You are on page 1of 76

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 1 of 76

Exhibit 1
DOCUMENTS RESPONSIVE
TO REQUEST NO. 1

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 2 of 76

Exhibit A

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 3 of 76


Gmail - NV training material

11/3/16, 6:33 AM

M Gmail
NV training material
Mike Roman <mroman@donaldtrump.com>
Sun, Oct 23, 2016 at 5:19 PM
To: "Ann@annbrowning.com" <Ann@annbrowning.com>, "heatherflick@gmail.com" <heatherflick@gmail.com>,
"jesse.law@gmail.com" <jesse.law@gmail.com>

Created by HQ. Please review, amend, and use as needed.

MR

2 attachments
41 Nevada Poll Watcher Training Slides.pptx
274K
Nevada Poll Watcher Guide.docx
39K

Ann Browning <ann@annbrowning.com>


Sun, Oct 23, 2016 at 5:20 PM
Reply-To: Ann Browning <ann@annbrowning.com>
To: Mike Roman <mroman@donaldtrump.com>, "Ann@annbrowning.com" <Ann@annbrowning.com>,
"heatherflick@gmail.com" <heatherflick@gmail.com>, "jesse.law@gmail.com" lesse.law@gmail.com>
Thanks!

From: Mike Roman <mroman@donaldtrump.com>


To: "Ann@annbrowning.com" <Ann@annbrowning.com>; "heatherflick@gmail.com" <heatherflick@gmail.com>;
"jesse.law@gmail.com" <jesse.law@gmail.com>
Sent: Sunday, October 23, 2016 5:19 PM
Subject: NV training material

Created by HQ. Please review, amend, and use as needed.


MR

https://mail.google.com/mail/u/0/?ui=2&ik=064b61f645&view=pt&as_...&th=157f4Oec13e8a65e&sim1=157f4Oec13e8a65e&sim1=157f40f745e16505

Page 1 of 2

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 4 of 76


Gmail - NV training material

https://mail.google.com/mail/u/0/?ui=2&ik=064b61f645&view=pt&as_...th=157f4Oec13e8a65e&sim1=157f4Oec13e8a65e&sim1=157f40f745e16505

11/3/16, 6:33 AM

Page 2 of 2

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 5 of 76

Nevada Poll Watcher Training

MAKE AMERICA GREAT AGAIN!


2416

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 6 of 76

Poll Watchers Are The First Line Of Defense


oPart of a coordinated system to quickly detect, mitigate, and
document unintentional or intentional election-related
disruptions that arise during the registration, voting, and
counting periods.
oProgram goal is to ensure a fair and open process where every
person entitled to vote has the opportunity to legally cast a
ballot and have that ballot counted properly.

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 7 of 76

Low on
Ballots

County
Election
Official
sends more
ballots

omman
Center Call
County
Election
Official

Command Center sends


lawyer to ensure more
ballots arrive, resolve
disputes on proceeding if
run out of ballots, and
record events
Observer
Calls
Command
Center
Lawyers provide :_
record of events to,
litigators if needed
for court

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 8 of 76

Poll Watchers Do Not.


oWe do not and will not tolerate any voter intimidation or
suppression.
oNo person should interfere with any individual's right to legally
cast a ballot.
No person should interfere with or delay the legal voting
process.

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 9 of 76

Rules Regarding Poll Watchers


Poll watchers are permitted to:
0 Observe the conduct of the election.
o View the posted roster of registered voters in the precinct.
o The roster will be updated at several points during Election Day to.
reflect who in the precinct has already voted.

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 10 of 76

Rules Regarding Poll Watchers

oEach poll watcher must sign and file a form with the Secretary
of State prior to Election Day.
oEach poll watcher must wear a name tag while in the polling
place.
OPoll watchers must remain within the area designated for

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 11 of 76

Rules Regarding Poll Watchers


Poll watchers are prohibited from:
o Speaking/interacting with any voters.
o Touching or handling ballots or other voting equipment.
o Wearing campaign gear (e.g., clothing, buttons, etc.).
o Using cell phone or other electronic device inside the polling place.
o Taking photographs or video inside the polling place.
Attempting to determine for which candidates a person has voted.
Asking for or writing down any personally identifying information about any voter.
01

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 12 of 76

If You See Something, Say Someth'ng


o If you see a problem and the poll official does not resolve it
quickly, call the Command Center.

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 13 of 76

Rules Regarding Voters


o Voters are entitled to:
o Receive a replacement ballot if the original ballot is spoiled.
o Cast a provisional ballot if registration or identity is in question.
o Bring voting aid materials (e.g., sample ballot) into the booth.
0 Voters are prohibited from:
Engaging in any electioneering activityl o include wearing political buttons,
pins, Fiats, etc or solicitation within 100 feet of the polling place.
to

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 14 of 76

Polling Place Process


0 Voters generally are not required to present an I.D. in order to'vote.
o The .onlv exception is that individuals who reggistered to vote by maiLand who have not
previouSlv voted at a poiorm place must present some form of I.u. he I.U. need not
paystub, etc. is acceptable).
contain a- photo (a utility

o The voter mu$t sign theiolling place Ms er. Thepoll worker then checks the
si nature against-the 1 ature containe in the voter's re 'station record or the
presented by e voter (e.g., dr er's license).
si nature on a Corm ot
natureso not match, the poll worker may ask the voter a series ofquestions to
or her entity.

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 15 of 76

Polling Place Process


e oli workers are unable to. c.onfirrn th.is
at
.-registerecl- o-vote.M.the..precinct
voter may vote only oy provisiona a
o A yoter who presents at the wrong precinct must be informed of. is correct precinct.and must be
'wormed that any provisional balio.t cast at the wrong precinct witi no e counted. it the voter
chooses to vote rn the wrong precinct, he may cast only a provisiona allot.

o If a voter moved into the precinct before Election Day but has not yet updated his voter registration
record, he must vote in his old precinct.

poll, workers,. ..a.


rovitional- ballot m s complete and
ai he pollworker must prQv.i e the voter with a receipt that contains a unique
te voter c n
enti
Li mber for the provisionalballot and information on how a
etermine whether or .not t e provisional ballot is counted.

Vet rs . ca Ling

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 16 of 76

Voter Challenges
Poll watchers generally are not permitted to challenge the qualifications of a
voter.
A poll watcher may, however, challenge a voter if the poll watcher is a registered voter in
the precinct where he is serving as an observer.

There are two permissible reasons for challenging a voter:


The voter is:.not the.peron..01e. claims to be.
The voter has already voted in this election.

Challenged voters will be issued a ballot if they sign an affidavit affirmin


t

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 17 of 76

Issues to Monitor Hours of Operation


Polls not o ening/closing on time.
oPolls must open at 7am.
oPolls close at 7pm. Voters in line by 7pm may vote.
oIf a court orders polls to remain open after 7pm, voters
must vote rovis o al ballots that are segregated from all

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 18 of 76

ssues to Monitor E ectioneeringActivity


oCampaigning/electioneering/solicitation by any person is
prohibited within 100 feet of polling place.
oWearing political attire/materials or even discussing politics is
prohibited.

-5-Y11-f,...

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 19 of 76

Issues to Monitor Improper Voter Assistance


Voters with a physical disability or who do not speak English
may receive assistance in completing and casting their ballot.
A poll worker or another person chosen by the elector may assist (but
not persuade), the voter throughout the voting process.
But: a voter's employer or an official of a labor union to which the voter belongs
ay not row ,assistance
vote

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 20 of 76

Issues to Monitor Voter Already Cast Ballot


o A voter who has already voted an early or absentee ballot is not entitled to
vote a regular ballot on Election Day.
o A voter who has not yet voted an absentee ballot may vote in person if
they have returned the ballot to the election board in the voter s precinct.
A voter who received an absentee ballot but who has not yet returned it
may be given a regular ballot at the polling place if the voter:

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 21 of 76

ssues to Monitor Miscellaneous


Please immediately report any instances of the following:
Shortage of ballots.
Malfunctioning voter equipmen
ong lines.

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 22 of 76

o If you have questions before Election Day, please contact


[Insert name and contact info]

AtrAk-44-4;*11..

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 23 of 76

TRUMP
PENCE
MAKE AMERICA GREAT AGAIN!
2016

Nevada Poll Watcher Guide


Rules Regarding Poll Watchers

We do not and will not tolerate any voter intimidation or suppression.

No person should interfere with any individual's right to legally cast a ballot.
No person should interfere with or delay the legal voting process.

Poll watchers must have filed an acknowledgment form with the Secretary of State
prior to election day, and must wear a name tag while inside the polling place.

Poll watchers are permitted to:


o Observe the conduct of the election.
o View the precinct register to see who has voted and who is registered in the
precinct.
o

Pose questions directly to the polling place officials for resolution.

Poll watchers are prohibited from:


o Speaking/interacting with any voters.
o

Wearing campaign gear (e.g., clothing, buttons, etc.).

o Touching any ballots or voting equipment.


o Taking photographs or videos inside the polling place.
o Using cell phones or electronic devices inside the polling place.

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 24 of 76

What To Look For

Campaigning/electioneering/solicitation by any person is prohibited within 100 feet


ofpolling place.

All persons (including voters) are prohibited from wearing political attire within 100
feet of the polling place.

Voters generally are not required to show an I.D. at the polling place.

If the poll workers are unable to confirm that a voter is registered to vote in the
precinct, the voter may only vote a provisional ballot.
o Voter must complete and sign, in front of the poll worker, an affidavit. The poll
worker must indicate why the voter is voting a provisional ballot.
o The sealed provisional ballot envelope must be placed in a ballot box to be
reviewed by the county canvassing board before being counted.

Voters who are physically disabled or who do not speak English may receive
voting assistance from either election officials or another person of voter's
choosing.
o If one person (other than a poll worker) is assisting multiple voters, contact the
Command Center.

A voter who has already voted an early or mail-in ballot is not entitled to vote a normal
ballot on Election Day.

A voter who has been issued an unreturned mail-in ballot may vote a normal ballot only
if he (a) provides proof of I.D., and (b) signs an affidavit saying he has not already
voted.

Polls close at 7:00 P.M. but voters in line by then may vote.
o If a court orders polls to remain open after 7:00 P.M., voters must vote
provisional ballots that are segregated from all other ballots.

Paid for by Donald J. Trump for President, Inc.

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 25 of 76

Exhibit B

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 26 of 76


11/3/16, 7:00 AM

Gmail - Poll watcher material

M Gmail
Poll watcher material
Jesse Law <jesse.law@gmail.com>
To: jon.staab@nevadagop.org

Mon, Oct 31, 2016 at 3:58 PM

3 attachments
Nevada Poll Watcher Guide.docx
36K
djt intake poll watch.docx
123K
ai Nevada Poll Watcher Training Slides.pptx
274K

Jesse law <jesse.law@gmail.com>


To: Michael Ding <ding.michael@gmail.com>

Mon, Oct 31, 2016 at 6:00 PM

Sent from my iPhone


Begin forwarded message:
From: Jesse Law <jesse.law@gmail.com>
Date: October 31, 2016 at 3:58:05 PM PDT
To: jon.staab@nevadagop.org
Subject: Poll watcher material

3 attachments
io Nevada Poll Watcher Guide.docx
36K
djt intake poll watch.docx
https://mail.google.com/mail/u/Onui=28tik=064b61f6458eview=pt&q=n m1=1581cf6ca3a9017581sim1=1581d6712c76172484sim1=1581d8bc767f55a8

Page 1 of 2

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 27 of 76


Gmail - Poll watcher material

11/3/16, 7:00 AM

123K
41 Nevada Poll Watcher Training Slides.pptx
274K

Michael Ding <ding.michael@gmail.com>


To: Jesse law lesse.law@gmail.com>

Mon, Oct 31, 2016 at 6:40 PM

Thanks! Edgar is trained.


[Quoted text hidden]

https://mail.google.com/mail/u/Onui=2&ik=064b61f645&view=pt&g=...m1=1581cf6ca3a90175&sim1=1581d6712c761724&sim1=1581d8bc767f55a8

Page 2 of 2

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 28 of 76

What To Look For

Nevada Poll Watcher Guide


Rules Regarding Poll Watchers
We do not and will not tolerate any voter intimidation or suppression.
No person should interfere with any individual's right to legally cast a
ballot.
No person should interfere with or delay the legal voting process.
Poll watchers must fill out acknowledgment form with the County Registrar prior to
Poll watching, and must wear a name tag while inside the polling place. The form and
name tag is provided at the polling location
Poll watchers are permitted to:
o Observe the conduct of the election.
o View the precinct register to see who has voted and who is registered in the
precinct.
o Pose questions directly to the polling place officials for resolution.
Poll watchers are prohibited from:
o Speaking/interacting with any voters.
o Wearing campaign gear (e.g., clothing, buttons, etc.).
o Touching any ballots or voting equipment.
o Taking photographs or videos inside the polling place.
o Using cell phones or electronic devices inside the polling place.

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 29 of 76

Campaigning/electioneering/solicitation by any person is prohibited within 100 feet


ofpolling place.
All persons (including voters) are prohibited from wearing political attire within 100
feet of the polling place.
Voters generally are not required to show an I.D. at the polling place.
If the poll workers are unable to confirm that a voter is registered to vote in the
precinct, the voter may only vote a provisional ballot.
o Voter must complete and sign, in front of the poll worker, an affidavit. The poll
worker must indicate why the voter is voting a provisional ballot.
o The sealed provisional ballot envelope must be placed in a ballot box to be
reviewed by the county canvassing board before being counted.
Voters who are physically disabled or who do not speak English may receive
voting assistance from either election officials or another person of voter's
choosing.
o If one person (other than a poll worker) is assisting multiple voters, contact the
Command Center.
A voter who has already voted an early or mail-in ballot is not entitled to vote a normal
ballot on Election Day.
A voter who has been issued an unreturned mail-in ballot may vote a normal ballot only
if he (a) provides proof of I.D., and (b) signs an affidavit saying he has not already
voted.
Polls close at 7:00 P.M. but voters in line by then may vote.
o If a court orders polls to remain open after 7:00 P.M., voters must vote
provisional ballots that are segregated from all other ballots.

Paid for by Donald J. Trump for President, Inc.

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 30 of 76

TRUMP
MAKE AMERICA GREAT AGAIN!

Name:

Phone:

Email:

Area in LV:
Precinct #:

Address:
Preferred Poll Watch Days/Times:
10/26

AM

PM

10/27

AM

PM

10/28

AM

PM

10/29

AM

PM

10/30

AM

PM

10/31 AM

PM

11/1

AM

PM

11/2

AM

PM

11/3

PM

11/4

AM

PM

AM

Tuesday 11/8 7A 11A 3P

During early voting, polls open from 8-10:30AM and close as late as 9PM. We ask that you commit to at
least 5 hours. Clark County has 28 early vote locations per day and 280 polling locations on November 8.
Your participation is crucial to keeping the election fair and honest.

Will you poll watch for at least 5 hours at a time?


Preferred volunteer location?
Notes /other considerations:

Stand for long periods?

Refer more Poll Watchers:

In office use
Attorney?

Date Trained:

Confirm each poll shift:

Paid for by Donald J. Trump for President, Inc.

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 31 of 76

Nevada Poll Watcher Training

TRUMP
PENCE
MAKE AMERICA GREAT AGAIN!

2 01 6

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 32 of 76

Poll Watchers Are The First Line Of Defense


oPart of a coordinated system to quickly detect, mitigate and
document unintentional or intentional election-related
disruptions that arise during the registration, voting, and
counting periods.
oProgram goal is to ensure a fair and open process where every
person entitled to vote has the opportunity to legally cast a
ballot and have that ballot counted properly.

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 33 of 76

County
Election
Official
sends more
ballots

Command Center sends


lawyer to ensure more
ballots arrive, resolve
disputes on proceeding if
run out of ballots, and
record events

Lawyers provide
record of events to
litigators if needed
m?-:-'t?
for court

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 34 of 76

Poll Watchers Do Not. .


0 We do not and will not tolerate any voter intimidation or
suppression.
o No person should interfere with any individual's right to legally
cast a ballot.
0 No person should interfere with o delay the legal voting
process.

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 35 of 76

Rules Regarding Poll Watchers


oPoll watchers are permitted to:
0 Observe the conduct of the election.
oView the posted roster of registered voters in the precinct.
o The roster will be updated at several points during Election Day to
reflect who in the precinct has already voted.

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 36 of 76

Rules Regarding Poll Watchers

oEach poll watcher must sign and file a form with the Secretary
of State prior to Election Day.
oEach poll watcher must wear a name tag while in the polling
place.
Poll watchers must remain within the area designated for

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 37 of 76

Rules Regarding Poll Watchers


Poll watchers are prohibited from:
o Speaking/interacting with any voters.
o Touching or handling ballots or other voting equipment.
o Wearing campaign gear (e.g., clothing, buttons, etc.).
o Using cell phone or other electronic device inside the polling place.
o Taking photographs or video inside the polling place.
Attempting to determine for which candidates a person has voted.
Asking for or writing down any personally identifying information about any voter.
Challengingor arguing

"signs of polling place officials.

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 38 of 76

Azeoep.:141.4.1-.

If You See Someth


o If you see a problem and the poll official does not resolve it
quickly, call the Command Center.

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 39 of 76

Rules Regarding Voters


o Voters are entitled to:
o Receive a replacement ballot if the original ballot is spoiled.
o Cast a provisional ballot if registration or identity is in question.
o Bring voting aid materials (e.g., sample ballot) into the booth.
o Voters are prohibited from:
ing in any electioneering activity to include wearing political buttons,
ats, etc.)or solicitation within 100 feet of the polling place.

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 40 of 76

Polling Place Process


0 Voters generally are not required to present an ID. in order to vote.
o The .only exception is that individuals who registered to vote IN maiLand who have not
prevaouSIv voted at a, poiljng place must resent some form on.u. I he I.U. need not
contain g photo (a utility bilT, paystub, etc. is acceptable).

o T.he voter must sign theiolling place Ms er. The poll worker then checks the
signature again.stine N ature containe in the voter's re istrat on record or the
. presented by e voter (e.g., driver's 'cense).
si nature on a Corm of
If the' si natures .do not match, the poll worker may ask the voter a series o
verity h or her identity.

11%*
4,
E4'715..: ;:f1
4:93.
:eall
P.
'

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 41 of 76

''5 1:,:'Lf:20:4;',...4 -4

Polling Place Process


the oa i workers are unable to. c.onfirm that a person is registered to vote in the precinc
e voter may vote only by provisional baliot.
o A oter wh.o presents at the wrong.precinct must be informed of is correct precinct A. ncei r\Tistrbe
provisional ballOX cast at the wrong precinct witi not be counted. it ti
wormed that

voceIn the wrong precinct, he may cast Only a provisional ballot.


chooses to vote

If a voter moved into the prenct before Election Day but has not yet updated his voter registration
record, he must vote in his old precinct.

Vet.rs ca ting a provisional ballot must complete and si n,,in front of poll workers, a
ida it. the poll worker must rvide he vOter with a r cei t thatcontains a unique
and information on how the voter can
enti 'cation. number for the pr
it as counteoi.
er or not the p
etermine

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 42 of 76

Voter Challenges
Poll watchers generally are not permitted to challenge the qualifications of a
voter.
A poll watcher may, however, challenge a voter if the poll watcher is a registered voter in
the precinct where he is serving as an observer.

There are two permissible reasons for challenging a voter:


The voter is .not..the..perori.s./hp claims. to be.
The voter has already voted in this election.

Challenged voters will be issued a ballot if they sign an affidavit affirming that
b

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 43 of 76

ssues to Monitor Hours of Operation

Polls not opening/closing on time.


oPolls must open at 7am.
OPolls close at 7pm. Voters in line by 7pm may vote.
oIf a court orders polls to remain open after 7pm, voters
must vote provisional ballots that are segregated from, all

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 44 of 76

ssues to Monitor

Electioneering Activity

oCampaigning/electioneering/solicitation by any person is


prohibited within 100 feet of polling place.
oWearing political attire/materials or even discussing politics is
prohibited.

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 45 of 76

ssues to Monitor Improper Voter Assistance


Voters with a physical disability or who do not speak English
may receive assistance in completing and casting their ballot.
A poll worker or another person chosen by the elector may assist (but
not persuade), the voter throughout the voting process.
But: a voter's employer or an official of a labor union to which the voter belongs

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 46 of 76

Issues to Monitor Voter Already Cast Ballot


o A voter who has already voted an early or absentee ballot is not entitled to
vote a regular ballot on Election Day.
o A voter who has not yet voted an absentee ballot may vote in person if
they have returned the ballot to the election board in the voter s precinct.
A voter who received an absentee ballot but who has not yet returned
may be given a regular ballot at the polling place if the voter:

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 47 of 76

ssues to Monitor Miscellaneous


Please immediately report any instances of the following:
Shortage of ballots.
Malfunctioning voter equipmen
Unusually long lines.

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 48 of 76

Questions
oIf you have questions before Election Day, please contact
oJesse Law 702-715-1401
oNEVADA COMMAND CENTER HOTLINE

775 204 0500

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 49 of 76

Exhibit C

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 50 of 76


Gmail - TrumpElection Day Poll Watching EMAIL #1 (response needed)

11/3/16, 8:01 AM

M Gmail
TrumpElection Day Poll Watching EMAIL #1 (response needed)
Jesse Law <jesse.law@gmail.com>
To: Jesse Law <*esse.law mail.com>
Bcc:

Tue, Nov 1, 2016 at 4:35 PM

Team Trump Nevada!


I wanted to send out a quick note and let you know that we have begun the arduous work of prioritizing precincts for
coverage on Election Day.
I also wanted to write and ensure that you know we have your email and we should have assignments begin to be
released as early as tomorrow.
I wanted to remind you that if you have any folks that can join us for election day poll watching, they are needed!
Thanks for all of your help, and MAGA!
Jesse Law
https://mail.google.com/mail/u/0/?ui=2&ik=064b61f645&view=pt&search=sent&msg=158223fa99410870&sim1=158223fa99410870

Page 1 of 2

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 51 of 76


Gmail - TrumpElection Day Poll Watching EMAIL #1 (response needed)

11/3/16, 8:01 AM

Election Day Operations


7027151401

https://maiLgoogle.com/mail/u/0/?ui=2&ik=064b61f64581yiew=pt&search=sent&msg=158223fa994108708Lsim1=158223fa99410870

Page 2 of 2

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 52 of 76

Exhibit D

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 53 of 76


Gmail - (no subject)

11/3/16, 6:56 AM

M Gmail
(no subject)
Jesse Law <jesse.law@gmail.com>
To: Jon Staab <jon.staab@nevadagop.org>

Wed, Nov 2, 2016 at 6:01 PM

ai Nevada Poll Watcher Training Slides.pptx


273K

https://mail.google.com/mail/u/0/?ui=2&ik=064b61f645&view=pt&search=sent&th=15827b43fa6594f7&sim1=15827b43fa6594f7

Page 1 of 1

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 54 of 76

Nevada Poll Watcher Training

TRUMP
PENCE
MAKE AMERICA GREAT AGAIN!
2016

'

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 55 of 76

Poll Watchers Are The First Line Of Defense


oPart of a coordinated system to quickly detect, mitigate, and
document unintentional or intentional election-related
disruptions that arise during the registration, voting, and
counting periods.
oProgram goal is to ensure a fair and open process where every
person entitled to vote has the opportunity to legally cast a
ballot and have that ballot counted properly.

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 56 of 76

Low on
Ballots 3=,%

County
Election
Official
sends more
ballots

omman
Center Call
County
Election
Official

Observer
Notices
roble

'1;
Command Center sends
lawyer to ensure more
ballots arrive, resolve
- disputes on proceeding if
run out of ballots, and
record events

Lawyers provide
record of events to
litigators if needed
-?z6At
for court

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 57 of 76

Poll Watchers Do Not .


oWe do not and will not tolerate any voter intimidation or
suppression.
oNo person should interfere with any individual's right to legally
cast a ballot.
No person should interfere with or delay the legal voting
process.

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 58 of 76

Rules Regarding Poll Watchers


Poll watchers are permitted to:
0 Observe the conduct of the election.
oView the posted roster of registered voters in the precinct.
o The roster will be updated at several points during Election Day to
reflect who in the precinct has already voted.

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 59 of 76

Rules Regarding Po

oEach poll watcher must sign and file a form with the Secretary
of State prior to Election Day.
oEach poll watcher must wear a name tag while in the polling
place.
OPoll watchers must remain with n the area des nated for

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 60 of 76

c"

Rules Regarding Poll Watchers

Poll watchers are prohibited from:


o Speaking/interacting with any voters.
o Touching or handling ballots or other voting equipment.
o Wearing campaign gear (e.g., clothing, buttons, etc.).
o Using cell phone or other electronic device inside the polling place.
o Taking photographs or video inside the polling place.
Attempting to determine..forwhich:candidates:a person has. voted.
Asking for or writing down any personally identifying information about any voter.
r

iz,4

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 61 of 76

If You See Something, Say Something


o If you see a problem and the poll official does not resolve it
quickly, call the Command Center.

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 62 of 76

Rules Regarding Voters


o Voters are entitled to:
o Receive a replacement ballot if the original ballot is spoiled.
o Cast a provisional ballot if registration or identity is in question.
o Bring voting aid materials (e.g., sample ballot) into the booth.
o Voters are prohibited from:
Engaging in any electioneering activity to include wearing political buttons,
s, etc. or solicitation within 100 feet of the polling place.
pins,

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 63 of 76

Polling Place Process


Voters generally are not required to present an 1.D. in order o vote.
o The .only exception is tha4 individuals who registered to vote by maiand who have not
I.U. need not
previouSly voted at a. polling place must pronnt some form on.u.
contain a' photo (a utlity
paystub, etC. is acceptable).

the

o The voter mu$t sign the olling place .ros tr. The poll worker then checks the
sinature againstihe N ature contatne in the voter's re 'station record or the
presentea by e voter (e.g., drivers license).
signature on a Corm of
If tbo signatures .do not match, the poll worker may ask the voter a series o
verity h1 or her identity.
le;;5192?,

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 64 of 76

Polling Place Process


0I the boll worker.: are unable to. confirm hat a person is registered to vote in the precinct,
t

voter may vote only by provisional 13 llot.

be
presents at the wrong.precinct must be informed ofbis correct precinct.and must be
wformed tnat any provisionai balior cast at tne wrong precinct wilt not be coUnted. it tne voter
to vote rn tne wrong precinct, ne may cast any a provisional ballot.
o If a voter moved into the prenct before Election Day but has not yet updated his voter registration
record, he must vote in nis old precinct.
V trs ca ting a provisional ballot must complete and sign,.in front of poll workers, a
ayi . he poll worker must provide the voter with a recei pt that cant ins a uniue
. provisional ba 0 and informati n on how tie voter can
entaication. number for the
etermine whether or not the provisional ballot is counted.

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 65 of 76

Voter Challenges
Poll watchers generally are not permitted to challenge the qualifications of a voter.
A poll watcher may, however, challenge a voter if the poll watcher is a registered voter in the precinct
where he is serving as an observer.
In order to challenge, YOU MUST have personal knowledge of that voter, use a special form from the
Secretary of State
ANY WILLFUL VIOLATION OF THE VOTER CHALLENGE RULE COULD RESULT IN FINES OR
IMPRISONMENT OR BOTH.

There are two permissible reasons for challenging a voter:


The voter is not the oerson s/he claims to be.
The voter has alreacy voted in this election.

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 66 of 76

-,;----EV--',44:rgc,

1-'*;(gte

-STS YV

ssues to Monitor Hours of Operation

Polls not opening/closing on time.


oPolls must open at 7am.
0 Polls close at 7pm. Voters in line by 7pm may vote.
oIf a court orders polls to remain open after 7pm, voters
must vote s rovisional ballots that are segreg ed from all

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 67 of 76

ssues to Monitor Electioneering Activity


oCampaigning/electioneering/solicitation by any person is
prohibited within 100 feet of polling place.
oWearing political attire/materials or even discussing politics is
prohibited.

. -?)193-

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 68 of 76

ssues to Monitor Improper Voter Assistance


Voters with a physical disability or who do not speak English
may receive assistance in completing and casting their ballot.
A poll worker or another person chosen by the elector may assist (but
not persuade), the voter throughout the voting process.
But: a voter's employer or an official of a labor union to which the voter belongs
.

..

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 69 of 76

Issues to Monitor Voter Already Cast Ballot


o A voter who has already voted an early or absentee ballot is not entitled to
vote a regular ballot on Election Day.
o A voter who has not yet voted an absentee ballot may vote in person if
they have returned the ballot to the election board in the voter s precinct.
0 A voter who received an absentee ballot but who has not et returned it
may be given a regular ballot at the polling place if the vote
0.,;tk;

.:'?1.5

...........

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 70 of 76

ssues to Monitor Miscellaneous


Please immediately report any instances of the following:
Shortage of ballots.
Malfunctioning voter equ pmen

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 71 of 76

oIf you have questions before Election Day, please contact


OJesse Law 702-715-1401
ONEVADA COMMAND CENTER HOTLINE

775 204 0500

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 72 of 76

Exhibit E

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 73 of 76


11/3/16, 7:57 AM

Gmail - TrumpElection Day Poll Watching EMAIL #2 *** Important Info

M Small
TrumpElection Day Poll Watching EMAIL #2 *** Important Info
Jesse Law < esse.Iaw
Bcc:

mail.corn>

Thu Nov 3 2016 at 7:51 AM

Dear Poll Watchers:


https://mail.google.com/mail/u/0/?ui=2&ik=064b61f645&yiew=pt&search=sent&msg=1582aaca33afb815&sim1=1582aaca33afb815

Page 1 of 2

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 74 of 76


Gmail - TrumpElection Day Poll Watching EMAIL #2 * Important Info

11/3/16, 7:57 AM

As you may have heard, the Nevada State Democratic Party is accusing the Nevada State Republican
Party and the Trump Campaign of voter intimidation. One of their main arguments is that you may have
been misled or confused during our poll watcher training session, and that on Election Day you might
challenge voters without justification. That is a very serious accusation, which, as you know, is totally
untrue. But because they are making it, we wanted to reiterate something that all of you already know
about: The legal requirements for orally challenging voters in Nevada and the need for you to call the
legal hotline beforeattempting to challenge anyone's eligibility to vote.
As you will recall from your poll watcher training, there are three legal requirements for oral challenges
in Nevada: (1) the challenger must reside in the same precinct as the challenged voter, (2) the challenger
must base his/her challenge on personal knowledgQ that the challenged voter either is not entitled to vote
as claimed or has already voted in the same election, and (3) the challenger must submit an affirmation
concerning the challenge under penalty of perjury and in the form prescribed by the Secretary of State.
See N.R.S. 293.303(1)(a). A frivolous or knowingly false challenge may give rise to civil and/or
criminal liability for the challenger. Because this process is technical and carries significant risks for
both the challenger and the challenged voter, we reiterate that all poll watchers must confer with the legal
hotline before initiating any challenge. In almost all instances, we will advise against challenging
someone who is trying to cast a vote.
For the vast majority of you, this won't come up at all---and it won't be necessary to memorize the details
of the challenge procedures---because you won't be assigned to watch the polls in your own precinct, so
you are not eligible to challenge voters in the first place. But for the few of you who may be watching
polls in your own precinct, I trust this message is sufficient to remind you of the legal requirements for an
oral voter challenge. Your job as poll watchers is to quietly and respectfully observe the democratic
process in action. As we have explained to all of you, if you see anything that causes concern, please let
our legal hotline know rather than try to correct the situation yourself.
If you have any questions on this topic, please do not hesitate to call me at 702-715-1401 anytime.
Best wishes,
Jesse Law

https://mail.google.com/mail/u/0/?ui=2&ik=064b61f645&yiew=pt&search=sent&msg=1582aaca33afb815&sim1=1582aaca33afb815

Page 2 of 2

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 75 of 76

Exhibit F

Case 2:16-cv-02514-RFB-NJK Document 39-1 Filed 11/03/16 Page 76 of 76

PRIVILEGED
COMMUNICATION

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