Case: 2:14-cv PCE-NMK Doc #: Filed: 06/30/14 Page: 1 of 19 PAGEID #: 475

Transcription

1 Case: 2:14-cv PCE-NMK Doc #: Filed: 06/30/14 Page: 1 of 19 PAGEID #: 475 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 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 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 1

2 Case: 2:14-cv PCE-NMK Doc #: Filed: 06/30/14 Page: 2 of 19 PAGEID #: 476 Machine s search page, 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 bottomright 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. 2

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

4 Case: 2:14-cv PCE-NMK Doc #: Filed: 06/30/14 Page: 4 of 19 PAGEID #: 478 Cuyahoga County Early In-Person Voting Hours,

5 Case: 2:14-cv PCE-NMK Doc #: Filed: 06/30/14 Page: 5 of 19 PAGEID #: 479 Franklin County Early In-Person Voting Hours,

6 Case: 2:14-cv PCE-NMK Doc #: Filed: 06/30/14 Page: 6 of 19 PAGEID #: 480 Hamilton County Early In-Person Voting Hours,

7 Case: 2:14-cv PCE-NMK Doc #: Filed: 06/30/14 Page: 7 of 19 PAGEID #: 481 Summit County Early In-Person Voting Hours,

8 Case: 2:14-cv PCE-NMK Doc #: Filed: 06/30/14 Page: 8 of 19 PAGEID #: 482 Lucas County Early In-Person Voting Hours,

9 Case: 2:14-cv PCE-NMK Doc #: Filed: 06/30/14 Page: 9 of 19 PAGEID #: 483 Greene County Early In-Person Voting Hours,

10 Case: 2:14-cv PCE-NMK Doc #: Filed: 06/30/14 Page: 10 of 19 PAGEID #: 484 Butler County Early In-Person Voting Hours,

11 Case: 2:14-cv PCE-NMK Doc #: Filed: 06/30/14 Page: 11 of 19 PAGEID #: 485 Cuyahoga County Early In-Person Voting Hours,

12 Case: 2:14-cv PCE-NMK Doc #: Filed: 06/30/14 Page: 12 of 19 PAGEID #: 486 Franklin County Early In-Person Voting Hours,

13 Case: 2:14-cv PCE-NMK Doc #: Filed: 06/30/14 Page: 13 of 19 PAGEID #: 487 Hamilton County Early In-Person Voting Hours, 2010 (Early in-person voting hours were pulled from two sources) 13

14 Case: 2:14-cv PCE-NMK Doc #: Filed: 06/30/14 Page: 14 of 19 PAGEID #: 488 Hamilton County Early In-Person Voting Hours, 2010 (Early in-person voting hours were pulled from two sources) 14

15 Case: 2:14-cv PCE-NMK Doc #: Filed: 06/30/14 Page: 15 of 19 PAGEID #: 489 Summit County Early In-Person Voting Hours,

16 Case: 2:14-cv PCE-NMK Doc #: Filed: 06/30/14 Page: 16 of 19 PAGEID #: 490 Montgomery County Early In-Person Voting Hours,

17 Case: 2:14-cv PCE-NMK Doc #: Filed: 06/30/14 Page: 17 of 19 PAGEID #: 491 Lucas County Early In-Person Voting Hours,

18 Case: 2:14-cv PCE-NMK Doc #: Filed: 06/30/14 Page: 18 of 19 PAGEID #: 492 Greene County Early In-Person Voting Hours,

19 Case: 2:14-cv PCE-NMK Doc #: Filed: 06/30/14 Page: 19 of 19 PAGEID #: 493 Cuyahoga County Early In-Person Voting Hours,