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VIA EMAILOctober 18, 2013
Mr. Lawrence HaakeChesterfield County General Registrar PO Box 1690Chesterfield, VA 23832RE: Notice of Violation Under Section 8 of the National Voter Registration Act.I represent a client interested in election integrity, and herby notify you that the Chesterfield CountyElectoral Board is in likely violation of Section 8 of the National Voter Registration Act.You submitted a declaration, which I attach, in
Virginia Democratic Party v. SBE
, et al., (Case No.1:13-cv-01219, E.D.Va.) which admits that your office is failing to comply with state law. Thedeclaration demonstrates that your office is failing to take reasonable steps to ensure the voter rollsare free from ineligible voters. Federal law requires election officials to conduct a reasonable effortto maintain voter registration lists free from dead voters, ineligible voters and voters who havemoved away; 42 U.S.C. §§ 1973gg-(6)(a)(4) and 15483(a)(2)(A)(ii)(I).In particular, the declaration indicates that your office has suspended the removal of voters who nolonger reside in Chesterfield County and have been found to have registered in other states throughthe interstate cross check program.If the circumstances described in the attached affidavit are not cured within the 90 day notice period,my clients may initiate action in federal court seeking an order to command you to comply withfederal and state law. My clients have brought multiple successful lawsuits under this provision of federal law for failure to maintain the rolls.This letter serves as the statutory notice to your county, required by 42 U.S.C. §1973gg-9(b)(2) prior to the commencement of any lawsuit under 42 U.S.C. §1973gg-9(b)(1)
to enforce provisions of Section 8 of the National Voter Registration Act 42 U.S.C. §1973gg-6.It is our hope that your county will work quickly towards full compliance with 42 U.S.C. §1973gg-6,rendering legal proceedings unnecessary.