declaration of molly m. rugg (pursuant to 28 u.s.c ......declaration of molly m. rugg (pursuant to...
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DECLARATION OF MOLLY M. RUGG
(pursuant to 28 U.S.C. Section 1776)
My name is Molly M. Rugg and I am over the age of 18 and fully competent to make this
declaration. Under penalty of perjury, I declare the following:
1. I am a paralegal for the American Civil Liberties Union Foundation’s Voting Rights
Project.
2. Attached to this declaration are screenshots of certain websites concerning the early
voting (absentee in-person voting) hours offered by certain counties in Ohio in general
elections prior to 2012.
3. To find this information, I first searched Google for the early voting hours of a particular
county during a particular year. I took screenshots of any webpages I found that
contained that information.
4. In cases where I was not able to find the information through Google, I used a webpage
archive called the WayBack Machine, located at https://archive.org/web/. According to
the website, the archive is run by a nonprofit organization whose goal is to create a
library of internet pages that might otherwise disappear or change with time.
5. The WayBack Machine pulled up old versions of county Board of Elections websites.
Some county websites displayed early voting information for a particular general election
in the months leading up to that election, but removed that information after the election.
I used the WayBack Machine to attempt to find the website as it existed during that time
window.
6. If I could not find a county’s past early voting hours through Google, I searched for the
website address for the county Board of Elections. I then visited the WayBack
Case: 2:14-cv-00404-PCE-NMK Doc #: 18-28 Filed: 06/30/14 Page: 1 of 19 PAGEID #: 475
https://archive.org/web/
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Machine’s search page, https://archive.org/web/. I pasted the address for the county
Board of Elections website into the “Browse History” bar and clicked “Browse History.”
7. From there, the WayBack Machine brought me to a calendar page that displayed the
twelve months of the present year, with blue circles indicating dates on which the
Machine had taken a snapshot of the webpage for the archives. Across the top of the
calendar page was a bar displaying all years from 1996 to the present. Upon clicking on
any of these years, a new twelve-month calendar appeared showing blue circles for the
dates on which the Machine took a snapshot of that particular webpage during that year.
8. I clicked on the relevant year (e.g., 2010) and then selected a snapshot from a day during
the months leading up to the November election (or, in some cases, shortly after the
election). Some of the counties’ websites displayed their early voting hours on the
homepage, while others required me to click through to their absentee information pages,
voter information pages, or frequently asked questions pages. When I did locate the early
voting hours, I took a screenshot on my computer. All screenshots from this site contain
the date of the webpage version in the top-right.
9. The screenshots attached to this declaration were pulled using the methods described
above.
10. The screenshots include my computer’s taskbar. The time and date located at the bottom-
right corner on the taskbar indicates the date and time that I took the screenshot (i.e., the
date and time that I visited the website).
11. According to the attached screenshots, the following counties had multiple Sundays
available for early in-person voting in 2008 and/or 2010: Cuyahoga, Franklin, Hamilton,
Summit, Lucas, and Montgomery.
Case: 2:14-cv-00404-PCE-NMK Doc #: 18-28 Filed: 06/30/14 Page: 2 of 19 PAGEID #: 476
https://archive.org/web/
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Case: 2:14-cv-00404-PCE-NMK Doc #: 18-28 Filed: 06/30/14 Page: 3 of 19 PAGEID #: 477
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Cuyahoga County Early In-Person Voting Hours, 2008
Case: 2:14-cv-00404-PCE-NMK Doc #: 18-28 Filed: 06/30/14 Page: 4 of 19 PAGEID #: 478
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Franklin County Early In-Person Voting Hours, 2008
Case: 2:14-cv-00404-PCE-NMK Doc #: 18-28 Filed: 06/30/14 Page: 5 of 19 PAGEID #: 479
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Hamilton County Early In-Person Voting Hours, 2008
http://votetodayohio.blogspot.com/2008/09/early-voting-centers.html
Case: 2:14-cv-00404-PCE-NMK Doc #: 18-28 Filed: 06/30/14 Page: 6 of 19 PAGEID #: 480
http://votetodayohio.blogspot.com/2008/09/early-voting-centers.html
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Summit County Early In-Person Voting Hours, 2008
Case: 2:14-cv-00404-PCE-NMK Doc #: 18-28 Filed: 06/30/14 Page: 7 of 19 PAGEID #: 481
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Lucas County Early In-Person Voting Hours, 2008
http://www.toledonewsnow.com/story/8871545/early-voting-new-location-and-hours-for-lucas-county
Case: 2:14-cv-00404-PCE-NMK Doc #: 18-28 Filed: 06/30/14 Page: 8 of 19 PAGEID #: 482
http://www.toledonewsnow.com/story/8871545/early-voting-new-location-and-hours-for-lucas-county
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Greene County Early In-Person Voting Hours, 2008
Case: 2:14-cv-00404-PCE-NMK Doc #: 18-28 Filed: 06/30/14 Page: 9 of 19 PAGEID #: 483
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Butler County Early In-Person Voting Hours, 2008
Case: 2:14-cv-00404-PCE-NMK Doc #: 18-28 Filed: 06/30/14 Page: 10 of 19 PAGEID #: 484
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Cuyahoga County Early In-Person Voting Hours, 2010
http://boe.cuyahogacounty.us/pdf_boe/en-US/ElectionNotices/2010NovInhouseVoting.pdf
Case: 2:14-cv-00404-PCE-NMK Doc #: 18-28 Filed: 06/30/14 Page: 11 of 19 PAGEID #: 485
boe.cuyahogacounty.us/pdf_boe/en-US/ElectionNotices/2010NovInhouseVoting.pdf
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Franklin County Early In-Person Voting Hours, 2010
http://www.10tv.com/content/stories/2010/09/27/story-columbus-franklin-delaware-county-early-voting.html
Case: 2:14-cv-00404-PCE-NMK Doc #: 18-28 Filed: 06/30/14 Page: 12 of 19 PAGEID #: 486
http://www.10tv.com/content/stories/2010/09/27/story-columbus-franklin-delaware-county-early-voting.html
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Hamilton County Early In-Person Voting Hours, 2010
(Early in-person voting hours were pulled from two sources)
http://www.cincinnati.com/story/news/politics/elections/2014/02/25/husted-sets-uniform-voting-hours/5807307/
Case: 2:14-cv-00404-PCE-NMK Doc #: 18-28 Filed: 06/30/14 Page: 13 of 19 PAGEID #: 487
http://www.cincinnati.com/story/news/politics/elections/2014/02/25/husted-sets-uniform-voting-hours/5807307/
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Hamilton County Early In-Person Voting Hours, 2010
(Early in-person voting hours were pulled from two sources)
http://www.hamiltoncountyohio.gov/hc/hc_pdfs/102010HHC.pdf
Case: 2:14-cv-00404-PCE-NMK Doc #: 18-28 Filed: 06/30/14 Page: 14 of 19 PAGEID #: 488
www.hamiltoncountyohio.gov/hc/hc_pdfs/102010HHC.pdf
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Summit County Early In-Person Voting Hours, 2010
Case: 2:14-cv-00404-PCE-NMK Doc #: 18-28 Filed: 06/30/14 Page: 15 of 19 PAGEID #: 489
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Montgomery County Early In-Person Voting Hours, 2010
http://www.mcohio.org/newsdetail492.html
Case: 2:14-cv-00404-PCE-NMK Doc #: 18-28 Filed: 06/30/14 Page: 16 of 19 PAGEID #: 490
http://www.mcohio.org/newsdetail492.html
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Lucas County Early In-Person Voting Hours, 2010
http://7online.com/archive/7691805/
Case: 2:14-cv-00404-PCE-NMK Doc #: 18-28 Filed: 06/30/14 Page: 17 of 19 PAGEID #: 491
http://7online.com/archive/7691805/
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Greene County Early In-Person Voting Hours, 2010
Case: 2:14-cv-00404-PCE-NMK Doc #: 18-28 Filed: 06/30/14 Page: 18 of 19 PAGEID #: 492
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Cuyahoga County Early In-Person Voting Hours, 2011
Case: 2:14-cv-00404-PCE-NMK Doc #: 18-28 Filed: 06/30/14 Page: 19 of 19 PAGEID #: 493