IN THE UNITED STATES DISTRICT COURT

FOR THE MIDDLE DISTRICT OF NORTH CAROLINA

DEMOCRACY NORTH CAROLINA, THE

LEAGUE OF WOMEN VOTERS OF
NORTH CAROLINA, DONNA PERMAR,
JOHN P. CLARK, MARGARET B. CATES,
LELIA BENTLEY, REGINA WHITNEY
EDWARDS, ROBERT K. PRIDDY II,
WALTER HUTCHINS, AND SUSAN
SCHAFFER.
Civil Action No. 20-cv-457
Plaintiffs,
vs.
THE NORTH CAROLINA STATE BOARD
OF ELECTIONS; DAMON CIRCOSTA, in
his official capacity as CHAIR OF THE
STATE BOARD OF ELECTIONS; STELLA
ANDERSON, in her official capacity as
SECRETARY OF THE STATE BOARD OF
ELECTIONS; KEN RAYMOND, in his
official capacity as MEMBER OF THE
STATE BOARD OF ELECTIONS; JEFF
CARMON III, in his official capacity as
MEMBER OF THE STATE BOARD OF
ELECTIONS; DAVID C. BLACK, in his
official capacity as MEMBER OF THE
STATE BOARD OF ELECTIONS; THE
NORTH CAROLINA DEPARTMENT OF
TRANSPORTATION; J. ERIC BOYETTE,
in his official capacity as
TRANSPORTATION SECRETARY; THE
NORTH CAROLINA DEPARTMENT OF
HEALTH AND HUMAN SERVICES;
MANDY COHEN, in her official capacity as
SECRETARY OF HEALTH AND HUMAN
SERVICES,

Defendants.

DECLARATION OF MARGARET B. CATES IN SUPPORT OF PLAINTIFFS’

MOTION FOR PRELIMINARY INJUNCTION

Case 1:20-cv-00457-WO-JLW Document 11-5 Filed 06/05/20 Page 1 of 4

 I, Margaret B. Cates, hereby declare as follows :

1. I am a U.S. citizen and a resident of the Town ofFaison in Duplin County, North

Carolina.

2. I am 85 years old. I taught piano for a living but have since retired.

3. I am a registered North Carolina voter who is eligible to vote in the November

2020 general election.

4. I have had chronic fatigue syndrome for the last 27 years since 1993. When I

first came down with it, I was totally bedridden. Gradually, over a period of a

few years, I was able to get up, dress and function somewhat. I could go out but

not very far. I also could go to my children' s house but not often. I would have

some recovery periods but then crashes. I was able to rehabilitate to about half

my original function. Right now, I am not in good health. I have had several falls

and have had a urinary tract infection coming and going for this past year which

has been very debilitating. As a result, I have been pretty weak and have been

using a walker in the house. I have not been able to function in a normal way. I

am in bed twelve hours at night a nd two in the afternoon. I seldom get up and

get dressed. There is no treatment for this syndrome.

5. I have also psoriasis and am being treated for that, and I also have had cancer

though it is not active now though.

6. For the last six months, after the tlu·ee falls and infection, I have had someone

who comes over to the house for a couple hours every day except Sunday to help

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 with household chores, like cleaning, getting food , and doing laundry. She goes

for grocery shopping and occasionally cooks. Since the coronavirus pandemic

started, we have been following social distancing, and wc stay far apart. I have

not left the house in 3 months, except to go to a doctor's appointment right before

March began and before the social distancing guidelines were put in place. She

only goes out to go to the grocery store for me and her family. She is very

cautious, wears a mask, and keeps her distance. I could not live in this home by

myself without her help.

7. I have voted in every presidential election since the 1956 presidential election.

I also vote in many state and local elections.

8. I want to vote in the November 2020 general election. I do not have a computer

or printer. I do have a tablet and a smart phone. I have never voted by mail, but

from what I understand there is no way for me to request an absentee ballot

online. If this option were available, I could (with some assistance) and would

request a ballot that way. I could also request one by phone call. I have not yet

requested an absentee ballot for the November election.

9. My nearest family member is my son, who lives a two-hours ' drive away in

Southern Pines, North Carolina. Without an online or phone option to request an

absentee ballot, I would not be able to request an absentee ballot on my own and

would depend on others to mail or otherwise provide it to me.

I O.Ifl were able to get an absentee ballot, I understand there is a requirement that I

either get two witnesses or a notary public for it to be counted. My assistant who

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 comes to the house to help with daily tasks could serve as one witness for my

absentee ballot, but I would be taking a risk in getting a second witness for the

ballot. Given my poor health and debilitated state, I would have to ask someone

to come into my house to serve as a second witness , and no one has been here

besides my assistant. I am reluctant to ask someone to come in because of the

coronavirus. Each additional person I interact with poses a risk to my life. I will

not be able to get a second witness without breaking the social distancing rules

that T am following to protect my health .

11 . Voting in person is not an option for me, and I believe it would pose too much

of a risk to me. Given the current rules for voting by mail , I am unable to figure

out how I will safely cast a ballot by mail in the upcoming election.

I declare under penalty of perjury under the laws of the United States of America

that the foregoing is true and correct to the best of my knowledge.

Executed this ~O ofMay, 2020.

Isl
Margaret B) Cates

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