DISTRICT COURT CIVIL COVER SHEET County, Nevada Case No, XXVI say Cc ie) ‘TParty Talormation grovas tom hone ont nating tivoner/ fom) A-16-74629 inf (nameless Detent uameTadieadphoney DONALD J. TRUMP, an individual and DONALD J. TRUMP JOE P. GLORIA, in his oficial capacity asthe FOR PRESIDENT, INC.,a New York nonprofit corporation | Car County Regier of Voters | 7 “Anoreyoame/adaesopheney [anomey (ametdaesvphon} David 8. Loo, Esq - Bar No. 6033, ___| Beinn 2. Heaoy, tsg ~ Bae No 10066 ‘Aurora M Maskel- bar No. 6470 Auoered Gag 7 7579 Vegas Or. #190, Las Veyas, NV 09125 “Lek eee, SN BRS Tet: (702) 308-9776 fature of COMIFOVErSY (peas sel the one most apple Civil Case Filing Types Real Property ~ Tors — Tandlord/Tenant Nealgence ‘Other Tors DJuntewsst deiner Daw produce riaiiy ClotierantoraTennt [remiss Liability [tnenona Misconduct Title to Property Lotter Negligence [employment Tor tvs Foreconure Malpractice Ltssurnce Tor [oter Tite to Ropeny LsetiatDenat Clomertoa Otter Real Property Cee [condemnativtiminest Domain | FJAccounting lower Rea! Propery Llotierstapeactice Probate Construction Detect Contract Taal Review Appel Prabal Gao pan wa | —Constroction Defect Tada Review [Csummary Adnan Dlonapterao [Drorectosute Metistion Ce ener aniston Doster contrition Deft retton to sat Recons [Bspeciat Administration ‘Contract Case [Fetentat Competency set aside [nit Commercial Code ‘Nevada State Agency Ape Ltrsvconservastip suiting and Constrctin Locpenirent of Motor Vehicle Loner Protate Lotnsuance Carer L]workers compensation Estate Value Clcommeria intent Lllotsernevadn State Agency over $200,000 Lcottetion of Accounts ‘Appeal Other l2enee $100,000an8 200.000 | [EJemploymentConsact arp om tower Cour under $100,000 a Unknown otter conact otter tudisi Review/Appeat Cunders2.s00 Guawrn Other Ci ing Civil Writ 7 ‘Other Civil Filing, Z Lic or aes Copus Dwi froin compromise oftin’s Cam Wit oranda Biorierciv wee (DForian sdament wii or quo warant Bother civ maters Basins Core lings should beled wg he Business Court ccna Mar 7, Ele Be ee ‘of iitiati iy or representative So oter sie for fay relate case ngs.MARQUIS AURBACH COFFING 10004 Pak Ram Drive 16 7 18 9 20 Electronically Filed OF GY 11/07/2016 05:19:13 PM é lf . ‘ Aira 4 brine Marquis Aurbach Coffing Brian R. Hardy, Nevada Bar No. 10068 10001 Park Run Drive Las Vegas, Nevada 89145, Telephone: (702) 382-0711 CLERK OF THE COURT bhardy@maclaw.com DAVID 8. LEE, ESQ. SHANA D. WEIR, ESQ. Nevada Bar No. 6033 Nevada Bar No. 9468 A. MARIA MASKALL, ESQ. PARKER, NESLON & ASSOCIATES evada Bar No. 6410 2460 Professional Court, Ste. 200 , HERNANDEZ, LANDRUM Las Vegas, NV 89128 & GAROFALO, AP. ‘Ts (702) 868-8000 7575 Vegas Drive, Suite 150 F: (702) 868-8001 Las Vegas, Nevada 89128 @pnalaw.net (702) 880-9750 + (702) 314-1210 dice@lee-lawfirm.com amaskall @lee-lawfirm.com, Attorneys for Petitioners DISTRICT COURT CLARK COUNTY, NEVADA DONALD I. TRUMP, an individual; and | DONALD J. TRUMP FOR PRESIDENT, INC., New York nonprofit corporation, Case No. Dope Noten A-16-746298-W Petitioners, ELECTION RELATED ACTION PETITION FOR WRIT OF MANDAMUS, | OR, ALTERNATIVELY, PETITION FOR WRIT OF PROHIBITION ws. JOE P. GLORIA, in his official capacity as the Clark County Registrar of Voters, Defendant, | 1. Petitioners DONALD J. TRUMP (the \didate”), and DONALD J. TRUMP FOR PRESIDENT, INC. (the “Campaign”) bring this Petition for Writ of Mandamus or, Alternatively, Petition for Writ of Prohibition against Respondent JOE P. GLORIA, in his official capacity as the Clark County Registrar (the sgistrar”). Page | of LI -MAC‘1421.02 Petton for Wet of Mando o leave Plone Writof Prin DOCK 1172016337 PML2 Pack Run Dive j 2 5 OTL FAX: (1 MARQUIS AURBACH COFFING 1000 aw keen ~~ io u 12 13 4 ibs 16 17 8 19 INTRODUCTION 2. This action is to preserve the starus quo so that, if the election of presidential electors from the State of Nevada is contested, the candidates and courts may redress egregious: violations of Nevada election law perpetrated by the Registrar on November 4, 2016, 3. The Registrar's violations were not random and neutral in their effect, but very ‘much appear to have been intentionally coordinated with Democratic activists in order to skew the vote unlawfully in favor of Democratic candidates. JURISDICTION AND V1 4. The Court has jurisdiction over this Complaint, and venue in this Court is proper. The Respondent is a resident of or maintains his principal place of business in Clark County, Nevada, and all or part of the claim for relief at issue in this litigation arose in Clark County, Nevada, PARTIES 5. The Candidate is a duly qualified elector of New York County, New York and is the Republican nominee for the office of President of the United States in the November 8, 2016 general election (the “El The Candidate has a direct, personal, and substantial interest in ensuring that elections officials enforce ~ and that voters are entitled to rely upon - the plain language of the Nevada Revised Statutes (“Nev. Rev. Stat.” 0 ") setting forth the rule for voting in the Election, 6. ‘The Campaign is the Candidate's official campaign committee. ts primary place of business is 725 Fifth Avenue, New York, New York 10022, As the entity through which rillions of voters in Nevada and elsewhere across the county exercise their First Amendment rights of association and expression, the Campaign has a direct, personal, representational, and substantial interest in ensuring that elections officials enforce ~ and that voters are entitled to rely upon ~ the plain language of the Nev. Rey. Stat. Ann. 7, Respondent JOE P, GLORIA, the Clark County Registrar of Voters, is responsible for overseeing the conduct of elections in Clark County, including but not limited to the regolation of polling places and the conduct of election personnel at polling locations Page 2 of 1 MAC-14221-00 Petition for Writ of Mandans or Alemdvely Petition tr Wei of Proibion, DOCK 15/720163:37 PMAX (12) 382-5816 MARQUIS AURBACH COFFING aah & wD throughout Clark County. The Registrar's principal place of business is 965 Trade Drive, Suite A, North Las Vegas, Nevada 89030. STATEMENT OF FACTS 8. On November 4, 2016 (the last day of early voting in Clark County), poll watcher Ronald Keichan personally appeared at the polling location for Precinct 4536 at Cardenas Market, 4421 E, Bonanza Road, Las Vegas, Nevada 891 10 (hereinafter the “Polling Location"), and served as a poll watcher at the Polling Location until approximately 10:00 p.m., except for 2 hours between 6:00 p.m. and 8:00 pam. See Declaration of Ronald Ketcham, attached hereto as. Exhibit 1, 9. The Polling Location was scheduled to close at 8:00 p.m. according to the written materials distributed by the County of Clark pursuant to NRS 293.3576, 10. Around 5:00 p.m, the head of the Polling Location (identified as Joe”) spoke with Mr. Ketcham and the lead Democrat Party Observer, stating that he was instructed by the Registrar to keep this polling location open until the market closed at 10:00 p.m. Id, at 8. 11. ‘The Registrar's instructions kept the Polling Location open two (2) hours beyond the designated closing time published pursuant to NRS § 293.3576. 12. Joe also told Mr, Ketcham that the voting area would remain open after the store closed if there were voters in line and inside the store at 10:00 p.m, Jd, at] 9. 13. After 8:00 p.m, Joe told Mr. Ketcham directly that other polling locati being closed on time and voters still in fine were instructed to come to the Polling Location at Cardenas Market. Jd, at § 10. Joe commented to Mr. Ketcham that he felt this selective closing was done to help Hillary Clinton, id. 14, Mr, Ketcham estimates that more between 150 and 300 people entered the line 4 11. The line after 8: pam., but the actual number could have been significantly higher. after 8:00 pan. became larger than Mr. Ketcham had observed at any other point during the day, id 15, At approximately 9:40 p.m. Michael Chamberlain personally appeared at the Polling Location at Cardenas Market, See Declaration of Michael Chamberlain, attached hereto Page 3 of LS MACL14221-002 Potion fr Writ of Manda o Alesatvely Pelton fx Weit of Profibiton DOCK 11772016 337 PMMARQUIS AURBACH COFFING * a as Exhibit 2. Mr. Chamberlain personally researched the issue regarding closing times and was generally aware that the Polling Location at the Cardenas Market was scheduled to close at 8:00 pm, Id, a6. : 16, When Mr. Chamberlain arrived at 9:40 p.m., he personally witnessed Democrat candidate for Senate, Catherine Cortez Masto, speaking to approximately 20-30 individuals, some of whom were carying signs written in Spanish, Zd, at § 7. He entered the store and | witnessed the voting area, where 2 or 3 people were standing in line waiting to vote, and a cameraman and reporter fiom Pox 5 News were standing nearby, Id. | 17, Because it was so nmuch later than 8:00 pam. when polls were required to close (it was neatly 10:00 p.m.), Mr. Chamberlain was alarmed when a person entered the line intending to vote, $0 he attempted to videotape the situation. Jd, at § 8. A person who was wearing a name tag reading “foe,” identified as a poll worker, approached Mr. Chamberlain telling him he could not use his phone to take a video at that location, /d. Mr. Chamberlain asked him if it was against the law to videotape. Jd. He said it was, and Mr. Chamberlain asked Joe if it was against the law for people to come in and vote after 8:00 p.m. {ed Joe answered, “I don’t care what you think, we are going to let people vote here until 10:00 p.m.” Id. 18, A few minutes later, Joe stood at the end of the poll line and announced that the polls were closed. At that point, be placed a barrier at the end of the poll fine, Zi, at 9. Lorena Portillo, who was wearing a lanyard with a name card identifying her by name as a Clark County employee, also announced the polls were closed. /d. 19. Within minutes, two individuals walked around the barrier to the table where voters were given cards to vote. Id, at 10. Two separate individual poll workers at the table handed voter cards to the two voters, who then proceeded to vote. Jd. Mr, Chamberlain looked at his phone, and noticed that the time was approximately 9:50 p.m, id. 20. Lorena Portitlo, a county official, approached Mr. Chamberlain, who asked her why this polling place was allowing people to vote after 8:00 p.m., as he had been told that it would not close until 10:00 p.m, /d, at § 13, In response, Ms. Portillo confessed: “There were two people who voted after we said the polls were closed, and that should not have happened. Page 4 of 15° | MAC: 14221-012 Petion or Wit of Manda or Aral Petion fr Woof Probiton DOCK 1172016137 PMMARQUIS AURBACH COFFING ao {d, She further explained that the reason the polls were closing at this time was because the store was closing. fd. 21, Jesse Law, the Director of Election Day Operations for the campaign, on the evening of Friday, November 4, 2016, at 8:10 p.m., was present and working at the Trump Headquarters in Las Vegas when they received ealls from Me. Ketcham referenced earlier, who was at the Polling Place at Cardenas Supermarket, and the call from Mr, Ding (referenced earlier), who was at the Deer Springs Long Term Early Voting site in North Las Vegas. See Declaration of Jesse Law, attached hereto as Exhibit 3. 22. Mr, Law wanted to confirm the reports were not just isolated so, at approximately 8:30 pam., he drove to the Silverado Ranch Plaza, another polling location, located at 9845 S. Eastern Avenue in Las Vegas. Jd. at $7. There was a long line, and he spoke to a site worker there who said that people were being allowed to enter the fine as long as there were people in line, no matter what time they arrived fo the polling location, even if it was after the required 8:00 pam. closing time. Id. 23, Mr, Law then drove to the Cardenas Market and arrived at approximately 9:05 pam. idl. at (9. There was a large crowd of volunteers and political professionals at a booth set up promoting Democrat senator Catherine Cortez Masto, Jd He walked into the market through the entrance that saa closest to the polling location and saw a Culinary Union official known to. be a political director for the union and one of Masto’s chief campaign people directing their volunteers and staff to hand out books and literature, and seemingly coordinating with the polling location management in what appeared to be violation of electioneering prohibitions. Zc 24, Once inside the market, Mr. Law was immediately greeted with a voter yelling “Hillary Hillary Hillary,” who was standing in a line that was not moving, with between 100 to: 150 voters waiting to vote, and democrat volunteers walking the lines taking pictures and videos of the line or passing out cookies and water. fd. at $10, 25, Standing at the end of the voting line, Mr. Law witnessed the county official Lorena Portillo talking to Democrat operatives and volunteers along the line while they were filming, Je at G11 Page 5 of 8 ‘MAC:14221-002Petiion for Writof Manas oF Altematively Pitan fr Writ of Proton DOCK 11772016 337 PMFAX, (202) 382-816 evade 89185 = & a MARQUIS AURBACH COFFING 10001 ask Ran Drive ow aw Se ul 12 13 14 1s 16 7 18 19 20 2 2 23 24 25 26 27 28 26. Over a period of 45 minutes, Mr. Law observed over 30 but fewer than 40 new people get in line and the Democrat volunteers distribute food and water to the voters in line, Id. at $12, He recorded approximately five people get in line via video, and recorded Democrat operatives and volunteers filming the line. id, He did not record the polling equipment nor people voting. Id. These materials are available for an in camera inspection upon request. 27. Mr, Law saw Michael Chamberlain atrive at about 9:40 p.m. and they both observed that the line that had not moved more than ten feet in 20 minutes begin to rapidly inove. fd, at 113. They both walked to the front, and when there was only one person in line, Mr. Chamberlain snapped 2 photos. fd. ‘The poll site manager “Joe” walked out of the polling Jocation to tell Mr, Chamberlain that he was not permitted to photograph the polling equipment. Id. Mr. Chamberlain indicated that the site cannot allow new people to enter the voter line after 8:00 p.m. Id. 28, Joe then shouted “this location is staying open until ten and there is nothing you can say or do about it,” Jd. at §14, Mr. Law pointed out to Joe that there was a gap in the line or, in other words, there was now no one in line at all and that they were required to close the polling location, even according to their own interpretation of the election rules concerning closing time, Jd. Joe ignored Mr. Law, who went to the front of the empty line area and filmed an empty line when people started running up to get in line again, kd. 29. Ms, Portillo then approached Mr. Law and said that filming was not allowed. Jd. at 415, Mr, Law told her that she needs to close the site because there was a gap in the line. Jd She argued. Id, Mr, Law approached the local news media, FoxS, who was there in the store and told the reporter what was happening, and he said he thought they were closing the line. Jd At that point, Joc closed the line by crossing the roped area and announcing that the polls were closed, Jd, Ms, Portillo told the site volunteers the line was closed and announced the same to those present in the supermarket. Id, She then repeatedly said to Messrs. Chamberlain and Law: “There, we are closed. You can leave now.” Ia. 30, Messrs, Chamberlain and Law did not leave. Id at 416. They observed Ms. Portillo within onc minute ushering three more people to vote AFTER SHE HAD Page 6 of 16 MAC.14221-D02 Peston for Wit of Madam ot Reavy Peon Writ of Probiilon DOC 1112016 3°37 PMMARQUIS AURBACH COFFING 16004 Park Ra Drive ‘Nevada 89145 FAX: (02) 325816 aoa we ANNOUNCED CLOSING. Jd. Ms, Portillo then got on the phone with who she said was her boss, and Mr. Law overheard her say, “they are just observing.” Jd. Poll workers allowed one nore woman to vote, and so Mr, Law asked this poll worker why she closed the polling location and then allowed more people to vote. She asked that Mr. Law “talk to her bos: she made a call and handed her phone to Mr. Law, which indicated the call was to “Joe Work. Id. 1t was Joe Gloria, who Mr. Law knew to be the Clark County Registrar of Voters. id. Mr. Law did not engage in a conversation, but said what he had just observed Ms. Portillo doing would be put into affidavits and submitted to the courts, fd. Ms, Portillo then stopped one man from voting who returned to the voting table two more times with different Union, Cortez-Masto or Democrat officials. fd. at 417. All of them were looking at Ms. Portillo with a pleading look in their eyes wondering if she would just let one more person vote. Jd, There was clear familiarity and cooperation. Jd Mr. Law saw Ms. Portillo announce that the polls closed g 1d time, at about 9:50 p.m. fd 32. Im the meantime, at approximately 7:00 p.m. the same day, attomey Jeanne Valentine was als informed by Mr. Ketcham that the Polling Location at Cardenas Market intended to remain open for voting past the mandated law requiring that polls close at 8:00 p.m. See Declaration of Jeanne M, Valentine, attached hereto as Exhibit 4, 33. On the same day, at approximately 8:05 p.m., Ms. Valentine was informed by Clark County poll watcher, Michael Ding, that he was also told the polling place for Precinct 2446, located at Deer Springs Town Center, which was inside a trailer, located at 7090 N Sth Street in North Las Vegas, Nevada 89084, was intending to stay open as long as necessary, with ‘no closing time, to allow any voter fo vote who appeared at this location; all night if necessary. See 97 of Exhibit 4, According to Mr. Ding, the poll workers said that the Secretary of State had given thens permission to ignore the statute requiring that polis close at 8:00 p.m. Id. 34, Ms, Valentine called the office of the Secretary of State at 8:10 p.m., but the office was closed. See { 8 of Exhibit 4. She then immediately called the Clark County Registrar of Voters, and a woman answered the phone. Jd, Ms. Valentine asked her if polling locations Page 7 of 16 MAC:14221-000 Paton foe Writ of Mandan or Akemaively Potion fs Writ of Prohibition DOCK 1/7/2016 3:37 PM. ser which \ were being permitted to remain open past 8:00 p.m., and she said that as long as voters were in|BAX: (202) 382-5816 "Nevada 89188 Pak Run Drive MARQUIS AURBACH COFFING oo © line, the polling locations were not allowed to close. /d. Ms. Valentine asked her if the last person in line at 8:00 p.m. was required to be identified and then that person would be the last voter allowed tw vote, and she said she was going to hand the call to a supervisor. fd. 35, Ms, Valentine then spoke with a man who identified himself as Charles Hurley, the Assistant Registrar of Voters in Clark County, See {19 of Exhibit 4, Ms, Valentine repeated her question, and he expressly said that polls do not close on the fast day of early voting until everyone gets a chance to vote. /d. Ms, Valentine presented the following hypothetical scenario: if a person who worked until 9:30 p.m. who obviously was not in line to vote at the 8:00 p.m. deadline, or even at 9:00 p.m, appeared at a polling location after work, would that person be allowed to vote? Id. Mr. Hurley enthusiastically said that yes, any voter who wanted to vote on the last day of early voting would be permitted to vote at any time, Id 36. Ms. Valentine asked Mr. Hurley what the purpose was, in his mind, of the 8:00 pom, time listed in the written literature stating that polls close at 8:00 p.m., and he said that is purely guidance. See 10 of Exhibit 4, Mr, Hurley expressly stated that Clark County does not follow the law regarding poll closure on the last day of early voting. Id. 37. Mr Hurley said that Clark County allowed voters to vote past the deadline listed {in written materials so as to not “disenfianchise” voters. See 11 of Exhibit 4, Ms. Valentine then asked him whether he thought the practice of allowing voters to vote past the 8:00 p.m. deadline that was communicated to all voters of Clark County actually disenfranchised voters ‘who relied on the written information and who chose to follow the law by staying home after 8:00 p.m. because they believed, in good faith, that the polls would be closed at 8:00 p.m. Id. See a true and accurate copy of the Early Voting Schedule prepared and distributed by the Clerk of Clark County, a copy of which is attached hereto as Exhibit §. (An original of Exhibit $ bas been provided to the Court.) Mr. Hurley did not answer the question, 38. At approximately 10:20 pm., Ms. Valentine was informed by an unidentified poll ‘watcher that a different polling location, located on the Las Vegas Strip, was still open. See § 12 of Exhibit 4, ‘This was verified with pictures, as was the long line of voters at the Cardenas Markct location afier 8:00 p.m., which the Nevada legal team decided not to attach to this motion Page 8 of 18 SMACEI$221-000 Pett for Whit of Mandar or Aleradvely Petson fr Wit of Prohibition. DOC 1172016:3:37 PMMARQUIS AURBACH COFFING 101 Park Ran Dive ee aan eo 18 19 20 26 27 28 due to the unknown identities of the individuals captured in the pictures. Jd, The pictures are available for in camera inspection by the Court, if necessary. Id. 39. In wlditiun, throughout the evening, several twitter accounts supporting Democrats and the press tweeted that the polls were indeed open until 10:00 p.m., and encouraging voters to go vote after the 8:00 p.m. deadline passed. See § 13 of Exhibit 4. it appeared that Democrats were aware of this selective enforcement of the law, but Republicans were not, which plainly harmed the latter while improperly benefitting the former. See a true and uvcurale copy uf screen shots taken from Ms. Valentine’s mobile phone are attached hereto as. Exhibit 6. 40. Also on the last day of early voting, Mr. Ketcham witnessed young people associated with the Democrat candidate for Senator, Catherine Cortez Masto, hand out half-page documents that stated at the top: “Clark County Democratic Party URGES YOU TO VOTE IN SUPPORT OF THE FOLLOWING CANDIDAT (emphasis on the document). See Ketcham Declaration, 4 12. Throughout the afternoon, he saw hundreds of voters standing in line holding this material. Jd. He witnessed a Democrat poll watcher hand what he believes was one of those sheets to a voter standing well within the 100-foot prohibited area for electioncering, as the voter ‘was at the front of the line. He believes it was one of these sheets because they have a very unique shape and appearance which makes them very distinguishable, a@ copy of which is attached as Exhibit 7 to the motion seeking a Declaratory Judgment 41, On November 7, 2016, the Campaign filed a complaint raising the foregoing misconduct with the Secretary of State, See a true and correct copy of the Complaint to Secretary of State, attached hereto as Exhibit 8. LEGAL STANDARD 42, Interpretation of statutes is a matter of law. See Marquis & Aurbach v. Eighth Judicial District Court, 122 Nev. 1147, 1156 (2006). When the language of a statue is unambiguous, courts are not permitied to look beyond the statute itself when determining its meaning. Id. Page 9 of 16° MAC-14221-02 Petition for Writof Manca er Atomalvely Pion Sr Writ of Prohibition DOCK 11/2036 3:37 PM1 43, The Registrar is responsible for the regulation of polling places and the conduct of | 2 || election personnel at polting locations throughout Clark County. ‘This means that the Registrar is. 3 || cesponsible for following Nevada law, which xequircs that election personnel are informed of, 4 |] and enforce, the following statutes: i 3 Ney. Rev. Stat. § 293.3025 Posting of copies of certain other information and 6 | documents at polling place. u ‘The Secretary of State and each county and city clerk shall ensure that a copy of . each of the following is posted in a conspicuous place at each polling place on : election day: i 9 1. A sample ballot; 10 2. Information concerning the date and hours of operation of the polling nL place: | g 2 E . Nev. Rev, Stat. § 293.305 Closing of polls; admission of voters and other persons. 9 u 14 1. [fat the hour of closing the polls there are any registered voters waiting to Bats vote, the doors of the poiling place must be closed after all such voters have been i aij, admitted to the polling place. Voting must continue until those voters have voted, | @ #25 2oiz ' Nev, Rev, Stat. § 293.3876 Schedule of locations and times for early voting, a a ala 1. The county clerk shall publish during the week before the period for early SB 2 is voting and at least once each week during the period for early voting in a Z newspaper of general circulation a schedule stating: = (a) The location of each permanent and temporary polling 20, place for early voting. 2k (6) The dates and hours that early voting will be conducted at each location, 2 a 2. The county clerk shall post a copy of the schedule on the bulletin board 2 used for posting notice of meetings of the board of county commissioners. ‘Ihe 4 schedule must be posted continuously for a period beginning not iater than the fifth day before the first day of the period for early voting by personal 25 appearance and ending on the last day of that period, 26 3. The county clerk shall make copies of the schedule available to the public in - reasonable quantities without charge during the period of posting. | 28 | | | Page 10 of 1€ | MAC‘ 1424-002 Pete for Writ of Manda cr Alera Peon x Wit ohn DOCK 172016339 PM |a3 = MARQUIS AURBACH COFFING 100) 3824 4, No additional polling places for early voting may be established after the schedule is published pursuant to this section. Nev. Rey. Stat. § 293.361 Electioncering prohibited near polling place; penalty 1, During the time a polling place for early voting is open for voting, a person may not electioneer for or against any candidate, measure or political party in or within 100 feet from the entrance to the voting area. 44, The Registrar’s misconduct on November 4, 2016 gives rise to no fewer than three violations of Nevada election law. 45, First, the Registrar violated the law in extending polling hours beyond the 8:00 p.m, published cutoff time in violation of Nev. Rey. Stat, § 293.305(1). Although the voters physically standing in line at 8:00 p.m, were inarguably entitled to vote, see Nev. Admin, Code § 293.247(1)(a), poll workers were required under Nev. Rev. Stat. § 293.305(1) to “folose] the doors of the polling place” at 8:00 p.m., identify who the last person waiting to vote was at the time that the polls closed, and not admit additional voters into the waiting line, See also Nev. ‘Admin. Code § 293.247. To be sure, the Registrar could have published longer voting hours for the Cardenas Market location pursuant to Nev. Rev. Stat, § 293.3576 so that voters of either major party arriving later than 8:00 could lawfully cast non-provisional ballots, but his unilateral and unpublished extension of polling hours exceeded his statutory authority. ‘This s especially problematic because the selective, non-uniform process for closing polling places, especially in a jwal Protection Clause of the manner that favors one political party over another, violates the Fourteenth Amendment. See generally Bush v. Gore, $31 U.S. 98 (2000) (considering non- uniform voting procedures in Florida in connection with the 2000 presidential election). 46, Second, even if the Registrar had authority 10 unilaterally extend polling hours without publication, he erred in reopening the polling place for late arrivals. He effectively || created a new polling place from the time that the polls reopened at approximately 9:47 p.m, and the time that the polling place finally closed at approximately 9:50 p.m., without any publ notice, This violated the statutory requirement that “[nJo additional polling places for early voting may be established after the schedule is published.” See Nev. Rev. Stat. § 293.3576(4). Page IL of LS MACL14221-000 Petition fer Wit of Manda or Alternatively Petin fir Wit of Prohibition DOCK 11/720163:37 PMMARQUIS AURBACH COFFING vy 47, Finally, the Registrar clearly violated the law by allowing Democratic operatives to brazenly distribute the Clark County Democratic Party’s literature in direct violation of the prohibition on “clectioncerfing] for... any candidate .. . within 100 feet from the entrance to the voting area.” Jd. $293.361(1). As the elections officer responsible for ensuring the proper operation of polling places, it was the Registrar's duty to monitor the activities of campaign operatives within the Cardenas Market polling place, and he failed to stop clearly illegel activities under his supervision. REQUEST FOR IMMEDIATE RELIEF 48. The Candidate and the Campaign have no plain, speedy, and adequate remedy at Jaw of any kind. 49, The Campaign filed a complaint about the foregoing misconduct with the Scoretary of State, but the Secretary has not yet granted any relief, Now, with the election only hours away, there is insufficient time to wait for the Secretary of State to grant relief through the ordinary administrative procedures. This is an emergency action requiring judicial intervention. 50, Because the Registrar violated the statutory voting procedures, the ballots and voting machines involved in the November 4, 2016 events must not be comingied with the ballots and voting machines that were not involved in the incidents described above. ‘The affected ballots and voting machines must be set aside, sequestered, and impounded to ensure that, in the event of post-election challenges, the sfatus quo has been preserved. 51. Failure to set aside, sequester, and impound the affected ballots and voting machines will impede or prevent the candidates, voters, and courts from reviewing the misconduct on November 4, 2016 and obtaining a legal remedy in due course. 52. The petitioners have been required to retain the services of counsel, to prosecute this action and are entitled to an award of attorney’s fees and cost 53, The Candidate and the Campaign respectfully represent and request a writ of mandamus of, alternatively, a writ of prohibition mandating and prohibiting the following: Page 12 of 16° [MAC:14221-602Petiion for Writ of Manaus a Altmatvely Peto Sr Writ of Prohbion DOCK 11/7/2056 337 PM.MARQUIS AURBACH COFFING wR BN aia ‘The ballots and voting machines from the following early voting polling places shail be set aside, sequestered, and impounded pending any legal challenges to the results of the November 8, 2016 election: i, Cardenas Market located at 4421 East Bonanza Road, at the intersection of North Lamb Boulevard in Las Vegas. ii, Deer Springs Town Center, located in the trailer in the parking lot near Michaels on North Fifth Street, south of CC- 215, at West Dorrell Lane in North Las Vegas. Silverado Ranch Plaza, located in the trailer in the parking lot near PetSmart on Eastern Avenue at East Silverado Ranch Boulevard in Las Vegas. iv. Las Vegas Strip, located at 3550 West Harmon Avenue, West of Polaris Avenue in Las Vegas. ‘The ballots and voting machines from the foregoing early voting polling places shall not be modified or commingled or interspersed with other ballots and voting machines pending any legal challenges to the results of the November 8, 2016 election. ‘The Registrar shall take all other steps necessary to preserve the status quo and allow legal review of the allegations in this petition after the completion of voting on November 8, 2016. This specifically includes identifying, preserving, and retaining all documents, records, log books, and evidence of any kind relating to the ations in this petition. ‘The Registrar shall ensure that such materials are not destroyed, lost, or comingled with other materials. ‘The Registrar shall pay the petitioners’ reasonable legal fees and costs in this action. Page 13 of 16 ‘MAC-{4221-2 Betton Ge Writ of Mandan of Allemativey Potion for Wri of Probibiton.OOCX 5177016 3:37 PMQe a Eas 3 8 es gA28 He E58 aia 3 é z = & = e. Such other relief as equity and the nature of the case may require, DATED this 7th day of November, 2016. Respectfully submitted, MARQUIS AURBACH COFFING TR Nevada Bar Ne. 10068 10001 Park Run Dri Las Vegas, Nevada 89145 Telephone: (702) 382-0711 Facsimile: (702) 382-5816 Counsel for Petitioners, DONALD J. TRUMP and DONALD J. TRUMP FOR PRESIDENT, INC. Page 14 of 16 AC>14221.002 Ption for Wei of Mads or Alter etion fr We of Poon DOCK 1/2016 337 N4 |FAX: (702) 382-816 00} Par Ro Neva MARQUIS AURBACH COFFING s aw DECLARATION OF BRIAN R. HARDY, ESQ. IN SUPPORT OF PETITION FOR WRITS OF MANDAMUS AND PROHIBITION TO COMPLY WITH NEV. REV. STAT. §§ 34.170 AND .330 BRIAN R. HARDY, Esq., declares as follows: 1 1am over the age of 18 years and have personal knowledge of the facts stated herein, except for those stated upon information and belief, and as to those, I believe them to be true. 2. Laman attorney at Marquis Aurbach Coffing, which is counsel for Petitioners Donald J. Trump and Donald J. Trump for President, tnc. 3. Ef the Court does not issue a Writ ordering Joe P. Gloria to impound and segregate the ballots and voting machines involved in the unlawfully extended voting hours on November 4, 2016, it is highly probable that valid votes cast on Election Day will be commingled with the unlawfully cast votes, therefore preventing or complicating post-election review by and challenges in this Court or others. 4. {certify and affirm pursuant to Nev. Rev, Stat. §§ 34.170 and 330 that the Petition for Writ of Mandamus and Prohibition is filed in good faith, and that the petitioners have no plain, speedy, and adequate remedy in the ordinary course of law that they could pursue in absence of the extraordinary relief requested 5, Pursuant to NRS § 53.045, I declare under penalty of perjury under the laws of the State of Nevada that the foregoing is true and correct. Dated this 7th day of November, 2016. \ MARQUIS AURBACH COFFING Brian R. Hardy, Esq. 10001 Park Run Drive Las Vegas, NV 89145 i | 702.207.6096 1 702.888.8908 ‘bhardy@maciaw.com | veard maclaw.com Ap piense consider the environment before printing this e-mail 280, any ta iforaton oF writen we ates contain heres (elutiog any attachments) net ended o be anc cn nether be wed by a Pureuant oR Ce festa for he pupose of ave [DO NOT road, copy or cssaminat his coemenican une you Sf he Intended addressee. Th -alcomemunicatin conti casentl andr pivleged nforaton| Intent ony or tne aera, you havea Be onicin i aor, peass cass (ote! inet (702) 2€2711 ad ask speak to ha see of he ng {enmunioalon Aap pisase sabe naar are nly the sence imesatey hal you ave reseed ihe commooseavon a. hark you Magus Aura ‘omeys a3Exhibit B Election Integrity Violation ReportSECRETARY OF STATE BARBARA K. CEGAVSKE 401 N, Carson St. ‘Carsan City, NV 83701 ayolost@sos.nv.gov “wurw.nvsos. gor ELECTION INTEGRITY VIOLATION REPORT ‘The information you report on this form may be used to help us Investigate violations of Nevada election laws, When completed, mail, eral, or fax your form and supporting documents to the office listed above. Upon receipt, your complaint wil be reviewed by a member of our staff, The length ofthis process can vary depending on the circumstances and Ininrmatinn you previa with your coreplaint. The Oifice of the Secretary of State may contact you if additonal information fs needed. INSTRUCTIONS: Please TYPE/PRINT your complaint in dark ink. You must write LEGIBLY, Allfields MUST be completed. 715.834.5705, 7788865718 Sattaton: ©Mr. QMes. QMs. Oniss Timothy First “Your Organization, i any, Donald J. Trump for President, inc. 725 Fifth Avenue New York NY 10022 Sale Zip iy 617-303-6824 Work Fx Callme between Bam-fpm at; Heme Coll 4 Work [RYPE OF COMPLAIN] ‘Campaign Practices Voter Fraud Contributions / Expenses Initiative Referendum Petition Voter Registration Financial Disclosure Statoment v Other See attached letter. ‘Complana Form: Page Tot? Reve osr24n20%6‘SECTION 3. (COMPLAINT IS AGAINST] Please detail the nature of your complaint. Include the name and contact information (if known) of the individual, candidate, campaign, or group that is the subject of your complaint. Your ‘complaint must also include a clear and concise statement of facts sufficient to establish that the alleged violation occurred. Any relevant documents or other evidence that support your complaint should be listed and attached. You may attach additional sheets if necessary. See attached otter SECTION 4. Sign and late this form. The Secrotary of State's Office cannot process any unsigned, incomplate, or iitegible complaints, In order to resolve your complaint, we may send a copy of this form to the person or group about || whom you are complaining. | am fing this complaint fo notify the Office of the Secretary of State of the activites of a particular candidate, campaign, individual or group. | understand that the information contained in this complaint may be used to establish violations af Nevads law in both private and public enforcement actions. | authorize the Oifice of the Secretary of State to send my ‘complaint and supporting documents to the individual or group identified in this complaint By signing my name below, | certly under penalty of perjury thatthe information provided inthis complaint is true and correct othe best of my knowledge Asst, ds Timothy Jost Siaure Print 1106/2016 Bate Gamndahyyy Complain Fer: Page 1 of 2 Rew 08242056Exhibit C Letter from Timothy JostTRUMP MAKE AMERICA GREAT AGAIN! November 6, 2016 Nevada Secretary of State cio Elections Division 101 North Carson Street, Suite 3 Carson City, Nevada 89701-3714 nvelect@sos.nv.gov Re: Report of Election Violations by Joe P. Gloria, the Clark County Registrar of Voters Dear sir or madam: am writing on behalf of Donald J. Trump for President, Inc. to report egregious violations of Nevada election law by Joe P, Gloria, the Clark County Registrar of Voters (965 Trade Drive, Suite A, North Las Vegas, Nevada 89030). The violations in question were not random and neutral in their effect, but very much appear to have been intentionally coordinated with Democratic activists in order to skew the vote unlawfully in favor of Democratic candidates. We request an immediate investigation of these allegations, segregation and preservation of the ballots and voting machines involved, and curative instructions to and oversight of Mr. Gloria on Election Day. Factual Background For the final three days of the early voting period ending November 4, 2016, a temporary polling place was established at Cardenas Market located at 4421 East Bonanza Road, at the intersection of North Lamb Boulevard in Las Vegas. See Exhibit A at 7. Pursuant to Nev. Rev. Stat. § Mr. Gloria published the voting hours for the Cardenas Market location for November jam - 8pm.” See id Mr. Gloria instructed the poll workers, however, not to close the Cardenas Market polling place at the published closing time. Instead, Mr. Gloria kept the polling place open without public notice and allowed voters who arrived after the published closing time of 8:00 p.m, to cast non- provisional ballots. See Exhibit B 8; Exhibit C 12; Exhibit D 9 9-11; Exhibit Hf 8-10, Poll watchers estimate that up to 300 voters arrived after 8:00 p.m. and were allowed to cast non- provisional ballots. See Exhibit B 11. These voters appear to have strongly favored Hillary Clinton's presidential campaign, as the area around Cardenas Market is disproportionately Democratic. Mr. Gloria reportedly held open at least three other polling places in disproportionately Democratic areas (i.e., Deer Springs in North Las Vegas, the Silverado Ranch Plaza in Las Vegas, and on the Las Vegas Strip) the same evening. See Exhibit C §§ 6-7: Exhibit D4W?7, 12.Report of Election Violations November 6, 2016 When a poll watcher brought this violation of statutory procedures to the attention of the individual supervising the Cardenas Market polling place, the supervisor stated belligerently. “This location is staying open until ten and there is nothing you ean say or do about it.” see Exhibit C 14, and, “E don’t care what you think. We are going to let people vote here until 19:00 p.m..” see Exhibit H$ 8. The supervisor further stated that other polling places were being closed on time, and that he believed the selective closing of polling places was intended to assist Hillary Clinton's presidential campaign. See Exhibit B 10. Indeed, contemporaneous social media reports suggest that Democratic activists had been made aware of the extended polling hours, while Republican activists had not. See Exhibit D #13: Exhibit F. At approximately 9:45 p.m., all voters present had cast ballots and there were no more voters standing in line. A poll worker announced foudly that polling was closed and another poll worker closed the ropes surrounding the polling area. See Exhibit C 15; Exhibit H4}9. Several minutes later, however, additional voters appeared. The poll workers then reopened the polling place and allowed the new arrivals to cast non-provisional ballots, See Exhibit C 4 16; Exhibit H $10. Minutes later, a poll worker admitted that they should not have reopened the poiling place. ‘See Exhibit H§ 13. Furthermore, Democratic operatives brazenly handed out, to voters standing in line within the 100 foot radius of the Cardenas Market polling place, electioneering literature listing and recommending the Clark County Democratic Party's favored candidates. See Exhibit B§ 12; Exhibit G, Legal Analysis The Nevada Revised Statutes provides as follows: 1, The county clerk shall publish during the week before the period for early voting and at least once each week during the period for early voting in a newspaper of generat circalation « schedule stating: (a) The focation of each permanent and temporary polling place for early voting. (b) ‘The dates and hours that early voting will be conducted at each location. 2. The county clerk shall post a copy of the schedule on the bulletin board ased for posting notice of meetings of the board of county commissioners. The schedule must be posted continuously for a period beginning not iater than the fifth day before the first day of the period for early voting hy personal appearance and ending on the last day of that period. 4. No additional polling places for carly voting may be established after the schedule is published pursuant to this section. Nev. Rey, Stat, § 293.3576. The statutes further provide as follows:Report of Bieetion Violations November 6, 2016 If at the hour of closing the polls there are any registered voters waiting to vote, the doors of the polling place must be closed after all such voters have been admitted to the polling place. Voting must continue until shose voters have voted. Jad, § 293.305(1). Finally, the statutes provide as follows: During the time 2 polling place for early voting is open for voting, @ person may not eleotioneer for or against any candidate, measure or political party in or within 100 feet from the entrance to the voting area. Id. §293.361(0). Mr. Gloria’s operation of the Cardenas Market polling location gives rise to no fewer than three violations of Nevada election law. First, Mr. Gloria violated the law in extending polling hours beyond the 8:00 p.m. published cutoff time in violation of Nev. Rev. Stat. § 293.305(1). Although the voters physically standing in line at 8:00 p.m. were inarguably entitled to vote, see Nev, Admin, Code § 293.247(1}(2), poll workers were required under Nev. Rev. Stat, § 293.305(1) to “{close] the doors of the polling place” at 8:00 p.m., identify who the last person waiting to vote was af the time that the polls closed, and not admit additional voters into the waiting line. See also Nev. Admin. Code § 293.247. To be sure, Mr. Gloria could have published fonger voting hours for the Cardenas Market location pursuant to Nev. Rev. Stat. § 293.3576 so that voters of either major party arriving later than 8:00 could lawfully cast non- provisional ballots, but his unilateral and unpublished extension of polling hours exceeded his statutory authority. This is especially problematic because the selective, non-wniform process for closing polling places, especially in a manner that favors one political party over another, violates the Equal Protection Clause of the Fourteenth Amendment. See generally Bush v. Gore, 531 U.S, 98 (2000) (considering non-uniform voting procedures in Florida in connection with the 2000 presidential election). Second, even if Mr. Gloria had authority to unilaterally extend potling hours without publication, he erred in reopening the polling place for fate arrivals. He effectively created a new polling place from the time that the polls reopened at approximately 9:47 p.m. and the time that the polling place finally closed at approximately 9:50 p.m... without any public notice. This violated ‘the statutory requirement that “{nJo additional polling places for early voting may be established after the schedule is published.” See Nev. Rev. Stat. § 293.3576(4), Finally, Mr, Gloria clearly violated the law by allowing Democratic operatives to brazenly distribute the Clark County Democratic Party's literature in direct violation of the probibition on “electioncerfing] for. .. any candidate . .. within 100 feet from the entrance to the voting area.” Jd, § 293.361(1). As the elections officer responsible for ensuring the proper operation of polling places, it was Mr. Gloria's duty to monitor the activities of campaign operatives within the Cardenas Market polling place, and be failed to stop clearly illegal activities under his supervision.Report of Election Violations November 6, 2016 Conclusion Mr. Giloria's wanton disregard for Nevada election laws requires prompt remedial action by your office. Specifically, we ask that you take three steps without delay. First, your office should immediately investigate and confirm these allegations. Second, in order to preserve the status quo and the possibility of post-election legal challenges that may prevent Mr. Gloria’s misconduct from swinging the election in favor of his preferred candidates, your office should segregate and preserve the ballots and voting machines involved in the Cardenas Market fiasco and from the other three polling places that were unlawfully held open after their published closing dimes. Finally, your office should clearly instruct Mr. Gloria oa the proper conduct of polling places and deploy to his office a sufficient number of observers from your office to oversee his actions and ensure that he does not engage in similarly unlawful conduict on Election Day. Please do not hesitate to contact me if you require any further information Respectfully, és! Timothy Jost. Timothy Jost, Treasurer Donald J. Trump for President, Inc,Exhibit AGENERAL ELECTION EARLY VOTING Is OCTOBER 22 (SarurDAyY) TO NOVEMBER 4 (FRIDAY) VOTING IS EASY at the 97 convenient early voting sites or on Election Day at your poiting place. Any voter registered in Clark County may vote before Election Day at any early voting site. MALL EARLY VOTING SITES Early voting dates and hours for the three mall sites are: Saturdays, Ali Malls: 1st Week, All Malls: October 22... . 10am- 8pm October 24 - 28 (Nevada Day), October 29. . . 10am - Spm Monday to Friday... . . 10am - 8pm ys. Hours Vary by Mall, October 23 and 30: 2nd Week, All Malls: . Mall and Galleria at Sunset. Meadows Mall............... 10am - 6pm Boulevard Mall: East Corridor near Christy Candy and Rear (EAST) Mall Entrance, Park in the Back of the Mall, 3528 S. Maryland Pkwy. @ E. Twain Ave., LV. am - 6pm jovember 4, «10am - 9pm Meadows Mall: Sears Court, 1st Floor, 4300 Meadows Ln. @ S. ‘alley View Blvd, LY. Slike ces sy a eu toss) All of the seven shopping center sites below have the same hours of operation: Oct. 22 - Nov. 3 (Sat. -Thurs.): 9am - 7pm _/ Nov. 4 (Last Friday): 9am - 8pm Arroyo Market Square, Trailer in Parking Lot CC-215 @ S. Rainbow Blvd, Las Vegas Blue Diamond Crossing, Trailer in Parking Lot between Target and Kohl's Blue Diamond Rd. @ Arvile St,, Las Vegas Centennial Center, frailer in Parking Lot Near Home Depot W. Tropical Pkwy. @ Centennial Center Blvd, Las Vegas Deer Springs Town Center, Trailer in Parking Lot Near Michaels N. Sth St. South of CC-215 @ W. Dorrell Ln., North Las Vegas Downtown Summerlin Shopping Center, Traiier in Parking Lot South of Dillard’s Sahara Ave. @ CC-215, Las Vegas Lowe's at Tropicana Beltway Center, Trailer in Parking Lot near Lowe's 5050 S. Ft. Apache Rd. @ Tropicana Ave., Las Vegas Silverado Ranch Plaza, Trailer in Parking Lot Near PetSmart Fastern Ave. @ F. Silverado Ranch Rivd., Las Vegas Clark County, NY a 2016 General ElectionPUBLIC BUILDING EARLY VOTING SITES Clark County Government Center ‘Saturday, October 22 and 29... . am- 5pm Regional Transportation Sunday, October 23 and 30. CLOSED Commission (RTC) Building : Ast Floor, Room 108 Mondoy - Friday (EXCEPT the Lost Friday) October 24 - 28 (Nevada Day) and 600 S. Grand Central Pkwy. ore St nor @ W. Bonneville Ave,, Las Vegas a ee ee last Friday, November 4 . . 8am - 8pm East Las Vegas Community Center —_ Saturday, October 22 and 29... . 10am- 6pm 250 N. Eastern Ave. Si ti . @ Stewart Ave,, Las Vegas sunday, October 23 and 30. CLOSED ek AND Monday of 2nd Week Fri October 2a 128 Nex Dayland 31. . 9am - 6pm Tuesday - Thursday of 2nd Week November 1-3............9am- 7pm lost friday, November 4.2... . gam - 8pm Dr. William U. Pearson Saturdey-Sunday, October 22-23. . 9am - Spm Community Center* Mondoy-Fridoy Room C, 1625 W. Carey Ave. October 24-28 (Nevada Day}. . . . 9am - 7pm @ Martin Luther King Blvd., North Las Vegas “Open only on October 22-28 Doolittle Community Center” Soturduy, Octaber 29. . +... 9am- 5pm Room B, 1950 J St Sunday October 30.......... CLOS @ Lake Mead Bivd., Las Vegas eee eee “Open only on October 29 and October 31- November 4 Monday - Thursday October 31-November 3... . . 9am - 7pm Last Friday, November 4 ....... 9am- 8pm LAS VEGAS STRIP EARLY VOTING SITE Las Vegas Strip Saturday, October 22 and 29... . 9am- 7pm eee eee Sunday, October 23 and 30... . CLOSED West of Polaris Ave., Las Vegas Monday to Friday (E. 1 Lost Friday) October 24 - 28 (Nevada Day) and October 31 - November 3... .. 9am- 7pm Last Friday, November 4... ... 9am- 8pm Clark County, NY 2 2016 General Electionalee Te Sola VOTING SITES VOTING TIPS | + Lines are shorter in the afternoon or during the first week of early voting. + To minimize the time it takes to vote and as a courtesy to other voters, study, mark, and bring your sample baltot to the polls. Be prepared to vote. |. Don't wait until you're in the voting booth to make your decisions. + Conveniently find a wide variety of election related and voter registration information at www.ClarkCountyNV.gov/vote. DATE ZL LOCATION “ADDRESS L CROSS STREETS TIME OCTOBER 32 LCT TTT Albertsons Cheyenne / Durango Albertsons ~ Craig / Decatur Albertsons Craig / Tenaya Albertsons § pe DesertiInn / Pecos McLeod Albertsons Hualapai / Flamingo Albertsons 9) Stéphanie / Horizon Ridge 8am “6pm Buy Low Market Owens / H St. 9am - 7pm Desert Crossing Shop. Cte (taller) Desert'tnn / Decatur” vam = 7pm Las Vegas Athletic Club (fraile} +1725 N. Rainbow Bivd., South of Lake Mead Blvd. 9am - 7pm Laughlin Library Nellis Crossing Shop. Ctr. (f 2840'S, Needles Hwy., Laughlin 8am - 6pm Nellis / Charleston 9am - Tpm Seafood City Market 3890'S: Maryland Pkwy. / Katie 9am ~ 7pm Searchlight Community Cte. 200 Michael Wendell Way, Searchlight 10am - 3pm Vons ‘Winidimill Pkwy. / Pecos 8am - 6pm OCTOBER 23, SUNDAY : Albertsons Ann / Drexel 9am - 7pm Albertsons sve Cheyenne / Durango Bam - 6pm Albertsons Craig / Decatur 8am - 6pm Albertsons om Craig / Tenaya gam - 7pm Albertsons Desert Inn / Pecos McLeod 9am - 7pm Albertsons ©) Hualapal / Flamingo” 9am - 7pm Albertsons Stephanie / Horizon Ridge 8am - 6pm Buy Low Market» ‘Owens/H St. 3 gam 7pm Desert Crossing Shop. ctr. {liiter) Desert Inn / Decatur 9am - 7pm Las Vegas Athletic Club fiicile) 1725 N. Rainbow Blvd, South of Lake Mead Blvd, Sam - 7pm. Nellis Crossing Shop: Ctr. (Irailer). Nellis / Charleston 9am = 7pm Seafood City Market 3890 S. Maryland Pkwy. / Katie gam - 7pm vons y z Windmill Pkwy. / Pecos Bam“ bpm Clark County, NV 3 2016 General ElectionNEIGHBORHOOD EARLY VOTING SITES (conrnuep) Alberts rf pm Albertsons Cheyenne / Durango 8am-6pm Albertsons Craig / Decatur am - opm Albertsons Desert inn / Pecos McLeod Qam- 7pm Albertsons Hualapai / Flamingo 9am - 7pm Henderson'City Hall 240 S. Water St. / W. Basic 7:30am = 5:30pm Las Vegas Athletic Club (frailer) 1725 N. Rainbow Blvd, South of Lake Mead Blvd. | 9am - 7prn Nellis'Crossing Shop. Ctr. (Trailer) Nellis / Charleston 9am - 7pm Ney. St. College - Rogers Student Ctr. 1125 Nevada State Dr, Henderson Sam - 4:30pm Paradise Park Community Ctr. 4775'S. McLeod Dr, North of Tropicana Bam - 6pm Paseo Verde Library 280 S. Green Valley Pkwy. / Paseo Verde 10am - 8pm SkyView YMCA 3050 E. Centennial Pkwy. 9am- 7pm Sun iy HacDonald Ranch Community Cr. 2020 W. Horizon Ridge, Faso Green Vy Pe 8am - 6pm Spring Mountain Rd. / Rainbow Qam= 7pm OCTOBER 25, TUESDAY Aliante Library 2400 W. Deer Springs, West of Clayton 10:30am - 7:30pm Price Rec.Ctr 2050 Bonnie Ln. / . Lake Mead Blvd)? Canyon Ridge Church (Trailer) 6200 W. Lone Mountain Rd. / Jones Heritage Park’Sr. Facility 300'S. Racetrack Rd. / Burkholder Holy Spirit Lutheran Church 6670 W. Cheyenne Ave., East of Rainbow Nellis Crossing Shop. Ctr: (Trailer) Nellis / Charleston’ Nev. St. College - Rogers Studen! Cit. 1125 Nevada State Dr., Henderson gam - 4:30pm North Las VegasiCity Hall 2250 Las Veqas Blvd. N. / Civie Ct" 8am- Spm Paradise Park Community Ctr. 4775 S. McLeod Dr, North of Tropicana Bam - 6pm. Paseo Verde Library 280 S. Green Valley Pkwy. / Paseo Verde L0am='8pm Sahara West Library 9600 W. Sahara Ave. / Grand Canyon 11am ~-fpm SkyView YMCA 3050 £. Centennial Pkwy. gam - Tom Sun City MacDonald Ranch Community Ctr, 2020 W. Horizon Ridge, East of Green Vly. Pkwy. 8am - 6pm Target (Trailer) Spring Mountain Rd. / Rainbow gam 7pm “OCTOBER 26, WEDNESD, Alexander Library lexander Rd, West of ML King 10:30am Aliante Library 2400 W. Deer Springs, West of Clayton 10:30am = 7: 30pm Bob Price Rec. Ctr. 2050 Bonnie Ln. / E. Lake Mead Blvd. 8am - 6pm Canyon Ridge Church (Haile) 6200 W, Lone Mountain Rd: / Jones 9am= 7pm College of thn. Nev.(CSN)- N.Las Vegas. 3200 E. Cheyenne Ave. @ Pecos 8am - 6pm Heritage Park Sr. Facility 300 5. Racetrack Rd. / Burkholder Bam - 6pm Holy Spirit Lutheran Church 6670 W. Cheyenne Ave., East of Rainbow — 9am - 7pm La Bonita Supermarket (fraler) Rainbow / Flamingo gam= 7pm Paradise Park Community Ctr. 4775 S. McLeod Dr, North of Tropicana 8am - 6pm Sahara West Library 9600 W. Sahara Ave. / Grand Canyon 10am =Tpmr SkyView YMCA 3050 E. Centennial Pkwy. 9am - 7pm Solera Anthem Community Ctr. 2401 Somersworth Dr. / Solera Sky gam =6pm Trails Village Ctr. (Trailer) Village Ctr. Cir. / Trails Ctr, 9am - 7pm vons Sky Pointe / Buffalo gam’: 7pm Clark County, NV 4 216 General ElectionNEIGHBORHOOD EARLY VOTING SITES (conninueo) Nellis / Vegas Vailey ‘Alexander Library 1755 W. Alexander Rd, WestoML.King 10:30am = 1:30pm Bob Price Rec. Ctr. 2050 Bonnie Ln. / E. Lake Mead Blvd. 8am - 6pm. Canyon Ridge Church (irae) 6200.W. Lone Mountain Rd. / Jones gam= 7pm College of Sthin. Nev. (CSN)-N.Las Vegas 3200 E. Cheyenne Ave. @ Pecos 8am - 6pm Desert Vista Community Ctt 10360 Sun City Blvd. / Thomas W. Ryan 9am 7pm Holy Spirit Lutheran Church 6670 W. Cheyenne Ave., East of Rainbow = 9am- 7pm Bonita Supermarket {rile Rainbow / Flamingo Qam- 7pm Sahara West Library 9600 W. Sahara Ave. / Grand Canyon 40am - 7pm Solera Anthem Community Ctr” 2401 Somersworth Dr / Solera Sky 8am - 6pm Sun City Aliante Community Ctr. 7390 Aliante Pkwy. / Elkhorn Bam 6pm Trails Village Cte (aller) Village Cte Citi / Trails Ctr. 9am -Tpri Vons Sky Pointe / Buffalo gam - 7pm Winchester Cultural ctr: 3130 McLeod Dr, North of E, Desert inn Rd, 10am = 8pm Oct iDAY (Nevada Day Holiday) sis Albertsons Charleston / Sloan Sam - 7pm Albertsons" Charleston / Town Ctr. 8ain - 6pm. Albertsons College / Horizon Bam - 6pm Albertsons = Eastern / Warm Springs 8am - 6pm Albertsons Farm / Durango Sam - 7pm Albertsons 5 Laké Mead Blvd: / Hollywood Qari 7pm Aibertsons Nellis / Vegas Valley 9am - 7pm Albertsons Tropicana / Jones gam - Tpm Canyon Ridge Church (aller) 6200 W. Lone Mountain Rd. / Jones 9am - 7pm Desert Vista Community Ctr 10360 Sun City Blvd / Thomas W. Ryan 9am- 7pm Kmart (Iraiter) 2671 N. Las Vegas Blvd. / Evans Qam - 7pm . / Elkhorn Bam - 6pm. Sun City Aliante Community Ctr 7390 Aliante Pkt Trails Village Ctr. (Trailer) Village Cte. Cie / Albertsons Albertsons 5 Charleston / Town Ctr. Albertsons College / Horizon Albertsons Eastern’ / Warm Springs Albertsons Farm / Durango Albertsons Lake Mead Blvd. / Hollywood Albertsons Tropicana / Jones Chinatown Plaza 4215 Spring Mountain’ Rd. / Wynn Kmart iailer) 2671N. Las Vegas Blvd. / Evans Lowe's Parking Lot (Itiler) 2570€, Craig / Losee Min. Shadows Community Ctr. 9107 Dei Webb Blvd. / Crown Ridge Mtn.'s Edge Exploration Peak Park (Trailer) 9700 S. Buffalo Dr, South of Blue Diamond’ 9am - 6pm Sun City Aliante Community Ctr. 7390 Aliante Pkwy. / Elkhorn 8am - 6pm Trails Village Ctr. (ratler) village Ctr. Cir. / Trails Ctr, gam - rpm Clork County, NY 5 2016 General ElectionNEIGHBORHOOD EARLY VOTING SITES (conn Albertsons Albertsons Chatieston / Tow Ct Bam- ean Albertsons College / Horizon 8am - 6pm Albertsons Lake Mead Pkwy. / Boulder Hwy. gam = Tpm Chinatown Plaza 4215 Spring Mountain Rd. / Wynn 10am - 6pm Enterprise Library 25 £. Shelbourne Ave. / S. Las Vegas'Blvd, 40am = 6pm Kmart (Trailer) 2671 N. Las Vegas Blvd. / Evans gam - 7pm Lowe's Parking Lot (iaile) «2570 E. Craig / Losee 2am - 7pm Mtn. Shadows Community Ctr. 9107 Del Webb Blvd. / Crown Ridge gam - 7pm Mtn’s Edge Exploration Peak Park (railer) 9700'S. Buffalo Dr., South of Blue Diamond Sam~ 6pm Rainbow Library 3150 N. Buffalo Dr. / Cheyenne 40am - 6pm Southern Highlands Mktpl: (Waiter) Southern Highlands Pkwy. / Cactus Sam= 7pm Sun City Anthem Ctr 2450 Hampton Rd. / Anthem Pkwy. Sam - 6pm Whitney Library : 5175E. Tropicana, East of Nellis Loam = 5:30pm OCTOBER 31, MONDA' ssh sims i Albertsons Flamingo / Durango 8am - 6pm Albertsons 2 Lake Mead Pkwy. / Boulder Hwy. £ pm Boulder City, City Hall 401 California Ave, Boulder City 7am - 6pm Centennial Hilis YMCA 6601 N: Buffalo Dt: / Sky Pointe = Bam= 6pm Building © 700 College Dr @ Heather 9am~ 4:30pm ~0 25: Shelbourne AVE. /S. Las Vegas Bld? 0am ~ Tom Lakes Lutheran Church | 8200 W. Sahara Ave. / S. Cimarron 9am - 7pm Lowe's Parking Lot (rraléi)” ©" 25720 E. Craig / Losee* ye gam = 7pm Moapa Valley Community Ctr. 320 N, Moapa Valley Blvd., Overton Barn - 6pm Rainbow Library 3150N. Buffalo Dr. / Cheyenne 10am =7pmn Southern Highlands Mktpl. (Iiiler) Southern Hightands Pkwy. / Cactus am - Tpm Sum City Anthem Ctr. ° 2450 Hampton Rd. / Anthem Pkwy. 9° 9am “6pm. Whitney Library 5175 E. Tropicana, East of Nellis 10am - 7pm Whole Foods Marketplace {(Teoiter) 7290 W. Lake Mead B Blvd. / Tenaya “sam eh NOVEMBER 1 Albertsons Flamingo / Durango 8am - 6pm Boiilder City, City Halt 401 California Ave., Boulder City Tam = 6pm Centennial Hills YMCA 6601 N. Buffalo Dr. / Sky Pointe Bam - 6pm College of Sthn. Nev.{CSN}- Henderson Building C, 700 College Dr. @ Heather 9am - 4:30pm. lowe's Parking Lot (irailer) 2570 E. Craig / Losee Sam - 7pm Mesquite Deuce 2 Bldg. 150 N. Yucca St;, Mesquite» Bam* 7pm Rainbow Library 3150 N. Buffalo Dr. / Cheyenne 10am - 7pm Silver Mesa Rec. Ctr: 4025 Allen Ln. / Alexander Sam 7pm Silver Springs Rec. Ctr. 1951 Silver Springs Pkwy. / Pinion Springs 8am - 6pm Southern Highlands Mktpl. (Traifer) Southern Highlands Pkwy. / Cactus gam - 7pm Sun City Anthem Ctr. 2450 Hampton Rd. / Anthem Pkwy. gam - 6pm walnut Rec, Ctr Z 3075 N, Walnut Rd., South of Cheyenne 9am = 7pm West Charleston Library 6301 W. Charleston Blvd., Last of Torrey Pines. 10am - 7pm Whole Foods Marketplace (Mailer) 7290 W. iis Mead Blvd. / Tenaya 9am - 7pm Clark County, NV 2016 General ElectionNEIGHBORHOOD EARLY VOTING SITES (Cconnnuep) ibertsor Albertsons Albertsons Cardenas Market Centennial Hills YMCA Green Valley Library Lowe's Parking Lot (Trailer) Silver Mesa Rec. Ctr. Sun City Mesquite Target, Boca Park (trailer) UNLV Lied Library Veterans Memorial Leisure Ct Wainut Rec. Ctr. f Buffalo / Vegas Charleston / Rainbow: 4421 €. Bonanza Rd. / Lamb 6601 N. Buffalo Dr. / Sky Pointe 2197 N. Green Valley Pkwy./ Sunset 2570 E. Craig / Losee 4025 Allen Ln. / Alexander 1350 Flat Top Mesa Dr, Mesquite Charleston / Rampart Harmon St,, East of E. Swenson 101 N. Pavilion Ctr. De “/Alta 3075 N. Walnut Rd, South of Cheyenne Whale Foods Marketplace’ frail?) 7290 Wijkake Mead Blvd. / Tenaya NOVEMBER : Albertsons Albertsons Albertsons Cardenas Market Desert Breeze Community Ctr. Green Valley Library Hollywood Rec. Ctr. Lowe's Parking Lot (Trailer) Target, Boca Park {Irailer) UNLV Lied Library Veterans Memorial Leisure Ct Vons West Flamingo Senior Ctr. Whole Foods Marketplace (ial 3, TH Albertsons Albertsons Albertsons Cardenas Market Desert Breeze Community Ctr. Green Valley Library Hollywood Rec. Ctr. Lowe's Parking Lot (trailer) Target, Boca Park (Irailer) UNLV Lied Library Veterans Memorial Leisure Ctr Vons West Flamingo Senior Ctr. 219 6255 W. ‘Ann / Simmons 4421 E Bonanza Rd. / Lamb 8275 Spring Mtn. Rd. /S. Cimarron Rd. | Green valley Pkwy. / Sunset 1650 S. Hollywood, South of E. Charleston 25T0ECiaig’/ Losee Charieston / Rampart Harmon St; East of E. Swenson OLN, Pavilion Ctr. Dr. / Alta ~ Horizon / Horizon Ridge lamingo Rd. / Jones Lake Mead Blvd. / Tenaya’ Ann / Simmons Buffalo / Vegas! Charleston / Rainbow 4421 & Bonanza Rd. / Lamb 8275 Spring Mtn. Rd. /S. Cimarron Rd. 2797 N. Green Valley Pkwy. / Sunset 1650 S. Hollywood, South of E. Charleston 2570 E, Craig / Losee Charleston / Rampart _ Harmon St, East of E. Swenson 101 N. Pavilion Ctr, Or. / Alta Horizon / Horizon Ridge 6255 W. Flamingo Rd. / Jones Whole Foods Marketplace (fuile!) 7290'W, Lake Meal! Blvd. / Tenaya Clark County, NV pm Bam - 6pm gam - 7pm am - 7pm Bam - 6pm 10am - 7pm gam - Tpm gam = Tpm gam - Tpm gam = 7pm Bam - 5pm “gam=7pm 9am - 7pm gam = 7pm Bam - 6pm - Bam - 6pm gam - 7pm gam = Tpm gam - 7pm 1am= 7pm am - 6pm Sam - 7pm gam - Tpm 8am - 5pm gam - Tpm gam - 6pm 8:30am - 5:30pm gam - Tpm Bam - 7pm gam-Tpm 9am - 8pm gam = 8pm 9am - 8pm 10am = Tpit gam - Tpm 9am = 8pm 9am - 8pm 8am - Spm 9am - 8pm gam = Tpm 8:30am - 5:30pm Sani =Bpi 7 2016 General ElectionExhibit BDECLARATION OF RONALD KETCHAM, 1, RONALD RETCHAM, hereby declare as follows under penalty Of perjury; A 2. Ea 10, io The following statements are based on my personal knowledge, and if called to testify T could swear competently thereto. Taam ut least 18 years ofd and of sound mind, Lam a citizen of the United States and of the State of Nevada. I reside at 5013 Elm, Grove Drive, Las Vegas, Nevada 89130, which is located in Clark County. Tam aan eligible Nevada voter and am registered to vote. 1 submit this Declaration in support of the motion by Donald J. Trump For President, inc., seeking 4 declaratory judgment against the Clerk and Registrar of Voters of Clark County, Nevada, On November 4, 2016, at approximately 8:30 a.n., 1 personally appeared at the polling location for Precinot 4536 ut Cardenas Markel, 4421 E. Bonanza Road, Las ‘Vegas, Nevada 89110 and served as a poll watcher. ‘On November 4, 2016, voting at the Cardenas Market began just prior to 9:00 am. Heft the palling location at approximetely 6:00 p.m. and setumed at exactly #:00 p.m. 1 then remained af the potting location until it elosed at 9:50 pan. ‘The polling location at the Cardenas Market was scheduled to close at 8:00 p.m. aceording to the written materials distributed by the County of Clark. (See Valentine Declaration, Exhibit E.) 1 understood the law to require that, at 8:00 p.m., the last person in line should have been the last person permitted to vote, Around 5:00 pam,, the head of the polling ovation Joe) came over to talk to me ‘and the lead Democrat Party Observer, to inform us that he was instructed by the Registrar to keep this polling location open until the market closed at 19:90 p.m. ‘This would be two (2) hours beyond the designated closing time. ge also told me later that the voting area would remain open after the store closed if'there were voters in line and inside the store at 10:00 p.m, After 8:00 p.m, Joe expressed to me directly that other polling focations were being closed on time and voters stil fn line were instructed to come to this polling station. ‘He stated to me that he felt this selective closing was done to help Hillary Clinton, In my estimation, between 150 and 300 people entered the line after 8:00 p.m, The actual number contd. have been significantly higher. The line after $00 p.m. became larger than I had observed at any other point during the-day.12. Farlier in the afternoon on the same day, T personally witnessed young people associated with the democrat candidate for Senator, Catherine Cortez Masto, bend our balfpage documents that stated at the tap: “Clark County Democratic Party URGES YOU TO VOTE IN SUPPORT OF THE FOLLOWING CANDIDATES” (emphasis on the document). ‘Throughoat the aftemoon, f saw hundreds of voters standing in line holding this material, { witnessed a democrat po!l watcher hand ‘what I strongly believe was one of those sheets to a voter standing well within the 100” prohibited area for electioneeting, as the voter was at the:front of the line, 1 believe it was one of these sheets because they have a very untgue shape and appearance which makes them very distinguishable, @ copy of which is annexed as Exhibfe G to the motion seeking a Declaratory Judgment. Lhereby swear or affirm under penalty of perjury that the foregoing is true:and correct to ‘the best of my knowledge. Qs 9 6 Nevemdan 204% ‘Ronald KetchamExhibit CDECLARATION OF JESSE LAW 1, JESSE LAW, hereby declare as follows under penalty of perjury: 1 2. The following statements are based on my personal knowledge, and if called to testify 1 could swear competently thereto, Lam over 18 years old and of sound mind, 1am a citizen of the United States and of the State of Nevada, I reside 9599 West Charleston Boulevard 89117, which is located in Clark Conmty, Iam an eligible and registered voter in Clark County, Nevada. 1am the Director of Election Day Operations for the Donald J, Trump For President, Ine. campaign, | submit this Declaration in support of the motion by Donald J, Trump For President, fte.. seeking a declaratory judgment against the Clerk and Registrar of Voters of Clark County, Nevada. (On the eventing of Friday, November 4, 2016, at 8:10 pan., I was wotking at the Trump Headquarters in Las Vegas when we received calls from our poll watcher Ron Ketcham, eho wos stationed at the polling place located within Cardenas Supermarket, 4421 E Bonanza in North Las Vegas, and mother call fforn Michael Ding (a volunteer roving attomey for the Trump campaign, licensed to practice law ix Washington, D.C., and State of Tilinois), who was at the Deer Springs Long Term Barly Voting site in North Las ‘Vegas. Mr. Ketcham informed us that the site was saying they would stay open until 10:00 pam. Mr. Ding reported that a poll worker at the Deer Speings site informed him that they ‘would be staying open until 10:00 pan. or 11:00 pam, | wanted to confirm the report was not just isolated, an T drove to the Silverado Ranch Plaza, another polling location, located at 9845 8, Eastem Avenue in Las Vegas, There ‘was a long line, and { spoke toa site worker there who informecl me that people are allowed 10 enier the tine as long as there are people in line, no matter what time they arrive to the polling location, even if'it was after the required 8:00 p.m, closing time, 1 then drove to the Cardenas Market because the campaign was informed that the poll workers said they would stay open until 10:00 p.m, when the siore closes no matter what anyone says or does. Larrived at the Cardenas Market at approximately 9:05 p.m. 1 personally observed a large crowd of volunteers and political professionals outside of the 100-foot radius at a booth set ‘up promoting democrat senator Catherine Cortex Masto. I walked into the market through ‘the entrance that was closest to the polling location, T observed a Culinary Union official known to be a political director for the union and one of Masto’s chief campaign people, which I believed to be such as I was told this by a poll abserver, directing their volunteers10, a 12 1B. ca 1 16, ‘o hand out books and literature, and seemingly coordinating with the polling location management in what appeared to be violation of electionescing prohibitions Once inside the market, 1 was immediately greeted with a voter yelling “Hillary Hillery Hillary,” who was standing in a fine that was aot moving, with beiweon 100 to 150 vaters waiting fo vote, and democrat volunteers walking the Jines taking pictures and videos of the line or passing out cookies and water: I walked along the line, walked around the store, and I observed the Masto booth outside, Standing.at the end of the voting line, T witnessed the county official Lorena Pottilto talking to the democrat operatives and volunteers along the line while they were filming. While [was there over a period of 45 minutes, T observed over 30 but fewer than 40) new people get io line and the democrat volunteers distribute food and water. { recorded approximately 5 people get in line via video. 1 recorded democrat operatives and volunteers filming the fine, did not record the polling equipment nor people voting, These materials are available for an in camera inspection upon request. Tsaw Michael Chamberlain arrive at about 9:40 pum. and he and T observed a line that had ot moved more than ten feet in 20 minutes begin to rapidly move. We walked to the front, ‘and when there was one person in line, Mr. Chamberlain snapped 2 photos. The poll site manager “Joe” walked out of the polling location to tell Mr. Chamberlain he was not penniited to photograph the polling equipment. Mr. Chamberlain indicated that the site ‘cannot allow new people to enter the voter line after 8:00 p.m. ‘oe then shouted “this location is staying open until ten and there is nothing you can say or do about it” I pointed out to Joe that there was a gap in the line or. in-other words, there was now no one in line af all and that they were required to close the polling location. He ignored me. J went fo the fant of the empty line area and I filmed an empty line when people starting running up to get in ine again, Ms. Portillo then approached me and informed ine that fihning was not allowed. E said that she needs to close the site because there suas a gap in the line, She argued, {approached the local news media, Fox, sho suns there in the store and told the reponter what was happening, He said he thought they were closing the line. At that point, Joe closed the line by crossing the roped area and announcing that the polls were clased. Ms, Portillo told the site volunteers the line was closed and announced the same to those present in the supermarket. She then repeatedly said to Mr. Chaniberlain and me: “There, we are closed. You can leave now.” Mr. Chamberlain and I didnot leave. We abscrved Ms, Portillo within one ninute ushering three more people fo vote APTER SHE HAD ANNOUNCED CLOSING. Ms. Portillo then. got on the phone with who she said was her boss. Loverheard her say, “they are just ‘observing.” Poll workers allowed one more woman to vote, and so I asked this poll worker ‘why she closed the polling focation and then allowed more people to vote. She asked that Ttalk to her boss, after she made a call and handed me her phone, which indicated the callwas 10 “Joe Work.” It was Joo Gloria, who I know to be the Clark County Registrar of Voters. 1 did not engage in a conversation, J said what I had just observed Ms. Partita doing and that we would put these events into affidavits and submai chem to the courts, 17. Ms, Portillo then stopped one man from vating who returned to the voting table two more ‘times with different Union, Cortez-Masto or democrat officials. All of them were looking ‘at Ms. Portilio with 2 pleading fook in her eyes wondering if she would just let one more person vote, There was clear fumilisrity and cooperation. Isaw Ms, Portillo amounce that the polis closed a second time, At this time it was about 9:50 p.m. 1 heteby swear or alfitm under penalty of perjury that the foregoing fs true and correct to the best of my knowledge,Exhibit DDECLARATION OF JEANNE VALENTINE 1 JEANNE VALENTINE, hereby declare as follows under penalyy of perjury: 6. ‘The following statements are based on my personal knowledge, and if catled to tes could swear competently thereto, Fam over 18 years old and of sound mind, ‘Lam a citizen of the United States and of the State of California, } reside at 475 Lombard Street in San Francisco, California 94133, which is located int San Francisco County. [am attomey in good standing and lfeensed to practice in the State of New York. {ama volunteer lawyer for the Donald J. Trump For President, Inc. campaign, ‘1 submit this Declaration in support of the motion by Donald J. Tramp For President, Inc., seeking a declaratory judgment against the Clerk and Registrar of Clark County. On November 4, 2016, at approximately 7-00 pam., 1 was informed by Clark County, ‘Nevada poll watcher Ronald Ketcham that a particular polling place intended to remain open for voting past the mandated iaw requiring that polls clase at 8:00 p.m, The polling place in question was located at Cardenas: Market, 4421 E, Bonanza Road, Las Vegas, ‘Nevada 89110, On November &, 2016, at approximately 8:05 pam, { was informed by Clark County, Nevada poll watcher Michael Ding that he was told by a poll worker that the polling place Precinct 2446, located at Deer Springs Town Center, a trailer located at 7090 N Sth St, North Las Vegas, Nevade 89084, owas intending to stay open as long as necessaty, with 10 closing time, 10 allow any voter to vote who appeared at this location, all night if necessary. Michael said, essentially, the poll workers said that the Secretary of State had given them petinission to ignore the statate requiring that polls close at 8:00 p.m. ‘called the office of the Secreiaty of State at 8:10 p.m. but the office was closed. I then immediately called the Clark County Registrar of Voters, and a woman answered the phone, f asked her if potting locations were being permitted to remain open past 8:00 p.m., and she told me that as long as voters were in line, the polling locations were not allowed to close, | asked her if the last person in line st 8:00 p.m. was required to be identified and then that person would be the last voter allowed to vote, and she told me she was going to ‘band my call toa supervisor. then spoke with a gentleman who identified himsclfas Charles Hurley, the Assistant Clark ‘County Registrar of Voters. I repeated my question and he expressly told me that polls do not close on the last day of carly voting until everyone gets a chance to vote. I presented the following hypothetical scenario: ifa person who worked until 9:30 pan., who obviously ‘was not in ling to vote at 8:00 p.m., or even at 9:00 p.m. appeared at a polling loeation