IN the UNITED STATES DISTRICT COURT for the MIDDLE DISTRICT of NORTH CAROLINA LEAGUE of WOMEN VOTERS of NORTH CAROLINA, Et Al
IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF NORTH CAROLINA LEAGUE OF WOMEN VOTERS OF NORTH CAROLINA, et al., Plaintiffs, Civil Action No. 1:13-CV-660 RULE 26(A)(2)(B) EXPERT v. REPORT AND DECLARATION OF THEODORE T. ALLEN, PhD THE STATE OF NORTH CAROLINA, et al., Defendants. I. INTRODUCTION 1. I have been retained by Plaintiffs’ Counsel as an expert witness in the above- captioned case. Plaintiffs’ Counsel requested that I offer my opinions as to: (1) whether HB 589, if it had been in effect in the most recent general election in North Carolina, would have caused longer lines at polling places and longer average waiting times to vote; and (2) the possible effect of such waiting times, if any, on voter turnout. As explained below, I conclude that eliminating seven days of early voting before the 2012 election would have caused waiting times to vote on Election Day in North Carolina to increase substantially, from a low-end estimate of an average of 27 minutes, to a worst-case scenario of an average of 180 minutes of waiting. Moreover, I further conclude that, as a result of longer lines, a significant number of voters would have been deterred from voting on Election Day in 2012 (with a conservative estimate of several thousand). Finally, I conclude that, barring some additional changes to the law or to the resources allocated to polling places, HB 589’s reductions to early voting are likely to result in longer average waiting times to vote in future elections.
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