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Day3SCvUSA8-2912TrialAM_

Day3SCvUSA8-2912TrialAM_

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1

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA


STATE OF SOUTH CAROLINA,
CA No. 12-203
Plaintiffs, Washington, DC
August 29, 2012
vs. 9:00 a.m.

UNITED STATES OF AMERICA, ET AL., DAY 3 - AM SESSION

Defendants. Page 1 thru 160
___________________________________



TRANSCRIPT OF TRIAL
BEFORE
DISTRICT JUDGE COLLEEN KOLLAR-KOTELLY
CIRCUIT JUDGE BRETT M. KAVANAUGH
DISTRICT JUDGE JOHN D. BATES


APPEARANCES:

For the Plaintiffs: H. CHRISTOPHER BARTOLOMUCCI, ESQ
BRIAN J. FIELD, ESQUIRE
MICHAEL McGINLEY, ESQUIRE
STEPHEN POTENZA, ESQUIRE
Bancroft, PLLC
1919 M Street, NW
Suite 470
Washington, DC 20036
(202) 416-0257

H. CHRISTOPHER COATES, ESQUIRE
934 Compass Point
Charleston, SC 29412
(843) 609 7080

ALSO PRESENT: ALAN M. WILSON
Attorney General South Carolina
BRYAN STIRLING
Deputy Attorney General
South Carolina
KARL S. BOWERS, ESQUIRE


2
For the Defendants: BRADLEY E. HEARD, ESQUIRE
RICHARD ALAN DELLHEIM, ESQUIRE
BRYAN L. SELLS, ESQUIRE
ANNA M. BALDWIN, ESQUIRE
CATHERINE MEZA, ESQUIRE
ERIN MARIE VELANDY, ESQUIRE
DANIEL J. FREEMAN, ESQUIRE
ANGELA MILLER, ESQUIRE
U.S. Department of Justice
Civil Rights Division
Voting Section
950 Pennsylvania Avenue, NW
Washington, DC 20530
(202) 353-8743


For Defendant Intervenors: GARRARD R. BEENEY, ESQUIRE
MICHAEL COOPER, ESQUIRE
THEODORE A.B. McCOMBS, ESQUIRE
TALY DVORKIS, ESQUIRE
SEAN A. CAMONI, ESQUIRE
PETER STECIUK, ESQUIRE
Sullivan & Cromwell, LLP
125 Broad Street
New York, NY 10004
(212) 558-1863

NANCY ABUDU, ESQUIRE
American Civil Liberties Union
Foundation, Inc.
230 Peachtree Street, NW
Suite 1440
Atlanta, GA 30303
(404) 523 2721

SUSAN K. DUNN, ESQUIRE
American Civil Liberties Union
Foundation of South Carolina
40 Calhoun Street
Suite 210
Charleston, SC 29401
(843) 720-1428



3
ARTHUR B. SPITZER, ESQUIRE
American Civil Liberties Union
of the Nation's Capital
4301 Connecticut Avenue, NW
Suite 434
Washington, DC 20008
(202) 457-0800 x113

J. GERALD HEBERT, ESQUIRE
The Campaign Legal Center
215 E Street, NE
Washington, DC 20002
(202) 736-2200

MIMI MARZIANI, ESQUIRE
Brennan Center for Justice
161 Avenue of the Americas
12th Floor
New York, NY 10013
(646) 292-8327

MARK A. POSNER, ESQUIRE
Lawyers' Committee for Civil
Rights
1401 New York Avenue, NW
Suite 400
Washington, DC 20005
(202) 662-8389


Court Reporter: Lisa M. Foradori, RPR
Official Court Reporter
U.S. Courthouse, Room 6706
333 Constitution Avenue, NW
Washington, DC 20001
(202) 354-3269






Proceedings recorded by mechanical stenography; transcript
produced by computer-aided transcription
4

INDEX TO WITNESSES
For the Plaintiffs: Page
MARCI ANDINO

Examination by Mr. Beeney 6
Examination by Mr. Bowers 63
Examination by Ms. Meza 74

MARILYN BOWERS
Examination by Mr. Bowers 76
Examination by Mr. Meza 99
Examination by Ms. Beeney 107

M.V. HOOD, III
Examination by Mr. Bartolomucci 108









5
1 P R O C E E D I N G S
2 HON. COLLEEN KOLLAR-KOTELLY: This is the case of
3 State of South Carolina versus the United States et al. and
4 Intervenor-Defendants et al., 12-CV-203. I will not have
5 counsel identify themselves again.
6 In looking at the timing of it, assuming that we
7 progress as we have, I've talked to the other two judges, and
8 this assumes that we progress in the manner that we've done.
9 We can, I think, have a little -- we have a little extra time
10 on Friday. This assumes this progresses. And we're willing
11 to give 30 extra minutes to South Carolina and 30 extra
12 minutes to the defendants. I don't know whether DOJ didn't
13 ask for extra time. So if not, it can go to the intervenors.
14 This assumes that this moves along. But so far we have been
15 pretty good.
16 All right. Then I believe we had stopped with Ms.
17 Andino. Ms. Andino, if you'd come on up, and counsel. So Ms.
18 Andino and Mr. Beeney and the two crosses.
19 Thereupon,
20 MARCI ANDINO, resumed the stand,
21 the witness herein, having been previously duly sworn, was
22 examined and testified as follows:
23 HON. COLLEEN KOLLAR-KOTELLY: Good morning,
24 Ms. Andino.
25 THE WITNESS: Good morning.
6
1 HON. COLLEEN KOLLAR-KOTELLY: Go ahead.
2 MR. BEENEY: Thank you, Your Honor.
3 EXAMINATION CONTINUED
4 BY MR. BEENEY:
5 Q. Good morning, Ms. Andino.
6 A. Good morning.
7 Q. Ms. Andino, I want to start by just discussing for a
8 moment or two the State Election Commission photo registration
9 card that is not yet available but will be required under the
10 act. Okay? In order to get one, a voter will have to go to
11 the county election office in the county seat, is that right?
12 A. That's correct, if the office is in the county seat.
13 Q. Are there places where they are not in the county
14 seats?
15 A. In Charleston County.
16 Q. In any of the other 46 counties, or in the other 45,
17 are they all in the county seat?
18 A. I believe they are. And in Beaufort County they have a
19 satellite office outside of the county seat as well.
20 Q. I want to show you Defendant-Intervenors' Exhibit 418,
21 and as we're pulling it up, it's a map of the state that we
22 introduced earlier in the trial with Senator Clemmons, I
23 believe, that shows by county the residents who are African
24 American of the voting age population. And superimposed on
25 those we have put in what really show up as kind of squiggly
7
1 lines, the public transportation that is available. And we've
2 compared that with your exhibit of county by county registered
3 voters who don't have a DMV-issued photo ID that you sent to
4 the Senate. Do you remember that?
5 A. Yes, I do.
6 Q. That list I think is Defendant-Intervenors' 48. And
7 what we've done is in these five counties where there is no
8 public transportation except around the city in Orangeburg,
9 where there is the highest percentage in the state of African
10 American voting age population, we've counted up the nonwhite
11 persons that you've identified for the Senate who don't have a
12 DMV-issued ID and it comes out 7,018 people.
13 And my question is, are there any plans that
14 you're aware of on the part of the election commission or the
15 state, to try to help in some way any of these 7,000 people,
16 who we know don't have driver's licenses and we know don't
17 have access to public transportation, to get to the county
18 seat so they can get a DMV, quote, free, quote, issued ID?
19 A. We will, once, if there's -- if preclearance is
20 granted, of course, we will take the bus and we'll concentrate
21 on areas where there's a higher percentage of people that
22 potentially may not have photo IDs. And then counties will
23 also provide events and do things to help reach those people.
24 Q. You only have one bus, is that right?
25 A. That's correct.
8
1 Q. And so whatever you can do with one bus is limited by
2 the fact that you have a single bus?
3 A. It is.
4 Q. And you're not aware of any other plan to help these
5 people get to the county seats so they can get their ID?
6 A. No.
7 Q. Now, requiring these people to get to the county seat,
8 I think we discussed at some point that you were in agreement
9 that if people had to go to the county seat to vote it would
10 drastically reduce turnout. Do you remember that?
11 A. Not really.
12 Q. Do you remember we had a discussion, and I can show you
13 in your deposition, about if you had to vote at the county
14 seat there was, I think you said that it was likely or it was
15 probable that that would have a drastic effect on turnout?
16 A. I believe it would have an effect on the turnout, yes.
17 Q. And it would drastically reduce turnout, isn't that
18 fair?
19 A. Possibly.
20 Q. Doesn't it follow that if these 178,000 people have to
21 get to a county seat to get their ID in order to vote, that it
22 will also reduce turnout among those people because they'd
23 have to get to the county seat as a precondition to voting?
24 A. Unless they have a reasonable -- or that could be a
25 reasonable impediment, or they may have a religious objection,
9
1 or they may have another form of ID. We were only looking at
2 driver's license and other IDs issued by DMV.
3 Q. Right. So they may have a passport or they may have a
4 military ID. But apart from that, if they want to vote in
5 person, regular ballot, like their neighbors, they would have
6 to get to the county seat?
7 A. Yes.
8 Q. Just another quick question about the photo IDs and
9 providing photo IDs. Your plan is to provide each of the
10 counties except the three largest counties one webcam camera
11 like the kind you can buy at Best Buy, is that right?
12 A. I believe so. I'm not sure of the exact model that
13 we've tested.
14 Q. I think the last time we spoke you told us that you
15 actually didn't have a model identified, but it was the kind
16 of webcam you buy at Best Buy?
17 A. We may have a specific model. If we do, I mean, I
18 don't know, I couldn't tell you off the top of my head, but I
19 do know that our IT staff has tested a specific camera.
20 Q. Do you remember telling us in July it was the kind of
21 camera that you could walk into Best Buy and get?
22 A. Yes.
23 Q. The intent is to print a black and white photo with a
24 laser printer and put it on the card?
25 A. Yes.
10
1 Q. Now, in terms of the counties and the way they run
2 their elections and the way they staff their elections, it's
3 your view that on election day the counties could probably use
4 twice as many people as they have, is that right?
5 A. On election day, yes.
6 Q. And on election day there are 2,100 precincts where
7 people can vote, and there are 20,000 poll managers?
8 A. Roughly, yes.
9 Q. And they get paid $60 to train for a few hours and then
10 they get paid $60 to spend 12 hours at the poll on election
11 day?
12 A. That is correct except for the clerk of each polling
13 place, they get an additional $60.
14 Q. And you referred to the poll managers when we talked
15 about them as basically volunteers. Do you remember that?
16 A. Yes.
17 Q. And the staff -- excuse me. Withdrawn. The State
18 Election Commission can offer suggestions to poll managers,
19 but you have no basis to require them to follow your guidance?
20 A. No.
21 Q. And if the county says to the poll managers, we
22 disagree with the way the State Election Commission is
23 interpreting this and you're going to do it the way we tell
24 you, there's nothing you can do to prevent that?
25 A. No.
11
1 Q. And there are problems, as I suppose there always are,
2 with election administration at the county level, right?
3 A. Sometimes, yes.
4 Q. Did you happen to read or hear Representative Clemmons'
5 testimony about how the poll managers were giving voters, I
6 think he referred to it as unrequested assistance in the
7 actual voting booth?
8 A. I did not.
9 Q. Now, at the end of the 2008 election, you do a little
10 bit of a recap in a document that you refer to as lessons
11 learned, is that right?
12 A. That's correct.
13 Q. And you try to figure out how you're going to make
14 elections better based on what you saw in the previous
15 election, is that right?
16 A. It is.
17 Q. And I want to just ask you a couple things that are in
18 that lessons learned procedure. And one of them is that
19 several of the counties don't use the State Election
20 Commission training online for the poll managers, right?
21 A. That's correct.
22 Q. And the online training is the only way that the State
23 Election Commission directly trains poll managers, right? And
24 by directly, I mean the other way you do it is you provide
25 information to the county and then the county trains its poll
12
1 managers. Those are the two ways, right?
2 A. That's right.
3 Q. So many of the counties don't have their poll managers
4 take the online training that you offer?
5 A. That's right.
6 Q. And another thing that you concluded from the 2008
7 election is that county commissioners are not educated about
8 how to rule on provisional ballots. Do you remember that?
9 A. No, I don't.
10 Q. Let's turn to Defendant-Intervenor Exhibit 6. And
11 Ms. Andino, this is a page -- do you recognize this as a page
12 from the 2008 election learned document?
13 A. I do.
14 Q. And this is the entry that I'm referring to right here
15 (indicating). "Commissioners are not educated about how to
16 rule on provisional ballots." Do you recall that being a
17 concern with the 2008 election?
18 A. Yes.
19 Q. And in fact, although state law requires it, according
20 to the 2011 State Election Commission accountability report,
21 you had 82 county election officials who were not trained, in
22 violation of state law, is that correct?
23 A. I believe so. I don't know the number off the top of
24 my head.
25 Q. But you can agree that it's of that magnitude of people
13
1 who aren't trained?
2 A. It's a lower number today than it was in 2008.
3 Q. This is the 2011 accountability report.
4 A. Okay.
5 Q. So in 2011, I don't want to take the time to show you
6 the document, but it does, I will represent to you, say that
7 there are 82 county election officials who are not trained, in
8 violation of state law. And you can't disagree with that, can
9 you?
10 A. No.
11 Q. Now, I want to turn to the guidelines that you prepared
12 that were produced to the defendants and the
13 defendant-intervenors on August 14th. And I believe those are
14 Defendant-Intervenor Exhibit 5 -- 505. Sorry. Thank you.
15 HON. COLLEEN KOLLAR-KOTELLY: I'm sorry. What was
16 it?
17 MR. BEENEY: 505, Your Honor.
18 BY MR. BEENEY:
19 Q. Ms. Andino, yesterday you mentioned to us that you
20 certainly want R54 implemented in ways in which you're going
21 to err in favor of the voters, is that right?
22 A. That's correct.
23 Q. Is there anything in Exhibit 505 that says that to the
24 counties or to the poll managers?
25 A. I'm not sure without seeing the entire document.
14
1 Q. Let me see if I can give you a copy of it. All right,
2 we'll pull that out. Let me move on while we're pulling that
3 out, Ms. Andino. And poll managers --
4 MR. BEENEY: Your Honor, may we approach?
5 HON. COLLEEN KOLLAR-KOTELLY: Yes.
6 BY MR. BEENEY:
7 Q. Ms. Andino, is there anything in Exhibit 505 that tells
8 county officials or poll managers to err on the side of
9 voters?
10 A. I haven't read every word, but I don't see where it
11 says those specific words.
12 Q. Do you think there's any words in there that are
13 intended to convey that impression and that you believe county
14 officials or poll managers will understand that your guidance
15 is to err on the side of the voter?
16 A. I don't know if it's specifically in here, but that's
17 certainly what we always communicate to poll managers and to
18 county election officials.
19 Q. So there's nothing different with respect to R54 in
20 terms of the guidance about erring on the side of the voter,
21 that's just SOP, standard operating procedure?
22 A. Yes.
23 Q. Now, these 20,000 poll managers, you provided them with
24 some guidance in this section here of Exhibit 505 that gives
25 them a definition of reasonable impediment, right?
15
1 A. Yes.
2 Q. And it gives them some nonexclusive examples of
3 reasonable impediment, right?
4 A. That's correct.
5 Q. And is the purpose of this so they can recognize what
6 is a reasonable impediment and what is not?
7 A. The purpose is to give them some guidance.
8 Q. As to how do define reasonable impediment?
9 A. Yes.
10 Q. Now, you have not given any guidance in here or the
11 training materials as to what current and valid means, is that
12 right?
13 A. I don't believe so.
14 Q. And you haven't given any guidance on what constitutes
15 a military ID, is that right?
16 A. No.
17 Q. Now, Exhibit 505 -- and if we can turn to page 2, also
18 contemplates in section 3(b)(2), which is right here if I've
19 got it right, that you're telling the poll managers, quote,
20 "If completing for reasonable impediment, voter must list
21 impediment unless disclosure is protected by state or federal
22 law." You haven't trained anybody on what kind of information
23 is protected by state or federal law, have you?
24 A. We haven't done any training yet.
25 Q. Do you have any training materials that are drafted
16
1 that would allow a poll manager to be trained as to what is
2 protected by state or federal law?
3 A. No.
4 Q. Now, I'd like to go through with you if we can,
5 Ms. Andino, exactly how you see on voting day R54 and
6 particularly the reasonable impediment provision, how it will
7 be implemented and how it will work. Okay? So I'm a voter
8 and I walk into the polling place and there is a check-in
9 table, is that right?
10 A. Yes.
11 Q. And the poll manager sitting at the check-in table will
12 ask me for one of the five required R54 IDs, correct?
13 A. That's correct.
14 Q. And if I say I don't have one, the poll manager will
15 say is there a reason beyond your control that created any
16 obstacle to you obtaining one of the necessary IDs, or do you
17 have a religious objection to being photographed?
18 A. Yes.
19 Q. And you believe that most South Carolina voters will
20 have no problem understanding that?
21 A. I believe so.
22 Q. Now, would you agree with me that asking that question
23 invites a dialogue between the voter and the poll manager, and
24 that the voter is likely to respond to that question with
25 questions of his or her own?
17
1 A. That's possible.
2 Q. And you haven't suggested to the poll manager what they
3 do to answer any questions that a voter may have?
4 A. Not specifically.
5 Q. Now, if a voter is not aware of the law, they are not
6 going to know that they have to go to the county seat and that
7 transportation could be a reasonable impediment. Maybe I can
8 ask the question in a better way. If a voter doesn't know of
9 the law, they are not going to know what a reasonable
10 impediment could possibly be, is that right?
11 A. It's possible.
12 Q. Well, how is it possible in the reverse? If I don't
13 know what the law is, how could I possibly know what my
14 individual circumstances are that would constitute a
15 reasonable impediment to not getting a photo ID if I don't
16 know how I can get one?
17 A. I think it would invite a conversation between the poll
18 manager.
19 Q. Now, if a voter says yes, and then let's put aside the
20 conversations that we've been having about who determines
21 whether a reasonable impediment is reasonable. But if a voter
22 says yes, the voter is handed a reasonable impediment envelope
23 with a printed affidavit on it with certain blanks, is that
24 right?
25 A. That's correct.
18
1 Q. And the voter has to fill in the blanks, putting down
2 the reasons for the reasonable impediment, or not, depending
3 upon whoever may have any knowledge of state or federal law
4 protecting privacy, is that correct?
5 A. Yes. Or I believe the poll manager could also assist
6 and fill that out for them.
7 Q. So if the voter is illiterate, the poll manager will
8 help them read the affidavit and help them write out what they
9 want to write out in terms of the reasonable impediment?
10 A. That's right.
11 Q. And the voter has got no way of verifying, since they
12 are illiterate, that the poll manager is writing down what
13 they are telling them to write down?
14 A. Well, there are other people there and they could
15 certainly ask for assistance.
16 Q. So there are other people there, including poll
17 watchers representing the candidates, watching this whole
18 process go on? Excuse me. Poll watchers representing the
19 candidates watching this whole process go on?
20 A. Yes.
21 Q. Now, if a notary is present -- and we'll get to what
22 may or may not happen if one is not -- the voter presents the
23 affidavit to the notary, and under state law the notary has to
24 ask the voter for some proof that the voter is the person who
25 the voter claims to be unless the notary knows them?
19
1 A. Yes, or unless there's a credible witness or someone
2 else there that knows the voter.
3 Q. So if I'm the voter, I've been told I can't vote
4 because I don't have the required ID, that I have to sign an
5 affidavit, and then I take it to somebody else, who tells me I
6 need to show them an ID to prove who I am. Do I have that
7 right?
8 A. No. You haven't been told that you can't vote.
9 Q. Well, I've been told I can't go to the poll and pull
10 the lever. I've been told I have to vote a different way.
11 A. Okay.
12 Q. Is that right?
13 A. Well, we don't have levers, but yes.
14 Q. Sorry. I haven't voted in South Carolina, which
15 everybody will be happy to hear. So I'm told I can't vote by
16 going to the booth, that I have to do it by reasonable
17 impediment because I don't have an ID, and then someone that I
18 take the ballot envelope to tells me I have to prove who I am.
19 A. Yes.
20 Q. Is that likely in your view to be a source of
21 confusion?
22 A. It could potentially, but a person may have their voter
23 registration card without a photograph, or some other document
24 that would be acceptable to the notary.
25 Q. And are you aware, Ms. Andino, that the notary handbook
20
1 for the state of South Carolina suggests that the first thing
2 that the notary asks is for a photo ID?
3 A. I'm not familiar with the handbook. I've seen it but
4 I'm not versed in it.
5 Q. And what Defendant's Exhibit 505 suggests to the notary
6 in section 3(b)(4) on page 2 of Exhibit 505 is that the notary
7 should accept the non-photo voter registration card, is that
8 right?
9 A. Yes.
10 Q. So the State Election Commission is saying to the
11 notary, we won't accept that card to prove who the person is
12 to vote, but you ought to accept that card to prove who the
13 person is to execute an affidavit?
14 A. Well, if this is precleared, then we will have a law
15 that will require a photo ID, so we won't be able to accept a
16 voter registration card without the ID -- or without the
17 photo.
18 Q. Right. So your message to the notary is, accept what
19 we can't accept under the law for voting?
20 A. Yes.
21 Q. I think when we spoke on Friday, I think you told us
22 that it would be not unreasonable for a notary to say, you
23 won't take it to prove who this person is, I'm not going to
24 take it to prove who a person is. Do you remember that?
25 A. I remember our discussion on Friday about that, yes.
21
1 Q. Do you remember you agreeing that that would not be an
2 unreasonable position for a notary to take?
3 A. It may not.
4 Q. Now, we also I think agreed on Friday that it was
5 reasonable for a notary to say R54 is state policy that you
6 can't prove who you are with a non-photo registration card.
7 You remember we agreed that that also would be a not
8 unreasonable position for a notary to take?
9 A. Yes.
10 Q. Now, if a voter doesn't have proof satisfactory to --
11 under the assumption that there are 2,100 notaries in the
12 2,100 precincts -- if the voter doesn't have proof that is
13 acceptable to that notary, the voter won't get a ballot, is
14 that right?
15 A. Yes.
16 Q. So 2,100 notaries, applying state guidelines, over
17 which you have no control, get to decide whether they are
18 willing to or not willing to notarize an affidavit. And that
19 decision is a decision that determines whether the person gets
20 a ballot to exercise their franchise.
21 A. Yes.
22 Q. Now, I want to just briefly delve back into a couple of
23 issues about if the notary -- if there is no notary there.
24 And again, just so we're clear, Ms. Andino, you've known
25 for -- I hope I have the period right, but it's been several
22
1 weeks at least, if not a few months, that the state has taken
2 the position that the reasonable impediment affidavit has to
3 be notarized, right?
4 A. I've known for a few weeks.
5 Q. And as of Friday you could not identify a single notary
6 in the state of South Carolina who was willing to sit at the
7 November election and not charge a fee for notarizing an
8 affidavit, is that right?
9 A. We identified a number of poll managers who are
10 notaries, and it is something that the county election
11 commissions and not the State Election Commission would be
12 identifying. So I would not personally identify those.
13 Q. No, I understand that. But you personally and the
14 State Election Commission is not aware of a single notary who
15 has been willing to do what you think needs to be done?
16 A. I have not talked to any notaries about doing this.
17 Q. And none of the counties have said we've got somebody?
18 A. They haven't indicated either way.
19 Q. Well, didn't one county official tell you that this
20 whole process was ridiculous?
21 A. One county election official did post that on
22 ElectionNet.
23 Q. So that might be an indication of how they are feeling
24 about trying to get the notaries.
25 A. Well, quite often they use ElectionNet to vent, but
23
1 when it comes right down to it, they are going to do what we
2 ask them to do.
3 Q. But at the end of the day, you don't know of any single
4 person who's agreed to sit as a notary?
5 A. Not personally.
6 Q. Now, you talked yesterday about asking the counties to
7 count reasonable impediment votes through the affidavit even
8 if they are not notarized. Do you remember that?
9 A. Yes.
10 Q. Now, there is no conceivable way that the county could
11 do that if someone at the certification hearing on Friday
12 challenges the ballot, can they?
13 A. It depends. The burden of proof is going to be on the
14 challenger to present grounds that that affidavit is false.
15 Q. Well, suppose someone representing one of the
16 candidates shows up at the ballot challenge procedure on the
17 Friday that the vote is being certified, and says, you can't
18 count that because it's not notarized, and under state law it
19 has to be an affidavit that is notarized. Now, if someone
20 challenges that, it's inconceivable that the county would
21 accept that vote, isn't it?
22 A. You know, not really. There's a procedure in election
23 law that allows polls to be opened if none of the poll
24 managers show up. Voters can take over the polling place and
25 run the polling place. And I think that that just goes to
24
1 show that voting must take place, that the polls must open at
2 7:00 o'clock and, you know, if there is a situation where,
3 through no fault of the voter, that there's not a notary
4 available, our poll managers are authorized to administer
5 oaths and, you know, I'm not going to sit here and say I would
6 disenfranchise any voter, because it's not their fault that we
7 didn't have a notary available. We'll make every attempt to
8 have a notary in every polling place, but if something
9 unforeseen happens and there's not one there, voting still has
10 to go on.
11 Q. Well, voting may have to go on, but there's nothing in
12 state law that says that everybody has to vote, is there?
13 A. No.
14 Q. So there's nothing in state law that says anybody who
15 wants to vote gets a chance to vote regardless of their
16 qualifications?
17 A. No, but if they are standing there and they want to
18 vote and they say they have a reasonable impediment, I'm not
19 going to turn them away because we don't have a notary.
20 Q. But we agree the law requires a reasonable impediment
21 vote to be notarized?
22 A. The law requires the affidavit to be completed.
23 Q. Which it requires a notary?
24 A. That's what we've just learned.
25 Q. Now, do you know of any other situation in which, to
25
1 not disenfranchise people, you've been asking the county
2 officials to ignore legal requirements?
3 A. No.
4 HON. COLLEEN KOLLAR-KOTELLY: Can I just intercede
5 here for a second just on this. You've got -- let's assume
6 that the reasonable impediment affidavit, notarized or not,
7 arrives for the county to consider it. At what point between
8 election day and Saturday, when it's certified, would the
9 county commissioners meet to consider any challenges? Do you
10 know?
11 THE WITNESS: Yes, they meet on Thursday following
12 a primary and on Friday following a general election.
13 HON. COLLEEN KOLLAR-KOTELLY: Okay. How would the
14 voter get any information that somebody is going to go and
15 challenge this? In other words, if somebody comes up and
16 says, well, you know, it's a lie, the reasonable impediment
17 the voter has listed is not true. How will the voter know to
18 come and challenge that?
19 THE WITNESS: The voter gets a notice of the
20 provisional ballot hearing, but I think that there would be
21 some indication at the polling place when the vote was cast,
22 because other than that, those names aren't made public
23 between election day and when the provisional ballot hearing
24 takes place. So it's not like you could vote and then later
25 on I could find out you cast a provisional ballot. Somebody
26
1 would almost need to be at the polling place at that time.
2 HON. COLLEEN KOLLAR-KOTELLY: So if they put lack
3 of transportation, it went forward and got to the county
4 commissioners, there would be nobody who would have notice out
5 in the public that that is what was put down and the person
6 may have had a car or something, so that they could come and
7 challenge it?
8 THE WITNESS: Right, because those envelopes are
9 dropped into the ballot box and they are not made public.
10 HON. COLLEEN KOLLAR-KOTELLY: How would, if there
11 is some challenge by somebody, the poll watcher that's there
12 who knows them and feels that there's some other reason, or
13 for some reason wants to put a challenge in, how would they
14 actually get notice between Tuesday, showing up for Thursday
15 or Friday, to be able to, the voter, get notice?
16 In other words, if somebody comes in to challenge
17 it, the voter you said would get some sort of notice that this
18 is happening so they could appear and respond to it. How
19 would they know, if the election is Tuesday, it goes to them
20 and then they have a hearing either Thursday or Friday?
21 THE WITNESS: The voter is given notice at the
22 polling place of the provisional ballot hearing.
23 HON. COLLEEN KOLLAR-KOTELLY: So they are given
24 notice that there will be generally a provisional ballot
25 hearing. So every voter would get this notice?
27
1 THE WITNESS: Yes, everybody who casts a
2 provisional ballot.
3 HON. COLLEEN KOLLAR-KOTELLY: So you cast a
4 provisional ballot and you get notice of this hearing. You
5 don't know whether your reasonable impediment affidavit is
6 challenged or not, but you're expected to check somehow or
7 find out? How would you know whether it's worth showing up?
8 THE WITNESS: There's not a way in place that they
9 would know.
10 HON. COLLEEN KOLLAR-KOTELLY: Okay. So you get the
11 provisional ballot, you're told that there is a hearing and
12 somebody could or could not come in and challenge your -- you
13 know. So if you want to make sure that it gets counted, maybe
14 you should show up. Is that the theory?
15 THE WITNESS: Yeah, that's the current process with
16 provisional ballots.
17 HON. COLLEEN KOLLAR-KOTELLY: Okay. Is that true
18 of any provisional ballot?
19 THE WITNESS: Yes.
20 HON. COLLEEN KOLLAR-KOTELLY: Under the current
21 law.
22 THE WITNESS: It is.
23 HON. COLLEEN KOLLAR-KOTELLY: So if you get a
24 provisional ballot, they give you a notice that they are going
25 to have a hearing, and so if you want to make sure your vote
28
1 counts, you'd show up at that as well, in essence?
2 THE WITNESS: Yes.
3 HON. COLLEEN KOLLAR-KOTELLY: Okay.
4 THE WITNESS: But the voter is not required to be
5 there.
6 HON. COLLEEN KOLLAR-KOTELLY: But if somebody
7 decides to knock it out, you're not there, right, so you have
8 no way of responding?
9 THE WITNESS: Right.
10 HON. COLLEEN KOLLAR-KOTELLY: If I could just ask
11 one other thing, slightly different. For some people who
12 simply come in and forget their ID. They've got a driver's
13 license at home, they forgot to bring it, they brought their
14 voter registration. Again, they get a provisional ballot, as
15 I understand it. Not the reasonable impediment, but
16 provisional ballot. And do they, when they -- if they have to
17 go back home and whatever, get it, can they go back to the
18 polling place, or do they have to go to the commissioner, you
19 know, wherever the county commissioners are?
20 THE WITNESS: Under current law, if they don't have
21 their ID with them, then they are not given a ballot at all
22 and they would have to go home and then return to the polling
23 place. Under the new law, then they could vote a provisional
24 ballot. They could -- and then show up any time at the voter
25 registration and election office between the election and the
29
1 provisional ballot hearing to show their ID.
2 HON. JOHN D. BATES: That would be at the county
3 seat.
4 THE WITNESS: Yes. Yes.
5 HON. COLLEEN KOLLAR-KOTELLY: And they would be
6 given notice that they have to come back with their driver's
7 license -- I'm assuming they've got one. And they'd either
8 have to -- so they'd have to go to the county seat. They
9 couldn't just show up at the provisional challenge thing and
10 present it there?
11 THE WITNESS: They could show up at the
12 provisional.
13 HON. COLLEEN KOLLAR-KOTELLY: Okay. Those are my
14 questions.
15 BY MR. BEENEY:
16 Q. Ms. Andino, just to follow up a little bit on some of
17 the Court's questions. If my reasonable impediment is I have
18 no transportation to the county seat, I have to get to the
19 county seat to defend that, right?
20 A. Not unless it's challenged.
21 Q. Well, if it's challenged, the only way I can defend it
22 is to get to the county seat, which might suggest to a county
23 commissioner that a lack of transportation reasonable
24 impediment is false, since you're standing in front of me
25 trying to defend your ballot.
30
1 A. Yes.
2 Q. Now, again, just to follow up on a couple of the
3 Court's questions. At the polls there are people representing
4 the candidates, right?
5 A. Yes, we have poll watchers.
6 Q. And so if I was a poll watcher, I get to watch what
7 goes on at the table, the check-in table where all this is
8 happening, right?
9 A. Yes.
10 Q. And if I wanted to, for whatever reason I may have, I
11 could write down the name of every African American who voted
12 by reasonable impediment and show up on Friday and challenge
13 every one of those if I wanted to, right?
14 A. Yes.
15 Q. And there's no way that our hypothetical African
16 American voter who's getting challenged would have any idea in
17 the world that that's what's happening, is that correct?
18 A. That's correct.
19 HON. COLLEEN KOLLAR-KOTELLY: So the poll watchers
20 have access to the names?
21 THE WITNESS: The poll watchers are there to watch
22 the process, and they can come over and look at the voter
23 registration list and the poll list.
24 HON. COLLEEN KOLLAR-KOTELLY: Okay.
25
31
1 BY MR. BEENEY:
2 Q. Ms. Andino, on the issue of saying to the counties,
3 please ignore the requirements of R54 that the reasonable
4 impediment affidavit be notarized, do you think that asking
5 counties to ignore the requirements of state law somehow has a
6 negative effect on people's confidence in the electoral
7 system?
8 A. I think people have confidence when voters are allowed
9 to vote and they are not disenfranchised.
10 Q. Even if the process to get there requires you to ignore
11 and violate state law?
12 A. R54 doesn't specifically say it has to be signed by a
13 notary.
14 Q. Well, R54, I mean, there are just really not a lot of
15 steps here. It's just two steps. R54 says it's got to be an
16 affidavit, and the state says it can't be an affidavit unless
17 it's notarized, right?
18 A. That's what I hear.
19 Q. I also on this topic want to follow up on one of the
20 Court's questions from yesterday. There was a question, do
21 you recall, about if the county election commission decides
22 that the affidavit is false but the voter is there with an ID
23 that's acceptable under R54, I think you said the vote would
24 be counted, right?
25 A. It should be.
32
1 Q. Well, I'm confused about that because the only way the
2 person who shows up on Friday has voted on Tuesday is by the
3 reasonable impediment affidavit, and now that's being thrown
4 out, so what is the vote that is going to be counted on Friday
5 if I can prove who I am?
6 A. Between Tuesday and Friday, the individual may have had
7 a chance to go and get one of the acceptable forms of ID. And
8 maybe the reasonable impediment applied on Tuesday, but
9 they've overcome that because they have received an ID. You
10 know, they are at the county office, they may have gotten one
11 before the challenged ballot hearing.
12 We're going to make every attempt to, if we can
13 identify the person and that's the person who voted, to count
14 their vote.
15 Q. I'm not disagreeing under this hypothetical that the
16 person doesn't have a proper ID. I think what I'm disagreeing
17 with you about is that on Tuesday, the only method by which I
18 voted was the reasonable impediment affidavit, and now that's
19 being thrown out because it was determined to be false. So
20 what vote do I have that I can prove who I am, because the
21 only way I voted on Tuesday is thrown out?
22 A. Perhaps it was proven to be false, but if the person
23 then has an ID and you know that's who voted, why wouldn't you
24 count their vote?
25 Q. Because the law tells me if I think the affidavit is
33
1 false, I have to throw it out. Is this another place where
2 you're asking the counties to ignore the requirements of R54?
3 A. I don't really believe I'm asking them to require -- or
4 asking the county to ignore the requirements. I'm trying to
5 meet every aspect of the law. We're lawful people, we follow
6 the law, but there are some areas that are gray, and we're
7 going to try to err on the side of the voter and count their
8 vote if they are entitled to vote.
9 Q. What is your view about if the county commission
10 decides that a reasonable impediment vote by affidavit, that
11 the affidavit is false, do they then have to throw out the
12 vote, or can they still accept it?
13 A. If the county believes it's false?
14 Q. Yes, ma'am.
15 A. They should not count it.
16 Q. So if the affidavit is false, then the only vote that
17 I've cast on Tuesday is gone on Friday, is that correct?
18 A. The envelope is still sitting there.
19 Q. No, but they are not allowing that because they believe
20 the affidavit is false, so there's nothing left, there is no
21 other way that I voted that can be counted.
22 A. The affidavit may have been true on Tuesday.
23 Q. No, but -- I hate to interrupt you, but my hypothetical
24 is, based on what you just told me, that they have to throw it
25 out if it's false, my hypothetical is the affidavit is false
34
1 and the county is not going to count it. So even if I can
2 prove who I am on Friday, what vote is there to be counted?
3 A. The whole reason that the person voted using the
4 reasonable impediment on Tuesday is because they didn't have
5 an ID.
6 Q. So if I have an ID on Friday, even though the
7 reasonable impediment affidavit is false, you're asking the
8 county to open up that envelope and count what is in that
9 envelope?
10 A. If they have an ID on Friday that they did not have on
11 Tuesday, yes.
12 Q. Even if the determination is that the affidavit that
13 was submitted with the ballot under the reasonable impediment
14 exception is false?
15 A. Yes.
16 HON. JOHN D. BATES: How is the county
17 commissioner, Mary Smith, going to know that that's your view
18 unless they happen to in every instance call you up and get
19 that view and then choose to follow it? Might not different
20 county commissioners have different assessments of just what
21 they should do in that situation?
22 THE WITNESS: It is possible and, you know, we will
23 try to cover that through training, and as situations come up.
24 I mean, these are things that we didn't think about three
25 weeks ago that are being thrown out. And you know, we'll
35
1 certainly try to incorporate that into our training, just as,
2 after we go through the first election, or every election, we
3 always do a lessons learned.
4 So there will be situations that we need to
5 address, and we will do that in future training materials.
6 We're just taking -- we're doing the best we can right now to
7 anticipate the situations, and as things came up in
8 depositions, we adjusted, and we will adjust accordingly after
9 this.
10 HON. JOHN D. BATES: You're being hit, Ms.
11 Andino -- and I say this complimenting -- you're being hit
12 with a lot of different situations in the questioning today,
13 not only by counsel but by members of the Court. And some of
14 them are new to you, and you've admitted that. And in
15 deposition that happened as well.
16 Are you confident that all of these hypotheticals
17 and situations that are being thrown at you, you're going to
18 be able to incorporate into training to give to all these
19 20,000 poll watchers and all the county commissioners involved
20 in making decisions? Do you have confidence that you'll be
21 able to do that?
22 THE WITNESS: We are going to do the best that we
23 can.
24 HON. JOHN D. BATES: I understand you'll do the
25 best you can. But I'm asking you, are you confident that you
36
1 will be able to do comprehensive training that covers all of
2 these different kind of situations?
3 THE WITNESS: I'm confident that we're going to
4 cover as much as we can. And you know, I'm also sure that
5 there will be something that takes place on election day that
6 we haven't thought of.
7 HON. JOHN D. BATES: But that happens every
8 election day.
9 THE WITNESS: That happens every election day, it's
10 just a very volatile and always-changing environment that we
11 work in. So when there's a new law, you know, we do the best
12 we can to get out procedures, but sometimes they have to be
13 amended.
14 HON. JOHN D. BATES: One more hypothetical based on
15 something that you said a moment ago, I think. If someone
16 has, a voter has gone through this provisional process with
17 the affidavit, and then they come in to the county
18 commissioners on the Saturday challenge day, or Friday
19 challenge day, whatever it is, and they say -- because they
20 are worried that someone is going to challenge it and say that
21 the reasonable impediment they came up with was false. And
22 they say, ah, in the meantime, in the meantime, since Tuesday,
23 I've gone and gotten this photo voter ID. Is that going to
24 enable them then to vote, even if the affidavit was false?
25 THE WITNESS: I say yes because the whole purpose
37
1 is to establish the identity of the person who went to the
2 poll. And if they used the reasonable impediment because they
3 didn't have an ID, you know, and then they produce one, then
4 we've verified who cast that ballot and the ballot should be
5 counted.
6 HON. JOHN D. BATES: So even though that voter had,
7 let's just put it bluntly, had lied about a reasonable
8 impediment and hadn't gone to the trouble of getting the photo
9 voter ID, but then had gone and done it on Wednesday, that's
10 good enough and their votes count?
11 THE WITNESS: I think so, because again, the
12 purpose is to establish that the voter who cast the ballot was
13 the person that was, you know, in the polling place.
14 HON. JOHN D. BATES: So that's in effect
15 encouraging those who show up without a photo ID to perhaps
16 lie on an affidavit so that they then have time to go and get
17 photo ID.
18 THE WITNESS: I don't want to encourage them to
19 lie, but --
20 HON. BRETT M. KAVANAUGH: Couldn't they be
21 prosecuted for that? I asked this yesterday, but if you do a
22 false statement under oath, you're at least exposed.
23 THE WITNESS: Yes.
24 HON. JOHN D. BATES: But unlikely to be prosecuted
25 in your view.
38
1 THE WITNESS: Well, it's up to the solicitors and,
2 you know, they don't often take these things. But it would
3 make an example of somebody and probably deter it.
4 HON. BRETT M. KAVANAUGH: For this election -- I
5 have a couple other questions. For this election, I thought
6 it was established yesterday that everyone will have a
7 reasonable impediment who doesn't have one of the required IDs
8 because of the short timeframe between any preclearance that
9 may or may not happen and the election day.
10 THE WITNESS: That's correct.
11 HON. BRETT M. KAVANAUGH: And then in the future,
12 one hypothetical we haven't talked about, and I'd rather talk
13 about a more realistic hypothetical, which is someone who says
14 I don't have a car or access to a car and therefore couldn't
15 get to the county election office. That's a reasonable
16 impediment.
17 THE WITNESS: In my view, yes.
18 HON. BRETT M. KAVANAUGH: Okay.
19 HON. JOHN D. BATES: To follow up on that, your
20 view is that everyone, basically everyone would have a
21 reasonable impediment under the circumstances of the November
22 2012 election.
23 THE WITNESS: Yes, because of the short timeframe.
24 HON. JOHN D. BATES: Are you going to advise voters
25 in some way that you think everyone has a reasonable
39
1 impediment? Or is this just going to be left to what happens
2 to take place in the dialogue with the poll watcher and how
3 things evolve in that setting?
4 THE WITNESS: We'll encourage voters to get one of
5 the acceptable forms of ID if they don't --
6 HON. JOHN D. BATES: For instance, in the notice --
7 you're going to put some notice in each polling place, right?
8 THE WITNESS: Yes.
9 HON. JOHN D. BATES: In that notice, have you
10 contemplated saying, any voter who's unable because of the
11 short timeframe of this election to get a photo ID can simply
12 inform the poll watcher that that was an impediment to their
13 getting one of these photo IDs, and therefore will be
14 permitted to vote through the affidavit process? Are you
15 going to put up that notice?
16 THE WITNESS: We haven't considered that but, you
17 know, that would be a good way not to disenfranchise voters,
18 to inform them.
19 HON. COLLEEN KOLLAR-KOTELLY: Then in future
20 elections, can you in perpetuity say I lack transportation
21 because you do, and for all of the elections you can always
22 come up with that as the reason?
23 THE WITNESS: Well, for some people, you know, they
24 may not be able to drive or afford a car. So that is
25 something that they could use repeatedly. We wouldn't limit
40
1 it just to one election.
2 HON. BRETT M. KAVANAUGH: And as long as it's not
3 false, in other words, they don't have -- as long as they
4 don't have a car or access to a car, that has to be accepted,
5 correct.
6 THE WITNESS: Yes.
7 HON. BRETT M. KAVANAUGH: Okay.
8 BY MR. BEENEY:
9 Q. Ms. Andino, to follow up a couple of the Court's
10 questions. If I'm not qualified under the law to vote on
11 Tuesday, but I get an ID on Thursday and show it to the county
12 commission on Friday, it's your view that my vote should count
13 even though I was not qualified to vote on election day?
14 A. I don't know that I would call it qualified. You
15 didn't have your ID.
16 Q. Well, that's a qualification of the law, isn't it?
17 A. Not a qualification to be a registered voter.
18 Q. No, but it's a qualification to vote. The law says I
19 can't -- the whole reason we're here is because the law says I
20 can't vote unless I've got one of these five IDs on election
21 day. Is it really your testimony that if I get it later, I
22 can still vote, even though I wasn't qualified to vote on
23 election day?
24 A. If you don't have your ID with you on election day, the
25 law provides that you can vote through the reasonable
41
1 impediment. And if you provide an ID afterwards, then you've
2 proven your identity, and yes.
3 Q. But what if I get it on Wednesday, Thursday or Friday
4 and I didn't have it on Tuesday?
5 A. Yes.
6 Q. I can still vote?
7 A. Yes.
8 Q. Even though I wasn't qualified on election day?
9 A. Yes.
10 Q. And in terms of the Court's questions about everybody
11 being able to vote in November because of the preclearance
12 date, if there is any, that would mean you have to process by
13 your count, and putting aside military and passports, 180,000
14 reasonable impediment affidavits on election day?
15 A. Well --
16 HON. BRETT M. KAVANAUGH: That assumes a hundred
17 percent turnout, right?
18 MR. BEENEY: It does.
19 HON. JOHN D. BATES: It doesn't happen in this
20 country very often.
21 BY MR. BEENEY:
22 Q. Yes. Well, let's even assume 90,000. I'm more than
23 happy to adopt the Court's correction to my question, my
24 hypothetical, make it more reasonable. You'd still have to
25 process 90,000 reasonable impediment affidavits on election
42
1 day?
2 A. We would have to produce, or process some number. I
3 don't know if it's even 90,000. You know, we have not taken
4 into consideration that they have another form of ID, that
5 they have received, or gotten an ID since January of 2010 when
6 that report was produced.
7 Q. But that also doesn't include all the other people who
8 have registered with a State Election Commission registration
9 card without photo ID, including, as the Court asked
10 yesterday, all these people you're going to try to register in
11 September, who you're going to give a non-photo ID
12 registration card to that they can't use to vote in November,
13 right?
14 A. Yes.
15 HON. COLLEEN KOLLAR-KOTELLY: If I could ask one
16 follow-up. So let's assume 90,000, a combination of
17 reasonable impediments and the provisional ballots, which the
18 county commissioners are reviewing, you know, with the hearing
19 Thursday or Friday. What if they can't get through all of
20 them before they have to certify the election? What happens?
21 THE WITNESS: They will stay in session and go
22 through every ballot before they meet to certify. So it could
23 be a very lengthy process, but they would stay in session
24 until they finished the provisional ballots and then certify
25 the election.
43
1 HON. JOHN D. BATES: Is there a required date for
2 certification --
3 THE WITNESS: Yes.
4 HON. JOHN D. BATES: -- under state law? What is
5 that date?
6 THE WITNESS: It is, for the primary, it's the
7 Thursday following the election, and for a general or special
8 election, it's the Friday.
9 HON. JOHN D. BATES: So by that Friday they have to
10 under state law certify?
11 THE WITNESS: Correct.
12 HON. JOHN D. BATES: And you're saying they'd just
13 work around the clock between early Wednesday morning and
14 Friday at 11:59 p.m. in order to do that.
15 THE WITNESS: Yes.
16 HON. COLLEEN KOLLAR-KOTELLY: Including any
17 challenge hearings. So let's suppose that somebody, the poll
18 watchers show up and decide to challenge a whole bunch of
19 reasonable impediments. They are going to count them, they're
20 going to review them, they are going to count them, they are
21 going to have these hearings, and have this all done after the
22 polls close on Tuesday by, what did you say, noon on Friday?
23 I thought it was Saturday.
24 THE WITNESS: It's Saturday when the State Election
25 Commission typically meets, but we actually have 10 days after
44
1 the general election before we have to certify. But counties
2 meet on the Friday for a general.
3 HON. JOHN D. BATES: Wait a minute. I was taking
4 your certification date as being that Friday after the
5 election. You're saying you have 10 days?
6 THE WITNESS: The State Election Commission has 10
7 days. There is a two-step process.
8 HON. JOHN D. BATES: Oh, I see. The county has to
9 get it in to the state by that Friday.
10 THE WITNESS: Correct.
11 HON. COLLEEN KOLLAR-KOTELLY: So between that time,
12 they would have to look at whatever you reviewed at the
13 reasonable impediment in terms of looking at it, opening it
14 up, making whatever decision, and if there were challenges,
15 they would have to have all of this done in that time period?
16 THE WITNESS: Yes.
17 HON. COLLEEN KOLLAR-KOTELLY: Just for purposes of
18 this, let's assume they just didn't have enough time, 24 hours
19 or not, because a whole bunch of people came and, you know,
20 challenged them at particular hearings. What would happen?
21 THE WITNESS: I think they would continue to meet
22 and they would get the certification to us on Saturday or
23 Sunday or whenever they finished it. It would be after the
24 date that they set to certify, but I think it's more important
25 that they continue the process and they get the certification
45
1 correct so that everyone has the assurance that their vote was
2 counted.
3 HON. JOHN D. BATES: That would be preferable even
4 though it might be a violation of state legal requirements?
5 THE WITNESS: Yes.
6 HON. JOHN D. BATES: Just as several other things
7 that have been mentioned today.
8 THE WITNESS: Yes.
9 HON. BRETT M. KAVANAUGH: Just as in Florida.
10 BY MR. BEENEY:
11 Q. Ms. Andino, again just to follow up on a couple of the
12 Court's questions. The hearing to look at the provisional
13 ballots and the reasonable impediment ballots doesn't start
14 until Friday, right?
15 A. That's correct.
16 Q. So the time that the county commissioners have by law
17 to certify the vote and look at whatever number that we use
18 for these reasonable impediment affidavits is Friday and only
19 Friday?
20 A. It is Friday.
21 Q. Now, back to the procedure of I'm coming in to vote.
22 Assuming there is a notary, I've gone in, I've said yes, I
23 have a reasonable impediment, I've either filled out the
24 affidavit or I've gotten help doing that, I've gotten it
25 notarized. The next step is is that I bring it back to the
46
1 poll manager, right?
2 A. Yes.
3 Q. Or I hand it over to the poll manager, because this is
4 all happening at the check-in table while my neighbors are
5 standing behind me, right?
6 A. I believe that it would -- it could be at the check-in
7 table. It may be a different table, and it depends on really
8 the size of the polling place. If there's room to separate
9 out the processes, they will. But some polling places are
10 limited by size. So it could potentially be, yes.
11 Q. Do you remember telling us on Friday that that is the
12 way it would happen, that all this would be done while I'm
13 checking in and everybody, all my neighbors are standing
14 behind me?
15 A. Well, I did say that, but I wanted to clarify that in
16 some polling places check-in takes place at multiple tables,
17 and it's just, you know, with 2,100 polling places, they don't
18 all have the luxury of having additional space or lots of
19 space.
20 Q. Now, I think you told us again on Friday that you
21 really have no belief one way or the other of whether this
22 process is likely to cause huge embarrassment to a voter who
23 has got to write down things like I can't afford a car or I
24 don't have a car or whatever else they might be writing. You
25 don't have a view one way or the other, is that right?
47
1 A. You know, it's not a -- it's not a completely public
2 process as you implied. Your neighbors and people are going
3 to be back. I mean, they shouldn't be crowded around the
4 table listening. So I don't know if that's going to be an
5 embarrassment to people or not.
6 Q. And the poll watcher representing the candidate is
7 watching this process anyway?
8 A. Could be, yes.
9 Q. So assuming I get my affidavit and I get it notarized
10 because I've been able to prove to the notary who I am, the
11 poll manager then gives me a ballot, and I take it to the
12 voting booth to complete the ballot, correct?
13 A. Yes.
14 Q. And then putting aside for a minute the reasonable
15 impediment process, for other provisional ballots, I put it in
16 the envelope and drop it in something called the -- sorry,
17 withdrawn.
18 Putting aside reasonable impediment affidavit
19 ballots, if I'm voting by other provisional ballot, I put it
20 in an envelope that says "challenged ballot envelope," and
21 then I drop it into the ballot box, right?
22 A. I believe they go, all of them go into the same type of
23 envelope.
24 Q. But what I'm going to get at is there is a step in
25 between under the procedures that you have identified here,
48
1 which is that if I'm voting by reasonable impediment
2 affidavit, I have to hand my ballot, with no security at all,
3 back to the poll manager, right?
4 A. I believe that is in our procedure, yes.
5 Q. And so the poll manager can look to see how I voted, if
6 they are so inclined. And maybe even the poll watcher can
7 look to see how I voted, if they are so inclined?
8 A. No.
9 Q. Well, if we take Exhibit 505 and assume this is my
10 ballot, I've got to hand this back to the poll manager, and
11 the poll -- withdrawn. I have to hand this back to the poll
12 manager, and the poll manager puts it into the envelope under
13 your procedures, right?
14 A. Yes.
15 Q. You certainly have received complaints from time to
16 time that poll managers act in partisan ways?
17 A. Yes.
18 Q. Now, finally, after I do all this and I hand my ballot
19 back to the poll manager, I get notice that there will be a
20 hearing on my ballot on Friday at the county seat?
21 A. Yes.
22 Q. And at the hearing -- and we're going to get to those
23 procedures in a moment -- the county board sits as the board
24 of canvassers and decides whose vote gets counted?
25 A. That's correct.
49
1 Q. And only a court can overrule that decision; the State
2 Election Commission cannot?
3 A. Yes.
4 Q. The county boards are appointed by the Governor after
5 she receives recommendations from the county general assembly
6 delegation?
7 A. Yes.
8 Q. And boards can range in size from five to 11?
9 A. Yes.
10 Q. And the only requirement with respect to party
11 affiliation of the boards is that there must be one Democrat
12 and one Republican?
13 A. That's correct.
14 Q. So an 11-member county board, the Governor could
15 appoint 10 Republicans or 10 Democrats?
16 A. Yes, that's possible.
17 Q. And the decisions about whether to count a provisional
18 ballot, including one that is offered by reasonable impediment
19 affidavit, is made by a majority vote at the county board?
20 A. Yes.
21 Q. And you've tried to give the counties some guidance on
22 how to determine whether the county board has grounds to
23 believe that the reasonable impediment affidavit is false, is
24 that right?
25 A. Would you repeat that.
50
1 Q. Yes, ma'am. You've tried to give the counties some
2 guidance about how to determine whether a reasonable
3 impediment affidavit is false?
4 A. Yes.
5 Q. And anybody at that hearing can offer evidence about
6 whether that affidavit is true or false?
7 A. Yes.
8 Q. Now, going to Defendant-Intervenors' Exhibit 505, there
9 is an appendix here that is the State Election Commission
10 guidance to the county board about how to determine whether an
11 affidavit is false, is that right?
12 A. Yes.
13 Q. And one of the things that you've provided guidance to
14 the county, and I believe this comes directly out of the state
15 Attorney General's opinion under section 4(a) of Exhibit 505,
16 is that the burden is on the board to prove that a false
17 statement was knowingly included in the affidavit, or was
18 included with reckless regard for the truth. Is that right?
19 A. I believe that should be the burden is on the
20 challenger.
21 Q. Okay.
22 A. And it does say "board," but I believe it should be
23 "challenger."
24 Q. Okay. But that burden is to establish that the
25 affidavit was executed with reckless regard for the truth, and
51
1 then you quote up in section 3 the state Attorney General
2 opinion, which also talks about reckless regard for the truth,
3 right?
4 A. Yes.
5 Q. What is reckless regard for the truth?
6 A. It's language that was used in the Attorney General
7 opinion, and we're trying not to interpret that, so we did not
8 offer a definition of what reckless regard for the truth is.
9 Q. So you're leaving that up to each individual county
10 board?
11 A. Yes.
12 HON. JOHN D. BATES: Do you have an understanding
13 of what it is, reckless regard for the truth?
14 THE WITNESS: Yes.
15 HON. JOHN D. BATES: What is it in your view?
16 THE WITNESS: That the person did not tell the
17 truth and --
18 BY MR. BEENEY:
19 Q. Then after all these hearings are conducted, then the
20 board decides, does voter A honestly not have transportation
21 to the county seat, and if I believe it was honest, they get
22 to vote. Voter B, who says I had no transportation to the
23 county seat, and if I'm a county election commissioner and I
24 have grounds to believe that that is false, voter B's vote
25 isn't counted?
52
1 A. Yes.
2 Q. And the only way that decision can be overturned if I'm
3 a voter is to sue the county board in court?
4 A. Yes.
5 Q. Now, the county board will be making that determination
6 knowing the identity of the voter? Before they decide whether
7 to count the vote, they will know the name of the voter,
8 right?
9 A. Yes.
10 Q. And if I know the person or I happen to believe that
11 the voter is an African American, given the fact that voting
12 in South Carolina is racially polarized, I have a pretty good
13 idea how that person voted, don't I?
14 A. Yes.
15 Q. Before I decide whether to count the vote?
16 A. Yes.
17 Q. So after all this, Ms. Andino, can we agree that R54
18 gives the county boards at least some discretion over whether
19 to allow someone to exercise their franchise?
20 A. Yes.
21 Q. And unless I get myself to the county seat on Friday
22 for the hearing, I don't know until after the vote is
23 certified whether my vote was ever counted?
24 A. That's correct.
25 Q. And the only way I'll ever know is if I call the State
53
1 Election Commission or happen to have access to the Internet
2 and go online?
3 A. Yes, or call the county.
4 Q. Don't you think that also destroys confidence in the
5 system?
6 A. Well, that's what's provided for in the law.
7 Q. Well, as one Senator once said to another, I'll take
8 that as a no.
9 HON. JOHN D. BATES: But your testimony won't be
10 counted.
11 (Laughter)
12 MR. BEENEY: Judge Bates, this is
13 cross-examination. I thought it was always testimony.
14 BY MR. BEENEY:
15 Q. Now, Ms. Andino, I want to go through just some
16 reactions that the county has had to some of the guidance that
17 you've given them. And we've already I think established that
18 the director in Beaufort County, Scott Marshall, told you the
19 procedures, or at least part of them are ridiculous, right?
20 A. Yes.
21 Q. And he told you that the counties can't prohibit a
22 notary from charging to notarize an affidavit, right?
23 A. I don't recall that part.
24 Q. Let's take a look at Defendant-Intervenors' Exhibit
25 512. Do you recognize this as excerpts from the State
54
1 Election Commission ElectionNet?
2 A. Yes.
3 Q. And if we go to the third page, this is sent to you by
4 Scott Marshall, who's the director in Beaufort County, is that
5 right?
6 A. Yes. Beaufort.
7 Q. Beaufort. I'm sorry. Proves again I don't vote in
8 South Carolina. Do you see he says here, "Conversely, we
9 cannot prohibit them from charging a fee"?
10 A. I disagree.
11 Q. But you at least now recall that that's what he told
12 you?
13 A. Yes.
14 Q. And when you've got disagreement with the county
15 officials, there's nothing you can do about it if they
16 continue to want to disagree with you?
17 A. No.
18 Q. So if the director in Beaufort County maintains his
19 position that they can't prohibit the notary at the polls from
20 charging a fee, we have a poll tax if someone wants to vote by
21 reasonable impediment affidavit?
22 A. Although Mr. Marshall's comments don't always seem
23 reasonable, he tends to be, and we can get an Attorney
24 General's opinion, and we'll also work with the Secretary of
25 State's office on notaries to make sure that there's a smooth
55
1 process in place.
2 Q. It wasn't only -- I'm sorry -- Beaufort County that
3 told you this amounts to a poll tax, but it was also the
4 officials in Kershaw County that told you it amounts to a poll
5 tax, right?
6 A. Yes.
7 Q. And it was the Kershaw County official who said that
8 the R54 law was, quote, making our state out to be the fool in
9 the national press, quote, right?
10 A. Yes, I believe so. Mr. Fitzpatrick is a staff member
11 in Kershaw County. And like I said earlier, sometimes they
12 use ElectionNet to vent.
13 Q. And speaking of venting, the director in Spartanburg
14 told you that once again the state, quote, has crafted
15 legislation which requires a citizen to incur an express to
16 participate in an event. Do you recall that?
17 A. Yes.
18 Q. And the Kershaw County official also told you that R54
19 will result in, quote, a plethora of coming lawsuits?
20 A. Yes.
21 Q. And that the reasonable impediment provision was
22 intentionally vague to give the legislature an, quote, out,
23 quote, for preclearance?
24 A. Yes.
25 Q. And the director in Jasper County told you that -- she,
56
1 I think?
2 A. She.
3 Q. She doesn't have enough poll manager notaries to cover
4 her precinct, and she ended that comment with a "wow," W-O-W,
5 exclamation point. Do you remember that?
6 A. Yes.
7 Q. And the director of Lancaster County told you, quote, I
8 hope the poll workers will not have to decide what a
9 reasonable impediment is and what it's not. Do you remember
10 that?
11 A. Yes.
12 Q. That person said, this is not a good way to handle
13 voter ID. Do you remember that?
14 A. Yes.
15 Q. And finally, the director of Union County asked you,
16 how do you notarize an affidavit stating that they don't have
17 an ID? The purpose of the notary is to verify the
18 identification of the person filing the document. Do you
19 remember that?
20 A. Yes.
21 Q. Ms. Andino, you are required under R54 to notify by
22 mail voters you identify who don't have a DMV ID, correct?
23 A. Yes.
24 Q. And the process is is that you're going to have to get
25 a list from DMV of people who have DMV IDs?
57
1 A. That's correct.
2 Q. And after preclearance, that process you think will
3 take about two weeks?
4 A. Yes.
5 Q. Once you get that list, after the two weeks, you have a
6 mailing that you intend to send out to the voters?
7 A. That's correct.
8 Q. Would you identify for me that the exhibit we're going
9 to put up now, which is Defendant-Intervenors' Exhibit 506, is
10 the postcard that you're going to use to send to voters.
11 HON. COLLEEN KOLLAR-KOTELLY: While that is coming
12 up, if I can ask, the list that you're going to do, which
13 would be DMV driver's licenses and DMV identification, is that
14 going to include people that have only current, so they
15 wouldn't include anybody who's expired? Would it include
16 people that have suspended or revoked, or do you know?
17 THE WITNESS: In the past they had provided only
18 the current. So anyone that was suspended or revoked, they
19 were not included.
20 HON. COLLEEN KOLLAR-KOTELLY: So the list that you
21 gave also to the General Assembly some time ago when you
22 compared those that had the IDs to those, the voters, the
23 178,000 we've been talking about, then the DMV list would only
24 have been current and non-expired, non-revoked driver's
25 licenses?
58
1 THE WITNESS: Yes. And what they've, what DMV has
2 told us is that when somebody's license is revoked they offer
3 the identification card to them.
4 HON. COLLEEN KOLLAR-KOTELLY: Okay.
5 BY MR. BEENEY:
6 Q. Ms. Andino, would you identify for us
7 Defendant-Intervenor Exhibit 506 as the information that
8 you're going to provide to voters that you identify as not
9 possessing a DMV-issued photo ID that is acceptable for voting
10 under R54?
11 A. This is the current version of that postcard.
12 Q. And the current version of the postcard does not say
13 anything about the ID to be used to vote having to be current
14 and valid, does it?
15 A. It does not.
16 Q. And I think you told us on Friday that it would be
17 reasonable for a voter to believe that they could vote with an
18 expired driver's license. Do you recall that?
19 A. Yes.
20 Q. Now, you told the voter in this section here on
21 Defendant-Intervenors' Exhibit 506, under the portion of the
22 card that says "New South Carolina photo identification
23 requirements," that if you can -- if you need to complete an
24 affidavit at the polls because you don't have one of the five
25 required IDs, you should bring your current voter registration
59
1 card with you to the polling place, right?
2 A. Yes.
3 Q. And that is based on your hope that the notary will
4 accept a form of identification to prove who the voter is
5 which you can't accept to prove who the voter is for voting?
6 A. Yes.
7 Q. But you don't tell the voter in the card to bring any
8 other form of photo ID to prove who they are to the notary?
9 A. We do not.
10 Q. Ms. Andino, I think just one final question. As you
11 sit here today, and I want to ask you not about R54, but I
12 want to ask you about existing voting requirements in the
13 state of South Carolina. And with all of your experience with
14 the State Election Commission, do you believe that the
15 non-photo registration card that everyone can use to vote
16 today that's eliminated by R54 is sufficient to identify a
17 person as to who they are for voting purposes?
18 A. Under current law it is.
19 Q. And do you believe that it is sufficient to identify
20 who the person is for voting purposes?
21 MR. BOWERS: Objection on relevance grounds. I
22 don't think this is relevant in terms of a Section 5
23 determination.
24 HON. COLLEEN KOLLAR-KOTELLY: I'll allow it.
25 Overruled. Go ahead.
60
1 THE WITNESS: Could you repeat your question.
2 BY MR. BEENEY:
3 Q. Sure. And maybe I'll say it in a way that's a little
4 bit quicker. Friday you told us that you thought that the
5 non-photo registration card would be sufficient to identify
6 who a person is. Do you still believe that today?
7 A. Yes.
8 MR. BEENEY: Thank you, Your Honors. Thank you,
9 Ms. Andino.
10 HON. COLLEEN KOLLAR-KOTELLY: All right.
11 HON. JOHN D. BATES: Let me just make sure I have
12 the timing of this postcard correct. You haven't printed
13 these postcards yet.
14 THE WITNESS: No. They won't be printed until we
15 have the list.
16 HON. JOHN D. BATES: And you won't -- will you get
17 the list before there's any preclearance by this court,
18 assuming this court preclears R54?
19 THE WITNESS: No. Upon preclearance I will
20 personally call the director of DMV and request the list.
21 HON. JOHN D. BATES: You'll get the list, and
22 you'll make any changes that you think are appropriate to this
23 postcard, and then you'll have the postcards printed. And you
24 said that whole process will take how long?
25 THE WITNESS: The comparison, our experience in
61
1 doing the comparison and reviewing and making sure that we're
2 using the right variables and -- usually takes between a week
3 or two. And I believe that this card can be edited right up
4 to the minute it prints. It's not that we have a preprinted
5 card, it's laid down by the printer as it's addressed to each
6 voter.
7 HON. JOHN D. BATES: So how long after preclearance
8 will you actually have the cards in hand and the addresses of
9 the people so you can put those on the cards ready to put in
10 the mail?
11 THE WITNESS: A conservative estimate would be two
12 weeks.
13 HON. JOHN D. BATES: Do you think that's a
14 reasonable estimate, or is "conservative" meant to indicate
15 something other than reasonable and likely?
16 THE WITNESS: No, I believe that we can do it a
17 little quicker than that, but I'm trying to build in a little
18 extra time.
19 HON. JOHN D. BATES: So two weeks.
20 THE WITNESS: Yes.
21 HON. JOHN D. BATES: And then they would have to be
22 mailed out.
23 THE WITNESS: Yes.
24 HON. JOHN D. BATES: So if there were preclearance,
25 again to use the September 15 date that has occasionally been
62
1 used in the conversation over the last three days -- to use
2 that date, it would be the beginning of October before they
3 were mailed, right around the beginning of October. And then
4 before they were received, it would be the end of the first
5 week, maybe into the second week of October. Is that a fair
6 guesstimate?
7 THE WITNESS: I hope they will receive them faster
8 than that after they're mailed, but yes.
9 HON. JOHN D. BATES: But it's about 30 days before
10 election day.
11 THE WITNESS: It is.
12 HON. JOHN D. BATES: So that's the period of time
13 that the voters, particularly the voters who are most likely
14 not to have the requisite IDs, would receive this notification
15 and then be able to do anything about it, 30 days.
16 THE WITNESS: Yes.
17 BY MR. BEENEY:
18 Q. Ms. Andino, just to follow up. There's one little
19 point in there that I think you've got to build in to the
20 timeline that you may not have done in the questions, which is
21 you also have to wait for the DMV to generate its list before
22 you do anything, because you need that list to do your
23 comparison, right?
24 A. I have factored that in, and we've been working with
25 DMV and they have been very cooperative, and I believe that if
63
1 I call their director, that within a day or so I will have
2 that list. It will be a priority for them.
3 Q. Is that new? Because I think you told us it would take
4 about a week to get the information from DMV.
5 A. It has taken a week in the past, but we have been
6 working very closely with them on other issues, and I believe
7 they understand the importance and that they will provide the
8 list as quickly as they can.
9 Q. But at least history's guide is that it takes about a
10 week to get the list, and then you need about two weeks to
11 generate your list?
12 A. Yes, and that's when we were requesting a list for the
13 purpose of jury rolls.
14 MR. BEENEY: Thank you, Ms. Andino. Thank you,
15 Your Honors.
16 HON. COLLEEN KOLLAR-KOTELLY: All right. South
17 Carolina.
18 MR. BOWERS: Just a few questions, Your Honor.
19 Again, Butch Bowers here for the state of South Carolina.
20 EXAMINATION
21 BY MR. BOWERS:
22 Q. Ms. Andino, Mr. Beeney spent a little bit of time
23 asking you about ElectionNet here just a few moments ago. Do
24 you recall that?
25 A. Yes.
64
1 Q. Tell the Court again, please, how many people have
2 access to ElectionNet approximately?
3 A. Approximately 400. All county election commission,
4 voter registration and election commission staff, as well as
5 commissioners, as well as State Election Commission staff have
6 access to the intranet site.
7 Q. And all of the comments that Mr. Beeney was asking you
8 about, were those just unsolicited or had you posted something
9 about R54?
10 A. I had posted an update to the status of R54 and had
11 notified the counties that notaries would be required at the
12 polling place, suggested that when they are recruiting poll
13 managers, they ask if they're notaries. And also provided
14 them with a list of poll managers that we have identified as
15 also being notaries.
16 Q. So these weren't just out of the blue comments; you had
17 posted something?
18 A. That's right.
19 Q. And when did you post that, do you recall?
20 A. I don't recall the date. It's been probably two to
21 three weeks ago.
22 Q. And then how many people do you recall, approximately
23 how many responded?
24 A. Maybe 20, 25. I'm not sure.
25 Q. Mr. Beeney also asked you about the director in
65
1 Beaufort County, Mr. Scott Marshall. Do you recall that
2 testimony?
3 A. Yes.
4 Q. Has Mr. Marshall ever disagreed with you on the law of
5 South Carolina regarding elections?
6 A. Yes.
7 Q. In fact he sued you, didn't he?
8 A. Yes, he did.
9 Q. Tell the Court about that, please.
10 A. Last year, late last year after the General Assembly
11 passed the appropriations act, which required us, or allowed
12 us to use carry-forward funds for primaries, to conduct the
13 presidential preference primaries in January, Mr. Marshall did
14 not feel that we had the authority to order counties to
15 conduct those elections. And they brought suit in the Supreme
16 Court --
17 Q. In the Supreme Court --
18 A. -- of South Carolina.
19 Q. In the South Carolina Supreme Court. And what was the
20 outcome of that?
21 A. The Court ruled against Mr. Marshall.
22 Q. So at least according to the Supreme Court in that
23 issue, Mr. Marshall was wrong about South Carolina election
24 law, correct?
25 A. Yes.
66
1 Q. Did he ever vent on ElectionNet regarding the
2 presidential primary funding issue -- I'm sorry. Did
3 Mr. Marshall ever vent on ElectionNet with regard to the
4 funding issue with the PPP?
5 A. Yes, Mr. Marshall comments frequently on ElectionNet.
6 Q. I want to take you back to some of the questions I
7 think the Court was asking you, and then also Mr. Beeney. If
8 a voter appears at the polling place and he already possesses
9 a valid and current photo identification, but he didn't bring
10 it with him to the polling place, what happens?
11 A. Under current law?
12 Q. Yes, ma'am.
13 A. There's no provision in the law currently for that
14 person to vote, so they would be turned away, and they would
15 have to go back and get their ID. And poll managers across
16 the state have done that to several high-profile people.
17 Q. In fact Governor Sanford at one point, correct?
18 A. Governor Sanford and Chief Justice Jean Toal.
19 Q. So that's current law. What happens under R54?
20 A. Under R54 they could vote a provisional ballot, and
21 produce their ID after the election.
22 Q. In that situation are they required to fill out the
23 reasonable impediment affidavit?
24 A. No.
25 Q. So this whole issue of whether the affidavit was false
67
1 at the time he swore it out, if the person had ID, that's a
2 nonissue, is it not, because there is no affidavit?
3 A. Yes, that's correct.
4 Q. Do you view that provision of R54 as an improvement or
5 as a detriment to voters?
6 A. It makes it easier for a voter to cast a ballot if
7 they've forgotten their ID at home.
8 Q. Ms. Andino, I heard some questions from Mr. Beeney
9 about qualified to vote. What does it currently take under
10 South Carolina law to register to vote?
11 A. You have to be a citizen of the United States, you have
12 to be a resident of South Carolina, you have to be 18 years of
13 age or older, not under a court declaring you mentally
14 incompetent, and have not been convicted of a felony or
15 offense against the election laws unless you've served your
16 entire sentence, including probation or parole.
17 Q. So have you just described for the Court the
18 qualifications to become a registered voter?
19 A. Yes.
20 Q. And talk for a moment, please, ma'am, about the
21 registration process, and specifically what does a voter --
22 I'm sorry. Strike that. What does a person who is qualified,
23 what do they have to bring to the, or provide to the election,
24 to the election officials with regard to identification?
25 A. When they are registering to vote?
68
1 Q. Yes, ma'am.
2 A. If they are registering through one of the motor voter
3 agencies, they do not have to provide any additional
4 information proving identity; they've already established
5 their identity through one of these agencies.
6 If they come into the voter registration office,
7 the registration clerk is going to ask for something to
8 establish that they are a registered -- or they are a citizen
9 and they are a resident of that county. It could be -- and we
10 use the list that's in the Help America Vote Act as our
11 guideline.
12 If a person registers by mail for the first time
13 in a jurisdiction, then they do have to show a photo ID or one
14 of the other documents listed in the Help America Vote Act.
15 Q. And in registration by mail, do they -- does a person
16 have to provide photo identification?
17 A. Yes, if they are registering in the jurisdiction for
18 the first time, they have to show one of those IDs that is
19 listed in the Help America Vote Act.
20 Q. That's in the mail-in application, correct?
21 A. Yes.
22 Q. Okay. But then once they appear for the first time to
23 cast a ballot, are they required to show a photo
24 identification?
25 A. Not at this time.
69
1 HON. COLLEEN KOLLAR-KOTELLY: What do you mean by
2 not at the time? You mean prior to R54?
3 THE WITNESS: Yes.
4 HON. COLLEEN KOLLAR-KOTELLY: Okay.
5 THE WITNESS: They would only have to show an ID at
6 the polling place in addition to the voter registration card
7 if they did not provide that identification when they
8 submitted the application.
9 BY MR. BOWERS:
10 Q. Okay. I believe Mr. Beeney --
11 HON. COLLEEN KOLLAR-KOTELLY: If I can just -- if
12 you registered to vote for the first time and you had some
13 sort of photo ID at that point, does it then get superimposed?
14 I thought at this point you wouldn't be able to add it to the
15 voter registration card. So did I misunderstand? I mean,
16 when you show up at the polling place, if you had shown it to
17 register but you don't have it on the card, you still could
18 use it without the photo?
19 THE WITNESS: Yes. The federal law requires that
20 if you are registering to vote for the first time by mail,
21 that you have to show either photo ID -- and then it goes
22 through a list of, it could be a government-issued document
23 and a number of documents that don't have a photograph. We
24 don't capture that and put it on the voter registration card.
25 There are documents that would allow you to register to vote
70
1 that would not under R54 allow you to vote.
2 HON. COLLEEN KOLLAR-KOTELLY: So you could get the
3 card, but you couldn't actually vote unless you had the photo
4 added to it?
5 THE WITNESS: Correct.
6 BY MR. BOWERS:
7 Q. Following up on that with regard to adding the photo to
8 the voter registration card. I believe you testified earlier
9 that initially that will be a black and white photograph, is
10 that correct?
11 A. That's correct.
12 Q. And will that be permanent, and as we -- assuming R54
13 is precleared, will that be the way the law is implemented in
14 the future, a black and white photograph?
15 A. Well, that's a temporary card. There's actually not
16 a -- it's not temporary that it expires, it is less permanent
17 because it is not on a plastic, it's on a paper, a heavy card
18 stock. That will be issued by the voter registration office.
19 The picture will be electronically sent to our office and we
20 will produce the plastic, more permanent card.
21 Q. In color?
22 A. In color.
23 Q. There was some discussion about the numbers of
24 potential folks who would not have an approved form of photo
25 identification, and there was some discussion about turnout.
71
1 In your experience at the State Election Commission, have you
2 ever seen a hundred percent voter turnout in South Carolina?
3 A. Never.
4 Q. What is the most recent election that occurred in South
5 Carolina statewide? Was it the primary in June?
6 A. No, because all counties weren't included in the
7 primary. It would have been the presidential preference
8 primary in January.
9 Q. Okay. What was the turnout there approximately? Do
10 you recall?
11 A. I think it was around 12 percent.
12 Q. And that was in January of 2012?
13 A. Correct.
14 Q. And then there was a primary election held in most
15 counties in June, correct?
16 A. Yes.
17 Q. Do you know what the turnout in that election was?
18 A. I do not.
19 Q. Do you think it was higher or lower than 12 percent?
20 A. Higher.
21 HON. COLLEEN KOLLAR-KOTELLY: What was the --
22 HON. BRETT M. KAVANAUGH: How about in the
23 presidential election in 2008?
24 THE WITNESS: About 70 percent turnout.
25 HON. BRETT M. KAVANAUGH: Okay.
72
1 BY MR. BOWERS:
2 Q. And that was four years ago, correct?
3 A. Correct.
4 Q. Let's talk about the provisional ballot procedure
5 briefly. There was a lot of questions with regard to the
6 procedure. When the voter is casting a provisional ballot,
7 whether it's the reasonable impediment, the one accompanied by
8 the reasonable impediment affidavit, or just the regular
9 provisional ballot, once it's handed to the poll worker --
10 well, back up. When it's handed to the poll worker, does the
11 voter have to -- what does the voter do when he hands it to
12 the poll worker?
13 A. The voter would normally fold the ballot in half, or
14 the poll manager would fold it in half because the ballots are
15 larger than the envelopes. It would be inserted into the
16 envelope and then dropped into the ballot box.
17 Q. Inserted into the envelope. Is the envelope left
18 unsealed?
19 A. No, it's sealed.
20 Q. It's sealed. Okay. Is that the current process?
21 A. Yes.
22 Q. And will that change under R54?
23 A. No.
24 Q. Are you familiar with the online training materials,
25 poll manager training materials?
73
1 A. Yes.
2 Q. With regard to determining the identity of a voter, can
3 you tell the Court a little bit about that and about what
4 those materials contain?
5 A. Well, currently the online training only contains the
6 three forms of ID that are in effect today: The driver's
7 license, the ID issued by DMV, or the voter registration card.
8 Q. Right. It hasn't been updated yet to reflect R54, has
9 it?
10 A. It is being updated this week.
11 Q. But with regard to determining whether -- determining
12 the identity of a person based on the three forms that are
13 currently acceptable, is there any guidance in there about
14 what the poll manager should do in determining whether it is
15 who that voter says he is?
16 A. Yes. The poll managers are instructed to compare the
17 signature on the form of ID that is presented with the
18 signature that the person signs on the poll list.
19 Q. Anything else in terms of, you know, the visual
20 inspection of the voter?
21 A. I don't recall if it tells them to, you know, look,
22 compare the picture or not.
23 Q. Okay.
24 A. I do remember the signature part.
25 Q. Okay.
74
1 MR. BOWERS: Begging the Court's indulgence.
2 Nothing further, Ms. Andino. Thank you.
3 THE WITNESS: Thank you.
4 HON. COLLEEN KOLLAR-KOTELLY: All right. Justice
5 has an opportunity to ask some additional redirect questions.
6 EXAMINATION
7 BY MS. MEZA:
8 Q. Good morning, Ms. Andino.
9 A. Good morning.
10 Q. You just testified that under current law a voter
11 without the requisite ID would be turned away, correct?
12 A. Yes.
13 Q. And you just also mentioned the Help America Vote Act,
14 HAVA. You're familiar with HAVA?
15 A. Yes.
16 Q. Isn't it true that under HAVA that voter would be
17 entitled to vote by provisional ballot? A voter that under
18 current law comes in and doesn't have the requisite ID.
19 A. If the voter asked to vote provisional ballot, I
20 believe the poll manager will let them do that. But they
21 would still have to produce the ID in order for that ballot to
22 be counted.
23 Q. Produce the ID, I'm sorry?
24 A. Produce the ID.
25 Q. So if a voter under current law were to come in and not
75
1 have what is currently required, the poll manager wouldn't at
2 least offer them the provisional ballot? They would simply be
3 turned away?
4 A. I think that they ask them to go get the ID.
5 Q. And if they are not able to, or if they don't want to,
6 would they be offered the provisional ballot?
7 A. Yes.
8 Q. Also just to clarify, you indicated that a voter would
9 receive a paper black and white card from the county, is that
10 right?
11 A. Yes.
12 Q. And they would also be mailed a color or laminated one
13 from the State Election Commission following that?
14 A. Yes.
15 Q. So when they receive the card from the State Election
16 Commission in the mail, are they required to then return the
17 paper black and white card?
18 A. No, the black and white card serves as the notification
19 of registration, and it would contain their voting place and
20 their districts.
21 Q. So they would essentially have two cards?
22 A. Yes.
23 MS. MEZA: That's all. Thank you.
24 HON. COLLEEN KOLLAR-KOTELLY: All right. Let me
25 excuse you, Ms. Andino. Thank you.
76
1 THE WITNESS: Thank you.
2 HON. COLLEEN KOLLAR-KOTELLY: Why don't we take our
3 morning break. So it's 20 of. Five minutes to 11:00.
4 BRIEF RECESS
5 AFTER RECESS
6 HON. COLLEEN KOLLAR-KOTELLY: Good morning again.
7 MR. BOWERS: Good morning, Your Honor. Thank you,
8 Judge.
9 HON. COLLEEN KOLLAR-KOTELLY: Call your next
10 witness.
11 MR. BOWERS: At this time the State of South
12 Carolina calls Marilyn Bowers.
13 HON. COLLEEN KOLLAR-KOTELLY: Ms. Bowers, if you'd
14 step up over here, please.
15 Thereupon,
16 MARILYN W. BOWERS,
17 the witness herein, having been duly sworn, was examined and
18 testified as follows:
19 EXAMINATION
20 BY MR. BOWERS:
21 Q. Ms. Bowers, would you please state your full name for
22 the record?
23 A. Marilyn W. Bowers.
24 Q. Are we related?
25 A. No, sir.
77
1 HON. COLLEEN KOLLAR-KOTELLY: We were just
2 wondering about -- not whether you're related but your
3 spelling was the same.
4 MR. BOWERS: Spelling is the same.
5 BY MR. BOWERS:
6 Q. Ms. Bowers, where do you reside?
7 A. Easley, South Carolina. 301 North A Street.
8 Q. How long have you lived in South Carolina?
9 A. All of my life.
10 Q. When did you first become involved in elections in
11 South Carolina?
12 A. 1979.
13 Q. In what capacity?
14 A. I was the clerk to the Board of Voter Registration in
15 Pickens County.
16 Q. How long were you in that position?
17 A. Until 1981.
18 Q. And then --
19 A. I became -- I was appointed to the Board of Voter
20 Registration for Pickens County at that time where I served
21 until we combined the Boards in 1985. Through legislation,
22 the Board of Voter Registration and the Election Commission
23 combined, and I became the first director of the combined
24 boards.
25 Q. And that's in Pickens County?
78
1 A. All in Pickens County. Yes, sir.
2 Q. I should have asked you this earlier. Easley where you
3 live now, is that in Pickens County?
4 A. In Pickens County.
5 Q. How long were you the Director there in Pickens County?
6 A. From 1985 to 2005.
7 Q. And then what happened in -- so 20 years. What
8 happened in 2005?
9 A. I had the opportunity to go to Charleston County in
10 South Carolina and serve as their executive director there
11 until I retired from that post in January of 2011.
12 Q. Okay. And are you still involved in elections?
13 A. I currently am serving as a commissioner on the South
14 Carolina State Election Commission.
15 Q. And do you know when you became a member of the State
16 Election Commission?
17 A. It was in the fall of 2011.
18 Q. So, so you were appointed by Governor Haley?
19 A. Yes, sir. When Tracy Green's term -- he went out, I'm
20 filling his unexpired term.
21 Q. When you were in Pickens County as the Director, can
22 you please explain for the Court briefly what your duties and
23 responsibilities were?
24 A. We had a very small office and small staff. So, my
25 duties were everything from registering a voter to doing
79
1 everything involved in conducting the election, preparing the
2 databases for the elections, hiring/training poll managers,
3 down to count the votes. So, I did everything.
4 Q. And in that capacity in Pickens County, you just
5 mentioned training, where would you get your training
6 materials?
7 A. We used training materials for the poll manager
8 training from the State Election Commission.
9 Q. Did you ever have occasion to ask questions for the
10 State Election Commission or seek instruction or direction
11 from 0the State Election Commission?
12 A. We had close contact with the State Election
13 Commission, yes, sir.
14 Q. How about Charleston County, tell the Court a little
15 bit about your experience in Charleston County?
16 A. I was not quite as hands-on in Charleston County
17 because I had a much larger staff that did more of the
18 hands-on. I was more of an overseer to make sure that
19 everything was done correctly and properly. I did do some
20 poll manager training occasionally, but not as much hands-on.
21 And just oversaw the whole operation.
22 Q. And in Charleston County during the poll manager
23 training, did you use the State Election Commission's
24 materials?
25 A. Yes, sir.
80
1 Q. And did you follow those directives?
2 A. Yes, sir.
3 Q. In your vast experience both in Pickens County and
4 Charleston County, can you recall a time where you did not
5 follow the instructions of the State Election Commission?
6 A. No, sir.
7 Q. During your time in both Charleston and Pickens, were
8 you a member of any professional organizations?
9 A. I was a member of our state association of registration
10 and election officials, commonly known as SCARE.
11 Q. Is SCARE and acronym?
12 A. It is an acronym for South Carolina Association of
13 Registration and Election Officials.
14 Q. Tell us a little bit about your role in SCARE, if you
15 would, from start to finish?
16 A. I served in pretty much every position there was on
17 various committees. I held the secretary's office. I was on
18 the board of directors. And then eventually I became the
19 president of SCARE.
20 Q. When was that?
21 A. Between '04 and '06, I believe, was when I had my term
22 as president.
23 Q. What were your duties and responsibilities as president
24 of SCARE?
25 A. Organizing. Just overseeing the whole appointment of
81
1 committees. I was very active then in the legislative process
2 as president. Planning and organizing our annual legislative
3 conference.
4 Q. We'll get to that in just a second. I want to ask you
5 about your -- as president of SCARE, did the organization have
6 any type of working relationship with the State Election
7 Commission?
8 A. Yes, sir. We coordinated very tightly with the State
9 Election Commission. As election officials we were all
10 required to receive certification that was administered by the
11 State Election Commission, and so they were very involved with
12 our conferences and they conducted all of our training for
13 that certification program.
14 Q. Tell the Court, if you would, please, your personal
15 experience in terms of the membership of SCARE and their
16 relationship with the State Election Commission; was it a good
17 one?
18 A. It was very good, yes, sir. I felt like it was very
19 important to have a close working relationship from the state
20 and county levels.
21 Q. Are you familiar at all with whether or not the State
22 Election Commission would from time to time send instructions
23 or directives to the various county election boards?
24 A. Yes, sir. We routinely received instruction or
25 suggestions. If it was not law, they would send us
82
1 recommendations for additional hours, for certain things, so
2 that we would be more uniform throughout the 46 counties
3 instead of doing things 46 different ways.
4 Q. In your experience as the president of SCARE, did you
5 have occasion to talk with your membership with regard to the
6 instructions or training received from the State Election
7 Commission?
8 A. I greatly encouraged uniformity throughout the 46
9 counties in following the guidelines that we were being sent
10 from the State Election Commission.
11 Q. And how was that received?
12 A. It was received good.
13 Q. I want to jump back to Charleston County just for a
14 second. When you were in Charleston County, you said your
15 title was executive director?
16 A. Yes, sir.
17 Q. And how many board members were there or are there in
18 Charleston County?
19 A. We had seven board members.
20 Q. And does executive director serve at the pleasure of
21 the board in Charles County?
22 A. Yes, sir.
23 Q. Seven board members. When you were there, do you know
24 the racial composition of the board members?
25 A. We had I think three African Americans -- or four
83
1 African Americans and three -- I'm -- it was three and four, I
2 think.
3 Q. Okay. You don't recall which way, but it was three
4 African Americans and four whites or vice versa?
5 A. Yes, sir. I believe Charles, Carolyn -- I think it was
6 three African Americans and four white.
7 Q. Okay. In your time in Charleston County or even in
8 Pickens County, did you ever have occasion to become aware of
9 voter impersonation?
10 A. During the 2008 elections, we were very busy processing
11 about a thousand absentees a day during that last two week
12 period. So, I was out helping our staff with that, and I had
13 a young lady actually walk up to me and just say --
14 MS. MEZA: Objection, this is hearsay.
15 HON. COLLEEN KOLLAR-KOTELLY: It is hearsay.
16 BY MR. BOWERS:
17 Q. Without revealing -- let he frame it this way. Without
18 revealing what some third party told you, can you describe
19 what you witnessed without describing the third party's
20 discussion?
21 A. I don't know how I can do that without saying what I
22 was told.
23 Q. Let me ask it another way. Do you believe that voter
24 impersonation fraud was at least attempted in Charleston
25 County?
84
1 A. From what I was told, yes, sir.
2 MS. MEZA: Objection. No foundation.
3 HON. COLLEEN KOLLAR-KOTELLY: I will sustain the
4 objection.
5 MS. MEZA: I'd like to move to strike as well.
6 HON. COLLEEN KOLLAR-KOTELLY: I will strike it.
7 MR. BOWERS: Very well.
8 BY MR. BOWERS:
9 Q. Let's talk about, again, your time in Charleston County
10 with the board. Did you ever have occasion to attend
11 challenged ballot hearings?
12 A. Yes, sir. It was my responsibility to provide all the
13 information for the board during those hearings.
14 HON. COLLEEN KOLLAR-KOTELLY: Can I just ask what
15 time period you're talking about?
16 THE WITNESS: I was in Charleston from April of '05
17 until January of 2011.
18 HON. COLLEEN KOLLAR-KOTELLY: So, it would have
19 been during that time period that you would be attending these
20 board hearings?
21 THE WITNESS: Yes, ma'am, but I also did the same
22 thing in Pickens County before that.
23 HON. COLLEEN KOLLAR-KOTELLY: Okay. Go ahead.
24 BY MR. BOWERS:
25 Q. In your experience in both counties, in Pickens and
85
1 Charleston, did you have occasion to see the way that the
2 boards would handle these challenges?
3 A. The boards always tried to err on the side of the
4 voter. If there was any doubt about which way they should
5 rule, they would typically err on the side of the voter and
6 count the ballot.
7 Q. You mentioned -- I want to go back to SCARE again. You
8 mentioned some legislative efforts that you were a part of, do
9 you recall that?
10 A. Yes, sir. After I was no long president, the next
11 president actually appointed me as the chair of the
12 legislative committee, which I had served on that committee
13 previously, but I was appointed as chair. So then it became
14 more my responsibility to track any legislation that pertained
15 to elections and to monitor that.
16 Q. In 2009 did SCARE have any legislative priorities?
17 A. We had legislative priorities every year. Yes, sir.
18 Q. In 2009 do you recall what the priorities were?
19 A. Not specifically. I remember that early voting was our
20 number one priority, and things like removing the witness
21 signature from the back of an absentee ballot, a lot of
22 clean-up issues.
23 Q. Why was early voting a priority?
24 A. We saw that after the 2008 elections, and we had such
25 massive numbers of people coming into our offices to vote,
86
1 they were coming in saying they wanted to vote early. They
2 were hearing from our neighboring states that they had early
3 voting, so they assumed that South Carolina had early voting.
4 When we had to explain to them that South
5 Carolina didn't have early voting, you had to qualify under
6 1 of 17 reasons to vote absentee, some of them were surprised.
7 So, we saw the voters and we felt like they spoke that they
8 wanted early voting.
9 Q. Did SCARE take a legislative position with regard to
10 photo ID?
11 A. Our only position on photo ID was -- at the time the
12 legislation was requiring the photo ID to be a photo on your
13 voter registration card. It was not referring to any other
14 form of photo ID. And after registration by mail and motor
15 voter with more people registering at the DMVs, we very seldom
16 saw people who registered to vote. We never saw them walk
17 into our office. So, we saw that as a hinderance if every
18 voter that registered had to come into our office for us to
19 put their photo on a voter registration card.
20 Q. Did you see any other issues with the photo ID
21 requirement?
22 A. No, sir.
23 Q. Fair enough. In 2010 you were in Charleston County,
24 correct?
25 A. Yes, sir.
87
1 Q. Tell us any experiences you had with voters and their
2 efforts to vote and their reaction to the lack of a photo ID
3 requirement?
4 A. As I said, I was -- during the large number of
5 absentees, many times I would go out into the front office and
6 help the staff. And during the 2010 elections, in that
7 position, lots of times or most of the time people would walk
8 up and actually hand me and other staff members their driver's
9 license as well as their voter registration card. And when we
10 would say, we only need one form of ID, or something like
11 that, they had heard so many in the news about photo ID, they
12 thought they were required to provide that ID. So, they came
13 prepared to do that.
14 Q. Okay. Even though it wasn't required, obviously,
15 in 2010?
16 A. Right.
17 Q. Ms. Bowers, do you have an opinion with regard to --
18 let me ask you this way. Are you familiar with R54?
19 A. Yes, sir.
20 Q. Do you have an opinion with regard to the reasonable
21 impediment procedures in terms of whether county election
22 officials have discretion?
23 MS. MEZA: Objection. There's no foundation.
24 HON. COLLEEN KOLLAR-KOTELLY: You need to use the
25 hand-held --
88
1 MR. BEENEY: The intervenors offer another grounds
2 for the objection, which is at the deposition of Ms. Bowers,
3 Mr. Bowers made it clear that she was speaking only in her
4 individual capacity. And, therefore, her view is not relevant
5 to anything before the Court. That's on Page --
6 HON. COLLEEN KOLLAR-KOTELLY: Speak on behalf of
7 all -- are you asking for her personal opinion?
8 MR. BOWERS: Yes, Your Honor. I'm asking for her
9 personal opinion. And to clarify, I think -- from her
10 deposition I was stating that she wasn't speaking on behalf of
11 the State Election Commission, she was speaking individually
12 in her individual capacity.
13 HON. COLLEEN KOLLAR-KOTELLY: Well, okay. But then
14 you've asked her an opinion, it sounded like, and had her
15 opining about all of them --
16 MR. BOWERS: That's right.
17 HON. COLLEEN KOLLAR-KOTELLY: -- and she's not in a
18 position to do that, at least -- you know, I don't have the
19 deposition in front of me, so I'm not sure -- if you said she
20 could give her -- leaving aside the foundation issue -- she's
21 going to give an opinion for herself as opposed to speaking
22 for, it sounded like the county.
23 MR. BOWERS: Correct. It will be her own personal
24 opinion.
25 HON. JOHN D. BATES: Personal opinion as a county
89
1 commissioner?
2 MR. BOWERS: Well, she's no longer -- based on her
3 experiences as a county commissioner, but she's no longer a
4 county commissioner. She's currently a --
5 HON. JOHN D. BATES: She's a state -- her opinion
6 as a State Election Commission commissioner?
7 HON. COLLEEN KOLLAR-KOTELLY: That's not what he
8 asked.
9 HON. JOHN D. BATES: That's what her position is?
10 Isn't that what her current position is?
11 MR. BOWERS: She's currently a commissioner on
12 the --
13 HON. JOHN D. BATES: When you asked for her
14 opinion, you're asking it in her capacity as a commissioner of
15 the State Election Commission?
16 MR. BOWERS: Respectfully, no, Your Honor. Even
17 though she calls that position, it's her personal position.
18 HON. JOHN D. BATES: Just like a citizen?
19 MR. BOWERS: Yes, sir. Based on her experiences at
20 the county level for almost 30 years.
21 HON. COLLEEN KOLLAR-KOTELLY: She also hasn't
22 discussed anything about her familiarity with reasonable
23 impediment, she hasn't said anything about that. So, you're
24 asking her to give an opinion without establishing that she
25 had anything to do with it.
90
1 MR. BOWERS: Your Honor --
2 HON. COLLEEN KOLLAR-KOTELLY: So, there's that
3 problem and -- so, the foundation is certainly a problem for
4 you. It also -- it sounds like you're asking her -- based on
5 her experience back as a county official to give an opinion.
6 Was she personally, at this point in time, about the statute,
7 if she had been on the county? I'm not sure I understand what
8 opinion you're asking. In what capacity?
9 MR. BOWERS: In her own personal individual
10 capacity based on her --
11 HON. COLLEEN KOLLAR-KOTELLY: Based on what? Just
12 as a plain --
13 MR. BOWERS: As a voter and citizen and in her --
14 yes.
15 HON. COLLEEN KOLLAR-KOTELLY: Well, if she's a
16 voter and citizen, then you have to ask a lot more about her
17 foundation as to the reasonable impediment. If you're not
18 asking her in any of other official positions.
19 MR. BOWERS: And based on her experience as the
20 legislative committee chair.
21 HON. COLLEEN KOLLAR-KOTELLY: Then you're moving to
22 another -- then she's just not a voter. We're trying to
23 figure out -- in what capacity are you asking for the opinion?
24 It sounded like, at least the question I had, which is back
25 some place, I had is -- relating to when she was speaking for
91
1 a county official.
2 MR. BOWERS: Correct.
3 HON. COLLEEN KOLLAR-KOTELLY: So, but if she
4 couldn't speak as the county official speaking on behalf of
5 them, the county commissioners, you're asking her her opinion
6 as if she had been a county commissioner.
7 MR. BOWERS: I apologize for the lack of clarity.
8 HON. COLLEEN KOLLAR-KOTELLY: Instead of asking for
9 her opinion, I think we've got too many problems here. I'll
10 sustain the objection and you'll have to figure out another
11 way to get this in.
12 MR. BOWERS: Thank you, Your Honor.
13 BY MR. BOWERS:
14 Q. Ms. Bowers, let's go back to your role in SCARE.
15 Remind the Court again, you were president during what time
16 period?
17 A. '04 through '06.
18 Q. And I think you testified to your position with
19 legislative committee?
20 A. I was on the legislative committee prior to that, and
21 then after my presidency ended I was appointed as chair of the
22 legislative committee.
23 Q. Tell the Court, if you would, please, Ms. Bowers, about
24 your activities post-presidency with the legislative
25 committee?
92
1 A. I followed any legislation that pertained to elections
2 very closely. That was something that I was very interested
3 in. As the legislative committee, we were the ones that
4 provided the recommended priorities to the full group. And
5 then our responsibility was to go to the State House and sit
6 in on judiciary subcommittee meetings, full judiciary
7 meetings. Even at times testify and provide information to
8 the legislators as to why we thought certain parts of the
9 legislation would adversely affect voters. It was good, bad,
10 and tried to guide them in creating a good piece of
11 legislation that would be to the benefit of the voters.
12 Q. And did you in fact personally attend any of these
13 subcommittee meetings?
14 A. Many times.
15 Q. With regard to what is now R54?
16 A. Yes, sir.
17 Q. Did you ever testify?
18 A. Yes, sir.
19 Q. Do you recall how many times?
20 A. Not an exact number, but quite a few.
21 Q. And in what capacity, if any, were you providing
22 testimony?
23 A. Typically as the chair of the legislative committee.
24 Q. And that's the legislative committee of --
25 A. -- of SCARE.
93
1 Q. Okay. And were you presenting the views of SCARE based
2 on experiences of the body?
3 A. Yes. And speaking with other members from other
4 counties.
5 Q. Okay. And did you have an occasion to review various
6 pieces of legislation with regard to photo ID?
7 A. Yes, sir, I did.
8 Q. During this time -- okay. And in telling -- tell us
9 about -- are you familiar with what is now R54?
10 A. Yes, sir.
11 Q. Can you tell us what you think the requirements are of
12 R54?
13 A. A voter must provide a photo ID, and it lists, I
14 believe, a driver's license, passport, various kinds of photo
15 ID other than just -- and it does allow for a photo on their
16 voter registration card, but that's not the only form. So,
17 that's why we could support that.
18 It also allows them -- if a person does not have
19 a way to obtain a photo ID, then they have a way to sign a
20 waiver. We also -- they put the option in for them to
21 actually get free transportation to the DMV to obtain a free
22 photo ID from the South Carolina Department of Motor Vehicles.
23 That is a provision in the legislation.
24 HON. JOHN D. BATES: Could I ask your indulgence
25 for one second.
94
1 MR. BOWERS: Of course.
2 HON. JOHN D. BATES: Let me just give my view.
3 This witness is one of the commissioners of the State Election
4 Commission, correct?
5 MR. BOWERS: Yes, sir.
6 HON. JOHN D. BATES: We've heard the opinions of
7 the executive director of the State Election Commission as to
8 what reasonable impediment means. Why should we be precluded
9 from hearing the opinions of one of the commissioners of the
10 State Election Commission as to what reasonable impediment is?
11 HON. COLLEEN KOLLAR-KOTELLY: As opposed to the
12 county, which is what you seem to be asking her to do.
13 MR. BOWERS: Are you asking me why?
14 HON. JOHN D. BATES: Counsel. They made an
15 objection. But if her opinion is asked in her capacity as a
16 commissioner of the State Election Commission, why shouldn't
17 we hear it? We heard the opinions of the executive director
18 of that Commission. Why shouldn't we hear from one of the
19 commissioners?
20 MR. BEENEY: Judge Bates, the basis of our
21 objection on behalf of intervenors is that we were told at the
22 July 19th deposition of Ms. Bowers, the following by Mr.
23 Bowers. The witness -- and I'm reading from Page 104 of the
24 deposition at Line 23.
25 The witness is here only on her own personal
95
1 behalf, and she's not speaking on behalf of the Commission or
2 any other commissioners.
3 Now, that was the basis on which we took the
4 deposition.
5 HON. JOHN D. BATES: Was that her personal behalf
6 as a commissioner -- barely within that?
7 MR. BEENEY: No. In fact, Mr. Bowers went on to
8 say, and not on behalf of the Commission.
9 MR. BOWERS: He's right. I don't dispute what he
10 says. So, I'll withdraw the questions with regard to that.
11 Because as Your Honor has correctly noted, Ms. Andino has
12 already testified to that. And Mr. Beeney is correct, during
13 her deposition she was not testifying on behalf of the
14 Commission.
15 HON. JOHN D. BATES: Or even as an individual
16 commissioner. Go ahead.
17 MR. BOWERS: Correct. Right.
18 BY MR. BOWERS:
19 Q. Let's go back to the -- we'll go back to the
20 legislative committee for just a second. Did you ever speak
21 to legislators?
22 A. Yes, sir.
23 Q. Or communicate with them otherwise?
24 A. Yes, sir.
25 Q. Tell the Court about that, please.
96
1 A. When you went to the subcommittee meetings, we had to
2 opportunity to actually sign up and address them pertaining to
3 the piece of legislation that they were addressing on that
4 day. I did that many times, as well as occasionally I would
5 sent e-mails to the members of election law subcommittee, or
6 on the Senate side, the committee that was reviewing
7 particular legislation.
8 Q. And did you ever talk to -- communicate with
9 legislators regarding the photo ID requirement?
10 A. Yes, sir.
11 Q. And describe those communications?
12 A. Mainly, we were pointing out that --
13 MS. MEZA: Objection. This is hearsay.
14 MR. BOWERS: I'm asking what she told legislators,
15 not the -- I don't want to know what the legislators told you.
16 What did you tell the legislators?
17 HON. COLLEEN KOLLAR-KOTELLY: There are still some
18 issues, but I will --
19 HON. JOHN D. BATES: If it's what she told them,
20 it's not --
21 HON. COLLEEN KOLLAR-KOTELLY: I don't have a
22 problem with it. Go ahead.
23 BY MR. BOWERS:
24 Q. What did you tell legislators on behalf of the SCARE?
25 A. We were encouraging them to allow various forms of
97
1 photo ID to make it's easier. Things other than just a
2 driver's license and a photo ID issued by the Highway
3 Department, like a passport, military ID, things like that.
4 We were just trying to make recommendations that we felt would
5 make it easier for the voters.
6 Q. Ms. Bowers, when you were in your capacity as a
7 director of elections in either Pickens or Charleston, did you
8 ever receive a report of voter fraud? Not what anybody told
9 you. Did you ever receive a report?
10 A. The main one we did in Pickens County was -- we had an
11 instance where --
12 MS. MEZA: Objection. Calls for hearsay.
13 HON. COLLEEN KOLLAR-KOTELLY: Well, is this a full
14 report that was investigated?
15 THE WITNESS: Yes, ma'am.
16 HON. COLLEEN KOLLAR-KOTELLY: All right. Then I'll
17 allow it in that respect.
18 THE WITNESS: We had actual evidence presented to
19 us that a candidate had given $20 gift certificates to voters.
20 And we had a copy -- an actual piece of the $20 gift
21 certificate. And we presented that to our solicitor and
22 didn't get any kind of charge brought.
23 BY MR. BOWERS:
24 Q. Pardon the interruption. Just for the Court's
25 awareness. What is a solicitor in South Carolina?
98
1 A. The solicitor would be the person that would decide
2 whether or not to actually bring charges against this person.
3 Q. The prosecutor?
4 A. Prosecutor. Yes, sir.
5 Q. Pardon the interruption. Continue.
6 A. Then in Charleston County we had a case where, if you
7 had voted or requested an absentee ballot, it was placed
8 beside your name on the voter registration list, ABS. That
9 told the poll manager that you had at least requested an
10 absentee ballot.
11 A voter showed up at a polling place and his name
12 was marked ABS. So, the poll manager allowed this young man
13 to vote a provisional ballot. Of course, we count the
14 absentee ballots on the day of the election. So, his ballot
15 was counted. His absentee ballot was counted. During the
16 process of our staff reviewing the provisional ballots, we
17 discovered that this young man had also cast a provisional
18 ballot.
19 So, we went back to verify. Did he actually
20 return his absentee ballot and has it been counted. It had.
21 So, I presented that to the board during our provisional
22 ballot hearing, and we did not count his provisional ballot
23 based on the fact that he had already voted an absentee
24 ballot.
25 We submitted this information to the solicitor
99
1 there in Charleston, and was again unsuccessful in receiving
2 any kind of indictment, based on the fact that they said this
3 voter did not vote twice because we didn't count the second
4 ballot. It didn't prevent the fact that he had actually voted
5 two times. We just didn't count the second ballot because we
6 caught it.
7 Q. Okay. Any other reports in your official capacity
8 during your time in Pickens or Charleston?
9 A. Other than we also had, in Charleston County, people
10 giving out turkeys for people to go vote, that situation.
11 Again, that went nowhere. Again, it's very hard to get any
12 kind of indictment.
13 MR. BOWERS: Beg the Court's indulgence just for
14 one moment. Thank you, Ms. Bowers. I don't have any further
15 questions. Please answer any questions that the intervenors
16 or the Department of Justice has for you.
17 THE WITNESS: Thank you.
18 HON. COLLEEN KOLLAR-KOTELLY: All right. The
19 Department of Justice.
20 EXAMINATION
21 BY MS. MEZA:
22 Q. Good morning. Catherine Meza for the United States.
23 Good morning, Ms. Bowers, how are you?
24 A. Good morning.
25 Q. Ms. Bowers, the State Election Commission provides for
100
1 guidelines and standards to county boards to promote
2 uniformity, correct?
3 A. Yes, ma'am.
4 Q. However, counties do have discretion over how to
5 implement certain procedures and policies?
6 A. They have the discretion on policies and procedures as
7 long as it does not conflict with law.
8 Q. And has the State Election Commission ever asked you to
9 violate state law?
10 A. No, ma'am.
11 Q. I'd like to ask you a few questions about SCARE. Are
12 representatives from all 46 counties involved in SCARE?
13 A. Yes, ma'am. We had at least one member from every
14 county in the state.
15 Q. And you've been a member of SCARE since you started
16 your career in South Carolina elections?
17 A. I actually became a member in 1981 when I went on the
18 board.
19 Q. And you testified that you served as president of the
20 association?
21 A. Yes, ma'am.
22 Q. And you were also chair of the legislative committee
23 from 2004 to 2010, is that correct?
24 A. I was chair of the legislative committee after my
25 presidency ended in '06 through '11.
101
1 Q. And one of the purposes of SCARE is to give state
2 election officials a forum to discuss and recommend
3 improvements to registration and election laws, is that
4 correct?
5 A. Yes, ma'am.
6 Q. And another purpose of SCARE is to promote legislation
7 that improves the efficiency of the election and registration
8 process in South Carolina, is that correct?
9 A. Yes, ma'am.
10 Q. And you and members of the SCARE -- let me first back
11 up. During questioning from Mr. Bowers you indicated that you
12 provided testimony during the consideration of H.3003, that
13 was the photo voter ID law or bill introduced during the 2011
14 and 2012 legislative session. Was that the bill you provided
15 testimony on?
16 A. No, ma'am. I had retired at that time. So I had
17 testified on the legislation during the two previous sessions.
18 Q. The previous bill or 3418, correct?
19 A. Yes, ma'am.
20 Q. So, you and members of SCARE with actively involved
21 during the consideration of the 3418?
22 A. Very involved during 3418. Yes, ma'am.
23 Q. And what was SCARE's position on early voting?
24 A. We -- it was our number one priority, favoring it.
25 Q. So, as local elections officials, SCARE had identified
102
1 a need for early voting and made it a priority -- a
2 legislative priority, correct?
3 A. Yes, ma'am. As I stated, we based that on the large,
4 very large number of voters that came out during the 2008
5 elections, assuming that South Carolina had early voting and
6 were surprised when they had to qualify under 1 of the 17
7 reasons for absentee voting that we have.
8 Q. And you would agree that local elections officials are
9 probably the most knowledgable and in the best position to
10 determine what polling place procedures may need to be changed
11 or improved?
12 A. We are at the grassroots of that and hear what actually
13 then the poll managers even tell us, concerns, needs, of
14 things like that. Yes, ma'am.
15 Q. And SCARE sets forth legislative priorities every year,
16 correct?
17 A. Yes.
18 Q. What are those priorities based on?
19 A. Needs that have been identified through things we've
20 heard from voters, concerns from voters. Things like I
21 mentioned, the witness address on an absentee ballot. That we
22 cannot count an absentee ballot if there's no witness
23 signature, and there's really no way to verify who that
24 witness is. So, we tried to bring to the legislature's
25 attention that that was causing us not to count ballots when
103
1 there really was no justification for it. Just things like
2 that that would generate and we would see the need for
3 Title 7, which is our election code, to be amended.
4 Q. Did SCARE issue legislative priorities in in 2009?
5 A. Yes, ma'am.
6 Q. And at that time you were chair of the legislative
7 committee, correct?
8 A. Yes, ma'am.
9 Q. And none of SCARE legislative priorities for 2009
10 included any measures to combat voter fraud, is that correct?
11 A. Not that I can recollect.
12 Q. And none of the 2009 priorities included any measures
13 to introduce a photo voter ID law, is that correct?
14 A. No, ma'am.
15 Q. SCARE also issued legislative priorities in 2010,
16 correct?
17 A. Yes, ma'am.
18 Q. And you also served as chair of the committee or the
19 legislative committee in 2010?
20 A. Yes, ma'am.
21 Q. Did any of the priorities in 2010 include measures to
22 combat voter fraud?
23 A. Not that I can remember.
24 Q. Did any of the priorities include measures to introduce
25 a photo ID law?
104
1 A. Not in our priorities.
2 Q. During some of your testimony and lobbying efforts for
3 early voting in 2009, you indicated that the location of early
4 voting sites should be left to the discretion of counties,
5 correct?
6 A. Yes, ma'am.
7 Q. Why?
8 A. We felt that the individual counties were more familiar
9 with the layout of their counties, what sites would be more
10 accessible to the voters. Are they on routes such as public
11 transportation, routes that voters would typically travel in
12 their routine trips to the grocery store, to Wal-Mart, making
13 them evenly accessible to the voters, and not allowing the
14 legislators to dictate where these sites are, based on maybe
15 political aspirations.
16 Q. So, considerations like distance and assessability and
17 convenience were important, correct?
18 A. Yes, ma'am.
19 Q. Would you agree that these same considerations are also
20 important in determining whether to supply a voter photo
21 registration card only at the county board office?
22 A. I'm sorry, can you restate that. I didn't --
23 Q. Sure. Would you agree that the same considerations
24 that you think are important in determining early voting sites
25 should also be considered when deciding whether or not a
105
1 county board office would be the only place that would supply
2 photo voter registration cards?
3 A. Yes, ma'am. That's why we were opposed to only -- it
4 being only the voter registration office.
5 Q. You just relayed an incident of attempted double voting
6 where an individual voted in absentee ballot and then
7 attempted to also vote at the polls on election day?
8 A. Yes, ma'am.
9 Q. And you said that they were given a provisional ballot?
10 A. Yes, ma'am.
11 Q. Correct. However, the voter only actually voted once,
12 correct?
13 A. No, ma'am. He actually cast the absentee ballot,
14 returned it to our office, and then actually voted the paper
15 provisional ballot, and it was turned into our office at the
16 end of the election day. So, he actually cast two ballots.
17 Q. But the provisional ballot up until the time that the
18 county board considers whether or not it's a legitimate ballot
19 doesn't count, correct?
20 A. We did not count that ballot. No, ma'am.
21 Q. So, it's not a counted ballot until that determination
22 is made by the county board, correct?
23 A. Correct.
24 Q. So, it was not a cast ballot? It was not?
25 A. He cast the ballot, we just didn't counted it.
106
1 Q. It wasn't a counted ballot, correct?
2 A. Correct.
3 Q. So no crime had actually occurred, correct?
4 A. To my knowledge it's a crime to have cast more than one
5 vote in any election.
6 Q. Well, is it possible that this voter forgot he cast an
7 absentee ballot? Has that occurred in --
8 A. I can't speak for that voter.
9 Q. Go ahead.
10 A. I can't speak for that voter. I guess it's possible.
11 Q. But there was no crime committed. The second ballot
12 didn't count, correct?
13 A. The crime was committed when he voted more than one
14 ballot. We did not count the ballot, but that does not
15 prevent the fact that he voted more than one ballot.
16 HON. JOHN D. BATES: You can use your time as you
17 wish, but that witnesses view on whether it's a crime or not
18 is not going to be that important for me.
19 BY MS. MEZA:
20 Q. Had this voter been successful at casting both ballots,
21 had the procedures you have in place to catch that not worked,
22 would this have been addressed by the photo ID law?
23 A. No, ma'am.
24 Q. And the fact that you actually were able to identify
25 the second ballot, the provisional ballot, indicates that the
107
1 procedures you have in place -- or counties have in place now
2 are effective?
3 A. Yes, ma'am.
4 Q. And you also just testified previously that it would be
5 a hinderance for a large number of voters to come into the
6 county board office to get a photo voter registration card,
7 correct?
8 A. I don't know that I said it would be a hinderance. Are
9 you saying a hinderance to us or it would be a hinderance for
10 the voter to have to come to our office only? That's what I
11 said. It would be a hinderance to put that burden on the
12 voter to have to come to our office to get a photo ID in lieu
13 of being able to use a photo ID that they possibly already
14 have, such as a driver's license or a military ID or something
15 like that.
16 MS. MEZA: Can I have a moment, please. Thank you,
17 Ms. Bowers. I have no further questions.
18 HON. COLLEEN KOLLAR-KOTELLY: Mr. Beeney, any
19 questions?
20 MR. BEENEY: Thank you, Your Honor.
21 EXAMINATION
22 BY MR. BEENEY:
23 Q. Ms. Bowers, I'm Garrard Beeney and I represent some of
24 the intervenors. I'm going to be very, very brief. I want to
25 direct your attention to your experience in Pickens and
108
1 Charleston County, ma'am. Have you ever known either of those
2 boards to ever intentionally violate state election law?
3 A. No, sir.
4 Q. Do you believe that those county boards would for any
5 reason ever violate intentionally state election law?
6 A. No, sir.
7 Q. Regardless of who asked them?
8 A. No, sir.
9 MR. BEENEY: Thank you, Ms. Bowers.
10 HON. COLLEEN KOLLAR-KOTELLY: Okay. Redirect?
11 MR. BOWERS: Nothing, Your Honor.
12 HON. COLLEEN KOLLAR-KOTELLY: Then she's being
13 excused. You can be excused. Thank you.
14 HON. JOHN D. BATES: You can step down.
15 HON. COLLEEN KOLLAR-KOTELLY: You're excused.
16 MR. BARTOLOMUCCI: The state will call as its
17 witness, M.V. Hood.
18 Thereupon,
19 M. V. HOOD, III, Ph.D.,
20 the witness herein, having been duly sworn, was examined and
21 testified as follows:
22 EXAMINATION
23 BY MR. BARTOLOMUCCI:
24 Q. Professor, could you please state your full name for
25 the record?
109
1 A. My name is M.V. Hood, III. I also go by Trey.
2 Q. What is your occupation, sir?
3 A. I'm an Associate Profession at the University of
4 Georgia.
5 Q. Now, the Court has already accepted your qualifications
6 as an expert for the purpose of allowing you to testify today
7 so I'm not going to go through the long list of questions I
8 might otherwise ask. But I will ask a few questions to
9 introduce you to this Court.
10 How long have you been at that University of
11 Georgia?
12 A. I've been at the University of Georgia since the fall
13 of 1999.
14 Q. And are you a tenured professor?
15 A. Yes.
16 Q. Is your CV in the record in this case attached to your
17 expert report?
18 A. Yes.
19 Q. What postgraduate agrees do you hold?
20 A. I hold three degrees in political science.
21 Q. Tell us about those degrees?
22 A. Okay. A BS from Texas A & M. University, and MA from
23 Baylor University, and a Ph.D from Texas Tech University.
24 Q. Have you published articles in peer review journals?
25 A. Yes.
110
1 Q. Do you know approximately how many?
2 A. I think approximately 28.
3 Q. Now, as a professor of political science, what are your
4 areas of scholarly interest and expertise?
5 A. My areas of the interest and expertise specifically are
6 southern politics and issues related to election
7 administration. I guess that's -- specifically within the
8 broader area of American politics and policy.
9 Q. As a professor of political science, have you performed
10 any research regarding state laws on voter ID?
11 A. Yes.
12 Q. Likewise, as a professor, have you performed any
13 research on the voter turn-out of minority voters in the
14 American south in recent elections?
15 A. Yes.
16 Q. Are you familiar with South Carolina's Act R54?
17 A. Yes.
18 Q. What is Act R54?
19 A. It's an Act that was passed by the legislature, but has
20 not been precleared for implementation, that would require
21 South Carolina voters voting in person to present one of five
22 different forms of photographic government-issued --
23 government-issued identification.
24 Q. And what are those several forms of photo ID accepted
25 under R54, if you can tell us?
111
1 A. Yes. A valid and current South Carolina driver's
2 license, a state ID card from the DMV, a passport, military ID
3 or a photographic voter registration card. The fifth form of
4 ID has not been implemented yet.
5 Q. And that's because that provision of the law has not
6 been precleared, is that your understanding?
7 A. Yes, that's my understanding.
8 Q. Does R54 contain any fail-safe provisions for voters
9 who lack an ID?
10 A. Yes. There are a couple of provisions in the law that
11 will be enacted if the law is precleared. There's a
12 reasonable impediment clause and a religious exception clause
13 that are included. And, also, someone may have an ID but
14 might not have it in their possession at the polls. They can
15 go ahead and cast a provisional ballot and then show a valid
16 ID at a later point in time and have their ballot counted.
17 Q. What is your understanding of the reasonable impediment
18 and religious objection provisions?
19 A. Well, my understanding of the reasonable impediment
20 clause would be anything beyond a voter's control that did not
21 allow them to obtain a photo ID. And in that case, they can
22 sign an affidavit stating the reason and go ahead and cast a
23 provisional ballot. If the voter signed an affidavit, it's my
24 understanding that the burden of proof would shift to the
25 election board, and that that ballot would be counted unless
112
1 proof could be brought to bear that the person that cast the
2 ballot wasn't that person.
3 And the religious exception clause. My
4 understanding of that is anyone that may have -- because of
5 religious reasons can't be photographed, can sign a similar
6 affidavit and go through a similar process.
7 Q. Now, you've been retained by the State of South
8 Carolina as an expert witness in this case, is that correct?
9 A. That's correct.
10 Q. And, generally speaking, what were you asked to do?
11 A. Well, my number one task I was asked to undertake was
12 to try to figure out how many South Carolina registrants might
13 not be in possession currently of an R54 ID. And that
14 included -- eventually I received data on up to four of those
15 five forms of ID. I was also asked to do some things like
16 make a comparison between Act R54 as it would be implemented
17 in Georgia's current voter ID law.
18 Q. In this case did you have the occasion to examine a
19 database received from the South Carolina State Election
20 Commission?
21 A. Yes, I did.
22 Q. And can you tell us about how you came to examine that
23 database?
24 A. That was a voter registration file I received from the
25 State Election Commission and it should list all voters that
113
1 are currently classified as active or inactive in the state.
2 Q. And for what purpose did you examine that election
3 commission database?
4 A. Well, I needed that database, but I also needed data
5 from other sources, again, to try to ascertain who in the
6 voter registration database did or did not have a current Act
7 R54 ID. So, I needed other pieces of data as well to make
8 that determination.
9 Q. I'll ask you about the other databases, but I want to
10 stay with the election commission database for now. Can you
11 generally describe the contents of that election commission
12 database that you received?
13 A. There are a number of important fields in the database.
14 One of the most important would be the full social security
15 number of the registrants in the database. Also, full name,
16 date of birth, physical address, and also information on the
17 race and ethnicity of these registrants as recorded in the
18 database.
19 Q. And what was the -- to your understanding, what was the
20 date of the data in that database?
21 A. The date when the database was created?
22 Q. Yes, sir.
23 A. That I received? April 20th was my understanding,
24 of 2012.
25 Q. And when roughly did you first examine that database?
114
1 A. It would have been some time after that. Late May.
2 Q. Did the election commission database include any fields
3 or data relating to the income of the registrants on the
4 database?
5 A. No, sir.
6 Q. Did the election commission database contain any
7 information or fields regarding the socioeconomic standing of
8 the particular registrants in the database?
9 A. No, sir. There was no data in that database on income
10 level of registrants or, excuse me, education level,
11 occupation, anything like that.
12 Q. And is it your understanding that the election
13 commission database that you received and examined was the
14 election commission's entire voter registration roll current
15 as of the date of the database?
16 A. It was my understanding that should be the universe of
17 registrants in South Carolina as of April 20th, 2012.
18 Q. Did the election commission database categorize certain
19 registrants as having an active or inactive status?
20 A. Yes, they did.
21 Q. Can you tell us about that?
22 A. There were a couple of status in the database, one
23 active and two inactive. And, clearly, within the -- I did
24 make use of some inactive categories for my analysis in
25 addition to the entire set of active registrants. Some
115
1 categories of inactive registrants clearly were not qualified
2 or could not cast a ballot, so did I not make use of all the
3 inactive categories.
4 Q. Now, after you received the database, you had one or
5 more discussions with people at the election commission
6 regarding the database, is that correct?
7 A. I had an interview with Brian Leach at the State
8 Election Commission.
9 Q. And based on that conversation did you develop an
10 understanding of what the active and inactive categories in
11 the database meant?
12 A. Well, you know, based on that interview -- everyone in
13 the active category should certainly be included in any
14 analysis. All of these individuals are registered. If their
15 registration status is up-to-date they should be able to turn
16 out to vote. Again, through this interview I also learned
17 that there were a couple of categories of inactive registrants
18 who would most likely be able to -- even though they were
19 inactive -- should be able to turn out to vote a
20 non-provisional ballot. Two categories in particular, using
21 the South Carolina nomenclature IM and IF.
22 These were voters that may have been identified
23 as having moved within a county, so they were transferred to
24 the inactive status. Or voters that may have been sent a
25 mailing, that's IF, failed to respond. They may have been
116
1 sent to mailing and not responded to the mailing. So, it
2 doesn't preclude them from being able to turn out to vote
3 necessarily, though.
4 Q. So, the registrants who were categorized as active,
5 they are registered to vote, correct?
6 A. Yes. All of those are included in my analyses.
7 Q. And the election commission regards them as active and
8 eligible to vote?
9 A. Yes.
10 Q. And the registrants that were categorized by the
11 election commission as inactive in the two categories you
12 described, IM and IF, are in fact registered voters?
13 A. Yes.
14 Q. And they are eligible to vote, as you understand it?
15 A. Yes.
16 Q. And the election commission advised you that in their
17 view these are two categories of inactive registrants most
18 likely to present themselves to vote?
19 A. They certainly could. The most conservative method
20 would be to include everyone that we believed could be
21 eligible to vote and might show up to vote.
22 Q. But you had this conversation with the election
23 commission, and did you discuss whether your analysis should
24 include the active registrants plus these two categories of
25 inactive registrants?
117
1 A. Well, I was convinced through this conversation that I
2 did need to include these two categories of inactive
3 registrants.
4 Q. And that's what you did, sir, right?
5 A. Yes. Throughout my analysis I present usually two
6 different tables. One table would be active registrants only
7 and another table would include active plus these two
8 categories of inactive registrants.
9 Q. We'll get a look at the tables later. So, when you
10 presented your data, you presented some data sets with only
11 the active registrants and then you presented parallel data
12 sets that combined active plus inactive registrants, is that
13 right?
14 A. That's correct.
15 Q. Now, Professor Hood, do you know whether some of the
16 registrants listed in the election commission database were in
17 fact deceased as of the time you received the database?
18 A. I didn't run an analysis to determine whether there
19 were decedents in the registration database.
20 Q. Is it your understanding that there were or may have
21 been?
22 A. Well, you know, usually there are some small number of
23 decedents in any registration database.
24 Q. Generally speaking, how many registrants were on the
25 database?
118
1 A. Active registrants, about 2.7 million.
2 Q. And do you remember, roughly, the figure for active
3 plus the two categories of inactive that you looked at?
4 A. I don't remember exactly, but it was nearing -- it
5 wasn't 2.8, but it was nearing 2.8 million.
6 Q. Now, if you had additional data such as death records
7 that current -- as of the date of the database, could you
8 have, you know, attempted to identify who on the database was
9 actually deceased?
10 A. I could have performed that type of analysis, yes.
11 Q. But is that something that you did in this case?
12 A. I did not do that for this case, no.
13 Q. Could you tell the Court why you didn't perform that
14 function?
15 A. Well, I didn't ask for the data, for one, on decedents.
16 I didn't necessarily view it as being pertinent to the issue
17 at hand.
18 Q. The fact is, Professor, you analyzed the election
19 commission's entire database as it was presented to you?
20 A. Yes. I think maybe we can think of it as a snapshot in
21 time. So, to our best knowledge that was the entire universe
22 of registrants on that date. And, of course, the registration
23 database can change -- could change daily, conceivably.
24 Q. Now, I understand that you didn't undertake any
25 analysis of whether some of the registrants on the list were
119
1 deceased, but drawing upon your expertise in the area of the
2 political science, would you have any reason to believe that
3 accounting for deceased registrants and setting them aside in
4 your analysis would affect your the rate calculations that you
5 were subsequently to make?
6 A. I don't think it would affect the calculations to any
7 great degree. At any given point in time there shouldn't be
8 that many decedents in the registration database.
9 Q. But to be clear, you didn't perform that function?
10 A. No, I did not.
11 Q. But your testimony is that doesn't trouble you in terms
12 of analyzing the database?
13 A. Correct.
14 Q. Let's talk about the Department of Motor Vehicle
15 database. And did you receive a database from the Department
16 of Motor Vehicles?
17 A. Yes.
18 Q. And, generally speaking, what were the contents of that
19 database?
20 A. There were quite a few files in that database related
21 to license holding.
22 Q. What sorts of pertinent fields were contained within
23 the DMV database?
24 A. Well, let me, I guess, clarify and say I made use of
25 three of the tables in the DMV -- South Carolina DMV database.
120
1 And within those three tables, some critical pieces of
2 information I needed to complete my analyses were the social
3 security number -- a full social security number of South
4 Carolinians who had a driver's license or state ID card.
5 Also, again, full name, date of birth. Those were the primary
6 data fields I needed from that database.
7 Q. And I believe you testified, your objective here, at
8 least part of it, was to see whether you could determine that
9 someone on the election commission database was listed as on
10 the DMV database, is that right?
11 A. That's correct. I'm trying to figure out who in the
12 voter registration file has a current and valid -- either a
13 state driver's license or state ID card.
14 Q. Did the DMV database indicate which licenses were
15 expired or not expired?
16 A. Yes. There was a date of expiration field I was able
17 to make use of in that license table.
18 Q. And your understanding is that Act R54 requires a
19 current and valid photo ID in order to vote, is that right?
20 A. That's correct. I used the expiration date field to
21 determine or to make a determination of whether a license or
22 state ID card was expired or unexpired.
23 Q. If a driver's license was indicated as expired on the
24 DMV database, even if you could match that record with someone
25 on the election commission database, you would not have
121
1 counted that person as having an Act R54-type of ID, is that
2 correct?
3 A. That's correct. That's correct. I set the expiration
4 date to be, again, April 20th.
5 Q. And did the Department of Motor Vehicle databases also
6 tell you which licenses were regarded as valid by the
7 Department of Motor Vehicles?
8 A. There was another field in the table that indicated
9 whether a license or state ID card was valid or not, so I made
10 use of that field as well.
11 Q. Now, I think you testified that both the election
12 commission database and the DMV database contained social
13 security number fields?
14 A. That's correct.
15 Q. Was that a method that you used to match up registrants
16 on the election commission database and driver's licenses on
17 the DMV database?
18 A. That was one of the matching methods I used, yes.
19 Q. And what was your methodology for performing that
20 match?
21 A. I need to back up a little bit and clarify some things.
22 So, I had the license holder table from the South Carolina DMV
23 database. All these files came with a data map, which
24 outlined how all the tables -- what the tables were, what
25 variables were in the tables, how these tables were
122
1 interconnected with one another.
2 I studied the data map and wrote out a protocol
3 for how I would extract valid and current license holders from
4 this data set. I conducted an interview with a Department of
5 Motor Vehicle data technician and explained my methodology,
6 and he confirmed that this would be the proper way to extract
7 valid and current, either driver's license or state ID cards,
8 from the DMV database. And I proceeded to do that.
9 So I created essentially a new table from the
10 South Carolina DMV database that contained a list of all valid
11 and current, either license holders or state ID holders.
12 Q. So --
13 A. That table contained social security numbers along with
14 other facts, such as name and date of birth, for instance.
15 Q. So, as in the case of the election commission database,
16 you had a conversation or conversations with DMV officials to
17 understand the data and what you had and how best to perform
18 your matching analysis, is that right?
19 A. Not really a matching analysis itself, but the --
20 confirming my methodology for creating a list of everyone in
21 the DMV database that had a valid and current license or state
22 ID card.
23 Q. And so you were able to perform matching, based in part
24 on social security numbers, can you tell us more about that?
25 A. At that point it's fairly straightforward using a
123
1 database program to link the table I had created from the DMV
2 files, which would again be all valid and current licenses or
3 state ID holders, to connect the social security field in that
4 table to the social security field back in the voter
5 registration database.
6 And I ran a match query and I added information
7 to the voter registration database. I added a field in the
8 voter registration database to indicate whether someone had a
9 valid and current state ID or driver license.
10 Q. Now, were there certain registrants on the election
11 commission database who you couldn't match by social security
12 number, but you were nonetheless able to match by other means?
13 A. There were some registrants who either had nothing in
14 their social security field, so it was blank, or had what I
15 will term invalid social security number. You know, for
16 instance, nine 0s or nine 1s or nine 9s. And so in that case
17 I went through and did some cleaning and eliminated those
18 invalid social security numbers. So, again, that would just
19 mean there was a blank there, they don't have a social
20 security number.
21 So, obviously if they have -- if they didn't have
22 a social security number listed or it was invalid and I
23 cleaned it, it's impossible obviously to match that back to
24 the DMV file in that field. You only have half of the
25 equation there. So, for those individuals -- actually, for
124
1 everyone, but to try to match those individuals that didn't
2 have a valid social security number, where it was missing, I
3 conducted a second match where I used first name, last name
4 and date of birth between the two registration databases to
5 try to match individuals in those cases.
6 Q. And did that result in additional matching?
7 A. There were additional matches. Yes.
8 Q. And so when you were assessing your output, you
9 would -- did you regard someone as having an R54 ID if you
10 could match them based upon either social security number or
11 name and address?
12 A. Either social security number or name and date of
13 birth.
14 Q. Name and date of birth. Thank you for that --
15 A. I'm not double counting people. So one way or the
16 other.
17 Q. Okay. So the only made it on to the list of folks who
18 had an ID once?
19 A. Right. Right.
20 Q. Whether or not you could match them up --
21 A. Right. Whether I could match them using both methods
22 or not. If they matched using at least one method, they were
23 considered to have a valid and current either driver's license
24 or state ID card.
25 Q. And method one was exact social security number, all
125
1 eight digits, right?
2 A. Yes.
3 Q. And method two is name and date of birth?
4 A. Name and date of birth, yes.
5 Q. Did you insist upon exact similarity of name and date
6 of birth?
7 A. If the first name, last name, and date of birth fields
8 were not exact matches, then a match would not have been
9 produced. So, if it was John Smith and another database said
10 Jonathan Smith, that would not be a match, for instance.
11 Q. Even if they had the exact same date of birth?
12 A. Yes.
13 Q. Now, did the Department of Motor Vehicles' database
14 supply information on driver's licenses that had been returned
15 to the South Carolina Department of Motor Vehicles from out of
16 state?
17 A. There was another table in the database. Again, yes,
18 that database was pretty voluminous. There were a lot of
19 tables. One of them contained that type of information.
20 Q. And, again, the information we're talking about is
21 South Carolina driver's licenses that were sent back to the
22 State of South Carolina DMV from another state?
23 A. That's correct.
24 Q. And why might that occur, if you know?
25 A. Why might that situation occur?
126
1 Q. Yes.
2 A. From my understanding, at least, if someone had moved
3 out of state possibly and gotten a driver's license from the
4 state -- from the state where they moved, they should have to
5 turn in their South Carolina driver's license.
6 Q. Now, if you know, does the fact that someone returns a
7 driver's license from out of state, if they are a registered
8 voter in South Carolina, does that affect their South Carolina
9 voter registration?
10 A. It shouldn't. I mean, they could remain on the South
11 Carolina voter registration roll.
12 Q. So, if I'm a registered South Carolina voter and I have
13 a South Carolina driver's license, and then for whatever
14 reason that driver's license gets mailed back to the SC DMV
15 from out of state, I would remain on the election commission
16 roll, is that right?
17 A. From with what I understand, yes.
18 Q. And, therefore, such a person could still vote in the
19 South Carolina election, all other qualifications being met?
20 A. Yes.
21 Q. And do you know whether such persons in fact do vote in
22 South Carolina elections?
23 A. Apparently they do.
24 Q. What do you base that statement on?
25 A. Another expert's report in this case indicated that
127
1 some of these individuals had voted.
2 Q. In other words --
3 A. Specifically, I believe the rebuttal report of
4 Professor Stewart indicated that some of these individuals had
5 voted in South Carolina at about approximately the same rate
6 as inactive registrants.
7 Q. So, even though their South Carolina driver's license
8 had been returned to SC DMV from out of state?
9 A. Yes.
10 Q. Now, are there forms of identification acceptable under
11 R54 that are not driver's licenses or DMV issued photo ID
12 cards?
13 A. Yes.
14 Q. And what would those be?
15 A. Military IDs, passports and photographic voter
16 registration cards.
17 Q. So, is it your understanding that a South Carolina
18 voter who doesn't have a driver's license or a DMV photo ID
19 card can vote if she possesses a U.S. passport or a U.S.
20 military ID?
21 A. That's my understanding of the law, yes.
22 Q. Did you make an attempt to match any individuals on the
23 election commission database with holders of U.S. passports
24 and military ID?
25 A. Yes.
128
1 Q. And how did you go about doing that?
2 A. I didn't actually perform that match myself, but after
3 I performed the match using the DMV data. So, we should have
4 a good idea at that point of who has a valid and current
5 driver's license or state ID card. Any registrant left in the
6 database who was unmatched by that first match attempt, I was
7 able to send a list with social security numbers of those
8 registrants to the Department of Defense and to the Department
9 of State, and they performed a match on social security
10 numbers as to whether these registrants had a passport or
11 military ID. And then I was sent the data back with an
12 indication of -- these registrants had been matched as having
13 a passport or military ID and these had not.
14 Q. And did you just testify that that DOD and State
15 performed -- the matching function was based on social
16 security number?
17 A. Yes.
18 Q. So, to make sure I have this clear. You matched as
19 many registrants on the election commission database as you
20 could to the DMV database -- to holders of a South Carolina
21 driver's license or a South Carolina issued photo ID card?
22 A. That's correct. Yes.
23 Q. And step two, you made a list of unmatched registrants
24 from the election commission database?
25 A. I took anyone who was unmatched after that point and
129
1 created a list, yes.
2 Q. That list, am I correct, was supplied to the
3 Departments of State and Defense?
4 A. Yes.
5 Q. And that list included social security numbers?
6 A. Yes.
7 Q. Now, were all those social security numbers valid in
8 your parlance or were some invalid?
9 A. Well, again, I did -- I cleaned as many social security
10 entries as I could. I can't say that every one was valid or
11 not at that point.
12 Q. But --
13 A. It's possible that there could have been some invalid
14 numbers there.
15 Q. What I mean, on that list of folks you had not yet been
16 able to match, you had social security numbers, but for some
17 folks you didn't have all eight digits or you had 99999 across
18 the board?
19 A. No, I had cleaned things at that point.
20 Q. You took out those obviously improper social security
21 numbers?
22 A. Yes. I didn't remove the registrant, I think that's an
23 important point, but I removed the -- what I thought was an
24 invalided social security entry.
25 Q. So the list of unmatched registrants with their social
130
1 security numbers was supplied to the Departments of Defense
2 and State, is that correct?
3 A. That's correct.
4 Q. And what did they do?
5 A. They undertook a matching procedure with their
6 databases using social security numbers to determine if these
7 registrants that I had been unable to match, so the unmatched
8 registrant list, if you will, if any of these had a passport
9 or military ID.
10 Q. Now, what did you do with that data, if anything,
11 vis-a-vis the data matches that you had already performed
12 against the DMV database?
13 A. Well, if they had been matched with the DMV database,
14 those weren't cases that were sent to the Department of
15 Defense or the State Department. They had already been
16 matched doing -- they already had been found to have at least
17 one Act R54 ID. So, I was just at that point trying to match
18 registrants who didn't have a driver's license or state ID
19 card.
20 Q. So, am I correct that at the end of this process you
21 had a single list of registrants who had at least one of these
22 four forms of ID, a driver's license, state DMV-issued photo
23 ID card, a passport or a military ID?
24 A. I think we left out a step. Let me just back up real
25 quick. So, eventually I got these lists back from the
131
1 Department of Defense and from the State Department, you know,
2 with their indication of whether these registrants had been
3 matched as having a passport or military ID.
4 So then I was able to take these lists and update
5 my main database, my voter registration database, to include a
6 field for, A, if the registrant was identified as having a
7 passport; and, B, whether they were identified as having a
8 military ID.
9 Q. And do you know how the Departments of State and
10 Defense perform their matching, was it solely based on social
11 security number?
12 A. From what I understand, yes.
13 Q. And do you have an understanding about whether they
14 insisted upon an exact match of numbers?
15 A. For a match to be valid, yes, it would have to -- the
16 social security number would have to exactly match a social
17 security number in one of their databases, yes.
18 Q. Am I correct that State and Defense did not undertake a
19 second step to try to match by name and date of birth or any
20 other method?
21 A. It's my understanding they didn't try to undertake any
22 type of matching analysis.
23 Q. Okay. So, at the end of the day after -- starting with
24 the list of registrants in the election commission database,
25 you were able to analyze which of those folks had a DMV ID, a
132
1 DMV driver's license from South Carolina, a passport or a
2 military ID?
3 A. Yes. I mean, I eventually created an indicater that
4 just denoted whether a registrant had one of those four forms
5 of ID or not. So, yes, eventually I was able to make a
6 determination of how many registrants had a valid and current
7 Act R54 ID, one of the four forms that's currently available,
8 versus those that did not.
9 Q. That's actually an important point. So, you're
10 matching consisted of -- effort consisted of four of the five
11 forms of R54 ID?
12 A. Well, the fifth form is not available. It won't be
13 available unless the law is precleared. That's the
14 photographic voter registration card.
15 Q. So, there's no way to match on that basis because it's
16 not available, is that right?
17 A. Right, it doesn't exist.
18 Q. I've put a demonstrative on the screen. Professor
19 Hood, do you recognize this document?
20 A. Yes.
21 MR. BARTOLOMUCCI: And just for the record I'll
22 note that this table appears in the record at JA001085. I'm
23 advised it's also Plaintiff's Exhibit 140.
24 BY MR. BARTOLOMUCCI:
25 Q. Now, Professor Hood, you said that you recognize this
133
1 document what is it?
2 A. This is a summary table I created. Now, this just
3 includes active registrants. There's another summary table
4 for active plus inactive registrants. Yes. And I did this
5 throughout the analysis. This is a summary table of the
6 number of active registrants who possess these types of
7 identification.
8 Q. And by that you mean the types listed here in the left
9 column?
10 A. Yes, sir.
11 Q. And this figure that I'm now circling, about
12 2.7 million. What does that figure represent?
13 A. That is the total number of active registrants in the
14 South Carolina voter registration database that I received.
15 Q. And this figure that I'm now circling, the
16 95.11 percent, what does that figure reflect?
17 A. By my calculations, 95.11 percent of active registrants
18 in South Carolina possess one of these four forms of Act R54
19 ID.
20 Q. And then doing a little math, what percentage lack,
21 currently, an R54 ID?
22 A. 4.89 percent of active registrants.
23 Q. I'm going to put on another demonstrative, Professor
24 Hood. Do you recognize this document?
25 A. Yes.
134
1 Q. And what is this document?
2 A. It's Table 4 from my supplemental report I produced.
3 MR. BARTOLOMUCCI: And, for the record, this
4 appears at JA001086.
5 BY MR. BARTOLOMUCCI:
6 Q. And how, if at all, does this table differ from the one
7 that we just saw?
8 A. This table is analogous to the previous table except it
9 adds those two categories of inactive registrants that I had
10 discussed previously. So, the total number at the bottom in
11 terms of the number of registrants is now at about
12 2.79 million.
13 Q. So, pretty close to 2.8 million?
14 A. Yes. That would, again, include all active registrants
15 and everyone in these two categories of inactive registrants,
16 IM and IF that I mentioned.
17 Q. Why did you decide to present the data both ways, one
18 table with active only and one table with active plus the two
19 categories of inactive?
20 A. Well, I did this throughout the analysis. I was just
21 trying to be as straightforward and transparent in what I was
22 doing as possible. And I thought about doing this as a
23 progression moving forward of tables, so...
24 Q. And what percentage of registrants on the election
25 commission's database were you able to determine had one of
135
1 the four already available forms of R54 ID?
2 A. 94.66 percent of this registrant set by my calculations
3 have an active and current form of Act R54 ID.
4 Q. And then that means that the percentage who lack such
5 an ID is, am I right, is that 5.34 percent figure?
6 A. That's correct.
7 HON. COLLEEN KOLLAR-KOTELLY: Does this also have a
8 Plaintiff's exhibit number or not?
9 MR. BARTOLOMUCCI: This is the same document, so...
10 HON. COLLEEN KOLLAR-KOTELLY: Okay. It would be
11 the same one.
12 MR. BARTOLOMUCCI: To be clear, both of these
13 tables come out of Professor Hood's supplemental declaration
14 or expert report.
15 HON. COLLEEN KOLLAR-KOTELLY: Thank you.
16 MR. BARTOLOMUCCI: This is a third demonstrative on
17 the screen, it's from the same source, Professor Hood's
18 supplemental report. It's JA001088.
19 BY MR. BARTOLOMUCCI:
20 Q. And, Professor Hood, could you -- do you recognize this
21 document?
22 A. Yes.
23 MR. BEENEY: We have an objection to this document.
24 As we pointed out to counsel before and as Dr. Hood agreed
25 with us in his deposition, the last column --
136
1 HON. COLLEEN KOLLAR-KOTELLY: You need to talk into
2 the microphone, we can't hear you. We're not going to get a
3 record.
4 MR. BEENEY: Our objection to this deposition, as
5 pointed out to counsel and as agreed to by Dr. Hood during his
6 deposition, is that the last column is misleading. The
7 difference is not 1.86 percent or 1.9 percent, it is 1.86
8 percentage points.
9 MR. BARTOLOMUCCI: Your Honors, if I may. This
10 document is already in the record exactly as it appears, and
11 Mr. Beeney is free to question the witness about it in --
12 HON. COLLEEN KOLLAR-KOTELLY: Did you lodge an
13 objection to this material or is this --
14 MR. BEENEY: It was offered as a demonstrative and
15 we objected to it.
16 HON. BRETT M. KAVANAUGH: As long as we understand
17 that.
18 MR. BEENEY: I agree with you, Judge. As long as
19 that point is made and everybody understands that that is not
20 the percentage difference.
21 HON. BRETT M. KAVANAUGH: We get that.
22 HON. COLLEEN KOLLAR-KOTELLY: Okay. Thank you.
23 MR. BEENEY: But that's what the document --
24 HON. BRETT M. KAVANAUGH: I understand it's there.
25 Yeah, I got it. I understand that.
137
1 MR. BARTOLOMUCCI: And, again, just so the record
2 is clear, this chart is in the record in exactly this form in
3 Professor Hood's supplemental report, it has not been altered.
4 BY MR. BARTOLOMUCCI:
5 Q. Professor Hood, can you identify this document?
6 A. Yes. It's Table 5 from my supplemental report.
7 Q. And what does the information on this table reflect?
8 A. This is, again, using just active registrants. And
9 what I'm doing is partitioning active registrants with and
10 without ID by racial and ethnic category -- racial and ethnic
11 category is defined in the voter registration database.
12 Q. So these various categories of race, ethnicity, those
13 are reflected in the election commission database?
14 A. Yes.
15 Q. And this is the analysis of only active registrants, is
16 that right?
17 A. That's correct.
18 Q. And the total number, as before, is about 2.7 million?
19 A. Yes.
20 Q. And what would be the total number of registrants by
21 race on this chart who lack -- who currently lack an available
22 form of R54 ID?
23 A. Well, the total number is 133,800.
24 Q. If you break that down by race, let's do it as white
25 and minority?
138
1 A. Certainly. Can I just clarify what minority includes?
2 Q. Yes, sir.
3 A. So, as denoted by the indentation there, the minority
4 category I created includes Black registrants, Hispanics,
5 Asians and American Indians.
6 Q. And for the categories of non-Hispanic white and
7 minority registrants, what was the total number in those
8 categories that lacked presently a currently available form of
9 R54 ID?
10 A. There were 82,193 non-Hispanic white registrants
11 lacking some form of Act R54 ID, and 50,570 -- it looks like
12 to me.
13 Q. Let me clear that out. I'm channeling my inner John
14 Madden.
15 A. So, 50,570 minority registrants lacking current and
16 valid Act R54 ID.
17 Q. So, this is obvious, but I want it in the record. So,
18 the number of white registrants without R54 ID is greater than
19 the number of minority registrants without R54 ID, is that
20 right?
21 A. Yes.
22 Q. Now, what would be the percentage of white registrants
23 who lack an R54 ID?
24 A. 4.32 percent.
25 Q. And if my math is correct, does that mean that the
139
1 percentage that do have ID is going to be something like
2 95 percent?
3 A. Yes.
4 Q. And what would be the percentage of minority
5 registrants who lack an R54 ID on this chart?
6 A. 6.18 percent.
7 Q. Going back to math, that's about -- that means that
8 about 94 percent of minority registrants do possess an R54 ID?
9 A. Yeah. Just slightly under that. If you round to the
10 closest it would be 96 and 94, right?
11 MR. BARTOLOMUCCI: I think the figures I have, to
12 be more accurate, would be 95.68 percent, so you could
13 certainly round that to 96. And 93.82 percent, which I have
14 rounded to 94.
15 HON. BRETT M. KAVANAUGH: Right. To make sure
16 we're using the same rounding.
17 MR. BARTOLOMUCCI: The numbers certainly speak for
18 themselves.
19 HON. BRETT M. KAVANAUGH: Right.
20 BY MR. BARTOLOMUCCI:
21 Q. So, to avoid Mr. Beeney's objection, Professor Hood,
22 what would be the percentage point difference between the
23 percentage of minorities who lack an R54 ID and the percentage
24 of whites who lack an R54 ID in percentage point terms?
25 A. The difference would be 1.86 percent.
140
1 HON. BRETT M. KAVANAUGH: Points.
2 MR. BEENEY: Points.
3 MR. BARTOLOMUCCI: Okay. Let's go to the next
4 chart.
5 HON. COLLEEN KOLLAR-KOTELLY: I think this is
6 probably -- it's a little after 12:30. Why don't we stop here
7 before you move to another chart. So, we'll see you back
8 at -- make it 1:35, instead of 1:33.
9 LUNCHEON RECESS AT 1:35 P.M.
10
11 C E R T I F I C A T E
12 I, Lisa M. Foradori, RPR, certify that the foregoing
13 is a correct transcript from the record of the proceedings in
14 the above-titled matter.
15
16 Date: 8-29-12 /s/ Lisa M. Foradori, RPR
17
18
19
20
21
22
23
24
25
$
$20 [2] 97/19 97/20
$60 [3] 10/9 10/10 10/13
'
'04 [2] 80/21 91/17
'05 [1] 84/16
'06 [3] 80/21 91/17 100/25
'11 [1] 100/25
/
/s [1] 140/16
0
0257 [1] 1/18
0800 [1] 3/4
0s [1] 123/16
0the [1] 79/11
1
1.86 [1] 136/7
1.86 percent [2] 136/7 139/25
1.9 percent [1] 136/7
10 [5] 43/25 44/5 44/6 49/15 49/15
10004 [1] 2/14
10013 [1] 3/10
104 [1] 94/23
107 [1] 4/10
108 [1] 4/13
11 [1] 49/8
11-member [1] 49/14
11:00 [1] 76/3
11:59 p.m [1] 43/14
12 [2] 10/10 140/16
12 percent [2] 71/11 71/19
12-203 [1] 1/3
12-CV-203 [1] 5/4
125 [1] 2/13
12:30 [1] 140/6
12th [1] 3/9
133,800 [1] 137/23
140 [1] 132/23
1401 [1] 3/13
1428 [1] 2/22
1440 [1] 2/17
14th [1] 13/13
15 [1] 61/25
160 [1] 1/7
161 [1] 3/9
17 [2] 86/6 102/6
178,000 [2] 8/20 57/23
18 [1] 67/12
180,000 [1] 41/13
1863 [1] 2/14
1919 [1] 1/17
1979 [1] 77/12
1981 [2] 77/17 100/17
1985 [2] 77/21 78/6
1999 [1] 109/13
19th [1] 94/22
1:33 [1] 140/8
1:35 [2] 140/8 140/9
1s [1] 123/16
2
2,100 [5] 10/6 21/11 21/12 21/16 46/17
2.7 million [3] 118/1 133/12 137/18
2.79 million [1] 134/12
2.8 [1] 118/5
2.8 million [2] 118/5 134/13
20 [3] 64/24 76/3 78/7
20,000 [3] 10/7 14/23 35/19
20001 [1] 3/18
20002 [1] 3/6
20005 [1] 3/14
20008 [1] 3/3
20036 [1] 1/18
2004 [1] 100/23
2005 [2] 78/6 78/8
2008 [9] 11/9 12/6 12/12 12/17 13/2
71/23 83/10 85/24 102/4
2009 [6] 85/16 85/18 103/4 103/9 103/12
104/3
2010 [8] 42/5 86/23 87/6 87/15 100/23
103/15 103/19 103/21
2011 [7] 12/20 13/3 13/5 78/11 78/17
84/17 101/13
2012 [6] 1/4 38/22 71/12 101/14 113/24
114/17
202 [6] 1/18 2/7 3/4 3/7 3/14 3/18
203 [2] 1/3 5/4
20530 [1] 2/7
20th [2] 113/23 121/4
210 [1] 2/21
212 [1] 2/14
215 [1] 3/6
2200 [1] 3/7
23 [1] 94/24
230 [1] 2/17
24 [1] 44/18
25 [1] 64/24
2721 [1] 2/18
28 [1] 110/2
29 [1] 1/4
292-8327 [1] 3/10
29401 [1] 2/22
29412 [1] 1/20
3
30 [5] 5/11 5/11 62/9 62/15 89/20
301 [1] 77/7
30303 [1] 2/18
3269 [1] 3/18
333 [1] 3/17
3418 [3] 101/18 101/21 101/22
353-8743 [1] 2/7
354-3269 [1] 3/18
4
4.32 percent [1] 138/24
4.89 percent [1] 133/22
40 [1] 2/21
400 [2] 3/13 64/3
404 [1] 2/18
416-0257 [1] 1/18
418 [1] 6/20
4301 [1] 3/2
434 [1] 3/3
45 [1] 6/16
457-0800 [1] 3/4
46 [5] 6/16 82/2 82/3 82/8 100/12
470 [1] 1/17
48 [1] 7/6
5
5.34 percent [1] 135/5
50,570 [2] 138/11 138/15
505 [11] 13/14 13/17 13/23 14/7 14/24
15/17 20/5 20/6 48/9 50/8 50/15
506 [3] 57/9 58/7 58/21
512 [1] 53/25
523 [1] 2/18
558-1863 [1] 2/14
6
6.18 percent [1] 139/6
609 [1] 1/21
63 [1] 4/5
646 [1] 3/10
662-8389 [1] 3/14
6706 [1] 3/17
7
7,000 [1] 7/15
7,018 [1] 7/12
70 percent [1] 71/24
7080 [1] 1/21
720-1428 [1] 2/22
736-2200 [1] 3/7
74 [1] 4/6
76 [1] 4/9
7:00 o'clock [1] 24/2
8
8-29-12 [1] 140/16
82 [2] 12/21 13/7
82,193 [1] 138/10
8327 [1] 3/10
8389 [1] 3/14
843 [2] 1/21 2/22
8743 [1] 2/7
9
90,000 [4] 41/22 41/25 42/3 42/16
93.82 percent [1] 139/13
934 [1] 1/20
94 [2] 139/10 139/14
94 percent [1] 139/8
94.66 percent [1] 135/2
95 percent [1] 139/2
95.11 percent [2] 133/16 133/17
95.68 percent [1] 139/12
950 [1] 2/6
96 [2] 139/10 139/13
99 [1] 4/9
99999 [1] 129/17
9:00 [1] 1/5
9s [1] 123/16
A
A.B [1] 2/11
a.m [1] 1/5
able [26] 20/15 26/15 35/18 35/21 36/1
39/24 41/11 47/10 62/15 69/14 75/5
106/24 107/13 115/15 115/18 115/19
116/2 120/16 122/23 123/12 128/7
129/16 131/4 131/25 132/5 134/25
about [91] 8/13 9/8 10/15 11/5 12/7
12/15 14/20 17/20 20/25 21/23 22/16
22/24 23/6 31/21 32/1 32/17 33/9 34/24
37/7 38/12 38/13 41/10 49/17 50/2 50/5
50/10 51/2 54/15 57/3 57/23 58/13
59/11 59/12 62/9 62/15 63/4 63/9 63/10
63/23 64/8 64/9 64/25 65/9 65/23 67/9
67/20 70/23 70/25 71/22 71/24 72/4
73/3 73/3 73/13 77/2 79/14 79/15 80/14
81/5 83/11 84/9 84/15 85/4 87/11 88/15
89/22 89/23 90/6 90/16 91/23 93/9
95/25 100/11 109/21 112/22 113/9
114/21 118/1 119/14 122/24 125/20
127/5 128/1 131/13 133/11 134/11
134/22 136/11 137/18 139/7 139/8
above [1] 140/14
above-titled [1] 140/14
ABS [2] 98/8 98/12
absentee [14] 85/21 86/6 98/7 98/10
98/14 98/15 98/20 98/23 102/7 102/21
102/22 105/6 105/13 106/7
absentees [2] 83/11 87/5
ABUDU [1] 2/15
accept [10] 20/7 20/11 20/12 20/15
141
A
accept... [6] 20/18 20/19 23/21 33/12
59/4 59/5
acceptable [8] 19/24 21/13 31/23 32/7
39/5 58/9 73/13 127/10
accepted [3] 40/4 109/5 110/24
access [7] 7/17 30/20 38/14 40/4 53/1
64/2 64/6
accessible [2] 104/10 104/13
accompanied [1] 72/7
according [2] 12/19 65/22
accordingly [1] 35/8
accountability [2] 12/20 13/3
accounting [1] 119/3
accurate [1] 139/12
acronym [2] 80/11 80/12
across [2] 66/15 129/17
act [20] 6/10 48/16 65/11 68/10 68/14
68/19 74/13 110/16 110/18 110/19
112/16 113/6 120/18 121/1 130/17
132/7 133/18 135/3 138/11 138/16
active [29] 81/1 113/1 114/19 114/23
114/25 115/10 115/13 116/4 116/7
116/24 117/6 117/7 117/11 117/12
118/1 118/2 133/3 133/4 133/6 133/13
133/17 133/22 134/14 134/18 134/18
135/3 137/8 137/9 137/15
actively [1] 101/20
activities [1] 91/24
actual [3] 11/7 97/18 97/20
actually [26] 9/15 26/14 43/25 61/8 70/3
70/15 83/13 85/11 87/8 93/21 96/2 98/2
98/19 99/4 100/17 102/12 105/11
105/13 105/14 105/16 106/3 106/24
118/9 123/25 128/2 132/9
add [1] 69/14
added [3] 70/4 123/6 123/7
adding [1] 70/7
addition [2] 69/6 114/25
additional [8] 10/13 46/18 68/3 74/5
82/1 118/6 124/6 124/7
address [5] 35/5 96/2 102/21 113/16
124/11
addressed [2] 61/5 106/22
addresses [1] 61/8
addressing [1] 96/3
adds [1] 134/9
adjust [1] 35/8
adjusted [1] 35/8
administer [1] 24/4
administered [1] 81/10
administration [2] 11/2 110/7
admitted [1] 35/14
adopt [1] 41/23
adversely [1] 92/9
advise [1] 38/24
advised [2] 116/16 132/23
affect [4] 92/9 119/4 119/6 126/8
affidavit [55] 17/23 18/8 18/23 19/5
20/13 21/18 22/2 22/8 23/7 23/14 23/19
24/22 25/6 27/5 31/4 31/16 31/16 31/22
32/3 32/18 32/25 33/10 33/11 33/16
33/20 33/22 33/25 34/7 34/12 36/17
36/24 37/16 39/14 45/24 47/9 47/18
48/2 49/19 49/23 50/3 50/6 50/11 50/17
50/25 53/22 54/21 56/16 58/24 66/23
66/25 67/2 72/8 111/22 111/23 112/6
affidavits [3] 41/14 41/25 45/18
affiliation [1] 49/11
afford [2] 39/24 46/23
African [9] 6/23 7/9 30/11 30/15 52/11
82/25 83/1 83/4 83/6
after [29] 35/2 35/8 43/21 43/25 44/4
44/23 48/18 49/4 51/19 52/17 52/22
57/2 57/5 61/7 62/8 65/10 66/21 76/5
85/10 85/24 86/14 91/21 100/24 114/1
115/4 128/2 128/25 131/23 140/6
afterwards [1] 41/1
again [31] 5/5 21/24 28/14 30/2 37/11
45/11 46/20 54/7 55/14 61/25 63/19
64/1 76/6 84/9 85/7 91/15 99/1 99/11
99/11 113/5 115/16 120/5 121/4 123/2
123/18 125/17 125/20 129/9 134/14
137/1 137/8
against [4] 65/21 67/15 98/2 130/12
age [3] 6/24 7/10 67/13
agencies [2] 68/3 68/5
ago [6] 34/25 36/15 57/21 63/23 64/21
72/2
agree [8] 12/25 16/22 24/20 52/17 102/8
104/19 104/23 136/18
agreed [5] 21/4 21/7 23/4 135/24 136/5
agreeing [1] 21/1
agreement [1] 8/8
agrees [1] 109/19
ah [1] 36/22
ahead [8] 6/1 59/25 84/23 95/16 96/22
106/9 111/15 111/22
aided [1] 3/25
al [3] 1/6 5/3 5/4
ALAN [2] 1/22 2/1
all [58] 5/16 6/17 14/1 28/21 30/7 35/16
35/18 35/19 36/1 39/21 42/7 42/10
42/19 43/21 44/15 46/4 46/12 46/13
46/18 47/22 48/2 48/18 51/19 52/17
59/13 60/10 63/16 64/3 64/7 71/6 74/4
75/23 75/24 77/9 78/1 81/9 81/12 81/21
84/12 88/7 88/15 97/16 99/18 100/12
112/25 115/2 115/14 116/6 121/23
121/24 122/10 123/2 124/25 126/19
129/7 129/17 134/6 134/14
allow [9] 16/1 52/19 59/24 69/25 70/1
93/15 96/25 97/17 111/21
allowed [3] 31/8 65/11 98/12
allowing [3] 33/19 104/13 109/6
allows [2] 23/23 93/18
almost [2] 26/1 89/20
along [2] 5/14 122/13
already [12] 53/17 66/8 68/4 95/12
98/23 107/13 109/5 130/11 130/15
130/16 135/1 136/10
also [49] 1/22 7/23 8/22 15/17 18/5 21/4
21/7 31/19 36/4 42/7 51/2 53/4 54/24
55/3 55/18 57/21 62/21 64/13 64/15
64/25 66/7 74/13 75/8 75/12 84/21
89/21 90/4 93/18 93/20 98/17 99/9
100/22 103/15 103/18 104/19 104/25
105/7 107/4 109/1 111/13 112/15 113/4
113/15 113/16 115/16 120/5 121/5
132/23 135/7
altered [1] 137/3
although [2] 12/19 54/22
always [8] 11/1 14/17 35/3 36/10 39/21
53/13 54/22 85/3
always-changing [1] 36/10
am [12] 1/6 19/6 19/18 32/5 32/20 34/2
47/10 78/13 129/2 130/20 131/18 135/5
amended [2] 36/13 103/3
AMERICA [5] 1/6 68/10 68/14 68/19
74/13
American [11] 2/16 2/20 3/1 6/24 7/10
30/11 30/16 52/11 110/8 110/14 138/5
Americans [4] 82/25 83/1 83/4 83/6
Americas [1] 3/9
among [1] 8/22
amounts [2] 55/3 55/4
analogous [1] 134/8
analyses [2] 116/6 120/2
analysis [14] 114/24 115/14 116/23
117/5 117/18 118/10 118/25 119/4
122/18 122/19 131/22 133/5 134/20
137/15
analyze [1] 131/25
analyzed [1] 118/18
analyzing [1] 119/12
and 2012 [1] 101/14
ANDINO [34] 4/4 5/17 5/17 5/18 5/20
5/24 6/5 6/7 12/11 13/19 14/3 14/7 16/5
19/25 21/24 29/16 31/2 35/11 40/9
45/11 52/17 53/15 56/21 58/6 59/10
60/9 62/18 63/14 63/22 67/8 74/2 74/8
75/25 95/11
ANGELA [1] 2/4
ANNA [1] 2/2
annual [1] 81/2
another [21] 9/1 9/8 12/6 33/1 42/4 53/7
83/23 88/1 90/22 91/10 101/6 117/7
121/8 122/1 125/9 125/17 125/22
126/25 133/3 133/23 140/7
answer [2] 17/3 99/15
anticipate [1] 35/7
any [72] 6/16 7/13 7/15 8/4 14/12 15/10
15/14 15/24 15/25 16/15 17/3 18/3
22/16 23/3 24/6 24/25 25/9 25/14 27/18
28/24 30/16 38/8 39/10 41/12 43/16
59/7 60/17 60/22 68/3 73/13 80/8 81/6
85/4 85/14 85/16 86/13 86/20 87/1
90/18 92/1 92/12 92/21 95/2 97/22 99/2
99/7 99/11 99/14 99/15 103/10 103/12
103/21 103/24 106/5 107/18 108/4
110/10 110/12 111/8 114/2 114/6
115/13 117/23 118/24 119/2 119/6
119/7 127/22 128/5 130/8 131/19
131/21
anybody [5] 15/22 24/14 50/5 57/15
97/8
anyone [3] 57/18 112/4 128/25
anything [13] 13/23 14/7 58/13 62/15
62/22 73/19 88/5 89/22 89/23 89/25
111/20 114/11 130/10
anyway [1] 47/7
apart [1] 9/4
apologize [1] 91/7
Apparently [1] 126/23
appear [2] 26/18 68/22
APPEARANCES [1] 1/13
appears [4] 66/8 132/22 134/4 136/10
appendix [1] 50/9
application [2] 68/20 69/8
applied [1] 32/8
applying [1] 21/16
appoint [1] 49/15
appointed [6] 49/4 77/19 78/18 85/11
85/13 91/21
appointment [1] 80/25
approach [1] 14/4
appropriate [1] 60/22
appropriations [1] 65/11
approved [1] 70/24
approximately [7] 64/2 64/3 64/22 71/9
110/1 110/2 127/5
April [4] 84/16 113/23 114/17 121/4
April 20th [2] 113/23 121/4
April 20th, 2012 [1] 114/17
are [141]
area [2] 110/8 119/1
areas [4] 7/21 33/6 110/4 110/5
aren't [2] 13/1 25/22
around [5] 7/8 43/13 47/3 62/3 71/11
arrives [1] 25/7
ARTHUR [1] 3/1
142
A
articles [1] 109/24
as [171]
ascertain [1] 113/5
Asians [1] 138/5
aside [6] 17/19 41/13 47/14 47/18 88/20
119/3
ask [28] 5/13 11/17 16/12 17/8 18/15
18/24 23/2 28/10 42/15 57/12 59/11
59/12 64/13 68/7 74/5 75/4 79/9 81/4
83/23 84/14 87/18 90/16 93/24 100/11
109/8 109/8 113/9 118/15
asked [15] 37/21 42/9 56/15 64/25 74/19
78/2 88/14 89/8 89/13 94/15 100/8
108/7 112/10 112/11 112/15
asking [25] 16/22 23/6 25/1 31/4 33/2
33/3 33/4 34/7 35/25 63/23 64/7 66/7
88/7 88/8 89/14 89/24 90/4 90/8 90/18
90/23 91/5 91/8 94/12 94/13 96/14
asks [1] 20/2
aspect [1] 33/5
aspirations [1] 104/15
assembly [3] 49/5 57/21 65/10
assessability [1] 104/16
assessing [1] 124/8
assessments [1] 34/20
assist [1] 18/5
assistance [2] 11/6 18/15
Associate [1] 109/3
association [3] 80/9 80/12 100/20
assume [5] 25/5 41/22 42/16 44/18 48/9
assumed [1] 86/3
assumes [4] 5/8 5/10 5/14 41/16
assuming [7] 5/6 29/7 45/22 47/9 60/18
70/12 102/5
assumption [1] 21/11
assurance [1] 45/1
Atlanta [1] 2/18
attached [1] 109/16
attempt [4] 24/7 32/12 127/22 128/6
attempted [4] 83/24 105/5 105/7 118/8
attend [2] 84/10 92/12
attending [1] 84/19
attention [2] 102/25 107/25
Attorney [6] 1/22 1/23 50/15 51/1 51/6
54/23
August [2] 1/4 13/13
August 14th [1] 13/13
authority [1] 65/14
authorized [1] 24/4
available [11] 6/9 7/1 24/4 24/7 132/7
132/12 132/13 132/16 135/1 137/21
138/8
Avenue [5] 2/6 3/2 3/9 3/13 3/17
avoid [1] 139/21
aware [6] 7/14 8/4 17/5 19/25 22/14
83/8
awareness [1] 97/25
away [4] 24/19 66/14 74/11 75/3
B
B's [1] 51/24
back [34] 21/22 28/17 28/17 29/6 45/21
45/25 47/3 48/3 48/10 48/11 48/19 66/6
66/15 72/10 82/13 85/7 85/21 90/5
90/24 91/14 95/19 95/19 98/19 101/10
121/21 123/4 123/23 125/21 126/14
128/11 130/24 130/25 139/7 140/7
bad [1] 92/9
BALDWIN [1] 2/2
ballot [94] 9/5 19/18 21/13 21/20 23/12
23/16 25/20 25/23 25/25 26/9 26/22
26/24 27/2 27/4 27/11 27/18 27/24
28/14 28/16 28/21 28/24 29/1 29/25
32/11 34/13 37/4 37/4 37/12 42/22
47/11 47/12 47/19 47/20 47/21 48/2
48/10 48/18 48/20 49/18 66/20 67/6
68/23 72/4 72/6 72/9 72/13 72/16 74/17
74/19 74/21 75/2 75/6 84/11 85/6 85/21
98/7 98/10 98/13 98/14 98/15 98/18
98/20 98/22 98/22 98/24 99/4 99/5
102/21 102/22 105/6 105/9 105/13
105/15 105/17 105/18 105/20 105/21
105/24 105/25 106/1 106/7 106/11
106/14 106/14 106/15 106/25 106/25
111/15 111/16 111/23 111/25 112/2
115/2 115/20
ballots [15] 12/8 12/16 27/16 42/17
42/24 45/13 45/13 47/15 47/19 72/14
98/14 98/16 102/25 105/16 106/20
Bancroft [1] 1/16
barely [1] 95/6
BARTOLOMUCCI [2] 1/14 4/13
base [1] 126/24
based [23] 11/14 33/24 36/14 59/3
73/12 89/2 89/19 90/4 90/10 90/11
90/19 93/1 98/23 99/2 102/3 102/18
104/14 115/9 115/12 122/23 124/10
128/15 131/10
basically [2] 10/15 38/20
basis [4] 10/19 94/20 95/3 132/15
BATES [3] 1/12 53/12 94/20
Baylor [1] 109/23
be [170]
bear [1] 112/1
Beaufort [8] 6/18 53/18 54/4 54/6 54/7
54/18 55/2 65/1
became [6] 77/19 77/23 78/15 80/18
85/13 100/17
because [42] 8/22 19/4 19/17 23/18 24/6
24/19 25/22 26/8 32/1 32/9 32/19 32/20
32/25 33/19 34/4 36/19 36/25 37/2
37/11 38/8 38/23 39/10 39/21 40/19
41/11 44/19 46/3 47/10 58/24 62/22
63/3 67/2 70/17 71/6 72/14 79/17 95/11
99/3 99/5 111/5 112/4 132/15
become [3] 67/18 77/10 83/8
been [56] 5/14 5/21 17/20 19/3 19/8
19/9 19/10 21/25 22/15 25/1 33/22 45/7
47/10 57/23 57/24 61/25 62/24 62/25
63/5 64/20 67/14 71/7 73/8 76/17 84/19
90/7 91/6 98/20 100/15 102/19 106/20
106/22 108/20 109/10 109/12 110/20
111/4 111/6 112/7 114/1 115/22 115/24
115/25 117/21 125/8 125/14 127/8
128/12 129/13 129/15 130/7 130/13
130/15 130/16 131/2 137/3
BEENEY [14] 2/10 4/5 4/10 5/18 63/22
64/7 64/25 66/7 67/8 69/10 95/12
107/18 107/23 136/11
Beeney's [1] 139/21
before [17] 1/10 32/11 42/20 42/22 44/1
52/6 52/15 60/17 62/2 62/4 62/9 62/21
84/22 88/5 135/24 137/18 140/7
Beg [1] 99/13
Begging [1] 74/1
beginning [2] 62/2 62/3
behalf [10] 88/6 88/10 91/4 94/21 95/1
95/1 95/5 95/8 95/13 96/24
behind [2] 46/5 46/14
being [20] 12/16 16/17 23/17 32/3 32/19
34/25 35/10 35/11 35/17 41/11 44/4
64/15 73/10 82/9 105/4 107/13 108/12
116/2 118/16 126/19
belief [1] 46/21
believe [44] 5/16 6/18 6/23 8/16 9/12
12/23 13/13 14/13 15/13 16/19 16/21
18/5 33/3 33/19 46/6 47/22 48/4 49/23
50/14 50/19 50/22 51/21 51/24 52/10
55/10 58/17 59/14 59/19 60/6 61/3
61/16 62/25 63/6 69/10 70/8 74/20
80/21 83/5 83/23 93/14 108/4 119/2
120/7 127/3
believed [1] 116/20
believes [1] 33/13
benefit [1] 92/11
beside [1] 98/8
best [10] 9/11 9/16 9/21 35/6 35/22
35/25 36/11 102/9 118/21 122/17
better [2] 11/14 17/8
between [16] 16/23 17/17 25/7 25/23
26/14 28/25 32/6 38/8 43/13 44/11
47/25 61/2 80/21 112/16 124/4 139/22
beyond [2] 16/15 111/20
bill [3] 101/13 101/14 101/18
birth [12] 113/16 120/5 122/14 124/4
124/13 124/14 125/3 125/4 125/6 125/7
125/11 131/19
bit [8] 11/10 29/16 60/4 63/22 73/3
79/15 80/14 121/21
black [7] 9/23 70/9 70/14 75/9 75/17
75/18 138/4
blank [2] 123/14 123/19
blanks [2] 17/23 18/1
blue [1] 64/16
bluntly [1] 37/7
board [33] 48/23 48/23 49/14 49/19
49/22 50/10 50/16 50/22 51/10 51/20
52/3 52/5 77/14 77/19 77/22 80/18
82/17 82/19 82/21 82/23 82/24 84/10
84/13 84/20 98/21 100/18 104/21 105/1
105/18 105/22 107/6 111/25 129/18
boards [12] 49/4 49/8 49/11 52/18 77/21
77/24 81/23 85/2 85/3 100/1 108/2
108/4
body [1] 93/2
booth [3] 11/7 19/16 47/12
both [8] 80/3 80/7 84/25 106/20 121/11
124/21 134/17 135/12
bottom [1] 134/10
BOWERS [27] 1/24 4/5 4/8 4/9 63/19
76/12 76/13 76/16 76/21 76/23 77/6
87/17 88/2 88/3 91/14 91/23 94/22
94/23 95/7 97/6 99/14 99/23 99/25
101/11 107/17 107/23 108/9
box [3] 26/9 47/21 72/16
BRADLEY [1] 2/1
break [2] 76/3 137/24
Brennan [1] 3/8
BRETT [1] 1/11
BRIAN [2] 1/15 115/7
brief [2] 76/4 107/24
briefly [3] 21/22 72/5 78/22
bring [8] 28/13 45/25 58/25 59/7 66/9
67/23 98/2 102/24
Broad [1] 2/13
broader [1] 110/8
brought [4] 28/13 65/15 97/22 112/1
BRYAN [2] 1/23 2/2
BS [1] 109/22
build [2] 61/17 62/19
bunch [2] 43/18 44/19
burden [6] 23/13 50/16 50/19 50/24
107/11 111/24
bus [4] 7/20 7/24 8/1 8/2
busy [1] 83/10
Butch [1] 63/19
buy [5] 9/11 9/11 9/16 9/16 9/21
C
CA [1] 1/3
143
C
calculations [4] 119/4 119/6 133/17
135/2
Calhoun [1] 2/21
call [8] 34/18 40/14 52/25 53/3 60/20
63/1 76/9 108/16
called [1] 47/16
calls [3] 76/12 89/17 97/12
came [7] 35/7 36/21 44/19 87/12 102/4
112/22 121/23
camera [3] 9/10 9/19 9/21
CAMONI [1] 2/12
Campaign [1] 3/5
can [85] 5/9 5/13 7/18 8/1 8/5 8/12 9/11
10/7 10/18 10/24 12/25 13/8 14/1 15/5
15/17 16/4 17/7 17/16 23/12 23/24 25/4
28/17 29/21 30/22 32/5 32/12 32/20
33/12 33/21 34/1 35/6 35/23 35/25 36/4
36/12 39/11 39/20 39/21 40/22 40/25
41/6 48/5 48/6 49/1 49/8 50/5 52/2
52/17 54/15 54/23 57/12 58/23 59/15
61/3 61/9 61/16 63/8 69/11 73/2 78/21
80/4 83/18 83/21 84/14 93/11 103/11
103/23 104/22 106/16 107/16 108/13
108/14 110/25 111/14 111/21 112/5
112/22 113/10 114/21 118/20 118/23
122/24 127/19 137/5 138/1
can't [22] 13/8 19/3 19/8 19/9 19/15
20/19 21/6 23/17 31/16 40/19 40/20
42/12 42/19 46/23 53/21 54/19 59/5
106/8 106/10 112/5 129/10 136/2
candidate [2] 47/6 97/19
candidates [4] 18/17 18/19 23/16 30/4
cannot [3] 49/2 54/9 102/22
canvassers [1] 48/24
capacity [12] 77/13 79/4 88/4 88/12
89/14 90/8 90/10 90/23 92/21 94/15
97/6 99/7
Capital [1] 3/2
capture [1] 69/24
car [8] 26/6 38/14 38/14 39/24 40/4 40/4
46/23 46/24
card [52] 6/9 9/24 19/23 20/7 20/11
20/12 20/16 21/6 42/9 42/12 58/3 58/22
59/1 59/7 59/15 60/5 61/3 61/5 69/6
69/15 69/17 69/24 70/3 70/8 70/15
70/17 70/20 73/7 75/9 75/15 75/17
75/18 86/13 86/19 87/9 93/16 104/21
107/6 111/2 111/3 120/4 120/13 120/22
121/9 122/22 124/24 127/19 128/5
128/21 130/19 130/23 132/14
cards [7] 61/8 61/9 75/21 105/2 122/7
127/12 127/16
career [1] 100/16
CAROLINA [67] 1/3 1/22 1/24 2/20 5/3
5/11 16/19 19/14 20/1 22/6 52/12 54/8
58/22 59/13 63/17 63/19 65/5 65/18
65/19 65/23 67/10 67/12 71/2 71/5
76/12 77/7 77/8 77/11 78/10 78/14
80/12 86/3 86/5 93/22 97/25 100/16
101/8 102/5 110/21 111/1 112/8 112/12
112/19 114/17 115/21 119/25 121/22
122/10 125/15 125/21 125/22 126/5
126/8 126/8 126/11 126/12 126/13
126/19 126/22 127/5 127/7 127/17
128/20 128/21 132/1 133/14 133/18
Carolina's [1] 110/16
Carolinians [1] 120/4
Carolyn [1] 83/5
carry [1] 65/12
carry-forward [1] 65/12
case [11] 5/2 98/6 109/16 111/21 112/8
112/18 118/11 118/12 122/15 123/16
126/25
cases [2] 124/5 130/14
cast [19] 25/21 25/25 27/3 33/17 37/4
37/12 67/6 68/23 98/17 105/13 105/16
105/24 105/25 106/4 106/6 111/15
111/22 112/1 115/2
casting [2] 72/6 106/20
casts [1] 27/1
catch [1] 106/21
categories [18] 114/24 115/1 115/3
115/10 115/17 115/20 116/11 116/17
116/24 117/2 117/8 118/3 134/9 134/15
134/19 137/12 138/6 138/8
categorize [1] 114/18
categorized [2] 116/4 116/10
category [4] 115/13 137/10 137/11
138/4
CATHERINE [2] 2/3 99/22
caught [1] 99/6
cause [1] 46/22
causing [1] 102/25
Center [2] 3/5 3/8
certain [6] 17/23 82/1 92/8 100/5 114/18
123/10
certainly [11] 13/20 14/17 18/15 35/1
48/15 90/3 115/13 116/19 138/1 139/13
139/17
certificate [1] 97/21
certificates [1] 97/19
certification [7] 23/11 43/2 44/4 44/22
44/25 81/10 81/13
certified [3] 23/17 25/8 52/23
certify [8] 42/20 42/22 42/24 43/10 44/1
44/24 45/17 140/12
chair [9] 85/11 85/13 90/20 91/21 92/23
100/22 100/24 103/6 103/18
challenge [15] 23/16 25/15 25/18 26/7
26/11 26/13 26/16 27/12 29/9 30/12
36/18 36/19 36/20 43/17 43/18
challenged [8] 27/6 29/20 29/21 30/16
32/11 44/20 47/20 84/11
challenger [3] 23/14 50/20 50/23
challenges [5] 23/12 23/20 25/9 44/14
85/2
chance [2] 24/15 32/7
change [3] 72/22 118/23 118/23
changed [1] 102/10
changes [1] 60/22
changing [1] 36/10
channeling [1] 138/13
charge [2] 22/7 97/22
charges [1] 98/2
charging [3] 53/22 54/9 54/20
Charles [2] 82/21 83/5
Charleston [25] 1/20 2/22 6/15 78/9
79/14 79/15 79/16 79/22 80/4 80/7
82/13 82/14 82/18 83/7 83/24 84/9
84/16 85/1 86/23 97/7 98/6 99/1 99/8
99/9 108/1
chart [5] 137/2 137/21 139/5 140/4
140/7
check [7] 16/8 16/11 27/6 30/7 46/4
46/6 46/16
check-in [6] 16/8 16/11 30/7 46/4 46/6
46/16
checking [1] 46/13
Chief [1] 66/18
choose [1] 34/19
CHRISTOPHER [2] 1/14 1/19
circling [2] 133/11 133/15
CIRCUIT [1] 1/11
circumstances [2] 17/14 38/21
citizen [6] 55/15 67/11 68/8 89/18 90/13
90/16
city [1] 7/8
Civil [5] 2/5 2/16 2/20 3/1 3/12
claims [1] 18/25
clarify [6] 46/15 75/8 88/9 119/24
121/21 138/1
clarity [1] 91/7
classified [1] 113/1
clause [4] 111/12 111/12 111/20 112/3
clean [1] 85/22
clean-up [1] 85/22
cleaned [3] 123/23 129/9 129/19
cleaning [1] 123/17
clear [7] 21/24 88/3 119/9 128/18
135/12 137/2 138/13
clearly [2] 114/23 115/1
Clemmons [1] 6/22
Clemmons' [1] 11/4
clerk [3] 10/12 68/7 77/14
clock [1] 43/13
close [4] 43/22 79/12 81/19 134/13
closely [2] 63/6 92/2
closest [1] 139/10
COATES [1] 1/19
code [1] 103/3
COLLEEN [1] 1/11
color [3] 70/21 70/22 75/12
COLUMBIA [1] 1/1
column [3] 133/9 135/25 136/6
combat [2] 103/10 103/22
combination [1] 42/16
combined [4] 77/21 77/23 77/23 117/12
come [17] 5/17 25/18 26/6 27/12 28/12
29/6 30/22 34/23 36/17 39/22 68/6
74/25 86/18 107/5 107/10 107/12
135/13
comes [6] 7/12 23/1 25/15 26/16 50/14
74/18
coming [5] 45/21 55/19 57/11 85/25
86/1
comment [1] 56/4
comments [4] 54/22 64/7 64/16 66/5
commission [83] 6/8 7/14 10/18 10/22
11/20 11/23 12/20 20/10 22/11 22/14
31/21 33/9 40/12 42/8 43/25 44/6 49/2
50/9 53/1 54/1 59/14 64/3 64/4 64/5
71/1 75/13 75/16 77/22 78/14 78/16
79/8 79/10 79/11 79/13 80/5 81/7 81/9
81/11 81/16 81/22 82/7 82/10 88/11
89/6 89/15 94/4 94/7 94/10 94/16 94/18
95/1 95/8 95/14 99/25 100/8 112/20
112/25 113/3 113/10 113/11 114/2
114/6 114/13 114/18 115/5 115/8 116/7
116/11 116/16 116/23 117/16 120/9
120/25 121/12 121/16 122/15 123/11
126/15 127/23 128/19 128/24 131/24
137/13
commission's [4] 79/23 114/14 118/19
134/25
commissioner [15] 28/18 29/23 34/17
51/23 78/13 89/1 89/3 89/4 89/6 89/11
89/14 91/6 94/16 95/6 95/16
commissioners [16] 12/7 12/15 25/9
26/4 28/19 34/20 35/19 36/18 42/18
45/16 64/5 91/5 94/3 94/9 94/19 95/2
commissions [1] 22/11
committed [2] 106/11 106/13
committee [18] 3/12 85/12 85/12 90/20
91/19 91/20 91/22 91/25 92/3 92/23
92/24 95/20 96/6 100/22 100/24 103/7
103/18 103/19
committees [2] 80/17 81/1
commonly [1] 80/10
communicate [3] 14/17 95/23 96/8
communications [1] 96/11
144
C
compare [2] 73/16 73/22
compared [2] 7/2 57/22
comparison [4] 60/25 61/1 62/23 112/16
Compass [1] 1/20
complaints [1] 48/15
complete [3] 47/12 58/23 120/2
completed [1] 24/22
completely [1] 47/1
completing [1] 15/20
complimenting [1] 35/11
composition [1] 82/24
comprehensive [1] 36/1
computer [1] 3/25
computer-aided [1] 3/25
conceivable [1] 23/10
conceivably [1] 118/23
concentrate [1] 7/20
concern [1] 12/17
concerns [2] 102/13 102/20
concluded [1] 12/6
conduct [2] 65/12 65/15
conducted [4] 51/19 81/12 122/4 124/3
conducting [1] 79/1
conference [1] 81/3
conferences [1] 81/12
confidence [4] 31/6 31/8 35/20 53/4
confident [3] 35/16 35/25 36/3
confirmed [1] 122/6
confirming [1] 122/20
conflict [1] 100/7
confused [1] 32/1
confusion [1] 19/21
connect [1] 123/3
Connecticut [1] 3/2
conservative [3] 61/11 61/14 116/19
consider [2] 25/7 25/9
consideration [3] 42/4 101/12 101/21
considerations [3] 104/16 104/19
104/23
considered [3] 39/16 104/25 124/23
considers [1] 105/18
consisted [2] 132/10 132/10
constitute [1] 17/14
constitutes [1] 15/14
Constitution [1] 3/17
contact [1] 79/12
contain [4] 73/4 75/19 111/8 114/6
contained [5] 119/22 121/12 122/10
122/13 125/19
contains [1] 73/5
contemplated [1] 39/10
contemplates [1] 15/18
contents [2] 113/11 119/18
continue [4] 44/21 44/25 54/16 98/5
CONTINUED [1] 6/3
control [3] 16/15 21/17 111/20
convenience [1] 104/17
conversation [6] 17/17 62/1 115/9
116/22 117/1 122/16
conversations [2] 17/20 122/16
Conversely [1] 54/8
convey [1] 14/13
convicted [1] 67/14
convinced [1] 117/1
COOPER [1] 2/10
cooperative [1] 62/25
coordinated [1] 81/8
copy [2] 14/1 97/20
correct [93] 6/12 7/25 10/12 11/12 11/21
12/22 13/22 15/4 16/12 16/13 17/25
18/4 30/17 30/18 33/17 38/10 40/5
43/11 44/10 45/1 45/15 47/12 48/25
49/13 52/24 56/22 57/1 57/7 60/12
65/24 66/17 67/3 68/20 70/5 70/10
70/11 71/13 71/15 72/2 72/3 74/11
86/24 88/23 91/2 94/4 95/12 95/17
100/2 100/23 101/4 101/8 101/18 102/2
102/16 103/7 103/10 103/13 103/16
104/5 104/17 105/11 105/12 105/19
105/22 105/23 106/1 106/2 106/3
106/12 107/7 112/8 112/9 115/6 116/5
117/14 119/13 120/11 120/20 121/2
121/3 121/3 121/14 125/23 128/22
129/2 130/2 130/3 130/20 131/18 135/6
137/17 138/25 140/13
correction [1] 41/23
correctly [2] 79/19 95/11
could [60] 8/24 9/21 10/3 17/7 17/10
17/13 18/5 18/14 19/22 22/5 23/10
25/24 25/25 26/6 26/18 27/12 27/12
28/10 28/23 28/24 29/11 30/11 39/25
42/15 42/22 46/6 46/10 47/8 49/14
58/17 60/1 66/20 68/9 69/17 69/22 70/2
88/20 93/17 93/24 108/24 112/1 115/2
116/19 116/20 118/7 118/10 118/13
118/23 120/8 120/24 124/10 124/20
124/21 126/10 126/18 128/20 129/10
129/13 135/20 139/12
couldn't [7] 9/18 29/9 37/20 38/14 70/3
91/4 123/11
counsel [6] 5/5 5/17 35/13 94/14 135/24
136/5
count [28] 23/7 23/18 32/13 32/24 33/7
33/15 34/1 34/8 37/10 40/12 41/13
43/19 43/20 49/17 52/7 52/15 79/3 85/6
98/13 98/22 99/3 99/5 102/22 102/25
105/19 105/20 106/12 106/14
counted [22] 7/10 27/13 31/24 32/4
33/21 34/2 37/5 45/2 48/24 51/25 52/23
53/10 74/22 98/15 98/15 98/20 105/21
105/25 106/1 111/16 111/25 121/1
counties [33] 6/16 7/7 7/22 9/10 9/10
10/1 10/3 11/19 12/3 13/24 22/17 23/6
31/2 31/5 33/2 44/1 49/21 50/1 53/21
64/11 65/14 71/6 71/15 82/2 82/9 84/25
93/4 100/4 100/12 104/4 104/8 104/9
107/1
counting [1] 124/15
country [1] 41/20
counts [1] 28/1
county [151]
couple [9] 11/17 21/22 30/2 38/5 40/9
45/11 111/10 114/22 115/17
course [4] 7/20 94/1 98/13 118/22
court [30] 1/1 3/16 3/16 35/13 42/9 49/1
52/3 60/17 60/18 64/1 65/9 65/16 65/17
65/19 65/21 65/22 66/7 67/13 67/17
73/3 78/22 79/14 81/14 88/5 91/15
91/23 95/25 109/5 109/9 118/13
Court's [10] 29/17 30/3 31/20 40/9
41/10 41/23 45/12 74/1 97/24 99/13
Courthouse [1] 3/17
cover [3] 34/23 36/4 56/3
covers [1] 36/1
crafted [1] 55/14
created [8] 16/15 113/21 122/9 123/1
129/1 132/3 133/2 138/4
creating [2] 92/10 122/20
credible [1] 19/1
crime [5] 106/3 106/4 106/11 106/13
106/17
critical [1] 120/1
Cromwell [1] 2/13
cross [1] 53/13
cross-examination [1] 53/13
crosses [1] 5/18
crowded [1] 47/3
current [38] 15/11 27/15 27/20 28/20
57/14 57/18 57/24 58/11 58/12 58/13
58/25 59/18 66/9 66/11 66/19 72/20
74/10 74/18 74/25 89/10 111/1 112/17
113/6 114/14 118/7 120/12 120/19
122/3 122/7 122/11 122/21 123/2 123/9
124/23 128/4 132/6 135/3 138/15
currently [14] 66/13 67/9 73/5 73/13
75/1 78/13 89/4 89/11 112/13 113/1
132/7 133/21 137/21 138/8
CV [2] 5/4 109/16
D
daily [1] 118/23
DANIEL [1] 2/4
data [22] 112/14 113/4 113/7 113/20
114/3 114/9 117/10 117/10 117/11
118/6 118/15 120/6 121/23 122/2 122/4
122/5 122/17 128/3 128/11 130/10
130/11 134/17
database [80] 112/19 112/23 113/3
113/4 113/6 113/10 113/12 113/13
113/15 113/18 113/20 113/21 113/25
114/2 114/4 114/6 114/8 114/9 114/13
114/15 114/18 114/22 115/4 115/6
115/11 117/16 117/17 117/19 117/23
117/25 118/7 118/8 118/19 118/23
119/8 119/12 119/15 119/15 119/19
119/20 119/23 119/25 120/6 120/9
120/10 120/14 120/24 120/25 121/12
121/12 121/16 121/17 121/23 122/8
122/10 122/15 122/21 123/1 123/5
123/7 123/8 123/11 125/9 125/13
125/17 125/18 127/23 128/6 128/19
128/20 128/24 130/12 130/13 131/5
131/5 131/24 133/14 134/25 137/11
137/13
databases [6] 79/2 113/9 121/5 124/4
130/6 131/17
date [30] 41/12 43/1 43/5 44/4 44/24
61/25 62/2 64/20 113/16 113/20 113/21
114/15 115/15 118/7 118/22 120/5
120/16 120/20 121/4 122/14 124/4
124/12 124/14 125/3 125/4 125/5 125/7
125/11 131/19 140/16
day [30] 1/6 10/3 10/5 10/6 10/11 16/5
23/3 25/8 25/23 36/5 36/8 36/9 36/18
36/19 38/9 40/13 40/21 40/23 40/24
41/8 41/14 42/1 62/10 63/1 83/11 96/4
98/14 105/7 105/16 131/23
days [6] 43/25 44/5 44/7 62/1 62/9
62/15
DC [7] 1/4 1/18 2/7 3/3 3/6 3/14 3/18
death [1] 118/6
deceased [4] 117/17 118/9 119/1 119/3
decedents [4] 117/19 117/23 118/15
119/8
decide [7] 21/17 43/18 52/6 52/15 56/8
98/1 134/17
decides [5] 28/7 31/21 33/10 48/24
51/20
deciding [1] 104/25
decision [5] 21/19 21/19 44/14 49/1
52/2
decisions [2] 35/20 49/17
declaration [1] 135/13
declaring [1] 67/13
defend [3] 29/19 29/21 29/25
defendant [11] 2/10 6/20 7/6 12/10
13/13 13/14 50/8 53/24 57/9 58/7 58/21
Defendant's [1] 20/5
Defendant-Intervenor [3] 12/10 13/14
58/7
145
D
defendant-intervenors [1] 13/13
Defendant-Intervenors' [6] 6/20 7/6 50/8
53/24 57/9 58/21
defendants [5] 1/7 2/1 5/4 5/12 13/12
Defense [7] 128/8 129/3 130/1 130/15
131/1 131/10 131/18
define [1] 15/8
defined [1] 137/11
definition [2] 14/25 51/8
degree [1] 119/7
degrees [2] 109/20 109/21
delegation [1] 49/6
DELLHEIM [1] 2/1
delve [1] 21/22
Democrat [1] 49/11
Democrats [1] 49/15
demonstrative [4] 132/18 133/23 135/16
136/14
denoted [2] 132/4 138/3
Department [18] 2/5 93/22 97/3 99/16
99/19 119/14 119/15 121/5 121/7 122/4
125/13 125/15 128/8 128/8 130/14
130/15 131/1 131/1
Departments [3] 129/3 130/1 131/9
depending [1] 18/2
depends [2] 23/13 46/7
deposition [12] 8/13 35/15 88/2 88/10
88/19 94/22 94/24 95/4 95/13 135/25
136/4 136/6
depositions [1] 35/8
Deputy [1] 1/23
describe [3] 83/18 96/11 113/11
described [2] 67/17 116/12
describing [1] 83/19
destroys [1] 53/4
deter [1] 38/3
determination [7] 34/12 52/5 59/23
105/21 113/8 120/21 132/6
determine [9] 49/22 50/2 50/10 102/10
117/18 120/8 120/21 130/6 134/25
determined [1] 32/19
determines [2] 17/20 21/19
determining [6] 73/2 73/11 73/11 73/14
104/20 104/24
detriment [1] 67/5
develop [1] 115/9
dialogue [2] 16/23 39/2
dictate [1] 104/14
did [92] 11/4 11/8 22/21 34/10 43/22
46/15 51/7 51/16 64/19 65/8 65/13 66/1
66/2 69/7 69/15 77/10 79/3 79/9 79/17
79/19 79/23 80/1 80/4 81/5 82/4 83/8
84/10 84/21 85/1 85/16 86/9 86/20
92/12 92/17 93/5 93/7 95/20 96/4 96/8
96/16 96/24 97/7 97/9 97/10 98/19
98/22 99/3 103/4 103/21 103/24 105/20
106/14 111/20 112/18 112/21 113/2
113/6 113/6 113/25 114/2 114/6 114/18
114/20 114/23 115/2 115/9 116/23
117/2 117/4 118/11 118/12 119/10
119/15 120/14 121/5 123/17 124/6
124/9 125/5 125/13 127/22 128/1
128/14 129/9 130/4 130/10 131/18
132/8 133/4 134/17 134/20 136/12
didn't [33] 5/12 9/15 22/19 24/7 34/4
34/24 37/3 40/15 41/4 44/18 65/7 66/9
86/5 97/22 99/3 99/4 99/5 104/22
105/25 106/12 117/18 118/13 118/15
118/16 118/24 119/9 123/21 124/1
128/2 129/17 129/22 130/18 131/21
differ [1] 134/6
difference [4] 136/7 136/20 139/22
139/25
different [11] 14/19 19/10 28/11 34/19
34/20 35/12 36/2 46/7 82/3 110/22
117/6
digits [2] 125/1 129/17
direct [1] 107/25
direction [1] 79/10
directives [2] 80/1 81/23
directly [3] 11/23 11/24 50/14
director [19] 53/18 54/4 54/18 55/13
55/25 56/7 56/15 60/20 63/1 64/25
77/23 78/5 78/10 78/21 82/15 82/20
94/7 94/17 97/7
directors [1] 80/18
disagree [4] 10/22 13/8 54/10 54/16
disagreed [1] 65/4
disagreeing [2] 32/15 32/16
disagreement [1] 54/14
disclosure [1] 15/21
discovered [1] 98/17
discretion [5] 52/18 87/22 100/4 100/6
104/4
discuss [2] 101/2 116/23
discussed [3] 8/8 89/22 134/10
discussing [1] 6/7
discussion [5] 8/12 20/25 70/23 70/25
83/20
discussions [1] 115/5
disenfranchise [3] 24/6 25/1 39/17
disenfranchised [1] 31/9
dispute [1] 95/9
distance [1] 104/16
DISTRICT [4] 1/1 1/1 1/11 1/12
districts [1] 75/20
Division [1] 2/5
DMV [46] 7/3 7/12 7/18 9/2 56/22 56/25
56/25 57/13 57/13 57/23 58/1 58/9
60/20 62/21 62/25 63/4 73/7 93/21
111/2 119/23 119/25 119/25 120/10
120/14 120/24 121/12 121/17 121/22
122/8 122/10 122/16 122/21 123/1
123/24 125/22 126/14 127/8 127/11
127/18 128/3 128/20 130/12 130/13
130/22 131/25 132/1
DMV-issued [4] 7/3 7/12 58/9 130/22
DMVs [1] 86/15
do [133] 7/4 7/5 7/23 8/1 8/10 8/12 9/17
9/19 9/20 10/15 10/23 10/24 11/9 11/24
12/8 12/11 12/13 12/16 14/12 15/8
15/25 16/16 17/3 19/6 19/16 20/24 21/1
22/15 23/1 23/2 23/8 23/11 24/25 25/9
28/16 28/18 31/4 31/20 32/20 33/11
34/21 35/3 35/5 35/20 35/21 35/22
35/24 36/1 36/11 37/21 39/21 43/14
46/11 48/18 51/12 53/25 54/8 54/15
55/16 56/5 56/9 56/13 56/16 56/18
57/12 57/16 58/18 59/9 59/14 59/19
60/6 61/13 61/16 62/15 62/22 62/22
63/23 64/19 64/22 65/1 67/4 67/23 68/3
68/13 68/15 69/1 71/9 71/17 71/18
71/19 72/11 73/14 73/24 74/20 77/6
78/15 79/19 82/23 83/21 83/23 85/8
85/18 87/13 87/17 87/20 88/18 89/25
92/19 94/12 100/4 108/4 109/19 110/1
112/10 112/15 117/15 118/2 118/12
122/8 126/21 126/21 126/23 126/24
130/4 130/10 131/9 131/13 132/19
133/24 135/20 137/24 139/1 139/8
document [17] 11/10 12/12 13/6 13/25
19/23 56/18 69/22 132/19 133/1 133/24
134/1 135/9 135/21 135/23 136/10
136/23 137/5
documents [3] 68/14 69/23 69/25
DOD [1] 128/14
does [28] 13/6 41/18 50/22 51/20 58/12
58/14 58/15 67/9 67/21 67/22 68/15
69/13 72/10 72/11 82/20 93/15 93/18
100/7 106/14 111/8 126/6 126/8 133/12
133/16 134/6 135/7 137/7 138/25
doesn't [17] 8/20 17/8 21/10 21/12
31/12 32/16 38/7 41/19 42/7 45/13 56/3
74/18 105/19 116/2 119/11 127/18
132/17
doing [12] 22/16 35/6 45/24 61/1 78/25
82/3 128/1 130/16 133/20 134/22
134/22 137/9
DOJ [1] 5/12
don't [68] 5/12 7/3 7/11 7/16 7/16 9/18
11/19 12/3 12/9 12/23 13/5 14/10 14/16
15/13 16/14 17/12 17/15 19/4 19/13
19/17 23/3 24/19 27/5 28/20 33/3 37/18
38/2 38/14 39/5 40/3 40/4 40/14 40/24
42/3 46/17 46/24 46/25 47/4 52/13
52/22 53/4 53/23 54/7 54/22 56/16
56/22 58/24 59/7 59/22 64/20 69/17
69/23 69/24 73/21 75/5 76/2 83/3 83/21
88/18 95/9 96/15 96/21 99/14 107/8
118/4 119/6 123/19 140/6
done [11] 5/8 7/7 15/24 22/15 37/9
43/21 44/15 46/12 62/20 66/16 79/19
double [2] 105/5 124/15
doubt [1] 85/4
down [11] 18/1 18/12 18/13 23/1 26/5
30/11 46/23 61/5 79/3 108/14 137/24
Dr [2] 135/24 136/5
drafted [1] 15/25
drastic [1] 8/15
drastically [2] 8/10 8/17
drawing [1] 119/1
drive [1] 39/24
driver [1] 123/9
driver's [34] 7/16 9/2 28/12 29/6 57/13
57/24 58/18 73/6 87/8 93/14 97/2
107/14 111/1 120/4 120/13 120/23
121/16 122/7 124/23 125/14 125/21
126/3 126/5 126/7 126/13 126/14 127/7
127/11 127/18 128/5 128/21 130/18
130/22 132/1
drop [2] 47/16 47/21
dropped [2] 26/9 72/16
duly [3] 5/21 76/17 108/20
DUNN [1] 2/19
during [23] 79/22 80/7 83/10 83/11
84/13 84/19 87/4 87/6 91/15 93/8 95/12
98/15 98/21 99/8 101/11 101/12 101/13
101/17 101/21 101/22 102/4 104/2
136/5
duties [3] 78/22 78/25 80/23
DVORKIS [1] 2/11
E
e-mails [1] 96/5
each [5] 9/9 10/12 39/7 51/9 61/5
earlier [4] 6/22 55/11 70/8 78/2
early [14] 43/13 85/19 85/23 86/1 86/2
86/3 86/5 86/8 101/23 102/1 102/5
104/3 104/3 104/24
easier [3] 67/6 97/1 97/5
Easley [2] 77/7 78/2
edited [1] 61/3
educated [2] 12/7 12/15
education [1] 114/10
effect [5] 8/15 8/16 31/6 37/14 73/6
effective [1] 107/2
efficiency [1] 101/7
effort [1] 132/10
efforts [3] 85/8 87/2 104/2
eight [2] 125/1 129/17
146
E
either [14] 22/18 26/20 29/7 45/23 69/21
97/7 108/1 120/12 122/7 122/11 123/13
124/10 124/12 124/23
election [161]
ElectionNet [9] 22/22 22/25 54/1 55/12
63/23 64/2 66/1 66/3 66/5
elections [22] 10/2 10/2 11/14 39/20
39/21 65/5 65/15 77/10 78/12 79/2
83/10 85/15 85/24 87/6 92/1 97/7
100/16 101/25 102/5 102/8 110/14
126/22
electoral [1] 31/6
electronically [1] 70/19
eligible [3] 116/8 116/14 116/21
eliminated [2] 59/16 123/17
else [4] 19/2 19/5 46/24 73/19
embarrassment [2] 46/22 47/5
enable [1] 36/24
enacted [1] 111/11
encourage [2] 37/18 39/4
encouraged [1] 82/8
encouraging [2] 37/15 96/25
end [6] 11/9 23/3 62/4 105/16 130/20
131/23
ended [3] 56/4 91/21 100/25
enough [4] 37/10 44/18 56/3 86/23
entire [6] 13/25 67/16 114/14 114/25
118/19 118/21
entitled [2] 33/8 74/17
entries [1] 129/10
entry [2] 12/14 129/24
envelope [13] 17/22 19/18 33/18 34/8
34/9 47/16 47/20 47/20 47/23 48/12
72/16 72/17 72/17
envelopes [2] 26/8 72/15
environment [1] 36/10
equation [1] 123/25
ERIN [1] 2/3
err [6] 13/21 14/8 14/15 33/7 85/3 85/5
erring [1] 14/20
ESQ [1] 1/14
ESQUIRE [25] 1/15 1/15 1/16 1/19 1/24
2/1 2/1 2/2 2/2 2/3 2/3 2/4 2/4 2/10 2/10
2/11 2/11 2/12 2/12 2/15 2/19 3/1 3/5
3/8 3/11
essence [1] 28/1
essentially [2] 75/21 122/9
establish [4] 37/1 37/12 50/24 68/8
established [3] 38/6 53/17 68/4
establishing [1] 89/24
estimate [2] 61/11 61/14
et [3] 1/6 5/3 5/4
ethnic [2] 137/10 137/10
ethnicity [2] 113/17 137/12
even [24] 23/7 31/10 34/1 34/6 34/12
36/24 37/6 40/13 40/22 41/8 41/22 42/3
45/3 48/6 83/7 87/14 89/16 92/7 95/15
102/13 115/18 120/24 125/11 127/7
evenly [1] 104/13
event [1] 55/16
events [1] 7/23
eventually [5] 80/18 112/14 130/25
132/3 132/5
ever [18] 52/23 52/25 65/4 66/1 66/3
71/2 79/9 83/8 84/10 92/17 95/20 96/8
97/8 97/9 100/8 108/1 108/2 108/5
every [19] 14/10 24/7 24/8 26/25 30/11
30/13 32/12 33/5 34/18 35/2 36/7 36/9
42/22 80/16 85/17 86/17 100/13 102/15
129/10
everybody [6] 19/15 24/12 27/1 41/10
46/13 136/19
everyone [11] 38/6 38/20 38/20 38/25
45/1 59/15 115/12 116/20 122/20 124/1
134/15
everything [4] 78/25 79/1 79/3 79/19
evidence [2] 50/5 97/18
evolve [1] 39/3
exact [7] 9/12 92/20 124/25 125/5 125/8
125/11 131/14
exactly [5] 16/5 118/4 131/16 136/10
137/2
examination [15] 4/5 4/5 4/6 4/9 4/9
4/10 4/13 6/3 53/13 63/20 74/6 76/19
99/20 107/21 108/22
examine [4] 112/18 112/22 113/2 113/25
examined [4] 5/22 76/17 108/20 114/13
example [1] 38/3
examples [1] 15/2
except [4] 7/8 9/10 10/12 134/8
exception [3] 34/14 111/12 112/3
excerpts [1] 53/25
exclamation [1] 56/5
excuse [4] 10/17 18/18 75/25 114/10
excused [3] 108/13 108/13 108/15
execute [1] 20/13
executed [1] 50/25
executive [5] 78/10 82/15 82/20 94/7
94/17
exercise [2] 21/20 52/19
exhibit [20] 6/20 7/2 12/10 13/14 13/23
14/7 14/24 15/17 20/5 20/6 48/9 50/8
50/15 53/24 57/8 57/9 58/7 58/21
132/23 135/8
Exhibit 5 [1] 13/14
exist [1] 132/17
existing [1] 59/12
expected [1] 27/6
experience [11] 59/13 60/25 71/1 79/15
80/3 81/15 82/4 84/25 90/5 90/19
107/25
experiences [4] 87/1 89/3 89/19 93/2
expert [4] 109/6 109/17 112/8 135/14
expert's [1] 126/25
expertise [3] 110/4 110/5 119/1
expiration [3] 120/16 120/20 121/3
expired [7] 57/15 57/24 58/18 120/15
120/15 120/22 120/23
expires [1] 70/16
explain [2] 78/22 86/4
explained [1] 122/5
exposed [1] 37/22
express [1] 55/15
extra [5] 5/9 5/11 5/11 5/13 61/18
extract [2] 122/3 122/6
F
fact [17] 8/2 12/19 52/11 65/7 66/17
92/12 95/7 98/23 99/2 99/4 106/15
106/24 116/12 117/17 118/18 126/6
126/21
factored [1] 62/24
facts [1] 122/14
fail [1] 111/8
fail-safe [1] 111/8
failed [1] 115/25
fair [3] 8/18 62/5 86/23
fairly [1] 122/25
fall [2] 78/17 109/12
false [25] 23/14 29/24 31/22 32/19
32/22 33/1 33/11 33/13 33/16 33/20
33/25 33/25 34/7 34/14 36/21 36/24
37/22 40/3 49/23 50/3 50/6 50/11 50/16
51/24 66/25
familiar [8] 20/3 72/24 74/14 81/21
87/18 93/9 104/8 110/16
familiarity [1] 89/22
far [1] 5/14
faster [1] 62/7
fault [2] 24/3 24/6
favor [1] 13/21
favoring [1] 101/24
federal [5] 15/21 15/23 16/2 18/3 69/19
fee [3] 22/7 54/9 54/20
feel [1] 65/14
feeling [1] 22/23
feels [1] 26/12
felony [1] 67/14
felt [4] 81/18 86/7 97/4 104/8
few [9] 10/9 22/1 22/4 63/18 63/23
92/20 100/11 109/8 119/20
field [11] 1/15 120/16 120/20 121/8
121/10 123/3 123/4 123/7 123/14
123/24 131/6
fields [7] 113/13 114/2 114/7 119/22
120/6 121/13 125/7
fifth [2] 111/3 132/12
figure [11] 11/13 90/23 91/10 112/12
118/2 120/11 133/11 133/12 133/15
133/16 135/5
figures [1] 139/11
file [3] 112/24 120/12 123/24
files [3] 119/20 121/23 123/2
filing [1] 56/18
fill [3] 18/1 18/6 66/22
filled [1] 45/23
filling [1] 78/20
final [1] 59/10
finally [2] 48/18 56/15
find [2] 25/25 27/7
finish [1] 80/15
finished [2] 42/24 44/23
first [15] 20/1 35/2 62/4 68/12 68/18
68/22 69/12 69/20 77/10 77/23 101/10
113/25 124/3 125/7 128/6
Fitzpatrick [1] 55/10
five [9] 7/7 16/12 40/20 49/8 58/24 76/3
110/21 112/15 132/10
Floor [1] 3/9
Florida [1] 45/9
fold [2] 72/13 72/14
folks [5] 70/24 124/17 129/15 129/17
131/25
follow [14] 8/20 10/19 29/16 30/2 31/19
33/5 34/19 38/19 40/9 42/16 45/11
62/18 80/1 80/5
follow-up [1] 42/16
followed [1] 92/1
following [7] 25/11 25/12 43/7 70/7
75/13 82/9 94/22
follows [3] 5/22 76/18 108/21
fool [1] 55/8
for 2009 [1] 103/9
Foradori [3] 3/16 140/12 140/16
foregoing [1] 140/12
forget [1] 28/12
forgot [2] 28/13 106/6
forgotten [1] 67/7
form [16] 9/1 42/4 59/4 59/8 70/24 73/17
86/14 87/10 93/16 111/3 132/12 135/3
137/2 137/22 138/8 138/11
forms [15] 32/7 39/5 73/6 73/12 96/25
110/22 110/24 112/15 127/10 130/22
132/4 132/7 132/11 133/18 135/1
forth [1] 102/15
forum [1] 101/2
forward [3] 26/3 65/12 134/23
found [1] 130/16
foundation [7] 2/16 2/20 84/2 87/23
88/20 90/3 90/17
147
F
four [12] 72/2 82/25 83/1 83/4 83/6
112/14 130/22 132/4 132/7 132/10
133/18 135/1
frame [1] 83/17
franchise [2] 21/20 52/19
fraud [4] 83/24 97/8 103/10 103/22
free [4] 7/18 93/21 93/21 136/11
FREEMAN [1] 2/4
frequently [1] 66/5
Friday [39] 5/10 20/21 20/25 21/4 22/5
23/11 23/17 25/12 26/15 26/20 30/12
32/2 32/4 32/6 33/17 34/2 34/6 34/10
36/18 40/12 41/3 42/19 43/8 43/9 43/14
43/22 44/2 44/4 44/9 45/14 45/18 45/19
45/20 46/11 46/20 48/20 52/21 58/16
60/4
from 2004 [1] 100/23
front [3] 29/24 87/5 88/19
full [9] 76/21 92/4 92/6 97/13 108/24
113/14 113/15 120/3 120/5
function [3] 118/14 119/9 128/15
funding [2] 66/2 66/4
funds [1] 65/12
further [3] 74/2 99/14 107/17
future [4] 35/5 38/11 39/19 70/14
G
GA [1] 2/18
GARRARD [2] 2/10 107/23
gave [1] 57/21
general [11] 1/22 1/23 25/12 43/7 44/1
44/2 49/5 51/1 51/6 57/21 65/10
General's [2] 50/15 54/24
generally [5] 26/24 112/10 113/11
117/24 119/18
generate [3] 62/21 63/11 103/2
Georgia [3] 109/4 109/11 109/12
Georgia's [1] 112/17
GERALD [1] 3/5
get [76] 6/10 7/17 7/18 8/5 8/5 8/7 8/21
8/21 8/23 9/6 9/21 10/9 10/10 10/13
17/16 18/21 21/13 21/17 22/24 25/14
26/14 26/15 26/17 26/25 27/4 27/10
27/23 28/14 28/17 29/18 29/22 30/6
31/10 32/7 34/18 36/12 37/16 38/15
39/4 39/11 40/11 40/21 41/3 42/19 44/9
44/22 44/25 47/9 47/9 47/24 48/19
48/22 51/21 52/21 54/23 56/24 57/5
60/16 60/21 63/4 63/10 66/15 69/13
70/2 75/4 79/5 81/4 91/11 93/21 97/22
99/11 107/6 107/12 117/9 136/2 136/21
gets [6] 21/19 24/15 25/19 27/13 48/24
126/14
getting [4] 17/15 30/16 37/8 39/13
gift [2] 97/19 97/20
give [15] 5/11 14/1 15/7 27/24 35/18
42/11 49/21 50/1 55/22 88/20 88/21
89/24 90/5 94/2 101/1
given [11] 15/10 15/14 26/21 26/23
28/21 29/6 52/11 53/17 97/19 105/9
119/7
gives [4] 14/24 15/2 47/11 52/18
giving [2] 11/5 99/10
go [48] 5/13 6/1 6/10 8/9 16/4 17/6
18/18 18/19 19/9 24/10 24/11 25/14
28/17 28/17 28/18 28/22 29/8 32/7 35/2
37/16 42/21 47/22 47/22 53/2 53/15
54/3 59/25 66/15 75/4 78/9 84/23 85/7
87/5 91/14 92/5 95/16 95/19 95/19
96/22 99/10 106/9 109/1 109/7 111/15
111/22 112/6 128/1 140/3
goes [4] 23/25 26/19 30/7 69/21
going [53] 10/23 11/13 13/20 17/6 17/9
19/16 20/23 23/1 23/13 24/5 24/19
25/14 27/24 32/4 32/12 33/7 34/1 34/17
35/17 35/22 36/3 36/20 36/23 38/24
39/1 39/7 39/15 42/10 42/11 43/19
43/20 43/20 43/21 47/2 47/4 47/24
48/22 50/8 56/24 57/8 57/10 57/12
57/14 58/8 68/7 88/21 106/18 107/24
109/7 133/23 136/2 139/1 139/7
gone [6] 33/17 36/16 36/23 37/8 37/9
45/22
good [22] 5/15 5/23 5/25 6/5 6/6 37/10
39/17 52/12 56/12 74/8 74/9 76/6 76/7
81/16 81/18 82/12 92/9 92/10 99/22
99/23 99/24 128/4
got [16] 15/19 18/11 22/17 25/5 26/3
28/12 29/7 31/15 40/20 46/23 48/10
54/14 62/19 91/9 130/25 136/25
gotten [6] 32/10 36/23 42/5 45/24 45/24
126/3
government [3] 69/22 110/22 110/23
government-issued [3] 69/22 110/22
110/23
Governor [5] 49/4 49/14 66/17 66/18
78/18
granted [1] 7/20
grassroots [1] 102/12
gray [1] 33/6
great [1] 119/7
greater [1] 138/18
greatly [1] 82/8
Green's [1] 78/19
grocery [1] 104/12
grounds [5] 23/14 49/22 51/24 59/21
88/1
group [1] 92/4
guess [3] 106/10 110/7 119/24
guesstimate [1] 62/6
guidance [13] 10/19 14/14 14/20 14/24
15/7 15/10 15/14 49/21 50/2 50/10
50/13 53/16 73/13
guide [2] 63/9 92/10
guideline [1] 68/11
guidelines [4] 13/11 21/16 82/9 100/1
H
H.3003 [1] 101/12
had [110] 5/16 8/9 8/12 8/13 12/21 26/6
32/6 37/6 37/7 37/9 51/22 53/16 57/17
57/22 64/8 64/10 64/10 64/16 65/14
67/1 69/12 69/16 70/3 78/9 78/24 79/12
79/17 80/21 82/19 82/25 83/12 85/12
85/17 85/24 86/2 86/3 86/4 86/5 86/18
87/1 87/11 88/14 89/25 90/7 90/24
90/25 91/6 96/1 97/10 97/18 97/19
97/20 98/6 98/7 98/9 98/17 98/20 98/23
99/4 99/9 100/13 101/16 101/16 101/25
102/5 102/6 106/3 106/20 106/21 115/4
115/7 116/22 118/6 120/4 121/22
122/16 122/17 122/21 123/1 123/8
123/13 123/14 124/18 125/11 125/14
126/2 127/1 127/4 127/8 128/10 128/12
128/13 129/15 129/16 129/17 129/19
130/7 130/8 130/11 130/13 130/15
130/16 130/21 130/21 131/2 131/25
132/4 132/6 134/9 134/25
hadn't [1] 37/8
Haley [1] 78/18
half [3] 72/13 72/14 123/24
hand [9] 46/3 48/2 48/10 48/11 48/18
61/8 87/8 87/25 118/17
hand-held [1] 87/25
handbook [2] 19/25 20/3
handed [3] 17/22 72/9 72/10
handle [2] 56/12 85/2
hands [4] 72/11 79/16 79/18 79/20
hands-on [3] 79/16 79/18 79/20
happen [9] 11/4 18/22 34/18 38/9 41/19
44/20 46/12 52/10 53/1
happened [3] 35/15 78/7 78/8
happening [4] 26/18 30/8 30/17 46/4
happens [7] 24/9 36/7 36/9 39/1 42/20
66/10 66/19
happy [2] 19/15 41/23
hard [1] 99/11
has [45] 9/19 18/1 18/11 18/23 22/1
22/2 22/15 23/19 24/9 24/12 25/17 31/5
31/12 32/2 32/23 36/16 36/16 38/25
40/4 44/6 44/8 45/1 46/23 49/22 53/16
55/14 58/1 61/25 63/5 65/4 73/8 74/5
95/11 95/11 98/20 99/16 100/8 106/7
109/5 110/19 111/4 111/5 120/12 128/4
137/3
hasn't [3] 73/8 89/21 89/23
hate [1] 33/23
HAVA [3] 74/14 74/14 74/16
have [276]
haven't [12] 14/10 15/14 15/22 15/24
17/2 19/8 19/14 22/18 36/6 38/12 39/16
60/12
having [14] 5/21 17/20 46/18 58/13
76/17 108/20 114/19 115/23 121/1
124/9 128/12 131/3 131/6 131/7
he [28] 11/6 53/21 54/8 54/11 54/23
65/7 65/7 65/8 66/1 66/8 66/9 67/1
72/11 73/15 78/19 83/17 89/7 95/9
98/19 98/23 99/4 105/13 105/16 105/25
106/6 106/13 106/15 122/6
He's [1] 95/9
head [2] 9/18 12/24
hear [7] 11/4 19/15 31/18 94/17 94/18
102/12 136/2
heard [6] 2/1 67/8 87/11 94/6 94/17
102/20
hearing [20] 23/11 25/20 25/23 26/20
26/22 26/25 27/4 27/11 27/25 29/1
32/11 42/18 45/12 48/20 48/22 50/5
52/22 86/2 94/9 98/22
hearings [7] 43/17 43/21 44/20 51/19
84/11 84/13 84/20
hearsay [4] 83/14 83/15 96/13 97/12
heavy [1] 70/17
HEBERT [1] 3/5
held [3] 71/14 80/17 87/25
help [11] 7/15 7/23 8/4 18/8 18/8 45/24
68/10 68/14 68/19 74/13 87/6
helping [1] 83/12
her [39] 16/25 56/4 88/3 88/4 88/7 88/8
88/9 88/12 88/14 88/14 88/20 88/23
89/2 89/5 89/9 89/10 89/13 89/14 89/17
89/19 89/22 89/24 90/4 90/5 90/9 90/10
90/13 90/16 90/18 90/19 91/5 91/5 91/9
94/12 94/15 94/15 94/25 95/5 95/13
here [22] 12/14 14/16 14/24 15/10 15/18
24/5 25/5 31/15 40/19 47/25 50/9 54/8
58/20 59/11 63/19 63/23 76/14 91/9
94/25 120/7 133/8 140/6
herein [3] 5/21 76/17 108/20
herself [1] 88/21
high [1] 66/16
high-profile [1] 66/16
higher [3] 7/21 71/19 71/20
highest [1] 7/9
Highway [1] 97/2
him [1] 66/10
hinderance [6] 86/17 107/5 107/8 107/9
107/9 107/11
hiring [1] 79/2
148
H
hiring/training [1] 79/2
his [10] 16/25 54/18 78/20 98/11 98/14
98/15 98/20 98/22 135/25 136/5
Hispanic [2] 138/6 138/10
Hispanics [1] 138/4
history's [1] 63/9
hit [2] 35/10 35/11
hold [2] 109/19 109/20
holder [1] 121/22
holders [6] 122/3 122/11 122/11 123/3
127/23 128/20
holding [1] 119/21
home [4] 28/13 28/17 28/22 67/7
honest [1] 51/21
honestly [1] 51/20
Honor [12] 6/2 13/17 14/4 63/18 76/7
88/8 89/16 90/1 91/12 95/11 107/20
108/11
Honors [3] 60/8 63/15 136/9
HOOD [13] 4/12 108/17 108/19 109/1
117/15 132/19 132/25 133/24 135/20
135/24 136/5 137/5 139/21
Hood's [3] 135/13 135/17 137/3
hope [4] 21/25 56/8 59/3 62/7
hours [4] 10/9 10/10 44/18 82/1
House [1] 92/5
how [56] 11/5 11/13 12/8 12/15 15/8
16/5 16/6 16/7 17/12 17/13 17/16 22/23
25/13 25/17 26/10 26/13 26/18 27/7
34/16 39/2 48/5 48/7 49/22 50/2 50/10
52/13 56/16 60/24 61/7 64/1 64/22
64/23 71/22 77/8 77/16 78/5 79/14
82/11 82/17 83/21 92/19 99/23 100/4
109/10 110/1 112/12 112/22 117/24
121/24 121/25 122/3 122/17 128/1
131/9 132/6 134/6
However [2] 100/4 105/11
huge [1] 46/22
hundred [2] 41/16 71/2
hypothetical [8] 30/15 32/15 33/23
33/25 36/14 38/12 38/13 41/24
hypotheticals [1] 35/16
I
I'd [4] 16/4 38/12 84/5 100/11
I'll [9] 52/25 53/7 59/24 60/3 91/9 95/10
97/16 113/9 132/21
I'm [58] 9/12 12/14 13/15 13/25 16/7
19/3 19/15 20/3 20/4 20/23 24/5 24/18
29/7 32/1 32/15 32/16 33/3 33/4 35/25
36/3 36/4 40/10 41/22 45/21 46/12
47/19 47/24 48/1 51/23 52/2 54/7 55/2
61/17 64/24 66/2 67/22 74/23 78/19
83/1 88/8 88/19 90/7 94/23 96/14
104/22 107/23 107/24 109/3 109/7
120/11 124/15 126/12 132/22 133/11
133/15 133/23 137/9 138/13
I've [19] 5/7 15/18 19/3 19/9 19/10 20/3
22/4 33/17 36/23 40/20 45/22 45/22
45/23 45/24 45/24 47/10 48/10 109/12
132/18
ID [155]
idea [3] 30/16 52/13 128/4
identification [14] 56/18 57/13 58/3
58/22 59/4 66/9 67/24 68/16 68/24 69/7
70/25 110/23 127/10 133/7
identified [10] 7/11 9/15 22/9 47/25
64/14 101/25 102/19 115/22 131/6
131/7
identify [14] 5/5 22/5 22/12 32/13 56/22
57/8 58/6 58/8 59/16 59/19 60/5 106/24
118/8 137/5
identifying [1] 22/12
identity [7] 37/1 41/2 52/6 68/4 68/5
73/2 73/12
IDs [15] 7/22 9/2 9/8 9/9 16/12 16/16
38/7 39/13 40/20 56/25 57/22 58/25
62/14 68/18 127/15
ignore [6] 25/2 31/3 31/5 31/10 33/2
33/4
III [3] 4/12 108/19 109/1
illiterate [2] 18/7 18/12
IM [3] 115/21 116/12 134/16
impediment [70] 8/25 14/25 15/3 15/6
15/8 15/20 15/21 16/6 17/7 17/10 17/15
17/21 17/22 18/2 18/9 19/17 22/2 23/7
24/18 24/20 25/6 25/16 27/5 28/15
29/17 29/24 30/12 31/4 32/3 32/8 32/18
33/10 34/4 34/7 34/13 36/21 37/2 37/8
38/7 38/16 38/21 39/1 39/12 41/1 41/14
41/25 44/13 45/13 45/18 45/23 47/15
47/18 48/1 49/18 49/23 50/3 54/21
55/21 56/9 66/23 72/7 72/8 87/21 89/23
90/17 94/8 94/10 111/12 111/17 111/19
impediments [2] 42/17 43/19
impersonation [2] 83/9 83/24
implement [1] 100/5
implementation [1] 110/20
implemented [5] 13/20 16/7 70/13 111/4
112/16
implied [1] 47/2
importance [1] 63/7
important [10] 44/24 81/19 104/17
104/20 104/24 106/18 113/13 113/14
129/23 132/9
impossible [1] 123/23
impression [1] 14/13
improper [1] 129/20
improved [1] 102/11
improvement [1] 67/4
improvements [1] 101/3
improves [1] 101/7
in 2008 [2] 13/2 71/23
in 2009 [4] 85/16 85/18 103/4 104/3
in 2010 [5] 86/23 87/15 103/15 103/19
103/21
in 2011 [1] 13/5
inactive [22] 113/1 114/19 114/23
114/24 115/1 115/3 115/10 115/17
115/19 115/24 116/11 116/17 116/25
117/2 117/8 117/12 118/3 127/6 133/4
134/9 134/15 134/19
Inc [1] 2/16
incident [1] 105/5
inclined [2] 48/6 48/7
include [13] 42/7 57/14 57/15 57/15
103/21 103/24 114/2 116/20 116/24
117/2 117/7 131/5 134/14
included [11] 50/17 50/18 57/19 71/6
103/10 103/12 111/13 112/14 115/13
116/6 129/5
includes [3] 133/3 138/1 138/4
including [5] 18/16 42/9 43/16 49/18
67/16
income [2] 114/3 114/9
incompetent [1] 67/14
inconceivable [1] 23/20
incorporate [2] 35/1 35/18
incur [1] 55/15
indentation [1] 138/3
INDEX [1] 4/2
Indians [1] 138/5
indicate [3] 61/14 120/14 123/8
indicated [8] 22/18 75/8 101/11 104/3
120/23 121/8 126/25 127/4
indicater [1] 132/3
indicates [1] 106/25
indicating [1] 12/15
indication [4] 22/23 25/21 128/12 131/2
indictment [2] 99/2 99/12
individual [9] 17/14 32/6 51/9 88/4
88/12 90/9 95/15 104/8 105/6
individually [1] 88/11
individuals [7] 115/14 123/25 124/1
124/5 127/1 127/4 127/22
indulgence [3] 74/1 93/24 99/13
inform [2] 39/12 39/18
information [17] 11/25 15/22 25/14 58/7
63/4 68/4 84/13 92/7 98/25 113/16
114/7 120/2 123/6 125/14 125/19
125/20 137/7
initially [1] 70/9
inner [1] 138/13
inserted [2] 72/15 72/17
insist [1] 125/5
insisted [1] 131/14
inspection [1] 73/20
instance [6] 34/18 39/6 97/11 122/14
123/16 125/10
instead [3] 82/3 91/8 140/8
instructed [1] 73/16
instruction [2] 79/10 81/24
instructions [3] 80/5 81/22 82/6
intend [1] 57/6
intended [1] 14/13
intent [1] 9/23
intentionally [3] 55/22 108/2 108/5
intercede [1] 25/4
interconnected [1] 122/1
interest [2] 110/4 110/5
interested [1] 92/2
Internet [1] 53/1
interpret [1] 51/7
interpreting [1] 10/23
interrupt [1] 33/23
interruption [2] 97/24 98/5
Intervenor [4] 5/4 12/10 13/14 58/7
Intervenor-Defendants [1] 5/4
intervenors [7] 2/10 5/13 13/13 88/1
94/21 99/15 107/24
Intervenors' [6] 6/20 7/6 50/8 53/24 57/9
58/21
interview [4] 115/7 115/12 115/16 122/4
intranet [1] 64/6
introduce [3] 103/13 103/24 109/9
introduced [2] 6/22 101/13
invalid [5] 123/15 123/18 123/22 129/8
129/13
invalided [1] 129/24
investigated [1] 97/14
invite [1] 17/17
invites [1] 16/23
involved [8] 35/19 77/10 78/12 79/1
81/11 100/12 101/20 101/22
is [350]
isn't [6] 8/17 23/21 40/16 51/25 74/16
89/10
issue [8] 31/2 65/23 66/2 66/4 66/25
88/20 103/4 118/16
issued [15] 7/3 7/12 7/18 9/2 58/9 69/22
70/18 73/7 97/2 103/15 110/22 110/23
127/11 128/21 130/22
issues [6] 21/23 63/6 85/22 86/20 96/18
110/6
it [284]
it's [73] 6/21 10/2 12/25 13/2 14/16
17/11 21/25 23/18 23/20 24/6 25/8
25/16 25/24 27/7 29/20 29/21 31/15
31/15 31/17 33/13 33/25 36/9 38/1 40/2
40/12 40/18 42/3 43/6 43/8 43/24 44/24
149
I
it's... [42] 46/17 47/1 47/1 51/6 56/9
61/4 61/5 61/5 62/9 64/20 70/16 70/17
72/7 72/9 72/10 72/19 72/20 76/3 89/17
96/19 96/20 97/1 99/11 105/18 105/21
106/4 106/10 106/17 110/19 111/23
122/25 123/23 129/13 131/21 132/15
132/23 134/2 135/17 135/18 136/24
137/6 140/6
its [3] 11/25 62/21 108/16
itself [1] 122/19
J
JA001085 [1] 132/22
JA001086 [1] 134/4
JA001088 [1] 135/18
January [6] 42/5 65/13 71/8 71/12 78/11
84/17
Jasper [1] 55/25
Jean [1] 66/18
JOHN [3] 1/12 125/9 138/13
Jonathan [1] 125/10
journals [1] 109/24
JUDGE [7] 1/11 1/11 1/12 53/12 76/8
94/20 136/18
judges [1] 5/7
judiciary [2] 92/6 92/6
July [2] 9/20 94/22
July 19th [1] 94/22
jump [1] 82/13
June [2] 71/5 71/15
jurisdiction [2] 68/13 68/17
jury [1] 63/13
just [81] 6/7 9/8 11/17 14/21 21/22
21/24 23/25 24/24 25/4 25/5 28/10 29/9
29/16 30/2 31/14 31/15 33/24 34/20
35/1 35/6 36/10 37/7 39/1 40/1 43/12
44/17 44/18 45/6 45/9 45/11 46/17
53/15 59/10 60/11 62/18 63/18 63/23
64/8 64/16 67/17 69/11 72/8 74/10
74/13 75/8 77/1 79/4 79/21 80/25 81/4
82/13 83/13 84/14 89/18 90/11 90/22
93/15 94/2 95/20 97/1 97/4 97/24 99/5
99/13 103/1 105/5 105/25 107/4 123/18
128/14 130/17 130/24 132/4 132/21
133/2 134/7 134/20 137/1 137/8 138/1
139/9
Justice [6] 2/5 3/8 66/18 74/4 99/16
99/19
justification [1] 103/1
K
KARL [1] 1/24
KAVANAUGH [1] 1/11
Kershaw [4] 55/4 55/7 55/11 55/18
kind [9] 6/25 9/11 9/15 9/20 15/22 36/2
97/22 99/2 99/12
kinds [1] 93/14
knock [1] 28/7
know [72] 5/12 7/16 7/16 9/18 9/19
12/23 14/16 17/6 17/8 17/9 17/13 17/13
17/16 23/3 23/22 24/2 24/5 24/25 25/10
25/16 25/17 26/19 27/5 27/7 27/9 27/13
28/19 32/10 32/23 34/17 34/22 34/25
36/4 36/11 37/3 37/13 38/2 39/17 39/23
40/14 42/3 42/3 42/18 44/19 46/17 47/1
47/4 52/7 52/10 52/22 52/25 57/16
71/17 73/19 73/21 78/15 82/23 83/21
88/18 96/15 107/8 110/1 115/12 117/15
117/22 118/8 123/15 125/24 126/6
126/21 131/1 131/9
knowing [1] 52/6
knowingly [1] 50/17
knowledgable [1] 102/9
knowledge [3] 18/3 106/4 118/21
known [4] 21/24 22/4 80/10 108/1
knows [3] 18/25 19/2 26/12
KOLLAR [1] 1/11
KOLLAR-KOTELLY [1] 1/11
KOTELLY [1] 1/11
L
lack [14] 26/2 29/23 39/20 87/2 91/7
111/9 133/20 135/4 137/21 137/21
138/23 139/5 139/23 139/24
lacked [1] 138/8
lacking [2] 138/11 138/15
lady [1] 83/13
laid [1] 61/5
laminated [1] 75/12
Lancaster [1] 56/7
language [1] 51/6
large [4] 87/4 102/3 102/4 107/5
larger [2] 72/15 79/17
largest [1] 9/10
laser [1] 9/24
last [9] 9/14 62/1 65/10 65/10 83/11
124/3 125/7 135/25 136/6
late [2] 65/10 114/1
later [4] 25/24 40/21 111/16 117/9
Laughter [1] 53/11
law [66] 12/19 12/22 13/8 15/22 15/23
16/2 17/5 17/9 17/13 18/3 18/23 20/14
20/19 23/18 23/23 24/12 24/14 24/20
24/22 27/21 28/20 28/23 31/5 31/11
32/25 33/5 33/6 36/11 40/10 40/16
40/18 40/19 40/25 43/4 43/10 45/16
53/6 55/8 59/18 65/4 65/24 66/11 66/13
66/19 67/10 69/19 70/13 74/10 74/18
74/25 81/25 96/5 100/7 100/9 101/13
103/13 103/25 106/22 108/2 108/5
111/5 111/10 111/11 112/17 127/21
132/13
lawful [1] 33/5
laws [3] 67/15 101/3 110/10
lawsuits [1] 55/19
Lawyers' [1] 3/12
layout [1] 104/9
Leach [1] 115/7
learned [6] 11/11 11/18 12/12 24/24
35/3 115/16
least [18] 22/1 37/22 52/18 53/19 54/11
63/9 65/22 75/2 83/24 88/18 90/24 98/9
100/13 120/8 124/22 126/2 130/16
130/21
leaving [2] 51/9 88/20
left [7] 33/20 39/1 72/17 104/4 128/5
130/24 133/8
legal [3] 3/5 25/2 45/4
legislation [13] 55/15 77/21 85/14 86/12
92/1 92/9 92/11 93/6 93/23 96/3 96/7
101/6 101/17
legislative [26] 81/1 81/2 85/8 85/12
85/16 85/17 86/9 90/20 91/19 91/20
91/22 91/24 92/3 92/23 92/24 95/20
100/22 100/24 101/14 102/2 102/15
103/4 103/6 103/9 103/15 103/19
legislators [8] 92/8 95/21 96/9 96/14
96/15 96/16 96/24 104/14
legislature [2] 55/22 110/19
legislature's [1] 102/24
legitimate [1] 105/18
lengthy [1] 42/23
less [1] 70/16
lessons [3] 11/10 11/18 35/3
let [13] 14/1 14/2 60/11 74/20 75/24
83/17 83/23 87/18 94/2 101/10 119/24
130/24 138/13
let's [16] 12/10 17/19 25/5 37/7 41/22
42/16 43/17 44/18 53/24 72/4 84/9
91/14 95/19 119/14 137/24 140/3
level [4] 11/2 89/20 114/10 114/10
levels [1] 81/20
lever [1] 19/10
levers [1] 19/13
Liberties [3] 2/16 2/20 3/1
license [37] 9/2 28/13 29/7 58/2 58/18
73/7 87/9 93/14 97/2 107/14 111/2
119/21 120/4 120/13 120/17 120/21
120/23 121/9 121/22 122/3 122/7
122/11 122/21 123/9 124/23 126/3
126/5 126/7 126/13 126/14 127/7
127/18 128/5 128/21 130/18 130/22
132/1
licenses [10] 7/16 57/13 57/25 120/14
121/6 121/16 123/2 125/14 125/21
127/11
lie [3] 25/16 37/16 37/19
lied [1] 37/7
lieu [1] 107/12
life [1] 77/9
like [28] 9/5 9/11 16/4 25/24 46/23
55/11 81/18 84/5 85/20 86/7 87/10
88/14 88/22 89/18 90/4 90/24 97/3 97/3
100/11 102/14 102/20 103/1 104/16
107/15 112/15 114/11 138/11 139/1
likely [8] 8/14 16/24 19/20 46/22 61/15
62/13 115/18 116/18
Likewise [1] 110/12
limit [1] 39/25
limited [2] 8/1 46/10
Line [1] 94/24
lines [1] 7/1
link [1] 123/1
Lisa [3] 3/16 140/12 140/16
list [41] 7/6 15/20 30/23 30/23 56/25
57/5 57/12 57/20 57/23 60/15 60/17
60/20 60/21 62/21 62/22 63/2 63/8
63/10 63/11 63/12 64/14 68/10 69/22
73/18 98/8 109/7 112/25 118/25 122/10
122/20 124/17 128/7 128/23 129/1
129/2 129/5 129/15 129/25 130/8
130/21 131/24
listed [7] 25/17 68/14 68/19 117/16
120/9 123/22 133/8
listening [1] 47/4
lists [3] 93/13 130/25 131/4
little [15] 5/9 5/9 11/9 29/16 60/3 61/17
61/17 62/18 63/22 73/3 79/14 80/14
121/21 133/20 140/6
live [1] 78/3
lived [1] 77/8
LLP [1] 2/13
lobbying [1] 104/2
local [2] 101/25 102/8
location [1] 104/3
lodge [1] 136/12
long [13] 40/2 40/3 60/24 61/7 77/8
77/16 78/5 85/10 100/7 109/7 109/10
136/16 136/18
longer [2] 89/2 89/3
look [9] 30/22 44/12 45/12 45/17 48/5
48/7 53/24 73/21 117/9
looked [1] 118/3
looking [3] 5/6 9/1 44/13
looks [1] 138/11
lot [6] 31/14 35/12 72/5 85/21 90/16
125/18
lots [2] 46/18 87/7
lower [2] 13/2 71/19
LUNCHEON [1] 140/9
150
L
luxury [1] 46/18
M
M.V [3] 4/12 108/17 109/1
MA [1] 109/22
ma'am [33] 33/14 50/1 66/12 67/20 68/1
84/21 97/15 100/3 100/10 100/13
100/21 101/5 101/9 101/16 101/19
101/22 102/3 102/14 103/5 103/8
103/14 103/17 103/20 104/6 104/18
105/3 105/8 105/10 105/13 105/20
106/23 107/3 108/1
Madden [1] 138/14
made [12] 25/22 26/9 49/19 88/3 94/14
102/1 105/22 119/24 121/9 124/17
128/23 136/19
magnitude [1] 12/25
mail [8] 56/22 61/10 68/12 68/15 68/20
69/20 75/16 86/14
mail-in [1] 68/20
mailed [5] 61/22 62/3 62/8 75/12 126/14
mailing [4] 57/6 115/25 116/1 116/1
mails [1] 96/5
main [2] 97/10 131/5
Mainly [1] 96/12
maintains [1] 54/18
majority [1] 49/19
make [26] 11/13 24/7 27/13 27/25 32/12
38/3 41/24 54/25 60/11 60/22 79/18
97/1 97/4 97/5 112/16 113/7 114/24
115/2 119/5 120/17 120/21 127/22
128/18 132/5 139/15 140/8
makes [1] 67/6
making [6] 35/20 44/14 52/5 55/8 61/1
104/12
man [2] 98/12 98/17
manager [29] 16/1 16/11 16/14 16/23
17/2 17/18 18/5 18/7 18/12 46/1 46/3
47/11 48/3 48/5 48/10 48/12 48/12
48/19 56/3 72/14 72/25 73/14 74/20
75/1 79/7 79/20 79/22 98/9 98/12
managers [26] 10/7 10/14 10/18 10/21
11/5 11/20 11/23 12/1 12/3 13/24 14/3
14/8 14/14 14/17 14/23 15/19 22/9
23/24 24/4 48/16 64/13 64/14 66/15
73/16 79/2 102/13
manner [1] 5/8
many [19] 10/4 12/3 64/1 64/22 64/23
82/17 87/5 87/11 91/9 92/14 92/19 96/4
110/1 112/12 117/24 119/8 128/19
129/9 132/6
map [3] 6/21 121/23 122/2
MARCI [2] 4/4 5/20
MARIE [1] 2/3
MARILYN [4] 4/8 76/12 76/16 76/23
MARK [1] 3/11
marked [1] 98/12
Marshall [9] 53/18 54/4 65/1 65/4 65/13
65/21 65/23 66/3 66/5
Marshall's [1] 54/22
Mart [1] 104/12
Mary [1] 34/17
MARZIANI [1] 3/8
massive [1] 85/25
match [28] 120/24 121/15 121/20 123/6
123/11 123/12 123/23 124/1 124/3
124/5 124/10 124/20 124/21 125/8
125/10 127/22 128/2 128/3 128/6 128/9
129/16 130/7 130/17 131/14 131/15
131/16 131/19 132/15
matched [6] 124/22 128/12 128/18
130/13 130/16 131/3
matches [3] 124/7 125/8 130/11
matching [10] 121/18 122/18 122/19
122/23 124/6 128/15 130/5 131/10
131/22 132/10
material [1] 136/13
materials [9] 15/11 15/25 35/5 72/24
72/25 73/4 79/6 79/7 79/24
math [3] 133/20 138/25 139/7
matter [1] 140/14
may [33] 7/22 8/25 9/1 9/3 9/3 9/17 14/4
17/3 18/3 18/22 18/22 19/22 21/3 24/11
26/6 30/10 32/6 32/10 33/22 38/9 38/9
39/24 46/7 62/20 102/10 111/13 112/4
114/1 115/22 115/24 115/25 117/20
136/9
maybe [9] 17/7 27/13 32/8 48/6 60/3
62/5 64/24 104/14 118/20
McCOMBS [1] 2/11
McGINLEY [1] 1/15
me [32] 10/17 14/1 14/2 16/12 16/22
18/18 19/5 19/18 29/24 32/25 33/24
46/5 46/14 47/11 57/8 60/11 75/24
83/13 83/23 85/11 87/8 87/18 88/19
94/2 94/13 101/10 106/18 114/10
119/24 130/24 138/12 138/13
mean [15] 9/17 11/24 31/14 34/24 41/12
47/3 69/1 69/2 69/15 123/19 126/10
129/15 132/3 133/8 138/25
means [5] 15/11 94/8 123/12 135/4
139/7
meant [2] 61/14 115/11
meantime [2] 36/22 36/22
measures [4] 103/10 103/12 103/21
103/24
mechanical [1] 3/25
meet [6] 25/9 25/11 33/5 42/22 44/2
44/21
meetings [4] 92/6 92/7 92/13 96/1
meets [1] 43/25
member [8] 49/14 55/10 78/15 80/8 80/9
100/13 100/15 100/17
members [10] 35/13 82/17 82/19 82/23
82/24 87/8 93/3 96/5 101/10 101/20
membership [2] 81/15 82/5
mentally [1] 67/13
mentioned [8] 13/19 45/7 74/13 79/5
85/7 85/8 102/21 134/16
message [1] 20/18
met [1] 126/19
method [7] 32/17 116/19 121/15 124/22
124/25 125/3 131/20
methodology [3] 121/19 122/5 122/20
methods [2] 121/18 124/21
MEZA [4] 2/3 4/6 4/9 99/22
MICHAEL [2] 1/15 2/10
microphone [1] 136/2
might [11] 22/23 29/22 34/19 45/4 46/24
109/8 111/14 112/12 116/21 125/24
125/25
military [16] 9/4 15/15 41/13 97/3
107/14 111/2 127/15 127/20 127/24
128/11 128/13 130/9 130/23 131/3
131/8 132/2
MILLER [1] 2/4
million [6] 118/1 118/5 133/12 134/12
134/13 137/18
MIMI [1] 3/8
minorities [1] 139/23
minority [9] 110/13 137/25 138/1 138/3
138/7 138/15 138/19 139/4 139/8
minute [3] 44/3 47/14 61/4
minutes [3] 5/11 5/12 76/3
misleading [1] 136/6
missing [1] 124/2
misunderstand [1] 69/15
model [3] 9/12 9/15 9/17
moment [6] 6/8 36/15 48/23 67/20 99/14
107/16
moments [1] 63/23
monitor [1] 85/15
months [1] 22/1
more [20] 36/14 38/13 41/22 41/24
44/24 70/20 79/17 79/18 82/2 85/14
86/15 90/16 104/8 104/9 106/4 106/13
106/15 115/5 122/24 139/12
morning [13] 5/23 5/25 6/5 6/6 43/13
74/8 74/9 76/3 76/6 76/7 99/22 99/23
99/24
most [10] 16/19 62/13 71/4 71/14 87/7
102/9 113/14 115/18 116/17 116/19
motor [10] 68/2 86/14 93/22 119/14
119/16 121/5 121/7 122/5 125/13
125/15
move [3] 14/2 84/5 140/7
moved [3] 115/23 126/2 126/4
moves [1] 5/14
moving [2] 90/21 134/23
Mr [20] 4/5 4/5 4/9 4/9 4/13 5/18 63/22
64/7 64/25 66/7 67/8 69/10 88/3 94/22
95/7 95/12 101/11 107/18 136/11
139/21
Mr. [9] 54/22 55/10 65/1 65/4 65/13
65/21 65/23 66/3 66/5
Mr. Fitzpatrick [1] 55/10
Mr. Marshall [6] 65/4 65/13 65/21 65/23
66/3 66/5
Mr. Marshall's [1] 54/22
Mr. Scott [1] 65/1
Ms [45] 4/6 4/10 5/16 5/17 5/17 6/5 6/7
14/3 14/7 19/25 21/24 29/16 31/2 35/10
40/9 45/11 52/17 53/15 56/21 58/6
59/10 60/9 62/18 63/14 63/22 67/8 74/2
74/8 75/25 76/13 76/21 77/6 87/17 88/2
91/14 91/23 94/22 95/11 97/6 99/14
99/23 99/25 107/17 107/23 108/9
Ms. [4] 5/24 12/11 13/19 16/5
Ms. Andino [4] 5/24 12/11 13/19 16/5
much [4] 36/4 79/17 79/20 80/16
multiple [1] 46/16
must [5] 15/20 24/1 24/1 49/11 93/13
my [55] 7/13 9/18 12/24 17/13 29/13
29/17 33/23 33/25 38/17 40/12 41/23
41/23 46/4 46/13 47/9 48/2 48/9 48/18
48/20 52/23 77/9 78/24 80/21 84/12
85/14 91/21 94/2 100/24 106/4 109/1
110/5 111/7 111/19 111/23 112/3
112/11 113/23 114/16 114/24 116/6
117/5 120/2 122/5 122/20 126/2 127/21
131/5 131/5 131/21 133/17 134/2 135/2
137/6 138/13 138/25
myself [2] 52/21 128/2
N
name [21] 30/11 52/7 76/21 98/8 98/11
108/24 109/1 113/15 120/5 122/14
124/3 124/3 124/11 124/12 124/14
125/3 125/4 125/5 125/7 125/7 131/19
names [2] 25/22 30/20
NANCY [1] 2/15
Nation's [1] 3/2
national [1] 55/9
NE [1] 3/6
nearing [2] 118/4 118/5
necessarily [2] 116/3 118/16
necessary [1] 16/16
need [14] 19/6 26/1 35/4 58/23 62/22
63/10 87/10 87/24 102/1 102/10 103/2
117/2 121/21 136/1
151
N
needed [5] 113/4 113/4 113/7 120/2
120/6
needs [3] 22/15 102/13 102/19
negative [1] 31/6
neighboring [1] 86/2
neighbors [4] 9/5 46/4 46/13 47/2
never [2] 71/3 86/16
new [9] 2/14 3/10 3/13 28/23 35/14
36/11 58/22 63/3 122/9
news [1] 87/11
next [4] 45/25 76/9 85/10 140/3
nine [3] 123/16 123/16 123/16
no [76] 1/3 7/7 8/6 10/19 10/20 10/25
12/9 13/10 15/16 16/3 16/20 18/11 19/8
21/17 21/23 22/13 23/10 24/3 24/13
24/17 25/3 28/8 29/18 30/15 33/19
33/20 33/23 40/18 46/21 48/2 48/8
51/22 53/8 54/17 60/14 60/19 61/16
66/13 66/24 67/2 71/6 72/19 72/23
75/18 76/25 80/6 84/2 85/10 86/22
87/23 89/2 89/3 89/16 95/7 100/10
101/16 102/22 102/23 103/1 103/14
105/13 105/20 106/3 106/11 106/23
107/17 108/3 108/6 108/8 114/5 114/9
114/9 118/12 119/10 129/19 132/15
nobody [1] 26/4
nomenclature [1] 115/21
non [10] 20/7 21/6 42/11 57/24 57/24
59/15 60/5 115/20 138/6 138/10
non-expired [1] 57/24
non-Hispanic [2] 138/6 138/10
non-photo [5] 20/7 21/6 42/11 59/15
60/5
non-provisional [1] 115/20
non-revoked [1] 57/24
none [4] 22/17 23/23 103/9 103/12
nonetheless [1] 123/12
nonexclusive [1] 15/2
nonissue [1] 67/2
nonwhite [1] 7/10
noon [1] 43/22
normally [1] 72/13
North [1] 77/7
not [198]
notaries [10] 21/11 21/16 22/10 22/16
22/24 54/25 56/3 64/11 64/13 64/15
notarize [3] 21/18 53/22 56/16
notarized [10] 22/3 23/8 23/18 23/19
24/21 25/6 31/4 31/17 45/25 47/9
notarizing [1] 22/7
notary [34] 18/21 18/23 18/23 18/25
19/24 19/25 20/2 20/5 20/6 20/11 20/18
20/22 21/2 21/5 21/8 21/13 21/23 21/23
22/5 22/14 23/4 24/3 24/7 24/8 24/19
24/23 31/13 45/22 47/10 53/22 54/19
56/17 59/3 59/8
note [1] 132/22
noted [1] 95/11
nothing [9] 10/24 14/19 24/11 24/14
33/20 54/15 74/2 108/11 123/13
notice [16] 25/19 26/4 26/14 26/15
26/17 26/21 26/24 26/25 27/4 27/24
29/6 39/6 39/7 39/9 39/15 48/19
notification [2] 62/14 75/18
notified [1] 64/11
notify [1] 56/21
November [4] 22/7 38/21 41/11 42/12
now [58] 8/7 10/1 11/9 13/11 14/23
15/10 15/17 16/4 16/22 17/5 17/19
18/21 21/4 21/10 21/22 23/6 23/10
23/19 24/25 30/2 32/3 32/18 35/6 45/21
46/20 48/18 50/8 52/5 53/15 54/11 57/9
58/20 78/3 92/15 93/9 95/3 107/1 109/5
110/3 112/7 113/10 115/4 117/15 118/6
118/24 121/11 123/10 125/13 126/6
127/10 129/7 130/10 132/25 133/2
133/11 133/15 134/11 138/22
nowhere [1] 99/11
number [42] 12/23 13/2 22/9 42/2 45/17
69/23 85/20 87/4 92/20 101/24 102/4
107/5 112/11 113/13 113/15 117/22
120/3 120/3 121/13 123/12 123/15
123/20 123/22 124/2 124/10 124/12
124/25 128/16 131/11 131/16 131/17
133/6 133/13 134/10 134/11 135/8
137/18 137/20 137/23 138/7 138/18
138/19
numbers [16] 70/23 85/25 122/13
122/24 123/18 128/7 128/10 129/5
129/7 129/14 129/16 129/21 130/1
130/6 131/14 139/17
NW [6] 1/17 2/6 2/17 3/2 3/13 3/17
NY [2] 2/14 3/10
O
o'clock [1] 24/2
oath [1] 37/22
oaths [1] 24/5
objected [1] 136/15
objection [18] 8/25 16/17 59/21 83/14
84/2 84/4 87/23 88/2 91/10 94/15 94/21
96/13 97/12 111/18 135/23 136/4
136/13 139/21
objective [1] 120/7
obstacle [1] 16/16
obtain [3] 93/19 93/21 111/21
obtaining [1] 16/16
obvious [1] 138/17
obviously [4] 87/14 123/21 123/23
129/20
occasion [7] 79/9 82/5 83/8 84/10 85/1
93/5 112/18
occasionally [3] 61/25 79/20 96/4
occupation [2] 109/2 114/11
occur [2] 125/24 125/25
occurred [3] 71/4 106/3 106/7
October [3] 62/2 62/3 62/5
of 2011 [3] 78/11 78/17 84/17
of 2012 [2] 71/12 113/24
off [2] 9/18 12/23
offense [1] 67/15
offer [7] 10/18 12/4 50/5 51/8 58/2 75/2
88/1
offered [3] 49/18 75/6 136/14
office [23] 6/11 6/12 6/19 28/25 32/10
38/15 54/25 68/6 70/18 70/19 78/24
80/17 86/17 86/18 87/5 104/21 105/1
105/4 105/14 105/15 107/6 107/10
107/12
offices [1] 85/25
official [10] 3/16 22/19 22/21 55/7 55/18
90/5 90/18 91/1 91/4 99/7
officials [17] 12/21 13/7 14/8 14/14
14/18 25/2 54/15 55/4 67/24 80/10
80/13 81/9 87/22 101/2 101/25 102/8
122/16
often [3] 22/25 38/2 41/20
Oh [1] 44/8
okay [40] 6/10 13/4 16/7 19/11 25/13
27/10 27/17 28/3 29/13 30/24 38/18
40/7 50/21 50/24 58/4 68/22 69/4 69/10
71/9 71/25 72/20 73/23 73/25 78/12
83/3 83/7 84/23 87/14 88/13 93/1 93/5
93/8 99/7 108/10 109/22 124/17 131/23
135/10 136/22 140/3
older [1] 67/13
once [8] 7/19 53/7 55/14 57/5 68/22
72/9 105/11 124/18
one [86] 6/10 7/24 8/1 9/10 11/18 16/12
16/14 16/16 17/16 18/22 22/19 22/21
23/15 24/9 28/11 29/7 30/13 31/19 32/7
32/10 36/14 37/3 38/7 38/12 39/4 39/13
40/1 40/20 42/15 46/21 46/25 49/11
49/12 49/18 50/13 53/7 58/24 59/10
62/18 66/17 68/2 68/5 68/13 68/18 72/7
75/12 81/17 85/20 87/10 93/25 94/3
94/9 94/18 97/10 99/14 100/13 101/1
101/24 106/4 106/13 106/15 110/21
112/11 113/14 114/22 115/4 117/6
118/15 121/18 122/1 124/15 124/22
124/25 125/19 129/10 130/17 130/21
131/17 132/4 132/7 133/18 134/6
134/17 134/18 134/25 135/11
ones [1] 92/3
online [6] 11/20 11/22 12/4 53/2 72/24
73/5
only [37] 7/24 9/1 11/22 29/21 32/1
32/17 32/21 33/16 35/13 45/18 49/1
49/10 52/2 52/25 55/2 57/14 57/17
57/23 69/5 73/5 86/11 87/10 88/3 93/16
94/25 104/21 105/1 105/3 105/4 105/11
107/10 117/6 117/10 123/24 124/17
134/18 137/15
open [2] 24/1 34/8
opened [1] 23/23
opening [1] 44/13
operating [1] 14/21
operation [1] 79/21
opining [1] 88/15
opinion [21] 50/15 51/2 51/7 54/24
87/17 87/20 88/7 88/9 88/14 88/21
88/24 88/25 89/5 89/14 89/24 90/5 90/8
90/23 91/5 91/9 94/15
opinions [3] 94/6 94/9 94/17
opportunity [3] 74/5 78/9 96/2
opposed [3] 88/21 94/11 105/3
option [1] 93/20
Orangeburg [1] 7/8
order [6] 6/10 8/21 43/14 65/14 74/21
120/19
organization [1] 81/5
organizations [1] 80/8
organizing [2] 80/25 81/2
other [48] 5/7 6/16 6/16 8/4 9/2 11/24
18/14 18/16 19/23 24/25 25/15 25/22
26/12 26/16 28/11 33/21 38/5 40/3 42/7
45/6 46/21 46/25 47/15 47/19 59/8
61/15 63/6 68/14 86/13 86/20 87/8
90/18 93/3 93/3 93/15 95/2 97/1 99/7
99/9 113/5 113/7 113/9 122/14 123/12
124/16 126/19 127/2 131/20
otherwise [2] 95/23 109/8
ought [1] 20/12
our [36] 9/19 20/25 24/4 30/15 35/1 48/4
55/8 60/25 68/10 70/19 76/2 80/9 81/2
81/12 81/12 83/12 85/19 85/25 86/2
86/11 86/17 86/18 92/5 94/20 97/21
98/16 98/21 101/24 103/3 104/1 105/14
105/15 107/10 107/12 118/21 136/4
out [55] 7/12 11/13 14/2 14/3 18/6 18/8
18/9 25/25 26/4 27/7 28/7 32/4 32/19
32/21 33/1 33/11 33/25 34/25 36/12
45/23 46/9 50/14 55/8 55/22 57/6 61/22
64/16 66/22 67/1 78/19 83/12 87/5
90/23 91/10 96/12 99/10 102/4 110/13
112/12 115/16 115/19 116/2 120/11
122/2 125/15 126/3 126/7 126/15 127/8
129/20 130/24 135/13 135/24 136/5
138/13
outcome [1] 65/20
152
O
outlined [1] 121/24
output [1] 124/8
outside [1] 6/19
over [8] 21/16 23/24 30/22 46/3 52/18
62/1 76/14 100/4
overcome [1] 32/9
overrule [1] 49/1
Overruled [1] 59/25
oversaw [1] 79/21
overseeing [1] 80/25
overseer [1] 79/18
overturned [1] 52/2
own [4] 16/25 88/23 90/9 94/25
P
p.m [2] 43/14 140/9
page [9] 1/7 4/3 12/11 12/11 15/17 20/6
54/3 88/5 94/23
paid [2] 10/9 10/10
paper [4] 70/17 75/9 75/17 105/14
parallel [1] 117/11
Pardon [2] 97/24 98/5
parlance [1] 129/8
parole [1] 67/16
part [7] 7/14 53/19 53/23 73/24 85/8
120/8 122/23
participate [1] 55/16
particular [4] 44/20 96/7 114/8 115/20
particularly [2] 16/6 62/13
partisan [1] 48/16
partitioning [1] 137/9
parts [1] 92/8
party [2] 49/10 83/18
party's [1] 83/19
passed [2] 65/11 110/19
passport [12] 9/3 93/14 97/3 111/2
127/19 128/10 128/13 130/8 130/23
131/3 131/7 132/1
passports [3] 41/13 127/15 127/23
past [2] 57/17 63/5
Peachtree [1] 2/17
peer [1] 109/24
Pennsylvania [1] 2/6
people [40] 7/12 7/15 7/21 7/23 8/5 8/7
8/9 8/20 8/22 10/4 10/7 12/25 18/14
18/16 25/1 28/11 30/3 31/8 33/5 39/23
42/7 42/10 44/19 47/2 47/5 56/25 57/14
57/16 61/9 64/1 64/22 66/16 85/25
86/15 86/16 87/7 99/9 99/10 115/5
124/15
people's [1] 31/6
percent [19] 41/17 71/2 71/11 71/19
71/24 133/16 133/17 133/22 135/2
135/5 136/7 136/7 138/24 139/2 139/6
139/8 139/12 139/13 139/25
percentage [14] 7/9 7/21 133/20 134/24
135/4 136/8 136/20 138/22 139/1 139/4
139/22 139/23 139/23 139/24
perform [6] 118/13 119/9 122/17 122/23
128/2 131/10
performed [7] 110/9 110/12 118/10
128/3 128/9 128/15 130/11
performing [1] 121/19
perhaps [2] 32/22 37/15
period [7] 21/25 44/15 62/12 83/12
84/15 84/19 91/16
permanent [3] 70/12 70/16 70/20
permitted [1] 39/14
perpetuity [1] 39/20
person [41] 9/5 18/24 19/22 20/11 20/13
20/23 20/24 21/19 23/4 26/5 32/2 32/13
32/13 32/16 32/22 34/3 37/1 37/13
51/16 52/10 52/13 56/12 56/18 59/17
59/20 60/6 66/14 67/1 67/22 68/12
68/15 73/12 73/18 93/18 98/1 98/2
110/21 112/1 112/2 121/1 126/18
personal [9] 81/14 88/7 88/9 88/23
88/25 89/17 90/9 94/25 95/5
personally [6] 22/12 22/13 23/5 60/20
90/6 92/12
persons [2] 7/11 126/21
pertained [2] 85/14 92/1
pertaining [1] 96/2
pertinent [2] 118/16 119/22
PETER [1] 2/12
Ph.D [2] 108/19 109/23
photo [69] 6/8 7/3 7/22 9/8 9/9 9/23
17/15 20/2 20/7 20/15 20/17 21/6 36/23
37/8 37/15 37/17 39/11 39/13 42/9
42/11 58/9 58/22 59/8 59/15 60/5 66/9
68/13 68/16 68/23 69/13 69/18 69/21
70/3 70/7 70/24 86/10 86/11 86/12
86/12 86/14 86/19 86/20 87/2 87/11
93/6 93/13 93/14 93/15 93/19 93/22
96/9 97/1 97/2 101/13 103/13 103/25
104/20 105/2 106/22 107/6 107/12
107/13 110/24 111/21 120/19 127/11
127/18 128/21 130/22
photograph [4] 19/23 69/23 70/9 70/14
photographed [2] 16/17 112/5
photographic [4] 110/22 111/3 127/15
132/14
physical [1] 113/16
Pickens [18] 77/15 77/20 77/25 78/1
78/3 78/4 78/5 78/21 79/4 80/3 80/7
83/8 84/22 84/25 97/7 97/10 99/8
107/25
picture [2] 70/19 73/22
piece [3] 92/10 96/3 97/20
pieces [3] 93/6 113/7 120/1
place [35] 10/13 16/8 23/24 23/25 24/1
24/8 25/21 25/24 26/1 26/22 27/8 28/18
28/23 33/1 36/5 37/13 39/2 39/7 46/8
46/16 55/1 59/1 64/12 66/8 66/10 69/6
69/16 75/19 90/25 98/11 102/10 105/1
106/21 107/1 107/1
placed [1] 98/7
places [4] 6/13 46/9 46/16 46/17
plain [1] 90/12
Plaintiff's [2] 132/23 135/8
Plaintiffs [3] 1/4 1/14 4/3
plan [2] 8/4 9/9
Planning [1] 81/2
plans [1] 7/13
plastic [2] 70/17 70/20
please [13] 31/3 64/1 65/9 67/20 76/14
76/21 78/22 81/14 91/23 95/25 99/15
107/16 108/24
pleasure [1] 82/20
plethora [1] 55/19
PLLC [1] 1/16
plus [6] 116/24 117/7 117/12 118/3
133/4 134/18
point [22] 1/20 8/8 25/7 56/5 62/19
66/17 69/13 69/14 90/6 111/16 119/7
122/25 128/4 128/25 129/11 129/19
129/23 130/17 132/9 136/19 139/22
139/24
pointed [2] 135/24 136/5
pointing [1] 96/12
points [3] 136/8 140/1 140/2
polarized [1] 52/12
policies [2] 100/5 100/6
policy [2] 21/5 110/8
political [5] 104/15 109/20 110/3 110/9
119/2
politics [2] 110/6 110/8
poll [81] 10/7 10/10 10/14 10/18 10/21
11/5 11/20 11/23 11/25 12/3 13/24 14/3
14/8 14/14 14/17 14/23 15/19 16/1
16/11 16/14 16/23 17/2 17/17 18/5 18/7
18/12 18/16 18/18 19/9 22/9 23/23 24/4
26/11 30/5 30/6 30/19 30/21 30/23
35/19 37/2 39/2 39/12 43/17 46/1 46/3
47/6 47/11 48/3 48/5 48/6 48/10 48/11
48/11 48/12 48/16 48/19 54/20 55/3
55/4 56/3 56/8 64/12 64/14 66/15 72/9
72/10 72/12 72/14 72/25 73/14 73/16
73/18 74/20 75/1 79/2 79/7 79/20 79/22
98/9 98/12 102/13
polling [24] 10/12 16/8 23/24 23/25 24/8
25/21 26/1 26/22 28/18 28/22 37/13
39/7 46/8 46/9 46/16 46/17 59/1 64/12
66/8 66/10 69/6 69/16 98/11 102/10
polls [8] 23/23 24/1 30/3 43/22 54/19
58/24 105/7 111/14
population [2] 6/24 7/10
portion [1] 58/21
position [17] 21/2 21/8 22/2 54/19 77/16
80/16 86/9 86/11 87/7 88/18 89/9 89/10
89/17 89/17 91/18 101/23 102/9
positions [1] 90/18
POSNER [1] 3/11
possess [3] 133/6 133/18 139/8
possesses [2] 66/8 127/19
possessing [1] 58/9
possession [2] 111/14 112/13
possible [9] 17/1 17/11 17/12 34/22
49/16 106/6 106/10 129/13 134/22
possibly [5] 8/19 17/10 17/13 107/13
126/3
post [4] 22/21 64/19 78/11 91/24
post-presidency [1] 91/24
postcard [5] 57/10 58/11 58/12 60/12
60/23
postcards [2] 60/13 60/23
posted [3] 64/8 64/10 64/17
postgraduate [1] 109/19
potential [1] 70/24
potentially [3] 7/22 19/22 46/10
POTENZA [1] 1/16
PPP [1] 66/4
precinct [1] 56/4
precincts [2] 10/6 21/12
preclearance [9] 7/19 38/8 41/11 55/23
57/2 60/17 60/19 61/7 61/24
precleared [6] 20/14 70/13 110/20 111/6
111/11 132/13
preclears [1] 60/18
preclude [1] 116/2
precluded [1] 94/8
precondition [1] 8/23
preferable [1] 45/3
preference [2] 65/13 71/7
prepared [2] 13/11 87/13
preparing [1] 79/1
preprinted [1] 61/4
present [8] 1/22 18/21 23/14 29/10
110/21 116/18 117/5 134/17
presented [8] 73/17 97/18 97/21 98/21
117/10 117/10 117/11 118/19
presenting [1] 93/1
presently [1] 138/8
presents [1] 18/22
presidency [3] 91/21 91/24 100/25
president [10] 80/19 80/22 80/23 81/2
81/5 82/4 85/10 85/11 91/15 100/19
presidential [4] 65/13 66/2 71/7 71/23
press [1] 55/9
pretty [5] 5/15 52/12 80/16 125/18
153
P
pretty... [1] 134/13
prevent [3] 10/24 99/4 106/15
previous [4] 11/14 101/17 101/18 134/8
previously [4] 5/21 85/13 107/4 134/10
primaries [2] 65/12 65/13
primary [8] 25/12 43/6 66/2 71/5 71/7
71/8 71/14 120/5
print [1] 9/23
printed [4] 17/23 60/12 60/14 60/23
printer [2] 9/24 61/5
prints [1] 61/4
prior [2] 69/2 91/20
priorities [13] 85/16 85/17 85/18 92/4
102/15 102/18 103/4 103/9 103/12
103/15 103/21 103/24 104/1
priority [6] 63/2 85/20 85/23 101/24
102/1 102/2
privacy [1] 18/4
probable [1] 8/15
probably [5] 10/3 38/3 64/20 102/9
140/6
probation [1] 67/16
problem [4] 16/20 90/3 90/3 96/22
problems [2] 11/1 91/9
procedure [9] 11/18 14/21 23/16 23/22
45/21 48/4 72/4 72/6 130/5
procedures [11] 36/12 47/25 48/13
48/23 53/19 87/21 100/5 100/6 102/10
106/21 107/1
proceeded [1] 122/8
proceedings [2] 3/25 140/13
process [29] 18/18 18/19 22/20 27/15
30/22 31/10 36/16 39/14 41/12 41/25
42/2 42/23 44/7 44/25 46/22 47/2 47/7
47/15 55/1 56/24 57/2 60/24 67/21
72/20 81/1 98/16 101/8 112/6 130/20
processes [1] 46/9
processing [1] 83/10
produce [7] 37/3 42/2 66/21 70/20 74/21
74/23 74/24
produced [5] 3/25 13/12 42/6 125/9
134/2
Profession [1] 109/3
professional [1] 80/8
professor [17] 108/24 109/14 110/3
110/9 110/12 117/15 118/18 127/4
132/18 132/25 133/23 135/13 135/17
135/20 137/3 137/5 139/21
profile [1] 66/16
program [2] 81/13 123/1
progress [2] 5/7 5/8
progresses [1] 5/10
progression [1] 134/23
prohibit [3] 53/21 54/9 54/19
promote [2] 100/1 101/6
proof [6] 18/24 21/10 21/12 23/13
111/24 112/1
proper [2] 32/16 122/6
properly [1] 79/19
prosecuted [2] 37/21 37/24
prosecutor [2] 98/3 98/4
protected [3] 15/21 15/23 16/2
protecting [1] 18/4
protocol [1] 122/2
prove [15] 19/6 19/18 20/11 20/12 20/23
20/24 21/6 32/5 32/20 34/2 47/10 50/16
59/4 59/5 59/8
proven [2] 32/22 41/2
Proves [1] 54/7
provide [14] 7/23 9/9 11/24 41/1 58/8
63/7 67/23 68/3 68/16 69/7 84/12 87/12
92/7 93/13
provided [8] 14/23 50/13 53/6 57/17
64/13 92/4 101/12 101/14
provides [2] 40/25 99/25
providing [2] 9/9 92/21
proving [1] 68/4
provision [6] 16/6 55/21 66/13 67/4
93/23 111/5
provisional [46] 12/8 12/16 25/20 25/23
25/25 26/22 26/24 27/2 27/4 27/11
27/16 27/18 27/24 28/14 28/16 28/23
29/1 29/9 29/12 36/16 42/17 42/24
45/12 47/15 47/19 49/17 66/20 72/4
72/6 72/9 74/17 74/19 75/2 75/6 98/13
98/16 98/17 98/21 98/22 105/9 105/15
105/17 106/25 111/15 111/23 115/20
provisions [3] 111/8 111/10 111/18
public [8] 7/1 7/8 7/17 25/22 26/5 26/9
47/1 104/10
published [1] 109/24
pull [2] 14/2 19/9
pulling [2] 6/21 14/2
purpose [9] 15/5 15/7 36/25 37/12 56/17
63/13 101/6 109/6 113/2
purposes [4] 44/17 59/17 59/20 101/1
put [20] 6/25 9/24 17/19 26/2 26/5 26/13
37/7 39/7 39/15 47/15 47/19 57/9 61/9
61/9 69/24 86/19 93/20 107/11 132/18
133/23
puts [1] 48/12
putting [4] 18/1 41/13 47/14 47/18
Q
qualification [3] 40/16 40/17 40/18
qualifications [4] 24/16 67/18 109/5
126/19
qualified [8] 40/10 40/13 40/14 40/22
41/8 67/9 67/22 115/1
qualify [2] 86/5 102/6
query [1] 123/6
question [11] 7/13 9/8 16/22 16/24 17/8
31/20 41/23 59/10 60/1 90/24 136/11
questioning [2] 35/12 101/11
questions [25] 16/25 17/3 29/14 29/17
30/3 31/20 38/5 40/10 41/10 45/12
62/20 63/18 66/6 67/8 72/5 74/5 79/9
95/10 99/15 99/15 100/11 107/17
107/19 109/7 109/8
quick [2] 9/8 130/25
quicker [2] 60/4 61/17
quickly [1] 63/8
quite [4] 22/25 79/16 92/20 119/20
quote [11] 7/18 7/18 15/19 51/1 55/8
55/9 55/14 55/19 55/22 55/23 56/7
R
R54 [62] 13/20 14/19 16/5 16/12 21/5
31/3 31/12 31/14 31/15 31/23 33/2
52/17 55/8 55/18 56/21 58/10 59/11
59/16 60/18 64/9 64/10 66/19 66/20
67/4 69/2 70/1 70/12 72/22 73/8 87/18
92/15 93/9 93/12 110/16 110/18 110/25
111/8 112/13 112/16 113/7 120/18
121/1 124/9 127/11 130/17 132/7
132/11 133/18 133/21 135/1 135/3
137/22 138/9 138/11 138/16 138/18
138/19 138/23 139/5 139/8 139/23
139/24
R54-type [1] 121/1
race [4] 113/17 137/12 137/21 137/24
racial [3] 82/24 137/10 137/10
racially [1] 52/12
ran [1] 123/6
range [1] 49/8
rate [2] 119/4 127/5
rather [1] 38/12
reach [1] 7/23
reaction [1] 87/2
reactions [1] 53/16
read [3] 11/4 14/10 18/8
reading [1] 94/23
ready [1] 61/9
real [1] 130/24
realistic [1] 38/13
really [11] 6/25 8/11 23/22 31/14 33/3
40/21 46/7 46/21 102/23 103/1 122/19
reason [11] 16/15 26/12 26/13 30/10
34/3 39/22 40/19 108/5 111/22 119/2
126/14
reasonable [78] 8/24 8/25 14/25 15/3
15/6 15/8 15/20 16/6 17/7 17/9 17/15
17/21 17/21 17/22 18/2 18/9 19/16 21/5
22/2 23/7 24/18 24/20 25/6 25/16 27/5
28/15 29/17 29/23 30/12 31/3 32/3 32/8
32/18 33/10 34/4 34/7 34/13 36/21 37/2
37/7 38/7 38/15 38/21 38/25 40/25
41/14 41/24 41/25 42/17 43/19 44/13
45/13 45/18 45/23 47/14 47/18 48/1
49/18 49/23 50/2 54/21 54/23 55/21
56/9 58/17 61/14 61/15 66/23 72/7 72/8
87/20 89/22 90/17 94/8 94/10 111/12
111/17 111/19
reasons [4] 18/2 86/6 102/7 112/5
rebuttal [1] 127/3
recall [18] 12/16 31/21 53/23 54/11
55/16 58/18 63/24 64/19 64/20 64/22
65/1 71/10 73/21 80/4 83/3 85/9 85/18
92/19
recap [1] 11/10
receive [8] 62/7 62/14 75/9 75/15 81/10
97/8 97/9 119/15
received [17] 32/9 42/5 48/15 62/4
81/24 82/6 82/11 82/12 112/14 112/19
112/24 113/12 113/23 114/13 115/4
117/17 133/14
receives [1] 49/5
receiving [1] 99/1
recent [2] 71/4 110/14
RECESS [3] 76/4 76/5 140/9
reckless [6] 50/18 50/25 51/2 51/5 51/8
51/13
recognize [7] 12/11 15/5 53/25 132/19
132/25 133/24 135/20
recollect [1] 103/11
recommend [1] 101/2
recommendations [3] 49/5 82/1 97/4
recommended [1] 92/4
record [13] 76/22 108/25 109/16 120/24
132/21 132/22 134/3 136/3 136/10
137/1 137/2 138/17 140/13
recorded [2] 3/25 113/17
records [1] 118/6
recruiting [1] 64/12
redirect [2] 74/5 108/10
reduce [3] 8/10 8/17 8/22
refer [1] 11/10
referred [2] 10/14 11/6
referring [2] 12/14 86/13
reflect [3] 73/8 133/16 137/7
reflected [1] 137/13
regard [20] 50/18 50/25 51/2 51/5 51/8
51/13 66/3 67/24 70/7 72/5 73/2 73/11
82/5 86/9 87/17 87/20 92/15 93/6 95/10
124/9
regarded [1] 121/6
regarding [6] 65/5 66/1 96/9 110/10
114/7 115/6
regardless [2] 24/15 108/7
regards [1] 116/7
154
R
register [4] 42/10 67/10 69/17 69/25
registered [13] 7/2 40/17 42/8 67/18
68/8 69/12 86/16 86/18 115/14 116/5
116/12 126/7 126/12
registering [6] 67/25 68/2 68/17 69/20
78/25 86/15
registers [1] 68/12
registrant [6] 128/5 129/22 130/8 131/6
132/4 135/2
registrants [67] 112/12 113/15 113/17
114/3 114/8 114/10 114/17 114/19
114/25 115/1 115/17 116/4 116/10
116/17 116/24 116/25 117/3 117/6
117/8 117/11 117/12 117/16 117/24
118/1 118/22 118/25 119/3 121/15
123/10 123/13 127/6 128/8 128/10
128/12 128/19 128/23 129/25 130/7
130/18 130/21 131/2 131/24 132/6
133/3 133/4 133/6 133/13 133/17
133/22 134/9 134/11 134/14 134/15
134/24 137/8 137/9 137/15 137/20
138/4 138/7 138/10 138/15 138/18
138/19 138/22 139/5 139/8
registration [63] 6/8 19/23 20/7 20/16
21/6 28/14 28/25 30/23 42/8 42/12
58/25 59/15 60/5 64/4 67/21 68/6 68/7
68/15 69/6 69/15 69/24 70/8 70/18 73/7
75/19 77/14 77/20 77/22 80/9 80/13
86/13 86/14 86/19 87/9 93/16 98/8
101/3 101/7 104/21 105/2 105/4 107/6
111/3 112/24 113/6 114/14 115/15
117/19 117/23 118/22 119/8 120/12
123/5 123/7 123/8 124/4 126/9 126/11
127/16 131/5 132/14 133/14 137/11
regular [2] 9/5 72/8
related [4] 76/24 77/2 110/6 119/20
relating [2] 90/25 114/3
relationship [3] 81/6 81/16 81/19
relayed [1] 105/5
relevance [1] 59/21
relevant [2] 59/22 88/4
religious [6] 8/25 16/17 111/12 111/18
112/3 112/5
remain [2] 126/10 126/15
remember [21] 7/4 8/10 8/12 9/20 10/15
12/8 20/24 20/25 21/1 21/7 23/8 46/11
56/5 56/9 56/13 56/19 73/24 85/19
103/23 118/2 118/4
Remind [1] 91/15
remove [1] 129/22
removed [1] 129/23
removing [1] 85/20
repeat [2] 49/25 60/1
repeatedly [1] 39/25
report [14] 12/20 13/3 42/6 97/8 97/9
97/14 109/17 126/25 127/3 134/2
135/14 135/18 137/3 137/6
Reporter [2] 3/16 3/16
reports [1] 99/7
represent [3] 13/6 107/23 133/12
Representative [1] 11/4
representatives [1] 100/12
representing [5] 18/17 18/18 23/15 30/3
47/6
Republican [1] 49/12
Republicans [1] 49/15
request [1] 60/20
requested [2] 98/7 98/9
requesting [1] 63/12
require [4] 10/19 20/15 33/3 110/20
required [17] 6/9 16/12 19/4 28/4 38/7
43/1 56/21 58/25 64/11 65/11 66/22
68/23 75/1 75/16 81/10 87/12 87/14
requirement [4] 49/10 86/21 87/3 96/9
requirements [9] 25/2 31/3 31/5 33/2
33/4 45/4 58/23 59/12 93/11
requires [8] 12/19 24/20 24/22 24/23
31/10 55/15 69/19 120/18
requiring [2] 8/7 86/12
requisite [3] 62/14 74/11 74/18
research [2] 110/10 110/13
reside [1] 77/6
resident [2] 67/12 68/9
residents [1] 6/23
respect [3] 14/19 49/10 97/17
Respectfully [1] 89/16
respond [3] 16/24 26/18 115/25
responded [2] 64/23 116/1
responding [1] 28/8
responsibilities [2] 78/23 80/23
responsibility [3] 84/12 85/14 92/5
restate [1] 104/22
result [2] 55/19 124/6
resumed [1] 5/20
retained [1] 112/7
retired [2] 78/11 101/16
return [3] 28/22 75/16 98/20
returned [3] 105/14 125/14 127/8
returns [1] 126/6
revealing [2] 83/17 83/18
reverse [1] 17/12
review [3] 43/20 93/5 109/24
reviewed [1] 44/12
reviewing [4] 42/18 61/1 96/6 98/16
revoked [4] 57/16 57/18 57/24 58/2
RICHARD [1] 2/1
ridiculous [2] 22/20 53/19
right [102] 5/16 6/11 7/24 9/3 9/11 10/4
11/2 11/11 11/15 11/20 11/23 12/1 12/2
12/5 12/14 13/21 14/1 14/25 15/3 15/12
15/15 15/18 15/19 16/9 17/10 17/24
18/10 19/7 19/12 20/8 20/18 21/14
21/25 22/3 22/8 23/1 26/8 28/7 28/9
29/19 30/4 30/8 30/13 31/17 31/24 35/6
39/7 41/17 42/13 45/14 46/1 46/5 46/25
47/21 48/3 48/13 49/24 50/11 50/18
51/3 52/8 53/19 53/22 54/5 55/5 55/9
59/1 60/10 61/2 61/3 62/3 62/23 63/16
64/18 73/8 74/4 75/10 75/24 87/16
88/16 95/9 95/17 97/16 99/18 117/4
117/13 120/10 120/19 122/18 124/19
124/19 124/21 125/1 126/16 132/16
132/17 135/5 137/16 138/20 139/10
139/15 139/19
Rights [2] 2/5 3/12
role [2] 80/14 91/14
roll [3] 114/14 126/11 126/16
rolls [1] 63/13
room [2] 3/17 46/8
roughly [3] 10/8 113/25 118/2
round [2] 139/9 139/13
rounded [1] 139/14
rounding [1] 139/16
routes [2] 104/10 104/11
routine [1] 104/12
routinely [1] 81/24
RPR [3] 3/16 140/12 140/16
rule [3] 12/8 12/16 85/5
ruled [1] 65/21
run [3] 10/1 23/25 117/18
S
safe [1] 111/8
said [21] 8/14 22/17 26/17 31/23 36/15
45/22 53/7 55/7 55/11 56/12 60/24
82/14 87/4 88/19 89/23 99/2 105/9
107/8 107/11 125/9 132/25
same [12] 47/22 77/3 77/4 84/21 104/19
104/23 125/11 127/5 135/9 135/11
135/17 139/16
Sanford [2] 66/17 66/18
satellite [1] 6/19
satisfactory [1] 21/10
Saturday [5] 25/8 36/18 43/23 43/24
44/22
saw [7] 11/14 85/24 86/7 86/16 86/16
86/17 134/7
say [24] 13/6 16/14 16/15 20/22 21/5
24/5 24/18 31/12 35/11 36/19 36/20
36/22 36/25 39/20 43/22 46/15 50/22
58/12 60/3 83/13 87/10 95/8 119/24
129/10
saying [8] 20/10 31/2 39/10 43/12 44/5
83/21 86/1 107/9
says [20] 10/21 13/23 14/11 17/19 17/22
23/17 24/12 24/14 25/16 31/15 31/16
38/13 40/18 40/19 47/20 51/22 54/8
58/22 73/15 95/10
SC [4] 1/20 2/22 126/14 127/8
SCARE [27] 80/10 80/11 80/14 80/19
80/24 81/5 81/15 82/4 85/7 85/16 86/9
91/14 92/25 93/1 96/24 100/11 100/12
100/15 101/1 101/6 101/10 101/20
101/25 102/15 103/4 103/9 103/15
SCARE's [1] 101/23
scholarly [1] 110/4
science [4] 109/20 110/3 110/9 119/2
Scott [3] 53/18 54/4 65/1
screen [2] 132/18 135/17
sealed [2] 72/19 72/20
SEAN [1] 2/12
seat [21] 6/11 6/12 6/17 6/19 7/18 8/7
8/9 8/14 8/21 8/23 9/6 17/6 29/3 29/8
29/18 29/19 29/22 48/20 51/21 51/23
52/21
seats [2] 6/14 8/5
second [12] 25/5 62/5 81/4 82/14 93/25
95/20 99/3 99/5 106/11 106/25 124/3
131/19
Secretary [1] 54/24
secretary's [1] 80/17
section [8] 2/6 14/24 15/18 20/6 50/15
51/1 58/20 59/22
security [33] 48/2 113/14 120/3 120/3
121/13 122/13 122/24 123/3 123/4
123/11 123/14 123/15 123/18 123/20
123/22 124/2 124/10 124/12 124/25
128/7 128/9 128/16 129/5 129/7 129/9
129/16 129/20 129/24 130/1 130/6
131/11 131/16 131/17
see [12] 14/1 14/10 16/5 44/8 48/5 48/7
54/8 85/1 86/20 103/2 120/8 140/7
seeing [1] 13/25
seek [1] 79/10
seem [2] 54/22 94/12
seen [2] 20/3 71/2
seldom [1] 86/15
SELLS [1] 2/2
Senate [3] 7/4 7/11 96/6
Senator [2] 6/22 53/7
send [5] 57/6 57/10 81/22 81/25 128/7
sent [10] 7/3 54/3 70/19 82/9 96/5
115/24 116/1 125/21 128/11 130/14
sentence [1] 67/16
separate [1] 46/8
September [2] 42/11 61/25
September 15 [1] 61/25
serve [2] 78/10 82/20
served [6] 67/15 77/20 80/16 85/12
100/19 103/18
155
S
serves [1] 75/18
serving [1] 78/13
session [4] 1/6 42/21 42/23 101/14
sessions [1] 101/17
set [5] 44/24 114/25 121/3 122/4 135/2
sets [3] 102/15 117/10 117/12
setting [2] 39/3 119/3
seven [2] 82/19 82/23
several [5] 11/19 21/25 45/6 66/16
110/24
she [22] 49/5 55/25 56/2 56/3 56/4 88/3
88/10 88/11 88/19 89/17 89/21 89/23
89/24 90/6 90/7 90/25 91/3 91/6 95/13
96/14 96/19 127/19
she's [11] 88/17 88/20 89/2 89/3 89/4
89/5 89/11 90/15 90/22 95/1 108/12
shift [1] 111/24
short [3] 38/8 38/23 39/11
should [24] 20/7 27/14 31/25 33/15
34/21 37/4 40/12 50/19 50/22 58/25
73/14 78/2 85/4 94/8 104/4 104/25
112/25 114/16 115/13 115/15 115/19
116/23 126/4 128/3
shouldn't [5] 47/3 94/16 94/18 119/7
126/10
show [25] 6/20 6/25 8/12 13/5 19/6
23/24 24/1 27/14 28/1 28/24 29/1 29/9
29/11 30/12 37/15 40/11 43/18 68/13
68/18 68/23 69/5 69/16 69/21 111/15
116/21
showed [1] 98/11
showing [2] 26/14 27/7
shown [1] 69/16
shows [3] 6/23 23/16 32/2
side [7] 14/8 14/15 14/20 33/7 85/3 85/5
96/6
sign [5] 19/4 93/19 96/2 111/22 112/5
signature [5] 73/17 73/18 73/24 85/21
102/23
signed [2] 31/12 111/23
signs [1] 73/18
similar [2] 112/5 112/6
similarity [1] 125/5
simply [3] 28/12 39/11 75/2
since [6] 18/11 29/24 36/22 42/5 100/15
109/12
single [5] 8/2 22/5 22/14 23/3 130/21
sir [40] 76/25 78/1 78/19 79/13 79/25
80/2 80/6 81/8 81/18 81/24 82/16 82/22
83/5 84/1 84/12 85/10 85/17 86/22
86/25 87/19 89/19 92/16 92/18 93/7
93/10 94/5 95/22 95/24 96/10 98/4
108/3 108/6 108/8 109/2 113/22 114/5
114/9 117/4 133/10 138/2
sit [5] 22/6 23/4 24/5 59/11 92/5
site [1] 64/6
sites [4] 104/4 104/9 104/14 104/24
sits [1] 48/23
sitting [2] 16/11 33/18
situation [6] 24/2 24/25 34/21 66/22
99/10 125/25
situations [6] 34/23 35/4 35/7 35/12
35/17 36/2
size [3] 46/8 46/10 49/8
slightly [2] 28/11 139/9
small [3] 78/24 78/24 117/22
Smith [3] 34/17 125/9 125/10
smooth [1] 54/25
snapshot [1] 118/20
so [182]
social [32] 113/14 120/2 120/3 121/12
122/13 122/24 123/3 123/4 123/11
123/14 123/15 123/18 123/19 123/22
124/2 124/10 124/12 124/25 128/7
128/9 128/15 129/5 129/7 129/9 129/16
129/20 129/24 129/25 130/6 131/10
131/16 131/16
socioeconomic [1] 114/7
solely [1] 131/10
solicitor [4] 97/21 97/25 98/1 98/25
solicitors [1] 38/1
some [60] 7/15 8/8 14/24 15/2 15/7
18/24 19/23 25/21 26/11 26/12 26/13
26/17 28/11 29/16 33/6 35/13 38/25
39/7 39/23 42/2 46/9 46/16 49/21 50/1
52/18 53/15 53/16 57/21 66/6 67/8
69/12 70/23 70/25 74/5 79/19 83/18
85/8 86/6 90/25 96/17 104/2 107/23
112/15 114/1 114/24 114/25 117/10
117/15 117/22 118/25 120/1 121/21
123/13 123/17 127/1 127/4 129/8
129/13 129/16 138/11
somebody [11] 19/5 22/17 25/14 25/15
25/25 26/11 26/16 27/12 28/6 38/3
43/17
somebody's [1] 58/2
somehow [2] 27/6 31/5
someone [17] 19/1 19/17 23/11 23/15
23/19 36/15 36/20 38/13 52/19 54/20
111/13 120/9 120/24 123/8 124/9 126/2
126/6
something [16] 22/10 24/8 26/6 36/5
36/15 39/25 47/16 61/15 64/8 64/17
68/7 87/10 92/2 107/14 118/11 139/1
sometimes [3] 11/3 36/12 55/11
SOP [1] 14/21
sorry [10] 13/14 13/15 19/14 47/16 54/7
55/2 66/2 67/22 74/23 104/22
sort [2] 26/17 69/13
sorts [1] 119/22
sounded [3] 88/14 88/22 90/24
sounds [1] 90/4
source [2] 19/20 135/17
sources [1] 113/5
south [70] 1/3 1/22 1/24 2/20 5/3 5/11
16/19 19/14 20/1 22/6 52/12 54/8 58/22
59/13 63/16 63/19 65/5 65/18 65/19
65/23 67/10 67/12 71/2 71/4 76/11 77/7
77/8 77/11 78/10 78/13 80/12 86/3 86/4
93/22 97/25 100/16 101/8 102/5 110/14
110/16 110/21 111/1 112/7 112/12
112/19 114/17 115/21 119/25 120/3
121/22 122/10 125/15 125/21 125/22
126/5 126/8 126/8 126/10 126/12
126/13 126/19 126/22 127/5 127/7
127/17 128/20 128/21 132/1 133/14
133/18
southern [1] 110/6
space [2] 46/18 46/19
Spartanburg [1] 55/13
speak [6] 88/6 91/4 95/20 106/8 106/10
139/17
speaking [12] 55/13 88/3 88/10 88/11
88/21 90/25 91/4 93/3 95/1 112/10
117/24 119/18
special [1] 43/7
specific [3] 9/17 9/19 14/11
specifically [8] 14/16 17/4 31/12 67/21
85/19 110/5 110/7 127/3
spelling [2] 77/3 77/4
spend [1] 10/10
spent [1] 63/22
SPITZER [1] 3/1
spoke [3] 9/14 20/21 86/7
squiggly [1] 6/25
staff [12] 9/19 10/2 10/17 55/10 64/4
64/5 78/24 79/17 83/12 87/6 87/8 98/16
stand [1] 5/20
standard [1] 14/21
standards [1] 100/1
standing [5] 24/17 29/24 46/5 46/13
114/7
start [3] 6/7 45/13 80/15
started [1] 100/15
starting [1] 131/23
state [131] 1/3 5/3 6/8 6/21 7/9 7/15
10/17 10/22 11/19 11/22 12/19 12/20
12/22 13/8 15/21 15/23 16/2 18/3 18/23
20/1 20/10 21/5 21/16 22/1 22/6 22/11
22/14 23/18 24/12 24/14 31/5 31/11
31/16 42/8 43/4 43/10 43/24 44/6 44/9
45/4 49/1 50/9 50/14 51/1 52/25 53/25
55/8 55/14 59/13 59/14 63/19 64/5
66/16 71/1 75/13 75/15 76/11 76/21
78/14 78/15 79/8 79/10 79/11 79/12
79/23 80/5 80/9 81/6 81/8 81/11 81/16
81/19 81/21 82/6 82/10 88/11 89/5 89/6
89/15 92/5 94/3 94/7 94/10 94/16 99/25
100/8 100/9 100/14 101/1 108/2 108/5
108/16 108/24 110/10 111/2 112/7
112/19 112/25 113/1 115/7 120/4
120/13 120/13 120/22 121/9 122/7
122/11 122/21 123/3 123/9 124/24
125/16 125/22 125/22 126/3 126/4
126/4 126/7 126/15 127/8 128/5 128/9
128/14 129/3 130/2 130/15 130/18
130/22 131/1 131/9 131/18
State's [1] 54/25
stated [1] 102/3
statement [3] 37/22 50/17 126/24
states [6] 1/1 1/6 5/3 67/11 86/2 99/22
statewide [1] 71/5
stating [3] 56/16 88/10 111/22
status [5] 64/10 114/19 114/22 115/15
115/24
statute [1] 90/6
stay [3] 42/21 42/23 113/10
STECIUK [1] 2/12
stenography [1] 3/25
step [8] 44/7 45/25 47/24 76/14 108/14
128/23 130/24 131/19
STEPHEN [1] 1/16
steps [2] 31/15 31/15
Stewart [1] 127/4
still [12] 24/9 33/12 33/18 40/22 41/6
41/24 60/6 69/17 74/21 78/12 96/17
126/18
STIRLING [1] 1/23
stock [1] 70/18
stop [1] 140/6
stopped [1] 5/16
store [1] 104/12
straightforward [2] 122/25 134/21
Street [6] 1/17 2/13 2/17 2/21 3/6 77/7
strike [3] 67/22 84/5 84/6
studied [1] 122/2
subcommittee [4] 92/6 92/13 96/1 96/5
submitted [3] 34/13 69/8 98/25
subsequently [1] 119/5
successful [1] 106/20
such [8] 85/24 104/10 107/14 118/6
122/14 126/18 126/21 135/4
sue [1] 52/3
sued [1] 65/7
sufficient [3] 59/16 59/19 60/5
suggest [1] 29/22
suggested [2] 17/2 64/12
suggestions [2] 10/18 81/25
suggests [2] 20/1 20/5
suit [1] 65/15
156
S
Suite [5] 1/17 2/17 2/21 3/3 3/13
Sullivan [1] 2/13
summary [3] 133/2 133/3 133/5
Sunday [1] 44/23
superimposed [2] 6/24 69/13
supplemental [5] 134/2 135/13 135/18
137/3 137/6
supplied [2] 129/2 130/1
supply [3] 104/20 105/1 125/14
support [1] 93/17
suppose [3] 11/1 23/15 43/17
Supreme [4] 65/15 65/17 65/19 65/22
sure [16] 9/12 13/25 27/13 27/25 36/4
54/25 60/3 60/11 61/1 64/24 79/18
88/19 90/7 104/23 128/18 139/15
surprised [2] 86/6 102/6
SUSAN [1] 2/19
suspended [2] 57/16 57/18
sustain [2] 84/3 91/10
swore [1] 67/1
sworn [3] 5/21 76/17 108/20
system [2] 31/7 53/5
T
table [30] 16/9 16/11 30/7 30/7 46/4
46/7 46/7 47/4 117/6 117/7 120/17
121/8 121/22 122/9 122/13 123/1 123/4
125/17 132/22 133/2 133/3 133/5 134/2
134/6 134/8 134/8 134/18 134/18 137/6
137/7
tables [12] 46/16 117/6 117/9 119/25
120/1 121/24 121/24 121/25 121/25
125/19 134/23 135/13
take [25] 7/20 12/4 13/5 19/5 19/18
20/23 20/24 21/2 21/8 23/24 24/1 38/2
39/2 47/11 48/9 53/7 53/24 57/3 60/24
63/3 66/6 67/9 76/2 86/9 131/4
taken [3] 22/1 42/3 63/5
takes [5] 25/24 36/5 46/16 61/2 63/9
taking [2] 35/6 44/3
talk [8] 38/12 67/20 72/4 82/5 84/9 96/8
119/14 136/1
talked [5] 5/7 10/14 22/16 23/6 38/12
talking [3] 57/23 84/15 125/20
talks [1] 51/2
TALY [1] 2/11
task [1] 112/11
tax [3] 54/20 55/3 55/5
Tech [1] 109/23
technician [1] 122/5
tell [26] 9/18 10/23 22/19 51/16 59/7
64/1 65/9 73/3 79/14 80/14 81/14 87/1
91/23 93/8 93/11 95/25 96/16 96/24
102/13 109/21 110/25 112/22 114/21
118/13 121/6 122/24
telling [5] 9/20 15/19 18/13 46/11 93/8
tells [5] 14/7 19/5 19/18 32/25 73/21
temporary [2] 70/15 70/16
tends [1] 54/23
tenured [1] 109/14
term [4] 78/19 78/20 80/21 123/15
terms [12] 10/1 14/20 18/9 41/10 44/13
59/22 73/19 81/15 87/21 119/11 134/11
139/24
tested [2] 9/13 9/19
testified [12] 5/22 70/8 74/10 76/18
91/18 95/12 100/19 101/17 107/4
108/21 120/7 121/11
testify [4] 92/7 92/17 109/6 128/14
testifying [1] 95/13
testimony [10] 11/5 40/21 53/9 53/13
65/2 92/22 101/12 101/15 104/2 119/11
Texas [2] 109/22 109/23
than [15] 13/2 25/22 41/22 61/15 61/17
62/8 71/19 72/15 93/15 97/1 99/9 106/4
106/13 106/15 138/18
Thank [22] 6/2 13/14 60/8 60/8 63/14
63/14 74/2 74/3 75/23 75/25 76/1 76/7
91/12 99/14 99/17 107/16 107/20 108/9
108/13 124/14 135/15 136/22
that [785]
that's [89] 6/12 7/25 11/12 11/21 12/2
12/5 13/22 14/16 14/21 15/4 16/13 17/1
17/25 18/10 24/24 26/11 27/15 30/17
30/18 31/18 31/23 32/3 32/13 32/18
32/23 34/17 37/9 37/14 38/10 38/15
40/16 45/15 47/4 48/25 49/13 49/16
52/24 53/6 54/11 57/1 57/7 59/16 60/3
61/13 62/12 63/12 64/18 66/19 67/1
67/3 68/10 68/20 70/11 70/15 75/23
77/25 88/5 88/16 89/7 89/9 92/24 93/16
93/17 105/3 107/10 110/7 111/5 111/7
112/9 115/25 117/4 117/14 120/11
120/20 121/3 121/3 121/14 125/23
127/21 128/22 129/22 130/3 132/7
132/9 132/13 135/6 136/23 137/17
139/7
the 2008 [7] 11/9 12/6 12/12 12/17 83/10
85/24 102/4
the 2009 [1] 103/12
the 2010 [1] 87/6
the 2011 [3] 12/20 13/3 101/13
their [52] 8/5 8/21 9/5 10/2 10/2 12/3
19/22 21/20 24/6 24/15 28/12 28/13
28/21 29/1 29/6 32/14 32/24 33/7 37/10
39/12 45/1 52/19 63/1 66/15 66/21 67/7
68/5 75/19 75/20 78/10 81/15 86/19
87/1 87/2 87/8 87/9 93/15 104/9 104/12
111/14 111/16 115/14 116/16 123/14
126/5 126/8 127/7 129/25 130/5 131/2
131/10 131/17
them [63] 10/15 10/19 11/18 14/23
14/25 15/2 15/7 18/6 18/8 18/8 18/13
18/25 19/6 23/2 24/19 26/12 26/19
28/21 33/3 35/14 36/24 37/18 39/18
42/20 43/19 43/20 43/20 44/20 47/22
53/17 53/19 54/9 58/3 62/7 63/2 63/6
64/14 73/21 74/20 75/2 75/4 86/4 86/6
86/16 88/15 91/5 92/10 93/18 93/20
95/23 96/2 96/19 96/25 104/13 108/7
111/21 116/2 116/7 119/3 124/10
124/20 124/21 125/19
themselves [3] 5/5 116/18 139/18
then [75] 5/16 7/22 10/9 11/25 17/19
19/5 19/17 20/14 25/24 26/20 28/21
28/22 28/23 28/24 32/23 33/11 33/16
34/19 36/17 36/24 37/3 37/3 37/9 37/16
38/11 39/19 41/1 42/24 47/11 47/14
47/21 51/1 51/19 51/19 57/23 60/23
61/21 62/3 62/15 63/10 64/22 66/7
68/13 68/22 69/13 69/21 71/14 72/16
75/16 77/18 78/7 80/18 81/1 85/13
88/13 90/16 90/21 90/22 91/21 92/5
93/19 97/16 98/6 102/13 105/6 105/14
108/12 111/15 117/11 125/8 126/13
128/11 131/4 133/20 135/4
THEODORE [1] 2/11
theory [1] 27/14
there [106] 6/13 7/7 7/9 7/13 8/14 10/6
10/7 11/1 11/1 13/7 13/23 14/7 14/12
16/8 16/15 18/14 18/14 18/16 18/16
19/2 21/11 21/23 21/23 23/10 24/2 24/9
24/12 24/17 25/20 26/4 26/10 26/11
26/24 27/11 28/5 28/7 29/10 30/3 30/21
31/10 31/14 31/20 31/22 33/6 33/18
33/20 34/2 35/4 36/5 41/12 43/1 44/7
44/14 45/22 47/24 48/19 49/11 50/8
61/24 62/19 67/2 69/25 70/23 70/25
71/9 71/14 72/5 73/13 73/13 78/5 78/10
80/16 82/17 82/17 82/23 85/4 96/17
99/1 103/1 106/11 111/10 113/13 114/9
114/22 115/17 117/18 117/20 117/22
119/7 119/20 120/16 121/8 123/10
123/13 123/19 123/19 123/25 124/7
125/17 125/18 127/10 129/13 129/14
136/24 138/3 138/10
there's [30] 7/19 7/21 10/24 14/12 14/19
19/1 23/22 24/3 24/9 24/11 24/14 26/12
27/8 30/15 33/20 36/11 46/8 54/15
54/25 60/17 62/18 66/13 70/15 87/23
90/2 102/22 102/23 111/11 132/15
133/3
therefore [4] 38/14 39/13 88/4 126/18
Thereupon [3] 5/19 76/15 108/18
these [50] 7/7 7/15 8/4 8/7 8/20 14/23
34/24 35/16 35/18 36/2 38/2 39/13
40/20 42/10 43/21 45/18 51/19 60/13
64/16 68/5 84/19 85/2 92/12 104/14
104/19 113/17 115/14 115/22 116/17
116/24 117/2 117/7 121/23 121/25
127/1 127/4 128/10 128/12 128/13
130/6 130/8 130/21 130/25 131/2 131/4
133/6 133/18 134/15 135/12 137/12
they [244]
they'd [4] 8/22 29/7 29/8 43/12
they're [3] 43/19 62/8 64/13
they've [6] 28/12 29/7 32/9 58/1 67/7
68/4
thing [5] 12/6 20/1 28/11 29/9 84/22
things [21] 7/23 11/17 34/24 35/7 38/2
39/3 45/6 46/23 50/13 82/1 82/3 85/20
97/1 97/3 102/14 102/19 102/20 103/1
112/15 121/21 129/19
think [58] 5/9 7/6 8/8 8/14 9/14 11/6
14/12 17/17 20/21 20/21 21/4 22/15
23/25 25/20 31/4 31/8 31/23 32/16
32/25 34/24 36/15 37/11 38/25 44/21
44/24 46/20 53/4 53/17 56/1 57/2 58/16
59/10 59/22 60/22 61/13 62/19 63/3
66/7 71/11 71/19 75/4 82/25 83/2 83/5
88/9 91/9 91/18 93/11 104/24 110/2
118/20 118/20 119/6 121/11 129/22
130/24 139/11 140/5
third [4] 54/3 83/18 83/19 135/16
this [138] 5/2 5/8 5/10 5/10 5/14 5/14
10/23 12/11 12/11 12/14 13/3 14/24
15/5 18/17 18/19 20/14 20/23 22/16
22/19 25/5 25/15 26/17 26/25 27/4 30/7
31/19 32/15 33/1 35/9 35/11 36/16
36/23 37/21 38/4 38/5 39/1 39/11 41/19
43/21 44/15 44/18 46/3 46/12 46/21
47/7 48/9 48/10 48/11 48/18 50/14
52/17 53/12 53/25 54/3 55/3 56/12
58/11 58/20 59/22 60/12 60/17 60/18
60/22 61/3 62/14 66/25 68/25 69/14
73/10 76/11 78/2 83/14 83/17 87/18
90/6 91/11 93/8 94/3 96/13 97/13 98/2
98/12 98/17 98/25 99/2 106/6 106/20
106/22 109/9 109/16 112/8 112/18
115/16 116/22 117/1 118/11 118/12
122/4 122/6 126/25 128/18 130/20
132/19 132/22 132/25 133/2 133/2
133/4 133/5 133/11 133/15 133/24
134/1 134/3 134/6 134/8 134/20 134/22
135/2 135/7 135/9 135/16 135/20
135/23 136/4 136/9 136/13 136/13
137/2 137/2 137/5 137/7 137/8 137/15
137/21 138/17 139/5 140/5
those [47] 6/25 7/23 8/22 12/1 13/13
14/11 22/12 25/22 26/8 29/13 30/13
157
T
those... [36] 37/15 48/22 57/22 57/22
61/9 64/8 65/15 68/18 73/4 80/1 84/13
96/11 102/18 108/1 108/4 109/21
110/24 112/14 116/6 120/1 120/5
123/17 123/25 124/1 124/5 127/14
128/7 129/7 129/20 130/14 131/25
132/4 132/8 134/9 137/12 138/7
though [11] 34/6 37/6 40/13 40/22 41/8
45/4 87/14 89/17 115/18 116/3 127/7
thought [10] 36/6 38/5 43/23 53/13 60/4
69/14 87/12 92/8 129/23 134/22
thousand [1] 83/11
three [14] 9/10 34/24 62/1 64/21 73/6
73/12 82/25 83/1 83/1 83/3 83/6 109/20
119/25 120/1
through [23] 16/4 23/7 24/3 34/23 35/2
36/16 39/14 40/25 42/19 42/22 53/15
68/2 68/5 69/22 77/21 91/17 100/25
102/19 109/7 112/6 115/16 117/1
123/17
throughout [5] 82/2 82/8 117/5 133/5
134/20
throw [3] 33/1 33/11 33/24
thrown [5] 32/3 32/19 32/21 34/25 35/17
thru [1] 1/7
Thursday [7] 25/11 26/14 26/20 40/11
41/3 42/19 43/7
tightly [1] 81/8
time [50] 5/9 5/13 9/14 13/5 26/1 28/24
37/16 44/11 44/15 44/18 45/16 48/15
48/16 57/21 61/18 62/12 63/22 67/1
68/12 68/18 68/22 68/25 69/2 69/12
69/20 76/11 77/20 80/4 80/7 81/22
81/22 83/7 84/9 84/15 84/19 86/11 87/7
90/6 91/15 93/8 99/8 101/16 103/6
105/17 106/16 111/16 114/1 117/17
118/21 119/7
timeframe [3] 38/8 38/23 39/11
timeline [1] 62/20
times [7] 87/5 87/7 92/7 92/14 92/19
96/4 99/5
timing [2] 5/6 60/12
title [2] 82/15 103/3
titled [1] 140/14
to 2010 [1] 100/23
Toal [1] 66/18
today [8] 13/2 35/12 45/7 59/11 59/16
60/6 73/6 109/6
told [33] 9/14 19/3 19/8 19/9 19/10
19/15 20/21 27/11 33/24 46/20 53/18
53/21 54/11 55/3 55/4 55/14 55/18
55/25 56/7 58/2 58/16 58/20 60/4 63/3
83/18 83/22 84/1 94/21 96/14 96/15
96/19 97/8 98/9
too [1] 91/9
took [3] 95/3 128/25 129/20
top [2] 9/18 12/23
topic [1] 31/19
total [6] 133/13 134/10 137/18 137/20
137/23 138/7
track [1] 85/14
Tracy [1] 78/19
train [1] 10/9
trained [5] 12/21 13/1 13/7 15/22 16/1
training [23] 11/20 11/22 12/4 15/11
15/24 15/25 34/23 35/1 35/5 35/18 36/1
72/24 72/25 73/5 79/2 79/5 79/5 79/7
79/8 79/20 79/23 81/12 82/6
trains [2] 11/23 11/25
transcript [3] 1/10 3/25 140/13
transcription [1] 3/25
transferred [1] 115/23
transparent [1] 134/21
transportation [12] 7/1 7/8 7/17 17/7
26/3 29/18 29/23 39/20 51/20 51/22
93/21 104/11
travel [1] 104/11
Trey [1] 109/1
trial [2] 1/10 6/22
tried [5] 49/21 50/1 85/3 92/10 102/24
trips [1] 104/12
trouble [2] 37/8 119/11
true [5] 25/17 27/17 33/22 50/6 74/16
truth [7] 50/18 50/25 51/2 51/5 51/8
51/13 51/17
try [12] 7/15 11/13 33/7 34/23 35/1
42/10 112/12 113/5 124/1 124/5 131/19
131/21
trying [10] 22/24 29/25 33/4 51/7 61/17
90/22 97/4 120/11 130/17 134/21
Tuesday [15] 26/14 26/19 32/2 32/6 32/8
32/17 32/21 33/17 33/22 34/4 34/11
36/22 40/11 41/4 43/22
turkeys [1] 99/10
turn [9] 12/10 13/11 15/17 24/19 110/13
115/15 115/19 116/2 126/5
turn-out [1] 110/13
turned [4] 66/14 74/11 75/3 105/15
turnout [11] 8/10 8/15 8/16 8/17 8/22
41/17 70/25 71/2 71/9 71/17 71/24
twice [2] 10/4 99/3
two [33] 5/7 5/18 6/8 12/1 31/15 44/7
57/3 57/5 61/3 61/11 61/19 63/10 64/20
75/21 83/11 99/5 101/17 105/16 114/23
115/20 116/11 116/17 116/24 117/2
117/5 117/7 118/3 124/4 125/3 128/23
134/9 134/15 134/18
two-step [1] 44/7
type [6] 47/22 81/6 118/10 121/1 125/19
131/22
types [2] 133/6 133/8
typically [4] 43/25 85/5 92/23 104/11
U
U.S [5] 2/5 3/17 127/19 127/19 127/23
unable [2] 39/10 130/7
under [39] 6/9 18/23 20/19 21/11 23/18
27/20 28/20 28/23 31/23 32/15 34/13
37/22 38/21 40/10 43/4 43/10 47/25
48/12 50/15 56/21 58/10 58/21 59/18
66/11 66/19 66/20 67/9 67/13 70/1
72/22 74/10 74/16 74/17 74/25 86/5
102/6 110/25 127/10 139/9
understand [14] 14/14 22/13 28/15
35/24 63/7 90/7 116/14 118/24 122/17
126/17 131/12 136/16 136/24 136/25
understanding [20] 16/20 51/12 111/6
111/7 111/17 111/19 111/24 112/4
113/19 113/23 114/12 114/16 115/10
117/20 120/18 126/2 127/17 127/21
131/13 131/21
understands [1] 136/19
undertake [4] 112/11 118/24 131/18
131/21
undertook [1] 130/5
unexpired [2] 78/20 120/22
unforeseen [1] 24/9
uniform [1] 82/2
uniformity [2] 82/8 100/2
Union [4] 2/16 2/20 3/1 56/15
UNITED [5] 1/1 1/6 5/3 67/11 99/22
universe [2] 114/16 118/21
University [6] 109/3 109/10 109/12
109/22 109/23 109/23
unless [13] 8/24 15/21 18/25 19/1 29/20
31/16 34/18 40/20 52/21 67/15 70/3
111/25 132/13
unlikely [1] 37/24
unmatched [5] 128/6 128/23 128/25
129/25 130/7
unreasonable [3] 20/22 21/2 21/8
unrequested [1] 11/6
unsealed [1] 72/18
unsolicited [1] 64/8
unsuccessful [1] 99/1
until [10] 42/24 45/14 52/22 60/14 77/17
77/21 78/11 84/17 105/17 105/21
up [58] 5/17 6/21 6/25 7/10 23/16 23/24
25/15 26/14 27/7 27/14 28/1 28/24 29/9
29/11 29/16 30/2 30/12 31/19 32/2 34/8
34/18 34/23 35/7 36/21 37/15 38/1
38/19 39/15 39/22 40/9 42/16 43/18
44/14 45/11 51/1 51/9 57/9 57/12 61/3
62/18 69/16 70/7 72/10 76/14 83/13
85/22 87/8 96/2 98/11 101/11 105/17
112/14 115/15 116/21 121/15 121/21
124/20 130/24
up-to-date [1] 115/15
update [2] 64/10 131/4
updated [2] 73/8 73/10
upon [6] 18/3 60/19 119/1 124/10 125/5
131/14
us [30] 9/14 9/20 13/19 20/21 44/22
46/11 46/20 58/2 58/6 58/16 60/4 63/3
65/11 65/12 80/14 81/25 86/18 87/1
93/8 93/11 97/19 102/13 102/25 107/9
109/21 110/25 112/22 114/21 122/24
135/25
use [23] 10/3 11/19 22/25 39/25 42/12
45/17 55/12 57/10 59/15 61/25 62/1
65/12 68/10 69/18 79/23 87/24 106/16
107/13 114/24 115/2 119/24 120/17
121/10
used [9] 37/2 51/6 58/13 62/1 79/7
120/20 121/15 121/18 124/3
using [10] 34/3 61/2 115/20 122/25
124/21 124/22 128/3 130/6 137/8
139/16
usually [3] 61/2 117/5 117/22
V
vague [1] 55/22
valid [23] 15/11 58/14 66/9 111/1
111/15 120/12 120/19 121/6 121/9
122/3 122/7 122/10 122/21 123/2 123/9
124/2 124/23 128/4 129/7 129/10
131/15 132/6 138/16
variables [2] 61/2 121/25
various [6] 80/17 81/23 93/5 93/14
96/25 137/12
vast [1] 80/3
Vehicle [3] 119/14 121/5 122/5
Vehicles [4] 93/22 119/16 121/7 125/15
Vehicles' [1] 125/13
VELANDY [1] 2/3
vent [4] 22/25 55/12 66/1 66/3
venting [1] 55/13
verified [1] 37/4
verify [3] 56/17 98/19 102/23
verifying [1] 18/11
versa [1] 83/4
versed [1] 20/4
version [2] 58/11 58/12
versus [2] 5/3 132/8
very [21] 36/10 41/20 42/23 62/25 63/6
78/24 81/1 81/8 81/11 81/18 81/18
83/10 84/7 86/15 92/2 92/2 99/11
101/22 102/4 107/24 107/24
vice [1] 83/4
view [17] 10/3 19/20 33/9 34/17 34/19
158
V
view... [12] 37/25 38/17 38/20 40/12
46/25 51/15 67/4 88/4 94/2 106/17
116/17 118/16
views [1] 93/1
violate [4] 31/11 100/9 108/2 108/5
violation [3] 12/22 13/8 45/4
vis [2] 130/11 130/11
vis-a-vis [1] 130/11
visual [1] 73/19
volatile [1] 36/10
voluminous [1] 125/18
volunteers [1] 10/15
vote [101] 8/9 8/13 8/21 9/4 10/7 19/3
19/8 19/10 19/15 20/12 23/17 23/21
24/12 24/15 24/15 24/18 24/21 25/21
25/24 27/25 28/23 31/9 31/23 32/4
32/14 32/20 32/24 33/8 33/8 33/10
33/12 33/16 34/2 36/24 39/14 40/10
40/12 40/13 40/18 40/20 40/22 40/22
40/25 41/6 41/11 42/12 45/1 45/17
45/21 48/24 49/19 51/22 51/24 52/7
52/15 52/22 52/23 54/7 54/20 58/13
58/17 59/15 66/14 66/20 67/9 67/10
67/25 68/10 68/14 68/19 69/12 69/20
69/25 70/1 70/3 74/13 74/17 74/19
85/25 86/1 86/6 86/16 87/2 98/13 99/3
99/10 105/7 106/5 115/16 115/19 116/2
116/5 116/8 116/14 116/18 116/21
116/21 120/19 126/18 126/21 127/19
voted [22] 19/14 30/11 32/2 32/13 32/18
32/21 32/23 33/21 34/3 48/5 48/7 52/13
98/7 98/23 99/4 105/6 105/11 105/14
106/13 106/15 127/1 127/5
voter [154]
voter's [1] 111/20
voters [38] 7/3 11/5 13/21 14/9 16/19
23/24 31/8 38/24 39/4 39/17 56/22 57/6
57/10 57/22 58/8 62/13 62/13 67/5 86/7
87/1 92/9 92/11 97/5 97/19 102/4
102/20 102/20 104/10 104/11 104/13
107/5 110/13 110/21 111/8 112/25
115/22 115/24 116/12
votes [3] 23/7 37/10 79/3
voting [35] 2/6 6/24 7/10 8/23 11/7 16/5
20/19 24/1 24/9 24/11 47/12 47/19 48/1
52/11 58/9 59/5 59/12 59/17 59/20
75/19 85/19 85/23 86/3 86/3 86/5 86/8
101/23 102/1 102/5 102/7 104/3 104/4
104/24 105/5 110/21
W
W-O-W [1] 56/4
wait [2] 44/3 62/21
waiver [1] 93/20
Wal [1] 104/12
Wal-Mart [1] 104/12
walk [5] 9/21 16/8 83/13 86/16 87/7
want [27] 6/7 6/20 9/4 11/17 13/5 13/11
13/20 18/9 21/22 24/17 27/13 27/25
31/19 37/18 53/15 54/16 59/11 59/12
66/6 75/5 81/4 82/13 85/7 96/15 107/24
113/9 138/17
wanted [5] 30/10 30/13 46/15 86/1 86/8
wants [3] 24/15 26/13 54/20
was [189]
Washington [7] 1/4 1/18 2/7 3/3 3/6 3/14
3/18
wasn't [8] 40/22 41/8 55/2 87/14 88/10
106/1 112/2 118/5
watch [2] 30/6 30/21
watcher [6] 26/11 30/6 39/2 39/12 47/6
48/6
watchers [7] 18/17 18/18 30/5 30/19
30/21 35/19 43/18
watching [3] 18/17 18/19 47/7
way [42] 7/15 10/1 10/2 10/22 10/23
11/22 11/24 17/8 18/11 19/10 22/18
23/10 27/8 28/8 29/21 30/15 32/1 32/21
33/21 38/25 39/17 46/12 46/21 46/25
52/2 52/25 56/12 60/3 70/13 83/3 83/17
83/23 85/1 85/4 87/18 91/11 93/19
93/19 102/23 122/6 124/15 132/15
ways [5] 12/1 13/20 48/16 82/3 134/17
we [167]
we'll [11] 7/20 14/2 18/21 24/7 34/25
39/4 54/24 81/4 95/19 117/9 140/7
we're [19] 5/10 6/21 14/2 21/24 32/12
33/5 33/6 35/6 35/6 36/3 40/19 48/22
51/7 57/8 61/1 90/22 125/20 136/2
139/16
we've [15] 5/8 7/1 7/7 7/10 9/13 17/20
22/17 24/24 37/4 53/17 57/23 62/24
91/9 94/6 102/19
webcam [2] 9/10 9/16
Wednesday [3] 37/9 41/3 43/13
week [8] 61/2 62/5 62/5 63/4 63/5 63/10
73/10 83/11
weeks [9] 22/1 22/4 34/25 57/3 57/5
61/12 61/19 63/10 64/21
well [54] 6/19 17/12 18/14 19/9 19/13
20/14 22/19 22/25 23/15 24/11 25/16
28/1 29/21 31/14 32/1 35/15 38/1 39/23
40/16 41/15 41/22 46/15 48/9 53/6 53/7
64/4 64/5 70/15 72/10 73/5 84/5 84/7
87/9 88/13 89/2 90/15 96/4 97/13 106/6
111/19 112/11 113/4 113/7 115/12
117/1 117/22 118/15 119/24 121/10
129/9 130/13 132/12 134/20 137/23
went [9] 26/3 37/1 78/19 95/7 96/1
98/19 99/11 100/17 123/17
were [96] 8/8 9/1 11/5 12/21 13/12
44/14 57/19 61/24 62/3 62/4 63/12 64/8
74/25 77/1 77/16 78/5 78/18 78/21
78/23 78/25 80/7 80/23 81/9 81/11 82/9
82/14 82/17 82/23 83/10 85/8 85/18
86/1 86/2 86/6 86/23 87/12 91/15 92/3
92/21 93/1 94/21 96/3 96/12 96/25 97/4
97/6 100/22 102/6 103/6 104/8 104/17
105/3 105/9 106/24 112/10 114/22
115/1 115/17 115/18 115/22 115/23
116/4 116/10 117/16 117/19 117/20
117/24 118/25 119/5 119/18 119/20
119/22 120/2 120/5 120/14 121/6
121/24 121/25 121/25 122/23 123/10
123/12 123/13 124/7 124/8 124/22
125/8 125/18 125/21 129/7 129/8
130/14 131/7 131/25 134/25 138/10
weren't [3] 64/16 71/6 130/14
what [151]
what's [2] 30/17 53/6
whatever [9] 8/1 28/17 30/10 36/19
44/12 44/14 45/17 46/24 126/13
when [47] 10/14 20/21 23/1 25/8 25/21
25/23 28/16 31/8 36/11 42/5 43/24
54/14 57/21 58/2 63/12 64/12 64/19
67/25 69/7 69/16 72/6 72/10 72/11
75/15 77/10 78/15 78/19 78/21 80/20
80/21 82/14 82/23 86/4 87/9 89/13
90/25 96/1 97/6 100/17 102/6 102/25
104/25 106/13 113/21 113/25 117/9
124/8
when I [1] 80/21
whenever [1] 44/23
where [21] 6/13 7/7 7/9 7/21 10/6 14/10
24/2 30/7 33/1 77/6 77/20 78/2 79/5
80/4 97/11 98/6 104/14 105/6 124/2
124/3 126/4
wherever [1] 28/19
whether [44] 5/12 17/21 21/17 21/19
27/5 27/7 46/21 49/17 49/22 50/2 50/6
50/10 52/6 52/15 52/18 52/23 66/25
72/7 73/11 73/14 77/2 81/21 87/21 98/2
104/20 104/25 105/18 106/17 116/23
117/15 117/18 118/25 120/8 120/21
121/9 123/8 124/20 124/21 126/21
128/10 131/2 131/7 131/13 132/4
which [32] 13/20 15/18 19/14 21/17
24/23 24/25 29/22 32/17 38/13 42/17
48/1 51/2 55/15 57/9 57/12 59/5 62/20
65/11 83/3 85/4 85/12 88/2 90/24 94/12
95/3 103/3 120/14 121/6 121/23 123/2
131/25 139/13
while [4] 14/2 46/4 46/12 57/11
white [12] 9/23 70/9 70/14 75/9 75/17
75/18 83/6 137/24 138/6 138/10 138/18
138/22
whites [2] 83/4 139/24
who [83] 6/23 7/3 7/11 7/16 12/21 13/1
13/7 17/20 18/24 19/5 19/6 19/18 20/11
20/12 20/23 20/24 21/6 22/6 22/9 22/14
24/14 26/4 26/12 27/1 28/11 30/11 32/2
32/5 32/13 32/20 32/23 34/2 37/1 37/4
37/12 37/15 38/7 38/13 42/7 42/11
46/22 47/10 51/22 55/7 56/22 56/25
59/4 59/5 59/8 59/17 59/20 60/6 62/13
67/22 70/24 73/15 86/16 102/23 108/7
111/9 113/5 115/18 116/4 118/8 120/4
120/11 123/11 123/13 124/17 127/18
128/4 128/6 128/25 130/18 130/21
133/6 135/4 137/21 137/21 138/23
139/5 139/23 139/24
who's [5] 23/4 30/16 39/10 54/4 57/15
whoever [1] 18/3
whole [12] 18/17 18/19 22/20 34/3 36/25
40/19 43/18 44/19 60/24 66/25 79/21
80/25
whose [1] 48/24
why [16] 32/23 76/2 85/23 92/8 93/17
94/8 94/13 94/16 94/18 104/7 105/3
118/13 125/24 125/25 134/17 140/6
will [62] 5/4 6/9 6/10 7/19 7/20 7/22 8/22
13/6 14/14 16/6 16/7 16/11 16/14 16/19
18/7 19/15 20/14 20/15 25/17 26/24
34/22 35/4 35/5 35/8 36/1 36/5 38/6
39/13 42/21 46/9 48/19 52/5 52/7 55/19
56/8 57/2 59/3 60/16 60/19 60/24 61/8
62/7 63/1 63/2 63/7 70/9 70/12 70/13
70/18 70/19 70/20 72/22 74/20 84/3
84/6 88/23 96/18 108/16 109/8 111/11
123/15 130/8
willing [5] 5/10 21/18 21/18 22/6 22/15
WILSON [1] 1/22
wish [1] 106/17
withdraw [1] 95/10
withdrawn [3] 10/17 47/17 48/11
within [7] 63/1 95/6 110/7 114/23
115/23 119/22 120/1
without [16] 13/25 19/23 20/16 20/16
37/15 42/9 69/18 74/11 83/17 83/17
83/19 83/21 89/24 137/10 138/18
138/19
witness [15] 5/21 19/1 76/10 76/17
85/20 94/3 94/23 94/25 102/21 102/22
102/24 108/17 108/20 112/8 136/11
witnessed [1] 83/19
witnesses [2] 4/2 106/17
won't [8] 20/11 20/15 20/23 21/13 53/9
60/14 60/16 132/12
wondering [1] 77/2
word [1] 14/10
159
W
words [6] 14/11 14/12 25/15 26/16 40/3
127/2
work [4] 16/7 36/11 43/13 54/24
worked [1] 106/21
worker [3] 72/9 72/10 72/12
workers [1] 56/8
working [4] 62/24 63/6 81/6 81/19
world [1] 30/17
worried [1] 36/20
worth [1] 27/7
would [157]
wouldn't [5] 32/23 39/25 57/15 69/14
75/1
wow [1] 56/4
write [5] 18/8 18/9 18/13 30/11 46/23
writing [2] 18/12 46/24
wrong [1] 65/23
wrote [1] 122/2
X
x113 [1] 3/4
Y
Yeah [3] 27/15 136/25 139/9
year [4] 65/10 65/10 85/17 102/15
years [4] 67/12 72/2 78/7 89/20
yes [246]
yesterday [6] 13/19 23/6 31/20 37/21
38/6 42/10
yet [6] 6/9 15/24 60/13 73/8 111/4
129/15
York [3] 2/14 3/10 3/13
you [544]
you'd [4] 5/17 28/1 41/24 76/13
you'll [6] 35/20 35/24 60/21 60/22 60/23
91/10
you're [38] 7/14 8/4 10/23 11/13 13/20
15/19 27/6 27/11 28/7 29/24 33/2 34/7
35/10 35/11 35/17 37/22 39/7 42/10
42/11 43/12 44/5 51/9 56/24 57/10
57/12 58/8 74/14 77/2 84/15 89/14
89/23 90/4 90/8 90/17 90/21 91/5
108/15 132/9
you've [16] 7/11 21/24 25/1 25/5 35/14
41/1 49/21 50/1 50/13 53/17 54/14
62/19 67/15 88/14 100/15 112/7
young [3] 83/13 98/12 98/17
your [107] 6/2 7/2 8/13 9/9 10/3 10/19
13/17 14/4 14/14 16/15 19/20 20/18
27/5 27/12 27/25 29/25 33/9 34/17
37/25 38/19 40/12 40/15 40/21 40/24
41/2 41/13 44/4 47/2 48/13 51/15 53/9
58/25 59/3 59/13 60/1 60/8 62/22 63/11
63/15 63/18 67/15 71/1 76/7 76/9 76/21
77/2 78/22 79/5 79/15 80/3 80/7 80/14
80/23 81/5 81/14 82/4 82/5 82/14 83/7
84/9 84/25 86/12 88/8 89/16 90/1 91/12
91/14 91/18 91/24 93/24 95/11 97/6
98/8 99/7 99/8 100/16 104/2 106/16
107/20 107/25 107/25 108/11 108/24
109/2 109/5 109/16 109/16 110/3 111/6
111/17 113/19 114/12 116/23 117/10
117/20 119/1 119/4 119/4 119/11 120/7
120/18 121/19 122/18 124/8 127/17
129/8 136/9
160

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