Memo

For: ​All interested parties
By:​ Scott Dworkin, Senior Advisor
RE:​ DoJ, FBI Complaints Filed Against Trump for Violating Voting Rights Act
Date:​ October 24, 2016
Executive Summary
Over the weekend, the Democratic Coalition Against Trump filed complaints against Donald Trump with the
United States Department of Justice Civil Rights Division and with the FBI Public Corruption Unit for violations of
the Voting Rights Act of 1965, which guarantees the right to vote for all citizens. The complaints were filed as a
reaction to Donald Trump’s call for his supporters to go out and “watch the polls,” which will prevent citizens from
exercising their right to vote. The full complaint filed with the both the DoJ and the FBI can be found below.
Please reach out to us with any questions or concerns by contacting Francesca Lucia, (914) 618-0446,
francesca@keepamericagreat.us​.
Copy of Complaint
This complaint is against Donald Trump and his campaign for voter intimidation and suppression nationally.
Trump has encouraged his supporters to "go over and watch" polling places, the implication being to instill fear
specifically to minority communities in the inner cities.
(​https://www.washingtonpost.com/news/post-politics/wp/2016/10/01/trump-urges-supporters-to-monitor-polli
ng-places-in-certain-areas/​).
By encouraging his supporters to go out and watch polling places, Donald Trump is violating the Voting Rights Act
of 1965. Based on the history of violence at Donald Trump rallies and similar events, which Donald Trump has
egged on on multiple occasions, it can be safely assumed that voters who hear that there will be Trump supporters
watching their polling place will stay home out of fear of potential violence, therefore preventing them from casting
their vote.
Section 11 (b) of the Voting Rights Act of 1965 states:
(b) No person, whether acting under color of law or otherwise, shall intimidate, threaten, or coerce, or attempt to
intimidate, threaten, or coerce any person for voting or attempting to vote, or intimidate, threaten, or coerce, or
attempt to intimidate, threaten, or coerce any person for urging or aiding any person to vote or attempt to vote, or
intimidate, threaten, or coerce any person for exercising any powers or duties under section 3(a), 6, 8, 9, 10, or 12(e).
Donald Trump is violating this section, and should be held accountable immediately.
***FOR INTERNAL USE ONLY – NOT FOR DISTRIBUTION***

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