Case 1:13-cv-01218-CMH-TRJ Document 31-1 Filed 10/17/13 Page 1 of 4 PageID# 329

EXHIBIT A

Case 1:13-cv-01218-CMH-TRJ Document 31-1 Filed 10/17/13 Page 2 of 4 PageID# 330

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF VIRGINIA ALEXANDRIA DIVISlON

THE DEMOCRATIC PARTY OF VIRGINIA, Plaintiff,
)

v.

) VIRGINIA STATE BOARD OF ELECTIONS; CHARLES JUDD, in his ) capacity as Chalnnau. of the Virginia State ) Board of Elections; KIMBERI,Y BOWERS,) in her capacity as Vice-Chair of the Virginia ) State Board of Elections; DON PALMER, in) his capacity as Secretary of the Virginia State) Board of Elections; ROBERT F. ) MCDONNELL, in his capacity as Governor ) of Virginia; and KENNETH T. ) CUCCINELLI, II, in his capacity as ) AttorneY General of Virginia, )

l
)
)

Civil Action No. 113-cv-01218-CMH-TRJ

Defendants.

DECLARATION OF JERYLE A, JONES

I, Jeryie A. Jones, state that I have personal knowledge of the matters set forth in this Declaration and, if sworn as a witness, would testifY as follows:
l.

I am 47 years of age and reside at 8309 Turner Forest Road, Henrico,

Virginia with my wife Carla of26 years. We have two adult children. 1 registered to vote in the Commonwealth of Virginia in October 2004 and have voted in every election since then. 2. I served active duty in the United States Army for 23 years. I was

deployed to Saudi Arabia in 1990, and Iraq from 2003 to 2004. 3.

In 2002, I received orders to be stationed at Fort Campbell, Kentucky. My

rank was Sargent First Class then. Upon receiving the orders, my wife and I moved to Fort Campbell, Kentucky where I served as a Platoon Sergeant.

10

39\ld

S3NOf

90TP6SPP08

gp:s0

E006/S0/T0

Case 1:13-cv-01218-CMH-TRJ Document 31-1 Filed 10/17/13 Page 3 of 4 PageID# 331

4.

We stayed in Kentucky until October 2004, when I received permanent

change of station orders to relocate to Fort Lee, Virginia. Upon arriving in Fort Lee, Virginia, I attained the rank of first Sargent. 1 was a First Sergeant at Fort Lee until 2008, when I retired from the U.S. Army. 5. Upon retirement, I took a positions as a Department of the Army Civilian,

serving as the Executive Officer for the Army Logistics University, Fort Lee, Virginia, which is my position today. 6. On Saturday, September 28, 2013, both my wife and I received voter

cancellation notices from the Office of Voter Registration of the County oflfeurico. The notice informed us that we were no longer entitled to be registered to vote in the Commonwealth of Virginia. 7. We were surprised to receive them since we have lived, paid taxes, and

voted in Virginia since arriving here in 2004. For 8 years, from 2004 2012, my wife and I lived in Prince George's County. Last year, we moved into a home we built in Henrico, Virginia. Even though we moved within Virginia, we have not lived outside of Virginia for the last 9 years, nor registered to vote anywhere else. 8. On Monday, September 30, 2013, I telephoned the Office of Voter

Registration of the Henrico County to ask why I was no longer entitled to vote in the Commonwealth of Virginia. I had registered to vote in 2004 and had voted in every election since then. 9. I was told by someone in the Office of Voter Registration that they ''didn't

know how" it happened but it had something to do with my registering to vote in

2-

S3N0f

gp:s0

E006/S0/T0

Case 1:13-cv-01218-CMH-TRJ Document 31-1 Filed 10/17/13 Page 4 of 4 PageID# 332

Kentucky. I told them that I lived in Kentucky over 9 years ago. They said they would fix it and I would be put back on the voter registration rolls. 10. I ftnally received my renewed voter registration card on October 9, 2013.

I am glad l received it but I don't understand why my voter registration was cancelled in the first place. 11. I served my cotmU:y active duty in the U.S. Army for 23 years. I have

lived in. paid taxes, and voted in every election in Virginia since I registered to vote here in 2004. I have a right to vote in Virginia. I shouldn't have been removed from the voter registration rolls and telling me they "didn't know how" it happened is not a good enough answer. 12. I declare under penalty ofpeJjury under 28 U.S. C. 1746 that the

foregoing is true and correct. Executed on October 10, 2013.

E0

39\ld

S3N0f

90TP6SPP08

gp:s0

E006/S0/T0