IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA
STATE OF SOUTH CAROLINA,
CA No. 12-203
Washington, DC
August 30, 2012
9:00 a.m.

Plaintiffs,
vs.
UNITED STATES OF AMERICA, ET AL.,
Defendants.
___________________________________

DAY 4 - AM SESSION
Page 1 thru 177

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

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
ALICIA AMDUR, 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

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
LISA GENN, 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

1
2

INDEX TO WITNESSES

3

For the Plaintiffs:

4

DR. M.V. HOOD, III

5

Examination by Mr. Dellheim
Examination by Mr. Beeney
Examination by Mr. Bartolomucci

6

Page

7
10
35

7
8

For Defendant-Intervenors:

9

DELORES FREELON

10
11

Examination by Ms. Abudu
Examination by Mr. Bartolomucci
Examination by Ms. Abudu

12

DR. BRENDA C. WILIAMS

13

Examination by Ms. Abudu
Examination by Mr. McGinley

53
61
75

77
90

14
15

CRAIG DEBOSE

16
17

Examination by Ms. Genn
Examination by Mr. Field
Examination by Ms. Genn

18

DR. ANDREW D. MARTIN

19

Examination by Ms. Marziani
Examination by Mr. Field

99
113
116

118
118

20
21

DR. KEVIN QUINN

22

Examination by Ms. Marziani
Examination by Mr. Harris
Examination by Ms. Marziani

23
24
25

124
131
146

5

1
2

P R O C E E D I N G S
HON. COLLEEN KOLLAR-KOTELLY: Good morning,

3

everyone. State of South Carolina versus the United States et

4

al. versus Intervenors et al., 12-CV-203. And two quick

5

business things. In terms of the time that remains, which is

6

building in the time that the Government originally ceded to

7

the intervenors back before we started the trial, the

8

additional 30 minutes for intervenors and South Carolina. So

9

South Carolina has four hours and 45 minutes left. DOJ has

10

four hours and eight minutes left. And the intervenors have

11

two hours and 14 minutes left.

12

We received just as we were coming on the bench

13

South Carolina's request for judicial notice, which in essence

14

is a motion. I don't see any discussion with the other side.

15

Are you aware of it from either side? I just want to see

16

whether you -- if you want to respond to it.

17
18
19

MR. BEENEY: We are, Your Honor, and we would like
to respond if we may.
HON. COLLEEN KOLLAR-KOTELLY: Okay. Then what

20

is -- what would you see as a reasonable timeframe for you to

21

respond? At least before the end of the trial.

22
23
24
25

MR. BEENEY: Is it all right if we submit it by the
end of the calendar this evening, Your Honor?
HON. COLLEEN KOLLAR-KOTELLY: That's fine, not a
problem, that's terrific. That would be great. Okay. We

6

1
2
3
4
5

were -HON. JOHN D. BATES: Does that go for both the
defendant-intervenors and the defendant?
HON. COLLEEN KOLLAR-KOTELLY: Does DOJ wish to
respond as well?

6

MR. DELLHEIM: We have not, in candor, Your Honor,

7

had a chance to review the state's submission, and we will do

8

so. And if we find it appropriate to respond, we will do so

9

by the end of the day today.

10

HON. COLLEEN KOLLAR-KOTELLY: Perfect, all right.

11

And then just for the court reporter, we're in the

12

cross-examination of Dr. Hood. Good morning, Dr. Hood.

13

THE WITNESS: Good morning, Your Honor.

14

HON. COLLEEN KOLLAR-KOTELLY: By counsel...

15

MR. DELLHEIM: Richard Dellheim.

16

HON. COLLEEN KOLLAR-KOTELLY: Let's proceed.

17

MR. DELLHEIM: Thank you very much, Your Honor.

18

One bit of housekeeping. And that is in our examination

19

yesterday I neglected to ask Ms. Velandy to check off one of

20

the types of ID that South Carolina accepts, and I would just

21

like to have her do that now. And I'd also like to mark these

22

demonstratives. So with the Court's permission, I'll have her

23

do that and we'll mark them.

24

HON. COLLEEN KOLLAR-KOTELLY: Yes.

25

MR. DELLHEIM: Thank you very much.

7

1

Thereupon,

2

M. V. HOOD, III, Ph.D.,

3

the witness herein, having been previously sworn, was examined

4

and testified as follows:

5
6

EXAMINATION CONTINUED
BY MR. DELLHEIM:

7

Q.

Good morning, Dr. Hood.

8

A.

Good morning, Mr. Dellheim.

9

Q.

I will do my very best not to keep you much longer. I

10

want to ask you about the reports submitted by the

11

plaintiffs -- excuse me, by the United States' expert, Dr.

12

Stewart.

13

A.

Okay.

14

Q.

You've had a chance to read the two reports that he

15

submitted in conjunction with this case?

16

A.

Yes, sir.

17

Q.

Now, it's true, is it not, that nowhere in any of the

18

three reports you've submitted in this case or in your

19

deposition testimony did you criticize or take issue with Dr.

20

Stewart's data matching methodology, correct?

21

A.

I don't think I directly addressed any of that.

22

Q.

Okay. And in fact nowhere in his -- in your reports or

23

your deposition testimony or your direct testimony did you

24

challenge any methodology that Dr. Stewart employed in his two

25

reports, correct?

8

1

A.

I think that's correct, yes, sir.

2

Q.

Now, I think we talked a little bit yesterday about

3

your appearance as an expert witness in the Billups case,

4

correct?

5

A.

Yes, sir.

6

Q.

And you did an absentee voting analysis in that case?

7

A.

I did a brief analysis in that case.

8

Q.

And the court rejected that analysis, too, correct? Do

9

you recall the court saying that your absentee voting analysis

10

was, quote, either unreliable or not relevant to the questions

11

the court must resolve, end quote?

12
13
14

A.

It's been quite a while since I've looked at that, in

all honesty.
Q.

And we talked also about the Wisconsin case. You just

15

recently served as an expert witness in the Florida versus

16

United States case as well, correct?

17

A.

That's correct, sir.

18

Q.

And the court there rejected the analysis you

19

performed, and it stated, quote, we reject the contrary

20

opinions of Florida's expert witness, Professor Hood. We do

21

so because the analysis underlying his conclusions suffers

22

from a number of methodological flaws, end quote. Do you

23

recall that, sir?

24

A.

I don't have it in front of me.

25

Q.

Have you read it?

9

1

A.

I've read most of it, yes, sir.

2

Q.

Does that -- the opinion came out just recently. Do

3

you recall reading anything about -- anything like what I've

4

just read to you?

5

A.

I recall something similar to that.

6

Q.

All right. Is it true that every court to consider

7

your testimony in voting cases, including the two other courts

8

in which you've served as an expert witness considering voter

9

ID laws, has rejected your testimony as an methodologically

10

flawed?

11

A.

12
13

I think in the Wisconsin case my testimony was

accepted, from what I remember reading.
Q.

Forgive me. Maybe I was inartful. I don't mean that

14

the court has thrown out or excluded your testimony. My

15

question was that in every case in which you have served as an

16

expert witness, every -- excuse me -- every case you've served

17

as an expert witness, including two voter ID cases, the court

18

has rejected, not accepted your analysis because in every

19

instance the courts found your analyses to be methodologically

20

flawed?

21

A.

I don't know if they, quote, used that term. Yes, I

22

mean, I think that's fairly accurate. I don't know if it used

23

the term methodologically flawed in all those cases, but...

24
25

Q.

Now, given the three reports you've produced in this

case and the Georgia analysis and everything else to which

10

1

you've testified, I have a yes or no question for you. You do

2

not know and you cannot testify to a reasonable degree of

3

scientific certainty that the gap in ID possession between

4

white voters and minority voters in South Carolina will not

5

result in a disparate impact at the polls, correct?

6

A.

Well, as I indicated yesterday, I don't think anyone

7

can. That's a future event; the law has not been implemented.

8

MR. DELLHEIM: I thank you very much for your time.

9

I have no further questions.

10
11

HON. COLLEEN KOLLAR-KOTELLY: All right. Mr.
Beeney.

12

MR. BEENEY: If I may, Your Honor.

13

HON. COLLEEN KOLLAR-KOTELLY: All right.

14

EXAMINATION

15

BY MR. BEENEY:

16

Q.

Good morning, Dr. Hood.

17

A.

Good morning.

18

Q.

Good to see you again, sir.

19

A.

You as well.

20

Q.

Dr. Hood, did I understand correctly that the point

21

that you are making with respect to your Georgia study that

22

you would like the Court to take is that the Court should be

23

careful about taking the results, the disparate results of ID

24

ownership, and applying that to any conclusion of what happens

25

at the polls?

11

1

A.

2

event.

3

Q.

Well, yes, using that to necessarily predict a future

And did I also understand you to say that the Georgia

4

study demonstrated that at least in Georgia the voter ID law

5

that was implemented between the 2004 and the 2008 elections

6

did not appreciably suppress turnout?

7
8

A.

Well, not quite. I don't think that's quite what we

concluded.

9

Q.

What did you conclude?

10

A.

Well, there was a depression in turnout that wasn't

11
12

racially disparate, was one of the conclusions we made.
Q.

But you agree the conclusion that you draw from your

13

data -- and putting aside all the questions that were raised

14

about your data -- but that one of the conclusions is that

15

your -- withdrawn. One of the points of your conclusion is

16

that you agree it stands in contrast to other researchers who

17

have concluded that ID laws do disproportionately affect

18

racial minorities?

19

A.

In fairness, our study is the only study I know of

20

sitting here right now that uses individual level data and it

21

has a before and after comparison point. Other studies have

22

come to that conclusion, but many of them have been based on

23

other types of data or they are looking at things before a law

24

has been implemented.

25

Q.

Doctor, can I direct you to page 248 of your deposition

12

1

testimony, sir. And specifically lines 8 through 13, which we

2

can put up on the ELMO, I believe. And if you're there --

3

A.

Okay.

4

Q.

Got it? "Question: Now, your contributions that

5

you've offered to the court in this case about your Georgia

6

results, they actually stand in contrast to other researchers

7

who have concluded that ID laws disproportionately affect

8

racial minorities, correct?

9

"Answer: Yes."

10
11

Were you asked that question and did you give
that answer, sir?

12

A.

Yes.

13

Q.

Now, I'd like to direct your attention to the charts

14

that you discussed with Mr. Dellheim yesterday, which is U.S.

15

demonstrative 179A, and ask you just a couple questions about

16

that.

17

A.

These handwritten charts?

18

Q.

Yes, sir.

19

A.

Okay.

20

Q.

We know that there are tens of thousands of registered

21

minority voters who do not possess the IDs that are required

22

by South Carolina Act R54, correct?

23
24
25

A.

Yes, we know that they don't have at least one of the

four forms of Act R54 ID, yes.
Q.

But we don't know whether and to the extent whether any

13

1

of those minority voters have any of the other IDs permitted

2

under the Georgia law, correct?

3
4
5

A.

No, I wasn't able to make that analysis. I don't know

the answer to that, sir.
Q.

And your Georgia study really is not a no-ID study,

6

correct? It's really a no-DMV driver's license ID study, is

7

that right?

8
9
10
11

A.

That's what we had data on, that's correct, on driver's

license or state ID card as issued by the Georgia Department
of Motor Vehicles, that's correct.
Q.

So you treated in your study all of the voters who may

12

have had any other kind of ID -- the 119 state agencies, the

13

valid ID by the U.S., Georgia, other states -- you treated all

14

those people as having no ID, is that right?

15
16
17

A.

Well, we weren't able to discern whether they had those

types of ID or not. I didn't have any data on that.
Q.

Believe me, I understand the limits of your data. But

18

the question is, given the limits of your data, you treated

19

people who had all the other forms of ID in Georgia as having

20

no ID, is that right?

21

A.

No. No.

22

Q.

How did you treat people who did not have a driver's

23

license --

24

A.

We had --

25

Q.

Let me finish my question.

14

1

A.

I'm sorry.

2

Q.

It's okay. It's just better for the record. How did

3

you treat people who did not have a DMV-issued ID but who, for

4

example, may have had a state employee-issued ID?

5

A.

Well, again, we had the no-match list that the state

6

had run, which were essentially DMV data. So we could tell if

7

someone didn't have a driver's license or state ID card.

8

Those registrants were denoted as not having identification.

9

Everyone else was treated as having identification.

10

Q.

So when you looked at turnout of people who did not

11

have a driver's license -- withdrawn. When you looked at

12

turnout of people who did not have a driver's license but who

13

may have had a state-issued ID acceptable under the Georgia

14

law, you treated those people as having an ID?

15
16
17

A.

Well, again, I couldn't partition the data based on

these other forms of ID.
Q.

My point, Dr. Hood, is that you treated people who did

18

not have a DMV driver's license or a DMV ID in your matching

19

as having no ID, isn't that right?

20
21
22

A.

People who did not have a DMV ID -- I'm just having a

hard time following you. I'm sorry.
Q.

No, no. My questions may very well have been

23

convoluted. Let me start from the beginning. You matched

24

people who had no ID to their voter registration and voting,

25

is that right?

15

1

A.

Yes, to -- yes.

2

Q.

And the only data --

3

A.

We could -- I guess --

4

Q.

That's all I need, is a "yes." The only data that you

5

had was DMV-issued IDs to match to the vote, right?

6

A.

Yes, that's correct.

7

Q.

And so the people who may have had all of the other

8

types of IDs but not a DMV ID were treated in your analysis as

9

having no ID?

10

A.

No, they were just considered to have ID. I mean, the

11

only people we treated as not having ID were the people we

12

knew that were denoted on the no-match list run by the state.

13

Q.

And the no-match list was everybody who didn't have a

14

DMV ID?

15

A.

That's correct, yes.

16

Q.

So someone --

17

A.

I don't know, maybe we're talking past each other.

18

Q.

No, no. I think now we're getting there. So someone

19

who had a state employee ID but not a DMV ID was treated by

20

you as not having an ID, right?

21

A.

Okay. If that was -- in that hypothetical, yes. If

22

someone had a state employee ID and they were denoted on the

23

no-match list as not having a driver's license or state ID

24

card, then yes, we noted that they didn't have a driver's

25

license or state ID card.

16

1

Q.

So when --

2

A.

So they were in the no ID category.

3

Q.

That's what I was trying to establish.

4

A.

I'm sorry.

5

Q.

No, that's okay. So when you looked at turnout of

6

people with no IDs, you may have, and you don't know one way

7

or the other, included tens or hundreds of thousands of people

8

who actually had an ID, but not just a DMV ID?

9

A.

Well, when -- I don't know what the number would be. I

10

have no idea about that. There could be people, yes, that may

11

have had, for instance, a passport, say, but not a driver's

12

license. So they may have been denoted as not having ID under

13

our study.

14

Q.

Now, on that topic yesterday, I think you told the

15

Court that African American turnout in Georgia between 2004

16

and 2008 was actually higher in 2008 notwithstanding the

17

implementation of a voter ID law, is that right?

18

A.

Yes, sir.

19

Q.

But you left out, I think, Dr. Hood, the fact that

20

turnout as you know among African American voters who did not

21

have an ID actually went down from 2004 to 2008, didn't it?

22

A.

It did, yes. It was in the chart that was shown.

23

Q.

And you have an explanation for why turnout among

24

African Americans as a whole went up between 2004 and 2008,

25

and why it went down between 2004 and 2008 among African

17

1

Americans who did not have a photo ID, don't you?

2

A.

Yes.

3

Q.

And the explanation is the Georgia photo ID law?

4

A.

Yes. That's what we were testing. And again, in

5

fairness, I think you have to make some comparisons between

6

registrants with and without identification, and their turnout

7

rates.

8

Q.

9
10
11
12

Just so we can put the numbers in the record, turnout

among African Americans between 2004 and 2008 went up
13 percent?
A.

I don't have that in front of me. It's in one of my

reports, or the turnout rates are in one of my reports.

13

Q.

Can you disagree that it was 13 percent?

14

A.

I'm not disagreeing, I'm just saying I don't have that

15
16
17

in front of me, sir.
Q.

Okay. Would you turn to page 239 of your deposition,

Dr. Hood.

18

A.

Okay.

19

Q.

If you bear with me, Dr. Hood, I'm going to read you

20

several questions and answers starting at line 13, which we

21

have up on the ELMO. And just so you know, at the end of my

22

reading of this portion of the deposition, I'm just going to

23

ask you whether you were asked the questions and gave the

24

answers, so you can have the question in mind. So here are

25

the questions.

18

1
2

"So there was a 13 percent increase in black
turnout in Georgia between 2004 and 2008, correct?

3

"Answer: Yes. From what this says, yes.

4

"Question: And that's for all black registered

5

voters?

6

"Answer: It should be.

7

"Question: But when you look at people who

8

didn't have an ID in 2004, their participation in the 2000

9

election dropped by 5 percent.

10
11

"Answer: Their participation did go down, we
estimate by that low, yes.

12

"Question: Can you explain the disparity between

13

blacks with an ID, participate without an ID, participation

14

dropping by 5 percent between 2004 and 2008, and overall

15

participation increasing by 13 percent between 2004 and 2008

16

by anything other than the imposition between 2004 and 2008 of

17

the Georgia photo ID law?

18
19

"Answer: Well, again, that would be the
inference to be drawn.

20
21

"Question: That it was the photo ID law that
caused those two numbers to differ?

22

"Answer: Yes."

23

Were you asked those questions and did you give

24
25

that answer?
A.

Yes, sir.

19

1

MR. BARTOLOMUCCI: I just need to note a quick

2

objection for the record. Mr. Beeney left out the word

3

"black" in his recitation of page 239, line 25.

4
5

HON. COLLEEN KOLLAR-KOTELLY: Why don't you read
that over for the record.

6
7
8
9

MR. BEENEY: Thank you. I will, Judge.
BY MR. BEENEY:
Q.

So again, Dr. Hood, starting then at line 23 of page

239, were you asked the following questions and did you give

10

the following answers: "Can you explain the disparity between

11

blacks without an ID participation dropping by 5 percent

12

between 2004 and 2008, and overall black participation

13

increasing by 13 percent between 2004 and 2008 by anything

14

other than the imposition between 2004 and 2008 in Georgia of

15

a photo ID law?

16
17

"Answer: Well, again, that would be the
inference to be drawn.

18
19

"Question: That it was the photo ID law that
caused these two numbers to differ?

20

"Answer: Yes."

21

Were you asked those questions and give those

22

answers, now that I hopefully have read it correctly?

23

A.

Yes, sir.

24

Q.

Thank you. So in fact, one of the reasonable

25

conclusions from your Georgia study is that voter ID laws

20

1

adversely impact African American turnout?

2

A.

Well, they adversely impacted everyone's turnout.

3

Q.

And certainly they disparately impact -- withdrawn.

4

Certainly they impacted African American turnout, right?

5

A.

Yes. I mean, that's in the paper, yes, sir.

6

Q.

In fact, in the Wisconsin voter ID case, looking at

7

these numbers and this portion of your analysis, the court in

8

Wisconsin actually found that your Georgia study supported the

9

idea that the Wisconsin ID law would impede voting by African

10

Americans, correct?

11

A.

I don't have that in front of me, sir.

12

Q.

Okay. Doctor, would you turn to page 258 of your

13

deposition.

14

A.

Okay.

15

Q.

I'm putting up on the ELMO page 258, and we're going to

16

go over to page 259, starting at line 21: "And in fact,

17

didn't the court in Wisconsin find that your Georgia studies

18

actually supported the idea that the Wisconsin photo ID law

19

would impede voting by African Americans?

20

"Answer: That's what they found. I don't

21

disagree with that, I think -- I'm sorry. I don't agree with

22

that, I think, I don't agree with that interpretation."

23
24
25

Were you asked that question and did you give
that answer?
A.

Yes.

21

1

Q.

Now, you did another study of Georgia voters, didn't

2

you, Dr. Hood, that was basically a phone polling? Do you

3

remember that?

4

A.

Yes.

5

Q.

And in that --

6

A.

Well, I mean, I've done -- could you be more specific?

7
8
9

I've done -Q.

Yeah, the one I'm referring to is the one we discussed

in your deposition in which you found that when asked why

10

people used absentee voting, 30 percent of African Americans

11

in Georgia cited the photo ID law as an important reason, as

12

compared with 19 percent for whites?

13

A.

I remember conducting a study, it was somewhat limited,

14

it was a three-county post-election study. And we had a

15

fairly limited set of absentee voters by mail. I think there

16

were only 200 total in the entire survey. So I think that is

17

accurate, from what I can remember. I think there's also, I

18

think, a footnote in that report somewhere noting some caution

19

because of the low number of African American voters that we

20

surveyed that actually voted absentee by mail. There just

21

weren't that many, in fairness.

22

Q.

Would you turn to page 255 of your deposition, please.

23

I think by now you probably know the question I'm going to ask

24

you after I read it. 255, line 2. And the question was

25

asked: "Page 7, second sentence from the bottom, which reads:

22

1

'In our sample of absentee voters, a third of African

2

Americans, 30 percent, compared with about a fifth of white

3

voters, 19 percent, cited lack of photo ID as an important

4

reason for voting absentee.' Do you see that?

5

"Answer: Yes.

6

"Question: And that was the result of your

7

analysis, correct?

8
9

"Answer: That was part of the result of my
analysis. It was a little more inclusive than that."

10
11

Were you asked those questions and did you give
that answer?

12

A.

Yes, sir.

13

Q.

Dr. Hood, I just want to kind of understand the work

14

that you've done in this case, and so I'm going to run through

15

a bit of a list and ask you if I've got it right. You got DMV

16

data, you got South Carolina election commission data, you

17

spoke to the DMV and the SEC people about the data, you did

18

whatever you needed to do with the data, you wrote your

19

initial report, you read whatever you needed to read in the

20

record, you got the Department of Defense data, you got the

21

State Department data, again, you did whatever you needed to

22

do with that data, you wrote a supplemental report, you read

23

other expert reports, you wrote a rebuttal report. Did you do

24

all that?

25

A.

I did all that, yes.

23

1
2

Q.

And you had no help from anyone in doing all that, is

that right?

3

A.

Yes. I mean no, I had no help. I did it myself.

4

Q.

And the totality of the time you spent doing all that

5
6
7

was 50 hours?
A.

Well, I said I didn't know. I didn't -- I hadn't added

it up at the time.

8

Q.

The estimate you gave us was 50 hours?

9

A.

Well, it was an estimate is all I'm saying.

10

Q.

Okay. Just to follow up on a couple of questions, Dr.

11

Hood, that the Court asked yesterday. And again, just to give

12

us a little bit of background. In your numbers there are tens

13

of thousands of African Americans who don't have the four

14

types of R54 IDs that are offered today, is that correct?

15

A.

Yes, I mean, we can look at the exact figures again.

16

Q.

But my statement is correct, isn't it?

17

A.

Yes. I can't sit here even now -- I don't have the

18
19

figure memorized, but yes.
Q.

And they lack IDs, I think as you agreed with Mr.

20

Dellheim yesterday, they being African Americans, in

21

disproportionate rates as compared with white voters?

22

A.

Yes, there is a gap there.

23

Q.

And we can all agree that some portion of these people

24

who don't have the four types of IDs that are currently

25

offered will at some point get an ID if they overcome whatever

24

1

obstacles R54 places in front of them, correct?

2

A.

Yes, I think so.

3

Q.

But we don't know how many, of course?

4

A.

No. No.

5

Q.

But yesterday you were asked about whether you could

6

make any judgment as to whether the disproportionate rate of

7

ID ownership would continue to be felt at the polls even

8

though some number of people may remedy the fact that they

9

don't have an ID. Do you remember that?

10

A.

Yes.

11

Q.

And I think -- well, let me suggest to you that we

12

really do have a pretty good reason, a pretty good reason to

13

believe what is likely to happen to that gap, don't we?

14

A.

Well, go ahead, I guess.

15

Q.

Well, I think you told Mr. -- I think I will.

16
17
18

HON. JOHN D. BATES: But be careful not to testify.
BY MR. BEENEY:
Q.

I think yesterday you agreed with Mr. Dellheim that

19

socioeconomic factors have an impact on turnout, is that

20

right?

21

A.

Certainly, just in a general sense, yes.

22

Q.

Educational attainment, per capita income, access to

23
24
25

transportation, all those things affect turnout, don't they?
A.

Well, I wouldn't say per capita income. I mean, if

we're talking about individuals, it's the individual's income

25

1
2
3

level or their family income level.
Q.

With that very proper correction, all those things

affect turnout?

4

A.

Yes, they can.

5

Q.

And so, if in the state of South Carolina, if African

6

Americans are of lower income, lower educational attainment

7

and less access to transportation, isn't it reasonable to

8

conclude that the gap that exists now is likely to increase,

9

if anything, after people do whatever they need to do to

10
11
12

obtain an ID?
A.

Well, in fairness to your question, I did not conduct

any analyses with demographic data, as I indicated yesterday.

13

Q.

Based on --

14

A.

And you're presenting to me some facts. I didn't run

15
16

an analysis, though.
Q.

Okay. But -- and you can't offer a view based on the

17

social science as it exists today as to whether that gap is

18

going to increase or decrease in light of the socioeconomic

19

factors in South Carolina?

20

A.

Which gap are we talking about at this point?

21

Q.

The gap in ID ownership.

22

A.

Well, again, I would suspect that the gap would be

23

narrowed to some degree, or that -- you know, overall -- I

24

guess it depends on which table you look at in my reports.

25

But where it -- somewhere less than, it looks like 5 percent

26

1

by my best estimate of registrants in South Carolina, of all

2

races, not possessing one of these four forms of ID. So I

3

would hope once the law was implemented, these mitigating

4

factors that come along with the law would reduce that

5

5 percent down to close to zero. Excuse me.

6
7

Q.

Rather than the number in the absolute terms, we want

to talk about the gap.

8

A.

Okay.

9

Q.

Do you have a view about the gap in light of the

10
11
12
13

socioeconomic factors in South Carolina?
A.

Well, I think as the overall number is decreased, the

gap should decrease as well.
Q.

Notwithstanding lower education attainment, lower

14

income, lower -- lack of access to transportation among

15

African Americans, traditional factors that people look at in

16

terms of voter turnout?

17

A.

I agree those factors are related to voter turnout in

18

the general sense. I didn't conduct an analysis specifically

19

in South Carolina that analyzed that.

20

HON. BRETT M. KAVANAUGH: As the overall number

21

decreases, why would the gap decrease, in your view? I think

22

you just said that.

23

THE WITNESS: Well, yes, Your Honor. I'm just

24

considering that, you know, we're starting out at something

25

less than 5 percent. Once the free ID program takes effect,

27

1

the educational campaign takes effect --

2
3

HON. BRETT M. KAVANAUGH: That pushes everything
down, but why does that change the gap?

4

THE WITNESS: Well, I guess there could still be a

5

gap. I think once those programs are initiated and put in

6

place, that everything should be pushed down. Perhaps there's

7

still a gap --

8

HON. BRETT M. KAVANAUGH: The absolute numbers?

9

THE WITNESS: Yes. Perhaps there's still a gap,

10

but I think as we push the overall number down, that hopefully

11

the gap is going to shrink.

12

HON. BRETT M. KAVANAUGH: One other question. Do

13

you know the socioeconomic status of the African Americans or

14

whites who are in the category of being registered but not

15

having one of the R54 IDs?

16

THE WITNESS: I didn't specifically study that.

17

HON. BRETT M. KAVANAUGH: You don't have any

18

knowledge about the whites or the African Americans?

19
20
21

THE WITNESS: I didn't look at any of that, Your
Honor.
HON. JOHN D. BATES: Would the issue of whether the

22

gap was decreased be influenced by the kinds of programs that

23

were undertaken to get certain categories of voters who didn't

24

have IDs, undertaken either by the state or by the county or

25

by churches or by other organizations? Would that influence

28

1

what happened to the gap?

2

THE WITNESS: It could, Your Honor.

3

HON. JOHN D. BATES: And we don't know what that

4

influence is going to be.

5

THE WITNESS: No, but one of the programs that

6

would be implemented if the law is precleared is a free ID

7

program, you know, with the idea that, again, that should be

8

targeting some of these people.

9

HON. JOHN D. BATES: But it's going to be targeting

10

people not based on their race, it's going to be targeting

11

whites without IDs as well as minorities.

12

THE WITNESS: Correct, everyone without IDs. But

13

it's possible that, you know, if someone -- if I could run

14

through -- you know, you could run through a hypothetical,

15

someone doesn't have a car so they don't have a driver's

16

license, they don't have a passport, et cetera, et cetera. So

17

that program should help to mitigate some of these registrants

18

who don't have any of these four types of ID. And it is to

19

some degree targeted at that group specifically, I would

20

argue.

21
22

HON. JOHN D. BATES: That group being those without
the ID?

23

THE WITNESS: Yes. Yes, sir.

24

HON. JOHN D. BATES: But not at one race versus

25

another?

29

1

THE WITNESS: That's correct.

2

HON. JOHN D. BATES: But there may be other

3

programs undertaken by churches, organizations, et cetera,

4

that would be more targeted and that could influence that gap?

5

THE WITNESS: Certainly, there could be other

6

programs implemented.

7

BY MR. BEENEY:

8
9

Q.

Dr. Hood, on that topic, since your August 6

deposition, have you reviewed any evidence in the case?

10

A.

Just expert reports, I believe.

11

Q.

So you haven't looked at the State Election Commission

12
13

implementation procedures?
A.

Well, not -- I looked at the procedures. I think I

14

looked at how they were going to implement the law. I mean, I

15

looked at that probably prior to my deposition.

16

Q.

You looked at the law, right?

17

A.

I looked at the law, and there were some materials --

18

Q.

That's all -- let me just see if I can move along a

19

little bit.

20

A.

Okay.

21

Q.

You've looked at the law but you haven't looked at

22

documents that the SEC produced recently about their

23

implementation procedures?

24

A.

I guess how recently is the question.

25

Q.

Since your deposition.

30

1

A.

I don't think so, no.

2

Q.

And you haven't read any of Ms. Andino's testimony?

3

A.

Well, no, but --

4
5

HON. JOHN D. BATES: He was sitting in the
courtroom during the testimony.

6
7
8
9
10

THE WITNESS: -- I was here.
BY MR. BEENEY:
Q.

I'm going to get to that after we go through the

reading. You didn't read her Friday deposition or any prior
deposition?

11

A.

No, sir.

12

Q.

But you were here in the courtroom when Ms. Andino was

13

testifying?

14

A.

Yes, I think I was here for all of that, from what --

15

Q.

That's the only time that you've heard any State

16

Election Commission implementation plans with respect to R54,

17

is that right?

18
19

A.

Well, that's the only time I've heard someone testify

about it.

20

Q.

Either in writing or orally?

21

A.

Again, I read some -- I read at one point some

22

documents relating to implementation.

23

Q.

I know. And we're talking now about testimony.

24

A.

Okay. Yes. Yes, that's correct.

25

Q.

Now, finally, Dr. Hood, let me ask you a couple

31

1

questions about your opinion in the case. You are not asking

2

the Court to base its decision on anyone's speculation, is

3

that right?

4

A.

That's correct.

5

Q.

And putting aside speculation, I want to ask you what

6

your opinions are in the case. And I think you agreed with

7

Mr. Dellheim yesterday that you are of the opinion that if you

8

looked at the R54 ID ownership, there's a significant racial

9

disparate impact on African Americans. That is one opinion,

10

is that right?

11

A.

There is a gap in ID possession, yes.

12

Q.

Well, my question is is that there's a significant

13

racial disparate impact on African Americans when you look at

14

ID ownership, is that right?

15

A.

Yes.

16

Q.

So that's one opinion. Now, is the next opinion you're

17

offering, as a result of the Georgia study, is that the Court

18

should take care in extrapolating from that disparate racial

19

impact to making any conclusions about what is going to happen

20

at the polls?

21

A.

I think we need to be -- anyone needs to be cautious.

22

Q.

Are you offering, in addition to the numbers that we

23

looked at yesterday when Mr. Bartolomucci was asking you

24

questions, are you offering any other opinions in the case?

25

A.

Well, not that I'm aware of. I think that summarizes

32

1
2

most of it.
Q.

And since we have your numbers about the significant

3

racial disparate impact of ID ownership under R54, in order to

4

reach a conclusion that R54 will not produce a racially

5

disparate impact on minority turnout, you're required to rely

6

on the mitigating factors under R54, like the reasonable

7

impediment provision, right?

8

A.

I think those are important --

9

Q.

No, but --

10

A.

-- but can I say one other -- back up for a second and

11

say one other thing? I think from the Georgia study, this is

12

a very --

13
14
15
16

Q.

Dr. Hood, would you mind if I let Mr. Bartolomucci -MR. BARTOLOMUCCI: I have to object to that.

Please let him finish.
HON. COLLEEN KOLLAR-KOTELLY: I think he can go

17

ahead. But tell us what you're hooking it up to, since

18

frankly I can -- I'm not sure what you're talking about.

19

Which answer are you trying to amend?

20

THE WITNESS: Well, I was just trying to add to

21

when Mr. Beeney asked me specifically about conclusions I was

22

drawing in the case.

23

HON. JOHN D. BATES: What opinions you're --

24

THE WITNESS: Opinions, yes, your Honor. Can I?

25

HON. COLLEEN KOLLAR-KOTELLY: Yes. Give the

33

1

answer.

2

THE WITNESS: Thank you. Well, from the Georgia

3

study, again, this is a pretty fine point, but I think it

4

needs to be made -- I think I tried to make it yesterday -- in

5

that in Georgia at least, there was a noted gap in ID

6

possession, but that didn't necessarily translate into a gap

7

in turnout. So that's all I wanted to say on that. I'm

8

sorry.

9

BY MR. BEENEY:

10

Q.

So the three opinions you're offering are significant

11

racial disparate impact of ID ownership, take care in reaching

12

the conclusions you reach about that in terms of what happens

13

at the polls, and the Georgia study opinion you just

14

mentioned. Is that right?

15

A.

Yes, sir.

16

Q.

All right. Now, since we agree that the numbers of ID

17

ownership show a significant disparate impact on minorities,

18

you need to rely on the mitigation factors, such as the

19

reasonable impediment provision of R54, to reach any

20

conclusion that those numbers will not produce a racially

21

disparate impact on minority turnout at the polls, right?

22
23
24
25

A.

That was one of them, yes. There are other mitigating

factors as well, like the free ID program.
Q.

But in any event, you need to rely on all those

mitigating factors to reach the conclusion that the disparate

34

1

impact of ownership won't result in disparate impact at the

2

polls?

3

A.

Yes, I think they are important.

4

Q.

And your conclusions, to the extent you have any, about

5

the extent to which those mitigating factors, including the

6

reasonable impediment provision, have an impact, is

7

speculation, right?

8

A.

Well, they have -- the law has not been implemented.

9

Q.

Would you turn to page 285 of your deposition, Dr.

10

Hood.

11

A.

285?

12

Q.

Yes, sir.

13

A.

Okay.

14

Q.

On line 10, were you asked the following questions and

15

did you give the following answers. "Question: Not quite my

16

question, though. My question is whether you believe today,

17

as you're sitting here, that any conclusion concerning the

18

future effect of R54 is speculation?

19

"Answer: I state it in the report.

20

"Question: And you believe it today?

21

"Answer: Yes."

22

Were you asked those questions and did you give

23
24
25

those answers?
A.

Yes. I'm trying to look at the context of what was

going on here.

35

1

Q.

Well, Dr. Hood, I'm going to move on.

2

A.

Yeah, I did state that, yes.

3

Q.

So stripped from speculation, we're left with your

4

three opinions, disparate impact of ownership, take care, and

5

the conclusion you reached from Georgia. Do I have it right?

6

A.

Yes.

7

MR. BEENEY: Thank you, Dr. Hood.

8

HON. COLLEEN KOLLAR-KOTELLY: All right. South

9

Carolina.

10
11
12

EXAMINATION
BY MR. BARTOLOMUCCI:
Q.

Professor Hood, Mr. Beeney just asked you a question

13

about significant racial disparate impact of ID ownership. Do

14

you recall that?

15

A.

Yes.

16

Q.

Does R54 have any impact on ID ownership?

17

A.

It will if implemented.

18

Q.

Today does it have any impact?

19

A.

No. It has not been implemented.

20

Q.

In this context, what do you mean, if anything, by the

21
22

term "significant"?
A.

Well, I think I was referencing the fact that again we

23

had enumerated population data, and whatever gap was there was

24

the gap that we would recognize in the real world. I mean, it

25

was very representative of the actual gap that might exist in

36

1

the real world.

2

Q.

So you're referring to the gap, that number?

3

A.

Yes.

4

Q.

Are you characterizing that gap in some way with the

5

word "significant"?

6

A.

Not particularly. I mean...

7

Q.

Do I correctly understand it's merely a reference to

8

the gap and its magnitude, whatever it is?

9

A.

Yes.

10

Q.

You were also asked some questions this morning about

11

whether any of the mitigating provisions would particularly

12

help individuals of lower socioeconomic status. Do you

13

remember that line of questioning?

14

A.

Yes.

15

Q.

Are you aware of whether the election commission has

16
17
18
19

plans for a mobile unit, a bus to go around?
MR. DELLHEIM: Objection. There's no foundation
for his response. I think he said that -HON. COLLEEN KOLLAR-KOTELLY: Yes, I have to say I

20

thought he had said that he didn't know what other plans there

21

were. So you're asking him about something he's already

22

indicated he hasn't looked at.

23
24
25

MR. BARTOLOMUCCI: I think I can lay a foundation,
Your Honor.
HON. COLLEEN KOLLAR-KOTELLY: Go ahead.

37

1
2
3

BY MR. BARTOLOMUCCI:
Q.

Were you in the courtroom to hear Ms. Andino's

testimony?

4

A.

Yes.

5

Q.

Did she testify regarding a mobile unit?

6

A.

Yes.

7

Q.

Would a mobile unit assist individuals of lower

8
9
10
11
12

socioeconomic status?
A.

Most likely, and those that might not have access to

public transportation, for instance in rural areas.
Q.

Would a free ID program assist persons of lower

socioeconomic status?

13

A.

Yes.

14

Q.

Black and white?

15

A.

Anyone, yes.

16

Q.

Are you aware of any provision in R54 of making -- of

17
18

creating any lists?
A.

Yes. There should be a list, from testimony I heard, a

19

list created of those -- similar to a list that I drew up, of

20

those that don't have ID, one of the current forms of Act R54

21

ID. And they should receive a mailer, from what I understand,

22

to indicate the change in the law and that they need to get a

23

free ID to vote in person and the method for doing that.

24

Q.

Are you aware of any other use to which that list would

25

be put?

38

1

A.

No.

2

Q.

Okay. To return to a topic from yesterday, the topic

3

of South Carolina driver's licenses returned by registrants

4

from out of state. Do you remember that line of questioning?

5

A.

Yes.

6

Q.

Now, in your analysis, your matching analysis, if a

7

registrant was on the election commission database and you saw

8

on the DMV database that a driver's license that matched that

9

individual was returned from out of state, did you count that

10
11

person as having a South Carolina driver's license?
A.

Well, again, I mean, using the criteria I laid down, I

12

used an indicater in the database for valid ID, plus the

13

expiration date field, to make sure that the license had not

14

been expired. So, you know, again, in terms of the voter

15

registration database, I didn't subtract anyone from that

16

database. I had the same number of registrants that I started

17

the analysis with at the beginning and at the end.

18

Q.

Did you exclude such a registrant who returned a

19

license from out of state from your tally of registrants who

20

do or do not possess an R54 ID?

21

A.

No.

22

Q.

In your analysis did you treat a license that was

23
24
25

returned as a valid license?
A.

No, that -- well, again, it would have to be denoted in

the valid indicater field. So I don't think it should have

39

1
2

been valid if it's been returned.
Q.

Am I correct that when you found a registrant who

3

returned a license from out of state, you excluded the license

4

but not the registrant?

5

A.

Yes, I did not exclude the registrant.

6

Q.

Did you make an assumption about whether such a person

7
8
9
10
11
12

is registered to vote in South Carolina?
A.

Well, the assumption is if they were on the

registration roll, that they were registered to vote in South
Carolina. That's the assumption I made.
Q.

And is such a person who appears on the registration

roll in fact registered to vote in South Carolina?

13

A.

Yes.

14

Q.

Do you know whether such persons actually vote in South

15
16

Carolina elections?
A.

Well, from an expert report I reviewed in this case

17

from Professor Stewart, apparently some subset of those that

18

had returned out-of-state licenses were continuing to vote in

19

South Carolina even after their license had been reported as

20

having been returned. And their turnout rate was

21

approximately the same as those in the inactive category for

22

registrants. So again, my goal wasn't to exclude anyone from

23

the analysis who could potentially be impacted by Act R54.

24
25

Q.

Did you exclude any registrants from your analysis of

the election commission database?

40

1

A.

No. No.

2

Q.

In your opinion, Professor Hood, was it appropriate for

3

you to include in your analysis registrants who returned

4

licenses from out of state?

5

MR. DELLHEIM: I object to the leading questions.

6

MR. BARTOLOMUCCI: I asked an opinion.

7

HON. JOHN D. BATES: Well, you still can ask it in

8

a non-leading fashion. You can ask, what is your opinion with

9

respect to, rather than telling him what opinion he should

10

have.

11
12
13

MR. BARTOLOMUCCI: Thank you, Your Honor.
BY MR. BARTOLOMUCCI:
Q.

Professor, do you have an opinion about whether it is

14

appropriate for you to include in your analysis registrants

15

who returned licenses from out of state?

16

A.

I think it is. And let me just buttress that by

17

saying, again, I think it's appropriate to include everyone

18

that is on the voter registration roll because those are the

19

individuals who could potentially turn out to vote in the next

20

election cycle.

21

Q.

Do you have an opinion, Professor Hood, as to whether

22

the approach you just described is more or less appropriate

23

than a contrary approach of taking out of the analysis

24

altogether individuals who returned licenses from out of

25

state?

41

1

A.

I think it's more appropriate. I think hopefully my

2

approach was more conservative, again, in that I included all

3

registrants.

4
5

Q.

Professor Hood, I'd like to ask you a few questions

about the Billups case that we've been talking about.

6

A.

Okay.

7

Q.

Were you retained as an expert in the Billups case?

8

A.

Yes.

9

Q.

By which party or parties?

10

A.

The plaintiffs in the case.

11

Q.

And by the plaintiffs, does that mean the parties --

12

the parties that were challenging the Georgia voter ID law or

13

defending it?

14

A.

Challenging the law.

15

Q.

Did you prepare an expert report in that case?

16

A.

Yes. I guess you could say I already had it prepared

17

because my -- one version of my "Worth a Thousand Words"

18

article was essentially my expert report. That's what I used

19

for my expert report in that case.

20
21
22
23
24
25

Q.

Did you change your "Worth a Thousand Words" paper, or

is that what you submitted?
A.

That's what I submitted.
MR. DELLHEIM: Your Honor, I'm going to object

again to the continuing leading questions.
HON. COLLEEN KOLLAR-KOTELLY: It would be helpful,

42

1

I mean, in terms of what he used, instead of -- you are asking

2

very leading questions, which doesn't give us the benefit of

3

what his answer would have been.

4

BY MR. BARTOLOMUCCI:

5

Q.

Let me just rephrase. Could you tell us what if

6

anything you submitted to the Billups court as your expert

7

report?

8

A.

9
10
11
12

It was essentially the "Worth a Thousand Words"

article, which had not been published at that point, but I had
already prepared it.
Q.

At the time of your involvement in Billups, had the

2008 election occurred?

13

A.

No.

14

Q.

At the time of your involvement in Billups, did you

15

have access to data following the implementation of the

16

Georgia voter ID law?

17

MR. DELLHEIM: Your Honor, again, forgive me. I'm

18

going to continue to object to the continuing leading

19

questions.

20
21

MR. BARTOLOMUCCI: I don't know that that was a
leading question.

22
23

HON. COLLEEN KOLLAR-KOTELLY: Yeah, I think that's
one he can ask.

24
25

THE WITNESS: Could you say that one more time.
I'm sorry.

43

1
2

BY MR. BARTOLOMUCCI:
Q.

Yes, sir. At the time of your involvement in Billups,

3

did you have access to data following the implementation of

4

the Georgia voter ID law?

5
6
7

A.

No, that was -- the law was enjoined, so it was prior

to implementation.
Q.

At the time of your involvement in Billups, did you

8

have any hypothesis about the effect the Georgia voter ID law

9

would have on the turnout of minority registrants who lacked a

10
11

photo ID?
A.

Again, that was prior to implementation. I don't want

12

to rehash the whole thing because we discussed it yesterday.

13

But we did learn from that academic study that there was a

14

noted gap in ID possession by race. It was logical to

15

conclude or at least to hypothesize at that point that if the

16

law went into effect, that there might be a racially disparate

17

effect in terms of turnout from that.

18

Q.

Was that your hypothesis at that time?

19

A.

That's what I was thinking, yes.

20

Q.

Fast forward to today. Do you have any view as to that

21
22
23
24
25

hypothesis?
A.

Well, I mean, from our post-implementation study in

Georgia, it doesn't seem to be the case.
Q.

I'm going to put up a portion of the judge's ruling in

the Billups decision. I believe we saw this yesterday. I'm

44

1

going to read part of it.

2

HON. COLLEEN KOLLAR-KOTELLY: Can you give us the

3

page that you're reading from. The cite and the page if you

4

could.

5

HON. JOHN D. BATES: Is this an exhibit?

6

MR. BARTOLOMUCCI: This was used yesterday.

7

HON. JOHN D. BATES: I don't think it's an exhibit.

8

We don't have it.

9

MR. BARTOLOMUCCI: No, it's not an exhibit because

10

I believe it was only offered yesterday for impeachment

11

purposes. But it's the same document that was used yesterday

12

for impeachment purposes. We could supply the Court with a

13

copy.

14
15

HON. COLLEEN KOLLAR-KOTELLY: That's okay. All I'm
asking is what page in the opinion.

16

MR. BARTOLOMUCCI: Page 48. Page 48 of the slip

17

opinion in the Billups matter, in the relevant ruling.

18

BY MR. BARTOLOMUCCI:

19

Q.

So Dr. Hood, if I can -- this opinion states in part:

20

"The analysis failed to consider whether voters might have

21

other forms of acceptable photo ID, including free voter ID

22

cards, and consequently cannot adequately predict the number

23

of voters who lack a photo ID."

24
25

Now, Professor, in this case did you consider the
forms of photo ID that are available under Act R54?

45

1

MR. DELLHEIM: I object to the leading question.

2

HON. COLLEEN KOLLAR-KOTELLY: Can we -- I'm not

3

sure what you're trying to do here. You read from the opinion

4

are you're asking him what? That it applies in this case,

5

doesn't apply in this case? What are you getting at?

6

MR. BARTOLOMUCCI: I'm getting at whether the

7

court's criticism of his approach in that case would or would

8

not apply in this case.

9

HON. COLLEEN KOLLAR-KOTELLY: Then you can ask it

10

that way.

11

BY MR. BARTOLOMUCCI:

12
13
14
15
16
17

Q.

What did you consider with respect to, if anything,

with respect to forms of ID under R54?
A.

I considered any of the four existing forms of ID. The

fifth form has not been implemented yet.
Q.

And did you, in this matter, with respect to South

Carolina, did you make any predictions in this case?

18

A.

Post-implementation predictions?

19

Q.

Yes.

20

A.

No, I tried to caution against that to some degree.

21

Q.

Now, Professor, did you or did you not include passport

22

and military ID information in any of your reports?

23

A.

Yes, I had that data available for a supplemental

24

report.

25

Q.

Was it included in your original report?

46

1

A.

No.

2

Q.

Why was it not included in your original report?

3

A.

At that time I didn't have access to those data

4
5

sources.
Q.

When you went to add passport and military ID data, did

6

you have any expectation about what that might do to your

7

data?

8

A.

9

I had no idea what the end results would be. I just

knew that those were two forms of identification which would

10

be accepted under Act R54, and we needed to be as inclusive as

11

possible.

12

Q.

And do you know whether your inclusion of that data

13

increased or decreased the gap that we've been talking about

14

in ID possession rates?

15

A.

Well, it increased the gap actually.

16

Q.

Now, when you looked at active registrants only, you

17

found a gap, correct?

18

A.

Yes.

19

Q.

And do you remember what the percentage point gap was?

20

A.

No. You know, we'd have to refer to a specific table.

21

Q.

Okay. When you then went to include active registrants

22

plus the two categories of inactive registrants, do you know

23

whether the gap increased or decreased?

24

A.

The gap typically increased, I believe.

25

Q.

Did you offer both sets of data in your report?

47

1

A.

Yes.

2

Q.

Do you recall Mr. Dellheim yesterday asking you whether

3

minority registrants in South Carolina were 1.4 times more

4

likely to lack photo ID than white registrants?

5

A.

Yes.

6

Q.

Do you remember that line of questioning?

7

A.

Yes.

8

Q.

And do you recall him asking you if when you look at

9
10

only registrants under the age of 65, you get the result that
minorities are 1.67 times more likely to lack such ID?

11

A.

Yes.

12

Q.

Now, you could have presented only the data for

13

under-65 registrants, correct?

14

MR. DELLHEIM: Objection to the leading questions.

15

HON. COLLEEN KOLLAR-KOTELLY: I'll sustain it. Mr.

16

Bartolomucci, you know how to do this.

17

BY MR. BARTOLOMUCCI:

18

Q.

On the subject of the Georgia voter ID law, if I can

19

turn your attention to the demonstratives that were created

20

yesterday, the two charts with the lists?

21

A.

Okay.

22

Q.

Are you aware of any way under the Georgia law for a

23

voter to vote without a government ID?

24

A.

Not in person, no, sir.

25

Q.

Under Act R54 are you aware of any way for a voter to

48

1

cast an in-person ballot without a photo ID?

2

MR. DELLHEIM: Object to the leading questions.

3

MR. BARTOLOMUCCI: I don't think that one was

4

leading.

5
6

HON. COLLEEN KOLLAR-KOTELLY: Go ahead and answer
it.

7
8
9
10

THE WITNESS: No.
BY MR. BARTOLOMUCCI:
Q.

In any of your expert reports in this case are you

offering a prediction as to voter turnout rates?

11

A.

No.

12

Q.

In your opinion is it possible to predict voter turnout

13

rates post-implementation of R54?

14

A.

At this point in time?

15

Q.

Yes.

16

A.

No.

17

Q.

With reference to your Georgia 2 study, do you have any

18

opinion regarding the acceptability or not of the methodology

19

you used in that study?

20
21
22
23

A.

Well, it's a commonly used, what's called policy impact

analysis methodology, so...
Q.

I think you testified that you were present in the

courtroom to hear Ms. Andino's testimony, is that right?

24

A.

Yes.

25

Q.

And did you hear her testimony regarding the guidance

49

1

she plans to offer on the reasonable impediment exception?

2

A.

Yes.

3

Q.

Does the testimony that you heard change in any way

4
5

your understanding of the reasonable impediment exception?
A.

I don't know that it changes it. Perhaps it clarifies

6

it a little bit, since she's part of a team that would be

7

implementing the law.

8

Q.

And how did it clarify your understanding?

9

A.

Well, I seem to remember her to continually say that

10

they were going to err on the side of the voter, and that if a

11

voter showed up without ID and said that they had a reasonable

12

impediment that prevented them from getting a photo ID, that

13

they would be allowed to complete the affidavit and cast a

14

ballot.

15

Q.

16
17

With respect to the Florida litigation that was

discussed -HON. JOHN D. BATES: Mr. Bartolomucci, just, unless

18

you're connecting it to something that he's giving an opinion

19

on, just having him repeat the testimony of Ms. Andino doesn't

20

do anything for us.

21

MR. BARTOLOMUCCI: I was responding to questions

22

yesterday about his understanding and the basis of his

23

understanding of the reasonable impediment affidavit. That's

24

the only question I had on that.

25

50

1
2
3
4

BY MR. BARTOLOMUCCI:
Q.

With respect to the Florida litigation, what were the

issues in that case?
A.

There were a number of them. I guess the chief issue

5

was in these five covered counties in Florida, implementation

6

of a change to Florida's early voting laws. That was the

7

chief issue.

8
9
10

Q.

Were there any other types of legal changes at issue in

that case?
A.

Yes. Issues about how to treat out-of-county movers,

11

and there was an issue about retention of signatures on

12

constitutional amendments, or for state constitutional

13

amendments.

14

Q.

Were those the only issues?

15

A.

There was one other concerning third-party

16
17
18

registration.
Q.

So am I correct there would be no voter ID issue in

that case?

19

A.

Yes.

20

Q.

Just finally, your matching analysis.

21

A.

Yes.

22

Q.

Is that an empirical analysis?

23

A.

Yes, I think it's an empirical analysis.

24
25

MR. BARTOLOMUCCI: We have no further questions for
this witness.

51

1

HON. COLLEEN KOLLAR-KOTELLY: Can I just ask, in

2

terms of you had answered that all of the other ID, all of the

3

IDs that were allowed in Georgia would be all government IDs.

4

Is that true of the colleges and universities? I mean, do

5

they give government IDs, state IDs?

6

THE WITNESS: Well, Your Honor, I think they are

7

considered government because they are state colleges and

8

universities.

9
10

HON. COLLEEN KOLLAR-KOTELLY: So it's only state
colleges, so private schools would not be included?

11

THE WITNESS: I don't think so. There's a list

12

that the state posted on the Secretary of State's website

13

specifically on -- and I don't have it memorized, but which

14

colleges and universities the IDs would be valid for. I mean,

15

I work at a state university, so I could conceivably use my

16

UGA ID card. But it's a state university.

17
18

HON. COLLEEN KOLLAR-KOTELLY: I was curious as to
whether it included private schools or not. Okay. Anything?

19
20

HON. BRETT M. KAVANAUGH: (Shook head in a negative
response).

21
22

HON. JOHN D. BATES: (Shook head in a negative
response).

23

HON. COLLEEN KOLLAR-KOTELLY: You can step down.

24

THE WITNESS: Thank you, Your Honor.

25

MR. BARTOLOMUCCI: Your Honors, that would conclude

52

1

the case in chief of the state of South Carolina, and we would

2

reserve the right to offer rebuttal testimony.

3

HON. COLLEEN KOLLAR-KOTELLY: All right. Then

4

we're at the Department of Justice unless you're switching

5

things around. However you want to do this.

6

MR. DELLHEIM: Your Honor, we are -- the

7

defendant-intervenors are going to begin the defense's case.

8

The Department of Justice will follow after that. Thank you.

9

HON. COLLEEN KOLLAR-KOTELLY: All right.

10

MR. BEENEY: And Your Honors, with the Court's

11

permission, I have the honor of introducing Nancy Abudu,

12

counsel for the ACLU, who will be presenting the intervenors'

13

first two witnesses if we may. Thank you.

14

MS. ABUDU: Good morning, Your Honors. Nancy

15

Abudu, again with the ACLU, representing several

16

defendant-intervenors in this case. And our first witness

17

will be Delores Freelon.

18

HON. COLLEEN KOLLAR-KOTELLY: Ma'am, if you would

19

step up over here, please.

20

Thereupon,

21

DELORES FREELON,

22

the witness herein, having been duly sworn, was examined and

23

testified as follows:

24
25

53

1
2

EXAMINATION
BY MS. ABUDU:

3

Q.

Could you state your name for the record?

4

A.

Delores Freelon.

5

Q.

And your race?

6

A.

Afro-American.

7

Q.

Where do you live?

8

A.

Columbia, South Carolina.

9

Q.

How long have you lived in Columbia?

10

A.

Since November of 2008.

11

Q.

And where were you born?

12

A.

Los Angeles, California.

13

Q.

Are you a registered voter in South Carolina, though?

14

A.

I am.

15

Q.

And how long have you been registered there?

16

A.

Since September of 2009.

17

Q.

Now, are you familiar with the photo ID law that is at

18

issue in this case?

19

A.

I am.

20

Q.

Have you had a chance to read the list of acceptable

21

IDs under the photo ID law?

22

A.

I have.

23

Q.

And do you currently possess any of those acceptable

24
25

forms of ID?
A.

Not at this time.

54

1
2
3

Q.

Could you be more specific and state which of those

identifications you do not possess?
A.

I don't have the state photo ID, I do not possess a

4

driver's license, I don't have a military ID, nor do I have a

5

passport.

6
7

Q.

Have you at any time tried to obtain any of these forms

of identification?

8

A.

I have tried to obtain all of them but the military ID.

9

Q.

Why don't we go through the forms that you've tried to

10

get. Can you tell me the efforts that you made to get a

11

passport?

12

A.

Yes, I called the postmaster and explained to him I was

13

trying to get a passport. He gave me a date to go to the

14

local post office where I live. I went there, I filled out

15

the application, completed it, and then I handed it to the

16

agent. And after he looked over everything, he said I needed

17

to have my birth certificate. I produced that birth

18

certificate, but because it does not have my first name on it,

19

the application was rejected.

20

Q.

What name appears on your birth certificate?

21

A.

Jones.

22

Q.

Is there a first name on that birth certificate?

23

A.

No, it doesn't have a first or middle name.

24

Q.

Now, what steps did you take to get a driver's license?

25

A.

I went to two different DMVs in Columbia. I filled out

55

1

the application, I presented it to the agent, and they told me

2

I was not able to get a photo ID or a driver's license because

3

my birth certificate was incomplete because of no first name,

4

omission of the first name.

5
6
7

Q.

Well, so did you ever try to get the name issue on your

birth certificate corrected?
A.

Yes. The first step I did was I contacted the vital

8

statistics office in Sacramento, California, and when I talked

9

to the representative there, I asked about what steps would I

10

need to amend my birth certificate. At that time, after we

11

did a little talking, she then explained to me that the

12

amendment process at that time was going to take me about a

13

year, and she said it could be a little bit over a year

14

because at that particular time California was going through

15

some serious budget cuts.

16
17

MR. BARTOLOMUCCI: We'll lodge a hearsay objection
to that.

18
19
20

HON. COLLEEN KOLLAR-KOTELLY: I'll sustain it.
BY MS. ABUDU:
Q.

You indicated that you went -- you tried to get your

21

birth certificate -- you contacted an agency in California and

22

attempted to get your birth certificate corrected. What was

23

your understanding in terms of the process you'd to have go

24

through to get your birth certificate amended?

25

A.

Okay. I was told that it would probably be better for

56

1

me to try to get a court-ordered name. And then after that, I

2

contacted an attorney and asked about the process that it was

3

going to take for me to get a court-ordered name. And he

4

explained to me what I was going to have to do. And then I

5

started taking the course of getting this court-ordered name.

6

I first had to get a fingerprint card, and that

7

was $10, I had to pay $10 for that. I then had to get a

8

statement from Social Services saying that I did not owe -- I

9

mean I was not ever convicted of child abuse or child neglect.

10

That cost me $8. I then had to get a criminal background

11

check and a check that says that I was never convicted of

12

sexual abuse or anything like that. That was $25. Then I had

13

to pay a $150 filing fee to go into family court.

14
15

Q.

Now, you indicated that you retained an attorney, is

that right?

16

A.

Correct.

17

Q.

Did you pay any attorney's fees to this person?

18

A.

No, I contacted Legal Aid services.

19

Q.

Now, the $100 filing fee, who paid for that?

20

A.

I paid it.

21

Q.

Without the attorney's assistance, would you have been

22

able to navigate the court process of getting your birth

23

certificate corrected?

24

A.

Not in the least, no.

25

Q.

Now, how did you get from Columbia to Washington, D.C.

57

1

for this trial?

2

A.

I flew.

3

Q.

But without a photo ID, how were you able to get on the

4

plane?

5

A.

Because the week before the flight date --

6

Q.

Actually, I'm sorry, let me correct that. Without a

7

government-issued current and valid photo identification, how

8

were you able to get on the plane?

9

A.

A week before flight date, I went to the airport and I

10

talked with the TSA manager, head of security. I explained to

11

him my situation, and then he asked me did I have any other

12

identification that I could show him that would match the

13

boarding, the name on the boarding pass. He asked me for --

14

Q.

Without indicating what he told you, what

15

identification did you show or were you allowed to show in

16

order to board the plane to get here?

17
18
19
20

A.

My Social Security card, AARP card, and my expired

driver's license.
Q.

And how were you able to get into the courthouse today

without a government-issued valid and current photo ID?

21

A.

Expired driver license.

22

Q.

Now, do you have a car or your own form of

23

transportation?

24

A.

No.

25

Q.

So how do you get around to different places?

58

1

A.

My daughter when she's available.

2

Q.

And do you -- have you voted in South Carolina since

3

being registered?

4

A.

Yes.

5

Q.

And how did you vote? Did you vote in person or

6

another means?

7

A.

I voted in person.

8

Q.

So how did you get to your polling place?

9

A.

At that particular time my daughter had taken me.

10

Q.

Now, are you familiar with South Carolina's absentee

11

voting law?

12

A.

Yes.

13

Q.

What is your understanding in terms of your ability to

14
15

cast an absentee ballot?
A.

My understanding is that you would have to be 65 years

16

or older, that you would have some type of medical condition,

17

or that you would be out of the country or the state at that

18

particular time, or it could be work-related.

19
20

Q.

Okay. Do any of those excuses apply to you in terms of

voting absentee?

21

A.

No.

22

Q.

Now, you indicated that you are familiar with the photo

23

ID law in this case, right?

24

A.

Correct.

25

Q.

So are you aware that the law allows for someone to

59

1

sign an affidavit indicating that they have a reasonable

2

impediment and therefore do not have a government-issued valid

3

and current photo ID?

4

A.

Yes, I'm aware of the law that says -- not the law, but

5

the clause that says about the reasonable impediment, and I

6

know because I don't have a birth certificate -- I don't have

7

it right now because the attorney has that -- but under that

8

statement, I think first I would have to, you know, understand

9

what is reasonably a reasonable impediment. Also, that under

10

that also, I think I understood it to be that I can go to the

11

polling place and I can write that -- get an affidavit, write

12

the reasonable impediment down. I understand that the poll

13

manager would have to look at my reason, you know, what I

14

deemed to be a reasonable impediment, and that he would have

15

to make a decision as to is that a reasonable impediment.

16

Also, when I do this affidavit, I understand that

17

it has to be notarized. And since it has to be notarized at

18

that particular time, that's the only contingency, if you have

19

the money to pay for a notary. Most notaries charge $10. So

20

you might have it at that time, and you might not.

21

Q.

So if you were to be charged a fee in order to get that

22

affidavit notarized, would that be something that would be

23

easy or difficult for you to do?

24
25

A.

It probably would be difficult for me because I'm just

really on a fixed income, and so money, most of my money go

60

1

out real quick, real quick. So it would just be a toss-up,

2

you know, it might happen, it may not happen.

3

Q.

All right. Now, would you say that voting is important

4

to you?

5

A.

Of course it is.

6

Q.

Why is that?

7

A.

Because I have been voting since I was 18 and I enjoy

8

the process because it's just the patriotic thing to do, and

9

also because it's my constitutional right to vote.

10

Q.

All right. Now, one of the arguments that the state of

11

South Carolina has made is that having this photo ID

12

requirement will increase voter confidence in how elections

13

are run. As a South Carolina registered voter, does this ID

14

requirement make you feel more confident in how the system

15

operates, or would operate?

16

A.

No, no, it doesn't make me feel more confident, because

17

I understand now that you can get the voter card, that you can

18

have your birthday put on it and the last four digits of your

19

Social Security number. And to me, instead of having

20

confidence, it looks like to me it probably would create a

21

room for ID theft, that people can, you know, if you lose your

22

card, they get it or something, they can take that and really

23

turn it into something else. So no, I feel confident with the

24

old way.

25

MS. ABUDU: Thank you. I have no further questions

61

1

for this witness at this time.

2

HON. COLLEEN KOLLAR-KOTELLY: Mr. Bartolomucci.

3
4

EXAMINATION
BY MR. BARTOLOMUCCI:

5

Q.

Good morning, Ms. Freelon.

6

A.

Good morning to you.

7

Q.

I'm Chris Bartolomucci. I'm one of the attorneys for

8

the state of South Carolina in this case. I'm going to ask

9

you a few questions if that's okay. What is your date of

10

birth?

11

A.

July 6, 1952.

12

Q.

Can you tell us your educational background?

13

A.

Yes. Well, I was a high school graduate, and then

14

after that I went to vocational school.

15

Q.

Are you employed?

16

A.

Not at this time.

17

Q.

What is your home address?

18

A.

One --

19
20

HON. JOHN D. BATES: Wait a minute. We don't put
home addresses on the record unless there's a need for it.

21

MR. BARTOLOMUCCI: Withdrawn.

22

HON. COLLEEN KOLLAR-KOTELLY: You can ask her other

23

questions about where she lives or poll places or something.

24

BY MR. BARTOLOMUCCI:

25

Q.

You testified that you live in Columbia, South

62

1

Carolina, is that right?

2

A.

Correct.

3

Q.

What part of Columbia do you live in, just generally?

4

A.

I live in northeast.

5

Q.

Does anyone live with you?

6

A.

No, I live with my daughter and son-in-law.

7

Q.

Anyone else?

8

A.

Their three children.

9

Q.

How old is your daughter?

10

A.

Forty.

11

Q.

Do you have any other children?

12

A.

Yes.

13

Q.

Where do they live?

14

A.

I have a son that lives in Little Rock, Arkansas. He's

15

36 years old. I have another son that lives in San Diego,

16

California, and he's 28.

17

Q.

How old is your son-in-law, the one that you live with?

18
19
20
21
22
23
24
25

MS. ABUDU: Objection to the relevance of these
questions.
HON. COLLEEN KOLLAR-KOTELLY: Especially the age.
I mean, if you're trying to get -HON. JOHN D. BATES: You just want to establish
that they're of driving age?
MR. BARTOLOMUCCI: That's correct.

63

1
2
3

BY MR. BARTOLOMUCCI:
Q.

Do your daughter and son-in-law that you live with, do

they have driver's licenses?

4

A.

Yes, to my knowledge they do.

5

Q.

Do they drive in Columbia?

6

A.

Yes.

7

Q.

I think you testified that they own a car, is that

8

right?

9

A.

Yes.

10

Q.

Do they own more than one car?

11

A.

Yes.

12

Q.

How many cars do they own?

13

A.

They have two.

14

Q.

Does your son-in-law, is he employed?

15
16

MS. ABUDU: Again I object to the relevancy of
these questions.

17
18

MR. BARTOLOMUCCI: Your Honors, it goes to the time
he may have available to drive her.

19

HON. COLLEEN KOLLAR-KOTELLY: Then ask it another

20

way without getting to all the demographics of it. You can

21

ask in terms of whether he would be available to take her --

22

BY MR. BARTOLOMUCCI:

23
24
25

Q.

Is your son-in-law available to drive you to places you

need to go if need be?
A.

No, he really never drives me anywhere.

64

1

Q.

2

case?

3

A.

Excuse me?

4

Q.

Do you remember being deposed in this case?

5

A.

Yes, uh-huh.

6

Q.

Do you remember testifying at your deposition that your

7
8
9
10
11
12

Ms. Freelon, do you remember being deposed in this

son-in-law has driven you to go vote?
A.

No, I've never testified that my son-in-law has driven

me to vote. I've only voted one time, so my daughter took me
there, so he hasn't -- we don't have it like that.
Q.

Does your daughter drive you places you want to go in

Columbia?

13

A.

Yes, when she's available.

14

Q.

Has she ever driven you to the bank?

15

A.

Yes, sometimes, yeah.

16

Q.

Has she ever driven you to the grocery store?

17

A.

Yes.

18

Q.

Has she ever driven you to a doctor's office?

19

A.

Yes.

20

Q.

Do you remember testifying in your deposition that she

21

has driven you to a doctor's office on Laurel Street in

22

Columbia?

23

A.

Yes. That was before -- she's gotten new employment,

24

and the new employment has been about six months. So she's

25

not available now to really drive me to -- she works on a

65

1

military base, but she's work as a civilian on a military

2

base. And they just do not let you just take off and do what

3

you want to do. So it's very inconvenient for her, and she's

4

trying to hold on to this job. So I have to set some things,

5

like if I have a doctor's appointment and things now, a lot of

6

times I have called and canceled a lot of appointments because

7

I'm not able -- you know, I can't inconvenience her. Her job

8

is important because that's her livelihood.

9

Q.

How do you get to the doctor's office when you need to?

10

A.

I just -- well, lately I haven't been getting there.

11
12
13

I've been making -- you know, canceling, canceling, canceling.
Q.

When is the last time your daughter has driven you

someplace in Columbia?

14

A.

The last time, on the 28th.

15

Q.

Of this month?

16

A.

Yes.

17

Q.

So two days ago?

18

A.

Yes.

19

Q.

Now, you see a doctor on Laurel Street in Columbia, is

20

that right?

21

A.

Yes.

22

Q.

Where is Laurel Street?

23

A.

I really -- I know the street when I see it, but I

24

can't tell you how to get there because I'm not that familiar

25

with Columbia.

66

1

Q.

Do you know if Laurel Street is near Benedict College?

2

A.

I really don't.

3

Q.

Do you know if Laurel Street is near the voter

4

registration office in downtown Columbia?

5
6

MS. ABUDU: Objection, asked and answered. She
testified she's not very familiar with the area.

7
8

HON. COLLEEN KOLLAR-KOTELLY: She can answer this
particular one.

9

THE WITNESS: Okay. I don't have a clue where the

10

voters office is, I mean really, because since coming to

11

Columbia, and I had a lot of health issues, that I didn't

12

really leave the house too much, I didn't do too much

13

traveling around. Right now, all I can tell you is about the

14

little area around, just a little bit around northeast. You

15

get out of northeast, I can't tell you nothing. I mean, I'd

16

be the wrong person to give you some directions.

17

BY MR. BARTOLOMUCCI:

18

Q.

Now, how did you get your voter registration card?

19

A.

I'm sure then my daughter had taken me to get it, and I

20

don't even know where -- I mean, I can't tell you, honestly,

21

where I got the card. I just know I have it.

22
23
24
25

Q.

Can you tell us what was involved in getting the card?

What do you remember about that?
A.

Sir, I remember nothing. I was having some health

issues at that particular time, and at that particular time I

67

1

was on some really heavy medications. I was taking things, I

2

mean, because of the pain that I was enduring because of, you

3

know, my back. I was taking things like, you know, Dilaudid

4

and Vicodin, stuff like that. I couldn't tell you, no.

5
6
7
8

Q.

Do you -- but do you remember what year it was when you

got your voter registration card?
A.

Yeah, I know what year it is because I can look on the

card and see.

9

Q.

Do you have an independent recollection?

10

A.

No. I even asked my daughter prior to this, and she

11
12
13

forget where she took me too.
Q.

Would your daughter take you back to that location if

you asked her to?

14

A.

No, I just stated that she forgot where she took me

15

too.

16

Q.

Did you vote in the general election in 2010?

17

A.

No, I didn't vote in the general election because at

18

that particular time I was living in New York, and in fact I

19

was living with my daughter and son-in-law there, and my

20

son-in-law was in the military at that particular time, and he

21

was at West Point. So we were getting ready to come back to

22

Columbia. And at that particular time I was caught between --

23

we was in a hotel in New York because their home in Columbia

24

was under a lease and the people that was living there needed

25

more time in order to move out of their home. So we were in a

68

1

hotel in New York.

2

I called to Louisiana because that's where I was

3

registered to vote. Louisiana, when I called the voting

4

office there, they said no, do it from New York. When I

5

called the voting place there in New York, they said do it in

6

Louisiana. So they were just bouncing. But since I was just

7

caught between a rock and a hard spot, I did not get to

8

participate in that particular presidential election.

9

Q.

Have you ever voted in a South Carolina election?

10

A.

Yes.

11

Q.

How did you get to the polls, if you voted at the

12

polls?

13

A.

14
15
16

At that particular time my daughter took me. It was --

yeah, I remember that.
Q.

Do you intend to vote in future South Carolina

elections if you can?

17

A.

Of course.

18

Q.

And how would you get to the polls in the future?

19

A.

I would just have to wait till that particular time and

20

then figure out my situation, how I would get there. What I'm

21

saying is I can't write it in stone that my daughter would

22

take me to the poll. But I'm just assuming at that particular

23

time that some kind of way, hopefully I'll get there.

24

Q.

Would you ask her to take you?

25

A.

At this particular time, no. My daughter is not

69

1

interested in the voting process. I mean, every time I bring

2

up something about some voting, you know, she kind of get a

3

little flipped about it, so -- she don't think it's necessary.

4

So, I don't know.

5

Q.

Do you know where your voter registration card is?

6

A.

In my purse.

7

Q.

Do you get monthly bank statements?

8

A.

Not monthly.

9

Q.

Do you ever receive bank statements?

10

A.

Yes, uh-huh.

11

Q.

Do you ever receive checks from the Social Security

12

Administration?

13

A.

Yes.

14

Q.

Do you have a Social Security card?

15

A.

Yes.

16

Q.

And do you know your Social Security number?

17

A.

I do.

18

Q.

Do you know how to access the Internet?

19

A.

Yes.

20

Q.

In fact, did you ever post a YouTube video of yourself?

21

A.

YouTube?

22

Q.

YouTube.

23

A.

No. Huh-uh. I'm sorry. No. No.

24

Q.

Did you ever make a video talking about South

25

Carolina's voter ID law?

70

1

A.

Yes, not on YouTube, though.

2

Q.

What did you do with that video?

3

A.

Oh, I don't have the video. I mean, I never had the

4

video.

5

Q.

Who made the video?

6

A.

The video was made by a guy, Brett Bursey.

7

Q.

And do you know what he did with it?

8

A.

I have no idea, sir. No.

9

Q.

Have you ever been on television to talk about voter ID

10
11

in South Carolina?
A.

Yes, sir.

12
13

MR. BARTOLOMUCCI: Could I give the witness her
deposition?

14

HON. COLLEEN KOLLAR-KOTELLY: Sure.

15

HON. JOHN D. BATES: Could you tell me what answer

16

you're impeaching or about to impeach?

17

MR. BARTOLOMUCCI: This has to do with whether her

18

daughter would drive her to the place where she was registered

19

to vote.

20

BY MR. BARTOLOMUCCI:

21
22

Q.

Ms. Freelon, could I ask you to turn to page 60 of your

deposition.

23

HON. COLLEEN KOLLAR-KOTELLY: When did you do it?

24

MR. BARTOLOMUCCI: Page 60.

25

HON. COLLEEN KOLLAR-KOTELLY: No, when is the

71

1

deposition, the date on the deposition?

2

MR. BARTOLOMUCCI: The date of the deposition is

3

June 7, 2012.

4

BY MR. BARTOLOMUCCI:

5

Q.

Are you on page 60?

6

A.

Yes, uh-huh.

7

Q.

Can I direct your attention to line 9. I'm going to

8

read this and then ask you whether you were asked the question

9

and the answer you gave. "Question: Okay. Is there any

10

reason today why if you wanted to go back to that location

11

where you received your voter registration card you could not

12

ask and get assistance from your daughter to drive there?

13
14

"Answer: I'm sure she would. I mean, you know,
she knows."

15
16

Do you see that?
A.

Yes, sir. And I did make that statement, and then

17

right after I left that office and went home, and later that

18

evening when I saw my daughter when she got off work, I asked

19

her, I said, do you know where you taken me to get the voter

20

card. She said, I don't know where I took you. And I said,

21

are you sure, I said because I was asked a question, you know,

22

I told her I was asked the question. She couldn't remember.

23

So I couldn't remember, and if she can't remember, I don't

24

know where it came -- I know I got the card, but I don't know

25

where, uh-huh.

72

1
2

Q.

You testified you're familiar with the South Carolina

voter ID law, is that right?

3

A.

Yes.

4

Q.

And are you aware that if it goes into effect you can

5

trade in a voter ID card for one with a photograph?

6

A.

Yes, I've heard that.

7

Q.

Would you do that if you could?

8

A.

Yeah, if I could. I mean, my understanding is that you

9

can get a card that has your picture on it, but you would have

10

to also have your Social Security number and your birth date,

11

and I think the birthday automatically comes with the card,

12

but to put your Social Security number on there, I don't know,

13

I would really be reluctant to do that. I'd rather have my

14

old card that I have because that's like, even though it's the

15

last four digits of your Social Security card, to me that's

16

like too much information.

17

Q.

If you had the ability to turn in your old voter

18

registration card for one with a photograph, and that would

19

allow you to vote, would you do that?

20

A.

If I had to what now?

21

Q.

If you had to take your old voter registration card to

22

the government office and turn it in for one with a photograph

23

on it, would you do that, if that were to allow you to vote?

24
25

A.

Oh, okay. Maybe so. But what I'm saying is, so even

if I had my old one, I wouldn't be allowed to vote? Because I

73

1

mean, what I'm saying is, you know, just in case I didn't get

2

to the voters, you know, office to have that process done,

3

then could I use my old one?

4
5

HON. COLLEEN KOLLAR-KOTELLY: He can't answer the
question.

6

THE WITNESS: Oh, he can't?

7

HON. COLLEEN KOLLAR-KOTELLY: No.

8

THE WITNESS: Sorry.

9

HON. COLLEEN KOLLAR-KOTELLY: It's all right.

10
11
12

BY MR. BARTOLOMUCCI:
Q.

Let me try again. You've got your voter registration

card, right?

13

A.

Yes.

14

Q.

It does not have a photograph?

15

A.

No.

16

Q.

If you could take that to a county office building and

17

trade that in for one with a photograph, would you do that if

18

doing that would let you vote?

19

A.

I guess I would if I could. Yes, I guess I would. But

20

then, like I say, I still would have some reservations about

21

it, about that particular card.

22
23

Q.

Do you think your daughter would help you get to the

county office?

24

MS. ABUDU: Objection, calls for speculation.

25

HON. COLLEEN KOLLAR-KOTELLY: She's already

74

1

indicated, you know, what answer she's given with it, so let's

2

move on.

3

BY MR. BARTOLOMUCCI:

4

Q.

Would you say that your difficulties in obtaining a

5

birth certificate is preventing you from getting a South

6

Carolina driver's license or South Carolina photo ID card?

7

A.

Yes, it is.

8

Q.

If on election day you were told that you could vote by

9
10
11
12

signing an affidavit that said you had a reasonable impediment
to voting, would you do that?
A.

That I had a reasonable impediment, yes, because I

guess my reasonable impediment would be the birth certificate.

13

Q.

How do you know that most notaries charge $10?

14

A.

Most notaries I've been to, they charged me $10. I

15

mean, every one I've ever used, it was $10.

16

Q.

And was that in South Carolina?

17

A.

Yes, sir.

18

MR. BARTOLOMUCCI: No further questions.

19

HON. COLLEEN KOLLAR-KOTELLY: Does the government

20

have anything they want to ask?

21

MR. HEARD: No questions.

22

HON. COLLEEN KOLLAR-KOTELLY: All right.

23

MS. ABUDU: I have just one quick question.

24
25

75

1
2
3

EXAMINATION
BY MS. ABUDU:
Q.

You testified during cross about moving, being in New

4

York and moving to South Carolina. Can you just be clear

5

about what time period that was, what was the year that all of

6

that moving occurred?

7

A.

It occurred at the latter end of 2008.

8

Q.

Thank you.

9

A.

Uh-huh.

10
11

MS. ABUDU: Nothing further, Your Honor, for this
witness. May she be excused?

12

HON. COLLEEN KOLLAR-KOTELLY: Yes.

13

THE WITNESS: You've all been very nice. Thank

14

you.

15
16

MS. ABUDU: At this time we would call Dr. Brenda
Williams to the stand.

17

HON. COLLEEN KOLLAR-KOTELLY: At this point why

18

don't we take our morning break so we don't break up her

19

testimony.

20

MS. ABUDU: Sure.

21

HON. COLLEEN KOLLAR-KOTELLY: Ten of 11:00.

22
23
24
25

BRIEF RECESS
AFTER RECESS
MR. HEARD: Your Honor, before we start with the
next witness, could I just take a moment. The U.S. wanted to

76

1

introduce the three demonstratives that it had put on the Elmo

2

for the examination of Dr. Hood.

3

HON. COLLEEN KOLLAR-KOTELLY: Okay.

4

MR. HEARD: 185A and B. 185A is a two-page

5

exhibit. These were the Georgia Actual Turn Out by Race and

6

ID Possession, Estimated Turn Out, and the live demonstrative

7

exhibits for both of those.

8
9

HON. COLLEEN KOLLAR-KOTELLY: Is there any
objection?

10

MR. BARTOLOMUCCI: No objection.

11

HON. COLLEEN KOLLAR-KOTELLY: All right. Then

12

we'll admit those. I take it they were not on the list

13

originally, is that correct?

14

MR. HEARD: That's correct. These were

15

demonstratives -- and does the Court wish us to electronically

16

file these or give these to the courtroom deputy?

17

HON. COLLEEN KOLLAR-KOTELLY: Let me consult. Why

18

don't you give them to the court deputy for now and we'll

19

figure it out.

20

MR. HEARD: All right.

21

HON. COLLEEN KOLLAR-KOTELLY: Go ahead.

22

MS. ABUDU: Defendant-Intervenors call Dr. Brenda

23
24
25

Williams.
HON. COLLEEN KOLLAR-KOTELLY: Dr. Williams, you if
you'd step up over here, please.

77

1
2

THE WITNESS: Okay.
Thereupon,

3

DR. BRENDA WILLIAMS,

4

the witness herein, having been duly sworn, was examined and

5

testified as follows:

6
7

EXAMINATION
BY MS. ABUDU:

8

Q.

Could you state your name for the record?

9

A.

My name is Brenda Chapman Williams.

10

Q.

And what is your race?

11

A.

I am an African American.

12

Q.

Where do you live?

13

A.

I live in Sumter, South Carolina.

14

Q.

How long have you lived in Sumter?

15

A.

I lived there for 30 years.

16

Q.

Where were you born?

17

A.

I was born in Savannah, Georgia.

18

Q.

So, other than Georgia and South Carolina, have you

19

lived anywhere else?

20

A.

No.

21

Q.

So, does that mean that you lived in the south your

22

entire life?

23

A.

Yes, ma'am.

24

Q.

What do you do for a living?

25

A.

I am a Doctor of Medicine.

78

1

Q.

How long have you been a doctor?

2

A.

I've been a Doctor of Medicine for 32 years.

3

Q.

And are you in private practice or do you work for a

4
5

hospital?
A.

I am in the private practice of medicine with my

6

husband who is also a physician at the Excelsior Medical

7

Clinic in Sumter, South Carolina.

8

Q.

So how would you describe your patients?

9

A.

My patients generally are African American. Most of

10

them are over the age of 65, so they are in the geriatric

11

population. And usually they come from families wherein they

12

have to depend on the family members for a lot of support.

13

They are also of Medicare and Medicaid qualifications. Most

14

of them are indigent people.

15
16
17
18
19
20
21

Q.

Now, are you active in your community outside of your

professional work?
A.

Yes, ma'am. I'm very active in and outside of my

community.
Q.

So, are you a member of any organizations, and if so,

could you let the Court know?
A.

Yes, ma'am. I am a Golden Heritage Life Member of the

22

NAACP. I am an active member of the American Medical

23

Association. I'm also an active member of the National

24

Medical Association. I am the Executive Director and

25

President of the Family Unit, Incorporated. I am a member of

79

1

the Victory Full Gospel Interdenominational Church, also of

2

Sumter.

3

Q.

4
5

Well, let's talk a little bit about the Family Unit.

What is the Family Unit's mission?
A.

The Family Unit is a 501(c)(3) organization, a

6

charitable nonprofit organization, which is designed primarily

7

to raise the living standards of people living in poverty.

8
9
10
11

Q.

And you indicated you're a nonprofit organization. Do

you receive any federal grants or foundation -- money from
foundations?
A.

No, ma'am. We receive no federal government funds or

12

grants, nor grants from any private foundation. My husband

13

and I fund about 99.9 percent of the funds of the Family Unit.

14

However, we have some very compassionate people in our

15

community who have donated as little as $1.50 to the

16

organization, which we are very grateful. We have received

17

some in-kind donations over the years from some companies.

18
19
20

Q.

Okay. Now, how do you go about achieving the Family

Unit's mission?
A.

Well, the Family Unit has a multifaceted purpose. We

21

have a senior citizen division, wherein we provide recycled

22

cell phones that can only dial 911. We give these out for

23

free to senior citizens who live in high crime areas. We also

24

have a children's division called the Do Right Kids. They

25

range in ages from 15 months old to 22 years old. And we

80

1

strive to teach these children to always do what is right. We

2

are introducing the concept of doing right to even babies.

3

We also have a division of the Family Unit

4

wherein we go into the lowest economic areas, devastated

5

areas, and find homes that are abandoned. We have been, by

6

God's grace, been able to renovate at least three homes and

7

give them away totally free to families who are striving to do

8

right, and to families who are active in their children's

9

lives in school.

10

We are also have a division wherein we register

11

people to vote and encourage those individuals to become

12

politically active and tax paying citizens. We have a

13

division wherein we go out into the jail, the Sumter-Lee

14

Regional Detention Center, and have done so regularly for the

15

past five years. Every three months we are out at the jail.

16

And we have a Family Unit Do Right Crew at the jail.

17

We challenge the inmates to do the right thing

18

inside of the jail, and we will help them when they get out of

19

jail. And we've been successful in helping those inmates,

20

many of whom get jobs and keep the recidivism down.

21

Q.

I'm sorry to interrupt you.

22

A.

Sorry.

23

Q.

In terms of the work that you do inside the jails, does

24

any of that include voter registration or voter education

25

work?

81

1

A.

Yes, ma'am. We have been engaged, very actively, in

2

voter registration inside the jail. The State of South

3

Carolina allows inmates who are awaiting trial to vote. It

4

has been a mission of ours to register those inmates, and we

5

help them to vote by way of absentee voting inside the jail,

6

and have done so for the past five years.

7
8

Q.

All right. Now, you know that this case is about the

photo ID law that South Carolina has passed; do you know that?

9

A.

Yes, ma'am.

10

Q.

And when did you first become aware of this law?

11

A.

In March 2001 it came to my attention that the

12

legislators in South Carolina were seriously pushing through

13

this voter ID bill. It struck my attention acutely basically

14

because I knew that in the practice of medicine for 30 years,

15

we, my husband and I, have treated tens of thousands of

16

citizens of South Carolina, and many of whom had never ever

17

had a government-issued photo ID.

18

These individuals were birthed by midwives, 60,

19

70, 80, 90 years ago, during the time wherein documentation of

20

birth wasn't that important, in the south, particularly. And

21

so there were many individuals who had lived 60, 70, 80 plus

22

years who had never had a birth certificate, who had Medicare

23

and Medicaid because birth certificates aren't even required

24

to get Medicare and Medicaid. They have social security

25

numbers. Birth certificates were not required and still are

82

1

not required for social security numbers.

2

So, I became acutely concerned that these decent

3

human citizens would be denied the right to vote by this voter

4

ID bill. And then I became vigilant in fighting this bill.

5
6

Q.

I just want to be clear. I believe you testified you

became aware of the law in 2001?

7

A.

I'm sorry, I made a mistake. 2011. I'm so sorry.

8

Q.

All right. Now, you have indicated that you were --

9
10

you understood that there would be some people who would be
affected by this law?

11

A.

Yes, ma'am.

12

Q.

Did any of these individuals approach you about the

13

law?

14

A.

Yes. As a matter of fact, it was at my beckoning and

15

call, when -- in March 2011 I realized -- March 9th, 2011, to

16

be exact, I realized that this law was indeed being pushed

17

through, I personally went to the Department of Motor Vehicles

18

in my car. I drove with my checkbook -- the checkbook of the

19

Family Unit. We only had $200 in the checkbook.

20

And I said to myself: I'm going to take it upon

21

myself to do whatever I can as an individual to help as many

22

people as I could to get photo IDs. So, I went to the DMV

23

looking to open up an account with them.

24
25

Q.

Okay. Well, let me just stop you right there to

clarify. Now, you indicated that there were individuals who

83

1
2

approached you about the photo ID law?
A.

Yes, ma'am. And it was after my trip to the DMV when I

3

found out that I could not set up an account with the DMV and

4

pay them $200. I thought that the cost would be $5. And $5

5

into $200 goes 40 times. So, I wanted to pay for 40 of these

6

strangers off the street to get ID. I found out I couldn't do

7

that, there were rules.

8
9

Q.

And I definitely would like for you to talk about that.

But in terms of the individuals --

10

A.

Yes.

11

Q.

-- were any of the individuals who approached you about

12
13

the law, are they apart of this litigation?
A.

Yes, ma'am. As a matter of fact, 65 people came to me.

14

The flood gates were open. I put out flyers in the community

15

and got on the radio, TV, local newspaper, saying the Family

16

Unit is going to help people get IDs. 65 came. Six of those

17

are litigants in this case.

18

Amanda Wolf. Matter of fact, she's one of my

19

medical assistants, was adopted and never had a birth

20

certificate. So, we went through much to find out who her

21

parents were. Amanda also needed a driver's -- I'm sorry, she

22

needed a marriage license. Amanda needed a divorce decree, we

23

had to help her.

24
25

Mr. James Dubose, an indigent man, never finished
the first grade, came to me. Never had -- well, he had a

84

1

birth certificate, but it was damaged in a fire. It was

2

destroyed in a fire. Mr. Junior Glover, another individual,

3

never had a birth certificate. Mr. Raymond Rutherford, works

4

at Wal-Mart -- has been working at Wal-Mart for three years in

5

Sumter. He never had a birth certificate in his life. His

6

sister -- as a matter of fact, his name was misspelled as

7

Ramon instead of Raymond on his birth certificate.

8

His sister, Mrs. Naomi Gordon, on her birth

9

certificate her name was spelled LNNOIE, was Naomi. So these

10

individuals are litigants in this case, however 65 people came

11

and we were able to purchase birth certificates for those

12

other persons.

13

Q.

Well, if you could just provide a little bit more

14

detail in terms of the process that you took to assist these

15

individuals?

16

A.

Yes, ma'am. The process was very complicated, very

17

exhausting and extremely expensive. I -- initially when the

18

first person came to me, had to catch a ride 40 miles to

19

travel to Sumter. I contacted the Health Department, the

20

first place I thought you can get birth certificates from.

21

You couldn't get a birth certificate from the

22

Health Department because you don't have a photo ID. So, the

23

Health Department referred me to the Department of Vital

24

Statistics. The Vital Statistics people said: No way, this

25

person needs a government-issued photo ID, Dr. Williams. You

85

1

need to go to Vital Check. Vital Check is a registry. It's a

2

national registry for birth certificates, marriage licenses,

3

death certificates, divorce decrees.

4

So, I subsequently went online to Vital Check and

5

I found out instantaneously that one must have a major credit

6

card to order any vital records. One must have a MasterCard,

7

Visa, American Express or a Discover card, and one must have

8

an e-mail address. I was floored.

9

Q.

To your knowledge did any of the individuals you were

10

assisting have a credit card or an e-mail account to go

11

through this process on their own?

12

A.

No, ma'am. All of the individuals that came for help

13

were indigent people. They lived in blighted communities

14

where there's poverty. They lived in communities where there

15

are boarded homes and shambles. They come from communities

16

wherein there's a lot of crime. 99.9 percent of the people

17

that came for help had less than a high school education. The

18

average education level was the 7th grade.

19

And so these individuals came by walking, they

20

caught rides and had to pay people to ride them and so forth.

21

So, none of these individuals had the wherewithal to even

22

order the certificates -- the documents that they needed.

23
24
25

Q.

So, in order to get those documents, how were those

documents purchased or who paid for all of that?
A.

Yes, ma'am. As I mentioned, the Family Unit,

86

1

Incorporated, had $200 in the checking account. First it

2

started out with $2 and my husband and I kicked in the $198 to

3

round it off to $200. That $200 was exhausted in two days

4

after helping three people. We were famished. We had no more

5

money.

6

So, therefore, I pulled out my credit card, my

7

Visa card, and proceeded to pay for the documents for all 65

8

people. And the average cost was $47.70. And that's for

9

people who were born in South Carolina. We had several who

10

were born out of state but now lived in South Carolina, and

11

those individuals -- one came from New York. The average cost

12

for that birth certificate was $71.70. There were two from

13

Connecticut. The average cost for those birth certificates

14

was $71.70.

15
16
17
18

One might ask the question: Why so much? Well,
the birth certificate generally is $30 -Q.

Okay. I'm just going to have to stop you there,

Dr. Williams, I apologize, it's just with limited time --

19

A.

I'm sorry.

20

Q.

In addition to going through Vital Check, was there any

21

other route that you had to take to help people with birth

22

certificates?

23

A.

Yes, ma'am. Matter of fact, I took a two-pronged

24

approach to this problem. I called it a "just in case"

25

approach, and that was this. I decided to take it upon myself

87

1

to help as many people as possible to get photo IDs from the

2

DMV so they wouldn't be disenfranchised. That is the first

3

point. I wanted to help them.

4

Secondly, I wanted to fight this very bad bill --

5

that I considered very, very bad -- by going through the ACLU.

6

I contacted the ACLU by way of phone, the 1-800 number. I

7

contacted the Justice Department. I wrote innumerable letters

8

to the Justice Department. I sent e-mails, faxes to the

9

Justice Department. I sent a box with pictures of the people

10

that came to me.

11

I made up affidavits myself at 3:00 a.m. one

12

morning in my office. And I got those persons to sign the

13

affidavits, explaining to them what an affidavit was, because

14

none of them knew even what an affidavit was.

15

Q.

Okay. And at any point did you have to seek the

16

assistance of others in getting these people birth

17

certificates?

18

A.

Yes, ma'am. I sent out letters to all of the attorneys

19

in Sumter County, and also I called the attorneys on the

20

phone. I send out e-mails entitled legal help desperately

21

needed.

22

Q.

23
24
25

And did any of these attorneys volunteer their time or

assistance to you in getting people birth certificates?
A.

Yes. We were graced by the help of a handful of

attorneys, one was a retired Family Court Judge, Judge

88

1

Ruben L. Gray, who was very gracious. Matter of fact, he's a

2

patient of ours. Very gracious, to volunteering many hours.

3

He helped at least 20 people get photo IDs on his own pro

4

bono.

5

Q.

6

Do you believe, to your knowledge -HON. COLLEEN KOLLAR-KOTELLY: Stop one second.

7

Does somebody have a phone on? Because obviously there's a

8

problem here. We can tell, it interferes. Either counsel or

9

witnesses or do people in the audience have phones on? Did

10

you not see the notice outside? Electronics are off. No

11

photos. No recording. Okay. I don't hear the buzz, so

12

somebody has turned it off. Go ahead. Sorry to interrupt.

13

BY MS. ABUDU:

14

Q.

Now, to your knowledge, would these individuals have

15

been able to navigate the process of getting a birth

16

certificate in some instances without an attorney's -- without

17

an attorney?

18

A.

Oh, no, ma'am.

19

Q.

And would they have been able to -- well, you testified

20

that, for example, Judge Gray provided his assistance pro

21

bono, is that correct?

22

A.

That's correct.

23

Q.

And the individuals who he helped, would they have been

24

able, to your knowledge, would they have been able to afford

25

his legal fees?

89

1

A.

No, ma'am. Judge Gray charged $1,800 generally for

2

that kind of service, and he did it by his graciousness

3

pro bono.

4

Q.

Now, do you assist voters with absentee voting at all?

5

A.

Yes, ma'am.

6

Q.

And are any of the voter you assist, are they able to

7

read or are some of them illiterate?

8

A.

Most of them are barely literate.

9

Q.

And are you aware of any organizations in South

10

Carolina, in Sumter in particular, that are providing the

11

level of assistance to voters that the Family Unit and that

12

you provide?

13

A.

No, ma'am.

14

Q.

Now, you testified earlier that you lived in the south

15

all your life, correct?

16

A.

Yes.

17

Q.

Are you a registered voter in South Carolina?

18

A.

Yes, ma'am.

19

Q.

And do you believe or do you -- now that the photo ID

20

law has been passed in South Carolina, does that law increase

21

your confidence in how elections are handled?

22

A.

Oh, absolutely not. As a matter of fact, it makes me

23

terrified. I have never worked so hard to register people in

24

my life than since the advent of the photo ID bill. My

25

husband and I have registered people in our office to vote for

90

1

30 years, and never in 30 years have I had such difficulty. I

2

am months behind in just doing plain old voter registration.

3

Because of the substantial burdens, financially and otherwise,

4

that have brought upon myself just helping people. Most of

5

the people that have come for help are indigent.

6

MS. ABUDU: I apologize, I have to cut you off, Dr.

7

Williams, but I have no further questions at this time. I

8

pass the witness.

9

THE WITNESS: Thank you.

10
11

HON. COLLEEN KOLLAR-KOTELLY: All right. South
Carolina.

12
13
14

EXAMINATION
BY MR. McGINLEY:
Q.

Your Honors, Dr. Williams, Mike McGinley, we spoke on

15

the phone a few months ago for our deposition, do you remember

16

that?

17

A.

Good morning. Yes.

18

Q.

Good morning, good to see you.

19
20

MR. McGINLEY: Permission to approach the witness
with her deposition, please.

21
22
23
24
25

HON. COLLEEN KOLLAR-KOTELLY: Yes.
BY MR. McGINLEY:
Q.

Dr. Williams, you just described the work that you've

done with people trying to get them birth certificates?
A.

Yes.

91

1

Q.

And DMV ID, correct?

2

A.

Yes, sir.

3

Q.

But Act R54 would provide for other means of

4
5

identification at the polls, correct?
A.

Oh, yes, there are other means of identification that

6

will be acceptable, according to the Voter ID Law of South

7

Carolina. Do you want me to name them?

8
9

Q.

Is there a photo voter registration card that you're

aware of?

10

A.

Yes.

11

Q.

Would a person need a birth certificate to obtain one

12
13

of those?
A.

According to the law as it is written, no. But even

14

with that, I have some grave concerns about even that photo

15

voter registration card. May I expound on that now or do you

16

want me to do that later?

17

Q.

I can ask you a few questions first.

18

A.

Okay.

19

Q.

To obtain that photo voter registration card, would the

20

voter have to have their current voter registration card and

21

trade that in to get a photograph on it?

22

A.

Well, it's not that easy, to tell you the honest to

23

God's truth. It sounds very simple. And it's flawed, whoever

24

designed it, because the law says that the persons who present

25

themselves to the voter registration office need only to say

92

1

the last four digits of their social security number and their

2

date of birth.

3

I found that flawed, basically because many of

4

the persons that we treat, and have treated for 30 years in

5

Sumter, have confusion as to which day they were born on.

6

Many of their births were not documented, so this went by word

7

of mouth from a relative. You were born in 1923. Anybody

8

asks you, tell them you were born in '23. And then a relative

9

down the road would say, no, you weren't born the '23, Sugar,

10
11

you were born in 1924.
So, in essence, when someone is asked the

12

question, what year were they born, in the south, my

13

experience has shown that that is not a relevant question.

14

You know why? Basically, because as physicians, as I

15

mentioned, my husband is a geriatrician, a Board-certified

16

geriatrician. And we have over the years -- not just myself

17

and my husband -- physicians, particularly in the south, have

18

always had the experience of patients coming to us, saying:

19

Dr. Williams, can you write a letter stating that I was born

20

in 1915, ma'am, because the people down at the bank want a

21

statement from your medical doctor.

22

So, looking at that person's medical records we

23

have been following for 30 years, those persons -- I'll say,

24

I'll look at the records. Yes, ma'am. Well, you came to us

25

and you told us you were born in 1915. And we would have to

93

1

write letters verifying their age. So, when a person goes to

2

the voter registration office, saying: I want a photo ID.

3

Excuse me, I want a photo voter registration card, sir. Just

4

stating the date of birth, some people might be confused as

5

the what date they should tell them.

6
7

Q.

Sure. Sure. I understand that. Can I direct you to

Page 28 of your deposition, please.

8

A.

Yes.

9

Q.

And we're going to start on Line 10.

10
11

MR. McGINLEY: And for the Court, we'll be
finishing on line 15.

12

HON. COLLEEN KOLLAR-KOTELLY: Let her find it.

13

HON. JOHN D. BATES: Page 28, Lines 10 through 15.

14

THE WITNESS: Yes, sir.

15
16
17

BY MR. McGINLEY:
Q.

So, I'll just read from the deposition here, and you

can let me know if this is correct.

18

A.

Yes, sir.

19

Q.

If a person has a current voter registration card and

20

the law is precleared, will they be able to go to their local

21

county election office and obtain a photo voter registration

22

card? Answer: Well, according to the document, the voter ID

23

law, they should be able.

24
25

Is that correct?
A.

Yes.

94

1
2

Q.

And, Dr. Williams, when we spoke later in that

deposition --

3

MS. ABUDU: Objection, Your Honor. Counsel didn't

4

finish reading Dr. Williams' entire response in the sentence.

5
6

HON. COLLEEN KOLLAR-KOTELLY: All right. Then read
the rest of it.

7
8
9

MR. McGINLEY: I apologize.
BY MR. McGINLEY:
Q.

So, I'll reread the Answer. Well, according to that

10

document, the voter ID law, they should be able. I'm not

11

going to say yes, they can do that, because I don't know.

12

Dr. Williams, do you have any reason to believe

13

that a person cannot present their voter registration card and

14

obtain a photo voter registration card?

15

A.

Let me put it like this. The state wants the world to

16

believe that just by having a photo voter registration card,

17

that will be the cure all and panacea for people voting in

18

South Carolina without problems.

19
20
21
22
23
24
25

Now, let me tell you, if I may, why I strongly
disagree and challenge this.
Q.

Well, if I could ask you -HON. COLLEEN KOLLAR-KOTELLY: You have to listen to

his question.
THE WITNESS: Oh, I'm sorry.

95

1
2

BY MR. McGINLEY:
Q.

My only question is whether you disagree with the fact

3

that a person could obtain the photo voter registration card

4

by presenting their current voter registration card?

5

A.

I don't disagree with that at all.

6

Q.

Okay. And do you also remember when we spoke in your

7

deposition, I asked if you could identify anybody who would

8

not be able to obtain one of those photo voter registration

9

cards, and you identified one person, I believe his name was

10

Mr. House; is that correct?

11

A.

Yes, Mr. Joseph House.

12

Q.

Do you remember that later in that conversation you

13

also informed me that Mr. House has a voter registration card,

14

and thus, he could obtain a photo voter registration card?

15

A.

Yes. He had applied for a voter registration card. So

16

at the time that you asked the question, actually,

17

technically, he did not have the card in his possession. His

18

application was at the voter registration office. However, if

19

I might add my serious concerns about this photo voter

20

registration card, because it is made to seem that all a

21

person needs -- would be to have a voter registration card

22

with a photo, and that person would catch no problems at the

23

polls.

24
25

And I challenge that, mainly because the same
South Carolina voter ID law specifically states that the poll

96

1

managers may require further identification at the polls.

2

And, also, the poll manager may require the voter to prove his

3

or her right to vote. And that is --

4
5

HON. COLLEEN KOLLAR-KOTELLY: I think you can stop
here. You're get a little beyond what his question was.

6
7
8
9

THE WITNESS: Oh, I'm sorry.
BY MR. McGINLEY:
Q.

I just want to confirm. You would agree that Mr. House

would be able to obtain a photo voter registration card?

10

A.

Yes, sir.

11

Q.

And I believe I just have one more question for you --

12

or maybe one or two more questions, Dr. Williams. So, you

13

said earlier that your mission is to ensure that every person

14

that you can help is able to obtain identification in order to

15

vote?

16

A.

Yes, sir.

17

Q.

And, so, is it safe to assume that if the photo voter

18

registration cards became available in South Carolina upon

19

preclearance, that you would similarly attempt to help all the

20

people that you've attempted to help so far to obtain that

21

photo voter registration card?

22

A.

Yes. My efforts to help people will never end, never

23

end. However, I have no control, though, over the poll

24

managers and how they operate.

25

Q.

Sure.

97

1

A.

In South Carolina there are 46 counties --

2
3

HON. COLLEEN KOLLAR-KOTELLY: We're not talking
about that. That's not what he asked.

4
5
6

THE WITNESS: Yes.
BY MR. McGINLEY:
Q.

Then my last question is, am I correct, from your

7

earlier testimony, that the Family Unit primarily helps people

8

in lower socioeconomic areas that are predominantly African

9

American?

10
11
12

A.

Yes, sir.
MR. McGINLEY: Thank you, Dr. Williams. Have a

safe trip home.

13

THE WITNESS: Thank you very kindly.

14

HON. COLLEEN KOLLAR-KOTELLY: Any redirect?

15

MS. ABUDU: I have no further questions for

16

Dr. Williams.

17

MR. HEARD: Nothing for the United States.

18

HON. COLLEEN KOLLAR-KOTELLY: Thank you very much.

19

You're excused.

20

HON. JOHN D. BATES: Thank you for coming.

21

THE WITNESS: God bless you.

22

HON. JOHN D. BATES: Thank you.

23

HON. COLLEEN KOLLAR-KOTELLY: Your next witness.

24

MR. BEENEY: Yes, Your Honor, with the Court's

25

permission, we would like to call Mr. Craig Debose. Ms. Lisa

98

1

Genn from the Brennan Center for Justice will be conducted the

2

direct examination with the permission of the Court. Thank

3

you very much.

4
5

MR. McGINLEY: Could I just obtain the deposition
binder that is up there?

6

HON. COLLEEN KOLLAR-KOTELLY: Yes. Go ahead. Sir,

7

if you'd step up over here, please.

8

Thereupon,

9

CRAIG DEBOSE,

10

the witness herein, having been duly sworn, was examined and

11

testified as follows:

12
13

EXAMINATION
BY MS. GENN:

14

Q.

Good morning, Your Honors. Good morning, Mr. Debose.

15

A.

Good morning.

16

Q.

Would you please state your name for the record?

17

A.

Craig Otto Debose.

18

Q.

Mr. Debose, without giving us your exact address, where

19
20

do you currently live?
A.

I live at 76 --

21

HON. COLLEEN KOLLAR-KOTELLY: You don't need.

22

MS. GENN: Without giving us your address.

23

HON. COLLEEN KOLLAR-KOTELLY: Mr. Debose, you don't

24

need to give us the exact address. Can you tell us where,

25

what state, what city or town you live?

99

1
2
3
4

THE WITNESS: St. Helena Island, South Carolina.
BY MS. GENN:
Q.

How did you get to Washington, D.C. from St. Helena

Island in South Carolina?

5

A.

I took a train.

6

Q.

How long did that take you?

7

A.

Oh, 11 hours.

8

Q.

And how long did it take you to get to the train from

9

where you live?

10

A.

About an hour and 15 minutes.

11

Q.

How did you get there?

12

A.

By taxi.

13

Q.

And why did you come all this way to tell the Court

14

your story?

15

A.

So I can vote.

16

Q.

Where were you born, Mr. Debose?

17

A.

North New Jersey.

18

Q.

When was that?

19

A.

March 3rd, 1949.

20

Q.

Could you please tell us what your race is?

21

A.

Biracial.

22

Q.

Could you describe your education for us?

23

A.

High school.

24

Q.

Did you get any education after that?

25

A.

Not really, as far as, you know, furthering my

100

1

education.

2

Q.

Did you take any classes at all even if --

3

A.

I took some classes while -- after I graduated, I took

4

some classes at Newark School of Fine & Industrial Arts.

5

Q.

Why didn't you complete that degree?

6

A.

Vietnam.

7

Q.

So you served in the military?

8

A.

Yes.

9

Q.

What was your role?

10

A.

I was an aircraft mechanic.

11

Q.

For how long?

12

A.

6 years, 11 months, 2 weeks, roughly that.

13

Q.

Mr. Debose, do you have a current military ID?

14

A.

I don't have a current ID. I have a VA card, though.

15

Q.

When did you come to South Carolina?

16

A.

I believe it was October 19 -- no, 2004.

17

Q.

Why did you move to South Carolina at that time?

18

A.

Excuse me.

19

Q.

Why did you move to South Carolina at that time?

20

A.

Truthfully, I got tired of North New Jersey.

21

Q.

Was there any other reason? Was there any other reason

22

why you moved to South Carolina then?

23

A.

I was looking for a better place to live, basically.

24

Q.

And do you have any family in South Carolina?

25

A.

Yes, I have two brothers.

101

1

Q.

Where do they live?

2

A.

One lives in Bluffton, South Carolina, and the other is

3

in Hilton Head, South Carolina.

4

Q.

How far away are those places from where you live?

5

A.

I would say 30 miles for Bluffton and about 40 miles

6

for Hilton Head.

7

Q.

Does anyone live with you in your home?

8

A.

No, they don't.

9
10

HON. COLLEEN KOLLAR-KOTELLY: Slow down a little so
we can get a record.

11
12

MS. GENN: Of course, Your Honor.
BY MS. GENN:

13

Q.

Does anyone live with you in your home?

14

A.

No.

15

Q.

Where do you work, Mr. Debose?

16

A.

I work on St. Helena at a local junkyard.

17

Q.

What do you do there?

18

A.

I maintain customer service with the people that do

19
20
21

come to the establishment.
Q.

Can you tell us a little bit more about your what your

work involves?

22

A.

Okay. Excuse me.

23

Q.

Can you tell us a little bit more about what your work

24
25

involves?
A.

Customers will come in, they will be looking for

102

1

certain items, automotive items, you know, and they are the

2

older cars and they just can't find them in the stores

3

anymore. So, I provide my services as working with that.

4

Plus, I turn around and work independently on my own.

5

Q.

And how do you get to your work?

6

A.

Walk.

7

Q.

How far away is it?

8

A.

Me to the shop, about three quarters of a mile.

9

Q.

How many hours a week do you work?

10

A.

As many as I can, to be honest with you. That's

11

normally around 8 to 10, depending on what actually I'm having

12

to do that day.

13

Q.

Is that a day or a week?

14

A.

That's a day. Normally I'm working about a good 42-45

15

hours day -- a week, rather.

16

Q.

Do you have a working phone where you live?

17

A.

Just the office phone.

18

Q.

So that's not in your home?

19

A.

No, it's not.

20

Q.

And do you have any way to access the Internet where

21

you live?

22

A.

No, I don't.

23

Q.

Do you have access to a computer?

24

A.

No, I don't.

25

Q.

Do you a passport, Mr. Debose?

103

1

A.

No, I don't.

2

Q.

Do you have any need for one?

3

A.

At times I would like to have one, but I don't have

4

access.

5

Q.

That's to a passport?

6

A.

Excuse me.

7

Q.

Are you talking about a passport?

8

A.

I thought you were talking about a computer.

9

Q.

Going back to the question. Let me just say it again.

10

You don't have a passport, is that right?

11

A.

No, I don't.

12

Q.

Do you have any need for a passport? Do you have any

13

need for a passport?

14

A.

Not at this time. I would like to have one, though.

15

Q.

Do you own a car?

16

A.

No, I don't.

17

Q.

And do you have a driver's license?

18

A.

No, I don't.

19

Q.

Do you have a non-driver state issued ID?

20

A.

No, I don't.

21

Q.

And when was the last time you had a driver's license?

22

A.

I would say nine years ago.

23

Q.

Which state was that from?

24

A.

New Jersey.

25

Q.

What happened to that driver's license?

104

1

A.

I lost it.

2

Q.

And when was that?

3

A.

I believe it was about six months before I came to

4
5
6

South Carolina.
Q.

Have you tried to get a state issued ID since you lost

your New Jersey driver's license?

7

A.

Yes, I have.

8

Q.

Can you tell us about that?

9

A.

I have been to Motor Vehicles numerous times to acquire

10

an ID, period. And when I was there they would turn around

11

and tell me I would need a social security card. When I lost

12

my license and my wallet, I also lost my social security card.

13

So, I went to Social Security to apply for a card from them

14

and they turned around and told me I have to have an ID to

15

acquire a social security card. It's been somewhat of a

16

Catch-22 issue. You need one for one thing and you need the

17

other, back and forth.

18
19
20
21
22

Q.

And about how many times did you try to get a

DMV-issued ID in South Carolina?
A.

I would say I tried about twice a year for the last

7 years. So, 13-14 times.
Q.

And did you -- on all of those occasions did you try

23

going both to the DMV and then back to the Social Security

24

office?

25

A.

Yes.

105

1
2
3

Q.

And what kind of papers did you try to show to the DMV

in order to obtain the driver's license?
A.

I had my birth certificate. I had my DD Form 214, my

4

discharge papers with my social security number on it. I have

5

a county ID from the State of New Jersey, City of Newark.

6

What else did I have? I had my VA identification. But none

7

of those are acceptable.

8
9

Q.

And your VA card and the Essex County card, do those

have photos on them?

10

A.

Yeah, photo IDs.

11

Q.

Were those acceptable in order to get the South

12

Carolina driver's license?

13

A.

No, they weren't.

14

Q.

How far away is the DMV that you were going to to try

15

to accomplish this?

16

A.

25 to 30 miles.

17

Q.

Is that the closest one to where you live?

18

A.

Yes, that's in Beaufort.

19

HON. COLLEEN KOLLAR-KOTELLY: Excuse me a minute.

20

Did you say that the VA and the other county card, I didn't

21

see the answer on the record. Did they have a photo on them

22

or they didn't have a photo?

23
24
25

THE WITNESS: No, my VA card has an ID on it. My
county -HON. COLLEEN KOLLAR-KOTELLY: As a photo ID?

106

1

THE WITNESS: Yes, photo ID.

2

HON. COLLEEN KOLLAR-KOTELLY: Okay.

3

THE WITNESS: And my county card has a photo ID.

4

HON. COLLEEN KOLLAR-KOTELLY: Okay.

5
6
7

BY MS. GENN:
Q.

How far away is the Social Security Administration

office from where you live?

8

A.

Social Security?

9

Q.

Yes. How far away is that office from --

10

A.

About the same. They are both located in Beaufort.

11

Q.

How did you get to those offices on all of those

12

occasions when you tried to get --

13

A.

-- I either had to ask --

14

Q.

-- a document?

15

A.

-- friends of mine to take me and transport me, or I

16

would turn around and go down by cab occasionally when I could

17

afford it.

18
19

Q.

Mr. Debose, are you aware of a new law related to photo

identification to vote in South Carolina?

20

A.

I have heard about that law.

21

Q.

How did you first hear about it?

22

A.

I was listening to the radio. And the talk show I

23

listen to constantly, they brought the subject up about

24

needing identification in the State of South Carolina to vote.

25

Q.

And what was your reaction to that story?

107

1
2

A.

I couldn't understand why, you know, it became such a

necessity to have it to vote all of a sudden.

3

Q.

And what did you do when you heard that story?

4

A.

I contacted the agency that was discussing the matter

5

on the radio show, and they notified me to -- to certain other

6

agencies that I could get in touch with to find out more

7

information about it.

8
9

Q.

Is that how you ultimately came to be in contact with

us and involved in this case?

10

A.

Yes, it is.

11

Q.

And at that point in time were you registered to vote

12

in South Carolina?

13

A.

No, I wasn't.

14

Q.

Why was that?

15

A.

I really haven't been politically involved in too much

16

politicians. But the one thing I really wanted to do was to

17

have a vote before I die. I'm 63 years old, and that was one

18

thing I said I was going to do for myself.

19
20
21

Q.

And what was your understanding at that time of what

identification you needed then in order to be able to vote?
A.

I wasn't sure of it, but like I said, I found out

22

identification, and I later found out I needed a voter

23

registration card.

24
25

Q.

Did you have an understanding at the time that you

already needed some kind of ID that you didn't have in order

108

1

to vote?

2

A.

No. I found out -- I understood the principle of the

3

matter.

4

Q.

Just to go back. This is in -- what time period are

5

you talking about? This is when you first were starting to

6

get involved in the case after you heard this story on the

7

radio?

8

A.

9

Both. Once I heard this situation, I turned around and

applied for my voter registration card.

10

Q.

And how did you first attempt to do that?

11

A.

It was one of the matters where I found out I need to

12

register to vote. Like I said, I never was politically

13

involved. I would turn around -- and deep in my heart, I

14

said, like I said, I wanted to turn around and actually,

15

before I die, vote.

16

Q.

And so what did you do? It sounds like you were

17

motivated to vote. What did you do in order to become

18

registered?

19
20

A.

I had to go down to the county voter registration

office to register.

21

Q.

And how did you try to get that there?

22

A.

I tried to have a few friends that would take me down,

23
24
25

but they weren't available at the time. I had to take a cab.
Q.

And did you have to get assistance from your attorneys

in order to be able to get down there?

109

1
2
3
4
5
6

A.

Yes, I did. That's how I found out about the

registration.
Q.

And as far as you know now, currently, are you able to

use that voter registration card in order to vote?
A.

Yes. But I have to have ID with it, from what I

understand.

7

Q.

And, Mr. Debose, have you ever voted before?

8

A.

No, I haven't.

9

Q.

Can you just explain why not?

10

A.

In the beginning when I was 18 years old, I was in the

11

service. I did not want to vote for somebody who might send

12

me to war and I become a casualty of it. After that I turned

13

around and I never really found any of the candidates

14

worthwhile voting for.

15

Q.

And at some point did that change?

16

A.

Yes, it did.

17

Q.

When was that?

18

A.

In 2008.

19

Q.

Can you tell us about that?

20

A.

I found out that President Obama was running for

21

office, and I decided I would like to vote for the man.

22

Q.

And why didn't you vote then?

23

A.

No ID. Like I said, I was under the assumption you had

24

to turn around and have identification to vote. I did not

25

have identification, so I didn't vote. I think that might

110

1

have been just my ignorance because I didn't know if there was

2

any other way I could go about it. But the biggest reason I

3

was going to vote was -- like I said, for President Obama, it

4

wasn't just a white or black issue, he's like I am, a biracial

5

individual.

6
7

Q.

Mr. Debose, do you know where you'd have to go in order

to vote?

8

A.

Yes, I do.

9

Q.

How far away is the polling place?

10

A.

That's about five miles from where I live at.

11

Q.

How would you get there?

12

A.

I would have to walk.

13

Q.

Most of the time how do you get around St. Helena

14

Island?

15

A.

Walking.

16

Q.

When was the last time you were on a plane?

17

A.

9 to 10 years ago.

18

Q.

How about a bus?

19

A.

About 5-6 years ago.

20

Q.

And is there any public transportation that goes to

21

St. Helena Island?

22

A.

None whatsoever.

23

Q.

How far away is the nearest bus stop from your home?

24

A.

30 miles.

25

Q.

You mentioned that you sometimes rely on friends to

111

1

drive you places, is that right?

2

A.

Yes.

3

Q.

And how do you feel about asking them to do that?

4

A.

It's kind of, not embarrassing, but kind of a humbling

5

feeling because I have to ask, wherever I go, to have somebody

6

take me somewhere. And normally I have to wind up paying for

7

it -- to take me somewhere.

8

Q.

And how much do you have to pay friends --

9

A.

-- I normally --

10

Q.

-- to do that?

11

A.

-- pay them $20 for a trip from St. Helena to Beaufort

12
13
14
15
16

and back.
Q.

Does that include gas or do you have to pay separately

for gas?
A.

Sometimes it includes gas in a round trip and sometimes

it takes more.

17

Q.

Are your friends always available when you ask them?

18

A.

No, I don't find it all the time. I usually have to go

19
20
21

on their schedules.
Q.

Do you have to ever ask your friends to take time off

from their work in order to drive you?

22

A.

Yes, I have.

23

Q.

And do you have to ask them to wait for you?

24

A.

Yes, I have.

25

Q.

Did that happen sometimes when you tried to go to the

112

1

DMV?

2

A.

Yes, I had -- one, when I went to Motor Vehicles and

3

the Social Security office, I had them waiting roughly -- one

4

place it was almost 70 minutes and another one was about

5

another 45 minutes. So, almost three hours.

6

Q.

If you had to go to the county election officer in

7

Beaufort to get another form of ID, what steps would you have

8

to take?

9

A.

I would first have to contact one of my friends to take

10

me down to the voter registration office and apply. Like I

11

said, another time away from job, and they will probably have

12

to take off work because it's going to be during business

13

hours that they operate.

14

Q.

And you would have to forego your own pay for the day?

15

A.

Yes, I would.

16

MS. GENN: No further questions at this time.

17

HON. COLLEEN KOLLAR-KOTELLY: All right. South

18

Carolina.

19
20

MR. FIELD: Good morning, Your Honors. Brian Field
on behalf of the State of South Carolina.

21
22

EXAMINATION
BY MR. FIELD:

23

Q.

Good morning, Mr. Debose.

24

A.

Good morning.

25

Q.

My name is Brian Field and I'm one of the attorneys

113

1
2

representing the State of South Carolina.
A.

3

Okay.
HON. COLLEEN KOLLAR-KOTELLY: You need to move the

4

microphone up.

5

BY MR. FIELD:

6

Q.

I have just a few questions for you this morning.

7

A.

Go right ahead.

8

Q.

Just to make sure that I am clear. So, you are

9
10

registered to vote and you also have a voter registration
card, isn't that correct?

11

A.

Yes, I do.

12

Q.

And you know your social security number, correct?

13

A.

Yes, I do.

14

Q.

And you know your date of birth, correct?

15

A.

Yes, I do.

16

Q.

And you said that St. Helena Island, this is about 20

17

minutes from Beaufort?

18

A.

No, 20 miles.

19

Q.

20 miles. Okay. And you registered to vote in

20
21

February -HON. COLLEEN KOLLAR-KOTELLY: Could you slow down a

22

little bit. It doesn't make it any better by going faster to

23

take the time. You need to make a record and we need to hear

24

what you're saying.

25

114

1
2
3

BY MR. FIELD:
Q.

And you registered to vote in February of this year, is

that correct?

4

A.

Yes.

5

Q.

And you went to Beaufort to register, is that correct?

6

A.

Yes.

7

Q.

And that's to the voter registration officer on John

8

Galt Road, is that correct?

9

A.

I believe that's the road.

10

Q.

And do you recall in your deposition when you were

11

asked if you're able to get rides on occasion, and you

12

answered: Yes, I have friends that I can call to get rides?

13

A.

Yes.

14

Q.

Do you recall whether at that time you qualified that

15

it would be difficult to get rides?

16

A.

Yes.

17

Q.

You believe that you did qualify that?

18

A.

That it was hard for me to get rides?

19

Q.

Do you remember saying, when the question was asked:

20

Are you able to get rides in a car from anyone on occasion?

21

And answering: Yes. I have people I do give a call to when I

22

have distances to go. They will give me rides.

23

A.

I said that.

24

Q.

And are you aware of a free ride program offered by the

25

South Carolina Department of Transportation?

115

1

A.

No, I'm not.

2

Q.

And you set your own hours, correct?

3

A.

I set my own working hours. I do work for proprietor,

4
5
6

and I give him my hours as well.
Q.

And you testified that you work about 40 to 50 hours a

week, is that correct?

7

A.

Yes.

8

Q.

So, if you needed to, you would be able to get to the

9

county election office in Beaufort, isn't that right?

10

A.

If I needed to --

11

Q.

If you needed to get to the county office?

12

A.

I would make a way, yes.

13

Q.

Okay. And, lastly, has anyone told you that if this

14

voter ID law goes into effect that you would be able to get a

15

photo ID from the county election office?

16
17

A.

If the law goes into effect that I would be able to get

a photo ID?

18

Q.

Yes.

19

A.

I have heard that.

20

MR. FIELD: No other questions.

21

MR. HEARD: Nothing from the United States, Your

22

Honor.

23
24
25

EXAMINATION
BY MS. GENN:
Q.

Mr. Debose, I have one follow-up question.

116

1

A.

Yes.

2

Q.

You were asked whether you set your own hours.

3

A.

Yes.

4

Q.

Do you nevertheless sometimes have to confer with the

5

owner of the yard before --

6

A.

-- yes, I do.

7

Q.

-- being able to take time off?

8

A.

Every time.

9

MS. GENN: Thank you.

10
11

HON. COLLEEN KOLLAR-KOTELLY: All right. You're
excused at this time, sir.

12
13

HON. JOHN D. BATES: Thank you for coming,
Mr. Debose.

14

HON. COLLEEN KOLLAR-KOTELLY: Thank you.

15

MR. BEENEY: If I may at this time, Your Honors,

16

introduce to the Court Ms. Mimi Marziani also from the Brennan

17

Center for Justice with respect to our next witness.

18
19

HON. COLLEEN KOLLAR-KOTELLY: And the next witness
is?

20
21

MR. BEENEY: Dr. Andrew Martin, who is appearing by
written direct.

22
23

MS. MARZIANI: Good morning. I'd like to call to
the stand Dr. Andrew Martin.

24
25

HON. COLLEEN KOLLAR-KOTELLY: Sir, if you'd step up
over here.

117

1

Thereupon,

2

ANDREW D. MARTIN,

3

the witness herein, having been duly sworn, was examined and

4

testified as follows:

5

MS. MARZIANI: Your Honors, we submitted written --

6

or direct testimony in written form, and we have no further

7

questions at this time.

8

HON. COLLEEN KOLLAR-KOTELLY: All right.

9

MR. FIELD: Brian Field, again, on behalf of the

10

State of South Carolina. May I approach the witness to

11

provide him with a copy of his deposition.

12

HON. COLLEEN KOLLAR-KOTELLY: Yes.

13

MR. FIELD: Thank you.

14
15

EXAMINATION
BY MR. FIELD:

16

Q.

Good morning, Dr. Martin.

17

A.

Good morning, Mr. Field.

18

Q.

It's good to see you again. In your written testimony

19

you state that blacks are 1.5 times more likely than whites to

20

cast an in-person absentee ballot, is that correct?

21

A.

Yes.

22

Q.

And you stated in your supplemental expert record,

23

which you've incorporated into your written testimony, that,

24

quote, this is important because the proposed photo

25

identification requirements under Act R54 apply to those who

118

1

cast their absentee ballot in person, end quote. Is that

2

correct?

3

A.

Yes.

4

Q.

And do you know where a South Carolina voter goes to

5
6

cast an in-person absentee ballot?
A.

My understanding is that South Carolina voters need to

7

go to a local election office to cast an absentee ballot in

8

person.

9

Q.

10

And just to confirm, you believe it to be the county

election and registration offices, is that correct?

11

A.

That's my understanding.

12

Q.

And you have read Act R54, is that correct?

13

A.

Yes.

14

Q.

And you understand that one of the five forms of

15

identification provided for under Act R54 is a South Carolina

16

voter registration card that contains a photograph?

17

A.

Yes.

18

Q.

And do you know where a voter obtains that card if Act

19
20
21
22
23

R54 is precleared?
A.

My understanding is that an individual would need to go

to a local election office.
Q.

And that's the same election office that the voters go

to cast in-person absentee ballots, is that correct?

24

A.

That is my understanding.

25

Q.

So, you would agree with me, would you not, that your

119

1

analysis demonstrates that blacks are 1.5 times more likely

2

than white voters to cast in-person absentee ballots at the

3

same location where free photo voter registration cards will

4

be available, is that correct?

5
6
7

A.

Assuming my understanding is correct about standard

operating procedure in the state of South Carolina, yes.
Q.

And in addition to that -- in addition to showing that

8

blacks are more likely than whites to use in-person absentee

9

voting, your analysis also shows that blacks are more likely

10

than whites to register to vote in person at the county

11

election office, isn't that correct?

12

A.

13

report.

14

Q.

15
16

I'm not sure about that. I need to look back at my

Sure. We'll go ahead and I can put it up here for you.

Dr. Martin, do you recognize this document?
A.

17

Yes.
MR. FIELD: And just for the record, this is Dr.

18

Martin's expert report. Plaintiff's Exhibit 61. And this is

19

specifically on the page bearing Bates number JA001767.

20

BY MR. FIELD:

21

Q.

Dr. Martin, can you tell us what this Table 8 shows?

22

A.

Yes. What this table shows is the place of

23

registration for active, in the first two columns, and active

24

plus the F and M inactive voters in second two columns. I

25

show their place of registration for these active voters.

120

1

HON. COLLEEN KOLLAR-KOTELLY: Can I ask if they

2

could move the -- perhaps you can move the board a little bit.

3

We're having a little bit of trouble seeing the screen. If

4

you can move those back so we can actually see the screen.

5
6

HON. JOHN D. BATES: Unless they are going to be
utilized in upcoming testimony, you can take them down.

7
8

HON. COLLEEN KOLLAR-KOTELLY: Turn the TV and see a
little better.

9
10

HON. JOHN D. BATES: Move it -- move the screen a
little closer.

11

HON. COLLEEN KOLLAR-KOTELLY: Closer. That would

12

be helpful. Good. Thank you.

13

BY MR. FIELD:

14

Q.

Dr. Martin, my question was -- before we looked at this

15

chart. My question was whether or not your analysis shows

16

that blacks are more likely than whites to register to vote in

17

person at the county election office? Isn't that what this

18

table shows?

19
20
21

A.

Yes. That is what the first two rows of numbers show

in that table.
Q.

And, in fact, after mail-in registrations, in person

22

registration at the county election offices is the second most

23

used method of registration for blacks, isn't that correct?

24

A.

Correct.

25

Q.

So, in your analysis -- or strike that. So, your

121

1

analysis shows that blacks are more likely than whites to

2

register to vote at the county election office, and blacks are

3

more likely than whites to cast in-person absentee ballots at

4

county election offices, correct?

5

A.

Correct.

6

Q.

And this is the same county election office that, if

7

Act R54 is precleared, photo voter registration identification

8

cards will be provided, correct?

9

A.

That is my understanding, yes.

10

Q.

And just one other thing that I'd like to make sure

11

that we understand. On Page 2 of your written testimony, you

12

conclude that, quote: There are significant disparities in

13

socioeconomic status between the black and white voting age

14

populations in South Carolina, unquote. Is that correct?

15

A.

Correct.

16

Q.

But you were offering no testimony that any of these

17

significant disparities will exist in the future, correct?

18

A.

I am making no prediction about the future.

19

Q.

So, rather, you are simply offering an opinion about

20
21
22
23

the levels of socioeconomic status in the past, correct?
A.

I'm offering evidence of the significant differences in

socioeconomic status in 2004 -- I'm sorry, 2002 through 2010.
Q.

And you also state in your written testimony, quote:

24

There are significant differences in the political behavior

25

between black and white voters in South Carolina, end quote.

122

1

Is that correct?

2

A.

Correct.

3

Q.

And just as you are not drawing any conclusions about

4

future levels of socioeconomic status, you are likewise not

5

testifying about any future levels of political participation

6

in South Carolina, correct?

7

A.

I am not.

8

Q.

So, your opinions are solely about political

9
10

participation in the past, correct?
A.

Correct.

11

MR. FIELD: I have no other questions.

12

HON. COLLEEN KOLLAR-KOTELLY: All right. Any

13

cross-examination from the Government?

14
15

MR. HEARD: Nothing from the United States, Your
Honor.

16

HON. COLLEEN KOLLAR-KOTELLY: Any redirect?

17

MS. MARZIANI: We have nothing further.

18

HON. COLLEEN KOLLAR-KOTELLY: You can step down,

19
20

sir. Thank you.
MS. MARZIANI: Our next witness is Dr. Kevin Quinn.

21

Your Honor, while he's making his way up to the stand, Dr.

22

Quinn submitted the majority of his testimony in written form

23

last week, but pursuant to the Court's August 17th order

24

concerning the new materials the State has produced concerning

25

the reasonable impediment exception, I'm going to ask him a

123

1

couple of questions about those new materials, with your

2

permission.

3

HON. COLLEEN KOLLAR-KOTELLY: Yes. Go ahead.

4

MS. MARZIANI: Thank you.

5

Thereupon,

6

KEVIN QUINN,

7

the witness herein, having been duly sworn, was examined and

8

testified as follows:

9
10

EXAMINATION
BY MS. MARZIANI:

11

Q.

Good morning, Dr. Quinn?

12

A.

Good morning.

13

Q.

In the past two weeks have you received new information

14

about the State's planned implementation of reasonable

15

exception -- or the reasonable impediment exception?

16

A.

Yes, I have.

17

Q.

Please briefly describe what you've received and

18
19

reviewed?
A.

So, the things that I've seen and reviewed have been an

20

additional deposition transcript from Chris Whitmire, an

21

additional deposition transcript from Marci Andino. I've also

22

seen the script for the planned video training that the SEC

23

has produced, as well as the depositions of SEC officials the

24

last couple of days.

25

Q.

And have you also reviewed --

124

1
2
3
4
5
6
7

A.

I'm sorry, the trial testimony from the last couple of

days, I'm sorry.
Q.

Of course. Thank you. And have you also reviewed the

materials the state produced on the August 14th?
A.

I have, yes. I believe that shows up in the my direct

testimony.
Q.

And so sitting here today and in light of all this new

8

information, do you have an opinion as to whether there is

9

currently a clear consistent definition of reasonable

10
11
12

impediment?
A.

No. I don't think that there is a clear definition of

reasonable impediment right now.

13

Q.

And why do you have that opinion?

14

A.

I think what's become apparent is that key SEC

15

officials still have different views as to what this is. I

16

think that the attempts to clarify this have not gone very

17

far.

18

Q.

All right. And in your June 18th expert report, which

19

is of course incorporated into your written direct testimony,

20

you discuss a study that you coauthored concerning the

21

application of voter identification requirements in the city

22

of Boston. Can you briefly describe the results of that

23

study?

24

A.

25

Yes, I can. So, this was a study that was done in

the 2008 General Election, and without burdening the Court and

125

1

everyone else with the full details, the simple results are

2

that we found that African American voters were asked for ID

3

at higher rates than both -- than white voters, both on

4

average and after adjusting for a number of other covariants.

5

We also found that Hispanic voters were asked for

6

ID at rates higher than white voters, both on average on and

7

after adjusting for a number of covariants.

8
9
10
11

Q.

Great. And how these did results compare with the

results of other empirical studies looking at the application
of voter identification requirements?
A.

As I noted in my June 18th report, these results are

12

qualitatively similar to the other two studies that I know

13

about that deal with this question.

14

Q.

And what do the results of your Boston study suggest

15

about the state's planned training and guidance that it plans

16

to give to poll workers?

17

A.

So, one aspect of the Boston study that I didn't

18

mention right now was that we implemented a experimental poll

19

worker training program, one aspect of which was training on

20

the appropriate Massachusetts law regarding photo ID -- I'm

21

sorry, not photo ID, just general ID. And what we found was

22

that there was no statistically significant effect of this

23

poll worker training. That people -- poll workers in

24

precincts who received the training seemed to behave no

25

differently than poll workers who do not receive the training.

126

1
2
3

Q.

And so what does that suggest to you about the state's

plans for poll worker training?
A.

Well, so, again, this is a study in Boston, it's not a

4

study in South Carolina. But I think one thing that this does

5

suggest is that in Massachusetts where poll workers have very

6

little discretion as to what they should be doing, the law is

7

quite clear as to what they should be doing. A poll worker

8

training program that explicitly dealt with ID requirements

9

didn't have a statistically significant effect.

10

And so that leads me to believe that the poll

11

worker training that South Carolina has put forth may very

12

well not be successful at creating uniform implementation.

13

Q.

Great. And in your June 18th report you describe a

14

high likelihood that the reasonable impediment exception would

15

be applied in a non-uniformed manner across counties in South

16

Carolina. How does the new information that you received

17

affect this conclusion?

18
19
20

A.

The new information that I've seen in the last few

weeks has only reinforced that conclusion.
Q.

Specifically, how has this new information affected

21

your conclusions as to whether the state has a centralized

22

election administration mechanism, robust training, consistent

23

support from local officials, and robust voter education?

24
25

A.

It has reinforced my views on all of those things -- my

opinions on all of those things. I mean, in particular, I

127

1

think one thing that really struck me the last few days was

2

looking at Ms. Andino's testimony where she stated that she

3

would be encouraging local officials to disregard the law --

4

would be one way to put it.

5

And we similarly saw Ms. Bowers say that she

6

would clearly never disobey the law. This, again, creates

7

these mixed messages about what people should be doing. And I

8

think this, again, leads towards nonuniformity -- likely

9

nonuniformity.

10

Q.

And also in that report you explain that without

11

uniform application it is unlikely that the reasonable

12

impediment exception will rectify any racial disparities in

13

photo ID ownership. And you concluded that the state's

14

planned implementation of the exception poses a substantial

15

risk of racial discrimination.

16
17
18

So, how does the new information you've received
affect these conclusions?
A.

Again, it reinforces those conclusions. The first

19

point about lack of uniform implementation leading to failure

20

to mitigate any pre-existing racial differences and ID

21

possession is largely a logical conclusion. So, if there's

22

not uniform application, it's hard for me to see how you would

23

get of any kind of racial differences.

24
25

The substantial risk of discriminatory
implementation. My views on that are similarly reinforced. I

128

1

have seen nothing that would suggest that that's not going to

2

be -- that would change my views on that.

3
4

MS. MARZIANI: Thank you very much. Nothing
further at this time.

5

HON. COLLEEN KOLLAR-KOTELLY: Okay. Cross.

6

HON. JOHN D. BATES: I have one question before

7

cross. You said that key SEC officials have different views

8

as to the meaning or definition of reasonable impediment. You

9

cited one example from the testimony here in court relating to

10
11

disobeying laws, between Ms. Andino and Ms. Bowers.
Can you give us any other information on what key

12

SEC officials have different views and precisely on what

13

relating to reasonable implementation -- impediment, rather?

14

THE WITNESS: So, I'm not able to recall the exact

15

examples. I believe there were some hypotheticals that were

16

raised where Ms. Whitmire -- I'm sorry, Mr. Whitmire and --

17
18
19
20
21

HON. JOHN D. BATES: So, you're referring to
Mr. Whitmire's -THE WITNESS: Whitmire, Andino and Marilyn Bowers,
is who I was thinking of.
HON. COLLEEN KOLLAR-KOTELLY: So, are these based

22

on Ms. Andino in court, Mr. Whitmire by deposition, and Ms.

23

Bowers in court?

24
25

THE WITNESS: I believe all of their deposition
transcripts and what I saw of Ms. Andino in court yesterday.

129

1

HON. JOHN D. BATES: Those are the three officials?

2

THE WITNESS: The three SEC officials that I looked

3

at, that's correct. There's also been some testimony by

4

county officials that have, I think, raised some questions

5

about what he knew about the law as well.

6
7

HON. JOHN D. BATES: Again, in deposition, not in
court.

8
9
10
11

THE WITNESS: I was thinking about Mr. Joseph
Debney, D-E-B-N-E-Y.
BY MS. MARZIANI:
Q.

And just to clarify, from the Court's questioning,

12

approximately how many depositions transcripts have you

13

reviewed from state and local election officials?

14

A.

Let's see. So, there were four from Ms. Andino. There

15

were two from Mr. Whitmire. There was at least one from Janet

16

Reynolds. Marilyn Bowers. I think that's it for the SEC

17

officials. And did you include the county officials as well?

18

Q.

Yes.

19

A.

So, that would include Joseph Debney and Patricia

20
21

Calkins.
Q.

One more follow-up question. Have you also had the

22

chance to review some of the deposition transcripts and other

23

testimony from members of the General Assembly concerning

24

their understanding of the meaning of the reasonable

25

impediment exception?

130

1

A.

Yes, I have some.

2

Q.

How would you describe the consistency of these

3
4
5

definitions?
A.

I would say that the -- I would say that there's not a

great deal of consistency.

6

MS. MARZIANI: Thank you. Nothing further.

7

MR. BARTOLOMUCCI: Your Honor, I would like to

8

introduce Mr. Jeff Harris, counsel for South Carolina, who

9

will cross-examine Dr. Quinn.

10

HON. COLLEEN KOLLAR-KOTELLY: All right.

11

MR. HARRIS: Good morning. Good morning, Dr.

12

Quinn. May I hand him a deposition transcript?

13

HON. COLLEEN KOLLAR-KOTELLY: Yes.

14

MR. HARRIS: Thank you.

15
16
17

EXAMINATION
BY MR. HARRIS:
Q.

Dr. Quinn, if you could just put aside the new statute

18

Act R54 for a minute. Are you familiar with the pre-existing

19

South Carolina law regarding voting?

20

A.

I'm somewhat familiar, yes.

21

Q.

Are you aware that the pre-existing South Carolina law

22

requires voters to show certain forms of identification?

23

A.

Yes.

24

Q.

And is it fair to say that poll workers have discretion

25

in implementing that requirement?

131

1

A.

Yes, I believe they do have discretion.

2

Q.

As part of your work on this case, have you analyzed

3

the guidance that was given to poll workers about how to

4

implement that discretion in applying the -- sorry. As part

5

of work in this case, have you analyzed the official guidance

6

that was given to poll workers about how to apply that

7

identification requirement?

8

A.

Under the current law?

9

Q.

The pre-existing law, sir.

10

A.

I don't believe I spent very much time on that.

11

Q.

And have you looked at any of the training programs or

12

public education programs about how to comply with the prior

13

law?

14

A.

The current law?

15

Q.

Pre-existing.

16

A.

Pre-R54. I don't -- I haven't spent much time with

17
18

that. I don't believe I have.
Q.

And you haven't done any empirical analysis of whether

19

that pre-existing ID requirement was applied in a uniform

20

manner?

21

A.

In South Carolina? No, I have not.

22

Q.

Okay. And are you aware that the pre-existing South

23

Carolina law allows for provisional ballots under certain

24

circumstances?

25

A.

Yes.

132

1

Q.

And have you done any empirical analysis of whether, in

2

applying that provisional ballot rule, whether that's been

3

applied in a uniform manner?

4
5

A.

By empirical analysis, I assume you're referring to me

personally looking at data directly from --

6

Q.

Yes.

7

A.

-- South Carolina?

8

Q.

Yes.

9

A.

No, I have not.

10

Q.

Yes. Great. Dr. Quinn, are you familiar with the

11

process of double-blind peer review in the political science

12

field?

13

A.

Yes, I am.

14

Q.

Have you personally ever served as a reviewer in a

15

double-blind peer reviewed journal?

16

A.

Yes, I have.

17

Q.

And in that role as a peer reviewer, would you ever

18

recommend publication of a paper that what you think are

19

serious methodological problems?

20

A.

If you mean serious methodological problems --

21

foundational problems? No, I would not. I would not

22

recommend publication if it had severe foundational problems.

23

Q.

And you're aware that this study of Georgia's voter

24

identification law by Dr. Hood and Dr. Bullock that you

25

address in your rebuttal report, you're aware that -- sorry.

133

1

You're aware that the study of Georgia's voter identification

2

law that Dr. Hood and Dr. Bullock submitted to the -- I'm

3

sorry. Strike that.

4

Are you aware that the study by Hood and Bullock

5

that you address in your rebuttal report has been accepted in

6

a peer review journal?

7

A.

It's been represented to me that that's true.

8

Q.

Dr. Quinn, I'd like to refer you to the 2006 article by

9

David Kimball, et al., entitled Helping America Vote?

10

Election Administration, Partisanship, and Provisional Voting

11

in the 2004 Election?

12

A.

Yes. Uh-huh.

13

Q.

That's an article that you rely on in your report in

14

this case?

15

A.

Of my June 18th report, that's correct, yes.

16

Q.

And the Kimball article, that was a national study

17
18

about provisional ballots, is that right?
A.

Yes, it was. It looked at data from not quite every

19

municipality in the U.S., but a very large number that was

20

nearly exhaustive. There was a small number of municipalities

21

where they could not get the data.

22

Q.

And the core conclusion of that article was that

23

there's much variation across jurisdictions in terms of how

24

these ballots are cast and counted, is that a fair --

25

A.

That is one of the conclusions they reach, yes.

134

1
2
3

Q.

But Kimball didn't separately break out any data about

South Carolina, is that right?
A.

There was nothing -- there was no -- the short answer

4

to your question is, no, they do separate South Carolina out

5

by itself.

6

Q.

So, we're just not sure whether South Carolina was at

7

the high end or the low end in that wide variation of how

8

provisional ballots are cast and counted?

9

A.

That's correct.

10

Q.

And are you aware that in that 2006 article that

11

Kimball cited a paper by Dr. Trey Hood and Dr. Charles

12

Bullock?

13
14

A.

I'm not sure about that, but if you're representing

that to me as true, I will --

15

Q.

Would that surprise you?

16

A.

Your you're representing that to me, I'm happy to go

17
18

with it.
Q.

And, now, let's turn to your 2012 article that you had

19

been discussing a minute ago, Can Voter ID Laws Be

20

Administered in a Race-Neutral Manner?

21

A.

Uh-huh.

22

Q.

Just to confirm, in that piece you also cite an article

23

by Dr. Hood and Dr. Bullock?

24

A.

That's correct.

25

Q.

And as you mentioned a minute ago, the 2012 article

135

1

solely addresses the General Election in Boston in 2008, is

2

that right?

3
4
5

A.

That's -- all of our data came from the 2008 General

Election in Boston, that's correct.
Q.

And that was -- am I right to say that not everyone in

6

Massachusetts has to show photo ID under the law enforced when

7

you did your study?

8

A.

No.

9

Q.

So, for example, only voters who met certain criteria,

10

such as people who registered by mail, they had to photo ID,

11

but many voters didn't; is that right?

12

A.

They wouldn't necessarily have to show photo ID, but

13

they would have to show some form of ID, yes. The classes of

14

people who have show ID would be people who registered by mail

15

but did not show ID when they registered by mail under HAVA.

16

Then there were people who did not respond to --

17

oh, I apologize. The two groups of people who would have to

18

show ID would be people who registered by mail but did not

19

send ID in in their registration. They would have to show ID

20

at the polls. And registrants who do not respond to municipal

21

census would have to show ID at the polls.

22

Q.

Now, for each individual respondent in your survey, you

23

didn't know if that person was on the list to show ID or was

24

not on the list to show ID, is that right?

25

A.

That's correct.

136

1

Q.

And am I right to say you -- you say in your article

2

that you wanted to sort of keep the interview short, so you

3

didn't ask them the questions that you would have needed to

4

figure out if they were on the list, is that right?

5

A.

The reason that we did not ask them if they were on

6

that list was two-fold. One, we judged the recall task of a

7

voter, having to think back to when they registered and

8

whether they sent ID or not. It would be too difficult for

9

most voters and they wouldn't be able to respond accurately to

10

that question.

11

We could also have asked and tried to get some

12

kind of identifying information to link the voters into the --

13

I'm sorry. The other thing that we could have done would have

14

been to ask a question about some sort of identifying

15

information so that we could have linked the voter's exit poll

16

response back to the master voter list we received from the

17

city of Boston.

18

The reason we did not attempt to do that was

19

because the academic literature on exit polls is quite clear

20

that if you want accurate, reliable, honest answers to the

21

exit poll, it's very important to make the voter believe that

22

their response is going to be anonymous, there's no

23

identifying information tacked on to that.

24
25

Q.

Am I right to say that of the voters in Boston who were

supposed to have their voter IDs checked, you don't know the

137

1
2

racial composition of that group?
A.

We do not know the -- the voter list that we received

3

from Boston did not have racial information attached it to.

4

So, we don't know specifically which individuals, yes.

5

Q.

Okay. And is it right, you were talking a minute ago

6

about -- you mentioned a minute ago that you did some work

7

looking at how the poll workers reacted to training. Is it

8

true that in your study of that there was contamination of the

9

control group?

10

A.

There were some individuals who were randomized to

11

receive training who actually took training at a different

12

polling location. So, there was some -- call it

13

noncompliance.

14
15

Q.

Do you know -- do you have an estimate of how much that

would have affected the results?

16

A.

I don't know the exact numbers.

17

Q.

Taking a step back. In your empirical academic work,

18

have you ever relied on a Internet survey as your primary data

19

set?

20

A.

21
22

As my primary data set, I don't believe that I have,

no.
Q.

And is it fair to say that respondents to Internet

23

surveys are usually not representative of the population as a

24

whole?

25

A.

If we're talking purely about the respondents who --

138

1

the raw respondents, that would be correct. There are ways to

2

re-weight them to make them representative.

3

Q.

And is it fair to say that another problem is that --

4

in the specific context of election research -- that a person

5

might not take the survey until well after they've voted and

6

been at the polls?

7

A.

Yes, that's correct.

8

Q.

And so I'd like to refer you to the 2009 article by

9

Lonna Atkeson, et al., that you cite in your report?

10

A.

Uh-huh.

11

Q.

Atkeson relies in large part on Internet surveys, is

12
13
14
15

that right?
A.

My recollection is that it's a multimode survey, which

is part Internet survey, part mail survey.
Q.

And is it right that only 22 percent of the people that

16

she asked about their experience at the polls responded to her

17

survey?

18

A.

Yes, the response rate was about 22 percent.

19

Q.

And Atkeson relied only on 2006 data from the First

20
21
22
23

Congressional District of New Mexico, is that right?
A.

I believe that's right. If you're representing that to

me, I'm willing to take it. Yeah.
Q.

And do you recall that in that New Mexico election a

24

voter could vote without ID if she provided a name, date of

25

birth, and last four digits of her social security number?

139

1

A.

I believe that's correct. Yes.

2

Q.

And do you know -- do you know if the authors of the

3

Atkeson study made any attempt to calculate the percentage of

4

each racial group that voted that way?

5

A.

Sitting here right now I don't -- I don't recall.

6

Q.

And have you made any attempt to compare the election

7

procedures of the New Mexico Congressional District to South

8

Carolina?

9

A.

A direct comparison? Not a direct comparison, no. The

10

Atkeson study of New Mexico was one small piece of the broader

11

set of evidence that I used in my June 18th report.

12
13

Q.

And are you aware that in her 2009 article that we were

just talking about, Professor Atkeson -- are you aware that --

14

HON. COLLEEN KOLLAR-KOTELLY: You're very fast.

15

We're also near the end of the morning. If you both -- they

16

understand this is not a colloquy between the two of you. We

17

have to understand your questions as well.

18
19
20

MR. HARRIS: Of course.
BY MR. HARRIS:
Q.

Are you aware that in the 2009 article that we have

21

been talking about, Professor Atkeson favorably cites two

22

different articles by Dr. Trey Hood and Dr. Charles Bullock?

23
24
25

A.

I don't recall that, but if you're representing that to

me, I'll take it.
Q.

And, finally, I'd like to turn to the 2009 article 0by

140

1

Stephen Ansolabeher, is that --

2

A.

Ansolabeher.

3

Q.

Stephen Ansolabeher entitled Effects of Identification

4

Requirements of Voters on Election Day?

5

A.

Uh-huh.

6

Q.

That's an article that you rely on in your report?

7

A.

Yes. That's in my June 18th report.

8

Q.

And Ansolabeher's article was based on a national

9
10
11

survey and then a survey of Super Tuesday states, is that
correct?
A.

That's correct. There was a 2006 survey that was a

12

stratified national sample, and then there was a 2008 survey,

13

I believe, that was just Super Tuesday states.

14
15
16
17
18
19

Q.

And that study didn't -- that also didn't have any

specific findings about South Carolina?
A.

There were no specific -- South Carolina specific

findings, no. They were general -- more general findings.
Q.

And South Carolina is not a Super Tuesday state to the

best of your knowledge?

20

A.

It's not, no.

21

Q.

And were Ansolabeher's conclusions based on an Internet

22

survey?

23

A.

They were, yes.

24

Q.

But despite that, you nonetheless think that his

25

conclusions were generally sound?

141

1

A.

As I think I testified in my deposition, the actual

2

Internet survey that Professor Ansolabeher used is widely

3

regarded as one of the best Internet surveys there is. And,

4

in fact, great care has been given to exactly the sort of

5

issues that you alluded to earlier, which is how do you get

6

these Internet respondents and re-weight them in a way to make

7

them representative of things happening both nationally and

8

within congressional districts. So, the study is able to look

9

at state level variations as well as national level variation.

10

Q.

In that same 2009 study, are you aware that Ansolabeher

11

concluded that photo ID laws may prevent almost no one from

12

voting?

13

A.

14
15

He does look at that question and reaches that

conclusion, yes.
Q.

And are you aware that he found that less than 1/10 of

16

1 percent of respondents claimed that they were not allowed to

17

vote because they didn't have photo ID?

18
19

A.

I don't recall the exact number, but it's a number of

approximately that that size I believe.

20

Q.

Do you have any reason to question those conclusions?

21

A.

To question your representation of Professor

22

Ansolabeher's conclusions or--

23

Q.

-- his conclusions.

24

A.

Uh, no, no, I --

25

Q.

I'm happy to hand you --

142

1

A.

2

was --

3

Q.

4
5

No, no, no. I just want to be clear about what I

Yeah, I'm asking if you -HON. COLLEEN KOLLAR-KOTELLY: You're speaking at

the same time. Again --

6

MR. HARRIS: I'll start over. Again, this is not a

7

conversation between the two of you. We need a record. Slow

8

down and let him finish the answer before you start, please.

9

BY MR. HARRIS:

10

Q.

My question is just whether you agree with

11

Ansolabeher's conclusion that very few, if any, voters are

12

prevented from voting by photo ID laws?

13

A.

So, I think there is some reasons to question that

14

conclusion. That doesn't necessarily mean I think it's right

15

or wrong, but I think there's some reasons to question that

16

conclusion. And so one issue is that the -- many of the

17

stricter forms of photo ID were not on the books when these

18

studies were conducted, certainly in the 2006 study, and the

19

2008 studies to some extent as well.

20

So, I think part of what we're seeing are

21

stricter forms of photo ID law being implemented now. And

22

it's not obviously clear that the comparisons that were drawn

23

in 2006, with the laws in place in 2006, would translate to

24

the stricter laws now in terms of what would happen in terms

25

of turn out at least.

143

1

Another issue of that study is that -- or I'm

2

sorry, with that conclusion from the study that -- the turn

3

out conclusion -- is that I -- to the best of my knowledge

4

they don't differentiate casting a provisional ballot from

5

casting a regular in-person ballot. So, what may have

6

happened is that many of these people who were asked for ID,

7

they should have been able to vote a provisional ballot. But

8

I don't think there was a follow-up asking whether their

9

provisional ballot was actually counted or not.

10

So, if that's the case, there would be some

11

slippage there potentially as well. And then one other

12

possible issue is that if you think that the people who might

13

be most impacted by these laws would be people who would be

14

very unlikely to show up in an Internet survey, people who are

15

of very low socioeconomic status, the methods of weighting

16

that would be used to get the Internet survey to match up with

17

the national representative sample might be most discrepant

18

for these types of people because it's harder to get the

19

weighting right.

20
21

Q.

And are you aware that Ansolabeher also did a survey of

non-voters -- of people who didn't vote?

22

A.

I believe that's correct.

23

Q.

And are you aware that based on that survey only

24

7 out of 4,000 respondents claimed that they chose not to vote

25

because they lacked proper identification?

144

1
2
3

A.

I don't recall the exact number. But, again, if you're

representing that, I'm happy to take it.
Q.

Okay. Just a couple more questions. Are you aware

4

that Ansolabeher found that in the two states that actually

5

had photo ID requirements, nearly 80 percent of voters

6

reported being asked for ID?

7

A.

Yes, I believe that's right.

8

Q.

And in those two states that had photo ID requirements

9
10
11

at the time, Ansolabeher made no attempt to analyze the racial
make-up of those groups?
A.

So what Professor Ansolabeher did was to fit a

12

particular type of multivariate regression model in which

13

both, if my memory serves me correctly, both race, as well as

14

an indicater for the type of state level law were included in

15

the model, as well as number of other demographic variables.

16

So, while I don't believe Professor Ansolabeher

17

specifically broke out the data to states with voter ID laws

18

and did a completely separate analysis, he did something that

19

was functionally very similar to that by including these

20

variables in his multivariate regression.

21
22
23
24
25

Q.

But fundamentally, 48 of the 50 states did not have

photo ID laws at the time?
A.

In 2006, I think that's right -- in 2008 I believe more

states had photo ID laws, but I'm not -Q.

Okay.

145

1
2

MR. HARRIS: That's all I have. Thank you,
Dr. Quinn.

3

THE WITNESS: Thank you.

4

HON. COLLEEN KOLLAR-KOTELLY: All right. Any

5

redirect? Unless the Government wishes to ask anything.

6

MR. HEARD: Nothing for the United States.

7

MS. MARZIANI: And I just have two quick follow-up

8

questions about the Boston study.

9
10
11

EXAMINATION
BY MS. MARZIANI:
Q.

And, Dr. Quinn, you just discussed that the individual

12

voter files had no racial information in Boston. But what

13

other racial demographic information did you have, if any, and

14

how did you use that?

15

A.

Right. So, we did know the racial composition of each

16

of the polling locations. And so what we could do and did do,

17

actually, that shows up as one of the figures in the paper, we

18

could look at what we called ecological associations between

19

the aggregate fraction, African American fraction-wide,

20

fraction Hispanic, fraction Asian in each of these polling

21

locations, and the aggregate fraction of people who were --

22

who should have been asked for ID. These people who were the

23

HAVA voters who registered by mail but did not send an ID in

24

with their registration, or for the people that didn't respond

25

to the municipal census.

146

1

And if we look at that what we find is that there

2

is some association between race and what we're calling HAVE

3

or inactive voters, people who should be asked for ID

4

according to law. The associations are not strong, though.

5

And if we extrapolate out and look at the precincts that are

6

nearly 100 percent white, we find that about 5 percent of the

7

people, approximately, this is going from memory, should have

8

been asked for ID, based on the voter list that the city of

9

Boston provided to us.

10

If we do the same thing for African Americans and

11

we look a precincts that are 95 percent African American --

12

approaching 100 percent African American, we find -- I believe

13

it's the case that approximately 10 percent of those people

14

should have been asked for ID. There's about a 5 percentage

15

point gap.

16

One thing that we did -- a very important part of

17

the Boston study, and this shows up in the report as well the

18

paper itself, is we conducted a sensitivity analysis that --

19

I'm sorry. One of the important things of the Boston study

20

was that we explicitly recognized this fact that there may

21

very well be different legitimate rates at which people should

22

be asked for ID based on race.

23

To account for this, we conducted what would be

24

called a sensitivity analysis. And the way we did this would

25

be to ask ourselves: How big would these gaps have to be in

147

1

the legitimate ID request rates by race in order to make our

2

results become statistically insignificant? And what we found

3

was that the size of the gaps would have to be around 10

4

percentage points, the difference between the legitimate ID

5

request rates for blacks and legitimate ID request rates for

6

whites, and roughly the similar number for Hispanics compared

7

to whites.

8

And so what we see is that there would need to be

9

approximately a 10 percentage point gap. Based on the

10

ecological information, it seems like there is likely a

11

5 percentage point gap, something like that. So, to us that

12

seemed to be good evidence that there were racial differences

13

in the non-legitimate ID request rates.

14

Q.

Okay. A final question. Do you have a view as to

15

whether or not poll workers in Boston have more or less

16

discretion in applying identification requirements than poll

17

workers in South Carolina would have under R54?

18

A.

My opinion on that is that poll workers in Boston have

19

much less discretion that poll workers in South Carolina would

20

have under RR54.

21

MS. MARZIANI: Great. Thank you.

22

HON. COLLEEN KOLLAR-KOTELLY: All right. Anything

23

else? Then you're excused, sir. You can step down.

24

THE WITNESS: Thank you.

25

HON. COLLEEN KOLLAR-KOTELLY: Before we break for

148

1

lunch, I believe Judge Bates had a few questions he wished to

2

ask.

3

HON. JOHN D. BATES: It's all going to be one

4

question -- one item, but it may have a couple of questions in

5

it, and it's really directed to South Carolina. It relates to

6

the record that we will have in this case. And I'm pleased

7

that the Attorney General and Deputy Attorney General are here

8

and have been here for much of the trial.

9

Given what has transpired, I just want to make

10

sure, given what has transpired in the case to date, including

11

the testimony that we've heard, and especially the testimony

12

relating to implementation. And there's a certain illogic in

13

this question, but just assuming that the Court were to

14

preclear R54 and were to do so not earlier than October 1st.

15

I think our briefing schedule would make it difficult to do it

16

before October 1st. I want to make sure that South Carolina

17

does in fact intend to put R54 into effect for the

18

November 2012 General Election.

19

You don't have to answer this question now. I

20

would just like an answer or a sense of South Carolina's

21

position before we break tomorrow. I'm not asking for an

22

answer at this moment.

23

And then the next subset to that is whether -- if

24

it will be put into effect for 2012, it will be implemented as

25

interpreted and described by Ms. Andino in her testimony. And

149

1

I ask that because obviously there's been some evolution in

2

the course of this case, and indeed in the course of the

3

testimony at trial, and indeed by Ms. Andino in the course of

4

her testimony in reaction to hypotheticals and other

5

information presented to her.

6

There's been some changes in responses with respect

7

to the interpretation of the law and the process to implement

8

the law. So, what I'm really searching for is a

9

representation from the State as to whether it's adopting and

10

accepting all of Ms. Andino's interpretations and

11

clarifications of the law and the process to implement the

12

law. So that when we close the record on Friday we'll know

13

that that is in fact true and that we then -- and I'm asking

14

this for myself, I haven't coordinated this with the other

15

judges, they may have a different feeling on it -- but so that

16

at least I can then expect that there will not be new facts

17

and new interpretations of R54 and its implementation that

18

will be offered during the course of the briefing or during --

19

or through Attorney General opinions or any other method.

20

What I'm looking for is to know what South

21

Carolina's position is, and I'd like it by the end of the day

22

tomorrow if we can have it, as to whether they're going to

23

accept and adopt Ms. Andino's interpretations and

24

clarifications or not.

25

HON. BRETT M. KAVANAUGH: I would follow-up on that

150

1

by saying, in specific, I understand the testimony to be that

2

the law -- the reasonable impediment provision of the law

3

would apply to everyone for the 2012 election because of

4

the -- who claims that the timeframe made it an impediment and

5

that for future elections -- I think her testimony, and

6

obviously you'll respond if you disagree -- covers people

7

without cars, people with disabilities or medical conditions,

8

people with no birth certificates, people with any impediment

9

that the voter deems reasonable, unless the reason stated is

10
11

false.
So, I understood her testimony to grant a very

12

expansive set of exceptions that potentially could cover the

13

waterfront of issues that have been raised about the law.

14

That raises a lot of question for us as judges about

15

interpreting the laws and how we should interpret this law so

16

as to avoid a conflict. There's constitutional avoidance you

17

have sometimes, and when you're interpreting a state statute,

18

as the Supreme Court did in the Arizona case and many others,

19

as Justice Kennedy did, interpret the state statute in a way

20

to avoid a conflict with federal law.

21

And the number of exceptions or qualifications that

22

have been made on the reasonable impediment standard may make

23

this law fundamentally different from what it was originally

24

portrayed to us when we started many months ago, and from how

25

it's been litigated. So, I'm interested more broadly -- I

151

1

guess I would throw this out to the three parties. How should

2

we think about this legal test if all of the things that I

3

just listed are really going to qualify as reasonable

4

impediments for this law?

5

And, particularly, if it were precleared on the

6

basis of the representations that have been made, therefore,

7

on the basis that those exceptions would continue to apply in

8

the future. So, those are things -- since Judge Bates opened

9

the door, I thought I would walk through it as well and give

10

you some of my current thoughts about thinking about this

11

case, which may affect -- speaking only for me -- my analysis

12

at the end.

13

HON. JOHN D. BATES: Let me add one thing more to

14

it, and that is, part of the issue that we really haven't

15

heard much about during this course of this trial is who has

16

the authority to interpret and apply the law? We've got Ms.

17

Andino as Executive Director. We've got the State Election

18

Commission. We haven't heard really their view. Indeed, we

19

specifically did not hear it from Ms. Bowers. And we've got

20

the county election commissioners. And then we've got the

21

State of South Carolina sort of over everything. And it's

22

hard to determine what exactly the position is with respect to

23

interpretation and implementation of R54.

24
25

HON. COLLEEN KOLLAR-KOTELLY: I would follow-up
with just a few more details in that. In Ms. Andino's

152

1

testimony, if her interpretation -- if you indicate that that

2

would be what was adopted, it would be helpful if you would be

3

very specific and not just with a broad sweep. She talked in

4

certain instances of not following statutes if she viewed them

5

as an impediment to erring on the side of letting a voter

6

actually vote.

7

So, I would certainly want to know precisely, you

8

know, breaking it down in terms of what she said about

9

different parts of it. And the focus predominantly was on the

10

reasonable impediment, the notaries, et cetera, that whole

11

particular process. If we could get something that would be

12

fairly specific.

13

And I guess the other question is if you adopted

14

these positions, are you willing to carry it through by making

15

sure that the material that goes out as training to the

16

voters, to everybody else, actually says that. Because

17

certainly looking at it, without getting into specifics, the

18

materials we have been given certainly don't reflect -- and I

19

realize it's a work-in-progress -- do not reflect some of the

20

statements that Ms. Andino indicated would be her view of how

21

she would want to have it implemented.

22
23
24
25

So, I would just add that on to the discussion of
the other two individuals.
HON. BRETT M. KAVANAUGH: I would add one more
thing on the notaries to the list of things I said that

153

1

Ms. Andino said that are important, at least speaking for

2

myself. The fact that they would not be charging, that they

3

would be available, and that the kinds of ID that would be

4

required for a notary -- I'm not even going to attempt to

5

characterize it, but I would be interested in what South

6

Carolina's view of that is.

7

And, again, all three parties' views of how a very

8

broad, potentially, reasonable impediment exception should

9

affect our overall legal analysis here of the question of

10

discriminatory effect, which in turn may depend on the

11

question I asked two days ago about what tests we're applying

12

here for discriminatory effect.

13

HON. JOHN D. BATES: Again, I know this is a lot

14

that we have thrown at you since I opened the door, but it's

15

important to have a sense of this earlier rather than later.

16

Personally, I don't want to find out that I'm dealing with a

17

new case three weeks from now. The record is supposed to

18

close tomorrow. And to the extent that you can give us as

19

much advice, all of you, as possible, on your positions, that

20

would be very helpful.

21

HON. COLLEEN KOLLAR-KOTELLY: All right. With that

22

we'll break for lunch and we'll come back at 1:40 p.m.

23

LUNCHEON RECESS AT 12:40 P.M.

24
25

154

1
2
3

C E R T I F I C A T E
I, Lisa M. Foradori, RPR, certify that the foregoing

4

is a correct transcript from the record of the proceedings in

5

the above-titled matter.

6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

Date: 8-30-12

/s/ Lisa M. Foradori, RPR

155

185A [2] 76/4 76/4
$
1863 [1] 2/14
$1,800 [1] 89/1
18th [6] 124/18 125/11 126/13 133/15
$1.50 [1] 79/15
139/11 140/7
$10 [6] 56/7 56/7 59/19 74/13 74/14
19 [1] 100/16
19 percent [2] 21/12 22/3
74/15
$100 [1] 56/19
1915 [2] 92/20 92/25
$150 [1] 56/13
1919 [1] 1/17
$198 [1] 86/2
1923 [1] 92/7
$2 [1] 86/2
1924 [1] 92/10
$20 [1] 111/11
1949 [1] 99/19
$200 [6] 82/19 83/4 83/5 86/1 86/3 86/3 1952 [1] 61/11
$25 [1] 56/12
1:40 p.m [1] 153/22
$30 [1] 86/16
1st [2] 148/14 148/16
$47.70 [1] 86/8
2
$5 [2] 83/4 83/4
$71.70 [2] 86/12 86/14
20 [4] 88/3 113/16 113/18 113/19
$8 [1] 56/10
200 [1] 21/16
2000 [1] 18/8
'
20001 [1] 3/18
'23 [2] 92/8 92/9
20002 [1] 3/6
'In [1] 22/1
20005 [1] 3/14
20008 [1] 3/3
/
2001 [2] 81/11 82/6
/s [1] 154/7
2002 [1] 121/22
20036 [1] 1/18
0
2004 [17] 11/5 16/15 16/21 16/24 16/25
0257 [1] 1/18
17/9 18/2 18/8 18/14 18/15 18/16 19/12
0800 [1] 3/4
19/13 19/14 100/16 121/22 133/11
0by [1] 139/25
2006 [8] 133/8 134/10 138/19 140/11
142/18 142/23 142/23 144/23
1
2008 [24] 11/5 16/16 16/16 16/21 16/24
1-800 [1] 87/6
16/25 17/9 18/2 18/14 18/15 18/16
1.4 [1] 47/3
19/12 19/13 19/14 42/12 53/10 75/7
1.5 [2] 117/19 119/1
109/18 124/25 135/1 135/3 140/12
1.67 [1] 47/10
142/19 144/23
1/10 [1] 141/15
2009 [6] 53/16 138/8 139/12 139/20
10 [9] 4/5 34/14 93/9 93/13 102/11
139/25 141/10
2010 [2] 67/16 121/22
110/17 141/15 147/3 147/9
10 percent [1] 146/13
2011 [3] 82/7 82/15 82/15
100 [1] 146/12
2012 [7] 1/4 71/3 134/18 134/25 148/18
100 percent [1] 146/6
148/24 150/3
10004 [1] 2/14
202 [6] 1/18 2/7 3/4 3/7 3/15 3/19
10013 [1] 3/10
203 [2] 1/3 5/4
11 [2] 99/7 100/12
20530 [1] 2/7
113 [1] 4/16
21 [1] 20/16
116 [1] 4/17
210 [1] 2/21
118 [2] 4/19 4/19
212 [1] 2/14
119 [1] 13/12
214 [1] 105/3
11:00 [1] 75/21
215 [1] 3/6
12 [1] 154/7
22 [3] 79/25 104/16 138/18
12-203 [1] 1/3
22 percent [1] 138/15
12-CV-203 [1] 5/4
2200 [1] 3/7
124 [1] 4/22
23 [1] 19/8
125 [1] 2/13
230 [1] 2/17
12:40 [1] 153/23
239 [3] 17/16 19/3 19/9
12th [1] 3/10
248 [1] 11/25
13 [2] 12/1 17/20
25 [2] 19/3 105/16
13 percent [5] 17/10 17/13 18/1 18/15
255 [2] 21/22 21/24
258 [2] 20/12 20/15
19/13
13-14 [1] 104/21
259 [1] 20/16
131 [1] 4/22
2721 [1] 2/18
14 [2] 5/11 104/21
28 [3] 62/16 93/7 93/13
1401 [1] 3/13
285 [2] 34/9 34/11
1428 [1] 2/22
28th [1] 65/14
1440 [1] 2/17
292-8327 [1] 3/11
146 [1] 4/23
29401 [1] 2/22
14th [1] 124/4
29412 [1] 1/20
15 [4] 79/25 93/11 93/13 99/10
3
161 [1] 3/9
30 [8] 1/4 5/8 77/15 81/14 90/1 90/1
177 [1] 1/7
179A [1] 12/15
92/4 92/23
30 miles [3] 101/5 105/16 110/24
17th [1] 122/23
30 percent [2] 21/10 22/2
18 [2] 60/7 109/10

30303 [1] 2/18
32 [1] 78/2
3269 [1] 3/19
333 [1] 3/18
35 [1] 4/6
353-8743 [1] 2/7
354-3269 [1] 3/19
36 [1] 62/15
3:00 a.m [1] 87/11
3rd [1] 99/19

4
4,000 [1] 143/24
40 [4] 2/21 83/5 83/5 115/5
40 miles [2] 84/18 101/5
400 [1] 3/14
404 [1] 2/18
416-0257 [1] 1/18
42-45 [1] 102/14
4301 [1] 3/2
434 [1] 3/3
45 [3] 5/9 102/14 112/5
457-0800 [1] 3/4
46 [1] 97/1
470 [1] 1/17
48 [3] 44/16 44/16 144/21

5
5 percent [6] 18/9 18/14 19/11 25/25
26/5 146/6
5 percentage [1] 147/11
5-6 [1] 110/19
50 [4] 23/5 23/8 115/5 144/21
501 [1] 79/5
523 [1] 2/18
53 [1] 4/10
558-1863 [1] 2/14

6
60 [5] 70/21 70/24 71/5 81/18 81/21
609 [1] 1/21
61 [2] 4/10 119/18
63 [1] 107/17
646 [1] 3/11
65 [8] 47/9 47/13 58/15 78/10 83/13
83/16 84/10 86/7
662-8389 [1] 3/15
6706 [1] 3/17

7
70 [3] 81/19 81/21 112/4
7080 [1] 1/21
720-1428 [1] 2/22
736-2200 [1] 3/7
75 [1] 4/11
76 [1] 98/20
77 [1] 4/13
7th [1] 85/18

8
8-30-12 [1] 154/7
80 [2] 81/19 81/21
80 percent [1] 144/5
800 [1] 87/6
8327 [1] 3/11
8389 [1] 3/15
843 [2] 1/21 2/22
8743 [1] 2/7

9
90 [2] 4/13 81/19
911 [1] 79/22
934 [1] 1/20
95 percent [1] 146/11

9
950 [1] 2/6
99 [1] 4/16
99.9 percent [2] 79/13 85/16
9:00 [1] 1/5
9th [1] 82/15

A
a 2006 [1] 140/11
A.B [1] 2/11
a.m [2] 1/5 87/11
AARP [1] 57/17
abandoned [1] 80/5
ability [2] 58/13 72/17
able [34] 13/3 13/15 55/2 56/22 57/3
57/8 57/19 65/7 80/6 84/11 88/15 88/19
88/24 88/24 89/6 93/20 93/23 94/10
95/8 96/9 96/14 107/20 108/25 109/3
114/11 114/20 115/8 115/14 115/16
116/7 128/14 136/9 141/8 143/7
about [139] 7/10 8/2 8/14 9/3 10/23
11/14 12/5 12/15 16/10 22/2 22/17 24/5
24/25 25/20 26/7 26/9 27/18 29/22
30/19 30/23 31/1 31/19 32/2 32/18
32/21 33/12 34/4 35/13 36/10 36/21
39/6 40/13 41/5 41/5 43/8 46/6 46/13
49/22 50/10 50/11 55/9 55/12 56/2 59/5
61/23 64/24 66/13 66/23 69/2 69/3
69/24 70/9 70/16 73/20 73/21 75/3 75/5
79/3 79/13 79/18 81/7 82/12 83/1 83/8
83/11 91/14 95/19 97/3 99/10 101/5
101/20 101/23 102/8 102/14 103/7
103/8 104/3 104/8 104/18 104/20
106/10 106/20 106/21 106/23 107/7
108/5 109/1 109/19 110/2 110/10
110/18 110/19 111/3 112/4 113/16
115/5 119/5 119/12 121/18 121/19
122/3 122/5 122/8 123/1 123/14 125/13
125/15 126/1 127/7 127/19 129/5 129/5
129/8 131/3 131/6 131/12 133/17 134/1
134/13 136/14 137/6 137/25 138/16
138/18 139/13 139/21 140/15 142/1
145/8 146/6 146/14 150/13 150/14
151/2 151/10 151/10 151/15 152/8
153/11
above [1] 154/5
above-titled [1] 154/5
absentee [19] 8/6 8/9 21/10 21/15 21/20
22/1 58/10 58/14 58/20 81/5 89/4
117/20 118/1 118/5 118/7 118/23 119/2
119/8 121/3
absentee.' [1] 22/4
absolute [2] 26/6 27/8
absolutely [1] 89/22
ABUDU [6] 2/15 4/10 4/11 4/13 52/11
52/15
abuse [2] 56/9 56/12
academic [3] 43/13 136/19 137/17
accept [1] 149/23
acceptability [1] 48/18
acceptable [7] 14/13 44/21 53/20 53/23
91/6 105/7 105/11
accepted [4] 9/12 9/18 46/10 133/5
accepting [1] 149/10
accepts [1] 6/20
access [11] 24/22 25/7 26/14 37/9 42/15
43/3 46/3 69/18 102/20 102/23 103/4
accomplish [1] 105/15
according [5] 91/6 91/13 93/22 94/9
146/4
account [5] 82/23 83/3 85/10 86/1
146/23
accurate [3] 9/22 21/17 136/20

accurately [1] 136/9
achieving [1] 79/18
ACLU [4] 52/12 52/15 87/5 87/6
acquire [2] 104/9 104/15
across [2] 126/15 133/23
Act [14] 12/22 12/24 37/20 39/23 44/25
46/10 47/25 91/3 117/25 118/12 118/15
118/18 121/7 130/18
active [11] 46/16 46/21 78/15 78/17
78/22 78/23 80/8 80/12 119/23 119/23
119/25
actively [1] 81/1
actual [3] 35/25 76/5 141/1
actually [20] 12/6 16/8 16/16 16/21 20/8
20/18 21/20 39/14 46/15 57/6 95/16
102/11 108/14 120/4 137/11 143/9
144/4 145/17 152/6 152/16
acutely [2] 81/13 82/2
add [6] 32/20 46/5 95/19 151/13 152/22
152/24
added [1] 23/6
addition [4] 31/22 86/20 119/7 119/7
additional [3] 5/8 123/20 123/21
address [7] 61/17 85/8 98/18 98/22
98/24 132/25 133/5
addressed [1] 7/21
addresses [2] 61/20 135/1
adequately [1] 44/22
adjusting [2] 125/4 125/7
Administered [1] 134/20
administration [4] 69/12 106/6 126/22
133/10
admit [1] 76/12
adopt [1] 149/23
adopted [3] 83/19 152/2 152/13
adopting [1] 149/9
advent [1] 89/24
adversely [2] 20/1 20/2
advice [1] 153/19
affect [8] 11/17 12/7 24/23 25/3 126/17
127/17 151/11 153/9
affected [3] 82/10 126/20 137/15
affidavit [9] 49/13 49/23 59/1 59/11
59/16 59/22 74/9 87/13 87/14
affidavits [2] 87/11 87/13
afford [2] 88/24 106/17
African [28] 16/15 16/20 16/24 16/25
17/9 20/1 20/4 20/9 20/19 21/10 21/19
22/1 23/13 23/20 25/5 26/15 27/13
27/18 31/9 31/13 77/11 78/9 97/8 125/2
145/19 146/10 146/11 146/12
Afro [1] 53/6
Afro-American [1] 53/6
after [22] 11/21 21/24 25/9 30/8 39/19
52/8 54/16 55/10 56/1 61/14 71/17
75/23 83/2 86/4 99/24 100/3 108/6
109/12 120/21 125/4 125/7 138/5
again [40] 10/18 14/5 14/15 17/4 18/18
19/8 19/16 22/21 23/11 23/15 25/22
28/7 30/21 33/3 35/22 38/11 38/14
38/24 39/22 40/17 41/2 41/24 42/17
43/11 52/15 63/15 73/11 103/9 117/9
117/18 126/3 127/6 127/8 127/18 129/6
142/5 142/6 144/1 153/7 153/13
against [1] 45/20
age [6] 47/9 62/20 62/23 78/10 93/1
121/13
agencies [2] 13/12 107/6
agency [2] 55/21 107/4
agent [2] 54/16 55/1
ages [1] 79/25
aggregate [2] 145/19 145/21
ago [12] 65/17 81/19 90/15 103/22
110/17 110/19 134/19 134/25 137/5

156
137/6 150/24 153/11
agree [10] 11/12 11/16 20/21 20/22
23/23 26/17 33/16 96/8 118/25 142/10
agreed [3] 23/19 24/18 31/6
ahead [10] 24/14 32/17 36/25 48/5
76/21 88/12 98/6 113/7 119/14 123/3
Aid [1] 56/18
aided [1] 3/24
aircraft [1] 100/10
airport [1] 57/9
al [5] 1/6 5/4 5/4 133/9 138/9
ALAN [2] 1/22 2/1
ALICIA [1] 2/12
all [87] 5/22 6/10 8/13 9/6 9/23 10/10
10/13 11/13 13/11 13/13 13/19 15/4
15/7 18/4 22/24 22/25 23/1 23/4 23/9
23/23 24/23 25/2 26/1 29/18 30/14 33/7
33/16 33/24 35/8 41/2 44/14 51/2 51/2
51/3 52/3 52/9 54/8 60/3 60/10 63/20
66/13 73/9 74/22 75/5 75/13 76/11
76/20 81/7 82/8 85/12 85/24 86/7 87/18
89/4 89/15 90/10 94/5 94/17 95/5 95/20
96/19 99/13 100/2 104/22 106/11 107/2
111/18 112/17 116/10 117/8 122/12
124/7 124/18 126/24 126/25 128/24
130/10 135/3 145/1 145/4 147/22 148/3
149/10 151/2 153/7 153/19 153/21
allow [2] 72/19 72/23
allowed [5] 49/13 51/3 57/15 72/25
141/16
allows [3] 58/25 81/3 131/23
alluded [1] 141/5
almost [3] 112/4 112/5 141/11
along [2] 26/4 29/18
already [5] 36/21 41/16 42/10 73/25
107/25
also [40] 1/22 6/21 8/14 11/3 21/17
36/10 59/9 59/10 59/16 60/9 72/10 78/6
78/13 78/23 79/1 79/23 80/3 80/10
83/21 87/19 95/6 95/13 96/2 104/12
113/9 116/16 119/9 121/23 123/21
123/25 124/3 125/5 127/10 129/3
129/21 134/22 136/11 139/15 140/14
143/20
altogether [1] 40/24
always [3] 80/1 92/18 111/17
am [22] 1/6 39/2 50/17 53/14 53/19
77/11 77/25 78/5 78/21 78/22 78/24
78/25 90/2 97/6 110/4 113/8 121/18
122/7 132/13 135/5 136/1 136/24
Amanda [3] 83/18 83/21 83/22
AMDUR [1] 2/12
amend [2] 32/19 55/10
amended [1] 55/24
amendment [1] 55/12
amendments [2] 50/12 50/13
AMERICA [2] 1/6 133/9
American [18] 2/16 2/20 3/1 16/15 16/20
20/1 20/4 21/19 53/6 77/11 78/9 78/22
85/7 97/9 125/2 145/19 146/11 146/12
Americans [16] 16/24 17/1 17/9 20/10
20/19 21/10 22/2 23/13 23/20 25/6
26/15 27/13 27/18 31/9 31/13 146/10
Americas [1] 3/9
among [5] 16/20 16/23 16/25 17/9 26/14
analyses [2] 9/19 25/12
analysis [42] 8/6 8/7 8/8 8/9 8/18 8/21
9/18 9/25 13/3 15/8 20/7 22/7 22/9
25/15 26/18 38/6 38/6 38/17 38/22
39/23 39/24 40/3 40/14 40/23 44/20
48/21 50/20 50/22 50/23 119/1 119/9
120/15 120/25 121/1 131/18 132/1
132/4 144/18 146/18 146/24 151/11
153/9

A
analyze [1] 144/9
analyzed [3] 26/19 131/2 131/5
and 2008 [11] 16/16 16/24 16/25 17/9
18/2 18/14 18/15 18/16 19/12 19/13
19/14
and the [1] 11/5
Andino [13] 30/12 49/19 123/21 128/10
128/19 128/22 128/25 129/14 148/25
149/3 151/17 152/20 153/1
Andino's [7] 30/2 37/2 48/23 127/2
149/10 149/23 151/25
ANDREW [4] 4/18 116/20 116/23 117/2
ANGELA [1] 2/4
Angeles [1] 53/12
ANNA [1] 2/2
anonymous [1] 136/22
another [12] 21/1 28/25 58/6 62/15
63/19 84/2 112/4 112/5 112/7 112/11
138/3 143/1
Ansolabeher [10] 140/1 140/2 140/3
141/2 141/10 143/20 144/4 144/9
144/11 144/16
Ansolabeher's [4] 140/8 140/21 141/22
142/11
answer [36] 12/9 12/11 13/4 18/3 18/6
18/10 18/18 18/22 18/24 19/16 19/20
20/20 20/24 22/5 22/8 22/11 32/19 33/1
34/19 34/21 42/3 48/5 66/7 70/15 71/9
71/13 73/4 74/1 93/22 94/9 105/21
134/3 142/8 148/19 148/20 148/22
answered [3] 51/2 66/5 114/12
answering [1] 114/21
answers [7] 17/20 17/24 19/10 19/22
34/15 34/23 136/20
any [102] 5/14 7/17 7/21 7/24 10/24
12/25 13/1 13/12 13/16 24/6 25/12
27/17 27/19 28/18 29/9 30/2 30/9 30/15
31/19 31/24 33/19 33/24 34/4 34/17
35/16 35/18 36/11 37/16 37/17 37/24
39/24 43/8 43/20 45/14 45/17 45/22
46/6 47/22 47/25 48/9 48/17 49/3 50/8
53/23 54/6 54/6 56/17 57/11 58/19
62/11 71/9 76/8 78/19 79/9 79/12 80/24
82/12 83/11 85/6 85/9 86/20 87/15
87/22 89/6 89/9 94/12 97/14 99/24
100/2 100/21 100/21 100/24 102/20
103/2 103/12 103/12 109/13 110/2
110/20 113/22 121/16 122/3 122/5
122/12 122/16 127/12 127/20 127/23
128/11 131/11 131/18 132/1 134/1
139/3 139/6 140/14 141/20 142/11
145/4 145/13 149/19 150/8
anybody [2] 92/7 95/7
anymore [1] 102/3
anyone [12] 10/6 23/1 31/21 37/15
38/15 39/22 62/5 62/7 101/7 101/13
114/20 115/13
anyone's [1] 31/2
anything [14] 9/3 9/3 18/16 19/13 25/9
35/20 42/6 45/12 49/20 51/18 56/12
74/20 145/5 147/22
anywhere [2] 63/25 77/19
apart [1] 83/12
apologize [4] 86/18 90/6 94/7 135/17
apparent [1] 124/14
apparently [1] 39/17
appearance [1] 8/3
APPEARANCES [1] 1/13
appearing [1] 116/20
appears [2] 39/11 54/20
application [8] 54/15 54/19 55/1 95/18
124/21 125/9 127/11 127/22

applied [5] 95/15 108/9 126/15 131/19
132/3
applies [1] 45/4
apply [10] 45/5 45/8 58/19 104/13
112/10 117/25 131/6 150/3 151/7
151/16
applying [5] 10/24 131/4 132/2 147/16
153/11
appointment [1] 65/5
appointments [1] 65/6
appreciably [1] 11/6
approach [9] 40/22 40/23 41/2 45/7
82/12 86/24 86/25 90/19 117/10
approached [2] 83/1 83/11
approaching [1] 146/12
appropriate [7] 6/8 40/2 40/14 40/17
40/22 41/1 125/20
approximately [6] 39/21 129/12 141/19
146/7 146/13 147/9
are [148] 5/15 5/17 10/21 11/23 12/20
12/21 17/12 17/24 23/12 23/14 23/24
25/6 25/20 26/17 27/5 27/14 31/1 31/6
31/7 31/22 31/24 32/8 32/19 33/10
33/22 34/3 36/4 36/15 37/16 37/24
40/18 42/1 44/25 45/4 45/5 47/10 47/22
47/25 48/9 51/6 51/7 52/6 52/7 53/13
53/17 58/10 58/22 58/25 60/13 61/15
71/5 71/21 72/4 78/3 78/9 78/10 78/10
78/13 78/14 78/15 78/19 79/16 80/2
80/5 80/7 80/8 80/10 80/15 81/3 81/25
83/12 83/17 84/10 85/15 88/10 89/6
89/6 89/7 89/8 89/9 89/10 89/17 89/21
90/5 91/5 97/1 97/8 101/4 102/1 103/7
105/7 106/10 106/18 108/4 109/3
111/17 113/8 114/20 114/24 117/19
119/1 119/8 119/9 120/5 120/16 121/1
121/2 121/12 121/19 121/24 122/3
122/4 122/8 125/1 125/11 127/25
128/21 129/1 130/18 130/21 131/22
132/10 132/18 133/4 133/24 134/8
134/10 137/23 138/1 139/12 139/13
139/20 141/10 141/15 142/11 142/20
143/14 143/20 143/23 144/3 146/4
146/5 146/11 148/7 151/3 151/8 152/14
153/1
area [2] 66/6 66/14
areas [5] 37/10 79/23 80/4 80/5 97/8
aren't [1] 81/23
argue [1] 28/20
arguments [1] 60/10
Arizona [1] 150/18
Arkansas [1] 62/14
around [18] 36/16 52/5 57/25 66/13
66/14 66/14 102/4 102/11 104/10
104/14 106/16 108/8 108/13 108/14
109/13 109/24 110/13 147/3
ARTHUR [1] 3/1
article [17] 41/18 42/9 133/8 133/13
133/16 133/22 134/10 134/18 134/22
134/25 136/1 138/8 139/12 139/20
139/25 140/6 140/8
articles [1] 139/22
Arts [1] 100/4
as [143] 5/12 5/20 6/5 7/4 8/3 8/15 8/16
9/8 9/9 9/15 9/17 10/6 10/19 13/9 13/14
13/19 14/8 14/9 14/14 14/19 15/8 15/11
15/20 15/23 16/12 16/20 16/24 21/11
21/11 22/3 23/19 23/21 24/6 25/12
25/17 25/17 26/11 26/12 26/20 27/10
28/11 28/11 31/17 33/18 33/23 34/17
38/10 38/23 39/19 39/21 40/21 41/7
42/6 43/20 46/10 46/10 48/10 51/17
52/23 59/15 60/13 65/1 77/5 79/15
79/15 82/14 82/21 82/21 82/22 83/13

157
84/6 84/6 85/25 87/1 87/1 89/22 91/13
92/5 92/14 92/14 93/4 98/11 99/25
99/25 102/3 102/10 102/10 105/25
109/3 109/3 115/4 117/4 122/3 123/8
123/23 123/23 124/8 124/15 125/11
126/6 126/7 126/21 128/8 129/5 129/17
131/2 131/4 132/14 132/17 134/14
134/25 135/10 137/18 137/20 137/23
139/17 141/1 141/3 141/9 141/9 142/19
143/11 144/13 144/13 144/15 144/15
145/17 146/17 147/14 148/24 149/9
149/22 150/14 150/16 150/18 150/19
151/3 151/9 151/17 152/5 152/15
153/18 153/19
Asian [1] 145/20
aside [3] 11/13 31/5 130/17
ask [40] 6/19 7/10 12/15 17/23 21/23
22/15 30/25 31/5 40/7 40/8 41/4 42/23
45/9 51/1 61/8 61/22 63/19 63/21 68/24
70/21 71/8 71/12 74/20 86/15 91/17
94/21 106/13 111/5 111/17 111/20
111/23 120/1 122/25 136/3 136/5
136/14 145/5 146/25 148/2 149/1
asked [47] 12/10 17/23 18/23 19/9 19/21
20/23 21/9 21/25 22/10 23/11 24/5
32/21 34/14 34/22 35/12 36/10 40/6
55/9 56/2 57/11 57/13 66/5 67/10 67/13
71/8 71/18 71/21 71/22 92/11 95/7
95/16 97/3 114/11 114/19 116/2 125/2
125/5 136/11 138/16 143/6 144/6
145/22 146/3 146/8 146/14 146/22
153/11
asking [13] 31/1 31/23 36/21 42/1 44/15
45/4 47/2 47/8 111/3 142/3 143/8
148/21 149/13
asks [1] 92/8
aspect [2] 125/17 125/19
Assembly [1] 129/23
assist [5] 37/7 37/11 84/14 89/4 89/6
assistance [7] 56/21 71/12 87/16 87/23
88/20 89/11 108/24
assistants [1] 83/19
assisting [1] 85/10
association [3] 78/23 78/24 146/2
associations [2] 145/18 146/4
assume [2] 96/17 132/4
assuming [3] 68/22 119/5 148/13
assumption [4] 39/6 39/8 39/10 109/23
Atkeson [7] 138/9 138/11 138/19 139/3
139/10 139/13 139/21
Atlanta [1] 2/18
attached [1] 137/3
attainment [3] 24/22 25/6 26/13
attempt [7] 96/19 108/10 136/18 139/3
139/6 144/9 153/4
attempted [2] 55/22 96/20
attempts [1] 124/16
attention [5] 12/13 47/19 71/7 81/11
81/13
attorney [9] 1/22 1/23 56/2 56/14 59/7
88/17 148/7 148/7 149/19
attorney's [3] 56/17 56/21 88/16
attorneys [7] 61/7 87/18 87/19 87/22
87/25 108/24 112/25
audience [1] 88/9
August [4] 1/4 29/8 122/23 124/4
August 14th [1] 124/4
August 17th [1] 122/23
August 6 [1] 29/8
authority [1] 151/16
authors [1] 139/2
automatically [1] 72/11
automotive [1] 102/1
available [13] 44/25 45/23 58/1 63/18

A
available... [9] 63/21 63/23 64/13 64/25
96/18 108/23 111/17 119/4 153/3
Avenue [5] 2/6 3/2 3/9 3/13 3/18
average [6] 85/18 86/8 86/11 86/13
125/4 125/6
avoid [2] 150/16 150/20
avoidance [1] 150/16
awaiting [1] 81/3
aware [31] 5/15 31/25 36/15 37/16 37/24
47/22 47/25 58/25 59/4 72/4 81/10 82/6
89/9 91/9 106/18 114/24 130/21 131/22
132/23 132/25 133/1 133/4 134/10
139/12 139/13 139/20 141/10 141/15
143/20 143/23 144/3
away [9] 80/7 101/4 102/7 105/14 106/6
106/9 110/9 110/23 112/11

B
babies [1] 80/2
back [17] 5/7 32/10 67/3 67/12 67/21
71/10 103/9 104/17 104/23 108/4
111/12 119/12 120/4 136/7 136/16
137/17 153/22
background [3] 23/12 56/10 61/12
bad [2] 87/4 87/5
BALDWIN [1] 2/2
ballot [12] 48/1 49/14 58/14 117/20
118/1 118/5 118/7 132/2 143/4 143/5
143/7 143/9
ballots [7] 118/23 119/2 121/3 131/23
133/17 133/24 134/8
Bancroft [1] 1/16
bank [4] 64/14 69/7 69/9 92/20
barely [1] 89/8
BARTOLOMUCCI [9] 1/14 4/6 4/10
31/23 32/13 47/16 49/17 61/2 61/7
base [3] 31/2 65/1 65/2
based [12] 11/22 14/15 25/13 25/16
28/10 128/21 140/8 140/21 143/23
146/8 146/22 147/9
basically [5] 21/2 81/13 92/3 92/14
100/23
basis [3] 49/22 151/6 151/7
BATES [4] 1/12 119/19 148/1 151/8
be [149] 5/25 9/19 10/22 16/9 16/10
18/6 18/18 18/19 19/16 19/17 21/6 24/7
24/16 25/22 27/4 27/6 27/22 28/4 28/6
28/7 28/9 28/10 29/2 29/4 29/5 31/21
31/21 33/4 37/18 37/25 38/24 39/23
41/25 43/16 43/23 46/8 46/10 46/10
49/6 49/13 50/17 51/3 51/10 51/14
52/12 52/17 54/1 55/13 55/25 58/15
58/17 58/18 59/10 59/14 59/17 59/17
59/21 59/22 59/22 59/24 60/1 63/21
63/24 66/16 72/13 72/25 74/12 75/4
75/11 82/3 82/5 82/9 82/9 82/16 83/4
87/2 91/6 93/4 93/10 93/20 93/23 94/10
94/17 95/8 95/21 96/9 98/1 101/25
102/10 107/8 107/20 108/25 112/12
114/15 115/8 115/14 115/16 118/9
119/4 120/5 120/12 121/8 126/6 126/7
126/12 126/15 127/3 127/4 127/7 128/2
134/19 135/14 135/18 136/8 136/9
136/22 138/1 142/1 143/10 143/13
143/13 143/13 143/16 143/17 146/3
146/21 146/22 146/23 146/25 146/25
147/3 147/8 147/12 148/3 148/24
148/24 149/16 149/18 150/1 152/2
152/2 152/2 152/11 152/20 153/2 153/3
153/3 153/5 153/20
bear [1] 17/19
bearing [1] 119/19

Beaufort [7] 105/18 106/10 111/11
112/7 113/17 114/5 115/9
became [5] 82/2 82/4 82/6 96/18 107/1
because [58] 8/21 9/18 21/19 40/18
41/17 43/12 44/9 51/7 54/18 55/2 55/3
55/14 57/5 59/6 59/7 59/24 60/7 60/8
60/9 60/16 65/6 65/8 65/24 66/10 67/2
67/2 67/7 67/17 67/23 68/2 71/21 72/14
72/25 74/11 81/14 81/23 84/22 87/13
88/7 90/3 91/24 92/3 92/14 92/20 94/11
95/20 95/24 110/1 111/5 112/12 117/24
136/19 141/17 143/18 143/25 149/1
150/3 152/16
beckoning [1] 82/14
become [6] 80/11 81/10 108/17 109/12
124/14 147/2
been [73] 7/3 8/12 10/7 11/22 11/24
14/22 16/12 34/8 35/19 38/14 39/1 39/1
39/19 39/20 41/5 42/3 42/9 45/15 46/13
52/22 53/15 56/21 60/7 64/24 65/10
65/11 70/9 74/14 75/13 77/4 78/1 78/2
80/5 80/6 80/19 81/1 81/4 84/4 88/15
88/19 88/23 88/24 89/20 92/23 98/10
104/9 104/15 107/15 110/1 117/3 123/7
123/19 129/3 132/2 133/5 133/7 134/19
136/14 138/6 139/21 141/4 143/7
145/22 146/8 146/14 148/8 149/1 149/6
150/13 150/22 150/25 151/6 152/18
BEENEY [6] 2/10 4/5 10/11 19/2 32/21
35/12
before [20] 1/10 5/7 5/21 11/21 11/23
57/5 57/9 64/23 75/24 104/3 107/17
108/15 109/7 116/5 120/14 128/6 142/8
147/25 148/16 148/21
begin [1] 52/7
beginning [3] 14/23 38/17 109/10
behalf [2] 112/20 117/9
behave [1] 125/24
behavior [1] 121/24
behind [1] 90/2
being [11] 23/20 27/14 28/21 58/3 64/1
64/4 75/3 82/16 116/7 142/21 144/6
believe [40] 12/2 13/17 24/13 29/10
34/16 34/20 43/25 44/10 46/24 82/5
88/5 89/19 94/12 94/16 95/9 96/11
100/16 104/3 114/9 114/17 118/9 124/5
126/10 128/15 128/24 131/1 131/10
131/17 136/21 137/20 138/21 139/1
140/13 141/19 143/22 144/7 144/16
144/23 146/12 148/1
bench [1] 5/12
Benedict [1] 66/1
benefit [1] 42/2
best [5] 7/9 26/1 140/19 141/3 143/3
better [5] 14/2 55/25 100/23 113/22
120/8
between [26] 10/3 11/5 16/15 16/24
16/25 17/5 17/9 18/2 18/12 18/14 18/15
18/16 19/10 19/12 19/13 19/14 67/22
68/7 121/13 121/25 128/10 139/16
142/7 145/18 146/2 147/4
between 2004 [11] 16/15 16/24 16/25
17/9 18/2 18/14 18/15 18/16 19/12
19/13 19/14
beyond [1] 96/5
big [1] 146/25
biggest [1] 110/2
bill [5] 81/13 82/4 82/4 87/4 89/24
Billups [10] 8/3 41/5 41/7 42/6 42/11
42/14 43/2 43/7 43/25 44/17
binder [1] 98/5
biracial [2] 99/21 110/4
birth [45] 54/17 54/17 54/20 54/22 55/3
55/6 55/10 55/21 55/22 55/24 56/22

158
59/6 61/10 72/10 74/5 74/12 81/20
81/22 81/23 81/25 83/19 84/1 84/3 84/5
84/7 84/8 84/11 84/20 84/21 85/2 86/12
86/13 86/16 86/21 87/16 87/23 88/15
90/24 91/11 92/2 93/4 105/3 113/14
138/25 150/8
birthday [2] 60/18 72/11
birthed [1] 81/18
births [1] 92/6
bit [15] 6/18 8/2 22/15 23/12 29/19 49/6
55/13 66/14 79/3 84/13 101/20 101/23
113/22 120/2 120/3
black [8] 18/1 18/4 19/3 19/12 37/14
110/4 121/13 121/25
blacks [11] 18/13 19/11 117/19 119/1
119/8 119/9 120/16 120/23 121/1 121/2
147/5
bless [1] 97/21
blighted [1] 85/13
blind [2] 132/11 132/15
Bluffton [2] 101/2 101/5
board [3] 57/16 92/15 120/2
Board-certified [1] 92/15
boarded [1] 85/15
boarding [2] 57/13 57/13
bono [3] 88/4 88/21 89/3
books [1] 142/17
born [14] 53/11 77/16 77/17 86/9 86/10
92/5 92/7 92/8 92/9 92/10 92/12 92/19
92/25 99/16
Boston [16] 124/22 125/14 125/17 126/3
135/1 135/4 136/17 136/24 137/3 145/8
145/12 146/9 146/17 146/19 147/15
147/18
both [13] 6/2 46/25 76/7 104/23 106/10
108/8 125/3 125/3 125/6 139/15 141/7
144/13 144/13
bottom [1] 21/25
bouncing [1] 68/6
BOWERS [7] 1/24 127/5 128/10 128/19
128/23 129/16 151/19
box [1] 87/9
BRADLEY [1] 2/1
break [6] 75/18 75/18 134/1 147/25
148/21 153/22
breaking [1] 152/8
BRENDA [5] 4/12 75/15 76/22 77/3 77/9
Brennan [3] 3/9 98/1 116/16
BRETT [2] 1/11 70/6
BRIAN [4] 1/15 112/19 112/25 117/9
brief [2] 8/7 75/22
briefing [2] 148/15 149/18
briefly [2] 123/17 124/22
bring [1] 69/1
broad [3] 2/13 152/3 153/8
broader [1] 139/10
broadly [1] 150/25
broke [1] 144/17
brothers [1] 100/25
brought [2] 90/4 106/23
BRYAN [2] 1/23 2/2
budget [1] 55/15
building [2] 5/6 73/16
Bullock [6] 132/24 133/2 133/4 134/12
134/23 139/22
burdening [1] 124/25
burdens [1] 90/3
Bursey [1] 70/6
bus [3] 36/16 110/18 110/23
business [2] 5/5 112/12
buttress [1] 40/16
buzz [1] 88/11

C
CA [1] 1/3

C
cab [2] 106/16 108/23
calculate [1] 139/3
calendar [1] 5/23
Calhoun [1] 2/21
California [5] 53/12 55/8 55/14 55/21
62/16
Calkins [1] 129/20
call [8] 75/15 76/22 82/15 97/25 114/12
114/21 116/22 137/12
called [11] 48/20 54/12 65/6 68/2 68/3
68/5 79/24 86/24 87/19 145/18 146/24
calling [1] 146/2
calls [1] 73/24
came [17] 9/2 71/24 81/11 83/13 83/16
83/25 84/10 84/18 85/12 85/17 85/19
86/11 87/10 92/24 104/3 107/8 135/3
CAMONI [1] 2/12
campaign [2] 3/5 27/1
can [84] 10/7 11/25 12/2 17/8 17/13
17/24 18/12 19/10 21/17 23/15 23/23
25/4 29/18 32/10 32/16 32/18 32/24
36/23 40/7 40/8 42/23 44/2 44/19 45/2
45/9 47/18 51/1 51/23 54/10 59/10
59/11 60/17 60/17 60/21 60/22 61/12
61/22 63/20 66/7 66/13 66/22 67/7
68/16 71/7 72/4 72/9 75/4 79/22 82/21
84/20 88/8 91/17 92/19 93/6 93/17
94/11 96/4 96/14 98/24 99/15 101/10
101/20 101/23 102/10 104/8 109/9
109/19 114/12 119/14 119/21 120/1
120/2 120/4 120/4 120/6 122/18 124/22
124/24 128/11 134/19 147/23 149/16
149/22 153/18
can't [11] 23/17 25/16 65/7 65/24 66/15
66/20 68/21 71/23 73/4 73/6 102/2
canceled [1] 65/6
canceling [3] 65/11 65/11 65/11
candidates [1] 109/13
candor [1] 6/6
cannot [3] 10/2 44/22 94/13
capita [2] 24/22 24/24
Capital [1] 3/2
car [7] 28/15 57/22 63/7 63/10 82/18
103/15 114/20
card [71] 13/9 14/7 15/24 15/25 51/16
56/6 57/17 57/17 60/17 60/22 66/18
66/21 66/22 67/6 67/8 69/5 69/14 71/11
71/20 71/24 72/5 72/9 72/11 72/14
72/15 72/18 72/21 73/12 73/21 74/6
85/6 85/7 85/10 86/6 86/7 91/8 91/15
91/19 91/20 93/3 93/19 93/22 94/13
94/14 94/16 95/3 95/4 95/13 95/14
95/15 95/17 95/20 95/21 96/9 96/21
100/14 104/11 104/12 104/13 104/15
105/8 105/8 105/20 105/23 106/3
107/23 108/9 109/4 113/10 118/16
118/18
cards [5] 44/22 95/9 96/18 119/3 121/8
care [4] 31/18 33/11 35/4 141/4
careful [2] 10/23 24/16
CAROLINA [108] 1/3 1/22 1/24 2/20 5/3
5/8 5/9 6/20 10/4 12/22 22/16 25/5
25/19 26/1 26/10 26/19 35/9 38/3 38/10
39/7 39/10 39/12 39/15 39/19 45/17
47/3 52/1 53/8 53/13 58/2 60/11 60/13
61/8 62/1 68/9 68/15 70/10 72/1 74/6
74/6 74/16 75/4 77/13 77/18 78/7 81/3
81/8 81/12 81/16 86/9 86/10 89/10
89/17 89/20 90/11 91/7 94/18 95/25
96/18 97/1 99/1 99/4 100/15 100/17
100/19 100/22 100/24 101/2 101/3
104/4 104/19 105/12 106/19 106/24

107/12 112/18 112/20 113/1 114/25
117/10 118/4 118/6 118/15 119/6
121/14 121/25 122/6 126/4 126/11
126/16 130/8 130/19 130/21 131/21
131/23 132/7 134/2 134/4 134/6 139/8
140/15 140/16 140/18 147/17 147/19
148/5 148/16 151/21
Carolina's [6] 5/13 58/10 69/25 148/20
149/21 153/6
carry [1] 152/14
cars [3] 63/12 102/2 150/7
case [62] 7/15 7/18 8/3 8/6 8/7 8/14 8/16
9/11 9/15 9/16 9/25 12/5 20/6 22/14
29/9 31/1 31/6 31/24 32/22 39/16 41/5
41/7 41/10 41/15 41/19 43/23 44/24
45/4 45/5 45/7 45/8 45/17 48/9 50/3
50/9 50/18 52/1 52/7 52/16 53/18 58/23
61/8 64/2 64/4 73/1 81/7 83/17 84/10
86/24 107/9 108/6 131/2 131/5 133/14
143/10 146/13 148/6 148/10 149/2
150/18 151/11 153/17
cases [3] 9/7 9/17 9/23
cast [12] 48/1 49/13 58/14 117/20 118/1
118/5 118/7 118/23 119/2 121/3 133/24
134/8
casting [2] 143/4 143/5
casualty [1] 109/12
catch [3] 84/18 95/22 104/16
Catch-22 [1] 104/16
categories [2] 27/23 46/22
category [3] 16/2 27/14 39/21
CATHERINE [1] 2/3
caught [3] 67/22 68/7 85/20
caused [2] 18/21 19/19
caution [2] 21/18 45/20
cautious [1] 31/21
ceded [1] 5/6
cell [1] 79/22
census [2] 135/21 145/25
Center [5] 3/5 3/9 80/14 98/1 116/17
centralized [1] 126/21
certain [8] 27/23 102/1 107/5 130/22
131/23 135/9 148/12 152/4
certainly [8] 20/3 20/4 24/21 29/5
142/18 152/7 152/17 152/18
certainly in [1] 142/18
certainty [1] 10/3
certificate [27] 54/17 54/18 54/20 54/22
55/3 55/6 55/10 55/21 55/22 55/24
56/23 59/6 74/5 74/12 81/22 83/20 84/1
84/3 84/5 84/7 84/9 84/21 86/12 86/16
88/16 91/11 105/3
certificates [13] 81/23 81/25 84/11
84/20 85/2 85/3 85/22 86/13 86/22
87/17 87/23 90/24 150/8
certified [1] 92/15
certify [1] 154/3
cetera [4] 28/16 28/16 29/3 152/10
challenge [4] 7/24 80/17 94/20 95/24
challenging [2] 41/12 41/14
chance [4] 6/7 7/14 53/20 129/22
change [7] 27/3 37/22 41/20 49/3 50/6
109/15 128/2
changes [3] 49/5 50/8 149/6
Chapman [1] 77/9
characterize [1] 153/5
characterizing [1] 36/4
charge [2] 59/19 74/13
charged [3] 59/21 74/14 89/1
charging [1] 153/2
charitable [1] 79/6
Charles [2] 134/11 139/22
Charleston [2] 1/20 2/22
chart [2] 16/22 120/15

159
charts [3] 12/13 12/17 47/20
check [7] 6/19 56/11 56/11 85/1 85/1
85/4 86/20
checkbook [3] 82/18 82/18 82/19
checked [1] 136/25
checking [1] 86/1
checks [1] 69/11
chief [3] 50/4 50/7 52/1
child [2] 56/9 56/9
children [3] 62/8 62/11 80/1
children's [2] 79/24 80/8
chose [1] 143/24
Chris [2] 61/7 123/20
CHRISTOPHER [2] 1/14 1/19
Church [1] 79/1
churches [2] 27/25 29/3
CIRCUIT [1] 1/11
circumstances [1] 131/24
cite [3] 44/3 134/22 138/9
cited [4] 21/11 22/3 128/9 134/11
cites [1] 139/21
citizen [1] 79/21
citizens [4] 79/23 80/12 81/16 82/3
city [5] 98/25 105/5 124/21 136/17
146/8
Civil [5] 2/5 2/16 2/20 3/1 3/12
civilian [1] 65/1
claimed [2] 141/16 143/24
claims [1] 150/4
clarifications [2] 149/11 149/24
clarifies [1] 49/5
clarify [4] 49/8 82/25 124/16 129/11
classes [4] 100/2 100/3 100/4 135/13
clause [1] 59/5
clear [9] 75/4 82/5 113/8 124/9 124/11
126/7 136/19 142/1 142/22
clearly [1] 127/6
Clinic [1] 78/7
close [3] 26/5 149/12 153/18
closer [2] 120/10 120/11
closest [1] 105/17
clue [1] 66/9
COATES [1] 1/19
coauthored [1] 124/20
COLLEEN [1] 1/11
College [1] 66/1
colleges [4] 51/4 51/7 51/10 51/14
colloquy [1] 139/16
COLUMBIA [17] 1/1 53/8 53/9 54/25
56/25 61/25 62/3 63/5 64/12 64/22
65/13 65/19 65/25 66/4 66/11 67/22
67/23
columns [2] 119/23 119/24
come [11] 11/22 26/4 67/21 78/11 85/15
90/5 99/13 100/15 101/19 101/25
153/22
comes [1] 72/11
coming [5] 5/12 66/10 92/18 97/20
116/12
commission [7] 22/16 29/11 30/16
36/15 38/7 39/25 151/18
commissioners [1] 151/20
Committee [1] 3/12
commonly [1] 48/20
communities [3] 85/13 85/14 85/15
community [4] 78/15 78/18 79/15 83/14
companies [1] 79/17
compare [2] 125/8 139/6
compared [4] 21/12 22/2 23/21 147/6
comparison [3] 11/21 139/9 139/9
comparisons [2] 17/5 142/22
Compass [1] 1/20
compassionate [1] 79/14
complete [2] 49/13 100/5

COOPER [1] 2/10
C
coordinated [1] 149/14
completed [1] 54/15
copy [2] 44/13 117/11
completely [1] 144/18
core [1] 133/22
complicated [1] 84/16
correct [89] 7/20 7/25 8/1 8/4 8/8 8/16
comply [1] 131/12
8/17 10/5 12/8 12/22 13/2 13/6 13/8
composition [2] 137/1 145/15
13/10 15/6 15/15 18/2 20/10 22/7 23/14
computer [3] 3/24 102/23 103/8
23/16 24/1 28/12 29/1 30/24 31/4 39/2
computer-aided [1] 3/24
46/17 47/13 50/17 56/16 57/6 58/24
conceivably [1] 51/15
62/2 62/24 76/13 76/14 88/21 88/22
concept [1] 80/2
89/15 91/1 91/4 93/17 93/24 95/10 97/6
concerned [1] 82/2
113/10 113/12 113/14 114/3 114/5
concerning [6] 34/17 50/15 122/24
114/8 115/2 115/6 117/20 118/2 118/10
122/24 124/20 129/23
118/12 118/23 119/4 119/5 119/11
concerns [2] 91/14 95/19
120/23 120/24 121/4 121/5 121/8
conclude [5] 11/9 25/8 43/15 51/25
121/14 121/15 121/17 121/20 122/1
121/12
122/2 122/6 122/9 122/10 129/3 133/15
concluded [5] 11/8 11/17 12/7 127/13
134/9 134/24 135/4 135/25 138/1 138/7
141/11
139/1 140/10 140/11 143/22 154/4
conclusion [19] 10/24 11/12 11/15
corrected [3] 55/6 55/22 56/23
correction [1] 25/2
11/22 32/4 33/20 33/25 34/17 35/5
correctly [4] 10/20 19/22 36/7 144/13
126/17 126/19 127/21 133/22 141/14
cost [5] 56/10 83/4 86/8 86/11 86/13
142/11 142/14 142/16 143/2 143/3
conclusions [18] 8/21 11/11 11/14 19/25 could [63] 14/6 15/3 16/10 21/6 24/5
31/19 32/21 33/12 34/4 122/3 126/21
27/4 28/2 28/13 28/14 29/4 29/5 39/23
127/17 127/18 133/25 140/21 140/25
40/19 41/16 42/5 42/24 44/4 44/12
141/20 141/22 141/23
47/12 51/15 53/3 54/1 55/13 57/12
condition [1] 58/16
58/18 70/12 70/15 70/21 71/11 72/7
conditions [1] 150/7
72/8 73/3 73/16 73/19 74/8 75/25 77/8
conduct [2] 25/11 26/18
78/20 82/22 83/3 84/13 94/21 95/3 95/7
conducted [4] 98/1 142/18 146/18
95/14 98/4 99/20 99/22 106/16 107/6
146/23
110/2 113/21 120/2 130/17 133/21
conducting [1] 21/13
136/11 136/13 136/15 138/24 145/16
confer [1] 116/4
145/18 150/12 152/11
confidence [3] 60/12 60/20 89/21
couldn't [7] 14/15 67/4 71/22 71/23 83/6
confident [3] 60/14 60/16 60/23
84/21 107/1
confirm [3] 96/8 118/9 134/22
counsel [5] 6/14 52/12 88/8 94/3 130/8
conflict [2] 150/16 150/20
count [1] 38/9
confused [1] 93/4
counted [3] 133/24 134/8 143/9
confusion [1] 92/5
counties [3] 50/5 97/1 126/15
congressional [3] 138/20 139/7 141/8
country [1] 58/17
conjunction [1] 7/15
county [27] 21/14 27/24 50/10 73/16
Connecticut [2] 3/2 86/13
73/23 87/19 93/21 105/5 105/8 105/20
connecting [1] 49/18
105/24 106/3 108/19 112/6 115/9
consequently [1] 44/22
115/11 115/15 118/9 119/10 120/17
conservative [1] 41/2
120/22 121/2 121/4 121/6 129/4 129/17
consider [4] 9/6 44/20 44/24 45/12
151/20
considered [4] 15/10 45/14 51/7 87/5
couple [8] 12/15 23/10 30/25 123/1
considering [2] 9/8 26/24
123/24 124/1 144/3 148/4
consistency [2] 130/2 130/5
course [13] 24/3 56/5 60/5 68/17 101/11
consistent [2] 124/9 126/22
124/3 124/19 139/18 149/2 149/2 149/3
constantly [1] 106/23
149/18 151/15
Constitution [1] 3/18
court [43] 1/1 3/16 3/17 6/11 8/8 8/9
constitutional [4] 50/12 50/12 60/9
8/11 8/18 9/6 9/14 9/17 10/22 10/22
150/16
12/5 16/15 20/7 20/17 23/11 31/2 31/17
consult [1] 76/17
42/6 44/12 56/1 56/3 56/5 56/13 56/22
contact [2] 107/8 112/9
76/15 76/18 78/20 87/25 93/10 98/2
contacted [8] 55/7 55/21 56/2 56/18
99/13 116/16 124/25 128/9 128/22
84/19 87/6 87/7 107/4
128/23 128/25 129/7 148/13 150/18
contains [1] 118/16
court's [6] 6/22 45/7 52/10 97/24 122/23
contamination [1] 137/8
129/11
context [3] 34/24 35/20 138/4
court-ordered [3] 56/1 56/3 56/5
contingency [1] 59/18
courthouse [2] 3/17 57/19
continually [1] 49/9
courtroom [5] 30/5 30/12 37/2 48/23
continue [3] 24/7 42/18 151/7
76/16
CONTINUED [1] 7/5
courts [2] 9/7 9/19
continuing [3] 39/18 41/24 42/18
covariants [2] 125/4 125/7
contrary [2] 8/19 40/23
cover [1] 150/12
contrast [2] 11/16 12/6
covered [1] 50/5
contributions [1] 12/4
covers [1] 150/6
control [2] 96/23 137/9
CRAIG [4] 4/15 97/25 98/9 98/17
conversation [2] 95/12 142/7
create [1] 60/20
convicted [2] 56/9 56/11
created [2] 37/19 47/19
convoluted [1] 14/23
creates [1] 127/6

160
creating [2] 37/17 126/12
credit [3] 85/5 85/10 86/6
Crew [1] 80/16
crime [2] 79/23 85/16
criminal [1] 56/10
criteria [2] 38/11 135/9
criticism [1] 45/7
criticize [1] 7/19
Cromwell [1] 2/13
cross [6] 6/12 75/3 122/13 128/5 128/7
130/9
cross-examination [2] 6/12 122/13
cross-examine [1] 130/9
cure [1] 94/17
curious [1] 51/17
current [12] 37/20 57/7 57/20 59/3
91/20 93/19 95/4 100/13 100/14 131/8
131/14 151/10
currently [5] 23/24 53/23 98/19 109/3
124/9
customer [1] 101/18
Customers [1] 101/25
cut [1] 90/6
cuts [1] 55/15
CV [1] 5/4
cycle [1] 40/20

D
D-E-B-N-E-Y [1] 129/9
D.C [2] 56/25 99/3
damaged [1] 84/1
DANIEL [1] 2/4
data [40] 7/20 11/13 11/14 11/20 11/23
13/8 13/16 13/17 13/18 14/6 14/15 15/2
15/4 22/16 22/16 22/17 22/18 22/20
22/21 22/22 25/12 35/23 42/15 43/3
45/23 46/3 46/5 46/7 46/12 46/25 47/12
132/5 133/18 133/21 134/1 135/3
137/18 137/20 138/19 144/17
database [6] 38/7 38/8 38/12 38/15
38/16 39/25
date [15] 38/13 54/13 57/5 57/9 61/9
71/1 71/2 72/10 92/2 93/4 93/5 113/14
138/24 148/10 154/7
daughter [19] 58/1 58/9 62/6 62/9 63/2
64/9 64/11 65/12 66/19 67/10 67/12
67/19 68/13 68/21 68/25 70/18 71/12
71/18 73/22
David [1] 133/9
day [11] 1/6 6/9 74/8 92/5 102/12
102/13 102/14 102/15 112/14 140/4
149/21
days [6] 65/17 86/3 123/24 124/2 127/1
153/11
DC [7] 1/4 1/18 2/7 3/3 3/6 3/14 3/18
DD [1] 105/3
deal [2] 125/13 130/5
dealing [1] 153/16
dealt [1] 126/8
death [1] 85/3
Debney [2] 129/9 129/19
DEBOSE [17] 4/15 97/25 98/9 98/14
98/17 98/18 98/23 99/16 100/13 101/15
102/25 106/18 109/7 110/6 112/23
115/25 116/13
decent [1] 82/2
decided [2] 86/25 109/21
decision [3] 31/2 43/25 59/15
decrease [3] 25/18 26/12 26/21
decreased [4] 26/11 27/22 46/13 46/23
decreases [1] 26/21
decree [1] 83/22
decrees [1] 85/3
deemed [1] 59/14

D
deems [1] 150/9
deep [1] 108/13
defendant [7] 2/10 4/8 6/3 6/3 52/7
52/16 76/22
defendant-intervenors [5] 4/8 6/3 52/7
52/16 76/22
Defendants [2] 1/7 2/1
defending [1] 41/13
Defense [1] 22/20
defense's [1] 52/7
definitely [1] 83/8
definition [3] 124/9 124/11 128/8
definitions [1] 130/3
degree [5] 10/2 25/23 28/19 45/20 100/5
DELLHEIM [9] 2/1 4/5 6/15 7/8 12/14
23/20 24/18 31/7 47/2
DELORES [4] 4/9 52/17 52/21 53/4
demographic [3] 25/12 144/15 145/13
demographics [1] 63/20
demonstrated [1] 11/4
demonstrates [1] 119/1
demonstrative [2] 12/15 76/6
demonstratives [4] 6/22 47/19 76/1
76/15
denied [1] 82/3
denoted [5] 14/8 15/12 15/22 16/12
38/24
Department [15] 2/5 13/9 22/20 22/21
52/4 52/8 82/17 84/19 84/22 84/23
84/23 87/7 87/8 87/9 114/25
depend [2] 78/12 153/10
depending [1] 102/11
depends [1] 25/24
deposed [2] 64/1 64/4
deposition [38] 7/19 7/23 11/25 17/16
17/22 20/13 21/9 21/22 29/9 29/15
29/25 30/9 30/10 34/9 64/6 64/20 70/13
70/22 71/1 71/1 71/2 90/15 90/20 93/7
93/16 94/2 95/7 98/4 114/10 117/11
123/20 123/21 128/22 128/24 129/6
129/22 130/12 141/1
depositions [2] 123/23 129/12
depression [1] 11/10
deputy [4] 1/23 76/16 76/18 148/7
describe [6] 78/8 99/22 123/17 124/22
126/13 130/2
described [3] 40/22 90/23 148/25
designed [2] 79/6 91/24
desperately [1] 87/20
despite [1] 140/24
destroyed [1] 84/2
detail [1] 84/14
details [2] 125/1 151/25
Detention [1] 80/14
determine [1] 151/22
devastated [1] 80/4
dial [1] 79/22
did [146] 7/19 7/23 8/6 8/7 10/20 11/3
11/6 11/9 12/10 13/22 13/22 14/2 14/3
14/10 14/12 14/17 14/20 16/20 16/22
17/1 18/10 18/23 19/9 20/23 21/1 22/10
22/17 22/21 22/23 22/25 23/3 25/11
34/15 34/22 35/2 37/5 38/9 38/18 38/22
39/5 39/6 39/24 41/15 41/20 42/14 43/3
43/7 43/13 44/24 45/12 45/16 45/17
45/21 45/21 46/5 46/25 48/25 49/8
54/24 55/5 55/7 55/11 56/8 56/17 56/25
57/11 57/15 58/5 58/5 58/8 66/18 67/16
68/7 68/11 69/20 69/24 70/2 70/7 70/23
71/16 81/10 82/12 85/9 87/15 87/22
88/9 89/2 95/17 99/3 99/6 99/8 99/11
99/13 99/24 100/2 100/15 100/17

100/19 104/18 104/22 104/22 105/1
105/6 105/20 105/21 106/11 106/21
107/3 107/24 108/10 108/16 108/17
108/21 108/24 109/1 109/11 109/15
109/16 109/24 111/25 114/17 125/8
129/17 135/7 135/15 135/16 135/18
136/5 136/18 137/3 137/6 143/20
144/11 144/18 144/18 144/21 145/13
145/14 145/15 145/16 145/23 146/16
146/24 150/18 150/19 151/19
didn't [43] 13/16 14/7 15/13 15/24 16/21
18/8 20/17 21/1 23/6 23/6 25/14 26/18
27/16 27/19 27/23 30/9 33/6 36/20
38/15 46/3 66/11 66/12 67/17 73/1 94/3
100/5 105/20 105/22 107/25 109/22
109/25 110/1 125/17 126/9 134/1
135/11 135/23 136/3 140/14 140/14
141/17 143/21 145/24
die [2] 107/17 108/15
Diego [1] 62/15
differ [2] 18/21 19/19
difference [1] 147/4
differences [5] 121/21 121/24 127/20
127/23 147/12
different [11] 54/25 57/25 124/15 128/7
128/12 137/11 139/22 146/21 149/15
150/23 152/9
differentiate [1] 143/4
differently [1] 125/25
difficult [5] 59/23 59/24 114/15 136/8
148/15
difficulties [1] 74/4
difficulty [1] 90/1
digits [4] 60/18 72/15 92/1 138/25
Dilaudid [1] 67/3
direct [12] 7/23 11/25 12/13 71/7 93/6
98/2 116/21 117/6 124/5 124/19 139/9
139/9
directed [1] 148/5
directions [1] 66/16
directly [2] 7/21 132/5
Director [2] 78/24 151/17
disabilities [1] 150/7
disagree [6] 17/13 20/21 94/20 95/2
95/5 150/6
disagreeing [1] 17/14
discern [1] 13/15
discharge [1] 105/4
Discover [1] 85/7
discrepant [1] 143/17
discretion [6] 126/6 130/24 131/1 131/4
147/16 147/19
discrimination [1] 127/15
discriminatory [3] 127/24 153/10 153/12
discuss [1] 124/20
discussed [5] 12/14 21/8 43/12 49/16
145/11
discussing [2] 107/4 134/19
discussion [2] 5/14 152/22
disenfranchised [1] 87/2
disobey [1] 127/6
disobeying [1] 128/10
disparate [16] 10/5 10/23 11/11 31/9
31/13 31/18 32/3 32/5 33/11 33/17
33/21 33/25 34/1 35/4 35/13 43/16
disparately [1] 20/3
disparities [3] 121/12 121/17 127/12
disparity [2] 18/12 19/10
disproportionate [2] 23/21 24/6
disproportionately [2] 11/17 12/7
disregard [1] 127/3
distances [1] 114/22
DISTRICT [6] 1/1 1/1 1/11 1/12 138/20
139/7

161
districts [1] 141/8
division [6] 2/5 79/21 79/24 80/3 80/10
80/13
divorce [2] 83/22 85/3
DMV [24] 13/6 14/3 14/6 14/18 14/18
14/20 15/5 15/8 15/14 15/19 16/8 22/15
22/17 38/8 82/22 83/2 83/3 87/2 91/1
104/19 104/23 105/1 105/14 112/1
DMV-issued [3] 14/3 15/5 104/19
DMVs [1] 54/25
do [213]
doctor [7] 11/25 20/12 65/19 77/25 78/1
78/2 92/21
doctor's [4] 64/18 64/21 65/5 65/9
document [5] 44/11 93/22 94/10 106/14
119/15
documentation [1] 81/19
documented [1] 92/6
documents [6] 29/22 30/22 85/22 85/23
85/24 86/7
does [29] 6/2 6/4 9/2 27/3 35/16 35/18
41/11 49/3 54/18 60/13 62/5 63/14
64/11 73/14 74/19 76/15 77/21 80/23
88/7 89/20 101/7 101/13 111/13 126/1
126/4 126/16 127/16 141/13 148/17
doesn't [9] 28/15 42/2 43/23 45/5 49/19
54/23 60/16 113/22 142/14
doing [9] 23/1 23/4 37/23 73/18 80/2
90/2 126/6 126/7 127/7
DOJ [2] 5/9 6/4
don't [102] 5/14 7/21 8/24 9/13 9/21
9/22 10/6 11/7 12/23 12/25 13/3 15/17
16/6 16/9 17/1 17/11 17/14 19/4 20/11
20/20 20/21 20/22 23/13 23/17 23/24
24/3 24/9 24/13 24/23 27/17 28/3 28/15
28/16 28/18 30/1 37/20 38/25 42/20
43/11 44/7 44/8 48/3 49/5 51/11 51/13
54/3 54/4 54/9 59/6 59/6 61/19 64/10
66/2 66/9 66/20 69/3 69/4 70/3 71/20
71/23 71/24 72/12 75/18 75/18 76/18
84/22 88/11 94/11 95/5 98/21 98/23
100/14 101/8 102/22 102/24 103/1
103/3 103/10 103/11 103/16 103/18
103/20 111/18 124/11 131/10 131/16
131/17 136/25 137/4 137/16 137/20
139/5 139/5 139/23 141/18 143/4 143/8
144/1 144/16 148/19 152/18 153/16
donated [1] 79/15
donations [1] 79/17
done [11] 21/6 21/7 22/14 73/2 80/14
81/6 90/24 124/24 131/18 132/1 136/13
door [2] 151/9 153/14
double [2] 132/11 132/15
double-blind [2] 132/11 132/15
down [25] 16/21 16/25 18/10 26/5 27/3
27/6 27/10 38/11 51/23 59/12 80/20
92/9 92/20 101/9 106/16 108/19 108/22
108/25 112/10 113/21 120/6 122/18
142/8 147/23 152/8
downtown [1] 66/4
DR [71] 4/4 4/12 4/18 4/21 6/12 6/12 7/7
7/11 7/19 7/24 10/16 10/20 14/17 16/19
17/17 17/19 19/8 21/2 22/13 23/10 29/8
30/25 32/13 34/9 35/1 35/7 44/19 75/15
76/2 76/22 76/24 77/3 84/25 86/18 90/6
90/14 90/23 92/19 94/1 94/4 94/12
96/12 97/11 97/16 116/20 116/23
117/16 119/15 119/17 119/21 120/14
122/20 122/21 123/11 130/9 130/11
130/17 132/10 132/24 132/24 133/2
133/2 133/8 134/11 134/11 134/23
134/23 139/22 139/22 145/2 145/11
draw [1] 11/12
drawing [2] 32/22 122/3

38/17 46/8 75/7 96/22 96/23 118/1
D
121/25 134/7 134/7 139/15 149/21
drawn [3] 18/19 19/17 142/22
151/12
drew [1] 37/19
enduring [1] 67/2
drive [9] 63/5 63/18 63/23 64/11 64/25 enforced [1] 135/6
engaged [1] 81/1
70/18 71/12 111/1 111/21
driven [7] 64/7 64/8 64/14 64/16 64/18 enjoined [1] 43/5
enjoy [1] 60/7
64/21 65/12
driver [2] 57/21 103/19
ensure [1] 96/13
driver's [27] 13/6 13/8 13/22 14/7 14/11 entire [3] 21/16 77/22 94/4
entitled [3] 87/20 133/9 140/3
14/12 14/18 15/23 15/24 16/11 28/15
38/3 38/8 38/10 54/4 54/24 55/2 57/18 enumerated [1] 35/23
63/3 74/6 83/21 103/17 103/21 103/25 ERIN [1] 2/3
err [1] 49/10
104/6 105/2 105/12
drives [1] 63/25
erring [1] 152/5
driving [1] 62/23
especially [2] 62/20 148/11
dropped [1] 18/9
ESQ [1] 1/14
dropping [2] 18/14 19/11
ESQUIRE [26] 1/15 1/15 1/16 1/19 1/24
drove [1] 82/18
2/1 2/1 2/2 2/2 2/3 2/3 2/4 2/4 2/10 2/10
Dubose [1] 83/24
2/11 2/11 2/12 2/12 2/15 2/19 3/1 3/5
duly [5] 52/22 77/4 98/10 117/3 123/7
3/8 3/8 3/12
DUNN [1] 2/19
essence [2] 5/13 92/11
during [7] 30/5 75/3 81/19 112/12
essentially [3] 14/6 41/18 42/8
Essex [1] 105/8
149/18 149/18 151/15
DVORKIS [1] 2/11
establish [2] 16/3 62/22
establishment [1] 101/19
E
estimate [5] 18/11 23/8 23/9 26/1
e-mail [2] 85/8 85/10
137/14
e-mails [2] 87/8 87/20
Estimated [1] 76/6
each [5] 15/17 135/22 139/4 145/15
et [9] 1/6 5/3 5/4 28/16 28/16 29/3 133/9
145/20
138/9 152/10
earlier [6] 89/14 96/13 97/7 141/5
even [15] 23/17 24/7 39/19 66/20 67/10
148/14 153/15
72/14 72/24 80/2 81/23 85/21 87/14
early [1] 50/6
91/13 91/14 100/2 153/4
easy [2] 59/23 91/22
evening [2] 5/23 71/18
ecological [2] 145/18 147/10
event [3] 10/7 11/2 33/24
economic [1] 80/4
ever [18] 55/5 56/9 64/14 64/16 64/18
education [9] 26/13 80/24 85/17 85/18
68/9 69/9 69/11 69/20 69/24 70/9 74/15
99/22 99/24 100/1 126/23 131/12
81/16 109/7 111/20 132/14 132/17
educational [4] 24/22 25/6 27/1 61/12
137/18
effect [15] 26/25 27/1 34/18 43/8 43/16 every [11] 9/6 9/15 9/16 9/16 9/18 69/1
43/17 72/4 115/14 115/16 125/22 126/9 74/15 80/15 96/13 116/8 133/18
everybody [2] 15/13 152/16
148/17 148/24 153/10 153/12
Effects [1] 140/3
everyone [7] 5/3 14/9 28/12 40/17 125/1
efforts [2] 54/10 96/22
135/5 150/3
eight [1] 5/10
everyone's [1] 20/2
either [6] 5/15 8/10 27/24 30/20 88/8
everything [5] 9/25 27/2 27/6 54/16
106/13
151/21
election [44] 18/9 21/14 22/16 29/11
evidence [4] 29/9 121/21 139/11 147/12
evolution [1] 149/1
30/16 36/15 38/7 39/25 40/20 42/12
67/16 67/17 68/8 68/9 74/8 93/21 112/6 exact [8] 23/15 82/16 98/18 98/24
115/9 115/15 118/7 118/10 118/21
128/14 137/16 141/18 144/1
exactly [2] 141/4 151/22
118/22 119/11 120/17 120/22 121/2
examination [36] 4/5 4/5 4/6 4/10 4/10
121/4 121/6 124/25 126/22 129/13
133/10 133/11 135/1 135/4 138/4
4/11 4/13 4/13 4/16 4/16 4/17 4/19 4/19
138/23 139/6 140/4 148/18 150/3
4/22 4/22 4/23 6/12 6/18 7/5 10/14
151/17 151/20
35/10 53/1 61/3 75/1 76/2 77/6 90/12
elections [6] 11/5 39/15 60/12 68/16
98/2 98/12 112/21 115/23 117/14
89/21 150/5
122/13 123/9 130/15 145/9
electronically [1] 76/15
examine [1] 130/9
Electronics [1] 88/10
examined [6] 7/3 52/22 77/4 98/10
ELMO [4] 12/2 17/21 20/15 76/1
117/3 123/7
else [9] 9/25 14/9 60/23 62/7 77/19
example [4] 14/4 88/20 128/9 135/9
examples [1] 128/15
105/6 125/1 147/23 152/16
embarrassing [1] 111/4
Excelsior [1] 78/6
empirical [7] 50/22 50/23 125/9 131/18 exception [10] 49/1 49/4 122/25 123/15
132/1 132/4 137/17
123/15 126/14 127/12 127/14 129/25
employed [3] 7/24 61/15 63/14
153/8
employee [3] 14/4 15/19 15/22
exceptions [3] 150/12 150/21 151/7
employee-issued [1] 14/4
exclude [4] 38/18 39/5 39/22 39/24
employment [2] 64/23 64/24
excluded [2] 9/14 39/3
encourage [1] 80/11
excuse [9] 7/11 9/16 26/5 64/3 93/3
encouraging [1] 127/3
100/18 101/22 103/6 105/19
end [18] 5/21 5/23 6/9 8/11 8/22 17/21 excused [4] 75/11 97/19 116/11 147/23

162
excuses [1] 58/19
Executive [2] 78/24 151/17
exhausted [1] 86/3
exhausting [1] 84/17
exhaustive [1] 133/20
exhibit [5] 44/5 44/7 44/9 76/5 119/18
exhibits [1] 76/7
exist [2] 35/25 121/17
existing [8] 45/14 127/20 130/18 130/21
131/9 131/15 131/19 131/22
exists [2] 25/8 25/17
exit [3] 136/15 136/19 136/21
expansive [1] 150/12
expect [1] 149/16
expectation [1] 46/6
expensive [1] 84/17
experience [3] 92/13 92/18 138/16
experimental [1] 125/18
expert [19] 7/11 8/3 8/15 8/20 9/8 9/16
9/17 22/23 29/10 39/16 41/7 41/15
41/18 41/19 42/6 48/9 117/22 119/18
124/18
expiration [1] 38/13
expired [3] 38/14 57/17 57/21
explain [4] 18/12 19/10 109/9 127/10
explained [4] 54/12 55/11 56/4 57/10
explaining [1] 87/13
explanation [2] 16/23 17/3
explicitly [2] 126/8 146/20
expound [1] 91/15
Express [1] 85/7
extent [5] 12/25 34/4 34/5 142/19
153/18
extrapolate [1] 146/5
extrapolating [1] 31/18
extremely [1] 84/17

F
fact [24] 7/22 16/19 19/24 20/6 20/16
24/8 35/22 39/12 67/18 69/20 82/14
83/13 83/18 84/6 86/23 88/1 89/22 95/2
120/21 141/4 146/20 148/17 149/13
153/2
factors [11] 24/19 25/19 26/4 26/10
26/15 26/17 32/6 33/18 33/23 33/25
34/5
facts [2] 25/14 149/16
failed [1] 44/20
failure [1] 127/19
fair [4] 130/24 133/24 137/22 138/3
fairly [3] 9/22 21/15 152/12
fairness [4] 11/19 17/5 21/21 25/11
false [1] 150/10
familiar [9] 53/17 58/10 58/22 65/24
66/6 72/1 130/18 130/20 132/10
families [3] 78/11 80/7 80/8
family [19] 25/1 56/13 78/12 78/25 79/3
79/4 79/5 79/13 79/18 79/20 80/3 80/16
82/19 83/15 85/25 87/25 89/11 97/7
100/24
famished [1] 86/4
far [11] 96/20 99/25 101/4 102/7 105/14
106/6 106/9 109/3 110/9 110/23 124/17
fashion [1] 40/8
fast [2] 43/20 139/14
faster [1] 113/22
favorably [1] 139/21
faxes [1] 87/8
February [2] 113/20 114/2
federal [3] 79/9 79/11 150/20
fee [3] 56/13 56/19 59/21
feel [4] 60/14 60/16 60/23 111/3
feeling [2] 111/5 149/15
fees [2] 56/17 88/25

Forty [1] 62/10
F
forward [1] 43/20
felt [1] 24/7
found [23] 9/19 20/8 20/20 21/9 39/2
few [11] 41/4 61/9 90/15 91/17 108/22
46/17 83/3 83/6 85/5 92/3 107/21
113/6 126/18 127/1 142/11 148/1
107/22 108/2 108/11 109/1 109/13
151/25
109/20 125/2 125/5 125/21 141/15
field [10] 1/15 4/16 4/19 38/13 38/25
144/4 147/2
foundation [6] 2/16 2/20 36/17 36/23
112/19 112/25 117/9 117/17 132/12
fifth [2] 22/2 45/15
79/9 79/12
fight [1] 87/4
foundational [2] 132/21 132/22
fighting [1] 82/4
foundations [1] 79/10
figure [4] 23/18 68/20 76/19 136/4
four [13] 5/9 5/10 12/24 23/13 23/24
figures [2] 23/15 145/17
26/2 28/18 45/14 60/18 72/15 92/1
file [1] 76/16
129/14 138/25
files [1] 145/12
fraction [5] 145/19 145/19 145/20
filing [2] 56/13 56/19
145/20 145/21
filled [2] 54/14 54/25
fraction-wide [1] 145/19
final [1] 147/14
frankly [1] 32/18
finally [3] 30/25 50/20 139/25
free [10] 26/25 28/6 33/23 37/11 37/23
financially [1] 90/3
44/21 79/23 80/7 114/24 119/3
find [12] 6/8 20/17 80/5 83/20 93/12
FREELON [7] 4/9 52/17 52/21 53/4 61/5
102/2 107/6 111/18 146/1 146/6 146/12 64/1 70/21
FREEMAN [1] 2/4
153/16
findings [3] 140/15 140/17 140/17
Friday [2] 30/9 149/12
fine [3] 5/24 33/3 100/4
friends [8] 106/15 108/22 110/25 111/8
fingerprint [1] 56/6
111/17 111/20 112/9 114/12
finish [4] 13/25 32/15 94/4 142/8
from 2004 [1] 16/21
finished [1] 83/24
front [5] 8/24 17/11 17/15 20/11 24/1
finishing [1] 93/11
full [2] 79/1 125/1
fire [2] 84/1 84/2
functionally [1] 144/19
first [25] 52/13 52/16 54/18 54/22 54/23 fund [1] 79/13
fundamentally [2] 144/21 150/23
55/3 55/4 55/7 56/6 59/8 81/10 83/25
funds [2] 79/11 79/13
84/18 84/20 86/1 87/2 91/17 106/21
further [13] 10/9 50/24 60/25 74/18
108/5 108/10 112/9 119/23 120/19
127/18 138/19
75/10 90/7 96/1 97/15 112/16 117/6
fit [1] 144/11
122/17 128/4 130/6
five [5] 50/5 80/15 81/6 110/10 118/14 furthering [1] 99/25
five miles [1] 110/10
future [11] 10/7 11/1 34/18 68/15 68/18
fixed [1] 59/25
121/17 121/18 122/4 122/5 150/5 151/8
flawed [5] 9/10 9/20 9/23 91/23 92/3
G
flaws [1] 8/22
GA [1] 2/18
flew [1] 57/2
Galt [1] 114/8
flight [2] 57/5 57/9
gap [39] 10/3 23/22 24/13 25/8 25/17
flipped [1] 69/3
flood [1] 83/14
25/20 25/21 25/22 26/7 26/9 26/12
Floor [1] 3/10
26/21 27/3 27/5 27/7 27/9 27/11 27/22
floored [1] 85/8
28/1 29/4 31/11 33/5 33/6 35/23 35/24
Florida [4] 8/15 49/15 50/2 50/5
35/25 36/2 36/4 36/8 43/14 46/13 46/15
Florida's [2] 8/20 50/6
46/17 46/19 46/23 46/24 146/15 147/9
flyers [1] 83/14
147/11
gaps [2] 146/25 147/3
focus [1] 152/9
GARRARD [1] 2/10
fold [1] 136/6
gas [3] 111/13 111/14 111/15
follow [8] 23/10 52/8 115/25 129/21
gates [1] 83/14
143/8 145/7 149/25 151/24
follow-up [6] 115/25 129/21 143/8 145/7 gave [4] 17/23 23/8 54/13 71/9
general [17] 1/22 1/23 24/21 26/18
149/25 151/24
following [9] 14/21 19/9 19/10 34/14
67/16 67/17 124/25 125/21 129/23
135/1 135/3 140/17 140/17 148/7 148/7
34/15 42/15 43/3 92/23 152/4
follows [6] 7/4 52/23 77/5 98/11 117/4
148/18 149/19
generally [5] 62/3 78/9 86/16 89/1
123/8
footnote [1] 21/18
140/25
GENN [4] 3/8 4/16 4/17 98/1
for 2012 [1] 148/24
Georgia [39] 9/25 10/21 11/3 11/4 12/5
Foradori [3] 3/16 154/3 154/7
forego [1] 112/14
13/2 13/5 13/9 13/13 13/19 14/13 16/15
foregoing [1] 154/3
17/3 18/2 18/17 19/14 19/25 20/8 20/17
forget [1] 67/11
21/1 21/11 31/17 32/11 33/2 33/5 33/13
forgive [2] 9/13 42/17
35/5 41/12 42/16 43/4 43/8 43/23 47/18
forgot [1] 67/14
47/22 48/17 51/3 76/5 77/17 77/18
form [7] 45/15 57/22 105/3 112/7 117/6 Georgia's [2] 132/23 133/1
GERALD [1] 3/5
122/22 135/13
forms [17] 12/24 13/19 14/16 26/2 37/20 geriatric [1] 78/10
geriatrician [2] 92/15 92/16
44/21 44/25 45/13 45/14 46/9 53/24
54/6 54/9 118/14 130/22 142/17 142/21 get [97] 23/25 27/23 30/8 37/22 47/9
forth [3] 85/20 104/17 126/11
54/10 54/10 54/13 54/24 55/2 55/5

163
55/20 55/22 55/24 56/1 56/3 56/6 56/7
56/10 56/25 57/3 57/8 57/16 57/19
57/25 58/8 59/11 59/21 60/17 60/22
62/21 65/9 65/24 66/15 66/18 66/19
68/7 68/11 68/18 68/20 68/23 69/2 69/7
71/12 71/19 72/9 73/1 73/22 80/18
80/20 81/24 82/22 83/6 83/16 84/20
84/21 85/23 87/1 88/3 90/24 91/21 96/5
99/3 99/8 99/11 99/24 101/10 102/5
104/5 104/18 105/11 106/11 106/12
107/6 108/6 108/21 108/24 108/25
110/11 110/13 112/7 114/11 114/12
114/15 114/18 114/20 115/8 115/11
115/14 115/16 127/23 133/21 136/11
141/5 143/16 143/18 152/11
getting [15] 15/18 45/5 45/6 49/12 56/5
56/22 63/20 65/10 66/22 67/21 74/5
87/16 87/23 88/15 152/17
give [27] 12/10 18/23 19/9 19/21 20/23
22/10 23/11 32/25 34/15 34/22 42/2
44/2 51/5 66/16 70/12 76/16 76/18
79/22 80/7 98/24 114/21 114/22 115/4
125/16 128/11 151/9 153/18
given [9] 9/24 13/18 74/1 131/3 131/6
141/4 148/9 148/10 152/18
giving [3] 49/18 98/18 98/22
Glover [1] 84/2
go [45] 6/2 18/10 20/16 24/14 30/8
32/16 36/16 36/25 48/5 54/9 54/13
55/23 56/13 59/10 59/25 63/24 64/7
64/11 71/10 76/21 79/18 80/4 80/13
85/1 85/10 88/12 93/20 98/6 106/16
108/4 108/19 110/2 110/6 111/5 111/18
111/25 112/6 113/7 114/22 118/7
118/20 118/22 119/14 123/3 134/16
goal [1] 39/22
God [1] 97/21
God's [2] 80/6 91/23
goes [9] 63/17 72/4 83/5 93/1 110/20
115/14 115/16 118/4 152/15
going [50] 17/19 17/22 20/15 21/23
22/14 25/18 27/11 28/4 28/9 28/10
29/14 30/8 31/19 34/25 35/1 41/23
42/18 43/24 44/1 49/10 52/7 55/12
55/14 56/3 56/4 61/8 71/7 82/20 83/16
86/17 86/20 87/5 93/9 94/11 103/9
104/23 105/14 107/18 110/3 112/12
113/22 120/5 122/25 128/1 136/22
146/7 148/3 149/22 151/3 153/4
Golden [1] 78/21
gone [1] 124/16
good [33] 5/2 6/12 6/13 7/7 7/8 10/16
10/17 10/18 24/12 24/12 52/14 61/5
61/6 90/17 90/18 90/18 98/14 98/14
98/15 102/14 112/19 112/23 112/24
116/22 117/16 117/17 117/18 120/12
123/11 123/12 130/11 130/11 147/12
Gordon [1] 84/8
Gospel [1] 79/1
got [18] 12/4 22/15 22/15 22/16 22/20
22/20 66/21 67/6 71/18 71/24 73/11
83/15 87/12 100/20 151/16 151/17
151/19 151/20
gotten [1] 64/23
government [15] 5/6 47/23 51/3 51/5
51/7 57/7 57/20 59/2 72/22 74/19 79/11
81/17 84/25 122/13 145/5
government-issued [5] 57/7 57/20 59/2
81/17 84/25
grace [1] 80/6
graced [1] 87/24
gracious [2] 88/1 88/2
graciousness [1] 89/2
grade [2] 83/25 85/18

G
graduate [1] 61/13
graduated [1] 100/3
grant [1] 150/11
grants [3] 79/9 79/12 79/12
grateful [1] 79/16
grave [1] 91/14
Gray [3] 88/1 88/20 89/1
great [7] 5/25 125/8 126/13 130/5
132/10 141/4 147/21
grocery [1] 64/16
group [5] 28/19 28/21 137/1 137/9
139/4
groups [2] 135/17 144/10
guess [12] 15/3 24/14 25/24 27/4 29/24
41/16 50/4 73/19 73/19 74/12 151/1
152/13
guidance [4] 48/25 125/15 131/3 131/5
guy [1] 70/6

H
had [97] 6/7 7/14 13/8 13/12 13/15
13/19 13/24 14/4 14/5 14/6 14/13 14/24
15/5 15/7 15/19 15/22 16/8 16/11 21/14
23/1 23/3 35/23 36/20 38/13 38/16
39/18 39/19 41/16 42/9 42/9 42/11
45/23 46/8 49/11 49/24 51/2 53/20 56/6
56/7 56/7 56/10 56/12 58/9 66/11 66/19
70/3 72/17 72/20 72/21 72/25 74/9
74/11 76/1 81/16 81/17 81/21 81/22
81/22 81/22 82/19 83/19 83/23 83/25
83/25 84/3 84/5 84/18 85/17 85/20
85/21 86/1 86/4 86/9 86/21 90/1 92/18
95/15 103/21 105/3 105/3 105/6 106/13
108/19 108/23 109/23 112/2 112/3
112/6 129/21 132/22 134/18 135/10
144/5 144/8 144/24 145/12 148/1
hadn't [1] 23/6
hand [2] 130/12 141/25
handed [1] 54/15
handful [1] 87/24
handled [1] 89/21
handwritten [1] 12/17
happen [6] 24/13 31/19 60/2 60/2
111/25 142/24
happened [3] 28/1 103/25 143/6
happening [1] 141/7
happens [2] 10/24 33/12
happy [3] 134/16 141/25 144/2
hard [6] 14/21 68/7 89/23 114/18 127/22
151/22
harder [1] 143/18
Harris [2] 4/22 130/8
has [51] 5/9 5/9 9/9 9/14 9/18 10/7
11/21 11/24 34/8 35/19 36/15 45/15
59/7 59/17 59/17 60/11 64/7 64/8 64/14
64/16 64/18 64/21 64/24 65/12 70/17
72/9 79/20 81/4 81/8 84/4 88/12 89/20
92/13 93/19 95/13 105/23 106/3 115/13
122/24 123/23 126/11 126/19 126/20
126/21 126/24 133/5 135/6 141/4 148/9
148/10 151/15
hasn't [2] 36/22 64/10
HAVA [2] 135/15 145/23
have [362]
haven't [11] 29/11 29/21 30/2 65/10
107/15 109/8 131/16 131/18 149/14
151/14 151/18
having [29] 7/3 13/14 13/19 14/8 14/9
14/14 14/19 14/20 15/9 15/11 15/20
15/23 16/12 27/15 38/10 39/20 49/19
52/22 60/11 60/19 66/24 77/4 94/16
98/10 102/11 117/3 120/3 123/7 136/7

he [41] 7/14 30/4 32/16 36/18 36/20
36/20 36/22 40/9 42/1 42/23 54/13
54/16 54/16 56/3 57/11 57/13 57/14
59/14 63/14 63/18 63/21 63/25 64/10
67/20 70/7 73/4 73/6 83/25 84/5 88/3
88/23 89/2 95/14 95/15 95/17 97/3
129/5 141/13 141/15 144/18 148/1
he's [7] 36/21 49/18 62/14 62/16 88/1
110/4 122/21
head [5] 51/19 51/21 57/10 101/3 101/6
health [5] 66/11 66/24 84/19 84/22
84/23
hear [7] 37/2 48/23 48/25 88/11 106/21
113/23 151/19
heard [14] 2/1 30/15 30/18 37/18 49/3
72/6 106/20 107/3 108/6 108/8 115/19
148/11 151/15 151/18
hearsay [1] 55/16
heart [1] 108/13
heavy [1] 67/1
HEBERT [1] 3/5
Helena [7] 99/1 99/3 101/16 110/13
110/21 111/11 113/16
help [22] 23/1 23/3 28/17 36/12 73/22
80/18 81/5 82/21 83/16 83/23 85/12
85/17 86/21 87/1 87/3 87/20 87/24 90/5
96/14 96/19 96/20 96/22
helped [2] 88/3 88/23
helpful [4] 41/25 120/12 152/2 153/20
helping [4] 80/19 86/4 90/4 133/9
helps [1] 97/7
her [37] 6/21 6/22 30/9 48/25 49/9 61/22
63/18 63/21 65/3 65/7 65/7 65/8 67/13
68/24 70/12 70/17 70/18 71/19 71/22
75/18 83/20 83/23 84/8 84/9 90/20
93/12 96/3 138/16 138/25 139/12
148/25 149/4 149/5 150/5 150/11 152/1
152/20
her 2009 [1] 139/12
here [25] 11/20 17/24 23/17 30/6 30/12
30/14 34/17 34/25 45/3 52/19 57/16
76/25 88/8 93/16 96/5 98/7 116/25
119/14 124/7 128/9 139/5 148/7 148/8
153/9 153/12
herein [6] 7/3 52/22 77/4 98/10 117/3
123/7
Heritage [1] 78/21
high [6] 61/13 79/23 85/17 99/23 126/14
134/7
higher [3] 16/16 125/3 125/6
Hilton [2] 101/3 101/6
him [14] 32/15 36/21 40/9 45/4 47/8
49/19 54/12 57/11 57/12 115/4 117/11
122/25 130/12 142/8
his [30] 7/22 7/24 8/21 19/3 36/18 42/3
45/7 49/22 49/22 84/5 84/5 84/6 84/7
84/8 88/3 88/20 88/25 89/2 94/23 95/9
95/17 95/17 96/2 96/5 117/11 122/21
122/22 140/24 141/23 144/20
Hispanic [2] 125/5 145/20
Hispanics [1] 147/6
hold [1] 65/4
home [10] 61/17 61/20 67/23 67/25
71/17 97/12 101/7 101/13 102/18
110/23
homes [3] 80/5 80/6 85/15
honest [3] 91/22 102/10 136/20
honestly [1] 66/20
honesty [1] 8/13
honor [27] 5/17 5/23 6/6 6/13 6/17 10/12
26/23 27/20 28/2 32/24 36/24 40/11
41/23 42/17 51/6 51/24 52/6 52/11
75/10 75/24 94/3 97/24 101/11 115/22
122/15 122/21 130/7

164
Honors [9] 51/25 52/10 52/14 63/17
90/14 98/14 112/19 116/15 117/5
HOOD [34] 4/4 6/12 6/12 7/2 7/7 8/20
10/16 10/20 14/17 16/19 17/17 17/19
19/8 21/2 22/13 23/11 29/8 30/25 32/13
34/10 35/1 35/7 35/12 40/2 40/21 41/4
44/19 76/2 132/24 133/2 133/4 134/11
134/23 139/22
hooking [1] 32/17
hope [1] 26/3
hopefully [4] 19/22 27/10 41/1 68/23
hospital [1] 78/4
hotel [2] 67/23 68/1
hour [1] 99/10
hours [16] 5/9 5/10 5/11 23/5 23/8 88/2
99/7 102/9 102/15 112/5 112/13 115/2
115/3 115/4 115/5 116/2
house [5] 66/12 95/10 95/11 95/13 96/8
housekeeping [1] 6/18
how [85] 13/22 14/2 24/3 29/14 29/24
47/16 49/8 50/10 53/9 53/15 56/25 57/3
57/7 57/19 57/25 58/5 58/8 60/12 60/14
62/9 62/17 63/12 65/9 65/24 66/18
68/11 68/18 68/20 69/18 74/13 77/14
78/1 78/8 79/18 85/23 89/21 96/24 99/3
99/6 99/8 99/11 100/11 101/4 102/5
102/7 102/9 104/18 105/14 106/6 106/9
106/11 106/21 107/8 108/10 108/21
109/1 110/9 110/11 110/13 110/18
110/23 111/3 111/8 125/8 126/16
126/20 127/16 127/22 129/12 130/2
131/3 131/6 131/12 133/23 134/7 137/7
137/14 141/5 145/14 146/25 150/15
150/24 151/1 152/20 153/7
however [5] 52/5 79/14 84/10 95/18
96/23
huh [10] 64/5 69/10 69/23 71/6 71/25
75/9 133/12 134/21 138/10 140/5
Huh-uh [1] 69/23
human [1] 82/3
humbling [1] 111/4
hundreds [1] 16/7
husband [7] 78/6 79/12 81/15 86/2
89/25 92/15 92/17
hypothesis [3] 43/8 43/18 43/21
hypothesize [1] 43/15
hypothetical [2] 15/21 28/14
hypotheticals [2] 128/15 149/4

I
I'd [11] 6/21 12/13 41/4 66/15 72/13
116/22 121/10 133/8 138/8 139/25
149/21
I'll [10] 6/22 47/15 55/18 68/23 92/23
92/24 93/16 94/9 139/24 142/6
I'm [91] 14/1 14/20 14/21 16/4 17/14
17/14 17/19 17/22 20/15 20/21 21/8
21/23 22/14 23/9 26/23 30/8 31/25
32/18 33/7 34/24 35/1 41/23 42/17
42/25 43/24 43/25 44/14 45/2 45/6 57/6
59/4 59/24 61/7 61/7 61/8 65/7 65/24
66/19 68/20 68/22 69/23 71/7 71/13
72/24 73/1 78/17 78/23 80/21 82/7 82/7
82/20 83/21 86/17 86/19 94/10 94/24
96/6 102/11 102/14 107/17 112/25
115/1 119/12 121/21 121/22 122/25
124/1 124/2 125/20 128/14 128/16
130/20 133/2 134/13 134/16 136/13
138/22 141/25 142/3 143/1 144/2
144/24 146/19 148/6 148/21 149/8
149/13 149/20 150/25 153/4 153/16
I've [17] 8/12 9/1 9/3 21/6 21/7 22/15
30/18 64/8 64/9 65/11 72/6 74/14 74/15
78/2 123/19 123/21 126/18

I
ID [214]
idea [6] 16/10 20/9 20/18 28/7 46/8 70/8
identification [31] 14/8 14/9 17/6 46/9
54/7 57/7 57/12 57/15 91/4 91/5 96/1
96/14 105/6 106/19 106/24 107/20
107/22 109/24 109/25 117/25 118/15
121/7 124/21 125/10 130/22 131/7
132/24 133/1 140/3 143/25 147/16
identifications [1] 54/2
identified [1] 95/9
identify [1] 95/7
identifying [3] 136/12 136/14 136/23
IDs [24] 12/21 13/1 15/5 15/8 16/6 23/14
23/19 23/24 27/15 27/24 28/11 28/12
51/3 51/3 51/5 51/5 51/14 53/21 82/22
83/16 87/1 88/3 105/10 136/25
ignorance [1] 110/1
III [2] 4/4 7/2
illiterate [1] 89/7
illogic [1] 148/12
impact [20] 10/5 20/1 20/3 24/19 31/9
31/13 31/19 32/3 32/5 33/11 33/17
33/21 34/1 34/1 34/6 35/4 35/13 35/16
35/18 48/20
impacted [4] 20/2 20/4 39/23 143/13
impeach [1] 70/16
impeaching [1] 70/16
impeachment [2] 44/10 44/12
impede [2] 20/9 20/19
impediment [32] 32/7 33/19 34/6 49/1
49/4 49/12 49/23 59/2 59/5 59/9 59/12
59/14 59/15 74/9 74/11 74/12 122/25
123/15 124/10 124/12 126/14 127/12
128/8 128/13 129/25 150/2 150/4 150/8
150/22 152/5 152/10 153/8
impediments [1] 151/4
implement [4] 29/14 131/4 149/7 149/11
implementation [22] 16/17 29/12 29/23
30/16 30/22 42/15 43/3 43/6 43/11
43/22 45/18 48/13 50/5 123/14 126/12
127/14 127/19 127/25 128/13 148/12
149/17 151/23
implemented [14] 10/7 11/5 11/24 26/3
28/6 29/6 34/8 35/17 35/19 45/15
125/18 142/21 148/24 152/21
implementing [2] 49/7 130/25
important [13] 21/11 22/3 32/8 34/3 60/3
65/8 81/20 117/24 136/21 146/16
146/19 153/1 153/15
imposition [2] 18/16 19/14
in 2001 [1] 82/6
in 2004 [2] 18/8 121/22
in 2006 [3] 142/23 142/23 144/23
in 2008 [4] 16/16 109/18 135/1 144/23
in-kind [1] 79/17
in-person [8] 48/1 117/20 118/5 118/23
119/2 119/8 121/3 143/5
inactive [4] 39/21 46/22 119/24 146/3
inartful [1] 9/13
Inc [1] 2/16
include [9] 40/3 40/14 40/17 45/21
46/21 80/24 111/13 129/17 129/19
included [7] 16/7 41/2 45/25 46/2 51/10
51/18 144/14
includes [1] 111/15
including [6] 9/7 9/17 34/5 44/21 144/19
148/10
inclusion [1] 46/12
inclusive [2] 22/9 46/10
income [7] 24/22 24/24 24/25 25/1 25/6
26/14 59/25
incomplete [1] 55/3

inconvenience [1] 65/7
inconvenient [1] 65/3
incorporated [4] 78/25 86/1 117/23
124/19
increase [5] 18/1 25/8 25/18 60/12
89/20
increased [4] 46/13 46/15 46/23 46/24
increasing [2] 18/15 19/13
indeed [4] 82/16 149/2 149/3 151/18
independent [1] 67/9
independently [1] 102/4
INDEX [1] 4/2
indicate [2] 37/22 152/1
indicated [11] 10/6 25/12 36/22 55/20
56/14 58/22 74/1 79/8 82/8 82/25
152/20
indicater [3] 38/12 38/25 144/14
indicating [2] 57/14 59/1
indigent [4] 78/14 83/24 85/13 90/5
individual [8] 11/20 38/9 82/21 84/2
110/5 118/20 135/22 145/11
individual's [1] 24/25
individuals [24] 24/25 36/12 37/7 40/19
40/24 80/11 81/18 81/21 82/12 82/25
83/9 83/11 84/10 84/15 85/9 85/12
85/19 85/21 86/11 88/14 88/23 137/4
137/10 152/23
Industrial [1] 100/4
inference [2] 18/19 19/17
influence [3] 27/25 28/4 29/4
influenced [1] 27/22
information [18] 45/22 72/16 107/7
123/13 124/8 126/16 126/18 126/20
127/16 128/11 136/12 136/15 136/23
137/3 145/12 145/13 147/10 149/5
informed [1] 95/13
initial [1] 22/19
initially [1] 84/17
initiated [1] 27/5
inmates [4] 80/17 80/19 81/3 81/4
innumerable [1] 87/7
inside [4] 80/18 80/23 81/2 81/5
insignificant [1] 147/2
instance [3] 9/19 16/11 37/10
instances [2] 88/16 152/4
instantaneously [1] 85/5
instead [3] 42/1 60/19 84/7
intend [2] 68/15 148/17
Interdenominational [1] 79/1
interested [3] 69/1 150/25 153/5
interferes [1] 88/8
Internet [12] 69/18 102/20 137/18
137/22 138/11 138/14 140/21 141/2
141/3 141/6 143/14 143/16
interpret [3] 150/15 150/19 151/16
interpretation [4] 20/22 149/7 151/23
152/1
interpretations [3] 149/10 149/17
149/23
interpreted [1] 148/25
interpreting [2] 150/15 150/17
interrupt [2] 80/21 88/12
intervenors [10] 2/10 4/8 5/4 5/7 5/8
5/10 6/3 52/7 52/16 76/22
intervenors' [1] 52/12
interview [1] 136/2
introduce [3] 76/1 116/16 130/8
introducing [2] 52/11 80/2
involved [5] 66/22 107/9 107/15 108/6
108/13
involvement [4] 42/11 42/14 43/2 43/7
involves [2] 101/21 101/24
is [266]
Island [5] 99/1 99/4 110/14 110/21

165
113/16
isn't [8] 14/19 23/16 25/7 113/10 115/9
119/11 120/17 120/23
issue [15] 7/19 27/21 50/4 50/7 50/8
50/11 50/17 53/18 55/5 104/16 110/4
142/16 143/1 143/12 151/14
issued [13] 13/9 14/3 14/4 14/13 15/5
57/7 57/20 59/2 81/17 84/25 103/19
104/5 104/19
issues [7] 50/3 50/10 50/14 66/11 66/25
141/5 150/13
it [251]
it's [54] 7/17 8/12 13/6 14/2 14/2 17/11
24/25 28/9 28/10 28/13 36/7 39/1 40/17
41/1 44/7 44/9 44/11 48/20 50/23 51/9
51/16 60/8 60/9 65/3 69/3 72/14 73/9
85/1 86/18 91/22 91/23 102/19 104/15
111/4 112/12 117/18 126/3 127/22
133/7 136/21 138/13 140/20 141/18
142/14 142/22 143/18 146/13 148/3
148/5 149/9 150/25 151/21 152/19
153/14
item [1] 148/4
items [2] 102/1 102/1
its [3] 31/2 36/8 149/17
itself [2] 134/5 146/18

J
JA001767 [1] 119/19
jail [7] 80/13 80/15 80/16 80/18 80/19
81/2 81/5
jails [1] 80/23
James [1] 83/24
Janet [1] 129/15
Jeff [1] 130/8
Jersey [5] 99/17 100/20 103/24 104/6
105/5
job [3] 65/4 65/7 112/11
jobs [1] 80/20
JOHN [2] 1/12 114/7
Jones [1] 54/21
Joseph [3] 95/11 129/8 129/19
journal [2] 132/15 133/6
JUDGE [10] 1/11 1/11 1/12 19/6 87/25
87/25 88/20 89/1 148/1 151/8
judge's [1] 43/24
judged [1] 136/6
judges [2] 149/15 150/14
judgment [1] 24/6
judicial [1] 5/13
July [1] 61/11
July 6 [1] 61/11
June [7] 71/3 124/18 125/11 126/13
133/15 139/11 140/7
June 18th [4] 124/18 126/13 133/15
140/7
June 7, 2012 [1] 71/3
Junior [1] 84/2
junkyard [1] 101/16
jurisdictions [1] 133/23
just [104] 5/12 5/15 6/11 6/20 8/14 9/2
9/4 12/15 14/2 14/20 15/10 16/8 17/8
17/14 17/21 17/22 19/1 21/20 22/13
23/10 23/11 24/21 26/22 26/23 29/10
29/18 32/20 33/13 35/12 40/16 40/22
42/5 46/8 49/17 49/19 50/20 51/1 59/24
60/1 60/8 62/3 62/22 65/2 65/2 65/10
66/14 66/21 67/14 68/6 68/6 68/19
68/22 73/1 74/23 75/4 75/25 82/5 82/24
84/13 86/17 86/18 86/24 90/2 90/4
90/23 92/16 93/3 93/16 94/16 96/8
96/11 98/4 102/2 102/17 103/9 108/4
109/9 110/1 110/4 113/6 113/8 118/9
119/17 121/10 122/3 125/21 129/11

J
just... [17] 130/17 134/6 134/22 139/13
140/13 142/1 142/10 144/3 145/7
145/11 148/9 148/13 148/20 151/3
151/25 152/3 152/22
Justice [10] 2/5 3/9 52/4 52/8 87/7 87/8
87/9 98/1 116/17 150/19

K
KARL [1] 1/24
KAVANAUGH [1] 1/11
keep [3] 7/9 80/20 136/2
Kennedy [1] 150/19
KEVIN [3] 4/21 122/20 123/6
key [3] 124/14 128/7 128/11
kicked [1] 86/2
Kids [1] 79/24
Kimball [4] 133/9 133/16 134/1 134/11
kind [12] 13/12 22/13 68/23 69/2 79/17
89/2 105/1 107/25 111/4 111/4 127/23
136/12
kindly [1] 97/13
kinds [2] 27/22 153/3
knew [5] 15/12 46/9 81/14 87/14 129/5
know [97] 9/21 9/22 10/2 11/19 12/20
12/23 12/25 13/3 15/17 16/6 16/9 16/20
17/21 21/23 23/6 24/3 25/23 26/24
27/13 28/3 28/7 28/13 28/14 30/23
36/20 38/14 39/14 42/20 46/12 46/20
46/22 47/16 49/5 59/6 59/8 59/13 60/2
60/21 65/7 65/11 65/23 66/1 66/3 66/20
66/21 67/3 67/3 67/7 69/2 69/4 69/5
69/16 69/18 70/7 71/13 71/19 71/20
71/21 71/24 71/24 71/24 72/12 73/1
73/2 74/1 74/13 78/20 81/7 81/8 92/14
93/17 94/11 99/25 102/1 107/1 109/3
110/1 110/6 113/12 113/14 118/4
118/18 125/12 135/23 136/25 137/2
137/4 137/14 137/16 139/2 139/2
145/15 149/12 149/20 152/7 152/8
153/13
knowledge [8] 27/18 63/4 85/9 88/5
88/14 88/24 140/19 143/3
knows [1] 71/14
KOLLAR [1] 1/11
KOLLAR-KOTELLY [1] 1/11
KOTELLY [1] 1/11

L
lack [7] 22/3 23/19 26/14 44/23 47/4
47/10 127/19
lacked [2] 43/9 143/25
laid [1] 38/11
large [2] 133/19 138/11
largely [1] 127/21
last [15] 60/18 65/12 65/14 72/15 92/1
97/6 103/21 104/20 110/16 122/23
123/24 124/1 126/18 127/1 138/25
lastly [1] 115/13
lately [1] 65/10
later [6] 71/17 91/16 94/1 95/12 107/22
153/15
latter [1] 75/7
Laurel [5] 64/21 65/19 65/22 66/1 66/3
law [102] 10/7 11/4 11/23 13/2 14/14
16/17 17/3 18/17 18/20 19/15 19/18
20/9 20/18 21/11 26/3 26/4 28/6 29/14
29/16 29/17 29/21 34/8 37/22 41/12
41/14 42/16 43/4 43/5 43/8 43/16 47/18
47/22 49/7 53/17 53/21 58/11 58/23
58/25 59/4 59/4 62/6 62/17 63/2 63/14
63/23 64/7 64/8 67/19 67/20 69/25 72/2
81/8 81/10 82/6 82/10 82/13 82/16 83/1

83/12 89/20 89/20 91/6 91/13 91/24
93/20 93/23 94/10 95/25 106/18 106/20
115/14 115/16 125/20 126/6 127/3
127/6 129/5 130/19 130/21 131/8 131/9
131/13 131/14 131/23 132/24 133/2
135/6 142/21 144/14 146/4 149/7 149/8
149/11 149/12 150/2 150/2 150/13
150/15 150/20 150/23 151/4 151/16
laws [16] 9/9 11/17 12/7 19/25 50/6
128/10 134/19 141/11 142/12 142/23
142/24 143/13 144/17 144/22 144/24
150/15
Lawyers' [1] 3/12
lay [1] 36/23
leading [11] 40/5 40/8 41/24 42/2 42/18
42/21 45/1 47/14 48/2 48/4 127/19
leads [2] 126/10 127/8
learn [1] 43/13
lease [1] 67/24
least [12] 5/21 11/4 12/23 33/5 43/15
56/24 80/6 88/3 129/15 142/25 149/16
153/1
leave [1] 66/12
Lee [1] 80/13
left [7] 5/9 5/10 5/11 16/19 19/2 35/3
71/17
legal [7] 3/5 50/8 56/18 87/20 88/25
151/2 153/9
legislators [1] 81/12
legitimate [5] 146/21 147/1 147/4 147/5
147/13
less [8] 25/7 25/25 26/25 40/22 85/17
141/15 147/15 147/19
let [23] 13/25 14/23 24/11 29/18 30/25
32/13 32/15 40/16 42/5 57/6 65/2 73/11
73/18 76/17 78/20 82/24 93/12 93/17
94/15 94/19 103/9 142/8 151/13
let's [5] 6/16 74/1 79/3 129/14 134/18
letter [1] 92/19
letters [3] 87/7 87/18 93/1
letting [1] 152/5
level [8] 11/20 25/1 25/1 85/18 89/11
141/9 141/9 144/14
levels [3] 121/20 122/4 122/5
Liberties [3] 2/16 2/20 3/1
license [34] 13/6 13/9 13/23 14/7 14/11
14/12 14/18 15/23 15/25 16/12 28/16
38/8 38/10 38/13 38/19 38/22 38/23
39/3 39/3 39/19 54/4 54/24 55/2 57/18
57/21 74/6 83/22 103/17 103/21 103/25
104/6 104/12 105/2 105/12
licenses [7] 38/3 39/18 40/4 40/15 40/24
63/3 85/2
life [5] 77/22 78/21 84/5 89/15 89/24
light [3] 25/18 26/9 124/7
like [43] 5/17 6/21 6/21 9/3 10/22 12/13
25/25 32/6 33/23 41/4 56/12 60/20
64/10 65/5 67/3 67/4 72/14 72/16 73/20
83/8 94/15 97/25 103/3 103/14 107/21
108/12 108/14 108/16 109/21 109/23
110/3 110/4 112/10 116/22 121/10
130/7 133/8 138/8 139/25 147/10
147/11 148/20 149/21
likelihood [1] 126/14
likely [14] 24/13 25/8 37/9 47/4 47/10
117/19 119/1 119/8 119/9 120/16 121/1
121/3 127/8 147/10
likewise [1] 122/4
limited [3] 21/13 21/15 86/18
limits [2] 13/17 13/18
line [12] 17/20 19/3 19/8 20/16 21/24
34/14 36/13 38/4 47/6 71/7 93/9 93/11
lines [2] 12/1 93/13
link [1] 136/12

166
linked [1] 136/15
LISA [5] 3/8 3/16 97/25 154/3 154/7
list [20] 14/5 15/12 15/13 15/23 22/15
37/18 37/19 37/19 37/24 51/11 53/20
76/12 135/23 135/24 136/4 136/6
136/16 137/2 146/8 152/25
listed [1] 151/3
listen [2] 94/22 106/23
listening [1] 106/22
lists [2] 37/17 47/20
literate [1] 89/8
literature [1] 136/19
litigants [2] 83/17 84/10
litigated [1] 150/25
litigation [3] 49/15 50/2 83/12
little [24] 8/2 22/9 23/12 29/19 49/6
55/11 55/13 62/14 66/14 66/14 69/3
79/3 79/15 84/13 96/5 101/9 101/20
101/23 113/22 120/2 120/3 120/8
120/10 126/6
live [28] 53/7 54/14 61/25 62/3 62/4
62/5 62/6 62/13 62/17 63/2 76/6 77/12
77/13 79/23 98/19 98/20 98/25 99/9
100/23 101/1 101/4 101/7 101/13
102/16 102/21 105/17 106/7 110/10
lived [10] 53/9 77/14 77/15 77/19 77/21
81/21 85/13 85/14 86/10 89/14
livelihood [1] 65/8
lives [5] 61/23 62/14 62/15 80/9 101/2
living [6] 67/18 67/19 67/24 77/24 79/7
79/7
LLP [1] 2/13
LNNOIE [1] 84/9
local [9] 54/14 83/15 93/20 101/16
118/7 118/21 126/23 127/3 129/13
located [1] 106/10
location [4] 67/12 71/10 119/3 137/12
locations [2] 145/16 145/21
lodge [1] 55/16
logical [2] 43/14 127/21
long [7] 53/9 53/15 77/14 78/1 99/6 99/8
100/11
longer [1] 7/9
Lonna [1] 138/9
look [18] 18/7 23/15 25/24 26/15 27/19
31/13 34/24 47/8 59/13 67/7 92/24
119/12 141/8 141/13 145/18 146/1
146/5 146/11
looked [21] 8/12 14/10 14/11 16/5 29/11
29/13 29/14 29/15 29/16 29/17 29/21
29/21 31/8 31/23 36/22 46/16 54/16
120/14 129/2 131/11 133/18
looking [12] 11/23 20/6 82/23 92/22
100/23 101/25 125/9 127/2 132/5 137/7
149/20 152/17
looks [2] 25/25 60/20
Los [1] 53/12
lose [1] 60/21
lost [4] 104/1 104/5 104/11 104/12
lot [7] 65/5 65/6 66/11 78/12 85/16
150/14 153/13
Louisiana [3] 68/2 68/3 68/6
low [4] 18/11 21/19 134/7 143/15
lower [9] 25/6 25/6 26/13 26/13 26/14
36/12 37/7 37/11 97/8
lowest [1] 80/4
lunch [2] 148/1 153/22
LUNCHEON [1] 153/23

M
M.V [1] 4/4
ma'am [22] 52/18 77/23 78/17 78/21
79/11 81/1 81/9 82/11 83/2 83/13 84/16
85/12 85/25 86/23 87/18 88/18 89/1

M
ma'am... [5] 89/5 89/13 89/18 92/20
92/24
made [16] 11/11 33/4 39/10 54/10 60/11
70/5 70/6 82/7 87/11 95/20 139/3 139/6
144/9 150/4 150/22 151/6
magnitude [1] 36/8
mail [11] 21/15 21/20 85/8 85/10 120/21
135/10 135/14 135/15 135/18 138/14
145/23
mail-in [1] 120/21
mailer [1] 37/21
mails [2] 87/8 87/20
mainly [1] 95/24
maintain [1] 101/18
major [1] 85/5
majority [1] 122/22
make [26] 13/3 17/5 24/6 33/4 38/13
39/6 45/17 59/15 60/14 60/16 69/24
71/16 113/8 113/22 113/23 115/12
121/10 136/21 138/2 141/6 144/10
147/1 148/9 148/15 148/16 150/22
make-up [1] 144/10
makes [1] 89/22
making [7] 10/21 31/19 37/16 65/11
121/18 122/21 152/14
man [2] 83/24 109/21
manager [3] 57/10 59/13 96/2
managers [2] 96/1 96/24
manner [4] 126/15 131/20 132/3 134/20
many [21] 11/22 21/21 24/3 63/12 80/20
81/16 81/21 82/21 87/1 88/2 92/3 92/6
102/9 102/10 104/18 129/12 135/11
142/16 143/6 150/18 150/24
March [4] 81/11 82/15 82/15 99/19
March 2001 [1] 81/11
March 2011 [1] 82/15
March 3rd [1] 99/19
March 9th [1] 82/15
Marci [1] 123/21
MARIE [1] 2/3
Marilyn [2] 128/19 129/16
mark [3] 3/12 6/21 6/23
marriage [2] 83/22 85/2
Mart [2] 84/4 84/4
MARTIN [8] 4/18 116/20 116/23 117/2
117/16 119/15 119/21 120/14
Martin's [1] 119/18
MARZIANI [5] 3/8 4/19 4/22 4/23 116/16
Massachusetts [3] 125/20 126/5 135/6
master [1] 136/16
MasterCard [1] 85/6
match [7] 14/5 15/5 15/12 15/13 15/23
57/12 143/16
matched [2] 14/23 38/8
matching [4] 7/20 14/18 38/6 50/20
material [1] 152/15
materials [5] 29/17 122/24 123/1 124/4
152/18
matter [12] 44/17 45/16 82/14 83/13
83/18 84/6 86/23 88/1 89/22 107/4
108/3 154/5
matters [1] 108/11
may [32] 5/18 10/12 13/11 14/4 14/13
14/22 15/7 16/6 16/10 16/12 24/8 29/2
52/13 60/2 63/18 75/11 91/15 94/19
96/1 96/2 116/15 117/10 126/11 130/12
141/11 143/5 146/20 148/4 149/15
150/22 151/11 153/10
maybe [4] 9/13 15/17 72/24 96/12
McCOMBS [1] 2/11
McGINLEY [3] 1/15 4/13 90/14
me [98] 7/11 8/24 9/13 9/16 13/17 13/25

14/23 17/11 17/15 17/19 20/11 24/11
25/14 26/5 29/18 30/25 32/21 40/16
42/5 42/17 54/10 54/13 55/1 55/11
55/12 56/1 56/3 56/4 56/10 57/6 57/11
57/13 58/9 59/24 60/16 60/19 60/20
63/25 64/3 64/9 64/9 64/25 66/19 67/11
67/14 68/13 68/22 70/15 71/19 72/15
73/11 74/14 76/17 82/24 83/13 83/25
84/18 84/23 87/10 89/22 91/7 91/16
93/3 93/17 94/15 94/19 95/13 100/18
101/22 102/8 103/6 103/9 104/11
104/14 105/19 106/15 106/15 107/5
108/22 109/12 111/6 111/7 112/10
114/18 114/22 118/25 126/10 127/1
127/22 132/4 133/7 134/14 134/16
138/22 139/24 144/13 151/11 151/13
mean [34] 9/13 9/22 15/10 20/5 21/6
23/3 23/15 24/24 29/14 35/20 35/24
36/6 38/11 41/11 42/1 43/22 51/4 51/14
56/9 62/21 66/10 66/15 66/20 67/2 69/1
70/3 71/13 72/8 73/1 74/15 77/21
126/25 132/20 142/14
meaning [2] 128/8 129/24
means [3] 58/6 91/3 91/5
mechanic [1] 100/10
mechanical [1] 3/24
mechanism [1] 126/22
Medicaid [3] 78/13 81/23 81/24
medical [8] 58/16 78/6 78/22 78/24
83/19 92/21 92/22 150/7
Medicare [3] 78/13 81/22 81/24
medications [1] 67/1
medicine [4] 77/25 78/2 78/5 81/14
member [5] 78/19 78/21 78/22 78/23
78/25
members [2] 78/12 129/23
memorized [2] 23/18 51/13
memory [2] 144/13 146/7
mention [1] 125/18
mentioned [6] 33/14 85/25 92/15 110/25
134/25 137/6
merely [1] 36/7
messages [1] 127/7
met [1] 135/9
method [3] 37/23 120/23 149/19
methodological [3] 8/22 132/19 132/20
methodologically [3] 9/9 9/19 9/23
methodology [4] 7/20 7/24 48/18 48/21
methods [1] 143/15
Mexico [4] 138/20 138/23 139/7 139/10
MEZA [1] 2/3
MICHAEL [2] 1/15 2/10
microphone [1] 113/4
middle [1] 54/23
midwives [1] 81/18
might [16] 35/25 37/9 43/16 44/20 46/6
59/20 59/20 60/2 86/15 93/4 95/19
109/11 109/25 138/5 143/12 143/17
Mike [1] 90/14
mile [1] 102/8
miles [8] 84/18 101/5 101/5 105/16
110/10 110/24 113/18 113/19
military [9] 45/22 46/5 54/4 54/8 65/1
65/1 67/20 100/7 100/13
MILLER [1] 2/4
MIMI [2] 3/8 116/16
mind [2] 17/24 32/13
mine [1] 106/15
minorities [5] 11/18 12/8 28/11 33/17
47/10
minority [7] 10/4 12/21 13/1 32/5 33/21
43/9 47/3
minute [7] 61/19 105/19 130/18 134/19
134/25 137/5 137/6

167
minutes [8] 5/8 5/9 5/10 5/11 99/10
112/4 112/5 113/17
mission [4] 79/4 79/19 81/4 96/13
misspelled [1] 84/6
mistake [1] 82/7
mitigate [2] 28/17 127/20
mitigating [6] 26/3 32/6 33/22 33/25
34/5 36/11
mitigation [1] 33/18
mixed [1] 127/7
mobile [3] 36/16 37/5 37/7
model [2] 144/12 144/15
moment [2] 75/25 148/22
money [5] 59/19 59/25 59/25 79/9 86/5
month [1] 65/15
monthly [2] 69/7 69/8
months [8] 64/24 79/25 80/15 90/2
90/15 100/12 104/3 150/24
more [38] 21/6 22/9 29/4 40/22 41/1
41/2 42/24 47/3 47/10 54/1 60/14 60/16
63/10 67/25 84/13 86/4 96/11 96/12
101/20 101/23 107/6 111/16 117/19
119/1 119/8 119/9 120/16 121/1 121/3
129/21 140/17 144/3 144/23 147/15
150/25 151/13 151/25 152/24
morning [30] 5/2 6/12 6/13 7/7 7/8 10/16
10/17 36/10 52/14 61/5 61/6 75/18
87/12 90/17 90/18 98/14 98/14 98/15
112/19 112/23 112/24 113/6 116/22
117/16 117/17 123/11 123/12 130/11
130/11 139/15
most [16] 9/1 32/1 37/9 59/19 59/25
74/13 74/14 78/9 78/13 89/8 90/4
110/13 120/22 136/9 143/13 143/17
motion [1] 5/14
motivated [1] 108/17
Motor [4] 13/10 82/17 104/9 112/2
mouth [1] 92/7
move [12] 29/18 35/1 67/25 74/2 100/17
100/19 113/3 120/2 120/2 120/4 120/9
120/9
moved [1] 100/22
movers [1] 50/10
moving [3] 75/3 75/4 75/6
Mr [42] 4/5 4/5 4/6 4/10 4/13 4/16 4/19
4/22 7/8 10/10 12/14 19/2 23/19 24/15
24/18 31/7 31/23 32/21 35/12 47/2
47/15 49/17 61/2 97/25 98/14 98/18
98/23 99/16 100/13 101/15 102/25
106/18 109/7 110/6 112/23 115/25
116/13 128/16 128/18 128/22 129/8
129/15
Mr. [10] 32/13 83/24 84/2 84/3 95/10
95/11 95/13 96/8 117/17 130/8
Mr. Bartolomucci [1] 32/13
Mr. Field [1] 117/17
Mr. House [3] 95/10 95/13 96/8
Mr. James [1] 83/24
Mr. Jeff [1] 130/8
Mr. Joseph [1] 95/11
Mr. Junior [1] 84/2
Mr. Raymond [1] 84/3
Mrs. [1] 84/8
Mrs. Naomi [1] 84/8
Ms [37] 4/10 4/11 4/13 4/16 4/17 4/19
4/22 4/23 6/19 30/2 30/12 37/2 48/23
49/19 61/5 64/1 70/21 97/25 116/16
127/2 127/5 128/10 128/10 128/16
128/22 128/22 128/25 129/14 148/25
149/3 149/10 149/23 151/16 151/19
151/25 152/20 153/1
much [22] 6/17 6/25 7/9 10/8 66/12
66/12 72/16 83/20 86/15 97/18 98/3
107/15 111/8 128/3 131/10 131/16

M
much... [6] 133/23 137/14 147/19 148/8
151/15 153/19
multifaceted [1] 79/20
multimode [1] 138/13
multivariate [2] 144/12 144/20
municipal [2] 135/20 145/25
municipalities [1] 133/20
municipality [1] 133/19
must [4] 8/11 85/5 85/6 85/7
my [131] 7/9 9/11 9/14 13/25 14/17
14/22 17/11 17/12 17/21 22/8 23/16
25/24 26/1 29/15 31/12 34/15 34/16
39/22 41/1 41/17 41/17 41/18 41/19
51/15 54/17 54/18 55/3 55/10 57/11
57/17 57/17 58/1 58/9 58/15 59/13
59/25 60/9 62/6 63/4 64/8 64/9 66/19
67/3 67/10 67/19 67/19 68/13 68/20
68/21 68/25 69/6 71/18 72/8 72/13
72/25 73/3 74/12 77/9 78/5 78/9 78/17
79/12 81/11 81/13 81/15 82/14 82/18
82/18 83/2 83/18 86/2 86/6 86/6 87/12
89/24 89/24 92/12 92/15 92/17 95/2
95/19 96/22 97/6 99/25 102/3 102/4
104/12 104/12 104/12 105/3 105/3
105/3 105/4 105/6 105/23 105/23 106/3
108/9 108/13 110/1 112/9 112/25 115/3
115/4 118/6 118/11 118/20 118/24
119/5 119/12 120/14 120/15 121/9
124/5 125/11 126/24 126/24 127/25
128/2 133/15 137/20 138/13 139/11
140/7 141/1 142/10 143/3 144/13
147/18 151/10 151/11
myself [10] 23/3 82/20 82/21 86/25
87/11 90/4 92/16 107/18 149/14 153/2

N
NAACP [1] 78/22
name [21] 53/3 54/18 54/20 54/22 54/23
55/3 55/4 55/5 56/1 56/3 56/5 57/13
77/8 77/9 84/6 84/9 91/7 95/9 98/16
112/25 138/24
NANCY [3] 2/15 52/11 52/14
Naomi [2] 84/8 84/9
narrowed [1] 25/23
Nation's [1] 3/2
national [7] 78/23 85/2 133/16 140/8
140/12 141/9 143/17
nationally [1] 141/7
navigate [2] 56/22 88/15
NE [1] 3/6
near [3] 66/1 66/3 139/15
nearest [1] 110/23
nearly [3] 133/20 144/5 146/6
necessarily [4] 11/1 33/6 135/12 142/14
necessary [1] 69/3
necessity [1] 107/2
need [32] 15/4 19/1 25/9 31/21 33/18
33/24 37/22 55/10 61/20 63/24 63/24
65/9 85/1 91/11 91/25 98/21 98/24
103/2 103/12 103/13 104/11 104/16
104/16 108/11 113/3 113/23 113/23
118/6 118/20 119/12 142/7 147/8
needed [18] 22/18 22/19 22/21 46/10
54/16 67/24 83/21 83/22 83/22 85/22
87/21 107/20 107/22 107/25 115/8
115/10 115/11 136/3
needing [1] 106/24
needs [4] 31/21 33/4 84/25 95/21
negative [2] 51/19 51/21
neglect [1] 56/9
neglected [1] 6/19
Neutral [1] 134/20

never [18] 56/11 63/25 64/8 70/3 81/16
81/22 83/19 83/24 83/25 84/3 84/5
89/23 90/1 96/22 96/22 108/12 109/13
127/6
nevertheless [1] 116/4
new [34] 2/14 3/10 3/13 64/23 64/24
67/18 67/23 68/1 68/4 68/5 75/3 86/11
99/17 100/20 103/24 104/6 105/5
106/18 122/24 123/1 123/13 124/7
126/16 126/18 126/20 127/16 130/17
138/20 138/23 139/7 139/10 149/16
149/17 153/17
Newark [2] 100/4 105/5
newspaper [1] 83/15
next [8] 31/16 40/19 75/25 97/23 116/17
116/18 122/20 148/23
nice [1] 75/13
nine [1] 103/22
no [153] 1/3 10/1 10/9 13/3 13/5 13/6
13/14 13/20 13/21 13/21 14/5 14/19
14/22 14/22 14/24 15/9 15/10 15/12
15/13 15/18 15/18 15/23 16/2 16/5 16/6
16/10 23/1 23/3 23/3 24/4 24/4 28/5
30/1 30/3 30/11 32/9 35/19 36/17 38/1
38/21 38/24 40/1 40/1 42/13 43/5 44/9
45/20 46/1 46/8 46/20 47/24 48/7 48/11
48/16 50/17 50/24 54/23 55/3 56/18
56/24 57/24 58/21 60/16 60/16 60/23
60/25 62/6 63/25 64/8 67/4 67/10 67/14
67/17 68/4 68/25 69/23 69/23 69/23
70/8 70/8 70/25 73/7 73/15 74/18 74/21
76/10 77/20 79/11 79/11 84/24 85/12
86/4 88/10 88/11 88/18 89/1 89/13 90/7
91/13 92/9 95/22 96/23 97/15 100/16
101/8 101/14 102/19 102/22 102/24
103/1 103/11 103/16 103/18 103/20
105/13 105/23 107/13 108/2 109/8
109/23 111/18 112/16 113/18 115/1
115/20 117/6 121/16 121/18 122/11
124/11 125/22 125/24 131/21 132/9
132/21 134/3 134/4 135/8 136/22
137/21 139/9 140/16 140/17 140/20
141/11 141/24 141/24 142/1 142/1
142/1 144/9 145/12 150/8
no-DMV [1] 13/6
no-ID [1] 13/5
no-match [4] 14/5 15/12 15/13 15/23
non [5] 40/8 103/19 126/15 143/21
147/13
non-driver [1] 103/19
non-leading [1] 40/8
non-legitimate [1] 147/13
non-uniformed [1] 126/15
non-voters [1] 143/21
noncompliance [1] 137/13
none [4] 85/21 87/14 105/6 110/22
nonetheless [1] 140/24
nonprofit [2] 79/6 79/8
nonuniformity [2] 127/8 127/9
normally [4] 102/11 102/14 111/6 111/9
North [2] 99/17 100/20
northeast [3] 62/4 66/14 66/15
not [174]
notaries [5] 59/19 74/13 74/14 152/10
152/25
notarized [3] 59/17 59/17 59/22
notary [2] 59/19 153/4
note [1] 19/1
noted [4] 15/24 33/5 43/14 125/11
nothing [12] 66/15 66/24 75/10 97/17
115/21 122/14 122/17 128/1 128/3
130/6 134/3 145/6
notice [2] 5/13 88/10
notified [1] 107/5

168
noting [1] 21/18
notwithstanding [2] 16/16 26/13
November [2] 53/10 148/18
November 2012 [1] 148/18
now [64] 6/21 7/17 8/2 9/24 11/20 12/4
12/13 15/18 16/14 19/22 21/1 21/23
23/17 25/8 30/23 30/25 31/16 33/16
38/6 44/24 45/21 46/16 47/12 53/17
54/24 56/14 56/19 56/25 57/22 58/10
58/22 59/7 60/3 60/10 60/17 64/25 65/5
65/19 66/13 66/18 72/20 76/18 78/15
79/18 81/7 82/8 82/25 86/10 88/14 89/4
89/14 89/19 91/15 94/19 109/3 124/12
125/18 134/18 135/22 139/5 142/21
142/24 148/19 153/17
nowhere [2] 7/17 7/22
number [32] 8/22 16/9 21/19 24/8 26/6
26/11 26/20 27/10 36/2 38/16 44/22
50/4 60/19 69/16 72/10 72/12 87/6 92/1
105/4 113/12 119/19 125/4 125/7
133/19 133/20 138/25 141/18 141/18
144/1 144/15 147/6 150/21
numbers [14] 17/8 18/21 19/19 20/7
23/12 27/8 31/22 32/2 33/16 33/20
81/25 82/1 120/19 137/16
numerous [1] 104/9
NW [6] 1/17 2/6 2/17 3/2 3/13 3/18
NY [2] 2/14 3/10

O
Obama [2] 109/20 110/3
object [7] 32/14 40/5 41/23 42/18 45/1
48/2 63/15
objection [10] 19/2 36/17 47/14 55/16
62/18 66/5 73/24 76/9 76/10 94/3
obstacles [1] 24/1
obtain [15] 25/10 54/6 54/8 91/11 91/19
93/21 94/14 95/3 95/8 95/14 96/9 96/14
96/20 98/4 105/2
obtaining [1] 74/4
obtains [1] 118/18
obviously [4] 88/7 142/22 149/1 150/6
occasion [2] 114/11 114/20
occasionally [1] 106/16
occasions [2] 104/22 106/12
occurred [3] 42/12 75/6 75/7
October [3] 100/16 148/14 148/16
October 19 [1] 100/16
October 1st [2] 148/14 148/16
of 2008 [2] 53/10 75/7
of 2009 [1] 53/16
off [11] 6/19 65/2 71/18 83/6 86/3 88/10
88/12 90/6 111/20 112/12 116/7
offer [4] 25/16 46/25 49/1 52/2
offered [6] 12/5 23/14 23/25 44/10
114/24 149/18
offering [8] 31/17 31/22 31/24 33/10
48/10 121/16 121/19 121/21
office [37] 54/14 55/8 64/18 64/21 65/9
66/4 66/10 68/4 71/17 72/22 73/2 73/16
73/23 87/12 89/25 91/25 93/2 93/21
95/18 102/17 104/24 106/7 106/9
108/20 109/21 112/3 112/10 115/9
115/11 115/15 118/7 118/21 118/22
119/11 120/17 121/2 121/6
officer [2] 112/6 114/7
offices [4] 106/11 118/10 120/22 121/4
official [2] 3/17 131/5
officials [12] 123/23 124/15 126/23
127/3 128/7 128/12 129/1 129/2 129/4
129/13 129/17 129/17
oh [10] 70/3 72/24 73/6 88/18 89/22
91/5 94/24 96/6 99/7 135/17
okay [52] 5/19 5/25 7/13 7/22 12/3 12/19

169
123/13
O
patient [1] 88/2
okay... [46] 14/2 15/21 16/5 17/16 17/18
patients [3] 78/8 78/9 92/18
Patricia [1] 129/19
20/12 20/14 23/10 25/16 26/8 29/20
patriotic [1] 60/8
30/24 34/13 38/2 41/6 44/14 46/21
pay [12] 56/7 56/13 56/17 59/19 83/4
47/21 51/18 55/25 58/19 61/9 66/9 71/9
72/24 76/3 77/1 79/18 82/24 86/17
83/5 85/20 86/7 111/8 111/11 111/13
87/15 88/11 91/18 95/6 101/22 106/2
112/14
paying [2] 80/12 111/6
106/4 113/2 113/19 115/13 128/5
Peachtree [1] 2/17
131/22 137/5 144/3 144/25 147/14
old [14] 60/24 62/9 62/15 62/17 72/14
peer [4] 132/11 132/15 132/17 133/6
Pennsylvania [1] 2/6
72/17 72/21 72/25 73/3 79/25 79/25
people [89] 13/14 13/19 13/22 14/3
90/2 107/17 109/10
older [2] 58/16 102/2
14/10 14/12 14/14 14/17 14/20 14/24
omission [1] 55/4
15/7 15/11 15/11 16/6 16/7 16/10 18/7
on 2006 [1] 138/19
21/10 22/17 23/23 24/8 25/9 26/15 28/8
once [4] 26/3 26/25 27/5 108/8
28/10 60/21 67/24 78/14 79/7 79/14
one [99] 6/18 6/19 11/11 11/14 11/15
80/11 82/9 82/22 83/13 83/16 84/10
12/23 16/6 17/11 17/12 19/24 21/8 21/8
84/24 85/13 85/16 85/20 86/4 86/8 86/9
26/2 27/12 27/15 28/5 28/24 30/21 31/9
86/21 87/1 87/9 87/16 87/23 88/3 88/9
31/16 32/10 32/11 33/22 37/20 41/17
89/23 89/25 90/4 90/5 90/24 92/20 93/4
42/23 42/24 48/3 50/15 60/10 61/7
94/17 96/20 96/22 97/7 101/18 114/21
61/18 62/17 63/10 64/9 66/8 72/5 72/18
125/23 127/7 135/10 135/14 135/14
72/22 72/25 73/3 73/17 74/15 74/23
135/16 135/17 135/18 138/15 143/6
83/18 85/5 85/6 85/7 86/11 86/15 87/11
143/12 143/13 143/14 143/18 143/21
87/25 88/6 91/11 95/8 95/9 96/11 96/12
145/21 145/22 145/24 146/3 146/7
101/2 103/2 103/3 103/14 104/16
146/13 146/21 150/6 150/7 150/8 150/8
per [2] 24/22 24/24
104/16 105/17 107/16 107/17 108/11
percent [26] 17/10 17/13 18/1 18/9
112/2 112/3 112/4 112/9 112/25 115/25
118/14 121/10 125/17 125/19 126/4
18/14 18/15 19/11 19/13 21/10 21/12
127/1 127/4 128/6 128/9 129/15 129/21
22/2 22/3 25/25 26/5 26/25 79/13 85/16
133/25 136/6 139/10 141/3 141/11
138/15 138/18 141/16 144/5 146/6
142/16 143/11 145/17 146/16 146/19
146/6 146/11 146/12 146/13
percentage [6] 46/19 139/3 146/14
148/3 148/4 151/13 152/24
online [1] 85/4
147/4 147/9 147/11
only [26] 11/19 15/2 15/4 15/11 21/16
Perfect [1] 6/10
P
performed [1] 8/19
30/15 30/18 44/10 46/16 47/9 47/12
p.m [2] 153/22 153/23
perhaps [4] 27/6 27/9 49/5 120/2
49/24 50/14 51/9 59/18 64/9 79/22
82/19 91/25 95/2 126/19 135/9 138/15 page [25] 1/7 4/3 11/25 17/16 19/3 19/8 period [3] 75/5 104/10 108/4
permission [6] 6/22 52/11 90/19 97/25
20/12 20/15 20/16 21/22 21/25 34/9
138/19 143/23 151/11
open [2] 82/23 83/14
44/3 44/3 44/15 44/16 44/16 70/21
98/2 123/2
opened [2] 151/8 153/14
permitted [1] 13/1
70/24 71/5 76/4 93/7 93/13 119/19
operate [3] 60/15 96/24 112/13
person [35] 37/23 38/10 39/6 39/11
121/11
paid [3] 56/19 56/20 85/24
operates [1] 60/15
47/24 48/1 56/17 58/5 58/7 66/16 84/18
pain [1] 67/2
operating [1] 119/6
84/25 91/11 93/1 93/19 94/13 95/3 95/9
panacea [1] 94/17
opinion [24] 9/2 31/1 31/7 31/9 31/16
95/21 95/22 96/13 117/20 118/1 118/5
31/16 33/13 40/2 40/6 40/8 40/9 40/13 paper [6] 20/5 41/20 132/18 134/11
118/8 118/23 119/2 119/8 119/10
145/17 146/18
120/17 120/21 121/3 135/23 138/4
40/21 44/15 44/17 44/19 45/3 48/12
papers [2] 105/1 105/4
143/5
48/18 49/18 121/19 124/8 124/13
parents [1] 83/21
person's [1] 92/22
147/18
part [13] 22/8 44/1 44/19 49/6 62/3
personally [4] 82/17 132/5 132/14
opinions [10] 8/20 31/6 31/24 32/23
131/2 131/4 138/11 138/14 138/14
153/16
32/24 33/10 35/4 122/8 126/25 149/19
persons [7] 37/11 39/14 84/12 87/12
orally [1] 30/20
142/20 146/16 151/14
order [19] 32/3 57/16 59/21 67/25 85/6 participate [2] 18/13 68/8
91/24 92/4 92/23
85/22 85/23 96/14 105/2 105/11 107/20 participation [8] 18/8 18/10 18/13 18/15 Ph.D [1] 7/2
phone [7] 21/2 87/6 87/20 88/7 90/15
19/11 19/12 122/5 122/9
107/25 108/17 108/25 109/4 110/6
particular [20] 55/14 58/9 58/18 59/18
102/16 102/17
111/21 122/23 147/1
phones [2] 79/22 88/9
ordered [3] 56/1 56/3 56/5
66/8 66/25 66/25 67/18 67/20 67/22
photo [80] 17/1 17/3 18/17 18/20 19/15
organization [4] 79/5 79/6 79/8 79/16
68/8 68/13 68/19 68/22 68/25 73/21
organizations [4] 27/25 29/3 78/19 89/9 89/10 126/25 144/12 152/11
19/18 20/18 21/11 22/3 43/10 44/21
particularly [5] 36/6 36/11 81/20 92/17
original [2] 45/25 46/2
44/23 44/25 47/4 48/1 49/12 53/17
originally [3] 5/6 76/13 150/23
151/5
53/21 54/3 55/2 57/3 57/7 57/20 58/22
parties [4] 41/9 41/11 41/12 151/1
other [63] 5/14 9/7 11/16 11/21 11/23
59/3 60/11 74/6 81/8 81/17 82/22 83/1
84/22 84/25 87/1 88/3 89/19 89/24 91/8
12/6 13/1 13/12 13/13 13/19 14/16 15/7 parties' [1] 153/7
Partisanship [1] 133/10
91/14 91/19 93/2 93/3 93/21 94/14
15/17 16/7 18/16 19/14 22/23 27/12
partition [1] 14/15
94/16 95/3 95/8 95/14 95/19 95/22 96/9
27/25 29/2 29/5 31/24 32/10 32/11
parts [1] 152/9
96/17 96/21 105/10 105/21 105/22
33/22 36/20 37/24 44/21 50/8 50/15
party [2] 41/9 50/15
105/25 106/1 106/3 106/18 115/15
51/2 57/11 61/22 62/11 77/18 84/12
pass [2] 57/13 90/8
115/17 117/24 119/3 121/7 125/20
86/21 91/3 91/5 100/21 100/21 101/2
passed [2] 81/8 89/20
125/21 127/13 135/6 135/10 135/12
104/17 105/20 107/5 110/2 115/20
passport [13] 16/11 28/16 45/21 46/5
141/11 141/17 142/12 142/17 142/21
121/10 122/11 125/4 125/9 125/12
54/5 54/11 54/13 102/25 103/5 103/7
144/5 144/8 144/22 144/24
128/11 129/22 136/13 143/11 144/15
photograph [7] 72/5 72/18 72/22 73/14
103/10 103/12 103/13
145/13 149/4 149/14 149/19 152/13
past [6] 15/17 80/15 81/6 121/20 122/9 73/17 91/21 118/16
152/23

others [2] 87/16 150/18
otherwise [1] 90/3
Otto [1] 98/17
our [16] 6/18 11/19 16/13 22/1 43/22
52/16 75/18 79/14 89/25 90/15 116/17
122/20 135/3 147/1 148/15 153/9
ours [2] 81/4 88/2
ourselves [1] 146/25
out [58] 9/2 9/14 16/19 19/2 26/24 38/4
38/9 38/19 39/3 39/18 40/4 40/15 40/19
40/23 40/24 50/10 54/14 54/25 58/17
60/1 66/15 67/25 68/20 76/5 76/6 76/19
79/22 80/13 80/15 80/18 83/3 83/6
83/14 83/20 85/5 86/2 86/6 86/10 87/18
87/20 107/6 107/21 107/22 108/2
108/11 109/1 109/20 134/1 134/4 136/4
142/25 143/3 143/24 144/17 146/5
151/1 152/15 153/16
out-of-county [1] 50/10
out-of-state [1] 39/18
outside [3] 78/15 78/17 88/10
over [14] 19/5 20/16 52/19 54/16 55/13
76/25 78/10 79/17 92/16 96/23 98/7
116/25 142/6 151/21
overall [7] 18/14 19/12 25/23 26/11
26/20 27/10 153/9
overcome [1] 23/25
owe [1] 56/8
own [12] 57/22 63/7 63/10 63/12 85/11
88/3 102/4 103/15 112/14 115/2 115/3
116/2
owner [1] 116/5
ownership [13] 10/24 24/7 25/21 31/8
31/14 32/3 33/11 33/17 34/1 35/4 35/13
35/16 127/13

170

P
photos [2] 88/11 105/9
physician [1] 78/6
physicians [2] 92/14 92/17
picture [1] 72/9
pictures [1] 87/9
piece [2] 134/22 139/10
place [12] 27/6 58/8 59/11 68/5 70/18
84/20 100/23 110/9 112/4 119/22
119/25 142/23
places [7] 24/1 57/25 61/23 63/23 64/11
101/4 111/1
plain [1] 90/2
Plaintiff's [1] 119/18
plaintiffs [6] 1/4 1/14 4/3 7/11 41/10
41/11
plane [4] 57/4 57/8 57/16 110/16
planned [4] 123/14 123/22 125/15
127/14
plans [6] 30/16 36/16 36/20 49/1 125/15
126/2
please [11] 21/22 32/15 52/19 76/25
90/20 93/7 98/7 98/16 99/20 123/17
142/8
pleased [1] 148/6
PLLC [1] 1/16
plus [5] 38/12 46/22 81/21 102/4 119/24
point [22] 1/20 10/20 11/21 14/17 23/25
25/20 30/21 33/3 42/9 43/15 46/19
48/14 67/21 75/17 87/3 87/15 107/11
109/15 127/19 146/15 147/9 147/11
points [2] 11/15 147/4
policy [1] 48/20
political [4] 121/24 122/5 122/8 132/11
politically [3] 80/12 107/15 108/12
politicians [1] 107/16
poll [25] 59/12 61/23 68/22 95/25 96/2
96/23 125/16 125/18 125/23 125/23
125/25 126/2 126/5 126/7 126/10
130/24 131/3 131/6 136/15 136/21
137/7 147/15 147/16 147/18 147/19
polling [7] 21/2 58/8 59/11 110/9 137/12
145/16 145/20
polls [18] 10/5 10/25 24/7 31/20 33/13
33/21 34/2 68/11 68/12 68/18 91/4
95/23 96/1 135/20 135/21 136/19 138/6
138/16
population [3] 35/23 78/11 137/23
populations [1] 121/14
portion [4] 17/22 20/7 23/23 43/24
portrayed [1] 150/24
poses [1] 127/14
position [3] 148/21 149/21 151/22
positions [2] 152/14 153/19
POSNER [1] 3/12
possess [5] 12/21 38/20 53/23 54/2 54/3
possessing [1] 26/2
possession [8] 10/3 31/11 33/6 43/14
46/14 76/6 95/17 127/21
possible [6] 28/13 46/11 48/12 87/1
143/12 153/19
post [6] 21/14 43/22 45/18 48/13 54/14
69/20
post-election [1] 21/14
post-implementation [3] 43/22 45/18
48/13
posted [1] 51/12
postmaster [1] 54/12
potentially [5] 39/23 40/19 143/11
150/12 153/8
POTENZA [1] 1/16
poverty [2] 79/7 85/14
practice [3] 78/3 78/5 81/14

pre [8] 127/20 130/18 130/21 131/9
131/15 131/16 131/19 131/22
pre-existing [7] 127/20 130/18 130/21
131/9 131/15 131/19 131/22
Pre-R54 [1] 131/16
precincts [3] 125/24 146/5 146/11
precisely [2] 128/12 152/7
preclear [1] 148/14
preclearance [1] 96/19
precleared [5] 28/6 93/20 118/19 121/7
151/5
predict [3] 11/1 44/22 48/12
prediction [2] 48/10 121/18
predictions [2] 45/17 45/18
predominantly [2] 97/8 152/9
prepare [1] 41/15
prepared [2] 41/16 42/10
present [4] 1/22 48/22 91/24 94/13
presented [3] 47/12 55/1 149/5
presenting [3] 25/14 52/12 95/4
President [3] 78/25 109/20 110/3
presidential [1] 68/8
pretty [3] 24/12 24/12 33/3
prevent [1] 141/11
prevented [2] 49/12 142/12
preventing [1] 74/5
previously [1] 7/3
primarily [2] 79/6 97/7
primary [2] 137/18 137/20
principle [1] 108/2
prior [6] 29/15 30/9 43/5 43/11 67/10
131/12
private [5] 51/10 51/18 78/3 78/5 79/12
pro [3] 88/3 88/20 89/3
probably [6] 21/23 29/15 55/25 59/24
60/20 112/11
problem [4] 5/25 86/24 88/8 138/3
problems [6] 94/18 95/22 132/19 132/20
132/21 132/22
procedure [1] 119/6
procedures [4] 29/12 29/13 29/23 139/7
proceed [1] 6/16
proceeded [1] 86/7
proceedings [2] 3/24 154/4
process [15] 55/12 55/23 56/2 56/22
60/8 69/1 73/2 84/14 84/16 85/11 88/15
132/11 149/7 149/11 152/11
produce [2] 32/4 33/20
produced [7] 3/24 9/24 29/22 54/17
122/24 123/23 124/4
professional [1] 78/16
Professor [15] 8/20 35/12 39/17 40/2
40/13 40/21 41/4 44/24 45/21 139/13
139/21 141/2 141/21 144/11 144/16
program [8] 26/25 28/7 28/17 33/23
37/11 114/24 125/19 126/8
programs [7] 27/5 27/22 28/5 29/3 29/6
131/11 131/12
progress [1] 152/19
pronged [1] 86/23
proper [2] 25/2 143/25
proposed [1] 117/24
proprietor [1] 115/3
prove [1] 96/2
provide [6] 79/21 84/13 89/12 91/3
102/3 117/11
provided [5] 88/20 118/15 121/8 138/24
146/9
providing [1] 89/10
provision [5] 32/7 33/19 34/6 37/16
150/2
provisional [8] 131/23 132/2 133/10
133/17 134/8 143/4 143/7 143/9
provisions [1] 36/11

public [3] 37/10 110/20 131/12
publication [2] 132/18 132/22
published [1] 42/9
pulled [1] 86/6
purchase [1] 84/11
purchased [1] 85/24
purely [1] 137/25
purpose [1] 79/20
purposes [2] 44/11 44/12
purse [1] 69/6
pursuant [1] 122/23
push [1] 27/10
pushed [2] 27/6 82/16
pushes [1] 27/2
pushing [1] 81/12
put [17] 12/2 17/8 27/5 37/25 43/24
60/18 61/19 72/12 76/1 83/14 94/15
119/14 126/11 127/4 130/17 148/17
148/24
putting [3] 11/13 20/15 31/5

Q
qualifications [2] 78/13 150/21
qualified [1] 114/14
qualify [2] 114/17 151/3
qualitatively [1] 125/12
quarters [1] 102/8
question [68] 9/15 10/1 12/4 12/10
13/18 13/25 17/24 18/4 18/7 18/12
18/20 19/18 20/23 21/23 21/24 22/6
25/11 27/12 29/24 31/12 34/15 34/16
34/16 34/20 35/12 42/21 45/1 49/24
71/8 71/9 71/21 71/22 73/5 74/23 86/15
92/12 92/13 94/23 95/2 95/16 96/5
96/11 97/6 103/9 114/19 115/25 120/14
120/15 125/13 128/6 129/21 134/4
136/10 136/14 141/13 141/20 141/21
142/10 142/13 142/15 147/14 148/4
148/13 148/19 150/14 152/13 153/9
153/11
questioning [4] 36/13 38/4 47/6 129/11
questions [51] 8/10 10/9 11/13 12/15
14/22 17/20 17/23 17/25 18/23 19/9
19/21 22/10 23/10 31/1 31/24 34/14
34/22 36/10 40/5 41/4 41/24 42/2 42/19
47/14 48/2 49/21 50/24 60/25 61/9
61/23 62/19 63/16 74/18 74/21 90/7
91/17 96/12 97/15 112/16 113/6 115/20
117/7 122/11 123/1 129/4 136/3 139/17
144/3 145/8 148/1 148/4
quick [6] 5/4 19/1 60/1 60/1 74/23 145/7
QUINN [12] 4/21 122/20 122/22 123/6
123/11 130/9 130/12 130/17 132/10
133/8 145/2 145/11
quite [7] 8/12 11/7 11/7 34/15 126/7
133/18 136/19
quote [10] 8/10 8/11 8/19 8/22 9/21
117/24 118/1 121/12 121/23 121/25

R
R54 [35] 12/22 12/24 23/14 24/1 27/15
30/16 31/8 32/3 32/4 32/6 33/19 34/18
35/16 37/16 37/20 38/20 39/23 44/25
45/13 46/10 47/25 48/13 91/3 117/25
118/12 118/15 118/19 121/7 130/18
131/16 147/17 148/14 148/17 149/17
151/23
race [12] 28/10 28/24 43/14 53/5 76/5
77/10 99/20 134/20 144/13 146/2
146/22 147/1
Race-Neutral [1] 134/20
races [1] 26/2
racial [20] 11/18 12/8 31/8 31/13 31/18
32/3 33/11 35/13 127/12 127/15 127/20

R
racial... [9] 127/23 137/1 137/3 139/4
144/9 145/12 145/13 145/15 147/12
racially [4] 11/11 32/4 33/20 43/16
radio [4] 83/15 106/22 107/5 108/7
raise [1] 79/7
raised [4] 11/13 128/16 129/4 150/13
raises [1] 150/14
Ramon [1] 84/7
randomized [1] 137/10
range [1] 79/25
rate [3] 24/6 39/20 138/18
rates [13] 17/7 17/12 23/21 46/14 48/10
48/13 125/3 125/6 146/21 147/1 147/5
147/5 147/13
rather [7] 26/6 40/9 72/13 102/15
121/19 128/13 153/15
raw [1] 138/1
Raymond [2] 84/3 84/7
re [2] 138/2 141/6
re-weight [2] 138/2 141/6
reach [5] 32/4 33/12 33/19 33/25 133/25
reached [1] 35/5
reaches [1] 141/13
reaching [1] 33/11
reacted [1] 137/7
reaction [2] 106/25 149/4
read [23] 7/14 8/25 9/1 9/4 17/19 19/4
19/22 21/24 22/19 22/19 22/22 30/2
30/9 30/21 30/21 44/1 45/3 53/20 71/8
89/7 93/16 94/5 118/12
reading [6] 9/3 9/12 17/22 30/9 44/3
94/4
reads [1] 21/25
ready [1] 67/21
real [4] 35/24 36/1 60/1 60/1
realize [1] 152/19
realized [2] 82/15 82/16
really [23] 13/5 13/6 24/12 59/25 60/22
63/25 64/25 65/23 66/2 66/10 66/12
67/1 72/13 99/25 107/15 107/16 109/13
127/1 148/5 149/8 151/3 151/14 151/18
reason [14] 21/11 22/4 24/12 24/12
59/13 71/10 94/12 100/21 100/21 110/2
136/5 136/18 141/20 150/9
reasonable [36] 5/20 10/2 19/24 25/7
32/6 33/19 34/6 49/1 49/4 49/11 49/23
59/1 59/5 59/9 59/12 59/14 59/15 74/9
74/11 74/12 122/25 123/14 123/15
124/9 124/12 126/14 127/11 128/8
128/13 129/24 150/2 150/9 150/22
151/3 152/10 153/8
reasonably [1] 59/9
reasons [2] 142/13 142/15
rebuttal [4] 22/23 52/2 132/25 133/5
recall [16] 8/9 8/23 9/3 9/5 35/14 47/2
47/8 114/10 114/14 128/14 136/6
138/23 139/5 139/23 141/18 144/1
receive [7] 37/21 69/9 69/11 79/9 79/11
125/25 137/11
received [10] 5/12 71/11 79/16 123/13
123/17 125/24 126/16 127/16 136/16
137/2
recently [4] 8/15 9/2 29/22 29/24
RECESS [3] 75/22 75/23 153/23
recidivism [1] 80/20
recitation [1] 19/3
recognize [2] 35/24 119/15
recognized [1] 146/20
recollection [2] 67/9 138/13
recommend [2] 132/18 132/22
record [19] 14/2 17/8 19/2 19/5 22/20
53/3 61/20 77/8 98/16 101/10 105/21

113/23 117/22 119/17 142/7 148/6
149/12 153/17 154/4
recorded [1] 3/24
recording [1] 88/11
records [3] 85/6 92/22 92/24
rectify [1] 127/12
recycled [1] 79/21
redirect [3] 97/14 122/16 145/5
reduce [1] 26/4
refer [3] 46/20 133/8 138/8
reference [2] 36/7 48/17
referencing [1] 35/22
referred [1] 84/23
referring [4] 21/8 36/2 128/17 132/4
reflect [2] 152/18 152/19
regarded [1] 141/3
regarding [5] 37/5 48/18 48/25 125/20
130/19
Regional [1] 80/14
register [9] 80/10 81/4 89/23 108/12
108/20 114/5 119/10 120/16 121/2
registered [25] 12/20 18/4 27/14 39/7
39/9 39/12 53/13 53/15 58/3 60/13 68/3
70/18 89/17 89/25 107/11 108/18 113/9
113/19 114/2 135/10 135/14 135/15
135/18 136/7 145/23
registrant [5] 38/7 38/18 39/2 39/4 39/5
registrants [21] 14/8 17/6 26/1 28/17
38/3 38/16 38/19 39/22 39/24 40/3
40/14 41/3 43/9 46/16 46/21 46/22 47/3
47/4 47/9 47/13 135/20
registration [59] 14/24 38/15 39/9 39/11
40/18 50/16 66/4 66/18 67/6 69/5 71/11
72/18 72/21 73/11 80/24 81/2 90/2 91/8
91/15 91/19 91/20 91/25 93/2 93/3
93/19 93/21 94/13 94/14 94/16 95/3
95/4 95/8 95/13 95/14 95/15 95/18
95/20 95/21 96/9 96/18 96/21 107/23
108/9 108/19 109/2 109/4 112/10 113/9
114/7 118/10 118/16 119/3 119/23
119/25 120/22 120/23 121/7 135/19
145/24
registrations [1] 120/21
registry [2] 85/1 85/2
regression [2] 144/12 144/20
regular [1] 143/5
regularly [1] 80/14
rehash [1] 43/12
reinforced [3] 126/19 126/24 127/25
reinforces [1] 127/18
reject [1] 8/19
rejected [5] 8/8 8/18 9/9 9/18 54/19
related [3] 26/17 58/18 106/18
relates [1] 148/5
relating [4] 30/22 128/9 128/13 148/12
relative [2] 92/7 92/8
relevance [1] 62/18
relevancy [1] 63/15
relevant [3] 8/10 44/17 92/13
reliable [1] 136/20
relied [2] 137/18 138/19
relies [1] 138/11
reluctant [1] 72/13
rely [6] 32/5 33/18 33/24 110/25 133/13
140/6
remains [1] 5/5
remedy [1] 24/8
remember [25] 9/12 21/3 21/13 21/17
24/9 36/13 38/4 46/19 47/6 49/9 64/1
64/4 64/6 64/20 66/23 66/24 67/5 68/14
71/22 71/23 71/23 90/15 95/6 95/12
114/19
renovate [1] 80/6
repeat [1] 49/19

171
rephrase [1] 42/5
report [29] 21/18 22/19 22/22 22/23
34/19 39/16 41/15 41/18 41/19 42/7
45/24 45/25 46/2 46/25 119/13 119/18
124/18 125/11 126/13 127/10 132/25
133/5 133/13 133/15 138/9 139/11
140/6 140/7 146/17
reported [2] 39/19 144/6
reporter [3] 3/16 3/17 6/11
reports [13] 7/10 7/14 7/18 7/22 7/25
9/24 17/12 17/12 22/23 25/24 29/10
45/22 48/9
representation [2] 141/21 149/9
representations [1] 151/6
representative [6] 35/25 55/9 137/23
138/2 141/7 143/17
represented [1] 133/7
representing [7] 52/15 113/1 134/13
134/16 138/21 139/23 144/2
request [5] 5/13 147/1 147/5 147/5
147/13
require [2] 96/1 96/2
required [6] 12/21 32/5 81/23 81/25
82/1 153/4
requirement [5] 60/12 60/14 130/25
131/7 131/19
requirements [8] 117/25 124/21 125/10
126/8 140/4 144/5 144/8 147/16
requires [1] 130/22
reread [1] 94/9
research [1] 138/4
researchers [2] 11/16 12/6
reservations [1] 73/20
reserve [1] 52/2
resolve [1] 8/11
respect [11] 10/21 30/16 40/9 45/12
45/13 45/16 49/15 50/2 116/17 149/6
151/22
respond [10] 5/16 5/18 5/21 6/5 6/8
135/16 135/20 136/9 145/24 150/6
responded [1] 138/16
respondent [1] 135/22
respondents [6] 137/22 137/25 138/1
141/6 141/16 143/24
respondents who [1] 137/25
responding [1] 49/21
response [7] 36/18 51/20 51/22 94/4
136/16 136/22 138/18
responses [1] 149/6
rest [1] 94/6
result [6] 10/5 22/6 22/8 31/17 34/1 47/9
results [12] 10/23 10/23 12/6 46/8
124/22 125/1 125/8 125/9 125/11
125/14 137/15 147/2
retained [2] 41/7 56/14
retention [1] 50/11
retired [1] 87/25
return [1] 38/2
returned [11] 38/3 38/9 38/18 38/23
39/1 39/3 39/18 39/20 40/3 40/15 40/24
review [4] 6/7 129/22 132/11 133/6
reviewed [8] 29/9 39/16 123/18 123/19
123/25 124/3 129/13 132/15
reviewer [2] 132/14 132/17
Reynolds [1] 129/16
RICHARD [2] 2/1 6/15
ride [3] 84/18 85/20 114/24
rides [7] 85/20 114/11 114/12 114/15
114/18 114/20 114/22
right [99] 5/22 6/10 9/6 10/10 10/13
11/20 13/7 13/14 13/20 14/19 14/25
15/5 15/20 16/17 20/4 22/15 23/2 24/20
29/16 30/17 31/3 31/10 31/14 32/7
33/14 33/16 33/21 34/7 35/5 35/8 48/23

screen [3] 120/3 120/4 120/9
R
script [1] 123/22
right... [68] 52/2 52/3 52/9 56/15 58/23 SEAN [1] 2/12
searching [1] 149/8
59/7 60/3 60/9 60/10 62/1 63/8 65/20
SEC [9] 22/17 29/22 123/22 123/23
66/13 71/17 72/2 73/9 73/12 74/22
76/11 76/20 79/24 80/1 80/2 80/8 80/16 124/14 128/7 128/12 129/2 129/16
80/17 81/7 82/3 82/8 82/24 90/10 94/5 second [5] 21/25 32/10 88/6 119/24
96/3 103/10 111/1 112/17 113/7 115/9
120/22
Secondly [1] 87/4
116/10 117/8 122/12 124/12 124/18
Secretary [1] 51/12
125/18 130/10 133/17 134/2 135/2
Section [1] 2/6
135/5 135/11 135/24 136/1 136/4
security [23] 57/10 57/17 60/19 69/11
136/24 137/5 138/12 138/15 138/20
138/21 139/5 142/14 143/19 144/7
69/14 69/16 72/10 72/12 72/15 81/24
144/23 145/4 145/15 147/22 153/21
82/1 92/1 104/11 104/12 104/13 104/15
Rights [2] 2/5 3/13
104/23 105/4 106/6 106/8 112/3 113/12
risk [2] 127/15 127/24
138/25
road [3] 92/9 114/8 114/9
see [19] 5/14 5/15 5/20 10/18 22/4 29/18
robust [2] 126/22 126/23
65/19 65/23 67/8 71/15 88/10 90/18
rock [2] 62/14 68/7
105/21 117/18 120/4 120/7 127/22
role [2] 100/9 132/17
129/14 147/8
roll [3] 39/9 39/12 40/18
seeing [2] 120/3 142/20
room [2] 3/17 60/21
seek [1] 87/15
roughly [3] 100/12 112/3 147/6
seem [3] 43/23 49/9 95/20
round [2] 86/3 111/15
seemed [2] 125/24 147/12
route [1] 86/21
seems [1] 147/10
rows [1] 120/19
seen [4] 123/19 123/22 126/18 128/1
RPR [3] 3/16 154/3 154/7
SELLS [1] 2/2
RR54 [1] 147/20
send [4] 87/20 109/11 135/19 145/23
Ruben [1] 88/1
senior [2] 79/21 79/23
rule [1] 132/2
sense [4] 24/21 26/18 148/20 153/15
rules [1] 83/7
sensitivity [2] 146/18 146/24
ruling [2] 43/24 44/17
sent [4] 87/8 87/9 87/18 136/8
run [7] 14/6 15/12 22/14 25/14 28/13
sentence [2] 21/25 94/4
separate [2] 134/4 144/18
28/14 60/13
running [1] 109/20
separately [2] 111/13 134/1
rural [1] 37/10
September [1] 53/16
Rutherford [1] 84/3
serious [4] 55/15 95/19 132/19 132/20
seriously [1] 81/12
S
served [6] 8/15 9/8 9/15 9/16 100/7
Sacramento [1] 55/8
132/14
safe [2] 96/17 97/12
serves [1] 144/13
said [31] 23/6 26/22 36/18 36/20 49/11 service [3] 89/2 101/18 109/11
services [3] 56/8 56/18 102/3
54/16 55/13 68/4 68/5 71/19 71/20
SESSION [1] 1/6
71/20 71/21 74/9 82/20 84/24 96/13
set [10] 21/15 65/4 83/3 115/2 115/3
107/18 107/21 108/12 108/14 108/14
109/23 110/3 112/11 113/16 114/23
116/2 137/19 137/20 139/11 150/12
sets [1] 46/25
128/7 152/8 152/25 153/1
same [11] 38/16 39/21 44/11 95/24
several [3] 17/20 52/15 86/9
severe [1] 132/22
106/10 118/22 119/3 121/6 141/10
sexual [1] 56/12
142/5 146/10
same 2009 [1] 141/10
shambles [1] 85/15
sample [3] 22/1 140/12 143/17
she [36] 37/5 49/1 55/11 55/13 61/23
San [1] 62/15
64/14 64/16 64/18 64/20 64/25 66/5
Savannah [1] 77/17
66/7 67/10 67/11 67/14 67/14 69/2 69/3
saw [5] 38/7 43/25 71/18 127/5 128/25 70/18 71/13 71/14 71/18 71/20 71/22
say [32] 11/3 16/11 24/24 32/10 32/11
71/23 75/11 83/21 127/2 127/2 127/5
33/7 36/19 41/16 42/24 49/9 60/3 73/20 138/16 138/24 152/3 152/4 152/8
74/4 91/25 92/9 92/23 94/11 101/5
152/21
she's [11] 49/6 58/1 64/13 64/23 64/24
103/9 103/22 104/20 105/20 127/5
130/4 130/4 130/24 135/5 136/1 136/1
65/1 65/3 66/6 73/25 74/1 83/18
Shook [2] 51/19 51/21
136/24 137/22 138/3
saying [14] 8/9 17/14 23/9 40/17 56/8
shop [1] 102/8
short [2] 134/3 136/2
68/21 72/24 73/1 83/15 92/18 93/2
should [26] 10/22 18/6 26/12 27/6 28/7
113/24 114/19 150/1
says [6] 18/3 56/11 59/4 59/5 91/24
28/17 31/18 37/18 37/21 38/25 40/9
152/16
93/5 93/23 94/10 126/6 126/7 127/7
SC [2] 1/20 2/22
143/7 145/22 146/3 146/7 146/14
schedule [1] 148/15
146/21 150/15 151/1 153/8
schedules [1] 111/19
show [21] 33/17 57/12 57/15 57/15
school [6] 61/13 61/14 80/9 85/17 99/23 105/1 106/22 107/5 119/25 120/19
100/4
130/22 135/6 135/12 135/13 135/14
schools [2] 51/10 51/18
135/15 135/18 135/19 135/21 135/23
science [2] 25/17 132/11
135/24 143/14
scientific [1] 10/3
showed [1] 49/11

172
showing [1] 119/7
shown [2] 16/22 92/13
shows [9] 119/9 119/21 119/22 120/15
120/18 121/1 124/5 145/17 146/17
shrink [1] 27/11
side [4] 5/14 5/15 49/10 152/5
sign [2] 59/1 87/12
signatures [1] 50/11
significant [14] 31/8 31/12 32/2 33/10
33/17 35/13 35/21 36/5 121/12 121/17
121/21 121/24 125/22 126/9
signing [1] 74/9
similar [5] 9/5 37/19 125/12 144/19
147/6
similarly [3] 96/19 127/5 127/25
simple [2] 91/23 125/1
simply [1] 121/19
since [18] 8/12 29/8 29/25 32/2 32/17
33/16 49/6 53/10 53/16 58/2 59/17 60/7
66/10 68/6 89/24 104/5 151/8 153/14
sir [42] 7/16 8/1 8/5 8/17 8/23 9/1 10/18
12/1 12/11 12/18 13/4 16/18 17/15
18/25 19/23 20/5 20/11 22/12 28/23
30/11 33/15 34/12 43/2 47/24 66/24
70/8 70/11 71/16 74/17 91/2 93/3 93/14
93/18 96/10 96/16 97/10 98/6 116/11
116/24 122/19 131/9 147/23
sister [2] 84/6 84/8
sit [1] 23/17
sitting [5] 11/20 30/4 34/17 124/7 139/5
situation [3] 57/11 68/20 108/8
six [3] 64/24 83/16 104/3
size [2] 141/19 147/3
slip [1] 44/16
slippage [1] 143/11
slow [3] 101/9 113/21 142/7
small [2] 133/20 139/10
so [170]
social [24] 25/17 56/8 57/17 60/19 69/11
69/14 69/16 72/10 72/12 72/15 81/24
82/1 92/1 104/11 104/12 104/13 104/15
104/23 105/4 106/6 106/8 112/3 113/12
138/25
socioeconomic [13] 24/19 25/18 26/10
27/13 36/12 37/8 37/12 97/8 121/13
121/20 121/22 122/4 143/15
solely [2] 122/8 135/1
some [58] 17/5 21/18 23/23 23/25 24/8
25/14 25/23 28/8 28/17 28/19 29/17
30/21 30/21 36/4 36/10 39/17 45/20
55/15 58/16 65/4 66/16 66/24 67/1
68/23 69/2 73/20 79/14 79/17 79/17
82/9 88/16 89/7 91/14 93/4 100/3 100/4
107/25 109/15 128/15 129/3 129/4
129/22 130/1 135/13 136/11 136/14
137/6 137/10 137/12 142/13 142/15
142/19 143/10 146/2 149/1 149/6
151/10 152/19
somebody [4] 88/7 88/12 109/11 111/5
someone [9] 14/7 15/16 15/18 15/22
28/13 28/15 30/18 58/25 92/11
someplace [1] 65/13
something [12] 9/5 26/24 36/21 49/18
59/22 60/22 60/23 61/23 69/2 144/18
147/11 152/11
sometimes [7] 64/15 110/25 111/15
111/15 111/25 116/4 150/17
somewhat [3] 21/13 104/15 130/20
somewhere [4] 21/18 25/25 111/6 111/7
son [11] 62/6 62/14 62/15 62/17 63/2
63/14 63/23 64/7 64/8 67/19 67/20
son-in-law [9] 62/6 62/17 63/2 63/14
63/23 64/7 64/8 67/19 67/20
sorry [29] 14/1 14/21 16/4 20/21 33/8

S
sorry... [24] 42/25 57/6 69/23 73/8 80/21
80/22 82/7 82/7 83/21 86/19 88/12
94/24 96/6 121/22 124/1 124/2 125/21
128/16 131/4 132/25 133/3 136/13
143/2 146/19
sort [4] 136/2 136/14 141/4 151/21
sound [1] 140/25
sounds [2] 91/23 108/16
sources [1] 46/4
south [119] 1/3 1/22 1/24 2/20 5/3 5/8
5/9 5/13 6/20 10/4 12/22 22/16 25/5
25/19 26/1 26/10 26/19 35/8 38/3 38/10
39/7 39/9 39/12 39/14 39/19 45/16 47/3
52/1 53/8 53/13 58/2 58/10 60/11 60/13
61/8 61/25 68/9 68/15 69/24 70/10 72/1
74/5 74/6 74/16 75/4 77/13 77/18 77/21
78/7 81/2 81/8 81/12 81/16 81/20 86/9
86/10 89/9 89/14 89/17 89/20 90/10
91/6 92/12 92/17 94/18 95/25 96/18
97/1 99/1 99/4 100/15 100/17 100/19
100/22 100/24 101/2 101/3 104/4
104/19 105/11 106/19 106/24 107/12
112/17 112/20 113/1 114/25 117/10
118/4 118/6 118/15 119/6 121/14
121/25 122/6 126/4 126/11 126/15
130/8 130/19 130/21 131/21 131/22
132/7 134/2 134/4 134/6 139/7 140/15
140/16 140/18 147/17 147/19 148/5
148/16 148/20 149/20 151/21 153/5
speaking [3] 142/4 151/11 153/1
specific [10] 21/6 46/20 54/1 138/4
140/15 140/16 140/16 150/1 152/3
152/12
specifically [12] 12/1 26/18 27/16 28/19
32/21 51/13 95/25 119/19 126/20 137/4
144/17 151/19
specifics [1] 152/17
speculation [6] 31/2 31/5 34/7 34/18
35/3 73/24
spelled [1] 84/9
spent [3] 23/4 131/10 131/16
SPITZER [1] 3/1
spoke [4] 22/17 90/14 94/1 95/6
spot [1] 68/7
St [7] 99/1 99/3 101/16 110/13 110/21
111/11 113/16
stand [4] 12/6 75/16 116/23 122/21
standard [2] 119/5 150/22
standards [1] 79/7
stands [1] 11/16
start [5] 14/23 75/24 93/9 142/6 142/8
started [5] 5/7 38/16 56/5 86/2 150/24
starting [5] 17/20 19/8 20/16 26/24
108/5
state [71] 1/3 5/3 13/9 13/12 14/4 14/5
14/7 14/13 15/12 15/19 15/22 15/23
15/25 22/21 25/5 27/24 29/11 30/15
34/19 35/2 38/4 38/9 38/19 39/3 39/18
40/4 40/15 40/25 50/12 51/5 51/7 51/9
51/12 51/15 51/16 52/1 53/3 54/1 54/3
58/17 60/10 61/8 77/8 81/2 86/10 94/15
98/16 98/25 103/19 103/23 104/5 105/5
106/24 112/20 113/1 117/10 117/19
119/6 121/23 122/24 124/4 126/21
129/13 140/18 141/9 144/14 149/9
150/17 150/19 151/17 151/21
state's [6] 6/7 51/12 123/14 125/15
126/1 127/13
state-issued [1] 14/13
stated [5] 8/19 67/14 117/22 127/2
150/9
statement [5] 23/16 56/8 59/8 71/16

92/21
statements [3] 69/7 69/9 152/20
states [18] 1/1 1/6 5/3 8/16 13/13 44/19
95/25 97/17 115/21 122/14 140/9
140/13 144/4 144/8 144/17 144/21
144/24 145/6
States' [1] 7/11
stating [2] 92/19 93/4
statistically [3] 125/22 126/9 147/2
statistics [3] 55/8 84/24 84/24
status [9] 27/13 36/12 37/8 37/12
121/13 121/20 121/22 122/4 143/15
statute [3] 130/17 150/17 150/19
statutes [1] 152/4
stenography [1] 3/24
step [9] 51/23 52/19 55/7 76/25 98/7
116/24 122/18 137/17 147/23
STEPHEN [3] 1/16 140/1 140/3
steps [3] 54/24 55/9 112/7
Stewart [3] 7/12 7/24 39/17
Stewart's [1] 7/20
still [7] 27/4 27/7 27/9 40/7 73/20 81/25
124/15
STIRLING [1] 1/23
stone [1] 68/21
stop [5] 82/24 86/17 88/6 96/4 110/23
store [1] 64/16
stores [1] 102/2
story [4] 99/14 106/25 107/3 108/6
strangers [1] 83/6
stratified [1] 140/12
street [12] 1/17 2/13 2/17 2/21 3/6 64/21
65/19 65/22 65/23 66/1 66/3 83/6
stricter [3] 142/17 142/21 142/24
strike [2] 120/25 133/3
stripped [1] 35/3
strive [1] 80/1
striving [1] 80/7
strong [1] 146/4
strongly [1] 94/19
struck [2] 81/13 127/1
studies [6] 11/21 20/17 125/9 125/12
142/18 142/19
study [47] 10/21 11/4 11/19 11/19 13/5
13/5 13/6 13/11 16/13 19/25 20/8 21/1
21/13 21/14 27/16 31/17 32/11 33/3
33/13 43/13 43/22 48/17 48/19 124/20
124/23 124/24 125/14 125/17 126/3
126/4 132/23 133/1 133/4 133/16 135/7
137/8 139/3 139/10 140/14 141/8
141/10 142/18 143/1 143/2 145/8
146/17 146/19
stuff [1] 67/4
subject [2] 47/18 106/23
submission [1] 6/7
submit [1] 5/22
submitted [9] 7/10 7/15 7/18 41/21
41/22 42/6 117/5 122/22 133/2
subsequently [1] 85/4
subset [2] 39/17 148/23
substantial [3] 90/3 127/14 127/24
subtract [1] 38/15
successful [2] 80/19 126/12
such [9] 33/18 38/18 39/6 39/11 39/14
47/10 90/1 107/1 135/10
sudden [1] 107/2
suffers [1] 8/21
Sugar [1] 92/9
suggest [5] 24/11 125/14 126/1 126/5
128/1
Suite [5] 1/17 2/17 2/21 3/3 3/14
Sullivan [1] 2/13
summarizes [1] 31/25
Sumter [10] 77/13 77/14 78/7 79/2

173
80/13 84/5 84/19 87/19 89/10 92/5
Sumter-Lee [1] 80/13
Super [3] 140/9 140/13 140/18
supplemental [3] 22/22 45/23 117/22
supply [1] 44/12
support [2] 78/12 126/23
supported [2] 20/8 20/18
supposed [2] 136/25 153/17
suppress [1] 11/6
Supreme [1] 150/18
sure [21] 32/18 38/13 45/3 66/19 70/14
71/13 71/21 75/20 93/6 93/6 96/25
107/21 113/8 119/12 119/14 121/10
134/6 134/13 148/10 148/16 152/15
surprise [1] 134/15
survey [18] 21/16 135/22 137/18 138/5
138/13 138/14 138/14 138/17 140/9
140/9 140/11 140/12 140/22 141/2
143/14 143/16 143/20 143/23
surveyed [1] 21/20
surveys [3] 137/23 138/11 141/3
SUSAN [1] 2/19
suspect [1] 25/22
sustain [2] 47/15 55/18
sweep [1] 152/3
switching [1] 52/4
sworn [6] 7/3 52/22 77/4 98/10 117/3
123/7
system [1] 60/14

T
table [6] 25/24 46/20 119/21 119/22
120/18 120/20
tacked [1] 136/23
take [41] 7/19 10/22 31/18 33/11 35/4
54/24 55/12 56/3 60/22 63/21 65/2
67/12 68/22 68/24 72/21 73/16 75/18
75/25 76/12 82/20 86/21 86/25 99/6
99/8 100/2 106/15 108/22 108/23 111/6
111/7 111/20 112/8 112/9 112/12
113/23 116/7 120/6 138/5 138/22
139/24 144/2
taken [3] 58/9 66/19 71/19
takes [3] 26/25 27/1 111/16
taking [6] 10/23 40/23 56/5 67/1 67/3
137/17
talk [5] 26/7 70/9 79/3 83/8 106/22
talked [5] 8/2 8/14 55/8 57/10 152/3
talking [17] 15/17 24/25 25/20 30/23
32/18 41/5 46/13 55/11 69/24 97/2
103/7 103/8 108/5 137/5 137/25 139/13
139/21
tally [1] 38/19
TALY [1] 2/11
targeted [2] 28/19 29/4
targeting [3] 28/8 28/9 28/10
task [1] 136/6
tax [1] 80/12
taxi [1] 99/12
teach [1] 80/1
team [1] 49/6
technically [1] 95/17
television [1] 70/9
tell [26] 14/6 32/17 42/5 54/10 61/12
65/24 66/13 66/15 66/20 66/22 67/4
70/15 88/8 91/22 92/8 93/5 94/19 98/24
99/13 99/20 101/20 101/23 104/8
104/11 109/19 119/21
telling [1] 40/9
Ten [1] 75/21
tens [4] 12/20 16/7 23/12 81/15
term [3] 9/21 9/23 35/21
terms [19] 5/5 26/6 26/16 33/12 38/14
42/1 43/17 51/2 55/23 58/13 58/19

T
terms... [8] 63/21 80/23 83/9 84/14
133/23 142/24 142/24 152/8
terrific [1] 5/25
terrified [1] 89/23
test [1] 151/2
testified [19] 7/4 10/1 48/22 52/23 61/25
63/7 64/8 66/6 72/1 75/3 77/5 82/5
88/19 89/14 98/11 115/5 117/4 123/8
141/1
testify [4] 10/2 24/16 30/18 37/5
testifying [4] 30/13 64/6 64/20 122/5
testimony [44] 7/19 7/23 7/23 9/7 9/9
9/11 9/14 12/1 30/2 30/5 30/23 37/3
37/18 48/23 48/25 49/3 49/19 52/2
75/19 97/7 117/6 117/18 117/23 120/6
121/11 121/16 121/23 122/22 124/1
124/6 124/19 127/2 128/9 129/3 129/23
148/11 148/11 148/25 149/3 149/4
150/1 150/5 150/11 152/1
testing [1] 17/4
tests [1] 153/11
than [28] 18/16 19/14 22/9 25/25 26/6
26/25 40/9 40/23 47/4 63/10 77/18
85/17 89/24 117/19 119/2 119/8 119/10
120/16 121/1 121/3 125/3 125/3 125/6
125/25 141/15 147/16 148/14 153/15
thank [36] 6/17 6/25 10/8 19/6 19/24
33/2 35/7 40/11 51/24 52/8 52/13 60/25
75/8 75/13 90/9 97/11 97/13 97/18
97/20 97/22 98/2 116/9 116/12 116/14
117/13 120/12 122/19 123/4 124/3
128/3 130/6 130/14 145/1 145/3 147/21
147/24
that [888]
that 2006 [1] 134/10
that's [79] 5/24 5/25 8/1 8/17 9/22 10/7
11/7 13/8 13/8 13/10 15/4 15/6 15/15
16/3 16/5 17/4 18/4 20/5 20/20 29/1
29/18 30/15 30/18 30/24 31/4 31/16
33/7 39/10 41/18 41/22 42/22 43/19
44/14 49/23 59/18 61/9 62/24 65/8 68/2
72/14 72/15 76/14 86/8 88/22 97/3
102/10 102/14 102/18 103/5 105/18
109/1 110/10 114/7 114/9 118/11
118/22 128/1 129/3 129/16 132/2 133/7
133/13 133/15 134/9 134/24 135/3
135/4 135/25 138/7 138/21 139/1 140/6
140/7 140/11 143/10 143/22 144/7
144/23 145/1
the 2000 [1] 18/8
the 2004 [2] 11/5 133/11
the 2006 [1] 133/8
the 2008 [2] 124/25 135/3
the 2009 [3] 138/8 139/20 139/25
the 2012 [1] 150/3
theft [1] 60/21
their [36] 14/24 17/6 18/8 18/10 25/1
28/10 29/22 39/19 39/20 62/8 67/23
67/25 80/8 85/11 87/22 91/20 92/1 92/1
92/6 93/1 93/20 94/13 95/4 111/19
111/21 118/1 119/25 128/24 129/24
135/19 136/22 136/25 138/16 143/8
145/24 151/18
them [42] 6/23 11/22 24/1 33/22 49/12
50/4 54/8 76/18 78/10 78/14 80/7 80/18
81/5 82/23 83/4 85/20 87/3 87/13 87/14
89/7 89/8 90/24 91/7 92/8 93/5 102/2
104/13 105/9 105/21 111/3 111/11
111/17 111/23 112/3 120/6 136/3 136/5
138/2 138/2 141/6 141/7 152/4
themselves [1] 91/25
then [41] 5/19 6/11 15/24 19/8 45/9

46/21 52/3 54/15 55/11 56/1 56/4 56/7
56/10 56/12 57/11 61/13 63/19 66/19
68/20 71/8 71/16 73/3 73/20 76/11 82/4
92/8 94/5 97/6 100/22 104/23 107/20
109/22 135/16 140/9 140/12 143/11
147/23 148/23 149/13 149/16 151/20
THEODORE [1] 2/11
there [101] 8/18 11/10 12/2 12/20 15/18
16/10 18/1 21/15 21/20 23/12 23/22
23/22 27/4 29/2 29/5 29/17 31/11 33/5
33/22 35/23 36/20 37/18 43/13 43/16
50/4 50/8 50/11 50/15 50/17 53/15
54/14 54/22 55/9 64/10 65/10 65/24
67/19 67/24 68/4 68/5 68/20 68/23 71/9
71/12 72/12 76/8 77/15 81/21 82/9
82/24 82/25 83/7 85/14 86/12 86/17
86/20 91/5 91/8 97/1 98/5 99/11 100/21
100/21 101/17 104/10 108/21 108/25
110/1 110/11 110/20 121/12 121/24
124/8 124/11 125/22 128/15 129/14
129/14 129/15 133/20 134/3 134/3
135/16 137/8 137/10 137/12 138/1
140/11 140/12 140/16 141/3 142/13
143/8 143/10 143/11 146/1 146/20
147/8 147/10 147/12 149/16
there's [22] 21/17 27/6 27/9 31/8 31/12
36/17 51/11 61/20 85/14 85/16 88/7
127/21 129/3 130/4 133/23 136/22
142/15 146/14 148/12 149/1 149/6
150/16
therefore [3] 59/2 86/6 151/6
Thereupon [6] 7/1 52/20 77/2 98/8 117/1
123/5
these [51] 6/21 12/17 14/16 19/19 20/7
23/23 26/2 26/3 28/8 28/17 28/18 50/5
54/6 62/18 63/16 76/5 76/14 76/16
76/16 79/22 80/1 81/18 82/2 82/12 83/5
84/9 84/14 85/19 85/21 87/16 87/22
88/14 119/25 121/16 125/8 125/11
127/7 127/17 128/21 130/2 133/24
141/6 142/17 143/6 143/13 143/18
144/19 145/20 145/22 146/25 152/14
they [128] 9/21 11/23 12/6 12/23 13/15
15/10 15/22 15/24 16/2 16/12 20/2 20/3
20/4 20/20 23/19 23/20 23/25 24/8
24/23 25/4 25/9 28/15 28/16 29/14 34/3
34/8 37/21 37/22 39/8 39/9 49/10 49/11
49/13 51/5 51/6 51/7 55/1 59/1 60/22
60/22 62/13 63/3 63/4 63/5 63/7 63/10
63/12 63/13 65/2 68/4 68/5 68/6 74/14
74/20 76/12 78/10 78/11 78/11 78/13
79/24 80/18 81/24 83/12 85/13 85/14
85/15 85/19 85/22 87/2 88/19 88/23
88/24 89/6 92/5 92/12 93/5 93/20 93/23
94/10 94/11 96/24 101/1 101/8 101/25
102/1 102/2 104/10 104/14 105/13
105/21 105/22 106/10 106/23 107/5
108/23 112/11 112/13 114/22 120/1
120/5 126/6 126/7 131/1 133/21 133/25
134/4 135/10 135/12 135/13 135/15
135/19 136/4 136/5 136/7 136/8 136/9
139/15 140/17 140/23 141/16 141/17
143/4 143/7 143/24 143/25 149/15
153/2 153/2
they're [2] 62/23 149/22
they've [1] 138/5
thing [15] 32/11 43/12 60/8 80/17
104/16 107/16 107/18 121/10 126/4
127/1 136/13 146/10 146/16 151/13
152/25
things [17] 5/5 11/23 24/23 25/2 52/5
65/4 65/5 67/1 67/3 123/19 126/24
126/25 141/7 146/19 151/2 151/8
152/25

174
think [85] 7/21 8/1 8/2 9/11 9/22 10/6
11/7 15/18 16/14 16/19 17/5 20/21
20/22 21/15 21/16 21/17 21/18 21/23
23/19 24/2 24/11 24/15 24/15 24/18
26/11 26/21 27/5 27/10 29/13 30/1
30/14 31/6 31/21 31/25 32/8 32/11
32/16 33/3 33/4 34/3 35/22 36/18 36/23
38/25 40/16 40/17 41/1 41/1 42/22 44/7
48/3 48/22 50/23 51/6 51/11 59/8 59/10
63/7 69/3 72/11 73/22 96/4 109/25
124/11 124/14 124/16 126/4 127/1
127/8 129/4 129/16 132/18 136/7
140/24 141/1 142/13 142/14 142/15
142/20 143/8 143/12 144/23 148/15
150/5 151/2
thinking [4] 43/19 128/20 129/8 151/10
third [2] 22/1 50/15
third-party [1] 50/15
this [143] 5/23 7/15 7/18 9/24 12/5
17/22 18/3 20/7 22/14 25/20 32/11 33/3
35/20 36/10 39/16 43/25 44/5 44/6
44/19 44/24 45/4 45/5 45/8 45/16 45/17
47/16 48/9 48/14 50/25 52/5 52/16
53/18 53/25 56/5 56/17 57/1 58/23
59/16 60/11 60/13 61/1 61/1 61/8 61/16
64/1 64/4 65/4 65/15 66/7 67/10 68/25
70/17 71/8 75/10 75/15 75/17 81/7
81/10 81/13 82/3 82/4 82/10 82/16
83/12 83/17 84/10 84/24 85/11 86/24
86/25 87/4 90/7 92/6 93/17 94/15 94/20
95/19 99/13 103/14 105/15 107/9 108/4
108/5 108/6 108/8 112/16 113/6 113/16
114/2 115/13 116/11 116/15 117/7
117/24 119/15 119/17 119/18 119/21
119/22 120/14 120/17 121/6 124/7
124/15 124/16 124/24 125/13 125/22
126/3 126/4 126/17 126/20 127/6 127/8
128/4 131/2 131/5 132/23 133/14
139/16 142/6 146/7 146/17 146/20
146/23 146/24 148/6 148/13 148/19
148/22 149/2 149/14 149/14 150/15
150/23 151/1 151/2 151/4 151/10
151/15 151/15 153/13 153/15
those [69] 9/23 13/1 13/14 13/15 14/8
14/14 18/21 18/23 19/21 19/21 22/10
24/23 25/2 26/17 27/5 28/21 32/8 33/20
33/24 34/5 34/22 34/23 37/9 37/19
37/20 39/17 39/21 40/18 46/3 46/9
50/14 53/23 54/1 58/19 76/7 76/12
80/11 80/19 81/4 83/16 84/11 85/23
85/23 86/11 86/13 87/12 91/12 92/23
95/8 101/4 104/22 105/7 105/8 105/11
106/11 106/11 117/25 120/4 123/1
126/24 126/25 127/18 129/1 141/20
144/8 144/10 146/13 151/7 151/8
though [10] 24/8 25/15 34/16 53/13 70/1
72/14 96/23 100/14 103/14 146/4
thought [5] 36/20 83/4 84/20 103/8
151/9
thoughts [1] 151/10
Thousand [3] 41/17 41/20 42/8
thousands [4] 12/20 16/7 23/13 81/15
three [18] 7/18 9/24 21/14 33/10 35/4
62/8 76/1 80/6 80/15 84/4 86/4 102/8
112/5 129/1 129/2 151/1 153/7 153/17
three-county [1] 21/14
through [19] 12/1 22/14 28/14 28/14
30/8 54/9 55/14 55/24 81/12 82/17
83/20 85/11 86/20 87/5 93/13 121/22
149/19 151/9 152/14
through 2010 [1] 121/22
throw [1] 151/1
thrown [2] 9/14 153/14
thru [1] 1/7

truth [1] 91/23
T
Truthfully [1] 100/20
thus [1] 95/14
try [8] 55/5 56/1 73/11 104/18 104/22
till [1] 68/19
105/1 105/14 108/21
time [77] 5/5 5/6 10/8 14/21 23/4 23/7
trying [9] 16/3 32/19 32/20 34/24 45/3
30/15 30/18 42/11 42/14 42/24 43/2
54/13 62/21 65/4 90/24
43/7 43/18 46/3 48/14 53/25 54/6 55/10 TSA [1] 57/10
Tuesday [3] 140/9 140/13 140/18
55/12 55/14 58/9 58/18 59/18 59/20
turn [24] 17/16 20/12 21/22 34/9 40/19
61/1 61/16 63/17 64/9 65/12 65/14
66/25 66/25 67/18 67/20 67/22 67/25
47/19 60/23 70/21 72/17 72/22 76/5
68/13 68/19 68/23 68/25 69/1 75/5
76/6 102/4 104/10 106/16 108/13
75/15 81/19 86/18 87/22 90/7 95/16
108/14 109/24 120/7 134/18 139/25
100/17 100/19 103/14 103/21 107/11
142/25 143/2 153/10
turned [4] 88/12 104/14 108/8 109/12
107/19 107/24 108/4 108/23 110/13
turnout [28] 11/6 11/10 14/10 14/12
110/16 111/18 111/20 112/11 112/16
113/23 114/14 116/7 116/8 116/11
16/5 16/15 16/20 16/23 17/6 17/8 17/12
116/15 117/7 128/4 131/10 131/16
18/2 20/1 20/2 20/4 24/19 24/23 25/3
142/5 144/9 144/22
26/16 26/17 32/5 33/7 33/21 39/20 43/9
timeframe [2] 5/20 150/4
43/17 48/10 48/12
times [10] 47/3 47/10 65/6 83/5 103/3
TV [2] 83/15 120/7
twice [1] 104/20
104/9 104/18 104/21 117/19 119/1
tired [1] 100/20
two [37] 5/4 5/11 7/14 7/24 9/7 9/17
titled [1] 154/5
18/21 19/19 46/9 46/22 47/20 52/13
to 2008 [1] 16/21
54/25 63/13 65/17 76/4 86/3 86/12
today [10] 6/9 23/14 25/17 34/16 34/20 86/23 96/12 100/25 119/23 119/24
35/18 43/20 57/19 71/10 124/7
120/19 123/13 125/12 129/15 135/17
told [10] 16/14 24/15 55/1 55/25 57/14
136/6 139/16 139/21 142/7 144/4 144/8
71/22 74/8 92/25 104/14 115/13
145/7 152/23 153/11
tomorrow [3] 148/21 149/22 153/18
two-fold [1] 136/6
too [8] 8/8 66/12 66/12 67/11 67/15
two-page [1] 76/4
two-pronged [1] 86/23
72/16 107/15 136/8
took [11] 64/9 67/11 67/14 68/13 71/20 type [3] 58/16 144/12 144/14
types [9] 6/20 11/23 13/16 15/8 23/14
84/14 86/23 99/5 100/3 100/3 137/11
topic [4] 16/14 29/8 38/2 38/2
23/24 28/18 50/8 143/18
toss [1] 60/1
typically [1] 46/24
toss-up [1] 60/1
U
total [1] 21/16
U.S [6] 2/5 3/17 12/14 13/13 75/25
totality [1] 23/4
totally [1] 80/7
133/19
UGA [1] 51/16
touch [1] 107/6
uh [11] 64/5 69/10 69/23 71/6 71/25
towards [1] 127/8
town [1] 98/25
75/9 133/12 134/21 138/10 140/5
trade [3] 72/5 73/17 91/21
141/24
uh-huh [9] 64/5 69/10 71/6 71/25 75/9
traditional [1] 26/15
train [2] 99/5 99/8
133/12 134/21 138/10 140/5
ultimately [1] 107/8
training [16] 123/22 125/15 125/19
under [25] 13/2 14/13 16/12 32/3 32/6
125/19 125/23 125/24 125/25 126/2
44/25 45/13 46/10 47/9 47/13 47/22
126/8 126/11 126/22 131/11 137/7
47/25 53/21 59/7 59/9 67/24 109/23
137/11 137/11 152/15
transcript [6] 1/10 3/24 123/20 123/21
117/25 118/15 131/8 131/23 135/6
135/15 147/17 147/20
130/12 154/4
under-65 [1] 47/13
transcription [1] 3/24
underlying [1] 8/21
transcripts [3] 128/25 129/12 129/22
understand [18] 10/20 11/3 13/17 22/13
translate [2] 33/6 142/23
transpired [2] 148/9 148/10
36/7 37/21 59/8 59/12 59/16 60/17 93/6
transport [1] 106/15
107/1 109/6 118/14 121/11 139/16
transportation [7] 24/23 25/7 26/14
139/17 150/1
understanding [17] 49/4 49/8 49/22
37/10 57/23 110/20 114/25
travel [1] 84/19
49/23 55/23 58/13 58/15 72/8 107/19
traveling [1] 66/13
107/24 118/6 118/11 118/20 118/24
treat [5] 13/22 14/3 38/22 50/10 92/4
119/5 121/9 129/24
understood [4] 59/10 82/9 108/2 150/11
treated [11] 13/11 13/13 13/18 14/9
undertaken [3] 27/23 27/24 29/3
14/14 14/17 15/8 15/11 15/19 81/15
uniform [6] 126/12 127/11 127/19
92/4
Trey [2] 134/11 139/22
127/22 131/19 132/3
uniformed [1] 126/15
trial [9] 1/10 5/7 5/21 57/1 81/3 124/1
Union [3] 2/16 2/20 3/1
148/8 149/3 151/15
unit [15] 36/16 37/5 37/7 78/25 79/3
tried [12] 33/4 45/20 54/6 54/8 54/9
79/5 79/13 79/20 80/3 80/16 82/19
55/20 104/5 104/20 106/12 108/22
83/16 85/25 89/11 97/7
111/25 136/11
Unit and [1] 89/11
trip [4] 83/2 97/12 111/11 111/15
Unit's [2] 79/4 79/19
trouble [1] 120/3
UNITED [9] 1/1 1/6 5/3 7/11 8/16 97/17
true [7] 7/17 9/6 51/4 133/7 134/14
115/21 122/14 145/6
137/8 149/13

175
universities [3] 51/4 51/8 51/14
university [2] 51/15 51/16
unless [6] 49/17 52/4 61/20 120/5 145/5
150/9
unlikely [2] 127/11 143/14
unquote [1] 121/14
unreliable [1] 8/10
until [1] 138/5
up [40] 12/2 16/24 17/9 17/21 20/15
23/7 23/10 32/10 32/17 37/19 43/24
49/11 52/19 60/1 69/2 75/18 76/25
82/23 83/3 87/11 98/5 98/7 106/23
111/6 113/4 115/25 116/24 119/14
122/21 124/5 129/21 143/8 143/14
143/16 144/10 145/7 145/17 146/17
149/25 151/24
upcoming [1] 120/6
upon [4] 82/20 86/25 90/4 96/18
us [31] 23/8 23/12 32/17 42/2 42/5 44/2
49/20 61/12 66/22 76/15 92/18 92/24
92/25 98/18 98/22 98/24 98/24 99/20
99/22 101/20 101/23 104/8 107/9
109/19 119/21 128/11 146/9 147/11
150/14 150/24 153/18
use [6] 37/24 51/15 73/3 109/4 119/8
145/14
used [15] 9/21 9/22 21/10 38/12 41/18
42/1 44/6 44/11 48/19 48/20 74/15
120/23 139/11 141/2 143/16
uses [1] 11/20
using [2] 11/1 38/11
usually [3] 78/11 111/18 137/23
utilized [1] 120/6

V
VA [5] 100/14 105/6 105/8 105/20
105/23
valid [9] 13/13 38/12 38/23 38/25 39/1
51/14 57/7 57/20 59/2
variables [2] 144/15 144/20
variation [3] 133/23 134/7 141/9
variations [1] 141/9
Vehicles [4] 13/10 82/17 104/9 112/2
VELANDY [2] 2/3 6/19
verifying [1] 93/1
version [1] 41/17
versus [4] 5/3 5/4 8/15 28/24
very [45] 6/17 6/25 7/9 10/8 14/22 25/2
32/12 35/25 42/2 65/3 66/6 75/13 78/17
79/14 79/16 81/1 84/16 84/16 87/4 87/5
87/5 88/1 88/2 91/23 97/13 97/18 98/3
124/16 126/5 126/11 128/3 131/10
133/19 136/21 139/14 142/11 143/14
143/15 144/19 146/16 146/21 150/11
152/3 153/7 153/20
Vicodin [1] 67/4
Victory [1] 79/1
video [8] 69/20 69/24 70/2 70/3 70/4
70/5 70/6 123/22
Vietnam [1] 100/6
view [8] 25/16 26/9 26/21 43/20 147/14
151/18 152/20 153/6
viewed [1] 152/4
views [7] 124/15 126/24 127/25 128/2
128/7 128/12 153/7
vigilant [1] 82/4
Visa [2] 85/7 86/7
vital [8] 55/7 84/23 84/24 85/1 85/1 85/4
85/6 86/20
vocational [1] 61/14
volunteer [1] 87/22
volunteering [1] 88/2
vote [63] 15/5 37/23 39/7 39/9 39/12
39/14 39/18 40/19 47/23 58/5 58/5 60/9

V
vote... [51] 64/7 64/9 67/16 67/17 68/3
68/15 70/19 72/19 72/23 72/25 73/18
74/8 80/11 81/3 81/5 82/3 89/25 96/3
96/15 99/15 106/19 106/24 107/2
107/11 107/17 107/20 108/1 108/12
108/15 108/17 109/4 109/11 109/21
109/22 109/24 109/25 110/3 110/7
113/9 113/19 114/2 119/10 120/16
121/2 133/9 138/24 141/17 143/7
143/21 143/24 152/6
voted [9] 21/20 58/2 58/7 64/9 68/9
68/11 109/7 138/5 139/4
voter [109] 9/8 9/17 11/4 14/24 16/17
19/25 20/6 26/16 26/17 38/14 40/18
41/12 42/16 43/4 43/8 44/21 47/18
47/23 47/25 48/10 48/12 49/10 49/11
50/17 53/13 60/12 60/13 60/17 66/3
66/18 67/6 69/5 69/25 70/9 71/11 71/19
72/2 72/5 72/17 72/21 73/11 80/24
80/24 81/2 81/13 82/3 89/6 89/17 90/2
91/6 91/8 91/15 91/19 91/20 91/20
91/25 93/2 93/3 93/19 93/21 93/22
94/10 94/13 94/14 94/16 95/3 95/4 95/8
95/13 95/14 95/15 95/18 95/19 95/21
95/25 96/2 96/9 96/17 96/21 107/22
108/9 108/19 109/4 112/10 113/9 114/7
115/14 118/4 118/16 118/18 119/3
121/7 124/21 125/10 126/23 132/23
133/1 134/19 136/7 136/16 136/21
136/25 137/2 138/24 144/17 145/12
146/8 150/9 152/5
voter's [1] 136/15
voters [43] 10/4 10/4 12/21 13/1 13/11
16/20 18/5 21/1 21/15 21/19 22/1 22/3
23/21 27/23 44/20 44/23 66/10 73/2
89/4 89/11 118/6 118/22 119/2 119/24
119/25 121/25 125/2 125/3 125/5 125/6
130/22 135/9 135/11 136/9 136/12
136/24 140/4 142/11 143/21 144/5
145/23 146/3 152/16
voting [29] 2/6 8/6 8/9 9/7 14/24 20/9
20/19 21/10 22/4 50/6 58/11 58/20 60/3
60/7 68/3 68/5 69/1 69/2 74/10 81/5
89/4 94/17 109/14 119/9 121/13 130/19
133/10 141/12 142/12

W
wait [3] 61/19 68/19 111/23
waiting [1] 112/3
Wal [2] 84/4 84/4
Wal-Mart [2] 84/4 84/4
walk [3] 102/6 110/12 151/9
walking [2] 85/19 110/15
wallet [1] 104/12
want [27] 5/15 5/16 7/10 22/13 26/6
31/5 43/11 52/5 62/22 64/11 65/3 74/20
82/5 91/7 91/16 92/20 93/2 93/3 96/8
109/11 136/20 142/1 148/9 148/16
152/7 152/21 153/16
wanted [9] 33/7 71/10 75/25 83/5 87/3
87/4 107/16 108/14 136/2
wants [1] 94/15
war [1] 109/12
was [236]
Washington [9] 1/4 1/18 2/7 3/3 3/6 3/14
3/18 56/25 99/3
wasn't [7] 11/10 13/3 39/22 81/20
107/13 107/21 110/4
waterfront [1] 150/13
way [22] 16/6 36/4 45/10 47/22 47/25
49/3 60/24 63/20 68/23 81/5 84/24 87/6
99/13 102/20 110/2 115/12 122/21

127/4 139/4 141/6 146/24 150/19
ways [1] 138/1
we [177]
we'd [1] 46/20
we'll [9] 6/23 55/16 76/12 76/18 93/10
119/14 149/12 153/22 153/22
we're [18] 6/11 15/17 15/18 20/15 24/25
26/24 30/23 35/3 52/4 93/9 97/2 120/3
134/6 137/25 139/15 142/20 146/2
153/11
we've [8] 41/5 46/13 80/19 148/11
151/16 151/17 151/19 151/20
website [1] 51/12
week [7] 57/5 57/9 102/9 102/13 102/15
115/6 122/23
weeks [4] 100/12 123/13 126/19 153/17
weight [2] 138/2 141/6
weighting [2] 143/15 143/19
well [81] 6/5 8/16 10/6 10/19 11/1 11/7
11/10 13/15 14/5 14/15 14/22 16/9
18/18 19/16 20/2 21/6 23/6 23/9 24/11
24/14 24/15 24/24 25/11 25/22 26/11
26/12 26/23 27/4 28/11 29/13 30/3
30/18 31/12 31/25 32/20 33/2 33/23
34/8 35/1 35/22 38/11 38/24 39/8 39/16
40/7 43/22 46/15 48/20 49/9 51/6 55/5
61/13 65/10 79/3 79/20 82/24 83/25
84/13 86/15 88/19 91/22 92/24 93/22
94/9 94/21 115/4 123/23 126/3 126/12
129/5 129/17 138/5 139/17 141/9
142/19 143/11 144/13 144/15 146/17
146/21 151/9
went [21] 16/21 16/24 16/25 17/9 43/16
46/5 46/21 54/14 54/25 55/20 57/9
61/14 71/17 82/17 82/22 83/20 85/4
92/6 104/13 112/2 114/5
were [129] 5/12 6/1 11/13 12/10 14/6
14/8 15/8 15/10 15/11 15/12 15/22 16/2
17/4 17/23 18/23 19/9 19/21 20/23
21/16 22/10 24/5 27/23 29/14 29/17
30/12 34/14 34/22 36/10 36/21 37/2
39/8 39/9 39/18 41/7 41/12 46/9 47/3
47/19 48/22 49/10 50/2 50/4 50/8 50/14
51/3 53/11 57/3 57/8 57/15 57/19 59/21
67/21 67/25 68/6 71/8 72/23 74/8 76/5
76/12 76/14 77/16 81/12 81/18 81/21
81/25 82/8 82/25 83/7 83/11 83/14
83/21 84/11 85/9 85/13 85/23 86/4 86/9
86/10 86/12 87/24 92/5 92/6 92/7 92/8
92/10 92/12 92/25 99/16 103/8 105/11
105/14 107/11 108/5 108/16 110/16
114/10 116/2 121/16 125/2 125/5
128/15 128/15 129/14 129/15 135/16
136/4 136/5 136/24 137/5 137/10
137/10 139/12 140/16 140/17 140/21
140/23 140/25 141/16 142/17 142/18
142/22 143/6 144/14 145/21 145/22
147/12 148/13 148/14 151/5
weren't [5] 13/15 21/21 92/9 105/13
108/23
West [1] 67/21
what [146] 5/19 5/20 9/3 9/12 10/24 11/7
11/9 13/8 16/3 16/9 17/4 18/3 20/20
21/17 24/13 28/1 28/3 30/14 31/5 31/19
32/17 32/18 32/23 33/12 34/24 35/20
36/20 37/21 40/8 40/9 41/18 41/21
41/22 42/1 42/3 42/5 43/19 44/15 45/3
45/4 45/5 45/12 46/6 46/8 46/19 50/2
54/20 54/24 55/9 55/22 56/4 57/14
57/14 58/13 59/9 59/13 61/9 61/17 62/3
65/2 66/22 66/23 67/5 67/7 68/20 70/2
70/7 70/15 72/20 72/24 73/1 74/1 75/5
75/5 77/10 77/24 79/4 80/1 87/13 87/14
92/12 93/5 96/5 97/3 98/25 98/25 99/20

176
100/9 101/17 101/20 101/23 102/11
103/25 105/1 105/6 106/25 107/3
107/19 107/19 108/4 108/16 108/17
109/5 112/7 113/24 119/21 119/22
120/17 120/19 123/17 124/15 125/14
125/21 126/1 126/6 126/7 127/7 128/11
128/12 128/25 129/5 132/18 142/1
142/20 142/24 143/5 144/11 145/12
145/16 145/18 146/1 146/2 146/23
147/2 147/8 148/9 148/10 149/8 149/20
149/20 150/23 151/22 152/2 152/8
153/5 153/11
what's [2] 48/20 124/14
whatever [8] 22/18 22/19 22/21 23/25
25/9 35/23 36/8 82/21
whatsoever [1] 110/22
when [65] 14/10 14/11 16/1 16/5 16/9
18/7 21/9 30/12 31/13 31/23 32/21 39/2
46/5 46/16 46/21 47/8 55/8 58/1 59/16
64/13 65/9 65/12 65/23 67/5 68/3 68/4
70/23 70/25 71/18 71/18 80/18 81/10
82/15 83/2 84/17 92/11 93/1 94/1 95/6
99/18 100/15 103/21 104/2 104/10
104/11 106/12 106/16 107/3 108/5
109/10 109/17 110/16 111/17 111/25
112/2 114/10 114/19 114/21 135/6
135/15 136/7 142/17 149/12 150/17
150/24
where [45] 25/25 53/7 53/11 54/14
61/23 62/13 65/22 66/9 66/20 66/21
67/11 67/14 68/2 69/5 70/18 71/11
71/19 71/20 71/24 71/25 77/12 77/16
85/14 85/14 98/18 98/24 99/9 99/16
101/1 101/4 101/15 102/16 102/20
105/17 106/7 108/11 110/6 110/10
118/4 118/18 119/3 126/5 127/2 128/16
133/21
wherein [7] 78/11 79/21 80/4 80/10
80/13 81/19 85/16
wherever [1] 111/5
wherewithal [1] 85/21
whether [42] 5/16 12/25 12/25 13/15
17/23 24/5 24/6 25/17 27/21 34/16
36/11 36/15 39/6 39/14 40/13 40/21
44/20 45/6 46/12 46/23 47/2 51/18
63/21 70/17 71/8 95/2 114/14 116/2
120/15 124/8 126/21 131/18 132/1
132/2 134/6 136/8 142/10 143/8 147/15
148/23 149/9 149/22
which [36] 5/5 5/13 9/8 9/15 9/25 12/1
12/14 14/6 17/20 21/9 21/25 25/20
25/24 32/19 34/5 37/24 41/9 42/2 42/9
46/9 51/13 54/1 79/6 79/16 92/5 103/23
117/23 124/18 125/19 137/4 138/13
141/5 144/12 146/21 151/11 153/10
while [4] 8/12 100/3 122/21 144/16
white [12] 10/4 22/2 23/21 37/14 47/4
110/4 119/2 121/13 121/25 125/3 125/6
146/6
whites [12] 21/12 27/14 27/18 28/11
117/19 119/8 119/10 120/16 121/1
121/3 147/6 147/7
Whitmire [6] 123/20 128/16 128/16
128/19 128/22 129/15
Whitmire's [1] 128/18
who [91] 11/16 12/7 12/21 13/11 13/19
13/22 14/3 14/3 14/10 14/12 14/12
14/17 14/20 14/24 15/7 15/13 15/19
16/8 16/20 17/1 18/7 23/13 23/24 27/14
27/23 28/18 38/18 38/19 39/2 39/11
39/23 40/3 40/15 40/19 40/24 43/9
44/23 52/12 56/19 70/5 78/6 79/15
79/23 80/7 80/8 81/3 81/21 81/22 81/22
82/9 82/25 83/11 83/20 85/24 86/9 86/9

177

worthwhile [1] 109/14
W
would [201]
who... [35] 88/1 88/23 91/24 95/7 109/11 wouldn't [5] 24/24 72/25 87/2 135/12
116/20 117/25 125/24 125/25 128/20
136/9
write [5] 59/11 59/11 68/21 92/19 93/1
130/8 135/9 135/10 135/14 135/14
writing [1] 30/20
135/16 135/17 135/18 135/20 136/24
written [10] 91/13 116/21 117/5 117/6
137/10 137/11 137/25 143/6 143/12
143/13 143/14 143/21 145/21 145/22
117/18 117/23 121/11 121/23 122/22
145/22 145/23 146/3 150/4 151/15
124/19
whoever [1] 91/23
wrong [2] 66/16 142/15
whole [4] 16/24 43/12 137/24 152/10
wrote [4] 22/18 22/22 22/23 87/7
whom [2] 80/20 81/16
X
why [25] 16/23 16/25 19/4 21/9 26/21
27/3 46/2 54/9 60/6 71/10 75/17 76/17 x113 [1] 3/4
86/15 92/14 94/19 99/13 100/5 100/17
Y
100/19 100/22 107/1 107/14 109/9
yard [1] 116/5
109/22 124/13
wide [2] 134/7 145/19
yeah [10] 21/8 35/2 42/22 64/15 67/7
widely [1] 141/2
68/14 72/8 105/10 138/22 142/3
WILIAMS [1] 4/12
year [8] 55/13 55/13 67/5 67/7 75/5
will [35] 6/7 6/8 7/9 10/4 19/6 23/25
92/12 104/20 114/2
years [24] 58/15 62/15 77/15 78/2 79/17
24/15 32/4 33/20 35/17 52/8 52/12
52/17 60/12 80/18 91/6 93/20 94/17
79/25 80/15 81/6 81/14 81/19 81/22
96/22 98/1 101/25 101/25 112/11
84/4 90/1 90/1 92/4 92/16 92/23 100/12
114/22 119/3 121/8 121/17 127/12
103/22 104/21 107/17 109/10 110/17
130/9 134/14 148/6 148/24 148/24
110/19
yes [245]
149/16 149/18
Williams [16] 75/16 76/23 76/24 77/3
yesterday [23] 6/19 8/2 10/6 12/14 16/14
77/9 84/25 86/18 90/7 90/14 90/23
23/11 23/20 24/5 24/18 25/12 31/7
92/19 94/1 94/12 96/12 97/11 97/16
31/23 33/4 38/2 43/12 43/25 44/6 44/10
Williams' [1] 94/4
44/11 47/2 47/20 49/22 128/25
willing [2] 138/22 152/14
yet [1] 45/15
WILSON [1] 1/22
York [10] 2/14 3/10 3/13 67/18 67/23
wind [1] 111/6
68/1 68/4 68/5 75/4 86/11
Wisconsin [7] 8/14 9/11 20/6 20/8 20/9 you [836]
you'd [5] 55/23 76/25 98/7 110/6 116/24
20/17 20/18
you'll [1] 150/6
wish [2] 6/4 76/15
you're [40] 12/2 25/14 31/16 32/5 32/17
wished [1] 148/1
wishes [1] 145/5
32/18 32/23 33/10 34/17 36/2 36/21
withdrawn [4] 11/15 14/11 20/3 61/21
44/3 45/3 45/4 49/18 52/4 62/21 70/16
within [1] 141/8
72/1 79/8 91/8 96/5 97/19 113/24
without [25] 17/6 18/13 19/11 28/11
114/11 116/10 128/17 132/4 132/23
132/25 133/1 134/13 134/16 138/21
28/12 28/21 47/23 48/1 49/11 56/21
139/14 139/23 142/4 144/1 147/23
57/3 57/6 57/14 57/20 63/20 88/16
88/16 94/18 98/18 98/22 124/25 127/10 150/17
you've [18] 7/14 7/18 9/8 9/16 9/24 10/1
138/24 150/7 152/17
witness [25] 7/3 8/3 8/15 8/20 9/8 9/16
12/5 22/14 29/21 30/15 54/9 73/11
75/13 90/23 96/20 117/23 123/17
9/17 50/25 52/16 52/22 61/1 70/12
127/16
75/11 75/25 77/4 90/8 90/19 97/23
your [242]
98/10 116/17 116/18 117/3 117/10
your 2012 [1] 134/18
122/20 123/7
yourself [1] 69/20
witnesses [3] 4/2 52/13 88/9
YouTube [4] 69/20 69/21 69/22 70/1
Wolf [1] 83/18
won't [1] 34/1
Z
word [3] 19/2 36/5 92/6
zero [1] 26/5
Words [3] 41/17 41/20 42/8
work [26] 22/13 51/15 58/18 65/1 71/18
78/3 78/16 80/23 80/25 90/23 101/15
101/16 101/21 101/23 102/4 102/5
102/9 111/21 112/12 115/3 115/5 131/2
131/5 137/6 137/17 152/19
work-in-progress [1] 152/19
work-related [1] 58/18
worked [1] 89/23
worker [5] 125/19 125/23 126/2 126/7
126/11
workers [12] 125/16 125/23 125/25
126/5 130/24 131/3 131/6 137/7 147/15
147/17 147/18 147/19
working [5] 84/4 102/3 102/14 102/16
115/3
works [2] 64/25 84/3
world [3] 35/24 36/1 94/15
Worth [3] 41/17 41/20 42/8

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