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[Counsel Listed on Inside Cover] SUPREME COURT of WISCONSIN No. 2020AP001971 DONALD J. TRUMP, Et Al., Petitioners, V. ANTHONY S

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[Counsel Listed on Inside Cover] SUPREME COURT of WISCONSIN No. 2020AP001971 DONALD J. TRUMP, Et Al., Petitioners, V. ANTHONY S SUPREME COURT OF WISCONSIN No. 2020AP001971 DONALD J. TRUMP, et al., Petitioners, v. ANTHONY S. EVERS, Governor of Wisconsin in his official capacity, et al., Respondents. Original Action in the Wisconsin Supreme Court RESPONSE OF PROPOSED RESPONDENT-INTERVENORS Seth P. Waxman* Charles G. Curtis, Jr. WILMER CUTLER PICKERING SBN 1013075 HALE AND DORR LLP Sopen B. Shah 1875 Pennsylvania Ave., NW Washington, DC 20006 SBN 1105013 (202) 663-6000 Will M. Conley [email protected] SBN 1104680 PERKINS COIE LLP One East Main St., Suite 201 Madison, WI 53703 [Counsel listed on inside cover] (608) 663-7460 [email protected] [email protected] [email protected] David S. Lesser* Jamie Dycus* Marc E. Elias* WILMER CUTLER PICKERING John Devaney* HALE AND DORR LLP Zachary J. Newkirk* 7 World Trade Center PERKINS COIE LLP 250 Greenwich Street 700 Thirteenth St., N.W., New York, NY 10007 (212) 230-8800 Suite 800 [email protected] Washington, D.C. 20005 [email protected] (202) 654-6200 [email protected] [email protected] [email protected] Matthew W. O’Neill SBN 1019269 FOX, O’NEILL & SHANNON, S.C. 622 North Water Street, Suite 500 Milwaukee, WI 53202 (414) 273-3939 [email protected] Counsel for Proposed Intervenor-Respondent *Pro hac vice applications forthcoming TABLE OF CONTENTS Page 1. In Person Absentee Application Brief ............................................. App. 1 2. Declaration of Megan Spicer ......................................................... App. 10 3. Declaration of Steven Hesse ......................................................... App. 13 4. Declaration of John Chick ............................................................. App. 15 5. Declaration of Gordon Case Stiglbauer ........................................ App. 17 6. Declaration of Jenny Aicher .......................................................... App. 19 7. Declaration of Milady Ramos ....................................................... App. 21 8. Declaration of Sara Vondracheck ................................................. App. 23 9. Declaration of Sinclair Johnston ................................................... App. 25 10. Declaration of Steven Robertson ................................................... App. 27 11. Declaration of Gregory J. Mueler ................................................. App. 29 12. Declaration of Kim Koch ............................................................... App.30 13. Declaration of Kristen Nelson ....................................................... App. 32 14. Declaration of Laurel Heebsh ....................................................... App. 34 15. Declaration of Lucy Koch ............................................................. App. 36 16. Declaration of Tim Sulik ............................................................... App. 38 17. No Right to Review Applications / Access to Absentee Ballot Brief .................................................................................... App. 40 18. Witness Address / "Red Ink" Brief................................................ App. 43 19. Indefinite Confinement Brief ........................................................ App. 55 TABLE OF CONTENTS (Continued) Page 20. Brief on Democracy in the Park .................................................... App. 65 21. Declaration of Dante Katz Andrade .............................................. App. 72 22. Affidavit of Francesca Hong ......................................................... App. 74 23. Affidavit of Carrie Kruse .............................................................. App. 77 24. Affidavit of Heather Pape.............................................................. App. 80 25. Affidavit of Kelda Roys ................................................................ App. 83 26. Affidavit of Jaala Spiro ................................................................. App. 86 27. Affidavit of Robert Streiffer .......................................................... App. 88 28. Affidavit of Michael Martin Walsh ............................................... App. 90 29. Zimmerman Affidavit of Laura Zimmerman ................................ App. 92 30. WEC Memo re: Recount ............................................................... App. 94 31. Affidavit of Kevin J. Kennedy .................................................... App. 101 32. Final Report: The Examination of Early Voting in Wisconsin .................................................................................... App. 105 33. Affidavit of Steven Hesse............................................................ App. 159 34. Affidavit of Devin Remiker ........................................................ App. 161 35. Affidavit of Amy Ullrich ............................................................. App. 168 36. Affidavit of Shannon A. Allen .................................................... App. 172 37. Affidavit of Catherine Streiffer ................................................... App. 176 38. Affidavit of Douglas M. Poland .................................................. App. 178 39. Memorandum from Meagan Wolfe, WEC Administrator to Interested Parties (Nov. 12, 2020) ........................................... App. 196 40. Memorandum from Michael Hass, WEC Interim Elections Administrator, and Diane Lowe, WEC Lead Elections Specialist, to Wisconsin Municipal Clerks et al. (Sept. 2020) ............................................................. App. 198 41. Election Administration Manual for Wisconsin’s Election, WEC (Nov. 10, 2020) .................................................. App. 200 42. Correcting Misinformation about Wisconsin’s Election, WEC (Nov. 10, 2020) .................................................. App. 203 43. Memorandum from Meagan Wolfe, WEC Administrator, to Wisconsin Municipal Clerks et al. (Mar. 29, 2020) ................ App. 208 44. Memorandum from Meagan Wolfe, WEC Administrator, to Wisconsin County Clerks et al. (Oct. 19, 2020) ..................... 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I am over the age of 18 and competent to testify to the matters contained herein. 2. I am the Deputy Director of the Wisconsin Coordinated Campaign and Senior Elections Director of the Democratic Party of Wisconsin. 3. Among my duties in these roles, I am responsible for acquiring the official absentee submitted absentee ballot requests in the state of Wisconsin for the November 3, 2020, Presidential election. 4. This data was last acquired on November 3rd, 2020, the day of the deadline for absentee ballot returns in Wisconsin. 5. Ballots returned on the day of acquisition prior to 8PM that were legally counted, in the following numbers. 6. On November 19, 2020, I personally supervised a team of staff to search the official WEC absentee ballot voting data. According to that data, at least the following numbers of voters cast ballots in varying methods or combinations of methods in different geographies in Wisconsin. Across all of Wisconsin, 940,623 voters returned absentee ballots after requesting them through electronic means, 649,348 voters returned absentee ballots after requesting them in person through in person early voting, and 1,589,971 in total between both methods cast absentee ballots. In Dane County, 163,960 voters returned absentee ballots after requesting them through electronic means, App.161 61,087 voters returned absentee ballots after requesting them in person through in person early voting, and 271,174 in total between both methods cast absentee ballots. In Milwaukee County, 162,253 voters returned absentee ballots after requesting them through electronic means, 108,921 voters returned absentee ballots after requesting them in person through in person early voting, and 225,047 in total between both methods cast absentee ballots. 7. In addition, I supervised those staff members to search the WEC data to identify certain individuals who had voted by absentee ballot in the November 3 election, either by mail, or in person. For those officials that voted by mail, I also asked staff to determine whether those voters requested their absentee ballot with a paper application, by email, or online
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