientists are currently assessing whether the virus is aerosolized, such that tiny droplets containing the virus remain in the air and can be inhaled by others who come into contact with that air. The virus is also known to be spread through the touching of contaminated surfaces, for example, when an infected person touches a surface with a hand they have coughed into and then another person touches that same surface before it has
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been disinfected and then touches their face. Each infected individual is estimated to infect two to eight others. In addition, some people are so-called “superspreaders,” who cause widespread infections.
9. Diagnostic testing for the virus is currently most often done through use of a reverse-transcriptase polymerase chain reaction (RT-PCR) test. There has not been sufficiently wide-spread and easily accessible testing throughout the United States, including in Virginia. Serologic tests, which detect antibodies to the virus and thus indicate whether someone has already been exposed to it, are being developed but have not yet been validated or produced at scale.
10. There is not yet any FDA-approved vaccine against SARS-CoV-2, which could be used to immunize the population to the virus. As a result, the only ways to limit its spread are self-isolation, social distancing, frequent handwashing, and disinfecting surfaces. Self-isolation involves not physically interacting with those outside one’s household. Social or physical distancing is maintaining at least six feet of distance between individuals. Both of these interventions are aimed at keeping infected individuals far enough apart from other individuals so that they do not pass the virus along. Frequent handwashing and regular disinfecting of surfaces curb the spread via contaminated surfaces.
11. Transmission of SARS-CoV-2 can occur in any location where there is close proximity (less than six feet) between individuals. And because transmission of the virus can occur via environmental surfaces, there is also risk of spread of the virus at any location where multiple individuals touch surfaces. Some individuals who are infected with the virus do not have any symptoms but can transmit the virus and/or are infectious before they develop any symptoms. This means that isolating only persons known to be infected will not stop the spread
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of infection. Rather, to prevent increasing the scope of the outbreak of COVID-19, we must assume that anyone could be infected and infect another person.
12. Due to the lack of adequate testing, the time lag in getting results back from laboratories, and the lengthy incubation time, we cannot yet definitely determine the full effects of stay-at-home orders and social distancing. But social distancing has worked to slow the spread of respiratory viruses generally and in places that are ahead of Virginia and the United States in the current pandemic. There is evidence that cities and states that have implemented stay-at-home orders earlier than Virginia are experiencing reduced transmission. Current modeling shows that social distancing and stay-at-home orders are lessening transmission. However, transmission of the virus will continue through the population until the development and widespread use of a vaccine and/or herd immunity.
13. It is unlikely that an FDA-approved vaccine will be available for approximately 12 to 18 months, and indeed may take longer than that due to the number of steps in the process of development, trial and error, scaling to clinical trials, assessing side effects, and assessing efficacy across the population at large.
14. Herd immunity occurs when a high percentage of the population become immune to an infectious disease, such that the spread is dramatically slowed, as infected persons can become dead-ends for the virus, so to speak, because they are not interacting with anyone to whom they can transmit the virus. Approximately 80-95% of a population must be immune in order to achieve herd immunity, depending on the infectiousness of the agent. In this context, an individual’s immunity can come from either a vaccine or from previous infection. Herd immunity can protect those in a population who cannot be vaccinated and for whom infection can be particularly serious. Without herd immunity, we can expect that COVID-19 will continue
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to transmit widely. 15. As SARS-CoV-2 is a new virus, also referred to as a novel virus, only those who
have been infected and recovered are possibly immune; there is not a pre-existing population already immune to the virus. Anyone who has not yet been infected is susceptible to infection. Also, due to the virus’s novelty, we do not know whether any immunity generated by previous infection lasts permanently, for a specified period, or whether reinfection is possible. As a result, herd immunity is unlikely unless and until the development and widespread use of an effective vaccine or a sufficiently high proportion of the population has been infected. Only once serologic antibody testing is widely available will we be able to determine who in the population is not susceptible to either infection or transmission based on their immunity due to earlier infection. As a result, even if transmission slows due to behavioral interventions such as social distancing and stay-at-home orders, we can expect resurgences of COVID-19, including significant community transmission, throughout 2020 and into 2021 across the United States, until the development and widespread use of a vaccine. Such resurgence is particularly likely if/when these behavioral modifications are lifted when community transmission is still continuing.
16. As SARS-CoV-2 is novel, we also cannot say definitively whether its incidence and prevalence will rise and fall based on weather / what season it is. If virus transmission and prevalence do decline over the summer months, it remains likely that they will resurge in the fall and winter. However, certain other coronaviruses—such as SARS and MERS-CoV—do not appear to demonstrate seasonality of infection. And the current virus has circulated widely in countries currently in their hot seasons. These two points suggest that transmission of and infection with the virus may not be affected by the weather.
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Case 6:20-cv-00024-NKM Document 17-1 Filed 04/21/20 Page 8 of 40 Pageid#: 139

EXHIBIT A

November, 2019

CURRICULUM VITA

Arthur Lawrence Reingold

PRESENT POSITION:

Professor of Epidemiology Head, Division of Epidemiology and Biostatistics School of Public Health University of California, Berkeley 2121 Berkeley Way, #5302 Berkeley, California 94720-7360 Phone: (510) 642-0327 Fax: (510) 643-5056 E-mail: Reingold@berkeley.edu

DATE OF BIRTH:

October 31, 1948

PLACE OF BIRTH: Chicago, Illinois

MARITAL STATUS: Married

EDUCATION:

1966 - 70 1970 - 76

A.B. M.D.

University of Chicago University of Chicago

POSTGRADUATE TRAINING:

1976 - 78

Internal Medicine Resident, Mount Auburn Hospital Cambridge, Massachusetts

1980 - 82

Preventive Medicine Resident, Centers for Disease Control (CDC) - Atlanta, Georgia

POSITIONS HELD:

1979 - 80

1980 - 81

1981 - 85

1985 - 87

Epidemic Intelligence Service Officer, State of Connecticut - Department of Health Services Hartford, Connecticut
Epidemic Intelligence Service Officer, Special Pathogens Branch - Bacterial Diseases Division Centers for Disease Control (CDC) - Atlanta, Georgia
Assistant Chief, Respiratory & Special Pathogens Epidemiology Branch, Center for Infectious Diseases Centers for Disease Control (CDC) - Atlanta, Georgia
CDC Liaison Officer, Office of the Director Centers for Disease Control - Atlanta, Georgia

FACULTY APPOINTMENTS:

1979 - 80 1985 - 87
1987 1989 -

Instructor, Department of Medicine (Epidemiology) University of Connecticut - Hartford, Connecticut
Visiting Lecturer, Department of Biomedical and Environmental Health Sciences (Epidemiology) University of California, Berkeley
Professor of Epidemiology, School of Public Health, University of California, Berkeley
Professor, Department of Epidemiology and Biostatistics - University of California, San Francisco

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Arthur Lawrence Reingold

FACULTY APPOINTMENTS: (CONTINUED)

1990 - 94
1991 1994 - 2000 2000 - 2018

Head, Epidemiology Program, Department of Biomedical and Environmental Health Sciences, University of California, Berkeley
Clinical Professor, Department of Medicine University of California, San Francisco
Head, Division of Public Health Biology and Epidemiology University of California, Berkeley
Head, Division of Epidemiology, School of Public Health, University of California, Berkeley

2018 -

Head, Division of Epidemiology and Biostatistics, School of Public Health University of California, Berkeley

2008 - 2014 Associate Dean for Research, School of Public Health, University of California, Berkeley

2009 - 2014

MEDICAL LICENSURE:

BOARD CERTIFICATION:

1980

AWARDS:

1970 - 74 1985 1986

MEMBERSHIPS:

1970 1978 1983 1984 1986 1988 1991 1994 2003

Edward Penhoet Distinguished Chair for Global Health and Infectious Disease
California
American Board of Internal Medicine
Medical Scientist Training Program Commendation Medal, U.S. Public Health Service Charles Shepard Award, Centers for Disease Control (CDC)
Sigma Xi American College of Physicians American Society for Microbiology Society for Epidemiologic Research Infectious Disease Society of America (Fellow) American Epidemiological Society American College of Epidemiology (Fellow) AAAS (Fellow) Institute of Medicine (Member)

PROFESSIONAL ACTIVITIES

CONSULTATIONS:

1981

1981

1982

1983

1983

1984

Institute of Medicine: Toxic-shock syndrome
Food and Drug Administration: Toxic-shock syndrome
United States Agency for International Development: Control of meningococcal meningitis in West Africa
World Health Organization (WHO): Control of meningococcal meningitis in Nepal
East-West Center, University of Hawaii: Role of indoor air pollution in acute respiratory infections in developing countries
Institute of Medicine: Meningococcal vaccines
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Arthur Lawrence Reingold

CONSULTATIONS: (CONTINUED)

1986 1987 - 1993 1988 1994 1995 1995 1996 1996 - 2000 1996 1998 – 2002 2002 – 2003

World Health Organization (WHO): Control of meningococcal meningitis in South Asia
Center for Child Survival, University of Indonesia: Control of Acute Respiratory Infections
Evaluation of the Combating Communicable Childhood Disease Program, Ivory Coast
Evaluation of National Epidemiology Board Program, Rockefeller Foundation
Planning of a School-based Acute Rheumatic Fever Prevention Project - New Zealand Heart Foundation
Vaccines Advisory Committee, Food & Drug Administration Approval of accellular pertussis vaccine
External Reviewer, NIAID Group B Streptococcus Research Contract with Harvard University
U.S. Food and Drug Administration; Consultant to the Vaccines Advisory Committee
World Health Organization, Consultation on Control of Meningococcal Meningitis in Africa
Advisor to the INCLEN "Indiaclen" project
Evaluation of a School-based Acute Rheumatic Fever Prevention Project – New Zealand Heart Association

ADVISORY BOARDS AND PANELS:

1988 - 1989 1989 - 1990 1989 - 1993 1993 - 1995 1992 - 1994 1996 - 2000 1997 - 2012 1998 - 2003 1998 – 2000

Member, Advisory Committee on Ground Water and Reproductive Outcomes, State of California Department of Health Services
AIDS Advisory Committee, Alameda County Board of Supervisors
Advisory Committee, Birth Defects Monitoring Program, State of California Department of Health Services
Centers for Disease Control (CDC): Public Health Service Advisory Panel on the Case Definition for Lyme Disease
World Health Organization (WHO): Task Force on Strengthening Epidemiologic Capacity; Childhood Vaccine Initiative
Armed Forces Epidemiological Board
University of California, San Francisco AIDS Research Institute Steering Committee
Emerging Infections Committee of the Infectious Diseases Society of America
Panelist, Howard Hughes Medical Institute Predoctoral Fellowship

2001 - 2006

Technical expert, Sub-Committee on the Protection of Public Health; California State Strategic Committee on Terrorism
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Arthur Lawrence Reingold

ADVISORY BOARDS PANELS (CONTINUED)

2003 - 2008 2004 -

Advisory Board, Chinese University of Hong Kong – Centre for Emerging AND Infectious Diseases
Advisory Board, University of California, Berkeley Clinical Research Center

2004 - 2008 2004 - 2005 2005 - 2012 2005 2007 - 2012 2007 - 2009 2008 - 2012 2008 - 2011 2008 - 2012 2008 - 2009 2009 - 2012 2011 - 2013 2011 - 2014 2012 - 2014 2012 - 2014 2013 - 2018

Advisory Board, New York University School of Medicine Fellowship in Medicine and Public Health Research
Institute of Medicine Committee on Measures to Enhance the Effectiveness of CDC Quarantine Station Plan for U.S. Ports of Entry
Strategic Advisory Group of Experts (SAGE) for Vaccine Policy, World Health Organization (WHO) (Deputy Chairman, 2010-2012)
Data and Safety Monitoring Committee; F.I. Proctor Foundation, University of California, San Francisco (UCSF)
NIH Fogarty International Center External Advisory Board
Chair, Working Group on Pneumococcal Vaccine, Strategic Advisory Group of Experts (SAGE), World Health Organization (WHO)
Working Group on H5N1 Influenza Vaccines, Strategic Advisory Group of Experts (SAGE), World Health Organization (WHO)
Chair, Leptospirosis Burden Epidemiology Reference Group, World Health Organization (WHO)
National Biosurveillance Advisory Subcommittee of the Advisory Committee to The Director, Centers for Disease Control and Prevention (CDC)
Institute of Medicine Committee on the Review of Priorities in the National Vaccine Plan
Chair, Working Group on Hepatitis A Vaccine, Strategic Advisory Group of Experts (SAGE), World Health Organization (WHO)
Member, Institute of Medicine Committee on Vaccine Priorities
Member, Working Group on Vaccine Hesitancy, Strategic Advisory Group of Experts (SAGE), World Health Organization (WHO)
Chair, Review of the Heterologous Effects of Childhood Vaccines, World Health Organization (WHO)
Chair, External Review of the Measles Rubella Initiative (of WHO, CDC, UNICEF, American Red Cross, and United Nations Foundation)
Advisory Committee on Immunization Practices (ACIP), U.S. Department of Health and Human Services

2016-2017

Member, Institute of Medicine Committee on a National Strategy for the Elimination of Hepatitis B and C

2018 2018 -

Member, Independent Review Committee, Global Alliance for Vaccines and Immunizations (GAVI) Member, Strategic Advisory Group, Partnership for Influenza Vaccination Introduction
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Arthur Lawrence Reingold

LEADERSHIP POSITIONS:

1997 - 2012 2009 - 2010 2015 – 2016

Secretary-Treasurer, American Epidemiological Society President, Society for Epidemiologic Research President, American Epidemiological Society (AES)

EDITORIAL BOARDS: 1995 - 2000 2001 - 2005 2005 2009 - 2010

Board of Editors, American Journal of Epidemiology Board of Editors, Epidemiology Editorial Advisory Board, Global Public Health Editorial Advisory Board, American Journal of Epidemiology

ASSOCIATE EDITORSHIPS:

2017 -

Current Epidemiology Reports

2018 -

Vaccine

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Arthur Lawrence Reingold
PUBLICATIONS:
1. Hayes RV, Pottenger LA, Reingold AL, Getz GS, Wissler RW. Degradation of I125 - labeled serum low density lipoprotein in normal and estrogen-treated male rats. Biochem Biophys Res Comm 1971;44:14711477.
2. Reingold AL, Kane MA, Murphy BL, Checko P, Francis DP, Maynard JE. Transmission of hepatitis B by an oral surgeon. J Infect Dis 1982;145:262-268.
3. Reingold AL, Dan BB, Shands KN, Broome CV. Toxic-shock syndrome not associated with menstruation: a review of 54 cases. Lancet 1982;1:1-4.
4. Bartlett P, Reingold AL, Graham DR, et al. Toxic-shock syndrome associated with surgical wound infections. JAMA 1982;247:1448-1450.
5. Reingold AL, Hargrett NT, Shands KN, et al. Toxic-shock syndrome surveillance in the United States, 1980-1981. Ann Intern Med 1982;96:875-880.
6. Reingold AL, Hargrett NT, Dan BB, Shands KN, Strickland BY, Broome CV. Nonmenstrual toxic-shock syndrome: a review of 130 cases. Ann Intern Med 1982;6:871-874.
7. Broome CV, Hayes PS, Ajello GW, Feeley JC, Gibson RJ, Graves LM, Hancock GA, Anderson RJ, Highsmith AK, Mackel DC, Hargrett NT, Reingold AL. In-vitro studies of interactions between tampons and Staphylococcus aureus. Ann Intern Med 1982;96:959-962.
8. Guinan ME, Dan BB, Guidotti RJ, Reingold AL, et al. Vaginal colonization with Staphylococcus aureus in healthy women: a review of four studies. Ann Intern Med 1982;96(pt.2):944-947.
9. Schlech WF III, Shands KN, Reingold AL, et al. Risk factors for development of toxic-shock syndrome: association with a tampon brand. JAMA 1982;248:835-839.
10. Reingold AL, Bank JD. Legionellosis. In: Easmon CSF, Jeljaszewicz J, eds. Medical Microbiology. London: Academic Press 1982 (I):217-239.
11. Reingold AL. Toxic-shock syndrome. In: Spittell JA Jr., ed. Clinical Medicine. Philadelphia: Harper & Row Publishers 1982 (II):1-6.
12. Kornblatt AN, Reingold AL. Legionellosis. In: Steele JH, Hillyer RV, Hopla CE, eds. CRC Handbook Series in Zoonoses. CRC Press 1982:313-324.
13. Wilkinson HW, Reingold AL, Brake JB, McGiboney DL, Gorman GW, Broome CV. Reactivity of serum from patients with suspected Legionellosis against 29 antigens of legionellaceae and Legionella-like organisms by indirect immunofluorescence assay. J Infect Dis 1983;147:23-31.
14. Meenhorst PL, Reingold AL, Gorman GW, et al. Legionella pneumonia in guinea pigs exposed to aerosols of concentrated potable water from a hospital with nosocomial Legionnaires’ disease. J Infect Dis 1983;147:129-132.
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Arthur Lawrence Reingold
15. Reingold AL. Nonmenstrual toxic-shock syndrome: the growing picture. JAMA 1983; 249:932 (editorial).
16. Reingold AL. Meningococcal meningitis. Nepal Paed Soc J 1983; 2:144-148.
17. Reingold AL, Broome CV, Phillips CJ, Meda H, Tiendrebeogo H, Yada A. Evidence of continuing protection against group A meningococcal disease one year after vaccination: a case-control approach. Med Trop 1983;43:225.
18. Reingold AL, Kane MA, Hightower AW. Disinfection procedures and infection control in the outpatient oral surgery practice. J Oral Maxillofac Surg 1984;42:568-572.
19. Broome CV, Reingold AL. Current issues in toxic-shock syndrome. In: Remington JS, Swartz MN, eds. Current clinical topics in infectious diseases. McGraw Hill 1984;65-85.
20. Herwaldt LA, Gorman GW, McGrath T, Toma S, Brake B, Hightower AW, Jones J, Reingold AL, et al. A new Legionella species, Legionella feeleii species nova, causes Pontiac fever in an automobile plant. Ann Intern Med 1984;100:333-338.
21. Ajello GW, Feeley JC, Hayes PS, Reingold AL, Bolan G, et al. Trans-isolate medium: a new medium for primary culturing and transport of Neisseria meningitidis, Streptococcus pneumoniae, and Haemophilus influenzae. J Clin Microbial 1984;20:55-58.
22. Hayes PS, Graves LM, Feeley JC, Hancock GA, Cohen ML, Reingold AL, et al. Production of toxicshock-associated protein(s) in Staphylococcus aureus strains isolated from 1956 through 1982. J Clin Microbial 1984;20:42-46.
23. Reingold AL, Thomason BM, Brake BJ, Thacker L, Wilkinson HW, Kuritsky JN. Legionella pneumonia in the United States: the distribution of serogroups and species causing human illness. J Infect Dis 1984;149:819.
24. Blaser M, Reingold AL, Alsever RN, Hightower A. Primary meningococcal pericarditis: A disease of adults associated with serogroup C Neisseria meningitidis. Rev Infect Dis 1984;6:625-632.
25. Jones EE, Alford PL, Reingold AL, et al. Predisposition to invasive pneumococcal illness following parainfluenza type 3 virus infection in chimpanzees. JAVMA 1984;185:1351-1353.
26. Reingold AL, Thomason BM, Kuritsky J. Results of Legionnaires’ disease direct fluorescent-antibody testing at Centers for Disease Control, 1980-1982. In: Thornsberry C, Balows A, Feeley JC, and Jakubowski J, eds. Legionella, ASM 1984;21-22.
27. Kuritsky JN, Reingold AL, Hightower AW, Broome CV. Sporadic Legionellosis in the United States, 1970 to 1982. In: Thornsberry C, Balows A, Feeley JC, and Jakubowski J, eds. Legionella, ASM 1984;243-245.
28. Fleming DW, Reingold AL. Legionella. In: Braude AI ed. Medical Microbiology and Infectious Diseases, Second Edition W.B. Saunders 1985;352-358.
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Arthur Lawrence Reingold
29. Garbe PL, Arko RJ, Reingold AL, et al. Staphylococcus aureus isolates from patients with non-menstrual Toxic Shock Syndrome: Evidence for Additional Toxins. JAMA 1985;253:2538-2542.
30. Garbe PL, Davis BJ, Weisfeld J, Markowitz L, Miner P, Garrity F, Barbaree JM, Reingold AL. Nosocomial Legionnaires’ Disease: Epidemiologic Demonstration of Cooling Towers as a Source. JAMA 1985;254:521-524.
31. Fleming DW, Cochi SL, MacDonald KL, Brondum J, Haves PS, Plikaytis BD, Holmes MB, Audurier A, Broome CV, Reingold AL. Pasteurized milk as a vehicle of infection in an outbreak of listeriosis. NEJM 1985;312:404-407.
32. Meenhorst P, Reingold AL, Groothius DL, et al. Water-related nosocomial pneumonia caused by Legionella pneumophila serogroups 1 and 10. J Infect Dis 1985;152:356-364.
33. Bolan G, Reingold AL, Carson L, et al. Infections with Mycobacterium chelonei in patients receiving dialysis and using processed hemodialyzers. J Infect Dis 1985;152:1013-1019.
34. Reingold AL. Toxic-shock in the United States of America: epidemiology. Postgrad Med J 1985;61:2122.
35. Reingold AL, Broome CV, Hightower AW, et al. Age-specific differences in duration of clinical protection after vaccination with meningococcal polysaccharide A vaccine. Lancet 1985;II:114-118.
36. Petitti DB, Reingold AL, Chin J. The incidence of toxic-shock syndrome in Northern California: 19721983. JAMA 1986;255:368-372.
37. Reingold AL. Toxic-shock syndrome and the contraceptive sponge. JAMA 1986;255:242-243 (editorial).
38. Berkley S, Reingold AL. Toxic-shock syndrome. In: Kass EH and Platt R, eds. Current Therapy in Infectious Disease. B.C. Decker, Inc. 1986;78-81.
39. Reingold AL. Toxic-shock syndrome. In: Wheat J and White A, eds. Infectious Diseases, University of Chicago Press, 1986.
40. Reingold AL, Broome CV. Nosocomial central nervous system infections. In: Bennett JV, Brachman PS, eds. Hospital Infections. Little Brown & Co. 1986;521-529.
41. Markowitz L, Reingold AL. Toxic-shock syndrome. In: Maxcy-Rosenau Public Health and Preventive Medicine, 12th edition Appleton-Century-Crofts 1986;456-459.
42. Reingold AL, Xiao DL, Plikaytis B, Ajello L. Systemic mycoses in the United States, 1980-1982. J Med Vet Mycol 1986;24:433-436.
43. Cochi SL, Markowitz L, Owens Jr RC, Stenhouse DH, Regmi DN, Shrestha RPB, Acharya IL, Manandhar M, Gurubacharya VL, Owens D, Reingold AL. Control of epidemic group A meningococcal meningitis in Nepal. Int J Epid 1987;16:91-97.
44. Markowitz LE, Hightower AW, Broome CV, Reingold AL. Toxic-shock syndrome: Evaluation of national surveillance data using a hospital discharge survey. JAMA 1987;258:75-78.
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45. Berkley SF, Hightower AW, Reingold AL, Broome CV. The relationship of tampon characteristics to menstrual toxic-shock syndrome. JAMA 1987;258:917-920.
46. Reingold AL, Kane MA, Hightower AW. Failure of gloves and other protective devices to prevent transmission of hepatitis B virus in oral surgeons. JAMA 1988;259:2558-2560.
47. Reingold AL. The role of Legionellae in acute infections of the lower respiratory tract. Rev Infect Dis 1988;10(5):1018-1028.
48. Harrison LH, Broome CV, Hightower AW, Hoppe CC, Makintubee S, Sitze SL, Taylor JA, Gaventa S, Wenger JD, Facklam RR, and the Haemophilus Vaccine Efficacy Study Group (includes A.L. Reingold). A day-care based study of the efficacy of Haemophilus influenzae B polysaccharide vaccine. JAMA 1988;260(10):1413-1418.
49. Schwartz B, Broome CV, Hightower AW, Brown GR, Ciesielski CA, Gaventa S, Gellin BG, Mascola L, and the Listeriosis Study Group (includes A.L. Reingold). Association of sporadic listeriosis with consumption of uncooked hot dogs and undercooked chicken. Lancet 1988;II:779-782.
50. Carson LA, Bland LA, Cusick LB, Favero MS, Bolan G, Reingold AL, et al. Prevalence of nontuberculous mycobacteria in water supplies of hemodialysis centers. Appl Environ Micro 1988; 54:3122-3125.
51. Petitti DB, Reingold AL. Update through 1985 on the incidence of toxic shock syndrome among members of a prepaid health plan. Rev Infect Dis 1989;11:S22-27.
52. Reingold AL, Broome CV, Gaventa S, Hightower SW, and the Toxic-Shock Syndrome Study Group. Risk factors for menstrual toxic-shock syndrome: results of a multi-state case-control study. Rev Infect Dis 1989;11:S35-42.
53. Gaventa S, Reingold AL, Hightower AW, et al. Active surveillance for toxic-shock syndrome in the United States, 1986. Rev Infect Dis 1989;11:S28-34.
54. Schwartz B, Gaventa S, Broome CV, Reingold AL, et al. Non-menstrual toxic-shock syndrome associated with barrier contraceptives: report of a case-control study. Rev Infect Dis 1989;11:S43-49.
55. Reingold AL, Hearst N. Identifying the health care needs of the community. In: Overall N, Williamson J, eds. Community Oriented Primary Care in Action: A Practice Manual for Primary Care Settings. U.S. Department of Health and Human Services.
56. Koo D, Bouvier B, Wesley M, Courtright P, Reingold AL. Epidemic keratoconjunctivitis in a university medical center ophthalmology clinic: need for re-evaluation of the design and disinfection of instruments. Inf Control and Hosp Epi 1989;10:547-552.
57. Harrison LH, Broome CV, Hightower AW, and the Haemophilus Vaccine Efficacy Study Group (includes A.L. Reingold). Haemophilus influenzae type b polysaccharide vaccine: an efficacy study. Pediatrics 1989;84:225-261.
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58. Wenger JD, Harrison LH, Hightower A, Broome CV, Haemophilus influenzae Study Group (includes A.L. Reingold). Day care characteristics associated with Haemophilus influenzae disease. Am J Public Health 1990;80:1455-1458.
59. Morrow HW, Slaten DD, Reingold AL, et al. Risk factors associated with a school-related outbreak of serogroup C meningococcal disease. Pediatric Infect Dis J 1990;9:394-398.
60. Wenger JD, Hightower AW, Facklam RR, Gaventa S, Broome CV, Bacterial Meningitis Study Group (includes A.L. Reingold). Bacterial meningitis in the United States, 1986: Report on a multistate surveillance study. J Infect Dis 1990;162:1316-1323.
61. Reingold AL. Toxic-shock syndrome. In: Evans AS, Brachman PS, eds. Bacterial Infections of Humans. Plenum, 1991;727-743.
62. Gellin BG, Broome CV, Bibb WF, Weaver RE, Gaventa S, Mascola L, the Listeriosis Study Group. (includes A.L. Reingold). The epidemiology of listeriosis in the United States - 1986. Am J Epi 1991;133:392-401.
63. Reingold AL. Toxic-shock syndrome. In: Rakel RE, ed. Conn’s Current Therapy. W. B. Saunders, 1991;1010-1012.
64. Reingold AL, Markowitz LE. Toxic-shock syndrome. In: Maxcy-Rosenau Public Health and Preventive Medicine, 13th Edition. Appleton-Century-Crofts, 1991;304-306.
65. Bauer HM, Ting Y, Greer CE, Chambers JC, Tashiro CJ, Chimera J, Reingold AL, Manos MM. Genital human papillomavirus infection in female university students as determined by a PCR-based method. JAMA 1991;265:472-477.
66. Sutrisna B, Frerichs RR, Reingold AL. Randomised, controlled trial of effectiveness of ampicillin in mild acute respiratory infections in Indonesian children. Lancet 1991;338:471-474.
67. Reingold AL. Toxic-shock syndrome: an update. Am J Ob & Gyn 1991;165:1236-1239.
68. Pettiti DB, Reingold AL. Recent trends in the incidence of toxic-shock syndrome in Northern California. Am J Public Health 1991;81:1209-1211.
69. Ley C, Reingold AL, et al. Determinants of genital human papillomavirus infection in young women. JNCI 1991;83:997-1003.
70. Pinner RW, Gellin BG, Bibb WF, Baker CN, Weaver R, Hunter SB, Waterman SH, Mocca LF, Frasch CE, Broome CV, the Meningococcal Disease Study Group (includes A.L. Reingold). Meningococcal disease in the United States-1986. J Infect Dis 1991;164:368-374.
71. Wenger JD, Pierce R, Deaver KA, Plikaytis BD, Facklam RR, Broome CV, and the Haemophilus influenzae Study Group (includes A.L. Reingold). Efficacy of Haemophilus influenzae type b polysaccharide-diphtheria toxoid conjugate vaccine in U.S. children aged 18-59 months. Lancet 1991; 338:395-398.
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72. Moore PS, Plikaytis BD, Bolan GA, Oxtoby MJ, Yada A, Zoubga A, Reingold AL, Broome CV. Detection of meningitis epidemics in Africa: a population-based analysis. International J Epi 1992;21:155-162.
73. Schuchat A, Deaver KA, Wenger JD, Plikaytis BD, Mascola L, Pinner RW, Reingold AL, Broome CV, and the Listeria Study Group. Role of foods in sporadic listeriosis. I. Case-control study of dietary risk factors. JAMA 1992;267:2041-2045.
74. Pinner RW, Schuchat A, Swaminathan B, Hayes PS, Deaver KA, Weaver RE, Plikaytis BD, Reeves M, Broome CV, Wenger JD, and the Listeria Study Group (includes A.L. Reingold). Role of foods in sporadic listeriosis. II. Microbiologic and epidemiologic investigation. JAMA 1992; 267:2046-2050.
75. Wenger JD, Pierce R, Deaver K, Franklin R, Bosley G, Pigott N, Broome CV, and the Listeria Study Group (includes A.L. Reingold). Invasive Haemophilus influenzae disease: A population-based evaluation of the role of capsular polysaccharide serotype. J Infect Dis 1992;165(suppl 1):S34-5.
76. Steinhart R, Reingold AL, Taylor F, Anderson G, Wenger JD. Invasive Haemophilus influenzae infections in men with HIV infection. JAMA 1992;268:3350-3352.
77. Hayes PS, Graves LM, Swaminathan B, Ajello GW, Malcolm GB, Weaver RE, Ransom R, Deaver K, Plikaytis BD, Schuchat A, Wenger JD, Pinner RW, Broome CV, and the Listeria Study Group (includes A.L. Reingold). Comparison of three selective enrichment methods for the isolation of Listeria monocytogenes naturally contaminated foods. J of Food Protection, 1992; 55:952-959.
78. Osmond DH, Charlebois E, Sheppard HW, Page KA, Winkelstein W Jr, Moss AR, Reingold AL. A comparison of risk factors for hepatitis C and hepatitis B virus infection in homosexual men. J Infect Dis, 1993;167:66-71.
79. Osmond DH, Padian N, Sheppard HW, Glass S, Shiboski SC, Reingold AL. Risk factors for hepatitis C virus seropositivity in heterosexual couples. JAMA 1993;269:361-365.
80. Tappero JW, Koehler JE, Berger TG, Reingold AL, et al. Bacillary angiomatosis and bacillary splenitis in immunocompetent adults. Ann Int Med, 1993;118:363-365.
81. Tappero JW, Mohle-Boetani J, Koehler JE, Reingold AL, et al. The epidemiology of bacillary angiomatosis and bacillary peliosis. JAMA 1993;269:770-775.
82. Weinstock HS, Bolan G, Reingold AL, Polish LB. Hepatitis C virus infection among patients attending a clinic for sexually transmitted diseases. JAMA 1993;269:392-394.
83. Yajko DM, Nassos PS, Sanders CA, Gonzalez PC, Reingold AL, et al. Comparison of four decontamination methods for recovery of Mycobacterium avium complex from stools. J Clin Micro, 1993;31:302-306.
84. Adams WG, Deaver KA, Cochi SL, Plikaytis BD, Zell ER, Broome CV, Wenger JD, and the Haemophilus influenzae Study Group (includes A.L. Reingold). Decline of childhood Haemophilus influenzae type b (Hib) disease in the Hib vaccine era. JAMA 1993;269:221-226.
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85. Sutrisna B, Reingold AL, Kresno S, Harrison G, Utomo. Care-seeking for fatal illnesses in young children in Indramayu, West Java, Indonesia. Lancet 1993;342:787-789.
86. Sudarti K, Harrison GG, Sutrisna B, Reingold AL. Acute respiratory infection in children under five years in Indramayu, West Java, Indonesia: a rapid ethnographic assessment. Medical Anthropology. 1994;15:1-10.
87. Ley C, Olshen EM, Chin L, Reingold AL. The use of serologic tests for Lyme disease in a prepaid health plan in California. JAMA 1994;271:460-463.
88. Ley C, Davila I, Mayer N, Murray R, Reingold AL. Lyme disease in Northwestern coastal California. Western J Med, 1994;160:534-539.
89. Chin DP, Reingold AL, Stone EN, Vittinghoff E, Horsburgh Jr CR, et al. The impact of Mycobacterium avium complex bacteremia and its treatment on survival of AIDS patients-a prospective study. J Infect Dis 1994;170:578-584.
90. Horsburgh CR, Chin DP, Yajko DM, Hopewell PC, Reingold AL, et al. Environmental risk factors for acquisition of Mycobacterium avium complex in persons with human immunodeficiency virus infection. J Infect Dis 1994;170:362-367.
91. Chin DP, Reingold AL, Horsburgh CR, Yajko DM, et al. Predicting Mycobacterium avium complex bacteremia in patients with human immunodeficiency virus - a prospectively validated model. Clin Infect Dis 1994;19:668-674.
92. Chin DP, Hopewell PC, Yajko DM, Vittinghoff E, Horsburgh CR, Hadley WK, Stone EN, Nassos PS, Ostroff SM, Jacobson MA, Matkin CC, Reingold AL. Mycobacterium avium complex in the respiratory or gastrointestinal tract and the risk of M. avium complex bacteremia in patients with human immunodeficiency virus infection. J Infect Dis 1994;169:289-295.
93. Jackson LA, Tenover FC, Baker C, Plikaytis BD, Reeves MW, Stocker SA, Weaver RE, Wenger JD, and the Meningococcal Disease Study Group (includes A.L. Reingold). Prevalence of Neisseria meningitidis relatively resistant to penicillin in the United States, 1991. J Infect Dis 1994; 169:438-441.
94. Schuchat A, Deaver-Robinson K, Plikayatis BD, Zangwill KM, Mohle-Boetani J, Wenger JD, and the Active Surveillance Study Group (includes A.L. Reingold). Multistate case-control study of maternal risk factors for neonatal Group B streptococcal disease. Pediatric Infect Dis J 1994; 13:623-629.
95. Weinstock HS, Bolan G, Moran JS, Peterman TA, Polish L, Reingold AL. Routine hepatitis B immunization in a clinic for sexually transmitted diseases. AJPH 1995;85:846-849.
96. Wang F, So Y, Vittinghoff E, Malani H, Reingold A, et al. Incidence proportion of and risk factors for AIDS patients diagnosed with HIV dementia, central nervous system toxoplasmosis, and cryptococcal meningitis. J AIDS 1995;8:75-82.
97. Espinal M, Reingold AL, Koenig E, Lavandera M, Sanchez S. Screening for active tuberculosis in HIV testing centre. Lancet 1995;345:890-893.
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98. Yajko DM, Chin DP, Gonzalez PC, Nassos PS, Hopewell PC, Reingold AL, et al. Mycobacterium avium complex in water, food, and soil samples collected from the environment of HIV-infected individuals. J AIDS 1995;9:176-182.
99. Lurie P, Fernandes M, Hughes V, Arevalo E, Hudes E, Reingold A, et al. Socioeconomic status and risk for HIV-1, syphilis and hepatitis B infection among sex workers in São Paulo State, Brazil. AIDS 1995 9(suppl 1):S31-S37.
100. Jackson L, Hilsdon R, Farley M, Harrison L, Reingold A, et al. Risk factors for Group B streptococcal disease in adults. Ann Int Med 1995;123:415-420.
101. Tappero J, Schuchat A, Deaver K, Mascola L, Wenger JD, and the Listeriosis Study Group (includes A.L. Reingold). Reduction in the incidence of human listeriosis in the United States – Effectiveness of prevention efforts? JAMA 1995;273:1118-1122.
102. Brandt ME, Hutwagner LC, Kuykendall RJ, Pinner RW, and the Cryptococcal Disease Active Surveillance Group (includes A.L. Reingold). Comparison of multilocus enzyme electrophoresis and random amplified polymorphic DNA analysis for molecular subtyping of Cryptococcus neoformans. J Clin Microbiol 1995:33:1890-1895.
103. Ley C, Olshen EM, Reingold AL. Case-control study of risk factors for incident Lyme disease in California. Am J Epi 1995:142; Suppl:S39-S47.
104. Espinal MA, Reingold AL, Lavandera M. Effect of pregnancy on the risk of developing active tuberculosis. J Inf Dis 1996;173:488-491.
105. Perkins BA, Flood JM, Danila R, Holman RC, Reingold AL, et al. Unexplained deaths due to possibly infectious causes in the United States: Defining the problem and design of surveillance and laboratory approaches. Emerg Inf Dis 1996;Vol 2:47-53.
106. Hessol NA, Priddy FH, Bolan G, Baumrind N, Vittinghoff E, Reingold AL, Padian NS. Management of pelvic inflammatory disease by primary care physicians: A comparison with Centers for Disease Control and Prevention guidelines. Sex Trans Dis 1996;Mar-Apr:157-163.
107. Mohle-Boetani JC, Koehler JE, Berger TG, LeBoit PE, Kemper CA, Reingold AL, et al. Bacillary angiomatosis and bacillary peliosis in patients infected with human immunodeficiency virus: Clinical characteristics in a case-control study. Clin Inf Dis 1996;22:794-800.
108. Espinal MA, Reingold AL, Pérez G, et al. Human immunodeficiency virus infection in children with tuberculosis in Santo Domingo, Dominican Republic: Prevalence, clinical findings, and response to antituberculosis treatment. J AIDS 1996;13:155-159.
109. Brandt ME, Hutwagner LC, Klug LA, Baughman WS, Rimland D, Graviss EA, Hamill RJ, Thomas C, Pappas PG, Reingold AL, et al. Molecular subtype distribution of Cryptococcus neoformans in four areas of the United States. J Clin Microbiol, 1996;34:912-917.
110. Bradford WZ, Martin JN, Reingold AL, et al. The changing epidemiology of acquired drug-resistant tuberculosis in San Francisco, USA. Lancet 1996;348:928-931.
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111. Passaro DJ, Waring L, Armstrong R, Bolding F, Bouvier B, Rosenberg J, Reingold AL, et al. Beauty and the beast: Postoperative Serratia marcescens wound infections traced to an out-of-hospital source. J Inf Dis 1997;175:992-995.
112. Urwin G, Krohn JA, Deaver-Robinson K, Wenger JD, Farley MM, and the Haemophilus influenzae Study Group (includes A.L. Reingold). Invasive disease due to Haemophilus influenzae serotype f: Clinical and epidemiologic characteristics in the H. influenzae serotype b vaccine era. Clin Inf Dis, 1996;22:1069-76.
113. Sabino EC, Diaz RC, Brigido LF, Learn GH, Mullins JI, Reingold AL, et al. Distribution of HIV-1 subtypes seen in an AIDS clinic in São Paulo City, Brazil. AIDS 1996; 10:1579-1584.
114. Brandt ME, Pfaller MA, Hajjeh RA, Graviss EA, Rees J, Spitzer ED, Pinner RW, Mayer LW, and the Cryptococcal Disease Active Surveillance Group (includes A.L. Reingold). Molecular subtypes and antifungal susceptibilities of serial Cryptococcus neoformans isolates in human immunodeficiency virus associated cryptococcosis. J Inf Dis 1996;174:812-820.
115. Whitney CG, Pllikaytis BD, Gozansky WS, Wenger JD, Schuchat A, and the Neonatal Group B Streptococcal Disease Study Group (includes A.L. Reingold). Prevention practices for perinatal group B streptococcal disease: A multi-site surveillance analysis. Obstet & Gyn 1997;89:28-32.
116. McFarland W, MvereD, Shandera W, Reingold A. The epidemiology and prevention of transfusionassociated Human Immunodeficiency Virus transmission in Sub-Saharan Africa. Vox Sanguinis 1997; 72:85-92.
117. Mazurek GH, Chin DP, Hartman S, Reddy V, Horsburgh Jr, CR, Green TA, Yajko DM, Hopewell PC, Reingold AL, et al. Genetic similarity among Mycobacterium avium isolates from blood, stool, and sputum of persons with AIDS. J Inf Dis 1997; 176:1-8.
118. Schuchat A, Robinson K, Wenger JD, Harrison LH, Farley M, Reingold AL, et al. Bacterial meningitis in the United States in 1995. N Eng J Med 337:970-976, 1997.
119. DeRiemer K, Chin DP, Schecter GF, Reingold AL. Tuberculosis among immigrants and refugees. Arch Int Med, 1998; 158:753-760.
120. Glaser CA, Safrin S, Reingold AL, Newman TB. The association between Cryptosporidium infection and animal exposure in HIV-infected individuals. J AIDS 17:79-82, 1998.
121. Reingold AL. Outbreak investigations: A perspective. Emerg Inf Dis 4:21-27, 1998.
122. Bradford WZ, Koehler J, El-Hajj H, Hopewell PC, Reingold AL, et al. Dissemination of Mycobacterium tuberculosis across the San Francisco Bay area. J Inf Dis 177:1104-1107, 1998.
123. Rees JR, Pinner RW, Hajjeh RA, Brandt ME, Reingold AL. The epidemiological features of invasive mycotic infections in the San Francisco Bay Area 1992-1993: Results of population-based laboratory active surveillance. Clin Inf Dis, 27:1138-1147, 1998.
124. Ragland DR, Buffler PA, Reingold AL, Syme SL, Winkelstein WW Jr, Buffler M. Disease and injury in California with projections to the year 2007: Implications for medical education. West J Med, 168:1-23, 1998.
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125. Espinal MA, Báez J, Soriano G, Garcia V, Laszlo A, Reingold AL, Sanchez S. Drug-resistant tuberculosis in the Dominican Republic: Results of a nationwide survey. Int J Tuberc Lung Dis, 2:490-498, 1998.
126. Bindman AB, Osmond D, Hecht FM, Lehman S, Vranizan K, Keane D, Reingold A, et al. Multistate evaluation of anonymous HIV testing and access to medical care. JAMA, 280:1416-1420, 1998.
127. Bloch KC, Zwerling L, Pletcher MJ, Hahn JA, Gerberding JL, Ostroff SM, Vugia DJ, Reingold AL. Incidence and clinical implications of isolation of Mycobacterium kansasii: Results of a 5-year, population-based study. Ann Intern Med 129:698-704, 1998.
128. Hajjeh RA, Conn LA, Stephens DS, Baughman W, Hamill R, Graviss E, Pappas PG, Thomas C, Reingold AL, et al. Cryptococcosis: Population-based multistate active surveillance and risk factors in Human Immunodeficiency Virus-infected persons. J Inf Dis, 179:449-454, 1999.
129. DeRiemer K, Daley CL, Reingold AL. Preventing tuberculosis among HIV-infected persons: A survey of physicians’ knowledge and practices. Prev Med, 28:437-444, 1999.
130. Jafari HS, Adams WG, Robinson KA, Plikaytis BD, Wenger JD, and the Haemophilus influenzae Study Group(includes A.L. Reingold). Efficacy of Haemophilus influenzae type b conjugate vaccines and persistence of disease in disadvantaged populations. AJPH, 89:364-368, 1999.
131. Fonseca LAM, Reingold AL, Casseb JR, Brigido LFM, Duarte AJS. AIDS incidence and survival in a hospital-based cohort of asymptomatic HIV seropositive patients in São Paulo, Brazil. J Inf Dis 28:11561160, 1999.
132. Reingold AL, Phares C. Communicable Diseases (chapter). In: Introduction to International Health (M. Merson, ed.).
133. Kao AS, Brandt ME, Pruitt WR, Conn LA, Perkins BA, Stephens DS, Baughman WS, Reingold AL, et al. The epidemiology of candidemia in two United States cities: Results of a population-based active surveillance. Clin Inf Dis 29:1164-1170, 1999.
134. Rosenstein NE, Perkins BA, Stephens D, Lefkowitz L, Cartter M, Danila R, Cieslak P, Shutt KA, Popovic T, Schuchat A, Harrison LH, Reingold AL, et al. The changing epidemiology of meningococcal disease in the United States, 1992-1996. J Inf Dis, 180:1894-1901, 1999.
135. Hajjeh RA, Reingold AL, Weil A, Shutt K, Schuchat A, Perkins BA. Toxic shock syndrome in the United States: Surveillance update, 1979-1996. Emerg Inf Dis J 5:807-810, 1999.
136. Osmond DH, Bindman AB, Vranizan K, Lehman JS, Hecht FM, Keane D, Reingold AL. Name-based surveillance and public health interventions for persons with HIV infection. Ann Int Med 131:775-779, 1999.
137. Baer JT, Vugia DJ, Reingold AL, Aragon T, Angulo FJ, Bradford WZ. HIV infection as a risk factor for shigellosis. Emerg Inf Dis 6:820-823, 1999.
138. Reingold AL. Infectious disease epidemiology in the twenty-first century - will it be eradicated or will it re-emerge? Epi Reviews 22:57-63, 2000.
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139. Kahane SM, Watt JP, Smith NJ, Wight S, Reingold AL, Newell K, et al. Immunization levels and risk factors for low immunization coverage among private practices. Pediatrics, 2000;105:73-.
140. Espinal MA, Pérez EN, Báez J, Henriquez L, Fernandez K, Lopez M, Olivo P, Reingold AL. Infectiousness of Mycobacterium tuberculosis in HIV-1-infected subjects with tuberculosis: A prospective study. Lancet 355:275-280, 2000.
141. Schrag SJ, Zywicki S, Farley M, Reingold AL, et al. Group B streptococcal disease in the era of intrapartum antibiotic prophylaxis. New Eng J Med 342:15-20, 2000.
142. Nuorti JP, Butler JC, Gelling L, Kool JL, Reingold AL, et al. Epidemiologic relation between HIV and invasive pneumococcal disease in San Francisco County, California. Ann Int Med 132: 182-190, 2000.
143. Hecht FM, Chesney MA, Lehman JS, Osmond D, Vranizan K, Colman S, Keane D, Reingold A, et al. Does HIV reporting by name deter testing? AIDS 14:1801-1808, 2000.
144. Breiman RF, Keller DW, Phelan MA, Sniadack DH, Stephens DS, Rimland D, Farley MM, Schuchat A, Reingold AL. Evaluation of effectiveness of the 23-valent pneumococcal capsular polysaccharide vaccine for HIV-infected patients. Arch Int Med 160:2633-2638, 2000.
145. Whitney CG, Farley MM, Hadler J, Harrison LH, Lexau C, Reingold A, Lefkowitz L, et al. Increasing prevalence of multi-drug resistant Streptococcus pneumoniae in the United States. N Engl J Med 343:1917-1924, 2000.
146. Alpers L, Chrouser K, Halabi S, Moeti T, Reingold A, Binkin N, Kenyon T. Validation of the surveillance system for tuberculosis in Botswana. Int J Tuberc Lung Dis, 2000; 4:737-743.
147. Factor SH, Whitney CG, Zywicki S, Schuchat A. for the ABC Surveillance Team (includes Reingold, A.). Effects of hospital policies on the 1996 group B streptococcal consensus guidelines. Obstet Gynecol 2000; 95:377-382.
148. Factor SF, Whitney CG, Zywicki SS, Schuchat A, Active Bacterial Core Surveillance Team (includes Reingold, AL). Effects of hospital policies based on 1996 group B streptococcal disease consensus guidelines. Hospital Policies 2000; 95:377-382.
149. Robinson KA, Baughman W, Rothrock G, Barrett NL, Pass M, Lexau C, Damske B, Stefonek K, Barnes B, Patterson J, Zell ER, Schuchat A, Whitney CG for the Active Bacterial Core Surveillance (ABCs)/Emerging Infections Program Network (includes Arthur L. Reingold, MD). Epidemiology of invasive Streptococcus pneumoniae Infections in the United States, 1995-1998: Opportunities for prevention in the conjugate vaccine era. JAMA 285:1729-1735, 2001.
150. Rosenstein NE, Emery KW, Werner SB, Kao A, Johnson R, Rogers D, Vugia D, Reingold A, Talbot R, et. al. Risk factors for severe pulmonary and disseminated coccidioidomycosis: Kern County, California, 1995-1996. Clin Inf Dis 32:708-715, 2001.
151. Kellam S, Pascopella L, Desmond E, Reingold A, Chin DP. Use of recommended laboratory testing methods among patients with tuberculosis in California. J Clin Micro 39:1969-1971, 2001.
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152. Mesquita F, Kral A, Reingold A, Bueno R, Trigueiros D, Araujo PJ, and the SMR Collaborative Study Group. Trends of HIV infection among injecting drug users in Brazil in the 1990's - the impact of changes in patterns of drug use. J AIDS, 2001; 28:298-302.
153. Mesquita F, Kral A, Reingold A, Haddad I, Sanches M, Turienzo G, Piconez D, Araujo P, Bueno R. Overdoses among cocaine users in Brazil. Addiction, 2001; 96:1809-1813.
154. Larson JI, Ridzon R, Hannan MM, Conde MB, Mello FCQ, Reingold AL, Daley CL, Kritski AL. Sputum induction vs. fiberoptic bronchoscopy in the diagnosis of tuberculosis. Am J Respir Crit Care Med, 2001;163:1279-1280.
155. Schuchat A, Hilger T, Zell E, Farley MM, Reingold A, Harrison L, Lefkowitz L, Danila R, Stefonek K, Barrett N, Morse D, Pinner R. Active bacterial core surveillance of the Emerging Infections Program network. Emerg Inf Dis, 2001; 7:92-99.
156. Brandt ME, Pfaller MA, Hajjeh RA, Hamill RJ, Pappas PG, Reingold AL, Rimland D, et al. Trends in antifungal drug susceptibility of Cryptococcus neoformans isolates in the United States: 1992 to 1994 and 1996 to 1998. Antimicrobial Agents and Chemotherapy 2001;45:3065-3069.
157. Hajjeh RA, Relman D, Cieslak PR, Sofair AN, Passaro D, Flood J, et al. and the Critical Illness Working Group (includes Reingold, AL.). Surveillance for unexplained deaths and critical illnesses due to possibly infectious causes, United States, 1995-1998. Emerg Inf Dis, 2002;8:145-153.
158. Huang SS, Labus BJ, Samuel MC, Wan DT, Reingold AL. Antibiotic resistance patterns of bacterial isolates from blood in San Francisco county, 1996-1999. Emerg Inf Dis, 2002; 8:195-201.
159. Conde MB, Loivos AC, Rezende VM, Soares SLM, Mello FCQ, Reingold AL, Daley CL, Kritski AL. The yield of sputum induction in the diagnosis of pleural tuberculosis. Am J Respir and Crit Care Med, 2002; 167:723-725.
160. Handley MA, Reingold AL, Shiboski S, Padian NS. Incidence of acute urinary tract infection in young women and use of male condoms with and without nonoxynol-9 spermicides. Epidemiology, 2002;13:431436.
161. Hyde TB, Hilger TM, Reingold A, Farley MM, O’Brien KL, Schuchat A. for the Active Bacterial Core surveillance (ABCs) of the Emerging Infections Program Network. Trends in the incidence and antimicrobial resistance of early-onset sepsis: Population-based surveillance in San Francisco and Atlanta. Pediatrics, 2002;110:690-695.
162. Schrag SJ, Zell ER, Lynfield R, Roome A, Arnold KE, Craig A, Harrison L, Reingold A, Stefonek K, Smith G, Gamble M, Schuchat A for the Active Bacterial Core Surveillance team. A population-based comparison of strategies to prevent early-onset group B streptococcal disease in neonates. New Engl J Med 2002;347:233-239.
163. O’Brien KL, Beall B, Barrett NL, Cieslak P, Reingold A, Farley MM, Danila R, Zell ER, Facklam R, Schwartz B, Schuchat A for the Active Bacterial Core Surveillance team. Epidemiology of invasive group A streptococcus disease in the United States, 1995-1999. Clin Infect Dis, 2002;35:268-276.
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164. Morita JY, Zell ER, Danila R, Farley MM, Hadler JH, Harrison LH, Lefkowitz L, Reingold A, Kupronis B, Schuchat A, Whitney CG. Association between antimicrobial resistance among pneumococcal isolates and burden of invasive pneumococcal disease in the community. Clin Infect Dis, 2002;35:420-427.
165. Chuang I, Van Beneden C, Beall B, Schuchat A. and the ABCs/EIP network (includes Reingold, A.). Population-based surveillance for postpartum invasive group A streptococcal Infections, 1995-2000. Clin Infect Dis, 2002;35:665-670.
166. Passaro DJ, Smith DS, Hett EC, Reingold AL, Daily P, Van Beneden CA, Vugia DJ. Invasive Group A Streptococcal infections in the San Francisco Bay Area, 1989-1999. Epi&Infect, 2002; 129:471-478.
167. McCormick AW, Whitney CG, Farley MM, Lynfield R, Harrison LH, Bennett NM, Schaffner W, Reingold A, Hadler J, et al. Geographic diversity and temporal trends of antimicrobial resistance in Streptococcus pneumoniae in the United States. Nature Med 2003;doi:10.1038/nm839.
168. Whitney CG, Farley MM, Hadler J, Harrison LH, Bennett NM, Lynfield R, Reingold A, Cieslak PR, Pilishvili T, et al. Decline in invasive pneumococcal disease after the introduction of proteinpolysaccharide conjugate vaccine. N Engl J Med 2003;348:1737-1746.
169. Reingold A. If syndromic surveillance is the answer, what is the question? Biosecurity & Bioterrorism: Biodefense Strategy, Science, and Practice. 2003;1:1-5.
170. Koehler JE, Sanchez MA, Tye S, Garrido-Rowland CS, Chen FM, Maurer T, Cooper JL, Olson JG, Reingold AL, Hadley WK, Regnery RR, Tappero JW. Prevalence of Bartonella infection among HIVinfected patients with fever. Clin Inf Dis 2003;37:559-566.
171. Schrag SJ, Arnorld KE, Mohle-Boetani JC, Lynfield R, Zell ER, Stefonek K, Noga H, Craig AS, Thomson Sanza L, Smith G, Schuchat A, Active Bacterial Core Surveillance Team (includes Reingold AL). Prenatal screening for infectious diseases and opportunities for prevention. Obstet Gynecol 2003;102:753-760.
172. King MD, Whitney CG, Parekh F, Farley MM, Active Bacterial Core Surveillance Team/Emerging Infections Program Network (includes Reingold AL). Recurrent invasive pneumococcal disease: A population-based assessment. Clin Inf Dis 2003;37:1029-1036.
173. Carvalho HB, Seibel SD, Burattini MN, Massad E, Reingold A. Hepatitis B and C and Syphilis: Vulnerability Related Infections among Institutionalized Disadvantaged Youth in São Paulo, Brazil. J Bras Doenças Sex Transm 2003;15:41-45.
174. Louie JK, Hacker JK, Mark J, Gavali SS, Yagi S, Espinosa A, Schnurr D, Cossen CK, Isaacson ER, Glaser CA, Fischer M, Reingold AL, Vugia DJ. SARS and common viral infections, Emerg Inf Dis, 2004;10:1143-1146.
175. Flanders SA, Stein J, Shochat G, Sellers K, Holland M, Maselli J, Drew WL, Reingold AL, Gonzales. Performance of a bedside c-reactive protein test in the diagnosis of community-acquired pneumonia in adults with acute cough. Amer J Med 2004;116:529-535.
176. Pascopella L, Kellam S, Ridderhof J, Chin DP, Reingold A, Desmond E, Flood J, Royce S. Laboratory reporting of tuberculosis test results and patient treatment initiation in California. J Clin Micro, 2004;42:4209-4213.
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177. Nicas M, Hubbard AE, Jones RM, Reingold AL. The infectious dose of variola (smallpox) virus. Appl Biosafety 2004;9:118-127.
178. Flannery B, Schrag S, Bennett NM, Lynfield R, Harrison LH, Reingold A, Cieslak PR, Hadler J, Farley MM, Facklam RR, Zell ER, Whiteney CG. Impact of childhood vaccination on racial disparities in invasive Streptococcus pneumoniae infections. JAMA, 2004;291:2197-2203.
179. Facklam R, Elliott J, Shewmaker L, Reingold A. Identification and characterization of sporadic isolates of Streptococcus iniae isolated from human infections. J Clin Micro 2005; 43:933-937.
180. Heffernan RT, Barrett NL, Gallagher KM, Hadler JL, Harrison LH, Reingold AL, Khoshnood K, Holford TR, Schuchat A. Declining incidence of invasive Streptococcus pneumoniae infections among persons living with AIDS in an era of highly-active antiretroviral therapy (HAART), 1995-2000. J Inf Dis, 2005;191:2038-2045.
181. Bakyaita N, Dorsey G, Yeka A, Banek K, Staedke SG, Kamya MR, Talisuna A, Kironde F, Nsobya S, Kilian A, Reingold A, Rosenthal PJ, Wabwire-Mangen F. Sulfadoxine-pyrimethamine plus chloroquine or amodiaquine for uncomplicated falciparum malaria: A randomized, multisite trial to guide national policy in Uganda. Am J Trop Med Hyg 2005;72:573-580.
182. Pai M, Gokhale K, Joshi R, Dogra S, Kalantri SP, Mendiratta DK, Narang P, Daley CL, Granich RM, Mazurek GH, Reingold AL, Riley LW, Colford Jr, JM. Mycobacterium tuberculosis infection in health care worker in rural India: Comparison of whole-blood interferon ϒ assay with tuberculin skin testing. JAMA 2005;293:2746-2755.
183. Pai M, Kalantri S, Pascopella L, Riley LW, Reingold AL. Bacteriophage-based assays for the rapid detection of rifampicin resistance in Mycobacterium tuberculosis: a meta-analysis. Journal of Infection 2005;51:175-187.
184. Lexau CA, Lynfield R, Danila R, Pilishvili T, Facklam R, Farley MM, Harrison LH, Schaffner W, Reingold AL, Bennett NM, Hadler J, Cieslak PR, Whiteny CG (for the Active Bacterial Core Surveillance Team). Changing epidemiology of invasive pneumococcal disease among older adults in the era of pediatric pneumococcal conjugate vaccine. JAMA 2005;294:2043-2051.
185. Kalantri S, Pai M, Pascopella L, Riley L, Reingold A. Bacteriophage-based tests for the detection of Mycobacterium tuberculosis in clinical specimens: a systematic review and meta-analysis. BMC Inf Dis 2005;5:59; doi:10.1186/1471-2334-5-59.
186. Feikin DR, Klugman KP, Facklam RR, Zell ER, Schuchat A, Whitney CA for the Active Bacterial Core surveillance/Emerging Infections Program Network (includes Reingold AL). Increased prevalence of pediatric pneumococcal serotypes in elderly adults. Clin Inf Dis 2005;41:481-487.
187. Tappero JW, Bradford WZ, Agerton TB, Hopewell P, Reingold AL, Lockman S, Oyewo A, Talbot EA, et al. Serum concentrations of antimycobacterial drugs in patients with pulmonary tuberculosis in Botswana. Clin Inf Dis 2005;41:461-469.
188. Kyaw MH, Rose CE, Fry AM, Singleton JA, Moore Z, Zell ER, Whitney CG for the Active Bacterial Core surveillance program of the Emerging Infections Program Network (includes Reingold AL). The influence
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of chronic illnesses on the incidence of invasive pneumococcal diseases in adults. J Inf Dis 2005;192:377386.
189. Flannery B, Heffernan RT, Harrison LH, Ray SM, Reingold AL, Hadler J, Schaffner W, Lynfield R, Thomas AR, Jianmin Li DPE, Campsmith DDS, Whitney CG, Schuchat A. Changes in invasive pneumococcal disease among HIV-infected adults living in the era of childhood pneumococcal immunization. Ann Int Med 2006; 144:1-9.
190. Pai M, Joshi R, Dogra S, Mendiratta DK, Narang P, Kalantri S, Reingold AL, Colford JM Jr, Riley LW, Menzies D. Serial testing of health care workers for tuberculosis using interferon-γ assay. Amer J Resp Crit Care Med 2006;doi:10.1164/rccm.200604-4720C.
191. Kyaw MH, Lynfield R, Schaffner W, Craig AS, Hadler J, Reingold A, Thomas AR, Harrison LH, et al. Effect of introduction of the pneumococcal conjugate vaccine on drug-resistant Streptococcus pneumoniae. New Eng J Med 2006;354:1455-1463.
192. Poehling KA, Talbot TR, Griffin MR, Craig AS, Whitney CG, Zell E, Lexau CA, Thomas AR, Harrison LH, Reingold AL, Hadler JL, et al. Invasive pneumococcal disease among infants before and after introduction of pneumococcal conjugate vaccine. JAMA 2006;295:1668-1674.
193. Jones RM, Nicas M, Hubbard AE, Reingold AL. The infectious dose of Coxiella burnetii (Q Fever). Appl Biosafety 2006;11:32-41.
194. Whitney CG, Pilishvili T, Farley MM, Schaffner W, Craig AS, Lynfield R, Nyquist A-C, Gershman K, Vazquez M, Bennett NM, Reingold A, Thomas A, et al. Effectiveness of seven-valent pneumococcal conjugate vaccine against invasive pneumococcal disease: a matched case-control study. Lancet 2006; 368:1495-1502.
195. Hwang J, Bitarakwate E, Pai M, Reingold A, Rosenthal PJ, Dorsey G. Chloroquine or amodiaquine combined with sulfadoxine-pyrimethamine for uncomplicated malaria: a systematic review. Trop Med & Int Hlth 2006;11:789-799.
196. Joshi R, Reingold AL, Menzies D, Pai M. Tuberculosis among health-care workers in low- and middleincome countries: A systematic review. PLoS Med 2006;3(12):e494. Doi:10.1371/journal.pmed. 0030494
197. Pai NP, Lawrence J, Reingold AL, Tulsky JP. Structured treatment interruptions (STI) in chronic unsuppressed HIV infection in adults. Cochrane Database Syst Rev. 2006;3:CD006148.
198. Schrag SJ, Hadler JL, Arnold KE, et al. Risk factors for invasive, early-onset Escherichia coli infections in the era of widespread intrapartum antibiotic use. Pediatrics. 2006;118(2):570-576.
199. Malamba SS, Mermin J, Reingold A, et al. Effect of cotrimoxazole prophylaxis taken by human immunodeficiency virus (HIV)-infected persons on the selection of sulfadoxine-pyrimethamine-resistant malaria parasites among HIV-uninfected household members. Am. J. Trop. Med. Hyg. 2006;75(3):375-380.
200. Winkelstein W Jr, Reingold AL. Alex Langmuir and CDC. Emerging Infect. Dis. 2006;12(10):1619; author reply 1619.
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201. Klevens RM, Morrison MA, Fridkin SK, et al. Community-associated methicillin-resistant Staphylococcus aureus and healthcare risk factors. Emerging Infect. Dis. 2006;12(12):1991-1993.
202. Aragón TJ, Vugia DJ, Shallow S, Samuel MC, Reingold A, Angulo FJ, Bradford WZ. Case-control study of shigellosis in San Francisco: The role of sexual transmission and HIV infection. Clin Inf Dis 2007;44:327-334.
203. Dogra S, Narang P, Mendiratta DK, Chaturvedi P, Reingold AL, Colford JM, Riley LW, Pai M. Comparison of a whole blood interfon-γ assay with tuberculin skin testing for the detection of tuberculosis infection in hospitalized children in rural India. J Inf 2007;54:267-276.
204. Nunes CLX, Andrade T, Galvão-Castro B, Bastos FI, Reingold A. Assessing risk behaviors and prevalence of sexually transmitted and blood-borne infections among female crack cocaine users in Salvador--Bahia, Brazil. Braz J Infect Dis. 2007;11(6):561-566.
205. Pai N, Peterson Tulsky J, Cohan D, Colford Jr JM, Reingold AL. Rapid point-of-care HIV testing in pregnant women: A systematic review and meta-analysis. Trop Med and Int Hlth 2007;12:1-12.
206. Madhivanan P, Krupp K, Chandrasekaran V, et al. The epidemiology of Herpes simplex virus type-2 infection among married women in Mysore, India. Sex Transm Dis. 2007;34(11):935-937.
207. Chainani-Wu N, Silverman Jr S, Reingold A, Bostrom A, McCulloch C, Lozada-Nur F, Weintraub J. A randomized, placebo-controlled, double-blind clinical trial of curcuminoids in oral lichen planus. Phytomed 2007;14:437-446.
208. Veras Maria Ameli SM, Enanoria WTA, Castilho EA, Reingold AL. Effectiveness of the polysaccharide pneumococcal vaccine among HIV-infected persons in Brazil: A case control study. BMC Inf Dis 2007;7:119.
209. Krupp K, Madhivanan P, Karat C, Chandrasekaran V, Sarvode M, Klausner J, Reingold A. Novel recruitment strategies to increase participation of women in reproductive health research in India. Glob Pub Hlth 2007;4:395-403.
210. Lippman SA, Pulerwitz J, Chinaglia M, Hubbard A, Reingold AL, Diaz J. Mobility and its liminal context: Exploring sexual partnering among truck drivers crossing the Southern Brazilian border. Soc Sci & Med 2007;doi:10.1016.
211. Hicks LA, Harrison LH, Flannery B, Hadler JL, Schaffner W, Craig AS, Jackson D, Thomas A, Beall B, Lynfield R, Reingold AL, Farley MM, et al. Incidence of pneumococcal disease due to non-pneumococcal conjugate vaccine (PCV7) serotypes in the United States during the era of widespread PCV7 vaccination, 1998-2004. J Inf Dis 2007;196:1346-1354.
212. O’Loughlin RE, Roberson A, Cieslak PR, Lynfield R, Gershman K, Craig A, Albanese BA, Farley MM, Barrett NL, Spina NL, Beall B, Harrison LH, Reingold AL, Van Beneden C, et al. The epidemiology of invasive group A streptococcal infection and potential vaccine implications: United States, 2000-2004. Clin Inf Dis 2007;45:853-862.
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213. Thigpen MC, Richards Jr CL, Lynfield R, Barrett NL, Harrison LH, Arnold KE, Reingold A, Bennett NM, et al. Invasive group A streptococcal infection in older adults in long-term care facilities and the community, United States, 1998-2003. Emerg Inf Dis 2007;13:1852-1859.
214. Malamba S, Hladik W, Reingold AL, Banage F, McFarland W, Rutherford G, Mimbe D, Nzaro E, Downing R, Mermin J. The effect of HIV on morbidity and mortality in children with severe malarial anaemia. Malaria J 2007;6:143.
215. Pant Pai N, Joshi R, Dogra S, Taksande B, Kalantri SP, Pai M, Narang P, Tulsky JP, Reingold AL. Evaluation of diagnostic accuracy, feasibility, and client preference for rapid oral fluid-based diagnosis of HIV infection in rural India. PLos One 2007;2(4): e367.doi.10.1371/journal.pone.0000367.
216. Chainani-Wu N, Silverman S Jr, Reingold A, Bostrom A, Lozada-Nur F, Weintraub J. Validation of visual analogue scale, numeric rating scale, change in symptoms scale and modified oral mucousitis index for measurement of symptoms and signs of oral lichen planus. Oral Surg Med Oral Pathol Oral Radiol Endod 2008;105:51-58.
217. Koo D, Birkhead GS, Reingold AL. Competency-based epidemiologic training in public health practice. Pub Hlth Rep 2008 (Suppl 1);123:1-3.
218. Joshi R, Colford Jr JM, Reingold AL, Kalantri S. Nonmalarial acute undifferentiated fever in a rural hospital in Central India: Diagnostic uncertainty and overtreatment with anti-malarial agents. Am J Trop Med Hyg 2008;78:393-399.
219. Moore MR, Gertz RE, Woodbury RL, Barkocy-Gallagher GA, Schaffner W, Lexau C, Gershman K, Reingold AL, Farley M, Harrison LH, et al. Population snapshot of emergent Streptococcus pneumoniae Serotype 19A in the United States, 2005. J Inf Dis 2008; 197:1016-1027.
220. Madhivanan P, Krupp K, Chandrasekaran V, Karat SC, Reingold AL, Klausner JD. Acceptability of male circumcision among mothers with male children in Mysore, India. AIDS 2008; 22:983-988.
221. Blumenshine P, Reingold A, Egerter S, Mockenhaupt R, Braveman P, Marks J. Pandemic influenza planning in the United States from a health disparities perspective. Emerg Inf Dis 2008; 14:5.
222. Madhivanan P, Krupp K, Chandrasekaran V, Karat C, Arun A, Cohen CR, Reingold AL, Klausner JD. Prevalence and correlates of bacterial vaginosis among young women of reproductive age in Mysore, India. Ind J Med Microbiol 2008; 26:132-137.
223. Pant Pai N, Joshi R, Moodie E EM, Taksande B, Kalantri SP, Pai M, Tulsky JP, Reingold AL. Profile of adults seeking voluntary HIV testing and counseling in rural Central India: Results from a hospital-based study. AIDS Care 2009;21:294-300.
224. Hsu HE, Shutt KA, Moore MR, Beall BW, Bennett NM, Craig AS, Farley MM, Jorgensen JH, Lexau CA, Petit S, Reingold A, Schaffner W, Thomas A, Whitney CG, Harrison LH. Effect of pneumococcal conjugate vaccine on pneumococcal meningitis. NEJM 2009;360:244-256.
225. Gordon A, Ortega O, Kuan G, Reingold A, Saborio S, Balmaseda A, Harris E. Prevalence and seasonality of influenza-like illness in children, Nicaragua, 2005-2007. Emerg Inf Dis 2009;15:408-414.
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226. Broyles LN, Van Beneden C, Beall B, Facklam R, Shewmaker PL, Malpiedi P, Daily P, Reingold A, Farley MM. Population-based study of invasive disease due to β-hemolytic streptococci of groups other than A and B. Clin Inf Dis 2009;48:706-712.
227. Madhivanan P, Krupp K, Hardin J, Karat C, Klausner JD, Reingold AL. Simple and inexpensive point-ofcare tests improve diagnosis of vaginal infections in resource constrained settings. Trop Med & Int Hlth 2009;14:703-708.
228. Madhivanan P, Krupp K, Yashodha MN, Marlow L, Klausner JD, Reingold AL. Attitudes toward HPV vaccination among parents of adolescent girls in Mysore, India. Vaccine 2009;27:5203-5208.
229. Madhivanan P, Bartman MT, Pasutti L, et al. Prevalence of Trichomonas vaginalis infection among young reproductive age women in India: implications for treatment and prevention. Sex Health. 2009;6(4):339344.
230. Chideya S, Winston CA, Peloquin CA, Bradford WZ, Hopewell PC, Wells CD, Reingold AL, Kenyon TA, Moeti TL, Tappero JW. Isoniazid, Rifampin, Ethambutol, and Pyrazinamide, pharmokinetics and treatment outcomes among a predominantly HIV-infected cohort of adults with tuberculosis from Botswana. Clin Inf Dis 2009;48:1685-1694.
231. Carvalho M da G, Pimenta FC, Gertz RE Jr, Joshi HH, Trujillo AA, Keys LE, et al. PCR-based quantitation and clonal diversity of the current prevalent invasive serogroup 6 pneumococcal serotype, 6C, in the United States in 1999 and 2006 to 2007. J. Clin. Microbiol. 2009 Mar;47(3):554–9.
232. Gordon A, Videa E, Saborio S, et al. Performance of an influenza rapid test in children in a primary healthcare setting in Nicaragua. PLoS ONE. 2009;4(11):e7907.
233. Pai NP, Estes M, Moodie EEM, Reingold AL, Tulsky JP. The impact of antiretroviral therapy in a cohort of HIV infected patients going in and out of the San Francisco county jail. PLoS ONE. 2009;4(9):e7115.
234. Ahmad Y, Gertz RE Jr, Li Z, et al. Genetic relationships deduced from emm and multilocus sequence typing of invasive Streptococcus dysgalactiae subsp. equisimilis and S. canis recovered from isolates collected in the United States. J. Clin. Microbiol. 2009;47(7):2046-2054.
235. Eisenberg JNS, Aiello AE, Spicknall IH, Monto AS, Reingold A. Protecting the herd from H1N1. Science. 2009;326(5955):934; author reply 934.
236. Pilishvili T, Lexau C, Farley MM, Hadler J, Harrison LH, Bennett NM, Reingold A, et al. Sustained reductions in invasive pneumococcal disease in the era of conjugate vaccine. J Inf Dis 2010;201:32-41.
237. Krupp K, Marlow LAV, Kielmann K, et al. Factors associated with intention-to-recommend human papillomavirus vaccination among physicians in Mysore, India. J Adolesc Health. 2010;46(4):379-384.
238. Lippman SA, Donini A, Díaz J, et al. Social-environmental factors and protective sexual behavior among sex workers: the Encontros intervention in Brazil. Am J Public Health. 2010;100 Suppl 1:S216-223.
239. Durrheim DN, Reingold A. Modifying the GRADE framework could benefit public health. J Epidemiol Community Health. 2010;64(5):387.
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240. Pilishvili T, Zell ER, Farley MM, et al. Risk factors for invasive pneumococcal disease in children in the era of conjugate vaccine use. Pediatrics. 2010;126(1):e9-17.
241. Malamba S, Sandison T, Lule J, Reingold A, Walker J, Dorsey G, Mermin J. Plasmodium falciparum dihydrofolate reductase and dihyropteroate syntase mutations and the use of trimethoprimsulfamethoxazole prophylaxis among persons infected with human immunodeficiency virus. Am J Trop Med Hyg 2010;82:766-771.
242. Dawood FS, Fiore A, Kamimoto L, Nowell M, Reingold A, Gershman K, Meek J, et al. Influenzaassociated pneumonia in children hospitalized with laboratory-confirmed influenza, 2003-2008. Ped Inf Dis 2010;29:585-590.
243. Kallen AJ, Mu Y, Bulens S, Reingold A, Petit S, Gershman K, Ray SM, Harrison LH, et al. Health careassociated invasive MRSA infections, 2005-2008. JAMA 2010;304:641-648.
244. Cohn AC, MacNeil JR, Harrison LH, et al. Changes in Neisseria meningitidis disease epidemiology in the United States, 1998-2007: implications for prevention of meningococcal disease. Clin. Infect. Dis. 2010;50(2):184-191.
245. Cohen AL, Harrison LH, Farley MM, et al. Prevention of invasive pneumococcal disease among HIVinfected adults in the era of childhood pneumococcal immunization. AIDS. 2010;24(14):2253-2262.
246. Dao CN, Kamimoto L, Nowell M, et al. Adult hospitalizations for laboratory-positive influenza during the 2005-2006 through 2007-2008 seasons in the United States. J. Infect. Dis. 2010;202(6):881-888.
247. Cochran LW, Black S, Klein NP, et al. Vaccine effectiveness against laboratory-confirmed influenza in infants: A matched case control study. Hum Vaccin. 2010;6(9). Available at: http://www.ncbi.nlm.nih.gov/pubmed/20855940. Accessed September 26, 2011.
248. Burton DC, Flannery B, Bennett NM, et al. Socioeconomic and racial/ethnic disparities in the incidence of bacteremic pneumonia among US adults. Am J Public Health. 2010;100(10):1904-1911.
249. Dawood FS, Fiore A, Kamimoto L, et al. Burden of seasonal influenza hospitalization in children, United States, 2003 to 2008. J. Pediatr. 2010;157(5):808-814.
250. Thigpen MC, Whitney CG, Messonnier NE, Zell ER, Lynfield R, Hadler JL, Harrison LH, Farley MM, Reingold AL, et al. Bacterial meningitis in the United States, 1998-2007. New Engl J Med 2011; 364:2016-2025.
251. Pinho AA, Chinaglia M, Lippman SA, Reingold AL, Diaz RS, Sucupira MC, Page K, Diaz J. Prevalence and factors associated with HSV-2 and hepatitis B infections among truck drivers crossing the southern Brazilian border. Sex Trans Infect 2011; doi:10.1136/sextrans-2011-050186.
252. Veras MA de SM, Ribeiro MCA, Jamal LF, et al. The “AMA-Brazil” cooperative project: a nation-wide assessment of the clinical and epidemiological profile of AIDS-related deaths in Brazil in the antiretroviral treatment era. Cad Saude Publica. 2011;27 Suppl 1:S104-113.
253. Madhivanan P, Chen Y-H, Krupp K, et al. Incidence of Herpes simplex virus type 2 in young reproductive age women in Mysore, India. Indian J Pathol Microbiol. 2011;54(1):96-99.
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254. Creanga AA, Kamimoto L, Newsome K, et al. Seasonal and 2009 pandemic influenza A (H1N1) virus infection during pregnancy: a population-based study of hospitalized cases. Am. J. Obstet. Gynecol. 2011;204(6 Suppl 1):S38-45.
255. Weston EJ, Pondo T, Lewis MM, et al. The burden of invasive early-onset neonatal sepsis in the United States, 2005-2008. Ped Inf Dis. 2011. Available at: http://www.ncbi.nlm.nih.gov/pubmed/21654548. Accessed September 26, 2011.
256. Dawood FS, Kamimoto L, D’Mello TA, et al. Children with asthma hospitalized with seasonal or pandemic influenza, 2003-2009. Pediatrics. 2011;128(1):e27-32.
257. Rosen JB, Thomas AR, Lexau CA, et al. Geographic variation in invasive pneumococcal disease following pneumococcal conjugate vaccine introduction in the United States. Clin. Infect. Dis. 2011;53(2):137-143.
258. Rathod SD, Krupp K, Klausner JD, et al. Bacterial vaginosis and risk for Trichomonas vaginalis infection: A longitudinal analysis. Sex Transm Dis. 2011;38(9):882-886.
259. Adamson PC, Krupp K, Freeman AH, Klausner JD, Reingold AL, Madhivanan P. Prevalence & correlates of primary infertility among young women in Mysore, India. Indian J. Med. Res. 2011 Oct;134:440–6.
260. Madhivanan P, Krupp K, Reingold A. Correlates of Intimate Partner Physical Violence Among Young Reproductive Age Women in Mysore, India. Asia-Pacific journal of public health / Asia-Pacific Academic Consortium for Public Health [Internet]. 2011 Dec 20 [cited 2012 Jun 18]; Available from: http://www.ncbi.nlm.nih.gov/pubmed/22186382
261. MacNeil JR, Cohn AC, Farley M, Mair R, Baumbach J, Bennett N, et al. Current epidemiology and trends in invasive Haemophilus influenzae disease--United States, 1989-2008. Clin. Infect. Dis. 2011 Dec;53(12):1230–6.
262. Doshi S, Kamimoto L, Finelli L, Perez A, Reingold A, Gershman K, et al. Description of antiviral treatment among adults hospitalized with influenza before and during the 2009 pandemic: United States, 2005-2009. J. Infect. Dis. 2011 Dec 15;204(12):1848–56.
263. MacNeil JR, Cohn AC, Zell ER, Schmink S, Miller E, Clark T, et al. Early estimate of the effectiveness of quadrivalent meningococcal conjugate vaccine. Pediatr. Infect. Dis. J. 2011 Jun;30(6):451–5.
264. Lippman SA, Chinaglia M, Donini AA, Diaz J, Reingold A, Kerrigan DL. Findings from Encontros: a multilevel STI/HIV intervention to increase condom use, reduce STI, and change the social environment among sex workers in Brazil. Sex Transm Dis. 2012 Mar;39(3):209–16.
265. Vandermeer ML, Thomas AR, Kamimoto L, Reingold A, Gershman K, Meek J, et al. Association between use of statins and mortality among patients hospitalized with laboratory-confirmed influenza virus infections: a multistate study. J. Infect. Dis. 2012 Jan 1;205(1):13–9.
266. Wise ME, Viray M, Sejvar JJ, Lewis P, Baughman AL, Connor W, et al. Guillain-Barre Syndrome during the 2009-2010 H1N1 influenza vaccination campaign: Population-based surveillance among 45 million Americans. Am. J. Epidemiol. 2012 Jun 1;175(11):1110–9.
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267. Luckhaupt SE, Sweeney MH, Funk R, Calvert GM, Nowell M, D’Mello T, et al. Influenza-associated hospitalizations by industry, 2009-10 influenza season, United States. Emerging Infect. Dis. 2012 Apr;18(4):556–62.
268. Hampton LM, Farley MM, Schaffner W, Thomas A, Reingold A, Harrison LH, et al. Prevention of antibiotic-nonsusceptible Streptococcus pneumoniae with conjugate vaccines. J. Infect. Dis. 2012 Feb 1;205(3):401–11.
269. De Serres G, Pilishvili T, Link-Gelles R, Reingold A, Gershman K, Petit S, et al. Use of surveillance data to estimate the effectiveness of the 7-valent conjugate pneumococcal vaccine in children less than 5 years of age over a 9 year period. Vaccine. 2012 Jun 8;30(27):4067–72.
270. Reingold AL. Review: “Smallpox-The Death of a Disease: The Inside Story of Eradicating a Worldwide Killer” by D.A. Henderson. 2010; Am J Epidemiol 171:384-385.
271. Cohen AL, Taylor T Jr, Farley MM, Schaffner W, Lesher LJ, et al. An assessment of the screening method to evaluate vaccine effectiveness: The case of 7-valent pneumococcal conjugate vaccine in the United States. PLoS One 2012;7:341785. Doi:10.1371/journal.pone.0041785.
272. Henry JA, Reingold AL. Prehospital trauma systems reduce mortality in developing countries: A systematic review and meta-analysis. Trauma Acute Care Surg 2012;73:261-268.
273. Rathod SD, Klausner JD, Krupp K, Reingold AL, Madhivanan P. Epidemiologic features of vulvovaginal candidiasis among reproductive-age women in India. Inf Dis Obst Gyn 2012; Article ID 859071; doi:10.1155/2012/859071.
274. Duclos P, Durrheim DN, Reingold AL, Bhutta ZA, Vannice K, et al. Developing evidence-based immunization recommendations and GRADE*. Vaccine 2012;31:12-19.
275. Joshi R, Kalantri SP, Reingold AR, Colford JM. Changing landscape of acute encephalitis syndrome in India: A systematic review. Nat Med J India 2012;25:212-220.
276. Muhammad RD, Oza-Frank R, Zell E, Link-Gelles R, Venkat Narayan KM, Schaffner W, Thomas A, Lexau C, Bennett NM, Farley MM, Harrison LH, Reingold A, et al. Epidemiologoy of invasive pneumococcal disease among high-risk adults since the introduction of pneumococcal conjugate vaccine for children. Clin Inf Dis 2013;56:e59-67.
277. Cox CM, D’Melio T, Perez A, Reingold A, Gershman K, et al. Increase in rates of hospitalization due to laboratory-confirmed influenza among children and adults during the 2009-2010 influenza pandemic. J Inf Dis 2012; 206:1350-1358.
278. Livorsi DJ, MacNeil JR, Cohn AC, Bareta J, Zansky S, Petit S, Gershman K, Harrison LH, Lynfield R, Reingold A, et al. Invasive Haemophilus influenzae in the United States, 1999-2008: Epidemiology and Outcomes. J Inf Dis 2012; 65:496-504.
279. * Keller AC, Ansell CK, Reingold AL, Bourrier M, Hunter MD, Burrowes S, MacPhail TM. Improving Pandemic Response: A Sensemaking Perspective on the Spring 2009 H1N1 Pandemic. Risk, Hazards & Crisis in Public Policy: Vol. 3: Iss. 2, Article 1; 2012. DOI: 10.1515/1944-4079.1101.
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280. Terrault NA, Dodge JL, Murphy EL, Tavis JE, Kiss A, Levin TR, Gish RG, Busch MP, Reingold AL, Alter MJ. Sexual transmission of hepatitis C virus among monogamous heterosexual couples: The HCV partners study. Hepatology; 2013;53:881-889.
281. Muhammed RD, Oza-Frank R, Zell E, Link-Gelles R, Venkat Narayan KM, Schaffner W, Thomas A, Lexau C, Bennett NM, Farley MM, Harrison LH, Reingold A, et al. Epidemiology of invasive pneumococcal disease among high-risk adults since the introduction of pneumococcal conjugate vaccine for children. Clin Inf Dis 2013;56:e59-e67.
282. Fleming-Dutra KE, Taylor T, Link-Gelles R, Garg S, Jhung MA, Finelli L, Jain S, Shay D, Chaves SS, Baumbach J, Hancock EB, Beall B, Bennett N, Zansky S, Petit S, Yousey-Hindes K, Farley MM, Gershman K, Harrison LH, Ryan P, Lexau C, Lynfield R, Reingold A, et al. Effect of the 2009 influenza A(H1N1) pandemic on invasive pneumococcal pneumonia. J Inf Dis 2013;207:1135-1143.
283. Kamimoto L, Euler GL, Lu P-J, Reingold A, Hadler J, Gershman K, et al. Seasonal influenza morbidity estimates obtained from telephone surveys, 2007. Am J Pub Hlth 2013;103:755-763.
284. Salmon DA, Proschan M, Forshee R, Gargiullo P, Bleser W, Burwen DR. . .H1N1 GBS Meta-Analysis Working Group (Reingold AL-member). Association between Guillain Barré syndrome and influenza A (H1N1) 2009 monovalent inactivated vaccines in the USA: A meta-analysis. Lancet 2013;381:1461-1468.
285. Ssekitoleko R, Kamya MR, Reingold AL. Primary prophylaxis for cryptococcal meningitis and impact on mortality in HIV: A systematic review and meta-analysis. Future Virol 2013;8:doi: 10.2217/fvl.13.71.
286. Joshi R, Mishra PK, Joshi D, Santhosh SR, Parida MM, Desikan P, Gangane N, Kalantri SP, Reingold A, Colford JM Jr. Clinical presentation, etiology, and survival in adult acute encephalitis syndrome in rural Central India. Clin Neuro Neurosurg 2013;115:1753-1761.
287. Dawood FS, Chaves SS, Perez A, Reingold A, Meek J, Farley MM, et al. Complications and associated bacterial coinfections among children hospitalized with seasonal or pandemic influenza, United States, 2003-2010. J Inf Dis 2013; Epub DOI: 10.1093/infdis/jit473.
288. Thompson MG, Sokolow LZ, Almendares O, Openo K, Farley MM, Meek J, Ray J, Daily Kirley P, Reingold A, et al. Effectiveness of nonadjuvanted monovalent influenza A (H1N1) pdm09 vaccines for preventing reverse transcription polymerase chain reaction-confirmed pandemic influenza hospitalizations: Case-control study of children and adults at 10 U.S. influenza surveillance network sites. Clin Inf Dis 2013;11:1587-1592.
289. Wiringa AE, Shutt KA, Marsh JW, Cohn AC, Messonnier NE, Zansky SM, Petit S, Farley MM, Gershman K, Lynfield R, Reingold A, et al. Geotemporal analysis of Neisseria meningitidis clones in the United States: 2000-2005. PLoS One 2013;8:e82048l doi:10.1371/journal.pone.0082048.
290. Woolf-King SE, Steinmaus CM, Reingold AL, Hahn JA. An update on alcohol use and risk of HIV infection in sub-Saharan Africa: Meta:analysis and future research directions. IJADR, 2013, 2(1), 99-110; doi: 10.7895/ijadr.v2il.45.
291. Jhung MA, D’Mello T, Perez A, Aragon D, Bennett NM, Cooper T, Farley MM, Fowler B, Grube SM, Hancock EB, Lynfield R, Morin C, Reingold A, et al. Hospital-onset influenza hospitalizations – United States, 2010-2011. Am J Inf Control 2014; 42:7-11.
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292. Ayieko J, Abuogi L, Simchowitz B, Bukusi EA, Smith AH, Reingold A. Efficacy of isoniazid prophylactic therapy in prevention of tuberculosis in children: a meta-analysis. BMC Inf Dis 2014; 14:91; doi:10.1186/1471-2334-14-91.
293. Dharan NJ, Sokolow LZ, Cheng PY, Gargiullo P, Gershman K, Lynfield R, Morin C, Thomas A, Meek J, Farley MM, Arnold KE, Reingold A, et al. Child, household, and caregiver characteristics associated with hospitalization for influenza among children 6-59 months of age: an emerging infections program study. Pediatr Infect Dis J. 2014 Jun;33(6):e141-50. doi: 10.1097/INF.0000000000000283.PMID: 24642518.
294. Wortham JM, Zell ER, Pondo T, Harrison LH, Schaffner W, Lynfield R, Thomas A, Reingold A, et al. Racial disparities in invasive Streptococcus pneumoniae infections, 1998-2009. Clin Infect Dis. 2014 May;58(9):1250-7. doi: 10.1093/cid/ciu108. Epub 2014 Feb 27.PMID:24585565.
295. Madhivanan P, Raphael E, Rumphs A, Krupp K, Ravi K, Srinivas V, Arun A, Reingold AL, et al. Characterisation of culturable vaginal Lactobacillus species among women with and without bacterial vaginosis from the United States and India: A cross-sectional study. J Med Microbiol. 2014 Jul;63(Pt 7):931-5. doi: 10.1099/jmm.0.073080-0. Epub 2014 May 16.PMID :24836413.
296. Chaves SS, Perez A, Farley MM, Miller L, Schaffner W, Lindegren ML, Sharangpani R, Meek J, YouseyHindes K, Thomas A, Boulton R, Baumbach J, Hancock EB, Bandyopadhyay AS, Lynfield R, Morin C, Zansky SM, Reingold A,et al. The burden of influenza hospitalizations in infants from 2003 to 2012, United States. Pediatr Infect Dis J. 2014 Sep;33(9):912-9. doi: 10.1097/INF.0000000000000321.PMID:24577042.
297. Blain A, MacNeil J, Wang X, Bennett N, Farley MM, Harrison LH, Lexau C, Miller L, Nichols M, Petit S, Reingold A, et al. Invasive Haemophilus Influenzae Disease in Adults ≥65 Years, United States, 2011. Open Forum Infect Dis (Summer 2014) 1 (2): first published online June 13, 2014. doi:10.1093/ofid/ofu044.
298. Greenbaum A, Chaves S S, Perez A, Aragon D, Bandyopadhyay A, Bennett N, Fowler B, Hancock E, Lynfield R, McDonald-Hamm C, Reingold A, et al. Heavy alcohol use as a risk factor for severe outcomes among adults hospitalized with laboratory-confirmed influenza, 2005-2012. Infection (2014) 42:165-170. Doi 10.1007/s15010-013-0534-8.
299. Langley G, Schaffner W, Farley MM, Lynfield R, Bennett NM, Reingold A, et al. Twenty years of Active Bacterial Core surveillance. Emerg Infect Dis. 2015 Sept. http://dx.doi.org/10.3201/eid2109.141333.
300. Vugia DJ, Meek JI, Danila RN, Jones TF, Schaffner W, Baumbach J, Lathrop S, Farley MM, TobinD’Angelo M, Miller L, Harrison LH, Bennett NM, Cieslak PR, Cartter ML, Reingold A. Training in Infections Disease Epidemiology through the Emerging Infections Program Sites. Emerg Infect Dis. 2015 Sept. doi:http//dx.doi.org/10.3201/eid2109.150443.
301. MacNeil JR, Bennett N, Farley MM, Harrison LH, Lynfield R, Nichols M, Petit S, Reingold A, et al. Epidemiology of Infant Meningococcal Disease in the United States, 2006-2012. Pediatrics Volume 135, number 2, February 2015. doi:10.1542/peds.2014-2035.
302. Arriola CS, Anderson EJ, Baumbach J, Bennett N, Bohm S, Hill M, Lindegree ML, Lung K, Meek J, Mermel E, Miller L, Monroe ML, Morin C, Oni O, Reingold A, et al. Does Influenza Vaccination Modify
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Influenza Severity: Data on Older Adults Hospitalized With Infuluenza During the 2012-2013 Season in the United States. J. Infect Dis March 2015. doi: 10.10936/infdis/jiv200.
303. Moore MR, Link-Gelles R, Schaffner W, Lynfield R, Lexau C, Bennett NM, Petit S, Zanksy SM, Harrison LH, Reingold A, et al. Effect of use of 13-valent pneumococcal conjugate vaccine in children on invasive pneumococcal disease in children and adults in the USA: analysis of multisite, population-based surveillance. Lancet Infect Dis 2015; 15:301-09. http://dx.doi.org/10.1016/S1473-3099(14)71081-3.
304. Madhivanan P, Alleyn HN, Raphael E, Krupp K, Ravi K, Nebhrajani R, Arun A, Reingold A, et al. Identification of culturable vaginal Lactobacillus species among reproductive age women in Mysore, India. Med Micro (2015), 64. doi.10.1099/jmm.0.000070.
305. Brito AM, Kendall C, Kerr L, Salani Mota RM, Crosland Guimaraes MD, Dourado I, Pinho A, Schwartz Benzaken A, Brignol S, Reingold A. Factors Associated with Low Levels of HIV Testing among Men Who Have Sex with Men (MSM) in Brazil. PLOS One (2015). doi:10.1371/journal.pone.0130445.
306. Dorjee K, Dierberg K, Sadutshang TD, and Reingold A. First report of multi-drug resistant tuberculosis in a systemic lupus erythematosus patient. BMC Res Notes (2015) 8:337. doi 10.1186/s13104-015-1302-x.
307. Garg S, Jain S, Dawood F S, Jhung M, Perez A, D’Mello T, Reingold A, et al. Pneumonia among adults hospitalized with laboratory-confirmed seasonal influenze virus infection—United States, 2005-2008. BMC Infectious Diseases (2015) 15:369. Doi 10.1186/s12879-015-1004-y.
308. Shuster M, Eskola J, Duclos P, SAGE Working Group on Vaccine Hesitancy. Review of vaccine hesitancy: Rationale, remit, and methods. Elsevier Ltd. 2015. http://dx.doi.org/10.1016/j.vaccine.2015.04.035.
309. MacDonald N, SAGE Working Group on Vaccine Hesitancy. Vaccine hesitancy: Definition, scope and determinants. Elsevier Ltd. 2015. http://dx.doi.org/10.1016/j.vaccine.2015.04.36.
310. Larson H, Jarrett C, Schulz W, Chaudhuri M, Zhou Y, Dube E, Schuster M, MacDonald N, Wilson R, SAGE Working Group on Vaccine Hesitancy. Measuring vaccine hesitancy: The development of a survey tool. Elsevier Ltd. 2015. http://dx.doi.org/10.1016/j.vaccine.2015.04.37.
311. Butler R, MacDonald N, SAGE Working Group on Vaccine Hesitancy. Diagnosing the determinants of vaccine hesitancy in specific subgroups: The Guide to Tailoring Immunization Programmes (TIP). Elsevier Ltd. 2015. http://dx.doi.org/10.1016/j.vaccine.2015.04.038.
312. Jarrett C, Wilson R, O’Leary M, Eckersberger E, Larson H, SAGE Working Group on Vaccine Hesitancy. Strategies for addressing vaccine hesitancy—A systematic review. Elsevier Ltd. 2015. http://dx.doi.org/10.1016/j.vaccine.2015.04.040.
313. Dube E, Gagnon D, MacDonald N, SAGE Working Group on Vaccine History. Strategies intended to address vaccine hesitancy: Review of published reviews. Elsevier Ltd. 2015. http://dx.doi.org/10.1016/j.vaccine.2015.04.0041.
314. Nowak G, Gellin B, MacDonald N, Butler R, SAGE Working Group on Vaccine Hesitancy. Addressing vaccine hesitancy: The potential value of commercial and social marketing principles and practices. Elesevier Ltd. 2015. Vaccine 33 (2015) 4204–4211 http://dx.doi.org/10.1016/j.vaccine.2015.04.039.
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315. Goldstein S, MacDonald N, Guirguis S, SAGE Working Group on Vaccine Hesitancy. Health Communication and vaccine hesitancy. Elesvier Ltd. 2015.http://dx.doi.org/10.1016/j.vaccine.2015.04.042.
316. Eskoka J, Duclos P, Schuster M, MacDonald N, SAGE Working Group on Vaccine Hesitancy. How to deal with vaccine hesitancy? Elsevier Ltd. 2015. http://dx.doi.org/10.1016./j.vaccine.2015.04.043.
317. Rathod SD, Li T, Klausner JD, Hubbard A, Reingold AL, and Madhivanan P, Logic regression-derived algorithms for syndromic management of vaginal infections. Medical Informatics and Decision Making. 2015. 15:106. DOI 10.1186/s12911-015-0228-5.
318. Vugia DJ, Meek JI, Danila RN, Jones TF, Schaffner W, Baumbach J, Lathrop S, Farley MM, TobinD’Angelo M, Miller L, Harrison LH, Bennett NM, Cieslak PR, Cartter ML, Reingold AL. Training in Infectious Disease Epidemiology through the Emerging Infections Program Sites. Emerging Infectious Diseases. Vol. 21, No. 9; September 2015.
319. Smith EM, Khan MA, Reingold AL, Watt JP. Group B streptococcus infections of soft tissue and bone in California adults, 1995-2012. Epidemiol. Infect. (2015), 143, 3343-3350. doi:10.1017/S0950268815000606.
320. Pekka N, Reingold A. Preventing pneumococcal infections in older adults. The Lancet, Vol 3 November 2015. http://dx.doi.org/10.1016/52213-2600(15)00365-3.
321. Tomczyk S, Lynfield R, Schaffner W, Reingold A, et al. Prevention of Antibiotic-Nonsusceptible Invasive Pneumococcal Disease With the 13-Valent Pneumococcal Conjugate Vaccine. Clin Infect Dis 2016;62(9):1119-25. doi: 10.1093/cid/ciw067.
322. Cardosa CS, Sabino EC, Oliveira CdL, de Oliveira LC, Ferreira AM, Cunha-Neto E, Bierrenback AL, Ferreira JE, Haikal DS, Reingold AL, et al. Longitudinal study of patients with chronic Chagas cardiomyopathy in Brazil (SaMi-Trop project): a cohort profile. BMJ Open 2016;6:e011181. doi:10.1136/bmjopen-2016-011181.
323. Moore MR, Link-Gelles R, Schaffner W, Lynfield R, Haltzman C, Harrison LH, Zansky SM, Rosen JB, Reingold A, et al. Effectiveness of 13-valent pneumococcal conjugate vaccine for prevention of invasive pneumococcal disease in children in the USA: a matched case-control study. The Lancet, Vol 4 May 2016. http://dx.doi.org/10.1016/52213-2600(16)00052-7.
324. Bramley AM, Chaves SS, Dawood FS, Doshi S, Reingold A, et al. Utility of keywords from chest radiograph reports for pneumonia surveillance among hospitalized patients with influenza: The CDC Influenza Hospitalization Surveillance Network, 2008-2009. Public Health Reports. May/Jun 2016, Vol. 131 Issue 3, p483-490.
325. Blain AE, Sema M, Wu H, MacNeail JR, Harrison LH, Farley MM, Lynfield R, Miller L, Nichols M, Petit S, Reingold A, et al. Penicillin use in Meningococcal disease management: Active Bacterial Core Surveillance Sites, 2009. Open Forum Infectious Diseases. 11 July 2016. doi: 10.1093/ofid/ofw152.
326. Link-Gelles R, Westreich D, Aiello AE, Shang N, Weber DJ, Holtzman C, Scherzinger K, Reingold A, et al. Bias with respect to socioeconomic status: A closer look at zip code matching in a pneumococcal vaccine effectiveness study. 8 August 2016. Elsevier. http://dx.doi.org/10.1016/j.ssmph.2016.08.005.
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327. Higgins JPT, Soares-Weiser K, Lopez JA, Kakourou A, Chaplin K, Martin NK, Sterne JAC, Reingold A. Association of BCG, DTP, and measles containing vaccines with childhood mortality: systematic review. BMJ. 2016;355:i5170. doi:10.1136/bmj.i5170.
328. Andreuccetti G, Leyton V, Lemos NP, Miziara ID, Ye Y, Takitane J, Munoz DR, Reingold AL, et al. Alcohol use among fatally injured victims in São Paulo, Brazil: bridging the gap between research and health services in developing countries. 2016 Nov 6. doi: 10.1111/add.13688. [Epub ahead of print]
329. Harris CM, Wu HM, Li J, Hall HI, Lee A, Zell E, Harrison LH, Petit S, Farley MM, Lynfield R, Miller L, Nichols M, Reingold A, et al. Meningococcal disease in patients with human immunodeficiency virus infection: a review of cases reported through active surveillance in the United States, 2000-2008. Open Forum Infect Dis. 2016 Dec 20;3(4):ofw226. doi: 10.1093/ofid/ofw226.
330. Schrag SJ, Farley MM, Petit S, Reingold A, et al. Epidemiology of invasive early-onset neonatal sepsis, 2005 to 2014. Pediatrics. 2016 Dec; 138(6). pii: e20162013.
331. Metcalf BJ, Chochua S, Gertz RE, Li Z, et al. Using whole genome sequencing to identify resistance determinants and predict antimicrobial resistance phenotypes for year 2015 invasive pneumococcal disease isolates recovered in the United States. Clinical Microbiology and Infection, Volume 22, Issue 12, 2016,Pages 1002.e1-1002.e8, https://doi.org/10.1016/j.cmi.2016.08.001.
332. Wesson P, Reingold A, McFarland W. Theoretical and empirical comparisons of methods to estimate the size of hard-to-reach populations: a systematic review. AIDS Behav. 2017 Jan 11. doi: 10.1007/s10461017-1678-9. [Epub ahead of print] Review.
333. Cohn AC, MacNeil JR, Harrison LH, Lynfield R, Reingold AL, et al. Effectiveness and duration of protection of one dose of a meningococcal conjugate vaccine. Pediatrics. Volume 139, No. 2; February 2017.
334. Belongia EA, Karron RA, Reingold A, et al. The Advisory Committee on Immunization Practices recommendations regarding the use of live influenza vaccine: A rejoinder. Vaccine (2017), http://dx.doi.org/10.1016/j.vaccine.2017.06.017.
335. Carmen SA, Garg S, Anderson EJ, Ryan PA, George A, Zansky SM, Bennett N, Reingold A, et al. Influenza vaccination modifies disease severity among community-dwelling adults hospitalized with influenza. Clin Infect Dis 2017 cix468. doi: 10.1093/cid/cix468.
336. Link-Gelles R, Westreich D, Aiello AE, Shang N, Weber DJ, Rosen JB, Motala T, Mascola L, Eason J, Scherzinger K, Holtzman C, Reingold AL, et al. Generalisability of vaccine effectiveness estimates: an analysis of cases included in a postlicensure evaluation of 13-valent pneumococcal conjugate vaccine in the USA. BMJ Open 2017; 7:e017715. doi:10.1136/bmjopen-2017-017715.
337. Metcalf BJ, Chochua S, GirtzJr. RE, et al. Short-read whole genome sequencing for determination of antimicrobial resistance mechanisms and capsular serotypes of current invasive Streptococcus agalactiae recovered in the USA, Clinical Microbiology and Infection, Volume 23, Issue 8, 18 Feb 2017,Pages 574.e7-574.e14, https://doi.org/10.1016/j.cmi.2017.02.021.
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338. Arriola C, Garg S, Anderson E, Ryan PA, George A, Zansky SM, Bennett N, Reingold A, et al. Influenza vaccination modifies disease severity among community-dwelling adults hospitalized with influenza. Clin Infect Dis May 2017;00(00):1-9. doi:10.1093/cid/cix468.
339. Wong KK, Burdette E, Mahon B, et al. Recommendations of the Advisory Committee on Immunization Practices for use of cholera vaccine. MMWR 12 May 2017, 66(18):482-485. doi:10.15585/mmwr.mm6618a6.
340. Wesson P, Lechtenberg R, Reingold, A, et al. Evaluating the completeness of HIV surveillance using capture-recapture models, Alameda County, California. AIDS Behav 21 August 2017. doi: 10.1007/s10461-017-1883-6.
341. Orenstein WA, Hinman A, Nkowane B, Olive JM, Reingold A. Measles and Rubella Global Strategic Plan 2012-2020 midterm review. Vaccine 36 (2018); A1-A34; https://doi.org/10.1016/j.vaccine.2017.09.026
342. Orenstein WA, Cairns L., Hinman .A, Nkowane B., J-M., Olive, Reingold A.L. Measles and Rubella Global Strategic Plan 2012-2020 midterm review report: background and summary. Vaccine 36 (2018) A35-A42: https://doi.org/10.1016/j.vaccine.2017.10.065.
343. Schille S, Vellozzi C, Reingold A, et al. Prevention of Hepatitis B Virus Infection in the United States: Recommendations of the Advisory Committee on Immunization Practices. Recommendations and Reports:12 January 2018: 67(1);1-31.
344. Gordon A, Reingold A. The Burden of Influenza: a Complex Problem. Current Epidemiology Reports: 05 February 2018. https://doi.org/10.1007/s40471-018-0136-1.
345. Liang JL, Tiwari T, Moro P, et al. Prevention of Pertussis, Tetanus, and Diphtheria with Vaccines in the United States: Recommendations of the Advisory Committee on Immunization Practices (ACIP). MMWR Recommendations and Reports. 27 April 2018;67(2):1-44. doi:10.15585/mmwr.rr6702a1
346. G. Andreuccetti, C.J. Cherpitel, H.B. Carvalho, V. Leyton, I.D. Miziara, D.R. Munoz, Reingold A, et al. Alcohol in combination with illicit drugs among fatal injuries in Sao Paulo, Brazil: An epidemiological study on the association between acute substance use and injury. Injury, Volume 49, Issue 12, 2018, Pages 2186-2192. https://doi.org/10.1016/j.injury.2018.09.035.
347. Soeters HM, Blain A, Pondo T, Doman B, Farley MM, Harrison LH, Lynfield R, Miller L, Petit S, Reingold A, et al. Current epidemiology and trends in invasive Haemophilus influenzae disease—United States, 2009–2015, Clin Infec Dis, Volume 67, Issue 6, 15 September 2018, Pages 881–889. https://doi.org/10.1093/cid/ciy187.
348. O’Brien KS, Emerson P, Hooper PJ, Reingold AL, et al. Antimicrobial resistance following mass azithromycin distribution for trachoma: a systematic review. Lancet Infect. Dis 2018. October 3, 2018. http://dx.doi.org/10.1016/S1473-3099(18)30444-4.
349. Mendes Lobão W, Duarte FG, Burns JD, et al. Low coverage of HPV vaccination in the national immunization programme in Brazil: Parental vaccine refusal or barriers in health-service based vaccine delivery PLoS One. 2018;13(11):e0206726. doi:10.1371/journal.pone.0206726.
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350. Duarte FG, da Silva Moreir S, da Conceicao C Almeida M, de Souza Teles CA, Andrade CS, Reingold A, et al. Sex differences and correlates of poor glycaemic control in type 2 diabetes: a cross-sectional study in Brazil and Venezuela. BMJ Open. 2019;9:e023401. doi:10.1136/bmjopen-2018-023401.
351. Lewnard JA, Reingold AL. Emerging challenges and opportunities in infectious disease epidemiology. American Journal of Epidemiology. May 2019 Volume 188, Issue 5, Pages 873–882. https://doi.org/10.1093/aje/kwy264
352. Schaffner W, Nichol KL, Reingold AL, Preventing hepatitis in us adults through vaccination. Infectious Diseases In Clinical Practice. November 2018, Volume 26, Issue 6 p 304-312. doi: 10.1097/IPC.0000000000000685.
353. Cardoso CS, Ribeiro ALP, Oliveira CDL, Oliveira LC, Ferreira AM, Bierrenbach AL, Silva JLP, Colosimo EA, Ferreira JE, Lee TH, Busch MP, Reingold AL, et al. Beneficial effects of benznidazole in Chagas disease: NIH SaMi-Trop cohort study. PLoS neglected tropical diseases. 2018.12. https://doi.org/10.1371/journal.pntd.0006814.
354. Dorjee K, Choden T, Baxi SM, Steinmaus C, and Reingold AL. Risk of cardiovascular disease associated with exposure to abacavir among individuals with HIV: a systematic review and meta-analyses of results from 17 epidemiologic studies. International Journal of Antimicrobial Agents. 2018, 52(5), pp.541-553. https://doi.org/10.1016/j.ijantimicag.2018.07.010.
355. Ahmed SS, Pondo T, Xing W, McGee L, Farley M, Schaffner W, Thomas A, Reingold A, et al. Early impact of 13-valent pneumococcal conjugate vaccine use on invasive pneumococcal disease among adults with and without underlying medical conditions--United States. Clinical Infectious Diseases. CID 2019:19. doi:10.1093/cid/ciz739.
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)

Case No. 6:20-cv-00024-NKM

DECLARATION OF STEPHANIE L. ILES (Pursuant to 28 U.S.C. § 1746)
I, Stephanie Iles, hereby declare as follows: 1. I am the Director of Elections & General Registrar of the City of Norfolk, Virginia. In my capacity as Director of Elections & General Registrar, I am responsible for protecting the integrity of the electoral process in the City of Norfolk through maintaining accurate voter records and efficient administration of elections in accordance with federal, state, and local election laws. 2. The responsibilities of my office include providing absentee ballot applications to voters, receiving and processing voters' absentee ballot applications; and sending voters absentee ballots along with the appropriate accompanying materials, including return envelopes and instructions for completing the ballot and voter statement on the ballot envelope. Our office is currently in the process of sending and receiving absentee ballots for the General Election for Mayor, City Council, and School Board (by Superward) scheduled for May 5, 2020 ("May General Election").

Page 1 of 4

Case 6:20-cv-00024-NKM Document 17-2 Filed 04/21/20 Page 2 of 4 Pageid#: 173
3. The spread of the novel coronavirus, along with the accompanying public health response by national, state, and local governments, is having a direct and severe impact on the May General Election and the Primary Election scheduled for June 23, 2020. For example, our office, like all City of Norfolk public buildings, is closed to the public. As a result, persons needing in-person assistance, including those who wish to vote an absentee ballot in person, are being aided through curbside assistance upon request. We are also strongly encouraging all citizens to use online services in order to register to vote, update voter registration information, or to request an absentee ballot. Moreover, our office has been short staffed for several weeks, and we have had difficulties recruiting the same number of poll workers this year as compared with recent years.
4. The health emergency and voters' fear of contracting COVID-19 has led to an unprecedented increase in the share of voters who are requesting absentee ballots. Due to the health risks that the novel coronavirus poses for in-person interactions, our office has been encouraging City of Norfolk voters to vote at home via absentee ballot by mail. As part of that effort, we mailed postcards to 130,605 registered voters in the City of Norfolk, providing information about requesting an absentee ballot online to vote by mail. We also conducted outreach in newspapers, through social media, and in interviews with local news stations, among other methods. Through this outreach we informed voters that they may request an absentee ballot for the May General Election by using "My disability or illness" under the section of the application where they must choose a reason for voting an absentee ballot, provided they do not have another qualifying reason for voting an absentee ballot.
5. Although Governor Northam has proposed moving the May General Election to November 3, 2020, this proposal requires approval by the Virginia General Assembly, which
Page 2 of 4

Case 6:20-cv-00024-NKM Document 17-2 Filed 04/21/20 Page 3 of 4 Pageid#: 174
reconvenes on April 22, 2020. As such, we have continued to process absentee ballots for the May General Election.
6. The very first voter to return an absentee ballot for the May General Election omitted a witness signature on the ballot envelope, as required under state law. The voter made a note that they were unable to obtain a signature because they were social distancing as a result of COVID-19 and in accordance with the orders of state and national officials.
7. The Norfolk Office of Elections has since received several other absentee ballots for the May General Election whose envelopes were missing a witness signature. We have also received phone calls and other inquiries from voters asking what they should do if they do not have a witness to signature. In those cases, we have explained that the witness signature is required under law and they must try to get someone to witness their ballot, if possible. We do not know if these voters were able to comply or not.
8. Under state law and regulations, after an absentee ballot has been returned to the General Registrar office, there is no process for curing or correcting errors on the absentee ballot envelopes before Election Day. As a result, once my office receives an absentee ballot, the vote is considered cast and will be rejected as invalid if there is no witness signature on the ballot envelope.
9. When reviewing absentee ballot envelopes for compliance with the witness requirement, we simply confirm there is a signature such that the law's requirement is met. The signature need not be legible, and we have no ability to confirm the witness's identity.
10. After learning about voters who were unable to comply with the witness requirement as a result of the health emergency, I sent an email to the Commissioner of Elections asking if the Department of Elections planned to loosen requirements for the witness signature. I
Page 3 of 4

Case 6:20-cv-00024-NKM Document 17-2 Filed 04/21/20 Page 4 of 4 Pageid#: 175 was told that they were aware of the concern and were reviewing it, and while there was no change in the requirement at that time, we would be receiving guidance if there were any changes. To date, my office has received no guidance on this issue.
11. Based on the ballots we have received so far, inquiries from voters, and concerns from the general public, I expect that, if the absentee ballot witness requirement remains in place for the May General Election and June primary, and voters are still dealing with the impact of the COVID-19 pandemic, it will result in a disproportionate number of absentee ballots being rejected for not meeting the witness signature requirement as compared with past elections. I declare under penalty of perjury, under the laws of the United States, that the foregoing is true and correct to the best of my knowledge. Dated this 20th day of April 2020.
Stephanie L. Iles
Page 4 of 4

Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 1 of 67 Pageid#: 176

UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA
Lynchburg Division

LEAGUE OF WOMEN VOTERS OF

VIRGINIA;

KATHERINE

D.

CROWLEY; ERIKKA GOFF; and

SEIJRA TOOGOOD,

Plaintiffs,

v.

VIRGINIA STATE BOARD OF ELECTIONS; ROBERT H. BRINK, JOHN O’BANNON, and JAMILAH D. LECRUISE, in their official capacities as Chairman, Vice-Chair, and Secretary of the Virginia State Board of Elections, respectively; and CHRISTOPHER E. PIPER, in his official capacity as Commissioner of the Virginia Department of Elections,

Defendants.

Case No.: 6:20-cv-00024-NKM

DECLARATION OF DAVIN M. ROSBOROUGH (pursuant to 28 U.S.C. § 1746)
My name is Davin M. Rosborough. I am over the age of 18 and fully competent to make this declaration. Under penalty of perjury, I declare the following based upon my personal knowledge:
1. I am attorney with the American Civil Liberties Union Foundation. I personally located and/or prepared the attached materials.
2. Attached as Exhibit A is a true and current copy of United States Census Bureau Current Population Survey data from the year 2018 concerning Virginians’ household size, which is also broken down by age group, race, and disability status. I downloaded this table

Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 2 of 67 Pageid#: 177
using the CPS Table Creator, available at https://www.census.gov/cps/data/cpstablecreator.html. 3. Attached as Exhibit B is a true and correct copy of data downloaded from the
Virginia Department of Elections website reflecting turnout numbers for the 2018 June Republican primary, as accessed at https://apps.elections.virginia.gov/SBE_CSV/ELECTIONS/ELECTIONTURNOUT/.
4. Attached as Exhibit C is a true and correct copy of data downloaded from the Virginia Department of Elections website reflecting turnout numbers for the 2018 June Democratic primary, as accessed at https://apps.elections.virginia.gov/SBE_CSV/ELECTIONS/ELECTIONTURNOUT/.
5. Attached as Exhibit D is a true and correct copy of a March 25, 2020 Order granting a preliminary injunction in Faulkner v. Virginia Department of Elections, No. CL 201546, in the Circuit Court for the City of Richmond.
6. Attached as Exhibit E is a true and current copy of data from the 2018 Election Assistance Commission (EAC) Election Administration and Voting Survey reflecting data, broken down by Virginia city and county, of the total number of mail ballots received for counting and the number rejected for lack of a witness signature. I created this table from data accessed on the EAC’s website at https://www.eac.gov/research-and-data/datasets-codebooksand-surveys, using the EAVS Data Codebook and the EAVS Datasets Version 1.2 (released February 18, 2020).
7. Attached as Exhibit F is a true and correct copy of a March 30, 2020 Letter sent by Marci Andino, in her capacity as Executive Director of the South Carolina State Election Commission, to South Carolina Governor Henry McMaster and other recipients.
8. Attached as Exhibit G is a true and correct copy of an April 17, 2020 Order on
2

Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 3 of 67 Pageid#: 178 Application for Temporary Injunction in the case, Texas Democratic Party v. DeBeauvoir, No. D1-GN-001610, in Travis County District Court in Texas.
I declare under penalty of perjury that the foregoing is true and correct. Executed on April 20, 2020 __________________________________________ Davin M. Rosborough
3

Case 6:20-cv-00024-NKM DocumeEnXt 1H7I-3BIFTileAd 04/21/20 Page 4 of 67 Pageid#: 179

A
2 CPS Data Year 2018 (Numbers in Thousands)
3 State: VA
4 5 Totals 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Race 26 White alone 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 Black or African American alone 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 American Indian and Alaska Native alone 67 68 69

B

C

Totals
Age 00 to 17
18 to 64
65 to 80+

Totals Disability Status With a Disability With no Disability Not in Universe
Totals Disability Status With a Disability With no Disability Not in Universe Totals Disability Status With a Disability With no Disability Not in Universe Totals Disability Status With a Disability With no Disability

Totals
Age 00 to 17
18 to 64
65 to 80+ Totals
Age 00 to 17
18 to 64
65 to 80+ Totals

Totals Disability Status With a Disability With no Disability Not in Universe
Totals Disability Status With a Disability With no Disability Not in Universe Totals Disability Status With a Disability With no Disability Not in Universe Totals Disability Status With a Disability With no Disability Totals Disability Status With a Disability With no Disability Not in Universe
Totals Disability Status With a Disability With no Disability Not in Universe Totals Disability Status With a Disability With no Disability Not in Universe Totals Disability Status With a Disability With no Disability Totals Disability Status With a Disability With no Disability

D

E

F

G

H

I J KL

Totals 8,262

1 1,632

2 2,051

Family Size

3

4

5 6 78

1,402 1,740 920 244 256 16

781 281 291

5,872 1,337 1,651

1,608

14 109

90

76 24 2 17 .

985 1,095 551 121 122 10

327 569 345 120 117 6

1,898 20 128 383 695 400 130 137 6

32 325 1,542 5,170

2 6 12 1,218

12 22 94 1,266

5

4 5 . 4.

73 132 62 13 16 .

305 558 333 117 117 6

952 1,006 506 103 108 10

424 136 128

72

63 14 . 11 .

4,679 1,080 1,123 858 932 480 99 97 10

67

2

15

22

11 12 4 . .

1,194 394 657

67

39 14 11 11 .

325 143 151

13

9 5 2 2.

868 251 506

54

30 9 9 9 .

5,721 1,136 1,469 937 1,211 553 178 221 16

594 206 234

65

61 9 2 17 .

4,103 924 1,188 658 786 333 95 107 10

1,025

6

47 213 364 211 80 97 6

1,199

10

49 245 445 240 88 116 6

14

2

2

2

2 2 . 4.

215

2

12

49

88 36 12 16 .

970

6 34 194 355 201 77 97 6

3,553 799 876 654 730 309 79 95 10

306

83

97

57

52 6 . 11 .

3,193 716 766 578 670 293 75 84 10

55

.

13

19

9 10 4 . .

969 327 544

38

35 5 11 9 .

274 121 134

7

7 1 2 2.

695 206 410

31

28 3 9 7 .

1,607 383 429 265 217 232 61 20 .

146

67

47

15

8 8 . ..

1,137 310 327 200 129 139 26 5 .

325

6

55

50

80 85 35 15 .

403

9

70

66 107 100 37 15 .

10

.

10

.

. . . ..

76

3

8

19

27 17 2 . .

317

6

52

47

80 83 35 15 .

1,044 320 280 178 106 130 24 5 .

98

50

22

11

6 8 . ..

938 269 255 163 100 120 24 5 .

8

.

2

3

. 2 . ..

161

54

79

21

4 2 . ..

38

17

15

4

123

38

64

18

39

9

11

12

2 . . .. 2 2 . ..
7 . . ..

2

2

.

.

20

5

11

5

. . . .. . . . ..

Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 5 of 67 Pageid#: 180

A 70 71 72 73 74 75 76 77 78 79 80 81 82 83 Asian alone 84 85 86 87 88 89 90 91 92 93 94 95 96 97 98 99 100 101 102 Native Hawaiian and Other Pacific Islander alone 103 104 105 106 107 108 109 110 111 112 113 114 115 116 Two or more races 117 118 119 120 121 122 123 124 125 126 127 128 129 130 131 132 133
Inferences should be made with extreme caution when the cell sizes are small. To examine cell sizes, select "Display 134 Unweighted Record Counts" under the Statistics Option.

B Age 00 to 17 18 to 64
65 to 80+ Totals
Age 00 to 17
18 to 64
65 to 80+
Totals
Age 00 to 17 18 to 64 65 to 80+ Totals
Age 00 to 17
18 to 64
65 to 80+

C Not in Universe
Totals Disability Status Not in Universe Totals Disability Status With a Disability With no Disability Not in Universe Totals Disability Status With no Disability Totals Disability Status With a Disability With no Disability Not in Universe
Totals Disability Status With a Disability With no Disability Not in Universe Totals Disability Status With a Disability With no Disability Totals Disability Status With a Disability With no Disability Totals Disability Status With no Disability Not in Universe
Totals Disability Status Not in Universe Totals Disability Status With no Disability Totals Disability Status With no Disability Totals Disability Status With a Disability With no Disability Not in Universe
Totals Disability Status With a Disability With no Disability Not in Universe Totals Disability Status With a Disability With no Disability Totals Disability Status With no Disability

D

E

F

G

H

I J KL

16

2

.

7

7 . . ..

12

.

.

7

5 . . ..

12

.

.

7

5 . . ..

25

9

9

5

2 . . ..

2

2

.

.

. . . ..

18

5

9

5

. . . ..

4

2

.

.

2 . . ..

2

.

2

.

. . . ..

2

.

2

.

. . . ..

625

70 118 127 206 92 . 13 .

25

5

5

6

6 4 . ..

449

65 105

91 124 58 . 7 .

150

.

8

30

76 30 . 6 .

169

1

9

32

86 34 . 6 .

2

.

.

.

2 . . ..

16

1

2

2

7 4 . ..

150

.

8

30

76 30 . 6 .

404

59

80

89 120 50 . 5 .

10

.

3

4

4 . . ..

393

59

78

85 117 50 . 5 .

52

9

28

6

. 7 . 2.

13

5

2

2

40

4

26

4

.4 .4

. .. . 2.

34

5

4

3

22 . . . .

30

5

4

3

17 . . . .

5

.

.

.

5 . . ..

5

.

.

.

5 . . ..

5

.

.

.

5 . . ..

27

2

4

3

17 . . . .

27

2

4

3

17 . . . .

3

3

.

.

. . . ..

3

3

.

.

. . . ..

235

29

21

58

78 43 5 2 .

14

.

5

4

2 3 . ..

134

29

16

29

38 21 . 2 .

87

.

.

26

38 19 5 . .

111

.

.

33

48 26 5 . .

7

.

.

4

. 3 . ..

17

.

.

3

10 4 . . .

87

.

.

26

38 19 5 . .

118

29

17

24

30 16 . 2 .

7

.

5

.

2 . . ..

111

29

11

24

28 16 . 2 .

6

.

4

2

. . . ..

6

.

4

2

. . . ..

Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 6 of 67 Pageid#: 181

A

B

Some CPS questions, such as income, ask about the previous

year. Others, such as age, refer to the time of the survey. The

column labels indicate any subject with a reference year which

135 differs from the survey year.

Current Population Survey, Annual Social and Economic

136 Supplement, 2018

137 Source: U.S. Census Bureau

C

D

E

F

G

H

I J KL

Case 6:20-cv-00024-NKM DocumEeXntH17IB-3ITFiBled 04/21/20 Page 7 of 67 Pageid#: 182

election 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary

locality ACCOMACK COUNTY ACCOMACK COUNTY ACCOMACK COUNTY ACCOMACK COUNTY ACCOMACK COUNTY ACCOMACK COUNTY ACCOMACK COUNTY ACCOMACK COUNTY ACCOMACK COUNTY ACCOMACK COUNTY ACCOMACK COUNTY ACCOMACK COUNTY ACCOMACK COUNTY ACCOMACK COUNTY ACCOMACK COUNTY ACCOMACK COUNTY ACCOMACK COUNTY ACCOMACK COUNTY ALBEMARLE COUNTY ALBEMARLE COUNTY ALBEMARLE COUNTY ALBEMARLE COUNTY ALBEMARLE COUNTY ALBEMARLE COUNTY ALBEMARLE COUNTY ALBEMARLE COUNTY ALBEMARLE COUNTY ALBEMARLE COUNTY ALBEMARLE COUNTY ALBEMARLE COUNTY ALBEMARLE COUNTY ALBEMARLE COUNTY ALBEMARLE COUNTY ALBEMARLE COUNTY ALBEMARLE COUNTY ALBEMARLE COUNTY ALBEMARLE COUNTY ALBEMARLE COUNTY ALBEMARLE COUNTY ALBEMARLE COUNTY ALBEMARLE COUNTY ALBEMARLE COUNTY ALBEMARLE COUNTY ALBEMARLE COUNTY ALBEMARLE COUNTY ALBEMARLE COUNTY ALBEMARLE COUNTY ALBEMARLE COUNTY ALBEMARLE COUNTY ALBEMARLE COUNTY ALEXANDRIA CITY ALEXANDRIA CITY ALEXANDRIA CITY ALEXANDRIA CITY ALEXANDRIA CITY ALEXANDRIA CITY ALEXANDRIA CITY ALEXANDRIA CITY ALEXANDRIA CITY ALEXANDRIA CITY ALEXANDRIA CITY ALEXANDRIA CITY ALEXANDRIA CITY ALEXANDRIA CITY ALEXANDRIA CITY ALEXANDRIA CITY ALEXANDRIA CITY ALEXANDRIA CITY ALEXANDRIA CITY ALEXANDRIA CITY ALEXANDRIA CITY ALEXANDRIA CITY ALEXANDRIA CITY ALEXANDRIA CITY ALEXANDRIA CITY ALEXANDRIA CITY ALEXANDRIA CITY ALEXANDRIA CITY ALEXANDRIA CITY ALEXANDRIA CITY ALLEGHANY COUNTY ALLEGHANY COUNTY ALLEGHANY COUNTY ALLEGHANY COUNTY ALLEGHANY COUNTY ALLEGHANY COUNTY ALLEGHANY COUNTY ALLEGHANY COUNTY ALLEGHANY COUNTY ALLEGHANY COUNTY ALLEGHANY COUNTY ALLEGHANY COUNTY ALLEGHANY COUNTY ALLEGHANY COUNTY AMELIA COUNTY AMELIA COUNTY AMELIA COUNTY AMELIA COUNTY AMELIA COUNTY AMELIA COUNTY AMELIA COUNTY AMHERST COUNTY AMHERST COUNTY AMHERST COUNTY AMHERST COUNTY AMHERST COUNTY

precinct ##Central Absentee ##Central Absentee 101 - CHINCOTEAGUE 201 - ATLANTIC 202 - GREENBACKVILLE 301 - NEW CHURCH 401 - BLOXOM 402 - PARKSLEY 403 - SAXIS 501 - MAPPSVILLE 502 - RUE 601 - ACCOMAC 602 - TANGIER 701 - NANDUA 801 - BOBTOWN 802 - MELFA 803 - WACHAPREAGUE 901 - PAINTER ##Central Absentee ##Central Absentee 101 - WOODBROOK 103 - BRANCHLANDS 104 - AGNOR-HURT 105 - DUNLORA 106 - NORTHSIDE 201 - JACK JOUETT 202 - UNIVERSITY 203 - GEORGETOWN 301 - IVY 302 - RED HILL 304 - EAST IVY 305 - COUNTRY GREEN 306 - PORTERS 307 - YELLOW MOUNTAIN 401 - SCOTTSVILLE 402 - MONTICELLO 405 - CALE 406 - STONE ROBINSON 407 - BISCUIT RUN 501 - KESWICK 502 - STONY POINT 503 - HOLLYMEAD 504 - FREE BRIDGE 506 - BAKER-BUTLER 507 - PANTOPS 601 - CROZET 602 - FREE UNION 603 - EARLYSVILLE 604 - BROWNSVILLE 606 - MECHUMS RIVER ##Central Absentee ##Central Absentee 101 - LADREY SENIOR BUILDING 102 - CITY HALL 103 - LYLES CROUCH SCHOOL 104 - DURANT CENTER 105 - LEE CENTER 106 - CORA KELLY 107 - MT VERNON RECREATION CENTER 108 - GEORGE WASHINGTON MIDDLE SCH 109 - FIRE DEPARTMENT HEADQUARTERS 110 - CHARLES HOUSTON CENTER 111 - POTOMAC YARD 201 - MAURY SCHOOL 202 - GEORGE MASON SCHOOL 203 - AGUDAS ACHIM SYNAGOGUE 204 - BLESSED SACRAMENT CHURCH 205 - DOUGLAS MACARTHUR SCHOOL 206 - CHINQUAPIN PARK RECREATION CTR 207 - TEMPLE BETH EL SYNAGOGUE 208 - NOVA ARTS CENTER 209 - JAMES K POLK SCHOOL 210 - The Hermitage 302 - PATRICK HENRY REC CENTER 303 - CHARLES E BEATLEY LIBRARY 304 - SAMUEL TUCKER SCHOOL 305 - JOHN ADAMS SCHOOL 306 - WILLIAM RAMSAY SCHOOL 307 - SOUTH PORT 308 - CAMERON STATION COMMUNITY CTR ##Central Absentee ##Central Absentee 101 - ARRITT 103 - DAMERON 201 - HUMPBACK BRIDGE 202 - DOLLY ANN 301 - CALLAGHAN 302 - GRIFFITH 401 - LOW MOOR 402 - JACKSON HEIGHTS 501 - IRON GATE 502 - PETERS SWITCH 601 - DISTRICT 1 701 - DISTRICT 2 ##Central Absentee ##Central Absentee 101 - NUMBER ONE 201 - NUMBER TWO 301 - NUMBER THREE 401 - NUMBER FOUR 501 - NUMBER FIVE ##Central Absentee ##Central Absentee 101 - WRIGHT SHOP 102 - NEW GLASGOW 103 - COOLWELL

provisional ballots absentee_ballots in_person_ballots in_person_curbside_ballots

0

18

19

0

18

19

0

0

193

0

0

107

0

0

140

0

0

88

0

0

54

0

0

110

0

0

36

0

0

45

0

0

17

0

0

128

0

0

84

0

0

217

0

0

94

0

0

61

0

0

98

0

0

183

0

105

0

0

105

0

0

0

170

0

0

50

1

0

77

0

0

136

1

0

176

0

0

226

0

0

40

0

0

57

1

0

204

0

0

129

0

0

55

0

0

83

0

0

91

0

0

36

0

0

80

0

0

83

0

0

103

0

0

238

0

0

47

0

0

83

0

0

145

0

0

124

0

0

87

1

0

206

0

0

125

0

0

141

0

0

79

0

0

211

0

0

107

0

0

137

0

176

0

0

176

0

0

0

80

0

0

53

0

0

95

0

0

72

0

0

93

0

0

67

1

0

76

0

0

87

0

0

89

0

0

90

0

0

49

0

0

80

0

0

58

0

0

68

0

0

67

1

0

92

1

0

55

1

0

122

1

0

58

0

0

65

0

0

56

0

0

56

0

0

68

0

0

66

0

0

51

0

0

45

0

0

70

0

0

149

0

4

0

0

4

0

0

0

26

0

0

19

0

0

16

0

0

24

0

0

22

0

0

48

0

0

31

0

0

32

0

0

14

0

0

52

0

0

42

0

0

29

0

5

24

0

5

24

0

0

128

0

0

144

0

0

168

0

0

189

0

0

188

0

44

0

0

44

0

0

0

42

0

0

101

0

0

56

TotalVoteTurnout

0

37

0

37

0

193

0

107

0

140

0

88

0

54

0

110

0

36

0

45

0

17

0

128

0

84

0

217

0

94

0

61

0

98

0

183

0

105

0

105

1

170

0

50

0

78

1

136

0

177

0

226

0

40

0

57

0

205

0

129

0

55

0

83

0

91

1

36

0

80

0

83

0

103

0

238

0

47

0

83

2

145

0

124

0

87

0

207

0

125

0

141

0

79

0

211

0

107

1

137

0

176

0

176

0

80

0

53

0

95

0

72

0

93

0

67

0

77

0

87

0

89

0

90

0

49

0

80

0

58

0

68

0

67

0

93

0

56

0

123

0

59

0

65

0

56

0

56

0

68

0

66

0

51

0

45

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Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 8 of 67 Pageid#: 183

2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary

AMHERST COUNTY AMHERST COUNTY AMHERST COUNTY AMHERST COUNTY AMHERST COUNTY AMHERST COUNTY AMHERST COUNTY AMHERST COUNTY APPOMATTOX COUNTY APPOMATTOX COUNTY APPOMATTOX COUNTY APPOMATTOX COUNTY APPOMATTOX COUNTY APPOMATTOX COUNTY APPOMATTOX COUNTY APPOMATTOX COUNTY APPOMATTOX COUNTY APPOMATTOX COUNTY APPOMATTOX COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY ARLINGTON COUNTY AUGUSTA COUNTY AUGUSTA COUNTY AUGUSTA COUNTY AUGUSTA COUNTY AUGUSTA COUNTY AUGUSTA COUNTY AUGUSTA COUNTY AUGUSTA COUNTY AUGUSTA COUNTY AUGUSTA COUNTY AUGUSTA COUNTY AUGUSTA COUNTY AUGUSTA COUNTY AUGUSTA COUNTY AUGUSTA COUNTY AUGUSTA COUNTY AUGUSTA COUNTY AUGUSTA COUNTY AUGUSTA COUNTY AUGUSTA COUNTY AUGUSTA COUNTY AUGUSTA COUNTY AUGUSTA COUNTY AUGUSTA COUNTY AUGUSTA COUNTY AUGUSTA COUNTY AUGUSTA COUNTY BATH COUNTY BATH COUNTY BATH COUNTY BATH COUNTY BATH COUNTY

201 - COURT HOUSE 202 - TEMPERANCE 301 - MONROE 302 - ELON 303 - PLEASANT VIEW 401 - AMELON 402 - LONCO 501 - MADISON ##Central Absentee ##Central Absentee 101 - VERA 102 - PAMPLIN 201 - CHAP 202 - SPOUT SPRING 301 - US 460 302 - STONEWALL 401 - COURTHOUSE 501 - OAKVILLE 502 - AGEE ##Central Absentee ##Central Absentee 001 - ARLINGTON 002 - ASHTON HEIGHTS 003 - AURORA HILLS 004 - BALLSTON 005 - BARCROFT 006 - CRYSTAL CITY 007 - CHERRYDALE 008 - HUME 009 - COLUMBIA 010 - WILSON 011 - EAST FALLS CHURCH 012 - FAIRLINGTON 013 - GLEN CARLYN 014 - CLARENDON 015 - LYON PARK 016 - LYON VILLAGE 017 - OVERLEE KNOLLS 018 - PARK LANE 019 - ROSSLYN 020 - THRIFTON 021 - VIRGINIA HIGHLANDS 022 - ABINGDON 023 - WESTOVER 024 - WOODLAWN 025 - ARLINGTON FOREST 026 - FILLMORE 027 - JEFFERSON 028 - WAKEFIELD 029 - DOMINION HILLS 030 - GLEBE 031 - LEXINGTON 032 - OAKRIDGE 033 - ROCK SPRING 034 - YORKTOWN 035 - MADISON 036 - MARSHALL 037 - NOTTINGHAM 038 - ARLINGTON VIEW 039 - ASHLAWN 040 - VIRGINIA SQUARE 041 - NAVY LEAGUE 042 - SHIRLINGTON 043 - CAMPBELL 044 - DAWSON TERRACE 045 - BUCKINGHAM 046 - CENTRAL 047 - FOUR MILE RUN 048 - AUSA 049 - MONROE 050 - CRYSTAL PLAZA 051 - TAYLOR 052 - GUNSTON 053 - MET PARK 054 - GARFIELD PARK ##Central Absentee ##Central Absentee 101 - JOLIVUE 102 - STUARTS DRAFT ELEMENTARY 103 - VERONA 201 - CRIMORA 202 - NEW HOPE 203 - WEYERS CAVE 301 - FORT DEFIANCE 302 - NORTH RIVER 303 - MOUNT SOLON 304 - CHURCHVILLE FIRE STATION 401 - BUFFALO GAP 402 - CHURCHVILLE ELEMENTARY 403 - CRAIGSVILLE 404 - DEERFIELD 405 - CEDAR GREEN 501 - GREENVILLE 502 - MIDDLEBROOK 503 - SPOTTSWOOD 504 - WHITE HILL 601 - SHERANDO 602 - RIDGEVIEW 603 - LYNDHURST 801 - DOOMS 802 - FISHERSVILLE 803 - WILSON ##Central Absentee ##Central Absentee 101 - WARM SPRINGS 102 - MOUNTAIN GROVE 201 - HOT SPRINGS

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Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 9 of 67 Pageid#: 184

2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary

BATH COUNTY BATH COUNTY BATH COUNTY BATH COUNTY BEDFORD COUNTY BEDFORD COUNTY BEDFORD COUNTY BEDFORD COUNTY BEDFORD COUNTY BEDFORD COUNTY BEDFORD COUNTY BEDFORD COUNTY BEDFORD COUNTY BEDFORD COUNTY BEDFORD COUNTY BEDFORD COUNTY BEDFORD COUNTY BEDFORD COUNTY BEDFORD COUNTY BEDFORD COUNTY BEDFORD COUNTY BEDFORD COUNTY BEDFORD COUNTY BEDFORD COUNTY BEDFORD COUNTY BEDFORD COUNTY BEDFORD COUNTY BEDFORD COUNTY BEDFORD COUNTY BEDFORD COUNTY BEDFORD COUNTY BEDFORD COUNTY BEDFORD COUNTY BEDFORD COUNTY BEDFORD COUNTY BEDFORD COUNTY BEDFORD COUNTY BEDFORD COUNTY BEDFORD COUNTY BLAND COUNTY BLAND COUNTY BLAND COUNTY BLAND COUNTY BLAND COUNTY BLAND COUNTY BLAND COUNTY BLAND COUNTY BLAND COUNTY BOTETOURT COUNTY BOTETOURT COUNTY BOTETOURT COUNTY BOTETOURT COUNTY BOTETOURT COUNTY BOTETOURT COUNTY BOTETOURT COUNTY BOTETOURT COUNTY BOTETOURT COUNTY BOTETOURT COUNTY BOTETOURT COUNTY BOTETOURT COUNTY BRISTOL CITY BRISTOL CITY BRISTOL CITY BRISTOL CITY BRISTOL CITY BRISTOL CITY BRUNSWICK COUNTY BRUNSWICK COUNTY BRUNSWICK COUNTY BRUNSWICK COUNTY BRUNSWICK COUNTY BRUNSWICK COUNTY BRUNSWICK COUNTY BRUNSWICK COUNTY BRUNSWICK COUNTY BRUNSWICK COUNTY BRUNSWICK COUNTY BRUNSWICK COUNTY BRUNSWICK COUNTY BRUNSWICK COUNTY BRUNSWICK COUNTY BUCHANAN COUNTY BUCHANAN COUNTY BUCHANAN COUNTY BUCHANAN COUNTY BUCHANAN COUNTY BUCHANAN COUNTY BUCHANAN COUNTY BUCHANAN COUNTY BUCHANAN COUNTY BUCHANAN COUNTY BUCHANAN COUNTY BUCHANAN COUNTY BUCHANAN COUNTY BUCHANAN COUNTY BUCHANAN COUNTY BUCHANAN COUNTY BUCHANAN COUNTY BUCHANAN COUNTY BUCHANAN COUNTY BUCKINGHAM COUNTY BUCKINGHAM COUNTY BUCKINGHAM COUNTY BUCKINGHAM COUNTY BUCKINGHAM COUNTY BUCKINGHAM COUNTY BUCKINGHAM COUNTY

301 - FAIRVIEW 302 - BURNSVILLE 401 - MILLBORO 501 - HEALING SPRINGS ##Central Absentee ##Central Absentee ##Central Absentee 101 - GOODVIEW ELEM SCHOOL 102 - HARDY VOL FIRE CO 103 - CHAMBLISSBURG BAPTIST CHURCH 104 - STEWARTSVILLE RESCUE SQUAD 201 - BEDFORD CHRISTIAN CHURCH 202 - STAUNTON RIVER HIGH SCHOOL 203 - MONETA ELEM SCHOOL 204 - Quaker BAPTIST CHURCH 205 - SAUNDERS VOL FIRE CO 301 - NEW LONDON ACADEMY 302 - BEDFORD REGIONAL WATER AUTH 303 - BETHESDA UNITED METHODIST CHURCH 304 - RIVERSIDE CHURCH 305 - HUDDLESTON ELEM SCHOOL 306 - FOREST FIRE STATION #2 401 - FOREST ELEMENTARY SCHOOL 402 - THOMAS JEFFERSON ELEM SCHOOL 403 - KNIGHTS OF COLUMBUS BLDG 404 - ST. PAUL BAPTIST CHURCH 502 - BIG ISLAND ELEM SCHOOL 503 - SEDALIA CENTER 504 - SUCK SPRINGS BAPTIST CHURCH 505 - BOONSBORO ELEMENTARY SCHOOL 506 - BOONSBORO RURITAN CLUB 601 - MONTVALE ELEM SCHOOL 602 - SHADY GROVE FIRE DEPARTMENT 603 - THAXTON BAPTIST CHURCH #1 604 - BEDFORD WELCOME CENTER 701 - GOODE VOL RESCUE SQUAD 702 - LIBERTY HIGH SCHOOL 703 - THAXTON BAPTIST CHURCH #2 704 - BEDFORD CENTRAL LIBRARY ##Central Absentee ##Central Absentee 101 - BASTIAN 102 - CERES 201 - DAVIS 202 - SEDDON 301 - HOLLYBROOK 302 - MECHANICSBURG 401 - ROCKY GAP ##Central Absentee ##Central Absentee 101 - DALEVILLE 102 - GREENFIELD 201 - BLUE RIDGE 202 - RAINBOW FOREST 301 - BUCHANAN 302 - MILL CREEK 403 - EAGLE ROCK 406 - FINCASTLE 501 - TROUTVILLE 502 - CLOVERDALE ##Central Absentee ##Central Absentee 001 - FIRST WARD 002 - SECOND WARD 003 - THIRD WARD 004 - FOURTH WARD ##Central Absentee ##Central Absentee 101 - BRODNAX 102 - ROCK STORE 103 - TILLMAN 201 - DROMGOOLE 202 - EDGERTON 203 - FITZHUGH 301 - ALBERTA 302 - DANIELTOWN 303 - ELMORE 304 - SEYMOUR 401 - STURGEON 402 - KING'S STORE 501 - TOTARO ##Central Absentee ##Central Absentee 102 - BLACKEY 103 - HURLEY 201 - GRASSY 202 - BULL 203 - ROCKLICK 301 - SLATE 302 - NORTH GRUNDY 403 - SOUTH GRUNDY 404 - OAKWOOD 501 - PRATER 502 - FOX 503 - VANSANT 601 - COUNCIL 602 - GARDEN 603 - HURRICANE 701 - WHITEWOOD 702 - CONTRARY ##Central Absentee ##Central Absentee 101 - NEW CANTON 102 - GEORGIA CREEK 201 - WHITE HALL 301 - CURDSVILLE 302 - NEW STORE

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Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 10 of 67 Pageid#: 185

2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary

BUCKINGHAM COUNTY BUCKINGHAM COUNTY BUCKINGHAM COUNTY BUCKINGHAM COUNTY BUCKINGHAM COUNTY BUENA VISTA CITY BUENA VISTA CITY CAMPBELL COUNTY CAMPBELL COUNTY CAMPBELL COUNTY CAMPBELL COUNTY CAMPBELL COUNTY CAMPBELL COUNTY CAMPBELL COUNTY CAMPBELL COUNTY CAMPBELL COUNTY CAMPBELL COUNTY CAMPBELL COUNTY CAMPBELL COUNTY CAMPBELL COUNTY CAMPBELL COUNTY CAMPBELL COUNTY CAMPBELL COUNTY CAMPBELL COUNTY CAMPBELL COUNTY CAROLINE COUNTY CAROLINE COUNTY CAROLINE COUNTY CAROLINE COUNTY CAROLINE COUNTY CAROLINE COUNTY CAROLINE COUNTY CAROLINE COUNTY CAROLINE COUNTY CAROLINE COUNTY CAROLINE COUNTY CAROLINE COUNTY CAROLINE COUNTY CAROLINE COUNTY CARROLL COUNTY CARROLL COUNTY CARROLL COUNTY CARROLL COUNTY CARROLL COUNTY CARROLL COUNTY CARROLL COUNTY CARROLL COUNTY CARROLL COUNTY CARROLL COUNTY CARROLL COUNTY CARROLL COUNTY CARROLL COUNTY CARROLL COUNTY CARROLL COUNTY CARROLL COUNTY CARROLL COUNTY CARROLL COUNTY CARROLL COUNTY CHARLES CITY COUNTY CHARLES CITY COUNTY CHARLES CITY COUNTY CHARLES CITY COUNTY CHARLES CITY COUNTY CHARLOTTE COUNTY CHARLOTTE COUNTY CHARLOTTE COUNTY CHARLOTTE COUNTY CHARLOTTE COUNTY CHARLOTTE COUNTY CHARLOTTE COUNTY CHARLOTTE COUNTY CHARLOTTE COUNTY CHARLOTTESVILLE CITY CHARLOTTESVILLE CITY CHARLOTTESVILLE CITY CHARLOTTESVILLE CITY CHARLOTTESVILLE CITY CHARLOTTESVILLE CITY CHARLOTTESVILLE CITY CHARLOTTESVILLE CITY CHARLOTTESVILLE CITY CHARLOTTESVILLE CITY CHARLOTTESVILLE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY

401 - MAYSVILLE 501 - WRIGHTS 502 - GLENMORE 601 - SLATE RIVER 701 - GOLD HILL 001 - FIRST WARD 002 - SECOND WARD ##Central Absentee ##Central Absentee 101 - BROOKVILLE 102 - NEW LONDON 201 - WALKER 202 - BEDFORD SPRINGS 301 - EVINGTON 302 - OTTER RIVER 303 - ALTAVISTA 401 - THREE FORKS 402 - COURT HOUSE 501 - SPRING HILL 502 - YELLOW BRANCH 601 - KINGS 602 - CONCORD 701 - BROOKNEAL 702 - GLADYS 703 - MORRIS CHURCH ##Central Absentee ##Central Absentee 101 - BOWLING GREEN 102 - SPARTA 201 - NORTH MADISON 202 - SOUTH MADISON 301 - PORT ROYAL 302 - WOODFORD 401 - DAWN 402 - CARMEL CHURCH 501 - WEST MATTAPONI 502 - MILFORD 601 - CHILESBURG 602 - LAKE ##Central Absentee ##Central Absentee 101 - MT BETHEL 102 - ST PAUL 103 - LAMBSBURG 105 - FANCY GAP 201 - HILLSVILLE B 202 - LAUREL FORK 203 - GLADESBORO 301 - HILLSVILLE C 302 - SYLVATUS 303 - DUGSPUR 401 - OAKLAND 402 - WOODLAWN D 406 - WOODLAWN F 501 - VAUGHAN 502 - GLADEVILLE 503 - WOODLAWN E 504 - LAUREL ##Central Absentee ##Central Absentee 101 - PRECINCT 1-1 201 - PRECINCT 2-1 301 - PRECINCT 3-1 ##Central Absentee ##Central Absentee 101 - COUNTY SEAT 201 - RED OAK WYLLIESBURG 302 - DRAKES BRANCH 401 - KEYSVILLE 501 - CULLEN/RED HOUSE 602 - PHENIX 702 - BACON/SAXE ##Central Absentee ##Central Absentee 101 - RECREATION 102 - CLARK 201 - CARVER 202 - WALKER 301 - BENJAMIN TONSLER 302 - JOHNSON 303 - BUFORD 401 - VENABLE 402 - ALUMNI HALL ##Central Absentee ##Central Absentee ##Central Absentee 001 - GREAT BRIDGE 002 - BETHEL 003 - CAMELOT 004 - CHURCHLAND 005 - CRESTWOOD 006 - DEEP CREEK 007 - GREENBRIER 008 - SOUTH NORFOLK RECREATION 009 - BELLS MILL 010 - OSCAR SMITH 011 - GENEVA PARK 012 - GEORGETOWN 013 - GILMERTON 014 - GRASSFIELD 015 - B M WILLIAMS 016 - HICKORY GROVE 017 - INDIAN CREEK 018 - INDIAN RIVER 019 - JOLLIFF 020 - E W CHITTUM 020 - E W CHITTUM

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Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 11 of 67 Pageid#: 186

2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary

CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESAPEAKE CITY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY

021 - FELLOWSHIP 022 - NORFOLK HIGHLANDS 023 - OAK GROVE 024 - OAKLETTE 025 - ST JULIANS 026 - JOHNSON PARK 027 - SILVERWOOD 028 - SUNRAY I 029 - TANGLEWOOD 030 - SOUTH NORFOLK 031 - CARVER SCHOOL 032 - PROVIDENCE 033 - WESTOVER 034 - HICKORY MIDDLE SCHOOL 035 - TAYLOR ROAD 036 - GREAT BRIDGE BAPTIST CHURCH 037 - BRIDGETOWN 038 - BAILEY CREEK 039 - LAKE DRUMMOND 040 - RIVER BIRCH 041 - JOHN T WEST 042 - PARKWAYS 043 - PLEASANT CROSSING 044 - NANSEMOND 045 - SUNRAY II 046 - BELLS MILL II 047 - GREEN SEA 048 - JOLLIFF MIDDLE SCHOOL 049 - WATERWAY 050 - RIVER WALK 051 - COOPERS WAY 052 - SHIPYARD ROAD 053 - FAIRWAYS 054 - PUGHSVILLE 055 - GEORGETOWN EAST 056 - GREEN TREE 057 - CYPRESS 058 - EXPRESSWAY 059 - CLEARFIELD 060 - PARKER ROAD 061 - CENTERVILLE 062 - FENTRESS 063 - POPLAR BRANCH ##Central Absentee ##Central Absentee ##Central Absentee 101 - BELLWOOD 102 - SOUTH CHESTER 103 - ENON 104 - NORTH CHESTER 105 - DREWRYS BLUFF 106 - HARROWGATE 107 - WELLS 108 - ECOFF 109 - ELIZABETH SCOTT 110 - DUTCH GAP 111 - IRON BRIDGE 112 - CARVER 201 - GATES 202 - BEULAH 203 - BIRD 204 - JACOBS 205 - FALLING CREEK 206 - BELMONT 207 - CHIPPENHAM 208 - MEADOWBROOK 209 - SALEM CHURCH 210 - FIVE FORKS 211 - NASH 212 - ST. LUKE'S 213 - SOUTHSIDE 214 - HOPKINS 215 - North Bird 301 - ETTRICK 302 - DEER RUN 303 - MATOACA 304 - WINFREES STORE 305 - BEACH 306 - WINTERPOCK 307 - COSBY 308 - SOUTH MANCHESTER 309 - SKINQUARTER 310 - TOMAHAWK 313 - WOOLRIDGE 315 - BAILEY BRIDGE 316 - SPRING RUN 317 - BIRKDALE 318 - WEST BEACH 401 - HARBOUR POINTE 402 - GENITO 403 - BRANDERMILL 404 - PROVIDENCE 405 - LA PRADE 406 - SMOKETREE 407 - MONACAN 408 - REAMS 409 - MANCHESTER 410 - WAGSTAFF 411 - SWIFT CREEK 413 - SHENANDOAH 414 - CRENSHAW 415 - EVERGREEN 416 - EVERGREEN WEST 417 - EDGEWATER 501 - HUGUENOT 502 - CRESTWOOD 503 - MIDLOTHIAN

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Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 12 of 67 Pageid#: 187

2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary

CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CHESTERFIELD COUNTY CLARKE COUNTY CLARKE COUNTY CLARKE COUNTY CLARKE COUNTY CLARKE COUNTY CLARKE COUNTY CLARKE COUNTY CLARKE COUNTY CLARKE COUNTY COLONIAL HEIGHTS CITY COLONIAL HEIGHTS CITY COLONIAL HEIGHTS CITY COLONIAL HEIGHTS CITY COLONIAL HEIGHTS CITY COLONIAL HEIGHTS CITY COLONIAL HEIGHTS CITY COVINGTON CITY COVINGTON CITY COVINGTON CITY COVINGTON CITY COVINGTON CITY COVINGTON CITY COVINGTON CITY CRAIG COUNTY CRAIG COUNTY CRAIG COUNTY CRAIG COUNTY CRAIG COUNTY CRAIG COUNTY CRAIG COUNTY CRAIG COUNTY CULPEPER COUNTY CULPEPER COUNTY CULPEPER COUNTY CULPEPER COUNTY CULPEPER COUNTY CULPEPER COUNTY CULPEPER COUNTY CULPEPER COUNTY CULPEPER COUNTY CULPEPER COUNTY CULPEPER COUNTY CULPEPER COUNTY CULPEPER COUNTY CULPEPER COUNTY CULPEPER COUNTY CULPEPER COUNTY CULPEPER COUNTY CUMBERLAND COUNTY CUMBERLAND COUNTY CUMBERLAND COUNTY CUMBERLAND COUNTY CUMBERLAND COUNTY CUMBERLAND COUNTY CUMBERLAND COUNTY DANVILLE CITY DANVILLE CITY DANVILLE CITY DANVILLE CITY DANVILLE CITY DANVILLE CITY DANVILLE CITY DANVILLE CITY DANVILLE CITY DANVILLE CITY DANVILLE CITY DANVILLE CITY DANVILLE CITY DANVILLE CITY DANVILLE CITY DANVILLE CITY DANVILLE CITY DANVILLE CITY DICKENSON COUNTY DICKENSON COUNTY DICKENSON COUNTY DICKENSON COUNTY DICKENSON COUNTY DICKENSON COUNTY DICKENSON COUNTY DICKENSON COUNTY DICKENSON COUNTY DICKENSON COUNTY DICKENSON COUNTY DICKENSON COUNTY DINWIDDIE COUNTY DINWIDDIE COUNTY DINWIDDIE COUNTY DINWIDDIE COUNTY DINWIDDIE COUNTY DINWIDDIE COUNTY DINWIDDIE COUNTY DINWIDDIE COUNTY

504 - ROBIOUS 505 - BON AIR 506 - GREENFIELD 507 - SALISBURY 508 - BELGRADE 509 - CRANBECK 510 - SYCAMORE 511 - BLACK HEATH 513 - BEAUFONT 514 - WATKINS 515 - DAVIS 516 - POCOSHOCK 517 - ROSELAND 518 - MIDLOTHIAN NORTH ##Central Absentee ##Central Absentee 101 - RUSSELL 201 - BERRYVILLE 301 - MILLWOOD 302 - PINE GROVE 401 - WHITE POST 501 - BUCKMARSH 502 - BLUE RIDGE ##Central Absentee ##Central Absentee 001 - FIRST 002 - SECOND 003 - THIRD 004 - FOURTH 005 - FIFTH ##Central Absentee ##Central Absentee 101 - PRECINCT 1-1 201 - PRECINCT 2-1 301 - PRECINCT 3-1 401 - PRECINCT 4-1 501 - PRECINCT 5-1 101 - COURT HOUSE 201 - AMMENDALE PRECINCT 301 - GIVENS & REYNOLDS STORE 303 - MARSHALLS STORE 401 - BARBOURS CREEK 402 - PAINT BANK 403 - CRAIG SPRINGS 501 - CRAIG CITY ##Central Absentee ##Central Absentee 101 - WEST FAIRFAX 201 - EAST FAIRFAX 302 - EGGBORNSVILLE 303 - CARDOVA 304 - WILLOW SHADE 401 - ELDORADO 402 - BROWNS STORE 501 - JEFFERSONTON 502 - RIXEYVILLE 601 - MITCHELLS 602 - PEARL SAMPLE 603 - SOUTH RIDGE 702 - BRANDY STATION 703 - LIGNUM 704 - RICHARDSVILLE ##Central Absentee ##Central Absentee 101 - PRECINCT 1 201 - PRECINCT 2 301 - PRECINCT 3 401 - PRECINCT 4 501 - PRECINCT 5 ##Central Absentee ##Central Absentee 001 - WARD ONE 002 - WARD TWO 003 - WARD THREE 004 - WARD FOUR 006 - WARD SIX 007 - WARD SEVEN 008 - WARD EIGHT 009 - WARD NINE 010 - WARD TEN 011 - WARD ELEVEN 012 - WARD TWELVE 013 - WARD THIRTEEN 014 - WARD FOURTEEN 015 - WARD FIFTEEN 016 - WARD SIXTEEN 017 - WARD SEVENTEEN ##Central Absentee ##Central Absentee 101 - SOUTH CLINTWOOD 201 - NORA 202 - FRYING PAN 203 - CLINCHCO 301 - WEST DANTE 302 - HERALD 303 - RIDGE 401 - HAYSI-COLLEY 501 - TARPON 502 - NORTH CLINTWOOD ##Central Absentee ##Central Absentee 101 - WHITE OAK 102 - ROCKY RUN 103 - CHURCH ROAD 201 - ROHOIC 202 - SUTHERLAND 301 - REAMS

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Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 13 of 67 Pageid#: 188

2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary

DINWIDDIE COUNTY DINWIDDIE COUNTY DINWIDDIE COUNTY DINWIDDIE COUNTY DINWIDDIE COUNTY DINWIDDIE COUNTY DINWIDDIE COUNTY EMPORIA CITY EMPORIA CITY EMPORIA CITY EMPORIA CITY EMPORIA CITY EMPORIA CITY EMPORIA CITY EMPORIA CITY EMPORIA CITY ESSEX COUNTY ESSEX COUNTY ESSEX COUNTY ESSEX COUNTY ESSEX COUNTY ESSEX COUNTY FAIRFAX CITY FAIRFAX CITY FAIRFAX CITY FAIRFAX CITY FAIRFAX CITY FAIRFAX CITY FAIRFAX CITY FAIRFAX CITY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY

302 - NEW HOPE 303 - LITTLE ZION 401 - DINWIDDIE 402 - MCKENNEY 403 - CHERRY HILL 501 - EDGEHILL 502 - CHESDIN ##Central Absentee ##Central Absentee 101 - PRECINCT 1-1 201 - PRECINCT 2-1 301 - PRECINCT 3-1 401 - PRECINCT 4-1 501 - PRECINCT 5-1 601 - DISTRICT 6 701 - DISTRICT 7 ##Central Absentee ##Central Absentee 101 - GREATER TAPPAHANNOCK 201 - NORTH 301 - SOUTH 401 - CENTRAL ##Central Absentee ##Central Absentee 001 - ONE 002 - TWO 003 - THREE 004 - FOUR 005 - FIVE 006 - SIX ##Central Absentee ##Central Absentee ##Central Absentee ##Central Absentee 104 - CHAPEL 105 - FAIRVIEW 106 - HERITAGE 108 - KINGS PARK 109 - LITTLE RUN 110 - NORTH SPRINGFIELD 113 - CANTERBURY 114 - OLDE CREEK 115 - RAVENSWORTH 116 - WAKEFIELD 117 - WOODSON 118 - LAKE BRADDOCK 119 - LAUREL 120 - SIDEBURN 121 - VILLA 123 - ROBINSON 125 - SIGNAL HILL 126 - BONNIE BRAE 127 - BURKE CENTRE 128 - CARDINAL 129 - KEENE MILL 130 - TERRA CENTRE 131 - EAGLE VIEW 132 - MONUMENT 133 - DANBURY 134 - UNIVERSITY 201 - Armstrong 202 - FLINT HILL 203 - FLORIS 204 - MADISON 208 - RESTON #1 209 - RESTON #2 213 - VIENNA #1 214 - VIENNA #2 216 - VIENNA #4 218 - VIENNA #6 219 - WESTBRIAR 220 - DOGWOOD 221 - HUNTERS WOODS 222 - RESTON #3 223 - GLADE 224 - SOUTH LAKES 225 - HUGHES 226 - WOLFTRAP 227 - SUNRISE VALLEY 229 - FOX MILL 233 - NORTH POINT 234 - ALDRIN 235 - FRYING PAN 236 - STUART 237 - MCNAIR 238 - CAMERON GLEN 240 - COLVIN 301 - CHAIN BRIDGE 302 - CHESTERBROOK 303 - CHURCHILL 304 - COOPER 305 - EL NIDO 306 - GREAT FALLS 307 - HAYCOCK 309 - KENMORE 310 - KIRBY 311 - LANGLEY 312 - LONGFELLOW 314 - MCLEAN 315 - PIMMIT 316 - SALONA #1 317 - WESTHAMPTON 318 - WESTMORELAND 319 - HERNDON #1 320 - HERNDON #2 321 - CLEARVIEW 322 - FORESTVILLE

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2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary

FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY

323 - SHOUSE 324 - HERNDON #3 325 - HUTCHISON 327 - SUGARLAND 328 - HICKORY 329 - SENECA 331 - SPRING HILL 332 - COATES 333 - SALONA #2 401 - BUSH HILL 402 - CAMERON 403 - FORESTDALE 404 - FRANCONIA 405 - GROVETON 406 - HAYFIELD 408 - MOUNT EAGLE 409 - PIONEER 410 - ROSE HILL 411 - VIRGINIA HILLS 413 - FAIRFIELD 415 - CRESTWOOD 417 - GARFIELD 418 - LYNBROOK 419 - LANE 420 - VILLAGES 421 - KINGSTOWNE 422 - VAN DORN 423 - CLERMONT 424 - HUNTLEY 426 - GREENSPRING 427 - ISLAND CREEK 428 - PINEWOOD 429 - HYBLA VALLEY 501 - BAILEYS 502 - BARCROFT 503 - BELVEDERE 504 - BRISTOW 505 - GLEN FOREST 506 - HOLMES #1 507 - LINCOLNIA 508 - MASONVILLE 509 - PLAZA 510 - PARKLAWN 511 - RAVENWOOD 512 - SLEEPY HOLLOW 513 - SAINT ALBANS 513 - SAINT ALBANS 514 - CROSSROADS 515 - WESTLAWN 516 - WEYANOKE 517 - WILLSTON 518 - COLUMBIA 519 - HUMMER 520 - SKYLINE 521 - BROOK HILL 522 - CAMELOT 523 - POE 525 - WALNUT HILL 526 - BREN MAR 527 - EDSALL 528 - RIDGELEA 530 - HOLMES #2 601 - BELLE HAVEN 602 - BELLEVIEW 604 - BUCKNELL 605 - FORT HUNT 606 - HOLLIN HALL 607 - HUNTINGTON 608 - KIRKSIDE 609 - MARLAN 610 - SHERWOOD 611 - STRATFORD 612 - WAYNEWOOD 613 - WESTGATE 614 - RIVERSIDE 615 - WOODLEY 616 - GUNSTON 617 - LORTON 618 - NEWINGTON 619 - BELVOIR 621 - GROSVENOR 622 - LORTON STATION 623 - ALBAN 626 - SARATOGA 627 - WOODLAWN 628 - LAUREL HILL 629 - SOUTH COUNTY 630- ARMY 701 - BLAKE 703 - FORT BUFFALO 704 - FREEDOM HILL 705 - GRAHAM - GREENWAY 707 - MANTUA 708 - MARSHALL 709 - MOSBY 710 - PINE SPRING 711 - PRICE 712 - SHREVE 713 - TIMBER LANE 714 - WALKER 717 - WOODBURN 718 - PINE RIDGE 720 - THOREAU 721 - MERRIFIELD 723 - GALLOWS EAST 726 - MAGARITY 727 - OAKTON

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Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 15 of 67 Pageid#: 190

2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary

FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FAIRFAX COUNTY FALLS CHURCH CITY FALLS CHURCH CITY FALLS CHURCH CITY FALLS CHURCH CITY FALLS CHURCH CITY FAUQUIER COUNTY FAUQUIER COUNTY FAUQUIER COUNTY FAUQUIER COUNTY FAUQUIER COUNTY FAUQUIER COUNTY FAUQUIER COUNTY FAUQUIER COUNTY FAUQUIER COUNTY FAUQUIER COUNTY FAUQUIER COUNTY FAUQUIER COUNTY FAUQUIER COUNTY FAUQUIER COUNTY FAUQUIER COUNTY FAUQUIER COUNTY FAUQUIER COUNTY FAUQUIER COUNTY FAUQUIER COUNTY FAUQUIER COUNTY FAUQUIER COUNTY FAUQUIER COUNTY FAUQUIER COUNTY FLOYD COUNTY FLOYD COUNTY FLOYD COUNTY FLOYD COUNTY FLOYD COUNTY FLOYD COUNTY FLOYD COUNTY FLUVANNA COUNTY FLUVANNA COUNTY FLUVANNA COUNTY FLUVANNA COUNTY FLUVANNA COUNTY FLUVANNA COUNTY FLUVANNA COUNTY FRANKLIN CITY

729 - NOTTOWAY 730 - PENDERBROOK 731 - TYSONS 732 - OAK MARR 733 - KILMER 734 - HUNTERS BRANCH 735 - ROTONDA 801 - BURKE 802 - CEDAR LAKE 803 - CLIFTON 804 - COLCHESTER 805 - FAIRFAX STATION 806 - SYDENSTRICKER 807 - HUNT VALLEY 811 - POHICK 812 - VALLEY 815 - WOODYARD 824 - ORANGE 825 - CHERRY RUN 827 - IRVING 833 - WHITE OAKS 838 - SANGSTER 839 - SILVERBROOK 840 - WEST SPRINGFIELD 841 - POPES HEAD 842 - PARKWAY 843 - FAIR LAKES 844 - CENTERPOINTE 845 - FOUNTAINHEAD 846 - GREENBRIAR EAST 847 - GREENBRIAR WEST 848 - FAIR OAKS 849 - NEWGATE 850 - SOUTH RUN 851 - WILLOW SPRINGS 901 - CENTRE RIDGE 902 - BROOKFIELD 903 - CUB RUN 904 - STONECROFT 905 - FRANKLIN 908 - HIDDEN MEADOW 909 - OAK HILL 910 - LONDON TOWNE 911 - NAVY 913 - ROCKY RUN 914 - VALE 915 - VIRGINIA RUN 916 - WAPLES MILL 917 - STONE NORTH 918 - CENTREVILLE 919 - GREEN TRAILS 920 - CHANTILLY 921 - DEER PARK 923 - BULL RUN 924 - SPINDLE 925 - OLD MILL 926 - POWELL 927 - ARMFIELD 928 - POPLAR TREE 929 - DIFFICULT RUN 930 - LEES CORNER 931 - CARSON 932 - STONE SOUTH 933 - COMPTON ##Central Absentee ##Central Absentee 001 - FIRST WARD 002 - SECOND WARD 003 - THIRD WARD ##Central Absentee ##Central Absentee ##Central Absentee 101 - KETTLE RUN 102 - CATLETT 103 - CASANOVA 104 - LOIS 105 - OPAL 106 - BALDWIN RIDGE 201 - COURTHOUSE 202 - AIRLIE 203 - WARRENTON 301 - MORRISVILLE 302 - REMINGTON 303 - BEALETON 401 - MARSHALL 402 - LEEDS 403 - WATERLOO 404 - SPRINGS VALLEY 501 - THE PLAINS 502 - NEW BALTIMORE 503 - BROAD RUN 504 - VINT HILL ##Central Absentee ##Central Absentee 101 - LOCUST GROVE 201 - LITTLE RIVER 301 - COURTHOUSE 401 - BURKS FORK 501 - INDIAN VALLEY ##Central Absentee ##Central Absentee 101 - PALMYRA 201 - COLUMBIA 301 - FORK UNION 401 - CUNNINGHAM 501 - RIVANNA ##Central Absentee

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Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 16 of 67 Pageid#: 191

2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary

FRANKLIN CITY FRANKLIN CITY FRANKLIN CITY FRANKLIN CITY FRANKLIN CITY FRANKLIN CITY FRANKLIN CITY FRANKLIN COUNTY FRANKLIN COUNTY FRANKLIN COUNTY FRANKLIN COUNTY FRANKLIN COUNTY FRANKLIN COUNTY FRANKLIN COUNTY FRANKLIN COUNTY FRANKLIN COUNTY FRANKLIN COUNTY FRANKLIN COUNTY FRANKLIN COUNTY FRANKLIN COUNTY FRANKLIN COUNTY FRANKLIN COUNTY FRANKLIN COUNTY FRANKLIN COUNTY FRANKLIN COUNTY FRANKLIN COUNTY FRANKLIN COUNTY FRANKLIN COUNTY FRANKLIN COUNTY FRANKLIN COUNTY FRANKLIN COUNTY FRANKLIN COUNTY FREDERICK COUNTY FREDERICK COUNTY FREDERICK COUNTY FREDERICK COUNTY FREDERICK COUNTY FREDERICK COUNTY FREDERICK COUNTY FREDERICK COUNTY FREDERICK COUNTY FREDERICK COUNTY FREDERICK COUNTY FREDERICK COUNTY FREDERICK COUNTY FREDERICK COUNTY FREDERICK COUNTY FREDERICK COUNTY FREDERICK COUNTY FREDERICK COUNTY FREDERICK COUNTY FREDERICK COUNTY FREDERICK COUNTY FREDERICK COUNTY FREDERICK COUNTY FREDERICKSBURG CITY FREDERICKSBURG CITY FREDERICKSBURG CITY FREDERICKSBURG CITY FREDERICKSBURG CITY FREDERICKSBURG CITY FREDERICKSBURG CITY GALAX CITY GALAX CITY GALAX CITY GALAX CITY GALAX CITY GILES COUNTY GILES COUNTY GILES COUNTY GILES COUNTY GILES COUNTY GILES COUNTY GILES COUNTY GILES COUNTY GILES COUNTY GILES COUNTY GILES COUNTY GLOUCESTER COUNTY GLOUCESTER COUNTY GLOUCESTER COUNTY GLOUCESTER COUNTY GLOUCESTER COUNTY GLOUCESTER COUNTY GLOUCESTER COUNTY GLOUCESTER COUNTY GLOUCESTER COUNTY GLOUCESTER COUNTY GLOUCESTER COUNTY GLOUCESTER COUNTY GLOUCESTER COUNTY GOOCHLAND COUNTY GOOCHLAND COUNTY GOOCHLAND COUNTY GOOCHLAND COUNTY GOOCHLAND COUNTY GOOCHLAND COUNTY GOOCHLAND COUNTY GOOCHLAND COUNTY GOOCHLAND COUNTY GOOCHLAND COUNTY GOOCHLAND COUNTY GOOCHLAND COUNTY GRAYSON COUNTY GRAYSON COUNTY GRAYSON COUNTY GRAYSON COUNTY

##Central Absentee 101 - PRECINCT 1-1 201 - PRECINCT 2-1 301 - PRECINCT 3-1 401 - PRECINCT 4-1 501 - PRECINCT 5-1 601 - PRECINCT 6-1 ##Central Absentee ##Central Absentee 102 - BURNT CHIMNEY 103 - SCRUGGS 201 - GLADE HILL 202 - PENHOOK 203 - HODGESVILLE 204 - DUDLEY 301 - SNOW CREEK 302 - FORK MOUNTAIN 303 - SONTAG 304 - DICKINSON 401 - HENRY 402 - FERRUM 403 - ENDICOTT 501 - WAIDSBORO 502 - CALLAWAY 503 - BOWMANS 504 - GOGGINSVILLE 601 - BOONES MILL 602 - BONBROOK 603 - COOPERS COVE 701 - ROCKY MOUNT EAST 702 - ROCKY MOUNT WEST 703 - ROCKY MOUNT SOUTH ##Central Absentee ##Central Absentee 101 - RUSSELLS 102 - GORE 103 - KERNSTOWN 104 - CEDAR CREEK 201 - GAINESBOROUGH 202 - ALBIN 203 - REDLAND 204 - NAIN 301 - CLEAR BROOK 302 - NEFF'S TOWN 303 - WHITE HALL 401 - CARPERS VALLEY 402 - SHENANDOAH 403 - PARKIN'S MILL 404 - ARMEL 501 - STEPHENS CITY 502 - NEWTOWN 503 - CANTERBURG 601 - MILLBROOK 602 - ASH HOLLOW 603 - GREENWOOD ##Central Absentee ##Central Absentee 101 - PRECINCT 1 - DISTRICT ONE 201 - PRECINCT 1 - DISTRICT TWO 301 - PRECINCT 1 - DISTRICT THREE 401 - PRECINCT 1 - DISTRICT FOUR 402 - PRECINCT 2 - DISTRICT FOUR ##Central Absentee ##Central Absentee 001 - EAST 002 - NORTH 003 - SOUTH ##Central Absentee ##Central Absentee 101 - GLEN LYN 102 - RICH CREEK 103 - NARROWS 201 - PEARISBURG 202 - STAFFORDSVILLE 203 - WHITE GATE 301 - EGGLESTON 302 - PEMBROKE 303 - NEWPORT ##Central Absentee ##Central Absentee 101 - HARCUM 102 - SALEM 103 - PEASLEY 201 - COURTHOUSE 202 - BOTETOURT 301 - WHITE MARSH 302 - ROANES 401 - HAYES 402 - SARAHS CREEK 501 - ACHILLES 502 - WALKER ##Central Absentee ##Central Absentee 101 - FIFE 102 - HADENSVILLE 201 - THREE SQUARE 202 - SANDY HOOK 301 - GOOCHLAND COURT HOUSE 1 302 - GOOCHLAND COURT HOUSE 2 401 - SHALLOW WELL 402 - CENTERVILLE 501 - MANAKIN 502 - BLAIR ROAD ##Central Absentee ##Central Absentee 101 - BRIDLE CREEK 102 - FLATRIDGE

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Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 17 of 67 Pageid#: 192

2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary

GRAYSON COUNTY GRAYSON COUNTY GRAYSON COUNTY GRAYSON COUNTY GRAYSON COUNTY GRAYSON COUNTY GRAYSON COUNTY GRAYSON COUNTY GRAYSON COUNTY GRAYSON COUNTY GRAYSON COUNTY GRAYSON COUNTY GRAYSON COUNTY GREENE COUNTY GREENE COUNTY GREENE COUNTY GREENE COUNTY GREENE COUNTY GREENE COUNTY GREENE COUNTY GREENSVILLE COUNTY GREENSVILLE COUNTY GREENSVILLE COUNTY GREENSVILLE COUNTY GREENSVILLE COUNTY GREENSVILLE COUNTY GREENSVILLE COUNTY GREENSVILLE COUNTY GREENSVILLE COUNTY HALIFAX COUNTY HALIFAX COUNTY HALIFAX COUNTY HALIFAX COUNTY HALIFAX COUNTY HALIFAX COUNTY HALIFAX COUNTY HALIFAX COUNTY HALIFAX COUNTY HALIFAX COUNTY HALIFAX COUNTY HALIFAX COUNTY HALIFAX COUNTY HALIFAX COUNTY HALIFAX COUNTY HALIFAX COUNTY HALIFAX COUNTY HALIFAX COUNTY HALIFAX COUNTY HALIFAX COUNTY HALIFAX COUNTY HALIFAX COUNTY HAMPTON CITY HAMPTON CITY HAMPTON CITY HAMPTON CITY HAMPTON CITY HAMPTON CITY HAMPTON CITY HAMPTON CITY HAMPTON CITY HAMPTON CITY HAMPTON CITY HAMPTON CITY HAMPTON CITY HAMPTON CITY HAMPTON CITY HAMPTON CITY HAMPTON CITY HAMPTON CITY HAMPTON CITY HAMPTON CITY HAMPTON CITY HAMPTON CITY HAMPTON CITY HAMPTON CITY HAMPTON CITY HAMPTON CITY HAMPTON CITY HAMPTON CITY HAMPTON CITY HAMPTON CITY HAMPTON CITY HAMPTON CITY HAMPTON CITY HAMPTON CITY HANOVER COUNTY HANOVER COUNTY HANOVER COUNTY HANOVER COUNTY HANOVER COUNTY HANOVER COUNTY HANOVER COUNTY HANOVER COUNTY HANOVER COUNTY HANOVER COUNTY HANOVER COUNTY HANOVER COUNTY HANOVER COUNTY HANOVER COUNTY HANOVER COUNTY HANOVER COUNTY HANOVER COUNTY HANOVER COUNTY HANOVER COUNTY HANOVER COUNTY HANOVER COUNTY HANOVER COUNTY

103 - GRANT 104 - MOUTH OF WILSON 105 - MOUNT ROGERS 106 - RUGBY 107 - TROUTDALE 108 - COMERS ROCK 202 - ELK CREEK 203 - INDEPENDENCE 301 - BAYWOOD 302 - FAIRVIEW 401 - FRIES 402 - PROVIDENCE 403 - OLDTOWN ##Central Absentee ##Central Absentee 101 - DYKE 102 - SWIFT RUN 201 - RUCKERSVILLE 301 - STANARDSVILLE 401 - MIDWAY 101 - PRECINCT 1-A 102 - PRECINCT 1-B 103 - PRECINCT 1-C 201 - PRECINCT 2-A 202 - PRECINCT 2-B 302 - PRECINCT 3-A 401 - PRECINCT 4-A 402 - PRECINCT 4-B 403 - PRECINCT 4-C ##Central Absentee ##Central Absentee 101 - CHILDREY 102 - LIBERTY 103 - REPUBLICAN GROVE 201 - CLAYS MILL 202 - CROSSROADS 203 - CLOVER 302 - MEADVILLE 304 - VERNON HILL 305 - SINAI 401 - COURTHOUSE 403 - CENTER 502 - DAN RIVER 503 - SCOTTSBURG 601 - BLACK WALNUT 603 - MT CARMEL 605 - UNION 701 - HYCO 702 - MIDWAY 703 - VIRGILINA 801 - SOUTH BOSTON ##Central Absentee ##Central Absentee ##Central Absentee 101 - ABERDEEN 102 - BASSETTE 103 - CITY HALL 104 - COOPER 105 - EAST HAMPTON 106 - ARMSTRONG 107 - LINDSAY 108 - THOMAS 109 - PHENIX 110 - PHOEBUS 111 - HAMPTON LIBRARY 112 - SMITH 115 - WYTHE 116 - JONES 117 - KECOUGHTAN 118 - MALLORY 201 - BOOKER 202 - BRYAN 203 - BURBANK 204 - FORREST 205 - ASBURY 208 - KRAFT 209 - LANGLEY 210 - MACHEN 212 - BETHEL 213 - PHILLIPS 214 - TUCKER CAPPS 215 - TYLER 215 - TYLER 216 - SANDY BOTTOM 217 - SYMS ##Central Absentee ##Central Absentee 101 - ASHLAND 104 - SLIDING HILL 105 - BERKLEY 106 - KERSEY CREEK 107 - CHICKAHOMINY 201 - BEAVERDAM 202 - BLUNTS 203 - WILMINGTON PARISH 206 - COURTHOUSE 208 - OAK KNOLL 209 - WEST HANOVER 210 - OAK HILL 301 - CLAY 303 - SHADY GROVE 304 - ATLEE 305 - COOL SPRING 401 - BATTLEFIELD 403 - COLD HARBOR 404 - BLACK CREEK 405 - PEBBLE CREEK

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2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary

HANOVER COUNTY HANOVER COUNTY HANOVER COUNTY HANOVER COUNTY HANOVER COUNTY HANOVER COUNTY HANOVER COUNTY HANOVER COUNTY HANOVER COUNTY HANOVER COUNTY HANOVER COUNTY HANOVER COUNTY HANOVER COUNTY HANOVER COUNTY HANOVER COUNTY HANOVER COUNTY HARRISONBURG CITY HARRISONBURG CITY HARRISONBURG CITY HARRISONBURG CITY HARRISONBURG CITY HARRISONBURG CITY HARRISONBURG CITY HARRISONBURG CITY HARRISONBURG CITY HARRISONBURG CITY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY

406 - BEAVERDAM CREEK 502 - RURAL POINT 503 - NEWMAN 504 - STUDLEY 505 - TOTOPOTOMOY 506 - GEORGETOWN 507 - LAUREL MEADOW 601 - VILLAGE 602 - LEE DAVIS 603 - MECHANICSVILLE 604 - HANOVER GROVE 701 - FARRINGTON 702 - MONTPELIER 703 - ROCKVILLE 704 - ELMONT 705 - SOUTH ANNA ##Central Absentee ##Central Absentee 101 - NORTHEAST 102 - EAST CENTRAL 103 - SOUTHEAST 104 - EAST 105 - South East Central 201 - NORTHWEST 202 - SOUTHWEST 203 - WEST ##Central Absentee ##Central Absentee ##Central Absentee 101 - COALPIT 102 - DUMBARTON 103 - GLEN ALLEN 105 - GREENDALE 106 - HERMITAGE 108 - HUNGARY CREEK 109 - HUNTON 110 - JOHNSON 111 - LAKESIDE 112 - LONGAN 113 - MAUDE TREVVETT 114 - MONUMENT HILLS 115 - STAPLES MILL 117 - WESTWOOD 201 - ADAMS 202 - AZALEA 203 - BELMONT 204 - BROOKLAND 205 - CANTERBURY 206 - CENTRAL GARDENS 207 - CHAMBERLAYNE 208 - FAIRFIELD 209 - GLEN LEA 210 - GREENWOOD 211 - HIGHLAND GARDENS 212 - HOLLYBROOK 213 - HUNGARY 214 - LONGDALE 215 - MAPLEWOOD 216 - MOODY 217 - MOUNTAIN 218 - OAKVIEW 219 - RANDOLPH 220 - RATCLIFFE 221 - STRATFORD HALL 222 - WILDER 223 - YELLOW TAVERN 224 - ESSEX VILLAGE 301 - CAUSEWAY 302 - CEDARFIELD 303 - INNSBROOK 304 - JACKSON DAVIS 305 - NUCKOLS FARM 306 - POCAHONTAS 307 - RIDGE 308 - RIVERS EDGE 309 - SADLER 310 - SHADY GROVE 311 - SHORT PUMP 312 - SPRINGFIELD 313 - STONEY RUN 314 - THREE CHOPT 315 - TUCKER 401 - QUIOCCASIN 402 - CRESTVIEW 403 - DERBYSHIRE 404 - FREEMAN 405 - GAYTON 406 - GODWIN 407 - LAKEWOOD 408 - LAUDERDALE 409 - MAYBEURY 410 - MOORELAND 411 - PEMBERTON 412 - PINCHBECK 413 - RIDGEFIELD 414 - ROLLINGWOOD 415 - SKIPWITH 416 - SPOTTSWOOD 417 - TUCKAHOE 418 - WELBORNE 419 - WEST END 501 - ANTIOCH 502 - CEDAR FORK 503 - CHICKAHOMINY 504 - DONAHOE 505 - DOREY 506 - EANES

0

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45

Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 19 of 67 Pageid#: 194

2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary

HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRICO COUNTY HENRY COUNTY HENRY COUNTY HENRY COUNTY HENRY COUNTY HENRY COUNTY HENRY COUNTY HENRY COUNTY HENRY COUNTY HENRY COUNTY HENRY COUNTY HENRY COUNTY HENRY COUNTY HENRY COUNTY HENRY COUNTY HENRY COUNTY HENRY COUNTY HENRY COUNTY HENRY COUNTY HENRY COUNTY HENRY COUNTY HENRY COUNTY HENRY COUNTY HENRY COUNTY HENRY COUNTY HENRY COUNTY HENRY COUNTY HENRY COUNTY HENRY COUNTY HENRY COUNTY HIGHLAND COUNTY HIGHLAND COUNTY HIGHLAND COUNTY HIGHLAND COUNTY HIGHLAND COUNTY HIGHLAND COUNTY HOPEWELL CITY HOPEWELL CITY HOPEWELL CITY HOPEWELL CITY HOPEWELL CITY HOPEWELL CITY HOPEWELL CITY HOPEWELL CITY HOPEWELL CITY ISLE OF WIGHT COUNTY ISLE OF WIGHT COUNTY ISLE OF WIGHT COUNTY ISLE OF WIGHT COUNTY ISLE OF WIGHT COUNTY ISLE OF WIGHT COUNTY ISLE OF WIGHT COUNTY ISLE OF WIGHT COUNTY ISLE OF WIGHT COUNTY ISLE OF WIGHT COUNTY ISLE OF WIGHT COUNTY ISLE OF WIGHT COUNTY ISLE OF WIGHT COUNTY ISLE OF WIGHT COUNTY ISLE OF WIGHT COUNTY ISLE OF WIGHT COUNTY JAMES CITY COUNTY JAMES CITY COUNTY JAMES CITY COUNTY JAMES CITY COUNTY JAMES CITY COUNTY JAMES CITY COUNTY JAMES CITY COUNTY JAMES CITY COUNTY JAMES CITY COUNTY JAMES CITY COUNTY JAMES CITY COUNTY JAMES CITY COUNTY JAMES CITY COUNTY JAMES CITY COUNTY JAMES CITY COUNTY JAMES CITY COUNTY JAMES CITY COUNTY JAMES CITY COUNTY JAMES CITY COUNTY JAMES CITY COUNTY JAMES CITY COUNTY JAMES CITY COUNTY JAMES CITY COUNTY JAMES CITY COUNTY KING & QUEEN COUNTY KING & QUEEN COUNTY KING & QUEEN COUNTY KING & QUEEN COUNTY KING & QUEEN COUNTY KING & QUEEN COUNTY KING & QUEEN COUNTY KING GEORGE COUNTY KING GEORGE COUNTY KING GEORGE COUNTY KING GEORGE COUNTY

507 - ELKO 508 - HIGHLAND SPRINGS 509 - LABURNUM 510 - MEHFOUD 511 - MONTROSE 512 - NINE MILE 513 - PLEASANTS 514 - ROLFE 515 - SANDSTON 516 - SULLIVANS 517 - TOWN HALL 518 - WHITLOCKS ##Central Absentee ##Central Absentee ##Central Absentee 101 - BASSETT NUMBER TWO 102 - GUNVILLE 103 - SCOTT'S TANYARD 201 - FIELDALE 202 - HORSEPASTURE #1 203 - HORSEPASTURE #2 204 - SPENCER 302 - AXTON 303 - IRISBURG 304 - MOUNT OLIVET 304 - MOUNT OLIVET 305 - MOUNTAIN VALLEY 401 - COLLINSVILLE NUMBER 1 402 - DANIELS CREEK 404 - COLLINSVILLE NUMBER 2 405 - MOUNTAIN VIEW 501 - BASSETT NUMBER ONE 502 - FIGSBORO 503 - STANLEYTOWN 504 - OAK LEVEL 505 - DYERS STORE 505 - DYERS STORE 601 - FONTAINE 602 - HILLCREST 603 - RIDGEWAY #1 604 - RIDGEWAY #2 001 - MONTEREY 003 - WILSONS MILL 005 - BLUE GRASS 007 - MILL GAP 008 - MCDOWELL 010 - HEADWATERS ##Central Absentee ##Central Absentee 101 - WARD ONE 201 - WARD TWO 301 - WARD THREE 401 - WARD FOUR 501 - WARD FIVE 601 - WARD SIX 701 - WARD SEVEN ##Central Absentee ##Central Absentee 101 - SMITHFIELD 102 - CYPRESS CREEK 201 - BARTLETT 202 - CARROLLTON 301 - RUSHMERE 302 - PONS 401 - COURTHOUSE 402 - WINDSOR 403 - LONGVIEW 501 - WALTERS 502 - CAMPS MILL 503 - CARRSVILLE 504 - ZUNI 505 - RAYNOR ##Central Absentee ##Central Absentee ##Central Absentee 101 - BERKELEY A 102 - BERKELEY B 103 - BERKELEY C 104- BERKELEY D 201 - JAMESTOWN A 202 - JAMESTOWN B 202 - JAMESTOWN B 203 - JAMESTOWN C 204 - JAMESTOWN D 301 - POWHATAN A 302 - POWHATAN B 303 - POWHATAN C 304 - POWHATAN D 401 - STONEHOUSE A 402 - STONEHOUSE B 403 - STONEHOUSE C 501 - ROBERTS A 502 - ROBERTS B 503 - ROBERTS C 504 - ROBERTS D 504 - ROBERTS D ##Central Absentee ##Central Absentee 101 - OWENTON 201 - CLARKS 301 - SHACKLEFORDS 401 - COURTHOUSE 501 - OLDMILL ##Central Absentee ##Central Absentee 101 - COURTHOUSE 102 - PASSAPATANZY

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Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 20 of 67 Pageid#: 195

2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary

KING GEORGE COUNTY KING GEORGE COUNTY KING GEORGE COUNTY KING WILLIAM COUNTY KING WILLIAM COUNTY KING WILLIAM COUNTY KING WILLIAM COUNTY KING WILLIAM COUNTY KING WILLIAM COUNTY KING WILLIAM COUNTY KING WILLIAM COUNTY LANCASTER COUNTY LANCASTER COUNTY LANCASTER COUNTY LANCASTER COUNTY LANCASTER COUNTY LANCASTER COUNTY LANCASTER COUNTY LANCASTER COUNTY LEE COUNTY LEE COUNTY LEE COUNTY LEE COUNTY LEE COUNTY LEE COUNTY LEE COUNTY LEE COUNTY LEE COUNTY LEE COUNTY LEE COUNTY LEE COUNTY LEE COUNTY LEE COUNTY LEE COUNTY LEE COUNTY LEE COUNTY LEE COUNTY LEXINGTON CITY LEXINGTON CITY LEXINGTON CITY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY

201 - MONROE 301 - DAHLGREN 401 - SHILOH ##Central Absentee ##Central Absentee 101 - WEST POINT 201 - SWEET HALL 202 - COURTHOUSE 301 - AYLETT 401 - MANQUIN 501 - MANGOHICK ##Central Absentee ##Central Absentee 101 - PRECINCT 1-1 201 - PRECINCT 2-1 301 - PRECINCT 3-1 302 - PRECINCT 3-2 401 - PRECINCT 4-1 501 - PRECINCT 5-1 ##Central Absentee ##Central Absentee 101 - ELYDALE 102 - EWING 103 - ROSE HILL 201 - BLACKWATER 202 - FLATWOODS 203 - JONESVILLE 301 - BEN HUR 302 - WOODWAY 401 - STICKLEYVILLE 402 - JASPER 403 - SEMINARY 404 - DRYDEN 501 - SAINT CHARLES 502 - PENNINGTON 503 - ROBBINS CHAPEL 504 - KEOKEE ##Central Absentee ##Central Absentee 001 - LEXINGTON ##Central Absentee ##Central Absentee 107 - LITTLE RIVER 108 - MERCER 112 - FREEDOM 114 - DULLES SOUTH 117 - CARTER 118 - MOOREFIELD 119 - ARCOLA 120 - LUNSFORD 121 - TOWN HALL 122 - HUTCHISON FARM 123 - CARDINAL RIDGE 124 - LIBERTY 125 - ROCK RIDGE 207 - RIVER BEND 208 - ALGONKIAN 209 - POTOMAC FALLS 210 - CASCADES 213 - COUNTRYSIDE 214 - SUGARLAND NORTH 215 - SUGARLAND SOUTH 216 - LOWES ISLAND 217 - SOUTH BANK 218 - UNIVERSITY CENTER 219 - GALILEE CHURCH 301 - PURCELLVILLE 302 - ROUND HILL 303 - HILLSBORO 305 - PHILOMONT 307 - MIDDLEBURG 308 - ST LOUIS 309 - ALDIE 310 - MOUNTAIN VIEW 311 - ROUND HILL ELEMENTARY 312 - BRIAR WOODS 313 - PINEBROOK 314 - LEGACY 315 - FIREHOUSE 316 - CREIGHTON'S CORNER 318 - MADISON'S TRUST 319 - JOHN CHAMPE 320 - STONE HILL 321 - BRAMBLETON MIDDLE 401 - WEST LOVETTSVILLE 402 - WATERFORD 403 - LUCKETTS 407 - HARPER PARK 408 - EVERGREEN 409 - CLARKES GAP 411 - EAST LOVETTSVILLE 413 - TUSCARORA 414 - RED ROCK 416 - HAMILTON 420 - RIVER CREEK 421 - BETWEEN THE HILLS 422 - SYCOLIN CREEK 501 - WEST LEESBURG 502 - EAST LEESBURG 503 - DRY MILL 504 - SMARTS MILL 505 - COOL SPRING 506 - BRANDON PARK 507 - GREENWAY 508 - BALLS BLUFF 509 - TOLBERT 510 - HERITAGE

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2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary

LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUDOUN COUNTY LOUISA COUNTY LOUISA COUNTY LOUISA COUNTY LOUISA COUNTY LOUISA COUNTY LOUISA COUNTY LOUISA COUNTY LOUISA COUNTY LOUISA COUNTY LOUISA COUNTY LOUISA COUNTY LOUISA COUNTY LOUISA COUNTY LOUISA COUNTY LOUISA COUNTY LOUISA COUNTY LOUISA COUNTY LUNENBURG COUNTY LUNENBURG COUNTY LUNENBURG COUNTY LUNENBURG COUNTY LUNENBURG COUNTY LUNENBURG COUNTY LUNENBURG COUNTY LUNENBURG COUNTY LUNENBURG COUNTY LUNENBURG COUNTY LUNENBURG COUNTY LUNENBURG COUNTY LUNENBURG COUNTY LYNCHBURG CITY LYNCHBURG CITY LYNCHBURG CITY LYNCHBURG CITY LYNCHBURG CITY LYNCHBURG CITY LYNCHBURG CITY LYNCHBURG CITY LYNCHBURG CITY LYNCHBURG CITY LYNCHBURG CITY LYNCHBURG CITY LYNCHBURG CITY LYNCHBURG CITY LYNCHBURG CITY LYNCHBURG CITY LYNCHBURG CITY LYNCHBURG CITY LYNCHBURG CITY LYNCHBURG CITY MADISON COUNTY MADISON COUNTY MADISON COUNTY MADISON COUNTY MADISON COUNTY MADISON COUNTY MADISON COUNTY MADISON COUNTY MADISON COUNTY MADISON COUNTY MADISON COUNTY MANASSAS CITY MANASSAS CITY MANASSAS CITY MANASSAS CITY MANASSAS CITY MANASSAS CITY MANASSAS CITY MANASSAS CITY MANASSAS PARK CITY MANASSAS PARK CITY MANASSAS PARK CITY MANASSAS PARK CITY MANASSAS PARK CITY MARTINSVILLE CITY MARTINSVILLE CITY

615 - HILLSIDE 616 - EAGLE RIDGE 617 - OAK GROVE 619 - RIDGETOP 620 - RUSSELL BRANCH 621 - DOMINION TRAIL 622 - FARMWELL STATION 623 - WELLER 625 - MILL RUN 626 - ASHBY PONDS 627 - ASHBROOK 628 - MOOREFIELD STATION 629 - DISCOVERY 701 - SULLY 702 - PARK VIEW 703 - ROLLING RIDGE 705 - FOREST GROVE 707 - CLAUDE MOORE PARK 708 - SENECA 709 - MIRROR RIDGE 710 - STERLING 808 - STONE BRIDGE 810 - CEDAR LANE 813 - SELDENS LANDING 814 - NEWTON - LEE 815 - BELMONT RIDGE 817 - SANDERS CORNER 818 - BROAD RUN 819 - HERITAGE CHURCH 820 - BELMONT STATION 822 - RIVERSIDE ##Central Absentee ##Central Absentee 101 - ZION 102 - MECHANICSVILLE 201 - LOUISA #1 202 - LOUISA #2 301 - PATRICK HENRY NO 1 302 - PATRICK HENRY #2 401 - MINERAL 402 - YANCEYVILLE 501 - FREDERICKS HALL 502 - CUCKOO 503 - ELK CREEK 601 - BUMPASS 602 - LOCUST CREEK 701 - SHELTONS MILL 702 - SOUTH ANNA ##Central Absentee ##Central Absentee 101 - PLYMOUTH 201 - BROWNS STORE 301 - ROSEBUD 302 - FLAT ROCK 401 - ARROWHEAD GUN CLUB 402 - PLEASANT GROVE 501 - REEDY CREEK 502 - PEOPLES COMMUNITY CENTER 601 - HOUNDS CREEK 701 - MEHERRIN FIRE DEPARTMENT 702 - VICTORIA PUBLIC LIBRARY ##Central Absentee ##Central Absentee 101 - FIRST WARD FIRST PRECINCT 102 - FIRST WARD SECOND PRECINCT 103 - FIRST WARD THIRD PRECINCT 104 - FIRST WARD FOURTH PRECINCT 105 - FIRST WARD FIFTH PRECINCT 201 - SECOND WARD FIRST PRECINCT 202 - SECOND WARD SECOND PRECINCT 203 - SECOND WARD THIRD PRECINCT 204 - SECOND WARD FOURTH PRECINCT 301 - THIRD WARD FIRST PRECINCT 302 - THIRD WARD SECOND PRECINCT 303 - THIRD WARD THIRD PRECINCT 304 - THIRD WARD FOURTH PRECINCT 305 - THIRD WARD FIFTH PRECINCT 401 - FOURTH WARD FIRST PRECINCT 402 - FOURTH WARD SECOND PRECINCT 403 - FOURTH WARD THIRD PRECINCT 404 - FOURTH WARD FOURTH PRECINCT ##Central Absentee ##Central Absentee 001 - OAK PARK 002 - RADIANT 003 - ROCHELLE 004 - GRAVES MILL 005 - MADISON 006 - WOLFTOWN 007 - BRIGHTWOOD 008 - CRIGLERSVILLE 009 - ETLAN ##Central Absentee ##Central Absentee 001 - DEAN 002 - WEEMS 003 - METZ 004 - HAYDON 005 - BALDWIN 006 - ROUND ##Central Absentee ##Central Absentee 001 - PRECINCT ONE 002 - PRECINCT TWO 003 - PRECINCT THREE ##Central Absentee ##Central Absentee

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Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 22 of 67 Pageid#: 197

2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary

MARTINSVILLE CITY MARTINSVILLE CITY MARTINSVILLE CITY MARTINSVILLE CITY MARTINSVILLE CITY MARTINSVILLE CITY MATHEWS COUNTY MATHEWS COUNTY MATHEWS COUNTY MATHEWS COUNTY MATHEWS COUNTY MECKLENBURG COUNTY MECKLENBURG COUNTY MECKLENBURG COUNTY MECKLENBURG COUNTY MECKLENBURG COUNTY MECKLENBURG COUNTY MECKLENBURG COUNTY MECKLENBURG COUNTY MECKLENBURG COUNTY MECKLENBURG COUNTY MECKLENBURG COUNTY MECKLENBURG COUNTY MECKLENBURG COUNTY MECKLENBURG COUNTY MECKLENBURG COUNTY MECKLENBURG COUNTY MECKLENBURG COUNTY MECKLENBURG COUNTY MECKLENBURG COUNTY MECKLENBURG COUNTY MECKLENBURG COUNTY MECKLENBURG COUNTY MECKLENBURG COUNTY MECKLENBURG COUNTY MECKLENBURG COUNTY MIDDLESEX COUNTY MIDDLESEX COUNTY MIDDLESEX COUNTY MIDDLESEX COUNTY MIDDLESEX COUNTY MIDDLESEX COUNTY MIDDLESEX COUNTY MIDDLESEX COUNTY MONTGOMERY COUNTY MONTGOMERY COUNTY MONTGOMERY COUNTY MONTGOMERY COUNTY MONTGOMERY COUNTY MONTGOMERY COUNTY MONTGOMERY COUNTY MONTGOMERY COUNTY MONTGOMERY COUNTY MONTGOMERY COUNTY MONTGOMERY COUNTY MONTGOMERY COUNTY MONTGOMERY COUNTY MONTGOMERY COUNTY MONTGOMERY COUNTY MONTGOMERY COUNTY MONTGOMERY COUNTY MONTGOMERY COUNTY MONTGOMERY COUNTY MONTGOMERY COUNTY MONTGOMERY COUNTY MONTGOMERY COUNTY MONTGOMERY COUNTY MONTGOMERY COUNTY MONTGOMERY COUNTY MONTGOMERY COUNTY NELSON COUNTY NELSON COUNTY NELSON COUNTY NELSON COUNTY NELSON COUNTY NELSON COUNTY NELSON COUNTY NELSON COUNTY NELSON COUNTY NELSON COUNTY NELSON COUNTY NEW KENT COUNTY NEW KENT COUNTY NEW KENT COUNTY NEW KENT COUNTY NEW KENT COUNTY NEW KENT COUNTY NEW KENT COUNTY NEW KENT COUNTY NEW KENT COUNTY NEW KENT COUNTY NEW KENT COUNTY NEW KENT COUNTY NEWPORT NEWS CITY NEWPORT NEWS CITY NEWPORT NEWS CITY NEWPORT NEWS CITY NEWPORT NEWS CITY NEWPORT NEWS CITY NEWPORT NEWS CITY NEWPORT NEWS CITY NEWPORT NEWS CITY NEWPORT NEWS CITY NEWPORT NEWS CITY NEWPORT NEWS CITY NEWPORT NEWS CITY NEWPORT NEWS CITY

001 - PRECINCT #1 002 - PRECINCT #2 003 - PRECINCT #3 004 - PRECINCT #4 005 - PRECINCT #5 006 - PRECINCT #6 ##Central Absentee ##Central Absentee 001 - CHESAPEAKE 002 - WESTVILLE 003 - PIANKATANK ##Central Absentee ##Central Absentee 101 - WRIGHTS STORE 102 - PEARSONS STORE 103 - SOUTH CLARKSVILLE 201 - BOYDTON 202 - BLUESTONE SENIOR HIGH SCHOOL 203 - CHASE CITY VFW POST 301 - BRACEY 302 - LACROSSE 401 - AMERICAN LEGION HALL 402 - PARK VIEW MIDDLE SCHOOL 501 - SOUTH HILL 601 - BASKERVILLE 602 - UNION LEVEL 603 - SMITH CROSSROADS 604 - LAKE GASTON 701 - CHASE CITY 702 - SUNSHINE 801 - FINCHLEY 802 - BLUESTONE 803 - CHASE CITY ELEMENTARY SCHOOL 901 - AVERETT 902 - BUFFALO SPRINGS 903 - CLARKSVILLE ##Central Absentee ##Central Absentee 101 - SALUDA 102 - URBANNA 201 - NEW MARKET 302 - CHURCH VIEW 401- HARMONY VILLAGE 501 - WILTON ##Central Absentee ##Central Absentee 101 - PRECINCT A-1 102 - PRECINCT A-2 103 - PRECINCT A-3 201 - PRECINCT B-1 202 - PRECINCT B-2 203 - PRECINCT B-3 204 - PRECINCT B-4 301 - PRECINCT C-1 302 - PRECINCT C-2 303 - PRECINCT C-3 304 - PRECINCT C-4 401 - PRECINCT D-1 402 - PRECINCT D-2 403 - PRECINCT D-3 404 - PRECINCT D-4 405 - PRECINCT D-5 501 - PRECINCT E-1 502 - PRECINCT E-2 503 - PRECINCT E-3 601 - PRECINCT F-1 602 - PRECINCT F-2 603 - PRECINCT F-3 701 - PRECINCT G-1 702 - PRECINCT G-2 ##Central Absentee ##Central Absentee 101 - ROCKFISH 201 - LOVINGSTON 202 - SCHUYLER 301 - SHIPMAN 302 - GLADSTONE 401 - ROSELAND 402 - MONTEBELLO 501 - FABER 502 - NELLYSFORD ##Central Absentee ##Central Absentee 102 - TUNSTALL 103 - SOUTHERN BRANCH 201 - QUINTON 202 - KENTWOOD 301 - WATKINS 302 - CUMBERLAND 401 - PROVIDENCE FORGE 403 - MOUNTCASTLE 501 - ELTHAM 502 - CHICKAHOMINY RIVER ##Central Absentee ##Central Absentee 101 - DENBIGH 102 - EPES 103 - JENKINS 104 - MCINTOSH 105 - OYSTER POINT 106 - RESERVOIR 107 - RICHNECK 108 - LEE HALL 109 - WINDSOR 110 - GREENWOOD 201 - BLAND 202 - BOULEVARD

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Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 23 of 67 Pageid#: 198

2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary

NEWPORT NEWS CITY NEWPORT NEWS CITY NEWPORT NEWS CITY NEWPORT NEWS CITY NEWPORT NEWS CITY NEWPORT NEWS CITY NEWPORT NEWS CITY NEWPORT NEWS CITY NEWPORT NEWS CITY NEWPORT NEWS CITY NEWPORT NEWS CITY NEWPORT NEWS CITY NEWPORT NEWS CITY NEWPORT NEWS CITY NEWPORT NEWS CITY NEWPORT NEWS CITY NEWPORT NEWS CITY NEWPORT NEWS CITY NEWPORT NEWS CITY NEWPORT NEWS CITY NEWPORT NEWS CITY NEWPORT NEWS CITY NEWPORT NEWS CITY NEWPORT NEWS CITY NEWPORT NEWS CITY NEWPORT NEWS CITY NEWPORT NEWS CITY NEWPORT NEWS CITY NEWPORT NEWS CITY NEWPORT NEWS CITY NEWPORT NEWS CITY NEWPORT NEWS CITY NEWPORT NEWS CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORFOLK CITY NORTHAMPTON COUNTY NORTHAMPTON COUNTY NORTHAMPTON COUNTY NORTHAMPTON COUNTY NORTHAMPTON COUNTY NORTHAMPTON COUNTY NORTHAMPTON COUNTY NORTHUMBERLAND COUNTY NORTHUMBERLAND COUNTY NORTHUMBERLAND COUNTY NORTHUMBERLAND COUNTY NORTHUMBERLAND COUNTY NORTHUMBERLAND COUNTY NORTHUMBERLAND COUNTY NORTHUMBERLAND COUNTY NORTON CITY NOTTOWAY COUNTY NOTTOWAY COUNTY NOTTOWAY COUNTY NOTTOWAY COUNTY

203 - CHARLES 204 - WELLESLEY 205 - DEEP CREEK 208 - HIDENWOOD 209 - HILTON 210 - NELSON 211 - PALMER 212 - RIVERSIDE 213 - SANFORD 215 - WARWICK 216 - YATES 217 - RIVERVIEW 218 - KILN CREEK 219 - DEER PARK 302 - BRIARFIELD 303 - CARVER 304 - CHESTNUT 305 - DOWNTOWN 306 - DUNBAR 307 - HUNTINGTON 308 - JEFFERSON 309 - MAGRUDER 310 - MARSHALL 311 - NEWMARKET 312 - NEWSOME PARK 313 - REED 314 - RIVER 315 - SEDGEFIELD 316 - SOUTH MORRISON 317 - WASHINGTON 318 - WILSON 319 - SAUNDERS 320 - WATKINS ##Central Absentee ##Central Absentee ##Central Absentee 101 - GRANBY 101 - GRANBY 102 - OCEAN VIEW SCHOOL 103 - NORTHSIDE 104 - TITUSTOWN 104 - TITUSTOWN 106 - SECOND PRESBYTERIAN 201 - LARCHMONT SCHOOL 203 - GHENT SQUARE 207 - LAMBERT'S POINT 208 - LARCHMONT LIBRARY 210 - MAURY 211 - CHRYSLER MUSEUM 212 - PARK PLACE 213 - TAYLOR ELEMENTARY SCHOOL 214 - STUART 215 - SUBURBAN PARK 217 - WESLEY 218 - WILLARD 301 - BALLENTINE 302 - TANNERS CREEK 303 - BROAD CREEK 304 - COLEMAN PLACE SCHOOL 305 - LAFAYETTE-WINONA 306 - LINDENWOOD 309 - NORVIEW 310 - ROSEMONT 311 - SHERWOOD 313 - UNION CHAPEL 402 - BERKLEY 403 - BRAMBLETON 404 - CAMPOSTELLA 405 - CHESTERFIELD 406 - BARRON BLACK 408 - EASTON 409 - FAIRLAWN 411 - RUFFNER ACADEMY 412 - INGLESIDE 413 - POPLAR HALLS 414 - YOUNG PARK 415 - LAKE TAYLOR HIGH SCHOOL 501 - BAYVIEW 503 - EAST OCEAN VIEW 504 - LARRYMORE 505 - LITTLE CREEK 506 - OCEAN VIEW CENTER 507 - PRETLOW 509 - TARRALLTON 510 - THIRD PRESBYTERIAN 511 - CROSSROADS 512 - AZALEA GARDENS ##Central Absentee ##Central Absentee 101 - PRECINCT 1-1 201 - PRECINCT 2-1 301 - PRECINCT 3-1 401 - PRECINCT 4-1 501 - PRECINCT 5-1 ##Central Absentee ##Central Absentee 101 - 1A 201 - 2A 301 - 3A 302 - 3B 401 - 4A 501 - 5A 001 - EAST WARD ##Central Absentee ##Central Absentee 101 - PRECINCT 1-1 102 - PRECINCT 1-2

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50

Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 24 of 67 Pageid#: 199

2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary

NOTTOWAY COUNTY NOTTOWAY COUNTY NOTTOWAY COUNTY NOTTOWAY COUNTY NOTTOWAY COUNTY NOTTOWAY COUNTY NOTTOWAY COUNTY ORANGE COUNTY ORANGE COUNTY ORANGE COUNTY ORANGE COUNTY ORANGE COUNTY ORANGE COUNTY ORANGE COUNTY ORANGE COUNTY ORANGE COUNTY ORANGE COUNTY ORANGE COUNTY ORANGE COUNTY PAGE COUNTY PAGE COUNTY PAGE COUNTY PAGE COUNTY PAGE COUNTY PAGE COUNTY PAGE COUNTY PATRICK COUNTY PATRICK COUNTY PATRICK COUNTY PATRICK COUNTY PATRICK COUNTY PATRICK COUNTY PATRICK COUNTY PATRICK COUNTY PATRICK COUNTY PATRICK COUNTY PATRICK COUNTY PATRICK COUNTY PATRICK COUNTY PATRICK COUNTY PATRICK COUNTY PETERSBURG CITY PETERSBURG CITY PETERSBURG CITY PETERSBURG CITY PETERSBURG CITY PETERSBURG CITY PETERSBURG CITY PETERSBURG CITY PETERSBURG CITY PITTSYLVANIA COUNTY PITTSYLVANIA COUNTY PITTSYLVANIA COUNTY PITTSYLVANIA COUNTY PITTSYLVANIA COUNTY PITTSYLVANIA COUNTY PITTSYLVANIA COUNTY PITTSYLVANIA COUNTY PITTSYLVANIA COUNTY PITTSYLVANIA COUNTY PITTSYLVANIA COUNTY PITTSYLVANIA COUNTY PITTSYLVANIA COUNTY PITTSYLVANIA COUNTY PITTSYLVANIA COUNTY PITTSYLVANIA COUNTY PITTSYLVANIA COUNTY PITTSYLVANIA COUNTY PITTSYLVANIA COUNTY PITTSYLVANIA COUNTY PITTSYLVANIA COUNTY PITTSYLVANIA COUNTY PITTSYLVANIA COUNTY PITTSYLVANIA COUNTY PITTSYLVANIA COUNTY PITTSYLVANIA COUNTY PITTSYLVANIA COUNTY PITTSYLVANIA COUNTY PITTSYLVANIA COUNTY PITTSYLVANIA COUNTY PITTSYLVANIA COUNTY POQUOSON CITY POQUOSON CITY POQUOSON CITY POQUOSON CITY POQUOSON CITY PORTSMOUTH CITY PORTSMOUTH CITY PORTSMOUTH CITY PORTSMOUTH CITY PORTSMOUTH CITY PORTSMOUTH CITY PORTSMOUTH CITY PORTSMOUTH CITY PORTSMOUTH CITY PORTSMOUTH CITY PORTSMOUTH CITY PORTSMOUTH CITY PORTSMOUTH CITY PORTSMOUTH CITY PORTSMOUTH CITY PORTSMOUTH CITY PORTSMOUTH CITY PORTSMOUTH CITY PORTSMOUTH CITY PORTSMOUTH CITY PORTSMOUTH CITY

201 - PRECINCT 2-1 202 - PRECINCT 2-2 301 - PRECINCT 3-1 302 - PRECINCT 3-2 401 - PRECINCT 4-1 402 - PRECINCT 4-2 501 - PRECINCT 5-1 ##Central Absentee ##Central Absentee 101 - ONE WEST 102 - ONE EAST 201 - TWO WEST 202 - TWO EAST 301 - THREE WEST 302 - THREE EAST 401 - FOUR WEST 402 - FOUR EAST 501 - FIVE SOUTH 502 - FIVE NORTH ##Central Absentee ##Central Absentee 101 - WEST LURAY 201 - EAST LURAY 301 - MARKSVILLE 401 - NEWPORT 501 - SHENANDOAH ##Central Absentee ##Central Absentee 101 - ARARAT 102 - CLAUDVILLE 103 - WILLIS GAP 201 - DRY POND 202 - PATRICK SPRINGS 203 - RUSSELL CREEK 301 - CRITZ/STELLA 302 - LIBERTY 401 - MEADOWS OF DAN 402 - STUART FAIRGROUNDS 501 - STUART COMMUNITY 502 - ELAMSVILLE 503 - WOOLWINE ##Central Absentee ##Central Absentee 101 - FIRST WARD FIRST PRECINCT 201 - SECOND WARD FIRST PRECINCT 301 - THIRD WARD FIRST PRECINCT 401 - FOURTH WARD FIRST PRECINCT 501 - FIFTH WARD FIRST PRECINCT 601 - SIXTH WARD FIRST PRECINCT 701 - SEVENTH WARD FIRST PRECINCT ##Central Absentee ##Central Absentee 103 - TWIN SPRINGS 105 - CHATHAM 106 - TUNSTALL 108 - WEST BLAIRS 201 - CALLANDS 202- BEARSKIN 204 - SANDY LEVEL 206 - CLIMAX 207 - GRETNA 301 - CENTRAL 305 - RICEVILLE 307 - EAST BLAIRS 308 - MT AIRY 309 - EAST GRETNA 402 - KEELING 404 - KENTUCK 405 - RINGGOLD 501 - HURT 502 - MOTLEY SYCAMORE 503 - RENAN 603 - STONY MILL 604 - SWANSONVILLE 605 - WHITMELL 606 - BROSVILLE 607 - DRY FORK 702 - BACHELORS HALL 703 - FERRY ROAD 704 - MT HERMON 705 - MT CROSS ##Central Absentee ##Central Absentee 001 - CENTRAL 002 - EASTERN 003 - WESTERN ##Central Absentee ##Central Absentee 001 - EMANUEL A. M. E. CHURCH 005 - HAMPTON ROADS COMMUNITY HEALTH CENTER 007- PARK VIEW ELEMENTARY SCHOOL 009 - THIRD BAPTIST CHURCH 010 - PORT NORFOLK RECREATION CENTER 011 - MT. HERMON VILLAGE 013 - ST. MARK MISSIONARY BAPTIST CHURCH 014 - BRIGHTON ELEMENTARY SCHOOL 016 - CRADOCK MIDDLE SCHOOL 017 - VICTORY LIFE FELLOWSHIP 019 - FAIRVIEW HEIGHTS BAPTIST CHURCH 020 - NOBLE STREET BAPTIST CHURCH 021 - JOHN F. KENNEDY COMMUNITY CENTER 022 - ST. MARK DELIVERANCE CENTER 023 - WESTHAVEN BAPTIST CHURCH 024 - THE SENIOR STATION 025 - JOHN TYLER ELEMENTARY SCHOOL 026 - WILLIAM E. WATERS MIDDLE SCHOOL 027 - CAVALIER MANOR RECREATION CENTER

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2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary

PORTSMOUTH CITY PORTSMOUTH CITY PORTSMOUTH CITY PORTSMOUTH CITY PORTSMOUTH CITY PORTSMOUTH CITY PORTSMOUTH CITY PORTSMOUTH CITY PORTSMOUTH CITY PORTSMOUTH CITY PORTSMOUTH CITY PORTSMOUTH CITY POWHATAN COUNTY POWHATAN COUNTY POWHATAN COUNTY POWHATAN COUNTY POWHATAN COUNTY POWHATAN COUNTY POWHATAN COUNTY POWHATAN COUNTY POWHATAN COUNTY POWHATAN COUNTY POWHATAN COUNTY POWHATAN COUNTY POWHATAN COUNTY POWHATAN COUNTY PRINCE EDWARD COUNTY PRINCE EDWARD COUNTY PRINCE EDWARD COUNTY PRINCE EDWARD COUNTY PRINCE EDWARD COUNTY PRINCE EDWARD COUNTY PRINCE EDWARD COUNTY PRINCE EDWARD COUNTY PRINCE EDWARD COUNTY PRINCE EDWARD COUNTY PRINCE EDWARD COUNTY PRINCE EDWARD COUNTY PRINCE GEORGE COUNTY PRINCE GEORGE COUNTY PRINCE GEORGE COUNTY PRINCE GEORGE COUNTY PRINCE GEORGE COUNTY PRINCE GEORGE COUNTY PRINCE GEORGE COUNTY PRINCE GEORGE COUNTY PRINCE GEORGE COUNTY PRINCE GEORGE COUNTY PRINCE GEORGE COUNTY PRINCE GEORGE COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY

028 - LAKEVIEW ELEMENTARY SCHOOL 029 - SAINT ANDREW'S UNITED METHODIST CHURCH 030 - THE RESCUE CHURCH 031 - WEST PARK CHURCH OF CHRIST 032 - HODGES MANOR ELEMENTARY SCHOOL 033- PINECREST BAPTIST CHURCH 034- CHURCHLAND BRANCH LIBRARY 035 - CHURCHLAND ELEMENTARY SCHOOL 036 - SCOTTISH RITE TEMPLE 037 - CHURCHLAND MIDDLE SCHOOL 038 - GROVE BAPTIST CHURCH 039 - CHURCHLAND PRIMARY AND INTERMEDIATE SCHOOL ##Central Absentee ##Central Absentee 101 - SUBLETTS 102 - MANAKIN 103 - FLAT ROCK 201 - POWHATAN STATION 202 - GRACELAND 301 - BETHESDA 302 - LEE'S LANDING 401 - POWHATAN COURTHOUSE 402 - MT ZION 501 - SMITH CROSS ROADS 502 - PINEVILLE 503 - TOBACCOVILLE ##Central Absentee ##Central Absentee 101 - FARMVILLE 201 - LOCKETT 301 - LEIGH 302 - MT PLEASANT 401 - HAMPDEN 501 - DARLINGTON HTS 502 - BUFFALO HTS 601 - PROSPECT 701 - WEST END 801 - CENTER ##Central Absentee ##Central Absentee 101 - RICHARD BLAND 102 - TEMPLETON 103 - UNION BRANCH 104 - RIVES 105 - HARRISON 201 - BLAND 202 - BLACK WATER 203 - BRANDON 204 - COURTS BLDG 205 - JEFFERSON PARK ##Central Absentee ##Central Absentee ##Central Absentee ##Central Absentee 101 - BRENTSVILLE 102 - CEDAR POINT 103 - GLENKIRK 104 - NOKESVILLE 105 - LIMESTONE 106 - WESTGATE 107 - MARSTELLER 108 - VICTORY 109 - PINEY BRANCH 110 - BUCKLAND MILLS 110 - BUCKLAND MILLS 111 - BRISTOW RUN 112 - BURKE-NICKENS 112 - BURKE-NICKENS 201 - SAUNDERS 202 - MARSHALL 203 - BENNETT 204 - ELLIS 205 - BUCKHALL 206 - COLES 207 - SPRIGGS 208 - HYLTON 209 - INDEPENDENT HILL 210 - PENN 210 - PENN 211 - SIGNAL HILL 212 - YORKSHIRE 213 - SARATOGA 214 - LUCASVILLE 215 - ROSA PARKS 301 - DUMFRIES 302 - POTOMAC 303 - GRAHAM PARK 304 - QUANTICO 305 - PATTIE 306 - WASHINGTON-REID 307 - HENDERSON 308 - MONTCLAIR 309 - ASHLAND 310 - FOREST PARK 311 - SWANS CREEK 312 - TRIANGLE 312 - TRIANGLE 313 - CARDINAL 314 - CABIN BRANCH 401 - EVERGREEN 402 - BATTLEFIELD 403 - BULL RUN 404 - BEN LOMOND 405 - STONEWALL 406 - ALVEY 407 - HERITAGE HUNT 408 - SUDLEY

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Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 26 of 67 Pageid#: 201

2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary

PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PRINCE WILLIAM COUNTY PULASKI COUNTY PULASKI COUNTY PULASKI COUNTY PULASKI COUNTY PULASKI COUNTY PULASKI COUNTY PULASKI COUNTY PULASKI COUNTY PULASKI COUNTY PULASKI COUNTY PULASKI COUNTY PULASKI COUNTY PULASKI COUNTY PULASKI COUNTY RADFORD CITY RADFORD CITY RADFORD CITY RADFORD CITY RADFORD CITY RAPPAHANNOCK COUNTY RAPPAHANNOCK COUNTY RAPPAHANNOCK COUNTY RAPPAHANNOCK COUNTY RAPPAHANNOCK COUNTY RAPPAHANNOCK COUNTY RAPPAHANNOCK COUNTY RAPPAHANNOCK COUNTY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY

409 - TYLER 410 - MOUNTAIN VIEW 411 - MULLEN 412 - CATHARPIN 413 - REAGAN 501 - LAKE RIDGE 502 - OCCOQUAN 503 - OLD BRIDGE 504 - ROCKLEDGE 505 - MOHICAN 506 - BETHEL 507 - CHINN 508 - SPRINGWOODS 509 - MC COART 510 - YATES FORD 511 - WESTRIDGE 512 - YORK 513 - LYNNWOOD 514 - ANTIETAM 601 - DALE 602 - BEVILLE 603 - HAMPTON 604 - GIDEON 605 - MINNIEVILLE 606 - BEL AIR 607 - KERRYDALE 608 - ENTERPRISE 609 - KING 609 - KING 610 - FITZGERALD 611 - NEABSCO 701 - BELMONT 702 - LIBRARY 703 - LYNN 704 - PORTER 705 - POTOMAC VIEW 706 - RIPPON 707 - KILBY 708 - RIVER OAKS 709 - FREEDOM 710 - POWELLS CREEK 711 - GRAYSON 712 - LEESYLVANIA ##Central Absentee ##Central Absentee 101 - BELSPRING 102 - NEW RIVER 103 - WEST CLOYD 201 - DRAPER 202 - SOUTH PULASKI 203 - NEWBERN 301 - DUBLIN 302 - HIWASSEE 304 - SNOWVILLE 401 - MASSIE 402 - WALKER 501 - ROBINSON ##Central Absentee ##Central Absentee 001 - EAST PRECINCT 002 - CENTRAL PRECINCT 003 - WEST PRECINCT ##Central Absentee ##Central Absentee 101 - WASHINGTON 201 - AMISSVILLE 301 - SPERRYVILLE 401 - SCRABBLE 501 - CHESTER GAP 502 - FLINT HILL ##Central Absentee ##Central Absentee 101 - ONE HUNDRED ONE 102 - ONE HUNDRED TWO 104 - ONE HUNDRED FOUR 105 - ONE HUNDRED FIVE 106 - ONE HUNDRED SIX 111 - ONE HUNDRED ELEVEN 112 - ONE HUNDRED TWELVE 113 - ONE HUNDRED THIRTEEN 114 - ONE HUNDRED FOURTEEN 115 - ONE HUNDRED FIFTEEN 203 - TWO HUNDRED THREE 204 - TWO HUNDRED FOUR 206 - TWO HUNDRED SIX 207 - TWO HUNDRED SEVEN 208 - TWO HUNDRED EIGHT 213 - TWO HUNDRED THIRTEEN 214 - TWO HUNDRED FOURTEEN 301 - THREE HUNDRED ONE 302 - THREE HUNDRED TWO 303 - THREE HUNDRED THREE 304 - THREE HUNDRED FOUR 305 - THREE HUNDRED FIVE 306 - THREE HUNDRED SIX 307 - THREE HUNDRED SEVEN 308 - THREE HUNDRED EIGHT 309 - THREE HUNDRED NINE 310 - THREE HUNDRED TEN 402 - FOUR HUNDRED TWO 404 - FOUR HUNDRED FOUR 409 - FOUR HUNDRED NINE 410 - FOUR HUNDRED TEN 412 - FOUR HUNDRED TWELVE 413 - FOUR HUNDRED THIRTEEN 414 - FOUR HUNDRED FOURTEEN 501 - FIVE HUNDRED ONE

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Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 27 of 67 Pageid#: 202

2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary

RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND CITY RICHMOND COUNTY RICHMOND COUNTY RICHMOND COUNTY RICHMOND COUNTY RICHMOND COUNTY RICHMOND COUNTY RICHMOND COUNTY ROANOKE CITY ROANOKE CITY ROANOKE CITY ROANOKE CITY ROANOKE CITY ROANOKE CITY ROANOKE CITY ROANOKE CITY ROANOKE CITY ROANOKE CITY ROANOKE CITY ROANOKE CITY ROANOKE CITY ROANOKE CITY ROANOKE CITY ROANOKE CITY ROANOKE CITY ROANOKE CITY ROANOKE CITY ROANOKE CITY ROANOKE CITY ROANOKE CITY ROANOKE COUNTY ROANOKE COUNTY ROANOKE COUNTY ROANOKE COUNTY ROANOKE COUNTY ROANOKE COUNTY ROANOKE COUNTY ROANOKE COUNTY ROANOKE COUNTY ROANOKE COUNTY ROANOKE COUNTY ROANOKE COUNTY ROANOKE COUNTY ROANOKE COUNTY ROANOKE COUNTY ROANOKE COUNTY ROANOKE COUNTY ROANOKE COUNTY ROANOKE COUNTY ROANOKE COUNTY ROANOKE COUNTY ROANOKE COUNTY ROANOKE COUNTY ROANOKE COUNTY ROANOKE COUNTY ROANOKE COUNTY ROANOKE COUNTY ROANOKE COUNTY ROANOKE COUNTY ROANOKE COUNTY ROANOKE COUNTY ROANOKE COUNTY ROANOKE COUNTY ROANOKE COUNTY ROANOKE COUNTY ROCKBRIDGE COUNTY ROCKBRIDGE COUNTY ROCKBRIDGE COUNTY ROCKBRIDGE COUNTY ROCKBRIDGE COUNTY ROCKBRIDGE COUNTY ROCKBRIDGE COUNTY ROCKBRIDGE COUNTY ROCKBRIDGE COUNTY ROCKBRIDGE COUNTY ROCKBRIDGE COUNTY

503 - FIVE HUNDRED THREE 504 - FIVE HUNDRED FOUR 505 - FIVE HUNDRED FIVE 508 - FIVE HUNDRED EIGHT 509 - FIVE HUNDRED NINE 510 - FIVE HUNDRED TEN 602 - SIX HUNDRED TWO 603 - SIX HUNDRED THREE 604 - SIX HUNDRED FOUR 606 - SIX HUNDRED SIX 607 - SIX HUNDRED SEVEN 609 - SIX HUNDRED NINE 610 - SIX HUNDRED TEN 701 - SEVEN HUNDRED ONE 702 - SEVEN HUNDRED TWO 703 - SEVEN HUNDRED THREE 705 - SEVEN HUNDRED FIVE 706 - SEVEN HUNDRED SIX 707 - SEVEN HUNDRED SEVEN 708 - SEVEN HUNDRED EIGHT 802 - EIGHT HUNDRED TWO 806 - EIGHT HUNDRED SIX 810 - EIGHT HUNDRED TEN 811 - EIGHT HUNDRED ELEVEN 812 - EIGHT HUNDRED TWELVE 814 - EIGHT HUNDRED FOURTEEN 902 - NINE HUNDRED TWO 903 - NINE HUNDRED THREE 908 - NINE HUNDRED EIGHT 909 - NINE HUNDRED NINE 910 - NINE HUNDRED TEN 911 - NINE HUNDRED ELEVEN ##Central Absentee ##Central Absentee 101 - PRECINCT 1-1 201 - PRECINCT 2-1 301 - PRECINCT 3-1 401 - PRECINCT 4-1 501 - PRECINCT 5-1 ##Central Absentee ##Central Absentee 001 -Peters Creek 002 - Grandview 003 -Preston Park 004 - Williamson Road 005 - East Gate 006 - Hollins Road 007 - Southeast 008 - Lincoln Terrace 009 - Highland 010 - Old Southwest-Wasena 011 - RALEIGH COURT 012 - SOUTH ROANOKE 013 - GARDEN CITY 014 - Crystal Spring 015 - Grandin Court 016 - Deyerle 017 - LEE-HI 018 - Summit Hills 019 - Forest Park 020 - EUREKA PARK ##Central Absentee ##Central Absentee ##Central Absentee 101 - CATAWBA 102 - MASON VALLEY 103 - GLENVAR 104 - NORTHSIDE 105 - PETERS CREEK 106 - GREEN HILL 107 - BENNETT SPRINGS 108 - WILDWOOD 201 - PLANTATION 202 - BURLINGTON 203 - MOUNTAIN VIEW 204 - BOTETOURT SPRINGS 205 - ORCHARDS 206 - HOLLINS 301 - BENT MOUNTAIN 302 - POAGES MILL 303 - WINDSOR HILLS 304 - OAK GROVE 305 - CASTLE ROCK 306 - GARST MILL 402 - BONSACK 403 - NORTH VINTON 404 - SOUTH VINTON 405 - LINDENWOOD 406 - MOUNT PLEASANT 501 - COTTON HILL 502 - PENN FOREST 503 - CAVE SPRING 504 - OGDEN 505 - CLEARBROOK 506 - MOUNT VERNON 507 - HUNTING HILLS ##Central Absentee ##Central Absentee 101 - AIRPORT 102 - BEN SALEM 103 - PLANK ROAD 104 - EFFINGER 201 - COLLIERSTOWN 202 - HIGHLAND BELLE 203 - VO-TECH 301 - MAURY RIVER 302 - NATURAL BRIDGE

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Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 28 of 67 Pageid#: 203

2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary

ROCKBRIDGE COUNTY ROCKBRIDGE COUNTY ROCKBRIDGE COUNTY ROCKBRIDGE COUNTY ROCKBRIDGE COUNTY ROCKBRIDGE COUNTY ROCKBRIDGE COUNTY ROCKBRIDGE COUNTY ROCKINGHAM COUNTY ROCKINGHAM COUNTY ROCKINGHAM COUNTY ROCKINGHAM COUNTY ROCKINGHAM COUNTY ROCKINGHAM COUNTY ROCKINGHAM COUNTY ROCKINGHAM COUNTY ROCKINGHAM COUNTY ROCKINGHAM COUNTY ROCKINGHAM COUNTY ROCKINGHAM COUNTY ROCKINGHAM COUNTY ROCKINGHAM COUNTY ROCKINGHAM COUNTY ROCKINGHAM COUNTY ROCKINGHAM COUNTY ROCKINGHAM COUNTY ROCKINGHAM COUNTY ROCKINGHAM COUNTY ROCKINGHAM COUNTY ROCKINGHAM COUNTY ROCKINGHAM COUNTY ROCKINGHAM COUNTY ROCKINGHAM COUNTY ROCKINGHAM COUNTY ROCKINGHAM COUNTY ROCKINGHAM COUNTY ROCKINGHAM COUNTY ROCKINGHAM COUNTY ROCKINGHAM COUNTY ROCKINGHAM COUNTY RUSSELL COUNTY RUSSELL COUNTY RUSSELL COUNTY RUSSELL COUNTY RUSSELL COUNTY RUSSELL COUNTY RUSSELL COUNTY RUSSELL COUNTY RUSSELL COUNTY RUSSELL COUNTY RUSSELL COUNTY RUSSELL COUNTY RUSSELL COUNTY RUSSELL COUNTY RUSSELL COUNTY RUSSELL COUNTY RUSSELL COUNTY SALEM CITY SALEM CITY SALEM CITY SALEM CITY SALEM CITY SALEM CITY SALEM CITY SALEM CITY SALEM CITY SALEM CITY SALEM CITY SALEM CITY SCOTT COUNTY SCOTT COUNTY SCOTT COUNTY SCOTT COUNTY SCOTT COUNTY SCOTT COUNTY SCOTT COUNTY SCOTT COUNTY SCOTT COUNTY SCOTT COUNTY SCOTT COUNTY SCOTT COUNTY SCOTT COUNTY SCOTT COUNTY SCOTT COUNTY SCOTT COUNTY SCOTT COUNTY SCOTT COUNTY SCOTT COUNTY SHENANDOAH COUNTY SHENANDOAH COUNTY SHENANDOAH COUNTY SHENANDOAH COUNTY SHENANDOAH COUNTY SHENANDOAH COUNTY SHENANDOAH COUNTY SHENANDOAH COUNTY SHENANDOAH COUNTY SHENANDOAH COUNTY SHENANDOAH COUNTY SHENANDOAH COUNTY SHENANDOAH COUNTY SHENANDOAH COUNTY SMYTH COUNTY SMYTH COUNTY SMYTH COUNTY SMYTH COUNTY SMYTH COUNTY

303 - FALLING SPRING 401 - FAIRFIELD 402 - MOUNTAIN VIEW 403 - VESUVIUS 501 - GOSHEN 502 - MEADOWVIEW 503 - ROCKBRIDGE BATHS 504 - ROCKBRIDGE ##Central Absentee ##Central Absentee 101 - BROADWAY 102 - TIMBERVILLE 103 - FULKS RUN 104 - BERGTON 105 - LACEY SPRING 106 - TENTH LEGION 107 - PLAINS 108 - LITTLE NORTH MOUNTAIN 201 - SINGERS GLEN 202 - EDOM 203 - DAYTON 204 - MT CLINTON 205 - SILVER LAKE 301 - KEEZLETOWN 302 - PORT REPUBLIC 303 - MELROSE 304 - GROTTOES 305 - MASSANETTA SPRINGS 306 - CROSS KEYS 307 - CROSSROADS 401 - BRIDGEWATER 402 - MONTEZUMA 403 - MT CRAWFORD 404 - NORTH RIVER 405 - OTTOBINE 501 - ELKTON 502 - SWIFT RUN 503 - MCGAHEYSVILLE 504 - SOUTH FORK 505 - STONY RUN ##Central Absentee ##Central Absentee 101 - MOCCASIN 102 - COPPER CREEK 103 - SOUTH CASTLEWOOD 201 - NORTH CASTLEWOOD 202 - DANTE 301 - COOKS MILL 302 - DAUGHERTY 303 - NEW GARDEN 304 - CLEVELAND 401 - DRILL 402 - SWORDS CREEK 403 - HONAKER 501 - WEST LEBANON 601 - EAST LEBANON 602 - ELK GARDEN ##Central Absentee ##Central Absentee 001 - NORTH SALEM NO 2 002 - CONEHURST 003 - BEVERLY HEIGHTS 004 - WEST SALEM 005 - NORTH SALEM NO 1 006 - SOUTH SALEM NO 1 007 - SOUTH SALEM NO 2 008 - EAST SALEM 009 - SOUTH SIDE HILLS 010 - HIDDEN VALLEY ##Central Absentee ##Central Absentee 101 - WEBER CITY 102 - YUMA 202 - WEBER CITY EAST 203 - HILTONS 204 - CLARK'S 301 - NICKELSVILLE 302 - SNOWFLAKE 303 - TWIN SPRINGS 304 - COPPER CREEK 401 - GATE CITY 501 - DUNGANNON 502 - FORT BLACKMORE 503 - MANVILLE 504 - RYE COVE 601 - CLINCHPORT 602 - DUFFIELD-PATTONSVILLE 603 - FAIRVIEW ##Central Absentee ##Central Absentee 101 - ORKNEY SPRINGS 103 - NEW MARKET 201 - CONICVILLE 202 - MT JACKSON 302 - EDINBURG 303 - ST LUKE 304 - FORT VALLEY 401 - WOODSTOCK 501 - CEDAR CREEK 503 - TOMS BROOK 504 - LEBANON CHURCH 601 - STRASBURG ##Central Absentee ##Central Absentee 101 - SALTVILLE 201 - SEVEN MILE FORD 202 - RICH VALLEY

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2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary

SMYTH COUNTY SMYTH COUNTY SMYTH COUNTY SMYTH COUNTY SMYTH COUNTY SMYTH COUNTY SMYTH COUNTY SMYTH COUNTY SMYTH COUNTY SMYTH COUNTY SMYTH COUNTY SOUTHAMPTON COUNTY SOUTHAMPTON COUNTY SOUTHAMPTON COUNTY SOUTHAMPTON COUNTY SOUTHAMPTON COUNTY SOUTHAMPTON COUNTY SOUTHAMPTON COUNTY SOUTHAMPTON COUNTY SOUTHAMPTON COUNTY SOUTHAMPTON COUNTY SOUTHAMPTON COUNTY SOUTHAMPTON COUNTY SOUTHAMPTON COUNTY SOUTHAMPTON COUNTY SOUTHAMPTON COUNTY SPOTSYLVANIA COUNTY SPOTSYLVANIA COUNTY SPOTSYLVANIA COUNTY SPOTSYLVANIA COUNTY SPOTSYLVANIA COUNTY SPOTSYLVANIA COUNTY SPOTSYLVANIA COUNTY SPOTSYLVANIA COUNTY SPOTSYLVANIA COUNTY SPOTSYLVANIA COUNTY SPOTSYLVANIA COUNTY SPOTSYLVANIA COUNTY SPOTSYLVANIA COUNTY SPOTSYLVANIA COUNTY SPOTSYLVANIA COUNTY SPOTSYLVANIA COUNTY SPOTSYLVANIA COUNTY SPOTSYLVANIA COUNTY SPOTSYLVANIA COUNTY SPOTSYLVANIA COUNTY SPOTSYLVANIA COUNTY SPOTSYLVANIA COUNTY SPOTSYLVANIA COUNTY SPOTSYLVANIA COUNTY SPOTSYLVANIA COUNTY SPOTSYLVANIA COUNTY SPOTSYLVANIA COUNTY SPOTSYLVANIA COUNTY SPOTSYLVANIA COUNTY SPOTSYLVANIA COUNTY SPOTSYLVANIA COUNTY SPOTSYLVANIA COUNTY SPOTSYLVANIA COUNTY SPOTSYLVANIA COUNTY STAFFORD COUNTY STAFFORD COUNTY STAFFORD COUNTY STAFFORD COUNTY STAFFORD COUNTY STAFFORD COUNTY STAFFORD COUNTY STAFFORD COUNTY STAFFORD COUNTY STAFFORD COUNTY STAFFORD COUNTY STAFFORD COUNTY STAFFORD COUNTY STAFFORD COUNTY STAFFORD COUNTY STAFFORD COUNTY STAFFORD COUNTY STAFFORD COUNTY STAFFORD COUNTY STAFFORD COUNTY STAFFORD COUNTY STAFFORD COUNTY STAFFORD COUNTY STAFFORD COUNTY STAFFORD COUNTY STAFFORD COUNTY STAFFORD COUNTY STAFFORD COUNTY STAFFORD COUNTY STAUNTON CITY STAUNTON CITY STAUNTON CITY STAUNTON CITY STAUNTON CITY STAUNTON CITY STAUNTON CITY SUFFOLK CITY SUFFOLK CITY SUFFOLK CITY SUFFOLK CITY SUFFOLK CITY SUFFOLK CITY SUFFOLK CITY SUFFOLK CITY SUFFOLK CITY SUFFOLK CITY SUFFOLK CITY

301 - CHILHOWIE 302 - ST CLAIR 401 - EAST PARK 402 - WEST PARK 501 - ATKINS 502 - WASSONA 601 - ROYAL OAK EAST 602 - ROYAL OAK WEST 701 - ADWOLFE 702 - SUGAR GROVE 703 - KONNAROCK ##Central Absentee ##Central Absentee 101 - BERLIN 102 - IVOR 201 - BOYKINS 202 - BRANCHVILLE 301 - CAPRON 302 - SEBRELL 401 - DREWRYVILLE 501 - HUNTERDALE 502 - FORKS-OF-THE-RIVER 601 - COURTLAND 602 - SEDLEY 701 - BLACKWATER RIVER 702 - NEWSOMS ##Central Absentee ##Central Absentee ##Central Absentee 101 - PARTLOW 102 - BLAYDES CORNER 103 - TRAVELERS REST 103 - TRAVELERS REST 104 - MASSAPONAX 201 - WILDERNESS SCHOOL 202 - WILDERNESS FIRE 203 - NI RIVER / ELYS FORD 204 - CHANCELLOR 301 - PLANK ROAD 302 - HAZEL RUN 303 - RIVERBEND 401 - SUMMIT 402 - PARKSIDE 402 - PARKSIDE 403 - LEE HILL 501 - BELMONT 502 - BROKENBURG 503 - POST OAK 504 - COURTHOUSE 505 - BROCK 601 - SALEM 602 - SMITH STATION 603 - PIEDMONT 701 - BATTLEFIELD 702 - BRENTS MILL 702 - BRENTS MILL 703 - FAIRVIEW 703 - FAIRVIEW 704 - GAYLE 704 - GAYLE ##Central Absentee ##Central Absentee 101 - HARTWOOD 102 - ROCKY RUN 103 - SIMPSON 104 - COLLEGE 201 - ROCK HILL 202 - ROSEVILLE 203 - RUBY 204 - STEFANIGA 301 - GRIFFIS 302 - WIDEWATER 303 - HARBOUR 304 - BARRETT 401 - AQUIA 402 - COURTHOUSE 403 - BROOKE 404 - GOVERNMENT ISLAND 501 - GRAFTON 502 - FALMOUTH 503 - DREW 504 - GAYLE 601 - FERRY FARM 602 - CHATHAM 603 - WHITE OAK 604 - ENGLAND RUN 701 - WOODLANDS 702 - WHITSON 703 - HAMPTON ##Central Absentee ##Central Absentee 101 - WARD NO 1 201 - WARD NO 2 301 - WARD NO 3 401 - WARD NO 4 501 - WARD NO 5 ##Central Absentee ##Central Absentee ##Central Absentee 101 - BELLEHARBOUR 102 - DRIVER 104 - BENNETTS CREEK 201 - EBENEZER 202 - CHUCKATUCK 203 - KINGS FORK 204 - HILLPOINT 301 - WHITE MARSH

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Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 30 of 67 Pageid#: 205

2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary

SUFFOLK CITY SUFFOLK CITY SUFFOLK CITY SUFFOLK CITY SUFFOLK CITY SUFFOLK CITY SUFFOLK CITY SUFFOLK CITY SUFFOLK CITY SUFFOLK CITY SUFFOLK CITY SUFFOLK CITY SUFFOLK CITY SUFFOLK CITY SUFFOLK CITY SUFFOLK CITY SUFFOLK CITY SUFFOLK CITY SUFFOLK CITY SUFFOLK CITY SUFFOLK CITY SUFFOLK CITY SUFFOLK CITY SURRY COUNTY SURRY COUNTY SURRY COUNTY SURRY COUNTY SURRY COUNTY SURRY COUNTY SURRY COUNTY SUSSEX COUNTY SUSSEX COUNTY SUSSEX COUNTY SUSSEX COUNTY SUSSEX COUNTY SUSSEX COUNTY SUSSEX COUNTY SUSSEX COUNTY SUSSEX COUNTY SUSSEX COUNTY SUSSEX COUNTY SUSSEX COUNTY SUSSEX COUNTY TAZEWELL COUNTY TAZEWELL COUNTY TAZEWELL COUNTY TAZEWELL COUNTY TAZEWELL COUNTY TAZEWELL COUNTY TAZEWELL COUNTY TAZEWELL COUNTY TAZEWELL COUNTY TAZEWELL COUNTY TAZEWELL COUNTY TAZEWELL COUNTY TAZEWELL COUNTY TAZEWELL COUNTY TAZEWELL COUNTY TAZEWELL COUNTY TAZEWELL COUNTY TAZEWELL COUNTY TAZEWELL COUNTY TAZEWELL COUNTY TAZEWELL COUNTY TAZEWELL COUNTY TAZEWELL COUNTY TAZEWELL COUNTY TAZEWELL COUNTY TAZEWELL COUNTY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY

302 - JOHN F KENNEDY 302 - JOHN F KENNEDY 304 - NANSEMOND RIVER 305 - SHOULDERS HILL 401 - AIRPORT 402 - WHALEYVILLE 403 - SOUTHSIDE 404 - BOOKER T WASHINGTON 404 - BOOKER T WASHINGTON 405 - PITTMANTOWN 501 - KILBYS MILL 502 - HOLLAND 504 - LAKE COHOON 504 - LAKE COHOON 601 - LAKESIDE 602 - OLDE TOWNE 602 - OLDE TOWNE 603 - ELEPHANTS FORK/WESTHAVEN 604 - WILROY 605 - HOLLYWOOD 702 - HARBOURVIEW 704 - BURBAGE GRANT 706 - HUNTERSVILLE 101 - SURRY 201 - BACONS CASTLE 301 - DENDRON 302 - WALLS BRIDGE 401 - CARSLEY 501 - CLAREMONT 502 - SPRING GROVE ##Central Absentee ##Central Absentee 101 - WAVERLY 201 - STONY CREEK 202 - LITTLE MILL 301 - COURTHOUSE 302 - WAKEFIELD 401 - MARS HILL 402 - WEST WAKEFIELD 501 - HENRY 502 - YALE 601 - BLACKWATER 602 - NEWVILLE ##Central Absentee ##Central Absentee 101 - ABBS VALLEY 102 - TIP TOP 103 - BOISSEVAIN 104 - FALLS MILLS 106 - POCAHONTAS 107 - AMONATE 109 - BISHOP 110 - ADRIA 111 - GAP STORE 112 - BANDY 203 - BURKES GARDEN 204 - CLEAR FORK 207 - FREESTONE 209 - JEFFERSONVILLE 214 - THOMPSON VALLEY 301 - CEDAR BLUFF 302 - BAPTIST VALLEY 303 - WARDELL 305 - POUNDING MILL 401 - RICHLANDS 402 - JEWELL RIDGE 404 - RAVEN 501 - SPRINGVILLE 502 - GRAHAM ##Central Absentee ##Central Absentee 001 - NORTH BEACH 002 - SOUTH BEACH 003 - OCEAN LAKES 004 - LINKHORN 005 - SEATACK 006 - ALANTON 007 - KINGSTON 008 - LONDON BRIDGE 009 - TRANTWOOD 010 - GREAT NECK 011 - CAPE HENRY 012 - PLAZA 013 - MT TRASHMORE 014 - MALIBU 015 - OLD DONATION 016 - ARAGONA 017 - OCEAN PARK 018 - THOROUGHGOOD 019 - LAKE SMITH 020 - BAYSIDE 021 - DAVIS CORNER 022 - POINT O VIEW 023 - ARROWHEAD 024 - LARKSPUR 025 - AVALON 026 - FAIRFIELD 027 - EDWIN 028 - THALIA 029 - HOLLAND 030 - RED WING 031 - SIGMA 032 - CREEDS 033 - CAPPS SHOP 034 - BLACKWATER 035 - COURTHOUSE 036 - WINDSOR OAKS

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Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 31 of 67 Pageid#: 206

2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary

VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY VIRGINIA BEACH CITY WARREN COUNTY WARREN COUNTY WARREN COUNTY WARREN COUNTY WARREN COUNTY WARREN COUNTY WARREN COUNTY WARREN COUNTY WARREN COUNTY WARREN COUNTY WARREN COUNTY WARREN COUNTY WARREN COUNTY WASHINGTON COUNTY WASHINGTON COUNTY WASHINGTON COUNTY WASHINGTON COUNTY WASHINGTON COUNTY WASHINGTON COUNTY WASHINGTON COUNTY WASHINGTON COUNTY WASHINGTON COUNTY WASHINGTON COUNTY WASHINGTON COUNTY WASHINGTON COUNTY WASHINGTON COUNTY WASHINGTON COUNTY WASHINGTON COUNTY WASHINGTON COUNTY WASHINGTON COUNTY WASHINGTON COUNTY WASHINGTON COUNTY WASHINGTON COUNTY WASHINGTON COUNTY WAYNESBORO CITY WAYNESBORO CITY WAYNESBORO CITY WAYNESBORO CITY WAYNESBORO CITY WAYNESBORO CITY WESTMORELAND COUNTY WESTMORELAND COUNTY WESTMORELAND COUNTY

037 - CHESAPEAKE BEACH 038 - WITCHDUCK 039 - PEMBROKE 040 - BONNEY 041 - COLLEGE PARK 042 - BRANDON 043 - BELLAMY 044 - CENTERVILLE 045 - TIMBERLAKE 046 - GREEN RUN 047 - KINGS GRANT 048 - WOLFSNARE 049 - LYNNHAVEN 050 - OCEANA 051 - STRATFORD CHASE 052 - HOMESTEAD 053 - SHANNON 054 - CROMWELL 055 - MAGIC HOLLOW 056 - EDINBURGH 057 - SHERRY PARK 058 - GLENWOOD 059 - SHELTON PARK 060 - FOXFIRE 061 - BAKER 062 - LANDSTOWN 063 - CULVER 064 - ROSEMONT FOREST 065 - COLONIAL 066 - HUNT 067 - EASTERN SHORE 068 - MANOR 069 - SHELL 070 - CORPORATE LANDING 071 - ROUND HILL 072 - RUDEE 073 - DAHLIA 074 - BUCKNER 075 - COLONY 076 - VILLAGE 077 - BROOKWOOD 078 - INDIAN LAKES 079 - PLEASANT HALL 080 - CHIMNEY HILL 081 - ROCK LAKE 082 - SHELBURNE 083 - STRAWBRIDGE 084 - TALLWOOD 085 - UPTON 086 - HAYGOOD 087 - HILLCREST 088 - NORTH LANDING 089 - LAKE CHRISTOPHER 090 - LAKE JOYCE 091 - LEXINGTON 092 - LITTLE NECK 093 - NEWTOWN 094 - PINEWOOD 095 - DAM NECK 096 - HILLTOP 097 - INDIAN RIVER 098 - INDEPENDENCE 099 - SALEM WOODS 100 - SANDBRIDGE ##Central Absentee ##Central Absentee 101 - FORK TOWN 102 - OTTERBURN 201 - HAPPY CREEK 202 - LINDEN 301 - NORTH RIVER 302 - RIVERTON 401 - EAST SHENANDOAH 402 - TOWN - WEST SHENANDOAH 501 - SOUTH RIVER 502 - BENTONVILLE 504 - BROWNTOWN ##Central Absentee ##Central Absentee 101 - EAST ABINGDON 102 - WEST ABINGDON 201 - CLINCHBURG 202 - GREENDALE 203 - HAYTERS GAP 204 WOODLAND HILLS 301 - WATAUGA 302 - SOUTH ABINGDON 401 - GLADE SPRING 402 - MEADOWVIEW 501 - RHEA VALLEY 502 - DAMASCUS 504 - GREEN COVE 601 - BURSON PLACE 602 - MENDOTA 603 - VALLEY INSTITUTE 701 - HIGH POINT 702 - WALLACE 703 - JOHN BATTLE ##Central Absentee ##Central Absentee 001 - WARD A 002 - WARD B 003 - WARD C 004 - WARD D ##Central Absentee ##Central Absentee 101 - PRECINCT 1-1

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57

Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 32 of 67 Pageid#: 207

2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary 2018 June Republican Primary Total Statewide

WESTMORELAND COUNTY WESTMORELAND COUNTY WESTMORELAND COUNTY WESTMORELAND COUNTY WESTMORELAND COUNTY WESTMORELAND COUNTY WESTMORELAND COUNTY WILLIAMSBURG CITY WILLIAMSBURG CITY WILLIAMSBURG CITY WILLIAMSBURG CITY WINCHESTER CITY WINCHESTER CITY WINCHESTER CITY WINCHESTER CITY WINCHESTER CITY WINCHESTER CITY WINCHESTER CITY WINCHESTER CITY WISE COUNTY WISE COUNTY WISE COUNTY WISE COUNTY WISE COUNTY WISE COUNTY WISE COUNTY WISE COUNTY WISE COUNTY WISE COUNTY WISE COUNTY WISE COUNTY WISE COUNTY WISE COUNTY WYTHE COUNTY WYTHE COUNTY WYTHE COUNTY WYTHE COUNTY WYTHE COUNTY WYTHE COUNTY WYTHE COUNTY WYTHE COUNTY WYTHE COUNTY WYTHE COUNTY WYTHE COUNTY WYTHE COUNTY WYTHE COUNTY YORK COUNTY YORK COUNTY YORK COUNTY YORK COUNTY YORK COUNTY YORK COUNTY YORK COUNTY YORK COUNTY YORK COUNTY YORK COUNTY YORK COUNTY YORK COUNTY YORK COUNTY YORK COUNTY YORK COUNTY

102 - PRECINCT 1-2 201 - PRECINCT 2-1 202 - PRECINCT 2-2 301 - PRECINCT 3-1 302 - PRECINCT 3-2 401 - PRECINCT 4-1 501 - PRECINCT 5-1 ##Central Absentee ##Central Absentee 001 - STRYKER 002 - MATOAKA ##Central Absentee ##Central Absentee 101 - MERRIMANS 102 - OLD TOWN 201 - VIRGINIA AVENUE 301 - WAR MEMORIAL 401 - FREDERICK DOUGLASS 402 - ROLLING HILLS ##Central Absentee ##Central Absentee 101 - APPALACHIA 102 - DORCHESTER 103 - GUEST RIVER VOTING PLACE 104 - WEST POUND 201 - NORTH COEBURN 202 - WISE 203 - EAST POUND 301 - BIG STONE GAP 302 - EAST STONE GAP 401 - CLINCH VALLEY 402 - SOUTH COEBURN 403 - ST PAUL ##Central Absentee ##Central Absentee 101 - ROYAL OAK 102 - RURAL RETREAT 203 - WEST WYTHEVILLE 303 - EAST WYTHEVILLE 401 - FORT CHISWELL 402 - MAX MEADOWS 501 - JACKSON MEMORIAL 502 - SHEFFEY 601 - HUDDLE 602 - ZION 603 EVERGREEN ##Central Absentee ##Central Absentee 101 - QUEENS LAKE 102 - WALLER MILL 103 - MAGRUDER 201 - COVENTRY 202 - KILN CREEK 301 - SEAFORD 302 - YORKTOWN 303 - EDGEHILL 401 - HARWOODS MILL 402 - DARE 403 - GRAFTON 501 - TABB 502 - BETHEL

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321340

Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 33 of 67 Pageid#: 208

EXHIBIT C

election locality 2018 June ACCOMACK COUNTY 2018 June ACCOMACK COUNTY 2018 June ACCOMACK COUNTY 2018 June ACCOMACK COUNTY 2018 June ACCOMACK COUNTY 2018 June ACCOMACK COUNTY 2018 June ACCOMACK COUNTY 2018 June ACCOMACK COUNTY 2018 June ACCOMACK COUNTY 2018 June ACCOMACK COUNTY 2018 June ACCOMACK COUNTY 2018 June ACCOMACK COUNTY 2018 June ACCOMACK COUNTY 2018 June ACCOMACK COUNTY 2018 June ACCOMACK COUNTY 2018 June ACCOMACK COUNTY 2018 June ACCOMACK COUNTY 2018 June ALEXANDRIA CITY 2018 June ALEXANDRIA CITY 2018 June ALEXANDRIA CITY 2018 June ALEXANDRIA CITY 2018 June ALEXANDRIA CITY 2018 June ALEXANDRIA CITY 2018 June ALEXANDRIA CITY 2018 June ALEXANDRIA CITY 2018 June ALEXANDRIA CITY 2018 June ALEXANDRIA CITY 2018 June ALEXANDRIA CITY 2018 June ALEXANDRIA CITY 2018 June ALEXANDRIA CITY 2018 June ALEXANDRIA CITY 2018 June ALEXANDRIA CITY 2018 June ALEXANDRIA CITY 2018 June ALEXANDRIA CITY 2018 June ALEXANDRIA CITY 2018 June ALEXANDRIA CITY 2018 June ALEXANDRIA CITY 2018 June ALEXANDRIA CITY 2018 June ALEXANDRIA CITY 2018 June ALEXANDRIA CITY 2018 June ALEXANDRIA CITY 2018 June ALEXANDRIA CITY 2018 June ALEXANDRIA CITY 2018 June ALEXANDRIA CITY 2018 June ALEXANDRIA CITY 2018 June ALEXANDRIA CITY 2018 June ALLEGHANY COUNTY 2018 June ALLEGHANY COUNTY 2018 June ALLEGHANY COUNTY 2018 June ALLEGHANY COUNTY 2018 June ALLEGHANY COUNTY 2018 June ALLEGHANY COUNTY 2018 June ALLEGHANY COUNTY 2018 June ALLEGHANY COUNTY 2018 June ALLEGHANY COUNTY 2018 June ALLEGHANY COUNTY 2018 June ALLEGHANY COUNTY 2018 June ALLEGHANY COUNTY 2018 June ALLEGHANY COUNTY 2018 June AMELIA COUNTY 2018 June AMELIA COUNTY 2018 June AMELIA COUNTY 2018 June AMELIA COUNTY 2018 June AMELIA COUNTY 2018 June AMELIA COUNTY 2018 June AMHERST COUNTY 2018 June AMHERST COUNTY 2018 June AMHERST COUNTY 2018 June AMHERST COUNTY 2018 June AMHERST COUNTY 2018 June AMHERST COUNTY 2018 June AMHERST COUNTY 2018 June AMHERST COUNTY 2018 June AMHERST COUNTY 2018 June AMHERST COUNTY 2018 June AMHERST COUNTY 2018 June AMHERST COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY

precinct ##Central Absentee 101 - CHINCOTEAGUE 201 - ATLANTIC 202 - GREENBACKVILLE 301 - NEW CHURCH 401 - BLOXOM 402 - PARKSLEY 403 - SAXIS 501 - MAPPSVILLE 502 - RUE 601 - ACCOMAC 602 - TANGIER 701 - NANDUA 801 - BOBTOWN 802 - MELFA 803 - WACHAPREAGUE 901 - PAINTER ##Central Absentee 101 - LADREY SENIOR BUILDING 102 - CITY HALL 103 - LYLES CROUCH SCHOOL 104 - DURANT CENTER 105 - LEE CENTER 106 - CORA KELLY 107 - MT VERNON RECREATION CENTER 108 - GEORGE WASHINGTON MIDDLE SCH 109 - FIRE DEPARTMENT HEADQUARTERS 110 - CHARLES HOUSTON CENTER 111 - POTOMAC YARD 201 - MAURY SCHOOL 202 - GEORGE MASON SCHOOL 203 - AGUDAS ACHIM SYNAGOGUE 204 - BLESSED SACRAMENT CHURCH 205 - DOUGLAS MACARTHUR SCHOOL 206 - CHINQUAPIN PARK RECREATION CTR 207 - TEMPLE BETH EL SYNAGOGUE 208 - NOVA ARTS CENTER 209 - JAMES K POLK SCHOOL 210 - The Hermitage 302 - PATRICK HENRY REC CENTER 303 - CHARLES E BEATLEY LIBRARY 304 - SAMUEL TUCKER SCHOOL 305 - JOHN ADAMS SCHOOL 306 - WILLIAM RAMSAY SCHOOL 307 - SOUTH PORT 308 - CAMERON STATION COMMUNITY CTR ##Central Absentee 101 - ARRITT 103 - DAMERON 201 - HUMPBACK BRIDGE 202 - DOLLY ANN 301 - CALLAGHAN 302 - GRIFFITH 401 - LOW MOOR 402 - JACKSON HEIGHTS 501 - IRON GATE 502 - PETERS SWITCH 601 - DISTRICT 1 701 - DISTRICT 2 ##Central Absentee 101 - NUMBER ONE 201 - NUMBER TWO 301 - NUMBER THREE 401 - NUMBER FOUR 501 - NUMBER FIVE ##Central Absentee 101 - WRIGHT SHOP 102 - NEW GLASGOW 103 - COOLWELL 201 - COURT HOUSE 202 - TEMPERANCE 301 - MONROE 302 - ELON 303 - PLEASANT VIEW 401 - AMELON 402 - LONCO 501 - MADISON ##Central Absentee 001 - ARLINGTON 002 - ASHTON HEIGHTS 003 - AURORA HILLS 004 - BALLSTON 005 - BARCROFT 006 - CRYSTAL CITY 007 - CHERRYDALE 008 - HUME 009 - COLUMBIA

provisional_ballots absentee_ballots in_person_ballots in_person_curbside_ballots TotalVoteTurnout

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305

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2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June ARLINGTON COUNTY 2018 June AUGUSTA COUNTY 2018 June AUGUSTA COUNTY 2018 June AUGUSTA COUNTY 2018 June AUGUSTA COUNTY 2018 June AUGUSTA COUNTY 2018 June AUGUSTA COUNTY 2018 June AUGUSTA COUNTY 2018 June AUGUSTA COUNTY 2018 June AUGUSTA COUNTY 2018 June AUGUSTA COUNTY 2018 June AUGUSTA COUNTY 2018 June AUGUSTA COUNTY 2018 June AUGUSTA COUNTY 2018 June AUGUSTA COUNTY 2018 June AUGUSTA COUNTY 2018 June AUGUSTA COUNTY 2018 June AUGUSTA COUNTY 2018 June AUGUSTA COUNTY 2018 June AUGUSTA COUNTY 2018 June AUGUSTA COUNTY 2018 June AUGUSTA COUNTY 2018 June AUGUSTA COUNTY 2018 June AUGUSTA COUNTY 2018 June AUGUSTA COUNTY 2018 June AUGUSTA COUNTY 2018 June AUGUSTA COUNTY 2018 June BATH COUNTY 2018 June BATH COUNTY 2018 June BATH COUNTY 2018 June BATH COUNTY 2018 June BATH COUNTY 2018 June BATH COUNTY 2018 June BATH COUNTY 2018 June BATH COUNTY 2018 June BEDFORD COUNTY 2018 June BEDFORD COUNTY 2018 June BEDFORD COUNTY 2018 June BEDFORD COUNTY 2018 June BEDFORD COUNTY 2018 June BEDFORD COUNTY 2018 June BEDFORD COUNTY 2018 June BEDFORD COUNTY 2018 June BEDFORD COUNTY

010 - WILSON 011 - EAST FALLS CHURCH 012 - FAIRLINGTON 013 - GLEN CARLYN 014 - CLARENDON 015 - LYON PARK 016 - LYON VILLAGE 017 - OVERLEE KNOLLS 018 - PARK LANE 019 - ROSSLYN 020 - THRIFTON 021 - VIRGINIA HIGHLANDS 022 - ABINGDON 023 - WESTOVER 024 - WOODLAWN 025 - ARLINGTON FOREST 026 - FILLMORE 027 - JEFFERSON 028 - WAKEFIELD 029 - DOMINION HILLS 030 - GLEBE 031 - LEXINGTON 032 - OAKRIDGE 033 - ROCK SPRING 034 - YORKTOWN 035 - MADISON 036 - MARSHALL 037 - NOTTINGHAM 038 - ARLINGTON VIEW 039 - ASHLAWN 040 - VIRGINIA SQUARE 041 - NAVY LEAGUE 042 - SHIRLINGTON 043 - CAMPBELL 044 - DAWSON TERRACE 045 - BUCKINGHAM 046 - CENTRAL 047 - FOUR MILE RUN 048 - AUSA 049 - MONROE 050 - CRYSTAL PLAZA 051 - TAYLOR 052 - GUNSTON 053 - MET PARK 054 - GARFIELD PARK ##Central Absentee 101 - JOLIVUE 102 - STUARTS DRAFT ELEMENTARY 103 - VERONA 201 - CRIMORA 202 - NEW HOPE 203 - WEYERS CAVE 301 - FORT DEFIANCE 302 - NORTH RIVER 303 - MOUNT SOLON 304 - CHURCHVILLE FIRE STATION 401 - BUFFALO GAP 402 - CHURCHVILLE ELEMENTARY 403 - CRAIGSVILLE 404 - DEERFIELD 405 - CEDAR GREEN 501 - GREENVILLE 502 - MIDDLEBROOK 503 - SPOTTSWOOD 504 - WHITE HILL 601 - SHERANDO 602 - RIDGEVIEW 603 - LYNDHURST 801 - DOOMS 802 - FISHERSVILLE 803 - WILSON ##Central Absentee 101 - WARM SPRINGS 102 - MOUNTAIN GROVE 201 - HOT SPRINGS 301 - FAIRVIEW 302 - BURNSVILLE 401 - MILLBORO 501 - HEALING SPRINGS ##Central Absentee 301 - NEW LONDON ACADEMY 304 - RIVERSIDE CHURCH 306 - FOREST FIRE STATION #2 401 - FOREST ELEMENTARY SCHOOL 402 - THOMAS JEFFERSON ELEM SCHOOL 403 - KNIGHTS OF COLUMBUS BLDG 404 - ST. PAUL BAPTIST CHURCH 502 - BIG ISLAND ELEM SCHOOL

2

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34

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63

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39

0

24

Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 35 of 67 Pageid#: 210

2018 June BEDFORD COUNTY 2018 June BEDFORD COUNTY 2018 June BEDFORD COUNTY 2018 June BEDFORD COUNTY 2018 June BEDFORD COUNTY 2018 June BLAND COUNTY 2018 June BLAND COUNTY 2018 June BLAND COUNTY 2018 June BLAND COUNTY 2018 June BLAND COUNTY 2018 June BLAND COUNTY 2018 June BLAND COUNTY 2018 June BLAND COUNTY 2018 June BOTETOURT COUNTY 2018 June BOTETOURT COUNTY 2018 June BOTETOURT COUNTY 2018 June BOTETOURT COUNTY 2018 June BOTETOURT COUNTY 2018 June BOTETOURT COUNTY 2018 June BOTETOURT COUNTY 2018 June BOTETOURT COUNTY 2018 June BOTETOURT COUNTY 2018 June BOTETOURT COUNTY 2018 June BOTETOURT COUNTY 2018 June BRISTOL CITY 2018 June BRISTOL CITY 2018 June BRISTOL CITY 2018 June BRISTOL CITY 2018 June BRISTOL CITY 2018 June BUCHANAN COUNTY 2018 June BUCHANAN COUNTY 2018 June BUCHANAN COUNTY 2018 June BUCHANAN COUNTY 2018 June BUCHANAN COUNTY 2018 June BUCHANAN COUNTY 2018 June BUCHANAN COUNTY 2018 June BUCHANAN COUNTY 2018 June BUCHANAN COUNTY 2018 June BUCHANAN COUNTY 2018 June BUCHANAN COUNTY 2018 June BUCHANAN COUNTY 2018 June BUCHANAN COUNTY 2018 June BUCHANAN COUNTY 2018 June BUCHANAN COUNTY 2018 June BUCHANAN COUNTY 2018 June BUCHANAN COUNTY 2018 June BUCHANAN COUNTY 2018 June BUENA VISTA CITY 2018 June BUENA VISTA CITY 2018 June CAROLINE COUNTY 2018 June CAROLINE COUNTY 2018 June CAROLINE COUNTY 2018 June CAROLINE COUNTY 2018 June CAROLINE COUNTY 2018 June CAROLINE COUNTY 2018 June CAROLINE COUNTY 2018 June CAROLINE COUNTY 2018 June CAROLINE COUNTY 2018 June CAROLINE COUNTY 2018 June CAROLINE COUNTY 2018 June CAROLINE COUNTY 2018 June CAROLINE COUNTY 2018 June CARROLL COUNTY 2018 June CARROLL COUNTY 2018 June CARROLL COUNTY 2018 June CARROLL COUNTY 2018 June CARROLL COUNTY 2018 June CARROLL COUNTY 2018 June CARROLL COUNTY 2018 June CARROLL COUNTY 2018 June CARROLL COUNTY 2018 June CARROLL COUNTY 2018 June CARROLL COUNTY 2018 June CARROLL COUNTY 2018 June CARROLL COUNTY 2018 June CARROLL COUNTY 2018 June CARROLL COUNTY 2018 June CARROLL COUNTY 2018 June CARROLL COUNTY 2018 June CARROLL COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY

503 - SEDALIA CENTER 504 - SUCK SPRINGS BAPTIST CHURCH 505 - BOONSBORO ELEMENTARY SCHOOL 506 - BOONSBORO RURITAN CLUB 601 - MONTVALE ELEM SCHOOL ##Central Absentee 101 - BASTIAN 102 - CERES 201 - DAVIS 202 - SEDDON 301 - HOLLYBROOK 302 - MECHANICSBURG 401 - ROCKY GAP ##Central Absentee 101 - DALEVILLE 102 - GREENFIELD 201 - BLUE RIDGE 202 - RAINBOW FOREST 301 - BUCHANAN 302 - MILL CREEK 403 - EAGLE ROCK 406 - FINCASTLE 501 - TROUTVILLE 502 - CLOVERDALE ##Central Absentee 001 - FIRST WARD 002 - SECOND WARD 003 - THIRD WARD 004 - FOURTH WARD ##Central Absentee 102 - BLACKEY 103 - HURLEY 201 - GRASSY 202 - BULL 203 - ROCKLICK 301 - SLATE 302 - NORTH GRUNDY 403 - SOUTH GRUNDY 404 - OAKWOOD 501 - PRATER 502 - FOX 503 - VANSANT 601 - COUNCIL 602 - GARDEN 603 - HURRICANE 701 - WHITEWOOD 702 - CONTRARY 001 - FIRST WARD 002 - SECOND WARD ##Central Absentee 101 - BOWLING GREEN 102 - SPARTA 201 - NORTH MADISON 202 - SOUTH MADISON 301 - PORT ROYAL 302 - WOODFORD 401 - DAWN 402 - CARMEL CHURCH 501 - WEST MATTAPONI 502 - MILFORD 601 - CHILESBURG 602 - LAKE ##Central Absentee 101 - MT BETHEL 102 - ST PAUL 103 - LAMBSBURG 105 - FANCY GAP 201 - HILLSVILLE B 202 - LAUREL FORK 203 - GLADESBORO 301 - HILLSVILLE C 302 - SYLVATUS 303 - DUGSPUR 401 - OAKLAND 402 - WOODLAWN D 406 - WOODLAWN F 501 - VAUGHAN 502 - GLADEVILLE 503 - WOODLAWN E 504 - LAUREL ##Central Absentee 105 - DREWRYS BLUFF 202 - BEULAH 204 - JACOBS 205 - FALLING CREEK 206 - BELMONT 207 - CHIPPENHAM 208 - MEADOWBROOK

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105

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318

Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 36 of 67 Pageid#: 211

2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CHESTERFIELD COUNTY 2018 June CLARKE COUNTY 2018 June CLARKE COUNTY 2018 June CLARKE COUNTY 2018 June CLARKE COUNTY 2018 June CLARKE COUNTY 2018 June CLARKE COUNTY 2018 June CLARKE COUNTY 2018 June CLARKE COUNTY 2018 June COVINGTON CITY 2018 June COVINGTON CITY 2018 June COVINGTON CITY 2018 June COVINGTON CITY 2018 June COVINGTON CITY 2018 June COVINGTON CITY 2018 June CRAIG COUNTY 2018 June CRAIG COUNTY 2018 June CRAIG COUNTY 2018 June CRAIG COUNTY 2018 June CRAIG COUNTY 2018 June CRAIG COUNTY 2018 June CRAIG COUNTY 2018 June CRAIG COUNTY 2018 June CULPEPER COUNTY 2018 June CULPEPER COUNTY 2018 June CULPEPER COUNTY 2018 June CULPEPER COUNTY 2018 June CULPEPER COUNTY 2018 June CULPEPER COUNTY 2018 June CULPEPER COUNTY 2018 June CULPEPER COUNTY 2018 June CULPEPER COUNTY 2018 June CULPEPER COUNTY 2018 June CULPEPER COUNTY 2018 June CULPEPER COUNTY 2018 June CULPEPER COUNTY 2018 June CULPEPER COUNTY 2018 June CULPEPER COUNTY 2018 June CULPEPER COUNTY 2018 June DICKENSON COUNTY

210 - FIVE FORKS 212 - ST. LUKE'S 213 - SOUTHSIDE 214 - HOPKINS 215 - North Bird 302 - DEER RUN 306 - WINTERPOCK 307 - COSBY 308 - SOUTH MANCHESTER 309 - SKINQUARTER 310 - TOMAHAWK 313 - WOOLRIDGE 315 - BAILEY BRIDGE 316 - SPRING RUN 317 - BIRKDALE 318 - WEST BEACH 401 - HARBOUR POINTE 402 - GENITO 403 - BRANDERMILL 404 - PROVIDENCE 405 - LA PRADE 406 - SMOKETREE 407 - MONACAN 408 - REAMS 409 - MANCHESTER 410 - WAGSTAFF 411 - SWIFT CREEK 413 - SHENANDOAH 414 - CRENSHAW 415 - EVERGREEN 416 - EVERGREEN WEST 417 - EDGEWATER 501 - HUGUENOT 502 - CRESTWOOD 503 - MIDLOTHIAN 504 - ROBIOUS 505 - BON AIR 506 - GREENFIELD 507 - SALISBURY 508 - BELGRADE 509 - CRANBECK 510 - SYCAMORE 511 - BLACK HEATH 513 - BEAUFONT 514 - WATKINS 515 - DAVIS 516 - POCOSHOCK 517 - ROSELAND 518 - MIDLOTHIAN NORTH ##Central Absentee 101 - RUSSELL 201 - BERRYVILLE 301 - MILLWOOD 302 - PINE GROVE 401 - WHITE POST 501 - BUCKMARSH 502 - BLUE RIDGE ##Central Absentee 101 - PRECINCT 1-1 201 - PRECINCT 2-1 301 - PRECINCT 3-1 401 - PRECINCT 4-1 501 - PRECINCT 5-1 101 - COURT HOUSE 201 - AMMENDALE PRECINCT 301 - GIVENS & REYNOLDS STORE 303 - MARSHALLS STORE 401 - BARBOURS CREEK 402 - PAINT BANK 403 - CRAIG SPRINGS 501 - CRAIG CITY ##Central Absentee 101 - WEST FAIRFAX 201 - EAST FAIRFAX 302 - EGGBORNSVILLE 303 - CARDOVA 304 - WILLOW SHADE 401 - ELDORADO 402 - BROWNS STORE 501 - JEFFERSONTON 502 - RIXEYVILLE 601 - MITCHELLS 602 - PEARL SAMPLE 603 - SOUTH RIDGE 702 - BRANDY STATION 703 - LIGNUM 704 - RICHARDSVILLE ##Central Absentee

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23

Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 37 of 67 Pageid#: 212

2018 June DICKENSON COUNTY 2018 June DICKENSON COUNTY 2018 June DICKENSON COUNTY 2018 June DICKENSON COUNTY 2018 June DICKENSON COUNTY 2018 June DICKENSON COUNTY 2018 June DICKENSON COUNTY 2018 June DICKENSON COUNTY 2018 June DICKENSON COUNTY 2018 June DICKENSON COUNTY 2018 June ESSEX COUNTY 2018 June ESSEX COUNTY 2018 June ESSEX COUNTY 2018 June ESSEX COUNTY 2018 June ESSEX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAIRFAX COUNTY 2018 June FAUQUIER COUNTY 2018 June FAUQUIER COUNTY 2018 June FAUQUIER COUNTY 2018 June FAUQUIER COUNTY 2018 June FAUQUIER COUNTY 2018 June FLOYD COUNTY 2018 June FLOYD COUNTY 2018 June FLOYD COUNTY 2018 June FLOYD COUNTY 2018 June FLOYD COUNTY 2018 June FLOYD COUNTY 2018 June FREDERICK COUNTY 2018 June FREDERICK COUNTY 2018 June FREDERICK COUNTY 2018 June FREDERICK COUNTY 2018 June FREDERICK COUNTY 2018 June FREDERICK COUNTY 2018 June FREDERICK COUNTY 2018 June FREDERICK COUNTY 2018 June FREDERICK COUNTY 2018 June FREDERICK COUNTY 2018 June FREDERICK COUNTY 2018 June FREDERICK COUNTY

101 - SOUTH CLINTWOOD 201 - NORA 202 - FRYING PAN 203 - CLINCHCO 301 - WEST DANTE 302 - HERALD 303 - RIDGE 401 - HAYSI-COLLEY 501 - TARPON 502 - NORTH CLINTWOOD ##Central Absentee 101 - GREATER TAPPAHANNOCK 201 - NORTH 301 - SOUTH 401 - CENTRAL ##Central Absentee 229 - FOX MILL 240 - COLVIN 301 - CHAIN BRIDGE 303 - CHURCHILL 304 - COOPER 306 - GREAT FALLS 309 - KENMORE 311 - LANGLEY 314 - MCLEAN 321 - CLEARVIEW 322 - FORESTVILLE 323 - SHOUSE 327 - SUGARLAND 328 - HICKORY 329 - SENECA 331 - SPRING HILL 803 - CLIFTON 804 - COLCHESTER 805 - FAIRFAX STATION 815 - WOODYARD 838 - SANGSTER 839 - SILVERBROOK 841 - POPES HEAD 845 - FOUNTAINHEAD 847 - GREENBRIAR WEST 849 - NEWGATE 850 - SOUTH RUN 902 - BROOKFIELD 903 - CUB RUN 904 - STONECROFT 905 - FRANKLIN 908 - HIDDEN MEADOW 909 - OAK HILL 911 - NAVY 913 - ROCKY RUN 914 - VALE 915 - VIRGINIA RUN 916 - WAPLES MILL 917 - STONE NORTH 920 - CHANTILLY 921 - DEER PARK 923 - BULL RUN 925 - OLD MILL 927 - ARMFIELD 928 - POPLAR TREE 929 - DIFFICULT RUN 930 - LEES CORNER 931 - CARSON 932 - STONE SOUTH ##Central Absentee 102 - CATLETT 104 - LOIS 301 - MORRISVILLE 303 - BEALETON ##Central Absentee 101 - LOCUST GROVE 201 - LITTLE RIVER 301 - COURTHOUSE 401 - BURKS FORK 501 - INDIAN VALLEY ##Central Absentee 101 - RUSSELLS 102 - GORE 103 - KERNSTOWN 104 - CEDAR CREEK 201 - GAINESBOROUGH 202 - ALBIN 203 - REDLAND 204 - NAIN 301 - CLEAR BROOK 302 - NEFF'S TOWN 303 - WHITE HALL

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0

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55

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214

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224

Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 38 of 67 Pageid#: 213

2018 June FREDERICK COUNTY 2018 June FREDERICK COUNTY 2018 June FREDERICK COUNTY 2018 June FREDERICK COUNTY 2018 June FREDERICK COUNTY 2018 June FREDERICK COUNTY 2018 June FREDERICK COUNTY 2018 June FREDERICK COUNTY 2018 June FREDERICK COUNTY 2018 June FREDERICK COUNTY 2018 June FREDERICKSBURG CITY 2018 June FREDERICKSBURG CITY 2018 June FREDERICKSBURG CITY 2018 June FREDERICKSBURG CITY 2018 June FREDERICKSBURG CITY 2018 June FREDERICKSBURG CITY 2018 June GALAX CITY 2018 June GALAX CITY 2018 June GALAX CITY 2018 June GALAX CITY 2018 June GILES COUNTY 2018 June GILES COUNTY 2018 June GILES COUNTY 2018 June GILES COUNTY 2018 June GILES COUNTY 2018 June GILES COUNTY 2018 June GILES COUNTY 2018 June GILES COUNTY 2018 June GILES COUNTY 2018 June GILES COUNTY 2018 June GLOUCESTER COUNTY 2018 June GLOUCESTER COUNTY 2018 June GLOUCESTER COUNTY 2018 June GLOUCESTER COUNTY 2018 June GLOUCESTER COUNTY 2018 June GLOUCESTER COUNTY 2018 June GLOUCESTER COUNTY 2018 June GLOUCESTER COUNTY 2018 June GLOUCESTER COUNTY 2018 June GLOUCESTER COUNTY 2018 June GLOUCESTER COUNTY 2018 June GLOUCESTER COUNTY 2018 June GOOCHLAND COUNTY 2018 June GOOCHLAND COUNTY 2018 June GOOCHLAND COUNTY 2018 June GOOCHLAND COUNTY 2018 June GOOCHLAND COUNTY 2018 June GOOCHLAND COUNTY 2018 June GOOCHLAND COUNTY 2018 June GOOCHLAND COUNTY 2018 June GOOCHLAND COUNTY 2018 June GOOCHLAND COUNTY 2018 June GOOCHLAND COUNTY 2018 June GRAYSON COUNTY 2018 June GRAYSON COUNTY 2018 June GRAYSON COUNTY 2018 June GRAYSON COUNTY 2018 June GRAYSON COUNTY 2018 June GRAYSON COUNTY 2018 June GRAYSON COUNTY 2018 June GRAYSON COUNTY 2018 June GRAYSON COUNTY 2018 June GRAYSON COUNTY 2018 June GRAYSON COUNTY 2018 June GRAYSON COUNTY 2018 June GRAYSON COUNTY 2018 June GRAYSON COUNTY 2018 June GRAYSON COUNTY 2018 June GRAYSON COUNTY 2018 June HAMPTON CITY 2018 June HAMPTON CITY 2018 June HAMPTON CITY 2018 June HAMPTON CITY 2018 June HAMPTON CITY 2018 June HAMPTON CITY 2018 June HAMPTON CITY 2018 June HAMPTON CITY 2018 June HAMPTON CITY 2018 June HANOVER COUNTY 2018 June HANOVER COUNTY 2018 June HANOVER COUNTY 2018 June HANOVER COUNTY 2018 June HANOVER COUNTY 2018 June HANOVER COUNTY 2018 June HANOVER COUNTY 2018 June HANOVER COUNTY 2018 June HANOVER COUNTY 2018 June HANOVER COUNTY

401 - CARPERS VALLEY 402 - SHENANDOAH 403 - PARKIN'S MILL 404 - ARMEL 501 - STEPHENS CITY 502 - NEWTOWN 503 - CANTERBURG 601 - MILLBROOK 602 - ASH HOLLOW 603 - GREENWOOD ##Central Absentee 101 - PRECINCT 1 - DISTRICT ONE 201 - PRECINCT 1 - DISTRICT TWO 301 - PRECINCT 1 - DISTRICT THREE 401 - PRECINCT 1 - DISTRICT FOUR 402 - PRECINCT 2 - DISTRICT FOUR ##Central Absentee 001 - EAST 002 - NORTH 003 - SOUTH ##Central Absentee 101 - GLEN LYN 102 - RICH CREEK 103 - NARROWS 201 - PEARISBURG 202 - STAFFORDSVILLE 203 - WHITE GATE 301 - EGGLESTON 302 - PEMBROKE 303 - NEWPORT ##Central Absentee 101 - HARCUM 102 - SALEM 103 - PEASLEY 201 - COURTHOUSE 202 - BOTETOURT 301 - WHITE MARSH 302 - ROANES 401 - HAYES 402 - SARAHS CREEK 501 - ACHILLES 502 - WALKER ##Central Absentee 101 - FIFE 102 - HADENSVILLE 201 - THREE SQUARE 202 - SANDY HOOK 301 - GOOCHLAND COURT HOUSE 1 302 - GOOCHLAND COURT HOUSE 2 401 - SHALLOW WELL 402 - CENTERVILLE 501 - MANAKIN 502 - BLAIR ROAD ##Central Absentee 101 - BRIDLE CREEK 102 - FLATRIDGE 103 - GRANT 104 - MOUTH OF WILSON 105 - MOUNT ROGERS 106 - RUGBY 107 - TROUTDALE 108 - COMERS ROCK 202 - ELK CREEK 203 - INDEPENDENCE 301 - BAYWOOD 302 - FAIRVIEW 401 - FRIES 402 - PROVIDENCE 403 - OLDTOWN ##Central Absentee 110 - PHOEBUS 201 - BOOKER 202 - BRYAN 203 - BURBANK 205 - ASBURY 209 - LANGLEY 213 - PHILLIPS 215 - TYLER ##Central Absentee 101 - ASHLAND 104 - SLIDING HILL 105 - BERKLEY 106 - KERSEY CREEK 107 - CHICKAHOMINY 201 - BEAVERDAM 202 - BLUNTS 203 - WILMINGTON PARISH 206 - COURTHOUSE

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70

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71

1

126

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96

Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 39 of 67 Pageid#: 214

2018 June HANOVER COUNTY 2018 June HANOVER COUNTY 2018 June HANOVER COUNTY 2018 June HANOVER COUNTY 2018 June HANOVER COUNTY 2018 June HANOVER COUNTY 2018 June HANOVER COUNTY 2018 June HANOVER COUNTY 2018 June HANOVER COUNTY 2018 June HANOVER COUNTY 2018 June HANOVER COUNTY 2018 June HANOVER COUNTY 2018 June HANOVER COUNTY 2018 June HANOVER COUNTY 2018 June HANOVER COUNTY 2018 June HANOVER COUNTY 2018 June HANOVER COUNTY 2018 June HANOVER COUNTY 2018 June HANOVER COUNTY 2018 June HANOVER COUNTY 2018 June HANOVER COUNTY 2018 June HANOVER COUNTY 2018 June HANOVER COUNTY 2018 June HANOVER COUNTY 2018 June HANOVER COUNTY 2018 June HANOVER COUNTY 2018 June HANOVER COUNTY 2018 June HARRISONBURG CITY 2018 June HARRISONBURG CITY 2018 June HARRISONBURG CITY 2018 June HARRISONBURG CITY 2018 June HARRISONBURG CITY 2018 June HARRISONBURG CITY 2018 June HARRISONBURG CITY 2018 June HARRISONBURG CITY 2018 June HARRISONBURG CITY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY

208 - OAK KNOLL 209 - WEST HANOVER 210 - OAK HILL 301 - CLAY 303 - SHADY GROVE 304 - ATLEE 305 - COOL SPRING 401 - BATTLEFIELD 403 - COLD HARBOR 404 - BLACK CREEK 405 - PEBBLE CREEK 406 - BEAVERDAM CREEK 502 - RURAL POINT 503 - NEWMAN 504 - STUDLEY 505 - TOTOPOTOMOY 506 - GEORGETOWN 507 - LAUREL MEADOW 601 - VILLAGE 602 - LEE DAVIS 603 - MECHANICSVILLE 604 - HANOVER GROVE 701 - FARRINGTON 702 - MONTPELIER 703 - ROCKVILLE 704 - ELMONT 705 - SOUTH ANNA ##Central Absentee 101 - NORTHEAST 102 - EAST CENTRAL 103 - SOUTHEAST 104 - EAST 105 - South East Central 201 - NORTHWEST 202 - SOUTHWEST 203 - WEST ##Central Absentee 101 - COALPIT 102 - DUMBARTON 103 - GLEN ALLEN 105 - GREENDALE 106 - HERMITAGE 108 - HUNGARY CREEK 109 - HUNTON 110 - JOHNSON 111 - LAKESIDE 112 - LONGAN 113 - MAUDE TREVVETT 114 - MONUMENT HILLS 115 - STAPLES MILL 117 - WESTWOOD 202 - AZALEA 203 - BELMONT 204 - BROOKLAND 205 - CANTERBURY 207 - CHAMBERLAYNE 210 - GREENWOOD 212 - HOLLYBROOK 213 - HUNGARY 214 - LONGDALE 216 - MOODY 217 - MOUNTAIN 218 - OAKVIEW 219 - RANDOLPH 221 - STRATFORD HALL 222 - WILDER 223 - YELLOW TAVERN 301 - CAUSEWAY 302 - CEDARFIELD 303 - INNSBROOK 304 - JACKSON DAVIS 305 - NUCKOLS FARM 306 - POCAHONTAS 307 - RIDGE 308 - RIVERS EDGE 309 - SADLER 310 - SHADY GROVE 311 - SHORT PUMP 312 - SPRINGFIELD 313 - STONEY RUN 314 - THREE CHOPT 315 - TUCKER 401 - QUIOCCASIN 402 - CRESTVIEW 403 - DERBYSHIRE 404 - FREEMAN 405 - GAYTON 406 - GODWIN

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Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 40 of 67 Pageid#: 215

2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRICO COUNTY 2018 June HENRY COUNTY 2018 June HENRY COUNTY 2018 June HENRY COUNTY 2018 June HENRY COUNTY 2018 June HENRY COUNTY 2018 June HENRY COUNTY 2018 June HENRY COUNTY 2018 June HENRY COUNTY 2018 June HENRY COUNTY 2018 June HENRY COUNTY 2018 June HENRY COUNTY 2018 June HENRY COUNTY 2018 June HENRY COUNTY 2018 June HENRY COUNTY 2018 June HENRY COUNTY 2018 June HENRY COUNTY 2018 June HENRY COUNTY 2018 June HENRY COUNTY 2018 June HENRY COUNTY 2018 June HENRY COUNTY 2018 June HIGHLAND COUNTY 2018 June HIGHLAND COUNTY 2018 June HIGHLAND COUNTY 2018 June HIGHLAND COUNTY 2018 June HIGHLAND COUNTY 2018 June HIGHLAND COUNTY 2018 June JAMES CITY COUNTY 2018 June JAMES CITY COUNTY 2018 June JAMES CITY COUNTY 2018 June JAMES CITY COUNTY 2018 June JAMES CITY COUNTY 2018 June JAMES CITY COUNTY 2018 June JAMES CITY COUNTY 2018 June JAMES CITY COUNTY 2018 June JAMES CITY COUNTY 2018 June JAMES CITY COUNTY 2018 June JAMES CITY COUNTY 2018 June JAMES CITY COUNTY 2018 June JAMES CITY COUNTY 2018 June JAMES CITY COUNTY 2018 June JAMES CITY COUNTY 2018 June JAMES CITY COUNTY 2018 June JAMES CITY COUNTY 2018 June JAMES CITY COUNTY 2018 June JAMES CITY COUNTY 2018 June JAMES CITY COUNTY 2018 June JAMES CITY COUNTY 2018 June JAMES CITY COUNTY 2018 June JAMES CITY COUNTY 2018 June KING & QUEEN COUNTY 2018 June KING & QUEEN COUNTY 2018 June KING & QUEEN COUNTY 2018 June KING & QUEEN COUNTY 2018 June KING & QUEEN COUNTY 2018 June KING & QUEEN COUNTY 2018 June KING GEORGE COUNTY 2018 June KING GEORGE COUNTY 2018 June KING GEORGE COUNTY 2018 June KING GEORGE COUNTY 2018 June KING GEORGE COUNTY 2018 June KING GEORGE COUNTY 2018 June KING WILLIAM COUNTY 2018 June KING WILLIAM COUNTY 2018 June KING WILLIAM COUNTY 2018 June KING WILLIAM COUNTY 2018 June KING WILLIAM COUNTY 2018 June KING WILLIAM COUNTY 2018 June KING WILLIAM COUNTY 2018 June LANCASTER COUNTY 2018 June LANCASTER COUNTY 2018 June LANCASTER COUNTY 2018 June LANCASTER COUNTY 2018 June LANCASTER COUNTY 2018 June LANCASTER COUNTY 2018 June LANCASTER COUNTY

407 - LAKEWOOD 408 - LAUDERDALE 409 - MAYBEURY 410 - MOORELAND 411 - PEMBERTON 412 - PINCHBECK 413 - RIDGEFIELD 414 - ROLLINGWOOD 415 - SKIPWITH 416 - SPOTTSWOOD 417 - TUCKAHOE 418 - WELBORNE 419 - WEST END ##Central Absentee 101 - BASSETT NUMBER TWO 102 - GUNVILLE 103 - SCOTT'S TANYARD 201 - FIELDALE 202 - HORSEPASTURE #1 203 - HORSEPASTURE #2 204 - SPENCER 304 - MOUNT OLIVET 401 - COLLINSVILLE NUMBER 1 402 - DANIELS CREEK 404 - COLLINSVILLE NUMBER 2 501 - BASSETT NUMBER ONE 502 - FIGSBORO 503 - STANLEYTOWN 504 - OAK LEVEL 505 - DYERS STORE 601 - FONTAINE 602 - HILLCREST 604 - RIDGEWAY #2 001 - MONTEREY 003 - WILSONS MILL 005 - BLUE GRASS 007 - MILL GAP 008 - MCDOWELL 010 - HEADWATERS ##Central Absentee ##Central Absentee 101 - BERKELEY A 102 - BERKELEY B 103 - BERKELEY C 104- BERKELEY D 201 - JAMESTOWN A 202 - JAMESTOWN B 202 - JAMESTOWN B 203 - JAMESTOWN C 204 - JAMESTOWN D 301 - POWHATAN A 302 - POWHATAN B 303 - POWHATAN C 304 - POWHATAN D 401 - STONEHOUSE A 402 - STONEHOUSE B 403 - STONEHOUSE C 501 - ROBERTS A 502 - ROBERTS B 503 - ROBERTS C 504 - ROBERTS D 504 - ROBERTS D ##Central Absentee 101 - OWENTON 201 - CLARKS 301 - SHACKLEFORDS 401 - COURTHOUSE 501 - OLDMILL ##Central Absentee 101 - COURTHOUSE 102 - PASSAPATANZY 201 - MONROE 301 - DAHLGREN 401 - SHILOH ##Central Absentee 101 - WEST POINT 201 - SWEET HALL 202 - COURTHOUSE 301 - AYLETT 401 - MANQUIN 501 - MANGOHICK ##Central Absentee 101 - PRECINCT 1-1 201 - PRECINCT 2-1 301 - PRECINCT 3-1 302 - PRECINCT 3-2 401 - PRECINCT 4-1 501 - PRECINCT 5-1

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Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 41 of 67 Pageid#: 216

2018 June LEE COUNTY 2018 June LEE COUNTY 2018 June LEE COUNTY 2018 June LEE COUNTY 2018 June LEE COUNTY 2018 June LEE COUNTY 2018 June LEE COUNTY 2018 June LEE COUNTY 2018 June LEE COUNTY 2018 June LEE COUNTY 2018 June LEE COUNTY 2018 June LEE COUNTY 2018 June LEE COUNTY 2018 June LEE COUNTY 2018 June LEE COUNTY 2018 June LEE COUNTY 2018 June LEE COUNTY 2018 June LEXINGTON CITY 2018 June LEXINGTON CITY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY

##Central Absentee 101 - ELYDALE 102 - EWING 103 - ROSE HILL 201 - BLACKWATER 202 - FLATWOODS 203 - JONESVILLE 301 - BEN HUR 302 - WOODWAY 401 - STICKLEYVILLE 402 - JASPER 403 - SEMINARY 404 - DRYDEN 501 - SAINT CHARLES 502 - PENNINGTON 503 - ROBBINS CHAPEL 504 - KEOKEE ##Central Absentee 001 - LEXINGTON ##Central Absentee 107 - LITTLE RIVER 108 - MERCER 112 - FREEDOM 114 - DULLES SOUTH 117 - CARTER 118 - MOOREFIELD 119 - ARCOLA 120 - LUNSFORD 121 - TOWN HALL 122 - HUTCHISON FARM 123 - CARDINAL RIDGE 124 - LIBERTY 125 - ROCK RIDGE 207 - RIVER BEND 208 - ALGONKIAN 209 - POTOMAC FALLS 210 - CASCADES 213 - COUNTRYSIDE 214 - SUGARLAND NORTH 215 - SUGARLAND SOUTH 216 - LOWES ISLAND 217 - SOUTH BANK 218 - UNIVERSITY CENTER 219 - GALILEE CHURCH 301 - PURCELLVILLE 302 - ROUND HILL 303 - HILLSBORO 305 - PHILOMONT 307 - MIDDLEBURG 308 - ST LOUIS 309 - ALDIE 310 - MOUNTAIN VIEW 311 - ROUND HILL ELEMENTARY 312 - BRIAR WOODS 313 - PINEBROOK 314 - LEGACY 315 - FIREHOUSE 316 - CREIGHTON'S CORNER 318 - MADISON'S TRUST 319 - JOHN CHAMPE 320 - STONE HILL 321 - BRAMBLETON MIDDLE 401 - WEST LOVETTSVILLE 402 - WATERFORD 403 - LUCKETTS 407 - HARPER PARK 408 - EVERGREEN 409 - CLARKES GAP 411 - EAST LOVETTSVILLE 413 - TUSCARORA 414 - RED ROCK 416 - HAMILTON 420 - RIVER CREEK 421 - BETWEEN THE HILLS 422 - SYCOLIN CREEK 501 - WEST LEESBURG 502 - EAST LEESBURG 503 - DRY MILL 504 - SMARTS MILL 505 - COOL SPRING 506 - BRANDON PARK 507 - GREENWAY 508 - BALLS BLUFF 509 - TOLBERT 510 - HERITAGE 615 - HILLSIDE 616 - EAGLE RIDGE 617 - OAK GROVE

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Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 42 of 67 Pageid#: 217

2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUDOUN COUNTY 2018 June LOUISA COUNTY 2018 June LOUISA COUNTY 2018 June LOUISA COUNTY 2018 June LOUISA COUNTY 2018 June LOUISA COUNTY 2018 June LOUISA COUNTY 2018 June LOUISA COUNTY 2018 June LOUISA COUNTY 2018 June LOUISA COUNTY 2018 June LOUISA COUNTY 2018 June LOUISA COUNTY 2018 June LOUISA COUNTY 2018 June LOUISA COUNTY 2018 June LOUISA COUNTY 2018 June LOUISA COUNTY 2018 June LOUISA COUNTY 2018 June LYNCHBURG CITY 2018 June LYNCHBURG CITY 2018 June LYNCHBURG CITY 2018 June LYNCHBURG CITY 2018 June LYNCHBURG CITY 2018 June LYNCHBURG CITY 2018 June LYNCHBURG CITY 2018 June LYNCHBURG CITY 2018 June LYNCHBURG CITY 2018 June LYNCHBURG CITY 2018 June LYNCHBURG CITY 2018 June LYNCHBURG CITY 2018 June LYNCHBURG CITY 2018 June LYNCHBURG CITY 2018 June LYNCHBURG CITY 2018 June LYNCHBURG CITY 2018 June LYNCHBURG CITY 2018 June LYNCHBURG CITY 2018 June LYNCHBURG CITY 2018 June MANASSAS CITY 2018 June MANASSAS CITY 2018 June MANASSAS CITY 2018 June MANASSAS CITY 2018 June MANASSAS CITY 2018 June MANASSAS CITY 2018 June MANASSAS CITY 2018 June MANASSAS PARK CITY 2018 June MANASSAS PARK CITY 2018 June MANASSAS PARK CITY 2018 June MANASSAS PARK CITY 2018 June MARTINSVILLE CITY 2018 June MARTINSVILLE CITY 2018 June MARTINSVILLE CITY 2018 June MARTINSVILLE CITY 2018 June MARTINSVILLE CITY 2018 June MARTINSVILLE CITY 2018 June MARTINSVILLE CITY 2018 June MATHEWS COUNTY 2018 June MATHEWS COUNTY 2018 June MATHEWS COUNTY 2018 June MATHEWS COUNTY 2018 June MIDDLESEX COUNTY 2018 June MIDDLESEX COUNTY 2018 June MIDDLESEX COUNTY

619 - RIDGETOP 620 - RUSSELL BRANCH 621 - DOMINION TRAIL 622 - FARMWELL STATION 623 - WELLER 625 - MILL RUN 626 - ASHBY PONDS 627 - ASHBROOK 628 - MOOREFIELD STATION 629 - DISCOVERY 701 - SULLY 702 - PARK VIEW 703 - ROLLING RIDGE 705 - FOREST GROVE 707 - CLAUDE MOORE PARK 708 - SENECA 709 - MIRROR RIDGE 710 - STERLING 808 - STONE BRIDGE 810 - CEDAR LANE 813 - SELDENS LANDING 814 - NEWTON - LEE 815 - BELMONT RIDGE 817 - SANDERS CORNER 818 - BROAD RUN 819 - HERITAGE CHURCH 820 - BELMONT STATION 822 - RIVERSIDE ##Central Absentee 101 - ZION 102 - MECHANICSVILLE 201 - LOUISA #1 202 - LOUISA #2 301 - PATRICK HENRY NO 1 302 - PATRICK HENRY #2 401 - MINERAL 402 - YANCEYVILLE 501 - FREDERICKS HALL 502 - CUCKOO 503 - ELK CREEK 601 - BUMPASS 602 - LOCUST CREEK 701 - SHELTONS MILL 702 - SOUTH ANNA ##Central Absentee 101 - FIRST WARD FIRST PRECINCT 102 - FIRST WARD SECOND PRECINCT 103 - FIRST WARD THIRD PRECINCT 104 - FIRST WARD FOURTH PRECINCT 105 - FIRST WARD FIFTH PRECINCT 201 - SECOND WARD FIRST PRECINCT 202 - SECOND WARD SECOND PRECINCT 203 - SECOND WARD THIRD PRECINCT 204 - SECOND WARD FOURTH PRECINCT 301 - THIRD WARD FIRST PRECINCT 302 - THIRD WARD SECOND PRECINCT 303 - THIRD WARD THIRD PRECINCT 304 - THIRD WARD FOURTH PRECINCT 305 - THIRD WARD FIFTH PRECINCT 401 - FOURTH WARD FIRST PRECINCT 402 - FOURTH WARD SECOND PRECINCT 403 - FOURTH WARD THIRD PRECINCT 404 - FOURTH WARD FOURTH PRECINCT ##Central Absentee 001 - DEAN 002 - WEEMS 003 - METZ 004 - HAYDON 005 - BALDWIN 006 - ROUND ##Central Absentee 001 - PRECINCT ONE 002 - PRECINCT TWO 003 - PRECINCT THREE ##Central Absentee 001 - PRECINCT #1 002 - PRECINCT #2 003 - PRECINCT #3 004 - PRECINCT #4 005 - PRECINCT #5 006 - PRECINCT #6 ##Central Absentee 001 - CHESAPEAKE 002 - WESTVILLE 003 - PIANKATANK ##Central Absentee 101 - SALUDA 102 - URBANNA

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2018 June MIDDLESEX COUNTY 2018 June MIDDLESEX COUNTY 2018 June MIDDLESEX COUNTY 2018 June MIDDLESEX COUNTY 2018 June MONTGOMERY COUNTY 2018 June MONTGOMERY COUNTY 2018 June MONTGOMERY COUNTY 2018 June MONTGOMERY COUNTY 2018 June MONTGOMERY COUNTY 2018 June MONTGOMERY COUNTY 2018 June MONTGOMERY COUNTY 2018 June MONTGOMERY COUNTY 2018 June MONTGOMERY COUNTY 2018 June MONTGOMERY COUNTY 2018 June MONTGOMERY COUNTY 2018 June MONTGOMERY COUNTY 2018 June MONTGOMERY COUNTY 2018 June MONTGOMERY COUNTY 2018 June MONTGOMERY COUNTY 2018 June MONTGOMERY COUNTY 2018 June MONTGOMERY COUNTY 2018 June MONTGOMERY COUNTY 2018 June MONTGOMERY COUNTY 2018 June MONTGOMERY COUNTY 2018 June MONTGOMERY COUNTY 2018 June MONTGOMERY COUNTY 2018 June MONTGOMERY COUNTY 2018 June MONTGOMERY COUNTY 2018 June MONTGOMERY COUNTY 2018 June NEW KENT COUNTY 2018 June NEW KENT COUNTY 2018 June NEW KENT COUNTY 2018 June NEW KENT COUNTY 2018 June NEW KENT COUNTY 2018 June NEW KENT COUNTY 2018 June NEW KENT COUNTY 2018 June NEW KENT COUNTY 2018 June NEW KENT COUNTY 2018 June NEW KENT COUNTY 2018 June NEW KENT COUNTY 2018 June NORFOLK CITY 2018 June NORFOLK CITY 2018 June NORFOLK CITY 2018 June NORFOLK CITY 2018 June NORFOLK CITY 2018 June NORFOLK CITY 2018 June NORFOLK CITY 2018 June NORFOLK CITY 2018 June NORFOLK CITY 2018 June NORFOLK CITY 2018 June NORFOLK CITY 2018 June NORFOLK CITY 2018 June NORFOLK CITY 2018 June NORFOLK CITY 2018 June NORFOLK CITY 2018 June NORFOLK CITY 2018 June NORFOLK CITY 2018 June NORFOLK CITY 2018 June NORFOLK CITY 2018 June NORTHAMPTON COUNTY 2018 June NORTHAMPTON COUNTY 2018 June NORTHAMPTON COUNTY 2018 June NORTHAMPTON COUNTY 2018 June NORTHAMPTON COUNTY 2018 June NORTHAMPTON COUNTY 2018 June NORTHUMBERLAND COUNTY 2018 June NORTHUMBERLAND COUNTY 2018 June NORTHUMBERLAND COUNTY 2018 June NORTHUMBERLAND COUNTY 2018 June NORTHUMBERLAND COUNTY 2018 June NORTHUMBERLAND COUNTY 2018 June NORTHUMBERLAND COUNTY 2018 June NORTON CITY 2018 June NOTTOWAY COUNTY 2018 June NOTTOWAY COUNTY 2018 June NOTTOWAY COUNTY 2018 June NOTTOWAY COUNTY 2018 June NOTTOWAY COUNTY 2018 June NOTTOWAY COUNTY 2018 June NOTTOWAY COUNTY 2018 June NOTTOWAY COUNTY 2018 June NOTTOWAY COUNTY 2018 June NOTTOWAY COUNTY 2018 June ORANGE COUNTY 2018 June ORANGE COUNTY 2018 June ORANGE COUNTY 2018 June ORANGE COUNTY 2018 June ORANGE COUNTY

201 - NEW MARKET 302 - CHURCH VIEW 401- HARMONY VILLAGE 501 - WILTON ##Central Absentee 101 - PRECINCT A-1 102 - PRECINCT A-2 103 - PRECINCT A-3 201 - PRECINCT B-1 202 - PRECINCT B-2 203 - PRECINCT B-3 204 - PRECINCT B-4 301 - PRECINCT C-1 302 - PRECINCT C-2 303 - PRECINCT C-3 304 - PRECINCT C-4 401 - PRECINCT D-1 402 - PRECINCT D-2 403 - PRECINCT D-3 404 - PRECINCT D-4 405 - PRECINCT D-5 501 - PRECINCT E-1 502 - PRECINCT E-2 503 - PRECINCT E-3 601 - PRECINCT F-1 602 - PRECINCT F-2 603 - PRECINCT F-3 701 - PRECINCT G-1 702 - PRECINCT G-2 ##Central Absentee 102 - TUNSTALL 103 - SOUTHERN BRANCH 201 - QUINTON 202 - KENTWOOD 301 - WATKINS 302 - CUMBERLAND 401 - PROVIDENCE FORGE 403 - MOUNTCASTLE 501 - ELTHAM 502 - CHICKAHOMINY RIVER ##Central Absentee 101 - GRANBY 102 - OCEAN VIEW SCHOOL 103 - NORTHSIDE 104 - TITUSTOWN 106 - SECOND PRESBYTERIAN 215 - SUBURBAN PARK 217 - WESLEY 406 - BARRON BLACK 501 - BAYVIEW 503 - EAST OCEAN VIEW 504 - LARRYMORE 505 - LITTLE CREEK 506 - OCEAN VIEW CENTER 507 - PRETLOW 509 - TARRALLTON 510 - THIRD PRESBYTERIAN 511 - CROSSROADS 512 - AZALEA GARDENS ##Central Absentee 101 - PRECINCT 1-1 201 - PRECINCT 2-1 301 - PRECINCT 3-1 401 - PRECINCT 4-1 501 - PRECINCT 5-1 ##Central Absentee 101 - 1A 201 - 2A 301 - 3A 302 - 3B 401 - 4A 501 - 5A 001 - EAST WARD ##Central Absentee 101 - PRECINCT 1-1 102 - PRECINCT 1-2 201 - PRECINCT 2-1 202 - PRECINCT 2-2 301 - PRECINCT 3-1 302 - PRECINCT 3-2 401 - PRECINCT 4-1 402 - PRECINCT 4-2 501 - PRECINCT 5-1 ##Central Absentee 101 - ONE WEST 102 - ONE EAST 201 - TWO WEST 202 - TWO EAST

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Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 44 of 67 Pageid#: 219

2018 June ORANGE COUNTY 2018 June ORANGE COUNTY 2018 June ORANGE COUNTY 2018 June ORANGE COUNTY 2018 June ORANGE COUNTY 2018 June ORANGE COUNTY 2018 June PAGE COUNTY 2018 June PAGE COUNTY 2018 June PAGE COUNTY 2018 June PAGE COUNTY 2018 June PAGE COUNTY 2018 June PAGE COUNTY 2018 June PATRICK COUNTY 2018 June PATRICK COUNTY 2018 June PATRICK COUNTY 2018 June PATRICK COUNTY 2018 June PATRICK COUNTY 2018 June PATRICK COUNTY 2018 June PATRICK COUNTY 2018 June PATRICK COUNTY 2018 June PATRICK COUNTY 2018 June PATRICK COUNTY 2018 June PATRICK COUNTY 2018 June PATRICK COUNTY 2018 June PATRICK COUNTY 2018 June PATRICK COUNTY 2018 June POQUOSON CITY 2018 June POQUOSON CITY 2018 June POQUOSON CITY 2018 June POQUOSON CITY 2018 June POWHATAN COUNTY 2018 June POWHATAN COUNTY 2018 June POWHATAN COUNTY 2018 June POWHATAN COUNTY 2018 June POWHATAN COUNTY 2018 June POWHATAN COUNTY 2018 June POWHATAN COUNTY 2018 June POWHATAN COUNTY 2018 June POWHATAN COUNTY 2018 June POWHATAN COUNTY 2018 June POWHATAN COUNTY 2018 June POWHATAN COUNTY 2018 June POWHATAN COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY

301 - THREE WEST 302 - THREE EAST 401 - FOUR WEST 402 - FOUR EAST 501 - FIVE SOUTH 502 - FIVE NORTH ##Central Absentee 101 - WEST LURAY 201 - EAST LURAY 301 - MARKSVILLE 401 - NEWPORT 501 - SHENANDOAH ##Central Absentee 101 - ARARAT 102 - CLAUDVILLE 103 - WILLIS GAP 201 - DRY POND 202 - PATRICK SPRINGS 203 - RUSSELL CREEK 301 - CRITZ/STELLA 302 - LIBERTY 401 - MEADOWS OF DAN 402 - STUART FAIRGROUNDS 501 - STUART COMMUNITY 502 - ELAMSVILLE 503 - WOOLWINE ##Central Absentee 001 - CENTRAL 002 - EASTERN 003 - WESTERN ##Central Absentee 101 - SUBLETTS 102 - MANAKIN 103 - FLAT ROCK 201 - POWHATAN STATION 202 - GRACELAND 301 - BETHESDA 302 - LEE'S LANDING 401 - POWHATAN COURTHOUSE 402 - MT ZION 501 - SMITH CROSS ROADS 502 - PINEVILLE 503 - TOBACCOVILLE ##Central Absentee ##Central Absentee 101 - BRENTSVILLE 102 - CEDAR POINT 103 - GLENKIRK 104 - NOKESVILLE 105 - LIMESTONE 106 - WESTGATE 107 - MARSTELLER 108 - VICTORY 109 - PINEY BRANCH 110 - BUCKLAND MILLS 110 - BUCKLAND MILLS 111 - BRISTOW RUN 112 - BURKE-NICKENS 112 - BURKE-NICKENS 202 - MARSHALL 203 - BENNETT 204 - ELLIS 205 - BUCKHALL 206 - COLES 207 - SPRIGGS 208 - HYLTON 209 - INDEPENDENT HILL 210 - PENN 211 - SIGNAL HILL 212 - YORKSHIRE 213 - SARATOGA 214 - LUCASVILLE 304 - QUANTICO 305 - PATTIE 306 - WASHINGTON-REID 307 - HENDERSON 308 - MONTCLAIR 309 - ASHLAND 310 - FOREST PARK 312 - TRIANGLE 313 - CARDINAL 314 - CABIN BRANCH 401 - EVERGREEN 402 - BATTLEFIELD 403 - BULL RUN 404 - BEN LOMOND 405 - STONEWALL 406 - ALVEY

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Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 45 of 67 Pageid#: 220

2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PRINCE WILLIAM COUNTY 2018 June PULASKI COUNTY 2018 June PULASKI COUNTY 2018 June PULASKI COUNTY 2018 June PULASKI COUNTY 2018 June PULASKI COUNTY 2018 June PULASKI COUNTY 2018 June PULASKI COUNTY 2018 June PULASKI COUNTY 2018 June PULASKI COUNTY 2018 June PULASKI COUNTY 2018 June PULASKI COUNTY 2018 June PULASKI COUNTY 2018 June PULASKI COUNTY 2018 June RADFORD CITY 2018 June RADFORD CITY 2018 June RADFORD CITY 2018 June RADFORD CITY 2018 June RICHMOND COUNTY 2018 June RICHMOND COUNTY 2018 June RICHMOND COUNTY 2018 June RICHMOND COUNTY 2018 June RICHMOND COUNTY 2018 June RICHMOND COUNTY 2018 June ROANOKE CITY 2018 June ROANOKE CITY 2018 June ROANOKE CITY 2018 June ROANOKE CITY 2018 June ROANOKE CITY 2018 June ROANOKE CITY 2018 June ROANOKE CITY 2018 June ROANOKE CITY 2018 June ROANOKE CITY 2018 June ROANOKE CITY 2018 June ROANOKE CITY 2018 June ROANOKE CITY 2018 June ROANOKE CITY 2018 June ROANOKE CITY 2018 June ROANOKE CITY 2018 June ROANOKE CITY 2018 June ROANOKE CITY 2018 June ROANOKE CITY 2018 June ROANOKE CITY 2018 June ROANOKE CITY 2018 June ROANOKE CITY 2018 June ROANOKE COUNTY 2018 June ROANOKE COUNTY 2018 June ROANOKE COUNTY 2018 June ROANOKE COUNTY 2018 June ROANOKE COUNTY 2018 June ROANOKE COUNTY 2018 June ROANOKE COUNTY 2018 June ROANOKE COUNTY 2018 June ROANOKE COUNTY 2018 June ROANOKE COUNTY 2018 June ROANOKE COUNTY 2018 June ROANOKE COUNTY 2018 June ROANOKE COUNTY 2018 June ROANOKE COUNTY 2018 June ROANOKE COUNTY 2018 June ROANOKE COUNTY 2018 June ROANOKE COUNTY 2018 June ROANOKE COUNTY 2018 June ROANOKE COUNTY 2018 June ROANOKE COUNTY 2018 June ROANOKE COUNTY 2018 June ROANOKE COUNTY 2018 June ROANOKE COUNTY 2018 June ROANOKE COUNTY 2018 June ROANOKE COUNTY 2018 June ROANOKE COUNTY 2018 June ROANOKE COUNTY 2018 June ROANOKE COUNTY 2018 June ROANOKE COUNTY 2018 June ROANOKE COUNTY

407 - HERITAGE HUNT 408 - SUDLEY 409 - TYLER 410 - MOUNTAIN VIEW 411 - MULLEN 412 - CATHARPIN 413 - REAGAN 501 - LAKE RIDGE 505 - MOHICAN 508 - SPRINGWOODS 509 - MC COART 510 - YATES FORD 511 - WESTRIDGE 609 - KING ##Central Absentee 101 - BELSPRING 102 - NEW RIVER 103 - WEST CLOYD 201 - DRAPER 202 - SOUTH PULASKI 203 - NEWBERN 301 - DUBLIN 302 - HIWASSEE 304 - SNOWVILLE 401 - MASSIE 402 - WALKER 501 - ROBINSON ##Central Absentee 001 - EAST PRECINCT 002 - CENTRAL PRECINCT 003 - WEST PRECINCT ##Central Absentee 101 - PRECINCT 1-1 201 - PRECINCT 2-1 301 - PRECINCT 3-1 401 - PRECINCT 4-1 501 - PRECINCT 5-1 ##Central Absentee 001 -Peters Creek 002 - Grandview 003 -Preston Park 004 - Williamson Road 005 - East Gate 006 - Hollins Road 007 - Southeast 008 - Lincoln Terrace 009 - Highland 010 - Old Southwest-Wasena 011 - RALEIGH COURT 012 - SOUTH ROANOKE 013 - GARDEN CITY 014 - Crystal Spring 015 - Grandin Court 016 - Deyerle 017 - LEE-HI 018 - Summit Hills 019 - Forest Park 020 - EUREKA PARK ##Central Absentee ##Central Absentee 101 - CATAWBA 102 - MASON VALLEY 103 - GLENVAR 104 - NORTHSIDE 105 - PETERS CREEK 106 - GREEN HILL 107 - BENNETT SPRINGS 108 - WILDWOOD 201 - PLANTATION 202 - BURLINGTON 203 - MOUNTAIN VIEW 204 - BOTETOURT SPRINGS 205 - ORCHARDS 206 - HOLLINS 301 - BENT MOUNTAIN 302 - POAGES MILL 303 - WINDSOR HILLS 304 - OAK GROVE 305 - CASTLE ROCK 306 - GARST MILL 402 - BONSACK 403 - NORTH VINTON 404 - SOUTH VINTON 405 - LINDENWOOD 406 - MOUNT PLEASANT 501 - COTTON HILL 502 - PENN FOREST 503 - CAVE SPRING

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2018 June ROANOKE COUNTY 2018 June ROANOKE COUNTY 2018 June ROANOKE COUNTY 2018 June ROANOKE COUNTY 2018 June ROCKBRIDGE COUNTY 2018 June ROCKBRIDGE COUNTY 2018 June ROCKBRIDGE COUNTY 2018 June ROCKBRIDGE COUNTY 2018 June ROCKBRIDGE COUNTY 2018 June ROCKBRIDGE COUNTY 2018 June ROCKBRIDGE COUNTY 2018 June ROCKBRIDGE COUNTY 2018 June ROCKBRIDGE COUNTY 2018 June ROCKBRIDGE COUNTY 2018 June ROCKBRIDGE COUNTY 2018 June ROCKBRIDGE COUNTY 2018 June ROCKBRIDGE COUNTY 2018 June ROCKBRIDGE COUNTY 2018 June ROCKBRIDGE COUNTY 2018 June ROCKBRIDGE COUNTY 2018 June ROCKBRIDGE COUNTY 2018 June ROCKBRIDGE COUNTY 2018 June ROCKINGHAM COUNTY 2018 June ROCKINGHAM COUNTY 2018 June ROCKINGHAM COUNTY 2018 June ROCKINGHAM COUNTY 2018 June ROCKINGHAM COUNTY 2018 June ROCKINGHAM COUNTY 2018 June ROCKINGHAM COUNTY 2018 June ROCKINGHAM COUNTY 2018 June ROCKINGHAM COUNTY 2018 June ROCKINGHAM COUNTY 2018 June ROCKINGHAM COUNTY 2018 June ROCKINGHAM COUNTY 2018 June ROCKINGHAM COUNTY 2018 June ROCKINGHAM COUNTY 2018 June ROCKINGHAM COUNTY 2018 June ROCKINGHAM COUNTY 2018 June ROCKINGHAM COUNTY 2018 June ROCKINGHAM COUNTY 2018 June ROCKINGHAM COUNTY 2018 June ROCKINGHAM COUNTY 2018 June ROCKINGHAM COUNTY 2018 June ROCKINGHAM COUNTY 2018 June ROCKINGHAM COUNTY 2018 June ROCKINGHAM COUNTY 2018 June ROCKINGHAM COUNTY 2018 June ROCKINGHAM COUNTY 2018 June ROCKINGHAM COUNTY 2018 June ROCKINGHAM COUNTY 2018 June ROCKINGHAM COUNTY 2018 June ROCKINGHAM COUNTY 2018 June ROCKINGHAM COUNTY 2018 June RUSSELL COUNTY 2018 June RUSSELL COUNTY 2018 June RUSSELL COUNTY 2018 June RUSSELL COUNTY 2018 June RUSSELL COUNTY 2018 June RUSSELL COUNTY 2018 June RUSSELL COUNTY 2018 June RUSSELL COUNTY 2018 June RUSSELL COUNTY 2018 June RUSSELL COUNTY 2018 June RUSSELL COUNTY 2018 June RUSSELL COUNTY 2018 June RUSSELL COUNTY 2018 June RUSSELL COUNTY 2018 June RUSSELL COUNTY 2018 June RUSSELL COUNTY 2018 June SALEM CITY 2018 June SALEM CITY 2018 June SALEM CITY 2018 June SALEM CITY 2018 June SALEM CITY 2018 June SALEM CITY 2018 June SALEM CITY 2018 June SALEM CITY 2018 June SALEM CITY 2018 June SALEM CITY 2018 June SALEM CITY 2018 June SCOTT COUNTY 2018 June SCOTT COUNTY 2018 June SCOTT COUNTY 2018 June SCOTT COUNTY 2018 June SCOTT COUNTY 2018 June SCOTT COUNTY 2018 June SCOTT COUNTY 2018 June SCOTT COUNTY

504 - OGDEN 505 - CLEARBROOK 506 - MOUNT VERNON 507 - HUNTING HILLS ##Central Absentee 101 - AIRPORT 102 - BEN SALEM 103 - PLANK ROAD 104 - EFFINGER 201 - COLLIERSTOWN 202 - HIGHLAND BELLE 203 - VO-TECH 301 - MAURY RIVER 302 - NATURAL BRIDGE 303 - FALLING SPRING 401 - FAIRFIELD 402 - MOUNTAIN VIEW 403 - VESUVIUS 501 - GOSHEN 502 - MEADOWVIEW 503 - ROCKBRIDGE BATHS 504 - ROCKBRIDGE ##Central Absentee 101 - BROADWAY 102 - TIMBERVILLE 103 - FULKS RUN 104 - BERGTON 105 - LACEY SPRING 106 - TENTH LEGION 107 - PLAINS 108 - LITTLE NORTH MOUNTAIN 201 - SINGERS GLEN 202 - EDOM 203 - DAYTON 204 - MT CLINTON 205 - SILVER LAKE 301 - KEEZLETOWN 302 - PORT REPUBLIC 303 - MELROSE 304 - GROTTOES 305 - MASSANETTA SPRINGS 306 - CROSS KEYS 307 - CROSSROADS 401 - BRIDGEWATER 402 - MONTEZUMA 403 - MT CRAWFORD 404 - NORTH RIVER 405 - OTTOBINE 501 - ELKTON 502 - SWIFT RUN 503 - MCGAHEYSVILLE 504 - SOUTH FORK 505 - STONY RUN ##Central Absentee 101 - MOCCASIN 102 - COPPER CREEK 103 - SOUTH CASTLEWOOD 201 - NORTH CASTLEWOOD 202 - DANTE 301 - COOKS MILL 302 - DAUGHERTY 303 - NEW GARDEN 304 - CLEVELAND 401 - DRILL 402 - SWORDS CREEK 403 - HONAKER 501 - WEST LEBANON 601 - EAST LEBANON 602 - ELK GARDEN ##Central Absentee 001 - NORTH SALEM NO 2 002 - CONEHURST 003 - BEVERLY HEIGHTS 004 - WEST SALEM 005 - NORTH SALEM NO 1 006 - SOUTH SALEM NO 1 007 - SOUTH SALEM NO 2 008 - EAST SALEM 009 - SOUTH SIDE HILLS 010 - HIDDEN VALLEY ##Central Absentee 101 - WEBER CITY 102 - YUMA 202 - WEBER CITY EAST 203 - HILTONS 204 - CLARK'S 301 - NICKELSVILLE 302 - SNOWFLAKE

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3

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15

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2018 June SCOTT COUNTY 2018 June SCOTT COUNTY 2018 June SCOTT COUNTY 2018 June SCOTT COUNTY 2018 June SCOTT COUNTY 2018 June SCOTT COUNTY 2018 June SCOTT COUNTY 2018 June SCOTT COUNTY 2018 June SCOTT COUNTY 2018 June SCOTT COUNTY 2018 June SHENANDOAH COUNTY 2018 June SHENANDOAH COUNTY 2018 June SHENANDOAH COUNTY 2018 June SHENANDOAH COUNTY 2018 June SHENANDOAH COUNTY 2018 June SHENANDOAH COUNTY 2018 June SHENANDOAH COUNTY 2018 June SHENANDOAH COUNTY 2018 June SHENANDOAH COUNTY 2018 June SHENANDOAH COUNTY 2018 June SHENANDOAH COUNTY 2018 June SHENANDOAH COUNTY 2018 June SHENANDOAH COUNTY 2018 June SMYTH COUNTY 2018 June SMYTH COUNTY 2018 June SMYTH COUNTY 2018 June SMYTH COUNTY 2018 June SMYTH COUNTY 2018 June SMYTH COUNTY 2018 June SMYTH COUNTY 2018 June SMYTH COUNTY 2018 June SMYTH COUNTY 2018 June SMYTH COUNTY 2018 June SMYTH COUNTY 2018 June SMYTH COUNTY 2018 June SMYTH COUNTY 2018 June SMYTH COUNTY 2018 June SMYTH COUNTY 2018 June SPOTSYLVANIA COUNTY 2018 June SPOTSYLVANIA COUNTY 2018 June SPOTSYLVANIA COUNTY 2018 June SPOTSYLVANIA COUNTY 2018 June SPOTSYLVANIA COUNTY 2018 June SPOTSYLVANIA COUNTY 2018 June SPOTSYLVANIA COUNTY 2018 June SPOTSYLVANIA COUNTY 2018 June SPOTSYLVANIA COUNTY 2018 June SPOTSYLVANIA COUNTY 2018 June SPOTSYLVANIA COUNTY 2018 June SPOTSYLVANIA COUNTY 2018 June SPOTSYLVANIA COUNTY 2018 June SPOTSYLVANIA COUNTY 2018 June SPOTSYLVANIA COUNTY 2018 June SPOTSYLVANIA COUNTY 2018 June SPOTSYLVANIA COUNTY 2018 June SPOTSYLVANIA COUNTY 2018 June SPOTSYLVANIA COUNTY 2018 June SPOTSYLVANIA COUNTY 2018 June SPOTSYLVANIA COUNTY 2018 June SPOTSYLVANIA COUNTY 2018 June SPOTSYLVANIA COUNTY 2018 June SPOTSYLVANIA COUNTY 2018 June SPOTSYLVANIA COUNTY 2018 June SPOTSYLVANIA COUNTY 2018 June SPOTSYLVANIA COUNTY 2018 June SPOTSYLVANIA COUNTY 2018 June SPOTSYLVANIA COUNTY 2018 June SPOTSYLVANIA COUNTY 2018 June SPOTSYLVANIA COUNTY 2018 June SPOTSYLVANIA COUNTY 2018 June SPOTSYLVANIA COUNTY 2018 June STAFFORD COUNTY 2018 June STAFFORD COUNTY 2018 June STAFFORD COUNTY 2018 June STAFFORD COUNTY 2018 June STAFFORD COUNTY 2018 June STAFFORD COUNTY 2018 June STAFFORD COUNTY 2018 June STAFFORD COUNTY 2018 June STAFFORD COUNTY 2018 June STAFFORD COUNTY 2018 June STAFFORD COUNTY 2018 June STAFFORD COUNTY 2018 June STAFFORD COUNTY 2018 June STAFFORD COUNTY 2018 June STAFFORD COUNTY 2018 June STAFFORD COUNTY 2018 June STAFFORD COUNTY

303 - TWIN SPRINGS 304 - COPPER CREEK 401 - GATE CITY 501 - DUNGANNON 502 - FORT BLACKMORE 503 - MANVILLE 504 - RYE COVE 601 - CLINCHPORT 602 - DUFFIELD-PATTONSVILLE 603 - FAIRVIEW ##Central Absentee 101 - ORKNEY SPRINGS 103 - NEW MARKET 201 - CONICVILLE 202 - MT JACKSON 302 - EDINBURG 303 - ST LUKE 304 - FORT VALLEY 401 - WOODSTOCK 501 - CEDAR CREEK 503 - TOMS BROOK 504 - LEBANON CHURCH 601 - STRASBURG ##Central Absentee 101 - SALTVILLE 201 - SEVEN MILE FORD 202 - RICH VALLEY 301 - CHILHOWIE 302 - ST CLAIR 401 - EAST PARK 402 - WEST PARK 501 - ATKINS 502 - WASSONA 601 - ROYAL OAK EAST 602 - ROYAL OAK WEST 701 - ADWOLFE 702 - SUGAR GROVE 703 - KONNAROCK ##Central Absentee ##Central Absentee 101 - PARTLOW 102 - BLAYDES CORNER 103 - TRAVELERS REST 103 - TRAVELERS REST 104 - MASSAPONAX 201 - WILDERNESS SCHOOL 202 - WILDERNESS FIRE 203 - NI RIVER / ELYS FORD 204 - CHANCELLOR 301 - PLANK ROAD 302 - HAZEL RUN 303 - RIVERBEND 401 - SUMMIT 402 - PARKSIDE 402 - PARKSIDE 403 - LEE HILL 501 - BELMONT 502 - BROKENBURG 503 - POST OAK 504 - COURTHOUSE 505 - BROCK 601 - SALEM 602 - SMITH STATION 603 - PIEDMONT 701 - BATTLEFIELD 702 - BRENTS MILL 702 - BRENTS MILL 703 - FAIRVIEW 703 - FAIRVIEW 704 - GAYLE 704 - GAYLE ##Central Absentee 101 - HARTWOOD 102 - ROCKY RUN 103 - SIMPSON 104 - COLLEGE 201 - ROCK HILL 202 - ROSEVILLE 203 - RUBY 204 - STEFANIGA 301 - GRIFFIS 302 - WIDEWATER 303 - HARBOUR 304 - BARRETT 401 - AQUIA 402 - COURTHOUSE 403 - BROOKE 404 - GOVERNMENT ISLAND

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139

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134

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2018 June STAFFORD COUNTY 2018 June STAFFORD COUNTY 2018 June STAFFORD COUNTY 2018 June STAFFORD COUNTY 2018 June STAFFORD COUNTY 2018 June STAFFORD COUNTY 2018 June STAFFORD COUNTY 2018 June STAFFORD COUNTY 2018 June STAFFORD COUNTY 2018 June STAFFORD COUNTY 2018 June STAFFORD COUNTY 2018 June STAUNTON CITY 2018 June STAUNTON CITY 2018 June STAUNTON CITY 2018 June STAUNTON CITY 2018 June STAUNTON CITY 2018 June STAUNTON CITY 2018 June TAZEWELL COUNTY 2018 June TAZEWELL COUNTY 2018 June TAZEWELL COUNTY 2018 June TAZEWELL COUNTY 2018 June TAZEWELL COUNTY 2018 June TAZEWELL COUNTY 2018 June TAZEWELL COUNTY 2018 June TAZEWELL COUNTY 2018 June TAZEWELL COUNTY 2018 June TAZEWELL COUNTY 2018 June TAZEWELL COUNTY 2018 June TAZEWELL COUNTY 2018 June TAZEWELL COUNTY 2018 June TAZEWELL COUNTY 2018 June TAZEWELL COUNTY 2018 June TAZEWELL COUNTY 2018 June TAZEWELL COUNTY 2018 June TAZEWELL COUNTY 2018 June TAZEWELL COUNTY 2018 June TAZEWELL COUNTY 2018 June TAZEWELL COUNTY 2018 June TAZEWELL COUNTY 2018 June TAZEWELL COUNTY 2018 June TAZEWELL COUNTY 2018 June TAZEWELL COUNTY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY

501 - GRAFTON 502 - FALMOUTH 503 - DREW 504 - GAYLE 601 - FERRY FARM 602 - CHATHAM 603 - WHITE OAK 604 - ENGLAND RUN 701 - WOODLANDS 702 - WHITSON 703 - HAMPTON ##Central Absentee 101 - WARD NO 1 201 - WARD NO 2 301 - WARD NO 3 401 - WARD NO 4 501 - WARD NO 5 ##Central Absentee 101 - ABBS VALLEY 102 - TIP TOP 103 - BOISSEVAIN 104 - FALLS MILLS 106 - POCAHONTAS 107 - AMONATE 109 - BISHOP 110 - ADRIA 111 - GAP STORE 112 - BANDY 203 - BURKES GARDEN 204 - CLEAR FORK 207 - FREESTONE 209 - JEFFERSONVILLE 214 - THOMPSON VALLEY 301 - CEDAR BLUFF 302 - BAPTIST VALLEY 303 - WARDELL 305 - POUNDING MILL 401 - RICHLANDS 402 - JEWELL RIDGE 404 - RAVEN 501 - SPRINGVILLE 502 - GRAHAM ##Central Absentee 001 - NORTH BEACH 002 - SOUTH BEACH 003 - OCEAN LAKES 004 - LINKHORN 005 - SEATACK 006 - ALANTON 007 - KINGSTON 008 - LONDON BRIDGE 009 - TRANTWOOD 010 - GREAT NECK 011 - CAPE HENRY 012 - PLAZA 013 - MT TRASHMORE 014 - MALIBU 015 - OLD DONATION 016 - ARAGONA 017 - OCEAN PARK 018 - THOROUGHGOOD 019 - LAKE SMITH 020 - BAYSIDE 021 - DAVIS CORNER 022 - POINT O VIEW 023 - ARROWHEAD 024 - LARKSPUR 025 - AVALON 026 - FAIRFIELD 027 - EDWIN 028 - THALIA 029 - HOLLAND 030 - RED WING 031 - SIGMA 032 - CREEDS 033 - CAPPS SHOP 034 - BLACKWATER 035 - COURTHOUSE 036 - WINDSOR OAKS 037 - CHESAPEAKE BEACH 038 - WITCHDUCK 039 - PEMBROKE 040 - BONNEY 041 - COLLEGE PARK 042 - BRANDON 043 - BELLAMY 044 - CENTERVILLE 045 - TIMBERLAKE

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189

Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 49 of 67 Pageid#: 224

2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June VIRGINIA BEACH CITY 2018 June WARREN COUNTY 2018 June WARREN COUNTY 2018 June WARREN COUNTY 2018 June WARREN COUNTY 2018 June WARREN COUNTY 2018 June WARREN COUNTY 2018 June WARREN COUNTY 2018 June WARREN COUNTY 2018 June WARREN COUNTY 2018 June WARREN COUNTY 2018 June WARREN COUNTY 2018 June WARREN COUNTY 2018 June WASHINGTON COUNTY 2018 June WASHINGTON COUNTY 2018 June WASHINGTON COUNTY 2018 June WASHINGTON COUNTY 2018 June WASHINGTON COUNTY 2018 June WASHINGTON COUNTY 2018 June WASHINGTON COUNTY 2018 June WASHINGTON COUNTY 2018 June WASHINGTON COUNTY 2018 June WASHINGTON COUNTY 2018 June WASHINGTON COUNTY 2018 June WASHINGTON COUNTY 2018 June WASHINGTON COUNTY 2018 June WASHINGTON COUNTY 2018 June WASHINGTON COUNTY 2018 June WASHINGTON COUNTY 2018 June WASHINGTON COUNTY 2018 June WASHINGTON COUNTY 2018 June WASHINGTON COUNTY 2018 June WASHINGTON COUNTY 2018 June WAYNESBORO CITY

046 - GREEN RUN 047 - KINGS GRANT 048 - WOLFSNARE 049 - LYNNHAVEN 050 - OCEANA 051 - STRATFORD CHASE 052 - HOMESTEAD 053 - SHANNON 054 - CROMWELL 055 - MAGIC HOLLOW 056 - EDINBURGH 057 - SHERRY PARK 058 - GLENWOOD 059 - SHELTON PARK 060 - FOXFIRE 061 - BAKER 062 - LANDSTOWN 063 - CULVER 064 - ROSEMONT FOREST 065 - COLONIAL 066 - HUNT 067 - EASTERN SHORE 068 - MANOR 069 - SHELL 070 - CORPORATE LANDING 071 - ROUND HILL 072 - RUDEE 073 - DAHLIA 074 - BUCKNER 075 - COLONY 076 - VILLAGE 077 - BROOKWOOD 078 - INDIAN LAKES 079 - PLEASANT HALL 080 - CHIMNEY HILL 081 - ROCK LAKE 082 - SHELBURNE 083 - STRAWBRIDGE 084 - TALLWOOD 085 - UPTON 086 - HAYGOOD 087 - HILLCREST 088 - NORTH LANDING 089 - LAKE CHRISTOPHER 090 - LAKE JOYCE 091 - LEXINGTON 092 - LITTLE NECK 093 - NEWTOWN 094 - PINEWOOD 095 - DAM NECK 096 - HILLTOP 097 - INDIAN RIVER 098 - INDEPENDENCE 099 - SALEM WOODS 100 - SANDBRIDGE ##Central Absentee 101 - FORK TOWN 102 - OTTERBURN 201 - HAPPY CREEK 202 - LINDEN 301 - NORTH RIVER 302 - RIVERTON 401 - EAST SHENANDOAH 402 - TOWN - WEST SHENANDOAH 501 - SOUTH RIVER 502 - BENTONVILLE 504 - BROWNTOWN ##Central Absentee 101 - EAST ABINGDON 102 - WEST ABINGDON 201 - CLINCHBURG 202 - GREENDALE 203 - HAYTERS GAP 204 WOODLAND HILLS 301 - WATAUGA 302 - SOUTH ABINGDON 401 - GLADE SPRING 402 - MEADOWVIEW 501 - RHEA VALLEY 502 - DAMASCUS 504 - GREEN COVE 601 - BURSON PLACE 602 - MENDOTA 603 - VALLEY INSTITUTE 701 - HIGH POINT 702 - WALLACE 703 - JOHN BATTLE ##Central Absentee

0

0

109

0

0

273

0

0

200

0

0

231

0

0

102

0

0

167

0

0

264

0

0

192

0

0

158

0

0

171

0

0

101

0

0

102

2

0

206

0

0

117

0

0

180

0

0

171

1

0

186

0

0

187

0

0

191

0

0

149

0

0

142

0

0

77

0

0

169

0

0

220

0

0

127

0

0

102

0

0

170

0

0

188

0

0

144

2

0

208

0

0

133

0

0

153

0

0

159

0

0

162

0

0

180

0

0

224

0

0

125

0

0

135

0

0

163

0

0

169

0

0

221

0

0

170

0

0

111

0

0

198

0

0

114

0

0

219

0

0

137

0

0

184

0

0

89

0

0

86

0

0

104

0

0

159

0

0

106

0

0

84

0

0

76

0

42

0

0

0

53

0

0

106

0

0

78

0

0

101

0

0

77

0

0

63

0

0

115

0

0

34

0

0

110

0

0

31

0

0

51

0

102

0

0

0

215

0

0

130

0

0

26

0

0

31

0

0

18

0

0

61

0

0

108

0

0

187

0

0

49

0

0

112

0

0

54

0

0

62

0

0

6

0

0

32

0

0

13

0

0

38

0

0

40

0

0

25

0

0

51

0

18

0

2

109

3

273

2

200

4

231

1

102

0

167

7

264

4

192

0

158

0

171

0

101

0

102

0

208

0

117

0

180

3

171

1

187

1

187

3

191

0

149

3

142

0

77

2

169

10

220

1

127

0

102

0

170

5

188

1

144

1

210

2

133

4

153

0

159

1

162

1

180

2

224

1

125

0

135

1

163

0

169

3

221

0

170

0

111

0

198

0

114

5

219

0

137

5

184

1

89

0

86

1

104

2

159

0

106

0

84

0

76

1

42

0

53

0

106

0

78

0

101

0

77

1

63

0

115

0

34

2

110

0

31

0

51

0

102

0

215

0

130

0

26

1

31

0

18

0

61

0

108

0

187

0

49

0

112

0

54

0

62

0

6

0

32

0

13

0

38

0

40

0

25

1

51

0

18

Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 50 of 67 Pageid#: 225

2018 June WAYNESBORO CITY 2018 June WAYNESBORO CITY 2018 June WAYNESBORO CITY 2018 June WAYNESBORO CITY 2018 June WESTMORELAND COUNTY 2018 June WESTMORELAND COUNTY 2018 June WESTMORELAND COUNTY 2018 June WESTMORELAND COUNTY 2018 June WESTMORELAND COUNTY 2018 June WESTMORELAND COUNTY 2018 June WESTMORELAND COUNTY 2018 June WESTMORELAND COUNTY 2018 June WESTMORELAND COUNTY 2018 June WILLIAMSBURG CITY 2018 June WILLIAMSBURG CITY 2018 June WILLIAMSBURG CITY 2018 June WINCHESTER CITY 2018 June WINCHESTER CITY 2018 June WINCHESTER CITY 2018 June WINCHESTER CITY 2018 June WINCHESTER CITY 2018 June WINCHESTER CITY 2018 June WINCHESTER CITY 2018 June WISE COUNTY 2018 June WISE COUNTY 2018 June WISE COUNTY 2018 June WISE COUNTY 2018 June WISE COUNTY 2018 June WISE COUNTY 2018 June WISE COUNTY 2018 June WISE COUNTY 2018 June WISE COUNTY 2018 June WISE COUNTY 2018 June WISE COUNTY 2018 June WISE COUNTY 2018 June WISE COUNTY 2018 June WYTHE COUNTY 2018 June WYTHE COUNTY 2018 June WYTHE COUNTY 2018 June WYTHE COUNTY 2018 June WYTHE COUNTY 2018 June WYTHE COUNTY 2018 June WYTHE COUNTY 2018 June WYTHE COUNTY 2018 June WYTHE COUNTY 2018 June WYTHE COUNTY 2018 June WYTHE COUNTY 2018 June WYTHE COUNTY 2018 June YORK COUNTY 2018 June YORK COUNTY 2018 June YORK COUNTY 2018 June YORK COUNTY 2018 June YORK COUNTY 2018 June YORK COUNTY 2018 June YORK COUNTY 2018 June YORK COUNTY 2018 June YORK COUNTY 2018 June YORK COUNTY 2018 June YORK COUNTY 2018 June YORK COUNTY 2018 June YORK COUNTY 2018 June YORK COUNTY Total

001 - WARD A 002 - WARD B 003 - WARD C 004 - WARD D ##Central Absentee 101 - PRECINCT 1-1 102 - PRECINCT 1-2 201 - PRECINCT 2-1 202 - PRECINCT 2-2 301 - PRECINCT 3-1 302 - PRECINCT 3-2 401 - PRECINCT 4-1 501 - PRECINCT 5-1 ##Central Absentee 001 - STRYKER 002 - MATOAKA ##Central Absentee 101 - MERRIMANS 102 - OLD TOWN 201 - VIRGINIA AVENUE 301 - WAR MEMORIAL 401 - FREDERICK DOUGLASS 402 - ROLLING HILLS ##Central Absentee 101 - APPALACHIA 102 - DORCHESTER 103 - GUEST RIVER VOTING PLACE 104 - WEST POUND 201 - NORTH COEBURN 202 - WISE 203 - EAST POUND 301 - BIG STONE GAP 302 - EAST STONE GAP 401 - CLINCH VALLEY 402 - SOUTH COEBURN 403 - ST PAUL ##Central Absentee 101 - ROYAL OAK 102 - RURAL RETREAT 203 - WEST WYTHEVILLE 303 - EAST WYTHEVILLE 401 - FORT CHISWELL 402 - MAX MEADOWS 501 - JACKSON MEMORIAL 502 - SHEFFEY 601 - HUDDLE 602 - ZION 603 EVERGREEN ##Central Absentee 101 - QUEENS LAKE 102 - WALLER MILL 103 - MAGRUDER 201 - COVENTRY 202 - KILN CREEK 301 - SEAFORD 302 - YORKTOWN 303 - EDGEHILL 401 - HARWOODS MILL 402 - DARE 403 - GRAFTON 501 - TABB 502 - BETHEL

0

0

61

0

0

197

0

0

127

0

0

204

0

39

0

0

0

101

0

0

43

0

0

88

0

0

42

0

0

67

0

0

73

0

0

63

0

0

114

0

126

0

0

0

498

2

0

369

0

121

0

0

0

459

0

0

273

1

0

255

0

0

198

0

0

93

0

0

205

0

23

14

0

0

31

0

0

23

0

0

9

0

0

36

0

0

12

0

0

70

0

0

7

0

0

72

0

0

50

0

0

31

0

0

15

0

0

21

0

6

0

0

0

3

0

0

26

0

0

75

0

0

109

0

0

16

0

0

27

0

0

10

0

0

21

0

0

10

0

0

24

0

0

13

0

88

0

0

0

229

1

0

227

0

0

426

0

0

249

0

0

127

0

0

142

0

0

195

0

0

170

0

0

186

0

0

148

0

0

112

0

0

196

0

0

244

0

61

0

197

0

127

0

204

0

39

0

101

0

43

0

88

0

42

0

67

0

73

0

63

0

114

0

126

4

498

0

371

0

121

0

459

0

273

1

256

0

198

0

93

1

205

0

37

0

31

0

23

0

9

0

36

0

12

0

70

0

7

0

72

0

50

0

31

0

15

0

21

0

6

0

3

0

26

0

75

0

109

0

16

0

27

0

10

0

21

0

10

0

24

0

13

0

88

1

229

0

228

4

426

0

249

0

127

0

142

1

195

0

170

0

186

0

148

0

112

0

196

0

244

220087

Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 51 of 67 Pageid#: 226
EXHIBIT D
1Jirginia: 3Jn tbt Ol:irmtt Q!:ourt of tbt Q!:itp of .i\itbmonb, Jabn Jllarsball Qtourts ~uilbtng

OMARI FAULKNER FOR VIRGINIA,

)

OMARI FAULKNER,

)

)

Plaintiffs,

)

)

v.

)

)

VIRGINIA DEPARTMENT OF ELECTIONS, )

VIRGNIS STATE BOARD OF ELECTIONS, )

ROBERT H. BRINK,

)

JOHN O'BANNON,

)

JAMILAH D. LECRUISE,

)

CHRISTOPHER E. PIPER,

)

JESSICA BOWMAN,

)

THE REPUBLICAN PARTY OF VIRGINIA )

JACK R. WILSON

)

)

Defendants.

)

Case No.: CL 20-1456

ORDER
On March 25, 2020, the parties appeared, represented by Counsel via telephone conference, on Plaintiffs Emergency Motion for Preliminary Injunction. The Republican Party ofVirginia and the Commonwealth Defendants have taken no position on the relief sought in the preliminary injunction. However, Gade for Virginia, Inc. filed a Motion for Intervention, which was granted, and they also filed a response opposing the relief sought in the preliminary injunction.
In Virginia, in order for a Court to grant a preliminary injunction, the party seeking the injunction must establish they would "suffer irreparable harm without the injunction, and that the party has no adequate remedy at al." May v. R.A. Yancey Lumber Corp., 297 Va. 1, 17-18 (2019). Beyond this showing, ''granting or denying a temporary injunction is a discretionary act arising
from the court's equitable powers." Id. Accordingly, courts across the Commonwealth have applied a balancing test similar to that articulated federally in Winlers v. Nat 'I Res. Def Council, Inc., 555 U.S. 7, 20 (2008). Namely, courts evaluate (1) the likelihood of success on the merits,

Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 52 of 67 Pageid#: 227
(2) the likelihood of irreparable hann, (3) the balance of the equities, and (4) the public interest in issuing the injunction.
In evaluating the likelihood of success on the merits to this as-applied challenge to Va. Code§ 24.2-521(1), we must consider the burden placed on the Plaintiff by the statute. "The right to vote is a 'precious' and 'fundamental' right." Florida Democratic Party v. Scott, 215 F.Supp.3d 1250, 1256 (2016). Additionally, the "freedom to associate with others for the common advancement of political beliefs and ideas is a fonn of 'orderly group activity' protected by the First and Fourteenth Amendments. The right to associate with the political party of one's choice is integral part ofthis basic constitutional freedom." Kusper v. Pontikes, 414 U.S. 51, 56-57 (1973). However, because the regulation of the time, place, and manner of elections is vested with the states, a "more flexible standard" is required when evaluating those regulations. See Burdick v. Taskushi, 504 U.S. 428, 434 (1992). Specifically, "courts considering a challenge to state election laws 'must weigh the character and magnitude of the asserted injury to the rights protected by the First and Fourteenth Amendments that the plaintiff seeks to vindicate against the precise interests put fonvard by the State as justifications for the burden imposed by its rule, taking into consideration the extent to which those interests make it necessary to burden the plaintiffs rights."' Florida Democratic Party, 215 F.Supp.3d at 1256 (quoting Burdick, 504 U.S. at 434). As a preliminary matter, there has been no "precise interest[] put forward by the State" in this case. Id.
In normal circumstances, a signature requirement in order for an individual to be placed on the ballot is a light burden. See New York State Board ofElections v. Lopez Torres, 552 U.S. 196 (2008); see also Norman v. Reed, 502 U.S. 279 (1992). However, the circumstances as they exist in the Commonwealth ofVirginia and across the United States are not normal right now. On March 12, 2020, Governor Northman declared a state of emergency for the Commonwealth pursuant to Va. Code§ 44-146.13 et seq. in response to the continued spread of COVID-19. Executive Order Number Fifty-One (Northam) (2020). This declaration was clarified by guidance issued on March 17, 2020 which prohibited the non-essential gathering of more than ten people in any one location at any time. Press Release, Office of the Governor, Governor Northam Announces New Measures to Combat COVID-19 and Support Impacted Virginians (March 17, 2020). Under these circumstances, and as applied to the Plaintiff, and necessarily to all other Republican candidates for the 2020 primary election ballot for U.S. Senate in Virginia, the burden imposed by Va. Code

Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 53 of 67 Pageid#: 228
§ 24.2-521 ( 1) is significant, as it precludes them from freely associating at the highest level with the political party of their choice.
Therefore, at this time, the regulation imposed by Va. Code§ 24.2-521(1) is subject to strict scrutiny in order to satisfy the constitutional analysis. Meaning that the "regulation must be narrowly drawn to advance a state interest of compelling importance." Norman, 502 U.S. at 289. In their Response to the Plaintiffs' Emergency Motion for Preliminary Injunction, the Commonwealth articulates no precise interest supporting the application of this regulation in this circumstance. In fact, they neither consent nor object to the relief requested by the Plaintiff. Therefore, the Court has nothing to weigh against "the character and magnitude of the asserted injury to the rights protected by the First and Fourteenth Amendment." See Florida Democratic Party, 215 F.Supp.3d at 1256 (quoting Burdick, 504 U.S. at 434). Even were the Court to evaluate an interest in promoting the just and fair administration of primary elections, or providing "equal access to all citizens" as the Intervenor suggests, and assuming those interests are compelling, the regulation is not narrowly tailored to advance those interests as it does not provide for emergency circumstances, like those that currently exist.
Accordingly, the Court hereby FINDS that the regulation in Va. Code§ 24.2-521(1) as it applies to the Plaintiff, and necessarily to all other Republican candidates for the 2020 primary election ballot for U.S. Senate in Virginia under these circumstances fails constitutional analysis under strict scrutiny. Thus, the Plaintiff has a considerable likelihood of success on the merits.
Further, this Court FINDS that there is a likelihood of irreparable harm to Plaintiffs constitutional rights jf his name were omitted from the ballot because of the application of Va. Code§ 24.2-521 (1 ). Further, Plaintiff would be limited in his ability to engage in political dialogue or debate at the elevated level in which he seeks to engage in such discussion. Additionally, as the Commonwealth has not articulated any interest in support of the application of Va. Code § 24.2521 (1) to Republican candidates for the 2020 primary election ballot for U.S. Senate in Virginia under these circumstances, and Plaintiff has articulated a significant interest in Va. Code § 24.2521(1) not being applied to Republican candidates for the 2020 primary election ballot for U.S. Senate in Virginia under these circumstances, the Court FINDS that the balance of equities tips in favor of the Plaintiff. Furthermore, the Court FINDS that reasonable and educated debate among all candidates for office advances the political conversation, promoting the public interest as it does so.

Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 54 of 67 Pageid#: 229
Therefore, the Court FINDS that Plaintiff has established a likelihood of success on the merits, there is no other adequate remedy available at law, and the equities tip in favor of the Plaintiffs Emergency Motion for Preliminary Injunction. Thus, the Court GRANTS the Emergency Motion for Preliminary Injunction. Specifically, Plaintiff has requested the Defendants allow his qualification for the Republican Primary ballot for U.S. Senate in the Commonwealth with no fewer than a total of 3,500 valid signatures with no fewer than 100 signatures in each and every congressional district. While the Court is not qualified to articulate the number ofsignatures that should be required in order for an individual to appear on a ballot, the Plaintiff has articulated the above figures and the Commonwealth has not objected to those figures. Therefore, the Court accepts those numbers and thereby ORDERS that Defendants allow the qualification of Republican candidates for the 2020 primary election ballot for U.S. Senate in Virginia with no fewer than 3,500 valid signatures and no fewer than 100 signatures in each and every congressional district.
This Order applies to the Plaintiff, and all Republican candidates for the 2020 primary election ballot for U.S. Senate in Virginia because the burden of the statute's eligibility requirements are equally injurious to Plaintiff and all other Republican candidates for the 2020 primary election, and the State Board of Elections is tasked with aiding local election boards and registrars in obtaining "uniformity in their practices and proceedings." Va. Code§ 24.2-103. The Commonwealth did not object in their pleading or at oral argument to the broader application of the Court's ruling to all other Republican candidates. However, while the interest of maintaining such uniformity in ballot access procedures is an important interest, neither the Democratic Party, nor any other party holding a 2020 primary election, was noticed or served with the Verified Complaint or any other pleadings herein. Accordingly, the interests of those parties have not been adequately represented before the Court. Thus, the Court must limit its ruling to the Plaintiff and other Republican candidates for the 2020 primary election as those are the only individual's whose interests are before the Court.
The Plaintiffs Motion for Attorneys' Fees is CONTINUED pending further submissions by Counsel.
Pursuant to Rule 1: 13 of the Supreme Court of Virginia, the Court dispenses with the parties' endorsement of this Order. The Court NOTES the objections of the Intervening Party.
The Clerk is directed to forward a certified copy of this Order to the parties.

Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 55 of 67 Pageid#: 230
It is so ORDERED.
ENTER: ] I J\'i J oJ..d

Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 56 of 67 Pageid#: 231

EXHIBIT E

FIPSCode Jurisdiction_Name 5100100000 ACCOMACK COUNTY 5100300000 ALBEMARLE COUNTY 5100500000 ALLEGHANY COUNTY 5100700000 AMELIA COUNTY 5100900000 AMHERST COUNTY 5101100000 APPOMATTOX COUNTY 5101300000 ARLINGTON COUNTY 5101500000 AUGUSTA COUNTY 5101700000 BATH COUNTY 5101900000 BEDFORD COUNTY 5102100000 BLAND COUNTY 5102300000 BOTETOURT COUNTY 5102500000 BRUNSWICK COUNTY 5102700000 BUCHANAN COUNTY 5102900000 BUCKINGHAM COUNTY 5103100000 CAMPBELL COUNTY 5103300000 CAROLINE COUNTY 5103500000 CARROLL COUNTY 5103600000 CHARLES CITY COUNTY 5103700000 CHARLOTTE COUNTY 5104100000 CHESTERFIELD COUNTY 5104300000 CLARKE COUNTY 5104500000 CRAIG COUNTY 5104700000 CULPEPER COUNTY 5104900000 CUMBERLAND COUNTY 5105100000 DICKENSON COUNTY 5105300000 DINWIDDIE COUNTY 5105700000 ESSEX COUNTY 5105900000 FAIRFAX COUNTY 5106100000 FAUQUIER COUNTY 5106300000 FLOYD COUNTY 5106500000 FLUVANNA COUNTY 5106700000 FRANKLIN COUNTY 5106900000 FREDERICK COUNTY 5107100000 GILES COUNTY 5107300000 GLOUCESTER COUNTY 5107500000 GOOCHLAND COUNTY 5107700000 GRAYSON COUNTY 5107900000 GREENE COUNTY 5108100000 GREENSVILLE COUNTY 5108300000 HALIFAX COUNTY 5108500000 HANOVER COUNTY 5108700000 HENRICO COUNTY 5108900000 HENRY COUNTY 5109100000 HIGHLAND COUNTY 5109300000 ISLE OF WIGHT COUNTY 5109500000 JAMES CITY COUNTY 5109700000 KING & QUEEN COUNTY 5109900000 KING GEORGE COUNTY 5110100000 KING WILLIAM COUNTY 5110300000 LANCASTER COUNTY 5110500000 LEE COUNTY 5110700000 LOUDOUN COUNTY 5110900000 LOUISA COUNTY 5111100000 LUNENBURG COUNTY 5111300000 MADISON COUNTY 5111500000 MATHEWS COUNTY 5111700000 MECKLENBURG COUNTY 5111900000 MIDDLESEX COUNTY 5112100000 MONTGOMERY COUNTY 5112500000 NELSON COUNTY 5112700000 NEW KENT COUNTY 5113100000 NORTHAMPTON COUNTY 5113300000 NORTHUMBERLAND COUNTY 5113500000 NOTTOWAY COUNTY 5113700000 ORANGE COUNTY 5113900000 PAGE COUNTY 5114100000 PATRICK COUNTY 5114300000 PITTSYLVANIA COUNTY 5114500000 POWHATAN COUNTY

State_Abbr Total Mail ballots received Mail ballots rejected lack of witness sig

VA

713

0

VA

2786

16

VA

85

0

VA

140

0

VA

9

0

VA

113

0

VA

1838

25

VA

661

0

VA

33

0

VA

1165

0

VA

30

0

VA

416

0

VA

1

0

VA

208

0

VA

199

2

VA

492

1

VA

284

0

VA

246

1

VA

154

1

VA

108

0

VA

6319

16

VA

245

3

VA

42

0

VA

614

0

VA

156

0

VA

135

1

VA

288

0

VA

117

0

VA

7285

89

VA

262

12

VA

210

0

VA

597

0

VA

700

9

VA

1136

2

VA

151

2

VA

409

9

VA

572

0

VA

175

0

VA

245

3

VA

108

0

VA

290

0

VA

636

1

VA

5386

19

VA

329

0

VA

23

0

VA

445

0

VA

1812

0

VA

67

1

VA

309

0

VA

146

0

VA

199

0

VA

173

0

VA

9963

19

VA

560

4

VA

185

0

VA

149

0

VA

136

2

VA

361

8

VA

141

0

VA

1172

0

VA

289

0

VA

346

3

VA

236

3

VA

235

2

VA

101

0

VA

573

7

VA

227

0

VA

159

0

VA

458

0

VA

425

0

Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 57 of 67 Pageid#: 232

5114700000 PRINCE EDWARD COUNTY

VA

223

0

5114900000 PRINCE GEORGE COUNTY

VA

355

0

5115300000 PRINCE WILLIAM COUNTY

VA

3981

35

5115500000 PULASKI COUNTY

VA

279

5

5115700000 RAPPAHANNOCK COUNTY

VA

155

0

5115900000 RICHMOND COUNTY

VA

61

0

5116100000 ROANOKE COUNTY

VA

1413

0

5116300000 ROCKBRIDGE COUNTY

VA

293

0

5116500000 ROCKINGHAM COUNTY

VA

815

0

5116700000 RUSSELL COUNTY

VA

223

0

5116900000 SCOTT COUNTY

VA

101

0

5117100000 SHENANDOAH COUNTY

VA

384

0

5117300000 SMYTH COUNTY

VA

190

0

5117500000 SOUTHAMPTON COUNTY

VA

109

0

5117700000 SPOTSYLVANIA COUNTY

VA

2120

0

5117900000 STAFFORD COUNTY

VA

2152

9

5118100000 SURRY COUNTY

VA

144

1

5118300000 SUSSEX COUNTY

VA

86

0

5118500000 TAZEWELL COUNTY

VA

417

7

5118700000 WARREN COUNTY

VA

400

0

5119100000 WASHINGTON COUNTY

VA

561

8

5119300000 WESTMORELAND COUNTY

VA

161

0

5119500000 WISE COUNTY

VA

257

8

5119700000 WYTHE COUNTY

VA

238

0

5119900000 YORK COUNTY

VA

1375

7

5151000000 ALEXANDRIA CITY

VA

3573

16

5152000000 BRISTOL CITY

VA

119

0

5153000000 BUENA VISTA CITY

VA

51

0

5154000000 CHARLOTTESVILLE CITY

VA

1064

0

5155000000 CHESAPEAKE CITY

VA

2850

34

5157000000 COLONIAL HEIGHTS CITY

VA

185

0

5158000000 COVINGTON CITY

VA

25

0

5159000000 DANVILLE CITY

VA

412

8

5159500000 EMPORIA CITY

VA

37

0

5160000000 FAIRFAX CITY

VA

531

4

5161000000 FALLS CHURCH CITY

VA

415

1

5162000000 FRANKLIN CITY

VA

43

0

5163000000 FREDERICKSBURG CITY

VA

387

0

5164000000 GALAX CITY

VA

54

1

5165000000 HAMPTON CITY

VA

1327

16

5166000000 HARRISONBURG CITY

VA

402

0

5167000000 HOPEWELL CITY

VA

8

0

5167800000 LEXINGTON CITY

VA

127

1

5168000000 LYNCHBURG CITY

VA

880

4

5168300000 MANASSAS CITY

VA

408

1

5168500000 MANASSAS PARK CITY

VA

160

1

5169000000 MARTINSVILLE CITY

VA

125

0

5170000000 NEWPORT NEWS CITY

VA

1450

12

5171000000 NORFOLK CITY

VA

2565

38

5172000000 NORTON CITY

VA

88

0

5173000000 PETERSBURG CITY

VA

615

0

5173500000 POQUOSON CITY

VA

190

0

5174000000 PORTSMOUTH CITY

VA

869

19

5175000000 RADFORD CITY

VA

121

0

5176000000 RICHMOND CITY

VA

3343

44

5177000000 ROANOKE CITY

VA

1150

9

5177500000 SALEM CITY

VA

297

0

5179000000 STAUNTON CITY

VA

369

5

5180000000 SUFFOLK CITY

VA

1329

0

5181000000 VIRGINIA BEACH CITY

VA

4887

22

5182000000 WAYNESBORO CITY

VA

227

0

5183000000 WILLIAMSBURG CITY

VA

234

0

5184000000 WINCHESTER CITY

VA

358

6

Total

102746

583

Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 58 of 67 Pageid#: 233
EXHIBIT F

March 30, 2020

COMMISSIONERS JOHN WELLS Chairperson CLIFFORD J. EDLER SCOTT MOSELEY VACANT VACANT
MARCI ANDINO Executive Director
1122 Lady Street Suite 500 Columbia, SC 29201 P.O. Box 5987 Columbia, SC 29250 803.734.9060 Fax: 803.734.9366 www.scvotes.org

Honorable Henry D. McMaster Governor State of South Carolina State House 1100 Gervais Street Columbia, SC 29201
Honorable Harvey Peeler, Jr. President of the Senate S.C. Senate POB 142 Columbia, SC 29202
Honorable Jay Lucas Speaker of the House S.C. House of Representatives POB 11867 Columbia, SC 29202
Dear Governor McMaster, Senator Peeler and Speaker Lucas:
As the state’s chief election agency, the State Election Commission (SEC) is charged by law with supervising the conduct of voter registration and elections throughout the State. This includes ensuring county boards of voter registration and elections comply with federal law, state law, and SEC policies and procedures with regards to voter registration and elections. The SEC also maintains the statewide voter registration system, approves and supports the statewide voting system, conducts a training and certification program for local election officials, conducts candidate filing, and provides a candidate tracking system. However, no provision of state law provides the SEC with emergency powers with regards to the conduct of elections.
As the coronavirus continues to spread across South Carolina and the country, we are concerned about the safe conduct of the June Primaries, November General Election and all other elections scheduled for 2020. The main issue is that our elections, as currently prescribed by law, require large numbers of people to congregate in one place – something that everyone is currently being asked not to do by public safety and health officials. Compounding the issue is the fact that a large percentage of the state’s poll managers fall into high risk categories, which

Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 59 of 67 Pageid#: 234
Governor McMaster, Senator Peeler and Speaker Lucas Page 2
would likely lead to a deficit in the number of managers needed to staff polling places. Furthermore, we anticipate county election officials will likely experience issues with the availability of polling places as well as securing alternative polling places. It is likely that a number of facilities (schools, churches, etc.) will decline to continue being used as a polling place.
As currently defined by state law, voters have two options for casting a ballot: 1) in person at their polling place on election day, or 2) in person or by mail absentee voting. Election day voters at the polls present their identification, sign the poll list, and cast their ballot. To cast an absentee ballot, a voter with a qualifying reason must first request, complete, and return an application for an absentee ballot. The voter will then either vote in person or receive an absentee ballot by mail.
In order to safely and securely conduct elections during and following the coronavirus pandemic, we respectfully ask that sincere consideration be given to making emergency changes to our election process. There is no single or easy solution to protecting more than three million voters and election workers during or following a pandemic. The options outlined below represent proven methods used in other states to conduct elections. Some of the options would require careful planning and implementation, while others are easier to implement in a short timeframe.
• Absentee voting o Allow no excuse absentee voting o Allow applications for absentee ballots to be submitted electronically o Remove the witness requirement on ballot return envelopes o Allow voters with disabilities to use our existing electronic ballot delivery tool o Allow first responders and medical personnel to use our existing electronic ballot delivery tool
• Early voting and vote centers • Vote by mail
Absentee Voting
As voters look for ways to safely cast a ballot, we expect voters will likely avoid polling places and seek to vote absentee by mail. To qualify to vote absentee, the voter must fall into one of 18 categories, none of which include self-isolating due to a pandemic. Removing the requirement that a voter must fall into one of these

Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 60 of 67 Pageid#: 235
Governor McMaster, Senator Peeler and Speaker Lucas Page 3
categories, i.e. “no excuse” absentee voting, would open the absentee process to all South Carolinians.
To vote absentee, a voter must first request an application. Usually, the application is mailed to the voter, the voter then completes it and returns it to election officials. This process is time consuming and is not designed to accommodate large numbers of voters. Allowing voters to submit absentee ballots requests online would streamline the absentee voting process for voters and election officials. Voters would simply apply online and receive their ballot in the mail.
Absentee voting also requires voters to have another person witness their signature when returning their ballot. While election officials check the voter’s signature, the witness signature offers no benefit to election officials as they have no ability to verify the witness signature. Removing the requirement for a witness signature would remove a barrier many voters would likely encounter while in self-isolation.
Under current law, military and overseas citizens can access their ballot online through the SEC’s ballot delivery tool, mark it, print it and return it to election officials by mail, email or fax. Voters in these categories do not have to wait for their ballot to be sent to them and have additional options in returning their ballots. Like military and overseas citizens, first responders, medical personnel and voters with disabilities face unique barriers to accessing traditional voting methods. Expanding electronic ballot delivery and return to include these groups would help ensure they have access to the voting process.
Early Voting and Vote Centers
Early voting is the process by which any voter can vote during a defined period prior to election day. Early voting can take place in designated early vote centers. The goal of early voting is to relieve congestion at polling places on election day by spreading out the voting process and to increase participation by providing voters with additional voting options. Early voting is currently used in 40 states.
Vote by Mail
In most states that have enacted vote by mail, all registered voters are mailed a ballot prior to every election. The voter then mails the ballot back to election officials or drops the ballot off at a designated drop-off site. Some in-person voting locations would likely still be needed, particularly for voters who need the accessibility features of the ballot-marking devices.

Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 61 of 67 Pageid#: 236
Governor McMaster, Senator Peeler and Speaker Lucas Page 4
Even before the coronavirus pandemic, elections officials were challenged with a significant increase in the number of absentee ballots. To reduce the burden, a bill (S867) was introduced to allow county election officials to begin the lengthy process of opening absentee ballots the day before the election. The bill also requires challenges of in-person absentee voters be made at the time the voter casts their ballot. These changes are designed to ensure election officials have the requisite time to process absentee ballots and deliver results on election night as voters expect. Facing an even larger increases in absentee voting due to coronavirus, the changes in this bill are now even more relevant and desperately needed. In fact, when the bill was written, the coronavirus was not a consideration, and the extra 24 hours provided to process ballots will now likely be insufficient. The bill has passed the Senate and resides in the House Election Laws Subcommittee. We ask the General Assembly to at least pass the current bill and to consider amending the bill to allow election officials to begin processing ballots even earlier.
These potential solutions to conducting safe and secure elections in the midst of a pandemic are put forth in the spirit of identifying solutions that will enable the voters of South Carolina to continue to express their will through elections. Allowing no-excuse absentee voting and online absentee requests are relatively simple changes, while implementation of early voting or vote by mail options are significantly more complicated and will require more time to implement. With that in mind, we respectfully ask that any actions under consideration be made as soon as possible so election officials have to as much time as possible to ensure South Carolina is ready for this year’s elections.
Sincerely,
Marci Andino
/mba
Cc: Senator Hugh Leatherman, President Pro Tempore Emeritus Senator A. Shane Massey, Senate Majority Leader Senator Nikki G. Setzler, Senate Minority Leader Senator Luke Rankin, Chairman, Senate Judiciary Representative Thomas E. Pope, House Speaker Pro Tempore Representative J. Gary Simrill, House Majority Leader Representative J. Todd Rutherford, House Minority Leader Representative Peter McCoy, Chairman, House Judiciary Representative G. Murrell Smith, Jr., Chairman House Ways and Means

Case 6:20-cv-00024-NKM Document 17-3 Filed 04/21/20 Page 62 of 67 Pageid#: 237
EXHIBIT G

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Case 6:20-cv-00024-NKM Document 17-4 Filed 04/21/20 Page 1 of 3 Pageid#: 243

UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA
Lynchburg Division

LEAGUE OF WOMEN VOTERS OF

VIRGINIA;

KATHERINE

D.

CROWLEY; ERIKKA GOFF; and

SEIJRA TOOGOOD,

Plaintiffs,

v.

VIRGINIA STATE BOARD OF ELECTIONS; ROBERT H. BRINK, JOHN O’BANNON, and JAMILAH D. LECRUISE, in their official capacities as Chairman, Vice-Chair, and Secretary of the Virginia State Board of Elections, respectively; and CHRISTOPHER E. PIPER, in his official capacity as Commissioner of the Virginia Department of Elections,

Defendants.

Case No.: 6:20-cv-00024-NKM

DECLARATION OF ERIKKA GOFF (pursuant to 28 U.S.C. § 1746)
My name is Erikka Goff. I am over the age of 18 and fully competent to make this declaration. Under penalty of perjury, I declare the following based upon my personal knowledge:
1. I currently live in Scottsville, Virginia, in the 24590 zip code. I am a registered voter at my current address.
2. I have lived in Virginia for 17 years. I attended the University of Virginia twice for graduate school. I have lived in Scottsville for 12 years.
3. I live in Virginia’s Fifth Congressional district where I am represented in

Case 6:20-cv-00024-NKM Document 17-4 Filed 04/21/20 Page 2 of 3 Pageid#: 244
Congress by Denver Riggleman. I understand that there is a Democratic primary for that congressional seat on June 23, 2020, and I wish to vote in the primary.
4. I have been a registered voter since I turned 18 and have voted in virtually every state and federal election in which I have been able to vote. Voting and political participation are a core part of my values. I have volunteered for several years for groups that register voters and that help people with criminal convictions get their voting rights restored.
5. Since approximately March 13, 2020, I have been following public health recommendations and orders from the Governor to stay at home except for groceries, exercise, and other necessities. I live by myself and I have practiced social distancing since mid-March. I have avoided being physically within six feet of anyone, and I have used extra protections, such as gloves and a mask, at the grocery store.
6. I am practicing social distancing and staying at home not only because of public health guidance and government orders, but also because I am concerned about contracting COVID-19. My neighbors were sick with symptoms consistent with COVID-19 in mid-March and I am worried about contracting it as well.
7. My town of Scottsville is holding local elections on May 5, 2020, although I understand that the date of these elections may be moved to November 3, 2020. Although I generally vote in person, because of the COVID-19 outbreak I wanted to vote an absentee ballot by mail. I also received a letter and postcard in the mail from my registrar encouraging me to vote an absentee ballot.
8. I submitted an absentee ballot application and received my absentee ballot on March 27, 2020. I realized then that I needed to have a witness watch me mark and reseal ballot, and then sign the ballot envelope, and that I would have to violate social distancing practices and
2

Case 6:20-cv-00024-NKM Document 17-4 Filed 04/21/20 Page 3 of 3 Pageid#: 245
expose myself to another person outside my home in order to vote or have my ballot counted. 9. On March 30, 2020, the same day that Governor Northam announced a stay-at-
home order across Virginia, I called my local registrar to ask if I would need to comply with the requirement. The registrar connected me to the Department of Elections’ phone number in Richmond. I was unable to speak to someone at the Department of Elections but requested a call back on their automated phone system. I have not heard back.
10. I had planned to vote in the June 23 primary, but because of the health risks of going to the polls, I would like to vote by absentee ballot.
11. Because of the continuing transmission of COVID-19 and the serious health risks it poses, I do not wish to risk having another individual witness my ballot. If the need for a witness for my absentee ballot continues for the May election or the June primary, I will not risk my health by voting despite my strong desire to participate in the election.
I declare under penalty of perjury that the foregoing is true and correct. Executed on April 20, 2020 _____________________________________ Erikka Goff
3

Case 6:20-cv-00024-NKM Document 17-5 Filed 04/21/20 Page 1 of 4 Pageid#: 246

UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA
Lynchburg Division

LEAGUE OF WOMEN VOTERS OF

VIRGINIA;

KATHERINE

D.

CROWLEY; ERIKKA GOFF; and

SEIJRA TOOGOOD,

Plaintiffs,

v.

VIRGINIA STATE BOARD OF ELECTIONS; ROBERT H. BRINK, JOHN O’BANNON, and JAMILAH D. LECRUISE, in their official capacities as Chairman, Vice-Chair, and Secretary of the Virginia State Board of Elections, respectively; and CHRISTOPHER E. PIPER, in his official capacity as Commissioner of the Virginia Department of Elections,

Defendants.

Case No.: 6:20-cv-00024-NKM

DECLARATION OF SEIJRA TOOGOOD (pursuant to 28 U.S.C. § 1746)
My name is Seijra Toogood. I am over the age of 18 and fully competent to make this declaration. Under penalty of perjury, I declare the following based upon my personal knowledge:
1. I currently live in Fairfax, Virginia, in the 22030 zip code, and I work as a speech language pathologist for the Fairfax County Public School system. I am a registered voter at my current address.
2. I have lived in Virginia for the vast majority of my life and I graduated from both high school and college here.

Case 6:20-cv-00024-NKM Document 17-5 Filed 04/21/20 Page 2 of 4 Pageid#: 247
3. I live in Virginia’s Eleventh Congressional district where I am represented in Congress by Gerry Connolly. I understand that there is a Democratic primary for that congressional seat on June 23, 2020, and I wish to vote in the primary. I cannot think of the last federal or state election in which I have not voted, as voting and political participation are a core part of my values.
4. Since early March, I have been following public health recommendations and orders from the Governor to stay at home except for necessities. Because I live by myself, I do not believe I have not physically come within six feet of anyone since early March.
5. I am practicing social distancing and staying at home not only because of public health guidance and government orders, but also because I am truly concerned about contracting COVID-19. While I understand that anyone can contract COVID-19, experience health issues from it, and potentially die from it, I believe I am at particular risk for serious complications from COVID-19 because of two underlying medical conditions.
6. Specifically, I have asthma and a heart condition called postural orthostatic tachycardia syndrome (POTS). With this condition, I have difficulty recovering fully from viral illnesses, serious infections, and medical illnesses. What would take someone with a cold a week to recover typically takes me three. I suffer from low blood pressure and a high heart rate, regular dizziness and lightheadedness especially in standing up and from prolonged standing in one position, frequent exhaustion and fatigue, temperature deregulation (hot or cold), and exercise intolerance. My understanding is that both asthma and POTS may increase my risk of serious complications to a disease like COVID-19.
7. As an African-American woman, I am also aware of the higher rates of both contracting and experiencing serious complications and death from COVID-19 that African
2

Case 6:20-cv-00024-NKM Document 17-5 Filed 04/21/20 Page 3 of 4 Pageid#: 248 Americans are experiencing. This makes me particularly concerned about the virus and determined to practice social distancing.
8. I want to vote in the June 23 primary, but because of the health risks in going to the polls, I planned to vote by absentee ballot and have already submitted an online request for my ballot. After learning that I must have someone else witness me remove the ballot from the envelope and then that person must sign my ballot envelope, I now realize I will have to violate social distancing practices and expose myself to another person outside my home in order to vote or have my ballot counted.
9. Because of the continuing transmission of COVID-19 and the serious health risks I will face if I contract it, I cannot risk having another individual witness my ballot. If the need for a witness for my absentee ballot continues for the June primary, I will not risk my health by voting despite my strong desire to participate in the election.
3

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Case 6:20-cv-00024-NKM Document 17-6 Filed 04/21/20 Page 1 of 5 Pageid#: 250

UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA
Lynchburg Division

LEAGUE OF WOMEN VOTERS ET AL.,

)

)

Plaintiffs,

)

)

v.

)

)

VIRGINIA STATE BOARD OF ELECTIONS, )

ET. AL.

)

)

Defendants.

)

Case No. 6:20-cv-00024-NKM

DECLARATION OF DEBORA WAKE I, Debora Wake, hereby declare as follows: 1. I am the President of the League of Women Voters of Virginia (“LWV-VA”), a role which I assumed on July 1, 2019. As President of LWV-VA, I am responsible for, among other things, [overseeing the activities, membership, and events of LWV-VA, and directing its advocacy and voter outreach efforts]. 2. LWV-VA is a nonpartisan membership organization with a membership of nearly 2,000 people, and 14 local leagues across Virginia. LWV-VA works to encourage informed and active participation in government, and influence public policy through education and advocacy. 3. To meet these objectives, LWV-VA undertakes a number of activities related to voter registration including: organizing and running voter registration drives at high schools, colleges, libraries, farmers markers, assisted living centers, and various public events; designing and executing public information campaigns using press releases and social media about how to register and update one’s voter registration; creating brochures about voter registration and topics such as absentee voting; and assisting voters who ask questions about voting through email, occasional telephone hotlines, and through our internet platforms.
Page 1 of 5

Case 6:20-cv-00024-NKM Document 17-6 Filed 04/21/20 Page 2 of 5 Pageid#: 251
4. LWV-VA also conducts various voter mobilization and education activities including hosting candidate forums, developing voter guides, and conducting get-out-the-vote efforts. LWV-VA also educates voters about new laws, and plans to spend significant resources to educate voters this year about several laws passed this year by the Virginia General Assembly and signed into law by the Governor, including as they relate to absentee voting.
5. LWV-VA conducts voter registration, voter mobilization, and voter education efforts regularly, and these efforts require significant volunteer hours and other resources, particularly during the current global health crisis. Because of the crisis and the accompanying stay-at-home orders and social distancing recommendations, LWV-VA has been devoting significant resources toward adapting many of its voter registration and voter outreach activities such that they can be performed remotely or without relying on in-person interactions. For example, we have been expanding the use of flyers and emails to contact outreach, holding meetings online, and at least one local league of LWV-VA was able to hold a municipal candidate forum online.
6. One of the issues that has grown in importance since the beginning of this crisis is the need for strong protections for absentee voters, who will likely make up a much larger share of the electorate than in past elections. LWV-VA has been advocating for increased voting flexibility including the expanded use of absentee voting by mail in order to protect the safety and health of voters and poll workers during the COVID-19 pandemic. One aspect of the absentee balloting process that LWV-VA believes will pose a significant problem for voters in upcoming elections is the requirement that absentee voters have a witness watch them open, mark, and reseal their ballot, and then sign the ballot envelope.
Page 2 of 5

Case 6:20-cv-00024-NKM Document 17-6 Filed 04/21/20 Page 3 of 5 Pageid#: 252
7. Based on conversations and communication with other League members, I expect that this witness requirement will be a major barrier to voting for some League members and Virginia voters in general, and that many of them will be disenfranchised as a result of this requirement. For example, I am aware of the following LWV-VA members who are regular voters and will face difficulties complying with the witness requirement in upcoming elections:
a. Pat McGrady lives in a senior retirement community in Springfield, Virginia. She is 84 years old and has asthma, making her particularly vulnerable to the novel coronavirus. She lives alone and has not been outside of her apartment or had anyone come inside since the beginning of April, when Governor Northam’s administration asked everyone to stay at home. She hopes to vote an absentee ballot in the June primary for Virginia’s Eleventh congressional district and any future elections where COVID-19 transmission is still occurring but does not want to leave her apartment and does not believe she has any way to comply with the witness requirement without endangering herself.
b. Anne Claar is the Treasurer of the League of Women Voters of the Charlottesville area, one of LWV-VA’s local leagues. She lives alone and in recent months was hospitalized with a serious illness. That illness, and its long recovery period, makes her very careful about limiting exposure to other persons to avoid any possible contagion. She hopes to vote an absentee ballot in the June primary for Virginia’s Fifth congressional district but would find it very difficult to comply with the witness requirement without endangering herself or her friends and neighbors.
Page 3 of 5

Case 6:20-cv-00024-NKM Document 17-6 Filed 04/21/20 Page 4 of 5 Pageid#: 253
c. Joan Porte is the First Vice President of LWV-VA, and the President of the League of Women Voters of Arlington, a local league of LWV-VA. She lives alone and has been practicing social distancing in accordance with the Governor’s stay-at-home order and the recommendations of health officials. Ms. Porte hopes to vote an absentee ballot in the June primary for the Arlington County Board, but would find it exceedingly difficult to comply with the witness requirement.
d. Laura Lawson of Alexandria, Virginia, lives in Goodwin House, a retirement community with many active voters residing in a mix of living options including independent living, assisted living, and a health care center. The community requires all residents to maintain physical distance from one another and not to gather in groups, and residents in the assisted living facility and the health care center may not interact with one another or with those, like Ms. Lawson, in independent living. If COVID-19 community transmission is still occurring in the fall, she plans to vote by absentee ballot in the general election and believes that she and other residents of her community will find it exceedingly difficult to comply with the witness requirement without endangering their health.
8. I am also personally aware of other Virginia voters who are not members of LWV-VA but who will face difficulties voting in upcoming elections. For example, I spoke with a voter who is 67 years old, lives alone, has a compromised immune system, and is observing social distancing. She does not have anyone to witness her signature and feels that inviting someone to do so would jeopardize her health. She lives in the Williamsburg area and is hoping to vote absentee in the June primary. I spoke with another voter from Norfolk, Virginia, who is in her 60s, lives alone, and who is complying with social distancing recommendations. She has
Page 4 of 5

Case 6:20-cv-00024-NKM Document 17-6 Filed 04/21/20 Page 5 of 5 Pageid#: 254

not left her house except for a daily walk in over a month. She has already obtained an absentee ballot for the May general election and has never failed to vote as an adult. She has been in a quandary about how to comply with the witness requirement and is unsure whether she will take the risk to comply. I expect that there are many other voters such as these who are served by the LWV-VA and its members and will face significant burdens complying with the witness requirement and that many will be disenfranchised should it remain.
9. Because the witness requirement remains in effect, the LWV-VA has already
diverted and will need to continue to divert resources from its voter registration, voter education,
and voter mobilization activities to advocating against and educating voters about the witness requirement, to prevent the requirement from disenfranchising its members and the voters they
serve. If absentee voters were not required to have someone witness and sign their absentee ballot, LWV-VA could spend less of its volunteer resources and time on educating voters about
the witness requirement, and more on its other cntical activities including registering voters without being able to conduct in-person registration drives and educating voters about the many new laws passed by the 2020 General Assembly.

Pursuant to 28 U.S.C. $ 1746, I declare under penalty of perjury, under the laws of the United
States, that the foregoing is true and correct to the best of my knowledge.

Dated this 20th day of Apr 11,2020.

Or*., /rA/
Debora Wake

Page 5 of5

 </s> Case 6:20-cv-00024-NKM Document 22 Filed 04/23/20 Page 1 of 3 Pageid#: 264

United States District Court for the Western District of Virginia
Lynchburg Division

League of Women Voters of Virginia; Katherine D. Crowley; Erikka Goff; and Seijra Toogood,,

Plaintiffs,

v.

Civ. No. 6:20-cv-00024

Virginia State Board of Elections; Robert H. Brink, John O’Bannon, and Jamilah D. Lecruise, in their official capacities as Chairman, Vice-Chair, and Secretary of the Virginia State Board of Elections, respectively; and Christopher E. Piper, in his official capacity as Commissioner of the Virginia Department Of Elections,

Motion to Intervene

Defendants.

MOTION TO INTERVENE
Pursuant to Fed. R. Civ. P. 24, Sheila DeLappe Ferguson, Sandy Burchett, and Diane Crickenberger (collectively “the Voters”) move to intervene as Defendants to Plaintiffs’ Complaint for Injunctive and Declaratory Relief:
Virginia law requires that absentee voters, inter alia, open and mark their ballots in the presence of a witness. Va. Code § 24.2-707(A). And that voters enclose their ballots in the provided envelope, seal the envelope, and “fill in and sign the statement printed on the back of the envelope in the presence of a witness, who shall sign the same envelope[.]” Id. Plaintiffs seek to eliminate these witness requirements.
The requested relief violates Voters’ fundamental right to vote. Specifically, the requested relief violates: (1) controlling legislation and strips vital safeguards against voting fraud, (2) the right to vote under the Purcell principle, and (3) the Voters’ right to have, and to

Case 6:20-cv-00024-NKM Document 22 Filed 04/23/20 Page 2 of 3 Pageid#: 265

vote in, federal elections with the manner of election is chosen by the legislature (U.S. Const. art

I, § 4, cl. 1). Accordingly, Voters seek intervention to defend that right.

This Motion is made in a timely manner, less than one week after the filing of Plaintiffs’

Complaint. Fed. R. Civ. P. 24(a)-(b). It is accompanied by an Answer to Plaintiffs’ Complaint.

Id. at (c). And this Motion, and the accompanying Brief in Support of Motion to Intervene, state

the grounds for intervention. Id.

For the reason listed in this Motion and the Voters’ Brief in Support of Motion to

Intervene, the Voters respectfully request that this Court grant their request to intervene as

Defendants in this action.

Date: April 23, 2020

Respectfully Submitted,

_____________/s/___________ Bradley P. Marrs (VSB#25281) Patrick C. Henry II (VSB#80468) Marrs & Henry 7202 Glen Forest Drive, Suite 307 Richmond, VA 23226 (804) 662-5715 (804) 662-5712 (fax) bmarrs@marrs-henry.com phenry@marrs-henry.com Local Counsel for Proposed Intervenors

James Bopp, Jr.* IN Atty. No. 2838-84
Courtney Turner Milbank* IN Atty. No. 32178-29
True the Vote, Inc. Voters’ Rights Initiative
THE BOPP LAW FIRM, PC 1 South Sixth St. Terre Haute, IN 47807-3510 Telephone: (812) 232-2434 E-mails: jboppjr@aol.com,
cmilbank@bopplaw.com Lead Counsel for Proposed Intervenors * Pro Hac Vice Pending

Case 6:20-cv-00024-NKM Document 22 Filed 04/23/20 Page 3 of 3 Pageid#: 266

Certificate of Service

I hereby certify that the foregoing document was served electronically on April 23, 2020,

upon the following counsel via the United States District Court for the Western District of

Virginia, electronic filing system:

Vishal Mahendra Agraharkarvagraharkar@acluva.org

Sophia Lakinslakin@aclu.org

Adriel I. Cepeda Derieuxacepedaderieux@aclu.org

Theresa Leetlee@aclu.org

Eden Brooke Heilmaneheilman@acluva.org

Davin McKay Rosboroughdrosborough@aclu.org

Dale Ho- dho@aclu.org

Carol L. Lewis- clewis@oag.state.va.us

_____________/s/___________________ Bradley P. Marrs (VSB#25281) Patrick C. Henry II (VBS#80468) Marrs & Henry 7202 Glen Forest Drive, Suite 307 Richmond, VA 23226 (804) 662-5715 (804) 662-5712 (fax) bmarrs@marrs-henry.com phenry@marrs-henry.com Local Counsel for Proposed Intervenors
James Bopp, Jr.*(IN Atty. No. 2838-84) Courtney Turner Milbank (IN Atty. No. 32178-29) True the Vote, Inc.Voters’ Rights Initiative THE BOPP LAW FIRM, PC 1 South Sixth St. Terre Haute, IN 47807-3510 Telephone: (812) 232-2434 E-mails: jboppjr@aol.com,
cmilbank@bopplaw.com Lead Counsel for Proposed Intervenors * Pro Hac Vice Pending
3

Case 6:20-cv-00024-NKM Document 22-1 Filed 04/23/20 Page 1 of 16 Pageid#: 267

United States District Court for the Western District of Virginia
Lynchburg Division

League of Women Voters of Virginia; Katherine D. Crowley; Erikka Goff; and Seijra Toogood,,

Plaintiffs,

v.

Civ. No. 6:20-cv-00024

Virginia State Board of Elections; Robert H. Brink, John O’Bannon, and Jamilah D. Lecruise, in their official capacities as Chairman, Vice-Chair, and Secretary of the Virginia State Board of Elections, respectively; and Christopher E. Piper, in his official capacity as Commissioner of the Virginia Department Of Elections,

Intervening Defendants Answer to Plaintiffs’ Complaint for Injunctive and Declaratory Relief

Defendants.

INTERVENING DEFENDANTS ANSWER TO PLAINTIFFS’ COMPLAINT FOR INJUNCTIVE AND DECLARATORY RELIEF
Intervening Defendants Sheila DeLappe Ferguson, Sandy Burchett, and Diane Crickenberger (collectively “Voters”), through undersigned counsel, respond as follows to the Plaintiffs’ Complaint for Injunctive and Declaratory Relief, filed on April 17, 2020, in the abovecaptioned case. (Doc. 1) Everything not given in a specific response is denied.
1. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in the first and second sentences in paragraph 1. Defendant Voters deny the averments and allegations in the third sentence in paragraph 1.
2. Denied.

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3. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 3.
4. Denied. 5. Denied. 6. Denied. 7. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 7. 8. Denied. 9. Defendant Voters deny that Plaintiffs are entitled to the relief requested in paragraph 9. 10. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 10. 11. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 11. 12. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 12. 13. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 13. 14. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 14. 15. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 15. Intervening Defs. Answer to Compl.
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16. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 16.
17. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 17.
18. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 18.
19. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 19.
20. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 20.
21. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 21.
22. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 22.
23. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 23.
24. Defendant Voters deny that Plaintiffs have stated a claim under the cited Constitutional and statutory provisions, and therefore deny that the action arises under them.
25. Defendant Voters, upon information and belief, admits the averments and allegations in paragraph 25.
Intervening Defs. Answer to Compl.
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26. Defendant Voters deny that Plaintiffs have stated a claim under the cited Constitutional and statutory provisions, and therefore deny that declaratory relief is authorized.
27. Defendant Voters, upon information and belief, admits the averments and allegations in paragraph 27.
28. Defendant Voters, upon information and belief, admits the averments and allegations in paragraph 28.
29. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 29.
30. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 30.
31. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 31.
32. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 32.
33. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 33.
34. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 34.
35. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 35.
Intervening Defs. Answer to Compl.
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36. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 36.
37. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 37.
38. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 38.
39. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 39.
40. Defendant Voters are is without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 40.
41. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 41.
42. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 42.
43. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 43.
44. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 44.
45. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 45.
Intervening Defs. Answer to Compl.
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46. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 46.
47. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 47.
48. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 48.
49. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 49.
50. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 50.
51. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 51.
52. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 52.
53. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 53.
54. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 54.
55. Denied. 56. Denied. 57. Denied. Intervening Defs. Answer to Compl.
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58. Denied. 59. Denied. 60. Defendant Voters, upon information and belief, admits the averments and allegations in paragraph 60. 61. Defendant Voters, upon information and belief, admits the averments and allegations in paragraph 61. 62. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 62. 63. Denied. 64. Defendant Voters, upon information and belief, admits the averments and allegations in paragraph 64. 65. Denied. 66. Defendant Voters, upon information and belief, admits the averments and allegations in paragraph 66. 67. Defendant Voters, upon information and belief, admits the averments and allegations in paragraph 67. 68. Defendant Voters, upon information and belief, admits the averments and allegations in paragraph 68. 69. Defendant Voters, upon information and belief, admits the averments and allegations in paragraph 69.
Intervening Defs. Answer to Compl.
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70. Defendant Voters, upon information and belief, admits the averments and allegations in paragraph 70.
71. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 71.
72. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 72.
73. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 73.
74. Denied. 75. Denied. 76. Denied. 77. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 77. 78. Denied. 79. Denied. 80. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 80. 81. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 81. 82. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 82. Intervening Defs. Answer to Compl.
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83. Denied. 84. Denied. 85. Denied. 86. Denied. 87. Denied. 88. Defendant Voters, upon information and belief, admits the averments and allegations in paragraph 88. 89. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 89. 90. Defendant Voters, upon information and belief, admits the averments and allegations in paragraph 90. 91. Defendant Voters, upon information and belief, admits the averments and allegations in paragraph 91. 92. Defendant Voters, upon information and belief, admits the averments and allegations in paragraph 92. 93. Denied. 94. Denied. 95. Defendant Voters are without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 95. 96. Denied. 97. Denied. Intervening Defs. Answer to Compl.
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98. Denied. 99. Defendant Voters, upon information and belief, admits the averments and allegations in paragraph 99. 100. Defendant Voters without knowledge or information sufficient to form a belief as to the truth of the averments and allegations in paragraph 100. 101. Denied. 102. Denied. 103. Denied. Defendant Voters deny that Plaintiffs are entitled to any of the relief requested on pages 3334 of their Complaint.
Defenses
First Defense
Plaintiffs’ argument that the witness requirement and its enforcement severely and unreasonably burdens the fundamental right to vote of Virginia Defendant Voters lacks merit.
Second Defense
Plaintiffs’ claim that the witness requirement under Virginia law violates the First and Fourteenth Amendments of the United States Constitution lacks merit.
Third Defense
Plaintiffs’ claim that the witness requirement will materially burden the right to vote lacks merit. Intervening Defs. Answer to Compl.
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Fourth Defense
Plaintiffs’ claim that the witness requirement under Virginia law violates the Voting Rights Act lacks merit.
Fifth Defense
Plaintiffs’ requested relief violates Voters’ fundamental right to vote by violating controlling legislation and stripping vital safeguards against voting fraud
Sixth Defense
Plaintiffs’ requested relief violates Voters’ fundamental right to vote under the Purcell principle.
Seventh Defense
Plaintiffs’ requested relief violates Voters’ fundamental right to vote by violating the Voters’ right to have, and to vote in, federal elections with the manner of election chosen by the legislature (U.S. Const. art I, § 4, cl. 1).
Eighth Defense
Defendant Voters adopt and incorporate all defenses asserted by any other Defendants.
Intervening Defs. Answer to Compl.
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Cross Claim
I. State Defendants’ unlawful interpretation of “disability or illness” violates Voters’ fundamental right to vote.
1. Sheila DeLappe Ferguson is a resident of Appomattox County, Virginia. She is a registered and eligible voter with a political party. Ms. Ferguson intends to vote in the next election. She has been a resident of Virginia for 56 years.
2. Sandy Burchett is a resident of Appomattox County, Virginia. She is a registered and eligible voter with a political party. Ms. Burchett intends to vote in the next election. She was a reading tutor in the County for 10 years.
3. Diane Crickenberger is a resident of Bedford County, Virginia. She is a registered and eligible voter with a political party. Ms. Crickenberger intends to vote in the next election. She is a business owner.
4. Virginia law allows “[a]ny duly registered person with a disability, as defined in § 24.2101, who is unable to go in person to the polls on the day of election because of his disability, illness, or pregnancy” to vote absentee. Va. Code § 24.2-700(4). “‘Person with a disability’ means a person with a disability as defined by the Virginians with Disabilities Act[.]” Id. at § 24.2-101.
5. State Defendants have issued guidance, contrary to Virginia law, that any “Voters may choose reason ‘2A My disability or illness’ for absentee voting in the May and June 2020 elections due to COVID-19.” This interpretation allows all voters to vote absentee, even if they do not have a disability or illness.
Intervening Defs. Answer to Compl.
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6. State Defendants’ arbitrary and capricious misinterpretation of “[m]y disability or illness” requirement to obtain an absentee ballot to include all voters, even if they do not have a disability, violates the due process clause of the Fourteenth Amendment of the U.S. Constitution.
7. State Defendants’ unlawful interpretation of “[m]y disability or illness” requirement to obtain an absentee ballot to include all voters violates the Voters’ fundamental right to vote under the First and Fourteenth Amendment to the U.S. Constitution by: (1) acting contrary to controlling legislation and stripping vital safeguards against voter fraud, thereby diluting and debasing Voters’ right to vote and (2) violating the Purcell principle.
8. State Defendants’ unlawful interpretation of “[m]y disability or illness” requirement to obtain an absentee ballot to include all voters violates Voters’ right to have, and to vote in, a federal election with the manner of election prescribed by the Legislature under Article I, section 4, clause 1 of the U.S. Constitution.
Prayer for Relief 9. Declare State Defendants’ unlawful interpretation of “[m]y disability or illness” unconstitutional and enjoin its enforcement; 10. Grant Voters their costs and attorneys fees under 42 U.S.C. Section 1988 and any other applicable authority; and 11. Grant any and all other such relief as this Court deems just and equitable.
Intervening Defs. Answer to Compl.
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Dated: April 23, 2020
Respectfully Submitted,
_____________/s/___________ Bradley P. Marrs (VSB#25281) Patrick C. Henry II (VSB#80468) Marrs & Henry 7202 Glen Forest Drive, Suite 307 Richmond, VA 23226 (804) 662-5715 (804) 662-5712 (fax) bmarrs@marrs-henry.com phenry@marrs-henry.com Local Counsel for Proposed Intervenors

James Bopp, Jr.* IN Atty. No. 2838-84
Courtney Turner Milbank* IN Atty. No. 32178-29
True the Vote, Inc. Voters’ Rights Initiative
THE BOPP LAW FIRM, PC 1 South Sixth St. Terre Haute, IN 47807-3510 Telephone: (812) 232-2434 E-mails: jboppjr@aol.com,
cmilbank@bopplaw.com Lead Counsel for Proposed Intervenors * Pro Hac Vice Pending

Intervening Defs. Answer to Compl.
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Certificate of Service

I hereby certify that the foregoing document was served electronically on April 23, 2020,

upon the following counsel via the United States District Court for the Western District of

Virginia, electronic filing system:

Vishal Mahendra Agraharkarvagraharkar@acluva.org

Sophia Lakinslakin@aclu.org

Adriel I. Cepeda Derieuxacepedaderieux@aclu.org

Theresa Leetlee@aclu.org

Eden Brooke Heilmaneheilman@acluva.org

Davin McKay Rosboroughdrosborough@aclu.org

Dale Ho- dho@aclu.org

Carol L. Lewis- clewis@oag.state.va.us

Intervening Defs. Answer to Compl.

_____________/s/___________________ Bradley P. Marrs (VSB#25281) Patrick C. Henry II (VBS#80468) Marrs & Henry 7202 Glen Forest Drive, Suite 307 Richmond, VA 23226 (804) 662-5715 (804) 662-5712 (fax) bmarrs@marrs-henry.com phenry@marrs-henry.com Local Counsel for Proposed Intervenors
James Bopp, Jr.*(IN Atty. No. 2838-84) Courtney Turner Milbank (IN Atty. No. 32178-29) True the Vote, Inc. Voters’ Rights Initiative THE BOPP LAW FIRM, PC 1 South Sixth St. Terre Haute, IN 47807-3510
-15-

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Telephone: (812) 232-2434 E-mails: jboppjr@aol.com,
cmilbank@bopplaw.com Lead Counsel for Proposed Intervenors * Pro Hac Vice Pending
Intervening Defs. Answer to Compl.
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Case 6:20-cv-00024-NKM Document 22-2 Filed 04/23/20 Page 1 of 1 Pageid#: 283

United States District Court for the Western District of Virginia
Lynchburg Division

League of Women Voters of Virginia; Katherine D. Crowley; Erikka Goff; and Seijra Toogood,,

Plaintiffs,

v.

Civ. No. 6:20-cv-00024

Virginia State Board of Elections; Robert H. Brink, John O’Bannon, and Jamilah D. Lecruise, in their official capacities as Chairman, Vice-Chair, and Secretary of the Virginia State Board of Elections, respectively; and Christopher E. Piper, in his official capacity as Commissioner of the Virginia Department Of Elections,

Order Granting Motion to Intervene

Defendants.

Order Granting Motion to Intervene

Sheila DeLappe Ferguson, Sandy Burchett, and Diane Crickenberger (collectively “Voters”)

having timely filed a Motion to Intervene, and the Court being duly advised now GRANTS said motion. The Answer and Crossclaim are deemed filed and served as of the date of this order.

Dated: April ___, 2020

____________________________ Norman K. Moon Senior Judge

Case 6:20-cv-00024-NKM Document 23 Filed 04/23/20 Page 1 of 14 Pageid#: 284

United States District Court for the Western District of Virginia
Lynchburg Division

League of Women Voters of Virginia; Katherine D. Crowley; Erikka Goff; and Seijra Toogood,,

Plaintiffs,

v.

Civ. No. 6:20-cv-00024

Virginia State Board of Elections; Robert H. Brink, John O’Bannon, and Jamilah D. Lecruise, in their official capacities as Chairman, Vice-Chair, and Secretary of the Virginia State Board of Elections, respectively; and Christopher E. Piper, in his official capacity as Commissioner of the Virginia Department Of Elections,

Brief in Support of Motion to Intervene

Defendants.

Brief in Support of Motion to Intervene

On April 17, 2020, Plaintiffs League of Women Voters of Virginia, Katherine D. Crowley, Erikka Goff, and Seijra Toogood filed a Complaint for Injunctive and Declaratory Relief. (Doc. 1). Plaintiffs seek an order from this Court eliminating the witness requirements for absentee voting. (Id.)
Plaintiffs’ requested relief violates Voters’ fundamental right to vote. Accordingly, Sheila DeLappe Ferguson, Sandy Burchett, and Diane Crickenberger (collectively “Voters”) timely request to intervene in this action to protect their fundamental Constitutional right to vote as registered voters in Virginia elections.
Background on Proposed Intervenors 1. Sheila DeLappe Ferguson is a resident of Appomattox County, Virginia. She is a registered and eligible voter with a political party. Ms. Ferguson intends to vote in the next election. She has been a resident of Virginia for 56 years.

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2. Sandy Burchett is a resident of Appomattox County, Virginia. She is a registered and eligible voter with a political party. Ms. Burchett intends to vote in the next election. She was a reading tutor in the County for 10 years.
3. Diane Crickenberger is a resident of Bedford County, Virginia. She is a registered and eligible voter with a political party. Ms. Crickenberger intends to vote in the next election. She is a business owner.
Argument Intervention is permitted if a movant meets the requirements of Fed. R. Civ. P. 24. As shown below, Voters meet these requirements and should be permitted to intervene.
I. The voters are intervenors by right. Fed. R. Civ. P. 24(a) provides that: on timely motion, the court must permit anyone to intervene who . . . claims an interest relating to the property or transaction that is the subject of the action, and is so situated that disposing of the action may as a practical matter impair or impede the movant’s ability to protect its interest, unless existing parties adequately represent that interest. (emphasis added). Thus, there are three primary criteria that the movant must show to qualify for intervention of right: timeliness, an interest in the action, and the possibility that the action would, as practical matter, impair the movant’s ability to protect that interest. There is also an exception, under which the court is not required to permit intervention where “existing parties adequately represent [the movant’s] interest.” Here, Voters meet all three primary criteria, and the exception does not apply. A. Voters’ motion is timely. Voters’ Motion is made within a reasonable time. “Rule 24 is silent as to what constitutes

Brief in Support of

Motion to Intervene

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a timely application and the question must therefore be answered in each case by the exercise of the sound discretion of the court.” Black v. Cent. Motor Lines, Inc., 500 F.2d 407, 408 (4th Cir. 1974). “The most important consideration is whether the delay has prejudiced the other parties.” Spring Constr. Co. v. Harris, 614 F.2d 374, 377 (4th Cir. 1980).
Here, Plaintiffs filed their Complaint on April 17, 2020. The Voters have moved to intervene less than a week later, and before any Answer has been filed. Thus, there has been no delay, nor any prejudice. B. Voters have an interest in this action.
There can be no doubt that Voters have an interest in this action. The federal right to vote is fundamental, Harper v. Va. State Bd. of Elections, 383 U.S. 663, 667 (1966), and wellestablished: “Undeniably the Constitution of the United States protects the right of all qualified citizens to vote, in state as well as in federal elections” and to have that vote counted. Reynolds v. Sims, 377 U.S. 533, 554 (1964). “The right to vote can neither be denied outright, nor destroyed by alteration of ballots, nor diluted by ballot-box stuffing.” Id. at 555 (internal citations omitted). “And the right of suffrage can be denied by a debasement or dilution of the weight of a citizen’s vote just as effectively as by wholly prohibiting the free exercise of the franchise.” Id. The right to vote inheres in, and is protected by, the First and Fourteenth Amendments of the U.S. Constitution. Virginia also recognizes the right to vote. See Va. Const. Art. II, § 1 (detailing the qualifications of voters).
The requested relief would violate Voters’ fundamental right to vote, thereby creating a valid interest in this action.

Brief in Support of

Motion to Intervene

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C. The requested relief impairs and impedes Voters’ ability to protect their interests. Voters’ ability to protect their interest would be impaired or impeded by disposition of
Plaintiffs’ action. Plaintiffs have requested that this Court eliminate the witness requirement for absentee ballots. This requested relief violates Voters’ fundamental right to vote by violating: (1) controlling legislation and stripping vital safeguards against voting fraud, (2) the right to vote under the Purcell principle, and (3) the Voters’ right to have, and to vote in, federal elections with the manner of election chosen by the legislature. See Part II.A.
But without intervention, Voters have no ability to protect their interests. And if Plaintiffs were to succeed in obtaining their requested relief, Voter’s interests would be significantly impaired and impeded. For this reason, Voters should be permitted to defend their fundamental right to vote in the present action. D. The “adequately represented” exception does not apply.
The “adequately represent[ed]” exception in Rule 24(a) has nothing to do with the skill or diligence of the attorneys who would be representing the parties generally sharing the same side of the case as the parties seeking to intervene. Instead, under this prong, it must simply be “shown that representation of its interest ‘may be’ inadequate.” United Guar. Residential Ins. Co. v. Phila. Sav. Fund Soc'y, 819 F.2d 473, 475 (4th Cir. 1987) (citing Trbovich v. UMW, 404 U.S. 528, 538, n. 10 (1972)). Moreover, “the burden of making this showing should be treated as ‘minimal.’” Id. at 475.
Most importantly, in explaining Trbovich, the Fourth Circuit said: Trbovich recognized that when a party to an existing suit is obligated to serve two distinct interests, which, although related, are not identical, another with one of those interests should be entitled to intervene. …The test used by the Court in that case

Brief in Support of

Motion to Intervene

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was to inquire whether each of the dual interests may “always dictate precisely the same approach to the conduct of the litigation.”. United Guar., 819 F.2d at 475 (quoting Trbovich, 404 U.S. at 459) (emphasis added). These circumstances apply here. First, Voters are representing their own interests, not the interests of the Commonwealth or the Department of Elections. That interest is their own fundamental right to vote. See Part I.B. Second, while State Defendants have not yet answered, State Defendants will be responsible for defending Virginia’s statutes and regulations as well as any interests the State Defendants may have with respect to administrative procedures in the conduct of elections. These are different interests than Voters represent. But, even if the individual rights of Voters are added to the interests being represented by State Defendants, they are still representing multiple interests, whereas Voters are representing only one. Thus, it is no slight to Defendants or their counsel to note that, while some of State Defendants’ efforts may at times be useful or beneficial to Voters, “they may not always dictate precisely the same approach to the conduct of the litigation.” Trbovich, 404 U.S. at 539. Third, State Defendants’ position regarding the interpretation of “[m]y disability or illness” is adverse to Voters’ position. Because State Defendants’ unlawful interpretation is unconstitutional in violation of the First and Fourteenth Amendments to the U.S. Constitution and Article I, section 4, clause 1 of the U.S. Constitution, Voters seek to assert a cross claim against State Defendants in their Answer to Plaintiffs’ Complaint for Injunctive and Declaratory Relief. Thus, this final prong is met as well. II. In the alternative, the voters meet all the requirements for permissive intervention. Even if this Court determines that Voters cannot intervene as of right, Voters qualify for

Brief in Support of

Motion to Intervene

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permissive intervention. Fed. R. Civ. P. 24(b) provides that on “timely motion, the court may permit anyone to intervene who . . . has a claim or defense that shares with the main action a common question of law or fact.” “In exercising its discretion, the court must consider whether the intervention will unduly delay or prejudice the adjudication of the original parties’ rights.” Id. at 24(b)(3). A. The Voters’ defenses and claims share a common question of law with the main
action. If permitted to intervene, Voters would make at least the following defenses and claims—all of which share a common question of law with the main action. 1. The requested relief violates controlling legislation and strips vital
safeguards against voting fraud. The Virginia Legislature has enacted detailed legislation governing how elections are to be conducted—with vital safeguards against voting fraud—in Va. Code § 24.2 (titled “Elections”). In asking this Court to remove the witness requirements, Plaintiffs have requested that this Court eliminate one of these vital safeguards. Since the requested relief dispenses with current statutory protections against illegal voting found in absentee voting law, the requested relief is a cognizable dilution of the votes of eligible, registered voters such as intervenor Voters. This violation of Voters’ right to vote by dilution is made clear in Reynolds and Bush. In Reynolds v. Sims, 377 U.S. 533 (1964), the Supreme Court held that “the right of suffrage can be denied by a debasement or dilution of the weight of a citizen’s vote just as effectively as by wholly prohibiting the free exercise of the franchise.” 377 U.S. at 554. “[A]n individual’s right to vote for state legislators is unconstitutionally impaired when its weight is in a substantial fashion diluted when compared with votes of citizens living in other parts of the State,” id. at

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568. And in Bush v. Gore, 531 U.S. 98 (2000), the Supreme Court highlighted the fact that the Florida Supreme Court’s order lacked the necessary “safeguards” to assure confidence in the outcome.1 531 U.S. 98, 109 (2000) (per curiam). That mandate to maintain “safeguards” to assure confidence in the election is particularly relevant here. Under Reynolds and Bush it is readily seen that vote dilution cannot be justified, as would occur here if the witness requirement were removed.
Similarly, the Seventh Circuit recently stayed an injunction by the U.S. District Court for the Western District of Wisconsin because it had given inadequate attention to the interest in preventing voter fraud by eliminating the witness requirement for absentee-ballot signatures: “This court is concerned with the overbreadth of the district court’s order, which categorically eliminates the witness requirement applicable to absentee ballots and gives no effect to the state’s substantial interest in combating voter fraud.” Democratic National Committee v. Bostelmann, slip op. 3,2 Nos. 20-1538, 20-1539, 20-1545 & 20-1546 (7th Cir. Apr. 3, 2020) (citing Griffin v. Roupas, 385 F.3d 1128, 1130 (7th Cir. 2004)).3

1As Bush put it, adequate “safeguards” are mandatory, id. at 109:
[W]e are presented with a situation where a state court with the power to assure uniformity has ordered a statewide recount with minimal procedural safeguards. When a court orders a statewide remedy, there must be at least some assurance that the rudimentary requirements of equal treatment and fundamental fairness are satisfied.

2The slip opinion could not be found on LEXIS but is available at https://moritzlaw.osu.e du/electionlaw/litigation/documents/DNC_v_Bost_BL-30.pdf.

3Though the district-court order in Bostelmann, Nos. 3:20-cv-00249-wmc, 3:20-cv00278-wmc, 3:20-cv-00284-wmc, 2020 U.S. Dist. LEXIS 57918 (W.D. Wisc. Apr. 2, 2020), granted some election-related relief based on COVID-19 concerns, other courts have not. See, e.g., Williams v. DeSantis, No. 1:20-cv-00067 (N.D. Fla. Mar. 17, 2020), available at

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2. The requested relief violates the right to vote under the Purcell Principle. The requested relief also violates what has come to be called the Purcell Principle. See, e.g., Richard L. Hasen, Reining in the Purcell Principle, 43 Fl. St. U. L. Rev. 427 (2016). That Principle is named for Purcell v. Gonzalez, 549 U.S. 1 (2006). The Principle is anchored in the right to vote and its potential for debasement. Id. at 4 (citing Reynolds, 377 U.S. at 555). Among its critiques of the Ninth Circuit for staying a voter-identification requirement near an election, the Court held in Purcell that such near-election court orders themselves risk debasement and dilution of the right to vote because “[c]ourt orders affecting elections, especially conflicting orders, can themselves result in voter confusion and consequent incentive to remain away from the polls. As an election draws closer, that risk will increase.” 549 U.S. at 4-5. So the general rule is that no court order altering election procedures near an election is permissible because it violates the right to vote. On April 6, 2020, the U.S. Supreme Court issued an opinion in Republican National Committee v. Democratic National Committee, No. 19A1016, 2020 U.S. LEXIS 2195 (U.S. Apr. 6, 2020) (per curiam), slip op. available at https://www.supremecourt.gov/opinions/19pdf/19a10 16_o759.pdf, again applying that Principle, which it summarized thus: This Court has repeatedly emphasized that lower federal courts should ordinarily

https://www.clearinghouse.net/chDocs/public/VR-FL-0173-0003.pdf; Mays v. Thurston, 2020 U.S. Dist. LEXIS 54498, No. 4:20-cv-341 (E.D. Ark. voluntarily dismissed Mar. 31, 2020); League of Women Voters of Ohio v. LaRose, No. 2:20-cv-01638 (S.D. Ohio Apr. 3, 2020), available at https://moritzlaw.osu.edu/electionlaw/litigation/documents/LWVO_v_Larose_57.p df. The Supreme Court of New Mexico recently rejected an all-mail-in-ballot plan, instead ordering that absentee-ballot applications be mailed to registered voters so they could apply, in State ex rel Riddle v. Oliver, No. S-1-SC-38228 (Ariz. Apr. 16, 2020) (order available at https://cms.nmcourts.gov/uploads/files/News/38228%20Final%20Order%20(4-16-20).pdf).

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not alter the election rules on the eve of an election. See Purcell v. Gonzalez, 549 U. S. 1 (2006) (per curiam); Frank v. Walker, 574 U. S. 929 (2014); Veasey v. Perry, 574 U. S. __ (2014).
2020 U.S. LEXIS 2195, at **2-3. This RNC case stayed a lower-court order allowing voters to
mail absentee ballots after election day. RNC recited various problems that the lower-court order
posed and said they “underscore[] the wisdom of the Purcell principle, which seeks to avoid this
kind of judicially created confusion.” Id. at **3. A crucial point was that the lower-court order
“fundamentally alters the nature of the election.” Id.
Here, as in RNC, the Purcell-Principle should apply as applicable: “[W]hen a lower court
intervenes and alters the election rules so close to the election date, our precedents indicate that
this Court, as appropriate, should correct that error.” Slip op. 3.
3. The requested relief violates the Voters’ right to have, and to vote in, federal elections with the manner of election chosen by the legislature.
Though this election involves federal candidates, the requested relief is not the “Manner”
of election “prescribed . . . by the Legislature,” as required by the U.S. Constitution. Article I,
§ 4, cl. 1 provides:
The Times, Places and Manner of holding Elections for Senators and Representatives, shall be prescribed in each State by the Legislature thereof; but the Congress may at any time by Law make or alter such Regulations, except as to the Places of chusing Senators.
U.S. Const. art. I, § 4, cl. 1.
Candidates for federal office are on the Primary ballot. See https://www.elections.virginia
.gov/media/castyourballot/candidatelist/June-2020-Primary-Candidates-List-(4)-1.pdf (Virginia
Dep’t of Elections, “Certified Candidates in Ballot Order for June 23, 2020 Primary Elections”).
So the Primary must be conducted in the Legislature’s prescribed manner. But the requested

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relief is not at all what the Legislature chose and is contrary to controlling legislation. Virginia law requires that absentee voters, inter alia, open and mark their ballots in the
presence of a witness. Va. Code § 24.2-707(A). It also requires that voters enclose their ballots in the provided envelope, seal the envelope, and “fill in and sign the statement printed on the back of the envelope in the presence of a witness, who shall sign the same envelope[.]” Id.
The requested relief seeks to eliminate these requirements, thereby seeking to conduct the election in a manner not authorized by the Legislature and contrary to the Legislature’s choices. They seek to eliminate safeguards against vote fraud that the Legislature chose. See Part II.A.1. So the requested relief violates Article I, § 4, cl. 1, including a violation of the Voter’s right to have, and to vote in, such an election as the U.S. Constitution prescribes.
4. State Defendants’ unlawful interpretation of “disability or illness” violates Voters’ fundamental right to vote.
Voters’ also seek to bring a cross claim against State Defendants, which shares a common question of law with the main action. State Defendants have issued guidance, contrary to Virginia law, that any “Voters may choose reason ‘2A My disability or illness’ for absentee voting in the May and June 2020 elections due to COVID-19.”4 This interpretation allows all voters to vote absentee, even if they do not have a disability or illness.
State Defendants’ arbitrary and capricious misinterpretation of “[m]y disability or illness” requirement to obtain an absentee ballot to include all voters, even if they do not have a disability, violates the due process clause of the Fourteenth Amendment of the U.S. Constitution.

4Va. Dep’t of Elections, Absentee Ballots, https://www.elections.virginia.gov/casting-a-b allot/absentee-voting/ (last visited Apr. 22, 2020).

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Additionally, for the same reasons shown above (Part II.A.1-3), State Defendants’ unlawful interpretation of “[m]y disability or illness” requirement to obtain an absentee ballot to include all voters violates the Voters’ fundamental right to vote by: (1) acting contrary to controlling legislation and stripping vital safeguards against voting fraud, thereby diluting and debasing Voters’ right to vote, (2) violating the Purcell principle, and (3) violating the Voters’ right to have, and to vote in, federal elections with the manner of election chosen by the legislature under Article I, section 4, clause 1 of the U.S. Constitution. B. Voters’ Motion is timely.
As discussed above, this Motion is made in a timely manner—less than one week after Plaintiffs filed their Complaint. No delay and no prejudice results from the filing of Voters’ Motion. See Part I.D. C. Voters’ intervention will not cause any undue delay or prejudice.
No undue delay or prejudice will result from Voters’ intervention. Indeed, no Answer has been filed. So there has been and will be no delay to this case, nor is there any prejudice to either party.
Conclusion For these reasons, Voters’ Motion to Intervene should be granted.

Brief in Support of

Motion to Intervene

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Date: April 23, 2020
Respectfully Submitted,
/s/ Bradley P. Marrs (VSB#25281) Patrick C. Henry II (VBS#80468) Marrs & Henry 7202 Glen Forest Drive, Suite 307 Richmond, VA 23226 (804) 662-5715 (804) 662-5712 (fax) bmarrs@marrs-henry.com phenry@marrs-henry.com
Local Counsel for Proposed Intervenors

James Bopp, Jr.* IN Atty. No. 2838-84
Courtney Turner Milbank* IN Atty. No. 32178-29
True the Vote, Inc. Voters’ Rights Initiative
THE BOPP LAW FIRM, PC 1 South Sixth St. Terre Haute, IN 47807-3510 Telephone: (812) 232-2434 E-mails: jboppjr@aol.com,
cmilbank@bopplaw.com
Lead Counsel for Proposed Intervenors
* Pro Hac Vice Pending

Brief in Support of

Motion to Intervene

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Certificate of Service

I hereby certify that the foregoing document was served electronically on April 23, 2020,

upon the following counsel via the United States District Court for the Western District of

Virginia, electronic filing system:

Vishal Mahendra Agraharkarvagraharkar@acluva.org

Sophia Lakinslakin@aclu.org

Adriel I. Cepeda Derieuxacepedaderieux@aclu.org

Theresa Leetlee@aclu.org

Eden Brooke Heilmaneheilman@acluva.org

Davin McKay Rosboroughdrosborough@aclu.org

Dale Ho- dho@aclu.org

Carol L. Lewis- clewis@oag.state.va.us

/s/ Bradley P. Marrs (VSB#25281) Patrick C. Henry II (VBS#80468) Marrs & Henry 7202 Glen Forest Drive, Suite 307 Richmond, VA 23226 (804) 662-5715 (804) 662-5712 (fax) bmarrs@marrs-henry.com phenry@marrs-henry.com
Local Counsel for Proposed Intervenors

James Bopp, Jr.* IN Atty. No. 2838-84
Courtney Turner Milbank* IN Atty. No. 32178-29
True the Vote, Inc. Voters’ Rights Initiative
THE BOPP LAW FIRM, PC 1 South Sixth St. Terre Haute, IN 47807-3510 Telephone: (812) 232-2434 E-mails: jboppjr@aol.com,
cmilbank@bopplaw.com

Brief in Support of

Motion to Intervene

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Lead Counsel for Proposed Intervenors * Pro Hac Vice Pending

Brief in Support of

Motion to Intervene

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 </s> Case 6:20-cv-00024-NKM Document 35 Filed 04/27/20 Page 1 of 3 Pageid#: 356

UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA
Lynchburg Division

LEAGUE OF WOMEN VOTERS OF

VIRGINIA;

KATHERINE

D.

CROWLEY; ERIKKA GOFF; and

SEIJRA TOOGOOD,

Plaintiffs,

v.

VIRGINIA STATE BOARD OF ELECTIONS; ROBERT H. BRINK, JOHN O’BANNON, and JAMILAH D. LECRUISE, in their official capacities as Chairman, Vice-Chair, and Secretary of the Virginia State Board of Elections, respectively; and CHRISTOPHER E. PIPER, in his official capacity as Commissioner of the Virginia Department of Elections,

Defendants.

Case No. 6:20-cv-00024-NKM

JOINT MOTION FOR ENTRY OF PARTIAL CONSENT JUDGMENT AND DECREE Plaintiffs and Defendants (collectively, the “Parties”) seek approval of a partial consent
judgment and decree that would vindicate the public interests of ensuring access to the ballot, protecting election integrity, and promoting public health during the COVID-19 pandemic. Specifically, the agreement would stop enforcement for Virginia’s June 23 primary of the requirement that Virginia absentee voters have another individual observe them removing their absentee ballot from the envelope and then have that individual sign as a witness (the “witness requirement”) for voters who believe they may not safely have a witness present while completing their ballot. In support of their motion, the Parties rely upon the attached proposed

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Partial Consent Judgment and Decree and accompanying Brief in Support of Joint Motion for Entry of a Partial Consent Judgment and Decree.
This agreement represents a fair, adequate, and reasonable arrangement, negotiated through fast-paced but thorough conversations that have produced an agreement that will benefit all parties while serving the public interest. The Parties therefore request that the Court enter this agreement, which will provide certainty well in advance of the June 23 primary while allowing all qualified Virginians to vote and protect their health.

Dated: April 27, 2020

Respectfully submitted,

/s/ Davin M. Rosborough _______________ Davin M. Rosborough (VSB # 85935) Dale E. Ho* Sophia Lin Lakin* Theresa J. Lee* Adriel I. Cepeda-Derieux* American Civil Liberties Union Foundation 125 Broad Street, 18th Floor New York, NY 10004 Tel.: (212) 549-2500 drosborough@aclu.org dho@aclu.org slakin@aclu.org tlee@aclu.org acepedaderieux@aclu.org
Vishal Agraharkar (VSB #93265) Eden Heilman (VSB #93554) AMERICAN CIVIL LIBERTIES UNION FOUNDATION OF AMERICA, INC. 701 E. Franklin Street, Suite 1412 Richmond, Virginia 23219 Phone: (804) 644-8080 Fax: (804) 649-2733 vagraharkar@acluva.org eheilman@acluva.org

MARK R. HERRING Attorney General of Virginia By: /s/ Carol L. Lewis CAROL L. LEWIS (VSB #92362) MICHELLE S. KALLEN (VSB #93286) HEATHER HAYS LOCKERMAN (VSB #65535) Office of the Attorney General 202 North Ninth Street Richmond, Virginia 23219 804-692-0558 (telephone) 804-692-1647 (facsimile) clewis@oag.state.va.us
Attorneys for Robert H. Brink, John O’Bannon, Jamilah D. LeCruise and Christopher E. Piper in their official capacities, and the Virginia State Board of Elections

Attorneys for Plaintiffs

*Admitted pro hac vice

2

Case 6:20-cv-00024-NKM Document 35 Filed 04/27/20 Page 3 of 3 Pageid#: 358 CERTIFICATE OF SERVICE
I certify that on April 27, 2020, I served a copy of the foregoing Joint Motion for Entry of Partial Consent Judgment and Decree via filing with the Court’s CMECF system, which sent copies of this document to Counsel of Record.
/s/ Davin M. Rosborough _______________ Davin M. Rosborough (VSB # 85935) American Civil Liberties Union Foundation 125 Broad Street, 18th Floor New York, NY 10004 Tel.: (212) 549-2500 drosborough@aclu.org Counsel for Plaintiffs
3

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EXHIBIT A
UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA
Lynchburg Division

LEAGUE OF WOMEN VOTERS OF

VIRGINIA;

KATHERINE

D.

CROWLEY; ERIKKA GOFF; and

SEIJRA TOOGOOD,

Plaintiffs,

v.

VIRGINIA STATE BOARD OF ELECTIONS; ROBERT H. BRINK, JOHN O’BANNON, and JAMILAH D. LECRUISE, in their official capacities as Chairman, Vice-Chair, and Secretary of the Virginia State Board of Elections, respectively; and CHRISTOPHER E. PIPER, in his official capacity as Commissioner of the Virginia Department of Elections,

Defendants.

Case No. 6:20-cv-00024-NKM

PARTIAL CONSENT JUDGMENT AND DECREE 1. Whereas on March 12, 2020, Virginia Governor Ralph S. Northam issued Executive Order 51 (EO 51) in which he declared a state of emergency in Virginia in response to the spread in Virginia of a respiratory illness (COVID-19) caused by a novel coronavirus. 2. Whereas, on March 30, 2020, in Executive Order 55 (EO 55), Governor Northam directed that, subject to limited exceptions, “[a]ll individuals in Virginia shall remain at their place of residence, except as provided below by this Order and Executive Order 53.” ¶ 1. EO 55’s restrictions will remain in place until June 10. Id. at p. 3. 3. Whereas on April 13, 2020, researchers from the University of Virginia’s

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Biocomplexity Institute summarized their research in a presentation to Virginia’s Secretary of Health and Human Resources entitled “Estimation of COVID-19 Impact in Virginia.” See UVA Biocomplexity Institute PowerPoint presentation, https://www.governor.virginia.gov/media/ governorvirginiagov/governor-of-virginia/pdf/Combined-PPT-April-13.pdf. The researchers predict that if current restrictions were lifted on April 30, infection rates would begin to climb earlier than if the restrictions remained in place until June 10. See id. at p. 8-18. These researchers also predict that if current restrictions remain in place through June 10, COVID-19 cases in Virginia will likely not peak until approximately August. See id. at p. 15-16.
4. Whereas on April 17, 2020, Plaintiffs League of Women Voters of Virginia, Katherine D. Crowley, Erikka Goff, and Seijra Toogood (“Plaintiffs”) filed a complaint against the above-named Defendants challenging enforcement during the ongoing public health crisis caused by the spread of a novel coronavirus, SARS-CoV-2, of Virginia’s requirement that every voter filling out an absentee ballot must open, mark, and refold their ballot in the presence of a witness, and then have the witness sign their ballot envelope (the “witness requirement”). Among other relief requested, the Complaint sought to enjoin enforcement of the witness requirement (as stated in Va. Code § 24.2-706 and § 24.2-707 and as interpreted by 1 Va. Admin. Code 20-70-20(B)) for as long as public health officials continue to recommend social distancing practices due to the risk of community transmission of COVID-19, the respiratory disease caused by SARS-CoV-2. ECF No. 1 at 33.
5. Whereas on April 21, 2020, Plaintiffs filed a motion for preliminary injunction requesting this Court prohibit the above-named Defendants from enforcing the witness requirement for all Virginia voters for the primary election to be held on June 23, 2020 (“June Primary”), and for all subsequent elections in Virginia until such time as in-person interactions

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required by compliance with the witness requirement no longer pose a risk to public health and

personal safety. Plaintiffs’ motion further requested that Defendants be ordered to issue guidance

instructing election officials to count otherwise validly cast absentee ballots missing a witness

signature and conduct a public information campaign in conjunction with city and county

election officials about the elimination of the requirement.

6. Whereas federal guidelines state: “[e]veryone should . . . avoid close contact” by

“stay[ing] home as much as possible” and “put[ting] distance between yourself and other

people.” Centers for Disease Control and Prevention, Coronavirus Disease 2019: How to Protect

Yourself & Others, https://www.cdc.gov/coronavirus/2019-ncov/prevent-getting-

sick/prevention.html (last visited Apr. 27, 2020). And whereas other federal guidelines

“[e]ncourage voters to use voting methods that minimize direct contact.” Centers for Disease

Control and Prevention, Recommendations for Election Polling Locations: Interim guidance to

prevent

spread

of

coronavirus

disease

2019

(COVID-19),

https://www.cdc.gov/coronavirus/2019-ncov/community/election-polling-locations.html (last

visited Apr. 26, 2020).

7. Whereas on April 24, 2020, Governor Northam released “Forward Virginia,”

(Blueprint), explaining the metrics that must be in place to begin relaxing measures implemented

to slow the spread of COVID-19. Forward Virginia PowerPoint

https://www.governor.virginia.gov/media/governorvirginiagov/governor-of-virginia/pdf/Slide-

Deck-4-24-2020-.pdf. Phase One of the Blueprint will begin when, among other factors, the

percentage of positive COVID-19 tests decreases over a fourteen day period. See id. As of April

27, 2020, the percentage of positive tests continued to increase. See id.

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8. Whereas pursuant to Va. Code § 24.2-612, absentee voting must be available 45 days prior to the June Primary, or Saturday, May 9, 2020. For localities whose general registrar’s offices are closed on Saturday, absentee ballots must be available on May 8, 2020.
9. Whereas in light of the data that supports the Plaintiffs’ concerns for their safety if they are required to interact with others in order to cast their ballot in the June Primary, Plaintiffs and Defendants (collectively, the “Consent Parties”) agree that an expeditious resolution of this matter for the June Primary, in the manner encompassed by the terms of this Consent Decree, is in the best interests of the health, safety, and constitutional rights of the citizens of the Commonwealth of Virginia, and therefore in the public interest.
10. Whereas the Consent Parties further agree that no eligible voter should have to choose between casting a ballot that will count and placing their own health at risk.
11. Whereas Defendants agree not to enforce the witness requirement for the June Primary for absentee voters who believe they may not safely have a witness present while completing their ballot.
12. Whereas Plaintiffs agree to withdraw their April 21, 2020, motion for preliminary injunction upon entry of this Partial Consent Judgment and Decree.
13. Whereas the Consent Parties agree that entry of this Consent Decree does not affect the viability of Plaintiffs’ claims under the First and Fourteenth Amendments to the Constitution, or Section 2 of the Voting Rights Act, with respect to enforcement of the witness requirement in any subsequent elections after the June Primary.
14. Whereas Plaintiffs agree to a waiver of any entitlement to damages, fees, including attorneys’ fees, expenses, and costs, that may have accrued as of the date of the entry of this order, with respect to the claims raised by Plaintiffs in this action, provided, however, that

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Plaintiffs reserve their rights to seek costs and attorneys’ fees on their claims in the event of material non-compliance by Defendants with the terms and conditions of this Consent Decree.
15. Whereas the Court finds that it has subject matter jurisdiction over the Consent Parties and that the Partial Consent Judgment and Decree is fair, adequate, and reasonable and not illegal, a product of collusion, or against the public interest, because such agreement preserves the constitutional right to vote of Plaintiffs and other Virginia voters while promoting public health during a pandemic and does so without harming the integrity of Virginia’s elections. It does give appropriate weight to Defendants’ expertise and public interest responsibility in the area of election administration.
16. Whereas Plaintiffs made a sufficiently strong showing on the merits of the claim, as shown in their complaint and motion for preliminary injunction, to further support the fairness, adequacy, and reasonableness of this Partial Consent Judgment and Decree. IT IS HEREBY ORDERED, ADJUDGED, AND DECREED FOR THE REASONS STATED ABOVE IN PARAGRAPHS 1-16 THAT:
1. For the Primary elections scheduled for June 23, 2020, Defendants shall not enforce the requirement, as stated in Va. Code § 24.2-706 and § 24.2-707, that absentee voters who believe that they may not safely have another individual present to witness the voter open, mark, and refold their ballot, and then have that that individual sign the absentee ballot envelope next to the voter’s statement and signature.
2. Defendants shall issue guidance instructing all relevant city and county election officials to count all absentee ballots in the June primary that are otherwise validly cast but missing a witness signature.

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3. Defendants shall issue updated instructions to include with all absentee ballots as provided in Va. Code. § 24.2-706—or issue guidance instructing all relevant city and county election officials to modify or amend the printed instructions accompanying each absentee ballot—to inform voters that any absentee ballot cast in the June Primary without a witness signature will not be rejected on that basis and specifically informing voters in bold print that they may disregard the witness signature line on the absentee ballot envelope if they believe they may not safely have a witness present while completing their ballot.
4. Defendant Commissioner of Elections shall take additional reasonable steps to inform the public that the witness requirement will not be enforced for the June Primary for those absentee voters who believe they may not safely have a witness present while completing their ballot, and issue guidance instructing all relevant city and county election officials to do the same.
5. Plaintiffs will withdraw their motion for a preliminary injunction. 6. In accordance with the terms of this Consent Decree, the Consent Parties shall each bear their own fees, expenses, and costs incurred as of the date of this Order, with respect to all claims raised by Plaintiffs against the Defendants.

Dated: April ___, 2020

________________________ United States District Judge

/s/ Davin M. Rosborough_______________ Davin M. Rosborough (VSB # 85935) Dale E. Ho* Sophia Lin Lakin* Theresa J. Lee*

MARK R. HERRING Attorney General of Virginia By: /s/ Carol L. Lewis CAROL L. LEWIS (VSB #92362) MICHELLE S. KALLEN (VSB #93286)

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Adriel I. Cepeda-Derieux* American Civil Liberties Union Foundation 125 Broad Street, 18th Floor New York, NY 10004 Tel.: (212) 549-2500 drosborough@aclu.org dho@aclu.org slakin@aclu.org tlee@aclu.org acepedaderieux@aclu.org
Vishal Agraharkar (VSB #93265) Eden Heilman (VSB #93554) AMERICAN CIVIL LIBERTIES UNION FOUNDATION OF AMERICA, INC. 701 E. Franklin Street, Suite 1412 Richmond, Virginia 23219 Phone: (804) 644-8080 Fax: (804) 649-2733 vagraharkar@acluva.org eheilman@acluva.org
Attorneys for Plaintiffs
*Admitted pro hac vice

HEATHER HAYS LOCKERMAN (VSB #65535) Office of the Attorney General 202 North Ninth Street Richmond, Virginia 23219 804-692-0558 (telephone) 804-692-1647 (facsimile) clewis@oag.state.va.us
Attorneys for Robert H. Brink, John O’Bannon, Jamilah D. LeCruise and Christopher E. Piper in their official capacities, and the Virginia State Board of Elections

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UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA
Lynchburg Division

LEAGUE OF WOMEN VOTERS OF

VIRGINIA;

KATHERINE

D.

CROWLEY; ERIKKA GOFF; and

SEIJRA TOOGOOD,

Plaintiffs,

v.

VIRGINIA STATE BOARD OF ELECTIONS; ROBERT H. BRINK, JOHN O’BANNON, and JAMILAH D. LECRUISE, in their official capacities as Chairman, Vice-Chair, and Secretary of the Virginia State Board of Elections, respectively; and CHRISTOPHER E. PIPER, in his official capacity as Commissioner of the Virginia Department of Elections,

Defendants.

Case No. 6:20-cv-00024-NKM

BRIEF IN SUPPORT OF JOINT MOTION FOR ENTRY OF PARTIAL CONSENT JUDGMENT AND DECREE Plaintiffs and Defendants (collectively, the “Parties”) seek approval of a partial consent judgment and decree that would vindicate the public interests of ensuring access to the ballot, election integrity, and promoting public health during the COVID-19 pandemic. Specifically, the agreement would stop enforcement for Virginia’s June 23 primary of the requirement that Virginia absentee voters have another individual observe them removing their absentee ballot from the envelope and then have that individual sign as a witness (the “witness requirement”) for voters who believe they may not safely have a witness present while completing their ballot. This agreement represents a limited, fair, adequate, and reasonable arrangement, negotiated through

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fast-paced but thorough conversations that have produced an agreement that will benefit all
parties while serving the public interest. The Parties therefore request that the Court enter this
agreement, which will provide certainty well in advance of the June 23 primary while allowing
all qualified Virginians to vote and protect their health.
FACTUAL BACKGROUND
On March 12, 2020, Virginia Governor Ralph S. Northam declared a state of emergency
in Virginia in response to the spread of a respiratory disease (COVID-19) caused by a novel coronavirus known as SARS-CoV-2.1 In the weeks that followed, the Governor closed all Virginia K-12 schools for the remainder of the academic year,2 advised that Virginians “with chronic health conditions or aged 65 or older should self-quarantine,”3 and issued a statewide
“Stay at Home” order to last until June 10, directing all Virginians to stay at home except under extremely limited circumstances.4 As of March 31, the Virginia Department of Health (“VDH”)
was reporting “widespread community transmission across the state.” COVID-19 cases in
Virginia continue to rise. As of today (April 27, 2020), Virginia reports 13,535 total cases, 2,066 hospitalizations, and 458 total deaths.5
1 Va. Exec. Order No. 2020-51 (Mar. 12, 2020), https://www.governor.virginia.gov/media/governorvirginiagov/governor-of-virginia/pdf/eo/EO-51-Declaration-of-aState-of-Emergency-Due-to-Novel-Coronavirus-(COVID-19).pdf. 2 Press Release, Ralph Northam, Governor of Virginia, Governor Northam Orders All Virginia K-12 Schools Closed for Minimum of Two Weeks (Mar. 13, 2020), https://www.governor.virginia.gov/newsroom/allreleases/2020/march/headline-854442-en.html; Press Release, Ralph Northam, Governor of Virginia, Governor Northam Orders Statewide Closure of Certain Non-Essential Businesses, K-12 Schools (Mar. 23, 2020), https://www.governor.virginia.gov/newsroom/all-releases/2020/march/headline-855292-en.html. 3 Press Release, Ralph Northam, Governor of Virginia, Governor Northam Announces New Measures to Combat COVID-19 and Support Impacted Virginians (Mar. 17, 2020), https://www.governor.virginia.gov/newsroom/allreleases/2020/march/headline-854487-en.html. 4 Va. Exec. Order No. 2020-55 (Mar. 30, 2020), https://www.governor.virginia.gov/media/governorvirginiagov/executive-actions/EO-55-Temporary-Stay-at-HomeOrder-Due-to-Novel-Coronavirus-(COVID-19).pdf. 5 Va. Dep’t of Health, COVID-19 in Virginia, http://www.vdh.virginia.gov/coronavirus/ (last visited Apr. 27, 2020).
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On April 17, Plaintiffs filed this action challenging the enforcement, during the ongoing public health crisis caused by the novel coronavirus, of the witness requirement (as stated in Va. Code § 24.2-706 and § 24.2-707 and as interpreted by 1 Va. Admin. Code 20-70-20(B)), under the First and Fourteenth Amendments of the U.S. Constitution and Section 2 of the Voting Rights Act. Among other relief requested, the Complaint sought to enjoin enforcement of the witness requirement for as long as public health officials continue to recommend social distancing practices due to the risk of community transmission of COVID-19. ECF No. 1 at 33.
On April 21, Plaintiffs filed a motion for preliminary injunction requesting this Court to prohibit the above-named Defendants from enforcing the witness requirement for all Virginia voters for the primary election to be held on June 23, 2020 (“June Primary”), and for all subsequent elections in Virginia until such time as in-person interactions required by compliance with the witness requirement no longer pose a risk to public health and personal safety. See ECF No. 17. Plaintiffs’ motion further requested that Defendants be ordered to issue guidance instructing election officials to count otherwise validly cast absentee ballots missing a witness signature and conduct a public information campaign in conjunction with city and county election officials about the elimination of the requirement. Plaintiffs’ motion included declarations from a highly qualified epidemiologist explaining the risks of enforcing the witness requirement for individual who live by themselves, from the Chief Election Officer of one of Virginia’s largest cities as to the impact the witness requirement was already having in the early phases of absentee balloting in a municipal election, and from Plaintiffs about how the witness requirement would deny them or, in the case of Plaintiff League of Women Voters of Virginia, their members, their vote in the June primary without relief, see ECF Nos. 17-1, 17-2, 17-4, 175, 17-6.
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On Friday, April 24, counsel for the parties engaged in settlement negotiations with a focus on Plaintiffs’ preliminary injunction motion, and reached an agreement in principle after several days of discussions, reflected in the proposed Partial Consent Judgment and Decree.
ARGUMENT A “consent decree has elements of both judgment and contract,” Smyth ex rel. Smyth v. Rivero, 282 F.3d 268, 280 (4th Cir. 2002). When “considering whether to enter a proposed consent decree, a district court should be guided by the general principle that settlements are encouraged.” United States v. North Carolina, 180 F.3d 574, 581 (4th Cir. 1999); see also Stovall v. City of Cocoa, Fla., 117 F.3d 1238, 1240 (11th Cir. 1997) (“District courts should approve consent decrees so long as they are not unconstitutional, unlawful, unreasonable, or contrary to public policy.”). This policy “to encourage settlements ‘has particular force where, as here, a government actor committed to the protection of the public interest has pulled the laboring oar in constructing the proposed settlement.’” United States v. E.I. du Pont de Nemours and Co., No. 5:16-CV-00082, 2017 WL 3220449, at *11 (W.D. Va. July 28, 2017) (quoting United States v. Cannons Eng’g Corp., 899 F.2d 79, 84 (1st Cir. 1990)). Nonetheless, the Court “must satisfy itself that the agreement ‘is fair, adequate, and reasonable’ and ‘is not illegal, a product of collusion, or against the public interest.’” North Carolina, 180 F.3d at 581 (quoting United States v. Colorado, 937 F.2d 505, 509 (10th Cir. 1991)). It need not, however, “inquire into the precise legal rights of the parties nor reach and resolve the merits of the claims or controversy” because “it is precisely the desire to avoid a protracted examination of the parties’ legal rights that underlies entry of consent decrees.” Bragg v. Robertson, 83 F. Supp. 2d 713, 717 (S.D. W. Va. 2000), aff’d sub nom. Bragg v. W. Va. Coal Ass’n, 248 F.3d 275 (4th Cir. 2001).
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The Parties meet all of the necessary requirements and have reached an agreement under time-sensitive circumstances that serves the public interest. I. The Court has Jurisdiction over the Partial Consent Judgment and Decree.
A “consent decree must spring from and serve to resolve a dispute within the court’s subject-matter jurisdiction.” Loc. No. 93, Intern. Ass’n of Firefighters, AFL-CIO C.L.C. v. City of Cleveland, 478 U.S. 501, 525 (1986). In terms of the subject-matter of this action, Plaintiffs’ claims squarely raise the sort of constitutional issue this Court is equipped to decide: whether state election practices burden the fundamental right to vote. See, e.g., Burdick v. Takushi, 504 U.S. 428, 434 (1992) (citing Anderson v. Celebrezze, 460 U.S. 780, 788 (1983)).
In terms of Article III standing, Plaintiffs have provided substantial evidence that they will be injured by the operation of the witness requirement during the June 23 primary if that witness requirement remains in place. Therefore, they have established “a substantial risk” of harm, Susan B. Anthony List v. Driehaus, 573 U.S. 149, 158 (2014), that can be remedied with respect to the June primary by waiving the witness requirement for voters who believe they may not safely have a witness present while completing their ballot.
Moreover, the substance of the agreement comes squarely within the scope of the case. Plaintiffs’ preliminary injunction sought relief from the witness requirement for the June primary and any future elections affected by the spread of COVID-19. The agreement provides such relief for the June primary, for voters who believe they may not safely have a witness present while completing their ballot. The Court has subject-matter jurisdiction over this proposed consent decree. II. The Proposed Consent Decree is Fair, Adequate, and Reasonable.
The district court has some flexibility in determining whether a proposed consent decree is fair, adequate, and reasonable, but in doing so, it “must assess the strength of the plaintiff’s
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case.” North Carolina, 180 F.3d at 581. This review “does not require the court to conduct a trial or a rehearsal of the trial,” but “to ensure that it is able to reach an informed, just and reasoned decision.” Id. (internal citations and quotations omitted). This review should take into account “the extent of discovery that has taken place, the stage of the proceedings, the want of collusion in the settlement and the experience of plaintiffs’ counsel who negotiated the settlement.” Id. (internal citations and quotations omitted). Overall, courts must judge the fairness of the compromise “by weighing the plaintiff’s likelihood of success on the merits against the amount and form of the relief offered in the settlement” but they “do not decide the merits of the case or resolve unsettled legal questions.” Carson v. Am. Brands, Inc., 450 U.S. 79, 88 n.14 (1981) (internal citation omitted).
Although this case is in its early stages, the issues raised by Plaintiffs demanded timesensitive resolution as they implicate the upcoming June primary. Many of the concerns raised by Plaintiffs—including the severity of COVID-19 in Virginia and the anticipated risks associated with the witness requirement as applied to certain voters in Virginia for the June 23 primary—are matters of public record. And because this consent decree only seeks partial relief and resolution of this action as it related to Plaintiffs’ preliminary injunction, the availability of discovery and timing of this partial settlement do not carry the same weight they might otherwise in a consent decree seeking full resolution of the litigation. Nonetheless, the Parties have each compromised in their positions in order to reach this agreement in recognition of the strength of Plaintiffs’ constitutional claim and the interest of the Commonwealth in (i) ensuring that all eligible Virginians need not jeopardize their health or public health to vote, (ii) protecting election integrity, and (iii) that resolution well before the primary will best equip election officials to carry out their duties.
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As to the strength of Plaintiffs’ case, they have provided valid evidence in their preliminary injunction briefing (ECF No. 17) that enforcing the witness requirement during this pandemic may lead to disenfranchisement of a significant number of qualified Virginians, risks to public health, or both. That evidence includes:
• A detailed declaration from a highly qualified epidemiologist explaining the risks of enforcing the witness requirement for individual who live alone, see ECF No. 17-1;
• Declarations from the League about its members and from the individual Plaintiffs who provided credible testimony about how the witness requirement would deny them their vote in the June primary without relief, see ECF Nos. 17-4, 17-5, 17-6;
• A declaration from the Chief Election Officer of one of Virginia’s largest cities as to the impact of witness requirement she is already observing during the pandemic, and disenfranchisement of voters who cannot comply, see ECF No. 17-2; and
• Statistical evidence from the Census Bureau that details the scale of the witness requirement’s potential impact on Virginians who live alone, and particularly older Virginians, Virginians with disabilities, and African-American Virginians, see ECF Nos. 17 at 14, 17-3 at 4.
Given the likely impact of the witness requirement on certain Virginia voters during the June primary, Plaintiffs had a very real chance of success on their preliminary injunction motion regardless of how the Court weighed the efficacy of the witness requirement in promoting election integrity.
Additionally, the fairness and reasonableness of the proposed decree is reflected in the concessions each party made that nonetheless result in an agreement that will benefit all parties and all Virginians. In their preliminary injunction, Plaintiffs sought an injunction against the witness requirement as to all Virginians not only for the June primary but for all future elections affected by community transmission of COVID-19. ECF No. 16 at 2. Plaintiffs will continue to seek such relief as this litigation moves forward. They also requested attorneys’ fees in their complaint and would have likely sought those if they prevailed. ECF No. 1 at 34. But the proposed consent decree provides Plaintiffs relief only for the June primary and is targeted to the
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subset of Virginia voters who believe they may not safely have a witness present while completing their ballot and waives the right to any fees and costs. Nonetheless, it confers on Plaintiffs the right to vote in June that they would have otherwise lost due to the COVID-19 public health crisis, and does so for many other Virginians, including some members of the League.
On Defendants’ side, though they have agreed to not enforce the witness requirement for the June primary for a limited category of voters (those who believe they cannot have a witness present while completing their ballot), they avoid the possibility of a broader, longer-term preliminary injunction that would apply to the entirety of the witness requirement for all voters, as well as the risk of owing attorneys’ fees. They also gain the valuable benefit of having certainty as to the requirements they will apply for absentee ballots in advance of the election, and with sufficient time to incorporate appropriate instructions and provide guidance to local election officials. Additionally, they gain the substantial benefit—as do all Virginians—of avoiding public health consequences of more qualified voters seeking to vote at the polls in June. As Plaintiffs’ preliminary injunction brief detailed, evidence is already emerging about COVID19 transmission occurring at the polls, ECF No. 17 at 6–7, with the latest report citing at least forty people in Milwaukee County, Wisconsin alone who have likely contracted COVID-19 from voting in-person on Election Day.6
Further supporting the fairness and adequacy of the settlement, the parties are each ably represented by experienced counsel. Plaintiffs’ counsel from the American Civil Liberties Union and ACLU of Virginia have decades of combined public interest litigation experience, including substantial experience litigating voting rights cases at all levels of federal courts, including the
6 Teran Powell, 40 Coronavirus Cases In Milwaukee County Linked To Wisconsin Election, Health Official Says, Milwaukee Journal-Sentinel, Apr. 24, 2020, https://www.wuwm.com/post/40-coronavirus-cases-milwaukee-countylinked-wisconsin-election-health-official-says#stream/0.
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Supreme Court, while Defendants have the experienced and specialized representation from the Office of the Attorney General. See, e.g., Carcano v. Cooper, No. 1:16CV236, 2019 WL 3302208, at *6 (M.D.N.C. July 23, 2019) (finding that “the parties have had the benefit of excellent legal counsel” including representation “by several major nonprofit legal organizations” including the ACLU and the “Defendants are well-represented by the North Carolina Department of Justice.”). And “when a settlement has been negotiated by a specially equipped agency, the presumption in favor of settlement is particularly strong.” Md. Dep’t of the Env. v. GenOn Ash Mgt., LLC, No. CIV. PJM 10-0826, 2013 WL 2637475, at *1 (D. Md. June 11, 2013). Here, this presumption certainly applies because the parties are the Virginia State Board of Elections and Commissioner of the Department of Elections—each of which has specialized experience safely administering elections in Virginia.
Because the proposed partial consent decree achieves a fair compromise that benefits all parties and the public interest, it meets the criteria of fairness, adequacy, and reasonableness. III. The Proposed Consent Decree is in the Public Interest, and not Illegal or Collusive.
The public interest “favors permitting as many qualified voters to vote as possible.” League of Women Voters of N.C. v. North Carolina, 769 F.3d 224, 247–48 (4th Cir. 2014) (citations and internal quotation marks omitted). It also favors “safeguarding public health.” Pashby v. Delia, 709 F.3d 307, 331 (4th Cir. 2013). Each of these interests is advanced by this agreement.
Many voters in Virginia who live alone may not able to violate social distancing protocols to have an individual outside their home witness their absentee ballot or to vote inperson, meaning that they would not be able to cast a vote or have their vote counted in June without this consent decree’s elimination of the witness requirement for these individuals. And this protection of the right to vote will happen without harming election integrity. To be clear, the relief in this proposed consent decree does not eliminate the witness requirement altogether
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and the witness signature line will remain on the ballot envelope, but provides specifically targeted relief to the subset of voters who believe they may not safely have a witness present while completing their ballot. Aside from the witness requirement, many other Virginia laws ensure proper absentee voting including provision of identifying information, a signed attestation confirming identity, eligibility, and lack of double-voting, and a check of the ballot against the list of ballot requests, see, e.g., Va. Code § 24.2-706, 1 Va. Admin. Code 20-70-20(B)(2)-(6), Va. Code § 24.2-710, and penalize malfeasance, see, e.g., Va. Code §§ 24.2-1004(B), 24.2-1012, 24.2-1016.
The proposed consent decree also serves public health in that it promotes the continuation of social distancing as recommended by the Governor and state and federal public health officials. In light of the seriousness of the COVID-19 health crisis, Governor Northam has declared a State of Emergency, closed all Virginia K-12 schools for the remainder of the academic year, advised Virginians “with chronic health conditions or aged 65 or older should self-quarantine,” and issued a statewide “Stay at Home” order to last until June 10. VDH has “urge[d] all Virginians to stay home and practice social distancing” and to “stay at least 6 feet away from others” if going out.7 As of April 27, VDH reported over 13,500 COVID-19 diagnoses in Virginia, resulting in 2,066 hospitalizations and 458 deaths.8 Additionally, the CDC recommends that states “[e]ncourage voters to use voting methods that minimize direct contact with other people.”9
7 Va. Dep’t of Health, Travelers, https://www.vdh.virginia.gov/coronavirus/coronavirus/travel-to-areas-withwidespread-ongoing-community-spread/ (last visited Apr. 27, 2020). 8 Va. Dep’t of Health, COVID-19 Cases in Virginia, http://www.vdh.virginia.gov/coronavirus/ (last visited Apr. 27, 2020). 9 Centers for Disease Control and Prevention, Recommendations for Election Polling Locations: Interim guidance to prevent spread of coronavirus disease 2019 (COVID-19), https://www.cdc.gov/coronavirus/2019ncov/community/election-polling-locations.html (last updated Mar. 27, 2020).
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Moreover, this agreement is neither illegal nor collusive. The agreement is necessary to protect the constitutional rights of Virginia voters and “violations of federal rights justify the imposition of federal remedies.” Common Cause Ind. v. Marion Cty. Election Bd., No. 117CV01388SEBTAB, 2018 WL 3770134, at *2 (S.D. Ind. Aug. 9, 2018). And the Court “has the authority to approve a settlement that modifies state law. Federal courts have broad power to remedy violations of the federal Constitution.” Dillard v. City of Foley, 926 F. Supp. 1053, 1065 (M.D. Ala. 1995) (citing Missouri v. Jenkins, 495 U.S. 33, 57 (1990) and Dillard v. Crenshaw County, 831 F.2d 246, 248 (11th Cir. 1987)).
Finally, this agreement was the product of a good-faith negotiation. The parties reached a partial agreement early in the case after time-sensitive, arms-length negotiations. It was only after Plaintiffs filed their complaint and preliminary injunction motion and the Court set a fast briefing schedule that negotiations resulted in a narrow agreement with respect to only the June election as to a specific category of voters. Nor is there any concern here about “elected state officials seek[ing] to bind their successors as to a matter about which there is substantial political disagreement,” Carcano, 2019 WL 3302208, at *6, as this agreement only covers the June 2020 primary for federal and some local offices.
The proposed Partial Consent Judgment and Decree therefore serves the public interest and is neither illegal nor collusive.
CONCLUSION The fast-paced nature of this case and upcoming elections dictated a particularly short and intense negotiation period. But the Parties’ negotiation was conducted in good faith, involved compromises on both sides leading to a cabined, fair, adequate, and reasonable deal, and resulted in an agreement that serves the public interests of election integrity, access to the
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ballot, and protecting public health. Because this decree meets all of the necessary requirements and considering that “settlements are encouraged” as a matter of public policy, North Carolina, 180 F.3d at 581, the Parties request that the Court approve the Partial Consent Judgment and Decree.

Dated: April 27, 2020
/s/ Davin M. Rosborough______________ Davin M. Rosborough (VSB # 85935) Dale E. Ho* Sophia Lin Lakin* Theresa J. Lee* Adriel I. Cepeda-Derieux* American Civil Liberties Union Foundation 125 Broad Street, 18th Floor New York, NY 10004 Tel.: (212) 549-2500 drosborough@aclu.org dho@aclu.org slakin@aclu.org tlee@aclu.org acepedaderieux@aclu.org
Vishal Agraharkar (VSB #93265) Eden Heilman (VSB #93554) AMERICAN CIVIL LIBERTIES UNION FOUNDATION OF AMERICA, INC. 701 E. Franklin Street, Suite 1412 Richmond, Virginia 23219 Phone: (804) 644-8080 Fax: (804) 649-2733 vagraharkar@acluva.org eheilman@acluva.org
Attorneys for Plaintiffs
*Admitted pro hac vice.

Respectfully submitted,
MARK R. HERRING Attorney General of Virginia By: /s/ Carol L. Lewis CAROL L. LEWIS (VSB #92362) MICHELLE S. KALLEN (VSB # 93286) HEATHER HAYS LOCKERMAN (VSB #65535) Office of the Attorney General 202 North Ninth Street Richmond, Virginia 23219 804-692-0558 (telephone) 804-692-1647 (facsimile) clewis@oag.state.va.us
Attorneys for Robert H. Brink, John O’Bannon, Jamilah D. LeCruise and Christopher E. Piper in their official capacities, and the Virginia State Board of Elections

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Case 6:20-cv-00024-NKM Document 36 Filed 04/27/20 Page 13 of 13 Pageid#: 378 CERTIFICATE OF SERVICE
I certify that on April 27, 2020, I served a copy of the foregoing Brief in Support of Joint Motion for Entry of Partial Consent Judgment and Decree via filing with the Court’s CMECF system, which sent copies of this document to Counsel of Record.
/s/ Davin M. Rosborough _______________ Davin M. Rosborough (VSB # 85935) American Civil Liberties Union Foundation 125 Broad Street, 18th Floor New York, NY 10004 Tel.: (212) 549-2500 drosborough@aclu.org Counsel for Plaintiffs
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 </s> Case 6:20-cv-00024-NKM Document 37 Filed 04/28/20 Page 1 of 34 Pageid#: 379

United States District Court for the Western District of Virginia
Lynchburg Division

League of Women Voters of Virginia; Katherine D. Crowley; Erikka Goff; and Seijra Toogood,,

Plaintiffs,

v.

Civ. No. 6:20-cv-00024

Virginia State Board of Elections; Robert H. Brink, John O’Bannon, and Jamilah D. Lecruise, in their official capacities as Chairman, Vice-Chair, and Secretary of the Virginia State Board of Elections, respectively; and Christopher E. Piper, in his official capacity as Commissioner of the Virginia Department Of Elections,

Voter Defendants’ Opposition to Plaintiffs’ Preliminary-Injunction Motion

Defendants.

Voter Defendants’ Opposition to Plaintiffs’ Preliminary-Injunction Motion1

Plaintiffs seek the extraordinary remedy of a preliminary injunction near an election when the U.S. Supreme Court’s Purcell Principle, see Part III.B, requires rejection of late changes to prevent vote deprivation and suspect elections—due to the confusion caused by the injunction itself—and to allow election officials to focus on conducting the election, not defending suits like this. The potential for all these harms is greater, not less, where there are COVID-19 concerns because election officials are working to run an election and provide voter safety, and voters’ attention is not focused on last-minute changes, expecting instead that they can rely on the usual procedures mandated by the General Assembly.

1 On April 22, 2020, Plaintiffs filed a preliminary-injunction motion seeking to remove the absentee-voting witness requirement. Intervening Defendants Sheila DeLappe Ferguson, Sandy Burchett, and Diane Crickenberger (collectively “Voters” or “Voter Defendants”) timely respond.

Voter Defs. Opp’n.

to Pls. Prelim. Inj.

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But Plaintiffs’ motion can readily be denied because they fail their burden to justify stripping the General Assembly’s vital safeguard against absentee ballot fraud (“Anti-Fraud Witness Requirement”). And their requested relief would violate Voter Defendants’ fundamental right to vote because the stripped safeguard would strongly increase the likelihood of illegal votes, thereby debasing by dilution Voter Defendants’ right to vote. See Reynolds v. Sims, 377 U.S. 533 (1964); Bush v. Gore, 531 U.S. 98 (2000). The requested relief would also violate the right to vote in other ways, established below. And it would violate the Elections Clause because a federal election must be conducted in the “Manner prescribed . . . by the Legislature,” U.S. Const. art. I, § 4, cl. 1, and the requested relief would remove what the General Assembly prescribed.
Facts

A. COVID-19 Plaintiffs paint a grim picture of COVID-19 that is no longer accurate. While it is true that
COVID-19 is a virus with serious potential consequences and has resulted in a global pandemic, the situation is beginning to improve.2 Indeed, the curve is flattening, the spread of the virus is being controlled, the death rate is lowering, testing is increasing, and the death rate is lower than originally expected.3 States are starting to relax their stay-at-home orders including reopening inter alia retail businesses, restaurants, gyms, beaches, salons; and restarting elective medical

2 See This is where all 50 states stand on reopening, CNN.com, https://www.cnn.com/inter active/2020/us/states-reopen-coronavirus-trnd/ (last visited April 26, 2020).
3 Id; see also Provisional Death Counts for Coronavirus Disease (COVID-19), Center for Disease Control and Prevention (“CDC”), https://www.cdc.gov/nchs/nvss/vsrr/covid19/index. htm (last visited April 27, 2020); COVIDView, CDC, https://www.cdc.gov/coronavirus/2019-nc ov/covid-data/covidview/index.html (last visited April 27, 2020); Coronavirus death rate may be lower than previously thought, LiveScience.com, https://www.livescience.com/death-rate-lower -than-estimates.html (last visited April 27 2020) (showing that the death rate is around .66%).

Voter Defs. Opp’n.

to Pls. Prelim. Inj.

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procedures.4 And many of the states that have not yet re-opened, have established plans to do so in the month of May.5
Any alleged risk of COVID-19 for the primary is purely speculative. Plaintiffs’ evidence, if taken as true, detailed the current state of the affairs at the time of filing. But as shown, this information shifts quickly, the situation is improving, and Plaintiffs’ information is already outdated. Moreover, at the time of filing Plaintiffs’ Motion, there were still 63 days until the primary election, so it cannot be said that the situation will be the same on or close to election day. And the election has already been moved once, so it is possible that the election could be delayed again if the situation in Virginia were not improved.
Social distancing and good hygiene practices are the most effective ways to stop transmission of the virus.6 Social distancing means “deliberately increasing the physical space between people to avoid spreading illness. Staying at least six feet away from other people lessens [the] chances of catching COVID-19.”7
These same social distancing and good hygiene practices— which are effective for preventing the spread of the virus when going out for essential services, like grocery shopping and other

4 See This is where all 50 states stand on reopening, CNN.com, https://www.cnn.com/inter active/2020/us/states-reopen-coronavirus-trnd/ (last visited April 26, 2020).
5 Id.
6 See Coronavirus disease (COVID-19) advice for the public, World Health Organization, https://www.who.int/emergencies/diseases/novel-coronavirus-2019/advice-for-public (last visited April 26, 2020); Stop the Spread of Germs, CDC, https://www.cdc.gov/coronavirus/2019-n cov/downloads/stop-the-spread-of-germs.pdf (last visited April 26, 2020).
7 Coronavirus, Social and Physical Distancing and Self-Quarantine, John Hopkins Medicine, https://www.hopkinsmedicine.org/health/conditions-and-diseases/ coronavirus/coronavirus -social-distancing-and-self-quarantine (last visited April 26, 2020).

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essential services—are also an effective way to prevent the spread of the virus for in-person voting or voting activities, such as finding a witness for an absentee ballot. Voters are able to vote in-person using social distance, gloves, masks, hand-sanitizer, etc. to protect themselves and others from the virus. Indeed, there has been no link between in-person voting and contracting of the disease—Plaintiffs do not claim or offer any evidence that the individuals listed in Pls. Prelim. Inj. Br., Doc. 17, Pageid#102-103, contracted the disease from the polling locations or from voting in-person. Moreover, weeks after the Wisconsin election, COVID-19 cases had not spiked.8 And voters can employ these same techniques for securing a witness for their absentee ballot. Therefore, it cannot be said that in-person voting or absentee-ballot voting (with the required Anti-Fraud Witness Requirement) increases the risk of contracting COVID-19.
B. Absentee Ballot Fraud Virginia history, past and present, is riddled with examples of voter fraud. Evidence of voter fraud in the Commonwealth starts as early as the 1960’s when a federal probe resulted in mail ballot fraud charges.9 There were similar allegations in the 1970s and 1980s.10 In 2004, 15 individuals were convicted of voter fraud after conspiring to manipulate the elections in Appalachia through various unlawful means, including buying votes, stealing absentee ballots, and forging

8 Two weeks after election, COVID-19 cases have not spiked in Wisconsin but experts urge caution about conclusions, Milwaukee Journal Sentinel, https://www.jsonline.com/story/news/20 20/04/22/covid-19-hasnt-spiked-after-wisconsin-election-experts-urge-caution/2997394001/ (last visited April 26, 2020).
9 Laurence Hammack, Trial Begins Form Mayor Charges Election Violations, THE ROANOKE TIMES, July 19, 2006, available at: https://www.roanoke.com/archive/trial-begins-forformer-mayor-charged-with-election-violations/article_e018b5b2-86c8-5c10-90b10b0dd05685a5.html.
10 Id.

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ballots.11 In 2016, there was an FBI investigation after 20 voter applications were made under the
names of dead people.12 And most recently, in 2018, a man committed voter fraud when he at-
tempted to cast absentee ballots for both himself and his deceased wife.13
As shown, efforts to commit voter fraud have continued, efforts which would only increase
in volume and rate of success if the Plaintiffs’ requested remedy is permitted.
C. Anti-Fraud Witness Requirement
In response to the instances of absentee ballot fraud, the General Assembly added the Anti-
Fraud Witness Requirement to combat and reduce this threat to democracy. The Anti-Fraud Wit-
ness Requirement requires that upon “receipt of a mailed absentee ballot, the voter shall, in the
presence of a witness, (I) open the sealed envelope marked ‘ballot within’ and (ii) mark and
refold the ballot, without assistance and without making known how he marked the ballot[.]” Va.
Code § 24.2-707(A). After marking the absentee ballot, the voter shall:
(a) enclose the ballot in the envelope provided for that purpose, (b) seal the envelope, (c) fill in and sign the statement printed on the back of the envelope in the presence of a witness, who shall sign the same envelope, (d) enclose the ballot envelope and any required assistance form within the envelope directed to the general registrar, and (e) seal that envelope and mail it to the office of the general registrar or deliver it personally to the general registrar.

11 Laurence Hammack, Ex-Mayor to Plead Guilty in Fraud Case, THE ROANOKE TIMES, Nov. 9, 2006, available at: https://www.roanoke.com/archive/ex-mayor-to-plead-guilty-in-votefraud-case/article_a5bb2cd8-a966-559a-ac3c-ffd955dc520b.html.
12 Graham Moomaw, Investigation Launched After Dead People Are Registered to Vote In Harrisonburg, Richmond Times-Dispatch, Sept. 29, 2016, available at: https://www.richmond.com/news/virginia/investigation-launched-after-dead-people-areregistered-to-vote-in/article_e008ce00-0365-57a2-95c0-4d9aa70012f9.html.
13 See Steve Roberts, Jr., Court Docs: James City Man Indicted on Voter Fraud Charges, THE MORNING CALL, April 9, 2019, available at https://www.mcall.com/va-vg-richard-dohmenindicted-0409-story.html.

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Id. There are no requirements that a witness be within six feet of a voter in order to witness the signature. In fact, it is implicitly required that a witness not be in close proximity to the voter, since the witness is not permitted to assist with the ballot or know how the ballot was marked. Id. D. Virginia’s E-Notary Laws
Virginia allows for electronic notarization (e-notarization). A properly designated notary may perform an “electronic notarial act” or “electronic notarization,” Va. Code §§ 47.1-2, which includes taking acknowledgments, administering oaths and affirmations, certifying copies of any document as a true copy, certifying affidavits or depositions of witnesses, perform verification of fact, and performing “such other acts as may be specifically permitted by law.” Va. Code § 47.112. A voter and notary could comply with the Virginia Anti-Fraud Witness Requirements via a video conference in which the voter would open and mark their ballots in the presence of the notary. See Va. Code § 24.2-707(A). The voter would then enclose their ballots in the provided envelope, seal the envelope, and “fill in and sign the statement printed on the back of the envelope” while the notary witnessed the process via the video conference technology. At that point, the enotary could supply a notarial certificate including an electronic seal, Va. Code § 47.1-2, to the voter to be included in the returned envelope. This would fulfill the Anti-Fraud Witness Requirement and retain an important safeguard.
Argument

In their attempt to strip the General Assembly’s Anti-Fraud Witness Requirement, Plaintiffs

were required to show (1) likely merits success, (2) irreparable harm, (3) a favorable balance of

equities, and (4) the public interest favoring their requested relief. Winter v. Natural Resources

Defense Council, 555 U.S. 7, 20 (2008). They have not made the “clear showing” required for

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such an “extraordinary remedy.” Id. at 24, 22. So Plaintiffs failed to meet their burden here. As
established below, Plaintiffs’ preliminary-injunction motion should be denied because:
I. Plaintiffs are unlikely to succeed on the merits because they have not satisfied the controlling analyses here established;
II. Plaintiffs are unlikely to succeed on the merits under Anderson-Burdick because the Anti-Fraud Witness Requirement is a “reasonable, nondiscriminatory restriction” readily justified as an anti-fraud safeguard;
III. Plaintiffs are unlikely succeed on the merits under Reynolds-Bush because their requested relief violates Defendant Voters’ fundamental right to vote, including under the Purcell Principle and the Elections Clause; and
IV. Plaintiffs cannot satisfy the remaining preliminary injunction requirements.
I.
Plaintiffs are unlikely to succeed on the merits because they have not satisfied the controlling analyses here established.
Plaintiffs are unlikely to prevail on the merits in their attempt to strike the General Assem-
bly’s Anti-Fraud Witness Requirement because they have not satisfied any of the controlling
analyses, all of which they must meet. Here we lay the analytical foundations and establish the
tests and analyses, which are further explained and applied in following Parts.
Preliminarily, note the three foundations of the controlling analyses. First, a fundamental
right to vote has been recognized as arising from the First and Fourteenth Amendments to the
U.S. Constitution. See, e.g., Harper v. Va. State Bd. of Elections, 383 U.S. 663, 667 (1966). Sec-
ond, to protect the rights of all voters, and to protect the Republic (by insuring the integrity of
elections and the confidence of the People that elections are fair), government must impose pro-
cedural safeguards against illegal voting because absent those there is (a) debasement of voters’
rights by dilution with illegal votes and (b) danger to a Republican form of government. See,
Bush v. Gore, 531 U.S. 98, 109 (2000) (“procedural safeguards” required). Third, there is no

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constitutional right to vote by absentee ballot, but rather it is the Legislature’s role to balance (a) the interest in voting of those with difficulties in doing so and (b) the anti-vote-fraud safeguards required to prevent debasement by dilution by illegal votes of all voters’ by right to vote and to protect the integrity of, and the people’s confidence in, the elections. Griffin v. Roupas, 385 F.3d 1128, 1130-31 (7th 2004). On those foundations are built the four controlling analyses.
The first is the Anderson-Burdick test. Anderson v. Celebrezze, 460 U.S. 780 (1983); Burdick v. Takushi, 504 U.S. 428 (1992). This test applies to state election laws and recognizes that government must have election procedures and safeguards, so there is considerable deference to that legislative need and the level of scrutiny goes up or down with the degree of burden at issue—assuming that the burden is cognizable and established. Id. at 434. As set out in Part II, the Anderson-Burdick test governs Plaintiffs’ challenge to the absentee-ballot-witness provision. But as shown there, Plaintiffs are unlikely to succeed on the merits because they can’t establish a sufficient burden to get beyond rational-basis review since (a) absentee voters can meet the witness requirement in several ways while socially distancing, (b) Plaintiffs’ portrayal of COVID19 problems is speculative and overblown, especially as problems diminish, and (c) any burden must be balanced against the need for anti-fraud safeguards, which Griffin held to be uniquely within the legislature’s power and abilities—and the General Assembly has already done the balancing. The General Assembly’s balanced approach is readily, rationally justified by the requirement that the General Assembly impose safeguards to protect (a) all voters’ right to vote and (b) the legitimacy of elections.
The second controlling analysis is in the Reynolds-Bush case line. Reynolds, 377 U.S. 533 (1964); Bush, 531 U.S. 98. This analysis applies specifically to debasement of the right to vote

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by dilution, which is either a per-se ban or considered under strict scrutiny. See Part III. And as set out in Part III, this analysis applies to establish that what Plaintiffs seek would unconstitutionally debase by dilution Voter Defendants’ (and all voters’) fundamental right to vote.
The third controlling analysis is the Purcell Principle, by which the U.S. Supreme Court requires lower federal courts to not alter election procedures and protections near an election because doing so engenders confusion that in itself violates the right to vote and the integrity of elections. Under that Principle, near-election requested relief is simply not granted. See Part III.B.
The fourth controlling analysis is the dictate of the Election Clause, U.S. Const. art. I, § 4, cl. 1, that federal elections (at issue here given federal candidates) be conducted in the “Manner . . . prescribed by the Legislature.” Here the General Assembly has prescribed a “Manner” that Plaintiffs ask this Court to remove—a safeguard against absentee-ballot fraud—so that requested relief cannot be granted absent a truly clear federal constitutional violation. See Part III.C.
II.
Plaintiffs are unlikely to succeed on the merits under Anderson-Burdick because the Anti-Fraud Witness Requirement is a “reasonable, nondiscriminatory
restriction” readily justified as an anti-fraud safeguard. To begin with, there is a state-action problem. Plaintiffs don’t challenge the Anti-Fraud Witness Requirement as unconstitutional absent COVID-19, only during COVID-19 problems, Complaint, Doc. 1, Pageid#33 (Relief Requested for while under “emergency orders” and “social distancing”). But COVID-19 and resulting problems “are not impediments created by the State.” Bethea v. Deal, 2016 WL 6123241, at *2 (S.D. Ga. Oct 19, 2016). Plaintiffs don’t challenge the Governor’s action in moving the election. So Plaintiffs believe the Commonwealth has passive

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liability for not changing its law in the face of issues not of its making, which is not the sort of
claim Anderson-Burdick balances, which are legislative acts. See Bethea, id. at *2-3 (no “prece-
dent that would constitutionally or statutorily mandate that Defendants provide an extension in
the absence of any actual government action that burdens an individual’s right to vote”).
But if balancing is done here, Plaintiffs acknowledge that their challenge to the Anti-Fraud
Witness Requirement would be governed by the Anderson-Burdick test. Pls.’ Prel. Inj. Br., Doc.
17, Pageid#112.14 They are unlikely to succeed on the merits under that test. The test requires
“weighing ‘the character and magnitude of the asserted injury to the rights . . . that the plaintiff
seeks to vindicate’ against ‘the precise interests put forward by the State as justifications for the
burden imposed by its rule,’” considering “‘the extent to which those interests make it necessary
to burden the plaintiff’s rights.’” Burdick, 504 U.S. at 434 (quoting Anderson, 460 U.S. at
788–89). Under this test, strict scrutiny applies to “‘severe’ restrictions,” id. at 434, but rational-
basis scrutiny applies to “reasonable, nondiscriminatory restrictions”:
the rigorousness of our inquiry into the propriety of a state election law depends upon the extent to which a challenged regulation burdens First and Fourteenth Amendment rights. Thus, as we have recognized when those rights are subjected to “severe” restrictions, the regulation must be “narrowly drawn to advance a state interest of compelling importance.” Norman v. Reed, 502 U.S. 279, 289 (1992). But when a state election law provision imposes only “reasonable, nondiscriminatory restrictions” upon the First and Fourteenth Amendment rights of voters, “the State’s important regulatory interests are generally sufficient to justify” the restrictions. Anderson, 460 U.S. at 788; see also id., at 788-789, n. 9.
As established next, (A) the Anti-Fraud Witness Requirement is a “reasonable, nondiscrimi-

14 Count II of the Complaint alleges “Violations of Section 2 of the Voting Rights Act, 52 U.S.C. § 10301,” Complaint, Doc. 1, Pageid#31, but Plaintiffs’ preliminary-injunction-brief Table of Authorities shows that provision is not cited, Pls.’ Prel. Inj. Br., Doc. 17, Pageid#90, so that is not at issue here.

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natory restriction, and (B) it is readily justified by the Commonwealth’s vital anti-fraud interest.
A. The Anti-Fraud Witness Requirement is a “reasonable, nondiscriminatory restriction.”
The Anti-Fraud Witness Requirement is (1) “reasonable” and (2) “nondiscriminatory.”
These are established in turn below.
Preliminarily note that this is not a new issue in current, similar litigation. In the litigation
before Wisconsin held its recent primary with in-person and ordinary-absentee-ballot-rule vot-
ing, the U.S. District Court for the Western District of Wisconsin considered a similar challenge
to an absentee-ballot-witness requirement and provided relief similar to that requested here.
Democratic National Committee v. Bostelmann, Nos. 3:20-cv-00249-wmc, 3:20-cv-00278-wmc,
3:20-cv-00284-wmc, 2020 U.S. Dist. LEXIS 57918 (W.D. Wisc. Apr. 2, 2020). But that was
promptly stayed by the Seventh Circuit. Bostelmann, slip op. 3,15 Nos. 20-1538, 20-1539,
20-1545 & 20-1546 (7th Cir. Apr. 3, 2020) (citing Griffin, 385 F.3d at 1130). The Seventh Cir-
cuit held that the relief was overbroad and the district court had not adequately considered the
government’s strong anti-fraud interest and the Purcell Principle:
[T]he motions for a stay are GRANTED as to that portion of the district court’s order that enjoins the enforcement of Wis. Stat. § 6.87(2) for absentee voters who provide a written affirmation or other statement that they were unable to safely obtain a witness certification despite reasonable efforts to do so. The court concludes that the district court did not give adequate consideration to the state’s interests in suspending this requirement. Burdick v. Takushi, 504 U.S. 428, 434 (1992); Anderson v. Celebrezze, 460 U.S. 780, 789 (1983); Griffin v. Roupas, 385 F.3d 1128, 1130 (7th Cir. 2004). “Confidence in the integrity of our electoral processes is essential to the functioning of our participatory democracy,” and “[v]oter fraud drives honest citizens out of the democratic process and breeds distrust of our government.” Purcell v. Gonzalez, 549 U.S. 1, 4 (2006). The court is also cognizant of the Supreme Court’s admonition that “[c]ourt orders affecting elections . . . can them-

15 The slip opinion could not be found on LEXIS or Westlaw, but it is available at https://moritzlaw.osu.edu/electionlaw/litigation/documents/DNC_v_Bost_BL-30.pdf.

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selves result in voter confusion and consequent incentive to remain away from the polls. As an election draws closer, that risk will increase.” Id. at 4-5. This court is concerned with the overbreadth of the district court’s order, which categorically eliminates the witness requirement applicable to absentee ballots and gives no effect to the state’s substantial interest in combatting voter fraud. Griffin, 385 F.3d at 1130. Slip op. at 3. That same logic and analysis should be applied here to reject requested relief. Also preliminarily, note that the requested relief here is also overbroad. Part of that overbreadth is that Plaintiffs make a facial challenge. The Complaint seems at one point to seek a narrower, as-applied remedy, Complaint, Doc. 1, Pageid#33 (“especially for voters at risk of health complications”), but then it seeks the broad, facial remedy of dispensing with the AntiFraud Witness Requirement altogether, id. at. Pageid#34 (“count . . . absentee ballots . . . missing a witness signature”). And Plaintiffs’ preliminary-injunction brief argues for facial invalidation of the Requirement. See, e.g., Pls. Prelim. Inj. Br., Doc. 17, Pageid#96 (“Plaintiffs are thus likely to succeed on their claim that the witness requirement unconstitutionally burdens the fundamental right to vote.”); see also id. at Pageid#129 (Conclusion seeks facial relief of disregarding absent signatures). But for such a facial challenge, Plaintiffs must establish that no circumstances exist where the Requirement could be validly applied. United States v. Salerno, 481 U.S. 739, 745 (1987) (“A facial challenge to a legislative Act is, of course, the most difficult challenge to mount successfully, since the challenger must establish that no set of circumstances exists under which the Act would be valid”). Plaintiffs have made no effort to meet that required test,16 and so requested relief must be denied on that basis alone. “[T]he burden some voters face[] ca[n]not prevent the state from applying the law generally.” Frank v. Walker, 819 F.3d 384, 386 (7th Cir.

16 Though Plaintiffs speculate that the allegedly too-high burden would particularly impact certain demographics, they make no effort to tailor their remedy to those.

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2016). And given the “broad attack” Plaintiffs bring—not a narrow, as-applied challenge—they “bear a heavy burden of persuasion” to prevail. Crawford, 553 U.S. at 200.
The requested relief is also overbroad because it seeks relief so long as there is a Virginia or federal emergency order in place “regarding COVID-19 transmission” “and/or while public health officials continue to recommend social distancing practices due to risk of community transmission of COVID-19 . . . .” Complaint, Doc. 1, Pageid#33. Of course related emergency orders might be in place long after there is a significant risk of harm because they permit special assistance from and actions by governmental entities, which might be needed even after the serious risk is subsiding to deal with the aftermath. And social distancing recommended in such orders and by health authorities is for the purpose of making individuals safe, so it is what can be done during in-person and ordinary absentee-ballot-procedure voting, providing no reason to alter those normal procedures. So this overbreadth also dooms requested relief.
1. The Anti-Fraud Witness Requirement is reasonable. A witness requirement for absentee ballots is well within the scope of reasonable tools that the General Assembly could choose in asserting its undisputed interest in preventing vote fraud and insuring both actual and apparent election integrity. Burdick recognized that “‘as a practical matter, there must be a substantial regulation of elections if they are to be fair and honest and if some sort of order, rather than chaos, is to accompany the democratic processes.’” 504 U.S. at 433 (citation omitted; emphasis added). As noted above, the Seventh Circuit rejected a similar challenge based on the strong governmental interest in preventing vote fraud. See supra at 11 (Bostelmann and cited authorities). So the Anti-Fraud Witness Requirement is an inherently reasonable, traditional way that a state may combat ballot fraud—and how prevalent that is or isn’t

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need not be established because this interest is well established and cognizable without more. Burdick requires a balancing of the degree of burden on the right to vote with a state’s appli-
cable interests. 504 U.S. at 434. The degree of burden is discussed next, which must be balanced against the Commonwealth’s interests established in Part II.B. With proper balancing, the Requirement is readily established as a reasonable, neutral burden justified by state interests.
The benchmark for a reasonable burden is Crawford v. Marion Cty. Election Bd., 553 U.S. 181 (2008), which under Burdick held that it was not unreasonable to require those lacking photo identification (required to vote) to bear “the inconvenience of going to the Bureau of Motor Vehicles, gathering required documents, and posing for a photograph” to get a free ID card because that did “not qualify as a substantial burden on most voters’ right to vote . . . ,” id. at 198 (Stevens, J., joined by Roberts, C.J. and Kennedy, J.) (controlling op.). This insubstantial burden was closely related to legitimate state interests in “election modernization” (including cleaning up voter roles), preventing “voter fraud,” and “safeguarding voter confidence.” Id. at 192-97. As that burden was reasonable, Plaintiffs must prove any burden here substantially greater.
Plaintiffs don’t actually dispute that the Commonwealth has strong interests in preventing fraud and assuring election integrity. They acknowledge that ordinarily the Anti-Fraud Witness Requirement imposes “perhaps only a minor-to-moderate burden on the right to vote.” Pls. Prelim. Inj. Br., Doc. 17, Pagid#95. But, “[d]uring the pandemic,” Plaintiffs allege, “it will force thousands of voters to choose between disenfranchisement and placing their health at grave risk,” id., and “thousands” jumps to “tens of thousands” later. Id. Pageid#111. That claim is overblown and wrong.
Plaintiffs’ projections are as speculative as the early COVID-19 models with highly inflated

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numbers of deaths. Those projections were subsequently, substantially reduced more than once. Plaintiffs cite a March 11, 2020 Wall Street Journal article in asserting that “COVID-19 [is] a deadly disease that is now a global pandemic.” Complant, Doc.1, Pageid#10, ¶ 28.17 No one disputes it has been declared a pandemic and it has been deadly. But that was a March 11 article and much has already changed since then to undercut this claimed factual foundation for stripping the Anti-Fraud Witness Requirement, and much more will change before the June 23 primary, nearly two months from now. This Court may and should take judicial notice of the widespread news, reports, studies, findings, and changing government declarations and guidelines that show the downward-changing projections of deaths from the virus, the lowered fatality rate (as it is learned that more individuals were infected than thought and only had moderate or mild illness or no symptoms), the lowered hospitalization rates, the dramatic increase in testing capabilities, the surplus supply of ventilators, the lack of hospitals and medical staff being overwhelmed due to the flattening curve, the shut-down of unneeded extra hospital facilities in New York, the development of treatments, the ongoing clinical trials of treatments, the progress being made on vaccines, the success of social distancing and hand washing and mask wearing, the likely (though yet debated) rise of individual and herd immunity,18 as well as the widespread and ongoing reopening of society by government officials due to the reducing risk. See supra Facts (outlining some of these commonly known facts). For example, Wisconsin had an in-person

17 Plaintiffs similarly cite newspaper and other articles, of which this Court may and should take judicial notice, weighing their credibility based on the Court’s own experience.
18 Since the development of herd immunity is a typical human response to viruses, Plaintiffs have the burden to establish that it will not happen with COVID-19, just as they have the burden for all proof for their preliminary-injunction motion.

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election, with distancing, masks, gloves, hand sanitizing, facilities sanitizing, and plexiglass shields between election-board workers and voters, and there was no resulting spike in COVID19. See supra note 8. And as Plaintiffs acknowledge, the Commonwealth’s Governor already moved the federal primary from May 5 to June 23, nearly two months from now, so he could do it again if needed to allow more time for dangers to further subside. Pls. Prelim. Inj. Br., Doc. 17, Pageid#103-04. Plaintiffs speculate while harms recede, undercutting their foundation. For present analytical purposes any burden posed by COVID-19 is receding and should continue to do so over the next two months.
Government guidelines for present still encourage social distancing, wearing masks, and frequent hand washing or sanitizing. But they don’t prevent going out for essential services, such as grocery shopping. Essential services include important government activities, which includes voting and activities related to voting, such as finding a witness to witness the signing of a ballot. One can avoid this requirement by going to the polls, and there practice social distancing and other measures to prevent harm as was done in Wisconsin’s recent election.
And there are ways to socially distance with a witness.19 For example, a voter may go to a neighbor’s house, knock and step back six feet, explain the need to the neighbor, sign the absentee ballot in the witness’s presence, place the ballot down where one is standing and back up six feet so the witness can pick up the ballot and sign it before backing up so the voter can retrieve the ballot and finish the procedure while being witnessed. This voter-witness dance is quite simple, as are easy variations to fit different situations.

19 The following example ideas were provided by the Wisconsin Legislature in an amicus brief in Bostlemann, No. 3:20-cv-249 and -278, Doc. 31 at 19-20 (Mar. 30, 2020).

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Or have the witness observe through a window, then slide the signed ballot under the door for the witness’s signature, who then slides it back under the door and backs up so the voter can retrieve the ballot remaining six feet away with a door between. The same can be done with a cell-phone or online video connection in place of the window, followed by the door-slide procedure described.
Or a voter and e-notary could comply with the Anti-Fraud Witness Requirement via a video conference. See supra at 6. This would fulfill the Anti-Fraud Witness Requirement and retain an important safeguard.
These and other similar options are easily done and not beyond the reasonable efforts of most people—and they must make the sort of reasonable efforts required in Crawford. Almost all people who live alone can do something like what is described. For those who truly can’t, a narrow as-applied challenge might be appropriate, but Plaintiffs have brought a broad facial challenge so they must meet the Salerno test, and they have not shown that the foregoing options won’t allow most people to vote with the required reasonable effort—let alone show that there are no situations in which the Anti-Fraud Ballot Requirement may be applied. So most people can satisfy the Anti-Fraud Witness Requirement while complying with social distancing, mask wearing, and hand washing guidelines with no more reasonable effort than was required in Crawford. Certainly, Plaintiffs have not proven otherwise, and they have the preliminary-injunction burden and the Salerno burden in this preliminary-injunction motion. So under Burdick, there is no severe burden and no strict scrutiny for this reasonable requirement.

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2. The Anti-Fraud Witness Requirement is nondiscriminatory. Burdick speaks of “reasonable, nondiscriminatory restrictions.” 504 U.S. at 434. As just shown, the Anti-Fraud Witness Requirement is reasonable. It is also nondiscriminatory. On its face, it requires a witness for every absentee voter, without regard to who they are or anything unique about them, certainly not with regard to anything relating to some suspect class (though this is a Burdick analysis, not an equal-protection analysis, so suspect-class analysis is not involved). Plaintiffs talk of a history of racism, but that has nothing to with the neutral requirement that every absentee voter has a witness. And Plaintiffs argue about problems for certain subsets of individuals, but that fails to prove a Burdick violation for two simple reason. First, they have not shown that anyone in any subset can’t perform the reasonable effort to obtain a witness that is outlined above and is no more difficult that what the U.S. Supreme Court held to be reasonable in Crawford. So as in Crawford, “we cannot conclude that the statute imposes ‘excessively burdensome requirements’ on any class of voters.” 553 U.S. at 202 (citation omitted). Second, “[g]iven the fact that petitioners have advanced a broad attack . . . , seeking relief that would invalidate the statue in all its applications, they bear a heavy burden of persuasion.” Id. at 201 (citing Wash. State Grange v. Wash. State Republican Party, 552 U.S. 442 (2008)). “A facial challenge must fail where the statute has a plain plainly legitimate sweep.” Id. at 202 (citations omitted; quotations marks altered). Consequently, “[w]hen we consider only the statute’s broad application to all [Virginia] voters we conclude that it ‘it imposes only a limited burden on voters’ rights.’” Id. at 202-203 (quoting Burdick, 504 U.S. at 439). And that analysis controls here. So the Anti-Fraud Witness Requirement does not discriminate in any cognizable way.

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B. The Anti-Fraud Witness Requirement is readily justified by the Commonwealth’s vital interests in preventing vote fraud and safeguarding voter confidence. As established, the Anti-Fraud Witness Requirement is a reasonable, nondiscriminatory re-
quirement. As such, it is easily justified by the Commonwealth’s strong interests in preventing absentee-ballot fraud and protecting the integrity of elections. See, e.g., Crawford, 553 U.S. at 194-97 (recognizing state interests in preventing “voter fraud” and “safeguarding voter confidence” ). The Requirement prevents and discourages vote fraud in multiple ways. It assures that the voter is actually the one filling out the ballot. The witness can assure that the voter is not being coerced or unduly influenced. See Principles of Election Law § 103, cmt. c (Am Law Inst. 2018) (“through intimidation, other undue influence, or outright vote buying”). And the witness can assure that the voter is signing her ballot spontaneously, without trying to reproduce another’s signature from an exemplar. Absent the Requirement, absentee ballots could be seized from mail boxes and voted by others. See Veasey v. Abbott, 830 F.3d. 216, 255-56 (5th Cir. 2016) (en banc) (“people who harvest mail-in ballots from the elderly”). “[V]oting fraud is a serious problem in U.S. elections generally,” which is facilitated by absentee voting.” Griffin, 385 F.3d at 1130-31. “Voting by mail makes vote fraud much easier to commit.” Nader v. Keith, 385 F.3d 729, 734 (7th Cir. 2004). “Absentee ballots remain the largest source of potential voter fraud.” Carter-Baker Comm’n on Fed. Elections Reform, Building Confidence in U.S. Elections 46 (2005). Also on the Commonwealth’s side of the balance is assuring the integrity of elections, of which preventing and discouraging absentee-ballot fraud is part. The Commonwealth has an “indisputably . . . compelling interest in preserving the integrity of its election process.” Eu v. San Francisco County Democratic Central Committee, 489 U.S. 214, 231 (1989); see also

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Purcell v. Gonzalez, 549 U.S. 1, 4 (2006) (per curiam) (same). And this integrity is achieved when “only the votes of eligible voters” are counted. Crawford, 553 U.S. at 196). “[T]he striking of the balance between discouraging fraud and other abuses and encouraging turnout is quintessentially a legislative judgment . . . .” Griffin, 385 F.3d at 1131. And the Commonwealth has struck a balance that under Burdick is a permissible, reasonable, nondiscriminatory balance.
III.
Plaintiffs are unlikely to succeed on the merits under Reynolds-Bush because their requested relief violates Defendant Voters’ fundamental right to vote,
including under the Purcell Principle and the Elections Clause. While the Anti-Fraud Witness Requirement is a reasonable, nondiscriminatory restriction, and is readily justified by the Commonwealth’s vital anti-fraud interest, the remedy that Plaintiffs seek is unconstitutional. Defendant Voters have a fundamental right to vote, which includes the right to not have their votes debased or diluted by removal of vital safeguards. A. The requested violates the right to vote by removing safeguards against fraudulent votes that dilute legal votes. The requested relief strips a vital safeguard established by the General Assembly designed to protect against fraudulent votes that dilute Voters’ votes. This lack of a mandatory safeguard is a severe burden on Voters’ fundamental right to vote. The federal right to vote is fundamental, Harper, 383 U.S. at 667, and well-established: “Undeniably the Constitution of the United States protects the right of all qualified citizens to vote, in state as well as in federal elections” and to have that vote counted. Reynolds, 377 U.S. at 554. “The right to vote can neither be denied outright, nor destroyed by alteration of ballots, nor diluted by ballot-box stuffing.” Id. at 555 (internal citations omitted). “And the right of suffrage

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can be denied by a debasement or dilution of the weight of a citizen’s vote just as effectively as by wholly prohibiting the free exercise of the franchise.” Id. The right to vote inheres in, and is protected by, the First and Fourteenth Amendments of the U.S. Constitution. Virginia also recognizes the right to vote. See Va. Const. Art. II, § 1 (detailing the qualifications of voters).
The Anderson-Burdick test does not apply when evaluating the constitutionality of the requested relief, even though it would typically govern actual challenges to Virginia’s legislatively enacted election laws. This is so because the test by its terms applies to “[I] a challenge to [ii] a state election law,” id., and the requested relief involves no “challenge to” any “state election law.” The requested relief is not legislated “state election law,” but rather it would require this Court to override and replace legislated state election law. So the Anderson-Burdick test doesn’t apply to evaluating the constitutional infirmities of the requested relief.
Rather, the applicable scrutiny where voter disenfranchisement is involved, such as by vote dilution, is found in the Reynolds-Bush case line. Reynolds, 377 U.S. 533; Bush, 531 U.S. 98.20 In considering whether, under the federal Equal Protection Clause, “any constitutionally cognizable principles . . . would justify departures from the basic standard of equality among voters,” Reynolds, 377 U.S. at 561, Reynolds held that the right to vote is “fundamental”: “Undoubtedly, the right of suffrage is a fundamental matter in a free and democratic society.” 377 U.S. at 56162. So franchise impairments get careful, meticulous scrutiny: “Especially since the right to exercise the franchise in a free and unimpaired manner is preservative of other basic civil and polit-

20 Though Bush was decided long after Anderson and Burdick, no opinion in Bush cited Burdick and only one concurrence cited Anderson, once, but for another proposition. 551 U.S. at 112 (Rehnquist, joined by Scalia and Thomas, JJ., concurring). So those older cases have no bearing on the required analysis here.

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ical rights, any alleged infringement of the right of citizens to vote must be carefully and meticulously scrutinized.” Id. at 562. After reviewing arguments that these were “complex” issues, the Court held that “[t]o the extent that a citizen’s right to vote is debased, he is that much less a citizen,” id. at 567, and “an individual’s right to vote for state legislators is unconstitutionally impaired when its weight is in a substantial fashion diluted when compared with votes of citizens living in other parts of the State,” id. at 568.
Building on Reynolds, Bush didn’t discuss the scrutiny level, but held that the Florida Supreme Court could not by its orders and interpretations of state law dilute voters’ fundamental right to vote, 551 U.S. at 107-11, which was either a per-se ban of vote dilution or at least an exercise of the strict scrutiny now required in equal-protection challenges involving fundamental rights with an analysis and outcome so readily apparent that it required no detailing.
Bush is particularly analogous because it addressed the actions of the Florida Supreme Court (not the legislature) and found them in violation of the vote-dilution barred by Reynolds. The issue here, is action by this Court that would do the same, were the Court to grant Plaintiffs’ requested relief. Bush noted that “[t]he petition present[ed] the following questions: whether the Florida Supreme Court established new standards for resolving Presidential election contests, thereby violating Art. II, § 1, cl. 2, of the United States Constitution[21] and failing to comply with 3 U.S.C. § 5, and whether the use of standardless manual recounts violates the Equal Protection and Due Process Clauses.” 551 U.S. at 103. The Court found that “it is not necessary to

21 In elections selecting federal candidates, this provision mandates that the Legislature, establish procedures: “Each State shall appoint, in such Manner as the Legislature thereof may direct . . . . .” So the requested relief here could not be used in choosing federal candidates because it is not the Manner directed by the Legislature. See Part III.C.

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decide whether the Florida Supreme Court had the authority under the legislative scheme for resolving election disputes to define what a legal vote is and to mandate a manual recount implementing that definition,” id. at 105, because “recount mechanisms implemented in response to the decisions of the Florida Supreme Court do not satisfy the minimum requirement for nonarbitrary treatment of voters necessary to secure the fundamental right,” id. Bush also noted that where both sides claim they are vindicating the right to vote, constitutional guarantees such as equal protection still control. Id. at 105.22 And Bush highlighted the fact that the Florida Supreme Court order lacked the necessary “safeguards” to assure confidence in the outcome. As Bush put it, adequate “safeguards” are mandatory, id. at 109:
[W]e are presented with a situation where a state court with the power to assure uniformity has ordered a statewide recount with minimal procedural safeguards. When a court orders a statewide remedy, there must be at least some assurance that the rudimentary requirements of equal treatment and fundamental fairness are satisfied. That mandate to maintain “safeguards” to assure confidence in the election is particularly relevant to Defendant Voters’ argument below. So the requested relief here is either barred per se23 if votes are diluted or it would be subject to strict scrutiny and Plaintiffs must prove it is narrowly tailored to a compelling governmental interest.

22 As Bush put it, regarding both sides claiming they advance the right, id.:
There is no difference between the two sides of the present controversy on these basic propositions. Respondents say that the very purpose of vindicating the right to vote justifies the recount procedures now at issue. The question before us, however, is whether the recount procedures the Florida Supreme Court has adopted are consistent with its obligation to avoid arbitrary and disparate treatment of the members of its electorate.
23 If government may not dilute voters’ right to vote, doing so cannot be justified under any interest-tailoring analysis.

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Under Reynolds and Bush it is readily seen that vote dilution cannot be justified. The requested relief violates the Voters’ right to vote by diluting their votes with illegal votes given the removal of a vital safeguard against illegal voting established by the General Assembly.24 It is all but certain that, without the Anti-Fraud Witness Requirement, many absentee ballots will be unlawfully received, voted, and counted in the primary, as Virginia has a significant history with absentee ballot fraud. See supra pages 4-5 (detailing absentee voting fraud issues from 1960s to modern day); see also Griffin, 385 F.3d at 1130-31 (“Voting fraud is a serious problem in the U.S. . . . and is facilitated by absentee voting. . . . [A]bsentee voting is to voting in person as a take-home exam is to a proctored one.”) (citations omitted). Those individuals who illegally vote will unlawfully negate and ultimately dilute the choices made by the lawfully registered voters of the Commonwealth— voters the General Assembly has carefully and methodically taken great care to protect.25
Since the requested relief dispenses with current statutory protections against illegal voting

24 While vote dilution in Reynolds and Bush was reviewed under an equal-protection analysis, Reynolds held that “[t]he right to vote can neither be denied outright, nor destroyed by alteration of ballots, nor diluted by ballot-box stuffing.” 377 U.S. at 555 (internal citations omitted), and those violations don’t involve equal protection. “[T]he right of suffrage can be denied by a debasement or dilution of the weight of a citizen’s vote just as effectively as by wholly prohibiting the free exercise of the franchise,” id., which is not limited to the equal-protection context. Likewise, “the Fifteenth and Nineteenth Amendments prohibit a State from overweighting or diluting votes on the basis of race or sex,” id. at 557, which is not limited to the equal-protection context. So challenges based on vote debasement or dilution are not limited to the equal-protection context.
25 Plaintiffs claim that the Anti-Fraud Witness Requirement has been ineffectual. Pls. Prelim. Inj. Br., Doc. 17, Pageid# 86, 129. But Plaintiffs cite no evidence to support that claim. Plaintiffs further argue that the witness requirement is unnecessary because “attempts to manipulate the absentee process” are rare. Id. at 123. But as shown, there have been many efforts to manipulate the absentee voting process. Eliminating this safeguard would surely lead to more manipulation efforts.

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found in absentee law, the requested relief is a cognizable dilution of the votes of eligible, registered voters such as Defendant Voters. That risk is cognizable because “safeguards” are required, Bush, 531 U.S. at 109, and because “confidence in the integrity of our electoral processes is essential to the functioning of our participatory democracy” and “[v]oter fraud drives honest citizens out of the democratic process and breeds distrust of our government.” Purcell, 549 U.S. at 4. This dilution requires strict scrutiny, because “any alleged infringement of the right of citizens to vote must be carefully and meticulously scrutinized.” id. at 562, which the requested relief fails.
While strict scrutiny is required (if the requested relief is not barred per se), Plaintiffs have not justified their requested relief, which must be established if the requested relief is constitutional. Absent their proof that removal of the Anti-Fraud Witness Requirement is justified under the controlling interest-tailoring analysis, the requested relief must be considered an unconstitutional violation of Voter Defendants’ right to vote and rejected.
In sum, because the weakened safeguards in the requested relief predict dilution and debasement by illegal voting and create doubt about the legitimacy of the election, the right to vote of Defendant Voters is violated. B. The requested relief violates the right to vote under the Purcell Principle.
The requested relief also violates what has come to be called the Purcell Principle. See, e.g., Richard L. Hasen, Reining in the Purcell Principle, 43 Fl. St. U. L. Rev. 427 (2016). That Principle is named for Purcell, 549 U.S. 1. The Principle is anchored in the right to vote and its potential for debasement. Id. at 4 (citing Reynolds, 377 U.S. at 555). Among its critiques of the Ninth Circuit for staying a voter-identification requirement near an election, the Court held in Purcell

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that such near-election court orders themselves risk debasement and dilution of the right to vote because “[c]ourt orders affecting elections, especially conflicting orders, can themselves result in voter confusion and consequent incentive to remain away from the polls. As an election draws closer, that risk will increase.” 549 U.S. at 4-5. The “possibility that qualified voters might be turned away from the polls,” id. 4, violates their right to vote. So the general rule is that no court order altering election procedures near an election is permissible because it violates the right to vote. And because the Principle is anchored in the right to vote, it applies to state and local election administrators as well because their election-altering actions pose the same risk.
On April 6, 2020, the U.S. Supreme Court issued an opinion in Republican National Committee v. Democratic National Committee, No. 19A1016, 2020 U.S. LEXIS 2195 (U.S. Apr. 6, 2020) (per curiam), slip op. available at https://www.supremecourt.gov/opinions/19pdf/19a101 6_o759.pdf, again applying that Principle, which it summarized thus:
This Court has repeatedly emphasized that lower federal courts should ordinarily not alter the election rules on the eve of an election. See Purcell v. Gonzalez, 549 U. S. 1 (2006) (per curiam); Frank v. Walker, 574 U. S. 929 (2014); Veasey v. Perry, 574 U. S. __ (2014). 2020 U.S. LEXIS 2195, at **2-3. This RNC case stayed a lower-court order allowing voters to mail absentee ballots after election day. RNC recited various problems that the lower-court order posed and said they “underscore[] the wisdom of the Purcell principle, which seeks to avoid this kind of judicially created confusion.” Id. at **3. A crucial point was that the lower-court order “fundamentally alters the nature of the election.” Id. The requested relief also fundamentally alters the nature of Virginia’s election, drastically changing the absentee voting requirements. This fundamental alteration of the nature of the election raises the same possibility of voters losing their franchise as in Purcell and RNC. Here, as in

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RNC, the Purcell-Principle should apply as applicable: “[W]hen a lower court intervenes and alters the election rules so close to the election date, our precedents indicate that this Court, as appropriate, should correct that error.” Slip op. 3. C. The requested relief violates the Voters’ right to vote in, and have, a federal election in
the legislature’s prescribed manner. The requested relief violates Voters’ right to have, and to vote in, a federal election where the “Manner” of election is “prescribed . . . by the Legislature,” as required: The Times, Places and Manner of holding Elections for Senators and Representatives, shall be prescribed in each State by the Legislature thereof; but the Congress may at any time by Law make or alter such Regulations, except as to the Places of chusing Senators. U.S. Const. art. I, § 4, cl. 1. Candidates for federal office are on the Primary ballot. See https://www.elections.virginia .gov/media/castyourballot/candidatelist/June-2020-Primary-Candi dates-List-(4)-1.pdf (Virginia Dep’t of Elections, “Certified Candidates in Ballot Order for June 23, 2020 Primary Elections”). So the Primary must be conducted in the Legislature’s prescribed manner. But the requested relief is not at all what the Legislature chose and is contrary to controlling legislation. Virginia law requires that absentee voters, inter alia, open and mark their ballots in the presence of a witness. Va. Code § 24.2-707(A). It also requires that voters enclose their ballots in the provided envelope, seal the envelope, and “fill in and sign the statement printed on the back of the envelope in the presence of a witness, who shall sign the same envelope[.]” Id. The requested relief seeks to eliminate this Anti-Fraud Witness requirement, thereby seeking to conduct the election in a manner not authorized by the Legislature and contrary to the Legislature’s choices. They seek to eliminate safeguards against vote fraud that the Legislature

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chose. So the requested relief violates Article I, § 4, cl. 1, including a violation of the Voter’s

right to have, and to vote in, such an election as the U.S. Constitution prescribes.

Recall that in Bush the U.S. Supreme Court listed a similar provision requiring that elections

for presidential electors be conducted in the manner chosen by the Legislature as an issue in the

case, but decided that it need not reach it because what the Florida Supreme Court had done fell

so woefully short of what was required under the vote-dilution ban that the manner-of-election

issue need not be reached. 551 U.S. at 103 (“whether the Florida Supreme Court established new

standards for resolving Presidential election contests, thereby violating Art. II, § 1, cl. 2, of the

United States Constitution”). Similarly here, the parallel manner-of-election provision for other

federal elections is an issue that may not need to be reached because the vote-dilution claims un-

der the fundamental right to vote can readily decide the case. But if the Court doesn’t decide this

case on vote-dilution or another claim, this issue must be reached. And the requested relief vio-

lates Article I, § 4, cl. 1, so the Anti-Fraud Witness Requirement must not be enjoined absent a

truly clear federal constitutional violation, which is not present here.

IV.
Plaintiffs cannot satisfy the remaining preliminary injunction requirements.

Not only are Plaintiffs unlikely to succeed on the merits, they also cannot satisfy the remain-

ing requirements: irreparable harm, a favorable balance of equities, and the public interest favor-

ing their requested relief. See Winter, 555 U.S. at 20. As discussed, the Supreme Court has made

clear that ‘[a] preliminary injunction is an extraordinary remedy never awarded as of right.” Id.

at 24.

In each case, courts must balance the competing claims of injury and must consider the effect on each party of the granting or withholding of the requested relief. In exercising

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their sound discretion, courts of equity should pay particular regard for the public consequences in employing the extraordinary remedy of injunction. Id. (internal citations and quotes omitted). A. Plaintiffs do not have irreparable harm. Plaintiffs have not been irreparably harmed. First, there is no constitutional right to vote absentee. Griffin, 385 F.3d at 1131-33. Second, the Anti-Fraud Witness Requirement is a reasonable and nondisriminatory restriction. See Part II. Third, the Anti-Fraud Witness Requirement does not deprive Plaintiffs of their right to vote as there are other remedies at law that would allow them to vote and protect their health.26 Indeed, there are a multitude of ways that Plaintiffs can comply with the Anti-Fraud Witness Requirement without Court intervention. Plaintiffs could accomplish this: (1) via social distancing (which the CDC has found is an effective way to curb spread of the virus), (2) via smartphone or videochat, or (3) by using an e-notary (which is permitted under Virginia law). See supra at 16-17 (detailing options to comply with the witness requirement). So, Plaintiffs have not been irreparably harmed. On the other hand, if this Court were to enforce to eliminate the Anti-Fraud Witness Requirement, Defendant Voters would be deprived of their fundamental right to vote (see Part III), causing irreparable harm. This factor favors the denial of the preliminary injunction. B. The balance of equities weighs against the granting of a preliminary injunction. The balance of equities tip strongly in favor of Voter Defendants. As discussed, Plaintiffs burdens are minimal, as (1) Plaintiffs do not have a constitutional

26 Plaintiffs seek an extreme remedy—eliminating the Anti-Fraud Witness Requirement—for all Virginians. But “injunctive relief should be no more burdensome to the defendant than necessary to provide complete relief to the plaintiffs.” Madsen v. Women's Health Ctr., Inc., 512 U.S. 753, 765 (1994).

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right to vote absentee, (2) the Anti-Fraud Witness Requirement is a reasonable and nondisriminatory restriction, and (3) the Plaintiffs have many remedies at law that would allow them to vote and protect their health. See supra Part IV.A.
On the other hand are two significant injuries that would result from removal of the AntiFraud Witness Requirement. First, Virginia “indisputably has a compelling interest in preserving the integrity of its election process.” Purcell, 549 U.S. at 4 (internal citations omitted). But if the Anti-Fraud Witness Requirement is removed, Commonwealth Defendants cannot preserve that integrity.27 Without the Anti-Fruad Witness Requirement, there will be a significantly increased risk of illegal voting, fraud, and manipulation of the absentee process (which has long been a problem in Virginia). Second, Voter Defendants have core, fundamental, constitutional rights that will be violated by the removal of the Anti-Fraud Witness Requirement. The requested relief is not authorized by the General Assembly, is in violation of controlling laws, and opens this election up to fraud—diluting and debasing Voter Defendants’ right to vote.
Alone, either one of Commonwealth Defendants’ and Voter Defendants’ harms weighs against the granting of the preliminary injunction. But taken together, there can be no doubt that the balance of equities tips heavily in favor of denying the preliminary injunction. C. The public interest disfavors the injunction.
The public interest weighs favors denial of the preliminary injunction. The Supreme Court has made clear that:

27 And “the striking of the balance between discouraging fraud and other abuses and encouraging turnout is quintessentially a legislative judgment with which [ ] judges should not interfere unless strongly convinced that the legislative judgment is grossly awry. Griffin, 385 F.3d at 1131.

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Confidence in the integrity of our electoral processes is essential to the functioning of our participatory democracy. Voter fraud drives honest citizens out of the democratic process and breeds distrust of our government. Voters who fear their legitimate votes will be outweighed by fraudulent ones will feel disenfranchised. Purcell, 549 U.S. at 4. Public confidence in the integrity of elections weighs against a preliminary injunction. But the public also have an interest in confidence in the voting process. “Court orders affecting elections . . . can themselves result in voter confusion and consequent incentive to remain away from the polls. As an election draws closer, that risk will increase.” Id. at 5. Indeed “the late hour of Plaintiffs’ request exponentially increases the disruption to [the Commonwealth’s] electoral process and potentially impairs [its] ability to guarantee the integrity of its elections. Bethea, 2016 WL 6123241, at *3; see also Arizona Democratic Party v. Reagan, No. CV-16-03618-PHX-SPL, 2016 WL 6523427, at *10 (D. Ariz. Nov. 3, 2016) (holding that at times like these when public moral is low, last minute changes to election law “poses a realistic possibility that the public’s confidence in the state’s ability to competently administer elections and protect against disorder would be undermined and dissuade them from going to the ballot box next week.”) And the potential for all these harms is greater, not less, where there are COVID-19 concerns because voters’ attention is not focused on last-minute changes, expecting instead that they can rely on the usual procedures mandated by General Assembly. So public confidence in the election process also weighs against a preliminary injunction. While the public has a significant interest in the integrity of the election and confidence in the election process, Plaintiffs’ burden is minimal. Plaintiffs argue that the “public interest . . . favors permitting as many qualified voters to vote as possible.” But nothing about the Anti-Fraud

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Witness Requirement prevents voting. Pls.’ Prel. Inj. Br., Doc. 17, Pageid# 128. Again, (1) there is not a constitutional right to vote absentee, (2) the Anti-Fraud Witness Requirement is a reasonable and nondisriminatory restriction, and (3) the Plaintiffs have many remedies at law that would allow them to vote and protect their health. See supra Part IV.A. Plaintiffs could comply with the Anti-Fraud Witness Requirement (1) via social distancing, (2) via smartphone or videochat, or (3) by using an e-notary. See supra at 16-17. And these suggested remedies also comply with CDC and Virginia guidelines to protect the public health and prevent the spread of the virus. See Pls.’ Prel. Inj. Br., Doc. 17, Pageid# 128 (arguing for safeguarding public health). So no public health interest justifies the requested relief.
The public interest favors denial of Plaintiffs’ Preliminary Injunction.
Conclusion
For the reasons show, Plaintiffs’ Motion for Preliminary Injunction should be denied. If this Court grants Plaintiffs any relief, Voter Defendants respectfully request that this Court stay its decision for 24 hours, so that an emergency appeal in the Fourth Circuit may be filed.

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Date: April 28, 2020
Respectfully Submitted,
/s/ Bradley P. Marrs (VSB#25281) Patrick C. Henry II (VSB#80468) Marrs & Henry 7202 Glen Forest Drive, Suite 307 Richmond, VA 23226 (804) 662-5715 (804) 662-5712 (fax) bmarrs@marrs-henry.com phenry@marrs-henry.com
Local Counsel for Proposed Intervenors

James Bopp, Jr.* IN Atty. No. 2838-84
Courtney Turner Milbank* IN Atty. No. 32178-29
True the Vote, Inc. Voters’ Rights Initiative
THE BOPP LAW FIRM, PC 1 South Sixth St. Terre Haute, IN 47807-3510 Telephone: (812) 232-2434 E-mails: jboppjr@aol.com,
cmilbank@bopplaw.com
Lead Counsel for Proposed Intervenors
* Admitted Pro Hac Vice

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Certificate of Service

I hereby certify that the foregoing document was served electronically on April 28, 2020,

upon the following counsel via the United States District Court for the Western District of Vir-

ginia, electronic filing system:

Vishal Mahendra Agraharkarvagraharkar@acluva.org

Theresa Leetlee@aclu.org

Adriel I. Cepeda Derieuxacepedaderieux@aclu.org

Davin McKay Rosboroughdrosborough@aclu.org

Eden Brooke Heilmaneheilman@acluva.org
Dale Ho- dho@aclu.org

Carol L. Lewis- clewis@oag.state.va.us
Heather Hays Lockermanhlockerman@oag.state.va.us

Sophia Lakinslakin@aclu.org

/s/ Bradley P. Marrs (VSB#25281) Patrick C. Henry II (VSB#80468) Marrs & Henry 7202 Glen Forest Drive, Suite 307 Richmond, VA 23226 (804) 662-5715 (804) 662-5712 (fax) bmarrs@marrs-henry.com phenry@marrs-henry.com
Local Counsel for Proposed Intervenors

James Bopp, Jr.* IN Atty. No. 2838-84
Courtney Turner Milbank* IN Atty. No. 32178-29
True the Vote, Inc. Voters’ Rights Initiative
THE BOPP LAW FIRM, PC 1 South Sixth St. Terre Haute, IN 47807-3510 Telephone: (812) 232-2434 E-mails: jboppjr@aol.com,
cmilbank@bopplaw.com

Lead Counsel for Proposed Intervenors

* Admitted Pro Hac Vice

Voter Defs. Opp’n.

to Pls. Prelim. Inj.

-34-

 </s> Case 6:20-cv-00024-NKM Document 40 Filed 04/28/20 Page 1 of 21 Pageid#: 417

UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA
Lynchburg Division

LEAGUE OF WOMEN VOTERS OF

VIRGINIA;

KATHERINE

D.

CROWLEY; ERIKKA GOFF; and

SEIJRA TOOGOOD,

Plaintiffs,

v.

VIRGINIA STATE BOARD OF ELECTIONS; ROBERT H. BRINK, JOHN O’BANNON, and JAMILAH D. LECRUISE, in their official capacities as Chairman, Vice-Chair, and Secretary of the Virginia State Board of Elections, respectively; and CHRISTOPHER E. PIPER, in his official capacity as Commissioner of the Virginia Department of Elections,

Defendants.

Case No. 6:20-cv-00024-NKM

PLAINTIFFS’ CONSOLIDATED BRIEF IN OPPOSITION TO MOTIONS TO INTERVENE

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Movants Ferguson, Burchett, and Crickenberger (together, “Individual Voters”), and Republican Party of Virginia and its officials (“RPV”), seek to intervene in this time-sensitive election matter in which the Plaintiffs’ right to vote is on the line. Not mentioning the public health crisis once, they never explain how the resolution of this case will affect their own votes or interests differently from how it will affect from the public generally. This is because Movants’ asserted interest in electoral integrity generally, and vague concerns of vote dilution, do not justify intervention. And while the RPV may have associational interests in who may be eligible to participate in its primary, this case does not implicate voter eligibility, but rather concerns administrative procedures that, absent relief, will disenfranchise indisputably eligible Virginia voters. Thus, because Movants do not “stand to gain or lose by the direct legal operation of the district court’s judgment” in any particularized way, Teague v. Bakker, 931 F.2d 259, 261 (4th Cir. 1991), they are not entitled to intervene.
As detailed below, federal courts have repeatedly rejected efforts of individual voters and political parties and officials whose personal right to vote is not at stake to intervene in a case by asserting generalized interests in election integrity. And in the few instances where individuals have made the same non-specific, fact-free assertions that their votes will somehow be diluted by non-qualified voters participating in an election, courts have rejected those asserted interests as too abstract and speculative to support intervention. This Court should do the same here.
Movants also seek to permissively intervene in the case, citing the benefits of bringing together all interested parties for one resolution of the relevant issues. But Movants have no specific interests in this case, and allowing intervention would justify participation by any Virginia voter in any election-related case. And despite their agreement to participate in an expedited briefing schedule, in light of the proposed partial consent decree just filed by Plaintiffs
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and Defendants, Movants will likely use their party status, should it be granted, to try to block that order and delay resolution of Plaintiffs’ preliminary injunction motion. The same is true for the Individual Voters’ cross-claim, which will only be live (to the extent it is at all) for the June primary, due to the Virginia General Assembly’s recent changes to absentee voting laws beginning July 1. Instead, the Court can gain the benefit of Movants’ views through participation as amici curiae—to which Plaintiffs consent—without the downsides of delay, prejudice, and confusion. See Stuart v. Huff, 706 F.3d 345, 355 (4th Cir. 2013).
The Court should deny Movants’ efforts to intervene. ARGUMENT
Rule 24 of the Federal Rules of Civil Procedure provides the standards governing intervention, whether as a matter of right or permissive. Fed. R. Civ. P. 24. Movants cannot satisfy either standard, and their participation in this case would prejudice Plaintiffs by delaying relief and by adding additional confusion and uncertainty to this time-sensitive case. Because Movants have no substantial interests in this case different from that of the general public, they cannot justify intervention and can adequately express their views as amici curiae. I. The Court should deny intervention as a matter of right because Movants lack any
significantly protectable interest and instead assert only generalized interests shared by the public at large—interests adequately protected by existing Defendants. Rule 24(a)(2) allows intervention as a matter of right “if the movant can demonstrate ‘(1) an interest in the subject matter of the action; (2) that the protection of this interest would be impaired because of the action; and (3) that the applicant’s interest is not adequately represented by existing parties to the litigation.’” Stuart, 706 F.3d at 349 (quoting Teague, 931 F.2d at 260– 61). Each of these elements is required for intervention as a matter of right, but Movants satisfy none of them.
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A. Movants assert only generalized interests shared by the public at large and interests not directly implicated by this case. To demonstrate they have an interest in the action sufficient to intervene, movants must
establish a “‘significantly protectable interest,’” Teague, 931 F.2d at 261 (quoting Donaldson v. United States, 400 U.S. 517, 531 (1971)), and that “failure to allow intervention would impair that interest,” Lee v. Virginia Bd. of Elections, No.3:15CV357-HEH, 2015 WL 5178993, at *2 (E.D. Va. Sept. 4, 2015) (citing In re Richman, 104 F.3d 654, 659 (4th Cir. 1997)). In other words, the intervenors must have an interest that is “contingent on the outcome of other litigation,” meaning that they must “stand to gain or lose by the direct legal operation of the district court’s judgment.” Teague, 931 F.2d at 261. A “‘general interest in the subject matter of pending litigation does not constitute a protectable interest within the meaning of Rule 24(a)(2).’” RLI Ins. Co. v. Nexus Services, Inc., No. 5:18-CV-00066, 2018 WL 5621982, at *3 (W.D. Va. Oct. 30, 2018) (quoting Dairy Maid Dairy, Inc. v. United States, 147 F.R.D. 109, 111 (E.D. Va. 1993)).
Here, Movants have not shown specific interests in this case such that they “stand to gain or lose” depending on the outcome. The Individual Voters cite a broad interest in the “fundamental right to vote” and vague concerns about vote dilution due to voter fraud, with the RPV expressing similar concerns about “election integrity.” ECF No. 23 at 3, 6; ECF No. 29 at 1–2. These generalized interests and amorphous concerns in ensuring the integrity of the electoral process shared broadly by all members of the public are not “unique to the proposed intervenor,” Wis. Educ. Ass’n Council v. Walker, 705 F.3d 640, 658 (7th Cir. 2013), and are thus not “sufficiently specific . . . to be cognizable” for intervention, Sokaogon Chippewa Cmty. v. Babbitt, 214 F.3d 941, 948 (7th Cir. 2000). And the other interests cited by Movants are not affected by this case in any way, with some of them based on fundamental misunderstandings of
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constitutional law—namely, Individual Voters claiming a “right to vote under the Purcell Principle” and individual rights under the Elections Clause. See ECF No. 23 at 8-10.
1. Movants’ broad interests in election integrity and the right to vote are the shared by all Virginia voters and are not the type of specific interests that mandate intervention.
Courts have repeatedly held that individual voters’ and voting-related organizations’ broad interests in election integrity do not support intervention under Rule 24(a). See Common Cause Ind. v. Lawson, No. 117CV03936TWPMPB, 2018 WL 1070472, at *4–5 (S.D. Ind. Feb. 27, 2018) (in organizational plaintiff’s challenge to voter registration law under the National Voter Registration Act, denying intervention to organization whose mission includes election integrity and ensuring voter roll list maintenance laws are followed); One Wisconsin Inst., Inc. v. Nichol, 310 F.R.D. 394, 397 (W.D. Wis. 2015) (legislators, voters, and local election officials denied intervention in challenge to various Wisconsin election laws); Veasey v. Perry, No. 2:13cv-00193, slip op. at 1–2 (S.D. Tex. Dec. 11, 2013) (finding “True the Vote’s interests are generalized” and denying intervention in voter identification lawsuit) (attached as Exhibit A); United States v. Florida, No. 4:12-cv-285, slip op. at 3 (N.D. Fla. Nov. 6, 2012) (attached as Exhibit B); Wisc. Right to Life Political Action Comm. v. Brennan, No. 09-CV-764-VIS, 2010 WL 933809, at *3 (W.D. Wis. Mar. 11, 2010). This is because “generalized, public policy interests are insufficient to create [the] direct, substantial interest required.” Wisc. Right to Life, 2010 WL 933809, at *3; see also Hollingsworth v. Perry, 570 U.S. 693, 706 (2013) (intervenor’s interest in “vindicat[ing] the constitutional validity of a generally applicable California law” was a “‘generalized grievance’ . . . insufficient to confer standing”).
For example, in United States v. Florida, the court held that the interest of organizations and their members in ensuring confidence in the election process through accurate voting rolls are generalized interests that are “the same for the proposed intervenors . . . as for every other
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registered voter in the state” and thus “plainly do not afford a voter—or an organization with members who are voters—a right to intervene under Rule 24(a).” No. 4:12-cv-285, slip op. at 3. And in One Wisconsin Institute, the court rejected proposed intervenor’s “asserted interest in fraud-free elections” as insufficient to justify intervention as of right because such interest was “really just the proposed intervenors’ agreement with the policy underlying the challenged legislation.” One Wisconsin Inst., 310 F.R.D. at 397. The court explained that such an “[a]bstract agreement with the position of one side or another is not the type of ‘direct, significant, and legally protectable’ interest that gives rise to a right to intervene.” Id. (citation omitted).
The same is true here. Without any showing that the Individual Voters or RPV members will be deprived of the right to vote—as Plaintiffs and the League’s members will be if the witness requirement remains in place—their generalized interest in election integrity cannot support intervention. But this is all that Movants offer—vague assertions about having a “compelling interest in ensuring the integrity of the election(s) at issue in this litigation,” ECF No. 29 at 5, and seeking to preserve “vital safeguards against voting fraud,” ECF No. 23 at 4. Yet these interests are shared by all Virginia voters and the public at large. Allowing intervention on such a basis would allow “anyone with an interest—however broad or universal—to intervene in any lawsuit in which the government is a party” and the case touches upon voting. Sokaogon Chippewa Cmty., 214 F.3d at 948. Regardless, as Plaintiffs have already demonstrated, the witness requirement does not advance the Commonwealth’s interests in election integrity— interests already served by numerous other protections and disincentives. See ECF No. 17 at 26– 30. And Movants have made no argument let alone showing that the 39 other states that do not have a witness requirement run elections with any less integrity. Cf. ECF No. 17 at 28 & n.58.
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Not only do Movants share no interests different from the public at large, courts have rejected intervention based on a lack of significantly protectable interests even where proposed intervenors possessed a more direct connection to the action at issue. For example, in North Carolina State Conference of NAACP v. Cooper, 332 F.R.D. 161, 168 (M.D.N.C. 2019), the court denied intervention to state representatives in a case challenging the constitutionality of a voter identification law, holding that the movants “failed to demonstrate that they have a significantly protectable interest in likewise defending the constitutionality of S.B. 824 sufficient to warrant a right to intervene under Rule 24(a)(2).” See also One Wisconsin Inst., Inc., 310 F.R.D. at 397.
In Maryland Restorative Justice Initiative v. Hogan, 316 F.R.D. 106 (D. Md. 2016), proposed intervenors were “family members of persons who were killed by Juvenile Offenders” and intervened in a case in which Plaintiffs challenged the constitutionality of certain sentences awarded to juveniles. Id. at 108. The Court denied intervention, holding that despite their direct connection to the issue at hand, movants “will not be deprived of any rights in this case” and thus “have not demonstrated a ‘significantly protectable’ interest, as required for intervention of right.” Id. at 115.
And in Edwards v. Beck, No. 4:13CV00224 SWW, 2013 WL 12146739 (E.D. Ark. June 6, 2013), despite consent to intervention from the defendants, the court denied intervention to an anti-abortion group that provided counseling to pregnant women and had advocated for passage of the challenged abortion-related law because the group had not shown that overturning the law would harm its mission or services. Id. at *2–*3. Movants here lack even the sort of connection to the particular issue being litigated than these groups whose motions were denied.
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Moreover, Movants’ vague concerns about vote dilution also fail to raise significantly protectable interests that justify intervention. The vote-dilution cases cited by Movants arising in the “one-person, one-vote” context like Reynolds v. Sims, 377 U.S. 533 (1964), concern malapportioned legislative districts in which a district’s “weight is in a substantial fashion diluted when compared with votes of citizens living on other parts of the State,” id. at 568. Plaintiffs’ claims do not implicate legislative apportionment or even voter eligibility but rather voting procedures. Movants have not alleged that the application or removal of the witness requirement will favor or disfavor any particular area of the state or even one particular political party. And in the few cases where individuals or groups have alleged vote dilution based on a fear of non-eligible voters voting, courts routinely have rejected such arguments as reliant on speculation and abstract principles.
In Daughtrey v. Carter, 584 F.2d 1050, 1055 (D.C. Cir. 1978), for example, the plaintiffs were individuals who alleged dilution of their votes due to alleged voting by non-citizens. While recognizing that the “actual number of such persons is unknown,” they alleged that “the number may be in the thousands.” Id. The D.C. Circuit affirmed the district court’s dismissal for lack of standing, holding that because the plaintiffs had not alleged that their votes were or would be “diluted in any particular election. . . or geographical area” or that “they are an identifiable group of voters whose votes are disfavored Vis-a-vis those of some other group,” and because “the dilution of voting rights they have alleged is so diffuse, minute, and indeterminable,” their injures were “too speculative to support standing.” Id. at 1056.
Similarly, in American Civil Rights Union v. Martinez-Rivera (“ACRU”), 166 F. Supp. 3d 779, 787 (W.D. Tex. 2015), the court considered a claim by the plaintiff organization based on the dilution of its members’ votes due to one county allegedly failing to properly engage in voter
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registration list maintenance by supposedly including ineligible voters. Because the plaintiffs provided no way of telling “how many, if any, ineligible voters will actually vote, and historically, at least in Texas, there is little indication that many will,” the court held that “any injury would be entirely speculative.” Id. at 803; see also Pub. Interest Leg. Found., Inc. v. Bennett, No. 4:18-CV-00981, 2018 WL 2722331, at *4 (S.D. Tex. June 6, 2018).
Here, Movants provide even less than the plaintiffs in Daughtrey and ACRU. They do not argue, let alone provide any facts or evidence, for their concern that eliminating the witness requirement during a pandemic will result in voter fraud. And they certainly make no effort to quantify such assertions or otherwise show how such assertions are more than speculative, or demonstrate that such unlawful voting would disfavor their candidates of choice or even suggest that it would influence any particular election outcome.
Finally, Movants are likely to assert that they should be granted intervention to oppose entry of the partial consent decree. But in Dillard v. Chilton County Commission, 495 F.3d 1324, 1333 (11th Cir. 2007), the Eleventh Circuit rejected such an argument where the movants asserted “only the generalized incompatibility of the consent decree with the rights of all citizens in the county to be free of judicial interference, unauthorized by § 2 of the Voting Rights Act, with the democratically selected form of local governance.” Because this was “not a form of injury particularized to the Intervenors, but is rather an undifferentiated harm suffered in common by all citizens of the county,” the court reversed the district court’s grant of intervention. Id. Likewise here, the presence of the consent decree does not change Movants’ lack of particularized interest in this case.
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Because Movants have not established that they have anything to gain or lose regarding their votes and because their generalized interests are insufficient to support intervention, they fail to meet the “significantly protectable interest” test.
2. Movants’ other asserted interests are also entirely unaffected by this case. Movants offer some additional reasons for why they have sufficient interests to intervene in this case. None of those interests are at all affected by this case, however, because the case will have no bearing on them however it resolves, and because these supposed interests asserted are based on flawed legal grounding. For movant RPV, it has asserted two related interests other than its broad interest in election integrity, arguing that it has a substantial interests in its own primary election, as well as in “the ‘structur[e] of th[e] competitive environment’ of an election” faced by its candidates. ECF No. 29 at 4–5 (quoting Shays v. F.E.C., 414 F.3d 76, 85 (D.C. Cir. 2005)). As to the former, the cases cited by RPV concern eligibility to participate in a party’s primary—i.e., party members versus all registered voters, see Tashjian v. Republican Party of Conn., 479 U.S. 208 (1986), and Clingman v. Beaver, 544 U.S. 581 (2005)—or the party’s national convention—those selected by the Party or those chosen through an open primary process, see Democratic Party of U.S. v. Wisc. ex rel. La Follette, 450 U.S. 107, 108 (1981). For that reason, these cases all directly implicate the associational rights of the parties and their members under the First Amendment. See generally id. By contrast, this case concerns the administrative procedures by which eligible voters—and under Virginia law, all registered voters may exercise their fundamental right to vote in either party’s primary—can participate. Therefore, unlike the primary and convention eligibility cases cited by RPV, Plaintiffs’ claims challenging the state’s election administration procedures do not implicate the parties’ associational rights in any way. And whether or not Plaintiffs’ votes are counted due to the
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existence of the witness requirement do not infringe on any rights of the RPV—it has made no allegation, nor could it, that enjoining the witness requirement would somehow harm the RPV’s candidates or disfavor Republican candidates in the general election.
As to the latter interest, suspending the witness requirement during a pandemic will have no effect on the structuring of the competitive environment of the primary, instead affecting only the standards for whether certain ballots are counted—a prerogative of the Commonwealth and its officers, not a political party. See 1 Va. Admin. Code 20-70-20. It is Defendant Virginia State Board of Elections that sets standards that “tightly regulate[]” the “form of ballots used in Virginia elections,” Marcellus v. State Bd. of Elections, 849 F.3d 169, 172 (4th Cir. 2017), not the RPV. In Shays, the case relied upon by RPV, the court found that members of Congress facing reelection had standing to challenge regulations weakening campaign finance laws because these regulations created additional competition for them and more avenues for them to be attacked in the campaign. Id. at 85–86. By contrast, counting absentee ballots without witness signatures will have no particular impact on the RPV. It has not even alleged, let alone offered a factual basis, that enjoining the witness requirement during the pandemic will offer any particular advantage or disadvantage to one Republican candidate or another in the RPV primary, or one political party over another in the general election. Because the presence or absence of the witness requirement does nothing to change the structure of the competitive environment in a way from which the RPV stands to gain or lose, RPV has no significantly protectable interest in this case.
As for Individual Voters, the additional interests they assert not only suffer from the same generalized grievance problem as their election integrity and vote dilution arguments, but also from a misunderstanding of constitutional law. As to their argument that Plaintiffs’ lawsuit
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undermines their “right to vote under the Purcell principle,” it lacks merit for several reasons. For one, there is no substantive right under Purcell that can support standing (for intervention or otherwise). And no court has ever found a substantive right under Purcell to freeze elections procedures, let alone to do so regardless of whether such procedures violate federal constitutional or statutory guarantees. Rather, Purcell simply stands for the principle that, when weighing the equities as an election draws closer, a court should “weigh, in addition to the harms attendant upon issuance or nonissuance of an injunction, considerations specific to election cases and its own institutional procedures.” Purcell v. Gonzalez, 549 U.S. 1, 4 (2006). Movants lack any particular interest in the timing of an order expanding Virginians’ ability to vote beyond that of other voters and that of the Commonwealth.
Moreover, in Purcell, the relevant order enjoining a voter identification requirement occurred less than a month before the general election and days before early voting began. Likewise, in Republican National Comm. v. Democratic National Comm., 19A1016, 2020 WL 1672702, at *1 (U.S. Apr. 6, 2020), the Supreme Court stayed an injunction entered just five days before an election that would have extended the time to submit an absentee ballot, counseling against “alter[ing] the election rules on the eve of an election.”
Here, the Court has set a hearing on Plaintiffs’ preliminary injunction motion for May 4—over seven weeks before the relevant election—and has stated its plans to issue a decision by the end of that week. And the Plaintiffs and Defendants filed their Motion for Entry of a Partial Proposed Consent Judgment and Decree on April 27, over eight weeks before the election. Even if Movants had some particular interest above and beyond other voters under Purcell, that interest would not be affected by a ruling a full month-and-a-half before a primary election.
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Individual Voters’ argument that Plaintiffs’ requested relief violates the Elections Clause of the U.S. Constitution, U.S. Const. art. I, § 4, cl. 1, runs even farther afield. The Elections Clause confers powers on states, to the extent Congress chooses not to legislate in the field. Under the Elections Clause, the “States possess a broad power to prescribe the ‘Times, Places and Manner of holding Elections for Senators and Representatives,’ Art. I, § 4, cl. 1, which power is matched by state control over the election process for state offices.” Wash. State Grange v. Wash. State Republican Party, 552 U.S. 442, 451 (2008) (citation & internal quotation marks omitted). To the extent the Commonwealth believes the requested relief interferes with those powers, it can defend them itself. But the Elections Clause certainly creates no significantly protectable interest in the Individual Voters. And once again, if it did, that interest would be one shared by all Virginia voters, which is insufficient to support intervention.
Finally, to the extent Individual Voters rely on their cross-claim as a basis for intervention—alleging a violation of their right to vote due to the Commonwealth’s interpretation of the absentee “disability or illness” excuse—they must “demonstrate Article III standing” because they seek “additional relief beyond that which the plaintiff requests.” Town of Chester, N.Y. v. Laroe Estates, Inc., 137 S. Ct. 1645, 1651 (2017). They cannot do so here for several independent reasons.1
First, unlike Plaintiffs—who will be disenfranchised by operation of the witness requirement during the pandemic—the Individual Voters have not offered any facts indicating a burden on their right to vote by other Virginia registered voters having an opportunity to vote via absentee ballot. Nor have they otherwise shown how an expansion of absentee eligibility criteria “violates the due process clause of the Fourteenth Amendment of the U.S. Constitution,” Dkt.
1 Should the Individual Voters nonetheless be allowed to intervene and present a cross-claim, Plaintiffs intend to more fully brief at the appropriate time why such claim is meritless and the Court lacks jurisdiction to hear it.
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No. 22-1 at 13, having not identified harm to any of their own “‘liberty’ or ‘property’ interests,” to the extent they intend to raise a procedural due process claim. Mathews v. Eldridge, 424 U.S. 319, 332 (1976).
Second, the Individual Voters lack standing for similar reasons to why they lack a significant interest in this case—their general interest in election integrity and vague fear of vote dilution is insufficient to establish a “substantial risk” of harm, Susan B. Anthony List v. Driehaus, 573 U.S. 149, 158 (2014), as “[a]llegations of possible future injury are not sufficient,” Clapper v. Amnesty Int’l USA, 568 U.S. 398, 409 (2013) (internal quotation marks & citations omitted) (emphasis added). As in the cases cited in the previous section, the Individual Voters do not plead any facts indicating that their votes will be diluted or otherwise “disfavored Vis-a-vis those of some other group,” Daughtrey, 584 F.2d at 1056, and thus “any injury would be entirely speculative,” ACRU, 166 F. Supp. 3d at 803.
Third, based on their places of residence in Appomattox and Bedford Counties, see ECF No. 23 at 1–2, two of the Individual Voters reside in Virginia’s Fifth Congressional District and one resides either in the Fifth or Sixth Congressional District, see Va. Code § 24.2-302.2. The Sixth district has no primary on June 23 for either party, and the Fifth district has only a Democratic primary.2 Yet the Individual Voters have not alleged they intend to vote in the Fifth district Democratic primary, only vaguely alleging an intent to “vote in the next election.” ECF No. 23 at 1–2. It is unclear whether this “next election” is a May local election (which is unaffected by this lawsuit), the June 23 Democratic primary for the Fifth district, or the November general election. Of course, Virginia will institute a “no-excuse” absentee requirement as a matter of state law starting July 1, 2020, and thus for the November election,
2 Va. Dep’t of Elections, Certified Candidates in Ballot Order for June 9 Primary Elections, https://www.elections.virginia.gov/media/castyourballot/candidatelist/June-2020-Primary-Candidates-List-(3).pdf (last visited Apr. 28, 2020).
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meaning that the Individual Voters will not participate in an election affected by the State’s interpretation of the “disability or illness” absentee excuse unless they participate in the Fifth district Democratic primary.3 But because they have not alleged such an intent, the Individual Voters lack standing to bring their cross claim as well as lacking any basis to intervene.
B. Movants have not overcome the strong presumption that Defendants are adequately representing the interest in election integrity they assert. In the Fourth Circuit, a movant seeking to intervene as a defendant alongside the
government in a challenge to the constitutionality of a state statute must make a “very strong showing” of inadequacy of representation. Stuart, 706 F.3d at 351. This is because in “matters of public law litigation that may affect great numbers of citizens, it is the government’s basic duty to represent the public interest,” id., and because intervention in such cases places a “severe and unnecessary burden on government agencies as they seek to fulfill” these duties, id. at 352. Further, “the prospect of a deluge of potential intervenors” could compel the government “to modify its litigation strategy to suit the self-interested motivations of those who seek party status, or else suffer the consequences of a geometrically protracted, costly, and complicated litigation.” Id. at 351. To “rebut the presumption of adequacy,” Movants “must show either collusion between the existing parties, adversity of interests between themselves and the State Defendants, or nonfeasance on the part of the State Defendants.” N.C. State Conf. of NAACP, 332 F.R.D. at 169. They cannot do so here.
Here, Defendants have not failed to defend the case and thereby engaged in nonfeasance or a “clear dereliction of duty,” Chiglo v. City of Preston, 104 F.3d 185, 188 (8th Cir. 1997). Rather, Defendants have taken a different approach to defending the same interests asserted by
3 See 2020 Va. H.B. 1, available at https://lis.virginia.gov/cgi-bin/legp604.exe?201+ful+HB1ER; Press Release, Officer of the Governor, “Governor Northam Signs Sweeping New Laws to Expand Access to Voting” (Apr. 12, 2020), https://www.governor.virginia.gov/newsroom/all-releases/2020/april/headline-856055-en.html.
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Movants. And “disagreement over how to approach the conduct of the litigation is not enough to rebut the presumption of adequacy.” Stuart, 706 F.3d at 353; see also Saldano v. Roach, 363 F.3d 545, 555 (5th Cir. 2004) (“Simply because the [intervenor] would have made a different [litigation] decision does not mean that the Attorney General is inadequately representing the State’s interest.”); N.C. State Conf. of NAACP, 332 F.R.D. at 170 (“the Court is unpersuaded by Proposed Intervenors’ contention that there is adversity of interests because State Defendants will not employ the same approach to the litigation as would the General Assembly.”); Va. Uranium, Inc. v. McAuliffe, No. 4:15-CV-00031, 2015 WL 6143105, at *3 (W.D. Va. Oct. 19, 2015).
While Movants may disagree with Defendants’ decision to agree to seek a partial consent decree, this litigation decision made in the interests of simultaneously preserving Virginians’ right to vote, election integrity, and public health also does not amount to collusion or adversity of interests. In Stotts v. Memphis Fire Dept., 679 F.2d 579 (6th Cir. 1982), the Sixth Circuit affirmed the denial of a motion by white firefighters to intervene in a case where plaintiffs and the City of Memphis entered into a consent decree to resolve racial discrimination claims against the fire department. It noted that even though the “objectives of the City and some nonminorities may have diverged when the City agreed to a reasonable consent decree which embodied an affirmative action plan,” the “legally protected interests of the City and nonminorities did not” because the proposed intervenors did “not have a legally protected interest in promotions which could only occur as the result of presumptively discriminatory employment practices.” Id. at 583–84 (emphasis added). The agreement to seek a consent decree did not amount to collusion or adversity of interests in the legal sense, but rather a decision made to
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resolve a legal issue in a manner that represented the public interest in preventing racial discrimination.
As in Stotts, the proposed partial consent decree was negotiated after Plaintiffs were forced to file this action and seek preliminary relief due to a lack of action from the Commonwealth to preserve their constitutional rights during this pandemic. Far from collusive, it represents an attempt to preserve both the right of Virginians to vote and public health and still maintaining the integrity of the June 23 primaries (like the 39 other states that have no witness requirement). And as in Stotts, Movants have no legally protected interest in the denial of other Virginians of the right to vote during the pandemic, and this proposed consent decree in no way affects their right to vote. And while the RPV suggests that the Commonwealth’s dual interests of both election integrity and public health may create an adversity of interests, ECF No. 29 at 7, the fact that the Commonwealth wears multiple hats is not sufficient to demonstrate adversity when there is still a substantial overlap of the ultimate goals of preserving the right to vote and ensuring election integrity. See, e.g., Md. Restorative Justice Initiative, 316 F.R.D. at 113 (rejecting an adversity-of-interests argument based on the fact that “the Attorney General has many constitutional and statutory duties, including, in criminal cases, ‘a responsibility to seek justice’”).
Movants apparently do not trust the Commonwealth to defend this lawsuit. But it is the state Attorney General who is “charged with the duty to represent the State in defense of its existing laws,” and a disagreement as to how to defend this case is insufficient to supplant this role. N.C. State Conf. of NAACP, 332 F.R.D. at 169. And while Movants may have a “fervent desire to protect the statute, ‘stronger, more specific interests do not adverse interests make.’” United States v. North Carolina, No. 1:13CV861, 2014 WL 494911, at *3 (M.D.N.C.
16

Case 6:20-cv-00024-NKM Document 40 Filed 04/28/20 Page 18 of 21 Pageid#: 434
Feb. 6, 2014) (quoting Stuart, 706 F.3d at 353). Movants have not made the strong showing of nonfeasance, collusion, or adversity of interests necessary to overcome the presumption of adequacy of representation. II. The Court should deny permissive intervention because Proposed-Intervenors will
only complicate and delay the case and their views can be sufficiently shared through amicus curiae participation. Federal Rules of Civil Procedure 24(b) permits intervention in the court’s discretion “when a movant ‘has a claim or defense that shares with the main action a common question of law or fact.’” Lee, 2015 WL 5178993, at *4 (quoting Fed. R. Civ. P. 24(b)). In evaluating permissive intervention, however, “the court must consider ‘whether the intervention will unduly delay or prejudice the adjudication of the original parties’ rights.’” Stuart, 706 F.3d at 349 (quoting Fed. R. Civ. P. 24(b)(3)). In Stuart, the Fourth Circuit affirmed the district court’s denial of permissive intervention for this very reason, agreeing that adding multiple intervenors would “complicate the discovery process and consume additional resources of the court and the parties.” Id. at 355 (internal citation & quotation marks omitted). Instead, the Fourth Circuit and courts within it have repeatedly counseled that amicus curiae participation offers a way for movants to “present their views” without consuming additional time and resources of the court and parties. Id.; see also Lee, 2015 WL 5178993, at *5. These “alternative avenues of expression reinforce[] our disinclination to drive district courts into multi-cornered lawsuits by indiscriminately granting would-be intervenors party status and all the privileges pertaining thereto.” Id. Courts have also recognized that these concerns about intervenors complicating electionrelated litigation in the months leading up to an election create an additional disincentive for allowing intervention. See, e.g., N.C. State Conf. of NAACP, 332 F.R.D. at 172 (“The nature of
17

Case 6:20-cv-00024-NKM Document 40 Filed 04/28/20 Page 19 of 21 Pageid#: 435
the claims at issue and the imminence of the election require a swift resolution on the merits to bring certainty and confidence to the voting process.”). Rather, in “cases like this one, where a group of plaintiffs challenge state legislation, the court should evaluate requests to intervene with special care, lest the case be swamped by extraneous parties who would do little more than reprise the political debate that produced the legislation in the first place.” One Wisconsin Inst., 310 F.R.D. at 397.
Here, permitting intervention would only serve to delay and complicate resolution of this case and lead to greater risk of confusion close to the election. While Movants have agreed to the aggressive briefing schedule set by this Court, this participation in preliminary injunction briefing is unlikely to mark the end of their pre-primary efforts. Indeed, the Individual Voters have lodged a counterclaim concerning who counts as an eligible absentee voter—an issue that will only remain live before the June 23 primary due to Virginia’s recent legislative changes to absentee ballot rules. And now that Plaintiffs and Defendants have also sought entry of a partial consent decree, Movants will undoubtedly seek to challenge entry of that decree and prevent resolution of this issue well in advance of the primary. Allowing Movants to participate as amicus curiae, to which Plaintiffs consent, will allow Movants to express their views of the case without hindering a timely resolution before the election.
Therefore, in the interests of preventing delay and prejudice to Plaintiffs’ rights and unduly complicating this litigation, the Court should deny permissive intervention as well.
CONCLUSION For the foregoing reasons, Plaintiffs request that the Court deny Individual Voters’ and the RPV’s motions to intervene.
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Case 6:20-cv-00024-NKM Document 40 Filed 04/28/20 Page 20 of 21 Pageid#: 436

Dated: April 28, 2020
Vishal Agraharkar (VSB #93265) Eden Heilman (VSB #93554) AMERICAN CIVIL LIBERTIES UNION FOUNDATION OF AMERICA, INC. 701 E. Franklin Street, Suite 1412 Richmond, Virginia 23219 Phone: (804) 644-8080 Fax: (804) 649-2733 vagraharkar@acluva.org eheilman@acluva.org

Respectfully submitted,
/s/ Davin M. Rosborough_______________ Davin M. Rosborough (VSB # 85935) Dale E. Ho* Sophia Lin Lakin* Theresa J. Lee* Adriel I. Cepeda-Derieux* American Civil Liberties Union Foundation 125 Broad Street, 18th Floor New York, NY 10004 Tel.: (212) 549-2500 drosborough@aclu.org dho@aclu.org slakin@aclu.org tlee@aclu.org acepedaderieux@aclu.org

Attorneys for Plaintiffs *Admitted pro hac vice

19

Case 6:20-cv-00024-NKM Document 40 Filed 04/28/20 Page 21 of 21 Pageid#: 437 CERTIFICATE OF SERVICE
I certify that on April 28, 2020, I served a copy of the foregoing Consolidated Brief in Opposition to Motions in Intervene via filing with the Court’s CM/ECF system, which sent copies of this document to Counsel of Record.
/s/ Davin M. Rosborough_______________ Davin M. Rosborough (VSB # 85935) American Civil Liberties Union Foundation 125 Broad Street, 18th Floor New York, NY 10004 Tel.: (212) 549-2500 drosborough@aclu.org Counsel for Plaintiffs
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EXHIBIT A

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS
CORPUS CHRISTI DIVISION

MARC VEASEY, et al,
Plaintiffs, VS.
RICK PERRY, et al,
Defendants.

§ § § § CIVIL ACTION NO. 2:13-CV-00193 § § § §

ORDER DENYING INTERVENTION OF TRUE THE VOTE

Before the Court is the “Motion for Intervention of True the Vote” (D.E. 38).

After reviewing the documents on file and hearing arguments of counsel on November

15, 2013, the Court DENIES the Motion.

The burden of proof on a request to intervene as of right under FED. R. CIV. P.

24(a)(2) is on the party seeking intervention, True the Vote. See generally, Ordnance Container Corp. v. Sperry Rand Corp., 478 F.2d 844, 845 (5th Cir. 1973). Three of the

four requirements for intervention as of right under Rule 24(a)(2) require a particularized

interest that the litigation threatens and that no existing party to the suit adequately

represents. See generally, Haspel & Davis Milling & Planting Co., 493 F.3d 570, 578 (5th Cir. 2007) (listing the four requirements). The Court agrees with the opinion in

United States v. Florida, No. 4:12-cv-285, Slip. Op. at 3-4 (N.D. Fla. Nov. 6, 2012) (D.E.

59-1), concluding that True the Vote’s interests are generalized and are adequately

represented by the State Defendants.

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Permissive intervention under Fed. R. Civ. P. 24(a)(1) is a matter entrusted to the Court’s discretion. New Orleans Public Service, Inc. v. United Gas Pipe Line Co., 732 F.2d 452, 470-71 (5th Cir. 1984) (en banc). True the Vote does not claim a conditional right to intervene by federal statute, so the question for the Court is whether it “has a claim or defense that shares with the main action a common question of law or fact.” FED. R. CIV. P. 24(b)(1). The Court finds that True the Vote’s intended contribution to this case may be accomplished without the necessity of, or burden incident to, making it a party. The Court, instead, will duly consider any motion for leave to file briefing as amicus curiae that True the Vote may feel compelled to file.
For the reasons set out above, the Court DENIES the Motion for Intervention of True the Vote (D.E. 38) in its entirety.
ORDERED this 11th day of December, 2013. ___________________________________ NELVA GONZALES RAMOS UNITED STATES DISTRICT JUDGE
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Case 6:20-cv-00024-NKM Document 40-2 Filed 04/28/20 Page 1 of 7 Pageid#: 440

EXHIBIT B

Page 1 of 7

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF FLORIDA TALLAHASSEE DIVISION

THE UNITED STATES OF AMERICA,

Plaintiff,

v.

CASE NO. 4:12cv285-RH/CAS

STATE OF FLORIDA and KEN DETZNER, Secretary of State, in his official capacity,

Defendants.

__________________________________/

ORDER DENYING LEAVE TO INTERVENE

This case arises under the National Voter Registration Act. In the run up to the 2012 primary and general elections, the State of Florida embarked on a program to remove noncitizens from the voter-registration rolls. The United States asserted that the NVRA prohibited such a program within 90 days before a federal primary or general election. On June 12, 2012, the United States filed this action against the State of Florida and its Secretary of State (collectively “the State”) and moved for a temporary restraining order or preliminary injunction requiring the State to discontinue the program until after the 2012 general election.

Case No. 4:12cv285-RH/CAS

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At an oral argument on the motion on June 27, 2012, the State said that it had voluntarily abandoned the program. In a ruling announced on the record of the oral argument and confirmed in a written order on June 28, 2012, the motion for a temporary restraining order or preliminary injunction was denied, based on this circuit’s voluntary-cessation doctrine as applied to public defendants.
At the parties’ request, by an order entered on October 10, 2012, further proceedings were stayed until after the election. But the order explicitly did not stay proceedings on two motions to intervene as defendants. The motions were filed before the June 27 oral argument. This order now denies the motions.
I Four individuals have moved for permissive intervention under Federal Rule of Civil Procedure 24(b). Two organizations—Judicial Watch, Inc., and True the Vote—have moved to intervene either as of right under Rule 24(a) or permissively under Rule 24(b). The four individuals were allowed to present oral argument as amici at the June 27 hearing—not to intervene—when the State agreed to yield some of its time. The State has consented to the motions to intervene. The United States did not object to the individuals’ participation in the oral argument as amici and does not object to their further participation—or the other proposed intervenors’
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participation—as amici in further proceedings. But the United States objects to intervention.
II None of the proposed intervenors has a direct interest in the State’s voterregistration activities. The four individuals say that if people are improperly registered to vote, it will dilute the votes of properly registered voters, including the four individuals. The assertion of course is true; an improper vote dilutes a proper one. Judicial Watch makes a similar assertion on behalf of its members who are Florida registered voters and says their confidence in the election process will suffer if accurate voting rolls are not maintained. These asserted interests are the same for the proposed intervenors—and for Judicial Watch’s members—as for every other registered voter in the state. Generalized interests of this kind plainly do not afford a voter—or an organization with members who are voters—a right to intervene under Rule 24(a). And when, as here, the interest in avoiding vote dilution of this kind is adequately represented by existing defendants with a much more direct and substantial stake in the dispute, the better course is to deny permissive intervention as well. The State of Florida has recently—repeatedly—shown its willingness to litigate vigorously against the United States, including in this case and on other matters of this kind.
Case No. 4:12cv285-RH/CAS

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The State can be relied upon to adequately represent the same interests the intervenors propose to advocate.
True the Vote asserts an additional interest. It says one of its primary missions is to ensure that states and counties properly maintain voter-registration lists as required under federal law. To that end, True the Vote monitors the listmaintenance activities of states and counties, including in Florida. True the Vote sent a letter to the State of Florida in February 2012—long before this lawsuit was filed—inquiring about the State’s list-maintenance activities.
This interest differentiates True the Vote from voters generally. But neither the United States nor the State proposes to interfere in any way with True the Vote’s monitoring activities. And to the extent True the Vote may assert that the State is or may be doing too little to monitor its voting lists, that is a different issue altogether; it is not an issue that has been raised by the parties in this case. True the Vote’s interest in the maintenance of accurate voting lists—to the extent those interests are implicated by this litigation at all—will be adequately represented by the State.
True the Vote plainly is not entitled to intervene as of right. I conclude, as a matter of discretion, that True the Vote also should not be granted permissive intervention. True the Vote may indeed bring a useful perspective, and perhaps a
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level of legal expertise, to the litigation. But to the extent that is so, the perspective and expertise can be provided through amicus participation.
This is not a case like Johnson v. Mortham, 915 F. Supp. 1529, 1538-39 (N.D. Fla. 1995), in which the proposed intervenor, the NAACP, not only had a unique perspective but also participated in the event that led to the litigation—the creation of the challenged voting district. True the Vote has not alleged that it was involved in the State’s creation of its voter-list-monitoring program.
The motions to intervene thus will be denied. A long line of decisions supports the ruling. Citing or discussing them all would serve no purpose. Relevant decisions include Federal Savings & Loan Insurance Corp. v. Falls Chase Special Taxing District, 983 F.2d 211, 215 (11th Cir. 1993) (“This court will presume that a proposed intervenor’s interest is adequately represented when an existing party pursues the same ultimate objective as the party seeking intervention.” (citations omitted)); Worlds v. Department of Health & Rehabilitative Services, 929 F.2d 591, 595 (11th Cir. 1991) (noting the breadth of a district court’s discretion to grant or deny permissive intervention); and Chiles v. Thornburgh, 865 F.2d 1197, 1215 (11th Cir. 1989) (upholding a district court’s denial of permissive intervention by parties whose interests were identical to those of a governmental defendant). See also Dillard v. Chilton Cnty. Comm’n, 495 F.3d 1324, 1330 (11th Cir. 2007) (addressing an intervenor’s need for standing).
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In reaching this decision, I have not overlooked Meek v. Metropolitan Dade County, Florida, 985 F.2d 1471 (11th Cir. 1993), abrogated on other grounds by Dillard, 495 F.3d 1324. Meek was a challenge to at-large voting for a county commission. The Eleventh Circuit held that the district court should have allowed individuals to intervene for the purpose of appealing a judgment sustaining the challenge. The individuals’ own voting rights were at stake; their claim was that the district court’s decision would deny the individuals’ own rights. The Eleventh Circuit said the county was not an adequate advocate for the at-large system and held that the individuals should have been allowed to intervene to protect their own rights. Here, in contrast, the proposed intervenors’ own rights are not directly at stake as in Meek, and the State can be relied on to adequately represent their interests. Just because a governmental entity is not always an adequate representative of a position does not mean a governmental entity is never an adequate representative.
III The denial of intervention does not mean that these proposed intervenors cannot be fully heard on the issues that this case presents. Any of these proposed intervenors will ordinarily be granted leave to file a legal memorandum as amicus curiae on legal issues that arise as the case progresses. A motion for leave may be brief, especially if consented. And a proposed memorandum may be submitted
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with the motion for leave. An amicus memorandum should be filed by the deadline for the State’s memorandum on the same issue, absent good cause for a later filing.
IV For these reasons, IT IS ORDERED: The motions to intervene, ECF Nos. 18 and 28, are DENIED. SO ORDERED on November 6, 2012.
s/Robert L. Hinkle United States District Judge
Case No. 4:12cv285-RH/CAS

 </s> Case 6:20-cv-00024-NKM Document 44 Filed 04/28/20 Page 1 of 45 Pageid#: 462

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA
LYNCHBURG DIVISION

LEAGUE OF WOMEN VOTERS OF VIRGINIA, et al.,
Plaintiffs,
v.
VIRGINIA STATE BOARD OF ELECTIONS, et al.,
Defendants.

Case No.: 6:20-cv-00024-NKM

BRIEF OF PROPOSED INTERVENORS, REPUBLICAN PARTY OF VIRGINIA, INC., ET AL., IN OPPOSITION TO PLAINTIFFS’
MOTION FOR PRELIMINARY INJUNCTION

Patrick T. Lewis (pro hac vice pending) BAKER & HOSTETLER LLP 127 Public Square, Suite 2000 Cleveland, OH 44114-1214 216.621.0200 / Fax 216.696.0740 plewis@bakerlaw.com

Christopher M. Marston (VSB No. 65703) chris@2562group.com 2652 Group LLC P.O. Box 26141 Alexandria, VA 22313-6141 571.482.6790 / Fax 703.997.2549
Trevor M. Stanley (VSB No. 77351) E. Mark Braden (pro hac vice pending) Katherine L. McKnight (adm. pending) Richard Raile (VSB No. 84340) BAKER & HOSTETLER LLP Washington Square, Suite 1100 1050 Connecticut Avenue, N.W. Washington, DC 20036-5403 202.861.1500 / Fax 202.861.1783 tstanley@bakerlaw.com mbraden@bakerlaw.com kmcknight@bakerlaw.com rraile@bakerlaw.com

Counsel for Proposed Intervenors, Republican Party of Virginia, Inc., et al.

Case 6:20-cv-00024-NKM Document 44 Filed 04/28/20 Page 2 of 45 Pageid#: 463
TABLE OF CONTENTS
Table of Authorities ...................................................................................................... iii
I. Introduction and Summary of Argument .......................................................... 1
II. Statement of Facts .............................................................................................. 4
A. Virginia’s absentee ballot witness requirement has long been a part of Virginia law and serves an important role in preventing and deterring absentee ballot fraud. ....................................................... 4
B. The Virginia absentee ballot witness requirement is well within the range of absentee ballot security measures states require. ............. 5
C. Virginia’s policy responses to COVID-19 have focused on socialdistancing, reducing large gatherings of people and election-related issues......................................................................................................... 6
D. Plaintiffs’ limited evidence about voting-related risks relates to inperson voting, not absentee voting. ......................................................... 8
E. Plaintiffs’ evidence about election-related voting risks is sparse and unpersuasive........................................................................................... 10
F. Plaintiffs have no evidence – just mere speculation – that COVID19 will render it unsafe to comply with the absentee ballot witness requirement in any election after June 23, 2020. ................................. 11
G. Proposed Intervenors are not harmed by the absentee signature requirement, but may be harmed by absentee ballot fraud. ................ 14
III. Law and Argument ........................................................................................... 17
A. Standard of Review ................................................................................ 17
B. Plaintiffs have failed to satisfy their burden to show that a preliminary injunction is needed for any election, especially any election after the June 23, 2020 Primary. ............................................. 17
1. Plaintiffs are categorically not entitled to any relief directed to elections after the June 23, 2020 primary.............................. 17

Case 6:20-cv-00024-NKM Document 44 Filed 04/28/20 Page 3 of 45 Pageid#: 464
2. Plaintiffs have not demonstrated that COVID-19 has made compliance with Virginia’s absentee ballot witness requirement a severe burden on their right to vote. .................. 27
3. Virginia’s witness-signature requirement is long-standing and serves an important, compelling state interest in preserving the integrity of its elections. ..................................... 30
C. Plaintiffs Have Made No Showing That They Are Likely To Suffer Irreparable Harm If They Are Required To Comply With The Witness-Signature Requirement For Absentee Ballots........................ 32
D. The Public’s Interest In The Integrity Of Elections Outweighs Plaintiffs’ Speculative Claims Of Injury About Future Elections. ....... 33
E. Less Drastic Remedies Are Available For The June 23, 2020 Primary Than What Plaintiffs Demand. ............................................... 34
IV. Conclusion ......................................................................................................... 35 Certificate of Service.................................................................................................... 36
ii

Case 6:20-cv-00024-NKM Document 44 Filed 04/28/20 Page 4 of 45 Pageid#: 465
TABLE OF AUTHORITIES
Page(s)
Cases
Amnesty Int’l USA v. Clapper, 638 F.3d 118 (2d Cir. 2011) .................................................................................... 19
Anderson v. Celebrezze, 460 U.S. (1983) ................................................................................................. 25, 27
Arizonans for Fair Elections v. Hobbs, No. CV-20-00658, -- F. Supp. 3d --, 2020 WL 1905747 (D. Ariz. Apr. 17, 2020).................................................................................................................. 28
Benson Hotel Corp. v. Woods, 168 F.2d 694 (8th Cir. 1948) .................................................................................. 24
Bethea v. Deal, No. CV216-140, 2016 WL 6123241 (S.D. Ga. Oct. 19, 2016) ................................ 29
Burdick v. Takushi, 504 U.S. 428 (1992) ................................................................................................ 27
Burton v. City of Belle Glade, 178 F.3d 1175 (11th Cir. 1999) .............................................................................. 23
Carcano v. McCrory, 203 F. Supp. 3d 615 (M.D.N.C. 2016) .................................................................... 33
Clapper v. Amnesty Int’l USA, 568 U.S. 398 (2013) .................................................................................... 19, 21, 22
Crawford v. Marion County Elections Board, 553 U.S. 181 (2008) .................................................................................... 16, 28, 31
Democratic National Committee v. Bostelmann, slip op., Nos. 20-1538, 20-1539, 20-1545, 20-1546 (7th Cir. Apr. 3, 2020).................................................................................................................. 28, 32
Di Biase v. SPX Corp., 872 F.3d 224 (4th Cir. 2017) .................................................................................. 17
Eaglemed LLC v. Cox, 868 F.3d 893 (10th Cir. 2017) ................................................................................ 25
iii

Case 6:20-cv-00024-NKM Document 44 Filed 04/28/20 Page 5 of 45 Pageid#: 466
Esshaki v. Whitmer, No. 2:20-cv-10831, 2020 WL 1910154 (E.D. Mich. Apr. 20, 2020)........................ 30
Eu v. San Francisco County Democratic Central Comm., 489 U.S. 214 (1989) ................................................................................................ 31
Faircloth v. Finesod, 938 F.2d 513 (4th Cir. 1991) .................................................................................. 17
Faulkner v. Virginia Dep’t of Elections, No. CL 20-1546 (Va. Cir. Ct. Mar. 25, 2020) ......................................................... 30
Fusaro v. Cogan, 930 F.3d 241 (4th Cir. 2019) .................................................................................. 27
Gamza v. Aguirre, 619 F.2d 449 (5th Cir. 1980) .................................................................................. 33
Gasner v. Bd. of Sup’rs of the Cty. of Dinwiddie, Va., 103 F.3d 351 (4th Cir. 1996) .................................................................................. 19
Hamdi v. Rumsfeld, 542 U.S. 507............................................................................................................ 34
Howell v. McAuliffe, 292 Va. 320, 788 S.E.2d 706 (2016) ....................................................................... 32
Hutchinson v. Miller, 797 F.2d 1279 (4th Cir. 1986) .......................................................................... 33, 34
Int’l Longshoremen’s Ass’n, Local 1291 v. Philadelphia Marine Trade Ass’n, 389 U.S. 64 (1967)........................................................................................ 22
Lecky v. Virginia State Board of Elec., 285 F. Supp. 3d 908 (E.D. Va. 2018)...................................................................... 33
Lee v. Virginia State Board of Elections, 843 F.3d 592 (4th Cir. 2016) ............................................................................ 28, 31
Libertarian Party of Va. v. Alcorn, 826 F.3d 708 (4th Cir. 2016) ............................................................................ 27, 28
Louis W. Epstein Family P'ship v. Kmart Corp., 13 F.3d 762 (3d Cir. 1994)...................................................................................... 23
Mays v. Thurston, No. 4:20-cv-341, 2020 WL 1531359 (E.D. Ark. Mar. 30, 2020)............................. 28
iv

Case 6:20-cv-00024-NKM Document 44 Filed 04/28/20 Page 6 of 45 Pageid#: 467
McDonald v. Bd. of Election Comm’rs, 394 U.S. 802 (1969) ................................................................................................ 30
McLaughlin v. North Carolina Board of Elec., 65 F.3d 1215 (4th Cir. 1995) .................................................................................. 27
Pasadena City Bd. of Ed. v. Spangler, 427 U.S. 424 (1976) ................................................................................................ 22
Pashby v. Delia, 709 F.3d 307 (4th Cir. 2013) .................................................................................. 17
Payne v. Travenol Labs., Inc., 565 F.2d 895 (5th Cir. 1978) .................................................................................. 23
Purcell v. Gonzalez, 549 U.S. 1 (2006) .................................................................................................... 31
Reardon v. LaRose, No. 20CV-2105 (Franklin Co. C.P. Mar. 17, 2020)................................................ 28
Reynolds v. Sims, 377 U.S. 533 (1964) ................................................................................................ 32
Rizzo v. Goode, 423 U.S. 362 (1976) ................................................................................................ 22
Rosario v. Rockefeller, 410 U.S. 752 (1973) ................................................................................................ 31
Scotts Co. v. United Industries Corp., 315 F.3d 264 (4th Cir. 2002) .................................................................................. 32
Storer v. Brown, 415 U.S. 724 (1974) ................................................................................................ 27
Texas v. United States, 523 U.S. 296 (1998) ................................................................................................ 21
Toussaint v. McCarthy, 801 F.2d 1080 (9th Cir. 1986), abrogated in part on other grounds by Sandin v. Conner, 515 U.S. 472 (1995)....................................................... 24, 26
Veasey v. Abbott, 830 F.3d 216 (5th Cir. 2016) (en banc) .................................................................. 16
v

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Washington State Grange v. Washington State Republican Party, 552 U.S. 442 (2008) ................................................................................................ 26
Whitmore v. Arkansas, 495 U.S. 149 (1990) ................................................................................................ 19
Winter v. Natural Resources Defense Council, Inc., 555 U.S. 7 (2008) .................................................................................................... 17
Statutes Act of Apr. 1, 1948 ......................................................................................................... 4 Act of Mar. 22, 1975....................................................................................................... 4 Ala. Code § 17-9-30(b).................................................................................................... 5 Ark. Code § 7-5-409(4)(A)(v) .......................................................................................... 5 Cal. Elec. Code § 3019 ................................................................................................... 6 Colo. Rev. Stat. §1-7.5-107.3 ......................................................................................... 6 Fla. Stat. § 101.68 .......................................................................................................... 6 Ill. Comp. Stat. Ann. 5/19-8........................................................................................... 6 Iowa Code § 53.18(2) ...................................................................................................... 6 Kan. Stat. § 25-1122(c) .................................................................................................. 5 Mass. Gen. Laws ch. 54 § 94 ......................................................................................... 6 Mich. Comp. Laws § 168.766......................................................................................... 6 Minn. Stat. § 203B.07(3)................................................................................................ 5 Minn. Stat. § 203B.121 .................................................................................................. 6 Mont. Code § 13-13-241 ................................................................................................. 6 N.C. Gen. Stat. § 163-231(a).......................................................................................... 5 Nev. Rev. Stat. 293.333 ................................................................................................. 6 Ohio Rev. Code § 3509.05(A) ......................................................................................... 5 Ohio Rev. Code § 3509.06 .............................................................................................. 6
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Okla. Stat. tit. 26, § 14-108(A) ...................................................................................... 5 Ore. Rev. Stat. § 254.431 ............................................................................................... 6 R.I. Gen. Laws § 17-20-2.1(d)(4).................................................................................... 5 Utah Code Ann. § 20A-3-308 ......................................................................................... 6 Va. Code Ann. § 24.2-508 (2019) ................................................................................. 14 Va. Code § 24.2-516 ..................................................................................................... 14 Va. Code § 24.2-707(A)............................................................................................... 4, 5 Wash. Admin. Code 434-261-050 .................................................................................. 6 Wis. Stat. § 6.87 ............................................................................................................. 6 Rules Fed. R. Civ. P. 65(d) ............................................................................................... 22, 23 Other Authorities 11A Charles A. Wright, et al., Federal Practice & Procedure, Civil (3d
ed.)........................................................................................................................... 24 1948 Regular Session, ch. 377 ....................................................................................... 4 1975 Regular Session, ch. 515 ....................................................................................... 4 Absentee Voting, Va Dep’t of Elections (visited Apr. 26, 2020) ................................... 8 Andrew C. Berry, D.O., Madhuri S. Mulekar, and Bruce B. Berry,
M.D., Wisconsin April 2020 Election Not Associated With Increase In COVID-19 Infection Rates ................................................................................. 11 CDC, Opening Up America Again............................................................................... 13 CDC, Recommendations for Election Polling Locations, Coronavirus Diseaes 2019 (COVID-19) ......................................................................................... 9 David Wahlberg, No bump in COVID-19 rates after Wisconsin’s April 7 election, study says, Wisconsin State J., April 25, 2020........................................ 11 Dom Calicchio, Wisconsin saw no coronavirus infection-rate spike after April 7 election, study says, FoxNews.com, April 25, 2020 ................................... 11
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Executive Order 2020-51 ............................................................................................... 6 Executive Order 2020-53 ............................................................................................... 7 Executive Order 2020-55 ............................................................................................... 7 FAQ, Executive Order 2020-55 ................................................................................... 13 Fergus Walsh, Coronavirus: First patients injected in UK vaccine trial,
British Broadcasting Corp., Apr. 23, 2020 ............................................................ 12 Gerald F. Seib, Pence Says Coronavirus Could Be Largely Past by
Early June, Wall Street J. (April 22, 2020)........................................................... 20 Governor Northam Announces Plans to Postpone Upcoming Virginia
Elections In Response to COVID-19, Apr. 8, 2020 .................................................. 8 Jennifer Calfas et al., U.S. Debates How Quickly It Can Reopen, Wall
Street J. (Apr. 26, 2020) ......................................................................................... 20 Leigh Ann Caldwell and Dartunorro Clark, New election ordered in
North Carolina House district after possible illegal activities, NBC News (Feb. 21, 2019) .............................................................................................. 16 Newley Purnell and Max Colchester, Some States Ease Lockdowns as Global Coronavirus Cases Near 3 Million, Wall Street J. (April 27, 2020)........................................................................................................................ 20 President Jimmy Carter and James Baker, et al. Report of the 2005 Commission on Federal Election Reform, The Center for Democracy and Election Management, American University (Sept. 2005) ............................ 16 Sierra Fox, Reopening Virginia: Gov. Northam says state needs ample PPP, COVID-19 testing, before it’s safe, WRIC News, Apr. 21, 2020. .................. 13
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I. INTRODUCTION AND SUMMARY OF ARGUMENT The COVID-19 pandemic undisputedly presents an historic challenge to the
American people.1 Public-health experts and policymakers have moved swiftly to adopt measures to protect the public and to adjust those measures as the threat evolves and our understanding of this “novel” virus grows. At both the state and national levels, officials are now building a framework to “re-open” the country, in phases, as the pandemic slows.
The Commonwealth of Virginia has seen its own share of measures to protect the public, including a host of provisions aimed at, or resulting in, making the 2020 elections more safe. For example, citizens of Virginia are living under a state of emergency and are required to stay at home except for a set of specified exceptions; absentee ballots may be requested by all registered voters—not just those who have pre-approved excuses—in order to decrease in-person voting numbers; and the primary elections originally scheduled for June 9 have been postponed until June 23, after the stay-at-home order expires.
In their preliminary-injunction motion, Plaintiffs ask this Court to enjoin Virginia’s 70-year-old statutory requirement that absentee ballots be witnessed. They claim their health would be unacceptably imperiled if someone witnesses them cast their absentee ballots, then signs the ballot envelope. They also claim the statute serves no purpose that justifies the alleged burden on the right to vote caused by complying with the witness requirement.
1 For ease of reference this brief may also refer to COVID-19 as “coronavirus.”

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But Virginia’s policymakers—including Governor Northam—recently considered and adjusted the absentee ballot provisions and deemed the witness requirement worth keeping. Those same policymakers considered whether to act further in the face of this pandemic, and they stayed their hand.
The Court should stay its hand, too. Though this trial has provoked fear on the part of many Virginia citizens, Plaintiffs have not shown that compliance with the witness requirement for the June 23, 2020 primary would pose an unreasonable health risk to them. Voters can comply fully with the witness requirement while social-distancing and taking appropriate precautions to limit risk (including the same precautions they take in obtaining groceries and other necessities). If the Court does enjoin the witness requirement for the June 23 primary, it should order a substitute measure of protection. Proposed Intervenors would propose that, if the Court feels it must act, that it consider a less drastic remedy. The Voter Defendant Intervenors suggest using Virginia’s E-Notary law to allow electronic witnessing (ECF No. 37 at 6) if a voter feels that he or she cannot safely comply with the witness requirement. Another alternative would be to permit the voter to write the last four digits of the voter’s SSN on the ballot envelope, which would provide at least minimal authentication of the voter who cast the absentee ballot.
Even if this Court is inclined to grant relief for the upcoming June primary elections, it should deny Plaintiffs’ request for an indefinite injunction to apply to the November elections and beyond. But it is unlikely that current conditions will continue unchanged for six months, and the Court lacks jurisdiction to resolve the
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entirely hypothetical possibility that they will. COVID-19 did not even exist six months ago, and already public health officials and others, working around the clock, have a better grasp than they did just weeks ago about the nature of the virus and who is most at risk. Policymakers have time to consider this evolution and adjust, if necessary, any election rules before November. Furthermore, Plaintiffs’ motion is nearly silent on the preliminary-injunction factors as they relate to November’s elections. Plaintiffs failed to meet their evidentiary burden to support such an indefinite injunction, any dispute about an election after June is not ripe, and the Court lacks subject-matter jurisdiction to hear the dispute.
Finally, there is no merit in Plaintiffs’ casual dismissal of Virginia’s absentee witness requirement as (they claim) doing “little if nothing” to help ensure the integrity of Virginia elections. They are wrong about its value, and they are wrong about the risk of fraud. The Commonwealth has a compelling interest in deterring absentee ballot fraud and safeguarding the integrity of its elections. Proposed Intervenors also have a right to not have their votes diluted by fraud. The witness requirement serves an important role in furthering the objective of ensuring election integrity. Meanwhile, Plaintiffs have established no burden on the right to vote, even in the time of COVID-19, and Plaintiffs fail to establish that they or any other voter will be prevented from casting a vote.
For these reasons, Plaintiffs’ Motion for Preliminary Injunction (ECF No. 16) (“Pls’ Motion”) should be denied.
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II. STATEMENT OF FACTS A. Virginia’s absentee ballot witness requirement has long been a part of Virginia law and serves an important role in preventing and deterring absentee ballot fraud. Virginia’s witness requirement for absentee ballots has a long history. At
least as far back as 1948, Virginia required absentee ballots to be opened and voted in the presence of a notary public. See, e.g., Act of Apr. 1, 1948, Acts and Joint Resolutions of the General Assembly, 1948 Regular Session, ch. 377 (providing that ballots were not to be opened “‘except in presence of a notary public.’”). In 1975, the provision was amended to eliminate the notary requirement and to only require one witness. Act of Mar. 22, 1975, Acts and Joint Resolutions of the General Assembly, 1975 Regular Session, ch. 515 at 1074.
The longstanding witness requirement serves an important purpose: promoting and protecting the integrity of the electoral process by deterring absentee ballot fraud. The law’s requirements are simple. “On receipt of a mailed absentee ballot, the voter shall, in the presence of a witness, (i) open the sealed envelope marked “ballot within” and (ii) mark and refold the ballot, as provided in §§ 24.2644 and 24.2-646, without assistance and without making known how he marked the ballot, except [by reason of blindness, disability, or inability to read or write] as provided by § 24.2-704.” Va. Code § 24.2-707(A). Then, the voter seals, completes, and signs the ballot envelope, which is then signed by the witness. Finally, the voter encloses the ballot envelope in a return envelope addressed to the general registrar. Id.
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Thus, the basic elements of the requirement are simply that (1) there is a witness, and (2) that witness signs the ballot envelope. Notably, the statute says nothing about the distance between the voter and the witness. See id. And unsurprisingly, the statute also says nothing that would prevent now-commonplace social-distancing measures from being observed—masks, gloves, separate pens, hand sanitizer, and countless other precautions are all consistent with the statute.
B. The Virginia absentee ballot witness requirement is well within the range of absentee ballot security measures states require.
Plaintiffs suggest that Virginia’s absentee ballot requirements are uncommonly strict. That is not true. In reality, the rules for casting and verifying absentee ballots vary widely throughout the United States, and some states have much more protective rules than Virginia.
For example, some states require two witnesses, or notarization, where Virginia only requires one witness. See Ala. Code § 17-9-30(b); N.C. Gen. Stat. § 163-231(a); 17 R.I. Gen. Laws § 17-20-2.1(d)(4). At least one state requires notarization. See Okla. Stat. tit. 26, § 14-108(A). Another permits an absentee voter to obtain a signature from one attesting witness and also requires an official authorized to administer oaths to sign the initial application for the ballot. See Miss. Code. § 23-15-627 (an absent voter’s signature on a ballot application must be “sworn to and subscribed before” such an official). And several states require submission of a copy of an ID card or some other form of verification of registration, such as driver’s license numbers or Social Security numbers. See Ark. Code § 7-5409(4)(A)(v); Kan. Stat. § 25-1122(c); Minn. Stat. § 203B.07(3); Ohio Rev. Code §
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3509.05(A). More than half of the states impose some requirement to assure the integrity of absentee ballots, be it through the kinds of rules described above, or alternatives, like signature verification. See, e.g., Cal. Elec. Code § 3019; Colo. Rev. Stat. §1-7.5-107.3; Fla. Stat. § 101.68; 10 Ill. Comp. Stat. Ann. 5/19-8; Iowa Code § 53.18(2); Mass. Gen. Laws ch. 54 § 94; Mich. Comp. Laws § 168.766; Minn. Stat. § 203B.121; Mont. Code § 13-13-241; Nev. Rev. Stat. 293.333; Ohio Rev. Code § 3509.06; Ore. Rev. Stat. § 254.431; Utah Code Ann. § 20A-3-308; Wash. Admin. Code 434-261-050; Wis. Stat. § 6.87.
C. Virginia’s policy responses to COVID-19 have focused on socialdistancing, reducing large gatherings of people and electionrelated issues.
Virginia, like most states, has taken certain temporary, emergency actions to respond to the threat posed by COVID-19. These measures have focused on encouraging social-distancing and reducing gatherings of people but have also addressed election-related issues.
First, Governor Ralph Northam declared a state of emergency on March 12, 2020. (Va. Exec. Order 2020-51.)2 The declaration of emergency expires on June 10, 2020. (Id. at 2.)
Next, on March 23, 2020, Governor Northam entered an executive order that closed the schools in Virginia through the rest of the academic year and barred gatherings of more than 10 people, closed dining establishments, and limited the
2 Executive Order 2020-51 is available at: https://www.governor.virginia.gov/media/governorvirginiagov/governor-of-virginia/pdf/eo/EO-51Declaration-of-a-State-of-Emergency-Due-to-Novel-Coronavirus-(COVID-19).pdf.
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operation of certain businesses through April 23, 2020. (Va. Exec. Order 2020-53.)3 That Order required certain categories of businesses (e.g., beauty salons, racetracks, and bowling alleys) to close entirely; allowed other categories of businesses (e.g. restaurants) to operate with a limit on ten people inside the establishment; and permitted 13 categories of business—ranging from grocery stores to office supply stores to liquor stores—to remain open as “essential” businesses. (Id. ¶ 3-5.) This Executive Order did not, however, address elections.
On March 30, 2020, Governor Northam signed Executive Order 2020-55, the so-called “stay at home order,” that directed Virginians to stay at home except to engage in a wide range of activities permitted by that order, including obtaining food or beverages, seeking medical attention, taking care of other individuals, engaging in outdoor activities, volunteering with organizations that provide charitable or social services, or traveling to work. (Executive Order 2020-55, ¶ 1.)4 The Executive Order directs people to practice social-distancing by, among other things, staying at least “six feet” apart. (Id.). This order, like the emergency declaration, expires on June 10, 2020. (Id. at 3.) And like the other orders, it does not address voting.
3 Executive Order 2020-53 is available at: https://www.governor.virginia.gov/media/governorvirginiagov/executive-actions/EO-53-TemporaryRestrictions-Due-To-Novel-Coronavirus-(COVID-19).pdf. 4 Executive Order 2020-55 is available at: https://www.governor.virginia.gov/media/governorvirginiagov/executive-actions/EO-55-TemporaryStay-at-Home-Order-Due-to-Novel-Coronavirus-(COVID-19).pdf.
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On April 8, 2020, Governor Northam addressed voting when he postponed the Primary Election from June 9 to June 23.5 The Virginia Department of Elections also identified COVID-19 as a valid reason for voters to choose “2A My disability or illness” to request an absentee ballot, and stated that “voting absentee in the coming May and June elections is strongly encouraged.”6 Importantly, Virginia will still permit in-person voting during the rescheduled June 23, 2020 Primary Election; absentee balloting is just one available voting option.7
D. Plaintiffs’ limited evidence about voting-related risks relates to in-person voting, not absentee voting.
Plaintiffs have not produced evidence that Virginia’s policy response is not enough and that compliance with the witness requirement would result in the further spread of COVID-19. Instead, Plaintiffs present only a few examples of poll workers or voters contracting coronavirus after voting at the polls as evidence that voting is risky. (Plaintiffs’ Brief in Support of Motion for Preliminary Injunction, ECF No. 17, at 6-7) (“Pls’ Br.”) They cited the case of a Chicago poll worker who died from COVID-19, that of two poll workers in Broward County, Florida who tested positive for coronavirus, and assertions that Milwaukee, Wisconsin’s April 7 primary resulted in seven coronavirus infections (six voters and one poll worker). (Id. at 6-7, nn. 21-23; Reingold Decl. ¶ 17.) As shown below, this limited, anecdotal evidence is not useful to assess the risks posed even by in-person voting.
5 Governor Northam Announces Plans to Postpone Upcoming Virginia Elections In Response to COVID-19, Va. Gov Office, Apr. 8, 2020, https://www.governor.virginia.gov/newsroom/allreleases/2020/april/headline-855995-en.html. 6 Absentee Voting, Va Dep’t of Elections, https://www.elections.virginia.gov/casting-a-ballot/absenteevoting/ (visited Apr. 26, 2020). 7 See id.
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But this evidence does not address absentee voting at all, and voting inperson at a polling place is not comparable to voting absentee from home. Polling places expose voters to a closed and potentially crowded public space and require multiple interactions with the public. Hence, CDC’s guidance for election officials (that Plaintiffs cite) recommends that states “encourage voters to use voting methods that minimize direct contact with other people and reduce crowd size at polling stations.”8 Likewise, the thrust of the stay-at-home Executive Order 2020-55 is to discourage crowds (limiting any gatherings to ten persons) and unnecessary person-to-person contact (instead encouraging people to stay six feet apart.) (Id. at ¶¶ 1-3.) It is not reasonable to compare the risk to a voter of standing in line at a crowded public polling place in Milwaukee to the risk posed by one person witnessing a voter’s signature.
Dr. Reingold, for example, asserts that “requiring individuals to have someone they are not otherwise being exposed to come into close enough proximity to witness their ballot would place them at increased risk of infection” – an opinion he supports with the example of alleged transmission in Milwaukee polling places. (Reingold Decl. at ¶ 17.) Dr. Reingold has not studied Virginia’s absentee-ballot procedure to assess the required proximity between voter and witness, nor has he reported any medical evidence of coronavirus transmission through absentee voting.
8 Recommendations for Election Polling Locations, Coronavirus Disease 2019 (CIVID-19), U.S. Centers for Disease Control and Prevention, https://www.cdc.gov/coronavirus/2019ncov/community/election-polling-locations.html (visited Apr. 26, 2020).
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And critically, Dr. Reingold did not opine that compliance with the witness requirement compelled a violation of six-foot social-distancing guidelines.
A voter can comply with the witness requirement without coming within six feet of the witness. The witness can observe the act of voting the ballot from more than six feet away, and can sign the sealed ballot envelope afterward from a safe distance. Any concern about the witness touching the ballot envelope can be mitigated if the voter places the envelope in the mailbox straight away and then washes his or her hands. This is the same procedure health-conscious persons living alone during the COVID-19 quarantine employ to protect themselves after restocking their pantries; whether they do their own grocery shopping or receive athome deliveries, they can and do wash their hands. Even if COVID-19 can be transmitted at polling places, evidence of such transmission does not provide evidence of risk associated with absentee voting and compliance with Virginia’s witness requirement.
E. Plaintiffs’ evidence about election-related voting risks is sparse and unpersuasive.
Setting aside the key distinctions between in-person and absentee voting, Plaintiffs’ evidence of the COVID-19 risk of voting in person does not show a material risk of coronavirus infection posed by voting. A total of ten cases across the country is, on its own, weak evidence of a pattern. But without reporting how many total voters and poll-workers turned out in the elections Plaintiffs cited, the raw case count is meaningless as a tool to assess risk. Ten cases out of 1,000 people at the polls is one thing; ten cases out of 50,000 people, or 100,000 people, is another.
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And it is not clear whether these ten individuals caught coronavirus at the polls. The New York Times article Dr. Reingold relies upon, for example, stated that the
Wisconsin officials they quoted did not say how the coronavirus cases were traced to the polls.
Further, a recent study undercuts Plaintiffs’ argument about Wisconsin’s experience. The study,9 reported in the Wisconsin State Journal10 and Fox News,11
compared Wisconsin’s growth rate in COVID-19 cases before and after the April 7 primary, and the rate for the three most populous counties (including Milwaukee). The researchers “did not find any significant increase in the rate of new COVID-19
cases following the April 7, 2020 election post-incubation period, for the state of Wisconsin or its three major voting counties, as compared to the U.S.” (Study at 7.)
Indeed, they reported a decrease in the rate of new cases in Milwaukee County following the primary date. (Id. at 6.)
F. Plaintiffs have no evidence – just mere speculation – that COVID-19 will render it unsafe to comply with the absentee ballot witness requirement in any election after June 23, 2020.
Plaintiffs ask the Court to enjoin the witness requirement for not only the
June 23, 2020 Primary Election, but also for all “future” elections until any threat
9 Andrew C. Berro, D.O., Madhuri S. Mulekar, Ph.D., and Bruce B. Berry, M.D., Wisconsin April 2020 Election Not Associated With Increase In COVID-19 Infection Rates. Unpublished manuscript, https://bloximages.chicago2.vip.townnews.com/madison.com/content/tncms/assets/v3/editorial/6/47/64 7a9bf3-0646-5f61-913c-1d0a584824a5/5ea336829248d.pdf.pdf. 10 David Wahlberg, No bump in COVID-19 rates after Wisconsin’s April 7 election, study says, Wisc. St. J., April 25, 2020, https://madison.com/wsj/news/local/health-med-fit/no-bump-in-covid-19-ratesafter-wisconsins-april-7-election-study-says/article_b1aade1d-abec-5fc2-92fb-e1c64ccbc92f.html. 11 Dom Calicchio, Wisconsin saw no coronavirus infection-rate spike after April 7 election, study says, FoxNews.com, April 25, 2020, https://www.foxnews.com/politics/wisconsin-saw-no-coronavirusinfection-rate-spike-after-april-7-election-study-says.
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from COVID-19 passes. But Plaintiffs have produced no evidence to the Court, at all, to support such a broad and indefinite injunction.
Plaintiffs’ witness, Dr. Reingold, repeatedly refers to the coronavirus as a “novel virus” about which the medical community is still learning. (Reingold Decl. ¶¶ 7, 15-16.) He anticipates that the country “can expect resurgences of COVID19...throughout 2020 and into 2021 across the United States,” but does not opine about how many resurgences, how bad they will be, or where and specifically when they will strike. (Id. ¶ 15.) He is unable to even say whether coronavirus transmission is affected by the weather. (Id. ¶ 16.) Tellingly, he believes a vaccine will not be available until, possibly, the end of 2021 due to issues including the length of time it takes to conduct a human trial of any potential drug. (Id. ¶ 13.) But news reports since Plaintiffs filed their Motion indicate that human trials have already begun and a team of doctors from Oxford believe a vaccine may be available as early as September this year.12 To be clear, we do not know if this vaccine will succeed, and it is not surprising that a learned doctor such as Dr. Reingold does not fully understand this novel coronavirus today. And that is the problem. Dr. Reingold and other medical professionals will know more in several months, and the current dearth of information, and constantly evolving facts, are hardly the basis the Court needs to permanently enjoin the witness signature rule today.
In addition, the public health orders from Governor Northam expire on June 10, 2020, almost two weeks before the June 23,2020 Primary Election. Virginia’s
12 BBC, Coronavirus; First patients injected in UK vaccine trial, https://www.bbc.com/news/health52394485 (Apr. 23, 2020) (accessed on Apr. 27, 2020).
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policies, indeed, are short-term and subject to change. None of Governor Northam’s Executive Orders are in effect beyond June 10, 2020. The FAQs published by the Governor’s office for Executive Order 2020-55 highlight the “quickly-changing” nature of the policy response to COVID-19:
Q. Will this order be changed? A. Governor Northam, in consultation with State Health Commissioner Oliver, may adjust this order or issue new orders as needed, given the quickly-changing public health situation. (FAQ, Executive Order 2020-55, at https://www.virginia.gov/coronavirus/faq/ (visited Apr. 26, 2020). Further, the CDC has issued a three-phased plan titled “Opening Up America Again” that calls for a gradual, data-driven re-opening of the country.13 At a virtual townhall meeting on April 21, 2020, Governor Northam announced his intentions to follow the CDC’s plan, even expressing the hope that by July, the virus would be “in the rearview mirror,” while cautioning that large public gatherings this summer may not be feasible.14 In short, COVID-19 is not yet well understood. Policymakers are taking short, deliberate steps as they develop and refine their public-health strategies. While Virginia’s orders in the past have focused on getting residents to stay home, the thrust of policymaking going forward is to re-open the country. Plaintiffs have not provided evidence to this Court to suggest that prevailing health conditions in
13 CDC, Opening Up America Again, https://www.whitehouse.gov/openingamerica/#phase-one (visited Apr. 26, 2020.) 14 Sierra Fox, Reopening Virginia: Gov. Northam says state needs ample PPP, COVID-19 testing, before it’s safe, https://www.wric.com/news/virginia-news/reopening-virginia-gov-northam-says-stateneeds-ample-ppe-covid-19-testing-before-its-safe/ (Apr. 21, 2020, visited Apr. 26, 2020.)
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Virginia in November 2020 will preclude them from voting, whether in-person at the polls or absentee.
G. Proposed Intervenors are not harmed by the absentee signature requirement, but may be harmed by absentee ballot fraud.
Proposed Intervenors will not be harmed by the enforcement of Virginia’s witness requirement for absentee ballots. Proposed Intervenor, the Republican Party of Virginia, Inc. (“RPV”), is a major political party with a recognized power to “provide for the nomination of its candidates…,” and “perform all other functions inherent in political party organizations” is recognized in statute. Va. Code Ann. § 24.2-508 (2019). The RPV adopted a direct primary and timely notified the Virginia State Board of Elections of its choice pursuant to Va. Code § 24.2-516. The Board then ordered the holding of a Republican Primary for U.S. Senate and U.S. House of Representatives in the second and third congressional districts.
This absentee ballot witness requirement has long been part of Virginia law and in the RPV’s experience, has not been identified as impacting any election outcomes. Notably, the individual Proposed Intervenors each believe they can readily comply with the witness requirement without compromising their safety.
Ms. Mildred Scott is a 91-year-old woman who lives alone in Roanoke County. (Declaration of Mildred H. Scott, attached as Exhibit A (“Scott Decl.”) at ¶ 1, 2, 8.) She understands she is classified as a higher-risk for COVID-19 due to her age. (Id. ¶ 5.) She states that she complies with Governor Northam’s orders, including the stay-at-home order. (Id. ¶ 6.) Nonetheless, she is confident she can find a witness to
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sign her absentee ballot for the June 23, 2020 Primary, as she has several friends who live close by who are willing to help. (Id. ¶ 8).
Mr. Thomas Turner is a 30-year-old Black male who resides and votes in the City of Suffolk, in the third congressional district. (Declaration of Thomas N. Turner, Jr., attached as Exhibit B (“Turner Decl.”), ¶ 2.) Mr. Turner is also active in Virginia politics, serving as chairman of the Young Republican Federation of Virginia, which engages young voters, ages 18-40, in the political process and works to elect Republican candidates and to encourage its members to become officers of election. (Id. ¶ 3.) Like Ms. Scott, Mr. Turner intends to comply with socialdistancing guidelines and is confident he can find a witness to sign his absentee ballot for the June 23, 2020 Primary, as he has work colleagues willing to do so. (Id. ¶ 8.)Significantly, none of the individual Proposed Intervenors believe that the witness requirement burdens their right to vote. (Scott Decl. ¶ 9; Turner Decl. ¶ 9.)
Nevertheless, Proposed Intervenors are very concerned about the risk of absentee ballot fraud. Ms. Scott served for a number of years as an officer of election in Roanoke County. (Scott Decl. ¶ 2.) Mr. Turner is active in politics. (Turner Decl. ¶ 3.) The RPV is a political party. They believe that election integrity safeguards like the witness requirement are vital to fair and honest elections, and that removing the safeguard may allow votes to be cast by persons not entitled to cast them, thereby diluting Proposed Intervenors’ lawful votes. (Scott Decl. ¶ 10; see also Turner Decl. ¶ 10.)
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These concerns are not merely conjectural. As early as 2005, absentee ballot fraud was identified as “the largest source of potential voter fraud” by a bipartisan study co-chaired by President Jimmy Carter and James Baker.15 The lead opinion in Crawford v. Marion County Elections Board, 553 U.S. 181, 195-96 (2008) (plurality op.) described “fraudulent voting” that was “perpetrated using absentee ballots.” See also Veasey v. Abbott, 830 F.3d 216, 239, 256 (5th Cir. 2016) (en banc) (noting that “record evidence shows that the potential and reality of fraud is much greater in the mail-in ballot context than with in-person voting” and that the district court credited expert testimony “showing mail-in ballot fraud is a significant threat....”) On February 21, 2019, the North Carolina Board of Elections ordered a new election in a congressional race after investigating allegations that the winning candidate had engaged in “ballot harvesting” of absentee ballots in violation of state law.16 Given the rapid expansion of absentee balloting in Virginia due to COVID-19, Proposed Intervenors submit that now is not the time to eliminate long-standing anti-fraud safeguards in Virginia’s absentee ballot voting system.
15 Building Confidence in U.S. Elections, Report of the Commission on Federal Election Reform, the Center for Democracy and Election Management, American University (Sept. 2005), p. 46, https://www.legislationline.org/download/id/1472/file/3b50795b2d0374cbef5c29766256.pdf. Notably, this study garnered heated attention following its issuance, including a detailed “Response” from the Brennan Center, but that lengthy Response never questioned the study’s finding that absentee ballots are the largest source of potential voter fraud. Response to the Report of the 2005 Commission on Federal Election Reform (2005), https://www.brennancenter.org/sites/default/files/analysis/Response%20to%20CarterBaker%20Commission.pdf. 16 Leigh Ann Caldwell and Dartunorro Clark, New election ordered in North Carolina House district after possible illegal activities, NBC News (Feb. 21, 2019), https://www.nbcnews.com/politics/congress/republican-candidate-mark-harris-calls-new-electionnorth-carolina-disputed-n974176?cid=public-rss_20190221.
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III. LAW AND ARGUMENT A. Standard of Review In order to demonstrate entitlement to a preliminary injunction, Plaintiffs
must demonstrate the following four factors: “(1) [they are] likely to succeed on the merits, (2) [they are] likely to suffer irreparable harm, (3) the balance of hardships tips in [their] favor, and (4) the injunction is in the public interest.” Pashby v. Delia, 709 F.3d 307, 320 (4th Cir. 2013), citing Winter v. Natural Resources Defense Council, Inc., 555 U.S. 7, 20 (2008). Each element must be satisfied “as articulated.” Id.
B. Plaintiffs have failed to satisfy their burden to show that a preliminary injunction is needed for any election, especially any election after the June 23, 2020 Primary.
Here, Plaintiffs seek to enjoin the enforcement of a Virginia statute on Constitutional grounds. “Statutes are presumed constitutional.” Faircloth v. Finesod, 938 F.2d 513, 516 (4th Cir. 1991). Furthermore, the grant of a preliminary injunction is an “extraordinary remedy intended to protect the status quo and prevent irreparable harm during the pendency of a lawsuit.” Di Biase v. SPX Corp., 872 F.3d 224, 230 (4th Cir. 2017). Accordingly, Plaintiffs must “make a clear showing” that they are likely to succeed on the merits. Pashby, 709 F.3d at 321. Because Plaintiffs cannot make this showing, their motion should be denied.
1. Plaintiffs are categorically not entitled to any relief directed to elections after the June 23, 2020 primary.
As an initial matter, in their motion for preliminary injunction, Plaintiffs request not only that the absentee witness requirement be enjoined for the June 23,
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2020 Primary Election, but also for “any and all subsequent elections in Virginia until such time as in-person interactions required by compliance with the witness requirement no longer pose a risk to public health and safety.” (Pls’ Br. at 35.) However, as outlined in Section II(F), supra, Plaintiffs produced no evidence as to what prevailing health conditions would be in Virginia in November 2020 or any subsequent date, let alone what potential impact those conditions would have on Plaintiffs’ ability to vote in those elections. All Plaintiffs provided was speculation.
Plaintiffs are not entitled to such an open-ended injunction for two reasons. First, any dispute about elections several months or years away that hinge on unknowable future contingencies, like the future state of the COVID-19 epidemic, are not ripe. The Court therefore lacks subject-matter jurisdiction to review such disputes. Second, even if the Court finds the dispute is ripe, Plaintiffs have failed to meet their evidentiary burden for an injunction.
a. Plaintiffs’ claims are not ripe. The Court lacks jurisdiction to issue injunctive relief governing “any and all subsequent elections in Virginia,” as Plaintiffs demand. (Pl’s Br. at 35.) There is no constitutionally cognizable case or controversy over what (if any) modifications to Virginia election procedure will be constitutionally mandated in November 2020 and beyond due to COVID-19 because it is entirely speculative what the state of public health will then be. Plaintiffs’ effort to solve this problem by building in future contingencies into a proposed order is no solution at all; it only raises more problems. The issue is not ripe.
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1. Speculative Future Impact of COVID-19. “An allegation of a possible future injury does not satisfy the requirements of Article III of the Constitution.” Gasner v. Bd. of Sup’rs of the Cty. of Dinwiddie, Va., 103 F.3d 351, 361 (4th Cir. 1996). The Supreme Court has “repeatedly reiterated that ‘threatened injury must be certainly impending to constitute injury in fact,’ and that ‘[a]llegations of possible future injury’ are not sufficient” to establish a ripe controversy. Clapper v. Amnesty Int’l USA, 568 U.S. 398, 409 (2013) (quoting Whitmore v. Arkansas, 495 U.S. 149, 158 (1990)) (emphasis and edit marks in original). The Supreme Court has further emphasized that it is insufficient to establish even an “objectively reasonable likelihood” of future harm; rather, the injury must be certain and impending. Id. at 410 (quoting and rejecting the standard of Amnesty Int’l USA v. Clapper, 638 F.3d 118, 134 (2d Cir. 2011)).
Here, there is no certain and impending harm even alleged (or capable of being plausibly alleged or shown) beyond June 2020. Plaintiffs challenge Virginia’s absentee ballot witness requirement as applied under the “spread of COVID-19.” (Pls’ Mot. at 1.) But it is entirely speculative whether or to what degree COVID-19 will spread beyond the next few months. Plaintiffs acknowledge that the Virginia Governor’s stay-at-home order is set to last only “until June 10” (Pls’ Br. at 8), which signals the Virginia executive branch’s uncertainty as to conditions beyond that date. The myriad of state and federal guidance documents and orders are being continually updated, virtually on a day-to-day basis, and the necessity over stay-athome orders, even applied at present, is hotly contested. Some states are already
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easing restrictions; and those choices are subject to criticism. See, e.g., Newley Purnell and Max Colchester, Some States Ease Lockdowns as Global Coronavirus Cases Near 3 Million, the Wall Street Journal (April 27, 2020).17 The Vice President, meanwhile, predicts that “the coronavirus epidemic can be ‘largely in the past’ by early June.” Gerald F. Seib, Pence Says Coronavirus Could Be Largely Past by Early June, the Wall Street Journal (April 22, 2020).18
The Court need not take sides in this ongoing public-policy debate. The future of COVID-19 is unknown. Even the more pessimistic voices predict that “[s]ocial distancing will be with us through the summer” and do not purport to project the state of affairs as of November 2020, the next statewide Virginia election after June. Jennifer Calfas et al., U.S. Debates How Quickly It Can Reopen, The Wall Street Journal (Apr. 26, 2020).19 And Plaintiffs have failed to identify a single governmental guidance document, or a guidance document from any reputable research or public-policy institution, purporting to predict the impact of COVID-19 as of November 2020 or beyond. The Proposed Intervenors are aware of no such guidance or prediction. Certainly, the parties can all agree in hoping that COVID-19 will be safely behind us long before then.
And even if COVID-19 exists in some form in November 2020, there is no way to assess at this time the constitutionally significant issues of degree and harm it
17 https://www.wsj.com/articles/coronavirus-latest-news-04-27-202011587982265?mod=hp_lead_pos1. 18 https://www.wsj.com/articles/pence-says-u-s-will-be-prepared-if-second-coronavirus-wave-hits11587580040 19 https://www.wsj.com/articles/virus-fallout-continues-as-u-s-deaths-near-54-000-11587885746
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may entail. By that point, the impact may simply be more limited. Or else, there may be a better medical response, such as a vaccine or effective treatment. The general population may have developed “herd immunity,” limiting the disease’s reach, impact, or severity. And there may be factors calling for a different type of injunction than Plaintiffs envision (assuming one is merited at all), such as one incorporating future testing capabilities that may emerge or updated socialdistancing guidance. Besides that, the General Assembly and Governor may, with the guidance of this Court’s forthcoming ruling as to the June election, legislate a solution. The Court does not know and has no way to know how any of these contingencies will turn out.
Plaintiffs therefore fall well short of establishing that an injury in future elections is “certainly impending.” Clapper, 568 U.S. at 409. It is too early to know, beyond June 2020, “whether the problem [Plaintiffs] present[] will ever need solving.” Texas v. United States, 523 U.S. 296, 302 (1998). This is not a case where Plaintiffs contend that a procedure will, in all events violate the Constitution. (Nor would Plaintiffs have any hope of succeeding on such a facial challenge.) Rather, Plaintiffs contend that because of present circumstances, the witness requirement should be invalidated as applied. Because it is unknowable whether future circumstances will match present circumstances, the question is not ripe.
2. Plaintiffs Cannot Draft Their Way Around This Defect. Plaintiffs apparently propose to work around this ripeness problem with clever wordsmithing, suggesting that the proposed injunction apply “until such time as in-person
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interactions required by compliance with the witness requirement no longer pose a risk to public health and personal safety.” (Pls’ Mot. at 2.) This only exposes the problem; it is no solution.
For one thing, courts cannot draft around ripeness. If the injunction must (as Plaintiffs propose) hinge on contingencies, then that is itself powerful evidence that there is no live case or controversy. A ripeness defect goes to “injury in fact,” Clapper, 568 U.S. at 410 (emphasis added), and clever verbiage on paper is no cure. For example, an unripe challenge to racial discrimination that is not shown to be ongoing and imminent, see Rizzo v. Goode, 423 U.S. 362, 372 (1976), could not become ripe merely by writing an injunction that bars racial discrimination “if racial discrimination occurs.”
Another flaw in this approach is that the language renders the proposed order hopelessly vague and unworkable. Rule 65(d) requires that an injunction “state its terms specifically,” Fed. R. Civ. P. 65(d)(1)(B) (emphasis added), which means it must “be specific and reasonably detailed,” Pasadena City Bd. of Ed. v. Spangler, 427 U.S. 424, 439 (1976). That, in turn, serves the role of putting the parties bound on notice of what acts constitute “contempt.” See Int’l Longshoremen’s Ass’n, Local 1291 v. Philadelphia Marine Trade Ass’n, 389 U.S. 64, 76 (1967). For example, an injunction that states “only an abstract conclusion of law,” id. at 74, or “that merely enjoins a party to obey the law,” Louis W. Epstein Family P'ship v. Kmart Corp., 13 F.3d 762, 771 (3d Cir. 1994), fails this standard. See, e.g., Burton v. City of Belle Glade, 178 F.3d 1175, 1200 (11th Cir. 1999) (finding a proposed order
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that a city not discriminate in future annexation decisions incompatible with the Rule’s specificity requirement); Payne v. Travenol Labs., Inc., 565 F.2d 895, 898 (5th Cir. 1978) (finding an order forbidding discrimination in employment practices incompatible with the Rule’s specificity requirement).
Plaintiffs’ proposal that the injunction last until the witness requirement “no longer pose[s] a risk to public health and personal safety,” (Pls’ Mot. at 2,) fails under Rule 65(d). There is no way for Virginia officials to know what level of safety is sufficient to extinguish the proposed mandate. There is always some degree of danger of the type Plaintiffs purport to identify; interaction with a witness can, for example, spread the flu, which carries a small risk of death, or some other contagious disease. Plaintiffs have not provided a metric for acceptable “safety.” So when is this “safety” standard met? When the spread of COVID-19 slows? When a vaccine or other medial remedy emerges? When testing becomes more readily available? How readily available? When the death or new-infection rates fall substantially? How substantially is enough? None of these questions is answered or is answerable, and only by future litigation—i.e., a future lawsuit—could these issues be resolved.
In reality, this injunction is merely a restatement of Plaintiffs’ legal position that the Constitution forbids states from requiring voters “to choose between putting themselves and others in serious physical jeopardy and forfeiting their fundamental right to vote.” (Pls’ Br. at 28.) They want Virginia to follow the law (or, rather, their view of it), but that is not a reasonably specific injunctive mandate
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that can be enforced via contempt. The injunction cannot simply bar Virginia from enforcing election laws in abstract circumstances where doing so would be dangerous.
Yet another problem with this approach is that Plaintiffs demand this relief as a preliminary injunction; they do not move now for a permanent injunction. A preliminary injunction, however, “is preliminary to a hearing on the merits” and “does not involve a final determination on the merits,” Benson Hotel Corp. v. Woods, 168 F.2d 694, 696 (8th Cir. 1948), and therefore “remains in effect until a final judgment is rendered.” 11A Charles A. Wright, et al., Federal Practice & Procedure Civil § 2947 (3d ed.). This case will not be ongoing for all future elections; it is highly unlikely that it will be ongoing after the June election, after which point it will become moot and a challenge regarding future elections will not yet be ripe. Because the preliminary injunction will only be in effect during the pendency of this case, its terms must be restricted to that temporal duration.
b. Plaintiffs have failed to meet their evidentiary burden for an injunction against future elections.
Ripeness aside, Plaintiffs have not provided any evidence to support an injunction that extends beyond the June 2020 primary election. It is axiomatic that “injunctive relief against a state agency or official must be no broader than necessary to remedy the constitutional violation.” Toussaint v. McCarthy, 801 F.2d 1080, 1086 (9th Cir. 1986), abrogated in part on other grounds by Sandin v. Conner, 515 U.S. 472 (1995). See also Eaglemed LLC v. Cox, 868 F.3d 893, 905 (10th Cir. 2017). In this case, Plaintiffs say the constitutional deficiency flows from the
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immediate effects of the COVID-19 pandemic on Plaintiffs’ ability to vote absentee in the June 23, 2020 Primary Election. Plaintiffs do not mount a facial challenge to the absentee witness requirement itself, independent of COVID-19.
Application of the Anderson-Burdick balancing test requires the Court to weigh the burden on a voter’s fundamental right to vote against the state’s justification for the challenged statute. See Anderson v. Celebrezze, 460 U.S. at 780, 789 (1983) (requiring a court to “first consider the character and magnitude of the asserted injury to the rights ... the plaintiff seeks to vindicate,” then “identify and evaluate the precise interests put forward by the State as justifications for the burden imposed by its rule.”). Since the burden is caused by the virus, the prevailing public-health conditions must be examined for each election being challenged to weigh the “character and magnitude” of COVID-19-related burdens imposed on a voter’s right to vote in that election. Because public-health conditions around COVID-19 are fast-changing and unpredictable, it is impossible for the Court to conduct an Anderson-Burdick balancing test for an election several months or even a year into the future. Or stated more bluntly: a terrible blizzard may justify keeping the polls open later the night the blizzard occurs; it does not serve as a basis to permanently alter poll-hours for all future elections.
Any remedy the Court chooses to grant, therefore, should be confined to the June 23, 2020 Primary election. Plaintiffs have shown no likelihood of success on the merits of their claims as applied to future elections. They offer nothing more than sheer speculation, which is insufficient to strike down an election statute. See
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Washington State Grange v. Washington State Republican Party, 552 U.S. 442, 454 (2008). Indeed, the two voter-Plaintiffs, Ms. Goff and Ms. Toogood, do not even state in their declarations that they desire to vote in any election after June 23, 2020, and Ms. Wake’s declaration makes but a single inadmissible, hearsay reference to a voter who claims to “hope” to vote absentee in future elections. (Wake Decl. at ¶ 7(a).) These omissions place Plaintiffs’ standing to even raise a challenge to future elections in doubt. Granting Plaintiffs an indefinite injunction on all future elections violates the principle espoused in Toussaint that injunctions should be narrowly tailored to cure the constitutional violation.
Plaintiffs may argue that their requested injunction is not impermissibly indefinite because it would terminate once COVID-19 no longer posed a threat to their health or safety. But such a framework fails for lack of definiteness, as set forth in Section III(B)(1)(a)(2) above. It also impermissibly flips the presumption of constitutionality that Virginia’s absentee ballot statute enjoys, by rendering the statute unconstitutional until proven otherwise. It would also violate the AndersonBurdick framework because it would require the Defendants to prove, to lift the injunction against the witness statute, that COVID-19 no longer makes compliance “a risk to public health and personal safety.” (Pls’ Br. at 35.) Anderson-Burdick looks at not just the mere existence of a risk to health, but the magnitude of that risk.
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2. Plaintiffs have not demonstrated that COVID-19 has made compliance with Virginia’s absentee ballot witness requirement a severe burden on their right to vote.
Proposed Intervenors do not dispute that the right to vote is fundamental.
But nothing about Virginia’s absentee ballot witness statute offends that right.
The statute more than satisfies the Anderson-Burdick test.
In general, that test has been formulated as follows in this Circuit:
In short, election laws are usually, but not always, subject to ad hoc balancing. When facing any constitutional challenge to a state's election laws, a court must first determine whether protected rights are severely burdened. If so, strict scrutiny applies. If not, the court must balance the character and magnitude of the burdens imposed against the extent to which the regulations advance the state's interests in ensuring that “order, rather than chaos, is to accompany the democratic processes.” Storer v. Brown, 415 U.S. 724, 730 (1974). “The results of this evaluation will not be automatic; ... there is ‘no substitute for the hard judgments that must be made.’ ” Anderson, 460 U.S. at 789–90 (quoting Storer, 415 U.S. at 730). McLaughlin v. North Carolina Board of Elec., 65 F.3d 1215, 1221 (4th Cir. 1995).
As recognized in Fusaro v. Cogan, 930 F.3d 241 (4th Cir. 2019), a case
Plaintiffs cite, “if the challenged election law ‘imposes only ‘reasonable, non-
discriminatory restrictions’’ on First and Fourteenth Amendment rights, then ‘the
State’s important regulatory interests are generally sufficient to justify’ the
restrictions.” Id. at 257, quoting Burdick v. Takushi, 504 U.S. 428, 434 (1992). See
also Libertarian Party of Va. v. Alcorn, 826 F.3d 708, 717 (4th Cir. 2016) (holding
that statutes imposing only “modest” burdens are “usually justified by a state’s
important regulatory interests”).
Recently, Virginia’s voter-ID requirement – criticized for placing a burden on
voters to acquire and present a photo ID at the polls – was upheld as a permissible 27

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burden on the right to vote, justified by Virginia’s “important regulatory interests” in prevention of voter fraud and preservation of voter confidence in the integrity of elections. Lee v. Virginia State Board of Elections, 843 F.3d 592, 606-07 (4th Cir. 2016), quoting Crawford v. Marion County Election Bd., 553 U.S. 181 (2008). Lee vindicates the principle that modest, non-discriminatory burdens on voting rights, like Virginia’s absentee ballot witness statute, are justified and warranted as means to preserve election integrity and deter fraud.
Courts around the country have applied similar analysis to deny injunctions to bedrock election statutes on the grounds that COVID-19 renders their enforcement unconstitutional. See, e.g., Democratic National Committee v. Bostelmann, slip op. at 3, Nos. 20-1538, 20-1539, 20-1545, 20-1546 (7th Cir. Apr. 3, 2020) (staying district court opinion that enjoined enforcement of Wisconsin’s absentee signature requirement, finding district court gave “no effect to the state’s substantial interest in combating voter fraud”); Arizonans for Fair Elections v. Hobbs, No. CV-20-00658, -- F. Supp. 3d --, 2020 WL 1905747 (D. Ariz. Apr. 17, 2020) (finding that “the relief [plaintiffs] are seeking in this case is profound – the displacement of a bedrock component of Arizona law,” and declining to do so even in the midst of COVID-19); Reardon v. LaRose, No. 20CV-2105 (Franklin Co. C.P. Mar. 17, 2020) (unreported) (declining to issue TRO to enjoin Ohio’s primary election based on COVID-19 fears); Mays v. Thurston, No. 4:20-cv-341, 2020 WL 1531359, *2 (E.D. Ark. Mar. 30, 2020) (denying request for injunction expanding the time period for state election officials to receive absentee ballots due to COVID-19). See also
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Bethea v. Deal, No. CV216-140, 2016 WL 6123241, *2 (S.D. Ga. Oct. 19, 2016) (declining to extend voter-registration deadline in Georgia due to a hurricane).
As argued supra, Plaintiffs have not established, even for the June 23, 2020 Primary Election, that enforcement of the statute will impose any meaningful burden on their right to vote. Although Plaintiffs express concern about the risk of contracting COVID-19 simply by having their absentee ballots witnessed, they do not take into consideration the use of social-distancing measures to mitigate that risk. A witness need not stand within six feet of a voter. The act of witnessing does not require the voter to venture into a crowded public space and face a significant risk of COVID-19 exposure. (See supra Section II(D).) The voter and witness both can take basic precautions to avoid coronavirus infection for the brief period the witness needs to touch the ballot envelope to sign it. These are all the same types of precautions voters take when they collect their mail, buy groceries or products at a drug store, or get take-out from their local fast food drive-through.
Plaintiffs present no evidence that any material number of voters will be unable to vote due to this requirement; the Declaration of Stephanie Iles, an election official in Norfolk, only cited a single voter who attempted to cast an absentee ballot without a witness, claiming the voter could not get a witness due to COVID-19. (Iles Decl. ¶ 6.) But Virginia’s absentee witness requirement has been on the books for 70 years.
Plaintiffs cite a few cases from around the country where courts have granted COVID-19 related relief from election statutes. Faulkner v. Virginia Dep’t of
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Elections, No. CL 20-1546 (Va. Cir. Ct. Mar. 25, 2020) and Esshaki v. Whitmer, No. 2:20-cv-10831, 2020 WL 1910154 (E.D. Mich. Apr. 20, 2020) are distinguishable as those cases allowed plaintiffs to place petitions on the ballet with less than the normally required signatures due to COVID-19. The public health risk and difficulty associated with collecting enormous quantities of petition-signatures is a different question than the question presented here.
Finally, it is settled law that there is no constitutional right to an absentee ballot absent limited circumstances not present here. See McDonald v. Bd. of Election Comm’rs, 394 U.S. 802, 807 (1969) (declining to apply heightened scrutiny where it was only the claimed right to an absentee ballot, and not the franchise itself, at issue). Stated differently: citizens have the right to vote; they do not have a right to vote absentee. Virginia has not eliminated in-person voting at the polls for the June 23, 2020 Primary Election, and Plaintiffs remain free to vote at the polls. The Commonwealth has successfully conducted an election during a pandemic before (in 1918, during the Spanish Flu); and it did so without the level of absentee balloting or degree of mitigation measures available in 2020.
3. Virginia’s witness-signature requirement is long-standing and serves an important, compelling state interest in preserving the integrity of its elections.
Virginia has required that absentee ballots be witnessed, and that the witness sign the ballot envelope, since at least 1948. (See Section II(A), supra.) And Virginia is not alone; at least 10 other States require a witness signature. (Id.)
Plaintiffs concede that the absentee witness statute is a ballot-integrity measure. (Pls’ Br. at 27-29.) A “State indisputably has a compelling interest in
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preserving the integrity of its election process.” Eu v. San Francisco County Democratic Central Comm., 489 U.S. 214, 231 (1989), citing Rosario v. Rockefeller, 410 U.S. 752, 761 (1973). It is undisputed that the witness requirement serves to deter fraudulent absentee balloting activity. Deterrence of voter fraud and the promotion of public confidence in the integrity of a state’s elections have been recognized by both the Fourth Circuit and the Supreme Court as sufficiently weighty justifications to justify laws, like photo identification laws, that burden the right to vote. See, e.g,, Lee, 843 F.3d at 606-07; Crawford, 553 U.S. at 198-199 (plurality op.) See also Purcell v. Gonzalez, 549 U.S. 1, 4 (2006) (“Voter fraud drives honest citizens out of the democratic process and breeds distrust of our government”).
Plaintiffs argue the requirement is unnecessary, and that election integrity can be sufficiently served by requiring simply the voter’s name and address on he envelope, along with an attestation. (Pls’ Br. at 28.) But anyone could write in the voter’s name and address based on public records. The value in the witness requirement is that it provides a level of assurance that the voter cast the ballot, and provides some solemnity to the event of casting the ballot.
The General Assembly and the Governor recognize the value in the witness requirement. Governor Northam recently signed legislation that significantly reformed the requirements for absentee voting in Virginia. (See Pls’ Br. at 10.) Notably, while that legislation significantly reformed Virginia’s absentee ballot laws, the General Assembly chose to retain the witness requirement in full.
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The oversight provided by Virginia’s absentee ballot witness statute is more critical now than in past years, not less. Plaintiffs’ own evidence reveals signs that a great many voters may be casting ballots absentee in Virginia this year. Fraud pertaining to absentee ballots is a long-time, recognized problem, with a “ballot harvesting” scandal involving alleged absentee ballot fraud leading to the vacatur of a U.S. House race in North Carolina just last year. This risk of fraud, in turn, directly impacts the Proposed Intervenors’ right to vote. If persons are able to cast absentee ballots who are not authorized to do so, the effect is to dilute the votes of lawful voters, like Proposed Intervenors. Vote dilution is a violation of the fundamental right to vote. See Reynolds v. Sims, 377 U.S. 533, 554 (1964); Howell v. McAuliffe, 292 Va. 320, 335, 788 S.E.2d 706 (2016). Notably, when a Wisconsin district court enjoined that state’s absentee ballot witness statute, the Seventh Circuit stayed the injunction within days and, in doing so, specifically criticized the district court for giving “no effect to the state’s substantial interest in combating voter fraud.” Bostelmann, supra at 3.
The Court should deny the requested injunction. C. Plaintiffs Have Made No Showing That They Are Likely To
Suffer Irreparable Harm If They Are Required To Comply With The Witness-Signature Requirement For Absentee Ballots. Plaintiffs have also failed to show irreparable harm. Plaintiffs speculate they will not be able to vote, but speculation is insufficient to warrant the issuance of a preliminary injunction. See, e.g., Scotts Co. v. United Industries Corp., 315 F.3d 264, 283 (4th Cir. 2002) (requiring a plaintiff to make a “clear showing of irreparable harm” that “must be neither remote nor speculative, but actual and
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imminent”) (internal quotation omitted); Carcano v. McCrory, 203 F. Supp. 3d 615, 649 (M.D.N.C. 2016) (holding that “speculation about potential future industries is insufficient” to satisfy the irreparable harm prong). They fail to allege, much less to show, that they will be unable to find even one person to watch from afar as they vote and complete the witness requirement, and the notion that they cannot do so is facially untenable when they have managed to retain a whole team of lawyers to file this case on their behalf. Plaintiffs have, therefore, failed to make the requisite showing of irreparable injury.
D. The Public’s Interest In The Integrity Of Elections Outweighs Plaintiffs’ Speculative Claims Of Injury About Future Elections.
Finally, the public interest is not served by the issuance of the proposed injunction. While Plaintiffs accurately state that their right to vote is a fundamental matter, that is not the end of the analysis. Lecky v. Virginia State Board of Elec., 285 F. Supp. 3d 908, 921 (E.D. Va. 2018). To the contrary, the “functional structure embodied in the Constitution, the nature of the federal court system, and the limitations inherent in the concepts both of limited federal jurisdiction and of the remedy afforded by section 1983” must also be considered. Hutchinson v. Miller, 797 F.2d 1279, 1282 (4th Cir. 1986), quoting Gamza v. Aguirre, 619 F.2d 449, 452 (5th Cir. 1980). In our constitutional system, “the electoral process is to be largely controlled by the states and reviewed by the legislature,” with states retaining primary authority to regulate their own elections. Id. at 1283. The public interest is served by respecting state control over electoral processes, and not by striking down a bedrock, 70-year-old Virginia statute on the
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basis of the thin record before this Court, simply because the Nation finds itself in a crisis. See Hamdi v. Rumsfeld, 542 U.S. 507, 579 (Scalia and Stevens, JJ., dissenting) (observing that Cicero’s maxim, inter arma silent leges – that in times of war, the law falls silent – is a view that “has no place in the interpretation and application” of our Constitution).
E. Less Drastic Remedies Are Available For The June 23, 2020 Primary Than What Plaintiffs Demand.
Finally, although the Court should deny Plaintiffs’ motion for preliminary injunction for all the reasons set forth herein, Proposed Intervenors recognize the Court may grant some relief directed to the June 23, 2020 Primary Election over their objection. If the Court is so inclined, Proposed Intervenors wish to respectfully suggest a less drastic alternative to striking down the absentee witness requirement in its entirety.
The Voter Defendant Intervenors suggested Virginia’s E-Notary law. The Court could instead provide that, for those absentee voters who find themselves unable to comply with the absentee witness statute due to concerns about health and safety arising out of COVID-19, those voters instead write in the last four digits of their social security number on the ballot envelope. Although this alternate remedy does not provide a true substitute to the witness requirement, it would at least provide some minimal safeguard against absentee ballot fraud. Voters could easily comply with this requirement without risking their health or safety.
34

Case 6:20-cv-00024-NKM Document 44 Filed 04/28/20 Page 44 of 45 Pageid#: 505

IV. CONCLUSION

For the foregoing reasons, Proposed Intervenors respectfully request that the

Court deny Plaintiffs’ motion for preliminary injunction (ECF No. 16) in its entirety.

Dated:

April 28, 2020

Respectfully submitted,

/s/ Christopher M. Marston Christopher M. Marston (VSB No. 65703) chris@2562group.com 2652 Group LLC P.O. Box 26141 Alexandria, VA 22313-6141 571.482.6790 / Fax 703.997.2549
Trevor M. Stanley (VSB No. 77351) E. Mark Braden (pro hac vice pending) Katherine L. McKnight (adm. pending) Richard Raile (VSB No. 84340) BAKER & HOSTETLER LLP Washington Square, Suite 1100 1050 Connecticut Avenue, N.W. Washington, DC 20036-5403 202.861.1500 / Fax 202.861.1783 tstanley@bakerlaw.com mbraden@bakerlaw.com kmcknight@bakerlaw.com rraile@bakerlaw.com
Patrick T. Lewis (pro hac vice pending) BAKER & HOSTETLER LLP 127 Public Square, Suite 2000 Cleveland, OH 44114-1214 216.621.0200 / Fax 216.696.0740 plewis@bakerlaw.com
Counsel for Proposed Intervenors, Republican Party of Virginia, Inc., Mildred H. Scott, Vincent E. Falter, and Thomas N. Turner, Jr.

35

Case 6:20-cv-00024-NKM Document 44 Filed 04/28/20 Page 45 of 45 Pageid#: 506 CERTIFICATE OF SERVICE
I certify that on April 28, 2020, the foregoing was filed on the Court’s electronic case filing system. Notice of the filing was generated by the Court’s electronic system. Copies of the filing are available on that system.
/s/ Christopher M. Marston Christopher M. Marston (VSB No. 65703)
36

Case 6:20-cv-00024-NKM Document 44-1 Filed 04/28/20 Page 1 of 2 Pageid#: 507 EXHIBIT A

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA
LYNCHBURG DIVISION

LEAGUE OF WOMEN VOTERS OF VIRGINIA, et al.,
Plaintiffs,
v.
VIRGINIA STATE BOARD OF ELECTIONS, et al.,
Defendants.

Case No.: 6:20-cv-00024-NKM

DECLARATION OF MILDRED H. SCOTT My name is Mildred H. Scott. I am over the age of 18 and fully competent to make this declaration. I declare the following based upon my personal knowledge: 1. I am 91 years old and have been a registered voter in Virginia for over 40 years, having voted in virtually every state and federal election during that time. Voting and political participation are a core part of my values. 2. I currently live in Roanoke County, Virginia, in the 24179 zip code. I am registered to vote in Roanoke County and have resided and voted in this County for approximately 55 years. 3. I have served as an officer of election for Roanoke County for a number of elections. 4. I plan to vote in the Republican Primary to nominate a candidate for U.S. Senate on June 28, 2020, and to vote in November 3, 2020 General Election. 5. I am aware the U.S. Centers for Disease Control and Prevention have said that “older adults” are at a higher risk for COVID-19.

Case 6:20-cv-00024-NKM Document 44-1 Filed 04/28/20 Page 2 of 2 Pageid#: 508
6. I am aware of and have been following public health recommendations and orders from the Governor to stay at home except for necessary activities.
7. I consider voting to be a necessary activity and am aware that Alena Yarmosky, a spokeswoman for Governor Northam has said that his orders do not apply to the operation of government and that includes participating in elections.
8. Despite living alone, I am confident that I can find a witness to sign an absentee ballot security envelope so that I can participate in these elections. I have several friends who live close by and are willing to witness my signature following social distancing guidelines.
9. I do not believe that a requirement to have a witness sign an absentee ballot security envelope burdens my right to vote.
10. I am, however, concerned that what the Plaintiffs are asking for in this lawsuit might hurt my right to vote. Having served as an officer of election, I believe that election integrity safeguards like the witness signature requirement are vital to fair and honest elections. Removing those safeguards may allow votes to be cast by individuals who are not entitled to cast them, which would dilute my vote.
I declare under penalty of perjury that the foregoing is true and correct. Executed on April 27. 2020, at Roanoke County, Virginia.
_/s/ Mildred H. Scott_____________________ MILDRED H. SCOTT

Case
6:20-cv-00024-NKMDo
cumen t 44-2 Filed 04/28/20 Page 1 of 2 Pageid#: 1290

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA
LYNCHBURG DIVISION

LEAGUE OF WOMEN VOTERS OF VIRGINIA, et al.,
Plaintiffs,
v.
VIRGINIA STATE BOARD OF ELECTIONS, et al.,
Defendants.

Civil Action No.: 6:20-cv-00024-NKM

DECLARATION OF THOMAS N. TURNER, JR. My name is Thomas N. Turner, Jr. I am over the age of 18 and fully competent to make this declaration. I declare the following based upon my personal knowledge: 1. I am a 30-year-old Black man and have been a registered voter in Virginia for over 11 years, having voted in every state and federal election during that time. 2. I currently live in the City of Suffolk, Virginia, in the 23434 zip code in the Third Congressional District. I am registered to vote in City of Suffolk and have resided and voted in this City since 2012, prior to that time, I resided in and was registered to vote in the City of Lynchburg. 3. I currently serve as chairman of the Young Republican Federation of Virginia, engaging young voters, ages 18-40, in the political process, working to elect Republican candidates, and encouraging Federation members to serve as officers of election. 4. I plan to vote in the Republican Primary to nominate a candidate for U.S. Senate and U.S. House of Representatives on June 23, 2020, and to vote in November 3, 2020 General Election.

Case
6:20-cv-00024-NKMDo
cumen t 44-2 Filed 04/28/20 Page 2 of 2 Pageid#: 1291
5. I am aware of and have been following public health recommendations and orders from the Governor to stay at home except for necessary activities.
6. I work for the Circuit Court for the City of Suffolk and have been designated an essential employee, so necessary activities include work at the courthouse twice each week.
7. I consider voting to be a necessary activity and am aware that Governor Northam’s spokeswoman for said that voting in an election is allowed under his orders.
8. I have applied for an absentee ballot for the June 23, 2020 primary election and intend to have a colleague from work witness my ballot while observing social distancing and other public health recommendations.
9. I do not believe that a requirement to have a witness sign an absentee ballot security envelope burdens my right to vote.
10. I believe the witness signature requirement promotes the integrity of the vote and reassures me that I should have confidence in the results of the election.
I declare under penalty of perjury that the foregoing is true and correct. Executed on April __. 2020, at Suffolk, Virginia.

_________________________________________ THOMAS N. TURNER, JR.

 </s> Case 6:20-cv-00024-NKM Document 48 Filed 04/28/20 Page 1 of 13 Pageid#: 888

UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA
Lynchburg Division

LEAGUE OF WOMEN VOTERS OF VIRGINIA et al.,
Plaintiffs, v.
VIRGINIA STATE BOARD OF ELECTIONS et al.,
Defendants.

Case No. 6:20-cv-00024-NKM

BRIEF OF THE PUBLIC INTEREST LEGAL FOUNDATION AND LANDMARK LEGAL FOUNDATION AS AMICI CURIAE

Case 6:20-cv-00024-NKM Document 48 Filed 04/28/20 Page 2 of 13 Pageid#: 889
TABLE OF CONTENTS INTRODUCTION ...............................................................................................................1 ARGUMENT .......................................................................................................................2
I. PILF’s Voter Roll Research and Submission of Findings to the Virginia Department of Elections ......................................................................2
II. PILF Matched 11,600 Registrants to a Verifiable Record of Death ..................3 III. PILF Invites the Court to Appoint an Amicus Curiae to
Verify PILF’s Research .....................................................................................4 IV. Requiring a Witness Signature When Validating an Absentee Ballot
Does Not Amount to an Unconstitutional Burden .............................................5 A. Reasonable Limitations on the Voting Process Are
Not Unconstitutional ....................................................................................5 B. The Requirement Places a Minimal, But Necessary Burden on
Absentee Voters ...........................................................................................7 CONCLUSION ....................................................................................................................8
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TABLE OF AUTHORITIES
Cases
Anderson v. Celebrezze, 460 U.S. 780 (1983).................................................................................................... 5-6
Burdick v. Takushi, 504 U.S. 428 (1992).................................................................................................... 5-6
Crawford v. Marion Cty. Election Bd., 553 U.S. 181 (2008)........................................................................................................6
NE Ohio Coal. for Homeless v. Husted, 696 F.3d 580 (6th Cir. 2012) ..........................................................................................6
Norman v. Reed, 502 U.S. 279 (1991)........................................................................................................6
Timmons v. Twin Cities Area New Party, 520 U.S. 351 (1997)........................................................................................................6
Constitutions, Statutes, and Rules
Fed. R. Evid. 201(b)(2) ........................................................................................................5 Va. Code § 24.2-707(A).......................................................................................................1 Va. Code § 24.2-428.2(1) ..............................................................................................4 n.8 U.S. Const. art. I § 4, cl. 1....................................................................................................5 Other Authorities
https://www.elections.virginia.gov/candidatepac-info/client-services ..........................2 n.2 https://www.elections.virginia.gov/casting-a-ballot/absentee-voting/...........................3 n.5 https://www.elections.virginia.gov/media/formswarehouse/absentee-voting/applications/SBE701-Absentee-Ballot-Application-Rev7-17-long.pdf ....................................................3 n.6 Instructions, Virginia Absentee Ballot Application Form, https://www.elections.virginia.gov/media/formswarehouse/absentee-voting/applications/SBE701-Absentee-Ballot-Application-Rev7-17-long.pdf ....................................................4 n.8 Governor Northam Signs Sweeping New Laws to Expand Access to Voting, April 12, 2020, https://www.governor.virginia.gov/newsroom/all-releases/2020/april/headline856055-en.html ..............................................................................................................7 n.9 Report of the Commission on Federal Election Reform, Building Confidence in U.S. Elections, Sept. 2005, https://www.legislationline.org/download/id/1472/file/3b50795b2d0374cbe f5c 29766256.pdf ...............................................................................................................7 n.10
ii

Case 6:20-cv-00024-NKM Document 48 Filed 04/28/20 Page 4 of 13 Pageid#: 891 Steve Roberts Jr., Court docs: James City man indicted on voter fraud charges, The Morning Call, April 9, 2019, https://www.mcall.com/va-vg-richard-dohmen-indicted-0409story.html .......................................................................................................................1 n.1 Times Staff Writers, A ‘Modern’ Democracy That Can’t Count Votes, Los Angeles Times, December 11, 2000, https://www.latimes.com/archives/la-xpm-2000-dec-11-mn-64090story.html .......................................................................................................................3 n.7
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INTRODUCTION In 2018, according to reports and court documents, a James City, Virginia man submitted an absentee ballot application in the name of his deceased wife so that he could cast a second vote in the 2018 General Election.1 This failed attempt was presumably possible because the man’s wife remained registered to vote after her death. Research conducted by proposed amicus curiae Public Interest Legal Foundation (“PILF”) and attached to this brief indicates that such an occurrence is not rare. In fact, PILF’s research reveals thousands of active registrants in Virginia who are almost certainly deceased, according to verifiable death records. Plaintiffs ask this Court to invalidate Virginia’s requirement that absentee ballots be voted and signed in the presence of a witness. Va. Code § 24.2-707(A). That requirement is not “ineffectual,” as Plaintiffs claim. (Doc. 17 at 10.) Rather, it fosters trust in the absentee voting process and deters those who might attempt to cast a ballot in someone else’s name. Simply put, it is another layer of protection against absentee ballot fraud. If that layer is removed, as Plaintiffs desire, the James City man’s scheme will become more tempting and easier to accomplish. Attached to this brief is research submitted by PILF to the Virginia Department of Elections. PILF’s research reveals potential errors and inaccuracies on Virginia’s voter rolls. While election officials alone are the final judge of voter eligibility and are perfectly capable of replicating PILF’s research, PILF believes this Court should be aware of potential problems with the voter rolls that could be exploited under the absentee ballot system Plaintiffs seek.
1 Steve Roberts Jr., Court docs: James City man indicted on voter fraud charges, The Morning Call, April 9, 2019, https://www.mcall.com/va-vg-richard-dohmen-indicted-0409-story.html (last accessed April 28, 2020). Official court records can be found by using the Virginia Judiciary’s Online Case Information System 2.0 at https://eapps.courts.state.va.us/ocis/landing/false. The case numbers are CR19028447-00 and CR19028448-00.
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Additionally, Plaintiffs have not demonstrated their entitlement to preliminary injunctive relief under Supreme Court and Circuit precedent. Obligating an absentee voter to obtain a witness signature does not place an undue burden on the right to vote in violation of the First and Fourteenth Amendments. Rather, it helps protect the integrity of the absentee ballot voting process. Amici therefore respectfully urge the Court to deny Plaintiffs’ request for a preliminary injunction (Doc. 17) and deny the parties’ motion for consent judgment and decree (Doc. 35).
ARGUMENT I. PILF’s Voter Roll Research and Submission of Findings to the Virginia
Department of Elections. As part of its organizational mission, PILF analyzes voters rolls across the Nation to assess their health. In October 2019, PILF purchased a copy of Virginia’s statewide voter roll.2 Then, at considerable expense, using detailed methodologies and matching techniques (described infra and in the attached letter) PILF flagged registrations that are potentially inaccurate, outdated, or no longer valid. In Virginia, these registrations include the following: (1) registrations belonging to likely deceased individuals; (2) registrations apparently listing a commercial address as a residence; and, (3) persons apparently registered twice across state lines. On April 27, 2020, PILF sent a letter to the Virginia Department of Elections that describes PILF’s methodology and findings and asks the Department to investigate and take corrective action where necessary.3 Exhibit A (hereafter, the “Letter”). PILF also submitted unredacted spreadsheets containing the voter registration data described in the Letter. The portion of that data pertaining to potentially deceased registrants is attached as Exhibit B.
2 See https://www.elections.virginia.gov/candidatepac-info/client-services/ (last accessed April 28, 2020). 3 Election officials are the final judge of voter eligibility. PILF merely asks election officials to do what is permissible under state and federal law to investigate the leads PILF submits.
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II. PILF Matched 11,600 Registrants to a Verifiable Record of Death.
PILF’s research indicates that there are potentially 11,600 deceased individuals with an
active registration in Virginia. Letter at 1; Exhibit B. In a normal election, each of those
potentially deceased individuals presents an opportunity for confusion and even fraud. Surviving
spouses, relatives, or caretakers, may not—like the James City man—resist the temptation to request an absentee ballot in the name of the deceased,4 which can be done online5 and through the mail.6 In the election proposed by the Plaintiffs—where absentee ballots can be cast without
a witness—the temptation to cast an absentee ballot in the name of a deceased family member
may become even greater. Were someone to succeed in doing so, it would cancel out the legitimate vote of another Virginian.7
It is possible that surviving spouses and relatives may not need to even make a request to
receive an absentee ballot for a deceased registrant. Virginia’s absentee ballot application
explains, “You can apply to vote absentee as early as one year before the election. Ballots are
4 To request an absentee ballot, the applicant must provide the last four digits of the registrants Social Security number, among other personal information. See Application Form accessible at link in note 6. However, this is information surviving spouses and family members would know or could easily access. 5 https://www.elections.virginia.gov/casting-a-ballot/absentee-voting/ (last accessed April 28, 2020). 6 https://www.elections.virginia.gov/media/formswarehouse/absentee-voting/applications/SBE701-Absentee-Ballot-Application-Rev7-17-long.pdf (last accessed April 28, 2020). According to the Application Form, applicants can opt to have their ballots sent to them via email. 7 Those handling absentee ballots will sometimes try to match signatures on ballot envelopes with those on the voter rolls. While signature matching programs are admirable, they are often inefficient at detecting fraud. See Times Staff Writers, A ‘Modern’ Democracy That Can’t Count Votes, Los Angeles Times, December 11, 2000, https://www.latimes.com/archives/la-xpm-2000dec-11-mn-64090-story.html (last accessed April 24, 2020) (“‘I don’t have much faith in that process,” says Melody Rose, an assistant professor of political science at Portland State University. ‘I can forge my husband’s signature perfectly.’”).
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available 45 days before most elections.”8 Such a generous window for absentee ballot requests increases the likelihood that a registrant will apply to vote absentee, but later die prior to the election. If the registrant is not removed from the voter roll, an absentee ballot would likely be sent automatically to the applicant’s residence.
In order to ensure a high degree of confidence, PILF matched voter roll data against the federally maintained cummulative Social Security Death Index (SSDI), and where possible, against the SSDI and printed obituaries and other public notices. Letter at 2. Over 65 percent of registrants matched against the SSDI apparently died in September 2019 or earlier, with some dates of death reaching back decades. Letter at 2.
The true number of deceased registrants is likely even higher because PILF analyzed only registrants with active registrations. However, concerns about fraud remain even for deceased registrants with an inactive registration because all an inactive registrant (or someone pretending to be her) must do to return to active status is provide a current address. Va. Code § 24.2428.2(1). Unscrupulous actors could exploit such a scheme as well.
III. PILF Invites the Court to Appoint an Amicus Curiae to Verify PILF’s Research. PILF’s research can be replicated. PILF hopes that replication can resolve any doubts
concerning ambiguities in the data. PILF believes its data are correct but invites the Court to verify it. PILF welcomes efforts to verify and improve upon its work so that the Court is working with the most accurate and up-to-date data when rendering a decision in this matter. For example, PILF invites the Court to appoint its own amicus curiae to perform this function, if the
8 Instructions, Virginia Absentee Ballot Application Form, https://www.elections.virginia.gov/media/formswarehouse/absentee-voting/applications/SBE701-Absentee-Ballot-Application-Rev7-17-long.pdf (last accessed April 24, 2020) (emphasis added).
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Court believes it is warranted, and PILF is happy to work with any such designee to assist in cataloging the numbers of deceased registrants that could pose risks under the Plaintiffs’ requested absentee voting scheme.
If the Court does not appoint an amicus curiae, PILF requests that the Court take judicial notice of the attached findings that were derived from government records. Federal Rule of Evidence 201 allows the Court to take judicial notice of facts that “can be accurately and readily determined from sources whose accuracy cannot reasonably be questioned.” Fed. R. Evid. 201(b)(2). Given that the source of many of PILFs findings are government records (the SSDI and Virginia’s official voter roll), those findings “can be accurately and readily determined.” Id. Use of the Court’s judicial notice powers is therefore appropriate.
IV. Requiring a Witness Signature When Validating an Absentee Ballot Does Not Amount to an Unconstitutional Burden.
Virginia’s requirement that a voter completing an absentee ballot obtain a witness signature guards against fraud. Requiring verification of identity ensures a safe and honest election. It is a minimal burden that is especially necessary because of the increasing likelihood that large numbers of absentee ballots are expected to be cast in both the primary and the general elections. Plaintiffs’ arguments under the First and Fourteenth Amendments must therefore fail.
A. Reasonable Limitations on the Voting Process Are Not Unconstitutional. States regulate the time, place and manner of their elections. U.S. Const. art. I § 4, cl. 1. The right to vote in any way is not absolute. Burdick v. Takushi, 504 U.S. 428, 433 (1992). And to achieve the necessary objective of a fair, orderly and honest election, states enact comprehensive and sometimes complex election codes. These provisions affect—at least to some degree—the individual’s right to vote. Anderson v. Celebrezze, 460 U.S. 780, 788 (1983). Reasonable and nondiscriminatory restrictions are justifiable because of a state’s important
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regulatory interests in ensuring a fair and honest election. Id. Voting regulations, therefore, do not automatically trigger strict scrutiny—even when they affect the right to vote. Timmons v. Twin Cities Area New Party, 520 U.S. 351, 358 (1997).
Thus, courts must determine the burden the regulation places on voters when setting the standard of review. “While a rational basis standard applies to state regulations that do not burden the fundamental right to vote, strict scrutiny applies when a state’s restriction imposes ‘severe’ burdens.” NE Ohio Coal. for Homeless v. Husted, 696 F.3d 580, 592 (6th Cir. 2012). In less severe cases, courts apply the flexible Anderson-Burdick standard:
Under this test, A court considering a challenge to a state election law must weigh “the character and magnitude of the asserted injury to the rights protected by the First and Fourteenth Amendments that the plaintiff seeks to vindicate” against “the precise interests put forward by the State as justifications for the burden imposed by the rule,” taking into consideration “the extent to which those interests make it necessary to burden the plaintiff’s rights.” Burdick 504 U.S. at 434 (quoting Anderson, 460 U.S. at 789). There is thus no ‘litmus test’ to separate valid from invalid voting regulations. And courts must balance the burden placed on voters against the state’s asserted justifications and “make the ‘hard judgment’ that our adversary system demands.” Crawford v. Marion Cty. Election Bd., 553 U.S. 181, 190 (2008). Any burden should be “justified by relevant and legitimate state interests ‘sufficiently weighty to justify the limitation.’” Crawford, 553 U.S. at 191 (quoting Norman v. Reed, 502 U.S. 279, 288-289 (1991)). The absentee ballot witness requirement—by Plaintiffs’ own admission—does not trigger strict scrutiny. (Doc. 17 at 2.) Thus, the relevant and legitimate state interest of preventing absentee ballot fraud should be weighed against the burden of requiring a witness signature.
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B. The Requirement Places a Minimal, But Necessary Burden on Absentee Voters.
The Court should not circumvent the legislature and abolish a rule the Commonwealth considers necessary to the absentee ballot process. Recent actions by the Virginia legislature illuminate the importance the Commonwealth places on the witness signature requirement. During its most recent session, the legislature removed a traditional voter protection that had survived judicial review—the photo identification requirement for in-person voting. Governor Northam Signs Sweeping New Laws to Expand Access to Voting, April 12, 2020.9 The legislature also eliminated the requirement of needing an excuse for absentee mail voting. Id. Importantly, it did not remove the absentee ballot witness requirement. A reasonable conclusion can therefore be drawn that, even during a period where the Virginia legislature has abolished other voter protections, it continues to consider the witness signature requirement an important necessity in protecting the integrity of the voting process.
Second, requiring a witness signature reduces the chances for voter fraud. A comprehensive study, headed by former President Jimmy Carter and former Secretary of State James Baker concluded that “absentee ballot remains the largest source of potential voter fraud.” Report of the Commission on Federal Election Reform, Building Confidence in U.S. Elections, Sept. 2005.10 Absentee ballots are particularly vulnerable as they are unsecured and often mailed to the wrong person or address. The witness signature deters fraud by reducing the opportunities for vote buying and reduces the chances that a voter will be subject to undue pressure. In short, it
9 Available at https://www.governor.virginia.gov/newsroom/all-releases/2020/april/headline856055-en.html (last accessed April 26, 2020). 10 Available at https://www.legislationline.org/download/id/1472/file/3b50795b2d0374cbef5c29766256.pdf (last visited April 26, 2020).
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places another layer of protection and accountability into a process that is particularly vulnerable to fraud.
Finally, the Plaintiffs overstate the burden requiring a witness signature places on the voter. (Doc. 17 at 16.) They assert that living alone and having a witness sign an absentee ballot will automatically violate social distancing guidelines and expose them to transmission of COVID-19. (Doc. 17 at 9.) To them, it is a binary choice—either do not vote or unduly expose oneself to the virus. They make no allowance for commonsense practices that greatly reduce the chance of transmission.
It is possible to maintain social distance and still complete the witness signature requirement. Individuals can communicate and complete the absentee ballot while wearing protective face masks. A witness can be in the same room as the voter, maintain a distance of six feet and still observe the signature process. Voters and witnesses can also use different pens to complete and sign the ballot. Other basic sanitation procedures can further reduce the remote chance of transmission.
These burdens are minimal and necessary, despite Plaintiffs’ protestations. They are offset by the benefits of protecting the vulnerable absentee ballot process from fraud. As a result, the absentee witness requirement does not violate the Anderson-Burdick test.
CONCLUSION Inaccurate voter rolls create risks for the franchise. Those risks are heightened when safeguards—like Virginia’s witness requirement—are stripped away. For that reason, the research discussed herein merits consideration and further investigation by election officials and this Court alike. Moreover, the minimal burden of obtaining a witness signature does not rise to an unconstitutional level in light of the state’s important interest in deterring absentee ballot
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fraud. This Court should accordingly deny Plaintiffs’ request for a preliminary injunction and the parties’ motion for a consent judgment and decree.

Dated: April 28, 2020.
Respectfully submitted,
/s/ Graven W. Craig Graven W. Craig, Esq. (VSB 41367) CraigWilliams, PLC P.O. Box 68 202 W. Main Street Louisa, Virginia 23093 Phone: 540-967-9900 Fax: 540-967-3567 graven@callnow.law
J. Christian Adams** (Va. Bar #42543) Public Interest Legal Foundation 1555 King St., Ste. 200 Alexandria, VA 22314 (317) 203-5599 adams@publicinterestlegal.org ** Admission to Western District of Virginia forthcoming

Noel H. Johnson* Public Interest Legal Foundation 32 E. Washington Street, Ste. 1675 Indianapolis, IN 46204 (317) 203-5599 njohnson@publicinterestlegal.org
Michael J. O’Neill (Va. Bar # 45718)* Matthew C. Forys (Va. Bar # 65455)* Landmark Legal Foundation 19415 Deerfield Ave. Suite 312 Leesburg, VA 20176 (703) 554-6100 mike@landmarklegal.org matt@landmarklegal.org *Not admitted in Western District of Virginia Pro hac vice motions to be filed, if necessary

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Case 6:20-cv-00024-NKM Document 48-1 Filed 04/28/20 Page 1 of 3 Pageid#: 901

VIA EMAIL AND CERTIFIED MAIL

April 27, 2020

Virginia Department of Elections Washington Building 1100 Bank Street, First Floor Richmond, VA 23219

Re: Statutory Notice of Violation of National Voter Registration Act & Request for Meeting

Dear Commissioner Piper and Members Brink, Lecruise, and O’Bannon:

Based upon our findings outlined below, I write your offices pursuant to 52 U.S.C. § 205010(b) to notify you that the Commonwealth of Virginia is apparently not in compliance with the requirements of Section 8 of the National Voter Registration Act of 1993 (“NVRA”). This requires election officials to make a reasonable effort to maintain voter registration lists that are free of dead registrants and registrants who have moved to other jurisdictions, and to systematically remove the names of other ineligible registrants. 52 U.S.C. §§ 20507(a)(3), (4)(A)-(B), 20507(c)(2)(A)-(B).

Commissioner Piper is receiving this letter because, as Virginia’s chief election official, he is ultimately responsible under Commonwealth and federal law for maintaining accurate and current voter registration lists. Va. Code § 24.2-404.1. We believe the problems identified in this letter can be resolved quickly and amicably. We therefore request a meeting, via telephone or video, if necessary, with the Virginia Department of Elections to discuss our findings, identify why the violations are occurring, inspect supporting list maintenance records, and confirm how you plan to bring Virginia back into compliance with Commonwealth and federal law. We are hopeful that we may reach a curative plan so that we do not need to initiate litigation to cure these defects.

I. Evidence of Inadequate List Maintenance

1. Deceased Registrants

Our review of Virginia’s official registration list indicates your office is not making a reasonable effort to remove the names of deceased registrants, as required by the NVRA. 52 U.S.C. § 20507(a)(4)(A). Virginia has kept registrants has active long after the registrants have died. Virginia law also requires that the State Registrar of Vital Records and other official sources be used to make determinations of death prior to the cancellation of an affected registration record. Va. Code § 24.2-408; Va. Code §24.2-427. Using the Commonwealth’s official voter roll extract from October 2019, we matched the entire “active” registry against various data sources containing records of death, primarily the Social Security Death Index. Our comparison yielded a substantial number of strong matches showing that active registrants remain on your rolls after they die. The statewide roll contained at least 11,600 registrants who are matched against the
1

Exhibit A, Page 1

Case 6:20-cv-00024-NKM Document 48-1 Filed 04/28/20 Page 2 of 3 Pageid#: 902
SSDI or published obituaries with corresponding dates of death on file at various credit reporting bureaus, based on our point of purchase.
At least 65 percent of registrants matched against the SSDI apparently died in September 2019 or earlier, with some dates of death reaching back decades.
2. Apparent Use of Non-Residential Commercial Addresses for Voter Registration
Our research further identified more than 1,770 instances where registrations were established at addresses apparently not intended for single or multi-family residential use. As you know, the Virginia-printed voter registration application form asks the user to state “Residence address (May not be a P.O. Box).” Virginia law further explains that legal residency “requires both domicile and a place of abode. To establish domicile, a person must live in a particular locality with the intention to remain. A place of abode is the physical place where a person dwells.” § 24.2-101.
3. Persons Apparently Registered Twice Across State Lines with Concerning Overlapping Voter Credits from the 2018 General Election.
Finally, our research identified at least 592 examples where Virginia registrants (according to the October 2019 version of the official voter registration roll issued by ELECT) were apparently and simultaneously registered in another U.S. state. Further, face-value reviews of voter credit histories show cause for concern, given the apparently overlapping credits issued for the 2018 General Election. Virginia statute requires that voter registration lists and history files from other states be utilized for comparison to ultimately decide if a registrant has moved out of state. Va. Code § 24.2-404.4.
In sum, the highlighted registration files appeared to exist as interstate duplicates before the 2018 Election, were each assigned voting credits for the 2018 General Election, and remained on the rolls up to the point of purchase in October 2019. Potential matches of full names and dates of birth were filtered through commercial identity-validation services using Social Security data and more to process the resulting 592 examples. We have utilized multiple means to verify these duplicate registrations but ultimately only your office can conclusively determine whether or not these registrations are indeed duplications. They appear to be duplicate registrations based on a variety of data sources. You have procedures under state law to verify our work.
II. Notice of Violations and Curative Period
Given the nature of these findings, we are required to inform your office that this letter serves as your statutory notice pursuant to 52 U.S.C. § 20510(b) of violations of Section 8 of the NVRA, 52 U.S.C. § 20507. We do, however, believe these are best discussed directly and efficiently before any litigation or election contest complicates matters further.
Your office may face federal litigation if the violations are not cured with 90 days of your receipt of this letter. 52 U.S.C. § 20510(b)(2).
2
Exhibit A, Page 2

Case 6:20-cv-00024-NKM Document 48-1 Filed 04/28/20 Page 3 of 3 Pageid#: 903 III. Request for Meeting Our representatives are available to meet with you, via telephone or video, if needed, to discuss our research and a remedial plan. Please let us know which date(s) and time(s) you prefer. Should you need to contact the Foundation regarding this matter, please contact me at lchurchwell@publicinterestlegal.org. Thank you for your service. Sincerely,
Logan Churchwell Communications & Research Director Public Interest Legal Foundation lchurchwell@publicinterestlegal.org Enclosure Virginia ELECT Copy.xlsx
3 Exhibit A, Page 3

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 1 of 352 Pageid#: 904

voter_id

lname

919444140 A

901002120 A

256941471 A

225021104 A

4791782 A

203017411 A

809011993 A

312040843 A

808000222 A

227010766 A

363691661 A

304006355 A

918362416 A

24009637 A

229010453 A

918126102 A

708021313 A

23011754 A

920023340 A

409011565 A

805849094 A

608011358 A

402012931 A

505000243 A

508004463 A

919390939 A

107024474 A

427016966 A

703003282 A

907000855 A

209012256 A

703015441 A

917579722 A

fname ROBERT DORIS SAMIR ROBERT BRIANNE MARGARET BETTY RICHARD KENNETH ARTURO MARY PATRICIA ERIC RICHARD GERALDINE JOHN EDWARD CREED RICHARD IMOGENE MURIEL JOAN SARAH ALICE WILLIE JOHN DAVID JOSEPH JACK JAMES FRANKLIN EVELYN FLORENCE

dob 1924 1934 1949 1945 1979 1932 1938 1945 1928 1932 1929 1935 1955 1941 1947 1946 1940 1928 1932 1933 1927 1928 1940 1923 1946 1933 1946 1925 1947 1932 1932 1929 1933

date_registered 2002-12-10 2002-02-22 2019-04-03 1994-10-11 2012-05-04 1976-08-31 1966-10-08 1992-09-26 1961-06-05 1980-01-24 2017-06-14 1964-09-16 1998-10-05 1989-09-06 1999-09-23 1997-10-06 1962-01-04 1949-04-01 2004-11-18 2005-08-12 2008-10-02 1984-10-03 1964-09-19 1984-01-30 1974-02-04 2002-09-06 1992-09-22 2012-11-09 1981-09-09 1972-05-23 2005-10-11 1975-09-10 1996-11-06

ssdi_dod 2017-03-08
2019-10-31
2018-06-16 2018-12-12 2018-01-27 2017-12-20
2019-10-09 2019-10-26 2016-07-10 2019-08-16
2019-11-07 2018-12-18
2018-04-25 2019-10-09 2019-09-26 2020-01-19 2019-11-21 2019-10-18 2019-10-09 2019-08-29 2019-08-17 2019-08-08 2019-08-03 2019-06-02 2019-03-12 2018-12-15

obit_dod
2019-10-02
2019-01-28 2018-06-16 2018-12-12 2018-01-27 2017-12-20 2018-12-11 2019-10-07 2019-10-09 2019-10-26 2016-07-10
2019-09-27 2018-08-20 2019-11-07 2018-12-18 2018-12-03 2018-04-25 2019-10-09
2019-11-21 2019-10-18
2019-08-29 2019-08-17 2019-08-08
2019-06-02 2019-03-12 2018-12-15

Exhibit B, Page 1

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 2 of 352 Pageid#: 905

voter_id

lname

920036285 A

803020283 A

304041578 A

790801207 A

401004394 A

504002070 A

918889271 A

919989649 A

519027131 A

226020766 A

103027979 A

309018214 A

224019037 A

704015065 A

918182764 A

407016027 A

803001148 A

404000607 A

919185687 A

37715637 A

92102694 A

92209366 A

918787533 A

806015784 A

702014194 A

4007314 A

919574885 A

717013643 A

919875429 A

917751040 A

201009141 A

8419376 A

917430628 A

fname BRENDA JOHN ROBERT KATHLEEN RUTH ROY WILLIAM ONEDIA KENNETH MARJORIE SHERMAN JOHN PAMELA BOBBY JUDY JOHN MARGARET VICTOR MARIAN RICHARD CONSTANCE PHILIP TAMIRU JAMES HUBERT THOMAS BARRY TRAVIS NANCY THOMAS JUNE ALICE FLORENCIA

dob 1954 1940 1933 1946 1938 1931 1948 1926 1948 1947 1944 1930 1961 1936 1948 1935 1936 1943 1943 1928 1947 1923 1961 1936 1944 1933 1950 1974 1962 1947 1935 1930 1930

date_registered 2004-12-17 1988-10-04 1978-08-07 2008-12-04 1999-11-04 1955-08-20 2000-09-18 2004-08-25 1976-04-03 1988-10-07 2000-09-08 1991-09-12 1984-09-21 1959-09-28 1998-01-20 1977-10-08 1982-10-01 1968-10-01 2001-09-17 2017-07-19 2012-08-15 2012-08-14 2000-05-22 1972-02-11 1967-10-07 1992-10-03 2003-08-18 1992-08-10 2004-09-09 1997-01-02 1967-10-07 2016-10-12 1996-03-22

ssdi_dod 2018-11-11 2018-07-11 2018-02-21 2017-11-30 2001-03-07
2019-10-18 2018-12-20
2019-11-03 2019-10-30 2018-06-15 2018-03-13 2019-11-13 2018-02-16
2020-01-03 2019-09-23
2016-10-29 2019-02-06 2019-12-24 2019-12-09 2019-11-08 2019-10-28 2019-09-15 2019-06-20 2019-02-24 2018-01-26 2017-12-13 2018-12-21

obit_dod 2018-11-11 2018-07-11 2018-02-22
2019-10-31 2018-12-02 2018-03-25 2019-10-18 2018-12-20 2019-09-08 2019-11-03 2019-10-30
2018-03-13 2019-11-13 2018-02-16 2019-11-03
2019-09-22 2019-07-31 2016-10-29
2019-12-25
2019-11-08 2019-11-02 2019-09-15 2019-06-20 2019-02-24 2018-01-26

Exhibit B, Page 2

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 3 of 352 Pageid#: 906

voter_id

lname

918287735 A

228014211 A

221006578 A

382758292 A

519411482 A

917864599 A

301008469 A

918589123 A

920088209 A

918435941 A

352419221 A

97119409 A

405031429 A

293450379 A

919880574 A

613241724 A

918575027 A

503020731 A

601020252 A

918779966 A

919038881 A

605028492 A

918915414 A

503030125 A

403007530 A

704015067 A

920002663 A

221012808 A

706009315 A

406008266 A

826198416 A

750962634 A

919744454 A

fname ARMANDO PEGGY CAROLE EUDORA AURORA SORAYA BONNIE JAMES KAMBOOZIA AMINA AHMED BYUNG EDITH JOHN INEZ JOHN BILLY THEODORE JERRY TIMOTHY KATHERINE KAYE GENCY JACK LUCILLE DAVID LISA LATIFEH BRENDA PATRICK SHARON SUSAN BOBBY JOHN

dob 1953 1938 1940 1937 1925 1925 1945 1934 1937 1941 1929 1940 1946 1944 1920 1931 1940 1927 1945 1960 1927 1942 1948 1931 1935 1959 1934 1948 1960 1955 1948 1947 1950

date_registered 1998-06-23 1960-09-06 1986-03-18 2011-11-22 2008-11-17 1997-01-09 1970-10-02 1999-09-21 2005-04-20 1999-02-18 2010-08-09 2009-07-10 1968-08-29 2008-09-30 2004-09-11 2008-02-13 1999-09-02 1985-09-05 1976-03-11 2000-05-15 2001-02-12 1982-10-01 2002-08-14 1963-08-29 1988-01-21 1984-08-27 2004-10-04 1985-03-08 1992-09-04 1997-03-18 2007-02-05 2012-07-24 2004-05-05

ssdi_dod 2016-09-10
2018-12-13 2019-09-10 2018-01-20 2017-12-14 2020-01-12 2018-06-14 2019-02-19 2019-02-10 2018-12-26 2019-11-15 2013-10-15 2008-10-11 2019-11-14 2019-08-11 2019-12-04 2019-10-03 2018-12-26 2018-06-13 2020-01-28 2019-09-12 2019-09-03 2018-06-13 2017-07-29
2018-05-03 2019-11-24 2019-11-02 2018-12-22 2018-04-22 2019-05-25

obit_dod 2016-09-10 2018-12-15 2019-09-17
2017-12-14
2019-11-15 2013-10-14 2019-11-14 2019-08-11 2019-12-04 2019-10-03
2019-09-12 2019-09-03 2018-06-13 2019-07-23 2018-05-03 2019-11-24 2019-11-02
2019-05-25

Exhibit B, Page 3

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 4 of 352 Pageid#: 907

voter_id

lname

114993526 A

21009502 A

299301767 A

507015294 A

920380772 A

503030274 A

223001891 A

920217141 A

918276960 A

10004899 A

422029904 A

208026297 A

304050100 A

919102141 A

106017482 A

202029430 A

919110555 A

411369762 A

918120646 A

920017575 A

411022405 A

917414965 A

706014196 A

202016456 A

917093666 A

128001496 A

920145630 A

919451076 A

358012500 A

207014756 A

180374044 A

405017580 A

917858796 A

fname MITCHELL GRACE BENEDICTA PETER LOETTA OSCAR GARY DARRYL EDWARD JEROME JOHN ELIZABETH PETER ALLENBI KATHLEEN ROY SAMMY NUZHAT RANA JANIE CAROLYN GEORGE WILLIAM CHARLES SHARON ELIZABETH LEROY CLARICE BARBARA ROBERT ROY HERMAN GAIL

dob 1959 1971 1912 1932 1935 1933 1939 1965 1937 1938 1931 1929 1943 1936 1919 1932 1941 1949 1946 1939 1946 1928 1932 1937 1976 1917 1960 1945 1933 1939 1955 1942 1932

date_registered 2016-05-19 2003-03-04 2016-08-31 1984-09-08 2006-10-10 1975-07-12 2000-08-07 2005-11-22 1999-09-17 1976-09-18 2010-06-28 1992-02-21 1992-08-16 2001-05-03 1949-10-06 1992-09-30 2001-05-14 2015-09-21 1997-10-06 2004-11-12 1997-06-23 1996-02-29 1996-10-07 1999-03-11 1999-12-09 2003-10-06 2005-08-10 2002-12-19 2012-10-12 1990-10-06 2012-08-06 1999-02-10 1997-01-02

ssdi_dod 2019-10-24 2019-11-16 2019-09-28 2018-10-14 2018-05-14 2019-12-20 2019-10-19 2019-07-07 2018-12-20 2018-12-10
2019-10-14 2019-10-16 2018-10-22
2019-12-24 2020-01-06 2018-09-14
2019-12-27 2019-12-04 2019-12-04 2019-09-05 2019-08-21 2019-06-29 2019-06-21 2018-12-06 2018-11-24 2017-12-28 2017-11-25 2016-12-22 2016-11-01

obit_dod 2019-10-24 2019-11-16 2019-09-28
2019-10-19 2019-07-07 2018-12-20 2018-12-10 2019-09-20 2018-03-31 2019-10-14 2019-10-16
2018-09-09 2019-12-24
2019-11-09
2019-12-04 2019-12-04
2019-08-21 2019-06-29 2019-06-21 2018-12-06
2017-12-28
2016-11-01

Exhibit B, Page 4

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 5 of 352 Pageid#: 908

voter_id

lname

206024304 A

308014997 A

918492184 A

776887975 A

221004119 A

918394240 A

807018313 A

808014431 A

520789452 A

703004114 A

706014422 A

308020371 A

601024227 A

506018980 A

504004234 A

919263532 A

804000373 A

426329093 A

26199436 A

919951520 A

255690466 A

205019957 A

108019271 A

226019321 A

234016702 A

25003233 A

75233653 A

807003856 A

512027298 A

806016817 A

505013409 A

917005569 A

102001480 A

fname BERTHA STUART WILMA MARION FRANK MADELYNE RICHARD ELIZABETH JOYCE ANNIE FREDDIE FRANK EDITH LINDA ENNIS PAMELA JAMES ERNESTO STEPHEN JAMES TERESITA ROBERT AHMAD DORIS JUANITA LUCY RICHARD BOYD EVELYN GEORGE FLOYD RAFAT MARGARET

dob 1928 1937 1934 1939 1933 1930 1935 1929 1933 1937 1938 1938 1924 1941 1935 1942 1929 1939 1937 1938 1938 1933 1930 1926 1939 1931 1942 1934 1919 1934 1940 1938 1939

date_registered 1955-05-20 2003-08-07 1999-04-26 2012-09-08 1955-05-12 2006-06-21 1996-08-20 1976-05-05 2012-07-18 1977-10-07 1984-08-30 1984-08-20 1999-01-28 1968-10-04 1964-10-03 2002-01-22 1976-07-19 2016-09-08 2018-09-18 2004-10-04 2013-07-24 1976-10-02 1984-11-07 1983-02-05 1992-10-02 1988-02-06 2013-01-03 1998-11-04 1958-04-23 1978-03-25 1984-08-11 1993-07-31 1964-09-29

ssdi_dod 2015-05-14
2019-10-11 2018-10-21 2020-01-10 2017-12-28 2020-01-21 2019-12-18 2019-12-15
2018-11-26 2017-08-21 2019-08-09 2019-01-23 2019-08-01 2018-12-28 2019-08-10 2018-01-11 2019-12-05 2019-11-12 2019-10-07
2014-10-09 2019-12-03 2018-02-24 2017-04-21 2019-10-30

obit_dod 2015-05-14 2019-06-19 2017-12-14 2017-11-03 2016-04-24 2015-04-16 2016-03-29 2019-10-11 2018-10-21
2019-12-18 2019-12-15 2019-10-26 2018-11-26
2019-08-01
2019-08-10
2019-12-05 2019-11-12 2019-10-07 2018-12-19 2018-12-31
2018-02-24
2019-10-30

Exhibit B, Page 5

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 6 of 352 Pageid#: 909

voter_id

lname

2001714 A

901003997 A

201008472 A

40696967 A

708378077 A

208097182 A

575285767 A

306026004 A

103019273 A

606000511 A

918400920 A

920313816 A

202002962 A

114488673 A

304023495 A

918579182 A

919870958 A

607020672 A

53195334 A

918280967 A

109020202 A

919367739 A

1701842 A

306038197 A

608031825 A

917237877 A

919931053 A

673728236 A

101020203 A

807017014 A

806004533 A

917323959 A

908002123 A

fname FLORA RUBY MARTIN KEITH NUR HAMZA VINCENT FRANCIS HARRY FLORENCE DARLENE RONALD EARL PAMELA SAMUEL RONALD BIRGITTE EDNA MICHAEL ALLEN RUBY LYNNETTE CHARLES DWAYNE OZENA JAMES HELEN MICHAEL SHERMAN PATSY SARAH SCOTT JEROME

dob 1918 1927 1952 1938 1929 1996 1974 1949 1923 1928 1943 1951 1930 1961 1926 1943 1933 1920 1945 1938 1935 1938 1942 1927 1929 1955 1956 1943 1931 1924 1933 1971 1955

date_registered 1989-03-10 1964-07-16 1984-03-30 2018-10-15 2011-06-09 2015-10-13 2016-02-02 1979-04-25 1976-01-22 1963-05-01 2000-01-31 2006-06-14 1951-04-28 2017-02-15 1997-04-16 1999-09-10 2004-09-07 1956-04-27 2007-08-02 1998-06-11 1963-10-03 2002-07-31 2008-10-06 1985-04-15 1951-10-03 1995-02-03 2004-09-30 2008-01-07 1963-10-02 1976-02-19 1959-06-03 2003-11-14 1973-11-19

ssdi_dod
2018-12-06 2018-12-03 2019-12-11 2019-10-18 2018-05-11 2019-11-29
2019-12-09 2019-05-16 2017-02-21 2016-01-06
2019-09-16
2018-04-21 2019-01-05 2020-01-27 2020-01-01 2019-12-21 2019-12-02 2019-11-30 2019-11-21 2019-11-19 2019-11-11 2019-11-10 2019-11-02 2019-10-27 2019-10-25 2019-10-21 2019-09-24 2019-09-24 2019-09-13

obit_dod 2019-09-07
2018-12-03 2019-12-11
2019-11-29 2019-01-08
2019-05-16
2016-01-06 2019-08-27
2019-09-28 2018-04-21
2019-12-21
2019-11-21
2019-11-11 2019-11-10 2019-11-02
2019-10-21 2019-09-24 2019-09-24 2019-09-13

Exhibit B, Page 6

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 7 of 352 Pageid#: 910

voter_id

lname

807020388 A

917757133 A

49106703 A

126021029 A

110009665 A

918347018 A

918838734 A

207003595 A

223008967 A

710014424 A

378012059 A

950892059 A

8006355 A

126016216 A

541638296 A

919687997 A

918701057 A

917991289 A

122000006 A

920173154 A

204008095 A

2003454 A

707010382 A

29009351 A

6005570 A

407010797 A

226020771 A

25016692 A

29566575 A

209012645 A

301052541 A

110003844 A

602002221 A

fname FIELDEN PENIOR JUANITA DIANA LIDIA JEFFREY KATIE ANNIE KATHERINE ROSCOE JOSEPH CLIFTON EDWARD THADDEUS CUTHBERT CAREY PAULINE BARBARA OPAL MARIE STEPHEN GLENYS WALTER ADA MANGUS ERLE WILLIAM WILLIAM EILEEN GERLEAN ROBERT VIRGINIA JOHN

dob 1933 1934 1933 1936 1929 1952 1950 1948 1930 1954 1947 1933 1952 1956 1942 1971 1980 1927 1922 1928 1946 1923 1930 1931 1931 1925 1920 1924 1949 1935 1946 1932 1948

date_registered 1966-04-04 1996-10-07 2012-12-20 1993-05-03 1998-03-26 2000-01-27 2000-08-03 1983-08-22 1976-09-21 1992-03-30 2012-05-08 2008-09-04 1996-09-21 1985-06-20 2008-04-14 2004-02-11 2000-03-01 1997-04-22 1971-08-26 2005-09-23 1973-03-01 2004-10-04 1968-09-24 1988-08-19 1996-07-22 1946-06-15 1950-10-07 1976-09-29 2013-07-18 1980-09-03 2004-09-19 1990-09-28 1991-11-06

ssdi_dod 2019-09-08 2019-09-05 2019-08-06 2019-08-05 2019-07-15 2019-05-29 2018-12-04 2018-12-03 2018-12-02 2018-07-22 2018-04-25 2018-04-11 2018-02-20 2018-02-04 2018-01-26 2018-01-21 2018-01-17 2018-01-08 2017-11-26 2016-10-31 2016-09-14 2014-11-09

obit_dod 2019-09-08
2019-08-06 2019-08-05
2018-02-20 2018-02-04
2018-01-21
2017-11-26 2016-10-31 2016-09-14 2014-11-09 2019-11-07 2019-09-30 2019-09-23 2019-09-18 2019-09-17 2019-09-05 2019-08-23 2019-08-01 2018-06-16 2018-03-23 2018-02-28

Exhibit B, Page 7

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 8 of 352 Pageid#: 911

voter_id

lname

30005470 A

307018678 A

207018194 A

807014256 A

917510932 A

23002221 A

987439711 A

501024953 A

14006194 A

917674534 A

319807493 A

907019718 A

108005573 A

313029592 A

601003242 A

211017419 A

489013548 A

919376199 A

505011580 A

920401810 A

301002556 A

57754589 A

225018666 A

918093958 A

705006677 A

919561760 A

92578182 A

226003408 A

23008357 A

507024007 A

209004218 A

450737431 A

30309545 A

fname ODESSA BONITA BONNIE DAVID SARAH ELIZABETH MARY ELOISE ADELE MICHAEL GREALIE EDNA MICHAEL GERTRUDE KENNETH JACK BETTY EDOUARD THERESE NICKOLAS ANGELO MARCELA FRANK WILLIAM RUTH NOEL JULIA JACK NICHOLAS PHILIP FREDRICK JAIME LARRY

dob 1926 1944 1953 1933 1934 1928 1931 1933 1944 1976 1935 1942 1957 1923 1933 1931 1925 1932 1934 1978 1930 1936 1930 1933 1934 1939 1930 1929 1925 1925 1929 1939 1946

date_registered 1988-10-08 1992-10-01 2002-07-31 1967-05-29 1997-03-10 1952-06-11 2007-06-22 1955-12-13 1994-10-11 1999-08-27 2009-06-29 1964-10-02 1987-04-21 1992-08-19 1967-09-29 1978-10-07 2008-05-13 2002-08-16 1956-04-26 2006-11-20 1976-09-23 2011-03-04 1976-09-21 1997-09-17 1956-01-01 2003-07-24 2009-10-05 1979-03-30 1972-06-08 1996-06-12 1955-12-30 2009-12-10 2016-02-08

ssdi_dod
2005-05-01 2019-09-06 2020-01-28 2019-12-03 2019-11-01 2018-07-20 2018-05-07 2018-03-24 2018-01-30 2018-01-19 2017-06-05 2016-07-12 2014-03-19
2018-01-04 2019-09-13 2014-02-22
2018-09-03 2018-12-17
2019-04-21 2019-11-27 2019-08-23 2019-11-02 2019-09-13 2019-10-07 2019-10-07 2018-07-31 2019-11-01

obit_dod 2018-01-29
2019-09-09
2019-12-03 2019-11-01
2018-05-07
2018-01-30 2018-01-19 2017-06-05 2016-07-12 2014-03-19 2019-11-05 2019-09-11 2017-11-01
2015-10-22
2018-12-17 2015-08-04 2019-04-21 2019-11-27 2019-08-23 2019-11-02 2019-09-13 2019-10-07 2019-10-07
2019-11-01

Exhibit B, Page 8

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 9 of 352 Pageid#: 912

voter_id

lname

904005186 A

805018187 A

101004451 A

104011140 A

919299185 A

67151928 A

103030962 A

510005502 A

573716561 A

683618765 A

919153833 A

22020071 A

404022071 A

156973056 A

869819601 A

711016527 A

919050861 A

805008466 A

224018667 A

127007634 A

920279441 A

95091993 A

602021842 A

107004452 A

919004427 A

47136227 A

349832672 A

917982470 A

402007099 A

208001995 A

278971430 A

917441983 A

129008659 A

fname RICHARD PEARL HELEN CAITLYN ARISTOTLE ROSEMARY ARNOLD JOAN CECILIO JON ROMA JUDITH NOKOMIA MARGARET KAYLEIGH ROBERT BONNIE WILLIAM ALICE OPRA ROBERT FOROOGHAFAGH EDWARD KENNETH ANNA FAIZA MILDRED SABIN ROY MARY KENT GWENDOLYN BRENDA

dob 1930 1921 1958 1949 1944 1921 1931 1934 1947 1969 1933 1942 1946 1929 1988 1924 1923 1946 1928 1938 1946 1927 1933 1931 1926 1977 1929 1978 1935 1924 1949 1958 1951

date_registered 1976-10-03 1975-12-09 1996-11-15 1994-08-16 2002-03-29 2007-04-05 1992-04-30 1990-11-14 2008-09-29 2008-04-18 2001-08-03 2004-05-05 1983-10-08 2016-01-28 2007-03-08 1953-04-22 2001-03-01 1972-09-19 1979-07-09 1976-09-25 2006-03-30 2012-10-15 1996-05-13 2001-04-18 2000-12-13 2016-09-14 2012-10-11 1997-11-25 1975-10-04 2004-02-11 2016-10-06 2002-02-09 1996-10-07

ssdi_dod 2015-11-24 2019-10-14 2019-04-29 2018-07-28 2019-10-23 2019-11-25 2019-12-30 2019-12-13 2015-01-31 2018-11-24 2018-12-15
2019-11-15 2019-11-03 2019-06-20 2018-04-14 2017-11-27 2019-09-09 2019-09-30 2019-09-16 2019-09-20 2019-08-12 2019-08-01 2019-10-08
2018-02-11 2019-11-13 2019-03-03 2019-10-18 2019-11-18 2017-07-09 2014-07-03 2017-12-14

obit_dod 2015-11-24 2019-10-14
2018-07-28
2019-11-25
2013-09-29 2019-11-15 2019-11-01 2019-06-20 2018-04-14 2017-11-27 2019-09-09 2019-09-30 2019-09-16
2019-10-08 2018-12-14
2019-11-12
2019-10-18 2019-11-18 2017-07-09 2014-07-03

Exhibit B, Page 9

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 10 of 352 Pageid#: 913

voter_id

lname

909000862 A

26010182 A

74474837 A

222000240 A

306004420 A

808001153 A

703026916 A

919361804 A

918049185 A

305052464 A

608013323 A

341556606 A

716641728 A

32468473 A

603029121 A

3003455 A

105005795 A

225012108 A

103005707 A

919265711 A

604020974 A

204025553 A

305049572 A

35551249 A

918980131 A

610029121 A

221011855 A

25007509 A

194401548 A

402025780 A

806018999 A

106021798 A

920060447 A

fname DOROTHY HELEN LAWRENCE LINDA PHILIP GOLDIE DOROTHY KINGSLAND JOSEPH EARLENE PHYLLIS JOGINDER IGNACIO GERALDINE CARSON MARY JAMES DANIEL NANCY CLEVELAND DONALD EMIL HAROLD MAX CYNTHIA CAROL LOLITA HOMER TESFAYE KAYE THOMAS VAUGHN WILLIAM

dob 1943 1945 1929 1948 1934 1926 1934 1914 1936 1936 1942 1950 1990 1937 1927 1932 1927 1932 1925 1942 1940 1929 1947 1932 1947 1937 1933 1928 1953 1957 1947 1933 1938

date_registered 1980-04-04 1984-10-06 2017-01-17 1973-10-06 1972-09-22 1964-09-29 1992-02-20 2002-07-17 1997-07-08 1994-03-03 2005-01-29 2010-12-02 2008-09-19 2018-08-22 1951-05-28 2012-11-19 1952-06-14 1963-05-11 1947-05-03 2002-01-31 1981-09-01 1950-09-26 1997-06-19 2012-09-12 2000-11-13 1992-10-01 1980-04-01 1980-02-13 2008-10-04 1992-10-03 1998-06-30 1960-10-08 2005-02-22

ssdi_dod 2013-10-28 2020-01-10 2019-10-21 2019-08-18 2019-09-11 2019-06-26 2018-12-07 2011-04-17
2018-09-09 2014-02-03
2019-12-21 2019-11-25 2017-09-23
2017-02-25
2019-10-15 2020-01-23
2018-12-05
2019-08-31 2020-01-15 2019-09-03 2015-11-21 2018-06-19 2019-08-16 2019-10-10

obit_dod 2013-10-28
2019-10-21 2019-08-18 2019-09-11
2017-02-27 2014-06-07 2019-10-07
2014-02-03 2019-10-26
2019-11-25 2017-09-23 2018-12-03 2017-02-25 2019-09-02
2018-09-15
2019-01-16 2019-08-31
2019-09-03 2015-11-21
2019-08-16 2019-10-10 2019-08-21

Exhibit B, Page 10

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 11 of 352 Pageid#: 914

voter_id

lname

907015260 A

905004623 A

601006467 A

28017804 A

26005197 A

603000386 A

917120647 A

302025803 A

206009928 A

720898925 A

711001245 A

201009538 A

704894329 A

917044750 A

707888519 A

516015028 A

701003677 A

207019257 A

918542101 A

402018889 A

917329401 A

502008200 A

306000554 A

501011783 A

288357555 A

210010422 A

920021741 A

608012779 A

905009801 A

224023598 A

513008808 A

504007254 A

918072263 A

fname JEAN HARRIETTA PATSY ALBERT EMMA THOMAS ANNA DAISY MARION RANDELL DORIS I PAMALIA RONNIE JERRY EVERETT JESSE DONALD VIRGINIA LEOLA VIRGINIA DOROTHY RODERICK JOHN CYNTHIA KENNETH JANINE VIVIAN THOMAS RONALD BRUCE PATRICIA ADRIENNE

dob 1934 1931 1938 1952 1937 1943 1948 1923 1928 1956 1969 1920 1948 1945 1959 1927 1958 1947 1925 1925 1937 1918 1925 1930 1957 1941 1935 1923 1933 1939 1951 1922 1934

date_registered 1964-03-12 1964-10-01 1972-10-06 1988-03-26 1961-03-02 1972-09-29 1994-05-14 1980-10-01 1955-06-11 2008-10-06 1990-11-07 1968-10-05 2009-05-11 1993-10-04 2009-05-11 1995-10-10 1977-01-20 1976-10-01 1999-07-16 1968-05-15 1995-09-19 1960-10-05 1952-05-03 2002-03-05 2008-10-06 1980-09-27 2004-11-03 1986-03-21 1961-11-29 1998-05-28 2000-10-10 1998-11-13 1997-08-20

ssdi_dod 2020-01-06
2014-02-22 2019-10-30 2018-12-29
2019-09-15
2019-11-24 2019-09-19 2019-09-13 2019-02-12 2018-12-18 2018-11-02 2018-02-28 2017-07-03 2016-04-12
2019-11-21 2019-09-04 2018-10-28 2018-03-18 2017-11-07 2019-02-27 2020-01-11 2019-08-15 2018-12-18 2019-06-17 2018-01-11 2018-12-11

obit_dod
2019-09-22
2019-10-30 2018-12-29 2018-07-04 2019-09-15 2019-03-11 2019-11-24 2019-09-19
2019-02-12 2018-12-18 2019-11-01 2018-02-28
2016-04-12 2019-10-27 2019-09-23 2019-08-11 2018-12-25 2019-11-21 2019-09-04
2019-08-15
2019-06-17

Exhibit B, Page 11

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 12 of 352 Pageid#: 915

voter_id

lname

602002738 A

602004575 A

25006587 A

504001187 A

84669689 A

707015068 A

917603005 A

608026081 A

207003349 A

917282696 A

906022493 A

920419611 A

698801366 A

306041115 A

918166928 A

801002471 A

205007457 A

920402071 A

164555193 A

705027111 A

311037244 A

208003597 A

708021845 A

920130140 A

603028054 B

919148747 B

701024775 B

901002778 B

920263421 B

917610003 B

169071841 B

21004962 B

505009387 B

fname ROBERT JOHN MARY JOHN PAMELA BILLY FLORIENE TEDDY REBECCA MARY JAMES CONNIE JANET BILQUIS ANA MARGARET-ANN WILMA KAREN KENNETH GEORGE DAN DAVID LARRY NAWAL PAUL THERESA PAULINE MARZENIA JUDITH MARY GAGE GEORGE JAMES

dob 1946 1935 1936 1939 1953 1919 1921 1955 1951 1939 1925 1948 1945 1938 1928 1944 1935 1959 1943 1938 1952 1936 1941 1940 1939 1963 1935 1932 1945 1952 1998 1924 1927

date_registered 1976-10-01 1972-09-22 1960-10-04 1979-09-28 2013-10-11 1942-09-16 1996-08-15 2003-06-20 1982-10-02 2006-12-18 1956-09-17 2006-12-12 2015-06-10 1991-02-21 1997-12-24 1999-11-03 1958-09-22 2006-11-17 2007-09-18 1996-11-25 1997-05-12 1968-12-09 1996-11-30 2005-07-08 1976-07-02 2004-11-02 1968-01-18 1956-05-04 2006-03-13 1999-09-22 2017-02-28 1946-05-07 1951-04-03

ssdi_dod 2020-01-29 2019-12-13 2019-12-12 2019-12-05 2019-10-16 2019-09-04 2019-01-27 2018-12-28 2018-12-28 2018-10-29 2018-12-22 2019-09-07 2018-07-13 2017-02-05 2019-12-23 2019-12-10 2018-12-05 2018-03-04 2017-12-17
2017-04-29 2019-10-22
2018-12-19 2018-12-20 2018-12-08
2019-11-04
2017-12-12 2019-07-05 2019-12-03 2018-11-30

obit_dod
2019-12-13
2019-12-05
2019-09-04 2019-01-27 2018-12-28
2018-10-29
2019-09-07 2018-07-13
2019-12-23 2019-12-10 2018-12-05
2017-12-17 2019-10-05
2019-10-22 2019-09-27
2018-12-20 2018-12-08 2019-08-01 2019-11-04 2019-09-21
2019-07-05 2019-12-03 2018-11-30

Exhibit B, Page 12

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 13 of 352 Pageid#: 916

voter_id

lname

462803147 B

112022952 B

158204918 B

337905371 B

214004354 B

917993986 B

919176562 B

919108875 B

221013284 B

809004537 B

305028926 B

920392763 B

19802870 B

802022769 B

917659184 B

223003319 B

404028477 B

24005910 B

918075596 B

519025008 B

917879026 B

909004626 B

603027454 B

308028832 B

304037246 B

918928843 B

917058920 B

109010443 B

919938264 B

918707942 B

108006165 B

209000072 B

311038516 B

fname DAN HELEN ROBIN SEYMOUR KATHRYN ROBERT MICHAEL BOZY CHARLOTTE KLAUS EMAMODDIN MICHAEL MARTHA ROSE CHRIS PAUL ANNE SHIRLEY JOSHUA PRINCESS BARBARA VIOLET LOIS MARION MARGUERITE EDDIE JOHN HARRY THOMAS CAROL SUSAN A SARA

dob 1936 1928 1966 1942 1952 1925 1936 1948 1920 1952 1927 1942 1933 1940 1962 1936 1924 1936 1938 1951 1934 1922 1934 1927 1940 1937 1939 1929 1946 1960 1951 1927 1943

date_registered 2017-03-28 1993-06-03 2012-10-15 2017-07-11 1989-06-29 1997-05-08 2001-09-05 2001-05-14 1983-10-08 1989-09-26 1987-06-23 2006-11-09 2012-10-10 1999-04-05 1996-09-03 1964-09-10 1996-09-20 1968-10-04 2000-05-03 1992-03-28 1997-01-27 1975-08-14 1978-11-01 1960-10-08 1981-10-03 2000-10-06 2006-05-15 1992-09-22 2004-09-30 2000-03-06 1976-03-01 1945-03-01 1996-09-24

ssdi_dod
2019-09-24 2018-01-14 2018-11-01 2018-07-08
2019-09-17 2018-08-31 2019-12-21 2019-06-18 2019-10-24 2017-08-31 2019-12-04 2019-12-11 2019-11-27 2019-10-09 2019-09-05 2019-08-25 2018-03-30 2018-03-13 2018-01-11 2017-09-29 2017-09-08 2016-10-01 2015-03-23 1998-12-03
2014-11-02 2018-05-18 2015-11-28

obit_dod 2018-12-23 2019-09-24 2018-01-14 2018-11-01 2018-07-08 2019-04-08
2018-08-31 2019-12-21 2019-06-18
2019-12-04 2019-12-11 2019-11-27 2019-10-09 2019-09-05 2019-08-25
2018-03-13 2018-01-11 2017-09-29
2016-10-01 2015-03-23
2019-07-07 2017-03-31 2016-10-27 2014-11-02 2018-05-18
2019-06-09

Exhibit B, Page 13

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 14 of 352 Pageid#: 917

voter_id

lname

914002281 B

207004602 B

901004007 B

89180095 B

32827499 B

919771052 B

304014061 B

708014718 B

156140623 B

919636489 B

909021776 B

28001340 B

608007926 B

47270683 B

917053598 B

363005324 B

917589902 B

917692164 B

704012880 B

701014720 B

784102242 B

664353941 B

906019725 B

301018226 B

704013427 B

919114091 B

703015457 B

569760036 B

123013663 B

917214388 B

603003477 B

12004904 B

810012263 B

fname MURIEL THURMOND PEDRO ALBERT CHARLOTTE BARBARA ELENA BETTY MARALYN LINDA ROBERT NATHANIEL RUTH VIOLET KIM LORIE VIVIAN GILBERT THOMAS SUE STEPHANIE GEORGE GEORGE MARIE MARVIN MARY JAMES JOHN WARREN BEATRICE BOBBY ROBERT VIRGINIA

dob 1932 1948 1955 1926 1932 1929 1926 1938 1938 1954 1945 1931 1932 1929 1963 1965 1945 1950 1941 1951 1973 1957 1947 1929 1948 1917 1923 1958 1925 1910 1940 1936 1945

date_registered 1991-10-04 1983-10-08 1992-10-02 2017-05-22 2010-07-27 2004-06-01 1964-09-19 1972-10-07 2016-06-17 2003-11-21 1984-05-02 1968-05-10 2004-04-02 2014-03-27 2006-02-01 2016-03-09 1996-08-12 1996-09-26 1963-01-01 1987-09-29 2009-05-11 2008-01-14 2008-10-06 1987-09-12 1970-08-29 2001-06-13 1985-10-02 2008-11-20 1947-04-21 1994-10-11 1992-07-09 2000-09-13 2004-08-21

ssdi_dod 2019-09-13
2018-07-28 2019-11-13 2018-12-24 2020-01-08 2019-12-05 2019-11-24 2019-11-24 2019-09-10 2019-08-20 2019-08-17 2019-08-15 2019-08-11 2019-08-10 2019-03-21 2019-03-20 2019-03-06 2018-12-28 2018-09-26 2018-07-13 2018-05-06 2018-03-26 2018-02-27 2018-02-13 2018-01-21 2017-10-29 2017-07-28 2014-03-14 2000-02-04

obit_dod 2019-08-09 2019-11-13 2018-12-24
2019-11-24 2019-11-24 2019-09-10
2019-08-11 2019-08-10
2018-12-29 2018-09-26 2018-07-13 2018-05-06 2018-03-26 2018-02-27
2017-07-28
2019-09-23 2019-08-08 2019-06-09

Exhibit B, Page 14

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 15 of 352 Pageid#: 918

voter_id

lname

601010110 B

308019143 B

380135963 B

206669788 B

919885037 B

123017923 B

207015073 B

232015611 B

222014992 B

304020749 B

918126677 B

204027064 B

920015861 B

918595377 B

702029592 B

804005293 B

402007917 B

917039976 B

302017805 B

345118162 B

919549943 B

47830632 B

307033707 B

408010078 B

23004123 B

910141901 B

901000322 B

917991295 B

203008610 B

27000541 B

917204422 B

215151399 B

802019915 B

fname JANET E GLEN ASGHARAGHA SHANTARAM WILLIAM ANNE CLARENCE SUSAN EDGAR CAROLE CHARLES WILLIAM KATHY ELMER MARIO BETTY RACHEL AUDREY THOMAS VIRGINIA GARY THEODORE VERA HARVEY LINDA SHANNON SOLIL HASSAN ALPHA MARSHALL ARLINGTON JOHNNIE ALICE

dob 1937 1921 1930 1930 1939 1936 1940 1948 1946 1925 1961 1924 1957 1934 1946 1932 1920 1927 1946 1927 1953 1944 1941 1926 1942 1944 1933 1946 1925 1950 1938 1959 1933

date_registered 2003-08-11 1946-08-06 2008-02-27 2012-10-15 2004-09-14 1967-04-11 1992-10-03 1992-04-01 1973-10-04 1978-06-15 1997-10-06 1951-04-28 2004-11-09 1999-09-27 1992-04-22 1968-08-22 1955-05-06 1993-10-01 1997-09-15 2014-10-10 2003-07-03 2012-07-26 1964-10-01 1972-06-07 1972-10-03 2019-03-05 1983-02-24 1999-12-28 1947-09-12 1996-09-30 1994-10-08 2008-09-16 1988-03-26

ssdi_dod
2017-12-06 2018-03-26 2019-11-05 2019-08-03 2019-12-24 2019-11-24
2019-11-18 2019-09-23 2018-12-16
2019-08-01 2017-09-24 2018-12-15 2017-04-06 2019-10-21 2018-05-19 2019-11-09 2019-11-05 2018-12-08
2020-01-18 2019-09-19 2018-02-06 2019-10-21 2019-10-31 2019-10-10 2019-09-19 2018-12-01 2014-10-12

obit_dod 2017-12-23 2014-12-17 2017-12-06
2019-08-03
2019-11-24 2019-09-13 2018-02-26 2019-11-18
2019-07-10
2017-09-24 2018-12-15 2017-04-06 2019-10-15
2019-11-09
2018-12-08 2015-02-26
2019-10-31 2019-10-10 2019-09-19 2018-12-01 2014-10-12

Exhibit B, Page 15

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 16 of 352 Pageid#: 919

voter_id

lname

901004629 B

204026552 B

917544549 B

204022865 B

918116926 B

123009691 B

12004482 B

309021613 B

437800 B

307006372 B

919879567 B

708017808 B

917031707 B

502007937 B

810009312 B

919669832 B

58267137 B

368264622 B

301019447 B

918604878 B

101019956 B

246098192 B

917130321 B

919916797 B

565294620 B

707011096 B

217838727 B

21019066 B

917772072 B

919440079 B

907017019 B

243744085 B

608032421 B

fname JOSEPH THOMAS FRANCIS CHARLES OSCAR CAROLYN MERCEINE ANNA JOHN ISABEL MEI GEORGE ESTELLE WILLIAM WILLARD WILLIAM CHARLES FRANCES JACOB LONNIE WILFRED JAMES HERNANE FRANCES EDWARD WILLIAM OLIVER JERALD EDDIE BARBARA JUNE RAHIM BLANCHE

dob 1927 1934 1932 1943 1931 1940 1937 1929 1951 1934 1945 1930 1943 1942 1954 1947 1941 1949 1925 1933 1932 1948 1943 1917 1939 1929 1957 1920 1930 1944 1923 1959 1925

date_registered 1959-10-03 1987-10-03 1996-07-06 1978-03-11 1997-10-06 1980-09-10 2009-09-29 1989-08-17 2012-06-25 1976-09-15 2004-09-09 1983-04-15 1993-09-24 1966-06-09 1993-05-11 2005-11-28 2015-12-01 2013-08-14 1956-04-17 1999-10-04 1964-10-01 2015-01-29 1994-07-04 2004-09-27 2010-09-09 1968-04-27 2012-11-30 1950-11-06 1996-10-07 2002-11-30 1984-10-06 2010-10-04 1968-08-01

ssdi_dod
2018-01-25 2020-01-15 2019-10-14 2019-09-28 2018-12-19 2019-10-30
2018-03-15 2019-09-10 2020-01-15 2019-11-30 2019-02-06 2018-12-29 2018-12-26 2018-12-26 2018-12-20 2016-10-29 2013-12-04
2019-09-26 2018-01-10
2019-03-30 2019-08-14 1999-02-11 2019-02-23
2018-01-21 2019-12-01

obit_dod 2018-12-18 2018-01-25
2019-10-14 2019-09-28 2018-12-19
2016-08-01 2018-03-15 2019-09-10
2019-02-06
2018-12-26
2018-12-20
2019-10-12 2018-12-12 2017-10-16 2019-09-26 2018-01-10 2019-08-25 2019-03-30 2019-08-14
2019-02-23 2019-02-25 2017-11-20
2019-12-01

Exhibit B, Page 16

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 17 of 352 Pageid#: 920

voter_id

lname

228005264 B

705011475 B

6001397 B

918904459 B

224000626 B

395918014 B

211006127 B

623261006 B

407032002 B

919205710 B

901002784 B

303007913 B

233020115 B

902001225 B

221023664 B

808010839 B

123007391 B

223015828 B

920027418 B

305050107 B

919567660 B

702012710 B

601028582 B

31015106 B

706014206 B

917057957 B

920292158 B

13822208 B

204018178 B

508010498 B

104014568 B

604004358 B

466222314 B

fname ROSEMARY LUCILLE MARCI REGINA SHARON DORIS MYRTLE DAVID PHILLIP RUBY LOUISE THOMAS MARVIN STEPHEN WILLIAM ROBERT MORGAN DALE SYLVESTER ARTHUR ARMSTEAD MAUREEN JUDY LAFAYETTE MARY KENNETH GARY CAROLE MAXINE CHRIS PHILIP CHARLES ADELLE

dob 1929 1921 1957 1948 1943 1938 1936 1949 1938 1937 1927 1927 1944 1949 1949 1943 1947 1946 1938 1935 1943 1948 1947 1943 1921 1952 1940 1948 1937 1944 1923 1928 1948

date_registered 1976-08-28 1996-09-09 1997-03-11 2000-09-23 1984-09-26 2012-10-15 1988-08-12 2008-09-12 1996-09-20 2001-10-09 1963-09-30 1963-10-05 1995-07-24 1976-01-19 1985-10-05 1980-10-04 1992-09-12 1982-11-26 2004-11-26 1992-05-04 2003-08-06 1975-09-22 1968-09-01 1992-09-17 1959-10-02 2000-10-04 2006-05-03 2014-01-08 1980-09-03 1967-09-18 1956-04-24 1981-10-01 2014-11-06

ssdi_dod 2019-11-11 2019-05-14 2018-12-20 2019-10-24 2019-08-24 2019-06-27 2019-09-20 2018-12-01 2020-01-21 2020-01-17 2020-01-03 2019-12-12 2019-11-27 2019-08-29 2019-03-30 2018-12-14 2018-12-10 2018-05-12 2016-04-24 2015-03-06 2005-04-29
2018-12-25 2018-10-30 2018-01-25 2018-03-29
2019-11-01 2017-05-29
2019-10-21

obit_dod 2019-11-11
2018-12-20
2019-08-24
2019-09-20
2019-12-12 2019-11-27 2019-08-29 2019-03-30 2018-12-14
2018-05-12 2016-04-24 2015-03-06
2019-09-26
2018-10-30 2018-01-25
2019-11-17 2017-02-27 2019-11-01 2017-05-29 2016-03-31 2015-08-16

Exhibit B, Page 17

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 18 of 352 Pageid#: 921

voter_id

lname

507007404 B

61896447 B

31187817 B

305028020 B

917350035 B

917583802 B

204003478 B

410022760 B

805017021 B

716015465 B

920036425 B

406032532 B

804018318 B

780004818 B

919351073 B

919570992 B

918924955 B

406015146 B

917901794 B

401020227 B

918485793 B

809011805 B

919353899 B

33530593 B

121011209 B

304013027 B

302053024 B

12000918 B

223010225 B

221018132 B

188259698 B

226009238 B

206012654 B

fname GEORGE MARY IRENE ROBERT HENRY THOMAS PAUL MARILYN ALBERT HERSHEL AUSTIN GERALD NANCY RUPASREE WALTER SAMUEL ELMER THOMAS STEPHEN WAYNE MADDREY THELMA BERNICE CAESAR CLEVELAND LEONARD JOHN BETSY RUTH MARGARET TANDY ARTHUR SYLVIA

dob 1948 1935 1934 1940 1929 1934 1925 1953 1921 1934 1931 1972 1937 1972 1946 1931 1941 1932 1947 1952 1949 1928 1923 1956 1947 1939 1943 1940 1929 1924 1938 1928 1937

date_registered 1984-09-08 2013-10-15 2015-09-04 1973-10-03 1995-09-30 1996-08-07 1971-10-02 1992-09-09 1976-02-26 1990-02-15 2004-12-17 1999-10-04 1984-08-28 2007-02-21 2002-06-27 2003-08-12 2000-10-04 1955-12-12 1997-02-18 1992-09-19 1999-04-22 1957-06-08 2005-02-16 2012-08-24 1976-10-02 1976-03-04 2004-02-11 2005-08-08 1972-02-02 1980-10-04 2014-06-30 1972-09-25 1971-08-13

ssdi_dod 2019-08-12
2019-12-18 2019-06-04 2017-01-27 2019-05-11 2018-02-26 2019-08-24
2017-03-03 2016-08-27 2015-11-19
2018-10-17
2019-01-01 2019-10-29 2020-01-20 2020-01-12 2019-11-17 2018-02-12
2018-02-07 2016-12-08
2014-11-03
2019-10-11 2019-11-29 2019-11-21 2018-10-29

obit_dod
2019-05-21
2017-01-27 2019-05-11
2019-08-24 2016-01-31
2016-08-27
2018-12-02
2019-09-20
2019-10-29
2019-11-17 2018-02-12 2016-05-10
2016-12-08 2019-08-19
2019-09-19 2019-10-11 2019-11-29 2019-11-21 2018-10-29 2019-11-11 2019-10-26

Exhibit B, Page 18

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 19 of 352 Pageid#: 922

voter_id

lname

305018826 B

203000568 B

917470791 B

918370725 B

509003628 B

122017726 B

1929149 B

210015373 B

918283330 B

302037508 B

122292256 B

702017085 B

376810450 B

221019713 B

302035354 B

13590115 B

902000019 B

231016717 B

919022464 B

401006932 B

307042452 B

28018070 B

228662987 B

426155664 B

609028538 B

701024395 B

203023076 B

25012112 B

917609582 B

402028024 B

919842928 B

23009650 B

99670055 B

fname DOROTHY JEAN JUGAL ELIZABETH CLEM JANE NATHANIEL SYLVESTER JERRY JOSEPH DANA TED CLYDE GENEROSO FRANKLIN MURTAZA JANICE DONALD SUSAN CARL WALTER MARY MARY HISHAM LINDA ELLEN NANCY MARILYN VICTOR SAM JOSHUA CORNELUS DONNA

dob 1939 1947 1939 1942 1930 1926 1951 1940 1943 1946 1947 1959 1933 1937 1946 1989 1966 1934 1946 1931 1924 1936 1938 1970 1949 1925 1938 1930 1936 1937 1986 1943 1946

date_registered 1999-11-05 1979-09-04 2006-11-16 2006-02-09 1955-11-19 1996-11-06 2012-09-25 1992-08-28 1998-06-08 1988-09-26 2012-10-04 1981-11-27 2012-10-09 1997-02-26 1985-10-02 2016-04-01 2005-08-19 1999-07-28 2001-01-18 2006-08-18 1972-04-03 1968-03-27 2015-04-15 2012-04-26 1991-09-04 1957-02-20 1975-04-21 1985-10-05 1996-08-22 1959-02-19 2004-08-18 1964-12-01 2017-06-28

ssdi_dod 2020-01-12 2019-12-03
2019-12-03 2018-02-28 2019-11-12 2019-05-28 2017-12-28 2019-08-09 2019-11-15 2019-11-13 2019-08-21 2017-12-06
2018-02-23 2019-09-12 2017-07-27 2019-11-01 2019-12-05 2019-10-02 2019-08-15
2019-09-25 2017-10-20 2019-08-09 2014-10-21 2015-03-15 2018-12-16 2019-12-02 2019-01-22 2017-12-27 2019-12-08

obit_dod
2019-10-05 2019-12-03 2018-02-28
2017-12-29 2019-08-09 2019-11-15
2019-08-21 2017-12-06 2019-09-05 2018-12-17
2017-07-27 2019-11-01 2019-12-05 2019-10-02 2019-08-15 2019-09-16
2017-10-19
2014-10-21 2015-03-15 2018-12-16
2019-01-22
2019-12-08

Exhibit B, Page 19

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 20 of 352 Pageid#: 923

voter_id

lname

30018071 B

708018427 B

917372509 B

228020243 B

601007311 B

403022521 B

919272370 B

128011209 B

919211617 B

206008311 B

505021401 B

206011088 B

403022077 B

404021884 B

409026246 B

806014581 B

21017039 B

467846243 B

652012985 B

917917888 B

903023714 B

917740803 B

918790784 B

604004190 B

537092005 B

513024015 B

226003781 B

121366140 B

123566635 B

725057817 B

27004734 B

614008200 B

28001344 B

fname JAMES WILBER GARY LAWRENCE VERNON JACQUELINE SANDRA LOUISE KENNETH BARBARA DOROTHY SWADE REGINALD GRACIE IDA EVELYN MARY JOSEPH MARCELINO JAIME BRENDA SUSAN LAWRENCE ROBERT MARIAL SONDRA PHILIP ANNE SHARON CAROL WILLIAM ROBERT GEORGE

dob 1946 1931 1940 1928 1920 1931 1939 1928 1941 1938 1930 1936 1942 1927 1928 1933 1920 1946 1947 1976 1944 1942 1935 1930 1925 1941 1934 1940 1948 1949 1924 1947 1945

date_registered 1985-10-03 1972-10-04 1995-10-10 1968-10-05 1978-09-15 1984-08-28 2006-05-04 1984-10-06 2001-10-09 1960-10-08 1953-09-30 1976-03-16 1995-10-05 1979-10-04 1988-04-25 1963-07-10 1950-08-04 2013-01-31 2016-09-01 1997-03-03 1984-09-25 1996-10-07 2000-05-24 1992-12-03 2008-09-16 1988-12-22 1966-06-03 2007-03-16 2008-06-26 2017-02-07 1995-09-12 1993-06-17 1973-10-01

ssdi_dod 2018-12-31 2018-12-15 2018-03-25 2019-10-15 2019-12-18 2019-12-14 2019-10-15 2018-12-20 2019-12-31 2019-12-24 2019-11-23 2019-08-22 2018-12-24 2015-02-20 2016-03-15 2017-12-09
2018-07-15 2018-07-08 2014-01-13 2020-01-03 2020-01-01 2019-11-13 2018-03-10
2018-06-26 2019-01-21 2018-10-20
2018-01-22

obit_dod 2018-12-31 2018-12-15
2019-10-15 2019-12-18
2019-10-15 2018-12-20
2019-12-24 2019-11-23
2017-12-09 2016-04-30 2018-07-15
2014-01-13
2019-11-13
2019-12-14 2019-11-01 2019-09-04 2018-12-17
2018-10-20 2015-12-15 2018-01-22

Exhibit B, Page 20

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 21 of 352 Pageid#: 924

voter_id

lname

610010746 B

126015354 B

200207770 B

634747877 B

504012958 B

918114690 B

608008744 B

917171784 B

917344845 B

225001899 B

13001804 B

919759569 B

918826070 B

918781162 B

223005085 B

919115658 B

710004130 B

228020510 B

503010409 B

806015799 B

918201564 B

110012507 B

105079873 B

527556821 B

502017505 B

117218324 B

23013054 B

109217183 B

601004072 B

332388423 B

831525210 B

132655622 B

146715242 B

fname BONNIE JOSEPH ELIZABETH KATHLEEN MARCIA MILES MARY ANNA ANDREW ALLAN ROBERT BURHAN LARRY LILIAN SHERRY MARY PRISCILLA DAVID VELMA DONALD ERNEST JOYCE JEFFREY JAMES MARGARET CHARLES DAISY MARY LOUIS JAMES MICHAEL KENNETH RICHARD

dob 1942 1929 1974 1947 1942 1954 1929 1971 1940 1950 1919 1944 1942 1930 1965 1956 1933 1933 1931 1952 1941 1943 1942 1925 1924 1929 1931 1944 1939 1950 1946 1946 1949

date_registered 2004-09-21 1976-01-01 2018-05-14 2012-10-04 1964-01-04 1997-10-03 1996-06-12 2000-06-28 2006-08-17 2004-07-30 2011-05-27 2004-05-10 2000-07-19 2000-05-15 2000-03-28 2001-06-14 1988-09-28 2004-06-01 1956-06-03 1978-02-22 1998-02-23 1992-07-11 2015-08-12 2012-09-05 1975-10-02 2013-10-25 1964-10-01 2014-12-10 1984-09-21 2012-05-21 2007-11-15 2008-08-06 2012-04-27

ssdi_dod
2019-10-17 2018-08-18 2017-02-03 2019-10-30 2019-01-17
2017-12-19
2019-04-26
2019-02-12 2016-06-19 2018-11-15 2019-11-07 2018-12-12
2018-12-06 2019-12-20 2019-11-12 2019-10-14 2019-03-29 2019-10-11 2020-01-20 2019-12-02 2019-11-14 2019-10-16 2019-09-04 2019-08-03 2019-07-07 2018-11-06 2018-06-27 2017-11-27

obit_dod 2017-10-08 2019-10-17 2018-08-18
2019-01-17 2019-01-31
2014-05-21 2019-04-26 2016-09-10
2018-11-15
2017-11-30 2018-12-06 2019-12-20 2019-11-12 2019-10-14 2019-11-29
2019-12-02 2019-11-14 2019-10-16 2019-09-04 2019-08-03 2019-07-07
2017-11-27

Exhibit B, Page 21

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 22 of 352 Pageid#: 925

voter_id

lname

266878873 B

311003884 B

225008978 B

5005547 B

214044047 B

122547691 B

604027945 B

602027946 B

603027945 B

608028585 B

305035822 B

919557487 B

68189990 B

302041824 B

301010731 B

920171647 B

699333597 B

308007915 B

918874052 B

104024179 B

520277547 B

701001803 B

905005482 B

203018044 B

121020196 B

852713243 B

652633470 B

75500520 B

106020810 B

123013425 B

320141686 B

513015621 B

31450401 B

fname WAYNE WILLIAM MARION MARY BEVERLY ANNETTE FERNE MILDRED EDSEL BRENDA JAMES MOLLIE CHARLES MARY ANN EUGENIA LUIS THERESA LOIS PHYLLIS MYRTLE HAROLD JEANNE YVONNE WILLIAM FRANCES ANGELA LUCIA CAROLYN ELLA LAWRENCE RICHARD ROBERT DAVID

dob 1956 1929 1943 1940 1946 1960 1926 1932 1935 1943 1929 1948 1928 1941 1946 1948 1957 1930 1925 1938 1936 1922 1932 1945 1922 1954 1937 1948 1935 1930 1957 1940 1952

date_registered 2012-10-15 1981-05-15 1999-01-14 1996-06-14 2011-10-17 2008-10-06 1947-06-10 1959-07-23 1956-09-25 1975-03-20 1976-03-23 2003-07-14 2016-10-14 1998-11-05 1992-09-26 2005-09-22 2018-02-05 2000-09-12 2000-09-07 1966-10-07 2018-12-11 2005-07-07 1980-09-15 2001-01-24 2006-08-11 2008-10-06 2016-03-03 2016-10-20 2000-05-09 1998-01-28 2016-07-19 2000-04-06 2007-09-12

ssdi_dod 2016-09-30 2014-11-25 2014-11-08
2015-10-02 2018-06-25 2018-02-21 2018-01-12 2017-12-12
2019-12-30 2019-08-29 2019-09-10 2014-05-24 2019-03-23 2019-07-10 2018-01-20 2019-12-12 2019-11-28 2019-10-02 2019-08-09 2018-12-28 2018-12-05 2018-12-03 2018-05-04 2018-02-18 2017-07-30
2020-01-26 2019-11-24

obit_dod 2016-09-30 2014-11-25
2019-04-10 2018-12-08
2018-06-25 2018-02-21 2018-01-12 2017-12-12 2018-12-08
2019-08-29
2019-07-10 2018-01-20
2019-11-28 2019-10-02
2018-12-05 2018-12-03 2018-05-04 2018-02-18 2017-07-30 2019-09-05 2018-10-09 2017-08-31

Exhibit B, Page 22

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 23 of 352 Pageid#: 926

voter_id

lname

919921689 B

303051242 B

918407049 B

707014436 B

908021785 B

302007281 B

207009796 B

711013431 B

602015561 B

306028440 B

908006138 B

101402430 B

309044304 B

805001850 B

91985970 B

917727270 B

303014492 B

919162624 B

908012144 B

920357949 B

157717924 B

224000888 B

307038204 B

308020392 B

127002856 B

918500242 B

509032480 B

503011143 B

101010687 B

511001053 B

101007859 B

918848953 B

919571552 B

fname KATHLEEN CHARLES WILLARD EARL CALVIN JANIS HENRY MARK THOMAS JOHN CALVIN EDWARD JOE GLORIA TAMMY VIVIAN EVERETT MOHAMMED ALDA KATHLEEN RICHARD GEORGE PAUL FRANCIS HILBERT ROBERT WILLIAM WANDA BENNY BROOKIE OMA BETTYE SHIRLEY

dob 1950 1928 1938 1943 1935 1934 1936 1960 1944 1942 1930 1959 1948 1928 1965 1930 1931 1933 1928 1930 1932 1924 1925 1927 1927 1947 1942 1959 1945 1932 1934 1928 1937

date_registered 2004-09-28 1976-09-25 1999-01-04 1966-10-08 1976-05-05 1972-09-21 1960-04-25 1987-03-02 1976-01-05 1973-10-06 1977-09-14 2012-09-12 1991-09-12 1980-09-03 2019-01-07 1996-10-05 1994-11-09 2001-08-22 1974-12-16 2006-09-09 2018-09-13 1952-06-12 2005-08-01 1980-09-18 1998-11-04 2001-11-07 2003-08-08 1983-10-05 2002-06-04 1992-09-12 1976-10-02 2000-08-02 2003-08-11

ssdi_dod 2018-12-09 2018-01-09 2020-01-21 2020-01-15 2020-01-10 2019-11-05 2019-04-12 2016-11-26
2019-09-24 2018-12-12 2018-01-21 2018-04-30 2019-11-25 2019-08-06 2018-12-15 2017-12-07 2019-10-20
2019-08-26 2020-01-22 2019-12-07
2018-12-18 2018-05-07 2018-04-13
2019-12-02 2018-07-09 2018-05-25 2018-01-12 2017-01-20 2011-10-16

obit_dod 2018-12-09
2019-06-04 2019-09-24 2018-12-12 2018-01-22 2019-11-25 2019-08-06 2017-12-07 2019-05-23 2019-08-26 2019-12-07 2019-09-07 2018-12-18
2019-09-13 2019-12-02
2018-01-12 2017-01-20

Exhibit B, Page 23

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 24 of 352 Pageid#: 927

voter_id

lname

606006595 B

828549344 B

918262450 B

109011153 B

13144562 B

505029182 B

204006720 B

302007917 B

22017595 B

131535318 B

773366482 B

309018232 B

404000010 B

901006140 B

205024668 B

917151978 B

8386910 B

48252663 B

917045115 B

918128229 B

151183428 B

207004685 B

208012279 B

701021860 B

954721165 B

910010091 B

455870411 B

918905812 B

703021599 B

605019327 B

607011024 B

312451220 B

604025380 B

fname CECIL EASTER ETHEL JOAN RICKIE PEGGY FRANCES MARY VIVIAN LUTHER CHARLIE ROBERT FRANCES JOHN SAMUEL WILLIAM HARTMAN NITA PARVEZ CHARLES BERNADETTE WILLIE RITA BENJAMIN WILLIAM PEARRE ASBURY MARTHA HARRISON ELIZABETH ROBERT CHARLOTTE RUSSELL GEORGE

dob 1924 1930 1922 1945 1956 1949 1943 1921 1920 1953 1937 1939 1937 1945 1930 1941 1931 1950 1954 1945 1948 1927 1947 1929 1932 1906 1930 1929 1949 1948 1928 1936 1924

date_registered 1990-09-26 2008-03-31 1998-05-13 1980-09-20 2011-06-23 1975-10-01 2000-01-21 1966-10-07 1963-12-09 2015-11-05 2008-09-17 1976-04-22 1984-04-16 1982-10-02 1992-09-28 1994-09-02 2011-08-29 2014-07-28 1993-09-25 2000-03-09 2012-06-20 1956-10-06 1977-10-08 1951-12-08 2008-09-03 1988-07-29 2015-04-02 2000-09-27 1999-09-17 1984-09-13 1966-09-16 2017-08-17 1947-10-04

ssdi_dod
2017-03-24 2020-01-13 2019-10-12 2015-09-25 2020-01-13 2017-01-24
2019-12-08 2018-03-30 2019-10-02
2011-09-19 2019-11-28 2018-08-02 2018-12-15 2019-11-14 2017-05-28 2018-10-31 2018-06-22 2019-11-01 2019-10-31 2018-12-15 2017-10-24 2017-09-06 1997-03-20
2019-12-03 2019-08-28 2019-12-04 2019-12-24 2019-05-29 2019-10-03

obit_dod 2018-12-26
2017-01-24 2018-12-02 2019-12-08 2018-03-30 2019-10-02 2019-05-02 2011-09-19 2019-11-28
2018-12-15 2019-11-14 2017-05-28
2018-06-22
2019-10-31 2018-12-15 2017-10-24 2017-09-06
2019-09-07 2019-12-03
2019-12-04
2019-10-03

Exhibit B, Page 24

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 25 of 352 Pageid#: 928

voter_id

lname

202025885 B

502007663 B

508006211 B

568816039 B

122288453 B

103000017 B

709025248 B

134010676 B

919268513 B

406028492 B

104026225 B

103020413 B

907019733 B

409031723 B

803010109 B

337865764 B

205026430 B

126003372 B

909001230 B

201000075 B

919523953 B

701017636 B

404026252 B

917821375 B

303002568 B

401011386 B

696259375 B

771364375 B

123009487 B

407022252 B

221000017 B

863621325 B

162735618 B

fname KENNETH SHIRLEY ROLAND WALTER MARIA CHARLES NANCY JOSEPH EDITH RACHEL MARY DONALD PEGGY KATHELEENE HERMAN WILLIAM ELIZABETH ROBERT JOHN JOSEPH BERNIEL ROBERT JOHN FREDERICH CARL ANDREW MADELINE YASUKO THOMAS ARTHUR JAMES BROWNIE CONSTANCE

dob 1939 1934 1932 1951 1931 1948 1929 1937 1929 1918 1935 1921 1945 1946 1924 1962 1932 1958 1922 1938 1942 1928 1920 1921 1932 1960 1936 1931 1934 1932 1943 1933 1928

date_registered 2003-08-26 1976-03-23 1983-10-05 2011-02-17 2012-10-02 1978-09-01 2000-07-24 1992-09-23 2002-02-06 1973-10-06 1956-09-25 1950-10-06 1971-02-24 1996-08-30 1991-06-08 2014-11-13 1963-09-19 2000-01-20 1950-11-13 1971-09-30 2003-05-15 2004-06-16 1946-10-02 1996-11-18 1986-06-11 1979-09-11 2009-10-05 2011-10-14 1992-10-03 1979-09-15 1984-09-04 2008-03-21 2016-01-29

ssdi_dod 2020-01-23 2019-11-24
2019-05-24 2019-11-22
2019-08-05
2018-12-04 2019-09-17 2019-10-18 2020-01-26 2019-12-22 2019-12-14 2019-10-29 2018-09-24 2018-05-27
2019-11-04 2018-01-19 2019-12-11 2019-11-27 2011-12-06
2019-10-10 2019-10-22
2019-10-04 2019-09-29 2019-09-12 2018-12-31

obit_dod
2019-11-24 2019-08-05 2018-09-01
2019-11-22 2019-10-03
2017-06-18 2018-12-04 2019-09-17 2019-10-18
2019-12-14 2019-10-29 2018-09-24 2018-05-27 2018-12-01 2019-11-04 2018-01-19 2019-12-11 2019-11-27
2018-04-25 2019-10-10 2019-10-22 2018-12-05
2019-09-12 2018-12-31 2019-09-09

Exhibit B, Page 25

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 26 of 352 Pageid#: 929

voter_id

lname

614405213 B

908008931 B

607001560 B

201004687 B

608028987 B

697872606 B

917258503 B

503022839 B

221023288 B

25017816 B

24017816 B

240078897 B

649226612 B

918626319 B

112006119 B

201025887 B

807009617 B

806003677 B

404003284 B

205001522 B

203003700 B

506002894 B

27370351 B

372105736 B

917998187 B

918753795 B

29119535 B

308032774 B

206004228 B

219036627 B

917099934 B

602028057 B

919217921 B

fname BARBARA JOSEPH PEGGY HILDA GLORIA DIE VIRGINIUS DOROTHY MAXINE NATHANIEL HATTIE JOHN THOMAS CATALINO JEAN WILLIE KATHRYN RICHARD JAMES VIRGUS PRISCILLA JUNE LILLIAN DAVID ELIJAH SHIRLEY FLORENCE ESTEL EUGENE FLOYD IDA LINDA FRANCIS

dob 1944 1936 1943 1925 1942 1963 1949 1930 1951 1929 1930 1932 1949 1947 1922 1939 1922 1954 1925 1936 1941 1932 1925 1956 1952 1935 1943 1924 1936 1955 1935 1941 1963

date_registered 2012-10-15 1981-10-01 1975-09-22 1956-10-02 1967-10-15 2014-01-14 1995-03-29 1972-03-08 2017-11-13 1968-04-16 1964-10-03 2009-11-16 2007-04-11 2000-01-04 1988-09-21 1964-09-23 1959-03-03 2002-07-24 1946-10-03 2000-09-20 1964-04-22 1984-10-06 2009-10-05 2008-09-24 1997-05-10 2000-04-13 2007-09-20 1949-07-02 1966-02-28 2015-08-05 1994-03-30 1991-10-05 2001-11-07

ssdi_dod
2019-11-30 2019-11-03 2019-09-22 2018-05-15
2019-12-26 2019-08-24 2019-04-25 2018-01-02
2018-01-29 2016-08-22 2019-09-30 2019-09-11 2019-09-02
2019-12-05 2019-11-12 2019-10-16 2019-09-12 2019-02-05 2018-12-18 2018-12-01 2018-01-16
2019-10-25 2017-12-02 2020-01-15
2019-08-05

obit_dod 2016-10-24 2019-09-23 2019-11-30 2019-11-03 2019-09-22
2018-11-04 2019-12-26 2019-08-24 2019-04-25 2018-01-02 2019-06-08 2018-10-28 2018-01-29 2016-08-22 2019-09-30
2019-09-15 2019-12-05 2019-11-12
2018-12-18 2018-12-01 2018-01-16 2018-12-21 2019-10-25
2014-07-28

Exhibit B, Page 26

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 27 of 352 Pageid#: 930

voter_id

lname

410018766 B

226008093 B

262665001 B

910017025 B

505013427 B

225015844 B

602029243 B

23011614 B

917367986 B

919556080 B

601027823 B

608032640 B

401011879 B

918268324 B

505009726 B

307003294 B

306041593 B

602005293 B

301042192 B

306032775 B

199322710 B

656267553 B

902003060 B

903007104 B

473455277 B

272206972 B

234007479 B

919634270 B

509004588 B

917344897 B

909022691 B

850422983 B

918268233 B

fname WILLIAM THERESA HAROLD GREGORY EMIL CHARLES MAUDE EVELYN ERNEST THELMA MARK SHIRLEY SARA ROBYN AUBREY AVON HENRY MARVIN WAYNE JOHN WILLIAM MILDRED FREDA MARYANNE MARIE RICHARD WILBURN LILLIAN VERNICE THOMAS BARBARA SHIRLEY AINARS

dob 1927 1945 1946 1946 1931 1937 1932 1929 1924 1934 1960 1931 1931 1956 1929 1925 1930 1932 1929 1935 1949 1930 1923 1929 1946 1964 1947 1924 1932 1947 1942 1942 1943

date_registered 1992-08-10 1979-11-13 2008-08-06 2004-09-30 1984-09-08 1989-05-13 1954-03-08 1982-09-22 1995-10-03 2003-07-09 1989-08-23 1963-08-05 1963-04-30 1998-05-15 1958-01-01 1956-10-06 1966-04-02 1953-09-02 1968-09-26 1976-07-01 2019-09-04 2008-10-06 1991-04-04 1992-04-01 2008-06-26 2017-03-13 1992-09-17 2003-11-19 2003-12-29 2004-08-17 1988-09-27 2007-07-02 1998-05-20

ssdi_dod 2018-08-16
2019-12-14
2019-11-23 2019-10-09 2018-12-10 2018-12-03 2018-07-07 2018-04-17 2019-11-27 2019-11-14 2019-09-24 2019-06-10
2019-11-28 2019-07-25 2020-01-22 2019-10-28 2019-10-28 2018-03-24 2018-01-18 2019-09-22 2017-07-20 2018-07-03 2018-02-15 2017-01-07 2019-11-03 2018-12-24 2019-10-12 2019-09-10 2017-12-02

obit_dod 2018-08-16 2019-08-15 2019-12-14 2018-12-19 2016-01-10
2018-07-07
2019-11-27 2019-11-14 2019-09-24 2019-06-10 2019-08-17 2019-11-28 2019-07-25
2019-10-28
2018-01-21
2017-07-20 2018-07-03 2018-02-15
2019-11-03
2019-10-12 2019-09-10

Exhibit B, Page 27

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 28 of 352 Pageid#: 931

voter_id

lname

290072990 B

201004363 B

303053276 B

803020394 B

901022502 B

301010276 B

717011104 B

918250645 B

125004769 B

125012910 B

105009939 B

801010669 B

918568054 B

907001234 B

223017750 B

920325254 B

919120883 B

173723126 B

919019703 B

208013218 B

919363005 B

305031680 B

920129621 B

302041832 B

408028810 B

201006012 B

919269533 B

224008371 B

917897354 B

703015114 B

920383734 B

702015114 B

706027493 B

fname JULIA JOHN RACHEL CLIFTON PERCY DAVID PATTY THOMAS GRACIE BETTIE DOROTHY RICHARD PEGGY JOHN RUTH LINWOOD CLAUDE JANOS WILLIAM ELIZABETH ADA MAXINE NORA ANN MARIE ROGER DENNIS SHERRI MARGARITA ELIZABETH JANE QUINCY J VERNOY

dob 1923 1931 1931 1930 1927 1946 1939 1932 1938 1934 1941 1939 1929 1930 1925 1948 1922 1936 1946 1925 1944 1933 1929 1944 1956 1951 1947 1932 1932 1930 1955 1925 1923

date_registered 2012-10-15 1984-09-04 1997-04-21 1996-08-23 1951-04-21 1975-05-06 1999-09-07 1998-04-21 1978-04-01 2000-04-15 1969-10-04 1984-10-05 1999-08-16 1956-09-18 1978-09-01 2006-07-13 2001-06-13 2012-10-01 2001-01-11 1998-07-06 2002-07-19 1964-03-12 2005-07-08 1976-04-15 1992-09-30 2006-07-13 2002-02-07 1997-02-03 1999-08-20 1954-08-23 2006-10-10 1946-07-03 1953-03-09

ssdi_dod 2018-06-09 2019-09-14 2017-12-20 2019-03-01
2019-06-14 2019-10-08 2019-12-17
2019-09-08 2018-12-18 2016-12-13 2018-12-13
2017-12-22
2019-08-16 2018-01-21 2017-10-07
2019-12-18 2019-11-30 2019-02-13 2019-08-12 2019-11-14 2019-12-22 2019-09-03 2019-08-19 2017-09-30

obit_dod
2019-09-14 2017-12-20 2019-03-01 2019-10-03 2018-12-30 2019-06-14
2018-12-03 2019-09-08
2018-12-13 2019-08-15 2017-12-22 2018-12-27 2014-11-19 2017-12-10 2019-08-16
2019-10-01 2018-12-14
2019-11-30
2019-08-12 2019-11-14 2019-12-22 2019-09-03

Exhibit B, Page 28

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 29 of 352 Pageid#: 932

voter_id

lname

919595310 B

123004939 B

920169834 B

106023308 B

406018767 B

309019888 B

103019297 B

121022261 B

127013052 B

114021569 B

604018156 B

25013305 B

917518900 B

28376158 B

919254086 B

110023853 B

917365783 B

918241302 B

917010348 B

939897474 B

511020836 B

302027717 B

705002303 B

917869455 B

413032127 B

919064907 B

917765807 B

919943954 B

618685371 B

112006638 B

203024141 B

103024180 B

304019156 B

fname RONALD LEON DENNIS ROLOFE WILLIAM GARY VITO RACHEL DEBERA RODNEY FRANK LENDORA LYNN LORETTA THOMAS JOHN HOWARD ALLEN SERGIO SANTIAGO THOMAS JOHN LAURA FRANKLIN STEPHEN CONSTANCE JAMES ROSA LAFERNE YVONNE ARTHUR LEMON EVELYN HERMAN

dob 1946 1954 1933 1926 1927 1944 1925 1942 1956 1923 1943 1934 1942 1955 1944 1930 1934 1927 1936 1947 1937 1947 1954 1939 1939 1926 1937 1944 1939 1953 1930 1924 1935

date_registered 2003-09-18 1972-08-28 2005-09-20 2002-07-09 1981-09-08 1978-08-09 1965-03-22 1993-03-08 1976-09-28 1990-08-27 1964-09-10 1964-09-30 1996-06-12 2016-07-12 2005-08-12 1992-10-01 1995-10-10 1998-04-07 2004-12-10 2009-05-11 1984-08-30 1987-03-14 1999-12-06 1999-09-27 1978-08-26 2001-03-21 1997-12-17 2004-10-04 2008-09-30 1995-10-10 1956-09-18 1981-08-13 1987-07-02

ssdi_dod 2016-07-04 2007-11-29 2019-12-24 2020-01-07 2020-01-01 2019-12-18 2018-12-07 2019-11-04 2019-10-20
2019-11-06 2019-04-03 2018-12-10 2016-11-28
2019-10-28 2019-08-12 2019-12-14 2019-02-11 2019-07-23 2019-09-09
2019-11-13 2019-10-07 2019-11-01 2016-11-27 2019-11-16
2020-01-12 2019-11-27 2018-01-28
2019-12-18

obit_dod 2016-07-04 2007-11-29
2019-10-20 2018-12-30 2019-11-06 2019-04-03
2016-11-28 2019-10-27 2019-10-28 2019-08-12
2015-01-26 2019-11-13 2019-10-07 2019-11-01 2016-11-27
2018-12-30
2019-11-27 2018-01-28 2018-04-13 2019-12-18

Exhibit B, Page 29

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 30 of 352 Pageid#: 933

voter_id

lname

22001971 B

917055271 B

906003330 B

917929557 B

918748463 B

224003675 B

919897918 B

122013841 B

917232388 B

203011098 B

304032543 B

918209012 B

115768977 B

917002571 B

918945613 B

803899309 B

714006268 B

503003961 B

104027260 B

463415518 B

917150668 B

918561641 B

709017821 B

803006173 B

27004976 B

805005530 B

373319415 B

919591840 B

917480803 B

702018768 B

203022354 B

808001857 B

917400805 B

fname WILLIAM SONYA MICHAEL SANDRA FRANKLIN RUTH DALLAS MICHEAL EMMANUEL LINDA RUSSELL LESLIE DARRELL ALTON ROBERT JAMES LUTHER WILLIAM PHILLIP JOSEFINA ROBERT CHARLES JANICE CAROLYN CONCORDIO JAMES SEV THOMAS JEAN SHIRLEY RONALD PRISCILLA ROY

dob 1932 1962 1950 1955 1933 1935 1934 1964 1941 1944 1930 1945 1963 1932 1948 1955 1958 1926 1926 1942 1936 1936 1950 1935 1933 1947 1926 1946 1931 1935 1944 1941 1937

date_registered 1988-06-13 1993-11-03 1971-04-03 2003-12-01 2003-06-04 1974-03-04 2004-09-16 2000-07-06 1999-10-04 1976-09-15 1960-09-16 1998-02-27 2016-10-05 1997-01-17 2000-10-10 2010-10-07 1990-12-14 1980-09-16 1952-10-03 2007-02-09 1994-08-27 1999-08-17 1988-10-01 1984-01-03 1980-10-04 1986-10-03 2010-10-07 2003-09-11 1996-05-02 1988-09-16 1966-06-11 1979-10-06 1996-02-22

ssdi_dod 2019-11-30 2019-09-28 2019-09-26 2019-08-19 2017-08-05 2017-08-04
2019-11-25 2019-10-15 2019-03-05 2018-12-28 2018-12-07 2016-12-05
2019-10-14 2018-02-15 2014-01-05 2019-10-25 2019-09-23
2016-11-06 2019-09-27 2019-10-24 2018-10-23 2018-12-10 2018-01-24 2019-10-28
2019-01-27 2019-11-17 2019-09-26

obit_dod
2019-09-29
2019-08-19 2017-08-05 2017-08-04 2019-09-08 2019-11-25
2019-03-05 2018-12-28
2016-12-05 2019-10-05 2018-12-10 2019-10-14 2018-02-15
2019-10-25 2019-09-23 2018-06-07
2019-09-27
2018-12-10
2019-06-15 2019-01-27 2019-11-17 2019-09-26 2018-11-18

Exhibit B, Page 30

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 31 of 352 Pageid#: 934

voter_id

lname

307029839 B

917706008 B

127008981 B

102029327 B

917766800 B

201008737 B

708008594 B

779597159 B

919122062 B

91076036 B

806013521 B

918908782 B

704017335 B

918891277 B

918448807 B

919931197 B

911233549 B

601029147 B

309026354 B

41754943 B

917996160 B

107025556 B

604020690 B

505014103 B

224022427 B

228021779 B

812008638 B

919811007 B

121017122 B

606020266 B

778429609 B

904011827 B

901008934 B

fname ROSARIA MARJORIE DOROTHY CONSTANCE ROBERT LEWIS MARTIN INEZ NANCY MILDRED MYRA WILLIAM LINDA BARBARA JAMES RICKY KATHERINE WILLIAM ROBERT FRANCES MARGARET PEGGY CARL PAUL ROBERT FREDERICK WILL CHRISTINE KENNETH BETTY RUSSELL LEWIS IDA

dob 1927 1938 1938 1929 1936 1944 1934 1937 1938 1916 1936 1947 1937 1933 1939 1959 1937 1950 1940 1936 1945 1922 1925 1935 1928 1922 1936 1948 1933 1936 1944 1948 1931

date_registered 1968-02-10 1996-09-19 2001-04-30 2001-07-17 1996-10-07 1983-09-16 1982-05-10 2010-10-12 2002-08-14 2012-10-10 1963-07-22 2000-09-28 1966-02-05 2000-09-19 1999-03-09 2004-09-30 2008-01-03 1984-06-15 1991-09-12 2012-04-27 2005-03-10 1983-09-19 1949-05-06 1964-09-30 1967-10-07 1958-11-06 1989-08-11 2004-07-14 1968-10-02 1968-09-28 2016-10-12 1998-04-08 1977-10-08

ssdi_dod 2016-06-08
2020-01-26
2019-01-19 2019-12-25 2018-12-13 2018-07-30 2018-02-05 2018-01-23 2019-10-28 2019-10-21 2019-09-10 2019-12-18 2019-12-12 2019-08-07 2018-11-17 2018-06-20 2018-04-08 2018-01-01
2020-01-12 2017-11-08 2016-12-09 2016-10-07
2018-12-17 2019-12-21 2019-10-14 2019-10-10 2019-09-29 2018-09-23

obit_dod 2016-06-08 2019-03-05
2019-10-18
2018-12-13
2018-01-23 2019-10-28
2019-09-10 2019-12-18 2019-12-12 2019-08-07
2018-04-08
2019-10-21 2019-10-01
2016-10-07 2018-12-01 2018-12-17 2019-12-21 2019-10-14 2019-10-10 2019-09-29 2018-09-23

Exhibit B, Page 31

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 32 of 352 Pageid#: 935

voter_id

lname

221000264 B

502010192 B

504001197 B

502029251 B

901006774 B

106024006 B

502029313 B

912018675 B

227022183 B

507029251 B

917635572 B

23652126 B

804015290 B

307049241 B

409026731 B

918987586 B

917328045 B

398787734 B

707012368 B

204012069 B

213001905 B

249557327 B

917230062 B

599899367 B

501024180 B

817493707 B

919444612 B

707012894 B

706012894 B

208015386 B

109003514 B

101003515 B

917104634 B

fname JACQUELYN HELEN JUANITA GLORIA OPAL CECELIA JAMES RONALD HILDA JEFFERSON EVA STEVEN KENNETH MATHEW BENJAMIN RICHARD HUBERT HELEN HENRY ROBERT BETTY SYLVESTER PATRICK JACQUELINE JAMES PEGGY SANDRA JOANN DONALD YOLE GLEENWOOD MYRTLE CLARENCE

dob 1931 1943 1926 1946 1926 1933 1937 1953 1934 1937 1930 1946 1942 1926 1937 1945 1947 1942 1952 1941 1939 1954 1951 1939 1930 1938 1944 1924 1935 1926 1930 1930 1927

date_registered 1966-09-23 1983-09-06 1964-07-31 1979-06-22 2005-09-30 1980-04-03 1964-08-03 1988-03-29 1960-10-08 1975-10-01 1996-09-05 2008-11-12 1963-09-09 2004-05-28 2006-06-14 2000-10-18 1995-09-18 2012-08-09 2016-10-21 2001-09-21 1960-10-17 2012-11-30 2000-11-09 2007-06-26 2005-03-11 2008-10-06 2002-12-11 1981-08-10 1980-06-10 1976-10-02 1968-09-24 1980-09-18 1994-04-02

ssdi_dod
2018-01-15 2020-01-19 2019-12-25 2019-12-06 2019-11-24 2019-11-04 2019-10-29 2018-12-09 2018-10-07 2014-11-13
2019-10-29 2019-09-04
2019-12-22 2020-01-13 2020-01-12 2019-11-23 2019-10-11 2018-12-20 2018-09-20 2017-11-16 2017-04-20 2016-12-02
2020-01-11 2019-04-04 2019-03-21 2019-11-09 2019-11-14 2018-05-04 2017-04-01

obit_dod 2019-09-01 2018-01-15
2019-12-06 2019-11-24 2019-11-04 2019-10-29 2018-12-09
2014-11-13 2019-10-19 2019-10-29 2019-09-04 2019-08-05 2019-12-22
2019-11-23 2019-10-11 2018-12-20 2018-09-20
2016-12-02 2018-12-28
2019-03-21
2019-11-14 2018-05-04

Exhibit B, Page 32

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 33 of 352 Pageid#: 936

voter_id

lname

901020980 B

873869982 B

727858309 B

917421697 B

22018678 B

918588208 B

4003834 B

918205375 B

920134890 B

169308364 B

302015939 B

807000947 B

509025920 B

126017592 B

506014104 B

406004494 B

918207154 B

920156250 B

918819653 B

118074755 B

322813315 B

907022088 B

305003505 B

12031528 B

603007037 B

124007649 B

403017862 B

31018084 B

128004942 B

408020366 B

803019036 B

504025921 B

307011698 B

fname WILLIS ANNE SYLVIA ASHFIELD CONNIE JEAN JOYCE VERA HELEN CARL JAMES VERDIA CHESTER LARRY JAMES SILAS THOMAS DONNA VIRGINIUS BRUCE RAE BARBARA THOMAS LILLIAN ROBERT DELORIS ALFRED BYRDELL LOTTIE MARGARET DOROTHY EUGENE GARY

dob 1927 1928 1927 1938 1950 1926 1943 1929 1937 1936 1939 1948 1922 1948 1932 1941 1973 1947 1930 1947 1945 1932 1944 1927 1935 1940 1943 1923 1931 1921 1936 1924 1945

date_registered 1952-02-11 2008-11-25 2008-07-11 1996-03-25 1996-11-06 1999-09-17 1967-04-27 1998-03-03 2005-07-20 2015-12-09 1984-09-27 1972-10-07 1987-09-15 1976-10-01 1975-05-08 1975-03-20 1999-02-23 2005-08-30 2000-07-12 2012-05-02 2008-10-06 1968-08-12 1999-05-01 2012-10-15 1982-04-29 1976-10-02 1988-02-06 1965-07-14 1968-04-18 1960-11-21 1999-06-07 1974-09-20 1985-09-21

ssdi_dod 2019-11-01 2019-12-23 2019-11-22 2018-12-11 2019-09-23 2017-03-07
2019-06-27 2020-01-24 2019-11-12 2018-12-13 2017-06-17 2016-11-02
2018-01-20
2019-10-13 2018-02-25 2020-01-27
2020-01-06 2019-10-20 2019-10-14 2019-09-22 2018-10-22 2018-06-14 2018-01-28 2017-08-29 2018-02-07

obit_dod 2019-11-01 2019-12-23 2019-11-22 2018-12-11 2019-09-23 2017-03-07 2019-10-14 2019-06-27
2019-11-12 2018-12-13 2017-06-17 2016-11-02 2019-08-11 2014-05-07 2019-08-25 2018-01-20 2014-12-28 2019-10-13
2019-08-06 2019-09-10
2019-10-20
2019-09-22 2018-10-22
2018-01-28
2019-10-10

Exhibit B, Page 33

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 34 of 352 Pageid#: 937

voter_id

lname

702013673 B

605027691 B

2002730 B

44157064 B

107012869 B

221021782 B

918615135 B

611001491 B

502007869 B

209014172 B

730483849 B

917382326 B

17428299 B

303014089 B

701025025 B

375325623 B

514027310 B

918429794 B

203013740 B

603008564 B

917042831 B

505027144 B

206022675 B

702003695 B

101010459 B

204002522 B

730666161 B

601015958 B

309034935 B

502013724 B

805010846 B

228013228 B

308027522 B

fname WILLIE TRACY VERNON LOUISE FRANCES SUZANNE TRACY GILBERT CHARLIE WILLIAM DALJIT ARTHUR GWENDOLYN JEAN-PIERRE ELEANOR RAYMOND MARGARET VINCENT ANTOINETTE JOSEPH LOUIS WILLIE IRVIN MYRTLE CATHERINE INAFERN JASON RUTH NORA KATHRYN MILDRED ELFRIEDE JEFFREY

dob 1935 1959 1933 1924 1922 1941 1963 1935 1921 1941 1950 1930 1956 1938 1946 1947 1922 1948 1943 1942 1954 1926 1935 1938 1936 1932 1989 1924 1927 1943 1940 1921 1946

date_registered 1955-07-21 1978-07-06 1998-03-27 2012-09-06 1952-02-27 1989-10-06 1999-10-04 1992-09-01 1970-10-03 1992-09-22 2011-10-17 1995-12-04 2015-07-10 2000-08-07 1998-04-17 2008-05-09 1989-08-31 1999-01-29 1998-08-31 1988-06-07 1993-10-02 1987-04-02 1967-01-14 1964-09-30 1972-09-23 1978-06-05 2009-04-30 1968-10-05 1983-10-08 1976-09-11 2005-12-08 1984-09-15 1988-10-08

ssdi_dod 2018-02-28 2018-02-09 2019-12-11 2014-11-18 2018-12-29
2019-04-15 2020-01-22 2019-09-21
2014-02-21 2019-10-21
2019-09-28
2019-10-14 2019-08-13 2017-12-30 2019-10-24 2016-10-08
2018-12-03 2018-08-17 2014-09-24 2018-10-22
2019-12-24 2019-10-15

obit_dod
2018-02-08 2019-12-11
2018-12-29 2018-12-20 2019-04-15
2019-09-18 2014-02-21 2019-10-21 2017-01-28
2018-11-23 2017-07-01 2019-12-05 2019-08-20 2019-10-14
2019-10-24 2016-10-08 2019-11-05 2019-08-14 2018-12-03 2018-08-17 2014-09-24 2018-10-22 2015-11-20 2019-10-15
2019-10-15

Exhibit B, Page 34

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 35 of 352 Pageid#: 938

voter_id

lname

302041838 B

206019992 B

222015622 B

809018196 B

918918781 B

509019504 B

917639676 B

306033188 B

403011884 B

226010234 B

223010806 B

919904880 B

918467052 B

918974817 B

917064459 B

31016374 B

703002747 B

904016035 B

224000897 B

204008878 B

703004148 B

6682662 B

919130698 B

917209119 B

917678821 B

919866165 B

24018338 B

84887549 B

302003905 B

910010097 B

920292277 B

153255643 B

905018479 B

fname JAMES JOHN DANIEL PETER GEORGE AUSTIN LAURA THOMAS UNA JOHN BETTY JOYCELYN JAMES JACQUELINE ROBERT JEANNETTE ORAL WILLIAM DOROTHY THOMAS ADA ROBERT VIVIAN WALTER SHERRY SYLVIA ELDON DONALD JORDAN PHILIP LARRY STEVEN EFFIE

dob 1923 1925 1935 1927 1948 1934 1944 1940 1921 1930 1928 1948 1924 1947 1938 1937 1948 1943 1924 1945 1936 1943 1945 1951 1962 1936 1948 1933 1930 1950 1944 1974 1925

date_registered 1972-09-01 1969-07-24 1980-10-04 2000-03-01 2004-01-05 1988-08-05 1996-09-05 1984-05-05 1952-10-01 1976-06-09 1954-02-16 2004-09-16 1999-03-23 2000-11-08 1993-12-27 1991-09-12 1990-09-25 1985-10-05 1991-01-22 1978-08-23 1991-09-16 2016-12-22 2001-06-27 1994-10-11 2001-04-20 2004-08-28 1998-06-16 2017-03-16 1970-12-28 1991-09-14 2006-05-03 2011-04-22 1968-05-31

ssdi_dod
2019-12-22 2019-07-21 2018-01-03
2019-11-30 2019-11-26 2019-08-18 2019-07-29 2018-01-26 2019-10-13 2018-02-23 2018-12-14 2017-05-22 2019-12-26
2019-10-27 2019-03-12 2019-09-11 2020-01-22 2019-12-31 2018-01-19 2019-10-09 2019-09-17 2019-01-31 2015-03-30
2019-08-24 2018-12-19 2019-09-13 2019-12-09 2019-08-16 2017-10-21

obit_dod 2018-10-31 2019-12-22 2019-07-21
2015-02-07
2019-07-29
2019-10-13
2018-12-14 2017-05-22 2019-12-26 2018-12-18 2019-10-27 2019-03-12 2019-09-11
2018-01-19 2019-10-09 2019-09-17
2015-03-30 2019-10-12 2019-08-24
2019-09-13 2019-12-09 2019-08-16 2017-10-21

Exhibit B, Page 35

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 36 of 352 Pageid#: 939

voter_id

lname

918278748 B

212012293 B

301055390 B

225001302 B

917593610 B

601005015 B

808013056 B

919567967 B

803001184 B

919711548 B

515110481 B

106009310 B

29003613 B

406021658 B

917050602 B

31019919 B

404001843 B

919072000 B

43774909 B

917669903 B

224006604 B

809002491 B

101010695 B

221078354 B

24004493 B

803006403 B

228019569 B

920315235 B

310043426 B

918812795 B

602020695 B

533884942 B

920289206 B

fname MERRY BRENDA JUERGEN WILBUR BLANCHE WILLIAM MARY GARY PANSY EDNA JUNE CHRISTINE EDWARD ELSIE ELAINE ALICE ELEANOR WILLIAM ADAM GARRY LINDA JEAN ANTHONY CLAIRE ELIZABETH DENNIS ROBERT ANDREW KATHLEEN FREDERICK JOANN TERREL JOSEPH

dob 1948 1964 1949 1951 1939 1955 1922 1963 1933 1926 1920 1945 1939 1929 1930 1946 1934 1961 1987 1962 1943 1924 1940 1935 1930 1919 1943 1941 1946 1934 1932 1959 1957

date_registered 1998-06-10 2006-12-07 2004-05-19 1985-09-24 1996-08-13 1987-03-10 1964-10-02 2006-07-21 1962-04-21 2004-03-16 2008-08-15 2003-01-27 1960-10-07 1993-09-21 1993-10-04 1992-08-18 1984-09-07 2001-03-30 2011-07-07 1998-11-25 1971-01-06 1990-12-03 1984-09-09 2010-08-05 1964-07-22 1983-10-06 1991-02-09 2006-06-15 1999-12-30 2000-06-29 1979-09-20 2016-10-11 2006-04-10

ssdi_dod
2019-01-11 2013-11-01 2018-01-23 2013-05-30 2018-12-05 2018-03-26 2018-04-11 2019-07-17 2019-12-22 2019-08-19 2019-12-20 2019-08-04 2019-10-25 2019-07-21 2020-01-20 2018-01-14 2019-05-22 2019-10-18 2019-10-12
2016-11-27 2017-02-02
2019-08-11 2016-04-22
2018-01-26 2019-12-04 2019-10-25 2019-08-22 2019-08-22 2019-08-11

obit_dod 2018-12-06 2019-01-11
2018-01-23
2018-03-26 2018-04-11 2019-07-17 2019-12-22 2019-08-19
2018-01-14
2014-03-11 2016-11-27 2017-02-02 2016-07-17 2019-08-11 2016-04-22 2019-10-30 2018-01-26 2019-12-04 2019-10-01 2019-08-23 2019-08-22

Exhibit B, Page 36

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 37 of 352 Pageid#: 940

voter_id

lname

25001223 B

918624981 B

403016057 B

917899395 B

950745610 B

302019755 B

508019900 B

705022125 B

182446297 B

211014782 B

302014092 B

803010120 B

107000465 B

804015028 B

222000270 B

918594102 B

918011768 B

919084976 B

302021098 B

216002607 B

919469587 B

502003354 B

505027146 B

808014938 B

121000696 B

918146053 B

917908052 B

206023087 B

708021063 B

904001561 B

210019284 B

917078146 B

621071342 B

fname IRENE CLARENCE CAROL ANGELA MICHAEL BARBARA VIOLET DONALD ROGER DAVID DENNIS JOHN EMILY CARL WILMA GREGORY LEWIS IRENE DONALD ARMALEE PATRICIA EUNICE ALICE GLADYS ILIA YVONNE JOAN RAYMOND ELIZABETH ROSE EUGENE JANICE MARY

dob 1921 1939 1952 1964 1956 1928 1942 1922 1943 1933 1940 1949 1932 1935 1929 1949 1932 1942 1946 1934 1946 1936 1931 1933 1931 1947 1933 1932 1939 1950 1933 1953 1927

date_registered 1958-12-08 1999-11-10 2005-09-29 1997-02-13 2007-06-14 1972-05-18 1987-05-05 1976-09-27 2012-09-28 1976-10-02 1980-10-04 1983-09-20 1982-10-02 1968-10-02 1989-09-23 1999-09-15 1997-06-11 2001-04-17 2002-07-09 1992-09-11 2003-02-12 1980-10-04 1964-10-03 1980-03-17 1982-09-24 1997-11-05 1997-02-25 1991-09-07 1997-12-01 1999-07-30 1988-09-24 1994-03-08 2009-03-06

ssdi_dod 2019-07-09 2017-10-26 2017-10-02 2017-06-28 2017-05-02 2016-06-17 2016-03-11
2018-01-25
2019-10-26 2020-01-22 2020-01-16 2020-01-15 2020-01-12 2019-12-31 2019-12-27 2019-12-17 2019-12-15 2019-12-12 2019-12-11 2019-12-06 2019-12-03 2019-12-03 2019-11-28 2019-11-22 2019-11-15 2019-11-13 2019-11-12 2019-11-05

obit_dod 2019-07-09
2017-10-02 2017-06-28
2016-03-11 2019-10-12 2019-02-25 2018-12-20 2018-12-09 2018-01-25 2019-10-20 2019-10-26
2019-12-17 2019-12-15
2019-12-11 2019-12-06 2019-12-03
2019-11-28 2019-11-22 2019-11-15 2019-11-13

Exhibit B, Page 37

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 38 of 352 Pageid#: 941

voter_id

lname

184290342 B

7002732 B

106003866 B

185470926 B

507007486 B

304017082 B

905001559 B

308017081 B

651187758 B

207005798 B

239189867 B

623923584 B

112025652 B

7934272 B

3635560 B

909011980 B

917513135 B

303022935 B

918735610 B

906003671 B

605004456 B

903019745 B

919612337 B

312039549 B

906016258 B

885450713 B

810010121 B

919410505 B

504011974 B

405003289 B

127000021 B

603003262 B

208006733 B

fname KIMBERLY BETTY PATRICIA DAVID HELEN LOREN JAMES DORA DOROTHY LOUIS LORENA ANTHONY WILLIAM RONALD SHARON MARIAN TONYA MILDRED ROSA MARK MARY HUNTINGTON MALINDA WILLIAM MARY BONNI FRANKLIN EDITH HENRY JAKE BARBARA DOROTHY JOSEPH

dob 1961 1945 1939 1945 1933 1932 1935 1934 1919 1941 1938 1960 1952 1953 1962 1932 1971 1929 1957 1971 1928 1927 1967 1943 1923 1961 1947 1927 1926 1932 1934 1930 1937

date_registered 2016-06-24 1975-03-31 2000-03-09 2018-12-20 1982-09-16 1993-09-27 1964-09-30 1993-09-27 2009-08-31 1964-10-01 2008-11-13 2012-09-10 1989-09-18 2008-04-28 2012-05-21 1969-10-02 1997-04-07 2003-01-30 2002-10-07 1989-08-02 1966-06-10 2003-01-06 2003-10-06 2003-02-20 1984-03-15 2017-02-17 1992-09-12 2002-10-04 1949-01-04 1964-10-03 1955-01-01 1963-04-27 1968-09-10

ssdi_dod 2019-10-20 2019-10-13 2019-10-02 2019-09-26 2019-09-20 2019-09-19 2019-09-13 2019-09-09 2019-09-02 2019-08-22 2019-08-20 2019-08-16 2019-08-11 2019-08-10 2019-05-27 2018-12-29 2018-12-19 2018-12-16 2018-12-02 2018-07-25 2018-05-25 2018-03-24 2018-01-31 2018-01-20 2017-11-29 2017-10-27 2017-06-26 2017-02-14 2015-12-18 2014-12-11 2014-05-27 2009-09-29 2004-10-30

obit_dod 2019-10-20 2019-10-13 2019-10-02
2019-09-20 2019-09-19 2019-09-13 2019-09-09 2019-09-02 2019-08-22 2019-08-20 2019-08-16 2019-08-11 2019-08-09
2018-12-29 2018-12-19 2018-12-16
2018-07-25
2018-03-24
2017-11-29
2017-06-26 2017-02-14 2015-12-18 2014-12-11
2004-10-30

Exhibit B, Page 38

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 39 of 352 Pageid#: 942

voter_id

lname

919001742 B

170803899 B

919587270 B

132169679 B

919076995 B

307050127 B

808005309 B

303008698 B

919403250 B

89610071 B

303016242 B

354072250 B

804016835 B

919650711 B

307043771 B

502006228 B

301051757 B

46423152 B

22628777 B

121008057 B

182503031 B

601009196 B

204011484 B

917482422 B

917440319 B

515025263 B

606030799 B

401004857 B

203009939 B

401018399 B

613012260 B

221003445 B

302030405 B

fname SUSAN BETTY SHIRLEY MICHAEL MICHAEL ROBERT THERESA BRUCE WILLIAM ANNA KAREN CLIFTON KATHLEEN ROBERTA PATRICIA SAM ROBERT SANDRA THOMAS MARY NANCY ALICE M NANCY RANDOLPH CAROLYN ROBIN LEWIS RUBY CHARMIE WELFORD GORDON RICHARD LOIS

dob 1948 1943 1939 1944 1947 1936 1946 1930 1930 1939 1945 1918 1930 1943 1937 1931 1941 1947 1947 1920 1941 1926 1941 1947 1947 1960 1926 1926 1926 1947 1936 1929 1923

date_registered 2000-12-11 2016-12-02 2003-09-06 2008-10-06 2001-04-05 2001-09-19 1968-06-06 1987-09-10 2002-09-27 2008-07-17 1986-09-25 2013-10-08 1987-08-28 2003-11-17 1984-09-10 1991-10-05 1980-09-20 2016-05-18 2014-09-24 1955-11-28 2008-07-31 1970-10-01 1997-11-04 1996-04-30 1996-04-03 1992-04-04 1989-12-19 1949-06-24 1964-05-04 1978-05-04 1988-10-07 1985-07-19 1959-06-12

ssdi_dod 2003-08-18 1995-06-17
2020-01-12 2019-09-03 2018-03-19 2019-01-09 2018-12-09 2018-08-03 2019-10-02 2017-05-31
2016-06-09

obit_dod 2003-08-18
2019-10-19 2019-10-13 2019-10-11 2019-09-11 2019-08-24 2019-08-23 2019-08-23 2019-08-16 2019-08-04 2018-12-31 2018-11-28 2018-11-07 2018-01-22 2017-12-14 2016-10-29 2016-10-17
2019-09-03
2019-09-03 2019-08-12
2018-12-09
2019-10-02 2019-08-15 2017-05-31 2019-10-19 2016-10-30 2019-08-01

Exhibit B, Page 39

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 40 of 352 Pageid#: 943

voter_id

lname

503023708 B

305029235 B

611024065 B

1062095 B

102028496 B

607026458 B

304035846 B

917368277 B

403024422 B

440358109 B

604017791 B

602000023 B

508023710 B

201008481 B

918542292 B

501023325 B

224001911 B

223001911 B

105147626 B

919988475 B

221025111 B

8340649 B

920139147 B

308007297 B

701024416 B

608031066 B

121017463 B

627817708 B

702011303 B

709008381 B

310040018 B

918348153 B

798861747 B

fname EMILIE ELEANOR JOSEPH HELEN PETE MARY FAYETTE ELMO WILMA ELEANOR HOWARD CLARENCE ROBERT DOUGLAS MARJORIE EVELYN JAMES BARBARA BRETT BETTY CATHERINE CHRISTOPHER LILLIAN ANGELA VIVIAN RUTH JEAN JOHN MOLLY WILLIE GERALDINE MAUDIE THOMAS

dob 1930 1938 1935 1929 1931 1943 1944 1938 1926 1934 1954 1953 1948 1945 1949 1922 1942 1947 1994 1935 1930 1999 1921 1934 1955 1923 1921 1938 1933 1939 1936 1936 1946

date_registered 1951-07-17 1988-09-07 2000-06-05 2012-02-13 1992-07-05 1973-10-06 1980-09-10 1995-10-10 1995-10-03 2016-02-08 1972-03-09 1971-07-30 1991-08-06 1987-10-03 1999-07-16 1944-07-23 1985-10-05 1985-10-05 2012-10-02 2004-10-04 1992-03-16 2017-01-20 2005-07-28 1986-06-30 1991-01-10 1968-05-02 2001-04-09 2008-05-06 1958-05-24 1972-06-02 1974-10-05 1998-09-23 2019-07-09

ssdi_dod 2019-08-14
2019-03-12 2020-01-15
2019-08-26 2019-12-27 2019-12-13 2019-10-23 2019-10-19 2019-09-16 2019-08-09 2019-07-26 2018-12-23 2018-10-31 2018-02-07 2016-10-24 2014-01-09
2019-10-17 2019-03-30 2017-06-30 2018-03-11 2019-10-26 2018-12-17 2018-09-02 2018-05-02 1991-08-24
2018-03-08 2019-07-08

obit_dod 2019-08-14 2016-11-30 2018-12-21
2017-10-22 2019-08-26 2019-12-27
2019-10-23
2019-09-16 2019-08-09 2019-07-27 2018-12-23 2018-10-31 2018-02-07 2016-10-24
2019-10-02 2018-08-12
2018-03-11 2019-10-26 2018-12-17
2018-05-02
2017-07-24 2018-03-08 2019-07-08

Exhibit B, Page 40

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 41 of 352 Pageid#: 944

voter_id

lname

307014096 B

918101701 B

728374082 B

906023070 B

507008079 B

203007085 B

205020666 B

304015260 B

305031691 B

412004186 B

918521859 B

228002466 B

917042804 B

917344461 B

107023856 B

918638562 B

946549337 B

108001835 B

225018702 B

229017117 B

103026512 B

707002538 B

917307463 B

607010257 B

504015788 B

918311533 B

405026267 B

502026285 B

609022602 B

5012981 B

603005304 B

604032785 B

705009009 B

fname CHARLES WILLIAM JOSEPH JOHN PAUL CAROLYN MARTIN CHARLES RICHARD HENRY PHILIP DANIEL ROBERT EDNA JOYCE MARJORIE BARBARA CHARLES SHELDON DAVID BARRIE JERRY RICHARD MARY C ROBERT JOHN ESTHER GERTRUD GERALDINE ARCHIE JAMES CAROL LEE

dob 1924 1948 1926 1928 1944 1952 1925 1939 1929 1939 1935 1934 1932 1924 1936 1924 1940 1934 1954 1941 1945 1947 1947 1941 1947 1942 1923 1925 1936 1935 1944 1952 1927

date_registered 2002-09-12 1997-09-21 2014-06-13 1964-05-01 1984-09-29 1983-10-08 2006-09-26 1984-10-03 1973-10-02 1991-11-06 1999-06-08 1964-09-10 2005-09-02 1995-09-27 1976-03-16 1999-11-30 2008-10-06 1968-06-06 1972-10-06 1996-08-09 1979-09-27 1977-10-05 1995-08-09 1978-01-31 1974-03-01 1998-08-03 1971-04-09 1969-09-15 2005-01-20 2012-09-14 1983-02-23 1980-09-23 1980-07-25

ssdi_dod 2019-11-18 2017-12-28 2020-01-01
2019-09-28 2018-12-04 2018-12-03 2019-04-19 2020-01-21 2018-12-13
2019-08-16 2018-07-19 2015-02-05 2018-12-23 2020-01-20 2019-10-12 2018-01-08 2019-09-14 2014-11-13 2019-12-26
2019-12-19 2019-10-01
2018-12-02
2020-01-15 2018-02-25 2019-12-13 2019-07-09

obit_dod 2019-11-18
2017-10-10 2019-09-28 2018-12-04 2018-12-03 2019-04-19
2018-12-13 2019-10-04 2019-08-16 2018-07-19 2015-02-05 2018-12-23
2019-10-12
2019-12-26 2019-10-11 2018-12-31
2019-10-01 2016-05-09 2019-05-31 2018-12-02 2019-08-06
2019-12-13 2019-07-09

Exhibit B, Page 41

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 42 of 352 Pageid#: 945

voter_id

lname

917621441 B

615772622 B

917972962 B

118306720 B

507009614 B

446468600 B

513008329 B

28005720 B

347590320 B

918583411 B

106018179 B

918655273 B

23008564 B

702008851 B

910003677 B

918825433 B

405003101 B

918451079 B

121449878 B

918488999 B

919500376 B

106018453 B

682756186 B

902010103 B

808015033 B

226019727 B

322519153 B

45496989 B

919017750 B

311010292 B

11002734 B

57240765 B

809009198 B

fname DONNA HYLAS DAVID SHARON MARGUERETTE DANIEL BEVERLY THELMA NORMAN SOLOMON PAUL DONALD ELLEN WILLIAM KENNETH WILLIAM MICHAEL JERRY GENE ROBERT ALVIS LYNDA MILDRED CARLEASE WILLIE ROGER SUE HELEN ALBERT WALTER BARBARA VINCENT ALICE

dob 1965 1923 1945 1943 1945 1966 1941 1938 1956 1949 1946 1948 1939 1943 1957 1940 1943 1949 1946 1966 1967 1952 1944 1926 1937 1937 1922 1932 1962 1943 1938 1945 1941

date_registered 1996-08-28 2010-07-29 2003-03-20 2010-05-21 1983-06-01 2016-01-28 1990-10-05 1980-09-09 2016-10-21 2007-02-12 1972-08-12 2000-08-16 1964-07-31 1964-09-30 1992-09-29 2000-06-27 1979-05-11 1999-03-08 2011-04-21 2000-03-23 2004-11-29 1986-09-24 2009-03-30 1951-10-06 2000-08-03 1998-12-14 2012-08-27 2009-07-16 2001-01-09 1970-09-26 1989-11-28 2014-07-01 2002-06-11

ssdi_dod 2018-10-20 2019-07-15 2018-01-10 2019-12-18 2018-07-09 2017-07-20 2018-12-16 2017-04-19 2018-12-17 2018-02-15 2019-10-28 2019-08-19 2019-06-29 2019-05-20 2018-07-23
2016-10-09 2018-06-30
2018-11-12 2019-08-17 2019-04-30 2019-12-14 2019-10-14
2018-06-08 2019-12-03 2019-05-15 2016-09-07 2014-11-08
2018-02-27

obit_dod 2018-10-20
2019-12-18 2018-07-09 2017-07-20
2017-04-19 2018-12-17
2019-10-28 2019-08-19 2019-06-29 2019-05-20
2019-10-08 2016-10-09 2018-06-30 2019-10-25 2018-11-12 2019-08-17
2019-12-14 2019-10-14 2018-12-08 2019-08-21 2018-06-08 2019-12-03 2019-05-15 2016-09-07 2014-11-08 2019-07-09 2018-02-27

Exhibit B, Page 42

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 43 of 352 Pageid#: 946

voter_id

lname

917977897 B

707004498 B

918291291 B

504019904 B

917611361 B

917672396 B

95168586 B

204009981 B

306021419 B

918909298 B

707010879 B

917783669 B

301055299 B

22012449 B

133016981 B

806017277 B

707014739 B

83488508 B

402010995 B

703002755 B

275733602 B

806000031 B

601003823 B

920261341 B

508009616 B

519358587 B

79450141 B

302024591 B

610001096 B

908015661 B

919250201 B

918205598 B

503013728 B

fname PAUL LINDA BERTHA RAYMOND TERRY GERALD TIMOTHY MARGARET AUBREY HARRY JOHN FLORENCE DAVID DORCAS JENNIFER ELVERA ARLEE RONALD JOHN RUTH PHILLIP SARAH GERALDINE ROBERTA CARLOTTA JONATHAN ROBERT NANCY ROBERT FRANCES GLORIA ELMER DAVID

dob 1954 1947 1907 1919 1946 1932 1958 1939 1942 1935 1938 1930 1935 1942 1958 1925 1938 1961 1938 1938 1954 1922 1925 1934 1949 1967 1934 1947 1938 1921 1931 1936 1951

date_registered 1997-04-24 1983-10-04 1998-06-30 1948-05-10 1997-03-04 1996-09-20 2016-09-08 1974-09-30 1996-12-26 2000-09-13 1982-11-03 1996-10-07 1993-03-20 1987-09-30 1998-04-04 1968-10-05 1966-10-08 2012-01-17 1996-10-07 1983-08-13 2016-11-21 1994-07-14 1984-10-01 2006-03-08 1974-09-20 2007-09-05 2012-03-16 1976-03-04 1988-08-22 1957-07-10 2001-11-07 1998-03-02 1980-01-12

ssdi_dod 2019-10-17 2018-12-24 2000-04-22
2019-11-23
2017-12-20 2020-01-24
2018-06-04 2019-04-30 2018-12-08 2018-06-04 2019-11-05 2019-11-02 2019-10-21 2019-08-15 2018-12-10
2018-01-10 2015-03-29 2020-01-20 2020-01-01 2019-10-20 2018-06-28 2019-12-17 2019-09-06
2019-12-10 2019-08-30 2019-08-14 2014-05-08

obit_dod 2019-10-17 2018-12-24 2000-04-22 2019-10-12
2016-12-15 2017-12-20
2019-10-31 2018-06-04 2019-04-30
2018-06-04 2019-11-05
2019-10-21 2019-08-15
2019-03-29 2019-06-16
2015-03-29
2019-10-20 2018-06-28
2019-09-06 2019-11-24
2019-08-14

Exhibit B, Page 43

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 44 of 352 Pageid#: 947

voter_id

lname

305002031 B

918968198 B

917123282 B

201014182 B

711023385 B

206017449 B

694169274 B

18090745 B

917015040 B

604033919 B

124017913 B

918112595 B

919945061 B

918854320 B

106019654 B

908021326 B

32752662 B

153828323 B

25007370 B

106005514 B

45710159 B

919601293 B

505009734 B

917747931 B

643160601 B

405016597 B

502022483 B

225007493 B

27020243 B

706005127 B

202031010 B

274058881 B

755381241 B

fname BENJAMIN DELLA MARY DONALD JEANNE FRED VIOLET FRANCES PATRICK JOSIE JANE ESTHER SADIE HERSCHEL KENNETH GORDON ELAINE DEBORAH JAMES EDMUND MARIA ETHEL LEE EVANGELINE AVERIA MILDRED JACQUELINE WANDA ALBERT EARNEST KEVIN BOBBY HELEN

dob 1941 1930 1928 1936 1946 1943 1930 1951 1945 1916 1921 1932 1933 1920 1921 1951 1942 1945 1939 1927 1969 1945 1922 1935 1970 1941 1938 1938 1945 1931 1959 1935 1932

date_registered 1983-10-05 2000-10-10 1994-06-15 1983-09-30 1991-09-17 2004-08-20 2018-10-12 2012-09-19 1993-09-04 1983-09-21 1946-11-14 1997-09-27 2004-10-04 2000-08-21 1971-10-02 2004-07-01 2008-05-08 2018-11-07 1971-08-09 1967-10-07 2013-01-03 2003-09-24 1947-06-11 1996-10-07 2008-10-03 1984-10-06 1972-09-28 1972-03-31 2002-09-03 1956-07-19 1998-01-06 2015-03-18 2013-12-13

ssdi_dod 2019-12-18 2019-12-06 2019-12-03 2019-12-03 2019-11-20 2019-11-15 2019-10-21 2018-02-03 2016-06-24 2004-07-27
2019-10-20
2018-12-08
2019-02-18
2019-09-16 2017-03-07 2016-10-08 2016-08-09 2004-03-10 2019-12-20 2019-09-11 2019-12-22 2019-12-09 2019-11-14 2019-10-01 2019-09-30 2019-08-26 2018-03-04

obit_dod 2019-12-18 2019-12-06 2019-12-03 2019-12-03
2019-11-15 2019-10-21
2016-06-24
2018-12-21 2018-01-09 2019-10-20 2019-10-07 2018-12-08 2019-08-12
2018-12-27 2019-09-16 2017-03-07 2016-10-08 2016-08-09
2019-12-20 2019-09-11
2019-12-09 2019-11-14 2019-10-01
2019-08-26 2018-02-28 2016-07-30

Exhibit B, Page 44

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 45 of 352 Pageid#: 948

voter_id

lname

302051766 B

226002935 B

917402062 B

918203084 C

405015566 C

321736569 C

221007494 C

707021757 C

919331474 C

10007559 C

232007196 C

917127857 C

917805271 C

918383179 C

443472407 C

815323328 C

918616441 C

917522143 C

901025566 C

362849178 C

158492224 C

608029410 C

210220479 C

312520552 C

204018056 C

293524117 C

768518697 C

920220547 C

917012047 C

918343081 C

701016372 C

266160714 C

25366811 C

fname SUZANNE NELLIE MABLE ALVIN CATHERINE GARLON AMADEO PLATO ALFRED REGINA LOUIS ELENA BONNIE ROBERT GLENNA GERALD MARIA MARIANITA NORMA SALVATORE ALFRED LEWIS ANNA CARL LINDA GEORGIA BARBARA FRANCES DENNIS ARNOLD MARGARET DOLORES FRANCES

dob 1933 1939 1919 1943 1943 1948 1942 1929 1932 1944 1931 1944 1947 1947 1928 1950 1945 1933 1936 1942 1944 1945 1991 1975 1946 1943 1924 1939 1946 1937 1925 1925 1921

date_registered 1964-05-02 1984-09-12 1996-03-07 1998-02-26 1975-09-30 2008-10-06 1997-03-26 1956-08-24 2002-05-24 1992-10-01 1996-04-08 1994-06-15 1996-11-06 1998-11-16 2011-08-01 2008-10-06 1999-11-03 1996-06-12 1984-10-06 2015-10-01 2009-11-04 1984-02-11 2012-05-11 2017-04-24 1998-07-02 2015-09-16 2008-11-10 2005-11-30 1999-09-27 1998-09-21 1947-08-26 2019-02-20 2008-05-15

ssdi_dod
2017-12-16 2017-08-27 2018-03-10
2018-12-05 2019-10-27 2019-09-26 2018-01-19 2019-09-14 2018-12-17
2019-12-01 2019-11-16 2015-04-10 2018-06-02 2014-12-03 2019-11-06
2017-04-15
2019-10-14 2014-11-14 2018-11-12 2019-09-11 2017-06-04
2019-09-11 2019-11-20 2019-08-16 2018-04-29

obit_dod 2018-09-24 2017-12-16 2017-08-28
2019-09-12
2019-10-27 2019-09-26 2018-01-20 2019-09-14 2018-12-17 2019-10-05 2019-12-01 2019-11-16 2015-04-10
2014-12-03 2019-11-06 2015-04-20
2018-03-02 2019-10-14
2018-11-12 2019-09-11 2017-06-04 2018-12-20
2019-08-16 2018-04-29 2019-09-11 2017-09-18

Exhibit B, Page 45

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 46 of 352 Pageid#: 949

voter_id 918350433 C 107024185 C
58788394 C 508003137 C 704001829 C 360731058 C
28089300 C 210000232 C 402019086 C
25044712 C 108003124 C 918348603 C
9720547 C 919951319 C 225000281 C 302040876 C 917346099 C 801014806 C 172965817 C 903002528 C 126075332 C 919557541 C 509028768 C
9845556 C 907006159 C 919117647 C 806009334 C 203003721 C 259221592 C 919782589 C 616441668 C 605004585 C 615069650 C

lname

fname RICHARD BETTY RHYNE JEAN ROBERT RUTH WAYNE GARY SALLY ROBERT JUSTINIANO SAM KATHLEEN RONALD PEGGY ROBERT CECIL MARTHA JAMES VIRGINIA LAWRENCE JOHN LOUELLA LORETTA JAMES PATRICIA BERTIE IRENE DIA ROGER ROBERT LAURA ELISHA

dob 1937 1943 1988 1925 1946 1936 1964 1936 1929 1919 1936 1926 1943 1941 1931 1931 1949 1937 1941 1932 1930 1943 1938 1938 1941 1956 1928 1930 1975 1959 1962 1923 1942

date_registered 1998-09-28 1993-06-03 2016-03-08 1992-03-31 1983-09-10 2011-07-05 2017-11-14 1992-09-28 2006-11-27 2012-11-07 1979-10-05 1998-09-28 2017-10-16 2004-10-04 1984-10-04 1984-03-14 1997-03-03 1967-05-27 2016-07-20 1972-10-05 2019-08-28 2003-07-17 1964-09-26 2017-02-27 1992-09-21 2004-02-13 1968-06-04 1983-09-09 2009-01-20 2004-06-14 2012-11-07 1990-03-30 2012-08-10

ssdi_dod
2019-08-18 2019-03-14 2020-01-23 2019-12-04 2018-01-30 2019-08-19 2018-10-18 2017-08-11 2015-01-30 2019-11-23
2019-10-01 2020-01-13 2019-12-16 2019-12-07 2019-12-04 2019-11-28 2019-11-21 2019-11-08 2019-10-25 2019-10-24 2019-10-22 2019-05-26 2018-12-09 2018-12-03 2018-05-28 2018-05-23 2017-12-31 2017-12-05 2016-08-13 2014-10-02 2014-04-13

obit_dod 2017-04-11
2019-03-14
2019-12-04
2018-10-18 2017-08-11
2019-11-23 2019-09-04 2019-10-01
2019-12-16 2019-12-07
2019-11-28
2019-11-08 2019-10-25 2019-10-24 2019-10-22 2019-05-26 2018-12-09
2018-05-28 2018-05-23 2017-12-31

Exhibit B, Page 46

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 47 of 352 Pageid#: 950

voter_id 904000575 C 919192553 C 917723047 C 919000830 C 104005884 C 385998275 C 803009335 C 309027733 C 503022485 C 801010853 C 210026186 C 918191880 C 255600580 C 919835979 C 919353890 C 917734904 C 206357452 C 307001455 C 711014461 C 112026685 C
6372500 C 489505721 C 919977359 C 223007496 C 917540859 C
32244847 C 208014792 C 301013479 C 174428502 C 919330338 C 919796299 C 918125490 C 243614840 C

lname

fname WILLIAM ALLIE JAMES CHARLOTTE MARK SHIRLEY LAURA GEORGE HILBERT EVA WILLIE PAUL CECIL HARRY LEONOR ADELAIDA RAUL PATRICIA BRAXTON CHARLES WAYNE BELINDA ISAAC MAURICE ROBERT DOLPH JEAN MARY MARY EDWIN EDWARD JOSEPH RANDOLPH

dob 1941 1946 1942 1925 1928 1935 1927 1931 1934 1929 1930 1937 1944 1945 1946 1928 1941 1945 1934 1930 1947 1956 1957 1935 1946 1942 1940 1922 1939 1932 1953 1937 1948

date_registered 2001-09-19 2001-09-25 1996-10-04 2000-12-08 1976-03-29 2015-09-17 1971-09-27 2002-10-07 1968-10-03 2003-08-26 2000-10-07 1998-01-28 2008-07-25 2004-08-12 2005-09-29 1996-10-07 2007-08-07 1976-09-01 1991-10-05 1989-05-01 2013-09-03 2009-07-02 2004-10-04 1972-09-14 1996-09-24 2010-12-20 1976-10-02 1972-06-15 2012-10-03 2002-05-13 2004-06-26 1997-10-03 2012-10-08

ssdi_dod 2010-12-18
2020-01-17 2019-09-02 2018-04-28 2018-04-06 2019-04-04 2019-07-08 2019-10-11 2018-12-25 2018-11-02 2018-05-17 2019-11-03 2017-12-21 2018-04-12 2017-10-29 2019-08-08 2019-09-12 2018-02-11

obit_dod
2019-10-19 2019-10-15 2019-10-09 2019-10-05 2019-10-03 2019-08-30 2019-05-09 2018-12-21 2018-12-14 2018-11-19 2018-04-02 2016-10-01
2019-09-02
2016-10-03 2019-04-04 2019-07-08 2019-10-01 2018-12-25
2018-05-17
2017-12-21 2019-10-01 2018-04-12 2017-10-29 2019-08-08 2019-09-12 2018-02-11 2019-09-08

Exhibit B, Page 47

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 48 of 352 Pageid#: 951

voter_id 127015674 C 224009262 C 226022198 C 606030149 C 226008699 C
66459102 C 23012130 C 130002427 C 36187035 C
8005047 C 602031075 C 380862588 C 703028561 C
3003017 C 918827840 C 302016251 C
19677135 C 81510178 C 917919246 C 918653541 C 802000655 C 918147561 C 918327285 C 918690804 C 919107552 C 402024277 C 905016805 C 24005501 C 107001965 C 679385309 C 920371153 C 704381078 C 538858066 C

lname

fname MARY HARRY KATHERINE VICTOR KENNETH PATRICIA DOREEN CAROLYN ELIZABETH MARIE LINDA ANNIE ALVIN GLORIA EARNEST LEE ADRITH HUGH DONALD DAVID JAMES HELEN WILLIAM THOMAS ARTHUR ANNE PHYLLIS MARTHA NORMAN OTHA WILLIAM JOSEPH DAVID

dob 1930 1947 1931 1920 1926 1951 1920 1943 1938 1939 1945 1933 1947 1945 1936 1929 1948 1934 1934 1942 1935 1924 1923 1936 1946 1924 1926 1942 1929 1941 1943 1951 1933

date_registered 1976-08-17 1976-03-13 1952-06-14 1966-04-04 1953-10-03 2010-08-03 1957-11-21 1991-09-26 2008-06-25 1977-10-07 1966-10-05 2007-02-16 1991-11-06 1983-03-15 2000-07-20 1979-10-04 2010-01-28 2014-06-11 1999-07-22 1999-12-27 1972-06-29 1997-11-05 1998-08-28 2000-03-01 2001-05-15 1952-08-07 1972-09-07 1980-10-02 1964-05-08 2008-04-10 2006-10-04 2008-02-13 2008-09-16

ssdi_dod 2014-06-02 2019-11-14 2019-11-19 2019-11-07
2019-03-25 2013-12-28 2009-01-13 2014-06-15 2019-09-27 2020-01-04 2019-12-24 2019-12-16
2019-09-16 2019-08-01 2019-10-18
2019-10-24 2019-10-16
2004-11-03 2019-10-18
2019-11-18 2019-11-26 2019-09-09
2019-08-14 2019-06-10 2018-03-03 2018-02-02 2019-11-04

obit_dod 2014-06-02 2019-11-14 2019-11-19 2019-11-07 2018-01-30
2009-01-13 2014-06-01 2019-09-27
2019-12-16 2019-09-21 2019-09-16 2019-08-01 2019-10-18 2019-08-01 2019-10-24 2019-10-16 2018-02-15 2004-11-03 2019-10-18 2018-09-20 2019-11-18 2019-11-26
2019-09-04
2019-06-10 2018-03-03
2019-11-04

Exhibit B, Page 48

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 49 of 352 Pageid#: 952

voter_id 307005016 C 918513948 C 407030833 C 601005669 C 508012123 C 515004342 C 917716284 C 401011602 C 805000961 C 507008333 C
27007372 C 920145143 C 402016903 C 295286659 C 157583433 C 605028176 C 602000026 C 119942804 C 707014743 C 211019297 C 406015419 C 505028011 C 505009396 C 611001003 C 107025898 C 919702863 C 103024610 C 609028907 C 906009132 C 244135082 C 917326268 C 919213880 C 223015021 C

lname

fname BERNARD BOBBY ELIZABETH WILLIAM JAMES JAMES ELIZABETH DAVID VIRGINIA WINNIFRED ALBERT SHELLI WALLACE PATRICIA SHIRLEY VIRGINIA JULIUS MARIELLA WANDA WILLIAM IRIS ROSETTA RAYMOND ROBERT JULIAN JOSEPH CHARLES NANCY LINDA JOYCE EDWARD MARY BOBBIE

dob 1934 1937 1932 1938 1939 1947 1946 1952 1940 1930 1949 1969 1935 1932 1950 1923 1935 1929 1929 1929 1926 1943 1930 1935 1947 1949 1939 1952 1940 1934 1928 1943 1933

date_registered 1968-10-05 1999-06-07 1964-09-30 1999-09-30 1989-11-27 1968-10-02 1996-09-28 2014-06-09 1976-10-02 1994-09-15 1988-02-02 2005-11-09 1964-08-29 2018-05-08 2016-08-26 1956-10-01 1968-10-05 2017-04-10 1980-09-08 1972-07-20 1952-04-29 1967-10-02 1951-09-22 1993-04-02 1972-10-07 2004-03-04 1988-10-07 1992-06-08 1980-10-04 2013-09-18 1995-09-15 2001-10-09 1988-02-06

ssdi_dod 2019-10-30 2019-09-17 2019-08-13 2019-07-22
2017-11-20
2019-12-19 2019-09-21 2019-07-10 2020-01-18 2019-10-25 2019-09-14 2018-07-08 2018-05-06 2018-04-10 2015-08-03 2019-12-09 2020-01-07 2019-12-31 2019-11-11 2019-11-10 2019-11-06 2019-10-24 2019-10-22 2019-10-16 2019-10-15 2019-10-05 2019-09-28 2019-09-24 2019-09-23

obit_dod 2019-10-30 2019-09-14 2019-08-13 2019-07-22 2019-10-14 2019-10-07 2016-01-18
2019-08-22
2019-09-21
2019-10-25
2018-07-08 2018-05-06 2018-04-10
2019-12-09
2019-11-06
2019-10-22
2019-10-15 2019-10-05 2019-09-28

Exhibit B, Page 49

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 50 of 352 Pageid#: 953

voter_id 601002838 C 504003638 C 917023375 C 897366930 C 121011364 C 502002910 C 477783647 C
98882813 C 706015856 C 602028753 C 918466449 C 601002988 C 606002383 C 129003214 C 919213033 C 615001213 C 918373420 C 606002661 C 801017282 C 402002087 C 904013686 C
23017236 C 82365161 C 221019574 C 201381404 C 919205912 C 919176986 C 27012687 C 919954257 C 917399687 C 309045596 C 919781284 C 602023200 C

lname

fname CHRISTOPHER WILLIS ELLEN MARSHALL LEON JOHN BILLY RUBIN GEORGE LILLY KENNETH JAMES WILLA JERRY DAVID VIRGIE CHERYL RONNIE ROBERTA CARL DAVID JAMES HELEN ROBERT ENOCH LILY GRACE KATHLEEN FRANK SHIRLEY MICHAEL CYNTHIA HERBERT

dob 1960 1936 1925 1943 1948 1946 1964 1944 1952 1921 1942 1943 1928 1959 1957 1926 1958 1946 1934 1947 1944 1945 1955 1938 1933 1922 1936 1930 1923 1945 1947 1984 1934

date_registered 1992-11-04 1992-09-17 1993-09-17 2008-10-06 1999-05-10 1976-09-27 2012-09-28 2009-05-11 1977-10-08 1956-09-20 1999-03-25 1981-03-03 1960-10-07 1998-09-15 2001-10-09 1991-08-31 2000-03-01 1972-07-06 1956-01-02 2001-12-06 1984-05-02 1992-09-17 2015-04-13 1992-09-30 2016-05-19 2001-10-05 2001-09-05 1997-12-02 2004-10-04 1996-02-27 1991-09-12 2004-06-11 1967-10-07

ssdi_dod 2019-09-14 2019-09-04 2019-07-05 2019-07-01 2019-06-28 2019-06-07 2019-05-15 2019-03-27 2019-03-02 2018-12-30 2018-06-23 2018-05-28 2018-02-11 2018-01-26 2017-07-30 2017-04-07 2014-09-03 2006-10-03
2019-12-03 2019-03-26 2019-12-16 2019-10-27 2005-01-10
2019-10-17 2018-12-30
2019-03-20 2019-08-26

obit_dod 2019-09-14
2019-07-05 2019-07-01
2019-06-07 2019-05-15 2019-03-27 2019-03-02 2018-12-30
2018-05-28 2018-02-11
2017-04-07
2006-10-03 2019-10-10 2019-10-02 2018-12-12 2019-12-03 2019-03-26
2019-05-09 2019-08-25 2019-10-17
2019-08-13 2019-03-01 2019-08-26

Exhibit B, Page 50

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 51 of 352 Pageid#: 954

voter_id 909010489 C 918500180 C 917494341 C 537979216 C 308030937 C 920128324 C 104005340 C 918914817 C 228000033 C 105004795 C
18824522 C 501001672 C 917504937 C 580494425 C 224012535 C 206011125 C 102798183 C 393636468 C 920141495 C 918978676 C 319992778 C 306019169 C 506014568 C 228008112 C 408027097 C
12425207 C 605032590 C 917310598 C 704017257 C 401022788 C 917322238 C 503010361 C 917071502 C

lname

fname HENRY JOHN RONALD JAMES DORIS ELEANOR ROBERT DAVID BILLY WILLIAM MILLIE TOOTSIE CAROL MARGARET MARY BLANCHE JESUS TIMOTHY CAROLYN BEATRICE SALVADOR MARY ORAN LOVY STEPHEN EVELYN OLA BILLY VIVIAN DAPHNE SHIRLEY BERTHA LEWIS

dob 1939 1943 1938 1934 1922 1932 1940 1963 1934 1927 1935 1935 1944 1931 1943 1934 1956 1961 1934 1940 1946 1922 1933 1940 1940 1922 1931 1946 1909 1928 1945 1927 1956

date_registered 1962-11-15 1999-05-10 2000-08-16 2009-05-11 1980-10-04 2005-07-07 1976-09-15 2000-10-02 1957-04-04 1976-09-25 2012-10-10 1991-10-01 1998-02-09 2012-06-13 1967-06-02 1955-12-13 2017-02-16 2008-10-06 2005-08-02 2000-11-08 2012-04-09 1996-12-13 1997-06-11 2000-03-01 1996-03-20 2014-09-17 1975-04-04 1995-08-17 1967-05-03 2003-12-10 1995-09-11 1963-09-24 1994-02-09

ssdi_dod 2019-12-02 2019-08-15 2019-12-12 2019-08-26 2018-05-03 2019-09-27 2019-10-08 2014-11-11 2019-11-14 2019-09-09
2019-11-14 2019-12-07
2019-11-18 2019-10-26 2018-12-25 2019-05-11
2014-11-07 2018-08-14
2018-06-02 2020-01-06 2019-02-15
2019-11-25 2019-10-25 2015-04-10
2018-10-31

obit_dod 2019-12-02 2019-08-15 2019-12-12 2019-08-26 2018-05-03 2019-09-27 2019-10-08
2019-11-14 2019-09-09 2019-12-06 2019-11-14 2019-12-07 2017-01-10
2018-12-25
2016-12-25
2018-12-29 2018-06-02
2019-09-13 2019-11-25 2019-10-25
2019-09-20 2019-04-20 2018-12-21 2018-10-31

Exhibit B, Page 51

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 52 of 352 Pageid#: 955

voter_id 308032553 C 904008132 C 919290725 C 105011173 C 506028527 C 910021333 C
5505272 C 306035559 C
24010227 C 229018167 C 918897585 C 206517032 C 303014744 C 307020424 C 197093241 C 738759996 C 919598063 C 224000655 C 604026100 C 602026100 C 703000397 C 435087350 C 703017487 C 704017487 C
29006616 C 917442666 C 918378073 C 711017841 C 121005157 C 806011276 C 171902390 C 128009504 C 507003366 C

lname

fname RICHARD CLARK JOHN ALICE PAUL NELLE BRYAN PATRICIA CHESTER DONALD FRANCES JOHN DOLORES CHRISTINE ISMAEL MARY CONSTANCE JEAN BETTY BERNARD ROSS DELORES JAMES VIOLET CAROLYN BEVERLY LUCY EDWARD EVELYN GENE TOBEY ROBERT CHRISTINE

dob 1926 1933 1933 1956 1925 1914 1989 1919 1943 1947 1954 1933 1941 1957 1945 1925 1922 1937 1931 1936 1937 1935 1933 1944 1942 1949 1929 1946 1938 1928 1943 1935 1928

date_registered 1968-06-06 1974-10-02 2001-03-19 1993-08-14 1946-05-10 1992-10-03 2015-11-09 1989-04-22 1984-03-31 1996-12-30 2000-09-09 2017-06-28 1996-09-13 1993-09-18 2016-03-18 2007-03-15 2005-04-26 1958-04-18 1953-10-03 1959-07-31 1977-10-08 2016-02-08 1979-05-12 1968-10-02 1988-08-20 1996-04-03 2002-11-06 2004-01-12 1987-10-02 1954-10-02 2015-10-13 1964-09-28 1951-04-06

ssdi_dod
2016-03-16 2018-12-22 2019-10-06 2018-01-12 1995-01-25 2019-02-27 2002-01-23
2018-12-01 2019-10-29 2019-10-21 2018-02-27 2019-04-13 2019-11-08 2019-09-20 2019-12-24 2019-10-07 2018-12-28
2020-01-08 2019-10-22 2019-10-13 2020-01-15 2020-01-15 2019-12-28 2019-12-25 2018-12-11 2018-12-08
2019-11-24

obit_dod 2016-11-13
2018-12-22 2019-10-06
2019-01-15 2019-10-22 2018-12-01 2019-10-29 2019-10-21 2018-02-27
2019-11-08 2019-09-20 2019-12-24 2019-10-07
2019-10-04
2019-10-13
2019-12-28
2018-12-11 2018-12-08 2019-09-21
2018-12-11

Exhibit B, Page 52

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 53 of 352 Pageid#: 956

voter_id 206015403 C 203031845 C 702008391 C 148666773 C 302025098 C 267327077 C 822942822 C 902025422 C 513002335 C 108513835 C 382048660 C 920375723 C 917722975 C 284068404 C 354388737 C 502008336 C 222003798 C 917372486 C 501003368 C 506014988 C 203010457 C 470126826 C 106017217 C 918075402 C 919235269 C 917718920 C 354684524 C 919793959 C 902005506 C 203016822 C 604005671 C 225008114 C 211029668 C

lname

fname CALVIN CHRISTOPHER YOGESH REMEDIOS MARIA CARMEN ROBERT LINDA HERMAN KENNETH HOMER KWI JUNG-JUNG ONE TERRY JIMMY JOAN BARBARA AUDREY JAMES CHARLES SCARLETT CARL LETA HARRY NELSON JEANINE JUDY WILLIAM JOAN ROBERT VELMA WILLIAM DAVID

dob 1929 1957 1950 1947 1932 1933 1955 1947 1948 1966 1934 1941 1925 1946 1947 1932 1939 1930 1929 1938 1951 1943 1928 1939 1938 1927 1951 1940 1936 1945 1939 1928 1953

date_registered 1991-09-13 1992-10-03 1992-02-21 2016-10-03 1985-10-05 2012-05-16 2010-05-14 1985-09-07 2002-07-25 2010-06-16 2010-03-03 2006-10-06 1996-10-04 2010-03-10 2007-11-16 1987-01-07 1960-05-20 1995-10-10 1966-05-07 1989-09-27 1988-01-14 2016-11-28 1968-10-01 2005-01-10 2001-11-07 1996-10-04 2019-08-27 2005-08-30 1975-09-13 1987-07-02 1966-10-03 1968-09-27 1992-09-18

ssdi_dod 2018-12-04 2018-01-28 2018-10-23 2018-07-01 2017-06-10 2012-07-20
2018-02-08 2018-01-04
2019-11-29 2019-08-28 2019-08-17
2019-08-05 2019-11-27 2019-09-16 2018-12-08 2018-07-31
2019-11-15 2017-04-15
2020-01-25 2019-10-05 2019-12-18 2019-10-02 2019-07-16 2018-12-31 2018-12-25 2019-11-14 2019-12-16 2018-03-25

obit_dod
2018-10-23 2018-07-01
2012-07-20 2015-06-29 2018-02-08
2015-12-13 2019-11-29
2017-02-22 2019-08-05
2019-09-16 2018-12-08
2019-08-18 2019-11-16 2017-04-15 2014-11-08
2019-10-05 2019-12-18 2019-10-02
2018-12-31 2018-12-25 2019-11-14 2019-12-16 2018-04-01

Exhibit B, Page 53

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 54 of 352 Pageid#: 957

voter_id 402021162 C 919395525 C 919113959 C 308046516 C 918047272 C 705019698 C 919889927 C 920035665 C 240715455 C 920030712 C
44481532 C 21002098 C 14542007 C 427506243 C 21725840 C 917120419 C 917369929 C 919358249 C 223024598 C 326393696 C 306027533 C 917296683 C 121014777 C 206002174 C 461915305 C 917813470 C 225010248 C 523670274 C 205002012 C 207002011 C 226009004 C 904010998 C 917308217 C

lname

fname MARGARET ANNA HORACE ATAULLAH SHUJA EDGAR DAVID CAROLYN CHINGHAI MARION SHIU PHYLLIS CARLTON ALTHEA CAROLYN BARBARA STEPHEN RAFAEL JANICE VENKATA ARTHUR BARBARA HELEN FLOYD JACK ROBIN MARY SHARON PEARLIE JUDITH ESTHER REBA ROBERT

dob 1942 1984 1934 1933 1940 1925 1933 1949 1929 1947 1930 1934 1950 1933 1950 1944 1948 1951 1945 1947 1929 1946 1926 1918 1943 1951 1949 1968 1927 1943 1927 1924 1951

date_registered 2006-12-04 2002-09-17 2001-06-13 1991-04-10 1997-07-23 1987-12-05 2004-09-16 2004-12-16 2017-08-28 2004-12-06 2016-11-29 1980-06-02 2017-09-05 2012-09-19 2009-11-23 1994-05-13 1995-10-05 2002-07-15 1994-08-22 2015-04-02 1956-08-28 1995-06-27 1960-08-04 2003-11-24 2008-03-06 1996-11-06 2003-07-03 2011-08-22 1956-05-11 1987-10-03 1980-09-27 1960-10-03 1995-08-10

ssdi_dod
2017-08-22 2019-07-29 2011-11-27 2018-04-30
2018-07-11 2019-08-21 2019-09-16 2020-01-24 2019-12-10
2019-01-09 2018-04-20 2015-10-28 2017-01-25 2018-12-25 2019-08-31 2019-08-17 2019-07-09 2019-07-18 2020-01-16 2019-12-24 2019-12-22 2019-12-20 2019-10-04 2019-09-02 2018-05-24 2018-04-23
2016-12-18

obit_dod 2019-03-13 2017-08-22
2019-09-17
2019-09-03 2019-01-09 2018-04-20
2017-01-25 2018-12-25
2019-08-17
2019-07-18
2019-12-22 2019-12-20 2019-10-04 2019-09-02
2018-04-23 2017-11-02 2015-02-04 2010-07-09 2016-12-18

Exhibit B, Page 54

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 55 of 352 Pageid#: 958

voter_id 307019171 C 808002508 C 402010816 C 209018208 C 308046953 C 504011982 C 122004198 C 604011042 C 918149162 C 597066813 C 917920568 C 918990249 C 405005370 C 307007935 C 605009514 C 147784877 C 123000251 C 919853868 C 209000966 C 101007907 C 919834572 C 177380736 C 404001381 C 218172419 C 919729646 C 108004233 C 918640709 C
68790858 C 1000839 C
919946448 C 701018468 C 804008890 C 919240056 C

lname

fname WESLEY VIRGINIA JOANNE MARC KING WILLIAM JOHN JOYCE DEREK ROSA DEBORAH FRANK JEWEL ANDREW O-SONG PARKASH JAMES BENJAMIN BELVA PAULINE MILDRED LINDA CLARA ROBERTA EARL MARIE MARGARET THELMA MILDRED CLEO WILLIAM BERNADETTE JACK

dob 1942 1923 1942 1961 1942 1929 1937 1933 1959 1948 1962 1930 1942 1940 1935 1926 1922 1977 1947 1924 1926 1949 1933 1945 1935 1937 1934 1926 1931 1924 1932 1946 1938

date_registered 2012-05-02 1955-12-30 1983-08-09 1997-11-24 1989-07-08 1956-07-09 2006-09-08 2003-09-02 1999-12-07 2007-05-03 1997-02-13 2000-11-27 1968-08-07 1986-08-21 1978-09-28 2010-07-13 1947-05-10 2004-08-23 1984-05-30 1964-10-01 2004-08-12 2007-08-16 1964-09-29 2016-10-21 2004-04-05 1991-10-05 1999-12-02 2015-07-14 1955-12-21 2004-10-04 2000-09-28 1996-03-02 2001-12-04

ssdi_dod 2019-12-20 2019-09-01 2020-01-20 2016-05-30
2019-12-07 2019-09-09 2018-12-27 2018-07-01
2018-11-13 2018-12-15 2018-01-24 2019-08-01
2018-06-23 2009-11-09 2018-06-03 2020-01-14 2018-12-13 2018-01-24
2019-08-13 2018-10-22 2019-10-14 2018-12-15 2019-09-27
2018-02-05 2019-06-20 2019-10-13 2017-11-20

obit_dod 2019-12-20 2019-09-01
2016-05-30 2016-03-10 2019-12-07 2019-09-09 2018-12-27 2018-07-01 2018-12-22
2018-12-15 2018-01-24
2018-07-09
2009-11-09 2018-06-03
2018-12-13 2018-01-24 2019-10-18 2019-08-23 2019-08-13 2018-10-22 2019-10-14 2018-12-15
2019-09-14 2018-02-05
2019-10-13 2017-11-20

Exhibit B, Page 55

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 56 of 352 Pageid#: 959

voter_id 339846868 C 302015271 C 919536804 C 224024613 C 405014902 C 144562742 C 707015148 C 507024839 C 918939816 C 902021811 C 169436428 C 151936528 C 917274774 C 226010827 C 917510605 C 920143110 C 269937298 C 709009263 C 207027102 C 701014468 C 603001633 C 701011124 C
92844040 C 904003356 C 144365554 C 401023809 C 223019084 C 414000652 C
13001749 C 221004163 C 603003825 C 706017650 C 226005967 C

lname

fname SUKONTHA JENNY TONY JEAN JULIA JOHN VICTOR NAOMI ROBIN ALLEN SANDRA ROCCO MARJORIE ROBERT DOLORES BEVERLY WILLIAM CARL FLOYD HELEN BRENDA NANCY ANNABELLE WILLIAM DONALD NELDA RUSSELL RAY STANLEY WILLIAM JERRY CHARLES GERTRUDE

dob 1951 1946 1962 1931 1939 1951 1954 1930 1953 1941 1945 1929 1933 1921 1930 1942 1942 1946 1938 1945 1942 1943 1922 1939 1934 1927 1946 1940 1946 1928 1948 1932 1935

date_registered 2008-08-07 1991-09-12 2003-06-16 1992-03-02 1979-07-16 2013-06-19 1992-09-28 1984-09-17 2002-01-14 1984-10-02 2015-12-10 2011-10-11 1995-04-26 1984-07-18 1996-06-12 2005-08-05 2007-11-06 2006-02-24 1971-09-28 1992-09-22 1990-02-16 1971-01-18 2018-04-10 1967-03-02 2014-03-19 1964-09-11 1981-11-24 2004-11-08 1992-09-14 1965-04-24 1975-01-31 1960-10-08 1968-10-04

ssdi_dod 2018-12-19 2019-05-23 2017-11-17 2019-11-26 2019-11-05 2019-06-03 2019-04-18 2018-11-21 2017-12-31
2017-06-07 2019-11-19 2017-11-28
2019-12-03
2018-07-06 2020-01-17 2020-01-08 2020-01-01 2019-12-20 2019-12-19 2019-11-25 2019-11-08 2019-10-31 2019-10-28 2019-10-10 2019-10-09 2019-10-05 2019-09-25 2019-09-08 2019-08-17

obit_dod 2018-12-19 2019-05-23
2019-11-27 2019-11-05
2019-04-18 2018-11-21 2017-12-31 2019-08-23 2017-06-07 2019-11-19
2019-09-16 2019-12-03 2017-07-05 2017-05-07 2018-07-06
2019-12-20 2019-12-19 2019-11-25 2019-11-08 2019-10-31 2019-10-28 2019-10-10
2019-10-05 2019-09-25 2019-09-08 2019-08-17

Exhibit B, Page 56

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 57 of 352 Pageid#: 960

voter_id 23010594 C
208009808 C 49235466 C
704011974 C 805010542 C
9007715 C 38524175 C 156181653 C 221002623 C 918914816 C
1807283 C 687442168 C 314334173 C 601022523 C 180855692 C
90353496 C 177748919 C 708022248 C 606014213 C 102020915 C 920322307 C 501409358 C 108010475 C 918329273 C
16003617 C 201012086 C 817821433 C 906021813 C 509004188 C 512185350 C 455267823 C 204011540 C 505007080 C

lname

fname EUGENE GARLAND WILLIAM VIVIAN DOROTHY BARBARA DAVID JASON JANICE EVELYN ODILIA SHAFFER LEE SHERMAN MARY LEE ELLA JILL CHARLES ROBERT ANTHONY CHARLES ROBERT JOHN LINDSEY LEWIS MARK ALLON EDWIN ELEANOR LESLIE DWIGHT HELEN TONEY LEONARD MARY

dob 1951 1928 1979 1932 1934 1940 1954 1978 1943 1946 1946 1943 1922 1933 1945 1940 1937 1948 1935 1948 1934 1948 1929 1975 1934 1940 1936 1939 1957 1941 1959 1938 1926

date_registered 1992-01-08 1955-12-31 2016-10-13 1982-10-02 1967-10-05 2016-04-27 2011-11-18 2008-10-06 1971-10-01 2000-10-02 2016-08-19 2008-06-03 2008-09-04 1964-10-02 2012-10-09 2012-01-13 2012-07-31 1984-10-05 1992-12-07 2005-11-16 2006-07-07 2012-10-08 1952-07-30 2004-08-19 1996-09-12 1970-05-12 2009-02-11 1993-09-14 1976-09-21 2008-10-06 2008-10-06 1996-09-19 1947-10-04

ssdi_dod 2019-07-24 2019-03-30 2019-03-04 2018-12-25 2018-12-03 2018-06-15 2018-05-25 2018-02-07 2018-01-06 2017-12-31 2017-01-30 2015-11-21 2011-09-09 2008-12-09
2019-11-30 2019-02-11 2018-12-13 2018-02-13 2017-12-13 2016-12-31 2016-12-03 2015-04-06 2014-03-11

obit_dod 2019-07-24 2019-03-30
2018-12-25 2018-12-03 2018-06-15 2018-05-25 2018-02-07 2018-01-06 2017-12-31 2017-01-30 2015-11-21
2008-12-09 2019-10-17 2019-09-09 2019-06-25 2018-12-13 2018-12-06 2018-08-18 2016-12-06 2016-04-01 2019-11-30 2019-02-11 2018-12-13 2018-02-13 2017-12-13
2015-04-06
2019-08-13 2018-12-07

Exhibit B, Page 57

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 58 of 352 Pageid#: 961

voter_id 26013413 C
919823208 C 804006420 C 918815064 C 509023001 C 918923423 C
12785753 C 9591834 C
412002821 C 511024544 C 602022466 C 902002176 C 502012248 C 482722064 C 223000294 C 920263540 C 508023534 C 917209288 C 918638039 C 908012375 C 204029505 C 226000295 C 919007581 C 302049267 C 401031469 C 280950256 C 339867823 C 513011297 C 101021187 C 917692063 C 701001841 C 706002548 C 210007517 C

lname

fname VELMA HARLEY CHASTINE SHIRLEY MARCELLA CARL GLORIA MARIE LOWELL ALBERT BRENARD LOUISE ERIC HERMAN PATSY SHEILA MARGARET HYE ISABELLE MARGUERITE BRUCE RICHARD DOROTHY HILDA EDNA EDDIE EDWARD HERSHEL CATHERINE ISABELLE SANDRA IRMA CHARLES

dob 1945 1946 1928 1938 1936 1943 1941 1932 1938 1936 1930 1926 1941 1937 1939 1953 1925 1952 1933 1921 1936 1945 1943 1927 1928 1952 1942 1949 1918 1930 1944 1942 1934

date_registered 1966-05-09 2004-07-29 1991-10-03 2000-07-05 1976-08-28 2000-10-05 2017-06-15 2012-10-03 1998-01-07 1988-09-02 1960-04-28 1956-10-04 2005-04-12 2010-12-02 1963-10-05 2006-03-13 1982-08-10 1994-10-11 1999-11-30 1952-02-29 2003-09-30 1988-03-24 2003-12-29 1966-10-08 1968-05-15 2012-11-07 2008-08-25 1992-10-03 1967-03-30 1996-09-26 1986-07-21 1995-10-02 1999-12-14

ssdi_dod
2020-01-15
2019-12-20
2020-01-14 2019-09-18 2019-05-19 2019-11-30 2020-01-28 2019-10-17 2018-01-21
2018-12-06 2019-06-18
2019-11-20
2019-12-10 2020-01-08
2019-10-17 2018-12-20 2018-12-13
2018-12-09
2018-12-21
2019-08-30 2018-06-30

obit_dod 2018-04-11 2017-08-28
2018-04-08
2016-04-14
2019-09-18 2019-05-19 2019-11-30
2019-10-17
2019-08-16 2018-12-06
2019-08-04 2018-02-11 2019-11-20 2019-08-22 2019-12-10
2016-09-22
2018-12-20 2018-12-13 2017-08-19 2018-12-09 2016-08-14
2018-12-28 2019-08-30

Exhibit B, Page 58

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 59 of 352 Pageid#: 962

voter_id 223000297 C 103030997 C 710023833 C 224002074 C 917600050 C
52434710 C 919006236 C 701023834 C 917997592 C 221001118 C 502016945 C 904017291 C 917977158 C 917889044 C 401018779 C 919485814 C 919169790 C 404015425 C 227018500 C 123001527 C 918005137 C 302024859 C 919900365 C
20171436 C 506004248 C 203017196 C 106022549 C 307021117 C 709013252 C 307008715 C 918698264 C 918108795 C
21001567 C

lname

fname STANLEY SHELIA RICHARD SARA RUTH ROBERT BARBARA JOYCE PEGGY TIMOTHY DANIEL JOHN KAREN JAMES PATRICIA EARL PATRICK JANET ROBERT PHILIP ELLEN PATRICIA BERTHA GEORGE JACQUELINE ALVIN SYLVIA DOLLY EDWARD JERRY JAMES BARBARA EVERETT

dob 1923 1953 1936 1939 1928 1939 1943 1934 1941 1939 1940 1945 1957 1943 1935 1958 1961 1941 1941 1941 1930 1945 1919 1942 1946 1940 1944 1929 1927 1942 1935 1952 1938

date_registered 1944-01-01 1998-08-14 1992-08-01 1964-10-03 1996-08-19 2018-06-13 2000-12-15 1972-10-04 1997-05-09 2006-07-21 1963-09-30 1994-09-06 1997-04-17 1997-02-06 1979-01-18 2003-03-20 2001-08-28 1963-03-04 1984-10-04 2004-09-08 2003-11-12 1984-06-13 2004-09-20 2008-09-22 1978-06-20 1986-06-05 1980-10-04 1984-11-15 1974-04-01 1978-09-28 2000-03-03 1997-09-18 1995-11-16

ssdi_dod 2019-12-12 2019-08-21 2019-07-08 2018-12-17
2017-11-29 2019-11-06 2019-11-02
2019-08-06 2018-10-31 2018-12-26 2019-04-23 2018-12-10 2018-12-09 2018-10-30
2019-09-27 2019-11-05
2019-12-04 2019-12-03 2019-10-17 2018-01-15 2017-12-04
2019-07-30 2019-08-31 2017-12-13

obit_dod 2019-12-12 2019-08-21
2018-12-17 2019-09-17 2019-09-15 2019-08-21 2016-12-12 2017-11-29 2019-11-06 2019-11-02 2019-10-12 2019-08-06 2018-10-31 2018-12-26
2018-12-09 2018-10-30 2016-08-01 2019-09-27 2019-11-05 2018-12-06 2019-12-04 2019-12-03
2018-01-15 2017-12-04 2019-08-24 2018-12-30 2019-07-30 2019-08-30 2017-12-13

Exhibit B, Page 59

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 60 of 352 Pageid#: 963

voter_id 208860725 C 740855473 C
41626227 C 104004799 C 104021309 C 301024200 C 605552796 C 705007378 C 306017859 C 918131511 C 408012007 C
37514235 C 920319438 C 302007314 C 609862044 C 380640879 C 920357620 C
3003618 C 918468229 C
22012457 C 27016386 C 127018140 C 919251807 C 605000403 C 711001269 C 217162875 C 791282878 C 918694126 C 406013980 C 918514777 C 306035564 C 87014836 C 128010869 C

lname

fname PHILIP WILLIAM ANNE BETTY KATHRYN PAUL JOHN HELEN HOLLAND PATRICIA EUGENE TIMOTHY ALAN CHRISTY BRUCE EDWARD ANNA WILLIAM ROBERT JULIA ESTHER LINDA ROBERT CURTIS HANNAH ROBERT EDWARD FLORENCE LUCY MOLLIE MARY LINDA VIRGINIA

dob 1927 1937 1921 1936 1925 1950 1963 1930 1925 1947 1927 1959 1949 1951 1938 1943 1923 1922 1941 1931 1927 1940 1954 1934 1940 1948 1940 1920 1933 1939 1932 1961 1933

date_registered 2016-01-26 2008-10-06 2015-07-16 1988-09-20 1952-10-01 1984-09-27 2016-09-06 1956-04-04 1987-08-24 1997-11-05 2000-01-28 2008-02-13 2006-11-09 1992-09-22 2012-09-28 2007-06-28 2006-09-15 1996-10-07 2000-08-22 1964-10-01 1964-10-03 1976-01-01 2001-12-17 1984-01-16 1991-11-06 2014-09-26 2012-03-07 2000-02-24 1964-09-01 1999-06-08 1980-04-23 2009-09-28 1992-09-01

ssdi_dod 2017-08-24 2019-11-17 2019-08-14 2019-08-15
2017-05-23 2019-11-15 2019-10-09 2019-10-07 2019-08-14 2019-01-06 2018-12-24 2018-11-28 2018-02-19 2018-01-08 2016-11-30 2016-11-01 2010-11-14
2019-08-03 2019-12-29 2019-11-11 2019-11-08 2019-09-12 2019-08-02 2018-07-14 2018-04-29 2018-03-30 2016-07-24 2016-01-31 2015-10-10

obit_dod
2019-11-17
2019-08-15 2018-12-18 2017-05-23 2019-11-15 2019-10-09 2019-10-07 2019-08-14
2018-12-24 2018-11-28
2018-01-08 2016-11-30 2016-11-01
2019-09-19 2019-08-28 2019-08-03
2019-11-11 2019-11-08 2019-09-12
2018-07-14 2018-04-29 2018-03-30 2016-07-24
2019-09-19

Exhibit B, Page 60

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 61 of 352 Pageid#: 964

voter_id 205009553 C
12192284 C 917980063 C 813013407 C 211019215 C
3975808 C 102007913 C 201020395 C 402023794 C 601007605 C 919569075 C 827495347 C 917241958 C 919600516 C 504529788 C 917865990 C 226000468 C 110001226 C 917810275 C 591094611 C 699089075 C 508024842 C
40563607 C 605028069 C 223002627 C 920355043 C 306002394 C 153536163 C 919550956 C 702004178 C 917573115 C 920283108 C 228020132 C

lname

fname WILLIAM FRANK ODELL SYLVIA MAE LEROY ERNEST PEGGY RICHARD JOAN BETTY JOHN MAURICE ETHEL MELVIN GOLDIE JUDY BETTY EDITH LOUISE BOBBY THOMAS JAMES DONALD CLYDE LENNIS JOHN ELEANOR ELEANOR SANFORD WILLIAM ROBERT GLEN DOUGLAS

dob 1943 1940 1954 1955 1927 1978 1946 1943 1939 1922 1926 1944 1948 1938 1961 1941 1939 1935 1937 1941 1933 1925 1948 1926 1922 1937 1932 1932 1932 1927 1951 1940 1946

date_registered 1965-03-31 2018-05-14 1999-01-25 1992-10-03 2000-01-31 2016-11-17 1979-10-01 1984-10-06 1992-06-19 1976-10-02 2003-08-08 2007-04-06 2016-07-23 2003-09-26 2018-10-15 1996-12-19 1999-09-24 1991-09-11 1996-11-08 2016-10-17 2007-08-30 1976-03-15 2011-10-11 1976-10-02 1956-01-14 2006-09-12 1964-09-12 2017-09-19 2003-07-07 1998-06-26 2006-12-29 2006-04-17 1987-10-03

ssdi_dod
2019-11-24 2018-12-20 2018-01-18 2017-11-29
2019-12-06 2019-10-09 2020-01-12 2019-11-27 2019-10-08 2018-12-20 2017-12-26 2019-11-26 2019-11-25 2019-11-07 2019-10-15 2019-10-02 2019-08-18 2019-08-17 2019-03-30 2018-12-08 2018-09-04 2018-04-07 2014-02-10 1996-08-16
2020-01-24 2018-12-06 2019-11-17

obit_dod 2019-06-23 2019-11-24 2018-12-20 2018-01-12
2018-12-26 2019-12-06 2019-10-09
2019-11-27 2019-10-08 2018-12-20 2017-12-26
2019-11-07 2019-10-15 2019-10-02 2019-08-18 2019-08-17 2019-03-30 2018-12-08 2018-09-04 2018-04-07
2019-08-09 2019-08-09 2018-03-04
2018-12-07
2019-10-30

Exhibit B, Page 61

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 62 of 352 Pageid#: 965

voter_id 324913997 C 413016374 C 309007609 C 706008256 C 202002631 C 203002330 C 122014530 C 604028467 C 203001670 C 919933378 C 602010614 C
24009092 C 506008343 C 918930146 C 918162161 C 807000667 C 417818039 C 918281118 C 106005889 C 107022067 C 127018386 C 918687102 C 919200212 C 920221219 C
2765315 C 127012793 C
8989300 C 918825146 C 106025315 C 305008719 C 806003931 C
21006352 C 320504027 C

lname

fname PATRICIA WAYNE DONNA ROBERT THURMAN KENNETH HAZEL HAZEL LORRAINE BARBARA WILLIAM TERRY LEWIS GAIL KENNETH DOROTHY PATRICK JAMES WILLIAM RACHEL WILLIAM RODNEY ELVIN GRAHAM SUZANNE THOMAS RUTH SONIA JOSEPH EDWARD ALICE BILL CHRISTOPHER

dob 1930 1926 1944 1929 1948 1931 1936 1937 1927 1942 1928 1949 1923 1944 1942 1931 1935 1940 1943 1928 1944 1950 1951 1923 1937 1943 1936 1935 1941 1922 1927 1922 1949

date_registered 2012-10-11 1991-08-31 1992-10-01 1980-10-03 1970-09-14 1953-10-03 1988-09-13 1960-09-09 1968-09-09 2004-10-01 1973-10-01 1979-03-13 2003-06-26 2000-10-04 1997-12-15 1954-03-20 2018-11-28 1998-06-10 2005-05-10 1963-10-04 1984-07-26 2000-01-31 2001-10-02 2005-12-01 2012-01-17 1964-06-02 2012-08-06 2000-07-18 1967-10-07 1975-08-07 1972-09-12 1967-08-28 2014-07-14

ssdi_dod 2019-08-03 2019-10-29
2019-12-26 2019-11-22 2018-01-05 2017-04-05 2016-04-26 2003-12-05
2019-12-15 2017-12-26 2017-11-11 2017-07-08
2014-09-26 2019-12-10
2019-12-25 2019-12-22 2019-10-27 2019-10-03 2019-08-18 2019-07-22 2018-12-05
2019-11-23
2019-12-02 2019-11-12 2017-09-17 2019-10-21 2018-09-01

obit_dod
2015-06-09
2019-11-22 2018-01-05 2017-04-05 2016-04-26 2003-12-05 2019-10-11 2019-12-15 2017-12-26 2017-11-11 2017-07-08 2019-08-27
2019-12-10 2019-09-28
2019-12-22 2019-10-27 2019-10-03 2019-08-18 2019-07-22 2018-12-05 2019-09-19 2019-11-23 2019-10-08 2019-12-02 2019-11-12

Exhibit B, Page 62

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 63 of 352 Pageid#: 966

voter_id 919484799 C 308048806 C 304030944 C 905001263 C
9003384 C 227997553 C
21019944 C 918768517 C 121017360 C 405004500 C 501001066 C 108014948 C 917597189 C 578614436 C
96926173 C 613003059 C 308051274 C 303001470 C
32020252 C 504008347 C 917370954 C 710276428 C 106005691 C 917839385 C 707010413 C 608027958 C 709014964 C 204009456 C 917114370 C 612023844 C 373018407 C 525220871 C 707005977 C

lname

fname FREDERICK MARCIA ANNIE EDWARD FLOYD BONNIE BEVERLY JOHN CHARLES SARAH EARL RALPH PEGGY JOSEPH ROY CAROL WILLIAM ANN GEORGE MAMIE ROBERT CONNIE HELEN MILDRED AIKO MARY HAZEL WILLIAM LUCILLE GENE ROBERT NANCY BESSIE

dob 1925 1949 1933 1938 1930 1944 1939 1929 1940 1943 1947 1930 1942 1955 1941 1941 1935 1942 1955 1927 1948 1944 1922 1921 1933 1925 1914 1937 1923 1930 1948 1929 1949

date_registered 2003-03-19 2001-02-09 1998-12-07 1959-04-13 1983-08-31 2016-09-27 1984-09-29 2000-05-03 1992-10-01 1977-09-27 1997-02-14 1986-08-07 1996-08-12 2012-09-04 2012-10-04 1968-03-06 1976-04-12 1984-04-19 1992-04-04 1958-11-13 1995-10-10 2012-08-28 1979-03-09 1997-03-13 1977-08-29 2000-04-20 1991-09-26 1991-10-04 1994-05-04 1991-09-16 2008-10-06 2016-06-06 2000-04-03

ssdi_dod 2018-01-11 2019-02-08 2019-12-06 2019-10-21 2019-08-20 2018-09-04
2019-12-22 2019-12-22 2019-10-20 2019-10-17 2019-08-14 2018-12-20 2017-08-15 2014-11-16
2019-11-19 2019-10-13 2019-08-31 2017-05-03 2016-12-13 2019-10-02 2015-02-26 2018-06-29 1998-03-16 2019-12-26 2019-12-23 2019-11-18 2019-09-27 2019-09-16 2019-08-24

obit_dod 2018-01-11 2019-02-08
2019-08-20
2019-10-02 2019-12-22
2019-10-20 2019-10-17 2019-08-14 2018-12-20
2019-08-30 2019-08-22 2016-11-26 2019-11-19 2019-10-13 2019-08-31 2017-05-03 2016-12-13 2019-10-02 2015-02-26 2018-06-29
2019-12-23 2019-11-18
2019-09-16 2019-08-24

Exhibit B, Page 63

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 64 of 352 Pageid#: 967

voter_id 904025563 C 503004348 C 703004182 C 222002266 C 227009560 C
23013015 C 222003157 C 660552151 C 813007213 C
38750574 C 304037117 C
39269085 C 107006651 C 218332417 C
23006120 C 917014274 C 222016340 C 905015797 C 222010503 C 804019364 C 601013044 C 917513682 C 304022551 C 919003939 C 703018099 C 712002764 C 919066079 C 919008867 C 918899516 C 917535278 C 918192096 C
51340133 C 124018143 C

lname

fname LANE RUFUS JOHN SELENA JEANETTE BARBARA MARGARET ROLAND FLOYD ELSIE ALBERT JOSEPH MARY ANNE HELEN RANDOLPH ALICE JOHNNY VIRGINIA NORMAN DONNA IRIS ANITA MILDRED EMILY CURTIS DAVID JIMMY JULIAN DONALD JAMES CARL JOHN PAUL

dob 1963 1939 1932 1923 1920 1951 1945 1947 1943 1929 1933 1932 1938 1935 1938 1933 1941 1924 1937 1944 1937 1958 1922 1929 1946 1952 1946 1933 1938 1932 1943 1923 1931

date_registered 1994-09-15 1976-09-30 2005-01-11 1987-02-25 1961-11-25 1981-09-28 1968-10-01 2007-07-27 2004-02-11 2012-08-17 1998-08-04 2014-08-07 1959-05-02 2014-08-19 1992-06-10 1993-09-03 1984-09-18 1956-11-30 2000-10-10 1995-02-06 1997-07-08 1996-06-12 1980-08-13 2000-12-13 1999-03-11 1989-08-15 2001-03-22 2000-11-08 2000-09-23 1996-06-15 1998-01-23 2010-09-22 1998-02-25

ssdi_dod 2013-12-16 2016-10-31
2019-12-23 2019-11-26 2019-11-03 2019-09-03 2019-03-27 2016-09-23
2019-08-13 2019-03-27 2017-11-29 2017-11-23 2017-08-19
2019-11-27 2019-08-29 2016-09-14 2020-01-01 2019-10-31 2019-03-29 2016-11-29
2019-02-24 2018-12-17 2019-11-29 2019-03-12 2017-12-27 2017-05-11 2020-01-04 2019-09-06

obit_dod 2013-12-16 2016-10-31 2018-12-16
2019-11-26 2019-11-03 2019-09-03 2019-03-27 2016-09-23 2019-08-25
2019-03-27 2017-11-29 2017-11-23 2017-08-19 2019-09-28 2019-11-27 2019-08-29 2016-09-14
2019-10-31
2016-11-29 2016-01-30
2018-12-17 2019-11-29
2019-09-06 2018-12-09

Exhibit B, Page 64

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 65 of 352 Pageid#: 968

voter_id 66142210 C
404621673 C 917613650 C 920340904 C 101023773 C
68102404 C 16179601 C 380793294 C 801009901 C 918833331 C 606023271 C 301034756 C 101007637 C 91939193 C 918671157 C 866203552 C 703009029 C 125007672 C 269236153 C 404028859 C 917250634 C 917779172 C 682897693 C 131927383 C 448611431 C 598821513 C 919071266 C 202009048 C 804010548 C 918195778 C 304005317 C 601033648 C
3002748 C

lname

fname MARTA WILLIAM LEORY JOAN HAZEL FRANK SHIRLEY IDEN RODERICK CONSTANTE MAE HILARIO ANN ALTON PAUL JOHN KATHRYN DOROTHY LINWOOD ROBERTA CHRISTOPHER THERESA PHIL ISABELLA CAROL JEFF GEORGE ESTELLE HENRY JAMES AUSTIN JUANITA THELMA

dob 1946 1935 1947 1935 1934 1948 1944 1951 1940 1940 1923 1923 1929 1933 1948 1925 1916 1928 1950 1939 1977 1946 1949 1924 1943 1970 1941 1932 1930 1945 1937 1925 1943

date_registered 2016-01-04 2014-05-14 1996-08-23 2006-08-16 1997-07-16 2016-09-15 2009-12-09 2008-07-11 1968-09-11 2000-07-26 1973-09-11 2000-01-24 1951-07-06 2014-07-10 2000-01-18 2008-03-05 1937-01-01 1968-04-26 2008-09-29 1999-01-14 1995-03-13 1996-10-07 2018-04-11 2012-03-12 2008-02-13 2015-10-13 2001-03-29 1964-04-15 1970-03-23 2000-11-08 1982-02-10 1955-12-09 1975-04-11

ssdi_dod 2018-04-25 2019-09-25 2019-08-31 2017-05-18 2019-11-14 2019-02-09 2015-03-30 2018-09-03 2016-08-09 2018-12-01 2019-12-12 2018-01-31 2019-11-04 2018-12-28 2019-11-10
2017-12-21 2019-10-23 2019-10-05 2019-08-15 2019-05-23 2017-09-29 2018-12-25 2019-11-20
2019-09-14 2019-10-03 2018-01-27 2018-07-19 2019-10-30 2018-12-20 2018-12-08 2019-01-27

obit_dod
2019-09-25 2019-08-31 2017-05-18 2019-11-14 2019-02-09
2018-09-03 2016-08-09 2018-12-01 2019-12-12
2019-11-04 2018-12-28
2018-12-01
2019-10-05 2019-08-15 2019-05-23
2019-11-20 2019-05-13 2019-09-14 2019-10-03 2018-01-27
2019-10-30
2018-12-08 2019-01-27

Exhibit B, Page 65

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 66 of 352 Pageid#: 969

voter_id 6448408 C
911023761 C 705014479 C 902015798 C 165870035 C 705013712 C 303041188 C 703013713 C 917058839 C 805017562 C 306047634 C 919370376 C 161211959 C 135723987 C 233001924 C 675976591 C 919027755 C 408019099 C 917794686 C 506004844 C 917040581 C 801020306 C 601028071 C 401011899 C 207006030 C 211006029 C 201007699 C 903016057 C 605004873 C 202008319 C 701008259 C 807001209 C 711137196 C

lname

fname TANNIS WILBUR LEEROY GEORGE WILLIAM ROSE ERNEST MAMIE ELIZABETH BARBARA ROGER CHARLEY ELAINE LESHANNON SIMON DAVID RONALD ELIZABETH ROBERT ALICE ELAINE LONA DOUGLAS HELEN SUE JACK FLOYD ROBERT ELIZABETH PATRICIA BRUCELLA CHARLES STEPHEN

dob 1956 1939 1926 1929 1943 1931 1936 1940 1946 1948 1946 1940 1926 1970 1947 1955 1946 1925 1935 1948 1923 1931 1948 1927 1939 1932 1930 1947 1942 1942 1942 1931 1960

date_registered 2017-10-16 1968-08-22 1952-05-01 1964-08-04 2012-12-04 1952-09-04 2001-03-05 1981-09-26 1996-12-02 1985-04-03 1986-09-17 2007-02-28 2014-07-21 2008-08-13 1997-09-10 2007-12-14 2005-10-11 1966-10-08 1996-10-07 1989-10-05 1993-10-01 1952-10-04 1976-04-02 1949-07-02 1983-10-04 1999-09-17 2000-03-01 2000-03-07 1986-09-05 1968-09-07 1975-09-12 1964-04-29 2016-04-27

ssdi_dod 2018-12-06 2019-09-20 2019-05-24 2018-12-25 2018-06-18 2019-05-21 2019-11-02 2019-08-02 2017-01-06
2016-05-12 2019-11-16 2019-08-30 2019-11-04 2020-01-23 2019-11-15 2018-03-13 2008-02-25
2020-01-18 2020-01-12 2019-12-20 2019-12-16 2019-11-21 2019-10-07 2019-09-26 2019-09-14 2019-07-31 2019-05-20 2019-04-30 2019-03-19

obit_dod 2018-12-06 2019-09-01 2019-05-24
2018-06-07 2019-05-21
2019-08-02
2019-09-15 2019-09-02 2019-10-04 2016-05-12
2019-08-30
2019-11-15 2018-03-13 2008-02-25 2016-09-06
2019-12-20 2019-12-16 2019-11-21 2019-10-07 2019-09-26 2019-09-14 2019-07-31 2019-05-20 2019-04-30

Exhibit B, Page 66

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 67 of 352 Pageid#: 970

voter_id 807020305 C 602003416 C 409025801 C 918259658 C 123007673 C 604030478 C 802393473 C 520962189 C 568275011 C
22001576 C 601021000 C 208004707 C 507012250 C 905010120 C 917753733 C 917601260 C 702000407 C 919879860 C 904011843 C 262333564 C 435005640 C 919937946 C
11004929 C 403021350 C 920213893 C 917299885 C 607011403 C 701015959 C 377079149 C 903011536 C 917189693 C 104010194 C 108024025 C

lname

fname CAROLYN OPHELIA JOHN CAROL ROSA GILBERT LINDA ERMA WILBERT MATTIE MARTHA HERBERT WILLIAM EDITH JEFFREY BRENDA HAZEL CHARLENE ALICE CHRISTINE MARILYN KEITH HELEN K ROBERT ORTHALENE CLAY TIMOTHY KENNETH DORIS JOSEPH GENA TIMOTHY VERSEL

dob 1943 1927 1974 1938 1937 1958 1945 1938 1945 1932 1942 1931 1933 1922 1961 1942 1932 1922 1944 1948 1927 1961 1935 1935 1947 1958 1945 1933 1939 1927 1943 1940 1944

date_registered 1970-10-02 1959-03-30 1992-03-17 1998-05-07 1964-04-06 2003-01-09 2011-01-21 2008-03-26 2017-02-01 1964-08-07 1984-09-13 2003-10-06 1966-05-23 1964-04-30 2003-09-12 1996-08-13 1965-04-26 2004-09-10 1984-09-15 2009-09-28 2016-02-02 2004-10-01 1969-10-04 1974-09-28 2005-10-31 1995-07-08 1989-06-22 1987-09-16 2008-04-07 1964-07-15 1994-10-01 1969-10-04 1987-06-15

ssdi_dod 2018-12-26 2018-11-01 2018-09-14
2019-07-18 2018-01-16
2019-12-21 2018-03-26 2019-11-04 2019-10-07 2019-10-06
2019-09-22 2019-09-24 2018-12-02 2018-01-25
2019-08-20 2015-11-15 2019-08-04 2016-08-14 2017-10-29 2018-01-12 2018-04-19
2018-12-23 2019-12-19

obit_dod 2018-12-26 2018-11-01
2017-11-25
2019-09-04
2018-03-26 2019-11-04 2019-10-07 2019-10-06 2019-05-11 2019-09-22
2018-12-02
2019-09-18 2019-09-13 2018-12-17 2017-06-17
2015-11-15 2019-08-04
2018-04-19 2018-12-30 2018-12-11 2019-08-26 2018-12-23

Exhibit B, Page 67

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 68 of 352 Pageid#: 971

voter_id 122014130 C 306027750 C 919147384 C 206002420 C 302038218 C 917344637 C 226011900 C 501033831 C 201000018 C 507006258 C 917867818 C
78436156 C 135079029 C 304014129 C 202013481 C 304041191 C 211004902 C 505009760 C 705002555 C 707006347 C 262960539 C 403031234 C 227001553 C 917182076 C 126010247 C 918073381 C 307020799 C 402000663 C 808015057 C 323214790 C 919419798 C 917867535 C 807000417 C

lname

fname DREWEY CAROLYN GARY JAMES MICHAEL ANN JOHN STANLEY CELESTE ANNE LARRY KIMULA BRENDA ALISON CARROLL PAMELA WARNIE GEORGE ADAM HELEN NANETTE ROBERT BERTHA RUTH GERALDINE CHERYL JOSEPH DANA BETTY CASADEANA MARILYN SERGEANT ESTHER

dob 1935 1943 1954 1933 1941 1937 1948 1952 1949 1929 1976 1962 1961 1924 1939 1935 1933 1947 1935 1927 1956 1938 1922 1923 1928 1946 1933 1945 1932 1960 1931 1946 1927

date_registered 1992-10-02 2016-10-11 2001-07-23 1952-10-01 1997-03-17 1997-09-29 2000-03-29 1997-05-12 1980-09-29 1986-10-04 2004-08-26 2016-10-17 2008-10-06 1962-08-10 1971-06-09 1981-09-25 1988-09-17 1968-09-04 1987-06-16 1987-10-03 2018-08-13 2002-03-14 1948-12-11 1994-09-29 1964-10-03 2000-10-10 1994-04-19 1987-12-11 2006-11-07 2015-11-04 2002-11-06 1997-01-13 1988-04-05

ssdi_dod 2020-01-14
2019-11-20 2019-10-22
2019-10-28
2019-10-14 2019-10-02 2018-12-20 2016-09-10 2017-10-02 2019-11-04 2018-01-27
2018-12-14 2019-10-25 2018-06-18 2019-08-10 2019-11-02 2018-12-30 2019-10-17 2018-12-23 2019-11-24 2020-01-22 2018-12-26 2017-11-10 2018-02-11 2018-01-31 2017-06-11 2017-04-27

obit_dod
2019-10-06
2019-10-21 2017-09-05
2019-09-13 2019-10-14 2019-10-02
2016-09-10 2017-10-02 2019-11-04 2018-01-27 2019-11-07 2019-08-19 2018-12-14 2018-12-14 2019-10-25 2018-06-18 2019-08-10 2019-11-02 2018-12-30 2019-10-17 2018-12-23 2019-11-24
2018-12-26 2017-11-10 2018-02-11 2018-01-31 2017-06-11 2017-04-27

Exhibit B, Page 68

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 69 of 352 Pageid#: 972

voter_id 305030421 C 703018202 C 302005320 C 307040590 C
54680441 C 505521265 C 919935416 C 918936931 C 220763806 C 801003383 C 374841984 C 502019045 C 611001333 C
11003776 C 706014089 C
2003164 C 902022739 C 204012330 C 128000263 C 305793125 C
1005864 C 278447757 C 917707170 C 917387856 C 902004969 C 203020033 C 503009155 C 607029421 C 917281720 C 489688234 C 202014000 C 110014358 C 918573952 C

lname

fname NANCY BECKY LAWRENCE BART ELSIE BETTY DAVID JUDE DORIS PATRICIA CHARLES DORIS GEORGIA WENDELL JAMES JOY GEORGE WILLIAM JULIAN AMY PHILIP CAROLE RICHARD TERRY RICHARD ANNE JEFFREY ROBERT LOIS HERMAN CHARLES EDEN LUIS

dob 1926 1941 1923 1935 1929 1930 1968 1944 1927 1934 1932 1931 1928 1950 1942 1946 1922 1928 1935 1962 1926 1929 1946 1946 1939 1932 1958 1941 1945 1944 1941 1933 1981

date_registered 1976-03-18 1976-09-07 1976-09-18 1980-09-29 2016-11-28 2007-09-17 2004-10-01 2000-10-09 2013-04-16 1955-03-10 2016-01-20 1955-12-16 1991-07-23 1983-03-23 1974-11-07 1987-10-03 1972-02-25 1998-09-25 1998-06-30 2007-07-16 1992-03-09 2007-09-10 1996-10-01 1996-01-17 1972-10-07 1965-11-02 1983-08-18 1972-10-07 1995-05-05 2007-06-21 1966-06-11 1994-10-01 1999-09-01

ssdi_dod
2019-09-24
2019-11-01 2018-07-23 2017-02-05
2018-12-21 2019-10-08
2019-12-21 2019-10-30 2019-10-23 2019-05-09 2019-11-27 2019-12-21 2019-12-16
2019-11-21 2019-06-10 2016-08-08 2019-02-27 2019-09-24 2019-05-01 2019-11-21 2019-08-28 2019-06-03 2017-07-11 2015-08-31 2019-12-21 2017-12-24 2013-08-31

obit_dod 2018-03-09
2018-12-29 2014-09-21
2018-07-23 2017-02-05 2019-08-01
2019-10-08 2019-10-17 2019-12-21 2019-10-30 2019-10-23 2019-05-09
2019-12-16 2019-08-23
2019-06-10 2016-08-08
2019-09-24 2019-05-01
2019-08-28 2019-06-03
2015-08-31
2013-08-31

Exhibit B, Page 69

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 70 of 352 Pageid#: 973

voter_id 126014534 C 503028790 C 920093163 C 305006442 C 304019186 C 919720959 C 171298348 C 917273821 C 917111682 C
86211626 C 708014967 C 701013717 C 603028472 C 405020389 C 919493123 C 904007641 C 916551952 C 707016761 C
24012145 C 419584742 C 201010784 C 612027840 C 701019906 C
27011884 C 918205982 C 602009729 C 601008588 C 604029333 C 511390916 C 918811601 C 302000055 C 229007222 C 257934923 C

lname

fname TRUDY SYLVIA WANDA LEO LOUISE MANUEL PAUL JACQUELINE FLORIDA HUNTER BLANCHE LETTA MAE PHYLLIS LOIS ELOISE BERYL DARIUS CHARLES AGNES MARY MARY SYLVINA JOSEPH BERTHA DIANNE MAX RONALD THEODORE LOIS EDWARD GLENN EDWARD WILLIAM

dob 1945 1947 1960 1931 1928 1930 1930 1945 1936 1999 1934 1937 1937 1930 1939 1935 1980 1929 1940 1928 1923 1924 1935 1931 1949 1941 1945 1931 1914 1925 1937 1945 1932

date_registered 1992-07-21 1969-07-19 2005-04-11 1980-03-12 1972-05-04 2004-03-26 2013-09-05 1995-04-13 1994-04-22 2018-11-27 1956-10-06 1959-06-13 1974-03-08 1959-07-17 2003-03-31 1968-04-16 2008-10-03 1992-02-21 1971-10-02 2016-09-13 1956-10-06 1989-12-01 2001-09-18 1967-05-19 2005-08-15 1984-10-06 1999-11-22 1992-09-30 2008-05-01 2000-06-14 1960-05-03 2000-05-11 2015-04-16

ssdi_dod
2019-08-01 2010-08-07
2019-11-27 2016-09-08
2016-10-08 2016-02-01 2019-09-01 2017-08-26 2017-05-21 2016-12-29 2019-07-28 2019-11-30 2020-01-27 2018-12-04 2018-06-27 2019-09-23 2018-07-17 2018-01-09 2017-10-11 2017-05-05
2018-12-08 2019-10-28 2019-09-13 2019-12-25 2016-03-20 2020-01-13 2018-08-03 2019-12-02 2018-09-24

obit_dod 2019-09-17 2019-10-02 2010-08-07 2019-10-13 2019-11-27 2016-09-08 2019-08-28 2016-10-08
2016-12-29 2019-07-28 2019-11-30
2018-12-04 2018-06-27 2019-09-23 2018-07-17
2017-10-11 2017-05-05 2019-09-04 2018-12-08 2019-10-28 2019-09-13
2016-03-20
2019-12-02 2018-09-24

Exhibit B, Page 70

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 71 of 352 Pageid#: 974

voter_id

lname

9000959 C

606032906 C

213021937 C

221012863 C

403013712 C

2007256 C

507002202 C

225860721 C

604023757 C

29417132 C

918539883 C

801008495 C

917148628 C

920034004 C

917976787 C

918600593 C

919967743 C

234620264 C

920286835 C

304034406 C

121015845 D

605019854 D

204434231 D

806009090 D

917536416 D

920382809 D

116464011 D

918692736 D

4430265 D

304048067 D

25012461 D

603000200 D

204007782 D

fname MARLENE CHARLES JOHN KIRSTI LEON ELSIE FRANK VICTORENE JOSEPH PAUL BROCK EDWARD JOAN PAUL DONALD BONNIE MELISSA ROSE KENNETH JOHN WILLIAM SARA CUC GLORIA BURNICE PATRICIA HELEN GLORIA ANTOINNE NORALEA JAMES CONNIE BETTY

dob 1940 1940 1954 1946 1932 1930 1922 1927 1940 1932 1950 1932 1941 1960 1938 1956 1941 1936 1940 1944 1924 1920 1930 1936 1928 1949 1927 1927 1982 1944 1943 1956 1944

date_registered 1997-07-22 2000-05-05 1992-09-09 1976-08-18 1976-05-05 1992-09-15 1968-10-05 2019-04-05 1980-09-26 2015-08-12 1999-07-07 1985-10-05 1994-08-24 2004-12-13 1997-04-24 2004-03-22 2004-10-04 2016-03-08 2006-04-27 1991-05-30 1955-05-05 1956-05-03 2011-12-15 1968-09-04 1996-07-01 2006-10-10 2012-07-12 2000-03-02 2012-09-29 1988-03-24 1971-08-05 1984-09-25 1999-04-27

ssdi_dod
2019-09-23
2019-11-23 2019-11-18 2019-08-08 2019-10-17 2019-10-02 2019-08-14 2018-08-14 2016-09-06 2019-09-22 2019-02-26 2017-12-22 2019-10-13 2015-03-25 2016-11-14 2019-12-13 2016-01-30
2018-12-12 2015-03-28 2017-12-19 2019-11-27 2019-12-01 2018-03-11 2019-11-20 2019-12-21 2019-11-18 2018-02-13 2019-09-13 2019-09-06 2019-04-09

obit_dod 2019-09-25
2018-02-18
2019-10-17 2019-10-02 2019-08-14 2018-08-14 2016-09-06 2019-09-22 2019-02-26 2018-06-01 2019-10-13
2015-03-31 2018-12-12 2015-03-28 2017-12-19 2019-11-27 2019-12-01
2019-11-20
2019-09-13 2019-09-06

Exhibit B, Page 71

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 72 of 352 Pageid#: 975

voter_id

lname

918253951 D

661606183 D

327136948 D

309382540 D

904006478 D

917701235 D

913000930 D

25412011 D

917722165 D

224006635 D

306001787 D

918390059 D

919281436 D

917155685 D

919617921 D

737585878 D

910000596 D

917600208 D

122009457 D

368825788 D

203001674 D

804012257 D

275737283 D

704023856 D

308028952 D

917226384 D

761225576 D

606006278 D

605033199 D

221004178 D

101025669 D

918553144 D

505007417 D

fname DOWIN SAMMIE TERESA ROBERTA MILAN GEORGE JOHN PAUL MARIE BETH KATHLEEN GEORGE MOHAMMAD PHAT JOHN JAMES PHYLLIS JAMES DOROTHY EDWIN ERSELL ARLING MICHAEL ROGER WILLIAM GERARD GARETH RICHARD STEPHANIE GEORGE ANN DOUGLAS JOYCE

dob 1948 1936 1990 1946 1935 1936 1938 1936 1940 1910 1941 1926 1932 1925 1964 1937 1925 1958 1928 1952 1937 1924 1969 1941 1935 1943 1956 1924 1966 1929 1923 1939 1933

date_registered 1998-05-06 2016-10-12 2008-02-15 2007-02-09 1997-04-10 1996-09-25 1989-10-03 2016-04-11 2011-10-12 1979-02-14 1980-08-28 1998-11-16 2002-03-04 1999-05-24 2003-11-05 2015-02-27 1992-10-02 1996-08-07 2000-05-15 2011-06-22 2016-10-14 1990-09-19 2017-07-12 1997-08-15 1989-01-05 2000-08-07 2007-08-15 1992-10-02 1986-09-16 1956-01-30 2003-02-25 2006-09-08 1966-10-07

ssdi_dod 2018-04-30 2018-03-26 2015-03-27 2020-01-04 2018-12-31
2018-10-26 2019-11-12 1996-10-22 2013-09-21 2016-09-24 2019-10-15 2020-01-22 2019-04-28
2019-11-27 2019-04-29 2019-03-27 2018-12-20 2017-03-27 2016-08-17 2018-10-07 2019-09-28
2018-12-11 2018-05-31 2018-08-14 2018-06-17
2019-11-19 2019-01-04

obit_dod 2018-04-30 2018-03-26 2015-03-27
2018-12-31 2018-12-06 2013-08-12 2018-10-26 2019-11-12
2019-08-25 2019-11-27 2019-04-29
2018-12-20 2017-03-27 2016-08-17 2018-10-07 2019-09-28 2019-08-16 2019-10-26 2018-12-11 2018-05-31 2018-08-14 2018-06-17 2018-12-28 2019-11-19 2019-01-04

Exhibit B, Page 72

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 73 of 352 Pageid#: 976

voter_id

lname

918778803 D

404024454 D

343706277 D

409028538 D

917139367 D

601027842 D

918858433 D

806004595 D

917681313 D

103022161 D

202031847 D

919158759 D

25689911 D

202017777 D

919486752 D

401023660 D

304000058 D

304019496 D

27006629 D

919551630 D

603028073 D

213022206 D

24541139 D

508010329 D

340972821 D

803010869 D

402006956 D

104010487 D

608014059 D

206019319 D

920051089 D

121019999 D

919970335 D

fname MADELINE MARGARET VINCENT FRANCES VIRGLE INA MARY JOHN MICHAEL DONALD GLENN MICHAEL HIDEKO MICHAEL JOSEPH VIRGINIA TOM GAIL LINDELL HANAKO GEORGIA MARILYN WILLIAM AGNES CLAUDE CODY CLARENCE JOYCE BARBARA BONNIE HURLEY MARIAN ROBERT

dob 1925 1933 1954 1928 1955 1920 1932 1926 1953 1949 1953 1957 1931 1944 1943 1925 1923 1943 1924 1980 1917 1929 1949 1929 1947 1939 1948 1943 1936 1937 1941 1942 1943

date_registered 2000-05-03 1957-10-05 2008-10-06 2006-06-21 1994-07-29 1954-05-08 2000-08-23 1976-04-03 1998-04-29 1971-08-09 2006-01-09 2001-08-14 2016-09-13 1999-07-14 2003-03-20 1959-06-04 1973-09-13 1975-03-25 1984-08-21 2003-07-08 1948-04-26 1998-05-08 2010-07-29 1967-07-13 2017-11-20 1983-09-07 1983-08-23 1979-09-29 1996-07-25 1975-06-27 2004-11-03 1998-07-27 2004-10-04

ssdi_dod 2020-01-23 2018-12-31 2019-04-01 2019-08-16 2019-10-15 2017-12-29 2017-07-24 2015-10-27 2014-06-15 2019-11-24 2019-08-18 2019-04-21 2019-10-19 2019-10-12
2020-01-29 2020-01-06 2019-11-26 2019-11-01 2018-11-28 2005-04-30 2019-10-22 2019-01-05 2020-01-30 2020-01-28 2020-01-06 2020-01-01 2019-12-23 2019-12-21 2019-12-18 2019-12-11 2019-12-10 2019-12-04

obit_dod 2018-12-31
2019-10-15 2017-12-29 2015-10-27 2014-06-15 2019-11-24 2019-08-18
2014-02-02
2019-11-01 2005-04-30 2019-10-22 2019-01-05
2019-12-18 2019-12-10

Exhibit B, Page 73

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 74 of 352 Pageid#: 977

voter_id

lname

566112534 D

468027480 D

806009754 D

104007219 D

905023092 D

104001538 D

902024049 D

918355406 D

94900257 D

23018337 D

918409057 D

204006145 D

919288078 D

206020407 D

123015095 D

801016219 D

413015943 D

6799218 D

606014397 D

919613931 D

917320150 D

517026147 D

608000409 D

23010604 D

204027469 D

917279922 D

26907145 D

705013722 D

789885129 D

801008149 D

607001568 D

709018204 D

917594290 D

fname BILLY DEBORAH VELMA TERRY RONNIE LUCY WILLIAM ANGELA LESLIE JOANN NOELLA NANCY ELISHA ROBERT HELEN MILDRED RONALD WILLIAM ARLIE CLYDE THOMAS KEITH ANNIE CLYDE JAMES JOSEPH BARRY WILLIAM VIKKI JERRY BINNIE KENNETH VALERIE

dob 1935 1954 1962 1948 1943 1937 1928 1952 1964 1938 1926 1939 1983 1934 1928 1930 1935 1955 1936 1951 1932 1959 1918 1940 1941 1977 1951 1937 1949 1938 1944 1936 1946

date_registered 2008-09-19 2008-09-24 1990-09-15 2003-07-08 2000-08-08 1983-10-08 2006-09-11 1998-10-02 2016-09-15 1993-02-17 1999-01-07 1976-08-12 2002-03-13 1976-10-02 1957-02-04 1965-09-04 2005-12-06 2016-10-11 1973-09-25 2003-10-06 1995-09-08 2005-01-20 1959-03-10 1961-10-07 1995-10-04 1995-05-02 2017-04-03 1989-10-03 2013-11-06 1966-04-19 1968-05-11 1981-10-07 1999-06-10

ssdi_dod 2019-11-25 2019-11-19 2019-11-06 2019-11-04 2019-11-02 2019-10-29 2019-10-14 2019-10-14 2019-10-02 2019-09-29 2019-09-24 2019-09-09 2019-08-31 2019-08-25 2019-08-19 2019-08-09 2019-08-03 2019-07-31 2019-02-08 2018-12-27 2018-12-22 2018-12-13 2018-12-07 2018-12-02 2018-09-27 2018-09-23 2018-09-15 2018-08-30 2018-08-09 2018-05-28 2018-05-03 2018-01-21 2018-01-20

obit_dod
2019-11-19 2019-11-06 2019-11-04 2019-11-02 2019-10-29 2019-10-14 2019-10-14 2019-10-02 2019-09-29 2019-09-24 2019-09-09 2019-08-31
2019-08-09 2019-08-03
2019-02-08 2018-12-27 2018-12-22 2018-12-13 2018-12-07
2018-09-27 2018-09-23 2018-09-15 2018-08-30
2018-05-28 2018-05-03
2018-01-20

Exhibit B, Page 74

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 75 of 352 Pageid#: 978

voter_id

lname

613015225 D

602004471 D

918823365 D

917811484 D

918642412 D

89769330 D

919698272 D

919520647 D

222562 D

918204532 D

919568809 D

918222247 D

609029932 D

918846622 D

905011665 D

812005073 D

207024172 D

172960488 D

353635242 D

919950131 D

706022626 D

26015827 D

303030425 D

504009257 D

1003864 D

27009099 D

918514448 D

338503879 D

603012056 D

285528014 D

917227354 D

503010517 D

35226346 D

fname JOSEPH GEORGE BARBARA GARLAND NANNIE JAMES SHELTON VIRGIL SUE GLORIA BENJAMIN JOHN JEAN MARGARET THOMAS LILLIE JOHN ALAN DAVID JOSEPH RICHARD WILLIAM LAURA WILLIAM ALBERT B ANNIE JACQUELINE LAWRENCE WILLIAM MICHAEL CAROLYN JANE

dob 1951 1943 1929 1956 1924 1946 1942 1923 1929 1942 1936 1925 1927 1936 1947 1946 1945 1935 1944 1940 1937 1924 1939 1948 1932 1940 1952 1928 1937 1949 1961 1948 1939

date_registered 1972-10-31 1966-04-29 2000-07-14 1996-11-12 1999-12-06 2011-11-21 2004-03-01 2003-05-12 2011-06-23 1998-03-02 2003-08-07 1998-03-23 1952-04-12 2000-08-11 1988-06-02 1992-09-11 1987-03-09 2012-09-06 2008-09-16 2004-10-04 1964-01-22 1954-11-22 1968-10-03 1975-09-02 2002-01-25 1984-10-06 1999-06-08 2011-04-26 1997-04-28 2009-12-11 1994-10-18 1983-07-19 2012-10-02

ssdi_dod 2018-01-05 2017-12-23 2017-12-15 2017-12-13 2017-12-07 2017-03-03 2016-12-02 2016-01-02 2015-09-01 2013-08-28 2007-12-14
2017-10-02 2019-12-13 2018-11-27 2018-01-07 2016-05-08
2019-10-28 2019-10-16 2019-08-09 2019-03-08

obit_dod 2018-01-05
2017-12-13
2016-01-02
2013-08-28
2019-10-19 2019-09-30 2019-09-30 2019-09-18 2019-09-11 2019-09-05 2019-08-02 2019-06-25 2018-12-05 2018-08-11 2016-10-30 2016-09-19 2017-10-02
2018-01-07
2017-07-07 2019-10-28
2019-08-09

Exhibit B, Page 75

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 76 of 352 Pageid#: 979

voter_id

lname

918323512 D

389565539 D

917143545 D

920129572 D

125016282 D

710017265 D

918041771 D

221008130 D

802017823 D

919195736 D

260366293 D

225017513 D

253734214 D

305024607 D

712023571 D

492960325 D

607033114 D

303006196 D

105019063 D

221009020 D

881927434 D

301001791 D

142307998 D

917502390 D

512020324 D

127013693 D

206025315 D

208002198 D

918506397 D

225013684 D

124015408 D

606032451 D

920147233 D

fname JAMES ANNE IRMA FRANK RICHARD REBECCA HAROLD ELIZABETH WALLACE BROCHIE PARIS JAMES FAIRE BETTY HELEN ROBERT ELIZABETH PATRICE RUDOLPH DANIEL SANDRA SCOTT PAUL EVA ISSA MICHAEL WILLARD JERRY NANCY CHARLES JAMES LEE JAMES

dob 1943 1947 1937 1948 1935 1953 1932 1922 1944 1946 1997 1929 1949 1924 1949 1964 1927 1952 1942 1934 1935 1963 1941 1942 1937 1957 1945 1941 1948 1947 1947 1944 1942

date_registered 2006-11-27 2013-07-03 1994-08-12 2005-07-08 1978-08-23 1988-10-05 1997-07-14 1963-03-02 2000-11-15 2001-09-21 2014-11-13 1968-09-20 2016-10-04 1995-10-02 1992-09-03 2008-06-19 1964-10-01 1988-01-16 1996-12-10 1972-10-07 2018-06-15 2000-10-02 2016-10-17 1996-05-13 1972-09-23 2014-11-18 1971-10-01 1988-02-05 1999-05-19 1999-11-03 1997-08-05 1976-09-20 2005-08-10

ssdi_dod
2019-10-17 2019-01-22
2019-11-25 2019-03-18 2018-12-10 2016-09-10
2019-09-24 2018-12-23 2019-11-27 2018-06-09 2019-04-15
2018-12-05
2019-01-04
2019-11-10 2019-10-25 2018-02-06
2018-12-22
2019-08-06 2018-04-24 2015-11-17
2019-11-20 2019-12-18 2019-11-08

obit_dod 2018-12-30 2019-10-17
2019-05-19
2019-03-18 2018-12-10 2016-09-10 2019-10-07
2018-12-23
2018-06-09 2019-04-15 2017-02-17 2018-12-05 2016-10-05
2019-09-19
2018-02-06 2018-04-18 2018-12-22 2018-09-07 2019-08-06 2018-04-24 2015-11-16 2019-05-02 2019-11-20
2019-11-08 2017-01-20

Exhibit B, Page 76

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 77 of 352 Pageid#: 980

voter_id

lname

918785525 D

919861642 D

407007167 D

408005965 D

801007740 D

223006352 D

919308108 D

922959999 D

59879267 D

471299508 D

204025569 D

303009001 D

917431940 D

306040597 D

28017407 D

607010482 D

5814098 D

801016760 D

810007684 D

508394044 D

407006336 D

124745629 D

802019084 D

7027421 D

918056659 D

228005326 D

806008498 D

918500813 D

4244503 D

919290199 D

311039854 D

917137218 D

917490040 D

fname URSULA JOSE JUNE ALMA KATHY HARRIETTE MARJORIE GEORGE ALEC IHIEL LEE JOSEPH DIANNA MARGARET ODILON ELIZABETH KEITH ROBIN JERRY THERESA KENNETH CAROLYN SAM DAVID PAUL RUTH THERESA LARRY EDITH MARGUERITA TERRENCE EDWIN GORDON

dob 1924 1935 1932 1937 1955 1928 1919 1937 1996 1936 1937 1938 1969 1936 1925 1929 1944 1946 1948 1924 1937 1947 1930 1937 1942 1926 1959 1954 1943 1921 1949 1945 1956

date_registered 2000-05-17 2004-08-31 1969-12-01 1963-05-15 1983-10-08 1973-09-25 2002-04-08 2007-10-01 2016-08-02 2018-10-15 1966-09-28 2002-11-06 1996-03-28 2001-08-23 1950-10-17 1976-06-09 2016-06-16 1991-08-05 1989-10-07 2015-09-29 1983-11-17 2017-04-12 1983-11-10 2016-08-30 1997-07-24 1970-06-12 2004-10-01 1999-05-11 2018-04-23 2002-03-18 1996-10-06 1994-07-26 1996-05-09

ssdi_dod 2018-12-12
2019-11-20 2019-09-24 2018-12-26
2018-12-18 2018-02-26 2017-12-16 2019-12-19 2019-08-26 2019-08-10 2019-09-25 2019-11-02
2019-10-29 2018-05-07 2019-10-07
2019-01-30 2019-11-01 2019-03-28 2019-01-27
2019-11-17 2019-11-10 2018-04-18 2018-05-16 2018-12-28 2010-04-20 2019-12-07 2013-12-28 2020-01-27

obit_dod 2018-12-12 2018-08-17
2019-09-24
2018-12-17 2018-12-18 2018-02-26 2017-12-16
2019-08-26 2019-08-10 2019-09-25
2019-09-15 2019-10-29
2019-10-07 2018-10-28
2019-11-01 2019-03-28 2019-01-27 2019-10-18 2019-11-17 2019-11-10 2018-04-18
2019-12-07 2013-12-28

Exhibit B, Page 77

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 78 of 352 Pageid#: 981

voter_id

lname

917346072 D

49400853 D

917244321 D

808000982 D

401000033 D

12792323 D

51129662 D

917311013 D

607016544 D

152787173 D

311037291 D

507009413 D

707011884 D

701011884 D

201875687 D

9735833 D

918046627 D

542191834 D

25500113 D

202027123 D

917322313 D

903017567 D

67755877 D

146549570 D

917944990 D

416876014 D

923637352 D

918152244 D

703024821 D

804016857 D

269836315 D

783447005 D

918542038 D

fname HOWARD JACQUELYN PETER ROBERTA ARTHUR WAYNIE HENRY STANLEY DORIS DAVID DORIS DRUCILLA PAULINE OLA MARY DECLAN RICHARD ANN ROBERT LUTHER MARY BRYAN ELIZABETH BHALCHANDRA MACARTHUR GANESH MILDRED J JAMES RICHARD PAUL FLORENCE COREY

dob 1952 1927 1946 1949 1950 1940 1943 1936 1934 1951 1934 1922 1933 1922 1939 1951 1933 1932 1954 1927 1942 1937 1947 1947 1945 1946 1920 1963 1933 1934 1941 1916 1974

date_registered 1995-10-02 2015-08-13 2001-08-24 1972-05-30 2000-03-20 2018-08-08 2009-06-10 2003-04-10 1956-04-12 2016-09-09 1982-04-12 1943-09-22 1991-08-22 1997-09-11 2013-06-19 2012-05-19 1997-07-09 2008-04-28 2016-10-17 1975-03-26 1995-09-07 1984-08-11 2012-10-12 2018-10-15 1997-03-25 2017-06-30 2008-06-17 1997-11-17 1972-05-13 2001-03-29 2011-03-16 2007-02-27 1999-07-16

ssdi_dod 2019-10-14 2019-11-21 2018-01-22 2018-07-10 2019-10-19
2020-01-13 2019-11-14 2019-10-13 2019-09-27 2019-12-16 2018-12-30 2019-05-08 2017-05-24 2019-07-01 2018-05-30 2019-12-19 2018-01-27 2019-08-22 2018-01-22
2019-12-23 2019-08-17 2020-01-04 2019-07-27 2018-12-25 2011-11-18 2010-06-29 2018-12-18
2019-06-07 2015-11-28 2018-12-02

obit_dod 2019-10-14 2019-11-21 2018-07-10 2018-12-18
2019-10-13
2018-12-30 2019-05-08 2017-05-24 2019-07-01 2019-12-19
2018-01-22 2019-08-24
2019-07-27 2018-12-25
2018-12-19 2019-04-15
2018-12-02

Exhibit B, Page 78

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 79 of 352 Pageid#: 982

voter_id

lname

101006128 D

104006128 D

59095264 D

609002557 D

709016228 D

608033200 D

906012943 D

920324800 D

308003976 D

918564667 D

103143751 D

918954278 D

769139900 D

46144722 D

304038546 D

917055005 D

901005530 D

207014215 D

918864807 D

825862590 D

333738623 D

316209715 D

918374767 D

919441029 D

917491892 D

606011871 D

608004372 D

917001486 D

225015916 D

606020477 D

917441476 D

147826264 D

702008624 D

fname ANNABELLE NORMAN IMOGENE AUBREY JOYCE DAVID MILDRED MELVIN CLARENCE LINDA KELLE ITALA KENNETH LUIS NEDRA CHARLES MARGUERITE ELIZABETH THERESA PATRICIA CHARLES NARRES BARBARA SALLIE BRUCE MARIA VIRGINIA WILLIAM SHIRLEY SANDRA WILLIAM ROY ANNA

dob 1927 1924 1935 1944 1924 1942 1923 1930 1934 1949 1976 1933 1961 1933 1949 1938 1927 1926 1940 1954 1928 1951 1943 1947 1963 1944 1928 1929 1930 1942 1943 1948 1936

date_registered 1948-04-30 1947-04-09 2009-06-16 1983-03-01 1951-08-26 1990-10-04 1986-09-20 2006-07-10 1980-09-17 1999-08-20 2013-10-15 2000-10-10 2016-02-04 2013-08-22 1976-04-01 1993-11-03 1968-10-05 1960-04-12 2005-09-29 2010-02-08 2017-02-22 2013-12-11 1998-11-04 2002-11-27 1998-10-05 1991-07-10 1951-12-05 1993-07-07 1993-12-13 1965-10-01 1996-03-20 2008-06-23 1966-09-02

ssdi_dod 2016-12-08 2016-08-03 2019-12-07
2020-01-20 2018-12-18
2018-12-25 2018-09-26 2019-08-03 2019-01-20 2017-12-28 2017-06-11
2012-01-31 2019-10-21 2019-10-06
2019-08-16 2019-11-11 2019-10-06 2019-08-20 2018-12-17 2018-03-20 2018-03-05
2020-01-15 2019-03-31
2019-12-06
2018-11-17 2018-11-23

obit_dod 2016-12-09 2016-08-03 2019-12-07 2019-08-05
2019-09-20 2018-12-25
2019-08-03 2019-01-20
2018-12-03 2012-01-31
2019-10-06 2019-10-13 2019-08-16
2019-10-06
2018-03-05 2018-12-16
2019-03-31 2019-10-27 2019-12-06 2017-01-08
2018-11-23

Exhibit B, Page 79

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 80 of 352 Pageid#: 983

voter_id

lname

492959931 D

634736332 D

885979429 D

904000365 D

172464793 D

920403872 D

27002761 D

126005362 D

134425879 D

908023320 D

94246963 D

607001964 D

308005696 D

912000939 D

918356427 D

305016279 D

445045545 D

705014491 D

402003806 D

918134790 D

405017197 D

308033788 D

8000966 D

508027169 D

308011201 D

704013472 D

917698327 D

223009575 D

516603370 D

102616656 D

917676938 D

905014327 D

30122937 D

fname STEPHEN JOHN LOUISE LOUIS PAUL GREGORY VIRGINIA FRANCES JACQUELINE LIANE JAINISHA DORIS WARREN JEAN RAINEY BEVERLY WOODIE DORIS CLYDE CHARLOTTE RITA DOROTHY ANTHONY ELLEN THOMAS CECILE YEN DOROTHY CAROL ROLAND SEBASTIAN ROBERT ELSIE

dob 1942 1934 1927 1930 1940 1961 1932 1930 1926 1932 1992 1927 1921 1927 1928 1936 1955 1943 1934 1924 1942 1931 1941 1921 1921 1923 1930 1932 1945 1926 1939 1939 1916

date_registered 2018-08-21 2019-06-12 2008-02-15 1968-09-25 2016-10-05 2016-04-12 1978-03-20 1957-11-22 2008-10-06 2006-09-21 2010-01-28 1975-11-13 1960-02-15 1980-10-01 2000-11-08 1972-09-23 2009-08-31 1988-05-03 1975-04-09 2006-11-15 1973-10-04 2001-11-28 1997-09-05 1993-07-06 1968-09-07 1961-06-10 2000-03-27 1997-08-19 2019-07-18 2008-12-08 1999-09-10 2000-05-03 2016-08-24

ssdi_dod 2018-12-29 2019-12-25 2019-11-04 2019-12-30 2019-08-26 2018-09-16 2017-12-18
2019-12-13 2019-01-21 2019-12-25 2019-12-09 2019-10-16 2019-04-22 2019-10-18 2018-08-07 2019-12-02 2017-06-22 2014-09-29
2019-11-07
2018-02-21 2019-12-18 2017-12-15 2019-11-06 2019-10-18 2019-08-07 2020-01-06 2019-10-04 2018-10-29

obit_dod 2018-12-29
2019-11-04
2019-08-26 2018-09-16 2017-12-19 2019-04-14 2017-07-22 2019-12-13 2019-01-21
2019-12-09
2019-04-22
2017-06-22
2019-10-29 2019-09-24 2019-11-07 2018-07-21 2018-02-21
2019-08-07
2019-10-04 2018-10-29

Exhibit B, Page 80

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 81 of 352 Pageid#: 984

voter_id

lname

106018759 D

919638346 D

906438630 D

503016666 D

10006698 D

787934162 D

702015550 D

482368896 D

601019367 D

812011841 D

302023540 D

523432205 D

10609721 D

919044236 D

124007027 D

506000971 D

804006211 D

918425520 D

234013337 D

196653207 D

153716266 D

202026327 D

919589765 D

604029686 D

506016801 D

53443152 D

407006962 D

192681040 D

917262917 D

754951023 D

902017893 D

225009283 D

21011385 D

fname MARGARET LUCIANO RYAN BETTY LEWIS JAMES HAZEL EDWARD SALLIE SHERRI NHI THUY LEWIS BONNIE SUSAN EARL HENREESE DENNIS TERRY BELVA GRADY ANNA MARY LUCILLE BETTY FOSTER JAMES DOUGLAS JANET TERRY THOMAS LILLIE JANE

dob 1946 1929 1989 1938 1948 1949 1929 1930 1923 1962 1941 1931 1935 1945 1950 1967 1948 1952 1967 1938 1938 1936 1940 1926 1942 1950 1937 1957 1932 1967 1936 1922 1956

date_registered 1973-02-13 2003-11-24 2008-08-28 1978-09-30 1979-11-07 2016-10-17 1972-08-08 2007-12-22 2006-08-16 2004-10-04 1989-04-26 2008-11-25 2013-07-10 2001-02-20 2006-11-21 1992-07-02 1992-02-09 1998-12-16 1992-02-10 2017-05-22 2010-03-31 1965-09-22 2003-08-22 1951-10-06 1972-10-07 2012-02-07 1964-04-11 2016-12-15 1997-04-14 2007-06-01 1977-06-15 1966-05-04 1988-02-06

ssdi_dod 2019-10-14 2012-02-07 2019-08-31 2018-01-13 2019-11-26 2019-08-20 2019-05-18 2018-09-05 2018-04-21 2015-11-26
2019-09-07 2016-07-31 2019-08-19 2019-08-09 2014-06-29 2018-12-29 2017-04-05 2019-12-20 2019-12-26 2019-12-16 2019-11-10 2019-10-17
2019-11-10 2018-04-03 2018-02-16 2017-05-01 2019-03-06

obit_dod 2019-10-14
2019-08-31 2018-01-13 2019-11-26 2019-08-20 2019-05-18
2015-11-26 2019-08-02 2018-12-27 2019-09-07 2016-07-31
2019-08-09 2014-06-29 2018-12-29 2017-04-05
2019-12-16 2019-11-10 2019-10-17 2019-08-19 2018-12-29 2017-12-02
2018-02-16 2017-05-01
2016-01-31

Exhibit B, Page 81

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 82 of 352 Pageid#: 985

voter_id

lname

917383806 D

680188271 D

807015324 D

103026362 D

601004880 D

27101101 D

917138608 D

306047435 D

128007890 D

401012010 D

610011414 D

1185126 D

247351502 D

405363737 D

918148425 D

603011414 D

412026308 D

255599986 D

705026123 D

305004849 D

225013570 D

307019968 D

704013729 D

306811395 D

917266053 D

156597055 D

43079653 D

919043906 D

212001009 D

201001089 D

403012160 D

287494698 D

920022038 D

fname LLOYD LOUAN MARY ROBERT WILLIAM ABEL MATTHEW GEORGE JOHN JIMMIE LINDA MICHAEL JUDY CAROL JAMES JAMES MARK SAMUEL DOREEN NELDA MARTHA JAMES FLETCHER EARL DONNIE CECIL CARL RICKEY STEPHANIE ARTHY MARY PATRICIA ARNOLD

dob 1963 1931 1931 1943 1931 1929 1948 1945 1927 1948 1946 1942 1945 1940 1938 1923 1951 1946 1962 1937 1938 1946 1928 1947 1950 1965 1945 1956 1974 1923 1928 1939 1943

date_registered 1995-12-10 2016-09-07 1952-10-01 2001-08-27 1980-09-23 2014-12-23 2006-02-10 1984-01-09 2001-07-24 1985-09-27 1988-08-18 2011-02-04 2007-04-26 2016-12-13 1999-07-23 1980-04-09 1984-01-05 2014-02-27 2001-04-03 1987-01-24 1970-04-17 1988-08-13 1971-08-21 2017-09-27 1995-04-07 2011-08-24 2012-09-24 2001-02-20 1992-03-16 1980-09-08 1981-02-10 2015-09-10 2004-11-17

ssdi_dod 2018-03-16
2019-10-10 2019-08-26
2017-08-08
2019-08-30 2018-12-31 2019-08-16
2020-01-09 2019-11-20
2019-10-18
2015-08-05
2019-11-15 2019-12-02 2018-02-09 2019-10-28 2018-08-02 2019-11-04 2018-12-18 2017-11-28 2015-09-03 2014-01-17
2018-10-21

obit_dod
2019-09-21 2019-10-10 2019-08-26 2019-10-01 2019-08-29 2017-08-08 2016-11-09
2018-12-31 2019-08-16 2013-12-19
2019-11-20 2019-09-26 2018-12-04 2019-10-18 2018-11-09 2015-08-05 2016-01-03 2019-11-15 2019-12-02 2018-02-09 2019-10-28
2019-11-04
2017-11-28 2015-09-03
2019-09-11 2018-10-21 2019-02-06

Exhibit B, Page 82

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 83 of 352 Pageid#: 986

voter_id

lname

296037065 D

118484193 D

909002831 D

28137435 D

701009043 D

105007223 D

403002971 D

230465556 D

918648260 D

312012326 D

902013084 D

225415728 D

901010342 D

806012264 D

208027337 D

133395210 D

12001461 D

812001913 D

919555833 D

208007529 D

920163623 D

917233472 D

515024848 D

540767064 D

711000294 D

901021835 D

225010268 D

304043813 D

32004775 D

513004858 D

103021942 D

108021942 D

917424951 D

fname ANN ARTHUR ALONZO EARL JOCELYN EARL DONNA JOHN WILLIAM JERRY MARY DENISE JANIE ADA CLAIRE JO EDWARD RUTH WARREN DARLENE ROY BETTY PHILIP HILDA PATRICIA CHARLES BETTY CHARLES JERRY MATTIE WILLIAM ELSIE RODNEY DANIEL

dob 1924 1946 1946 1981 1927 1944 1944 1922 1946 1949 1940 1971 1947 1943 1933 1969 1922 1932 1963 1936 1926 1958 1924 1929 1921 1925 1947 1947 1930 1922 1932 1934 1940

date_registered 2007-03-02 2016-12-14 1988-07-28 2011-02-25 1974-07-19 1982-11-03 1998-04-04 2017-07-31 1999-11-03 1992-10-02 1998-08-12 2011-12-01 1999-09-07 1968-10-05 1992-01-02 2016-01-14 1997-12-11 1964-03-12 2004-09-09 1975-09-29 2005-09-09 2002-07-08 1989-10-07 2016-06-23 1991-08-07 1958-02-19 1980-07-22 1984-09-20 1988-10-07 1992-07-21 1997-08-07 1967-10-03 1996-03-19

ssdi_dod 2019-07-10 2020-01-11 2018-12-03 2018-09-19 2017-12-05
2020-01-12
2019-10-16 2016-10-03 2019-12-28 2019-10-20 2019-01-15 2018-09-23 2018-04-30 2019-12-18 2018-12-23 2018-07-04 2009-11-14
2019-08-27 2018-01-24 2016-09-08 2016-07-13
2019-12-17 2020-01-03 2019-12-25 2019-08-07

obit_dod
2018-12-03 2018-09-19
2019-09-17 2019-08-06 2018-12-22
2015-07-09 2019-10-16
2019-10-20 2019-01-15
2018-04-30 2019-12-18 2018-12-23 2018-07-04 2009-11-14 2017-02-15 2019-08-27
2016-09-08
2019-09-09 2019-03-24 2019-05-19
2019-12-25

Exhibit B, Page 83

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 84 of 352 Pageid#: 987

voter_id

lname

919181958 D

302032577 D

917191828 D

806010567 D

207006772 D

340281744 D

919729704 D

918134288 D

221012198 D

918488589 D

502000616 D

508002208 D

919735364 D

29001589 D

26001589 D

121001795 D

104472764 D

508004195 D

225012896 D

303037998 D

918414696 D

918184937 D

918864967 D

919264923 D

201000795 D

105004521 D

408027442 D

605005695 D

918476500 D

54226579 D

917653868 D

112881611 D

919194703 D

fname BETTY JOHN RUPBERT BEATRICE PATRICIA HOLLIS GEORGE ROBERT DARYL NONA GENEVA NELL ROBERT ARTHUR GERALDINE JOSEPHINE HENRY RONALD MARJORIE EDWARD CONNIE DIANE EVELYN ROBERT EUGENE JULIANNA MILTON FRANK ARTHUR ERNEST JOHN FLORENCE BERTRAM

dob 1928 1931 1937 1923 1931 1928 1951 1938 1956 1949 1926 1929 1944 1948 1947 1928 1946 1955 1925 1933 1945 1955 1982 1925 1945 1947 1931 1956 1939 1936 1937 1931 1946

date_registered 2001-09-11 1975-07-17 2003-07-10 1955-06-03 2000-09-27 2018-10-10 2004-04-05 1997-11-05 2005-09-08 2016-06-09 1983-10-07 1952-01-24 2004-04-09 1974-05-08 1983-10-07 2006-07-10 2013-05-20 1993-11-30 1952-04-12 1996-08-26 1999-01-15 1998-01-24 2000-08-26 2002-01-28 1991-09-14 1968-08-28 1984-05-11 1986-10-02 1999-04-12 2012-10-15 1996-09-05 2016-02-03 2002-05-13

ssdi_dod 2016-08-28
2017-04-14 2020-01-29 2019-12-29 2019-08-25 2018-10-24 2017-04-10
2019-11-29
2019-11-15 2018-12-19
2018-04-04 2018-01-28 2019-09-18
2018-01-03 2019-10-11 2019-11-15 2006-09-12
2019-10-14 2019-12-25 2015-05-01 2020-01-20
2020-01-04 2017-02-09

obit_dod
2019-08-28 2017-10-19 2017-04-14
2019-08-25 2018-10-24
2017-10-14
2019-09-07 2019-09-27 2019-11-15 2018-12-19 2019-09-24 2018-04-04 2018-01-28 2019-09-18 2019-09-20 2018-01-03
2019-11-15
2019-09-03 2019-10-14
2015-05-01
2019-10-17
2016-02-02

Exhibit B, Page 84

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 85 of 352 Pageid#: 988

voter_id

lname

425198211 D

585620204 D

920172444 D

919931750 D

107334764 D

312017899 D

960313139 D

204022910 D

607019863 D

920240104 D

411001657 D

203013257 D

21469098 D

229007234 D

806006699 D

917475477 D

301040907 D

803004606 D

201023982 D

918883088 D

105005813 D

917636638 D

101027457 D

917260438 D

303022241 D

917319266 D

227777193 D

606027846 D

502023158 D

830445153 D

108005701 D

674032620 D

918952809 D

fname CHRISTINE ELLEN NANCY LARRY LEONARD ROBERT O'HERN JON ASTRID JOHN WILLIAM PATRICIA BETH HELEN GURMUKH KARA STEPHEN FIDELINO DOLLY INA LEE ANNIE JERRY JOYCE SAMUEL ALICE MARK ONEDA BETTY MARY MARGUERITE BEULAH TAI

dob 1948 1940 1945 1948 1935 1944 1920 1939 1927 1926 1945 1941 1961 1933 1937 1978 1953 1939 1930 1912 1940 1949 1948 1953 1949 1956 1957 1936 1934 1959 1930 1935 1952

date_registered 2014-06-18 2012-11-13 2005-09-23 2004-09-30 2012-10-09 2003-08-21 2008-09-30 1993-09-25 1997-06-13 2006-01-19 1988-10-08 1976-09-27 2015-02-05 2003-01-30 1981-12-02 2013-04-24 1972-10-07 1988-10-04 1979-04-24 2000-09-13 1968-01-08 2001-08-27 1993-09-02 1995-03-24 1992-09-08 1995-09-06 2012-10-15 1959-10-03 1959-06-13 2012-06-21 1971-10-01 2015-08-24 2000-10-10

ssdi_dod 2018-04-14 2018-09-09 2019-10-22 2017-08-30
2019-09-22 2016-01-25 2019-08-03 2019-02-11 2019-12-12 2018-12-09 2017-06-30 2019-09-27 2019-08-21
2016-10-12 2019-10-14 2020-01-16
2011-12-09 2019-11-10 2019-10-23 2018-12-17 2019-11-07 2019-10-08 2019-09-24 2019-09-03 2018-12-14 2018-12-04 2018-05-24 2019-09-01 2018-06-29 2019-01-05

obit_dod 2018-04-14
2019-10-22
2019-10-02
2016-01-25 2019-08-03 2019-02-11 2019-12-12
2019-09-27 2019-08-21 2019-08-10
2019-10-14
2017-05-05
2019-11-10 2019-10-23 2018-12-17
2019-09-24
2018-12-14 2018-12-04
2019-09-01 2018-06-29 2019-01-05

Exhibit B, Page 85

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 86 of 352 Pageid#: 989

voter_id

lname

609031327 D

133008060 D

15464973 D

919635181 D

727024690 D

918865662 D

919165514 D

306019769 D

175275293 D

405023377 D

406016102 D

324236824 D

307043814 D

711002775 D

803021969 D

625229384 D

607532632 D

305042817 D

124015420 D

908003721 D

284237612 D

919386652 D

230011575 D

308041630 D

920406615 D

423349138 D

402002660 D

705015969 D

831854572 D

207002335 D

396392214 D

919552331 D

305002050 D

fname VERGIE JACQUELYNN STEPHEN SANDRA HERBERT ROGER FRANCES VONNIE JOSEPH NORMAN WILLIAM JEAN BERNARD RICHARD DOROTHY NATHAN JOHN ESMER CHARLES EDWARD WILLIAM GENEVIEVE NICHOLAS PATRICIA WALTER HELEN CHESTER GEORGE CHARLES WILLIAM WILLIAM MARY KATHLEEN

dob 1922 1953 1949 1943 1931 1947 1955 1922 1971 1930 1924 1926 1944 1943 1939 1978 1942 1937 1927 1944 1970 1929 1947 1946 1932 1924 1937 1941 1937 1935 1943 1939 1927

date_registered 1997-04-15 1998-02-05 2016-08-04 2006-03-12 2008-12-08 2000-08-30 2001-08-22 2000-01-31 2018-08-03 1966-05-02 2002-01-22 2010-01-21 1979-10-04 1998-06-15 1992-04-04 2013-09-04 2017-10-03 1988-09-16 1976-01-01 1968-10-04 2015-07-22 2002-09-03 1997-08-14 1976-10-02 2006-11-28 2016-06-07 1982-09-14 1962-08-28 2008-09-30 1982-09-28 2008-10-06 2003-07-10 1952-10-04

ssdi_dod
2019-10-05 2016-09-27
2019-10-09 2019-08-09 2018-01-26
2019-10-30 2019-11-15 2018-12-05 2017-11-03 2018-12-20 2016-06-16
2019-06-29 2019-05-03 2019-11-30 2019-04-06 2018-06-11 2018-06-09 2016-09-04 2019-12-02 2014-11-01
2019-12-11 2019-04-15 2019-09-02 2017-09-16 2019-12-02 2019-10-21 2019-02-01

obit_dod 2019-09-30 2019-10-05
2019-08-22 2019-10-07 2019-08-09
2015-09-30
2019-11-15 2018-12-01 2017-11-03 2018-12-20 2016-06-16 2019-08-02 2019-06-29 2019-05-03 2019-11-30
2018-06-11 2018-06-09 2016-09-04 2019-12-02 2014-11-01 2019-07-28 2019-08-22
2019-09-02 2017-09-16 2019-12-02

Exhibit B, Page 86

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 87 of 352 Pageid#: 990

voter_id

lname

616195776 D

206003769 D

706006769 D

515009966 D

610037058 D

709014771 D

810001229 D

903016833 D

304029410 D

917388861 D

405002660 D

22006135 D

804000695 E

918137412 E

918875829 E

202003770 E

3007723 E

405011021 E

623714063 E

302037556 E

22017865 E

917083187 E

222007853 E

467615043 E

406013921 E

918169504 E

917290264 E

919527979 E

204007469 E

917180780 E

605028477 E

232001568 E

429332788 E

fname JOAN DORCAS THOMAS TIMOTHY TIMOTHY PAUL DONALD BERTHA VICTOR JAMES PRISCILLA CARL JUSTINE CARL KATHLEEN DIANNE HELEN BROMBY FREEMAN JAMES JEAN PHILLIP DOROTHY PATRICIA BARBARA LARRY LONNIE DAISY HENRY LENWOOD BETTY CHARLES RANDY

dob 1929 1927 1944 1962 1960 1926 1936 1921 1944 1937 1923 1929 1929 1942 1920 1945 1922 1947 1932 1954 1932 1951 1931 1949 1940 1947 1944 1963 1935 1931 1932 1943 1953

date_registered 2016-07-15 1979-11-07 2004-09-01 1989-09-22 1978-10-04 1961-07-11 1992-10-01 1953-09-30 1984-09-13 1996-01-22 1976-09-23 1983-05-09 1956-04-30 1997-10-23 2000-09-08 1972-04-27 1960-09-23 2004-12-28 2007-02-12 2002-10-04 1964-10-03 2001-07-15 2000-10-04 2014-05-02 1980-03-19 1999-12-15 1995-05-26 2003-05-29 1966-10-08 2004-09-16 1953-10-03 1991-11-19 2008-09-20

ssdi_dod 2018-11-27 2019-07-27 2019-11-11 2019-08-31 2019-06-08 2015-03-30
2018-09-29 2020-01-14
2018-01-29
2020-01-29 2020-01-08 2019-09-14 2018-12-18 2019-12-01 2019-10-11
2019-12-24 2019-10-27 2019-08-14
2019-12-06 2019-06-10 2018-06-30 2017-12-28 2016-12-02 2019-11-10 2018-02-13 2019-11-27

obit_dod
2019-11-11 2019-08-31 2019-06-08
2019-02-11 2018-09-29
2015-12-16 2018-01-29 2018-12-28 2018-01-25 2019-08-15
2019-09-14 2018-12-18
2019-10-11 2019-10-11
2019-08-14 2019-08-10 2019-12-06 2019-06-10 2018-06-30 2017-12-28 2016-12-02
2018-02-13 2019-11-27

Exhibit B, Page 87

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 88 of 352 Pageid#: 991

voter_id 23007271 E
385228417 E 222022465 E 303047439 E 603002753 E 522291247 E 919545199 E
10006329 E 806011699 E 920086738 E 609003954 E 408018603 E 502009162 E 603027968 E 208010798 E 908004981 E 810010873 E 561438866 E 399749956 E 705017870 E 897129803 E 704016889 E 919573182 E
33013870 E 802009548 E 150586177 E 919903352 E 918314851 E
25003283 E 7002206 E
810004610 E 917898651 E 209007642 E

lname

fname BEULAH DORIS JULIAN FRANK BARBARA JANE PALMER DAVID PHILIP MAUDE HARRY RAYMOND VIRGINIA ALFRED GEORGE LINDA WILLIAM CHARLES ROSALIND NANCIE JOHN MARY LILLIAN BOBBY MARY HERMAN WILLIE BLONZELLA PATTIE VIRGINIA RUBIN RONALD ANNETTE

dob 1929 1933 1933 1946 1941 1932 1942 1929 1937 1931 1931 1935 1934 1929 1946 1948 1943 1947 1933 1943 1943 1948 1938 1938 1927 1943 1932 1949 1945 1939 1940 1961 1926

date_registered 1956-09-04 2013-09-12 1964-10-03 1983-09-24 1967-06-09 2016-03-07 2003-06-26 1994-09-29 1980-05-06 2005-04-04 1997-11-24 1959-04-28 1968-10-04 1980-08-28 1976-09-28 1982-09-18 2000-08-22 2016-03-02 2008-10-06 1983-10-07 2019-09-25 1979-04-16 2003-08-14 1992-10-03 1961-06-02 2011-06-14 2004-09-22 2000-06-14 1984-09-18 1964-10-01 1988-10-08 2000-04-03 1989-12-04

ssdi_dod 2016-06-29 2017-11-22 2018-01-25 2017-08-18 2018-10-04
2019-05-01
2018-08-28 2019-10-13 2019-01-31
2019-09-25 2018-01-23 2019-12-04 2019-09-18 2018-11-13 2019-12-27 2019-03-31 2019-09-26 2019-12-27 2019-12-04 2019-11-19 2019-11-10 2019-10-24 2019-09-25 2019-08-14 2018-08-09 2018-01-01 2016-11-26
2019-11-13 2019-03-09

obit_dod 2016-06-29 2017-11-22
2017-08-18 2018-10-04 2018-07-27
2019-08-09 2018-08-28
2019-01-31 2019-11-11
2018-01-23
2018-11-13
2019-09-26
2019-12-04 2019-11-19 2019-11-10 2019-10-24 2019-09-25 2019-08-14
2018-01-01 2016-11-26 2016-05-01 2019-11-13 2019-03-09

Exhibit B, Page 88

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 89 of 352 Pageid#: 992

voter_id 25010850 E 27015837 E
903001290 E 919801848 E 408019332 E 110022569 E 502004862 E 804019149 E 131382957 E 801005350 E 323828927 E 202000087 E 187347059 E 208025317 E 202007643 E 703013736 E
24012909 E 751852636 E 108706875 E 909018506 E
96977665 E 603028189 E 874778227 E
45891368 E 406022110 E 204012354 E 223011234 E
25006373 E 48981431 E 507009689 E 918718155 E 503003986 E 204001152 E

lname

fname THOMAS THOMAS WILLIAM COLIN LINWOOD SHERMAN EDITH RICHARD NANCY WILLIAM PAULINE JOSEPH ROBERT BOBBY CARLA THOMAS DORIS RICHARD SHEILDA WILNETTE LARRY GERALD HELEN DOLLIE ANDREW EBBY DOROTHY GWENDOLYN ERROL PEGGY LEONARD FLETCHER LUCILLE

dob 1948 1933 1936 1942 1935 1935 1934 1954 1938 1959 1920 1932 1962 1936 1947 1925 1935 1946 1938 1960 1944 1936 1922 1932 1943 1956 1920 1940 1944 1952 1928 1923 1931

date_registered 1986-04-05 1955-12-23 1978-10-07 2004-07-09 1968-09-11 1980-10-02 1967-06-09 1992-10-01 2009-12-16 1989-09-05 2013-06-12 1951-03-13 2016-07-15 1959-10-03 1987-05-29 1954-06-18 1968-10-05 2008-01-14 2017-10-02 1979-10-06 2008-10-06 1957-10-05 1949-02-18 2016-10-03 1967-10-05 1994-09-17 1955-12-20 1981-10-02 2012-01-26 1971-10-02 2000-03-16 1951-07-07 1951-10-01

ssdi_dod
2020-01-18 2020-01-17 2020-01-13 2019-12-11 2019-12-08 2019-12-03 2019-11-30 2019-11-22 2019-11-20 2019-11-16 2019-10-20 2019-09-29 2019-09-27 2019-09-14 2019-09-09 2019-09-03 2019-08-29 2019-08-19 2019-07-29 2019-04-17 2019-03-30 2019-02-22 2018-12-26 2018-12-26 2018-12-18 2018-10-30 2018-10-28 2018-10-11 2018-03-06 2018-01-27 2018-01-26 2018-01-16

obit_dod 2017-10-11
2019-12-08 2019-12-03 2019-11-30 2019-11-22 2019-11-20 2019-11-16
2019-09-29 2019-09-27
2019-09-09 2019-09-03 2019-08-31 2019-08-19 2019-07-29
2019-03-30 2019-02-22 2018-12-25
2018-10-30 2018-10-28
2018-03-06 2018-01-27 2018-01-26

Exhibit B, Page 89

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 90 of 352 Pageid#: 993

voter_id 307029411 E 228094892 E 703013734 E 207025320 E 602033420 E 253319442 E 918539698 E 208014007 E 918569255 E 327145826 E 307007711 E 918391056 E 211623271 E 918705454 E 308038362 E 402024054 E 223016375 E 917127652 E 301022975 E 919546583 E 229001787 E 624359818 E 917487692 E 908023783 E 920093265 E 808011847 E
24012155 E 917062827 E 129009184 E 191768569 E 390517771 E 918339159 E 129544510 E

lname

fname JANE MARY BETTY ESTHER RUTH KIRBY FAYE MARY MARY NEIL DOROTHY ROY BARBARA ROBERT PIERRE FRANCES ROBERT MARJORIE DANIEL SHIRLEY DINAH CHARLES ANGELA SARAH WILLIAM DOLORES GEORGE CHARLES GERALDINE MOULAY HASSAN FRANK PATRICIA RASHID

dob 1920 1937 1927 1935 1934 1948 1940 1935 1935 1943 1936 1938 1932 1941 1932 1936 1925 1935 1947 1923 1943 1930 1965 1935 1948 1929 1947 1941 1946 1949 1930 1943 1972

date_registered 1987-09-30 2008-07-16 1954-09-16 1956-06-12 1971-09-23 2013-10-01 1999-07-13 1992-09-23 1999-08-17 2016-09-21 1962-04-14 1998-11-25 2017-10-16 2000-03-01 1972-10-06 1996-11-15 1964-02-27 1994-06-18 1972-10-07 2003-07-01 2001-06-13 2008-01-04 1996-05-08 1984-10-02 2005-04-28 1987-11-04 1984-10-06 1993-12-09 1968-05-07 2012-09-20 2007-03-16 2005-06-16 2012-05-14

ssdi_dod 2017-04-15 2016-08-28 2015-11-02 2015-07-31 2014-11-27 2013-12-11
2015-03-27 2019-12-27 2019-11-23 2018-12-25 2019-11-20 2018-12-13
2019-08-20 2019-10-08
2016-01-11 2016-11-22 2019-08-26 2017-09-06
2018-01-16 2014-04-25 2019-03-13 2018-12-02
2019-10-17

obit_dod
2016-08-28
2015-07-31 2014-11-27
2019-08-22 2019-08-09 2019-07-20 2017-05-24 2018-12-30
2019-11-20 2018-12-13 2016-11-27 2019-08-20
2019-10-29 2016-01-11 2016-11-22 2019-08-26 2017-09-06 2019-08-22 2019-08-12 2018-01-16
2019-08-31 2019-10-17

Exhibit B, Page 90

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 91 of 352 Pageid#: 994

voter_id 205027914 E 917656173 E 919944689 E 918492245 E 125013095 E 901001610 E 307001094 E 608028642 E 641584717 E 804005814 E 918113023 E 919297981 E 708016233 E 919377107 E 917923888 E 919622028 E 601028644 E 918320603 E 803001232 E 803014838 E 802001233 E 918149689 E 387162429 E
51552802 E 262911901 E 919641017 E 917990942 E 980199894 E
23003284 E 208006042 E 738868554 E 918695751 E 123010415 E

lname

fname JANET FAYE LESLIE ANDREW MARY BILLIE PATRICIA BOBBY NORMAN WILLIAM SUSAN WILLIAM WILMA GEORGE LIZZIE EMMA MARY DAVID EDNA GEORGIA IRIS ARLENE FRED WILLIAM ALTHEA LINDA TINA THOMAS WILLIE JANICE HALLIE BRYAN PAULINE

dob 1939 1941 1949 1949 1929 1933 1942 1936 1944 1929 1962 1942 1923 1941 1933 1937 1923 1932 1924 1941 1921 1941 1949 1933 1953 1961 1956 1948 1920 1933 1938 1966 1926

date_registered 1960-04-10 1996-09-14 2004-10-04 2001-09-25 1998-08-13 1972-07-14 1976-09-09 1983-03-17 2016-10-14 1968-11-06 1997-10-03 2002-03-28 1966-11-09 2002-08-19 1997-03-10 2003-11-05 1955-02-25 1998-08-19 1992-09-03 1964-10-02 1943-06-12 1997-10-07 2018-06-28 2010-09-20 2008-01-14 2003-11-14 1997-04-19 2008-10-02 1990-10-06 1954-02-01 2015-09-21 2004-11-04 1970-05-08

ssdi_dod 2018-05-16 2019-12-10 2019-09-09 2019-12-09
2019-12-27 2019-11-29 2019-11-18 2019-09-25 2019-09-12 2019-08-27 2018-06-26 2017-02-25 2015-03-21
2020-01-01 2019-12-08 2019-09-15 2019-09-09 2019-07-26 2019-02-17 2019-01-29 2018-12-23 2017-11-18 2010-11-10
2019-12-03 2019-07-16 2019-07-09

obit_dod 2018-05-16 2019-12-10 2019-09-09 2019-12-09 2019-10-16 2019-01-20
2019-11-29
2019-09-25 2019-09-12
2018-06-26 2017-02-25
2019-08-11 2019-06-08 2019-01-06 2018-04-19
2019-12-08 2019-09-15 2019-09-09
2019-02-17 2019-01-29
2017-11-18
2018-12-30 2019-12-03 2019-07-16 2019-07-09

Exhibit B, Page 91

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 92 of 352 Pageid#: 995

voter_id 3002287 E
918185418 E 790361854 E 903016837 E 104005586 E 508012710 E 205010803 E 613035042 E 502028038 E 904006497 E 903006497 E 226009585 E 201030144 E 703012580 E 262841325 E 919080715 E 105000807 E 918051001 E 917168489 E 505733702 E 833204161 E 920358198 E 132231767 E
13963314 E 919670563 E 918310267 E 412015206 E 121015426 E 308044116 E 918081980 E 306010357 E 902002209 E 919840065 E

lname

fname RAYMOND HUBERT VELMA ROBERT LOUIS ROBERT SHIRLEY FRANKLIN GAYLE JONNIE JAMES KARL JENNIFER RUTH BENJAMIN STELLA ARETHIA HILTON ARTURO SOLEDAD VICTOR SHIRIN LEO DORIS MARION IRIS TRACY NAOMI SALLY WILLIAM MARY JOHN JUANITA

dob 1935 1935 1926 1931 1937 1945 1940 1942 1933 1940 1934 1931 1972 1923 1935 1946 1930 1951 1952 1912 1922 1945 1928 1925 1929 1948 1954 1945 1931 1931 1930 1944 1947

date_registered 1960-09-30 2000-10-10 2015-08-20 1956-09-14 1987-05-18 2000-05-03 1986-04-22 1997-12-18 1955-05-03 1984-03-23 1984-03-23 1971-09-30 1991-10-03 1998-06-01 2012-05-02 1977-06-11 1983-09-20 1997-07-29 1997-04-14 2012-10-15 2009-01-20 2006-09-13 2012-08-22 2012-10-05 2004-01-12 1998-07-14 1988-10-06 1980-09-04 1992-09-10 2003-09-30 1970-10-03 1993-10-02 2004-07-20

ssdi_dod 2019-11-15 2019-11-25 2019-03-12 2018-12-17 2017-01-09 2019-11-01 2019-11-19 2019-08-22 2017-08-17
2019-05-31 2019-07-21 2019-12-09 2019-11-21 2018-12-28 2017-06-29 2019-04-14 2018-12-30 2013-05-06 2019-03-30 2018-10-24 2019-07-20 2018-02-12 2019-12-17 2019-11-10 2017-10-18
2018-07-23 2019-12-17 2019-11-15 2019-12-22 2019-10-13

obit_dod 2019-11-15 2019-11-25 2019-03-12 2018-12-17 2017-01-09 2019-11-01 2019-11-19 2019-08-01 2017-08-17 2018-02-09 2017-06-02
2019-07-21 2019-12-09
2018-12-28 2017-06-29 2019-04-14 2018-12-30
2019-07-20 2018-02-12
2019-11-10 2017-10-18 2018-12-08 2018-07-23
2019-11-15 2019-12-22 2019-10-13

Exhibit B, Page 92

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 93 of 352 Pageid#: 996

voter_id 127007897 E 173688301 E 607026119 E 609027849 E 919504271 E 228011236 E 917854182 E 704028045 E 302027139 E 103029954 E 917784833 E 919782124 E 920210817 E 920210052 E 340322983 E 705007179 E 603029690 E 918623498 E 704015560 E 310186749 E 615092047 E 918951807 E
30000075 E 917536861 E
33889113 E 233010528 E
11527309 E 309009926 E 104018770 E 605021684 E 711019044 E
21012158 E 905020042 E

lname

fname DIAMOND MARY JUANITA ROBERT BENJAMIN DOTTIE M RAY ELSA DONALD JULIANA SYLVAIN-JACKSON FELICIANO JULIETA PATRICIA BRENDA BETTY BERTA CHARLOTTE DORA MELVA ROSARIO ELIJAH GERALDINE HARVEY JERRY FRANK CAROLE ELIZABETH RICHARD PATSY ROSCOE FRANCIS

dob 1925 1945 1929 1929 1941 1934 1942 1927 1940 1949 1938 1944 1935 1943 1947 1946 1938 1943 1931 1940 1924 1917 1953 1945 1944 1943 1954 1945 1916 1934 1941 1935 1950

date_registered 1972-03-30 2012-10-12 1950-09-03 1956-10-06 2003-04-17 1976-09-30 1996-12-26 1969-09-06 1996-10-07 1991-09-25 1996-10-07 2004-06-14 2005-11-16 2005-11-15 2008-01-28 1976-10-02 1960-04-27 1999-11-03 1956-09-23 2007-10-02 2016-04-13 2000-10-10 1988-09-14 1996-06-24 2016-10-07 1964-04-06 2017-09-25 2000-05-18 1951-04-10 1979-09-13 1988-10-01 1997-05-06 2006-08-03

ssdi_dod 2019-02-12 2018-12-14 2018-04-10 2016-03-09
2019-12-06 2019-04-07
2018-01-04 2018-06-14 2015-07-07 2007-08-01 2019-12-18 2019-11-27 2019-10-20 2016-04-23 2015-03-31 2018-01-29 2018-10-05 2018-03-07 2018-12-09 2018-12-04 2018-08-28 2018-05-29 2018-02-26 2019-08-18 2019-10-29 2020-01-07 2019-01-30
2019-10-23

obit_dod
2018-04-10 2016-03-09 2015-08-31 2019-12-06 2019-04-07 2019-10-06 2017-01-19 2018-12-11
2019-12-18 2019-11-27 2019-10-20 2016-04-23
2018-01-29
2018-12-09 2018-12-04 2018-08-28
2018-02-26 2019-08-18 2019-10-29
2019-08-06 2019-10-23

Exhibit B, Page 93

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 94 of 352 Pageid#: 997

voter_id 210020059 E 918035469 E 918308037 E 602009752 E 513678922 E 904017327 E 918243499 E 211831562 E 701000112 E 545466219 E 231007546 E 918812853 E 917600219 E 920377917 E 431904055 E 601001019 E 919111114 E 205009506 E 201009460 E 917561878 E 227013251 E 901021623 E 917388345 E 311047442 E 307047429 E 416018605 E 311016720 E 920075476 E 402029566 E 501004198 E 612003513 E
26009113 E 917345133 E

lname

fname RALPH GERALDINE GEORGE JOHN GERALD MARIE BONNIE JESSIE MICHAEL RUBY MARIA JENNA RUPPERT APRIL CHERYL LATANE NANCY TINA CHRIS DERRYCK TIMOTHY MURRAY KRISTIN EDKER JANET AUDREY ROBERT BARBARA MARILYN VERNON LEONARD ELLEN MICHAEL

dob 1919 1933 1944 1933 1945 1944 1948 1925 1957 1952 1943 1980 1927 1988 1981 1933 1943 1965 1943 1970 1947 1934 1948 1942 1939 1944 1948 1937 1927 1930 1948 1954 1967

date_registered 2001-09-06 1997-08-07 1998-07-29 1980-11-05 2012-08-28 1980-10-01 1998-04-09 2017-04-14 1979-09-17 2016-10-05 1992-05-06 2000-06-29 1999-02-09 2006-10-10 2017-11-09 1968-10-05 2006-05-03 1983-09-10 1970-05-08 2016-03-02 1980-07-19 1968-10-04 1996-01-19 2005-05-02 2004-02-12 1989-09-20 1992-10-03 2005-03-29 1979-10-02 1983-01-27 2007-02-26 1984-03-30 1995-09-22

ssdi_dod 2020-01-02
2020-01-28 2020-01-21 2020-01-04 2019-11-24 2019-11-22 2019-11-20 2019-11-18 2019-11-06 2019-11-05 2019-10-04 2019-08-23 2019-08-01 2019-03-07 2019-01-29 2018-12-21 2018-12-12 2018-12-07 2018-09-26 2018-06-24 2018-01-21
2019-08-16 2019-11-02 2018-02-24
2019-10-02 2014-09-11

obit_dod
2019-09-08
2019-11-22
2019-11-18 2019-11-06 2019-11-05 2019-10-04 2019-08-23
2019-03-07 2019-01-29
2018-12-12 2018-12-07 2018-09-26
2019-10-29 2019-08-15 2018-12-18 2018-04-22 2017-04-06 2019-08-16 2019-11-02
2019-08-16
2014-09-11

Exhibit B, Page 94

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 95 of 352 Pageid#: 998

voter_id 559946436 E 456544278 F 917306136 F 603029436 F 917360031 F 305038755 F 919027532 F 809001725 F 804002548 F 919014290 F 704002108 F 225003489 F 917251730 F 407012888 F 601005039 F 179879353 F 227005699 F 301015294 F 705018506 F 919931985 F 304013540 F 155289477 F 919555431 F 917593203 F 769619373 F 119142056 F 808012053 F 209004253 F
24012350 F 408016621 F 602027473 F 917320568 F 813014105 F

lname

fname BARBARA TODD JANET JUNE RICHARD WILLIAM JERRY DEWEY CAMILLA JOYCE LAYTON NANCY ANNE ETHEL LILLY MARY EDWARD LEONARD MONICA SUSAN RICHARD HU YU CHIAO JOANN LAVERNE CHARLES BETSY NELL SALLIE EDWARD DARYL JAMES WANDA MARSHALL

dob 1950 1976 1943 1935 1946 1932 1938 1930 1931 1947 1927 1944 1946 1925 1947 1932 1937 1925 1932 1942 1933 1940 1942 1946 1951 1948 1929 1927 1924 1924 1937 1954 1940

date_registered 2013-07-30 2016-05-02 1995-08-04 1956-09-06 1995-10-10 1995-02-18 2001-01-04 1989-07-25 1966-05-07 2001-01-03 1959-09-30 1986-01-08 1995-03-15 1976-03-20 1968-06-07 2014-03-24 1973-10-03 1964-10-03 1978-05-11 2004-09-29 1968-09-26 2007-02-12 2003-07-16 1996-08-13 2007-11-29 2014-08-05 1977-04-20 1948-09-24 1999-02-23 1976-09-07 1970-05-09 1995-09-08 2001-07-24

ssdi_dod 2018-07-12 2019-11-30
2018-12-20 2018-12-04 2015-04-09 2020-01-21
2019-12-21 2019-12-24 2019-09-17 2018-02-19 2018-12-18 2019-11-24 2019-09-30 2019-07-26
2018-05-16 2020-01-25 2019-02-25
2019-05-11
2019-10-18 2019-11-09 2019-11-25 2019-12-30 2019-08-27 2019-11-23
2020-01-28 2019-10-22 2018-12-23

obit_dod
2019-11-30 2019-10-23 2018-12-20 2018-12-04 2015-04-09
2019-10-01 2019-12-21
2018-12-18
2019-09-30 2019-07-26 2018-12-12 2018-05-16
2019-08-31
2019-05-13 2019-10-18 2019-11-09 2019-12-01
2019-08-27 2019-11-23 2018-12-23
2019-10-22 2018-12-23

Exhibit B, Page 95

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 96 of 352 Pageid#: 999

voter_id 602012069 F 919565449 F 402020796 F 302018279 F 503006294 F
44930883 F 605005366 F
72426410 F 121041775 F 501031019 F 918367592 F 226003697 F 204023817 F 907005261 F 919897046 F 903004972 F 906012194 F 212023698 F 918365151 F 917799187 F 919500885 F 917397586 F 408016396 F 918919774 F 904020334 F
21017623 F 718010922 F 917812672 F 741823211 F 709004630 F 918183783 F 902022387 F 323778181 F

lname

fname KENNETH LACY LILLIAN BETTY KIRSTEN STERLING ANDREW MARIE ZAHOOR DEBORAH FARRO THOMAS SUSIE VIRGINIA ROBERT EVELYN MARGARET LOUISE GAYLE PATRICK LEONA ANN VERNA HARRY DAVID ROBERT KEVIN RANDY NATHANIEL EVEYLN RUSSELL PHOEBE LAWRENCE ELINOR

dob 1941 1933 1930 1929 1949 1943 1937 1929 1936 1962 1948 1935 1919 1935 1941 1939 1925 1940 1961 1936 1920 1932 1943 1936 1936 1967 1955 1953 1928 1947 1938 1941 1930

date_registered 2000-04-20 2003-08-01 1964-09-22 1972-03-16 2000-08-07 2011-11-10 1984-08-21 2013-04-26 2011-09-22 1988-12-05 1998-10-05 1976-10-02 1964-05-22 1964-09-21 2004-09-16 2004-08-19 1948-11-05 1999-09-27 1998-10-05 1996-10-07 2003-04-11 1996-02-16 1972-04-26 2000-10-04 1964-09-11 1992-05-28 1980-10-02 1996-11-06 2009-10-05 1988-10-07 2001-07-31 1976-04-03 2014-04-04

ssdi_dod 2016-12-20 2016-09-07
2019-09-20 2019-09-09 2019-12-08 2019-10-13
2018-06-28 2018-12-14 2018-03-11
2019-12-14 2019-11-26 2019-01-28 2018-12-20 2019-12-25 2019-10-09 2019-07-09
2019-12-02
2019-12-20 2019-12-25 2019-03-16 2019-11-28 2018-12-01 2018-01-11
2019-10-21

obit_dod
2016-09-07 2019-08-01 2019-09-20
2019-10-13 2019-10-09
2018-12-14
2019-09-03 2019-12-14 2019-11-26 2019-01-28 2018-12-20
2019-10-09 2019-07-09 2019-10-13 2016-03-19 2019-12-02 2019-09-14
2019-11-28
2018-01-11 2018-07-11 2019-07-30 2019-10-21 2018-06-10

Exhibit B, Page 96

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 97 of 352 Pageid#: 1000

voter_id

lname

102008844 F

902026784 F

404014440 F

917871094 F

124012937 F

28000802 F

403018607 F

634910742 F

909023104 F

918887787 F

918211676 F

304013085 F

610032015 F

464217101 F

917179039 F

10868485 F

726719840 F

918480487 F

223020310 F

706007866 F

918798831 F

475035518 F

917321711 F

918103011 F

903021625 F

918273821 F

403007712 F

917561325 F

36078887 F

801011705 FI

221010533 FI

314702663 FI

605027487 FI

fname ANN DANNY JERE CARL RAYMOND FRED KATHERINE JANETTA CHUN JA DELORES CLYDE ANNE HUBERT DAVID FELICITA LUZ AGRIPINA ANNE WILLIAM KENNETH EDDIE SELESTA BETTY ARDITH ANTHONY BENJAMIN OSCAR SUSAN DEBBIEANN CHARLES BARBARA HERMAN NILE

dob 1943 1944 1946 1934 1925 1932 1941 1946 1930 1932 1938 1922 1951 1946 1945 1957 1929 1938 1925 1929 1950 1936 1941 1930 1959 1968 1927 1938 1955 1932 1927 1943 1939

date_registered 1980-09-09 1968-09-30 1981-10-03 1997-01-17 1964-09-19 1980-04-03 1976-10-01 2008-06-18 1988-09-03 2000-09-08 1998-02-02 1952-04-06 1988-09-26 2010-04-26 2000-03-01 2014-07-25 2008-10-04 1999-07-07 1956-07-16 1956-04-28 2002-03-14 2007-12-17 2003-10-06 1997-09-18 1999-03-18 2001-03-07 1964-09-29 1996-07-22 2018-06-25 1968-10-02 1975-01-28 2008-09-24 1963-06-08

ssdi_dod 2020-01-02 2019-12-31 2019-12-23 2019-12-16 2019-11-26 2019-08-29 2018-07-02 2018-01-20 2015-08-09 2008-10-07
2019-01-24 2019-11-15 2020-01-08 2019-10-14 2015-06-17 2018-01-08 2019-10-29 2019-12-17 2019-10-13 2019-08-18 2019-07-30 2019-03-18 2019-01-09 2018-12-05 2017-12-16 2017-11-30
2019-10-12
2019-11-24 2019-10-27

obit_dod
2019-11-26 2019-08-29 2018-07-02 2018-01-20
2019-09-15 2019-01-24 2019-11-15
2019-10-14 2015-06-17
2019-12-17 2019-10-13 2019-08-18 2019-07-30
2017-11-30 2019-09-01
2018-12-16 2019-08-03 2019-11-24 2019-10-27

Exhibit B, Page 97

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 98 of 352 Pageid#: 1001

voter_id

lname

918396238 FI

608026752 FI

602026372 FI

253673004 FI

917512197 FI

920233338 FI

208007267 FI

612025753 FI

919992009 FI

919401056 FI

103616853 FI

107022573 FI

917897090 FI

360101199 FI

903018222 FI

205019046 FI

197992995 FI

305013086 FI

704003970 FI

23006644 FI

906007071 FI

307051310 FI

918373195 FI

309005351 FI

806016556 FI

602002675 FI

221012213 FI

918870495 FI

604021016 FI

920305567 FI

643573480 FI

918830572 FI

918371100 FI

fname JAMES ARTHUR BOBBY DARRELL JOHN WALTER WILBERT TOM WILLIAM NILTON ROSEMARY LISA FRANCISCO PHILIPPE EUNICE JERALD JEAN LEE GERALDINE VIVIEN SHIRLEY LESTER ELONA JOHN SARAH NANCY ROSEMARIE MICHAEL PHILIP JAMES SUZANNE MARGARET EDWARD

dob 1971 1952 1934 1960 1942 1944 1933 1942 1932 1933 1935 1932 1951 1951 1935 1927 1958 1922 1925 1924 1938 1925 1954 1937 1963 1940 1939 1946 1942 1946 1939 1965 1942

date_registered 1998-12-08 1974-08-14 1996-10-07 2007-06-09 1999-11-16 2005-12-22 1980-01-29 1992-09-15 2004-10-04 2002-09-25 2008-10-06 1977-10-05 1997-02-10 2013-12-05 1964-10-03 1966-06-08 2014-10-07 1967-10-07 1983-07-16 1951-03-26 2000-04-03 1997-07-23 2000-01-05 1977-05-14 2006-11-21 1982-11-03 1986-05-07 2000-09-05 1980-04-18 2006-06-14 2007-12-05 2000-07-24 1998-11-05

ssdi_dod 2019-10-06 2019-09-26 2019-07-01 2019-04-23 2019-01-11 2017-07-19
2019-11-04 2019-09-07 2018-12-07
2019-08-06 2017-12-19 2019-09-28 2019-02-21
2019-09-23 2016-11-28 2019-11-30 2019-09-18 2019-09-27
2017-06-21
2019-11-07 2018-05-17 2019-09-03 2019-10-22 2019-10-17
2019-11-01 2016-09-03 2016-07-07

obit_dod 2019-10-06 2019-09-26 2019-07-01 2019-04-23
2017-07-19 2017-02-08 2019-11-04 2019-09-07
2019-07-30 2019-08-06
2019-09-28 2019-02-21 2019-08-12
2016-11-28 2019-11-30 2019-09-18 2019-09-27 2019-09-10 2017-06-21 2018-12-30 2019-11-07 2018-05-17
2019-10-17 2019-03-18 2019-11-01 2016-09-03 2016-07-07

Exhibit B, Page 98

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 99 of 352 Pageid#: 1002

voter_id

lname

808014842 FI

405023835 FI

917728706 FI

782065571 FI

708014262 FI

306030210 FI

58680212 FI

508023739 FI

414005212 FI

214022382 FI

919727919 FI

904004695 FI

919109086 FI

704014263 FI

601002854 FI

4003484 FI

917201148 FI

513680371 FI

101021072 FI

201011189 FI

905020338 FI

236042621 FI

919724669 FI

903005547 FI

302010821 FI

604020118 FI

703000692 FI

2888367 F

709019273 F

918887993 F

501010455 F

608028082 F

783652351 F

fname BERNARD HALLIE CARRIE SUZANNE CHARLES KATHERINE KIRBY GEORGE CHARLES CLYDE ARTHUR JAMES CHERYL ALVIE GARY BARBARA CARL HENRY ISABELL BARBARA PATRICIA DARRYL EDWARD SUSAN ROSITA ALICE JACKIE BRIAN DAVID SHARON HERBERT LOTTIE MARGARET

dob 1937 1935 1928 1938 1959 1920 1942 1942 1972 1944 1949 1930 1950 1939 1934 1947 1927 1948 1930 1932 1931 1966 1954 1959 1932 1927 1939 1941 1948 1945 1928 1924 1922

date_registered 1987-09-29 1992-04-03 1998-11-04 2007-08-30 1984-09-25 1985-09-18 2016-05-11 1971-07-12 1997-09-05 1991-10-02 2004-04-02 1958-02-12 2001-05-14 1991-09-19 1959-06-13 1968-10-05 1994-10-11 2007-01-04 1955-02-21 2004-09-14 1966-05-19 2016-10-04 2004-07-26 1999-10-04 1978-03-18 1949-06-30 2006-11-27 2017-05-15 1989-09-16 2000-09-12 1983-09-23 1945-10-06 2008-10-06

ssdi_dod 2019-11-11 2019-10-19 2019-10-18 2019-10-13 2019-07-01 2018-12-19 2018-10-28 2018-02-18 2017-08-07 2008-06-10
2019-11-19 2018-12-15
2019-12-19 2020-01-13 2019-12-21 2019-11-10 2019-09-19 2019-08-27 2018-01-19 2017-12-20 2016-01-05 2014-09-19
2015-11-23
2019-09-17 2016-09-03 2020-01-22 2018-03-27 2017-01-03

obit_dod 2019-11-11 2019-10-19 2019-10-18 2019-10-13 2019-07-01
2018-02-18 2017-08-07 2008-06-10 2018-12-30
2019-10-25 2019-12-19
2019-12-21 2019-11-10 2019-09-19 2019-08-27
2016-01-05
2019-09-23 2015-11-23 2019-07-29 2019-04-15
2018-03-27

Exhibit B, Page 99

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 100 of 352 Pageid#: 1003

voter_id 501010649 F 918546948 F 703012057 F 701012057 F 614023164 F 608010630 F 708002110 F 917560679 F 917343821 F 409025096 F
59362564 F 205025742 F 401003450 F 124011238 F 918925781 F 484496346 F 920032490 F 102002009 F 303017152 F 918449559 F 604001827 F 708003359 F 702001193 F 301042517 F 311044360 F 917793703 F 303044360 F 104019707 F 124005181 F 428562133 F 335246466 F 919405305 F
28005027 F

lname

fname DAVID MARILYN PEGGY MATTIE PATRICIA SHARON L JOSEPH BERRIS GAYE KENNETH RUFUS DODSON FRANCES WILLIAM EVERETT HAZEL MARIE GERALD DORIS DAISY MILDRED STEVE MARGARET THEODORE SANDRA EILEEN MANUEL THOMAS LAWRENCE LARRY ALMA GERTIE ELEANOR

dob 1944 1932 1942 1930 1934 1947 1939 1956 1938 1932 1965 1940 1924 1931 1939 1930 1936 1934 1936 1919 1921 1945 1920 1946 1937 1943 1934 1943 1926 1947 1926 1937 1932

date_registered 1983-07-29 1999-07-22 1967-10-07 1983-09-30 1991-08-08 1972-09-29 1983-09-26 1996-07-16 1995-09-29 2000-10-10 2011-11-17 1961-10-03 1962-05-15 1964-09-28 2000-10-05 2011-02-04 2004-12-09 1990-07-12 1960-10-03 1999-03-02 1972-11-08 2004-02-20 1947-05-08 1995-07-03 1997-08-25 1996-11-06 1983-10-08 2003-06-13 1955-12-15 2008-12-04 2012-10-11 2002-09-16 1956-09-15

ssdi_dod 2019-09-14 2018-12-27 2018-08-02 2017-06-20
2019-11-04 2019-11-27 2019-11-05 2019-10-17 2019-10-06 2019-04-09 2018-12-31 2018-03-27 2001-07-29
2020-01-09 2019-12-11 2019-11-30 2019-11-06 2018-10-20 2018-01-12
2018-04-30 2018-10-18 2019-11-20
2019-10-28 2020-01-05 2018-12-22

obit_dod 2019-09-14 2018-12-27
2017-06-20 2019-10-24 2019-11-04 2019-11-27
2019-10-17
2018-12-31 2018-03-27
2019-10-27
2019-12-11 2019-11-30 2019-11-06
2018-01-12 2019-09-15 2018-03-29 2018-09-14 2018-04-30
2019-11-20 2019-08-05 2019-10-28
2018-12-22 2019-09-26 2018-02-26

Exhibit B, Page 100

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 101 of 352 Pageid#: 1004

voter_id 104007542 F 227012915 F 802020689 F 918264764 F 186831762 F 301039603 F 306009349 F 906015345 F 703001399 F 173813574 F 223017533 F
97412913 F 109019083 F 918794294 F 229016390 F 607024576 F 513003234 F 919563853 F
31015846 F 602025173 F 919878136 F 505011332 F 917538893 F 405005554 F 902015825 F
46870179 F 906005862 F 203013267 F 803007938 F 919421956 F 122016301 F
9006562 F 601037936 F

lname

fname JAMES BENITA JERRY BARBARA PHILIP MARY MADELINE KATHARINE THEODORE MARVIN ALTA ROBERT FRANCES MARGARET GAYLE JAMES JANET JUAN ALENE VIRGINIA MAX BARBARA JAMES PEGGY CHARLES ODEMIR ETHEL GAYNELLE JAMES THOMAS DORIS EARNEST LOU

dob 1935 1940 1942 1931 1930 1940 1933 1934 1937 1951 1928 1948 1938 1965 1937 1940 1952 1939 1925 1918 1946 1935 1959 1928 1933 1936 1939 1942 1934 1930 1927 1946 1927

date_registered 1964-10-03 1982-04-03 1994-09-10 2000-07-06 2013-06-20 1987-04-23 1988-08-15 1959-05-01 1980-09-20 2017-03-08 1951-01-29 2016-10-12 1984-04-12 2000-06-02 1997-12-05 1962-11-07 1991-08-19 2003-07-30 1964-10-03 1939-10-07 2004-09-10 1992-09-17 1996-07-03 1998-09-25 1968-09-30 2014-05-20 1984-03-30 1983-10-01 2001-12-12 2005-03-24 1955-02-08 1992-10-03 2000-07-18

ssdi_dod 2019-11-26 2018-04-03
2018-01-26 2019-12-17
2020-01-06
2019-04-17 2019-09-06 2019-06-13 2019-12-04 2018-11-25 2018-01-04
2016-12-06 2019-03-14 2018-04-13 2019-12-08 2019-12-05 2018-03-30 2017-12-01
2019-11-18 2019-09-20 2018-12-06
2019-10-05 2018-09-16

obit_dod 2019-11-26 2018-04-03 2019-08-27 2019-09-10
2019-12-17 2018-12-21
2019-04-05 2019-04-27 2019-09-06
2018-01-04 2019-10-17 2016-12-06
2019-12-05 2018-03-30 2017-12-01 2019-08-27
2018-12-06 2019-08-22 2019-10-05 2018-09-16 2019-09-10 2017-12-28 2019-10-15

Exhibit B, Page 101

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 102 of 352 Pageid#: 1005

voter_id 308037567 F 123020023 F 917765059 F 502003787 F 899775255 F 908004089 F 920188246 F 408014556 F 231654459 F 920416673 F 920259659 F 401024780 F
52207776 F 97702261 F 213010500 F 914816029 F 709000428 F 918354523 F 710009509 F 201024357 F 919267017 F 514016884 F 49244596 F 580609639 F 301007969 F 401021706 F 121003609 F 208016546 F 126019587 F 917424677 F 918035642 F 608017133 F 306021677 F

lname

fname MAUREEN CHRIS GLENN LARRY RAYMOND EMMIT JOSEPH CARRIE ERNEST MARJORIE THOMAS PHILOMENA BENJAMIN JULIA NORMAN JOHN JEAN JAMES BETTY WILLIS PAUL PAUL FRANCES WALTER KATHARINE MALINDA ALMA JOE LYNDEL EDITH RALPH ARDEN LAWRENCE

dob 1939 1950 1949 1946 1944 1941 1953 1935 1948 1941 1941 1926 1948 1966 1929 1943 1935 1950 1938 1941 1953 1947 1937 1977 1937 1946 1925 1944 1935 1946 1949 1924 1953

date_registered 1964-02-21 1983-10-03 1996-10-07 1983-10-03 2008-07-02 1999-08-27 2005-10-07 2004-08-02 2016-09-06 2006-12-07 2006-03-06 1970-09-19 2014-08-12 2008-09-26 1996-11-06 2007-06-20 1975-11-05 1998-09-29 1984-03-23 1971-10-02 2002-02-01 1988-10-04 2016-09-29 2008-09-30 1974-08-29 1983-10-08 1993-01-04 1992-10-01 1972-09-22 1996-03-12 1997-06-28 1992-09-19 1980-04-17

ssdi_dod
2019-11-05 2019-09-22 2019-08-14 2019-05-27 2018-12-19 2017-01-03
2019-11-16 2019-12-23 2018-12-10 2015-10-28 2017-12-29
2019-10-09 2019-08-14 2020-01-03 2019-12-13 2019-10-25 2019-09-20 2019-03-13 2018-10-21 2018-08-28 2015-03-16
2019-11-16 2019-09-30 2019-06-29

obit_dod 2016-02-06 2019-11-05 2019-09-22 2019-08-14
2018-12-19 2017-01-03 2017-03-28 2017-01-27 2018-10-29 2019-11-16
2018-12-10
2017-12-29 2013-08-28 2019-10-09 2019-08-14
2019-12-13
2019-03-13 2018-10-21 2019-04-28
2019-11-19 2019-10-24 2019-10-07 2017-04-21
2019-09-30

Exhibit B, Page 102

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 103 of 352 Pageid#: 1006

voter_id 704024835 F 514016670 F 505026311 F 901020050 F 609016484 F 702004802 F 918938147 F 127001049 F 702000116 F 902020342 F 502020563 F 380335063 F 919006542 F 513144232 F 303048864 F 919552783 F 906015581 F 175680129 F 605005377 F
21021012 F 507023900 F 128333915 F
26010625 F 802010885 F 908011030 F 905010773 F 901021049 F 919854566 F 805007940 F 601001829 F 301048115 F 919106286 F 920257315 F

lname

fname SUSAN NORMAN ELSIE EDWARD ROBERT JAMES FD R TALLY HELEN CHARLES CHESTER HELEN DONALD CARMELLO MARK ETHEL MILDRED JAMES CHRISTINA MARK SHARRON WILLIAM VIOLET TEAJUANA ELSIE CONNIE NINA CHARLES DANNIS VIRGINIA ALICE THELMA ANNA

dob 1960 1930 1925 1935 1927 1925 1938 1926 1948 1942 1928 1930 1930 1941 1953 1915 1935 1947 1930 1937 1944 1935 1936 1963 1933 1922 1926 1946 1934 1934 1944 1922 1926

date_registered 1988-03-10 1961-06-08 1963-06-06 2000-06-14 1996-11-30 1966-11-11 2000-10-10 1959-02-11 1989-04-07 1966-10-08 1967-05-27 2014-06-11 2006-10-04 2008-12-26 2005-08-12 2003-07-10 1985-09-21 2016-09-08 1979-11-06 1996-09-03 1968-10-05 2008-03-24 1992-09-26 1984-09-26 1997-05-12 1964-12-03 1955-03-28 2004-08-26 1976-04-03 1988-03-09 1988-01-11 2001-05-14 2006-02-28

ssdi_dod 2019-08-25 2019-05-23 2013-08-22 2019-11-05 2019-09-28 2019-09-26 2014-06-19
2019-11-12
2019-09-17 2016-08-07 2018-12-22 2019-04-24 2019-12-14 2019-12-10 2019-08-29 2018-07-01 2020-01-09 2019-10-22 2019-01-20 2019-09-19 2019-08-15 2016-06-29 2015-02-04
2019-09-28
2015-03-22

obit_dod
2019-06-01 2013-08-22 2019-11-05
2019-09-26
2019-10-12 2018-01-23 2017-03-27 2019-11-12 2018-12-22
2016-08-07 2018-12-21
2019-12-14
2019-08-29
2019-10-22
2019-09-19 2019-08-15 2016-06-29
2014-06-02 2016-01-25 2019-09-28 2019-06-16 2015-03-22 2019-01-22

Exhibit B, Page 103

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 104 of 352 Pageid#: 1007

voter_id 204015452 F 301007970 F 907006814 F 213074916 F 101032500 F 534584319 F 490344587 F 919174719 F 902526009 F 307004533 F 944789892 F 106006024 F
76153642 F 404030388 F 226015353 F 918003841 F 918992231 F 201030154 F 919648663 F 905010774 F 420874853 F 808012061 F 103016451 F 310033423 F 917932204 F 918483857 F 920135710 F 701006366 F 918970165 F
49678239 F 406031411 F 304053286 F 282729978 F

lname

fname MARY SHARON CELESTINE MARY LESLIE JOYCE JOHN ELLEN PAULETTE CHESTER BARRON RICHARD ETHEL RUTH LOUISE MARIE JEMELVON RUBY CLARA LUCILLE ROBERT KENNETH JOHN OLIVE LYNNE BRIAN JOSEPH RUTH GAY GEORGE JEANETTE BRENDA SHARON DIANE

dob 1940 1934 1924 1924 1960 1935 1942 1936 1955 1943 1934 1945 1920 1937 1936 1957 1946 1928 1939 1945 1948 1944 1925 1949 1972 1933 1940 1945 1946 1924 1944 1943 1942

date_registered 1985-10-05 1988-07-21 1972-10-07 2008-04-10 2017-11-17 2008-10-01 2009-06-12 2003-12-30 2007-03-26 1976-05-08 2007-02-26 1979-08-13 2007-05-31 1998-08-12 2000-05-03 1997-04-28 2000-11-29 1998-10-21 2003-12-15 1980-10-02 2017-01-12 1984-05-02 1966-03-18 1993-09-30 1997-03-17 2001-10-02 2005-07-21 1998-01-15 2000-10-09 2011-01-18 2001-10-19 1992-10-03 2011-10-06

ssdi_dod 2019-11-10 2019-06-10 2019-11-06
2019-10-08 2018-07-19
2018-01-21
2020-01-03 2019-12-12 2019-12-04 2019-10-17 2019-10-15 2019-09-27 2019-09-19 2018-12-17 2017-02-20
2019-11-26 2019-03-11 2019-12-12 2019-09-28 2019-01-26 2018-01-18
2019-11-28

obit_dod
2019-11-06 2016-12-31 2019-10-07 2018-07-19 2015-09-12 2019-10-07 2018-01-21 2019-08-26 2018-12-23 2019-10-19
2019-12-04 2019-10-17
2019-09-19 2018-12-17 2017-02-20 2019-08-17 2016-01-30
2019-03-11 2019-12-12 2019-09-28 2019-01-26
2019-10-21 2019-08-03 2019-06-02

Exhibit B, Page 104

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 105 of 352 Pageid#: 1008

voter_id 305038233 F 408028253 F 919344406 F 110895746 F 917335709 F 104005523 F 803018605 F 225009042 F 108027155 F 602004601 F 306032592 F 658381451 F 706003747 F
48881819 F 228013575 F 205008638 F 304013550 F 602029586 F 919683989 F 919554206 F 101018501 F
22222347 F 608028280 F 404028254 F 304031193 F 405001401 F 122006277 F 508005929 F 920176552 F 207021959 F 917184180 F 801010176 F 918578421 F

lname

fname HELEN NEIL LILLIEMAE EDWARD DONALD MARGARET DAN DOROTHY BRUCE DRURY HARRY WAYNE MELVIN GLORIA IRENE JOE ANN GLENN MILTON SHARON ADOLFO ERCILIA HELEN JOE KATHLEEN MARTIN CHARLOTTE MARIE DOLLY SHIRLEY DONALD SHIRLEY DOROTHY FLORA

dob 1928 1949 1927 1938 1926 1934 1938 1921 1922 1914 1922 1939 1931 1926 1926 1940 1946 1938 1936 1936 1945 1927 1947 1941 1929 1944 1920 1927 1934 1939 1954 1931 1948

date_registered 1976-08-05 1972-09-05 2002-06-13 2015-05-26 1995-09-25 1956-10-06 1988-10-05 1957-03-25 1997-10-06 1987-07-24 1988-02-04 2011-08-01 1964-10-03 2018-10-01 1947-07-03 2000-05-16 2006-03-16 1984-10-03 2004-02-18 2003-07-14 2005-12-05 2018-10-15 1975-04-22 1975-09-13 1987-01-14 2000-07-05 2006-12-27 1988-03-09 2005-09-28 1964-09-19 1996-11-06 1996-09-25 1999-09-09

ssdi_dod 2019-10-09
2019-11-02
2019-07-27 2017-10-07 2019-09-05 2016-11-26 2016-10-02 2001-07-10 2018-01-20 2018-09-24 2019-11-13 2019-12-15 2019-12-10 2019-02-04
2020-01-14
2020-01-10 2018-07-01 2019-12-30 2017-10-06
2019-12-12
2014-10-12
2019-09-30 2019-04-21 2014-10-20 2014-09-03

obit_dod
2018-12-30 2019-11-02 2017-05-31 2019-07-27 2017-10-07 2019-09-05
2016-10-02
2018-01-20 2018-09-24 2019-11-13 2019-12-15 2019-12-10 2019-02-04 2019-08-30
2017-01-31
2017-10-06 2013-08-14 2019-12-12 2019-07-08 2015-03-29
2019-10-27 2019-09-30
2014-10-20

Exhibit B, Page 105

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 106 of 352 Pageid#: 1009

voter_id

lname

707011346 F

601027060 F

387720852 F

808003039 F

23020812 F

308050562 F

226011602 F

407012170 F

610009543 F

54535515 F

501012530 F

409006167 F

608021020 F

504031571 F

919427805 F

228018770 G

308034453 G

306019223 G

601035517 G

606005381 G

614001233 G

101012594 G

908012200 G

32939640 G

207011850 G

715373472 G

919927652 G

918264936 G

175646358 G

919426402 G

501001083 G

839072203 G

46783650 G

fname EARNEST LARRY JUDITH SUZANNE RAYMOND WILLIAM ANN-MARIE LELA MYRON OLETA DAVID WILDA RICHARD CHARLES CLARA MELVA DENISE RAYMOND CHARLES ROBERT MARGARET ELLEN TUCKER MURIEL SEAN PATRICIA CURTIS BYRON KEITH JEANNE ANNA VICENTE CAROL

dob 1936 1949 1948 1932 1927 1931 1948 1926 1944 1921 1949 1944 1950 1943 1949 1923 1942 1927 1931 1948 1945 1937 1935 1925 1967 1932 1935 1958 1954 1930 1916 1942 1947

date_registered 1971-01-18 1970-09-10 2018-11-08 1956-05-29 1992-10-02 1989-07-01 1986-10-04 1947-09-13 1988-09-12 2010-10-08 1980-09-11 1988-08-25 2000-01-06 1984-05-10 2002-11-12 1980-06-25 1989-05-10 1990-07-07 2006-02-04 1984-10-05 1988-09-27 2005-02-10 1984-10-04 2016-03-03 1986-10-04 2012-09-20 2004-09-29 1998-05-09 2011-03-28 2002-10-28 1964-10-02 2008-08-12 2016-08-10

ssdi_dod 2002-02-14
2019-12-31 2020-01-05
2019-10-21 2020-01-22
2019-12-23 2019-04-02 2019-10-07 2019-09-25 2019-09-03 2019-06-25 2018-02-07 2018-12-15 2015-11-29 2019-08-10
2020-01-29 2019-11-22 2019-08-12 2019-08-09 2018-07-23 2017-01-22 2019-12-04 2019-05-30 2018-12-22
2005-09-11 2019-09-12 2019-01-02

obit_dod
2019-10-04
2016-06-14 2015-06-29
2018-11-14 2019-12-23 2019-04-02 2019-10-07 2019-09-25 2019-09-03 2019-06-25 2018-02-08
2015-11-29 2019-08-10 2019-09-25
2019-08-12
2018-07-23
2019-12-04
2018-12-22 2018-03-06 2005-09-11 2019-09-12 2019-01-02

Exhibit B, Page 106

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 107 of 352 Pageid#: 1010

voter_id

lname

507024860 G

214510113 G

903012201 G

504011170 G

920295658 G

739990842 G

917174313 G

4544728 G

918818496 G

5006344 G

301021958 G

122002216 G

308041242 G

20991940 G

285023103 G

507021672 G

209020077 G

227020873 G

25007277 G

709004235 G

918644436 G

905026015 G

901017082 G

919023981 G

406019615 G

123013106 G

918602882 G

332201166 G

82680411 G

26227175 G

903015110 G

366657990 G

127012590 G

fname NOEL CHESTER GENE DOROTHEA PATRICIA RICHARD BETTY JO GEORGE MARTA DOROTHY MARIA ELIZABETH JERRYANN WILLIAM MICHAEL NANCY NANCY DONALD KATHLEEN LINDA RACHEL JOAN PEGGY PAUL FLORENCE VERA SHIRLEY MARGARET DONNA VIRGINIA SAMUEL JAMES DENISE

dob 1924 1942 1937 1919 1953 1952 1927 1965 1922 1920 1930 1929 1938 1966 1956 1951 1935 1940 1942 1943 1938 1935 1928 1939 1942 1931 1938 1948 1964 1944 1924 1931 1945

date_registered 1987-04-22 2010-05-12 1999-02-19 1987-09-21 2006-04-18 2007-07-27 1994-09-21 2018-02-28 2000-07-03 1988-10-07 1999-03-03 1958-12-05 1968-10-05 2016-04-21 2018-04-04 2003-08-25 2000-03-10 1998-08-11 1964-02-24 1974-10-05 2000-05-11 1992-10-03 1964-09-11 2001-01-19 1984-10-06 1984-03-27 1999-10-01 2015-11-27 2016-10-21 2012-04-30 1952-04-21 2008-09-03 1980-08-01

ssdi_dod 2018-01-06
2019-12-11 2019-08-07 2019-07-29 2018-12-27 2018-10-04 2018-04-28 2014-11-12 2009-11-01 2015-03-25
2020-01-26 2017-12-03 2018-12-27 2018-01-14 2020-01-17
2019-12-25
2018-12-23 2020-01-07 2018-12-15 2019-09-27 2019-10-05 2018-08-13 2018-02-05 2018-01-10 2018-12-05 2015-06-30 2019-10-21
2019-04-23

obit_dod 2018-01-06 2017-11-12 2019-12-11 2019-08-07 2019-07-29 2018-12-27 2018-10-04
2015-03-25 2019-06-23
2017-12-03 2018-12-27
2016-07-01
2019-10-18 2018-12-23
2019-09-27 2019-10-05 2018-08-13 2018-02-05
2018-12-05 2015-06-30 2019-10-21 2018-08-08 2019-04-23

Exhibit B, Page 107

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 108 of 352 Pageid#: 1011

voter_id

lname

806014475 G

433323539 G

906007677 G

552331647 G

493306743 G

917469502 G

917286296 G

407003482 G

911020642 G

920138368 G

707015573 G

919282766 G

707021924 G

206009309 G

405002666 G

223011254 G

607028194 G

161247875 G

918057798 G

606001830 G

125016796 G

806011090 G

132007456 G

907002225 G

123075606 G

808019982 G

103003199 G

411002496 G

501021978 G

501009245 G

502010371 G

907020055 G

917877983 G

fname VERA PEDRO JIMMY BENJAMIN CARIDAD JOSE RICHARD MARIA MATTHEW RONALD KYLE DANIEL GAIL HARMON ALVIS MABLE JOHNNY JERRY JAMAL MATTHEW MARGUERITE ROBERT BESSIE EVELYN LUTHER ROBERT DAVID HARRY JOHN TRACY ROY EARL LUCILLE

dob 1923 1977 1943 1926 1937 1948 1941 1940 1928 1950 1938 1964 1933 1954 1937 1926 1955 1953 1950 1930 1920 1940 1929 1928 1931 1935 1935 1934 1947 1973 1940 1931 1932

date_registered 1963-12-14 2008-06-11 1964-10-01 2016-09-23 2008-03-27 2004-09-17 2000-09-05 1968-10-04 1989-10-07 2005-07-27 1983-09-24 2006-12-12 1979-03-31 1999-01-28 1997-11-14 1977-09-27 2000-04-01 2016-09-21 2001-07-25 1959-04-29 1957-01-24 1968-06-07 1992-09-19 1968-09-30 2017-05-22 1968-05-09 1976-09-23 1990-12-07 1975-08-11 1998-08-17 1993-04-15 1964-09-29 1997-01-27

ssdi_dod 2019-12-12 2019-01-16 2018-11-20 2018-02-03 2017-10-15 2009-03-15
2019-12-22 2019-12-08 2019-11-15 2019-09-17 2019-08-12 2018-12-14 2018-12-14 2018-12-04 2018-10-19 2018-04-17 2019-10-31 2018-07-17 2016-09-09
2019-04-08
2020-01-25 2019-11-17 2020-01-22 2019-10-11 2019-09-24 2019-02-23 2018-12-17 2018-09-30 2018-07-03

obit_dod 2019-12-12 2019-01-16 2018-11-20 2018-02-03
2018-06-21
2019-12-08
2019-08-12 2018-12-14 2018-12-14 2018-12-04 2018-10-19 2018-04-17 2019-10-31
2016-09-09 2019-08-13 2019-04-08 2019-09-28 2018-12-11
2019-11-17
2019-09-24 2019-02-23 2018-12-17 2018-09-30

Exhibit B, Page 108

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 109 of 352 Pageid#: 1012

voter_id

lname

406026010 G

306032287 G

703010714 G

602005383 G

902012629 G

654874270 G

22006653 G

13002147 G

603007995 G

919997507 G

303013555 G

20734110 G

918690686 G

607009989 G

273340566 G

302002423 G

83222836 G

603016038 G

205003790 G

306009358 G

302008157 G

919195182 G

303031770 G

919266903 G

607000540 G

920385142 G

903024834 G

439274140 G

24018736 G

603000663 G

306017929 G

280048010 G

260554429 G

fname RUBY ANITA LEE LEWIS JAMES JAMES JOAN ROBERT WILSON MARY NORBY JOHN ALFONSO NAOMI ALBERDINE ALBERT BAHIYA NORMA NANNIE JAMES PAULINE KIMBERLY PAUL FREDERIC SAMUEL BARBARA RONALD RAYMOND ROBERT VIRGINIA HELEN TYRONE JOHN

dob 1921 1923 1937 1934 1930 1940 1933 1930 1942 1921 1944 1947 1950 1923 1937 1929 1944 1930 1926 1927 1927 1964 1932 1943 1939 1928 1929 1951 1934 1927 1935 1987 1947

date_registered 1978-03-10 1955-12-15 1959-04-26 1982-10-02 1990-10-02 2015-04-15 1972-03-23 1981-05-12 1975-04-04 2006-03-20 1986-09-16 2009-06-22 2000-02-17 1992-09-19 2007-04-16 1960-10-08 2016-03-07 1964-09-25 1968-09-26 1972-05-13 2006-09-05 2001-09-27 1999-11-04 2002-01-14 1999-01-28 2006-10-10 2004-04-06 2013-10-11 1956-11-07 1999-10-04 1970-09-29 2012-10-09 2016-12-05

ssdi_dod 2018-06-26
2020-01-11 2017-12-09
2019-10-03
2018-12-14 2019-12-05 2019-08-14 2018-12-20 2019-11-02 2018-12-09 2019-12-23 2018-04-11
2017-05-08 2018-09-09 2020-01-09 2018-03-23
2019-08-13 2019-09-26 2019-12-11 2019-12-02 2019-10-24 2018-10-25 2017-03-23

obit_dod 2018-06-26 2019-09-26 2019-09-22 2019-09-19 2018-12-21 2018-12-09
2019-08-11 2019-10-03 2019-08-09 2018-12-14 2019-12-05 2019-08-14 2018-12-20 2019-11-02
2019-12-23 2018-04-11 2019-10-10 2016-01-30
2018-03-23 2017-03-21
2019-12-02
2018-10-25 2017-03-23

Exhibit B, Page 109

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 110 of 352 Pageid#: 1013

voter_id

lname

303024624 G

656056962 G

78419985 G

502036082 G

920404781 G

308683226 G

101019718 G

308011229 G

508016670 G

105840316 G

310021684 G

605032463 G

301009950 G

302007975 G

629791118 G

919535864 G

920345355 G

919275632 G

502000628 G

4166401 G

401016127 G

609033551 G

315516074 G

636719814 G

2779554 G

505007528 G

917913095 G

226006387 G

307040261 G

807013600 G

225018227 G

610025403 G

917325625 G

fname WILDA CATHERINE ROBERT MARGARET EPHREM RONALD ELEANOR WING LUCY KASONDRA ALICE JOHN EDWIN JOSEF NEYDA MARY JANE JOSEPH EPHIRAM ELI DESEAN WALTER BILLY ROBERT CATHERINE JAMES JANE ARLYN RICHARD JAMES HELEN PATRICIA GLADYS CHRISTINE

dob 1928 1933 1932 1933 1955 1946 1923 1929 1933 1987 1936 1928 1941 1932 1938 1933 1940 1932 1935 1990 1923 1948 1924 1931 1928 1929 1939 1936 1943 1924 1940 1914 1929

date_registered 1972-09-14 2012-10-11 2018-11-08 1984-10-03 2006-11-22 2018-01-11 1990-04-17 1975-09-29 1980-03-22 2014-09-04 1992-04-20 1963-09-27 1980-09-03 1968-03-18 2012-01-10 2003-06-16 2006-08-06 2002-02-21 1984-10-01 2012-03-30 1984-10-02 2006-06-29 2018-08-01 2014-02-19 2019-03-25 2001-07-23 1997-02-28 1967-04-04 1988-04-25 1979-06-22 1968-04-17 1992-05-21 1995-09-14

ssdi_dod 2019-08-07
2019-12-01 2019-09-25 2019-04-15 2019-12-16 2018-06-21 2019-12-28 2019-10-12 2017-07-21
2019-10-11 2019-10-17 2018-01-03 2018-11-25 2019-09-30 2018-10-15 2020-01-01 2019-11-12 2019-11-10
2019-11-01 2019-08-20 2019-12-05 2019-11-24 2019-09-27 2019-09-25 2019-07-07 2018-02-20 2018-01-15 2007-10-02

obit_dod 2019-08-07 2019-08-05 2019-12-01 2019-09-25
2019-12-28 2019-10-12
2019-09-08 2019-10-11 2019-10-17
2019-09-30 2018-10-15
2019-11-12 2019-11-10 2019-08-26 2018-03-05 2019-11-01 2019-08-20 2019-12-05 2019-11-24 2019-09-27 2019-09-25 2019-07-07
2018-01-15 2007-10-02 2019-09-27

Exhibit B, Page 110

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 111 of 352 Pageid#: 1014

voter_id

lname

195754975 G

152823905 G

303007368 G

409025428 G

374732691 G

917505087 G

805018060 G

918957809 G

918732031 G

918592268 G

604012633 G

308023277 G

917682939 G

407026607 G

87234102 G

906000968 G

919956093 G

252347916 G

806009378 G

613027857 G

227013927 G

604029171 G

305002634 G

403005029 G

605001832 G

302047039 G

503008109 G

129018933 G

644943291 G

917868509 G

918253966 G

918009514 G

610007184 G

fname MARIE HOWARD DOROTHY FANNIE TOM EFSTRATIA RALPH LENA QUDRATULLAH JOYCE VICTOR MARY ALPHA ROBERT NAOMI CHARLES GEORGIE SHIRLEY DAVID BETTY EMMA ARTHUR CAROLYN CECIL CHRISTINE DONALD JAMES GATES CHARLES BARBARA SHELIA HELEN SUE

dob 1946 1954 1940 1921 1952 1944 1931 1943 1940 1960 1941 1920 1936 1924 1927 1930 1934 1937 1941 1947 1940 1947 1942 1948 1936 1932 1929 1945 1930 1946 1948 1945 1935

date_registered 2013-07-18 2017-04-19 1977-05-14 1975-04-09 2008-12-11 1996-05-13 1988-04-07 2000-10-10 2000-03-14 2003-01-18 1996-07-05 1973-10-06 1996-09-20 1956-09-05 2012-10-10 1980-02-05 2004-10-04 2018-09-21 2006-02-20 1992-10-02 1980-09-23 1992-09-25 1980-09-24 1998-04-28 1972-08-03 1968-03-22 1963-09-23 2000-10-02 2016-04-01 1997-01-06 1998-05-06 1997-05-07 1988-09-26

ssdi_dod 2018-12-08 2019-08-03 2019-05-16 2012-09-26 2017-03-01 2017-11-30 2014-01-02 2019-12-24 2019-08-02 2019-10-23 2019-08-22 2019-11-21 2019-10-05 2019-08-18
2019-11-20 2019-11-11 2019-11-03 2019-10-31 2019-10-24 2019-10-10 2019-10-05 2019-09-19 2019-09-18 2019-09-05 2019-01-11 2018-12-06 2018-12-03 2018-05-01 2018-03-30 2018-02-06 2013-12-11

obit_dod 2018-12-08
2012-09-26 2017-03-01
2019-10-23 2019-08-22 2019-11-21 2019-10-05
2016-08-06 2019-11-20 2019-11-11 2019-11-03 2019-10-31
2019-10-10 2019-10-05
2019-09-18
2019-01-11 2018-12-06 2018-12-03
2018-03-30
2019-09-23

Exhibit B, Page 111

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 112 of 352 Pageid#: 1015

voter_id

lname

919125655 G

308028971 G

917060555 G

802007265 G

702016558 G

303041249 G

501002954 G

806020729 G

604001667 G

455931682 G

702021778 G

601000062 G

804011302 G

806002207 G

702015578 G

601000811 G

121007250 G

122014799 G

12207761 G

904020351 G

338863266 G

298695834 G

301010383 G

904007088 G

295303975 G

225022068 G

401012472 G

124006279 G

207011581 G

3745418 G

3775348 G

905014611 G

806000449 G

fname JERRY REGINALD DORIS LULA MAE RICHARD CELESTE WILLIAM BETTY FLOYD MEVZETA NANCY JAMES ANNAMAE PHYLLIS MARGARET ANDREW JAMES GERALDINE THELMA MELBA CHARLES JULIA DANIEL CECIL PAUL ELAINE BONNIE ANN DOROTHY KHEM IRENE LEON EDITH

dob 1944 1927 1920 1919 1945 1926 1927 1938 1923 1949 1927 1948 1935 1932 1929 1926 1944 1944 1934 1940 1948 1930 1936 1927 1947 1924 1948 1952 1923 1930 1926 1943 1927

date_registered 2001-06-22 1988-03-13 1993-11-19 1941-10-02 1980-09-24 2003-04-16 1951-10-06 1992-09-12 1970-11-04 2013-07-30 1951-11-15 1988-05-13 1974-04-06 2005-06-29 1980-05-08 1952-05-01 1980-10-04 2004-07-23 2019-07-01 1989-10-02 2016-10-21 2008-09-24 2004-03-19 1956-10-05 2012-03-15 1951-09-28 1987-02-12 1980-10-04 2004-09-23 2017-10-11 2014-05-02 1998-11-04 1950-01-01

ssdi_dod
2019-11-04
2019-12-10 2019-10-20 2019-11-15 2019-11-01 2019-08-24 2018-12-24 2018-01-10 2015-03-27 2019-12-13 2019-12-07 2019-10-20 2019-10-07 2018-10-30 2018-10-23
2020-01-08 2019-12-15
2020-01-14 2019-11-12 2019-10-26 2019-09-17 2018-12-01

obit_dod 2019-08-29 2018-12-09 2018-07-12 2015-11-19 2018-12-27 2019-08-03 2019-11-04 2019-09-10 2019-12-10 2019-10-20
2019-11-01 2019-08-24 2018-12-24
2015-03-27 2019-12-13
2019-10-07 2018-10-30
2018-12-10
2019-12-15 2018-12-27
2019-11-12 2019-10-26
2018-12-01 2019-09-24 2018-12-14

Exhibit B, Page 112

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 113 of 352 Pageid#: 1016

voter_id

lname

920236447 G

107022355 G

917098517 G

131014954 G

918605818 G

704016242 G

508000176 G

607032668 G

917263546 G

919019576 G

708014517 G

769778628 G

22003065 G

607029251 G

702015584 G

224004860 G

918792459 G

605028964 G

104025517 G

197444448 G

659129183 G

890184873 G

504025256 G

666777055 G

183759155 G

706012193 G

122015861 G

508768712 G

555191740 G

910020353 G

703021124 G

307026810 G

919656014 G

fname GEORGE LEONARD ELEANOR MICHAEL RICK WILLIAM WANDA BILLY DEBRA HAROLD JANET SILAS CYNTHIA JESSIE SILAS CYNTHIA FAYE FLORA HERBERT ESTHER BRUCE IVAN HELEN KATHLEEN JOSEPH NINA DAVID THOMAS GENE JOSEPH IRENE KENDALL R

dob 1944 1938 1926 1947 1956 1928 1948 1942 1963 1945 1933 1958 1952 1926 1932 1954 1930 1915 1943 1940 1927 1962 1927 1929 1993 1943 1947 1945 1938 1952 1930 1938 1942

date_registered 2006-01-09 1971-09-01 1994-03-28 1996-09-10 1999-10-04 1971-03-22 1998-09-24 1979-07-25 2000-08-22 2001-01-16 1956-04-25 2010-04-05 1976-09-27 1959-07-18 1959-09-18 1989-09-23 2000-05-25 1967-09-26 1983-09-30 2010-11-03 2014-12-09 2012-05-21 1967-06-10 2016-02-08 2012-12-13 1966-08-17 1975-09-17 2008-02-13 2010-09-02 1997-09-22 1972-09-26 1972-05-12 2003-12-30

ssdi_dod
2019-12-11 2019-11-10 2019-09-30 2018-06-19 2018-08-22 2019-11-03 2019-10-06 2019-02-28 2019-11-27 2019-10-01 2019-09-08 2018-12-02 2018-11-10 2018-03-05 2016-09-22 2016-08-09 2007-12-10
2019-04-22 2017-12-30 2018-09-17 2019-11-02 2017-12-28 2019-10-15
2019-09-19 2019-12-12 2018-07-10 2018-12-04 2019-10-22 2017-05-13 2015-08-16

obit_dod 2018-08-02 2019-12-11 2019-11-10
2018-06-19 2018-08-22 2019-11-03 2019-10-06 2019-02-28 2019-11-27 2019-10-01
2018-12-02 2018-11-10
2016-09-22 2016-08-09 2007-12-10 2019-10-25
2018-09-17 2019-11-02
2019-10-15 2019-08-23 2019-09-19
2018-07-10 2018-12-04
2017-05-13 2015-08-16

Exhibit B, Page 113

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 114 of 352 Pageid#: 1017

voter_id

lname

229008752 G

302013101 G

108019092 G

223021271 G

127019781 G

305006502 G

309047702 G

507020567 G

128019485 G

808020180 G

917822109 G

503004879 G

602000664 G

803012517 G

919361531 G

415283354 G

105021603 G

95148821 G

101023108 G

919476051 G

809001252 G

301010386 G

100809329 G

917450598 G

918452853 G

24014452 G

920414885 G

133494302 G

917073736 G

506003795 G

25010866 G

919083705 G

204005698 G

fname SUSAN CHARLES EMMA GERALDINE MARTHA PHYLLIS CHARLES JAMES LEONARD ROBERT JOHN JOHN CHARLIE ROBERT JOAN ROBERT SAMUEL EDWARD ARTHUR JEFFREY EDITH IVAN ANDREW WILLIAM SUE SALLY ORTIS ROBERT JONATHAN EARNEST BARBARA HUBERT KATIE

dob 1920 1929 1927 1930 1929 1938 1941 1941 1927 1939 1934 1918 1946 1937 1935 1938 1932 1940 1938 1958 1930 1931 1975 1936 1949 1926 1949 1945 1967 1932 1933 1960 1929

date_registered 1951-03-09 1980-10-03 1968-08-27 1986-12-17 1998-11-16 2007-02-06 1992-05-05 1986-09-04 1989-08-30 1984-09-25 1996-11-19 1951-07-05 1999-04-08 1980-08-20 2003-07-24 2011-07-05 1964-03-24 2019-01-08 1988-03-24 2003-02-28 1956-10-04 2002-12-12 2015-03-14 1996-04-06 1999-03-15 1996-11-20 2006-12-13 2012-05-21 1994-02-08 1957-05-04 1984-09-27 2001-04-16 1963-10-04

ssdi_dod
2019-12-25 2019-09-19 2019-10-06 2019-09-22 2018-09-06 2019-02-21 2019-11-22 2019-12-24 2019-12-20
2017-09-23 2017-09-08
2018-12-09 2019-12-21 2019-09-05 2019-01-07 2017-10-18 2019-11-01 2018-06-16
2017-06-10 2019-09-15 2018-03-06 2019-05-30 2016-12-21
2018-12-31 2019-10-03 2019-09-10

obit_dod 2018-01-24
2019-09-19 2019-10-06 2019-09-22 2018-09-06 2019-02-21 2019-11-22
2019-12-20 2016-06-01 2017-09-23 2017-09-08 2019-08-30 2017-10-30 2016-11-08 2018-12-09 2019-12-21 2019-09-05
2017-10-18
2018-06-16 2019-11-08 2017-06-10 2019-09-15
2019-05-30 2016-12-21 2018-12-10
2019-10-03 2019-09-10

Exhibit B, Page 114

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 115 of 352 Pageid#: 1018

voter_id

lname

919931145 G

308015306 G

504029375 G

201007472 G

21021691 G

405020600 G

304004550 G

123000737 G

103011517 G

919997960 G

102019378 G

302017562 G

322772192 G

18571558 G

917315648 G

918512132 G

884358073 G

903010532 G

901021058 G

919370259 G

302042853 G

301005062 G

416456714 G

404025116 G

307015073 G

920061735 G

344840672 G

25077779 G

307003593 G

917723518 G

668661290 G

207602208 G

920157020 G

fname RAYMOND ROBERT HARVEY JUNIOR DEBORAH EDWARD LEWIS MORRIS SYLVIA LESLIE MARIAN SYLVIA RONALD MARTIN EVA FRED RENEE CHRISTOPHER DORIS MORTON JACK JOEL LEON RICHARD HERBERT JEANETTE MARIA MANUEL RALPH MARCO JULIO ALEXIS FRANCISCO

dob 1935 1941 1945 1952 1963 1942 1927 1919 1921 1929 1935 1934 1931 1933 1966 1945 1934 1947 1951 1936 1932 1948 1946 1938 1933 1935 1937 1956 1943 1950 1948 1982 1941

date_registered 2004-09-29 1990-09-15 1975-10-02 1987-05-19 1992-10-03 1998-12-07 1973-09-27 1952-04-29 1979-03-15 2004-10-04 1966-11-15 1964-08-31 2011-08-22 2009-03-11 1995-08-30 1999-05-21 2008-09-26 1987-09-12 1995-01-13 2005-04-29 1977-07-15 1976-09-25 2010-10-12 1984-07-16 1975-10-04 2005-02-16 2008-08-13 2016-08-09 1980-10-03 1996-10-04 2015-04-08 2007-06-19 2005-08-31

ssdi_dod 2018-02-26
2019-11-26 2018-02-14 2017-12-21 2019-10-30
2019-04-12 2005-02-23
2019-09-23 2019-11-07 2019-11-06 2018-03-12 2019-11-08 2019-02-16 2018-12-28 2018-07-29 2016-12-24 2019-09-23 2019-02-18 2019-08-18 2019-05-17
2019-09-05 2019-09-04
2019-09-20 2019-01-24 2018-03-21 2019-10-03

obit_dod 2018-02-26 2018-02-01 2019-11-26 2018-02-14 2017-12-21
2018-10-23
2019-10-14 2019-08-19 2019-09-23 2019-11-07
2018-12-28
2019-02-18 2019-08-18 2019-05-17 2019-08-28 2018-05-08
2019-09-04 2017-11-07
2018-03-21

Exhibit B, Page 115

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 116 of 352 Pageid#: 1019

voter_id

lname

452165673 G

105038620 G

918204615 G

906006822 G

601028667 G

601028092 G

806000270 G

296763800 G

113006197 G

225003343 G

917378962 G

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707015978 G

706015978 G

412255680 G

342321979 G

201005374 G

918270747 G

581282511 G

917826039 G

504003796 G

446542156 G

804015869 G

417135958 G

405011915 G

366268961 G

16040593 G

307022998 G

569532747 G

606008974 G

601003521 G

801005365 G

26015487 G

fname LEONARD SHARON KENNETH DIANA CONNIE SUE NINA JOSEPH MARSHALL THOMAS MARVIA LOTTIE JAMES RICHARD PATSY EUGENE ROSS LOUISE CLEVELAND BOBBIE STANLEY CHARLIE LOUELLA JEANETTE ROGER LOIS DOUGLAS MARGARET FLORENCE ROCHELLE MASAKO JEAN DAPHINE THOMAS

dob 1943 1964 1948 1946 1947 1934 1919 1943 1944 1942 1940 1928 1949 1951 1949 1960 1921 1957 1937 1929 1944 1938 1934 1935 1931 1945 1923 1924 1960 1936 1933 1931 1928

date_registered 2016-06-17 2013-03-08 1998-02-17 1980-09-12 1979-04-09 1984-09-21 1988-04-09 2008-08-13 1993-08-04 1978-03-30 1995-10-23 1998-06-11 1972-09-11 1983-09-07 2008-10-06 2011-07-26 1980-10-04 1998-04-26 2008-10-01 2002-09-18 1979-06-13 2019-03-15 1964-04-28 2018-06-18 1959-06-12 2017-12-15 2016-09-30 1968-04-13 2016-08-01 1984-10-06 1955-12-06 1963-01-24 2003-08-06

ssdi_dod 2016-10-19 2019-10-29 2019-10-25
2020-01-04 2019-06-30
2019-08-08 2018-06-21 2017-07-10 2019-09-30 2019-08-11 2018-12-09 2018-10-25 2018-08-09 2018-01-28 2016-03-31 2019-09-14 2019-10-17 2019-01-06 2018-12-11
2019-08-14 2018-12-30 2017-04-10 2019-10-10 2019-09-26 2018-12-22 2017-11-10

obit_dod
2019-10-29 2019-10-25 2019-08-24 2018-12-31
2019-10-31 2019-08-29 2019-08-19 2018-01-20 2019-08-08 2018-06-21 2017-07-10 2019-09-30 2019-08-11 2018-12-09
2018-08-09
2016-03-31 2019-09-14 2019-10-17 2019-01-06 2018-12-12 2019-04-10
2018-12-30 2017-04-10
2019-09-26 2018-12-22 2017-11-10

Exhibit B, Page 116

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 117 of 352 Pageid#: 1020

voter_id

lname

806005102 G

107022995 G

351662536 G

25012037 G

316488621 G

705016137 G

918771521 G

917946091 G

605006638 G

920418470 G

196628915 G

403011441 G

402000952 G

305011831 G

918178433 G

918394715 G

917227328 G

198162778 G

703007189 G

229012937 G

53247481 G

920332958 G

902021636 G

918115198 G

917136363 G

512035624 G

706003051 G

226023777 G

304025658 G

515008624 G

503027016 G

408027163 G

918317946 G

fname VERNON EDWARD ANN NATHANIEL JOHN REBECCA WILLIAM EDWARD SUSIE F MILDRED TAKEYTA ELSIE RICHARD SHEILA MARGARET A BARBARA SAROJ SHARON MARY ROBERT RICHARD PHILIPPE FRANK GEORGE ALLEN JOHN SANDRA GEORGE MELVIN ROBERT JEAN DOROTHY ROBERT

dob 1936 1931 1938 1939 1942 1954 1932 1942 1922 1928 1981 1930 1953 1943 1947 1943 1943 1947 1945 1945 1934 1975 1924 1950 1928 1941 1936 1955 1927 1928 1923 1929 1936

date_registered 1963-03-02 1964-02-22 2017-08-10 1983-10-05 2018-11-21 1997-06-11 2003-09-22 1997-03-13 1968-10-05 2006-12-20 2009-05-11 1983-08-09 1994-07-12 2006-05-15 2003-03-19 1998-11-12 1997-01-13 2008-10-06 1987-09-12 1988-09-06 2012-03-16 2006-07-27 1999-04-19 1997-10-06 1997-02-18 1992-10-03 1977-03-16 1996-10-07 1979-10-03 1989-09-16 1947-04-09 1964-09-24 1998-08-04

ssdi_dod 2019-10-31 2019-10-11 2019-10-03 2019-08-09 2018-12-17 2018-12-11 2018-02-16
2018-07-31 2018-06-18 2018-01-24
2019-10-20 2019-12-25 2019-08-22
2018-05-17 2019-06-27 2018-02-17 2019-11-28 2019-10-20 2019-09-02
2018-08-10 2018-03-28 2019-12-31 2019-09-28
2019-12-26

obit_dod 2019-10-31 2019-10-11
2019-08-09
2018-02-16 2019-08-27 2018-12-04 2018-10-26
2018-06-18 2018-01-24 2018-12-13 2019-01-21 2019-10-20
2019-01-20 2018-05-17
2018-02-17 2019-11-28 2019-10-20
2019-08-02 2019-05-01
2019-09-28 2019-09-05 2015-06-15 2019-12-16

Exhibit B, Page 117

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 118 of 352 Pageid#: 1021

voter_id

lname

402025821 G

918806594 G

601020126 G

919732692 G

59822190 G

501021980 G

125000075 G

919021581 G

29899278 G

305034468 G

171974630 G

221014263 G

405002132 G

917322138 G

604031131 G

918702962 G

210015896 G

31097941 G

501035699 G

27019111 G

918070849 G

28011656 G

221001948 G

304016734 G

904022395 G

703000306 G

403016968 G

250754152 G

608025930 G

501028584 G

228001591 G

504028065 G

920247435 G

fname MICHAEL MAURICE LEONARD ADRIAN HOLLY WADE ELIZABETH JOSEPHINE DORIAN RAUL ANN JOHN DONALD EDWIN ZELLA TINA JOHN KAREN POUL ROGER SHIRLEY AUSTRALIA JAMES JULIANA MAGNOLIA GLADYS BARBARA LEOTA JULIE FRANCES CONSTANCE BETTY BINA

dob 1948 1930 1939 1946 1965 1942 1942 1923 1972 1941 1921 1923 1935 1935 1923 1945 1939 1952 1954 1927 1935 1938 1938 1921 1927 1921 1945 1929 1945 1941 1937 1930 1931

date_registered 1992-10-03 2000-06-14 1999-02-01 2004-04-05 2009-09-04 1964-02-17 1963-10-03 2001-01-17 2013-11-07 1992-05-09 2013-10-15 1952-03-18 1987-09-26 1995-09-11 1968-05-02 2000-03-01 1995-01-19 2016-09-22 1992-10-03 1955-10-08 1997-08-22 1983-09-03 1964-10-03 1956-05-01 1955-12-27 2004-10-04 2000-03-16 2010-10-07 1992-09-28 1967-08-15 1997-08-01 1967-09-13 2006-02-02

ssdi_dod 2019-11-13 2019-11-12 2019-08-26 2019-01-27 2017-03-23 2013-11-16
2016-08-03 2019-09-24 2016-12-12 2014-11-07 2017-12-31 2019-12-10 2019-05-29 2019-05-10 2019-08-20 2019-11-20 2019-10-17 2016-05-27 2019-11-22 2017-11-25
2019-02-12 2019-01-31 2018-12-29 2018-12-02
2020-01-20 2019-12-23 2019-12-14 2019-11-14 2019-09-30 2019-09-29

obit_dod
2019-11-12
2017-03-23
2019-09-17
2019-09-24
2014-11-07
2019-05-29 2019-05-10 2019-08-20 2019-11-20 2019-10-17
2019-11-22 2017-11-25 2019-08-17
2019-01-31 2018-12-29
2019-08-01
2019-12-23 2019-12-14 2019-11-14 2019-09-30 2019-09-29

Exhibit B, Page 118

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 119 of 352 Pageid#: 1022

voter_id

lname

35142244 G

601032919 G

919686341 G

918367855 G

602033369 G

917993379 G

917894784 G

405016969 G

602019889 G

506011619 G

180241232 G

304013315 G

403023243 G

919788518 G

430217837 G

919032261 G

984969278 G

307035014 G

903020811 G

507006953 G

701009714 G

268255949 G

552105267 G

883204610 G

10578811 G

222002304 G

27015166 G

461228647 G

917951893 G

605028919 G

917318758 G

917731833 G

10548395 G

fname NAN THOMAS MARY ESTER JOSEPH JUSTIN JUDITH JAMES DAVID HELEN EUGENE BENSON ANN CARMELLO PAUL DOROTHY NORMA KARL WILLIAM DAISY CHARLES ALICIA W JOSEPH FRANCES BETTY CHARLIE CATHERINE FLORENCE CHARLES COLIN ANNIE PAUL SEYMOUR

dob 1941 1942 1945 1942 1931 1979 1946 1931 1940 1929 1941 1932 1943 1926 1963 1946 1943 1940 1931 1953 1947 1950 1986 1930 1933 1951 1942 1926 1949 1944 1930 1935 1927

date_registered 2012-09-26 1987-09-16 2004-02-19 1998-10-21 1951-10-03 2000-03-08 1996-12-20 1976-10-02 1977-04-26 1963-10-01 2012-10-15 2000-03-29 2001-12-03 2004-06-21 2010-06-15 2001-02-01 2008-10-06 2004-08-31 1955-10-08 2006-08-09 1971-09-29 2008-10-06 2011-12-13 2017-08-02 2016-09-26 1986-10-03 1972-10-06 2012-10-15 1997-04-01 1965-09-08 1995-09-06 2000-08-09 2019-08-21

ssdi_dod 2019-04-09 2019-03-13 2017-11-01 2017-08-18 2017-04-28 2017-03-31
2019-11-23 2018-12-07 2018-10-31
2019-08-24 2018-10-22 2019-04-11 2019-11-30 2019-11-19 2019-10-25 2019-10-18 2019-10-16 2019-10-11 2019-09-27 2019-06-26 2019-03-28 2019-02-16 2018-01-19 2015-10-29 2014-03-04
2019-12-03

obit_dod
2019-03-13 2017-11-01
2017-04-28 2017-03-31 2018-10-24 2018-09-10 2019-11-23
2018-10-31 2019-09-22 2019-08-24
2019-11-19 2019-10-25 2019-10-17 2019-10-16 2019-10-11
2019-03-28 2019-02-16 2018-01-19 2015-10-29
2019-06-15 2018-09-12 2018-06-29 2019-12-03 2019-09-21

Exhibit B, Page 119

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 120 of 352 Pageid#: 1023

voter_id

lname

310030688 G

405026821 G

917668762 G

918460695 G

917444477 G

907009029 G

919457877 G

28006868 G

606007384 G

23017890 G

802001743 G

762438385 G

920324063 G

206022523 G

919166665 G

307031784 G

128014801 G

920409728 G

653063780 G

229002103 G

703698965 G

165449988 G

918113482 G

409004507 G

501009282 G

917502847 G

302014194 G

228018780 G

918927058 G

605028669 G

920270433 G

918478017 G

307031202 G

fname HARVEY BANCROFT WILMA RODERICK JOAN JO ANN JOYCE BARBARA WILLIAM EVANGELINE MARIE CAROLE SUSAN ORAN PEGGY FRANCES ROBERT GARFIELD RICHARD NORMAN WILLIAM LARRY CORA PAULETTE DAVID AMY MARY JANE KATHLEEN SHIRLEY CARLOS JAMES PAIGE BENJAMIN

dob 1938 1941 1951 1942 1946 1934 1938 1932 1944 1928 1941 1944 1940 1943 1949 1947 1936 1933 1917 1943 1944 1940 1932 1942 1942 1978 1941 1925 1938 1940 1940 1933 1925

date_registered 1991-09-12 1997-07-16 1996-09-07 2007-03-28 2016-10-17 1993-11-03 2003-01-15 1976-10-01 1984-09-20 1954-11-03 1991-08-12 2008-05-15 2006-07-12 1967-07-28 2001-08-20 1999-09-30 1963-10-05 2006-12-01 2015-08-31 1976-03-17 2017-04-28 2016-03-02 1997-09-29 1968-09-26 1971-06-24 2001-01-20 1972-09-01 1956-06-21 2000-10-06 1983-05-19 2006-03-23 1999-04-13 1956-09-29

ssdi_dod
2019-12-22 2019-10-30 2019-09-24 2019-07-14 2019-05-26 2018-12-13 2018-10-31 2018-08-21 2018-03-22
2017-10-06 2020-01-22 2019-10-04 2018-08-19 2018-07-23 2018-03-12 2019-11-23 2019-10-10 2019-09-08 2019-04-08 2018-12-09 2018-03-25 2017-05-29 2018-12-29 2018-03-02 2020-01-17 2020-01-11 2020-01-01 2019-11-29 2019-10-16

obit_dod 2019-09-13
2019-09-24
2019-05-26 2018-12-13
2018-08-21 2018-03-22 2019-11-10 2018-04-13 2019-09-22
2019-10-04
2018-07-23 2018-03-12 2019-11-23 2019-10-10
2019-04-08 2018-12-09 2018-03-25
2019-11-29 2019-10-16

Exhibit B, Page 120

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 121 of 352 Pageid#: 1024

voter_id

lname

601009274 G

701005337 G

919881906 G

807007275 G

401003457 G

525114 G

806006859 G

227001358 G

920386632 G

805000453 G

306002238 G

404017038 G

919599084 G

128000514 G

105005643 G

64092469 G

918637099 G

303038567 G

294321590 G

918452458 G

391091817 G

24000100 G

124009205 G

918661833 G

919870466 G

906022791 G

188920805 G

735782282 G

218015416 G

607027981 G

918016482 G

249701114 G

919867483 G

fname ROBERT LINIA GERALD EVA MAE LAURA SHIRLEY JOHNNIE RICHARD WAYNE SHERRILL WILLARD CAROLYN PAULINE ROGER HAROLD JEWEL AMY LUCY CHARLES DONNA DOLORES JOHN MARTHA LAURA WILLIS WOLFGANG GEORGE CALVIN TERRY JOAN KENNETH CORRINE VIRGINIA THIERRY

dob 1933 1925 1936 1927 1928 1924 1944 1925 1938 1946 1918 1940 1934 1950 1934 1930 1914 1931 1940 1937 1931 1932 1933 1935 1938 1940 1930 1960 1940 1960 1938 1921 1962

date_registered 1962-03-16 1977-10-08 2004-09-13 1964-08-07 1952-12-13 2016-04-11 1988-02-04 1989-07-25 2006-10-06 2004-09-15 1956-06-02 1977-09-22 2003-09-25 1980-08-22 1960-10-05 2016-10-21 1999-11-29 2002-11-07 2014-10-07 1999-03-08 2016-02-08 1958-12-05 2000-04-03 2000-01-07 2013-10-15 1998-05-06 2016-05-09 2008-09-24 2017-11-15 1987-09-30 1998-09-10 2011-05-23 2004-08-27

ssdi_dod 2018-12-09 2018-04-22 2018-03-10 2018-03-10 2017-02-13 2016-10-04 2011-05-11
2019-12-17 2019-06-12 2018-03-25 2017-03-14 2018-12-27 2010-09-30
2016-10-01
2017-08-30
2018-11-11
2018-09-01 2019-11-04 2017-07-22
2018-12-31

obit_dod 2018-12-09
2018-03-10 2018-03-04 2017-02-13 2016-10-04
2018-12-06 2018-10-25 2017-10-27 2019-08-25 2019-12-17 2019-06-12 2018-03-25 2017-03-14 2018-12-27
2019-08-23 2017-03-14
2019-02-06 2017-08-30 2019-06-07
2017-09-12 2018-12-10 2018-07-01
2019-11-04 2017-07-22 2019-07-11 2018-12-11 2018-12-31

Exhibit B, Page 121

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 122 of 352 Pageid#: 1025

voter_id

lname

164195978 G

302024845 G

919058884 G

275131577 G

919659455 G

312005958 G

918762599 G

919033920 G

919028646 G

9259204 G

918745007 G

705017274 G

128002727 G

908015844 G

21012357 G

919206236 G

426941370 G

69350756 G

592027695 G

37942528 G

410000953 G

206000192 G

125805727 G

38949876 G

919435773 G

302030455 G

918564189 G

707015592 G

112022021 G

582738462 G

208007550 G

705027039 G

902021066 G

fname VIRGINIA NORMA PAMELA BETTY JEAN STANLEY PETER RUTH LAURA ALICE PATRICIA SHIRLEY BETTY JAMES GEORGE GEORGE EDELTRUD INES FLORENCE WILLIAM SERAFIM BETTY STEVEN MAE CAROL JAMES CHARLES GEORGE BEATRICE GLORIA VEONA JIMMIE GRACE

dob 1926 1933 1951 1937 1930 1931 1950 1948 1933 1927 1938 1936 1920 1930 1948 1934 1931 1936 1932 1923 1926 1938 1946 1929 1945 1936 1948 1932 1927 1942 1925 1938 1933

date_registered 2009-08-12 1983-03-21 2001-03-13 2010-08-13 2003-12-29 1992-09-14 2000-05-02 2001-02-01 2001-01-26 2015-12-17 2000-03-22 1964-09-30 1944-10-03 1956-04-12 1972-07-24 2001-10-01 2016-10-04 2012-03-19 2007-09-28 2012-07-05 1987-09-14 1966-04-06 2012-10-15 2019-04-12 2002-11-20 1976-10-02 1999-08-19 1983-10-10 1992-08-06 2012-10-06 1970-09-28 1996-08-02 1954-01-01

ssdi_dod 2019-09-11 2019-05-06 2015-11-22 2019-09-12 2019-03-01 2018-12-06 2016-11-30 2015-06-27 2018-11-12 2018-08-10
2019-12-29 2019-10-16 2014-01-14 2019-07-04 2020-01-26 2019-12-04 2018-12-27
2020-01-11 2019-10-03 2019-05-26 2018-12-12 2019-08-12 2018-02-10
2020-01-10 2020-01-11 2019-09-18 2020-01-04 2018-06-12 2019-08-06 2018-05-11

obit_dod 2019-09-11
2015-11-22
2019-03-01
2015-06-27 2018-11-13 2018-08-10 2019-10-24
2019-10-16 2014-01-14 2019-07-04
2018-12-27 2019-09-05
2019-05-26 2018-12-12 2019-08-12
2016-01-10
2019-09-18
2018-06-12 2019-08-06 2018-05-11

Exhibit B, Page 122

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 123 of 352 Pageid#: 1026

voter_id

lname

918359436 G

311014195 G

805020324 G

445377673 G

920196145 G

917147865 G

101002391 G

494672310 G

405000706 G

918808147 G

602000069 G

802011866 G

919276817 G

919266214 G

841793492 G

100528863 H

114004564 H

91752037 H

623079440 H

703017375 H

408024494 H

402016413 H

919305203 H

919686104 H

208001429 H

216025725 H

702018844 H

918213835 H

407027904 H

102014669 H

920205815 H

903020066 H

205016900 H

fname WILLIAM PATRICIA WILLIAM YAKOV JOHN THOMAS THOMAS GENE ERNEST EDITH MARIE MARY GAIL DEAN ROBERT HYUN MARY BENJAMIN JOYCE VIRGINIA RACHEL RUBY THADDEUS MYRTLE C EMALINE MARY RICHARD JOSEPH ROBERT JOAN FAY NANCY

dob 1932 1953 1949 1949 1941 1931 1932 1940 1947 1921 1932 1941 1946 1954 1945 1946 1939 1971 1939 1931 1926 1932 1938 1934 1944 1934 1919 1945 1937 1919 1943 1935 1936

date_registered 1998-10-05 1992-09-15 1971-07-12 2016-01-14 2005-10-11 1996-05-06 1956-05-05 2016-10-17 1988-10-04 2000-06-22 1967-05-25 1981-10-02 2002-02-22 2007-02-13 2008-10-06 2009-12-22 1992-10-03 2012-07-12 2017-08-04 2006-11-09 1947-05-05 1976-09-27 2003-01-09 2004-02-12 1967-09-20 1964-09-29 1952-10-03 1998-03-13 1959-07-16 1971-09-25 2005-11-10 1976-06-15 1987-03-30

ssdi_dod 2019-08-24 2018-01-27 2018-04-02 2019-07-02 2019-05-31
2017-01-16 2018-09-04
2019-11-02
2018-05-05 2019-08-17 2018-01-14 2019-12-10 2018-11-28 2019-10-04 2018-12-04 2019-10-23 2018-12-26
2019-08-12 2019-11-07 2019-08-09 2019-05-21 2016-03-11 2019-12-27
2019-09-05 2019-09-06

obit_dod
2018-01-27 2018-04-02
2019-10-14 2019-10-03 2017-09-22 2017-01-16 2018-09-04 2018-09-27
2019-10-28 2018-05-05 2019-08-17
2019-12-10
2019-10-04 2018-12-04 2019-10-23 2018-12-26 2016-04-18 2019-08-12 2019-11-07
2019-05-21 2016-03-11 2019-12-27 2018-12-08 2018-02-18 2019-09-05

Exhibit B, Page 123

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 124 of 352 Pageid#: 1027

voter_id

lname

309002071 H

917741383 H

804017092 H

408022297 H

74879525 H

604005725 H

918127342 H

469024245 H

420115603 H

918526183 H

704017515 H

919991708 H

107022999 H

307032075 H

403009203 H

206026215 H

917751860 H

125488681 H

108010245 H

121019790 H

918723536 H

28019711 H

703017184 H

805001261 H

701013780 H

918228947 H

920176394 H

803003064 H

919027096 H

305024249 H

918696133 H

919025951 H

605016057 H

fname SARAH TODD ROBERT DORIS WILLIAM FRANCES WILHELMINA DONALD GERALDINE MARK NEIL DAPHINE EDGAR ARNOLD ROBERT CHARLES JOAN ALTENIA ROBERT MARY AMY RAYMOND GENE PATRICIA ROGER ANNA MARIA GAYLE CURLEY MARY ANN ELIZABETHE GEORGE HOWARD BEVERIDGE

dob 1948 1946 1926 1920 1961 1945 1951 1931 1942 1954 1939 1953 1920 1946 1940 1939 1960 1945 1934 1932 1958 1941 1934 1966 1949 1936 1942 1949 1936 1930 1948 1931 1936

date_registered 1992-09-19 1996-10-07 1976-03-25 1960-07-25 2008-09-11 1983-10-04 1997-10-06 2016-10-14 2012-10-15 1999-06-17 2004-03-11 2004-10-01 1957-06-25 2000-03-30 1987-04-28 1967-01-25 1998-05-13 2016-04-08 1963-11-08 1985-12-09 2000-03-16 1994-11-09 1964-09-28 1986-04-03 1974-09-28 2007-03-12 2005-09-28 2006-01-09 2001-01-19 1975-10-04 2004-01-12 2001-01-23 1987-09-19

ssdi_dod
2019-11-27
2019-02-16 2015-12-17 2019-08-22 2020-01-13 2019-12-02 2019-01-04
2019-01-28 2018-12-12 2019-12-24 2019-10-17 2019-11-04 2019-09-25 2019-02-14
2019-08-06 2019-12-31 2019-12-12 2019-08-26 2019-02-16 2017-08-25
2019-12-12
2020-01-10 2019-12-26 2019-12-19 2019-12-18 2019-11-25

obit_dod 2018-12-20 2019-11-27 2019-05-23 2019-08-24
2019-08-22
2019-12-02
2019-08-25 2019-01-28 2018-12-12
2019-10-17 2019-11-04 2019-09-25 2019-02-14 2019-01-29 2019-08-06
2019-12-12 2019-08-26 2019-02-16
2018-12-10
2018-10-11
2019-11-25

Exhibit B, Page 124

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 125 of 352 Pageid#: 1028

voter_id

lname

504029210 H

911013003 H

30003967 H

407025125 H

398034068 H

920415188 H

919581519 H

918084228 H

208004940 H

705009073 H

917348005 H

507008388 H

601025932 H

772943581 H

403971832 H

505000313 H

918709314 H

702013496 H

996815471 H

501022090 H

917491569 H

14991756 H

804011309 H

108006198 H

204012394 H

709003575 H

412011444 H

301002241 H

297060778 H

408029279 H

919941652 H

918582949 H

703014801 H

fname HOMER GLENN MARGARET JAMES NELSON LARRY LYNN LOU STELLA FRANCIS ROY GENEVA CLARA BRENDA ALEXANDER RICHARD ROY DAVID CLEMENT CHARLIE GWENDOLYN VERNON MELINDA JOHN CARLEASE BETTY HOBERT MABEL DOROTHY SAMUEL CYNTHIA EVELYN JIMMIE

dob 1931 1948 1946 1932 1945 1945 1950 1940 1924 1930 1949 1919 1940 1944 1937 1932 1943 1956 1932 1928 1964 1925 1950 1930 1923 1930 1947 1921 1931 1942 1948 1936 1935

date_registered 1961-10-02 2003-08-20 1967-03-22 1968-02-07 2008-10-06 2006-12-13 2003-08-28 1997-09-08 1984-09-29 1951-11-07 1995-09-30 2002-11-19 1987-09-25 2007-12-20 2016-09-27 1967-10-03 2000-03-07 1974-08-27 2007-08-15 1967-06-01 2005-01-31 2016-08-26 1987-04-20 1964-09-03 1976-09-30 1993-07-30 1997-03-14 1975-04-10 2010-03-06 2000-01-14 2004-09-30 1999-09-14 1984-09-25

ssdi_dod 2019-11-20 2019-11-17 2019-11-11 2019-10-31 2019-09-29 2019-09-28 2019-08-25 2019-01-09 2018-12-31 2018-12-18 2018-12-17 2018-12-10 2018-11-28 2018-11-11 2018-09-29 2018-08-17 2018-04-16 2018-03-25 2018-03-08 2017-12-23 2017-12-22 2017-06-24 2017-02-19 2016-07-06 2014-12-17 2014-10-02

obit_dod 2019-11-20 2019-11-17
2019-10-31
2019-09-28 2019-08-25 2019-01-09 2018-12-31 2018-12-18 2018-12-17 2018-12-10 2018-11-28 2018-11-11
2018-08-17 2018-04-16
2017-06-24 2017-02-19 2016-07-06
2019-10-17 2019-10-16 2019-09-30 2019-09-29 2019-05-05 2019-03-14 2018-06-01

Exhibit B, Page 125

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 126 of 352 Pageid#: 1029

voter_id

lname

506010474 H

361609214 H

919370766 H

742695180 H

706004256 H

917719182 H

305034475 H

701021134 H

306030456 H

917164737 H

934723966 H

9618454 H

920160193 H

919185015 H

918664917 H

803006032 H

912020068 H

208009973 H

313150967 H

917439670 H

705015601 H

919154151 H

267465284 H

917374868 H

69177827 H

801000460 H

321151199 H

107022361 H

403029576 H

918623590 H

133009391 H

202009976 H

702013793 H

fname VIRGINIA MARGIE BARBARA PAULETTE LAWRENCE PATRICIA LETICIA DOUGLAS HELEN SENAN HELEN DAVID ROSE CLARA DAVID JANE NANCY NANCY QUINTON QUINTON RITA ELIZABETH CHARLES JOEL TRACI THELMA AGNES JAMES JAMES OTTO RUTH NANCY LOUETTA JOHN

dob 1944 1946 1922 1952 1937 1942 1931 1940 1928 1944 1932 1982 1940 1956 1959 1930 1946 1941 1945 1945 1945 1941 1949 1965 1969 1921 1943 1934 1916 1924 1935 1928 1945

date_registered 1998-03-06 2009-01-30 2002-08-06 2008-11-12 2002-11-25 2005-11-09 1984-10-06 1995-01-17 1953-10-01 1994-09-19 2016-08-09 2012-08-06 2005-09-06 2001-09-17 2002-07-22 1954-05-04 1978-10-07 1971-10-02 2019-05-10 1996-03-18 1967-08-19 2001-07-30 2012-07-11 1995-10-10 2015-01-28 1964-02-28 2008-04-07 2000-10-04 1999-12-09 1999-11-03 1997-12-01 1985-04-03 1985-11-22

ssdi_dod
2018-12-30
2019-10-20
2019-10-01 2018-08-12
2019-01-01 2018-01-15
2018-02-19 2018-12-06 2019-08-20
2019-11-07 2019-11-07 2019-11-07 2019-10-22 2019-09-04 2019-06-12 2018-12-22 2018-04-11 2014-10-11 2014-04-02
2019-10-25 2020-01-03 2019-12-06 2019-11-29

obit_dod 2018-03-19 2017-12-29 2017-01-30 2018-12-30 2019-05-27 2019-10-20 2019-10-21
2018-08-12 2019-09-07 2019-01-01
2019-08-04
2018-12-06 2019-08-20 2018-12-08 2019-11-07 2019-11-07 2019-11-07
2019-09-04
2018-04-11 2014-10-11 2014-04-02 2019-08-12 2019-08-01

Exhibit B, Page 126

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 127 of 352 Pageid#: 1030

voter_id

lname

124007054 H

408025440 H

707013791 H

918196291 H

812007710 H

917347502 H

498299820 H

102464151 H

913011394 H

401016810 H

901016858 H

521278841 H

124000300 H

34584589 H

42778253 H

706004518 H

310017574 H

917338164 H

97897099 H

36053463 H

202021368 H

121017015 H

919936541 H

917239479 H

221848701 H

208014872 H

506024577 H

307016319 H

908005009 H

642170788 H

917885854 H

231021290 H

403013933 H

fname EDGAR OLIVE CHRISTOPHER ROBERT TIMOTHY EDITH ROSEMARIE DOUGLAS VALTON KENNETH WILLIAM KERMIT PEGGY NORMAN LEE NELLIE THELMA JOHN RANDY FRANCES OLYN EUSTACE ELLEN JOSEPH ELSA MARY PATRICIA MABEL KAY TERRY DENNIS CLIFFORD IRENE

dob 1942 1923 1958 1951 1971 1946 1937 1946 1957 1925 1935 1936 1933 1924 1937 1939 1939 1946 1960 1930 1947 1927 1949 1977 1950 1949 1942 1914 1937 1947 1942 1924 1929

date_registered 1993-09-18 1997-02-27 1977-10-03 1998-02-17 1994-10-11 1995-09-30 2019-03-15 2016-10-21 1976-04-03 1957-08-12 1986-10-04 2017-06-15 1972-09-30 2016-08-04 2012-06-13 1971-07-01 2005-07-26 1995-09-23 2016-09-27 2013-10-15 1989-08-17 1979-11-07 2004-10-01 2004-10-04 2015-07-30 2000-03-07 1964-06-30 1964-10-01 1977-03-22 2012-02-10 1997-02-04 1988-10-08 1966-06-11

ssdi_dod 2019-04-19 2019-03-24 2018-07-26 2018-06-24 2016-11-24
2019-08-05 2020-01-18 2019-10-21 2019-08-12 2019-12-15 2018-09-25 2018-05-11
2020-01-14 2019-10-18 2018-12-28 2015-11-29 2002-01-08 2018-10-06 2019-02-06 2018-12-29 2018-06-17
2019-09-12 2019-09-13 2019-11-21
2020-01-18

obit_dod 2019-04-19
2016-11-24 2017-07-28 2019-08-05
2019-10-21 2019-08-12
2018-09-25
2019-10-20 2017-02-18 2016-01-11 2016-11-25
2019-10-18
2015-11-29
2019-02-06 2018-12-29
2019-10-04 2017-04-13 2019-09-12 2019-09-13 2019-11-21 2019-08-22

Exhibit B, Page 127

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 128 of 352 Pageid#: 1031

voter_id

lname

403014217 H

902007987 H

608001025 H

904017922 H

605016063 H

919379533 H

175583599 H

918913380 H

918869248 H

822368791 H

513030011 H

305039132 H

918583900 H

306025664 H

918499587 H

298505422 H

901022539 H

504010291 H

910011695 H

804013216 H

26010309 H

306031786 H

919752312 H

918973699 H

919480512 H

904022398 H

903022398 H

601000816 H

917747046 H

402658677 H

605004897 H

919901600 H

412016145 H

fname KATHLEEN GEORGE JANE MARY LUCILLE CHRISTINE JOAN JOSEPH RAYMOND JUDY RALPH DANNY LINDA CARNADA DAVID BENJAMIN ROBERT MILDRED JUANITA CHARLES THERESA BESSIE ELIZABETH MAURION GEORGE WAYNE MARSHA CARLTON HERMAN EDNA RANDALL DENNIS RALPH ROBIN

dob 1942 1965 1945 1922 1931 1937 1933 1930 1940 1956 1946 1939 1960 1943 1939 1925 1928 1930 1923 1928 1925 1925 1986 1953 1943 1954 1951 1947 1919 1955 1943 1920 1962

date_registered 1994-04-02 1998-09-09 1967-06-09 1951-06-29 1964-04-21 2002-08-21 2015-12-30 2000-10-02 2000-09-01 2016-12-13 1992-09-29 1984-09-22 2000-03-16 1976-04-22 1999-05-10 2016-11-15 1996-09-03 1979-09-04 2000-07-13 1977-11-09 1956-02-24 1993-11-03 2004-05-05 2000-10-10 2003-03-06 1992-10-03 1990-02-21 1972-07-17 1996-10-07 2016-10-17 1998-09-23 2004-09-21 1997-04-28

ssdi_dod 2019-12-23 2019-09-24
2019-10-07 2017-12-25 2019-12-18
2019-12-12 2018-08-16 2019-06-16 2018-10-14 2018-04-04
2019-11-04 2019-08-26
2016-04-28
2019-09-23 2017-06-24
2018-12-14 2018-09-28 2019-12-23 2019-11-02 2019-10-22 2018-12-17 2017-04-26 2019-08-29 2019-08-16 2019-06-25 2018-12-10

obit_dod 2019-09-24 2018-12-12 2016-03-15
2017-12-25
2018-02-10 2019-12-12 2018-08-16 2019-06-16
2019-02-07
2019-10-16 2016-04-28 2019-07-07 2019-09-23
2018-02-02 2018-12-14 2018-09-28
2018-12-17 2017-04-26
2018-12-10

Exhibit B, Page 128

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 129 of 352 Pageid#: 1032

voter_id

lname

221006681 H

918287102 H

918400598 H

910001328 H

269640074 H

904021070 H

919736767 H

201006807 H

918603815 H

706012301 H

507027577 H

401012677 H

901007696 H

703006427 H

802987424 H

126002492 H

26016454 H

403028072 H

5694906 H

501002387 H

906022802 H

905023566 H

131712636 H

3002934 H

833920099 H

122005895 H

31475488 H

918533327 H

917386025 H

95877776 H

917458742 H

605035128 H

803004036 H

fname CHARLES ELLEN ROGER JONNIE ODELL IRMA NANCY WILLIAM MARY PHYLLIS MARY OMER THELMA JOE JULIAN HENRY RONALD BENJAMIN DEALROY DELANO WILLIAM MOODY KEITH DAVID JOE ZOE LILLIE GEORGE LESLIE JOHN OLIVE JOSEPH AL

dob 1941 1948 1941 1949 1949 1932 1937 1949 1959 1939 1927 1933 1938 1959 1942 1931 1959 1928 1956 1935 1933 1943 1966 1951 1950 1925 1926 1933 1966 1924 1926 1934 1934

date_registered 1972-02-03 1998-06-09 2003-12-11 1981-09-09 2016-07-15 1980-09-25 2004-04-05 1976-10-01 1999-10-02 1983-02-17 1976-09-29 1967-09-02 1993-06-01 1977-10-06 2007-04-25 1970-05-08 2003-11-13 1976-07-14 2009-09-08 1968-08-02 1999-09-20 1968-07-11 2016-09-02 1992-09-30 2007-07-16 2006-08-09 2011-10-13 1999-07-01 1998-04-06 2018-09-05 1996-04-03 1997-07-29 2006-09-22

ssdi_dod 2018-04-20
2020-01-20 2019-11-24 2019-11-12 2019-10-22 2019-11-20 2020-01-06 2019-10-14 2018-06-27 2019-10-15
2020-01-30 2019-11-22 2018-04-12
2019-11-21 2019-11-07 2019-09-17 2019-08-05
2020-01-25 2019-09-27 2019-09-12 2019-01-06 2018-12-19 2018-08-30 2018-08-01 2018-01-27
2020-01-21 2019-09-25 2020-01-20

obit_dod 2018-04-20 2019-09-24
2019-11-24 2019-11-12 2019-10-22
2019-10-14 2018-06-27
2019-09-18
2019-11-22 2018-04-12 2019-06-08 2019-11-21
2019-09-17 2019-08-05 2019-09-17
2019-09-27 2019-09-12 2019-01-06 2018-12-19 2018-08-30 2018-08-01 2018-01-27 2019-07-26
2019-09-25

Exhibit B, Page 129

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 130 of 352 Pageid#: 1033

voter_id

lname

122010429 H

224003993 H

508007889 H

918058648 H

224007275 H

917532848 H

801011716 H

918432580 H

221008771 H

504001959 H

505011820 H

917146516 H

126013121 H

808006037 H

228003707 H

26000108 H

918581604 H

21673588 H

905019628 H

309022277 H

401023411 H

409033990 H

907015849 H

503023361 H

406015609 H

917456247 H

919330540 H

255448529 H

3424220 H

608003431 H

502004007 H

918280576 H

917089630 H

fname MARY JOHN ADALIA RONALD VERONICA OLIVIA FRANCES CEASAR FRANK SHIRLEY EVELYN HAROLD CALVIN THERESA HENRY VICKI LAWRENCE LAWRENCE ANNIE CURLIE FLORINE JERRY JEAN HELEN PATRICIA CARLTON SANDRA DIAGO KENNETH BARBARA OLLIE VIRGIL KEISHA

dob 1929 1938 1924 1951 1953 1963 1924 1937 1942 1949 1932 1940 1925 1941 1950 1956 1947 1929 1927 1927 1940 1945 1929 1936 1947 1953 1952 1959 1947 1933 1932 1958 1976

date_registered 1985-06-25 1966-09-25 1964-04-08 1997-08-01 1989-09-16 2004-02-12 1976-03-22 1999-02-12 1966-04-27 1976-09-29 2001-05-14 2012-10-15 1952-05-05 1984-01-26 1976-01-14 1975-05-15 1999-09-13 2012-06-26 2003-09-16 2003-05-22 1984-10-02 1992-10-02 1962-04-04 1992-08-28 1996-09-04 1998-01-28 2002-05-23 2012-01-18 2014-09-17 1997-04-28 1997-06-24 2008-03-04 1998-04-01

ssdi_dod 2019-12-19 2019-11-26 2019-10-19 2019-02-06 2018-05-31 2017-12-06 2015-03-31 2019-06-01
2020-01-30 2020-01-18 2020-01-02 2019-12-04 2019-11-23 2019-11-17 2019-11-14 2019-11-10 2019-11-04 2019-10-18 2019-10-12 2019-09-28 2019-08-08 2019-08-08 2019-08-05 2019-08-03 2019-08-01 2019-07-14 2019-06-30 2019-06-07 2018-12-20 2018-12-20 2018-12-09 2018-12-09

obit_dod 2019-12-19 2019-11-26 2019-10-19 2019-02-05 2018-05-31 2017-12-06 2015-03-31 2019-06-01 2019-09-11
2019-11-23
2019-11-14 2019-11-10 2019-11-04 2019-10-01 2019-10-12 2019-09-28 2019-08-08
2019-08-05 2019-08-03 2019-08-01
2019-06-30
2018-12-20
2018-12-09 2018-12-09

Exhibit B, Page 130

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 131 of 352 Pageid#: 1034

voter_id

lname

702012068 H

901006235 H

917876292 H

662856341 H

22914623 H

358807781 H

124007473 H

918625316 H

807016339 H

768120193 H

24400193 H

917260041 H

306013582 H

610473469 H

205012759 H

917224196 H

917444247 H

507024203 H

606019396 H

706012406 H

227005388 H

211153279 H

224008467 H

701005279 H

205026465 H

919974747 H

701012303 H

306017187 H

917431994 H

244085791 H

403025646 H

305047069 H

23005965 H

fname HENRY LILLIAN JAMES JOSEPH WILLIAM SUSIE NATHANIEL CARL AMELIA ROSE CARMEN PAUL JULIA TONY DOROTHY DAVID DONALD JAMES DAVID LINDA MELANIE HELEN CASSANDRA VICTORIA SHIRLEY JAMES OPAL NATALIE ELSIE MARIA HELEN CHARLES CLYDE

dob 1928 1926 1961 1943 1947 1918 1936 1949 1937 1919 1933 1930 1932 1931 1924 1944 1941 1931 1932 1946 1947 1927 1942 1928 1935 1932 1928 1926 1929 1931 1927 1940 1928

date_registered 1972-08-10 1968-05-27 1997-01-23 2013-10-11 2012-09-19 2016-10-16 1987-10-01 1999-11-10 1963-06-01 2008-06-16 2016-10-21 1995-03-30 1960-03-26 2008-10-06 1964-09-23 1994-10-28 1996-04-04 1960-01-17 2005-07-29 1967-03-16 1978-10-07 2011-05-27 1976-08-26 1964-01-04 1960-04-26 2004-10-02 1966-09-19 1983-09-02 1996-03-19 2016-08-04 1968-10-02 1976-08-25 1992-09-02

ssdi_dod 2018-12-04 2018-12-01 2018-11-02 2018-10-24 2018-10-10 2018-05-30 2018-03-31 2018-03-31 2018-03-30 2017-12-15 2017-06-06 2017-01-21 2016-03-01 2016-02-23 2015-11-29 2012-03-01 1999-11-07
2020-01-25 2019-12-01 2019-11-28 2019-11-10 2019-10-10 2019-10-09 2019-10-01 2019-08-27 2019-08-09 2019-04-23 2018-12-03

obit_dod 2018-12-04 2018-12-01 2018-11-02 2018-10-24
2018-05-30
2018-03-30
2017-01-21
2016-02-23
2012-03-01
2019-10-18 2019-09-06 2019-07-29 2018-12-19 2015-01-09
2019-11-10
2019-10-09 2019-10-01 2019-08-27 2019-08-09 2019-04-23 2018-12-03

Exhibit B, Page 131

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 132 of 352 Pageid#: 1035

voter_id

lname

22017652 H

214001433 H

221010566 H

23005049 H

508020360 H

307010858 H

403007744 H

204029416 H

285091837 H

603024363 H

401012513 H

917000260 H

919253981 H

612017606 H

508000321 H

673948076 H

108021087 H

918296419 H

502015333 H

105021087 H

705019071 H

72011560 H

517010539 H

601028205 H

805011458 H

803007964 H

919013268 H

919644759 H

917533963 H

13585001 H

404022847 H

105020460 H

918398230 H

fname ETHEL MICHAEL DENNIS JOAN NELL KINGSLEY BILLY RAYMOND ELLEN PHILIP HELEN DEBORAH CLAIR BEULAH REBECCA JACK LOUISE SHIRLEY WILLINA JESSE MARY ALICE MICHAEL PEARL MASIL EDWIN ROBERT KENNETH JOHNNIE WILLIAM JEAN GERRY KHWAJA

dob 1926 1955 1942 1925 1932 1947 1931 1943 1922 1927 1924 1952 1931 1925 1949 1943 1931 1933 1947 1928 1926 1934 1959 1943 1926 1934 1979 1951 1938 1972 1947 1937 1934

date_registered 1963-12-05 1991-08-27 1980-03-21 1995-09-15 1960-08-16 2000-10-05 1985-09-25 2005-10-29 2014-04-11 1980-10-02 1995-10-04 1996-10-04 2002-01-07 1991-05-14 1971-09-20 2008-07-25 1992-10-01 1998-07-13 1987-10-03 1954-06-12 1950-06-26 2014-08-07 1991-10-03 1998-04-23 1958-05-06 1972-01-17 2018-01-31 2003-12-01 1996-06-26 2016-04-13 2000-04-06 2004-10-04 1998-12-03

ssdi_dod 2018-10-30 2017-09-21 2015-03-29
2019-09-22 2019-12-04 2019-12-27 2019-09-23 2020-01-20 2019-09-25 2018-12-28 2018-12-22 2019-09-27 2019-10-09 2019-12-04 2019-10-19 2019-08-18 2018-02-24 2019-12-23 2019-10-07 2019-12-27 2019-10-20 2018-08-18 2016-06-28 2020-01-04 2019-07-01 2019-04-04 2019-12-04 2019-09-05
2017-07-23

obit_dod 2018-10-30 2017-09-21
2018-12-05 2015-01-26 2019-09-22 2019-12-05
2019-09-01
2019-09-25 2018-12-28 2018-12-22
2019-10-09
2019-12-23 2019-10-07
2019-10-20 2018-08-18 2016-06-28
2019-04-04
2019-09-05 2019-09-24 2017-12-29

Exhibit B, Page 132

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 133 of 352 Pageid#: 1036

voter_id

lname

133196517 H

604019621 H

804020329 H

101915163 H

919393762 H

904015851 H

554986113 H

919180037 H

114796184 H

920125810 H

778514799 H

918797762 H

912011870 H

578933645 H

503002975 H

504005953 H

126012613 H

912001332 H

918209464 H

82653414 H

705004520 H

702004264 H

214006810 H

702016420 H

127000523 H

224009630 H

305015211 H

205003491 H

27001642 H

24013879 H

703015606 H

122018417 H

918863493 H

fname LUELLA DAVID KELLY SAJIDA LAURA WILLIAM LEE MAXWELL SUE SHARON PAUL PARKER LENFORD ROBERT ROSA PHIL HERBERT MARGARET MELVIN RONALD PHILLIP ROBERT FRANCES PAMELA DARLENE ESTHER MARGARET MARREL JEANETTE CYRIL CHARLES KENNETH CALVIN

dob 1932 1943 1920 1920 1935 1932 1938 1921 1958 1948 1941 1947 1951 1977 1943 1941 1939 1920 1958 1937 1940 1936 1930 1948 1943 1934 1935 1927 1931 1938 1937 1959 1960

date_registered 2016-10-10 2004-09-23 1976-03-30 2008-06-16 2002-09-13 1953-08-14 2008-10-06 2001-08-23 2014-07-16 2006-02-10 2017-03-07 2000-06-08 1992-05-26 2012-10-10 1998-11-23 1984-10-05 1999-11-03 1999-05-25 1998-03-02 2008-12-29 1981-09-03 1979-10-06 1992-03-04 1969-10-04 1966-05-09 1980-10-04 1983-10-05 1979-05-10 1981-08-06 1978-10-07 1999-02-01 1998-07-30 2000-08-23

ssdi_dod
2019-08-14 2020-01-12 2019-11-17 2019-08-12 2019-08-01 2015-03-24 2019-11-23 2019-04-30 2019-12-25 2019-09-27 2019-04-21 2018-09-24 2018-02-04
2019-11-24 2019-08-06 2018-05-30 2019-11-16 2019-10-19
2019-08-14 2018-11-16
2018-06-24
2018-12-27 2020-01-13 2019-12-18 2019-11-04 2019-10-07 2018-12-22

obit_dod 2019-09-19 2019-08-08 2019-08-14
2019-11-17
2019-08-01 2015-03-24
2019-04-30
2019-09-27 2019-04-21
2018-02-04 2019-09-29 2019-11-24 2019-08-06 2018-05-30 2019-11-16 2019-10-19 2018-12-02 2019-08-14 2018-11-16 2018-12-16 2018-06-24 2017-10-11
2019-12-18 2019-11-04 2019-10-07

Exhibit B, Page 133

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 134 of 352 Pageid#: 1037

voter_id

lname

208013812 H

403034100 H

498476312 H

714013799 H

105002817 H

917722992 H

202026930 H

920067511 H

918372166 H

906008178 H

306025875 H

901005290 H

917083191 H

919884241 H

917895858 H

706011734 H

807010902 H

907019897 H

604001124 H

616000076 H

408008687 H

502000153 H

309022641 H

231018692 H

20433871 H

103012316 H

607022543 H

403025648 H

918187266 H

801015118 H

438699983 H

228009989 H

126010582 H

fname MARIE ROGER RAYMOND LINDA BARBARA LOIS LINDA WILLARD PRISCILLA BRENDA ROSAMOND ALICE MARY FREDERICK PRESTON GENE WARNER ETHEL CHARLES EMORY LORAY THOMAS ANDREA BETTE JOAN SHIRLEY ROBERT DOROTHY GEORGE FRANCES CURTIS LILY SHERMAN

dob 1929 1942 1946 1948 1932 1938 1955 1961 1942 1948 1927 1939 1930 1932 1935 1932 1937 1922 1936 1944 1918 1942 1953 1933 1931 1935 1941 1932 1938 1927 1965 1932 1952

date_registered 2003-09-15 2005-07-13 2017-09-08 1975-08-23 1955-10-01 1996-10-04 1973-05-09 2005-03-10 1998-11-06 1970-05-09 1956-09-06 1980-04-11 1994-03-14 2004-09-13 2004-08-18 1974-09-04 1984-10-06 1986-04-04 1967-06-09 1989-12-11 1953-05-27 1963-09-19 1991-09-17 2000-07-19 2011-10-14 1975-04-16 1963-05-09 1960-07-20 1998-01-29 1981-07-24 2019-02-05 1992-09-17 1992-09-21

ssdi_dod 2018-12-10 2018-08-05 2018-07-11 2016-12-21 2019-12-13 2019-09-08 2019-08-04 2019-10-23 2019-11-07 2019-11-07 2019-11-01 2019-10-19 2019-10-02 2019-09-17 2018-12-05 2018-10-15
2018-11-06 2018-01-24 2018-09-27 2019-11-19 2019-11-19 2019-08-18 2018-12-18 2018-01-24 2017-01-24 2019-12-24 2019-08-06 2018-01-19 2018-12-28 2019-11-04 2018-10-19 2018-02-03

obit_dod 2018-12-10
2018-07-18
2019-12-13 2019-09-08 2019-08-04 2019-10-23 2019-11-07 2019-11-07 2019-11-01 2019-10-19 2019-10-02
2018-10-15 2019-09-14
2018-01-24 2018-09-27 2019-11-19 2019-11-19
2018-12-18
2019-12-24
2018-12-28 2019-11-04 2018-10-19

Exhibit B, Page 134

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 135 of 352 Pageid#: 1038

voter_id

lname

13284680 H

27019723 H

919787964 H

503024581 H

403988189 H

503025154 H

209003187 H

105312272 H

712016254 H

903020073 H

525816823 H

225015988 H

705023948 H

917133078 H

210022633 H

901022555 H

517218106 H

406029588 H

801003455 H

908012031 H

407013193 H

246275527 H

112025351 H

919952463 H

648463430 H

134576883 H

918823322 H

306018864 H

917791048 H

124002734 H

919943393 H

918131627 H

705006364 H

fname CHARLOTTE THOMAS DOROTHY FRED JUANITA ROBERT MARY JAMES LEWIS DANIEL MELBA VAUGHN DORIS JUNE PHILIP JUNIOR ROBERT WILLIAM MARY M ELIZABETH DAVID JOAN DAVID JOHN GREGORY JEFFERY GARY LYNN ELINOR WILLIAM LUCY ROBERT JO STARLET

dob 1937 1939 1929 1923 1956 1929 1941 1961 1928 1965 1934 1928 1930 1949 1941 1932 1953 1934 1922 1942 1934 1940 1931 1951 1968 1936 1934 1936 1933 1920 1947 1927 1949

date_registered 2016-12-13 1966-04-21 2004-06-18 1947-11-11 2018-10-05 1973-10-06 1964-09-28 2016-10-14 1992-05-12 1997-09-03 2012-08-31 1987-09-30 1976-10-02 1994-07-13 1991-02-07 1973-09-19 2012-10-15 1980-09-06 1999-11-03 2005-04-14 2012-09-26 2012-02-10 1993-01-08 2004-10-04 2007-09-27 2007-11-27 2000-07-10 1988-10-08 1996-10-07 1976-10-01 2004-10-04 1997-11-06 1975-09-27

ssdi_dod 2018-12-21 2019-11-23 2018-06-04 2019-08-16 2018-12-25 2019-10-21 2019-10-02 2019-09-13 2015-10-24 2016-12-17 2019-09-05 2019-10-09 2014-05-19 2019-11-23 2019-12-14 2020-01-08 2019-08-06
2019-09-14 2019-11-12 2018-06-29
2019-09-03 2019-09-22 2016-12-24 2019-10-31
2019-12-04 2018-05-26 2019-12-21 2015-12-12 2018-11-29

obit_dod 2018-12-21 2019-11-23
2019-08-16 2018-12-25 2019-10-21 2019-10-02
2019-09-05 2019-10-09 2014-05-19 2019-11-23
2019-08-06 2018-07-17 2019-09-14 2019-11-13 2018-06-29 2017-03-10 2019-09-03 2019-09-22 2016-12-24 2019-10-31 2019-11-16 2019-09-07 2019-12-04 2018-05-26
2015-12-12

Exhibit B, Page 135

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 136 of 352 Pageid#: 1039

voter_id

lname

106029385 H

215731941 H

224011636 H

406026360 H

920042553 H

709012070 H

305018302 H

803015360 H

210013816 H

918603555 H

505020364 H

121007479 H

919797497 H

235885625 H

303039638 H

809001021 H

403004358 H

127016866 H

917564152 H

406011256 H

302020512 H

3004577 H

909019066 H

805010198 H

305032312 H

25037621 H

918946241 H

919966966 H

118789987 H

703009978 H

918928522 H

401025445 H

213020787 H

fname DOLORES BEVERLY LILLIAN EVELYN ELVA-LYNNE KENNETH MARY DORIS ANNIE MAUDE CLAUDINE ROBERT KEITH WILLIAM BONITA LORAINE JUSTINE MARY LOU WILBUR LAWRENCE ALLIERSON JOSEPH GRACE MARY BARBARA BEVERLY LESTER MARGARET MARY KERRY MARY JOSEPHINE RICHARD

dob 1931 1946 1921 1926 1954 1947 1937 1933 1923 1945 1930 1955 1959 1932 1957 1919 1934 1933 1936 1928 1937 1955 1933 1924 1928 1948 1937 1942 1925 1923 1927 1943 1928

date_registered 1991-10-01 2012-10-10 1982-09-28 1996-11-12 2005-01-10 1988-10-06 1976-05-05 1963-10-01 1992-09-29 1999-10-01 1991-08-16 1997-08-19 2004-06-22 2008-04-23 1990-03-22 1951-11-14 1985-11-06 1959-11-25 2000-03-07 1986-09-08 2000-12-18 1988-04-14 1992-08-26 1996-12-05 1984-03-21 2018-03-29 2000-09-21 2004-10-04 2009-08-06 1966-10-07 2000-10-06 2004-10-04 1992-10-02

ssdi_dod 2019-08-23 2019-12-18
2019-10-02 2019-10-31 2020-01-09 2019-11-10 2019-11-06 2019-11-04 2019-10-12 2019-09-25 2019-07-02 2019-01-31 2018-12-10 2018-01-27 2017-09-19 2014-05-22
2019-09-03 2017-01-26 2019-08-18
2018-12-21 2020-01-14 2019-11-20 2015-08-10 2009-01-04 2001-03-24
2019-09-08

obit_dod 2019-08-23
2018-12-31 2019-10-02 2019-10-31
2019-11-06 2019-11-04 2019-10-12 2019-09-25 2019-07-02
2017-09-19
2019-08-30 2019-02-20 2018-12-05 2018-01-05 2019-09-03
2019-08-18 2018-12-25
2015-08-10
2019-08-15 2019-09-08

Exhibit B, Page 136

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 137 of 352 Pageid#: 1040

voter_id

lname

125018203 H

102024845 H

917290377 H

919502300 H

919679973 H

919105261 H

917181062 H

918645602 H

528061027 H

918652991 H

603012097 H

129000310 H

516029275 H

10006724 H

701011904 H

403011353 H

303029930 H

806001578 H

860662713 H

607022418 H

301020867 H

305041285 H

77690000 H

225019770 H

144991777 H

306023298 H

607029453 H

412024507 H

707012774 H

203004952 H

574596605 H

103012982 H

229009322 H

fname GERALD JUDITH FANNIE ARNETHA WILLIAM ANTHONY ROBERT RANDY ACE FREDDIE RICHARD DOLPHUS GLENNIS GERALD DOROTHY JOHN GREGORY GEORGIE ARTHUR PATRICIA GWENDOLYN CHARLES JULIAN GEORGE MARILYN LORRAINE BETTY DANIEL BEVERLY MIRIAM SARAH BERNADITA MANUEL

dob 1931 1939 1944 1938 1943 1957 1926 1948 1926 1935 1943 1928 1937 1943 1931 1937 1948 1919 1949 1942 1932 1931 1957 1924 1944 1924 1927 1932 1927 1941 1945 1946 1936

date_registered 1996-08-15 1999-09-23 1995-05-26 2003-04-15 2004-02-13 2015-12-28 1994-09-27 1999-12-09 2007-08-09 2000-03-10 1999-08-27 1949-08-19 1991-08-26 2003-07-17 1957-08-13 1960-10-07 1992-12-21 1949-03-29 2007-10-02 1963-09-18 1964-10-03 1984-09-22 2014-02-20 2003-07-24 2010-10-08 1964-03-24 1975-01-25 1971-08-10 1980-03-21 1980-09-30 2008-10-06 1986-10-04 1972-09-06

ssdi_dod 2019-02-16 2018-03-19 2020-01-07 2019-11-24 2019-10-19 2019-01-08 2018-12-07 2015-10-31 2015-08-20
2019-10-14 2019-01-13 2018-12-26 2017-08-18
2019-12-21 2019-11-01
2018-08-31
2019-10-14 2019-10-26 2018-01-23 2019-12-29 2017-08-23
2019-11-10 2017-10-14 2016-09-09

obit_dod 2019-02-16 2018-03-19
2019-11-24 2019-10-19
2015-10-31 2015-08-20 2019-09-24 2019-09-16 2018-12-19 2019-10-14 2019-01-13 2018-12-26 2017-08-18 2017-12-05
2018-12-06 2019-08-16 2019-10-28
2019-09-28 2019-10-14 2019-10-26 2018-01-23
2019-10-05 2019-11-10
2016-09-09

Exhibit B, Page 137

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 138 of 352 Pageid#: 1041

voter_id

lname

804014868 H

806002218 H

917198123 H

4625448 H

203049329 H

918462864 H

605023209 H

102031055 H

406005707 H

223021670 H

918742536 H

704226723 H

222018795 H

503010541 H

27840190 H

601035039 H

702006826 H

920091016 H

485853158 H

519663353 H

811001281 H

202001436 H

28004245 H

920046789 H

918788940 H

920360010 H

917511663 H

56331531 H

808008714 H

307017958 H

907008440 H

202024502 H

303005728 H

fname CARROLL ROBERTA JANE CHARLES PRISCILLE CAROLINE WILLIAM BARBARA WILLIAM DIANE BETTY KEITH DOLORES PAUL MARIE JAMES LINDA CALVIN JAMES ELIZABETH GARLAND WALTER JOHN BENJAMIN SERENA ZACHARY WANDA CARA PATRICIA VERA BETTY BETTY LEO

dob 1940 1938 1932 1930 1948 1929 1928 1933 1944 1948 1953 1952 1930 1944 1935 1949 1947 1938 1942 1939 1929 1940 1933 1938 1943 1966 1948 1941 1941 1921 1927 1951 1930

date_registered 1999-02-17 2000-11-27 1994-10-04 2008-02-29 2014-01-15 1999-03-25 1969-07-19 1992-05-19 1965-06-12 1992-10-02 2000-04-03 2014-03-06 1988-10-03 1991-10-04 2009-10-13 1999-12-29 1972-10-07 2005-04-25 2009-05-22 2013-12-11 1992-09-10 1963-10-05 1971-08-06 2005-01-21 2000-05-23 2006-08-30 1996-05-20 2008-09-10 1980-09-10 1964-09-16 1967-05-31 1971-08-23 2005-07-14

ssdi_dod 2019-11-23 2019-11-05 2017-07-29
2019-09-30
2018-12-04 2019-11-22 2019-10-16 2019-10-02 2019-08-14
2018-01-27 2018-01-12 2019-11-15 2019-09-29 2019-06-20 2018-07-25 2018-05-03 2017-10-31 2017-05-28
2019-12-31 2018-10-28
2019-07-29 2018-12-29 2016-10-18
2019-10-27

obit_dod 2019-11-23 2019-11-05 2017-07-29 2018-05-30 2019-09-30 2018-04-03 2017-05-01 2018-12-04 2019-11-22 2019-10-16 2019-10-02 2019-08-14 2019-08-04
2018-01-12 2019-11-15 2019-09-29 2019-06-20 2018-07-25 2018-05-03 2017-10-31 2017-05-28 2019-10-29 2014-01-17
2018-10-28 2016-12-03 2019-07-29 2018-12-29
2016-10-06 2019-10-27 2018-01-30

Exhibit B, Page 138

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 139 of 352 Pageid#: 1042

voter_id

lname

343009395 H

709020223 H

682782209 H

808008524 H

805000086 H

918293846 H

903023822 H

221011638 H

294580402 H

917614081 H

394478452 H

411017383 H

21619638 H

903026700 H

805000470 H

128841526 H

203026347 H

103019745 H

604012326 H

919335856 H

309040292 H

508019112 H

606022638 H

601027554 H

303030464 H

499691895 H

21005970 H

614097493 H

226020166 H

409021376 H

919628732 H

4775218 H

401018812 H

fname CONSTANCE JOHN VERONICA ROBERT MARY MORRIS CARL DOLORES DOROTHY BETTY WILLIAM CECIL BILLY JOAN JAMES WILLIE VICTOR RONALD PATRICIA ALBERTO CYNTHIA ELBERT CLARA NINA MARGARET JAMES ALTHEA GEORGE RAYMOND EUGENE HARRY EVELYN JOHN

dob 1942 1945 1956 1938 1940 1948 1940 1928 1930 1935 1929 1937 1936 1945 1951 1932 1934 1938 1947 1943 1938 1946 1941 1941 1927 1955 1937 1952 1926 1937 1939 1939 1945

date_registered 2007-07-24 2004-09-13 2008-09-03 1976-04-03 2002-01-23 1998-06-29 1976-03-29 1964-10-03 2010-05-13 1996-08-26 2012-09-22 1991-09-28 2018-01-29 1992-10-03 1992-09-29 2007-03-27 1967-04-10 1991-10-05 1972-10-03 2006-11-27 1972-09-15 1971-03-30 2003-10-05 1996-10-05 1984-10-06 2016-11-15 1992-09-30 2012-02-10 1953-05-01 2006-11-20 2003-11-05 2015-11-13 2000-03-01

ssdi_dod 2018-12-06 2018-03-18 2018-02-09
2020-01-22 2019-11-06 2019-11-04 2019-10-14 2019-10-09 2019-10-06 2019-08-13 2019-04-14 2019-03-12 2019-02-06 2018-02-20
2019-12-09 2019-08-26
2019-11-19 2019-10-15 2017-01-02
2019-06-16 2019-09-22 2018-12-20

obit_dod
2019-09-17 2018-12-01
2019-11-06 2019-11-04 2019-10-14
2019-10-06
2019-04-14
2018-02-01 2019-10-14 2019-09-22 2019-08-02 2018-01-06 2019-09-10 2019-12-09 2019-08-26 2019-02-19 2015-10-31
2019-10-15
2019-12-15 2019-03-06 2019-06-16 2019-09-22 2018-12-20

Exhibit B, Page 139

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 140 of 352 Pageid#: 1043

voter_id

lname

919042335 H

602012868 H

325500390 H

575636475 H

301040293 H

602013859 H

918790594 H

711014809 H

72542393 H

919173922 H

908002599 H

324048500 H

323506952 H

919141505 H

305019013 H

904002872 H

919978424 H

713006828 H

231005397 H

291836520 H

484134228 H

21836763 H

604028551 H

919764323 H

225009325 H

917441816 H

975763984 H

920404818 H

917686222 H

201003401 H

918942379 H

903016490 H

917366823 H

fname PRISCILLA BARBARETTE STEVEN REBA CHARLES RITA GERALDINE DIXIE RONNIE DORA ELINOR JOHN LINDA CARL WALTER MARY ELIZABETH JUNIOR PAUL DOROTHY HARRY KENNETH ALMER BARBARA JO VIRGINIA ROGER GOLDA PHYLLIS BATOOL DAYTON ANNETTE DORIS NEVA

dob 1949 1940 1952 1919 1938 1929 1943 1939 1954 1928 1933 1966 1949 1962 1956 1926 1944 1941 1947 1929 1936 1944 1955 1940 1927 1947 1926 1942 1928 1927 1950 1922 1921

date_registered 2001-02-16 1980-12-29 2009-07-14 2011-07-29 1988-09-19 1964-05-02 2000-05-25 1972-10-07 2018-07-02 2001-08-31 1961-12-01 2013-06-27 2008-12-30 2001-07-13 1990-05-05 1949-11-28 2004-10-04 1992-09-29 2002-02-28 2014-06-13 2010-08-21 2016-10-10 1973-09-24 2004-05-21 1968-10-04 2003-06-23 2007-10-09 2006-11-21 1996-09-24 1990-04-09 2000-10-10 1964-08-25 1995-10-07

ssdi_dod
2020-01-02 2019-12-03 2019-11-16 2019-11-02 2019-10-31 2019-10-22 2019-10-01 2019-08-29 2019-08-29 2019-08-15 2019-04-02 2018-09-23 2018-06-12 2018-05-25 2018-03-31 2018-03-26 2018-03-06 2018-01-13 2017-10-18 2017-03-07 2016-12-29 2016-07-23 2016-01-04
2019-10-19 2018-01-12
2019-03-31 2019-09-30 2018-12-31 2017-07-30

obit_dod 2018-03-30
2019-12-03
2019-11-02
2019-10-22
2019-08-29
2019-08-15
2018-09-23 2018-06-12
2018-03-31
2018-03-06 2018-01-13
2019-08-22 2019-10-19 2018-01-12 2018-12-09 2019-03-29 2019-09-30 2018-12-31 2017-07-30 2018-12-01

Exhibit B, Page 140

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 141 of 352 Pageid#: 1044

voter_id

lname

307004578 H

506016677 H

907023130 H

356533554 H

305013324 H

918964954 H

918132547 H

601023527 H

601023655 H

506009806 H

52090322 H

918446637 H

515531460 H

222012618 H

920089507 H

404023424 H

705005285 H

920179985 H

905005298 H

305015774 H

208019744 H

919305394 H

917749623 H

605013615 H

603001842 H

404002149 H

221022501 H

566277390 H

919387734 H

550561814 H

502010667 H

121006135 H

602011450 H

fname VIRGINIA JOE CAROLYN ANGUS THOMAS JAMES LUTRELL LAURA HARDY DORTHY SUE REBA FAUSTINA RUTH JOHNNY JUDITH ELLOWEESE JOSEPHINE JUANITA LILLIE PAUL PAUL PATRICIA THOMAS NOLA ALICE JAMES ANN JOY RUSSELL EDITH JAMES EDITH DIANA E

dob 1921 1946 1945 1923 1938 1947 1935 1936 1940 1948 1944 1943 1914 1948 1942 1937 1937 1924 1928 1921 1927 1962 1940 1922 1943 1928 1936 1948 1927 1989 1938 1923 1947

date_registered 1956-10-06 1987-05-09 2002-08-08 2017-05-22 2002-11-22 2000-10-07 1997-11-07 1966-06-10 1964-10-02 1976-09-29 2013-11-25 1999-03-05 2008-05-07 1991-07-29 2005-04-21 1982-09-11 1997-05-08 2005-09-13 1980-04-03 1972-09-09 1997-11-06 2002-04-08 1996-10-07 2000-03-01 1976-10-02 1968-08-06 1959-12-01 2016-10-17 2002-09-05 2007-08-17 1960-04-06 1976-09-25 1980-10-04

ssdi_dod
2019-12-28 2019-12-06 2019-09-24 2019-09-24 2010-07-23 2000-03-16 2019-12-10 2019-09-01 2019-08-16 2019-06-13 2016-08-01 2018-12-24 2018-12-16 2017-08-20 2019-09-21 2019-08-25 2019-07-08 2018-01-12
2018-12-29 2018-12-11 2017-07-01 2014-04-24
2020-01-01 2019-02-02 2019-11-21 2018-09-25 2018-08-27 2018-07-31
2019-10-09

obit_dod 2018-12-10
2019-09-24
2019-12-10 2019-09-01 2019-08-16 2019-06-13
2018-12-16 2017-08-20 2019-09-21 2019-08-25 2019-07-08 2018-01-12 2019-08-10
2018-12-11 2017-07-01
2019-08-20
2019-02-02 2019-11-21 2018-09-25 2018-08-27
2019-09-24 2019-10-09

Exhibit B, Page 141

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 142 of 352 Pageid#: 1045

voter_id

lname

408021734 H

920239921 H

20164145 H

204006567 H

31001397 H

12317926 H

919953088 H

917327460 H

122002171 H

706016000 H

301019252 H

39487342 H

920128827 H

608001998 H

206006056 H

704017524 H

919583760 H

406004422 H

124018207 H

811009391 H

202005704 H

605001363 H

918292575 H

395847599 H

112016210 H

609008016 H

308023576 H

936551955 H

918363984 H

919033981 H

917179700 H

102025353 H

809016104 H

fname HAROLD EVELYN MARGARET RYLAND ALFRED VIOLET DOUG KELVIN HENRIETTA WALLACE CARELENE MELVIN RUBY JAMES MICHELLE ROBERT JOHN ELSIE LORETTA SAMUEL ACHILLES VERNELL EDWIN GEORGE DOROTHY SHIRLEY A ELIZABETH CHARLES MARIA CARLANN FRANK CHARLES JAMES

dob 1944 1948 1939 1938 1945 1947 1936 1953 1944 1930 1935 1945 1919 1944 1965 1926 1948 1925 1928 1959 1932 1926 1943 1931 1936 1941 1925 1946 1930 1941 1930 1932 1946

date_registered 1976-08-12 2006-01-19 2012-10-08 1964-09-05 2004-11-03 2016-08-29 2004-10-04 1995-09-18 1994-05-06 2000-03-01 1976-10-02 2016-09-19 2005-07-01 1993-11-24 1984-03-20 1977-10-08 2004-04-05 1993-03-09 1976-01-01 1977-04-13 1968-09-30 1961-06-01 2004-04-20 2016-03-15 2013-05-20 1988-10-04 1956-09-29 2008-09-05 1998-10-05 2001-02-05 1994-09-29 1971-09-14 1967-06-08

ssdi_dod 2019-08-23 2019-07-01 2016-11-23
2019-11-19 2019-08-31 2017-12-31
2019-02-20 2019-10-11 2019-09-19 2018-12-01 2018-04-06 2015-09-15
2018-05-30 2019-09-08 2019-01-04 2019-12-23
2019-11-18
2019-10-29 2019-09-26

obit_dod 2019-08-23 2019-07-01 2016-11-23 2019-08-01 2016-07-26
2019-08-31
2019-05-14 2018-12-01 2017-11-30 2016-12-27 2019-02-20 2019-10-11
2018-12-01
2015-09-15 2019-09-06 2018-05-30 2019-09-07 2019-01-14
2019-08-13 2015-11-13 2017-03-09 2018-12-20 2018-01-21 2017-09-19 2019-11-18 2018-12-13
2019-09-26

Exhibit B, Page 142

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 143 of 352 Pageid#: 1046

voter_id

lname

704018548 H

919466431 H

223010580 H

601013484 H

919632463 H

103017296 H

501014754 H

200370553 H

602010791 H

919659944 H

209019747 H

810019703 H

5214371 H

506014601 H

918594679 H

906015859 H

22010885 H

702004524 H

917186991 H

502015427 H

24000996 H

223633810 H

26020030 H

917599089 H

306020872 H

708005451 H

60642874 H

25008620 H

333180598 H

692038335 H

228003525 H

920107118 H

507021987 H

fname CAROLYN DOROTHY GERALD EDWARD ROBIN RUTH WENDELL HILLIARD WILLIAM CARL BETTY MILDRED REBECCA HARRY FAY RUTH CECIL MARY JOSEPH JULIA SHIRLEY WILLIAM VELMA TERESA DAVID JAMES ESTHER SHARON PEARL MARGARET HARDY GREGORY LINDA

dob 1955 1933 1937 1936 1951 1928 1935 1927 1937 1946 1956 1943 1958 1930 1938 1919 1943 1948 1943 1931 1935 1945 1946 1962 1943 1937 1930 1956 1942 1935 1921 1947 1939

date_registered 1999-11-03 2003-02-04 2003-05-09 1993-08-13 2004-11-03 1998-11-04 1973-03-16 2011-04-07 1980-09-11 2004-01-07 1996-11-05 1992-09-29 2017-03-20 1989-06-14 1999-09-24 1968-09-20 1975-11-05 1980-10-04 1994-09-24 1963-06-19 1972-05-24 2016-11-14 1979-12-17 1996-08-16 1972-09-21 2000-03-03 2012-08-22 2002-09-16 2012-10-08 2007-10-02 1969-05-26 2005-05-16 1975-10-02

ssdi_dod 2019-10-08 2018-05-15 2018-01-25
2019-08-16 2015-03-27 2018-12-10 2017-01-11
2019-07-02 2019-10-22 2018-12-18 2017-11-23 2019-11-20
2020-01-29 2020-01-29 2019-12-02 2019-09-29 2019-01-19 2018-11-06
2019-10-18 2018-01-26
2019-08-10 2018-04-12
2019-08-13

obit_dod 2019-10-08 2018-05-15 2018-01-25 2019-03-23 2019-08-16
2019-10-04 2018-12-14 2019-07-02
2018-12-18 2017-11-23 2019-11-20 2015-03-07
2019-12-02 2019-10-01 2019-01-19 2018-11-06 2018-01-22
2018-01-26 2019-08-29 2016-07-27 2019-08-10 2018-04-12 2017-11-29 2019-08-02 2018-12-21

Exhibit B, Page 143

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 144 of 352 Pageid#: 1047

voter_id

lname

321202024 H

506027808 H

501003815 H

224008185 H

919115980 H

29014246 H

918938951 H

681631823 H

917981365 H

607031157 H

701006646 H

190209677 H

707006647 H

918330864 H

207002435 H

901001657 H

917119549 H

508011920 H

901015386 H

506000326 H

918016778 H

323741013 H

918229324 H

610024964 H

601025418 H

917711542 H

302032320 H

23016080 H

708013817 H

918624124 H

504019119 H

224001376 H

221006071 H

fname CHRISTINA EGON HELEN ROOSEVELT JOHN JAMES JULIA ERNEST WILLIAM BILLIE JO CLARICE DONALD ANDREW DOROTHY WILMA JEAN THOMAS MARLENE SHEILA LAURA COY KATHERINE ERNEST ROBERT BARBARA HELEN JULIA GEORGE JOEL LINDA NANNIE HOWARD STEPHEN MARYJAYNE

dob 1969 1919 1928 1940 1928 1959 1908 1935 1928 1939 1929 1955 1946 1932 1947 1946 1940 1939 1961 1922 1957 1945 1943 1961 1925 1939 1927 1945 1945 1959 1951 1948 1930

date_registered 2016-02-08 1982-03-31 1976-05-05 1980-09-23 2001-06-13 1980-10-02 2000-10-10 2008-10-06 1997-04-28 1967-10-07 1956-12-30 2016-06-17 1970-01-02 1998-09-03 2000-08-15 1984-01-02 1994-05-11 2006-01-14 1981-10-03 1997-08-18 1997-06-13 2016-09-25 1998-03-31 1998-09-03 1973-10-01 1999-07-14 1973-09-06 1986-03-07 1974-10-05 2004-07-13 2006-06-22 1996-09-04 1987-09-23

ssdi_dod 2018-07-27
2018-01-13
2019-10-25 2019-07-04 2003-01-19
2016-09-08 2019-12-23 2019-10-19 2019-10-02 2019-09-17 2018-03-21
2020-01-03 2014-04-20 2019-11-23 2019-10-06 2018-06-13 2017-04-07 2016-10-07
2019-10-20
2019-12-11 2019-09-06 2019-03-14 2017-06-28 2018-01-31

obit_dod
2019-08-18 2018-01-13 2019-10-06 2019-10-25 2019-07-04
2019-09-17 2016-09-08 2019-12-23
2019-09-27 2018-03-21 2019-11-07 2018-12-30 2019-10-16
2014-04-20 2019-11-23 2019-10-06 2018-06-13 2017-04-07 2016-10-07 2019-09-23 2019-09-03
2019-08-03
2019-09-06 2019-03-14 2017-06-28 2018-01-31

Exhibit B, Page 144

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 145 of 352 Pageid#: 1048

voter_id

lname

917352489 H

110023934 H

920156800 H

906012662 H

919114716 H

401009895 H

17191125 H

919606156 H

238050145 H

630738556 H

986689368 H

917921851 H

15005361 H

121000913 H

917717520 H

101005910 H

109005909 H

742677784 H

712013302 H

28010326 H

411016431 H

917378261 H

607031787 H

918816172 H

919649425 H

654471703 H

918564509 H

229002949 H

565175335 H

919709690 H

206002653 H

919233475 H

123002738 H

fname ALICE DONNIS CHUNG-LIANG GLADYS NATIVIDAD JAMES MARY WESLEY BARBARA GERALD KRISTEN WILLIAM ROY WALTER CHARLES PAUL HELEN ERMAN HELEN BERNARD LINDA LOIS CARL HENRY JEAN WILLIAM ERNESTINE RONALD NYLE DUANE GLADYS VIRGINIA WILLIAM

dob 1923 1943 1955 1924 1920 1944 1936 1945 1943 1940 1990 1935 1932 1944 1951 1933 1929 1940 1947 1925 1947 1938 1936 1950 1940 1933 1936 1957 1937 1930 1943 1961 1924

date_registered 1995-10-04 1972-10-07 2005-08-31 1952-09-30 2001-06-13 1998-02-19 2010-10-12 2003-10-03 2008-05-12 2016-09-16 2008-05-12 1997-03-04 2002-10-07 1973-10-02 1996-09-14 1967-09-25 1986-10-04 2007-09-27 1992-10-02 1964-06-11 1992-07-20 1995-11-08 1970-09-28 2000-06-26 2003-12-12 2017-09-25 1999-08-20 1996-10-07 2013-11-11 2004-03-12 1987-12-01 2001-11-07 1984-03-28

ssdi_dod
2015-03-30
2018-01-30 2019-09-12 2018-12-15
2019-09-17 2018-03-03 2019-09-15 2018-01-01 2017-12-20
2018-12-20 2018-08-02 2016-07-30
2020-01-02 2019-12-18 2019-09-22 2019-09-22 2019-09-03 2019-08-13 2015-05-20 2019-09-02 2019-12-22 2019-09-11 2019-08-24 2019-11-14 2019-11-01 2018-05-10 1995-08-23

obit_dod 2018-12-07 2019-09-14
2019-09-15
2019-09-12 2018-12-15 2019-03-28 2019-09-17
2018-01-01 2017-12-20 2014-12-08 2018-12-20
2018-12-29
2019-09-22
2019-09-03 2019-08-13
2019-09-02 2019-12-22 2019-09-11
2019-11-14 2019-11-04 2018-05-10

Exhibit B, Page 145

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 146 of 352 Pageid#: 1049

voter_id

lname

605021511 H

305001851 H

917763821 H

311025415 H

919674565 H

278148575 H

612033883 H

211014528 H

710007918 H

8729612 H

112005099 H

304539878 H

648836980 H

614025284 H

8004961 H

307002439 H

206006569 H

919584213 H

905020082 H

211346198 H

708000223 H

920395772 H

850792028 H

802007307 H

301032321 H

502011630 H

918712574 H

401003167 H

918458961 H

221012973 H

298810987 H

907018535 H

222016249 H

fname RICHARD VIRGINIA JUDITH MARCIA MARK JOE EDWARD MARIE RILEY HARRY WILLIAM JAMES ROBERT MARY LAURA MIRIAM DAVID MICHAEL WESLEY GERALD RUSSELL JEANNETTE PATRICIA LAWTON KAREN CARTER BURNICE MARY FRANK DENNIS MARY ODELL MARIAN

dob 1925 1925 1936 1932 1943 1939 1942 1925 1923 1939 1960 1951 1978 1934 1943 1925 1946 1964 1935 1949 1923 1940 1948 1935 1949 1936 1947 1929 1933 1952 1947 1936 1940

date_registered 1979-10-06 1976-10-02 1996-10-07 1994-10-07 2004-02-11 2012-09-28 1964-09-24 1964-09-16 1955-06-07 2015-09-02 1991-05-16 2016-06-16 2008-10-06 2006-03-17 1983-10-08 1971-01-21 1983-10-08 2003-09-03 2004-08-16 2010-10-06 1954-10-02 2006-11-13 2007-09-28 1976-06-09 1993-10-04 1964-08-03 2000-03-01 2004-08-13 1999-03-22 1997-03-06 2007-03-08 1982-10-02 2001-07-05

ssdi_dod 2020-01-13
2019-11-25 2016-09-09
2018-12-09
2020-01-09
2018-12-15 2018-04-08
2019-12-24 2019-11-30 2018-12-05 2020-01-21 2020-01-14 2019-12-17 2019-11-25 2019-11-10 2019-11-07 2019-11-03 2019-10-26 2019-10-25 2019-10-08 2019-10-07 2019-09-30 2019-08-14 2019-08-02 2018-01-09

obit_dod
2017-06-28
2018-04-19 2018-12-09 2019-09-26 2019-09-14 2019-09-06
2017-06-30 2018-12-15
2019-10-11 2019-08-20
2019-12-17 2019-11-25 2019-11-10
2019-11-03 2019-10-26 2019-10-25 2019-10-09 2019-10-07
2019-08-14 2019-08-02

Exhibit B, Page 146

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 147 of 352 Pageid#: 1050

voter_id

lname

918556813 H

509009301 H

25009148 H

104003246 H

166854518 H

918608795 H

227020912 H

919266084 H

208017532 H

803023260 H

917538133 H

807016345 H

202029721 H

917516284 H

801005851 H

809009396 H

304033066 H

906009918 H

703002354 H

128011747 H

125005214 H

28005059 H

917024242 H

919303532 H

233010930 H

919023565 H

704014548 H

919848550 H

920246881 H

919806618 H

105005719 H

102025824 H

918389522 H

fname TIMOTHY LUCILLE JAMES CARTER LEROY BETTY MARGARET MARGARET ROBERT DAVID DARLENE WILLIAM JAMES JOHNNY ROBERT BETTY CARROLL JULIA CHARLES JAMES FAY DONALD DAVID CHIEN JOHN VIRGINIA JAMES JERRY BRANDY FLORENCE NANCY DONALD RAMONA

dob 1962 1925 1946 1938 1942 1925 1925 1942 1928 1948 1958 1943 1941 1943 1927 1940 1935 1940 1939 1934 1929 1952 1962 1931 1934 1925 1949 1944 1976 1951 1929 1943 1952

date_registered 2001-07-19 1999-07-26 1975-12-18 1989-09-30 2017-04-06 1999-10-04 1991-12-02 2002-01-31 1970-06-11 1983-09-17 1996-07-02 1974-09-07 1992-01-07 2004-07-01 1997-10-01 1992-09-26 1983-10-08 1964-08-18 1977-10-05 1982-11-05 1952-10-02 1971-08-14 2001-09-24 2002-04-05 1988-09-20 2000-12-20 1970-09-26 2004-08-23 2006-02-02 2004-07-15 1955-05-01 1967-10-01 1999-05-13

ssdi_dod 2016-05-05 2014-03-02
2019-12-10 2019-08-04 2014-04-29 2019-12-19 2019-11-17 2019-09-30 2019-08-23 2018-12-27 2018-12-17 2018-08-26
2019-12-15 2018-12-05
2019-10-03 2018-12-21 2019-10-27 2019-05-08 2014-01-05
2019-11-10 2019-11-05 2019-10-05 2019-09-24 2019-07-05 2018-09-14
2018-01-29

obit_dod 2016-05-05 2014-03-02 2018-10-25 2019-10-27 2019-12-10 2019-08-04 2014-04-29 2019-12-19 2019-11-17 2019-09-30 2019-08-23 2018-12-27
2018-08-26 2019-03-23 2018-12-17
2018-12-05 2018-12-05
2018-12-21 2019-10-27 2019-05-08
2019-10-01 2019-11-10
2019-10-05 2019-09-24 2019-07-05 2018-09-14 2018-12-02

Exhibit B, Page 147

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 148 of 352 Pageid#: 1051

voter_id

lname

386679184 H

919012549 H

918878840 H

502005700 H

603004497 H

104006942 H

209012421 H

918819176 H

905005591 H

918825490 H

393646822 H

806008722 H

917670216 H

383903680 H

106007686 H

606511048 H

802020334 H

303019786 H

917071883 H

226012624 H

919780323 H

14418119 H

919603256 H

805001604 H

255437589 H

911015388 H

917774142 H

410247524 H

715015218 H

601013779 H

919474414 H

228020609 H

112010262 H

fname ANTONINO ROLAND JOHNNIE JOYCE FLOSSIE PRESTON CLARENCE FRED OSCAR ARLENE HAMPTON DREAMA JOHN VIRGINIA JAMES MARCIA SHELBY CHRISTINE MARTHA DONLEY SHARON SUNNY DELMER CYNTHIA BRADFORD VIRGINIA TOMMY DAVID HUBERT ANNA M JOHN GERTRUDE ELENA

dob 1962 1949 1946 1936 1924 1935 1933 1935 1934 1923 1927 1932 1934 1939 1933 1930 1937 1950 1933 1937 1961 1939 1934 1948 1987 1923 1947 1944 1945 1922 1961 1920 1926

date_registered 2007-11-07 2000-12-27 2000-09-11 1985-10-05 1945-06-30 1964-09-30 1970-10-02 2000-07-07 1987-03-23 2000-07-18 2016-03-16 1965-09-30 1999-04-12 2012-04-05 2003-04-04 2009-11-17 1979-10-06 1997-10-06 1996-06-12 1976-10-02 2004-06-10 2016-08-30 2003-10-01 1992-09-22 2011-08-29 2000-11-13 1996-10-07 2012-08-29 1988-08-29 1962-05-19 2003-02-25 1957-10-05 1992-09-30

ssdi_dod 2019-05-27 2019-03-23
2016-12-18 2020-01-08 2019-12-21 2019-11-20 2019-11-11 2019-10-25 2019-05-18 2017-12-10
2020-01-27 2019-06-23 2018-01-16
2014-02-03 2019-10-31 2019-07-04 2018-06-20 2018-01-27
2020-01-02 2019-12-26 2019-10-18 2019-10-17 2019-09-25 2019-09-03

obit_dod 2019-05-27 2019-03-23 2019-09-29 2016-12-18
2019-12-21
2019-10-25
2017-12-10 2019-10-10 2019-06-15 2018-01-13 2019-09-18
2019-06-23 2018-01-16 2019-08-29 2017-08-15 2014-02-03 2019-10-31 2019-07-04
2018-01-27 2019-05-21 2018-12-29
2019-10-18 2019-10-17 2019-09-25 2019-09-03

Exhibit B, Page 148

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 149 of 352 Pageid#: 1052

voter_id

lname

609001613 H

918206594 H

918536530 H

105016166 H

305042281 H

226007287 H

230010314 H

919274540 H

920295979 H

303014572 H

303048554 H

206007655 H

6114055 H

103007984 H

415003830 H

209003553 H

918836657 H

201011880 H

23013008 H

207014529 H

123020268 H

806011122 H

202020470 H

918572236 H

108002834 H

506030676 H

204027175 H

920296431 H

605028923 H

204214577 H

211019754 H

210012424 H

532757479 H

fname NANCY MIRABEAU NANNIE JANET CHARLES BERNARD NORMAN JARROD BARBARA SAMUEL RUTH DINA MARY LYNDELLE FRANK BILLY SARAH CHARLES EDNA MYRTLE SARA WILLARD DAVID WILLIAM ROBERT BRENDA HENRY RICHARD CALVIN CHARLES JOHN CORNELIA BEVERLY

dob 1939 1932 1939 1942 1932 1947 1955 1982 1939 1932 1930 1932 1934 1926 1932 1933 1975 1933 1925 1933 1927 1935 1940 1979 1928 1948 1951 1949 1932 1944 1944 1927 1963

date_registered 1998-09-25 1998-03-04 2000-04-03 1995-07-10 1972-10-07 1983-11-14 2004-08-20 2002-02-07 2006-05-03 2004-03-23 1973-10-06 1966-09-23 2012-09-18 1956-10-06 1993-02-23 2000-04-20 2004-10-04 1992-10-03 1991-09-09 1987-10-03 1993-04-26 1955-12-30 2005-12-09 1999-08-31 1952-05-03 2005-11-15 2006-09-26 2006-05-03 1979-03-09 2009-09-24 1999-08-16 1988-06-18 2009-01-23

ssdi_dod 2019-01-19 2018-12-06 2018-03-22
2019-08-30 2017-08-01
2019-11-03 2019-11-23 2018-03-22
2020-01-22 2020-01-10 2019-08-24
2019-08-12 2019-11-01 2018-06-25 2018-06-24 2017-04-30 2019-11-20 2019-08-24 2019-08-10 2017-02-22 2019-08-09 2020-01-20 2019-12-06 2019-11-01 2019-10-07

obit_dod 2019-01-19 2018-12-06
2019-10-23 2019-10-08 2016-12-28
2017-08-01 2019-06-29 2019-11-03 2019-11-23 2018-03-22 2017-09-29 2019-09-08
2019-08-14 2015-10-29 2019-08-12 2019-11-01 2018-06-25
2017-04-30 2019-11-20 2019-08-24 2019-08-10 2017-02-22 2019-08-09
2019-12-06 2019-11-01 2019-10-07

Exhibit B, Page 149

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 150 of 352 Pageid#: 1053

voter_id

lname

804015369 H

919274829 H

880241906 H

917141421 H

224006077 H

223004009 H

905006844 H

920057199 H

920214401 H

126015899 H

27002815 H

918861738 H

506027814 H

303037150 H

30337607 H

917583425 H

51158505 H

920274345 H

708011834 H

204001167 H

808017623 H

221009338 H

706015887 H

917020456 H

920017621 H

107003251 H

919671871 H

918595415 H

808011123 H

304027578 H

400942015 H

223017235 H

919495273 H

fname HAZEL RUSSELL KENNETH CLAIRE RITA BENFORD DORIS CHARLOTTE SAMMY FREDA AARON DAVID WINNIFRED MICHAEL JANET MITZIE MELVILLE EVELYN BERNARD BETTY ESTELLE SANDRA SUE CALVIN IRA WILLIAM NANCY HELEN MARY LUCILLE JOHN LINDA EARNESTINE

dob 1930 1944 1933 1928 1932 1946 1927 1940 1940 1948 1928 1949 1929 1929 1932 1954 1946 1929 1927 1932 1934 1942 1947 1945 1930 1930 1930 1918 1933 1921 1957 1941 1933

date_registered 1992-09-22 2004-09-09 2012-10-10 1994-07-29 1985-08-26 1976-08-17 1971-11-04 2005-02-10 2005-11-18 1976-10-02 1972-04-01 2000-08-25 1976-09-16 1955-10-08 2007-02-01 1996-08-07 2016-09-26 2006-03-31 1986-12-23 1978-10-04 1960-10-06 2000-07-14 1973-10-05 1993-09-14 2004-11-03 1955-04-02 2004-01-12 1999-09-27 1974-09-30 1980-09-10 2016-09-20 1987-06-29 2003-04-04

ssdi_dod 2019-10-05 2018-03-20 2015-11-30
2020-01-01 2019-10-16 2019-08-11 2019-08-07 2018-09-10 2018-04-06
2020-01-24 2018-12-16 2005-06-29 2018-12-19 2018-12-19
2020-01-25 2019-12-01 2014-10-31 2019-11-11 2018-04-09 2019-10-26 2018-06-28 2019-12-13 2019-12-21 2019-10-09 2017-06-29
2019-10-08 2015-11-25 2019-10-27

obit_dod 2019-10-05 2018-03-20 2015-11-30 2017-09-15
2019-10-16 2019-08-11
2018-04-06 2018-12-10
2018-12-16
2018-12-19 2018-12-19 2019-09-10 2019-10-25
2019-12-01
2019-11-11
2019-10-26 2018-06-28 2019-12-13
2019-10-09 2017-06-29 2016-01-31 2019-10-08
2019-10-27

Exhibit B, Page 150

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 151 of 352 Pageid#: 1054

voter_id

lname

918074532 H

309048176 H

105270720 H

917141014 H

918934080 H

223000970 H

919027731 H

506009302 H

404026373 H

301017975 H

966664351 H

919651716 H

398193270 H

917911620 H

306008552 I

920307243 I

918074869 I

948820712 I

919908847 I

918911396 I

305007066 I

918826400 I

602027243 I

306004591 I

622111635 I

919981259 I

501002555 I

22014258 I

147147538 I

303029946 I

269140959 I

402721369 I

745129997 I

fname JOAN ANDREW GRADY JOHN JOYCE ELINOR COLLEEN JACK OLIN DENNY TOMMY THERESA JOSEPH LINDA MARIO MARGEE LOIS MARY ANTONINO ARILD KARL CARL ELLIS HARVIE DIANA PHYLLIS MARY SUZANNE JAVED DOMINIC ERNEST DONALD DORINE

dob 1936 1944 1925 1934 1934 1921 1966 1934 1930 1935 1944 1958 1951 1943 1929 1939 1928 1924 1939 1923 1932 1945 1948 1929 1942 1945 1944 1939 1960 1942 1948 1926 1947

date_registered 2000-06-14 1991-09-21 2014-04-30 1994-08-06 2000-10-09 1963-04-26 2000-12-13 1992-08-13 2002-05-29 1984-09-26 2007-06-07 2003-12-18 2008-10-02 1997-02-06 1984-10-03 2006-06-15 1997-08-28 2007-07-06 2004-09-23 2000-09-29 1967-08-21 2000-07-19 1991-07-12 1984-02-16 2018-11-15 2004-10-04 1980-10-04 1984-03-26 2010-05-17 2004-09-23 2008-10-06 2016-11-22 2014-01-15

ssdi_dod 2019-08-10
2019-10-23 2019-09-26 2019-08-27 2016-05-24 2019-10-17
2019-10-21 2018-08-27 2018-04-17 2019-01-29
2018-01-21 2019-08-29 2019-05-18 2019-08-18 2019-09-11 2019-11-20 2019-08-16 2019-10-20 2020-01-25 2019-09-29 2018-12-28 2015-08-30 2019-09-21 2019-08-28 2017-01-27
2016-12-27 2019-12-07

obit_dod 2019-08-10 2019-10-09 2016-04-02 2019-10-23 2019-09-26 2019-08-27
2019-10-17 2019-05-26 2019-10-21 2018-08-27
2019-01-29 2018-07-20
2019-08-18
2019-10-20
2019-09-29
2019-09-21
2016-09-01 2018-12-17
2019-12-07

Exhibit B, Page 151

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 152 of 352 Pageid#: 1055

voter_id

lname

406001888 I

803008952 I

607002433 I

30674401 I

601029350 I

121002512 IS

704967730 IS

51347612 IS

919219106 IS

551520133 IS

917494545 IS

492749120 IS

206020809 I

153348051 I

978155333 IZ

148685203 J

920232878 J

605013218 J

602017097 J

903000141 J

918137943 J

26019488 J

508008240 J

402031292 J

21055906 J

407022861 J

919774411 J

754123879 J

408012521 J

228005133 J

919743673 J

605102644 J

128010280 J

fname RICHARD CAROLYN WILLIE LUCY ALVIN CAROLYN MARY FELIX LUTHER WILLIAM DOROTHY YOUSEF JAMES ALEX SHARON JOHN ALVIN RONNIE HERMAN LUCILLE LARRY ERCELL ANN ROBERT DELOIS JAMES LOUISA JANICE DORIS NATHANIEL PHYLLIS STEPHANIE BENNIE

dob 1932 1933 1933 1928 1931 1924 1918 1944 1936 1953 1947 1946 1941 1925 1944 1941 1939 1946 1947 1917 1942 1921 1948 1927 1959 1947 1947 1952 1941 1940 1942 1971 1926

date_registered 1998-02-04 1968-08-18 1967-06-07 2016-10-17 1966-10-08 1999-11-22 2012-09-11 2012-09-12 2001-11-08 2014-11-05 1996-04-24 2008-06-11 1971-08-13 2016-10-04 2008-10-06 2012-10-10 2005-12-28 1984-09-20 2015-09-08 1961-10-07 1997-11-12 1950-10-06 1984-09-22 1996-12-12 2008-10-06 1984-01-17 2004-06-05 2008-01-05 1964-08-31 2000-03-08 2004-05-03 2008-07-29 1953-12-04

ssdi_dod
2019-12-17 1994-03-18
2019-09-25 2019-08-13 2019-05-22 2019-12-03 2019-12-05 2019-11-26 2019-12-19 2017-12-16
2020-01-02 2018-03-19 2019-10-02 2018-10-31 2020-01-09 2020-01-02 2019-12-27 2019-12-22 2019-12-19 2019-11-26 2019-11-17 2019-11-11 2019-10-26 2019-10-10 2019-08-13 2019-08-11 2019-08-07 2019-08-02 2019-07-16 2019-06-30

obit_dod 2016-06-17 2019-12-17 2019-09-17 2019-09-25 2019-08-13 2019-12-03 2019-12-05 2019-11-26
2019-08-09
2018-10-31
2019-11-26 2019-11-17 2019-11-11 2019-10-26 2019-10-10 2019-08-11 2019-08-07 2019-07-16

Exhibit B, Page 152

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 153 of 352 Pageid#: 1056

voter_id 140201587 J 293387372 J 130009406 J
27015675 J 919681042 J 130660216 J 505006813 J 918963317 J 652228304 J 963395091 J 127532277 J 304018736 J 135796260 J 705014819 J 919903683 J 207011883 J 919330264 J 703015222 J 901017382 J 805007732 J 608018875 J 703031166 J 918165949 J 108016172 J 701021656 J 919368947 J 402645911 J 507006374 J 304048935 J 230007291 J 919656065 J 919092664 J 204015724 J

lname

fname DERECK CHRISTAL ZENORI IRVIN ERIC MARY WALTER DIANE ELLEN ANN FANNIE CHARLES MILTON SUZANNE MARIE MARY ODELL BETTY ROBERT HOMER HENRY AUDREY GORDON ROBERT MARK CAROLYN BARBARA VERLA WILLIAM STEPHEN ARTHUR QAISAR KATALIN RAJAN

dob 1958 1954 1955 1930 1966 1944 1938 1954 1927 1965 1926 1928 1954 1946 1918 1943 1939 1938 1947 1945 1933 1928 1957 1946 1956 1947 1921 1925 1933 1945 1935 1936 1945

date_registered 2016-09-28 2016-02-02 2016-05-23 1963-05-01 2004-02-14 2008-10-06 1959-10-03 2000-10-10 2008-09-29 2008-03-06 2012-10-05 1998-09-28 2008-12-29 1987-10-02 2004-09-21 1996-09-24 2002-05-23 1959-08-31 1984-08-07 1992-08-20 1987-10-01 1992-10-03 1997-11-22 1997-06-27 1996-12-26 2002-08-02 2007-03-21 1984-08-10 2002-05-29 1992-10-02 2003-12-30 2001-04-27 1998-03-04

ssdi_dod 2019-01-11 2019-01-10 2018-12-26 2018-12-23 2018-03-18 2018-03-17 2018-01-28 2017-11-28 2017-11-15 2017-10-02 2016-10-11 2015-11-30 2014-11-07 2008-11-14 2004-05-27
2017-03-04 2019-10-31 2018-12-30
2018-07-19 2020-01-09 2018-10-20
2019-12-08 2019-08-22 2017-10-24 2018-09-09

obit_dod 2019-01-11 2019-01-10 2018-12-26 2018-12-23
2018-01-28 2017-11-28 2017-11-15
2008-11-14 2004-05-27 2019-10-12 2019-06-18 2018-05-12 2016-01-10 2014-11-20
2019-10-31 2018-12-30 2019-01-07
2019-09-05
2019-08-22
2018-09-09 2019-06-24

Exhibit B, Page 153

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 154 of 352 Pageid#: 1057

voter_id 302010444 J 126006791 J 115555154 J 503034103 J 702000224 J 104001551 J 646858275 J 110014144 J 308023904 J 541657274 J 505012164 J 917776977 J 108001843 J 716015636 J 904001011 J 807002600 J 503024589 J 512003819 J 854671203 J 123002515 J 905009324 J 919020912 J 242870330 J 304049363 J 303032329 J 919714810 J 306040063 J 454137060 J 917875015 J 727714466 J 609005994 J 918991575 J 506024999 J

lname

fname WILLIAM JOHN CELESTE CLAIRE WILLIAM BESSIE ROOSEVELT JACQUELINE HERBERT SUSIE BRUCE MARCHETTA ROBERT JOYCE IMOGENE JOHN MARTHA JOYCE JOSEPH HAIGH DONALD CHARLES PHILIP EDMUND MANNING ELIZABETH ANALYNN GEORGE ABEL MARIANNA CINDY JOHN IRVING

dob 1943 1941 1936 1935 1939 1948 1947 1956 1946 1953 1954 1944 1920 1935 1924 1946 1946 1934 1947 1924 1934 1941 1955 1928 1921 1935 1930 1932 1921 1967 1953 1934 1925

date_registered 1984-10-04 1972-09-12 2013-11-14 1992-09-09 1987-07-08 1983-10-04 2008-08-22 1988-04-06 1984-05-05 2008-07-17 1992-09-28 1996-09-29 1984-07-23 1988-09-28 1952-10-04 1973-10-03 1984-08-29 1993-04-27 2016-10-21 1956-08-10 1968-10-05 2001-01-16 2018-07-20 1966-10-08 1987-09-17 2004-03-19 1980-05-10 2013-03-13 1997-02-13 2011-04-15 2004-03-01 2000-11-28 1967-05-06

ssdi_dod 2019-11-02
2019-10-17 2020-01-21 2020-01-06 2019-12-16 2019-11-10 2019-01-23 2018-10-15 2018-08-28 2018-06-22 2018-02-28 2018-02-13 2017-05-09 2015-03-31 2014-11-28
2019-08-21 2019-11-18 2019-11-19 2019-06-07 2019-08-03
2019-11-06
2018-12-30 2019-04-16 2019-01-14 2018-08-08 2017-12-22 2019-11-19 2019-08-29

obit_dod 2019-11-02 2019-08-04 2019-10-17
2019-12-16
2019-01-23
2018-06-22 2018-02-28
2014-11-28 2019-10-11 2019-08-11 2019-08-21 2019-11-18 2019-11-19 2019-06-07 2019-08-03 2019-09-19 2019-11-06 2019-09-06 2018-12-30
2017-12-22 2019-11-19

Exhibit B, Page 154

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 155 of 352 Pageid#: 1058

voter_id 918266280 J 608008772 J 918148253 J 111020053 J 606004227 J 403013355 J 918537738 J 917041835 J 202000351 J 407003716 J 918895361 J 917384231 J 127012418 J 407015965 J 306119568 J 701008789 J 222022279 J 917335021 J 964462701 J 917923125 J 606033745 J 410023107 J 917558824 J
39303075 J 539057439 J 435967091 J 918966361 J 404005301 J
24018763 J 917393606 J 307012821 J 206567534 J 225007608 J

lname

fname ELEANOR LORA MARY KATHY BRANTLEY PURCELL JAMES HAROLD EVELYN GROVER INEZ MONTE JUNE MICHAEL ARTHUR THELMA NANCY CATHERINE KATHLEEN WILLIAM EVELYN FANNIE MAGALINE BELINDA ERNEST JASON CARRIE MICHAEL MONETTA MICHAEL CHARLES JOYCE NELSON

dob 1928 1945 1940 1954 1930 1948 1944 1947 1941 1943 1926 1941 1940 1946 1949 1933 1928 1932 1945 1939 1933 1931 1938 1959 1961 1977 1929 1967 1959 1956 1941 1952 1940

date_registered 1998-05-19 2004-09-07 2016-08-25 1989-09-14 1960-05-28 1975-04-12 1999-07-09 1994-10-08 1964-09-26 2014-06-20 2000-09-16 2000-05-03 2000-03-24 1986-12-30 2008-09-30 1988-03-30 1964-09-28 1995-09-23 2008-08-29 1997-03-04 1976-04-15 1991-07-30 1999-06-30 2016-09-06 2017-07-11 2012-09-06 2000-10-10 1992-10-03 1994-10-01 1997-01-03 1989-09-19 2011-03-16 1994-07-28

ssdi_dod
2018-12-31 2018-06-24 2019-09-08 2020-01-20 2019-10-23 2019-08-20 2019-05-26 2018-01-11
2019-08-16 2019-10-01 2019-11-01 2018-12-18 2018-09-17 2019-12-14 2019-10-17 2019-10-15 2019-09-25 2019-07-22 2018-12-19 2018-12-07 2018-06-26 2018-02-04 2018-02-02 2018-01-25 2015-11-18 2011-09-08
2019-08-03

obit_dod 2018-11-18 2018-12-31 2018-06-23 2019-09-08
2019-10-23
2018-01-11 2018-11-06 2013-12-01 2019-09-01
2019-11-02 2018-12-18 2018-09-17 2019-12-14 2019-10-17 2019-10-15 2019-09-25 2019-07-22 2018-12-19 2018-12-07
2018-02-04 2018-02-02 2018-01-25
2011-09-08 2019-08-30 2018-09-28 2019-08-03

Exhibit B, Page 155

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 156 of 352 Pageid#: 1059

voter_id

lname

918831607 J

106023936 J

405013541 J

804011126 J

606075393 J

225008794 J

599744576 J

917733182 J

919975993 J

66520497 J

303028874 J

6001013 J

223009081 J

504009306 J

614013219 J

607026034 J

602027870 J

702015223 J

506009997 J

917667489 J

917908456 J

406009249 J

710004002 J

507008653 J

401017401 J

603003122 J

810013440 J

488695190 JI

633408854 JI

509023376 J

917305241 J

907012672 J

807017366 J

fname JOHN DENNIS ANNIE DOROTHY THOMAS SANDRA EDWARD GARY JOANN DONALD CONRAD LAETITIA CLARA LESTER RUTH PAUL JERRY ELOISE RUTH JOHN DONNA LEWIS RUBY WILLIAM ROBERT DAVID CHERMICA BARNEY ROBERT JOHN THOMAS ALEXANDER FRANCES

dob 1931 1943 1918 1935 1924 1944 1947 1955 1937 1928 1944 1941 1912 1924 1928 1937 1943 1942 1923 1942 1945 1926 1933 1929 1934 1926 1975 1991 1943 1940 1926 1962 1939

date_registered 2000-07-25 1984-08-30 1968-04-26 1964-08-05 2013-09-27 1990-10-05 2016-10-17 1996-10-04 2008-10-06 2018-06-22 2002-05-08 1962-08-20 2003-10-06 1947-06-24 1989-10-07 1958-10-04 1972-05-24 1981-09-29 1998-05-11 1996-09-18 1997-02-25 1984-03-07 1967-10-03 1987-08-18 1973-10-06 2004-04-21 2004-10-04 2013-08-05 2008-10-06 1988-08-16 2001-08-28 1987-09-26 1989-10-03

ssdi_dod 2019-11-19 2019-11-05 2019-10-17 2019-09-14 2019-09-10 2018-12-05 2018-08-20 2017-11-27 2013-09-28 2020-01-14 2019-11-03 2018-12-01
2019-02-20 2020-01-12 2019-10-01 2018-02-22 2018-01-18 2017-12-26
2018-12-14 2019-12-13 2015-02-16 2019-09-28
2016-12-13 2017-12-27 2018-02-05 2016-05-25
2018-08-05 2015-03-28 2019-02-27

obit_dod
2019-11-05 2019-10-17 2019-09-14 2019-09-10
2018-08-20 2017-11-27 2013-09-28
2019-11-03
2018-12-27 2019-02-20
2019-10-01 2018-02-22
2017-12-26 2017-03-10 2018-12-14
2019-09-28 2019-08-02 2016-12-13 2017-12-27 2018-02-05
2019-09-27

Exhibit B, Page 156

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 157 of 352 Pageid#: 1060

voter_id 918293474 J 108003571 J 917352740 J 502007993 J 918593957 J 402026051 J 830800363 J 227020616 J 107007992 J 211000032 J 507004276 J 310002660 J 207322780 J 917597079 J 917195113 J 222019165 J 919611540 J 861820783 J 803018741 J 810010915 J 505016989 J 701023016 J 507015759 J 127896432 J 918944115 J 911012675 J
26013353 J 184553563 J
67997273 J 917181194 J 917390231 J 705000225 J 919958145 J

lname

fname NORMAN ALICE SARA BARRETT LLOYD LOREN PHILIP HELEN BLAND BEULAH ANDREW ERIK FREEDA BETTY HUBERT RITA MILTON SHIRLEY ASA WALTER EDWARD DOROTHY MAMIE MARTA BENJAMIN ROBERT ROSA ROGER RONALD RENOIT SYLVESTER WILLIAM TERESA

dob 1943 1922 1923 1926 1944 1933 1948 1926 1938 1943 1938 1974 1927 1933 1946 1944 1968 1942 1934 1942 1930 1929 1921 1953 1942 1943 1939 1965 1936 1950 1969 1949 1956

date_registered 1998-07-07 1943-08-03 1995-10-05 1958-06-04 1999-09-24 1978-09-16 2008-09-30 1964-09-25 1960-10-08 1997-04-08 1973-01-04 1999-11-05 2016-01-08 1996-08-12 1994-10-02 2001-02-02 2003-10-06 2008-09-29 1986-03-25 1988-09-26 1970-10-02 1960-09-21 1967-10-06 2016-03-31 2000-10-10 1981-10-01 1973-11-06 2016-10-03 2018-03-07 2001-11-15 1996-01-25 1995-09-11 2004-10-04

ssdi_dod
2020-01-24 2020-01-13 2019-12-24 2019-12-21 2019-12-12 2019-12-09 2019-12-08 2019-12-03 2019-12-03 2019-12-02 2019-11-15 2019-11-10 2019-11-07 2019-11-07 2019-10-27 2019-10-25 2019-10-25 2019-10-22 2019-10-22 2019-10-09 2019-10-08 2019-09-28 2019-09-27 2019-09-23 2019-09-15 2019-09-13 2019-09-10 2019-09-06 2019-09-03 2019-09-01 2019-08-31 2019-08-28

obit_dod 2019-08-24
2019-12-09 2019-12-08 2019-12-03 2019-12-03 2019-12-02 2019-11-15 2019-11-10 2019-11-07 2019-11-07 2019-10-27 2019-10-25 2019-10-22 2019-10-22 2019-10-22 2019-10-09
2019-09-28
2019-09-23 2019-09-15 2019-09-13
2019-09-06 2019-09-03 2019-09-01 2019-08-31 2019-08-28

Exhibit B, Page 157

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 158 of 352 Pageid#: 1061

voter_id 319724061 J 604027870 J 649007777 J 706002624 J 919434599 J 611019416 J 123010286 J 920191208 J 920237955 J 409023219 J 121010312 J 169798061 J 918562860 J 806018847 J 739088803 J 919150143 J 502009088 J 917747729 J 917790986 J 919361621 J 201004629 J 608006876 J 919608835 J 126016084 J 124156456 J 963569521 J 919935024 J
63231391 J 920069828 J 207007566 J 808008955 J 702017112 J
25000138 J

lname

fname HELEN CHRISTY BARBARA JACKLIN CLAYTON WILLIS KEALSY LONNIE STEVE ALVIN PATRICIA EDWARD SHERWOOD ANNIE SHERRY BARBARA JACK JOE HAWAII EDWARD EDGEBURT CHRISTINE SUZANNE HAZELTINE DAVID ESSIE GEORGE PAMELA DONALD BERNIE CHARLES SANDRA RICHARD

dob 1939 1967 1924 1926 1942 1926 1933 1947 1949 1950 1952 1935 1951 1942 1947 1945 1929 1936 1928 1929 1951 1941 1937 1952 1978 1922 1954 1959 1946 1933 1939 1939 1916

date_registered 2008-10-06 1985-05-09 2007-09-18 1975-09-24 2002-11-19 2002-11-06 1968-10-03 2005-10-11 2006-01-09 1980-09-27 1992-03-14 2008-03-10 1999-08-04 1972-10-07 2016-04-25 2001-07-23 1954-04-28 1996-09-27 1996-10-07 2002-07-22 1980-07-28 1968-09-10 2003-09-29 1972-03-29 2014-04-14 2008-10-06 2004-09-29 2018-01-24 2005-03-17 1966-09-26 1968-02-27 1967-10-07 2003-08-28

ssdi_dod 2019-08-27 2019-08-20 2019-08-11 2019-08-10 2019-08-08 2019-08-07 2019-08-04 2019-06-13 2019-06-08 2019-05-25 2019-05-21 2019-04-14 2019-04-03 2019-03-28 2019-03-16 2019-02-09 2018-12-31 2018-12-30 2018-12-28 2018-12-28 2018-12-17 2018-12-13 2018-12-10 2018-10-30 2018-09-11 2018-08-30 2018-07-17 2018-06-29 2018-05-12 2018-05-11 2018-02-21 2018-02-09 2018-01-05

obit_dod
2019-08-20
2019-08-10 2019-08-08 2019-08-07 2019-08-04 2019-06-13 2019-06-08 2019-05-25
2019-04-03 2019-03-28
2019-02-09 2018-12-31 2018-12-30 2018-12-28
2018-12-13 2018-12-10 2018-10-30
2018-07-17 2018-06-29
2018-05-11
2018-02-09 2018-01-05

Exhibit B, Page 158

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 159 of 352 Pageid#: 1062

voter_id 918245272 J 903018549 J 413000735 J 707023983 J 723924888 J 223014512 J 506006381 J 103005914 J 203002439 J 810000486 J 305022671 J 604007203 J 919035141 J 549642297 J 107006136 J 919660691 J 919509322 J 919349590 J 305029459 J 908011102 J 501006971 J 423108048 J
25006427 J 89278142 J 707000318 J 601001693 J 908017113 J 918196526 J 805008955 J 918171411 J 102015550 J 32426037 J 506016748 J

lname

fname PATRICIA SENORA DAVID THOMAS SUSAN PINA LURA BRENDA CLAYTON WILLIAM EDWARD CONNIE JAMES LOIS DOROTHY LISA RONNELL THOMAS BARBARA JIMMIE RUTH JAMES ARTHUR LOTTIE ALICE RUTH RONALD CARL BARBARA GLENN KATHLEEN LARRY ROBERT

dob 1945 1930 1945 1954 1949 1927 1925 1946 1929 1934 1937 1934 1948 1945 1930 1968 1982 1918 1935 1924 1933 1930 1940 1923 1947 1930 1945 1928 1935 1939 1946 1947 1941

date_registered 1998-04-21 1969-09-10 1988-10-08 1996-09-28 2007-02-06 1979-08-24 1959-05-02 1979-06-18 1966-10-05 2005-11-09 1988-10-08 2003-04-28 2001-02-06 2008-10-06 1984-09-13 2009-05-07 2003-04-12 2002-06-25 1984-03-07 1954-11-20 1963-04-16 2008-03-10 1976-03-25 2008-06-09 1983-07-28 1987-09-11 1978-09-18 1998-02-17 1987-10-03 1997-12-22 1989-05-06 2016-06-16 1964-09-08

ssdi_dod 2017-12-11 2017-11-30 2017-08-16 2017-08-14 2017-07-04 2017-06-24 2017-04-13 2017-03-16 2017-01-31 2016-12-27 2016-11-20 2016-11-12 2016-10-20 2016-10-01 2016-09-05 2015-09-26 2015-06-02 2015-03-30 2015-03-30 2014-10-06 2014-09-25 2014-05-09 2011-12-12 2011-01-03

obit_dod 2017-12-12 2017-11-30 2017-08-16 2017-08-14
2017-06-24
2016-03-16 2017-01-31
2016-11-20 2016-11-12
2016-10-01 2016-09-05 2015-09-26 2015-06-02 2015-03-30
2014-09-25
2011-12-12 2011-01-03 2019-10-28 2019-10-24 2019-10-05 2019-09-24 2019-09-19 2019-09-11 2019-08-30 2019-08-17 2019-08-11

Exhibit B, Page 159

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 160 of 352 Pageid#: 1063

voter_id 29000139 J
406017695 J 125005399 J 307011272 J 919152767 J 204012144 J 203007311 J 704027100 J 230010323 J 701003593 J 224013497 J 308002892 J 918478156 J 404027201 J 128000759 J 905002284 J 502024291 J 602004510 J 204015201 J 901005602 J 919350923 J 919253877 J
27005574 J 122007504 J
6402450 J 917391125 J 302019790 J 919238993 J 917490062 J 630859547 J 609019417 J 221003261 J 206006580 J

lname

fname SOROTA MERLIE GEORGE JEAN RUTH BLANCH EARNEST WILEY WIN JOHN THOMAS EDWARD FRANK WILLIAM MARIA MIKE CLIFFORD WALTER DONALD ALFRED IDA JOHN DOROTHY ELIJAH DAVID LOUISE HELEN ESSIE WILLIAM SHELBA JOHN JAMES LILLIAN

dob 1948 1940 1924 1925 1922 1936 1939 1933 1933 1946 1942 1921 1922 1925 1923 1934 1948 1929 1932 1945 1936 1938 1942 1943 1948 1922 1931 1938 1947 1938 1938 1927 1927

date_registered 2003-04-01 2005-08-04 1964-10-03 1976-04-15 2001-08-01 1981-03-31 1983-10-04 1989-09-30 1988-10-08 1975-08-01 1990-10-06 1963-10-05 1999-04-14 1958-04-25 1960-10-03 2000-09-28 1982-11-03 1981-10-02 1956-01-02 1976-09-17 2002-06-24 2001-12-31 1980-09-29 2004-02-17 2014-09-29 1996-01-23 1956-09-29 2001-12-03 2016-09-07 2012-09-28 1962-09-29 1948-08-09 1951-06-12

ssdi_dod
2019-11-06 2019-09-06 2019-06-20 2019-09-24 2020-01-23 2020-01-13 2020-01-08 2020-01-02 2019-12-15 2019-12-10 2019-12-09 2019-12-07 2019-12-06 2019-12-04 2019-12-01 2019-12-01 2019-11-28 2019-11-26 2019-11-26 2019-11-20 2019-11-20

obit_dod 2019-08-03 2019-02-20 2018-12-23 2018-12-10 2018-11-22 2018-03-10 2018-02-08 2018-02-04 2017-01-27 2016-07-28 2015-04-06 2014-10-06 2019-11-06 2019-09-06
2019-12-10 2019-12-09
2019-12-06 2019-12-04 2019-12-01
2019-11-28 2019-11-26 2019-11-26 2019-11-20 2019-11-20

Exhibit B, Page 160

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 161 of 352 Pageid#: 1064

voter_id 806005399 J 907004757 J 607013378 J 496914905 J 917355454 J 208026354 J 205009216 J 919087758 J 504024975 J 918023174 J 302039176 J 201025915 J 918093116 J
83098783 J 123004281 J 906013048 J
25009943 J 241042742 J 917683129 J 919885360 J 308029956 J 204005711 J 125004849 J 919918728 J 763397478 J 918887035 J 107003949 J 917710405 J
22012819 J 503026099 J 918380150 J 106021621 J 918164614 J

lname

fname RONALD DENISE ALLEN WILLIAM MINOR PHILLIP WILBERT DEBORAH ETHEL NELSON DOROTHY ELIZABETH GLENN LENWOOD KENNETH JOAN CHARLOTTE RAYMOND VIRGINIA WILLIAM BRADY WILLIAM LOUISE STEPHEN THOMASINA LOIS LESLIE KERMIT LEVY HILDA LOUISE HARRIETT CARL

dob 1949 1957 1935 1943 1939 1958 1942 1958 1926 1942 1938 1941 1932 1943 1951 1926 1926 1945 1941 1944 1937 1928 1934 1956 1927 1968 1924 1936 1949 1930 1938 1922 1937

date_registered 1972-03-10 2003-09-16 1984-07-20 2007-10-02 1995-10-06 2005-10-06 1963-10-04 2001-11-07 1992-11-04 2001-08-14 1972-05-11 1968-10-05 1997-09-08 2016-11-09 1979-07-27 1958-02-27 1983-07-14 2015-02-19 1996-09-22 2004-09-03 2004-08-12 1988-11-10 1956-10-05 2004-09-27 2012-12-12 2000-09-15 1975-11-17 1996-09-21 1973-05-10 1963-04-02 1998-11-13 1997-05-09 1997-12-15

ssdi_dod 2019-11-20 2019-11-13 2019-11-08 2019-11-08 2019-11-02 2019-10-16 2019-09-29 2019-09-29 2019-09-28 2019-09-25 2019-09-16 2019-09-13 2019-09-11 2019-09-03 2019-08-28 2019-08-26 2019-08-25 2019-08-14 2019-07-26 2019-07-25 2019-06-21 2019-05-29 2019-05-17 2019-04-08 2019-03-28 2019-03-24 2019-01-20 2018-12-27 2018-12-09 2018-12-05 2018-11-06 2018-10-12 2018-09-09

obit_dod 2019-11-20 2019-11-13 2019-11-08
2019-11-02 2019-10-16 2019-09-29
2019-09-28 2019-09-25 2019-09-16
2019-09-11 2019-09-03 2019-08-28
2019-08-25 2019-08-14
2019-07-25 2019-06-21 2019-05-29 2019-05-17
2019-03-24
2018-12-09
2018-11-06 2018-10-12 2018-09-09

Exhibit B, Page 161

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 162 of 352 Pageid#: 1065

voter_id 23369615 J
103025592 J 544029752 J 918496393 J 302527999 J 609008347 J 920367484 J 919854202 J
21018768 J 109022184 J 920155081 J 205014300 J 602000317 J 105005915 J 918146008 J 802005400 J 917048404 J 920111931 J 918564028 J 176444390 J 903014811 J 132992135 J 304038584 J 919741725 J 206012788 J 124009235 J 938431863 J 801008187 J 403030002 J 708004665 J 607013488 J 910002898 J 248555766 J

lname

fname GLORETTA GENOVA MICHAEL SHELVA DEMETRIUS WILLARD DOUGLAS JUNE SHERRY JANE WILLIE WELDON BRANTLEY BARBARA VIRGINIA SYLVIA HENRY MARILYN KATHRYN FRANKLIN LUCILLE PAULINE SYDNEY LONNIE MARGIE ESSIE CONRAD VELMA JOYCE PAUL DOROTHY A JOSEPHINE MICHAEL

dob 1952 1933 1939 1938 1954 1938 1944 1930 1949 1934 1957 1949 1938 1931 1930 1947 1936 1931 1945 1943 1928 1947 1949 1945 1937 1932 1943 1924 1928 1948 1933 1928 1956

date_registered 2007-11-16 1964-09-29 2013-11-18 1999-05-04 2007-11-28 1959-06-11 2006-09-29 2004-08-26 1993-03-09 2004-09-09 2005-08-29 1979-06-12 1998-05-07 1997-03-24 1997-11-18 1988-05-19 1993-10-03 2005-06-16 1999-08-17 2012-08-01 1962-02-10 2007-02-16 1993-02-20 2004-04-29 1964-09-19 1984-03-31 2016-07-07 1966-04-18 1956-03-01 1990-04-06 1963-03-29 1983-08-12 2011-08-25

ssdi_dod 2018-05-04 2018-03-27 2018-02-16 2018-02-02 2018-02-01 2018-01-26 2018-01-23 2017-12-18 2017-10-27 2017-09-12 2017-08-26 2017-07-07 2016-11-28 2016-10-16 2016-01-30 2015-06-08 2014-11-02 2014-09-23 2014-01-04 2009-07-14
2019-06-22

obit_dod
2018-03-27
2018-02-01 2018-01-26 2018-01-23 2017-12-18
2017-09-12 2017-08-26
2016-11-28 2016-10-16
2014-09-23
2019-10-13 2019-09-18 2019-09-10 2019-09-06 2019-08-27 2019-07-30 2019-01-28 2018-12-27 2018-01-16 2017-08-02 2015-04-13 2015-01-26 2019-06-22

Exhibit B, Page 162

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 163 of 352 Pageid#: 1066

voter_id 917367104 J 282312141 J 300278507 J 301045717 J 918837915 J 803006054 J
24018769 J 203015509 J 203006836 J 902016886 J 917601042 J 285817626 J 233010021 J 406032029 J 917576554 J 917878347 J 917958452 J 303027165 J 311039653 J 492602249 J 127359282 J 918477737 J 550023949 J 171675956 J 917957535 J
26007297 J 227003154 J 601033377 J 228010326 J 902019232 J 224005143 J 917851104 J 301004884 J

lname

fname ROSETTA JOHNNIE MARY HARRY DOROTHY ALICE BETTY RUTH EVERETT MAX BARBARA BRANDIE ANGELITA JOHN CYNTHIA ROBERT ROBERT HEDI ANDREW THOMAS RONALD DOYLE LINDA ESTHER WILLIE VIRGINIA MARY HELEN ANGUS MARY JAMES LOUIS JOSEPHINE

dob 1950 1953 1951 1934 1930 1927 1925 1934 1925 1938 1944 1987 1948 1945 1967 1946 1943 1941 1944 1940 1947 1936 1942 1935 1947 1948 1942 1915 1933 1933 1938 1933 1931

date_registered 1995-10-10 2012-01-12 2019-08-19 1984-04-12 2000-08-02 1955-12-09 1956-10-04 1968-10-05 1956-05-19 2003-08-12 1996-08-16 2008-10-06 1991-07-04 1989-04-06 1996-08-02 1997-01-22 1997-03-25 1996-12-31 1991-10-05 2008-04-28 2008-10-06 1999-04-13 2011-02-03 2018-07-05 1997-03-26 1982-03-02 1966-01-05 1952-12-16 1999-11-03 1998-11-12 1999-11-03 1996-12-19 1969-10-04

ssdi_dod 2019-11-16 2019-11-08 2019-10-22 2019-06-16 2019-03-05 2018-12-29 1987-02-01
2019-11-02 2019-12-19 2018-12-31 2018-05-27
2018-07-30 2019-03-25 2018-06-18 2017-06-28
2020-01-08 2020-01-06 2020-01-03 2019-09-24 2018-12-28 2018-02-24 2016-11-08
2020-01-12 2014-03-07

obit_dod 2019-11-16 2019-11-08
2019-06-16
2018-12-29
2019-10-12 2018-12-30 2017-07-12 2014-11-27 2019-11-02
2018-12-31 2018-05-27 2018-01-14 2019-06-22
2019-03-25 2018-06-18
2019-07-30 2016-11-29
2019-09-24 2018-12-28 2018-02-24 2016-11-08 2019-09-08

Exhibit B, Page 163

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 164 of 352 Pageid#: 1067

voter_id 356559924 J 604024268 J 407445749 J 920154661 J 920149663 J 906000418 J 920417630 J 917632596 J 306006570 J 202000987 J 917312348 J 208001087 J 204002218 J 361035614 J 203001178 J 206000991 J 918792714 K 918203261 K 604029462 K 607013379 K 306035995 K 309042901 K 918489159 K 221014518 K 567748522 K 310021720 K 570710295 K 919222170 K 901003809 K 918213513 K 917903629 K 308011549 K 223008496 K

lname

fname PAUL RAEBURN ASUNCION DONALD CONSTANCE HERMAN JOE CARLOS ANTHONY BETTY BETTY TOMMY LACY FOEY EARL JEAN DIANA WILLIAM CAROL HATTIE M GEOFFREY JERRI RAFAL VICKI JOSEPHINE ANTHONY MIKE EDWARD RAY LORETTA DAVID MICHELLE BETTY

dob 1949 1932 1943 1939 1940 1937 1956 1951 1931 1937 1939 1940 1943 1943 1931 1947 1950 1937 1943 1926 1948 1940 1980 1943 1932 1941 1949 1929 1949 1920 1944 1948 1925

date_registered 2009-07-31 1955-05-18 2008-06-12 2005-08-26 2005-08-18 1983-10-07 2006-12-18 1996-09-05 1979-10-06 1959-10-03 1995-08-22 1961-10-01 1975-08-29 2007-08-08 1957-10-03 1971-05-28 2000-05-31 2000-08-16 1972-03-30 1972-08-16 1976-03-18 2001-01-29 2006-06-14 1998-11-04 2007-08-06 2002-05-17 2016-02-08 2001-11-08 2004-04-09 1998-03-12 1997-02-21 1980-09-13 1972-10-04

ssdi_dod
2019-10-15 2019-06-24 2017-12-12
2019-09-01 2019-07-29 2018-12-06 2019-02-17 2019-11-02 2019-04-12 2018-05-06 2018-05-05 2016-09-29 2016-08-29 2015-08-28 2018-12-30 2018-06-06
2019-11-06 2017-02-26
2019-01-04 2019-09-19 2019-08-02 2018-12-11 2019-10-10
2019-09-22
2019-09-08

obit_dod 2017-01-01 2019-10-15 2019-06-24 2017-12-12 2018-05-26
2019-07-29 2018-12-06
2019-04-12 2018-05-06 2018-05-05 2016-09-29 2016-08-29 2015-08-28 2018-12-30 2018-06-06 2019-09-21 2019-07-13 2017-06-01 2019-11-13
2018-07-05 2019-01-04 2019-09-19 2019-08-02 2018-12-11 2019-10-10 2014-12-07
2019-07-23 2019-09-08

Exhibit B, Page 164

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 165 of 352 Pageid#: 1068

voter_id 917789581 K 502020383 K 308039180 K
14768875 K 221023206 K 902017741 K 920039564 K 920404336 K 919175558 K 240559198 K 920281522 K
22006688 K 123012272 K 705008202 K 121016577 K 702011986 K 510004210 K 307023034 K 228007617 K
48811520 K 709004530 K 905012680 K 862121897 K 917489895 K 123040681 K 919971808 K 917621966 K 207002931 K 307033238 K 919170381 K 908006852 K 709018570 K 246995889 K

lname

fname MUNAWAR NANCY EDWARD FLORENCE TYRONE SALLIE MICHAEL BARBARA RONALD KULWANT RAJINDER ANNE EMMA WILLIAM ALETHA SARAH HOWARD DOROTHY BILLIE DAKOTAH DOROTHY LELIA ROBERT JOHN ANITA BOBBY NELLIE OTIS KWENTIN JOHN ZELMA MONROE JOHN

dob 1950 1939 1923 1924 1972 1961 1945 1943 1938 1935 1932 1952 1929 1937 1939 1923 1946 1922 1931 1990 1929 1934 1934 1944 1944 1946 1946 1933 1946 1932 1926 1966 1942

date_registered 2000-03-30 2016-08-01 1976-09-29 2012-10-15 2007-05-01 1982-03-22 2004-12-30 2006-11-21 2005-11-22 2017-01-12 2006-04-11 1971-08-14 1952-07-26 1971-12-20 1980-10-04 1983-09-27 1967-12-11 1968-04-08 1986-09-12 2008-03-06 1964-10-03 1968-05-09 2013-11-21 2009-02-05 2012-09-20 2004-10-04 1996-08-28 1956-09-09 1981-09-30 2001-08-28 1984-03-22 1996-07-31 2018-10-15

ssdi_dod 2018-12-06 2018-05-27
2018-12-08 2018-10-30 2019-04-20
2019-11-20
2019-03-27 2018-10-29 2018-12-03 2019-11-13 2019-10-15 2019-02-25 2016-10-14 2019-10-27 2014-10-07 2019-08-30 2013-10-16
2019-12-25
2019-11-02 2019-12-15 2019-11-08
2020-01-28 2019-11-13 2019-10-03 2019-09-14 2018-12-24

obit_dod
2017-11-30 2018-12-08 2018-10-30 2019-04-20 2018-05-27
2019-04-12
2018-12-03 2019-11-13
2019-02-25 2016-10-14 2019-10-27
2019-08-29 2013-10-16 2019-10-28 2019-12-25 2014-10-21 2019-11-02 2019-12-15 2019-11-08 2019-10-06 2019-03-31
2019-11-13 2019-10-03 2019-09-14 2018-12-24

Exhibit B, Page 165

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 166 of 352 Pageid#: 1069

voter_id 212019412 K 253162288 K 409011447 K 917920208 K 608028352 K 254221161 K 918598448 K 301006575 K 302035648 K 602019926 K 981699543 K 917365696 K 502004920 K 705010965 K 708021793 K 104017315 K 708453004 K 308036978 K 917816932 K 101032635 K 919355498 K 919859464 K 917674798 K 221007682 K 309005740 K 702012671 K 918698086 K 312051625 K 918731908 K 308006576 K 506010465 K
22020050 K 25020546 K

lname

fname JOHN GLEN ROXANNA CECIL RITA DONALD MARY JOHN ERNESTINE GERALDINE ERVIN GAIL SHARON MARGIE DOROTHY ALTHEA PAMELA JOYCE LEE THOMAS KARON ROBERT VALLIE FLORA ROBERT SARAH MARTHA EDMUND JOHN EDWARD MYRTLE PAMELA JOYCE

dob 1938 1943 1954 1941 1939 1953 1939 1923 1943 1935 1947 1947 1931 1935 1925 1920 1946 1922 1948 1933 1944 1937 1933 1946 1939 1947 1930 1969 1949 1933 1923 1948 1944

date_registered 1988-08-23 2007-02-07 1973-10-06 1997-03-05 1962-10-06 2015-06-25 1999-09-28 1964-10-02 1984-09-15 1977-09-27 2008-08-21 1995-10-10 1992-10-01 1992-08-18 1946-10-02 1968-10-01 2008-10-01 1972-08-16 1996-11-06 2004-09-15 2002-06-24 2004-08-24 1996-09-20 2016-09-07 1992-03-02 2001-09-26 2001-11-09 2003-05-12 2000-03-21 1995-10-10 1944-05-25 1985-03-21 1984-09-24

ssdi_dod
2019-08-19 2020-01-10 2020-01-14 2018-08-09 2018-01-22
2019-08-20 2019-08-12 2019-12-24 2019-11-12 2019-04-21 2017-11-27
2020-01-21 2019-08-08
2015-11-14
2014-10-27
2019-11-12 2019-10-04 2019-08-03 2019-06-18 2019-03-18 2018-12-17 2018-12-08 2018-08-03 2015-05-02

obit_dod 2016-10-22 2019-09-18 2019-08-19
2018-08-09
2017-12-23 2019-08-20 2019-08-12 2019-12-24 2019-11-12
2019-09-29
2018-01-06 2015-11-14 2015-12-14
2018-12-10
2019-10-04 2019-08-02
2019-03-18 2018-12-17 2018-12-08 2018-08-03 2015-05-02 2019-10-14 2019-08-21

Exhibit B, Page 166

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 167 of 352 Pageid#: 1070

voter_id 603014872 K
2761766 K 204010707 K 701027626 K 917138360 K 919528653 K 917236432 K
7003722 K 105010548 K 704024556 K 708015000 K 917395936 K 919723914 K 223014522 K 803020020 K 205016605 K 917236385 K 901022152 K 917189734 K 918834652 K 309043325 K 917132909 K 108022880 K 308004119 K 363970257 K 906002291 K 608029020 K 920183487 K 606028106 K 407006008 K 682169002 K 147740379 K 501024603 K

lname

fname BONNIE JACKLYN KATHERINE JOSEPH MARY EDITH LINDA PEGGY JOSEPH HELEN DONALD EDITH ANNQUINETTE MARGUERITE MARY DORIS MAUREEN JEANNE STEPHEN THOMAS ROBERT ALFRED EDITH EARLENE PAUL FRED VIRGINIA PAUL CLARENCE BETTY PHILLIP JENNY ROBERT

dob 1940 1950 1924 1928 1924 1926 1947 1934 1926 1924 1935 1934 1970 1924 1933 1933 1933 1924 1948 1952 1944 1932 1934 1945 1944 1932 1932 1938 1951 1945 1949 1939 1930

date_registered 1963-05-29 2010-07-26 1999-07-28 1992-10-03 1997-06-13 2003-06-02 1995-01-26 1991-10-05 1984-09-08 1954-03-25 1967-09-14 1996-02-21 2004-03-08 1983-10-04 1963-12-06 1960-01-26 1995-01-23 1959-08-18 1996-03-11 2004-08-31 1981-06-17 1994-06-13 1955-12-31 2004-10-04 2019-05-11 1964-10-03 1963-10-01 2005-10-05 1975-09-30 1969-09-15 2015-07-02 2012-10-07 1987-06-24

ssdi_dod 2019-12-13 2014-11-14 2014-10-21
2019-12-22 2015-04-21
2020-01-13 2019-12-07 2019-08-08 2019-06-13 2019-10-23 2018-12-17 2017-05-13 2015-03-29 2017-04-01 2019-08-24
2017-04-21 2019-10-14
2019-11-10 2018-12-26 2019-10-20 2019-09-26 2019-09-18 2018-01-08 2018-12-14 2019-11-20
2017-12-20

obit_dod
2018-12-20
2015-04-21 2019-08-02
2019-12-07 2019-08-08
2019-10-23 2018-12-17
2015-03-29
2019-08-24 2019-09-10
2017-01-23 2019-11-10 2018-12-26 2019-10-20 2019-09-26
2018-01-08
2019-09-26 2017-12-20 2019-08-13 2018-04-09

Exhibit B, Page 167

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 168 of 352 Pageid#: 1071

voter_id 401019159 K 408020449 K 303044696 K 202016951 K 303047765 K 804001308 K 801001090 K 917657158 K 125002022 K 803007745 K 704002545 K 919681396 K 133587985 K 918279351 K 311045391 K 917684057 K 917526257 K
6786865 K 919514477 K 920337831 K 106017963 K 308005103 K 506002242 K 919154112 K 804015144 K 505027398 K 807011894 K 393342909 K 229022089 K 718015654 K 713013525 K 603028220 K 919489271 K

lname

fname ERNEST JOAN JULE CLARENCE ROBERT RICHARD LINDA WILLIAM CONSTANCE WILLIS ALMA LABIB AHMED SHAIR MOHAMMED AHMED MUSHARRAF SAMUEL BAHRAM MAHAJABEEN VELMA JOAN HAZEL CAROLYN HAZEL FRANKLIN THOMAS FRANKLIN JIMMY TROY PAUL FREIDA PRISCILLA

dob 1927 1930 1953 1935 1936 1943 1946 1941 1915 1927 1941 1962 1940 1932 1951 1943 1931 1936 1947 1944 1930 1928 1945 1946 1929 1928 1963 1941 1934 1934 1948 1947 1943

date_registered 1984-03-15 1972-09-22 1997-09-12 1972-10-07 1995-07-31 1988-02-06 1996-08-20 1996-09-16 2003-07-21 1964-10-03 1976-10-01 2004-02-11 2008-06-18 1998-06-10 1996-10-04 2000-10-07 1996-06-19 2018-07-10 2003-05-07 2006-08-10 1968-06-04 1967-06-09 1989-10-06 2001-08-01 1996-11-12 1964-10-01 1987-10-02 2016-10-12 1978-10-07 1963-09-26 1992-09-30 1983-04-21 2003-03-25

ssdi_dod 2019-08-11 2018-02-23 2019-03-13 2019-08-23 2020-01-15 2020-01-10 2017-12-19
2018-12-17 2019-12-21 2019-09-30 2019-10-17 2019-07-01
2018-05-26 2019-06-30 2019-08-24 2020-01-29 2018-10-15 2018-03-30
2019-11-10 2019-12-25 2019-12-06 2015-11-30 2018-12-08 2019-10-30 2019-07-14 2018-03-24 2019-06-12 2018-06-17 2018-04-06 2019-12-17

obit_dod
2018-02-23
2017-12-19 2018-09-14 2018-12-17 2019-12-21 2019-09-30 2019-10-17
2015-07-27
2019-10-17 2019-11-10 2019-12-25 2019-12-06 2015-11-30 2018-12-08 2019-10-30 2019-07-14 2019-07-01
2018-06-17 2018-04-06

Exhibit B, Page 168

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 169 of 352 Pageid#: 1072

voter_id 302030731 K 241206874 K 308043327 K 917186474 K 104002853 K 310038817 K 920385034 K
8523750 K 304004122 K 248593825 K 308001189 K 105525606 K 306035652 K 308006000 K 109003272 K 604004122 K
32615645 K 904019451 K 701026871 K 918339463 K 310002898 K 704354374 K 121015899 K 108027403 K 917594304 K 501020386 K 919068807 K 907023859 K 917042767 K 121009242 K 407019159 K 702016578 K 206010882 K

lname

fname JOAN ELEANOR SHINOK JE MARY RANDY QUEENIE SIN ILHO JONATHAN MIN SOON CHUNGKOOK BYUNG VICTORIA SHERRY ZELDA ISABELLE WILLIAM SANDRA MELINDA SHALONDA DELORIS EARL BETTY THELMA ELAINE WILLIAM LILA CARRIE MARGARET CARL JOHN

dob 1937 1931 1921 1934 1928 1931 1933 1953 1945 1989 1935 1922 1935 1936 1921 1944 1931 1930 1958 1939 1947 1975 1940 1931 1937 1922 1926 1949 1941 1927 1927 1942 1960

date_registered 1976-09-23 2007-10-05 1992-05-08 1994-09-29 1983-08-24 1992-03-18 2006-10-10 2016-09-23 1983-10-05 2008-06-27 2006-06-19 2012-03-13 1992-05-07 1990-06-30 1974-05-06 1984-02-29 2018-05-09 1955-05-12 1988-10-05 1998-09-16 1991-09-14 2008-09-23 1964-09-01 1976-09-21 1996-08-13 1956-09-28 2001-03-27 1991-07-22 1993-10-02 1960-01-27 1985-09-26 1971-10-01 1983-06-15

ssdi_dod 2019-11-25
2019-12-30 2019-11-28 2019-11-10 2019-11-05 2019-11-05 2019-10-28 2019-04-11 2018-12-04 2018-12-01 2018-04-08 2014-11-06
2019-08-19 2019-12-15
2019-08-19 2019-09-22
2019-06-02 2020-01-16 2019-12-23 2019-12-23 2019-11-25 2019-11-23 2019-11-05 2019-09-04 2019-08-22 2019-08-19 2019-07-06 2019-05-14

obit_dod 2019-11-25 2015-04-18
2019-11-28
2019-10-28
2018-12-04
2014-11-06 2019-09-26 2019-08-31 2019-08-19 2019-12-15 2014-11-14 2019-08-19 2019-09-22 2017-07-14 2019-06-01
2019-12-23 2019-12-23
2019-11-05 2019-09-04
2019-07-06 2019-05-14

Exhibit B, Page 169

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 170 of 352 Pageid#: 1073

voter_id 605033026 K 917783111 K 802003113 K 919172347 K 920353541 K 501015004 K 919519765 K 206023375 K 917179585 K 317724393 K 402011834 K 701015002 K 512009310 K 917029072 K 304018320 K 919730617 K 225022521 K 919949497 K 508026195 K 917202563 K 184256618 K 102023125 K 917448120 K 918716357 K 405004367 K 801012315 K 908006270 K 919535853 K 606027607 K 702015657 K 708014132 K 709015232 K 917326081 K

lname

fname TINNILE JEROME JAMES JOSEPH JANICE DEWEY RONDA ROBERT ELEANOR WILLIAM AUDREY JAMES MARCELLA JOHN CHARLES LULU JOHN JOSEPH ADDIE FRANCES EDGAR GENEVIEVE JANICE KLAY DORIS SHIRLEY HELEN KERRY-BETH DOROTHY VERNARD WILMA BILLY TOBY

dob 1935 1958 1937 1960 1944 1948 1929 1930 1941 1954 1940 1953 1940 1943 1927 1939 1927 1938 1927 1941 1937 1926 1933 1981 1916 1935 1931 1968 1932 1934 1948 1932 1937

date_registered 1999-11-09 1996-10-07 1974-04-05 2004-06-09 2006-09-08 1998-05-20 2003-05-12 1987-10-02 2000-05-03 2013-10-02 1979-05-22 2006-06-29 1991-09-12 1994-09-15 1974-05-29 2004-04-05 1980-10-02 2004-10-04 1963-06-06 1994-10-11 2008-09-08 1992-08-17 1996-04-03 2000-02-10 1955-01-01 1967-09-28 1976-10-02 2003-06-12 1955-08-11 1955-10-08 1981-10-01 1979-10-06 1995-09-15

ssdi_dod 2018-12-17 2018-07-23 2018-01-06 2017-11-25
2019-08-22 2020-01-21 2019-11-26
2019-04-03 2020-01-04 2019-06-28 2018-10-16 2020-01-10 2018-12-04 2019-12-18 2019-03-13 2019-12-23 2019-12-10 2014-10-10
2019-08-06 2019-06-19 2019-01-31 2017-03-05
2019-12-24 2018-10-01 2020-01-29 2019-08-04 2019-05-08 2018-04-03 2018-02-22

obit_dod 2018-12-17 2018-07-23
2018-08-12 2019-08-22
2019-11-26 2019-08-01
2019-06-28 2018-10-16
2018-12-04 2019-12-18
2019-12-10
2019-09-10 2019-08-06 2019-07-19 2019-01-31 2017-03-05 2018-12-19 2019-12-24 2018-10-01
2019-08-04 2019-05-08 2018-04-03 2018-02-22

Exhibit B, Page 170

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 171 of 352 Pageid#: 1074

voter_id 701010472 K 128019499 K 919380497 K 708018877 K
90727621 K 26672349 K 917317940 K 116023020 K 608032178 K 25009753 K 919257603 K 917289688 K 209000037 K 917528639 K 911021904 K 910021904 K 917101396 K 919693106 K 201015210 K 214015731 K 917798953 K 918172055 K 920230930 K 919191190 K 105010553 K 202423468 K 101022883 K 919782352 K 202020832 K 917629485 K 809018955 K 365756481 K 402023464 K

lname

fname TWILA ESTHER ARTHUR GERALD JOHN DONALD DORINE MYRTLE MARY MARY HAROLD WALTER EDNA VICTORIA WILLIAM BRENDA PHILIP RUBY SALLIE STEPHANIE MARVIN STANLEY GREGORY STEPHEN ROBERT SANDRA MARIE FRITZ FAMBRO NANCY SARAH MARK THOMAS

dob 1927 1947 1937 1945 1943 1930 1928 1942 1943 1929 1938 1940 1941 1937 1940 1942 1942 1929 1934 1930 1944 1931 1946 1961 1943 1942 1919 1927 1939 1932 1936 1956 1942

date_registered 1980-09-30 1980-10-03 2003-04-18 1984-09-26 2012-10-15 2015-04-29 1995-09-05 1992-09-14 2016-05-27 1981-10-03 2002-01-14 1995-05-24 1988-09-20 1998-09-14 1988-09-16 1988-09-16 1997-11-05 2004-02-24 1999-07-28 1992-09-15 1999-06-15 1998-01-07 2005-12-28 2001-09-24 2000-12-05 2008-09-30 1963-10-05 2004-06-14 1987-05-29 1996-09-03 1982-09-16 2010-09-28 1996-09-25

ssdi_dod 2017-06-16
2019-08-21 2020-01-20 2017-11-06
2020-01-21
2019-09-19 2018-05-21 2018-04-25 2019-10-29 2020-01-07 2019-12-28
2019-11-13 2019-12-27 2017-08-20 2018-11-12 2019-09-05 2019-10-01 2016-08-16
2019-08-28 2017-01-27 2019-11-15 2019-12-18 2019-10-11 2019-10-09 2019-09-17 2018-12-18

obit_dod 2017-06-16 2019-09-20 2019-10-27 2019-08-21 2017-12-06 2019-08-20 2019-10-15 2017-01-01 2019-09-19 2018-05-22
2013-12-17
2019-10-01 2019-09-05 2017-01-27
2019-10-09 2019-09-17 2018-12-18

Exhibit B, Page 171

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 172 of 352 Pageid#: 1075

voter_id 234021886 K 226002137 K 477772467 K 709004824 K 908007423 K 510028864 K 606010168 K 918984464 K 304022015 K 706015657 K 917850144 K 918121680 K 917938282 K 917012371 K 709014570 K 918968980 K 302034817 K 202941523 K 346090329 K 301033495 K 918380690 K 605012115 K 919297487 K 918748369 K 234010028 K 305043895 K 680507003 K 805008963 K 106011002 K 605008993 K 206012797 K 919265631 K 806006736 K

lname

fname BENAJMIN LOUISE GLORIA PATRICIA BEATRICE THOMAS JANET WILLIAM EMMA SAMUEL JAMES NANCY DOROTHY EVANGELINE MARIAN MARY CHRISTOPHER HAROLD LOIS SHERRY MARGUERITE LEE JOHN VIRGINIA FRANCES ROBERT JOSEPH BONNIE JOHN LORETTA A JEAN ETHEL THERON

dob 1936 1930 1934 1936 1916 1935 1930 1949 1936 1947 1931 1945 1938 1927 1914 1922 1948 1945 1933 1942 1919 1942 1946 1938 1940 1926 1934 1950 1940 1935 1936 1941 1935

date_registered 2005-10-11 1964-09-08 2012-12-04 1975-09-15 1968-04-24 1988-10-04 1960-09-24 2000-11-18 1984-05-09 1969-09-27 1996-12-17 1997-10-06 2001-08-08 1999-12-02 1992-08-21 2000-10-10 1984-10-06 2013-12-03 2011-09-02 1984-07-16 1998-11-13 1987-05-04 2002-03-28 2000-04-03 1992-10-03 2002-09-12 2017-03-29 1991-09-14 1968-03-18 1984-09-18 1987-02-20 2002-01-16 1964-10-03

ssdi_dod 2018-12-16 2017-10-18 2016-09-12
2019-07-10 2018-05-25
2019-08-15
2018-04-20 2019-10-03 2019-09-10 2019-12-25 2018-12-28 2019-12-03 2019-12-18 2019-11-13 2017-11-02 2019-08-01
2019-04-19 2019-08-13 2018-04-12 2018-12-02
2019-09-21 2018-10-30 2020-01-04 2019-12-30 2018-12-18 2019-09-03 2018-02-17

obit_dod 2018-12-16
2015-06-01 2019-07-10
2019-08-15 2019-08-15 2018-02-08
2019-12-25
2019-12-03 2019-12-18 2019-11-13 2017-11-02 2019-08-01 2019-05-01 2017-06-26 2019-04-19
2018-12-02 2019-10-07
2018-10-30
2019-09-03 2018-02-17

Exhibit B, Page 172

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 173 of 352 Pageid#: 1076

voter_id 109022382 K 213624409 K 705021972 K 607013229 K 305017998 K 102002861 K 907009617 K 220399577 K 904016683 K 808017643 K 301036013 K 305036736 K 307020900 K 913484974 K 917688134 K 484839710 K 918492353 K 314606491 K
21526586 K 10433698 K 919259248 K 920240993 K 138218525 K 804229143 K 918732868 K 151588640 K 544912788 K 408008960 K 302006592 K 209154020 K 380761206 K 606029733 K 103011560 K

lname

fname GENE LUCIA EUGENE TED PATRICK DIANA FREDERICK RONALD VIRGINIA PILAR COSSETTE ZHANNA MAXIM HILLARY CRAIG DONALD NORMAN ROBERT LORRAINE MICHAEL EARL JEAN MARTIN ROBERT RICHARD DEBORAH MARGARET KARTHIK LILLIAN EDWARD MARY RICHARD DOROTHY

dob 1929 1937 1934 1937 1948 1941 1948 1965 1926 1934 1933 1939 1934 1947 1947 1948 1940 1955 1933 1933 1937 1933 1932 1939 1927 1953 1934 1974 1927 1936 1932 1944 1926

date_registered 1991-02-26 2017-02-16 1982-09-24 2004-12-09 1981-10-03 1983-10-08 1989-09-23 2015-11-04 1954-03-19 1991-11-06 1968-09-26 1988-09-24 1988-01-23 2008-09-25 1997-01-29 2018-06-19 2003-11-05 2012-10-01 2010-11-19 2010-10-06 2002-01-16 2006-01-17 2016-01-19 2016-05-20 2000-03-14 2013-11-20 2007-07-12 2012-10-13 1972-07-25 2013-08-21 2017-09-06 1987-08-28 1960-10-04

ssdi_dod 2019-12-26 2020-01-09
2019-12-29 2018-03-29 2020-01-14
2019-08-07 2019-10-22
2019-09-02 2017-10-28 2019-12-24 2019-05-30
2020-01-15 2019-09-02 2017-09-05 2017-10-09 2018-11-01 2019-11-01 2019-09-05
2018-04-17 2019-10-11 2019-10-28 2018-02-20 2018-08-20 2019-11-30 2019-11-13 2018-12-08

obit_dod 2019-12-26
2019-05-13
2018-03-29
2019-09-10
2019-10-22 2019-03-14 2019-09-02 2017-10-28
2018-10-04
2019-09-02 2017-09-05 2017-10-09 2018-11-01 2019-11-01 2019-09-05 2018-09-21 2018-04-17 2019-10-11 2019-10-28 2018-02-20
2019-11-13
2019-10-16 2014-07-03

Exhibit B, Page 173

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 174 of 352 Pageid#: 1077

voter_id 303009097 K 917289866 K 306032096 K 607009810 K 413003602 K
1709369 K 408006199 K 919676565 K 224017914 K
16763710 K 919152843 K 202751055 K 301035064 K 919921293 K 704002373 K 503022741 K 920323625 K 232000116 K 178198910 K 810008191 K 407022877 K
5306846 K 403017415 K 759076602 K 199903266 K 605011472 L 917192933 L 920218396 L 917285001 L 802015147 L 917079040 L
67586341 L 128775876 L

lname

fname PHILIP JERRY DANIEL DANIEL ROBERT THEODORE PATRICIA KATHERINE CATHLEEN VIRENDER NARENDRA ALMA SEIJI SHIH HEINZ THANGAVELU MILDRED GRACE DENNIS JANIE IRVING WILLIAM PAUL GWENDOLYN THOMAS RAYMOND CHRISTOPHER MILTON RINA BARBARA JOSEPH JOSEPH JAMES

dob 1937 1945 1942 1933 1947 1939 1940 1935 1947 1941 1933 1929 1931 1949 1934 1940 1939 1929 1948 1936 1924 1921 1927 1951 1929 1938 1969 1943 1931 1932 1956 1940 1949

date_registered 1984-08-22 1995-05-24 1974-06-13 1997-07-24 1992-09-30 2016-03-07 1978-10-07 2004-02-11 1999-04-23 2014-07-09 2001-07-23 2008-10-06 1984-09-29 2004-09-28 1975-04-07 1989-09-06 2006-07-11 1992-09-30 2012-07-19 1992-09-29 1946-08-07 2012-04-16 1991-06-04 2008-09-17 2014-06-18 1984-10-06 1994-10-01 2005-11-28 1995-05-10 1973-09-25 1994-03-09 2016-04-12 2011-10-14

ssdi_dod 2019-08-01 2019-11-16 2019-08-27
2019-10-07 2018-11-24 2020-01-03 2020-01-03
2020-01-15 2018-11-11 2018-04-20
2015-10-04
2020-01-04 2017-11-18 2018-05-28 2014-02-21
2019-12-18 2016-01-17 2020-01-20
2019-06-09 2019-11-28 2019-12-18 2019-11-27 2014-08-11 2019-10-26 2018-12-24

obit_dod 2019-11-16 2019-08-27 2018-12-22 2018-11-24
2014-12-24
2018-04-20 2019-08-04 2018-12-11 2019-08-20 2018-12-18
2016-10-25 2019-12-18 2016-01-17 2018-12-06
2019-12-18 2019-11-27 2014-08-11 2018-12-24

Exhibit B, Page 174

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 175 of 352 Pageid#: 1078

voter_id 5286397 L
920211355 L 904022851 L 917864877 L 919473057 L 917659507 L
13532638 L 917992772 L 919057654 L 301047775 L 917176359 L 612028555 L 307028740 L 303002455 L 919621932 L 223022293 L 106026923 L 918085931 L 280213063 L 918080784 L 104110250 L 133586870 L 801007993 L 304036986 L 301041994 L 917371861 L 807001315 L 301008568 L 705010472 L 907017402 L 225010335 L 302028742 L 308028741 L

lname

fname SAMUEL VINCENT ELIZABETH JOAN RUTH EUGENE FRANCIS JOHN ELEANOR STEVEN LOUISE GLEN ANDREW ELLIOTT JOHN ALICE VIRGINIA CAROLYN JULIA PATRICIA JOHNNY RITA GEORGE JAMES WESLEY PETER JOYCE DAVID JAMES ANNIE R SHIRLEY JON DONNA

dob 1953 1942 1954 1936 1918 1929 1939 1941 1941 1948 1940 1934 1935 1927 1931 1923 1940 1961 1944 1942 1948 1944 1950 1929 1929 1927 1942 1929 1925 1915 1936 1950 1951

date_registered 2016-10-05 2006-07-21 2004-02-11 2004-10-01 2002-02-21 1996-09-12 2019-08-15 1997-04-11 2001-03-02 1987-10-01 2002-11-06 1991-09-05 1976-09-22 1997-09-15 2003-11-07 1952-09-25 1968-10-05 1997-09-10 2012-10-10 1997-09-04 2011-06-30 2016-09-29 1988-03-31 1990-09-29 2004-10-04 1995-10-07 1972-10-07 2004-08-19 2000-05-03 1959-05-01 1964-07-28 2000-01-06 1984-09-13

ssdi_dod 2018-04-25 2019-08-19 2018-01-31
2018-12-18 2019-12-24 2019-10-08 2018-12-29 2019-09-26 2018-12-08 2020-01-11 2018-05-16
2020-01-08 2019-11-27
2019-12-13 2019-10-06 2019-12-23 2019-11-20 2019-10-31 2017-07-10 2017-02-28
2019-10-01 2017-01-13
2019-12-07 2019-08-08 2018-12-04

obit_dod
2018-01-31 2019-11-01
2019-12-24
2018-12-29 2019-09-26 2018-12-08
2016-11-25
2019-09-26
2019-10-06
2019-11-20
2017-07-10 2017-02-28 2019-09-11 2019-05-26 2019-10-01 2017-01-13 2019-08-11 2015-11-26 2014-10-28 2019-12-07

Exhibit B, Page 175

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 176 of 352 Pageid#: 1079

voter_id 703001584 L 919233682 L 919708536 L 918213470 L 228014044 L 927434320 L 917342284 L 270455924 L 446546065 L 224353653 L 101020479 L 705003120 L 208016960 L 503028365 L
11280576 L 404030986 L 918533962 L 407027511 L 917135136 L 110010026 L 906001034 L 211024292 L
38143091 L 605033577 L 808018374 L 132012429 L 919314177 L 917605791 L 920077055 L 340333244 L 917005615 L 206007836 L 223011976 L

lname

fname WILLIAM WILLARD BARRY CHARLES PEGGY CHARLES JOSE MATTHEW RONALD GERALD ANNA BERNARD WILLIAM JUNIOR STANLEY RAMONA JEFFREY JOHN SANDRA GLENYS JAMES CORINE DONALD JANICE NORMA CANDACE KJOAN KATHERINE CHRYSTAL CLAIRE SUSAN WALTER SUSAN

dob 1944 1945 1959 1943 1935 1931 1936 1976 1948 1946 1925 1945 1933 1936 1955 1934 1972 1942 1942 1924 1940 1940 1939 1950 1933 1953 1930 1948 1955 1922 1939 1932 1944

date_registered 1983-07-28 2001-11-07 2004-03-05 1998-03-12 1980-09-24 2008-10-06 1995-09-18 2017-01-05 2007-12-27 2008-10-04 2004-02-11 2000-04-06 1985-10-05 1967-10-05 2015-11-30 1966-07-25 2004-05-27 1984-12-19 1995-10-10 1988-06-18 2000-06-07 1991-08-15 2012-03-15 1996-02-04 2003-01-21 1997-11-17 2002-05-04 2003-07-30 2005-03-19 2015-06-25 1993-07-31 1999-03-12 1984-03-16

ssdi_dod
2019-09-19 2019-02-08 2019-11-19 2018-11-19 2019-08-31 2019-11-04 2019-12-19 2019-07-25
2019-12-18 2018-09-13
2019-11-30 2018-12-26
2018-12-20 2020-01-23 2019-11-12 2019-12-18 2019-11-08 2019-10-13 2019-06-12
2015-08-21 2016-07-06
2019-12-30 2019-12-15

obit_dod 2019-09-08 2013-01-01 2019-09-19 2019-02-08
2018-11-19
2019-11-04
2019-10-25 2018-12-11 2015-11-30 2019-12-18 2018-09-13 2019-08-22
2019-10-25 2018-12-20
2019-11-12 2019-12-18 2019-11-08 2019-10-13
2016-11-20 2019-08-21 2015-08-21
2019-09-14
2019-12-15

Exhibit B, Page 176

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 177 of 352 Pageid#: 1080

voter_id 223019998 L 311036645 L 428968066 L 920259608 L 305042570 L 609006002 L 905021122 L 801007339 L 157479213 L 507005657 L 129003464 L 804008379 L 229018301 L
21000422 L 918779007 L 308048973 L 503004612 L 920129720 L 212021644 L 918944856 L 605029470 L 210005394 L 125001397 L 124001793 L 121169056 L 918790078 L 918728020 L 917711568 L 920170791 L 907011888 L 504027403 L 918047810 L 306004897 L

lname

fname ALMEDA ANA LIZZ ANDREW JUNE TERESA P THELMA BEVERLY DANIEL RUTH WILLIAM ROBERT BETTY ROBERT LILLIAN SAHIBZADA FRANCES MARJORIE DAVID HENRY ELWYN CHRISTINE STUART WILLIAM JEANNE DAVID HENRY KATHLEEN WILLIAM LUCILLE MARY ANNA JOHN HARRIET

dob 1922 1949 1971 1927 1923 1931 1939 1946 1944 1929 1937 1931 1938 1925 1936 1936 1931 1930 1966 1945 1933 1932 1940 1934 1928 1930 1945 1952 1940 1923 1922 1944 1933

date_registered 2003-08-08 1992-10-03 2008-09-17 2006-03-06 1972-05-09 1988-08-09 1988-04-05 1999-09-02 2009-07-17 1987-10-03 1987-07-10 1982-03-24 1966-05-14 1964-08-03 2000-05-11 2005-08-17 1985-09-09 2005-07-08 1993-06-05 2000-10-05 1979-10-05 2000-01-31 2000-03-15 1984-03-13 2015-10-13 2000-05-10 2000-03-22 1997-11-08 2005-09-21 1959-11-17 2002-07-22 1997-07-24 1984-09-04

ssdi_dod 2019-03-22 2019-06-30 2019-09-29 2018-12-19 2018-12-05 2019-11-30 2017-10-03
2019-06-29 2019-07-30
2018-12-31
2019-08-23 2019-10-01 2019-10-27 2014-09-10 2019-08-09
2018-12-21
2019-12-06
2019-12-20 2019-11-01 2019-11-04 2017-11-15
2018-05-08 2020-01-27 2019-11-08

obit_dod 2019-03-22
2019-09-29
2018-12-05 2019-11-30 2017-10-03 2019-08-16
2019-07-30 2018-05-26
2019-09-28 2019-09-12 2019-08-23
2019-10-27
2019-08-09 2019-08-19 2018-12-21 2019-10-23 2019-12-06 2019-04-02
2019-11-04 2017-11-15 2019-08-21 2019-11-14
2019-11-08

Exhibit B, Page 177

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 178 of 352 Pageid#: 1081

voter_id 917755259 L 122000769 L 807005409 L 409016187 L 917520353 L 165021570 L 920394693 L 708016682 L 919769130 L 708019103 L 308049390 L 918115119 L 689502971 L 917581867 L 601003137 L 205023901 L 605029189 L 918435699 L 919896635 L 908005329 L 113002584 L 310027888 L 807016122 L 629601501 L 303020907 L
23017246 L 907018807 L 208024393 L 102206351 L 253795497 L 603019940 L 371903840 L 919606261 L

lname

fname AARON SUSAN DAVID WILBUR SYLVIA DALARNO EUGENE SAMUEL ANNA BARBARA THOMAS CALVIN RONNIE WILLIAM HELEN BARBER BARBARA APRIL FIELDING SHIRLEY JEANETTE YVONNE RUTH BRIAN ROBERT DAVID MARK IRENE CHARLES LUCILLE LEE TONY THANH

dob 1957 1924 1938 1957 1932 1964 1941 1932 1930 1930 1948 1943 1947 1943 1923 1938 1942 1964 1943 1937 1934 1936 1921 1941 1931 1964 1925 1930 1924 1929 1937 1948 1944

date_registered 1996-10-07 1967-09-15 1968-10-03 2000-11-14 1997-06-27 2016-09-13 2006-11-08 1953-06-13 2004-05-27 1968-10-01 2004-10-01 1997-10-06 2012-10-05 2002-07-12 1955-10-12 1977-03-07 1967-10-06 1999-02-18 2004-09-19 1975-12-26 1995-10-10 1992-09-05 1974-10-01 2017-03-09 2006-08-11 2005-11-09 2005-06-29 1967-09-28 2012-10-15 2012-04-16 1997-07-21 2012-07-05 2003-10-03

ssdi_dod 2019-07-30 2019-06-22 2018-12-16 2018-12-15 2018-12-12 2017-02-26 2014-01-08
2020-01-13 2019-12-14 2019-12-10 2019-11-18 2019-09-16 2019-09-01 2018-12-18 2018-10-10 2018-05-07 2018-03-30 2018-01-29 2018-01-09 2018-12-21 2019-11-12 2018-12-27 2018-01-24 2019-08-07 2019-08-14 2018-12-22 2014-06-13 2019-10-16
2018-03-22

obit_dod 2019-07-30 2019-06-22 2018-12-16 2018-12-15
2017-02-26 2014-01-09 2019-10-13 2018-12-30
2019-12-14 2019-12-10 2019-11-18 2019-09-16 2019-09-01 2018-12-18 2018-10-10 2018-05-07 2018-03-30 2018-01-29 2018-01-09 2018-12-21 2019-11-12 2018-12-27 2018-01-24
2019-08-14 2018-12-22
2019-10-16 2019-08-15
2017-07-11

Exhibit B, Page 178

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 179 of 352 Pageid#: 1082

voter_id 225001638 L 301004142 L 187192109 L 919786832 L 208008836 L
1000867 L 917983731 L 917433666 L 560056679 L 304041998 L 918055935 L 918081126 L 308020114 L 602010804 L 301039911 L 306020907 L 226004272 L 104002091 L 918366648 L 919758336 L 502013277 L 919690029 L 919373859 L 506025165 L 919873617 L 918662343 L 918069611 L 917100322 L 813014345 L 803008195 L 403003842 L 806015149 L 116840733 L

lname

fname RONALD MANUEL ANDREW LAWRENCE SHIRLEY WAYNE CARROLL BEULAH MARY EDWARD RICHARD JANET EDWARD GLEN JAMIE DICK JANE MARY JUDITH PATRICIA WILLIAM KATHLEEN BARBARA WILLIE KUM PARIS WILLIAM BETTY DOROTHY JIMMIE CHARLES WALTER SHIRLEY

dob 1940 1931 1927 1944 1939 1947 1932 1951 1920 1926 1939 1937 1941 1933 1949 1935 1932 1925 1936 1937 1948 1941 1943 1945 1930 1982 1931 1938 1922 1940 1933 1940 1941

date_registered 1987-09-28 1988-08-19 2009-07-15 2005-10-06 1976-09-16 1977-09-24 1997-04-29 2001-02-13 2008-02-22 1976-10-01 1997-07-24 1997-08-29 1984-10-03 2016-05-11 1995-01-09 1989-04-13 1956-05-04 1963-05-04 2001-10-02 2004-05-13 1978-10-07 2004-02-21 2002-08-12 1967-05-10 2009-01-23 2002-10-07 2001-11-13 1994-03-29 1990-07-16 1987-10-03 1980-09-23 1992-09-26 2018-10-01

ssdi_dod 2020-01-09 2020-01-20 2019-08-10 2019-12-05 2019-10-14
2019-10-26 2018-12-20 2019-11-25 2019-10-18
2019-01-04 2018-12-10
2019-09-03 2019-08-28 2020-01-25 2019-01-15 2019-10-24 2019-12-31 2019-12-19 2019-12-16 2019-11-30 2019-11-29 2019-11-13 2019-11-03 2019-10-27 2019-10-07 2019-08-08 2019-07-29 2019-07-02 2019-01-24

obit_dod
2019-08-10 2019-12-05 2019-10-14 2016-04-13 2019-10-26 2018-12-20 2019-11-25 2019-10-18 2019-09-18 2019-06-23 2019-02-04 2018-12-10 2019-09-07 2019-09-03 2019-08-28
2018-09-04
2019-11-30
2019-11-13 2019-11-03 2019-10-27 2019-10-07 2019-08-08 2019-07-29 2019-07-02

Exhibit B, Page 179

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 180 of 352 Pageid#: 1083

voter_id 906003820 L 917437261 L
93749197 L 919923969 L 502007731 L 203001447 L 417911556 L 226000745 L 918152654 L 414013297 L 610010173 L 918747379 L 920188457 L 312345930 L 704016803 L 918561550 L 123011429 L 422416694 L
72420981 L 108010559 L 602029191 L 227008215 L 804017134 L 917565197 L 920370556 L 802008545 L 919424334 L 207019113 L 917512283 L 608023785 L 305011302 L
5003413 L 917163715 L

lname

fname DORIS PATRICIA WON STEVEN PATTY KENNETH CAROL MARGARET PAUL ANNIE PEGGY A JANE CAROLYN JANET ROBERTO JANIE DANETTA SALADO MARIA MARGARET JERRY JUNIOR RUTH DEBORA GEORGE CHESTER CAROLE LOUIS LOUIS WILMA FAITH EARL LYNDELL

dob 1929 1941 1948 1962 1939 1929 1938 1931 1944 1942 1946 1947 1927 1942 1940 1936 1925 1933 1934 1937 1941 1940 1925 1955 1952 1921 1947 1940 1943 1924 1933 1939 1942

date_registered 1999-11-03 1996-04-01 2011-02-02 2004-09-29 1983-09-22 1955-04-01 2015-07-31 1952-10-04 2005-09-12 1976-11-06 1988-10-08 2000-04-05 2005-09-19 2009-12-17 1984-10-02 1999-08-17 1999-01-04 2011-11-28 2012-10-15 1972-10-03 1962-09-27 1983-03-11 1968-10-05 1996-07-24 2006-10-03 1955-05-14 2002-11-06 1991-10-05 1996-06-12 1998-07-17 1988-04-30 1961-12-29 2000-03-10

ssdi_dod 2018-12-04 2018-12-04 2018-10-05 2018-05-04 2018-03-12 2018-01-11 2018-01-11 2017-03-13 2016-11-27 2007-11-20 2001-01-13
2018-12-20 2020-01-11 2019-10-19 2014-07-24 2019-12-25
2018-12-04 2018-11-13 2019-10-18 2019-11-05
2019-09-23 2016-09-11 2019-09-12
2019-08-25

obit_dod 2018-12-04 2018-12-04
2018-05-04
2018-01-11 2018-01-11 2017-03-13
2007-11-20
2019-08-17 2019-05-17 2018-12-05 2017-12-28 2018-12-20
2018-12-11 2019-10-14 2019-08-06 2018-12-04 2018-11-13
2019-11-05 2018-12-28 2019-09-23 2016-09-11 2019-09-12 2019-10-04 2019-08-25

Exhibit B, Page 180

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 181 of 352 Pageid#: 1084

voter_id 917516171 L 225064373 L 918364645 L
28009171 L 304039670 L 918535178 L 302033506 L 310023942 L 918868604 L 702012091 L 509009090 L 328648819 L 266462536 L 801011145 L 696788219 L 936960264 L 305053677 L 301053684 L 223018572 L 920242037 L 918408830 L
44979941 L 920319772 L 206007324 L 706012313 L 606014419 L 204001453 L 350668255 L 917641620 L 917705449 L 920375282 L
22019303 L 401033218 L

lname

fname PATRICIA HENRY DOLORES ANDREW ETHEL ARTHUR JOHN FERNANDO WILSON LESLIE EUNICE JACQUELINE JEANNE ROBERT CHARLES JULIO KARL JOHN JILL CAROLYN BARBARA EUGENE EDNA BENJAMIN PAUL DAVIS GERTRUDE BARBARA HECTOR DORIS CLARA RICHARD EDWARD

dob 1964 1936 1929 1930 1921 1931 1945 1940 1937 1942 1930 1934 1935 1945 1945 1933 1945 1934 1950 1948 1936 1944 1946 1928 1939 1931 1945 1929 1935 1943 1935 1943 1935

date_registered 1996-06-14 2013-07-09 1998-10-05 1984-08-01 1997-04-07 2001-10-09 1988-06-15 1986-09-23 2000-08-31 1996-08-20 1959-04-07 2017-01-09 2016-07-28 1980-04-05 2008-09-19 2008-02-28 1987-01-03 1992-10-03 1980-09-17 2006-01-24 2000-01-13 2009-09-21 2006-06-29 2000-03-01 1994-10-31 1980-09-30 1967-09-11 2008-10-03 1996-09-10 1996-10-01 2006-10-06 1988-03-09 1964-07-23

ssdi_dod 2017-12-15
2019-09-25
2018-12-22 2019-08-09 2019-06-04 2018-11-13
2018-01-02 2018-05-31 2014-11-07 2018-06-01 2019-09-25 2016-04-23 2016-03-31 2018-01-12 2019-08-29 2019-01-23 2020-01-08 2019-09-17 2018-08-01 2018-05-20 2015-09-17
2019-04-11
2018-12-08 2018-06-02

obit_dod 2017-12-15 2016-09-27 2019-09-08 2019-09-25 2019-11-01 2019-08-02 2014-11-09 2018-12-22 2019-08-09 2019-06-04 2018-11-13 2018-11-19
2014-11-07
2019-09-25
2018-01-12 2019-08-29
2019-09-17
2018-05-20
2017-05-01 2017-12-15 2019-04-13 2014-01-31 2018-12-08 2018-06-02

Exhibit B, Page 181

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 182 of 352 Pageid#: 1085

voter_id 2820201 L
66394783 L 302021506 L 157187269 L 920145769 L 203024107 L 801011336 L
98426092 L 917570454 L 502025087 L 810007582 L 805005869 L 904016901 L 606001853 L
23001914 L 705006018 L 125005239 L 460097316 L 125004681 L 406009280 L 221014848 L 502031796 L 103017977 L 810015150 L 318584997 L 705011920 L 308045405 L
23002847 L 43105267 L 601007428 L 917938322 L 505025087 L 202026016 L

lname

fname GERMAINE IRMA LILLIAN JESSE MARGARET HARVEY DONALD SHIRLEY DUFF PAULINE SAMUEL VICTOR BEULAH ESTA ANN JASPER LUCILLE JAMES LEROY FRANK DANIEL MARY WILLIAM LARRY JAMES EDDIE DAVID VIRGINIA TIMOTHY CYNTHIA MINNIE RUTH MARGARET

dob 1929 1947 1931 1925 1930 1927 1947 1937 1940 1938 1927 1936 1925 1928 1934 1923 1932 1940 1936 1922 1938 1940 1945 1953 1959 1940 1936 1932 1966 1961 1929 1921 1924

date_registered 2012-06-25 2012-04-17 1960-06-07 2015-06-03 2005-08-10 1970-05-01 1972-03-28 2017-10-02 1996-07-29 1975-10-04 2004-11-03 1980-10-01 1956-10-05 1998-05-19 1964-04-23 1989-12-13 2000-12-05 2015-10-06 1994-02-08 1955-07-13 1967-07-12 1990-07-16 2002-08-07 2006-09-11 2016-08-24 1989-10-06 1985-09-14 1958-12-04 2014-10-08 2003-09-09 1997-03-21 1981-11-30 1968-05-22

ssdi_dod 2019-12-31 2019-02-20
2019-03-24
2020-01-23 2020-01-05 2020-01-02 2019-12-24 2019-12-19 2019-12-18 2019-12-03 2019-11-06 2019-11-04 2019-11-01 2019-10-31 2019-10-08 2019-10-04 2019-09-27 2019-09-26 2019-09-10 2019-08-25 2019-08-24 2019-08-05 2019-04-21 2018-12-24 2018-08-30 2018-04-22 2018-03-14 2018-02-26 2017-11-30 2017-11-29 2017-11-28

obit_dod
2019-02-20 2019-08-18 2019-03-24 2019-08-09
2019-12-19 2019-12-18 2019-12-03 2019-11-06 2019-11-04
2019-10-31 2019-10-08 2019-10-04
2019-09-26 2019-09-10
2019-08-05
2018-12-24 2018-08-30 2018-04-22 2018-03-15
2017-11-30 2017-11-29 2017-11-28

Exhibit B, Page 182

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 183 of 352 Pageid#: 1086

voter_id

lname

628575581 L

918528616 L

704021670 L

612033454 L

917227842 L

399987077 L

22008746 L

308048219 L

25013714 L

906016902 L

918067097 L

302024294 L

908022425 LI

335198966 LI

310012457 LI

308000415 LI

920355581 LI

809360 LI

503000173 LI

201001202 LI

201003025 LI

205015948 LI

405012856 LI

213009218 LI

306038077 LI

598798592 LI

607003321 LI

255344545 LI

406001723 LI

507004931 LI

918968783 LI

917245029 LI

917888608 LI

fname ANDREW ROGER LEONARD DAPHNEY LUVINIA GREGORY SINCLAIR MARILYN PRISCILLA RICHARD THOMAS MARY GEORGE JACK TERESA ELIZABETH ALTA IRENE EVELYN WILLIAM AUBREY WARREN CALVIN DOLORES DIANA KEATH WILLIE ISABEL RONALD THOMAS TEOFILO JOSEPH PING

dob 1935 1946 1944 1921 1915 1948 1940 1937 1949 1937 1943 1925 1921 1924 1962 1939 1928 1926 1945 1946 1933 1927 1922 1939 1933 1958 1947 1933 1939 1923 1964 1946 1947

date_registered 2008-08-07 1999-06-21 1979-05-11 1982-08-31 1994-11-30 2016-12-14 2006-07-15 1984-09-26 1996-10-05 1960-06-01 2005-08-16 1969-09-23 1968-09-11 2016-06-30 1991-09-12 1974-09-25 2006-09-13 2012-10-01 1975-10-03 1991-09-14 1955-12-24 1997-12-01 1943-07-13 1991-03-07 1996-09-21 2013-11-06 1986-10-03 2010-10-12 1980-03-13 1988-01-15 2015-06-10 1995-03-03 1997-02-24

ssdi_dod 2016-12-29 2016-12-28 2016-11-17 2012-12-12 2000-05-06
2018-12-21
2019-08-14 2019-11-06
2019-11-21 2014-07-18 2019-11-24 2017-12-25 2018-12-23 2018-12-18 2013-11-27 2019-05-01 2015-08-20 2017-05-05 2019-12-01 2019-02-24
2019-12-09 2018-03-28 2002-05-01 2019-04-11

obit_dod
2016-12-28
2012-12-12
2019-09-12 2019-08-13 2019-05-29 2019-03-09 2018-12-04 2019-04-05
2019-09-21
2018-03-02
2019-11-24 2017-12-25 2018-12-23 2018-12-18
2017-05-05 2019-12-01
2018-01-30
2018-03-28

Exhibit B, Page 183

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 184 of 352 Pageid#: 1087

voter_id

lname

108012677 LI

21016605 LI

917864439 LI

917060850 LI

215006846 LI

875335195 LI

603011707 LI

505027609 LI

919152594 LI

8003273 LI

917750061 LI

919821956 LI

144903773 LI

413016674 LI

205008842 LI

211008976 LI

804011146 LI

11005524 LI

920029145 LI

508022309 LI

919495562 LI

374675351 LI

22011127 LI

109013037 LI

227002704 LI

302002681 LI

803019770 LI

689383158 LI

805000114 LI

919066334 LI

404006389 LI

304043910 LI

208004281 LI

fname KHAYAN DORIS ROBERT FREDERICK JEFFREY NANCY JAMES MARY AURELIA FANNIE TONYA RAYMOND ANTHONY JAMES ROLAND JEFFREY JOHN BARBARA JOSEPH DALLAS PATRICK ROBERT GERALD ROBERT EDNA IZABELA DOROTHY IRENE CLYDE CHERI LOURAIN LEWIS NORA

dob 1933 1930 1923 1941 1949 1937 1941 1957 1936 1925 1967 1939 1960 1959 1948 1962 1948 1938 1940 1927 1962 1939 1933 1930 1932 1929 1919 1939 1928 1972 1932 1943 1951

date_registered 2003-02-04 1987-03-05 1996-12-04 1993-11-10 2000-12-18 2008-10-03 1988-10-07 1991-01-29 2001-07-24 1973-10-04 1998-09-04 2004-08-02 2018-03-28 2001-06-26 2000-01-31 1987-04-09 1980-09-09 1976-10-01 2004-11-17 1960-09-28 2003-04-04 2015-10-13 1984-03-31 1962-10-02 1974-03-26 1969-10-04 1999-02-11 2007-09-24 1952-10-03 2001-03-08 1984-08-23 1987-05-02 1980-10-02

ssdi_dod 2016-12-28 2018-10-14
2019-11-23
2019-10-23 2019-08-18 2016-12-20 2019-11-23 2019-09-20 2019-08-21 2016-09-26 2020-01-05 2019-09-29
2018-12-21 2017-09-25 2018-10-04 2018-05-01
2019-11-10
2018-12-13 2019-08-20 2019-10-26
2019-11-29 2019-11-04 2019-10-24
2019-08-17

obit_dod
2018-12-14 2018-10-27 2019-11-23 2017-12-31 2019-08-29 2019-10-23 2019-08-18 2016-12-20 2019-11-23 2019-09-20 2019-08-21 2016-09-26
2019-09-29 2019-10-01
2018-10-04 2018-05-01 2019-08-20 2019-11-10 2018-10-29 2018-12-13 2019-08-20 2019-10-26 2015-02-07 2019-11-29
2019-10-24 2015-07-30 2019-08-17

Exhibit B, Page 184

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 185 of 352 Pageid#: 1088

voter_id

lname

604023546 LI

901007154 LI

918542725 LI

906009625 LI

918918275 LI

703026923 LI

701011563 LI

918246836 LI

917495165 LI

905014823 LI

128002270 LI

24000160 LI

11006744 LI

23007867 LI

44277136 LI

18034042 L

920140220 L

708001309 L

252171802 L

120960942 L

704025430 L

101005737 L

603035844 L

127009250 L

919137269 L

917235648 L

121014567 L

979186191 L

917675926 L

10005525 L

303029988 L

103010782 L

280194645 L

fname MARY GAIL WILLIAM WILLIS JESSICA CATHERINE SAMUEL PAUL JOHN MIRIAM JAMES JEANETTE JACQUELINE MICHAEL GLORIA GRACIELA OSCAR WESLEY LERA BONNIE MARY VIOLET HAROLD DAVID ANITA DEBORAH EMMA ANDREW JACQUELINE TIMOTHY WILLIAM JANE MELVYN

dob 1940 1947 1929 1940 1981 1946 1936 1943 1970 1938 1924 1934 1928 1956 1946 1927 1944 1924 1922 1942 1923 1925 1947 1935 1953 1963 1935 1977 1944 1944 1926 1926 1937

date_registered 1974-01-31 1980-09-16 2001-07-09 1964-09-16 2000-10-04 1991-08-19 1967-10-06 1998-04-14 2001-08-22 1996-09-20 1955-03-16 1984-06-18 1969-10-04 1980-09-26 2015-03-31 2016-04-01 2005-07-29 1946-10-02 2016-04-11 2015-05-13 1981-08-04 1992-09-30 1991-05-22 1968-10-03 2001-06-26 1997-11-26 2000-04-26 2008-06-24 1996-09-18 1968-09-28 1980-12-12 2004-11-10 2010-09-15

ssdi_dod 2020-01-22 2019-12-25 2019-11-26 2019-09-06 2017-02-05
2019-06-02
2018-12-22
2018-06-24 2019-10-25 2019-08-17 2018-12-20
2018-12-22 2019-05-12 2006-11-06
2019-10-05 2019-08-24 2019-08-14 2019-09-28 2018-03-27 2017-03-26 2016-09-30 2009-05-18
2019-11-27 2019-03-29

obit_dod
2019-12-25
2019-09-06
2019-08-17
2019-11-07 2018-12-22 2019-08-17
2019-08-17 2018-12-19 2018-11-30 2018-12-22
2006-11-06 2019-08-08 2019-05-22 2019-04-29 2019-10-05 2019-08-24
2019-09-28 2018-03-27 2017-03-26 2016-09-30
2019-08-22
2019-03-29 2019-10-14

Exhibit B, Page 185

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 186 of 352 Pageid#: 1089

voter_id 41562869 L
426717985 L 229012656 L 508029461 L 805000791 L 918012662 L 807008381 L 227014850 L 259182791 L 701014582 L 304043912 L 605036855 L 104022886 L 608015490 L
21015208 L 908007156 L 224009685 L 905010388 L 651351602 L 918577596 L 703028199 L 301000780 L 919515527 L 606019239 L
61444654 L 15618400 L 918773274 L 302022027 L 28848102 L 918946437 L 919566718 L 25871876 L 704023648 L

lname

fname JUNE ANTHONY ETHEL VIRGINIA GARY FRED CHARLES JACQUELINE MARY RICHARD DONNA CAROL BLANCHE JAMES JACQUELINE DOLORES HARMON REBECCA CHARLES ROBERT KATHLEEN DALE RICHARD MONTE ALVERINA THEODORE CATHERINE BONNIE AIDA NELETT ANNETTE BILL GRAYDON

dob 1951 1964 1944 1921 1939 1939 1940 1936 1928 1943 1942 1937 1936 1927 1926 1938 1933 1949 1931 1966 1945 1948 1938 1932 1955 1962 1938 1935 1931 1970 1945 1954 1932

date_registered 2008-09-10 2008-10-06 1992-03-31 1949-06-30 1985-10-04 1997-06-11 1976-04-03 1972-01-27 2008-10-06 1972-06-20 1968-09-25 1984-08-25 1964-10-01 1997-06-11 2000-09-06 1983-01-01 1963-10-05 1999-02-02 2008-07-18 1999-08-27 1987-04-01 1981-09-18 2003-05-07 1955-09-08 2017-12-07 2010-11-15 2000-05-09 1967-10-03 2016-07-22 2002-01-15 2003-08-04 2011-04-07 2016-10-17

ssdi_dod 2018-03-21 2018-01-21
2019-11-25
2019-11-05 2019-11-30 2019-11-01 2015-03-16 2017-09-17 2020-01-15 2020-01-09 2020-01-08 2019-11-04 2019-10-27 2019-10-02 2019-09-23 2019-08-11 2018-07-09 2015-11-21 2019-12-18 2019-11-08 2019-12-25 2019-10-18 2019-11-04 2019-05-03 2014-10-02
2019-06-24 2020-01-14 2018-10-10 2019-09-19

obit_dod
2016-08-02 2019-11-25 2018-04-29 2019-11-05 2019-11-30 2019-11-01 2015-03-16 2017-09-17
2019-11-04 2019-10-27 2019-10-02 2019-09-23 2019-08-11
2019-11-04
2019-08-05 2019-08-01
2019-09-19

Exhibit B, Page 186

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 187 of 352 Pageid#: 1090

voter_id 603036400 L 309013648 L 136474866 L 813012321 L 268795301 L 505001728 L 314011311 L 234769053 L 911019461 L 919794054 L 918360870 L 917188760 L 526011903 L 917916928 L 919905174 L 201025920 L 601026168 L 517958631 L 917845163 L 403006210 L 704003415 L 890401345 L 304020915 L 801008002 L 904015707 L 308037853 L 917747025 L 917191055 L
6003112 L 129436310 L
25008753 L 603014565 L 918261532 L

lname

fname DONALD MARY W EDWARD EVELYN THELMA DUANE MOLLIE GEORGE WILLIAM CONNIE WARREN VIOLA WALTER RICHARD ANNE JOSEPH PHILLIP WILLIAM FRANCES GEORGE EVA CHARLES CLARINE EUNICE MARTHA SUSAN WINTON ELEESA DANNY VIRGAL SHIRLEY ROSEMARY

dob 1931 1924 1935 1938 1920 1931 1941 1947 1947 1952 1932 1945 1943 1944 1965 1929 1942 1943 1946 1920 1937 1952 1925 1923 1925 1927 1953 1925 1948 1953 1943 1934 1930

date_registered 1994-10-11 1975-05-08 2011-10-17 1992-09-21 2008-03-28 1968-10-01 2000-06-20 2016-10-12 1997-08-27 2004-06-09 1998-10-05 2003-05-10 2008-09-25 1997-03-04 2004-09-22 1951-03-31 1999-08-02 2009-05-11 1996-12-12 1967-10-05 2016-09-14 2008-10-06 1968-08-13 1984-10-03 1966-05-11 1955-09-22 1996-10-04 1994-10-03 1972-10-05 2016-10-21 1964-07-23 1956-10-06 1998-05-11

ssdi_dod 2017-11-27
2018-11-20 2019-10-28 2016-09-13 2014-10-27
2019-02-05 2019-08-19 2017-12-04 2017-11-23 2018-05-03 2019-11-19 2019-08-16 2018-01-24 2020-01-12 2020-01-06 2019-12-19 2019-12-06 2019-11-01 2019-10-03 2018-01-22
2019-01-25 2019-11-19 2019-04-22 2018-12-27 2017-12-30 2017-12-10
2018-12-19

obit_dod 2017-11-27 2018-01-27
2019-10-28 2016-09-13
2018-11-29 2019-02-05 2019-08-19 2017-12-04 2017-11-23 2018-05-03 2019-11-19 2019-08-16
2019-12-19
2019-11-01
2019-08-19 2019-08-13 2019-08-05
2019-11-19 2019-04-22 2018-12-27
2017-12-10 2019-10-27 2018-12-19

Exhibit B, Page 187

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 188 of 352 Pageid#: 1091

voter_id 102005931 L 302023347 L 301041358 L 908005955 L 918913117 L 919983314 L 920077406 L 356239322 L 918048747 L 805009130 L 302043357 L 108023814 L 203543885 L
76201038 L 920398555 L
24009766 L 227015129 L 302010491 L 917735014 L 919177141 L 919697422 L 304042317 L 509010129 L 870852735 L 503005290 L 941699616 L 306031021 L 223005783 L 211012162 L 804008383 L 308032103 L 918588158 L 917491240 L

lname

fname ALLEN NANCY ALMA STEPHEN DOUGLAS JESSICA ALFREDO EDWARD PATRICIA DAVID JEFFREY CAROL CHANDRA ROSA NORMA EDWARD JERRY SARA MAUDIE THEODORE JOHNNY MARILYN PHYLLIS DOROTHY RICHARD DAVID VIRGINIA MELINDA ROBERT JANET PHILIP IDA DONALD

dob 1957 1934 1930 1954 1943 1984 1940 1940 1942 1928 1947 1952 1991 1930 1928 1928 1953 1940 1938 1951 1938 1941 1923 1938 1931 1940 1944 1937 1937 1933 1923 1939 1946

date_registered 1987-10-03 1984-09-08 1984-04-04 2000-01-07 2000-10-02 2004-10-04 2005-04-01 2012-10-15 1997-07-25 1986-09-22 2002-11-06 1992-09-25 2016-10-14 2012-11-13 2006-11-16 1972-01-19 1971-08-18 2002-05-23 1996-10-07 2001-09-05 2004-02-17 1997-12-08 1967-10-05 2008-10-06 1993-01-06 2007-04-04 1972-10-07 1966-05-28 1998-07-07 1999-04-26 1964-07-27 1999-09-09 1996-05-09

ssdi_dod 2016-10-27
2019-11-25 2019-11-25 2019-04-03
2019-11-29 2020-01-03 2018-07-10 2019-11-23 2019-08-14 2019-11-22 2019-11-14 2019-10-30 2019-10-26 2019-10-07 2019-09-19 2018-06-30 2015-07-29 2019-12-29
2020-01-15 2019-11-08 2019-12-19 2018-12-19 2018-09-08 2019-09-08 2019-08-10
2019-11-03 2018-09-17

obit_dod 2016-10-27 2019-08-27 2019-01-21 2019-11-25 2019-11-25 2019-04-03 2019-08-16 2019-11-29
2019-11-23 2019-08-14 2019-11-22 2019-11-14
2019-10-26 2019-10-07 2019-09-19
2018-12-20
2019-11-08
2018-12-19 2018-09-08
2019-08-10 2019-10-06 2019-10-03 2019-11-03 2018-09-17

Exhibit B, Page 188

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 189 of 352 Pageid#: 1092

voter_id

lname

69371913 L

920006347 L

714013881 L

607010031 L

608018042 L

82257646 L

306007680 L

309007680 L

919387811 L

26229405 L

919315615 L

919539888 L

259066504 L

802009986 L

703021986 L

602037184 L

918737822 L

47776627 L

141766677 L

410005513 L

801012106 L

902021678 L

309016374 L

306051389 L

919782230 L

513014240 L

919729876 M

208007588 M

708002013 M

12140133 M

919398511 M

308028354 M

906010389 M

fname GERTRUDE CHEH-KUEN JAMES EVELYN BILLY JOANNE CYNTHIA HARRY KATIE GERALD THOMAS TONI GURCHARAN WESLEY HERMAN ALTON ADRIAN JOANNE HERMAN JEARLINE RUTH SAMUEL MERIAM LINDA DELORIS ROBERT NORMAN MAYLEASE KATHRYN LINDA HERBERT DANTE ROBERT

dob 1927 1927 1941 1923 1941 1954 1946 1941 1962 1949 1944 1948 1944 1920 1925 1943 1962 1947 1948 1938 1922 1938 1927 1947 1940 1958 1948 1938 1927 1949 1922 1925 1932

date_registered 2014-07-02 2004-10-04 1979-04-02 1955-06-04 1979-10-03 2017-09-18 1976-10-02 1992-07-04 2002-09-05 2013-12-06 2002-05-08 2006-11-17 2018-04-16 1997-12-16 1997-06-11 1979-01-05 2000-04-03 2013-02-01 2011-04-28 1988-10-06 1964-04-23 1960-11-30 1982-10-01 2002-06-14 2004-05-28 1992-10-01 2004-03-25 1987-09-15 1983-05-31 2009-10-05 2002-09-03 1983-09-27 1968-07-25

ssdi_dod 2018-08-06 2019-08-01 2020-01-25
2019-03-26 2019-09-23
2019-09-29 2015-01-09
2019-04-03 2018-10-20 2018-07-31
2019-08-24 2020-01-12 2019-10-25 2019-09-10 2018-12-24 2018-12-02
2019-09-13 2018-10-27 2019-06-13
2019-11-27
2015-08-09 2019-01-03 2019-06-29 2019-09-25

obit_dod 2018-08-06
2017-04-04 2019-03-26 2019-09-23 2018-11-01 2014-08-29 2019-09-29
2019-10-05 2017-10-03
2018-10-20
2018-12-04 2019-08-24
2019-10-25 2019-09-10 2018-12-24
2017-04-20 2019-09-13 2018-10-27 2019-06-13 2019-01-13 2019-11-27 2019-03-02
2019-09-25

Exhibit B, Page 189

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 190 of 352 Pageid#: 1093

voter_id

lname

501030686 M

504006423 M

2685228 M

105004627 M

221023080 M

919832174 M

919509421 M

312950224 M

710020802 M

919143407 M

918026902 M

306042935 M

106023274 M

917182083 M

345627547 M

919453077 M

704024030 M

917125361 M

920099602 M

228004250 M

919242745 M

407281930 M

919112351 M

801011149 M

304004165 M

306031525 M

412031318 M

917968420 M

212328666 M

807012582 M

102019795 M

21003121 M

491576725 M

fname JOY WELDON RAYMOND JEAN FRANKLIN MATTIE RONALD GEORGE CALVIN DORETHEA PAUL WILLIAM ARTHUR PATRICIA JOHN CONLEY BRUCE DANIEL CASEY BEVERLY MOHAMMAD MARJORIE MARY KATHLEEN ROBERT WILLIAM CHARLES ANNE MARIAM KAY CHARLES ROBERT JUDY

dob 1937 1927 1948 1928 1922 1937 1962 1945 1924 1939 1947 1930 1932 1938 1949 1976 1935 1929 1987 1926 1924 1928 1944 1933 1930 1925 1951 1924 1935 1943 1923 1934 1943

date_registered 1993-09-24 1998-07-09 2012-11-09 1988-02-02 1993-08-24 2004-08-07 2005-10-06 2008-07-17 1981-07-13 2001-07-17 1997-06-19 1984-09-05 1953-09-26 1994-09-30 2016-10-14 2002-12-13 1984-08-22 1994-06-16 2005-04-20 1954-06-12 2001-12-10 2015-10-13 2001-06-13 1956-10-01 1993-10-29 1995-09-22 1991-09-27 1997-04-11 2018-02-05 1998-12-08 2005-05-10 1984-03-13 2018-08-24

ssdi_dod 2019-10-22 2019-09-11
2018-01-26 2019-08-13 2019-12-04 2019-09-14 2018-12-15 2018-12-04 2018-01-16
2019-08-06 2019-09-14
2018-12-16 2016-06-14 2016-08-22 2018-05-05 2018-12-24 2019-09-12 2014-10-14
2019-12-08 2018-12-24 2019-11-22
2018-05-13 2020-01-27 2018-07-16 2019-03-21

obit_dod 2019-10-22 2019-09-11 2018-12-12 2018-01-26
2019-12-04 2019-09-14
2018-01-16 2019-10-06 2019-10-25 2019-01-31 2017-05-02
2019-09-14 2019-09-10
2016-06-14 2016-08-22
2018-12-24
2017-09-08 2019-12-08 2018-12-24
2019-08-01 2018-05-13

Exhibit B, Page 190

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 191 of 352 Pageid#: 1094

voter_id

lname

902014431 M

904011806 M

687142184 M

917070097 M

918189251 M

637912695 M

782054764 M

262793290 M

225015442 M

918110115 M

32011480 M

104014733 M

183509097 M

917182629 M

30545593 M

217706553 M

917564183 M

911022873 M

919418032 M

919018177 M

361290570 M

918310799 M

919300174 M

253974572 M

917871717 M

917219456 M

304013657 M

919969243 M

917469883 M

532402450 M

919419288 M

919454013 M

917276738 M

fname ANTHONY CATHRYN MARIA ROBERT DAVID JOSEPH MANORMA OLGA NORMA DONALD TERENCE THOMAS ELSIE BETTY SHEILA PHYLLIS JOSEPH MARK JOSIE GEORGE JAMES LOIS NASHAAT CECIL ANTONIO EZZATOLLAH JANE GERALDINE MARY FRANK SANDRA ALICE WILLIAM

dob 1943 1929 1930 1942 1938 1979 1945 1929 1940 1947 1950 1935 1919 1944 1940 1930 1944 1962 1944 1944 1943 1934 1946 1924 1927 1936 1946 1937 1943 1941 1955 1947 1933

date_registered 1992-04-04 1955-04-16 2008-05-01 1994-01-29 1998-02-05 2015-04-08 2008-09-09 2009-06-12 1996-10-07 1997-10-02 1992-08-24 1999-08-13 2008-12-05 1994-09-30 2015-01-21 2015-06-16 1996-11-18 1996-12-06 2002-10-07 2001-01-09 2010-10-12 1998-07-17 2002-04-01 2008-06-27 1997-01-17 1994-10-08 1979-03-16 2004-10-04 1996-04-15 2007-02-05 2002-10-07 2002-12-02 1995-04-28

ssdi_dod 2019-09-01
2019-10-29
2019-11-05 2019-06-18 2019-11-01
2019-11-29 2019-10-23
2014-06-25
2017-05-10 2019-12-30 2019-08-23 2019-08-09 2019-10-04 2019-12-28 2019-09-09
2018-01-04 2016-12-02 2019-12-29 2014-10-21
2017-12-14 2018-02-14
2018-12-26 2014-11-11 2019-11-25

obit_dod
2019-08-10
2018-09-17 2015-05-18 2019-11-05 2019-06-18
2019-08-03
2018-06-30 2014-06-25 2018-09-27 2017-05-10
2019-08-23 2019-08-09 2019-10-04
2019-09-09 2017-04-27 2018-01-04
2018-05-25
2018-02-14 2017-02-05
2014-11-11 2019-11-25

Exhibit B, Page 191

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 192 of 352 Pageid#: 1095

voter_id

lname

32815513 M

409019679 M

303001596 M

703012097 M

920411774 M

919919839 M

906011895 M

919312135 M

213736391 M

302029015 M

919082042 M

413003725 M

805010667 M

113005539 M

222021387 M

917645918 M

603020558 M

205022980 M

919568610 M

738944715 M

259481254 M

702021405 M

502019733 M

204012475 M

123004860 M

504031863 M

128049585 M

405031900 M

123010115 M

301032885 M

919350085 M

702013886 M

501033692 M

fname VICKEY MARGARET KENNETH HAROLD ERIC FELIKS PAUL RODOLFO SEVELINA FRED JOSEPH JULIA PETER WAYNE LARA DAISY SHIRLEY CAROL HERMAN EILEEN MARY WILLIE ROSCOE JACQUELYN WILBUR MEMPHIS LEONA LOUISE FRANCES JOHN NITTAYA KENNETH GEORGE

dob 1948 1945 1942 1925 1973 1934 1927 1941 1948 1945 1960 1944 1951 1944 1919 1935 1947 1945 1936 1937 1928 1942 1953 1944 1929 1953 1935 1931 1940 1934 1943 1940 1930

date_registered 2015-11-06 1988-07-28 1983-08-31 1984-08-16 2006-12-06 2004-09-27 1973-10-06 2002-04-25 2008-07-30 1991-04-18 2001-11-16 2005-05-16 2014-12-03 1991-07-10 1999-09-13 1996-09-11 1976-10-02 1993-09-27 2003-08-07 2008-07-18 2012-08-08 1981-08-03 1984-04-02 1972-10-07 1964-08-04 1991-07-17 2007-12-17 1952-10-03 1999-08-16 1980-10-04 2002-06-25 1979-09-25 1964-10-05

ssdi_dod 2016-01-22
2019-11-14 2019-08-09 2019-08-06 2015-02-04 2019-12-25 2019-04-28 2018-07-31 2019-12-08 2019-02-16 2019-12-09 2017-01-23 2020-01-14 2019-10-13 2019-02-19
2019-12-26 2019-12-11 2019-11-17 2018-12-18 2018-11-17
2019-11-27 2018-06-21 2019-02-05 2019-06-23 2018-01-19
2018-08-12 2019-10-09

obit_dod 2018-12-03 2019-11-14 2019-08-09
2019-12-09
2019-02-19 2019-10-09 2019-09-17 2019-03-05
2019-11-17 2018-12-18 2018-11-17 2018-12-11 2019-11-27 2018-06-21 2019-06-23 2018-02-19 2019-10-09

Exhibit B, Page 192

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 193 of 352 Pageid#: 1096

voter_id

lname

449259686 M

402020901 M

809007352 M

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503009667 M

510009323 M

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1814656 M

102027583 M

306047170 M

225001826 M

172785571 M

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502010010 M

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30923689 M

553447462 M

81582965 M

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106025715 M

615703407 M

503006427 M

108003303 M

907003836 M

303031528 M

691424653 M

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301026102 M

fname MARIE LOIS JO ANN RUTH HAROLD PEGGY JERRY JERRY DORA PHYLLIS NANCY EUGENIA ELEANOR JOSEPH ANN JANET SUE KENNETH EFFIE YVELYNE PATRICIA LYNDA MANARD BILLISUE DONALD MARIAN LIESELOTTE DIANE BESSIE ORLAND MILFORD JOSEPH JOSE

dob 1918 1936 1942 1924 1938 1970 1952 1938 1932 1945 1946 1929 1926 1938 1925 1941 1941 1943 1932 1925 1950 1948 1942 1944 1939 1930 1933 1933 1935 1919 1938 1929 1933

date_registered 2010-04-12 1988-02-06 1997-11-05 2016-03-21 1961-10-22 1988-09-26 2000-05-18 1984-09-08 2014-06-11 1998-05-22 1980-06-11 1975-11-28 2012-10-15 2003-07-17 2000-06-14 1968-09-12 1994-09-21 2012-10-09 2009-11-04 2011-11-15 1993-10-02 2005-06-20 1987-04-21 1973-10-05 1976-09-28 2017-10-05 1981-10-02 1971-09-20 1980-10-04 1975-10-02 2008-05-10 2000-09-27 1976-09-16

ssdi_dod 2018-12-05
2017-08-17
2018-12-30 2018-12-30 2018-04-16
2019-12-09 2019-11-25 2019-11-13 2014-12-19
2019-08-04
2019-10-12
2015-02-09
2019-08-05 2018-12-28 2019-10-16 2018-12-14
2019-11-19 2019-09-17 2019-09-08
2018-06-21 2019-10-19 2019-11-06

obit_dod
2019-08-18 2017-08-17 2019-08-05 2018-12-30
2017-11-29
2019-11-25 2019-11-13
2018-12-18 2019-08-04 2019-06-08 2019-10-12 2019-09-20 2019-03-03
2017-03-21 2019-08-05 2018-12-28 2019-10-16 2018-12-14 2019-10-01 2019-11-19 2019-09-17 2019-09-08 2019-08-06 2018-01-25
2019-10-19 2019-11-06

Exhibit B, Page 193

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 194 of 352 Pageid#: 1097

voter_id

lname

919008611 M

701008487 M

22017469 M

107001306 M

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505005676 M

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387727483 M

404000278 M

604015744 M

194875469 M

223014550 M

917454332 M

920333066 M

919566471 M

241852059 M

909001052 M

206011315 M

207007662 M

203024846 M

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612008388 M

601024104 M

918583839 M

306042592 M

919789864 M

502007165 M

508002702 M

905004495 M

304006623 M

917366623 M

405030484 M

fname KISHA JUANITA DELORES REBECCA SUSAN CONSTANCE DONALD BERTHA BILLY DARLENE WARWICK ELLEN MARY ROSE GORDON NINA JAMES HENRY ARTHUR DORIS RUTH FLORENCE RALPH MERLE DEBORAH PATRICIA SANDRA BERNICE KATHY FRED RUTH WILLIE FRANCES

dob 1981 1933 1943 1926 1953 1935 1932 1927 1926 1943 1943 1953 1935 1925 1930 1936 1953 1944 1939 1939 1952 1915 1937 1931 1954 1944 1939 1942 1956 1944 1927 1934 1932

date_registered 2000-11-08 1964-10-01 1968-07-10 1949-04-28 1997-02-18 1987-10-03 1964-02-05 1950-11-08 2009-09-30 1997-12-11 2001-03-22 2012-09-20 1969-08-27 1996-04-08 2006-08-01 2003-08-04 2018-10-13 1992-09-17 1980-09-09 1967-10-06 1972-10-03 2004-01-12 1996-07-18 1964-08-06 1999-09-15 1983-09-10 2005-12-27 1997-11-05 1984-10-05 1982-09-27 2006-10-02 1995-10-10 1964-02-10

ssdi_dod 2018-10-27 2019-11-19 2019-12-24 2019-11-06 2019-10-16 2018-09-07 2018-05-25 2017-12-15 2014-04-22
2019-12-13 2019-11-27 2019-11-24 2019-11-18 2019-11-13 2019-11-03 2019-10-03 2019-08-24 2019-08-20 2017-07-31 2015-06-22 2015-01-08
2019-11-04 2016-07-05
2020-01-29 2020-01-22 2020-01-14 2020-01-06 2019-12-27 2019-12-26 2019-12-05

obit_dod 2018-10-27 2019-11-19
2019-11-06
2018-09-07
2019-08-01 2019-12-13 2019-11-27
2019-11-13 2019-11-03
2019-08-24 2019-08-20 2017-07-31 2015-06-22 2015-01-08 2016-09-03 2019-11-04 2016-07-05 2019-09-10
2019-12-26 2019-12-05

Exhibit B, Page 194

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 195 of 352 Pageid#: 1098

voter_id

lname

609020835 M

917017881 M

808015395 M

918760049 M

101008021 M

917062127 M

46367916 M

917197569 M

545629503 M

801002394 M

908013077 M

309051641 M

918589559 M

24009773 M

134142460 M

702015245 M

308018569 M

919752780 M

919276663 M

124014336 M

602020338 M

917430503 M

651507499 M

917831545 M

807020435 M

920095998 M

518845645 M

606000842 M

917850864 M

604022055 M

919608493 M

612023885 M

708023247 M

fname RUBY GREGORY THELMA RAMONA EDDIE LARRY WILLIAM BOBBY GLORIA JUDY JOAN THOMAS MARGARET WINIFRED LYNETTE EMMA VERNON GEORGE MICHAEL LARRY JAMES WILLIAM ROBERT HENRY CLEARIN CONNIE CURTIS RUTH CYNTHIA VELMA ESSIE JOHN JAMES

dob 1925 1956 1924 1947 1932 1952 1938 1935 1925 1949 1932 1947 1929 1923 1958 1941 1959 1935 1968 1938 1937 1941 1931 1964 1929 1960 1977 1929 1959 1926 1933 1956 1939

date_registered 1991-05-13 2010-10-08 1948-05-05 2005-07-29 1968-09-21 1993-12-06 2017-06-19 2000-01-04 2018-08-13 1987-02-09 1958-04-23 1988-10-08 1999-09-21 1955-12-07 2014-06-18 1962-10-01 1986-09-23 2004-04-23 2002-02-22 1999-07-29 1993-10-02 1996-03-25 2017-10-09 2005-06-15 1963-10-04 2005-04-29 2008-10-06 1999-04-08 1996-12-18 1960-10-06 2003-10-06 1999-03-19 1987-05-06

ssdi_dod 2019-11-28 2019-11-06 2019-11-03 2019-10-21 2019-10-12 2019-09-22 2019-09-20 2019-09-05 2019-08-27 2019-08-22 2019-08-11 2019-08-11 2019-08-03 2019-07-19 2019-06-28 2019-06-27 2019-05-15 2019-04-02 2019-03-26 2018-12-26 2018-12-15 2018-12-15 2018-12-10 2018-12-05 2018-10-19 2018-07-08 2018-05-14 2018-03-31 2017-12-08 2017-09-30 2017-05-14 2016-11-07 2016-05-29

obit_dod 2019-11-28 2019-11-06 2019-11-03 2019-10-21 2019-10-12
2019-09-20 2019-09-05 2019-08-27 2019-08-22 2019-08-11 2019-08-11 2019-08-03 2019-07-19 2019-06-28
2019-04-02 2019-03-26 2018-12-26
2018-10-19 2018-07-08 2018-05-14 2018-03-31 2017-12-08 2017-09-30
2016-11-07

Exhibit B, Page 195

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 196 of 352 Pageid#: 1099

voter_id

lname

807017395 M

80573989 M

23015523 M

207017569 M

408008691 M

106003590 M

804008386 M

607022054 M

209019797 M

303016073 M

290153849 M

918576486 M

702000797 M

917116411 M

305007118 M

920335339 M

98446617 M

918617003 M

479066232 M

92939403 M

918860842 M

919057490 M

304030278 M

895691625 M

782087299 M

801008757 M

114638260 M

809012327 M

208020183 M

917545367 M

403033378 M

9579143 M

805010241 M

fname MARGARET JUDITH PEARL CHARLES NANCY BRENDA LYNAL BELLE JAMES LULU FLORENCE BETTY RUTH RAWLEN LARRY OLGA PEDRO CARMEN EVERARDO MARY ALFREDO MARIA LUISA YVONNE LOUIS HILDA JESSE DOUGLAS WILLIAM MARJORIE JACQUELINE ROBERT DANIELLE JAMES

dob 1932 1949 1922 1945 1942 1948 1940 1929 1938 1938 1948 1939 1937 1947 1942 1929 1944 1932 1942 1948 1938 1950 1947 1926 1917 1941 1934 1933 1942 1960 1932 1985 1944

date_registered 1966-05-04 2010-11-18 1955-04-18 1973-09-18 1999-03-15 1979-10-06 2004-12-02 1967-10-07 1980-09-15 2002-01-15 2008-05-02 1999-09-08 2013-01-16 1994-05-06 2005-11-22 2006-08-04 2008-07-14 1999-11-03 2014-05-22 2011-03-16 2000-08-16 2001-03-09 2005-09-28 2014-01-14 2012-10-15 1968-10-05 2016-01-29 1960-10-07 1981-10-03 2001-07-16 1991-10-02 2018-07-09 1984-04-23

ssdi_dod 2015-05-19 2014-10-19 2014-01-25
2019-12-01 2019-10-11 2019-08-12 2019-12-11
2018-10-15 2018-08-27 2015-05-08 2017-05-07 2020-01-11 2019-11-07 2019-10-20 2019-10-16 2019-08-19 2019-07-14 2019-03-21 2018-09-03 2017-11-17

obit_dod 2015-05-19
2019-12-18 2019-10-18 2019-10-08 2019-10-03 2019-09-01 2019-08-17 2019-08-04 2019-05-13 2018-12-01 2017-03-26 2016-05-28 2019-09-19 2019-12-01
2019-08-12
2016-10-28 2018-10-15 2018-08-27
2017-05-07
2019-11-07 2019-10-20 2019-10-16 2019-08-19 2019-07-14 2019-03-21 2018-09-03 2017-11-17

Exhibit B, Page 196

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 197 of 352 Pageid#: 1100

voter_id

lname

189816732 M

806008006 M

606033304 M

209020506 M

918917067 M

920128837 M

507025010 M

22012521 M

230009110 M

304754860 M

101005935 M

918926619 M

406026416 M

702013538 M

232006730 M

602010179 M

306038420 M

917061963 M

814002018 M

538722990 M

301022722 M

919538135 M

56614308 M

29011485 M

405021771 M

650551153 M

920300470 M

190161262 M

608010947 M

918941748 M

120346422 M

509009466 M

209001209 M

fname WALLACE HARM PAIGE LINDA BEVERLEY ELEANOR NAOMI JULIA CLAYTON HARRY HANSFORD SUSAN SHERMAN BILLY JOSEPH ANTONIO NICHOLAS REGALADO WILLIAM DOROTHY HILDEGARD JEAN EDATHUMPADICKAL JOSEPH MARIE LYLE ROBERTA BONNIE MARCIA KAILASH HARISH ANITA RUBY

dob 1949 1929 1930 1947 1946 1938 1926 1918 1961 1926 1919 1938 1935 1934 1933 1935 1930 1924 1968 1947 1921 1920 1938 1928 1938 1939 1939 1927 1929 1931 1941 1948 1935

date_registered 2015-02-05 1976-10-02 1979-05-11 1988-08-27 2000-10-02 2005-07-07 1987-06-01 1955-12-27 1988-08-23 2016-10-21 1947-05-02 2000-10-06 1968-09-11 1967-10-06 1989-10-04 1993-08-11 1998-07-31 1998-01-30 1996-08-29 2016-11-22 1976-07-22 2003-06-17 2010-06-25 1968-10-05 1999-07-16 2014-02-07 2006-05-15 2016-03-04 2003-11-05 2000-10-10 2018-11-14 1988-08-18 1999-09-28

ssdi_dod 2016-09-03 2016-02-25 2014-11-04
2018-02-22 2016-12-21 2020-01-02 2019-08-21 2019-06-03 2010-04-14 2019-09-01
2019-06-10
2012-12-17 2019-08-12 2018-05-11 2016-02-03 2019-12-28 2018-10-07 2019-11-15 2018-12-10
2017-12-01
2019-01-20 2019-11-26 2019-11-25 2019-08-22 2019-12-16

obit_dod 2016-09-03
2014-11-04 2018-12-19 2018-08-31 2018-02-22
2019-06-03 2010-04-14 2019-09-01 2019-08-14 2019-06-10 2019-04-18 2015-10-04 2019-08-16
2019-08-12
2018-12-10 2019-08-11 2017-12-01 2019-09-03
2019-08-22 2019-12-16

Exhibit B, Page 197

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 198 of 352 Pageid#: 1101

voter_id

lname

918214567 M

918521485 M

561986842 M

908021140 M

607003330 M

17420712 M

410016206 M

917315122 M

265694531 M

307043656 M

602008659 M

37154921 M

920026189 M

506022428 M

2001043 M

402005431 M

1520399 M

919820914 M

222026137 M

126002040 M

407021243 M

406024562 M

24013124 M

124001599 M

919834016 M

32009320 M

801008553 M

121017522 M

689521031 M

4001044 M

917210362 M

608005921 M

808004699 M

fname GEORGIA RALPH JOHN BARBARA PAMELA ROBERT GEORGE CHRISANDRA GARY SYLVIA ANNE E MARIA RICHARD JAMES DENNIS JEAN BETTY SANN RUBY CONNIE WILLIAM RONALD ROBERT JOHN DORIS JUDY SARA ALTON SAUL CHRISTINE FANNIE EDITH SHERRY

dob 1929 1939 1941 1931 1957 1947 1947 1947 1939 1941 1945 1940 1955 1921 1946 1932 1933 1936 1923 1944 1928 1930 1941 1928 1927 1944 1933 1929 1932 1925 1944 1927 1962

date_registered 1998-03-04 1999-06-14 2016-12-09 1957-01-23 1997-06-17 2012-03-29 1988-09-20 1995-08-29 2013-10-04 1980-10-01 1974-01-25 2011-08-30 2004-11-24 1952-09-03 2006-11-20 1970-04-27 2016-09-08 2004-08-02 1997-06-11 2006-06-29 2000-01-31 1956-10-05 1968-05-11 1988-03-23 2004-08-11 1998-09-10 1976-08-27 1988-11-09 2017-09-22 1952-10-01 1994-10-10 1956-04-27 1992-09-18

ssdi_dod 2019-08-12
2019-12-14 2019-10-30 2019-10-23 2019-06-04
2019-11-05 2020-01-14 2019-08-19 2019-08-13 2018-05-24 2017-11-27 2016-08-28
2019-10-28 2019-10-06 2020-01-01 2019-08-26 2016-06-29
2018-12-14 2019-11-06 2019-09-26 2019-12-14 2019-10-24 2016-10-16

obit_dod 2019-08-12 2018-07-13 2019-12-14
2019-10-23 2019-06-04 2019-10-21 2018-12-17 2017-10-30 2017-01-28 2019-08-03 2018-12-08 2019-11-05
2019-08-13 2018-05-24
2016-08-28 2018-12-01 2019-09-02 2019-10-28 2019-10-06
2019-08-26 2016-06-29 2019-08-26 2018-12-14 2019-11-06 2019-09-26 2019-12-14 2019-10-24

Exhibit B, Page 198

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 199 of 352 Pageid#: 1102

voter_id

lname

122009597 M

124020656 M

366493733 M

917388685 M

5006643 M

920323636 M

801017148 M

541236387 M

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308014303 M

405025481 M

903478203 M

123005046 M

202015233 M

613003774 M

917874783 M

908004184 M

506001007 M

807002638 M

202013328 M

205001337 M

918160134 M

918398865 M

920342937 M

917290277 M

702026972 M

309852077 M

917371857 M

920384612 M

102020320 M

918791134 M

181546427 M

33009508 M

fname EMMA PAULETTE LOUIS WAYNE JAMES DREMA JEAN MARY JOE CHERYL PAUL ALICE LESLIE HOWARD CHARLOTTE MARY MICHEAL NANCY DORIS RAYMOND ERMA CONSTANCE CYNTHIA WILLIAM ROY WANDA LAURA LILLIE KENNETH SANDRA LINDA IRIS ROSA

dob 1930 1948 1954 1946 1932 1960 1938 1955 1942 1946 1922 1937 1942 1941 1920 1946 1941 1929 1935 1918 1936 1942 1966 1919 1944 1947 1943 1933 1932 1937 1948 1942 1922

date_registered 1961-05-04 1990-03-08 2016-02-08 2006-11-20 1960-07-14 2006-07-11 1975-09-09 2016-01-14 1997-04-30 2001-09-07 1968-09-04 2007-03-27 1980-10-10 1970-02-25 1955-04-21 1997-01-16 1984-09-25 1982-05-03 1960-03-03 1971-09-29 1969-10-02 1997-12-05 1999-11-24 2006-08-17 1995-05-26 1999-04-27 2008-04-30 1995-10-10 2006-10-10 1964-05-01 2000-05-26 2012-09-12 1992-09-23

ssdi_dod 2019-08-17 2018-12-22 2018-10-31
2019-12-05 2019-05-06 2019-11-29 2019-06-22 2016-11-25 2014-11-23 2019-11-03 2019-05-16 2018-12-26 2018-03-25 2015-09-27
2019-09-29 2018-12-31 2017-12-24
2016-04-06 2019-07-10 2019-08-23 2020-01-17 2018-01-28
2019-12-04 2013-12-27 2019-12-05 2019-09-04 2019-12-01

obit_dod
2018-12-22 2018-10-31 2018-12-05 2019-12-05 2019-05-06
2019-06-22
2019-11-03
2018-03-25 2015-09-27 2017-06-29 2018-01-30 2019-09-29 2018-12-31 2017-12-24 2018-09-23 2016-04-06 2019-07-10 2019-08-23
2018-01-28 2019-09-28 2019-09-20 2019-12-04
2019-09-04 2019-12-01

Exhibit B, Page 199

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 200 of 352 Pageid#: 1103

voter_id

lname

207000463 M

229011700 M

113025979 M

222010628 M

402036246 M

709028215 M

253269011 M

917533626 M

707012099 M

124002042 M

210012822 M

918130254 M

107012369 M

918273191 M

602028559 M

917575866 M

908018824 M

103015145 M

1453961 M

919044322 M

920101493 M

126013752 M

303016609 M

306025208 M

828112689 M

917356394 M

103983257 M

705016811 M

204015742 M

305022726 M

920249736 M

3948373 M

410022269 M

fname ELIZABETH SUZANNE ANNIE VIRGINIA GEORGIANA RICHARD GLORIA RUFUS MICHAEL JAMES VERENA HELEN ARLENE PEARL RALPH MARY JAMES BILLY JUSTIN SHARON JOHNNY MICHAEL HELEN HENRY PENNY LEON WILLIAM JOHN JANET HARLEY THOMASINE JOSEPH MAMIE

dob 1917 1950 1940 1921 1942 1934 1956 1946 1950 1935 1946 1931 1941 1948 1950 1930 1932 1935 1991 1961 1937 1953 1940 1924 1952 1938 1948 1939 1943 1922 1940 1929 1948

date_registered 1936-07-04 1988-09-12 1999-08-13 1963-12-16 1992-11-04 1962-06-04 2015-04-13 1996-06-27 1983-10-07 2004-08-30 1981-10-03 1997-11-06 1973-05-05 1998-05-28 1971-08-11 1996-07-30 1999-08-17 1986-06-16 2010-05-11 2001-02-09 2005-05-12 1987-09-10 2001-11-28 1979-05-05 2014-08-11 1995-10-06 2019-07-22 1980-09-24 1981-09-25 1984-10-06 2006-02-08 2011-03-29 1989-06-14

ssdi_dod 2020-01-05 2018-12-31
2018-12-24 2019-08-27 2019-11-10 2017-12-24 2019-09-25 2019-09-16 2019-05-16
2009-10-24
2018-04-19 2017-11-28
2019-10-14 2020-01-09 2019-01-05 2018-06-21
2018-11-16 2019-11-29
2019-09-17 2018-12-17
2015-11-30
2017-02-16 2019-04-28
2017-11-21

obit_dod
2018-12-31 2019-10-28 2018-12-24 2019-08-27 2019-11-10 2017-12-24
2019-10-30 2009-10-24 2017-12-31
2017-11-28 2019-01-19 2019-10-14
2019-01-05 2018-06-21 2019-08-06
2019-11-29 2019-09-20
2019-10-01
2019-02-03 2017-02-16 2019-04-28 2018-05-07

Exhibit B, Page 200

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 201 of 352 Pageid#: 1104

voter_id

lname

919218179 M

111022625 M

114022391 M

736822257 M

193758484 M

506016515 M

203009095 M

803010246 M

610028509 M

603028972 M

919240575 M

602028722 M

918099508 M

710010016 M

917526226 M

920270068 M

194482772 M

222006735 M

307041377 M

919704851 M

813006747 M

917569058 M

905011134 M

918287034 M

705009734 M

306004645 M

305042951 M

406004441 M

534536542 M

204007664 M

205009095 M

391374844 M

909009648 M

fname ROBERT POLLY GARY OLIVIA DONALD FELICIA JUNE MATTIE HJ WANDA JOE JOE JOHN MARY ALETHEA DAVID BERTHELIA LILLIAS FAITH WENDELL MICHAEL LESTER CLARA ROBERT MARTHA WILLIAM DONNA EMILY STEPHANIE LINWOOD BERNARD DETROY VALENCIA

dob 1932 1932 1949 1943 1940 1960 1940 1924 1945 1937 1941 1939 1943 1935 1952 1947 1948 1934 1947 1928 1947 1948 1927 1947 1934 1935 1942 1933 1956 1949 1934 1975 1960

date_registered 2001-11-07 1999-11-08 1984-10-02 2007-07-11 2016-10-21 1992-04-30 2003-12-29 1984-09-12 1979-08-23 1960-09-19 2001-12-05 1963-10-05 1997-09-23 2006-06-15 2000-01-07 2006-03-23 2015-10-13 1971-08-24 1980-10-03 2004-03-08 1992-10-03 1996-07-25 1976-09-30 2003-11-05 1992-01-31 2001-07-27 1984-10-06 1968-08-26 2008-07-10 1980-08-06 1991-08-15 2008-04-07 2005-08-19

ssdi_dod
2019-12-28 2015-11-18 2019-11-06 2018-12-20 2017-12-17
2018-12-15 2019-07-13 2017-11-28 2017-08-24 2017-04-20 2019-11-21 2019-08-30 2019-03-12
2019-10-18 2017-11-24 2017-04-02 2019-12-17 2019-11-05 2016-05-10
2019-09-16
2019-12-25 2018-12-25 2018-03-27 2018-02-27 2019-10-11 2019-04-25 2018-12-16

obit_dod 2019-10-04 2019-12-28
2019-11-06
2017-12-14 2019-10-07 2018-12-15
2017-11-28
2017-04-20
2019-08-30 2019-03-12 2019-08-06 2019-10-17
2019-12-17 2019-11-05 2016-05-10 2019-08-30 2019-08-30 2019-09-16 2019-09-14
2018-12-25 2018-03-27 2018-02-27
2019-04-25 2018-12-16

Exhibit B, Page 201

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 202 of 352 Pageid#: 1105

voter_id

lname

918226570 M

803016717 M

208019445 M

919131903 M

919634893 M

917272877 M

104006274 M

918733516 M

27003048 M

22006917 M

127020279 M

502022756 M

607028725 M

650947267 M

224005794 M

917496588 M

609016341 M

917061350 M

919633224 M

635094016 M

26009509 M

305008200 M

709009134 M

917048929 M

848027673 M

807009800 M

919017433 M

225013036 M

609027886 M

753513648 M

502015546 M

918890377 M

306013964 M

fname DANIELLE VIRGINIA KINSLEY NADINE ROBNETT ANGELIA BETTY MONA LAUREESE SYBIL HELEN CARL HELEN MARY ANDREW BETTY HAROLD JOAN MARY THOMAS ROBERT MARLENE JAMES MARGARET LUCILLE EVELYN RANDOLPH THERESA NANCY ALBERTA DENNY EDWIN OLIVIA

dob 1973 1926 1956 1968 1948 1976 1947 1937 1944 1933 1933 1930 1923 1927 1922 1932 1930 1949 1939 1954 1939 1935 1936 1925 1929 1939 1935 1941 1941 1946 1949 1943 1942

date_registered 1998-03-21 1955-10-08 1999-11-02 2001-06-28 2003-11-14 1995-04-24 2009-01-20 2000-03-24 2004-11-03 1960-09-19 2002-08-30 1960-10-04 1964-10-03 2007-07-17 1988-07-27 2004-09-08 1990-08-14 1993-11-30 2003-11-18 2007-10-04 1980-03-14 1984-10-05 1991-10-05 1998-12-14 2015-06-18 1986-12-01 2001-01-09 1999-04-15 1967-10-07 2008-09-22 1981-10-03 2000-08-31 1984-07-09

ssdi_dod 2018-12-05 2019-10-06 2019-08-08 2017-01-25
2018-02-25 2016-04-10 2014-02-13 2011-03-09 2019-09-27 2017-03-30
2019-12-09 2019-12-01 2017-12-02 2020-01-21 2018-12-27 2019-11-13 2019-09-28 2017-12-21
2018-12-02
2019-11-24 2019-08-13 2019-12-20 2018-06-18 2018-06-01 2018-01-07 2019-09-17 2016-12-31 2019-08-08

obit_dod
2019-10-06 2019-08-08
2017-05-21 2018-02-25 2016-04-10 2014-02-13 2011-03-09 2019-09-27 2017-03-30 2019-10-06 2019-12-09 2019-12-01 2017-12-02
2018-12-27 2019-11-13 2019-09-28 2017-12-21 2019-08-05 2018-08-29 2018-12-02 2019-06-19
2019-08-13
2018-01-07 2019-09-17
2019-08-08

Exhibit B, Page 202

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 203 of 352 Pageid#: 1106

voter_id

lname

110025235 M

104025329 M

785782343 M

712014331 M

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225010632 M

249510110 M

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407014249 M

708013333 M

707011753 M

82208935 M

705007975 M

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408011403 M

438045101 M

233017291 M

917782929 M

918083716 M

613816293 M

407029025 M

187687418 M

917921322 M

703025451 M

201024235 M

124000780 M

703002164 M

221009117 M

602017658 M

409004801 M

901020453 M

918563678 M

fname WAYNE MAVIS EUGENE HAROLD LAURA JEAN JOHN ROSE CALVIN CAROLYN VICKY JAMES MARIE LEDA MARY RICHARD SCOTT JACQUELINE CAREY MARILYN KAREN MELVIN MARY PEGGY WILLIAM PHILLIP CAROL LAVONNE GERTRUDE BETTY HELEN WILLIAM ALTON

dob 1959 1945 1933 1942 1952 1931 1940 1915 1936 1934 1948 1922 1924 1935 1931 1936 1964 1936 1945 1930 1943 1941 1929 1949 1940 1948 1942 1945 1924 1935 1940 1939 1941

date_registered 2001-07-06 1968-09-25 2007-09-07 1992-09-21 1993-08-23 1968-04-01 1964-08-25 2011-07-26 2008-08-11 1959-05-06 1996-11-15 1966-05-14 2012-06-15 2003-10-03 2005-08-25 1974-10-05 2011-03-02 2006-03-03 2007-01-11 1997-08-24 2014-06-19 1981-10-03 2016-07-26 1997-02-18 1980-07-19 1970-08-08 1982-08-05 1980-10-04 1968-10-05 1972-03-15 1967-05-26 1972-01-31 1999-08-19

ssdi_dod 2018-12-18 2019-12-17 2019-11-30 2020-01-28 2019-10-03 2020-01-25 2019-10-16 2018-10-09
2019-12-04
2019-07-28 2016-05-26 2020-01-09 2020-01-22 2019-01-31 2019-09-19 2018-05-14 2019-10-17 2018-01-09 2015-03-08 2018-07-19 2020-01-24 2019-10-07
2019-11-07 2019-07-19 2019-11-19 2016-10-23
2019-10-02 2018-12-23 2018-02-24

obit_dod
2019-12-17 2019-11-30
2019-10-03
2018-10-09 2018-12-22 2019-12-04 2019-05-25 2019-07-28 2016-05-26
2019-01-31 2019-09-19
2015-03-08 2018-07-19
2019-10-02
2019-07-19 2019-11-19 2016-10-23 2016-10-17 2019-10-02 2018-12-23 2018-02-24

Exhibit B, Page 203

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 204 of 352 Pageid#: 1107

voter_id

lname

302045778 M

264629103 M

806007585 M

919897672 M

206589815 M

539126970 M

303013967 M

408014627 M

225013777 M

307012486 M

110856400 M

108006051 M

230017949 M

805004702 M

227006738 M

917554589 M

920221687 M

918311114 M

917696598 M

12854533 M

225006738 M

906020127 M

704000332 M

702026098 M

917213538 M

302035687 M

114006454 M

302039242 M

608032938 M

502020218 M

920087313 M

919923126 M

10223741 M

fname BENNY RUTH CLAUDIA BARBARA VIRGIL KODY ELSIE CHARLES LONNIE MICHAEL TOMMY MAI JOHN CURTISTEEN PATRICIA WILLIAM PATRICK BERNADINE HELEN MARY ANNE MARIE CHARLES WILL ELWOOD JANET JANE PATRICK DONNA THOMAS TERRY WILLARD JOYCE

dob 1935 1939 1952 1952 1940 1993 1922 1927 1926 1939 1945 1947 1943 1941 1947 1947 1958 1943 1928 1944 1928 1925 1928 1944 1956 1926 1931 1940 1948 1937 1965 1943 1942

date_registered 1998-12-17 2016-11-29 1984-10-06 2004-09-20 2007-09-26 2011-05-20 1966-10-01 1955-12-28 1987-08-07 1988-07-02 2008-07-22 1997-01-22 1991-07-17 1976-07-23 1988-09-26 1996-07-05 2005-12-02 1998-07-27 1996-09-27 2018-02-05 1972-07-06 1968-10-05 1999-08-05 1976-06-10 1994-10-06 1952-04-30 1988-09-02 1984-09-22 1991-06-19 1984-08-28 2006-06-21 2004-09-27 2014-04-03

ssdi_dod 2017-05-05 2018-09-18 2019-12-02 2019-09-08 2019-08-15 2018-12-22 2018-12-17
2019-11-25 2019-09-12 2019-10-16 2016-05-18 2020-01-05 2019-10-02
2019-11-21 2018-10-23 2018-04-09 2015-07-25 1998-05-21
2020-01-12 2019-12-06 2019-11-17
2020-01-21 2018-08-27 2019-09-01 2018-12-06 2019-04-18 2018-03-18 2019-05-09

obit_dod
2018-09-18 2019-12-02 2019-09-08 2019-08-15 2018-12-22
2019-09-28 2019-11-25 2019-09-12 2019-10-16 2016-05-18
2019-10-02 2014-02-24
2018-10-23
2019-08-22
2019-12-06
2018-12-28 2013-01-30
2018-08-27 2019-09-01 2018-12-06 2019-04-18
2019-05-09

Exhibit B, Page 204

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 205 of 352 Pageid#: 1108

voter_id

lname

117878963 M

206007490 M

501022574 M

804011344 M

809020564 M

911020128 M

255669706 M

224010997 M

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605028233 M

906018273 M

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145404455 M

243493175 M

982590189 M

225004930 M

918685592 M

918757886 M

506029811 M

203022414 M

227018870 M

917856150 M

905004192 M

917926021 M

917333926 M

369814811 M

305042956 M

412023236 M

809000807 M

919316720 M

917084108 M

307043376 M

604028288 M

fname ALICIA CONNIE GLENN KATHLEEN PHYLLIS JACK MONTREAL JOHN DELOY LOIS JAMES WILLIAM SARAH JOHN JAMES DORRIS RICHARD FREDERICK PALMER MARY CLARENCE ROBERT REVA NANCY BETTE AUDREY CAMERON HARVEY JUDITH PATTY CAROLYN MARGUERITE RONALD

dob 1964 1926 1944 1928 1933 1934 1983 1943 1942 1949 1944 1948 1941 1944 1953 1919 1960 1936 1924 1927 1951 1933 1936 1948 1941 1924 1933 1936 1942 1943 1956 1925 1941

date_registered 2016-03-08 1947-11-22 1975-04-17 1981-09-22 1992-08-21 1989-09-28 2016-10-17 1985-04-18 1999-06-29 1983-04-04 1968-06-08 1997-04-01 2007-11-12 2007-08-31 2008-02-13 1941-06-11 2000-08-18 2000-04-21 1984-09-21 1971-09-07 1984-03-26 1996-11-15 2006-02-02 2002-03-20 1995-09-22 2017-04-25 1972-09-21 1988-10-08 1989-04-24 2002-05-06 1994-03-15 1988-03-19 1979-10-06

ssdi_dod 2018-10-17 2017-07-08 2019-10-21 2017-03-23 2019-10-13 2019-10-05 2018-01-23 2018-10-15
2017-10-01 2018-01-19 2016-10-05 2019-11-28 2018-01-12 2018-07-19 2018-07-06 2017-08-05 2020-01-02 2019-03-27 2019-10-17 2019-05-24 2018-10-26
2018-12-08 2020-01-06 2017-11-30 2019-08-14 2018-09-23 2018-12-11
2019-12-17

obit_dod
2017-07-08 2019-10-21 2017-03-23 2019-10-13 2019-10-05
2018-10-15 2019-02-16 2017-10-01
2018-01-12
2018-07-06
2019-10-17 2019-05-24 2018-10-26 2019-09-03 2019-07-17 2017-07-10
2017-11-30 2019-08-14 2018-09-23
2018-12-21 2019-12-17

Exhibit B, Page 205

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 206 of 352 Pageid#: 1109

voter_id

lname

302032112 M

917494263 M

702012459 M

919869433 M

708015251 M

204014338 M

406003729 M

208013594 M

919068215 M

905009037 M

703008495 M

917564133 M

705011928 M

307025919 M

103000745 M

919285629 M

509024619 M

204020875 M

106021486 M

228008233 M

147750302 M

502010694 M

304023615 M

688061745 M

867615603 M

83495742 M

224013042 M

501003022 M

919161330 M

917698885 M

229018327 M

445002564 M

687100947 M

fname LOUISE CHAD LARRY ROBERT BEULAH CHRISTINE JOHN BONNIE KELLENA LELIA ANDY KENNETH SONJA CHARLOTTE STELLA MYUNG MARY HELEN RONALD BRUCE ORLANDO ARTHUR VIRGINIA ALBERT MARY CHESTER GENE CLYDE BARBARA CATHERINE JAMES JERALD AUSTIN

dob 1934 1974 1940 1963 1915 1923 1938 1938 1959 1920 1924 1935 1944 1927 1933 1931 1929 1926 1938 1937 1929 1932 1913 1941 1932 1948 1933 1939 1941 1938 1924 1935 1981

date_registered 1958-10-04 1996-04-17 1964-10-04 2004-10-04 1959-10-01 1987-10-01 1975-04-09 1984-08-31 2001-03-26 1956-10-06 1958-12-01 1996-07-18 1982-09-23 1991-03-16 1975-05-07 2002-03-11 1964-09-25 1976-10-02 1982-09-29 1968-09-10 2012-08-14 1955-08-10 1964-10-03 2009-10-14 2008-09-22 2018-07-29 1999-11-10 1998-07-20 2001-08-08 1996-09-18 1974-10-03 2012-10-15 2008-01-04

ssdi_dod 2019-10-01 2019-09-07 2018-01-26 2016-12-06 2015-12-25
2019-12-03 2020-01-14 2019-11-21 2019-10-06 2017-03-14
2020-01-20 2020-01-11 2019-12-01 2018-01-29 2019-09-26 2018-04-25 2019-12-24 2018-12-24 2017-09-19 2005-02-02
2019-12-10 2019-10-29 2019-10-07 2020-01-02 2019-11-08 2019-08-20
2018-12-11 2018-09-10

obit_dod 2019-10-01 2019-09-07
2016-12-06 2015-12-25 2018-10-17 2019-12-03
2019-11-21 2019-10-06 2017-03-14 2019-10-02 2019-05-12
2019-12-01 2018-01-29
2019-12-24 2018-12-24
2005-02-02 2018-10-17
2019-10-07
2019-08-20 2019-09-04 2018-12-11

Exhibit B, Page 206

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 207 of 352 Pageid#: 1110

voter_id

lname

24371392 M

237102905 M

109018312 M

167365567 M

917682085 M

205007726 M

203011329 M

917332594 M

917778576 M

250182704 M

405019180 M

578570137 M

23008669 M

706008298 M

917951527 M

1403434 M

805118955 M

40633311 M

48010157 M

401016470 M

587933328 M

390526542 M

122012975 M

301021757 M

905011442 M

224004298 M

203011928 M

226012677 M

920254669 M

505011551 M

918991355 M

413008961 M

920214264 M

fname VINCENT JABBAR DAVIS PEARL LUDMILA NORMA MARY ELOISE ARTHUR EMMENTT SANDRA LEE FREDA BOBBIE BOBBY JANET LUIS TEOFILO MARTHA DOROTHY JOHN GEORGES CARLA BARBARA ANTHONY KATHLEEN HUGH ANDERSON WILLIAM CAROL GEORGE BRENDA JOHN CHARLES

dob 1931 1933 1929 1926 1923 1939 1933 1929 1927 1944 1943 1958 1950 1931 1952 1934 1931 1935 1933 1932 1936 1972 1935 1944 1927 1916 1935 1931 1944 1934 1944 1941 1949

date_registered 2018-06-19 2012-09-28 1972-09-01 2016-09-22 1996-09-24 1972-10-07 1988-02-05 1995-09-19 1996-10-04 2017-05-22 1981-09-23 2012-06-28 1980-09-26 1984-03-14 1997-04-02 2019-02-11 2008-03-15 2014-06-23 2015-07-01 1986-09-30 2009-01-20 2007-11-07 1972-09-21 2000-09-08 1972-10-06 1960-10-08 1971-06-16 1970-12-07 2006-02-21 1970-09-30 2000-11-28 1988-09-07 2005-11-18

ssdi_dod 2019-11-21 2019-11-15
2017-05-12 2018-04-27 2019-12-08 2019-11-06 2019-08-03 2018-12-12
2019-11-04 2018-12-18 2018-06-14 2016-03-26 2019-08-27 2020-01-04 2018-12-13 2019-11-25 2018-01-25 2019-08-20 2019-09-14
2019-12-10 2019-06-30 2019-06-04 2019-12-29
2018-12-31 2020-01-08 2019-11-28 2020-01-02

obit_dod 2019-11-21
2018-12-10 2017-05-12
2019-12-08 2019-11-06 2019-08-03 2018-12-12 2019-08-07 2019-04-18 2019-11-04 2018-12-18 2018-06-14 2016-03-26 2019-08-27
2018-12-13 2019-11-25
2019-09-14 2018-12-30 2019-10-05 2019-12-10 2019-06-30 2019-06-04 2019-12-29 2019-08-03 2018-12-31
2019-11-28

Exhibit B, Page 207

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 208 of 352 Pageid#: 1111

voter_id

lname

22017704 M

410004238 M

403029328 M

433635278 M

124001815 M

919879334 M

917038610 M

28007606 M

508006442 M

275934577 M

101000976 M

222004934 M

114025375 M

803008211 M

102021116 M

701017736 M

381634199 M

534921933 M

920217155 M

225007040 M

304014319 M

143870714 M

703589155 M

546356481 M

919926656 M

919227651 M

205013100 M

917308159 M

208004782 M

705025460 M

917969505 M

146143344 M

400509202 M

fname WILLIAM KIMBERLY RITA HOWARD JAMES PALMA AUBREY MARGARET JEAN SHIRLEY BEATRICE RUSSELL DONALD MARY BETTY KATHRYN ARLYNE PATRICIA ANN SUN NICHOLAS ARLEEN JEAN ANDREW CHARLOTTE JAMES ADOLPHUS EUGENIA BILLIE DOROTHY IRENE GLADYS MARY MARION

dob 1926 1955 1944 1960 1944 1966 1928 1925 1928 1927 1935 1934 1927 1917 1932 1931 1941 1941 1947 1941 1938 1927 1954 1921 1955 1952 1925 1936 1939 1924 1957 1929 1932

date_registered 1957-11-06 1991-09-12 1999-03-30 2018-04-11 2004-10-04 2004-09-10 1993-09-30 1964-07-23 1992-09-22 2018-01-25 1992-06-04 2006-08-24 1988-10-05 1980-09-10 1960-06-11 1968-08-03 2016-08-25 2016-06-15 2005-11-22 1963-07-19 1998-01-23 2008-08-13 2010-12-02 2012-10-15 2004-09-29 2001-11-15 1967-09-30 1999-08-04 2000-01-31 1990-09-20 2002-09-05 2012-09-24 2016-06-08

ssdi_dod 2019-11-03 2019-11-02
2018-12-11 2017-01-24 2016-07-11
2019-09-06 2019-12-13 2020-01-02 2019-10-19 2019-10-09 2018-12-03 2018-06-18 2019-12-11 2020-01-07 2019-04-22 2016-09-25
2019-11-24
2019-12-23 2016-02-03 2018-04-29 2018-01-21 2018-12-13 2019-08-01 2014-09-27 2019-12-28
2019-09-11 2018-12-10 2016-12-01

obit_dod 2019-11-03
2019-10-20 2018-12-11 2017-01-24
2018-04-17 2019-09-06 2019-12-13
2019-10-09 2018-12-03 2018-06-18 2019-12-11
2016-09-25 2018-01-20
2017-06-30 2019-12-23
2018-01-21 2018-12-13 2019-08-01
2019-10-21 2019-09-11 2018-12-10 2016-12-01

Exhibit B, Page 208

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 209 of 352 Pageid#: 1112

voter_id

lname

917583263 M

919619467 M

694910597 M

607004934 M

918996758 M

204020880 M

406012811 M

107000449 M

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61382414 M

610028559 M

132005736 M

121005250 M

223016524 M

202004998 M

225021916 M

475630177 M

404025857 M

50667640 M

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920151812 M

705000813 M

808004156 M

233011003 M

704008685 M

304039699 M

918364616 M

806004155 M

608024507 M

917644111 M

841710482 M

877584479 M

106020738 M

fname MARCO REBECCA JAMES SAMUEL JANET CHARLES ELLA GREGORY GEORGE RONALD JAMES VICTOR VIRGINIA MCWILBURN JANE LEILA PEGGY FRANK RUTH BEECHER THOMAS LAWRENCE WILLIAM JERRY GLENN WILLIAM CHERIE JOSEPH DONALD CHARLES CAROL HELEN JAMES

dob 1931 1980 1940 1930 1944 1939 1929 1955 1950 1965 1932 1954 1934 1935 1946 1926 1935 1940 1930 1940 1964 1938 1947 1937 1951 1930 1959 1948 1935 1962 1940 1927 1928

date_registered 1996-08-01 2003-11-06 2007-10-02 1955-04-12 2000-12-05 1977-10-07 1976-10-02 1982-03-02 1997-09-23 2012-10-12 1989-06-05 2015-07-23 1972-09-01 1976-07-22 1988-09-08 1986-06-24 2019-07-02 1976-10-01 2018-01-30 2004-09-03 2016-05-10 1984-03-15 1999-10-04 1992-10-03 1980-11-18 1960-05-09 1998-10-05 2000-04-03 1960-10-05 1996-09-10 2018-02-13 2008-01-10 1976-07-19

ssdi_dod 2019-12-21 2019-10-01
2019-12-18 2014-03-16 2019-11-17 2019-10-25 2019-10-15 2019-09-05 2019-02-17 2017-12-08 2017-01-21
2019-05-03 2019-08-29 2019-10-28
2019-11-14 2019-10-29 2019-12-13 2019-11-30 2019-11-08 2019-11-03 2019-11-02 2019-10-10 2019-09-30 2019-09-25 2019-09-13 2019-09-08 2019-09-01 2019-08-31

obit_dod
2019-10-01 2019-08-09 2019-12-18
2019-10-25 2019-10-15 2019-09-05 2019-02-17 2017-12-08
2019-08-10 2017-12-19 2009-01-17 2019-05-03 2019-08-29 2019-10-28 2019-09-13
2019-11-30 2019-11-08 2019-11-03 2019-11-02 2019-10-10 2019-09-30 2019-09-25 2019-09-13
2019-08-31

Exhibit B, Page 209

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 210 of 352 Pageid#: 1113

voter_id

lname

405005667 M

39061484 M

27018215 M

527760861 M

917489585 M

221000136 M

702027143 M

918602994 M

507007740 M

606000225 M

602028732 M

919285332 M

918163583 M

919689647 M

712031586 M

244202824 M

808000518 M

225017610 M

307036067 M

540658929 M

305040723 M

305000438 M

310033937 M

801003526 M

313028759 M

305043665 M

308022047 M

186553396 M

918979052 M

919973365 M

502009584 M

919499417 M

5007685 M

fname PAULINE N GRADE CAROL JEAN ALMA HOWARD DRATIE DEBORAH EVE SANDRA ETHEL CECIL WILLIAM BARBARA ANDREW TRENA PEGGY GERALD JANE DEAN DAVID DOLORES HUGO GUY ANN JANE HENRY IRENE WILLIAM AUSTIN DENNIS JAMES ROBERT

dob 1929 1972 1960 1933 1926 1932 1938 1956 1955 1945 1911 1943 1947 1941 1946 1944 1939 1940 1932 1932 1924 1931 1929 1932 1945 1944 1924 1935 1922 1950 1938 1961 1930

date_registered 1973-10-05 2008-10-06 1980-04-05 2016-01-26 1996-05-09 1987-03-16 2005-04-29 1999-10-01 1992-09-18 1967-06-10 1933-09-13 2002-03-08 1997-12-02 2006-10-02 2008-10-03 2012-07-09 1968-10-05 1988-01-23 1980-08-18 2017-07-06 1956-09-04 1964-04-15 2003-01-31 1989-07-21 2002-10-07 1984-07-11 1999-09-13 2012-10-15 2000-11-14 2007-02-06 1999-01-11 2003-04-07 1984-10-06

ssdi_dod 2019-07-30 2019-06-08 2019-03-31 2019-02-08 2018-12-24 2018-12-24 2018-12-11 2018-12-07 2018-08-27 2018-07-07 2018-03-25 2018-01-31 2017-12-25 2017-12-17 2017-10-05 2017-09-03 2017-06-27 2015-11-27
2014-09-25 2020-01-30 2019-08-23 2019-06-08 2018-09-11 2019-10-21

obit_dod 2019-07-30 2019-06-08 2019-03-31 2019-02-08 2018-12-24 2018-12-24 2018-12-11
2018-08-27 2018-07-07
2018-01-31 2017-12-25 2017-12-17 2017-10-05 2017-09-03 2017-06-27 2015-11-27 2019-10-18 2019-09-29 2019-09-26 2019-09-19 2019-07-05 2018-12-21 2018-12-17 2018-12-15 2018-01-24 2014-09-25
2019-08-23 2019-06-07 2018-09-11 2019-10-21

Exhibit B, Page 210

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 211 of 352 Pageid#: 1114

voter_id

lname

919398688 M

919842683 M

917557035 M

406621589 M

144667989 M

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706017120 M

207023746 M

107023819 M

701000506 M

307020942 M

606031920 M

709004342 M

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208007333 M

305018052 M

303042611 M

450017193 M

412896427 M

713012807 M

808000812 M

605010678 M

709003822 M

604006170 M

918954039 M

704012108 M

42778500 M

652247392 M

407023121 M

83573145 M

918202104 M

34426431 M

fname WALLACE GIEL MOSE JAMES ALICE JANET WILLIAM JULIUS JOCIE HERMAN BARBARA THOMAS JAMES CECIL WALTER DOROTHY RODERICK CARRIE WILLIAM WILLIAM CLAY HELEN JOHN JONATHAN SYLVESTER JOANN TROY MATTIE TONY ELIZABETH GWENDOLYN JUANA ALICE

dob 1939 1946 1947 1949 1948 1922 1949 1944 1927 1937 1944 1939 1937 1941 1924 1924 1933 1957 1941 1936 1955 1931 1939 1937 1944 1945 1949 1944 1974 1944 1936 1922 1926

date_registered 2002-09-20 2004-08-13 2011-07-12 2012-10-15 2013-07-10 1987-09-24 1994-10-11 1965-09-25 1968-10-05 1976-09-11 1984-09-27 1986-10-04 1992-05-26 1988-08-29 2017-07-26 1980-02-13 1994-09-13 1986-08-07 2008-02-14 2012-09-21 1988-10-08 1964-05-21 1964-02-08 1972-09-19 1988-04-11 2000-10-10 1972-08-10 2008-08-26 2007-10-09 1979-04-12 2015-03-09 1998-01-30 2011-05-13

ssdi_dod 2019-11-22 2019-11-21 2019-08-08 2018-12-02 2018-11-30 2019-09-12 2019-09-03 2019-07-07 2018-12-21 2018-02-04
2018-12-20 2019-12-06 2020-01-08
2019-06-04 2019-11-01 2019-09-18 2019-11-06 2018-10-12 2019-10-28
2019-10-15
2019-09-03 2019-08-22 2019-08-01 2018-12-12 2019-10-09 2016-09-26 2018-01-27

obit_dod 2019-11-22
2019-08-08 2018-12-02 2018-11-30
2019-09-03 2019-07-07 2018-12-21
2019-10-21 2019-07-24 2017-01-26 2018-12-20
2019-08-17 2019-06-04
2019-09-18 2019-11-06 2018-10-12 2019-10-28 2019-09-09
2019-10-10 2019-09-03 2019-08-22 2019-08-01
2016-09-26 2018-01-25

Exhibit B, Page 211

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 212 of 352 Pageid#: 1115

voter_id

lname

207014700 M

736496874 M

128018450 M

504014264 M

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396364333 M

25012382 M

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211015243 M

204010149 M

708000334 M

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226000767 M

310000814 M

554459416 M

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25001431 M

504006042 M

396884956 M

607030094 M

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709010227 M

121020090 M

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919144510 M

128004866 M

26016290 M

610033666 M

917410470 M

904005075 M

32788254 M

fname JULIA REGINALD JAMES MARY-JANE GERALDINE JAMES WILLIE LARRY JOHN BARBARA RONALD CATHERINE TYRONE DAN CONSTANCE BARBARA WILLIAM CINDY HAROLD REBECCA SHARON RAYMOND SUSIE ELIZABETH FRANCES VICTORIA LOUELLA SANDRA MARIE WILLIAM DAVID MARIA PRADIP

dob 1936 1948 1938 1948 1926 1944 1936 1947 1943 1943 1941 1940 1939 1933 1933 1938 1947 1967 1940 1948 1942 1921 1928 1927 1935 1954 1946 1943 1921 1943 1952 1939 1940

date_registered 1998-01-15 2008-07-08 1964-09-25 1982-09-18 1994-10-11 2008-09-18 2012-06-26 1976-09-10 1997-06-12 1998-06-15 1980-09-22 2004-11-18 2006-01-26 1998-06-10 1956-03-07 1992-10-03 2018-03-27 2000-10-10 1973-09-17 1983-10-08 2009-11-13 1981-10-02 1999-09-15 1967-10-05 1964-09-25 2006-06-14 2001-07-18 1974-01-14 1955-05-02 1988-10-06 2000-10-01 1990-11-08 2013-07-15

ssdi_dod 2020-01-04 2019-12-19 2019-12-14 2019-12-02 2019-11-29 2019-11-15 2019-10-25 2019-10-22 2019-09-26 2019-09-02 2019-08-30 2019-06-26 2019-06-02 2019-04-26 2018-12-31 2018-12-31 2018-12-14 2018-09-22 2017-11-28 2017-11-24 2017-01-02 2016-10-31 2015-11-30 2008-09-03
2019-08-20 2018-12-02 2019-11-25

obit_dod
2019-12-14 2019-12-02
2019-11-15 2019-10-25 2019-10-22 2019-09-26
2019-08-30 2019-06-26
2019-04-26 2018-12-31
2018-12-14 2018-09-22
2016-10-31
2008-09-03 2019-10-27 2019-10-18 2019-10-11 2019-07-01 2019-04-14 2018-12-19
2018-12-02

Exhibit B, Page 212

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 213 of 352 Pageid#: 1116

voter_id

lname

411013641 M

917337228 M

802002033 M

112030228 M

733788441 M

406018835 M

920291233 M

705018609 M

230018881 M

919970023 M

107169683 M

919440251 M

307038857 M

801022286 M

171192537 M

66067819 M

205007855 M

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205011932 M

28009519 M

453046931 M

904022892 M

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226013304 M

607008073 M

308038270 M

917642942 M

21005616 M

658253550 M

707012462 M

917851325 M

608028008 M

29020089 M

fname BERNARD ELLA CHARLES JOAN CLIFFORD MARION EUGENE LARRY MARYLOU NIAZMINA IBTISAM INGRID KANUKOLLU GEORGE MARGARET MANUCHER CLELLEN JEAN ADOLPH VINCENT DONNA RODGER NED LINDA KATHLEEN MILDRED SHERWOOD LINDA GIOVANNI ARCHIE MARY MARVIN ALICE

dob 1946 1946 1924 1931 1929 1928 1940 1944 1948 1929 1948 1949 1949 1960 1929 1932 1947 1925 1931 1934 1935 1943 1932 1948 1950 1924 1957 1946 1939 1936 1919 1944 1945

date_registered 1988-10-06 1995-09-23 1956-10-02 1997-01-03 2018-10-15 1980-10-04 2006-05-03 1980-10-04 1992-09-19 2004-10-04 2016-08-25 2002-12-02 1989-04-06 1992-06-22 2013-08-12 2007-02-08 1978-08-16 2001-02-05 2000-03-08 1959-06-12 2007-10-09 2001-07-06 2000-08-11 1998-07-15 1976-08-06 1963-10-03 1996-09-10 1968-10-02 2008-04-02 1968-09-17 1996-12-19 1967-02-11 1996-04-01

ssdi_dod 2019-07-14 2016-05-09 2013-02-07 2019-12-28 2019-09-11 2016-12-04 2019-11-13 2018-12-29 2020-01-10 2019-08-19 2019-12-02 2019-08-26 2018-11-03 2018-01-31 2020-01-12
2019-10-20
2019-10-14
2019-09-27
2019-09-12 2019-09-25 2019-10-01 2015-03-26 2017-12-29 2020-01-02 2019-08-11 2016-03-29 2019-03-29 2017-06-26

obit_dod 2019-07-14 2016-05-09 2013-02-07
2019-11-13 2018-12-29
2019-08-26 2018-11-03 2018-01-31
2019-08-14
2019-12-03 2019-10-14 2019-10-09 2017-12-30 2019-09-27 2019-05-10 2019-09-12 2019-09-25 2019-10-01
2019-08-11 2016-03-29
2017-06-26

Exhibit B, Page 213

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 214 of 352 Pageid#: 1117

voter_id

lname

225008239 M

551306570 M

202005912 M

919890191 M

122008396 M

811007586 M

307037015 M

107017062 M

833243835 M

919002989 M

229005483 M

917563410 M

903017431 M

801017412 M

505029347 M

3002365 M

207004134 M

503021555 M

909021692 M

211013102 M

704027931 M

127524928 M

918944176 M

126012671 M

51519575 M

125592619 M

902020135 M

917369792 M

507034007 M

74017683 M

107798609 M

901012457 M

918835333 M

fname LINDA NANCY GLORIA LEE HORACE MICHAEL JAMES DAVID JAMES RICHARD NICHOLAS RAFAEL JUANITA DEBORAH ROOSEVELT PAULINE ROBERT ROBERT ROBERT CAROLINE CHARLES VERONICA MELVIN ELLEN MARIA LAURA MARY HERBERT GREGORY SIDNEY ELIZABETH WISE MARILYN

dob 1939 1937 1948 1970 1938 1946 1927 1936 1980 1939 1927 1943 1934 1933 1936 1925 1930 1932 1928 1941 1949 1946 1957 1918 1925 1938 1930 1940 1965 1942 1924 1924 1938

date_registered 2006-12-07 2008-10-06 1976-09-16 2004-09-16 1966-05-12 1988-10-08 1968-09-10 1995-12-22 2019-04-25 2000-12-12 1980-10-01 1996-07-18 1999-10-04 1999-06-11 1974-10-05 1983-09-26 1993-12-07 1980-09-25 1971-10-06 2005-09-30 1992-09-09 2011-02-24 2000-10-10 2006-05-11 2016-01-07 2016-09-21 1972-09-12 1995-10-10 1996-09-13 2012-06-21 2013-09-16 1999-02-25 2000-07-31

ssdi_dod 2014-10-21
2018-02-08 2019-12-22 2018-12-22 2018-06-24
2019-08-18
2016-09-10 2019-05-27 2019-11-14 2019-09-25 2019-12-30 2019-12-24 2019-12-04 2019-11-25 2019-11-16 2019-11-15 2019-10-11 2019-09-03 2018-12-24 2016-12-03 2016-11-08
2020-01-17 2019-10-25 2019-06-18 2017-06-24 2017-06-12 2020-01-18 2019-11-23

obit_dod
2017-08-18 2014-12-07 2018-02-08
2018-12-13 2019-08-18 2018-05-27 2016-09-10
2019-11-14
2019-12-30
2019-12-04 2019-11-25 2019-11-16 2019-11-15 2019-10-11 2019-09-03 2018-12-24 2016-12-03
2019-08-08
2019-10-25
2017-06-24 2017-06-12
2019-11-23

Exhibit B, Page 214

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 215 of 352 Pageid#: 1118

voter_id

lname

919644568 M

801010001 M

514020089 M

805006080 M

401018020 M

804007773 M

803007773 M

109011888 M

917973943 M

317513958 M

507008015 M

308008387 M

917384339 M

301013686 M

917109299 M

433771184 M

202005730 M

115027413 M

907005644 M

203024583 M

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804008021 M

403031609 M

919680497 M

919547916 M

80137374 M

918491245 M

706000817 M

906021156 M

603000970 M

917457148 M

48786508 M

917473786 M

fname DOUGLAS MAYROSE SALLY JEAN NORMA PHYLLIS EUGENE MARY ELAINE SHELBY BENJAMIN ROSE MARIE JOHN CLARISSA KENNETH DONNA WILMOTH RODNEY KENNETH JOE ELIZABETH PAUL CATHERINE ELAINE HOWARD WILLIAM WILLIAM CARROLL PAMELA SUSAN SHIRLEY JOHN STANLEY

dob 1943 1935 1941 1927 1927 1939 1937 1942 1947 1937 1937 1932 1943 1921 1948 1957 1932 1944 1940 1937 1932 1921 1930 1940 1938 1928 1945 1940 1942 1932 1929 1939 1944

date_registered 2003-12-08 1965-06-09 1990-03-27 1952-05-03 1968-09-17 2005-09-08 2005-09-08 1994-09-28 1997-04-22 2016-10-21 1983-10-06 1997-08-15 1995-12-08 1966-06-09 1994-04-14 2012-09-20 1975-05-20 1999-03-10 1987-04-29 1986-02-20 2004-01-12 1946-09-28 1968-09-21 2004-02-13 2003-07-02 2016-08-03 1999-04-28 1979-08-20 1972-07-31 1953-06-01 2001-10-01 2016-01-07 2006-03-07

ssdi_dod 2018-12-04 2018-10-22 2018-05-13 2017-05-25 2019-11-09 2019-11-13 2019-11-06
2020-01-11 2019-12-27 2019-12-19 2019-12-16 2019-12-12 2019-12-04 2019-11-30 2019-11-18 2019-11-01 2019-11-01 2019-10-31 2019-10-15 2019-09-23 2019-09-18 2019-09-13 2019-09-10 2019-08-22 2019-07-12 2019-06-30 2018-12-24 2018-12-21 2018-12-10 2018-12-07 2018-08-14 2018-01-23

obit_dod 2018-12-04 2018-10-22
2017-05-25 2019-11-09
2019-09-12
2019-12-19 2019-12-16 2019-12-12
2019-11-01 2019-11-01 2019-10-31 2019-10-15 2019-09-23 2019-09-18 2019-09-13
2019-07-12 2019-06-30 2018-12-24
2018-12-10 2018-12-07 2018-08-14

Exhibit B, Page 215

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 216 of 352 Pageid#: 1119

voter_id

lname

907015009 M

917487709 M

384617177 M

548398190 M

919694145 M

917868653 M

79909049 M

703015265 M

787076938 M

2742335 M

920009530 M

25017952 M

104009135 M

27009521 M

708004029 M

901008512 M

608032201 M

123007311 M

223005486 M

106021643 M

917172265 M

704010030 M

608010369 M

201029785 M

513006043 M

907011587 M

507014789 M

125268746 M

801888298 M

102000170 M

226008845 M

917471964 M

106026162 M

fname BEULAH RONALD DONNIE DONNIE WILLIAM FRED MAJORIE DONNIE CATHERINE VIOLA WILLIE JAMES WILEY JOHN RICHARD MARY MICHAEL ALMA HALLIE ANNETTE DAN JOSEPH THELMA LUCILLE BRENDA HOWARD JUANA VIRGINIA VELIA NANCY SARAH GENEVIEVE LOLA

dob 1936 1948 1951 1964 1949 1947 1923 1946 1928 1930 1920 1928 1929 1931 1939 1927 1944 1938 1922 1936 1931 1948 1955 1939 1949 1934 1934 1934 1944 1946 1941 1923 1944

date_registered 1967-10-03 1996-05-08 2012-10-15 2017-09-11 2004-02-25 1997-01-14 2012-10-15 1987-09-24 2011-08-11 2012-10-15 2004-11-03 1957-06-06 1952-03-25 1957-01-21 1980-09-17 1961-04-19 2001-10-09 1998-11-18 1953-05-28 1988-02-01 1994-09-26 1994-10-06 1991-01-04 1999-06-09 1992-04-14 1988-10-04 1987-09-14 2016-06-20 2007-12-27 1980-05-27 1968-10-03 2003-08-22 1983-09-06

ssdi_dod 2018-01-06 2018-01-03 2017-12-29 2017-11-03 2017-10-07 2016-10-19 2015-11-09 2015-09-14 2013-09-25 2012-12-12 2009-07-26 1999-10-05
2019-12-03 2019-09-09 2019-01-19 2019-03-25 2019-12-23 2019-10-17
2015-11-15

obit_dod 2018-01-06 2018-01-03 2017-12-29 2017-11-03
2015-11-09
2012-12-12 2009-07-26
2019-10-25 2019-09-15 2019-09-11 2019-08-11 2019-07-28 2019-05-13 2019-03-14 2018-12-16 2018-12-04 2018-08-10 2017-12-27 2016-09-30 2015-02-14 2019-12-03
2019-01-19
2019-09-12 2015-11-15

Exhibit B, Page 216

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 217 of 352 Pageid#: 1120

voter_id

lname

704016288 M

304035696 M

279264197 M

968684827 M

402669542 M

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207026131 M

765152952 M

303032398 M

212011340 M

403001171 M

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704003826 M

306019321 M

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286210428 M

303014889 M

705001423 M

22356820 M

224018338 M

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104022031 M

403012301 M

302051131 M

504026361 M

21004326 M

905000733 M

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408003491 M

26020091 M

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703014849 M

917849898 M

fname JEAN KENNETH CHARLES FRANK MICHAEL CAROL DORIS FAYE HENRY RICHARD DENNIS RICHARD CHRISTINE JULIA EMILY REBECCA RICHARD GEORGE RICHARD RUTH RAMONA FRANK PAUL MARIJA CLIFTON ROBERT ROY REGINA PAMELA JOHN STEPHEN SHEILA RUTH

dob 1928 1924 1948 1922 1941 1948 1931 1922 1920 1929 1948 1948 1947 1914 1933 1944 1924 1944 1934 1927 1942 1928 1949 1955 1941 1920 1961 1949 1947 1941 1960 1938 1931

date_registered 1949-07-01 1959-05-06 2015-09-22 2008-01-12 2007-07-19 1999-11-19 1964-10-03 2008-09-23 1970-10-03 1991-10-05 1998-09-29 1999-12-02 1982-09-13 1972-09-13 1990-10-06 2012-10-15 1949-04-01 1999-04-23 2016-10-14 1980-10-02 1997-09-29 1952-04-10 1970-06-08 1984-03-16 2003-11-12 1995-07-19 1991-11-22 1994-08-05 1999-01-14 1994-07-25 2000-08-04 1987-09-22 1996-12-17

ssdi_dod
2019-10-29
2019-11-02 2020-01-12 2019-12-11 2019-12-08 2019-08-20 2017-05-06 1991-12-05
2000-06-14
2018-05-17
2019-11-27 2019-12-30 2020-01-21 2020-01-12 2019-12-06 2019-11-26 2019-11-24 2019-11-15 2019-11-03 2019-11-01 2019-10-21 2019-10-05 2019-08-30 2019-08-25 2019-08-23 2019-08-15

obit_dod 2018-12-21 2019-10-29 2019-09-28
2019-12-08
2017-05-06
2019-09-30 2019-09-29 2018-12-10
2018-12-20 2018-05-17 2018-12-07
2019-12-06 2019-11-26 2019-11-24 2019-11-15 2019-11-03 2019-11-01 2019-10-21 2019-10-05 2019-08-30 2019-08-25 2019-08-23 2019-08-15

Exhibit B, Page 217

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 218 of 352 Pageid#: 1121

voter_id

lname

805010002 M

122011289 M

28357380 M

466293291 M

248969295 M

222006154 M

918522172 M

920389788 M

221015469 M

918067713 M

828101720 M

103008044 M

813007374 M

103007323 M

603002699 M

203010933 M

28018221 M

410001909 M

400070159 M

919480241 M

308012895 M

4083443 M

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919236961 M

101025377 M

918911534 M

917706623 M

609000227 M

917058512 M

740074187 M

367030269 M

220020256 M

920278704 M

fname EDWARD JOHN HORACE JAMES CARROLL JOSEPH THOMAS DAVID HARRY DEBORAH JAMES JAMES ROY STANLEY SUSIE WILLIAM WINNIE SARA WILLIAM DARTCHIE META LEIGH PATRICIA SHAWN HENRY WAYNE BRENDA LUCIA GLORIA ISREAL BRENDA JOHN BRODER DANNY

dob 1942 1945 1956 1950 1948 1936 1924 1941 1958 1952 1931 1930 1935 1940 1941 1933 1926 1938 1946 1934 1941 1946 1980 1965 1947 1944 1951 1929 1923 1971 1960 1938 1969

date_registered 1981-11-30 1976-09-11 2016-09-26 2018-01-17 2008-09-04 1992-09-17 1999-06-09 2006-11-08 2004-07-21 1997-08-18 2008-09-10 1971-10-02 1988-10-04 1967-03-10 1993-05-05 1979-10-03 1998-02-23 1994-09-14 2012-06-19 2003-03-10 1980-10-04 2016-03-15 1999-09-18 2001-11-29 1981-10-03 2000-09-29 1999-05-17 1988-09-02 1993-11-03 2016-10-11 2017-09-27 2011-11-28 2006-03-30

ssdi_dod 2019-08-11 2019-08-05 2019-01-26 2019-01-22 2018-12-31 2018-12-21 2018-08-22 2018-06-12 2018-06-07 2017-11-25 2017-11-08
2019-12-18 2019-08-31 2019-08-21
2019-11-11 2017-11-21
2019-03-04 2018-05-27 2017-12-21
2019-09-09 2017-07-06 2017-04-01 2019-08-09 2018-07-18 2018-06-25 2018-01-30 2017-06-09

obit_dod
2019-08-05
2018-12-31
2018-06-07 2017-11-25
2019-09-27 2019-09-07 2019-05-08 2019-12-18 2019-08-31 2019-08-21 2016-12-18 2019-11-11
2019-06-25
2018-05-27
2019-08-21 2019-09-09 2017-07-06
2019-08-09 2018-07-18 2018-06-25
2017-06-09

Exhibit B, Page 218

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 219 of 352 Pageid#: 1122

voter_id

lname

305002710 M

698268240 M

304015825 M

215662430 M

67833090 M

602002787 M

919732260 M

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6812166 M

209008345 M

123018019 M

204001866 M

917152621 M

601024011 M

518673490 M

201023564 M

303042971 M

132013223 M

26007072 M

919430299 M

917059600 M

919529743 M

102031247 M

920234965 M

306021766 M

239422908 M

805005180 M

228000471 M

917947508 M

523197288 M

918303358 M

308050770 M

fname BONNIE BERNICE MARY ANN NANCY TED PERCY VIRGINIA NANCY OMAR JOAN JOHANNE MARY PATRICIA LAWRENCE RAY JACK MARIO ARCHIE ROY LEAH AZEEZUDDIN LINDA STEVE MONICA PAUL DANIEL SHAWN MAGNOLIA WILLIAM RAYMOND WILLIAM MARY GEORGE

dob 1944 1944 1945 1942 1926 1958 1976 1939 1937 1924 1940 1925 1948 1946 1941 1920 1943 1948 1928 1937 1947 1942 1956 1947 1924 1929 1976 1924 1935 1937 1935 1935 1940

date_registered 1979-05-01 2008-03-03 1988-07-07 2008-09-22 2014-09-03 2001-07-11 2004-04-05 2002-12-11 2000-10-07 2012-05-09 1990-11-07 1952-04-30 1971-09-30 2002-10-07 1987-10-02 2010-08-12 1983-03-19 1980-10-04 2018-05-21 1992-09-23 2002-11-06 1997-01-17 2003-06-04 1996-12-06 2006-01-06 1960-09-27 2012-10-02 1963-12-12 1968-07-12 1997-03-26 2015-11-09 1998-07-20 2004-05-20

ssdi_dod 2014-05-02
2019-09-30 2020-01-17 2017-10-02 2019-10-14 2019-10-22 2017-04-07 2019-09-04 2019-09-26 2014-01-21 2019-11-21
2020-01-06 2019-11-27
2019-08-30 2016-02-22
2019-08-15 2017-11-22 2019-10-20 2018-10-03 2019-11-03 2019-08-08
2018-02-17
2018-01-01 2018-01-25
2018-12-28

obit_dod
2019-10-12 2019-09-30
2017-10-02 2019-10-14
2017-04-07
2014-01-21 2019-11-21 2019-02-15
2019-11-27 2018-12-20 2019-08-30 2016-02-22 2019-08-01
2017-11-22 2019-10-20
2019-08-08 2018-12-06
2019-10-11 2018-01-01 2018-01-25 2018-04-19 2015-04-15 2018-12-28

Exhibit B, Page 219

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 220 of 352 Pageid#: 1123

voter_id

lname

809007587 M

604028240 M

205024240 M

708001755 M

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701014584 M

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63444512 M

506002714 M

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112299446 M

145219060 M

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702012467 M

706015314 M

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308041404 M

306042973 M

801000526 M

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185007402 M

603004632 M

449179451 M

986987570 M

201014350 M

274501597 M

fname THOMAS PAULINE BERNICE DONALD ARVILLE PATRICIA GOLDEAN RICKY ELBERT DANNY JENELL THOMAS CHRISTOPHER FRANCES BRENDA GAY BOBBY KATHLEEN DOROTHY LENA VIRGIL THEODOSIA JULIA BALWANT LEIGH BILLY CECIL VOLLIE JANET ANTHONY MARY ABDULAI JOYCE JAMES

dob 1947 1945 1925 1939 1928 1946 1945 1966 1935 1954 1918 1934 1961 1944 1951 1940 1948 1934 1927 1945 1941 1927 1939 1931 1951 1935 1944 1948 1928 1951 1955 1930 1995

date_registered 1992-04-02 1966-10-04 1992-10-16 1981-09-24 1949-10-08 2006-08-22 1991-09-19 1985-05-17 1982-03-08 1999-05-12 1989-09-26 1994-07-27 2015-07-17 1979-09-14 1987-08-14 2008-10-06 2018-06-04 2009-01-22 1950-10-03 1981-09-29 2002-02-19 2004-02-17 1992-02-20 1964-04-06 1984-01-11 1973-08-07 1999-12-28 2015-09-09 1962-10-06 2012-09-25 2008-02-15 2001-07-24 2014-03-21

ssdi_dod 2018-06-25 2020-01-15 2019-12-16 2019-12-09 2019-09-22 2019-05-15 2019-03-20 2019-03-19 2019-01-06 2018-12-31 2018-12-24 2018-07-08 2018-02-11 2018-01-06 2016-11-23 2016-03-03
2016-09-24 2018-02-15 2019-09-26 2016-11-21
2013-12-31
2019-08-14 2017-12-27 2017-10-14 2019-12-04 2018-07-06

obit_dod 2018-06-25
2019-12-16 2019-12-09 2019-09-22 2019-05-15
2019-03-19 2019-01-06
2018-07-08
2018-01-06 2016-11-23 2016-03-03 2019-10-15 2019-08-17 2019-07-21 2019-02-22 2018-06-08 2016-09-24 2018-02-15 2019-09-26 2016-11-21 2018-03-26
2019-10-31 2019-08-14 2017-12-27
2019-12-04 2018-07-06

Exhibit B, Page 220

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 221 of 352 Pageid#: 1124

voter_id

lname

208963451 M

303038436 M

206021679 M

403035902 M

703012811 M

901015914 M

705018314 M

919640245 M

918639596 M

420129234 M

308018064 M

919570828 M

918254130 M

307007147 M

922444075 M

919272705 M

11670996 M

918397387 M

254279383 M

307014624 M

705010234 M

404004523 M

602019967 M

27256746 M

401027261 M

107016542 M

237019896 M

918948230 M

917731938 M

584748215 M

601039403 M

107006225 M

305001911 M

fname GEORGE WILLIAM PATRICK WILLIAM HELEN HELEN SYBIL ESPERIA KENNETH JAMES JOYCE EILEEN JOHN SANDRA PHYLLIS DAVID JONATHAN SAMUEL FRANCINE JAMES GILMER JOHN ALMA NANCY ELIZABETH JAMES ABU BAKR GREGORY ROALD WILLIAM JOHN PHYLLIS EDNA

dob 1931 1939 1947 1943 1934 1924 1929 1928 1946 1935 1948 1957 1934 1942 1933 1947 1979 1947 1965 1950 1931 1923 1932 1939 1926 1923 1940 1947 1929 1944 1939 1938 1938

date_registered 2019-06-14 1989-03-20 1987-04-09 1992-09-29 1999-02-08 1947-08-18 1999-04-13 2003-11-26 1999-12-01 2007-04-10 1983-04-11 2003-08-11 2001-02-26 2004-11-02 2008-05-02 2002-02-12 2008-08-26 1998-12-09 2016-09-13 2016-02-08 1954-07-28 1967-03-25 2006-04-03 2012-09-13 1952-01-03 1956-10-06 2008-10-06 2000-10-10 1996-10-07 2007-06-18 1995-08-25 1990-10-05 1974-12-03

ssdi_dod 2019-10-01 2020-01-03 2019-12-08 2019-11-29 2019-10-17 2019-09-23 2019-07-05 2019-03-17 2019-01-03 2018-05-20 2018-01-27 2017-06-10
2018-12-17 2018-11-16 2018-03-08 2018-01-01 2017-12-14 2016-07-15 2018-12-19 2018-12-17 2019-08-07
2018-12-17 2015-10-27 2019-10-09 2019-10-21
2020-01-16 2016-08-28

obit_dod
2019-11-29 2019-10-17 2019-09-23 2019-07-05
2018-05-20 2018-01-27 2017-06-10 2019-09-15 2019-09-04 2018-11-08 2018-12-17
2016-07-15 2018-12-19
2019-08-07 2018-12-11 2018-12-17
2019-10-09 2019-10-21 2017-11-14
2016-08-28 2019-09-09

Exhibit B, Page 221

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 222 of 352 Pageid#: 1125

voter_id

lname

112017372 M

248371983 M

602032205 M

709001620 M

954757579 M

705006121 M

201008347 M

918156488 M

917411836 M

604002788 M

425659844 M

704003162 M

203370837 M

256447373 M

919393879 M

411012556 M

920027986 M

4346912 M

29017147 M

123012453 M

222007665 N

36750066 N

503017637 N

505008953 N

560227912 N

307025222 N

420132137 N

167315584 N

103257837 N

303016966 N

116021645 N

917194708 N

920077249 N

fname MARY NANCY HALLIE PIERRE RICHARD WESLEY WILLIAM CLIFTON CHARLES DOROTHY ROY MARY ROBIN JEAN EVELYN ANNE SARAH REGINA MARION WILLIAM PAUL STUART PHILIPPE JUNE KATHY JOHN ALBERT DANIEL CHUNG ROSCOE JANET BETTY WARREN

dob 1934 1945 1940 1950 1939 1946 1936 1937 1945 1925 1944 1933 1949 1963 1931 1942 1947 1938 1939 1936 1946 1928 1935 1926 1960 1933 1924 1949 1947 1948 1949 1930 1944

date_registered 1997-09-19 2014-08-20 2005-10-05 1992-06-03 2008-05-12 1975-09-27 1980-10-04 1997-12-04 1996-03-20 1963-11-26 2011-02-17 1984-10-02 2014-11-05 2016-08-26 2002-09-12 1989-08-25 2004-11-30 2009-08-11 1999-12-08 1976-10-02 2002-07-17 2016-04-08 1985-10-03 1983-10-07 2008-02-13 1956-10-06 2011-08-30 2013-01-15 2015-08-14 1987-02-14 1990-10-05 1994-10-07 2005-03-30

ssdi_dod 2019-10-02 2019-12-24 2017-12-08 2018-11-23 2019-09-30 2020-01-08 2019-12-19 2019-12-18 2019-12-17 2019-11-05 2019-11-03 2019-09-24 2019-09-19 2019-09-03 2019-08-08 2017-09-11
2019-10-25 2017-05-29 2019-12-12
2019-11-21
2019-09-05
2019-08-09
2018-10-30 2020-01-09 2018-10-27 2014-06-21 2019-09-27

obit_dod 2019-10-02
2018-11-23 2019-09-30
2019-12-19 2019-12-18 2019-12-17 2019-11-05 2019-11-03 2019-09-24
2019-09-03 2019-08-08 2017-09-11 2019-08-27 2017-01-07 2019-10-26
2019-12-12 2019-09-28 2019-11-21 2018-07-04 2019-09-01 2019-10-20
2018-01-18
2018-10-27 2014-06-21

Exhibit B, Page 222

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 223 of 352 Pageid#: 1126

voter_id

lname

806002043 N

218570627 N

502013599 N

403012726 N

917012929 N

707004699 N

906016929 N

222026292 N

918993716 N

304015382 N

102026275 N

4006864 N

919657913 N

919648187 N

920120198 N

102029313 N

920314485 N

918634015 N

219235944 N

112000865 N

280543018 N

917536749 N

604037303 N

14656756 N

506009479 N

919180936 N

919013256 N

920178237 N

226014089 N

25001822 N

7002652 N

801000317 N

5007241 N

fname JANICE ANN MARCELLA PHILIP LEMUEL VINCENT MARILYN PATRICIO MARY VIRGINIA CLAY WENDY GIAO LESLIE WILLIAM KATHLEEN JOHN VIRGINIA JOHN MELVIN HUNTER NAOMI CAROL CHARLOTTE FLORENCE HELEN RICHARD CLARICE BRENDA PATRICIA MARIE RAYMOND LYNDA

dob 1923 1941 1955 1939 1948 1935 1945 1944 1943 1925 1968 1972 1927 1928 1959 1934 1963 1957 1921 1927 1940 1947 1950 1939 1923 1924 1946 1923 1940 1945 1922 1940 1942

date_registered 1972-10-07 2008-09-08 1987-09-24 1963-07-11 1993-08-24 1988-04-06 1984-08-22 1992-09-24 2000-11-30 1967-10-07 1986-05-15 1992-09-12 2004-01-05 2003-12-12 2005-05-25 2006-10-09 2006-06-14 1999-11-22 2014-09-29 1967-03-25 2012-09-13 2004-07-19 1991-10-05 2013-10-15 1998-05-11 2001-08-01 2000-12-29 2005-09-29 1985-05-12 1972-01-06 1959-04-20 1992-09-28 1992-09-30

ssdi_dod 2019-08-13 2019-10-09 2019-02-05 2019-09-29 2019-09-03 2017-05-27 2019-10-16 2015-03-28
2019-06-20 2019-06-04 2017-10-10 2019-05-25 2019-10-20 2017-09-19 2019-10-29 2019-09-29 2018-12-15
2019-09-21
2015-01-17 2019-09-15
2018-04-12 2019-03-22 2019-12-24
2018-09-10 2020-01-10 2018-12-15

obit_dod 2019-08-13
2019-09-29 2019-09-03
2019-10-16
2018-08-28 2019-06-20 2019-06-04 2017-10-10
2019-10-20 2017-09-19
2019-09-29 2018-12-15 2019-10-10 2019-09-21 2019-07-25 2018-12-01 2015-01-17 2019-09-15 2019-08-04 2018-04-12 2019-03-22 2019-12-24 2019-08-25 2018-09-10
2018-12-15 2019-06-05

Exhibit B, Page 223

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 224 of 352 Pageid#: 1127

voter_id

lname

459768001 N

919278052 N

186493233 N

401017220 N

407011096 N

919035098 N

920118155 N

304000826 N

306018358 N

170355749 N

357004003 N

302040733 N

680604108 N

117026277 N

477696153 N

919487277 N

226009719 N

304008039 N

485889712 N

226010368 N

306016779 N

504025019 N

919222542 N

410002888 N

611014988 N

603016165 N

917537328 N

918041929 N

405013644 N

908004801 N

252416859 N

611008419 N

237018339 N

fname LOUIS JAMES MARK MABEL MELISSA PATRICIA WILLIAM SHIRLEY CLAUDIA FREDERICK NOEL GLORIA WANDA MICHAEL WILLIAM JOHNNIE WILLIAM THOMAS ANNE MARIE ELEANOR VIRGINIA ROXANNE KATHERINE STEPHEN WILLIE ROSE WALDO RAYMOND MARION JAYNE KLAUS LAL

dob 1923 1976 1958 1934 1937 1942 1943 1940 1929 1931 1932 1947 1950 1961 1954 1941 1926 1933 1949 1933 1925 1922 1958 1928 1954 1932 1946 1932 1946 1936 1958 1930 1940

date_registered 2012-10-01 2002-02-26 2012-11-08 1955-05-23 2005-10-11 2001-02-06 2005-05-31 2000-09-14 1972-09-16 2016-10-21 2016-06-27 2004-09-28 2009-04-28 2001-09-10 2017-09-25 2003-03-18 1947-06-30 1984-09-25 2012-10-15 1976-03-31 1968-05-15 1985-09-30 2001-10-17 1998-02-08 1999-06-15 1967-02-23 1996-07-01 1997-07-15 1988-03-09 1992-07-13 2014-08-06 1979-10-05 2019-01-17

ssdi_dod
2019-11-13 2019-11-03 2019-10-11 2019-10-09 2019-09-28 2019-09-24 2019-09-21 2019-09-04 2019-09-03 2019-01-17 2019-01-14 2019-01-10 2018-12-31 2018-12-20 2018-04-24 2018-01-04
2015-02-20 2019-10-15 2018-12-28 2017-07-20
2019-12-12 2020-01-15 2018-12-24 2019-01-01 2019-11-05 2019-09-05

obit_dod 2019-09-12 2019-11-13
2019-10-11 2019-10-09 2019-09-28 2019-09-24 2019-09-21
2019-09-03
2019-01-14 2019-01-10 2018-12-31
2018-01-04 2019-10-19 2019-08-20 2019-08-12 2019-05-16 2016-11-16
2019-10-15 2018-12-28 2017-07-20 2017-09-30
2019-11-05

Exhibit B, Page 224

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 225 of 352 Pageid#: 1128

voter_id

lname

917650017 N

917320592 N

606015500 N

504016520 N

30046095 N

123011943 N

804021765 N

706026645 N

919813056 N

917217144 N

601028740 N

708001622 N

806007381 N

504014273 N

121020976 N

917740632 N

408628465 N

801016364 N

919156133 N

917531016 N

567231951 N

220139454 N

919402383 N

514031895 N

4355763 N

180721324 N

249710428 N

917198573 N

918930523 N

403811610 N

324360899 N

919548912 N

207992573 N

fname ELIZABETH JIMMIE ERIC ARTHUR DORIS LOIS RICHARD JAMES WILLIAM JAMES CARL MARY CHARLES NANCY PHYLLIS MERLEAN JAMES ELSIE CHARLENE DORIS FRANK JOSEPH DELORIS JEANETTE CHARLES EUGENE QUANG LAM HAN KELVIN LIEU MOT TAN

dob 1937 1936 1929 1938 1923 1942 1932 1941 1955 1932 1919 1952 1934 1942 1926 1941 1939 1943 1945 1939 1948 1978 1936 1949 1934 1948 1939 1945 1939 1956 1946 1942 1969

date_registered 1996-08-30 1995-09-09 1974-10-05 1999-04-09 2009-09-04 1989-05-07 1992-05-06 1983-10-07 2004-07-22 1994-10-11 1946-10-03 1989-05-13 1984-10-06 1972-10-04 2006-12-14 1996-10-07 2010-05-05 1998-02-24 2001-07-29 1996-06-24 2015-07-29 2008-10-06 2006-12-07 1992-09-12 2014-06-13 2012-10-15 2008-01-14 1994-10-01 2000-10-07 2012-10-15 2008-01-09 2003-07-03 2013-07-03

ssdi_dod
2019-12-31 2017-12-18 2019-10-05 2019-10-08 2018-08-25
2018-12-16 2016-05-19 2019-09-25 2019-08-27 2018-12-21 2017-12-27
2019-01-28 2016-09-06 2019-10-10 2019-12-25 2019-11-01 2016-06-06
2014-11-27 2019-12-19 2019-11-18 2019-11-04 2019-08-17 2019-02-22 2019-01-31 2018-07-23 2018-06-17

obit_dod 2018-02-26
2017-12-18 2019-10-05 2019-10-08 2018-08-25 2019-08-29 2018-12-16
2019-09-25 2019-08-27 2018-12-21 2017-12-27 2019-11-05 2019-08-10 2018-12-26 2019-01-28 2016-09-06
2016-06-06 2019-08-27 2016-11-20
2019-11-04
2018-07-23 2018-06-17

Exhibit B, Page 225

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 226 of 352 Pageid#: 1129

voter_id

lname

917363852 N

917565691 N

630888073 N

920018734 N

214103036 N

918359637 N

917530762 N

918639600 N

918246495 N

484674595 N

917997469 N

918260840 N

274214363 N

304432994 N

801010006 N

127405955 N

209011351 N

104024288 N

917944476 N

9778952 N

709014854 N

29242110 N

907001726 N

702009293 N

401395438 N

405007297 N

221002366 N

220667694 N

918629971 N

135016498 N

255750615 N

701029255 N

222016097 N

fname RICH KHUONG TRUNG BE LAN THO THUC NINH DOANTRANG WILLIAM JOAN ZERNIE JAMES DANNY ROBERT BERNARD BARBARA CORINNE ROXANA JERMAINE CHARLES TAMMY GLORIA REID DARRYL JANET JACQUELINE GARY ROBERT MARGARET JOHN JERRY GEORGE

dob 1946 1941 1937 1937 1946 1920 1920 1932 1946 1928 1937 1934 1948 1947 1940 1933 1944 1937 1946 1978 1928 1963 1954 1924 1934 1934 1952 1956 1943 1940 1938 1964 1942

date_registered 2004-08-27 1996-07-18 2013-12-05 2004-11-02 2012-10-15 1998-10-01 1996-08-09 2003-02-27 1998-04-23 2016-02-01 1997-04-25 1998-05-12 2008-03-25 2012-09-07 1980-10-04 2017-10-04 1984-09-26 1967-09-27 1997-03-25 2015-04-01 1988-10-07 2015-07-01 1982-10-01 1952-04-25 2008-10-06 2005-11-09 1984-09-19 2007-06-12 1999-10-21 2012-08-30 2012-08-27 1988-02-22 1984-09-01

ssdi_dod 2018-04-28 2017-09-14 2016-12-01 2016-03-18 2015-09-01 2004-05-06 1999-06-26
2019-11-14 2016-12-23 2016-11-09 2014-03-13 2020-01-09 2019-12-08 2019-12-01 2019-11-10 2019-11-05 2019-11-05 2019-10-16 2019-08-17 2016-09-24 2016-05-27 2017-12-15
2018-12-21 2019-11-10 2018-06-18
2019-09-30 2019-11-25 2017-11-30

obit_dod
2016-03-18 2015-09-01
2018-12-20 2014-07-23
2016-11-09 2014-03-13
2019-12-08
2019-11-05 2019-11-05 2019-10-16 2019-08-17 2016-09-24 2016-05-27
2019-09-04 2018-12-21 2019-11-10 2018-06-18 2016-09-08 2019-09-30 2019-11-25
2019-08-19

Exhibit B, Page 226

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 227 of 352 Pageid#: 1130

voter_id

lname

1321281 N

901020143 N

917259366 N

225008551 N

124016127 N

918039387 N

511027630 N

919858619 N

701012257 N

917509920 N

509007589 N

302010544 N

514009676 N

918080780 N

917447417 N

213010010 N

918724163 N

919950932 N

919376280 N

29011955 N

920206781 N

704019132 N

917054110 N

918894308 N

917479644 N

256592050 N

978824830 N

407025230 N

204012506 N

3003207 N

902368918 N

302035120 N

226014881 N

fname JOYCE DANIEL CHRISTOPHER GAIL CYNTHIA JAMES BETTIE STEVEN CONNIE ANSUUSTE LOUISE EDWIN NADA WILLIAM MATTHEW JOHN DOROTHY FRANK BONNIE THELMA SALVACION HERMAN CHRISTIAN EDNA MICHAEL DALE THOMAS VIOLETTE STEVEN MILTON GENE JOYCE LEE

dob 1918 1946 1977 1946 1965 1929 1938 1952 1965 1947 1929 1922 1935 1970 1978 1948 1924 1924 1944 1921 1928 1916 1922 1930 1977 1953 1937 1928 1953 1922 1948 1927 1935

date_registered 2014-10-01 1994-09-23 1995-03-28 1996-12-06 1996-11-22 1998-02-26 1990-02-15 2004-08-30 2007-03-15 2001-10-04 2001-01-30 1977-09-21 1991-10-03 1997-08-20 1996-04-03 1991-11-06 2000-03-21 2004-10-04 2003-03-27 1995-09-15 2005-11-09 1943-12-04 1993-10-04 2000-09-20 2000-11-22 2012-10-06 2009-02-27 1996-09-30 2004-02-11 1983-04-21 2013-01-29 1999-08-10 1976-07-21

ssdi_dod 2018-01-26 2019-08-15 2019-08-11
2019-02-25 2019-08-25 2019-12-24 2019-10-30 2019-04-15 2015-05-08 2019-10-15
2018-01-28 2019-10-08 2019-08-28 2018-12-02 2018-05-12 2018-02-11 2019-08-27 2018-01-30 2019-05-24 2017-11-29 2018-12-15 2019-11-18 2019-08-22 2018-05-20
2019-10-31 2019-08-07
2020-01-09 2019-12-09

obit_dod 2018-01-26 2019-08-15 2019-08-11 2019-01-22 2019-02-25 2019-08-25
2019-04-15
2019-10-15 2013-01-03 2018-01-28 2019-10-08 2019-08-28 2018-12-02 2018-05-12 2018-02-11 2019-08-27 2018-01-30
2018-12-15 2019-11-18
2019-09-10 2019-10-31 2019-08-07 2018-12-06 2016-02-06
2019-12-09

Exhibit B, Page 227

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 228 of 352 Pageid#: 1131

voter_id

lname

607011736 N

620944533 N

917721068 N

305017671 N

917122011 N

918237132 N

918670742 N

702008893 N

702004547 N

705018624 N

920205706 N

608012529 N

6003527 N

807000826 N

211077034 N

917886738 N

919950039 N

602005797 N

919037630 N

122006350 N

204015986 N

920346755 N

918024314 N

701018625 N

407000296 N

918271136 N

25017150 N

35821521 N

918882655 O

505002264 O

703009424 O

806000827 O

918986291 O

fname ROBERT GERALD ALEX CHARLES GLORIA LOUISE SUSAN EDWARD ELISABETH FRANK MAYNELLE ANTONIO MAX JANET CHARLES KATHARINE DARTRELL LEONARD JAMES HENRY RALPH CARL BETTINE ARNOLD ROBERT MICHAEL CARL LARS POK MARY TROY HARRISON ELMER

dob 1942 1939 1925 1947 1950 1933 1943 1934 1940 1936 1938 1941 1941 1927 1957 1957 1970 1940 1946 1936 1940 1950 1945 1936 1941 1943 1948 1931 1924 1920 1939 1939 1935

date_registered 2009-04-28 2012-07-23 1996-10-04 1976-10-01 2002-12-19 1998-04-07 2000-01-20 1978-02-22 1986-10-03 1978-03-22 2005-10-28 1980-10-04 1964-10-03 1957-05-03 2016-10-17 1997-02-04 2004-09-30 2000-05-03 2001-02-08 1970-02-20 1972-08-18 2006-08-25 1999-05-03 1995-12-28 1999-08-31 1998-05-06 2000-08-23 2010-09-02 2000-09-13 1980-09-30 1962-01-08 1963-10-02 2000-11-21

ssdi_dod
2018-12-28 2020-01-19 2019-12-13 2019-11-14 2019-08-09 2019-07-06 2019-10-28 2019-11-08 2018-12-28 2018-12-12 2004-02-01 2019-11-28 2016-11-04 2019-09-20 2018-07-10 2017-11-28 2019-12-13 2019-12-10 2019-09-06
2019-08-07
2019-10-21 2019-08-31 2019-05-29 2019-08-06 2018-04-15 2017-07-18 2019-12-05 2018-12-17 2018-12-29 2018-12-10

obit_dod 2016-11-30 2018-12-28
2019-12-13
2019-08-09 2019-07-06
2019-11-07
2018-12-12
2019-11-28 2016-11-04 2019-09-20 2018-07-10 2017-11-28
2019-09-06 2019-09-16 2019-08-07 2014-09-11 2019-10-21
2019-08-06
2017-07-18 2019-12-05 2018-12-17 2018-12-29 2018-12-10

Exhibit B, Page 228

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 229 of 352 Pageid#: 1132

voter_id

lname

6003207 O

503005711 O

707013171 O

513008890 O

918997721 O

429260928 O

918706360 O

912022911 O

909017594 O

481450 O

550774526 O

310042053 O

309040287 O

918794197 O

301041025 O

307035705 O

919870051 O

302041415 O

518008703 O

917267518 O

437187434 O

604015777 O

404020075 O

226019476 O

502016755 O

8511614 O

919945886 O

919109692 O

917037278 O

97977549 O

902020477 O

257250307 O

918454436 O

fname CUSTIS INGE ROBERT RICHARD JAMES THELMA JAMES ROBERT JOSEPH THOMAS SHIRLEY MARGARET PATRICIA CATHERINE WILLIAM LINDA DONALD JUDITH ALFRED BRIGIDA MARILYN PATRICK LARRY MARY PAGE SONIA MARGARET BILLIE MARY SEAN HELEN GERALD RUBY

dob 1922 1937 1931 1935 1936 1948 1944 1933 1945 1941 1936 1973 1946 1932 1927 1947 1933 1948 1928 1951 1932 1935 1944 1931 1930 1960 1929 1941 1947 1934 1926 1932 1938

date_registered 1961-11-18 1986-12-11 1980-03-04 1990-04-03 2000-12-06 2013-08-22 2000-03-09 1992-08-26 1995-09-21 2015-08-04 2008-04-17 1997-01-03 1992-09-14 2000-05-31 1988-07-15 1983-09-28 2004-09-07 1980-09-03 1989-08-24 1995-04-12 2018-03-12 1978-05-12 1986-09-13 1965-12-08 1967-06-05 2010-02-04 2004-10-04 2001-05-14 1993-09-29 2018-08-28 1986-12-03 2016-08-05 1999-03-17

ssdi_dod 2019-09-09 2019-12-21 2020-01-23 2019-10-03 2019-09-25 2019-09-10
2019-12-16 2019-08-16 2019-08-06 2019-06-09 2018-07-21 2020-01-17 2019-12-16 2019-10-27 2019-10-11 2018-09-17 2019-10-06 2019-06-18 2019-10-20 2019-09-26 2019-08-08 2018-12-17 2016-09-14 2018-12-28 2018-04-18 2019-08-21 2017-11-24
2020-01-20 2019-12-22 2019-10-14 2018-12-13

obit_dod
2019-12-21
2019-09-25 2019-09-11 2015-05-06
2019-08-16
2019-06-09
2019-10-27
2018-09-26 2019-10-06 2019-06-18
2019-09-26 2019-08-08 2018-12-17 2016-09-14
2018-04-18 2019-08-21 2017-11-24 2016-09-14
2019-12-22
2018-12-13

Exhibit B, Page 229

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 230 of 352 Pageid#: 1133

voter_id

lname

233554981 O

230005501 O

603004944 O

206021684 O

228022115 O

920185323 O

109014216 O

19885504 O

948718091 O

204013611 O

307016107 O

712002411 O

11001601 O

909013115 O

106844227 O

221007671 O

918414562 O

91421674 O

901005997 O

305030797 O

625118266 O

920409749 O

406023725 O

301051962 O

405016482 O

708023276 O

307026708 O

917530769 O

26010707 O

901016708 O

21007618 O

225007987 O

918595216 O

fname STEPHEN DAVID RONALD JOSEPH RICHARD AUDREY CURT ONWUSONGONYE KEZIAH JENNIE PAUL MARK ROBERT DOROTHY EDWARD PATRICK ALBERT CHARLES BETTY ANTONETTE BILLIE LARRY RUSSELL SHIRLEY MARY ENOLA GRACE BECKY LUCILLE CONNIE GEORGE LINA JANICE

dob 1949 1930 1942 1920 1947 1924 1948 1938 1939 1916 1944 1961 1957 1928 1937 1943 1945 1928 1944 1923 1943 1946 1932 1927 1934 1934 1931 1970 1930 1950 1939 1937 1934

date_registered 2009-12-10 1952-09-12 2001-08-27 1992-09-29 1987-09-19 2005-10-06 1971-08-11 2007-12-03 2008-10-06 1980-08-19 1983-10-04 1988-10-03 1989-09-30 2004-03-12 2017-06-14 1992-04-04 1999-01-15 2008-10-06 1996-04-15 1951-06-14 2016-10-21 2006-12-01 1984-08-31 1980-06-11 1988-10-03 1989-10-07 2006-04-25 2003-09-04 2006-06-14 1993-01-14 1964-07-31 1995-06-14 1999-09-27

ssdi_dod 2018-12-23 2016-09-16 2019-07-29
2020-01-20 2019-09-01
2019-12-17 2019-12-29 2007-06-25 2019-09-28 2018-12-21 2019-10-16 2018-12-04 2019-03-21
2019-11-29 2014-02-02 2019-05-15 2018-05-24 2020-01-05 2019-09-30 2018-12-18 2018-12-13 2018-12-06 2018-01-29 2015-03-29 2019-01-01 2018-03-27 2013-10-15
2015-03-27 2018-12-20

obit_dod 2016-09-16 2019-07-29 2015-12-29 2019-09-01 2018-12-13
2019-09-28 2019-10-16 2019-03-21 2017-03-04 2019-11-29 2014-02-02 2018-05-24
2018-12-06 2015-03-29
2013-10-15 2019-08-28 2018-12-20

Exhibit B, Page 230

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 231 of 352 Pageid#: 1134

voter_id

lname

607011738 O

185743206 O

25076846 O

737635732 O

225017981 O

605034720 O

682924505 O

903001090 O

606032362 O

90008796 O

124794053 O

27010418 O

917162403 O

405026448 O

68216602 O

177430153 O

904008524 O

910008524 O

446226458 O

917625686 O

917623852 O

301035708 O

306033561 O

205003327 O

202017018 O

103025476 O

917742436 O

305002485 O

107011601 O

917111516 O

918031798 O

917106023 O

402353243 O

fname MARY MARYELLEN RICHARD OMAR DAVID BARBARA MARGARET EVA ALVIS CHRISTOPHER MARY NATHAN ROBERT WILLIAM ELIZABETH BARBARA JAMES MOYRA MARIE PAMELA BEATRICE LEWYN CHARLES LOREN STUART RUSSELL JOEL CATHERINE ELEANOR ROGER CHARLES SARAH GEORGE

dob 1933 1946 1929 1934 1940 1940 1935 1935 1921 1969 1948 1932 1927 1937 1929 1928 1934 1935 1924 1967 1930 1922 1938 1942 1936 1936 1945 1935 1923 1944 1944 1940 1948

date_registered 1986-10-04 2010-04-29 2010-04-29 2012-05-21 1974-05-14 1976-09-09 2008-01-14 1976-04-02 1947-05-02 2012-09-12 2012-02-09 1957-12-06 1994-09-16 1984-10-02 2012-06-14 2012-09-18 1984-02-21 1972-05-09 2008-11-20 1996-09-03 1996-08-28 1949-12-08 1972-10-06 1972-10-07 1972-01-19 1979-07-05 1996-10-07 1987-09-12 1999-04-13 1994-04-22 1997-06-23 1994-04-04 2018-06-14

ssdi_dod 2018-12-18 2019-11-17 2018-03-19 2018-09-08 2018-12-28
2020-01-30
2019-12-13 2019-10-28 2019-10-22 2019-09-30 2017-11-19 2019-08-29 2019-10-25 2018-12-24 2018-12-08 2019-11-01 2019-09-01 2019-10-18 2016-09-11 2015-03-28 2019-09-19 2019-11-23 2019-08-17 2019-08-01
2019-04-15
2019-10-03 2018-03-11 2019-10-10 2018-11-14

obit_dod 2018-12-18 2019-11-17
2018-12-28 2019-10-20
2019-09-23
2019-10-28 2019-10-22
2017-11-19 2019-08-28 2019-10-25 2018-12-24 2018-12-08 2019-11-01 2019-09-01 2019-10-18 2016-09-11
2019-09-19 2019-11-23 2019-08-17 2019-08-01 2019-11-10 2019-04-15 2018-05-25 2019-10-03 2018-03-11

Exhibit B, Page 231

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 232 of 352 Pageid#: 1135

voter_id

lname

917298490 O

906001420 O

917643375 O

38086022 O

302006061 O

307006061 O

951118483 O

917405067 O

918887293 O

919458504 O

225011732 O

124012182 O

504009859 O

209009615 O

201001592 O

601028880 O

602028877 O

918025851 O

173014766 O

342614327 O

918129080 O

917052583 O

91788162 O

308038114 O

309032683 O

605018615 O

913023622 O

607032515 O

917105047 O

506029550 O

302047234 O

603002903 O

917471908 O

fname LEONARD ROBERT WILLIAM WILLIAM JOSEPH KAREN CRESENCIANO JOSEPH JEAN JAMES WILLIAM EARL MARY JAMES ELLIE WILLIAM KATHLEEN FERNANDO LINDSEY JOANNE GALEN FRANCES HENRY MERLE MANUEL EDWIN MARGARET CHARLES JANICE BRENDA JOHN THELMA PATTON

dob 1937 1938 1938 1947 1942 1945 1956 1937 1932 1937 1933 1926 1943 1936 1943 1928 1928 1944 1981 1939 1942 1943 1973 1919 1930 1931 1951 1945 1937 1947 1952 1923 1945

date_registered 1995-07-06 1987-04-15 1996-09-10 2017-04-11 1992-08-13 1988-03-23 2009-02-23 1997-02-05 2000-09-15 2003-01-16 1979-10-01 1999-09-09 1999-01-08 1957-08-03 1999-09-13 1959-09-04 1951-10-02 1997-06-11 2007-09-20 2010-12-02 1997-11-05 1993-10-04 2017-06-26 1964-04-28 1990-09-20 1999-05-10 1990-05-08 1966-09-16 1994-04-02 1977-10-07 1988-03-28 1980-09-02 1996-04-22

ssdi_dod 2019-09-05 2017-01-15 2016-10-10 2019-09-17 2019-12-21 2019-11-14 2018-01-31
2012-12-13
2019-12-31 2019-12-18 2019-12-07 2019-06-29 2019-05-27 2019-03-30 2019-03-18 2018-11-11 2018-02-28 2018-01-17 2019-09-20 2019-11-22 2019-11-11 2008-02-25 2018-12-22 2020-01-21 2019-10-13 2020-01-01 2018-07-06 2019-10-17 2018-12-01 2018-01-23 2019-09-01

obit_dod
2017-01-15 2016-10-10
2019-11-14
2019-06-29
2015-08-23
2019-12-18 2019-12-07 2019-06-29
2019-03-30 2019-03-18 2018-11-11 2018-02-28 2018-01-17 2019-09-20
2018-12-22
2019-10-13
2018-07-06 2019-10-17
2018-01-23 2019-09-01

Exhibit B, Page 232

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 233 of 352 Pageid#: 1136

voter_id

lname

102023684 O

920057050 O

109614958 O

32010943 O

601001152 O

260685838 O

706006035 O

509006472 O

918623385 O

232023068 O

212025357 O

920129867 O

909016529 O

505009337 O

27017960 O

212024942 O

183757683 O

712809610 O

306024688 O

403016831 P

612016585 P

917024623 P

721617193 P

919823222 P

406012064 P

605003349 P

607018902 P

45974276 P

307007864 P

211005014 P

602010545 P

603006939 P

919864705 P

fname EDNA LEE JOHANNA JAMES SAMUEL JOSEPH VIRGINIA RANDY JOANN CLARICE BILLY CHAD BARBARA BERYL MAJORIE LEONA IRENE MILDRED ANNETTE RAYMOND MARK MARY JULIO JOSE RUTH WOODROW JUANITA STACCATO LILLIAN ANNA CHARLOTTE M PAUL OLIVER

dob 1921 1935 1935 1946 1942 1942 1935 1956 1953 1941 1938 1975 1941 1926 1927 1938 1929 1912 1928 1941 1953 1927 1943 1946 1925 1945 1942 1961 1923 1942 1946 1930 1948

date_registered 2000-07-21 2005-02-14 2013-10-11 1997-09-03 1963-05-01 2016-09-20 1961-05-01 1991-10-05 1999-11-09 2000-05-03 1991-10-03 2005-07-07 1998-01-15 1948-07-03 1972-07-17 1990-07-23 2013-12-04 2012-09-18 1956-10-06 1999-11-18 1988-11-12 1993-09-18 2007-10-04 2004-08-03 1964-09-28 1989-10-05 1980-09-18 2012-10-12 1976-10-02 1992-10-03 1984-05-21 1993-07-01 2004-09-02

ssdi_dod 2013-06-10 2018-05-24
2020-01-21 2019-09-22 2019-11-16 2019-10-31 2019-09-12 2019-08-01 2019-06-07 2018-12-18 2018-07-15 2018-05-22 2016-03-31 2015-11-22
2015-04-26 2019-08-12 2019-10-21 2019-10-01 2017-05-08 2020-01-10 2018-10-16 2019-12-22 2019-11-27 2019-11-05 2019-10-18 2019-09-02 2018-12-31 2019-07-16 2019-10-10 2019-09-02

obit_dod 2013-06-10 2018-05-24 2016-12-18
2019-09-22 2019-11-16 2019-10-31
2019-08-01 2019-06-07 2018-12-18 2018-07-15
2016-03-31
2019-08-20 2019-08-07
2019-10-21
2017-05-08
2019-12-22 2019-11-27 2019-11-05 2019-10-18 2019-09-02 2018-12-31
2019-10-10 2019-09-02

Exhibit B, Page 233

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 234 of 352 Pageid#: 1137

voter_id 122019861 P 501029227 P 124019861 P 920335006 P 212098292 P 589614709 P 919419049 P 905016711 P 409006840 P 917006439 P 917296504 P 514006059 P 201028665 P 208009349 P 128019143 P 107022274 P 919408033 P 311006064 P 606029757 P 506012603 P 232012366 P 919514430 P 301002299 P 254769272 P
67265236 P 301030306 P 311018084 P 914731686 P 503402819 P 405003360 P 101021501 P 503004759 P 124020308 P

lname

fname OPAL ORIS ROBERT ANNE MICHAEL JERRY LULA MARJORIE RONALD RICARDO DANILO GERALDINE MICHAEL AREATHA JUNE WILLIAM ARLENE JAMES MILDRED MARGUERITE MARY KI BYONG JAI JOYCE JEROME BALRAJ ANTHONY TYRONE JAMES ROBERTA LEWIS MARY

dob 1920 1949 1921 1946 1961 1953 1947 1919 1940 1928 1951 1939 1952 1928 1942 1919 1934 1929 1926 1922 1922 1933 1934 1957 1934 1932 1938 1944 1949 1923 1938 1965 1946

date_registered 1982-08-24 1992-09-18 1982-08-24 2006-08-04 2011-06-14 2008-04-04 2002-10-07 1949-08-05 2000-03-08 1993-07-31 1995-06-24 2009-03-03 1989-10-04 1951-06-12 1964-09-25 1953-06-13 2002-10-02 1992-04-08 1957-09-03 1997-03-21 1992-09-12 2003-05-07 1982-09-30 2008-06-18 2015-11-18 1976-09-02 1977-05-11 2016-07-13 2016-09-08 1973-05-05 1980-10-03 1991-09-30 1968-10-01

ssdi_dod 2019-08-28 2019-07-17 2018-12-19 2018-12-14 2018-08-21 2018-05-27 2017-12-05 2013-08-21 2020-01-03 2019-10-11 2018-12-29 2019-12-19 2019-02-27
2019-11-01 2019-09-08 2019-05-29 2018-12-20
2018-09-18 2017-10-14
2019-10-10 2019-09-26 2019-12-31
2020-01-03 2019-11-17 2018-04-24 2019-11-20 2018-10-23 2018-03-27

obit_dod
2018-05-26
2013-08-21
2018-12-29 2019-12-19 2019-02-27 2019-10-01 2019-11-01 2019-09-08
2018-12-20 2019-09-28 2017-02-12 2018-09-18
2019-08-18
2019-09-26
2017-01-05
2019-11-17 2018-04-01 2019-11-20 2018-10-23 2018-03-27

Exhibit B, Page 234

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 235 of 352 Pageid#: 1138

voter_id 917127617 P 307032685 P 918754039 P 259770850 P 920325673 P 919945120 P
11955480 P 693993741 P 918176724 P 506023244 P 919143041 P 506028665 P 181112322 P
53667175 P 919696820 P 901006635 P 206747321 P 919658622 P
25001742 P 302004684 P 604001152 P 109022406 P 919251073 P 125011446 P 918561615 P 121007124 P 205004794 P 401006414 P 920241118 P 221009405 P 232920784 P
65045567 P 104114512 P

lname

fname RUTH MARY DEBRA DIONISIO SHARON FRANCIS THELMA CAROL SYBIL WILLIAM FRANCES GEORGE POLLYANNA JOSEPH ANGELINA EDD RAMNIK DELKISHA GERTIE SONIA DEWEY GLENN CECILIA VIOLA WILLIE NOBUKO JOHNNY CONSTANCE LARRY WALTER RANDOLPH ELIJAH JAMES

dob 1922 1923 1959 1936 1946 1972 1940 1936 1938 1934 1929 1933 1931 1927 1929 1940 1944 1986 1935 1936 1929 1931 1952 1925 1945 1928 1931 1951 1946 1946 1951 1950 1933

date_registered 1997-05-12 1997-02-24 2000-04-13 2010-08-17 2006-07-13 2004-10-04 2012-10-15 2010-12-03 1997-12-30 1955-12-31 2001-07-16 1998-12-10 2015-05-04 2016-10-20 2004-02-26 1991-09-17 2015-08-14 2003-12-16 1974-11-12 1972-05-13 1979-09-13 1972-09-14 2001-12-28 1964-09-24 1999-08-11 1984-09-22 1996-05-15 1996-05-10 2006-01-23 1992-10-01 2008-10-01 2016-10-17 2011-09-13

ssdi_dod 2015-03-30
2019-09-30 2019-09-03 2019-10-01 2018-12-31
2019-11-02 2019-08-29 2019-12-22
2019-10-29 2019-11-09 2018-06-20 2018-12-02
2020-01-16 2019-11-08 2019-10-25 2019-07-01 2019-05-20 2019-05-17 2018-12-30 2018-12-28 2018-12-27 2018-09-22 2018-04-13 2018-02-16 2018-02-04

obit_dod 2015-03-30 2019-10-16 2019-09-30 2019-09-03 2019-10-01
2019-08-30 2018-12-10 2016-09-19 2019-09-29
2019-08-29
2019-09-17 2019-10-29 2019-11-09
2018-12-02 2019-09-17 2018-12-03
2019-11-08 2019-10-25 2019-07-01
2019-05-01 2018-12-30
2018-12-27

Exhibit B, Page 235

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 236 of 352 Pageid#: 1139

voter_id 905016935 P 801017430 P 357327448 P 564978789 P 303051968 P 918427335 P 917896127 P 608013973 P 106000617 P 513004420 P 110018338 P 920369687 P 205014562 P 507008263 P 502021869 P
33400067 P 122008930 P 807010268 P 108003066 P 504010240 P 490251028 P 501010307 P 918324704 P 709006124 P 917050731 P 106011434 P 304002489 P 920304927 P 511016698 P 917346204 P 370008393 P 268794404 P 112024811 P

lname

fname JOYCE JOYCE ROSE WILLARD SEIJA ROBIN RICHARD FRED ISABELL WILLIAM ANNE KARIN HARVEY CHARLES HELEN ANTHONY FRANCES GRACE JOY LORETTA HERMAN TROY MARILYN IRIS MABLE RUTH CLIFFORD GABRIELLA GORDON DILLARD ERNESTINA DIANE CAROLE

dob 1935 1929 1944 1917 1941 1948 1948 1944 1926 1941 1933 1948 1947 1936 1921 1994 1958 1921 1935 1937 1931 1933 1938 1928 1922 1921 1946 1944 1928 1930 1927 1939 1941

date_registered 1992-10-03 1974-11-06 2016-04-26 2008-10-06 1990-06-21 1999-02-04 2003-04-07 1972-10-03 1947-07-05 1992-10-03 1988-08-24 2006-10-02 1976-08-23 1971-10-02 1949-04-21 2016-03-04 2002-03-12 1997-10-06 1964-09-30 1959-05-20 2008-09-25 1998-02-26 2003-08-19 1967-04-29 2005-01-25 1966-05-16 1991-08-03 2006-06-14 1955-05-13 1995-10-02 2018-02-12 2008-04-30 1988-09-07

ssdi_dod 2018-01-24 2017-12-28 2017-11-28 2009-03-11
2018-12-30 2018-12-15 2018-04-29 2017-12-07
2018-12-03 2019-08-15 2018-12-21 2019-06-30 2018-03-31 2014-11-05 2019-09-24 2018-03-31 2018-03-18 2017-12-12 2019-09-20 2018-09-05 2019-08-20
2019-11-23 2019-10-07
2018-12-27 2020-01-23 2019-11-02

obit_dod 2018-01-24 2017-12-28 2017-11-28
2019-09-22 2018-12-17 2016-11-25 2017-12-29 2018-12-30
2018-04-29
2018-12-04 2018-12-03 2019-08-15 2018-12-21
2018-03-31
2019-09-24
2018-03-18 2017-12-12 2019-09-20 2018-09-05 2019-08-22 2019-11-08
2018-12-14 2018-12-27
2019-11-02

Exhibit B, Page 236

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 237 of 352 Pageid#: 1140

voter_id 919429098 P 818045658 P 148744820 P 920203535 P
46451170 P 119448886 P 832022008 P 358884395 P 710027020 P 308047502 P 917635432 P 919870037 P 156154739 P 205028258 P 685192340 P 918630543 P 122019273 P 501026764 P 503023246 P 106007333 P 917086380 P 514016698 P 267995474 P 917532123 P 405008250 P 711005652 P 917906281 P 314597777 P 107468910 P 907020874 P 806018527 P 917569024 P 227732588 P

lname

fname ROBERT ISHWERBHAI KANTABEN KAMLABEN VINODCHANDRA ROHITKUMAR KANTIBHAI DINESHKUMAR SANDRA DONALD MORA RODNEY ALPHEUS GLORIA MARGARET LARRY MARY ROBERT ANITA RICHARD DENISE THOMAS RUBY MILTON LUCILLE FLOYD EDWARD BRADFORD THADEUS MARY JANICE PASTORA BRUCE

dob 1971 1937 1940 1926 1947 1955 1945 1949 1945 1946 1926 1945 1934 1945 1944 1948 1929 1937 1922 1954 1960 1947 1937 1962 1930 1933 1934 1954 1936 1923 1931 1935 1944

date_registered 2002-11-13 2008-07-11 2008-10-06 2005-11-09 2017-03-23 2012-07-23 2012-07-24 2017-05-03 1967-10-07 2006-08-25 2001-04-18 2004-09-03 2017-06-26 1991-09-12 2008-03-22 2001-09-12 1984-08-24 1964-10-03 1983-04-21 2000-09-22 2000-03-09 1991-09-16 2007-01-09 1997-07-25 1992-10-03 1990-03-06 1997-02-24 2012-07-25 2015-03-03 1952-05-02 1960-09-10 2000-10-10 2017-04-06

ssdi_dod 2019-06-12 2019-12-11 2018-10-05 2018-01-19 2017-11-28 2017-09-26 2012-12-15
2019-03-27
2020-01-16 2019-12-02 2019-10-31 2019-10-26 2019-10-16 2019-09-27 2019-08-14 2019-08-14 2019-05-26 2018-03-02 2016-09-12 2016-09-08 1995-03-25
2019-10-29 2019-09-09 2019-12-13 2018-12-14 2019-10-20 2018-12-22

obit_dod 2019-06-12
2019-10-21 2018-12-09 2019-08-25 2019-03-27 2018-09-05
2019-12-02 2019-10-31 2019-10-26 2019-10-16
2019-08-14 2019-08-14 2019-05-26
2016-09-12 2016-09-08
2019-10-11 2019-03-05
2019-12-13
2018-12-22

Exhibit B, Page 237

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 238 of 352 Pageid#: 1141

voter_id 2918539 P
712013352 P 105025855 P 208007356 P 701000053 P 918485592 P 920403836 P 122018032 P 705016930 P 405000013 P 128008187 P 323236462 P 919565405 P 503009863 P 615000868 P 224014890 P 905016365 P 917286428 P
24019799 P 130008791 P 918153310 P 703014858 P 701016932 P 602032064 P 907001735 P
24011519 P 23002172 P 302030310 P 206012195 P 22002639 P 158374753 P 301065206 P 101017387 P

lname

fname HENRY ANNA MARY STAN ELWOOD DANIEL HELENA LINDA DANIEL CATHARINE ALFRED ATHELIA SUSAN PAULINE RUBY CONSTANCE KRISTA EDNA DEVLAMING CAROLYN LESLIE WILLIAM DORIS IRENE ELGIN KATHLEEN FAYE FRANCES KENNETH JOHN DIANA ROBERT MILDRED

dob 1930 1928 1947 1941 1947 1953 1960 1950 1934 1935 1937 1933 1910 1920 1932 1934 1963 1906 1939 1942 1945 1943 1955 1924 1929 1928 1933 1937 1945 1942 1961 1949 1932

date_registered 2008-02-26 1990-03-31 2000-05-19 2005-02-17 1983-10-08 1999-04-22 2006-11-21 1980-09-23 1967-10-06 1976-09-24 1960-12-05 2008-04-01 2003-08-01 1951-08-29 1992-09-29 2003-09-24 1998-01-08 1995-05-12 1980-09-29 2001-11-07 1997-11-05 1974-04-01 1976-09-21 1964-07-03 1989-09-16 1976-03-25 1964-04-13 1993-09-21 1997-08-19 1964-09-14 2007-08-17 2012-05-17 1974-03-28

ssdi_dod 2018-12-09 2020-01-02 2019-11-22 2019-10-22 2019-10-14 2019-09-25 2019-09-04 2019-08-10 2018-06-30 2017-10-28 2017-03-22 2014-10-24 2011-07-09
2019-11-12 2018-02-08 2004-12-07 2019-11-03 2019-10-12 2018-12-24 2018-10-31 2019-10-10 2019-11-07 2019-12-02
2019-12-10 2019-09-12 2019-09-01 2018-05-09 2017-05-31

obit_dod 2018-12-09
2019-11-22 2019-10-22 2019-10-14 2019-09-25 2019-09-04 2019-08-10 2018-06-30 2017-10-28
2014-10-24 2011-07-09 2018-04-28 2015-06-20
2018-02-08 2004-12-07 2019-11-03 2019-10-12 2018-12-24 2018-10-31 2019-10-10 2019-11-07 2019-12-02 2016-01-23 2019-09-07 2018-12-09 2019-12-10 2019-09-12

Exhibit B, Page 238

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 239 of 352 Pageid#: 1142

voter_id 301018370 P 208017026 P 425187309 P 919701209 P 917062006 P 918339930 P 111021651 P 126006871 P 411018498 P
22015234 P 919594073 P 228001025 P 918154417 P 124003862 P 917321514 P 701006932 P 917332725 P 103013941 P 507712518 P 917062269 P 919896853 P 609008433 P 110023141 P 123002309 P 636327244 P 603018071 P 805010959 P 285610926 P 908021181 P 205009110 P 918910980 P 103024092 P 388577517 P

lname

fname ELEANOR NORA WHITE SANDRA HOWARD CLIFTON GARY CECELIA CAROLYN ANNETTE ENOLA SUZANNE CHARLES EDWARD LAWRENCE LUCIAN HENRY JEREMY NANCY HILDA DORIS JOSEPH PHYLLIS JEAN CHARLES DOROTHY EVELYN DOROTHY ALICE SHIRLEY HAYWOOD SANDRA THOMAS FRANKLIN

dob 1919 1940 1942 1940 1955 1948 1955 1933 1951 1938 1938 1927 1935 1935 1947 1947 1933 1923 1946 1926 1919 1943 1934 1937 1924 1928 1926 1963 1933 1927 1955 1939 1948

date_registered 1975-11-06 1980-09-13 2012-09-19 2004-03-02 1998-05-04 1998-09-16 2009-03-20 1972-07-27 2003-01-09 1995-11-08 2003-09-16 1952-05-01 1997-11-05 1956-08-23 1995-09-07 1975-05-27 1995-09-21 1976-09-11 2016-07-06 1993-12-06 2004-09-03 1984-10-06 1992-09-30 1976-09-25 2016-05-12 1956-10-05 1976-10-02 2017-04-26 1969-10-03 1957-06-08 2000-09-29 1976-09-04 2013-04-25

ssdi_dod
2019-12-03 2014-01-13 2019-12-09 2019-09-26 2017-11-06 2016-12-08 2019-11-11 2019-08-11 2019-11-07
2019-11-28 2018-12-10 2019-09-09 2010-06-09 2019-10-30
2019-11-27 2018-12-25 2013-11-01 2019-08-11
2019-12-03
2018-01-31 2019-11-09
2018-05-12 2019-12-04 2019-12-10 2019-10-04

obit_dod 2019-09-05
2019-12-09 2019-09-26
2016-12-08 2019-11-11
2019-11-07 2017-09-05 2019-11-28
2010-06-09 2019-10-30 2019-08-02 2015-05-27 2019-08-01 2019-11-27
2013-11-01 2019-08-11 2019-05-22 2019-12-03 2019-10-02
2018-12-13 2018-05-12
2019-12-10 2019-10-04

Exhibit B, Page 239

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 240 of 352 Pageid#: 1143

voter_id 408028680 P 707805047 P 244440630 P 201002697 P 602027291 P 402014376 P 803006094 P 919600410 P 607032367 P 125002955 P 110024231 P 204001953 P 305051972 P 205011368 P 297338860 P 507008264 P 226012706 P 919135857 P 918359947 P 597814764 P 126006062 P 127009616 P 227021937 P 641442663 P 604033593 P 918082696 P 227018603 P 704009166 P 909004221 P 465150328 P 917997472 P 918735297 P 226001678 P

lname

fname WAYNE DANNY ROSBEL EDITH SWAIN MABEL ANITA ROGER JAMES MARTHA CARLISS CHARLES MATTHEW PAUL JAMES FRANK THOMAS CLYBURN CARLTON JAMES JOYCE DOLORES THOMAS HENRY MARY JAMES WILLIAM PHILIP ROBERT EVERETTE WENDY VERDELL JULIA

dob 1947 1946 1981 1924 1937 1933 1937 1955 1946 1937 1932 1928 1945 1935 1946 1940 1944 1946 1946 1954 1930 1936 1970 1960 1926 1948 1923 1948 1935 1934 1967 1963 1927

date_registered 1972-09-26 2018-08-21 2018-11-13 2005-11-16 1987-09-29 1963-09-30 1984-03-29 2003-09-26 2006-02-02 2000-01-07 1985-06-04 2011-09-08 1976-02-12 1980-02-19 2016-05-26 1984-04-11 1992-06-24 2001-07-02 1998-10-05 2015-02-27 1959-05-04 1982-09-15 1998-09-16 2016-10-17 1992-02-04 1997-09-08 1964-10-03 1984-10-06 1992-11-12 2007-03-22 1997-04-25 2000-03-28 1984-01-23

ssdi_dod 2017-11-09 2018-09-30 2019-03-25 2019-12-23 2019-11-27 2019-11-20 2019-08-01 2018-08-26 2018-06-03
2019-09-08
2019-11-26 2019-11-25 2019-11-03 2019-08-18 2019-08-04 2019-07-11 2018-08-26 2017-12-16 2017-10-25
2018-07-21 2016-05-28 2019-10-11 2019-08-10

obit_dod
2018-09-30
2019-12-23 2019-11-27 2019-11-20
2018-08-26 2018-06-03 2018-12-26 2018-12-19 2018-12-06 2019-10-02 2018-12-25 2019-09-08 2019-08-17 2019-11-26 2019-11-25 2019-11-03 2019-08-18 2019-08-04
2018-08-26 2017-12-16 2017-10-25 2019-09-06 2019-08-28 2018-12-09 2017-10-11 2018-07-21 2016-05-28 2019-10-11

Exhibit B, Page 240

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 241 of 352 Pageid#: 1144

voter_id 229991315 P 447145081 P 918426356 P 917435653 P 501005357 P
1321934 P 303608589 P 919793192 P 918584802 P 917359689 P 947032628 P 206014709 P 918375778 P
61449333 P 804005899 P 704015720 P 603015329 P
86593766 P 919262584 P 918637874 P 918401367 P 919343847 P 228000492 P 607002471 P 125009818 P
60776671 P 213011674 P 927365153 P 917358558 P 918950774 P 392203469 P
45440498 P 102023284 P

lname

fname LEON KATHERINE KURT IMOGENE CHARLENE MARY LANNY KENNETH ELIZABETH NANCY PHILIP HERBERT MICHAEL VIOLA HELEN AGATHA JUANITA HELEN WARREN JOHNNY VIMALA DORMA BETTY HARRY KATIE ERIC CALVIN TAT THUAN BON TRUNG WILLIAM JOAN

dob 1956 1947 1961 1949 1943 1937 1936 1942 1929 1955 1935 1929 1958 1913 1924 1927 1925 1931 1943 1944 1965 1933 1936 1940 1948 1936 1948 1934 1930 1941 1945 1924 1940

date_registered 2007-03-14 2014-01-03 1999-01-13 1996-03-26 1992-09-26 2014-10-20 2007-05-14 2004-06-25 1999-09-15 1995-10-06 2007-08-20 1980-08-19 1998-11-09 2012-09-14 1955-12-13 1948-09-30 1980-07-19 2018-10-15 2002-01-25 1999-11-12 1998-12-16 2002-06-13 1992-09-16 1980-10-03 1979-09-17 2010-07-08 1997-09-03 2008-08-04 1998-01-09 2000-10-10 2018-05-16 2017-10-12 1987-10-20

ssdi_dod 2018-12-07
2019-05-19 2016-05-31
2020-01-27 2019-12-16 2019-11-27 2019-10-25 2019-08-22 2018-12-02 2018-02-08 2017-06-12
2019-07-07 2015-03-30
2019-09-07 2020-01-14 2019-11-23 2018-12-10 2018-12-06 2018-09-12
2019-12-04 2019-11-22 2019-12-11 2019-10-21 2019-04-02 2018-11-02 2019-09-26 2018-12-22

obit_dod 2018-12-07 2018-12-05
2019-09-15 2017-12-18
2019-12-16 2019-11-27 2019-10-25 2019-08-22 2018-12-02
2015-11-04 2019-07-07 2015-03-30 2019-10-06 2019-09-07
2018-12-06 2018-09-12 2018-12-01
2019-12-11
2018-12-22

Exhibit B, Page 241

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 242 of 352 Pageid#: 1145

voter_id 296557788 P 806018767 P 917062631 P 604004251 P 524565752 P 918740732 P 709015722 P 208004519 P 918340986 P 917825095 P 227022569 P 309024524 P 447613722 P
31265367 P 6001315 P
920291739 P 713055191 P 404013114 P 919967150 P 101011060 P 918939607 P 612026194 P 920410445 P 207025601 P 911009992 P 917200304 P 920061593 P 107017688 P 917198770 P 917159714 P 918639340 P 307046745 P 604012535 P

lname

fname DANIEL RUTH ANNE EUGENE MARIE RICHARD SHARON THOMAS MYRTLE STEPHEN JACK MARY RICHARD ELIZABETH NELSON REMAY EMMA IRENE NEINA BARBARA LESA KITTY KEITH EMMA WILLIAM SUZETTE HELEN RAE CHARLES ADELINE MARIAN ARYA ROBERT

dob 1947 1926 1948 1939 1938 1949 1945 1928 1934 1945 1926 1943 1955 1928 1937 1931 1936 1939 1954 1944 1972 1948 1971 1927 1926 1965 1940 1923 1937 1929 1928 1930 1959

date_registered 2012-08-30 1966-04-07 1993-12-02 1960-04-23 2015-03-24 2000-03-30 1967-10-07 1998-09-04 1998-09-17 1996-11-20 1962-12-07 1991-09-29 2012-08-27 2016-10-16 1960-04-15 2006-05-03 2008-09-17 1978-10-07 2004-10-04 1988-02-01 2000-10-10 2006-03-21 2006-11-22 1979-01-18 2007-03-01 1994-10-08 2005-02-19 1964-01-24 1999-01-28 1994-09-07 2007-03-22 2005-08-24 1991-04-30

ssdi_dod 2018-12-19 2018-12-09 2016-09-12 2019-12-08 2019-11-20 2019-12-01 2019-12-27 2019-12-02 2019-10-30 2019-10-24 2019-10-19 2019-10-15 2019-09-30 2019-09-21 2019-09-15 2019-08-09 2018-12-29 2018-12-29 2018-12-25 2018-09-19 2018-08-20 2018-06-26 2017-11-30 2017-05-08 2016-12-13 2015-03-16
2014-11-15 2019-10-01

obit_dod 2018-12-19
2016-09-12 2019-12-08 2019-11-19 2019-12-01
2019-12-02 2019-11-01
2019-10-19 2019-10-15 2019-09-30 2019-09-21
2019-08-09 2018-12-29 2018-12-29
2018-09-18 2018-08-20 2018-06-26 2017-11-30 2017-05-08
2019-09-05 2019-09-01 2018-12-18 2017-08-04 2016-09-07 2014-11-15 2019-10-01

Exhibit B, Page 242

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 243 of 352 Pageid#: 1146

voter_id 801020235 P 222021000 P 304049461 P 918802484 P 123021134 P
76985089 P 416365308 P 919652814 P 106022778 P 501031081 P 917055796 P 903022607 P 503003534 P
26019330 P 918227565 P 919706813 P 917015875 P 918381924 P 918190293 P
25912742 P 28009545 P 917187869 P 917322056 P 919276990 P 289482371 P 221000495 P 303005160 P 919828851 P 906008838 P 919838996 P 918463638 P 307005160 P 918944427 P

lname

fname ELLER DELORES MARILYN CLARK PATRICIA JOSEPH ISHMAEL MYRA JOHN SALLY JAMES EVELYN WESLEY EDNA SARAH ROBT BETTY FRANCIS ROBERT RICHARD CHARLES JEAN DOUGLAS ALVOID EUGENIO J WILLIAM DAVID HAROLD CHARLES LARRY LEONOR MARION

dob 1941 1936 1936 1960 1946 1953 1929 1951 1945 1932 1950 1929 1935 1932 1963 1939 1936 1923 1951 1946 1922 1931 1944 1957 1962 1947 1934 1934 1943 1943 1948 1931 1932

date_registered 1966-05-11 1964-09-25 1999-04-21 2000-06-12 1991-09-28 2011-07-19 2007-08-31 2003-12-22 1984-09-28 1966-11-12 1999-09-10 1997-10-06 1964-10-03 1960-09-20 2002-06-05 2004-03-10 1993-08-27 1998-11-16 1998-02-05 2010-08-13 1967-05-29 1994-10-04 1995-09-11 2002-02-12 2012-12-17 1990-09-25 1974-03-14 2004-07-27 1978-10-05 2004-08-16 1999-03-25 1980-09-27 2000-10-10

ssdi_dod 2019-08-09
2018-12-16 2019-09-01
2018-06-14 2013-11-13 2018-12-02 2019-11-25 2019-09-25 2019-08-15 2018-06-19 2018-01-12
2019-09-20
2019-08-24 2019-10-18 2019-08-08 2018-09-22 2018-04-06 2019-11-15 2016-08-03 2019-12-01 2019-11-27 2019-06-21 2018-12-12 2017-07-25
2019-12-21

obit_dod 2019-08-09 2018-05-10 2018-12-16 2019-09-01 2018-12-05 2018-06-14 2013-11-13 2018-12-02 2019-11-25 2019-09-25 2019-08-15
2018-01-12 2019-10-15 2019-09-20 2019-11-03 2019-10-11 2019-10-17
2019-10-18 2019-08-08 2018-09-22 2018-04-06 2019-11-15 2016-08-03 2019-12-01 2019-11-27 2019-06-21
2017-07-25 2018-12-30 2018-12-12 2019-12-21

Exhibit B, Page 243

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 244 of 352 Pageid#: 1147

voter_id 410025250 P
69913571 P 24005122 P 14747988 P 404029350 P 917384908 P 990170665 P 919303972 P 919858993 P 226002535 P 317283642 P 501003882 P 404007310 P 731876954 P 918657380 P 794661015 P 24014315 P 918023907 P 701013959 P 103028099 P 223009737 P 918253487 P 707018922 P 514021329 P 305015163 P 406018500 P 306038123 P
5004854 P 313964800 P 918289093 P 128015283 P 392904088 P 128005588 P

lname

fname KATIE CARLTON PATRICIA PATRICIA MARY MARY MIRIAM STEVE ELEANOR ARRINGTON ETHEL JESSIE EARL WILSON JEFFERSON STEVEN PAUL ROBERT MILDRED HENRY PATRICIA JOANNE JOHN WILLIAM SALLY JEAN CAROLYN MARTHA NORMAN FREDDIE MARY JESSIE BEVERLEY

dob 1927 1965 1931 1944 1927 1954 1925 1947 1938 1947 1946 1932 1937 1942 1933 1975 1934 1948 1930 1945 1928 1948 1927 1937 1932 1927 1932 1939 1938 1951 1926 1944 1938

date_registered 1988-10-05 2012-09-13 1981-10-03 2017-03-03 1997-10-06 1995-12-19 2008-10-03 2002-04-04 2004-08-13 1974-03-18 2016-10-17 1966-05-28 1976-10-02 2014-07-25 1999-12-27 2012-10-09 1980-09-30 1997-06-11 1979-08-18 1987-09-13 1969-06-14 1998-05-05 1997-09-04 1988-11-09 1976-04-01 1964-10-02 1966-06-11 1989-06-14 2016-08-01 2002-11-12 1981-10-03 2008-03-06 1987-09-01

ssdi_dod 2019-12-18 2018-12-08
2019-11-20 2019-11-01 2014-09-23 2020-01-16 2019-11-23 2019-10-19 2019-09-14 2018-12-31
2018-04-12 2019-02-22 2019-07-03 2019-03-23 2019-10-27 2014-10-21 2002-10-01 2020-01-29 2019-11-25 2018-12-04
2019-12-15 2019-06-07 2019-12-03 2019-10-01 2020-01-27 2019-12-16 2018-12-19

obit_dod 2019-12-18 2018-12-08 2019-09-23 2019-09-30
2019-11-01
2019-11-23
2019-09-14 2018-12-31 2019-01-21 2019-10-14 2019-10-07
2019-07-03 2019-03-23 2019-10-27 2014-10-21
2019-11-25 2018-12-04 2019-09-16
2019-06-07
2019-10-01
2019-12-16

Exhibit B, Page 244

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 245 of 352 Pageid#: 1148

voter_id 404005171 P 125018275 P 803011936 P 918821487 P 701012328 P 404023825 P 918399059 P 808008408 P
10639206 P 74196578 P 701010789 P 902009203 P 901017168 P 106016562 P 126015927 P 306026521 P 918447387 P 437339164 P 920205543 P 502011857 P 918619165 P 123016420 P 864260994 P 919980769 P 307029746 P 93144943 P 917833929 P 918986144 P 802016156 P 908021711 P 207008853 P 601001728 P 603526439 P

lname

fname JAIRUS SHIRLEY RUTH DORIS BARNEY LOUISE LOUISA BETTIE JOHN JACK RODNEY SAMANTHA EUGENE MICHAEL LESSIE DONALD EVELYN MURIEL IRIS LEAH THOMAS JUANITA HOUSTON ODELIA JEFFREY CAROLYN LUIS MARY BERTHA ALICE KENNETH ROSA VERNELLE

dob 1918 1935 1934 1924 1938 1937 1929 1933 1938 1949 1942 1929 1929 1949 1916 1926 1939 1934 1931 1929 1936 1944 1940 1940 1951 1942 1937 1943 1925 1925 1957 1948 1924

date_registered 1997-12-11 1997-04-30 1977-10-01 2000-07-13 1983-05-11 1964-09-28 1998-12-11 1964-09-29 2012-05-18 2012-09-26 2001-07-17 1953-02-19 1972-09-28 1999-09-17 1949-08-15 1975-07-31 1999-03-05 2008-07-17 2005-11-09 1959-11-01 1999-10-27 1999-05-10 2008-09-02 2004-10-04 1983-03-30 2010-06-10 1998-10-01 2000-11-20 1963-08-22 1975-10-04 1980-05-07 1971-07-31 2012-02-13

ssdi_dod 2017-02-17 2020-01-03 2019-12-24 2016-12-26
2019-07-21 2019-08-23 2019-05-25 2019-11-04 2018-12-17 2019-11-29 2014-07-02 2019-12-19 2019-12-14 2019-11-18 2019-08-07
2019-09-27 2019-02-17
2019-04-28 2016-12-13 2019-09-23 2014-10-19 2007-12-22
2018-05-12 2018-01-26 2013-08-12

obit_dod 2017-02-17
2016-12-26 2018-12-27 2018-09-26 2019-09-20
2019-08-23
2019-11-04 2018-12-17 2019-11-29
2019-12-19 2019-12-14 2019-11-18
2019-08-12 2019-09-27 2019-02-17 2019-11-03 2019-10-21 2019-09-14
2016-12-13 2019-09-23
2015-01-29 2018-05-11 2018-01-26 2013-08-12

Exhibit B, Page 245

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 246 of 352 Pageid#: 1149

voter_id 608005094 P 917109363 P 607033968 P 918380441 P 919989990 P 145264880 P 808008572 P 919353728 P 906002685 P 228003384 P 605027903 P 919802708 P 508003536 P
44861632 P 919716692 P 918430416 P 802002881 P 702026137 P 829235092 P 606021083 P 919707220 P 102018922 P 918165826 P 105008941 P 112025253 P 229016121 P 920356581 P 918493708 P 708011222 P 201030103 P
27018601 P 53347519 P 917086949 P

lname

fname ADLENA SCOT ALBERTA PHILLIP HENRY BERNARD JOSEPH PEGGY MICHAEL MARION WALTER VIRGINIA CYNTHIA VINSTON WILLIAM DENISE HERBERT HARRY GARY ALVIN LARRY THOMAS MARIE ANN GEORGE CHARLES HENRY GENEVA MARGARET RONALD LINDA CHINNA WILLIAM

dob 1929 1975 1929 1965 1922 1926 1930 1940 1947 1934 1935 1924 1958 1935 1934 1970 1924 1939 1941 1942 1946 1944 1920 1937 1930 1941 1940 1924 1938 1939 1947 1943 1935

date_registered 1967-09-06 1994-04-14 1964-09-24 1998-11-13 2010-10-12 2013-05-20 1984-09-29 2002-07-03 1984-01-02 1959-04-29 1968-10-05 2004-07-12 1984-10-05 2019-01-10 2004-03-22 1999-02-08 1946-03-21 1981-09-28 2008-09-19 1978-10-07 2004-03-10 1980-09-27 1997-12-22 1966-06-11 1991-08-06 1984-10-03 2006-08-10 1999-04-30 1980-05-07 1991-10-05 1993-01-15 2017-07-26 1994-02-23

ssdi_dod
2018-08-14 2020-01-21 2018-12-20 2016-06-28
2019-11-19 2019-12-24 2019-11-14 2019-11-03 2019-10-06 2019-10-02 2019-08-05 2019-08-02 2019-07-09 2018-07-11 2018-06-15 2014-02-18
2019-10-14 2018-12-14
2019-09-30 2019-08-25 2019-12-21 2019-08-22
2018-01-12 2017-07-22
2019-11-12 2019-07-24 2019-12-11

obit_dod 2019-10-15
2018-12-20 2016-06-28 2018-10-14 2019-11-19 2019-12-24
2019-11-03 2019-10-06 2019-10-02 2019-08-05 2019-08-03 2019-07-09
2018-06-15
2018-12-08 2019-10-14 2018-12-14 2017-09-30 2019-09-30 2019-08-25
2019-10-24
2019-08-09 2019-11-12 2019-07-24 2019-12-11

Exhibit B, Page 246

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 247 of 352 Pageid#: 1150

voter_id 6158273 P
904009383 P 515011558 P 614025238 P 304008224 P 301030318 P 287251311 P 111024823 P 609012716 P 902007816 P 126014854 P 607002478 P 917600046 P
26012947 P 906021974 P 407026466 P 403014495 P 919011281 P
24003859 P 805008229 P
28007318 P 806008790 P 917157789 P 830211884 P 710021554 P
36470049 P 204023639 P 505003538 P 918141353 P 203029398 P
82346909 P 204025236 P 919852873 P

lname

fname JACKIE WILLIAM BETTY JAMES JOAN ANNA GEORGIA LOUIS AUDIE PEGGY NONIE VIRGINIA NORWOOD MARY EARL HERMENA LUCY CATHERINE GENE LOMA CATHERINE ARNOLD DAVID QUINTIN CRAIG JOHN DORA MARTHA JIMMIE PAMELA JOAN BETTY LUCILLE

dob 1951 1941 1947 1942 1932 1936 1922 1944 1947 1929 1927 1926 1931 1925 1929 1926 1927 1937 1930 1940 1946 1932 1944 1957 1959 1977 1934 1926 1934 1960 1930 1961 1933

date_registered 2010-09-22 1976-05-06 1992-09-26 1992-02-18 1964-10-03 1981-04-01 2011-02-28 1989-09-13 1980-06-11 1955-09-29 1992-09-26 1980-07-15 1996-08-12 1987-09-25 1956-04-17 1952-04-23 1976-10-02 2000-11-29 1956-10-05 1972-09-25 1983-04-22 1976-09-22 1994-09-12 2008-10-06 1989-04-21 2012-07-09 1972-10-07 1959-10-03 1997-11-05 1992-06-26 2016-08-23 1983-07-13 2004-08-25

ssdi_dod 2018-04-16
2020-01-21
2019-10-09 2015-12-03 2020-01-24 2020-01-07 2019-12-25 2019-11-29 2019-11-19 2019-10-31 2019-10-24 2019-10-22 2019-10-18 2019-10-14 2019-10-08 2019-10-05 2019-09-26 2019-08-08 2019-03-28 2018-12-29 2018-10-29 2018-01-08 2017-01-28
2019-10-30 2019-09-22 2019-09-07 2019-08-04 2018-02-13 2014-04-15

obit_dod
2019-10-11 2019-08-20
2019-09-25 2019-10-09 2015-12-03
2019-12-25
2019-10-31 2019-10-24 2019-10-22 2019-10-18 2019-10-14 2019-10-08
2019-09-26 2019-08-08 2019-03-28
2018-10-29
2014-11-28 2019-10-30 2019-09-22 2019-09-07 2019-08-04 2018-02-13

Exhibit B, Page 247

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 248 of 352 Pageid#: 1151

voter_id 918389215 P 603003354 P 505009588 P 918063967 P 202000210 P 202021701 P 919466589 P 107016267 P 917716729 P 308016790 P 650356209 P 979167705 P 612032370 P 919980918 P 110024375 P 126012862 P 404031636 P 405004157 P 920301367 P 919367426 P 208013891 P 225006182 P 540389007 P 918974851 P 126015930 P 903001438 P 105007344 P 103025061 P 606028757 P 917086961 P 122011451 P
18665150 P 917342917 P

lname

fname DON DANNY CAROL ROSE LOTTIE DOROTHY DRUSCILLA MARGARET DORIS WILLIAM DONALD JONATHAN SHIRLEY FLORENCE GUIDA EVELYN CORETA RAYMOND ERIKA DAVID MILDRED CHARLES ANNE MICHAEL CLARA RALPH DONALD MARJORIE DENVER EULA JOYCE KEITH BURLEY

dob 1933 1947 1942 1924 1933 1938 1931 1928 1938 1943 1950 1943 1937 1935 1943 1922 1930 1936 1987 1968 1919 1943 1947 1964 1943 1942 1918 1939 1927 1959 1941 1936 1940

date_registered 1998-11-23 2004-12-01 1980-07-17 1997-08-07 1952-08-29 1970-09-28 2003-02-05 1964-09-22 1996-10-03 1986-03-11 2016-10-14 2008-10-01 1987-09-23 2004-10-04 2001-03-15 1996-03-25 2000-05-03 1975-05-10 2006-05-12 2002-07-29 1980-09-23 1970-04-18 2013-08-26 2000-11-08 1999-08-05 1988-11-21 1939-08-01 1977-10-05 1950-10-01 1999-04-26 1976-10-02 2013-08-08 1995-09-28

ssdi_dod
2019-11-17 2020-01-09 2019-12-19 2019-10-04 2019-04-28 2019-05-01 2015-02-02 2019-08-20
2019-03-22 2018-01-18 2019-12-10 2019-11-18 2018-12-26 2018-07-25 2017-03-26 2014-07-19 2019-12-18 2019-12-04 2019-12-03 2019-11-03 2019-10-31 2019-08-29 2019-05-20 2019-05-14 2018-07-16 2018-03-18 2017-06-21 2017-03-23 2016-08-30

obit_dod 2019-10-06 2019-09-16 2018-05-27 2019-11-17
2019-10-04 2019-04-28 2019-05-01 2015-02-02
2018-01-16 2019-03-22 2018-01-18 2019-12-10
2018-12-26
2019-12-18
2019-11-03 2019-10-31 2019-08-29 2019-05-20 2019-05-14
2018-03-18 2017-06-21 2017-03-23 2016-08-30

Exhibit B, Page 248

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 249 of 352 Pageid#: 1152

voter_id 919208193 P
84317917 P 907020161 P 918592198 P 384180826 P 203023486 P 213606401 P 918211874 P 919493169 P
24019014 P 305045836 P 608473205 P 665284565 P 917672905 P 303044763 P 602009023 P 409011455 P 306014641 P 708010058 P 919770339 P 890112629 P 851015910 P 701029237 P 302038455 P 709012231 P 908006913 P 301011377 P 126001835 P 701024115 P 918225225 P 917360480 P
95794819 P 227004081 P

lname

fname ALICE ELIE ROBERT CARL SYBIL CHARLIE HECTOR CORNELIA KYLE JEAN MARIO JAMES HENRY SABRINA BILLY WILDA S MAXINE EDITH BARRY JOSEPH JERRY SHAUNDA ALBERT EUGENE HERSCHEL VERNON HENRY VINCENT ELIZABETH DOROTHY ALTON DIANNE PHYLLIS

dob 1919 1929 1931 1948 1918 1925 1949 1931 1950 1934 1936 1941 1950 1961 1932 1942 1936 1926 1951 1939 1944 1991 1927 1929 1929 1953 1929 1926 1921 1937 1947 1948 1922

date_registered 2001-10-09 2017-09-20 1976-04-03 1999-09-23 2010-11-08 1960-10-05 2008-10-01 2000-01-20 2003-03-31 1960-12-29 1986-07-31 2012-10-02 2017-09-11 1996-09-20 1988-06-23 1972-09-22 1992-09-09 1957-10-05 1982-09-29 2004-05-20 2008-02-26 2018-09-10 2000-03-01 1957-06-08 1977-10-08 1987-02-10 1975-10-02 1983-08-12 1967-06-07 1998-03-26 1995-10-10 2008-10-02 1970-10-01

ssdi_dod 2005-11-11
2019-07-11 2020-01-06
2018-12-07 2017-12-31 2019-11-09 2019-12-05 2018-05-22 2019-06-06 2019-03-27
2018-02-16 2019-10-10 2019-12-25 2019-06-12 2019-01-13 2019-12-18 2019-09-11
2019-09-20 2019-07-30 2017-06-13
2014-11-13 2019-12-30 2019-12-21 2018-12-06

obit_dod
2019-05-04 2016-10-31 2019-07-11
2019-09-01 2019-09-08
2017-12-31 2019-11-09 2019-12-05 2018-05-22 2019-06-06 2019-03-27 2015-12-26 2018-02-16 2019-10-10
2019-06-12
2019-09-11 2019-08-02 2019-09-20 2019-07-30 2017-06-13 2019-10-30 2019-09-18 2019-03-29
2018-12-06

Exhibit B, Page 249

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 250 of 352 Pageid#: 1153

voter_id 111818652 P 804001386 P 509007368 P 110003370 P 917796160 P 917326989 P
63365392 P 918001324 P 707010354 P 917070791 P 160115800 P 207024614 P 403026469 P 918629928 P 103005200 P 912022188 P 226007070 P 305021790 P 108128278 P 225000501 P 407019723 P 905016947 P 726650463 P 918589909 P 468793349 P 975621505 P 304008862 P 404020099 P 917817910 P 122002074 P 918007158 P 847576316 P 919224901 P

lname

fname BRINDA JAMES L MARY FLORENCE CLYDE CAROLYN PATRICK DAVID MARY RICHARD JOSEPH LAUDEENA ROSCOE WILLIAM ETHEL MAXINE JOHN LOUIS ELSIE ANNA ETHEL JOHN BENJAMIN SUZANNE CAMERON MILDRED CAROL GERALD GERALD ARTHUR DOROTHY CATHERINE JUDY

dob 1964 1924 1921 1924 1972 1946 1980 1957 1935 1940 1946 1929 1930 1946 1946 1938 1938 1929 1941 1928 1922 1939 1942 1925 1930 1914 1941 1942 1939 1925 1931 1935 1941

date_registered 2018-03-16 1982-06-07 1956-10-01 1998-11-09 1996-10-07 1995-09-18 2012-02-13 2000-05-15 1966-05-14 1994-02-07 2008-01-14 1951-09-26 1951-01-30 1999-11-09 1988-02-06 2002-08-09 1986-12-02 1962-06-09 2008-11-19 1955-02-19 1984-02-28 1960-09-21 2008-11-07 2005-12-05 2018-08-14 2008-09-26 1976-08-18 1964-09-24 1996-11-06 2002-10-07 1997-04-19 2016-06-22 2001-11-13

ssdi_dod 2019-05-17 2018-06-03 2019-10-14 2019-10-07 2019-06-15 2018-01-28 2018-01-06 2019-08-08 2019-09-03 2017-02-04 2016-05-31 2015-03-26
2020-01-16
2018-01-10 2010-12-11
2018-12-26 2018-12-05
2010-11-18 2019-08-21 2019-11-15
2019-10-04
2019-12-02

obit_dod 2019-05-17 2018-06-03 2019-10-14 2019-10-07 2019-06-15
2018-01-06
2019-09-03
2016-06-05 2015-03-26 2018-12-07 2018-02-03
2019-08-01 2018-04-10 2018-01-10 2010-12-11 2019-10-13 2018-12-26
2019-10-29 2018-10-27 2019-09-30 2010-11-18 2019-08-21 2019-11-15 2019-11-02 2019-08-02 2019-10-04 2019-06-17 2019-12-02

Exhibit B, Page 250

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 251 of 352 Pageid#: 1154

voter_id

lname

156600469 P

920236034 Q

602029096 Q

8005533 Q

581906689 Q

206007365 Q

919211811 Q

919247903 Q

503014804 Q

918663934 Q

204008987 Q

705006443 Q

702003454 Q

917932377 Q

917610080 Q

920340739 Q

919042808 Q

71760955 Q

917366712 Q

803006954 Q

237001537 Q

919104685 Q

605019715 Q

601002909 Q

263587807 Q

917305527 Q

918094337 R

917308059 R

906015937 R

272760663 R

604010968 R

917003595 R

920082956 R

fname RICKY KATHLEEN PATSY MAROLYN SYED CYNTHIA VERONICA SHIRLEY WINIFRED EPEFANIA PEARL STELLA WILLIAM DUDLEY SHEILA BERTHA JACK RANDALL R LILLIE GEORGE MIGUEL ANNE EVA GREGORIA JESSE SHELVY JEAN WAYNE ADDIE ESTON PAUL MOHAMMAD ROSA

dob 1960 1951 1934 1938 1942 1950 1955 1937 1936 1930 1920 1948 1945 1949 1935 1933 1938 1963 1932 1933 1927 1941 1927 1931 1924 1949 1937 1936 1933 1931 1936 1953 1925

date_registered 2016-11-15 2006-01-10 1966-09-26 1973-09-27 2011-11-09 1971-01-20 2001-10-09 2001-12-13 1984-10-06 2000-01-11 1942-11-19 1980-09-08 1971-09-29 1999-10-04 1996-08-10 2006-08-16 2001-02-16 2016-02-23 1995-10-10 1979-07-12 2011-07-14 2001-04-30 1950-04-15 1991-09-21 2008-10-03 1995-08-02 1997-09-12 1995-08-01 2002-01-11 2018-12-06 1964-02-06 1998-01-23 2005-04-13

ssdi_dod 2018-02-12 2019-10-11 2019-03-09
2019-12-05 2018-02-24 2019-09-27
2018-12-03 2019-07-12 2019-06-09 2018-07-05
2019-05-05 2018-12-20 2014-01-16 2019-02-17 2018-04-23 2018-09-12 2018-02-27 2014-03-11 2018-08-29 2019-08-01 2016-02-28 2018-12-02 2017-05-19
2019-11-04
2019-11-01 2018-05-14 2018-01-23 2018-12-12

obit_dod 2018-02-12 2019-10-11 2019-03-09 2018-12-26
2018-02-24 2019-09-27 2019-09-23
2019-06-09
2019-08-31 2019-05-05
2019-02-17
2018-02-27 2014-03-11
2019-08-01
2017-05-19 2019-09-29 2019-11-04 2019-09-04
2018-05-14

Exhibit B, Page 251

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 252 of 352 Pageid#: 1155

voter_id

lname

904020881 R

121020319 R

917048818 R

224008876 R

218958647 R

659821991 R

919308616 R

94291049 R

7476494 R

918493690 R

705012330 R

401035818 R

132299599 R

920368927 R

919274909 R

920381209 R

501002022 R

917965476 R

33023787 R

505011438 R

306005794 R

919543384 R

121001626 R

110765625 R

919615270 R

917455250 R

95679150 R

407006056 R

205012861 R

205025514 R

919076383 R

117163802 R

685582 R

fname RICHARD WILTON DAVID FRANK JAMES HAMID JAMIL MANOHAR JOHNNIE PATRICIA ANDREW JOAN BLANCH JOHN ERIK AMALANATHAN PETE ANNE JOHN RICHARD DAVID KATHERINE JOSEPH PALAKKADA HYMAVATHY PHYLLIS ANANTHANARAYANA EVA PATRICIA GEORGE LILLIAN ROSA CLAUDIO

dob 1926 1947 1946 1921 1940 1972 1943 1945 1956 1929 1920 1949 1930 1953 1973 1952 1941 1941 1948 1930 1930 1984 1942 1938 1935 1936 1938 1940 1947 1954 1939 1949 1942

date_registered 2000-09-07 2007-03-28 1993-10-04 1956-10-03 2015-03-13 2015-11-09 2002-04-15 2016-10-03 2019-04-22 1999-03-30 1955-12-12 1992-07-16 2016-10-12 2006-10-02 2002-02-19 2006-10-10 1967-10-05 1997-04-11 2018-08-03 1988-10-08 1976-03-25 2003-06-23 1976-07-19 2012-10-12 2003-10-06 1996-04-09 2017-09-26 1967-10-06 1980-10-04 1987-10-01 2001-04-03 2008-08-20 2016-11-16

ssdi_dod
2019-11-11 2017-11-18
2019-11-19 2018-01-09 2017-12-12 2018-09-08 2019-11-26 2019-11-23 2016-05-14
2017-09-21 2019-08-17 2018-11-02 2016-10-28 2019-11-19 2018-12-04 2019-10-13 2017-07-03 2020-01-15 2019-08-09 2019-04-19 2018-01-30 2019-10-30
2019-07-20 2019-08-30 2018-12-08 2017-12-30 2017-11-29 2019-03-27 2019-02-13

obit_dod 2015-07-17 2019-11-11 2018-02-18
2019-11-26 2019-11-23 2019-08-09
2018-11-02 2016-10-28 2019-11-19 2018-12-04 2017-07-03
2019-04-19
2018-09-02
2018-12-08 2017-12-30

Exhibit B, Page 252

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 253 of 352 Pageid#: 1156

voter_id

lname

45168726 R

225024575 R

917582495 R

804006579 R

43593776 R

11003666 R

404005520 R

918428361 R

801001636 R

917035214 R

36788714 R

917083268 R

918749630 R

908002382 R

918274711 R

122001128 R

101023049 R

489885828 R

404031356 R

920134630 R

516008970 R

228001031 R

106020654 R

410026471 R

919424671 R

918427475 R

920195719 R

424577317 R

918114085 R

6367338 R

76141290 R

919586307 R

608026901 R

fname JUSTA AUGUSTO MARCIAL WALLACE JOSE BRENDA MARTHA JOHN RUBY MAURICE ANDREW MARIA MARGARET WILLIAM JAMES CAROLINE ANGEL MARY QUEEN MARILYN SALLIE PHYLLIS BETTIE DENNIS MARGARET DANA JUDY JEAN SAM MARIA ABDUL WAALEE DOROTHY

dob 1928 1946 1948 1928 1937 1947 1922 1929 1927 1934 1949 1935 1913 1932 1941 1921 1943 1938 1931 1934 1919 1926 1937 1950 1952 1981 1947 1935 1952 1930 1934 1941 1935

date_registered 2011-12-22 1992-03-31 2001-02-03 2006-02-10 2017-03-09 1968-09-26 1971-04-06 1999-01-14 1997-01-30 1993-09-25 2008-10-06 1994-02-27 2000-04-03 1978-10-07 1998-06-02 1951-05-03 1983-10-06 2008-08-08 2006-10-25 2005-07-20 1988-08-24 1951-01-01 1978-09-14 1988-10-04 2003-01-16 1999-02-02 2005-10-11 2012-10-13 1999-01-20 2010-04-26 2010-08-09 2003-09-05 1955-07-10

ssdi_dod 2018-07-28 2017-01-06
2020-01-03 2019-01-18 2019-11-02 2018-12-22 2018-12-17
2019-02-01 2016-08-18 2018-12-05 2019-08-15
2019-12-26 2019-08-04 2018-12-08 2018-11-06
2019-12-29 2019-11-06 2019-10-10 2017-12-16 2019-03-04 2018-12-16
2019-11-17 2019-09-11 2018-01-19 2019-10-05 2018-12-30 2018-12-28

obit_dod
2019-07-19
2019-11-02 2018-12-22 2019-10-10 2018-02-18 2019-02-01 2018-12-05 2019-09-30 2019-08-04 2018-12-08 2018-11-06 2013-10-21 2019-11-06 2017-12-16 2018-12-16 2019-08-28
2018-01-19

Exhibit B, Page 253

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 254 of 352 Pageid#: 1157

voter_id

lname

202001479 R

919660327 R

63000520 R

226015172 R

401021419 R

918605965 R

203025004 R

917138221 R

201030029 R

206001963 R

919181857 R

920384981 R

226022576 R

308006695 R

211016005 R

206023189 R

221002381 R

337427875 R

222026087 R

917115507 R

920407138 R

502009348 R

506009347 R

501025297 R

302030529 R

405010915 R

306024976 R

919919874 R

920277846 R

918206630 R

207018901 R

403003506 R

507012432 R

fname MOLLY THOMAS LINDA GEORGE RICHARD LASSIE DONAL MAMIE JERLENE VERNON JUDITH JOHN JACK ROSARIO EDGAR GRACIE THOMAS DOUGLAS CAROL WILBER GRACIE ROY LOUELLA MARY LORENE GATHA ROBERT ARLENE SYED MOHAMMAD TOMMY MARSHALL LARRY KEITH

dob 1938 1941 1941 1947 1928 1938 1938 1936 1935 1941 1943 1942 1929 1936 1960 1942 1935 1935 1948 1938 1933 1943 1947 1937 1922 1924 1931 1949 1941 1963 1928 1943 1927

date_registered 1968-10-05 2003-11-14 2010-12-08 1989-10-05 1980-10-04 1999-10-01 1975-08-25 1957-04-23 2006-07-31 2006-07-20 2001-09-11 2006-10-02 1964-09-18 1986-03-13 1992-09-16 1983-10-01 1982-09-30 2008-10-06 1992-10-03 1994-05-04 2006-11-07 1971-07-19 1971-07-19 1987-08-24 1997-11-12 1956-10-06 1973-05-23 2004-09-28 2006-04-04 1998-02-09 1980-10-04 1987-09-19 1977-03-10

ssdi_dod 2018-01-26 2017-11-04 2014-10-17 2019-12-05 2019-12-17 2018-03-15 2018-01-08
2020-01-14 2019-10-30 2020-01-07 2018-01-04 2019-08-12 2018-09-30 2019-12-10
2019-12-25 2020-01-18 2019-08-08 2019-02-25 2018-12-27 2018-05-11
2020-01-22 2019-08-25 2019-12-14 2015-12-25 2016-08-22 2019-11-15 2019-11-21

obit_dod 2018-01-26 2017-11-04
2019-12-05
2018-03-15 2018-01-08 2019-06-22 2018-02-15 2017-01-10
2019-10-30
2018-01-04 2019-08-12 2018-09-30 2019-12-10 2018-12-18
2019-08-08 2019-02-25 2018-12-27 2018-05-11 2019-09-09
2019-11-15 2019-11-21 2018-04-23

Exhibit B, Page 254

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 255 of 352 Pageid#: 1158

voter_id

lname

404014751 R

918090371 R

917658589 R

918042247 R

606032372 R

919809950 R

513712239 R

501014941 R

3771389 R

402020648 R

174565192 R

917584531 R

610006028 R

225009151 R

206012204 R

15324190 R

918182380 R

180128756 R

203008549 R

225015174 R

310041452 R

917612841 R

917986937 R

302009502 R

636367607 R

919210964 R

918385100 R

604028770 R

636086812 R

56874906 R

920220717 R

705020322 R

917307916 R

fname LESLIE HOWARD HELEN VERA JOSEPH HARRIETTE LEROY WILLIAM MARION WILLIAM RONALD CHARLOTTE PATRICIA A FRANK IRENE DELORES GEORGIE JANICE PHYLLIS WALTER WILLIAM PAULINE ARTHUR CATHERINE VIRGINIA SUSAN BARBARA RAYFORD DONALD ERVIN LISA HELEN WILLIE

dob 1946 1972 1933 1928 1928 1918 1958 1933 1931 1935 1947 1941 1948 1959 1926 1933 1943 1951 1947 1926 1938 1964 1947 1946 1934 1944 1944 1944 1941 1948 1974 1929 1934

date_registered 1968-09-03 1997-09-04 2000-01-24 1997-07-02 1956-04-19 2004-07-19 2016-07-21 1979-04-21 2016-04-01 1981-11-04 2017-03-14 1996-08-07 1985-06-19 1999-09-07 1956-01-02 2017-04-28 1998-01-20 2014-11-13 1974-04-24 1976-09-28 1998-12-09 1996-08-26 1997-04-29 1987-09-12 2008-09-16 2003-01-29 1998-11-18 1968-10-02 2015-11-16 2015-09-11 2005-11-30 1999-11-23 1995-08-10

ssdi_dod 2020-01-06 2018-02-12
2019-09-29 2007-08-02 2019-03-20 2020-01-18 2019-06-11 2019-09-11 2019-01-08 2017-01-29 2018-08-08 2018-12-07 2020-01-24 2019-09-28 2019-09-14 2019-09-01 2019-06-06 2018-12-13 2018-02-16 2018-02-09 2018-01-25 2017-09-17 2017-02-19 2016-12-15
2018-10-14
2019-11-23

obit_dod
2018-02-12 2018-12-21 2016-09-11
2019-03-20
2019-06-11 2019-09-11 2019-01-08 2017-01-29 2018-12-18
2019-09-28
2019-09-01 2019-06-06 2018-12-13 2018-02-16
2018-01-25 2017-09-17 2017-02-19 2016-12-15 2019-11-02 2019-10-17 2017-05-29 2016-09-08 2018-10-14 2016-02-17 2019-11-23

Exhibit B, Page 255

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 256 of 352 Pageid#: 1159

voter_id

lname

297195384 R

342967266 R

905004826 R

917573554 R

917678903 R

123018041 R

918652771 R

903020884 R

242666380 R

704012331 R

21008833 R

917033820 R

27010446 R

704023690 R

918096149 R

919141757 R

917293326 R

918162845 R

801020065 R

71910111 R

918447335 R

802023089 R

919154155 R

222018005 R

918350673 R

222014120 R

917035493 R

902002037 R

920227310 R

919790058 R

51121629 R

108001511 R

804014527 R

fname JOE GEORGE DOROTHY JEANETTE ALBERT EDITH TOD LOUISE STANLEY BOBBY MARIE BETTY NORMAN WILLIAM RICHARD DONALD RHETA BRUCE JAMES JOHN EUGENE SANDRA ROBERT STANLEY CLIFFORD BLANCHE EARLENE DOLLIE RUDOLPH DANIEL JERRY LOLA STEVE

dob 1958 1949 1928 1926 1933 1942 1959 1934 1926 1945 1942 1932 1935 1947 1939 1936 1916 1947 1930 1931 1932 1931 1965 1945 1924 1921 1947 1942 1941 1949 1955 1936 1951

date_registered 2013-06-24 2012-05-21 1968-09-16 1996-07-25 2001-12-26 1984-02-13 2005-12-08 1965-04-09 2008-05-23 1967-06-10 1966-04-19 1993-09-27 1980-10-02 1992-06-10 1997-09-18 2001-07-13 1995-06-08 1997-12-09 1996-04-03 2012-06-21 2004-08-03 1993-05-12 2001-08-06 1991-03-05 1998-09-29 1980-10-02 1998-02-02 1976-09-13 2005-12-15 2004-06-21 2016-10-12 1970-09-29 1980-06-04

ssdi_dod 2019-07-16
2018-02-26
2019-11-14 2019-10-28 2018-12-13 2018-12-12 2018-11-13 2016-07-08
2020-01-13 2019-10-22 2019-09-21 2018-12-28 2018-04-17
2019-12-29 2019-12-09
2014-10-28 2017-11-28
2019-10-03 2018-01-31 2017-05-28 2019-12-02 2019-12-01 2019-11-02 2019-05-02 2019-04-24 2019-02-11

obit_dod 2019-07-16 2018-01-19 2018-02-26 2019-09-25
2019-10-28
2018-12-12
2016-07-08 2019-08-17
2018-12-28 2018-04-17 2019-08-22
2019-12-09 2018-12-02 2018-07-07
2017-11-28 2016-02-04 2019-10-03 2018-01-31 2017-05-28 2019-12-02 2019-12-01 2019-11-02
2019-02-11

Exhibit B, Page 256

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 257 of 352 Pageid#: 1160

voter_id

lname

919298550 R

911006022 R

917269458 R

919220806 R

305024529 R

919367841 R

204019854 R

919757908 R

917344369 R

301002739 R

224004337 R

716818054 R

999228825 R

758419048 R

29673815 R

917427836 R

918252628 R

920192761 R

305030056 R

848430511 R

918565811 R

919201606 R

918652695 R

48345008 R

301052890 R

610024881 R

342311351 R

917350571 R

427344607 R

502001372 R

807007091 R

35671656 R

603000879 R

fname ANTONYE MARY PATRICIA DOROTHY RICHARD ROBERT JANE PATRICIA HARRY THELMA DORIS SHERYL RICHARD EDITH STANLEY ROGER BARBARA JAMES KATHERINE CAROL JOHN CHANTE WILHELMINA HAROLD MARY LOUISE NORMA PAZ JULIO LEVITA JUNE JAMES JACKIE

dob 1984 1928 1948 1926 1943 1954 1934 1946 1929 1930 1926 1952 1938 1922 1931 1940 1943 1947 1915 1942 1951 1983 1946 1918 1953 1929 1943 1940 1969 1932 1935 1957 1960

date_registered 2002-03-29 1992-09-29 1995-04-12 2001-11-09 2005-10-07 2002-07-31 2000-05-03 2004-05-10 1995-10-02 1985-05-02 1976-09-11 2014-05-15 2007-12-26 2011-07-07 2015-09-23 1997-01-07 1999-11-16 2005-09-08 1966-06-04 2017-03-09 1999-09-01 2001-10-02 1999-12-22 2012-10-03 1988-07-30 1988-08-22 2013-03-21 1995-09-29 2008-05-12 1985-07-23 1998-11-04 2012-10-15 1987-08-10

ssdi_dod 2018-12-17 2018-03-27
2019-12-10 2019-04-14
2019-11-06
2019-08-20 2018-01-24 2018-01-30 2019-01-11 2018-12-01
2018-07-18 2019-01-08 2015-07-03 2018-04-08 2019-11-26 2018-05-02 2019-10-22 2018-05-21 2016-02-12 2019-11-14 2019-04-04 2017-06-06 2019-08-02 2020-01-23 2020-01-08 2019-10-24 2019-10-01

obit_dod 2018-12-17 2018-04-01 2019-10-30 2016-05-02 2019-12-10 2019-04-14 2018-09-14
2014-06-27 2019-08-20 2018-01-24 2018-01-30
2018-12-01 2019-09-24 2019-09-21
2019-01-08 2015-07-03
2019-11-26
2019-10-22
2016-02-12 2019-11-14
2019-10-24 2019-10-01

Exhibit B, Page 257

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 258 of 352 Pageid#: 1161

voter_id

lname

919034683 R

801000014 R

918962999 R

901005682 R

222694768 R

29013528 R

703013184 R

156733361 R

233010118 R

129725716 R

225005531 R

24017323 R

919862723 R

701013981 R

221006503 R

106014243 R

918448007 R

733266688 R

426738513 R

920215284 R

1002670 R

2003348 R

401022687 R

103026799 R

303016636 R

373855770 R

919063750 R

602017700 R

507006509 R

988609362 R

601038100 R

21009557 R

602003595 R

fname PAUL DORIS SHELDON MADELL DAWNE JEAN LOUISE WILLIAM FILOMENA GLENN JOHN IONA HATTIE JOHN DONALD SARAH DONNELLE GENTRY MOHAMAD MARC LOUISE WILLIAM LOTTIE WILLIAM PAUL NANCY WARREN JAMES PATRICIA EULA DAVID MILDRED ROBERT

dob 1930 1924 1958 1930 1959 1936 1927 1955 1950 1931 1941 1920 1950 1947 1965 1927 1935 1944 1930 1970 1924 1930 1921 1935 1937 1946 1931 1927 1935 1955 1933 1923 1954

date_registered 2003-09-02 2002-08-22 2000-10-10 1979-01-09 2010-01-11 1988-09-29 1983-09-16 2011-10-06 1991-01-18 2015-10-07 1991-09-10 1952-12-20 2004-08-28 1997-03-20 2000-01-31 1958-05-29 1999-03-04 2008-05-16 2007-11-27 2005-11-09 1964-10-21 1976-04-03 1976-09-23 1968-10-03 2005-07-05 2010-11-03 2001-03-20 1985-08-12 1983-10-01 2007-08-17 1992-09-29 1997-12-08 1984-10-01

ssdi_dod 2018-12-18 2018-03-09 2018-01-05
2009-03-28 2018-12-02 2018-09-09
2019-11-29 2019-11-08 2019-09-23 2019-01-27 2018-12-31 2017-06-29 2017-07-21 2016-12-30 2018-08-29 2018-07-04 2019-12-12 2019-12-11 2019-10-08 2019-09-28 2019-12-03 2019-05-19 2018-12-23 2019-12-01 2019-11-15 2019-10-19 2019-08-07 2018-12-13 2018-12-02

obit_dod 2018-12-18
2018-08-17 2017-08-04 2018-07-31 2009-03-28 2018-12-02
2019-06-25 2019-11-29 2019-11-08 2019-09-23
2018-08-29 2018-07-04 2019-12-12 2019-12-11 2019-10-08 2019-09-28 2019-12-03
2018-12-23 2019-12-01 2019-11-15 2019-10-19
2018-12-13 2018-12-02

Exhibit B, Page 258

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 259 of 352 Pageid#: 1162

voter_id

lname

714009179 R

605003180 R

104651644 R

208008718 R

407017485 R

123002323 R

712000531 R

919191133 R

919038874 R

919336059 R

917420024 R

18093012 R

918949197 R

159547296 R

206007604 R

917020771 R

905004829 R

142044892 R

107023492 R

395688897 R

310036530 R

33729606 R

919057047 R

920110904 R

917352890 R

502031525 R

226001442 R

801011194 R

917778400 R

23001765 R

128217578 R

601025108 R

601001055 R

fname WILLIAM LLEWELLYN EARL ROBERT ELINOR RALPH LAZALIA BRENDA SUE MARY BILLY SONIA BETTY MARVIN BERLIE NONIE MARY DOWNEY SAMUEL JUDY JOHN MARY DONALD GRACE JEAN RUSSELL CALDORA JUNE JULIA CURLUE STACIE EDWARD WILLIAM

dob 1943 1938 1926 1936 1927 1930 1948 1946 1921 1927 1946 1967 1931 1969 1933 1943 1930 1966 1942 1949 1948 1948 1962 1972 1940 1942 1920 1935 1939 1937 1974 1930 1930

date_registered 2000-03-17 1989-07-17 2011-11-09 1988-05-09 1972-09-29 1986-08-25 1991-10-05 2001-09-24 2001-02-12 2002-05-31 1996-03-13 2009-06-10 2000-10-10 2016-10-21 1955-09-27 1993-09-14 1968-10-05 2013-11-06 1980-10-04 2012-10-15 2003-08-15 2015-03-25 2001-03-10 2005-06-16 1995-09-25 2003-11-12 1983-09-13 1956-05-06 1999-03-15 1982-04-03 2010-03-16 2000-05-17 1981-10-02

ssdi_dod 2018-10-11
2020-01-01 2019-12-22 2019-12-21 2019-12-12 2019-11-21 2019-10-19 2019-10-12 2019-09-12 2019-05-09 2018-12-20 2018-12-04 2018-05-14
2018-12-29 2018-12-05 2018-09-19
2018-12-12 2016-03-02 2019-10-02 2019-08-22 2018-06-26
2019-09-17 2019-03-10 2012-09-20 2020-01-08 2019-11-01

obit_dod
2019-08-24 2018-12-05
2019-12-12 2019-11-21 2019-10-19 2019-10-12 2019-09-12 2019-05-09
2018-12-04 2018-05-14 2019-09-23 2018-12-03 2018-12-29 2018-12-05
2018-05-19 2017-08-28
2016-03-02 2019-10-02 2019-08-22
2016-06-17
2019-03-10 2012-09-20

Exhibit B, Page 259

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 260 of 352 Pageid#: 1163

voter_id

lname

607001037 R

107021250 R

131001629 R

919248506 R

606009027 R

13373956 R

919156225 R

408018508 R

918450745 R

753115836 R

180333825 R

73831876 R

34418629 R

611016582 R

304018903 R

702003197 R

232012397 R

601000881 R

917027274 R

917735876 R

103025256 R

401026965 R

906001754 R

406365397 R

100284396 R

207025005 R

918815542 R

121004364 R

506003890 R

220664919 R

32402314 R

513754742 R

825216753 R

fname IRIS ALICE JUDY HARVEY LYNN DAVYLU CARL WARREN RUBY JAMES RICHARD MICHAEL RUSSELL MARY FLETCHER JAMES PEGGY JAMES EARL LIBBY HAROLD OTHO DELIA DEBORAH BRITTA DOROTHY GEORGE RICHARD ROBERT CLIFTON DOUGLAS HAZEL STEPHEN

dob 1926 1935 1946 1935 1953 1928 1947 1946 1931 1930 1934 1957 1934 1953 1923 1943 1932 1942 1941 1956 1933 1924 1933 1951 1972 1944 1930 1930 1943 1948 1951 1929 1945

date_registered 1957-12-03 1980-06-13 2000-05-03 2001-12-19 2006-09-25 2013-07-10 2001-08-06 2003-10-06 2003-08-28 2008-10-02 2017-08-09 2008-08-06 2016-10-17 2013-09-25 1998-06-16 1991-09-24 1999-10-01 1967-03-14 2002-01-04 1996-10-07 1976-10-02 1993-10-01 1984-05-02 2012-10-03 2009-09-24 1968-08-28 2000-06-19 1980-10-04 2006-03-28 2014-06-04 2017-12-20 2016-11-30 2008-10-06

ssdi_dod
2018-11-04 2016-04-25 2019-08-30 2017-10-28 2019-10-01 2017-08-29 2018-12-01 2019-10-20 2019-12-02 2019-11-20 2015-11-29 2019-09-11 2018-10-01
2019-11-14 2019-10-17 2019-08-14 2017-07-28 2017-06-27 2016-01-25 2019-02-27 2014-10-03 2020-01-02 2019-06-24 2018-12-05
2019-05-08 2018-03-02 2018-07-27

obit_dod 2019-10-11 2019-09-03 2019-08-12 2018-11-04 2016-04-25 2019-08-30
2019-10-01 2017-08-29 2018-12-01
2019-11-20
2018-10-01 2019-10-21 2019-08-03
2019-10-17 2019-08-14 2017-07-28 2017-06-27
2018-12-05 2014-06-11
2018-03-02

Exhibit B, Page 260

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 261 of 352 Pageid#: 1164

voter_id

lname

40434681 R

917682805 R

104022785 R

919733736 R

402002242 R

302013388 R

414679920 R

508011161 R

706022576 R

918027678 R

300655008 R

610436534 R

918146828 R

4453148 R

276101184 R

304039316 R

919041905 R

292600513 R

920166171 R

83012659 R

508009199 R

919993770 R

917181723 R

120012889 R

503010711 R

508010156 R

507029947 R

904022950 R

917018657 R

407513789 R

901011187 R

707006131 R

707008167 R

fname ABERRA REBECCA JEAN VICKY CHARLES ANITA TORLING JUNE CORNELIA FRANCISCO MARGARITA MANUELA JACQUELINE JESSICA SOPHIA DONALD SHAKEEL NORA WILLIAM JOSHUA WILMA JANET MARK JAMES LEILA MARY FRANKLIN SAMUEL FAYE THOMASINE VELTON GARLAND KAREN

dob 1940 1955 1943 1951 1924 1963 1937 1921 1944 1942 1924 1927 1945 1995 1922 1928 1950 1936 1942 1976 1948 1947 1961 1948 1938 1924 1941 1955 1953 1942 1943 1945 1962

date_registered 2010-03-26 1996-09-24 1983-09-20 2004-04-05 1952-10-02 2002-03-26 2015-07-31 1989-08-28 1999-08-26 1997-06-23 2012-03-09 2012-03-29 1999-11-29 2016-02-04 2015-01-29 1964-10-03 2001-02-15 2017-08-07 2005-09-15 2011-12-07 1983-10-08 2004-10-04 1994-09-30 2012-09-27 1964-08-17 1950-09-11 1963-04-27 2005-06-15 1997-11-05 2009-09-28 1964-09-18 1970-06-13 1999-10-01

ssdi_dod 2019-09-12 2018-05-06 2019-10-23 2019-10-15 2019-10-06 2018-12-02 2019-01-30
2015-09-02 2014-04-15 2019-09-28 2019-10-08 2019-07-01
2019-12-23 2019-10-27 2019-03-20 2019-12-05 2019-02-24 2017-12-26 2019-12-07 2019-11-27 2019-08-07 2018-10-16 2018-01-04 2019-12-23 2019-09-02 2018-01-21 2017-01-30 2015-03-10 2019-12-27 2019-12-03

obit_dod
2018-05-06 2019-10-23 2019-10-15 2019-10-06 2018-12-02 2019-01-30 2016-01-15 2016-03-28
2018-12-10 2019-12-23
2019-03-20 2019-12-05 2019-02-24 2017-12-26 2019-12-07 2019-12-01 2019-08-07 2018-10-16 2018-01-04 2019-12-23 2019-09-02
2015-03-10
2019-12-03

Exhibit B, Page 261

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 262 of 352 Pageid#: 1165

voter_id

lname

407002900 R

756514707 R

597482647 R

918428290 R

103024297 R

702010533 R

920076531 R

803016505 R

705017050 R

181389403 R

917036166 R

223003148 R

202013638 R

312175919 R

134018472 R

23018829 R

24008272 R

907000234 R

13002174 R

306032138 R

226009158 R

226020699 R

111145850 R

507032983 R

917148019 R

443987876 R

401016717 R

506026386 R

226003286 R

207003922 R

342281242 R

307017345 R

24013533 R

fname DORIS JUDITH KATHLEEN AMANDA CLYDE CHARLES JAMES MOLLIE GENEVA GLADYS EDSEL SANDRA LARRIETTA NELL ELMA KEATH DOROTHY GWENDOLYN QUEEN HERBY MARY LAURANNA KYLE BEATRICE DONALD DIANE EMMA ELIZABETH BRENDA LOIS TONI KAREN JAMES

dob 1925 1949 1956 1976 1913 1947 1970 1937 1937 1924 1945 1946 1955 1915 1943 1938 1936 1933 1930 1938 1934 1946 1965 1931 1956 1948 1920 1940 1947 1941 1966 1955 1947

date_registered 2005-03-24 2012-09-14 2016-10-13 2000-05-15 1959-05-02 1968-10-04 2005-03-31 1959-05-29 1979-02-23 2010-09-23 1993-09-29 1987-11-04 1981-10-03 2007-10-09 1989-09-19 1962-07-12 1985-08-14 1964-10-01 1989-10-05 1960-10-04 1984-08-28 1974-04-03 2012-04-12 1964-08-10 1994-08-24 2017-11-13 1952-05-09 1964-03-01 1972-10-07 2006-03-08 2008-10-03 1985-05-04 1984-10-06

ssdi_dod 2019-11-21 2019-11-10 2019-10-19 2019-10-09 2019-09-10 2019-08-16 2019-06-29 2018-10-20 2018-04-25 2017-12-28 2017-12-10 2016-10-01 2015-12-15 2009-12-29
2020-01-17 2019-12-16 2019-10-17 2019-10-03 2019-09-17 2019-09-01 2019-06-29 2019-04-13 2003-09-07 1995-04-09
2016-11-07 2019-04-27 2017-06-22 2020-01-21

obit_dod 2019-11-21 2019-11-10 2019-10-19 2019-10-09 2019-09-10 2019-08-16 2019-06-29 2018-10-20 2018-04-25
2016-10-01
2019-10-20 2019-10-08 2019-09-21 2019-08-28
2019-12-16 2019-10-17 2019-10-03
2019-09-01 2019-07-01
2019-08-20 2016-11-07
2017-06-22

Exhibit B, Page 262

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 263 of 352 Pageid#: 1166

voter_id

lname

483958937 R

806020245 R

917286856 R

28830735 R

707014879 R

920358758 R

208007860 R

127007333 R

27004048 R

205026688 R

917580239 R

506006521 R

504000745 R

802020068 R

917118108 R

497269068 R

8001992 R

407013128 R

7001991 R

107006826 R

2001993 R

7001992 R

638030114 R

506008473 R

401011855 R

803020245 R

917278048 R

917392174 R

235282191 R

28012400 R

121013207 R

21012552 R

502023262 R

fname DONALD CARRIE PATRICIA IVAN LUCY GERTRUDE IRVING BARBARA JEANETTE JAMES WILLIE FREDERICK FRANCES NICOLE JOSEPH ANTHONY MARY FRANCES JAMES BARBARA ROBERT MARTHA CAROLYN INETTA BUDDY ALMA LOUISE EARL JEANNE MYRNA SUSIE DORIS EVELYN

dob 1937 1939 1940 1949 1945 1933 1941 1941 1947 1942 1952 1946 1936 1970 1974 1960 1939 1943 1940 1942 1933 1944 1962 1926 1939 1945 1922 1947 1932 1930 1928 1940 1934

date_registered 2008-06-02 1964-10-03 1995-05-10 2016-09-21 1977-09-16 2006-09-18 2018-10-09 2004-09-28 1983-06-06 1983-10-01 1996-08-05 1992-10-03 1976-10-02 1989-03-22 1994-04-06 2016-10-21 1966-08-03 1996-06-24 1997-11-05 1975-05-10 1966-08-03 1976-07-10 2016-10-12 1955-10-07 1963-09-30 1966-05-11 1995-05-01 1996-06-12 2012-09-19 1956-08-01 1984-03-31 1991-08-30 1959-06-04

ssdi_dod 2019-12-10 2019-11-23 2019-11-20 2019-11-17 2019-11-16 2019-11-06 2019-11-06 2019-10-24 2019-10-21 2019-10-20 2019-10-03 2019-09-16 2018-12-28 2018-12-08 2018-12-06 2018-09-22 2018-08-15 2018-01-24 2018-01-20 2017-12-23 2017-12-02 2017-11-12 2017-01-14 2016-09-06 2016-08-12 2016-02-18
2015-10-14 2019-11-05
2018-12-19

obit_dod 2019-12-10 2019-11-23 2019-11-20
2019-11-16
2019-10-24 2019-10-21 2019-10-20
2019-09-16 2018-12-28
2018-12-06 2018-09-22
2018-01-24
2017-12-02
2017-01-14
2016-08-12 2016-02-18 2018-12-09 2015-12-04 2015-10-14 2019-11-05 2019-08-02 2019-08-23 2018-12-19

Exhibit B, Page 263

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 264 of 352 Pageid#: 1167

voter_id

lname

823747620 R

274693909 R

102022915 R

105024841 R

386892975 R

226007698 R

124252647 R

82031890 R

919427943 R

917703026 R

184641753 R

136638598 R

120001762 R

711002194 R

104022786 R

24003742 R

334065616 R

601038566 R

917061237 R

919489844 R

918221204 R

706013583 R

306015174 R

609001524 R

104030367 R

307008232 R

121001632 R

225024210 R

605002191 R

612251392 R

301029055 R

301000210 R

227000522 R

fname FRANK KENNETH THOMAS CAROLE NELLIE JOSE MARIA SANTIAGO LUIS DANIEL ROSCOE JOSEPH DOROTHY WILLIAM JUDY PHILIP PHILIP JANIT LYLE MARY HARMONY GOLDIE JAMES BRENDA RICHARD ROBERT CAMILLA DAVID DOLORES VICTOR MARY JOE ANNE

dob 1933 1955 1947 1935 1934 1927 1929 1942 1943 1963 1949 1926 1930 1949 1944 1932 1948 1929 1927 1924 1979 1930 1938 1953 1933 1932 1948 1931 1933 1946 1928 1932 1941

date_registered 2012-09-28 2012-09-23 1975-10-03 2006-10-10 2013-06-29 1990-08-23 2016-06-28 2011-06-09 2002-11-13 2004-11-10 2007-09-24 2009-12-21 1955-05-01 2003-06-26 1993-02-01 1974-09-16 2007-08-24 1992-10-01 1993-11-29 2003-03-27 1998-03-23 1959-04-11 1990-08-18 1976-08-17 2000-01-24 1996-07-31 1978-04-01 1992-09-26 1980-09-25 2016-10-17 1964-09-30 1958-09-26 1966-06-09

ssdi_dod 2019-12-17 2019-09-24
2019-11-10 2019-09-12 2019-09-07 2006-03-07 2019-10-23 2019-08-06 2017-02-09
2020-01-07 2020-01-06 2019-12-04 2019-10-20 2019-10-13 2019-09-30 2019-09-29 2019-09-03 2019-08-12 2018-12-30
2018-12-15 2020-01-22
2019-12-17 2019-11-03
2017-12-08 2014-11-29
2018-12-06

obit_dod
2019-10-20 2018-07-12 2019-11-10 2019-09-12
2019-10-23 2019-08-06 2017-02-03 2017-01-01
2019-12-04 2019-10-20 2019-10-13 2019-09-30 2019-09-29 2019-09-03 2019-08-12
2019-05-22 2018-12-15
2019-08-28
2018-09-27
2019-08-20 2018-12-06

Exhibit B, Page 264

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 265 of 352 Pageid#: 1168

voter_id

lname

401007331 R

919380461 R

305050318 R

918033490 R

917897995 R

203750848 R

917075287 R

301006087 R

226377254 R

919762931 R

918887499 R

918958457 R

39421549 R

670787889 R

305004282 R

202199538 R

304024704 R

28017500 R

806009015 R

502022127 R

308051164 R

918035001 R

917298620 R

918419061 R

920123948 R

905011769 R

33520432 R

919990749 R

504008980 R

774913978 R

201025690 R

446056727 R

918526006 R

fname HARRY BOBBY GARY ROBERT CHARLES VERNON ALBERT GREGORY NICHOLAS NORMA JAMES JOSEPH JESSY FRANCES MARY EDWIN JUSTINE ALYCE FRANKLIN CECIL LINDA SAMUEL JUANITA JOHN BERNARD GEORGE LENA BERNARD LILA JO ANN ELIZABETH GARY ALBERT

dob 1931 1938 1943 1944 1964 1940 1927 1947 1944 1940 1944 1933 1992 1945 1937 1940 1924 1923 1941 1946 1947 1947 1938 1938 1945 1929 1932 1949 1924 1940 1937 1948 1944

date_registered 2003-07-29 2002-08-23 1992-12-07 1997-07-01 1997-02-07 2010-06-16 1994-02-15 1984-06-16 2012-11-21 2004-05-18 2000-09-15 2004-10-04 2011-03-28 2015-03-03 1972-10-02 2012-09-28 1955-12-12 1950-10-23 2004-08-23 1998-04-16 1998-10-05 1997-07-02 1995-06-30 1998-12-30 2005-06-15 1964-09-25 2012-08-15 2004-10-04 1948-07-02 2007-10-08 1959-09-28 2007-04-10 1999-06-18

ssdi_dod 2017-12-14 2019-04-11
2016-04-14 2019-09-26 2018-05-21 2019-11-27
2019-10-24 2019-10-09 2019-02-23 2016-12-20 2018-09-23 2019-09-10 2015-12-21 2019-10-09
2019-12-26 2019-08-22 2018-04-13 2019-10-27 2019-08-20 2018-05-20 2019-08-23 2019-03-31 2018-12-24 2018-12-13 2018-12-05 2018-03-24 2016-12-03

obit_dod 2017-12-14
2016-10-11
2019-09-26 2018-05-21 2019-11-27 2019-10-07 2018-06-08
2019-10-09 2019-02-23 2016-12-20
2019-09-10
2019-10-09 2018-03-17 2018-01-02 2019-12-26 2019-08-22 2018-04-13 2019-10-27 2019-08-20 2018-05-20 2019-08-23 2019-03-31 2018-12-24 2018-12-13 2018-12-05 2018-03-24
2019-11-01

Exhibit B, Page 265

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 266 of 352 Pageid#: 1169

voter_id

lname

658876312 R

901005690 R

918540855 R

702020057 R

918831179 R

918603468 R

21009820 R

303037897 R

10006955 R

103030596 R

918592562 R

803014020 R

918278556 R

903012773 R

917522900 R

278018639 R

918604093 R

869742897 R

902018970 R

919030963 R

918539088 R

307046767 R

227019831 R

226020059 R

309047517 R

919867712 R

302020648 R

404005175 R

917127274 R

919363096 R

303003216 R

814593307 R

704001119 R

fname PATSY ANN JAMES DOLORES GENIE RHODA SAMMY CAROLE RUTH JAMES CHARLES WILLIAM MYRNA JOSEPH LESLIE ANITA CHARLES LEONARD ENID RAMONA JUDY MELVIN MARGARET WILLIAM JANE JUAN JEFFREY DANIEL TODD VIRGINIA IRIS ANN FRANCES LILLIAN

dob 1931 1929 1929 1942 1930 1947 1934 1936 1957 1923 1945 1940 1933 1934 1916 1952 1947 1942 1953 1946 1927 1941 1942 1933 1950 1947 1946 1932 1934 1923 1928 1922 1918

date_registered 2018-08-13 1980-04-22 1999-07-15 1976-10-02 2000-07-24 1999-09-30 2002-08-06 1963-10-05 2004-03-10 1992-06-24 1999-09-23 1983-10-03 1998-08-11 1976-03-26 1999-09-23 2016-10-21 1999-10-04 2016-10-12 2006-09-07 2001-01-31 1999-07-08 1972-09-21 1992-09-10 1988-04-02 1987-07-29 2004-08-24 2006-10-05 1975-09-18 1994-06-15 2002-07-24 1972-09-12 2009-11-23 1955-06-09

ssdi_dod
2019-12-10
2019-09-14 2019-08-29 2019-03-11 2019-09-02 2018-12-08 2019-12-19 2019-12-05 2019-11-30 2019-08-08 2019-01-02 2018-12-25 2018-02-27 2018-02-22 2018-01-25 2018-01-22
2018-04-20 2019-08-31 2018-12-19 2014-12-08 2018-12-14 2018-12-04
2019-12-24 2018-12-02

obit_dod 2019-09-07 2019-03-06 2018-12-05 2019-08-01
2019-10-28 2019-09-14
2019-03-11 2019-09-02 2018-12-08
2019-12-05 2019-11-30
2018-12-25
2018-02-22
2019-09-26 2019-09-23 2018-09-21 2018-04-20 2019-08-31 2018-12-19
2018-12-14 2018-12-04 2019-09-15
2018-12-02

Exhibit B, Page 266

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 267 of 352 Pageid#: 1170

voter_id

lname

455278588 R

402659675 R

708025523 R

106022283 R

614462146 R

706009870 R

229017361 R

920338061 R

999815773 R

918120636 R

607002318 R

147546532 R

308005175 R

918943807 R

512027648 R

222012037 R

302001308 R

917063423 R

918102996 R

908010883 R

72878256 R

502016432 R

908010639 R

901022957 R

5108516 R

201017628 R

920115263 R

803020460 R

918605294 R

231007084 R

177163437 R

993347638 R

919933904 R

fname LINDA JOHN JUSTINE ROBERT MARIA BENJAMIN JEAN RANDOLPH JOANNE TED THOMAS BETTY FRANCES JOHNNY MARY GEORGE LENORA STEVEN CHARLES WILMA JAMES BARBARA THOMAS WILLIAM WILMER ADELE GERALD EDSEL ALBERT WILLIAM LARRY GERTRUDE TERRY

dob 1949 1980 1920 1937 1935 1940 1929 1936 1943 1931 1943 1943 1935 1930 1931 1943 1920 1933 1941 1961 1944 1929 1935 1932 1947 1917 1942 1930 1951 1943 1954 1940 1943

date_registered 2012-10-15 2016-07-18 1986-08-09 1984-08-10 2012-10-15 1964-05-09 1976-09-29 2006-08-10 2007-07-17 1997-11-05 1965-01-01 2008-04-11 1980-08-13 2000-10-10 1991-07-10 1995-05-13 1978-10-04 1993-12-15 2002-07-03 1983-09-08 2008-09-29 1987-10-01 1956-08-21 1976-08-24 2018-10-08 1964-05-21 2005-06-20 1955-10-08 1999-10-04 1992-07-25 2012-09-18 2008-09-24 2004-10-01

ssdi_dod 2015-04-11 2018-09-06 2019-10-09 2019-03-13 2018-06-14 2018-05-07
2020-01-12 2019-12-06 2019-10-17
2019-05-02 2016-07-12 2018-12-17 2019-11-18 2013-02-09
2016-11-22 2019-11-21 2019-08-07 2018-03-26
2019-08-25 2018-11-07
2019-09-18 2019-12-22 2019-08-08
2019-11-25

obit_dod
2019-03-13
2019-08-31
2019-12-05
2018-12-01 2016-06-27 2019-05-02 2016-07-12 2018-12-17 2019-11-18
2019-08-10
2019-11-21 2019-08-07
2017-08-19
2018-11-07 2019-06-12 2019-09-18 2019-12-22 2019-08-08 2019-07-20 2019-11-25 2018-11-23 2018-12-14

Exhibit B, Page 267

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 268 of 352 Pageid#: 1171

voter_id

lname

53234706 R

99802520 R

768050911 R

507004625 R

303012945 R

66461759 R

202011400 R

224017363 R

920042500 R

920042496 R

104004151 R

919194639 R

205011975 R

132586012 R

918320689 R

807020252 R

411023745 R

918606031 R

45323066 R

506010395 R

918037761 R

918948398 R

706003204 R

222015519 R

301019369 R

917758997 R

917668676 R

246536318 R

706012132 R

602020204 R

403001923 R

107018939 R

902000240 R

fname LOTHAR MARIO ELSA RUBY ROBERT BETTY DORIS KATHERINE NORMA DONALD MARGARET RAYMOND PAUL CHARLES TRICIA JOYCE EDGAR ANNIE JOHN DARRELL LEONA JOSEPH DAVID AARON ESTELLE JACK DEBORAH JOYCE JERRY BEVERLY JAMES JOHN TIMOTHY

dob 1931 1938 1946 1950 1934 1929 1929 1938 1945 1942 1939 1960 1930 1942 1972 1938 1931 1925 1920 1951 1952 1970 1941 1946 1937 1941 1951 1939 1947 1949 1926 1925 1941

date_registered 2016-04-20 2009-09-28 2008-10-06 1977-10-08 1994-03-28 2016-01-06 1984-09-22 1984-03-31 2005-01-10 2005-01-10 1971-09-30 2001-09-27 1964-10-01 2008-09-12 2000-05-15 1999-08-06 1988-06-28 1999-10-01 2010-05-12 1975-09-09 1997-07-07 2000-10-09 1968-05-17 2000-07-18 1960-09-20 1996-10-07 1996-09-19 2012-10-05 1979-04-24 2012-10-01 1949-03-10 2000-04-17 2005-07-25

ssdi_dod
2019-10-08
2018-12-04 2019-11-29 2019-11-29 2020-01-16
2018-05-31 2018-01-15
2019-12-21 2019-11-04 2019-10-08 2019-09-28 2019-09-21 2019-09-20 2019-08-20 2018-05-31 2018-03-06 2018-01-02 2016-09-30
2019-12-07 2018-12-18 2018-02-02
2019-11-10 2018-12-23

obit_dod 2019-01-17 2019-10-08 2018-02-21 2018-12-04 2019-11-29
2019-10-27 2018-05-31
2018-12-07 2019-09-08 2019-12-21 2019-11-04 2019-10-08 2019-09-28 2019-09-21 2019-09-20
2018-05-31 2018-03-06
2016-09-30 2018-12-05 2015-05-29
2018-08-10 2019-11-10 2018-12-23 2018-09-17 2019-10-15

Exhibit B, Page 268

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 269 of 352 Pageid#: 1172

voter_id

lname

393034981 R

123442904 R

601038083 R

818662939 R

150057622 R

224008892 R

285503501 R

409001203 R

909005112 S

919702731 S

104014497 S

403017494 S

904010884 S

602011770 S

102211722 S

405017494 S

918274007 S

906002398 S

205256054 S

119474267 S

920130588 S

278278241 S

919470934 S

613122312 S

919375989 S

918719906 S

920212177 S

918938131 S

919110999 S

33492279 S

703021438 S

720058528 S

919887548 S

fname CHARLOTTE JAMES RONALD ALICE VICKI DORIS LEROY DARYLE FRANCES HAROLD JOHN DONALD WILLIAM BARBARA J TUPE TINA VIJAYALAKSHMI MARY ASAAD DEBRA GREGORY JANE ABEL BRIAN BHAGWAN ARTHUR GEORGIA MOHAMMAD CYNTHIA DOMINADOR ANNE HARVEY MILES

dob 1943 1946 1927 1935 1947 1931 1938 1939 1946 1919 1947 1953 1934 1933 1946 1919 1963 1932 1941 1955 1963 1938 1984 1956 1946 1943 1956 1940 1946 1927 1934 1941 1949

date_registered 2015-10-09 2014-05-14 1998-06-29 2008-04-02 2017-07-14 1968-09-27 2012-10-10 1992-03-09 1992-03-28 2004-02-12 1980-06-11 2000-12-11 1964-05-01 1987-09-23 2018-02-14 1976-10-02 1998-06-01 2000-07-14 2008-05-12 2008-09-09 2006-04-13 2012-04-27 2008-08-28 2010-03-03 2002-08-16 2000-03-17 2005-11-17 2001-08-22 2001-05-14 2009-09-05 2016-08-18 2008-10-06 2004-09-15

ssdi_dod
2018-10-30
2019-12-01 2019-02-09 2017-04-19 2019-10-18 2017-09-30
2019-10-18 2017-03-28 2015-09-28 2019-02-28 2017-12-31 2019-08-06 2019-12-18 2018-05-24 2018-12-12 2019-05-06 2019-10-23 2019-09-07 2019-11-28 2018-12-13 2018-12-18 2018-02-09 2018-03-23 2019-11-08
2019-11-30
2017-11-30

obit_dod 2019-09-22
2019-06-08
2017-04-19 2019-10-18 2017-09-30 2019-08-25 2017-05-28 2019-08-20
2017-03-28
2019-08-06 2019-12-18
2019-05-06 2019-10-23 2019-09-07 2019-11-28 2018-12-13 2018-12-18
2019-11-08 2015-05-02 2019-11-30 2015-10-09 2017-11-30

Exhibit B, Page 269

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 270 of 352 Pageid#: 1173

voter_id 28389087 S
703014167 S 202016696 S 918547276 S 206025047 S 917509055 S 917404703 S 107006067 S 245632511 S 113001108 S
27010731 S 911006930 S 918024353 S 802014534 S 120876913 S 123005076 S 119289975 S 917642011 S
3060147 S 919127897 S 291520478 S 105002976 S 402018514 S 918309755 S 705014012 S 917919315 S
23000477 S 918319571 S
39935697 S 225016988 S 126012002 S 706006132 S 201020957 S

lname

fname LORIN ALICE LYNDA BERNARD VIRGINIA RHODA DOROTHY JAMES CHARLES SHIRLEY LOLA FRANCES TEODORA HAROLD EUGENE FELIX THOMAS BOLESLAUA ADRIANA BRUCE PAMELA REBA ELLA NEEDHAM RAY JOHN FRANCES NELLIE SHIRLEY VERNICE MAEREATHER JANET WALLACE

dob 1942 1933 1947 1948 1962 1949 1936 1954 1961 1949 1943 1948 1948 1936 1950 1925 1928 1943 1927 1966 1943 1934 1925 1943 1944 1949 1942 1923 1924 1933 1934 1937 1939

date_registered 2018-02-16 1956-09-29 1997-01-28 1999-07-23 1999-07-12 2005-10-03 1996-03-14 1984-02-03 2013-04-03 1983-09-17 1996-05-13 1999-11-03 1997-06-11 1980-10-03 2010-09-28 2008-09-04 2016-08-29 1996-09-03 2017-12-21 2001-06-13 2016-10-14 1966-12-21 1987-01-05 2003-01-16 1967-09-25 1997-02-13 1991-09-17 1998-08-04 2012-03-14 1988-09-11 1977-10-08 1959-07-20 1992-09-05

ssdi_dod
2019-10-04 2019-08-13 2019-10-15 2019-04-15 2018-04-28 2018-01-26 2017-01-30 2014-11-12 2018-12-01
2016-03-31 2019-12-07 2018-01-01 2016-11-20 2016-10-19
2018-12-28 2019-10-19 2018-08-28 2017-05-04 2020-01-17 2019-09-18 2019-04-15 2018-12-19 2018-01-12 2017-04-20
2020-01-13 2018-12-16 2018-10-27 2020-01-07

obit_dod 2019-10-23
2019-08-13 2019-10-15 2019-04-15 2018-04-28 2018-01-26 2017-01-30 2014-11-12 2018-12-01 2019-08-20 2016-03-31
2018-01-01
2019-08-24 2013-05-05
2019-09-18 2019-04-15
2018-01-10 2017-04-20 2019-02-08
2018-12-16

Exhibit B, Page 270

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 271 of 352 Pageid#: 1174

voter_id 357041771 S 513011222 S 919242517 S
82906884 S 919262728 S 204028080 S 350621504 S 477111380 S 919165634 S 396775385 S 918946586 S 207015291 S 703014367 S 919355313 S 919035106 S 301009672 S 227001698 S 409020120 S 203016365 S 910001131 S 307019371 S
33163236 S 5472616 S
26018261 S 901008857 S 223022784 S 201017965 S 920064680 S 807014209 S 703005229 S 506004498 S 918214373 S 403024926 S

lname

fname KATIE HENRY REGINALD ALBERT GLORIA TOORAJ JOSE EDWIN JOSEFINO KATHERINE JAMES JANNIE RETA JAGJIT CARMEN PARICHEHR DAVID RUFUS ROBERT DENNIS THOMAS SUHAG UHRETTA BEVERLY NORMA ROBERT CHARLES PEGGY BOBBIE MARIE MARTHA EVA BARRY

dob 1943 1938 1939 1926 1928 1945 1945 1961 1941 1948 1936 1938 1949 1932 1932 1941 1946 1931 1947 1943 1942 1924 1934 1941 1943 1937 1944 1958 1945 1939 1921 1939 1932

date_registered 2017-10-06 2003-10-01 2001-12-08 2012-08-17 2006-04-13 1988-05-28 2016-03-02 2010-12-16 2001-08-22 2016-10-12 2000-10-10 1972-03-07 1984-09-12 2002-07-08 2001-02-06 1993-04-09 1987-05-01 1989-10-04 2000-12-05 1998-07-22 1983-09-20 2012-08-01 2012-10-11 1976-09-29 2000-08-03 1999-11-03 1987-10-03 2005-03-03 1984-01-19 1964-05-02 1976-03-15 1998-03-13 1993-09-30

ssdi_dod
2019-12-13 2019-09-22
2019-08-15 2019-08-16 2018-07-23 2019-11-17 2019-09-11 2019-10-26 2018-12-21
2019-06-28 2017-11-22 2019-03-20 2019-11-23 2017-07-21 2018-12-25 2019-12-21 2019-11-14
2019-09-08 2019-12-03 2019-12-29 2019-12-24 2019-12-18 2019-12-15 2019-09-16 2019-07-16 2019-02-25 2018-12-29 2018-05-13 2018-05-01

obit_dod 2019-08-04 2019-09-22 2019-02-08 2019-08-15
2019-11-17 2019-09-11 2019-10-26 2019-10-30 2019-06-28
2017-07-21 2018-12-25
2019-08-13
2019-12-24
2019-09-16 2019-07-16 2019-02-25 2018-05-13 2018-05-01

Exhibit B, Page 271

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 272 of 352 Pageid#: 1175

voter_id 406092321 S 404025729 S 907022453 S 121004554 S 733545911 S 128015940 S 601017005 S 102001853 S 520729712 S 917795704 S 919034255 S 226019261 S 919229729 S 976456778 S 919400233 S 917302819 S
21009826 S 225004071 S 806004971 S 224001699 S
22006746 S 918951399 S 806006594 S 901018150 S 918301025 S 511731906 S 107106917 S 350811179 S 156696267 S 918040371 S 918588148 S 506010248 S 506021695 S

lname

fname THERESA GOLDIE ALBERTA EDNA IRVING HATTIE MARY BESS MARY WAYNE ALBERT WALTER ROSALIE CYNTHIA RUSSELL EHSAN ROLAND EDWARD PEGGY DONNA KENNETH CATHERINE JOHN DAVID MARVIN ROBERT KATHY HARRY EUGENE WILLIAM AUBREY PATSY HORACE

dob 1938 1931 1924 1939 1924 1937 1923 1948 1947 1954 1931 1945 1921 1932 1952 1941 1931 1952 1934 1957 1955 1929 1930 1944 1948 1944 1963 1935 1963 1949 1955 1938 1935

date_registered 2008-10-03 1972-09-14 1968-10-03 1960-08-15 2008-10-02 1976-10-02 1998-09-10 1980-04-09 2016-04-08 1996-10-07 2001-01-08 1972-09-28 2001-11-07 2009-01-29 2002-09-18 1995-07-20 1952-04-16 1987-02-05 1971-09-27 1975-05-13 2000-06-07 2000-10-10 1978-09-13 1979-10-04 2001-07-30 2008-09-30 2015-09-15 2013-07-10 2013-11-06 1997-07-11 1999-09-20 1971-09-23 1972-07-26

ssdi_dod 2018-04-24 2018-01-02 2017-04-25 2016-09-15 2009-07-16
2019-12-17 2019-12-09 2019-10-11 2018-08-26
2019-08-13 2016-07-26 2018-12-16 2019-12-25 2019-11-22 2019-10-13 2019-09-25 2019-09-19 2019-09-01 2019-08-27 2018-12-19
2018-12-08 2019-11-30 2018-12-22 2019-11-30 2019-10-29 2017-11-30 2017-10-10 2020-01-17 2018-12-17

obit_dod 2018-04-24
2017-04-25
2018-12-18 2016-09-09 2019-12-17 2019-12-09 2019-10-11 2018-08-26 2019-08-16 2019-08-13 2016-07-26 2018-12-16
2019-10-13
2019-09-19 2019-09-01 2019-08-27 2018-12-19 2019-10-21 2018-12-08 2019-11-30 2018-12-22 2019-11-30
2017-11-30 2017-10-10
2018-12-17

Exhibit B, Page 272

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 273 of 352 Pageid#: 1176

voter_id 918603724 S
21009996 S 23005857 S 809018777 S 809012160 S 808014644 S 606001886 S 602039412 S 223015763 S 179640325 S 919997035 S 308005555 S 155458970 S 918506464 S 504010040 S 705019610 S 701375601 S 918705510 S 138460623 S 919070250 S 602003892 S 917192821 S 27010969 S 917985318 S 406027314 S 919582012 S 920366315 S 60005733 S 304008421 S 918601241 S 918780863 S 154339773 S 920151322 S

lname

fname JOSEPH RUTH ELTON DON ROSEMARY BRENDA ROBERT ARLEEN HARRY MICHAEL CATHERINE GEORGE DANIEL HARRY JOSEPH DENNIS PATRICIA CARL WALTER DOROTHY PAUL CHARLES VIRGINIA RACHEL SUSAN SARA WALTER NORI RICHARD CHARLES ROBERT PEGGY DAVID

dob 1961 1930 1944 1953 1925 1940 1932 1942 1937 1949 1921 1940 1953 1951 1940 1952 1932 1934 1954 1966 1921 1935 1920 1979 1947 1927 1941 1933 1921 1953 1949 1947 1925

date_registered 1999-09-27 1963-04-15 1988-02-06 1988-01-26 1991-04-15 2004-11-30 1959-03-17 1992-10-01 1983-06-29 2016-10-21 2004-10-04 1987-08-31 2016-03-02 1999-05-19 1980-11-20 1993-07-01 2007-05-14 2000-03-01 2008-09-23 2001-03-28 1969-06-13 1997-07-18 1987-10-03 1997-04-24 2003-03-10 2003-08-28 2006-09-28 2014-05-02 1958-10-04 1999-09-30 2000-05-03 2012-10-15 2005-08-22

ssdi_dod 2018-01-11 2019-12-24
2019-09-27
2019-11-14 2020-01-04
2019-12-29 2018-05-05 2017-04-10 2019-11-22 2019-10-02 2017-10-01
2019-02-25
2019-11-25
2017-08-16
2019-08-10
2014-02-13
2019-10-30 2015-12-20 2018-05-01 2014-11-06 2019-08-21 2019-11-11 2019-11-30 2019-08-02

obit_dod 2018-01-11
2019-10-06
2019-09-03 2019-11-14
2018-10-08
2018-05-05
2019-11-22
2018-08-10
2019-05-23 2019-11-25 2015-06-21 2017-08-16 2017-09-20 2019-08-10 2017-02-15 2014-02-13 2019-08-28 2019-10-30
2018-05-01 2014-11-06 2019-08-21 2019-11-11 2019-11-30

Exhibit B, Page 273

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 274 of 352 Pageid#: 1177

voter_id 203020266 S 208020266 S 124962193 S 122001277 S 919418433 S 974520659 S 201028085 S 504006534 S 802006773 S 408029776 S
1192734 S 917658830 S 471484472 S 537664601 S 917385995 S 920231553 S 221008898 S 702029133 S 829974560 S 125017848 S 111521160 S 918558385 S 905020896 S 304024358 S 309032486 S
50679936 S 918162387 S 202019872 S 703026684 S 309018628 S
3695007 S 702026161 S
67226265 S

lname

fname DARLENE THOMAS JOY WARREN WILLIAM BRUCE ANNIE RUTH CHARLES PATRICIA ELIZABETH CHERIE DORIS CREMILDE JANE STEPHEN EDWARD WILLIAM GEORGE ROBERT JOHN CARL EUGENE HONOR DIANE CAROL PHILIP SHIRLIE MARTHA SHIRLEY KLEMENS RICHARD VERNICE

dob 1935 1932 1944 1935 1931 1943 1950 1926 1931 1925 1925 1948 1921 1919 1940 1945 1950 1945 1930 1932 1942 1933 1921 1920 1934 1943 1948 1940 1920 1950 1934 1927 1933

date_registered 1973-10-06 1997-12-30 2011-09-22 2003-08-26 2006-08-02 2009-04-29 1997-02-04 1979-09-28 1972-10-05 2000-03-01 2016-12-05 1998-11-04 2010-09-13 2010-07-08 1995-12-29 2005-12-29 1978-09-27 1992-02-06 2008-07-07 1960-01-26 2016-09-20 1999-08-10 1951-09-01 2004-02-11 1980-09-10 2016-10-12 1997-12-06 2000-04-21 1968-10-03 1988-05-09 2008-05-14 1986-09-20 2016-08-04

ssdi_dod 2019-11-01 2018-12-29
2019-06-17 2019-09-28
2018-07-01 2019-08-26 2018-06-23 2019-11-23 2019-12-03
2019-12-22 2019-11-29 2018-05-15 2019-05-20 2019-11-22 2019-10-26
2018-10-17 2017-01-02 2019-12-18 2017-11-29 2018-05-07 2017-01-28
2019-10-07 2019-01-10 2019-01-31
2019-11-04 2017-12-24

obit_dod 2019-11-01
2018-02-03
2018-12-03 2018-07-01 2019-08-25 2018-06-23 2019-11-23 2019-12-03 2018-12-13 2017-04-27
2019-11-29
2019-05-20 2019-11-22 2019-10-26 2018-12-20
2017-01-02
2017-11-29 2018-05-07 2017-01-28 2019-05-27 2019-10-07
2017-12-21

Exhibit B, Page 274

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 275 of 352 Pageid#: 1178

voter_id 125014590 S 307049109 S
25012720 S 396594413 S 915765458 S 201010648 S 605004540 S
85854732 S 83118765 S 508010248 S 128005077 S 222019264 S 501025308 S 21017995 S 403003750 S 418220238 S 501009489 S 920323080 S 26952602 S 918635888 S 920183713 S 802002422 S 917741163 S 503535533 S 905007844 S 904006677 S 303049987 S 638883787 S 24018263 S 924111895 S 502007450 S 223001453 S 918627282 S

lname

fname MARY CHARLES ALFRED JOHN JESSE DAVID GILBERT SAMANTHA RUBY BERTHA JUANITA DONNA MARION RALPH JOHN DOUGLAS DANIEL LYNDA LEDONNA MARSHALL RONALD EDWARD HARRIET WALTER ROBERT WILLODENE JOSEPH FRED BERNARD INEZ PANIE LUBERTA SANDRA

dob 1929 1948 1938 1933 1948 1947 1937 1951 1926 1920 1925 1946 1932 1929 1925 1958 1925 1948 1931 1954 1934 1926 1950 1933 1939 1947 1935 1929 1946 1947 1937 1925 1941

date_registered 1976-09-14 1997-10-02 1999-11-16 2010-09-11 2008-08-08 1975-09-05 1967-05-12 2014-08-06 2009-09-25 1951-08-06 1984-03-23 2005-10-10 1956-05-05 1972-09-25 2000-05-22 2012-10-15 1946-10-31 2006-06-29 2010-10-01 1999-11-09 2005-10-05 1983-04-04 1996-10-07 2010-09-30 2005-06-15 1974-04-05 1998-11-12 2008-01-14 1967-05-29 2008-05-16 1959-04-24 1986-08-28 1999-11-03

ssdi_dod 2012-04-22
2019-11-20 2019-12-15 2019-12-08 2019-10-11 2019-09-12 2019-08-29 2019-08-16 2019-05-10 2019-01-31 2018-12-24 2018-12-17 2018-12-03 2018-05-29 2018-03-15 2018-02-27 2017-10-13 2017-07-26 2016-10-30 2015-03-22 2014-06-15 1998-07-22
2018-09-29

obit_dod 2012-04-22 2013-06-22 2019-09-07 2019-11-20 2019-12-15
2019-10-11
2019-08-29 2019-08-16 2019-05-10
2018-12-17 2018-12-03 2018-05-29 2018-03-15
2017-10-13 2017-07-26 2016-10-30 2015-03-22
2019-11-04 2019-10-27 2019-10-12 2019-09-27 2019-09-24 2019-09-22 2018-12-20 2017-09-28 2018-09-29

Exhibit B, Page 275

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 276 of 352 Pageid#: 1179

voter_id 301011402 S 919937104 S
5348586 S 28019026 S 303045481 S 919580153 S 306033135 S 11033177 S 25007956 S 701016711 S 406013955 S 229013783 S 274757849 S 301039966 S 229013822 S 917182883 S 206019189 S
5006815 S 310044788 S 803011206 S 125007804 S
65668448 S 607006558 S 227005856 S 920399248 S 303036157 S
35340987 S 920175722 S 233014332 S 712004730 S 512020684 S 107013150 S 687427703 S

lname

fname JAMES TSEHAY WALTER THOMAS DENNIS ANNE ALICE EDDIE LAMAR BARNEY CURTIS JANE DENNIS IRENE KENNETH NINA ANN LYN PATRICIA WILLIAM ROBERT JAMES JANE IRVING ESTELLE NELSON ALICE PEER BRIDGET LARRY ELLERY RAMSAY ERIC

dob 1937 1977 1948 1929 1945 1942 1932 1967 1948 1948 1935 1943 1953 1929 1947 1930 1923 1943 1947 1965 1948 1945 1933 1947 1928 1925 1917 1978 1938 1940 1944 1948 1960

date_registered 1972-09-29 2004-10-01 2015-11-06 1966-12-02 1989-09-28 2003-08-26 1993-11-30 2016-09-09 1984-09-19 1976-09-28 1964-10-20 1998-08-21 2016-09-16 1972-03-02 1972-10-06 1994-10-03 2001-08-15 1996-11-06 1991-09-14 1983-05-03 1999-11-05 2018-03-08 1987-03-26 1996-05-13 2006-11-16 1952-05-09 2013-10-01 2005-09-27 1992-10-01 1998-02-02 1999-01-14 1999-09-21 2008-01-04

ssdi_dod 2014-09-13 2018-12-25 2019-11-01 2020-01-13 2018-12-12 2019-11-23 2019-12-30 2018-01-16 2019-12-10 2018-12-09 2019-08-26 2019-09-26 2019-10-26
2020-01-17 2016-12-26
2019-10-16 2019-09-22 2019-09-17
2020-01-08 2019-12-05 2020-01-08 2018-02-02 2019-11-18
2019-12-18 2019-11-10
2018-01-24

obit_dod
2018-12-25 2019-11-01
2019-11-23
2018-01-16
2018-12-09 2019-08-26 2019-09-26 2019-10-26 2019-08-18
2016-12-26 2019-10-03 2019-08-16 2019-09-25 2019-10-15 2019-09-22 2019-09-17 2018-12-08
2019-12-05
2018-02-02 2019-11-18 2015-03-21 2019-12-18 2019-11-10 2019-05-30

Exhibit B, Page 276

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 277 of 352 Pageid#: 1180

voter_id 5003052 S
919258329 S 98764329 S
601029521 S 105014809 S 903001770 S 236821701 S 310014661 S 208017973 S 540637877 S 104017421 S 226863318 S 148910456 S 917357979 S 808006933 S
25014918 S 702013378 S 806015737 S 919357275 S 615620213 S 203022817 S 705006052 S 801006934 S 602013520 S 919666585 S 305045872 S 918587930 S 917335080 S 106005616 S 906006194 S 370925695 S
18706809 S 255134975 S

lname

fname MARY MORRIS BARBARA ROSALIE HELEN NORVICE DONALD PHILIP LOUIS CHARLES JOSE JEFFREY PEARLINE PATRICIA FRAITUS BARBARA WILEY GEORGE DORIS DELOIS CHARLES IRVIN ALFRED WILLIAM CANDY JOHN CLIFTON ARTIE BULIS EVELYN HOMER JAMES SANDRA

dob 1939 1937 1945 1918 1926 1948 1931 1945 1929 1951 1933 1955 1926 1948 1939 1942 1943 1947 1930 1966 1930 1949 1942 1946 1978 1932 1949 1932 1944 1943 1934 1943 1938

date_registered 1965-06-12 2002-01-04 2009-04-17 1946-10-22 1975-05-30 1979-08-20 2007-11-20 1991-09-12 1989-09-26 1995-04-03 2001-01-29 2011-06-10 2008-10-06 2000-11-06 1987-07-06 1989-10-07 1970-03-28 1968-07-25 2002-07-11 2007-05-03 1956-01-14 1993-11-24 1982-09-30 1998-07-15 2007-03-01 1994-11-10 1999-09-20 1995-09-22 1980-10-03 1999-08-18 2007-06-04 2010-10-05 2012-09-21

ssdi_dod 2018-12-05 2019-09-26 2019-07-24 2018-12-14
2019-11-18 2019-09-05
2019-09-04 2019-11-12 2019-04-03 2013-10-13 2019-12-19 2019-11-18 2019-10-06 2019-04-15 2018-05-02 2016-09-19 2019-10-12 2019-08-22 2018-12-19 2016-12-16 2019-12-24 2019-11-24 2019-11-03 2019-10-22 2019-08-27 2019-05-09 2018-05-06 2017-11-23

obit_dod 2018-12-05 2019-09-26 2019-07-24 2018-12-14 2019-08-02 2018-04-30 2018-12-06 2019-05-15
2019-09-05 2019-06-27 2019-09-04 2019-11-12
2019-11-18 2019-10-06 2019-04-15 2018-05-02 2016-09-19
2019-08-22
2019-12-24 2019-11-24 2019-11-03 2019-10-22 2019-08-27 2019-05-09 2018-05-06 2017-11-23

Exhibit B, Page 277

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 278 of 352 Pageid#: 1181

voter_id 403170773 S 606031514 S 705022366 S
76929076 S 463773850 S 239177140 S 608005557 S 607023587 S 919746390 S 301002962 S 603034339 S 919988090 S 305017001 S 302840958 S 415607350 S 918391865 S 509023975 S
53197068 S 918826708 S 805010037 S 308026545 S 301005563 S
23006521 S 26011547 S 918179911 S 304004306 S 308029541 S 917219400 S 201029067 S 803008589 S 906002712 S 919454800 S 917542633 S

lname

fname MELVIN JAMES SHARON NORMA INGEBORG JEAN SANDRA JUDY JUDITH VIVIAN RATILAL BABUBHAI MOHAMMED NAWIN EINELHAYAT MOYASSER SHAHIN ROOBEKHAIR GAUDA DAVID ROLAND WILLIAM FLOSSIE ROBERT KATHERINE PAUL LEELAH DANA GLORIA GARNETT JOSEPH MAYNARD ADRIENNE

dob 1948 1942 1948 1966 1931 1927 1946 1947 1944 1940 1919 1937 1920 1967 1929 1935 1934 1932 1963 1927 1928 1928 1935 1940 1942 1946 1933 1928 1952 1919 1935 1922 1948

date_registered 2012-10-02 1970-10-02 1980-09-26 2015-05-05 2016-10-07 2015-11-13 1985-08-03 1981-09-09 2004-05-05 1977-10-01 1992-09-16 2004-10-04 2002-12-02 2010-01-05 2016-03-09 2000-11-08 1983-10-08 2018-10-12 2004-09-23 1992-03-15 1977-10-05 1991-07-29 1972-06-30 1975-11-28 1998-01-14 1976-10-01 1972-09-09 1994-10-08 1988-09-23 1999-03-08 1996-11-06 2003-01-09 1998-02-04

ssdi_dod 2019-09-18 2019-11-10 2020-01-09 2019-11-24 2018-05-24 2019-05-11 2018-12-26 2018-12-01
2019-12-09 2019-09-23 2017-08-24 2019-04-08 2020-01-29 2018-12-17 2018-12-11 2019-09-26 2017-09-19 2018-12-21
2019-11-07 2018-06-12 2019-09-15
2019-10-07 2014-09-30 2019-09-27 2018-12-14 2018-01-18 2018-01-01 2016-04-19

obit_dod 2019-11-10
2019-05-11 2018-12-26 2018-12-01 2019-03-18 2018-12-06 2019-12-09
2018-12-11
2018-12-21 2018-10-23 2018-08-31
2019-09-15 2019-04-10
2019-09-27 2018-12-14 2018-01-18 2018-01-01

Exhibit B, Page 278

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 279 of 352 Pageid#: 1182

voter_id 901008566 S 203008992 S 201007612 S 114004341 S 308001325 S 222012046 S 232033309 S 608007845 S 224010404 S 787651826 S 403011741 S 137686596 S 583323410 S 919914258 S 500084510 S 223011784 S
22018619 S 29016322 S 98604905 S 917256327 S 919241021 S 407010761 S 471925155 S 77292309 S 107020796 S 206026268 S 507019229 S 301025525 S 809018660 S 605015514 S 226008591 S 130006380 S 207002875 S

lname

fname JERRY EULA PATSY PAULINE JOAN CHARLES MICHAEL ROBERT ROBERT JOAN BRYAN JOHN DENNIS PRISCILLA GEORGE JOHN CHARLOTTE WILLIE MILDRED JOAN JOHN JOSEPH JANIPHER PAMELA NANCY SAMUEL BOBBIE ANITA STEPHEN GLADYS MARGARET DONNA DONALD

dob 1932 1928 1945 1934 1931 1936 1961 1945 1936 1931 1940 1955 1947 1926 1928 1945 1934 1948 1918 1931 1952 1943 1981 1952 1936 1927 1921 1931 1922 1919 1929 1944 1929

date_registered 1955-12-21 1966-07-23 1977-10-03 1988-10-02 1968-10-01 2006-08-18 2008-05-10 1974-06-28 1972-10-06 2011-08-01 1976-10-02 2015-10-07 2016-09-21 2004-09-25 2011-09-12 1969-07-17 1974-09-24 1992-03-05 2014-09-05 1995-03-22 2001-12-06 1983-09-22 2008-10-06 2016-05-23 1968-09-23 1968-08-14 2005-06-27 1963-10-05 2006-08-28 1980-10-04 1972-09-07 1989-03-15 1971-05-15

ssdi_dod
2019-11-05 2017-08-22 2019-09-23 2019-10-06 2019-08-14 2019-10-16
2020-01-12 2019-12-10 2019-12-08 2019-10-04 2019-07-09 2018-12-29 2018-12-12
2019-11-19
2017-06-01 2019-11-24 2018-12-17 2019-10-13 2019-12-26 2019-10-02 2019-03-19 2018-12-18 2018-01-21 2006-05-21 2020-01-15 2019-07-05 2018-01-30

obit_dod 2019-09-18 2019-11-05 2017-08-22 2019-09-23
2019-08-14 2019-10-16 2019-08-25
2019-12-10 2019-12-08 2019-10-04
2018-12-29 2018-12-12 2016-08-12 2018-12-06 2019-11-19 2019-08-20 2016-01-29 2017-06-01 2019-11-24
2019-10-13
2019-03-19
2018-01-21 2006-05-21
2018-01-30

Exhibit B, Page 279

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 280 of 352 Pageid#: 1183

voter_id 918116067 S 707016712 S 705008047 S 208012881 S 105003627 S 918995606 S 704017766 S 918001949 S 919257863 S 919699167 S 801011515 S
4005269 S 702014016 S
17955322 S 702013379 S 802008247 S 918930755 S 203026269 S 918966806 S 701024695 S 685295212 S 113024859 S 917159112 S 918713313 S 130003321 S 917234193 S 104022125 S 203023495 S 920190529 S 867302867 S 223001245 S 905007850 S 920382092 S

lname

fname SUZANNE EDMOND BEATRICE CLIFTON ERNEST REX LINDA MARTINA LEON LICHENG MABEL ANDREW ESTHER CHARLES EVELYN CLARENCE PATRICIA FLOYD GERALD RALPH GEORGE JOEL SHIRLEY BARBARA CAROLYN CHARLES WILLIAM BARBARA JAMES MARY JANE MARY VIRGINIA

dob 1947 1945 1932 1943 1920 1955 1944 1944 1939 1931 1924 1948 1935 1968 1928 1928 1949 1931 1942 1948 1949 1934 1926 1943 1936 1950 1925 1938 1961 1938 1918 1939 1947

date_registered 1997-10-06 1980-09-24 1975-05-05 1980-09-23 1987-09-01 2000-12-04 1996-08-09 1997-05-12 2001-12-28 2004-03-01 1992-08-05 1972-09-28 1991-05-06 2013-02-07 1991-09-18 1972-01-21 2000-10-07 1959-11-11 2000-10-10 1977-11-09 2017-09-27 1988-09-30 1994-09-10 2000-03-01 1991-09-23 1995-01-09 1984-03-24 1992-09-23 2005-10-11 2008-05-22 1950-08-28 1983-01-01 2006-10-10

ssdi_dod 2020-01-17 2020-01-20 2019-12-23 2019-12-12 2019-12-05 2019-03-11
2018-05-15 2016-09-28 2020-01-17 2019-11-12 2019-09-04
2019-11-26 2019-11-23 2019-10-11 2019-12-12 2019-09-06 2018-07-16 2019-07-22 2019-12-20
2020-01-25 2019-07-20 2018-12-06
2019-03-19 2018-12-28 2014-10-25 2020-01-30 2019-12-19

obit_dod
2019-12-23
2019-12-05 2019-03-11 2019-10-02 2018-11-04 2015-12-19
2016-09-28
2019-11-12 2019-09-04 2018-10-11 2019-11-26 2019-11-23 2019-10-11 2019-12-12
2019-07-22 2019-12-20 2016-02-10
2019-07-20 2018-12-06 2019-08-01
2018-12-28 2014-10-25
2019-12-19

Exhibit B, Page 280

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 281 of 352 Pageid#: 1184

voter_id 108004025 S 555453773 S 404012425 S
74752273 S 401006261 S 511027651 S 903007851 S 918309198 S 346603645 S 513027653 S 707024161 S
12934829 S 833228172 S 224001858 S 917040330 S 222022365 S 703008906 S 932833645 S 803009158 S 907007238 S
68962550 S 405004679 S 303007519 S 919182380 S 209010653 S 505010595 S 231003620 S 203009633 S 308009779 S 918378938 S 509029144 S 128018301 S 122017852 S

lname

fname DAVID CHARLES MARIE CASEY CHARLES DAVID LEONARD JULIA ELLEN ALVIN TEH BARBARA JOSEPH JUDY JOSEPH ROGER WAYNE ANNA SHEPHERD EARL NELSON NANCY JEANNE DILIP ELEANOR AUDREY ROBERT VIOLET JOHN JUDY CHARLES CLARENCE ROSALIE

dob 1944 1957 1952 1972 1939 1965 1930 1945 1916 1933 1929 1934 1953 1939 1942 1942 1930 1948 1945 1927 1941 1933 1942 1943 1926 1946 1944 1941 1953 1945 1932 1945 1940

date_registered 2006-10-10 2016-09-27 1976-10-02 2012-10-10 1983-09-13 2014-12-01 1977-08-25 1998-07-31 2019-09-20 1967-04-20 1976-05-08 2015-08-10 2015-09-24 1984-09-24 1994-06-21 2002-09-13 1987-09-29 2007-12-14 2000-09-14 1948-09-29 2009-09-08 1975-04-10 1986-11-26 2002-01-02 1965-10-02 1992-10-03 1995-04-26 1968-09-19 1987-05-02 1998-11-04 1993-03-23 1972-10-05 2001-08-24

ssdi_dod 2019-11-23 2019-11-12 2019-08-06 2019-06-27 2018-01-28 2018-01-22
2019-12-07 2015-02-02 2012-11-27 2018-01-18 2016-11-22
2019-11-19 2019-10-07 2017-12-18
2019-11-05
2019-12-12 2018-12-07
2016-10-16 2017-01-12 2017-09-09 2017-02-25
2019-10-18 2019-09-20

obit_dod 2019-11-23 2019-11-12 2019-08-06 2019-06-27 2018-01-28 2018-01-22 2019-09-06 2018-11-26 2019-12-07 2015-02-02 2012-11-27 2018-01-18
2018-12-18 2019-11-19
2017-12-18 2018-05-21 2019-03-03 2019-11-05 2019-09-25 2019-09-22
2018-12-07 2019-10-05
2017-09-09
2014-05-07 2019-11-17 2019-10-18

Exhibit B, Page 281

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 282 of 352 Pageid#: 1185

voter_id

lname

308018630 S

920408004 S

917194095 S

707015362 S

918882355 S

506009501 S

804005224 S

702004557 S

102022792 S

504021697 S

202007167 S

918606462 S

807007603 S

32110002 S

920396304 S

918028545 S

602031719 S

504010481 S

701015910 S

22276922 S

505032178 S

608003010 S

920340561 S

705006251 S

223010707 S

501010437 S

918815061 S

917720907 S

806000866 S

917939186 SI

409017504 SI

301034164 SI

233005205 SI

fname CYNTHIA LOUISE MONTEZE DEBRA JAMES SHARON BEATRICE EVA RICHARD DAVARD DANIEL MELVIN MARGARET REBECCA ROBERT HAJERA MILDRED RALPH JOSEPHINE ROBERT VICTOR RICHARD WILLIAM TINA JOANNE WILHITE SONIA ROBERT HAROLD ROBERT OLGA PATRICIA JAMES

dob 1946 1930 1934 1959 1946 1955 1934 1926 1938 1943 1940 1951 1946 1942 1927 1949 1934 1923 1931 1944 1942 1934 1966 1972 1945 1939 1971 1933 1927 1933 1930 1928 1949

date_registered 1986-04-05 2006-11-29 1996-04-11 2001-10-01 2000-09-13 2000-03-31 1968-09-30 1949-06-25 1976-09-28 1992-07-28 1987-10-02 1999-10-01 1988-09-20 2011-06-16 2006-11-08 1997-06-11 1959-04-21 1979-10-04 1955-10-04 2012-05-21 1991-10-04 1975-03-27 2006-08-15 2004-10-01 1972-09-14 1971-08-17 2000-06-19 1996-10-04 1987-03-16 1997-03-24 1991-01-03 1997-06-11 1992-10-03

ssdi_dod 2019-09-11 2019-08-04 2019-03-28 2018-12-28 2018-02-03 2017-12-14 2018-10-23
2018-08-15 2019-10-01 2017-12-06 2017-11-11 2014-11-11 2019-01-18 2018-12-29 2019-12-07 2019-11-29 2017-10-16 2019-08-30
2018-12-08 2018-11-05 2018-06-07 2019-11-23
2018-02-09 2015-12-12
2015-03-10 2019-10-28
2018-01-24

obit_dod 2019-09-11 2019-08-04 2019-03-28
2018-02-03
2018-10-23 2019-09-13 2018-08-15 2019-10-01
2019-01-18 2018-12-29
2019-11-29
2019-08-30 2019-09-11 2018-12-08 2018-11-05
2019-11-23 2019-04-03 2018-08-19
2015-12-12 2018-02-14 2015-03-10 2019-10-28 2018-08-24

Exhibit B, Page 282

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 283 of 352 Pageid#: 1186

voter_id

lname

918007512 SI

204008926 SI

405004264 SI

211018922 SI

919954678 SI

601004419 SI

222004361 SI

68810914 SI

533948980 SI

918966128 SI

806010758 SI

110813877 SI

10003849 SI

26004668 SI

603022091 SI

917351220 SI

208480511 SI

108023716 SI

401017229 SI

403025737 SI

602033852 SI

825412577 SI

919323319 SI

29010480 SI

807011372 SI

60289319 SI

703008059 SI

125011964 SI

69113272 SI

706022728 SI

706024960 SI

918615888 SI

808015220 SI

fname RICHARD LEONARD DORIS LORRAINE CHRISTOPHER FANNIE JULES RUSSELL PATRICIA ALFRED DOROTHY JEROME JAMES DORIS HARRIS EMMETT CLELLAN WALTER MIRIAM SHIRLEY MARY ELIZABETH REUBEN MICHAEL KEITH CAROLYN LORETTA MARY JEROME PATRICIA HARRY CANDLER A

dob 1931 1948 1931 1952 1974 1934 1919 1945 1971 1945 1921 1947 1938 1955 1932 1930 1937 1930 1928 1936 1927 1947 1917 1946 1931 1943 1936 1942 1955 1934 1929 1933 1927

date_registered 1997-05-15 1987-10-03 1986-10-03 2000-03-14 2004-10-02 1992-09-25 1984-10-06 2012-09-13 2018-10-05 2000-10-10 1945-01-30 2012-02-10 1998-08-06 1993-06-08 1964-09-10 1995-10-04 2012-02-08 1951-01-31 1956-10-06 1960-09-26 1949-06-23 2008-11-17 2002-05-13 1967-10-07 1960-10-08 2018-01-11 2001-05-14 1984-04-10 2012-09-27 2002-12-06 1998-09-18 1999-10-04 1963-11-29

ssdi_dod 2019-12-17 2019-12-29 2019-07-31 2018-01-28 2019-10-17 2018-12-20 2015-02-23 2019-10-13 2019-11-04 2020-01-29 2019-11-27 2019-11-23 2019-09-30 2019-09-06 2019-08-29 2019-08-10 2019-05-15 2019-01-12 2018-12-31 2018-12-21 2018-09-02 2018-08-29 2018-01-21 2018-01-10 2017-01-09
2019-08-28 2018-07-30 2018-06-01
2015-08-28 2019-12-29

obit_dod 2019-12-17
2019-07-31
2019-10-17 2018-12-20
2019-10-13 2019-11-04
2019-11-23 2019-09-30
2019-08-29 2019-08-10 2019-05-15 2019-01-12
2018-09-02 2018-08-29 2018-01-21
2017-01-09 2018-12-11 2017-03-24 2019-08-29 2018-07-30
2015-05-03
2019-12-29

Exhibit B, Page 283

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 284 of 352 Pageid#: 1187

voter_id

lname

784365 SI

406016728 SI

301035750 SI

918855289 SI

918764991 SI

60596985 SI

917679246 SI

917304433 SI

501026919 SI

502015580 SI

919660588 SI

918047368 SI

917061217 SI

222009772 SI

28004386 SI

977398855 SI

801004489 SI

2007678 SI

432156129 SI

604004032 SI

484132481 SI

231011893 SI

10197708 SI

202017643 SI

157431100 SI

918585981 SI

918011233 SI

802004757 SI

920247211 SI

907023656 SI

906008071 SI

918480050 SI

21386143 SI

fname DAVID DONALD BARBARA TERRY RICHARD DALE RICHARD BONITA BRENDA VILAI MARGARET LEWIS ROBERT THELMA MARY AARON JASPER FRED HAZEL LILLIE MARCUS YVETTE AUDREY ROSALIE DAVID KULDIP JAI MOSES EDWARD LAWRENCE IRVIN WINSTON JAMES

dob 1955 1941 1932 1953 1968 1930 1939 1964 1966 1936 1932 1965 1947 1936 1929 1985 1936 1927 1940 1952 1957 1948 1938 1923 1947 1958 1956 1937 1942 1946 1946 1940 1951

date_registered 2010-03-31 1982-10-02 1985-01-31 2000-08-21 2000-05-03 2015-11-10 1996-09-23 1995-07-31 2004-03-03 2003-02-12 2009-03-24 1997-07-23 1998-09-03 1992-09-05 1952-07-28 2008-04-07 1964-01-22 1992-10-01 2012-10-11 1983-10-07 2008-09-16 1998-06-01 2010-11-03 1984-09-05 2011-09-29 1999-09-09 1997-06-11 1984-10-05 2006-02-03 1993-03-22 1992-05-29 1999-04-14 2014-06-23

ssdi_dod 2017-01-03 2019-12-11 2019-12-03 2019-11-13 2019-11-13 2019-10-18 2019-10-16 2019-09-05 2019-07-05 2019-06-08 2019-05-30 2019-04-23 2018-12-27 2018-12-19 2018-12-10 2017-02-10
2020-01-20 2019-12-24 2018-12-22 2017-10-12
2019-10-13 2017-12-12 2019-11-23 2018-03-07 2019-10-06 2016-09-04
2019-11-19 2019-01-17

obit_dod
2019-11-13 2019-11-13 2019-10-18 2019-10-16 2019-09-05 2019-07-05
2019-04-23 2018-12-27 2018-12-19
2019-09-24
2019-12-24 2018-12-22 2017-10-12 2019-05-30 2017-10-21 2019-10-13 2017-12-20 2019-11-23
2019-10-06
2019-08-23 2019-11-08
2019-01-17

Exhibit B, Page 284

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 285 of 352 Pageid#: 1188

voter_id

lname

919562126 SI

918145554 SI

808011773 SI

200445323 SI

917973169 SI

918430448 SI

508023425 SI

920191414 SI

513025994 SI

918390564 SI

204016380 SI

23009035 S

601024903 S

5001101 S

920097840 S

106018952 S

26000229 S

919549599 S

122052862 S

918610630 S

19691050 S

5000889 S

918138649 S

413018859 S

917673489 S

917510287 S

917387238 S

7001102 S

306007208 S

709015771 S

226005207 S

306000227 S

801008249 S

fname BRENT SUSAN WILBUR VIOLET JAMES GEORGE NELLIE ARLENA ROBERT JEFFREY LILY BETTEMAE BOYD DWIGHT ENGLISH ROGER ALFRED RUBYE JAMES FRANK SHIRLEY CAROLYN DEAN SANDERS COY RALPH DONALD SHERRIN MARY LOU GENEVA DIANA CONNIE MICHAEL

dob 1964 1935 1933 1934 1935 1947 1935 1933 1926 1958 1935 1926 1927 1945 1921 1928 1934 1936 1939 1951 1933 1943 1938 1940 1936 1946 1936 1937 1926 1927 1929 1931 1949

date_registered 2003-07-28 1997-11-05 1954-11-08 2015-06-30 1997-04-07 1999-02-08 1975-03-25 2005-10-04 1989-10-06 1998-11-25 1997-04-28 1980-02-21 1955-10-05 1972-08-31 2005-05-06 2005-06-24 1967-06-01 2006-03-20 2014-01-21 1999-10-04 2008-08-22 1965-05-03 1997-11-05 1989-03-02 1996-09-17 1996-06-12 1996-01-10 1960-10-08 1981-07-22 1971-08-30 1995-10-09 1988-03-16 2002-11-14

ssdi_dod 2018-04-21
2018-03-18 2015-08-08
2019-04-21 2018-12-24 2018-01-07 2018-12-03 2018-12-12 2019-08-08 2019-01-09
2016-05-02 2019-12-18
2019-10-22 2019-05-03 2019-09-12
2018-12-26 2018-12-14
2020-01-06 2014-10-15 2019-11-04 2014-10-09 2017-11-20
2019-11-25

obit_dod 2018-04-21 2019-09-27 2019-09-06
2015-03-15 2019-04-21 2018-12-24 2018-01-07
2018-12-12
2019-01-09 2019-10-18 2016-05-02
2019-08-10 2019-08-08 2019-10-22 2019-05-03
2019-10-26 2018-12-26
2018-12-22
2014-10-15 2019-11-03 2014-10-09
2015-02-13 2019-09-02 2019-11-25

Exhibit B, Page 285

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 286 of 352 Pageid#: 1189

voter_id 105494208 S 125013629 S 917639084 S 208001490 S 204001105 S 918871506 S 401031947 S 431466018 S 607028386 S 920125255 S 701029628 S 405024638 S
77741269 S 919847107 S 907017605 S 906001145 S 920073154 S 101021266 S 124019169 S 805001421 S 917443965 S 917425601 S 610002499 S 894830339 S 909006944 S 707014023 S 102003629 S 602028790 S 917151826 S 402021289 S 125002978 S 904011779 S 103023889 S

lname

fname BERTINA NORMAN MELISSA PLENNIE ALICE FRANKLIN RICHARD DONALD SHARON CHARLES JANET RICHARD NEVRESA FRANK RITA GARY ANN BERRY MABLE KYLE MANDY CHARLES HOWARD PATRICIA ERNEST BETTY FAYE ANN EDGAR PRESTON LINDA KATHERINE JOHN BOYD

dob 1934 1944 1964 1936 1937 1935 1966 1955 1965 1947 1937 1945 1956 1932 1939 1945 1919 1948 1934 1941 1978 1953 1925 1929 1939 1938 1931 1945 1942 1943 1917 1938 1947

date_registered 2012-09-11 1995-09-25 1996-09-09 2003-08-06 1966-10-03 2000-08-31 1996-10-07 2016-05-19 1984-10-04 2005-06-30 1992-03-19 1991-11-06 2017-01-18 2004-08-20 1999-02-01 1986-09-25 2005-03-10 1999-11-08 1998-05-12 1967-10-02 1996-03-27 1997-03-27 1992-11-19 2008-09-09 1980-10-03 1960-09-22 1968-10-02 1967-02-28 1994-09-01 1984-09-24 1955-10-06 1966-10-08 2000-04-21

ssdi_dod 2018-03-30 2020-01-29 2018-12-05 2017-09-19
2020-01-24 2018-12-19 2018-01-19 2019-09-20 2016-12-02 2016-09-19 2020-01-06 2018-08-01 2015-01-10 2019-11-05 2018-12-20 2018-10-27 2019-11-21
2019-08-02 2014-11-26
2020-01-25 2020-01-24 2020-01-14 2020-01-10 2020-01-02 2020-01-02 2019-12-27 2019-12-25 2019-12-23

obit_dod 2018-03-30
2018-12-05 2017-09-19 2018-07-12
2018-12-19 2018-01-19 2019-09-20
2016-09-19
2019-11-05
2019-11-21 2019-10-22 2018-01-06 2019-08-02 2014-11-26 2019-08-29 2019-10-05
2019-12-27 2019-12-25 2019-12-23

Exhibit B, Page 286

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 287 of 352 Pageid#: 1190

voter_id 802016175 S 124020335 S
9004666 S 25002924 S 918530273 S 407003242 S 271792703 S 754992710 S 427343215 S 171362966 S 705019624 S 919687848 S 32379241 S 831414914 S 409011981 S 400690824 S 791320773 S 894950409 S 31019839 S 707024170 S 502029358 S 402013138 S 604021948 S 22018004 S 734487071 S 183341023 S 304025531 S 306048678 S 808008066 S 920170671 S 806008064 S 126011315 S 335906798 S

lname

fname DOROTHY RAY WILLIE LOUISE ALFORD LOUISE HUBERT AMANDA MARIE REBECCA JUDITH JAMES LYNDA WELDON WILMA SIDNEY CLEVE FLORENCE JOHN JAMES JOHN ROBERT BETTY AUDREY ALFRED BEVERLY MAXINE JUDITH ROSA LOU GLADYS WILSON LUCIOUS

dob 1928 1941 1942 1929 1938 1944 1941 1945 1933 1957 1941 1940 1943 1959 1926 1940 1938 1947 1944 1948 1935 1933 1934 1942 1950 1957 1923 1943 1924 1927 1929 1946 1978

date_registered 1967-11-07 1975-05-09 2000-11-22 1987-12-10 1999-06-28 1976-10-02 2013-01-04 2008-10-06 2008-10-01 2012-09-04 1963-06-08 2004-02-19 2019-04-19 2009-04-17 1955-10-05 2008-02-13 2008-08-06 2007-03-01 1990-11-13 1980-10-01 1956-10-06 1955-12-20 1983-09-29 1963-12-04 2008-10-02 2016-10-21 1980-09-20 2005-06-15 1964-10-03 2005-09-13 1972-10-05 2008-01-14 2013-08-15

ssdi_dod 2019-12-21 2019-12-18 2019-12-16 2019-12-09 2019-12-05 2019-12-05 2019-12-03 2019-11-30 2019-11-27 2019-11-27 2019-11-21 2019-11-19 2019-11-19 2019-11-16 2019-11-14 2019-11-08 2019-11-05 2019-11-02 2019-10-29 2019-10-26 2019-10-25 2019-10-23 2019-10-21 2019-10-20 2019-10-19 2019-10-15 2019-10-14 2019-10-12 2019-10-10 2019-10-06 2019-09-30 2019-09-29 2019-09-29

obit_dod 2019-12-21 2019-12-18 2019-12-16 2019-12-09 2019-12-05 2019-12-05 2019-12-03 2019-11-30 2019-11-27 2019-11-27 2019-11-21 2019-11-19 2019-11-19
2019-11-05
2019-10-29 2019-10-26 2019-10-25 2019-10-23
2019-10-20 2019-10-19 2019-10-15 2019-10-14 2019-10-12 2019-10-10 2019-10-06 2019-09-30 2019-09-30 2019-09-29

Exhibit B, Page 287

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 288 of 352 Pageid#: 1191

voter_id 905016970 S 708011247 S 709011622 S 207015001 S 918358360 S
28011806 S 918772974 S 107005850 S 450824037 S 501025315 S 918367727 S 708013600 S 420474946 S 906016382 S 406005783 S 702015775 S 918107134 S 138291666 S 290632965 S 917533597 S 505010437 S 182081816 S 182304419 S 572416225 S 704011245 S 603028978 S 508002745 S 100964412 S 375740320 S 502020113 S 919792466 S 917725899 S 906019923 S

lname

fname DONALD PANSY MARY CHARLES ALFRED RUTH FRANK AARON JAMES ALMA CHARLES ROBERT WILLIAM DORA SUSAN CAYNOR ANGELA DOROTHY DEJAUN MICHAEL GERALD LINDA JOANN CHARLIE BERKLEY PHILLIP DORETHA CHRISTINA RICKIE JOYCE FLORA HELEN LEON

dob 1939 1939 1932 1931 1928 1930 1927 1941 1933 1929 1940 1957 1939 1939 1943 1934 1974 1926 1981 1951 1948 1961 1948 1947 1947 1955 1931 1976 1950 1941 1917 1931 1934

date_registered 1983-09-10 1983-04-29 1956-04-16 1953-12-21 2001-09-04 1990-12-06 2006-08-22 1967-09-29 2012-10-15 1987-05-20 1998-10-05 1976-09-28 2015-07-21 2005-04-22 1984-03-27 1956-06-01 1997-09-24 2016-09-12 2016-09-21 1996-06-20 1984-09-06 2012-09-30 2016-09-23 2008-08-19 1985-11-06 2000-02-15 1992-01-02 2018-09-12 2008-09-23 1999-08-11 2004-06-25 1996-09-30 1984-09-11

ssdi_dod 2019-09-29 2019-09-25 2019-09-24 2019-09-04 2019-09-01 2019-09-01 2019-08-31 2019-08-30 2019-08-28 2019-08-26 2019-08-22 2019-08-15 2019-08-08 2019-08-06 2019-06-10 2019-05-24 2019-04-30 2019-04-16 2019-04-15 2019-04-10 2019-04-09 2019-03-31 2019-03-24 2019-02-18 2019-02-17 2019-02-09 2019-01-14 2018-12-31 2018-12-29 2018-12-25 2018-12-22 2018-12-17 2018-12-10

obit_dod
2019-09-25
2019-09-04 2019-09-01
2019-08-31 2019-08-30 2019-08-28 2019-08-26 2019-08-22
2019-08-08 2019-08-06 2019-06-10
2019-04-30 2019-04-16 2019-04-15 2019-04-10 2019-04-09
2019-03-24 2019-02-18 2019-02-17 2019-02-09
2018-12-25 2018-12-22 2018-12-17 2018-12-10

Exhibit B, Page 288

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 289 of 352 Pageid#: 1192

voter_id 105003823 S 917706166 S 508005766 S
30011181 S 958126925 S 125010988 S 607028791 S 917533691 S 918129880 S 309552236 S 706012244 S 919356015 S 803002099 S 917370121 S 309014673 S 903017490 S 506011231 S 707012668 S 508015773 S 392036170 S 602024906 S 532260757 S 241053939 S 920175849 S 106005771 S 454156928 S 905003927 S 704021263 S 918485958 S 703005531 S 816478889 S 808011681 S 919730268 S

lname

fname EARL BETTY MARTHA CAROL MAGGIE ANGELO LINDA CHRISTOPHER OVELLA ALEX JUNE JOSEPH LLOYD JEFFREY WALTER ESTERINE WALTER MARTHA ROBERT HAROLD STEVAN CHARLES JOHN WILLIAM ELMO LAURANCE MARY EARLINE ALMA THOMAS LAURENCE HELEN MELANIE

dob 1939 1934 1940 1948 1941 1972 1943 1944 1928 1964 1930 1939 1932 1973 1939 1929 1936 1938 1938 1942 1958 1934 1939 1987 1924 1943 1946 1938 1934 1922 1942 1941 1970

date_registered 1977-10-08 1996-09-30 1965-09-17 2000-06-01 2008-08-14 2002-08-14 1964-08-17 1996-06-19 1997-11-05 2016-11-14 1984-09-14 2002-07-10 1956-07-11 1998-05-21 1995-07-05 1979-10-06 2006-09-21 1966-01-01 1984-10-03 2010-10-12 1993-03-17 2012-10-15 2016-10-21 2005-09-21 1990-11-07 2012-08-21 1969-06-13 1998-10-05 2004-03-29 1991-10-04 2008-10-06 1981-09-30 2004-04-05

ssdi_dod 2018-12-10 2018-12-04 2018-12-02 2018-11-23 2018-10-25 2018-10-22 2018-09-26 2018-08-25 2018-08-12 2018-08-01 2018-07-21 2018-07-01 2018-06-25 2018-05-31 2018-05-25 2018-05-12 2018-04-06 2018-03-19 2018-02-22 2018-01-01 2017-12-12 2017-12-10 2017-11-16 2017-01-26 2017-01-15 2016-11-29 2016-10-02 2015-11-21 2015-11-17 2015-11-16 2015-10-05 2015-06-22 2014-10-13

obit_dod 2018-12-04 2018-11-23
2018-08-25 2018-08-12 2018-07-21 2018-07-01 2018-06-25
2018-04-06 2018-03-19
2017-12-12 2017-12-10 2017-11-16 2017-01-26 2017-01-15 2016-11-29
2015-11-18
2015-06-22

Exhibit B, Page 289

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 290 of 352 Pageid#: 1193

voter_id 506014327 S 882777009 S 124015596 S 918292023 S 402023565 S 204001237 S 395368527 S 601027732 S 805010044 S 918054802 S 801009824 S
22015973 S 27434442 S 407009366 S 208023769 S 402008805 S 403007855 S 26018004 S 706002696 S 222011083 S 901005409 S 97651076 S 86602005 S 307001968 S 917370204 S
7139565 S 230023795 S 413015675 S 507013105 S 919509736 S 705012503 S 202001493 S 905002057 S

lname

fname JOEL MURIEL STANLEY DOROTHY MARTHA GEORGIA MARY BILLY HELEN MARTHA CARRIE RANDOLPH PATRICA GOLDIE DONNA JESSE FRANCES CAROLYN JEWEL JACK JAMES BERNARD HARRY JAMES JUNIOUS ALFRED GEORGE JOHN DORIS DONALD JAMES FLORENCE HATTIE

dob 1940 1939 1924 1929 1949 1916 1941 1941 1929 1921 1939 1924 1944 1940 1943 1936 1925 1945 1944 1928 1943 1935 1929 1930 1939 1931 1948 1923 1930 1948 1936 1942 1927

date_registered 1992-04-17 2007-10-04 1976-01-01 1998-06-25 1982-09-28 1951-10-04 2019-09-09 1963-10-05 1980-01-09 2000-04-26 1987-06-10 1964-10-03 2014-11-21 1992-10-01 1975-04-11 1987-09-23 1980-03-11 1980-04-04 1980-10-03 1950-06-12 1985-09-18 2012-03-13 2016-08-19 1974-09-26 2000-01-12 2004-10-02 1987-10-03 1991-12-05 1997-02-06 2003-04-29 1996-11-06 1966-10-08 1992-03-23

ssdi_dod 2014-07-03 2014-01-13 2012-08-02 2012-06-04 2010-08-09 2010-04-07 2008-06-18 2006-12-16 2004-05-06 2001-08-16 1999-01-17 1990-02-23

obit_dod
2012-08-02 2012-06-04
2006-12-16 2004-05-06 2001-08-16
2019-10-28 2019-10-26 2019-10-20 2019-10-07 2019-09-09 2019-09-01 2019-08-30 2019-08-24 2019-08-21 2019-08-09 2019-08-08 2019-07-20 2019-05-27 2019-05-09 2018-12-28 2018-12-16 2018-12-14 2018-10-24 2018-06-17 2018-03-26 2018-02-16

Exhibit B, Page 290

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 291 of 352 Pageid#: 1194

voter_id 919652118 S 207001492 S 405004164 S 918355244 S 405017512 S
9420471 S 918569864 S 905008264 S 906008264 S 227018968 S 919948867 S 703008719 S 506010049 S 290545328 S 207008267 S 918169264 S 704000071 S 427761950 S
74440384 S 605026927 S 903010260 S 205023037 S 920347291 S 107026974 S 307029775 S 708002462 S 702003480 S 206022591 S 104004927 S 304050342 S 803014955 S 122005800 S
27007974 S

lname

fname THOMAS DORSEY REX LOUISE CHARLES GRANVILLE ESTELLE JANET WILSON NOTON RHYNNEE NANCY DEWEY MARTHA ALENE MARVIN ROLAND JULIE DELORES SHELBY KATHLEEN EILEEN STEPHEN GORDON ALBERT KENNETH JOHN WILBERT DAVID JERRY JAMES BARBARA EDWIN

dob 1946 1936 1937 1923 1934 1948 1911 1944 1942 1925 1964 1939 1943 1928 1949 1942 1933 1973 1935 1937 1920 1927 1942 1941 1922 1952 1926 1946 1933 1934 1933 1925 1924

date_registered 2003-12-19 1980-09-13 1993-06-08 1998-09-30 1979-11-09 2016-10-17 1999-08-24 1996-08-27 1996-08-27 1953-06-03 2004-10-04 1979-10-03 1966-04-06 2014-07-31 1982-08-10 1997-12-30 2006-08-08 2014-08-27 2008-06-12 1959-04-04 2005-09-01 1964-05-02 2006-08-28 1980-09-29 1976-06-18 1981-10-03 1951-07-02 1967-10-07 1998-06-15 1988-08-22 1963-08-05 1952-09-26 1956-10-04

ssdi_dod
2020-01-13 2020-01-12 2002-10-26 2019-10-29 2019-09-10 2019-03-28 2019-11-03 2019-12-27 2018-12-26
2014-12-07 2020-01-12 2020-01-10 2019-07-23 2019-07-15 2019-03-25 2018-01-23
2019-10-09 2018-12-15 2019-09-26
2016-12-19
2019-10-23 2019-04-23 2019-11-27

obit_dod 2018-02-16 2017-09-15 2015-12-14 2014-11-14
2019-10-29 2019-09-10 2019-03-28 2019-11-03
2018-12-26 2019-03-01 2014-12-07
2018-12-18 2019-03-25 2018-01-23 2018-07-01 2019-09-18 2019-10-09 2018-12-15
2019-10-21 2016-12-19 2016-11-13 2013-07-28 2019-10-23 2019-04-23

Exhibit B, Page 291

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 292 of 352 Pageid#: 1195

voter_id 803010769 S 919890156 S 308028225 S
42511272 S 106023151 S 103021674 S 706003224 S 302025970 S 508002160 S 918935661 S 920041558 S 203020573 S
68757059 S 810009162 S 919656242 S 918012852 S 918676056 S 205021471 S 920063448 S 191692947 S 350815626 S
23011558 S 100586434 S 911007250 S 801008252 S 223008029 S 303035181 S 920037761 S
50874477 S 225006228 S 917220367 S 918855198 S 808012663 S

lname

fname ROBERT JIMMY FRANK MARY KENNETH LESLIE FRANCIS KATHRYN FRANKLIN GEORGIA MARYHELEN PATRICK CLAUDIA EDWARD ESSAMELDIN MAXIMINO EDGAR DONALD MAHDI TAHEREH SHEILA SIGFRIED HELEN DONALD GLORIA BRUCE DAVE EMILY THOMAS CHESTER FELICITO ELEANOR ANNE

dob 1943 1941 1926 1946 1928 1960 1940 1921 1927 1931 1932 1955 1954 1937 1949 1941 1940 1935 1931 1922 1938 1948 1928 1939 1951 1950 1926 1948 1932 1940 1945 1930 1929

date_registered 1987-09-29 2004-09-16 2001-06-13 2016-10-07 1974-01-30 1996-05-07 1975-09-03 1971-08-12 1976-09-28 2000-10-09 2005-01-06 1995-08-24 2014-01-28 1989-10-04 2003-12-30 1997-06-11 2000-01-27 1984-09-08 2005-02-28 2015-06-18 2015-10-13 1984-03-16 2009-11-25 1992-09-25 1976-09-08 1994-09-19 1985-12-28 2004-12-22 2018-08-14 1966-09-30 2009-04-28 2000-07-26 1978-09-29

ssdi_dod 2018-12-20 2018-12-05
2020-01-08 2019-11-23 2019-10-16 2019-08-19 2019-03-26 2018-07-28 2018-01-28 2019-12-03 2019-08-01 2018-12-18 2019-12-30
2019-04-01 2018-12-16 2017-02-28 2017-09-08
2019-12-16 2018-12-15 2015-11-29 2018-12-08 2016-07-06 2018-11-02
2019-12-19 2019-08-14 2018-12-21 2020-01-09 2019-08-18

obit_dod 2018-12-20 2018-12-05 2019-08-30 2018-02-21
2019-10-16 2019-08-19
2018-12-18 2019-03-07
2019-10-18 2019-12-16 2018-12-15 2015-11-29 2018-12-08 2016-07-06 2019-09-25 2019-08-14
2019-08-18

Exhibit B, Page 292

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 293 of 352 Pageid#: 1196

voter_id 917010197 S 918387982 S 268520670 S 225021527 S 919015327 S 364456743 S 297026116 S 704019368 S 809011467 S 404003244 S 918548100 S 303021571 S 920401380 S 405005246 S 206009481 S 908022988 S 604002922 S 918969689 S 405000856 S 906000260 S 920238632 S 918889613 S 407010480 S 142913713 S 918006762 S 308015652 S 801015229 S 919012339 S 401013013 S 919790592 S 513012638 S 918822939 S 850874523 S

lname

fname LAWRENCE JULIA JOHN LORINE PHETSANOU DAVID AUBREY BETTY DOROTHY HENRY RICHARD VAN KATHLEEN EDITH DELMAS EMMA MARY BARBARA THERESA NANCY VIRGINIA DAVID SHAWNA GREGORY LAMAE JOSEPH BERTHA ISA WILLIAM ELEANOR CAROLYN NANCY ERNEST

dob 1928 1923 1943 1926 1968 1947 1936 1939 1942 1939 1944 1949 1928 1935 1953 1943 1946 1942 1944 1936 1936 1930 1951 1960 1945 1927 1920 1925 1931 1934 1947 1925 1934

date_registered 1996-09-23 1998-11-04 2019-04-24 1983-03-08 2000-12-18 2012-09-19 2008-09-24 1984-09-26 2000-10-02 1971-09-03 1999-07-26 1980-09-27 2006-11-20 1963-05-01 1971-10-02 1984-09-08 1983-06-30 2000-10-10 1975-05-01 1968-09-18 2006-01-12 2000-09-18 1992-10-02 2014-08-25 1997-05-12 1957-01-11 1973-08-28 2000-12-18 1962-04-07 2005-03-18 1973-03-28 2000-07-14 2008-02-27

ssdi_dod 2014-11-24 2018-11-20
2020-01-23 2016-07-28 2019-12-21 2018-02-27 2019-10-12 2016-10-02 2019-12-13
2019-09-08 2018-12-16 2018-12-07 2014-01-16 2017-06-27
2018-12-16 2019-11-09 2017-11-27 2019-10-10 2019-08-12 2016-09-09 2016-04-15
2020-01-20 2016-08-05 2009-11-16 2019-12-13 2017-06-13 2019-10-13 2019-05-22

obit_dod
2019-09-22
2019-10-12 2016-10-02 2019-11-16 2019-07-23 2019-09-08 2018-12-16 2018-12-07 2014-01-16 2017-06-27 2019-06-09
2017-11-27 2019-08-12 2016-09-09 2016-04-15 2019-09-23
2019-12-13 2019-10-13

Exhibit B, Page 293

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 294 of 352 Pageid#: 1197

voter_id 411017786 S 908004265 S 918631707 S 907011935 S 917506897 S 296531500 S 137841185 S 918451759 S 413004607 S 918862608 S 918410083 S 907009736 S 447783683 S 306279672 S
24013393 S 36400254 S 212024449 S 903010034 S 123014489 S 268720288 S 917209220 S 919117407 S 207023918 S 345023870 S 918723842 S 918301141 S 302001347 S 607033612 S 356854098 S 245639027 S 864695484 S 448789150 S 301024909 S

lname

fname THELMA THEODORE WILLARD CHARLES SHERRY COURTNEY MAUDE JAMES DON MONTY ANNE ROSELDA WARREN EDWARD IRENE JUANITA HARVEY STEWART LOUISE MIKE LYNN ELIZABETH WESTLEY MELONIE ARTHUR ELMER JAMES JUNE MARY CALVIN JUANITA HAROLD DORIS

dob 1920 1930 1929 1926 1924 1979 1924 1939 1940 1950 1932 1946 1951 1948 1931 1948 1923 1935 1919 1935 1942 1936 1935 1984 1945 1930 1928 1926 1927 1927 1947 1936 1929

date_registered 1993-08-30 1978-09-15 2001-11-07 1971-06-17 1996-05-13 2016-10-20 2008-10-06 1999-03-08 1993-04-01 2000-08-28 1999-01-08 1998-12-02 2008-09-23 2017-02-24 1960-07-01 2010-10-06 2000-04-03 1964-08-30 1960-10-05 2016-10-15 1994-10-08 2001-06-14 1974-10-05 2016-12-06 2000-02-15 1998-07-20 1977-02-24 1972-03-09 2008-08-28 2008-08-22 2008-02-13 2015-10-06 2005-11-17

ssdi_dod 2018-12-01 2019-09-10 2019-05-25
2014-04-22 2018-07-08 2015-09-10 2019-12-10 2019-10-16 2019-08-08 2019-06-27 2018-12-17 2014-10-22
2019-11-30 2014-04-06 2019-08-18 2019-08-04 2019-10-18
2015-03-22 2019-09-06 2019-11-13 2019-01-23 2019-09-20 2019-11-05 2019-10-15 2019-01-29 2010-02-18
2018-08-27 2018-01-09

obit_dod 2018-12-01 2019-09-10
2018-12-27
2018-07-08
2019-12-10 2019-10-16 2019-08-01 2019-06-27
2019-10-09 2018-12-30
2014-04-06 2019-08-18
2019-10-18 2018-02-23 2015-03-22 2019-09-06
2019-01-23
2019-11-05 2019-10-15 2019-01-29 2010-02-18 2018-12-10 2018-08-27 2018-01-09

Exhibit B, Page 294

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 295 of 352 Pageid#: 1198

voter_id 121005613 S 471891671 S 509004069 S 206020985 S
22018448 S 535035197 S 917742234 S 906007538 S 709011999 S 903000805 S 508015264 S 171582515 S 407022952 S 801018886 S 228019848 S 122008222 S 404022038 S 917488103 S 121011824 S 917812550 S 483877724 S 705012842 S 702000894 S 920379567 S 709020863 S 605017730 S 447570182 S 302034034 S 918016015 S 902016976 S 702030070 S 919443745 S
75242150 S

lname

fname JOHN VIOLET GENE EVANGELINE LINWOOD BILLY EDWARD LLOYD BETTY JEAN JULIA JOHN EDDIE EARLENE JOHN DENNIS JAMES LUCETTA EDNA CLAUDINE WILLIAM GEORGE ARLENE BETTY MEREDITH SIDNEY CARLOS KATHERINE JOYCE PAUL SELDON MICHAEL TONY

dob 1947 1930 1933 1927 1939 1955 1938 1939 1928 1927 1955 1946 1933 1939 1945 1946 1936 1918 1932 1943 1943 1936 1930 1939 1941 1937 1939 1914 1937 1946 1934 1984 1958

date_registered 2003-10-01 2007-09-26 1956-04-06 1972-10-07 1968-05-10 2010-01-23 1996-10-07 2002-10-05 1971-06-24 1949-07-02 1980-10-04 2009-07-20 1996-09-26 1996-02-27 2000-10-02 1989-11-15 1974-09-28 1996-05-08 1953-01-20 1996-11-05 2013-01-25 1984-10-02 1991-01-09 2006-10-10 1991-04-04 2003-07-14 2007-05-16 1989-10-02 1997-06-11 1980-09-18 1992-07-16 2002-12-09 2012-09-20

ssdi_dod 2018-01-30 2019-05-20 2019-11-21 2019-10-10
2019-09-01 2019-10-09 2019-09-26 2019-10-19 2019-11-18 2019-10-01 2018-09-20
2019-10-21
2019-12-07 2019-11-28 2019-10-14
2020-01-13
2019-12-21 2019-10-12 2019-09-21 2019-07-26 2019-11-13 2018-12-12 2020-01-21 2019-06-21 2018-09-19 2017-06-29

obit_dod
2019-05-20 2019-11-21
2019-08-05 2019-09-01 2019-10-09 2019-09-26 2019-10-19 2019-11-18 2019-10-01
2019-10-05 2019-08-02 2019-10-21 2019-07-24
2019-11-28 2019-10-14 2019-08-15 2019-05-16
2014-03-24
2019-10-12
2019-07-26 2019-11-13 2018-12-12
2019-06-22 2018-09-20

Exhibit B, Page 295

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 296 of 352 Pageid#: 1199

voter_id 213925351 S 919369252 S 121012317 S 227012430 S 903009085 S 121973731 S 495956447 S 111006156 S 206004180 S 708014034 S 601028145 S
24106146 S 908019285 S 758041690 S 908004267 S
28006760 S 903011220 S 917341116 S 703010641 S 605039287 S 306008436 S
11263835 S 215024638 S 907009405 S 227000191 S 917282999 S 919703271 S 202024642 S 201025614 S 605028259 S 703011057 S 105019232 S 406015682 S

lname

fname PAMELA LINDA BETTY MARTIN JAMES CHARLES ALSON MARILYN DORA WILLARD CHARLES JACQUELINE HAILOVES MARIA JACQUELYN CHARLOTTE ANTONY JIMMIE HAROLD WILLIE PATRICIA YURI ARTHUR JUNE LLOYD JOSEPH WILLIAM JETTIE JAMES BETTY J ROGER ELLEN

dob 1946 1958 1931 1936 1932 1935 1930 1927 1930 1940 1925 1947 1923 1955 1937 1931 1964 1930 1933 1948 1932 1933 1943 1941 1924 1935 1946 1925 1929 1941 1919 1947 1949

date_registered 2016-08-22 2002-07-30 1984-03-19 1986-09-13 1976-03-30 2017-09-07 2014-06-03 1989-10-03 1976-09-11 1980-11-26 1991-10-04 2007-05-11 1976-05-07 2008-07-31 1968-10-05 1952-09-30 1984-09-18 1995-09-27 1987-06-01 1973-09-25 1963-05-04 2013-12-17 1991-07-02 1984-08-25 1968-10-05 1995-05-09 2004-03-04 1946-06-04 1952-10-04 1968-09-26 1940-08-03 1978-04-12 1975-04-08

ssdi_dod 2017-12-04 2018-01-27
2019-10-16 2019-12-11 2019-12-19 2018-06-12 2016-12-20 2019-10-10 2019-10-10 2016-11-27 2020-01-20 2020-01-13
2019-12-24
2018-12-25 2013-09-03 2019-11-21
2019-11-17 2020-01-12 2019-12-11 2019-10-16 2019-08-03 2019-06-13 2019-05-12 2018-04-17 2016-11-27 1996-05-01

obit_dod
2018-06-01 2019-10-16 2019-12-11 2019-12-19
2016-12-20 2019-10-10
2016-11-27
2019-10-06
2019-08-29
2019-11-21 2019-10-12 2019-08-04 2019-11-17
2019-12-11 2019-10-16
2019-06-13 2019-05-12 2018-04-17 2016-11-27
2019-08-16 2018-12-22

Exhibit B, Page 296

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 297 of 352 Pageid#: 1200

voter_id 917870920 S 307014675 S 202003129 S 903010900 S 918470652 S 918345940 S 504010317 S 503009697 S 917909635 S
39159172 S 14447773 S 605029041 S 605028979 S 920212499 S 601028567 S 542528642 S
5001909 S 804810225 S 306038302 S 918738667 S 920258673 S 431033816 S 609029529 S 304018431 S 919061741 S 919373841 S 223011432 S 822358718 S 411027810 S 920359176 S 701024709 S 706004426 S 374800177 S

lname

fname BENJAMIN KATHERINE JOE KEITH MARY WINSTON JUDY LINDA PATTON DORA YVONNE MILTON THELMA IDA BETTY JERRY DORIS KAREN THOMAS ALLEN ANTOINETTE LYNN WILLIAM MARIA-THERESIA DAVID CHARLES MARILYN MIRIAM JUDITH MARY DAVID LOUIS THEODORE

dob 1946 1939 1917 1972 1924 1924 1957 1947 1927 1937 1959 1952 1931 1936 1930 1934 1919 1961 1939 1940 1943 1948 1930 1925 1926 1939 1931 1925 1946 1921 1944 1941 1946

date_registered 1997-01-16 2006-11-08 1970-04-27 1990-03-01 1999-04-05 1998-09-24 1975-08-01 1982-09-16 1997-02-26 2017-03-23 2016-08-16 1971-09-04 1959-09-29 2005-10-24 1990-03-09 2017-11-15 1951-04-28 2008-09-17 1964-10-03 2000-03-06 2006-03-02 2010-07-29 1988-07-15 2004-05-05 2003-04-09 2002-08-13 1968-10-04 2016-10-13 1988-09-17 2006-09-14 1968-09-26 1986-04-29 2008-08-14

ssdi_dod
2019-10-28 2005-01-03 2019-09-22
2018-11-12 2014-10-25 2014-09-08 2019-10-08 2018-05-30 2018-10-14 2018-03-02 2018-02-26 2016-07-24
2019-08-28 2018-09-01 2020-01-20
2019-11-05 2019-11-20 2018-06-03 2019-12-09 2018-12-07 2019-12-04 2018-06-04
2019-11-24 2018-12-15 2019-11-11
2019-06-05

obit_dod 2018-12-06 2019-10-28 2005-01-03 2019-09-22 2019-10-04 2013-06-15 2018-11-12
2019-10-08 2018-05-30
2018-03-02
2016-07-24 2019-08-25 2019-08-28 2018-09-01
2019-09-06
2019-11-20 2018-06-03
2018-12-07 2019-12-04 2018-06-04 2019-04-15 2019-11-24
2019-11-11 2016-02-13

Exhibit B, Page 297

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 298 of 352 Pageid#: 1201

voter_id 308002973 S 513004441 S 304032473 S 102009163 S 917822532 S 504004573 S 917782773 S 708019631 S 918482569 S 303030556 S 406026516 S 108216228 S 221014938 S 572730499 S
21002059 S 106026644 S 103012175 S 914718205 S 804019359 S 529105867 S
28009241 S 310046176 S 803006782 S 919923530 S 917700472 S 105011392 S
24955636 S 304006328 S 208026149 S
21005870 S 906016388 S 408005890 S
28015978 S

lname

fname ESTHER JOSEPH EVA BARBARA DANIEL DONALD ROBERT DONALD ANGELA RICHARD ROBERT ARTHUR CHARLOTTE BEULAH ANNE CHARLES EDWARD CAROLINE NORA ANNA PATRICIA CECIL JACK LILLIAN CYNTHIA GERALD JOHN DORRIS JAMES JAMES CURTIS WILFRED BETTY ANNIE

dob 1932 1957 1925 1938 1940 1950 1964 1937 1967 1935 1932 1951 1931 1938 1939 1932 1926 1944 1931 1929 1920 1932 1934 1953 1958 1920 1919 1944 1922 1942 1946 1921 1924

date_registered 2002-08-20 2008-11-12 1961-12-08 1983-06-04 2000-10-07 1973-10-06 1996-10-07 1991-08-06 2002-05-10 1992-10-01 1972-08-24 2012-03-26 1976-09-22 2008-08-21 1978-10-06 1954-06-11 1968-03-11 2008-03-20 1988-03-30 2015-10-09 2016-05-04 2004-09-29 1986-03-04 2016-09-30 1996-09-30 1979-09-29 2008-09-15 1995-02-13 1979-10-02 1984-09-19 1967-09-20 1951-10-04 1968-09-04

ssdi_dod 2020-01-19 2018-08-11 2014-11-27
2019-09-15 2016-09-10 2019-12-04 2018-12-16
2018-12-18 2018-09-18 2020-01-23 2020-01-10 2019-11-22 2019-11-14 2019-09-30 2019-08-23 2019-08-15 2019-08-11 2019-07-28 2018-12-20 2018-03-09 2018-02-16 2017-12-12
2019-12-17
2018-12-20 2019-12-31 2019-11-20 2019-11-11 2019-09-20

obit_dod
2018-08-11
2019-10-07 2019-01-18
2019-12-01 2018-12-16 2019-10-22 2018-12-18 2018-09-18
2019-11-22 2019-11-14
2019-08-23
2019-08-11
2018-12-20 2018-03-09 2018-02-16 2017-12-12 2019-07-16 2019-12-17 2016-10-29 2018-12-20
2019-11-20 2019-11-11 2019-09-20

Exhibit B, Page 298

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 299 of 352 Pageid#: 1202

voter_id 901519289 S
75514294 S 807009165 S 508010054 S 608012552 S 808009165 S 131907858 S 918662241 S 202001619 S 809004283 S 508010170 S 124047480 S 902006068 S 229005876 S 395582409 S
24009589 S 220514884 S 917766361 S 918945731 S 405005603 S 309040796 S 908006703 S 917509166 S 201001369 S 917157728 S 457342200 S 303023455 S 208012580 S 502024147 S 204023042 S 308031615 S 901024537 S 907013186 S

lname

fname GAIL JENETTE BETTY LUTHER ELAINE JAMES BETTY LILLIE CHARLES JANICE TREVA MARILYN MARSHA GLORIA ELIZABETH KENNETH RONNIE FRANK BONNIE MARY EUGENE MADELON BEVERLY CLINTON PAULINE JONATHAN HARLAN GWEN FRANK MARIA MARIAN JULIA TERRY

dob 1952 1937 1929 1934 1933 1928 1941 1937 1959 1941 1917 1938 1940 1931 1951 1923 1947 1945 1948 1920 1934 1934 1934 1932 1936 1990 1942 1938 1947 1930 1925 1926 1941

date_registered 2008-10-03 2008-10-06 1995-07-21 1975-06-10 1967-06-07 1995-07-21 2017-03-14 2000-01-11 1992-08-05 1964-09-30 1948-04-01 2010-12-30 1972-08-24 1968-08-12 2011-08-25 1976-09-30 2017-03-30 2004-08-31 2000-10-10 1985-11-14 1992-12-14 1964-08-28 1996-06-12 1967-08-11 1994-09-08 2016-02-08 1979-10-06 1972-09-28 1997-07-10 2000-10-10 1968-09-30 1989-09-12 1964-04-24

ssdi_dod 2019-09-20 2019-09-05 2019-08-20 2019-08-19 2019-03-07 2018-11-27 2018-09-18 2018-04-28 2018-03-14 2018-02-23 2016-02-15
2018-12-03 2019-11-09 2019-08-04 2018-04-13 2020-01-17 2019-12-18 2014-10-18 2019-09-15 2018-12-05 2019-10-08 2018-01-27 2015-09-11 2018-05-10
2017-08-26 2019-12-31 2018-11-26 2019-12-14 2019-09-05

obit_dod 2019-09-20 2019-09-05 2019-08-20
2019-03-07 2018-11-27
2018-04-28 2018-03-14 2018-02-23 2016-02-15 2019-10-30 2019-08-12
2019-11-09 2019-08-04
2019-12-18 2014-10-18 2019-09-15 2018-12-05 2019-10-08 2018-01-27 2015-09-11 2018-05-10 2019-08-25 2019-05-20
2018-11-26
2019-09-05

Exhibit B, Page 299

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 300 of 352 Pageid#: 1203

voter_id 920308294 S 301018162 S
24000496 S 917779742 S 919931033 S 508005433 S 460575156 S 205017655 S
86258178 S 918843247 S 705009392 S 106015988 S 925575225 S 227009787 S 917413070 S 919863256 S 919401252 S 808002108 S 604002331 S 920337374 S 304009554 S 501000418 S 800678494 S 501030113 S 901015022 S 205004323 S 919253625 S 601001481 S 920233181 S 917801192 S 203021740 S 207008784 S 715016950 S

lname

fname GARY MARY ALEXANDER EDITH MICHAEL EDWARD GARY ROGER HELEN AIMEE GENEVA FREDERICK CINDY GEORGE JOHN ELIZABETH JOANNE MARIE ROBERT PATRICIA ROGER MARVIN NANCY BETTY SHARLA WILLIAM JEFREY JULIAN CHARLES BARBARA MICHAEL HASWELL PATRICIA

dob 1951 1945 1927 1942 1939 1920 1949 1945 1944 1974 1946 1933 1951 1959 1931 1933 1952 1944 1934 1936 1932 1928 1922 1937 1946 1938 1958 1956 1947 1937 1949 1929 1962

date_registered 2006-06-16 2004-08-02 1968-05-10 1996-10-03 2004-09-30 1980-09-27 2012-11-26 1988-05-02 2018-07-31 2008-10-01 2005-03-21 1974-09-19 2008-10-06 1978-03-24 2004-06-01 2004-09-01 2002-09-25 1984-10-03 1956-01-01 2006-08-08 1969-09-30 1998-05-11 2007-08-02 1990-10-05 2002-10-07 1984-09-26 2002-01-07 1980-10-03 2006-01-03 1996-10-07 1980-09-10 1977-09-26 1996-06-14

ssdi_dod 2014-12-22
2019-06-26
2017-02-26 2017-08-02 2017-01-29 2019-12-30 2019-10-08 2019-08-13 2019-10-01 2019-07-01 2018-12-19 2018-01-12
2018-07-20 2018-12-09 2020-01-22 2019-11-04 2019-10-15 2019-09-24 2019-09-19 2019-09-15 2018-12-28 2018-12-16 2016-09-22 2016-08-17 2016-02-26 2006-02-26 2018-12-17 2019-03-13 2018-12-02

obit_dod 2014-12-22 2018-11-06 2019-06-26 2019-06-26 2019-09-08
2019-08-13 2019-10-01
2018-01-13 2017-07-07
2019-10-15 2019-09-24 2019-09-19 2019-09-15 2018-12-28 2018-12-16
2006-02-26 2019-03-13 2018-12-02

Exhibit B, Page 300

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 301 of 352 Pageid#: 1204

voter_id 177961762 S 404024503 S 122020775 S 702018037 S
11005124 S 908014530 S 902007543 S 706011444 S 116439496 S 917138537 S 917348983 S 604001415 S 410003247 S 898685468 S 918860382 S 223000195 S
20740878 S 205010373 S 801010054 S 289609324 S 305005589 S 917630746 S 918754049 S 508028452 S 305000927 S 208024117 S 613000161 S 917166367 S 212002488 S 208002889 S 697451054 S 507019577 S 918936610 S

lname

fname WALTER ELIZABETH VIVIAN CONNIE SUSAN E JERRY ELSIE HELEN STEPHENE JOSEPHINE MELNER BETTY THELMA CHARLTON SUSAN JACQUELIN ADELINE MELVIN LORI SALLY SANDRA GORDON WALTER FRANK ROY JOHN IRENE MARIANNE LUTHER JAMES CALVIN SARAH NATALIA

dob 1942 1944 1926 1938 1944 1939 1928 1938 1978 1939 1959 1943 1926 1946 1948 1937 1920 1941 1960 1942 1936 1947 1945 1935 1939 1922 1934 1933 1936 1942 1955 1944 1930

date_registered 2016-10-17 1981-09-26 1992-06-10 1971-04-16 1972-02-18 1978-11-08 1971-05-10 1984-09-24 2016-10-17 1992-09-14 1995-10-03 1984-03-06 1988-08-22 2008-09-24 2000-08-24 1976-07-14 2012-09-07 1972-08-31 2004-07-08 2010-11-08 1964-10-03 1999-02-08 2000-03-28 1962-04-28 1995-09-14 1952-10-04 1991-07-19 1996-10-03 1991-09-04 1977-01-04 2008-10-03 1987-10-03 2012-03-22

ssdi_dod 2019-10-18 2005-03-15 2019-11-24 2019-12-23 2019-10-18 2018-12-01 2019-10-23 2019-10-22 2019-06-26
2019-09-09 2019-01-30
2019-05-02
2020-01-01 2019-08-05 2018-12-22 2019-10-21 2018-09-27
2015-04-01 2019-01-16 2019-10-07
2019-09-20 2019-05-26 2019-04-23
2019-06-20 2019-10-26 2018-10-26

obit_dod
2019-11-24 2019-12-23 2019-10-18
2019-10-23
2019-06-26 2017-08-28
2019-01-30 2019-11-14 2019-05-02 2019-09-19
2018-12-22 2019-10-21 2018-09-27 2019-10-06
2019-01-16 2019-10-07 2019-10-10 2018-06-01 2019-09-20
2019-04-23 2018-06-22 2019-06-20 2019-10-26 2018-10-26

Exhibit B, Page 301

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 302 of 352 Pageid#: 1205

voter_id 303045899 S 917694960 S 508016162 S 901003939 S 234008037 S 308026562 S 405006455 S 903001787 S 703005535 S 917018059 S 918678814 S
20440144 S 919352283 S
25000991 S 701002471 S 251749224 S 917122256 S 401012112 S
21017518 S 221010164 S 907009410 S 918310769 S 918974968 S 226014659 S 708014476 S 711028243 S 102023732 S 103024114 S 705008336 S 412011751 S 345965147 S 701015041 S 403011751 S

lname

fname ANTHONY JOHN CARROLL KENNETH ROBERT JUNE JOHN PRISCILLA CLARENCE MAY JEANNE CLARENCE STACY MATTIE LEOTA CAROLYN LEANUARD GARNETT DAVID ADDIE JANE CATHERINE CYNTHIA ELLENE MARGIE CHARLES DESSIE JAMES DONALD GARNETT JOHN DOROTHY ARVILLE

dob 1935 1936 1939 1939 1938 1921 1939 1948 1938 1939 1940 1938 1972 1941 1943 1928 1930 1934 1929 1951 1922 1949 1948 1920 1946 1938 1931 1938 1954 1932 1946 1928 1925

date_registered 2004-10-04 2004-10-04 1983-10-08 1980-04-05 1988-10-08 1951-01-16 1978-10-07 1972-10-03 1966-08-01 2002-06-28 2000-01-31 2016-06-23 2002-06-26 1967-01-27 1998-05-06 2016-09-27 1994-05-16 1960-10-08 1964-09-24 1986-04-05 1964-09-16 1999-04-19 2000-11-09 1966-09-15 1994-03-01 1992-09-25 1956-11-05 1986-11-26 2009-04-09 1992-09-18 2011-04-13 1983-08-13 1983-10-04

ssdi_dod
2019-10-16 2020-01-04 2018-12-01 2016-09-14
2019-10-09
2015-11-21 2019-10-20 2019-11-16 2019-10-20 2018-06-19
2017-12-27 2018-03-16 2019-12-25
2018-12-01 2014-10-19 2019-10-29 2018-07-21
2019-11-01 2018-12-31
2019-09-10 2019-09-02 2019-11-05 2019-03-01 2018-03-12 2017-12-10

obit_dod 2019-11-19
2018-12-01
2016-10-07
2019-09-03 2015-11-21 2019-10-20 2019-11-16 2019-10-20 2018-06-19 2019-08-17 2019-08-08 2017-12-27 2018-03-16
2017-02-28
2014-10-19 2019-10-21 2018-07-21 2019-08-29 2019-11-01 2018-12-31 2019-10-16 2019-09-10 2019-09-02 2019-11-05
2017-12-10

Exhibit B, Page 302

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 303 of 352 Pageid#: 1206

voter_id 104001572 S 105001772 S
2235238 S 303050908 S 132002107 S 123009452 S 708014178 S 920086912 S 704002477 S 305001691 S 920140938 S 303000929 S 919402277 S 918470779 S 221009790 S 706028155 S 702002025 S 917456708 S 127002107 S 917107764 S 108020761 S 203002252 S 917315144 S 602007518 S 919494621 S
12007097 S 606013125 S 917403968 S
88374933 S 507301318 S 206005628 S 918876977 S 504002498 S

lname

fname LEONARD PRESTON JOHN KAILASH HERBERT WILLIAM SHIRLEY MARGARET WALLACE JEROME CAROLE WILLIAM LOIS LLOYD SUSAN GARY MARY ROSE JEREMIAH MARK BARBARA PAULETTE MIRIAM WARTHEN CATHARINE CAROLYN IRENE MARY ROBERT DILLARD MARIAN RAGIBOMMANAHALL ADELINE

dob 1925 1937 1938 1937 1920 1944 1938 1987 1936 1929 1937 1928 1926 1959 1931 1958 1934 1928 1933 1952 1960 1946 1937 1942 1939 1943 1924 1934 1950 1954 1924 1948 1921

date_registered 1947-06-28 1971-09-21 2012-09-04 1996-09-17 1988-10-05 1982-10-02 1986-04-05 2005-04-19 1971-01-01 1964-09-21 2005-08-01 1956-10-04 2002-09-26 1999-04-05 1979-10-02 1996-11-14 1981-10-03 1996-04-08 1976-10-02 1994-04-08 1987-02-03 1972-10-03 1995-08-21 1972-10-07 2003-04-03 1988-10-08 1963-10-01 1996-03-07 2015-11-09 2007-12-03 1990-03-02 2000-09-09 1984-04-04

ssdi_dod 2019-11-06 2018-03-10 2018-12-29 2017-12-22 2018-12-05 2019-06-10 2019-07-15 2019-09-03 2019-12-29 2019-12-20 2019-12-19 2019-12-09 2019-10-20 2019-10-11 2019-10-04 2019-09-21 2019-08-03 2019-03-30 2018-12-09 2018-09-23 2018-02-27 2018-01-10 2014-03-30
2019-09-28 2019-08-31 2019-10-18 2019-01-16 2018-07-28 2017-02-07 2017-07-08

obit_dod 2019-11-06 2018-03-10 2018-12-29 2017-12-22 2018-12-05 2019-06-10 2019-07-15 2019-09-03
2019-12-09 2019-10-20 2019-10-11 2019-10-04 2019-09-21 2019-08-03 2019-03-30 2018-12-09
2018-02-27 2018-01-10 2014-08-30 2015-12-13 2018-12-09 2018-01-31
2019-08-31 2019-10-18 2019-01-16
2017-07-08

Exhibit B, Page 303

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 304 of 352 Pageid#: 1207

voter_id 202021742 S 918525257 S 918415766 S 101022211 S 521146436 S 710017445 S 705014043 S 605032240 S
27007222 S 102026300 S 231243168 S 905004274 S 226006239 S 918313560 S 225025017 S 803178709 S 713017063 S 346813356 S
29007987 S 301047533 S
35591726 S 475733881 S 797293616 S
26010008 S 917202347 S 704025565 S 198375004 S 919106532 S 306005593 S 947073307 S 601021810 S 103021153 S 504027664 S

lname

fname JOHN RANDY ANDREW ANNE BERNITA JOHN WILLIAM NOAH DANIEL JOANN SHIRLEY LORRAINE JOE MAY JEANETTE ELIZABETH ANN ROBERT TOLLEY JEAN JOYCE CAROL WILLIAM JOHN DOROTHY BARBARA GERALDINE RITA LAWRENCE THEODORE ROBERT ETHEL BARBARA CHARLES GARY

dob 1926 1956 1936 1943 1946 1940 1919 1948 1937 1930 1934 1937 1934 1936 1944 1929 1943 1935 1946 1940 1943 1955 1933 1932 1938 1925 1938 1958 1937 1928 1926 1948 1938

date_registered 1983-09-21 1999-06-08 2000-03-07 2012-03-23 2013-08-29 1990-09-18 1994-11-23 1998-11-05 1972-03-27 1953-04-21 2019-04-03 1968-06-03 1988-08-01 1998-08-10 1992-09-22 2009-10-02 1992-10-02 2008-03-10 1976-09-29 1991-05-25 2016-06-29 2008-06-23 2008-10-02 1972-10-05 1994-10-11 1978-09-27 2013-10-04 2006-04-12 2005-04-27 2008-05-22 1990-10-04 1996-09-06 1989-08-11

ssdi_dod
2018-07-09 2019-10-09 2019-08-14
2019-12-10 2018-12-22 2020-01-11 2019-12-18 2018-01-20 2019-12-02 2019-07-29 2018-01-06 2014-07-23 2006-10-03
2018-09-16
2018-03-27
2019-11-24 2017-06-20 2020-01-20 2020-01-13 2019-12-26 2019-12-14 2019-04-13
2019-07-17 2017-04-10 2020-01-01 2019-10-06 2018-01-28

obit_dod 2016-05-02 2018-07-09
2019-08-14 2018-12-17 2019-12-10
2018-01-20
2019-07-29 2018-01-06 2014-07-23
2019-10-04 2018-09-16 2018-12-26 2018-03-27 2018-06-24 2019-11-24
2019-12-14 2019-04-13 2014-07-25
2019-10-06

Exhibit B, Page 304

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 305 of 352 Pageid#: 1208

voter_id 919991172 S 918506127 S 705030023 S 919695857 S
29013914 S 502699988 S 108006080 S 185274027 S 919766915 S 917333949 S 919846464 S
38283887 S 807920588 S 114589277 S 917963644 S 308021834 S 902006957 S 419667482 T 224011804 T
38036224 T 202001503 T 919572072 T 232013836 T 278134628 T 917393295 T 163225156 T 917941393 T 920273205 T 917831843 T 604003710 T 507007024 T 178077122 T 917466035 T

lname

fname STUART BRENDA MYRON ELSIE CAROL THOMAS MATTIE BRIAN SABINO LLOYD ANNIE AGNES ROBERT JUDY GYALOKAY DONALD ROSEANN ANSELMO MARK RALPH STEVEN HOWARD LINDA FRANK JULIO ROBERT DARREN WILLIAM REYNALDO JEAN THELMA MARY KELLIE

dob 1959 1940 1942 1934 1929 1947 1924 1971 1924 1937 1939 1942 1928 1954 1942 1937 1940 1944 1946 1946 1959 1943 1943 1951 1937 1923 1963 1975 1946 1942 1952 1944 1963

date_registered 2004-10-04 2004-01-12 1992-10-03 2004-02-13 2000-10-02 2017-06-21 1968-09-26 2012-11-08 2004-05-25 1995-09-22 2004-08-19 2008-08-29 2008-01-07 2007-09-17 2002-05-28 1986-06-11 1972-09-30 2008-10-06 1976-09-14 2011-02-17 1984-10-01 2003-08-13 1988-10-05 2015-06-03 1996-01-30 2015-04-15 1997-03-10 2006-03-30 1997-08-27 1964-04-04 1980-10-04 2010-02-01 1996-04-15

ssdi_dod 2019-09-11 2018-06-23 2019-12-30
2020-01-12 2019-11-26 2018-02-25 2015-12-28 2018-04-15 2019-12-09 2019-11-27 2019-10-03 2018-01-11 2014-02-05
2020-01-05 2019-09-27 2019-12-05
2018-03-20 2018-03-16 2020-01-27 2018-09-28 2019-11-27 2017-04-22 2015-01-06 2019-11-01 2018-01-31 2019-11-16 2019-09-25 2018-01-30 2018-02-16

obit_dod 2019-09-11
2019-11-05 2018-12-10 2019-11-26
2018-04-15 2019-12-09 2019-11-27
2014-02-05 2019-04-10 2019-09-27 2019-12-05 2018-12-29 2018-03-20
2017-04-21
2018-01-31 2019-11-16 2019-09-25 2018-02-16

Exhibit B, Page 305

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 306 of 352 Pageid#: 1209

voter_id 228018380 T 253692499 T 245817239 T 919630194 T 918418718 T 302048380 T 917610031 T 303020303 T 107018970 T 707018043 T 228011442 T 918473275 T 917828979 T 261447279 T 919824410 T 247904731 T 405018531 T 904023669 T 917913844 T 160746973 T 117351177 T 563699330 T
84987851 T 309034046 T 407019234 T 507002499 T 919414759 T 919717506 T 502029832 T 917805184 T
64018249 T 126001872 T 613015373 T

lname

fname DORIS MARGARET YAYESH KATHERINE DAVID YAEKO ANGELA JEAN MARLENE EDWARD ESTHER JEMISHA JERALD WAVERLY GEORGE JAMES BARBARA CARNELL MICHAEL FRED ELIZABETH WILLIAM FLORENCE GEORGE WILLIAM EDWARD MILDRED ARTHUR ANNE GEORGE ROBERTA BOYCE LOVELLE

dob 1922 1926 1952 1922 1940 1934 1931 1931 1931 1942 1921 1981 1942 1957 1955 1943 1937 1922 1954 1926 1910 1923 1934 1942 1933 1935 1929 1956 1941 1959 1938 1935 1949

date_registered 1976-10-02 2012-09-10 2010-09-16 2003-11-05 1999-01-14 1971-06-09 1996-08-22 1958-11-28 1959-10-03 2006-06-14 2000-05-25 1999-03-25 1996-11-22 2014-10-14 2004-08-04 2010-09-03 1968-09-10 2006-09-28 2016-09-26 2018-09-19 2016-05-06 2014-08-08 2016-09-25 1994-10-11 1957-10-05 1967-10-05 2002-10-01 2004-03-23 1984-09-22 1996-11-06 2008-01-14 1964-09-24 1972-10-07

ssdi_dod 2019-05-17 2014-10-14 2018-12-15 2018-12-20 2015-11-27 2018-12-03 2019-09-05 2019-11-19 2018-12-21
2019-10-24 2016-09-30
2018-03-22 2019-11-03
2019-12-07 2019-10-19 2016-11-04
2018-12-31 2018-12-16
2019-01-22 2019-12-21 2019-12-17 2019-11-30 2019-11-25 2019-11-21 2019-11-15 2019-11-02 2019-10-25 2019-10-24

obit_dod 2019-05-17
2018-12-20 2015-11-27 2018-12-03
2019-02-14 2019-10-24 2016-09-30 2019-08-22 2018-03-22 2019-11-03 2019-10-05
2016-11-04 2019-08-28 2018-12-31 2018-12-16 2019-08-01
2019-12-21 2019-12-17 2019-11-30 2019-11-25 2019-11-21
2019-10-25 2019-10-24

Exhibit B, Page 306

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 307 of 352 Pageid#: 1210

voter_id 918532293 T 203024456 T 918875827 T 919898527 T 306016185 T 405012114 T 365818237 T 501004074 T 708004439 T 903020550 T 706004561 T 824982354 T 203011016 T 107020672 T 517025326 T 501010173 T 917836133 T 917471118 T 125013229 T 903009092 T 917742380 T
21016840 T 918271010 T 220009438 T 209000061 T 226009795 T
49631255 T 177039825 T 604028446 T 917707994 T 708015808 T 406010772 T
91956305 T

lname

fname CAROL EARL NANCY DONNA IONYA HOPE SANDRA JAMES RUBY IRENE ARTIE JUDY HARRY NANCY WILLIAM EDITH LAWRENCE JEFFIE CLIFTON MARGARET ROBERT ESELENE JOHNNY BESSIE ELIZABETH PETER ARCHER JANE HOWARD DONNA LARRY HELEN HARLEY

dob 1945 1930 1935 1948 1953 1924 1953 1938 1941 1942 1954 1948 1939 1940 1943 1930 1946 1943 1938 1939 1941 1925 1949 1924 1921 1944 1939 1932 1944 1942 1950 1926 1941

date_registered 1999-06-25 1963-02-25 2000-08-28 2004-09-20 1986-09-15 1952-03-01 2007-07-17 1964-02-24 1986-03-28 1980-10-04 1988-03-09 2016-06-15 1980-09-27 1964-10-03 1991-09-20 1950-06-15 1996-11-15 1996-04-22 1963-11-07 1968-09-04 1996-10-07 1966-05-11 1998-05-20 1956-05-09 1964-10-02 1996-10-05 2016-10-17 2008-06-09 1967-05-30 1996-10-01 1983-09-24 1951-04-26 2017-04-06

ssdi_dod 2019-10-20 2019-10-20 2019-10-19 2019-10-17 2019-10-17 2019-09-24 2019-09-23 2019-09-18 2019-09-11 2019-09-11 2019-09-09 2019-09-07 2019-08-24 2019-08-11 2019-08-08 2019-08-04 2019-08-02 2019-07-30 2019-06-03 2019-05-03 2019-03-09 2019-03-02 2019-02-26 2018-12-23 2018-12-19 2018-12-13 2018-12-07 2018-11-29 2018-11-25 2018-11-22 2018-09-19 2018-03-31 2018-03-31

obit_dod 2019-10-20
2019-10-19 2019-10-17 2019-10-17 2019-09-24 2019-09-23 2019-09-18 2019-09-11 2019-09-11 2019-09-09 2019-09-07 2019-08-24 2019-08-11 2019-08-08 2019-08-04 2019-08-02 2019-07-30 2019-06-03 2019-05-03 2019-03-09 2019-03-02 2019-02-26 2018-12-23 2018-12-19 2018-12-13 2018-12-07 2018-11-29 2018-11-25 2018-11-22
2018-03-31

Exhibit B, Page 307

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 308 of 352 Pageid#: 1211

voter_id 546975816 T 701001229 T 128009847 T 905005421 T 917779601 T 601029109 T
79103901 T 230013837 T 104006262 T 387388341 T 127011635 T 121009652 T 228006818 T 360926285 T 302027973 T 204016403 T 919860577 T 302004348 T 121012732 T 919601270 T 917140010 T 901012813 T 902210661 T 917318881 T 918988580 T 279827193 T 223020733 T 703020085 T 981793787 T 505015660 T 920193764 T 202005756 T 905008886 T

lname

fname TIMOTHY MARION FRANK ISAAC BONNIE JACK JAMES EDWARD NORA JIMMY ELEANOR JUANITA JEAN SUSANNE DOLORES ULYSSES MICHAEL DORRIS VIRGINIA JAMES DIETMAR VICTORIA JOLANDA MARTIN RAUL OSCAR JAMES DONALD BARBARA EDMUND CAROL WILLIE ERNEST

dob 1946 1936 1943 1932 1943 1938 1954 1960 1947 1947 1939 1928 1945 1946 1929 1929 1946 1933 1948 1948 1942 1945 1926 1950 1938 1958 1935 1933 1943 1948 1943 1945 1937

date_registered 2015-07-23 1965-10-01 2014-07-29 1966-10-08 1996-10-07 1998-01-12 2012-10-05 1992-10-03 1979-09-21 2007-06-25 1972-09-12 1963-12-09 1975-06-11 2012-10-04 1985-04-25 1984-09-15 2004-08-31 1993-09-23 1993-09-11 2003-09-29 1994-07-23 1980-10-02 2008-03-14 2004-06-22 2000-11-08 2008-10-06 1999-08-19 1974-06-13 2008-03-06 1969-06-11 2005-10-11 1968-10-05 1958-10-04

ssdi_dod 2018-03-08 2018-01-29 2017-11-24 2017-11-23 2017-11-22 2017-07-26 2016-12-13 2016-09-10 2016-04-11
2019-07-24 2019-04-02 2018-07-08 2016-12-20 2018-01-27 2017-08-25 2020-01-22 2019-09-08 2019-12-03

obit_dod
2018-01-29
2017-11-23 2017-11-22 2017-07-26 2016-12-13 2016-09-10 2016-04-11 2019-10-03 2019-07-01 2019-05-02 2018-12-31 2018-12-08 2018-09-29 2018-07-17 2018-06-09 2018-05-07 2017-05-03 2016-03-30 2018-11-05 2018-12-08
2016-12-21 2018-01-27 2016-05-22 2017-08-25
2019-10-16 2019-12-03

Exhibit B, Page 308

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 309 of 352 Pageid#: 1212

voter_id 24642401 T 4004120 T
607203947 T 478164413 T 506003579 T 240844839 T 901023992 T 918480468 T 223006819 T 305015183 T 920269166 T 917393947 T 356406531 T 128018494 T 128018323 T 905015038 T 920036325 T 710197894 T 603028040 T 203025395 T 909017208 T 605009145 T 917721995 T 918362732 T 918508320 T
23006050 T 908020205 T 707020085 T 221013343 T 250040487 T 202819771 T
77361393 T 908020552 T

lname

fname SUSIE JESSIE JACK SHIRLEY CHARLES MARILYN VIOLA DANNIE MENORU RONALD MONIQUE ALLEN JENNIFER SHARON BETTY VICTORIA STEPHEN VIRGINIA BONNIE ROY ERNEST BIRGER IRIS A ROLAND ELIZABETH JUSTIN DIANE BUFORD MARY LESLIE BALACHANDRA MARVIN FANNIE ARETHA

dob 1931 1958 1937 1948 1935 1922 1927 1950 1944 1934 1955 1954 1954 1931 1947 1949 1937 1941 1946 1971 1928 1945 1937 1938 1981 1932 1932 1939 1925 1941 1955 1927 1946

date_registered 2016-09-22 1982-10-02 2010-09-22 2012-09-28 1992-09-25 2012-09-14 1989-09-14 1999-04-15 1992-10-03 1984-02-15 2006-03-22 1996-02-11 2012-10-09 1960-09-21 1999-07-09 2000-05-03 2004-12-17 2014-08-04 1979-10-06 1992-11-04 1990-10-06 1969-04-19 1996-10-04 1998-10-05 1999-05-20 1960-04-21 1982-09-21 1973-09-25 1984-05-02 2010-04-12 2008-10-06 2013-05-20 1996-11-06

ssdi_dod 2019-12-21 2019-05-25 2019-04-12 2018-06-20 2018-01-29 2014-10-06
2018-05-10 2020-01-11
2018-05-13
2020-01-26 2019-12-07 2019-11-26 2019-11-02 2019-06-21 2018-12-23 2018-10-10 2018-04-10 2019-10-10 2018-06-28
2019-03-17 2016-02-07
2019-08-18 2018-02-16 2015-02-04 2019-10-18 2018-09-16 2019-12-27 2019-12-23

obit_dod
2019-05-25
2018-06-20 2018-01-29
2019-09-02
2019-09-15 2018-05-13 2017-10-22
2019-12-07 2019-11-26 2019-11-02
2018-10-10 2018-04-10
2018-06-28 2018-12-29
2018-12-30 2019-08-18 2018-02-16 2015-02-04 2019-10-18 2018-09-16

Exhibit B, Page 309

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 310 of 352 Pageid#: 1213

voter_id 904010275 T 801015238 T 105026480 T 755212043 T 919434469 T 402023585 T 918846388 T 228002769 T 920360606 T 807014032 T 337802661 T 919097361 T
74192545 T 287369510 T 917192873 T 622525498 T 401004105 T 803004776 T
62798603 T 917305095 T
26788182 T 391229289 T 609032622 T 908002076 T 406024224 T 412026186 T
26009848 T 308037215 T 919805227 T 149982355 T 301004973 T 702008562 T 607021814 T

lname

fname ARVON LAWRENCE WILLIAM VIKKI JOYCE MARGUERITE ALAN RICHARD RICHARD VIVIAN GIBSON DEBORAH CHARLES JOANNE RICHARD NORMARSHA JOHN JOHN MARY ANNAMMA WILLIAM WILLIAM JAMES JAMES MAUREEN PAUL JOHN CARROLL STANLEY ANNIE RHEA CHARLES WALTER

dob 1929 1947 1950 1971 1954 1926 1946 1936 1938 1956 1957 1957 1953 1942 1941 1977 1938 1929 1924 1930 1944 1944 1929 1932 1928 1946 1927 1923 1933 1927 1932 1934 1934

date_registered 1960-05-31 1979-09-12 2002-06-20 2016-10-17 2002-11-05 1972-07-28 2000-08-11 1981-09-09 2006-09-20 1996-08-07 2018-06-22 2001-04-20 2008-07-30 2009-04-24 1996-08-14 2007-11-26 1972-09-26 1979-09-20 2012-09-29 1996-09-20 2017-08-04 2018-03-15 1976-10-01 1958-05-21 1949-12-12 1980-08-15 1968-03-12 1964-09-16 2004-07-13 2007-11-26 1992-10-02 1999-03-10 1986-10-02

ssdi_dod 2019-12-15 2019-11-26 2019-11-18 2019-10-15 2019-10-03 2019-09-15 2019-09-05 2019-09-01 2019-08-16 2019-08-10 2019-07-21 2019-01-27 2018-12-30 2018-12-29 2018-12-14 2018-08-04 2018-03-28 2016-12-12 2014-01-18 2012-08-10 2011-07-07 2011-07-07 2001-12-03
2019-12-31 2020-01-21

obit_dod 2019-12-15 2019-11-26 2019-11-18 2019-10-15 2019-10-03 2019-09-15 2019-09-05 2019-09-01
2019-08-10 2019-07-21
2018-12-30 2018-12-29
2016-12-12 2014-01-18
2019-10-17 2019-10-06 2019-09-13 2019-08-14 2019-08-13 2018-12-22 2016-09-28 2015-04-19

Exhibit B, Page 310

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 311 of 352 Pageid#: 1214

voter_id 21008898 T
507023821 T 203018150 T 187804227 T 908023005 T 224006247 T
25013809 T 202007618 T 910010632 T 917015397 T 918797409 T 809005728 T 919729502 T 204017187 T
9003441 T 607027929 T 601001763 T 650623977 T 203029965 T 920058758 T
23013400 T 917139807 T 108928468 T 222007411 T
21003405 T 920278298 T 918091272 T 283545912 T 918889241 T 918686089 T 305045912 T
12006482 T 306008648 T

lname

fname DOROTHY SARAH MARTHA LORETTA JACK ANNIE NORMA MAUDE IRENE FAYE EDITH MICHAEL LARRY TAMMY LORETTA DOROTHY HELEN RUBY DENIZ NANCY GEORGETTE CHARLIE SCOTT MAVIS BARBARA BEATRICE NELDA ELLEN ELSIE JOHN DARLENE MICHAEL GARNETT MONICA

dob 1933 1948 1920 1943 1927 1927 1935 1931 1935 1942 1935 1944 1963 1947 1921 1931 1945 1943 1953 1928 1930 1969 1913 1937 1930 1931 1948 1937 1943 1934 1946 1943 1930

date_registered 1992-07-29 1985-07-16 1976-09-08 2015-06-18 1993-09-30 1974-10-04 1965-04-23 1978-11-08 1988-09-17 1997-04-15 2000-06-08 1992-07-21 2004-03-31 1998-11-03 1999-04-30 1967-10-07 1980-03-25 2008-09-18 1992-10-01 2005-02-17 1967-05-24 1998-07-23 2013-06-18 1972-02-01 2004-09-09 2006-03-30 1997-09-15 2012-05-03 2000-09-18 1999-12-13 1978-03-13 1972-10-04 1964-09-30

ssdi_dod 2020-01-08 2019-12-24 2019-12-02 2019-10-18 2019-10-14 2019-10-07 2019-08-19 2019-06-22 2019-04-01 2019-01-29 2019-01-02 2018-12-30 2018-12-24 2018-12-17 2018-12-01 2018-09-26 2018-08-23 2018-07-14 2018-01-27 2018-01-21 2017-01-24 2017-01-22 2015-12-16 2015-11-26 2015-11-24 2015-10-05 2013-11-10 2012-01-18

obit_dod
2019-10-18 2019-10-14
2019-08-19 2019-06-22
2018-12-30 2018-12-24 2018-12-17 2018-12-01
2018-08-23
2018-01-27 2018-01-21 2017-01-24 2017-01-22 2015-12-16 2015-11-26
2015-10-05
2012-01-18 2019-11-16 2019-10-04 2019-09-07 2019-08-11 2019-08-07

Exhibit B, Page 311

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 312 of 352 Pageid#: 1215

voter_id 917632675 T 204006942 T
38303502 T 603031264 T 606000061 T 519007773 T
12004417 T 458820371 T 403007874 T 504025204 T 508011016 T 911023994 T 601038883 T 603001420 T 123010181 T 917809651 T 701005951 T 111023066 T 374816724 T 505022967 T 508022452 T 302025979 T 182990577 T 511015276 T 106027501 T 205013929 T 804004305 T 222014666 T 905021540 T 207008287 T
45427029 T 919124228 T 209018940 T

lname

fname LINDA BERTHA MARILYN SARA BOBBY HENRY EDITH JAMES MILDRED ETHEL NELLIE KAY DARLENE WANDA CHARLES GERALD BESSIE LEWIS GEORGE ROY KATHLEEN WESSON PATRICIA PEARL ELIZABETH ARKELL CHRIS FRANK ALLYNE RICHARD CATHERINE EVELYN HENRY

dob 1946 1937 1937 1946 1939 1946 1933 1935 1929 1931 1916 1932 1958 1926 1925 1936 1926 1929 1937 1946 1948 1933 1955 1935 1922 1930 1951 1945 1931 1940 1919 1924 1938

date_registered 1999-10-04 1987-10-01 2014-06-19 1976-10-02 1991-09-04 1992-01-23 1967-04-22 2012-05-01 1974-09-20 1954-04-08 1997-08-13 1988-09-24 1998-08-03 1986-09-19 1997-11-05 2016-09-14 2000-03-13 2001-09-19 2012-09-14 1996-09-03 1984-09-08 1968-10-02 2016-10-17 1990-09-15 1970-10-03 1972-04-21 1986-03-19 1992-09-29 1980-09-25 2006-10-06 2010-01-27 2001-06-21 1992-10-03

ssdi_dod
2019-12-23 2018-12-23 2018-04-09 2017-03-10
2018-12-05 2019-11-05 2019-09-08 2019-08-27 2019-07-19 2019-06-25 2017-11-29 2017-02-25 2019-08-01 2019-10-22
2019-11-03
2018-05-06 2019-12-22 2018-12-27
2019-08-02 2018-03-30
2019-05-14 2014-08-05
2017-07-25

obit_dod 2018-12-02 2017-08-28 2016-07-13 2019-02-10 2019-12-23 2018-12-22
2017-04-30 2018-12-05 2019-11-05 2019-09-08 2019-08-27 2019-07-19 2019-06-25
2017-02-25 2019-08-01 2019-10-22 2019-08-11
2012-02-26 2018-05-06 2019-12-22 2018-12-27 2018-12-27 2019-08-02
2016-03-31 2019-05-14 2014-08-05 2013-01-12 2017-07-25

Exhibit B, Page 312

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 313 of 352 Pageid#: 1216

voter_id 917576380 T 917869913 T 502033679 T 602027776 T 919134709 T 508033679 T 808007476 T 102026303 T 918206058 T 784732911 T 406012437 T 918902910 T 805007477 T 107003448 T 908004281 T 919270032 T 602032567 T 919439715 T 903003005 T 233187777 T 919731070 T
3003360 T 126007601 T 117006082 T 917955304 T 919704005 T 263972656 T 405017141 T 311352925 T 222009459 T 918746360 T 561611867 T 901004873 T

lname

fname JOHN MARCY HERBERT WILLIAM SHARAD ROBERT FLORENCE BETTY RAIMUND ARLENE ROSEMARY HENRY WALLACE BOBBY HARRISON BETTY PATRICIA RONDAL INEZ STEFHAN KAMSANG REBECCA REGINALD WILLIAM CURTIS GARY HAROLD CORNELIUS YOLONDA CECIL HILDA AMY EMILY

dob 1924 1945 1929 1952 1943 1952 1924 1948 1946 1924 1942 1939 1929 1933 1945 1937 1934 1959 1945 1988 1928 1953 1947 1931 1941 1949 1948 1931 1975 1922 1941 1940 1927

date_registered 1996-07-29 2000-03-21 1977-04-11 1971-07-30 2001-07-03 1983-10-06 1964-08-01 1987-08-28 1998-02-25 2007-01-16 1963-06-08 2002-07-12 2002-02-04 1975-08-28 2006-08-23 2002-02-07 1974-10-05 2002-11-20 1980-10-02 2010-07-16 2004-04-05 1980-09-22 2005-04-26 1991-11-20 1998-04-01 2007-02-07 2008-10-01 1976-09-28 2016-10-21 1997-06-11 2000-04-03 2008-05-23 1976-03-03

ssdi_dod 2016-09-15 2015-12-09 2019-11-29 2018-12-17
2019-06-26 2018-05-15 2019-03-15
2019-10-22 2019-10-31 2019-10-08 2018-12-03
2019-11-27 2018-06-19 2019-10-17 2019-08-08 2019-01-04 2018-03-08 2019-05-19 2019-10-31 2019-08-23 2018-01-12 2016-02-27 2018-02-20 2019-11-19 2019-08-02 2018-08-06 2018-03-10 2018-02-07

obit_dod 2016-09-15 2015-12-09 2019-11-29 2018-12-17 2019-01-21 2019-06-26 2018-05-15
2016-12-13
2019-10-31 2019-10-08 2018-12-03 2019-09-04 2019-11-27 2018-06-19
2019-08-08 2019-01-04
2019-08-23 2018-01-12 2016-02-27 2018-02-20 2019-11-19 2019-08-02 2018-08-06
2018-08-06 2015-04-26

Exhibit B, Page 313

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 314 of 352 Pageid#: 1217

voter_id 303029563 T
10006561 T 917453935 T
57148164 T 919593753 T 203008079 T 501028673 T 471687864 T 509217009 T 807000894 T 919244391 T 606022995 T 207007452 T 402011560 T 917052030 T 778510013 T 347359173 T 920076119 T 371931711 T
14144297 T 414179379 T 918329308 T 918715349 T 307032963 T 608029111 T 920022381 T 370459672 T 708014049 T 918672818 T 204013930 T 911891659 T 917332159 T 205009643 T

lname

fname ALFRED CLIFTON KAREN JAMES VICKIE LEONARD FREDERICK LAMONT OTIS ALEXANDER EVELYN LUTHER JUDITH BETTY DENNIS MICHAEL PATRICK SABINA ELIZABETH STELLA ALICE ALAN BRENDA JACK LUCILLE TAMARA VIVIAN FRANK BARBARA ALBERT BARBARA JASON BEATRICE

dob 1923 1935 1927 1932 1954 1931 1946 1982 1978 1923 1931 1936 1943 1941 1942 1960 1969 1943 1933 1941 1949 1961 1950 1926 1924 1981 1943 1936 1945 1932 1939 1974 1942

date_registered 1972-05-13 1995-08-19 1996-03-29 2014-10-14 2003-09-09 1979-10-05 1985-03-29 2008-04-21 2008-08-06 1952-04-05 2001-12-10 1980-09-12 1977-10-08 1978-10-07 2000-10-09 2008-09-30 2010-07-15 2005-03-30 2016-12-19 2012-08-09 2018-10-15 2017-04-28 2000-03-15 1980-06-18 1956-09-29 2004-11-18 2011-08-24 1959-07-25 2000-01-24 1976-05-21 2008-10-01 1995-09-21 1968-10-03

ssdi_dod 2018-12-15
2019-11-22 2018-01-10 2016-07-27 2016-02-09 2014-11-02
2019-09-10 2019-02-20 2018-12-14 2020-01-01
2018-03-13 2015-11-26 2019-09-26 2019-01-31 2018-12-18 2018-12-03 2018-10-13 2018-01-19 2019-10-30 2019-09-17 2019-08-26 2018-12-17 2018-05-03 2017-02-26 2019-11-25 2020-01-26 2019-08-24

obit_dod 2018-12-15 2015-04-02 2019-08-04 2019-07-24 2019-11-22 2018-01-10
2016-02-09
2016-02-11 2019-09-10 2019-02-20 2018-12-14
2016-09-03 2018-03-13 2015-11-27
2019-01-31 2018-12-18 2018-12-04 2018-10-13 2018-01-19 2019-10-30 2019-09-17 2019-08-26
2018-05-03
2019-11-25
2019-08-24 2019-10-10

Exhibit B, Page 314

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 315 of 352 Pageid#: 1218

voter_id 862661413 T
26020180 T 857963650 T 906003596 T 917232046 T 406029386 T 302031626 T 919977278 T 102877409 T 917441034 T 302026571 T 508012222 T 803007122 T 197351323 T 917450715 T 128013804 T 703027072 T 252099926 T 304040811 T 920322876 T 918216749 T 918688824 T 919848624 T 156850687 T 918382050 T 705022215 T 309007546 T 505017544 T 909005148 T 206009440 T 917495842 T 919494641 T
27005878 T

lname

fname JOANNE GERTIE ROBERT JAMES ROBERT EDWIN VICTOR DIANE CLETO CHARLES THOMAS RICHARD EMMITT DESMON RHONDA WILMER LINDA HELEN ROSELLA TRI CHAU HOANG MOT BENJAMIN MARYSE VINCENT JAMES ELSIE ELVA ELIZABETH ELLA ELTON LULA

dob 1947 1940 1928 1929 1941 1952 1938 1947 1945 1947 1958 1937 1926 1952 1960 1929 1946 1918 1928 1949 1926 1942 1931 1932 1934 1920 1933 1924 1935 1948 1962 1933 1933

date_registered 2008-09-04 1983-10-01 2007-09-14 1980-04-03 1994-12-30 1992-09-30 1986-08-20 2004-10-04 2017-07-20 1996-04-03 1984-09-20 2006-09-11 1968-09-30 2014-06-27 1996-03-27 1958-12-19 1992-07-27 2008-10-06 1960-10-07 2006-06-08 1998-03-17 2000-01-31 2004-08-23 2016-08-10 1998-11-30 1946-04-27 1955-02-26 2004-01-03 2000-01-12 1971-09-02 1997-04-02 2003-04-03 1984-09-13

ssdi_dod 2019-07-01 2019-12-11 2020-01-19 2019-12-22 2019-08-11 2019-09-10
2019-10-06 2018-05-12 2016-12-11
2018-12-16 2017-10-17 2017-08-11 2020-01-05 2019-11-02 2015-11-29 2019-11-27 2018-03-09 2005-06-05
2018-11-07 2018-10-04
2019-10-29 2014-10-20 2019-10-20 2019-08-09 2017-12-26 2017-12-16

obit_dod 2019-07-01 2019-12-11
2019-12-22
2019-09-10 2019-03-15 2018-12-26 2019-10-07 2018-05-12
2019-09-28 2018-12-16 2017-10-17 2017-08-11
2019-11-02
2019-11-27
2018-12-21 2016-01-26
2019-09-18
2014-10-20
2019-08-09
2017-12-16 2019-10-28

Exhibit B, Page 315

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 316 of 352 Pageid#: 1219

voter_id 125013639 T 203010172 T 805001455 T
6659062 T 917290176 T 507007775 T 544613820 T 920137421 T 705026717 T 917761315 T 920126963 T 508010601 T 920350467 T
12406932 T 920374763 T 310039387 T 917764347 T 503004608 T
63887702 T 109016337 T 102005272 T 305029209 T 114027623 T 232002908 T 918176833 T 306019714 T
32675391 T 304016191 T
12005012 T 42463409 T 918814872 T 307009798 T 107300758 T

lname

fname JACK MABEL JACK ROBERT DONALD CHARLOTTE BETTY CHUNG VICTOR TODD DONNA GLADIOLA STEVEN MORLAND MERCEDES MICHELLE MATTHEW THELMA MICHAEL THEODORE KATHERINE MICHEAL ALAN TERRY LOYOLA BLOIS TUONG MARILYN THERESA BERTHA ZHAO-HUI OTTO CAROL

dob 1942 1931 1937 1944 1935 1935 1918 1937 1949 1968 1955 1925 1966 1942 1928 1964 1970 1934 1979 1928 1955 1945 1934 1951 1950 1929 1947 1943 1958 1936 1937 1925 1943

date_registered 1963-08-22 1955-06-11 1996-10-04 2012-09-13 1995-05-25 1998-02-26 2012-08-17 2005-07-25 2008-04-21 2001-11-13 2005-06-20 2014-08-07 2006-09-02 2016-11-02 2006-10-06 1991-12-09 1996-10-04 1999-09-27 2017-04-24 1988-07-16 1994-06-30 2000-05-19 2013-02-27 2006-12-07 1998-01-14 1968-10-01 2008-10-01 1968-09-30 2003-10-06 2018-03-23 2000-07-05 1986-08-27 2017-01-20

ssdi_dod
2019-02-24 2019-10-06 2019-10-26 2018-12-11 2019-08-03 2019-05-30 2019-11-20 2018-06-11 2019-03-28 2018-02-22
2019-02-20 2019-11-04 2019-12-06 2018-01-26 2018-03-09 2019-08-27
2019-01-21 2016-11-30 2018-12-03 2019-12-31 2018-08-10
2019-08-10 2019-08-14 2019-11-21
2018-12-03

obit_dod 2019-10-16 2019-03-01 2018-11-03 2019-02-24
2018-12-11 2019-08-03
2019-11-20 2018-06-11 2019-03-28 2018-02-22 2018-05-21 2016-10-18 2019-02-20 2019-11-04
2018-01-26 2018-03-09
2019-08-12 2019-01-21 2016-11-30 2018-12-03
2019-08-30
2019-08-14
2018-12-12 2018-12-03

Exhibit B, Page 316

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 317 of 352 Pageid#: 1220

voter_id 404003891 T 204020589 T 917211883 T 205013396 T 604033988 T 917320392 T 204009776 T 917588484 T
92609318 T 919516683 T 918948719 T 203009776 T 919223790 T 608008866 T 221018073 T 806001456 T 920420721 T 917073841 T 919186651 T 775704368 T 210026279 T 481342273 T 918937362 T 806007616 T 920048202 T 918867279 T 917354710 T 508030116 T 805000355 T 374316263 T 403015533 T 352489141 T 120260344 T

lname

fname MICHAEL MARGARET JAMES ANNIE CHARLES TRACEY DOROTHY CARLA GLEN BETTY GREGORY DOROTHY ELLEN ETHEL ALEXANDER JUNE GEORGETTE GRADY JAMES JAMES RAYMOND PAUL CLARA HARRY TOBY EVELYN CARROLL CLYDE MATTIE CHERYL ALFRED JEFFERY ADRIAN

dob 1940 1938 1936 1931 1943 1971 1923 1952 1957 1930 1966 1928 1953 1937 1937 1926 1925 1924 1930 1963 1935 1927 1939 1920 1934 1932 1935 1934 1924 1956 1927 1957 1962

date_registered 1979-07-02 1973-04-17 2005-06-15 1976-10-01 1967-09-28 2017-02-02 1951-05-15 1996-08-08 2018-08-30 2018-10-11 2000-10-10 1955-03-21 2001-11-13 1968-08-31 1994-09-14 1961-01-31 2006-12-27 1994-02-07 2001-09-17 2008-10-06 1998-08-20 2012-10-10 2000-10-10 1952-09-17 2005-01-04 2000-08-30 1995-10-05 1972-04-20 1985-08-09 2019-04-15 1954-06-25 2016-09-06 2016-10-21

ssdi_dod
2019-12-28 2019-12-27 2019-11-29 2019-10-05 2019-08-30 2019-07-27 2019-05-08 2019-01-17 2018-12-10 2017-12-02 2017-05-24 2016-06-12
2016-09-04 2019-12-17
2019-09-05 2018-04-04 2018-12-14 2019-12-28 2017-09-14
2020-01-24 2020-01-04 2019-12-17 2019-12-15 2019-11-26 2019-11-03 2019-10-16 2019-10-14

obit_dod 2019-10-14
2019-11-29 2019-10-05 2019-08-30 2019-07-27 2019-05-08 2019-01-17 2018-12-10 2017-12-02 2017-05-24 2016-06-12 2019-08-15 2017-01-02
2019-05-29 2019-09-05
2018-12-14
2018-01-12 2019-08-21
2019-12-17 2019-12-15 2019-11-26 2019-11-03 2019-10-18 2019-10-14

Exhibit B, Page 317

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 318 of 352 Pageid#: 1221

voter_id 917030991 T 919063233 T 902009098 T
23000508 T 918487735 T 918587937 T
24001818 T 126002990 T 201018006 T 606033336 T 501000227 T 507017039 T 222014672 T 301030565 T 917185636 T 405029830 T 107019587 T 918509873 T 607014442 T 304025984 T 802017978 T 918834447 T 204020590 T 225007419 T 223003897 T 704000255 T 406017535 T 917392056 T 407024667 T 917020364 T 332616308 T 918874832 T 804997790 T

lname

fname RICHARD ELIZABETH MARGARET HORACE SHIRLEY NELSON ERNEST ROSIE JACK MARY BETTY BETTY SHIRLEY LEE MADELYN DEIDRE ROSLYN BETTY BRENDA NORA ARCHELAUS MARION JOSEPH LOIS CARLTON BILLY LYNN JOHN LINDA GEORGE ALMA JAMES ALBERT HESTER

dob 1943 1937 1932 1942 1938 1952 1937 1920 1958 1938 1947 1935 1932 1947 1947 1942 1928 1949 1942 1936 1942 1945 1927 1928 1933 1930 1928 1959 1942 1916 1937 1972 1931

date_registered 2001-07-23 2001-03-19 1984-03-31 1989-10-07 2006-05-10 1999-09-20 1966-04-28 1952-05-07 2002-12-26 1964-08-27 1985-03-05 1964-10-03 1997-02-19 1976-10-02 1994-09-24 1980-08-13 1976-04-27 1999-05-25 1969-12-04 2001-11-15 1972-03-25 2000-07-28 1980-10-03 1971-10-02 1984-03-10 1971-10-02 1975-04-03 1996-02-03 2003-10-06 1993-09-13 2011-11-28 2000-08-31 2008-09-16

ssdi_dod 2019-09-15 2019-09-09 2019-08-26 2019-07-29 2019-04-22 2019-01-31 2019-01-20 2017-10-30 2016-11-09 2016-07-17
2019-08-19 2019-09-20 2019-06-06 2017-06-17
2019-10-22 2019-11-12
1995-05-27 2017-11-20 2018-11-02 2018-12-26 2018-12-21 2019-11-20 2019-08-11 2018-12-10 2018-01-30

obit_dod 2019-09-15
2019-08-26 2019-07-29 2019-04-22 2019-01-31 2019-01-19 2017-10-30 2016-11-09 2016-07-17 2019-10-18 2019-09-29 2018-12-06 2018-05-16 2016-07-11 2019-08-19
2019-06-06 2017-06-17 2019-08-07
2019-11-12 2019-02-14
2017-11-20
2018-12-26 2018-12-21 2019-11-20 2019-08-11 2018-12-10
2019-09-09

Exhibit B, Page 318

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 319 of 352 Pageid#: 1222

voter_id

lname

203023783 T

917018041 T

733999664 T

917478221 T

917178490 T

404004426 T

6003444 T

917656032 U

605011805 U

920246505 U

22004935 U

920276695 U

222009196 U

918216555 U

714013618 U

304026575 U

108019250 U

920193236 U

917553500 U

53280053 U

412028745 U

205007504 U

608019769 U

101012471 U

810004996 U

759806015 U

213005063 V

918557098 V

343519606 V

306026575 V

42360391 V

430419475 V

178520908 V

fname BETTY JOHN LORRAINE HAZEL ORMAN BRENDA CLEVELAND SAM BERTRAM WILLIAM IRENE LARRY MILDRED RANDOLPH SADIE LUONG OLGA ARTHUR ABDUL WILLIAM DOROTHY MABEL JAMES LOUISE ANTOINETTE FLOYD HENRY USMAN JANICE ANTHONY EDWARD MARTA HEINZ

dob 1935 1953 1988 1939 1928 1947 1943 1945 1924 1925 1937 1947 1928 1938 1945 1927 1923 1934 1926 1945 1917 1933 1930 1939 1945 1947 1929 1929 1944 1923 1930 1934 1926

date_registered 1979-01-16 1993-09-13 2008-10-06 1996-04-29 2001-09-05 1977-12-28 1968-10-02 1997-08-05 1984-05-04 2006-02-02 1963-01-16 2006-04-03 2002-11-06 1998-03-17 2000-05-11 2000-04-19 1969-10-04 2005-10-11 1996-07-03 2017-11-21 1988-08-30 1957-06-08 1995-08-15 1972-10-07 2003-04-22 2012-06-14 1976-10-02 1999-08-09 2009-11-05 1976-08-25 2016-02-08 2011-04-14 2007-06-28

ssdi_dod 2019-10-02 2019-04-07 2019-03-17 2019-11-21 2018-01-22 2018-02-27
2019-12-30
2018-12-30 2018-01-26 2019-08-19 2018-12-31 2019-02-03 2018-11-08 2019-05-30 2018-12-01
2017-11-02
2016-09-06 2019-10-11

obit_dod 2017-06-17
2019-04-07 2019-03-17 2019-11-21 2019-06-14
2017-07-14 2019-08-11
2019-10-03 2016-07-14 2018-12-30
2019-09-05
2019-09-18 2019-05-30
2016-06-02 2017-01-30 2017-08-10 2019-10-31
2018-05-28 2015-03-27 2016-09-06 2016-06-08 2019-10-11

Exhibit B, Page 319

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 320 of 352 Pageid#: 1223

voter_id

lname

920315667 V

221945685 V

919722166 V

109008415 V

391757572 V

232018611 V

11543586 V

502026418 V

919216469 V

405022051 V

209001034 V

531679888 V

703014054 V

917036276 V

436255415 V

918701894 V

602015019 V

508009509 V

104030961 V

223000208 V

607030686 V

920091678 V

605033621 V

470415476 V

206001117 V

920270081 V

917354463 V

918568183 V

919813518 V

919042495 V

310041785 V

2001925 V

874614120 V

fname CHHEANG GRACE ELEUSIPA RUBY SARAH RAYMOND JOHN JOHN WOODROW ROBERT HAROLD DAVID JOSEPH REGINA JIM PHONG CLYDE AUDREY KENNETH MONA ALVIN DOROTHY ROY ELIZABETH BURTON WILLIAM SHIRLEY MARILYN VIRGIL ANDRAS NELLIE MARY HILARIO

dob 1952 1927 1961 1926 1932 1948 1936 1926 1941 1926 1944 1938 1955 1972 1931 1937 1924 1940 1949 1928 1936 1944 1940 1932 1944 1974 1944 1941 1942 1926 1940 1925 1959

date_registered 2006-06-22 2010-07-29 2004-03-27 1980-09-17 2016-03-18 2014-07-02 2014-01-16 1978-08-02 2001-10-09 1978-09-26 1965-09-24 2012-02-08 1987-09-30 1999-08-20 2016-09-12 2000-03-01 1964-09-11 1962-05-03 1992-10-02 1983-10-03 1966-10-04 2005-04-26 1967-08-24 2012-07-25 2002-10-07 2006-03-22 1995-10-06 2005-04-21 2004-07-12 2001-02-16 2004-11-03 1951-05-05 2011-04-01

ssdi_dod 2019-10-03 2019-11-19 2019-11-09 2018-12-23 2019-11-18
2018-09-18 2017-11-29 2019-11-28 2018-07-05 2018-02-07 2016-08-19 2017-08-10 2019-08-13
2019-08-24 2017-10-30 2017-12-23 2019-10-13 2019-11-20 2020-01-01 2019-10-08 2017-10-17 2019-12-18 2019-06-16 2018-08-20
2019-03-26 2018-08-31 2018-12-03
2019-04-18

obit_dod 2019-10-03
2019-11-09 2018-12-23 2019-11-18 2016-04-05 2018-09-18 2017-11-29 2019-11-28
2018-02-07
2019-08-13 2018-03-12 2019-08-24 2017-10-30 2017-12-23 2019-10-13 2019-11-20
2019-10-08
2019-06-16
2019-08-13 2018-02-28 2019-03-26
2018-12-03 2018-12-15

Exhibit B, Page 320

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 321 of 352 Pageid#: 1224

voter_id

lname

429811582 V

208008725 V

917152802 V

918594410 V

28015283 V

408013145 V

917271277 V

221001480 V

809005254 V

406010485 V

29001948 V

801012394 V

917401179 V

144559562 V

227001728 V

229017695 V

26006777 V

920071716 V

918969446 V

709361245 V

281411612 V

2001926 V

405021447 V

906010920 V

223010432 V

403017808 V

669446258 V

157266063 V

917862108 V

407023596 V

29007105 V

221016659 V

658354452 V

fname DOREEN JAMES BARRY ALMEDA JUANITA JAMES RALPH EVELYN BERNICE BERNICE ANNIE VIRGINIA ALICE MAXIMINA RENDY HOWARD CHARLES LEONCIO SALOMON PETRONILA ELEUTERIO LAURA JOHN ROSETTA EDWARD ALICE FRANKLIN THIRUNILAYI BENJAMIN KATHERINE VICTOR FELIXBERTO ROBERT

dob 1951 1918 1934 1927 1941 1929 1933 1929 1936 1942 1929 1942 1928 1941 1941 1933 1941 1956 1953 1933 1933 1934 1934 1946 1932 1947 1947 1934 1946 1936 1931 1943 1941

date_registered 2013-04-11 1987-10-02 1994-08-30 1999-09-24 1984-01-31 1955-03-14 1995-04-20 1992-03-25 1965-09-20 2003-09-10 1972-09-26 1963-11-29 2000-01-24 2013-11-21 1984-09-20 1988-07-26 1984-05-26 2005-03-17 2001-10-05 2008-11-05 2014-04-07 1964-03-26 1964-05-14 1983-10-08 2002-11-06 2000-01-04 2007-06-12 2014-11-14 1997-11-05 1979-10-06 1991-04-17 1998-11-04 2013-01-29

ssdi_dod 2018-12-15 2019-12-13
2019-12-11 2019-10-25 2019-09-23 2018-05-29 2017-11-29
2019-09-13 2014-06-01 2007-01-01 2016-10-06 2017-06-06 2019-09-03
2019-12-11 2019-11-13
2019-09-08
2018-12-26 2019-12-06

obit_dod
2019-12-13 2019-08-20 2019-12-11 2019-10-25 2019-09-23 2018-05-29 2017-11-29 2019-10-31 2019-10-29 2019-05-15 2018-12-03 2019-08-10 2018-08-21 2016-04-19 2017-06-21 2019-09-13
2016-10-06
2019-09-03 2018-12-10 2019-12-11
2019-09-29 2019-09-27
2019-04-08 2018-12-26 2019-12-06 2019-10-04 2019-10-15

Exhibit B, Page 321

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 322 of 352 Pageid#: 1225

voter_id

lname

5004664 V

919852960 V

222022618 V

610028265 V

604032571 V

918192837 V

401004276 V

101006266 V

919368583 V

164993947 V

918378014 V

127013243 V

917444657 V

604014807 V

799357807 V

306021844 V

33351675 V

610005602 V

105840950 V

917863812 V

802002447 V

302098972 V

905006379 V

803010794 V

917698909 V

301051207 V

603028267 V

901019298 V

920066764 V

106015301 V

314931392 V

588574975 V

302021371 V

fname ROY ROMEO ALICE MARY GERTRUDE LEOTA RAY MARY LATOYA DOUGLAS MELINDA HELEN GRADY JAY CRAIG DALLAS AGRIPOLDO DENNIS RANDALL ARMETRIA ROBERT ERIC THEODORE SHEILA EDWARD BONNIE JOHN NORFLEET COLIN SHARON JANE ROBERT JEAN

dob 1930 1943 1905 1946 1949 1942 1932 1933 1984 1920 1980 1924 1958 1943 1934 1933 1933 1966 1930 1939 1932 1964 1935 1935 1920 1943 1948 1945 1984 1947 1932 1942 1919

date_registered 1984-08-12 2004-08-25 1989-10-07 1991-09-23 1999-02-20 2005-06-17 1975-09-29 1973-10-06 2012-06-14 2010-06-16 1999-04-26 1958-09-20 1996-04-04 1983-04-01 2008-03-07 2002-12-31 2008-09-12 2004-08-04 2010-10-01 1996-12-16 1998-09-25 2016-08-01 1966-06-02 1998-06-26 1996-09-28 1987-08-10 1983-10-08 1971-04-28 2005-03-09 1998-03-06 2009-12-07 2008-03-06 1960-10-06

ssdi_dod 2019-09-05 2019-10-01 2003-12-05 2020-01-02 2019-12-01 2018-02-14
2016-10-17 2018-10-23 2019-11-06 2019-11-04 2019-08-08 2013-10-30
2018-02-11
2019-06-13 2018-12-20
2019-12-13
2019-05-16 2018-12-17 2019-08-30 2019-10-12 2019-11-24 2019-11-02 2019-11-21 2017-12-20
2018-03-05 2019-11-20 2017-04-19

obit_dod 2019-09-05 2019-10-01
2018-02-14 2019-09-01 2016-10-17 2018-10-23 2019-11-06 2019-11-04 2019-08-08 2013-10-30 2019-10-01
2018-03-24
2018-12-20 2018-12-30 2019-12-13 2019-08-10
2018-12-17 2019-08-30
2019-11-02 2019-11-21
2017-01-03 2018-03-05 2019-11-20 2017-04-19

Exhibit B, Page 322

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 323 of 352 Pageid#: 1226

voter_id

lname

205018406 V

307031339 V

917405785 V

919045706 V

917324203 V

224022619 V

109192450 V

918906861 V

917384509 V

22021067 V

108716868 V

917060135 V

918567138 V

919598581 V

104027490 W

917429698 W

301000252 W

406003400 W

305019842 W

917437518 W

909023679 W

414030604 W

402027362 W

736003580 W

205004835 W

227012076 W

917155488 W

308044271 W

307030366 W

313021372 W

8005669 W

507030397 W

907008896 W

fname ELLA MARGARET LEON THOMAS ARTHUR GRACE ELIZABETH ON KARON JERRELL SHONETT RUDOLF QUYET ANN THIEN EDNA ROSA CAROLE SHELIA MARGARET ALLEN HENRY DUANE HELEN LEROY CURTIS FAYE GINGER ROBERT DOROTHY MICHAEL REGINALD LYLE STANLEY

dob 1922 1919 1943 1941 1969 1930 1934 1941 1935 1945 1947 1934 1931 1956 1929 1952 1937 1970 1921 1941 1940 1956 1920 1951 1933 1948 1947 1945 1923 1946 1933 1944 1937

date_registered 1971-10-02 1960-08-27 1996-03-13 2001-02-22 1999-02-03 1959-06-06 2015-04-08 2000-09-27 1995-12-14 1994-11-09 2017-04-17 1996-10-05 1999-08-24 2003-09-24 1955-05-03 1996-03-14 2002-03-19 1988-02-02 1964-09-23 2005-04-21 1980-04-05 1985-09-07 1959-06-11 2008-10-06 1968-10-01 2005-10-11 2004-03-31 1984-09-26 1968-07-31 1992-10-01 1991-10-05 1992-09-25 1987-09-19

ssdi_dod
2016-12-14 2020-01-17 2019-09-22 2019-09-28 2019-10-23
2018-08-26 2017-03-01 2017-08-04
2019-10-12 2019-09-16 2019-09-12 2019-12-24 2019-10-11
2019-11-03 2019-12-29 2019-12-19 2019-12-07 2019-07-13 2019-04-02 2018-12-15 2018-12-10 2016-09-29 2018-12-06 2019-10-25
2018-08-08
2020-01-16

obit_dod 2019-09-20
2019-09-22 2019-09-28 2019-10-23 2019-10-18
2017-03-01 2017-08-04 2018-12-24 2019-10-12 2019-09-16
2019-12-24 2019-10-11 2019-08-02 2019-11-03
2019-12-07
2019-04-02
2018-12-10
2018-12-06 2019-10-25 2018-12-23
2018-12-26 2018-12-14

Exhibit B, Page 323

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 324 of 352 Pageid#: 1227

voter_id

lname

510002291 W

109009635 W

487869415 W

629155330 W

389650658 W

920414639 W

907015236 W

233018003 W

601007531 W

712022925 W

165276783 W

906025067 W

919988836 W

903005158 W

209021022 W

506002292 W

712008102 W

920009757 W

604034427 W

360611100 W

506004450 W

919361833 W

320016686 W

207010042 W

918565296 W

615023608 W

920027496 W

918285006 W

601014809 W

290863716 W

27019866 W

917520220 W

920235309 W

fname THOMAS ANN EDWARD GLORIA RICHARD CLAUS ERNEST ROBERT MICHAEL BETTY SCOTT NATHAN MARIA JAMES MARGARET HARRY EDITH NANCY ELIZABETH JESUEAG VICTOR ANNA ROSEZENIA DANIEL DEBRA WILBERT ROBERT NATALENE HAROLD MITCHELL DENNIS LIZZIE LUCY MILDRED

dob 1947 1921 1936 1926 1964 1937 1927 1942 1944 1938 1963 1936 1941 1924 1946 1928 1936 1939 1948 1947 1931 1924 1945 1947 1956 1931 1940 1933 1939 1939 1940 1933 1940

date_registered 1988-07-12 1952-04-21 2009-05-11 2016-07-07 2016-10-17 2006-12-11 1976-04-01 1997-01-28 1992-04-06 1984-10-04 2015-10-13 1991-07-25 2004-10-04 1971-10-02 1988-07-23 2002-07-21 1992-10-02 2004-11-03 2000-10-06 2008-10-06 2004-09-13 2002-07-22 2018-09-10 1980-02-13 1999-08-23 1988-10-05 2004-11-29 1998-06-18 1980-10-02 2008-09-24 1981-10-03 1998-08-27 2005-12-10

ssdi_dod 2019-11-11 2019-10-11 2019-09-02 2018-12-17 2018-07-09 2017-11-10 2019-11-27 2019-12-04 2019-11-02
2019-03-21 2019-11-20 2019-10-13 2019-10-15 2019-12-26 2019-09-17 2019-11-03 2020-01-24 2020-01-22 2019-12-28 2019-12-16 2019-12-10 2019-12-01 2019-12-01 2019-11-21 2019-11-12 2019-11-04 2019-11-01 2019-10-22 2019-10-08 2019-10-04 2019-07-12 2019-01-28

obit_dod 2019-11-11
2019-09-09
2018-07-09
2019-11-27 2019-12-04 2019-11-02 2018-12-19 2019-03-21 2019-11-20 2019-10-13 2019-10-15
2019-09-17 2019-11-03
2019-12-16 2019-12-10 2019-12-01 2019-12-01 2019-11-21 2019-11-12 2019-11-04
2019-10-22 2019-10-08 2019-10-04 2019-07-12 2019-01-28

Exhibit B, Page 324

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 325 of 352 Pageid#: 1228

voter_id

lname

917579026 W

917010960 W

810007488 W

602001771 W

331475575 W

918483005 W

920218935 W

448707894 W

917691468 W

917012400 W

103016346 W

229001730 W

801014233 W

807011002 W

704004461 W

603004662 W

917825980 W

919500213 W

603026433 W

222906897 W

504006157 W

213025710 W

141535711 W

47824534 W

122012745 W

303005621 W

919382765 W

305028820 W

802006791 W

501027119 W

152950939 W

604000917 W

918888229 W

fname FRANCES SAMUEL DON MARGARET EULA HELEN EMILY HARRY MARY MARY WILLIAM MARY MARY WARREN JOHN WILLIAM JULIE CATHERINE JOHNNY HILDA LUCILE STEVEN ARTHUR SHIRLEY MARIE BETTYE JAMES KATHRYN ROSE DAVID SUSAN LOUISE WILLIAM

dob 1944 1941 1950 1948 1939 1947 1941 1959 1952 1965 1929 1930 1943 1942 1938 1928 1936 1930 1940 1942 1930 1961 1945 1934 1942 1940 1949 1942 1954 1970 1963 1930 1936

date_registered 1996-08-02 1993-08-25 2004-09-08 1982-09-09 2008-10-02 1999-04-20 2005-11-09 2015-04-29 2007-03-14 1993-08-28 1959-12-02 1990-11-07 1992-09-26 1984-09-26 2005-03-24 1950-07-07 1996-11-06 2004-02-11 1966-10-08 2008-10-06 1964-10-03 1992-04-22 2014-05-08 2016-08-11 1997-11-24 2003-08-18 2002-08-26 1984-09-20 1984-09-08 1992-02-24 2014-10-14 1999-11-10 2000-09-13

ssdi_dod 2018-12-24 2018-12-20 2018-12-09 2018-02-07 2018-01-17 2017-12-18 2017-09-11 2017-04-02 2015-12-23 2013-06-25 2010-08-03 2000-05-23
2020-01-08 2019-11-20 2020-01-12 2019-12-25 2019-10-14 2019-10-02 2018-12-10 2018-02-24 2018-01-26
2018-12-07 2017-08-24 2019-08-07 2018-12-14 2016-11-23 2014-10-03

obit_dod 2018-12-24 2018-12-20 2018-12-09 2018-02-07
2017-12-18
2015-12-23
2010-08-03
2019-10-05 2019-09-11 2018-12-30
2019-11-20
2019-10-01 2018-12-10 2018-02-24 2018-01-26 2019-09-01 2015-11-13
2019-08-07 2018-12-14 2016-11-23
2018-01-10

Exhibit B, Page 325

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 326 of 352 Pageid#: 1229

voter_id

lname

607013716 W

919850826 W

918365127 W

917597895 W

308002538 W

807006950 W

308043096 W

918462596 W

8003559 W

43463183 W

516019585 W

806010798 W

223002780 W

2003447 W

409029394 W

601002813 W

13006798 W

708016675 W

202002394 W

904000288 W

224018086 W

86859548 W

308032169 W

206019923 W

811015251 W

506019697 W

919803125 W

302031988 W

606015880 W

508019878 W

410028000 W

802010799 W

374366811 W

fname LOUIS JAMES JANET KENNETH TERRENCE ELMER LORNA NORMA JOYCE CORNELL JAMES SHERRY DOROTHY GLORIA JOHNNIE MILDRED MARY BOBBY JOE VICTOR GLADYS JANE LIPING SUSIE BONNIE CYNTHIA FRANCES JOHN HENRY JOYCE BARBARA DAVID NANCY CHARLES

dob 1935 1942 1943 1939 1937 1928 1940 1937 1938 1946 1927 1945 1925 1941 1927 1941 1934 1928 1963 1924 1930 1973 1925 1943 1925 1933 1929 1923 1936 1941 1947 1931 1966

date_registered 1964-01-27 2004-08-23 1998-10-05 1998-03-19 2001-08-29 1952-05-26 1989-10-07 1999-03-18 1966-10-06 2012-09-19 1990-06-18 1987-08-29 1952-09-26 2000-10-06 1960-10-08 1964-10-02 1964-01-10 1951-10-08 1981-09-24 1964-03-24 1984-10-06 2014-11-20 1963-05-04 1972-09-08 1989-10-04 1959-03-03 2004-07-01 1964-04-27 1969-05-12 1976-10-02 1995-09-18 2002-07-11 2007-06-13

ssdi_dod
2019-12-16 2020-01-08 2020-01-03 2018-12-17
2018-12-19 2020-01-30 2020-01-18 2019-12-01 2019-11-12 2019-11-05 2019-11-04 2019-10-22 2019-03-28 2018-12-25 2019-10-26 2019-05-01 2015-11-26 2019-12-16 2018-10-29 2019-10-18 2018-12-21 2019-12-25 2019-12-10 2019-11-04 2019-10-03 2019-09-01 2019-08-11 2018-01-02 2017-09-26 2017-01-03

obit_dod 2012-02-21 2019-08-27
2018-12-17 2016-08-06
2019-11-12 2019-11-05 2019-11-04
2019-03-28 2018-12-25 2019-10-26 2019-05-01 2015-11-26
2019-10-18
2019-12-25 2019-12-10 2019-11-04
2019-09-01

Exhibit B, Page 326

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 327 of 352 Pageid#: 1230

voter_id

lname

205017122 W

406016546 W

303028250 W

804006791 W

505010060 W

506010060 W

509009120 W

707002039 W

310032501 W

167989284 W

917877588 W

917234759 W

129199418 W

32936656 W

917863482 W

229009469 W

125018082 W

917348945 W

501001420 W

406016308 W

31014361 W

919537854 W

917910230 W

801006936 W

918209006 W

918896167 W

917405829 W

22469160 W

876719578 W

504007926 W

877891944 W

919566699 W

509027120 W

fname DORIS SYBIL PEGGY GAIL CLYDE LELA LUTHER ROBERT ARTHUR ANN CYNTHIA EDWARD BETTIE ARNOLD ALEXANDER FRED ALMA LAURA FREDA JEAN DOROTHY BARBARA MARY ANNETTE LEWIS MARY WALTER CHARLIE TRINA ALMA GLORIA SCOTT AUGUSTA

dob 1939 1934 1931 1940 1928 1940 1941 1927 1937 1922 1960 1952 1940 1956 1941 1925 1920 1938 1941 1929 1937 1948 1944 1930 1935 1960 1948 1954 1976 1929 1951 1973 1927

date_registered 1987-10-03 1984-10-05 1968-09-12 1978-10-07 1967-10-07 1967-10-07 1963-10-03 1987-09-18 2007-03-19 2017-09-11 2000-03-06 1997-05-02 2011-04-19 2008-09-03 1997-01-08 1967-06-10 2005-04-20 1995-10-03 2000-03-14 1999-01-27 1991-04-10 2003-06-12 1997-02-24 1964-10-03 1998-03-06 2000-09-21 1996-03-14 2008-03-17 2008-07-11 1979-09-13 2008-09-29 2003-08-04 1988-02-03

ssdi_dod 2015-11-12
2019-02-10 2018-06-01 2019-06-17 2019-10-16 2019-10-27 2019-08-07 2017-03-02 2020-01-16 2019-08-03 2018-08-17 2018-03-10 2017-11-18 2016-06-30
2019-11-02
2018-12-15 2019-11-22 2019-10-20 2019-10-09 2019-09-25 2019-08-25 2019-06-28 2019-04-14 2018-04-04 2018-01-28 2018-01-10 2017-09-06

obit_dod
2019-10-05 2019-09-06 2019-08-22 2019-02-10 2018-06-01 2019-06-17 2019-10-16
2019-08-07
2019-08-03 2018-08-17 2018-03-10 2017-11-17 2016-06-30 2019-09-06 2018-12-15 2019-11-02 2016-10-01
2019-11-22 2019-10-20 2019-10-09 2019-09-25 2019-08-25 2019-06-28
2018-04-04
2018-01-10

Exhibit B, Page 327

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 328 of 352 Pageid#: 1231

voter_id

lname

605008720 W

211215177 W

68228492 W

743174943 W

507028942 W

216925197 W

290042545 W

515030321 W

609017976 W

918824285 W

231019009 W

918113710 W

503003597 W

176161366 W

226014353 W

920210306 W

515016175 W

602037855 W

917388888 W

918125712 W

605015391 W

121012331 W

918893786 W

859501897 W

905003016 W

301006787 W

917754340 W

105009263 W

361594623 W

3045999 W

908006386 W

402026544 W

710806339 W

fname GEORGE KATIE LEROY ROBERTA JEFFERY RUTH KAPSU LEMUEL PEGGIE JANE KEARY ROBERT DONALD DAVID ROBERT SUE ALICE ROBERT KWI BOBBY GLENN ELIZABETH DONNA DEBORAH ELIZA WANDA ANNE RUTH WILLIE WILLIAM MYRTLE ALICE RICHARD

dob 1945 1941 1935 1931 1959 1942 1944 1940 1931 1937 1946 1933 1927 1951 1929 1932 1931 1946 1951 1933 1940 1949 1968 1964 1920 1937 1939 1921 1931 1952 1918 1941 1936

date_registered 1992-08-14 2013-04-11 2008-09-29 2016-10-14 1996-04-15 2016-10-21 2016-03-30 1991-09-21 2004-05-10 2005-11-29 1988-08-27 1997-10-04 1955-05-14 2018-10-12 1951-05-09 2005-11-15 1965-09-18 2006-08-08 1996-11-21 1997-10-03 2000-05-11 1976-09-25 2000-09-20 2016-04-05 1952-04-26 1988-06-15 1996-10-07 1954-03-10 2016-06-29 2012-10-15 2006-11-28 1999-06-10 2016-05-26

ssdi_dod
2019-10-19 2020-01-29 2019-11-21 2018-10-13 2019-12-12 2019-12-07 2019-11-28 2019-08-12 2018-03-01 2018-02-08
2019-09-13
2020-01-06 2019-12-08 2019-11-27 2019-11-04 2019-08-29 2019-03-13 2018-12-13 2018-07-21 2018-02-21 2016-12-10 2020-01-07 2019-11-04 2019-09-22 2019-09-12 2019-06-16 2019-04-05 2018-08-17

obit_dod 2019-09-15 2019-08-10
2019-11-20
2019-11-28 2019-08-12 2018-03-01 2018-02-08 2018-11-12 2019-09-13 2019-08-28
2019-11-27
2019-08-29 2019-03-13
2018-07-21 2018-02-21
2019-09-22 2019-09-12 2019-06-16 2019-04-05 2018-08-17 2018-01-09

Exhibit B, Page 328

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 329 of 352 Pageid#: 1232

voter_id

lname

603011814 W

918108452 W

918414074 W

918788444 W

209023787 W

920190968 W

107005287 W

24013559 W

806001129 W

308017027 W

101022000 W

917479439 W

27004434 W

300291289 W

606024195 W

104012819 W

507001645 W

919389009 W

106026834 W

606038151 W

306040513 W

708001702 W

394481358 W

368458852 W

110022000 W

920403898 W

612004664 W

538367971 W

917666590 W

304005146 W

130178087 W

412017160 W

201229176 W

fname EDNA M DORIS RALPH JAMES FLOYD PEGGY JAMES LOYCE ANNA CAREY RUTH REBECCA NANCY PAUL PATRICIA RICHARD EDWARD ZEFRA DON BETTY WILLIAM MARGARET HARRIETT CAROLYN JAMES DEBRA CALLIE MABLE JOHN CYNTHIA MARLIN JOSEPHINE PATRICK

dob 1923 1926 1953 1950 1941 1938 1942 1925 1933 1935 1930 1947 1942 1925 1930 1945 1937 1927 1946 1925 1946 1949 1938 1946 1928 1966 1925 1948 1945 1947 1948 1938 1945

date_registered 1976-05-03 1997-10-01 1999-01-15 2000-05-23 1996-11-18 2005-10-11 2005-09-09 1954-09-29 1998-11-30 1976-09-29 1975-03-20 2016-03-09 2006-03-10 2014-05-02 1954-05-14 1968-09-27 1960-10-08 2002-09-06 1982-05-05 1993-02-17 2005-06-30 1999-10-04 2007-06-27 2018-02-14 1987-02-20 2006-11-21 1989-09-21 2012-09-27 1996-09-18 2003-07-22 2011-11-11 1989-03-20 2018-10-15

ssdi_dod 2019-12-26 2015-03-29 2019-09-13 2018-12-06
2020-01-07 2018-12-16 2008-05-23
2019-02-09 2019-12-11 2019-10-22 2019-06-01 2016-05-09 2001-09-10 2019-12-20 2019-11-24 2019-10-16 2019-10-13 2019-09-03 2019-08-30 2019-07-27 2019-07-26 2019-01-28 2018-12-13 2018-06-16 2018-06-01 2017-12-14 2017-09-15

obit_dod
2019-09-13
2019-10-28
2018-12-16 2008-05-23 2018-12-04 2019-02-09 2019-12-11 2019-10-22 2019-06-01
2001-09-10 2019-12-20 2019-11-24 2019-10-16 2019-10-13 2019-09-03 2019-08-30 2019-07-27 2019-07-26 2019-01-28 2018-12-13 2018-06-16
2017-09-15 2019-10-31 2019-10-08 2019-08-02 2018-12-17

Exhibit B, Page 329

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 330 of 352 Pageid#: 1233

voter_id

lname

919652546 W

373578394 W

26620862 W

110024124 W

919355270 W

7325902 W

225019011 W

606021122 W

26004435 W

605002936 W

202024472 W

264177759 W

226004404 W

507025332 W

107005984 W

964148750 W

806019754 W

659871580 W

224007140 W

917391276 W

708019197 W

703020105 W

348250699 W

409007387 W

407009043 W

918153044 W

602015885 W

904021760 W

306027679 W

710006257 W

920164922 W

918875833 W

704013622 W

fname DONALD NANA COOPER DOUGLAS SAMUEL LEO KENNETH WREFORD DONALD HILDA BEATRICE MAJOR MARCELLE MAURICE RETA JACQUELINE MARY URSULA FRANKLIN JEROME PAULINE DAVID STEPHEN GEORGE EARLEN CATHERINE ARNOLD CARL CHARLES BETH CECIL JAMES BETTY JO

dob 1932 1924 1944 1947 1964 1938 1943 1925 1940 1925 1938 1930 1918 1934 1942 1919 1954 1949 1935 1944 1929 1934 1933 1925 1942 1951 1938 1927 1929 1941 1933 1951 1929

date_registered 2003-12-22 2018-10-09 2014-09-03 2002-03-07 2004-05-10 2017-02-14 1992-10-03 1947-04-03 2001-01-09 1946-04-30 1976-09-14 2018-04-13 1966-09-29 1972-10-07 1975-01-15 2008-09-02 1984-10-06 2008-05-02 1995-08-02 2002-08-30 1968-09-10 1980-09-20 2012-05-16 1978-10-02 1985-09-07 1997-11-05 1979-09-28 1956-10-04 1972-01-20 1992-09-26 2005-09-13 2000-09-01 1951-05-21

ssdi_dod
2019-10-07 2019-03-09 2018-01-22 2019-08-14
2020-01-15 2018-11-08 2019-11-25 2019-11-12 2016-09-16
2018-08-28 2019-10-08 2018-05-03 2019-10-30
2019-12-24
2019-10-17 2019-10-13 2019-11-05 2019-11-03 2019-09-16 2019-09-05 2018-04-29 2018-03-14

obit_dod 2018-10-29
2018-01-22
2019-05-11 2017-12-17 2019-10-11 2019-08-11
2019-11-25
2016-09-16 2018-10-31
2019-10-08
2019-10-30 2015-12-29
2018-12-15 2017-03-05 2018-12-17 2019-10-17 2019-10-13 2019-11-05
2019-09-16 2019-09-05 2018-04-29 2018-03-14 2018-12-18

Exhibit B, Page 330

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 331 of 352 Pageid#: 1234

voter_id

lname

531270997 W

903024013 W

126018339 W

601029387 W

918577312 W

605010097 W

606013436 W

919717398 W

918666022 W

917675784 W

602026971 W

607004347 W

966107336 W

917808726 W

501021371 W

209018418 W

409030124 W

812021063 W

919173456 W

604012219 W

16225802 W

804021198 W

307012658 W

919323242 W

68690715 W

209022611 W

708015432 W

401008817 W

223025176 W

715816743 W

202015041 W

441832112 W

806017234 W

fname JARRELL ETHEL LOIS FREDDIE ROBERT LARRY LOIS THEREON EDWARD LIONEL BETTY HARRY MARY WILLIAM CHARLES SHIRLEY EUDAMA JOSEPH DAVID JOHNNIE ERIKA RICHARD MICHAEL MARLEEN ROBERT SHIRLEY DONNIE PATRICIA SANDRA RICHARD WILLIE ANNIE ADELINE

dob 1951 1926 1931 1948 1929 1936 1939 1939 1930 1942 1940 1944 1949 1929 1932 1947 1934 1935 1964 1937 1932 1940 1939 1941 1937 1934 1947 1940 1945 1930 1928 1933 1936

date_registered 2017-08-02 1968-03-13 1976-01-01 1970-10-03 1999-08-18 1985-11-18 1971-08-12 2006-07-18 2000-01-14 2000-01-31 1984-03-31 1975-02-07 2007-09-11 1998-06-24 1984-10-04 1996-05-10 1983-05-25 1992-08-30 2001-08-30 1984-10-06 2015-12-09 1991-03-22 1987-06-13 2002-05-13 2017-10-16 1993-10-02 1979-08-18 1999-08-09 1992-10-03 2018-12-27 1956-09-11 2017-01-31 1996-08-16

ssdi_dod 2019-06-12 2018-02-24 2019-11-19 2011-01-12 2019-02-14 2019-09-07 2020-01-05 2019-11-02 2019-10-04 2019-10-01 2019-09-22 2019-08-06 2019-07-16 2018-12-31 2018-12-31 2018-12-22 2018-06-05 2019-11-04 2018-01-02 2019-08-02 2019-06-11 2016-06-30 2019-12-21
2018-05-03 2020-01-18 2020-01-22 2020-01-07 2019-11-08 2019-09-29 2019-09-27 2019-09-16 2018-12-25

obit_dod
2019-11-19 2011-01-12 2019-02-14 2019-09-07 2019-11-02
2019-09-22 2019-08-06 2018-12-31
2019-11-04 2018-01-04
2016-06-30 2019-01-03 2018-05-03
2019-11-01 2019-09-29 2019-09-25 2018-12-25

Exhibit B, Page 331

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 332 of 352 Pageid#: 1235

voter_id

lname

902004892 W

885221762 W

918940473 W

212013702 W

88512747 W

123006630 W

309009579 W

918699376 W

918075346 W

101019931 W

763888110 W

917156429 W

25007111 W

225006562 W

105024917 W

304008460 W

112653629 W

108030099 W

304013001 W

505006614 W

901011254 W

507005035 W

603024549 W

115259044 W

406020199 W

601360903 W

489874661 W

230169638 W

608015393 W

920033802 W

304006148 W

409022058 W

102926405 W

fname BERNARD EDWARD RUTH ROVA DOROTHY DOROTHY LEON DANIEL AGNES EDGAR EMILIA LOUIS MICHEAL FRANK TIMOTHY ALDA JACK JOHN AURELIA CARL PEDETHER BEVERLY CHARLES LAWRENCE DONNA VINCENT GRADY GEORGE DOROTHY CHARLES JAMES CLEVELAND PHYLLIS

dob 1929 1955 1924 1945 1929 1925 1934 1928 1945 1934 1920 1953 1938 1941 1960 1926 1950 1938 1920 1923 1938 1940 1939 1948 1946 1969 1950 1954 1922 1956 1962 1932 1943

date_registered 1964-07-15 2008-10-01 2000-10-10 1991-09-26 2010-10-12 1972-02-24 2005-11-28 2000-03-01 1997-08-28 1964-04-02 2012-09-20 2003-11-06 1968-07-18 1988-02-06 1984-09-21 1992-08-14 2018-09-11 1992-10-03 2003-11-14 1988-06-13 1963-04-30 1984-06-24 1980-08-25 2014-07-07 1985-09-21 2008-10-06 2007-04-19 2010-07-23 1968-10-04 2004-12-13 2003-07-21 1988-10-01 2018-03-09

ssdi_dod 2018-12-22 2018-03-18 2018-01-19 2015-10-25 2013-12-01
2019-11-26 2019-10-25
2019-09-06 2019-07-19 2020-01-20 2019-08-13 2018-05-15 2017-10-04 2019-09-10 2020-01-19 2019-12-11
2019-09-29 2019-12-31 2020-01-20 2019-08-17 2018-11-25 2016-01-23 2015-10-03 2017-06-02 2019-01-04 2017-08-13 2019-10-26 2018-12-26

obit_dod
2018-03-18 2018-01-19 2015-10-25
2019-06-07 2014-01-29
2017-11-25
2019-08-13 2018-05-01 2017-10-04 2019-09-10
2019-09-12 2019-09-04 2019-09-29
2019-08-17 2018-11-25 2016-01-23
2017-06-02
2017-08-13 2019-10-26 2018-12-26

Exhibit B, Page 332

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 333 of 352 Pageid#: 1236

voter_id

lname

911010677 W

102006617 W

536833747 W

704011960 W

497719490 W

249927148 W

601034157 W

9005164 W

301018666 W

903016997 W

917418111 W

408031698 W

512023832 W

919829867 W

918448003 W

300332320 W

910016225 W

466536228 W

917059024 W

927100888 W

917456357 W

109006161 W

917451882 W

121009331 W

606010229 W

25019872 W

918466746 W

917633717 W

909001509 W

917367867 W

701008737 W

511008297 W

918783552 W

fname TERESSA CLAIRE DIANE JENNY RONNIE WILLIAM RUTH M GARY RUTH MAXINE BETTY WALTER DAVID RODNEY PATRICIA JOHN WILLIAM JUNE RENA WILLIAM SHEILA JOSEPHINE BETTY JAMES JOHN CHARLES SHAWN CAROL EARL PATRICIA HAROLD PETRINA GREGORY

dob 1956 1925 1950 1947 1956 1947 1917 1946 1933 1933 1933 1939 1950 1968 1943 1959 1933 1922 1961 1933 1966 1924 1945 1926 1939 1939 1979 1945 1933 1959 1934 1972 1963

date_registered 1992-07-15 1964-08-28 2008-02-13 1970-10-03 2014-07-22 2016-09-22 1988-09-29 1991-10-02 1967-10-06 1968-09-13 1996-03-04 1996-10-03 1998-11-04 1998-08-18 1999-03-08 2016-10-21 1989-06-28 2011-12-21 1993-11-08 2008-06-03 2000-03-03 1990-10-06 1996-04-04 1968-02-24 1984-09-19 1997-11-05 1999-03-30 1996-09-05 2003-12-10 1997-03-21 1976-02-21 1990-03-20 2000-05-03

ssdi_dod 2019-10-02 2019-09-26 2018-09-24 2018-03-04 2018-12-19 2020-01-19 2020-01-12 2019-12-22 2019-12-02 2019-12-01 2019-11-27 2019-11-03 2019-10-24 2019-10-22 2019-10-07 2019-09-22 2019-09-10 2019-08-01 2019-07-11 2019-05-30 2018-12-29 2018-12-10 2018-12-06 2018-07-26 2018-02-28 2018-01-27 2018-01-19 2018-01-17 2017-11-23 2017-05-01 2017-04-30 2016-11-16 2016-09-01

obit_dod 2019-10-02 2019-09-26 2018-09-24 2018-03-04 2018-12-19
2019-12-22
2019-12-01
2019-11-03 2019-10-24 2019-10-22
2019-09-22 2019-09-10
2019-05-30 2018-12-29 2018-12-10 2018-12-06
2018-02-28 2018-01-27
2018-01-17
2017-05-01 2017-04-30 2016-11-16

Exhibit B, Page 333

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 334 of 352 Pageid#: 1237

voter_id

lname

802009843 W

917935776 W

31004601 W

917188775 W

33004441 W

912017536 W

205015035 W

307291591 W

704004965 W

107013733 W

306030373 W

919931147 W

917726828 W

917100210 W

505004314 W

918269470 W

918161470 W

918530886 W

96310659 W

919595186 W

504012319 W

901006978 W

919653616 W

918446363 W

305041558 W

807006642 W

227008951 W

502003937 W

127016493 W

707001781 W

810009297 W

222007434 W

504027503 W

fname LUCILLE RUSSELL MARY WILLIAM WILLIE FREDERICK SANDRA JOHNNY MARY HAROLD RONALD MARY DARLENE CHRISTINE ESTELLE CAROL WANDA WALTER ARLOA JERRY JAMES CONSTANCE RICHARD GEORGE PATRICIA LOTTIE MARION STEPHEN JAMES AYER ADA JAMES MARY

dob 1923 1962 1941 1934 1944 1942 1945 1949 1938 1933 1933 1935 1958 1976 1938 1941 1957 1933 1930 1945 1940 1964 1939 1933 1949 1937 1945 1929 1941 1939 1933 1930 1941

date_registered 1976-09-08 1997-03-20 1989-10-07 1994-10-03 1992-09-19 2000-12-06 1995-09-16 2017-04-18 1992-02-04 1965-08-06 1968-10-05 2004-09-30 1996-10-04 2006-01-17 1961-04-24 1998-05-06 1997-12-04 1999-06-28 2012-05-01 2003-09-08 1980-09-27 1984-10-06 2003-12-23 2015-09-10 1988-06-23 1999-11-03 1980-10-04 1950-12-26 1976-01-01 2002-04-08 1984-01-05 1976-01-07 1990-05-04

ssdi_dod 2016-06-26 2015-04-15 2011-02-28 1991-06-15
2016-12-22 2018-02-06 2018-01-19 2014-10-19
2019-05-12 2020-01-04 2019-06-13 2019-04-09
2016-09-07
2017-03-04 2019-10-19 2014-10-05 2018-11-26 2019-11-20 2019-11-13 2019-11-07 2019-08-06 2015-03-31 2019-11-22

obit_dod 2016-06-26 2015-04-15 2011-02-28
2019-09-30 2019-09-02 2019-08-30 2019-05-02 2018-12-13 2018-02-15 2015-01-21 2016-12-22 2018-02-06
2014-10-19 2019-08-22 2019-05-12
2019-06-13
2019-03-19 2016-09-07 2016-01-04 2017-03-04 2019-10-19
2019-11-20 2019-11-13 2019-11-07 2019-08-05
2019-11-22

Exhibit B, Page 334

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 335 of 352 Pageid#: 1238

voter_id

lname

919789708 W

101462163 W

688862547 W

304025995 W

28016349 W

919735164 W

919393127 W

196163911 W

231018454 W

406016020 W

164466065 W

917161099 W

919149345 W

4004873 W

8363524 W

29018043 W

810002455 W

4514090 W

182386463 W

405018121 W

402028758 W

920062217 W

704001706 W

12790099 W

307044555 W

205011047 W

401011381 W

917707933 W

255033826 W

609012222 W

205024475 W

205020331 W

301042428 W

fname MARVIN THOMAS FRANCES BIRDIE AFTON CAROLE JOSEPH LINDA PARRAN JOHN VIRGINIA GEORGE RENE VIVIAN M EVELYN WILLIE ROLAND SHAWN RAYMOND MARY MARY FREDDIE CLAUDINE LAWRENCE MACK DOYLE JAMES JANYCE BETTY WILLIAM JUANITA JOHN THOMAS

dob 1962 1947 1924 1922 1929 1942 1936 1945 1948 1950 1925 1922 1934 1934 1924 1938 1932 1965 1936 1927 1934 1940 1926 1965 1940 1946 1941 1946 1937 1940 1922 1931 1937

date_registered 2005-02-25 2016-09-27 2007-11-09 1956-09-29 1964-09-04 2004-04-07 2002-09-12 2009-07-16 1980-10-04 1972-09-18 2008-11-06 2016-10-12 2001-07-25 1981-07-02 2010-09-23 1968-07-17 1996-04-03 2009-06-17 2016-05-27 1951-01-20 1998-08-18 2005-02-25 1982-05-17 2016-07-25 1984-10-05 1981-10-03 1963-10-04 2005-09-22 2010-03-30 1998-11-23 1953-12-12 1975-08-19 1988-01-15

ssdi_dod 2017-02-08 2019-11-09 2016-12-03 2016-03-08
2019-10-04
2019-08-15 2020-01-31 2017-10-01
2018-12-18 2020-01-08 2019-12-03 2019-11-20 2018-12-28 2018-07-06 2019-04-13 2018-09-13
2019-09-01 2018-11-03 2018-10-15
2018-12-30 2018-04-07 2018-03-08 2019-11-07 2013-03-08

obit_dod
2016-12-03 2016-03-08 2016-05-21 2019-10-04 2015-11-23 2019-01-06 2019-09-30 2019-08-15
2017-10-01 2014-11-11 2018-12-18
2019-12-03 2019-11-20 2018-12-28 2018-07-06 2019-04-13 2018-09-13 2018-01-11 2019-09-01 2018-11-03 2018-10-15 2019-08-16 2018-12-30 2018-04-07
2019-11-07
2019-09-18 2019-09-15

Exhibit B, Page 335

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 336 of 352 Pageid#: 1239

voter_id

lname

917461977 W

917244725 W

101005566 W

106012484 W

226005715 W

917118573 W

101032496 W

227000601 W

803005267 W

105153374 W

917835008 W

26010539 W

919098754 W

919697608 W

608008876 W

9006053 W

223006841 W

126014504 W

103022680 W

107016007 W

224003654 W

124002644 W

608019095 W

703016104 W

701024998 W

563612552 W

802006957 W

918107762 W

127016497 W

405018372 W

264364981 W

121015064 W

207015662 W

fname GENEVIEVE MICHELLE MARGARET ANNE LYNN JEAN BARBARA BURNETT CECELIA JUNE WALTER EDNA CARROLL HERBERT MARVIN RUBY MILTON RITA BRENDAN PEGGY MARJORIE ALFRED WILLIAM JAMES HOWARD GLENDON MARY CHARLES LINDSEY THOMAS BILLY JAMES EDWIN

dob 1931 1968 1944 1948 1948 1926 1940 1936 1928 1932 1936 1927 1956 1936 1936 1941 1933 1931 1930 1927 1924 1927 1932 1937 1936 1939 1927 1946 1930 1941 1937 1933 1928

date_registered 1996-04-08 1995-03-03 1975-08-29 1982-08-12 1990-02-01 1994-05-10 1992-10-03 1958-10-04 1976-10-01 2012-04-16 1996-11-27 2000-12-21 2001-05-03 2004-02-27 1968-08-26 1980-09-15 1980-10-03 1975-06-02 2000-01-20 1995-11-13 1947-07-03 1960-06-11 1979-10-06 1964-01-04 1984-09-29 2008-10-03 1949-06-01 2006-05-03 1991-10-05 1966-08-30 2016-12-30 1979-10-06 1985-09-09

ssdi_dod 2019-03-09 2019-10-01 2019-09-27 2018-12-10 2016-08-26 2020-01-01 2018-12-19 2018-12-09 2018-09-11 2016-11-24 2019-12-22 2018-08-01 2019-12-28 2019-12-14 2019-10-03 2017-07-25 2017-06-06 2019-12-26 2019-11-14 2019-10-30 2018-04-17
2019-08-31
2019-11-21 2015-02-18 2020-01-07 2020-01-05 2019-12-26 2019-12-16 2019-12-07 2019-11-24

obit_dod 2019-03-09 2019-10-01 2019-09-27
2018-12-09 2018-09-11 2016-11-24 2019-12-22 2018-08-01
2019-10-03 2017-07-25 2017-06-06
2019-11-14 2019-10-30 2018-04-17 2019-10-17 2019-08-31 2019-02-21 2019-08-11
2019-12-16 2019-12-07 2019-11-24

Exhibit B, Page 336

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 337 of 352 Pageid#: 1240

voter_id

lname

918642476 W

226017709 W

918602287 W

918604655 W

156632115 W

502019702 W

12168364 W

6209524 W

451849283 W

417519692 W

506006782 W

919972629 W

911018032 W

25013045 W

706020110 W

28009624 W

404008219 W

919042690 W

120691937 W

919756115 W

16005482 W

507880417 W

404017821 W

918132970 W

748484512 W

224012795 W

204026536 W

307955134 W

121011195 W

104024173 W

867946342 W

56447314 W

917169173 W

fname EMMA DONALD FRANKIE WILFORD MELVIN JESSIE LEMUEL KATHY VIRGIE MALCOM JOHN LARRY GRAYSON LETHA CHARLES JOHN ELSIE GENE JOHN LAWRENCE CHARLES WILSON MARVIN DOROTHY KEVIN MARY EMMA BRUCE JAMES HAROLD KATHRYN WILLIAM MARIAN

dob 1950 1931 1949 1923 1950 1930 1934 1955 1975 1977 1940 1953 1929 1936 1931 1946 1934 1956 1953 1939 1928 1945 1935 1932 1961 1931 1928 1955 1947 1929 1949 1944 1936

date_registered 2005-03-21 1980-10-04 1999-09-29 1999-10-04 2016-08-23 1984-03-31 2017-02-07 2018-02-23 2007-09-17 2019-08-16 1986-10-01 2004-10-04 1988-10-08 1984-10-05 1980-07-01 2000-08-09 1984-10-02 2001-02-14 2008-09-24 2004-05-12 1956-01-21 2016-08-10 1975-09-09 1997-11-05 2008-09-29 1980-09-24 1964-10-02 2008-10-06 1999-08-23 1967-05-05 2010-05-05 2011-06-21 2004-09-09

ssdi_dod 2019-11-23 2019-11-21 2019-11-21 2019-11-16 2019-11-16 2019-11-13 2019-11-04 2019-11-04 2019-11-04 2019-10-28 2019-10-27 2019-10-23 2019-10-17 2019-10-09 2019-10-08 2019-10-07 2019-10-03 2019-09-29 2019-09-28 2019-09-27 2019-09-24 2019-09-23 2019-09-19 2019-09-18 2019-09-13 2019-09-09 2019-09-07 2019-08-30 2019-08-25 2019-08-02 2019-07-22 2019-06-09 2019-05-11

obit_dod
2019-11-21 2019-11-21 2019-11-16 2019-11-16 2019-11-13 2019-11-16 2019-11-04 2019-11-04
2019-10-23
2019-11-09
2019-10-03
2019-09-28 2019-09-27 2019-09-24 2019-09-23
2019-09-18 2019-09-13 2019-09-09 2019-09-07 2019-08-30 2019-08-25 2019-08-02 2019-07-22

Exhibit B, Page 337

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 338 of 352 Pageid#: 1241

voter_id

lname

905003030 W

19628553 W

919217002 W

918124598 W

643923096 W

410006646 W

917175331 W

147213654 W

409026214 W

96184282 W

595728691 W

24010774 W

122001173 W

24000283 W

22015168 W

225006274 W

917447282 W

402483283 W

806010349 W

103011261 W

706016342 W

805008102 W

919198711 W

188358649 W

115593993 W

919702484 W

805015262 W

702006147 W

919517786 W

917153818 W

808001474 W

34398075 W

918258762 W

fname RONALD OLEN ROBERT JOSEPH CANDIS LINDA HEZRON BERTHA DAVID CLARA HOWARD ALBERT HAROLD SHIRLEY LINDA IRIS DENNIS THOMAS ALEXANDER PEGGY ERNEST SAMUEL ALICE RONALD KEITH JOHN KATHRYN ROY PATSY SYLVIA MARGARET LATONYA ALAN

dob 1954 1957 1956 1938 1934 1943 1954 1941 1943 1942 1947 1926 1933 1937 1957 1923 1949 1952 1938 1933 1929 1944 1942 1952 1963 1954 1936 1924 1939 1959 1928 1975 1959

date_registered 1972-08-16 2013-01-28 2001-10-09 1997-10-05 2012-06-19 2004-11-29 1994-09-20 2012-08-07 1988-09-27 2009-06-10 2012-10-15 1976-08-19 2002-08-05 1980-09-15 1991-11-22 1987-11-06 1996-04-05 2016-09-01 1964-09-30 1992-06-20 1959-09-05 1987-11-23 2001-10-01 2016-11-18 2016-11-22 2004-03-04 1963-07-15 1983-09-03 2003-05-08 1994-09-07 1974-03-05 2010-03-04 2000-01-04

ssdi_dod 2019-05-07 2019-05-02 2019-03-24 2019-03-21 2019-01-30 2019-01-13 2019-01-02 2018-12-30 2018-12-26 2018-12-25 2018-12-22 2018-12-20 2018-12-20 2018-12-11 2018-12-05 2018-12-04 2018-12-02 2018-11-17 2018-07-29 2018-07-15 2018-06-02 2018-05-22 2018-04-16 2018-02-25 2018-02-08 2018-02-06 2017-12-10 2017-12-02 2017-09-30 2017-09-01 2017-05-08 2017-03-23 2017-01-28

obit_dod
2019-03-24
2019-01-30
2019-01-02 2018-12-30 2018-12-26 2019-01-01 2018-12-22 2018-12-20 2018-12-20 2018-12-11 2018-12-05 2018-12-04 2018-12-02
2018-06-02 2018-05-22 2018-04-16 2018-02-25 2018-02-08 2018-02-06 2017-12-10
2017-09-30
2017-03-23 2017-01-28

Exhibit B, Page 338

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 339 of 352 Pageid#: 1242

voter_id

lname

447174226 W

920092894 W

917894203 W

902006741 W

705617 W

918737702 W

45614581 W

205012250 W

218375899 W

126015792 W

222026220 W

27008341 W

909001817 W

703005160 W

210010701 W

503004286 W

917639361 W

406030037 W

222012089 W

50741351 W

833982951 W

21000280 W

808008986 W

509026430 W

919744717 W

807009717 W

214890009 W

917497442 W

522488974 W

223006490 W

26006295 W

803008103 W

802015264 W

fname LEROY AARON WILLIAM DAVID JAMES MARY HOWARD JOHN MARY COSTON BARBARA ELEANOR CALVIN JAMES GARY CAROLYN THOMAS ROSE BEVERLY RUTH CALENA EMMA JUDITH JAMES JAMES BETTY ALAN ALMAE CARL DIANA JOAN JAMES ANNIE

dob 1944 1940 1925 1942 1927 1930 1927 1936 1930 1921 1939 1925 1941 1936 1920 1942 1942 1938 1938 1938 1960 1943 1945 1929 1962 1923 1927 1945 1937 1942 1948 1924 1933

date_registered 2012-06-26 2005-04-26 1997-02-11 1984-09-29 2019-02-08 2000-03-10 2016-05-26 1976-10-02 2008-10-06 2006-09-01 1992-09-26 1993-12-23 1980-03-25 1973-09-19 1988-08-13 1999-02-10 1997-02-28 1968-09-09 1959-05-07 2014-09-26 2008-09-26 1988-04-09 1987-02-03 1956-05-12 2004-05-05 1968-09-25 2010-08-19 1996-05-13 2010-05-13 1972-09-21 1998-06-04 1958-05-08 1955-03-09

ssdi_dod 2016-10-31 2016-01-27 2015-11-25 2015-11-25 2009-03-19 2006-05-09 2000-04-01 1994-01-11 1990-06-15
2017-12-22 2020-01-27 2019-11-08 2019-08-27 2015-12-06 2015-11-16 2019-12-06 2017-11-29 2019-12-17

obit_dod 2016-10-31 2016-01-27 2015-11-25 2015-11-25 2009-03-19
2019-12-15 2019-10-12 2019-09-04 2019-08-26 2019-08-24 2019-08-22 2019-08-05 2018-12-10 2018-12-07 2018-12-03 2018-02-07 2017-04-22 2016-08-13 2017-12-21
2019-11-08 2019-08-27
2015-11-16 2016-11-14
2019-03-29 2019-12-17

Exhibit B, Page 339

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 340 of 352 Pageid#: 1243

voter_id

lname

401018553 W

461252018 W

506027957 W

560098512 W

201007747 W

206024773 W

308031998 W

1002083 W

175819799 W

206012931 W

918559801 W

227018103 W

223010757 W

206009784 W

301019424 W

226008341 W

608020059 W

906013452 W

23077858 W

920340091 W

917602887 W

919135546 W

193713284 W

714012694 W

918103942 W

919097783 W

210014748 W

316943584 W

917927305 W

752552624 W

108019001 W

622693417 W

801012408 W

fname BARBARA PEARL EUGENE DANA FRANCES JIMMY LOUISE JAMES DYLAN JOAN ELIZABETH WILLIAM DONALD EVA JUANITA JULIA ROBERT MAYNARD JEAN LACEY JOAN HENRY ARCHER CLINTON DELORES DONALD BETTY ROBERT JIMMY ELISABETH THURLOW GLADYS LAWRENCE

dob 1937 1932 1941 1958 1925 1938 1927 1934 1993 1933 1958 1919 1927 1925 1935 1943 1931 1931 1941 1936 1946 1951 1932 1942 1938 1931 1946 1944 1945 1957 1928 1929 1938

date_registered 1979-10-04 2008-08-18 1982-04-21 2007-07-26 1982-10-01 1996-08-20 1976-09-09 1955-07-28 2016-12-08 1976-09-23 1999-08-13 1981-10-02 1974-10-03 1975-05-10 1978-10-07 1971-07-20 1997-07-31 2005-04-21 2016-01-06 2006-08-15 2012-09-21 2001-07-05 2014-03-25 1999-10-04 1997-09-25 2001-05-02 1977-10-08 2017-10-16 1997-03-12 2017-07-26 1980-08-14 2008-06-03 1968-10-05

ssdi_dod 2019-10-22 2019-05-11 2018-09-01 2018-05-20 2018-03-30 2017-12-30 2015-03-30
2019-04-22 2019-12-24 2019-10-21
2018-12-12 2017-07-04 2020-01-21 2020-01-21 2020-01-07 2019-12-23 2019-12-03 2019-11-19 2019-11-14 2019-11-13 2019-11-03 2019-10-25 2019-08-27 2019-08-23 2019-08-23 2019-08-13 2019-05-30 2018-12-30 2018-12-24 2018-12-24 2018-12-23

obit_dod 2019-10-22
2018-09-01 2018-05-20 2018-03-30 2017-12-30 2015-03-30 2019-09-20 2019-04-22
2019-10-21 2019-08-23 2018-12-12 2017-07-04
2019-12-23 2019-12-03
2019-11-14 2019-11-14 2019-11-03 2019-10-25 2019-08-27 2019-08-23
2019-05-30 2018-12-30 2018-12-24 2018-12-24 2018-12-23

Exhibit B, Page 340

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 341 of 352 Pageid#: 1244

voter_id

lname

805001138 W

124008019 W

918717022 W

919033102 W

405012257 W

919289022 W

920229710 W

605002643 W

302029582 W

17002305 W

502025335 W

806002459 W

502010181 W

917476219 W

801010085 W

603008727 W

128013236 W

110019001 W

299566974 W

910021271 W

709011082 W

917590249 W

21005683 W

413025552 W

303040834 W

807014960 W

54895196 W

225000225 W

502012829 W

127015066 W

208013480 W

917204684 W

125014090 W

fname PERCY SAMMIE LILLIAN MARILYN FRANCES JANET SHIRLEY RAUSBIN HAROLD LORENE THEODORE WILFRED PINIA KATIE ERNEST LEROY ALMAIRA KATHERINE SUZANNE JOANN MARTHA EVELYN SHIRLEY ELIZABETH BETTY OSTELLA DENNIS GENEVA PATRICIA PAULINE SUSAN JUDY LEE

dob 1956 1923 1960 1945 1943 1936 1933 1922 1928 1929 1950 1926 1926 1935 1927 1949 1942 1948 1925 1958 1924 1949 1945 1917 1931 1925 1954 1932 1924 1924 1953 1953 1926

date_registered 1985-04-04 1956-10-01 2000-03-02 2001-02-01 1984-09-04 2002-03-14 2005-12-20 1960-01-19 1975-01-02 2014-04-14 2000-11-21 1959-05-04 1951-05-05 1996-04-27 1960-05-25 1996-11-06 1978-10-07 1986-09-27 2012-09-26 1992-03-20 1989-04-21 2000-03-06 1992-10-03 1953-05-22 1976-04-28 1957-05-06 2016-04-08 1960-05-07 1999-09-16 1980-09-15 1980-08-19 1994-10-11 1956-10-05

ssdi_dod 2018-12-23 2018-12-22 2018-12-11 2018-12-06 2018-06-10 2018-02-07 2018-01-27 2018-01-24 2018-01-24 2016-04-15 2015-12-26 2015-08-31 2015-04-06 2015-02-15 1994-07-12
2020-01-20 2019-12-25 2017-08-08 2018-06-14 2019-10-02
2019-12-17 2018-12-28 2018-06-17 2019-08-07

obit_dod 2018-12-23
2018-06-10 2018-02-07 2018-01-27 2018-01-24
2015-08-31 2015-04-06 2015-02-15
2019-11-17 2019-09-28 2019-09-16 2019-09-01 2019-08-23 2018-08-02 2014-07-02 2013-05-06
2017-08-08 2018-06-14 2019-10-02 2014-12-20
2018-12-28 2018-06-17 2019-08-07

Exhibit B, Page 341

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 342 of 352 Pageid#: 1245

voter_id

lname

23014958 W

409038719 W

128285862 W

155242688 W

103021400 W

202004847 W

158266196 W

713005672 W

207012038 W

404017564 W

917625208 W

404018748 W

604004352 W

224011135 W

607028048 W

179532294 W

703022106 W

513001524 W

222007765 W

20915236 W

662303286 W

919690043 W

396291278 W

919360614 W

20395818 W

708011817 W

348013675 W

918203564 W

501029307 W

228015596 W

409002300 W

243309264 W

917300557 W

fname JONNIE JERRY ROBERT DAVID STANLEY JOAN MIRIAM ELSIE JUNE WILLIAM ANDY CHARLES CARTER DAVID KENNETH CHARLES RICHARD BARBARA GEORGE DONALD JEROME CURTIS SYBILLA PAT JEAN LOIS LARRY CHERYL MARY BARBARA GEORGE JOHN BARBARA

dob 1924 1948 1922 1953 1929 1931 1921 1926 1945 1933 1939 1953 1954 1932 1950 1931 1945 1927 1937 1933 1947 1921 1929 1940 1934 1941 1934 1961 1940 1932 1926 1932 1931

date_registered 1959-12-01 2012-08-30 2016-10-07 2008-08-21 1952-10-02 1959-04-20 2012-08-22 1996-08-23 1980-10-04 1972-03-29 1996-09-03 2000-03-01 2000-05-03 1977-09-08 1987-10-02 2010-04-12 1990-10-05 1989-05-23 1975-10-02 2017-03-07 2008-10-06 2004-02-11 2014-07-25 2002-07-19 2019-03-20 1972-08-23 2012-10-05 1998-02-10 1986-08-09 1980-09-24 1972-10-07 2012-09-10 1995-07-13

ssdi_dod 2018-12-31
2019-08-09 2018-12-23 2019-12-30 2019-09-12
2019-10-22 2019-09-04 2019-09-28 2019-09-29
2019-01-01 2018-03-30 2019-12-13 2019-08-08 2019-12-26 2020-01-14 2019-11-28 2019-11-06 2019-12-22 2019-11-10 2018-09-22
2019-12-24 2014-03-12 2019-12-10 2019-10-22
2018-04-21 2019-09-24
2019-10-13

obit_dod 2018-12-31 2019-09-11 2019-08-09
2019-12-30
2019-08-15 2019-10-22 2019-09-04 2019-09-28 2019-09-29 2019-08-20 2019-01-01
2019-08-08
2019-11-06
2019-11-10 2018-09-22 2018-04-07
2014-03-12 2019-12-10 2019-10-22 2019-10-09 2018-04-21 2019-09-24 2018-08-31 2019-10-13

Exhibit B, Page 342

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 343 of 352 Pageid#: 1246

voter_id

lname

427328224 W

918021111 W

918495041 W

610291476 W

388737276 W

918076730 W

919951626 W

502010407 W

919864242 W

918703137 W

307028919 W

918508165 W

308484930 W

917434932 W

302026328 W

917885642 W

406906942 W

356391736 W

920334353 W

492891152 W

919086589 W

108005627 W

106005627 W

29485594 W

21079334 W

917578412 W

303032175 W

308031352 W

919488529 W

225001085 W

608002982 W

202015669 W

317032495 W

fname SUZANNE JUANITA LAWRENCE PETE ELLEN PATTIE DENISE KERMIT LEOLA ANNIE MARILYN DAVID JACK MARY JO HELEN DAFFIE WILLIAM NAOMI MARY DARLENE EUGENE SUE LAWRENCE CECIL DON SHIRLEY RICHARD MARION JAMES SARAH JEANETTE THERESA FRANCIS

dob 1930 1948 1959 1939 1949 1954 1964 1945 1965 1944 1929 1954 1931 1962 1925 1946 1933 1936 1924 1930 1936 1943 1942 1938 1931 1944 1926 1929 1946 1939 1943 1924 1928

date_registered 2016-03-17 2003-02-18 1999-05-03 2008-10-06 2012-09-04 1997-08-27 2004-10-04 1990-08-31 2004-08-30 2000-03-07 2006-07-05 1999-05-24 2016-09-08 1996-03-29 1967-10-05 1997-02-04 2012-10-15 2016-04-06 2006-08-03 2013-12-19 2001-04-17 1966-10-04 1963-09-24 2011-10-12 2014-09-12 1996-07-30 1974-08-29 1976-09-25 2003-03-07 1992-09-24 1968-10-01 1999-02-24 2012-06-28

ssdi_dod 2019-11-10 2019-05-12 2018-07-22 2013-07-15 2018-12-10 2018-12-29 2016-04-30 2019-10-25 2018-04-21
2019-11-02 2019-11-20 2019-09-29 2019-10-27 2019-11-04 2019-08-07 2019-12-04 2019-11-29 2019-10-21 2017-11-30 2019-10-10 2018-12-19 2016-11-24 2019-03-16 2018-12-16 2018-08-31
2019-11-11 2019-09-14 2018-12-24 2014-10-12

obit_dod
2019-05-12 2018-07-22
2018-12-10 2018-12-29 2016-04-30 2019-10-26
2017-01-10 2019-11-02
2019-09-29
2019-11-04 2019-08-07 2019-12-04 2019-11-29
2017-11-30 2019-10-10 2018-12-19 2016-11-24
2018-08-31 2018-12-19 2019-10-18 2019-11-20 2019-09-14 2018-12-24 2014-10-12 2019-08-02

Exhibit B, Page 343

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 344 of 352 Pageid#: 1247

voter_id

lname

27006071 W

234019027 W

919524843 W

287036472 W

282109107 W

920409357 W

405006292 W

604037178 W

405016560 W

129020183 W

501029847 W

20331506 W

99790572 W

408020549 W

375555359 W

918449544 W

129008564 W

208024662 W

917915208 W

28016039 W

918946346 W

29004715 W

920338578 W

507014845 W

49478404 W

504003618 W

108023426 W

918785095 W

506001431 W

809019901 W

121012335 W

4002902 W

919050769 W

fname ETHEL KENNETH SZE JOSEPH CHING MARY ARLIE JAY VIRGINIA ISAAC ROBERTA JAMES WANDA CHARLES JIMMY CHRISTINE WILLIAM MILDRED SHELBY LILLY THOMAS CHARLES DONALD MILTON ROGER BALLARD GERALD CLARENCE GRACE SUZANNE ADDIE LUCILLE LINDA

dob 1921 1948 1933 1948 1939 1929 1926 1942 1927 1943 1932 1951 1947 1935 1941 1963 1962 1931 1945 1950 1937 1967 1942 1938 1950 1928 1929 1930 1942 1939 1937 1926 1944

date_registered 1997-04-02 1988-09-27 2003-05-12 2007-11-16 2009-02-17 2006-11-30 1984-09-18 1992-11-18 1964-09-02 1992-10-01 1959-08-20 2018-09-14 2012-08-14 2000-01-04 2018-04-13 1999-03-01 2001-02-16 1996-12-12 1997-03-03 2004-03-30 2000-10-10 1996-10-07 2006-08-11 1966-06-11 2017-05-10 2002-01-28 1984-10-06 2000-05-12 1967-10-06 1993-06-07 2000-05-03 1984-03-09 2001-02-28

ssdi_dod
2019-06-13 2019-11-29 2019-11-28 2019-09-04 2020-01-05 2019-12-25 2019-12-15 2019-11-24 2019-11-16 2019-11-12 2019-11-10 2019-11-05 2019-10-30 2019-10-17 2019-10-16 2019-10-06 2019-10-02 2019-09-24 2019-09-03 2019-08-29 2019-08-19 2019-06-24 2018-12-27 2018-09-08 2018-07-20 2017-07-28 2016-09-08
2019-12-13 2019-05-07

obit_dod 2017-01-19 2019-06-13 2019-11-29
2019-12-25
2019-11-24 2019-11-16 2019-11-12 2019-11-10 2019-11-05
2019-10-17 2019-10-16 2019-10-06 2019-10-02 2019-09-24 2019-09-03 2019-08-29
2018-12-27 2018-09-08 2018-07-20 2017-07-28
2019-10-19 2019-08-15 2019-05-17
2019-05-07

Exhibit B, Page 344

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 345 of 352 Pageid#: 1248

voter_id

lname

919803209 W

305025794 W

305030136 W

701012259 W

918513429 W

704005325 W

919878496 W

919082629 W

919066962 W

917675415 W

3721797 W

918344299 W

206002263 W

371394780 W

701258838 W

405018377 W

847692687 W

917888361 W

917770101 W

98858097 W

125000666 W

507027688 W

917141322 W

911011311 W

203003077 W

920362404 W

609004752 W

918215000 W

203005445 W

704008579 W

208002499 W

403014783 W

407018751 W

fname MICHAEL JUDITH JOHN FRANCES JESSIE VERNICE JAMES NATHANIEL JOHN JOANNE THOMAS GRACE SHELDON MARGARET DOROTHY GEORGE KIM BOBBY LEROY YVONNE ADOLPHUS GAYNELLE KARYL BETTY WILLIAM MILLIE WILLIAM FRANCES GLADYS ARTHUR DONALD MARY GLADYS

dob 1955 1946 1929 1936 1943 1927 1944 1952 1940 1952 1937 1964 1946 1948 1941 1933 1961 1967 1948 1935 1905 1937 1946 1938 1927 1941 1926 1947 1936 1928 1948 1932 1928

date_registered 2006-05-15 1972-03-23 1999-09-29 1971-01-19 1999-06-04 1948-12-06 2004-09-10 2001-04-12 2007-03-12 1996-09-21 2008-10-06 2002-05-16 1976-10-02 2012-06-22 2011-10-14 1970-10-03 2016-09-06 1997-01-13 1996-10-07 2016-08-23 1964-09-02 1960-04-05 1994-08-08 1988-10-08 1951-04-28 2006-09-21 1989-08-17 1998-03-06 1976-03-03 1968-10-04 1995-01-03 1987-07-27 1955-05-18

ssdi_dod 2018-06-08
2015-03-29 2017-06-08
2019-11-11 2019-09-02 2018-01-11 2017-05-06 2018-01-16
2018-09-10 2019-12-07 2019-06-05 2019-05-27 2018-12-11 2018-11-02 2018-04-13 2018-01-27 2017-05-15 2000-07-20
2019-12-22 2018-01-14 2013-11-09
2020-01-27
2019-10-20 2018-12-09

obit_dod
2019-09-14
2017-06-08 2014-05-14
2019-09-02 2018-01-11
2018-01-16 2019-08-20 2018-09-10 2019-12-07
2019-05-27 2018-12-11 2018-11-02 2018-04-13 2018-01-27
2019-09-21 2018-09-11 2016-02-13 2019-12-22
2019-05-10 2018-12-14
2018-12-07
2018-12-09

Exhibit B, Page 345

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 346 of 352 Pageid#: 1249

voter_id

lname

802000925 W

918285207 W

906021275 W

918347038 W

918578490 W

803016155 W

381764843 W

709004483 W

918370915 W

414008821 W

918857152 W

227011483 W

804000925 W

102004073 W

904009788 W

918631442 W

905017549 W

104018140 W

113499909 W

917045632 W

979341167 W

727848433 W

605033801 W

805000926 W

508021655 W

603000378 W

211018029 W

918637486 W

26020211 W

412007528 W

414007528 W

225012096 W

285324328 W

fname JESSE TONY EMMERSON DONALD BETH PHYLLIS PATRICIA SAMUEL ALICE SHELLEY ARTHUR JOYCE AUDREY HOBERT RALPH JOYCE GLENDA ANTHONY DOROTHY ELDRED HAZEL SHIRLEY DIANE JIMMY RICHARD EARL DONNA PAUL WILLIAM DAVID SHIRLEY WILLIAM LEWIS

dob 1952 1953 1928 1939 1954 1956 1946 1942 1937 1963 1925 1929 1928 1908 1913 1945 1947 1960 1925 1940 1939 1939 1943 1948 1941 1931 1937 1931 1923 1932 1937 1943 1947

date_registered 1987-05-13 1998-06-18 1964-09-10 1998-09-23 1999-09-07 2000-11-08 2012-10-01 1984-10-02 1998-11-04 1992-10-02 2000-08-23 1983-03-02 1958-03-29 1972-10-07 1969-08-20 1999-11-17 1981-08-08 1982-04-16 2012-10-15 1993-10-04 2008-10-01 2012-09-28 1968-10-03 1972-10-06 1988-01-11 1967-06-10 1992-09-01 1999-11-29 1971-08-14 1988-10-05 1988-10-05 1982-04-03 2016-05-04

ssdi_dod 2017-11-03 2015-12-05 2018-12-07 2019-08-22 2017-10-22 2019-11-07
2019-06-22
2019-10-10 2019-11-27 2019-10-22 2019-01-02 2002-02-11 1992-09-21
2019-09-09 2018-05-13 2015-07-31
2020-01-08 2019-10-21 2019-08-23 2018-11-27
2019-10-24
2019-02-25 2019-02-25 2019-12-11 2019-10-24

obit_dod 2017-11-03 2015-12-05 2018-12-07 2019-08-22
2019-11-07 2019-09-15 2019-06-22 2016-08-13 2019-10-10
2019-10-22 2019-01-02
2019-02-09 2019-09-09 2018-05-13
2019-09-28
2019-10-21 2019-08-23
2019-09-27 2019-10-24 2014-01-30 2019-09-13 2014-11-11
2019-12-11

Exhibit B, Page 346

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 347 of 352 Pageid#: 1250

voter_id

lname

758565594 W

802016544 W

911000309 W

308015683 W

605020417 W

917057315 W

230735543 W

201014460 W

917459209 W

303016492 W

701012166 W

125000668 W

106025785 W

920146316 W

601021450 W

402029206 W

917766761 W

518058826 W

701014067 W

121015975 W

807014995 W

919558413 W

76695455 W

707003670 W

905001521 W

900386417 W

261642630 W

918870981 W

377685923 W

237995818 W

562575947 W

514023658 W

918781268 W

fname ESTELLE WILLIE RAYMOND GRETA ISHMEAL LINDA RICHARD SAMUEL CHERYL JAMES JAMES ROBERT MARGARET AMY SARAH CHARLES JOSEPH JEFFERY MAXIE ALVERNA THELMA DONALD MICHAEL EDWARD CLARESTINE CAROLYN BEATRICE DOROTHY JOSEPH VALLI FRANCES OLINE CLARINE

dob 1940 1926 1932 1932 1946 1947 1946 1935 1949 1944 1939 1932 1929 1980 1962 1924 1929 1965 1933 1926 1935 1942 1959 1928 1929 1961 1932 1930 1929 1936 1923 1929 1940

date_registered 2008-09-04 1977-11-12 1988-10-06 1979-09-12 1970-09-15 1999-06-03 2013-09-19 1976-04-23 1998-11-04 1981-10-03 1976-09-02 2000-09-26 1973-09-30 2005-08-11 1997-06-11 1991-09-30 1996-10-05 2010-10-04 1967-06-08 1963-10-05 2002-05-10 2003-07-18 2018-11-07 2001-02-01 1980-10-03 2008-03-07 2014-12-03 2000-08-31 2008-09-29 2012-10-15 2009-11-30 1995-06-19 2000-05-11

ssdi_dod 2019-12-02 2014-12-05 2019-12-31 2019-12-25 2019-12-25 2019-12-09 2019-11-27 2019-11-24 2019-11-24 2019-11-15 2019-11-04 2019-10-16 2019-10-11 2019-09-27 2019-09-22 2019-08-15 2019-08-12 2019-07-04 2019-05-31 2019-04-12 2019-03-24 2018-12-30 2018-12-17 2018-12-13 2018-07-15 2018-06-08 2018-03-26 2018-01-23 2017-08-24 2017-04-22 2013-12-20

obit_dod 2019-12-02
2019-12-09 2019-11-27 2019-11-24 2019-11-24 2019-11-15 2019-11-04 2019-10-16 2019-10-11 2019-09-27 2019-09-22 2019-08-15 2019-08-12
2019-04-12 2019-03-24 2018-12-30 2018-12-17 2018-12-13
2018-03-26 2018-01-23 2017-08-24 2017-04-22 2013-12-20 2019-09-04 2019-05-05

Exhibit B, Page 347

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 348 of 352 Pageid#: 1251

voter_id

lname

806001143 W

304034898 W

43130171 W

919152811 W

210018736 W

919796212 W

305000539 W

958035743 W

530814591 W

605031535 W

604015161 W

601007912 W

372565500 W

23019383 W

215002152 W

225003909 W

919686738 W

802020990 W

22013572 W

608033496 W

107012689 W

919696917 W

508013699 W

918040541 W

919897779 W

223016693 W

919025901 W

27007116 W

918900378 X

305050384 Y

10005449 Y

412004961 Y

136176332 Y

fname GENEVA ETHEL DIANA JIMMIE PAULA CHENG-TSU ELEANOR SANGUAN HAZELTINE CLIFTON CAROLYN MAGGIE RICHARD LULA ROBERT JUANITA WALTER BEATRICE MARY CATHERINE BARBARA NELLIE ALVIN MAGGIE CHRISTOPHER MARY BESSIE ELSIE LI JEANETTE HENRY DEBORAH CHARLES

dob 1937 1919 1942 1936 1942 1922 1920 1925 1934 1943 1947 1929 1950 1929 1938 1942 1935 1951 1922 1947 1952 1915 1930 1947 1943 1940 1932 1922 1945 1929 1932 1956 1955

date_registered 1984-03-30 1964-09-22 2018-10-15 2001-08-01 1988-09-24 2004-07-01 1997-09-19 2008-10-06 2016-08-15 1968-05-11 2001-08-16 1976-04-01 2010-10-07 1999-07-23 1967-10-07 1968-02-29 2004-02-19 1996-07-30 1955-12-12 1996-12-18 1988-02-01 2004-02-27 1979-12-27 2004-10-04 2004-09-20 1994-12-21 2001-01-23 2004-09-17 2007-02-14 1997-12-01 1991-10-03 1991-06-17 2016-10-17

ssdi_dod
2019-10-05 2019-09-26 2018-12-16 2019-02-24 2016-04-12 2012-02-12 2019-12-16 2019-10-28 2019-10-24 2019-09-20 2018-02-20 2016-09-15 2014-03-04
2018-10-15 2018-02-16 2018-01-13 2019-07-01 2019-05-22
2019-10-04 2019-09-29 2019-10-03 2006-11-14
2015-05-11 2019-10-20 2017-08-30 2018-06-01

obit_dod 2019-04-21 2017-08-24
2019-09-26 2018-12-16
2016-04-12
2019-12-16 2019-10-28 2019-10-24 2019-09-20 2018-02-20 2016-09-15
2019-08-02 2018-12-23
2018-02-16 2018-01-13
2019-05-22 2019-08-30 2019-09-23
2006-11-14 2019-08-31 2018-03-10
2019-10-20 2017-08-30 2018-05-31

Exhibit B, Page 348

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 349 of 352 Pageid#: 1252

voter_id 809012413 Y 510544798 Y 905005761 Y 305024744 Y 905019571 Y 917829138 Y 122404755 Y 205027954 Y 445373331 Y 412018379 Y 204025550 Y 202025277 Y 205002274 Y 404018136 Y 128002138 Y 208002229 Y 221535794 Y
7007585 Y 919517050 Y 302003468 Y 381735701 Y 308037492 Y 201029692 Y 917904351 Y 610013139 Y 504009221 Y
45497540 Y 206022854 Y 920006130 Y 202008873 Y 307033688 Y 207011755 Y 221010765 Y

lname

fname ADAM DA TAN ANTHONY NANCY ETHEL ELIZABETH LUCITA ERNEST JANET ROBERT LOIS ALFRED RUTH HELEN JERRY EMILY LOUISE JOAN ABDUL GLORIA KARLYN DAVID CATHY EDWIN ROY RENA GARLAND CELESTE KATHLEEN LEONARD GEORGE SHIRLEY WILLIAM

dob 1939 1951 1939 1929 1927 1946 1932 1949 1940 1931 1935 1930 1945 1915 1940 1929 1935 1937 1947 1930 1936 1940 1969 1936 1943 1925 1943 1924 1949 1936 1936 1933 1932

date_registered 1980-10-04 2019-01-22 1988-03-28 1980-01-23 1960-08-05 1998-02-12 2013-03-20 2002-07-31 2016-05-12 1984-09-15 1999-06-15 1952-10-04 1985-11-05 1936-10-01 1992-09-28 1982-09-14 2007-09-17 1993-05-26 2003-05-08 1995-07-28 2013-01-31 1970-10-03 1999-05-04 1997-02-21 1988-10-04 1947-04-15 2013-10-03 1984-10-04 2004-10-04 1987-09-03 1979-04-11 1968-05-07 1997-07-17

ssdi_dod 2019-12-11 2019-10-26 2020-01-01 2020-01-29 2018-01-17
2017-02-06 2019-07-15 2018-12-11 2018-12-30 2019-12-29 2019-11-14 2019-10-25 2019-10-19 2018-12-24 2017-08-18 2013-02-15 2019-08-30 2019-12-24 2019-12-02 2019-08-04
2018-11-15 2018-10-28 2019-10-14 2019-06-02 2014-10-24 2018-12-09 2019-08-27
2019-10-31 2018-12-25

obit_dod 2019-12-11
2019-09-26
2019-11-14 2019-10-25
2018-12-24 2017-08-18
2019-08-30
2019-12-02
2018-05-01 2018-11-15 2018-10-28 2019-10-14 2019-06-02
2018-12-09 2019-08-27 2019-10-18 2019-10-24 2019-10-31 2018-12-25

Exhibit B, Page 349

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 350 of 352 Pageid#: 1253

voter_id 603030408 Y 919227778 Y
55340542 Y 46015605 Y 601019792 Y 42068056 Y 602004287 Y 919326540 Y
4007117 Y 501021943 Y 917326050 Y
8004468 Y 808005014 Y 705008744 Y 501024707 Y 918118755 Y
28018058 Y 313706575 Y 407004392 Y 804011252 Y 920159132 Y 405017574 Y 906018959 Y 704023359 Y 920018448 Y 520118608 Y 705005785 Y 304045952 Y 920399343 Y 701027361 Y 919638857 Y 107005309 Y 506009603 Y

lname

fname CHARLES JAE TYON VERNELL THELMA SUSAN VADA DANIEL MAYARD MARGARET LOUIS MARILYN SAMUEL FRANCES ROSALIE ANNIE SANDRA FRANCES GLENNIS ANTONIO WILLIAM PATRICIA MARGARET IRENE CALVIN THOMAS HAROLD PAUL YVONNE ROBERT LAWRENCE CAROL JOHNNY

dob 1934 1935 1927 1937 1935 1951 1933 1952 1940 1942 1926 1942 1935 1928 1933 1935 1946 1939 1934 1952 1947 1935 1937 1935 1942 1953 1954 1930 1988 1925 1948 1944 1939

date_registered 1967-10-06 2004-02-11 2013-01-08 2017-09-21 1968-10-02 2015-11-12 1980-05-15 2002-05-16 1976-05-08 1983-12-01 1995-08-25 1984-07-02 1963-05-04 1968-09-25 1955-12-17 1997-10-06 2001-06-18 2017-10-05 1967-05-10 1996-04-01 2005-08-31 1962-08-20 1979-11-07 1998-01-28 2004-11-13 2008-07-31 1972-03-06 2003-10-06 2006-11-08 2008-06-17 2003-11-25 1974-09-27 1961-06-09

ssdi_dod 2019-10-14 2019-12-05 2017-11-09 2019-09-15
2020-01-11 2019-04-17 2018-12-03 2019-09-04 2020-01-24 2019-08-19
2019-12-23 2020-01-05 2019-12-31 2019-12-17 2019-12-16 2019-11-25 2019-11-12 2019-10-21 2019-10-07 2019-09-28 2019-09-28 2019-08-31 2019-08-21 2019-08-04 2019-04-23 2019-03-24 2019-01-18 2018-12-24 2018-12-05 2018-09-11

obit_dod 2019-10-14
2019-09-01 2017-01-06 2017-08-19
2018-12-03
2019-08-19 2019-12-02
2019-12-17 2019-11-25 2019-11-12
2019-09-28 2019-08-31
2019-04-23 2019-03-24
2018-09-11

Exhibit B, Page 350

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 351 of 352 Pageid#: 1254

voter_id 128000985 Y 608004287 Y
15779387 Y 89847825 Y 919938572 Y 607027155 Y 203006976 Y 918505245 Y 607008934 Y 87766300 Y 113344407 Y 405027385 Y 117211387 Y 596026302 Z 303035796 Z 11184183 Z 307049206 Z 72735938 Z 165169761 Z 917057422 Z 262716781 Z 918787454 Z 226017716 Z 225021617 Z 801001830 Z 253337992 Z 917507956 Z 704012873 Z 919649023 Z 185628691 Z 919906106 Z 64739851 Z 23002215 Z

lname

fname JANE LAUMEN WILLIAM MICHAEL PATRICIA MABLE LOUISE WALTER ALBERTA BOYCE EMIEL KUEN HSIANG LULA AMINA EDWARD NORA JOHN ADHAM WENDY MARK KATINA PETER LOUIS MARY PATRICIA EDWARD KIRSTEN CHARLES SAMUEL MILTON HENRY RICHARD PALMER BETTY

dob 1930 1935 1959 1955 1929 1934 1931 1964 1927 1927 1930 1922 1934 1926 1935 1923 1928 1952 1962 1934 1933 1935 1921 1935 1931 1984 1948 1937 1918 1938 1942 1933 1926

date_registered 1983-02-03 2007-03-14 2017-03-08 2012-05-21 2004-10-01 1997-02-03 1955-12-12 1999-05-14 1981-02-27 2019-01-09 2009-09-25 2004-04-21 2011-12-20 2019-07-30 1980-10-02 2014-10-03 1989-11-18 2015-10-13 2014-01-02 1993-11-05 2014-01-30 2000-05-18 1982-06-11 1985-08-16 2003-08-14 2012-08-14 1996-05-13 1991-08-16 2003-12-15 2008-02-14 2004-09-22 2017-09-26 1952-09-03

ssdi_dod 2018-03-31 2018-02-12 2017-12-09 2017-03-08 2014-11-08 2013-12-18
2018-02-25 2019-08-31 2020-01-29 2019-04-22 2018-12-18 2019-11-30 2020-01-17 2018-12-05 2019-10-26 2020-01-24 2019-04-27 2018-08-17 2019-03-12
2019-11-06 2017-10-17
2018-12-20 2018-12-27
2018-01-28 2016-04-19 2016-10-26
2019-11-28

obit_dod
2018-02-12 2017-12-09 2017-03-08
2013-12-18 2018-12-04
2019-08-31
2018-12-18
2018-12-05 2019-10-26
2018-12-29 2019-11-06 2017-10-17 2019-08-10 2018-12-20 2018-12-27 2019-11-05 2018-01-28
2016-10-26 2019-11-09 2019-08-27 2019-11-28

Exhibit B, Page 351

Case 6:20-cv-00024-NKM Document 48-2 Filed 04/28/20 Page 352 of 352 Pageid#: 1255

voter_id 707002514 Z 918591344 Z 917209249 Z 503030869 Z 221021104 Z 917169483 Z 207019598 Z 602021422 Z 222015246 Z
58277546 Z 605012234 Z 213022114 Z 712316133 Z
17147762 Z 918332545 Z 108019945 Z 311010706 Z

lname

fname MARTIN MICHAEL JOHN JUNE SHIRLEY RUTH ROSE MARTHA ROBERT ALICE JOHN EARL RONALD ROBERT CHRISTINE MICHAEL RICHARD

dob 1934 1938 1938 1924 1931 1927 1924 1924 1927 1928 1919 1925 1945 1993 1946 1931 1933

date_registered 1979-10-06 1999-09-22 1994-10-11 1990-08-15 1988-10-07 1994-09-22 1979-01-16 1999-09-13 1993-10-04 2015-04-20 1979-09-28 2005-10-11 2008-05-12 2011-09-09 1998-08-31 1970-01-27 1986-05-09

ssdi_dod
2019-09-25 2019-12-23
2019-10-19 2018-01-30 2019-12-22 2020-01-14 2019-11-07 2020-01-21 2018-01-20 2016-10-31
2014-11-07 2019-11-06
2018-12-09

obit_dod 2018-12-05 2019-09-25
2016-07-02 2019-10-19 2018-01-30
2019-11-07
2018-01-20
2019-10-14 2014-11-07 2019-11-06 2019-08-07 2018-12-09

Exhibit B, Page 352

 </s> Case 6:20-cv-00024-NKM Document 49 Filed 04/28/20 Page 1 of 12 Pageid#: 1256

UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA
Lynchburg Division

LEAGUE OF WOMEN VOTERS OF

VIRGINIA, et al.,

)

)

Plaintiffs,

)

)

v.

)

)

VIRGINIA STATE BOARD OF ELECTIONS, )

et al.,

)

)

Defendants.

)

Case No. 6:20-cv-00024

MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO MOTION TO INTERVENE

The Defendants oppose the motions to intervene filed by Sheila DeLappe Ferguson, Sandy Burchett, and Diane Crickenberger (Ferguson Intervenors) and by the Republican Party of Virginia, Inc., Vincent E. Falter, Mildred H. Scott, and Thomas N. Turner, Jr. (RPV Intervenors) (all seven collectively referenced as the Movants) for two reasons. First, the Movants lack standing to intervene. To allow the Movants to intervene without showing an injury in fact would have the staggering effect of opening the door for any voter to intervene based on a change in elections procedures. Second, the Movants do not (and cannot) show that they are entitled to intervene as of right or that their intervention should be permitted. The Fourth Circuit has been clear that “where a proposed intervenor’s ultimate objective is the same as that of an existing party, the party’s representation is presumptively adequate . . . .” Stuart v. Huff, 706 F.3d 345, 350 (4th Cir. 2013). The Movants contend—and the Defendants take the Movants at their word—that their objective is to assure the fundamental right to vote and to ensure the integrity of the election. “[W]here the party who shares the intervenor’s objective is a government agency,

Case 6:20-cv-00024-NKM Document 49 Filed 04/28/20 Page 2 of 12 Pageid#: 1257
the intervenor has the burden of making a strong showing of inadequacy.” Id. (emphasis added). Because no such showing has been made here, intervention is inappropriate.
BACKGROUND The Defendants are charged with “supervis[ing] and coordinat[ing] the work of the county and city electoral boards and of the registrars to obtain uniformity in their practices and proceedings and legality and purity in all elections.” Va. Code § 24.2-103(A). As such, the Defendants have a significant, statutory interest in ensuring that elections are conducted consistently by all localities from the day that absentee ballots are made available to qualified voters through the day the final election results are certified. Ballots are to be made available to qualified absentee voters 45 days prior to the election. Va. Code § 24.2-612. Along with the ballots, absentee voters will receive instructions regarding how to mark and return their absentee ballots so that they are considered valid. Va. Code § 24.2-706(4). Under Virginia Code §§ 24.2706 and 24.2-707, a voter who wishes to cast an absentee ballot by mail is required to complete their ballot in the presence of a witness and have the ballot signed by the witness. On March 30, 2020, Governor Ralph Northam issued an Executive Order ordering Virginians to stay at home except for a limited number of circumstances. The Governor stated that, “[w]e are in a public health crisis, and we need everyone to take this seriously and act responsibly …. Our message to Virginians is clear: stay home.”1 Under Virginia Code § 24.2603.1 and Executive Order Fifty-Six (Amended), the congressional primary election in Virginia originally scheduled for June 9 was postponed to June 23.2 Accordingly, the date for ballots to be made available to be made available to qualified absentee voters is Saturday, May 9, 2020,
1 Press Release, Ralph Northam, Governor of Virginia, Governor Northam Issues Statewide Stay at Home Order (Mar. 30, 2020), https://www.governor.virginia.gov/newsroom/all-releases/2020/march/headline-855702-en.html. 2 Va. Exec. Order No. 2020-56 (Amended) (Apr. 24, 2020), https://www.governor.virginia.gov/media/governorvirginiagov/executive-actions/EO-56-AMENDED---PostponingJune-9,-2020-Primary-Election-to-June-23,-2020-Due-to-Novel-Coronavirus-(COVID-19).pdf.
2

Case 6:20-cv-00024-NKM Document 49 Filed 04/28/20 Page 3 of 12 Pageid#: 1258
unless the relevant general registrar’s office is not open on that date, in which case, for that locality, it shall be May 8, 2020. See id.; see also Va. Code § 24.2-612.
STANDARD Federal Rule of Civil Procedure 24 sets forth two methods for a nonparty to intervene: (1) intervention as of right under Rule 24(a); and (2) permissive intervention under Rule 24(b). Movants seek both types of intervention. As recognized by the Fourth Circuit, intervention must be permitted as a matter of right under Rule 24(a) if a movant can demonstrate “(1) an interest in the subject matter of the action; (2) that the protection of this interest would be impaired because of the action; and (3) that the applicant’s interest is not adequately represented by existing parties to the litigation.” Teague v. Bakker, 931 F.2d 259, 260-61 (4th Cir. 1991). The Fourth Circuit has also recognized that, if intervention of right is not warranted, a court may still allow a movant “to intervene permissively under Rule 24(b), although in that case the court must consider ‘whether the intervention will unduly delay or prejudice the adjudication of the original parties’ rights.’” Stuart, 706 F.3d at 349.
ARGUMENT I. Movants lack standing to intervene in this case.
As an initial matter, Movants lack standing to interpose themselves in the case. As the D.C. Circuit explained, “[i]ntervenors become full-blown parties to litigation, and so all wouldbe intervenors must demonstrate Article III standing.” Old Dominion Elec. Coop. v. Fed. Energy Regulatory Comm’n, 892 F.3d 1223, 1233 n.2 (D.C. Cir. 2018) (noting “our settled precedent that all intervenors must demonstrate Article III standing”). And “where a party tries to intervene as another defendant,” it makes sense to “require[] it to demonstrate Article III standing,”
3

Case 6:20-cv-00024-NKM Document 49 Filed 04/28/20 Page 4 of 12 Pageid#: 1259
because “otherwise any organization or individual with only a philosophic identification with a
defendant—or a concern with a possible unfavorable precedent—could attempt to intervene and
influence the course of litigation. . . . The standing inquiry for an intervening-defendant is the
same as for a plaintiff: the intervenor must show injury in fact, causation, and redressability.”
Crossroads Grassroots Policy Strategies v. Fed. Election Comm’n, 788 F.3d 312, 316 (D.C. Cir.
2015) (citations omitted); see also Mausolf v. Babbitt, 85 F.3d 1295, 1300 (8th Cir. 1996) (“We
conclude that the Constitution requires that prospective intervenors have Article III standing to
litigate their claims in federal court.”).3
The Movants fail to show that removal of the witness requirement will cause them any
injury in fact.4 While the Movants allege that removal of the witness requirement could
potentially lead to dilution of their votes if individuals fraudulently vote absentee, they have not
provided any substantive evidence to corroborate the allegation. Accordingly, Movants have not
shown any injury in fact that would give them standing to intervene in this case.
The issue of standing is particularly important in a case like this one where one group of
proposed intervenors seeks to inject an unrelated cross-claim into the litigation.5 Permitting
intervention and the proposed cross-claim here would allow Movants to sidestep Article III
3 See also Waterkeeper All., Inc. v. Wheeler, 330 F.R.D. 1, 6 (D.D.C. 2018) (“Prospective defendant-intervenors must also demonstrate Article III standing by establishing injury in fact, causation, and redressability.”); Campaign Legal Ctr. v. Fed. Election Comm’n, No. CV 19-2336 (JEB), 2019 WL 6051549, at *2 (D.D.C. Nov. 15, 2019) (“The standing inquiry for an intervening defendant is the same as for a plaintiff: the intervenor must show injury in fact, causation, and redressability.”); cf. Ruiz v. Estelle, 161 F.3d 814, 830 (5th Cir. 1998) (“we hold that Article III does not require intervenors to independently possess standing where the intervention is into a subsisting and continuing Article III case or controversy and the ultimate relief sought by the intervenors is also being sought by at least one subsisting party with standing to do so”). 4 The individual voter Plaintiffs, by contrast, have asserted that they will be hindered from casting absentee ballots in light of the witness requirement due to concerns for their individual health and safety. And, because the individual voter Plaintiffs have standing, the Court need not consider the League of Women Voters of Virginia Plaintiff’s standing. Village of Arlington Heights v. Metro. Hous. Dev. Corp., 429 U.S. 252, 264 (1977) (holding because “one individual plaintiff . . . has demonstrated standing,” the Court “need not consider whether the other individual and corporate plaintiffs have standing to maintain the suit”). The Movants, by contrast, have only speculatively asserted that they will be injured if the witness requirement is enjoined and other qualified voters are permitted to cast absentee ballots without endangering their health and safety during the COVID-19 pandemic. 5 See infra § II.B.
4

Case 6:20-cv-00024-NKM Document 49 Filed 04/28/20 Page 5 of 12 Pageid#: 1260
standing barriers that would otherwise prevent them from bringing those claims as plaintiffs. And the implications of allowing Movants to intervene on their theories in a case relating to elections are staggering. Effectively, it would recognize that any voter could intervene in a suit involving election procedures.
We would also note that the Plaintiffs and Defendants have requested that this Court enter a partial consent judgment and decree that would end the litigation in this case with respect to the June primary. Other courts have explained that, when original parties no longer seek to pursue litigation, “[i]t is clear that an intervenor, whether permissive or as of right, must have Article III standing in order to continue litigating if the original parties do not do so.” Mangual v. Rotger-Sabat, 317 F.3d 45, 61 (1st Cir. 2003); see also Chiles v. Thornburgh, 865 F.2d 1197, 1213 (11th Cir. 1989) (“We therefore hold that a party seeking to intervene need not demonstrate that he has standing in addition to meeting the requirements of Rule 24 as long as there exists a justiciable case and controversy between the parties already in the lawsuit.”) (emphasis added). To the extent that the Movants wish to continue litigation regarding the witness requirement for the June primary as applied to voters who believe they may not safely have a witness present while completing their ballot, the Movants must demonstrate that they have Article III standing to do so. To allow otherwise would permit a party not subject to the original case to use it as a vehicle to pursue its own objectives. II. Movants are not entitled to either form of intervention.
Even if Movants had standing to intervene, they fail to meet the requirements for intervention as of right, and permissive intervention should likewise be denied. “Intervention is a procedural device that attempts to accommodate two competing policies: efficiently administrating legal disputes by resolving all related issues in one lawsuit, on the one hand, and
5

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keeping a single lawsuit from becoming unnecessarily complex, unwieldy or prolonged, on the other hand.” United States v. Pitney Bowes, Inc., 25 F.3d 66, 69 (2d Cir. 1994). Protecting litigation from becoming unnecessarily complex, unwieldy, or prolonged is particularly important in a case involving an upcoming election where the burdens associated with adding more parties—including a party seeking to file a crossclaim—is especially painful. Movants’ arguments supporting both forms of intervention do not establish why they will be insufficiently supported by the Defendants. The motion should therefore be denied.
A. Movants are not entitled to intervention as of right under Rule 24(a). The Movants assure the Court that their interest is to ensure the integrity of Virginia’s election. Protecting these interests is squarely within Defendants’ roles, and no one is better equipped to ensure the integrity of Virginia’s elections than Defendants. “Where parties share the same ultimate objective, differences in litigation strategy do not normally justify intervention.” Arakaki v. Cayetano, 324 F.3d 1078, 1086 (9th Cir. 2003); see also Saldano v. Roach, 363 F.3d 545, 555 (5th Cir. 2004) (“Simply because the [Movants] would have made” or may at some point would like to make “a different decision does not mean that the Attorney General is inadequately representing the State’s interest—and hence, the [Movants’] claimed interest[.]”). As required by Virginia Code § 24.2-103(A), the interest of the Defendants is to “supervise and coordinate the work of the county and city electoral boards and of the registrars to obtain uniformity in their practices and proceedings and legality and purity in all elections.” (emphasis added). Further, “[t]he Board is charged with carrying out Virginia's election laws.” Miller v. Brown, 462 F.3d 312, 321 (4th Cir. 2006). Under Virginia’s elections laws, “[a]ny person who is registered to vote and is a qualified voter shall be entitled to vote in the precinct where he resides.” Va. Code § 24.2-400. Accordingly, the Defendants, in their duties with
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respect to ensuring the legality of elections and ensuring that any qualified voter be entitled to vote, are required to ensure that all qualified voters are capable of having their ballots counted.
To the extent that the Movants may be interested in advancing different arguments than the Defendants in order to meet that objective, these differences would be nothing more than a “reasonable litigation decision[ ] made by the Attorney General with which [the prospective intervenors] disagree.” Stuart, 706 F.3d at 354–55. “Such differences of opinion cannot be sufficient to warrant intervention as of right,” and “the harms that the contrary rule would inflict upon the efficiency of the judicial system and the government’s representative function are alltoo-obvious.” Id. at 355; see also United States v. South Bend Cmty. Sch. Corp., 692 F.2d 623, 627 (7th Cir. 1982) (“[T]hat a proposed intervenor might . . . [take] a different view of the applicable law does not mean that the [government does] not adequately represent its interests in the litigation.” (quotation marks omitted)).
The Movants fail to make the more exacting showing of inadequacy required in the context of a government party. Stuart, 706 F.3d at 351 (“[J]oin[ing] our fellow courts of appeals in holding that the putative intervenor must mount a strong showing of inadequacy [when the government is a party]). The Fourth Circuit has been clear that not requiring intervenors to make a strong showing of inadequacy “would place a severe and unnecessary burden on government agencies as they seek to fulfill their basic duty of representing the people in matters of public litigation.” Id.
The Defendants—represented by the Commonwealth’s Attorney General—are ideally placed to robustly protect the propriety of Virginia’s elections.6 As stated by the Commonwealth’s Attorney General, Mark Herring, “[f]ree and fair elections are at the core of
6 See also American Nat. Bank & Tr. Co. of Chicago v. City of Chicago, 865 F.2d 144, 148 (7th Cir. 1989) (rejecting argument that proposed intervenor could “make any concrete showing of inadequacy of representation” by arguing that “because of certain political considerations, [defendant] may be less than zealous in the defense of this cause”).
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our democracy and no Virginian should have to choose between their health and exercising their right to vote.”7 If the interest of the Movants is to protect the integrity of Virginia elections, as is the interest of the Commonwealth, the Movants fail to demonstrate the inability of the Defendants to protect that interest.8
B. Permissive intervention should be rejected for this same reason. Permissive intervention should be denied for the same reason there is no basis for intervention as of right. See Virginia Uranium, Inc. v. McAuliffe, No. 4:15-CV-00031, 2015 WL 6143105, at *4 (W.D. Va. Oct. 19, 2015) (“[W]here . . . intervention as of right is decided based on the government’s adequate representation, the case for permissive intervention diminishes or disappears entirely.”) (quoting Tutein v. Daley, 43 F.Supp.2d 113, 131 (D. Mass. 1999)). Even if the Movants could establish the elements of permissive intervention, permissive intervention is inappropriate if this Court concludes that intervention would not provide an appreciable “benefit to the process, the litigants, or the court,” Lee v. Virginia Bd. of Elections, 2015 WL 5178993, at *4 (E.D. Va. Sept. 4, 2015), or would “unduly delay or prejudice the adjudication of the original parties’ rights.” Fed. R. Civ. P. 24(b)(3). When “intervention as of right is decided based on the government’s adequate representation, the case for permissive intervention diminishes or disappears entirely.” Tutein, 43 F. Supp. 2d at 131 (citation omitted); see generally Hoots v. Pennsylvania, 672 F.2d 1133, 1136 (3d Cir. 1982) (Where “the interests of the applicant in every manner match those of an existing party and the party’s representation is deemed adequate, the district court is well within its
7 Press Release, Ralph Northam, Governor of Virginia, Governor Northam Announces Plans to Postpone Upcoming Virginia Elections in Response to COVID-19 (Apr. 8, 2020), https://www.governor.virginia.gov/newsroom/allreleases/2020/april/headline-855995-en.html. 8 To the extent the Movants-individual voters assert a broad “right to vote” as the interest justifying their intervention, see ECF 23 at 3, Defendants are best equipped to protect the right to vote (just as they are best equipped to protect election integrity). Accepting the Movants-individual voters’ position that simply invoking the broad “right to vote” is sufficient to merit intervention as of right, could set the stage for any voter have a right to intervene in any elections case.
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discretion in deciding that the applicant’s contributions to the proceedings would be superfluous and that any resulting delay would be ‘undue.’”). As established above, the interest of the Defendants in this action is to defend the integrity of elections and protect the right to vote in the Commonwealth, which the Movants have also asserted as their interest. ECF 29, at 1–2; ECF 23 at 3. The Movants have shown no reason why the representation by the Defendants of that interest would be inadequate. As such, intervention by the Movants is unnecessary and should be denied. Further, Ferguson Voters seek to inject into this litigation a cross-claim against the Defendants with respect to an absentee voting requirement that is wholly unrelated to the witness requirement. Rule 24(b)(3) requires that the intervenor “claim[] an interest relating to the property or transaction that is the subject of the action, and is so situated that disposing of the action may as a practical matter impair or impede the movant’s ability to protect its interest, unless existing parties adequately represent that interest.” The reasons that qualify a voter to cast an absentee ballot are unrelated to how a ballot is marked.9 To permit litigation of that unrelated claim would not be germane to the issue in this case—the witness requirement—and would cause delay that could increase voter and election official confusion a little more than a week before absentee ballots for the June primary must be mailed to voters. Therefore, the cross-claim would not provide “benefit to the process, the litigants, or the court” and gives further reason to deny the motion to intervention of the Ferguson Voters. And, for the reasons discussed above, Ferguson Voters should not be permitted to sidestep Article III standing requirements by intervening as defendants.
* * *
9 The reasons for which a voter may cast an absentee ballot are governed under Va. Code §§ 24.2-700, 24.2-701, 24.2-701.1, and 24.2-703. The procedures that an individual must take in completing an absentee ballot are governed under Va. Code §§ 24.2-706 and 24.2-707.
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It bears noting that the Movants are not without a medium to raise their concerns. To the extent that the Movants will at some point represent a perspective distinct from the Defendants’ and may be helpful to this Court’s resolution of this matter, that perspective may brought to bear through the filing of a brief amicus curiae. Indeed, “[n]umerous cases,” including in the Fourth Circuit, “support the proposition that allowing a proposed intervenor to file an amicus brief is an adequate alternative to permissive intervention.” McHenry v. Comm’r, 677 F.3d 214, 227 (4th Cir. 2012) (citing cases); see also Stuart, 706 F.3d at 355.
CONCLUSION For these reasons, the Movants’ motions to intervene should be denied. First, Movants have failed to demonstrate injury in fact and therefore lack standing to intervene. Second, the Movants share the same objective as the Defendants: protecting the integrity of Virginia elections and the right to vote. The Movants have not demonstrated why the Defendants will not adequately protect that interest, and, thus, have not shown that they meet the requirements to intervene as of right. Third, for the same reasons that the Movants should not be permitted to intervene as of right, the Movants fail to meet their burden for permissive intervention. Further, permissive intervention may unduly delay this litigation in a manner that could jeopardize absentee voting for the June primary. Finally, to the extent they have a unique perspective the Movants may raise their arguments in an amicus brief. For the reasons stated above, the Defendants would request that the Movants’ motions to intervene be dismissed.
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MARK R. HERRING Attorney General of Virginia /s/ Carol L. Lewis CAROL L. LEWIS (VSB #92362) MICHELLE S. KALLEN (VSB #93286) HEATHER HAYS LOCKERMAN (VSB #65535) Office of the Attorney General 202 North Ninth Street Richmond, Virginia 23219 804-692-0558 (telephone) 804-692-1647 (facsimile) clewis@oag.state.va.us Attorneys for Robert H. Brink, John O’Bannon, Jamilah D. LeCruise and Christopher E. Piper in their official capacities, and the Virginia State Board of Elections
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Case 6:20-cv-00024-NKM Document 49 Filed 04/28/20 Page 12 of 12 Pageid#: 1267 CERTIFICATE OF SERVICE
Pursuant to Local Rule 7(g)(3), I hereby certify that on April 28, 2020, I will file this document electronically through the Court’s CM/ECF system, which will effect service on all counsel who have appeared.
/s/ Carol L. Lewis Carol L. Lewis Counsel for Defendants, for Robert H. Brink, John O’Bannon, Jamilah D. LeCruise and Christopher E. Piper in their official capacities, and the Virginia State Board of Elections
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 </s> Case 6:20-cv-00024-NKM Document 53 Filed 04/29/20 Page 1 of 14 Pageid#: 1293

United States District Court for the Western District of Virginia
Lynchburg Division

League of Women Voters of Virginia; Katherine D. Crowley; Erikka Goff; and Seijra Toogood,,

Plaintiffs,

v.

Civ. No. 6:20-cv-00024

Virginia State Board of Elections; Robert H. Brink, John O’Bannon, and Jamilah D. Lecruise, in their official capacities as Chairman, Vice-Chair, and Secretary of the Virginia State Board of Elections, respectively; and Christopher E. Piper, in his official capacity as Commissioner of the Virginia Department Of Elections,

Reply Brief in Support of Motion to Intervene

Defendants.

Reply Brief in Support of Motion to Intervene

On April 23, 2020, Proposed Intervening Voter Defendants1 Sheila DeLappe Ferguson, Sandy Burchett, and Diane Crickenberger filed a Motion to Interevene—seeking to defend their fundamental right to vote. Doc. 22. On April 28, 2020, Plaintiffs and Commonwealth Defendants each filed an Opposition to Voter Defendants’ Motion. Doc. 40, 49.2 Voter Defendants now timely file this reply.
Argument Voter Defendants have met all of the requirements of Fed. R. Civ. 24, and should be

1 While intervention has not yet been granted, “Proposed Intervening Voter Defendants” will simply be referred to as “Voter Defendants” throughout this brief for length and clarity.
2 Where applicable, Voter Defendants will refer to Plaintiffs and Commonwealth Defendants collectively as the “parties.”

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permitted to intervene. Indeed, Voter Defendants should be given an opportunity to be heard on their significant harms. First, before this case was filed, Commonwealth Defendants harmed Voter Defendants by implementing their unlawful interpretation of “[m]y disability or illness.” This unlawful interpretation gave rise to Plaintiffs’ claims, as many more people would be seeking absentee ballots and would have to comply Anti-Fraud Witness Requirement. And, the Commonwealth Defendants’ directly adverse position to Voter Defendants also gave rise to their crossclaim. Second, after this case was filed, Commonwealth Defendants took another step to harm Voter Defendants—by not defending the Commonwealth’s statutes and cementing the violation of Voter Defendants fundamental right to vote in their proposed consent decree. While the Commonwealth Defendants’ job is to comply with and defend Commonwealth law, they have done neither. Accordingly, Voter Defendants are the only ones defending their rights.
Voter Defendants deserve to be heard and to have their rights protected, which can only be done through intervention. Granting intervention does not change the current scheduling order and does not delay this case, but it does give Voter Defendants an opportunity to protect their fundamental right to vote.
The parties suggestion that Voter Defendants be allowed to file an amicus brief, rather than be granted leave to intervene (Doc. 40, Pageid#435, Doc. 49, Pageid#1265), is in direct contradiction to the plain language of Fed. R. Civ. P. 24. Intervention, not leave to file an amicus brief, is proper if the movant meets the requirements of Fed. R. Civ. P. 24. As shown below, Voters meet both the requirements for intervention as of right and permissive intervention, so their Motion should be granted.
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I. The voters are intervenors by right. A. Voters’ motion is timely.
The parties do not argue that Voter Defendants’ motion is untimely. Thus, this factor is conceded. Voter Defendants have timely intervened in this action. B. Voters have an interest in this action.
Plaintiffs argue that Voter Defendants do not have a personal interest in this case. Doc. 40, Pageid#420. The parties also argue that Voter Defendants cannot satisfy standing requirements. Doc. 40, Pageid#429-30, Doc. 49, Pageid# 1258. Both are wrong. For the reasons detailed below, Voter Defendants’ harms are sufficient to establish both a personal interest in this case and standing.
Voter Defendants established that the requested relief violates their right to vote by removing safeguards against fraudulent votes that dilute legal votes. The substantial risk and high likelihood of illegal votes is the very harm for which that safeguard was instituted by the General Assembly. But the requested relief removes this vital safeguard, thereby creating a cognizable violation of Voters Defendants’ right to vote. Doc. 37, Pageid#398-403.
Harm. Voter Defendants have a cognizable, imminent harm. The harm is cognizable because the safeguard that will be removed was designed by the General Assembly to protect against fraudulent votes that dilute Voter Defendants’ votes. Voter Defendants explained that the fundamental right to vote can be denied in a variety of ways, and one of those is debasement by vote dilution resulting from inadequate safeguards to prevent illegal votes. Doc. 37, Pageid#399403. And the harm of removing of a vital safeguard that the General Assembly imposed to prevent illegal voting creates a substantial risk of such vote dilution, which is a cognizable harm.

Motion to Intervene Reply

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Id. Voter Defendants described the safeguard for absentee voting (the Anti-Fraud Witness Requirement) (Doc. 37, Pageid#383-384), but that will be gone with the requested relief. The result of removing the General Assembly’s safeguard is a substantial risk of vote fraud, making it highly likely that illegal voting will occur. Contrary to the parties assertions (Doc. 40, Pageid#424-25, Doc. 49, Pageid#1259), Voter Defendants need not prove that it will occur, the harm is well established and the removal of the General Assembly’s safeguard suffices to make that harm cognizable. If a voter is 1 in 10 legal votes, her vote is worth 1/10 of the whole, but if an extra 10 illegal votes are allowed, her vote is debased to 1/20 of the whole—that is debasement by vote dilution. A substantial vote dilution risk caused by removal of a safeguard is a cognizable harm, but “‘a substantial risk that the harm will occur,’” suffices for standing. Susan B. Anthony List v. Driehaus, 573 U.S. 149, 158 (2014). And that substantial risk of harm was the precise harm that Bush v. Gore, 531 U.S. 98 (2000), held that the Florida Supreme Court had imposed by its lack of required “safeguards” to assure the integrity of the election and prevent vote dilution. Id. at 102; see Doc. 37, Pageid# 400-402 (discussing this and identifying the precise harm of removing necessary “safeguards”). And based on that lack of safeguards to prevent vote dilution, the Court halted the vote counting. The Supreme Court didn’t wait until proven vote dilution happened, nor was it required to, and it didn’t require the plaintiffs (who were voters, and political committees, and candidates) to prove actual vote dilution because the lack of safeguards and a resulting substantial risk of vote dilution was a sufficient and cognizable harm. And it is no answer to say that Bush was a one-time-only decision, because that opinion relied on a vote-dilution analysis already well established that applies here, and the Bush analysis has been cited by courts since then. See, e.g., Northeast Ohio Coalition v. Husted, 696

Motion to Intervene Reply

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F.3d 580, 592, 598 (6th Cir. 2012).3 The cognizable harm of vote dilution by lack of safeguards is an imminent injury. On
May 8, 2020, when the absentee ballots (without the Anti-Fraud Witness Requirement) are mailed to active, registered voters, the harms of sending unlawful ballots and of voter confusion occur, see, e.g., Purcell v. Gonzalez, 549 U.S. 1, 4-5 (2006) (confusion harm),4 because recipients will think that they may lawfully vote those ballots without a witness signature when those ballots are not lawful. A second harm occurs when voters actually mail or deliver those absentee ballots, because then the violation of Voters Defendants’ right to vote actually occurs, given the lack of General Assembly-prescribed safeguards that result in the cognizable risks of (a) vote fraud and debasement and dilution of Voter Defendants’ right to vote and (b) an election without public confidence that it is legitimate. A third harm occurs when those unlawful absentee ballots are counted, which seals the vote-dilution and legitimacy harms in place, absent a new election under proper safeguards. Voters need not await some after-election evidence of illegal voting and consequent vote dilution and seek a new election.
Though Voter Defendants’ harm is fully cognizable as a matter of law, given the removal of a vital safeguard against vote fraud that the General Assembly has found to be necessary in Virginia, the problem with absentee ballots is readily documented. Virginia history is riddled with examples of voter fraud. Voter Defendants presented a sampling of the absentee voter fraud

3 Defendants say there is no personal interest in this case because they are not being “deprived the right to vote[.]” Doc. 40, Pageid#422. But that misunderstands the harm claimed.

4 Plaintiffs argue that Purcell is not applicable because this case will be decided 7 weeks before the election (Doc. 40, Pageid#428), but they fail to acknowledge that the Court’s decision is set to come just 4 days before absentee ballots will be sent out. These last minute changes are exactly the type of harm Purcell prohibits.

Motion to Intervene Reply

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issues in the Commonwealth starting as early as the 1960s and continuing until more recently. Doc. 37, Pageid#382-383. And voter fraud issues have also occurred all of the county. The following are some examples. First, vote buying, coercion, and fraud within the absentee voting process occurred in Rio Grande Valley Texas, where several “politiqueras” workers charged with collecting ballots directly from voters–were arrested under charges of buying votes for specific candidates.5 The New York Times reports that vote buying and fraud became commonplace among Rio Grande Valley politiqueras and many came to expect payment for votes. Id. One worker estimated that over 2,000 votes were bought in 2012 elections. Id. In U.S. v. Brown, Noxubee County, Mississippi absentee ballots were required to be notarized, so a group of notaries was sent to steal ballots from mailboxes and fill them out fraudulently. 494 F. Supp. 2d 440, 457 (2007). In the 2018 North Carolina election for the 9th Congressional District,6 multiple arrests7 were made over an election fraud network of individuals who reportedly altered, forged, and/or collected ballots from voters. Additionally, The Daily Signal reported on 15 elections thrown out because of mail-in voting fraud.8 In some cases, blank

5 Manny Fernandez, Texas Vote-Buying Case Casts Glare on Tradition of Election Day Goads, The New York Times, Jan. 12, 2014, https://www.nytimes.com/2014/01/13/us/politics/texas-vote-buying-case-casts-glare-ontradition-of-election-day-goads.html (last visited Apr. 27, 2020).

6 Philip Elliott, Why North Carolina’s Election Fraud Hurts American Democracy, Time USA Magazine, February 22, 2019, https://time.com/5535292/north-carolina-election-fraud/ (last visited Apr 27, 2020).

7 Richard Gonzales, North Carolina GOP Operative Faces New Felony Charges That Allege Ballot Fraud, National Public Radio, July 30, 2019, https://www.npr.org/2019/07/30/746 800630/north-carolina-gop-operative-faces-new-felony-charges-that-allege-ballot-fraud (last visited Apr 27, 2020).

8 Fred Lucas, 15 Election Results That Were Tossed Over Fraudulent Mail-In Ballots, The Daily Signal (2020),

Motion to Intervene Reply

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ballots were stolen from mailboxes and filled out by fraudsters for a specific candidate. Id. In other cases, voters were offered “assistance” as a ruse to fill out mail-in ballots for a different candidate than the voter instructed. Id.
Second, mail-in ballots can be filled out in private by someone other than the voter or someone subjecting to undue influence. In Oregon, a survey found that 5% of polled voters admitted that someone else filled out their ballot.9
Third, absentee ballots have been filled out fraudulently for ineligible, false, impersonated, or duplicate voter registrations. Investor’s Business Daily reports there are about 3.5 million more registered voters than living adults in the United States as of 2015.10 This data comes from the “Judicial Watch’s Election Integrity Project [which] looked at data from 2011 to 2015 produced by the U.S. Census Bureau’s American Community Survey, along with data from the federal Election Assistance Commission.” Id. According to the Oregon Catalyst, this is exemplified in the case of a voter in Oregon who plead guilty to voter fraud after casting multiple ballots in the name of his deceased son.11 It was also exemplified in the Commonwealth

https://www.dailysignal.com/2020/04/21/15-election-results-that-were-thrown-out-because-of-fr audulent-mail-in-ballots/ (last visited Apr 27, 2020).

9 A ‘Modern’ Democracy That Can’t Count Votes, Los Angeles Times, December 11, 2000, https://www.latimes.com/archives/la-xpm-2000-dec-11-mn-64090-story.html (last visited Apr. 27, 2020).

10 U.S. Has 3.5 Million More Registered Voters Than Live Adults — A Red Flag For Electoral Fraud, Investor's Business Daily, August 16, 2017, https://www.investors.com/politic s/editorials/u-s-has-3-5-million-more-registered-voters-than-live-adults-a-red-flag-for-electoral-f raud/ (last visited Apr 27, 2020).

11 Oregon AG gets guilty plea voter fraud case, Oregon Catalyst, September 18, 2010, https://oregoncatalyst.com/3510-oregon-ag-gets-guilty-plea-voter-fraud-case.html (last visited Apr 27, 2020).

Motion to Intervene Reply

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when a Virginia man attempted to cast ballots for both himself and his deceased wife.12 In sum, the harm Voters claim is concrete, imminent, and well-established in controlling
law. Causation. Voters’ cognizable harm of vote dilution is readily traceable to requested
relief, because it seeks to strip the vital legislated safeguard, the lack of which creates the cognizable substantial risk of vote dilution by illegal votes.
Redressability. The requested relief will redress the injury because it will prevent the removal of the Anti-Fraud Witness Requirement, which is the source of Voters Defendants’ harm of vote dilution.
In sum regarding standing, all elements are readily met and were self-evident in Voters Defendants’ Motion to Intervene (Doc. 22) and Opposition to Plaintiffs’ Preliminary Injunction Motion (Doc. 37). So Voters have standing.
Plaintiffs attempt to dismiss Voter Defendants’ right as a generalized interest. Doc. 40, Pageid#420-426. But this attempt cannot be reconciled with the Supreme Court’s conclusion that “[t]he right to vote is personal,” and includes protection against dilution and disenfranchisement. Reynolds v. Sims, 377 U.S. 533, 555, 561 (1964). And disenfranchisement is a severe burden that is personal to the person disenfranchised.13 So voters experiencing it have standing to challenge government action that disenfranchises them, including by posing a substantial risk of doing so. Voter Defendants have established a personal interest, not a generalized grievance. So this case

12 Doc. 37, PageID#383.

13Disenfranchisement is a severe burden. See, e.g., League of Women Voters of N.C. v. North Carolina, 769 F.3d 224, 244 (4th Cir. 2014); Ne. Ohio Coal. for the Homeless v. Husted, 696 F.3d 580, 597 (6th Cir. 2012).

Motion to Intervene Reply

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is not like Plaintiffs’ cited cases. Doc. 40, Pageid#421. Moreover, Voter Defendants’ standing discussion shows why their harm is a personal interest and not a generalized grievance. See supra at 2-8.
Allowing voter intervention is not uncommon. In fact, Voters have been permitted to intervene in many cases. See, e.g., Reynolds, 377 U.S. 433; Democratic Nat’l Comm. v. Republican Nat’l Comm., 543 U.S. 1304 (2004); Spencer v. Pugh, 543 U.S. 1301 (2004); Abrams v. Johnson, 521 U.S. 74 (1997); Lopez v. Montery County, 519 U.S. 9 (1996); United States v. Mississippi, 444 U.S. 1050 (1980); Wise v. Lipscomb, 434 U.S. 1329 (1977); Bullock v. Carter, 405 U.S. 134 (1972); Gore v. Harris, 772 So. 2d 143 (Fla. 2000); Ward v. Columbus County, 782 F. Supp. 1097 (E.D.N.C. 1991); League of Women Voters of N.C. v. North Carolina, 769 F.3d 224 (4th Cir. 2014); Bates v. Jones, 127 F.3d 870 (9th Cir. 1997); Marks v. Stinson, 19 F.3d 873 (3d Cir. 1994); N.C. State Conference of the NAACP v. McCrory, 182 F. Supp. 3d 320 (M.D.N.C. 2016); Navajo Nation v. Ariz. Indep. Redistricting Comm’n, 230 F. Supp. 2d 998, 1000 (D. Ariz. 2002); Shaw v. Hunt, 861 F. Supp. 408 (E.D.N.C. 1994); Goines v. Heiskell, 362 F. Supp. 313 (S.D. W. Va. 1973). Likewise, here intervention is both proper and necessary.
In sum, Voters do have standing to bring their vote-dilution claim and they have established a personalized harm. C. The requested relief impairs and impedes Voters’ ability to protect their interests.
Without intervention, Voter Defendants have no ability to protect their personal interests. And if Plaintiffs were to succeed in obtaining their requested relief, Voter’s interests would be significantly impaired and impeded. So this prong is satisfied.

Motion to Intervene Reply

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D. The Commonwealth Defendants are directly adverse to Voter Defendants. Voter Defendants need only “show[ ] that representation of its interest ‘may be’
inadequate.” United Guar. Residential Ins. Co. v. Phila. Sav. Fund Soc’y, 819 F.2d 473, 475 (4th Cir. 1987) (citing Trbovich v. UMW, 404 U.S. 528, 538, n. 10 (1972)). “The burden of making this showing should be treated as ‘minimal.’” Id. at 475. While Voter Defendants acknowledge that when the government is a defendant, they must make a “strong showing” of inadequacy of representation, Stuart v. Huff, 706 F.3d 345, 352 (4th Cir. 2013), this burden can be met by “showing of adverse interests, collusion, or nonfeasance” id. at 350. Voter Defendants have shown both adverse interests and nonfeasance.
Voter Defendants have more than satisfied this minimal burden. In fact, it is difficult to comprehend a more “‘strong showing’ of inadequacy of representation” (see Doc. 40, Pageid# 431; see also Doc. 49, Pageid#1262) than this case. Defendants are not just inadequately representing Voter Defendants, they are taking a position directly adverse to Voter Defendants’ personal interest. First, Commonwealth Defendants have submitted a Joint Motion for Entry of Partial Consent Judgment and Decree (Doc. 35), so Commonwealth Defendants are not even attempting to defend Voter Defendants’ interest. Second, Commonwealth Defendants’ position regarding the interpretation of “[m]y disability or illness” is directly adverse to Voters Defendants’ position. This interpretation is unconstitutional and violates Voter Defendants’ right to vote, so Voter Defendants seek to bring their cross claim against Commonwealth Defendants.14 Moreover, the Commonwealth Defendants refusal to defend this case should be

14 For the reasons in Part I.B, Voter Defendants have standing to bring their cross claim. Plaintiffs argue that based on their places of residence, Voter Defendants do not have a primary on June 23rd. Doc. 40, Pageid#430 But there is also a statewide Republican June 23rd primary for Senate. See https://www.elections.virginia.gov/media/castyourballot/candidatelist/June-2020-

Motion to Intervene Reply

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considered nonfeasance—which is also sufficient to show inadequacy of representation. See Stuart, 706 F.3d at 350.
Plaintiffs attempt to shoehorn this clear adversity and nonfeasance into a “different approach.” Doc. 40, Pageid#431. But the Commonwealth Defendants aren’t defending the laws at all.15 And because Voter Defendants have a legally protected interest in this case (see Part I.B), they have a right to defend against the requested relief. Thus, Plaintiffs’ reliance on Stotts v. Memphis Fire Dept., 679 F.2d 579 (6th Cir. 1982) is misplaced (as proposed intervenors in that case did not have a protected interest).
Thus, this adversity between Commonwealth Defendants and Voter Defendants satisfies this prong.
II. In the alternative, the voters meet all the requirements for permissive intervention. Even if this Court determines that Voters cannot intervene as of right, Voters qualify for
permissive intervention. Fed. R. Civ. P. 24(b).16 A. The Voters’ defenses and claims share a common question of law with the main
action. The parties do not attempt to rebut that the Voter Defendants’ defenses share a common question of law with the main action. Thus, they have conceded this factor as to Voter

Primary-Candidates-List-(4)-1.pdf at 3.

15 Commonwealth Defendants argue that they are “best equipped to protect” Voter Defendants’ right to vote. Doc. 49, Pageid#1263. But Commonwealth Defendants aren’t defending that right, their consenting to the very harm that violates Voter Defendants’ fundamental right to vote.

16 Commonwealth Defendants argue that permissive intervention should also be denied when “intervention as of right is decided based on the government’s adequate representation[.]” Doc. 49, Pageid#1263. But as shown, Commonwealth Defendants’ position is directly adverse to Voter Defendants, so Voter Defendants are not adequately represented. See Part I.D.

Motion to Intervene Reply

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Defendants’ defenses. Likewise, Plaintiffs do not attempt to rebut that Voter Defendants’ claims share a
common question of law with the main action, so Plaintiffs have conceded this factor as to Voter Defendants’ claims.
Commonwealth Defendants, on the other hand, attempt to argue that Voter Defendants’ cross claim is “wholly unrelated to the witness requirement.” Doc. 49, Pageid#1264. But Commonwealth Defendants fail to acknowledge that the claim of who can obtain an absentee ballot is directly related to if that ballot is properly cast. Moreover, the crossclaim arises out of the same facts, same code sections, same fundamental rights, and same case law as Plaintiffs’ claims, so they clearly share a common question of law. B. Voters’ Motion is timely.
The parties do not argue that Voter Defendants’ motion is untimely. Thus, this factor is conceded. Voter Defendants’ have timely intervened in this action. C. Voters’ intervention will not cause any undue delay or prejudice.
Plaintiffs claim that delay will result if Voter Defendants are permitted to intervene. Doc. 40, Pageid#435. But Plaintiffs acknowledge that Voter Defendants “have agreed to the aggressive briefing schedule set by this Court[.]” Doc 40, Pageid#435. And Voter Defendants’ requested brief in response to the proposed consent decree will be filed less than two days from now. So no delay or prejudice will result as to Plaintiffs claims.
And Voter Defendants’ crossclaim needs to be resolved before the primary election, so as to avoid violations of their fundamental right to vote. So that claim will also be resolved without delay and in a swift manner. Moreover, the parties only submitted a “partial” consent decree, so

Motion to Intervene Reply

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this case will remain active even if the consent decree is approved. So the crossclaim does not

delay resolution of Plaintiffs’ claims, nor the case as whole. There is also no prejudice to either

party.

Finally, Voter Defendants’ crossclaim would not complicate this litigation, as the claims

are directly related. And all arguments are based on the same code sections, same case law, and

same fundamental rights.

So Voter Defendants’ intervention would not cause any delay or prejudice.

Conclusion

For these reasons, this Court should grant intervention as of right or, in the alternative,

permissive intervention.

Date: April 29, 2020

Respectfully Submitted,

/s/ Bradley P. Marrs (VSB#25281) Patrick C. Henry II (VSB#80468) Marrs & Henry 7202 Glen Forest Drive, Suite 307 Richmond, VA 23226 (804) 662-5715 (804) 662-5712 (fax) bmarrs@marrs-henry.com phenry@marrs-henry.com
Local Counsel for Proposed Intervenors

James Bopp, Jr.* IN Atty. No. 2838-84
Courtney Turner Milbank* IN Atty. No. 32178-29
True the Vote, Inc. Voters’ Rights Initiative
THE BOPP LAW FIRM, PC 1 South Sixth St. Terre Haute, IN 47807-3510 Telephone: (812) 232-2434 E-mails: jboppjr@aol.com,
cmilbank@bopplaw.com
Lead Counsel for Proposed Intervenors

*Admitted Pro Hac Vice

Motion to Intervene Reply

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Certificate of Service
I hereby certify that the foregoing document was served electronically on April 29, 2020,
upon all counsels of record via the United States District Court for the Western District of
Virginia, electronic filing system.
/s/ Bradley P. Marrs (VSB#25281) Patrick C. Henry II (VSB#80468) Marrs & Henry 7202 Glen Forest Drive, Suite 307 Richmond, VA 23226 (804) 662-5715 (804) 662-5712 (fax) bmarrs@marrs-henry.com phenry@marrs-henry.com Local Counsel for Proposed Intervenors
James Bopp, Jr.* IN Atty. No. 2838-84
Courtney Turner Milbank* IN Atty. No. 32178-29
True the Vote, Inc. Voters’ Rights Initiative
THE BOPP LAW FIRM, PC 1 South Sixth St. Terre Haute, IN 47807-3510 Telephone: (812) 232-2434 E-mails: jboppjr@aol.com,
cmilbank@bopplaw.com
Lead Counsel for Proposed Intervenors
* Admitted Pro Hac Vice

Motion to Intervene Reply

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 </s> Case 6:20-cv-00024-NKM Document 58 Filed 04/30/20 Page 1 of 23 Pageid#: 1326

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA
LYNCHBURG DIVISION

LEAGUE OF WOMEN VOTERS OF VIRGINIA, et al.,
Plaintiffs,
v.
VIRGINIA STATE BOARD OF ELECTIONS, et al.,
Defendants.

Case No.: 6:20-cv-00024-NKM

BRIEF OF INTERVENOR, REPUBLICAN PARTY OF VIRGINIA, INC., IN OPPOSITION TO MOTION FOR PARTIAL
CONSENT JUDGMENT AND DECREE

Patrick T. Lewis (pro hac vice) BAKER & HOSTETLER LLP 127 Public Square, Suite 2000 Cleveland, OH 44114-1214 216.621.0200 / Fax 216.696.0740 plewis@bakerlaw.com

Christopher M. Marston (VSB No. 65703) chris@2562group.com 2652 Group LLC P.O. Box 26141 Alexandria, VA 22313-6141 571.482.6790 / Fax 703.997.2549

Trevor M. Stanley (VSB No. 77351) E. Mark Braden (pro hac vice) Katherine L. McKnight (adm. pending) Richard Raile (VSB No. 84340) BAKER & HOSTETLER LLP Washington Square, Suite 1100 1050 Connecticut Avenue, N.W. Washington, DC 20036-5403 202.861.1500 / Fax 202.861.1783 tstanley@bakerlaw.com mbraden@bakerlaw.com kmcknight@bakerlaw.com rraile@bakerlaw.com

Counsel for Intervenor, Republican Party of Virginia, Inc.

Case 6:20-cv-00024-NKM Document 58 Filed 04/30/20 Page 2 of 23 Pageid#: 1327
TABLE OF CONTENTS
I. Introduction and Summary of Argument .......................................................... 1 II. Background ......................................................................................................... 2 III. Argument............................................................................................................. 6
A. Standard of Review .................................................................................. 6 B. RPV’s objections may be heard because the proposed consent
decree would impose obligations or duties on RPV’s interests............... 7 C. The proposed settlement is not fair or adequate. ................................. 10 D. The Consent Decree has several hallmarks of collusion. ..................... 13 E. The parties inappropriately ask this Court to enter a consent
decree without finding an underlying violation of law. ........................ 15 F. The public interest is not served by entry of the Consent Decree........ 17 IV. Alternative methods of voter verification exist ............................................... 18 V. Conclusion ......................................................................................................... 20

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I. INTRODUCTION AND SUMMARY OF ARGUMENT Just ten days after the Complaint was filed in this case, and six days after
Plaintiffs moved for a preliminary injunction, Plaintiffs and Defendants filed their Joint Motion for Entry of Partial Consent Judgment and Decree (ECF No. 35) (the “Joint Motion”) that seeks the entry of a proposed Consent Decree (ECF No. 35-1) (the “Consent Decree”). The Defendants gave Plaintiffs the main relief they sought via preliminary injunction: an agreement not to enforce the absentee ballot witness statute, Va. Code § 24.2-707, for the June 23, 2020 Primary, at least for any voter who believes it would be unsafe to have his or her ballot witnessed.
The Consent Decree should not be approved. Consent decrees, which carry the force of law, may not impose duties or obligations on non-consenting parties. This one does, by requiring RPV to conduct its primary election, and accept the candidates nominated through that primary election, without the benefit of the absentee witness statute.
Nor is the settlement fair and adequate. So far as RPV can tell, the Defendants made little or no effort to defend the statute, despite apparent weaknesses in Plaintiffs’ case and the compelling state interest Virginia has in preventing voter fraud and ensuring election integrity. The fact that four different sets of proposed intervenors or amicus curiae have participated in this case alone highlights its significance. Yet, the Defendants simply capitulated. Any “concessions” they obtained from Plaintiffs in “settlement” were minor.
Furthermore, the settlement appears collusive. Plaintiffs and Defendants both favor an injunction against the use of the absentee ballot witness statute, at

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least for the June 23, 2020 Primary Election. The Attorney General, who represents Defendants and is politically aligned with Plaintiffs, issued a triumphant press release the morning after the Joint Motion was filed proclaiming the agreement a “win for Virginians.” And the Joint Motion’s timing, filed only a few days after RPV and a separately represented group of voter-intervenors sought to intervene, appears to be an effort to act quickly before other interests could be represented.
Moreover, the parties are using their Consent Decree to attempt to achieve by agreement what they appear not to have the authority to order on their own. The General Assembly has prescribed the absentee ballot process for Virginia, and earlier this month passed legislation making revisions to the relevant statute—but preserving the witness requirement. The statute is presumed valid, and absent a finding that it violates federal law, the Court should not enjoin the statute simply because the parties ask it to do so via their proposed Consent Decree.
For these reasons, the Court should not adopt the proposed Consent Decree. If, however, the Court feels it must ask, RPV believes that alternatives be considered to simply enjoining the statute’s enforcement. II. BACKGROUND
On April 17, 2020, this action was commenced with the filing of a Complaint (ECF No. 1, the “Complaint”) by three Democratic Party voters and an ideologically aligned interest group, seeking to enjoin the enforcement of Va. Code §§ 24.2-706 and 24.2-707 “while emergency orders regarding COVID-19 transmission are in effect and/or while public health officials continue to recommend social distancing practices due to risk of community transmission of
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COVID-19....” (Compl. at 33, ¶ A.) Plaintiffs sought related relief, including requests
for orders to be issued to “city and county election officials to count otherwise validly
cast absentee ballots that are missing a witness signature for Virginia’s primary
and general elections in 2020” and for a “public information campaign informing
Virginia voters about the elimination of this requirement...” (Id. at 34, ¶ B(2-3).)
And, of course, Plaintiffs seek their attorney fees and costs. (Id. at 34, ¶¶ C-D.)
On April 21, 2020, Plaintiffs filed their Motion for Preliminary Injunction
(ECF No. 16, their “Motion for PI”) seeking the issuance of the following
preliminary injunction:
(1) Prohibiting Defendants from enforcing the witness requirement (as stated in Va. Code § 24.2-706 and § 24.2-707 and as interpreted by 1 Va. Admin. Code 20-70-20(B)) for all Virginia voters for the June 23 primaries and for any and all subsequent elections in Virginia until such time as in-person interactions required by compliance with the witness requirement no longer pose a risk to public health and personal safety; (2) Ordering Defendants to issue guidance instructing city and county election officials to count otherwise validly cast absentee ballots that are missing a witness signature for Virginia’s June 23 primary elections; and (3) Ordering Defendants to conduct a public information campaign informing Virginia voters about the elimination of this requirement, in coordination with city and county election officials. (Mot. for PI at 2.)
On April 23, 2020, three voters (Sheila DeLappe Ferguson, et al.) (the
“Ferguson Proposed Intervenors”) filed a motion to intervene (ECF No. 22)
seeking to intervene in the case to vindicate their right to vote.
On April 24, 2020, Intervenor Republican Party of Virginia, Inc. (“RPV”) and
three voters moved to intervene (ECF No. 28), seeking to vindicate their First and
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Fourteenth Amendment rights as well as their and their members’ fundamental
right to vote.
Later in the day on April 24, 2020, the Court held a status conference in
which counsel for Defendants represented the Defendants were interested in
settlement, and RPV offered to participate in settlement discussions. The Court
then set a very tight briefing deadline for the Motion for PI and the intervention
motions and scheduling argument for May 4. (ECF No. 31.)
On April 27, 2020, with intervention motions still pending and a briefing
schedule set on the Motion for PI, Plaintiffs and Defendants filed the Joint Motion
seeking entry of the Consent Order. In the proposed Consent Order, Plaintiffs and
Defendants agreed to the following:
1. For the Primary elections scheduled for June 23, 2020, Defendants shall not enforce the requirement, as stated in Va. Code § 24.2-706 and § 24.2-707, that absentee voters who believe that they may not safely have another individual present to witness the voter open, mark, and refold their ballot, and then have that that individual sign the absentee ballot envelope next to the voter’s statement and signature.
2. Defendants shall issue guidance instructing all relevant city and county election officials to count all absentee ballots in the June primary that are otherwise validly cast but missing a witness signature.
3. Defendants shall issue updated instructions to include with all absentee ballots as provided in Va. Code. § 24.2-706—or issue guidance instructing all relevant city and county election officials to modify or amend the printed instructions accompanying each absentee ballot—to inform voters that any absentee ballot cast in the June Primary without a witness signature will not be rejected on that basis and specifically informing voters in bold print that they may disregard the witness signature line on the absentee ballot envelope if they believe they may not safely have a witness present while completing their ballot.
4. Defendant Commissioner of Elections shall take additional reasonable steps to inform the public that the witness requirement will
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not be enforced for the June Primary for those absentee voters who believe they may not safely have a witness present while completing their ballot, and issue guidance instructing all relevant city and county election officials to do the same.
5. Plaintiffs will withdraw their motion for a preliminary injunction.
6. In accordance with the terms of this Consent Decree, the Consent Parties shall each bear their own fees, expenses, and costs incurred as of the date of this Order, with respect to all claims raised by Plaintiffs against the Defendants.
(Consent Order pp. 5-6.)
As can be seen, the limited differences between the preliminary injunction
requested in the Motion for PI itself and the proposed Consent Order are as follows:
• The injunction only applies to the June 23, 2020 Primary Election and not to subsequent elections;
• More specific direction is provided as to how Defendants will instruct or educate election officials and voters;
• A representation that the Motion for PI would be withdrawn upon entry of the Consent Decree; and
• A waiver by Plaintiffs of their attorney fee claim for time incurred as of the date of the Consent Order
On April 28, 2020, the Virginia Attorney General’s office, who represents
Defendants in this litigation, issued a press release publicizing the proposed
Consent Decree. The press release stated, among other things, that:
“This agreement is a win for Virginians because it will protect both the health and voting rights of those who would otherwise have to violate social distancing requirements and jeopardize their well-being just to exercise their fundamental right to vote,” said Attorney General Herring. “No Virginian should have to choose between their health and their right to vote during this pandemic.” (emphasis in original)1
1 Office of Virginia Attorney General Mark R. Herring, Attorney General Herring Reaches Agreement To Promote Safe Absentee Voting By Mail, Apr. 28, 2020,
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Defendants’ press release even paraphrased the talking point from their Motion for PI that the witness signature requirement allegedly will “force thousands of voters to choose between disenfranchisement and placing their health in grave peril.” (ECF No. 17 at 1.)
Later in the day on April 28, 2020, Defendants filed their only substantial pleading to date in this case: an opposition to RPV’s motion to intervene. (ECF No. 49.) So far as RPV is aware, no discovery of any kind has been exchanged and the case is in its infancy. III. ARGUMENT
A. Standard of Review When considering whether to grant a consent decree, the Court should “not blindly accept the terms of a proposed settlement.” United States v. North Carolina, 180 F.3d 574, 581 (4th Cir. 1999), citing Flinn v. FMC Corp., 528 F.2d 1169, 1173 (4th Cir. 1975). “Rather, before entering a consent decree the court must satisfy itself that the agreement ‘is fair, adequate, and reasonable’ and ‘is not illegal, a product of collusion, or against the public interest.’” Id., quoting United States v. Colorado, 937 F.2d 505, 509 (10th Cir. 1991). In making its assessment, the “court should consider the extent of discovery that has taken place, the stage of the proceedings, the want of collusion in the settlement and the experience of plaintiffs’ counsel who negotiated the settlement.” Id. (internal quotations omitted). “If the decree also affects third parties, the court must be satisfied that the effect on them
https://oag.state.va.us/media-center/news-releases/1703-april-28-2020-herringreaches-agreement-to-promote-safe-absentee-voting-by-mail.
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is neither unreasonable nor proscribed. United States v. City of Miami, Fla., 664 F.2d 435, 441 (5th Cir. 1981) (Rubin, J., concurring). Here, for the reasons that follow, Plaintiffs and Defendants have not met their burden and their Joint Motion should be denied.
B. RPV’s objections may be heard because the proposed Consent Decree would impose obligations or duties on RPV’s interests.
The framework for the adjudication of an intervenor’s objection to a consent decree was laid out in Local No. 93, Int’l Ass’n of Firefighters, AFL-CIO C.L.C. v. City of Cleveland, 478 U.S. 501 (1986). As the Court explained:
A consent decree is primarily a means by which parties settle their disputes without having to bear the financial and other costs of litigating. It has never been supposed that one party—whether an original party, a party that was joined later, or an intervenor—could preclude other parties from settling their own disputes and thereby withdrawing from litigation. Thus, while an intervenor is entitled to present evidence and have its objections heard at the hearings on whether to approve a consent decree, it does not have power to block the decree merely by withholding its consent. Id. at 528-29 (citations omitted). As a result, at a minimum, the RPV’s objections to the Consent Decree are properly before the Court and may be considered by the Court in determining whether to adopt the Consent Decree. Local No. 93 gives even greater protection to an intervenor like RPV to protect its rights in the face of a consent decree that would infringe those rights. As the Court explained, “a court may not enter a consent decree that imposes obligations on a party that did not consent to the decree.” Id. at 529. This is because “parties who choose to resolve litigation through settlement may not dispose of the
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claim of a third party, and a fortiori may not impose duties or obligations on a third party, without that party’s agreement.” Id.
Hence, where the proposed consent decree would alter the rights of the objecting party, the court should not approve the decree. In United States v. City of Miami, 664 F.3d 435 (5th Cir. 1981) (en banc), for example, a police union objected to (and then moved to vacate) a consent decree resolving employment discrimination claims between the federal government and the City of Miami. The decree made several changes to the City’s employment practices, and while the Court upheld most of the decree, it reversed those provisions of the decree that changed promotion practices in ways inconsistent with the police union’s collective bargaining agreement. Id. at 447 (Rubin, J., concurring). Similarly, in League of United Latin American Citizens, Dist. 19 v. City of Boerne, 659 F.3d 421 (5th Cir. 2011), the court permitted a voter to intervene in a voting-rights case to oppose a motion by the parties (a city and a civil-rights group) to modify a consent decree, specifically, to switch city council elections from cumulative voting to single-member districts. Id. at 434. The voter sought intervention to argue the proposed modified decree infringed his right to vote in elections for all city council members. Id. After holding the voter was entitled to intervene of right (reversing the district court’s denial of leave to intervene), the Fifth Circuit vacated the consent decree and remanded. Id. at 440.
As set forth more fully in RPV’s reply in support of its motion to intervene (ECF No. 54), at 2-5, the RPV has distinct interests in the primary and election
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structure due to its status as a major political party in Virginia. The RPV made a choice to have a primary (i.e., the June 23, 2020 Primary Election) by statute, Va. Code Ann. § 24.2-509(A), and that primary will select the Republican candidates for the November 2020 General Election. The RPV has both a statutory and constitutionally protected interest in the conduct of its own primary. Changing the rules as Plaintiffs and Defendants seek to do would force the RPV to undertake a different primary election process than the one prescribed by statute, and would force RPV to accept a risk of fraudulent or otherwise unauthorized voting in that primary.2 Finally, the RPV has a strong interest, both on its own and on behalf of its members and candidates, in preventing voter fraud and enhancing public confidence in the integrity of elections. All of these constitute duties, obligations, or burdens RPV would suffer if the Court issues the Consent Decree.
In opposing intervention, Plaintiffs cited one case to suggest that RPV has no authority to object to the entry of the Consent Decree, Dillard v. Chilton County Comm’n, 495 F.3d 1324 (11th Cir. 2007), but it is readily distinguished. In Dillard, the intervenors sought to oppose the entry of a consent decree based only on an assertion of a “generalized incompatibility of the consent decree with the rights of all citizens in the county to be free of judicial interference...” Id. That type of claim is, as Dillard recognized, a textbook example of an “undifferentiated harm suffered in common by all citizens” that is a generalized grievance. Id. But Dillard
2 The RPV further has an interest in the protecting itself and candidates from changes in the competitive environment.
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distinguished that grievance from those of parties “who alleged concrete and particularized injuries in the form of denials of equal treatment or of vote dilution...” Id. (emphasis added). The vote-dilution risk posed by eliminating a key election integrity measure is one of the interests RPV seeks to vindicate. And, unlike in Dillard, a very subject of the Consent Decree is the RPV’s own June 23, 2020 Primary Election, at which the party will nominate its candidates for the U.S. Senate and U.S. House. RPV has an obvious, particularized interest in that election and, hence, the proposed Consent Decree. RPV also has a particularized interest in the Consent Decree to the extent it affects the competitiveness of its races.
Because the proposed Consent Decree would impose duties, obligations, or burdens on RPV and its supporters and candidates, and because RPV does not consent to the Consent Decree, the Court should deny the Joint Motion.
C. The proposed settlement is not fair or adequate. The Joint Motion should also be denied because the proposed settlement is not fair or adequate under the Fourth Circuit’s test. As set forth in North Carolina, analysis of the settlement’s fairness and adequacy requires the court to “assess the strength of the plaintiff’s case.” 180 F.3d at 581. That assessment requires an analysis of the extent of discovery and the stage of the pleadings. Id. Here, Defendants capitulated, and did so within ten days of when the Complaint was filed. RPV sees no evidence that Defendants have defended the relevant statute. They simply agreed to enjoin it for the June 23, 2020 Primary Election.
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Plaintiffs’ evidence has significant weaknesses (see generally Br. in Opp. to Mot. for Prelim. Injunction, ECF No. 44, at 8-14), as do their legal theories. (See generally id.) Yet there is no evidence that those weaknesses were ever explored by Defendants or informed the ultimate settlement analysis of either party. In addition to Plaintiffs’ weaknesses, the Commonwealth also has a compelling interest in deterring voter fraud and protecting election integrity, including through the use of the absentee ballot witness statute.3 The interest in election integrity is of such great public interest, in fact, that four different sets of parties have either sought to intervene or to file an amicus brief in this case. The Joint Motion does not meaningfully analyze the evidence around voter fraud and election-integrity, either.
The failure of the parties to adequately justify the allocation of liability or other substantive terms of a settlement is grounds to deny the entry of a consent decree. See United States v. Pioneer Natural Resources Co., No. 17-cv-0168, 2020 WL 1694471, *6-7 (D. Colo. Apr. 7, 2020) (denying motion of United States to enter into consent decree in CERCLA litigation where the government “failed to discharge its burden of showing that the consent decree is fair, reasonable, and in the public interest’); United States v. ATP Oil & Gas Corp., No. 13-0262, 2015 WL 13648078, *3 (E.D. La. Jan. 28, 2015) (denying entry of consent decree where calculation of
3 It bears noting that the concern about fraud in absentee voting is substantial and, importantly, bipartisan. Brennan Center for Justice, The Truth About Voter Fraud 34 n.16 (2007) (opposing photo identification laws for voters because they “do not address the absentee voting process, where fraud through forgery or undue influence, often directly implicating candidates or their close associates, is far more of a threat”).
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civil monetary penalty to be paid by defendant was insufficiently supported). The parties’ failure to meaningfully analyze the grounds for settlement is a factor weighing against the Court entering the Consent Order in this case.
Plaintiffs will doubtlessly tout the “concessions” they gave to Defendants in connection with the Consent Decree. But those so-called concessions were illusory or minor. Plaintiffs correctly say that the proposed Consent Decree addresses only the June 23, 2020 Primary Election and will not apply by its terms in future elections. But that claim is illusory. As set forth in Intervenors’ opposition to the motion for preliminary injunction, claims grounded in future, speculative, and contingent events (i.e., the impact of COVID-19 on the Commonwealth’s public health in November 2020) are neither ripe for judicial review nor supported by evidence to meet the burden to satisfy the issuance of preliminary injunction. (See ECF No. 44 at 17-26.)
Similarly, Plaintiffs will claim that their “concession” of allowing voters to voluntarily comply with the witness requirement if they can do it without risking their health is significant. But that, too, misses the point. If the absentee ballot witness requirement is no longer a requirement, then the Commonwealth, the RPV, and their respective voters are deprived of the election-integrity benefits it provides just the same as if the requirement was enjoined in its entirety.
Finally, as detailed, infra, at Section IV, alternative methods of voter verification exist that could help ensure that the Commonwealth’s compelling interest in deterring voter fraud and protecting election integrity is balanced with
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the current exigent public health needs. There is no evidence that Defendant even considered employing any such alternative methods of verification.
The proposed Consent Decree is neither fair nor adequate, and the Joint Motion should be accordingly denied.
D. The Consent Decree has several hallmarks of collusion. The substantial risk of collusion at play in this litigation is another reason for the Court to decline to enter the Consent Decree. A consent decree is generally a “request for the court to exercise its equitable powers,” which in turn “involves the court’s sanction and power and is not a tool bending without question to the litigants’ will.” League of United Latin American Citizens, Council No. 4434 v. Clements, 999 F.2d 831, 846 (5th Cir. 1993). In federal court, “parties cannot, by giving each other consideration, purchase from a court of equity a continuing injunction.” Id., quoting System Federation No. 91, Ry. Employees Dep’t, AFL-CIO v. Wright, 364 U.S. 642, 651 (1961). The “collusion” prong of the North Carolina inquiry implicates the Constitutional limitation on the federal judiciary to only act in “the decision of ‘Cases’ or ‘Controversies.’ Standing to sue or defend is an aspect of the case-orcontroversy requirement.” Arizonans for Official English v. Arizona, 520 U.S. 43, 64 (1997) (emphasis added), quoting U.S. Const., Art. III, § 2. To satisfy the Cases or Controversies requirement, both sides to a dispute must possess an interest in the outcome. Federal courts demand “that concrete adverseness which sharpens the presentation of issues upon which the court so largely depends for illumination of difficult constitutional questions.” Baker v. Carr,
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369 U.S. 186, 204 (1962). Hence, “collusive” lawsuits—where the parties are not genuinely adverse—must not be adjudicated in federal courts. See United States v. Johnson, 319 U.S. 302, 305 (1943) (a collusive suit lacks “the ‘honest and actual antagonistic assertion of rights’ to be adjudicated—a safeguard essential to the integrity of the judicial process, and one which we have held to be indispensable to adjudication of constitutional questions by this Court.”) And a judgment entered into by non-adverse parties “is no judgment of the court. It is a nullity ....” Lord v. Veazie, 49 U.S. 251, 256 (1850). Put another way, there is “no case or controversy within the meaning of Art. III of the Constitution” when “both litigants desire precisely the same result ....” Moore v. Charlotte-Mecklenburg Bd. of Edn., 402 U.S. 47, 47-48 (1971) (holding that where both parties to a school desegregation suit argued the state’s anti-busing law was unconstitutional, there was no Article III “case or controversy”).
Here, there are multiple indicia of collusion. The Defendants have so far failed to defend the absentee ballot witness statute. Instead, they almost immediately decided to enter into the Consent Decree to enjoin its use, issued a press release touting their deal, and have actively tried to exclude RPV from this litigation, which would lead to the statute having no defender in Court. The Defendants’ failure to defend the statute, and their almost immediate decision to enter a consent decree to enjoin the statute, is evidence of collusion. See, e.g., Horne v. Flores, 557 U.S. 443, 449 (2009) (observing that “public officials sometimes consent to...decrees that...bind state and local officials to the policy preferences of
14

Case 6:20-cv-00024-NKM Document 58 Filed 04/30/20 Page 17 of 23 Pageid#: 1342
their predecessors and may thereby deprive future officials of their legislative and executive powers”); Northwest Environmental Advocates v. E.P.A., 340 F.3d 853, 855 (9th Cir. 2003) (Kleinfeld, J., dissenting) (warning that “consent decrees between advocacy groups and agencies presents a risk of collusion to avoid executive and ultimately democratic control over the agencies”); Carcano v. Cooper, No. 1:16cv236, 2019 WL 3302208, *6 (M.D.N.C. July 23, 2019) (“where there has been little adversarial activity, a federal court must be especially discerning when presented with a proposal in which elected state officials seek to bind their successors as to a mater about which there is substantial political disagreement”).
In effect, Defendants are aligned with Plaintiffs, and this Court should find the resultant proposed Consent Decree bears too many hallmarks of collusion to be appropriately entered by the Court. The Joint Motion should be denied.
E. The parties inappropriately ask this Court to enter a consent decree without finding an underlying violation of law.
The Consent Decree should also be denied because it asks this Court to exercise federal judicial power to enjoin a state statute without a finding that the statute violates federal law. Importantly, “consent is not enough when litigants seek to grant themselves power they do not hold outside of court.” Clements, 999 F.2d at 846. Hence, “a local government may not use a consent decree to avoid a state law requiring a referendum before the issuance of construction bonds.” Id., citing Dunn v. Carey, 808 F.2d 555, 561 (7th Cir. 1986). In City of Boerne, the court found it noteworthy that the parties were attempting to use a consent decree to change the manner in which city council members were elected—a change that normally would
15

Case 6:20-cv-00024-NKM Document 58 Filed 04/30/20 Page 18 of 23 Pageid#: 1343
require a popular vote. 659 F.3d at 434. Accordingly, “an alteration of the [state] statutory scheme may not be based on consent alone; it depends on an exercise of federal power, which in turn depends on a violation of federal law.” Kasper v. Board of Election Commr’s of the City of Chicago, 814 F.2d 332, 342 (7th Cir. 1987). See also PG Pub. Co. v. Aichele, 705 F.3d 91 (3d Cir. 2013) (finding that where no violation of federal law had been found, court lacked authority to enter a consent decree “that would violate a valid state law”); Kasper, 814 F.2d at 341-42 (“A consent decree is not a method by which state agencies may liberate themselves from the statutes enacted by the legislature that created them”); Nat’l Rev. Corp. v. Violet, 807 F.2d 285, 288 (1st Cir. 1986) (holding that a consent judgment was “void on its face” because State Attorney General lacked authority to stipulate that a statute was unconstitutional); League of Residential Neighborhood Advocates v. City of Los Angeles, 498 F.3d 1052, 1055 (9th Cir. 2007) (“A federal consent decree ... cannot be a means for state officials to evade state law”).
Most recently, the court in League of Women Voters of Mich. v. Benson, No. 2:17-cv-14148, 2019 WL 8106156 (E.D. Mich. Feb. 1, 2019), denied a motion to enter a consent decree resolving a partisan-gerrymandering case. The LWV had cut a deal with the newly elected Democratic Michigan Secretary of State to require portions of Michigan’s redistricting maps to be redrawn. The Republican congressional delegation and two GOP state legislators, who had intervened, objected to the entry of the consent decree. Id. at *1. The court declined to enter the consent decree because under the Michigan constitution, only the Michigan Legislature had
16

Case 6:20-cv-00024-NKM Document 58 Filed 04/30/20 Page 19 of 23 Pageid#: 1344
authority to “regulate the time, place and manner of all...elections.” Id. at *3, citing Mich. Const. Art. 2, § 4. The Commonwealth’s constitution likewise vests authority to “regulate the time, place, manner, conduct, and administration of primary, general, and special elections” in its General Assembly. Va. Const. Art. II, § 4.
Here, in addition to the Virginia Constitutional provisions assigning the regulation of elections to the General Assembly, there is the fact that the General Assembly just amended the absentee ballot statute to provide for no-fault absentee balloting. The General Assembly, during that process, elected to retain the witness requirement for absentee ballots. That statute enjoys a presumption of constitutionality, and absent a finding that the statute violates federal law, the parties cannot leverage this Court’s federal judicial authority to enjoin that statute by their agreement alone. The Court should, therefore, deny the Joint Motion.
F. The public interest is not served by entry of the Consent Decree.
Finally, Plaintiffs and Defendants argue that entry of the Consent Decree will further the public interest by promoting public health. The public health is undeniably a public good, but it is far from clear how the proposed Consent Decree would meaningfully further the public health. As set forth more fully in the RPV’s brief in opposition to the motion for preliminary injunction, voters can use the same common-sense social-distancing and safety measures they use for gathering groceries and other necessities to have their ballots witnessed.
Further, the public interest is also served by allowing for state control of its election mechanics by democratically accountable officials. The “functional structure
17

Case 6:20-cv-00024-NKM Document 58 Filed 04/30/20 Page 20 of 23 Pageid#: 1345
embodied in the Constitution, the nature of the federal court system, and the limitations inherent in the concepts both of limited federal jurisdiction and of the remedy afforded by section 1983” must also be considered. Hutchinson v. Miller, 797 F.2d 1279, 1282 (4th Cir. 1986), quoting Gamza v. Aguirre, 619 F.2d 449, 452 (5th Cir. 1980). In our constitutional system, “the electoral process is to be largely controlled by the states and reviewed by the legislature,” with states retaining primary authority to regulate their own elections. Id. at 1283. The public interest is served by respecting state control over electoral processes, and not by striking down a bedrock, 70-year-old Virginia statute based on a very thin record. IV. ALTERNATIVE METHODS OF VOTER VERIFICATION EXIST
If the Court feels it must act, then the RPV encourages the Court and the parties to consider alternative methods to verify voter identity and resolve this current dispute related to the June primary.
The remedy proposed by the original parties is overinclusive and fails to offer any replacement mechanism to support the election integrity purpose of the witness signature requirement they seek to eliminate. While the remedy purports to be limited to those voters “who believe they may not safely have a witness present while completing their ballot,” it would require “election officials to count all absentee ballots in the June primary that are otherwise validly cast but missing a witness signature.” Dkt. 35, Ex. A at 5-6.
The RPV would suggest, pursuant to Fed. R. Evid. 408, an alternative remedy to resolve both of these shortcomings. The Defendants would be directed to add an additional set of instructions to the material required to be sent by Va. Code
18

Case 6:20-cv-00024-NKM Document 58 Filed 04/30/20 Page 21 of 23 Pageid#: 1346
Ann. § 24.2-706. Those instructions would include a separate form that would require any voter who believes having a witness would be unsafe to attest to that belief and to provide an additional indicator to verify the voter’s identity. This additional indicator, such as the last 4 digits of the voter’s social security number, would be verified by comparison to the voter’s registration record. The voter would include this completed form in the same return envelope pre-addressed to the Secretary of the Electoral Board in which the voter returns “Envelope B.” Envelope B, a copy of which is attached as Exbibit A, is the envelope in which the voter inserts the ballot and complete the “Statement of Voter” described in Va. Code Ann. §24.2-706 (2019); the same envelope on which a witness would ordinarily sign. This arrangement—inserting an additional item in the return envelope—would be familiar to election officials as it mirrors the implementation of the Help America Vote Act of 2002, 52 U.S.C. § 21083 (“HAVA”), requirements applicable to voters who vote absentee for the first time after having registered by mail. A copy of the standard instructions for voting an absentee ballot are attached as Exhibit B. A copy of the HAVA notice is attached as Exhibit C.
On Election Day, officers of election handling absentee votes would count the votes of absentee voters who do not seek an exemption from the witness signature requirement as they ordinarily would, setting aside the ballot envelopes of those seeking an exemption from the requirement. The attestations for those set-aside ballots would then be compared to the voter’s registration record and, if verified,
19

Case 6:20-cv-00024-NKM Document 58 Filed 04/30/20 Page 22 of 23 Pageid#: 1347

counted in the usual fashion except for treating the lack of a witness signature as a

material omission.

V. CONCLUSION

For the foregoing reasons, Intervenor, the Republican Party of Virginia, Inc.,

respectfully request that the Court deny Plaintiffs’ motion for preliminary

injunction (ECF No. 16) in its entirety.

Dated:

April 30, 2020

Respectfully submitted,

/s/ Christopher M. Marston Christopher M. Marston (VSB No. 65703) chris@2562group.com 2652 Group LLC P.O. Box 26141 Alexandria, VA 22313-6141 571.482.6790 / Fax 703.997.2549

Trevor M. Stanley (VSB No. 77351) E. Mark Braden (pro hac vice pending) Katherine L. McKnight (adm. pending) Richard Raile (VSB No. 84340) BAKER & HOSTETLER LLP Washington Square, Suite 1100 1050 Connecticut Avenue, N.W. Washington, DC 20036-5403 202.861.1500 / Fax 202.861.1783 tstanley@bakerlaw.com mbraden@bakerlaw.com kmcknight@bakerlaw.com rraile@bakerlaw.com

Patrick T. Lewis (pro hac vice pending) BAKER & HOSTETLER LLP 127 Public Square, Suite 2000 Cleveland, OH 44114-1214 216.621.0200 / Fax 216.696.0740 plewis@bakerlaw.com

Counsel for Intervenor, Republican Party of Virginia, Inc.

20

Case 6:20-cv-00024-NKM Document 58 Filed 04/30/20 Page 23 of 23 Pageid#: 1348 CERTIFICATE OF SERVICE
I certify that on April 30, 2020, the foregoing was filed on the Court’s electronic case filing system. Notice of the filing was generated by the Court’s electronic system. Copies of the filing are available on that system.
/s/ Christopher M. Marston Christopher M. Marston (VSB No. 65703)
21

Case 6:20-cv-00024-NKM Document 58-1 Filed 04/30/20 Page 1 of 2 Pageid#: 1349

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA
LYNCHBURG DIVISION

LEAGUE OF WOMEN VOTERS OF VIRGINIA, et al.,
Plaintiffs,
v.
VIRGINIA STATE BOARD OF ELECTIONS, et al.,
Defendants.

Civil Action No.: 6:20-cv-00024-NKM

DECLARATION OF CHRISTOPHER M. MARSTON My name is Christopher M. Marston. I am over the age of 18 and fully competent to make this declaration. I declare the following based upon my personal knowledge: 1. I am counsel to Defendant-Intervenors, Republican Party of Virginia, Inc. I personally located and/or prepared the attached materials. 2. Attached as Exhibit A is a true and correct copy of the Department of Elections’ “Envelope B,” the envelope in which absentee voters insert their ballots, denoted SBE-706-2, as accessed at https://www.elections.virginia.gov/media/formswarehouse/absenteevoting/ballots/SBE-706-2-Envelope-B.pdf. 3. Attached as Exhibit B is a true and correct copy of the Department of Elections’ Instructions for Voting an Absentee Ballot, denoted ELECT-706.4, as accessed at https://www.elections.virginia.gov/media/formswarehouse/absentee-voting/ballots/ELECT706.4-AB-Instructions-for-Voting-an-Absentee-Ballot_2-20.pdf. 4. Attached as Exhibit C is a true and correct copy of the Department of Elections’ Help America Vote Act Important Notice to Absentee Voters, denoted ELECT-AB-HAVA-1, as

Case 6:20-cv-00024-NKM Document 58-1 Filed 04/30/20 Page 2 of 2 Pageid#: 1350 accessed at https://www.elections.virginia.gov/media/formswarehouse/absenteevoting/ballots/ELECT-AB-HAVA-1-Important-Notice-to-Absentee-Voters.docx.
I declare under penalty of perjury that the foregoing is true and correct. Executed on April 30, 2020, at Alexandria, Virginia.
_________________________________________ CHRISTOPHER M. MARSTON
2

Case 6:20-cv-00024-NKM Document 58-2 Filed 04/30/20 Page 1 of 3 Pageid#: 1351
Exhibit A

Case 6:20-cv-00024-NKM Document 58-2 Filed 04/30/20 Page 2 of 3

BALLOT

Statement of Absentee Voter

Do not put anything except your ballot in this envelope

· Please print legibly · Your Ballot(s) will not be counted if you fail to complete all blanks

Pageid#: 1352
B

; ;

I do hereby state, subject to felony penalties for making false statements pursuant to §24.2-1016, Code of Virginia, that my full name is

Last

First

Middle

Suffix (Jr., Sr., III, Etc.)

that I am now or have been at some time since last November’s general election a legal resident of (state your legal residence in Virginia including the house number,

street name or rural route address, city, zip code):

Address

City

Zip Code

that I received the enclosed ballot(s) upon application to the registrar of such county or city; that I opened the envelope marked “ballot within” and marked the ballot(s)

in the presence of the witness, without assistance or knowledge on the part of anyone as to the manner in which I marked it (or I am returning the form required to

report how I was assisted); that I then sealed the ballot(s) in this envelope; and that I have not voted and will not vote in this election at any other time or place.

Signature of Voter

Signature of Witness

I swear/affirm, under felony penalty for making willfully false material statements or entries, that the information provided on this form is true.

MM

DD

YYYY

/

/

Date

Revision Date 7/2012

Case 6:20-cv-00024-NKM Document 58-2 Filed 04/30/20 Page 3 of 3

BALLOT

Statement of Absentee Voter

Do not put anything except your ballot in this envelope

· Please print legibly · Your Ballot(s) will not be counted if you fail to complete all blanks

Pageid#: 1353
B

; ;

I do hereby state, subject to felony penalties for making false statements pursuant to §24.2-1016, Code of Virginia, that my full name is

Last

First

Middle

Suffix (Jr., Sr., III, Etc.)

that I am now or have been at some time since last November’s general election a legal resident of (state your legal residence in Virginia including the house number,

street name or rural route address, city, zip code):

Address

City

Zip Code

that I received the enclosed ballot(s) upon application to the registrar of such county or city; that I opened the envelope marked “ballot within” and marked the ballot(s)

in the presence of the witness, without assistance or knowledge on the part of anyone as to the manner in which I marked it (or I am returning the form required to

report how I was assisted); that I then sealed the ballot(s) in this envelope; and that I have not voted and will not vote in this election at any other time or place.

Signature of Voter

Signature of Witness

I swear/affirm, under felony penalty for making willfully false material statements or entries, that the information provided on this form is true.

MM

DD

YYYY

/

/

Date

Revision Date 7/2012

Case 6:20-cv-00024-NKM Document 58-3 Filed 04/30/20 Page 1 of 3 Pageid#: 1354
Exhibit B

Case 6:20-cv-00024-NKM Document 58-3 Filed 04/30/20 Page 2 of 3 Pageid#: 1355

INSTRUCTIONS FOR VOTING AN ABSENTEE BALLOT
The law requires that a witness must be present for Steps 3 through 7 listed below. Any person can serve as your witness.

BEFORE VOTING
VOTING THE BALLOT

1. IFIFYOYUOUDEDCEICDIEDE NNOOTT TTOOVVOOTTEEBYBAYBASBESNETNETEEBEABLALLOLTO,Td,odoNOTNOopTenoEpnevnelope Envelope A [BALLOT WITHIN]. If you can vote in person, hand the unused ballot to an election official when presenting your identification, or mail the ballot unopened in the pre-addressed envelope to be received by the General Registrar on or before election day.
2. When voting, do not open Envelope A until the person who will be your witness is present. IF you vote in the office of a Virginia election official, your witness must be a Registrar or member of the Electoral Board.
3. Open Envelope A. Remove the ballot and mark it in the presence of your witness without assistance and without letting the witness know how you vote. If you are unable to vote without assistance, see Item 11.
4. Follow the instructions on your ballot for marking the name of each candidate or question response for which you want to vote. Leave all other choices blank. For each office, vote only for the number of candidates indicated.
5. Place your voted ballot(s) inside Envelope B, folding if needed. Place ALL of your ballots in Envelope B [BALLOT(S)] and seal it. Do not put anything else in that envelope.
6. Fill in ALL the blank spaces in the STATEMENT OF ABSENTEE VOTER on Envelope B. Your ballots WILL NOT BE COUNTED if you fail to complete any blank. You must provide your Virginia residence address NOT the ballot-mailing address in this affidavit. Then, sign and date the statement. If you are unable to sign or make your mark, see Item 11.
7. Your witness also must sign at the bottom of the STATEMENT OF ABSENTEE VOTER on Envelope B; an X or mark is not acceptable.

VOTING THE BALLOT
[continued]

8. Place Envelope B in the return envelope pre-addressed to the Secretary of the Electoral Board. Return your ballot using ONE of the following methods:
 MAIL IT (United States Postal Service), OR
RETURN IT BY A COMMERCIAL DELIVERY SERVICE [e.g., Federal Express, UPS, DHL]; OR

Form number (ELECT-706-4)

Revision date (09/2019)

Case 6:20-cv-00024-NKM Document 58-3 Filed 04/30/20 Page 3 of 3 Pageid#: 1356

LOST BALLOT SPOILED BALLOT
ASSISTANCE IN VOTING
BLIND VOTER

 HAND DELIVER YOUR OWN BALLOT PERSONALLY
to the General Registrar or to a member of the Electoral Board so that it is received before 7:00 p.m. on election day. Neither a personal courier service nor another individual may deliver it for you. You may not leave your voted absentee ballot at a precinct polling place; doing so will invalidate the ballot.
9. If you lose your ballot, immediately contact the General Registrar or a member of the Electoral Board.
10. If you make an error in marking the ballot or if you accidentally damage it, and there is sufficient time to receive it before election day, you may request a new ballot. Return the ballot you received to the General Registrar with a letter, signed by you, stating that your enclosed ballot is spoiled and requesting a new ballot.
11. If you indicated on your application that you need assistance in voting your ballot, a REQUEST FOR ASSISTANCE form is enclosed. This form must be completed by the voter and by the person who assists the voter BEFORE assistance is provided. If, upon receipt of this form, assistance is not needed, you do not need to return the form. For blind voters, see Item 12.
Sign the REQUEST FOR ASSISTANCE on the form. If you are unable to sign or make your mark, the person assisting you must enter APPLICANT CANNOT SIGN and must print your name on the line provided. Have your assistant sign and print his/her name and address in the ASSISTANT section. Return the REQUEST FOR ASSISTANCE form in the envelope pre-addressed to the General Registrar or Electoral Board. Do NOT insert this form in Envelope B with your ballots.
12. BEFORE assisting a blind voter, the person providing the assistance must print the blind voter's full name and the words "BLIND VOTER" on the Signature of Voter line in the VOTER section. The assistant then must sign and print his/her full name and address in the ASSISTANT section. Return the form in the envelope pre-addressed to the General Registrar or Electoral Board. Do NOT insert this form in Envelope B with your ballots.

13. Remember you can CHECK THE STATUS OF YOUR BALLOT ONLINE and confirm the date it was received by your locality using the Virginia Department of Elections website, ELECTIONS.VIRGINIA.GOV

Form number (ELECT-706-4)

Revision date (09/2019)

Case 6:20-cv-00024-NKM Document 58-4 Filed 04/30/20 Page 1 of 2 Pageid#: 1357
Exhibit C

Case 6:20-cv-00024-NKM Document 58-4 Filed 04/30/20 Page 2 of 2 Pageid#: 1358 IMPORTANT NOTICE to ABSENTEE VOTERS
Our records indicate that you registered by mail without providing a copy of your identification and have applied to vote by mail in the upcoming federal election. This notice is to inform you that federal law requires, the first time you vote in a federal election, that you mail a copy of one of the following identification documents with your voted absentee ballot:
• Your current and valid photo identification, for example, your valid Virginia Driver’s License (Note: licenses expiring within the 12 months before Election Day will be considered valid for use as voter ID); OR
• A copy of a current utility bill, bank statement, government check, paycheck or other government document that shows your name and address (for example, your Virginia voter card). Only documents that show the voter’s name and address will be considered acceptable as ID.
Do not place the copy of your ID Document inside the inner envelope with your voted ballot. Put it inside the outer envelope.
If you do not mail a copy of your ID with your voted ballot, your ballot must be treated as a “provisional ballot” and will not be counted unless you submit a copy of your ID to be received by the Electoral Board by Monday November 14, 2016. If you have questions regarding this requirement you may call your local voting official at ____________. After Election Day, you can find out if your ballot was counted by calling 1-866-839-2556 and entering locality code ______ once prompted.

Form number (HAVA-1)

Revision date (09/2014)

 </s> Case 6:20-cv-00024-NKM Document 59 Filed 04/30/20 Page 1 of 12 Pageid#: 1359


 



 





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 </s> Case 6:20-cv-00024-NKM Document 61 Filed 05/01/20 Page 1 of 18 Pageid#: 1382

UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA
Lynchburg Division

LEAGUE OF WOMEN VOTERS OF

VIRGINIA;

KATHERINE

D.

CROWLEY; ERIKKA GOFF; and

SEIJRA TOOGOOD,

Plaintiffs,

v.

VIRGINIA STATE BOARD OF ELECTIONS; ROBERT H. BRINK, JOHN O’BANNON, and JAMILAH D. LECRUISE, in their official capacities as Chairman, Vice-Chair, and Secretary of the Virginia State Board of Elections, respectively; and CHRISTOPHER E. PIPER, in his official capacity as Commissioner of the Virginia Department of Elections,

Defendants.

Case No. 6:20-cv-00024-NKM

REPLY BRIEF IN SUPPORT OF PLAINTIFFS’ MOTION FOR PRELIMINARY INJUNCTION The Republican Party of Virginia (“RPV”) and amici throw a kitchen sink of objections at Plaintiffs with the hope that something will land, suggesting that the COVID-19 pandemic is supposedly not as bad as predicted; asserting that requiring voters to jump through extra hoops to find a witness during the pandemic is not particularly burdensome; and papering the Court with broad claims of voter fraud and irrelevant examples, without ever showing how the witness requirement addresses these concerns. Evaluating the actual evidence of harm, however, and weighing it against the minimal (if any) value of the witness requirement, there is no contest. In the context of the pandemic, continued enforcement of the witness requirement will
1

Case 6:20-cv-00024-NKM Document 61 Filed 05/01/20 Page 2 of 18 Pageid#: 1383
unconstitutionally burden the right to vote of Plaintiffs and many thousands of other Virginians and cannot be justified by vague election integrity interests. The Court should grant Plaintiffs’ preliminary injunction motion if it denies entry of the proposed consent decree. I. The RPV and amici misframe the relevant legal standards and fail to rebut
Plaintiffs’ demonstration of significant harm, including through suggested workarounds such as a “voter-witness dance.” A. Courts evaluate the burden on voters in light of present circumstances, including in the context of pandemics and disasters. The RPV and amici note that Plaintiffs do not challenge the witness requirement in a “COVID-less world,” but rather in the context of the current pandemic. They are correct. Where they are wrong is in how this affects the Court’s analysis. In reviewing right to vote claims, courts must assess the burdens imposed by a challenged voting restriction within the context of circumstances as they currently exist—regardless of whether those circumstances are unusual or abnormal. And several courts have already struck down various election administration procedures as unduly burdensome in the context of the current pandemic, particularly where complying with such procedures would conflict with a state’s “stay-at-home” orders. See, e.g., Libertarian Party of Ill. v. Pritzker, No. 20-cv-2112, 2020 WL 1951687, at *4 (N.D. Ill. Apr. 23, 2020) (finding that the “combined effect of . . . Illinois’ stay-at-home order and the usual in person signature requirements [posed] a nearly insurmountable hurdle”); Esshaki v. Whitmer, No. 20-cv-10831, 2020 WL 1910154, at *1 (E.D. Mich. Apr. 20, 2020) (noting state’s “insist[ence] on enforcing [ballot-access] requirements as if its Stay-at-Home Order . . . had no impact on the rights of candidates and the people who may wish to vote for them”). Indeed, although the RPV contests the relevance of the ongoing pandemic when assessing the constitutionality of Virginia’s elections administration procedures, it recently argued precisely the opposite in state court. In fact, the RPV recently sought and obtained a
2

Case 6:20-cv-00024-NKM Document 61 Filed 05/01/20 Page 3 of 18 Pageid#: 1384
consent order extending a temporary injunction in state court against a Virginia statute providing for certain candidate selection deadlines for all non-primary districts through July 28, 2020, on the grounds that the statutory deadlines were unconstitutionally burdensome in the context of the pandemic. See Compl., Seventh Cong. Dist. Republican Comm. v. Va. Dep’t of Elections (“Seventh Cong. Dist.”), No. CL20001640-00 (City of Richmond Circuit Ct. Apr. 7, 2020) (attached as Ex. A); Id. ¶ 73 (requesting injunction under Anderson-Burdick framework and arguing that the “fact that State Defendants are encouraging voters to vote absentee and not travel to the polls insinuates that it is contrary to the health of Virginians to come into close contact with others.”); Plaintiff-Intervenor Republican Party of Va.’s Unopposed Mot. & Consent Order to Extend Temp. Injunction, Seventh Cong. Dist. (Apr. 20, 2020) (requesting and agreeing in consent order that injunction against Va. Code § 24.2-510 in Seventh District until July 28 be applied to all district committees using a non-primary method of selecting candidates) (attached as Ex. B). Having recently endorsed the claim that election procedures can impose particularly significant burdens in the context of the COVID-19 pandemic that take on constitutional significance, the RPV should be estopped from taking the opposite position in this case.1 See New Hampshire v. Maine, 532 U.S. 742, 749 (2001) (the doctrine of judicial estoppel “protect[s] the integrity of the judicial process by prohibiting parties from deliberately changing positions according to the exigencies of the moment.”).
1 In another recent state court case challenging Virginia’s signature requirements for a prospective candidate to gain a place on the ballot as unduly burdensome in light of the pandemic, the RPV (which was a defendant along with the Commonwealth) took no position on relief, which was ultimately granted. See Faulkner v. Va. Dep’t of Elections, No. CL 20-1546, Slip Op. at 2 (Va. Cir. Ct. Mar. 25, 2020) (previously filed in this case at ECF No. 17-3 at pp. 51–55) (granting emergency preliminary injunction against Virginia election statute to Republican candidate in which RPV took no position). If the RPV had no position on whether it is unduly burdensome for prospective Republican candidates to gather voter signatures during the pandemic, it is odd that RPV now takes the position here that gathering a witness signature poses no significant burden on voters.
3

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In any event, when confronted with other natural disasters or emergencies, courts have not hesitated to enjoin election laws that, in the context of the emergency, would unconstitutionally burden individuals’ right to vote. For example, a district court found that Florida’s voter registration deadline unconstitutionally burdened the right to vote in light of Hurricane Matthew, which “foreclosed the only methods of registering to vote” during the final week of Florida’s voter registration window, such that maintaining Florida’s statutory registration deadline would “completely disenfranchise[] thousands of voters,” amounting “to a severe burden on the right to vote.” Fla. Democratic Party v. Scott, 215 F. Supp. 3d 1250, 1257 (N.D. Fla. 2016); see also Ga. Coalition for the Peoples’ Agenda, Inc. v. Deal, 214 F. Supp. 3d 1344, 1345–46 (S.D. Ga. 2016) (granting preliminary injunction to extend statutory voter registration deadline for a Georgia county after a hurricane). Similarly, the federal court in the Eastern District of Virginia granted a preliminary injunction in 2016 extending Virginia’s statutory voter registration deadline after the state voter registration website crashed on the final day of registration. Order, New Va. Majority Educ. Fund v. Va. Dep’t of Elections, No. 1:16-cv01319-CMH-MSN, Dkt. No. 10 (E.D. Va. Oct. 20, 2016) (granting preliminary injunction extending Virginia’s statutory voter registration deadline after state voter registration website crashed on the final day of registration). And an appellate court in Pennsylvania upheld a decision postponing an election entirely in light of significant flooding because, “[w]ithout the court’s action, some voters, by reason of the elements, would have incurred the discrimination of disenfranchisement.” In re Gen. Election-1985, 531 A.2d 836, 839 (Pa. Commw. Ct. 1987).
The Anderson/Burdick framework is a “flexible standard,” Burdick v. Takushi, 504 U.S. 428, 434 (1992), requiring courts to take a context-specific approach to its burden analysis. The scrutiny applied “will wax and wane with the severity of the burden imposed on the right to vote
4

Case 6:20-cv-00024-NKM Document 61 Filed 05/01/20 Page 5 of 18 Pageid#: 1386
in any given case; heavier burdens will require closer scrutiny, lighter burdens will be approved more easily.” Fish v. Schwab, No. 18-3133, --- F.3d ----, 2020 WL 2050644, at *12 (10th Cir. Apr. 29, 2020). In the hurricane and technological failure cases described above, federal courts took for granted that the registration deadlines ordinarily did not raise significant constitutional concerns, but conducted their analysis in light of the unusual circumstances that rendered those deadlines particularly burdensome. In the circumstances present in these cases, the states’ registration deadlines significantly burdened the right to vote such that the state’s regulatory interest—which might justify the deadlines under normal times—were no longer constitutionally sufficient. As one court explained, “[o]f course, the State of Florida has the ability to set its own deadlines and has an interest in maintaining those deadlines. But it would be nonsensical to prioritize those deadlines over the right to vote, especially given the circumstances here.” Fla. Democratic Party, 215 F. Supp. 3d at 1258.
Here, the toll of sickness and loss of life from the COVID-19 pandemic now dwarfs those of the natural disasters that, in Florida and Georgia, rendered those state’s voter registration deadlines unduly burdensome. Indeed, the national death toll from COVID-19 now exceeds American lives lost in the Vietnam War.2 Unfortunately, the “painful new reality is that we are constantly at risk of contracting a deadly virus and are experiencing previously unimagined safety measures to stop its spread.” Thakker v. Doll, 1:20-CV-480, 2020 WL 1671563, at *7 (M.D. Pa. Mar. 31, 2020); see also Faulkner, Slip Op. at 2 (“the circumstances as they exist in the Commonwealth of Virginia . . . are not normal right now”); Chief Judge Michael Urbanski,
2 See, e.g., David Welna, Coronavirus Has Now Killed More Americans Than Vietnam War, NPR, Apr. 28, 2020, https://www.npr.org/sections/coronavirus-live-updates/2020/04/28/846701304/pandemic-deathtoll-in-u-s-now-exceeds-vietnam-wars-u-s-fatalities.
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Ltr. to Members of WDVA Bar, Apr. 16, 2020 (“In a few short weeks, the global pandemic has changed the way we live . . . .”).
For this same reason, the RPV’s argument that absentee voting is not a constitutional right, and that “Plaintiffs remain free to vote at the polls,” ECF No. 44 at 30, misses the mark. Many if not most Virginians rightfully do not feel safe voting in person for the June primary.3 This concern carries particular weight for older Virginians and Virginians who have preexisting conditions that put them at a higher risk for serious COVID-19 complications like Plaintiff Toogood and League members McGrady and Claar. See ECF No. 17-5 ¶¶ 5–6; ECF No. 17-6 ¶¶ 7–8. As Dr. Reingold explains, “geriatric patients are at the greatest risk of severe cases, longterm impairment, and death,” as are “those with immunologic conditions and with other preexisting conditions, such as hypertension, certain heart conditions, lung diseases (e.g., asthma, COPD), diabetes mellitus, obesity, and chronic kidney disease.” ECF No. 17-1 ¶ 7; see also United States v. Edwards, No. 6:17-CR-00003, 2020 WL 1650406, at *6 (W.D. Va. Apr. 2, 2020) (explaining that COVID-19 “presents a significant risk to those . . . with compromised immune systems”); In re Poulios, No. 2:09-CR-109, 2020 WL 1922775, at *1 (E.D. Va. Apr. 21, 2020) (noting that the “COVID-19 pandemic” can “result in catastrophic health consequences for [individuals] vulnerable to infection”).
Despite amicus Individual Voters’ assertion that other elections have been safe and the RPV’s suggestion that voters merely need to wear appropriate protective gear and everything will be fine, they disregard the actual evidence. Indeed, although the Individual Voters amici
3 Nor is it assured that in-person voting will be as accessible—let alone safe—in upcoming elections as in past years, as localities are having difficulty recruiting poll workers to work the polls on Election Day. See e.g., Iles Decl., ECF No. 17-2 ¶ 3.
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assert that, “weeks after the Wisconsin election” on April 7, which featured substantial in-person voting, “COVID-19 cases had not spiked,” ECF No. 37 at 4, in fact, the opposite is true: Wisconsin state officials have reported that at least 50 people who voted in-person last month’s primary have already tested positive for COVID-19.4 And Dr. Reingold has specifically cited incidents like this as further evidence for his opinion that requiring individuals to come within six feet of others to whom they are not otherwise being exposed would increase their risk of infection.” ECF No. 17-1 ¶ 17. Given the current environment, the right at stake is not the “right to vote absentee” but the right to vote at all without endangering one’s health.
Because of the risk to our communities posed by the pandemic, the witness requirement imposes particularly severe burdens on Virginia voters—particularly those who are at a higher risk for health complications and death.
B. The RPV and amici fail to rebut Plaintiffs’ demonstration of irreparable harm to Plaintiffs and Virginia voters, including through their suggested alternative practices. The most remarkable aspect of Intervenor’s and amici’s responses is their disregard of
the burdens placed on voters should the witness requirement stay in place. They discount the expert evidence of real health risks as well as Plaintiffs’ unrebutted testimony that they face real risks by observing the witness requirement or in-person voting and will be disenfranchised if it is not removed. And in all of their proposals, they expect voters to bear extra burdens to exercise the franchise without regard to the costs and consequences or their limitations. Only one proposal—requiring the voter to write the last four digits of their social security number on the
4 Associated Press, The Latest: 52 positive cases tied to Wisconsin election, Apr. 28, 2020, https://apnews.com/b1503b5591c682530d1005e58ec8c267.
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ballot envelope—merits any serious consideration in the longer term. But even that proposal, if employed in the June primary, would likely create confusion and disenfranchise eligible voters.
Amici and the RPV collectively suggest a number of more “narrowly tailored” alternatives than elimination of the witness requirement for the June election for individuals who live alone. They casually suggest electronic notaries, videoconference witnessing, and a “voterwitness dance” with neighbors. ECF No. 37 at 6, 16–17; ECF No. 44 at 10, 29, 34. None of these are likely to solve the witness problem for many thousands of Virginians, and even for those who could employ these techniques, they impose additional burdens that increase the cost of voting for those individuals with no tangible benefit for election integrity interests. For one, many Virginians lack access to smartphones and/or broadband internet, making all of the proposed technological solutions nonstarters. A recent report by Virginia’s Chief Broadband Adviser and a study from the Virginia Chamber of Commerce found that approximately 600,000 Virginians do not have broadband access,5 and this disparity is not evenly distributed across the Commonwealth. Moreover, Virginians should not need to pay a notary to exercise their fundamental right to vote. Cf. U.S. Const. amend. XXIV (“The right of citizens of the United States to vote in any primary or other election . . . shall not be denied or abridged by . . . any State by reason of failure to pay any poll tax or other tax.”).
Both RPV and the Individual Voters also propose a system which the latter refer to as a “voter-witness dance,” wherein a voter finds a neighbor, knocks on their door, and engages in some sort of elaborate choreography to complete the witnessing of the ballot where neither
5 Va. Chamber of Commerce, Increasing Support for Virginia’s Broadband Needs: An Update from the Commonwealth’s Chief Broadband Advisor, Evan Feinman, Nov. 22, 2019, https://www.vachamber.com/2019/11/22/increasing-support-for-virginias-broadband-needs-an-updatefrom-the-commonwealths-chief-broadband-advisor-evan-feinman/.
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person comes within six feet of the other. ECF No. 37 at 16. As an initial matter, this once again fails to consider that many Virginians do not live near another neighbor or know someone willing to come close enough to them to serve as a witness, may be experiencing symptoms or illness and thus quarantined, or may otherwise have accessibility issues. They also simply ignore the only scientific testimony in this case from Dr. Reingold that any such in-person exposure carries grave risks, and the evidence put forward by Plaintiffs and League members regarding the particular dangers for high-risk individuals like Plaintiff Toogood and older League members.
Even if the voter can find a witness who will agree to assist the voter in somehow meeting the requirement without coming within six feet of the voter, RPV and the Individual Voters miss two important points. First, “transmission of the virus can occur via environmental surfaces, [so] there is also risk of spread of the virus at any location where multiple individuals touch surfaces,” Reingold Decl. ¶ 11, ECF No. 17-1, which would include here the ballot materials. Second, these parties do not explain how any “anti-fraud” interest is served by forcing voters to jump through these hoops only to end up with a witness who may not know the voter and cannot see the ballot materials themselves and link that person to them.
Finally, the RPV suggests another alternative where instead of finding a witness, voters who are unable to do so write the last four digits of their social security number on the witness signature line. ECF No. 44 at 34. While this or a similar proposal may be a viable alternative in a scenario where election officials have time to print absentee ballot envelopes to reflect this new requirement, this is not the case for the June primary. Requiring voters to provide a different type of information than that called for on the envelope will likely result in confusion for many voters, and lead to disenfranchisement for those who misunderstand the requirement. In contrast, allowing individuals who cannot safely find a witness to simply omit putting anything on the
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witness signature line, while still attesting to the requirements with their signature under penalty of perjury, preserves election integrity and minimizes the risk of wrongful disenfranchisement during a public health crisis. II. The RPV and amici ignore Virginia’s other substantial election integrity
protections, and fail to connect their sparse examples of voter fraud to the witness requirement or show how it outweighs the significant harm Plaintiffs and many thousands of Virginians will face absent preliminary relief. Whatever the level of scrutiny applied when evaluating a voting restriction, in weighing that against the government interests affected by enjoining an election law, courts must consider “the precise interests put forward by the State,” and take into account “the extent to which those interests make it necessary to burden the plaintiff’s rights.” Price v. N.Y. State Bd. of Elections, 540 F.3d 101, 108–09 (2d Cir. 2008) (internal citations and quotation marks omitted); see also Ne. Ohio Coalition for the Homeless v. Husted, 837 F.3d 612, 632 (6th Cir. 2016) (“none of the precise interests put forward by Ohio,” including a generalized interest in “[c]ombatting voter fraud perpetrated by mail,” was sufficient to overcome burden of ballot rejection due to technical errors). While the RPV and amici all repeatedly assert the general interest in preventing voter fraud, none of them ever explain how the witness requirement actually advances this interest or even how eliminating the requirement during the pandemic would harm voter integrity. The most the RPV offers is an incorrect assertion that it “is undisputed that the witness requirement serves to deter fraudulent absentee balloting activity,” and references to a “level of assurance” and “solemnity” to the event of casting a ballot. ECF No. 44 at 31. Plaintiffs have previously explained why the requirement has little-to-no anti-fraud value. ECF No. 17 at 27–30. The state elections board in South Carolina, which has a similar requirement, agrees, see ECF No. 17 at 28 and ECF No. 17-3 at 58–61, as it appears at least one chief election official of a major Virginia city does as well, see ECF No. 17-2 ¶ 9. It cannot be the case that preserving an
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essentially ceremonial aspect of filling out a ballot in the middle of a pandemic outweighs the disenfranchisement of thousands of Virginia voters.
But that suggestion drives home the point that the RPV and amici have not been able to identify how the witness requirement actually advances the state’s election integrity interests, and surely not that it outweighs the risks of disenfranchisement in maintaining it. Intervenors and amici trot out vague concerns and isolated examples of “voter fraud” from across the United States as a reason to deny Plaintiffs’ motion and enforce the witness requirement during the pandemic. Much of this “evidence,” however, consists of cobbled together accusations and incidents that have nothing to do with absentee voting. Especially bold is the list supposedly listing Virginians who are deceased but who remain on voting rolls by amicus Public Interest Legal Foundation (“PILF”), an organization which recently was forced to settle a voter intimidation and defamation lawsuit against it in Virginia after publishing similar lists of purportedly unlawfully registered voters based on PILF’s faulty research and methodology. See League of United Latin Am. Citizens – Richmond Region Council 4614 v. Pub. Interest Legal Found., No. 18-cv-00423 (E.D. Va.) (alleging PILF falsely accused eligible citizens of voting illegally and resulting in a settlement requiring PILF to apologize for incorrectly characterizing these individuals as “noncitizen felons”).6
More importantly, none of these groups have connected any of these isolated incidents to the presence or absence of a witness requirement, and have not rebutted Plaintiffs’ showing of only two single incidences of absentee voting misconduct in Virginia over the past couple of
6 S. Coalition for Social Justice, Voters Strike Back and Win Settlement and Apology in Challenge to Voter Intimidation in Virginia, July 11, 2019, https://www.southerncoalition.org/voters-strike-back-andwin-settlement-in-virginia/.
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decades. ECF No. 17 at 29. As recently explained by MIT Professor Charles Stewart and coauthor Amber McReynolds, “[v]ote fraud in the United States is exceedingly rare, with mailed ballots and otherwise.”7 They noted, over the last 20 years, an average “one case per state every six or seven years” which “translates to about 0.00006 percent” of total mail votes cast in that period.8 And even if there were some minimal incidences of voter misconduct relating to absentee voting, the RPV and amici have not shown that such rare instances would or could be prevented by Virginia’s witness requirement, or that preventing those rare instances outweighs the harm of disenfranchising thousands of Virginia voters through enforcement of the witness requirement this year.
And just this week, the Tenth Circuit unanimously held that, although a state’s “interest in counting only the votes of eligible voters is legitimate in the abstract,” that interest is not a talisman justifying any restrictions on voting, and cannot suffice where the court did “not see any evidence that such an interest made it necessary to burden voters’ rights here.” Fish, 2020 WL 2050644, at *18 (affirming injunction against Kansas’s documentary proof of citizenship requirement for voter registration). Like the record in this case, the record in Fish included only “incredibly slight evidence that [the state’s] interest in counting only the votes of eligible voters is under threat,” leading the Court to rule that the challenged restrictions were unconstitutionally burdensome. Id.; see also Paher v. Cegavske, No. 3:20-cv-00243-MMD-WGC, Slip Op. at 2, 12 (D. Nev. Apr. 30, 2020) (attached as Ex. C) (denying preliminary injunction to stop plan to implement mostly mail ballot elections for the upcoming June 9, 2020 Nevada primary, because
7 Amber McReynolds & Charles Stewart, Let’s put the vote-by-mail ‘fraud’ myth to rest, The Hill, Apr. 28, 2020, https://thehill.com/opinion/campaign/494189-lets-put-the-vote-by-mail-fraud-myth-to-rest. 8 Id.
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state’s interest in protecting the health and safety of voters far outweigh Plaintiffs’ claimed burden on their right to vote that was premised on a speculative and baseless claim of potential voter fraud).
Finally, Intervenors and amici cite the recent decision by the Seventh Circuit to stay a district court decision in Wisconsin enjoining that state’s witness requirement. See Democratic Nat’l Comm. v. Bostleman, No. 20-1538 (7th Cir. Apr. 3, 2020) (filed as ECF No. 50-2 in this case). But that decision, which Plaintiffs believe was wrongly decided as to Wisconsin’s witness requirement, is nevertheless distinguishable on several grounds. First, the Seventh Circuit based its decision in part on the fact that the election was less than a week away, an issue not presented here. Slip Op. at 3. Second, the Court did not reverse the district court but rather stayed its ruling, and did so out of a concern that the district court did not properly conduct the Anderson-Burdick balancing test and evaluate the requirement’s effect on voter fraud. Id. at 3–4.9 Here, Plaintiffs recognize the need for the Court to conduct this balancing test before granting a preliminary injunction. They have shown that Virginia’s witness requirement serves little to no purpose in advancing government interests in election integrity, and even if it did, the benefit it provides would be far outweighed by the substantial risk of disenfranchisement of thousands of Virginia voters.
Because the RPV and amici have failed to rebut the burdens caused by the witness requirement in the context of the pandemic and have not even shown how the requirement promotes election integrity, Plaintiffs are entitled to a preliminary injunction.
9 Further, the Seventh Circuit specifically noted that Wisconsin’s Election Commission appeared to be issuing guidance to ease the witness requirement including by eliminating “the witness’s physical signature.” Bostleman, No. 20-1538, Slip Op. at 4.
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III. Plaintiffs’ claims are timely, not premature, and they have standing to bring them. The Individual Voters also argue that Plaintiffs have brought their claims too close to the
June primary to afford any relief. Meanwhile, the RPV asserts that any relief beyond the June primary is premature, notwithstanding that it has separately sought relief from a Virginia election statute through at least late July. The RPV also disregards the substance of the evidence Plaintiffs submitted that proves a substantial risk of irreparable harm to them absent relief. To read these briefs, everything is coming up roses and despite preexisting medical conditions and the advice of public health officials, Plaintiffs have plenty of options to safely vote in June and comply with the witness requirement. The facts in Virginia and the opinions of experts do not bear out these arguments. Plaintiffs have provided ample evidence that they face a substantial risk of imminent, irreparable harm, and are entitled to relief for the June primary and other future elections affected by COVID-19 (which will likely include at least the upcoming July special elections in Arlington and Smyth Counties).
First, amici Individual Voters and Honest Elections Project argue that Plaintiffs’ relief should be barred under Purcell v. Gonzalez, 549 U.S. 1, 4–5 (2006). But amici fail to explain how relief sought more than a month and a half before the relevant election, and before absentee ballots even begin going out to voters, fits in with the cited cases. Purcell itself concerned a ruling striking down a state law within several weeks of the election, id. at 3, and the recent Bostleman order was issued five days before Wisconsin’s April 7 election. Further, Purcell was concerned with ensuring courts weigh the risk of “voter confusion and consequent incentive to remain away from the polls,” in ordering last minute changes to voting procedures. 549 U.S. at 7. But the concerns animating Purcell are exceptionally weak where, as here, election officials have shown they are entirely capable of and willing to timely inform voters of the change—in this
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case, by agreeing to a proposed consent decree relieving some voters of the witness requirement for the June primary.
In contrast, the RPV does not argue that Purcell forbids relief for the June primary but rather that any injunction extending beyond the June primary is overbroad and the claims for those elections are not ripe. ECF No. 44 at 17–26. These arguments ignore several relevant facts and much of the evidence presented by Plaintiffs. For one, they completely disregard that two counties—Arlington and Smyth—are holding special elections in July,10 a time period they have already conceded in their state litigation will be affected by COVID-19. See Ex. B. Moreover, they ignore and fail to rebut the expert testimony of public health expert and epidemiologist Dr. Reingold, who testified that “transmission of the virus will continue through the population until the development and widespread use of a vaccine and/or herd immunity,” ECF No. 17-1 ¶ 12, neither of which are likely to occur until 2021, id. ¶¶ 13–15. Similarly, experts at the University of Virginia recognized by Virginia’s Public Health Commissioner have identified mid-August as the most likely peak of transmission in Virginia, suggesting continued community transmission through the summer and into the fall. See ECF No. 35-1 ¶ 3. Therefore, it is the RPV who is engaging in speculation about future virus transmission, not Plaintiffs.
Similarly, though the RPV makes no real challenge to Plaintiffs’ standing with respect to the June primary, it does do so with respect to future elections including the November election. Although RPV contends that Plaintiffs Toogood and Goff do not specifically allege they will vote in November, the Court can draw a reasonable inference that they will based on Erikka
10 See Arlington Cty., Voting and Elections, https://vote.arlingtonva.us/elections/ (last visited Apr. 30, 2020); Smyth Cty. Voter Registrar, http://www.smythcounty.org/voter_registrar/voter_reg.htm (last visited Apr. 30, 2020).
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Goff’s statement that she has “voted in virtually every state and federal election in which I have been able to vote,” ECF No. 17-4 ¶ 4, and Seijra’ Toogood’s statement that she “cannot think of the last federal or state election in which I have not voted, as voting and political participation are a core part of my values,” ECF No. 17-5 ¶ 3. And the League’s declaration concerning Pat McGrady’s intent to vote in future elections, hearsay or not, is still admissible in considering a preliminary injunction. ECF No. 17-6 ¶ 7-a; TechINT Sols. Group, LLC v. Sasnett, No. 5:18-CV00037, 2018 WL 4655752, at *5 (W.D. Va. Sept. 27, 2018) (“The Fourth Circuit has determined that a district court ruling on a preliminary injunction ‘may look to, and indeed in appropriate circumstances rely on, hearsay or other inadmissible evidence when deciding whether a preliminary injunction is warranted.’” (quoting G.G. ex rel. Grimm v. Gloucester Cty. Sch. Bd., 822 F.3d 709, 725–26 (4th Cir. 2016), vacated and remanded on other grounds, 137 S. Ct. 1239 (2017))).
RPV’s and amici’s arguments concerning Plaintiffs’ timing and future injuries lack merit.
CONCLUSION The RPV and amici seek to use broad assertions of voter fraud and minimizing the threat of COVID-19 to deny Plaintiffs’ relief. But the actual evidence before the Court shows otherwise. The Court should grant Plaintiffs’ preliminary injunction motion if it denies the proposed Partial Consent Judgment and Decree.
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Dated: May 1, 2020
Vishal Agraharkar (VSB #93265) Eden Heilman (VSB #93554) AMERICAN CIVIL LIBERTIES UNION FOUNDATION OF AMERICA, INC. 701 E. Franklin Street, Suite 1412 Richmond, Virginia 23219 Phone: (804) 644-8080 Fax: (804) 649-2733 vagraharkar@acluva.org eheilman@acluva.org

Respectfully submitted,
/s/ Davin M. Rosborough_______________ Davin M. Rosborough (VSB # 85935) Dale E. Ho* Sophia Lin Lakin* Theresa J. Lee* Adriel I. Cepeda-Derieux* American Civil Liberties Union Foundation 125 Broad Street, 18th Floor New York, NY 10004 Tel.: (212) 549-2500 drosborough@aclu.org dho@aclu.org slakin@aclu.org tlee@aclu.org acepedaderieux@aclu.org

Attorneys for Plaintiffs *Admitted pro hac vice

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Case 6:20-cv-00024-NKM Document 61 Filed 05/01/20 Page 18 of 18 Pageid#: 1399 CERTIFICATE OF SERVICE
I certify that on May 1, 2020, I served a copy of the foregoing Reply Brief in Support of Plaintiffs’ Motion for a Preliminary Injunction via filing with the Court’s CM/ECF system, which sent copies of this document to Counsel of Record.
/s/ Davin M. Rosborough_______________ Davin M. Rosborough (VSB # 85935) American Civil Liberties Union Foundation 125 Broad Street, 18th Floor New York, NY 10004 Tel.: (212) 549-2500 drosborough@aclu.org Counsel for Plaintiffs
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EXHIBIT A

V I R G I N I A: IN THE CIRCUIT COURT FOR THE CITY OF RICHMOND

SEVENTH CONGRESSIONAL DISTRICT REPUBLICAN COMMITTEE, A Subdivision of the Republican Party of Virginia, Inc. A Virginia Corporation,

And

BENJAMIN J. SLONE III, CHAIRMAN,

Plaintiffs,

v.

Civil Action No.: _______________________

VIRGINIA DEPARTMENT OF ELECTIONS
And
VIRGINIA STATE BOARD OF ELECTIONS
ROBERT H. BRINK, Chairman of the State Board of Elections, in his official capacity, JOHN O’BANNON, Vice-Chairman of the State Board of Elections, in his official capacity, JAMILAH D. LECRUISE, Secretary of the State Board of Elections, in her official capacity, CHRISTOPHER E. "CHRIS" PIPER, Commissioner of the State Board of Elections, in his official capacity, and JESSICA BOWMAN, Deputy Commissioner of the State Board of Elections, in her official capacity,
Defendants.
VERIFIED COMPLAINT
COME NOW, The Seventh Congressional District Republican Committee, an
official Committee of the Republican Party of Virginia, Inc. A Virginia Nonstock
Corporation (RPV), and its Chairman, Benjamin J. Slone III (Slone) (hereafter,

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collectively, “The Committee” unless otherwise designated), by counsel, and pursuant to the First and Fourteenth Amendments to the United States Constitution, 42 U.S.C. §1983, §8.01-184 et seq. and §8.01-620, et seq., of the Code of Virginia (the “Code”), state the following verified complaint for declaratory judgment and permanent, preliminary, and emergency injunctive relief against the Virginia Department of Elections (The Department), the Virginia State Board of Elections (The State Board), its Chairman, Vice-Chairman, Secretary, Commissioner, and Deputy Commissioner, (hereafter, collectively, “Defendants”) to restrain defendants, in the 2020 election cycle only, from enforcing the requirements of §24.2-510 of the Code of Virginia, as amended, requiring the Committee to select its candidate for U.S. Congress by June 9, 2020, which is the second Tuesday in June of 2020, and in support state the following;
PARTIES 1. The Seventh Congressional District Republican Committee, as previously stated, is an Official Committee of the RPV, it is comprised of twenty-four committee members, eighteen of whom are voting members, and represents all, or a portion of the following Counties in the Commonwealth of Virginia: Amelia, Chesterfield, Culpeper, Goochland, Henrico, Louisa, Nottoway, Orange, Powhatan and Spotsylvania. 2. Slone is a resident of Goochland County, Virginia, and is the duly elected Chairman of the Committee. He is suing in his official capacity as Chairman. 3. The State Board, through the Department oversees “voter registration, verification of candidates that are nominated by nonprimary methods, ballot access for candidates, campaign finance disclosure and voting equipment certification in coordination with
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Virginia’s 133 local election offices.” See also Va. Code § 24.2-103(A) (vesting the State Board of Elections, through the Department of Elections, with supervisory authority to obtain uniformity in election laws). 4. The State Board is also the entity to be notified by Slone, as Chairman, once a nominee for Congress is selected, the State Board is then tasked with notifying the general registrars of the nominee, so the proper name is placed on the ballot for the general election, which is scheduled for November 3, 2020. See §24.2-511 of the Code of Virginia 1950, as amended. 5. Defendant Robert H. Brink is the Chairman of the State Board of Elections. He is sued in his official capacity. 6. Defendant John O’Bannon is the Vice-Chairman of the State Board of Elections. He is sued in his official capacity. 7. Defendant Jamilah D. LeCruise is the Secretary of the State Board of Elections. She is sued in her official capacity. 8. Defendant Christopher E. "Chris" Piper is the Commissioner of the State Board of Elections. He is sued in his official capacity. 9. Defendant Jessica Bowman is the Deputy Commissioner of the State Board of Elections. She is sued in her official capacity.
JURISDICTION AND VENUE 10. This Court has jurisdiction to hear this suit through both §§8.01-184, et seq. and 8.01-620 of the Code of Virginia 1950, as amended.
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11. Venue is proper because the defendants are primarily based and operate within the City of Richmond, Virginia, pursuant to §8.01-261 of the Code of Virginia 1950, as amended.
FACTS 12. On August 19, 2019, the Committee met pursuant to a duly and properly called meeting by its Chairman and during that meeting the Committee unanimously voted to select its method of nomination for Congress by a convention, which is an approved method of nomination of the Party Plan (The Plan) of the RPV. 13. On February 3, 2020, The Committee met pursuant to a duly and properly called meeting by its Chairman and at that meeting the Committee approved a “Call for Convention” (The Call) to select, among other offices, its nominee for the Seventh Congressional District general election on November 3, 2020, via Convention pursuant to the RPV Plan. 14. On February 6, 2020, the Call for a convention was published on the RPV web site and has been continuously posted to this date. 15. The RPV Plan mandates that once the Call for a method of nomination is published, the method of nomination cannot be changed. 16. The published Call states that the Committee will hold its convention on April 25, 2020 at the Arthur Ashe, Jr. Athletic Center, 3001 N. Arthur Ashe Blvd., starting at 11:00 a.m. 17. As the Committee was beginning to work on logistics, contact vendors, and arrange for liability insurance to host the convention, a global pandemic in the form of a
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coronavirus, now known as Covid-19, gripped our society and brought life as we know it to a screeching halt. 18. In fact, On March 11, 2020, the World Health Organization declared COVID-19 a global pandemic.1 19. In response to the conflagration of cases and to combat COVID-19, on March 12, 2020 Governor Northam declared a State of Emergency. In his “Declaration Of A State Of Emergency Due To Novel Coronavirus (Covid-19),” Governor Northam declared that COVID-19 is public health threat because it is a communicable disease. 20. The following day, President Trump declared a national emergency. 21. On Monday, March 16, 2020, Governor Northam issued a directive stating that restaurants, fitness centers, and theatres either had to reduce capacity to 10 people or close. Governor Northam also banned all events with 100 or more persons. 22. That same day the Supreme Court of Virginia declared a judicial emergency. This order declared that a judicial emergency exists from March 16 to Monday April 6, 2020. The order further ordered that all non-emergency and non-essential court proceedings be suspended and that all deadlines are tolled for 21 days. 23. The Supreme Court of Virginia has since extended its judicial emergency Order an additional twenty-one (21) days and is now affect until April 27, 2020. 24. On March 17, President Trump declared that for a period of 15 days, there should be no gatherings of 10 or more people.
1 In fact, six candidates have filed to seek the congressional nomination and almost five thousand citizens residing within the Seventh Congressional District have filed to participate as Delegates at the scheduled convention.
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25. The White House in collaboration with the Center for Disease Control published guidelines for how people should conduct themselves through these next 15 days. Included within these guidelines is the recommendation that in areas where community spread of COVID-19 is present, “bars, restaurants, food courts, gyms, and other indoor and outdoor venues where groups of people congregate should be closed.” 26. By the beginning of March 2020, it became apparent to Slone that alternative arrangements for the convention needed to be considered in case a traditional convention could not be held on the selected date at the selected location. 27. As the impact of the pandemic became more imminent, Slone started consulting with the known congressional candidates, their campaign staffers, and members of the Committee to seek input and suggestions for an alternative way to select a nominee for Congress that would satisfy the constraints of the RPV Plan and also comply with §24.2510 of the Code of Virginia, as amended, which requires a political committee that selects its nominee by a method other than a primary election, to do so by the second Tuesday of June, which this year falls on June 9. 28. On March 23, 2020, Governor Northam issued Executive Order 53 (EO 53) in response to the global health crisis secondary to the spread of the Covid-19 coronavirus. 29. In part, EO 53 banned all gatherings of more than ten (10) persons, public or private, until 11:59 p.m., Thursday April 29, 2020; closure of all restaurants, dining establishments, food courts, breweries, microbreweries, distilleries, wineries, tasting rooms, and farmers markets to did not offer delivery or take-out services; closure of all
6

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public access to recreational and entertainment businesses; and, finally, ordered the closure of all K-12 public schools in the Commonwealth of Virginia. 30. Upon entry of EO 53, Slone duly called a telephonic conference of the Committee to discuss the impact of the Governor’s Order and also met with the known congressional candidates (all in compliance with EO 53) to further discuss how the Committee can host a convention that complies with the mandates of EO 53 and the RPV Plan that outlines the mandates of a convention, and several options were being and explored by Slone and the Committee. 31. However, on March 30, 2020, Governor Northam issued Executive Order 55 (EO 55), which took immediate effect until June 10, 2020, which is one day after the Committee is required to select its nominee for Congress by convention. 32. EO 55 mandates, “All individuals in Virginia shall remain at their place of residence, except as provided below by this Order and Executive Order 53.” 33. Additionally, it states, “All public and private in-person gatherings of more than ten individuals are prohibited. This includes parties, celebrations, religious, or other social events, whether they occur indoor or outdoor.” 34. Moreover, a violation of the public and private in-person gatherings of more than ten individuals contained in EO 55, is punishable as a Class 1 Misdemeanor pursuant to §44-146.17 of the Code of Virginia 1950, as amended. 35. In response to the issuance of EO 55, Slone and select Committee members have reached out to vendors who provide services for convention and none of them are willing to provide services before June 10.
7

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36. Additionally, since the convention is a private event, The Committee and Slone agree that a convention, especially considering the severity of the symptoms associated with the Covid-19 coronavirus, cannot be held without insurance. 37. Slone and Committee member have contacted insurers who typically underwrite insurance policies for such an event, and not one insurer will even quote a premium for a policy of insurance for an event to occur before June 10, 2020. 38. Simply stated, at this time, there is no practicable or feasible way for the Committee to conduct a convention to select its nominee for Congress that complies with the RPV Plan and does not violate EO 55. 39. Absent the global pandemic caused by the Covid-19 coronavirus, resulting in the issuance of Governor Northam’s Executive Orders 53 and 55, the Committee would have conducted its convention on April 25, 2020, pursuant to the Call and would have complied with the statutory mandates of §24.2-510 of the Code of Virginia, as amended, by notifying the Board of the identity of its nominee well before the June 9, 2020 deadline. 40. Absent an injunction, The Committee’s nominee for Congress will not appear on the ballot for the general election to be conducted on November 3, 2020. 41. This will violate the Committee’s and Slone’s constitutional right to speech and free association. 42. The defendants at all relevant times are acting under color of state law.
8

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U.S. CONSTITUTIONAL LAW – 1ST AMENDMENT 43. The First Amendment declares in no uncertain terms that Congress shall make no law abridging the freedom of speech. U.S. Const. amend. I. See also Citizens United v. FEC, 558 U.S. 310, 336 (2010). This restriction against governmental power is applied to the states through the Fourteenth Amendment. Reed v. Town of Gilbert, 135 S. Ct. 2218, 2226 (2015). 44. “It is beyond debate that freedom to engage in association for the advancement of beliefs and ideas is an inseparable aspect of the ‘liberty’ assured by the Due Process Clause of the Fourteenth Amendment, which embraces freedom of speech.” NAACP v. Alabama, 357 U.S. 449, 460 (1958). 45. The Supreme Court has made clear, “whether the beliefs sought to be advanced by association pertain to political, economic, religious or cultural matters … state action which may have the effect of curtailing the freedom to associate is subject to the closest scrutiny” Id. at 460-61. 46. The right to “voluntary political association … is an important aspect of the First Amendment freedom” that the Supreme Court “has consistently found entitled to constitutional protection.” Lefkowitz v. Cunningham, 431 U.S. 801, 808 (1977). 47. A person’s ability to exercise their rights guaranteed under the First Amendment is “[u]ndeniably enhanced by group association.” Buckley v. Valeo, 424 U.S.1, 15 (1976) (quoting NAACP v. Alabama, 357 U.S. at 460). 48. Both the First and the Fourteenth Amendments, therefore, guarantee the “freedom to associate with others for the common advancement of political beliefs and ideas...” Id.;
9

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see also Anderson v. Celebrezze, 460 U.S. 780, 787 (1983) (“[T]he right of individuals to associate for the advancement of political beliefs . . . rank[s] among our most precious freedoms.”). 49. Further, because the freedom of association enhances the effectiveness of the freedom of speech, the government cannot limit or dictate who an association chooses to associate with for the common advancement of the association’s beliefs. Tashjian v. Republican Party, 479 U.S. 208, 224 (1986). 50. Although states are entrusted with administering their elections and imposing reasonable restrictions “in exercising their powers of supervision over elections… the States may not infringe upon basic constitutional protections.” Kusper v. Pontikes, 414 U.S. 51, 57 (1973). 51. “[Ballot] Access restrictions also implicate the right to vote because, absent recourse to referendums, voters can assert their preferences only through candidates or parties or both.” Illinois State Board of Elections v. Socialist Workers Party, 440 U.S. 173, 184 (1979). 52. In constitutional analysis, the primary concern of courts is “with the tendency of ballot access restrictions to limit the field of candidates from which voters might choose.” Anderson v. Celebrezze, 460 U.S. 780, 786 (1983). 53. “By limiting the choices available to voters, the State impairs the voters' ability to express their political preferences.” Illinois State Board of Elections v. Socialist Workers Party, 440 U.S. 173, 184 (1979).
10

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VIRGINIA LAW 54. Virginia political parties are empowered to make their own rules and regulations, and for the purposes of this case, provide for the nomination of its candidates. §24.2-508 of the Code of Virginia, as amended. 55. Virginia political parties are also provided the ability to select its method of nomination, which in this case the Committee did, selecting a convention as the method of nomination. §24.2-509 of the Code of Virginia, as amended. 56. If a political party elects to use a nomination method other than by primary, the nomination process for a general election must be completed by 7:00 p.m. on the second Tuesday in June. Additionally, and equally as important, the nonprimary method of nomination shall only occur within the 47 days immediately preceding the primary date established for nominating candidates. §24.2-510 of the Code of Virginia, as amended. 57. As it applies to the case at bar, the Committee is required to nominate its nominees between April 23, 2020 and June 9, 2020. §24.2-510 of the Code of Virginia, as amended. 58. Once a nominee is selected, the Chairman of the respective Committee must notify the State Board not later than five days after the last day nominations are to be made. §24.2-511 of the Code of Virginia, as amended. 59. While it is not explicitly stated in the Code, if a political party fails to comply with these mandates, no candidate for the respective party will appear on the general election ballot.
11

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ARGUMENT 60. It goes without saying that we are all in unprecedented times due to a pandemic that threatens the health and safety of millions of people across the globe. 61. In the midst of this crisis, the citizens of this Commonwealth are attempting to move forward in order to select nominees for their respective political parties for the upcoming general election this November. 62. Unfortunately, the Committee’s efforts to select it nominee for Congress, and other positions, has ground to a halt through no fault of its own. 63. The Committee selected a convention pursuant to the RPV Plan as its method of nomination in August of 2019, with no expectation that we would be where we are today. 64. The Call for a convention was properly adopted, approved, published, and preparation for the convention began in earnest when life as we know it, in a word, stopped. 65. As a result of Governor Northam’s issuance of EO 53 and EO 55, the Committee is now unable to conduct the method of nomination within the 47-day window allowed under Virginia law. 66. “No right is more precious in a free country than that of having a voice in the election of those who make the laws under which, as good citizens, we must live. Other rights, even the most basic, are illusory if the right to vote is undermined.” Wesberry v. Sanders, 376 U.S. 1, 17, 84 S. Ct. 526, 11 L. Ed. 2d 481 (1964).
12

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67. Ballot restrictions that severely burden the right to vote and associate violate the First Amendment to the U.S. Constitution. See Storer v. Brown, 415 U.S. 724, 728-29 (1974). 68. Accordingly, “[p]recision of regulation must be the touchstone in an area so closely touching our most precious freedoms. If the State has open to it a less drastic way of satisfying its legitimate interests, it may not choose a legislative scheme that broadly stifles the exercise of fundamental personal liberties.” Kusper v. Pontikes, 414 U.S. 51, 59 (1973) (internal quotation marks and citations omitted). 69. Therefore, in recognizing that States must enact election codes for orderly, fair, and honest elections, courts reviewing challenges to ballot access cases impose a flexible standard. Burdick v. Takushi, 504 U.S. 428, 433-34 (1992). If the election regulation imposes a severe burden, then the regulation must survive strict scrutiny. Id. At 434. By contrast, if the election regulation imposes a light burden, rational basis or intermediate scrutiny applies. Id. 70. Under the current conditions created by COVID-19, including the mandates of EO 53 and EO 55, the statutory mandates of §§24.2-510 and 511, impose a severe burden on the Committee and Slone. 71. This burden is compounded because of the Governor’s mandate contained within EO 55 that “All public and private in-person gatherings of more than ten individuals are prohibited. This includes parties, celebrations, religious, or other social events, whether they occur indoor or outdoor.”
13

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72. The Department, the State Board, and Virginia do not have a compelling justification to require Plaintiffs to attempt to conduct a convention that cannot practicably be done under law until after June 10, 2020. 73. Furthermore, defendants cannot claim a compelling justification when Virginia, recognizing the danger imposed by the communicable disease COVID-19, is encouraging voters to cast absentee ballots rather than go to the polls and vote. The fact that State Defendants are encouraging voters to vote absentee and not travel to the polls insinuates that it is contrary to the health of Virginians to come into close contact with others. Virginia cannot say that for the health of voters, do not vote in person but still demand that Plaintiffs attempt to seek a nominee that would violate the Governor’s EO 55. 74. In analogous situations, courts have extended voter registration deadlines due to natural disasters, like hurricanes. See Fla. Democratic Party v. Scott, 215 F. Supp. 3d 1250 (N.D. Fla. 2016). In that court’s analysis of the burden, the court noted that in the final week before voter registration closed, an estimated 100,000 people were expected to register. Id. at 1257. But because of Hurricane Matthew, these potential voters were forced to flee the State. Id. Thus, these potential voters could not vote because they were unregistered. Id. Florida’s voter registration statute imposed a severe burden that it could not justify. Id. 75. Similarly, in this case, without an extension of the June 9, 2020, deadline, the Delegates who have signed up to elect their nominee, will be deprived of their right to vote for the candidate of their choice, and the defendants cannot articulate a compelling
14

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or sufficient reason to require the Committee to comply with the applicable Virginia statutes. 76. Absent an injunction extending the deadline for the Committee to select its nominee by a method other than a primary, the Committee’s candidate will not appear on the November ballot, which is a severe burden to the Committee’s and Slone’s First Amendment rights. See Fla. Democratic Party, 215 F. Supp. 3d at 1257. 77. Lastly, the Committee and Slone have demonstrated, absent the occurrence of the Covid-19 pandemic and Governor Northam’s issuance of EO 53 and EO 55, they would have selected a congressional nominee to appear on this November’s general election ballot. See Bowe v. Board of Election Comm'rs, 614 F.2d 1147, 1152 (7th Cir. 1980) (“The ultimate question was said to be whether in the context of California politics, a reasonably diligent candidate could be expected to be able to meet the requirements and gain a place on the ballot.”) (citing Storer, 415 U.S. at 742).
PRAYER FOR RELIEF A. That this Court take jurisdiction of this action and declare that §24.2-510 of the Code of Virginia, as amended, is unconstitutional in this particular election cycle as it is applied to the Seventh Congressional District Republican Committee and Benjamin J. Slone III; B. Temporarily enjoin the defendants from enforcing §24.2-510 of the Code of Virginia, as amended, through a date to be determined by this Court;
15

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C. That this Court select a date in the future wherein the plaintiffs can safely conduct the convention they elected to have so that they can select a congressional nominee to appear on the general election ballot on November 3, 2020; and, D. That this Court maintain jurisdiction of this case after the entry of its Temporary Injunction, so that in the event that health conditions within the Commonwealth last longer than anticipated, or even worsen, the Court will have the ability to extend the deadline again, if necessary; and, E. For such other and further relief as this Court may deem appropriate.
Respectfully Submitted, The Seventh Congressional District
Republican Committee & Benjamin J. Slone III, Chairman
VERIFICATION PURSUANT TO CODE SECTION 8.01-4.3 I, Benjamin J. Slone III, as Chairman of the Seventh Congressional District Republican Committee have reviewed the factual averments in the Verified Complaint and I can swear under penalty of perjury that those factual averments are true and correct to the best of my knowledge.
_________________________________ Benjamin J. Slone III, Chairman
16

Case 6:20-cv-00024-NKM Document 61-1 Filed 05/01/20 Page 17 of 18 Pageid#: 1416 Graven W. Craig, Esquire (VSB #41367) Rea T. “Torrey” Williams, Esquire (VSB# 84691) CraigWilliams, PLC P.O. Box 68 - 202 W. Main Street Louisa, VA 23093 (540) 967-9900 (540) 967-3567 facsimile graven@callnow.law e-mail Counsel for Plaintiffs
17

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CERTIFICATE OF SERVICE
I hereby certify that on the 7th day of April 2020, an original of the foregoing Verified Complaint was filed in the Clerk’s Office of the City of Richmond Circuit Court and a true copy was sent by electronic mail and overnight delivery to:
Heather Hays Lockerman (VSB #65535) Senior Assistant Attorney General & Section Chief Carol L. Lewis (VSB #92362) Assistant Attorney General 202 North 9th Street Richmond, VA 23219 (804) 692-0558 HLockerman@oag.state.va.us clewis@oag.state.va.us On behalf of: VIRGINIA DEPARTMENT OF ELECTIONS -andVIRGINIA STATE BOARD OF ELECTIONS ROBERT H. BRINK, Chairman of The State Board of Elections, in his official capacity, JOHN O’BANNON, Vice-Chairman of the State Board of Elections, in his official capacity, JAMILAH D. LECRUISE, Secretary of the State Board of Elections, In her official capacity, CHRISTOPHER E. "CHRIS" PIPER, Commissioner of the State Board of Elections, in his official capacity JESSICA BOWMAN, Deputy Commissioner of the State Board of Elections, in her official capacity.
Graven W. Craig
18

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EXHIBIT B

VIRGINIA: IN THE CIRCUIT COURT FOR THE CITY OF RICHMOND

SEVENTH CONGRESSIONAL DISTRICT REPUBLICAN COMMITTEE, et al.,
Plaintiffs,
v.
VIRGINIA DEPARTMENT OF ELECTIONS, et al.,
Defendants.

Civil Action No. CL20001640-00

PLAINTIFF-INTERVENOR’S UNOPPOSED MOTION TO EXTEND TEMPORARY INJUNCTION
The Republican Party of Virginia, Inc. (“Plaintiff-Intervenor” or “RPV”), by counsel, respectfully files this motion to extend the temporary injunction issued by the Court to apply to all of its Congressional District Committees that have selected a non-primary method of nomination pursuant to §24.2-509 of the Code of Virginia.
On April 14, 2020, the Court enjoined Defendants from enforcing the provisions of §24.2-510 against Plaintiffs until 7:00 p.m., Tuesday, July 28, 2020. Ct.’s Order Granting Temporary Inj. p. 7. The Court’s findings of fact in that order as they relate to the Plan of Organization of the Republican Party of Virginia, Inc. (“Party Plan”), the actions of the Governor, and the mandates of the Code of Virginia apply equally to the situation of the five other committees that have made plans to nominate by convention. Only the specific details of those other committees’ meeting dates and preparations for a convention differ and not in any material way (e.g., each Committee made its nominating method decision at a properly called

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meeting, adopted a call for convention at another such meeting, and posted its call to the RPV website; three other committees had scheduled conventions for May 30, while two also planned conventions for April 23).
The Court’s findings of law and application of law to the facts should apply equally to each of the other committees, having turned primarily on the application of the same statute and executive actions to a committee operating under the same resulting constraints. Specifically, each of the committees must meet the June 9 deadline set by §24.2-510 in order for the Party’s nominees to appear on the November 3, 2020 ballot and, in the current emergency situation, none of the committees can do so.
Counsel for Plaintiffs and Defendants have confirmed that their clients do not oppose this motion and an endorsed Consent Order is attached as Exhibit A.
For the foregoing reasons, RPV respectfully requests that the Court grant its motion to extend its temporary injunction to all of its Congressional District Committees that have selected a non-primary method of nomination.
Respectfully submitted, REPUBLICAN PARTY OF VIRGINIA, INC.

Dated: April 20, 2020

Christopher M. Marston (VSB # 65703) 2652 Group, LLC PO Box 26141 Alexandria VA 22313 (571) 482-7690 chris@2652group.com Counsel for Petitioner

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CERTIFICATE OF SERVICE I hereby certify that a true copy of the foregoing was electronically mailed on the 20th day of April, 2020, to the following: Heather Hays Lockerman (VSB # 65535) Senior Assistant Attorney General & Section Chief hlockerman@oag.state.va.us Carol L. Lewis (VSB # 92362) Assistant Attorney General Office of the Attorney General 202 North Ninth Street Richmond VA 23219 804-692-0558 clewis@oag.state.va.us Counsel for Defendants Graven W. Craig (VSB # 41367) CraigWilliams, PLC PO Box 68 – 202 W Main St Louisa VA 23093 540-967-9900 graven@callnow.law Counsel for Plaintiffs
____________________________________ Counsel

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1

EXHIBIT C

2

3

UNITED STATES DISTRICT COURT

4

DISTRICT OF NEVADA

5

***

6 STANLEY WILLIAM PAHER, et al.,

Case No. 3:20-cv-00243-MMD-WGC

7

Plaintiffs,

v.

8

BARBARA CEGAVSKE, in her official

9 capacity as Nevada Secretary of State, et

al.,

10

Defendants.

11

ORDER

12 I. SUMMARY

13

Contending with the novel coronavirus disease (“COVID-19”) pandemic, Nevada’s

14 Secretary of State Barbara Cegavske (the “Secretary”), in partnership with Nevada’s 17

15 county election officials, developed a plan to implement an all-mail election for the

16 upcoming June 9, 2020 Nevada primary in order to diminish the spread of COVID-19 (the

17 “Plan”1). Relevantly, there are currently five states in the western United States that

18 conduct elections entirely by mail: Oregon, Washington, Colorado, Utah, and Hawaii.

19 Nevada also currently allows for mail-in voting in certain mailing precincts—separate from

20 absent ballot precincts—with no reported incidents of election fraud. It is also undisputable

21 that under NRS Chapter 293, the Nevada Legislature has vested the Secretary with

22 authority to enact voting regulations and that the Secretary has pronounced the Plan to

23 safeguard the health and safety of Nevada voters (and the larger public) during

24 unprecedented times.

25 ///

26 ///

27

1The Court adopts Plaintiffs’ reference to the Plan but recognizes that Plaintiffs

challenge only the expansion of voting by mail. Intervenor-Defendants have filed a

28 separate action challenging other aspects of the Plan (ECF No. 27 at 3–4) which are not

at issue in this case.

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1

Plaintiffs William Paher, Gary Hamilton, and Terresa Monroe-Hamilton here sue

2 the Secretary and Deanna Spikula—Registrar of Voters for Washoe County (“Washoe

3 Registrar”)—chiefly claiming that the Plan is not “chosen” by Nevada’s Legislature, and

4 that an all-mail election strips voter-fraud-prevention safeguards and unconstitutionally

5 violates Plaintiffs’ right to vote due to purported vote dilution. (ECF No. 1.) Upon these

6 contentions and others, Plaintiffs seek a preliminary injunction to stop the Plan (“PI

7 Motion”).

8

The Court finds that Plaintiffs have not established an injury particularized to them

9 to confer standing. However, even if they can establish standing, Plaintiffs’ claims fail on

10 the merits and the other relevant factors for preliminary injunctive relief counsel against

11 the Court enjoining Defendants from implementing the all-mail election provisions of the

12 Plan. The Court finds that Defendants’ interests in protecting the health and safety of

13 Nevada’s voters and to safeguard the voting franchise in light of the COVID-19 pandemic

14 far outweigh any burden on Plaintiffs’ right to vote, particularly when that burden is

15 premised on a speculative claim of voter fraud resulting in dilution of votes. The Court will

16 therefore deny the PI Motion.2

17 II. BACKGROUND

18

The following facts are taken from the Verified Complaint and exhibits attached

19 thereto as well as the evidence submitted concerning the PI Motion.

20

A. The Parties

21

This action stems from the decision to hold the all-mail primary (i.e., to implement

22 the Plan’s mailing provisions), which was announced to the public on March 24, 2020.

23 ///

24 ///

25 2In addition to the PI Motion, the Court has considered Defendants’ and Intervenor-
26 Defendants’ oppositions (ECF Nos. 25 (Washoe Registrar), 27-1 (Defendant-Intervenors), 28 (Secretary), and Plaintiffs’ reply (ECF No. 43). The Court has also deliberated the
27 arguments the parties presented at a hearing on the PI Motion on April 29, 2020 (“Hearing”). Because Plaintiffs’ reply was unresponsive to Intervenor-Defendants’ brief,
28 the Court provided Plaintiffs an additional opportunity for Plaintiffs to respond to those arguments at the Hearing.
2

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1 (ECF No. 1-1.) The Plan applies only to Nevada’s June 9, 2020 primary election. (Id.) The

2 parties are described as follows.

3

Plaintiffs are all registered Nevada voters. (ECF No. 1.) Stanley resides in Reno,

4 Nevada and typically participates in in-person early voting. (Id.) Terresa Monroe-Hamilton

5 and Garry Hamilton (together, “Hamiltons”) are married, recently moved to Nevada, and

6 also reside in Reno. (Id.) The Hamiltons ordinarily vote early or in person on election day.

7 They registered to vote online the day before filing this lawsuit. (Id.)

8

The Secretary is the Chief Officer of Elections for the State of Nevada, see NRS §

9 293.124. (Id.) The Washoe Registrar is responsible for implementing the state’s election

10 laws in Washoe County. (Id.) The Secretary and Washoe Registrar are collectively

11 referenced as Defendants, where not individually referenced.

12

B. Impetus and Concerns that Led to the Plan

13

The decision to implement the Plan was made to “maintain a high level of access

14 to the ballot, while protecting the safety of voters and poll workers[—who belong to groups

15 who are at high risks for severe illness from COVID-19—].” (ECF No. 1-1.) In decreeing

16 the Plan, the Secretary wanted to “reassure voters in Nevada that their health and safety

17 while participating in voting is paramount to state and local election officials.” (Id.)

18 Pertinently, the Secretary is quoted, stating:

19

Because of the many uncertainties surrounding the COVID-19 pandemic, as

well as the immediate need to begin preparations for the 2020 primary

20

election, it became necessary for me to take action regarding how the

election will be conducted.

21

22 She further states that she, along with Nevada’s 17 county election officials, “jointly”

23 determined that “the best option for the primary election is to conduct an all-mail election.”

24 (Id.) The Secretary’s announcement of the Plan emphasized that election officials are

25 focused on also maintaining the integrity of the election: “the high standard Nevada has

26 set for ensuring the security, fairness, and accuracy of elections will still be met.” (Id.)

27 ///

28 ///

3

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1

C. The New Details of the Plan and Maintained Election Safeguards

2

Under the Plan, all active registered voters will be mailed an absentee ballot (mail-

3 in ballot) for the primary election. If a voter is registered to vote at his or her current

4 address, they need not take any further action to receive an absentee ballot. (E.g., ECF

5 No. 1-3.) If an individual is not registered or needs to update registration information (e.g.,

6 name, address, and party), they are required to do so. (Id.) To accommodate same-day

7 registration requirements enacted by the 2019 Nevada Legislature, the Plan also

8 establishes at least one physical polling place in each of Nevada’s counties and in Carson

9 City. (ECF No. 1-1.)

10

The Plan otherwise maintains Nevada’s election system and safeguards. (See ECF

11 No. 21 (Decl. of Wayne Thorley, Deputy of Elections for the Secretary).) For example,

12 NRS § 293.2725(1) requires first-time voters in Nevada to present identification and proof

13 of residency before being allowed to vote, whether in person or by mail. (Id.) The

14 requirements to present identification and proof of residency for first-time voters are

15 waived pursuant to NRS § 293.2725(2)(b) if election officials are able to match the voter’s

16 driver’s license number, ID card number or social security number with personal identifier

17 on file with the Nevada Department of Motor Vehicle (“DMV”) or Social Security

18 Administration (“SSA”). (Id.)

19

When voter registration applicants register (1) by mail, (2) through the DMV by

20 appearing in person or using the DMV's on-line system, or (3) via the Secretary of State's

21 on-line system, the overwhelming majority of those applicants are positively matched to

22 the personal identifiers on file with the DMV or the SSA. (Id.) The match is made through

23 automated systems, which the Secretary finds to be highly reliable. (Id.) Voters who are

24 positively matched to personal identifiers on file with the DMV or SSA are not required to

25 present identification and proof of residency before voting, even if they are voting for the

26 first time in Nevada. (Id.) They can simply vote in person or by mail without submitting to

27 ///

28 ///

4

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1 additional verification processes. (Id.) Voters who are not positively matched3 to personal

2 identifiers on record with the DMV or SSA must present identification and proof of

3 residency before voting (referred to as “ID required voters”). (Id.) These ID required voters

4 constitute less than 1% of all registered voters. (Id.) They have different ballot return

5 envelopes than other voters with an envelope flap indicating that the voter must return a

6 copy of the voter’s identification and proof of residency, without which their votes will not

7 count.

8

Penalties against fraudulent votes are provided for under, inter alia, NRS §§

9 293.313, 293.730(2), (3), and 293.840.

10

D. Nevada’s Election System Already Permits Mail-in Ballots in Mailing

Precincts 11

12

Nevada’s governing statutes provide for mailing precincts—specifically NRS §§

13 293.343 through 293.355. Through these provisions, the Nevada Legislature has given

14 the Secretary and county clerks authority to mail ballots to registered voters rather than

15 requiring voters to request those ballots through the absent ballot process.

16

NRS § 293.343 provides that “[w]henever the county clerk has designated a

17 precinct as a mailing precinct, registered voters residing in that precinct may vote at any

18 election regulated by this chapter in the manner provided in NRS [§§] 293.345 to 293.355,

19 inclusive.” NRS § 293.343(2). Further, NRS § 293.213 gives the county clerk unilateral

20 authority to designate a precinct as a mailing precinct if one of two conditions is met: (1) if

21 fewer than 20 registered voters reside in that precinct, or (2) if fewer than 200 ballots were

22 cast in the last general election. NRS § 293.213(1), (3). A county clerk may establish a

23 mailing precinct that does not meet the requirements of NRS § 293.213(1)–(3) “if the

24 county clerk obtains prior approval from the Secretary of State.” NRS § 293.213(4).

25

Mailing precincts, as opposed to absent ballot precincts, have been used in

26 Nevada—albeit on a small scale—for many years. (ECF No. 21 at 3.) In recent Nevada

27 3The Deputy of Elections for the Nevada Secretary of State attests that the lack of
28 a match is “almost always because of a typographical or printing error in [the] application to register to vote.” (ECF No. 21 at 2.)
5

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1 elections, a statistically significant numbers of ballots were cast by the voters in mailing

2 precincts, providing a reasonable sample of ballots cast without incidents of election fraud.

3 (Id.) The number of ballots that voters recently cast in mailing precincts are: 2018 General

4 election (3,879); 2018 Primary election (2,273); 2016 General election (6,069); 2016

5 Primary election (362); 2014 General election (4,288). (Id.)

6

E. Lawsuit

7

Plaintiffs filed this lawsuit on April 21, 2020. The Verified Complaint asserts five

8 claims for relief, detailed infra, and requests declaratory and injunctive relief to prevent the

9 Secretary and county administrators from implementing the Plan. (ECF No. 1 at 8–13.)

10 Plaintiffs particularly challenge the Plan’s expansion of mail-in voting or in their

11 characterization, “[t]he Plan would require the State to forego almost all in-person voting

12 and instead conduct the Primary by mailed absent ballots.” (ECF No. 1 at 9.) Plaintiffs

13 contend that the largely all-mail primary circumvents various statutory safeguards

14 designed to protect against voter fraud, and that their votes will as a result be diluted by

15 illegal votes. (E.g., id., at 2, 9, 12.)

16

Along with the Verified Complaint, Plaintiffs filed the PI Motion, a motion to expedite

17 briefing and hearing on the PI Motion, and a motion to consolidate the requested hearing

18 on the PI Motion with hearing on the merits of Plaintiffs’ Verified Complaint (“Consolidation

19 Motion”). (ECF Nos. 1, 2, 3,4.) The Court granted the motion to expedite in part (ECF No.

20 14) and later granted the Consolidation Motion under Fed. R. Civ. P. 65(a)(2) (ECF No.

21 36)4. The Court further granted intervention by the following parties: Nevada State

22 Democratic Party (“NSDP”), DNC Services Corporation/Democratic National Committee

23 (“DNC”), DCCC, Priorities USA, and John Solomon (collectively, “Intervenor-Defendants”).

24 (ECF No. 39.)

25 ///

26 ///

27

4However, at the Hearing the Court determined that a resolution on the merits of

the case should be deferred given the Secretary’s position as to her right to assert

28 Eleventh Amendment immunity. Such a deferral would not affect the parties’ ability to seek

interlocutory appeal.

6

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1 III. PI MOTION STANDARD

2

Federal Rule of Civil Procedure 65 governs preliminary injunctions. “‘An injunction

3 is a matter of equitable discretion’ and is ‘an extraordinary remedy that may only be

4 awarded upon a clear showing that the plaintiff is entitled to such relief.’” Earth Island Inst.

5 v. Carlton, 626 F.3d 462, 469 (9th Cir. 2010) (quoting Winter v. Nat. Res. Def. Council,

6 555 U.S. 7, 22, 32 (2008)). This relief is “never awarded as of right.” Alliance for the Wild

7 Rockies v. Cottrell (“Alliance”), 623 F.3d 1127, 1131 (9th Cir. 2011). To qualify for a

8 preliminary injunction, a plaintiff must satisfy four requirements: (1) a likelihood of success

9 on the merits; (2) a likelihood of irreparable harm; (3) that the balance of equities favors

10 the plaintiff; and (4) that the injunction is in the public interest. See Winter, 555 U.S. at 20.

11 A plaintiff may also satisfy the first and third prongs by showing serious questions going

12 to the merits of the case and that a balancing of hardships tips sharply in plaintiff’s favor.

13 Alliance, 632 F.3d at 1135 (holding that the Ninth Circuit's “sliding scale” approach

14 continues to be valid following the Winter decision).

15

On the merits-success prong, “the burdens at the preliminary injunction stage track

16 the burdens at trial.” Gonzales v. O Centro Espirita Beneficente Uniao do Vegetal, 546

17 U.S. 418, 429 (2006); see also id. at 428 (citing Ashcroft v. ACLU, 542 U.S. 656, 666

18 (2004).

19 IV. DISCUSSION

20

Plaintiffs’ claims are that the Plan: (1) violates the right to vote by removing

21 safeguards against fraudulent votes that dilute votes, which they claim is a severe burden;

22 (2) violates the right to vote for legislative representatives to establish the manner of

23 elections by substituting a scheme that replaces the Nevada Legislature’s plan; (3) violates

24 the right to vote under the Purcell5 principle; (4) violates Plaintiffs’ right to have, and to

25 vote in, federal elections where the manner of election is chosen by the state’s legislature;

26 and (5) violates the right to a republican form of government under the United States

27

28

5Purcell v. Gonzalez, 549 U.S. 1 (2006) (per curiam).

7

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1 Constitution. (ECF No. 2 at 7–20.) Defendants and Intervenor-Defendants raise threshold

2 issues about Plaintiffs’ claims that the Court will address before turning to the merits.6

3

A. Standing

4

Both Defendants and Intervenor-Defendants argue that Plaintiffs lack standing to

5 assert their claims. (ECF No. 25 at 11–16; ECF No. 28 at 8–10; ECF No. 27-1 at 9–11.)

6 The Court agrees.

7

“Article III of the Constitution limits federal-court jurisdiction to ‘Cases’ and

8 ‘Controversies.’” Massachusetts v. EPA, 549 U.S. 497, 516 (2007). “To satisfy Article III’s

9 standing requirements, a plaintiff must show (1) it has suffered an ‘injury in fact’ that is (a)

10 concrete and particularized and (b) actual or imminent, not conjectural or hypothetical; (2)

11 the injury is fairly traceable to the challenged action of the defendant; and (3) it is likely,

12 as opposed to merely speculative, that the injury will be redressed by a favorable

13 decision.” Friends of the Earth, Inc. v. Laidlaw Envtl. Servs. (TOC) Inc., 528 U.S. 167, 180-

14 81 (2000) (quoting Lujan v. Defenders of Wildlife, 504 U.S. 555, 560–61 (1992)). The party

15 invoking federal jurisdiction bears the burden of establishing these elements. FW/PBS,

16 493 U.S. at 231. Moreover, the party invoking standing also must show that it has standing

17 for each type of relief sought. Summers v. Earth Island Inst., 555 U.S. 488, 493 (2009).

18

Among other things, the Secretary argues that Plaintiffs lack standing because their

19 alleged injury is speculative and at best Plaintiffs hint at a possible injury only in the first

20 claim for voter dilution. (ECF No. 28 at 8–10.) Washoe Registrar similarly argues that

21 Plaintiffs’ injury is speculative, unsupported and not particularized. (ECF No. 25 at 11–16.)

22 Intervenor-Defendants make the same arguments, but more fully argue why Plaintiffs have

23 not alleged an injury-in-fact. (ECF No. 27-1 at 9–11.) Intervenor-Defendants contend, inter

24 alia, that Plaintiffs do not allege an injury-in-fact because Plaintiffs’ “purported injury is no

25 ///

26 6Intervenor-Defendants argue that this Court is barred by the Eleventh Amendment
27 from deciding this action—which they contend amounts to an action to enjoin state officials for alleged violations of state law. (ECF No. 27-1 at 8–9.) Neither the Secretary nor the
28 Washoe Registrar, who are the directly concerned parties, substantively argue the issue in briefing or at the Hearing. The Court will therefore not consider the issue here.
8

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1 different than that of any other voter in Nevada (or any other citizen who will be governed

2 by the candidates elected through Nevada’s elections, for that matter).” (Id. at 10.) In

3 briefing and at the Hearing, Plaintiffs counter that they have standing, in gist arguing that

4 mail-in ballots are unlawful under state law, resulting in vote dilution, and that vote dilution

5 from voter fraud results in disenfranchisement, and “disenfranchisement is a severe

6 burden that is personal to the person disenfranchised.” (E.g., ECF No. 43 at 4, 7.)

7

Plaintiffs’ argument is difficult to track and fails to even minimally meet the first

8 standing prong. The theory of Plaintiffs’ case, and which is the only alleged injury driving

9 all of their claims, is that the Plan will lead to an increase in illegal votes thereby harming

10 them as rightful voters by diluting their vote. (See generally ECF No. 1.) But Plaintiffs’

11 purported injury of having their votes diluted due to ostensible election fraud may be

12 conceivably raised by any Nevada voter. Such claimed injury therefore does not satisfy

13 the requirement that Plaintiffs must state a concrete and particularized injury. See, e.g.,

14 Spokeo Inc. v. Robins, 136 S. Ct. 1540, 1548 (2016) (citation omitted) (providing, inter

15 alia, that an injury must be “concrete and particularized”); Lujan v. Defs. of Wildlife, 504

16 U.S. 555, 573–74 (1992) (explaining that U.S. Supreme Court’s case law has “consistently

17 held that a plaintiff raising only a generally available grievance about government—

18 claiming only harm to his and every citizen’s interest in proper application of the

19 Constitution and laws, and seeking relief that no more directly and tangibly benefits him

20 than it does the public at large—does not state an Article III case or controversy”). This is

21 not a pioneering finding. Other courts have similarly found the absence of an injury-in-fact

22 based on claimed vote dilution. See, e.g., Am. Civil Rights Union v. Martinez-Rivera, 166

23 F. Supp. 3d 779, 789 (W.D. Tex. 2015) (“[T]he risk of vote dilution[ is] speculative and, as

24 such, [is] more akin to a generalized grievance about the government than an injury in

25 fact.”); cf. United States v. Florida, No. 4:12cv285-RH/CAS, 2012 WL 13034013, at *1

26 (N.D. Fla. Nov. 6, 2012) (rejecting a motion to intervene under Rule 24 based on the same

27 theory of vote dilution because the “asserted interests are the same . . . as for every other

28 registered voter in the state” and therefore constitute “[g]eneralized interests”).

9

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1

The Secretary additionally argues that she did not violate state law—because she

2 was authorized to implement the Plan under NRS § 293.213(4) and therefore Plaintiffs fail

3 to show a “causal connection” between the alleged injury of vote dilution and the purported

4 unlawful conduct they allege the Secretary has engaged in, see Lujan, 504 U.S. at 560.

5 (ECF No. 28 at 4, 7, 9.) The Court ultimately agrees with this contention in light of its

6 findings below.7

7

Even if the Court had concluded that Plaintiffs have standing here, Plaintiffs’ claims

8 also fail on the merits.8

9

B. The Merits of Plaintiffs’ Claims

10

In the PI Motion, Plaintiffs focus chiefly on likelihood of success on the merits,

11 arguing that they are likely to succeed on each of their claims. (See ECF No. 2 at 7–20.)

12 In considering the merits of Plaintiffs’ claims, the Court finds that Plaintiffs’ second, fourth,

13 and fifth claims are in many ways materially intertwined, as discussed infra. The Court

14 ultimately concludes that Plaintiffs fail to establish the merits of each claim. While the Court

15 therefore need not further consider the Winter factors, the Court also finds that the balance

16 of equities favors Defendants and Intervenor-Defendants and that injunction would not be

17 in the public’s interest.9

18 ///

19 ///

20

7Even if the Court had concluded infra that there was a violation of Nevada law in

the implementation of the all-mail provisions of the Plan, such as the Plan being untimely

21 or otherwise “inconsistent” with the intent of Nevada’s Legislature—which Plaintiffs argue,

see infra, the Court finds that Plaintiffs have not established a nexus between such alleged

22 violations and the alleged injury of vote dilution.

23

8The Court does not consider Intervenor-Defendants’ argument that Plaintiffs do

not state a cognizable federal cause of action because Plaintiffs have no private right of

24 action to enforce Nevada’s election laws. (ECF No. 27-1 at 11–12.)

25

9If the Court had concluded that Plaintiffs establish that they are likely to succeed

on the merits, the Court would also necessarily find irreparable harm. See Sanchez, et al.

26 v. Cegavske, et al., 214 F. Supp. 3d 961, 976 (D. Nev. 2016) (citing Cardona v. Oakland

Unified Sch. Dist., California, 785 F. Supp. 837, 840 (N.D. Cal. 1992) (“Abridgement or

27 dilution of a right so fundamental as the right to vote constitutes irreparable injury.”) &

Melendres v. Arpaio, 695 F.3d 990, 1002 (9th Cir. 2012) (“It is well established that the

28 deprivation of constitutional rights ‘unquestionably constitutes irreparable injury.’”)).

10

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1

1. Plaintiffs’ First Claim

2

Plaintiffs’ predominant claim, on which they expend most of their bandwidth, is that

3 the Plan violates the fundamental right to vote by removing safeguards against fraudulent

4 votes—that they claim are attendant to in-person and request-only-absentee-ballot

5 voting—that dilute votes. (ECF No. 2 at 7–15; ECF No. 43 at 3.) The Court addresses

6 some threshold issues before turning to the merits (i.e., whether Plaintiffs have established

7 a constitutional violation).

8

As an initial matter, the Court must determine the applicable test/analytical

9 framework for considering this argument. Plaintiffs specifically present the Anderson-

10 Burdick balancing test/line of cases and the Reynolds-Bush line of cases as the possible

11 frameworks for this case (ECF No. 2 at 8–9). Compare Anderson v. Celebrezze, 460 U.S.

12 780, 788–89 (1983) & Burdick v. Takushi, 504 U.S. 428, 434 (1992) with Reynolds v. Sims,

13 377 U.S. 533 (1964) & Bush v. Gore, 531 U.S. 98 (2000) (per curiam). Plaintiffs argue that

14 the latter should govern the case because they claim that voter disenfranchisement in the

15 form of vote dilution is at issue here and that the Anderson-Burdick balancing test is not

16 suitable for such claims. (See id. at 9.) They additionally posit that the Anderson-Burdick

17 line of cases should not apply because the Plan being challenged is not a state-enacted

18 election law, to which they appear to concede the Anderson-Burdick balancing test would

19 typically apply. (See id.) Defendants and Intervenor-Defendants argue that the Court

20 should, like other courts, apply the Anderson-Burdick balancing test where it is alleged

21 that an election law or policy violates the right to vote. (ECF No. 28 at 7; ECF No. 27-1 at

22 14–15; ECF No. 25 at 18.)

23

The Court will apply the Anderson-Burdick balancing test. The Court finds Plaintiffs’

24 reasons for the Reynolds-Bush framework and for rejecting the Anderson-Burdick

25 balancing test, which Plaintiffs admit is ordinarily applicable to these types of cases,

26 unpersuasive. For one, as will be explained infra, the Court disagrees with Plaintiffs that

27 the Plan does not constitute state-enacted election law. Further, Plaintiffs provide no case

28 where a Reynolds-Bush framework was applied within a context similar to the instant one.

11

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1 (See id. at 9–15.) To be sure, while Plaintiffs present this case as one about voter

2 disenfranchisement due to purported vote dilution as a result of voter fraud; their claim of

3 voter fraud is without any factual basis.10 Regarding the latter, Plaintiffs notably moved to

4 consolidate the hearing on the PI Motion with a motion on the merits of the Verified

5 Complaint, contending that the merits of this case turns on “purely legal issues.” (E.g.,

6 ECF No. 4 at 1.) Moreover, at least one case more recent than Reynolds, Anderson,

7 Burdick, and Bush—Crawford v. Marion Cty. Election Bd., 553 U.S. 181, 190 (2008)—

8 applies the Anderson-Burdick balancing test.11

9

Plaintiffs next argue that if the Court applies the Anderson-Burdick balancing test,

10 the Court should apply strict scrutiny in evaluating the burdens caused by the Plan. (ECF

11 No. 2 at 8.)12 But the Supreme Court has not been so exacting. In Crawford, the Court

12 reiterated that it has not “identif[ied] any litmus test for measuring the severity of a burden

13 that a state law imposes on a political party, an individual voter, or a discrete class of

14 voters. However slight that burden may appear, as Harper [v. Virginia Bd. Of Elections,

15 383 U.S. 663 (1966)] demonstrates, it must be justified by relevant and legitimate state

16 interests ‘sufficiently weighty to justify the limitation.’” Id. at 190 (quoting Norman v. Reed,

17 502 U.S. 279, 288–289 (1992)); see also Timmons v. Twin Cities Area New

18 Party, 520 U.S. 351, 359 (1997) (“No bright line separates permissible election-related

19 regulation from unconstitutional infringements.”). But, “[w]hen a state election law

20 ///

21 10Plaintiffs, for the first time in their reply, attempt to argue voter fraud through the
22 presentation of evidence in the form of newspaper articles. (See ECF No. 43 at 4–5.)

23

11The PI Motion makes no mention of Crawford and appears to suggest that

Anderson and Burdick should not apply here also because they predate Bush. (See ECF

24 No. 2 at 9 n.8.)

25

12Notably, Plaintiffs concede that Bush did not discuss, much less explicate, any

particular level of scrutiny. (See ECF No. 2 at 10 (“Building on Reynolds, Bush didn’t

26 discuss the scrutiny level, but held that the Florida Supreme Court could not by its orders

and interpretations of state law dilute voters’ fundamental right to vote, 551 U.S. at 107–

27 11, which was either a per-se ban of vote dilution or at least an exercise of the strict

scrutiny now required in equal-protection challenges involving fundamental rights with an

28 analysis and outcome so readily apparent that it required no detailing.”) (emphasis added).

12

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1 provision imposes only ‘reasonable, nondiscriminatory restrictions’ upon the First and

2 Fourteenth Amendment rights of voters, ‘the State's important regulatory interests are

3 generally sufficient to justify’ the restrictions.” Burdick, 504 U.S. at 434 (quoting Anderson,

4 460 U.S. at 788; see Crawford, 553 U.S. at 189–90 (internal quotation and citations

5 omitted) (“[E]venhanded restrictions that protect the integrity and reliability of the electoral

6 process itself are not invidious.”).

7

As the Supreme Court did in Crawford, this Court begins its analysis of the

8 constitutionality of the Plan’s all-mail provision by focusing on the state’s interests. See id.

9 at 191. Here, the Secretary, acting on behalf of the State of Nevada, has identified at least

10 two interests that justify the burdens that the Plan imposes on voters and potential voters

11 like Plaintiffs. The Secretary expressly implemented the Plan to protect the health and

12 safety of Nevada’s voters and to safeguard the voting franchise. (E.g., ECF No. 1-1.)

13 These are indisputably compelling and longstanding interests. For example, the states’

14 police powers over matters of public health and safety and to act over the general welfare

15 of their inhabitants is entrenched in the rights reserved to the state under the Tenth

16 Amendment to the United States Constitution. See also Reynolds, 377 U.S at 554

17 (“Undeniably the Constitution of the United States protects the right of all qualified citizens

18 to vote, in state as well as in federal elections.”).

19

On the other hand, and as the Secretary puts it (ECF No. 28 at 8), Plaintiffs cannot

20 demonstrate a burden upon their voting rights, only an imposition upon their preference

21 for in-person voting—as opposed to mail-in voting, where ballots are mailed to voters. The

22 same can be said regarding Plaintiffs’ emphasis on request-only-absentee-ballots, where

23 ballots are sent to voters only if they request one. (ECF No. 2 at 12–13, 17, 21.) Cf.

24 McDonald v. Bd. of Election Commissioners, 394 U.S. 802, 807 (1969) (providing that the

25 right to absentee voting (i.e., a preference where other voting options exists) is not a

26 fundamental right because it does not in fact put the right to vote at stake). Further,

27 Plaintiffs’ overarching theory that having widespread mail-in votes makes the Nevada

28 ///

13

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1 election more susceptible to voter fraud seems unlikely where the Plan essentially

2 maintains the material safeguards to preserve election integrity. (See ECF Nos. 1-1, 21.)

3

Moreover, although Plaintiffs cloak their preference in a claim of voter

4 disenfranchisement (e.g., ECF No. 2 at 8, 9, 17; ECF No. 43 at 7), Defendants may equally

5 claim that voters will be disenfranchised. For example, if the Plan is not implemented

6 voters worried about risks to their health or unsure about how to obtain an absentee ballot

7 may very well be discouraged from exercising the right to vote all together. Additionally,

8 as Defendants also point out, under the Plan, Plaintiffs may—if they choose to exercise

9 their preference for in-person voting—vote in person on election day at a county wide

10 polling center regardless of their precinct per NRS §§ 293.3072–.3075. (Id. at 6–7; ECF

11 No. 25 at 13.) The Court therefore concludes that Nevada’s interests, reflected by the

12 Secretary in implementing the Plan, far outweigh the burdens placed on Plaintiffs’ right to

13 vote. Thus, Plaintiffs’ first claim fails on the merits.

14

2. Plaintiffs’ Second and Fourth Claims

15

For efficiency, the Court discusses Plaintiffs’ second and fourth claims in a single

16 section because the two overlap. As noted above, Plaintiffs’ second argument is that the

17 Plan violates the right to vote for legislative representatives to establish the manner of

18 elections by substituting a scheme that replaces the Nevada Legislature’s plan. (ECF No.

19 2 at 15–16.) This argument is expressly premised on Plaintiffs’ fourth contention. (See id.

20 at 16; see also ECF No. 43 at 7–8 (explaining that the violation in the second claim results

21 due to the Plan allegedly disregarding the legislature’s chosen manner of elections—which

22 is captured by the fourth claim).) The latter is that the Plan violates Plaintiffs’ right to have,

23 and to vote in, federal elections where the manner of election is chosen by the state’s

24 legislature under Article I, section 4, clause 1 of the United States Constitution.13 (Id. at 3–

25 ///

26 13Article I, section 4, clause 1 provides:

27 The Times, Places and Manner of holding Elections for Senators and

28

Representatives, shall be prescribed in each State by the Legislature

14

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1 5, 17–18.) To be clear, both arguments rest on the claim that the Plan contravenes

2 Nevada’s Legislature/representatives’ chosen manner of election.

3

Plaintiffs appear to classify the June 9, 2020 Nevada Primary as a “federal” election

4 because “[c]andidates for the office of U.S. Representative are on the Primary ballot.” (Id.

5 at 17.) Assuming that this primary constitutes a “federal election,” the Court disagrees with

6 Plaintiffs’ material premise—that the Plan is not the Legislature’s chosen manner of

7 election.

8

The Nevada Legislature has authorized the Secretary to enact voting regulations

9 under NRS § 293.124. The section provides:

10

1. The Secretary of State shall serve as the Chief Officer of Elections for this

11

State. As Chief Officer, the Secretary of State is responsible for the

execution and enforcement of the provisions of title 24 of NRS and all other

12

provisions of state and federal law relating to elections in this State.

13

2. The Secretary of State shall adopt such regulations as are necessary to

carry out the provisions of [the election laws under Title 24—NRS Chapters

14

293–306].

15 NRS § 293.124(1)–(2). While at the Hearing Plaintiffs’ counsel argued that the Plan is not

16 a regulation—but instead a news release—such is an argument of mechanical semantics.

17 The Plan is in fact a directive authorized by the Secretary regulating the upcoming Nevada

18 primary. The Court therefore finds that, as a baseline, the Plan is effectively prescribed by

19 the state’s legislature because the Nevada Legislature has in the first instance authorized

20 the Secretary to adopt regulations to carry out the state’s election laws.

21

Plaintiffs nonetheless argue that the Plan is inconsistent with the state’s election

22 laws, contrary to NRS § 293.247. (ECF No. 2 at 3–5.) NRS § 293.247 pronounces:

23 24 25 26 ///

1. The Secretary of State shall adopt regulations, not inconsistent with the election laws of this State, for the conduct of primary, general, special and district elections in all cities and counties. Permanent regulations of the Secretary of State that regulate the conduct of a primary, general, special or district election and are effective on or before the last business day of

27

thereof; but the Congress may at any time by Law make or alter such

Regulations, except as to the Places of ch[oo]sing Senators.

28

U.S. Const. art. I, § 4, cl. 1.

15

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1

February immediately preceding a primary, general, special or district

election govern the conduct of that election.

2

. . .

3

3. The regulations must prescribe: [inter alia]

4

(j) Such other matters as determined necessary by the Secretary.

5

4. The Secretary of State may provide interpretations and take other actions

6

necessary for the effective administration of the statutes and regulations

governing the conduct of primary, general, special and district elections in this

7

State.

8 (Emphasis added.)

9

Plaintiffs particularly pinpoint four ways in which they believe the Plan is

10 “inconsistent” with election laws. Defendants and Intervenor-Defendants largely ignore the

11 minutiae of these purported inconsistencies. They instead directly argue that the all-mail

12 provisions of the Plan were lawfully prescribed pursuant to, inter alia, NRS § 293.213(4)—

13 detailed supra (ECF No. 25 at 6; ECF No. 28 at 2, 4; ECF No. 27-1 at 13) NRS §

14 293.247(4) (see ECF No. 25 at 5 (Washoe Registrar’s brief); and NRS §§ 293.343–.355

15 (ECF No. 27-1 at 13)). Plaintiffs similarly fail to grapple with the statutes Defendants and

16 Intervenor-Defendants contend authorize the all-mail in provisions of the Plan; Plaintiffs

17 merely claim that NRS § 293.213(4) was not intended to apply to the whole state. (ECF

18 No. 2 at 4 n.5.) Plaintiffs also do not particularly address subsections within NRS §

19 293.247, such as subsection (4),14 which the Court concludes also supports the

20 implementation of the Plan’s mail-in provisions. In any event, upon considering each of

21 Plaintiffs’ arguments of inconsistencies, the Court finds they are tenuous at best. The

22 Court addresses each purported inconsistency in turn below.

23 ///

24 ///

25 14That is, Plaintiffs provide no argument beyond the claim at the Hearing that the
26 Plan is not a regulation and therefore the subsection does not apply. But, if NRS § 293.247(4) does not apply based on Plaintiffs’ “the Plan is not a regulation” contention,
27 then NRS § 293.247(1), which Plaintiffs rely on for their claimed inconsistencies would be equally inapplicable. Plaintiffs’ reliance on NRS § 293.247(1) in briefing is an implicit
28 concession that the Plan is a regulation.

16

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1

First, Plaintiffs argue that the Plan is untimely, seemingly based on the last

2 sentence in subsection 1 of NRS § 293.247, because it was only announced on March 24,

3 2020. (ECF No. 2 at 3–4.) According to Plaintiffs, per subsection 1, the Plan had to be

4 implemented on or before the last business day of February 2020. (Id.) Plaintiffs’ argument

5 is flawed, at minimum, because the subject sentence clearly pertains to [p]ermanent

6 regulations of the Secretary.” NRS § 293.247(1). It is undisputed that the Plan is not

7 intended to be permanent—it only applies to the upcoming June 9, 2020 primary. (See,

8 e.g., ECF No. 1-2.)

9

Second, Plaintiffs argue that the Plan is inconsistent with certain requirements

10 under NRS §§ 293.205 and .206. (ECF No. 2 at 4.) It became clear at the Hearing that

11 Plaintiffs were more precisely contending that the Plan’s “designation” of mailing precincts

12 under NRS § 293.34315 was not timely per NRS § 293.205. Plaintiffs’ counsel appeared

13 unaware that the PI Motion also argues NRS § 293.206(1). In diligence, the Court

14 discusses both sections as briefed.

15

The first provision, NRS § 293.205, pertains to election precincts. Plaintiffs

16 particularly rely on NRS § 293.205(1), noting that it requires county clerks to establish

17 election precincts “on or before the third Wednesday in March of every even-numbered

18 year.” (Id.) NRS § 293.206 requires that “[o]n or before the last day in March of every even-

19 numbered year, the county clerk shall provide the Secretary of State and the Director of

20 the Legislative Counsel Bureau with a copy or electronic file of a map showing the

21 boundaries of all election precincts in the county,” NRS § 293.206(1). (See id.) In making

22 these arguments, Plaintiffs appear to recognize the obvious—that these provisions on

23 their face concern physical election precincts, not mail-in votes. (Id. (recognizing that

24 county clerks may establish “mailing precincts” with certain exceptions under NRS

25 293.343).) Plaintiffs nonetheless contend that based on NRS §§ 293.205(1) and .206(1)

26 ///

27 15While both the PI Motion and Plaintiffs’ reply once reference NRS § 293.343,
28 neither even mentions the words “designate” or “designation.” (See generally ECF Nos. 2, 43.)
17

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1 election precincts and maps showing the precincts’ boundaries had to be established by

2 March 18, 2020. (Id.)

3

However, the Plan would not violate the date requirements of NRS § 293.206(1)

4 because March 24 is before the “last day in March.” Even accepting Plaintiffs’ position, in

5 briefing, that the Plan is inconsistent with NRS §§ 293.205(1) and .206(1), based on the

6 purported March 18 deadlines of these provisions and assuming such provisions apply

7 here, Plaintiffs’ argument is transparently grounded on the technicality of a difference of

8 six days. It is hard to imagine that a procedural difference of six days in implementation

9 would render the Plan inconsistent with Nevada’s election laws.

10

In any event, the Court finds that Plaintiffs’ argument does not support a conclusion

11 that the Plan is inconsistent. It is obvious that the Plan does not alter the establishment of

12 precincts nor their existence as a matter of fact. The Secretary echoes this in her

13 opposition. (See ECF No. 28 at 6 (“[T]here were no changes to precinct boundaries . . .

14 [t]he only change was to the method of voting within existing precinct boundaries.”).) On

15 its face, the Plan simply supersedes the need to appear at a physical precinct as the

16 Secretary found “necessary” due to the COVID-19 pandemic. (See ECF No. 1-1 (the

17 Secretary explaining that the Plan was enacted because in light of the uncertainties

18 surrounding the COVID-19 pandemic, “it became necessary for me to take action

19 regarding how the election will be conducted”).)

20

Moreover, the Court finds that the Secretary has authority based on the plain

21 reading of NRS §§ 293.213(4) and 293.247 to prescribe regulations, like the Plan here, to

22 allow for voting by mail. Particularly, § 293.213(4) gives the Secretary authority to approve

23 mailing precincts. As noted supra, Plaintiffs merely claim that NRS § 293.213(4) was not

24 intended to apply to the whole state. (ECF No. 2 at 4 n.5.) But § 293.213(4) does not

25 suggest such a reading because it effectively operates as an exception to the preceding

26 sections—e.g., subsections (1) and (3), which permits mailing precincts if fewer than 20

27 registered voters reside in a precinct, or fewer than 200 ballots were cast in the precinct

28 in the last general election, respectively. At minimum, the Secretary had the authority to

18

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1 interpret § 293.213(4) to permit her to act in concert with county election officials to allow

2 for voting by mail in all precincts pursuant to § 293.247(4). See NRS § 293.247(4)

3 (“providing that the Secretary “may provide interpretations and take other actions

4 necessary for the effective administration of the statutes and regulations governing the

5 conduct” of the state’s elections). Section 293.247(3) also requires the Secretary to

6 prescribe, among other things, “[s]uch other matters [i.e., forms, procedures, etc.,] as

7 determined necessary by the Secretary of State.” NRS § 293.247(3)(g).

8

The Court’s conclusion regarding the Secretary’s authority further applies to

9 Plaintiffs’ third claimed inconsistency. (ECF No. 2 at 4.) Plaintiffs’ third assertion of

10 inconsistency also relies on NRS §§ 293.205 and .206 and similarly contends that these

11 sections “indicate[] the [Nevada] Legislatures’ intent for such precincts for in-person

12 voting, not that the whole election be subsumed under an exception allowing mailing

13 districts in certain circumstances.” (Id.) Again, this argument in no way undermines the

14 Secretary’s implementation of all-mail voting in light of the authority the Nevada

15 Legislature has vested with the Secretary to, for example, act as she determines

16 necessary. See NRS § 293.247(3)(g), (4). Nor does Plaintiffs’ follow-on claim that the

17 noted NRS sections reflect the Nevada Legislature’s intent “to have regular in-person

18 voting and actual absentee-ballot as the controlling model” renders the Plan inconsistent.

19 (Id. at 4–5.) This latter argument is beside the point. Implementation of the Plan is a one-

20 off situation triggered by a pandemic. It therefore would not contravene the legislature’s

21 intent “as [to] the controlling model.” What is evident is that the Secretary’s challenged

22 action here also comports with the legislature’s intent. Plaintiffs’ third argument of

23 inconsistency therefore fails.

24

Finally, Plaintiffs contend in briefing, without citing to any particular provision, that

25 where mailing precincts are created, “county clerk[s] shall, at least 14 days before

26 establishing or designating a precinct as a mailing precinct . . . cause notice of such action

27 to be: (a) Posted [as prescribed] . . . ; and (b) Mailed to each Assemblyman, [etc. as

28 prescribed]” and argue that the Plan “supplant[s]” this requirement. (Id. at 5.) The Court

19

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1

4. Plaintiffs’ Third Claim

2

Plaintiffs’ third claim is that the Plan violates the right to vote under the Purcell

3 principle. (ECF No. 2 at 16–17.) It is not clear that this is even a cognizable claim, though

4 Plaintiffs’ contention contains other defects that render the purported claim meritless,

5 which the Court discusses.

6

In Purcell, the Supreme Court vacated an order of the Court of Appeals for the Ninth

7 Circuit enjoining operation of Arizona voter identification procedures. 549 U.S. at 2. The

8 Supreme Court’s ultimate ruling to vacate the Ninth Circuit’s order resulted in the subject

9 Arizona election proceeding “without an injunction.” Id. at 6.

10

The ruling district court had denied the plaintiffs’ request for an injunction to enjoin

11 Arizona’s voter identification requirements. Id. at 3. In ruling, the district court did not issue

12 findings of facts or conclusions of law. Id.17 The plaintiffs appealed and the Ninth Circuit

13 set forth a briefing schedule that would have closed two weeks after the election. Id. The

14 circuit court ultimately issued a four-panel order, about a month before the election,

15 enjoining the enforcement of the Arizona requirement pending disposition after full

16 briefing. Id. The court “offered no explanation or justification” for its decision in the order

17 or upon a subsequent reconsideration. Id.

18

The Supreme Court’s decision to vacate the Ninth Circuit’s order emphasized the

19 “imminence of the election and the inadequate time to resolve the factual disputes” as well

20 as the possibility that a court’s order, or conflicting orders concerning election provisions,

21 may result in voter confusion. Id. at 4–6.18 The Court underscored that such possibility

22 ///

23 ///

24

17The Court noted that “[t]hese findings were important because resolution of legal

questions in the Court of Appeals required evaluation of underlying factual issues.” Purcell,

25 549 U.S. at 3.

26

18In vacating the circuit court’s decision, the Court concluded that the Ninth Circuit

failed to necessarily give deference to the district court, although recognizing that the

27 district court had not yet made factual findings. Purcell, 549 U.S. at 5. The Court also found

that the circuit court’s decision failed to show that the “ruling and findings of the District

28 Court [were] incorrect.” Id.

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1 should caution courts in deciding whether to grant or deny an injunction as an election

2 draws closer. Id.

3

This Court finds, as argued by Defendants (ECF No. 25 at 21–23, ECF No. 28 at

4 11), Plaintiffs’ reliance on Purcell is wholly inapposite to Plaintiffs’ position and ultimate

5 goal here—for the Court to issue an injunction.19 To be sure, Purcell does not appear to

6 support the Court deciding the PI Motion. Nonetheless, the Court considers and rejects

7 Plaintiffs’ specific contention that, as to courts, Purcell “applies to state and local election

8 administrators” because “election-alerting actions pose the same risk” as to both. (Id. at

9 16; see also id. at 17.) Plaintiffs provide no support for treating courts and states the same

10 under Purcell. Clearly, courts and states serve very different functions in our system of

11 governance, including in relation to prescribing the rules that govern an election. It is

12 obvious in this regard that the states ordinarily do what the courts cannot—prescribe voting

13 regulations. The Secretary, acting on behalf of the State of Nevada, has done so here,

14 and the Court finds the contention that Purcell prohibits the state doing so meritless.

15 Accordingly, Plaintiffs’ third claim fails.

16

In sum, the Court finds that Plaintiffs have not established the merits of any of their

17 five claims raised in the Verified Complaint.

18

C. Balancing of the Equities

19

The Court further finds that a balancing of the equities favors Defendants and

20 Intervenor-Defendants.

21

“To determine which way the balance of the hardships tips, a court must identify

22 the possible harm caused by the preliminary injunction against the possibility of the harm

23 caused by not issuing it.” Univ. of Haw. Prof’l Assembly v. Cayetano, 183 F.3d 1096, 1108

24 ///

25

19Plaintiffs also reference the recent Supreme Court decision in Republican Nat'l

Comm. v. Democratic Nat'l Comm. (“RNC”), No. 19A1016, 2020 WL 1672702 (U.S. Apr.

26 6, 2020). (ECF No. 2 at 16–17.) In RNC, the Supreme Court relevantly stated: “This Court

has repeatedly emphasized that lower federal courts should ordinarily not alter the election 27 rules on the eve of an election.” Id. at *1 (citing Purcell; Frank v. Walker, 574 U.S. 929

28 (2014); and Veasey v. Perry, 574 U. S. __, 135 S. Ct. 9 (2014)). Thus, RNC is equally unsupportive of Plaintiffs’ ultimate request for an injunction.

22

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1 (9th Cir. 1999). The Court must then weigh “the hardships of each party against one

2 another.” Id.

3

As indicated above, even accepting Plaintiffs’ purported harm to them of being

4 disenfranchised due to vote dilution, such disenfranchisement could be, even more

5 concretely, claimed in the absence of the Plan (and additionally by confusion that may

6 result by the Court enjoining the Plan, and appeal—which would surely follow). The Court

7 therefore concludes that, at minimum, the Plan’s all-mail election implementation to

8 protect the public during a public health crisis tips the scale of equity in favor of Defendants

9 and Intervenor-Defendants (i.e., against the issuance of an injunction).

10

D. The Public Interest

11

“In exercising their sound discretion, courts of equity should pay particular regard

12 for the public consequences in employing the extraordinary remedy of injunction.” Winter,

13 555 U.S. at 24. It is clear that as triggered by the uncertainties of COVID-19, the public’s

14 interests align with the Plan’s all-mail election provisions. As provided above, an injunction

15 precluding Defendants’ use of mail ballots in the June 9, 2020 Primary would put

16 Nevadans at risk and may result in the very type of confusion that Purcell cautions against.

17

In short, the Court finds that Plaintiffs have not proven that they are entitled to have

18 this Court enjoin the Plan’s challenged provisions.

19 V. CONCLUSION

20

The Court notes that the parties made several arguments and cited to several cases

21 not discussed above. The Court has reviewed these arguments and cases and determines

22 that they do not warrant discussion as they do not affect the outcome of the issues before

23 the Court.

24 ///

25 ///

26 ///

27 ///

28 ///

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1

It is therefore ordered that Plaintiffs’ motion for preliminary injunction (ECF No. 2)

2 is denied for the reasons provided herein.

3

DATED THIS 30th day of April 2020.

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MIRANDA M. DU

6

CHIEF UNITED STATES DISTRICT JUDGE

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 </s> Case 6:20-cv-00024-NKM Document 62 Filed 05/01/20 Page 1 of 16 Pageid#: 1448

UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA
Lynchburg Division

LEAGUE OF WOMEN VOTERS OF

VIRGINIA;

KATHERINE

D.

CROWLEY; ERIKKA GOFF; and

SEIJRA TOOGOOD,

Plaintiffs,

v.

VIRGINIA STATE BOARD OF ELECTIONS; ROBERT H. BRINK, JOHN O’BANNON, and JAMILAH D. LECRUISE, in their official capacities as Chairman, Vice-Chair, and Secretary of the Virginia State Board of Elections, respectively; and CHRISTOPHER E. PIPER, in his official capacity as Commissioner of the Virginia Department of Elections,

Defendants.

Case No. 6:20-cv-00024-NKM

PLAINTIFS’ REPLY BRIEF IN SUPPORT OF JOINT MOTION FOR ENTRY OF PARTIAL CONSENT JUDGMENT AND DECREE It is ironic that Defendant-Intervenor Republican Party of Virginia (the “RPV”) objects to the proposed consent decree in this case, having itself recently sought to enjoin a Virginia election law in state court, intervening as plaintiffs in an action claiming the law was unconstitutional in the context of the COVID-19 pandemic. Indeed, after entry of a temporary injunction, the RPV then sought and entered into a consent order with the Commonwealth expanding the temporary injunction from one congressional district into several others through July 22, again, due to COVID-19. And in yet another lawsuit filed by a Republican candidate for elected office seeking relief from a law requiring a certain number of petition signatures to

Case 6:20-cv-00024-NKM Document 62 Filed 05/01/20 Page 2 of 16 Pageid#: 1449
qualify for the primary ballot, the RPV was a defendant and did not oppose a preliminary injunction against the state law due to COVID-19. Apparently the RPV thinks the protection extended to its candidate and delegates should be withheld from voters and that consent orders on injunctions on fast timetables are only appropriate for political parties, but not when the right to vote is at stake.
But now, when a non-partisan organization and individual voters seek similar relief from a state election law requiring them to obtain third party signatures to vote during a pandemic, the RPV protests a partial consent decree as “collusive,” despite having made a similar arrangement only weeks ago. The Court should dismiss these crocodile tears, and instead grant the Partial Consent Judgment and Decree because it represents a fair, reasonable, and adequate settlement that serves the public interest in this unprecedented time. Indeed, while RPV may, and has, aired its views, it lacks standing to block approval of the Consent Decree or impose additional, confusing conditions at the final hour.
The consent decree represents hard fought progress for Plaintiffs, who were forced to bring this action and a preliminary injunction in order to bring the Commonwealth to the bargaining table to prevent deprivation of their right to vote. This agreement will preserve the right to vote and health of many Virginians, but grants Plaintiffs less than they sought in their preliminary injunction motion. That is the process that led to this compromise, and it is similar to how other consent decrees have played out in voting and other public interest cases across decades, albeit on the truncated timeline caused by the collision of a pandemic with a fastapproaching election.
Plaintiffs therefore respectfully request that the Court enter the proposed Partial Consent Judgment and Order.
2

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ARGUMENT Plaintiffs do not ask that the Court “blindly accept” the proposed partial consent decree. United States v. North Carolina, 180 F.3d 574, 581 (4th Cir. 1999). Rather, Plaintiffs merely ask the Court to review the relevant factors and, “guided by the general principle that settlements are encouraged,” find the support provided sufficient to determine it fair, adequate, reasonable, and in the public interest. As demonstrated below, the RPV cites inapplicable cases and presents requirements for approval of consent decrees that are either easily met here, or not requirements at all. I. While the Court May Consider the RPV’s Viewpoint, the RPV has No Rights Implicated by the Agreement that Would Allow the RPV to Block or Alter it. While the RPV correctly contends its objections to the consent decree “may be heard” by the Court, RPV Opp. at 7, the implication that the RPV may somehow block the consent decree because it would alter its rights lacks any merit. This is because “while an intervenor is entitled to present evidence and have its objections heard at the hearings on whether to approve a consent decree, it does not have power to block the decree merely by withholding its consent.” Loc. No. 93, Intern. Ass’n of Firefighters, AFL-CIO C.L.C. v. City of Cleveland (“Local No. 93”), 478 U.S. 501, 528–29 (1986) (internal citations omitted). Of course, if an intervening party has an independent claim, then a consent decree “cannot dispose of the valid claims of nonconsenting intervenors.” Id. at 529. But here, the RPV has no claims. In fact, as demonstrated by one of the cases the RPV relies upon in its opposition, the RPV would need to demonstrate Article III standing in order to block the consent decree—an assertion even the RPV never makes and a finding the Court has not made. In League of United Latin American Citizens, Dist. 19 v. City of Boerne, 659 F.3d 421, 428 (5th Cir. 2011), a voter in small city intervened and blocked a consent decree proposing to change the way voters elected
3

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their city council members. The court held that because the voter was “plainly seeking different relief from what the subsisting parties. . . are seeking, because he urges the court to reject the amended consent decree,” he “must establish that he has Article III standing.” Id. The Fifth Circuit found the intervenor had standing because the change at issue would have converted the city’s elections from at-large voting to single-district voting and thus the voter would lose the right to vote for all five city council members due to the decree. Id. at 531. And in the other case cited by RPV for their right to object, United States v. City of Miami, 664 F.2d 435 (5th Cir. 1981) (en banc), the court held that consent decree would have modified the collective bargaining agreement the police union negotiated and therefore its rights were directly affected. Id. at 447.
Here, the RPV not only lacks standing to object to the consent decree, it lacks any significantly protectable interests. This Court granted RPV permissive intervention, and explicitly declined to rule on whether it has any significantly protectable interests. Mem. Opinion, ECF No. 60 at 7. The rights implicated by this case are those of the Plaintiffs and Virginia voters who would be disenfranchised by the operation of the witness requirement in its current form, and those of the Commonwealth which enforces these laws. Unlike the cases cited by the RPV, this law does not implicate who is eligible to participate in Republican Party primaries or conventions and thus does not implicate the RPV’s associational rights under the First Amendment. Rather, this is a case about state administrative procedures for voting that will affect all voters and has no bearing on who or what category of person may vote in a Republican primary or convention. The State Board of Elections sets standards that “tightly regulate[]” the “form of ballots used in Virginia elections,” Marcellus v. State Bd. of Elections, 849 F.3d 169, 172 (4th Cir. 2017)—not the RPV.
4

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And despite the RPV’s attempts to cast themselves as a counterweight in a partisan battle, see ECF No. 54 at 1 (referring to Plaintiffs as “three Democratic voters and an ideologically allied nonprofit group”) and ECF No. 58 at 2 (same), RPV is the only partisan force at play here and thus has no special purpose as a counterbalance. While two of the three Plaintiffs are voting in open Democratic primaries, they seek relief to vindicate their rights as qualified Virginia voters, not as Democrats. And it is hard to think of a more non-partisan organization than the League of Women Voters, which has a long history of issues-based advocacy in support of voters, not on behalf of either political party. Cf. Preminger v. Peake, 536 F.3d 1000, 1010 (9th Cir. 2008) (“[t]he purpose of the . . . Democratic Central Committee is to promote the election of Democratic Party candidates . . . . The League [of Women Voters], by contrast, is nonpartisan. Although it seeks to influence public policy through education and advocacy, the League neither endorses nor opposes candidates—including partisan candidates—for office at any level of government”), opinion amended and superseded on denial of reh’g, 552 F.3d 757 (9th Cir. 2008).
Instead, the RPV has no direct interest like the police union did in City of Miami, because the proposed consent decree does not affect the terms of its relationship with party members or officials as the agreement did between the union members and the city. And unlike in City of Boerne, it does not change the way Republicans select their candidates. RPV is still free to choose its method for candidate selection and, in fact, used that prerogative to intervene and reach a consent agreement with the Commonwealth to extend statutory deadlines for its nonprimary selection process due to a risk of constitutional violations if those deadlines stayed in place. See ECF No. 61-2. Finally, even if the RPV’s inaccurate framing of this issue were taken as correct, at most it would have an interest in the Consent Decree’s operation in the RPV’s own
5

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primaries, and in requiring Republican primary voters to provide witness signatures during the pandemic. The RPV certainly has no interest in the Consent Decree’s operation in Virginia’s Democratic primaries.
The Court has allowed the RPV to be heard and the Court can consider whether its legal arguments are persuasive. But the RPV has no direct interest in this consent decree beyond that. The Court should reject any implication otherwise. II. The RPV’s Fairness and Adequacy Arguments Improperly Skew the Appropriate
Legal Standard, Fail to Recognize the Significant Concessions Made by Each Side, and Mischaracterize the Requirements for a Consent Decree. The RPV asserts that the settlement agreement is not fair and adequate, nor legally proper, because the parties did not take enough time to hash out the legal issues of the case; that the Plaintiffs’ claims had “significant weaknesses”; that the Defendants conceded too much; and that there is no finding of liability. As to the first three issues, the RPV ignores the unique posture of this case and limited nature of the agreement, mischaracterizes its own arguments about Plaintiffs’ evidence, and fails to properly account for the concessions made by Plaintiffs. As to the final issue, the RPV misreads the consent decree and misstates the law. First, under the RPV’s standards, consent decrees should never be reached in cases requiring resolution on a short timeline. If the Parties had let the issues play out, the Plaintiffs risked missing their opportunity for relief (indeed, amici are already arguing that it is too late for relief under Purcell), and Defendants risked having less time to adapt its election procedures to prevent voter confusion and public health consequences like those emerging in Wisconsin. And although the RPV treats this proposed consent decree as one according full relief, it is in fact much narrower, affecting only one primary election for the subset of voters unable to safely find a witness. Under these unique circumstances and in these unique times, the proposed partial
6

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consent decree should not be judged in comparison to a consent decree lasting years into the future, affecting many future elections, and binding future administrations.
Second, the RPV downplays the Plaintiffs’ concessions while pointing to supposed weaknesses in their case in implying that Defendants conceded too much. While the RPV cites pages 8-14 of their opposition to the preliminary injunction motion as an indication of “significant weaknesses,” RPV Opp. at 11, much of this takes issue with Plaintiffs’ attempt to gain relief beyond the June primary. So the purported “weaknesses” called out by the RPV are not even pertinent to the proposed partial consent decree. Relatedly, the RPV downplays the significance of Plaintiffs’ concession in the partial consent decree not to include relief for elections beyond June, which is ironic given that the RPV spent more than half of the argument section in their preliminary injunction opposition brief arguing that post-June relief was unwarranted. See ECF No. 44 at 17–26. For a supposedly minor concession, the RPV appears quite preoccupied with the issue. And while the RPV claims the request for post-June relief is “illusory,” it ignores Plaintiffs’ uncontested scientific evidence regarding the continuing risk of COVID-19 transmission beyond June, as well as the fact that the RPV itself has requested and obtained a state court consent judgment extending COVID-related relief through late July—a month in which two counties will hold special elections. See Pls.’ PI Reply at 3, 14–15. The RPV also ignores Plaintiffs’ waiver of their right to attorneys’ fees.
Finally, the RPV also concocts a new legal principle from an assortment of case law, that the consent decree is inappropriate because it “asks this Court to exercise federal judicial power to enjoin a state statute without a finding that the statute violates federal law.” RPV Opp. at 15. As an initial matter, this argument ignores that the proposed partial consent decree does support that it is necessary to remedy an impending constitutional violation. The proposed decree
7

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explains that the “agreement preserves the constitutional right to vote of Plaintiffs and other Virginia voters . . . and does so without harming the integrity of Virginia’s elections.” ECF No. 35-1 at 5 (emphasis added). Magic incanting of the word “liability” is not necessary for entry of a consent decree, and any such requirement would elevate form over substance. Indeed, the Court need not “inquire into the precise legal rights of the parties nor reach and resolve the merits of the claims or controversy” to enter a consent decree. Bragg v. Robertson, 83 F. Supp. 2d 713, 717 (S.D. W. Va. 2000), aff’d sub nom. Bragg v. W. Va. Coal Ass’n, 248 F.3d 275 (4th Cir. 2001); see also Local No. 93, 478 U.S. at 522 (“it is the agreement of the parties, rather than the force of the law upon which the complaint was originally based, that creates the obligations embodied in a consent decree.”). The cases cited by the RPV fail to show otherwise.
In Kasper v. Board of Election Com’rs of the City of Chicago, 814 F.2d 332, 342 (7th Cir. 1987), cited multiple times by the RPV, the Seventh Circuit explicitly rebuts their argument when it explains that an “alteration of the statutory scheme . . . depends on a violation of federal law” and required “a demonstration of at least a probable violation of that law as a condition to the entry of this decree.” In other words, an admission of liability was not required, but instead a showing that superseding rights were likely being violated—here, the “constitutional right to vote of Plaintiffs and other Virginia voters.” ECF No. 35-1 at 5.
In League of United Latin American Citizens, Council No. 4434 v. Clements, 999 F.2d 831, 847 (5th Cir. 1993), the problem with the proposed consent decree was not the lack of an underlying violation but rather that the proposed consent decree sought relief in an area where the parties had not identified an illegality. As the Fifth Circuit explained, a “consent decree must arise from the pleaded case and further the objectives of the law upon which the complaint is based.” Id. at 846. That is precisely the case here, where Plaintiffs have identified the illegality—
8

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a constitutional violation—and the consent decree seeks to address that precise issue. And in National Review Corp. v. Violet, 807 F.2d 285, 288 (1st Cir. 1986), the principle was that a court may not enter an unconstitutional consent judgment, the inverse of the consent judgment here.
As to League of Women Voters of Michigan v. Benson, No. 2:17-CV-14148, 2019 WL 8106156, at *2 (E.D. Mich. Feb. 1, 2019), the issue in that case was not a lack of admission of liability, but that there were parties to the case—sitting elected representatives whose districts would be affected by the redistricting agreement in the consent decree—who “would not obtain their requested relief if the Court entered the Proposed Consent Decree offered by Plaintiffs and Benson.” And while the RPV quotes League of Residential Neighborhood Advocates v. City of Los Angeles, 498 F.3d 1052, 1055 (9th Cir. 2007), for the proposition that a “federal consent decree or settlement agreement cannot be a means for state officials to evade state law,” this does not mean a consent decree cannot interpret or alter state law to prevent a constitutional violation. As the court in that case held, the “City might not have to comply with the procedural and substantive limitations set forth in its zoning ordinances if there has been a violation of federal law or if compliance will result in such a violation.” Id. at 1057–58 (9th Cir. 2007); see also Dillard v. City of Foley, 926 F. Supp. 1053, 1065 (M.D. Ala. 1995) (“consent decrees, like other judgments, can be used to modify state law.”).
Because the RPV misframes the nature of this partial consent decree, gives inappropriately short shrift to the concessions made by Plaintiffs, and relies on a non-existent legal principle that nonetheless would not defeat the agreement here, it has not rebutted the Consent Parties’ showing of fairness, adequacy, and reasonableness.
9

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III. The RPV Misunderstands the Collusion Standard and Fails to Rebut Evidence that the Proposed Consent Decree is in the Public Interest and not Collusive. The RPV also implies that the proposed partial consent decree is collusive. But it submits
no actual evidence of this purported collusion, simply ignoring the process that led to this agreement, and using general language from case law to stretch its meaning far beyond the factual contexts of those cases. In the RPV’s conception, any consent decree could bear the “hallmarks of collusion.” Moreover, the RPV’s objections based on collusion are hardly credible when just last month, the RPV itself entered into a consent agreement with the Commonwealth to expand an extended temporary injunction that allowed the RPV to ignore statutory election requirements due to the pandemic in all non-primary-method congressional districts. See Plaintiff-Intervenor Republican Party of Va.’s Unopposed Mot. to Extend Temp. Injunction, Seventh Cong. Dist. Republican Comm. v. Va. Dep’t of Elections (“Seventh Cong. Dist.”), No. CL20001640-00 (City of Richmond Cir. Ct. Apr. 20, 2020) (filed at ECF No. 61-2).
At the outset, the RPV implies that the parties are not genuinely adverse and do not possess separate interests in the outcome of the case. But the cases cited by the RPV contained actual evidence of collusion far different from the mere act of compromise in this case. In United States v. Johnson, 319 U.S. 302, 305 (1943), a case brought by a private party to challenge the constitutionality of a federal law, the suit was brought under a fictitious name, it was instituted at the defendant’s request, the plaintiff “did not employ, pay, or even meet, the attorney who appeared of record in his behalf,” and he “did not read the complaint which was filed in his name as plaintiff.” Id. at 304. Similarly, in Lord v. Veazie, 49 U.S. 251 (1850), the parties conspired to bring a suit to obtain a judgment that secured the rights to one of them that a third party had large interests in and there was no real dispute. And in Moore v. Charlotte-Mecklenburg Board of
10

Case 6:20-cv-00024-NKM Document 62 Filed 05/01/20 Page 11 of 16 Pageid#: 1458
Education, 402 U.S. 47, 48 (1971), the Court confronted the “anomaly that both litigants desire precisely the same result, namely a holding that the anti-busing statute is constitutional.”
Here, far from being a contrived or collusive lawsuit, Plaintiffs filed this action fully expecting and prepared to litigate their preliminary injunction motion to decision and beyond. On March 31, the ACLU of Virginia sent a letter to Governor Northam urging him to work with the Department of Elections to adopt a series of recommendations to “ensure that voting in all 2020 elections can occur safely and without disenfranchising any eligible voters,” including by eliminating the witness requirement.1 On April 14, Plaintiff League of Women Voters of Virginia sent a letter to Governor Northam urging that he expand options to vote at home, including by eliminating the witness requirement.2 On April 15, the ACLU of Virginia sent a letter to Defendants requesting they take immediate action to alleviate the impact of the ongoing health crisis on upcoming elections by waiving Virginia’s witness requirement. The letter informed Defendants that the ACLU and ACLU of Virginia intended to file a federal complaint on behalf of impacted persons and organizations if immediate action was not taken. See ACLU of Va. Ltr. to Defs., Apr. 15, 2020 (attached as Ex. A). The Parties did not reach an agreement, and Plaintiffs filed this action. The fact that a partial settlement was reached after Plaintiffs filed this case and their preliminary injunction motion indicates only that both parties carried distinct motivations to reach this resolution. This was not a case where the parties coordinated in advance of filing to achieve a mutually beneficial result, and thus is not collusive under the cases cited by the RPV or under any recognized legal principle.
1 ACLU Va Ltr. To Gov. Northam, Mar. 31, 2020, https://acluva.org/sites/default/files/field_documents/covid19_executive_action_voting_rights_letter_final.pdf. 2 LWV Va Ltr. To Gov. Northam, Apr. 14, 2020, https://lwv-va.org/wp-content/uploads/2020/04/2020-04-10-LWVVA-Letter-to-Gov.-Northam-re-Vote-by-Mail-1.pdf.
11

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Nor is this a case where the parties “desire precisely the same result” of holding the witness requirement unconstitutional for the duration of the pandemic. This partial consent judgment will resolve only Plaintiffs’ preliminary injunction motion, and indicates that Defendants intend to continue litigating this case and defending the challenged statute. As the Court correctly noted, the “parties’ proposed partial consent decree makes clear that this action will continue, and that the parties have no intention of ceasing litigation.” Mem. Opinion, ECF No. 60 at 6. Moreover, Plaintiffs’ interests were for a broader, longer term remedy, while Defendants wished to have certainty and resolution only for the upcoming primary. This case is nothing like Moore.
The RPV also cites several cases for the proposition that courts should be wary of consent decrees that bind public officials to their predecessors’ policy preferences. RPV Opp. at 14–15. But the partial consent decree here affects only the next two months, and does nothing to bind future administrations. Instead, it addresses an urgent situation in the context of a public health emergency—a need that the RPV surely recognizes through its state court litigation. Indeed, in Carcaño v. Cooper, No. 1:16CV236, 2019 WL 3302208, at *6 (M.D.N.C. July 23, 2019), despite its warning about binding of predecessors when there has been “little adversarial activity,” the court entered the proposed consent decree.
Finally, the RPV makes a half-hearted argument that this agreement is not in the public interest, and broadly asserts that the “public interest is served by respecting state control over electoral processes.” RPV Opp. at 17. But as another federal court recently held, the argument that it is “not in the public interest for a federal court to enter, enforce, and monitor a consent decree that dictates the operation of state-run elections” is “not a cogent objection” because whatever preferences for “federal noninterference in voting rights cases generally, . . . violations
12

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of federal rights justify the imposition of federal remedies.” Common Cause Ind. v. Marion Cty. Election Bd., No. 117CV01388SEBTAB, 2018 WL 3770134, at *2 (S.D. Ind. Aug. 9, 2018). IV. The Alternative Remedy Proposed by the RPV Would Create Voter Confusion and
Make it More Difficult for Election Officials to Timely Implement. In its last attempt to thwart the proposed partial consent decree, the RPV proposes adding new forms and imposing new requirements to replace the witness signature for certain voters in the June primary. This procedure is more involved than the one the RPV proposed just the day before, now implicating an additional form for some, but not all voters to sign. Adopting the RPV’s proposal or some variation of it will likely cause voter confusion and result in additional Virginians who are needlessly disenfranchised. For one, Plaintiffs do not understand the RPV’s reference to Federal Rule of Evidence 408. To the extent it considers this proposal some sort of offer of settlement, as explained earlier, the RPV has no standing to interject itself into approval of the partial settlement or to change the consent decree’s terms beyond making its views known to the Court. Thus, while Plaintiffs are happy to engage in further discussions and even consider mediation as the case moves forward, this eleventh-hour curveball should not be entertained. Substantively, the RPV’s idea will likely create more voter confusion and complicate the work of election officials as they begin to mail out ballots. Adding an additional form for voters to sign and attest that they are unable to safely obtain a witness signature will not only cause logistical issues, but will accomplish nothing beyond what the voter’s attestation under penalty of perjury already does. By signing the attestation under the revised rules proposed by the consent decree, the voter is affirming their identity and eligibility as well as the truthfulness of their ballot. The RPV fails to show how signing an additional piece of paper serves any “antifraud” purposes.
13

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And while having voters write the last four digits of their social security numbers as an alternative to the witness signature may be worth exploring as part of an appropriate remedy for future elections, imposing that requirement here will likely confuse some voters and risk greater disenfranchisement. Under any scenario, the absentee ballot envelopes for the June primary sent out will contain a line for a witness signature. Under the proposed consent decree, the instructions accompanying the ballot will inform voters that if they believe they may not safely obtain a witness signature, they can leave that line blank, and the process favors enfranchisement of these voters and the functioning of Virginia’s other extensive anti-fraud measures. Under the RPV’s proposal, voters who are unable to safely find a witness will have to write a different, unrelated piece of information on the witness line. Writing the last four digits of one’s social security number on a line labeled “witness signature” is bound to create confusion and cause some voters to miss that odd instruction.
Plaintiffs remain ready to discuss the social security number proposal or other variations in terms of solutions for future elections. But, at this time, imposing new requirements that voters include a piece of information that is not specified on the ballot envelopes themselves would likely defeat some of the remedial intent of the consent decree and should be rejected.
CONCLUSION The RPV’s objections to the proposed partial consent decree are surprising given its own recent conduct. No matter, its objections have no substantive merit either, as they fail to contend with the course of this litigation, substance of the consent decree, and legal framework surrounding consent decrees. The Court should reject the RPV’s arguments and enter the proposed Partial Consent Judgment Decree as a fair, adequate, reasonable settlement that serves the public interest.
14

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Dated: May 1, 2020
Vishal Agraharkar (VSB #93265) Eden Heilman (VSB #93554) AMERICAN CIVIL LIBERTIES UNION FOUNDATION OF AMERICA, INC. 701 E. Franklin Street, Suite 1412 Richmond, Virginia 23219 Phone: (804) 644-8080 Fax: (804) 649-2733 vagraharkar@acluva.org eheilman@acluva.org

Respectfully submitted,
/s/ Davin M. Rosborough______________ Davin M. Rosborough (VSB # 85935) Dale E. Ho* Sophia Lin Lakin* Theresa J. Lee* Adriel I. Cepeda-Derieux* American Civil Liberties Union Foundation 125 Broad Street, 18th Floor New York, NY 10004 Tel.: (212) 549-2500 drosborough@aclu.org dho@aclu.org slakin@aclu.org tlee@aclu.org acepedaderieux@aclu.org
Attorneys for Plaintiffs
*Admitted pro hac vice.

15

Case 6:20-cv-00024-NKM Document 62 Filed 05/01/20 Page 16 of 16 Pageid#: 1463 CERTIFICATE OF SERVICE
I certify that on May 1, 2020, I served a copy of the foregoing Plaintiffs’ Reply Brief in Support of Joint Motion for Entry of Partial Consent Judgment and Decree via filing with the Court’s CMECF system, which sent copies of this document to Counsel of Record.
/s/ Davin M. Rosborough _______________ Davin M. Rosborough (VSB # 85935) American Civil Liberties Union Foundation 125 Broad Street, 18th Floor New York, NY 10004 Tel.: (212) 549-2500 drosborough@aclu.org Counsel for Plaintiffs
16

Case 6:20-cv-00024-NKM Document 62-1 Filed 05/01/20 Page 1 of 4 Pageid#: 1464
EXHIBIT A
April 15, 2020
Department of Elections Washington Building 1100 Bank Street, First Floor Richmond, VA 23219

701 E. Franklin Street Suite 1412 (804) 644-8022 Richmond VA 23219 acluva.org
Eden Heilman Legal Director Direct Dial: 804-523-2152 Email: eheilman@acluva.org

Dear Commissioner Piper and Members Brink, O’Bannon, and Lecruise:
We write to request that the Commissioner of the Department of Elections (“Commissioner”) take immediate action to alleviate the impact of the current global health crisis on upcoming elections by waiving, for the election on June 23, 2020, as well as any future election affected by the novel coronavirus including the November general election, Virginia’s requirement that absentee voters open, mark, and reseal their absentee ballot in the presence of a witness, and have that witness sign the ballot envelope before mailing it to their registrar.1 We request further that the State Board of Elections (“Board”) take action to repeal or modify 1 Va. Admin. Code 20-70-20(B), which provides that lack of a witness signature on an absentee ballot envelope is always considered a material omission that renders invalid the ballot inside. The witness requirement, along with the Board’s regulation that ballots without witness signatures be rejected as a matter of course, presents potentially tens of thousands of Virginia voters who live alone and are social distancing in accordance with expert guidance and government orders with the Hobson’s choice of either risking their health or even their lives to vote or not voting at all. As such, because of the urgency of the matter in light of fast-approaching elections, in the event the Commissioner does not act by 5 p.m. on Thursday, April 16, 2020, the ACLU of Virginia and national ACLU intend to seek federal court involvement on behalf of persons and organizations who are impacted by this requirement.
On March 12, 2020, Gov. Northam declared a state of emergency in the Commonwealth of Virginia as a result of the outbreak of a deadly respiratory illness known as COVID-19.2 That declaration remains in force until June 10, 2020, and a subsequent Executive Order reinforced the magnitude of the emergency by directing all Virginians to stay at home except under extremely limited circumstances, and to maintain six feet of distance from all other
1 The witness requirement is codified in Va. Code § 24.2-706 and § 24.2-707. 2 See Executive Order No. 51 (Mar. 12, 2020), Declaration of a State of Emergency Due to Novel Coronavirus (COVID-19), available at https://www.governor.virginia.gov/media/governorvirginiagov/governor-ofvirginia/pdf/eo/EO-51-Declaration-of-a-State-of-Emergency-Due-to-NovelCoronavirus-(COVID-19).pdf

Case 6:20-cv-00024-NKM Document 62-1 Filed 05/01/20 Page 2 of 4 Pageid#: 1465

701 E. Franklin Street Suite 1412 (804) 644-8022 Richmond VA 23219 acluva.org
Eden Heilman Legal Director Direct Dial: 804-523-2152 Email: eheilman@acluva.org

persons with the exception of household members or caretakers.3 As of April 14, the Virginia Department of Health reported over 6,171 COVID-19 diagnoses in Virginia, resulting in 978 hospitalizations and 154 deaths.
In light of this crisis, the Commissioner has not only the moral obligation but also the explicit legal authority to waive the witness requirement to preserve Virginians’ constitutional rights which will be violated without this action or court intervention. First, Virginia law provides that the Commissioner has authority to “designate alternative methods and procedures” for handling absentee ballots “in the case of an emergency that will not allow sufficient time for the distribution and handling of . . . absentee ballots.” Va. Code § 24.2-713. The present crisis is precisely such an emergency. Because the threat posed by the novel coronavirus will last throughout the summer, including the entirety of the absentee voting period for the June 23 election,4 many of the approximately one-quarter of Virginians who live alone will not have “sufficient time” within the absentee voting period to safely comply with the witness requirement without putting their health or someone else’s health at risk. The Commissioner is squarely within his rights during this extraordinary time to rectify this problem in order to preserve the constitutional rights of Virginia voters.
Second, the Commissioner may also utilize the authority conferred upon him directly by Gov. Northam’s March 12 emergency declaration. That order granted “[a]uthorization for the heads of executive branch agencies, on behalf of their regulatory boards as appropriate, and with the concurrence of their Cabinet Secretary, to waive any state requirement or regulation.”5 As the head of the Department of Elections, one of the five executive branch agencies overseen by the Secretary of Administration, the Commissioner is authorized by Executive Order 51 to waive the absentee ballot witness requirement with concurrence of Secretary Conner, and should do so to ensure Virginians can vote without meeting unnecessary and unconstitutional requirements.
In addition to the Commissioner waiving the absentee witness requirement for the upcoming election, the Board can and should take steps to ensure that
3 See Executive Order No. 55 (2020), Temporary Stay at Home Order Due to Novel Coronavirus (COVID-19), available at https://www.governor.virginia.gov/media/governorvirginiagov/executiveactions/EO-55-Temporary-Stay-at-Home-Order-Due-to-Novel-Coronavirus(COVID-19).pdf 4 Mel Leonor & Justin Mattingly, UVA Researchers Project Mid-August Peak for New COVID-19 Cases in Virginia, Apr. 13, 2020, available at https://www.richmond.com/special-report/coronavirus/uva-researchers-projectmid-august-peak-for-new-covid-19-cases-in-virginia/article_c4e2c008-1617-52d8ad08-706abfb3d696.html 5 See Executive Order No. 51, supra note 1.

Case 6:20-cv-00024-NKM Document 62-1 Filed 05/01/20 Page 3 of 4 Pageid#: 1466

701 E. Franklin Street Suite 1412 (804) 644-8022 Richmond VA 23219 acluva.org
Eden Heilman Legal Director Direct Dial: 804-523-2152 Email: eheilman@acluva.org

no ballot is rejected because of a voter’s inability to obtain a witness signature during a pandemic. Although Virginia statutes require voters who receive a mailed absentee ballot to open, mark, and seal their ballot before a witness, and then have the witness sign their ballot envelope, see Va. Code § 24.2707, those statutes do not state that absentee ballots that are missing witness signatures must be rejected as invalid. The statute simply says that complying with the witness requirement as provided will shield the voter from a challenge. The requirement that the ballot be rejected as invalid comes from an administrative regulation providing that the lack of a witness signature must always be considered a material omission rendering the ballot invalid. See 1 Va. Admin. Code 20-70-20(B). The Board has the authority under Va. Code § 24.2-103 to repeal or ease this rule without any legislative action, and should use that authority to ensure that (a) the mere lack of a witness signature is not sufficient to invalidate the ballot of a voter without any opportunity for the voter to verify their identity by other means, and that (b) in any event no ballot is rejected for failure to obtain a witness signature during a pandemic.6
The upcoming elections will almost certainly see a dramatic increase in the share of the Virginia electorate that will need to vote an absentee ballot, including many who live alone and will be voting absentee for the first time as a result of current global health crisis. Elderly, disabled, and Black Virginians over 18 are more likely to live alone relative to the population of Virginia as a whole and also are suffering from disproportionate rates of COVID-19 infection and death. These groups therefore will face a disproportionate share of the severe burden posed by the witness requirement on voters who live alone and are social distancing. It is our hope that the Department of Elections and the Board will take steps now to alleviate this very foreseeable problem by waiving the witness requirement for upcoming elections and repealing or modifying the rule requiring the rejection of absentee ballots without a witness signature.
We would welcome the opportunity to work with the Commissioner and the Board to come to an appropriate resolution in time for registrars and electoral boards to implement changes in advance of the June 20 election. As noted above, however, in light of fast-approaching elections, in the event the Commissioner does not act by 5 p.m. on Thursday, April 16, 2020, the ACLU of Virginia and national ACLU will seek relief from the federal courts on behalf of impacted persons and organizations. Despite our potential need to pursue litigation, we also remain willing to work with you cooperatively on

6 The Board is required to post on the Internet within three business days, Va. Code § 24.2-103, but its actions concerning the conduct of elections are otherwise exempt from the requirements of the Virginia Administrative Process Act. See Va. Code § 2.2-4002(B)(8).

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appropriate solutions to ensure that all Virginians can safely participate in the 2020 elections. We look forward to reaching a quick resolution of this issue. Please do not hesitate to contact us at any time at 804-523-2152 or eheilman@acluva.org.
Sincerely,

Eden B. Heilman Legal Director

701 E. Franklin Street Suite 1412 (804) 644-8022 Richmond VA 23219 acluva.org
Eden Heilman Legal Director Direct Dial: 804-523-2152 Email: eheilman@acluva.org

cc: Secretary Keyanna Conner Chief Deputy Attorney General Erin Ashwell

 </s> Case 6:20-cv-00024-NKM Document 68 Filed 05/05/20 Page 1 of 8 Pageid#: 1589

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF VIRGINIA
LYNCHBURG DIVISION

5/5/2020

LEAGUE OF WOMEN VOTERS OF VIRGINIA, et al.,
v.

Plaintiffs,

CASE NO. 6:20-CV-00024 ORDER

VIRGINIA STATE BOARD OF ELECTIONS, et al.,

JUDGE NORMAN K. MOON Defendants.

Before the Court is the Joint Motion for Entry of Partial Consent Judgment and Decree, Dkt. 35 (“Joint Motion”), submitted by Plaintiffs League of Women Voters of Virginia, Katherine D. Crowley, Erikka Goff, and Seijra Toogood and Defendants Virginia State Board of Elections and, in their official capacities, its Chairman (Robert H. Brink), Vice-Chair (John O’Bannon), and Secretary (Jamilah D. LeCruise), as well as the Commissioner of the Virginia Department of Elections (Christopher E. Piper) (“State Defendants”).
For the reasons set forth in the accompanying Memorandum Opinion, the Court hereby GRANTS the Joint Motion, Dkt. 35, and APPROVES the proposed Partial Consent Judgment and Decree, Dkt. 35-1, which shall be attached to, and incorporated in, this Order.
It is so ORDERED. The Clerk of the Court is directed to send a certified copy of this Order and the accompanying Memorandum Opinion to all counsel of record. Entered this day of _5_t_h__ May, 2020.

CCaassee 66::2200--ccvv--0000002244--NNKKMM DDooccuummeenntt 3658-1 FiFleilded050/40/52/72/020 PaPgaege2 1ofo8f 7 PaPgaegiedi#d:#1: 539509
&9)*#*5"
UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA
Lynchburg Division

LEAGUE OF WOMEN VOTERS OF

VIRGINIA;

KATHERINE

D.

CROWLEY; ERIKKA GOFF; and

SEIJRA TOOGOOD,

Plaintiffs,

v.

VIRGINIA STATE BOARD OF ELECTIONS; ROBERT H. BRINK, JOHN O’BANNON, and JAMILAH D. LECRUISE, in their official capacities as Chairman, Vice-Chair, and Secretary of the Virginia State Board of Elections, respectively; and CHRISTOPHER E. PIPER, in his official capacity as Commissioner of the Virginia Department of Elections,

Defendants.

Case No. 6:20-cv-00024-NKM

PARTIAL CONSENT JUDGMENT AND DECREE 1. Whereas on March 12, 2020, Virginia Governor Ralph S. Northam issued Executive Order 51 (EO 51) in which he declared a state of emergency in Virginia in response to the spread in Virginia of a respiratory illness (COVID-19) caused by a novel coronavirus. 2. Whereas, on March 30, 2020, in Executive Order 55 (EO 55), Governor Northam directed that, subject to limited exceptions, “[a]ll individuals in Virginia shall remain at their place of residence, except as provided below by this Order and Executive Order 53.” ¶ 1. EO 55’s restrictions will remain in place until June 10. Id. at p. 3. 3. Whereas on April 13, 2020, researchers from the University of Virginia’s

CCaassee 66::2200--ccvv--0000002244--NNKKMM DDooccuummeenntt 3658-1 FiFleilded050/40/52/72/020 PaPgaege3 2ofo8f 7 PaPgaegiedi#d:#1: 539610
Biocomplexity Institute summarized their research in a presentation to Virginia’s Secretary of Health and Human Resources entitled “Estimation of COVID-19 Impact in Virginia.” See UVA Biocomplexity Institute PowerPoint presentation, https://www.governor.virginia.gov/media/ governorvirginiagov/governor-of-virginia/pdf/Combined-PPT-April-13.pdf. The researchers predict that if current restrictions were lifted on April 30, infection rates would begin to climb earlier than if the restrictions remained in place until June 10. See id. at p. 8-18. These researchers also predict that if current restrictions remain in place through June 10, COVID-19 cases in Virginia will likely not peak until approximately August. See id. at p. 15-16.
4. Whereas on April 17, 2020, Plaintiffs League of Women Voters of Virginia, Katherine D. Crowley, Erikka Goff, and Seijra Toogood (“Plaintiffs”) filed a complaint against the above-named Defendants challenging enforcement during the ongoing public health crisis caused by the spread of a novel coronavirus, SARS-CoV-2, of Virginia’s requirement that every voter filling out an absentee ballot must open, mark, and refold their ballot in the presence of a witness, and then have the witness sign their ballot envelope (the “witness requirement”). Among other relief requested, the Complaint sought to enjoin enforcement of the witness requirement (as stated in Va. Code § 24.2-706 and § 24.2-707 and as interpreted by 1 Va. Admin. Code 20-70-20(B)) for as long as public health officials continue to recommend social distancing practices due to the risk of community transmission of COVID-19, the respiratory disease caused by SARS-CoV-2. ECF No. 1 at 33.
5. Whereas on April 21, 2020, Plaintiffs filed a motion for preliminary injunction requesting this Court prohibit the above-named Defendants from enforcing the witness requirement for all Virginia voters for the primary election to be held on June 23, 2020 (“June Primary”), and for all subsequent elections in Virginia until such time as in-person interactions

CCaassee 66::2200--ccvv--0000002244--NNKKMM DDooccuummeenntt 3658-1 FiFleilded050/40/52/72/020 PaPgaege4 3ofo8f 7 PaPgaegiedi#d:#1: 539621

required by compliance with the witness requirement no longer pose a risk to public health and

personal safety. Plaintiffs’ motion further requested that Defendants be ordered to issue guidance

instructing election officials to count otherwise validly cast absentee ballots missing a witness

signature and conduct a public information campaign in conjunction with city and county

election officials about the elimination of the requirement.

6. Whereas federal guidelines state: “[e]veryone should . . . avoid close contact” by

“stay[ing] home as much as possible” and “put[ting] distance between yourself and other

people.” Centers for Disease Control and Prevention, Coronavirus Disease 2019: How to Protect

Yourself & Others, https://www.cdc.gov/coronavirus/2019-ncov/prevent-getting-

sick/prevention.html (last visited Apr. 27, 2020). And whereas other federal guidelines

“[e]ncourage voters to use voting methods that minimize direct contact.” Centers for Disease

Control and Prevention, Recommendations for Election Polling Locations: Interim guidance to

prevent

spread

of

coronavirus

disease

2019

(COVID-19),

https://www.cdc.gov/coronavirus/2019-ncov/community/election-polling-locations.html (last

visited Apr. 26, 2020).

7. Whereas on April 24, 2020, Governor Northam released “Forward Virginia,”

(Blueprint), explaining the metrics that must be in place to begin relaxing measures implemented

to slow the spread of COVID-19. Forward Virginia PowerPoint

https://www.governor.virginia.gov/media/governorvirginiagov/governor-of-virginia/pdf/Slide-

Deck-4-24-2020-.pdf. Phase One of the Blueprint will begin when, among other factors, the

percentage of positive COVID-19 tests decreases over a fourteen day period. See id. As of April

27, 2020, the percentage of positive tests continued to increase. See id.

CCaassee 66::2200--ccvv--0000002244--NNKKMM DDooccuummeenntt3658-1 FiFleilded050/40/52/72/020 PaPgaege5 4ofo8f 7 PaPgaegiedi#d:#1: 539632
8. Whereas pursuant to Va. Code § 24.2-612, absentee voting must be available 45 days prior to the June Primary, or Saturday, May 9, 2020. For localities whose general registrar’s offices are closed on Saturday, absentee ballots must be available on May 8, 2020.
9. Whereas in light of the data that supports the Plaintiffs’ concerns for their safety if they are required to interact with others in order to cast their ballot in the June Primary, Plaintiffs and Defendants (collectively, the “Consent Parties”) agree that an expeditious resolution of this matter for the June Primary, in the manner encompassed by the terms of this Consent Decree, is in the best interests of the health, safety, and constitutional rights of the citizens of the Commonwealth of Virginia, and therefore in the public interest.
10. Whereas the Consent Parties further agree that no eligible voter should have to choose between casting a ballot that will count and placing their own health at risk.
11. Whereas Defendants agree not to enforce the witness requirement for the June Primary for absentee voters who believe they may not safely have a witness present while completing their ballot.
12. Whereas Plaintiffs agree to withdraw their April 21, 2020, motion for preliminary injunction upon entry of this Partial Consent Judgment and Decree.
13. Whereas the Consent Parties agree that entry of this Consent Decree does not affect the viability of Plaintiffs’ claims under the First and Fourteenth Amendments to the Constitution, or Section 2 of the Voting Rights Act, with respect to enforcement of the witness requirement in any subsequent elections after the June Primary.
14. Whereas Plaintiffs agree to a waiver of any entitlement to damages, fees, including attorneys’ fees, expenses, and costs, that may have accrued as of the date of the entry of this order, with respect to the claims raised by Plaintiffs in this action, provided, however, that

CCaassee 66::2200--ccvv--0000002244--NNKKMM DDooccuummeenntt 3658-1 FiFleilded050/40/52/72/020 PaPgaege6 5ofo8f 7 PaPgaegiedi#d:#1: 539643
Plaintiffs reserve their rights to seek costs and attorneys’ fees on their claims in the event of material non-compliance by Defendants with the terms and conditions of this Consent Decree.
15. Whereas the Court finds that it has subject matter jurisdiction over the Consent Parties and that the Partial Consent Judgment and Decree is fair, adequate, and reasonable and not illegal, a product of collusion, or against the public interest, because such agreement preserves the constitutional right to vote of Plaintiffs and other Virginia voters while promoting public health during a pandemic and does so without harming the integrity of Virginia’s elections. It does give appropriate weight to Defendants’ expertise and public interest responsibility in the area of election administration.
16. Whereas Plaintiffs made a sufficiently strong showing on the merits of the claim, as shown in their complaint and motion for preliminary injunction, to further support the fairness, adequacy, and reasonableness of this Partial Consent Judgment and Decree. IT IS HEREBY ORDERED, ADJUDGED, AND DECREED FOR THE REASONS STATED ABOVE IN PARAGRAPHS 1-16 THAT:
1. For the Primary elections scheduled for June 23, 2020, Defendants shall not enforce the requirement, as stated in Va. Code § 24.2-706 and § 24.2-707, that absentee voters who believe that they may not safely have another individual present to witness the voter open, mark, and refold their ballot, and then have that that individual sign the absentee ballot envelope next to the voter’s statement and signature.
2. Defendants shall issue guidance instructing all relevant city and county election officials to count all absentee ballots in the June primary that are otherwise validly cast but missing a witness signature.

CCaassee 66::2200--ccvv--0000002244--NNKKMM DDooccuummeenntt 3658-1 FiFleilded050/40/52/72/020 PaPgaege7 6ofo8f 7 PaPgaegiedi#d:#1: 539654

3. Defendants shall issue updated instructions to include with all absentee ballots as provided in Va. Code. § 24.2-706—or issue guidance instructing all relevant city and county election officials to modify or amend the printed instructions accompanying each absentee ballot—to inform voters that any absentee ballot cast in the June Primary without a witness signature will not be rejected on that basis and specifically informing voters in bold print that they may disregard the witness signature line on the absentee ballot envelope if they believe they may not safely have a witness present while completing their ballot.
4. Defendant Commissioner of Elections shall take additional reasonable steps to inform the public that the witness requirement will not be enforced for the June Primary for those absentee voters who believe they may not safely have a witness present while completing their ballot, and issue guidance instructing all relevant city and county election officials to do the same.
5. Plaintiffs will withdraw their motion for a preliminary injunction. 6. In accordance with the terms of this Consent Decree, the Consent Parties shall each bear their own fees, expenses, and costs incurred as of the date of this Order, with respect to all claims raised by Plaintiffs against the Defendants.

Dated: May _5__, 2020

________________________ United States District Judge

/s/ Davin M. Rosborough_______________ Davin M. Rosborough (VSB # 85935) Dale E. Ho* Sophia Lin Lakin* Theresa J. Lee*

MARK R. HERRING Attorney General of Virginia By: /s/ Carol L. Lewis CAROL L. LEWIS (VSB #92362) MICHELLE S. KALLEN (VSB #93286)

CCaassee 66::2200--ccvv--0000002244--NNKKMM DDooccuummeenntt 3658-1 FiFleilded050/40/52/72/020 PaPgaege8 7ofo8f 7 PaPgaegiedi#d:#1: 539665

Adriel I. Cepeda-Derieux* American Civil Liberties Union Foundation 125 Broad Street, 18th Floor New York, NY 10004 Tel.: (212) 549-2500 drosborough@aclu.org dho@aclu.org slakin@aclu.org tlee@aclu.org acepedaderieux@aclu.org
Vishal Agraharkar (VSB #93265) Eden Heilman (VSB #93554) AMERICAN CIVIL LIBERTIES UNION FOUNDATION OF AMERICA, INC. 701 E. Franklin Street, Suite 1412 Richmond, Virginia 23219 Phone: (804) 644-8080 Fax: (804) 649-2733 vagraharkar@acluva.org eheilman@acluva.org
Attorneys for Plaintiffs
*Admitted pro hac vice

HEATHER HAYS LOCKERMAN (VSB #65535) Office of the Attorney General 202 North Ninth Street Richmond, Virginia 23219 804-692-0558 (telephone) 804-692-1647 (facsimile) clewis@oag.state.va.us
Attorneys for Robert H. Brink, John O’Bannon, Jamilah D. LeCruise and Christopher E. Piper in their official capacities, and the Virginia State Board of Elections

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Case 6:20-cv-00024-NKM Document 69 Filed 05/05/20 Page 19 of 28 Pageid#: 1615

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 </s> Case 6:20-cv-00024-NKM Document 72 Filed 05/11/20 Page 1 of 14 Pageid#: 1629

UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA
Lynchburg Division

LEAGUE OF WOMEN VOTERS OF

VIRGINIA, et al.,

)

)

Plaintiffs,

)

)

v.

)

)

VIRGINIA STATE BOARD OF ELECTIONS, )

et al.,

)

)

Defendants.

)

Case No. 6:20-cv-00024

ANSWER TO COMPLAINT FOR INJUNCTIVE DECLARATORY RELIEF

1. Defendants admit the first sentence of paragraph 1 of Plaintiffs’ Complaint

accurately recites the statement of Virginia Attorney General Mark R. Herring that appeared in

an April 8, 2020 press release. Defendants lack knowledge or information sufficient to form a

belief about the truth of the allegations in the second sentence of paragraph 1 of Plaintiffs’

Complaint. With respect to the allegations in the third sentence of paragraph 1, Defendants

admit that as a result of the COVID-19 pandemic, there are absentee voters who believe they

may not, and who in reality may not, safely have a witness present while completing their ballot.

Defendants deny the remaining allegations in paragraph 1.

2. Defendants lack knowledge or information sufficient to form a belief about the

truth of the allegations regarding Plaintiffs’ motivations for bringing this action. With respect to

the second sentence of paragraph 2 of Plaintiffs’ Complaint, Defendants admit that based on

current conditions and information, certain voters might be at higher risk for severe illness from

COVID-19. Defendants admit that for these higher risk voters who live alone, the witness

Case 6:20-cv-00024-NKM Document 72 Filed 05/11/20 Page 2 of 14 Pageid#: 1630
requirement may place a burden on the ability to vote during the June 23 primary elections. Defendants deny the remaining allegations in paragraph 2.
3. Statements of the Centers for Disease Control and Prevention and the Virginia Department of Health and Governor Northam’s Executive Order speak for themselves. Defendants deny any allegations in paragraph 3 that are inconsistent with those statements and orders.
4. Defendants admit that, based on current conditions and information, certain voters might be at higher risk for severe illness from COVID-19. Defendants admit that for these higher risk voters who live alone, the witness requirement may place a burden on the ability to vote during the June 23 primary elections. Defendants deny the remailing allegations in paragraph 4.
5. Defendants admit that voters at higher risk for severe illness from COVID-19 may believe that they are unable to fulfill the witness requirement of the absentee ballot for the June 23 primary elections because they deem the risk of contact with a third party is too high. Defendants admit, to the extent that certain voters at higher risk for severe illness from COVID19 live alone in higher proportions, that the witness requirement may place a burden on their ability to vote during the June 23 primary elections. Defendants deny the remaining allegations in paragraph 5.
6. Defendants admit that, based on current conditions and information, certain voters might be at higher risk for severe illness from COVID-19. Defendants admit that Virginia has a history of voter discrimination with respect to African Americans and that discrimination in other areas of the economy may persist. Defendants deny the remaining allegations in paragraph 6.
2

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7. Defendants admit the allegations in the first sentence of paragraph 7. Defendants lack knowledge or information sufficient to form a belief about the truth of the allegations in the second sentence of paragraph 7.
8. Defendants admit that the impact of the witness requirement on voters at higher risk for severe illness from COVID-19 who live alone may be the disenfranchisement of those voters during the June 23 primary elections. Defendants lack knowledge or information sufficient to form a belief about the truth of the allegations with respect to the impact of the witness requirement on the degree of disenfranchisement that may be caused during other elections. Defendants deny the remaining allegations in paragraph 8.
9. Defendants deny the allegations in paragraph 9. PARTIES
10. Defendants lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 10.
11. Defendants lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 11.
12. Defendants lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 12.
13. Defendants lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 13.
14. Defendants lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 14.
15. Defendants lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 15.
3

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16. Defendants lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 16.
17. Defendants lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 17.
18. Defendants lack knowledge or information sufficient to form a belief about the truth of the allegations in paragraph 18.
19. Defendants admit the allegations in paragraph 19. 20. Defendants admit the allegations in paragraph 20. 21. Defendants admit the allegations in paragraph 21. 22. Defendants admit the allegations in paragraph 22. 23. Defendants admit the allegations in paragraph 23.
JURSIDICTION AND VENUE 24. Paragraph 24 presents conclusions of law to which no response is required. Defendants do not challenge this Court’s jurisdiction over this matter. 25. Paragraph 25 presents conclusions of law to which no response is required. Defendants do not challenge this Court’s jurisdiction over this matter. 26. Paragraph 26 presents conclusions of law to which no response is required. 27. Paragraph 27 presents conclusions of law to which no response is required. Defendants do not challenge this matter being venued in the Western District of Virginia.
FACTS Transmission of COVID-19 and Public Health Guidelines
28. Defendants admit the allegations in paragraph 28. 29. Defendants admit the allegations in paragraph 29.
4

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30. Defendants admit the allegations in paragraph 30. 31. Defendants admit the allegations in paragraph 31. 32. Defendants admit the allegations in paragraph 32. 33. Defendants admit that there are voters at higher risk for severe illness from COVID-19. Defendants admit that Plaintiffs have accurately described the media reports referenced in paragraph 33. Defendants lack knowledge or information sufficient to form a belief about the remaining allegations in paragraph 33. 34. Defendants admit that Plaintiffs have accurately described the media reports referenced in paragraph 34. Defendants lack knowledge or information sufficient to form a belief about the remaining allegations in paragraph 34. 35. Defendants admit the allegations in paragraph 35. 36. Defendants admit the allegations in paragraph 36. 37. Defendants admit that in person activities, such a voting, increase the risk of the spread of the virus that causes COVID-19. Defendants lack knowledge or information sufficient to form a belief about the truth of the remaining allegations in paragraph 37. 38. Defendants admit that Plaintiffs have accurately described the media reports referenced in paragraph 38. Defendants lack knowledge or information sufficient to form a belief about truth of the facts presented in the media reports relied upon in paragraph 38. 39. Defendants admit that Plaintiffs have accurately described the media reports referenced in paragraph 39. Defendants lack knowledge or information sufficient to form a belief about truth of the facts presented in the media reports relied upon in paragraph 39. Defendants deny the remaining allegations in paragraph 39. COVID-19 in Virginia
5

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40. Defendants admit the allegations in paragraph 40. 41. Defendants admit the allegations in paragraph 41. 42. Defendants admit the allegations in paragraph 42. 43. Defendants admit the allegations in paragraph 43. 44. Defendants admit the allegations in paragraph 44. 45. Defendants admit the allegations in paragraph 45. 46. Defendants admit the allegations in paragraph 46. 47. Defendants admit the allegations in paragraph 47. 48. Defendants admit the allegations in paragraph 48. 49. Defendants admit the allegations in paragraph 49. 50. Defendants admit the allegations in paragraph 50. 51. Defendants admit the allegations in paragraph 51. 52. Defendants admit the allegations in paragraph 52. 53. Defendants admit the allegations in paragraph 53. COVID-19’s Impact on African American Virginians in Light of Ongoing and Historical Discrimination 54. Defendants admit that, based on current conditions and information, certain voters might be at higher risk for severe illness from COVID-19. Defendants admit that Plaintiffs have accurately described the media report referenced in paragraph 54. Defendants lack knowledge or information sufficient to form a belief about truth of the facts presented in the media report relied upon in paragraph 54. 55. Defendants admit that, based on current conditions and information, certain voters might be at higher risk for severe illness from COVID-19. Defendants admit that Plaintiffs have accurately described the media reports referenced in paragraph 55. Defendants lack knowledge
6

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or information sufficient to form a belief about truth of the facts presented in the media reports relied upon in paragraph 55.
56. Defendants admit that, based on current conditions and information, certain voters might be at higher risk for severe illness from COVID-19. Defendants admit that Plaintiffs have accurately described the media report referenced at footnote 45 of Plaintiffs’ Complaint. Defendants lack knowledge or information sufficient to form a belief about truth of the facts presented in the media report relied upon in paragraph 56.
57. Defendants admit the allegations in paragraph 57. 58. Defendants admit the allegations in paragraph 58. 59. Defendants admit the allegations in paragraph 59. Virginia’s Absentee Voting Process and Witness Requirement 60. Defendants admit the allegations in paragraph 60. 61. Defendants admit the allegations in paragraph 61. 62. Defendants admit the allegations in paragraph 62. 63. Defendants admit the allegations in paragraph 63. 64. Defendants admit the allegations in paragraph 64, with respect to non-military voters. Defendants deny the allegations in paragraph 64 to the extent that they apply to military voters whose ballots are received after the close of polls under Va. Code § 24.2-709(B). 65. Defendants admit the allegations in paragraph 65 regarding the absentee ballot application process. Defendants deny that the absentee ballot application process is described at Virginia Code § 24.2-701(B)(1). 66. Defendants admit the allegations in paragraph 66. 67. Defendants admit the allegations in paragraph 67.
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68. Defendants admit the allegations in paragraph 68. 69. Defendants admit the allegations in paragraph 69. 70. Defendants admit the allegations in paragraph 70. 71. Defendants admit the allegations in paragraph 71. 72. Defendants admit the allegations in paragraph 72. Virginia’s witness requirement will deny large numbers of Virginians the right to vote vet (sic) provides only marginal benefits for election integrity 73. Defendants admit the allegations in paragraph 73. 74. Governor Northam’s Executive Orders No. 53 and 55 speak for themselves, and Defendants deny any allegations in paragraph 74 that are inconsistent with those orders. 75. Defendants admit that any individual of any age or race, including those without preexisting conditions, is susceptible to COVID-19 and that person to person contact increases the risk of transmission of the virus. Defendants lack knowledge or information sufficient to form a belief about the truth of the remaining allegations in paragraph 75. 76. Defendants admit that enforcement of the witness requirement for the June 23 primary elections will likely prevent thousands of eligible Virginians from casting ballots. Defendants lack knowledge or information sufficient to form a belief about the truth of the remaining allegations in paragraph 76. 77. Defendants admit the allegations in the first three sentences in paragraph 77. Defendants lack knowledge or information sufficient to form a belief about the truth of the remaining allegations in paragraph 77. 78. With respect to the first sentence of paragraph 78, Defendants deny any allegations that are inconsistent with the data from the 2018 Current Population Survey.
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Defendants lack knowledge or information sufficient to form a belief about the truth of the remaining allegations in paragraph 78.
79. Defendants admit that any individual of any age or race, including those without preexisting conditions, is susceptible to COVID-19 and that person to person contact increases the risk of transmission of the virus. Defendants deny any remaining allegations in paragraph 79.
80. Defendants lack knowledge or information sufficient to form a belief about the trust of the remaining allegations in paragraph 80.
81. Defendants admit that certain voters might be at higher risk for severe illness from COVID-19. With respect to the conclusions drawn from statements of the Centers for Disease Control and Prevention, the statements speak for themselves. Defendants deny any remaining allegations in paragraph 81.
82. Defendants admit that certain voters might be at higher risk for severe illness from COVID-19. With respect to the conclusions drawn from media reports, the reports speak for themselves. Defendants deny any remaining allegations in paragraph 82.
83. With respect to the June 23 primary elections, Defendants admit that voters at higher risk for severe illness from COVID-19 may believe that they are unable to fulfill the witness requirement of the absentee ballot because they deem the risk of contact with a third party is too high and, that, accordingly, these voters may decide to not cast a ballot. Defendants deny the allegations in paragraph 83 with respect to any elections but the June 23 primary elections.
84. Defendants admit that only as a result of the current pandemic and only for the June 23 primary elections, the burden placed on voters at higher risk of contracting COVID-19
9

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who live alone outweighs the enforcement of the witness requirement. Defendants admit that Virginia has a history of voter discrimination with respect to African Americans and that discrimination in other areas of the economy may persist. Defendants deny the remaining allegations in paragraph 84.
85. Defendants admit that only as a result of the current pandemic and only for the June 23 primary elections, the burden placed on voters at higher risk of contracting COVID-19 who live alone outweighs the enforcement of the witness requirement. Defendants deny any remaining allegations in paragraph 85.
86. Defendants admit the allegations in the first sentence of paragraph 86. With respect to the conclusions drawn from the chart cited in footnote 57 of Plaintiffs’ Complaint, the chart speaks for itself. Defendants deny any remaining allegations in paragraph 86.
87. Defendants admit the allegations in paragraph 87. 88. Defendants admit the allegations in paragraph 88. 89. Defendants admit the allegations in paragraph 89. 90. Defendants admit the allegations in paragraph 90. 91. Defendants admit the allegations in paragraph 91. 92. Defendants admit the allegations in paragraph 92. 93. Defendants admit that with respect to the June 23 primary elections, the burden that high risk voters living alone believe would be placed on them by abiding by the witness requirement outweighs the utility inherent in the witness requirement in light of other measures present to ensure election integrity. Defendants also admit that Virginia law does not require witnesses to identify themselves by printing their name or providing any other information and
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Board regulations instruct election officials to accept ballots even where the witness signature is illegible. Defendants deny any remaining allegations in paragraph 93.
94. Defendants admit that only as a result of the current pandemic and only for the June 23 primary elections, the burden placed on voters at higher risk of contracting COVID-19 who live alone outweighs the enforcement of the witness requirement. Defendants deny any remaining allegations in paragraph 94.
CLAIMS FOR RELIEF COUNT I
Violation of the Fundamental Right to Vote 42 U.S.C. § 1983, First and Fourteenth Amendments to the U.S. Constitution
95. Defendants deny any allegations in paragraph 95 that are inconsistent with the cited authority.
96. Defendants admit that only as a result of the current pandemic and only for the June 23 primary elections, the burden placed on voters at higher risk of contracting COVID-19 who live alone outweighs the enforcement of the witness requirement. Defendants deny any remaining allegations in paragraph 96.
97. Defendants admit that only as a result of the current pandemic and only for the June 23 primary elections, the burden placed on voters at higher risk of contracting COVID-19 who live alone outweighs the enforcement of the witness requirement. Defendants deny any remaining allegations in paragraph 97.
98. Defendants deny the allegations in paragraph 98. COUNT II
Violations of Section 2 of the Voting Rights Act, 52 U.S.C. § 10301
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99. Defendants deny any allegations in paragraph 99 that are inconsistent with the cited authority.
100. Defendants deny any allegations in paragraph 100 that are inconsistent with the cited authority.
101. Defendants admit that only as a result of the current pandemic and only for the June 23 primary elections, the burden placed on voters at higher risk of contracting COVID-19 who live alone outweighs the enforcement of the witness requirement. Defendants deny any remaining allegations in paragraph 101.
102. Defendants admit that only as a result of the current pandemic and only for the June 23 primary elections, the burden placed on voters at higher risk of contracting COVID-19 who live alone outweighs the enforcement of the witness requirement. Defendants admit that Virginia has a history of voter discrimination with respect to African Americans and that discrimination in other areas of the economy may persist. Defendants deny the remaining allegations in paragraph 102.
103. Defendants admit that only as a result of the current pandemic and only for the June 23 primary elections, the burden placed on voters at higher risk of contracting COVID-19 who live alone, regardless of race, outweighs the enforcement of the witness requirement. Defendants deny any remaining allegations in paragraph 103.
104. Defendants deny that Plaintiffs are entitled to any of the relief requested in the WHEREFORE clause following paragraph 103, except with respect to the relief accorded pursuant to the Consent Decree entered by the Court on May 5, 2020.
105. Defendant has not knowingly or intentionally waived any applicable defenses, and it reserves the right to assert and rely upon other applicable defenses that may become
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available or apparent during discovery in this matter. Defendant reserves the right to amend or seek to amend its answer and/or affirmative defenses.
MARK R. HERRING Attorney General of Virginia /s/ Heather Hays Lockerman MICHELLE S. KALLEN (VSB #93286) CAROL L. LEWIS (VSB #92362) HEATHER HAYS LOCKERMAN (VSB #65535) Office of the Attorney General 202 North Ninth Street Richmond, Virginia 23219 804-692-0558 (telephone) 804-692-1647 (facsimile) clewis@oag.state.va.us Attorneys for Robert H. Brink, John O’Bannon, Jamilah D. LeCruise and Christopher E. Piper in their official capacities, and the Virginia State Board of Elections
13

Case 6:20-cv-00024-NKM Document 72 Filed 05/11/20 Page 14 of 14 Pageid#: 1642 CERTIFICATE OF SERVICE
Pursuant to Local Rule 7(g)(3), I hereby certify that on May 11, 2020, I will file this document electronically through the Court’s CM/ECF system, which will effect service on all counsel who have appeared.
/s/ Heather Hays Lockerman Heather Hays Lockerman Counsel for Defendants, for Robert H. Brink, John O’Bannon, Jamilah D. LeCruise and Christopher E. Piper in their official capacities, and the Virginia State Board of Elections
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 </s> Case 6:20-cv-00024-NKM Document 64 Filed 05/01/20 Page 1 of 13 Pageid#: 1498

UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA
Lynchburg Division

LEAGUE OF WOMEN VOTERS OF

VIRGINIA, et al.,

)

)

Plaintiffs,

)

)

v.

)

)

VIRGINIA STATE BOARD OF ELECTIONS, )

et al.,

)

)

Defendants.

)

Case No. 6:20-cv-00024

REPLY IN SUPPORT OF JOINT MOTION FOR ENRY OF PARTIAL CONSENT JUDGMENT AND DECREE

Intervenor Republican Party of Virginia (RPV) seeks to politicize defendants’ effort to ensure that all eligible absentee voters, regardless of political party, have a safe and fair opportunity to vote in Virginia’s upcoming June primary.
In an effort to obtain certainty and turn their focus to the upcoming elections, defendants—election officials tasked with conducting Virginia’s elections—negotiated and agreed to the terms of the proposed consent decree. The agreement would resolve the most urgent aspect of this case well before the June primary with sufficient time to implement any change. In the election officials’ judgment, the proposed consent decree is narrowly crafted to maintain election integrity while, at the same time, ensuring that all qualified voters in Virginia—Republicans, Democrats and Independents alike—need not jeopardize their health to vote.

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I. The Republican Party of Virginia misrepresents the terms of the proposal RPV’s objections misrepresent the parties’ proposal in three key respects. First,
defendants have not simply capitulated to the terms of the plaintiffs’ preliminary injunction. Second, the proposal says nothing of the constitutionality of the witness requirement. And third, the proposal imposes no obligations on RPV.
1. RPV asserts that defendants “simply agreed to enjoin [the witness requirement] for the June 23, 2020 Primary Election.” RPV Opposition to Motion for Partial Consent Judgment, ECF 58 (RPV Opp.) 10; see RPV Opp. 18 (representing the proposal as “striking down a bedrock, 70-year-old Virginia statute”). That is not what the proposal does.
The proposed consent decree would suspend enforcement of the witness requirement for a limited group of voters (those who may not safely have a witness present while completing their ballot) and for a single election (Virginia’s June 23 primary). Proposed Partial Consent Judgment and Decree, ECF 35-1 (proposal or consent decree). The proposal is thus significantly narrower than the relief plaintiffs sought in their motion for a preliminary injunction, which asked this Court to enjoin defendants from enforcing the witness requirement as to (i) “all Virginia voters for the June 23 primaries,” and (ii) “for any and all subsequent elections in Virginia until such time as in-person interactions required by compliance with the witness requirement no longer pose a risk to public health and personal safety.” Mot. for Prelim. Inj., ECF 16 at 2 (emphases added). The terms of the proposal are narrower both in scope and time than the relief plaintiffs originally sought.
2. RPV claims that “[i]n joining Plaintiffs in proposing the Partial Consent Judgment and Decree, . . . Defendants conceded that they believe the statute they are charged with defending is unconstitutional as applied to the June 23 Primary.” Reply to Response to Motion to
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Intervene, ECF 54 (RPV Reply) at 9. That is also not true. The proposal says nothing about the
constitutionality of §§ 24.2-706 or 24.2-707. Nor is the Court required to find an underlying
violation of law to approve the proposed consent decree.
a. RPV argues the consent decree should also be denied “because it asks this Court
to exercise federal judicial power to enjoin a state statute without a finding that the statute
violates federal law.” RPV Opp. 15. RPV cites no case—and defendants are aware of none—
setting forth the broad rule that a court must make an independent finding of unconstitutionality
before accepting a proposed consent decree. Indeed, the main case on which RPV itself relies
specifically states that “[i]f a court accepts a decree, it need not decide the merits.” Kasper v. Bd.
of Election Comm’rs of the City of Chicago, 814 F.2d 332, 338 (7th Cir. 1987) (emphasis added).1 The fact that no such finding is required makes sense because, otherwise, consent
decrees would be indistinguishable from final judgments. See generally Local No. 93, Int’l Ass’n
of Firefighters, AFL-CIO C.L.C. v. City of Cleveland, 478 U.S. 501, 519 (1986) (consent decrees
1 The other decisions on which RPV relies, RPV Opp. 15–17, likewise do not stand for the broad proposition that the Court’s role in evaluating a proposed consent decree is to assess the underlying merits of the case. Instead, these decisions stand for the well-established proposition that a court must determine whether or not the proposed consent decree is itself illegal. League of United Latin Am. Citizens, Council No. 4434 v. Clements, 999 F.2d 831, 846 (5th Cir. 1993) (in considering a consent decree, a court should “examine [the consent decree] carefully to ascertain not only that it is a fair settlement but also that it does not put the court’s sanction on and power behind a decree that violates Constitution, statute, or jurisprudence”) (quoting United States v. City of Miami, Fla., 664 F.2d 435, 441 (5th Cir. 1981) (Rubin, J.)); PG Pub. Co. v. Aichele, 705 F.3d 91, 117 (3d Cir. 2013) (“the District Court did not err in refusing to enter a consent decree that would violate a valid state law”) (emphasis added); League of Residential Neighborhood Advocates v. City of Los Angeles, 498 F.3d 1052, 1055–56 (9th Cir. 2007) (agreement was “invalid and unenforceable under state law” because consent decree itself violated municipality’s zoning law); League of Women Voters of Michigan v. Benson, No. 2:17CV-14148, 2019 WL 8106156, at *2 (E.D. Mich. Feb. 1, 2019) (relying heavily on Lawyer v. Department of Justice, 521 U.S. 567, 579 (1997), where the United States Supreme Court affirmed a “[t]he district court’s approv[al of a] consent decree over the objection of an individual plaintiff who argued that the district court could not enact a remedial district plan without first explicitly finding that the current district was unconstitutional.”).
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“have attributes both of contracts and of judicial decrees, a dual character that has resulted in different treatment for different purposes”) (internal quotation marks and citation omitted). And if a defendant must both confess liability and obtain an independent judicial finding of illegality before a court may accept a proposed consent decree, few defendants would ever agree to enter into such arrangements.
b. RPV itself recently asked a court to exercise judicial power to enjoin a state election statute in light of COVID-19. In Seventh Congressional District Republican Committee, et al. v. Virginia Department of Elections, RPV asked a state trial court to extend relief to all of its congressional district committees that selected a non-primary method of nomination because “in the current emergency situation, none of the committees” could meet the June 9 deadline under Va. Code § 24.2-510 for the RPV’s nominees to appear on the November 3, 2020 ballot.2 Seventh Cong. District Republican Committee, et al. v. Virginia Dep’t of Elections, et al. – Plaintiff-Intervenor’s Unopposed Motion to Extend Temporary Injunction, attached as Exhibit A. In another case, a potential Republican candidate for the United States Senate recently sought relief from state law, explaining that “[b]ecause of the current health crisis in Virginia, particularly because COVID-19 is a communicable disease, Mr. Faulkner and his campaign are unlikely to be able to obtain the necessary signatures [to qualify as a candidate on the June 23 primary ballot under Va. Code 24.2-521(1)].” Omari Faulkner for Virginia, et al. v. Virginia Dep’t of Elections, et al. – Verified Complaint, attached as Exhibit B, at ¶ 33. Faulkner asked the court to enjoin the election officials from enforcing that provision in full against United States Senate candidates for the June primary. RPV was named as a defendant in Faulkner and raised
2 RPV also sought to extend the relief at issue modifying the method for nominating congressional candidates in June by entering into an Unopposed Motion to Extend Temporary Injunction with both original parties to that suit.
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no objection to judicial modification of that statutory requirement relating to how a person could qualify to appear on the June 23 primary ballot as a United States Senate candidate. RPV argues today, contrary to its silent acquiescence to Court modification of a statute just a month ago in Faulkner, that election officials in Virginia should be powerless to respond to the pandemic without legislative action.
3 RPV objects that the proposed consent decree would “impose obligations or duties on RPV.” RPV Opp. 7. That is simply wrong. The proposed consent decree does not require RPV to do, or refrain from doing, anything.
Although RPV begins with the Supreme Court’s statement that “a court may not enter a consent decree that imposes obligations on a party that did not consent to the decree,” Local No. 93, Int’l Ass’n of Firefighters, AFL-CIO C.L.C. v. City of Cleveland, 478 U.S. 501, 529 (1986) (emphasis added), it then shifts to summarily assert that “where the proposed consent decree would alter the rights of the objecting party, the court should not approve the decree,” RPV Opp. 7–8 (emphasis added). In any event, no infringement on RPV’s “rights” justifies rejecting the consent decree.
First, RPV claims it “has both a statutory and constitutionally protected interest in the conduct of its own primary.” RPV Opp. 9.3 Defendants do not dispute that, under current Virginia law, political parties have a significant interest in the method by which their candidates are nominated for office because Virginia law gives political parties the right to determine the
3 Despite asserting that the consent decree violates its constitutional interests, RPV fails to identify any constitutional interest at stake and sets forth no argument as to constitutional interests impacted by the parties’ proposal. Any argument that the consent decree violates RPV’s constitutional rights is thus waived.
5

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method of nomination.4 But when a party chooses, that primary is run by and paid for by the
Commonwealth and its localities and the political party is constrained to follow the processes set forth by the State.5 See Declaration of Christopher E. Piper, attached as Exhibit C, at ¶ 9
(describing the local and State Board of Elections’ process); Va. Code Ann. § 24.2-103(A)
(mandating “uniformity” in elections).
Second, RPV claims that the consent decree “would force the RPV to undertake a
different primary election process than the one prescribed by statute[.]” RPV Opp. 9. That is not
true. Section 24.2-509 does not give RPV a statutory entitlement to a particular primary
“process” and it certainly does not entitle RPV to the witness requirement. By statute, RPV may
select the “method” of nomination, and the proposed consent decree would have no impact on
RPV’s ability to do so. The consent decree has no impact on the “method” of the primary. It
would not switch RPV’s selection under § 24.2-509 from a primary to one of the other
“methods” of nomination; that is, the selection does not impact the manner in which the
primaries are conducted, such as by requiring RPV district committees to switch their chosen
method of nomination from primary to convention or party canvass.
4 Va. Code Ann. § 24.2-509 (“Party to determine method of nominating its candidates for office”); Va. Code Ann. § 24.2-508 (in delineating the powers of political parties “[e]ach political party shall have the power to . . . provide for the nomination of its candidates, including the nomination of its candidates for office in case of any vacancy”); 6th Cong. Dist. Republican Comm. v. Alcorn, 913 F.3d 393, 398 (4th Cir. 2019) (noting that RPV “allows for four different methods of nomination: a primary, a party canvass, a convention, and a mass meeting”).
5 See, e.g., Va. Code Ann. §§ 24.2-700 (establishing the criteria for eligibility to vote absentee – regardless of the type of election); 24.2-525 (in addition to meeting her party’s requirements, a party nominee must also meet all requirements and qualifications imposed by the Commonwealth on all candidates); 24.2-529 (“The primary ballots for the several parties taking part in a primary shall be composed, arranged, printed, delivered, and provided in the same manner as the general election ballots except that at the top of each official primary ballot shall be printed in plain black type the name of the political party and the words ‘Primary Election.’”); 24.2-532 (designating electoral boards as the entity who determines which primary candidate “received the highest number of voters for nomination to any such office”).
6

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Third, RPV suggests that, because of the consent decree, it would be forced to “accept a risk of fraudulent or otherwise unauthorized voting in that primary.” RPV Opp. 9. RPV’s suggestion relies on the flawed premise that permitting a subset of absentee voters—those who cannot safely obtain a witness—to vote without a witness would increase fraud. There is simply no evidence that the terms of the consent decree will lead to fraud.
a. Just yesterday, a federal district court in Nevada rejected a similar “vote dilution” fraud argument to the one RPV advances here. See RPV Opp. 10 (“The vote-dilution risk posed by eliminating a key election integrity measure is one of the interests RPV seeks to vindicate.”). In Paher v. Cegavske, a group of voters (represented by the same counsel as amici prospective voters in this case) challenged Nevada’s implementation of an all-mail election in response to the COVID-19 pandemic. No. 3:20-cv-243, (D. Nev. Apr. 30, 2020), ECF 57. Like RPV here, those voters insisted that the alleged elimination of voter fraud protections, will result in voter fraud. Id. at 13–14. The court firmly rejected those claims, finding that claim of “voter fraud is without any factual basis.” Id. at 12. The court reasoned that the voters’ “overarching theory that having widespread mail-in votes makes the Nevada election more susceptible to voter fraud seems unlikely where [Nevada’s] Plan essentially maintains the material safeguards to preserve election integrity.” Id. at 13–14. Likewise here, the consent decree maintains Virginia’s material safeguard to preserve election integrity.
b. A plethora of other Virginia laws protect against fraud in absentee voting. Voter malfeasance can trigger harsh criminal penalties. See Va. Code § 24.2- 1004(B) (“Any person who intentionally (i) votes more than once in the same election . . . is guilty of a Class 6 felony.”) (emphasis added); § 24.2-1016 (“Any willfully false material statement or entry made by any person in any statement, form, or report required by this title shall constitute the crime of election
7

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fraud and be punishable as a Class 5 felony.”) (emphasis added); § 24.2-1012 (“Any person who knowingly aids or abets or attempts to aid or abet a violation of the absentee voting procedures . . . shall be guilty of a Class 5 felony” and “[a]ny person attempting to vote by fraudulently signing the name of a qualified voter shall be guilty of forgery and shall be guilty of a Class 4 felony.”) (emphases added). Voters are required to provide identifying information, § 24.2-706, and absentee ballots include a signed attestation confirming identity, eligibility, and absence of double-voting, id. Absentee ballots also include a check of the ballot against the list of ballot requests. § 24.2-710.
There is no reason to believe that, for the subset of voters at issue in the proposed consent decree (those who may not safely meet the witness requirement) in a single election (the June primary), these measures will fail to deter fraud. II. Defendants have reasonably concluded the proposal balances the interests at issue in
this case RPV has previously emphasized the deference that should be accorded to government officials during a public health crisis. Brief in Opposition to Motion for Preliminary Injunction, ECF 44 (RPV PI Opp.) 1–2. Virginia’s election officials considered the pandemic’s evolution in the Commonwealth and deemed it necessary to enter into the consent decree. This recommendation is consistent with the state of the pandemic in the Commonwealth. See Executive Order 55;6 see also Declaration of M. Norman Oliver, MD, MA, Virginia Health Commissioner, attached as Exhibit D (Oliver Decl.), at ¶¶ 16, 22; Declaration of Bryan Lewis, Research Associate Professor, University of Virginia, attached as Exhibit E (Lewis Decl.), at ¶¶ 8–10.
6 Executive Order 55 is available at https://www.governor.virginia.gov/media/governorvirginiagov/executive-actions/EO-55Temporary-Stay-at-Home-Order-Due-to-Novel-Coronavirus-(COVID-19).pdf.
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RPV now asks this Court to disregard that decision and rely instead, on RPV’s unsubstantiated and non-Virginia specific information about the pandemic. RPV PI Opp. 10–11. But the burdens of weighing the strengths of Fox News (see RPV PI Opp. 11) or CNN articles (see Brief in Opposition to Motion for Preliminary Injunction (Amici PI Opp.), ECF 37 at n.2) should not be placed on the Court when the government officials tasked with responding to the COVID-19 pandemic do exactly that. See Oliver Decl. ¶¶ 15–16 (describing measures taken in response to the pandemic); Lewis Decl. ¶¶ 6–10 (same).
1. RPV emphasizes the importance of deference to the legislature, RPV Opp. 17, but it looks to one statute only (the witness requirement) and ignores the remainder of the Virginia Code.
The Virginia General Assembly clearly did not contemplate a once-in-a-century global pandemic when crafting § 24.2-707(1).7 The legislature did, however, recognize the need to defer to executive officials in an emergency. See Va. Code Ann. §§ 44-146.14(a), -146.16 (granting executive branch authority to act during emergencies for purpose of “protect[ing] the public peace, health, and safety, and . . . preserv[ing] the lives and property and economic wellbeing of the people of the Commonwealth,” especially during a “[d]isaster,” which includes a “communicable disease of public health threat”); § 32.1-2 (declaring that “the protection, improvement and preservation of the public health and of the environment are essential to the general welfare of the citizens of the Commonwealth” and directing the State Board of Health

7 Any suggestion that the legislature had a global pandemic in mind when it amended this

statute is misplaced. HB1 (which relates to no-excuse absentee voting), for example, was prefiled

on November 18 of last year. It had to go through committee hearings and pass both Houses and

was considered and approved by the Governor in addition to thousands of other bills. See

Virginia’s

Legislative

Information

System,

https://lis.virginia.gov/cgi-

bin/legp604.exe?201+sum+HB1. To presume that the legislature could have predicted that the

witness requirement would endanger voter health for the June primary is to presume that the

legislature can predict all potential future events: it is simply not reasonable.

9

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and the State Health Commissioner, assisted by the State Department of Health, to develop a comprehensive public health program). The legislature’s decision to delegate emergency management to the executive branch makes sense because emergencies, including the current pandemic, present unanticipated threats to the lives of the people and necessitate urgent and changeable responses. See generally People ex rel. Barmore v. Robertson, 134 N.E. 815, 819 (Ill. 1922) (“Legislatures cannot anticipate all the contagious and infectious diseases that may break out in a community.”).
As election officials housed in the executive branch, defendants (with advice of some of the Nation’s leading epidemiologists, doctors, and economists), carefully weighed the benefits of preserving the witness requirement against the health risks to the Commonwealth caused by the current emergency and made the decision to provide clarity for this one election in a circumscribed form. RPV claims that “COVID-19 is not yet well understood”8 and “[p]olicymakers are taking short, deliberate steps as they develop and refine their public-health strategies.” RPV PI Opp. 3. One of these steps is the decision to resolve the most immediate aspect of this case on the terms set forth in the proposed consent judgment.
2. RPV summarily asserts that “Defendants are aligned with Plaintiffs” and faults defendants for entering into the consent decree quickly. RPV Opp. 13–15. In a typical case, the speed of agreement may fairly raise judicial concern. But this case involves an upcoming election and time is of the essence. An inference of collusion simply does not make sense where
8 Although much may still be learned about COVID-19, it is unquestionably true that the risks for the community gets worse as more people become ill. Intervenor suggest “the lack of a witness signature requirement will likely cause some voters who would have voted in person in order to avoid the minor inconvenience of finding a witness to vote by absentee ballot.” RPV Reply at 4. To the extent that factual assertion is true, and to the extent that voters for whom it is unsafe to meet the witness requirement nevertheless interact with people to fulfill that requirement, the risk extends far beyond those voters because the nature of infection is such that as these people become infected, they infect others. See Oliver Decl. ¶¶ 5–6.
10

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there is an obvious, good-faith explanation for why agreement was reached quickly.9 Likewise, defendants have not “capitulated.” RPV Opp. 10. The proposed consent decree does not resolve the entire case. Defendants sought resolution only of the most pressing portion of the litigation: the upcoming June election.
* * * RPV sets forth two alternatives to the relief set forth in the consent decree: use of social security numbers and Virginia’s E-Notary Law. See RPV Opp. 18–20; RPV PI Opp. 2, 34. Defendants are not opposed to exploring other options to resolve this dispute, so long as all eligible voters have a fair opportunity to vote safely and securely10 and the current dispute is resolved quickly. As Amici-Prospective Voters recognized, “election officials” should be allowed “to focus on conducting the election, not defending suits like this.” Amici PI Opp. at 1.
CONCLUSION No Virginian should be placed in the tenuous position of having to choose between their health and their right to vote during this pandemic. The proposed consent decree reflects an appropriate balance between the interest in election integrity and the health and safety of the people of the Commonwealth. The proposed consent decree should be approved.
9 Similarly, that “RPV sees no evidence that Defendants have defended the relevant statute” or that the record contain no “evidence that Defendant even considered employing any such alternative methods of verification,” RPV Opp. 10, 13, reflects only that the case was recently filed and that defendants need certainty as to how the election will proceed.
10 The E-Notary option may not be accessible to voters in the Commonwealth who do not have access to broadband. Declaration of Evan Feinman, attached as Exhibit F, at ¶ 6 (“we now know that there are hundreds of thousands of Virginians without residential access to broadband, and that many thousands of Virginians lack residential access to cellular service sufficient to engage in simultaneous video exchanges”).
11

Case 6:20-cv-00024-NKM Document 64 Filed 05/01/20 Page 12 of 13 Pageid#: 1509
Respectfully Submitted, MARK R. HERRING Attorney General of Virginia /s/ Michelle S. Kallen MICHELLE S. KALLEN (VSB #93286) CAROL L. LEWIS (VSB #92362) HEATHER HAYS LOCKERMAN (VSB #65535) Office of the Attorney General 202 North Ninth Street Richmond, Virginia 23219 804-692-0558 (telephone) 804-692-1647 (facsimile) clewis@oag.state.va.us Attorneys for Robert H. Brink, John O’Bannon, Jamilah D. LeCruise and Christopher E. Piper in their official capacities, and the Virginia State Board of Elections
12

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CERTIFICATE OF SERVICE Pursuant to Local Rule 7(g)(3), I hereby certify that on May 1, 2020, I will file this document electronically through the Court’s CM/ECF system, which will effect service on all counsel who have appeared.
/s/ Michelle S. Kallen Michelle S. Kallen Counsel for Defendants, for Robert H. Brink, John O’Bannon, Jamilah D. LeCruise and Christopher E. Piper in their official capacities, and the Virginia State Board of Elections

Uploaded: 20C2a0AsPeR620:2106:-5c5vF-i0le0d 0By2:B4a-rN# K65M703 CDMoAcRuSmTOeNntRe6f4er-e1nce:FEilFe-6d520152/01/20 Page 1 of 3 Pageid#: 1575
E-Filed: 2020APR20 RICHMOND CITY CC JCRIGGER at 2020APR21 08:42 CL20001640-00

VIRGINIA: IN THE CIRCUIT COURT FOR THE CITY OF RICHMOND

SEVENTH CONGRESSIONAL DISTRICT REPUBLICAN COMMITTEE, et al.,
Plaintiffs,
v.
VIRGINIA DEPARTMENT OF ELECTIONS, et al.,
Defendants.

Civil Action No. CL20001640-00

PLAINTIFF-INTERVENOR’S UNOPPOSED MOTION TO EXTEND TEMPORARY INJUNCTION
The Republican Party of Virginia, Inc. (“Plaintiff-Intervenor” or “RPV”), by counsel, respectfully files this motion to extend the temporary injunction issued by the Court to apply to all of its Congressional District Committees that have selected a non-primary method of nomination pursuant to §24.2-509 of the Code of Virginia.
On April 14, 2020, the Court enjoined Defendants from enforcing the provisions of §24.2-510 against Plaintiffs until 7:00 p.m., Tuesday, July 28, 2020. Ct.’s Order Granting Temporary Inj. p. 7. The Court’s findings of fact in that order as they relate to the Plan of Organization of the Republican Party of Virginia, Inc. (“Party Plan”), the actions of the Governor, and the mandates of the Code of Virginia apply equally to the situation of the five other committees that have made plans to nominate by convention. Only the specific details of those other committees’ meeting dates and preparations for a convention differ and not in any material way (e.g., each Committee made its nominating method decision at a properly called

Case 6:20-cv-00024-NKM Document 64-1 Filed 05/01/20 Page 2 of 3 Pageid#: 1576
meeting, adopted a call for convention at another such meeting, and posted its call to the RPV website; three other committees had scheduled conventions for May 30, while two also planned conventions for April 23).
The Court’s findings of law and application of law to the facts should apply equally to each of the other committees, having turned primarily on the application of the same statute and executive actions to a committee operating under the same resulting constraints. Specifically, each of the committees must meet the June 9 deadline set by §24.2-510 in order for the Party’s nominees to appear on the November 3, 2020 ballot and, in the current emergency situation, none of the committees can do so.
Counsel for Plaintiffs and Defendants have confirmed that their clients do not oppose this motion and an endorsed Consent Order is attached as Exhibit A.
For the foregoing reasons, RPV respectfully requests that the Court grant its motion to extend its temporary injunction to all of its Congressional District Committees that have selected a non-primary method of nomination.
Respectfully submitted, REPUBLICAN PARTY OF VIRGINIA, INC.

Dated: April 20, 2020

Christopher M. Marston (VSB # 65703) 2652 Group, LLC PO Box 26141 Alexandria VA 22313 (571) 482-7690 chris@2652group.com Counsel for Petitioner

Case 6:20-cv-00024-NKM Document 64-1 Filed 05/01/20 Page 3 of 3 Pageid#: 1577
CERTIFICATE OF SERVICE I hereby certify that a true copy of the foregoing was electronically mailed on the 20th day of April, 2020, to the following: Heather Hays Lockerman (VSB # 65535) Senior Assistant Attorney General & Section Chief hlockerman@oag.state.va.us Carol L. Lewis (VSB # 92362) Assistant Attorney General Office of the Attorney General 202 North Ninth Street Richmond VA 23219 804-692-0558 clewis@oag.state.va.us Counsel for Defendants Graven W. Craig (VSB # 41367) CraigWilliams, PLC PO Box 68 – 202 W Main St Louisa VA 23093 540-967-9900 graven@callnow.law Counsel for Plaintiffs
____________________________________ Counsel

Case 6:20-cv-00024-NKM Document 64-2 Filed 05/01/20 Page 1 of 21 Pageid#: 1514

V I R G I N I A :

IN THE CIRCUIT COURT FOR THE CITY OF RICHMOND

OMARI FAULKNER FOR VIRGINIA,

)

)

-and-

)

)

OMARI FAULKNER

)

)

Plaintiffs,

)

)

v.

)

)

)

VIRGINIA DEPARTMENT OF ELECTIONS )

)

-and-

)

)

VIRGINIA STATE BOARD OF ELECTIONS )

ROBERT H. BRINK, Chairman of

)

The State Board of Elections, in his

)

official capacity, JOHN O’BANNON,

)

Vice-Chairman of the State Board of Elections, )

in his official capacity,

)

JAMILAH D. LECRUISE,

)

Secretary of the State Board of Elections,

)

In her official capacity,

)

CHRISTOPHER E. "CHRIS" PIPER,

)

Commissioner Of the State Board of Elections, )

in his official capacity

)

JESSICA BOWMAN, Deputy Commissioner )

Of the State Board of Elections, in her

)

official capacity.

)

)

- and -

)

)

THE REPUBLICAN PARTY OF VIRGINIA )

)

-and-

)

)

Chairman Jack R. Wilson, in his capacity

)

As Chairman of the Republican Party of

)

Virginia

)

)

Defendants.

)

Civil Action No.:

1

Case 6:20-cv-00024-NKM Document 64-2 Filed 05/01/20 Page 2 of 21 Pageid#: 1515
VERIFIED COMPLAINT Plaintiffs, Omari Faulkner and his United States Senate campaign committee, Omari Faulkner For Virginia, a political committee registered with the Federal Election Commission, by counsel and pursuant to the First and Fourteenth Amendments to the United States Constitution, 42 U.S.C. § 1983, Section 8.01-620 of the Code of Virginia (the “Code”), and Rule 3:2 of the Rules of Supreme Court of Virginia, state the following verified complaint for declaratory judgment and permanent, preliminary, and emergency injunctive relief against the Virginia Department of Elections, the Virginia State Board of Elections, its Chairman, Vice-Chairman, Secretary, Commissioner, and Deputy Commissioner, the Republican Party of Virginia, and Chairman of the Republican Party of Virginia, Jack R. Wilson, in his official capacity, (together, “Defendants”) to restrain defendants, in this election only, from enforcing in full the candidate signature requirement for U.S. Senate candidates codified at Va. Code § 24.2-521(1).
PARTIES 1. Plaintiff Omari Faulkner resides in Bluemont, Virginia and is a member of the United States Navy Reserve. Mr. Faulkner is also a candidate for the Republican nomination for U.S. Senate. Mr. Faulkner filed his Statement of Candidacy with the Federal Election Commission on November 11, 2019. (Ex. A, Statement of Candidacy). 2. Plaintiff Omari Faulkner For Virginia is the official candidate committee for Mr. Faulkner’s bid for United States Senate. The campaign committee filed its Statement of Organization with the Federal Election Commission on November 11, 2019 and has the campaign ID number as C00726570. (Ex. B, Statement of Organization).
2

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3. Defendant State Board of Elections, through the Virginia Department of Elections oversees “voter registration, absentee voting, ballot access for candidates, campaign finance disclosure and voting equipment certification in coordination with Virginia’s 133 local election offices.”1 See also Va. Code § 24.2-103(A) (vesting the State Board of Elections, through the Department of Elections, with supervisory authority to obtain uniformity in election laws).
4. The State Board has the duty to receive both Declarations of Candidacy from candidates for United States Senate, as well as a Petition containing at least 10,000 signatures statewide, with at least 400 signatures from each congressional district. Va. Code §§ 24.2-522(C) 24.2-521(1). The State Board is then required to “transmit the material so filed to the state chairman of the party of the candidate.” Va. Code § 24.2522.
5. The State Board of Elections also has the duty to prescribe various forms for the registration of voters and the conduct of elections. See Va. Code § 24.2-105. The State Board of Elections has prescribed Form SBE 506/521, the form that contains the signatures of voters to get a candidate’s name on the ballot.
6. Defendant Robert H. Brink is the Chairman of the State Board of Elections. He is sued in his official capacity.
7. Defendant John O’Bannon is the Vice-Chairman of the State Board of Elections. He is sued in his official capacity.
1 See Department of Elections, About the Agency available at https://www.virginia.gov/agencies/department-of-elections/ (last visited March 19, 2020) (emphasis added).
3

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8. Defendant Jamilah D. LeCruise is the Secretary of the State Board of Elections. She is sued in her official capacity.
9. Defendant Christopher E. "Chris" Piper is the Commissioner of the State Board of Elections. He is sued in his official capacity.
10. Defendant Jessica Bowman is the Deputy Commissioner of the State Board of Elections. She is sued in her official capacity.
11. Defendant Republican Party of Virginia (“RPV”) is the State Party affiliate of the Republican National Committee.2
12. Defendant Jack Wilson is the Chairman of the Republican Party of Virginia and he is sued in that capacity only. As Chairman, Mr. Wilson is responsible for verifying the number of signatures and certifying to the State Board that the candidate had a sufficient number of signatures to obtain a position on the ballot. See Va. Code § 24.2-527(A).
JURISDICTION 13. This Court has jurisdiction over the subject matter of this Complaint pursuant to Sections 8.01-184 and 8.01-186 of the Code. This statute permits this Court to issue both declaratory judgments as well as grant injunctive relief to effectuate its declaratory judgment.
2 See, e.g., RPV Party Plan at 6, §A ¶ 5 (membership on the Republican Party of Virginia’s State Central Committee includes the two Virginia representatives to the Republican National Committee. See also id. at 7, §C ¶ 3 (stating that the Republican Party of Virginia’s State Central Committee has the authority to fill vacancies for Virginia’s National Committee representative in the event a vacancy occurs before the next Republican National Convention) available at https://virginia.gop/wpcontent/uploads/2020/01/Party-Plan-Amended-December-2019.pdf (last visited March 19, 2020).
4

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14. Venue is appropriate in the City of Richmond Circuit Court because several officers of the Commonwealth are sued in their official capacity and those officers have offices within the City of Richmond. Va. Code § 8.01-261(2).
FACTS 15. Mr. Faulkner began his bid for the Republican nomination to represent Virginia in the United States Senate back in November of 2019. 16. Within weeks, Omari Faulkner for Virginia, contracted with an individual to run the campaign’s signature gathering operation to obtain the necessary signatures pursuant to Va. Code § 24.2-521(1). 17. Beginning in approximately early January of 2020, the campaign committee assiduously and diligently began circulating petitions to obtain these signatures. These efforts were done so that Mr. Faulkner’s name would appear on the Virginia’s Republican Primary Ballot. 18. Just as the sun was rising on 2020 and heating the campaign trails, the menace that is COVID-19, also known as the Coronavirus, landed on the shores of the Commonwealth. Within the past week alone, there has been a steady and persistent cascade of emergency actions taken to combat COVID-19. 19. On March 11, 2020, the World Health Organization declared COVID-19 a global pandemic. (attached as Ex. H). 20. In response to the conflagration of cases and to combat COVID-19, on March 12, 2020 Governor Northam declared a State of Emergency. In his “Declaration Of A State Of Emergency Due To Novel Coronavirus (Covid-19)” (attached as Exhibit
5

Case 6:20-cv-00024-NKM Document 64-2 Filed 05/01/20 Page 6 of 21 Pageid#: 1519

C), Governor Northam declared that COVID-19 is public health threat because it is a

communicable disease. (Ex. C at 1).

21. The following day, President Trump declared a national emergency.

22. Three days later on Monday, March 16, 2020, Governor Northam issued a

directive stating that restaurants, fitness centers, and theatres either had to reduce capacity

to 10 people or close. (attached as Ex. E). Governor Northam also banned all events with

100 or more persons.

23. Later, on Monday March 16, 2020, the Supreme Court of Virginia

declared a judicial emergency. (attached as Ex. F). This order declared that a judicial

emergency exists from March 16 to Monday April 6, 2020. (Ex. F at 1). The order further

ordered that all non-emergency and non-essential court proceedings be suspended and

that all deadlines are tolled for 21 days. Ex. F. at 2.

24. Then, on March 17, President Trump declared that for a period of 15 days,

there should be no gatherings of 10 or more people.3

25. The White House in collaboration with the Center for Disease Control

published guidelines for how people should conduct themselves through these next 15

days. Included within these guidelines is the recommendation that in areas where

community spread of COVID-19 is present, “bars, restaurants, food courts, gyms, and

other indoor and outdoor venues where groups of people congregate should be closed.”

(attached as Ex. D). Additionally, people should avoid discretionary travel, including

shopping trips and social visits. Id.

3 See The President’s Coronavirus Guidelines for America: 15 Days To Slow The Spread

available

at

https://www.whitehouse.gov/wp-

content/uploads/2020/03/03.16.20_coronavirus-guidance_8.5x11_315PM.pdf (last visited

March 19, 2020).

6

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26. Finally, of specific importance, the Center for Disease Control has recommended that people maintain a safe social distance of at least six feet. (attached as Exhibit G). This is because contact with a person within six feet can cause transmission of COVID-19. Ex. G.
27. States have addressed COVID-19 and its impact on elections in various ways.
28. The State Defendants themselves have in fact started taking measures to limit human interaction in relation to the upcoming election. In recognizing the danger of coming into close contact with others, the Virginia Department of Elections “to protect [Voters’] health during COVID-19 outbreak” is strongly encouraging voters to vote absentee in the upcoming May elections. The Department is advising voters to choose reason "2A My disability or illness" for Absentee voting in the June 2020 elections due to COVID-19.”4
29. Seven states, Georgia, Louisiana, Alabama, Kentucky, Ohio, Maryland, and Connecticut, have all moved their election dates to later in the calendar. For example, Alabama’s primary runoff election was moved from March 31, 2020 to July 14, 2020.5 Additionally, Louisiana has moved their primary election from April 4, 2020 to June 20, 2020,6 while Georgia has moved its primary election from March 24, to May 19, 2020.7

4 See Va. Department of Elections, Absentee Voting available at

https://www.elections.virginia.gov/casting-a-ballot/absentee-voting/ last visited (March

19, 2020).

5 See Supplemental State of Emergency: Coronavirus COVID-19 available at

https://governor.alabama.gov/newsroom/2020/03/supplemental-state-of-emergency-

coronavirus-covid-19/ (last visited March 19, 2020).

6

See

Covid-19

And

Elections

Update

available

at

https://www.sos.la.gov/Pages/NewsAndEvents.aspx#faq258 (last visited March 16,

2020).

7

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Kentucky has moved its primary election from May 19 to June 23, 2020, 8 while Maryland moved its primary election from April 28, 2020 to June 2, 2020.9 Connecticut moved its election from April 28 to June 2, 2020.10 Finally, the Ohio Department of Health canceled its March 17, 2020 primary election.11
30. Then, prior to President Trump’s declaration of a national emergency, and before Governor Northam’s declaration of a state emergency, Governor Cuomo of New York took emergency action. On March 7, 2020, Governor Cuomo of New York issued Executive Order 202.2 which modified New York’s petition signature requirement. New York reduced the number of signatures a candidate is required to obtain by 70%. See Ex. I at 1. Furthermore, Governor Cuomo suspended all signature gathering activity on March 17, 2020. See id.
31. Despite the steady drumbeat of warnings to maintain a safe social distance by the Governor, the President, the State Board of Elections, and the CDC, Mr. Faulkner

7 See Secretary Of State Raffensperger Postpones The Presidential Preference Primary

available

at

https://sos.ga.gov/index.php/elections/secretary_of_state_raffensperger_postpones_the_p

residential_preference_primary (last visited March 16, 2020). 8 See Secretary Of State Moves To Delay May 19 Elections available at

https://kentucky.gov/Pages/Activity-stream.aspx?n=SOS&prId=300 (last visited March

19, 2020).

9 See Renewal Declaration of State Of Emergency and Existence of Catastrophic Health

Emergency –COVID-19, available at

https://governor.maryland.gov/wp-

content/uploads/2020/03/Renewal-of-State-of-Emergency.pdf (last visited March 19,

2020).

10 See Executive Order No. 7G available at https://portal.ct.gov/-/media/Office-of-the-

Governor/Executive-Orders/Lamont-Executive-Orders/Executive-Order-No-7G.pdf (last

visited March 19, 2020).

11 See In re: Closure of Poling Locations in the State of Ohio on Tuesday March 17, 2020

available

at

https://content.govdelivery.com/attachments/OHOOD/2020/03/17/file_attachments/1402

754/Director%27s%20Order%20Closure%20of%20the%20Polling%20Locations.pdf

(last visited March 19, 2020).

8

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has obtained 3,769 signatures statewide. Mr. Faulkner’s campaign has also obtained the following amounts of signatures in each congressional district:
a. CD 1: 242 b. CD 2: 319 c. CD 3: 690 d. CD 4: 109 e. CD 5: 262 f. CD 6: 391 g. CD 7: 374 h. CD 8: 201 i. CD 9: 168 j. CD 10: 747 k. CD 11: 267 32. Despite their diligence, Mr. Faulkner and his campaign are still 6,231 signatures shy of the statewide requirement and have at least 200 signatures in 9 congressional districts. 33. Because of the current health crisis in Virginia, particularly because COVID-19 is a communicable disease, Mr. Faulkner and his campaign are unlikely to be able to obtain the necessary signatures prior to the deadline absent relief sought in this lawsuit. 34. At best, continued attempts to obtain signatures is challenging, and at worst is in direct conflict with directives from everyone in the public health community,
9

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which only risks making a very serious situation worse and specifically exposes campaign staff to additional dangers.
35. Mr. Faulkner and his campaign must submit the requisite signatures by Thursday, March 26, 2020. Va. Code § 24.2-522(A). This is because Virginia’s primary is scheduled for June 9, 2020 and the statute requires candidates to file their declaration of candidacies and petition signatures 75 days prior to the election. Va. Code § 24.2522(A).12
36. When the State Board receives Mr. Faulkner’s petition papers, the State Board is then required to “transmit the material so filed to the state chairman of the party of the candidate” within 72 hours of receipt. Va. Code § 24.2-522. In this case, the State Board must transmit this material to Jack Wilson, chairman of the Republican Party of Virginia.
37. Only the State Chairman is permitted to open the sealed containers containing the signed petitions. Va. Code § 24.2-522.
38. Then, the State Chairman of the Republican Party of Virginia must certify to the State Board that the Party reviewed the petitions and found that the requisite number of petitions was satisfied. Va. Code § 24.2-527. The State Chairman must provide the State Board with this certification by March 31, 2020, or seventy days before June 9, 2020. Va. Code § 24.2-527.
39. Mr. Faulkner would have been able to satisfy the signature requirement but for the unanticipated and unprecedented pandemic of COVID-19.
12 See Upcoming Elections, Virginia Department of Elections available at https://www.elections.virginia.gov/casting-a-ballot/calendars-schedules/upcomingelections.html (last visited March 19, 2020).
10

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40. Absent an injunction, Mr. Faulkner’s name will not appear on the ballot. This will violate his constitutional right to free speech and free association.
41. Defendants at all times are acting under the color of state law. U.S. CONSTITUTIONAL LAW
42. The First Amendment declares in no uncertain terms that Congress shall make no law abridging the freedom of speech. U.S. Const. amend. I. See also Citizens United v. FEC, 558 U.S. 310, 336 (2010). This restriction against governmental power is applied to the states through the Fourteenth Amendment. Reed v. Town of Gilbert, 135 S. Ct. 2218, 2226 (2015).
43. “It is beyond debate that freedom to engage in association for the advancement of beliefs and ideas is an inseparable aspect of the ‘liberty’ assured by the Due Process Clause of the Fourteenth Amendment, which embraces freedom of speech.” NAACP v. Alabama, 357 U.S. 449, 460 (1958).
44. The Supreme Court has made clear, “whether the beliefs sought to be advanced by association pertain to political, economic, religious or cultural matters … state action which may have the effect of curtailing the freedom to associate is subject to the closest scrutiny” Id. at 460-61.
45. The right to “voluntary political association … is an important aspect of the First Amendment freedom” that the Supreme Court “has consistently found entitled to constitutional protection.” Lefkowitz v. Cunningham, 431 U.S. 801, 808 (1977).
46. A person’s ability to exercise their rights guaranteed under the First Amendment is “[u]ndeniably enhanced by group association.” Buckley v. Valeo 424 U.S. 1, 15 (1976) (quoting NAACP v. Alabama, 357 U.S. at 460).
11

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47. Both the First and the Fourteenth Amendments therefore, guarantee the “freedom to associate with others for the common advancement of political beliefs and ideas...” Id.; see also Anderson v. Celebrezze, 460 U.S. 780, 787 (1983) (“[T]he right of individuals to associate for the advancement of political beliefs . . . rank[s] among our most precious freedoms.”).
48. Further, because the freedom of association enhances the effectiveness of the freedom of speech, the government cannot limit or dictate who an association chooses to associate with for the common advancement of the association’s beliefs. Tashjian v. Republican Party, 479 U.S. 208, 224 (1986) (emphasis added).
49. Although states are entrusted with administering their elections and imposing reasonable restrictions “in exercising their powers of supervision over elections … the States may not infringe upon basic constitutional protections.” Kusper v. Pontikes, 414 U.S. 51, 57 (1973).
50. “[Ballot] Access restrictions also implicate the right to vote because, absent recourse to referendums, voters can assert their preferences only through candidates or parties or both.” Illinois State Board of Elections v. Socialist Workers Party, 440 U.S. 173, 184 (1979).
51. In constitutional analysis, the primary concern of courts is “with the tendency of ballot access restrictions to limit the field of candidates from which voters might choose.” Anderson v. Celebrezze, 460 U.S. 780, 786 (1983).
52. “By limiting the choices available to voters, the State impairs the voters' ability to express their political preferences.” Illinois State Board of Elections v. Socialist Workers Party, 440 U.S. 173, 184 (1979).
12

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VIRGINIA LAW 53. Under Virginia law, Mr. Faulkner and his campaign are required to obtain 10,000 signatures statewide. Included within that 10,000 signatures is a requirement to obtain 400 signatures within each congressional district. Va. Code § 24.2-521(1). 54. Mr. Faulkner and his campaign are required to submit these signatures to the State Board of Elections on March 26, 2020. Va. Code § 24.2-522(A). 55. Then, within 72 hours of receipt, the State Board is required to “transmit the material so filed to the state chairman of the party of the candidate” who is Jack Wilson of the RPV. Va. Code § 24.2-522. 56. Only the State Chairman, Mr. Wilson, is permitted to open the sealed containers containing the signed petitions. Va. Code § 24.2-522. 57. Then, by March 31, 2020, the State Chairman of the Republican Party of Virginia must certify to the State Board that the Party reviewed the petitions and found that the requisite number of petitions was satisfied. Va. Code § 24.2-527.
CLAIMS COUNT I Violation of The First Amendment’s Free Speech And Association Clauses 1983 Action 58. Plaintiffs incorporate by reference paragraphs 1-57 as if fully restated herein. 59. It is impracticable for Mr. Faulkner and his campaign to complete their task of obtaining 10,000 signatures statewide and 400 signatures in each of Virginia’s eleven congressional districts given recent events. Given the impracticability of Mr.
13

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Faulkner and his campaign to obtain signatures since the declaration of a State emergency, Mr. Faulkner seeks redress.
60. “No right is more precious in a free country than that of having a voice in the election of those who make the laws under which, as good citizens, we must live. Other rights, even the most basic, are illusory if the right to vote is undermined.” Wesberry v. Sanders, 376 U.S. 1, 17, 84 S. Ct. 526, 11 L. Ed. 2d 481 (1964).
61. Ballot restrictions that severely burden the right to vote and associate violate the First Amendment to the U.S. Constitution. See Storer v. Brown, 415 U.S. 724, 728-29 (1974).
62. Accordingly, “[p]recision of regulation must be the touchstone in an area so closely touching our most precious freedoms. If the State has open to it a less drastic way of satisfying its legitimate interests, it may not choose a legislative scheme that broadly stifles the exercise of fundamental personal liberties.” Kusper v. Pontikes, 414 U.S. 51, 59 (1973) (internal quotation marks and citations omitted).
63. Therefore, in recognizing that States must enact election codes for orderly, fair, and honest elections, courts reviewing challenges to ballot access cases impose a flexible standard. Burdick v. Takushi, 504 U.S. 428, 433-34 (1992). If the election regulation imposes a severe burden, then the regulation must survive strict scrutiny. Id. at 434. By contrast, if the election regulation imposes a light burden, rational basis or intermediate scrutiny applies. Id.
64. Under the current conditions created by COVID-19, including a declared state of emergency in our Commonwealth as well as a declared National emergency, Virginia’s signature requirement imposes a severe burden on Plaintiffs.
14

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65. This burden is compounded because of the various government recommendations that individuals maintain at least six feet distance between them.
66. Virginia does not have a compelling justification to require Plaintiffs to continue circulating large numbers of petitions between now and March 26 when there are guidelines from the U.S. Government, Virginia government, and the Center for Disease Control recommending people to maintain a safe distance of six fee or more.
67. Furthermore, Virginia cannot claim a compelling justification when Virginia, recognizing the danger imposed by the communicable disease COVID-19, is encouraging voters to cast absentee ballots rather than go to the polls and vote. The fact that State Defendants are encouraging voters to vote absentee and not travel to the polls insinuates that it is contrary to the health of Virginians to come into close contact with others. Virginia cannot say that for the health of voters, do not vote in person but still demand that Plaintiffs still send volunteers out to neighborhoods and business and collect signatures in person.
68. In analogous situations, courts have extended voter registration deadlines in light of natural disasters, like hurricanes. See Fla. Democratic Party v. Scott, 215 F. Supp. 3d 1250 (N.D. Fla. 2016). In that court’s analysis of the burden, the court noted that in the final week before voter registration closed, an estimated 100,000 people were expected to register. Id. at 1257. But because of Hurricane Matthew, these potential voters were forced to flee the State. Id. Thus, these potential voters could not vote because they were unregistered. Id. Florida’s voter registration statute imposed a severe burden that it could not justify. Id.
15

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69. Because the inability to register to vote meant these 100,000 people could not vote, the court ruled that was a severe burden. Id.
70. Florida could not justify its severe burden because, similar to here, several other states impacted by Hurricane Matthew either extended their voter registration deadlines or permitted voter registration on Election Day. Id. Accordingly, under the flexible approach explained in Burdick, the court ruled that under any standard, Florida could not justify its decision not to extend voter registration in light of Hurricane Matthew. Id. at 1257-58; see also Ga. Coalition for the Peoples' Agenda, Inc. v. Deal, 214 F. Supp. 3d 1344 (S.D. Ga. 2016) (ordering an extension of voter registration deadline due to Hurricane Matthew because the loss of the right to vote would be an irreparable harm and when balanced to administrative burden of extending registration deadline, the harm to voting rights outweighed the administrative burden).
71. Accordingly, Virginia does not have a compelling or even sufficiently important interest to justify maintaining its 10,000-signature requirement and 400signature per congressional district requirement in light of the current public health emergency.
72. Absent an injunction, Mr. Faulkner will not appear on the ballot, a severe burden to his First Amendment rights. See Fla. Democratic Party, 215 F. Supp. 3d at 1257.
73. Additionally, because Mr. Faulkner and his campaign have obtained 3,769 signatures, he has demonstrated a sufficient modicum of support in the context of this election. See Bowe v. Board of Election Comm'rs, 614 F.2d 1147, 1152 (7th Cir. 1980) (“The ultimate question was said to be whether in the context of California politics, a
16

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reasonably diligent candidate could be expected to be able to meet the requirements and gain a place on the ballot.”) (citing Storer, 415 U.S. at 742). Given the global pandemic that has seized our Commonwealth and our Nation, Mr. Faulkner and his campaign have demonstrated a modicum of support to merit a place on the ballot.
74. At all times, State Defendants were acting under the color of state law. PRAYER FOR RELIEF
A. Declare Va. Code § 24.2-521(1) unconstitutional as applied to Senate candidates in this particular pending election.
B. Enjoin all Defendants from enforcing Va. Code § 24.2-521(1) in full against United States Senate candidates in this primary election.
C. Order that, to obtain a position on the partisan primary election ballot for U.S. Senate, candidates for the U.S. Senate must obtain 3,500 signatures statewide and 100 signatures in each of Virginia’s eleven congressional districts.
D. DEMAND FOR ATTORNEYS’ FEES: Pursuant to Rule 3:25 of the Rules of the Supreme Court of Virginia, Plaintiffs seek reasonable attorneys’ fees pursuant to 42 U.S.C. § 1988.
E. Award all other relief that this Court deems just and necessary. Respectfully submitted, March 23, 2020
Jason Torchinsky (VA Bar# 47481) Jonathan P. Lienhard (VA Bar# 41648) Shawn Sheehy (VA Bar# 82630)
17

Case 6:20-cv-00024-NKM Document 64-2 Filed 05/01/20 Page 18 of 21 Pageid#: 1531 Holtzman Vogel Josefiak Torchinsky 45 N. Hill Drive Suite 100 Warrenton, VA 20186 (W) 540-341-8808 (F) 540-341-8809 jtorchinsky@hvjt.law jlienhard@hvjt.law ssheehy@hvjt.law Counsel to Plaintiffs
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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a copy of the foregoing was this 23rd day of March

2020 served, by email and FedEx, postage pre-paid, upon the following:

Carol Lewis & Heather Hays Lockerman Assistant Attorneys General 202 North 9th Street Richmond, VA 23219 (804) 692-0558 CLewis@oag.state.va.us HLockerman@oag.state.va.us

Chris Marston 110 Shooters Ct. Alexandria, VA 22314 (571) 482-7690 chris@electioncfo.com

On behalf of:

Counsel to:

VIRGINIA DEPARTMENT OF

THE REPUBLICAN PARTY OF

ELECTIONS

VIRGINIA )

)

-and-

-and-

)

)

VIRGINIA STATE BOARD OF

Chairman Jack R. Wilson, in his capacity

)

ELECTIONS

As Chairman of the Republican Party of

)

ROBERT H. BRINK, Chairman of

Virginia.

The State Board of Elections, in his

official capacity, JOHN O’BANNON,

Vice-Chairman of the State Board of

Elections,

in his official capacity,

JAMILAH D. LECRUISE,

Secretary of the State Board of Elections,

In her official capacity,

CHRISTOPHER E. "CHRIS" PIPER,

Commissioner Of the State Board of

Elections, in his official capacity

JESSICA BOWMAN, Deputy

Commissioner

Of the State Board of Elections, in her

official capacity.

By: Jason B. Torchinsky
21

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Lewis Declaration Exhibit

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Case 6:20-cv-00024-NKM Document 64-6 Filed 05/01/20 Page 1 of 2 Pageid#: 1573

UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA
Lynchburg Division

LEAGUE OF WOMEN VOTERS OF

VIRGINIA, et al.,

)

)

Plaintiffs,

)

)

v.

)

)

VIRGINIA STATE BOARD OF ELECTIONS, )

et al.,

)

)

Defendants.

)

Case No. 6:20-cv-00024

DECLARATION OF EVAN FEINMAN

1. I am over the age of 18, competent to offer testimony, and have personal

knowledge of the facts in this Declaration.

2. I have served as the Governor’s Chief Broadband Advisor since July of 2018.

3. In this position I developed a plan to realize Governor Northam’s goal of

universal broadband coverage prior to 2028, and oversee the inter-agency efforts to implement

that plan.

4. The Commonwealth’s Broadband Effort, “Commonwealth Connect” is an inter-

agency team consisting of staff from the Governor’s office, the Center for Innovative

Technology, the Department of Housing and Community Development, and the Tobacco Region

Revitalization Commission, with ad-hoc assistance from many additional executive agencies.

The Commonwealth Connect team partners with Virginia’s communities, utilities, and

telecommunications providers to develop local and regional universal coverage plans, and to

direct appropriated funds in support of those plans.

1

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5. In order to fulfill the mission to extend broadband service to unserved areas, we researched both the flaws in the current federal reporting requirements and worked with federal, state, local, and provider data to determine good estimates for the nature and extent of broadband coverage as well as estimates of the numbers of citizens without access.
6. As a result of this work, we now know that there are hundreds of thousands of Virginians without residential access to broadband, and that many thousands of Virginians lack residential access to cellular service sufficient to engage in simultaneous video exchanges, such as FaceTime, Google Chat, to name a few.
7. Many of the unserved communities in which we work also contain a disproportionally high concentration of low-income Virginians. Many of these Virginian do not own, and lack the resources to own, the devices and subscriptions necessary to engage in video chatting even if their home could receive service.
Pursuant to 28 USC § 1746, I declare under penalty of perjury that the foregoing is true and correct.

Executed on: April 30, 2020

Evan Feinman Office of Governor Northam

2

 </s> Case 6:20-cv-00024-NKM Document 28 Filed 04/24/20 Page 1 of 3 Pageid#: 318

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA
LYNCHBURG DIVISION

LEAGUE OF WOMEN VOTERS OF VIRGINIA, et al.,
Plaintiffs,
v.
VIRGINIA STATE BOARD OF ELECTIONS, et al.,
Defendants.

Case No.: 6:20-cv-00024-NKM
MOTION TO INTERVENE OF THE REPUBLICAN PARTY OF VIRGINIA, VICKI BURNS, VINCE FALTER, MILDRED H. SCOTT, AND THOMAS TURNER

NOW COMES the Republican Party of Virginia, Inc. (“RPV”), MG Vincent E. Falter, USA (ret), Mildred H. Scott, and Thomas N. Turner, Jr. (collectively, “Applicants”), by counsel, and respectfully move this Court to intervene in this case pursuant to Rules 24(a)(2) and 24(b) of the Federal Rules of Civil Procedure. This motion is accompanied by a Memorandum of Points and Authorities that explains why Applicants are entitled to intervene in this case of right and are also entitled to permissive intervention. Applicants respectfully request that the Court grant intervention.
Applicants’ counsel contacted counsel for the parties seeking their consent on this motion. Counsel for Plaintiffs and Defendants both indicated their opposition to Applicants’ intervention.

Case 6:20-cv-00024-NKM Document 28 Filed 04/24/20 Page 2 of 3 Pageid#: 319

In conformance with Federal Rule of Civil Procedure 24(c), a proposed

Answer is attached as Exhibit A to this motion, and a proposed order is attached as

Exhibit B.

Dated:

April 24, 2020

Respectfully submitted,

/s/ Christopher M. Marston Christopher M. Marston (VSB No. 65703) chris@2562group.com 2652 GROUP LLC P.O. Box 26141 Alexandria, VA 22313-6141 571.482.6790 / Fax 703.997.2549
Trevor M. Stanley (VSB No. 77351) E. Mark Braden (pro hac vice pending) Katherine L. McKnight (adm. pending) Richard Raile (VSB No. 84340) BAKER & HOSTETLER LLP Washington Square, Suite 1100 1050 Connecticut Avenue, N.W. Washington, DC 20036-5403 202.861.1500 / Fax 202.861.1783 tstanley@bakerlaw.com mbraden@bakerlaw.com kmcknight@bakerlaw.com rraile@bakerlaw.com
Patrick T. Lewis (pro hac vice pending) BAKER & HOSTETLER LLP 127 Public Square, Suite 2000 Cleveland, OH 44114-1214 216.621.0200 / Fax 216.696.0740 plewis@bakerlaw.com
Counsel for Proposed Intervenors

2

Case 6:20-cv-00024-NKM Document 28 Filed 04/24/20 Page 3 of 3 Pageid#: 320 CERTIFICATE OF SERVICE
I certify that on April 24, 2020, the foregoing was filed on the Court’s electronic case filing system. Notice of the filing was generated by the Court’s electronic system. Copies of the filing are available on that system.
/s/ Christopher M. Marston Christopher M. Marston (VSB No. 65703)
3

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Exhibit A

Case 6:20-cv-00024-NKM Document 28-1 Filed 04/24/20 Page 2 of 15 Pageid#: 322

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA
LYNCHBURG DIVISION

LEAGUE OF WOMEN VOTERS OF VIRGINIA, et al.,
Plaintiffs,
v.
VIRGINIA STATE BOARD OF ELECTIONS, et al.,
Defendants.

Case No.: 6:20-cv-00024-NKM
[PROPOSED] ANSWER OF INTERVENOR-DEFENDANTS REPUBLICAN PARTY OF VIRGINIA, INC., VINCENT E. FALTER, MILDRED H. SCOTT, AND THOMAS N. TURNER, JR.

Proposed Intervenors, Republican Party of Virginia, Inc., MG Vincent E. Falter USA (ret.), Mildred H. Scott, and Thomas N. Turner, Jr., by counsel, submit the following Answer to Plaintiffs’ Complaint (Doc. 1).
1. To the extent this paragraph states factual allegations; Intervenors lack knowledge or information sufficient to form a basis as to the truth of these allegations. To the extent this paragraph states a legal conclusion, no response is required.
2. This paragraph is a legal conclusion to which no response is required. 3. Intervenors admit to the factual allegations in the first two sentences. Intervenors note in response to the third sentence that Governor Northam’s order provides that it “will remain in place until June 10, 2020, unless amended or rescinded.”1 Intervenors further note that the Richmond Times Dispatch attributed to Governor Northam’s spokeswoman Alena Yarmosky

1 Va. Executive Order No. 2020-55, https://www.governor.virginia.gov/media/governorvirginiagov/executiveactions/ EO-55-Temporary-Stay-at-Home-Order-Due-to-Novel-Coronavirus-(COVID-19).pdf

Case 6:20-cv-00024-NKM Document 28-1 Filed 04/24/20 Page 3 of 15 Pageid#: 323
a statement that “the order doesn’t apply to ‘the operation of government,’ which she said includes operating in and participating in elections.”2
4. This paragraph is a legal conclusion to which no response is required. 5. The 2018 Current Population Survey speaks for itself, the remainder of this paragraph consists of legal conclusions to which no response is required. 6. This paragraph is a legal conclusion to which no response is required. 7. Intervenors admit to the statistical allegations in the first sentence. Intervenors deny other factual allegations. 8. Most of this paragraph is a legal conclusion to which no response is required. Intervenors admit that Virginia is one of only 11 states that require an individual submitting an absentee ballot to have a witness sign their ballot envelope, but notes that because absentee voting presents a higher risk of fraud than in-person voting, states impose a number of different integrity measures. Some states require a copy of the voter’s ID be returned with the absentee ballot,3 or require both a copy of the voter’s ID and notary or witness signature on the returned absentee ballot.4 Some states require proof of identification at the absentee ballot application phase,5 some use signature matching to verify absentee ballot applications and/or returned
2 Mel Leonor, Northam administration urges Virginians to vote absentee by mail; GOP questions timing of ‘stat-at-home’ order, Richmond Times Dispatch, Mar. 31, 2020, https://www.richmond.com/news/virginia/northam-administration-urges-virginians-to-voteabsentee-by-mail-gop-questions-timing-of-stay-at/article_a2db7528-2afa-5d5a-b018826c97f984fb.html. 3 See ARK. CODE ANN. §7-5-409(b)(4)(A)(v) (2018). 4 See ALA. CODE § §17-9-30(b), 17-11-7 (2019). 5 WISC. STAT. §6.87 (2019) (unless specifically exempted, absentee ballot applicant must include proof of identification with the application), S.D. CODIFIED LAWS §12-19-2(2019) (requiring an absentee ballot application be accompanied by either a copy of the applicant’s ID or a notarized oath), KAN. STAT. ANN. §25-1122(b),(c) (2018) (requiring that a person applying in person for an absentee ballot show a valid ID, and that an absentee ballot application returned by mail include
2

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absentee ballot,6 and some have implemented various other rules designed to ensure electoral integrity in the absentee voting process.7
9. Intervenors deny that Plaintiffs are entitled to the relief requested in this paragraph.
PARTIES 10. Intervenors lack knowledge or information sufficient to form a basis as to the truth of these allegations. 11. Intervenors lack knowledge or information sufficient to form a basis as to the truth of these allegations. 12. Intervenors lack knowledge or information sufficient to form a basis as to the truth of these allegations. 13. Intervenors lack knowledge or information sufficient to form a basis as to the truth of these allegations.
either a valid Kansas driver’s license number or a copy one of the specified alternative forms of identification). 6 See TENN. CODE ANN. §2-6-202(g) (2018) (Upon receipt by mail of the absentee ballot, the administrator shall open only the outer envelope and compare the voter's signature on the application with the voter's signature on the appropriate registration record.), MICH. COMP. LAWS §168.761 (2019) (The qualified voter file must be used to determine the genuineness of a signature on an application for an absent voter ballot.); see also TEX. ELEC. CODE ANN. §87.027 (2019) (providing for the use of a signature verification committee), KY. REV. STAT. ANN. §117.085(6) (2019) (requiring that the absentee ballot return envelope be signed by two witnesses if the voter signs the envelope with a mark instead of a signature). 7 See, e.g., OKLA. STAT. TIT. 26, §14-108.1 (2019) (absentee ballot return envelopes must include an affidavit which the voter must sign and which must be witnessed by a notary, notary publics must maintain a log of all absentee ballot application for a single election for two years, and may not notarize more than 20 absentee ballot affidavits without the written approval of the secretary of the county election board).
3

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14. Intervenors lack knowledge or information sufficient to form a basis as to the truth of these allegations.
15. Intervenors lack knowledge or information sufficient to form a basis as to the truth of these allegations.
16. Admitted. 17. Intervenors lack knowledge or information sufficient to form a basis as to the truth of these allegations. 18. Intervenors lack knowledge or information sufficient to form a basis as to the truth of these allegations. 19. Admitted. 20. Admitted. 21. Admitted. 22. Admitted. 23. Admitted.
JURISDICTION AND VENUE 24. Intervenors admit that Plaintiff purports to bring this action under 42 U.S.C. §§ 1983 and 1988 and 52 U.S.C. § 10302. 25. Admitted. 26. Admitted. 27. Admitted.
FACTS Transmission of COVID-19 and Public Health Guidelines
28. Admitted.
4

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29. Admitted. 30. Admitted. 31. Admitted. 32. Admitted. 33. Admitted. 34. Intervenors lack knowledge or information sufficient to form a basis as to the truth of these allegations. 35. Admitted. 36. Admitted. 37. The CDC’s recommendations, which include minimizing direct contact and reducing crowd size at polling stations, speak for themselves. The factual allegations in the second sentence are admitted. 38. The conclusory statement in the first sentence is denied as none of the other factual allegations claim that COVID-19 was contracted at a polling place. The remaining factual allegations are admitted. 39. To the extent this paragraph states a legal conclusion, no response is required. To the extent this paragraph states a factual allegation, Intervenors lack knowledge or information sufficient to form a basis as to the truth of these allegations. COVID-19 in Virginia 40. Intervenors admit that COVID-19 cases present a serious health issue in Virginia. Intervenors lack knowledge or information sufficient to form a basis as to the truth of these allegations.
5

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41. The contents of statements issued by the Virginia Department of Health speak for themselves.
42. Intervenors lack knowledge or information sufficient to form a basis as to the truth of these allegations.
43. The contents of the Governor’s statements speak for themselves. 44. The contents of the Governor’s statements speak for themselves. Intervenors admit that schools in Virginia are closed indefinitely. 45. The contents of the Governor’s statements speak for themselves. 46. The contents of the Governor’s statements speak for themselves. 47. The contents of the Governor’s statements speak for themselves. 48. Admitted. 49. Intervenors lack knowledge or information sufficient to form a basis as to the truth of these allegations. 50. Admitted. 51. The contents of statements issued by the Virginia Department of Elections speak for themselves. 52. The contents of the Governor’s statements speak for themselves. Intervenors admit that the election originally scheduled for June 9, 2020, is now set to take place on June 23, 2020. 53. This Court’s orders speak for themselves. COVID-19’s Impact on African American Virginians in Light of Ongoing and Historical Discrimination 54. Intervenors lack knowledge or information sufficient to form a basis as to the truth of these allegations.
6

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55. Intervenors lack knowledge or information sufficient to form a basis as to the truth of these allegations.
56. To the extent the paragraph states factual allegations, Intervenors lack knowledge or information sufficient to form a basis as to the truth of these allegations.
57. The contents of the Governor’s statement speak for themselves. To the extent this paragraph states factual allegations, Intervenors lack knowledge or information sufficient to form a basis as to the truth of these allegations.
58. To the extent the paragraph states factual allegations, Intervenors lack knowledge or information sufficient to form a basis as to the truth of these allegations.
59. To the extent this paragraph states factual allegations; Intervenors lack knowledge or information sufficient to form a basis as to the truth of these allegations. To the extent this paragraph states a legal conclusion, no response is required. Virginia’s Absentee Voting Process and Witness Requirement
60. The contents of Va. Code § 24.2-700 speak for themselves; the remainder of this paragraph are legal conclusion to which no response is required.
61. Admitted. 62. The contents of statements issued by the Department of Elections speak for themselves. 63. Admitted. 64. The contents of Va. Code §§ 24.2-701 and 24.2-709 speak for themselves. 65. The contents of Va. Code § 24.2-701 speak for themselves. 66. The contents of Va. Code § 24.2-706 speak for themselves. 67. The contents of Va. Code § 24.2-707 speak for themselves.
7

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68. The contents of Va. Code § 24.2-707 speak for themselves. 69. The contents of Va. Code § 24.2-711 speak for themselves. 70. The contents of 1 VA. Admin. Code 20-70-20(B) speak for themselves. 71. The contents of 1 VA. Admin. Code 20-70-20(B) speak for themselves; the remainder of this paragraph are legal conclusions to which no response is required. 72. The contents of Va. Code § 24.2-711.1 speak for themselves; the remainder of this paragraph are legal conclusions to which no response is required. Virginia’s witness requirement will deny large numbers of Virginians the right to vote yet provides only marginal benefits for election integrity 73. Admitted. 74. Intervenors deny that voters “have no safe means to have an individual witness and sign their ballot envelope.” Intervenors admit the other factual allegations in this paragraph. 75. Denied. 76. Intervenors lack knowledge or information sufficient to form a basis as to the truth of these allegations. 77. Intervenors admit to the statistics regarding registered voters and election turnout. Intervenors lack knowledge or information sufficient to form a basis as to the truth of the remainder of the allegations in this paragraph. 78. Intervenors deny that those who vote in person or find a witness for an absentee ballot necessarily risk their health as it is possible to do either while observing social distancing and other safeguards. The 2018 Current Population Survey speaks for itself. Intervenors deny that applying the Survey’s population percentage to the population of registered voters or the voters who wish to participate in either the primary or general election is a valid statistical approach.
8

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79. To the extent this paragraph states a legal conclusion, no response is required. To
the extent this paragraph states factual allegations; Intervenors lack knowledge or information
sufficient to form a basis as to the truth of these allegations.
80. Intervenors lack knowledge or information sufficient to form a basis as to the
truth of these allegations.
81. The contents of statements made by the CDC speak for themselves.
82. The first sentence of this paragraph consists of legal conclusions to which no
response is required. Reports issued by Maryland and North Carolina speak for themselves.
83. This paragraph consists of legal conclusions to which no response is required.
84. This paragraph consists of legal conclusions to which no response is required.
85. Intervenors admit that protecting election integrity and preventing improper use of
absentee ballots are valid government interests. Controls on the absentee ballot process are
among the most important safeguards for election integrity because of the broad, bipartisan and nonpartisan, consensus that the occurrence of vote fraud is highest among votes cast by mail.8
8 See, e.g., “Absentee ballots remain the largest source of potential voter fraud.” Building Confidence In U.S. Elections, Report of the Commission on Federal Election Reform (Sept. 2005), at 46, https://web.archive.org/web/20070609115256/http:/www.american.edu/ia/cfer/report/full_re port.pdf (accessed Apr. 22, 2020). “It is no surprise that in going back to the 1980s I couldn’t find a single example where an election was arguably stolen with [] impersonation fraud. In contrast, I could find examples just about every year somewhere in the country of absentee ballot fraud schemes used to try to swing (sometimes successfully) an election.” Rick Hasen, “Good Example of Why Large Scale Impersonation Voter Fraud is So Hard to Pull Off,” (Nov. 2, 2014), https://electionlawblog.org/?p=67807 (accessed Apr. 22, 2020). “[W]hen there has been significant voter fraud in recent U.S. elections, it has been through the absentee ballot process, not in-person voting…. No such problem has yet developed in the western states (Washington, Oregon, and Colorado) that now use VBM for all their elections, but we still ought to be concerned about the potential for fraud that VBM introduces.” Richard Pildes, “How Democrats Should Reform Elections in the States,” The American Prospect (Jan.
9

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Intervenors deny that maintaining the witness requirement during this pandemic fails to serve that interest. To the extent this paragraph states other legal conclusion, no response is required.
86. Denied. Virginia’s absentee ballot procedures work together to achieve the valid government interest in protecting election integrity. Likewise, other states have a combination of absentee ballot procedures, some similar to Virginia’s, others different, to vindicate their interest in protecting election integrity.
87. Intervenors admit that there are other safeguards that work in conjunction with the witness signature requirement to vindicate the government interest in protecting election integrity, and otherwise deny the allegations of Paragraph 87.
88. The contents of Va. Code § 24.2-710 speak for themselves, presenting one of the safeguards that work together to vindicate the government interest in protecting election integrity.
89. The contents of Va. Code § 24.2-706 speak for themselves, presenting one of the safeguards that work together to vindicate the government interest in protecting election integrity.
90. The contents of Va. Code § 24.2-1004 speak for themselves, presenting one of the safeguards that work together to vindicate the government interest in protecting election integrity.
22, 2020), https://prospect.org/power/democrats-reform-elections-states/ (accessed Apr. 23, 2020). It has been widely believed “that absentee voting is much more susceptible to illegal activity than voting in person at the polling place.” Sal H. Lee, Judicial Review of Absentee Voting Laws: How Courts Should Balance State Interests Against the Fundamental Right to Vote Going Forward, 105 IOWA L. REV. 799, 805 (2020) (citing William T. McCauley, Comment, Florida Absentee Voter Fraud: Fashioning an Appropriate Judicial Remedy, 54 U. MIAMI L. REV. 625, (2000)). (https://ilr.law.uiowa.edu/assets/Uploads/ILR-105-2-Lee.pdf)
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91. The contents of Va. Code § 24.2-1016 speak for themselves, presenting one of the safeguards that work together to vindicate the government interest in protecting election integrity.
92. The contents of Va. Code § 24.2-1012 speak for themselves, presenting one of the safeguards that work together to vindicate the government interest in protecting election integrity.
93. Denied. 94. This paragraph consists of legal conclusions to which no response is required.
CLAIMS FOR RELIEF COUNT I
95. This paragraph states a legal conclusion to which no response is required. 96. Denied. 97. Denied. 98. Denied.
COUNT II 99. Section 2 of the Voting Rights Act speaks for itself. 100. This paragraph consists of legal conclusions to which no response is required. 101. Denied. 102. Denied. 103. Denied.
ADDITIONAL DEFENSES 104. Plaintiffs have failed to state a claim upon which relief can be granted. 105. Plaintiffs lack standing to pursue some or all of their claims.
11

Case 6:20-cv-00024-NKM Document 28-1 Filed 04/24/20 Page 13 of 15 Pageid#: 333 106. Plaintiffs’ claims are barred, in whole or by part, by the doctrines of estoppel,
waiver, and/or laches. 107. Proposed Intervenors reserve the right to assert additional affirmative defenses
uncovered during the course of discovery and otherwise in this litigation. PRAYER FOR RELIEF
Proposed Intervenor-Defendants deny that Plaintiffs are entitled to their requested relief, and pray that this Court dismiss the Complaint with prejudice, at Plaintiffs’ cost, and grant to Proposed Intervenor-Defendants such other and further relief to which they are entitled at law or in equity.
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Dated: April 24, 2020

Respectfully submitted,
/s/ Christopher M. Marston Christopher M. Marston (VSB No. 65703) chris@2562group.com 2652 GROUP LLC P.O. Box 26141 Alexandria, VA 22313-6141 571.482.6790 / Fax 703.997.2549
Trevor M. Stanley (VSB No. 77351) E. Mark Braden (pro hac vice pending) Katherine L. McKnight (adm. pending) Richard Raile (VSB No. 84340) BAKER & HOSTETLER LLP Washington Square, Suite 1100 1050 Connecticut Avenue, N.W. Washington, DC 20036-5403 202.861.1500 / Fax 202.861.1783 tstanley@bakerlaw.com mbraden@bakerlaw.com kmcknight@bakerlaw.com rraile@bakerlaw.com
Patrick T. Lewis (pro hac vice pending) BAKER & HOSTETLER LLP 127 Public Square, Suite 2000 Cleveland, OH 44114-1214 216.621.0200 / Fax 216.696.0740 plewis@bakerlaw.com
Counsel for Proposed Intervenors

13

Case 6:20-cv-00024-NKM Document 28-1 Filed 04/24/20 Page 15 of 15 Pageid#: 335 CERTIFICATE OF SERVICE
I hereby certify that on April 24, 2020, I caused the foregoing to be filed with the United States District Court for the Western District of Virginia via the Court’s CM/ECF system, which will serve all registered users.
/s/ Christopher M. Marston Counsel for Proposed Intervenors
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Case 6:20-cv-00024-NKM Document 28-2 Filed 04/24/20 Page 1 of 3 Pageid#: 336
Exhibit B

Case 6:20-cv-00024-NKM Document 28-2 Filed 04/24/20 Page 2 of 3 Pageid#: 337

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA
LYNCHBURG DIVISION

LEAGUE OF WOMEN VOTERS OF VIRGINIA, et al.,
Plaintiffs,
v.
VIRGINIA STATE BOARD OF ELECTIONS, et al.,
Defendants.

Case No.: 6:20-cv-00024-NKM [PROPOSED] ORDER

Upon consideration of the Motion to Intervene filed by the Republican Party of Virginia (“RPV”), MG Vincent E. Falter, USA (ret), Mildred H. Scott, and Thomas N. Turner, Jr., (the “Motion”) filed herein, the Court having considered the Motion, the Memorandum of Points and Authorities in support thereof, any opposition thereto, and any oral argument thereon, and it appearing to the Court after due deliberation that the relief requested is appropriate and will facilitate efficient resolution of this case, it is by the Court this ____ day of ________, 2020,
ORDERED, that the Motion be, and it is hereby, granted; and it is further ORDERED, that the Republican Party of Virginia, MG Vincent E. Falter, USA (ret), Mildred H. Scott, and Thomas N. Turner, Jr., are each permitted to intervene as a defendant in the above-captioned proceeding as a matter of right; and it is further

Case 6:20-cv-00024-NKM Document 28-2 Filed 04/24/20 Page 3 of 3 Pageid#: 338 ORDERED, that the proposed Answer of the Intervenor-Defendants, which is
attached as Exhibit A to the Motion, is deemed filed as of the date of this Order. _______________________________ Honorable United States Judge
2

Case 6:20-cv-00024-NKM Document 29 Filed 04/24/20 Page 1 of 10 Pageid#: 339

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA
LYNCHBURG DIVISION

LEAGUE OF WOMEN VOTERS OF VIRGINIA, et al.,
Plaintiffs,
v.
VIRGINIA STATE BOARD OF ELECTIONS, et al.,
Defendants.

Case No.: 6:20-cv-00024-NKM
MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION TO INTERVENE

I. INTRODUCTION On April 17, the League of Women Voters of Virginia and four Virginia voters
brought this action for declaratory and injunctive relief against Virginia’s election officials in order to enjoin Va. Code. Ann. § 24.2-707(A) for the June 23, 2020, primary election and future elections. That statute requires that absentee ballots be marked in the presence of a witness and that the witness sign the sealed envelope containing the marked ballot. The relief sought by Plaintiffs goes too far, seeking to eliminate absentee voting protections designed to protect the integrity of Virginia elections for all voters.
The Republican Party of Virginia, Inc. (“RPV”), MG Vincent E. Falter, USA (ret), Mildred H. Scott, and Thomas N. Turner, Jr. (collectively, “Applicants”), respectfully move this Court to intervene in this case to vindicate their unique interest in the integrity of the Republican Primary Election initiated by RPV to nominate candidates, and in the integrity of the General Election in which those

Case 6:20-cv-00024-NKM Document 29 Filed 04/24/20 Page 2 of 10 Pageid#: 340
Republican candidates will compete. These interests are not adequately represented by existing parties to this case, and the relief Plaintiffs seek would materially impair that interest.
Finally, Applicants’ intervention will not disrupt these proceedings. Applicants are prepared to comply with the Court’s deadlines related to Plaintiffs’ pending Motion for Preliminary Injunction (Dkt. 16) and all future deadlines set by the Court. II. BACKGROUND OF APPLICANTS
Applicants each have strong and unique interests in this matter. The RPV is a major political party in Virginia and seeks to intervene on its own behalf, as well as on behalf of its candidates and party members. The power of a political party, such as RPV, to “provide for the nomination of its candidates…,” and “perform all other functions inherent in political party organizations” is recognized in statute. Va. Code Ann. § 24.2-508 (2019). In exercising those powers, RPV adopted a direct primary and timely notified the Virginia State Board of Elections (“Board”) of its choice pursuant to Va. Code § 24.2-516. The Board then ordered the holding of a Republican Primary for U.S. Senate and U.S. House of Representatives in the second and third congressional districts, now scheduled for June 23, 2020. The conduct of that Primary Election is a subject of this lawsuit.
Applicants Gen. Falter, Ms. Scott, and Mr. Turner are registered Virginia voters, members of the RPV, and intend to vote in the June 23, 2020 Republican Primary Election and in the 2020 General Election. Many have been voters for quite
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some time in the Commonwealth, and Ms. Scott served as an officer of election in Roanoke County for years.
Finally, Applicant Mr. Turner is also the chairman of the Young Republican Federation of Virginia and, in such capacity, spends considerable time organizing get-out-the-vote and other efforts to encourage young voters to vote and to support Republican candidates throughout the Commonwealth. III. LAW AND ARGUMENT
A. Applicants Are Entitled To Intervene As A Matter Of Right Under Rule 24(a)(2) of the Federal Rules of Civil Procedure, intervention as a matter of right is appropriate when, upon a “timely motion,” a party: claims an interest relating to the property or transaction that is the subject of the action, and is so situated that disposing of the action may as a practical matter impair or impede the movant’s ability to protect its interest, unless existing parties adequately represent that interest. Fed. R. Civ. P. 24(a)(2). The Fourth Circuit has interpreted the rule to require that an applicant timely “demonstrate: (1) that they have an interest in the subject matter of the action; (2) that the protection of this interest would be impaired because of the action; and (3) that the applicant’s interest is not adequately represented by existing parties to the litigation.” Teague v. Bakker, 931 F.2d 259, 260-61 (4th Cir. 1991). As outlined below, Applicants meet these requirements.
1. Applicants’ Request To Intervene Is Timely Applicants motion is certainly timely. “Where a case has not progressed beyond the initial pleading stage, a motion to intervene is timely.” United States v. Commonwealth of Virginia, 282 F.R.D. 403, 405 (E.D. Va. 2012) (citing Scardelletti
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Case 6:20-cv-00024-NKM Document 29 Filed 04/24/20 Page 4 of 10 Pageid#: 342
v. Debarr, 265 F.3d 195, 203 (4th Cir.2001)). The Complaint was filed on April 17, 2020, and Applicants filed this motion a mere 7 days later, and prior to April 28, the date on which the Plantiffs have requested the Defendants’ response to their motion for a preliminary injunction. (Pls.’ Mot. for Expedited Briefing at 1). Defendants have not yet responded to the complaint on file, a hearing is not yet scheduled, and no adjudication on the merits has taken place.
The passage of time is only one element of the timeliness inquiry. “The most important consideration is whether the delay has prejudiced the other parties.” Spring Constr. Co, Inc. v. Harris, 614 F.2d 374 (4th Cir. 1980). Applicants’ intervention is made without any delay and causes no prejudice to the existing parties. Should this court allow Applicants to intervene at this early stage, they will have an opportunity to assert their defenses and protect their interests without disrupting, delaying, or protracting the litigation. Applicants are prepared to meet the expedited briefing schedule requested by Plaintiffs. Therefore, this Motion is timely and will not cause delay or prejudice any of the existing parties.
2. Applicants Have An Interest In This Litigation That Is Not Adequately Represented By Existing Parties
Applicants each have vital interests in the subject matter of this litigation. Because those interests are not adequately represented by existing parties, they must be permitted to intervene to vindicate those interests.
First consider the RPV, which seeks to intervene both on its own behalf and in a representative capacity on behalf of its nominees, candidates, and members. As set forth above, the RPV elected to have a Primary Election to nominate candidates
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Case 6:20-cv-00024-NKM Document 29 Filed 04/24/20 Page 5 of 10 Pageid#: 343
for the U.S. House of Representatives (CD-2 and CD-3) and the U.S. Senate. That a political party has an interest in its own primary election is axiomatic. Clingman v. Beaver, 544 U.S. 581 (2005); Tashjian v. Republican Party of Connecticut, 479 U.S. 208 (1986); see also Democratic Party of the United States v. Wisconsin, 450 U.S. 107 (1981). And just as surely, RPV has a vital interest in the conduct of the 2020 General Election at which its nominated candidates will compete for office.
Additionally, RPV, particularly on behalf of its candidates, has a substantial interest in any change, such as one to absentee voting rules, to the “structure[e] of th[e] competitive environment” of an election. Shays v. F.E.C., 414 F.3d 76, 85 (D.C. Cir. 2005). If Plaintiffs’ relief is granted, RPV and its candidates will face “a broader range of competitive tactics than [state] law would otherwise allow.” Id. at 86. Eliminating the witness signature requirement would “fundamentally alter the environment in which [they] defend their concrete interests (e.g., […] winning reelection).” Id.; see also id. at 87 (holding that political candidates have a legally cognizable interest in preventing electoral “competition [becoming] intensified by [statutorily]-banned practices”). Because RPV’s candidates “actively seek [election or] reelection in contests governed by challenged rules,” they have an interest in “demand[ing] adherence” to those requirements. Id. at 88; see also Nader v. F.E.C., 725 F.3d 226, 228-9 (D.C. Cir. 2013).
Each of the Applicants also has a compelling interest in ensuring the integrity of the election(s) at issue in this litigation. Plaintiffs seek to enjoin a statute that serves to mitigate the risk of absentee ballot fraud. If unauthorized
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Case 6:20-cv-00024-NKM Document 29 Filed 04/24/20 Page 6 of 10 Pageid#: 344
ballots are cast due to fraud, they dilute the votes of legal voters, like the individual Applicants and other Republican voters the RPV represents here. Vote dilution is a violation of the fundamental right to vote. See Reynolds v. Sims, 377 U.S. 533, 554 (1964); Howell v. McAuliffe, 292 Va. 320, 335, 788 S.E.2d 706 (2016). RPV also seeks to vindicate this interest on behalf of its candidate and members.
These vital interests are not adequately represented by the existing parties to this action. Certainly they are not represented by Plaintiffs, who seek relief that Applicants oppose.
Nor are Applicants’ interests adequately represented by the Defendants. Ordinarily, “the burden on the applicant of demonstrating a lack of adequate representation ‘should be treated as minimal.’” Teague, 931 F.2d at 262 (citing Trbovich v. United Mine Workers, 404 U.S. 528, 538 n.10 (1972)). Applicants recognize that in the Fourth Circuit, intervenors must make a “strong showing” that government agency defendants will inadequately represent their interests. Stuart v. Huff, 706 F.3d 345, 352 (4th Cir. 2013). But central to Stuart’s holding was the proposed-intervenors’ concession that the government defendants in that case shared “the same ultimate objective as the existing defendants” and that they merely disagreed with “the Attorney General’s reasonable litigation tactics.” Id.
Applicants have a strong basis to believe their interests are not adequately represented. To begin, at this juncture it is not clear whether the Defendants will even defend the statute or will do so aggressively. And, if they chose not to, there would be no litigant before this Court to defend it.
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Further, Applicants and Defendants do not share the same ultimate objectives, and it is unreasonable to believe they would. The Defendants are obligated to serve “two distinct interests,” which the Fourth Circuit has recognized are grounds to permit intervention to a party who is only obligated to serve one such interest. United Guaranty Residential Ins. Co. v. Philadelphia Sav. Fund Soc’y, 819 F.2d 473, 475 (4th Cir. 1987). Specifically, the Defendants have a generalized interest in election-administration that may come into tension with a defense of the statute in question. Further, the Defendants also have an interest in advancing the Governor’s public health goals. It is exactly the conflict between these two goals that underly the Plaintiffs’ claim. While Applicants share great concern for the public health, meeting the Governor’s goals is not their ultimate objective. This conflict makes this case much more like Trbovich, in which the Secretary of Labor had to “serve two distinct interests,” and intervenor only served one. 404 U.S. at 538. In Stuart, the intervenors “concede[d] that they share[d] the same ultimate objective as the existing defendants and where those defendants are represented by a government agency.” 706 F.3d at 352. Because of the differing interests of Applicants and Defendants, the rule in Teague should be decisive in this case.
B. In The Alternative, Applicants Should Be Granted Permissive Intervention
Alternatively, this Court should permit Applicants to intervene pursuant to Rule 24(b) of the Federal Rules of Civil Procedure. Rule 24(b) provides for permissive intervention where a party timely files a motion and “has a claim or
7

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defense that shares with the main action a common question of law or fact.” Fed. R. Civ. P. 24(b)(1)(B). “In exercising its discretion, the court must consider whether the intervention will unduly delay or prejudice the adjudication of the original parties’ rights.” Fed. R. Civ. P. 24(b)(3).
The arguments set forth in Part I, infra, establish that Applicants meet the criteria for permissive intervention, which should be liberally granted. “[T]he Fourth Circuit generally recognizes that liberal intervention is desirable to dispose of as much of a controversy involving as many apparently concerned persons as is compatible with efficiency and due process.” Pinnacle Bank v. Bluestone Energy Sales Corp., Civil Action No. 7:15CV00149, 2017 WL 6915289 (W.D. Va. Nov. 24, 2017) (internal quotation marks omitted), citing Feller v. Brock, 802 F.2d 722, 729 (4th Cir. 1986); see also Baker Packing Co. v Andrews Farming, Inc., Civil Action No. 7:17CV00395, 2016 WL 8777364 (W.D. Va. Nov. 23, 2016). IV. CONCLUSION
For the reasons set forth above, Applicants respectfully request that their Motion be granted, and that this honorable Court allow Applicants to intervene as defendants in order to protect their interest in the subject matter of this litigation.
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Case 6:20-cv-00024-NKM Document 29 Filed 04/24/20 Page 9 of 10 Pageid#: 347

Dated:

April 24, 2020

Respectfully submitted,
/s/ Christopher M. Marston Christopher M. Marston (VSB No. 65703) chris@2562group.com 2652 GROUP LLC P.O. Box 26141 Alexandria, VA 22313-6141 571.482.6790 / Fax 703.997.2549
Trevor M. Stanley (VSB No. 77351) E. Mark Braden (pro hac vice pending) Katherine L. McKnight (adm. pending) Richard Raile (VSB No. 84340) BAKER & HOSTETLER LLP Washington Square, Suite 1100 1050 Connecticut Avenue, N.W. Washington, DC 20036-5403 202.861.1500 / Fax 202.861.1783 tstanley@bakerlaw.com mbraden@bakerlaw.com kmcknight@bakerlaw.com rraile@bakerlaw.com
Patrick T. Lewis (pro hac vice pending) BAKER & HOSTETLER LLP 127 Public Square, Suite 2000 Cleveland, OH 44114-1214 216.621.0200 / Fax 216.696.0740 plewis@bakerlaw.com
Counsel for Proposed Intervenors

9

Case 6:20-cv-00024-NKM Document 29 Filed 04/24/20 Page 10 of 10 Pageid#: 348

CERTIFICATE OF SERVICE

I certify that on April 24, 2020, the foregoing was filed on the Court’s

electronic case filing system. Notice of the filing was generated by the Court’s

electronic system. Copies of the filing are available on that system.

/s/

Christopher M. Marston

Christopher M. Marston (VSB No. 65703)

10

 </s> Case 6:20-cv-00024-NKM-RSB Document 81 Filed 06/19/20 Page 1 of 32 Pageid#: 1700

UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA
Lynchburg Division

6/19/2020

LEAGUE OF WOMEN VOTERS OF

VIRGINIA;

KATHERINE

D.

CROWLEY; and SEIJRA TOOGOOD,

Plaintiffs,

v.

VIRGINIA STATE BOARD OF ELECTIONS; ROBERT H. BRINK, JOHN O’BANNON, and JAMILAH D. LECRUISE, in their official capacities as Chairman, Vice-Chair, and Secretary of the Virginia State Board of Elections, respectively; and CHRISTOPHER E. PIPER, in his official capacity as Commissioner of the Virginia Department of Elections,

Defendants.

Case No.: 6:20-cv-00024-NKM
AMENDED COMPLAINT FOR INJUNCTIVE AND DECLARATORY RELIEF

1. Virginia Attorney General Mark Herring recently said that “[f]ree and fair elections are at the core of our democracy and no Virginian should have to choose between their health and exercising their right to vote.”1 Plaintiffs League of Women Voters of Virginia, Katherine Crowley, and Seijra Toogood agree. Yet Virginia’s requirement that each voter submitting a mail absentee ballot have another individual witness and sign their ballot envelope does exactly that:

1 Press Release, Ralph Northam, Governor of Virginia, Governor Northam Announces Plans to Postpone Upcoming Virginia Elections in Response to COVID-19 (Apr. 8, 2020), https://www.governor.virginia.gov/newsroom/allreleases/2020/april/headline-855995-en.html.
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presents tens of thousands of Virginia voters like Plaintiffs with the Hobson’s choice of either risking their health to vote or not voting at all.
2. Plaintiffs therefore bring this action challenging the constitutionality of Virginia’s witness requirement on absentee ballots to preserve their and many other Virginians’ fundamental right to vote in the midst of the pandemic of a respiratory disease known as the coronavirus disease 2019 (“COVID-19”), caused by the spread of a novel coronavirus, SARS-CoV-2. Without relief, the extreme burden the witness requirement places on voters in the current environment far outweighs any marginal benefit to the Commonwealth in retaining it.
3. The “United States is now the ‘epicenter’ of the global pandemic and has far more confirmed COVID-19 cases than any other nation.”2 The Centers for Disease Control and Prevention (“CDC”) and the Virginia Department of Health have both urged people to avoid coming within six feet of individuals with whom they do not reside, as a key to both slowing the spread of the virus and keeping individuals healthy. As such, Governor Ralph Northam has ordered that all Virginians remain at home except for the basic necessities through at least June 10, 2020.3
4. In the midst of this crisis and especially during a stay-at-home mandate, Virginia’s requirement that every individual filling out an absentee ballot find another adult to witness their filling out of the ballot and sign on their ballot envelope alongside the voter’s own signed attestation amounts to an unconstitutional burden on the right to vote. This is certainly true for
2 General Order No. 2020-11, In re: Court Operations Under the Exigent Circumstances Created by the Outbreak of Coronavirus Disease (COVID-19): Temporary Policy for Remote Proceedings and Public Access to Such Proceedings (hereinafter “In re Court Operations”), Case No. 2:20mc7 (E.D. Va. Apr. 6, 2020). 3 See Va. Executive Order No. 2020-55, https://www.governor.virginia.gov/media/governorvirginiagov/executiveactions/EO-55-Temporary-Stay-at-Home-Order-Due-to-Novel-Coronavirus-(COVID-19).pdf
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Virginia’s federal office primaries in June, and will likely be true for voting in the November general election as well.
5. The COVID-19 outbreak means that the witness requirement will disenfranchise many thousands of Virginians like the individual Plaintiffs who cannot risk contact with other individuals to vote in person or obtain a witness signature on their absentee ballot. Over a quarter of Virginians age 18 and over live by themselves, and almost a third of Virginians over 65 years of age—one of the groups most vulnerable to COVID-19—live alone.4 And the impact of this requirement will also fall more heavily on Virginians with disabilities and African Americans, who both live alone in larger percentages than the population as a whole.5
6. The witness requirement mostly directly and disproportionately harms African Americans during the COVID-19 pandemic, though, because they face greater rates of severe health complications and death from COVID-19. Virginia’s history of voting-related discrimination against African Americans, as well as continuing discrimination in areas such as education, employment, and health, interacts with the witness requirement to hinder their ability to participate effectively in the political process in violation of Section 2 of the Voting Rights Act.
7. Over half a million Virginians cast ballots in the June 2018 Democratic and Republican primaries, and over 3.98 million Virginians cast ballots in the November 2016 general election. The Virginians who live alone and would have otherwise voted in the upcoming elections but will not, or those whose absentee ballots will be rejected, will therefore likely number in the
4 2018 Current Population Survey, U.S. Census Bureau, statistics accessed by using the Census Bureau Current Population Survey Table Creator tool at https://www.census.gov/cps/data/cpstablecreator.html. 5 Id.
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tens of thousands, if not hundreds of thousands, given the likely explosion of voting by mail this year.
8. The witness requirement is not worth this massive disenfranchisement of Virginia voters and its disproportionate harm to elderly voters, African American voters, and voters with disabilities. While election integrity is an important interest, the witness requirement does very little if anything—and it is certainly not narrowly tailored—to serve this interest in light of the many other provisions of Virginia law that safeguard absentee voting and penalize those who abuse the process. The fact that Virginia is one of only 11 states that require an individual submitting an absentee ballot to have a witness sign their ballot envelope further underscores the requirement’s lack of necessity. Regardless, whatever additional marginal benefits the witness requirement may offer, such benefit is greatly outweighed by the risk of disenfranchisement. The lack of an opportunity to cure a missing witness signature further compounds the burden.
9. Plaintiffs therefore ask that the Court enjoin Virginia’s absentee witness requirement and declare it unconstitutional and in violation of Section 2 of the Voting Rights Act for this year’s elections.
PARTIES 10. Plaintiff Katherine D. Crowley is a resident of Lexington, Virginia, where she is a registered voter. She has been a Virginia registered voter for many years and has consistently voted in both state and federal elections. She lives in Virginia’s Sixth congressional district, where there is no congressional primary this year, but she intends to vote in the November 2020 general election. 11. Because of the COVID-19 outbreak, Ms. Crowley does not feel safe voting in person for the November election if COVID-19 community transmission persists or recurs during
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that time frame. She would request an absentee ballot, but she lives by herself and does not feel safe finding an individual to witness and sign her absentee ballot envelope so she will not be able to vote in the November election or have her vote counted if the witness requirement remains in place. This is because she not only intends to follow any stay-at-home order if in place and practice social distancing if needed, but also because she has a previous medical diagnosis that she is concerned may put her at a higher risk for contracting COVID-19 and facing heightened medical consequences if she does. If the witness requirement is lifted, she will vote by absentee ballot in the November general election should COVID-19 transmission present a risk to her health at that point.
12. Plaintiff Seijra Toogood is a resident of Fairfax, Virginia, where she is a registered voter. She has been a Virginia registered voter for many years and has consistently voted in both state and federal elections. She lives in Virginia’s Eleventh congressional district and would like to vote in the June 23, 2020 primary election being held for that district.
13. Because of the COVID-19 outbreak, Ms. Toogood does not feel safe voting in person during the race. She has requested an absentee ballot, but she lives by herself and does not feel safe finding an individual to witness and sign her absentee ballot envelope so she will not be able to vote in the June primary or have her vote counted if the witness requirement remains in place. This is because she is not only following the Governor’s stay-at-home order and practicing social distancing, but also because she has underlying heart and respiratory issues that put her at a higher risk for contracting COVID-19 and facing serious medical consequences if she does. Similarly, if COVID-19 community transmission either persists or resurges around the time of the November general election, she will not be able to vote or have her vote counted if the witness requirement remains in place. If the witness requirement is lifted, she will vote by absentee ballot
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in the June primary, as well as in the November general election should COVID-19 transmission present a risk to her health at that point. As an African-American Virginian, Ms. Toogood is also aware of the ongoing history of voting, economic, and health discrimination against African Americans in Virginia, and believes the witness requirement perpetuates and worsens this discrimination.
14. Plaintiff League of Women Voters of Virginia (“the League”) is a nonprofit, nonpartisan membership organization that was founded in 1920. Its principal address is 1011 E. Main Street, Ste. 214A, Richmond, VA 23219.
15. The League works to encourage informed and active participation in government and influence public policy through education and advocacy. The League supports full voting and representational rights for all eligible Commonwealth citizens and promotes policies that encourage voter participation. The League has nearly 2,000 members across Virginia, some of whom live alone and are vulnerable to becoming severely ill from COVID-19 because they are elderly and/or have underlying health conditions. Certain of these members will seek to vote absentee in upcoming elections but will be unable to comply with the witness requirement without placing their own health at risk.
16. The League regularly conducts voter registration and get-out-the-vote activities for thousands of voters across the state, and in recent weeks it has been advocating through letters and calls to state officials for expanded use of voting by mail, absentee voting by mail and elimination of the witness requirement in order to better protect the health of voters and poll workers during the COVID-19 outbreak. The League anticipates that it will have to divert additional resources from its regular activities to advocate for lifting the requirement and to conduct outreach to its
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members and the voters they serve to ensure they understand and can find ways to comply with the requirements if possible.
17. Defendant Virginia State Board of Elections (the “Board”) is the regulatory authority authorized to make rules and regulations that, consistent with election laws, govern the work of local electoral boards, general registrars, and officers of election in properly administering elections in Virginia. Through the Department of Elections, it is also responsible for supervising and coordinating the work of the county and city electoral boards and registrars to ensure uniformity in their practices, as well as ensuring that electoral boards and general registrars are properly trained to carry out their duties. The Board also prescribes forms for voter registration and elections. See Va. Code § 24.2-103(a); Va. Code § 24.2-105. The Board sets standards that “tightly regulate[]” the “form of ballots used in Virginia elections.” Marcellus v. State Bd. of Elections, 849 F.3d 169, 172 (4th Cir. 2017).
18. Defendant Robert H. Brink is the Chairman of the Virginia Board of Elections. As Chairman, he is responsible for presiding over Board meetings and performing the functions of a presiding officer. As a member of the Board, he is also one of three individuals responsible for the actions of the Board. 1 Va. Admin. Code 20-20-30. He is sued in his official capacity.
19. Defendant John O’Bannon is the Vice-Chair of the Virginia Board of Elections. As Vice-Chair, he is responsible for performing the Board Chairman’s duties in the Chairman’s absence. As a member of the Board, he is also one of three individuals responsible for the actions of the Board. 1 Va. Admin. Code 20-20-30. He is sued in his official capacity.
20. Defendant Jamilah D. Lecruise is the Secretary of the Virginia Board of Elections. As Secretary, she is “authorized to do all things necessary to the proper execution of the law creating and governing the board and in the performance of the duties imposed upon it” so long as
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they are not such as they can only be performed “by the board in its corporate capacity.” 1 Va. Admin. Code 20-20-30. She also has the “authority to conduct the board’s administrative and programmatic operations and to discharge the board’s duties consistent with specific delegations of authority.” 1 Va. Admin. Code 20-20-60. As a member of the Board, she is also one of three individuals responsible for the actions of the Board. She is sued in her official capacity.
21. Defendant Christopher E. Piper is the Commissioner of the Virginia Department of Elections (the “Department”). The Department conducts the Board’s administrative and programmatic activities and discharges the Board’s duties within its delegated authority. The Department is also responsible for administering and maintaining the Commonwealth’s voter registration system and overseeing registered voter list maintenance, and for providing electronic applications for voter registration and absentee ballots. As Commissioner, Defendant Piper is responsible for overseeing the day-to-day operations of the Department. He also has powers “to designate alternative methods and procedures to handle” absentee applications and ballots “in the case of an emergency that will not allow sufficient time for the distribution and handling of absentee ballot applications and absentee ballots . . . for qualified voters who are unable to vote in person because of the emergency.” Va. Code § 24.2-713. He is sued in his official capacity.
JURSIDICTION AND VENUE 22. This action arises under the First and Fourteenth Amendments to the U.S. Constitution as well as Section 2 of the Voting Rights Act, and is brought under 42 U.S.C. §§ 1983 and 1988 and authorized under 52 U.S.C. § 10302 to seek injunctive and declaratory relief for
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violations of constitutional and statutory rights under color of state law. This Court therefore has subject matter jurisdiction under 28 U.S.C. §§ 1331 and 1343.
23. This Court has personal jurisdiction over Defendants because each is either a state agency or sued in their official capacity as a state official, and the violations complained of concern their conduct in such capacities.
24. Declaratory relief is authorized by 28 U.S.C. §§ 2201 and 2202. 25. Venue in the Western District of Virginia is proper based on 28 U.S.C. § 1391(b)(2) because a substantial part of the events that gave rise to Plaintiffs’ claims occurred or will occur there, including concerning Plaintiff Crowley (City of Lexington) who resides there.
FACTS Transmission of COVID-19 and Public Health Guidelines
26. The novel coronavirus, SARS-CoV-2, is the virus that causes COVID-19, a deadly disease that is now a global pandemic.6
27. According to the CDC, this coronavirus spreads aggressively and asymptomatic people can spread it.7 All age groups have contracted the disease.8 There is no vaccine, and there is no cure.
28. As of early April, the United States led the world in the total number of COVID-19 cases, surpassing even China and Italy before spread of the virus has even peaked. As many as
6 Betsy McKay et al., Coronavirus Declared Pandemic by World Health Organization, WALL ST. J. (Mar. 11, 2020, 11:59 PM), https://www.wsj.com/articles/u-s-coronavirus-cases-top-1-000-11583917794. 7 Centers for Disease Control and Prevention, How Coronavirus Spreads, https://www.cdc.gov/coronavirus/2019ncov/prevent-getting-sick/how-covid-spreads.html (last visited Apr. 15, 2020). 8 Robert Verity, PhD., et al., Estimates of the Severity of Coronavirus Disease 2019: A Model-Based Analysis, Lancet Infec Dis (March 30, 2020), 6.
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240,000 people in the United States may die from COVID-19 during the current outbreak, even accounting for existing governmental and public health interventions.9
29. The World Health Organization (“WHO”) estimates that approximately 20 percent of those infected by SARS-CoV-2 require hospitalization.10 This is because COVID-19 can severely damage lung tissue, cause a permanent loss of respiratory capacity, and also damage tissues in the kidney, heart, and liver.11
30. Despite some initial comparisons to seasonal influenza, estimates from early March put the fatality rate for people infected with COVID-19 at approximately ten times higher than even a severe flu season, including in countries with advanced health care systems.12
31. While people of all ages have contracted and died from COVID-19, it is particularly fatal for older individuals. Preliminary reports based on WHO data show a 3.6% mortality rate for individuals between 60-69 years old, an 8% mortality rate for those 70-79 years old, and a 14.8% mortality rate for those who are 80 years old or older.13 COVID-19 also poses greater risks for
9 Rick Noack, et al., White House Task Force Projects 100,000 to 240,000 Deaths in U.S., Even With Mitigation Efforts, WASH. POST (April 1, 2020, 12:02 am), https://www.washingtonpost.com/world/2020/03/31/coronaviruslatest-news/. 10 World Health Organization, Q&A on Coronaviruses (COVID-19), “Should I Worry About COVID-19?,” https://www.who.int/news-room/q-a-detail/q-a-coronaviruses. 11 Centers for Disease Control and Prevention, Interim Clinical Guidance for Management of Patients with Confirmed Coronavirus Disease (COVID-19), https://www.cdc.gov/coronavirus/2019-ncov/hcp/clinical-guidancemanagement-patients.html (last visited Apr. 15, 2020). 12 Betsy McKay, Coronavirus vs. Flu Which Virus is Deadlier, WALL ST. J. (Mar. 10, 2020, 12:49 PM), https://www.wsj.com/articles/coronavirus-vs-flu-which-virus-is-deadlier-11583856879. 13 Centers for Disease Control and Prevention, Interim Clinical Guidance for Management of Patients with Confirmed Coronavirus Disease (COVID-19), https://www.cdc.gov/coronavirus/2019-ncov/hcp/clinical-guidancemanagement-patients.html (last visited Apr. 15, 2020).
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people with preexisting heart and respiratory conditions, individuals with compromised immune systems, and those with many other conditions.14
32. The effects of the pandemic on social life will last well into the summer of 2020, if not much longer. While there is some reason to believe that transmission may taper somewhat in the summer months, experts have indicated that COVID-19 “will face less immunity and thus transmit more readily even outside of the winter season,” and that season changes are “unlikely to stop transmission.”15 Further, even those who develop an immune response to the virus after an infection are not necessarily safe from reinfection, as we do not yet have sufficient data about how long immunity to the virus will last.16 This week, Dr. Anthony Fauci, head of the National Institute of Allergy and Infectious Diseases, said that he “can’t guarantee” in-person voting will be safe in November, because of a potential resurgence of COVID-19 in the fall.17
33. Because there is no vaccine, social distancing measures, including maintaining at least six feet of space between people (as well as consistent hygiene practices), are the only known effective measures for protecting against transmission of COVID-19.18 The CDC has issued guidance informing individuals to avoid public gatherings until at least May 15, 2020.
14 Centers for Disease Control and Prevention, Groups at Higher Risk of Severe Illness, https://www.cdc.gov/coronavirus/2019-ncov/need-extra-precautions/groups-at-higher-risk.html (last visited Apr. 15, 2020). 15 Marc Lipsitch, DPhil, Professor of Epidemiology and Director, Center for Communicable Disease Dynamics, Harvard T.H. Chan School of Public Health, Seasonality of SARS-CoV-2: Will COVID-19 go away on its own in warmer weather?, https://ccdd.hsph.harvard.edu/will-covid-19-go-away-on-its-own-in-warmer-weather/. 16 Apoorva Mandavilli and Katie Thomas, Will an Antibody Test Allow Us to Go Back to School or Work?, N.Y. TIMES (Apr. 11, 2020), https://www.nytimes.com/2020/04/10/health/coronavirus-antibody-test.html 17 Jason Silverstein, Fauci says he “can’t guarantee” in-person voting in November will be safe, CBSNews.com (Apr. 13, 2020), https://www.cbsnews.com/news/coronavirus-fauci-says-he-cant-guarantee-in-person-voting-innovember-will-be-safe/?ftag=CNM-00-10aac3a. 18 Johns Hopkins University, Coronavirus, Social Distancing and Self-Quarantine, https://www.hopkinsmedicine.org/health/conditions-and-diseases/coronavirus/coronavirus-social-distancing-and-
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34. For this reason, the CDC has issued specific guidelines concerning voting during the COVID-19 pandemic. Among other things, it recommends that states “[e]ncourage voters to use voting methods that minimize direct contact with other people and reduce crowd size at polling stations” including “mail-in methods of voting if allowed in the jurisdiction.”19
35. These recommendations make sense, given the relative risks of voting in person during the pandemic versus voting by mail. There is no evidence that SARS-CoV-2 can be spread through the mail, and the U.S. Postal Service has further changed their policies to “eliminate the requirement that customers sign our Mobile Delivery Devices for delivery” and now require the customer “to step back a safe distance or close the screen door/door so that they may leave the item in the mail receptacle or appropriate location by the customer door.”20
36. In contrast, the risks of interpersonal interaction while voting have already borne out unfortunate results. In Illinois, a person who worked at a Chicago polling place during the March 17 primary died from COVID-19,21 while another tested positive after voting in person.22 And during Florida’s recent primary, two Broward County poll workers tested positive for
self-quarantine (last visited Apr. 15, 2020); Declaration of Dr. Jonathan Louis Golob at ¶ 8, ECF No. 5, Dawson v. Asher, 2:20-cv-00409-JLRMAT (W.D. Wash. Mar. 16, 2020). 19 Centers for Disease Control & Prevention, Recommendations for Election Polling Locations: Interim guidance to prevent spread of coronavirus disease 2019 (COVID-19) (updated Mar. 27, 2020), https://www.cdc.gov/coronavirus/2019-ncov/community/election-polling-locations.html. 20 United States Postal Service. USPS Statement on Coronavirus (Apr. 2, 2020), https://about.usps.com/newsroom/statements/usps-statement-on-coronavirus.htm (citing guidance from World Health Organization, CDC, and Surgeon General) 21 Mary Ann Ahern, Poll Worker at Chicago Voting Site Dies of Coronavirus, Election Officials Say, NBC CHICAGO (Apr. 13, 2020, 10:59 AM), https://www.nbcchicago.com/news/local/chicago-politics/poll-worker-at-chicagovoting-site-dies-of-coronavirus-election-officials-say/2255072/. 22 Gov. Pritzker Encourages Illinoisans to Vote by Mail After In-Person Voter Tests Positive for Coronavirus, NBC CHICAGO (Apr. 12, 2020, 6:07 PM), https://www.nbcchicago.com/news/local/gov-pritzker-encourages-illinoisansto-vote-by-mail-in-upcoming-general-election/2254687/..
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COVID-19, one of whom was handling driver’s licenses as part of the identification verification process.23
37. In Milwaukee and Green Bay, Wisconsin, voters experienced multi-hour waits and
lines stretching blocks upon blocks because government officials there were unable to create a viable vote-by-mail process for all voters.24 These are the opposite of constitutionally appropriate conditions called for in an infectious disease pandemic.25 Virginia must not emulate them.
COVID-19 in Virginia
38. Virginia faces a steadily rising number of COVID-19 cases. As of March 31, the
Virginia Department of Health (“VDH”) was reporting “widespread community transmission across the state.”26 And as of April 16, VDH reported 6,889 COVID-19 diagnoses in Virginia, resulting in 1,114 hospitalizations and 208 deaths.27 Moreover, as of late March, “Virginia’s
fatality rate, based on the number of known cases, is relatively higher than many other states” and
“insufficiency of current testing suggests the likelihood that COVID-19 is substantially more
23 Anthony Man, Two Broward poll workers, including one who handled voters’ driver licenses, test positive for coronavirus, S. FLA. SUN SENTINEL (Mar. 26, 2020), https://www.sun-sentinel.com/coronavirus/fl-ne-browardelections-poll-workers-coronavirus-20200326-wmgy775dvjc5jis2oagxlpmule-story.html. 24 Parker Schorr, Wisconsin’s pandemic election: Long waits, face masks as voters go to polls, THE CAP TIMES (Apr. 8, 2020), https://madison.com/ct/news/local/govt-and-politics/wisconsin-s-pandemic-election-long-waits-facemasks-as-voters-go-to-polls/article_bfd2c391-f390-5364-8c14-a88b548fe017.html; Benjamin Swasey, Wisconsin Vote Ends As Trump Blames Governor For Long Lines, NPR (Apr. 7, 2020 12:23 PM), https://www.npr.org/2020/04/07/828835153/long-lines-masks-and-plexiglas-barriers-greet-wisconsin-voters-atpolls. 25 Devi Shastri, In-person voting was likely a ‘disaster’ for Wisconsin’s efforts to flatten coronavirus curve, national experts say, MILWAUKEE JOURNAL SENTINEL (Apr. 8, 4:51 PM), https://www.jsonline.com/story/news/politics/elections/2020/04/08/coronavirus-wisconsin-election-likely-hurteffort-flatten-curve/2961718001/. 26 Va. Dep’t of Health, COVID-19 Cases in Virginia, http://www.vdh.virginia.gov/coronavirus/ (last visited Apr. 16, 2020). 27 Id.
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widespread in Virginia than it appears from the official numbers.”28 Tragically, one of the nation’s deadliest COVID-19 outbreaks appears to have occurred at an assisted living center in Richmond, where at least 45 residents have died and around 80 percent have been diagnosed as positive.29
39. VDH has “urge[d] all Virginians to stay home and practice social distancing. If you have to go out for critical things like grocery shopping or medical care, stay at least 6 feet away from others.”30 It has also adopted “Guiding Principles for Community Mitigation Strategies” based on similar CDC guidance. Among these principles are considering “all aspects of a community that might be impacted, including populations most vulnerable to severe illness and those that may be more impacted socially or economically, and select appropriate actions,” and identifying “ways to ensure the safety and social well-being of groups that may be especially impacted by mitigation strategies, including individuals at increased risk for severe illness.”31
40. Since early March, Governor Northam has also taken a series of increasingly aggressive actions in response to the growing threat posed by the virus, including an emergency declaration and numerous executive orders.
41. Notably, on March 12, 2020, invoking his statutory and Virginia constitutional authority, Governor Northam declared a State of Emergency for Virginia “to continue to prepare
28 In re Extension to Modifications of Ct. Operations: S. to Gen. Orders 2020-02 and 2020-03, No. 2:20MC7, 2020 WL 1441770, at *1 (E.D. Va. Mar. 24, 2020). 29 Danielle Ivory, et al., N.Y. TIMES, Coronavirus Outbreak at Virginia Nursing Home Spirals Out of Control as 45 Die (Apr. 14, 2020), https://www.nytimes.com/2020/04/14/us/coronavirus-nursing-homes.html. 30 Id. 31 Virginia Department of Health, Schools, Workplaces & Community Locations, http://www.vdh.virginia.gov/coronavirus/schools-workplaces-community-locations/ (last visited Apr. 15, 2020).
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and coordinate our response to the potential spread of COVID-19, a communicable disease of public health threat.”32
42. On March 13, he closed all Virginia K-12 schools for a minimum of two weeks, and eventually extended that order for the remainder of the academic year.33
43. Governor Northam advised on March 17 that Virginians “with chronic health conditions or aged 65 or older should self-quarantine,” and ordered all DMV offices closed.34 He
also requested and the Supreme Court of Virginia granted a suspension of “non-emergency court
proceedings in all district and circuit courts” absent specific exceptions through April 6, and extended and tolled non-exempted court deadlines for 21 days.35
44. On March 23, Governor Northam ordered all non-essential businesses closed until at least April 23 and banned public gatherings of more than 10 people.36
45. On March 30, Governor Northam issued a statewide “Stay at Home” order to last
at least until June 10, directing all Virginians to stay at home except under extremely limited
circumstances. He added: “We are in a public health crisis, and we need everyone to take this
32 Va. Exec. Order No. 2020-51 (Mar. 12, 2020), https://www.governor.virginia.gov/media/governorvirginiagov/governor-of-virginia/pdf/eo/EO-51-Declaration-of-aState-of-Emergency-Due-to-Novel-Coronavirus-(COVID-19).pdf. 33 Press Release, Ralph Northam, Governor of Virginia, Governor Northam Orders All Virginia K-12 Schools Closed for Minimum of Two Weeks (Mar. 13, 2020), https://www.governor.virginia.gov/newsroom/allreleases/2020/march/headline-854442-en.html; Press Release, Ralph Northam, Governor of Virginia, Governor Northam Orders Statewide Closure of Certain Non-Essential Businesses, K-12 Schools (Mar. 23, 2020), https://www.governor.virginia.gov/newsroom/all-releases/2020/march/headline-855292-en.html. 34 Press Release, Ralph Northam, Governor of Virginia, Governor Northam Announces New Measures to Combat COVID-19 and Support Impacted Virginians (Mar. 17, 2020), https://www.governor.virginia.gov/newsroom/allreleases/2020/march/headline-854487-en.html. 35 Id. 36 Press Release, Ralph Northam, Governor of Virginia, Governor Northam Orders Statewide Closure of Certain Non-Essential Businesses, K-12 Schools (Mar. 23, 2020), https://www.governor.virginia.gov/newsroom/allreleases/2020/march/headline-855292-en.html.
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seriously and act responsibly. Our message to Virginians is clear: stay home. We know this virus
spreads primarily through human-to-human contact, and that’s why it’s so important that people follow this order and practice social distancing.”37
46. Virginia received a Major Disaster Declaration from the federal government on April 2.38
47. Just this week, researchers at the University of Virginia projected that COVID-19 cases in Virginia may not peak until mid-August.39
48. Faced with local elections in some parts of Virginia scheduled for May, and a
primary for federal races in June, both the Governor and Elections Department have begun to take
some steps in recognition of the dual priorities of public health and representative government.
49. For one, the Virginia Department of Elections has issued guidance that all registered
Virginia voters may vote absentee by mail in the June primary (and May elections if they go
forward) due to the COVID-19 outbreak by selecting reason “2A My disability or illness” on the ballot application.40 Defendants have further encouraged Virginians to use this option, with the
37 Va. Exec. Order No. 2020-55 (Mar. 30, 2020), https://www.governor.virginia.gov/media/governorvirginiagov/executive-actions/EO-55-Temporary-Stay-at-HomeOrder-Due-to-Novel-Coronavirus-(COVID-19).pdf; Press Release, Ralph Northam, Governor of Virginia, Governor Northam Issues Statewide Stay at Home Order (Mar. 30, 2020), https://www.governor.virginia.gov/newsroom/allreleases/2020/march/headline-855702-en.html (emphasis added). 38 Press Release, Ralph Northam, Governor of Virginia, Virginia Receives Major Disaster Declaration from Federal Government for COVID-19 (Apr. 2, 2020), https://www.governor.virginia.gov/newsroom/allreleases/2020/april/headline-855921-en.html. 39 Mel Leonor & Justin Mattingly, UVA researchers project mid-August peak for new COVID-19 cases in Virginia, RICHMOND TIMES DISPATCH (Apr. 13, 2020), https://www.richmond.com/special-report/coronavirus/uvaresearchers-project-mid-august-peak-for-new-covid-19-cases-in-virginia/article_c4e2c008-1617-52d8-ad08706abfb3d696.html. 40 Va. Dep’t of Elections (@vaELECT), Twitter (Mar. 23, 2020, 8:34 AM), https://twitter.com/vaELECT/status/1242067184521748480; Va. Dep’t of Elections, Absentee Ballots, https://www.elections.virginia.gov/casting-a-ballot/absentee-voting/.
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Department of Elections “encourag[ing] voters to protect their health during COVID-19 outbreak,” and noting that absentee voting for the upcoming elections “is strongly encouraged.”41
50. On April 8, Governor Northam exercised his statutory authority to move the June primary elections from June 9, 2020, to June 23, 2020, and requested that General Assembly move the May General Election and all special elections scheduled for May 5, 2020 to the November 3, 2020 General Election. He took these actions “to further mitigate the spread of COVID-19,” and for purposes of “protecting the health and safety of Virginians during this pandemic and ensuring our citizens can make their voices heard in a safe, fair, and uniform manner.”42
51. This Court has taken similar steps in light of the pandemic. For example, on March 24, the Court extended its restriction on in-person court proceedings to “any criminal, civil and bankruptcy proceedings on or before May 2, 2020.”43 COVID-19’s Impact on African American Virginians in Light of Ongoing and Historical Discrimination
52. Nationally, the COVID-19 epidemic has had a particularly devastating effect in African-American communities. A recent analysis—one of the first attempts to examine the racial disparities of COVID-19 cases and deaths nationwide—found that, in areas where the demographic data has been publicly shared by government officials, African-Americans have
41 Va. Dep’t of Elections, Absentee Ballots, https://www.elections.virginia.gov/casting-a-ballot/absentee-voting/ (last visited Apr. 15, 2020). ress Release, Ralph Northam, Governor of Virginia, Governor Northam Announces Plans to Postpone Upcoming Virginia Elections in Response to COVID-19 (Apr. 8, 2020), https://www.governor.virginia.gov/newsroom/allreleases/2020/april/headline-855995-en.html. 43 Am. Standing Order No. 2020-5, In re: Court Operations Under the Exigent Circumstances Created by COVID19 (W.D. Va. Mar. 24, 2020).
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made up 42% of people who have died from COVID-19, despite accounting for roughly only 21% of the total population in these areas.44
53. Virginia fits this trend, witnessing racially disparate patterns of serious illness and mortality due to COVID-19. “African Americans constitute approximately 20% of Virginia’s population, but make up about 30% of the total number of reported positive cases in Virginia.”45 Public health experts believe that these statistics likely understate the racially disparate effect of COVID-19 in African-American communities in Virginia. For example, Dr. Robert Winn, the Director of the Massey Cancer Center at Virginia Commonwealth University, estimates that “[i]n some cases,” African Americans are “three to six times more [likely to be infected by the COVID19 virus] than their white counterparts.”46
54. Courtney Cogburn, an associate professor at the Columbia University School of Social Work, noted that “[t]here are patterns at this intersection of race and socioeconomic status that make it very clear this is just not a story about poverty.” That is, racial disparities in serious illness and death due to COVID-19 are inextricably linked to a long history and ongoing patterns of racial discrimination against African Americans:
44 Kat Stafford, et al., Outcry over racial data grows as virus slams black Americans, ASSOCIATED PRESS, (Apr. 8, 2020), https://apnews.com/71d952faad4a2a5d14441534f7230c7c?fbclid=IwAR1plunY_qfeA2KrSUPA1TuJobAwQh53a_Qlkf5dw0dWjz-iz85GA1FOt4. 45 Nana-Séntuo Bonsu, Disproportionate numbers appearing in African American COVID-19 cases in Virginia; doctor explains, WKTR (Apr. 10, 2020), https://www.wtkr.com/news/disproportionate-numbers-appearing-inafrican-african-covid-19-cases-in-virginia-doctor-explains; see also Elizabeth Thomas & Dr. Nancy A. Anoruo, Coronavirus is disproportionately killing the black community. Here’s what experts say can be done about it, ABC NEWS (Apr. 9, 2020), https://abcnews.go.com/Politics/coronavirus-disproportionately-killing-black-communityexperts/story?id=70011986. 46 Matthew Fultz, African Americans 3 to 6 times more likely to get COVID-19, expert says, WTVR (last updated Apr. 13, 2020), https://www.wtvr.com/news/coronavirus/african-americans-3-to-6-times-more-likely-to-get-covid19-expert-says.
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A history of systemic racism and inequity in access to health care and economic opportunity has made many African Americans far more vulnerable to the virus. Black adults suffer from higher rates of obesity, diabetes and asthma, which make them more susceptible, and also are more likely to be uninsured. They also often report that medical professionals take their ailments less seriously when they seek treatment.47 55. Virginia has long experienced patterns of racial discrimination in health and socioeconomic life patterns that render African-American Virginians at greater risk of severe health complications from COVID-19. As Governor Northam has acknowledged, We know that long-standing racial inequities in things like access to health care, education, and economic opportunities lead to differences in underlying health conditions. The existence of such inequities is one reason why communities of color, including African American people, are more likely to have some of the underlying health conditions that put them at greater risk with COVID-19.48 56. Similarly, Virginia Health Commissioner Norman Oliver has acknowledged that racial inequalities render African-American Virginians particularly vulnerable to COVID-19, noting that lack of access to health care in African-American communities contributes “to much higher disease burden, with twice the rate of diabetes, hypertension, obesity,” resulting in “underlying problems [that] then place these folks at higher risk of mortality from COVID-19.” Health Commissioner Oliver further noted that African Americans in Virginia more frequently “tend to be concentrated in the essential industries and are working,” with “less social distancing . . . and less opportunity for teleworking.”49 And Dr. Winn of VCU has noted that, in comparison to their white counterparts, African American Virginians lack access to healthcare and
47 See supra n. 44 (Stafford, et al.). 48 Neal Augenstein, Virginia governor seeks more data on how COVID-19 affects minorities, WTOP (Apr. 9, 2020), https://wtop.com/virginia/2020/04/virginia-governor-seeks-more-data-on-how-covid-19-affects-minorities/. 49 Id.
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information, suffer from underlying health conditions, and are more likely to hold “essential jobs” and cannot work from home.50
57. Virginia has a long history of racial discrimination in a wide range of areas in socioeconomic life, including in voting. Virginia’s Absentee Voting Process and Witness Requirement
58. Virginia law sets out certain categories of individuals who may vote by mail ballot, known in Virginia as absentee voting. These categories include people absent from the jurisdiction on Election Day including students, service members on active duty, a person with a disability unable to vote in person because of “disability, illness, or pregnancy,” people prevented from voting on Election Day due to religious observance, and several other categories. Va. Code § 24.2700.
59. During the 2020 legislative session, the Virginia General Assembly passed and the Governor signed a number of voting reforms, including an expansion of absentee voting to make all registered voters eligible to use this process without an excuse.51 This takes effect July 1, 2020.
60. Nonetheless, as previously noted, the Department of Elections has published informal guidance on their website providing that voters may apply for and submit an absentee ballot for the May and June elections by choosing reason “2A My disability or illness” due to COVID-19.
50 See supra n. 46 (Fultz). 51 See 2020 Va. H.B. 1, available at https://lis.virginia.gov/cgi-bin/legp604.exe?201+ful+HB1ER; Press Release, Officer of the Governor, “Governor Northam Signs Sweeping New Laws to Expand Access to Voting” (Apr. 12, 2020), https://www.governor.virginia.gov/newsroom/all-releases/2020/april/headline-856055-en.html.
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61. On June 23, 2020, Virginia will hold Democratic and Republican primaries for federal offices. Republicans have a statewide primary for a U.S. Senate seat as well as primaries in Virginia’s Second and Third congressional districts. Meanwhile, Democrats have primaries for House races in the First, Fourth, Fifth, and Eleventh congressional districts.
62. Absentee ballot applications submitted by mail for these races must be received by the appropriate registrar no later than June 16 at 5 PM. Va. Code § 24.2-701(B)(2). Completed absentee ballots must be returned to the registrar by the close of polls on Election Day. Va. Code § 24.2-709.
63. Individuals may request an absentee ballot online or by sending in a mail request, among other methods. When applying, individuals must sign the application “subject to felony penalties for making false statements” that the “facts contained in the application are true and correct” and that they “will not vote in the election at any other place in Virginia or in any other state.” Va. Code § 24.2-701(B)(1). An exception exists for individuals who cannot sign due to disability, in which case “a person assisting the applicant will note this fact on the applicant signature line and provide his signature, name, and address.” Id.
64. When a registrar receives an absentee ballot application and verifies that the individual properly competed the application and that they are a registered voter in the jurisdiction, the registrar mails to the individual the following items:
a. A sealed envelope containing the unmarked ballot; b. An envelope for resealing the marked ballot on which is printed a “Statement
of Voter,” as well as spaces for the voter to sign and date and for a witness to sign. The “Statement of Voter” informs voters, among other things, that their signature certifies “subject to felony penalties for making false statements,”
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their name, legal residence, that they received the ballot after requesting it, that they opened the ballot envelope “in the presence of the witness” but without assistance, that they sealed the ballot in the envelope, and that they “have not voted and will not vote in this election at any other time or place”; c. “A properly addressed envelope for the return of the ballot to the general registrar by mail or by the applicant in person”; and d. “Printed instructions for completing the ballot and statement on the envelope and returning the ballot.” Va. Code § 24.2-706. 65. As noted by the instructions, when voters receive their mailed absentee ballots, they “shall, in the presence of a witness, (i) open the sealed envelope marked ‘ballot within’ and (ii) mark and refold the ballot . . . without assistance and without” indicating how they marked the ballot. Va. Code § 24.2-707(A). 66. Once voters fill out their ballots, they “shall (a) enclose the ballot in the envelope provided for that purpose, (b) seal the envelope, (c) fill in and sign the statement printed on the back of the envelope in the presence of a witness, who shall sign the same envelope, (d) enclose the ballot envelope and any required assistance form within the envelope directed to the general registrar, and (e) seal that envelope and mail it to the office of the general registrar or deliver it personally to the general registrar.” Id. 67. When the absentee ballot process counting begins, election officers examine each absentee ballot envelope to determine whether to accept the ballot for counting. The relevant statute provides that an absentee ballot may not be rejected on the basis that the voter failed to provide a middle name, middle initial, or the date, Va. Code § 24.2-711, but is silent as to whether
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an absentee ballot may or must be rejected if the voter failed to provide any of the other parts of the absentee ballot envelope, such as the witness signature.
68. However, under regulations promulgated by the Board, the lack of a witness signature on the absentee ballot envelope is an omission that is “always material” and that renders the ballot invalid. 1 Va. Admin. Code 20-70-20(B).
69. By contrast, absentee ballots that do contain a witness signature are not rendered invalid if the witness signature is illegible, even though there is no requirement that the witness print their name or otherwise identify themselves anywhere on the ballot envelope.
70. Virginia statutes and regulations provide no process by which voters may correct any errors on their absentee ballot envelopes after they are mailed to the general registrar, and in practice, all absentee ballots lacking a witness signature are rejected as a matter of course without any effort to verify whether the absentee ballot came from the intended voter. Voters whose ballots are rejected because of a lack of a witness signature do not learn of this until after the election, when the electoral board “send[s] a written explanation of the reason for rejection of an absentee ballot to the voter whose absentee ballot is rejected within 90 days of the date on which the ballot is rejected.” Va. Code § 24.2-711.1(B). Virginia’s witness requirement will deny large numbers of Virginians the right to vote yet provides only marginal benefits for election integrity
71. As just noted, election officials currently have no discretion under the regulations promulgated by the Board as to whether to count an unwitnessed absentee ballot—they must reject such a ballot and are only obligated to inform the voter as such within 90 days after the ballot rejection.
72. Yet in the current pandemic, individuals living alone and not isolating with a potential witness in accordance with Executive Orders No. 53 and 55 have no safe means to have
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an individual witness and sign their ballot envelope. Under the Governor’s orders, individuals should maintain at least six feet of distance from others with whom they do not live. These orders also reflect the consensus of doctors and public health officials.
73. Older Virginians and those with certain preexisting medical conditions face even more grave risks by interacting with another individual to obtain a witness signature. But because COVID-19 can strike and kill individuals of any age and those without preexisting conditions, any individual living alone faces a real risk by seeking someone to witness their ballot.
74. Enforcing the witness requirement in an environment in which COVID-19 is still being transmitted will likely prevent thousands of eligible Virginians from casting ballots.
75. As of March 31, 2020, Virginia had over 5.73 million registered voters. In the June 2018 Democratic and Republican primaries, over 541,000 Virginians cast ballots. And in the November 2016 general election, over 3.98 million Virginians cast ballots. While many of these individuals voted in-person, the combination of the COVID-19 outbreak, the loosening of absentee voting excuse requirements, and the examples from states like Wisconsin—where absentee ballot requests were five times higher in this year’s primary than in the 2016 primary52—indicate that voting by mail will explode in Virginia this year.
52 Compare Absentee Ballot Report - April 7, 2020 Spring Election and Presidential Preference Primary, Wisc. Election Comm’n, https://elections.wi.gov/node/6833 (reporting over 1.28 million absentee ballots requested for April 7, 2020 primary) with Riley Vetterkind, Absentee ballot requests in Wisconsin already exceed number in recent spring elections, WISC. STATE JOURNAL (Mar. 18, 2020), https://madison.com/wsj/news/local/govt-andpolitics/absentee-ballot-requests-in-wisconsin-already-exceed-number-in-recent-spring-elections/article_dfb34fc56aa8-5428-90c3-26c3f82a1d70.html (noting that just under 250,000 absentee ballots were requested for spring 2016 Wisconsin primary).
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76. According to 2018 Current Population Survey (“CPS”) statistics from the Census Bureau,53 25.3% of Virginians age 18 and older live alone. Assuming similar numbers in the 2020 June primaries, over 136,000 Virginians will face the choice of either risking their health by voting in person or finding a witness for their absentee ballots, or not voting at all. For the general election, over a million Virginians will fall into this category. Like the individual Plaintiffs, many of them will be forced to risk their (and others’) health in order to vote.
77. To make matters worse, this burden on the right to vote will fall more heavily upon certain groups—older Virginians, Virginians with disabilities, and African American Virginians, among others.
78. Approximately 33% of Virginians age 65 and older live alone compared to 25.3% of the general population. 37.2% of Virginians 18 and older with a disability live alone and 44% of Virginians aged 65 and older with a disability live alone. 31% of African American Virginians 18 and older live alone versus only 24.7% of white Virginians 18 and older.
79. As noted above, older individuals already face higher rates of infection and death from COVID-19, further magnifying its impact. And the CDC has found that “some people with disabilities might be at a higher risk of infection or severe illness because of their underlying medical conditions.”54
80. Recent evidence also revealed racial disparities in the impact of COVID-19— disparities that will also likely transfer to burdens on voting. While Virginia is not yet fully
53 2018 Current Population Survey, U.S. Census Bureau, statistics accessed by using the Census Bureau Current Population Survey Table Creator tool at https://www.census.gov/cps/data/cpstablecreator.html.. 54 Centers for Disease Control and Prevention, People Who Need Extra Precautions: People with Disabilities, https://www.cdc.gov/coronavirus/2019-ncov/need-extra-precautions/people-with-disabilities.html (last visited Apr. 15, 2020).
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collecting COVID-19 data by race, both Maryland and North Carolina have released data showing that African Americans face higher rates of both infection and death from COVID-19 than the population as a whole.55
81. Virginia’s witness requirement will therefore likely prevent tens of thousands of Virginians who might otherwise cast absentee ballots from doing so this year, with a disproportionate impact on older Virginians, Virginians with a disability, and African American Virginians.
82. The witness requirement is particularly burdensome for African Americans in Virginia, who, as noted, are more likely to live alone and thus will be more likely to risk exposure to COVID-19 in the course of obtaining a witness signature. African Americans in Virginia continue to bear the effects of discrimination in areas such as education, employment, and health, which hinder their ability to participate effectively in the political process. It is precisely because of these patterns that African Americans in Virginia face particularly severe health risks from COVID-19 exposure. In these circumstances, the witness requirement interacts with these conditions to deny African Americans in Virginia an equal opportunity to participate in the political process.
83. While protecting election integrity and preventing improper use of absentee ballots certainly are valid governmental interests, maintaining the witness requirement during this pandemic fails to even serve this interest, let alone present a narrowly tailored method of doing so.
55 North Carolina Department of Health and Human Services, COVID-19 Cases in North Carolina By Race, https://www.ncdhhs.gov/divisions/public-health/covid19/covid-19-nc-case-count#by-race/ethnicity (last visited Apr. 15, 2020); Fenit Nirappil et al., Record set for single-day covid-19 deaths in D.C., Maryland and Virginia at 53; black residents hit hardest, WASH POST (Apr. 9, 2020, 3:47 PM), https://www.washingtonpost.com/local/covid-19deaths-hit-new-high-in-dc-maryland-and-virginia-at-53-black-residents-hit-hardest/2020/04/09/cc85cd14-77b311ea-b6ff-597f170df8f8_story.html.
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And to the extent it does serve these or any other governmental interests, it is substantially outweighed by its massive burden on Virginia voters and other Virginia procedures that serve the same interests.
84. The witness requirement is not Virginia’s sole method of policing the integrity of absentee ballots—far from it. Indeed, only 10 other states even contain such a requirement in their state laws yet the states without this requirement still have absentee balloting systems not undermined by fraud.56
85. Meanwhile, Virginia has several other mechanisms to both confirm the legitimacy of the absentee ballot cast and disincentivize fraudulent use of absentee ballots.
86. For one, the general registrar maintains a list of voters who applied for and returned absentee ballots, and that list is attested to by the secretary of the electoral board and delivered to the chief officer of election for each precinct. Absentee ballots are only accepted “from voters whose names appear on the attested list.” Va. Code § 24.2-710.
87. Most directly, voters themselves must attest under penalty of perjury their identity, residence, and that they did not double vote when they sign their ballot envelope. Va. Code § 24.2706.
88. Any individual who double votes or otherwise improperly uses an absentee ballot faces severe criminal penalties for violating their attestation: “Any person who intentionally (i) votes more than once in the same election . . . is guilty of a Class 6 felony.” Va. Code § 24.21004(B).
56 See Chart, “Verifying Authenticity of Absentee/Mailed Ballots,” Voting Outside the Polling Place: Absentee, AllMail and other Voting at Home Options, Nat’l Conf. of State Legislatures (Apr. 3, 2020), https://www.ncsl.org/research/elections-and-campaigns/absentee-and-early-voting.aspx.
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89. Additionally, any “willfully false material statement or entry made by any person in any statement, form, or report required by this title shall constitute the crime of election fraud and be punishable as a Class 5 felony.” Va. Code § 24.2-1016.
90. And “[a]ny person attempting to vote by fraudulently signing the name of a qualified voter shall be guilty of forgery and shall be guilty of a Class 4 felony.” Va. Code § 24.21012.
91. In light of these attestation and verification requirements and criminal penalties associated with misusing absentee ballots, the additional step of requiring a witness signature adds little on top of these safeguards. And while instances of fraud are rare, an individual determined to break these laws and risk the penalties can just as easily forge the signature of another individual as they can falsely attest when they sign their own name. Indeed, the witness requirement has little if any practical utility for election integrity because Virginia law does not require witnesses to identify themselves by printing their name or providing any other information and Board regulations instruct election officials to accept ballots even where the witness signature is illegible.
92. The burden on the voting rights of the many thousands of Virginians, including Plaintiffs, who will be prevented from either casting their ballots safely or having them counted by retaining the witness requirement far outweighs any upside of the requirement, if any.
CLAIMS FOR RELIEF COUNT I
Violation of the Fundamental Right to Vote 42 U.S.C. § 1983, First and Fourteenth Amendments to the U.S. Constitution 93. Eligible individuals have a fundamental right to vote under the First and Fourteenth Amendments of the United States Constitution. Under the First and Fourteenth Amendments, a
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court considering a challenge to a state election law must carefully balance the character and magnitude of the injury to the rights that the plaintiff seeks to vindicate against the justifications put forward for the burdens imposed by the rule. See Burdick v. Takushi, 504 U.S. 428, 434 (1992); Anderson v. Celebrezze, 460 U.S. 780, 789 (1983).
94. In light of the COVID-19 pandemic, Virginia’s witness requirement and its enforcement severely and unreasonably burdens the fundamental right to vote of Virginia voters. This requirement will likely prevent thousands of eligible Virginians from casting ballots, with particularly heavy burdens on older Virginians, Virginians with disabilities, and African American Virginians.
95. And while Virginia has a general interest in election integrity, the witness requirement does very little to advance this interest in light of the substantial other protections against fraudulent submission of ballots, let alone providing a narrowly tailored way to address this potential issue. Whatever interests the witness requirement may serve pales in comparison to the substantial burden on voters during the COVID-19 pandemic.
96. Therefore, Defendants, acting under color of state law, have and will continue to deprive Plaintiffs of rights secured to them by the First and Fourteenth Amendments to the United States Constitution— namely, the fundamental right to vote—and protected by 42 U.S.C. § 1983 by enforcing the witness requirement.
COUNT II Violations of Section 2 of the Voting Rights Act, 52 U.S.C. § 10301 97. Section 2 of the Voting Rights Act provides in part that “[n]o voting qualification or prerequisite to voting or standard, practice, or procedure shall be imposed or applied by any
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State . . . in a manner which results in a denial or abridgement of the right of any citizen of the United States to vote on account of race or color.” 52 U.S.C. § 10301(a).
98. The “essence of a [Section] 2 claim is that a certain electoral law, practice, or structure interacts with social and historical conditions to cause an inequality in the opportunities enjoyed by black and white voters to elect their preferred representatives.” League of Women Voters of N.C. v. North Carolina, 769 F.3d 224, 238–39 (4th Cir. 2014) (internal quotation marks and citation omitted). “[A] Section 2 vote-denial claim consists of two elements:
First, the challenged standard, practice, or procedure must impose a discriminatory burden on members of a protected class, meaning that members of the protected class have less opportunity than other members of the electorate to participate in the political process and to elect representatives of their choice. Second, that burden must in part be caused by or linked to social and historical conditions that have or currently produce discrimination against members of the protected class. Id. at 240 (internal quotation marks and citations omitted). 99. The witness requirement, if not declared illegal and enjoined, will materially burden the right to vote, and will have an adverse and disparate impact on African-American voters in Virginia. African Americans in Virginia are more likely to suffer from severe health complications and to die from COVID-19, and are therefore more significantly burdened by the witness requirement. 100. This disparate burden resulting from the witness requirement is directly linked to social and historical conditions. Virginia has a long history of voting-related discrimination. African Americans in Virginia continue to suffer from discrimination in areas such as education, employment, and health, which hinders their ability to participate effectively in the political process. In particular, these discriminatory patterns render African Americans more vulnerable to
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COVID-19, such that the witness requirement is particularly burdensome for them as a group relative to other voters.
101. Under the totality of the circumstances, the witness requirement interacts with these social and historical conditions to abridge and deny African Americans in Virginia the right to vote. As a result of the witness requirement, African Americans in Virginia will have less opportunity than other members of the electorate to participate in the political process and to elect representatives of their choice.
RELIEF REQUESTED WHEREFORE, Plaintiffs respectfully requests that this Court: A. Declare that Virginia’s enforcement of the witness requirement (as stated in Va. Code
§ 24.2-706 and § 24.2-707 and as interpreted by 1 Va. Admin. Code 20-70-20(B)) while emergency orders by Virginia or federal authorities regarding COVID-19 transmission are in effect and/or while public health officials continue to recommend social distancing practices due to risk of community transmission of COVID-19 violates the fundamental right to vote under First and Fourteenth Amendments to United States Constitution as well as Section 2 of the Voting Rights Act; B. Issue a preliminary and permanent injunction that orders relief including:
1. Prohibiting Defendants from enforcing the witness requirement (as stated in Va. Code § 24.2-706 and § 24.2-707 and as interpreted by 1 Va. Admin. Code 20-70-20(B)) for all voters, especially for voters at risk of health complications arising from COVID-19 exposure, while emergency orders concerning COVID-19 are in place and/or while public health officials continue to
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recommend social distancing practices due to risk of community transmission of COVID-19; 2. Ordering Defendants to issue guidance instructing city and county election officials to count otherwise validly cast absentee ballots that are missing a witness signature for Virginia’s primary and general elections in 2020; and 3. Ordering Defendants to conduct a public information campaign informing Virginia voters about the elimination of this requirement, in coordination with city and county election officials; C. Award Plaintiffs attorneys’ fees in this action; D. Award Plaintiffs their costs of suit; and E. Grant such other and further relief as this Court deems just and proper in the circumstances.

Dated: June 15, 2020
Davin M. Rosborough (VSB # 85935) Dale E. Ho* Sophia Lin Lakin* Theresa J. Lee* Adriel I. Cepeda-Derieux* American Civil Liberties Union Foundation 125 Broad Street, 18th Floor New York, NY 10004 Tel.: (212) 549-2500 drosborough@aclu.org dho@aclu.org slakin@aclu.org tlee@aclu.org acepedaderieux@aclu.org

Respectfully submitted,
/s/ Vishal Agraharkar __ Vishal Agraharkar (VSB #93265) Eden Heilman (VSB #93554) AMERICAN CIVIL LIBERTIES UNION FOUNDATION OF VIRGINIA, INC. 701 E. Franklin Street, Suite 1412 Richmond, Virginia 23219 Phone: (804) 644-8080 Fax: (804) 649-2733 vagraharkar@acluva.org eheilman@acluva.org
Attorneys for Plaintiffs * Admitted pro hac vice

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UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA
Lynchburg Division

LEAGUE OF WOMEN VOTERS OF

VIRGINIA;

KATHERINE

D.

CROWLEY; SEIJRA TOOGOOD;

GAYLE HARDY; CAROL D.

PETERSEN; and TRACY SAFRAN,

Plaintiffs,

v.

VIRGINIA STATE BOARD OF ELECTIONS; ROBERT H. BRINK, JOHN O’BANNON, and JAMILAH D. LECRUISE, in their official capacities as Chairman, Vice-Chair, and Secretary of the Virginia State Board of Elections, respectively; and CHRISTOPHER E. PIPER, in his official capacity as Commissioner of the Virginia Department of Elections,

Defendants.

Case No.: 6:20-cv-00024-NKM
SECOND AMENDED COMPLAINT FOR INJUNCTIVE AND DECLARATORY RELIEF

1. Virginia Attorney General Mark Herring recently said that “[f]ree and fair elections are at the core of our democracy and no Virginian should have to choose between their health and exercising their right to vote.”1 Plaintiffs League of Women Voters of Virginia, Katherine Crowley, and Seijra Toogood agree. Yet Virginia’s requirement that each voter submitting a mail absentee ballot have another individual witness and sign their ballot envelope
1 Press Release, Ralph Northam, Governor of Virginia, Governor Northam Announces Plans to Postpone Upcoming Virginia Elections in Response to COVID-19 (Apr. 8, 2020), https://www.governor.virginia.gov/newsroom/allreleases/2020/april/headline-855995-en.html.

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does exactly that: presents tens of thousands of Virginia voters like Plaintiffs with the Hobson’s choice of either risking their health to vote or not voting at all.
2. Plaintiffs therefore bring this action challenging the constitutionality of Virginia’s witness requirement on absentee ballots to preserve their and many other Virginians’ fundamental right to vote in the midst of the pandemic of a respiratory disease known as the coronavirus disease 2019 (“COVID-19”), caused by the spread of a novel coronavirus, SARSCoV-2. Without relief, the extreme burden the witness requirement places on voters in the current environment far outweighs any marginal benefit to the Commonwealth in retaining it.
3. The “United States is now the ‘epicenter’ of the global pandemic and has far more confirmed COVID-19 cases than any other nation.”2 The Centers for Disease Control and Prevention (“CDC”) and the Virginia Department of Health have both urged people to avoid coming within six feet of individuals with whom they do not reside, as a key to both slowing the spread of the virus and keeping individuals healthy. As such, Governor Ralph Northam has ordered that all Virginians remain at home except for the basic necessities through at least June 10, 2020.3
4. In the midst of this crisis and especially during a stay-at-home mandate, Virginia’s requirement that every individual filling out an absentee ballot find another adult to witness their filling out of the ballot and sign on their ballot envelope alongside the voter’s own signed attestation amounts to an unconstitutional burden on the right to vote. This is certainly true for
2 General Order No. 2020-11, In re: Court Operations Under the Exigent Circumstances Created by the Outbreak of Coronavirus Disease (COVID-19): Temporary Policy for Remote Proceedings and Public Access to Such Proceedings (hereinafter “In re Court Operations”), Case No. 2:20mc7 (E.D. Va. Apr. 6, 2020). 3 See Va. Executive Order No. 2020-55, https://www.governor.virginia.gov/media/governorvirginiagov/executiveactions/EO-55-Temporary-Stay-at-Home-Order-Due-to-Novel-Coronavirus-(COVID-19).pdf
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Virginia’s federal office primaries in June, and will likely be true for voting in the November general election as well.
5. The COVID-19 outbreak means that the witness requirement will disenfranchise many thousands of Virginians like the individual Plaintiffs who cannot risk contact with other individuals to vote in person or obtain a witness signature on their absentee ballot. Over a quarter of Virginians age 18 and over live by themselves, and almost a third of Virginians over 65 years of age—one of the groups most vulnerable to COVID-19—live alone.4 And the impact of this requirement will also fall more heavily on Virginians with disabilities and African Americans, who both live alone in larger percentages than the population as a whole.5
6. The witness requirement mostly directly and disproportionately harms African Americans during the COVID-19 pandemic, though, because they face greater rates of severe health complications and death from COVID-19. Virginia’s history of voting-related discrimination against African Americans, as well as continuing discrimination in areas such as education, employment, and health, interacts with the witness requirement to hinder their ability to participate effectively in the political process in violation of Section 2 of the Voting Rights Act.
7. Over half a million Virginians cast ballots in the June 2018 Democratic and Republican primaries, and over 3.98 million Virginians cast ballots in the November 2016 general election. The Virginians who live alone and would have otherwise voted in the upcoming elections but will not, or those whose absentee ballots will be rejected, will therefore likely
4 2018 Current Population Survey, U.S. Census Bureau, statistics accessed by using the Census Bureau Current Population Survey Table Creator tool at https://www.census.gov/cps/data/cpstablecreator.html. 5 Id.
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number in the tens of thousands, if not hundreds of thousands, given the likely explosion of voting by mail this year.
8. The witness requirement is not worth this massive disenfranchisement of Virginia voters and its disproportionate harm to elderly voters, African American voters, and voters with disabilities. While election integrity is an important interest, the witness requirement does very little if anything—and it is certainly not narrowly tailored—to serve this interest in light of the many other provisions of Virginia law that safeguard absentee voting and penalize those who abuse the process. The fact that Virginia is one of only 11 states that require an individual submitting an absentee ballot to have a witness sign their ballot envelope further underscores the requirement’s lack of necessity. Regardless, whatever additional marginal benefits the witness requirement may offer, such benefit is greatly outweighed by the risk of disenfranchisement. The lack of an opportunity to cure a missing witness signature further compounds the burden.
9. Plaintiffs therefore ask that the Court enjoin Virginia’s absentee witness requirement and declare it unconstitutional and in violation of Section 2 of the Voting Rights Act for this year’s elections.
PARTIES 10. Plaintiff Katherine D. Crowley is a resident of Lexington, Virginia, where she is a registered voter. She has been a Virginia registered voter for many years and has consistently voted in both state and federal elections. She lives in Virginia’s Sixth congressional district, where there is no congressional primary this year, but she intends to vote in the November 2020 general election. 11. Because of the COVID-19 outbreak, Ms. Crowley does not feel safe voting in person for the November election because COVID-19 community transmission will continue to
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persist and may even have a greater resurgence during that time frame. Because of this, she intends to vote by absentee ballot in November and any future elections during which COVID-19 transmission presents a risk to her health, but she lives by herself and does not feel safe finding an individual to witness and sign her absentee ballot envelope. This is because she not only intends to follow any stay-at-home order if in place and continues to practice social distancing, but also because she has a previous medical diagnosis that she is concerned may put her at a higher risk for heightened medical consequences if she contracts COVID-19. Therefore, to vote in November, Ms. Crowley will need to undertake the burden of finding a witness and risk her health if the witness requirement remains in place. If the witness requirement is lifted, she will be able to vote safely by absentee ballot in the November general election.
12. Plaintiff Seijra Toogood is a resident of Fairfax, Virginia, where she is a registered voter. She has been a Virginia registered voter for many years and has consistently voted in both state and federal elections. She lives in Virginia’s Eleventh congressional district and would like to vote in the June 23, 2020 primary election being held for that district.
13. Because of the COVID-19 outbreak, Ms. Toogood does not feel safe voting in person. She voted by absentee ballot for the June 23 primary and was able to do so safely because of the partial consent decree in this case, since she lives by herself and did not feel safe finding an individual to witness and sign her absentee ballot envelope. This is because she was not only following the Governor’s stay-at-home order and was practicing and continues to practice social distancing, but also because she has an underlying heart condition and asthma that put her at a higher risk for contracting COVID-19 and facing serious medical consequences if she does. Similarly, because COVID-19 community transmission will continue to persist and may even have a greater resurgence around the time of the November general election and she is
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concerned about lines at the polling place as she has experienced in the past, she intends to vote by absentee ballot in that election. But Ms. Toogood does not feel safe finding an individual to witness her ballot since she lives alone and has asthma and a heart condition, so will have to risk her health and undergo the burden of finding a witness in order to vote in November. If the witness requirement is lifted, she will be able to vote safely by absentee ballot in the November general election and any future elections during which COVID-19 transmission presents a risk to her health. As a Black Virginian, Ms. Toogood is also aware of the ongoing history of voting, economic, and health discrimination against Black Virginians, and believes the witness requirement perpetuates and worsens this discrimination. And as a Fairfax NAACP member, she is aware of the disproportionate impact COVID-19 has had on Black Virginians and how maintenance of the witness requirement will harm Black Virginians disproportionately.
14. Plaintiff Gayle Hardy is a resident of Henrico County, Virginia, where she is a registered voter. She regularly votes in elections and she has done so mostly in-person in the past.
15. Because of the COVID-19 outbreak, Ms. Hardy does not feel safe voting inperson for the November election. She is 61 years old and has been treated for breast cancer and has a diagnosis of rheumatoid arthritis, both of which she understands increase her risks for severe consequences from COVID-19. Since the COVID-19 outbreak began, she has been practicing social distancing and rarely leaves her home. Therefore, she intends to vote by absentee ballot for the November election. Ms. Hardy lives by herself, however, so finding a witness for her absentee ballot during the pandemic would be both burdensome and dangerous. She does not know what she will do if the witness requirement is in place for the November election. She also is particularly concerned about the significant number of asymptomatic
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individuals who nonetheless have COVID-19 and can transmit it, so does not believe there is a “safe” option for having a witness stand by for several minutes while she fills out her ballot and then sign her ballot envelope. Although she might consider asking her best friend to serve as a witness, her friend also has health problems and she does not want to put either herself or her friend at risk.
16. Plaintiff Carol D. Petersen is a resident of Arlington, Virginia, where she is a registered voter. She regularly votes in elections and she has done so mostly in-person in the past.
17. Because of the COVID-19 outbreak, Ms. Petersen does not feel safe voting inperson for the November election. She will be 64 years old in October, and has an auto-immune disorder as well as high-blood pressure, both of which place her at a higher risk for contracting COVID-19 and facing serious medical consequences if she does. Because COVID-19 community transmission will continue to persist and may even have a greater resurgence around the time of the November general election, she intends to vote by absentee ballot in that election. Ms. Petersen lives by herself, has been teleworking full-time since mid-March, continues to practice social distancing, and has had very limited interactions with other people. If the witness requirement remains in place for the November general election, she will be forced to undertake significant burdens and risk her health to find an individual outside of her home to witness her absentee ballot.
18. Plaintiff Tracy Safran is a resident of Woodbridge, Virginia, where she is a registered voter. She regularly votes in elections and she has done so mostly in-person in the past.
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19. Because of the COVID-19 outbreak, Ms. Safran does not feel safe voting inperson for the November election. In recent years, her polling place has had extremely long lines, which further dissuade her from that option. She is in her mid-50s, lives by herself, and has had asthma her whole life, takes daily medication for it, and has been hospitalized for it in the past. She is also being treated for high blood pressure. Both of these conditions put her at a higher risk for serious complications from COVID-19. Since COVID-19 community transmission will continue to persist and may even have a greater resurgence around the time of the November general election, Ms. Safran would like to vote by absentee ballot in that election. But because she lives by herself and has strictly practiced social distancing, the witness requirement will force her to undertake significant burdens and risk her health to find an individual outside of her home to witness her absentee ballot. In fact, although Ms. Safran requested an absentee ballot for the June 23 primary, she ultimately did not vote in that election solely because she thought the witness requirement was still in place and she did not believe she could safely comply.
20. Plaintiff League of Women Voters of Virginia (“the League”) is a nonprofit, nonpartisan membership organization that was founded in 1920. Its principal address is 1011 E. Main Street, Ste. 214A, Richmond, VA 23219.
21. The League works to encourage informed and active participation in government and influence public policy through education and advocacy. The League supports full voting and representational rights for all eligible Commonwealth citizens and promotes policies that encourage voter participation. The League has nearly 2,000 members across Virginia, some of whom live alone and are vulnerable to becoming severely ill from COVID-19 because they are elderly and/or have underlying health conditions. Certain of these members will seek to vote
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absentee in upcoming elections but will be unable to comply with the witness requirement without placing their own health at risk.
22. The League regularly conducts voter registration and get-out-the-vote activities for thousands of voters across the state, and in recent weeks it has been advocating through letters and calls to state officials for expanded use of absentee voting by mail and elimination of the witness requirement in order to better protect the health of voters and poll workers during the COVID-19 outbreak. The League anticipates that it will have to divert additional resources from its regular activities to advocate for lifting the requirement and to conduct outreach to its members and the voters they serve to ensure they understand and can find ways to comply with the requirements if possible.
23. Defendant Virginia State Board of Elections (the “Board”) is the regulatory authority authorized to make rules and regulations that, consistent with election laws, govern the work of local electoral boards, general registrars, and officers of election in properly administering elections in Virginia. Through the Department of Elections, it is also responsible for supervising and coordinating the work of the county and city electoral boards and registrars to ensure uniformity in their practices, as well as ensuring that electoral boards and general registrars are properly trained to carry out their duties. The Board also prescribes forms for voter registration and elections. See Va. Code § 24.2-103(a); Va. Code § 24.2-105. The Board sets standards that “tightly regulate[]” the “form of ballots used in Virginia elections.” Marcellus v. State Bd. of Elections, 849 F.3d 169, 172 (4th Cir. 2017).
24. Defendant Robert H. Brink is the Chairman of the Virginia Board of Elections. As Chairman, he is responsible for presiding over Board meetings and performing the functions of a
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presiding officer. As a member of the Board, he is also one of three individuals responsible for the actions of the Board. 1 Va. Admin. Code 20-20-30. He is sued in his official capacity.
25. Defendant John O’Bannon is the Vice-Chair of the Virginia Board of Elections. As Vice-Chair, he is responsible for performing the Board Chairman’s duties in the Chairman’s absence. As a member of the Board, he is also one of three individuals responsible for the actions of the Board. 1 Va. Admin. Code 20-20-30. He is sued in his official capacity.
26. Defendant Jamilah D. Lecruise is the Secretary of the Virginia Board of Elections. As Secretary, she is “authorized to do all things necessary to the proper execution of the law creating and governing the board and in the performance of the duties imposed upon it” so long as they are not such as they can only be performed “by the board in its corporate capacity.” 1 Va. Admin. Code 20-20-30. She also has the “authority to conduct the board’s administrative and programmatic operations and to discharge the board’s duties consistent with specific delegations of authority.” 1 Va. Admin. Code 20-20-60. As a member of the Board, she is also one of three individuals responsible for the actions of the Board. She is sued in her official capacity.
27. Defendant Christopher E. Piper is the Commissioner of the Virginia Department of Elections (the “Department”). The Department conducts the Board’s administrative and programmatic activities and discharges the Board’s duties within its delegated authority. The Department is also responsible for administering and maintaining the Commonwealth’s voter registration system and overseeing registered voter list maintenance, and for providing electronic applications for voter registration and absentee ballots. As Commissioner, Defendant Piper is responsible for overseeing the day-to-day operations of the Department. He also has powers “to designate alternative methods and procedures to handle” absentee applications and ballots “in the case of an emergency that will not allow sufficient time for the distribution and handling of
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absentee ballot applications and absentee ballots . . . for qualified voters who are unable to vote in person because of the emergency.” Va. Code § 24.2-713. He is sued in his official capacity.
JURSIDICTION AND VENUE 28. This action arises under the First and Fourteenth Amendments to the U.S. Constitution as well as Section 2 of the Voting Rights Act, and is brought under 42 U.S.C. §§ 1983 and 1988 and authorized under 52 U.S.C. § 10302 to seek injunctive and declaratory relief for violations of constitutional and statutory rights under color of state law. This Court therefore has subject matter jurisdiction under 28 U.S.C. §§ 1331 and 1343. 29. This Court has personal jurisdiction over Defendants because each is either a state agency or sued in their official capacity as a state official, and the violations complained of concern their conduct in such capacities. 30. Declaratory relief is authorized by 28 U.S.C. §§ 2201 and 2202. 31. Venue in the Western District of Virginia is proper based on 28 U.S.C. § 1391(b)(2) because a substantial part of the events that gave rise to Plaintiffs’ claims occurred or will occur there, including concerning Plaintiff Crowley (City of Lexington) who resides there.
FACTS Transmission of COVID-19 and Public Health Guidelines
32. The novel coronavirus, SARS-CoV-2, is the virus that causes COVID-19, a deadly disease that is now a global pandemic.6
6 Betsy McKay et al., Coronavirus Declared Pandemic by World Health Organization, WALL ST. J. (Mar. 11, 2020, 11:59 PM), https://www.wsj.com/articles/u-s-coronavirus-cases-top-1-000-11583917794.
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33. According to the CDC, this coronavirus spreads aggressively and asymptomatic people can spread it.7 All age groups have contracted the disease.8 There is no vaccine, and there
is no cure.
34. As of early April, the United States led the world in the total number of COVID-
19 cases, surpassing even China and Italy before spread of the virus has even peaked. As many
as 240,000 people in the United States may die from COVID-19 during the current outbreak, even accounting for existing governmental and public health interventions.9
35. The World Health Organization (“WHO”) estimates that approximately 20 percent of those infected by SARS-CoV-2 require hospitalization.10 This is because COVID-19
can severely damage lung tissue, cause a permanent loss of respiratory capacity, and also damage tissues in the kidney, heart, and liver.11
36. Despite some initial comparisons to seasonal influenza, estimates from early
March put the fatality rate for people infected with COVID-19 at approximately ten times higher than even a severe flu season, including in countries with advanced health care systems.12
7 Centers for Disease Control and Prevention, How Coronavirus Spreads, https://www.cdc.gov/coronavirus/2019ncov/prevent-getting-sick/how-covid-spreads.html (last visited Apr. 15, 2020). 8 Robert Verity, PhD., et al., Estimates of the Severity of Coronavirus Disease 2019: A Model-Based Analysis, Lancet Infec Dis (March 30, 2020), 6. 9 Rick Noack, et al., White House Task Force Projects 100,000 to 240,000 Deaths in U.S., Even With Mitigation Efforts, WASH. POST (April 1, 2020, 12:02 am), https://www.washingtonpost.com/world/2020/03/31/coronaviruslatest-news/. 10 World Health Organization, Q&A on Coronaviruses (COVID-19), “Should I Worry About COVID-19?,” https://www.who.int/news-room/q-a-detail/q-a-coronaviruses. 11 Centers for Disease Control and Prevention, Interim Clinical Guidance for Management of Patients with Confirmed Coronavirus Disease (COVID-19), https://www.cdc.gov/coronavirus/2019-ncov/hcp/clinical-guidancemanagement-patients.html (last visited Apr. 15, 2020). 12 Betsy McKay, Coronavirus vs. Flu Which Virus is Deadlier, WALL ST. J. (Mar. 10, 2020, 12:49 PM), https://www.wsj.com/articles/coronavirus-vs-flu-which-virus-is-deadlier-11583856879.
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37. While people of all ages have contracted and died from COVID-19, it is particularly fatal for older individuals. Preliminary reports based on WHO data show a 3.6% mortality rate for individuals between 60-69 years old, an 8% mortality rate for those 70-79 years old, and a 14.8% mortality rate for those who are 80 years old or older.13 COVID-19 also poses greater risks for people with preexisting heart and respiratory conditions, individuals with compromised immune systems, and those with many other conditions.14
38. The effects of the pandemic on social life will last well into the summer of 2020, if not much longer. While there is some reason to believe that transmission may taper somewhat in the summer months, experts have indicated that COVID-19 “will face less immunity and thus transmit more readily even outside of the winter season,” and that season changes are “unlikely to stop transmission.”15 Further, even those who develop an immune response to the virus after an infection are not necessarily safe from reinfection, as we do not yet have sufficient data about how long immunity to the virus will last.16 This week, Dr. Anthony Fauci, head of the National
13 Centers for Disease Control and Prevention, Interim Clinical Guidance for Management of Patients with Confirmed Coronavirus Disease (COVID-19), https://www.cdc.gov/coronavirus/2019-ncov/hcp/clinical-guidancemanagement-patients.html (last visited Apr. 15, 2020). 14 Centers for Disease Control and Prevention, Groups at Higher Risk of Severe Illness, https://www.cdc.gov/coronavirus/2019-ncov/need-extra-precautions/groups-at-higher-risk.html (last visited Apr. 15, 2020). 15 Marc Lipsitch, DPhil, Professor of Epidemiology and Director, Center for Communicable Disease Dynamics, Harvard T.H. Chan School of Public Health, Seasonality of SARS-CoV-2: Will COVID-19 go away on its own in warmer weather?, https://ccdd.hsph.harvard.edu/will-covid-19-go-away-on-its-own-in-warmer-weather/. 16 Apoorva Mandavilli and Katie Thomas, Will an Antibody Test Allow Us to Go Back to School or Work?, N.Y. TIMES (Apr. 11, 2020), https://www.nytimes.com/2020/04/10/health/coronavirus-antibody-test.html
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Institute of Allergy and Infectious Diseases, said that he “can’t guarantee” in-person voting will be safe in November, because of a potential resurgence of COVID-19 in the fall.17
39. Because there is no vaccine, social distancing measures, including maintaining at least six feet of space between people (as well as consistent hygiene practices), are the only known effective measures for protecting against transmission of COVID-19.18 The CDC has issued guidance informing individuals to avoid public gatherings until at least May 15, 2020.
40. For this reason, the CDC has issued specific guidelines concerning voting during the COVID-19 pandemic. Among other things, it recommends that states “[e]ncourage voters to use voting methods that minimize direct contact with other people and reduce crowd size at polling stations” including “mail-in methods of voting if allowed in the jurisdiction.”19
41. These recommendations make sense, given the relative risks of voting in person during the pandemic versus voting by mail. There is no evidence that SARS-CoV-2 can be spread through the mail, and the U.S. Postal Service has further changed their policies to “eliminate the requirement that customers sign our Mobile Delivery Devices for delivery” and
17 Jason Silverstein, Fauci says he “can’t guarantee” in-person voting in November will be safe, CBSNews.com (Apr. 13, 2020), https://www.cbsnews.com/news/coronavirus-fauci-says-he-cant-guarantee-in-person-voting-innovember-will-be-safe/?ftag=CNM-00-10aac3a. 18 Johns Hopkins University, Coronavirus, Social Distancing and Self-Quarantine, https://www.hopkinsmedicine.org/health/conditions-and-diseases/coronavirus/coronavirus-social-distancing-andself-quarantine (last visited Apr. 15, 2020); Declaration of Dr. Jonathan Louis Golob at ¶ 8, ECF No. 5, Dawson v. Asher, 2:20-cv-00409-JLRMAT (W.D. Wash. Mar. 16, 2020). 19 Centers for Disease Control & Prevention, Recommendations for Election Polling Locations: Interim guidance to prevent spread of coronavirus disease 2019 (COVID-19) (updated Mar. 27, 2020), https://www.cdc.gov/coronavirus/2019-ncov/community/election-polling-locations.html.
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now require the customer “to step back a safe distance or close the screen door/door so that they may leave the item in the mail receptacle or appropriate location by the customer door.”20
42. In contrast, the risks of interpersonal interaction while voting have already borne
out unfortunate results. In Illinois, a person who worked at a Chicago polling place during the March 17 primary died from COVID-19,21 while another tested positive after voting in person.22
And during Florida’s recent primary, two Broward County poll workers tested positive for
COVID-19, one of whom was handling driver’s licenses as part of the identification verification process.23
43. In Milwaukee and Green Bay, Wisconsin, voters experienced multi-hour waits
and lines stretching blocks upon blocks because government officials there were unable to create a viable vote-by-mail process for all voters.24 These are the opposite of constitutionally
20 United States Postal Service. USPS Statement on Coronavirus (Apr. 2, 2020), https://about.usps.com/newsroom/statements/usps-statement-on-coronavirus.htm (citing guidance from World Health Organization, CDC, and Surgeon General) 21 Mary Ann Ahern, Poll Worker at Chicago Voting Site Dies of Coronavirus, Election Officials Say, NBC CHICAGO (Apr. 13, 2020, 10:59 AM), https://www.nbcchicago.com/news/local/chicago-politics/poll-worker-at-chicagovoting-site-dies-of-coronavirus-election-officials-say/2255072/. 22 Gov. Pritzker Encourages Illinoisans to Vote by Mail After In-Person Voter Tests Positive for Coronavirus, NBC CHICAGO (Apr. 12, 2020, 6:07 PM), https://www.nbcchicago.com/news/local/gov-pritzker-encourages-illinoisansto-vote-by-mail-in-upcoming-general-election/2254687/.. 23 Anthony Man, Two Broward poll workers, including one who handled voters’ driver licenses, test positive for coronavirus, S. FLA. SUN SENTINEL (Mar. 26, 2020), https://www.sun-sentinel.com/coronavirus/fl-ne-browardelections-poll-workers-coronavirus-20200326-wmgy775dvjc5jis2oagxlpmule-story.html. 24 Parker Schorr, Wisconsin’s pandemic election: Long waits, face masks as voters go to polls, THE CAP TIMES (Apr. 8, 2020), https://madison.com/ct/news/local/govt-and-politics/wisconsin-s-pandemic-election-long-waits-facemasks-as-voters-go-to-polls/article_bfd2c391-f390-5364-8c14-a88b548fe017.html; Benjamin Swasey, Wisconsin Vote Ends As Trump Blames Governor For Long Lines, NPR (Apr. 7, 2020 12:23 PM), https://www.npr.org/2020/04/07/828835153/long-lines-masks-and-plexiglas-barriers-greet-wisconsin-voters-atpolls.
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appropriate conditions called for in an infectious disease pandemic.25 Virginia must not emulate them. COVID-19 in Virginia
44. Virginia faces a steadily rising number of COVID-19 cases. As of March 31, the Virginia Department of Health (“VDH”) was reporting “widespread community transmission across the state.”26 And as of April 16, VDH reported 6,889 COVID-19 diagnoses in Virginia, resulting in 1,114 hospitalizations and 208 deaths.27 Moreover, as of late March, “Virginia’s fatality rate, based on the number of known cases, is relatively higher than many other states” and “insufficiency of current testing suggests the likelihood that COVID-19 is substantially more widespread in Virginia than it appears from the official numbers.”28 Tragically, one of the nation’s deadliest COVID-19 outbreaks appears to have occurred at an assisted living center in Richmond, where at least 45 residents have died and around 80 percent have been diagnosed as positive.29
45. VDH has “urge[d] all Virginians to stay home and practice social distancing. If you have to go out for critical things like grocery shopping or medical care, stay at least 6 feet
25 Devi Shastri, In-person voting was likely a ‘disaster’ for Wisconsin’s efforts to flatten coronavirus curve, national experts say, MILWAUKEE JOURNAL SENTINEL (Apr. 8, 4:51 PM), https://www.jsonline.com/story/news/politics/elections/2020/04/08/coronavirus-wisconsin-election-likely-hurteffort-flatten-curve/2961718001/. 26 Va. Dep’t of Health, COVID-19 Cases in Virginia, http://www.vdh.virginia.gov/coronavirus/ (last visited Apr. 16, 2020). 27 Id. 28 In re Extension to Modifications of Ct. Operations: S. to Gen. Orders 2020-02 and 2020-03, No. 2:20MC7, 2020 WL 1441770, at *1 (E.D. Va. Mar. 24, 2020). 29 Danielle Ivory, et al., N.Y. TIMES, Coronavirus Outbreak at Virginia Nursing Home Spirals Out of Control as 45 Die (Apr. 14, 2020), https://www.nytimes.com/2020/04/14/us/coronavirus-nursing-homes.html.
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away from others.”30 It has also adopted “Guiding Principles for Community Mitigation Strategies” based on similar CDC guidance. Among these principles are considering “all aspects of a community that might be impacted, including populations most vulnerable to severe illness and those that may be more impacted socially or economically, and select appropriate actions,” and identifying “ways to ensure the safety and social well-being of groups that may be especially impacted by mitigation strategies, including individuals at increased risk for severe illness.”31
46. Since early March, Governor Northam has also taken a series of increasingly aggressive actions in response to the growing threat posed by the virus, including an emergency declaration and numerous executive orders.
47. Notably, on March 12, 2020, invoking his statutory and Virginia constitutional authority, Governor Northam declared a State of Emergency for Virginia “to continue to prepare and coordinate our response to the potential spread of COVID-19, a communicable disease of public health threat.”32
48. On March 13, he closed all Virginia K-12 schools for a minimum of two weeks, and eventually extended that order for the remainder of the academic year.33
30 Id. 31 Virginia Department of Health, Schools, Workplaces & Community Locations, http://www.vdh.virginia.gov/coronavirus/schools-workplaces-community-locations/ (last visited Apr. 15, 2020). 32 Va. Exec. Order No. 2020-51 (Mar. 12, 2020), https://www.governor.virginia.gov/media/governorvirginiagov/governor-of-virginia/pdf/eo/EO-51-Declaration-of-aState-of-Emergency-Due-to-Novel-Coronavirus-(COVID-19).pdf. 33 Press Release, Ralph Northam, Governor of Virginia, Governor Northam Orders All Virginia K-12 Schools Closed for Minimum of Two Weeks (Mar. 13, 2020), https://www.governor.virginia.gov/newsroom/allreleases/2020/march/headline-854442-en.html; Press Release, Ralph Northam, Governor of Virginia, Governor Northam Orders Statewide Closure of Certain Non-Essential Businesses, K-12 Schools (Mar. 23, 2020), https://www.governor.virginia.gov/newsroom/all-releases/2020/march/headline-855292-en.html.
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49. Governor Northam advised on March 17 that Virginians “with chronic health conditions or aged 65 or older should self-quarantine,” and ordered all DMV offices closed.34 He also requested and the Supreme Court of Virginia granted a suspension of “non-emergency court proceedings in all district and circuit courts” absent specific exceptions through April 6, and extended and tolled non-exempted court deadlines for 21 days.35
50. On March 23, Governor Northam ordered all non-essential businesses closed until at least April 23 and banned public gatherings of more than 10 people.36
51. On March 30, Governor Northam issued a statewide “Stay at Home” order to last at least until June 10, directing all Virginians to stay at home except under extremely limited circumstances. He added: “We are in a public health crisis, and we need everyone to take this seriously and act responsibly. Our message to Virginians is clear: stay home. We know this virus spreads primarily through human-to-human contact, and that’s why it’s so important that people follow this order and practice social distancing.”37
34 Press Release, Ralph Northam, Governor of Virginia, Governor Northam Announces New Measures to Combat COVID-19 and Support Impacted Virginians (Mar. 17, 2020), https://www.governor.virginia.gov/newsroom/allreleases/2020/march/headline-854487-en.html. 35 Id. 36 Press Release, Ralph Northam, Governor of Virginia, Governor Northam Orders Statewide Closure of Certain Non-Essential Businesses, K-12 Schools (Mar. 23, 2020), https://www.governor.virginia.gov/newsroom/allreleases/2020/march/headline-855292-en.html. 37 Va. Exec. Order No. 2020-55 (Mar. 30, 2020), https://www.governor.virginia.gov/media/governorvirginiagov/executive-actions/EO-55-Temporary-Stay-at-HomeOrder-Due-to-Novel-Coronavirus-(COVID-19).pdf; Press Release, Ralph Northam, Governor of Virginia, Governor Northam Issues Statewide Stay at Home Order (Mar. 30, 2020), https://www.governor.virginia.gov/newsroom/allreleases/2020/march/headline-855702-en.html (emphasis added).
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52. April 2.38

Virginia received a Major Disaster Declaration from the federal government on

53. Just this week, researchers at the University of Virginia projected that COVID-19 cases in Virginia may not peak until mid-August.39

54. Faced with local elections in some parts of Virginia scheduled for May, and a

primary for federal races in June, both the Governor and Elections Department have begun to

take some steps in recognition of the dual priorities of public health and representative

government.

55. For one, the Virginia Department of Elections has issued guidance that all

registered Virginia voters may vote absentee by mail in the June primary (and May elections if

they go forward) due to the COVID-19 outbreak by selecting reason “2A My disability or illness” on the ballot application.40 Defendants have further encouraged Virginians to use this

option, with the Department of Elections “encourag[ing] voters to protect their health during

COVID-19 outbreak,” and noting that absentee voting for the upcoming elections “is strongly encouraged.”41

38 Press Release, Ralph Northam, Governor of Virginia, Virginia Receives Major Disaster Declaration from Federal Government for COVID-19 (Apr. 2, 2020), https://www.governor.virginia.gov/newsroom/allreleases/2020/april/headline-855921-en.html. 39 Mel Leonor & Justin Mattingly, UVA researchers project mid-August peak for new COVID-19 cases in Virginia, RICHMOND TIMES DISPATCH (Apr. 13, 2020), https://www.richmond.com/special-report/coronavirus/uvaresearchers-project-mid-august-peak-for-new-covid-19-cases-in-virginia/article_c4e2c008-1617-52d8-ad08706abfb3d696.html. 40 Va. Dep’t of Elections (@vaELECT), Twitter (Mar. 23, 2020, 8:34 AM), https://twitter.com/vaELECT/status/1242067184521748480; Va. Dep’t of Elections, Absentee Ballots, https://www.elections.virginia.gov/casting-a-ballot/absentee-voting/. 41 Va. Dep’t of Elections, Absentee Ballots, https://www.elections.virginia.gov/casting-a-ballot/absentee-voting/ (last visited Apr. 15, 2020).
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56. On April 8, Governor Northam exercised his statutory authority to move the June primary elections from June 9, 2020, to June 23, 2020, and requested that General Assembly move the May General Election and all special elections scheduled for May 5, 2020 to the November 3, 2020 General Election. He took these actions “to further mitigate the spread of COVID-19,” and for purposes of “protecting the health and safety of Virginians during this pandemic and ensuring our citizens can make their voices heard in a safe, fair, and uniform manner.”42
57. This Court has taken similar steps in light of the pandemic. For example, on March 24, the Court extended its restriction on in-person court proceedings to “any criminal, civil and bankruptcy proceedings on or before May 2, 2020.”43 COVID-19’s Impact on African American Virginians in Light of Ongoing and Historical Discrimination
58. Nationally, the COVID-19 epidemic has had a particularly devastating effect in African-American communities. A recent analysis—one of the first attempts to examine the racial disparities of COVID-19 cases and deaths nationwide—found that, in areas where the demographic data has been publicly shared by government officials, African-Americans have made up 42% of people who have died from COVID-19, despite accounting for roughly only 21% of the total population in these areas.44
ress Release, Ralph Northam, Governor of Virginia, Governor Northam Announces Plans to Postpone Upcoming Virginia Elections in Response to COVID-19 (Apr. 8, 2020), https://www.governor.virginia.gov/newsroom/allreleases/2020/april/headline-855995-en.html. 43 Am. Standing Order No. 2020-5, In re: Court Operations Under the Exigent Circumstances Created by COVID19 (W.D. Va. Mar. 24, 2020). 44 Kat Stafford, et al., Outcry over racial data grows as virus slams black Americans, ASSOCIATED PRESS, (Apr. 8, 2020), https://apnews.com/71d952faad4a2a5d14441534f7230c7c?fbclid=IwAR1plunY_qfeA2KrSUPA1TuJobAwQh53a_Qlkf5dw0dWjz-iz85GA1FOt4.
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59. Virginia fits this trend, witnessing racially disparate patterns of serious illness and
mortality due to COVID-19. “African Americans constitute approximately 20% of Virginia’s population, but make up about 30% of the total number of reported positive cases in Virginia.”45
Public health experts believe that these statistics likely understate the racially disparate effect of
COVID-19 in African-American communities in Virginia. For example, Dr. Robert Winn, the
Director of the Massey Cancer Center at Virginia Commonwealth University, estimates that “[i]n
some cases,” African Americans are “three to six times more [likely to be infected by the COVID-19 virus] than their white counterparts.”46
60. Courtney Cogburn, an associate professor at the Columbia University School of
Social Work, noted that “[t]here are patterns at this intersection of race and socioeconomic status
that make it very clear this is just not a story about poverty.” That is, racial disparities in serious
illness and death due to COVID-19 are inextricably linked to a long history and ongoing patterns
of racial discrimination against African Americans:
A history of systemic racism and inequity in access to health care and economic opportunity has made many African Americans far more vulnerable to the virus. Black adults suffer from higher rates of obesity, diabetes and asthma, which make them more susceptible, and also are more likely to be uninsured. They also often report that medical professionals take their ailments less seriously when they seek treatment.47
45 Nana-Séntuo Bonsu, Disproportionate numbers appearing in African American COVID-19 cases in Virginia; doctor explains, WKTR (Apr. 10, 2020), https://www.wtkr.com/news/disproportionate-numbers-appearing-inafrican-african-covid-19-cases-in-virginia-doctor-explains; see also Elizabeth Thomas & Dr. Nancy A. Anoruo, Coronavirus is disproportionately killing the black community. Here’s what experts say can be done about it, ABC NEWS (Apr. 9, 2020), https://abcnews.go.com/Politics/coronavirus-disproportionately-killing-black-communityexperts/story?id=70011986. 46 Matthew Fultz, African Americans 3 to 6 times more likely to get COVID-19, expert says, WTVR (last updated Apr. 13, 2020), https://www.wtvr.com/news/coronavirus/african-americans-3-to-6-times-more-likely-to-get-covid19-expert-says. 47 See supra n. 44 (Stafford, et al.).
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61. Virginia has long experienced patterns of racial discrimination in health and socioeconomic life patterns that render African-American Virginians at greater risk of severe health complications from COVID-19. As Governor Northam has acknowledged,
We know that long-standing racial inequities in things like access to health care, education, and economic opportunities lead to differences in underlying health conditions. The existence of such inequities is one reason why communities of color, including African American people, are more likely to have some of the underlying health conditions that put them at greater risk with COVID-19.48 62. Similarly, Virginia Health Commissioner Norman Oliver has acknowledged that racial inequalities render African-American Virginians particularly vulnerable to COVID-19, noting that lack of access to health care in African-American communities contributes “to much higher disease burden, with twice the rate of diabetes, hypertension, obesity,” resulting in “underlying problems [that] then place these folks at higher risk of mortality from COVID-19.” Health Commissioner Oliver further noted that African Americans in Virginia more frequently “tend to be concentrated in the essential industries and are working,” with “less social distancing . . . and less opportunity for teleworking.”49 And Dr. Winn of VCU has noted that, in comparison to their white counterparts, African American Virginians lack access to healthcare and information, suffer from underlying health conditions, and are more likely to hold “essential jobs” and cannot work from home.50 63. Virginia has a long history of racial discrimination in a wide range of areas in socioeconomic life, including in voting.
48 Neal Augenstein, Virginia governor seeks more data on how COVID-19 affects minorities, WTOP (Apr. 9, 2020), https://wtop.com/virginia/2020/04/virginia-governor-seeks-more-data-on-how-covid-19-affects-minorities/. 49 Id. 50 See supra n. 46 (Fultz).
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Virginia’s Absentee Voting Process and Witness Requirement 64. Virginia law sets out certain categories of individuals who may vote by mail
ballot, known in Virginia as absentee voting. These categories include people absent from the jurisdiction on Election Day including students, service members on active duty, a person with a disability unable to vote in person because of “disability, illness, or pregnancy,” people prevented from voting on Election Day due to religious observance, and several other categories. Va. Code § 24.2-700.
65. During the 2020 legislative session, the Virginia General Assembly passed and the Governor signed a number of voting reforms, including an expansion of absentee voting to make all registered voters eligible to use this process without an excuse.51 This takes effect July 1, 2020.
66. Nonetheless, as previously noted, the Department of Elections has published informal guidance on their website providing that voters may apply for and submit an absentee ballot for the May and June elections by choosing reason “2A My disability or illness” due to COVID-19.
67. On June 23, 2020, Virginia will hold Democratic and Republican primaries for federal offices. Republicans have a statewide primary for a U.S. Senate seat as well as primaries in Virginia’s Second and Third congressional districts. Meanwhile, Democrats have primaries for House races in the First, Fourth, Fifth, and Eleventh congressional districts.
51 See 2020 Va. H.B. 1, available at https://lis.virginia.gov/cgi-bin/legp604.exe?201+ful+HB1ER; Press Release, Officer of the Governor, “Governor Northam Signs Sweeping New Laws to Expand Access to Voting” (Apr. 12, 2020), https://www.governor.virginia.gov/newsroom/all-releases/2020/april/headline-856055-en.html.
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68. Absentee ballot applications submitted by mail for these races must be received by the appropriate registrar no later than June 16 at 5 PM. Va. Code § 24.2-701(B)(2). Completed absentee ballots must be returned to the registrar by the close of polls on Election Day. Va. Code § 24.2-709.
69. Individuals may request an absentee ballot online or by sending in a mail request, among other methods. When applying, individuals must sign the application “subject to felony penalties for making false statements” that the “facts contained in the application are true and correct” and that they “will not vote in the election at any other place in Virginia or in any other state.” Va. Code § 24.2-701(B)(1). An exception exists for individuals who cannot sign due to disability, in which case “a person assisting the applicant will note this fact on the applicant signature line and provide his signature, name, and address.” Id.
70. When a registrar receives an absentee ballot application and verifies that the individual properly competed the application and that they are a registered voter in the jurisdiction, the registrar mails to the individual the following items:
a. A sealed envelope containing the unmarked ballot; b. An envelope for resealing the marked ballot on which is printed a “Statement
of Voter,” as well as spaces for the voter to sign and date and for a witness to sign. The “Statement of Voter” informs voters, among other things, that their signature certifies “subject to felony penalties for making false statements,” their name, legal residence, that they received the ballot after requesting it, that they opened the ballot envelope “in the presence of the witness” but without assistance, that they sealed the ballot in the envelope, and that they “have not voted and will not vote in this election at any other time or place”;
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c. “A properly addressed envelope for the return of the ballot to the general registrar by mail or by the applicant in person”; and
d. “Printed instructions for completing the ballot and statement on the envelope and returning the ballot.” Va. Code § 24.2-706.
71. As noted by the instructions, when voters receive their mailed absentee ballots, they “shall, in the presence of a witness, (i) open the sealed envelope marked ‘ballot within’ and (ii) mark and refold the ballot . . . without assistance and without” indicating how they marked the ballot. Va. Code § 24.2-707(A).
72. Once voters fill out their ballots, they “shall (a) enclose the ballot in the envelope provided for that purpose, (b) seal the envelope, (c) fill in and sign the statement printed on the back of the envelope in the presence of a witness, who shall sign the same envelope, (d) enclose the ballot envelope and any required assistance form within the envelope directed to the general registrar, and (e) seal that envelope and mail it to the office of the general registrar or deliver it personally to the general registrar.” Id.
73. When the absentee ballot process counting begins, election officers examine each absentee ballot envelope to determine whether to accept the ballot for counting. The relevant statute provides that an absentee ballot may not be rejected on the basis that the voter failed to provide a middle name, middle initial, or the date, Va. Code § 24.2-711, but is silent as to whether an absentee ballot may or must be rejected if the voter failed to provide any of the other parts of the absentee ballot envelope, such as the witness signature.
74. However, under regulations promulgated by the Board, the lack of a witness signature on the absentee ballot envelope is an omission that is “always material” and that renders the ballot invalid. 1 Va. Admin. Code 20-70-20(B).
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75. By contrast, absentee ballots that do contain a witness signature are not rendered invalid if the witness signature is illegible, even though there is no requirement that the witness print their name or otherwise identify themselves anywhere on the ballot envelope.
76. Virginia statutes and regulations provide no process by which voters may correct any errors on their absentee ballot envelopes after they are mailed to the general registrar, and in practice, all absentee ballots lacking a witness signature are rejected as a matter of course without any effort to verify whether the absentee ballot came from the intended voter. Voters whose ballots are rejected because of a lack of a witness signature do not learn of this until after the election, when the electoral board “send[s] a written explanation of the reason for rejection of an absentee ballot to the voter whose absentee ballot is rejected within 90 days of the date on which the ballot is rejected.” Va. Code § 24.2-711.1(B). Virginia’s witness requirement will deny large numbers of Virginians the right to vote yet provides only marginal benefits for election integrity
77. As just noted, election officials currently have no discretion under the regulations promulgated by the Board as to whether to count an unwitnessed absentee ballot—they must reject such a ballot and are only obligated to inform the voter as such within 90 days after the ballot rejection.
78. Yet in the current pandemic, individuals living alone and not isolating with a potential witness in accordance with Executive Orders No. 53 and 55 have no safe means to have an individual witness and sign their ballot envelope. Under the Governor’s orders, individuals should maintain at least six feet of distance from others with whom they do not live. These orders also reflect the consensus of doctors and public health officials.
79. Older Virginians and those with certain preexisting medical conditions face even more grave risks by interacting with another individual to obtain a witness signature. But
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because COVID-19 can strike and kill individuals of any age and those without preexisting conditions, any individual living alone faces a real risk by seeking someone to witness their ballot.
80. Enforcing the witness requirement in an environment in which COVID-19 is still being transmitted will likely prevent thousands of eligible Virginians from casting ballots.
81. As of March 31, 2020, Virginia had over 5.73 million registered voters. In the June 2018 Democratic and Republican primaries, over 541,000 Virginians cast ballots. And in the November 2016 general election, over 3.98 million Virginians cast ballots. While many of these individuals voted in-person, the combination of the COVID-19 outbreak, the loosening of absentee voting excuse requirements, and the examples from states like Wisconsin—where absentee ballot requests were five times higher in this year’s primary than in the 2016 primary52—indicate that voting by mail will explode in Virginia this year.
82. According to 2018 Current Population Survey (“CPS”) statistics from the Census Bureau,53 25.3% of Virginians age 18 and older live alone. Assuming similar numbers in the 2020 June primaries, over 136,000 Virginians will face the choice of either risking their health by voting in person or finding a witness for their absentee ballots, or not voting at all. For the
52 Compare Absentee Ballot Report - April 7, 2020 Spring Election and Presidential Preference Primary, Wisc. Election Comm’n, https://elections.wi.gov/node/6833 (reporting over 1.28 million absentee ballots requested for April 7, 2020 primary) with Riley Vetterkind, Absentee ballot requests in Wisconsin already exceed number in recent spring elections, WISC. STATE JOURNAL (Mar. 18, 2020), https://madison.com/wsj/news/local/govt-andpolitics/absentee-ballot-requests-in-wisconsin-already-exceed-number-in-recent-spring-elections/article_dfb34fc56aa8-5428-90c3-26c3f82a1d70.html (noting that just under 250,000 absentee ballots were requested for spring 2016 Wisconsin primary). 53 2018 Current Population Survey, U.S. Census Bureau, statistics accessed by using the Census Bureau Current Population Survey Table Creator tool at https://www.census.gov/cps/data/cpstablecreator.html..
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general election, over a million Virginians will fall into this category. Like the individual Plaintiffs, many of them will be forced to risk their (and others’) health in order to vote.
83. To make matters worse, this burden on the right to vote will fall more heavily upon certain groups—older Virginians, Virginians with disabilities, and African American Virginians, among others.
84. Approximately 33% of Virginians age 65 and older live alone compared to 25.3% of the general population. 37.2% of Virginians 18 and older with a disability live alone and 44% of Virginians aged 65 and older with a disability live alone. 31% of African American Virginians 18 and older live alone versus only 24.7% of white Virginians 18 and older.
85. As noted above, older individuals already face higher rates of infection and death from COVID-19, further magnifying its impact. And the CDC has found that “some people with disabilities might be at a higher risk of infection or severe illness because of their underlying medical conditions.”54
86. Recent evidence also revealed racial disparities in the impact of COVID-19— disparities that will also likely transfer to burdens on voting. While Virginia is not yet fully collecting COVID-19 data by race, both Maryland and North Carolina have released data showing that African Americans face higher rates of both infection and death from COVID-19 than the population as a whole.55
54 Centers for Disease Control and Prevention, People Who Need Extra Precautions: People with Disabilities, https://www.cdc.gov/coronavirus/2019-ncov/need-extra-precautions/people-with-disabilities.html (last visited Apr. 15, 2020). 55 North Carolina Department of Health and Human Services, COVID-19 Cases in North Carolina By Race, https://www.ncdhhs.gov/divisions/public-health/covid19/covid-19-nc-case-count#by-race/ethnicity (last visited Apr. 15, 2020); Fenit Nirappil et al., Record set for single-day covid-19 deaths in D.C., Maryland and Virginia at 53; black residents hit hardest, WASH POST (Apr. 9, 2020, 3:47 PM), https://www.washingtonpost.com/local/covid-19-
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87. Virginia’s witness requirement will therefore likely prevent tens of thousands of Virginians who might otherwise cast absentee ballots from doing so this year, with a disproportionate impact on older Virginians, Virginians with a disability, and African American Virginians.
88. The witness requirement is particularly burdensome for African Americans in Virginia, who, as noted, are more likely to live alone and thus will be more likely to risk exposure to COVID-19 in the course of obtaining a witness signature. African Americans in Virginia continue to bear the effects of discrimination in areas such as education, employment, and health, which hinder their ability to participate effectively in the political process. It is precisely because of these patterns that African Americans in Virginia face particularly severe health risks from COVID-19 exposure. In these circumstances, the witness requirement interacts with these conditions to deny African Americans in Virginia an equal opportunity to participate in the political process.
89. While protecting election integrity and preventing improper use of absentee ballots certainly are valid governmental interests, maintaining the witness requirement during this pandemic fails to even serve this interest, let alone present a narrowly tailored method of doing so. And to the extent it does serve these or any other governmental interests, it is substantially outweighed by its massive burden on Virginia voters and other Virginia procedures that serve the same interests.
90. The witness requirement is not Virginia’s sole method of policing the integrity of absentee ballots—far from it. Indeed, only 10 other states even contain such a requirement in
deaths-hit-new-high-in-dc-maryland-and-virginia-at-53-black-residents-hit-hardest/2020/04/09/cc85cd14-77b311ea-b6ff-597f170df8f8_story.html.
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their state laws yet the states without this requirement still have absentee balloting systems not undermined by fraud.56
91. Meanwhile, Virginia has several other mechanisms to both confirm the legitimacy of the absentee ballot cast and disincentivize fraudulent use of absentee ballots.
92. For one, the general registrar maintains a list of voters who applied for and returned absentee ballots, and that list is attested to by the secretary of the electoral board and delivered to the chief officer of election for each precinct. Absentee ballots are only accepted “from voters whose names appear on the attested list.” Va. Code § 24.2-710.
93. Most directly, voters themselves must attest under penalty of perjury their identity, residence, and that they did not double vote when they sign their ballot envelope. Va. Code § 24.2-706.
94. Any individual who double votes or otherwise improperly uses an absentee ballot faces severe criminal penalties for violating their attestation: “Any person who intentionally (i) votes more than once in the same election . . . is guilty of a Class 6 felony.” Va. Code § 24.21004(B).
95. Additionally, any “willfully false material statement or entry made by any person in any statement, form, or report required by this title shall constitute the crime of election fraud and be punishable as a Class 5 felony.” Va. Code § 24.2-1016.
56 See Chart, “Verifying Authenticity of Absentee/Mailed Ballots,” Voting Outside the Polling Place: Absentee, AllMail and other Voting at Home Options, Nat’l Conf. of State Legislatures (Apr. 3, 2020), https://www.ncsl.org/research/elections-and-campaigns/absentee-and-early-voting.aspx.
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96. And “[a]ny person attempting to vote by fraudulently signing the name of a qualified voter shall be guilty of forgery and shall be guilty of a Class 4 felony.” Va. Code § 24.2-1012.
97. In light of these attestation and verification requirements and criminal penalties associated with misusing absentee ballots, the additional step of requiring a witness signature adds little on top of these safeguards. And while instances of fraud are rare, an individual determined to break these laws and risk the penalties can just as easily forge the signature of another individual as they can falsely attest when they sign their own name. Indeed, the witness requirement has little if any practical utility for election integrity because Virginia law does not require witnesses to identify themselves by printing their name or providing any other information and Board regulations instruct election officials to accept ballots even where the witness signature is illegible.
98. The burden on the voting rights of the many thousands of Virginians, including Plaintiffs, who will be prevented from either casting their ballots safely or having them counted by retaining the witness requirement far outweighs any upside of the requirement, if any.
CLAIMS FOR RELIEF COUNT I
Violation of the Fundamental Right to Vote 42 U.S.C. § 1983, First and Fourteenth Amendments to the U.S. Constitution 99. Eligible individuals have a fundamental right to vote under the First and Fourteenth Amendments of the United States Constitution. Under the First and Fourteenth Amendments, a court considering a challenge to a state election law must carefully balance the character and magnitude of the injury to the rights that the plaintiff seeks to vindicate against the
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justifications put forward for the burdens imposed by the rule. See Burdick v. Takushi, 504 U.S. 428, 434 (1992); Anderson v. Celebrezze, 460 U.S. 780, 789 (1983).
100. In light of the COVID-19 pandemic, Virginia’s witness requirement and its enforcement severely and unreasonably burdens the fundamental right to vote of Virginia voters. This requirement will likely prevent thousands of eligible Virginians from casting ballots, with particularly heavy burdens on older Virginians, Virginians with disabilities, and African American Virginians.
101. And while Virginia has a general interest in election integrity, the witness requirement does very little to advance this interest in light of the substantial other protections against fraudulent submission of ballots, let alone providing a narrowly tailored way to address this potential issue. Whatever interests the witness requirement may serve pales in comparison to the substantial burden on voters during the COVID-19 pandemic.
102. Therefore, Defendants, acting under color of state law, have and will continue to deprive Plaintiffs of rights secured to them by the First and Fourteenth Amendments to the United States Constitution— namely, the fundamental right to vote—and protected by 42 U.S.C. § 1983 by enforcing the witness requirement.
COUNT II Violations of Section 2 of the Voting Rights Act, 52 U.S.C. § 10301 103. Section 2 of the Voting Rights Act provides in part that “[n]o voting qualification or prerequisite to voting or standard, practice, or procedure shall be imposed or applied by any State . . . in a manner which results in a denial or abridgement of the right of any citizen of the United States to vote on account of race or color.” 52 U.S.C. § 10301(a). 104. The “essence of a [Section] 2 claim is that a certain electoral law, practice, or structure interacts with social and historical conditions to cause an inequality in the opportunities
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enjoyed by black and white voters to elect their preferred representatives.” League of Women Voters of N.C. v. North Carolina, 769 F.3d 224, 238–39 (4th Cir. 2014) (internal quotation marks and citation omitted). “[A] Section 2 vote-denial claim consists of two elements:
First, the challenged standard, practice, or procedure must impose a discriminatory burden on members of a protected class, meaning that members of the protected class have less opportunity than other members of the electorate to participate in the political process and to elect representatives of their choice. Second, that burden must in part be caused by or linked to social and historical conditions that have or currently produce discrimination against members of the protected class. Id. at 240 (internal quotation marks and citations omitted). 105. The witness requirement, if not declared illegal and enjoined, will materially burden the right to vote, and will have an adverse and disparate impact on African-American voters in Virginia. African Americans in Virginia are more likely to suffer from severe health complications and to die from COVID-19, and are therefore more significantly burdened by the witness requirement. 106. This disparate burden resulting from the witness requirement is directly linked to social and historical conditions. Virginia has a long history of voting-related discrimination. African Americans in Virginia continue to suffer from discrimination in areas such as education, employment, and health, which hinders their ability to participate effectively in the political process. In particular, these discriminatory patterns render African Americans more vulnerable to COVID-19, such that the witness requirement is particularly burdensome for them as a group relative to other voters. 107. Under the totality of the circumstances, the witness requirement interacts with these social and historical conditions to abridge and deny African Americans in Virginia the right to vote. As a result of the witness requirement, African Americans in Virginia will have less
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opportunity than other members of the electorate to participate in the political process and to elect representatives of their choice.
RELIEF REQUESTED WHEREFORE, Plaintiffs respectfully requests that this Court: A. Declare that Virginia’s enforcement of the witness requirement (as stated in Va. Code
§ 24.2-706 and § 24.2-707 and as interpreted by 1 Va. Admin. Code 20-70-20(B)) while emergency orders by Virginia or federal authorities regarding COVID-19 transmission are in effect and/or while public health officials continue to recommend social distancing practices due to risk of community transmission of COVID-19 violates the fundamental right to vote under First and Fourteenth Amendments to United States Constitution as well as Section 2 of the Voting Rights Act; B. Issue a preliminary and permanent injunction that orders relief including:
1. Prohibiting Defendants from enforcing the witness requirement (as stated in Va. Code § 24.2-706 and § 24.2-707 and as interpreted by 1 Va. Admin. Code 20-70-20(B)) for all voters, especially for voters at risk of health complications arising from COVID-19 exposure, while emergency orders concerning COVID-19 are in place and/or while public health officials continue to recommend social distancing practices due to risk of community transmission of COVID-19;
2. Ordering Defendants to issue guidance instructing city and county election officials to count otherwise validly cast absentee ballots that are missing a witness signature for Virginia’s primary and general elections in 2020; and
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3. Ordering Defendants to conduct a public information campaign informing Virginia voters about the elimination of this requirement, in coordination with city and county election officials;
C. Award Plaintiffs attorneys’ fees in this action; D. Award Plaintiffs their costs of suit; and E. Grant such other and further relief as this Court deems just and proper in the circumstances.

Dated: June 29, 2020
Davin M. Rosborough (VSB # 85935) Dale E. Ho* Sophia Lin Lakin* Theresa J. Lee* Adriel I. Cepeda-Derieux* American Civil Liberties Union Foundation 125 Broad Street, 18th Floor New York, NY 10004 Tel.: (212) 549-2500 drosborough@aclu.org dho@aclu.org slakin@aclu.org tlee@aclu.org acepedaderieux@aclu.org

Respectfully submitted,
/s/ Vishal Agraharkar__ Vishal Agraharkar (VSB #93265) Eden Heilman (VSB #93554) AMERICAN CIVIL LIBERTIES UNION FOUNDATION OF VIRGINIA, INC. 701 E. Franklin Street, Suite 1412 Richmond, Virginia 23219 Phone: (804) 644-8080 Fax: (804) 649-2733 vagraharkar@acluva.org eheilman@acluva.org
Attorneys for Plaintiffs
* Admitted pro hac vice

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UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA
Lynchburg Division

LEAGUE OF WOMEN VOTERS OF

VIRGINIA;

KATHERINE

D.

CROWLEY; SEIJRA TOOGOOD;

GAYLE HARDY; CAROL D.

PETERSEN; and TRACY SAFRAN,

Plaintiffs,

v.

VIRGINIA STATE BOARD OF ELECTIONS; ROBERT H. BRINK, JOHN O’BANNON, and JAMILAH D. LECRUISE, in their official capacities as Chairman, Vice-Chair, and Secretary of the Virginia State Board of Elections, respectively; and CHRISTOPHER E. PIPER, in his official capacity as Commissioner of the Virginia Department of Elections,

Defendants,

REPUBLICAN PARTY OF VIRGINIA,

Intervenor-Defendant.

Case No. 6:20-cv-00024-NKM-RSB

JOINT MOTION FOR ENTRY OF PARTIAL CONSENT JUDGMENT AND DECREE Plaintiffs and Defendants (collectively, the “Consent Parties”) seek approval of a partial
consent judgment and decree that would vindicate the public interests of ensuring access to the ballot, protecting election integrity, and promoting public health during the COVID-19 pandemic. Specifically, the agreement would stop enforcement for the November 3, 2020 General Election of the requirement that Virginia absentee voters have another individual observe them removing their absentee ballot from the envelope and then have that individual sign as a witness (the “witness

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requirement”) for voters who believe they may not safely have a witness present while completing their ballot. In support of their motion, the Consent Parties rely upon the attached proposed Partial Consent Judgment and Decree and accompanying Brief in Support of Joint Motion for Entry of a Partial Consent Judgment and Decree.
This agreement represents a fair, adequate, and reasonable arrangement which will benefit all parties while serving the public interest. The Consent Parties therefore request that the Court enter this agreement, which will provide certainty well in advance of the November 3, 2020 General Election while allowing all qualified Virginians to vote and protect their health.

Dated: August 5, 2020

Respectfully submitted,

/s/ Davin M. Rosborough_____________ Davin M. Rosborough (VSB # 85935) Dale E. Ho* Sophia Lin Lakin* Theresa J. Lee* Adriel I. Cepeda-Derieux* American Civil Liberties Union Foundation 125 Broad Street, 18th Floor New York, NY 10004 Tel.: (212) 549-2500 drosborough@aclu.org dho@aclu.org slakin@aclu.org tlee@aclu.org acepedaderieux@aclu.org
Vishal Agraharkar (VSB #93265) Eden Heilman (VSB #93554) AMERICAN CIVIL LIBERTIES UNION FOUNDATION OF AMERICA, INC. 701 E. Franklin Street, Suite 1412 Richmond, Virginia 23219 Phone: (804) 644-8080 Fax: (804) 649-2733 vagraharkar@acluva.org eheilman@acluva.org

MARK R. HERRING Attorney General of Virginia By: /s/ Carol L. Lewis CAROL L. LEWIS (VSB #92362) MICHELLE S. KALLEN (VSB # 93286) HEATHER HAYS LOCKERMAN (VSB #65535) CALVIN C. BROWN (VSB #93192) Office of the Attorney General 202 North Ninth Street Richmond, Virginia 23219 804-692-0558 (telephone) 804-692-1647 (facsimile) clewis@oag.state.va.us
Attorneys for Robert H. Brink, John O’Bannon, Jamilah D. LeCruise and Christopher E. Piper in their official capacities, and the Virginia State Board of Elections

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Attorneys for Plaintiffs *Admitted pro hac vice

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CERTIFICATE OF SERVICE I certify that on August 5, 2020, I served a copy of the foregoing Joint Motion for Entry of Partial Consent Judgment and Decree via filing with the Court’s CMECF system, which sent copies of this document to Counsel of Record.
/s/ Davin M. Rosborough_____________ Davin M. Rosborough (VSB # 85935) American Civil Liberties Union Foundation 125 Broad Street, 18th Floor New York, NY 10004 Tel.: (212) 549-2500 drosborough@aclu.org
Counsel for Plaintiffs

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UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA
Lynchburg Division

LEAGUE OF WOMEN VOTERS OF

VIRGINIA;

KATHERINE

D.

CROWLEY; SEIJRA TOOGOOD;

GAYLE HARDY; CAROL D.

PETERSEN; and TRACY SAFRAN,

Plaintiffs,

v.

VIRGINIA STATE BOARD OF ELECTIONS; ROBERT H. BRINK, JOHN O’BANNON, and JAMILAH D. LECRUISE, in their official capacities as Chairman, Vice-Chair, and Secretary of the Virginia State Board of Elections, respectively; and CHRISTOPHER E. PIPER, in his official capacity as Commissioner of the Virginia Department of Elections,

Defendants,

REPUBLICAN PARTY OF VIRGINIA,

Intervenor-Defendant.

Case No. 6:20-cv-00024-NKM-RSB

PARTIAL CONSENT JUDGMENT AND DECREE 1. Whereas Virginia law requires that every voter filling out an absentee ballot must open, mark, and refold their ballot in the presence of a witness, and then have the witness sign their ballot envelope (the “witness requirement”), as stated in Va. Code § 24.2-706 and § 24.2-707 and as interpreted by 1 Va. Admin. Code 20-70-20(B). 2. Whereas on March 12, 2020, Virginia Governor Ralph S. Northam issued Executive Order 51 (EO 51) in which he declared a state of emergency in Virginia in response to

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the spread in Virginia of a respiratory illness (COVID-19) caused by a novel coronavirus—an order that remains in effect.
3. Whereas the virus that causes COVID-19 may be transmitted from person-toperson through close contact via inhalation of respiratory droplets when an infected person breathes, talks, coughs or sneezes; through inhalation of such droplets that become aerosolized and remain suspended in the air; and through contact with surfaces or objects on which the virus is present, followed by touching one’s own mouth, nose, or even eyes. The CDC has also confirmed that people infected with the virus may transmit it to others without showing symptoms themselves.
4. Whereas COVID-19 can cause severe consequences, including long-term illness and death, and the virus threatens to infect and harm any individual no matter their age or medical background. COVID-19 is particularly dangerous and sometimes fatal for older individuals, individuals with obesity, individuals with compromised immune systems, individuals with preexisting heart and respiratory conditions including hypertension and asthma, and individuals with various other conditions.
5. Whereas the Virginia Department of Health (“VDH”) continues to urge Virginians to do their “part to help stop the spread of COVID-19 by staying at home as much as possible,” and federal guidelines state: “[e]veryone [s]hould . . . avoid close contact” by “stay[ing] home as much as possible” and “put[ting] 6 feet of distance between yourself and people who don’t live in your household.” Centers for Disease Control and Prevention, Coronavirus Disease 2019 (COVID-19): How to Protect Yourself & Others, https://www.cdc.gov/coronavirus/2019ncov/prevent-getting-sick/prevention.html (last visited Aug. 4, 2020).
6. Whereas the witness requirement necessitates that any individual who lives alone
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and wishes to vote an absentee ballot will need to either invite another person into their home or travel outside their home to meet a witness. Then, the individual must have the witness watch while they open their ballot envelope, fill out their ballot, close and sign the envelope, and finally exchange the envelope back and forth with the witness to obtain their signature. This situation requires that individuals who live alone and are isolating or practicing social distancing per public health recommendations come into close contact with another individual, and increase the likelihood that those involved will contract COVID-19 and transmit it to others. For this reason, the witness requirement creates a health risk to the general public.
7. Whereas in-person voting also creates a risk to individual voters and to public health, as voting in person involves waiting in line with other voters, interacting with poll workers, and touching voting equipment—some of this in an indoor environment—which also creates significant risk of virus transmission.
8. Whereas as of July 29, 2020, there have been well over 4 million cases and over 150,000 deaths from COVID-19 in the United States, and over 87,000 cases and over 2,100 deaths from COVID-19 in Virginia alone. After declining in late May and into June, the number of daily new COVID-19 cases has once again been steadily rising in Virginia, as in most of the country.
9. Whereas an effective, widely available vaccine for COVID-19 will almost certainly not be available by November 3, 2020, and the significant weight of scientific evidence confirms that COVID-19 will likely continue to transmit widely in the community absent a vaccine or herd immunity, and that herd immunity will not occur anytime in the near future.
10. Whereas on April 17, 2020, Plaintiffs League of Women Voters of Virginia, Katherine D. Crowley, Erikka Goff, and Seijra Toogood filed a complaint against the above-named Defendants challenging enforcement during the ongoing public health crisis caused by the spread
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of a novel coronavirus, SARS-CoV-2, of Virginia’s witness requirement. Among other relief requested, the Complaint sought to enjoin enforcement of the witness requirement for as long as public health officials continue to recommend social distancing practices due to the risk of community transmission of COVID-19. ECF No. 1 at 33.
11. Whereas on April 21, 2020, the same Plaintiffs filed a motion for preliminary injunction requesting this Court prohibit the above-named Defendants from enforcing the witness requirement for all Virginia voters for the primary election to be held on June 23, 2020 (“June Primary”), and for all subsequent elections in Virginia until such time as in-person interactions required by compliance with the witness requirement no longer pose a risk to public health and personal safety. Plaintiffs’ motion further requested that Defendants be ordered to issue guidance instructing election officials to count otherwise validly cast absentee ballots missing a witness signature and to conduct a public information campaign in conjunction with city and county election officials about the elimination of the requirement.
12. Whereas those same Plaintiffs and Defendants reached a proposed partial consent decree and judgment (the “first consent decree”) that they submitted to the Court for approval on April 27, 2020, governing the operation of the witness requirement for the June Primary. See ECF Nos. 35, 35-1, 36. After full briefing on this motion and a hearing, this Court approved the first consent decree which, among other things: (a) prohibited enforcement of the witness requirement for the June Primary for Virginia voters who did not believe they could safely comply; (b) required Defendants to issue guidance instructing all relevant city and county election officials to count all absentee ballots in the June primary that are otherwise validly cast but missing a witness signature; (c) required Defendants to prepare updated voting instructions to accompany the absentee ballots informing voters that any absentee ballot cast in the June Primary without a witness signature will
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not be rejected on that basis and specifically inform voters in bold print that they may disregard the witness signature line on the absentee ballot envelope if they believe they may not safely have a witness present while completing their ballot; and (d) requiring Plaintiffs to withdraw their preliminary injunction motion and disclaiming Plaintiffs’ right to seek attorneys’ fees up to that point in the litigation. ECF No. 68.
13. Whereas in granting the first consent decree, the Court found that: “Plaintiffs’ case alleges a probable violation of federal law—that is, applying the witness requirement during this pandemic would impose a serious burden on the right to vote, particularly among the elderly, immunocompromised, and other at-risk populations. Weighed against those risks, the present record reflects the likelihood that the burden would not be justified by the witness requirement’s purpose as an anti-fraud measure. Thus, the Court finds that the partial settlement in the proposed consent decree is fair, adequate, and reasonable given the strength of the Plaintiffs’ case, and that entering it is not against the public interest, illegal, or the product of collusion.” ECF No. 69 at 1.
14. Whereas the June Primary proceeded smoothly under the terms of the first consent decree without an increase in fraud, to the knowledge of the Defendants.
15. Whereas on June 19, 2020, the Court granted Plaintiffs’ motion to dismiss Erikka Goff as a Plaintiff, ECF No. 80, and on July 17, 2020, the Court granted Plaintiffs’ motion to file a second amended complaint, which added new Plaintiffs Gayle Hardy, Carol D. Petersen, and Tracy Safran, see ECF Nos. 83, 84.
16. Whereas discovery produced in this case by Defendants shows that during the May 2020 local elections in Virginia, for which the witness requirement was still in full effect and which occurred after the COVID-19 pandemic began, both the rate and number of absentee ballots rejected for lack of a witness signature climbed substantially.
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17. Whereas on July 24, 2020, Plaintiffs League of Women Voters of Virginia, Katherine D. Crowley, Seijra Toogood, Gayle Hardy, Carol D. Petersen, and Tracy Safran filed a Motion for Preliminary Injunction requesting this Court prohibit Defendants from enforcing the witness requirement for all Virginia voters for the November election and for all subsequent elections in Virginia until such time as in-person interactions required by compliance with the witness requirement no longer pose a risk to public health and personal safety. Plaintiffs’ motion further requested that Defendants be ordered to issue guidance instructing election officials to count otherwise validly cast absentee ballots missing a witness signature and conduct a public information campaign in conjunction with city and county election officials about the elimination of the requirement.
18. Whereas pursuant to Va. Code § 24.2-612, absentee voting must be available 45 days prior to the November 3, 2020 General Election (“the November Election”), or Saturday, September 19, 2020. For localities whose general registrar’s offices are closed on Saturday, absentee ballots must be available on Friday, September 18, 2020.
19. Whereas in light of the data that supports the Plaintiffs’ concerns for their safety if they are required to interact with others in order to cast their ballot in the November Election, Plaintiffs and Defendants (collectively, the “Consent Parties”) agree that an expeditious resolution of this matter for the November general election, in the manner encompassed by the terms of this Consent Decree, is in the best interests of the health, safety, and constitutional rights of the citizens of the Commonwealth of Virginia, and therefore in the public interest.
20. Whereas the Consent Parties further agree that no eligible voter should have to choose between casting a ballot that will count and placing their own health at risk.
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21. Whereas Defendants agree not to enforce the witness requirement for the November Election for absentee voters who believe they may not safely have a witness present while completing their ballot.
22. Whereas Plaintiffs agree to withdraw their July 24, 2020 Motion for Preliminary Injunction upon entry of this Partial Consent Judgment and Decree.
23. Whereas the Consent Parties agree that entry of this Consent Decree does not affect the viability of Plaintiffs’ claims under the First and Fourteenth Amendments to the Constitution, or Section 2 of the Voting Rights Act, with respect to enforcement of the witness requirement in any subsequent elections after the November Election.
24. Whereas Plaintiffs agree to a waiver of any entitlement to damages, fees, including attorneys’ fees, expenses, and costs, that may have accrued as of the date of the entry of this order, with respect to the claims raised by Plaintiffs in this action, provided, however, that Plaintiffs reserve their rights to seek costs and attorneys’ fees on their claims in the event of material noncompliance by Defendants with the terms and conditions of this Consent Decree.
25. Whereas the Court finds that it has subject matter jurisdiction over the Consent Parties and that the Partial Consent Judgment and Decree is fair, adequate, and reasonable, and not illegal, a product of collusion, or against the public interest because such agreement preserves the constitutional right to vote of Plaintiffs and other Virginia voters while promoting public health during a pandemic and does so without harming the integrity of Virginia’s elections. The agreement also gives appropriate weight to Defendants’ expertise and public interest responsibility in the area of election administration.
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26. Whereas Plaintiffs made a sufficiently strong showing on the merits of the claim, as shown in their complaint and motion for preliminary injunction, to further support the fairness, adequacy, and reasonableness of this Partial Consent Judgment and Decree. IT IS HEREBY ORDERED, ADJUDGED, AND DECREED FOR THE REASONS STATED ABOVE IN PARAGRAPHS 1-26 THAT:
1. For the November Election, Defendants shall not enforce the requirement, as stated in Va. Code § 24.2-706 and § 24.2-707, that absentee voters have another individual present to witness the voter open, mark, and refold their ballot, and then have that that individual sign the absentee ballot envelope next to the voter’s statement and signature, for voters who believe that they may not safely comply.
2. Defendants shall issue guidance instructing all relevant city and county election officials to count all absentee ballots in the November Election that are otherwise validly cast but are missing a witness signature.
3. Defendants shall issue updated instructions to include with all absentee ballots as provided in Va. Code. § 24.2-706—or issue guidance instructing all relevant city and county election officials to modify or amend the printed instructions accompanying each absentee ballot— to inform voters that any absentee ballot cast in the November Election without a witness signature will not be rejected on that basis and specifically inform voters in bold print that they may disregard the witness signature line on the absentee ballot envelope if they believe they may not safely have a witness present while completing their ballot.
4. Defendant Commissioner of Elections shall take additional reasonable steps to inform the public that the witness requirement will not be enforced for the November Election for those absentee voters who believe they may not safely have a witness present while completing
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their ballot, and issue guidance instructing all relevant city and county election officials to do the same.
5. Plaintiffs will withdraw their motion for a preliminary injunction. 6. In accordance with the terms of this Consent Decree, the Consent Parties shall each bear their own fees, expenses, and costs incurred as of the date of this Order, with respect to all claims raised by Plaintiffs against the Defendants.

Dated: _______________, 2020

_______________________ United States District Judge

/s/ Davin M. Rosborough_______________ Davin M. Rosborough (VSB # 85935) Dale E. Ho* Sophia Lin Lakin* Theresa J. Lee* Adriel I. Cepeda-Derieux* American Civil Liberties Union Foundation 125 Broad Street, 18th Floor New York, NY 10004 Phone: (212) 549-2500 drosborough@aclu.org dho@aclu.org slakin@aclu.org tlee@aclu.org acepedaderieux@aclu.org
Vishal Agraharkar (VSB #93265) Eden Heilman (VSB #93554) AMERICAN CIVIL LIBERTIES UNION FOUNDATION OF VIRGINIA 701 E. Franklin Street, Suite 1412 Richmond, Virginia 23219 Phone: (804) 644-8080 Fax: (804) 649-2733 vagraharkar@acluva.org eheilman@acluva.org

MARK R. HERRING Attorney General of Virginia By: /s/ Carol L. Lewis CAROL L. LEWIS (VSB #92362) MICHELLE S. KALLEN (VSB #93286)
HEATHER HAYS LOCKERMAN (VSB #65535)
Office of the Attorney General 202 North Ninth Street Richmond, Virginia 23219 804-692-0558 (telephone) 804-692-1647 (facsimile) clewis@oag.state.va.us
Attorneys for Robert H. Brink, John O’Bannon, Jamilah D. LeCruise and Christopher E. Piper in their official capacities, and the Virginia State Board of Elections

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Attorneys for Plaintiffs *Admitted Pro Hac Vice
10

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UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA
Lynchburg Division

LEAGUE OF WOMEN VOTERS OF

VIRGINIA;

KATHERINE

D.

CROWLEY; SEIJRA TOOGOOD;

GAYLE HARDY; CAROL D.

PETERSEN; and TRACY SAFRAN,

Plaintiffs,

v.

VIRGINIA STATE BOARD OF ELECTIONS; ROBERT H. BRINK, JOHN O’BANNON, and JAMILAH D. LECRUISE, in their official capacities as Chairman, Vice-Chair, and Secretary of the Virginia State Board of Elections, respectively; and CHRISTOPHER E. PIPER, in his official capacity as Commissioner of the Virginia Department of Elections,

Defendants,

REPUBLICAN PARTY OF VIRGINIA,

Intervenor-Defendant.

Case No. 6:20-cv-00024-NKM-RSB

BRIEF IN SUPPORT OF JOINT MOTION FOR ENTRY OF PARTIAL CONSENT JUDGMENT AND DECREE

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Plaintiffs and Defendants (collectively, the “Parties”) seek approval of a partial consent judgment and decree that would vindicate the public interests of ensuring access to the ballot, election integrity, and promoting public health during the COVID-19 pandemic, just as did the consent decree approved by this Court for the June 23 primaries. See ECF Nos. 68, 69. Indeed, the substantive terms are nearly identical to that prior agreement that the Court approved as “fair, adequate, and reasonable given the strength of the Plaintiffs’ case, and . . . not against the public interest, illegal, or the product of collusion.” ECF No. 69 at 1. It did so because enforcing “the witness requirement during this pandemic would impose a serious burden on the right to vote, particularly among the elderly, immunocompromised, and other at-risk populations,” which, “[w]eighed against those risks, . . . would not be justified by the witness requirement’s purpose as an anti-fraud measure.” Id. The only relevant difference are the facts on the ground. Those facts make this consent decree even more vital for the public interest than the previous one.
When this Court approved the first partial consent decree on May 5, a little over 20,000 Virginians had contracted COVID-19 and over 700 had died from it. ECF No. 88-4 at 4. As of August 4, those numbers have climbed to over 94,000 cases and over 2,200 deaths.1 Notably, since that time, the June 23 primaries “proceeded smoothly under the terms of the first consent decree without an increase in fraud, to [election officials’] knowledge.” ECF No. 95-1 ¶ 14.
The vast weight of scientific evidence firmly shows that COVID-19 will still be transmitting in the community on November 3, 2020 at significant rates. Recognizing this, federal court granted a preliminary injunction against South Carolina’s witness requirement for its June primary shortly after this Court entered the first consent decree, finding a “strong likelihood that
1 See Va. Dep’t of Health, COVID-19 Cases in Virginia, https://www.vdh.virginia.gov/coronavirus/covid-19-dailydashboard/ (last updated Aug. 4, 2020).
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the burdens placed upon them by the Witness Requirement far outweigh the imprecise, and . . . ineffective, state interests of combating voter fraud and protecting voting integrity.” Thomas v. Andino, 3:20-CV-01552-JMC, --- F. Supp. 3d ----, 2020 WL 2617329, at *21 (D.S.C. May 25, 2020).
Ultimately, the proposed agreement to halt enforcement of the witness requirement for voters who believe they may not safely have a witness present while completing their ballot for the November 3 general election represents a limited, fair, adequate, and reasonable arrangement. It reflects sound public health judgment and the need for safe participation in exercising the fundamental right to vote. The Parties therefore request that the Court enter this agreement, which will provide certainty well in advance of the November 3 election while allowing all qualified Virginians to vote and protect their health.
FACTUAL BACKGROUND On March 12, 2020, Virginia Governor Ralph S. Northam declared a state of emergency in Virginia in response to the spread of a respiratory disease (COVID-19) caused by a novel coronavirus known as SARS-CoV-2—an order that remains in effect.2 In conjunction with the loosening of some restrictions, the Virginia Department of Health (“VDH”) continues to urge Virginians to do their “part to help stop the spread of COVID-19 by staying at home as much as possible,”3 and urges all Virginians to “practice social distancing” and encourages those aged 65
2 Va. Exec. Order No. 2020-51 (Mar. 12, 2020), https://www.governor.virginia.gov/media/governorvirginiagov/governor-of-virginia/pdf/eo/EO-51-Declaration-of-aState-of-Emergency-Due-to-Novel-Coronavirus-(COVID-19).pdf. 3 Va. Dep’t of Health, Prevention Tips, https://www.vdh.virginia.gov/coronavirus/prevention-tips/ (last visited Aug. 4, 2020).
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and older to self-quarantine.4 Similarly, federal guidelines state: “[e]veryone [s]hould . . . avoid close contact” by “stay[ing] home as much as possible” and “put[ting] 6 feet of distance between yourself and people who don’t live in your household.”5
On April 17, during the ongoing public health crisis caused by the novel coronavirus, Plaintiffs filed this action challenging the enforcement of the absentee ballot witness requirement (as stated in Va. Code § 24.2-706 and § 24.2-707 and as interpreted by 1 Va. Admin. Code 20-7020(B)), under the First and Fourteenth Amendments of the U.S. Constitution and Section 2 of the Voting Rights Act. Among other relief requested, the Complaint sought to enjoin enforcement of the witness requirement for as long as public health officials continue to recommend social distancing practices due to the risk of community transmission of COVID-19. ECF No. 1 at 33.
On April 21, 2020, Plaintiffs filed a motion for preliminary injunction requesting this Court to prohibit the above-named Defendants from enforcing the witness requirement for all Virginia voters for the primary election to be held on June 23, 2020 (“June Primary”), and for all subsequent elections in Virginia until such time as in-person interactions required by compliance with the witness requirement no longer pose a risk to public health and personal safety. See ECF No. 17. Plaintiffs’ motion further requested that Defendants be ordered to issue guidance instructing election officials to count otherwise validly cast absentee ballots missing a witness signature and conduct a public information campaign in conjunction with city and county election officials about the elimination of the requirement.
4 Va. Dep’t of Health, Disease Prevention, https://www.vdh.virginia.gov/coronavirus/frequently-askedquestions/disease-prevention/ (last visited Aug 4, 2020). 5 Ctrs. for Disease Control & Prevention, Coronavirus Disease 2019 (COVID-19): How to Protect Yourself & Others, https://www.cdc.gov/coronavirus/2019-ncov/prevent-getting-sick/prevention.html (last visited Aug. 4, 2020).
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On April 27, 2020, Plaintiffs and Defendants filed a motion for entry of a partial consent decree and judgment in which the parties agreed, pending court approval, to: (a) prohibit enforcement of the witness requirement for the June Primary for Virginia voters who did not believe they could safely comply; (b) require Defendants to issue guidance instructing all relevant city and county election officials to count all absentee ballots in the June Primary that are otherwise validly cast but missing a witness signature; (c) require Defendants to prepare updated voting instructions to accompany the absentee ballots informing voters that any absentee ballot cast in the June Primary without a witness signature will not be rejected on that basis; and (d) require Plaintiffs to withdraw their preliminary injunction motion and disclaim Plaintiffs’ right to seek attorneys’ fees up to that point in the litigation. ECF No. 35-1. The Court granted permissive intervention to the Republican Party of Virginia (“RPV”), ECF No. 60, which opposed entry of the consent decree, ECF No. 58.
After briefing and oral argument, the Court granted the motion and entered the partial consent decree and judgment. ECF Nos. 68, 69. In finding that the consent decree was fair, adequate, and in the public interest, the Court held that based on the record before it, there existed “a probable violation of federal law” which “further speaks to the strength of Plaintiffs’ case.” ECF No. 69 at 13. The Court explained that in the context of the pandemic, the witness requirement would “force a large class of Virginians to face the choice between adhering to guidance that is meant to protect not only their own health, but the health of those around them, and undertaking their fundamental right—and, indeed, their civic duty—to vote in an election,” but the “Constitution does not permit a state to force such a choice on its electorate.” Id. at 16. It further found that the witness requirement created a “substantial burden on the right to vote [that] has not been justified by countervailing, demonstrated interests in the witness requirement,” particularly
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because the “record does not demonstrate that it is especially effective in preventing voter fraud.” Id. at 17. The Court also found the agreement served the public interest “during the worst pandemic this state, country, and planet has seen in over a century,” id. at 21, and was not collusive, id. at 22– 26. Finally, although the Court allowed the RPV to intervene and present its views, it was “not convinced” that the consent decree imposed any duties or obligations on RPV that gave it a right to block the agreement. Id. at 26–28.
Following the entry of the consent decree, Plaintiffs sought discovery from the Defendants, including concerning data from the elections held this year compared to 2016 and 2018. For the towns and cities across Virginia that held local elections at the end of May this year, the witness requirement was still in place, in contrast to the June 23 Primary which was subject to the consent decree. In those May elections, the number of absentee ballots rejected for lack of a witness requirement rose, from 9 in 2016 and 25 in 2018 to 653 this year. See ECF No. 88-2 at 17–19. If Virginians vote in November at similar levels to 2016, vote absentee at the same rate in November as they did in May, and absentee ballots are rejected at the same rate as in May, there is a risk that more than 16,000 Virginia voters could have their absentee ballots rejected for lack of a witness signature. Id. at 19–20. This number includes only those individuals who attempt to vote absentee despite not having a witness, and not individuals discouraged from or fearful to vote for this reason.
On July 24, 2020, Plaintiffs filed a Motion for Preliminary Injunction requesting this Court prohibit Defendants from enforcing the witness requirement for all Virginia voters for the November election and for all subsequent elections in Virginia until such time as in-person interactions required by compliance with the witness requirement no longer pose a risk to public health and personal safety. ECF Nos. 87, 88. Plaintiffs’ motion further requested that Defendants be ordered to issue guidance instructing election officials to count otherwise validly cast absentee
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ballots missing a witness signature and conduct a public information campaign in conjunction with city and county election officials about the elimination of the requirement. Id.
With their brief in support, Plaintiffs submitted expert testimony from a highly qualified epidemiologist explaining the risks of enforcing the witness requirement for individuals who live by themselves and the risk of COVID-19 continuing through November, and from a University of Virginia public policy professor who offered evidence as to the significant negative effect of the witness requirements on many categories of Virginia voters during the pandemic. ECF Nos. 88-1, 88-2. They also submitted declarations from the Chief Election Officer of one of Virginia’s largest cities and a former Chief Election Officer of another Virginia city as to the impact and effectiveness of the witness requirement. ECF Nos. 88-5, 88-6. Plaintiffs also included declarations from all five individual plaintiffs, the President of the League of Women Voters of Virginia, six League members, and another Virginia voter—all testifying as to the severe burdens the witness requirement has created during the pandemic. ECF Nos. 88-3, 88-7, 88-8, 88-9, 88-10, 88-11, 88-12, 88-13, 88-14, 88-15, 88-16, 88-17, 88-18.
ARGUMENT A “consent decree has elements of both judgment and contract,” Smyth ex rel. Smyth v. Rivero, 282 F.3d 268, 280 (4th Cir. 2002). When “considering whether to enter a proposed consent decree, a district court should be guided by the general principle that settlements are encouraged.” United States v. North Carolina, 180 F.3d 574, 581 (4th Cir. 1999); see also Stovall v. City of Cocoa, Fla., 117 F.3d 1238, 1240 (11th Cir. 1997) (“District courts should approve consent decrees so long as they are not unconstitutional, unlawful, unreasonable, or contrary to public policy.”). This policy “to encourage settlements ‘has particular force where, as here, a government actor committed to the protection of the public interest has pulled the laboring oar in constructing
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the proposed settlement.’” United States v. E.I. du Pont de Nemours and Co., No. 5:16-CV-00082, 2017 WL 3220449, at *11 (W.D. Va. July 28, 2017) (quoting United States v. Cannons Eng’g Corp., 899 F.2d 79, 84 (1st Cir. 1990)).
Nonetheless, the Court “must satisfy itself that the agreement ‘is fair, adequate, and reasonable’ and ‘is not illegal, a product of collusion, or against the public interest.’” North Carolina, 180 F.3d at 581 (quoting United States v. Colorado, 937 F.2d 505, 509 (10th Cir. 1991)). It need not, however, “inquire into the precise legal rights of the parties nor reach and resolve the merits of the claims or controversy” because “it is precisely the desire to avoid a protracted examination of the parties’ legal rights that underlies entry of consent decrees.” Bragg v. Robertson, 83 F. Supp. 2d 713, 717 (S.D. W. Va. 2000), aff’d sub nom. Bragg v. W. Va. Coal Ass’n, 248 F.3d 275 (4th Cir. 2001).
The Parties meet all of the necessary requirements and have reached an agreement under circumstances that serves the public interest. I. The Court has Jurisdiction over the Partial Consent Judgment and Decree.
A “consent decree must spring from and serve to resolve a dispute within the court’s subject-matter jurisdiction.” Loc. No. 93, Int’l Ass’n of Firefighters, AFL-CIO C.L.C. v. City of Cleveland, 478 U.S. 501, 525 (1986). In terms of the subject-matter of this action, Plaintiffs’ claims squarely raise the sort of constitutional issue this Court is equipped to decide: whether state election practices burden the fundamental right to vote. See, e.g., Burdick v. Takushi, 504 U.S. 428, 434 (1992) (citing Anderson v. Celebrezze, 460 U.S. 780, 788–89 (1983)).
In terms of Article III standing, Plaintiffs have provided substantial evidence that they will be injured by the operation of the witness requirement during the November 3 election if the witness requirement remains in place. Therefore, they have established “a substantial risk” of harm, Susan B. Anthony List v. Driehaus, 573 U.S. 149, 158 (2014), that can be remedied with
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Case 6:20-cv-00024-NKM-RSB Document 96 Filed 08/05/20 Page 9 of 20 Pageid#: 2078
respect to the November election by waiving the witness requirement for voters who believe they may not safely have a witness present while completing their ballot.
Moreover, the substance of the agreement comes squarely within the scope of the case. Plaintiffs’ preliminary injunction sought relief from the witness requirement for the November election and any future elections affected by the spread of COVID-19. The agreement provides such relief for the November election for voters who believe they may not safely have a witness present while completing their ballot. The Court has subject-matter jurisdiction over this proposed consent decree. II. The Proposed Consent Decree is Fair, Adequate, and Reasonable.
The district court has discretion in determining whether a proposed consent decree is fair, adequate, and reasonable, but in doing so, it “must assess the strength of the plaintiff’s case.” North Carolina, 180 F.3d at 581. This review “does not require the court to conduct a trial or a rehearsal of the trial,” but “to ensure that it is able to reach an informed, just and reasoned decision.” Id. (internal citations and quotations omitted). This review should take into account “the extent of discovery that has taken place, the stage of the proceedings, the want of collusion in the settlement and the experience of plaintiffs’ counsel who negotiated the settlement.” Id. (internal citations and quotations omitted). Overall, courts must judge the fairness of the compromise “by weighing the plaintiff’s likelihood of success on the merits against the amount and form of the relief offered in the settlement” but they “do not decide the merits of the case or resolve unsettled legal questions.” Carson v. Am. Brands, Inc., 450 U.S. 79, 88 n.14 (1981) (internal citation omitted).
As to the stage of the case, it has progressed beyond where it was when the Court entered the first partial consent decree, and has allowed the parties an opportunity to begin conducting discovery. That discovery has yielded some useful information, including comparative numbers
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Case 6:20-cv-00024-NKM-RSB Document 96 Filed 08/05/20 Page 10 of 20 Pageid#: 2079
of ballots rejected for a lack of witness signature in local elections in 2016, 2018, and 2020— evidence that led Plaintiffs’ expert Dr. Holbein to opine that the witness requirement would result in over 16,000 Virginians having their absentee ballot rejected in November, putting aside the many other Virginians who would not attempt to vote at all due to the requirement and risk to their health. ECF No. 88-2 at 17–20. Nonetheless, the Court has already noted that because much of the necessary evidence comes from government reports and orders, public health policies, and expert declarations, “there is little indication this is a case for which the length or amount of discovery . . . will be particularly relevant to the strength of Plaintiffs’ case.” ECF No. 69 at 11.
And as before, with the November election approaching, with absentee voting beginning on September 19, the issues raised still demand time-sensitive resolution. Similarly, many of the concerns raised by Plaintiffs—including the severity of COVID-19 in Virginia and the anticipated risks associated with the witness requirement as applied to certain voters in Virginia for the November election—are matters of public record or offered through testimony of Plaintiffs’ epidemiologist and political participation experts. See ECF Nos. 88-1, 88-2.
Nonetheless, and as with the prior consent decree, this consent decree still only seeks partial relief and resolution of this action as it relates to Plaintiffs’ preliminary injunction, making some of these factors less weighty then they would be in the case of a final consent decree akin to a permanent injunction. See ECF No. 69 at 12 (noting that “the limited nature of the settlement agreement’s relief weighs in favor” of its fairness, adequacy, and reasonableness). Moreover, the Parties have each compromised in their positions in order to reach this agreement in recognition of the strength of Plaintiffs’ constitutional claim and the interest of the Commonwealth in (i) ensuring that all eligible Virginians need not jeopardize their health or public health to vote,
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Case 6:20-cv-00024-NKM-RSB Document 96 Filed 08/05/20 Page 11 of 20 Pageid#: 2080
(ii) protecting election integrity, and (iii) that resolution well before the general election will best
equip election officials to carry out their duties.
As to the strength of Plaintiffs’ case, on an even more limited record, the Court noted “the
clear strength of the Plaintiffs’ case,” ECF No. 69 at 19, and the “probable violation of federal
law” put forward, id. at 13. In their current preliminary injunction briefing (ECF No. 69), Plaintiffs
have put even more evidence that enforcing the witness requirement during this pandemic may
lead to disenfranchisement of a significant number of qualified Virginians, risks to public health,
or both. That evidence includes:
• A detailed report from a highly qualified epidemiologist explaining the risks of enforcing the witness requirement for individuals who live alone, the risks of voting in person during the pandemic, and the inevitability of COVID-19’s continuing transmission through this year, see ECF No. 88-1;
• Another thoroughly researched report from a University of Virginia professor explaining how the witness requirement will discourage voting from groups that already face barriers to voting, as well as evidence quantifying the potential for rejected ballots due to the witness requirement in November, see ECF No. 88-2;
• Declarations from the League about its members and from the individual Plaintiffs who provided credible testimony about how the witness requirement would burden their ability to vote in November and force them to put their health at risk, see ECF Nos. 883, 88-7, 88-8, 88-9, 88-10, 88-11, 88-12, 88-13, 88-14, 88-15, 88-16, 88-17, 88-18;
• Declarations from current and former Election Directors of Virginia cities as to the impact of the witness requirement during the pandemic, confusion created by the requirement, disenfranchisement of voters who cannot comply, and strength of existing mechanisms to prevent voter fraud in the absentee balloting process, see ECF Nos. 885, 88-6; and
• Statistical evidence from the Census Bureau and Virginia voter registration statistics that details the scale of the witness requirement’s potential impact on Virginians who live alone, and particularly on older Virginians, Virginians with disabilities, Black Virginians, and Virginians with poverty-level incomes, see ECF No. 88-2 at 13–15.
Given the likely impact of the witness requirement on many Virginia voters during the November
election, Plaintiffs had a real chance of success on their preliminary injunction motion regardless
of how the Court weighed the efficacy of the witness requirement in promoting election integrity.
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But the Court has already found that lifting or loosening the witness requirement was unlikely to harm election integrity, see ECF No. 69 at 18–19, and, indeed, the State Defendants are unaware of any issues of this kind in the June Primary when hundreds of thousands of Virginians voted.
Additionally, the fairness and reasonableness of the proposed decree is reflected in the concessions each Party made that nonetheless resulted in an agreement that will benefit all Parties and all Virginians. In their preliminary injunction, Plaintiffs sought an injunction against the witness requirement as to all Virginians not only for the November election but for all future elections affected by community transmission of COVID-19. ECF No. 87 at 2. Plaintiffs will continue to seek such relief as this litigation moves forward. They also requested attorneys’ fees in their operative complaint and would have likely sought those if they prevailed—an amount that the Court correctly noted would not be “an insignificant sum.” ECF No. 69 at 12. But the proposed consent decree provides Plaintiffs relief only for the November election and is targeted to the subset of Virginia voters who believe they may not safely have a witness present while completing their ballot and waives the right to any fees and costs. Nonetheless, it confers on Plaintiffs the right to vote in November that they would have otherwise been threatened or heavily burdened, and does so for many other Virginians, including some members of the League.
On Defendants’ side, though they have agreed not to enforce the witness requirement for the November election for voters who believe they cannot have a witness present while completing their ballot, they avoid the possibility of a broader preliminary injunction that would apply to the entirety of the witness requirement for a longer time period, as well as the risk of owing significant attorneys’ fees. They also gain the valuable benefit of having certainty as to the absentee ballot requirements well in advance of the election, and with sufficient time to incorporate appropriate instructions and provide guidance to local election officials. Additionally, they gain the substantial
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Case 6:20-cv-00024-NKM-RSB Document 96 Filed 08/05/20 Page 13 of 20 Pageid#: 2082
benefit—as do all Virginians—of avoiding public health consequences of larger numbers of qualified voters seeking to vote at the polls in November. As Plaintiffs’ preliminary injunction brief detailed, evidence and research has already found evidence of COVID-19 transmission occurring at the polls in other states. This includes 71 people who voted in-person in the Wisconsin primary who were diagnosed with COVID-19 shortly after. Reingold Decl. ¶ 21. As experts found after performing a multi-factor regression analysis and accounting for other potential causes, the April primary election likely accounted for approximately 700 more COVID-19 cases in Wisconsin.6
Further supporting the fairness and adequacy of the settlement, the Parties are each ably represented by experienced counsel. See ECF No. 69 at 10–11 (finding “the American Civil Liberties Union and American Civil Liberties Union of Virginia have provided fair and adequate legal counsel in representing Plaintiffs” and the “same can be said for the representation provided to the State Defendants in this case by the Virginia Office of the Attorney General”); see also Carcano v. Cooper, No. 1:16CV236, 2019 WL 3302208, at *6 (M.D.N.C. July 23, 2019). And “when a settlement has been negotiated by a specially equipped agency, the presumption in favor of settlement is particularly strong.” Md. Dep’t of the Env. v. GenOn Ash Mgt., LLC, No. CIV. PJM 10-0826, 2013 WL 2637475, at *1 (D. Md. June 11, 2013). Here, this presumption applies because the Parties are the Virginia State Board of Elections and Commissioner of the Department of Elections—each of which has specialized experience in safely administering elections in Virginia.
6 See also Dr. Chad D. Cotti, et al., The Relationship between In-Person Voting and COVID-19: Evidence from the Wisconsin Primary at 14, NBER Working Paper No. 27187, https://www.nber.org/papers/w27187.pdf (last updated June 2020).
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Case 6:20-cv-00024-NKM-RSB Document 96 Filed 08/05/20 Page 14 of 20 Pageid#: 2083
Because the proposed partial consent decree achieves a fair compromise that benefits all Parties and the public interest, it meets the criteria of fairness, adequacy, and reasonableness. III. The Proposed Consent Decree is in the Public Interest, and not Illegal or Collusive.
The public interest “favors permitting as many qualified voters to vote as possible.” League of Women Voters of N.C. v. North Carolina, 769 F.3d 224, 247–48 (4th Cir. 2014) (citations and internal quotation marks omitted). It also favors “safeguarding public health.” Pashby v. Delia, 709 F.3d 307, 331 (4th Cir. 2013). Each of these interests is advanced by this agreement. As the Court held in approving the first consent decree, an agreement “that permits the State Defendants to avoid the likely unconstitutional application of a state law . . . is neither unlawful, nor against the public interest.” ECF No. 69 at 21. Moreover, the evidence “points to the conclusion that adherence to the witness signature requirement” would increase the risk of COVID-19 transmission. Id.
Many voters in Virginia who live alone are able to both comply with social distancing protocols and have an individual witness their absentee ballot, and are unable to vote in-person, meaning that they would not be able to cast a vote or have their vote counted in November without this consent decree’s elimination of the witness requirement for these individuals. And this protection of the right to vote will happen without harming election integrity, especially “when considering all of the other means of combatting voter fraud integrated into the absentee-voting system.” ECF No. 69 at 18. Aside from the witness requirement, a plethora of other Virginia laws ensure proper absentee voting including provision of identifying information, a signed attestation confirming identity, eligibility, and lack of double-voting, and a check of the ballot against the list of ballot requests, see, e.g., Va. Code § 24.2-706, 1 Va. Admin. Code 20-70-20(B)(2)-(6), Va. Code § 24.2-710, and penalize malfeasance, see, e.g., Va. Code §§ 24.2-1004(B), 24.2-1012, 24.21016. Regardless, this proposed consent decree does not eliminate the witness requirement altogether and the witness signature line will remain on the ballot envelope, but does provide
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targeted relief to the subset of voters who believe they may not safely have a witness present while completing their ballot.
The proposed consent decree also serves public health in that it promotes the continuation of social distancing as recommended by the Governor and state and federal public health officials. In light of the seriousness of the COVID-19 health crisis, Governor Northam has declared a State of Emergency that continues to this day, VDH continues to urge Virginians to do their “part to help stop the spread of COVID-19 by staying at home as much as possible,” asks all Virginians to “practice social distancing,” and encourages those aged 65 and older to self-quarantine.7 Similarly, federal guidelines state: “[e]veryone [s]hould . . . avoid close contact” by “stay[ing] home as much as possible” and “put[ting] 6 feet of distance between yourself and people who don’t live in your household.”8 The CDC’s guidance on elections specifically warns that “[t]he more an individual interacts with others, and the longer that interaction, the higher the risk of COVID-19 spread,” and “[e]lections with only in-person voting on a single day are higher risk for COVID-19 spread because there will be larger crowds and longer wait times.”9 And as of August 3, VDH reported that there were over 93,000 cases and over 2,200 deaths in the State.10
Moreover, this agreement is neither illegal nor collusive. The agreement is necessary to protect the constitutional rights of Virginia’s voters and “violations of federal rights justify the imposition of federal remedies.” Common Cause Ind. v. Marion Cty. Election Bd., No. 1:17-CV01388-SEB-TAB, 2018 WL 3770134, at *2 (S.D. Ind. Aug. 9, 2018). The Court “has the authority
7 See supra notes 3–4. 8 See supra note 5. 9 Ctrs. for Disease Control & Prevention, Considerations for Election Polling Locations and Voters, https://www.cdc.gov/coronavirus/2019-ncov/community/election-polling-locations.html (last visited Aug. 4, 2020). 10 See Va. Dep’t of Health, COVID-19 Cases in Virginia, https://www.vdh.virginia.gov/coronavirus/covid-19-dailydashboard/ (last visited Aug. 4, 2020).
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to approve a settlement that modifies state law. Federal courts have broad power to remedy violations of the federal Constitution.” Dillard v. City of Foley, 926 F. Supp. 1053, 1065 (M.D. Ala. 1995) (citing Missouri v. Jenkins, 495 U.S. 33, 57 (1990) and Dillard v. Crenshaw County, 831 F.2d 246, 248 (11th Cir. 1987)).
Finally, this agreement was the product of a good-faith negotiation. It was only after Plaintiffs sought and received discovery and filed a preliminary injunction motion supported by extensive evidence for November and future elections that negotiations resulted in this agreement. Nor is there any concern here about “elected state officials seek[ing] to bind their successors as to a matter about which there is substantial political disagreement,” Carcano, 2019 WL 3302208, at *6, as this agreement only covers the November 2020 general election. As the Court already found, this hard-fought partial settlement does “not remotely resemble” cases in which prior courts have rejected settlements as collusive. ECF No. 69 at 23.
The proposed Partial Consent Judgment and Decree therefore serves the public interest and is neither illegal nor collusive. IV. Intervenor-Defendant Republican Party of Virginia Lacks Standing to Block Entry
of This Consent Decree. As this Court previous recognized, “while an intervenor is entitled to present evidence and have its objections heard at the hearings on whether to approve a consent decree, it does not have power to block the decree merely by withholding its consent.” Local No. 93, Intern. Ass’n of Firefighters, AFL-CIO C.L.C. v. City of Cleveland (“Local No. 93”), 478 U.S. 501, 528–29 (1986) (internal citations omitted). Of course, if an intervening party has an independent claim, then a consent decree “cannot dispose of the valid claims of nonconsenting intervenors.” Id. at 529. But here, the RPV has no claims. And even though the proposed consent decree does not alter any rights of the RPV, “consent decrees can alter the state law rights of third parties . . . where the
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Case 6:20-cv-00024-NKM-RSB Document 96 Filed 08/05/20 Page 17 of 20 Pageid#: 2086
change is necessary to remedy a violation of federal law.” ECF No. 69 at 28 (quoting State v. City of Chicago, 912 F.3d 979, 988 (7th Cir. 2019) (internal citations and quotations omitted)).
In fact, it is even more clear than during consideration of the last consent decree that the RPV has no concrete or particularized injuries due to this proposed consent decree. Last time, the RPV incorrectly argued that their associational rights to control the conduct of the primary election were affected, notwithstanding that the Commonwealth controls voter qualifications and the Party controls the method of candidate selection, whereas the witness requirement was and remains an election administration procedure. But with the June primary out of the way, the RPV does not even have that associational interest to assert here, given that it is a general election. And, as was true before, the proposed consent decree does not “bind the RPV to take or not to take any action,” and it “does not reference the RPV or any other political party whatsoever.” Id. at 27. “‘It imposes no legal duties or obligations’ on the RPV and ‘only the parties to the decree can be held in contempt of court for failure to comply with its terms,’” and it “does not purport to resolve or otherwise extinguish any claims that the RPV might have.” Id. at 27–28 (quoting Local No. 93, 478 U.S. at 529–30).
Rather, the RPV’s own communications make it clear that its concerns are not unique to it or capable of actual injury from entry of the consent decree, but rather generalized interests in election integrity. For example, the day after this Court entered the first partial consent decree, RPV Chairman Jack R. Wilson, III sent out a fundraising email stating that “Virginia’s liberal courts sided with the ACLU” and “[a]nti-fraud measures will not be required for absentee ballots for the June 23 primary,” but there was still time to “prevent the ACLU and the liberal Attorney General from making voter fraud easier for the November election.” (attached as Ex. A). Similarly, the day the Court allowed the RPV to intervene in the case, the RPV posted on Twitter that it was
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Case 6:20-cv-00024-NKM-RSB Document 96 Filed 08/05/20 Page 18 of 20 Pageid#: 2087

“fighting the ACLU in court over their attempts to delegitimize our elections. We need your help to protect election integrity.” (attached as Ex. B).
CONCLUSION As before, the Plaintiffs and Defendants have negotiated an agreement that serves the public interests of election integrity, access to the ballot, and protecting public health. They have done so based on an even more complete factual record than last time, and in the context of a pandemic that continues to get worse. Because this decree meets all of the necessary requirements and considering that “settlements are encouraged” as a matter of public policy, North Carolina, 180 F.3d at 581, the Parties request that the Court approve the Partial Consent Judgment and Decree.

Dated: August 5, 2020

Respectfully submitted,

/s/ Davin M. Rosborough______________ Davin M. Rosborough (VSB # 85935) Dale E. Ho* Sophia Lin Lakin* Theresa J. Lee* Adriel I. Cepeda-Derieux* American Civil Liberties Union Foundation 125 Broad Street, 18th Floor New York, NY 10004 Tel.: (212) 549-2500 drosborough@aclu.org dho@aclu.org slakin@aclu.org tlee@aclu.org acepedaderieux@aclu.org
Vishal Agraharkar (VSB #93265) Eden Heilman (VSB #93554) AMERICAN CIVIL LIBERTIES UNION FOUNDATION OF AMERICA, INC. 701 E. Franklin Street, Suite 1412 Richmond, Virginia 23219

MARK R. HERRING Attorney General of Virginia By: /s/ Carol L. Lewis CAROL L. LEWIS (VSB #92362) MICHELLE S. KALLEN (VSB # 93286) HEATHER HAYS LOCKERMAN (VSB #65535) CALVIN C. BROWN (VSB #93192) Office of the Attorney General 202 North Ninth Street Richmond, Virginia 23219 804-692-0558 (telephone) 804-692-1647 (facsimile) clewis@oag.state.va.us
Attorneys for Robert H. Brink, John O’Bannon, Jamilah D. LeCruise and Christopher E. Piper in their official capacities, and the Virginia State Board of Elections

17

Case 6:20-cv-00024-NKM-RSB Document 96 Filed 08/05/20 Page 19 of 20 Pageid#: 2088 Phone: (804) 644-8080 Fax: (804) 649-2733 vagraharkar@acluva.org eheilman@acluva.org Attorneys for Plaintiffs *Admitted pro hac vice.
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Case 6:20-cv-00024-NKM-RSB Document 96 Filed 08/05/20 Page 20 of 20 Pageid#: 2089 CERTIFICATE OF SERVICE
I certify that on August 5, 2020, I served a copy of the foregoing Brief in Support of Joint Motion for Entry of Partial Consent Judgment and Decree via filing with the Court’s CM/ECF system, which sent copies of this document to Counsel of Record.
/s/ Davin M. Rosborough _______________ Davin M. Rosborough (VSB # 85935) American Civil Liberties Union Foundation 125 Broad Street, 18th Floor New York, NY 10004 Tel.: (212) 549-2500 drosborough@aclu.org Counsel for Plaintiffs
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Case 6:20-cv-00024-NKM-RSB Document 96-1 Filed 08/05/20 Page 1 of 2 Pageid#: 2090
EXHIBIT A

From: Jack Wilson <info@rpv.org> Date: May 6, 2020 at 5:03:14 PM EDT Subject: The Court Made a Decision on Voter Fraud Reply‐To: info@rpv.org
You're not going to like this...

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- I'll be blunt: Virginia's liberal courts sided with the ACLU. Anti-fraud measures will not be required for absentee ballots for the June 23 primary.
But there is still time! Because of you, Republican Party of Virginia was able to prevent the ACLU and the liberal Attorney General from making voter fraud easier for the November election... for now
The fight is not over!
Liberals are trying to take away election protections for November because that's the only way they can defeat President Trump. The Republican Party of Virginia is heading back to court against the ACLU. Can you chip in to help cover the court costs?

Contribute to Fight Back

Jack R. Wilson, III Chairman Republican Party of Virginia
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Case 6:20-cv-00024-NKM-RSB Document 96-1 Filed 08/05/20 Page 2 of 2 Pageid#: 2091
P.S. - Grassroots activists like you are the last line of defense between Democrats and vulnerable Virginia families.
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Jack Wilson 115 E Grace Street Richmond, VA 23219
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 </s> Case 6:20-cv-00024-NKM-RSB Document 109 Filed 08/21/20 Page 1 of 28 Pageid#: 2314

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF VIRGINIA
LYNCHBURG DIVISION

8/21/2020

LEAGUE OF WOMEN VOTERS OF VIRGINIA, et al.,
v.

Plaintiffs,

CASE NO. 6:20-CV-00024 MEMORANDUM OPINION

VIRGINIA STATE BOARD OF ELECTIONS, et al.,

JUDGE NORMAN K. MOON Defendants.

In this action, the League of Women Voters of Virginia and several voters have sued the Virginia State Board of Elections and a number of state officials, arguing that Virginia’s witness signature requirement for absentee ballots is an unconstitutional burden on the right to vote as applied during the COVID-19 pandemic. The parties later reached a partial settlement, and the Court approved their joint request for a consent decree that would enjoin enforcement of the witness signature requirement for Virginia’s primaries on June 23, 2020, for voters who believe they may not safely have a witness present while completing their ballot. Plaintiffs later filed a second motion for a preliminary injunction, and the parties then reached another partial settlement and now jointly seek approval of a second consent decree that would enjoin the witness signature requirement for Virginia’s elections on November 3, 2020, for the same group of at-risk voters. The same reasons that motivated the Court to approve the parties’ previous consent decree carry even more force today, as the pandemic has resurged. Thus, the Court will grant the motion and approve the agreement, which does not address any election beyond the November 3, 2020 elections.

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Case 6:20-cv-00024-NKM-RSB Document 109 Filed 08/21/20 Page 2 of 28 Pageid#: 2315

A. Factual Background

I.

BACKGROUND

The Court incorporates the background set forth in its prior opinion, League of Women

Voters of Va. v. Va. State Bd. of Elections, No. 6:20-cv-00024 (Dkt. 69), --- F. Supp. ---, 2020 WL

2158249 (W.D. Va. May 5, 2020), as supplemented by the more recent significant factual

developments included in the record since that point and as set forth below.

1. The COVID-19 Pandemic

Over five months ago, Virginia Governor Ralph Northam declared a state of emergency in

response to the emergence of COVID-19. Va. Exec. Order No. 2020-51 (March 12, 2020). On

May 26, 2020, the Governor extended the state of emergency in response to the continued public

health threat posed by COVID-19, pursuant to an amended version of Executive Order 51. Va.

Exec. Order No. 2020-51 Amended (May 26, 2020). This declaration remains in effect until it has

been rescinded or amended by a subsequent order. Id.

Despite the efforts of state and local officials in the Commonwealth, the pandemic rages

on. State health guidelines continue to instruct everyone to stay home as much as possible and to continue social distancing practices.1 Federal guidelines, issued by the Centers for Disease Control

and Prevention (“CDC”), continue to instruct people to “[p]ut 6 feet of distance between yourself

1 See Va. Dep’t of Health, Prevention Tips, https://www.vdh.virginia.gov/coronavirus/prevention-tips/ (last accessed Aug. 21, 2020).
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Case 6:20-cv-00024-NKM-RSB Document 109 Filed 08/21/20 Page 3 of 28 Pageid#: 2316
and people who don’t live in your household.”2 The CDC has also instructed jurisdictions to “offer alternative voting methods that minimize direct contact.”3
There remains no dispute that, based on the Census Bureau’s 2018 Current Population Survey, over twenty-five percent of Virginians over the age of eighteen live alone. Dkt. 103 (Joint Proposed Findings of Fact and Conclusions of Law) at ¶ 55.4 Nor do the parties dispute that some at-risk populations are more likely to live alone, such as Virginians over the age of sixty-five. Id. While “[p]eople of every age can and have contracted COVID-19, including severe cases . . . geriatric patients are at the greatest risk of severe cases, long-term impairment, and death.” Dkt. 88-1 (Decl. of Dr. Arthur L. Reingold) at ¶ 8. This is also true of those “with immunologic conditions and with other pre-existing conditions, such as hypertension, certain heart conditions, lung diseases . . . diabetes mellitus, obesity, and chronic kidney disease.” Id.
When this Court granted the parties’ first motion for a partial consent decree and judgment, the Virginia Department of Health had calculated over 20,000 confirmed or probable cases of COVID-19, over 2,700 hospitalizations, and over 700 deaths attributed to the disease in the Commonwealth alone. League of Women Voters of Va., No. 6:20-cv-00024 (Dkt. 69), 2020 WL 2158249, at *2. In the three months since then, these numbers have now soared above 110,000
2 Centers for Disease Control and Prevention, Coronavirus Disease 2019 (COVID-19), How to Protect Yourself & Others, available at https://www.cdc.gov/coronavirus/2019ncov/prevent-getting-sick/prevention.html (last accessed Aug. 20, 2020).
3 Centers for Disease Control and Prevention, Recommendations for Election Polling Locations, available at https://www.cdc.gov/coronavirus/2019-ncov/community/election-pollinglocations.html (last accessed Aug. 20, 2020).
4 citing 2018 Current Population Survey, U.S. Census Bureau, statistics accessed by using the Census Bureau Current Population Survey Table Creator tool at https://www.census.gov/cps/data/cpstablecreator.html.
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confirmed or probable cases of COVID-19, over 9,000 hospitalizations, and over 2,400 deaths.5 As before, the data likely undercount the actual number of positive cases because of the Commonwealth’s limitations with regard to testing capacity. Dkt. 88-1 (Decl. of Dr. Arthur L. Reingold) at ¶ 11; Dkt. 103 (Joint Proposed Findings of Fact and Conclusions of Law) at ¶ 49. Indeed, this is true throughout the United States. Dkt. 88-1 (Decl. of Dr. Arthur L. Reingold) at ¶ 11.
On July 1, 2020, the Commonwealth began Phase Three of its three-phase re-opening. Va. Exec. Order No. 2020-67 (June 30, 2020). Among other changes, the Governor’s Phase Three Reopening order removes the capacity restrictions for a number of business sectors, including retail and restaurants,6 and expands the limits on public and private gatherings to permit gatherings of up to 250 people.7 Id. at 9. Phase Three still requires businesses to comply with social distancing practices and face-mask requirements. See, generally, id. On July 28, 2020, the Governor rolled back this re-opening for certain jurisdictions in the Hampton Roads region in response to “disturbing trends in connection with the increasing number of [COVID-19] cases. Va. Exec. Order 2020-68 Amended (Aug. 3, 2020). These restrictions reduced the permitted size of public and private in-person gatherings down to no more than 50 people and imposed operating-hours limitations on venues that serve alcohol. Id.
5 Virginia Department of Health, COVID-19 & You, available at https://www.vdh.virginia.gov/coronavirus/covid-19-daily-dashboard/ (last accessed Aug. 21, 2020). In a reflection of the rapid pace of the virus’s destruction, I have had to continually revise these numbers upward in the span of time I have spent writing this opinion.
6 Other business sectors, such as entertainment and amusement venues, racetracks and speedways, and fitness and exercise studios, do still have occupancy restrictions in place. See Va. Exec. Order 2020-67 (June 30, 2020) at 4, 7–8.
7 This number is up from 50 people during Phase Two. Va. Exec. Order 2020-65 Amended, at 11 (June 9, 2020).
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2. Virginia’s Absentee Voting Scheme Va. Code § 24.2-612 requires that absentee ballots be made available forty-five days prior
to the November 3, 2020 elections—Saturday, September 19, 2020. Or, in localities whose general registrar is closed on that day, ballots must be made available on Friday, September 18, 2020. Dkt. 95-1 at ¶ 18; see Dkt. 88-6 (Decl. of Stephanie L. Liles), at ¶ 6.
General registrars maintain lists of voters who have requested and returned absentee ballots, and absentee ballots are only accepted from voters whose names are on that list. Dkt. 643 at ¶ 7. Upon receiving a valid request for an absentee ballot and confirming that the applicant is a registered voter in the jurisdiction, the registrar provides an absentee voter’s package, which includes the following: a sealed envelope containing the ballot and a second envelope containing printed instructions as well as a “Statement of Voter” form, which the absentee voter is required to sign, attesting to their identity, residency status, and that they “marked the ballot(s) in the presence of [a] witness, without assistance or knowledge on the part of anyone as to the manner in which [the voter] marked it” and that they the voter has “not voted and will not vote in this election at any other time or place.” Va. Code § 24.2-706; see Dkt. 84 at ¶ 70.
Pertinent here, Va. Code §§ 24.2-706 and 24.2-707—the provision Plaintiffs challenge as unconstitutional as applied—require that the absentee voter “mark[] the ballot(s) in the presence of [a] witness, without assistance or knowledge on the part of anyone as to the manner in which [the voter] marked it” and that the voter personally attest to the ballot being so witnessed. See Dkt. 84 at ¶ 70. Individuals who make a willfully false material statement or entry on an absentee ballot are at risk of being charged with a Class 5 felony. Va. Code § 24.2-1012. And anyone who falsely signs the name of a different qualified voter on a ballot is at risk of being charged with a Class 4 felony. Va. Code § 24.2-1012.
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A voter’s failure to obtain a witness signature on their absentee ballot is an omission that is “always material” that renders the ballot invalid. See 1 Va. Admin. Code 20-70-20(B); Dkt. 1 at ¶ 70. However, “[t]he illegibility of a voter’s or witness’s signature . . . shall not be considered an omission or error.” 1 Va. Admin. Code 20-70-20(C)(10); see Dkt. 84 at ¶ 75; Dkt. 91 at ¶ 75.
In the May 2020 primary, which required absentee ballots to include a witness signature, 653 ballots were rejected for lack of a witness signature. This is a substantial increase over the 9 ballots rejected for this reason in 2016 and 25 rejected in 2018, Dkt. 96 at 6 (citing Dkt. 88-2 at 17–19). The parties dispute whether this increase resulted from some voters’ fear of obtaining a witness safely or whether it was the result of public confusion over the extent of this Court’s previous consent decree and the parties’ statements regarding it. Compare Dkt. 99 at 12, with Dkt. 88 at 26. Regardless, the Plaintiffs have put forth evidence supporting the claim that, if absentee ballots are rejected at the same rate as in May and historical patterns of absentee ballot usage and turnout hold, nearly 17,000 voters would have their ballots rejected for failure to meet the witness signature requirement. Dkt. 88-2 (Decl. of Dr. John B. Holbein) at 20.
B. Procedural History On April 17, 2020, the League of Women Voters of Virginia and three individual voters—
Katherine D. Crowley, Erikka Goff, and Seijra Toogood—(“Plaintiffs”) sued the Virginia State Board of Elections and, in their official capacities, its Chairman (Robert H. Brink), Vice-Chair (John O’Bannon), and Secretary (Jamilah D. LeCruise), as well as the Commissioner of the Virginia Department of Elections (Christopher E. Piper) (“State Defendants”), seeking to enjoin enforcement of Va. Code § 24.2-707(A), which mandates that all absentee ballots be signed by a witness before submission. Dkt. 1 at ¶¶ 1–2. Given the public health crisis spawned by the COVID-
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19 pandemic, Plaintiffs argue that the requirement unduly burdens their right to vote. Plaintiffs filed their second amended complaint on July 17, 2020. Dkt. 84.
On April 21, 2020, Plaintiffs moved for a preliminary injunction that: (1) would have prohibited State Defendants from enforcing the aforementioned witness requirement for all Virginia voters for the June 23, 2020 primaries and for any and all subsequent elections in Virginia until such time as in-person interactions required by compliance with the witness requirement no longer pose a risk to public health and personal safety; (2) would have ordered State Defendants to issue guidance instructing city and county election officials to count otherwise validly cast absentee ballots that are missing a witness signature for Virginia’s June 23 primary elections; and (3) would have ordered State Defendants to conduct a public information campaign informing Virginia voters about the elimination of this requirement, in coordination with city and county election officials. Dkt. 16.
Just days after Plaintiffs filed their motion for a preliminary injunction, two groups sought to intervene in this case: a group of three voters, Dkt. 22, and the Republican Party of Virginia (“RPV”) together with another three voters (Vincent E. Falter, Mildred H. Scott, and Thomas N. Turner, Jr.), Dkt. 28. After the motions to intervene were fully briefed, the Court heard arguments on the motions and denied intervention as to the six voters, but it permitted the RPV to intervene as a defendant in the suit. Dkts. 55, 57. The Court permitted the first group of three voters who were denied intervention in this suit to file amicus briefs in the case and treated all briefs it had filed thus far as amicus briefs. Dkt. 55 at 1 n.1.
On April 27, 2020, Plaintiffs and State Defendants filed their “Joint Motion for Entry of Partial Consent Judgment and Decree,” Dkt. 35, which would resolve these parties’ dispute over the application of the witness signature requirement for only the June primary elections. The Court
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held a second status conference on April 29, 2020, to preliminarily discuss the impact of the joint motion for a partial consent decree on this case. Dkt. 39. On April 30, 2020, the RPV filed a brief opposing the approval of the consent decree. Dkt. 58. The next day, Plaintiffs and State Defendants filed their reply briefs in support of their proposed agreement. Dkts. 62, 64. That week, the Court also accepted three amicus briefs in this case.
On May 4, 2020, the Court heard oral argument from Plaintiffs, State Defendants and Intervenor-Defendant RPV on the merits of both the pending motion for a preliminary injunction, Dkt. 16, and the motion for approval of the consent decree, Dkt. 35. The next day, the Court issued a Memorandum Opinion and Order approving the Plaintiffs and State Defendants’ partial consent decree. Dkt. 68. Pursuant to that consent decree, Plaintiffs then withdrew their first motion for a preliminary injunction. Dkt. 73.
On July 24, 2020, the Plaintiffs filed a second motion for a preliminary injunction. Dkt. 87. This second motion sought substantially the same relief as Plaintiffs’ first motion for a preliminary injunction—the key difference being that such relief would apply to the November 3, 2020 elections rather than the already completed June 23, 2020 primaries. The Court ordered expedited briefing on the motion. Dkt. 94. Twelve days after the filing of the second motion for a preliminary injunction, Plaintiffs and State Defendants reached another a partial settlement and filed a joint motion to approve a partial consent judgment and decree, which would enjoin the witness signature requirement for only the November 3, 2020 general election. Dkt. 95. This was supplemented on August 20, 2020, to clarify that the parties intended the term “general election” to encompass all elections held in Virginia on November 3, 2020—including the twenty-seven special elections
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being held that day and any ballot referenda or other measures appearing on ballots.8 Dkt. 108-1 at ¶ 1 (stating that “in referring to the ‘November 3, 2020 General Election’ and the ‘November Election’ [in the proposed partial consent decree, the Plaintiffs and State Defendants] intended to include all elections and measures for which Virginia voters are able to cast ballots with an election date of November 3, 2020, including any special elections, ballot referenda, or other measures appearing on Virginia voters’ ballots that are set to that Election Date.”).
On August 14, the Court heard oral argument from Plaintiffs, State Defendants, and the RPV on the merits of the motion to approve the proposed consent judgment and decree as well as the second motion for a preliminary injunction. On August 18, 2020, the Court received joint proposed findings of fact and conclusions of law from the RPV and the Plaintiffs9 as well as individual findings from the RPV, the Plaintiffs, and the State Defendants. Dkts. 103–106. The State Defendants’ proposed findings expressly endorse and agree with Plaintiffs’ proposed individual findings, with the exception of ¶ 24. Dkt. 106.
C. Proposed Partial Consent Decree On August 5, 2020, Plaintiffs and the State Defendants filed their “Joint Motion for Entry
of Partial Consent Judgment and Decree,” Dkt. 95, which would resolve these parties’ dispute over the application of the witness signature requirement for only the upcoming November 3, 2020 elections. The proposed partial consent judgment and decree provides in part:
Defendants shall issue updated instructions to include with all absentee ballots as provided in Va. Code. § 24.2-706—or issue guidance instructing all relevant city 8 The Court will use the term “November 3, 2020 elections” to refer to all elections and measures for which Virginia voters are able to cast ballots on that date. 9 The Court appreciates the parties’ substantial efforts to reach agreement wherever possible on aspects of the factual background of this case. The Court has found the parties’ joint proposed findings of fact as well as individual proposed findings very useful in its disposition of this motion.
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and county election officials to modify or amend the printed instructions accompanying each absentee ballot— to inform voters that any absentee ballot cast in the November Election without a witness signature will not be rejected on that basis and specifically inform voters in bold print that they may disregard the witness signature line on the absentee ballot envelope if they believe they may not safely have a witness present while completing their ballot. Dkt. 95-1 at 8. The Commissioner of the Virginia Department of Elections would also be required under this agreement to undertake “additional reasonable steps to inform the public that the witness requirement will not be enforced for those absentee voters who believe they may not safely have a witness present while completing their ballot, and issue guidance instructing all relevant city and county election officials to do the same.” Id. at 8–9. Plaintiffs would then withdraw their motion for a preliminary injunction and waive any entitlement to attorneys’ fees and costs that have accrued up to the date the agreement is approved by the Court. Id. at 9 To be clear, this agreement is limited in duration and scope to elections and ballot measures for a single date: November 3, 2020. As with this Court’s prior consent decree, this subsequent proposed consent decree does not address any future election. Dkt. 95 at 7.
II. LEGAL STANDARD Consent decrees have a dual nature, carrying elements “of both judgment and contract.” Szaller v. Am. Nat. Red Cross, 293 F.3d 148, 152 (4th Cir. 2002). As such, the Fourth Circuit has instructed courts to scrutinize their terms in order to first determine whether such agreements are “fair, adequate, and reasonable” and also to ensure that in approving and issuing a consent judgment, that a court does not stamp its imprimatur upon an agreement that is “illegal, a product of collusion, or against the public interest.” United States v. North Carolina, 180 F.3d 574, 581 (4th Cir. 1999); see Ohio Valley Envt’l Coal. v. Pocahontas Land Corp., No. 2:15-cv-15515, 2017 WL 988115, at *2 (S.D. W. Va. Mar. 14, 2017). In all this, courts should “be guided by the general principle that settlements are encouraged . . . [but] should not blindly accept the terms of a
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proposed settlement.” United States v. North Carolina, 180 F.3d at 581. In considering a proposed consent decree, the Court must assess “the strength of the plaintiff’s case,” id. (citing Flinn v. FMC Corp., 528 F.2d 1169, 1173 (4th Cir. 1975)), and
[w]hile this assessment does not require the court to conduct “a trial or a rehearsal of the trial,” the court must take the necessary steps to ensure that it is able to reach “an informed, just and reasoned decision.” Id. (internal quotation marks omitted.) In particular, the “court should consider the extent of discovery that has taken place, the stage of the proceedings, the want of collusion in the settlement and the experience of plaintiffs’ counsel who negotiated the settlement.” Id. (quoting Carson v. American Brands, Inc., 606 F.2d 420, 430 (4th Cir. 1979) (en banc) (Winter, J., dissenting), adopted by Carson v. Am. Brands, Inc., 654 F.2d 300, 301 (4th Cir. 1981) (en banc) (per curiam)); see United States v. E.I. du Pont de Nemours & Co., No. 5:16-cv-00082, 2017 WL 3220449, at *11 (W.D. Va. July 28, 2017). As in this case, “when a settlement has been negotiated by a specially equipped agency, the presumption in favor of settlement is particularly strong.” Md. Dept. of Env’t v. GenOn Ash Mgmt., LLC, Nos. 10-cv-0826, 11-cv-1209, 12-cv-3755, 2013 WL 2637475, at *1 (D. Md. June 11, 2013).
III. ANALYSIS The proposed settlement agreement now before the Court is nearly identical to that which this Court approved on May 5, 2020. The key difference, of course, is that it applies to the November 3, 2020 elections as opposed to the June 23, 2020 primaries. Importantly, just last week both the First Circuit and the Supreme Court denied the Republican National Committee and Rhode Island Republican Party’s (intervenor-defendants in that case) application to stay a consent decree between Rhode Island and voting rights groups issued by District of Rhode Island. Republican Nat. Comm. v. Common Cause RI, No. 20A28, 2020 WL 4680151, at *1 (U.S. Aug. 13, 2020). As here, the Rhode Island consent decree enjoined the state’s witness signature requirement for absentee voting.
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The Supreme Court held that “here the state election officials support the challenged decree, and no state official has expressed opposition. Under [these] circumstances, [the political party] applicants lack a cognizable interest in the State’s ability to ‘enforce its duly enacted’ laws.” Id. (internal citations omitted). Further, the Court stated how the status quo in Rhode Island during the pandemic was set in that state’s previous election, which had suspended the witness signature requirement, and it indicated that changing it could confuse the “many voters” who could be under the belief that it was also suspended for later elections. Id. For these reasons, the Supreme Court distinguished its prior recent Order granting the stay of a district court’s order that had enjoined a witness signature requirement in Alabama, Merrill v. People First of Ala., No. 19A1063, 2020 WL 3604049 (U.S. July 2, 2020).
The same reasons underlying the District of Rhode Island’s approval of the consent decree support this Court’s approval of Virginia’s proposed partial consent decree in this case. There is little, if any, meaningful difference between the pending motion to approve the proposed consent decree currently before this Court and the Rhode Island consent decree recently before Supreme Court, First Circuit, and District of Rhode Island. Consequently, the reasoning in those decisions has provided significant guidance to the Court in deciding this motion.
The Court has scrutinized the terms of the proposed partial consent decree, Dkt. 95-1, and all other submissions in the record. The briefing and oral argument in support of and against the proposed partial consent decree were ably presented by counsel. As the following analysis explains, the Court has determined that, based on the strength of Plaintiffs’ case and the quality of the counsel representing the parties to the agreement, as well as the other factors for consideration, the proposed consent decree is “fair, adequate, and reasonable.” Further, the Court finds that that
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this agreement is in the public interest, and that it is not unlawful or the product of collusion between the drafting parties. The Court will approve the proposed consent decree.
A. Fair, Adequate, and Reasonable In analyzing whether an agreement is fair, adequate, and reasonable, the Court must
examine the strength of the plaintiff’s case. United States v. North Carolina, 180 F.3d at 581 (citing Flinn, 528 F.2d at 1172–73). The Fourth Circuit has further directed courts to consider “the extent of discovery that has taken place, the stage of the proceedings, the want of collusion in the settlement and the experience of plaintiffs’ counsel who adopted the settlement.” United States v. North Carolina, 180 F.3d at 581.
This Court has already determined that the respective counsel for the parties who proposed the settlement provided fair and adequate legal counsel in representing Plaintiffs and State Defendants in their settlement negotiations. League of Women Voters of Va., No. 6:20-cv-00024 (Dkt. 69), 2020 WL 2158249, at *5. The case is now in a more advanced stage of proceedings than when the Court approved the previous consent decree. Indeed, Plaintiffs sought discovery, including on election data for the 2016, 2018, and 2020 elections, Dkt. 96 at 6, and responsive pleadings have been entered in the case, Dkts. 91, 93. These factors point in favor of the fairness, adequacy, and reasonableness of the consent decree.
The Court also finds that the limited nature of the settlement agreement’s relief weighs in favor of a finding that it is “fair, adequate, and reasonable.” See United States v. North Carolina, 180 F.3d at 581. Like the prior consent decree, the proposed consent decree is limited in duration and scope to elections and ballot measures for a single date: November 3, 2020.
The RPV argues that the Plaintiffs and State Defendants’ failure to address other portions of Virginia law that require witness signatures, such as the Commonwealth’s emergency absentee
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ballot scheme, somehow makes the agreement before the Court less fair, reasonable, or adequate. But, if anything, this fact reflects the limited nature of the agreement. Virginia’s emergency absentee ballot scheme under Va. Code 24.2-705 was not challenged in Plaintiffs’ complaint. Moreover, Virginia’s emergency absentee ballot scheme permits a voter’s designated representative to request an absentee ballot up until 2:00 PM on the day before the election—this involves different risks than when the absentee voter requests the ballot on their own. Virginia law requires a witness to sign the request form that the voter completes and signs in order to obtain the emergency ballot, and it requires the designated representative who obtained the ballot to witness the voter voting the ballot.
The benefit of the witness signature requirement in this context is clearly more significant, and this is reflected by the verification procedures in place for identifying the designated representative who obtains the ballot for the voter and witnesses them vote the ballot. Va. Code § 24.2-705 (“The designated representative shall complete a statement, subject to felony penalties for making false statements pursuant to § 24.2-1016, that (i) he is the designated representative of the requesting voter; (ii) he personally delivered the ballot to the voter who applied for it; (iii) in his presence, the voter marked the ballot, the ballot was placed in the envelope provided, the envelope was sealed, and the statement on its reverse side was signed by the requesting voter; and (iv) the ballot was returned, under seal, to the general registrar at the registrar's office.”). That the parties would not, pursuant to a settlement, seek to enjoin a law that was not challenged by the Plaintiffs should be expected. Contrary to the RPV’s contention, the failure to do so does not mean the proposed consent decree is any less fair, adequate, or reasonable.
It is also significant to the Court that Plaintiffs continue to plead a probable violation of federal law. See Kasper v. Bd. of Election Comm’rs of the City of Chi., 814 F.2d 332, 342 (7th Cir.
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1987); League of Women Voters of Va., No. 6:20-cv-00024 (Dkt. 69), 2020 WL 2158249, at *6. The Supreme Court has made clear that it has not identified any “litmus test for measuring the severity of a burden that a state law imposes on a political party, an individual voter, or a discrete class of voters.” Crawford v. Marion Cty. Election Bd., 553, U.S. 181, 191 (2008). Rather, “however slight that burden may appear” the reviewing court must find that it is “justified by relevant and legitimate state interests ‘sufficiently weighty to justify the limitation.’” Id. (quoting Norman v. Reed, 502 U.S. 279, 288–89 (1992)); McLaughlin v. N.C. Bd. of Elections, 65 F.3d 1215, 1221 n.6 (4th Cir. 1995) (“We believe that a regulation which imposes only moderate burdens could well fail the Anderson balancing test when the interests that it serves are minor, notwithstanding that the regulation is rational.”).
The Anderson-Burdick analysis set forth in the Court’s previous Memorandum Opinion, League of Women Voters of Va., No. 6:20-cv-00024 (Dkt. 69), 2020 WL 2158249, at *7–9, looks much the same on review of the current factual record. The witness signature requirement still creates a burden on a substantial and discrete class of Virginia’s electorate while the pandemic rages on,10 and this burden is not justified by the value of that requirement as an anti-fraud measure in face of the risk posed by COVID-19.
Since this Court issued its previous Memorandum Opinion, Plaintiffs have filed declarations from a number of voters who detail the health risks they are undertaking by attempting to meet the witness signature requirement. Each of the individual Plaintiffs, who all live alone, have attested that they do not feel safe interacting with a witness in order to fulfill the requirement.
10 What is more, the record indicates that these conditions are expected to continue for at least the rest of the year. Dkt. 103 (Joint Proposed Findings of Fact and Conclusions of Law) at ¶ 13 (citing e.g., League of Women Voters of Va. v. Va. State Bd. of Elections, Dkt. 6-20-cv-00024, 2020 WL 2158249, at *6 (W.D. Va. May 5, 2020)); Dkt. 88-1 at ¶¶ 14–19).
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And so, despite their desire to vote in upcoming elections, they feel they must refrain from voting. See Dkt. 84 at ¶¶ 10–19; Dkt. 88-3 (Decl. of Carol D. Peterson) at ¶¶ 5–6; Dkt. 88-7 (Decl. of Seijra Toogood) at ¶¶ 7–8; Dkt. 88-8 (Decl. of Katherine Crowley) at ¶ 6; Dkt. 88-9 (Decl. of Gayle Hardy) at ¶ 7; Dkt. 88-10 (Decl. of Tracy Safran) at ¶¶ 5–6. Plaintiff League of Women Voters of Virginia (“the League”) has “nearly 2,000 members across Virginia, some of whom live alone and are vulnerable to becoming severely ill from COVID-19 because they are elderly and/or have underlying health conditions.” Dkt. 84 at ¶ 21. The League states that some amount of these members will be unable to comply with the witness requirement on absentee voting “without placing their own health at risk.” Id. at ¶ 21.
Plaintiffs have also submitted two new expert declarations:11 a second declaration from epidemiologist Dr. Arthur Reingold, Dkt. 88-1—whose two declarations remain the only expert medical testimony in the record—and a declaration by Dr. John Holbein, a professor at the University of Virginia who studies voter participation, Dkt. 88-2. The testimony in Dr. Reingold’s second declaration builds on his first declaration, addressing relevant developments in COVID-19 research; this includes testimony that “SARS-CoV-2 is also aerosolized, such that tiny droplets containing the virus remain in the air and can be inhaled by others who come into contact with that air and SARS-CoV-2 can also be transmitted in that fashion,” Dkt. 88-1 at ¶ 10. Dr. Holbein’s testimony provides an expert opinion on academic, governmental, legal, and media sources to estimate the number of voters who might be estimated to submit a ballot without a witness signature and the effect of the witness signature on Virginia voter participation during the pandemic. Dkt. 88-2 at ¶¶ 1–2. In his testimony, Dr. Holbein ultimately concludes that “Virginia’s
11 Despite contesting the impact of aspects of their testimony, the parties do not contest their expert qualifications.
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witness requirement will decrease voter turnout, especially so among older, disabled, disadvantaged, and minority citizens. During a pandemic, this requirement effectively neuters the gains that vote-by-mail systems afford and disenfranchises voters.” Id. at ¶ 2.
The Court reiterates that “[i]n ordinary times, Virginia’s witness signature requirement may not be a significant burden on the right to vote.” League of Women Voters of Va., No. 6:20cv-00024 (Dkt. 69), 2020 WL 2158249, at *8. However, the witness requirement remains “both too restrictive and not restrictive enough to effectively prevent voter fraud.” Id. (quoting N.C. State Conference of NAACP v. McCrory, 831 F.3d 204, 235 (4th Cir. 2016); see Common Cause RI v. Gorbea, No. 1:20-cv-00318, 2020 WL 4365608, at *4 (D.R.I. July 30, 2020) (approving consent decree that enjoined Rhode Island’s witness signature requirement and stating that “the Court would have found that the mail-ballot witness or notary requirement, as applied during the COVID-19 pandemic, is violative of the First and Fourteenth Amendments to the United States Constitution because it places an unconstitutional burden on the right to vote”); Thomas v. Andino, No. 3:20-cv-01730, --- F. 3d ----, 2020 WL 2617329, at *21 (D.S.C. May 25, 2020) (enjoining witness signature requirement that did not include any witness verification measures because the burdens it imposed during the pandemic “far outweigh the imprecise, and (as admitted by SCEC Defendants) ineffective, state interests of combating voter fraud and protecting voting integrity”).
The RPV argues that people, even those who are at a greater risk of developing severe or life-threatening complications from COVID-19, have learned over the past several months how to manage their lives safely. But for those who are at a risk of developing severe or life-threatening COVID-19, every potential exposure is a risk—even when taking appropriate precautions, such as wearing a face mask, frequently washing one’s hands, and complying with social distancing guidelines. Such risks may be necessary to obtain food and other necessities, but the burden one
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might be forced to accept to feed oneself differs in kind from the burden that the First and Fourteenth Amendments tolerate on the right to vote.
Moreover, even with the available arsenal of conceivable precautions one could take to reduce risk of contracting the virus, many would be dissuaded from exercising their vote both because of the risk of illness and the efforts involved in mitigating that risk—especially those who are elderly, immunocompromised, or otherwise at grave risk from the virus. See Dkt. 88-2 (Decl. of Dr. John B. Holbein) at 20. That substantial burden on the right to vote has not been justified by countervailing, demonstrated interests in the witness requirement.
Indeed, the evidence in the record reflects that that the virus can be transmitted with more “ease” than was believed when this Court entered the first consent decree in this case. In addition to droplet transmission when an infected individual sneezes, coughs, and the like, Dkt. 103 (Joint Proposed Findings of Fact and Conclusions of Law) at ¶ 5 (citing CDC, How It Spreads, https://www.cdc.gov/coronavirus/2019-ncov/prevent-getting-sick/how-covid-spreads.html (last updated June 16, 2020)), and the parties agree that the evidence in the record demonstrates that the virus can be “aerosolized,” meaning that contagious particles of the virus can remain airborne for periods of time waiting to be inhaled by an unwitting host. Dkt. 103 (Joint Proposed Findings of Fact and Conclusions of Law) at ¶ 6 (citing Dkt. 88-1 at ¶ 10); Dkt. 106 (State Defendants Proposed Findings of Fact and Conclusions of Law).
The First Circuit, in denying an application to stay the District of Rhode Island’s approval of a consent decree enjoining a similar witness signature requirement than the one at issue here, put the issue well:
Could a determined and resourceful voter intent on voting manage to work around these impediments? Certainly. But it is also certain that the burdens are much more unusual and substantial than those that voters are generally expected to bear. Taking
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an unusual and in fact unnecessary chance with your life is a heavy burden to bear simply to vote. See Common Cause RI. v. Gorbea, No. 20-1753 , 2020 WL 4579367, at *2 (1st Cir. Aug. 7, 2020), aff’d No. 20A28, 2020 WL 4680151 (U.S. Aug. 13, 2020). As discussed at length in this Court’s previous Memorandum Opinion, the witness signature requirement is not restrictive enough in that the record does not demonstrate that it is especially effective in preventing voter fraud on its own. League of Women Voters of Va., No. 6:20-cv-00024 (Dkt. 69), 2020 WL 2158249, at *9. The only new evidence that RPV has brought to contest this finding is the declaration of a former North Carolina election official who did not testify as to any particular experience with enforcing Virginia’s election scheme. Moreover, the witness signature requirement in North Carolina is meaningfully distinct from Virginia’s in two ways. The first is that, for all elections before or after the year 2020, North Carolina law requires that an absentee voter must complete their ballot in the presence of two witnesses. The second, is that those witnesses are required “to sign the application and certificate as witnesses and to indicate those persons’ addresses. Failure to list a ZIP code does not invalidate the application and certificate.” N.C. Gen. Stat. § 163-231(a)(5). The ballot must then either be notarized or “the two persons in whose presence the voter marked that voter’s ballots to certify that the voter is the registered voter submitting the marked ballots.” N.C. Gen. Stat. § 163-231(a)(6). In response to the pandemic, for any election held in the year 2020, North Carolina has reduced the two-witness requirement down to one witness and, further, requires the witness to include on the ballot their printed name and address. 2020 N.C. Sess. Laws 2020-17 (H.B. 1169) § 1.(a). In comparison, Virginia merely requires a single witness to mark the absentee ballot envelope with an illegible signature. No address required. Compare Va. Code § 24.2-707, with 1 Va. Admin. Code 20-7020(C)(10).
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Ms. Strach’s testimony states that witness signature requirements “add a level of formality to the process of absentee voting that I think is important to the integrity of the election.” Dkt. 991 (Decl. of Kimberly W. Strach) at ¶ 20. Further, she states that even those requirements that do not require a legible signature or any witness verification measures [like Virginia’s] can be useful because state boards of elections have “little time to investigate any election irregularities and the more tools at their disposal to do so, the better.” Id. at ¶ 21. The risk to some voters’ health is not outweighed by an additional “level of formality,” particularly when considering the constellation of other safeguards in place to prevent absentee voter fraud. See supra Subsection I.A.2.
Because of the compromises the parties reached during settlement, experience of the counsel in this case, and the clear strength of the Plaintiffs’ case against the State Defendants, the Court concludes that the proposed partial settlement agreement is fair, adequate, and reasonable. See United States v. North Carolina, 180 F.3d at 581.
B. Proposed Consent Decree’s Relationship to the Public Interest The RPV argues that the public interest is served “by allowing for state control of its
election mechanics by democratically accountable officials.” That may well be preferable, but when the Court is confronted with a proposed settlement that would remedy a probable, impending violation of federal law—a settlement reached and advanced by the Attorney General for the Commonwealth, an elected statewide official and the chief law enforcement officer of Virginia12— a federal court cannot abdicate its separate institutional role and simply set such an agreement aside in the hope that an electoral solution to the same problem will arrive in time.
12 See Va. House of Delegates v. Bethune-Hill, 139 S. Ct. 1945, 1951 (2019) (“Authority and responsibility for representing the State’s interests in civil litigation, Virginia law prescribes, rest exclusively with the State’s Attorney General”) (citing Va. Code § 2.2-507(A)).
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Just as the previous settlement did, the entry of this consent decree would permit the State Defendants to avoid the likely unconstitutional application of a state law—at least with regard to the November 3, 2020 elections. It is neither unlawful, nor against the public interest. See Common Cause RI v. Gorbea, No. 1:20-cv-00318, 2020 WL 4365608, at *1, 5 (D.R.I. July 30, 2020); Common Cause Ind. v. Marion Cty. Election Bd., No. 1:17-cv-01388, 2018 WL 3770134, at *2 (S.D. Ind. Aug. 9, 2018) (holding that intervening party the State of Indiana’s objection to a consent decree governing early in-person voting that “was necessary to remedy a probable violation of federal law” was not compelling because it only argued that “it is not in the public interest for a federal court to enter, enforce, and monitor a consent decree that dictates the operation of state-run elections”).
For these reasons, the Court concludes that the proposed consent decree is not illegal nor against the public interest. See United States v. North Carolina, 180 F.3d at 581.
C. Product of Collusion This Court begins with the presumption that settlement negotiations were conducted in
good faith and that the agreement that resulted was not the product of fraud or collusion. See McCurley v. Flower Foods, Inc., No. 5:16-cv-00194, 2018 WL 6650138, at *2 (D.S.C. Sept. 10, 2018); Funkhouser v. City of Portsmouth, No. 2:13-cv-520, 2015 WL 12765639, at *3 (E.D. Va. May 14, 2015). Moreover, once any parties begin working toward a settlement, especially one that requires approval by a court, the relationship necessarily begins to align in a way that differs from an actively contested, adversarial proceeding. That alignment only increases once the parties have actually reached a settlement and present it to a court for approval. But that is not the same as fraud or collusion. The Court recognizes that the parties have, again, swiftly come to an agreement addressing an upcoming election in the days following the Plaintiffs’ second
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motion for a preliminary injunction. But the RPV has not brought forth any evidence that would permit the Court to overcome its presumption of good faith and fair dealing in the settlement negotiations between the Plaintiffs’ and State Defendants—instead, it relies on speculation and circumstantial evidence.
For example, the RPV points to how the State Defendants have “so far failed to defend the absentee ballot witness statute, and in fact they are selectively enforcing some witness signature requirements and not others.” Dkt. 99 at 41. The RPV also points to how the Plaintiffs and State Defendants have “almost immediately decided to enter into the Consent Decree” on a second occasion. Id. But such speculation is no substitute for evidence of collusion. See Common Cause RI, No. 1:20-cv-00318, 2020 WL 4365608, at *4 (D.R.I. July 30, 2020) (concluding that a consent decree enjoining a witness signature requirement during the COVID-19 pandemic was not collusive where “no evidence of collusion among the parties has been presented to this Court; in fact, the parties have represented that they engaged in good-faith negotiations in the crafting of the Consent Decree’s terms” despite the Republican Party intervenors’ arguments that the suit had lacked the requisite adversarial vigor).
It is no surprise to this Court that the parties were able to reach a settlement quickly for a second time, given this Court’s articulation that the Plaintiffs had pleaded a probable violation of federal law as to the witness signature requirement’s application to the June 2020 primaries. COVID-19 has resurged in the Commonwealth—if it ever truly receded—and this Court’s finding of such a probable violation presumably sent a signal to the State Defendants as to their chances of defending the requirement in court. The Court will not demand that litigants have blinders on to their chances of success. Rather, one would expect them to always be attuned to the likelihood
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of winning on the merits and, in turn, the possibility or even necessity of settlement. That a defendant in such a position would settle quickly is hardly evidence of collusion.
Further, contrary to the RPV’s contention, the Plaintiffs and State Defendants’ failure to include other witness signature requirements that appear in Virginia’s election scheme within the scope of the consent decree also provides no evidence of collusion. If anything, the more limited nature of the agreement demonstrates cuts the other way entirely.
The RPV also argues that the parties do not have standing to seek their consent decree because there is no case or controversy between them, as required by the Constitution. This is because, as the RPV contends, Plaintiffs are “aligned” with the State Defendants. Dkt. 99 at 42. The RPV made the same argument—based on the same caselaw—in its opposition to the prior consent decree, Dkt. 58 at 13–14, and the Court rejected the argument. The RPV cites no intervening developments that would change the Court’s reasoning as it was set forth in the previous opinion. League of Women Voters of Va., No. 6:20-cv-00024 (Dkt. 69), 2020 WL 2158249, at *11. As then, the Court finds the cases that the RPV cited to be inapposite to the facts presented in this case. For example, in Moore v. Charlotte-Mecklenburg Board of Education, 402 U.S. 47, 47–48 (1971), the Supreme Court stated that “at the hearing both parties argued to the three-judge court that the anti-busing law was constitutional and urged that order of the district court adopting the [plan] should be set aside.” Because the Court was “confronted with the anomaly that both litigants desire precisely the same result, namely a holding that the anti-busing statute is constitutional,” it held that there was no case or controversy as required under Article III of the U.S. Constitution. Id. In contrast, here, the parties have reached a settlement and have jointly requested a consent decree. They are, of course, aligned in their desire for the Court to approve the consent decree, but that is true of any motion for a consent decree. The RPV has not provided any
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persuasive reason why the Supreme Court’s order in Moore should undermine the framework for assessing a consent decree as set forth in United States v. North Carolina, 180 F.3d 574 (4th Cir. 1999).
The fact remains that the State Defendants have not betrayed any indication that they will not enforce the witness signature requirement under color of state law if this consent decree is not entered or Plaintiffs’ motion for a preliminary injunction is not granted. And, if the requirement were enforced, Plaintiffs argue that they would be harmed. That is the case or controversy before this Court, and the Court cannot identify anything in the record that demonstrates that this case or controversy has ceased to exist. Indeed, the litigation as to the remainder of Plaintiffs’ sought relief is ongoing, and the Plaintiffs and State Defendants still have legally cognizable interests at stake. See Genesis Healthcare Corp. v. Symczyk, 569 U.S. 66, 71 (2013) (“Article III, § 2, of the Constitution limits the jurisdiction of federal courts to ‘Cases’ and ‘Controversies,’ which restricts the authority of federal courts to resolving the legal rights of litigants in actual controversies . . . . In order to invoke federal-court jurisdiction, a plaintiff must demonstrate that he possesses a legally cognizable interest, or personal stake, in the outcome of the action.” (internal quotations and citations omitted)).
The RPV has not put forth sufficient evidence to overcome the presumption of good faith and fair dealing. But, even without such a presumption, the Court would be unable to find any basis for the conclusion that the parties colluded in bringing this suit and reaching their settlement.
D. Burdens on Third-Party Obligations, Rights, or Duties As with the prior consent decree, the proposed consent decree does not bind the RPV to
take or not to take any action. Local No. 93, Intern. Ass’n of Firefighters, AFL-CIO C.L.C. v. City of Cleveland, 478 U.S. 501, 529–30 (1986). It does not purport to resolve or otherwise extinguish any claims that the RPV, or any other party, might have. Id.
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Rather, just as before, this consent decree is limited to one of several verification requirements in place for absentee ballots in Virginia. It involves none of the RPV’s statutory functions or rights in providing for the nomination of its candidates. Va. Code § 24.2-508. And, as the Supreme Court stated just last week, a political party “lack[s] a cognizable interest in the State’s ability to ‘enforce its duly enacted’ laws.” Repub. Nat’l Comm., No. 20A28, 2020 WL 4680151, at *1 (U.S. Aug. 13, 2020) (quoting Abbott v. Perez, 138 S. Ct. 2305, 2324 n.17 (2018)).
The RPV, again, raises its concern that the consent agreement would endanger the security of the election. In support of its argument, it points to a declaration of a former North Carolina election official and argues that her testimony demonstrates that Virginia voters will be “disenfranchised” if the Court approves the consent decree. Dkt. 99 at 35 (quoting Dkt. 99-1, Decl. of Kimberly Strach, at ¶ 13). This quote is taken out of context—the declaration says no such thing. In full, it states,
Voters in North Carolina’s Congressional District 9 were disenfranchised by [a fraudulent] absentee ballot scheme [in 2018] because some voters did not cast their own votes, and residents of the district went without congressional representation for a period of time while the [fraud] investigation concluded and before the new election was completed. Dkt. 99-1 at ¶ 13. As they contend, “Ms. Strach’s affidavit clearly warns this Court that eliminating the witness signature requirement will hamper the ability of investigators to detect fraud, disenfranchise voters as a whole, and have a disparate impact on vulnerable populations.” Dkt. 99 at 36. The Court remains unconvinced. Ms. Strach’s testimony states that the witness signature requirements “add a level of formality to the process of absentee voting that I think is important to the integrity of the election.” Id. at ¶ 20. Further, she states that even those requirements that do
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not require a legible signature or any witness verification measures can be useful because state boards of elections have “little time to investigate any election irregularities and the more tools at their disposal to do so, the better.” Id. at ¶ 21. The Court’s reasoning as to whether the consent decree addresses a probable violation of federal law applies with equal force here: the strength of the witness signature requirement’s marginal utility as an anti-fraud measure is likely outweighed by the burden it places on the right to vote for a substantial and discrete class of Virginia’s electorate. That a former North Carolina election official who lacks familiarity with enforcing a Virginia election regulation has testified that its utility is limited to its role as another tool in the arsenal and, specifically, one that adds a layer of “formality” to the absentee voting process does little to tip the scales.
The value of her testimony in this case drops even further when weighed against the opinion of the Virginia State Board of Elections—the body that actually has experience in enforcing Virginia’s absentee ballot scheme and investigating Virginia election fraud. That body is before the Court now, requesting the approval of this proposed consent decree—indeed, as a party to the suit, it crafted this settlement with the Plaintiffs. The Court finds more persuasive that body’s assessment of the value of this requirement as compared to testimony from a former election official of a different state, who has experience enforcing a different absentee ballot scheme with a different witness signature requirement.13 See Common Cause RI, 2020 WL 4579367, at *3 (1st Cir. Aug. 7, 2020). Indeed, the previous consent decree has set a new status
13 As already discussed, North Carolina’s standard witness signature requirement (for elections held outside the year 2020) requires two witness signatures, the printed address of those witnesses, and either notarization of the absentee ballot or a certification from the witnesses that the voter is the registered voter submitting the marked ballots. N.C. Gen. Stat. § 163-231(a)(6).
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quo in Virginia—one in which the witness signature requirement is not enforced during the pandemic. Cf. Republican Nat. Comm., 20A28, 2020 WL 4680151, at *1 (U.S. Aug. 13, 2020).
Every indication before the Court is that the June primary was conducted without the witness signature requirement and without any corresponding increase in voter confusion or election fraud—the RPV has not provided any evidence to the contrary and no state official or entity has come forth to intervene or file an amicus brief expressing otherwise. To change the status quo set by the June election by setting aside the consent decree would likely do more to confuse and deter voters. Id. (“Second, Rhode Island just conducted an election without any attestation requirement, in which 150,000 mail-in ballots were requested. So, the status quo (indeed the only experience) for most recent voters is that no witnesses are required. Instructions omitting the two-witness or notary requirement have been on the state's website since at least mid-July.”); Republican Nat. Comm., 20A28, 2020 WL 4680151, at *1 (U.S. Aug. 13, 2020) (“The status quo is one in which the challenged requirement has not been in effect, given the rules used in Rhode Island’s last election, and many Rhode Island voters may well hold that belief.”); see also Democratic Nat’l Comm. v. Bostelmann, 140 S. Ct. 1205, 1207 (2020) (“This Court has repeatedly emphasized that lower federal courts should ordinarily not alter the election rules on the eve of an election.”) (citing Purcell v. Gonzalez, 549 U.S. 1 (2006)).
As before, the Court has given the RPV, as an intervening party, its chance to be heard both on brief and at this Court’s Fairness Hearing. It has ably advanced its objections to the proposed consent decree. But it is not entitled to block the other parties to this suit from settling any claims in this action. See Local No. 93, 478 U.S. at 529; Sierra Club v. North Dakota, 868 F.3d 1062, 1067 (9th Cir. 2017). In any event, this Court has concluded that the proposed consent
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Case 6:20-cv-00024-NKM-RSB Document 109 Filed 08/21/20 Page 28 of 28 Pageid#: 2341 decree is fair, adequate and reasonable, not illegal or the product of collusion, and no argument or evidence presented by the RPV warrants a contrary conclusion. CONCLUSION For the foregoing reasons, the Court will approve the proposed settlement agreement, Dkt. 95-1. It finds that the agreement is fair, adequate, and reasonable and, further, it is not the product of collusion, illegal, or against the public interest. Lastly, the agreement does not purport to extinguish the claims of any third party, nor does it impose any obligations or duties on any third party. The Clerk of the Court is directed to send a copy of this Memorandum Opinion to all counsel of record. Entered this __2_1_st__ day of August, 2020.
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UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA
Lynchburg Division

8/21/2020

LEAGUE OF WOMEN VOTERS OF

VIRGINIA;

KATHERINE

D.

CROWLEY; SEIJRA TOOGOOD;

GAYLE HARDY; CAROL D.

PETERSEN; and TRACY SAFRAN,

Plaintiffs,

v.

VIRGINIA STATE BOARD OF ELECTIONS; ROBERT H. BRINK, JOHN O’BANNON, and JAMILAH D. LECRUISE, in their official capacities as Chairman, Vice-Chair, and Secretary of the Virginia State Board of Elections, respectively; and CHRISTOPHER E. PIPER, in his official capacity as Commissioner of the Virginia Department of Elections,

Defendants,

REPUBLICAN PARTY OF VIRGINIA,

Intervenor-Defendant.

Case No. 6:20-cv-00024-NKM-RSB

PARTIAL CONSENT JUDGMENT AND DECREE 1. Whereas Virginia law requires that every voter filling out an absentee ballot must open, mark, and refold their ballot in the presence of a witness, and then have the witness sign their ballot envelope (the “witness requirement”), as stated in Va. Code § 24.2-706 and § 24.2-707 and as interpreted by 1 Va. Admin. Code 20-70-20(B). 2. Whereas on March 12, 2020, Virginia Governor Ralph S. Northam issued Executive Order 51 (EO 51) in which he declared a state of emergency in Virginia in response to

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the spread in Virginia of a respiratory illness (COVID-19) caused by a novel coronavirus—an order that remains in effect.
3. Whereas the virus that causes COVID-19 may be transmitted from person-toperson through close contact via inhalation of respiratory droplets when an infected person breathes, talks, coughs or sneezes; through inhalation of such droplets that become aerosolized and remain suspended in the air; and through contact with surfaces or objects on which the virus is present, followed by touching one’s own mouth, nose, or even eyes. The CDC has also confirmed that people infected with the virus may transmit it to others without showing symptoms themselves.
4. Whereas COVID-19 can cause severe consequences, including long-term illness and death, and the virus threatens to infect and harm any individual no matter their age or medical background. COVID-19 is particularly dangerous and sometimes fatal for older individuals, individuals with obesity, individuals with compromised immune systems, individuals with preexisting heart and respiratory conditions including hypertension and asthma, and individuals with various other conditions.
5. Whereas the Virginia Department of Health (“VDH”) continues to urge Virginians to do their “part to help stop the spread of COVID-19 by staying at home as much as possible,” and federal guidelines state: “[e]veryone [s]hould . . . avoid close contact” by “stay[ing] home as much as possible” and “put[ting] 6 feet of distance between yourself and people who don’t live in your household.” Centers for Disease Control and Prevention, Coronavirus Disease 2019 (COVID-19): How to Protect Yourself & Others, https://www.cdc.gov/coronavirus/2019ncov/prevent-getting-sick/prevention.html (last visited Aug. 4, 2020).
6. Whereas the witness requirement necessitates that any individual who lives alone
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and wishes to vote an absentee ballot will need to either invite another person into their home or travel outside their home to meet a witness. Then, the individual must have the witness watch while they open their ballot envelope, fill out their ballot, close and sign the envelope, and finally exchange the envelope back and forth with the witness to obtain their signature. This situation requires that individuals who live alone and are isolating or practicing social distancing per public health recommendations come into close contact with another individual, and increase the likelihood that those involved will contract COVID-19 and transmit it to others. For this reason, the witness requirement creates a health risk to the general public.
7. Whereas in-person voting also creates a risk to individual voters and to public health, as voting in person involves waiting in line with other voters, interacting with poll workers, and touching voting equipment—some of this in an indoor environment—which also creates significant risk of virus transmission.
8. Whereas as of July 29, 2020, there have been well over 4 million cases and over 150,000 deaths from COVID-19 in the United States, and over 87,000 cases and over 2,100 deaths from COVID-19 in Virginia alone. After declining in late May and into June, the number of daily new COVID-19 cases has once again been steadily rising in Virginia, as in most of the country.
9. Whereas an effective, widely available vaccine for COVID-19 will almost certainly not be available by November 3, 2020, and the significant weight of scientific evidence confirms that COVID-19 will likely continue to transmit widely in the community absent a vaccine or herd immunity, and that herd immunity will not occur anytime in the near future.
10. Whereas on April 17, 2020, Plaintiffs League of Women Voters of Virginia, Katherine D. Crowley, Erikka Goff, and Seijra Toogood filed a complaint against the above-named Defendants challenging enforcement during the ongoing public health crisis caused by the spread
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of a novel coronavirus, SARS-CoV-2, of Virginia’s witness requirement. Among other relief requested, the Complaint sought to enjoin enforcement of the witness requirement for as long as public health officials continue to recommend social distancing practices due to the risk of community transmission of COVID-19. ECF No. 1 at 33.
11. Whereas on April 21, 2020, the same Plaintiffs filed a motion for preliminary injunction requesting this Court prohibit the above-named Defendants from enforcing the witness requirement for all Virginia voters for the primary election to be held on June 23, 2020 (“June Primary”), and for all subsequent elections in Virginia until such time as in-person interactions required by compliance with the witness requirement no longer pose a risk to public health and personal safety. Plaintiffs’ motion further requested that Defendants be ordered to issue guidance instructing election officials to count otherwise validly cast absentee ballots missing a witness signature and to conduct a public information campaign in conjunction with city and county election officials about the elimination of the requirement.
12. Whereas those same Plaintiffs and Defendants reached a proposed partial consent decree and judgment (the “first consent decree”) that they submitted to the Court for approval on April 27, 2020, governing the operation of the witness requirement for the June Primary. See ECF Nos. 35, 35-1, 36. After full briefing on this motion and a hearing, this Court approved the first consent decree which, among other things: (a) prohibited enforcement of the witness requirement for the June Primary for Virginia voters who did not believe they could safely comply; (b) required Defendants to issue guidance instructing all relevant city and county election officials to count all absentee ballots in the June primary that are otherwise validly cast but missing a witness signature; (c) required Defendants to prepare updated voting instructions to accompany the absentee ballots informing voters that any absentee ballot cast in the June Primary without a witness signature will
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not be rejected on that basis and specifically inform voters in bold print that they may disregard the witness signature line on the absentee ballot envelope if they believe they may not safely have a witness present while completing their ballot; and (d) requiring Plaintiffs to withdraw their preliminary injunction motion and disclaiming Plaintiffs’ right to seek attorneys’ fees up to that point in the litigation. ECF No. 68.
13. Whereas in granting the first consent decree, the Court found that: “Plaintiffs’ case alleges a probable violation of federal law—that is, applying the witness requirement during this pandemic would impose a serious burden on the right to vote, particularly among the elderly, immunocompromised, and other at-risk populations. Weighed against those risks, the present record reflects the likelihood that the burden would not be justified by the witness requirement’s purpose as an anti-fraud measure. Thus, the Court finds that the partial settlement in the proposed consent decree is fair, adequate, and reasonable given the strength of the Plaintiffs’ case, and that entering it is not against the public interest, illegal, or the product of collusion.” ECF No. 69 at 1.
14. Whereas the June Primary proceeded smoothly under the terms of the first consent decree without an increase in fraud, to the knowledge of the Defendants.
15. Whereas on June 19, 2020, the Court granted Plaintiffs’ motion to dismiss Erikka Goff as a Plaintiff, ECF No. 80, and on July 17, 2020, the Court granted Plaintiffs’ motion to file a second amended complaint, which added new Plaintiffs Gayle Hardy, Carol D. Petersen, and Tracy Safran, see ECF Nos. 83, 84.
16. Whereas discovery produced in this case by Defendants shows that during the May 2020 local elections in Virginia, for which the witness requirement was still in full effect and which occurred after the COVID-19 pandemic began, both the rate and number of absentee ballots rejected for lack of a witness signature climbed substantially.
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17. Whereas on July 24, 2020, Plaintiffs League of Women Voters of Virginia, Katherine D. Crowley, Seijra Toogood, Gayle Hardy, Carol D. Petersen, and Tracy Safran filed a Motion for Preliminary Injunction requesting this Court prohibit Defendants from enforcing the witness requirement for all Virginia voters for the November election and for all subsequent elections in Virginia until such time as in-person interactions required by compliance with the witness requirement no longer pose a risk to public health and personal safety. Plaintiffs’ motion further requested that Defendants be ordered to issue guidance instructing election officials to count otherwise validly cast absentee ballots missing a witness signature and conduct a public information campaign in conjunction with city and county election officials about the elimination of the requirement.
18. Whereas pursuant to Va. Code § 24.2-612, absentee voting must be available 45 days prior to the November 3, 2020 General Election (“the November Election”), or Saturday, September 19, 2020. For localities whose general registrar’s offices are closed on Saturday, absentee ballots must be available on Friday, September 18, 2020.
19. Whereas in light of the data that supports the Plaintiffs’ concerns for their safety if they are required to interact with others in order to cast their ballot in the November Election, Plaintiffs and Defendants (collectively, the “Consent Parties”) agree that an expeditious resolution of this matter for the November general election, in the manner encompassed by the terms of this Consent Decree, is in the best interests of the health, safety, and constitutional rights of the citizens of the Commonwealth of Virginia, and therefore in the public interest.
20. Whereas the Consent Parties further agree that no eligible voter should have to choose between casting a ballot that will count and placing their own health at risk.
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21. Whereas Defendants agree not to enforce the witness requirement for the November Election for absentee voters who believe they may not safely have a witness present while completing their ballot.
22. Whereas Plaintiffs agree to withdraw their July 24, 2020 Motion for Preliminary Injunction upon entry of this Partial Consent Judgment and Decree.
23. Whereas the Consent Parties agree that entry of this Consent Decree does not affect the viability of Plaintiffs’ claims under the First and Fourteenth Amendments to the Constitution, or Section 2 of the Voting Rights Act, with respect to enforcement of the witness requirement in any subsequent elections after the November Election.
24. Whereas Plaintiffs agree to a waiver of any entitlement to damages, fees, including attorneys’ fees, expenses, and costs, that may have accrued as of the date of the entry of this order, with respect to the claims raised by Plaintiffs in this action, provided, however, that Plaintiffs reserve their rights to seek costs and attorneys’ fees on their claims in the event of material noncompliance by Defendants with the terms and conditions of this Consent Decree.
25. Whereas the Court finds that it has subject matter jurisdiction over the Consent Parties and that the Partial Consent Judgment and Decree is fair, adequate, and reasonable, and not illegal, a product of collusion, or against the public interest because such agreement preserves the constitutional right to vote of Plaintiffs and other Virginia voters while promoting public health during a pandemic and does so without harming the integrity of Virginia’s elections. The agreement also gives appropriate weight to Defendants’ expertise and public interest responsibility in the area of election administration.
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26. Whereas Plaintiffs made a sufficiently strong showing on the merits of the claim, as shown in their complaint and motion for preliminary injunction, to further support the fairness, adequacy, and reasonableness of this Partial Consent Judgment and Decree. IT IS HEREBY ORDERED, ADJUDGED, AND DECREED FOR THE REASONS STATED ABOVE IN PARAGRAPHS 1-26 THAT:
1. For the November Election, Defendants shall not enforce the requirement, as stated in Va. Code § 24.2-706 and § 24.2-707, that absentee voters have another individual present to witness the voter open, mark, and refold their ballot, and then have that that individual sign the absentee ballot envelope next to the voter’s statement and signature, for voters who believe that they may not safely comply.
2. Defendants shall issue guidance instructing all relevant city and county election officials to count all absentee ballots in the November Election that are otherwise validly cast but are missing a witness signature.
3. Defendants shall issue updated instructions to include with all absentee ballots as provided in Va. Code. § 24.2-706—or issue guidance instructing all relevant city and county election officials to modify or amend the printed instructions accompanying each absentee ballot— to inform voters that any absentee ballot cast in the November Election without a witness signature will not be rejected on that basis and specifically inform voters in bold print that they may disregard the witness signature line on the absentee ballot envelope if they believe they may not safely have a witness present while completing their ballot.
4. Defendant Commissioner of Elections shall take additional reasonable steps to inform the public that the witness requirement will not be enforced for the November Election for those absentee voters who believe they may not safely have a witness present while completing
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their ballot, and issue guidance instructing all relevant city and county election officials to do the same.
5. Plaintiffs will withdraw their motion for a preliminary injunction. 6. In accordance with the terms of this Consent Decree, the Consent Parties shall each bear their own fees, expenses, and costs incurred as of the date of this Order, with respect to all claims raised by Plaintiffs against the Defendants.

Dated: ____A_u_g_u_s_t_2_1____, 2020

_______________________ United States District Judge

/s/ Davin M. Rosborough_______________ Davin M. Rosborough (VSB # 85935) Dale E. Ho* Sophia Lin Lakin* Theresa J. Lee* Adriel I. Cepeda-Derieux* American Civil Liberties Union Foundation 125 Broad Street, 18th Floor New York, NY 10004 Phone: (212) 549-2500 drosborough@aclu.org dho@aclu.org slakin@aclu.org tlee@aclu.org acepedaderieux@aclu.org
Vishal Agraharkar (VSB #93265) Eden Heilman (VSB #93554) AMERICAN CIVIL LIBERTIES UNION FOUNDATION OF VIRGINIA 701 E. Franklin Street, Suite 1412 Richmond, Virginia 23219 Phone: (804) 644-8080 Fax: (804) 649-2733 vagraharkar@acluva.org eheilman@acluva.org

MARK R. HERRING Attorney General of Virginia By: /s/ Carol L. Lewis CAROL L. LEWIS (VSB #92362) MICHELLE S. KALLEN (VSB #93286)
HEATHER HAYS LOCKERMAN (VSB #65535)
Office of the Attorney General 202 North Ninth Street Richmond, Virginia 23219 804-692-0558 (telephone) 804-692-1647 (facsimile) clewis@oag.state.va.us
Attorneys for Robert H. Brink, John O’Bannon, Jamilah D. LeCruise and Christopher E. Piper in their official capacities, and the Virginia State Board of Elections

9

CCaassee66::2200--ccvv--0000002244--NNKKMM--RRSSBB DDooccuummeenntt19150--11 FFilieledd0088/0/251/2/200 PPaaggee1100ooff1100 PPaaggeeidid##:: 2036593
Attorneys for Plaintiffs *Admitted Pro Hac Vice
10

Case 6:20-cv-00024-NKM-RSB Document 110-2 Filed 08/21/20 Page 1 of 3 Pageid#: 2354

UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA
Lynchburg Division

8/21/2020

LEAGUE OF WOMEN VOTERS OF

VIRGINIA;

KATHERINE

D.

CROWLEY; SEIJRA TOOGOOD;

GAYLE HARDY; CAROL D.

PETERSEN; and TRACY SAFRAN,

Plaintiffs,

v.

VIRGINIA STATE BOARD OF ELECTIONS; ROBERT H. BRINK, JOHN O’BANNON, and JAMILAH D. LECRUISE, in their official capacities as Chairman, Vice-Chair, and Secretary of the Virginia State Board of Elections, respectively; and CHRISTOPHER E. PIPER, in his official capacity as Commissioner of the Virginia Department of Elections,

Defendants,

REPUBLICAN PARTY OF VIRGINIA,

Intervenor-Defendant.

Case No. 6:20-cv-00024-NKM-RSB

ADDENDUM TO PARTIAL CONSENT JUDGMENT AND DECREE 1. Whereas, in filing their Joint Motion for Entry of a Partial Consent Judgment and Decree (ECF No. 95), Proposed Partial Consent Judgment and Decree (ECF No. 95-1), and Memorandum in Support (ECF No. 96), Plaintiffs and Defendants (collectively, the “Consent Parties”), in referring to the “November 3, 2020 General Election” and the “November Election,” intended to include all elections and measures for which Virginia voters are able to cast ballots

Case 6:20-cv-00024-NKM-RSB Document 110-2 Filed 08/21/20 Page 2 of 3 Pageid#: 2355

with an election date of November 3, 2020, including any special elections, ballot referenda, or other measures appearing on Virginia voters’ ballots that are set to that Election Date.
2. Whereas the same justifications for entry of the Proposed Partial Judgment and Consent Decree for the General Election occurring on November 3, 2020, apply with equal force to any other special elections, ballot referenda, and any other measures appearing on a ballot for this election date.
3. Whereas excluding special elections, ballot referenda, and other measures appearing on Virginia voters’ ballots in connection with the November 3, 2020 election but including General Election choices would lead to confusion.
4. Whereas the Consent Parties wish to incorporate this Addendum by reference into the Proposed Partial Consent Judgment and Decree (ECF No. 95-1). IT IS HEREBY ORDERED, ADJUDGED, AND DECREED FOR THE REASONS STATED ABOVE IN PARAGRAPHS 1 to 4 THAT:
1. The terms “November Election” and “November 3, 2020 General Election,” where they appear in the Proposed Partial Consent Judgment and Decree (ECF No. 95-1) shall be deemed to include any elections, including special elections, ballot referenda, or other measures with an election date of November 3, 2020, on which a Virginia voter may cast a ballot.
2. This Addendum is hereby incorporated by reference into the Partial Consent Decree and Judgment entered by the Court as of this same date. All of other terms and conditions of the Partial Consent Decree and Judgment shall remained unchanged.

Dated: ____A_u_g_u_s_t _2_1____, 2020

_______________________ United States District Judge
2

Case 6:20-cv-00024-NKM-RSB Document 110-2 Filed 08/21/20 Page 3 of 3 Pageid#: 2356

/s/ Davin M. Rosborough_______________ Davin M. Rosborough (VSB # 85935) Dale E. Ho* Sophia Lin Lakin* Theresa J. Lee* Adriel I. Cepeda-Derieux* American Civil Liberties Union Foundation 125 Broad Street, 18th Floor New York, NY 10004 Phone: (212) 549-2500 drosborough@aclu.org dho@aclu.org slakin@aclu.org tlee@aclu.org acepedaderieux@aclu.org
Vishal Agraharkar (VSB #93265) Eden Heilman (VSB #93554) AMERICAN CIVIL LIBERTIES UNION FOUNDATION OF VIRGINIA 701 E. Franklin Street, Suite 1412 Richmond, Virginia 23219 Phone: (804) 644-8080 Fax: (804) 649-2733 vagraharkar@acluva.org eheilman@acluva.org
Attorneys for Plaintiffs
*Admitted Pro Hac Vice

MARK R. HERRING Attorney General of Virginia By: /s/ Michelle S. Kallen CAROL L. LEWIS (VSB #92362) MICHELLE S. KALLEN (VSB #93286)
HEATHER HAYS LOCKERMAN (VSB #65535)
Office of the Attorney General 202 North Ninth Street Richmond, Virginia 23219 804-692-0558 (telephone) 804-692-1647 (facsimile) clewis@oag.state.va.us
Attorneys for Robert H. Brink, John O’Bannon, Jamilah D. LeCruise and Christopher E. Piper in their official capacities, and the Virginia State Board of Elections

3


[CONTENT]  ||| Stanford |||  ||| 19 | The League of Women Voters | Virginia | three | the Virginia State Board of Elections | Virginia ||| the June 23, 2020 ||| August 5 | November 3 | General Election | August 21 |||  ||| April 17, 2020 | the League of Women Voters | Virginia | three | the Virginia State Board of Elections | Virginia | the U.S. District Court | the Western District | Virginia ||| the American Civil Liberties Union | ACLU | ACLU | Virginia | 42 | U.S.C. | § | 1983 | 1988 | 52 | 10302 | 28 | U.S.C. | § | 2201-02 | First | Fourteenth Amendment | Section 2 | the Voting Rights Act ||| COVID-19 ||| African American | COVID-19 ||| Norman K. Moon ||| April 21 | 1 | June 23 | 2 | June 23 | 3 | Virginia ||| April 23 | three ||| The next day | the Republican Party of Virginia | RPV | three |||  ||| 2020 | 2090679 ||| RPV ||| 2020 WL | 2090678 ||| April 27 ||| May 5 | Moon ||| 2020 WL | 2158249 ||| Magistrate | Robert S. Ballou ||| June 19 | one ||| July 17 | second | three | COVID-19 ||| November 3 | COVID-19 | July 23 ||| August 5 | November 3 | General Election ||| second | August 21 ||| 2020 WL | 4927524 ||| May 19-21, 2021 |||  [SUMMARY] <b>NOTE:  This case is being tracked in close to real time by the Stanford/MIT Healthy Elections Project. So for more current information, see <a href="https://healthyelections-case-tracker.stanford.edu/"> their tracker</a>.</b> COVID 19 Summary: The League of Women Voters of Virginia and three individual voters filed a suit against the Virginia State Board of Elections to remove Virginia’s witness requirement. The parties reached a partial agreement, which the court approved in a consent decree, to remove the requirement for the June 23, 2020 elections. On August 5, the parties came to an agreement to stop enforcement of the witness requirement for the November 3 General Election and collectively sought approval of a partial consent judgment, which the court approved on August 21. The case is ongoing. <hr>

On April 17, 2020, the League of Women Voters of Virginia and three individual voters filed a complaint against the Virginia State Board of Elections to remove Virginia’s witness requirement in the U.S. District Court for the Western District of Virginia. Represented by the American Civil Liberties Union (ACLU) and ACLU of Virginia, the plaintiffs brought this lawsuit under 42 U.S.C. §§ 1983 and 1988, 52 U.S.C. § 10302 and 28 U.S.C. §§ 2201-02, seeking declaratory and injunctive relief for violation of their First and Fourteenth Amendment rights and Section 2 of the Voting Rights Act.  Specifically, they alleged that requiring absentee ballots to be marked in the presence of a witness was contrary to social distancing guidelines and that forcing voters to comply amid the COVID-19 pandemic unduly burdened the fundamental right to vote by forcing voters to choose between their safety and right to vote. Additionally, they alleged that the requirement disproportionately discriminated against elderly voters, African American voters, and voters with disabilities who face a heightened risk of illness from COVID-19. The case was assigned to Judge Norman K. Moon. 

On April 21, the plaintiffs filed a motion for preliminary injunction that would: (1) prohibit the defendants from enforcing the witness requirement for the June 23 primary and all subsequent elections; (2) order the defendants to issue guidance instructing city and county election officials to count otherwise validly cast absentee ballots that are missing a witness signature for the June 23 primary election; (3) order the defendants to conduct a public campaign informing Virginia voters about the elimination of the requirement. 

On April 23, a group of three individuals filed a motion to intervene as defendants. The next day, the Republican Party of Virginia (RPV) and another group of three voters also filed a motion to intervene. The following day, all of the individuals' requests to intervene were denied because they would unnecessarily expand the scope of the litigation and detract from timely resolution. 2020 WL 2090679. However, the RPV’s motion to intervene was granted. 2020 WL 2090678.

On April 27, the parties filed a joint motion for a partial consent decree, agreeing to withdraw the preliminary injunction motion in exchange for the defendant’s agreement to forego enforcement of the witness requirement for the June Primary. 

On May 5, Judge Moon approved the partial consent decree. 2020 WL 2158249. The case was referred to Magistrate Judge Robert S. Ballou for all nondispositive pretrial motions and issues.

On June 19, the plaintiffs filed an amended complaint with one of the named plaintiffs removed. On July 17, the plaintiffs filed a second amended complaint with three additional plaintiffs who were at higher risk from COVID-19 due to underlying medical conditions. 

The plaintiffs moved for a preliminary injunction for the upcoming November 3 election and other subsequent elections affected by COVID-19 on July 23.

On August 5, the parties came to an agreement to stop enforcement of the witness requirement for the November 3 General Election and collectively sought approval of a partial consent judgment. The district court approved the second consent judgment and decree on August 21, finding that the same reasons for the previous consent decree carried even more force, as the pandemic has resurged. 2020 WL 4927524.

A bench trial is scheduled for May 19-21, 2021. The case is ongoing.