Ballot Harvesting Injunction

Case 2:24-cv-00420-RDP Document 34 Filed 05/03/24 Page 1 of 5 FILED
2024 May-03 AM 09:52

U.S. DISTRICT COURT
N.D. OF ALABAMA
IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ALABAMA
SOUTHERN DIVISION
ALABAMA STATE CONFERENCE OF

THE NAACP, et al.,
Plaintiffs, Civil Action No. 24 Civ. 420

Chief Judge R. David Proctor
v.
HEARING REQUESTED
STEVE MARSHALL, in his official capacity
as Alabama Attorney General, et al.,
Defendants.
PLAINTIFFS’ MOTION FOR PRELIMINARY INJUNCTION
Pursuant to Federal Rule of Civil Procedure 65, and for the reasons stated in the
accompanying memorandum, declarations and exhibits, all pleadings filed, and any oral argument
or testimony to be presented to the Court, Plaintiffs Alabama State Conference of the NAACP,
League of Women Voters of Alabama, League of Women Voters of Alabama Education Fund,
Greater Birmingham Ministries, and Alabama Disabilities Advocacy Program (collectively,
“Plaintiffs”) respectfully move for the following preliminary injunctive relief:
(1) Enjoin Defendants, along with their respective agents, officers, employees, and
successors, from implementing or enforcing the following Challenged Provisions of Alabama
Senate Bill 1, Act No. 2024-33 (“SB 1”):1
a. Payment Provisions: SB 1 makes it “unlawful for a third party to knowingly
1See 2024 Alabama Laws Act 2024-33 (S.B. 1),

https://1.next.westlaw.com/Document/I193614D0E76211EEBDB185AF89C5BCF3/View/FullText.html?VR=3.0&
RS=cblt1.0&__lrTS=20240501162006477&transitionType=Default&contextData=%28sc.Default%29. Section 1 of
SB 1 amends Ala. Code Section 17-11-4, which governs absentee applications. Sections 2, 3, and 4 of SB 1 contain
other provisions. Hereinafter, citations to Section 1 of SB 1 will be denoted by “§ 17-11-4.” Citations to other sections
of SB 1 will be identified by section number.
Case 2:24-cv-00420-RDP Document 34 Filed 05/03/24 Page 2 of 5
receive a payment,” or “knowingly pay . . . a third party,” to “distribute, order,
request, collect, prefill, complete, obtain, or deliver a voter’s absentee ballot
application.” § 17-11-4(d)(1)-(d)(2). These provisions carry a Class B or C felony
penalty (Class C for assistors who “receive a payment” and Class B for those who
“pay” such assistor). Id.
b. Gift Provisions: SB 1 makes it “unlawful for a third party to knowingly receive
. . . a gift,” or “knowingly . . . provide a gift,” to a “third party” to “distribute,
order, request, collect, prefill, complete, obtain, or deliver a voter’s absentee
ballot application.” § 17-11-4(d)(1)-(d)(2). These provisions carry a Class B or C
felony penalty (Class C for assistors who “receive a . . . gift” and Class B for
those who “provide a gift” to such assistor). Id.
c. Prefilling Restriction: SB 1 makes it “unlawful for any person to knowingly
distribute an absentee ballot application to a voter that is prefilled with the voter’s
name or any other information required on the application form.” § 17-11-4(b)(2).
This provision carries a Class A misdemeanor penalty. SB 1 § 2.
d. Submission Restriction: SB 1 makes it “unlawful for an individual to submit a
completed absentee ballot application to the absentee election manager other than
his or her own application,” unless that person is seeking emergency medical
treatment within five days before an election. § 17-11-4(c)(2). The application
“may be submitted” by personally dropping off one’s own application with the
Absentee Election Manager or placing one’s own application in the
mail/commercial carrier. Id. This provision carries a Class A misdemeanor
penalty. SB 1 § 2.
2
(2) Enjoin Defendants, along with their respective agents, officers, employees, and
successors, from issuing any instructions or communications—whether public-facing or
otherwise—indicating that the Challenged Provisions prohibit any form of absentee application
assistance, and order Defendants to issue corrective instructions stating that the Challenged
Provisions have been preliminary enjoined and accordingly, that those provisions are not
enforceable.
DATED: May 2, 2024
Respectfully submitted,
/s/ Alison Mollman /s/ Anuja D. Thatte

Alison Mollman Anuja D. Thatte*
Laurel Hattix NAACP Legal Defense & Educational Fund,
ACLU OF ALABAMA Inc.
P.O. Box 6179 700 14th Street NW, Suite 600
Montgomery, AL 36106 Washington, DC 20009
(510) 909-8908 (202) 249-2170
amollman@aclualabama.org athatte@naacpldf.org
lhattix@aclualabama.org
Amir Badat*
/s/ Valencia Richardson Tiffani Burgess*
Valencia Richardson* Uruj Sheikh*
Alice Huling* NAACP LEGAL DEFENSE &
Molly Danahy* EDUCATIONAL FUND, INC.
Ellen Boettcher* 40 Rector Street, 5th Floor
Reginald Thedford* New York, NY 10006
CAMPAIGN LEGAL CENTER (212) 965-2200
1101 14th Street NW, Suite 400 abadat@naacpldf.org
Washington, DC 20005 tburgess@naacpldf.org
(202) 736-2200 usheikh@naacpldf.org
vrichardson@campaignlegalcenter.org
ahuling@campaignlegalcenter.org /s/ Jess Unger
mdanahy@campaignlegalcenter.org Bradley E. Heard*
eboettcher@campaignlegalcenter.org Sabrina Khan*
rthedford@campaignlegalcenter.org Jess Unger*
Ahmed Soussi*
SOUTHERN POVERTY LAW CENTER
3
/s/ William Van Der Pol, Jr. 150 E. Ponce de Leon Avenue,
William Van Der Pol, Jr. Suite 340
Larry G. Canada Decatur, GA 30030
ALABAMA DISABILITIES (470) 521-6700
ADVOCACY PROGRAM bradley.heard@splcenter.org
University of Alabama sabrina.khan@splcenter.org
Box 870395 jess.unger@splcenter.org
Tuscaloosa, AL 35487 ahmed.soussi@splcenter.org
(205) 348-4928
wvanderpoljr@adap.ua.edu
lcanada@adap.ua.edu
*Admitted pro hac vice
Counsel for Plaintiffs
4
CERTIFICATE OF SERVICE
I hereby certify that I have electronically filed a copy of the foregoing with the Clerk of
Court using the CM/ECF system which provides electronic notice of filing to all counsel of record.
DATED: May 2, 2024
/s/ Laurel Hattix

Laurel Hattix
ACLU OF ALABAMA
P.O. Box 6179
Montgomery, AL 36106
(510) 909-8908
5
Case 2:24-cv-00420-RDP Document 34-1 Filed 05/03/24 Page 1 of 45 FILED
2024 May-03 AM 09:52
U.S. DISTRICT COURT
N.D. OF ALABAMA

SOUTHERN DIVISION

THE NAACP, et al.,

v.
HEARING REQUESTED
Defendants.
PLAINTIFFS’ MEMORANDUM OF LAW IN SUPPORT OF MOTION FOR

PRELIMINARY INJUNCTION
Case 2:24-cv-00420-RDP Document 34-1 Filed 05/03/24 Page 2 of 45
TABLE OF CONTENTS
INTRODUCTION..........................................................................................................................1
FACTUAL BACKGROUND ........................................................................................................2
I. Alabama’s Multi-Step Process for Applying to Vote Absentee ..........................................2
II. SB 1’s Enactment and the Challenged Provisions ...............................................................3
III. Proffered Justification for SB 1 ..........................................................................................5
IV. SB 1’s Impact on Alabama Voters and on Plaintiffs’ Ability to Assist Such Voters ..........6
A. SB 1’s Impact on Voters ...........................................................................................6
B. SB 1’s Impact on Plaintiffs .......................................................................................9
ARGUMENT ................................................................................................................................13
I. Plaintiffs Have Standing ....................................................................................................13
II. Plaintiffs Are Substantially Likely to Succeed on the Merits of their Constitutional
Claims ................................................................................................................................14
A. SB 1 Unconstitutionally Burdens Plaintiffs’ Core Political Speech and
Associational Activity. ...........................................................................................14
1. Absentee Application Assistance Is Core Political Speech........................15
2. Absentee Application Assistance Is Expressive Conduct. .........................16
3. Absentee Ballot Application Assistance Is Associational Activity. ...........18
4. SB 1 Restricts the Amount and Effectiveness of Plaintiffs’ Political
Speech, Expressive Conduct, and Associational Activity. .........................19
5. Defendants Cannot Meet Their Burden to Establish That SB 1 Serves a
Compelling and Narrowly Tailored Government Interest. ........................20
B. SB 1 is Unconstitutionally Vague ..........................................................................22
1. SB 1 Fails to Provide Ordinary People Reasonable Notice of What it
Prohibits. ....................................................................................................22
2. The Challenged Provisions Authorize and Encourage Arbitrary
Enforcement. ..............................................................................................25
C. SB 1 is Unconstitutionally Overbroad ...................................................................27
III. Plaintiffs Are Substantially Likely to Succeed on the Merits of Their Claim Under
Section 208 of the Voting Rights Act ...............................................................................28
A. SB 1 Infringes on Federally Protected Assistance to Disabled, Blind, and Low
Literacy Voters. ......................................................................................................29
B. Because SB 1 Conflicts with Section 208, It Is Preempted. ..................................31
IV. Plaintiff ADAP Is Substantially Likely to Succeed on the Merits of Its HAVA Claim ....31
ii
V. Plaintiffs Will Suffer Irreparable Harm Absent Preliminary Relief ..................................33

VI. The Balance of the Equities Weighs in Plaintiffs’ Favor and a Preliminary Injunction
Serves the Public Interest ...................................................................................................35
CONCLUSION ............................................................................................................................35
iii
TABLE OF AUTHORITIES
Cases Pages
Arkansas United v. Thurston, 626 F. Supp. 3d 1064 (W.D. Ark. 2022) .........................................28
Baughcum v. Jackson, 92 F.4th 1024 (11th Cir. 2024)...................................................................14
Buckley v. American Constitutional Law Foundation, Inc., 525 U.S. 182 (1999).........................20
Buckley v. Valeo, 424 U.S. 1 (1976) ...............................................................................................15
Burns v. Town of Palm Beach, 999 F.3d 1317 (11th Cir. 2021) .....................................................17
Disability Rights Mississippi v. Fitch, No. 23 Civ. 350, 2023 WL 4748788
(S.D. Miss. July 25, 2023) ......................................................................................................29
Disability Rights North Carolina. v. North Carolina State Board of Elections, No. 21 Civ. 361,
2022 WL 2678884 (E.D.N.C. July 11, 2022) ..........................................................................29
Federal Election Commission v. Cruz, 596 U.S. 289 (2022) .........................................................27
FF Cosmetics FL, Inc. v. City of Miami Beach, 866 F.3d 1290 (11th Cir. 2017) ..........................27
Florida State Conference of NAACP v. Browning, 522 F.3d 1153 (11th Cir. 2008) ......................13
Fort Lauderdale Food Not Bombs v. City of Fort Lauderdale, 901 F.3d 1235
(11th Cir. 2018) ...........................................................................................................16, 17, 18
Fort Lauderdale Food Not Bombs v. City of Fort Lauderdale, 11 F.4th 1266 (11th Cir. 2021) ....33
Gaston County v. United States, 395 U.S. 285 (1969) ...................................................................34
Georgia Latino Alliance for Human Rights v. Governor of Georgia, 691 F.3d 1250
(11th Cir. 2012) .................................................................................................................14, 34
Gonzalez v. Governor of Georgia, 978 F.3d 1266 (11th Cir. 2020) ...............................................33
Harris v. Siegelman, 695 F. Supp. 517 (M.D. Ala. 1988) ..............................................................18
Hillsborough County, Florida v. Automated Medical Laboratories, Inc., 471 U.S. 707 (1985) ...31
Hines v. Davidowitz, 312 U.S. 52 (1941) .................................................................................31, 33
Holloman ex rel. Holloman v. Harland, 370 F.3d 1252 (11th Cir. 2004) ......................................17
Honeyfund.com Inc. v. Governor, 94 F.4th 1272 (11th Cir. 2024)...........................................13, 16
KH Outdoor, LLC v. City of Trussville, 458 F.3d 1261 (11th Cir. 2006)........................................35
Kolender v. Lawson, 461 U.S. 352 (1983) .....................................................................................25
League of Women Voters of Florida v. Browning, 863 F. Supp. 2d 1155 (N.D. Fla. 2012) ...........15
iv
League of Women Voters v. Hargett, 400 F. Supp. 3d 706 (M.D. Tenn. 2019) ..............................17
League of Women Voters of North Carolina v. North Carolina, 769 F.3d 224 (4th Cir. 2014)......34
Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) .....................................................................13
McIntyre v. Ohio Elections Commission, 514 U.S. 334 (1995) .....................................................20
Meyer v. Grant, 486 U.S. 414 (1988) ..........................................................................15, 19, 20, 21
Mills v. Alabama, 384 U.S. 214 (1966) ..........................................................................................15
NAACP v. Alabama ex rel. Flowers, 377 U.S. 288 (1964) ............................................................18
NAACP v. Alabama ex rel. Patterson, 357 U.S. 449 (1958) ..........................................................18
NAACP v. Button, 371 U.S. 415 (1963) .............................................................................18, 22, 25
NetChoice, LLC v. Attorney General, Florida, 34 F.4th 1196 (11th Cir. 2022).............................16
New York Times Co. v. Sullivan, 376 U.S. 254 (1964) ...................................................................15
OCA-Greater Houston v. Texas, 867 F.3d 604 (2017) .............................................................28, 30
Otto v. City of Boca Raton, Florida, 981 F.3d 854 (11th Cir. 2020) ..............................................33
R.A.V. v. City of St. Paul, 505 U.S. 377 (1992) ..............................................................................21
Reed v. Town of Gilbert, Ariz., 576 U.S. 155 (2015) .....................................................................21
Roberts v. United States Jaycees, 468 U.S. 609 (1984) .................................................................18
Sorrell v. IMS Health Inc., 564 U.S. 552 (2011) ............................................................................15
Turner Broadcasting Systems, Inc. v. F.C.C., 512 U.S. 622 (1994) ...............................................21
United States v. Alabama, 691 F.3d 1269 (11th Cir. 2012) ............................................................35
United States v. Atkins, 323 F.2d 733 (5th Cir. 1963) ....................................................................18
United States v. Davis, 139 S. Ct. 2319 (2019)..............................................................................22
United States v. Stevens, 559 U.S. 460 (2010) ...............................................................................27
Village of Schaumburg v. Citizens for a Better Environment, 444 U.S. 620 (1980) ................15, 16
Virginia v. American Booksellers Association, Inc., 484 U.S. 383 (1988).....................................13
VoteAmerica v. Raffensperger, No. 21 Civ. 1390, 2023 WL 6296928
(N.D. Ga. Sept. 27, 2023) .................................................................................................16, 18
VoteAmerica v. Schwab, 576 F. Supp. 3d 862 (D. Kan. 2021) .......................................................19
Voting for America, Inc. v. Steen, 732 F.3d 382 (5th Cir. 2013) ....................................................16
Weaver v. Bonner, 309 F.3d 1312 (11th Cir. 2002) ........................................................................20
v
Westchester Disabled on the Move, Inc. v. County of Westchester, 346 F. Supp. 2d 473
(S.D.N.Y. 2004) ......................................................................................................................34
Wilson v. State Bar of Georgia, 132 F.3d 1422 (11th Cir. 1998) .............................................13, 14
Wollschlaeger v. Governor of Florida, 848 F.3d 1293 (11th Cir. 2017) ............................13, 22, 26
Constitutional Provisions
Ala. Const. art. IV § 111.08 .............................................................................................................3
Ala. Const. art. VIII § 177 (2022) ....................................................................................................8
Statutes
29 U.S.C. § 794e ...................................................................................................................... 11, 32
29 U.S.C. §§ 3001 - 3058 ..............................................................................................................32
42 U.S.C § 300d-53 .......................................................................................................................32
42 U.S.C. §§ 1320b - 21 ................................................................................................................32
42 U.S.C. § 10801 .......................................................................................................................... 11
42 U.S.C. §§ 10801 - 10851 ..........................................................................................................32
42 U.S.C. § 15002 ..........................................................................................................................32
42 U.S.C. § 15041 .......................................................................................................................... 11
42 U.S.C. §§ 15041 - 15045 ..........................................................................................................32
52 U.S.C. §§ 20901 - 21145...........................................................................................................31
52 U.S.C. § 21061(a) ...............................................................................................................32, 33
52 U.S.C. §§ 21061 - 21062 ..........................................................................................................32
52 U.S.C. § 10310(c)(1) .................................................................................................................28
52 U.S.C. § 10508 ..........................................................................................................................28
Ala. Code § 13A-5-6 ....................................................................................................................4, 5
Ala. Code § 13A-5-7 ........................................................................................................................5
Ala. Code § 13A-5-12 ......................................................................................................................5
Ala. Code § 13A-6-2 ........................................................................................................................4
Ala. Code § 13A-6-3 ........................................................................................................................4
Ala. Code § 13A-6-90 ......................................................................................................................5
Ala. Code § 13A-6-132 ...................................................................................................................5
Ala. Code § 13A-8-43. .....................................................................................................................5
vi
Ala. Code § 13A-11-241 .................................................................................................................5

Ala. Code § 17-3-30.1(c) .................................................................................................................8
Ala. Code § 17-11-3 .....................................................................................................................2, 8
Ala. Code § 17-11-3(a) ................................................................................................................2, 3
Ala. Code § 17-11-4(a) ....................................................................................................................5
Ala. Code § 17-11-4(b)(1) ...........................................................................................................3, 5
Ala. Code § 17-11-4(b)(2) ...............................................................................................................4
Ala. Code § 17-11-4(c)(1) ................................................................................................................3
Ala. Code § 17-11-4(c)(2) ................................................................................................................4
Ala. Code § 17-11-4(d)(1) ...............................................................................................................4
Ala. Code § 17-11-4(d)(2) ...............................................................................................................4
Ala. Code § 17-11-4(e) ..............................................................................................................5, 30
Ala. Code § 17-11-9 .......................................................................................................................22
Ala. Code § 17-11-33 .....................................................................................................................22
Ala. Code § 17-17-38 .....................................................................................................................22
Ala. Code § 17-17-39 .....................................................................................................................22
Other Authorities
2024 Alabama Laws Act 2024-33 (S.B. 1), https://1.next.westlaw.com/Document/I193614D
0E76211EEBDB185AF89C5BCF3/View/FullText.html?VR=3.0&RS=cblt1.0&__lrT
S=20240501162006477&transitionType=Default&contextData=%28sc.Default%29 ............1
Alabama Department of Corrections, Monthly Statistical Report for February 2024,
https://doc.alabama.gov/docs/MonthlyRpts/February%202024.pdf (last accessed May 1,
2024) ..........................................................................................................................................8
Alabama Office of the Governor, “Governor Ivey Signs Senate Bill 1, Bans Ballot Harvesting”
(Mar. 20, 2024), https://governor.alabama.gov/newsroom/2024/03/governor-ivey-signs-
senate-bill-1-bans-ballot-harvesting/ .........................................................................................5
Alabama Secretary of State, “Absentee Voting Information,”
https://www.sos.alabama.gov/alabama-votes/voter/absentee-voting ........................................3
Centers for Disease Control and Prevention Disability and Health Data System (DHDS),
Alabama, https://dhds.cdc.gov/SP?LocationId=01&CategoryId=DISEST&
ShowFootnotes=true&showMode=&IndicatorIds=STATTYPE,AGEIND,SEXIND,
RACEIND,VETIND&pnl0=Chart,false,YR6,CAT1,BO1,,,,AGEADJPREV&pnl1=
Chart,false,YR6,DISSTAT,,,,,PREV&pnl2=Chart,false,YR6,DISSTAT,,,,,AGEADJ
vii
PREV&pnl3=Chart,false,YR6,DISSTAT,,,,,AGEADJPREV&pnl4=Chart,false,YR6,
DISSTAT,,,,,AGEADJPREV&t=1714216511663 (last accessed May 1, 2024).......................7
Centers for Disease Control and Prevention, Disability and Health Promotion- Alabama,
https://www.cdc.gov/ncbddd/disabilityandhealth/impacts/alabama.html
(last accessed May 1, 2024) ......................................................................................................7
Client Assistance Program (“CAP”), Public Law 113-128............................................................32
Institute of Education Sciences - National Center for Education Statistics,
The Nation’s Report Card (2022) https://nces.ed.gov/nationsreportcard/subject/publications/
stt2022/pdf/2023010AL8.pdf (last access May 1, 2024) ..........................................................7
Jacob Holmes, Legislature passes bill criminalizing “ballot harvesting”, Ala. Political Reporter,
(Mar. 8, 2024) https://www.alreporter.com/2024/03/08/legislature-passes-bill-
criminalizing-ballot-harvesting/ ..........................................................................................5, 21
John Sharpe, AL.com, “Absentee ‘ballot harvesting’ bill advances in House amid questions
about proof”, (Feb. 28, 2024) https://www.al.com/news/2024/02/absentee-ballot-harvesting-
bill-advances-in-house-amid-questions-about-proof.html .......................................................26
Mike Cason, AL.com, “Sec’y of State Wes Allen says Alabama’s new absentee voting
law in effect for November election” (Mar. 23, 2024), https://www.al.com/news/2024/03/
secretary-of-state-wes-allen-says-alabamas-new-absentee-voting-law-in-effect-for-
november-election.html ............................................................................................................3
National Institute of Corrections, Alabama State Statistics Information,
https://nicic.gov/resources/nic-library/state-statistics/2020/alabama-2020
(last accessed May 1, 2024) ......................................................................................................8
Protection and Advocacy for Beneficiaries with Representative Payees (“PABRP”),
Public Law 115 – 165 ..............................................................................................................32
S. Rep. No. 97-417 (1982) .......................................................................................................28, 34
United States Census Bureau, Alabama QuickFacts,
https://www.census.gov/quickfacts/fact/table/AL/PST045223. (last accessed May 1, 2024) ...6
United States Census Bureau, Why We Ask Questions About Language Spoken at Home,
https://www.census.gov/acs/www/about/why-we-ask-each-question/language/
(last accessed May 1, 2024) .......................................................................................................8
United States Census Bureau, “Language Spoken at Home,” American Community Survey,
ACS 1-Year Estimates Subject Tables, Table S1601, 2022,
https://data.census.gov/table/ACSST1Y2022.S1601?t=Language Spoken at
Home&g=040XX00US01&moe=false (last accessed May 1, 2024). .......................................... 8
viii
INTRODUCTION
Plaintiffs 1 are civil rights, faith-based, and disability rights organizations that promote civic
participation by educating and assisting Alabamians to vote, including by assisting voters with the
multi-step application process for voting absentee. Alabama Senate Bill 1 (“SB 1”) 2 is a sweeping
and vague statute that turns such civic and neighborly engagement into serious crimes. Plaintiffs
seek a preliminary injunction against four provisions of SB 1 that unconstitutionally restrict their
speech and activities regarding absentee assistance and violate federal law (the “Challenged
Provisions”). 3
As Plaintiffs prepare to undertake civic engagement activities for the November 2024
general election, the Challenged Provisions are severely restricting their ability under the First and
Fourteenth Amendments to speak and engage with each other and with voters who require absentee
application assistance. The Challenged Provisions also violate the right of disabled, blind, and low
literacy voters to assistance guaranteed by Section 208 of the Voting Rights Act (“VRA”). And
the Challenged Provisions appear to prohibit voter assistance that Plaintiff ADAP is federally
mandated to undertake under the Help America Vote Act of 2002 (“HAVA”). Plaintiffs
respectfully request that the Challenged Provisions be preliminarily enjoined to prevent these
serious ongoing harms.
1
Plaintiffs are the Alabama State Conference of the NAACP (“Alabama NAACP”), League of Women Voters of
Alabama and League of Women Voters of Alabama Education Fund (collectively, “LWVAL”), Greater
Birmingham Ministries (“GBM”), and Alabama Disabilities Advocacy Program (“ADAP”).
2
See 2024 Alabama Laws Act 2024-33 (S.B. 1),
https://1.next.westlaw.com/Document/I193614D0E76211EEBDB185AF89C5BCF3/View/FullText.html?VR=3.
0&RS=cblt1.0&__lrTS=20240501162006477&transitionType=Default&contextData=%28sc.Default%29.
Section 1 of SB 1 amends Ala. Code Section 17-11-4, which governs absentee applications. Sections 2, 3, and 4
of SB 1 contain other provisions. Hereinafter, citations to Section 1 of SB 1 will be denoted by “§ 17-11-4.”
Citations to other sections of SB 1 will be identified by section number.
3
As described below, the Challenged Provisions are: (i) the Payment Provisions (§ 17-11-4(d)(1)-(d)(2)), (ii) the
Gift Provisions (§ 17-11-4(d)(1)-(2)), (iii) the Prefilling Restriction (§ 17-11-4(b)(2)), and (iv) the Submission
Restriction (§ 17-11-4(c)(2)).
1
FACTUAL BACKGROUND
I. Alabama’s Multi-Step Process for Applying to Vote Absentee.

Under Alabama law, with limited emergency exceptions, absentee voting is permitted only
if a voter: (i) will be absent from the county of residence on Election Day; (ii) is ill or has a physical
disability that prevents a trip to the polling place; (iii) is enrolled as a student at an educational
institution located outside the county of his or her personal residence, attendance at which prevents
his or her attendance at the polls; (iv) is an appointed election officer or poll watcher at a polling
place other than their regular polling place; (v) is working a required shift of ten hours or more
that coincides with polling hours; (vi) is a caregiver for a family member (to the second degree of
kinship) and the family member is confined to their home; (vii) is currently incarcerated in prison
or jail, but has not been convicted of a felony involving moral turpitude; (viii) is a member of, or
spouse or dependent of a member of, the Armed Forces of the United States or is similarly qualified
to vote absentee pursuant to the federal Uniformed and Overseas Citizens Absentee Voting Act. 4
There is no broad right to vote absentee for everyone over 65, nor for everyone with a disability.
For the subset of voters who do qualify to vote absentee, there is a multi-step process for
applying to do so. The application form is specified by the Alabama Secretary of State and, under
SB 1, Alabama no longer allows voters to request absentee ballots without using this form. 5 The
current application is two pages and includes various fields for the voter to complete, including
full name, physical and mailing addresses, e-mail address, date of birth, personal and work phone
numbers, driver’s license or social security number, and election(s) in which they are applying to
vote absentee. 6 The application also requires the voter to review and select from the list of excuses
4
Ala. Code § 17-11-3.
5
Id. § 17-11-4(a).
6
Alabama’s generic absentee application form is available on the Alabama Secretary of State’s website.
2
to vote absentee and lists the Alabama crimes that disqualify an individual from voting as well as
the penalties for failing to properly fill out and submit the form.
The application can be accessed in one of the following ways: (i) online, downloaded, and
printed, (ii) in hard copy from the relevant county Absentee Election Manager; or (iii) in hard copy
by mail, if a written request is first sent to the Absentee Election Manager. 7 The form then must be
completed fully and correctly, including by obtaining a witness signature if the voter signs by
mark. 8 The completed application packet also must include a printed copy of the voter’s valid
photo identification. Then, the application packet must be returned to the Absentee Election
Manager either in person or by mail/commercial carrier. 9 Absentee applications must be received
by the Absentee Election Manager seven days prior to the relevant election if submitted by mail
(or five days prior if submitted in person). 10 Voters must submit separate applications for elections
more than 42 days apart.
II. SB 1’s Enactment and the Challenged Provisions.

On March 19, 2024, the Alabama Legislature enacted SB 1. The Governor signed the bill
into law the next day. In key part, SB 1 amends Ala. Code § 17-11-4, which governs absentee
applications, to add new restrictions and criminal penalties. 11 The Challenged Provisions are:
• Payment Provisions: SB 1 makes it “unlawful for a third party to knowingly receive a
7
Ala. Sec’y of State, “Absentee Voting Information,” https://www.sos.alabama.gov/alabama-votes/voter/absentee-
voting.
8
Ala. Code § 17-11-4(b)(1).
9
Id. §§ 17-11-3(a), 17-11-4(c)(1).
10
Id. § 17-11-3(b).
11
SB 1 specifies that it goes into effect “immediately following its passage and approval by the governor, or its
otherwise becoming law.” SB 1 at Section 4. However, Defendant Secretary of State Wes Allen, who is
responsible for “provid[ing] uniform guidance for election activities,” Ala. Code § 17-1-3(a), has advised that SB
1 will go into effect for the November 5, 2024 general election. See Mike Cason, AL.com, “Sec’y of State Wes
Allen says Alabama’s new absentee voting law in effect for November election” (Mar. 23, 2024),
https://www.al.com/news/2024/03/secretary-of-state-wes-allen-says-alabamas-new-absentee-voting-law-in-
effect-for-november-election.html; see also Ala. Const. art. IV § 111.08 (providing that “the implementation date
for any bill enacted by the Legislature in a calendar year in which a general election is to be held and relating to
the conduct of the general election shall be at least six months before the general election”).
3
payment,” or “knowingly pay . . . a third party,” to “distribute, order, request, collect,
prefill, complete, obtain, or deliver a voter’s absentee ballot application.” § 17-11-4(d)(1)-
(d)(2). These provisions carry a Class B or C felony penalty (Class C for assistors who
“receive a payment” and Class B for those who “pay” such assistor). Id.
• Gift Provisions: SB 1 makes it “unlawful for a third party to knowingly receive a . . . gift,”
or “knowingly . . . provide a gift,” to a “third party” to “distribute, order, request, collect,
prefill, complete, obtain, or deliver a voter’s absentee ballot application.” § 17-11-4(d)(1)-
(d)(2). These provisions carry a Class B or C felony penalty (Class C for assistors who
“receive a . . . gift” and Class B for those who “provide a gift” to such assistor). Id.
• Prefilling Restriction: SB 1 makes it “unlawful for any person to knowingly distribute an
absentee ballot application to a voter that is prefilled with the voter’s name or any other
information required on the application form.” § 17-11-4(b)(2). This provision carries a
Class A misdemeanor penalty. SB 1 § 2.
• Submission Restriction: SB 1 makes it “unlawful for an individual to submit a completed
absentee ballot application to the absentee election manager other than his or her own
application,” unless that person is seeking emergency medical treatment within five days
before an election. § 17-11-4(c)(2). The application “may be submitted” by personally
dropping off one’s own application with the Absentee Election Manager or returning one’s
own application in the mail/commercial carrier. Id. This provision carries a Class A
misdemeanor penalty. SB 1 § 2.
In Alabama, Class B felonies carry a sentence of up to 20 years, 12 Class C felonies carry a
12
Ala. Code § 13A-5-6. Other Class B felonies include first-degree manslaughter and second-degree rape. Id.
§§ 13A-6-3, 13A-6-2.
4
sentence of up to 10 years, 13 and Class A misdemeanors carry a sentence of up to one year and a
$6,000 fine. 14 SB 1 does not define any of the statutory terms that trigger criminal liability,
including no definitions for “payment,” “gift,” “third-party,” “prefill,” “distribute,” or “submit.”
SB 1 also newly requires that voters apply for absentee ballots using the Secretary of State’s
specified printed form; Alabama no longer allows handwritten absentee requests. § 17-11-4(a).
Elsewhere, SB 1 states “[a]ny applicant may receive assistance in filling out the application as he
or she desires. . . .” § 17-11-4 (b)(1). SB 1 also states that “[a]ny voter who requires assistance to
vote by reason of blindness, disability, or inability to read or write may be given assistance by an
individual of the voter’s choice, other than the voter’s employer or agent of that employer or officer
or agent of the voter’s union.” § 17-11-4(e).
III. Proffered Justification for SB 1.

Proponents repeatedly and consistently asserted that SB 1’s justification was to target so-
called absentee “ballot harvesting.” SB 1’s sponsor, Senator Garlan Gudger, averred that SB 1 is
intended to address “ballot harvesting” by “groups or individuals seek[ing] to profit off the
absentee voting process.” 15 For example, he testified before the Senate State Government Affairs
Committee that “this bill is meant for ballot harvesting.” 16
Upon signing SB 1, Governor Kay Ivey stated that the bill would “ban[] ballot
harvesting.” 17 Defendant Secretary of State Wes Allen commented: “[t]he passage of SB1 signals
to ballot harvesters that Alabama votes are not for sale. The Alabama Legislature and Governor
13
Id. § 13A-5-6. Other Class C felonies include third-degree robbery and first-degree stalking. Id. §§ 13A-6-90,
13A-8-43.
14
Id. §§ 13A-5-7, 13A-5-12. Other Class A misdemeanors include third-degree domestic violence and cruelty to
animals. Id. §§ 13A-6-132, 13A-11-241.
15
Jacob Holmes, Ala. Political Reporter, “Legislature passes bill criminalizing ballot harvesting” (Mar. 8, 2024),
https://www.alreporter.com/2024/03/08/legislature-passes-bill-criminalizing-ballot-harvesting/.
16
Ex. B to Decl. of Lauren Bishop (“Bishop Decl.”) at 34:9-10.
17
Ala. Office of the Governor, “Governor Ivey Signs Senate Bill 1, Bans Ballot Harvesting” (Mar. 20, 2024),
https://governor.alabama.gov/newsroom/2024/03/governor-ivey-signs-senate-bill-1-bans-ballot-harvesting/.
5
Ivey have made it clear that Alabama voters have the right to cast their own vote without undue
influence.” 18
Neither SB 1’s sponsor nor the Governor nor Defendant Allen has ever explained what is
meant by “taking people’s votes”; what “ballot harvesting” is; whose votes have been “for sale”;
what “undue influence” occurs; or the relationship between absentee ballot applications and any
of these purported concerns. Likewise, legislative proceedings did not include any actual evidence
of problems regarding “ballot harvesting,” either in general or with respect to absentee voting
specifically. 19 During legislative proceedings, members of the public, including Plaintiffs,
provided extensive testimony about the lack of evidence of voter fraud or problems with “ballot
harvesting,” vagueness of the terms used in SB 1, and likelihood that SB 1’s criminal sanctions
would severely chill voter assistance across the state. 20
IV. SB 1’s Impact on Alabama Voters and on Plaintiffs’ Ability to Assist Such Voters.
For those who qualify, absentee voting provides access to the franchise when in-person
voting would be challenging if not impossible. But because of the numerous steps involved in
applying to vote absentee, such voters (including senior citizen, disabled, blind, low literacy, and
incarcerated voters) often rely on assistance in the process from family, neighbors, and civic
organizations like Plaintiffs. SB 1 severely impacts voters who require such assistance, as well as
assistors like Plaintiffs who would fill this need.
A. SB 1’s Impact on Voters.

Senior Citizen and Disabled Voters. Approximately 18% of all Alabamians are over 65
years old. 21 According to the Centers for Disease Control, more than 30% of all adults in Alabama
18
Id.
19
See Exs. A & B to Bishop Decl.
20
See id.; Doc. 1 (Compl.) ¶¶ 54-59 (quoting public testimony).
21
See United States Census Bureau, Alabama QuickFacts
https://www.census.gov/quickfacts/fact/table/AL/PST045223. (last accessed May 1, 2024).
6
have some form of disability, including many with mobility and vision impairments. 22 For
Alabamians over 65 years old, the number rises to nearly half (47.8%). 23 Approximately nine
percent of adults in Alabama have “serious difficulty doing errands alone.” 24
Many of these individuals often can only access the right to vote by casting absentee ballots,
such as individuals confined to a bed, with mobility impairments or other impairments, or whose
movement is restricted (such as individuals in jail, prison, or state mental health or forensic
hospitals). Decl. of Scott Douglas (“GBM Decl”) ¶ 22; Decl. of Nicole Watkins (“ADAP Watkins
Decl.”) ¶¶ 6, 9, 14. And moreover, as discussed below, many of these individuals depend on
assistance from others, including from Plaintiffs, to exercise this right, including the absentee
application assistance that may now be criminalized under SB 1. Decl. of Benard Simelton
(“Alabama NAACP Decl.”) ¶¶ 20-21; Decl. of Kathy Jones (“LWVAL Decl.”) ¶ 24; GBM Decl.
¶¶ 22, 32; ADAP Watkins Decl. ¶¶ 11-14. If denied an accessible absentee voting process, many
of these individuals would effectively be precluded from participating in what for them is the only
way to vote. ADAP Watkins Decl. ¶ 14.
Illiterate and Low Literacy Voters. Per the National Center for Education Statistics,
Alabama has the 44th lowest literacy rate in the country. 25 In 2022, 56% of Black Alabamians and
46% of Latino Alabamians, compared to 28% of white Alabamians, had “below” basic literacy
22
See Centers for Disease Control and Prevention Disability and Health Data System (DHDS), Alabama,
https://dhds.cdc.gov/SP?LocationId=01&CategoryId=DISEST&ShowFootnotes=true&showMode=&IndicatorI
ds=STATTYPE,AGEIND,SEXIND,RACEIND,VETIND&pnl0=Chart,false,YR6,CAT1,BO1,,,,AGEADJPREV
&pnl1=Chart,false,YR6,DISSTAT,,,,,PREV&pnl2=Chart,false,YR6,DISSTAT,,,,,AGEADJPREV&pnl3=Chart,f
alse,YR6,DISSTAT,,,,,AGEADJPREV&pnl4=Chart,false,YR6,DISSTAT,,,,,AGEADJPREV&t=1714216511663
. (last accessed May 1, 2024)
23
See id.
24
See Centers for Disease Control and Prevention, Disability and Health Promotion- Alabama,
https://www.cdc.gov/ncbddd/disabilityandhealth/impacts/alabama.html (last accessed May 1, 2024).
25
Institute of Education Sciences- National Center for Education Statistics, 2022 Reading State Snapshot Report,
Alabama (2022), https://nces.ed.gov/nationsreportcard/subject/publications/stt2022/pdf/2023010AL8.pdf (last
accessed May 1, 2024).
7
skills in the eighth grade. 26 Further, per U.S. Census estimates, among the state’s citizen voting-
age population, 27% of Spanish-speakers speak English “less than very well.” 27 Given the reading
comprehension and writing required to apply for an absentee ballot and the fact that Alabama does
not offer its absentee applications in languages other than English, many illiterate and low literacy
Alabamians require assistance from others, including from Plaintiffs, to complete the application
process. Alabama NAACP Decl. ¶ 20; ADAP Watkins Decl. ¶ 4. SB 1’s restrictions severely limit
their access to such assistance and therefore severely burden their right to vote.
Incarcerated Voters. In Alabama, voters who are incarcerated and who have not been
convicted of a crime of “moral turpitude,” including pre-trial detainees, remain eligible to vote. 28
As of February 2024, the Alabama Department of Corrections had over 27,000 inmates in its
jurisdiction (including jails and prisons). 29 According to the National Institute on Corrections, the
jail population in Alabama was 16,520 in 2020. 30
Incarceration is one of the state’s qualifying excuses to vote absentee. 31 Because no county
in Alabama provides jail- or prison-based voting sites, absentee voting is the only way that eligible
incarcerated voters are able to vote. GBM Decl. ¶ 22. Given the number of steps involved in
applying for an absentee ballot and the confinement restrictions to which incarcerated voters are
subject (such as limitations on access to the internet, printers/copiers, and mailing supplies) eligible
26
Id.
27
United States Census Bureau, Why We Ask Questions About Language Spoken at Home,
https://www.census.gov/acs/www/about/why-we-ask-each-question/language/ (last accessed May 1, 2024);
United States Census Bureau. "Language Spoken at Home." American Community Survey, ACS 1-Year Estimates
Subject Tables, Table S1601, 2022, https://data.census.gov/table/ACSST1Y2022.S1601?t=Language Spoken
at Home&g=040XX00US01&moe=false. (last accessed May 1, 2024).
28
Ala. Const. art. VIII § 177 (2022); Ala. Code § 17-3-30.1(c).
29
Alabama Department of Corrections, Monthly Statistical Report for February 2024,
https://doc.alabama.gov/docs/MonthlyRpts/February%202024.pdf (last accessed May 1, 2024).
30
National Institute of Corrections, Alabama State Statistics Information, https://nicic.gov/resources/nic-
library/state-statistics/2020/alabama-2020 (last accessed May 1, 2024).
31
Ala. Code § 17-11-3.
8
incarcerated voters depend on assistance from others, like Plaintiffs GBM and Alabama NAACP
and prison or jail staff, to vote. Alabama NAACP Decl. ¶¶ 12; GBM Decl. ¶¶ 22, 29.
B. SB 1’s Impact on Plaintiffs.

As described further herein and in Plaintiffs’ accompanying declarations, Plaintiffs have
paid staff and volunteers who assist voters with absentee applications, e.g., by providing the printed
applications, helping voters to read, understand, and complete applications, and providing
envelopes and postage so that applications can be returned. This includes voters who depend on
assistance with the application process, such as senior citizen, disabled, low literacy, and
incarcerated voters. Because of SB 1’s extreme vagueness and severe criminal penalties, SB 1
restricts Plaintiffs from engaging in absentee application assistance, which is a critical part of how
they convey their message to encourage participation in the democratic process.
Alabama NAACP. Plaintiff Alabama NAACP is the state conference of the National
Association for the Advancement of Colored People, Inc. and is a nonpartisan organization
dedicated to ensuring the political, educational, social, and economic equality of Black Americans
and all other Americans and to eliminate racial discrimination in the democratic process. Alabama
NAACP Decl. ¶¶ 2, 5. Voter assistance activities, including absentee ballot application assistance,
are a core part of the Alabama NAACP’s voter education and engagement programs and are part
of its mission to encourage participation in the democratic process. Id. ¶ 7. The Alabama NAACP’s
activities have included assistance for voters in nursing homes and jails who could not otherwise
vote without such assistance, such as by providing hard copies of the application and mailing
supplies. Id. ¶ 12. For the November 2024 election and going forward, the Alabama NAACP would
like to continue engaging in absentee ballot application assistance for its members and Alabamians
more broadly. Id. ¶ 22.
9
LWVAL. Plaintiff LWVAL is comprised of nonpartisan, nonprofit, grassroots
organizations that seek to encourage informed and active participation in government, work to
increase understanding of major public policy issues, and influence public policy through
education and advocacy. LWVAL’s voter services teams engage voters, including by assisting
with the absentee process. LWVAL Decl. ¶¶ 9-13. To that end, LWVAL provides regular training
to its local chapter leaders, their members, their volunteers, and to their nonpartisan partners to
assist voters in getting registered, applying for an absentee ballot, and voting absentee. Id. ¶ 10.
LWVAL considers its absentee application assistance to be an expression of its core values. Id.
¶ 11. As recently as the March 2024 primary election, LWVAL volunteers have assisted voters
with absentee ballot applications, including senior citizens who require assistance, and voters with
disabilities. Id. ¶ 5. LWVAL’s assistance has included providing printed applications, making
photocopies of voters’ photo IDs, working with the voter to ensure the application is accurately
filled out, and providing envelopes and postage to submit such application. Id. ¶ 18. For the year
2024 and after, LWVAL hopes to engage in absentee ballot application assistance on behalf of its
members and the communities it serves across the state of Alabama. Id. ¶ 6.
GBM. Plaintiff GBM is a multi-faith, multi-racial, membership organization that provides
emergency services to people in need and engages people to build a strong, supportive, and
engaged community and to build a more just society for all. GBM Decl. ¶ 5. GBM is a nonpartisan,
nonprofit organization. Id. ¶ 2. To promote civic engagement in the communities it serves, GBM
engages in voter education and assistance, including discussing civics with incarcerated
individuals and assisting Alabamians to register to vote, restore their voting rights, and encourage
them to vote, including by absentee ballot. Id. ¶ 6. GBM engages in voter assistance to express a
clear message: voting is a person’s fundamental right and is the key to advancing civil and human
10
rights in Alabama. Id. ¶ 7. GBM provides printed absentee applications, pens, and mailing supplies
to eligible voters and GBM’s staff and volunteers also spend time with each voter to ensure that
their application is marked correctly and completely. Id. ¶ 12. As recently as the March 2024
primary election, GBM paid staff and volunteers assisted voters with absentee ballot applications,
including eligible incarcerated voters who are in prison or jail. Id. ¶¶ 3, 21. For the November 2024
general election and in the future, GBM would like to engage in absentee ballot application
assistance on behalf of the communities it serves in the Greater Birmingham area and across
Alabama. Id. ¶ 4.
ADAP. Plaintiff ADAP is the duly authorized Protection and Advocacy Program (“P&A”)
of Alabama, as designated under federal law. 32 Decl. of Nancy Anderson (“ADAP Anderson
Decl.”) ¶ 2. As such, ADAP provides legal services to Alabama residents with disabilities to
promote their rights and all Alabama voters with disabilities are constituents of ADAP. Id. As a
P&A, ADAP is accountable to members of the disability community and is authorized under
federal law to represent the interests of Alabamans with disabilities. Id. ADAP’s mission is to
achieve equality in opportunity for people with disabilities, including in voting. Id. Through its
work, ADAP seeks to convey the message that voting should be accessible to all, regardless of
disability status. Id. ¶ 9. ADAP has a staff member whose primary responsibility is to undertake
voter education and promote voting rights for people with disabilities, including by assisting them
with applying for absentee ballots and helping residential facility staff to do the same. Id. ¶¶ 7-8;
ADAP Watkins Decl. ¶¶ 2-10. ADAP receives a federal grant under HAVA to undertake this work.
ADAP Anderson Decl. ¶¶ 5-10; ADAP Watkins Decl. ¶ 2. As recently as the March 2024 primary
election, ADAP assisted disabled voters with absentee applications. ADAP Watkins Decl. ¶ 10.
32
See 42 U.S.C. § 15041 et seq.; 42 U.S.C. § 10801 et seq.; 29 U.S.C. § 794e et seq.
11
ADAP would like to continue its work, and indeed its legal obligation, to assist its disabled
constituents with absentee applications for the November 2024 general election and beyond.
ADAP Watkins Decl. ¶ 11.
* * *
If not for SB 1, Plaintiffs would assist voters with absentee applications for the November
2024 general election and beyond. However, Plaintiffs and their paid staff and volunteers are
unlikely to engage in these activities given their reasonable fear of criminal prosecution if they
continue any assistance with absentee applications. Alabama NAACP Decl. ¶¶ 19-21; LWVAL
Decl. ¶ 27; GBM Decl. ¶ 33; ADAP Watkins Decl. ¶¶ 11, 14. As a result of SB 1, Plaintiffs are
being forced to cancel speech and expressive activities regarding absentee application assistance.
Alabama NAACP Decl. ¶ 17; LWVAL Decl. ¶ 26; GBM Decl. ¶¶ 24-31; ADAP Watkins Decl.
¶ 14. Plaintiff ADAP, which receives federal funding to conduct absentee application assistance
that is now possibly criminalized under SB 1, has also directed its staff not to engage in this work
notwithstanding its federal obligation to do so. ADAP Anderson Decl. ¶ 12; ADAP Watkins Decl.
¶ 14. Some of Plaintiffs’ members and constituents are also fearful that they could face criminal
prosecution under SB 1 for simply receiving assistance with their absentee applications. Alabama
NAACP Decl. ¶ 21; ADAP Watkins Decl. ¶¶ 12-13. Accordingly, it is likely that at least some of
these voters will forego assistance even if they need it and may not even vote at all. ADAP Watkins
Decl. ¶ 14.
12
ARGUMENT
A preliminary injunction is warranted if Plaintiffs establish: (1) a substantial likelihood of
success on the merits; (2) irreparable harm absent an injunction; (3) the harm they will experience
outweighs any injury the opposing party may experience under the injunction; and (4) the
injunction would not be adverse to the public interest. Honeyfund.com Inc. v. Governor, 94 F.4th
1272, 1277 (11th Cir. 2024). Plaintiffs satisfy all four requirements.
I. Plaintiffs Have Standing.

As a threshold matter, Plaintiffs have standing. First, Plaintiffs have direct standing to bring
their First and Fourteenth Amendment claims because the “credible threat” of criminal liability
chills Plaintiffs’ speech. Wollschlaeger v. Governor of Fla., 848 F.3d 1293, 1304 (11th Cir. 2017)
(en banc). When a plaintiff challenging a law is the subject of its enforcement, “there is ordinarily
little question that the [government’s] action or inaction has caused him injury[.]” Lujan v.
Defenders of Wildlife, 504 U.S. 555, 561–62 (1992). Here, SB 1’s restrictions force Plaintiffs to
limit their First Amendment activities due to their “actual and well-founded fear that the law will
be enforced against them.” Virginia v. Am. Booksellers Ass’n, Inc., 484 U.S. 383, 393 (1988). This
direct First Amendment harm alone confers standing on Plaintiffs. See Wilson v. State Bar of Ga.,
132 F.3d 1422, 1428 (11th Cir. 1998) (explaining that “the injury is self-censorship”).
In addition, each Plaintiff has direct standing to bring their claims because they have
cancelled and/or restricted planned voter assistance activities and been forced to divert resources
to educate and respond to SB 1’s changes to the law. Alabama NAACP Decl. ¶¶ 14-16; LWVAL
Decl. ¶¶ 26-31; GBM Decl. ¶¶ 24-31; ADAP Anderson Decl. ¶ 12; ADAP Watkins Decl. ¶¶ 12-
14; see, e.g., Fla. State Conf. of NAACP v. Browning, 522 F.3d 1153, 1165–66 (11th Cir. 2008)
(recognizing organizational standing where organizations “reasonably anticipate[d] that they
[would] have to divert personnel and time to educating volunteers and [affected individuals] on
13
compliance” with the statute’s requirements). Plaintiff ADAP also has direct standing to bring its
claim under HAVA because SB 1 harms its ability to engage in voter assistance that it is federally
mandated to undertake pursuant to HAVA. ADAP Anderson Decl. ¶¶ 12-13.
Second, Plaintiffs have associational standing on behalf of their members and constituents.
See Baughcum v. Jackson, 92 F.4th 1024, 1031 (11th Cir. 2024) (explaining that associational
standing exists where (i) members “otherwise have standing to sue,” (ii) “the interests the lawsuit
seeks to protect must be germane to the [organization’s] purpose,” and (iii) “the claim can be
resolved . . . without the participation of individual members”). Not only has Plaintiffs’ speech
been chilled by a reasonable fear of enforcement of SB 1, see Wilson, 132 F.3d at 1428, but
Plaintiffs also have cancelled plans for absentee voter assistance programming because of fear of
criminal liability for themselves and their members and volunteers. Alabama NAACP Decl. ¶ 17;
LWVAL Decl. ¶¶ 26, 31; GBM Decl. ¶¶ 30-31; ADAP Anderson Decl. ¶ 12; ADAP Watkins Decl.
¶ 14. Further, Plaintiffs’ blind, disabled, and/or low literacy members and constituents are suffering
injury to their right to receive assistance under Section 208. Alabama NAACP Decl. ¶ 12; LWVAL
Decl. ¶¶ 24-25; GBM Decl. ¶ 33; ADAP Anderson Decl. ¶ 12; ADAP Watkins Decl. ¶ 14.
And, because these injuries are “directly traceable to the passage of [SB 1],” they “would
be redressed by enjoining each provision.” Ga. Latino All. for Hum. Rts. v. Governor of Ga., 691
F.3d 1250, 1260 (11th Cir. 2012).
II. Plaintiffs Are Substantially Likely to Succeed on the Merits of their Constitutional
Claims.
A. SB 1 Unconstitutionally Burdens Plaintiffs’ Core Political Speech and

Associational Activity.
The First Amendment squarely protects Plaintiffs’ absentee ballot application assistance
activities for three reasons. First, because this assistance is interactive communication about
voting, its restriction limits core political speech. Second, absentee ballot application assistance is
14
also expressive conduct conveying a message about the importance of voting. Third, providing this
assistance is one of Plaintiffs’ chosen means of associating with others in the pursuit of their shared
social and political goals. Thus, by broadly criminalizing absentee ballot application assistance
activities, the Challenged Provisions severely burden Plaintiffs’ First Amendment rights to speech,
expressive conduct, and association.
1. Absentee Application Assistance Is Core Political Speech.

The “dissemination of information [is] speech within the meaning of the First
Amendment.” Sorrell v. IMS Health Inc., 564 U.S. 552, 570 (2011). And the First Amendment
“affords the broadest protection” to core political speech, especially to “[d]iscussion of public
issues” related to the political process. Buckley v. Valeo, 424 U.S. 1, 14 (1976). Our country has a
“profound national commitment to the principle that debate on public issues should be uninhibited,
robust, and wide-open.” New York Times Co. v. Sullivan, 376 U.S. 254, 270 (1964). For that reason,
“there is practically universal agreement that a major purpose of [the First Amendment] was to
protect the free discussion of governmental affairs,” including “all such matters relating to political
processes.” Mills v. Alabama, 384 U.S. 214, 218–19 (1966). Consistent with these fundamental
principles, activities that “involve[] interactive communication concerning political change” are
“appropriately described as ‘core political speech’” and are subject to special First Amendment
scrutiny. See Meyer v. Grant, 486 U.S. 414, 421–22 (1988); Vill. of Schaumburg v. Citizens for a
Better Env’t, 444 U.S. 620, 628–32 (1980).
Here, Plaintiffs’ absentee ballot assistance activities are core political speech because
Plaintiffs accomplish their assistance through interactive communications that encourage others to
vote. See League of Women Voters of Fla. v. Browning, 863 F. Supp. 2d 1155, 1158 (N.D. Fla.
2012) (“[E]ncouraging others to register to vote” is “pure speech,” and, because that speech is
political in nature, it is a “core First Amendment activity.”). As a central part of that political
15
speech, Plaintiffs regularly hold and participate in events at which they distribute absentee ballot
applications to voters, answer questions about the absentee voting process, and assist eligible
voters with completing their applications. Alabama NAACP Decl. ¶ 8, 9, 11; LWVAL Decl. ¶ 14;
GBM Decl. ¶ 11; ADAP Watkins Decl. ¶ 5. It would be impossible for Plaintiffs to assist voters
with their applications without “disclos[ing]” and “disseminat[ing] information,” including by
speaking with voters about how to fill out their applications. NetChoice, LLC v. Att’y Gen., Fla.,
34 F.4th 1196, 1210 (11th Cir. 2022) (quotation marks omitted). Because Plaintiffs’ absentee ballot
application assistance “depends on[] and cannot be separated from” Plaintiffs’ speech, the
Challenged Provisions are “functionally a regulation of speech.” Honeyfund.com Inc., 94 F.4th at
1278; see Voting for Am., Inc. v. Steen, 732 F.3d 382, 389 (5th Cir. 2013) (recognizing that activities
including “distributing” registration forms and “helping voters to fill out their forms” involve
speech (quotation marks omitted)). Moreover, Plaintiffs’ speech is political in nature because it
facilitates and encourages voting. See VoteAmerica v. Raffensperger, No. 21 Civ. 1390, 2023 WL
6296928, at *9 (N.D. Ga. Sept. 27, 2023) (“Encouraging others to vote or engage in the political
process is the essence of First Amendment expression.”). Accordingly, regulation of absentee
ballot application assistance “must be undertaken with due regard for the reality” that state
regulation will affect “the flow” of Plaintiffs’ core political speech. Schaumburg, 444 U.S. at 632.
2. Absentee Application Assistance Is Expressive Conduct.

And beyond involving direct speech, Plaintiffs’ absentee ballot application activities are
also expressive conduct. Fort Lauderdale Food Not Bombs v. City of Fort Lauderdale, 901 F.3d
1235, 1240 (11th Cir. 2018) (citing Texas v. Johnson, 491 U.S. 397, 404 (1989)) (noting that
constitutional protection for political expression “does not end at the spoken or written word,” but
extends with equal force to expressive conduct).
16
Conduct is sufficiently expressive to fall within the scope of the First Amendment if
(1) there was an “intent to convey a particularized message,” and (2) the “surrounding
circumstances” would lead a reasonable person to interpret the conduct as conveying “some sort
of message.” Holloman ex rel. Holloman v. Harland, 370 F.3d 1252, 1270 (11th Cir. 2004)
(emphasis in original). Several contextual factors are relevant to determining whether conduct is
likely to be understood as expressive, including: (1) whether the activity accompanies speech;
(2) whether the activity will be open to all; (3) whether the activity takes place in a traditional
public forum; (4) whether the activity addresses an issue of public concern; and (5) the history of
a particular symbol or type of conduct. See Burns v. Town of Palm Beach, 999 F.3d 1317, 1344–
45 (11th Cir. 2021); Food Not Bombs, 901 F.3d at 1242–44.
Plaintiffs’ absentee assistance activities constitute expressive conduct under this standard.
Plaintiffs intend to convey the message that voting is important and accessible, and that every
eligible voter should exercise their right to vote regardless of senior citizen status, disability, or
incarceration when they engage in absentee ballot application assistance. Alabama NAACP Decl.
¶ 6; LWVAL Decl. ¶¶ 7, 10-12, 17; GBM Decl. ¶ 7; ADAP Anderson Decl. ¶ 9. Thus, the first
Holloman factor is met. 370 F.3d at 1270.
And a reasonable person would interpret Plaintiffs’ absentee assistance activities as
conveying some message. Plaintiffs’ absentee assistance is intertwined with direct communication
about the importance and accessibility of voting. See League of Women Voters v. Hargett, 400 F.
Supp. 3d 706, 720 (M.D. Tenn. 2019) (“As a matter of simple behavioral fact . . . the collection
and submission of the applications gathered in a voter registration drive is intertwined with speech
and association.”) (citing League of Women Voters of Fla. v. Cobb, 447 F. Supp. 2d 1314, 1334
(S.D. Fla. 2006)) (quotation marks omitted). Plaintiffs also engage in voter assistance and
17
education events that are open to everyone, and which occur in both traditional public fora and
“places ‘historically associated with the exercise of First Amendment rights,’” such as public
parks. Food Not Bombs, 901 F.3d at 1242 (quoting Carey v. Brown, 447 U.S. 455, 460 (1980));
Alabama NAACP Decl. ¶ 11; LWVAL Decl. ¶ 14; GBM Decl. ¶¶ 11, 18. Plaintiffs’ absentee
assistance plainly addresses a matter of public concern. See Raffensperger, 2023 WL 6296928, at
*9 (noting that “discussing the right to vote and urging participation in the political process is a
matter of societal concern”). Finally, a reasonable observer would find the long history of voter
assistance efforts to counteract voting restrictions (including by Plaintiffs) and the Alabama
legislature’s history of attempting to criminalize and outlaw that same voter assistance to be
“instructive” in interpreting Plaintiffs’ assistance activities as conveying a pro-voting message.
Food Not Bombs, 901 F.3d at 1243; see, e.g., Alabama NAACP Decl. ¶ 16; LWVAL Decl. ¶¶ 1, 5;
GBM Decl. ¶¶ 22-23; ADAP Anderson Decl. ¶ 2; Doc. 1 ¶¶ 36-46; see also, e.g., NAACP v.
Alabama ex rel. Flowers, 377 U.S. 288 (1964); United States v. Atkins, 323 F.2d 733, 735 (5th Cir.
1963); Harris v. Siegelman, 695 F. Supp. 517 (M.D. Ala. 1988).
3. Absentee Ballot Application Assistance is Associational Activity.

Plaintiffs’ absentee application assistance also is protected associational activity. The First
Amendment’s broad protection of political expression also encompasses the “right to associate
with others in pursuit of” shared political goals. Roberts v. U.S. Jaycees, 468 U.S. 609, 622 (1984).
Indeed, “[i]t is beyond debate that freedom to engage in association for the advancement of beliefs
and ideas is an inseparable aspect of the . . . freedom of speech.” NAACP v. Alabama ex rel.
Patterson, 357 U.S. 449, 460 (1958). Accordingly, “state action which may have the effect of
curtailing the freedom to associate is subject to the closest scrutiny.” Id. at 460–61; see also
NAACP v. Button, 371 U.S. 415, 428–31, 37 (1963).
18
As noted, Plaintiffs engage in absentee ballot application assistance to express their mission
of ensuring equal access to the right to vote, regardless of race, age, disability, or incarceration
status. Plaintiffs also provide this assistance as a means of associating with voters, including those
who cannot vote without such assistance, as well as with other civic engagement organizations.
Alabama NAACP Decl. ¶ 12; LWVAL Decl. ¶ 19; GBM Decl. ¶¶ 19-20; ADAP Watkins Decl.
¶¶ 9-10. Accordingly, Plaintiffs’ absentee ballot application assistance is protected by the freedom
of association. See VoteAmerica v. Schwab, 576 F. Supp. 3d 862, 875 (D. Kan. 2021) (“Public
endeavors which ‘assist people with voter registration’ . . . and which expend resources ‘to broaden
the electorate to include allegedly under-served communities,’ qualify as expressive conduct which
implicates the First Amendment freedom of association.”) (citation omitted).
4. SB 1 Restricts the Amount and Effectiveness of Plaintiffs’ Political

Speech, Expressive Conduct, and Associational Activity.
The Challenged Provisions unconstitutionally burden political expression because they
reduce both the amount and effectiveness of Plaintiffs’ political speech, expressive conduct, and
associational activity. In Meyer, the Supreme Court held that a law impermissibly restricts political
expression where, as under the Payment Provisions here, Plaintiffs are prohibited from using paid
staff to communicate their message because such prohibition “has the inevitable effect of reducing
the total quantum of speech on a public issue,” such as participation in our country’s democratic
process through absentee voting. 486 U.S. at 423. 33
The First Amendment also protects a speaker’s right “to select . . . the most effective
means” of expressing their message. Id. at 424. The Challenged Provisions prevent Plaintiffs’ most
effective means of communicating that voters can and should exercise their right to vote, including
33
The Gift Provisions further may prohibit Plaintiffs from even lessening the burden of volunteering at long events
by providing volunteers at long events with food and water.
19
by voting absentee, and assisting them to do so. There is no other way for Plaintiffs to meaningfully
assist voters with their applications. Among these, the Payment, Prefilling, and Submission
Restrictions impede Plaintiffs from engaging in speech designed to encourage senior, disabled, or
incarcerated people to vote by helping them to fill out and submit their absentee ballot applications.
See Meyer, 486 U.S. at 424 (explaining that “direct one-on-one communication” is “the most
effective, fundamental, and perhaps economical avenue of political discourse”). SB 1 also serves
to undermine Plaintiffs’ message that every eligible person should vote, and that voting should be
accessible to all eligible voters. Likewise, the Gift Provisions impede Plaintiffs, inter alia, from
providing stamps and envelopes to be provided to voters who may need them. The Challenged
Provisions also restrict Plaintiffs from associating with voters and with one another to provide one-
on-one assistance with absentee ballot applications. Thus, by prohibiting absentee assistance, the
Challenged Provisions severely restrict the quantum and chosen method of Plaintiffs’ speech and
association.
5. Defendants Cannot Meet Their Burden to Establish That SB 1 Serves

a Compelling and Narrowly Tailored Government Interest.
State laws like SB 1 burdening the freedoms of speech and association are subject to strict
scrutiny. See Weaver v. Bonner, 309 F.3d 1312, 1319 (11th Cir. 2002) (“The proper test to be
applied to determine the constitutionality of restrictions on ‘core political speech’ is strict
scrutiny.”). Strict scrutiny applies to election-related laws that, as here, directly regulate protected
speech and associational activity. See, e.g., McIntyre v. Ohio Elections Comm’n, 514 U.S. 334,
344–47 (1995). “When a State’s election law directly regulates core political speech, we have
always subjected the challenged restriction to strict scrutiny and required that the legislation be
narrowly tailored to serve a compelling governmental interest.” Buckley v. Am. Const. L. Found.,
20
Inc., 525 U.S. 182, 207 (1999) (Thomas, J., concurring). 34 Under strict scrutiny, Defendants bear
the burden of establishing that SB 1 is necessary to serve a compelling and narrowly tailored
government interest. See Buckley, 525 U.S. at 207. This is a “well-nigh insurmountable” burden.
Meyer, 486 U.S. at 425.
Here, Defendants cannot satisfy strict scrutiny, or indeed any level of scrutiny, to justify
SB 1’s intrusion on constitutional rights. Defendants bear the burden of proving, through evidence
“that the recited harms are real, not merely conjectural, and that the regulation [of speech] will in
fact alleviate these harms in a direct and material way.” Turner Broadcasting Sys., Inc. v. F.C.C.,
512 U.S. 622, 664 (1994). Fatally, there is no interest—let alone a compelling interest—served by
SB 1. The sole purported interest for SB 1 was to target so-called “ballot harvesting” (i.e., the
collection of absentee ballots) by “groups or individuals seek[ing] to profit off of the absentee
voting process.” 35 But SB 1 does not regulate the collection of absentee ballots. It only regulates
assistance with applications to vote absentee and has no provisions about absentee ballots
themselves. Moreover, during SB 1’s consideration and passage, there was no evidence at all as to
why preventing absentee ballot collection is a compelling state interest or how any such interest is
served by SB 1. 36 There is simply no nexus—let alone a compelling and narrowly tailored one—
between any purported governmental interest and the conduct that SB 1 regulates.
Defendants also fail to meet their burden to show that the Challenged Restrictions are
narrowly tailored. There are far less restrictive means to achieve any interest regarding “ballot
34
Even if the Court determines that Plaintiffs’ absentee ballot application assistance is expressive conduct rather
than speech, strict scrutiny still applies to the Challenged Provisions. Content-based restrictions on expressive
conduct receive strict scrutiny. R.A.V. v. City of St. Paul, 505 U.S. 377, 382 (1992). The Challenged Provisions
are content-based because they apply only to expressive conduct related to a particular topic: absentee ballot
applications. Reed v. Town of Gilbert, Ariz., 576 U.S. 155, 163 (2015) (“Government regulation of speech is
content based if a law applies to particular speech because of the topic discussed.”).
35
Jacob Holmes, Legislature passes bill criminalizing “ballot harvesting”, Ala. Political Reporter (Mar. 8, 2024),
https://www.alreporter.com/2024/03/08/legislature-passes-bill-criminalizing-ballot-harvesting/.
36
See Exs. A & B to Bishop Decl.
21
harvesting.” Except in rare circumstances, Alabama prohibits anyone other than a voter from
collecting and returning absentee ballots. 37 Additionally, Alabama has long criminalized conduct
such as vote buying, voter intimidation, and voter bribery. 38 Furthermore, as next discussed, the
Challenged Provisions are also unconstitutionally vague and overbroad—thus by definition, not
narrowly tailored.
B. SB 1 is Unconstitutionally Vague.
The Challenged Provisions also are void-for-vagueness in violation of the First and
Fourteenth Amendments. “Vague laws contravene the first essential of due process” that
individuals must be afforded “fair notice of what the law demands of them.” United States v. Davis,
139 S. Ct. 2319, 2326 (2019) (quotation marks omitted). Here, in the First Amendment context,
vague laws raise especial concern because they “force potential speakers to steer far wider of the
unlawful zone than if the boundaries of the forbidden areas were clearly marked, thus silencing
more speech [and expression] than intended.” Wollschlaeger, 848 F.3d at 1320 (cleaned up).
Accordingly, “standards of permissible statutory vagueness” impacting First Amendment
freedoms “are strict.” NAACP v. Button, 371 U.S. 415, 432–33 (1963).
A law “can be impermissibly vague for either of two independent reasons.” Wollschlaeger,
848 F.3d at 1319–20. First, “if it fails to provide people of ordinary intelligence a reasonable
opportunity to understand what conduct it prohibits.” Id. Second, “if it authorizes or even
encourages arbitrary and discriminatory enforcement.” Id. Both conditions are plainly met here.
1. SB 1 Fails to Provide Ordinary People Reasonable Notice of What it

Prohibits.
First, the Challenged Provisions are impermissibly vague because they lend themselves to
varying interpretations and thus give no fair warning as to what they proscribe. Under SB 1, each
37
See Ala. Code § 17-11-9.
38
See Id. §§ 17-17-33, 38, 39.
22
of the terms “payment,” “gift,” “third-party,” “pre-fill,” “distribute,” and “submit” are triggers for
serious criminal liability but their scope is left ambiguous.
In particular, the Payment Provisions do not define what constitutes a “payment”
thereunder. It is unclear, for example, whether it is limited to monetary payments specifically for
the assistance of a voter with their absentee application, or whether an employee’s general salary,
reimbursement for general expenses, or even a non-monetary token would be implicated. Alabama
NAACP Decl. ¶ 18; GBM Decl. ¶ 29. “Payment” could even be read to cover funding that the
federal government gives Plaintiff ADAP to assist disabled and blind voters with their absentee
applications, ADAP Anderson Decl. ¶¶ 11-12; ADAP Watkins Decl. ¶ 14, and salaries paid by the
State of Alabama to jail and prison employees who might similarly help eligible incarcerated
voters, GBM Decl. ¶ 27. Absurdly then, agencies of the federal or state government could be held
liable for paying people who assist voters to apply absentee.
The Gift Provisions similarly fail to provide any (let alone reasonable) notice about what
they prohibit. Plaintiffs and others are left to wonder whether even providing the very materials
required to apply to vote absentee (e.g., a postage stamp, envelope, printing supplies, or a printed
unfilled application) are considered “gifts.” Moreover, it is unclear whether the term “gift” could
be construed as encompassing Plaintiffs’ provision of items like t-shirts, pens, or gas cards to
volunteers, regardless of whether their provision is expressly connected to absentee ballot
application assistance. Alabama NAACP Decl. ¶ 18; GBM Decl. ¶ 27.
SB 1 also does not define the term “third party,” which purports to identify who would be
regulated by the Payment and Gift Provisions. As a result, individuals who are conducting
necessary (and even mandatory) voter assistance activities are possibly liable under these
provisions. This includes potential Class C felony liability for any potential “third parties” in the
23
absentee application process such as staff in jails, prisons, and residential care facilities, as well as
employees or volunteers of organizations like Plaintiffs, who otherwise cannot obtain and/or return
an absentee ballot application and will thus be denied the right to vote. ADAP Watkins Decl. ¶ 11.
And similarly, due to this vagueness, the law also imposes potential Class B felony liability for
employers (like Plaintiffs and governmental entities) who employ such “third parties” to engage
in this assistance as part of their job duties. Id.
Next, SB 1 amorphously prohibits “prefill[ing]” an absentee application, triggering a Class
A misdemeanor under the Prefilling Provision (even without any “payment” or “gift” for such
conduct), or a Class B or C felony under the Payment or Gift Provisions. There is no temporal or
other guidance as to what constitutes “prefilling,” meaning that any assistance in completing an
absentee application could be deemed criminal under SB 1. Alabama NAACP Decl. ¶ 19; ADAP
Watkins Decl. ¶ 11. This term is especially vague given that SB 1 elsewhere conflictingly states
that “[a]ny applicant may receive assistance in filling out the application as he or she desires”—
suggesting that while an applicant may receive assistance without fear of criminal sanction, any
person providing it could be subject to criminal penalties. And because “prefilling” is criminalized
under the Prefilling Provision independent of the Payment or Gift Provisions, an even broader net
of would-be assistors (including family and neighbors who are not paid staff or volunteers) face
potential liability.
SB 1 also makes it a crime to “distribut[e]” another voter’s absentee application under the
Prefilling Restriction and Payment or Gift Provisions. But the scope of the term “distribute” is
wholly unclear in both places. For example, under the Prefilling Restriction, it is unclear whether
a person could be prosecuted even where a voter requests an application from Plaintiffs, accurately
provides Plaintiffs with the required information, and Plaintiffs merely fill in that information on
24
the application before “distributing” or handing it to the voter. Under the Payment or Gift
Provisions, it is unclear whether Plaintiffs’ paid staff and volunteers can even provide blank
applications to disabled or incarcerated voters who have no way to print the form for themselves
or if doing so itself runs afoul of the ban on “distribut[ing].” ADAP Watkins Decl. ¶ 11.
The Submission Restriction also is impermissibly vague. Although the Submission
Restriction identifies how a voter may “submit” their absentee application (i.e., in person or by
mail/commercial carrier), it provides no notice about whether a voter may consent to a third party
delivering their application on their behalf—including in situations where senior citizen, disabled,
blind, or incarcerated voters would otherwise have no way to return their application. Alabama
NAACP Decl. ¶ 21; GBM Decl. ¶ 22; ADAP Watkins Decl. ¶ 11. And because the Submission
Restriction applies to any assistor regardless of any “payment” or “gift,” it means that even a
grandchild who walks their grandparent’s application to the mailbox could face criminal liability
for doing so.
* * *
Rife with ambiguity, SB 1 will force Plaintiffs and others to steer “far wide of the unlawful
zone” for fear of engaging in speech and expressive activities that could risk criminal prosecution.
In the First Amendment context, the “government may regulate . . . only with narrow specificity.”
Button, 371 U.S. at 433. It fails to do so and the Challenged Provisions must be enjoined for this
reason alone.
2. The Challenged Provisions Authorize and Encourage Arbitrary

Enforcement.
The Challenged Provisions also must be enjoined because their ambiguity authorizes and
encourages arbitrary enforcement. See Kolender v. Lawson, 461 U.S. 352, 358 (1983) (“Where the
legislature fails to provide” law enforcement with “such minimal guidelines,” this “may permit a
25
standardless sweep that allows policemen, prosecutors, and juries to pursue their personal
predilections.”) (cleaned up and internal quotations omitted).
Indeed, during the legislative process, bill sponsor Senator Gudger testified that the
provision of a “stamp [or] sticker” could be considered an impermissible “gift” under the statute.39
He also acknowledged that SB 1 raised concerns about criminalizing “the grandfather giving the
grandson $5 for gas money.” 40 His testimony underscores that SB 1 is drafted so as to invite
arbitrary enforcement. SB 1 also was touted by Senator Gudger as responding to higher rates of
absentee voting in certain Black Belt counties during the 2022 primary election, 41 though he
offered no cogent argument suggesting there was any wrongdoing connected with the higher usage
rate of absentee ballots in those counties. 42 This presents serious risk that enforcement under SB 1
could be selectively focused on such areas (and on Plaintiffs and others who assist voters in these
parts of the state). Given this legislative history, and the extensive ambiguity of the statute, the
danger that the Challenged Provisions will be selectively enforced is substantial.
Without fair notice of what SB 1 proscribes, Plaintiffs and others who would provide voting
assistance are forced to choose between either “silence and self-censorship” or “proceed[ing] with
their speech and potentially fac[ing] punishment according to [] arbitrary whims.” Wollschlaeger,
848 F.3d at 1323. This cannot be countenanced, particularly not given the First Amendment
freedoms at stake.
39
Ex. A to Bishop Decl. at 33:17-20.
40
Id. at 28:7-9.
41
See Ex. A to Bishop Decl. at 28:11-29:12; John Sharpe, AL.com, “Absentee ‘ballot harvesting’ bill advances in
House amid questions about proof” (Feb. 28, 2024), https://www.al.com/news/2024/02/absentee-ballot-
harvesting-bill-advances-in-house-amid-questions-about-proof.html.
42
See id.
26
C. SB 1 is Unconstitutionally Overbroad.
The Challenged Provisions also must be struck down as unconstitutionally overbroad.
Laws restricting First Amendment freedoms “may be invalidated as overbroad if a substantial
number of its applications are unconstitutional, judged in relation to the statute’s plainly legitimate
sweep.” United States v. Stevens, 559 U.S. 460, 473 (2010) (quotations omitted); see FF Cosmetics
FL, Inc. v. City of Miami Beach, 866 F.3d 1290, 1304 (11th Cir. 2017) (citation omitted).
SB 1 regulates a sweeping amount of non-commercial political speech and constitutionally
protected expressive conduct, see supra Argument Section II.A, and lacks any reasonable bounds
in doing so. As discussed, SB 1 supposedly targets “ballot harvesting” yet it relates only to absentee
applications and does not advance any governmental interest in regulating absentee ballots.
Further, the Payment or Gift Provisions so broadly criminalize voter assistance that it appears to
sweep in even those employees and volunteers who help disabled, blind, and low literacy voters
entitled to such assistance under Section 208 of the VRA or incarcerated voters who cannot vote
without such assistance. Further confirming their overbreadth, the Payment Provisions also
apparently prohibit governmental employees such as elections or prison officials from helping
voters obtain, complete, and submit their absentee applications as part of their jobs. Indeed, even
employees or volunteers of political campaigns could be liable under these provisions—flatly
inconsistent with the Supreme Court’s repeated admonition that the First Amendment “has its
fullest and most urgent application precisely to the conduct of campaigns for political office.” Fed.
Election Commission v. Cruz, 596 U.S. 289 (2022) (quotation marks and citation omitted).
The Prefilling and Submission Restrictions are similarly untethered to any legitimate
purpose: under these restrictions, anyone (even a family member helping another family member,
or someone helping a voter entitled to such help under Section 208) might be charged with a
misdemeanor for writing the voter’s name on their application or placing their completed
27
application in the mailbox. Moreover, the Prefilling Restriction also appears to apply even where
there could be no conceivable concern because the application is requested by a voter, the voter
provides their assistor the information to include on the form, and that information is accurate.
This expansive reach blatantly exceeds any legitimate sweep and violates the First Amendment.
III. Plaintiffs Are Substantially Likely to Succeed on the Merits of Their Claim Under
Section 208 of the Voting Rights Act
Section 208 of the VRA provides: “Any voter who requires assistance to vote by reason of
blindness, disability, or inability to read or write may be given assistance by a person of the voter’s
choice,” except for “the voter’s employer or agent of that employer or officer or agent of the voter’s
union.” 52 U.S.C. § 10508; see Arkansas United v. Thurston, 626 F. Supp. 3d 1064, 1085 (W.D.
Ark. 2022) (“With the exception of the voter’s employer or union representative, Congress wrote
§ 208 to allow voters to choose any assistor they want.”).
Section 208 “plainly contemplates more than the mechanical act of filling out the ballot
sheet” and “includes steps in the voting process before entering the ballot box.” OCA-Greater
Houston v. Texas, 867 F.3d 604, 615 (2017). Section 208’s broad protections extend to the absentee
application process. See 52 U.S.C. § 10310(c)(1) (defining “vote” and “voting” under the VRA to
encompass “all action necessary to make a vote effective . . . , including, but not limited to, . . .
action required by law prerequisite to voting, casting a ballot, and having such ballot counted
properly.”).
Congress enacted Section 208 specifically to address the “significant effect” that limiting
assistance has on those “groups of citizens [who] are unable to exercise their rights to vote without
obtaining assistance in voting” and “avoid denial or infringement on their right to vote.” S. Rep.
No. 97-417, 62 (1982). As explained, disabled, blind, and low literacy voters are especially likely
to need to vote absentee and require assistance with the absentee voting applications.
28
The Challenged Provisions of SB 1 violate Section 208 by infringing on the universe of
lawful assistors provided by Section 208 and as a result, obstructing Congress’s purposes and goals
in ensuring equal access for disabled, blind, and low literacy voters. And because SB 1 conflicts
with Section 208, SB 1 is preempted.
A. SB 1 Infringes on Federally Protected Assistance to Disabled, Blind, and Low

Literacy Voters.
Restrictions that preclude or limit assistors violate Section 208. See Arkansas United, 626
F. Supp. 3d at 1085 (finding Section 208 preempted state law prohibiting assistors from helping
more than six voters). In enacting Section 208, “Congress contemplated the vulnerability of
[certain] voters when it discussed providing unrestricted choice of assist[ors] and provided two
explicitly excluded groups. States are not permitted to limit the right to assistance further.”
Disability Rights N.C. v. N.C. State Bd. of Elections, No. 21 Civ. 361, 2022 WL 2678884, at *5
(E.D.N.C. July 11, 2022).
Here, by imposing criminal penalties on both assistors and voters, SB 1 violates Section
208 because it impermissibly narrows the right of disabled, blind, and low literacy voters to receive
assistance from a person of their choosing. Because SB 1 “provides that there shall be a criminal
outcome for violations [by assistors]; [the danger of prosecution] is not speculative or imaginary
in nature.” Disability Rights Miss. v. Fitch, No. 23 Civ. 350, 2023 WL 4748788, at *3 (S.D. Miss.
July 25, 2023) (emphasis in original). Rather, “the contents of the statute promise to chill the
enthusiasm of those affected.” Id. Among other things, SB 1’s Payment or Gift Provisions
criminalize any person who “receive[s] a payment or gift” for assisting a voter (a Class C felony)
and appears to exclude such assistors like Plaintiffs from giving assistance to voters entitled to it
under Section 208. These provisions also criminalize those paying or giving gifts to assistors (a
Class B felony)—with no distinction for Section 208-eligible voters who might offer payment or
29
gift in exchange for the assistance, like a small token of appreciation. The Prefilling and
Submission Restrictions likewise criminalize application assistance such as writing a voter’s name
on their form or placing the voter’s form in the mail for them—even assistance for Section 208-
eligible voters who are physically unable to carry out these essential steps in applying to vote
absentee. This clearly violates the protections enshrined in Section 208.
To be clear, that SB 1 recites Section 208’s language in § 17-11-4(e) does not cure this
violation. Like Section 208, SB 1 Section 17-11-4(e) states: “Any voter who requires assistance to
vote by reason of blindness, disability, or inability to read or write may be given assistance by a
person of the voter’s choice,” except for “the voter’s employer or agent of that employer or officer
or agent of the voter’s union.” But at the same time, SB 1 contains the Challenged Provisions
criminalizing broad categories of assistance—with no distinction, as discussed, for situations
where assistance is being given pursuant to § 17-11-4(e) (or Section 208). Cf. OCA-Greater
Houston, 867 F.3d at 615 (“[A] state cannot restrict this federally guaranteed right [under Section
208] by enacting a statute tracking its language, then defining terms more restrictively than as
federally defined.”). SB 1 also does not define “vote” or “voting” as broadly as the VRA—it does
not define those terms at all—further compounding the ambiguity as to what conduct is permitted.
Therefore, it appears that a voter or assistor engaging in Section 208-protected conduct could still
face liability under the Challenged Provisions.
SB 1’s separate, differently worded provision protecting military and overseas voters
confirms the failure of SB 1 to protect Section 208 assistance. Directly below Section 17-11-4(e)
and in the same section as the Challenged Provisions, Section 17-11-4(f) provides: “Voters voting
by absentee ballot through the Uniformed and Overseas Citizens Absentee Voting Act are not
subject to this section” (emphasis added). Section 17-11-4(f) makes plain that the Legislature
30
understood how to exempt other federally protected voters fully and without ambiguity from the
Challenged Provisions. By contrast, Section 17-11-4(e) pointedly does not contain similar
language stating that conduct thereunder is “not subject to this section” (i.e., not subject to the
Challenged Provisions). That the Legislature did not include this “not subject to” language for
Section 208 voters or assistors underscores this violation of federal law.
B. Because SB 1 Conflicts with Section 208, It Is Preempted.
The Supremacy Clause of the United States Constitution “invalidates state laws that
interfere with or are contrary to federal law.” Hillsborough Cty., v. Automated Med. Lab., Inc., 471
U.S. 707, 712 (1985) (internal quotation omitted). A state law conflicts with a federal law when it
“stands as an obstacle to the accomplishment and execution” of Congress’s “full purposes and
objectives.” Hines v. Davidowitz, 312 U.S. 52, 67 (1941).
As set forth above, SB 1 violates Section 208 because it infringes on the right of voters
who are blind, disabled, and low literacy to voting assistance from an assistor of their choice.
Further, because of its restrictions on these voters, SB 1 would criminalize conduct expressly
protected and authorized under the VRA. SB 1 thus creates an impermissible barrier to
accomplishing the full purposes and goals of Congress under the statute. Accordingly, SB 1 is
constitutionally preempted by Section 208.
IV. Plaintiff ADAP Is Substantially Likely to Succeed on the Merits of Its HAVA Claim.
Plaintiff ADAP is also substantially likely to succeed on the merits of its claim that SB 1 is
preempted by HAVA, 43 a federal law which provides ADAP with funding to undertake absentee
application assistance that is now apparently criminalized by SB 1.
In enacting HAVA, Congress created a grant called “Protection and Advocacy for Voting
43
HAVA is codified at 52 U.S.C. §§ 20901 to 21145.
31
Assistance” (“PAVA”). The PAVA program is an integrated system of federal P&A grants to states
to support legal advocacy services to protect the legal and human rights of individuals with
disabilities and gives state P&As broad rights in carrying out their work. 44 Under PAVA, the federal
government is required “to pay the protection and advocacy [(“P&A”)] 45 system of each State to
ensure full participation in the electoral process for individuals with disabilities, including
registering to vote, casting a vote, and accessing polling places.” 52 U.S.C. § 21061(a). ADAP is
the designated Alabama P&A for all the federal P&A grant programs, including PAVA. ADAP
Anderson Decl. ¶ 2.
ADAP has a full-time employee whose primary duties focus on implementing the agency’s
PAVA grant mandate: ensuring the “full participation in the electoral process for individuals with
disabilities, including registering to vote, casting a vote, and accessing polling places.” 52 U.S.C.
§ 21061(a); ADAP Anderson Decl. ¶ 7. This requires the employee to work with and assist voters
with disabilities, including with absentee voting, and to provide education to other organizations
or persons on what and how someone can assist a person with a disability to vote. ADAP Watkins
Decl. ¶ 3. This employee provides direct assistance to voters in filling out their absentee ballot
applications. Id. ¶ 5.
Under SB 1, however, ADAP’s required work under the PAVA grant subjects the
organization and its employees to potential criminal liability. Specifically, the Payment Provisions
specifically prohibit and make it a Class B felony for someone to “receive a payment” to assist a
44
Protection and Advocacy for Persons with Developmental Disabilities (“PADD”) program. 42 U.S.C. §§ 15041-
15045; Protection and Advocacy for Individuals with Mental Illness Act (“PAIMI”), 42 U.S.C. § 10801-10851;
the Protection and Advocacy for Individual Rights Program of the Rehabilitation Act, (“PAIR”) 29 U.S.C. § 794e;
Protection and Advocacy for Assistive Technology (“PAAT”), 29 U.S.C. §§ 3001-3058; Protection and Advocacy
for Beneficiaries of Social Security (“PABSS”), 42 U.S.C. §§ 1320b-21; Protection and Advocacy for Individuals
with Traumatic Brain Injury (“PATBI”), 42 U.S.C §§ 300d-53; Protection and Advocacy for Voting Access
(“PAVA”), 52 U.S.C. §§ 21061-21062; the Client Assistance Program (“CAP”), Public Law 113-128; Protection
and Advocacy for Beneficiaries with Representative Payees (“PABRP”), Public Law 115 – 165.
45
As defined in 42 U.S.C. § 15002.
32
voter, including a voter with a disability. As explained, SB 1’s recitation of Section 208’s text does
not shield assistors from liability, even where the assistor is required by federal law to provide that
assistance, as ADAP is here. SB 1 thus apparently criminalizes and prohibits conduct explicitly
authorized under HAVA as applied to ADAP. Indeed, the federal government may run afoul of the
Payment Provisions by following federal law in allocating funds under PAVA.
As discussed, where a state law “stands as an obstacle to the accomplishment and
execution” of Congress’s “full purposes and objectives,” it is preempted under the Supremacy
Clause. Hines, 312 U.S. at 67. SB 1 makes it impossible for ADAP to fulfill its duties or
congressional mandate under PAVA to ensure the “the full participation of persons with disabilities
in the voting process.” 52 U.S.C. § 21061(a). SB 1’s prohibitions are thus preempted by HAVA.
V. Plaintiffs Will Suffer Irreparable Harm Absent Preliminary Relief.

Absent a preliminary injunction, Plaintiffs will suffer irreparable injuries with respect to
the November 2024 general election and beyond. “The loss of First Amendment freedoms, for
even minimal periods of time, unquestionably constitutes irreparable injury.” Fort Lauderdale
Food Not Bombs v. City of Fort Lauderdale, 11 F.4th 1266, 1286 (11th Cir. 2021) (quoting Elrod
v. Burns, 427 U.S. 347, 373 (1976)). SB 1 threatens to penalize Plaintiffs’ speech and conduct,
causing Plaintiffs to dramatically reduce and fundamentally alter their communications to Alabama
voters. This “direct penalization” of First Amendment rights is “per se irreparable.” Otto v. City of
Boca Raton, Fla., 981 F.3d 854, 870 (11th Cir. 2020).
Moreover, SB 1 severely burdens, if not entirely forecloses, the right to vote for Plaintiffs’
members and constituents and many other Alabamians—including senior, disabled, blind, low
literacy, and incarcerated voters who depend on absentee voting but cannot vote absentee without
assistance with their applications. “[M]issing the opportunity to vote [amounts to] an irreparable
[injury].” Gonzalez v. Governor of Ga., 978 F.3d 1266, 1272 (11th Cir. 2020). “[O]nce the election
33
occurs, there can be no do-over and no redress. The injury to these voters is real and completely
irreparable if nothing is done to enjoin th[ese] law[s].” League of Women Voters of N.C. v. North
Carolina, 769 F.3d 224, 247 (4th Cir. 2014).
Irreparable harm also exists where, as here, voting can become so burdensome for citizens
with disabilities or low literacy skills that “they may be dissuaded from attempting to vote at all.”
Westchester Disabled on the Move, Inc. v. Cnty. of Westchester, 346 F. Supp. 2d 473, 477-78
(S.D.N.Y. 2004); cf. also Gaston County v. United States, 395 U.S. 285, 295 (1969) (accepting that
some low literacy voters may “not attempt to register, knowing that they could not meet the [state’s
strict] standard”); S. Rep. 97-417, at *62 (noting that some Section 208 voters faced with casting
their vote under “adverse circumstances” will “in fact elect to forfeit their right to vote”). Beyond
the risk of complete disenfranchisement, blind, disabled, or low literacy voters face irreparable
harm even if they ultimately find a way to vote but experience additional burdens to doing so. Cf.
Westchester Disabled on the Move, 346 F. Supp. 2d at 477-78 (explaining that denying disabled
voters access to in person voting creates irreparable injury even if they are still ultimately able to
vote another way).
Further, Plaintiffs who would usually assist voters will lose opportunities to do so under SB
1. Those missed opportunities to help voters constitute irreparable harm not only because
unassisted voters may not be able to vote at all but also because those opportunities for voter
engagement will have been lost forever. The potential fear of prosecution under SB 1 also
constitutes irreparable harm for all Plaintiffs. See Ga. Latino All. for Human Rights v. Governor of
Ga., 691 F.3d 1250, 1269 (11th Cir. 2012). SB 1 additionally frustrates Plaintiffs’ missions by
diverting resources. Thus, Plaintiffs unequivocally face irreparable harm if SB 1 is not enjoined.
34
VI. The Balance of the Equities Weighs in Plaintiffs’ Favor and a Preliminary Injunction
Serves the Public Interest.
The ongoing injury to Plaintiffs far outweighs any interest that the Defendants may have in
enforcing SB 1, and the public will be best served by an injunction. Plaintiffs are suffering grave
violations of their constitutional and statutory rights. The State has no interest in defending
provisions that violate federal law. See United States v. Alabama, 691 F.3d 1269, 1301 (11th Cir.
2012) (“Frustration of federal statutes and prerogatives are not in the public interest.”); KH
Outdoor, LLC v. City of Trussville, 458 F.3d 1261, 1272 (11th Cir. 2006) (holding that neither city
nor public had any interest in “enforcing an unconstitutional ordinance”). And since Defendant
Allen has stated that SB 1 will first be enforced for the November 2024 general election, an
injunction now is in the public interest as it preserves the status quo.
CONCLUSION
For the foregoing reasons, Plaintiffs respectfully request that their Motion for Preliminary
Injunction be granted.
DATED: May 2, 2024
Respectfully submitted,
/s/ Alison Mollman /s/ Anuja D. Thatte

Alison Mollman Anuja D. Thatte*
Laurel Hattix NAACP LEGAL DEFENSE &
ACLU OF ALABAMA EDUCATIONAL FUND, INC.
P.O. Box 6179 700 14th Street NW, Suite 600
Montgomery, AL 36106 Washington, DC 20009
(510) 909-8908 (202) 249-2170
amollman@aclualabama.org athatte@naacpldf.org
Amir Badat*
/s/Valencia Richardson Tiffani Burgess*
Valencia Richardson* Uruj Sheikh*
Alice Huling* NAACP LEGAL DEFENSE &
Molly Danahy* EDUCATIONAL FUND, INC.
Ellen Boettcher* 40 Rector Street, 5th Floor
Reginald Thedford* New York, NY 10006
35
CAMPAIGN LEGAL CENTER (212) 965-2200

1101 14th Street NW, Suite 400 abadat@naacpldf.org
Washington, DC 20005 tburgess@naacpldf.org
(202) 736-2200 usheikh@naacpldf.org
vrichardson@campaignlegalcenter.org
ahuling@campaignlegalcenter.org /s/ Jess Unger
mdanahy@campaignlegalcenter.org Bradley E. Heard*
eboettcher@campaignlegalcenter.org Sabrina Khan*
rthedford@campaignlegalcenter.org Jess Unger*
Ahmed Soussi*
/s/ William Van Der Pol, Jr. SOUTHERN POVERTY LAW CENTER
William Van Der Pol, Jr. 150 E. Ponce de Leon Avenue,
Larry G. Canada Suite 340
ALABAMA DISABILITIES Decatur, GA 30030
ADVOCACY PROGRAM (470) 521-6700
University of Alabama bradley.heard@splcenter.org
Box 870395 sabrina.khan@splcenter.org
Tuscaloosa, AL 35487 jess.unger@splcenter.org
(205) 348-4928 ahmed.soussi@splcenter.org
wvanderpoljr@adap.ua.edu
lcanada@adap.ua.edu
*Admitted pro hac vice
36
CERTIFICATE OF SERVICE
I hereby certify that I have electronically filed a copy of the foregoing and accompanying
documents with the Clerk of Court using the CM/ECF system which provides electronic notice of
filing to all counsel of record.
DATED: May 2, 2024
/s/ Laurel Hattix

Laurel Hattix
ACLU OF ALABAMA
P.O. Box 6179
Montgomery, AL 36106
(510) 909-8908
37
2024 May-03 AM 09:52
U.S. DISTRICT COURT
N.D. OF ALABAMA

FOR THE NORTHERN DISTRICT OF ALABAM A
ALABAMA STATE
CONFERENCE OF THE
NAACP; LEAGUE OF WOMEN
VOTERS OF ALABAMA;
LEAGUE OF WOMEN VOTERS
OF ALABAMA EDUCATION
FUND; GREATER
BIRMINGHAM MINISTRIES;
and ALABAMA DISABILITIES
ADVOCACY PROGRAM, Case No. 2:24-cv-00420-RDP
Plaintiff,
v.
STEVE MARSHALL in his

official capacity as Alabama
Attorney General, WES
ALLEN in his official capacity
as Alabama Secretary of State,
Defendants.
DECLARATION OF LAUREN BISHOP
Pursuant to 28 U.S.C. § 1746, I, LAUREN BISHOP, declare as follows:

1. I am a transcriber employed by Planet Depos. I am over the age of
18 and competent to testify as to the matters set forth in this affidavit
based upon my own personal knowledge. This declaration is submitted to
verify the contents of the attached transcripts.
2. On March 4, 2024, I accessed the video footage of the February 28,
2024 meeting of the Alabama House Constitution, Campaigns and
Elections Committee from The Alabama Channel website, at
https://alabamachannel.ompnetwork.org/embed/sessions/285921/alabam
a-house-constitution-campaigns-and-elections-committee. A true and
correct transcript of this meeting is attached as Exhibit A to this
declaration.
3. On April 25, 2024, I accessed the video footage of the February 7,
2024 meeting of the Alabama Senate State Government Affairs
Committee from The Alabama Channel website, at
https://alabamachannel.ompnetwork.org/embed/sessions/284244/alabam
a-senate-state-government-affairs-committee. A true and correct
transcript of this meeting is attached as Exhibit B to this declaration.

I declare under penalty of perjury and the laws of the United States
of America that the foregoing is true and correct to the best of my
knowledge.
Executed this 26th day of April, 2024, in Wexford, Pennsylvania.
LAUREN BISHOP
EXHIBITA
Transcript of Alabama House

Constitution - Campaigns and
Elections Committee Meeting
Date: February 28, 2024
Case: Transcription Services
Planet Depos
Phone: 888-433-3767
Fax: 888-503-3767
Email: transcripts@planetdepos.com
www.planetdepos.com
WORLDWIDE COURT REPORTING & LITIGATION TECHNOLOGY

1
2
3
4
5
6
7 In re:
8 ALABAMA HOUSE CONSTITUTION
9 CAMPAIGNS AND ELECTIONS COMMITTEE MEETING
10
11 RECORDED HEARING
12 Wednesday, February 28, 2024
13
14
15
16
17
18
19
20 Job No.: 528713
21 Pages: 1 - 46
22 Transcribed by: Lauren Bishop
Transcript of Alabama House Constitution - Campaigns and Elections Committee Meeting
2
1 SENATOR GUDGER: So voting is secure,

2 honest and it knocks down what I call the last leg of
3 a wave that the bad actors out there are trying to
4 steal our elections on the local, state and federal
5 elections. This bill should not be read as a
6 Republican bill. This bill should not be read as a
7 Democrat bill. This bill should not be read as an
8 independent bill. This should be a bill for every
9 Alabamian to have fair and honest elections. After
10 doing some research I found a quote that kind of
11 represented I feel like the encompassed of this bill
12 and that is the Democratic Republic cannot survive if
13 election laws allow voters to commit fraud easily.
14 Right now, you're able to commit fraud easily through
15 ballot harvesting. We're trying to stop that through
16 SB1. To be clear, we did not change anything having
17 to do with disabilities, right? People that are deaf
18 or blind or veterans. You can get help from anybody
19 to help fill in your application that you want to and
20 that was a big deal with everyone that I talked to
21 her across the state. If someone needed help filling
22 in their application, they can have help and they can
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1 pick and choose whoever they want to, as long as you

2 sign the application and whoever helped you signed
3 the application and turn it back in yourself. That's
4 kind of an overview. I'll stop there. It is a pretty
5 simple bill, but then I'll be more than happy to come
6 up later and give final remarks if you want me to.
7 CHAIRMAN BOB FINCHER: Okay. We do and
8 thank you Senator Gudger. Appreciate that. All right.
9 We're going into the public hearing. I want to remind
10 everyone we -- we will have a maximum of six speakers
11 and y'all have already taken care of that it looks
12 like. Down here you will have three minutes each.
13 Cliff, will you keep the time for us and at when two
14 minutes have passed, Cliff will say one minute and
15 then when the three minutes is over, he will say time
16 and your time is up. He will quit addressing the
17 committee at that point and we will start -- we will
18 start with -- please turn your phones off. If you
19 have any electrical devices, please cut them off. We
20 don't want to interrupt this. Okay? So that would be
21 appreciated very much. Our first speaker that is
22 signed up to speak today is Tori Williams. Is it
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1 Terri or Tori? Tori. I got it right to start with.

2 Okay. Ms. Williams, would you please begin your
3 remarks?
4 TORI WILLIAMS: Yes. Good morning. My name
5 is Tori Williams. I'm an employee with Greater
6 Birmingham Ministries. We are a faith based,
7 nonpartisan Social Services advocacy -- and advocacy
8 organization. We provide voter education and lessons
9 and Civic engagement among other things to various
10 communities and populations. One such population is
11 the incarcerated population. Assisting them with
12 absentee ballot applications and absentee ballot is a
13 critical step in maintaining their connection to
14 society, aiding and smoother re-entry process and
15 reducing the likelihood of recidivism. Our role in
16 facilitating their right is not just assistance. Its
17 restoration of their dignity and a reaffirmation of
18 their voice in our democracy. To criminalize the act
19 of aiding these individuals as SB1 proposes is to
20 misunderstand the essence of democracy itself. The
21 threat of felony charges for those committed to
22 democratic engagement is not just disproportionate,
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1 it's fundamentally unjust. This bill does not address

2 voter fraud. It silences the already muted voices of
3 society's most vulnerable. Thank you for your
4 opportunity to share my concern.
5 CHAIRMAN BOB FINCHER: Thank you very much.
6 We will hold any committee comments or questions
7 until after all the speakers have appeared and so if
8 you have a question just remember and we'll -- we'll
9 -- we'll come from there. All right. Is it Armani
10 Benson? Okay. Would you please come forward and
11 present your comments on the bill?
12 ARMANI BENSON: Greetings. My name is
13 Armani Benson. I'm a senior who attends Alabama State
14 University. I currently hold positions as the
15 president Pi Sigma Alpha and a member of the NAACP.
16 College and Civic organizations help young adults
17 become active within their community and politics.
18 This is why the SB1 bill cannot be passed. For
19 obtaining the absentee ballot bill application for
20 someone else, SB1 will charge the individual with a
21 misdemeanor, provided absentee ballot assistance for
22 money who are also constant -- will also constitute a
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1 felony. The meaning staff members who facilitate

2 absentee voting as a part of their job could be
3 charged with a felony under SB1. If SB1 passed, it
4 could penalize student organizations, faculty and
5 staff that facilitate voting and stifle civic
6 participation on campuses. This bill will have a
7 negative impact for college students which will
8 resolve in the decline of young adults voting,
9 overcrowding in prisons that Alabama and also the
10 records and lives of many young adults will be
11 tarnished as if they're criminals. SB1 will also
12 dismantle the relationship between college students
13 and our local representatives. All 14 of the
14 University's partners of the higher education and
15 partnership have Civic and colleague organizations.
16 Meaning funding will be cut for those national
17 organizations of those schools and students, our
18 lives to be criminalized. Example, if a person is
19 disabled therefore, he gives the college student gas
20 money for absentee ballot assistance. He will be
21 charged with the crime. There are more current issues
22 now that will have a ripple effect of SB1 is passed.
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1 Colleges in Alabama already faced a shortage of

2 professor so how would we hired new professor for
3 simply doing their job could result in becoming a
4 felony. Also, the rate of Alabama state colleges will
5 continuously decrease. Finally as a result students
6 and faculty being arrested for helping with absentee
7 ballots, there's a possibly that alumni and corporate
8 funding could decline from these college
9 universities. How are you were getting the trust of
10 the students and faculties from your Alma Maters?
11 Passing SB1 will dismantle the trust and freedoms of
12 our constitutional rights as voters and also will
13 cause more problems financially and legally and cause
14 a decline in college and college voter registration.
15 So I ask that you consider -- consider all of these
16 causes and effects that will happen if SB1 is passed.
17 Thank you for your time.
18 CHAIRMAN BOB FINCHER: Thank you. All
19 right. Ashley Griffin. Okay, Ashley.
20 ASHLEY GRIFFIN: Good morning and
21 greetings, everybody. My name is Ashley Griffin. I'm
22 a 21-year-old political science major from East
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1 Lansing, Michigan. I currently serve as the chief

2 justice for the Student Government Association. I'm
3 also the president of the National Association of
4 Blacks and Criminal Justice and also the vice
5 president of Pi Sigma Alpha with Armani. I'm here to
6 speak today on SB1. This is the third consecutive
7 year this bill has been brought up to the legislature
8 and SB1 would charge people with a felony for simply
9 receiving someone else's absentee ballot whether you
10 are a member of a Civic organization, a church or
11 just to be a volunteer. And this one mainly affect
12 senior citizens, college students and people with
13 disabilities and also not only that but voters in
14 Alabama jails and prisons. My question to everybody
15 here today is, say you have a disabled college
16 student that lives on campus, how do you expect them
17 to be able to go vote if they can't even pay their
18 friend to take them to go vote or to fill out that
19 absentee ballot. How -- also not only that, but if
20 you have a senior citizen who can no longer drive
21 themselves, how do you expect them to get to their
22 absentee ballot if they can't even for example, go to
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9
1 their local church and register to vote that way

2 without it being considered a felony? Do you think
3 that is valid for someone to have a class C felony
4 just for helping out their senior citizen at their
5 local church or for someone to help their friend out
6 who it can't even assist themselves to go vote? And
7 how also -- how can we expect these people to still
8 exercise their right to vote under these limitations
9 or deliver absentee ballots or currently to those
10 currently incarcerated in jail or prison who depend
11 on Civic organizations to deliver their ballots to
12 the jails and vote? Not to mention, the state of
13 Alabama already has a backed-up court system and also
14 overcrowding jails and prisons. Why would we put
15 people away for felony -- why would we put people
16 away for felonies when we already have limited
17 resources that cannot be used and are -- that should
18 not be used for people who are just simply trying to
19 exercise their right to vote. I hope you guys think
20 about all these things when it comes to SB1 and thank
21 you for your time.
22 CHAIRMAN BOB FINCHER: Thank you, Ashley.
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1 Mr. John Wall.

2 JOHN WALL: Gentlemen, I want to start by
3 thanking -- gentlemen and ladies, I want to start by
4 thanking you for your service. This is a complicated
5 issue and I share the concerns of many people about
6 the potential for affecting voters. Our priority as a
7 state and as a body should be making sure that every
8 person's vote is counted, that everyone has the
9 ability to vote and that -- and no one's vote is
10 tampered with. And I think that's the priority of
11 this bill. I appreciate the substitute. I think the
12 substitute is a stronger version. I think it makes
13 sure we safeguard people's right to vote but also to
14 help others vote without -- in a respectful manner.
15 This is not a hypothetical situation. This is not
16 something that we don't know is happening. There are
17 people who are having their votes stolen or usurped
18 through the ballot harvesting process. There's a
19 lawsuit right now in Conecuh County where a candidate
20 was, in my opinion, deprived the right to hold the
21 office. He was duly elected to because of this
22 situation. And I expect that to be litigated --
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1 litigated soon in court and for the courts to rule

2 within that decision. So this is not a hypothetical
3 situation. We know that it happens. The only question
4 is to what extent? And I think for me, the priority
5 is making sure that every single person has your vote
6 counted the way -- they want it to be counted and
7 that it's not tampered with. The situations we're
8 seeing are people who are having someone help them
9 with their ballot and then that person helping with
10 their ballot actually votes for them. And that's a
11 tragedy and it's a tragedy that we do need to realize
12 is happening and we do need to realize that needs a
13 solution. So I think that's what we're looking at.
14 That's what this bill is about. It's about making
15 sure that every single vote is safeguarded and every
16 single vote has the ability to be counted as the
17 person wanted it to be wanted -- wanted it to be
18 cast. So I rise in support of this bill. I think it
19 is a common-sense solution to a problem that is
20 happening. I think it is a safeguard that puts in
21 place a measure that allows people to know that their
22 boats are secure, and I think that's an important
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1 thing for the state of Alabama to do and I appreciate

2 all of your work in this process. Thank you.
3 CHAIRMAN BOB FINCHER: Thank you, sir. Mrs.
4 Norma Sanders.
5 NORMA SANDERS: Good morning. On behalf of
6 the NAACP, I, Norma J. Sanders, would like to make
7 the following statement. I come before you today
8 saying the Senate Bill One, would change our Civic
9 organization employees, volunteers or individuals
10 with a crime simply for assisting their neighbors and
11 exercising their right to vote by absentee ballot.
12 State Senator Gudger proposed Senate Bill One to
13 create barriers to voting in Alabama. We firmly
14 believe Senate Bill One could pose significant
15 challenges for seniors, college students, people with
16 disabilities and people living inside Alabama prisons
17 and jails. The NAACP has for many years assisted
18 people with their absentee voting because we want to
19 ensure everyone's vote counts. Here we stand today
20 saying this is another attack on our Constitutional
21 rights to vote. I am reminded of March 7th, 1965 when
22 from Selma to Montgomery March. We as human beings
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1 being must not forget this protest. It was due to the

2 violation of individuals constitutional rights to
3 vote. Remember Senate Bill One will have a negative
4 impact on NAACP Civic engagement work. We urge the
5 Alabama legislature to kill the Senate Bill One
6 before it causing irreparable harm to our state.
7 Thank you so very much.
8 CHAIRMAN BOB FINCHER: Thank you, ma'am.
9 Next, Mr. Travis Jackson. Is he here?
10 TRAVIS JACKSON: Thank you, Chairman and
11 members of the committee. My name is Travis Jackson.
12 I am a Alabama District 31 and 88 citizen. I am also
13 a black lives/voters matter activists who volunteers
14 with a Civic org by the name of Roland to the polls,
15 which is a voting rights Advocate group of like-
16 minded people transporting voters to their accurate
17 voting polls. And I'm also an Iraq veteran and I
18 harshly stand against Senate Bill One. Senate Bill
19 One is the total opposite of aiding voters who want
20 to exercise their freedom of speech or freedom to
21 vote via absentee ballot. Last time I checked it, the
22 year was 2024, not 1924. Racial barriers such as
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1 literacy test, extensive legal documents and a

2 notorious how many marbles are in a jar quiz were put
3 in place during the calm -- during the Reconstruction
4 Era to discourage African-Americans from voting. This
5 bill is just a modern-day reflection. If you want to
6 call it like it is, Senate Bill One is the fabric of
7 the white supremacist cloth. Also Senate Bill One
8 criminalizes anyone receiving funds or delivering
9 payments for Absentee assistance. For example, if a
10 pregnant person, especially someone who is in with
11 who is within their second and third trimester
12 provides gas money to their non-relative neighbor for
13 issuing and absentee ballot, they both can be charged
14 with a felony. It's quite interesting -- it is quite
15 interesting how after the Millie -- Allen v. Milligan
16 decision over the summer, how many lawmakers are
17 still envious of the power of the vote. Or black
18 voters. It's even more interesting when ever since
19 President Obama became our president, the attack on
20 black voters have been harshly risen. It's even more
21 interesting when 10 white male Senators have been in
22 support of this modern-day racial terror of a bill.
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1 Taking away someone's civil rights or request for

2 voter assistance expresses the highest form of human
3 indecency. Therefore, I strongly, harshly oppose
4 Senate Bill One. Thank you for your time.
5 CHAIRMAN BOB FINCHER: Thank you, sir. All
6 right. Carol Mosley. Mosley? Okay. I'm sorry. All
7 right. Ms. Mosley.
8 CAROL MOSELY: Good morning. I am Carol
9 Moseley. I am vice president of the League of Women
10 Voters of Alabama. I am reading this statement on
11 behalf of our president. Across the state nonprofit
12 organizations like the league as well as caregivers,
13 nurses, church members, and school administrators,
14 teachers and students, fill a critical gap and
15 provide a needed service to all people to navigate a
16 fundamentally confusing and error-prone absentee
17 voting process. We fill a gap in the community that
18 election officials are not positioned to fill and we
19 have knowledge about the voting present -- process
20 that most citizens don't have. The SB1 before you
21 today is still an extremely harmful bill that will
22 entrap and criminalize samaritans who may be in a
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1 situation where they receive reimbursement for their

2 services or perhaps receive a token gift for helping
3 a friend or even a stranger download or fill out the
4 application. If any money, even gas money for
5 transportation is offered or accepted, both persons
6 would be guilty of a harsh felony. This new bill also
7 has a new problem by requiring a registered voter to
8 affirm that he or she is not barred from voting
9 because of a disqualifying felony conviction or if
10 the applicant was convicted of a disqualifying felony
11 that the applicants right to vote has been restored.
12 The registrar is the election official charged with
13 affirming, confirming voter eligibility when a person
14 is register -- registering to vote. The citizen
15 voting in person is not asked this question. Adding
16 it here is a violation of process and will intimidate
17 and confuse voters. Finally, the 2022 primary
18 election data that you -- that has been touted as the
19 reason our proof that we need this bill and if any of
20 you have not looked at this, I strongly urge you to
21 look at this. This is what is handed out when you ask
22 for proof of why we need this bill. The proportion of
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1 absentee ballot voting is simplistic and meaningless.

2 For a rural county, there are many reasons a person
3 would vote absentee, including poor transportation,
4 out of county jobs, aging or sick population. SB1 is
5 a harmful bill for the people of Alabama and will
6 only serve to suppress the voting rights of people
7 who have a right to vote absentee. It will also allow
8 innocent people to be criminalized for doing good.
9 The League of Women Voters ask you to give this bill
10 and unfavorable recommendation. Thank you.
11 CHAIRMAN BOB FINCHER: Thank you, Ms.
12 Mosley. All right. At this point, I will ask the
13 committee members if any of them have a question for
14 the sponsor or any of those who have testified before
15 the committee. Anything? I think Ms. Givan was first
16 one -- hand I saw.
17 JUANDALYNN GIVAN: Thank you, Mr. Chairman
18 for the opportunity to speak. The first thing is if
19 I'm allowed is I just want to commend the students of
20 Alabama State, Tori and Armani. It's a big, big deal
21 when you come before all of us big people who sit in
22 these chairs and for you to come and so eloquently do
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1 that, I think that you have represented your family

2 as well as your -- it's your college or your
3 institution in a very, very honorable manner. With
4 that being said I do have a question for Senator
5 Gudger.
6 SENATOR GUDGER: Yes, Ms. Representative.
7 JUANDALYNN GIVAN: Just a couple. I'm a
8 facts type of person. I pride myself in being that
9 way and I research a lot. When you come before me and
10 you begin to either cite -- that wasn't you so I
11 can't ask you that. It was I think it was the
12 representative from the Republican party, but I would
13 like to ask you this, because every time I see these
14 bills and we hear about so much voter fraud in the
15 state of Alabama, then when I ask the question of the
16 Secretary of State's office, the answer comes back to
17 very, very, very, very, very, very, very, very, very,
18 very, very minimal responses as to -- as it relates
19 to voter fraud in the state. From the previous
20 Secretary of State's office to this office and I see
21 that you feel -- you all feel that there's such an
22 urgency of now with regards to this. So do you -- can
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1 you give me the stats of the number of voter frauds,

2 especially in the area of absentee voting that we
3 have here in the state because you intimated that you
4 had spoken with several groups and so if you could
5 answer that question? Would you give me the true
6 definition also of ballot harvesting? If you can and
7 also you mentioned groups that you have met with on
8 both sides of the aisle on this issue. And if you
9 could answer those for me, I would appreciate it.
10 JUANDALYNN GIVAN: Thank I'm gonna probably
11 forget those three so I'm going to take them one at a
12 time. Tell me what I need to answer. Okay? But let's
13 start up with cases and I was looking for it when you
14 started saying that. These are things that I found
15 online that are as recent -- every one of these that
16 are in these boxes are voter fraud, call it ballot
17 harvesting. Obviously, I don't want to list the names
18 that are there. I don’t think we should hurt
19 somebody's character. But this is everything in the
20 last few years.
21 JUANDALYNN GIVAN: So are those -- so
22 you're counting on five sheets of paper. So are --
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1 is every name on there on the sheet of paper voter

2 fraud or is it person's name at the top of the list?
3 SENATOR GUDGER: These are people's name
4 and then they have been caught voter fraud through
5 this. Part of that would be about harvesting. Just
6 for example on mine, that's in my district, biggest
7 voter fraud case in Alabama is in Winston County
8 which is my district. Okay? It tells about who did it
9 and he was there and how they did it and I talked to
10 the Circuit Clerk who gave me this information, but
11 they were convicted and after they were convicted
12 they didn't go to jail. Nothing happened. But let me
13 just tell you at that time in my district, for
14 example, the sheriff, the circuit clerk, the district
15 judge, candidates for the school board and candidates
16 for County Commission all were in a scheme so that
17 they can make sure they stayed elected on top of it
18 and didn't count other people's votes that were
19 coming out. And I haven't said that the biggest case
20 in the history of Alabama, I'll give you the sheet if
21 you'd like it, that is in my district. And so is that
22 happening? Yes, it is. Can I give you an overview or
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1 details of how many? I can't do that but I have this

2 just on my research that I pulled.
3 JUANDALYNN GIVAN: And I just remember --
4 I'm about to -- I'm wrapping up, Mr. Chairman. And so
5 the question is that that's identifies the case so
6 that's about five sheets of paper. So that's roughly
7 about five people, individuals. Again, the number has
8 always been very minimal of regardless of who it is,
9 it's wrong. I don't care who does it. But I just want
10 to close Mr. -- Mr. Chairman with this. I wanted to
11 speak or spoke about jelly beans and no -- marbles.
12 Marbles in a jar, but I'm going to take you just a
13 step further. Jellybeans in a jar, poll taxes,
14 reciting the Constitution of the United States of
15 America, the 1964 Civil Rights Act, the 1965 Voting
16 Rights Act, the cross -- the journey from the Edmund
17 Pettus bridge to the capital of the state of Alabama.
18 And I simply say this. This is an opportunity to
19 further infringe upon the power and strength of the
20 black vote at the end of the day. And all I can say
21 to you all out there, is that this is not what
22 democracy looks like. What you all are what democracy
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22
1 looks like. Mount up. Mount up. Mount up.

2 CHAIRMAN BOB FINCHER: Are there any other
3 comments or questions for committee members? Let's go
4 around. Ms. Adline?
5 ADLINE CLARKE: Good morning, Mr. Chairman.
6 Good morning Senator Gudger.
7 SENATOR GUDGER: Good morning, Ms.
8 Representative.
9 ADLINE CLARKE: So talk to me a little
10 more about this -- this. Thank you -- about this
11 proof that that you have. I'd love to see it. I think
12 this committee ought to see it.
13 SENATOR GUDGER: Okay. I'll be more than
14 happy to give you the sheets. These are only ones
15 I've got that I've printed off myself, but I did my
16 research and just pulled in -- this is just the ones
17 that have the last few years that I've had. Am I an
18 attorney? No. Did I pull this off? Do I know what's
19 happening? Yes.
20 ADLINE CLARKE: In the case that you
21 mentioned, Senator.
22 SENATOR GUDGER: Yes.
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23
1 ADLINE CLARKE: That --

2 SENATOR GUDGER: In Winston County?
3 ADLINE CLARKE: Yes. So how was -- has that
4 case been disposed of?
5 SENATOR GUDGER: It has been. They get
6 convicted and was arrested but then they were after
7 that charges were dismissed because --
8 ADLINE CLARKE: So the justice system
9 worked. Is that correct?
10 SENATOR GUDGER: It was -- they were
11 dismissed and they still kept their jobs and they
12 still had places -- but it wasn't because it's not
13 legal and now there's loopholes you can get around it
14 and that is exactly what they did. They're arresting
15 and they found the loopholes to get out of it. So
16 it's happening and nothing's being done. This
17 particular bill -- and the definition real quick Mis
18 -- representative and also -- so you ask me I think
19 is Mohan good for both of us and say is if you're
20 getting paid or getting, receiving monetary value for
21 your application, that would be ballot harvesting as
22 you're pulling harvesting part all of that together.
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1 JUANDALYNN GIVAN: But these students

2 aren't being paid. They're not -- they're not being
3 paid. They represent legitimate student campus
4 organizations.
5 SENATOR GUDGER: Then they can do what they
6 want to. That's fine. I'm not sure what their
7 arguments were because they said you can't help
8 somebody fill that in. You can. You can have help. If
9 you look on the bill line 50 to 55, it says anybody
10 who can help anybody fill in their application as
11 long as you sign that. If you can't read or write you
12 have to put a mark, that's going --
13 ADLINE CLARKE: What -- what line is that?
14 It says anybody can help anybody?
15 SENATOR GUDGER: 50. Look in the bill. Line
16 50 to 55. Page Two. So you have anyone that you want
17 can help you fill in your application. I'd like to go
18 one step further or talking about restitution of
19 rights also. We worked with the Democratic party
20 upstairs to make sure that if someone went through
21 the process got convicted on felonies and then they
22 went through the judicial process and paid the
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1 restitution, they don't have to list the felonies on

2 their application because they shouldn't do that
3 anymore. They have restored their voting rights and
4 they don't have that. I think that's fair and we
5 added that Amendment upstairs. If you went through
6 the judicial system and restored your voting rights,
7 you don't have to list any of those felonies.
8 ADLINE CLARKE: So Mr. -- again, I'd like
9 to see the data. I'd like to -- if it is proper, Mr.
10 Chairman, make a motion or ask that you as Chair send
11 this bill to a subcommittee to review this data so
12 that this committee would be convinced that -- that -
13 -
14 CHAIRMAN BOB FINCHER: Right.
15 ADLINE CLARKE: -- ballot harvesting
16 exists.
17 CHAIRMAN BOB FINCHER: There's a motion to
18 send the bill to a subcommittee which has a do
19 second. I would love to tell you -- yes. There's a
20 move to table the motion. All those in favor of the
21 tabling motion, say aye. All those opposed nay. The
22 aye's have it. The aye's. All right. Representive
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26
1 Clarke, was that your ending remark?

2 ADLINE CLARKE: I know and I said through
3 the Senate hearing and the reason -- and you know
4 that I have a bill that addresses this the same
5 issue.
6 SENATOR GUDGER: That is correct.
7 ADLINE CLARKE: And so I was very
8 interested in tracking this bill closely so that that
9 I could see how we might work together. We've done
10 that before Senator Gudger.
11 SENATOR GUDGER: That's correct.
12 ADLINE CLARKE: I think Senator Singleton
13 pointed out that as lawmakers, we often are involved
14 in this process. Are we third parties? Would we be
15 guilty of ballot harvesting if we were to go out
16 there and try to -- I mean, we do it. And let me use
17 an example. In one of our more recent mayoral
18 elections in Mobile, one of our candidates mailed
19 about 1500 absentee ballot applications to a targeted
20 group. Is that ballot harvesting?
21 SENATOR GUDGER: Sending applications? If
22 they're requested there's not -- you can --
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27
1 ADLINE CLARKE: No. No. They weren't

2 requested.
3 SENATOR GUDGER: Okay.
4 ADLINE CLARKE: They weren’t requested.
5 SENATOR GUDGER: You have a couple options.
6 You can send applications and help somebody fill that
7 in. You can take yourself, 1,500 in your car and take
8 it to 1,500 people if you want to do that wasn't
9 requested. That's still legal. Okay?
10 ADLINE CLARKE: That's still --
11 SENATOR GUDGER: That's still legal. You're
12 able to be. That's legal what you just said. Now,
13 paying someone to application and tell them how to
14 fill that in, that's legal. I mean, excuse me. That's
15 illegal and you can't do that part. Right? So you've
16 got a blank form that you give to them and you can
17 pass out as many as you want to. You can get
18 assistance from anyone in this room or anyone in the
19 world that you want to, to help fill that in as long
20 as if you need assistance -- if they're disabled,
21 then you sign your name as the applicant and then the
22 person that helped you, fill that in and you put both
PLANET DEPOS
28
1 your names at the bottom and send that application in

2 yourself. So I'm -- I'm still -- and we're under in -
3 - to answer your question. We are under the same law.
4 This right here. So, where it is, it's if you getting
5 paid or receiving money. The intent of this bill,
6 right? And it says willing on here. Willing, knowing
7 intent. Okay? Is not to worry about grandfather given
8 the grandson $5 for gas money. I don't think
9 anybody's going after that. But if somebody's
10 bringing in 1,500 ballots at one time, there's an
11 issue there. There's certain counties that we have
12 data that they are one out of five ballots cast is an
13 absentee ballot. That's over 20 percent. Whether it's
14 transportation or whether that's rural or whether
15 they have to work outside of the county, that's so
16 far out of the norm of Alabama, which is three and a
17 half percent. 20 -- over 20 percent, that means
18 something's going on in those particular counties and
19 we're just trying to stop that. And again, I'm under
20 that same thing in my county.
21 ADLINE CLARKE: And what might be going on
22 is that state representatives and state senators are
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29
1 campaigning and out there beating the bushes trying

2 to get votes. I think that that is often where we see
3 the increase is every four years when our names are
4 on the ballot.
5 SENATOR GUDGER: There's a large increase.
6 Three percent of 20 over 20.
7 ADLINE CLARKE: And if you look -- if you
8 look at those numbers of absentee votes cast, I mean
9 any one of us might be suspicious because you're
10 going to see where the number is largely Democrat or
11 is largely Republican and that typically reflects,
12 you know, the demographics of those various counties.
13 I also think Mr. Senator Gudger and Chairman and
14 committee that we really need to define the words
15 gift, prefilling and third party in this bill.
16 SENATOR GUDGER: Okay.
17 ADLINE CLARKE: Can I get an Amen out
18 there? Thank you.
19 CHAIRMAN BOB FINCHER: Does that conclude
20 your remarks Representative Clarke?
21 ADLINE CLARKE: At the moment. Thank you,
22 Mr. Chairman.
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30
1 CHAIRMAN BOB FINCHER: Okay. Representative

2 Rafferty, you -- okay. Representative Paschal?
3 KENNETH PASCHAL: Thank you, Chair. I guess
4 the question -- the word that I have an issue with
5 intent, right? Because if you got a Civic
6 organization that they employed by this organization,
7 they get paid and they job is to hit with absentee
8 ballot. Would that person be prosecuted with a class
9 C felony?
10 SENATOR GUDGER: No. If that's just helping
11 somebody as far as assisting and filling out their
12 application, they would not be.
13 KENNETH PASCHAL: Okay. Because --
14 SENATOR GUDGER: If they're getting paid --
15 paid to do that over and over and over all day. Yes,
16 they would be under this, technically.
17 KENNETH PASCHAL: And I guess -- I think
18 Mr. John wall made a comment about a particular case
19 because what I noticed we get a lot of candidates,
20 right? They run a race and they lose. The first thing
21 they look at is the absentee ballot and they
22 automatically put in a lawsuit because they feel like
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31
1 if something was done in the absentee ballot process

2 -- because sometimes we don't -- we shouldn't do
3 things about -- about how we think but what we know,
4 right?
5 SENATOR GUDGER: Right.
6 KENNETH PASCHAL: Because of the -- if you
7 don't know, these people don't know but is it they
8 just going by what they think. I think we doing this
9 legislation about what we think but not what we know.
10 It is not even enough evidence to do legislation
11 because I'm so afraid -- and we have done this
12 throughout history. We can go back to the criminal
13 justice bill back in the 90s when we did the three-
14 strike rule. Nobody didn't think about judges putting
15 people locked in jail for 25 years over small
16 charges. You see the intent. That's the intent. The
17 intent was to stop -- help stop violence. Ans so what
18 I'm afraid with this legislation, the intent would
19 cause a lot of issues, especially with candidates,
20 right? Because when they lose, it's an audit because
21 I -- when I count votes in my elections and I ran
22 campaigns for my experiences, right? And they said,
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32
1 well I voted absentee. And I know in my area, you

2 know because I said the absentee ballot process works
3 because when I counted a hundred absentee ballots and
4 I only see 25 got counted, like what happened? You
5 know? And that's the issue that I get and I think the
6 process work. Now, even the scheme that you said to
7 happen in Winston County now, that's -- that's -- I'm
8 not saying it didn't happen. But when you get so many
9 people to agree to be re-elected and then they didn't
10 get prosecuted, that's -- that's voter fraud. It is a
11 desk -- that's a problem. They should be in -- they
12 shouldn't be -- should not be in office. And we do
13 have laws that should they be held accountable for
14 that, you know? But what I'm afraid is and I'm
15 finished. It's just the intent. Intent has always
16 hurt certain people in this country. The intent. And
17 that's what I'm afraid of with this legislation.
18 Thank you.
19 CHAIRMAN BOB FINCHER: Are there any other
20 questions or comments from the committee? All right.
21 We got one more over here. Representative Rafferty.
22 Yes. You got one --
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33
1 REPRESENTATIVE RAFFERTY: Thank you, Mr.

2 Chair. Okay. So I wanted to kind of walk through page
3 four here where you're breaking down these two
4 different. That's class C felony and a class B
5 felony. Can you explain the difference between these
6 two?
7 SENATOR GUDGER: Yes. If only -- let's
8 start at the top of the page on line 80 -- might has
9 well say 85. Just at the very top of the page. Okay?
10 Page four. And that is knowing -- if you look at page
11 line item 86, that is if you receive a payment or
12 gift for distribution in distributing --
13 REPRESENTATIVE RAFFERTY: What constitutes
14 a gift?
15 SENATOR GUDGER: I guess monetary value?
16 REPRESENTATIVE RAFFERTY: So a stamp?
17 SENATOR GUDGER: What we said upstairs is
18 the same thing. Stamp, sticker, everything else, but
19 we're not going after people that are trying to
20 stamp. This bill -- the intent against representative
21 hassle was the fact of going after the bad actors
22 that are trying to steal these elections. You want me
PLANET DEPOS
34
1 to finish that up? For that 85 through-line 90 would

2 go to a class C felony. If you receive a gift or
3 monetary value 91 through 96 is a class B felony. If
4 you're the one that's paying that. If you look at the
5 word on line 92, knowingly pay or provide a gift as a
6 term I found out through this process calls Men's
7 Raya. This is a law term that says that criminal
8 intent and that's what that means is the same way
9 knowingly intents on line 86, knowingly receive a
10 payment. Same way. That is knowingly criminal intent
11 is what that states in the law.
12 REPRESENTATIVE RAFFERTY: And is there any
13 clarification as far as whether or not these ballot
14 applications -- I mean, completed ballot applications
15 versus just a stack or packet of them?
16 SENATOR GUDGER: As me the question again.
17 REPRESENTATIVE RAFFERTY: Well, I'm trying
18 to see if you deliver a stack of applicants valid
19 application somewhere to a nonprofit that might be
20 having a voter, you know, --
21 SENATOR GUDGER: You can deliver those to
22 anybody you want to. 1,500 of them. That's fine.
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35
1 That's not against the law. Cannot. Representative

2 Rafferty, you brought up something early I'd like to
3 just put there real quick, which is disabilities.
4 REPRESENTATIVE RAFFERTY: Yes.
5 SENATOR GUDGER: There's federal law guys
6 that go with this -- and ladies -- that go and we're
7 not changing and can't change federal law. Anything
8 that has disability -- my father was disability,
9 couldn’t see at the end. Had one leg from diabetes.
10 Same thing. We helped him fill that in. He returned
11 to his application back in. You're still able to
12 again get assistance if you need it. We're not
13 affecting anything with disabilities because Federal
14 code and we can't change that. So I'm not changing
15 that in this bill and veterans that are overseas,
16 that is federal law and we can't change anything in
17 this bill. The only thing we're doing is making it a
18 crime to receive or get or pay people for ballot
19 harvesting.
20 REPRESENTATIVE RAFFERTY: All right. One
21 more question. Just one more follow-up with that. I
22 wanted to see about this getting paid out of that
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36
1 definition here. So if we have nonprofit

2 organizations and Civic organizations that their job
3 is to provide this assistance. Are you saying that
4 they would be subject to this this law here? Would
5 you in essence undermining their mission of trying to
6 get more voters voices heard?
7 SENATOR GUDGER: We want as many people to
8 be able to vote and have access to the polls and make
9 sure that it's secure voting and honest and integrity
10 election. Are we doing that? No. You can have
11 education. You can bring people in. You can talk to
12 them. You can help them fill it in and then send
13 those ballots back. I don't -- I don't see that we're
14 doing any of that that some of the people that were
15 here talking about would disagree with that.
16 REPRESENTATIVE RAFFERTY: I understand that
17 but I would just kind of piggyback off the impact
18 statement, the application and you know application
19 of the law and how that'll be interpreted and read
20 for everyone else across the state, also comes into
21 play here. So I have grave concerns about that. I
22 have grave concerns that you're going to be ripping
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37
1 into the ability for voters voices to be heard

2 through the absentee ballot process. And with that I
3 will --
4 CHAIRMAN BOB FINCHER: Thank you
5 Representative Rafferty. Representative Pringle, you
6 had some comments you would like to make.
7 CHRIS PRINGLE: Thank you, Senator. You
8 know, I've heard this that ballot harvesting doesn't
9 exist. And what I have right here is a lawsuit that
10 was filed in Mobile County where an organization sued
11 a candidate. and I'll just read the fee stated you
12 were to pay seven hundred dollars a week for us to
13 generate your absentee ballots and they sued because
14 the candidate didn't pay them and they went out and
15 they generated these absentee ballots and they wanted
16 to be an invoice. Of course, you know, you can't sue
17 for committing a crime. So, the lawsuit was
18 dismissed. But this right here in Mobile County
19 proves that there are ballot harvesting operations
20 that are going on. Candidates are contacting the
21 people to harvest ballots for their election. But I
22 just thought you'd see it government document proves
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38
1 this happens all over. When I was a consultant back,

2 I can't tell you how many times people came into my
3 office and offered to sell me absentee ballot votes.
4 The ballot queens would come in and say I've got -- I
5 got 300 or Kings whatever. I got 300 absentee ballot.
6 So I control County and your candidate is running
7 statewide, so for $5 a vote, I'll get you 300 votes
8 and that go to the County Commission say, I've only
9 got 75 in your District so five out -- they would
10 sell every single slot on every single battle for
11 five dollars. They're making a lot of money doing it.
12 SENATOR GUDGER: And it happens on both
13 sides of the aisle. Both parties, independents as
14 well.
15 CHRIS PRINGLE: But it is the people.
16 People do it. There are people out there that that
17 harvest ballots and they make money selling those
18 votes the candidate. So I've witnessed it. Thank you.
19 CHAIRMAN BOB FINCHER: Thank you. We have
20 one more comment. I know from Representative Givan.
21 JUANDALYNN GIVAN: I just wanted to just to
22 get the clarity. You mentioned the changes that you
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39
1 made upstairs working with the black caucus upstairs

2 --
3 SENATOR GUDGER: Yes, ma'am.
4 JUANDALYNN GIVAN: -- if you would just for
5 what you -- if you would just give me the clarity on
6 what those changes were within this as well as two
7 other things. As just to piggyback to what
8 Representative Rafferty was asking, he mentioned if
9 someone worked for a -- an organization, but my
10 question to you, if that person works for the
11 organization, this is going back to the gift and that
12 person is paid gas who delivered those -- those
13 ballots or if they're paid some type of stiffing in
14 refund for their gas or what have you to get the
15 balance there, is that a legitimate -- I guess I
16 don't want to say legitimate choice or option for
17 them to be able to accept that or it would they be
18 penalized for the crime just -- just for
19 reimbursement of gas as an expense? And lastly, I
20 don't know who made the comment but since they're
21 here, Mr. Chairman, I would like for them to answer
22 one question because I keep hearing this word and I'm
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40
1 just trying to get some clarity on when someone says

2 woke vote. I just want someone to define for me what
3 a woke vote is because I'm having problems with a lot
4 of the commercials I'm seeing from my colleagues on
5 the opposite side of the aisle with the word woke
6 vote, and I want to know what that is because that
7 seems to be something that you all are trying to
8 penalize and I'm just trying to get it for my own
9 clarity.
10 SENATOR GUDGER: I don't think I'm the
11 person to be able to --
12 CHAIRMAN BOB FINCHER: I don't know that we
13 heard the word woke vote today. I didn’t -- did
14 somebody say it? Yes?
15 JUANDALYNN GIVAN: He said it. I heard it.
16 CHAIRMAN BOB FINCHER: Okay. I don’t know.
17 JUANDALYNN GIVAN: That gentlemen there.
18 CHAIRMAN BOB FINCHER: The bill is on the
19 floor. The bill is on the floor before us and I'm
20 going to call on Representative Lomax.
21 JAMES LOMAX: Yeah. I'd like to offer small
22 amendment if appropriate this time. Sentator, this
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41
1 amendment would simply take -- replace line 59

2 through 60 on page 3 with the following required on
3 the application form. So, to remove the rest of the
4 sentence there. Other than marking the specific
5 election to which application applies the thought
6 here, not letting them fill out any of that
7 application just to make it more streamlined and not
8 leave any open -- open interpretation and put us at
9 risk.
10 CHAIRMAN BOB FINCHER: All right. Is there
11 a second to that motion that was made? Representative
12 Butler seconds. Okay. Is there any discussion on the
13 amendment? Okay. Sir?
14 JAMES LOMAX: Sure. Yeah. So it's so if you
15 look at page 3, clearly it outlines it it'll be
16 unlawful for a person to distribute an absentee
17 ballot application that's been pre-filed with the
18 voters name and it gives an exception though other
19 than marking the specific collection to which
20 application applies. I think we're open for -- for
21 legal issues are potentially, interpretation issues
22 and should just be no marking whatsoever if that's
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42
1 the case.
2 JUANDALYNN GIVAN: Glad you brought that up
3 because I actually had a question about that
4 particular part of the bill. It seems to be in
5 conflict with an earlier part of the of the bill. It
6 says any applicant may receive assistance in filling
7 out the application as he or she desires and then it
8 goes on to say that the bottom of page to you it
9 shall be unlawful for any person to knowingly
10 distribute an absentee ballot application to a voter
11 that is prefilled with the voter's name. Let me give
12 you an example. Over the weekend. I have a brother
13 for whom I'm caregiver, I print -- he doesn't have a
14 printer. He's much smarter than I am. He can sit up
15 and work algebraic equations all day long. He can't
16 do some simple kind of stuff. Doesn't have a printer.
17 So I printed out the absentee ballot application, but
18 I typed in his information and printed it. His
19 handwriting is horrible. The absentee election
20 manager would have been calling him back three and
21 four times they ask him to decipher what he would
22 have written on that application. Would I be guilty -
PLANET DEPOS
43
1 -
2 SENATOR GUDGER: No.
3 JUANDALYNN GIVAN: -- of a violation --
4 SENATOR GUDGER: No.
5 JUANDALYNN GIVAN: -- if I put in his -- I
6 put everything if --
7 SENATOR GUDGER: You're able to help him --
8 you are able to help --
9 JUANDALYNN GIVAN: I put everything but his
10 ID number and he had to sign it when I got there.
11 SENATOR GUDGER: You are able to fill in
12 and help him.
13 JUANDALYNN GIVAN: That's not what this
14 states.
15 SENATOR GUDGER: I mean can I explain that?
16 I didn't know this was coming, but that wasn't a
17 floor amendment that was brought to us and was voted
18 on and I would -- I'm fine with this amendment coming
19 back off, but that was a floor Amendment because it
20 wasn't in the bill that I had submitted in committee,
21 which was the sub that I put end. I think corrected a
22 lot of the issues were talking about today. So this
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44
1 particular one was added onto it.

2 JUANDALYNN GIVAN: Well with all due
3 respect, I think we not only need to replace lines 59
4 through 60. We need to replace lines 56 through 60.
5 CHAIRMAN BOB FINCHER: We have a motion on
6 the floor. Is there any other comment? We're going to
7 call for the vote on the motion. All right. The
8 amendment is -- is before you. All those in favor of
9 the amendment say aye.
10 SPEAKERS: Aye.
11 CHAIRMAN BOB FINCHER: All those opposed,
12 nay.
13 SPEAKERS: Nay.
14 CHAIRMAN BOB FINCHER: The ayes have it.
15 All right. So the amendment is added. All right.
16 There's a move for a favorable report. There is a
17 second for the -- so the motion is on the floor for a
18 favorable report on Senate Bill One.
19 FEMALE SPEAKER 1: Roll call vote.
20 CHAIRMAN BOB FINCHER: All right. We ask
21 for a roll call vote. That is proper. If the clerk
22 will read the roll. Go ahead and vote.
PLANET DEPOS
45
1 ARMANI BENSON: No.

2 JOHN WALL: Nay.
3 ADLINE CLARKE: No.
4 CHAIRMAN BOB FINCHER: He has left.
5 KENNETH PASCHAL: Yes.
6 REPRESENTATIVE RAFFERTY: Yes.
7 JAMES LOMAX: Yes.
8 CHAIRMAN BOB FINCHER: He left. Yeah. The
9 bill passes and Senate Bill One as amended is given a
10 favorable report. Thank you.
11 (The recording was concluded.)
12
13
14
15
16
17
18
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PLANET DEPOS
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1 CERTIFICATE OF TRANSCRIBER
2 I, LAUREN BISHOP, do hereby certify
3 that this transcript was prepared from the digital
4 recording of the foregoing proceedings; that the
5 recording of said proceedings was obtained from
6 https://alabamachannel.ompnetwork.org/embed/
7 sessions/285921/alabama-house-constitution-
8 campaigns-and-elections-committee; that said
9 proceedings were reduced to typewriting under
10 my supervision; that said transcript is a true and
11 accurate record of the proceedings to the best of
12 my knowledge, skills, and ability; and that I am
13 neither counsel for, related to, nor employed by any
14 of the parties to the case and have no interest,
15 financial or otherwise, in its outcome.
16
17 _____________________________
18 LAUREN BISHOP, TRANSCRIPTIONIST
19 PLANET DEPOS, LLC
20 MARCH 7, 2024
21
22
PLANET DEPOS
47
A accountable affect alabamachannel
ability 32:13 8:11 46:6
10:9, 11:16, accurate affecting alabamian
37:1, 46:12 13:16, 46:11 10:6, 35:13 2:9
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2:14, 8:17, 2:21, 15:11, 16:8 42:15
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36:8, 39:17, act 16:13 3:8, 5:7, 5:9,
40:11, 43:7, 4:18, 21:15, afraid 6:13, 7:15,
43:8, 43:11 21:16 31:11, 31:18, 7:18, 9:20,
about active 32:14, 32:17 12:2, 15:5,
9:20, 10:5, 5:17 african-americans 15:6, 15:15,
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24:18, 26:19, 11:10, 42:3 33:19, 33:21 25:22, 30:15,
28:7, 30:18, added again 32:20, 35:20,
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31:14, 35:22, 44:15 28:19, 34:16, 41:10, 42:15,
36:15, 36:21, adding 35:12 44:2, 44:7,
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26:19, 28:13, 23:8, 24:13, 13:19 7:10
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37:13, 37:15, 28:21, 29:7, 1:8, 5:13, 6:9, 9:13, 9:16
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42:17, 42:19 administrators 12:13, 12:16, 6:11, 7:4, 7:12,
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39:17 adults 15:10, 17:5, 8:19, 9:7, 9:13,
accepted 5:16, 6:8, 6:10 17:20, 18:15, 10:13, 13:12,
16:5 advocacy 20:7, 20:20, 13:17, 14:7,
access 4:7 21:17, 28:16 16:6, 17:7,
36:8 advocate alabama-house-co- 19:6, 19:7,
13:15 nstitution
46:7
PLANET DEPOS
48
23:18, 24:19, 27:18 around B
29:13, 36:20 anything 22:4, 23:13 back
alumni 2:16, 17:15, arrested 3:3, 18:16,
7:7 35:7, 35:13, 7:6, 23:6 31:12, 31:13,
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21:8, 32:15 appeared 23:14 38:1, 39:11,
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29:17 applicant 7:19, 7:20, backed-up
amended 16:10, 27:21, 7:21, 9:22 9:13
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amendment applicants 16:15 2:3, 33:21
25:5, 40:22, 16:11, 34:18 asking balance
41:1, 41:13, application 39:8 39:15
43:17, 43:18, 2:19, 2:22, assist ballot
43:19, 44:8, 3:2, 3:3, 5:19, 9:6 2:15, 4:12,
44:9, 44:15 16:4, 23:21, assistance 5:19, 5:21,
america 24:10, 24:17, 4:16, 5:21, 6:20, 8:9, 8:19,
21:15 25:2, 27:13, 6:20, 14:9, 8:22, 10:18,
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4:9 34:19, 35:11, 27:20, 35:12, 12:11, 13:21,
another 36:18, 41:3, 36:3, 42:6 14:13, 17:1,
12:20 41:5, 41:7, assisted 19:6, 19:16,
ans 41:17, 41:20, 12:17 23:21, 25:15,
31:17 42:7, 42:10, assisting 26:15, 26:19,
answer 42:17, 42:22 4:11, 12:10, 26:20, 28:13,
18:16, 19:5, applications 30:11 29:4, 30:8,
19:9, 19:12, 4:12, 26:19, association 30:21, 31:1,
28:3, 39:21 26:21, 27:6, 8:2, 8:3 32:2, 34:13,
any 34:14 attack 34:14, 35:18,
3:19, 5:6, applies 12:20, 14:19 37:2, 37:8,
16:4, 16:19, 41:5, 41:20 attends 37:19, 38:3,
17:13, 17:14, appreciate 5:13 38:4, 38:5,
22:2, 25:7, 3:8, 10:11, attorney 41:17, 42:10,
29:9, 32:19, 12:1, 19:9 22:18 42:17
34:12, 36:14, appreciated audit ballots
41:6, 41:8, 3:21 31:20 7:7, 9:9, 9:11,
41:12, 42:6, appropriate automatically 28:10, 28:12,
42:9, 44:6, 40:22 30:22 32:3, 36:13,
46:13 area away 37:13, 37:15,
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2:18, 24:9, aren't 15:1 39:13
24:10, 24:14, 24:2 aye barred
34:22 arguments 25:21, 44:9, 16:8
anybody's 24:7 44:10 barriers
28:9 armani aye's 12:13, 13:22
anymore 5:9, 5:12, 25:22 based
25:3 5:13, 8:5, ayes 4:6
anyone 17:20, 45:1 44:14
14:8, 24:16,
PLANET DEPOS
49
battle beings black brought
38:10 12:22 13:13, 14:17, 8:7, 35:2,
beans believe 14:20, 21:20, 42:2, 43:17
21:11 12:14 39:1 bushes
beating benson blacks 29:1
29:1 5:10, 5:12, 8:4 butler
became 5:13, 45:1 blank 41:12
14:19 best 27:16 C
because 46:11 blind call
10:21, 12:18, between 2:18 2:2, 14:6,
16:9, 18:13, 6:12, 33:5 board 19:16, 40:20,
19:3, 23:7, big 20:15 44:7, 44:19,
23:12, 24:7, 2:20, 17:20, boats 44:21
25:2, 29:9, 17:21 11:22 calling
30:5, 30:13, biggest bob 42:20
30:19, 30:22, 20:6, 20:19 3:7, 5:5, 7:18, calls
31:2, 31:6, bill 9:22, 12:3, 34:6
31:11, 31:20, 2:5, 2:6, 2:7, 13:8, 15:5, calm
32:2, 32:3, 2:8, 2:11, 3:5, 17:11, 22:2, 14:3
35:13, 37:13, 5:1, 5:11, 5:18, 25:14, 25:17, came
39:22, 40:3, 5:19, 6:6, 8:7, 29:19, 30:1, 38:2
40:6, 42:3, 10:11, 11:14, 32:19, 37:4, campaigning
43:19 11:18, 12:8, 38:19, 40:12,
become 29:1
12:12, 12:14, 40:16, 40:18, campaigns
5:17 13:3, 13:5, 41:10, 44:5,
becoming 1:9, 31:22
13:18, 14:5, 44:11, 44:14, campaigns-and-el-
7:3 14:6, 14:7, 44:20, 45:4,
been 45:8 ections-committee
14:22, 15:4,
8:7, 14:20, 15:21, 16:6, body 46:8
14:21, 16:11, 16:19, 16:22, 10:7 campus
16:18, 20:4, 17:5, 17:9, both 8:16, 24:3
21:8, 23:4, 23:17, 24:9, 14:13, 16:5, campuses
23:5, 41:17, 24:15, 25:11, 19:8, 23:19, 6:6
42:20 25:18, 26:4, 27:22, 38:12, can't
before 26:8, 28:5, 38:13 8:17, 8:22,
12:7, 13:6, 29:15, 31:13, bottom 9:6, 18:11,
15:20, 17:14, 33:20, 35:15, 28:1, 42:8 21:1, 24:7,
17:21, 18:9, 35:17, 40:18, boxes 24:11, 27:15,
26:10, 40:19, 40:19, 42:4, 19:16 35:7, 35:14,
44:8 42:5, 43:20, breaking 35:16, 37:16,
begin 44:18, 45:9 38:2, 42:15
33:3 candidate
4:2, 18:10 bills bridge
behalf 18:14 10:19, 37:11,
21:17 37:14, 38:6,
12:5, 15:11 birmingham bring
being 4:6 38:18
36:11 candidates
7:6, 9:2, 13:1, bishop bringing
18:4, 18:8, 1:22, 46:2, 20:15, 26:18,
28:10 30:19, 31:19,
23:16, 24:2 46:18 brother
42:12
PLANET DEPOS
50
37:20 13:8, 13:10, 15:13 closely
cannot 15:5, 17:11, circuit 26:8
2:12, 5:18, 17:17, 21:4, 20:10, 20:14 cloth
9:17, 35:1 21:10, 22:2, cite 14:7
capital 22:5, 25:10, 18:10 code
21:17 25:14, 25:17, citizen 35:14
car 29:13, 29:19, 8:20, 9:4, colleague
27:7 29:22, 30:1, 13:12, 16:14 6:15
care 32:19, 37:4, citizens colleagues
3:11, 21:9 38:19, 39:21, 8:12, 15:20 40:4
caregiver 40:12, 40:16, civic collection
42:13 40:18, 41:10, 4:9, 5:16, 6:5, 41:19
caregivers 44:5, 44:11, 6:15, 8:10, college
15:12 44:14, 44:20, 9:11, 12:8, 5:16, 6:7,
carol 45:4, 45:8 13:4, 13:14, 6:12, 6:19, 7:8,
15:6, 15:8 chairs 30:5, 36:2 7:14, 8:12,
case 17:22 civil 8:15, 12:15,
20:7, 20:19, challenges 15:1, 21:15 18:2
21:5, 22:20, 12:15 clarification colleges
23:4, 30:18, change 34:13 7:1, 7:4
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cases 35:7, 35:14, 38:22, 39:5, 3:5, 5:9, 5:10,
19:13 35:16 40:1, 40:9 12:7, 17:21,
cast changes clarke 17:22, 18:9,
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29:8 changing 22:20, 23:1, comes
caucus 35:7, 35:14 23:3, 23:8, 9:20, 18:16,
39:1 character 24:13, 25:8, 36:20
caught 19:19 25:15, 26:1, coming
20:4 charge 26:2, 26:7, 20:19, 43:16,
cause 5:20, 8:8 26:12, 27:1, 43:18
7:13, 31:19 charged 27:4, 27:10, commend
causes 6:3, 6:21, 28:21, 29:7, 17:19
7:16 14:13, 16:12 29:17, 29:20, comment
causing charges 29:21, 45:3 30:18, 38:20,
13:6 4:21, 23:7, class 39:20, 44:6
certain 31:16 9:3, 30:8, comments
28:11, 32:16 checked 33:4, 34:2, 34:3 5:6, 5:11,
certificate 13:21 clear 22:3, 32:20,
46:1 chief 2:16 37:6
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46:2 choice 41:15 40:4
chair 39:16 clerk commission
25:10, 30:3, choose 20:10, 20:14, 20:16, 38:8
33:2 3:1 44:21 commit
chairman chris cliff 2:13, 2:14
3:7, 5:5, 7:18, 37:7, 38:15 3:13, 3:14 committed
9:22, 12:3, church close 4:21
8:10, 9:1, 9:5, 21:10
PLANET DEPOS
51
committee constitute counting cut
1:9, 3:17, 5:6, 5:22 19:22 3:19, 6:16
13:11, 17:13, constitutes country D
17:15, 22:3, 33:13 32:16 data
22:12, 25:12, constitution counts 16:18, 25:9,
29:14, 32:20, 1:8, 21:14 12:19 25:11, 28:12
43:20 constitutional county day
committing 7:12, 12:20, 10:19, 17:2, 21:20, 30:15,
37:17 13:2 17:4, 20:7, 42:15
common-sense consultant 20:16, 23:2, deaf
11:19 38:1 28:15, 28:20, 2:17
communities contacting 32:7, 37:10, deal
4:10 37:20 37:18, 38:6, 2:20, 17:20
community continuously 38:8 decipher
5:17, 15:17 7:5 couple 42:21
completed control 18:7, 27:5 decision
34:14 38:6 course 11:2, 14:16
complicated convicted 37:16 decline
10:4 16:10, 20:11, court 6:8, 7:8, 7:14
concern 23:6, 24:21 9:13, 11:1 decrease
5:4 conviction courts 7:5
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10:5, 36:21, convinced create 29:14, 40:2
36:22 25:12 12:13 definition
conclude corporate crime 19:6, 23:17,
29:19 7:7 6:21, 12:10, 36:1
concluded correct 35:18, 37:17, deliver
45:11 23:9, 26:6, 39:18 9:9, 9:11,
conecuh 26:11 criminal 34:18, 34:21
10:19 corrected 8:4, 31:12, delivered
confirming 43:21 34:7, 34:10 39:12
16:13 could criminalize delivering
conflict 6:2, 6:4, 7:3, 4:18, 15:22 14:8
42:5 7:8, 12:14, criminalized democracy
confuse 19:4, 19:9, 26:9 6:18, 17:8 4:18, 4:20,
16:17 couldn’t criminalizes 21:22
confusing 35:9 14:8 democrat
15:16 counsel criminals 2:7, 29:10
connection 46:13 6:11 democratic
4:13 count critical 2:12, 4:22,
consecutive 20:18, 31:21 4:13, 15:14 24:19
8:6 counted cross demographics
consider 10:8, 11:6, 21:16 29:12
7:15 11:16, 32:3, current depend
considered 32:4 6:21 9:10
9:2 counties currently depos
constant 28:11, 28:18, 5:14, 8:1, 9:9, 46:19
5:22 29:12 9:10
PLANET DEPOS
52
deprived distribute east ending
10:20 41:16, 42:10 7:22 26:1
desires distributing edmund engagement
42:7 33:12 21:16 4:9, 4:22, 13:4
desk distribution education enough
32:11 33:12 4:8, 6:14, 31:10
details district 36:11 ensure
21:1 13:12, 20:6, effect 12:19
devices 20:8, 20:13, 6:22 entrap
3:19 20:14, 20:21, effects 15:22
diabetes 38:9 7:16 envious
35:9 document either 14:17
didn’t 37:22 18:10 equations
40:13 documents elected 42:15
difference 14:1 10:21, 20:17 era
33:5 doing election 14:4
different 2:10, 7:3, 2:13, 15:18, error-prone
33:4 17:8, 31:8, 16:12, 16:18, 15:16
digital 35:17, 36:10, 36:10, 37:21, especially
46:3 36:14, 38:11 41:5, 42:19 14:10, 19:2,
dignity dollars elections 31:19
4:17 37:12, 38:11 1:9, 2:4, 2:5, essence
disabilities done 2:9, 26:18, 4:20, 36:5
2:17, 8:13, 23:16, 26:9, 31:21, 33:22 even
12:16, 35:3, 31:1, 31:11 electrical 8:17, 8:22,
35:13 don’t 3:19 9:6, 14:18,
disability 19:18, 40:16 eligibility 14:20, 16:3,
35:8 down 16:13 16:4, 31:10,
disabled 2:2, 3:12, 33:3 eloquently 32:6
6:19, 8:15, download 17:22 ever
27:20 16:3 else 14:18
disagree drive 5:20, 33:18, every
36:15 8:20 36:20 2:8, 10:7,
discourage due else's 11:5, 11:15,
14:4 13:1, 44:2 8:9 18:13, 19:15,
discussion duly embed 20:1, 29:3,
41:12 10:21 46:6 38:10
dismantle during employed everybody
6:12, 7:11 14:3 30:6, 46:13 7:21, 8:14
dismissed E employee everyone
23:7, 23:11, each 4:5 2:20, 3:10,
37:18 3:12 employees 10:8, 36:20
disposed earlier 12:9 everyone's
23:4 42:5 encompassed 12:19
disproportionate early 2:11 everything
4:22 35:2 end 19:19, 33:18,
disqualifying easily 21:20, 35:9, 43:6, 43:9
16:9, 16:10 2:13, 2:14 43:21 evidence
31:10
PLANET DEPOS
53
exactly facts filed 17:18, 30:20
23:14 18:8 37:10 five
example faculties fill 19:22, 21:6,
6:18, 8:22, 7:10 2:19, 8:18, 21:7, 28:12,
14:9, 20:6, faculty 15:14, 15:17, 38:9, 38:11
20:14, 26:17, 6:4, 7:6 15:18, 16:3, floor
42:12 fair 24:8, 24:10, 40:19, 43:17,
exception 2:9, 25:4 24:17, 27:6, 43:19, 44:6,
41:18 faith 27:14, 27:19, 44:17
excuse 4:6 27:22, 35:10, follow-up
27:14 family 36:12, 41:6, 35:21
exercise 18:1 43:11 following
9:8, 9:19, far filling 12:7, 41:2
13:20 28:16, 30:11, 2:21, 30:11, foregoing
exercising 34:13 42:6 46:4
12:11 father final forget
exist 35:8 3:6 13:1, 19:11
37:9 favor finally form
exists 25:20, 44:8 7:5, 16:17 15:2, 27:16,
25:16 favorable financial 41:3
expect 44:16, 44:18, 46:15 forward
8:16, 8:21, 45:10 financially 5:10
9:7, 10:22 february 7:13 found
expense 1:12 fincher 2:10, 19:14,
39:19 federal 3:7, 5:5, 7:18, 23:15, 34:6
experiences 2:4, 35:5, 9:22, 12:3, four
31:22 35:7, 35:13, 13:8, 15:5, 29:3, 33:3,
explain 35:16 17:11, 22:2, 33:10, 42:21
33:5, 43:15 fee 25:14, 25:17, fraud
expresses 37:11 29:19, 30:1, 2:13, 2:14,
15:2 feel 32:19, 37:4, 5:2, 18:14,
extensive 2:11, 18:21, 38:19, 40:12, 18:19, 19:16,
14:1 30:22 40:16, 40:18, 20:2, 20:4,
extent felonies 41:10, 44:5, 20:7, 32:10
11:4 9:16, 24:21, 44:11, 44:14, frauds
extremely 25:1, 25:7 44:20, 45:4, 19:1
15:21 felony 45:8 freedom
F 4:21, 6:1, 6:3, fine 13:20
7:4, 8:8, 9:2, 24:6, 34:22, freedoms
fabric 43:18
14:6 9:3, 9:15, 7:11
14:14, 16:6, finish friend
faced 34:1
7:1 16:9, 16:10, 8:18, 9:5, 16:3
30:9, 33:4, finished fundamentally
facilitate 32:15
6:1, 6:5 33:5, 34:2, 34:3 5:1, 15:16
female firmly funding
facilitating 12:13
4:16 44:19 6:16, 7:8
few first funds
fact 3:21, 17:15,
33:21 19:20, 22:17 14:8
PLANET DEPOS
54
further gives groups happening
21:13, 21:19, 6:19, 41:18 19:4, 19:7 10:16, 11:12,
24:18 glad gudger 11:20, 20:22,
G 42:2 2:1, 3:8, 22:19, 23:16
gap go 12:12, 18:5, happens
15:14, 15:17 8:17, 8:18, 18:6, 20:3, 11:3, 38:1,
gas 8:22, 9:6, 22:6, 22:7, 38:12
6:19, 14:12, 20:12, 22:3, 22:13, 22:22, happy
16:4, 28:8, 24:17, 26:15, 23:2, 23:5, 3:5, 22:14
39:12, 39:14, 31:12, 34:2, 23:10, 24:5, harm
39:19 35:6, 38:8, 24:15, 26:6, 13:6
gave 44:22 26:10, 26:11, harmful
20:10 goes 26:21, 27:3, 15:21, 17:5
generate 42:8 27:5, 27:11, harsh
37:13 going 29:5, 29:13, 16:6
generated 3:9, 19:11, 29:16, 30:10, harshly
21:12, 24:12, 30:14, 31:5, 13:18, 14:20,
37:15 33:7, 33:15,
gentlemen 28:9, 28:18, 15:3
28:21, 29:10, 33:17, 34:16, harvest
10:2, 10:3, 34:21, 35:5,
40:17 31:8, 33:19, 37:21, 38:17
33:21, 36:22, 36:7, 38:12, harvesting
getting 39:3, 40:10,
7:9, 23:20, 37:20, 39:11, 2:15, 10:18,
40:20, 44:6 43:2, 43:4, 19:6, 19:17,
28:4, 30:14, 43:7, 43:11,
35:22 gonna 20:5, 23:21,
19:10 43:15 23:22, 25:15,
gift guess
16:2, 29:15, good 26:15, 26:20,
4:4, 7:20, 30:3, 30:17, 35:19, 37:8,
33:12, 33:14, 33:15, 39:15
34:2, 34:5, 12:5, 15:8, 37:19
17:8, 22:5, guilty hassle
39:11 16:6, 26:15,
givan 22:6, 22:7, 33:21
23:19 42:22 hear
17:15, 17:17, guys
18:7, 19:10, government 18:14
8:2, 37:22 9:19, 35:5 heard
19:21, 21:3,
24:1, 38:20, grandfather H 36:6, 37:1,
38:21, 39:4, 28:7 half 37:8, 40:13,
40:15, 40:17, grandson 28:17 40:15
42:2, 43:3, 28:8 hand hearing
43:5, 43:9, grave 17:16 1:11, 3:9,
43:13, 44:2 36:21, 36:22 handed 26:3, 39:22
give greater 16:21 held
3:6, 17:9, 4:5 handwriting 32:13
19:1, 19:5, greetings 42:19 help
20:20, 20:22, 5:12, 7:21 happen 2:18, 2:19,
22:14, 27:16, griffin 7:16, 32:7, 2:21, 2:22,
39:5, 42:11 7:19, 7:20, 32:8 5:16, 9:5,
given 7:21 happened 10:14, 11:8,
28:7, 45:9 group 20:12, 32:4 24:7, 24:8,
13:15, 26:20 24:10, 24:14,
PLANET DEPOS
55
24:17, 27:6, human integrity itself
27:19, 31:17, 12:22, 15:2 36:9 4:20
36:12, 43:7, hundred intent J
43:8, 43:12 32:3, 37:12 28:5, 28:7, jackson
helped hurt 30:5, 31:16, 13:9, 13:10,
3:2, 27:22, 19:18, 32:16 31:17, 31:18, 13:11
35:10 hypothetical 32:15, 32:16, jail
helping 10:15, 11:2 33:20, 34:8, 9:10, 20:12,
7:6, 9:4, 11:9, I 34:10 31:15
16:2, 30:10 id intents jails
here 43:10 34:9 8:14, 9:12,
3:12, 8:5, identifies interest 9:14, 12:17
8:15, 12:19, 21:5 46:14 james
13:9, 16:16, illegal interested 40:21, 41:14,
19:3, 28:4, 26:8 45:7
28:6, 32:21, 27:15
impact interesting jar
33:3, 36:1, 14:14, 14:15, 14:2, 21:12,
36:4, 36:15, 6:7, 13:4,
36:17 14:18, 14:21 21:13
36:21, 37:9, interpretation jelly
37:18, 39:21, important
11:22 41:8, 41:21 21:11
41:6 interpreted
hereby incarcerated jellybeans
4:11, 9:10 36:19 21:13
46:2 interrupt
higher including job
17:3 3:20 1:20, 6:2, 7:3,
6:14 intimated
highest increase 30:7, 36:2
29:3, 29:5 19:3 jobs
15:2 intimidate
hired indecency 17:4, 23:11
15:3 16:16 john
7:2 invoice
history independent 10:1, 10:2,
2:8 37:16 30:18, 45:2
20:20, 31:12 involved journey
hit independents
38:13 26:13 21:16
30:7 iraq juandalynn
hold individual
5:20 13:17 17:17, 18:7,
5:6, 5:14, irreparable 19:10, 19:21,
10:20 individuals
4:19, 12:9, 13:6 21:3, 24:1,
honest issue 38:21, 39:4,
2:2, 2:9, 36:9 13:2, 21:7
information 10:5, 19:8, 40:15, 40:17,
honorable 26:5, 28:11, 42:2, 43:3,
18:3 20:10, 42:18
infringe 30:4, 32:5 43:5, 43:9,
hope issues 43:13, 44:2
9:19 21:19
innocent 6:21, 31:19, judge
horrible 41:21, 43:22 20:15
42:19 17:8
inside issuing judges
house 14:13 31:14
1:8 12:16
institution it'll judicial
https 41:15 24:22, 25:6
46:6 18:3
item
33:11
PLANET DEPOS
56
justice large legitimate 27:19, 42:15
8:2, 8:4, 23:8, 29:5 24:3, 39:15, longer
31:13 largely 39:16 8:20
K 29:10, 29:11 lessons look
keep last 4:8 16:21, 24:9,
3:13, 39:22 2:2, 13:21, let's 24:15, 29:7,
kenneth 19:20, 22:17 19:12, 22:3, 29:8, 30:21,
30:3, 30:13, lastly 33:7 33:10, 34:4,
30:17, 31:6, 39:19 letting 41:15
45:5 later 41:6 looked
kept 3:6 likelihood 16:20
23:11 lauren 4:15 looking
kill 1:22, 46:2, limitations 11:13, 19:13
13:5 46:18 9:8 looks
kind law limited 3:11, 21:22,
2:10, 3:4, 28:3, 34:7, 9:16 22:1
33:2, 36:17, 34:11, 35:1, line loopholes
42:16 35:5, 35:7, 24:9, 24:13, 23:13, 23:15
kings 35:16, 36:4, 24:15, 33:8, lose
38:5 36:19 33:11, 34:5, 30:20, 31:20
knocks lawmakers 34:9, 41:1 lot
2:2 14:16, 26:13 lines 18:9, 30:19,
know laws 44:3, 44:4 31:19, 38:11,
10:16, 11:3, 2:13, 32:13 list 40:3, 43:22
11:21, 22:18, lawsuit 19:17, 20:2, love
26:2, 26:3, 10:19, 30:22, 25:1, 25:7 22:11, 25:19
29:12, 31:3, 37:9, 37:17 literacy M
31:7, 31:9, league 14:1 ma'am
32:1, 32:2, 15:9, 15:12, litigated 13:8, 39:3
32:5, 32:14, 17:9 10:22, 11:1 made
34:20, 36:18, leave little 30:18, 39:1,
37:8, 37:16, 41:8 22:9 39:20, 41:11
38:20, 39:20, left lives mailed
40:6, 40:12, 45:4, 45:8 6:10, 6:18, 26:18
40:16, 43:16 leg 8:16, 13:13 mainly
knowing 2:2, 35:9 living 8:11
28:6, 33:10 legal 12:16 maintaining
knowingly 14:1, 23:13, llc 4:13
34:5, 34:9, 27:9, 27:11, 46:19 major
34:10, 42:9 27:12, 27:14, local 7:22
knowledge 41:21 2:4, 6:13, 9:1, make
15:19, 46:12 legally 9:5 12:6, 20:17,
L 7:13 locked 24:20, 25:10,
ladies legislation 31:15 36:8, 37:6,
10:3, 35:6 31:9, 31:10, lomax 38:17, 41:7
lansing 31:18, 32:17 40:20, 40:21, makes
legislature 41:14, 45:7 10:12
8:1
8:7, 13:5 long
3:1, 24:11,
PLANET DEPOS
57
making member 37:18 13:7, 18:14,
10:7, 11:5, 5:15, 8:10 modern-day 42:14
11:14, 35:17, members 14:5, 14:22 must
38:11 6:1, 13:11, mohan 13:1
male 15:13, 17:13, 23:19 muted
14:21 22:3 moment 5:2
manager men's 29:21 myself
42:20 34:6 monetary 18:8, 22:15
manner mention 23:20, 33:15, N
10:14, 18:3 9:12 34:3 naacp
many mentioned money 5:15, 12:6,
6:10, 10:5, 19:7, 22:21, 5:22, 6:20, 12:17, 13:4
12:17, 14:2, 38:22, 39:8 14:12, 16:4, name
14:16, 17:2, met 28:5, 28:8, 4:4, 5:12,
21:1, 27:17, 19:7 38:11, 38:17 7:21, 13:11,
32:8, 36:7, 38:2 michigan montgomery 13:14, 20:1,
marbles 8:1 12:22 20:2, 20:3,
14:2, 21:11, might more 27:21, 41:18,
21:12 26:9, 28:21, 3:5, 6:21, 42:11
march 29:9, 33:8, 7:13, 14:18, names
12:21, 12:22, 34:19 14:20, 22:10, 19:17, 28:1,
46:20 millie 22:13, 26:17, 29:3
mark 14:15 32:21, 35:21, national
24:12 milligan 36:6, 38:20, 6:16, 8:3
marking 14:15 41:7 navigate
41:4, 41:19, minded morning 15:15
41:22 13:16 4:4, 7:20, nay
maters mine 12:5, 15:8, 25:21, 44:12,
7:10 20:6 22:5, 22:6, 22:7 44:13, 45:2
matter minimal moseley need
13:13 18:18, 21:8 15:9 11:11, 11:12,
maximum ministries mosely 16:19, 16:22,
3:10 4:6 15:8 19:12, 27:20,
mayoral minute mosley 29:14, 35:12,
26:17 3:14 15:6, 15:7, 44:3, 44:4
mean minutes 17:12 needed
26:16, 27:14, 3:12, 3:14, most 2:21, 15:15
29:8, 34:14, 3:15 5:3, 15:20 needs
43:15 mis motion 11:12
meaning 23:17 25:10, 25:17, negative
6:1, 6:16 misdemeanor 25:20, 25:21, 6:7, 13:3
meaningless 5:21 41:11, 44:5, neighbor
17:1 mission 44:7, 44:17 14:12
means 36:5 mount neighbors
28:17, 34:8 misunderstand 22:1 12:10
measure 4:20 move neither
11:21 mobile 25:20, 44:16 46:13
meeting 26:18, 37:10, much
1:9 3:21, 5:5,
PLANET DEPOS
58
new 18:20, 32:12, 22:14, 32:4, 16:21, 17:4,
7:2, 16:6, 16:7 38:3 33:7, 35:17, 20:19, 21:21,
next official 38:8, 44:3 23:15, 26:13,
13:9 16:12 open 26:15, 27:17,
nobody officials 41:8, 41:20 28:12, 28:16,
31:14 15:18 operations 29:1, 29:17,
non-relative often 37:19 30:11, 34:6,
14:12 26:13, 29:2 opinion 35:22, 37:14,
nonpartisan okay 10:20 38:9, 38:16,
4:7 3:7, 3:20, 4:2, opportunity 41:6, 42:7,
nonprofit 5:10, 7:19, 5:4, 17:18, 42:17
15:11, 34:19, 15:6, 19:12, 21:18 outcome
36:1 20:8, 22:13, oppose 46:15
norm 27:3, 27:9, 15:3 outlines
28:16 28:7, 29:16, opposed 41:15
norma 30:1, 30:2, 25:21, 44:11 outside
12:4, 12:5, 30:13, 33:2, opposite 28:15
12:6 33:9, 40:16, 13:19, 40:5 over
nothing 41:12, 41:13 option 3:15, 14:16,
20:12 ompnetwork 39:16 28:13, 28:17,
nothing's 46:6 options 29:6, 30:15,
23:16 one 27:5 31:15, 32:21,
noticed 3:14, 4:10, org 38:1, 42:12
30:19 8:11, 12:8, 13:14, 46:6 overcrowding
notorious 12:12, 12:14, organization 6:9, 9:14
14:2 13:3, 13:5, 4:8, 8:10, overseas
number 13:18, 13:19, 12:9, 30:6, 35:15
19:1, 21:7, 14:6, 14:7, 37:10, 39:9, overview
29:10, 43:10 15:4, 17:16, 39:11 3:4, 20:22
numbers 19:11, 19:15, organizations own
29:8 24:18, 26:17, 5:16, 6:4, 40:8
nurses 26:18, 28:10, 6:15, 6:17, P
15:13 28:12, 29:9, 9:11, 15:12, packet
32:21, 32:22, 24:4, 36:2 34:15
O 34:4, 35:9,
obama other page
35:20, 35:21, 4:9, 20:18,
14:19 38:20, 39:22, 24:16, 33:2,
obtained 22:2, 32:19, 33:8, 33:9,
44:1, 44:18, 39:7, 41:4,
46:5 45:9 33:10, 41:2,
41:18, 44:6 41:15, 42:8
obtaining one's others
5:19 10:9
pages
10:14 1:21
obviously ones otherwise
19:17 22:14, 22:16
paid
46:15 23:20, 24:2,
offer online ought
40:21 24:3, 24:22,
19:15 22:12 28:5, 30:7,
offered only out
16:5, 38:3 30:14, 30:15,
8:13, 8:19, 2:3, 8:18, 9:4, 35:22, 39:12,
office 11:3, 17:6, 9:5, 16:3,
10:21, 18:16,
PLANET DEPOS
59
39:13 penalized piggyback prefilled
paper 39:18 36:17, 39:7 42:11
19:22, 20:1, people place prefilling
21:6 2:17, 8:8, 11:21, 14:3 29:15
part 8:12, 9:7, 9:15, places pregnant
6:2, 20:5, 9:18, 10:5, 23:12 14:10
23:22, 27:15, 10:17, 11:8, planet prepared
42:4, 42:5 11:21, 12:15, 46:19 46:3
participation 12:16, 12:18, play present
6:6 13:16, 15:15, 36:21 5:11, 15:19
particular 17:5, 17:6, please president
23:17, 28:18, 17:8, 17:21, 3:18, 3:19, 5:15, 8:3, 8:5,
30:18, 42:4, 21:7, 27:8, 4:2, 5:10 14:19, 15:9,
44:1 31:7, 31:15, point 15:11
parties 32:9, 32:16, 3:17, 17:12 pretty
26:14, 38:13, 33:19, 35:18, pointed 3:4
46:14 36:7, 36:11, 26:13 previous
partners 36:14, 37:21, political 18:19
6:14 38:2, 38:15, 7:22 pride
partnership 38:16 politics 18:8
6:15 people's 5:17 primary
party 10:13, 20:3, poll 16:17
18:12, 24:19, 20:18 21:13 pringle
29:15 percent polls 37:5, 37:7,
paschal 28:13, 28:17, 13:14, 13:17, 38:15
30:2, 30:3, 29:6 36:8 print
30:13, 30:17, perhaps poor 42:13
31:6, 45:5 16:2 17:3 printed
pass person population 22:15, 42:17,
27:17 6:18, 11:5, 4:10, 4:11, 42:18
passed 11:9, 11:17, 17:4 printer
3:14, 5:18, 14:10, 16:13, populations 42:14, 42:16
6:3, 6:22, 7:16 16:15, 17:2, 4:10 priority
passes 18:8, 27:22, pose 10:6, 10:10,
45:9 30:8, 39:10, 12:14 11:4
passing 39:12, 40:11, positioned prison
7:11 41:16, 42:9 9:10
person's 15:18
pay positions prisons
8:17, 34:5, 10:8, 20:2 6:9, 8:14,
persons 5:14
35:18, 37:12, possibly 9:14, 12:16
37:14 16:5 probably
pettus 7:7
paying potential 19:10
27:13, 34:4 21:17 problem
phones 10:6
payment potentially 11:19, 16:7,
33:11, 34:10 3:18 32:11
pi 41:21
payments power problems
14:9 5:15, 8:5 7:13, 40:3
pick 14:17, 21:19
penalize pre-filed proceedings
6:4, 40:8 3:1 46:4, 46:5,
41:17
PLANET DEPOS
60
46:9, 46:11 43:5, 43:6, rate recording
process 43:9, 43:21 7:4 45:11, 46:4,
4:14, 10:18, puts raya 46:5
12:2, 15:17, 11:20 34:7 records
15:19, 16:16, putting re-elected 6:10
24:21, 24:22, 31:14 32:9 reduced
26:14, 31:1, Q re-entry 46:9
32:2, 32:6, queens 4:14 reducing
34:6, 37:2 38:4 read 4:15
professor question 2:5, 2:6, 2:7, reflection
7:2 5:8, 8:14, 24:11, 36:19, 14:5
proof 11:3, 16:15, 37:11, 44:22 reflects
16:19, 16:22, 17:13, 18:4, reading 29:11
22:11 18:15, 19:5, 15:10 refund
proper 21:5, 28:3, reaffirmation 39:14
25:9, 44:21 30:4, 34:16, 4:17 regardless
proportion 35:21, 39:10, real 21:8
16:22 39:22, 42:3 23:17, 35:3 regards
proposed questions realize 18:22
12:12 5:6, 22:3, 11:11, 11:12 register
proposes 32:20 really 9:1, 16:14
4:19 quick 29:14 registered
prosecuted 23:17, 35:3 reason 16:7
30:8, 32:10 quit 16:19, 26:3 registering
protest 3:16 reasons 16:14
13:1 quite 17:2 registrar
proves 14:14 receive 16:12
37:19, 37:22 quiz 16:1, 16:2, registration
provide 14:2 33:11, 34:2, 7:14
4:8, 15:15, quote 34:9, 35:18, reimbursement
34:5, 36:3 2:10 42:6 16:1, 39:19
provided R receiving related
5:21 8:9, 14:8, 46:13
provides race
23:20, 28:5 relates
14:12 30:20 recent
racial 18:18
public 19:15, 26:17 relationship
3:9 13:22, 14:22 recidivism
rafferty 6:12
pull 4:15 remark
22:18 30:2, 32:21, reciting
33:1, 33:13, 26:1
pulled 21:14 remarks
21:2, 22:16 33:16, 34:12,
34:17, 35:2, recommendation 3:6, 4:3, 29:20
pulling 17:10 remember
35:4, 35:20,
23:22 36:16, 37:5, reconstruction 5:8, 13:3, 21:3
put 39:8, 45:6 14:3 remind
9:14, 9:15, ran record 3:9
14:2, 24:12, 31:21 46:11 reminded
27:22, 30:22, recorded 12:21
35:3, 41:8, 1:11 remove
41:3
PLANET DEPOS
61
replace respect ripple sanders
41:1, 44:3, 44:3 6:22 12:4, 12:5,
44:4 respectful rise 12:6
report 10:14 11:18 saw
44:16, 44:18, responses risen 17:16
45:10 18:18 14:20 say
represent rest risk 3:14, 3:15,
24:3 41:3 41:9 8:15, 21:18,
representative restitution roland 21:20, 23:19,
18:6, 18:12, 24:18, 25:1 13:14 25:21, 33:9,
22:8, 23:18, restoration role 38:4, 38:8,
29:20, 30:1, 4:17 4:15 39:16, 40:14,
30:2, 32:21, restored roll 42:8, 44:9
33:1, 33:13, 16:11, 25:3, 44:19, 44:21, saying
33:16, 33:20, 25:6 44:22 12:8, 12:20,
34:12, 34:17, result room 19:14, 32:8,
35:1, 35:4, 7:3, 7:5 27:18 36:3
35:20, 36:16, returned roughly says
37:5, 38:20, 35:10 21:6 24:9, 24:14,
39:8, 40:20, review rule 28:6, 34:7,
41:11, 45:6 25:11 11:1, 31:14 40:1, 42:6
representatives right run sb1
6:13, 28:22 2:14, 2:17, 30:20 2:16, 4:19,
represented 3:8, 4:1, 4:16, running 5:18, 5:20, 6:3,
2:11, 18:1 5:9, 7:19, 9:8, 38:6 6:11, 6:22,
representive 9:19, 10:13, rural 7:11, 7:16, 8:6,
25:22 10:19, 10:20, 17:2, 28:14 8:8, 9:20,
republic 12:11, 15:6, S 15:20, 17:4
2:12 15:7, 16:11, scheme
republican safeguard 20:16, 32:6
17:7, 17:12, 10:13, 11:20
2:6, 18:12, 25:14, 25:22, school
29:11 safeguarded 15:13, 20:15
27:15, 28:4,
request 28:6, 30:5, 11:15 schools
15:1 30:20, 31:4, said 6:17
requested 31:5, 31:20, 18:4, 20:19, science
26:22, 27:2, 31:22, 32:20, 24:7, 26:2, 7:22
27:4, 27:9 35:20, 37:9, 27:12, 31:22, second
required 37:18, 41:10, 32:2, 32:6, 14:11, 25:19,
41:2 44:7, 44:15, 33:17, 40:15, 41:11, 44:17
requiring 44:20 46:5, 46:8, seconds
rights 46:10 41:12
16:7 samaritans
research 7:12, 12:21, secretary
13:2, 13:15, 15:22 18:16, 18:20
2:10, 18:9, same
21:2, 22:16 15:1, 17:6, secure
resolve 21:15, 21:16, 26:4, 28:3, 2:1, 11:22,
24:19, 25:3, 28:20, 33:18, 36:9
6:8 34:8, 34:10,
resources 25:6 see
ripping 35:10
9:17 18:13, 18:20,
36:22
PLANET DEPOS
62
22:11, 22:12, senators shouldn't skills
25:9, 26:9, 14:21, 28:22 25:2, 31:2, 46:12
29:2, 29:10, send 32:12 slot
31:16, 32:4, 25:10, 25:18, sick 38:10
34:18, 35:9, 27:6, 28:1, 17:4 small
35:22, 36:13, 36:12 side 31:15, 40:21
37:22 sending 40:5 smarter
seeing 26:21 sides 42:14
11:8, 40:4 senior 19:8, 38:13 smoother
seems 5:13, 8:12, sigma 4:14
40:7, 42:4 8:20, 9:4 5:15, 8:5 social
sell seniors sign 4:7
38:3, 38:10 12:15 3:2, 24:11, society
selling sentator 27:21, 43:10 4:14
38:17 40:22 signature-d2yvl society's
selma sentence 46:16 5:3
12:22 41:4 signed solution
senate serve 3:2, 3:22 11:13, 11:19
12:8, 12:12, 8:1, 17:6 significant some
12:14, 13:3, service 12:14 2:10, 36:14,
13:5, 13:18, 10:4, 15:15 silences 37:6, 39:13,
14:6, 14:7, services 5:2 40:1, 42:16
15:4, 26:3, 4:7, 16:2 simple somebody
44:18, 45:9 sessions 3:5, 42:16 24:8, 27:6,
senator 46:7 simplistic 30:11, 40:14
2:1, 3:8, seven 17:1 somebody's
12:12, 18:4, 37:12 simply 19:19, 28:9
18:6, 20:3, several 7:3, 8:8, 9:18, someone
22:6, 22:7, 19:4 12:10, 21:18, 2:21, 5:20,
22:13, 22:21, shall 41:1 8:9, 9:3, 9:5,
22:22, 23:2, 42:9 since 11:8, 14:10,
23:5, 23:10, share 14:18, 39:20 24:20, 27:13,
24:5, 24:15, 5:4, 10:5 single 39:9, 40:1, 40:2
26:6, 26:10, sheet 11:5, 11:15, someone's
26:11, 26:12, 20:1, 20:20 11:16, 38:10 15:1
26:21, 27:3, sheets singleton something
27:5, 27:11, 19:22, 21:6, 26:12 10:16, 31:1,
29:5, 29:13, 22:14 sir 35:2, 40:7
29:16, 30:10, sheriff 12:3, 15:5, something's
30:14, 31:5, 41:13 28:18
33:7, 33:15, 20:14
shortage sit sometimes
33:17, 34:16, 31:2
34:21, 35:5, 7:1 17:21, 42:14
should situation somewhere
36:7, 37:7,
38:12, 39:3, 2:5, 2:6, 2:7, 10:15, 10:22, 34:19
40:10, 43:2, 2:8, 9:17, 10:7, 11:3, 16:1 soon
43:4, 43:7, 19:18, 32:11, situations 11:1
43:11, 43:15 32:12, 32:13, 11:7 sorry
41:22 six 15:6
3:10
PLANET DEPOS
63
speak 36:18 6:17, 7:5, 7:10, take
3:22, 8:6, states 8:12, 12:15, 8:18, 19:11,
17:18, 21:11 21:14, 34:11, 15:14, 17:19, 21:12, 27:7,
speaker 43:14 24:1 41:1
3:21, 44:19 statewide stuff taken
speakers 38:7 42:16 3:11
3:10, 5:7, stats sub taking
44:10, 44:13 19:1 43:21 15:1
specific stayed subcommittee talk
41:4, 41:19 20:17 25:11, 25:18 22:9, 36:11
speech steal subject talked
13:20 2:4, 33:22 36:4 2:20, 20:9
spoke step submitted talking
21:11 4:13, 21:13, 43:20 24:18, 36:15,
spoken 24:18 substitute 43:22
19:4 sticker 10:11, 10:12 tampered
sponsor 33:18 sue 10:10, 11:7
17:14 stiffing 37:16 targeted
stack 39:13 sued 26:19
34:15, 34:18 stifle 37:10, 37:13 tarnished
staff 6:5 summer 6:11
6:1, 6:5 still 14:16 taxes
stamp 9:7, 14:17, supervision 21:13
33:16, 33:18, 15:21, 23:11, 46:10 teachers
33:20 23:12, 27:9, support 15:14
stand 27:10, 27:11, 11:18, 14:22 technically
12:19, 13:18 28:2, 35:11 suppress 30:16
start stolen 17:6 tell
3:17, 3:18, 10:17 supremacist 19:12, 20:13,
4:1, 10:2, 10:3, stop 14:7 25:19, 27:13,
19:13, 33:8 2:15, 3:4, sure 38:2
started 28:19, 31:17 10:7, 10:13, tells
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statement 8:16, 24:3 tabling 9:20, 9:22,
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6:7, 6:12,
PLANET DEPOS
64
13:7, 13:8, three transcribed 28:3, 28:19,
13:10, 15:4, 3:12, 3:15, 1:22 30:16, 46:9
15:5, 17:10, 19:11, 28:16, transcriber undermining
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threat tragedy 6:3, 9:8, 28:2, 13:17
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PLANET DEPOS
65
veterans voter's 40:6 4:5
2:18, 35:15 42:11 wanted willing
via voters 11:17, 21:10, 28:6
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3:11
PLANET DEPOS
66
yeah 21 88
40:21, 41:14, 7:22 13:12
45:8 25 9
year 31:15, 32:4 90
8:7, 13:22 28 31:13, 34:1
year-old 1:12 91
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46:20
PLANET DEPOS
EXHIBIT B
Transcript of Alabama Senate

Government Affairs Committee
Hearing
Date: February 7, 2024
Case: Transcription Services
Planet Depos
Phone: 888.433.3767
Email: transcripts@planetdepos.com
www.planetdepos.com
WORLDWIDE COURT REPORTING & LITIGATION TECHNOLOGY

1
2
3
4
5
6
7 In re:
8 ALABAMA SENATE
9 GOVERNMENT AFFAIRS COMMITTEE HEARING
10
11 RECORDED HEARING
12 Wednesday, February 7, 2024
13
14
15
16
17
18
19
20 Job No.: 535809
21 Pages: 1 - 63
22 Transcribed by: Lauren Bishop
Transcript of Alabama Senate Government Affairs Committee Hearing
Conducted on February 7, 2024 2
1 SENATOR TOM BUTLER: Let me go ahead and

2 call the meeting to order. Secretary, call the roll.
3 (phonetic).
4 SECRETARY: Senator Tom Butler?
5 SENATOR TOM BUTLER: Here.
6 SECRETARY: Senator Chris Elliott?
7 SENATOR CHRIS ELLIOTT: Here.
8 SECRETARY: Senator Arthur Orr?
9 SENATOR ARTHUR ORR: Here.
10 SECRETARY: Senator Gerald Allen?
11 SENATOR GERALD ALLEN: Here.
12 SECRETARY: Senator Greg Albritton?
13 SENATOR GREG ALBRITTON: Here.
14 SECRETARY: Senator Dan Roberts?
15 SENATOR DAN ROBERTS: Here.
16 SECRETARY: Senator Lance Bell?
17 SENATOR LANCE BELL: Here.
18 SECRETARY: Senator Keith Kelley?
19 SENATOR KEITH KELLEY: Here.
20 SECRETARY: Senator Coleman- Madison?
21 SENATOR COLEMAN-MADISON: Here.
22 SECRETARY: Senator Merika Coleman?
PLANET DEPOS
1 SENATOR MERIKA COLEMAN: Here.

2 SECRETARY: Senator Robert Stewart.
3 SENATOR ROBERT STEWART: Here.
4 SECRETARY: We have a quorum.
5 SENATOR TOM BUTLER: Okay. With quorum
6 being present, we're ready to conduct business. First
7 bill on the agenda will be Senate Bill 1. Senator
8 Gudger?
9 SENATOR GUDGER: Mr. Chairman, thank you
10 for the opportunity to be here today -- and
11 committee. I appreciate all the hard work and time
12 that you all let me have and putting into this bill
13 from last session until this session. I do have a
14 substitute that is in front of you. So make sure you
15 see that. Pull that out. And before we even start on
16 the last bill from last year that we brought forward
17 and pre-filed, this is the bill that we're going to
18 be talking about today. It is the substitute bill. I
19 don't know if you would like to, Chairman, to go
20 ahead and make a something -- if we can make a motion
21 to adopt that?
22 SENATOR TOM BUTLER: Senator Gudger, we
PLANET DEPOS
1 need to adopt --
2 MALE SPEAKER 1: Mr. Chairman, I would move
3 to adopt. So, second.
4 FEMALE SPEAKER 1: I'm three.
5 SENATOR LANCE BELL: Four.
6 SENATOR TOM BUTLER: Four owns. Moves to
7 adopt Gudger's substitute, by Senator Roberts.
8 SENATOR MERIKA COLEMAN: Mr. Chairman?
9 SENATOR TOM BUTLER: Yes, ma'am.
10 SENATOR MERIKA COLEMAN: Thank you, Mr.
11 Chair. I guess I was, as a relates to the setup and
12 even the adoption of it, the sub is six pages long.
13 The original bill is four pages long. We just kind of
14 got it right in front of us. Before the adoption can
15 he literally just give us a little bit of a synopsis
16 prior to --
17 SENATOR TOM BUTLER: Yeah. If you hadn't
18 answered in, that was the next thing is for Senator
19 Gudger to give us a overview of his bill and the
20 changes in the substitute.
21 SENATOR GUDGER: I've got some opening
22 remarks I'd like to say that's all right with the
PLANET DEPOS
1 committee first just for a moment and then go into

2 that if that's all right, Chairman?
3 SENATOR TOM BUTLER: Yeah.
4 SENATOR GUDGER: First of all, this bill
5 that's a substitute in front of you, has been
6 reviewed by groups all over this state over the last
7 nine months. The groups that oppose this bill and
8 groups that are for this bill. This substitute is --
9 that's being presented today, is to the best of our
10 ability for making changes so that we have heard
11 everyone's voice throughout this whole state.
12 I think this bill is the best for the
13 people of the state of Alabama. And I say that state
14 of Alabama, I'm talking about all people in the state
15 of Alabama. I believe that this bill helps it so that
16 voting is secure, honest and it knocks down the last
17 leg of ways that, I want to say the bad actors and
18 through the campaigns are trying to steal our
19 elections.
20 This bill should not be a Republican bill.
21 This bill should not be a Democratic bill. This bill
22 should not be an Independent bill. This should be a
PLANET DEPOS
1 bill for every Alabamian for secure elections.

2 Found a quote through my research and I
3 thought it represented this bill well. A Democratic
4 Republic cannot survive if election laws allow voters
5 to commit fraud easily. That's what's happening in
6 our state right now through ballot harvesting. Just
7 to be clear before we go into this, the number one
8 request that I get from groups all over the state is
9 that disabilities, people with disabilities,
10 including deaf, blind and especially our veterans
11 overseas, none of that changes from what we have on
12 federal code that we can't do anything about right
13 now anyway, because we're state government and it
14 supersedes us. We're not changing any of that in this
15 bill just to make sure everyone's clear. And those
16 people can still get assistance if they need to.
17 That's my opening remarks, Chairman. I'd
18 like to go into the bill just give the highlights if
19 that's okay?
20 SENATOR TOM BUTLER: Please.
21 SENATOR GUDGER: Okay. So this substitute
22 that's here, this bill has about five significant
PLANET DEPOS
1 changes or five things that changed and I want to

2 make sure everyone in the room that's -- and
3 listening on the microphone throughout the state and
4 your committee and you, Chairman, understand exactly
5 what it does.
6 First, the Substitute keeps the language
7 in the current law to allow for any voter to receive
8 assistance in filling out that absentee application
9 that he or she desires. It's current law now. We're
10 keeping it in the law. But as a number one point that
11 a lot of people said, we need assistance for people,
12 especially with disabilities. Again, we're not
13 changing that. They can still get assistance. My
14 father was an amputee and had bad eyesight at the end
15 of his life before he passed away, he could ask for
16 assistance. He could get this through the substitute.
17 Number two. This bill makes it unlawful
18 for any person to knowingly distribute an application
19 that is pre-filed or pre-filled with the voter's name
20 or any information already on the ballot application.
21 Meaning when you give someone a ballot application
22 there should -- everything should be blank. Should be
PLANET DEPOS
1 a name on there, any District, anything whatsoever.

2 Just a ballot application.
3 Number three. This bill makes it unlawful
4 for an individual to submit a completed absentee
5 ballot application to the absentee election manager
6 other than his or her own. So if you help somebody
7 fill in an application, or are you fill in your own,
8 you are responsible for returning that to the
9 election manager of your county or the Secretary of
10 State. Either one. But what's happening now is
11 they're grouping together in what we call harvesting
12 and there's data that shows where certain people pull
13 in 120 ballots at a time since the data I've got from
14 2016 'til now at one time and turn that in. We're
15 trying to alleviate that.
16 The bill also makes a class C felony for
17 anyone knowingly receiving payment or a gift for
18 distributing, ordering, requesting, collecting,
19 completing pre-filling or obtaining or delivering the
20 voters absentee ballot application. So if you receive
21 payment, there's a deterrent there now, which we
22 don't have currently that is a Class E felony.
PLANET DEPOS
1 The other side of that coin is this bill

2 makes it unlawful and makes it a Class B felony to
3 knowingly pay or provide a gift to a third party to
4 distribute, order, request, collect, pre-fill,
5 complete, obtain and deliver a voter's absentee
6 ballot application.
7 In short, you cannot pay or receive or it
8 will be a felony. Everything else is the same as in
9 the last bill, but those are the changes. I think
10 that I would like to reserve my time if we're going
11 to have a public hearing, Chairman. Or if you have
12 questions before I sit down, I'll answer those. But
13 if you want to wait until the public hearing or
14 whatever you decide, but those are the changes. Those
15 are my opening remarks. I would like another chance
16 at the microphone after we have a public hearing.
17 SENATOR TOM BUTLER: With your comments
18 we'll start with those who have signed up on Senate
19 Bill 1.
20 SENATOR GUDGER: Thank you, Chairman.
21 SENATOR TOM BUTLER: Becky Gerritson?
22 BECKY GERRITSON: Good afternoon. Welcome
PLANET DEPOS
1 back. It's nice to see you all again. I'm Becky

2 Gerritson, the executive director of Eagle Forum of
3 Alabama.
4 Over the last decade across the state of
5 Alabama, there have been multiple convictions for
6 absentee ballot fraud, also called ballot harvesting.
7 Eagle Forum is opposed to ballot harvesting because
8 it jeopardizes free and fair elections, it undermines
9 ballot secrecy and it allows ballot harvesters to
10 prey on vulnerable voters either by third-party
11 organizations with biased political opinions or by
12 people whom they don't even really know.
13 We support the provisions in this bill
14 that prohibit nonprofit groups or individuals from
15 distributing, collecting or returning ballots from
16 absentee voters for payment. And we also support the
17 important provision in the bill that allows
18 assistance to the blind, disabled or those who are
19 unable to read and write. Thank you for adding that.
20 In America, we are self-governed and we
21 accomplished this through our ballot. So it only
22 makes sense that we keep close tabs on where our
PLANET DEPOS
1 ballots go and how they get there once they leave our
2 control. Prohibiting ballot harvesting eliminates
3 risks and hazards that could cost you your vote and
4 it provides confidence of knowing that your ballot
5 will end up being counted as it should. By supporting
6 SB1, we recreate an opportunity to enhance the
7 security of elections in Alabama and safeguard the
8 sanctity of the voting process. Thank you.
9 SENATOR TOM BUTLER: Tari Williams?
10 TARI WILLIAMS: Good afternoon. My name is
11 Tari Williams. I'm a full-time employee with Greater
12 Birmingham Ministries. GBM is a faith-based,
13 nonprofit, social services and advocacy organization.
14 We provide voter education and lessons in civic
15 engagement and assistance with voter registration and
16 restoration and voting, as needed, among other
17 things.
18 We predominantly work with poor and low
19 come -- low-income individuals and communities
20 including those who are homeless, senior in age,
21 formerly incarcerated and currently incarcerated in
22 jail or prison. All would be severely impacted by the
PLANET DEPOS
1 passage of SB1. The bill purports to safeguard

2 electoral integrity, yet, in reality it
3 systematically dismantles the very mechanisms that
4 ensure every eligible citizen regardless of their
5 circumstances can participate in our democracy. The
6 word GBM undertakes educating registering voters and
7 nurturing responsible civic participation is rendered
8 null by SB1.
9 This bill doesn't just erect barriers. It
10 obliterates the bridge connecting disenfranchised
11 citizens to their Democratic right to vote. Focusing
12 on the incarcerated population. My role at GBM
13 involves empowering these individuals with knowledge
14 and tools for civic re-engagement and responsible
15 citizenship, emphasizing that they are societal
16 contribution does not pause with incarceration.
17 Voting via absentee ballot is a critical step in
18 maintaining their connection to society, aiding in a
19 smoother re-entry process and reducing the likelihood
20 of recidivism.
21 However, SB1's stringent measures making
22 absentee voting a challenge for these individuals who
PLANET DEPOS
1 already face significant obstacles from prison, from

2 within the prison system, such as lack of resources,
3 insufficient staffing and systematic inefficiencies
4 in mail handling.
5 SENATOR TOM BUTLER: Okay.
6 BECKY GERRITSON: Thank you.
7 SENATOR TOM BUTLER: Thank you very much.
8 Armani Benson? Let me remind everybody to speak and
9 you have two minutes.
10 ARMANI BENSON: Greetings. My name is
11 Armani Benson and I'm a senior who attends Alabama
12 State University and I hold current positions as the
13 president of Phi Sigma Alpha and the student
14 government Association of Justice. College and Civic
15 organizations help young adults become active within
16 her community and politics. This is why the SB1 bill
17 cannot be passed. For obtaining the absentee ballot
18 application for someone else, SB1 will charge
19 individuals with a -- a misdemeanor. Provide an
20 absentee ballot assistance for money will also
21 constitute a felony, meaning staff members to
22 facilitate absentee voting as a part of their job
PLANET DEPOS
1 could be charged with a felony under SB1.

2 If passed, SB1 could penalize to an
3 organization faculty and staff that facilitate voting
4 and stifle civic participation on campuses. This bill
5 will have a negative impact for college students
6 which will result in a decline of young adults
7 voting, overcrowding in prisons and Alabama. Also,
8 the record of lives of many young adults will be
9 tarnished as if they're criminals. SB1 will dismantle
10 the relationship between college students and our
11 local representatives.
12 All 14 of the University partners of the
13 higher education partnership have Civic in college
14 organizations. Those University partners our Alma
15 maters of Governor Kay Ivey and the six of the
16 Senators who support the bill. For example, for
17 college organization of the student or Student
18 Government Association, Sigma Nu or Alpha Gamma Delta
19 sets up at the student center to help students --
20 other students fill out their absentee ballot
21 applications. Should the students in organization --
22 organization be charged with a crime.
PLANET DEPOS
1 If an elderly person is disabled,

2 therefore he gives college students gas money for
3 absentee ballot assistance. Would you feel justified
4 of the student was charged with a felony? Could you
5 feel honorable knowing that students from your alma
6 mater were arrested for a law you passed? Also how
7 would you regain the trust of your alma mater
8 students and faculty?
9 Finally as a result of students being
10 arrested for helping with absentee ballots, would
11 alumni and corporate funding decline for these
12 universities? In passing, SB1 will dismantle the
13 cautiousness of our constitutional rights as voters.
14 Thank you.
15 SENATOR TOM BUTLER: Thank you, Miss
16 Benson.
17 SENATOR TOM BUTLER: Travis Jackson?
18 TRAVIS JACKSON: Thank you all for the
19 opportunity to speak. My name is Travis Jackson. I am
20 a black voters matter advocate who volunteers with
21 Roll Into the Polls, which is a group of like-minded
22 people transporting voters to their accurate voting
PLANET DEPOS
1 polls. And I'm also an Iraq veteran.

2 Many government officials are so
3 determined to send our state back to 1924 when it is
4 now 2024. When Jim Crow laws like black holds were
5 still in existence. Black holds were racially fueled
6 on policies exercise and confederate states like
7 Alabama in 1865. The sole purpose was to uphold white
8 supremacy by taking away their rights to vote from
9 African-American families.
10 Senate bill 1 is just that. It is a
11 modern-day black hold. It is a fact many individuals
12 with disabilities exercising their right to vote
13 through absentee ballot. If this bill becomes law,
14 then they will put other lives in jeopardy. If
15 someone is paralyzed and they asked for someone to
16 retrieve that absentee ballot, they will be charged
17 with a Class A misdemeanor. SB1 also criminalizes
18 people who receive funds. Example, if a pregnant
19 person, especially someone who's within their second
20 and third trimester provides gas money to their non-
21 relative neighbor for issue or acquiring an absentee
22 ballot, then they will both be charged with a felony.
PLANET DEPOS
1 Make that make sense.

2 If this authoritarianism bill becomes law
3 then there will be an increase of voter suppression,
4 such as heavy police forces at several voting pole
5 locations. Taking away someone's civil rights or
6 requests for their voter assistant, expresses the
7 highest form of human indecency. Therefore, I
8 strongly plead for the committee members to oppose
9 Senate Bill 1, just like I do. Thank you for your
10 consideration of my time.
11 SENATOR TOM BUTLER: Barbara Manuel?
12 BARBARA MANUEL: Thank you. Good afternoon.
13 My name is Barbara Manuel as stated. I am the
14 affiliate president of the National Federation of the
15 Blind of Alabama. I'm here once again to express
16 opposition to Senate Bill 1.
17 Basically, we want everyone to know that
18 we are against this bill. It states currently that
19 anyone who will assist individuals will be
20 criminalized for providing such services. Of course
21 currently the bill that you all have presented has
22 some provisions in there. Those provisions have not
PLANET DEPOS
1 been stated clearly how this is going to take place

2 and we just need some clear definitions of how we can
3 participate in one of America's greatest rights.
4 We know that if an individual assist us,
5 take just as has been stated maybe give someone
6 something, monetary or gas or maybe a meal,
7 individuals not only disabled individuals. Every
8 individual had -- runs a possibility of being
9 criminalized just performing one of Alabama's
10 hospitalities, which is showing appreciation.
11 Of course, most all of our Southern
12 states, we realize hospitality is within our -- what
13 we are defined to be. This bill does not exemplify
14 who we are. We do not want to be minimized from
15 casting our vote. Whether we're disabled or, quote
16 unquote, normal. We want to be able to cast votes as
17 any other individual and able to assist someone who
18 needs the assistance prior to an individual assisting
19 someone. They are qualified as a legal citizen, but
20 once this take place, they stand the possibility of
21 being criminalized. Thanks so much.
22 SENATOR TOM BUTLER: Thank you, Ms. Manuel.
PLANET DEPOS
1 Roland Grady? Rolanda?

2 ROLAND GRADY: Roland. Good afternoon. My
3 name is Roland Grady and I am an Andrew Goodman
4 Foundation Ambassador at the University of Alabama's
5 Chapter of Vote Everywhere.
6 The Andrew Goodman Foundation is a
7 National Organization that empowers young people to
8 initiate and sustain creative, effective social
9 actions that advanced civic engagement. At the
10 University of Alabama, students come from all of
11 Alabama's 67 counties. UA does not offer election day
12 off which makes traveling home to vote incredibly
13 difficult. As result students on Election Day are
14 left to navigate the absentee ballot process.
15 To vote by absentee ballot, students must
16 fill out and mail an application as well as provide a
17 copy of a photo ID. Once students are approved after
18 submitting their application, they will still need to
19 fill out their absentee ballot and mail it back home.
20 For many students who are juggling extracurriculars,
21 class and work, this process can be confusing and
22 daunting, but Everywhere came to help this void and
PLANET DEPOS
1 offer support to peers who are struggling to

2 understand the absent application process and
3 deadlines.
4 We are completely nonpartisan with the
5 goal to help ensure that every student is able to
6 make their voice heard. We do not assist students in
7 completing or returning their absentee ballots, but
8 we do actively work to educate and support our
9 students in learning to value and act on their right
10 to vote. Some of these efforts include providing
11 assistance in determining how our in-state and out-
12 of-state campus members can vote by absentee ballot.
13 A resource we offer for this is Turbo
14 Boat, a non-partisan online service which helps
15 voters on all 50 states and Washington D.C. access
16 voting guides, alerts and real-time help they need to
17 vote in every election. Since many of our students
18 are not from Tuscaloosa and continue to vote in their
19 hometowns, Turbo Vote provides critical resources to
20 help them navigate the absentee ballot system,
21 specifically with the regulations of where they're
22 from.
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1 With our contract of Turbo Vote, they send

2 any member of our community who signs up an
3 application for an absentee ballot. They include the
4 application with a stamped envelope, pre-addressed to
5 the appropriate official for where they are
6 registered. It is up to the individual who receives
7 these to complete the application and mail it in, but
8 if requested Turbo Vote can still continue to send
9 reminders via text and email to alert them to
10 deadlines and applications for the actual ballot to
11 be received.
12 SENATOR TOM BUTLER: Ms. Grady, two minutes
13 is up.
14 ROLAND GRADY: Okay. Thank you.
15 SENATOR TOM BUTLER: Thank you. Betty
16 McShannon (phonetic)? Shannon?
17 BETTY MCSHANNON: Good afternoon. My name
18 again is Betty McShannon. I'm here with the League of
19 Women Voters of Mobile. I'm the voter services chair.
20 I see SB1 as a scare tactic, misinformation and a
21 return to tactics that denied minorities access to
22 the vote. Things that -- things have changed
PLANET DEPOS
1 significantly. There is -- there -- the possibility

2 of ballot harvesting does not exist in the 21st
3 century. There's no documentation to that fact.
4 Thank God for technology reports of
5 tampering with votes if an unproved and deceitful
6 tactic to scare citizens. In 2020 when the Democratic
7 party was successful and cries got louder, the
8 accusations were more ridiculous. There is no proof.
9 None. No visible studies providing the existence of
10 voter fraud in any way shape or form.
11 SB1 is a ludicrous accusation and fear
12 tactic to impede absentee voting. Those unable to
13 make it to the polls need help with casting and
14 absentee ballot. From the physically disabled
15 unavailable -- unable to make it to the polls to
16 those without adequate transportation, students and
17 poor folk. You are effectively threatening
18 nonpartisan citizens willing to help the least of
19 those.
20 SENATOR TOM BUTLER: Thank you. Mr. Percy
21 Garrett?
22 PERCY GARRETT: All right. Good afternoon.
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1 My name is Percy Garrett from Dothan, Alabama. And I

2 salute the Senator from Coleman. A man of many good
3 things, businessman politician and called several
4 terms and now serving me -- serving us. I salute you
5 for your service. Although I think what you're
6 serving us today is tragic. This bill is on the third
7 go around. Last year was 209. This year was is
8 (inaudible).
9 I've come today to plead with you to stop
10 this bill yourself because it's a suppressive deal.
11 It hurts those who respect you and look up to you.
12 Sometimes I think we -- we strain on that. That's why
13 I came. I think we can do better. I think we can
14 serve those who vote for you. We vote for you because
15 we believe in you.
16 So I'm not coming to fight. I'm coming to
17 make a request, please. It's beyond that nothing good
18 for anybody. Please stop it.
19 SENATOR TOM BUTLER: Cathy Jones?
20 SECRETARY: One second. All right.
21 CATHY JONES: Thank you. Good afternoon. My
22 name is Cathy Jones and I live in Huntsville. And as
PLANET DEPOS
1 a president of the League of Women Voters of Alabama,

2 I am so honored to represent passionate volunteers
3 from across the state who are supporting citizens and
4 helping them get ready to vote. I also am honored to
5 represent League members across the state who have
6 disabilities. One-third of Alabamians are disabled.
7 It would -- they would be harmed by this
8 bill and not being able to choose to sister of their
9 choice -- sister of their choice when they're casting
10 their ballot, which is a federally protected law. I
11 realized that you've got an amendment or substitute
12 here, but -- but just wanted to say for the current
13 SB1, as it states here, and we'll look at the
14 substitute, we are concerned.
15 The league helps voters by providing voter
16 registration, polling place checks, appropriate
17 ballot application giving them the correct one for
18 their county, giving copies of IDs, even double-
19 checking because there's so many ways to have your
20 vote not count.
21 Across the state we are one of many Civic
22 organizations that provide help, as well as
PLANET DEPOS
1 caregivers, nurses, church members, and school

2 administrators, teachers and students are all
3 providing assistance to people who vote and this --
4 we are explaining a fundamentally confusing and
5 error-prone process and we fill a gap that the
6 elections officials cannot fill. They work their
7 business hours. We're there when they're not working.
8 SB1 is extremely harmful and it will
9 criminalize everyday voters who are asking friends
10 for help and asking any friend or volunteer who
11 responds would also be guilty of a crime and if any
12 money like gas money is offered to pay for
13 transportation and if it's accepted, then you're
14 looking at a Class C or B or C felony, which would
15 have harsh penalties equivalent to manslaughter in
16 the state of Alabama, which is not -- it is unfair.
17 All right. Thank you.
18 FEMALE SPEAKER 1: Good afternoon,
19 Senators. I serve congregations in both Birmingham
20 and Tuscaloosa. And as clergy, one of the values of
21 my faith tradition states that we promote the
22 Democratic process both in our congregations and in
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1 society at large. Protecting and defending our

2 democracy is part of our religious beliefs.
3 While I would never tell anyone how to
4 vote, it is my religious obligation to ensure that my
5 folks have access to their ballots and since our
6 sanctuary is a polling place, to ensure that every
7 citizen of Alabama has a clear and easy path to
8 voting. SB1 would inhibit access to voting and
9 inhibits the religious liberties of my people. I pray
10 that you will honor the importance of the voice of
11 each citizen of Alabama and allow them to vote for
12 their leaders and their religious values. Please
13 reject SB1.
14 KYLIE KERR: Good afternoon. My name is
15 Kylie Kerr (phonetic). I'm a resident of and a public
16 school teacher in Shelby County. I am here because my
17 students are students with individualized education
18 plans. They are students with IEPs. They have
19 specific learning disabilities. Autism, ADHD and they
20 fall under one of the 13 protected categories under
21 the Individuals with Disabilities Education Act.
22 My students have every right to vote, but
PLANET DEPOS
1 my students with executive functioning disorders, my

2 students who may never be able to physically drive
3 themselves, even though they are protected under part
4 of this substitution, they are still at risk because
5 I am not one of these protected people that could
6 help them. Who is to say that by making sure my
7 student as they get older fills out the form
8 correctly? Because I pre filled it out for them with
9 their address that is given to me, that I am not
10 committing a felony. If their parents many of whom
11 are registered voters and your constituents as well
12 need assistance themselves due to disability and as
13 many others have said, the disabled in our country
14 are the majority, minority. Any of us could become
15 them at any time, including my 25-year-old younger
16 sister who became a legally blind sitting in class at
17 age 17, who is no longer allowed to drive do to a
18 freak accident. I am a protected person under SB1 for
19 my sister. I am not for my students because I cannot
20 help them in the ways they may need it most.
21 Students with occupational therapy needs
22 physical therapy needs are not protected under this
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1 in the same way as others because they are not

2 illiterate. They are not deaf. They are not blind and
3 they are not considered invalid in an outdated term.
4 My students and my sisters deserve better. SB1 does
5 not protect them, it harms them. Thank you.
6 SENATOR TOM BUTLER: Brian Lords
7 (phonetic)?
8 BRIAN LORDS: Thank you. My name is Brian
9 Lords. I'm a resident of Limestone County and thank
10 you for let me address the committee today. I've
11 assisted many voters that need assistance with the
12 absentee voting process. Many of these people are
13 elderly, disabled or both. Many of them are
14 economically challenged. They have no internet. They
15 have no way to copy an ID that needs to accomplish --
16 to accompany the absentee application.
17 When it comes time to the application, I
18 have provided them with copies of the application but
19 with nothing pre-filled and I make copies of their
20 ID. When it comes time to vote, I've assisted with
21 the completion of the affidavit -- affidavit
22 envelope, which can be very confusing. I do this for
PLANET DEPOS
1 free and consider it a community service to allow

2 everyone a chance to exercise one of their most basic
3 rights, the right to vote.
4 I request that anything be done with SB1
5 will make sure that nothing takes away my ability to
6 provide the support. Thank you.
7 SENATOR TOM BUTLER: (Inaudible).
8 SENATOR GUDGER: First of all, I want to
9 say thank you to every one of the speaker's that got
10 up today and representing here. I've been a City
11 Councilmember in politics for 21 years. And when you
12 walk into a room and there's no one there or cares
13 about what happens, the Democratic process losses and
14 thank you for being here. Even if you're opposing
15 this bill, I appreciate you taking time to be here.
16 My goal of this bill and this substitute
17 is to realize everything you just heard, make the
18 changes from the original bill into this substitute,
19 which is what's happened. 95% of everything they just
20 said is covered in this substitute. My only fault is
21 that I can't process that bill until we got into
22 session or you would have seen this bill beforehand.
PLANET DEPOS
1 Having said that, I have met with everyone

2 that has opposed, that is called me and said I want
3 to meet with you, I've met with them. Anybody that
4 said I'm for this bill, I want to meet with you, I've
5 met with him. I've done my due diligence all over the
6 state to feel like this bill is fair and the key is
7 that we want everybody that wants to be able to vote
8 to have access, to make sure it's secure vote and
9 that they're able to vote.
10 The one thing that is the bottom line is
11 that there's illegal activities that are stealing
12 elections and there was some talk earlier that's not
13 happening. I have evidence-based facts and data that
14 show you exactly which counties it's happening in. On
15 average were three to three and a half percent
16 absentee ballots. There's a few counties that are
17 over 20 percent. That means one out of every five
18 ballots cast is an absentee ballot. That's -- there's
19 no way that's possible, right? Having said that
20 anyway, I've got the data. We can show that from
21 every County throughout the state. From that, it is
22 happening. This substitutes handles the issues that
PLANET DEPOS
1 we heard today. I feel like they have. I appreciate

2 the opportunity for the next meeting to come back and
3 forth and talk more about this bill, but until then,
4 Mr. Chairman, thank you for your time.
5 SENATOR TOM BUTLER: Well, we have one --
6 one question.
7 SENATOR GUDGER: Please.
8 SENATOR TOM BUTLER: Two questions.
9 SENATOR MERIKA COLEMAN: Thank you. Thank
10 you. Mr. Chairman. You know and I -- I guess I
11 appreciate that the chair -- the gentleman for
12 attempting to remedy some of the problems with the
13 original version of the bill, but they're definitely
14 not all remedied.
15 I was appointed some years ago by the
16 former Secretary of State John Merrill on the voter
17 fraud reform task force. I was on it. Think Senator
18 Singleton was on it. We had -- it was Democrats,
19 Republicans, ACLU and an Eagle Forum. So you have
20 this cross-section of folks that were on this
21 committee. And when I told Secretary Merrill at that
22 time was that I mean, I don't mind about serving as
PLANET DEPOS
1 long as we're not trying to fall into the trap of

2 what was going on federally and we stuck to what our
3 goal was. And when the research was -- I don't know
4 what you have Senator. I don't know. I mean your
5 office is down the hall from mine. I would welcome
6 looking at it. But for those of us that were on that
7 committee, I think from like 1986, maybe there were
8 six cases and there was the cases were on the local
9 government end when it came to absentees, there was
10 not this large-scale fraud that at the national level
11 the national media and some one of those three-letter
12 news stations kept talking about and so, you know,
13 that was my challenge there with the misinformation.
14 But even with this bill itself, I told this same
15 story all three years. I told it in the house on
16 Judiciary and now here in this particular committee.
17 Even under the version of the bill you have right
18 now, my great Aunt Olivia Bizzelle (phonetic), not my
19 aunt, my great-aunt who now has stepped into the role
20 of my grandmother since my grandmother has passed, I
21 go to my great aunt Olivia Bizzelle's home to help
22 her with her absentee ballot. If I help refill it or
PLANET DEPOS
1 when we complete the application itself, if she says

2 to me, which would not be uncommon for her to say,
3 baby, can I give you two dollars for your time or for
4 your gas, both of us according to this piece of
5 legislation have committed a crime and there's
6 something wrong with that.
7 So, again, if it doesn’t fix that, it
8 hasn't remedied the major issues. And again there
9 have been so many times in this legislative body in
10 the years that I've served, I've asked the question,
11 why are we doing this and then I'll end up saying
12 this piece of legislation is not worth the piece of
13 paper that is written on.
14 Another one of those situations where we
15 just have not had this widespread on voter fraud like
16 what the national -- and I just hate when we in,
17 Alabama get caught up in that as well. So my question
18 to you then, because I said I had a question, is,
19 with under the scenario that I gave you, have me and
20 my aunt Olivia Bizzelle committed a crime?
21 SENATOR GUDGER: The words knowingly
22 distribute our excuse me knowingly and willfully
PLANET DEPOS
1 receive payment or knowingly pay someone, that's the

2 intent and so I'm not an attorney.
3 SENATOR MERIKA COLEMAN: And I am.
4 SENATOR GUDGER: I know. That is --
5 SENATOR MERIKA COLEMAN: And I would
6 knowingly.
7 SENATOR GUDGER: The men's (inaudible) is
8 what they're calling that, right? Which is the term
9 intent. And so that intent and this bill is meant for
10 ballot harvesting. Now, you're not ballot harvesting
11 because you've got that one application turned down.
12 SENATOR MERIKA COLEMAN: You -- but you
13 have to show me -- and I hear you. And again, you're
14 a friend.
15 SENATOR GUDGER: I understand.
16 SENATOR MERIKA COLEMAN: But I still
17 wouldn't want to know in that particular situation,
18 because you said that this is this is honing in on
19 ballot harvesting, I just don't see that. Since the
20 Republicans done taken over in 2010. You know, we've
21 had so many pieces of legislation that had unintended
22 consequences. Let this not be another one. That's all
PLANET DEPOS
1 I'm saying. Just let it not be another one.

2 SECRETARY: Ms. Chairman? Ms. Chairman?
3 SENATOR COLEMAN-MADISON: And I'll try to
4 be brief. Thank you, sir. Thank you. Thank you, sir.
5 Senator Gudger, I agree with my colleague. I'm not
6 understanding ballot harvesting. Right now I think
7 federal law says if you need assistance at the poll,
8 you have a right to have anybody of your choosing to
9 assist you. That's in voting. What is the problem
10 with helping somebody to fill out an application or
11 even filling out the application? It is going to go
12 to the board of registrar's office who's going to
13 check it. And if something is wrong is going to be
14 thrown out.
15 I mean you're just filling out helping
16 them to get the application. The application is sent
17 to the voter. Again, it goes back to the board of
18 registrar's to check it. Yeah. I know you say
19 relatives. Everybody don't trust their relatives. And
20 I mean really and I say this because there may be a
21 young person that living with you and you say mail
22 this form and they go and by whatever they're doing.
PLANET DEPOS
1 It may not ever get mailed. I've had that situation

2 to happen because I've helped people with the filling
3 out the applications and everything and they don't
4 trust everybody. These little old ladies who work
5 with certain groups, they got this call chain. They
6 calling, you know, well, they'd -- she's coming.
7 She's on her way to help. But this ballot harvesting
8 doesn't make any sense because the ballot is not sent
9 back to the person who is helping them. It is sent
10 back to the individual person and they can mail it
11 back.
12 Now somebody mentioned about the
13 envelopes. Confusing. I don't know if you've ever
14 gone to your probates office or your a clerk's office
15 and watched them count those ballots and they go
16 through it. First of all, they do open it and if it's
17 in the wrong envelope, it's not going to be counted.
18 They're going to throw it out. You -- and I am seeing
19 it from the ground up. They're going to throw it out.
20 So all I'm saying is that the ballot harvesting just
21 doesn't fly.
22 The other things the reason why you may
PLANET DEPOS
1 find numbers higher on absentee ballot and we all not

2 to be trying to discourage people from voting whether
3 it's absentee ballot is there for a reason. We need
4 to be -- I wish more people can vote because stand in
5 a long line, but you have people who live in rural
6 counties who have to work and they live long
7 distances from their home. They can't take off of
8 their job on Election Day to go and vote. So many of
9 them vote absentee ballots and you still have in
10 spite of education, we still have a lot of people
11 that are don't read well and they need the
12 assistance.
13 So all I'm saying is that -- I don't want
14 to see unintended consequences. I don't want to see
15 the -- the election process abused and misused. You
16 will always have some rotten apples in the barrel,
17 but it is not a pervasive kind of thing. And wherever
18 you find the criminal convicted of these kinds of
19 crimes, let's go there. Don't call me into the
20 principal's office for something Miss Jone's did. Get
21 Ms. Jones. So like if somebody's violating this law,
22 get them. Don't penalize these people who are sitting
PLANET DEPOS
1 here. And as you can see this is -- this has a great

2 interest. This is going to be a ripple effect from
3 one end of the state to the other. I want to thank
4 everybody for coming.
5 SENATOR ROBERT STEWART: Mr. Chairman, can
6 I be recognized?
7 SENATOR TOM BUTLER: Senator Stewart.
8 SENATOR ROBERT STEWART: I just -- I thank
9 you for this opportunity Mr. Chairman to speak and I
10 want to just express my grave concerned because I
11 represented the black belt as you know, and Selma,
12 Alabama is my hometown and Senator Coleman alluded to
13 the hurdles that people face in the black belt and
14 other rural communities voting.
15 When you talk about GLTB organizations, we
16 need more people more engaged in the voting process
17 now more than ever, especially when we look at the
18 voter turnout is dismal. And this -- this legislation
19 doesn't warrant anyone to have a felony. We as a body
20 need to be serious, get serious about prisons
21 overcrowding and that is -- that's not an unintended
22 consequence. This is intentional. And -- just clap.
PLANET DEPOS
1 It's okay to clap. And these GLT organizations like

2 Greater Birmingham Ministries, like Black Voters
3 Matter, they are mutual aid societies. They are
4 helping impoverished people and the access -- the
5 lack of access to transportation is a huge hurdle. We
6 don't have public transportation in mass in this
7 state and let's not begin to talk about the distances
8 that people have to drive to their polling precincts.
9 So I would ask you to reconsider the
10 felony aspect of this legislation. Thank you.
11 SENATOR TOM BUTLER: Thank you, sir.
12 SENATOR GUDGER: May outside one more
13 thing, Chairman and I'll head out. I believe that a
14 lot of what all three of our Democratic senators just
15 said was assistant and I just want to read for the
16 crowd one paragraph that's on page 4, line 89 through
17 94 to make sure that everybody understands, I agree.
18 We need assistance and people need assistance, right?
19 But this states so you're able to.
20 Any applicant may receive assistance in
21 filling out the application that he or she desires,
22 that each application shall be mainly signed by the
PLANET DEPOS
1 applicant and, if he or she signs by the mark, the

2 application shall also include the name of the
3 witness and the witness' signature.
4 So again, a lot of what you're talking
5 about we heard. We put back into this bill. I'm going
6 to figure out a way so you can see the substitute
7 because it's changed from the original version, which
8 I think is why a lot of you are here today. That's
9 not voting on it. I'm not able to do that. So I will
10 figure out a way to do that, but I would love to
11 distribute so that you're able to see this to make
12 sure it's not want organizations and people are able
13 to get to the vote and polls. Mr. Chairman, that's
14 all I got. Thank you so much and committee. Thank
15 you.
16 SENATOR TOM BUTLER: Okay. We're going to -
17 - do you have something?
18 SENATOR GERALD ALLEN: No. I'm ready.
19 SENATOR TOM BUTLER: Okay. On Senate Bill
20 1. Secretary, call the roll.
21 SENATOR COLEMAN-MADISON: Mr. Chairman, are
22 we -- taking a vote on the --
PLANET DEPOS
1 SENATOR TOM BUTLER: The adoption is we had

2 a -- adoption of the (inaudible)?
3 SECRETARY: Roll call, please. (Inaudible).
4 MALE SPEAKER 1: Aye.
5 SECRETARY: (Inaudible).
7 SECRETARY: Mr. Elliott?
8 SENATOR CHRIS ELLIOTT: Aye.
9 SECRETARY: Mr. (Inaudible)?
11 SECRETARY: Mr. Roberts?
12 SENATOR DAN ROBERTS: Aye.
13 SECRETARY: Senator (Inaudible).
15 SECRETARY: Senator Kelley?
16 SENATOR KEITH KELLEY: Aye.
17 SECRETARY: Sorry. Senator Coleman-Madison?
18 SENATOR COLEMAN-MADISON: No.
20 SENATOR MERIKA COLEMAN: No.
21 SECRETARY: Senator Stewart?
22 SENATOR ROBERT STEWART: No.
PLANET DEPOS
1 SECRETARY: Senator Butler?

2 SENATOR TOM BUTLER: Aye. Seven ayes and
3 three nays. And bills given favorable report.
4 SENATOR CHRIS ELLIOTT: Mr. Chairman -- if
5 we adopt so that bill one is substituted.
6 SECRETARY: Okay. Who said that?
7 SENATOR MERIKA COLEMAN: Mr. Chair -- Mr.
8 Chairman. Yeah. I haven't -- we -- we -- even a
9 sponsor of the bill said we were not going to be
10 voting on this bill until next week. That's what was
11 just told to the public.
12 SENATOR TOM BUTLER: We're going to vote on
13 the bill --
14 SENATOR COLEMAN-MADISON: Did we not just
15 tell the people that?
16 SENATOR MERIKA COLEMAN: You told the
17 people that though, Mr. Chairman.
18 SENATOR COLEMAN-MADISON: It's all right.
19 It is probably going to change.
20 SENATOR TOM BUTLER: Since you want to have
21 --
22 MALE SPEAKER 5: Can't hear you.
PLANET DEPOS
1 SENATOR MERIKA COLEMAN: They can't hear

2 you, Mr. Chair is what they're saying. That's what
3 they're saying. They can't hear you.
4 SENATOR TOM BUTLER: Seven of three bills
5 give in favor report.
6 SENATOR COLEMAN-MADISON: But what are they
7 billing, Mr. Chairman?
8 SENATOR MERIKA COLEMAN: Mr. Chairman, I
9 really just think -- and I know we have to be in
10 session at 3:00 and I recognized --
11 SENATOR TOM BUTLER: Hold on. Just getting
12 this paperwork in order. Go ahead.
13 SENATOR MERIKA COLEMAN: Mr. Chairman, we
14 you know, it has culture normally, you know, we get a
15 substitute on the day of that we get an opportunity
16 to digest the bill and that's what I thought we were
17 going to get a chance to do today because that's how
18 it was presented to the public. Like this is
19 streaming live for people that all over the state
20 heard at the beginning that we were not going to vote
21 on this bill. That it would give us an opportunity
22 for all of us to look at the bill but right now,
PLANET DEPOS
1 we're being asked to vote on a bill that we have not

2 even had an opportunity to digest.
3 SENATOR TOM BUTLER: We didn't adopt the
4 substitute, I don't believe? Did we?
5 SENATOR MERIKA COLEMAN: And we just did
6 that. Y'all did it anyway. I didn't vote for it.
7 SENATOR CHRIS ELLIOTT: So, Mr. Chairman,
8 the motion is to give the bill a favor report and I
9 think you got to --
10 SENATOR TOM BUTLER: Is substituted.
11 SENATOR CHRIS ELLIOTT: As substituted and
12 it's got a first and a second. And it's ready.
13 SENATOR TOM BUTLER: Senator Grudger --
15 would tell you take control of your committee because
16 he's not the chair committee.
17 SENATOR TOM BUTLER: Hold on one second.
18 Senator Gudger spoke on the bill initially. He
19 wrapped up at the final vote, final conversation. We
20 had 12 people speak against the bill. One person
21 spoke for it. Chairman wants to have a vote today on
22 this bill because we've heard the public.
PLANET DEPOS
1 Now, it's time for Senator Gudger to take

2 consideration in all of you on the committee
3 consideration of what you've heard and be prepared to
4 go to the floor with amendments or however you want
5 to do it. So I'd like to call for a vote today in
6 this committee on --
7 SENATOR MERIKA COLEMAN: I am saying --
8 SENATOR COLEMAN-MADISON: Mr. Chairman, if
9 I may -- just -- just --
10 SENATOR TOM BUTLER: Hold on.
11 SENATOR COLEMAN-MADISON: May I just say
12 something? May I just make one comment? I just would
13 like because that's why I said with Senator Gudger
14 because I wanted to make sure just this last thing
15 that he brought up on page four that anybody can
16 receive assistance from anybody. If taken away you
17 got to be a family person. But all I'm saying is that
18 I just wish people would have the opportunity. We
19 just got it. So we're trying to read as you're going
20 through. We like you, but I think that people need to
21 read it and understand it.
22 I have a strange feeling that this bill
PLANET DEPOS
1 will be on the agenda tomorrow, which means that --

2 which means that citizens will not have had an
3 opportunity to look at this to -- to take it back and
4 digest it, to get back to your constituents and
5 people that you represent and try to help. I retired
6 from City of Birmingham as ADA Compliant. So I do
7 understand disabilities and barriers, but I want us
8 to understand because voting is a fundamental right
9 and we don't want Alabama to be accused of denying
10 anybody, but I do want people to read the bill and
11 understand what the bill says and have an opportunity
12 if you so desires, Senator Gudger and said to offer
13 the amendments and to get somebody to sponsor
14 amendments, but I don't think you going to have time
15 to do tomorrow.
16 SENATOR TOM BUTLER: Senator Gudger?
17 FEMALE SPEAKER 2: We can't hear you,
18 Senator.
19 SENATOR TOM BUTLER: Okay. Call the roll.
20 Call the roll. Go ahead.
21 SECRETARY: Senator Elliot?
PLANET DEPOS
1 SECRETARY: Senator Orr?

2 SENATOR ARTHUR ORR: Aye.
3 SECRETARY: Senator Allen?
4 SENATOR GERALD ALLEN: Aye.
5 SECRETARY: Senator Albritton?
6 SENATOR GREG ALBRITTON: Aye.
7 SECRETARY: Senator Roberts?
9 SECRETARY: Senator Bell?
10 SENATOR LANCE BELL: Aye.
11 SECRETARY CALDWELL: Senator Kelley?
13 SECRETARY: Senator Coleman-Madison?
14 SENATOR COLEMAN-MADISON: No.
16 SENATOR MERIKA COLEMAN: No.
17 SECRETARY CALDWELL: Senator Stewart?
19 SECRETARY: Senator Butler?
20 SENATOR TOM BUTLER: Aye.
21 SECRETARY: All right. Who made the motion?
22 Who made the motion? Elliott will be second.
PLANET DEPOS
1 SENATOR TOM BUTLER: Four (inaudible).

2 Okay. Senator Chairman? To call Senate Bill 39. Dam
3 safety bill.
4 SENATOR CHAMBLISS: Mr. Chairman, I thank
5 you for your indulgence. We can get into another
6 committee. This bill is a follow-up to a bill that we
7 passed last session. I had the bill applying to state
8 government at as well. But there were some issues
9 that were brought up by DCNR. We've worked over those
10 issues over this year. This is drafted by DCNR to
11 apply to DCNR and agreed upon so with that if there
12 any questions, I'd be happy to answer then.
13 SENATOR TOM BUTLER: Mr. Chairman, I make a
14 motion that we adopt the amendment.
15 SECRETARY: I am ready.
16 SENATOR TOM BUTLER: Hold on just a second.
17 Senator Chambliss?
18 SENATOR CHAMBLISS: Yes. Do you want me to
19 answer a question?
20 SENATOR TOM BUTLER: Yeah. Who's question?
21 SENATOR CHAMBLISS: Currently in state law
22 there is no provision or process for state
PLANET DEPOS
1 governments to the state government to inspect and

2 four dams, inspect their dams and then what they do
3 with that information and alerting their local EMAs.
4 This lines out that process for them to do.
5 SENATOR COLEMAN-MADISON: I'll second it.
6 SENATOR CHAMBLISS: We do have a technical
7 Amendment change in 2024 to 2023. There was an error
8 in there.
9 SECRETARY: You all have that.
10 SENATOR LANCE BELL: I'll make a motion
11 that we --
12 (Whereupon, committee speaks amongst
13 themselves).
14 SENATOR CHAMBLISS: I think there's a
15 question. Just for clarity the amendment corrects an
16 error. It referenced Act 2024 dash whatever. It
17 corrects it to 2023 dash.
18 SENATOR TOM BUTLER: That's an amendment to
19 Senate Bill 39 by Senator Roberts.
20 SECRETARY: I got Roberts and Bell.
21 SENATOR COLEMAN-MADISON: I am second.
22 Coleman-Madison amendment adoption.
PLANET DEPOS
1 SENATOR TOM BUTLER: All in favor say aye?

2 ALL: Aye.
3 SENATOR TOM BUTLER: All opposed say, nay.
4 Okay. Call the roll on the Senate Bill.
5 SECRETARY: 39 had ended.
6 SENATOR TOM BUTLER: Yeah.
7 SENATOR: Okay. Senator Butler?
8 SENATOR TOM BUTLER: Aye.
9 SENATOR: Senator Elliott?
11 SECRETARY: Senator Orr?
12 SENATOR ARTHUR ORR: No.
13 SECRETARY: No? Did you say anything? Oh,
14 he didn’t say anything. Okay.
15 SECRETARY: Senator Allen?
16 SENATOR GERALD ALLEN: Aye.
17 SECRETARY: Senator Albritton?
18 SENATOR GREG ALBRITTON: Aye.
19 SECRETARY: Senator Roberts?
21 SECRETARY: Senator Bell?
22 SENATOR LANCE BELL: Aye.
PLANET DEPOS
1 SECRETARY CALDWELL: Senator Kelley?

3 SECRETARY: Senator Coleman-Madison?
4 SENATOR COLEMAN-MADISON: Aye.
6 SENATOR MERIKA COLEMAN: Aye.
7 SECRETARY CALDWELL: Senator Stewart?
8 SENATOR ROBERT STEWART: Aye.
9 SECRETARY: Nine yeses. Nine passing.
10 SENATOR ROBERT STEWART: You didn’t vote
11 for me but it's an aye.
12 SECRETARY: Robert Stewart. I got it.
13 SENATOR TOM BUTLER: Nine ayes, bill in
14 favor of report.
15 SENATOR CHAMBLISS: Thank you, Mr. Chairman
16 and committee.
17 SENATOR TOM BUTLER: You ready on your
18 bill? Okay, Senator Allen's bill, Senate bill four.
19 SENATOR GERALD ALLEN: Thank you, Mr.
20 Chairman and committee. Many of you may remember a
21 2001 we were in a special session down here when --
22 when a tragedy happened when the Twin Towers was hit
PLANET DEPOS
1 and -- and this this bill here. This is a genesis of

2 it. This bill will provide that up to 9/11
3 remembrance freedom flag may be displayed on any
4 public owned property or premise and this bill would
5 also provide that person who displays and unapproved
6 flag on public owned properties and emits a
7 misdemeanor. And so that's -- that's in essence of
8 the violation of subsection A and is a Class C
9 misdemeanor.
10 So Mr. Chairman, we do have an amendment.
11 Like to go ahead and offer the amendment and that
12 amendment bills for -- with right here. Replace line
13 58 through 68 on page three with the following.
14 Four, the official flag of any county or
15 municipality in this state. Five, the National League
16 of POW/MIA family flag. And then number six is the
17 freedom flag. Mr. Chairman, that's the that's the
18 amendment and and I do accept that friendly
19 amendments.
21 SENATOR MERIKA COLEMAN: Mr. Chairman.
22 SENATOR TOM BUTLER: Senator Coleman?
PLANET DEPOS
1 SENATOR MERIKA COLEMAN: Is that all

2 because someone said it included any other flag
3 standard and signal approved? But there's you
4 speaking of private property is that this that on
5 there?
6 SENATOR GERALD ALLEN: Public. Public
7 property.
8 SENATOR MERIKA COLEMAN: And control any
9 other flag standard colors on insignia and proved by
10 the entity and control of the property? Why don't we
11 add that because this is vague. Can we delete that
12 part?
13 SENATOR GERALD ALLEN: What line are you
14 on?
15 SENATOR MERIKA COLEMAN: I am on line 67,
16 number 11. And just leave it at the other flags that
17 you had put on here? Because again you talking about
18 public property and but you're not specific on number
19 11, which leaves it open to who -- whatever.
20 SENATOR GERALD ALLEN: Okay.
21 SENATOR MERIKA COLEMAN: Or we could delete
22 that. I'm in agreement with your amendment.
PLANET DEPOS
1 SENATOR GERALD ALLEN: That is -- I guess

2 that's included in the --
3 SENATOR MERIKA COLEMAN: I'm just -- I'm
4 asking can we take that part off because it's not --
5 SENATOR GERALD ALLEN: Yes. Line 58 through
6 68.
7 SENATOR MERIKA COLEMAN: No. I agree with
8 the ones that you have articulated, but on -- on your
9 bill here in line 67 and 68, I'm saying take that off
10 because it says any other flag standard colored is
11 the signature, but it's just, it's vague.
12 SENATOR GERALD ALLEN: The amendment says
13 replace line 58 through 68. Okay?
14 SENATOR MERIKA COLEMAN: And just go with
15 the ones that you named?
16 SENATOR GERALD ALLEN: In this amendment.
17 Yes.
18 SENATOR MERIKA COLEMAN: Okay. Thank you.
19 SENATOR TOM BUTLER: Mr. Chairman? Senator
20 (Inaudible).
21 SENATOR GERALD ALLEN: Thank you.
22 SENATOR TOM BUTLER: All in favor of the
PLANET DEPOS
1 amendment, say aye.

2 ALL: Aye.
3 SENATOR TOM BUTLER: All opposed nay? The
4 amendment is adopted, Senator Allen.
5 SENATOR GERALD ALLEN: Okay. So, I --
6 SENATOR COLEMAN-MADISON: One question,
7 sir. Just one question. Quick question. I -- I tried
8 to look up 'cause I don't know what the freedom flag
9 was, but I looked it up and this is the one that I
10 saw. Is this it?
11 SENATOR GERALD ALLEN: That's it. That's
12 the flag.
13 SENATOR COLEMAN-MADISON: Okay.
14 SENATOR GERALD ALLEN: You got a whole
15 package. You should have been given a package and
16 that tells you all the details with the flag, program
17 and so that's it. Yes, sir -- ma'am.
18 SENATOR KEITH KELLEY: Mr. Chairman?
19 SENATOR TOM BUTLER: Senator Kelley?
20 SENATOR KEITH KELLEY: Thank you, sir. I
21 was made aware of something this morning that for
22 example, you got some public entities that under some
PLANET DEPOS
1 programs that would doubt go back probably 20 to 30

2 years for small towns to provide economic development
3 and have some shopping centers and things of that
4 nature. The way that I read this, is those individual
5 businesses could not because that is publicly owned
6 property. They could not display their own -- their
7 own business flags and whatever they need for their
8 business, for example, if it's a chain of grocery
9 stores, they couldn't -- couldn't display their own
10 company flag. That's my saw --
11 SENATOR GERALD ALLEN: I think that's
12 covered in -- yes, I think you're fine on that but
13 Senator Bell asked a question about the county or the
14 city owning a piece of property, shopping facility.
15 Right? Senator Bell.
16 SENATOR LANCE BELL: I think that's what
17 he's asking.
18 SENATOR GERALD ALLEN: Okay. All right. If
19 it's owned by the county then the bill says if you go
20 to the front page on line 7, it says line seven, any
21 public own property or prentice that they own.
22 Premise. Yes, sir.
PLANET DEPOS
1 SENATOR KEITH KELLEY: Okay. The individual

2 business is still don't own the property though, sir.
3 SENATOR COLEMAN-MADISON: That's correct.
4 SENATOR KEITH KELLEY: The tenants in those
5 buildings, for example, if it's a grocery store, the
6 grocery store still doesn't own the property so they
7 can't put up their own flags for their business.
8 Because the property itself is owned by the town or
9 the city in this particular scene.
10 SENATOR GERALD ALLEN: Yes, sir. I
11 understand your question.
12 SENATOR KEITH KELLEY: Yes, sir.
13 SENATOR GERALD ALLEN: I think that we need
14 to discuss this and maybe have them on the floor. Fix
15 it if that's -- if that's the case. I'm not certain
16 but let's take a look at this.
17 SENATOR KEITH KELLEY: Okay.
18 SENATOR GERALD ALLEN: Okay. I will work
19 with you on this.
20 SENATOR COLEMAN-MADISON: One question.
21 Senator Allen, one question. On page two, line 52,
22 the official flag of any nation or state that
PLANET DEPOS
1 preceded the United States or the State of Alabama in

2 controlling any territory currently constituting the
3 state of Alabama, you know, there were several flags
4 are flown over of Alabama. So, I guess, I mean are we
5 going to put Confederate flags all over the place or
6 Spanish flag? Who else had to control over their
7 territories? British and the French?
8 SENATOR GERALD ALLEN: Yeah.
9 SENATOR COLEMAN-MADISON: So are we going
10 to have them flying too?
11 SENATOR GERALD ALLEN: I don't think -- I
12 don't --
13 SENATOR COLEMAN-MADISON: Like why is this
14 necessary? You know, Senator Allen, we had this
15 conversation last night. You come up with these bills
16 and I just don't know why. I don't know you may
17 become see him at night. But your -- your smokers are
18 like it about the freedom flag. Honoring 9/11 but
19 then you throw all this other stuff into it. Why? Why
20 is this necessary? I mean, we don't want everybody's
21 flag flying here. I mean you keep saying you
22 (inaudible).
PLANET DEPOS
1 SENATOR GERALD ALLEN: Absolutely.

2 SENATOR COLEMAN-MADISON: But now this
3 looks like this opened up a can of worms that we just
4 need to take this out and have just look at a clean
5 bill to do what you want to do unless you thinking
6 about something else. What about that?
7 SENATOR GERALD ALLEN: No. I -- I think
8 we've got thing with -- I think we're okay here. I
9 really do.
10 SENATOR COLEMAN-MADISON: I don’t -- I
11 don’t think -- I don’t think we are. I think -- I
12 think this is -- line -- ohm here. I don't think this
13 -- this -- this done because like I said based on the
14 way this is written and looking at all the flags that
15 are flown over Alabama, I just -- I think this is
16 opening it up for something else.
17 SENATOR TOM BUTLER: Senator Kelley?
18 SENATOR KEITH KELLEY: Yes, sir. Would you
19 consider carrying this over and list -- get this
20 issue cleaned up because I've got two municipalities
21 that are concerned about this and -- and it sounds
22 like there may be some other concerns and then we can
PLANET DEPOS
1 get it cleaned up and get it what you want done.

2 SENATOR GERALD ALLEN: I would -- I ask Mr.
3 Chairman since we got some folks here already for the
4 public hearing or we can do it again next week.
5 Whatever you -- it's your call.
6 SENATOR TOM BUTLER: Well, I'm open for a
7 motion?
8 SENATOR MERIKA COLEMAN: He made and I
9 second it.
10 SENATOR TOM BUTLER: Senator Kelley, you
11 move to carry over? Senator Kelley, you move to carry
12 over to the second?
13 SENATOR MERIKA COLEMAN: Second.
14 SENATOR TOM BUTLER: Second. Senator
15 Coleman. All in favor say aye.
16 ALL: Aye.
17 SENATOR TOM BUTLER: All opposed nay.
19 SENATOR TOM BUTLER: Carry the bill over.
20 SENATOR MERIKA COLEMAN: Mr. Chairman?
21 SENATOR TOM BUTLER: Senate Bill 5.
22 SENATOR CHRIS ELLIOTT: Mr. Chairman in the
PLANET DEPOS
1 interest of time, we're scheduled going to floor on -

2 - at 3:00. I would move we carry this bill over.
3 SENATOR TOM BUTLER: Motion to carry the
4 bill over? Okay. All in favor say aye?
5 ALL: Aye.
7 SENATOR GERALD ALLEN: Thank you, Mr.
8 Chairman.
10 just want to say to the gentleman too as you're
11 preparing for next week. And I was just looking at
12 the list of flags. What about you know, doing breast
13 cancer awareness month and different things like that
14 that we honor when somebody wants to fly a flag. I
15 know my sorority or fraternity sometimes will fly
16 something. So just kind of thinking about those
17 things as well. And I really agree with the gentleman
18 /gentlewoman maybe if we could -- because it's two
19 different -- just two different things going on in
20 this bill.
21 One portion of it is opening up and
22 allowing a flag and the rest of the bill is being
PLANET DEPOS
1 punitive so nobody else can fly flags. So just FYI as

2 we're moving forward on that bill.
3 SENATOR TOM BUTLER: And we've carried
4 over. Our committee's adjourned.
5 (The recording was concluded.)
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PLANET DEPOS
1 CERTIFICATE OF TRANSCRIBER
2 I, LAUREN BISHOP, do hereby certify
3 that this transcript was prepared from the digital
4 recording of the foregoing proceedings; that the
5 recording of said proceedings was obtained from
6 https://alabamachannel.ompnetwork.org/embed/sessions/
7 285921/alabama-house-constitution-campaigns-and-
8 elections-committee; that said
9 proceedings were reduced to typewriting under
10 my supervision; that said transcript is a true and
11 accurate record of the proceedings to the best of
12 my knowledge, skills, and ability; and that I am
13 neither counsel for, related to, nor employed by any
14 of the parties to the case and have no interest,
15 financial or otherwise, in its outcome.
16
17 _____________________________
18 LAUREN BISHOP, TRANSCRIPTIONIST
19 PLANET DEPOS, LLC
20 APRIL 26, 2024
21
22
PLANET DEPOS
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PLANET DEPOS
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PLANET DEPOS
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3:6, 5:9, 11:5,
PLANET DEPOS
15:9, 18:8, 12:9, 13:16, bizzelle's butler

18:21, 24:8, 14:4, 14:16, 32:21 2:1, 2:4, 2:5,
29:14, 44:1, 16:10, 16:13, black 3:5, 3:22, 4:6,
61:22 17:2, 17:9, 15:20, 16:4, 4:9, 4:17, 5:3,
beliefs 17:16, 17:18, 16:5, 16:11, 6:20, 9:17,
26:2 17:21, 18:13, 38:11, 38:13, 9:21, 11:9,
believe 23:6, 23:10, 39:2 13:5, 13:7,
5:15, 23:15, 24:8, 29:15, blank 15:15, 15:17,
39:13, 44:4 29:16, 29:18, 7:22 17:11, 18:22,
bell 29:21, 29:22, blind 21:12, 21:15,
2:16, 2:17, 30:4, 30:6, 6:10, 10:18, 22:20, 23:19,
4:5, 47:9, 31:3, 31:13, 17:15, 27:16, 28:6, 29:7,
47:10, 49:10, 32:14, 32:17, 28:2 31:5, 31:8,
49:20, 50:21, 34:9, 40:5, board 38:7, 39:11,
50:22, 56:13, 40:19, 42:5, 35:12, 35:17 40:16, 40:19,
56:15, 56:16 42:9, 42:10, boat 41:1, 42:1,
belt 42:13, 43:16, 20:14 42:2, 42:12,
38:11, 38:13 43:21, 43:22, body 42:20, 43:4,
benson 44:1, 44:8, 33:9, 38:19 43:11, 44:3,
13:8, 13:10, 44:18, 44:20, both 44:10, 44:13,
13:11, 15:16 44:22, 45:22, 16:22, 25:19, 44:17, 45:10,
best 46:10, 46:11, 25:22, 28:13, 46:16, 46:19,
5:9, 5:12, 48:2, 48:3, 33:4 47:19, 47:20,
63:11 48:6, 48:7, bottom 48:1, 48:13,
better 49:19, 50:4, 30:10 48:16, 48:20,
23:13, 28:4 51:13, 51:18, breast 49:18, 50:1,
betty 52:1, 52:2, 61:12 50:3, 50:6,
21:15, 21:17, 52:4, 54:9, brian 50:7, 50:8,
21:18 56:19, 59:5, 51:13, 51:17,
60:19, 60:21, 28:6, 28:8
between bridge 52:20, 52:22,
14:10 61:2, 61:4, 54:19, 54:22,
61:20, 61:22, 12:10 55:3, 55:19,
beyond brief
23:17 62:2 59:17, 60:6,
billing 35:4 60:10, 60:14,
biased british
10:11 43:7 60:17, 60:19,
bills 58:7 60:21, 61:3,
bill brought 61:6, 62:3
3:7, 3:12, 42:3, 43:4,
52:12, 58:15 3:16, 45:15, C
3:16, 3:17, 48:9
3:18, 4:13, birmingham caldwell
11:12, 25:19, buildings
4:19, 5:4, 5:7, 57:5 47:11, 47:17,
5:8, 5:12, 5:15, 39:2, 46:6 51:1, 51:7
bishop business
5:20, 5:21, 3:6, 25:7, call
5:22, 6:1, 6:3, 1:22, 63:2, 2:2, 8:11,
63:18 56:7, 56:8,
6:15, 6:18, 57:2, 57:7 36:5, 37:19,
6:22, 7:17, 8:3, bit 40:20, 41:3,
4:15 businesses
8:16, 9:1, 9:9, 56:5 45:5, 46:19,
9:19, 10:13, bizzelle 46:20, 48:2,
32:18, 33:20 businessman
10:17, 12:1, 23:3
PLANET DEPOS
50:4, 60:5 cathy 61:9 50:10, 60:22

called 23:19, 23:21, challenge church
10:6, 23:3, 23:22 12:22, 32:13 25:1
30:2 caught challenged circumstances
calling 33:17 28:14 12:5
34:8, 36:6 cause chambliss citizen
came 55:8 48:4, 48:17, 12:4, 18:19,
19:22, 23:13, cautiousness 48:18, 48:21, 26:7, 26:11
32:9 15:13 49:6, 49:14, citizens
campaigns center 51:15 12:11, 22:6,
5:18 14:19 chance 22:18, 24:3,
campus centers 9:15, 29:2, 46:2
20:12 56:3 43:17 citizenship
campuses century change 12:15
14:4 22:3 42:19, 49:7 city
can't certain changed 29:10, 46:6,
6:12, 29:21, 8:12, 36:5, 7:1, 21:22, 56:14, 57:9
37:7, 42:22, 57:15 40:7 civic
43:1, 43:3, certificate changes 11:14, 12:7,
46:17, 57:7 63:1 4:20, 5:10, 12:14, 13:14,
cancer certify 6:11, 7:1, 9:9, 14:4, 14:13,
61:13 63:2 9:14, 29:18 19:9, 24:21
cannot chain changing civil
6:4, 9:7, 36:5, 56:8 6:14, 7:13 17:5
13:17, 25:6, chair chapter clap
27:19 4:11, 21:19, 19:5 38:22, 39:1
caregivers 31:11, 42:7, charge clarity
25:1 43:2, 44:16 13:18 49:15
cares chairman charged class
29:12 3:9, 3:19, 4:2, 14:1, 14:22, 8:16, 8:22,
carried 4:8, 5:2, 6:17, 15:4, 16:16, 9:2, 16:17,
62:3 7:4, 9:11, 9:20, 16:22 19:21, 25:14,
carry 31:4, 31:10, check 27:16, 52:8
60:11, 60:19, 35:2, 38:5, 35:13, 35:18 clean
61:2, 61:3 38:9, 39:13, checking 59:4
carrying 40:13, 40:21, 24:19 cleaned
59:19 42:4, 42:8, checks 59:20, 60:1
case 42:17, 43:7, 24:16 clear
57:15, 63:14 43:8, 43:13, choice 6:7, 6:15,
cases 44:7, 44:14, 24:9 18:2, 26:7
32:8 44:21, 45:8, choose clearly
cast 48:2, 48:4, 24:8 18:1
18:16, 30:18 48:13, 51:15, choosing clergy
casting 51:20, 52:10, 35:8 25:20
18:15, 22:13, 52:17, 52:21, chris clerk's
24:9 54:19, 55:18, 2:6, 2:7, 41:8, 36:14
categories 60:3, 60:20, 42:4, 44:7, close
26:20 60:22, 61:8, 44:11, 46:22, 10:22
PLANET DEPOS
code 14:17, 15:2 completing contract

6:12 colored 8:19, 20:7 21:1
coin 54:10 completion contribution
9:1 colors 28:21 12:16
coleman 53:9 compliant control
2:20, 2:22, come 46:6 11:2, 44:15,
3:1, 4:8, 4:10, 11:19, 19:10, concerned 53:8, 53:10,
23:2, 31:9, 23:9, 31:2, 24:14, 38:10, 58:6
34:3, 34:5, 58:15 59:21 controlling
34:12, 34:16, comes concerns 58:2
38:12, 41:19, 28:17, 28:20 59:22 conversation
41:20, 42:7, coming concluded 44:19, 58:15
42:16, 43:1, 23:16, 36:6, 62:5 convicted
43:8, 43:13, 38:4 conduct 37:18
44:5, 44:14, comment 3:6 convictions
45:7, 47:15, 45:12 confederate 10:5
47:16, 51:5, comments 16:6, 58:5 copies
51:6, 52:21, 9:17 confidence 24:18, 28:18,
52:22, 53:1, commit 11:4 28:19
53:8, 53:15, 6:5 confusing copy
53:21, 54:3, committed 19:21, 25:4, 19:17, 28:15
54:7, 54:14, 33:5, 33:20 28:22, 36:13 corporate
54:18, 60:8, committee congregations 15:11
60:13, 60:15, 1:9, 3:11, 5:1, 25:19, 25:22 correct
60:20, 61:9 7:4, 17:8, connecting 24:17, 57:3
coleman-madison 28:10, 31:21, 12:10 correctly
2:21, 35:3, 32:7, 32:16, connection 27:8
40:21, 41:17, 40:14, 44:15, 12:18 corrects
41:18, 42:14, 44:16, 45:2, consequence 49:15, 49:17
42:18, 43:6, 45:6, 48:6, 38:22 cost
45:8, 45:11, 49:12, 51:16, consequences 11:3
47:13, 47:14, 51:20 could
49:5, 49:21, 34:22, 37:14
committee's consider 7:15, 7:16,
49:22, 51:3, 62:4
51:4, 55:6, 29:1, 59:19 11:3, 14:1,
committing consideration 14:2, 15:4,
55:13, 57:3, 27:10
57:20, 58:9, 17:10, 45:2, 27:5, 27:14,
communities 45:3 53:21, 56:5,
58:13, 59:2, 11:19, 38:14
59:10 considered 56:6, 61:18
community 28:3 couldn't
colleague 13:16, 21:2,
35:5 constituents 56:9
29:1 27:11, 46:4 councilmember
collect company
9:4 constitute 29:11
56:10 13:21 counsel
collecting complete
8:18, 10:15 constituting 63:13
9:5, 21:7, 33:1 58:2 count
college completed
13:14, 14:5, constitutional 24:20, 36:15
8:4 15:13 counted
14:10, 14:13, completely continue 11:5, 36:17
20:4 20:18, 21:8
PLANET DEPOS
counties 17:18, 17:21, deliver director

19:11, 30:14, 48:21, 58:2 9:5 10:2
30:16, 37:6 D delivering disabilities
country dam 8:19 6:9, 7:12,
27:13 48:2 delta 16:12, 24:6,
county dams 14:18 26:19, 26:21,
8:9, 24:18, 49:2 democracy 46:7
26:16, 28:9, dan 12:5, 26:2 disability
30:21, 52:14, 2:14, 2:15, democratic 27:12
56:13, 56:19 41:12, 47:8, 5:21, 6:3, disabled
course 50:20 12:11, 22:6, 10:18, 15:1,
17:20, 18:11 dash 25:22, 29:13, 18:7, 18:15,
covered 49:16, 49:17 39:14 22:14, 24:6,
29:20, 56:12 data democrats 27:13, 28:13
creative 8:12, 8:13, 31:18 discourage
19:8 30:13, 30:20 denied 37:2
cries daunting 21:21 discuss
22:7 19:22 denying 57:14
crime day 46:9 disenfranchised
14:22, 25:11, 19:11, 19:13, depos 12:10
33:5, 33:20 37:8, 43:15 63:19 dismal
crimes dcnr deserve 38:18
37:19 48:9, 48:10, 28:4 dismantle
criminal 48:11 desires 14:9, 15:12
37:18 deadlines 7:9, 39:21, dismantles
criminalize 20:3, 21:10 46:12 12:3
25:9 deaf details disorders
criminalized 6:10, 28:2 55:16 27:1
17:20, 18:9, deal determined display
18:21 23:10 16:3 56:6, 56:9
criminalizes decade determining displayed
16:17 10:4 20:11 52:3
criminals deceitful deterrent displays
14:9 22:5 8:21 52:5
critical decide development distances
12:17, 20:19 9:14 56:2 37:7, 39:7
cross-section decline didn’t distribute
31:20 14:6, 15:11 50:14, 51:10 7:18, 9:4,
crow defending different 33:22, 40:11
16:4 26:1 61:13, 61:19 distributing
crowd defined difficult 8:18, 10:15
39:16 18:13 19:13 district
culture definitely digest 8:1
43:14 31:13 43:16, 44:2, documentation
current definitions 46:4 22:3
7:7, 7:9, 18:2 digital doesn’t
13:12, 24:12 delete 63:3 33:7
currently 53:11, 53:21 diligence doing
8:22, 11:21, 30:5 33:11, 35:22,
PLANET DEPOS
61:12 26:17, 26:21, embed 16:19, 38:17

dollars 37:10 63:6 essence
33:3 effect emits 52:7
done 38:2 52:6 even
29:4, 30:5, effective emphasizing 3:15, 4:12,
34:20, 59:13, 19:8 12:15 10:12, 24:18,
60:1 effectively employed 27:3, 29:14,
don’t 22:17 63:13 32:14, 32:17,
59:10, 59:11 efforts employee 35:11, 42:8,
dothan 20:10 11:11 44:2
23:1 either empowering ever
double 8:10, 10:10 12:13 36:1, 36:13,
24:18 elderly empowers 38:17
doubt 15:1, 28:13 19:7 every
56:1 election end 6:1, 12:4,
down 6:4, 8:5, 8:9, 7:14, 11:5, 18:7, 20:5,
5:16, 9:12, 19:11, 19:13, 32:9, 33:11, 20:17, 26:6,
32:5, 34:11, 20:17, 37:8, 38:3 26:22, 29:9,
51:21 37:15 ended 30:17, 30:21
drafted elections 50:5 everybody
48:10 5:19, 6:1, engaged 13:8, 30:7,
drive 10:8, 11:7, 38:16 35:19, 36:4,
27:2, 27:17, 25:6, 30:12 engagement 38:4, 39:17
39:8 elections-commit- 11:15, 19:9 everybody's
due tee enhance 58:20
27:12, 30:5 63:8 11:6 everyday
E electoral ensure 25:9
each 12:2 12:4, 20:5, everyone
26:11, 39:22 eligible 26:4, 26:6 7:2, 17:17,
eagle 12:4 entities 29:2, 30:1
10:2, 10:7, eliminates 55:22 everyone's
31:19 11:2 entity 5:11, 6:15
earlier elliot 53:10 everything
30:12 46:21 envelope 7:22, 9:8,
easily elliott 21:4, 28:22, 29:17, 29:19,
2:6, 2:7, 41:7, 36:17 36:3
6:5 everywhere
easy 41:8, 42:4, envelopes
44:7, 44:11, 36:13 19:5, 19:22
26:7 evidence-based
economic 46:22, 47:22, equivalent
50:9, 50:10, 25:15 30:13
56:2 exactly
economically 60:22 erect
else 12:9 7:4, 30:14
28:14 example
educate 9:8, 13:18, error
58:6, 59:6, 49:7, 49:16 14:16, 16:18,
20:8 55:22, 56:8,
educating 59:16, 62:1 error-prone
email 25:5 57:5
12:6 excuse
education 21:9 especially
emas 6:10, 7:12, 33:22
11:14, 14:13,
49:3
PLANET DEPOS
executive family 35:10 fly

10:2, 27:1 45:17, 52:16 filled 36:21, 61:14,
exemplify father 27:8 61:15, 62:1
18:13 7:14 filling flying
exercise fault 7:8, 35:11, 58:10, 58:21
16:6, 29:2 29:20 35:15, 36:2, focusing
exercising favor 39:21 12:11
16:12 43:5, 44:8, fills folk
exist 50:1, 51:14, 27:7 22:17
22:2 54:22, 60:15, final folks
existence 61:4 44:19 26:5, 31:20,
16:5, 22:9 favorable finally 60:3
explaining 42:3 15:9 follow-up
25:4 fear financial 48:6
express 22:11 63:15 following
17:15, 38:10 february find 52:13
expresses 1:12 37:1, 37:18 force
17:6 federal fine 31:17
extracurriculars 6:12, 35:7 56:12 forces
19:20 federally first 17:4
extremely 24:10, 32:2 3:6, 5:1, 5:4, foregoing
25:8 federation 7:6, 29:8, 63:4
eyesight 17:14 36:16, 44:12 form
7:14 feel five 17:7, 22:10,
F 15:3, 15:5, 6:22, 7:1, 27:7, 35:22
face 30:6, 31:1 30:17, 52:15 former
13:1, 38:13 feeling fix 31:16
facilitate 45:22 33:7, 57:14 formerly
13:22, 14:3 felony flag 11:21
facility 8:16, 8:22, 52:3, 52:6, forth
56:14 9:2, 9:8, 13:21, 52:14, 52:16, 31:3
fact 14:1, 15:4, 52:17, 53:2, forum
16:22, 25:14, 53:9, 54:10, 10:2, 10:7,
16:11, 22:3 55:8, 55:12,
facts 27:10, 38:19, 31:19
39:10 55:16, 56:10, forward
30:13 female 57:22, 58:6,
faculty 3:16, 62:2
4:4, 25:18, 58:18, 58:21, found
14:3, 15:8 46:17 61:14, 61:22
fair 6:2
few flags foundation
10:8, 30:6 30:16 53:16, 56:7,
faith 19:4, 19:6
fight 57:7, 58:3, four
25:21 23:16 58:5, 59:14,
faith-based 4:5, 4:6, 4:13,
figure 61:12, 62:1 45:15, 48:1,
11:12 40:6, 40:10 floor
fall 49:2, 51:18,
fill 45:4, 57:14, 52:14
26:20, 32:1 8:7, 14:20, 61:1
families fraternity
19:16, 19:19, flown 61:15
16:9 25:5, 25:6, 58:4, 59:15 fraud
6:5, 10:6,
PLANET DEPOS
22:10, 31:17, 33:4 glt 16:2, 32:9,

32:10, 33:15 gave 39:1 48:8, 49:1
freak 33:19 gltb governments
27:18 gbm 38:15 49:1
free 11:12, 12:6, go governor
10:8, 29:1 12:12 2:1, 3:19, 5:1, 14:15
freedom genesis 6:7, 6:18, 11:1, grady
52:3, 52:17, 52:1 23:7, 32:21, 19:1, 19:2,
55:8, 58:18 gentleman 35:11, 35:22, 19:3, 21:12,
french 31:11, 61:10, 36:15, 37:8, 21:14
58:7 61:17 37:19, 43:12, grandmother
friend gentlewoman 45:4, 46:20, 32:20
25:10, 34:14 61:18 52:11, 54:14, grave
friendly gerald 56:1, 56:19 38:10
52:18 2:10, 2:11, goal great
friends 40:18, 47:4, 20:5, 29:16, 32:18, 32:21,
25:9 50:16, 51:19, 32:3 38:1
front 53:6, 53:13, god great-aunt
3:14, 4:14, 53:20, 54:1, 22:4 32:19
5:5, 56:20 54:5, 54:12, goes greater
fueled 54:16, 54:21, 35:17 11:11, 39:2
16:5 55:5, 55:11, going greatest
full-time 55:14, 56:11, 3:17, 9:10, 18:3
11:11 56:18, 57:10, 18:1, 32:2, greetings
functioning 57:13, 57:18, 35:11, 35:12, 13:10
27:1 58:8, 58:11, 35:13, 36:17, greg
fundamental 59:1, 59:7, 36:18, 36:19, 2:12, 2:13,
46:8 60:2, 61:7 38:2, 40:5, 47:6, 50:18
fundamentally gerritson 40:16, 42:9, grocery
25:4 9:21, 9:22, 42:12, 42:19, 56:8, 57:5,
funding 10:2, 13:6 43:17, 43:20, 57:6
15:11 getting 45:19, 46:14, ground
funds 43:11 58:5, 58:9, 36:19
16:18 gift 61:1, 61:19 group
fyi 8:17, 9:3 gone 15:21
62:1 give 36:14 grouping
G 4:15, 4:19, good 8:11
6:18, 7:21, 9:22, 11:10, groups
gamma 18:5, 33:3, 17:12, 19:2,
14:18 5:6, 5:7, 5:8,
43:5, 43:21, 21:17, 22:22, 6:8, 10:14, 36:5
gap 44:8 23:2, 23:17,
25:5 grudger
given 23:21, 25:18, 44:13
garrett 27:9, 42:3, 26:14
22:21, 22:22, gudger
55:15 goodman 3:8, 3:9, 3:22,
23:1 gives 19:3, 19:6
gas 4:19, 4:21, 5:4,
15:2 government 6:21, 9:20,
15:2, 16:20, giving 1:9, 6:13,
18:6, 25:12, 29:8, 31:7,
24:17, 24:18 13:14, 14:18, 33:21, 34:4,
PLANET DEPOS
34:7, 34:15, harvesting 2:11, 2:13, honoring

35:5, 39:12, 6:6, 8:11, 2:15, 2:17, 58:18
44:18, 45:1, 10:6, 10:7, 2:19, 2:21, 3:1, hospitalities
45:13, 46:12, 11:2, 22:2, 3:3, 3:10, 6:22, 18:10
46:16 34:10, 34:19, 17:15, 21:18, hospitality
gudger's 35:6, 36:7, 24:12, 24:13, 18:12
4:7 36:20 26:16, 29:10, hours
guess hate 29:14, 29:15, 25:7
4:11, 31:10, 33:16 32:16, 38:1, house
54:1, 58:4 hazards 40:8, 51:21, 32:15
guides 11:3 52:1, 52:12, however
20:16 head 53:17, 54:9, 12:21, 45:4
guilty 39:13 58:21, 59:8, https
25:11 hear 59:12, 60:3 63:6
H 34:13, 42:22, hereby huge
half 43:1, 43:3, 63:2 39:5
30:15 46:17 higher human
hall heard 14:13, 37:1 17:7
32:5 5:10, 20:6, highest huntsville
handles 29:17, 31:1, 17:7 23:22
30:22 40:5, 43:20, highlights hurdle
handling 44:22, 45:3 6:18 39:5
13:4 hearing hit hurdles
happen 1:9, 1:11, 51:22 38:13
9:11, 9:13, hold hurts
36:2
happened 9:16, 60:4 13:12, 16:11, 23:11
heavy 43:11, 44:17, I
29:19, 51:22 45:10, 48:16
happening 17:4
help holds id
6:5, 8:10, 16:4, 16:5 19:17, 28:15,
30:13, 30:14, 8:6, 13:15,
14:19, 19:22, home 28:20
30:22 ids
happens 20:5, 20:16, 19:12, 19:19,
20:20, 22:13, 32:21, 37:7 24:18
29:13 homeless ieps
happy 22:18, 24:22,
25:10, 27:6, 11:20 26:18
48:12 27:20, 32:21, hometown illegal
hard 32:22, 36:7, 38:12 30:11
3:11 46:5 hometowns illiterate
harmed helped 20:19 28:2
24:7 36:2 honest impact
harmful helping 14:5
5:16
25:8 15:10, 24:4, honing impacted
harms 35:10, 35:15, 34:18 11:22
28:5 36:9, 39:4 honor impede
harsh helps 26:10, 61:14 22:12
25:15 5:15, 20:14, honorable importance
harvesters 24:15 15:5 26:10
10:9 here honored important
2:5, 2:7, 2:9, 24:2, 24:4 10:17
PLANET DEPOS
impoverished initially jim kept

39:4 44:18 16:4 32:12
in-state initiate job kerr
20:11 19:8 1:20, 13:22, 26:14, 26:15
incarcerated insignia 37:8 key
11:21, 12:12 53:9 john 30:6
incarceration inspect 31:16 kind
12:16 49:1, 49:2 jone's 4:13, 37:17,
include insufficient 37:20 61:16
20:10, 21:3, 13:3 jones kinds
40:2 integrity 23:19, 23:21, 37:18
included 12:2 23:22, 37:21 knocks
53:2, 54:2 intent judiciary 5:16
including 34:2, 34:9 32:16 know
6:10, 11:20, intentional juggling 3:19, 10:12,
27:15 38:22 19:20 17:17, 18:4,
increase interest justice 31:10, 32:3,
17:3 38:2, 61:1, 13:14 32:4, 32:12,
incredibly 63:14 justified 34:4, 34:17,
19:12 internet 15:3 34:20, 35:18,
indecency 28:14 K 36:6, 36:13,
17:7 invalid kay 38:11, 43:9,
independent 28:3 14:15 43:14, 55:8,
5:22 involves keep 58:3, 58:14,
individual 12:13 58:16, 61:12,
10:22, 58:21 61:15
8:4, 18:4, iraq keeping
18:8, 18:17, 16:1 knowing
7:10 11:4, 15:5
18:18, 21:6, issue keeps
36:10, 56:4, 16:21, 59:20 knowingly
7:6 7:18, 8:17,
57:1 issues keith
individualized 30:22, 33:8, 9:3, 33:21,
2:18, 2:19, 33:22, 34:1,
26:17 48:8, 48:10 41:16, 47:12,
individuals itself 34:6
51:2, 55:18, knowledge
10:14, 11:19, 32:14, 33:1, 55:20, 57:1,
12:13, 12:22, 57:8 12:13, 63:12
57:4, 57:12, kylie
13:19, 16:11, ivey 57:17, 59:18
17:19, 18:7, 14:15 kelley 26:14, 26:15
26:21 J 2:18, 2:19, L
indulgence jackson 41:15, 41:16, lack
48:5 15:17, 15:18, 47:11, 47:12, 13:2, 39:5
inefficiencies 15:19 51:1, 51:2, ladies
13:3 jail 55:18, 55:19, 36:4
information 11:22 55:20, 57:1, lance
7:20, 49:3 jeopardizes 57:4, 57:12, 2:16, 2:17,
inhibit 10:8 57:17, 59:17, 4:5, 47:10,
26:8 jeopardy 59:18, 60:10, 49:10, 50:22,
inhibits 16:14 60:11 56:16
26:9
PLANET DEPOS
language 39:10 49:3 mail

7:6 legislative locations 13:4, 19:16,
large 33:9 17:5 19:19, 21:7,
26:1 lessons long 35:21, 36:10
large-scale 11:14 4:12, 4:13, mailed
32:10 let's 32:1, 37:5, 37:6 36:1
last 37:19, 39:7, longer mainly
3:13, 3:16, 57:16 27:17 39:22
5:6, 5:16, 9:9, level look maintaining
10:4, 23:7, 32:10 23:11, 24:13, 12:18
45:14, 48:7, liberties 38:17, 43:22, major
58:15 26:9 46:3, 55:8, 33:8
lauren life 57:16, 59:4 majority
1:22, 63:2, 7:15 looked 27:14
63:18 like-minded 55:9 make
law 15:21 looking 3:14, 3:20,
7:7, 7:9, 7:10, likelihood 25:14, 32:6, 6:15, 7:2, 17:1,
15:6, 16:13, 12:19 59:14, 61:11 20:6, 22:13,
17:2, 24:10, limestone looks 22:15, 23:17,
35:7, 37:21, 28:9 59:3 28:19, 29:5,
48:21 line lords 29:17, 30:8,
laws 30:10, 37:5, 28:6, 28:8, 36:8, 39:17,
6:4, 16:4 39:16, 52:12, 28:9 40:11, 45:12,
leaders 53:13, 53:15, losses 45:14, 48:13,
26:12 54:5, 54:9, 29:13 49:10
league 54:13, 56:20, lot makes
21:18, 24:1, 57:21, 59:12 7:11, 37:10, 7:17, 8:3,
24:5, 24:15, lines 39:14, 40:4, 8:16, 9:2,
52:15 49:4 40:8 10:22, 19:12
learning list louder making
20:9, 26:19 59:19, 61:12 22:7 5:10, 12:21,
least listening love 27:6
22:18 7:3 40:10 male
leave literally low 4:2, 41:4,
11:1, 53:16 4:15 11:18 41:6, 41:10,
leaves little low-income 41:14, 42:22
53:19 4:15, 36:4 11:19 man
left live ludicrous 23:2
19:14 23:22, 37:5, 22:11 manager
leg 37:6, 43:19 M 8:5, 8:9
5:17 lives ma'am manslaughter
legal 14:8, 16:14 4:9, 55:17 25:15
18:19 living made manuel
legally 35:21 47:21, 47:22, 17:11, 17:12,
27:16 llc 55:21, 60:8 17:13, 18:22
legislation 63:19 madison many
33:5, 33:12, local 2:20 14:8, 16:2,
34:21, 38:18, 14:11, 32:8, 16:11, 19:20,
PLANET DEPOS
20:17, 23:2, member minority much

24:19, 24:21, 21:2 27:14 13:7, 18:21,
27:10, 27:13, members minutes 40:14
28:11, 28:12, 13:21, 17:8, 13:9, 21:12 multiple
28:13, 33:9, 20:12, 24:5, misdemeanor 10:5
34:21, 37:8, 25:1 13:19, 16:17, municipalities
51:20 men's 52:7, 52:9 59:20
mark 34:7 misinformation municipality
40:1 mentioned 21:20, 32:13 52:15
mass 36:12 miss must
39:6 merika 15:15, 37:20 19:15
mater 2:22, 3:1, 4:8, misused mutual
15:6, 15:7 4:10, 31:9, 37:15 39:3
maters 34:3, 34:5, mobile N
14:15 34:12, 34:16, 21:19 name
matter 41:19, 41:20, modern-day 7:19, 8:1,
15:20, 39:3 42:7, 42:16, 16:11 11:10, 13:10,
maybe 43:1, 43:8, moment 15:19, 17:13,
18:5, 18:6, 43:13, 44:5, 5:1 19:3, 21:17,
32:7, 57:14, 44:14, 45:7, monetary 23:1, 23:22,
61:18 47:15, 47:16, 18:6 26:14, 28:8,
mcshannon 51:5, 51:6, money 40:2
21:16, 21:17, 52:21, 53:1, 13:20, 15:2, named
21:18 53:8, 53:15, 16:20, 25:12 54:15
meal 53:21, 54:3, month nation
18:6 54:7, 54:14, 61:13
54:18, 60:8, 57:22
mean months national
31:22, 32:4, 60:13, 60:20, 5:7
61:9 17:14, 19:7,
35:15, 35:20, more 32:10, 32:11,
58:4, 58:20, merrill 22:8, 31:3,
31:16, 31:21 33:16, 52:15
58:21 37:4, 38:16, nature
meaning met 38:17, 39:12
30:1, 30:3, 56:4
7:21, 13:21 morning navigate
means 30:5 55:21
mia 19:14, 20:20
30:17, 46:1, most nay
46:2 52:16 18:11, 27:20,
microphone 50:3, 55:3,
meant 29:2 60:17
34:9 7:3, 9:16 motion
mind nays
measures 3:20, 44:8, 42:3
12:21 31:22 47:21, 47:22,
mine necessary
mechanisms 48:14, 49:10, 58:14, 58:20
12:3 32:5 60:7, 61:3
minimized need
media move 4:1, 6:16,
32:11 18:14 4:2, 60:11,
ministries 7:11, 18:2,
meet 61:2 19:18, 20:16,
30:3, 30:4 11:12, 39:2 moves 22:13, 27:12,
meeting minorities 4:6 27:20, 28:11,
2:2, 31:2 21:21 moving
62:2
PLANET DEPOS
35:7, 37:3, 29:5 oh 55:7, 55:9,

37:11, 38:16, nu 50:13 57:20, 57:21,
38:20, 39:18, 14:18 ohm 61:21
45:20, 56:7, null 59:12 one-third
57:13, 59:4 12:8 okay 24:6
needed number 3:5, 6:19, ones
11:16 6:7, 7:10, 6:21, 13:5, 54:8, 54:15
needs 7:17, 8:3, 21:14, 39:1, online
18:18, 27:21, 52:16, 53:16, 40:16, 40:19, 20:14
27:22, 28:15 53:18 42:6, 46:19, only
negative numbers 48:2, 50:4, 10:21, 18:7,
14:5 37:1 50:7, 50:14, 29:20
neighbor nurses 51:18, 52:20, open
16:21 25:1 53:20, 54:13, 36:16, 53:19,
neither nurturing 54:18, 55:5, 60:6
63:13 12:7 55:13, 56:18, opened
never O 57:1, 57:17, 59:3
26:3, 27:2 obligation 57:18, 59:8, opening
news 61:4, 61:6 4:21, 6:17,
26:4 old
32:12 obliterates 9:15, 59:16,
next 36:4 61:21
12:10 older
4:18, 31:2, obstacles opinions
42:10, 60:4, 27:7 10:11
13:1 olivia
61:11 obtain opportunity
nice 32:18, 32:21, 3:10, 11:6,
9:5 33:20
10:1 obtained 15:19, 31:2,
night ompnetwork 38:9, 43:15,
63:5 63:6
58:15, 58:17 obtaining 43:21, 44:2,
nine once 45:18, 46:3,
8:19, 13:17 11:1, 17:15,
5:7, 51:9, occupational 46:11
51:13 18:20, 19:17 oppose
27:21 one
nobody of-state 5:7, 17:8
62:1 6:7, 7:10, opposed
20:12 8:10, 8:14,
non offer 10:7, 30:2,
16:20 18:3, 18:9, 50:3, 55:3,
19:11, 20:1, 23:20, 24:17, 60:17
non-partisan 20:13, 46:12,
20:14 24:21, 25:20, opposing
52:11 26:20, 27:5,
none offered 29:14
6:11, 22:9 29:2, 29:9, opposition
25:12 29:12, 30:10,
nonpartisan office 17:16
20:4, 22:18 30:17, 31:5, order
32:5, 35:12, 31:6, 32:11,
nonprofit 36:14, 37:20 2:2, 9:4, 43:12
10:14, 11:13 33:14, 34:11, ordering
official 34:22, 35:1,
normal 21:5, 52:14, 8:18
18:16 38:3, 39:12, org
57:22 39:16, 42:5,
normally officials 63:6
43:14 44:17, 44:20, organization
16:2, 25:6 45:12, 55:6,
nothing 11:13, 14:3,
23:17, 28:19,
PLANET DEPOS
14:17, 14:21, 34:20, 43:19, 27:3, 53:12, 19:7, 25:3,

14:22, 19:7 48:9, 48:10, 54:4 26:9, 27:5,
organizations 58:4, 58:5, participate 28:12, 36:2,
10:11, 13:15, 58:6, 59:15, 12:5, 18:3 37:2, 37:4,
14:14, 24:22, 59:19, 60:11, participation 37:5, 37:10,
38:15, 39:1, 60:12, 60:19, 12:7, 14:4 37:22, 38:13,
40:12 61:2, 61:4, 62:4 particular 38:16, 39:4,
original overcrowding 32:16, 34:17, 39:8, 39:18,
4:13, 29:18, 14:7, 38:21 57:9 40:12, 42:15,
31:13, 40:7 overseas parties 42:17, 43:19,
orr 6:11 63:14 44:20, 45:18,
2:8, 2:9, 47:1, overview partners 45:20, 46:5,
47:2, 50:11, 4:19 14:12, 14:14 46:10
50:12 own partnership percent
other 8:6, 8:7, 56:6, 14:13 30:15, 30:17
8:6, 9:1, 56:7, 56:9, party percy
11:16, 14:20, 56:21, 57:2, 9:3, 22:7 22:20, 22:22,
16:14, 18:17, 57:6, 57:7 passage 23:1
36:22, 38:3, owned 12:1 performing
38:14, 53:2, 52:4, 52:6, passed 18:9
53:9, 53:16, 56:5, 56:19, 7:15, 13:17, person
54:10, 58:19, 57:8 14:2, 15:6, 7:18, 15:1,
59:22 owning 32:20, 48:7 16:19, 27:18,
others 56:14 passing 35:21, 36:9,
27:13, 28:1 owns 15:12, 51:9 36:10, 44:20,
otherwise 4:6 passionate 45:17, 52:5
63:15 P 24:2 pervasive
out package path 37:17
3:15, 7:8, 55:15 26:7 phi
14:20, 19:16, page pause 13:13
19:19, 20:11, 39:16, 45:15, 12:16 phonetic
27:7, 27:8, 52:13, 56:20, pay 2:3, 21:16,
30:17, 35:10, 57:21 9:3, 9:7, 26:15, 28:7,
35:11, 35:14, pages 25:12, 34:1 32:18
35:15, 36:3, 1:21, 4:12, payment photo
36:18, 36:19, 4:13 8:17, 8:21, 19:17
39:13, 39:21, paper 10:16, 34:1 physical
40:6, 40:10, peers 27:22
49:4, 59:4 33:13
paperwork 20:1 physically
outcome penalize 22:14, 27:2
63:15 43:12
paragraph 14:2, 37:22 piece
outdated penalties 33:4, 33:12,
28:3 39:16
paralyzed 25:15 56:14
outside people pieces
39:12 16:15
parents 5:13, 5:14, 34:21
over 6:9, 6:16, 7:11, place
5:6, 6:8, 10:4, 27:10
part 8:12, 10:12, 18:1, 18:20,
30:5, 30:17, 15:22, 16:18, 24:16, 26:6,
13:22, 26:2,
PLANET DEPOS
58:5 pray private proved

planet 26:9 53:4 53:9
63:19 pre probably provide
plans 27:8 42:19, 56:1 9:3, 11:14,
26:18 pre-addressed probates 13:19, 19:16,
plead 21:4 36:14 24:22, 29:6,
17:8, 23:9 pre-filed problem 52:2, 52:5, 56:2
please 3:17, 7:19 35:9 provided
6:20, 23:17, pre-fill problems 28:18
23:18, 26:12, 9:4 31:12 provides
31:7, 41:3 pre-filled proceedings 11:4, 16:20,
point 7:19, 28:19 63:4, 63:5, 20:19
7:10 pre-filling 63:9, 63:11 providing
pole 8:19 process 17:20, 20:10,
17:4 preceded 11:8, 12:19, 22:9, 24:15,
police 58:1 19:14, 19:21, 25:3
17:4 precincts 20:2, 25:5, provision
policies 39:8 25:22, 28:12, 10:17, 48:22
16:6 predominantly 29:13, 29:21, provisions
political 11:18 37:15, 38:16, 10:13, 17:22
10:11 pregnant 48:22, 49:4 public
politician 16:18 program 9:11, 9:13,
23:3 premise 55:16 9:16, 26:15,
politics 52:4, 56:22 programs 39:6, 42:11,
13:16, 29:11 prentice 56:1 43:18, 44:22,
poll 56:21 prohibit 52:4, 52:6,
35:7 prepared 10:14 53:6, 53:18,
polling 45:3, 63:3 prohibiting 55:22, 56:21,
24:16, 26:6, preparing 11:2 60:4
39:8 61:11 promote publicly
polls present 25:21 56:5
15:21, 16:1, 3:6 proof pull
22:13, 22:15, presented 22:8 3:15, 8:12
40:13 5:9, 17:21, properties punitive
poor 43:18 52:6 62:1
11:18, 22:17 president property purports
population 13:13, 17:14, 52:4, 53:4, 12:1
12:12 24:1 53:7, 53:10, purpose
portion prey 53:18, 56:6, 16:7
61:21 10:10 56:14, 56:21, put
positions principal's 57:2, 57:6, 57:8 16:14, 40:5,
13:12 37:20 protect 53:17, 57:7,
possibility prior 28:5 58:5
18:8, 18:20, 4:16, 18:18 protected putting
22:1 prison 24:10, 26:20, 3:12
possible 11:22, 13:1, 27:3, 27:5, Q
30:19 13:2 27:18, 27:22 qualified
pow prisons protecting 18:19
52:16 14:7, 38:20 26:1
PLANET DEPOS
question receive reject republic

31:6, 33:10, 7:7, 8:20, 9:7, 26:13 6:4
33:17, 33:18, 16:18, 34:1, related republican
48:19, 48:20, 39:20, 45:16 63:13 5:20
49:15, 55:6, received relates republicans
55:7, 56:13, 21:11 4:11 31:19, 34:20
57:11, 57:20, receives relationship request
57:21 21:6 14:10 6:8, 9:4,
questions receiving relative 23:17, 29:4
9:12, 31:8, 8:17 16:21 requested
48:12 recidivism relatives 21:8
quick 12:20 35:19 requesting
55:7 recognized religious 8:18
quorum 38:6, 43:10 26:2, 26:4, requests
3:4, 3:5 reconsider 26:9, 26:12 17:6
quote 39:9 remarks research
6:2, 18:15 record 4:22, 6:17, 6:2, 32:3
R 14:8, 63:11 9:15 reserve
racially recorded remedied 9:10
16:5 1:11 31:14, 33:8 resident
re-engagement recording remedy 26:15, 28:9
12:14 62:5, 63:4, 31:12 resource
re-entry 63:5 remember 20:13
12:19 recreate 51:20 resources
read 11:6 remembrance 13:2, 20:19
10:19, 37:11, reduced 52:3 respect
39:15, 45:19, 63:9 remind 23:11
45:21, 46:10, reducing 13:8 responds
56:4 12:19 reminders 25:11
ready referenced 21:9 responsible
3:6, 24:4, 49:16 rendered 8:8, 12:7,
40:18, 44:12, refill 12:7 12:14
48:15, 51:17 32:22 replace rest
real-time reform 52:12, 54:13 61:22
20:16 31:17 report restoration
reality regain 42:3, 43:5, 11:16
12:2 15:7 44:8, 51:14 result
realize regardless reports 14:6, 15:9,
18:12, 29:17 12:4 22:4 19:13
realized registered represent retired
24:11 21:6, 27:11 24:2, 24:5, 46:5
really registering 46:5 retrieve
10:12, 35:20, 12:6 representatives 16:16
43:9, 59:9, registrar's 14:11 return
61:17 35:12, 35:18 represented 21:21
reason registration 6:3, 38:11 returning
36:22, 37:3 11:15, 24:16 representing 8:8, 10:15,
regulations 29:10 20:7
20:21
PLANET DEPOS
reviewed 40:20, 41:3, 60:15, 61:4, 2:8, 2:10, 2:12,

5:6 46:19, 46:20, 61:10 2:14, 2:16,
ridiculous 50:4 saying 2:18, 2:20,
22:8 room 33:11, 35:1, 2:22, 3:2, 3:4,
right 7:2, 29:12 36:20, 37:13, 8:9, 23:20,
4:14, 4:22, rotten 43:2, 43:3, 31:16, 31:21,
5:2, 6:6, 6:12, 37:16 45:7, 45:17, 35:2, 40:20,
12:11, 16:12, runs 54:9, 58:21 41:3, 41:5,
20:9, 22:22, 18:8 says 41:7, 41:9,
23:20, 25:17, rural 33:1, 35:7, 41:11, 41:13,
26:22, 29:3, 37:5, 38:14 46:11, 54:10, 41:15, 41:17,
30:19, 32:17, S 54:12, 56:19, 41:19, 41:21,
34:8, 35:6, 56:20 42:1, 42:6,
safeguard 46:21, 47:1,
35:8, 39:18, 11:7, 12:1 sb1
42:18, 43:22, 11:6, 12:1, 47:3, 47:5,
safety 47:7, 47:9,
46:8, 47:21, 48:3 12:8, 13:16,
52:12, 56:15, 13:18, 14:1, 47:11, 47:13,
56:18
said 14:2, 14:9, 47:15, 47:17,
rights 7:11, 27:13, 15:12, 16:17, 47:19, 47:21,
29:20, 30:1, 21:20, 22:11, 48:15, 49:9,
15:13, 16:8, 30:2, 30:4,
17:5, 18:3, 29:3 24:13, 25:8, 49:20, 50:5,
30:19, 33:18, 26:8, 26:13, 50:11, 50:13,
ripple 34:18, 39:15,
38:2 27:18, 28:4, 50:15, 50:17,
42:6, 42:9, 29:4 50:19, 50:21,
risk 45:13, 46:12,
27:4 sb1's 51:1, 51:3,
53:2, 59:13, 51:5, 51:7,
risks 63:5, 63:8, 12:21
11:3 scare 51:9, 51:12
63:10 secure
robert salute 21:20, 22:6
3:2, 3:3, 38:5, scenario 5:16, 6:1, 30:8
23:2, 23:4 security
38:8, 41:22, same 33:19
47:18, 51:8, scene 11:7
9:8, 28:1, see
51:10, 51:12, 32:14 57:9
60:18 scheduled 3:15, 10:1,
sanctity 21:20, 34:19,
roberts 11:8 61:1
2:14, 2:15, school 37:14, 38:1,
sanctuary 40:6, 40:11,
4:7, 41:11, 26:6 25:1, 26:16
41:12, 47:7, second 58:17
saw seeing
47:8, 49:19, 55:10, 56:10 4:3, 16:19,
49:20, 50:19, 23:20, 44:12, 36:18
50:20
say seen
4:22, 5:13, 44:17, 47:22,
roland 48:16, 49:5, 29:22
5:17, 24:12, self-governed
19:1, 19:2, 27:6, 29:9, 49:21, 60:9,
19:3, 21:14 60:12, 60:13, 10:20
33:2, 35:18, selma
rolanda 35:20, 35:21, 60:14
19:1 secrecy 38:11
45:11, 50:1, senate
role 50:3, 50:13, 10:9
12:12, 32:19 secretary 1:8, 3:7, 9:18,
50:14, 55:1, 16:10, 17:9,
roll 2:2, 2:4, 2:6,
2:2, 15:21,
PLANET DEPOS
17:16, 40:19, 58:3 34:19, 42:20, 31:15, 32:11,

48:2, 49:19, severely 60:3 37:16, 48:8,
50:4, 51:18, 11:22 singleton 55:22, 56:3,
60:21 shall 31:18 59:22, 60:3
senators 39:22, 40:2 sir somebody
14:16, 25:19, shannon 35:4, 39:11, 8:6, 35:10,
39:14 21:16 55:7, 55:17, 36:12, 46:13,
send shape 55:20, 56:22, 61:14
16:3, 21:1, 22:10 57:2, 57:10, somebody's
21:8 shelby 57:12, 59:18 37:21
senior 26:16 sister someone
11:20, 13:11 shopping 24:8, 24:9, 7:21, 13:18,
sense 56:3, 56:14 27:16, 27:19 16:15, 16:19,
10:22, 17:1, short sisters 18:5, 18:17,
36:8 9:7 28:4 18:19, 34:1,
sent should sit 53:2
35:16, 36:8, 5:20, 5:21, 9:12 someone's
36:9 5:22, 7:22, sitting 17:5
serious 11:5, 14:21, 27:16, 37:22 something
38:20 55:15 situation 3:20, 18:6,
serve show 34:17, 36:1 33:6, 35:13,
23:14, 25:19 30:14, 30:20, situations 37:20, 40:17,
served 34:13 33:14 45:12, 55:21,
33:10 showing six 59:6, 59:16,
service 18:10 4:12, 14:15, 61:16
20:14, 23:5, shows 32:8, 52:16 sometimes
29:1 8:12 skills 23:12, 61:15
services side 63:12 sorority
11:13, 17:20, 9:1 small 61:15
21:19 sigma 56:2 sorry
serving 13:13, 14:18 smokers 41:17
23:4, 23:6, signal 58:17 sounds
31:22 53:3 smoother 59:21
session signature 12:19 southern
3:13, 29:22, 40:3, 54:11 social 18:11
43:10, 48:7, signature-mig2k 11:13, 19:8 spanish
51:21 63:16 societal 58:6
sessions signed 12:15 speak
63:6 9:18, 39:22 societies 13:8, 15:19,
sets significant 39:3 38:9, 44:20
14:19 6:22, 13:1 society speaker
setup significantly 12:18, 26:1 4:2, 4:4,
4:11 22:1 sole 25:18, 41:4,
seven signs 16:7 41:6, 41:10,
42:2, 43:4, 21:2, 40:1 some 41:14, 42:22,
56:20 since 4:21, 17:22, 46:17
several 8:13, 20:17, 18:2, 20:10, speaker's
17:4, 23:3, 26:5, 32:20, 30:12, 31:12, 29:9
PLANET DEPOS
speaking 18:5 strongly 44:11

53:4 states 17:8 substitutes
speaks 16:6, 17:18, struggling 30:22
49:12 18:12, 20:15, 20:1 substitution
special 24:13, 25:21, stuck 27:4
51:21 39:19, 58:1 32:2 successful
specific stations student 22:7
26:19, 53:18 32:12 13:13, 14:17, supersedes
specifically steal 14:19, 15:4, 6:14
20:21 5:18 20:5, 27:7 supervision
spite stealing students 63:10
37:10 30:11 14:5, 14:10, support
spoke step 14:19, 14:20, 10:13, 10:16,
44:18, 44:21 12:17 14:21, 15:2, 14:16, 20:1,
sponsor stepped 15:5, 15:8, 20:8, 29:6
42:9, 46:13 32:19 15:9, 19:10, supporting
st stewart 19:13, 19:15, 11:5, 24:3
22:2 3:2, 3:3, 38:5, 19:17, 19:20, suppression
staff 38:7, 38:8, 20:6, 20:9, 17:3
13:21, 14:3 41:21, 41:22, 20:17, 22:16, suppressive
staffing 47:17, 47:18, 25:2, 26:17, 23:10
13:3 51:7, 51:8, 26:18, 26:22, supremacy
stamped 51:10, 51:12, 27:1, 27:2, 16:8
21:4 60:18 27:19, 27:21, sure
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54:10 16:5, 19:18, 58:19 survive
start 21:8, 27:4, sub 6:4
3:15, 9:18 34:16, 37:9, 4:12 sustain
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58:1, 58:3 streaming 44:4
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17:13, 18:1, stringent 42:5, 44:10,
21:21
12:21
PLANET DEPOS
take territories think 8:14, 9:10,

18:1, 18:5, 58:7 5:12, 9:9, 17:10, 27:15,
18:20, 37:7, territory 23:5, 23:12, 28:17, 28:20,
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46:3, 54:4, text 32:7, 35:6, 31:22, 33:3,
54:9, 57:16, 21:9 40:8, 43:9, 45:1, 46:14,
59:4 thank 44:9, 45:20, 61:1
taken 3:9, 4:10, 46:14, 49:14, times
34:20, 45:16 9:20, 10:19, 56:11, 56:12, 33:9
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29:15, 40:22 18:22, 21:14, thinking 31:1, 40:8,
talk 21:15, 22:4, 59:5, 61:16 43:17, 44:21,
30:12, 31:3, 22:20, 23:21, third 45:5
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14:9 thanks 39:14, 42:3, 9:21, 11:9,
task 18:21 43:4, 52:13 13:5, 13:7,
31:17 themselves three-letter 15:15, 15:17,
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26:16 49:13 through 21:12, 21:15,
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22:4 36:6 54:13 41:1, 42:2,
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44:15 37:17, 39:13, 30:21 44:3, 44:10,
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57:4 48:16, 48:20,
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61:13, 61:17, time 49:18, 50:1,
28:3, 34:8 50:3, 50:6,
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23:4
PLANET DEPOS
50:8, 51:13, true 27:22, 32:17, values

51:17, 52:20, 63:10 33:19, 55:22, 25:20, 26:12
52:22, 54:19, trust 63:9 version
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55:19, 59:17, 36:4 10:8 40:7
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60:14, 60:17, 35:3, 46:5 7:4, 20:2, 16:1
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46:1, 46:15 45:19 understanding 12:17, 21:9
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56:2 turnout unintended 5:11, 20:6,
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51:22 twin 58:1 volunteer
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transcribed 7:17, 13:9, university 15:20, 24:2
1:22 21:12, 31:8, 13:12, 14:12, vote
transcriber 33:3, 57:21, 14:14, 19:4, 11:3, 12:11,
63:1 59:20, 61:18, 19:10 16:8, 16:12,
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63:3, 63:10 typewriting 7:17, 8:3, 9:2 19:12, 19:15,
transcriptionist 63:9 unless 20:10, 20:12,
63:18 U 59:5 20:17, 20:18,
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55:7 27:3, 27:18, value
trimester 51:10
20:9
16:20
PLANET DEPOS
voter 38:10, 39:15, whatever worms

7:7, 11:14, 40:12, 42:20, 9:14, 35:22, 59:3
11:15, 17:3, 45:4, 46:7, 49:16, 53:19, worth
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10:10, 10:16, 61:14 18:15, 37:2 33:13, 59:14
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30:4, 30:7, 42:10, 60:4, 37:6, 57:18 00
34:17, 37:13, 61:11 worked 43:10, 61:2
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9:22, 32:5 working 1
25:7 4:2, 4:4,
PLANET DEPOS
25:18, 41:4 285921

11 63:7
52:2, 53:16, 3
53:19, 58:18 3
12 41:10, 43:10,
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30:17, 56:1 58
2001 52:13, 54:5,
51:21 54:13
2010 6
34:20 63
2016 1:21
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2020 19:11, 53:15,
22:6 54:9
2023 68
49:7, 49:17 52:13, 54:6,
2024 54:9, 54:13
1:12, 16:4, 8
49:7, 49:16, 89
63:20 39:16
209 9
23:7 94
21 39:17
22:2, 29:11 95
25 29:19
27:15
26
63:20
PLANET DEPOS
2024 May-03 AM 09:52
U.S. DISTRICT COURT
N.D. OF ALABAMA

SOUTHERN DIVISION

THE NAACP, et al.,

v.

Defendants.
DECLARATION OF SCOTT DOUGLAS IN SUPPORT OF MOTION FOR

PRELIMINARY INJUNCTION
Pursuant to 28 U.S.C. § 1746, I, Scott Douglas, declare as follows:
1. I am the Executive Director of Greater Birmingham Ministries (“GBM”). I have
served in this role since February 1993.
2. GBM is a nonpartisan, 501(c)(3) nonprofit organization founded in 1969 in
response to the challenges posed by the mid-twentieth century Civil Rights movement and its
transformative impact in Birmingham, Alabama, and across the United States.
3. As recently as the March 2024 presidential preference primary election, GBM
effectively communicated its pro-voting message by assisting voters to apply for absentee ballot
applications and ballots, including assisting eligible incarcerated voters in applying for absentee
ballots.
1
4. In 2024 and in the future, GBM would like to continue to engage in its absentee
ballot application communication with and assistance on behalf of the communities it serves in the
Greater Birmingham area and across Alabama.
GBM’s Mission and Viewpoints
5. GBM is a multi-faith, multi-racial, non-profit membership organization that
provides emergency services to people in need and engages people to build a strong, supportive,
and engaged community and to build a more just society for all people. Though GBM primarily
works in Birmingham and Jefferson County, it seeks to address urgent human rights and social
justice needs across Alabama. Also central to GBM’s mission is increasing civic participation
among historically disenfranchised communities.
6. To promote civic engagement and encourage voting in the communities it serves,
GBM engages in voter education and assistance, including discussing civics with incarcerated
individuals and assisting Alabamians to register to vote, restore their voting rights, and encourage
them to vote, including by absentee ballot.
7. GBM engages in voter assistance to express a clear message: voting is a person’s
fundamental right and is the key to advancing civil and human rights in Alabama. GBM considers
its voter assistance critical to effectively expressing its message that voting is a means of creating
political power among historically disenfranchised communities in Alabama. GBM sees its voter
assistance as contributing to Alabama’s movement for civil and human rights in a state that has
long oppressed communities of color. GBM also sees its voter assistance as conveying the message
that voting should be equally accessible to eligible incarcerated voters.
GBM’s Absentee Ballot Application Activities
8. As part of its voter assistance activities, GBM’s paid staff and volunteers
2
communicate with and assist senior citizens, people with disabilities, shift workers, formerly
incarcerated people, and eligible incarcerated voters apply for absentee ballots.
9. GBM has seven paid staff members and three current vacancies in staff positions.
GBM has approximately 2,780 members who make a financial contribution to the organization.
GBM also has over 100 volunteers who assist GBM in its different program areas. GBM’s Board
of Directors is primarily comprised of representatives of Alabama’s faith communities.
10. GBM staff and volunteers primarily work in the Birmingham area, but they also
communicate with and assist hopeful voters across the state, often working in Wetumpka,
Tuscaloosa, St. Clair, and Springville. GBM utilizes both paid staff and volunteers to communicate
its pro-voting message and assist individuals in applying for absentee ballots. Such individuals
include senior citizens, people with disabilities, and current and formerly incarcerated people.
11. GBM also conducts voter registration and voter education events on sidewalks,
streets, pop-up voting events, and at other public events. GBM may organize these events on its
own or table at an event organized by other civic organizations in Alabama. During election season,
GBM may hold pop-up events several times a week. During these events, GBM will encourage
eligible voters to vote by absentee ballot and provide absentee ballot application assistance to
voters who request assistance. As part of their encouragement and assistance, GBM staff and
volunteers will ensure that the voter is (1) eligible to vote absentee and (2) able to apply for an
absentee ballot. GBM ensures that a person is able to apply for an absentee ballot by providing
that voter with a copy of the application, pen, envelope, and stamp to ensure that the person can
fill out the application and send it to their county’s Absentee Election Manager. For example, GBM
held a community event to educate people on absentee voting in 2020, encourage eligible
individuals to vote by absentee ballot, and to assist attendees with absentee ballot applications.
3
This event was open to the public and allowed GBM to spread its message about the importance
of voting and voting absentee.
12. GBM will inform the individual about absentee voting in Alabama, print the
absentee ballot application for the individual, provide a pen to assist the individual in filling out
the form, provide an envelope for voters to mail the application, and provide postage for the voter
to send the application. GBM staff and volunteers spend time reviewing the application to ensure
that all required boxes are marked correctly and completely. GBM pays for the envelope, pens,
and postage that it provides to individuals that it assists in applying for absentee ballots, as well as
the paper and printer for printing the applications.
13. GBM hands out snacks, branded pens, and sometimes t-shirts when its staff and
volunteers encourage and assist voters in applying for absentee ballots. GBM provides its
volunteers with pens, paper, t-shirts, gas stipends, and food when they participate in voter
registration and civic education drives. GBM pays for all of the supplies that it gives its volunteers
when those volunteers assist individuals in applying for absentee ballots.
14. Senior citizens, people with disabilities, and others in need come to GBM for food,
financial assistance, and clothing assistance. GBM conducts a free clothing distribution twice per
week and organizes food distribution twice per month to assist those in need in the Greater
Birmingham area. GBM also provides financial assistance once a month, which sometimes leads
to questions about voting. GBM will discuss and encourage absentee voting in Alabama—
including by providing absentee ballot application assistance to eligible people—when they come
to GBM for these other resources.
15. GBM also provides free materials acquired through donations that are needed by
these individuals for their health and well-being, including medical devices such as oxygen
4
machines and other items such as walkers, wheelchairs, and compression socks. GBM also
provides referrals to other organizations for other necessary sources. During these interactions,
GBM has discussed and encouraged voting by absentee ballot with individuals and assisted these
individuals with absentee ballot applications, which they require because of health and/or mobility
issues.
16. GBM specifically works to reach voters across the state who have past felony
convictions to register them to vote, if eligible, or to assist them in restoring their voting rights.
Once a person with a past felony conviction is registered to vote, GBM will inform them about
absentee voting in Alabama and assist that person in applying for an absentee ballot, if they request
that assistance. Assisting these voters is a critical part of GBM’s work to encourage voting among
every eligible individual; in GBM’s experience, many people mistakenly believe that any felony
conviction is a bar to voting, contrary to Alabama law.
17. GBM holds voter registration events around the state where they also discuss
absentee voting and assist with absentee ballot applications on behalf of formerly incarcerated
individuals. These events include second chance job fairs, expungement clinics, drug court, and
tabling on sidewalks outside of ABPP field offices. At these events, GBM provides absentee ballot
applications, as well as other provisions to help assist individuals with filling out those
applications, including a pen, envelope, and postage. At these events, GBM volunteers often wear
GBM-branded t-shirts that we provide to volunteers.
18. GBM also works with students from the University of Alabama on a program called
Return My Vote (“RMV”) to help register and assist voters with prior felony convictions in
applying for absentee ballots. Together, GBM and RMV encourage voting and distribute voter
registration applications, absentee ballot applications, and Certification of Eligibility to Register
5
to Vote (“CERV”) applications. GBM and RMV then help individuals fill out these applications
and provide postage. GBM also has a hotline where people make calls to inquire about voter
assistance and eligibility.
19. GBM regularly does this re-entry voting work in partnership with other civic
organizations, including the League of Women Voters of Alabama, Faith in Action Alabama, the
NAACP, and others. These partnerships are one way that GBM associates with other organizations
in order to amplify shared values of promoting equal participation in democracy and share their
pro-voting message.
20. GBM encourages voting and provides assistance to eligible individuals
incarcerated in Julia Tutwiler Prison for Women (“Tutwiler”) and St. Clair Correctional Facility
(“St. Clair”), as well as Birmingham County and City Jails. GBM assists those incarcerated
individuals in voter registration, voting rights restoration, and absentee ballot application
assistance. GBM visits Tutwiler once or twice per month to encourage democratic participation
and distribute absentee ballot applications and CERV applications. GBM successfully assisted 10
women in submitting applications for absentee ballots for the March 2024 presidential primary
election.
21. GBM seeks to expand its prison voting work across Alabama in 2024 and beyond,
fostering relationships in other prisons and expanding its voter education and assistance programs
in Tutwiler and St. Clair. For example, GBM participated in a job fair at the Bibb Correctional
Facility job fair on April 25, 2024. GBM provided information about voter restoration and
registration, but could not discuss absentee options because of SB 1.
22. Without our encouragement and assistance, many voters would be unable to apply
for absentee ballots. In particular, we are often the primary people that incarcerated voters have
6
assisting them with their absentee ballot applications. Because incarcerated voters are only able to
vote by absentee ballot (Alabama does not provide jail- or prison-based voting sites), such voters
have considered our absentee ballot application assistance a lifeline to exercising their right to
vote. Likewise, many voters with disabilities cannot vote without someone assisting them in filling
out and submitting the application. Many voters with disabilities who come to GBM for full-
service assistance also choose to have GBM assist them with their absentee ballot applications.
Now in its 55th year, GBM is well-known and greatly respected by Alabamians for its voting work,
and seek us out for our assistance.
23. GBM performs this work as a part of its larger organizational mission to promote
civil rights in Alabama. GBM considers absentee ballot application assistance to be a public
expression of its core value that voting is the key to advancing civil rights.
SB 1’s Effect on GBM’s Voter Assistance Activities
24. As a result of SB 1, GBM does not know which of its absentee ballot application
assistance communications and activities are lawful and which are not. This has prevented GBM
from being able to effectively plan its get-out-the-vote and public education events ahead of the
November 2024 general election. GBM staff and members, including myself, feel threatened by
the risk of criminal prosecution simply for helping voters lawfully apply for absentee ballots.
25. GBM has begun diverting time to understand which communications and activities
are lawful because GBM does not want to expose its staff, interns, and volunteers to possible
criminal prosecution. This has included spending hours reviewing SB 1 and its amendments,
listening to and attending legislative hearings, spending time meeting with coalition partners to
discuss SB1, and more. GBM has been forced to spend considerable time creating alternative plans
for its voting work inside correctional facilities, which has been a major programmatic priority.
7
GBM had been planning for over two years to ramp up its work inside jails and prisons across
Alabama to encourage and assist eligible individuals with absentee voting. To this end, GBM was
awarded a grant in September 2023 to support this programming, which GBM began earlier this
year in Tutwiler. GBM can no longer proceed with plans to train volunteers on absentee ballot
assistance, including a law student whose summer externship was intended to include work inside
Tutwiler encouraging and assisting eligible voters to request absentee ballots. GBM cannot risk
exposing student volunteers to felony prosecution under SB 1. GBM wants to assist Alabamians
with applying for absentee ballot applications and with casting absentee ballots successfully in the
November 2024 general election, as well as in future elections. GBM particularly wishes to
provide this assistance for the eligible incarcerated voters it encourages to participate in the
democratic process—who can only vote via absentee mail ballot—but SB 1 threatens GBM’s
ability to do this work. GBM staff and volunteers have a bona fide fear that they will be prosecuted
for their absentee ballot application assistance to Alabamians.
26. GBM received a grant to conduct absentee voter registration at Tutwiler Prison and
encourage democratic participation, and GBM assisted incarcerated voters in applying for absentee
ballots before the 2024 presidential primary election. GBM would like to continue this work in
advance of the November 2024 general election as well. SB 1, however, threatens GBM’s ability
to achieve grant objectives (as well as the grant funder) by threatening its staff and volunteers with
felony prosecution if they assist eligible incarcerated individuals with absentee ballot applications
and voting.
27. GBM hopes to expand their work encouraging and assisting eligible incarcerated
voters to apply for absentee ballots, both by adding more staff and by expanding the project to
other correctional facilities, including St. Clair Prison, the Bibb Correctional Facility, and federal
8
prisons. As noted, for incarcerated individuals who are eligible to vote, their only option is to vote
by absentee ballot. These individuals cannot complete the absentee ballot application process
without the assistance of a third party (such as a GBM employee or volunteer) who prints the
application, provides the pen needed to fill out the application, provides the envelope required to
mail the application, and provides the postage required to mail the application. It is even possible
that prison or jail officials and chaplains could face liability from providing application assistance
for eligible incarcerated voters since they receive a salary to do their work. In the past, GBM has
filled a critical gap by ensuring that eligible incarcerated voters can vote by registering for an
absentee ballot. Now this assistance risks criminal prosecution of GBM staff and volunteers under
SB 1. And if GBM or other similar organizations do not assist incarcerated voters with absentee
ballots, those individuals will be unable to exercise their fundamental right to vote.
28. SB 1 has already impacted our ability to encourage and assist eligible voters with
applying for absentee ballots and to educate the public on voting. GBM no longer brings absentee
ballot applications into Tutwiler Prison, which means that GBM staff and volunteers are unable to
assist eligible incarcerated voters apply to vote absentee. GBM recently held a training in Mobile
in April 2024 for voting rights restoration and voter registration advocates and community
members, but could not include information on absentee ballot application assistance because SB
1 does not clearly state what communication and assistance is lawful and we do not want to risk
misinforming the public.
29. GBM creates and distributes election guides that include information on applying
for and voting by absentee ballot. Because of SB 1, GBM has held off on distributing its 2024
guides in case the information regarding absentee ballot assistance is incorrect. GBM does not,
9
itself, understand what activities are criminalized under SB1, and does not want others prosecuted
because of its educational materials.
30. GBM also engages in online civic education through our Power of Participation
workshops. These modules include information on applying for and voting by absentee ballot.
Prior to SB 1, GBM partnered with the Birmingham Municipal Court to offer civic education
training online, which allowed participants to receive community service hours that counted
towards requirements from their criminal cases. Due to SB 1, GBM does not plan to restart this
program because it does not have the time, resources, or clarity on the law to amend its modules.
31. GBM has recruited new members at our voting events in the past. Members of the
public often express an interest in becoming more involved with GBM’s work and helping with
future events. GBM has many volunteers who are not members (because they did not make a
financial contribution), but instead help GBM occasionally. SB 1 will limit GBM’s ability to
recruit new volunteers and may lead current volunteers to quit because they fear felony
prosecution.
32. SB 1 has restricted GBM’s mission of registering people to vote, encouraging their
participation, and assisting them in being able to cast a ballot on Election Day. Our constituents
with disabilities, in particular, will be affected by SB 1 because they are unable to submit their
absentee ballot applications without our assistance. There is an assisted living facility across the
street from GBM’s office; in the past, GBM had spoken with staff at the facility about assisting
residents with applying for absentee ballots. Because of SB 1, GBM is unable to reach out to and
assist these individuals.
33. SB 1 is an enormous obstacle for GBM’s work and greatly reduces our ability to
effectively convey our pro-voting message. Our staff, volunteers, and board members do not
10
understand whether they can continue to communicate with voters about applying for absentee
ballots and assist them to do so, and whether they will be prosecuted for their actions if they do
engage in such communication and assistance. .
I declare under penalty of perjury that the foregoing is true and correct.
Executed on May ___,

02 2024 in Birmingham, Alabama.
______________________________
Scott Douglas
11
2024 May-03 AM 09:52
U.S. DISTRICT COURT
N.D. OF ALABAMA

SOUTHERN DIVISION

THE NAACP, et al.,

v.

Defendants.
DECLARATION OF BENARD SIMELTON

IN SUPPORT OF MOTION FOR PRELIMINARY INJUNCTION
Pursuant to 28 U.S.C. § 1746, I, Benard Simelton, declare as follows:
1. My name is Benard Simelton, and I am the President of the Alabama State Conference of
the NAACP (“Alabama NAACP”). I have served in this role since October 2009. The Alabama
NAACP is a Plaintiff in this matter.
2. The Alabama NAACP is the state conference of the National Association for the
Advancement of Colored People, Inc. (“NAACP”). The Alabama NAACP is a nonpartisan,
membership organization with nearly 5,000 members residing in the State. Members of the
Alabama NAACP pay annual dues. Approximately 95% of members identify as Black and most
are lawfully registered voters. The Alabama NAACP oversees 35 branches and approximately 10
youth and college units of the NAACP in Alabama (collectively “units”), and all members of local
units are members of the Alabama NAACP.

3. The Alabama NAACP’s leadership includes the statewide Executive Committee as well as
the leadership of local NAACP units throughout Alabama. The Alabama NAACP’s work is led by
unpaid members, such as my role as President, who staff and carry out the Alabama NAACP’s
voter engagement and education programming across the state. Paid staff and consultants also
assist in carrying out our work.
4. Individual members include Black registered voters who are senior citizens, disabled,
students, undereducated, and others who require assistance with the absentee voting process,
including their absentee ballot applications. Some Alabama NAACP members also serve as
assistors to such voters. The Alabama NAACP has assisted voters with absentee ballot applications
and would like to continue doing so in the future.
Alabama NAACP’s Mission and Viewpoints
5. The Alabama NAACP is the oldest and most significant civil rights organization in
Alabama. The mission of the Alabama NAACP is to ensure the political, educational, social, and
economic equality of Black Americans and all other Americans and to eliminate racial
discrimination in the democratic process. Our objectives include seeking the enforcement of
federal laws and constitutional provisions securing civil rights, as well as educating members and
the public about their rights.
6. Voting and encouraging voting are foundational values of the Alabama NAACP. To that
end, the Alabama NAACP conducts advocacy to safeguard equal access to the vote, as well as
robust voter education and engagement programs to communicate and advance our views about
the importance of participating in the political process by voting, including by absentee voting if
eligible. The Alabama NAACP’s voter education and engagement programs seek to engage
Alabamians including those who are Black, elderly, disabled, students, undereducated,
2
incarcerated, or others who are less likely to be engaged in the political process and need assistance
to participate in elections.
Alabama NAACP’s Voter Education and Assistance Activities
7. Voter assistance activities, including absentee ballot application assistance, are a core part
of the Alabama NAACP’s voter education and engagement communications and programming
and further our mission of encouraging participation in the democratic process.
8. Volunteers receive training and materials before participating in voter education and
engagement events where they will be communicating the Alabama NAACP’s pro-voting message
by registering people to vote and assisting voters with their absentee ballot applications.
Volunteers may also receive branded t-shirts, buttons, or pens as well as snacks/food and water.
9. To communicate our civic engagement message through our voter education and
engagement work, the Alabama NAACP organizes in-person and virtual town hall meetings.
During these events, we communicate the importance of voting through registering eligible
Alabamians and providing information on the voting process, including by answering questions
about in-person and absentee voting. Additionally, the Alabama NAACP hosts and participates in
voter outreach and education events on college campuses.
10. At town hall meetings or campus events, the Alabama NAACP encourages eligible
individuals to vote and has provided absentee ballot applications and assisted voters with
completing applications on an as-required basis as part of that encouragement. At in-person town
halls and campus events where we assist voters with their absentee ballot applications, we often
provide water and snacks/food, and provide branded materials to assistors and other attendees.
11. Local units of the Alabama NAACP also host events where volunteers express our pro-
voting message by helping to register Alabamians to vote, sharing voter education materials, and
3
providing absentee application assistance. For example, the Limestone County Branch of the
Alabama NAACP hosted a public Drive-Thru Voter-Registration, Voter Education, and Photo ID
event where volunteers assisted voters with registering to vote, updating voter information,
absentee applications, and voter restoration. Volunteers are usually given branded t-shirts to wear,
so that they are easily identifiable to voters who need their help. Volunteers at such events, which
can be several hours long, often are provided snacks/food and water to sustain them. The Alabama
NAACP often partners with other nonpartisan organizations, like the League of Women Voters of
Alabama, who share our goal of encouraging civic engagement through voter education and
engagement initiatives.
12. As part of our pro-voting encouragement and outreach, the Alabama NAACP assists voters
in nursing homes and jails, many of whom would not be able to vote without such assistance. To
encourage voters in these facilities to vote and vote absentee, the Alabama NAACP has obtained
copies of the application form from county election officials and brought the copies to the facilities.
We have also provided stamps and envelopes so that absentee ballot applicants can submit their
applications in the mail. Because disseminating physical voter education materials to voters is our
most effective means of communicating our pro-voting message to these voters and assisting them
to successfully apply for an absentee ballot, we also have provided branded materials for these
voters to review and share with other voters.
SB 1’s Effect on Alabama NAACP’s Voter Education and Assistance Activities
13. When SB 1 was being considered by the Alabama Legislature, the Alabama NAACP
expressed extreme concern about the criminal penalties imposed for providing assistance to other
members and the communities we serve. On February 28, 2024, Norma J. Sanders, a member of
the Alabama NAACP, testified before the House Constitution, Campaigns, and Elections
4
Committee about the critical role absentee voting assistance plays in our voter encouragement and
engagement work and our long history of providing assistance to voters. We explained our concern
that SB 1 will render criminal the assistance work the Alabama NAACP has historically provided,
our most effective means of communicating our pro-absentee voting message.
14. The Alabama NAACP would like to continue our work encouraging eligible voters to vote
absentee and help them to do so, but now that it is enacted, SB 1 severely chills the Alabama
NAACP’s ability to conduct effective absentee voting campaigns and communicate the message
that voting should be accessible to all. Due to past targeting of our members in Alabama who
assisted absentee voters, the fears of criminal prosecution and liability of current Alabama NAACP
volunteers and members are especially acute.
15. Indeed, SB 1 already has restricted the Alabama NAACP’s work. In the 2024 primary
elections earlier this year, the Alabama NAACP refrained from providing any absentee application
assistance, including for residents of nursing homes, because we felt threatened by the uncertainty
of SB 1’s language and did not want to put our members or anyone else at risk of prosecution.
16. The Alabama NAACP had planned to encourage eligible voters among our members and
the communities we serve to participate in the November 2024 general election by requesting an
absentee ballot. Due to SB 1, however, The Alabama NAACP has directed all local units to not
assist with the absentee application process, due to SB 1’s prohibitions. We do not plan to assist
voters with the absentee application process for the November 2024 general election, curtailing
this expression of our pro-absentee voting message. We will no longer provide absentee
applications or assistance in nursing homes, jails, and colleges and universities or at town halls.
17. Instead, as a result of SB 1, the Alabama NAACP must expend time and resources to try
to understand what conduct is and is not prohibited under the law and provide local units and
5
members with guidance regarding the same. Because the Alabama NAACP’s voter outreach work
is conducted by volunteers, the Alabama NAACP also will need to devote considerably more time
and resources into ensuring that our volunteers going forward receive training regarding SB 1’s
prohibitions to ensure that they do not risk committing a crime. We will need to produce new
training and materials for volunteers and produce new voter education materials. The burdens
caused by SB 1 also mean the Alabama NAACP will no longer be able to effectively engage in
our pro-absentee voting activities. We will be forced to divert resources away from absentee
application assistance and towards other forms of voter engagement communications aimed voter
education, voter registration, and getting out the vote on Election Day even though we know some
voters require absentee voting to participate. SB1 is a severe obstacle for our pro-absentee voting
message.
18. Through its vague terms, SB 1 criminalizes a broad swath of mission-related
communications and activities. Without defining “gift,” “payment,” or “third party,” SB 1’s
criminal penalties will severely curtail our get out the vote activities around absentee application
assistance. It is unclear if any of the following routine activities would constitute payment or gifts:
distributing tokens like t-shirts, buttons, and pens to volunteers who assist with absentee ballot
applications; disseminating branded voter education materials to volunteers who provide absentee
application assistance; providing volunteers with envelopes and stamps to be given to voters for
the purposes of mailing their application; or supplying water and snacks/food for volunteers at
events where absentee application assistance take place.
19. Further, it is unclear what kinds of absentee application assistance the Alabama NAACP
and our partners could provide because SB 1 does not define terms it uses like “prefill,”
“distribute,” or “submit.” The Alabama NAACP regularly assists voters who are elderly and have
6
a physical impairment or low literacy skills with completing their absentee ballot applications.
Under SB 1’s vague “prefilling” restriction, it appears we cannot input a voter’s information into
their absentee application, even when the information is copied from the state’s voter file and at
the direction of the voter. SB 1’s vague prohibition of “distributing” absentee ballot applications
suggests that the Alabama NAACP may be prohibited from sending a link to the application to our
members or voters who join our mailing list. For certain voters, especially those in nursing homes
or jails, SB 1 suggests that the Alabama NAACP may be unable to even place their application in
the mailbox, even if the voter has a physical impairment that makes it difficult or impossible for
them to deposit the application in the mail themselves.
20. SB 1 also appears to criminalize assistance from volunteers who belong to “third party”
organizations which might include organizations like the Alabama NAACP. This detrimentally
impacts voters who have relied on our volunteers for help in the absentee voting process. SB 1 will
deter our members and constituents from requesting assistance and volunteers from providing it.
For the disabled and low literacy voters who depend on our absentee application assistance, SB
1’s burdens are an extreme impediment to their ability to receive assistance with voting.
21. I fear that if voters who rely on the Alabama NAACP for assistance do not receive the
assistance they need, at least some of these voters will forego voting altogether. Voters have
expressed concern about not being able to receive the necessary assistance to vote absentee and
the deterrent effect SB 1 will have on them from voting absentee. Members and voters who depend
on our assistance have told me that they do not know how they will apply to vote absentee or vote
if they cannot receive assistance with their absentee applications.
7
22. As a result of SB 1, Alabama NAACP has been and will continue to be forced to severely
limit our absentee voting activities, including during the particularly critical period leading to the
November 5, 2024 general election.
Executed on May 2, 2024 in _____________, Alabama.
______________________________
Benard Simelton
8
2024 May-03 AM 09:52
U.S. DISTRICT COURT
N.D. OF ALABAMA

SOUTHERN DIVISION

THE NAACP, et al.,

v.

Defendants.
DECLARATION OF KATHY JONES

Pursuant to 28 U.S.C. § 1746, I, Kathy Jones, declare as follows:
1. I am the President of the League of Women Voters of Alabama and the League of
Women Voters of Alabama Education Fund (collectively “LWVAL” or the “League”). I have
served in this role since May 2021, and have been a member of the League since May 2017.
2. Plaintiffs League of Women Voters of Alabama and the League of Women Voters
of Alabama Education Fund, formed under Section 501(c)(4) and Section 501(c)(3) of the Internal
Revenue Code, respectively, are nonpartisan, nonprofit, grassroots organizations that seek to
encourage informed and active participation in government, work to increase understanding of
major public policy issues, and influence public policy through education and advocacy. LWVAL
is dedicated to encouraging its members and the people of Alabama to exercise their right to vote.
LWVAL was founded in 1920, created out of the Alabama Equal Suffrage Association.
3. LWVAL is a state chapter of the national League of Women Voters (“LWV”) which
1
was founded in 1920 as an outgrowth of the struggle to win voting rights for women and has more
than 500,000 members and supporters and is organized in more than 750 communities in all 50
states and the District of Columbia.
4. LWVAL consists of eight affiliated local Leagues statewide. LWVAL has
approximately 475 members across the state of Alabama. LWVAL’s members include voters who
are over 65 years old, who are disabled, and others who are students that may need or prefer
assistance with voting, including with completing their absentee ballot application.
5. As recently as the March 2024 primary elections, a part of the League’s
encouragement of voters to participate in the upcoming election included assisting voters in
applying for absentee ballot applications, including senior citizens who require assistance and
voters with disabilities.
6. For the year 2024 and beyond, LWVAL plans to continue encouraging eligible
Alabamians to vote and hopes to continue to do so by engaging in absentee ballot application
assistance on behalf of its members and the communities it serves across the state of Alabama.
LWVAL’s Mission and Viewpoints
7. LWVAL’s mission is to protect the right to vote for Alabama voters. We believe that
every Alabama voter should be able to effectively cast their ballot. We seek to encourage the
informed and active participation of citizens in Alabama government through participation in
public policy and voting. Our work builds on the history of the women’s suffrage movement, which
spurred the creation of the League of Women Voters. Since its founding, LWVAL has fought to
protect the rights of eligible voters and to expand access for those who have been left out of the
democratic process.
8. LWVAL comprises about 475 dues-paying members, many of whom volunteer in
2
Alabama communities to spread LWVAL’s pro-democratic engagement message and provide voter
services. LWVAL has no paid employees or staff involved with its operation, including its voter
services. Therefore, all the time that League members devote to the League and to voter services
is entirely voluntary.
9. LWVAL has eight affiliated local Leagues across the state of Alabama that make up
about 475 members statewide. All local Leagues have a voter services team that engages,
communicates with, and educates voters. This includes assisting Alabamians with the absentee
ballot process. LWVAL offers trainings to all its members, volunteers, and state partners to better
engage and educate Alabamians on civic participation, including assistance with absentee ballot
applications.
10. LWVAL believes that voter assistance is a vital component in expressing its belief
that all eligible voters should participate in the democratic process. To that end, LWVAL provides
regular training to its local League leaders, its members, its volunteers, and to its nonpartisan
partners to assist voters in getting registered, applying for an absentee ballot, and voting absentee.
11. LWVAL does this work as a part of its mission to protect the right to vote for
Alabama voters and considers absentee ballot application assistance to be an expression of those
core values. Likewise, LWVAL uses absentee ballot application assistance as a part of a larger
dialogue about a citizen’s voting plan and the importance of voter turnout. Voter services education
and direct services events are a means to associate with its members and the larger community,
often recruiting members in the process.
12. LWVAL members and volunteers do this work as a part of its mission to protect the
right to vote for Alabama voters, and LWVAL considers absentee ballot application assistance to
be an expression of those core values to the public.
3
LWVAL’s Absentee Ballot Application Activities
13. LWVAL hosts public civic education events to encourage civic participation and as
a central part of LWVAL’s voter services program. These events include discussion of absentee
voting and the provision of information and assistance with absentee ballot applications.
14. These events are hosted at various locations including nursing homes, college
campuses, libraries, music festivals, art festivals, food pantries, and other community events where
LWVAL members and volunteers can meet and speak with eligible Alabama voters. LWVAL’s
members and volunteers bring tents, tables, printers, printed absentee ballot applications, pens,
clipboards, papers, and any other supplies needed to further assist and educate voters to engage in
the democratic process. Specifically, LWVAL will bring printers and absentee ballot applications
to encourage and assist voters who would like to apply for an absentee ballot, and pens to help the
voter fill out the application. LWVAL members will inform voters about absentee voting in
Alabama and walk voters through the absentee ballot application section by section to ensure they
are completing the form accurately. LWVAL members and volunteers will serve as a witness for
voters submitting an absentee ballot application, if they sign with a mark. LWVAL will also make
a copy of voters’ ID to complete their absentee ballot application, if needed. LWVAL provide this
assistance and supplies at the organization’s expense.
15. The League’s assistance and education includes speaking with Alabamians to help
them determine if they are eligible to register to vote, help them navigate the voter registration
form, and help them apply for an absentee ballot application if the voter is eligible to vote absentee.
16. Often at these events, as part of promoting the League’s pro-voting message, the
League will often provide “I registered to vote” or “Alabama voter” stickers or bracelets which are
branded with the LWVAL logo, and express LWVAL’s message that voters have the right to vote
4
and should participate in our democracy. LWVAL provides these stickers and bracelets to
participating voters when they register to vote or apply for an absentee ballot application. LWVAL
and its local Leagues often provide “Future Voter” stickers to children attending the events.
17. To communicate the League’s pro-democratic engagement message, LWVAL
members and volunteers provide civic education and assist senior citizens who require assistance,
college students, voters with disabilities, residents in assisted living and nursing home facilities in
applying for and voting by absentee ballot. LWVAL is currently developing a strategy to better
communicate with, assist, and provide civic education to voters in rural areas, including regarding
absentee ballot applications.
18. Among other assistance, LWVAL members and volunteers print absentee ballot
applications for voters and provide detailed instructions on how to fill out the applications. Because
the state of Alabama does not allow voters to complete an absentee ballot application online,
LWVAL provides printed applications for voters’ respective county to convey their pro-absentee
voting message and ensure voters have the tools they need to act on the League’s message and
apply for an absentee ballot if they so desire.
19. LWVAL believes that its role in providing these printed applications and detailed
instructions is critical to voters because LWVAL members and volunteers are able to provide help
and assistance to voters when the voters needs it, including when county Absentee Election
Manager offices are closed. LWVAL voter services are not limited to weekdays or business hours.
Many voters are unable to visit their county’s Absentee Election Manager’s office during their
operating hours, so LWVAL members and volunteers meet voters where they are and host voter
education events weeknights and on the weekends to better assist and educate voters on the
absentee application process. LWVAL members and volunteers also provide envelopes and
5
postage to submit the application, make photocopies of the voters’ photo IDs, and spend time with
the voter to ensure any errors are corrected.
20. LWVAL members and volunteers go directly to Alabama college campuses and host
voter registration drives, where its members and volunteers communicate the League’s pro-voting
message and also assist college students in completing absentee ballot applications. To do this
work, LWVAL partners with school administrators, student organizations, and other civic
organizations that share the League’s goal of encouraging democratic engagement, including
Greater Birmingham Ministries, NAACP Alabama, and ADAP to provide voter education,
including information about voter registration and absentee voting. Many Alabama college
students are eligible to vote absentee but lack the requisite information to apply for an absentee
ballot application. LWVAL partners with student organizations to provide accurate absentee voting
information to those students who otherwise would not have known they were eligible to vote
absentee or known how to apply for an absentee ballot.
21. To communicate and share the Leagues’ pro-democracy message at voter
registration drives, LWVAL members and volunteers often give away stickers or pens to student
voters when assisting them in completing an absentee ballot application. The stickers include
messaging about the importance of voting, such as “I vote because I care.”
22. LWVAL believes that having its members and volunteers go directly into nursing
homes to provide civic education and assistance is the most effective means of communicating its
pro-voting message to these voters, and in many cases is necessary where voters are unable to
come and go into the nursing homes as they please. LWVAL’s providing voter services in nursing
homes is critical to fulfilling its vision of ensuring democracy works for everyone and furthering
the League’s pro-voting message. Because these voters often cannot make it to their polling place
6
on election day, LWVAL’s work to communicate with voters who are marginalized, homebound,
incapacitated, or that otherwise require assistance and ensure they can participate in the democratic
process is crucial to those voters’ ability to cast a ballot.
23. To further reach voters in Alabama, LWVAL manages the Alabama section of
VOTE411.org, a webpage dedicated to providing essential information to ensure all Alabamians
are informed about how to vote, including voting absentee. LWVAL will often refer voters to this
website for further information on how to apply for an absentee ballot in Alabama. This webpage
links voters to the Secretary of State’s website to direct voters to apply for an absentee ballot.
24. We believe that without our encouragement and assistance, many voters would be
unable to apply for an absentee ballot. Often, LWVAL assists voters over the age of 65 who are
hearing or vision impaired. LWVAL often serves as the main resource for these voters to turn to
for assistance with the absentee ballot application. It can also be difficult for college students to
find and complete an absentee ballot application. Because some students do not receive mail
directly at their dorm, students struggle with completing the form using their correct address.
Through partnering with student organizations and tabling at college campuses, LWVAL serves as
a critical proponent of democratic engagement by college students and resource for students
needing assistance in finding and completing an absentee ballot application.
25. Through LWVAL’s registration tables in the community, members have observed
voters making mistakes on registration forms and absentee applications which could result in a
denial and ultimately in position unable to participate in the electoral process. LWVAL’s
communication with those voters can often result in those voter mistakes being corrected so that
the voter is properly registered and has their absentee application successfully processed. However,
LWVAL believes that many voters they serve, including senior citizens that require assistance,
7
voters with disabilities, and college students would be unable to submit their absentee ballot
application without LWVAL’s assistance.
SB1’s Effect on LWVAL’s Voter Assistance Activities
26. LWVAL wants to continue effectively expressing its pro-absentee voting message
by assisting voters in applying for and voting absentee, especially senior citizens who require
assistance, voters with disabilities, and college students, but SB 1 threatens LWVAL’s ability to do
so. LWVAL is currently developing a voter service program targeting rural voters, but SB1 creates
much uncertainty as to what forms of absentee ballot application communication and assistance
are lawful, and what services are unlawful.
27. As such, LWVAL has had to severely limit how the League is communicating its
pro-absentee voting message. LWVAL has informed all local Leagues that it will provide formal
guidance and training regarding absentee ballot application assistance. Because the criminal
penalties are severe, LWVAL plans to provide their members and local Leagues with guidance
before they continue communicating about and assisting voters with their absentee ballot
applications. LWVAL partner organizations are also awaiting advice from LWVAL on what types
of communication and assistance are lawful.
28. LWVAL and our volunteers and members feel threatened by the uncertainty of SB
1’s provisions and fears that League members and volunteers will face felony prosecution and
conviction of a felony if they continue to help voters with their absentee ballot applications.
29. LWVAL plans to determine what communication is lawful, then conduct training
sessions solely focused on the impact of SB 1 to ensure its members and volunteers are still able
to speak with and assist voters lawfully. LWVAL plans to conduct additional training concerning
the absentee ballot process, including providing educational sessions that involve registrars and
8
circuit clerks.
30. LWVAL is an organization comprised entirely of volunteers and its resources are
finite. In order to understand what communication and assistance is lawful, LWVAL members and
volunteers are diverting time and money that they would otherwise have spent preparing for other
additional voter engagement activities that furthered the League’s pro- voting message in the
upcoming elections. LWVAL members and volunteers are having more meetings to discuss what
voter communications and services are lawful, rather than providing those voter services and
furthering the League’s pro-democracy messaging. LWVAL are also meeting with other
organizations that share the League’s goal of encouraging democratic engagement to create a
mobilization strategy for those unable to get to the polls on election day, and to ensure voters can
vote absentee in person at their absentee managers office. This mobilization strategy includes
working with other community organizations to coordinate rides to the polls for those voters that
cannot make it to their polling place on election day. LWVAL are also developing instructional
tools for voters to navigate the absentee ballot application.
31. Furthermore, because of the potential criminalization of absentee ballot application
communication and assistance, LWVAL plans to divert resources traditionally used for that work
to other forms of voter engagement such as increased efforts towards encouraging in person
absentee voting, in person voting on election day, and assisting Alabamians with voter registration.
This will decrease the overall number of eligible Alabamians that LWVAL is able to communicate
with and assist, as such efforts are time and resource intensive and in person voting is not possible
for every Alabama voter.
32. LWVAL has had to reduce the total quantum of its speech about the importance of
voting and the availability of voting absentee as a result of SB 1. I fear LWVAL will reach fewer
9
voters because of SB 1, and therefore, fewer voters will be able apply for and vote absentee, or
vote at all, as a result.
Executed on May 1, 2024 in Huntsville, Alabama.
______________________________
Kathy Jones
10
2024 May-03 AM 09:52
U.S. DISTRICT COURT
N.D. OF ALABAMA

SOUTHERN DIVISION

THE NAACP, et al.,

v.

Defendants.
DECLARATION OF NANCY ANDERSON, ESQ.

Pursuant to 28 U.S.C. § 1746, I, Nancy Anderson, Esq., declare as follows:
1. My name is Nancy Anderson, and I am the Acting Executive Director of Plaintiff Alabama
Disabilities Advocacy Program (“ADAP”), Alabama’s federally funded Protection and Advocacy
(“P&A”) agency. I was admitted to the Alabama Bar in 2000. I have been employed by ADAP
since 2000 and have served in various positions at the agency in intervening years. I am currently
the Interim Executive Director of ADAP and have served in this role since February 2024 upon
the retirement of the agency’s prior director.
2. ADAP is part of a nationwide system of P&A agencies which was created by the federal
government in 1974. The mission of the P&A system is to provide legal advocacy services to
protect and promote the civil rights, well-being, and equality of opportunity for individuals with
disabilities, including in voting. ADAP is the designated P&A for the State of Alabama. As such,
ADAP is accountable to members of the disability community and is authorized under federal law
to represent the interests of Alabamans with disabilities. All individuals with disabilities in
Alabama are constituents of ADAP.
3. ADAP’s advocacy work is funded primarily by nine federal grants, which are dedicated to
serving a particular community of persons with disabilities (e.g., persons with developmental
disabilities) or a particular issue area (e.g., access to assistive technology). ADAP also receives a
small amount of funding via private grants. In my role as Interim Executive Director, I am the
designated Principal Investigator (“PI”) for each of the grants which ADAP receives.
4. As PI, I am responsible for ensuring that ADAP complies with the terms and conditions of
each of its grants. This includes, but is not limited to, ensuring that each grant’s goals and priorities
are met and that ADAP meets regular financial and grant outcome reporting obligations.
5. One of the federal grants which ADAP receives is ADAP’s Protection and Advocacy for
Voting Accessibility (“PAVA”) grant. The PAVA grant program was created under Section 291
of the Help America Vote Act (“HAVA”), which was signed into law in October 2002. The PAVA
grant is administered at the federal level by the Administration for Community Living (“ACL”).
6. ADAP receives a substantial amount of federal funding under its PAVA program to
perform its obligations under the grant. The purpose of the PAVA grant is to provide services to
individuals with disabilities within the state, and to advocate for the full participation of individuals
with disabilities in the electoral process.
7. In addition to serving as the PI on the PAVA grant, I also serve as the direct supervisor of
Nicole Watkins, ADAP’s Voting Rights Advocate. Approximately 80% of Ms. Watkin’s work
involves voting rights advocacy under the PAVA grant. Other ADAP staff integrate PAVA voting
rights advocacy in the normal course of their advocacy activities though to a much lesser extent
than Ms. Watkins.

8. Under the terms of HAVA, ADAP must use PAVA funds to promote and participate in
activities focused on ensuring the full participation in the electoral process for individuals with
disabilities, including registering to vote, casting a vote, and accessing polling places. The
activities in which ADAP engages under the PAVA grant include encouraging individuals with
disabilities to vote; providing individuals with education regarding voter registration; providing
individuals with disabilities the opportunity to register to vote; providing information to people
with disabilities about their voting rights; and providing individuals with disabilities with help in
accessing the voting process.
9. As absentee voting is the only practical way for many individuals with disabilities to fully
participate in the election process – the key goal of the PAVA grant – ADAP assists individuals with
disabilities in accessing the absentee voting process. This includes informing people about and
helping them to understand absentee voting rules. A part of conveying this message and assistance
includes helping the individual to obtain and fill out an absentee ballot application, whether online
or on paper, and assisting them in delivering the absentee ballot application. Through its work,
ADAP seeks to convey the message that voting should be accessible to all, regardless of disability
status.
10. As I noted above, as PI, I am responsible for ensuring that ADAP complies with the terms
and conditions of each of its grants. This includes, but is not limited to, ensuring that each grant's
goals and priorities are met and that ADAP meets regular financial and grant outcome reporting
obligations. All ACL grantees must annually report activities and outcomes in federal reports. They
are also subject to cyclical remote and onsite audits to ensure compliance with the terms of the
grants.
11. As enacted, Alabama SB 1 criminalizes conventional but vital absentee voter
communication and assistance activities which ADAP undertakes to fulfill its obligations under the
PAVA grant to help individuals with disabilities participate fully in the election process.
12. SB 1 will force ADAP to forego this key pro-voting and voter access advocacy to ensure that
its staff are not subject to significant criminal penalties for simply doing their jobs. Setting aside
absentee ballot communications and assistance will gut a strategic activity ADAP undertakes to
fulfill its mandate under the PAVA grant to ensure full election participation.
13. Because HAVA precludes ADAP from using PAVA funds to engage in, initiate or
otherwise participate in any litigation related to election-related disability access, my efforts and
those of other ADAP staff related to this litigation are supported by non-PAVA funds.
Executed on April 29, 2024, in Tuscaloosa, Alabama.
______________________________
Nancy Anderson
2024 May-03 AM 09:52
U.S. DISTRICT COURT
N.D. OF ALABAMA

SOUTHERN DIVISION

THE NAACP, et al.,

v.

Defendants.
DECLARATION OF NICOLE WATKINS

Pursuant to 28 U.S.C. § 1746, I, Nicole Watkins, declare as follows:
1. My name is Nicole Watkins and I serve as the Senior Voting Rights Advocate and Outreach
Coordinator at Plaintiff Alabama Disabilities Advocacy Program (“ADAP”). I am a paid employee
of ADAP and I have worked at ADAP since March 2022.
2. My work at ADAP is divided into approximately 80% voting rights work (through the
mechanisms of HAVA, the Help America Vote Act), and 20% communications work. This
Declaration will focus on the voting rights aspect of my work, though there is by nature some
overlap between the two; training individuals often requires the creation of communications media
and using other tools at my disposal to create digestible and accessible content.
3. My PAVA (Protection and Advocacy for Voting Access) work includes, but is not limited
to, working with people with disabilities in the following ways:
• Polling site visits;

• Voter registration;
• Voter training;
• Residential and in-patient facility visits;
• Training employees of residential facilities on the voting process;
• Meeting with election officials to highlight and discuss accessibility issues;
• Attending statewide Voting Advisory Board meetings to present data and discuss
issues;
• Working with people with disabilities to assess their individual polling places for
potential access barriers;
• Training people with disabilities on available accommodations at the polls;
• Helping people with disabilities, both in facilities and in the community, to
understand the absentee ballot process; and
• Assisting voters in the application process for an absentee ballot.
4. People with disabilities who need assistance with the absentee ballot process, including
applications, require assistance for several reasons. The voter may be blind, so they would
need assistance filling out their application or ballot since Alabama does not provide these
materials in Braille. They may have mobility issues or dexterity issues and struggle to fill out
an application or a ballot. Many people with different types of neurodegenerative disabilities
struggle to write. Many people with different varieties of intellectual disabilities need
assistance reading through the application or ballot and processing the information,
particularly since most of the information is not available in plain language format, can require
a high level of reading and writing comprehension, and can be overwhelming for people with
certain kinds of sensory, intellectual, or mental disabilities.
5. Absentee applications require multiple steps, generally including accessing the
application either online or in hard copy, reading, understanding, and completing the fields
on the form, creating a hard copy of photo identification for inclusion with their application,
and returning the completed application back to the Absentee Election Manager either in
person or by mail. The assistance I provide with the application process, including when I
visit residents at residential facilities, can take several forms. The most basic would involve
helping a person who cannot easily read the absentee application. In these instances, I would
2
read to the person what each portion of the application asks of the voter and then fill in their
responses. Other forms of assistance include walking the voter through the numerous steps
involved in applying for an absentee ballot, filling out the application, and eventually, the
receipt of the absentee ballot and the subsequent steps for sending in the ballot and affidavit
appropriately.
6. Those living in residential and in-patient facilities will also need assistance to mail
their applications and ballot and typically require help from staff to access the internet. In
most facilities, the staff would be the people mailing the resident’s application or ballot.
People in facilities often do not send their own mail or have their own mailbox. Some do not have
ready or easy access to envelopes or stamps.
7. As I have alluded to above, I also provide voter education and training at these
facilities. In 2022, I gave a presentation to the Alabama Department of Mental Health
(“ADMH”) at the Alabama Institute for Recovery (“AIR”) conference, together with ADAP’s
Voting Rights Fellow at the time, Maddy Ard. In this presentation, we trained employees on
the absentee process specifically since the residents in the facilities would be voting absentee.
Employees attending worked at various ADMH facilities, including Taylor Hardin and Bryce
Hospitals.
8. I have also provided extensive training to county election officials, particularly in
Mobile County in 2022 and 2023. Much of that training relates more specifically to polling
place requirements under the Americans with Disabilities Act but has also included training
on the absentee process and the state laws surrounding the procedures of voting absentee.
3
9. Most of my training efforts and work with voters focuses on the absentee process,
simply because most of the people we serve (individuals with disabilities) vote absentee for
several reasons, including but not limited to:
• Limited or no access to transportation;

• Medical conditions that confine people to their homes (what we would formerly
describe as “homebound” individuals);
• Individuals with mobility disabilities who struggle to walk and navigate polling
places;
• Individuals with disabilities who are unable to drive and have limited family or care
worker support;
• Individuals with disabilities living in residential facilities or mental health
hospitals; and/or
• Individuals with disabilities in group homes.
10. I would estimate that around 70% of my work focuses on the absentee voting process,
including as recently as the March 2024 primary elections in the state. Evaluating data from
the past several years, I have trained hundreds of voters on the absentee voting process and
personally assisted scores of individuals with their absentee applications and ballots. I have
referred multiple people living in residential facilities or mental health hospitals to voting
rights attorneys when it appears their rights have been violated. Together with other ADAP staff
members, I have trained employees of two state hospitals (Bryce Hospital and Taylor Hardin)
on the absentee ballot process and how to assist residents with voting.
11. ADAP would very much like to continue its federally mandated work to assist disabled
voters with absentee ballot applications in Alabama for the upcoming November 2024
election and beyond. But since the passage of Alabama Senate Bill 1 (“SB 1”), my
understanding of ADAP and its employees’ (including myself) personal criminal liability
under this statute includes the fact that I may be able to assist a voter but may be subject to
the misdemeanor provisions of the statute – either for placing the ballot in the mailbox for the
voter and/or depending on what the legal definitions of “submit” and “prefilling” involves. I
4
have assisted voters by printing out applications (using our office printers) for absentee ballots
and then walking voters through the process of mailing the applications. I have also used my
own internet access and/or ADAP internet access to assist voters with the absentee application
process. While I understand that the current statute is not yet being enforced, in the future,
this would also leave ADAP and its staff legally vulnerable to felony liability depending on
how “payment” and “gifts” as well as the word “distribute” are legally defined under the
statute. I understand that, as an employee of ADAP, the mere fact of receiving a salary could
subject me to criminal liability if I were to continue helping disabled voters with their absentee
applications. I am extremely fearful of these criminal penalties and they are likely to foreclose
ADAP’s ability to engage in absentee ballot assistance for disabled and blind voters who
depend on it.
12. I have received questions about SB 1 from a wide variety of groups, nonprofit
organizations, and individuals with disabilities since its passage. People have asked for
guidance specifically on voter assistance, including many parents of older children with
disabilities who are of voting age. Caregivers, both familial and professional, have asked for
guidance on how to assist a disabled client with the absentee application and ballot process.
There is significantly heightened anxiety around the bill and concern about the potential for
breaking the law and what consequences these individuals might face.
13. Also since the passage of SB 1, a large portion of my professional time has been
devoted solely to SB 1 and questions around the new law. I have been fielding emails and
calls from concerned individuals in the disability community for several weeks now. When I
have trained disabled individuals in the community since the passage of the bill, I always
5
receive several questions about the bill and concerns from community members about what
the law means for either themselves or their disabled loved ones.
14. Under SB 1, it appears ADAP is unable to provide voters with the kinds of assistance
in the absentee ballot process outlined elsewhere in this declaration and will not be able to do
so while the law is in place. I, as the Senior Voting Rights Advocate, will personally be
violating the terms of my professional role and the required deliverables for my federal
funding stream under the Help America Vote Act. More significantly, people with disabilities
in Alabama will lose access to secure, nonpartisan, and federally funded assistance with the
voting process. People with disabilities in Alabama (and throughout the United States)
already vote in much more limited numbers than the non-disabled population. Limiting
assistance with the voting process available to these individuals with disabilities will mean
that many people with disabilities will be unable to vote at all.
Executed on April 29, 2024 in Birmingham, Alabama.
______________________________
Nicole DeBuono Watkins

Ballot Harvesting Injunction

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Ballot Harvesting Injunction

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Case 2:24-cv-00420-RDP Document 34 Filed 05/03/24 Page 1 of 5 FILED

2024 May-03 AM 09:52

IN THE UNITED STATES DISTRICT COURT

ALABAMA STATE CONFERENCE OF

Plaintiffs, Civil Action No. 24 Civ. 420

PLAINTIFFS’ MOTION FOR PRELIMINARY INJUNCTION

Greater Birmingham Ministries, and Alabama Disabilities Advocacy Program (collectively,

“Plaintiffs”) respectfully move for the following preliminary injunctive relief:

successors, from implementing or enforcing the following Challenged Provisions of Alabama

Senate Bill 1, Act No. 2024-33 (“SB 1”):1

a. Payment Provisions: SB 1 makes it “unlawful for a third party to knowingly

1See 2024 Alabama Laws Act 2024-33 (S.B. 1),

receive a payment,” or “knowingly pay . . . a third party,” to “distribute, order,

request, collect, prefill, complete, obtain, or deliver a voter’s absentee ballot

application.” § 17-11-4(d)(1)-(d)(2). These provisions carry a Class B or C felony

“pay” such assistor). Id.

b. Gift Provisions: SB 1 makes it “unlawful for a third party to knowingly receive

. . . a gift,” or “knowingly . . . provide a gift,” to a “third party” to “distribute,

order, request, collect, prefill, complete, obtain, or deliver a voter’s absentee

ballot application.” § 17-11-4(d)(1)-(d)(2). These provisions carry a Class B or C

those who “provide a gift” to such assistor). Id.

c. Prefilling Restriction: SB 1 makes it “unlawful for any person to knowingly

name or any other information required on the application form.” § 17-11-4(b)(2).

This provision carries a Class A misdemeanor penalty. SB 1 § 2.

d. Submission Restriction: SB 1 makes it “unlawful for an individual to submit a

treatment within five days before an election. § 17-11-4(c)(2). The application

Absentee Election Manager or placing one’s own application in the

mail/commercial carrier. Id. This provision carries a Class A misdemeanor

successors, from issuing any instructions or communications—whether public-facing or

DATED: May 2, 2024

/s/ Alison Mollman /s/ Anuja D. Thatte

*Admitted pro hac vice

Counsel for Plaintiffs

DATED: May 2, 2024

/s/ Laurel Hattix

Counsel for Plaintiffs

IN THE UNITED STATES DISTRICT COURT

ALABAMA STATE CONFERENCE OF

Plaintiffs, Civil Action No. 24 Civ. 420

PLAINTIFFS’ MEMORANDUM OF LAW IN SUPPORT OF MOTION FOR

V. Plaintiffs Will Suffer Irreparable Harm Absent Preliminary Relief ..................................33

Ala. Code § 13A-11-241 .................................................................................................................5

serious ongoing harms.

I. Alabama’s Multi-Step Process for Applying to Vote Absentee.

Manager either in person or by mail/commercial carrier. 9 Absentee applications must be received

more than 42 days apart.

II. SB 1’s Enactment and the Challenged Provisions.

• Payment Provisions: SB 1 makes it “unlawful for a third party to knowingly receive a

payment,” or “knowingly pay . . . a third party,” to “distribute, order, request, collect,

prefill, complete, obtain, or deliver a voter’s absentee ballot application.” § 17-11-4(d)(1)-

or “knowingly . . . provide a gift,” to a “third party” to “distribute, order, request, collect,

prefill, complete, obtain, or deliver a voter’s absentee ballot application.” § 17-11-4(d)(1)-

• Prefilling Restriction: SB 1 makes it “unlawful for any person to knowingly distribute an

information required on the application form.” § 17-11-4(b)(2). This provision carries a

Class A misdemeanor penalty. SB 1 § 2.

• Submission Restriction: SB 1 makes it “unlawful for an individual to submit a completed

before an election. § 17-11-4(c)(2). The application “may be submitted” by personally

In Alabama, Class B felonies carry a sentence of up to 20 years, 12 Class C felonies carry a

including no definitions for “payment,” “gift,” “third-party,” “prefill,” “distribute,” or “submit.”

or agent of the voter’s union.” § 17-11-4(e).

III. Proffered Justification for SB 1.

Committee that “this bill is meant for ballot harvesting.” 16

specifically. 19 During legislative proceedings, members of the public, including Plaintiffs,

would severely chill voter assistance across the state. 20