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Arizona Democratic Party Democratic Arizona Plaintiff for Attorneys [email protected]: 602.798.5595 Facsimile: 602.798.5400 Telephone: 85004 ArizonaPhoenix, Street, Washington1 East BALLARD SPAHRLLP 032304) No. (BarArellano A.Daniel 032901) No. (BarHerrera Roy [email protected]: Facsimile: 602.351.8000 Telephone: 85012 ArizonaPhoenix, 2000 SuiteCentral Avenue,North2901 LLP COIE PERKINS 034853) No. (BarBeaudoin J. Kristine 032567) No. (BarGonskiR. Sarah 028107) No. (BarGray H. John role, up Democratselect to effort coordinated statewide Party’s DemocraticArizonathe is which Arizona, forMission and declare as follows:declareas and
as Suzanne Sainz rzn Dmcai Party DemocraticArizona
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1. I,havepersonal Michael knowledge of Norton, inthethisfactscontained declaration v. [email protected] [email protected] [email protected] [email protected]
personal 602.648.7000 a the am I i h in , ony RecorderCounty
er nweg o h rzn Dmcai Prys fot to effortsensure Party’s DemocraticArizona oftheknowledge Defendant Plaintiff
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SANTA CRUZSANTA
in the November 2020 election. Through this this Throughelection. 2020 November the in (Assigned to Hon. to (Assigned SPECIAL ACTIO FOR CAUSETO STATUTORYSHOW ORDER FOR APPLICATION NORTONINSUPPORT OF DECLARATION OFMICHAEL No.
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lcin teAioa eortc at etawitn ulc eod eus toa sent public records Partyrequest the Democraticelection,writtenArizona i 30,000 general election 2020 Novemberthe for curing require may statewide more orballots eortc at ooti pbi eeto records. publicelectionobtainto Party Democratic ballots information from county counted. andare StatesSenate, forUnitedPresidency the dedincludingthe candidates, Party Democratic also is Party Democratic Arizona the mission, itsadvanceTo Senate. States Unitedtheand States Unitedthe of Presidentthe of offices the to includingArizona,ofState the throughout officepublic to Party Democratic counted by enfranchised cu can they how about voters to information accurate provide to carefully work Volunteers a and onstepsthethendeficiency, informationvoterprovide tocan take the curedeficiency. thems identifyclearly themprovidewith about informationhowto cure their ballots to make sure they are counted. Recordthe by identified
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eter ballots.theirre niiain of anticipation mail mail ht county’sthat
6. 5. 2. 3. 4. whose ballots have been identified as deficient is by obtaining a list of those voters voters ofthose a list byobtaining is deficient as identified been have ballots whose
l iaey eetd o eiiny ihu frhr cin yte voterthe by action further withoutdeficiency a for rejected ultimately are counted in the November 2020 election and related efforts by the Arizona Arizona the by efforts related and election 2020 November the in counted are rworcie al ballots. earlyreceivewhoor
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teAioa eortc at cnat vtr whose voters contacts Party DemocraticArizona the , otePry eoeeeto day. election beforetoParty the s srie o its to service a as ae nnmes rm rvos elections, previous fromnumberson Based votersto out reach can Party Democratic Arizona the way only The h Aioa eortc at i dedicate is Party Democratic Arizona The The Arizona Democratic Party has many members and constituents who vote vote who andconstituents membershas Partymany Democratic ArizonaThe Specifically, volunteers from the Arizona Democratic Party call voters, voters, call Party Democratic Arizona the from volunteers Specifically,
the Recorder. le, ask the ifhasvoterawarealready beenof madethecure need to elves,
oetal lre ubr of number large potentially er as potentially deficient to inform them of the deficiency and to to and deficiencythe of them inform to deficientpotentially as er
ery vr cut i Aioa a agree has Arizona in county every Nearly ebr ad constituents and members
As part of its strategy to ensure all Arizona votes are are votes allArizona ensure to strategy itsofpart As - 2
icated to ensuring that all ballots cast for for cast ballots all that ensuring to icated -
deficient d to electing candidates of the the of candidates electing to d siae ht pad of upward thatestimate I
o ensureto ballots in this year’s general general year’s this in ballots mail mail
that d to produce this this produce to d ballots have been been haveballots
they
the Recorder theRecorder .
Therefore , , Therefore are fully fully are in each each in 6 , with with , 0 ,000 ,000
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records request is attached to this declaration as Exhibit as this declaration to attached isrequest records 2020. 12, October of the during ballots,week early beginis completedRecorderto receivingexpectedthebefore on their cure to timeline.a short need onballots may who voters Arizona the also but Party, Democratic Arizona the and theonlyRecorder onnot burden the reducing thereby election, the during basisrolling t eus o hs ieie ogv te eodr ufcet oie f t rqet and request its of notice sufficient Recorder the give to timeline this on request things: would not be producing the requested thebe producing not would October hm bu their aboutthem and for data the needed Party the whatexplained and office Recorder’sthe at staff withspoke Ex list list
hat thehatreceivesArizona Party itsrequested Democraticlist of . or aboutor well 1 also .
8. 7. 9. 10.
16, 2020. T 16, 2020. before
that it needed the data on a rolling basis in advance of the election, starting around starting around theelection, of inadvance basis ona rollingdata itthe neededthat
Tuesday, September 1, 2020, 1, SeptemberTuesday, The The records public its withRecorder the provided Party Democratic ArizonaThe n Septem On person. in voting if ballots provisional or regular conditional including defect, other or signaturemismatched or missing a has ballot whose defect, voter any for contacted, ballottimes of number 5) 2) contacted, voter, of name 3) 1) indicating: logs other or sheets control completion, to comes period cure the before and dispositionfinal thebefore both processed, areballots As The Arizona Democratic Party will not have time to contact voters to inform inform votersto to contact time have not will Party Democratic ArizonaThe lcin Day Election
ehd f conta of method deficient rte pbi records publicwritten he Recorderhe
tu ad orc cp o te rzn D Arizona the of copy correct and true A e 2, 2020, 23, ber
ballots and ho and ballots
, starting on or before October 16, 2020 Octoberbefore onor starting , s office’s ct by recorder/staff, 4) time(s)/date(s) time(s)/date(s) 4) recorder/staff, by ct al ballotmail ersnaie o the of representatives ocr te i we if themcure to w informed
well in advance of the election and over a month a month over and election ofthe advance inwell eus t te Recorder the to request - 3 -
data h rzn Dmcai Party DemocratictheArizona .
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deficient do not Arizona Democratic Party Party DemocraticArizona emocratic Party’s public public Party’s emocratic . sought receive the requested requested thereceive
alt onballots a regular, , among other other among ,
ht the that to ensure ensure it it
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election. 2020 the inNovember count ballotsthattheir constitue and itsmembers eligiblevoters,includingassist toopportunity starting basis rolling a on oflist
the potentiallythe contact to time nothavewill Party Democratic ArizonaThe 10,2020. November Tuesday, person ballots theircuretohow of them inform andvoters Day. Election
— deficient XCTD this EXECUTED 13. 11. I 12.
elr udr eat o ejr ta h oeon i re andcorrect. is true foregoing thatthe perjury of penalty underdeclare nes ercie h it oflist the receive we unless
If the Arizona Democratic Party is not provided the records it has requested requested hasit records the provided not is Party DemocraticArizona theIf First, the deadline to cure ballots with missing signatures is 7:00pm on on 7:00pm is signatures missing with ballots cure to deadline the First, Second,t
T numerous numerous ballots e rzn Dmcai Pry il ae eo opp zero have will Party Democratic Arizona he he hs ot andthis month 12th
oes ih imthd intrs f it if signatures mismatched withvoters deadline to n r eoe coe 1, 2020 16, October before or on
day of October, 2020. ofOctober, day cur deficient
before the November thebefore e
alt wt msace signatu withballots mismatched - 4
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alt wl bfr Eeto Day. Election before wellballots ihe Norton Michael ______—
which can typically only be donein be only cantypically which
10 cure deadline10 cure , it will be deprived of the the of deprived be will it ,
does not receive a rolling a rolling receivenotdoes ortunity to contact these these contact to ortunity nts, in making sure inmaking sure nts, res is 5:00pm on is on 5:00pm res .
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