in the united states district court for the …...2. asit data manager, onemyjobduties is to managea...

IN THE UNITED STATES DISTRICT COURTFOR THE SOUTHERN DISTRICT OF OHIO

EASTERN DIVISION

THE NORTHEAST OHIO COALITIONFOR THE HOMELESS, et al.,

Plaintiffs,

vs.

JON HUSTED, in his official capacity asSecretary of State of Ohio,

Defendant,

and

STATE OF OHIO,

Intervenor-Defendant.

:::::::::::::::::

Case No. 2:06-CV-896

Judge Algenon Marbley

Magistrate Judge Terence P. Kemp

DECLARATION OF NICKSPEELMAN IN SUPPORT OFPLAINTIFFS’ MOTION TO MODIFYAPRIL 19, 2010 CONSENT DECREETO PREVENT CONSTITUTIONALVIOLATIONS

Case: 2:06-cv-00896-ALM-TPK Doc #: 315 Filed: 07/13/12 Page: 1 of 3 PAGEID #: 10465

DKCLAKATION ()!■ MCk SI'EKLMAN

1, Nick Speelman, declare the following baaed upon my personal knowledge:

1. I am an employee and member of Service Employees International Union District

1199 West Virginia/Kentucky/Ohio ("District 1199"), a plaintiff in the above-captioned lawsuit.

I have worked as District 1 199*s I P Data Manager since 2008.

2. As IT Data Manager, one my job duties is to manage a database iliat includes

information on District ! [99's membership. This database contains information on members"

names and addresses.

On or about July 6. Sand 11 2012. attorneys for District 1199 provided me with

lists of individuals' names and addresses, which I understand were lists of provisional voters

provided to the attorneys by some of Ohio's County Boards of Elections. True and correct

copies of excerpts of the lists from the Boards of Elections in Belmont County, Butler County,

Henry County. Lake County, Richland County. Trumhull County, and Wood County, which I

received from counsel, are attached hereto as Exhibit A.

4. 1 compared the lists of persons sel forth in Exhibit A to District 1199's

membership database. As a result of that comparison. 1 identified members of District 1199

whose names and addresses matched those on the lists in Exhibit A. These matches included the

following individuals: Rachel Tincher (Belmont County); Patricia Martin (Butler County);

Samantha Taylor (Henry County); Meredith Aker (Lake County): Lindsey Jacobs (Richland

County): and Kyasha Green (Trumball County). Each of these individuals is a current

bargaining unit member of District 1 199. except Patricia Martin, who became inactive according

lo the database in May 2010. bul who was a member of the bargaining unit when her provisional

ballot was cast.


5. The lists attached as Exhibit A identify the year in which a voter cast the

provisional ballot and, in some instances, whether the ballot was rejected and the reason for

rejection. As reflected in Exhibit A:

a. Rachel Tincher's 201 1 provisional ballot is identified as ■■Rejected: Voter Voted

in Wrong Precinct";

b. Patricia Martin's 2008 provisional ballot is identified as "Wrong Precinct";

c. Samantba Taylor is identified as casting a provisional ballot in 2011;

d. Meredith Aker's 2008 provisional ballot is identified as "'rejected." with the

reason being "voted wrong pet";

e. Lindsey Jacobs is identified as casting a provisional ballot in 2011; and

f. Kyasha Green's 2008 provisional ballot is identified as "NO1D," and is one of

122 that are identified as rejected ballots.

6. I identified other potential matches between the counties' lists of provisional

voters and District 1199*5 membership where, for example, the names matched but the street

addresses did not. However, if a member bad moved, this might be a match. Additionally, if

a member moved counties after casting a provisional ballot, no match would have been

found.

I declare under penalty of perjury that the foregoing^is/ rue and correct.

Executed this IX day of July. 2012.


EXHIBIT A

Case: 2:06-cv-00896-ALM-TPK Doc #: 315-1 Filed: 07/13/12 Page: 1 of 20 PAGEID #: 10468

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