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 ROBERT K. PRIDDY II IN SUPPORT OF PLAINTIFFS’

MOTION FOR PRELIMINARY INJUNCTION

Case 1:20-cv-00457-WO-JLW Document 11-8 Filed 06/05/20 Page 1 of 3

I, Robert K. Priddy II, hereby declare as follows:

1. I am a U.S. citizen and a resident of Brunswick County, North Carolina. I live

at 2 Kings Grant Court, Shallotte, North Carolina 28470, with my wife.

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

2020 General Election.

3. I am 70 years old. Before I retired, I worked in nuclear safety.

4. My doctor has informed me that I am at very high risk of developing severe

illness from the novel coronavirus because I have several serious pre-existing

health conditions and because of my age . In 2010, I received a kidney

transplant. To ensure that my body does not reject the transplant, I take

medication that suppresses my immune system. The medication also causes

borderline diabetic issues, so I receive treatment for diabetes.

5. To protect my health, my doctor has advised me to stay home and avoid

contact with people outside my household. Accordingly, I have remained at

home since mid-March. I rely on my wife to shop for groceries and mn other

errands. The only time I have gone outside is to pick up prescriptions from a

drive-thru pharmacy, where I remain in my vehicle and do not directly interact

with the pharmacist. In light of my doctor's advice, I am uncomfortable

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

Case 1:20-cv-00457-WO-JLW Document 11-8 Filed 06/05/20 Page 2 of 3

 6. I have voted in numerous elections in North Carolina. Although I usually vote

in person, I have also voted by absentee ballot on occasion. But for the threat

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

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

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

8. I would like to vote by mail-in absentee ballot, but I cannot safely comply with

North Carolina's two-witness requirement. Although my wife is available to

serve as·the first witness, I am not sure whether I am willing to jeopardize my

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

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

my right to vote.

10. Although I strongly wish to vote, I do not expect the risks to my physical

health to abate in the months leading up to the election. As a result, if the two-

witness requirement remains in effect, I am not sure whether I will be able to

vote in the 2020 General 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// day of May, 2020.

Robert K. Priddy II

Case 1:20-cv-00457-WO-JLW Document 11-8 Filed 06/05/20 Page 3 of 3