declaration of molly m. rugg (pursuant to 28 u.s.c ......declaration of molly m. rugg (pursuant to...

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1 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

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  • 1

    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/

  • 2

    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/

  • Case: 2:14-cv-00404-PCE-NMK Doc #: 18-28 Filed: 06/30/14 Page: 3 of 19 PAGEID #: 477

  • 4

    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

  • 5

    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

  • 6

    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

  • 7

    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

  • 8

    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

  • 9

    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

  • 10

    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

  • 11

    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

  • 12

    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

  • 13

    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/

  • 14

    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

  • 15

    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

  • 16

    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

  • 17

    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/

  • 18

    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

  • 19

    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