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 REGINA WHITNEY EDWARDS IN SUPPORT OF

PLAINTIFFS’ MOTION FOR PRELIMINARY INJUNCTION

Case 1:20-cv-00457-WO-JLW Document 11-7 Filed 06/05/20 Page 1 of 4

I, Regina Whitney Edwards, hereby declare as follows:

1. I am a U.S. citizen and a resident of Durham County, North Carolina. My

address is 3231 Sparger Road, Durham, North Carolina 27705. I live in a single-

family home with my partner.

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

2020 General Election.

3. I am 30 years old.

4. I am a Program Manager at the Duke Human Vaccine Institute. My

responsibilities include managing grants, including awards from the National

Institutes of Health, and overseeing a training and mentorship program for

students and researchers who are affiliated with the Institute. Because

immunologists and vaccine specialists at the Institute are actively working on

COVID-19, I am familiar with the health risks posed by COVID-19. I am also

an advocate for the American Diabetes Association.

5. I learned from the website of the Centers for Disease Control that I am at very

high risk of developing severe illness from the novel coronavirus because I have

a serious pre-existing medical condition, type 1 diabetes. I have had type 1

diabetes for 21 years.

6. Numerous medical professionals with whom I work at the Institute have warned

me about the impact of COVID-19 on high-risk individuals like myself. To

protect my health, I have remained at home since mid-March and have not seen

Case 1:20-cv-00457-WO-JLW Document 11-7 Filed 06/05/20 Page 2 of 4

 another person other than my partner. I work from home and avoid public

spaces. I rely on my partner to shop for groceries and run other errands. In light

of the advice of the medical professionals with whom I work, I am

uncomfortable leaving my home or being in close proximity to people other than

my partner.

7. Because of the nature of my work for the Duke Human Vaccine Institute and my

advocacy with the American Diabetes Association, I understand that these

measures are necessary to safeguard my physical wellbeing in light of the

COVID-19 pandemic.

8. I have voted in multiple elections in North Carolina, including the most recent

primary election in March 2020. I almost always vote in person. But for the

threat of COVID-19, I would vote in the 2020 General Election in person.

9. Because of the pandemic and the health risks posed by in-person voting, I am

not willing to vote in person during the 2020 General Election.

10. To protect my health, I would like to vote by mail-in absentee ballot. But I

cannot safely comply with North Carolina's two-witness requirement. Although

my partner is available to serve as the first witness, I am not willing to jeopardize

my physical wellbeing by asking another person to serve as the second witness.

11. The two-witness requirement thus forces me to choose between my health and

my right to vote.

12. Although I strongly wish to vote in this election, I will not do so if the two-

witness requirement remains in effect.

Case 1:20-cv-00457-WO-JLW Document 11-7 Filed 06/05/20 Page 3 of 4

 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 ~day of May, 2020.

Regina Whitney Edwards

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