DECLARATION OF LEE VASCHE

I, Lee J. Vasche, declare the following to be true to the best of my knowledge under penalty of perjury:

1.

I am making this declaration in support of my elections complaint against Our Oregon and Ben
Unger.

2.

I am the Executive Director of the Signature Gathering Company of Oregon (SGCO), an Oregon
mutual benefit non-profit corporation. SGCO's primary business activity is providing paid
signature gathering services to select political committees in Oregon. Established in 2011, SGCO
has emerged as one of the leading professional signature gathering companies in Oregon.

3.

In December of 2015, SGCO began collecting signatures on two initiative petitions, IP49 "The No
More Fake Emergencies Act" and IPSO "The Voter Privacy Act." The political committees for
which we rendered these services were "No More Fake Emergencies Committee" and "The
Voter Privacy Committee." The deadline to submit signatures to qualify these petitions for the
November 2016 ballot was July 8, 2016.

4.

On April 21, 2016, SGCO subcontracted with Encore Political Services LLC (EPS) to collect
signatures on IP49 for the "No More Fake Emergencies Committee." The contract was intended
to be a trial with EPS to collect a minimum of 5,000 signatures on IP49. Hiram Asmuth is the
owner/operator of EPS.

5. On May 2, 2016, the contract between SGCO and EPS was amended to increase the number of
signatures EPS was to collect on IP 49 by an additional minimum of 20,000 signatures on
because EPS was performing so well.

6.

EPS did good work and steadily collected signatures on IP49 during April, May and June. A
weekly breakdown of the total signatures collected by EPS on IP49 is attached as Exhibit 1. The
relationship between SGCO and EPS was very positive as both parties fulfilled their
responsibilities of the contract and Hiram was pleasant to work with.

7. The morning of June 17, 2016, I had a 9-minute phone conversation with Hiram where we
discussed and agreed to modify our agreement to increase the fees paid to EPS. We also
discussed and agreed to extend our agreement to keep EPS working on 49 until just before the
July 8, 2016 deadline. Hiram stated that even though he wasn't making any profit working on

49, he wanted to keep his "crew" working to "finish out" IP49 to ensure it qualified for the
ballot.

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8.

Later in the day on June 17, 2016, I exchanged text messages (Exhibit 2) with Hiram confirming
that SGCO would need to retain EPS's services through July 5, 2016 stating "On 49 I think we will
need to go all the way until July 5." Hiram replied "No prob. I figured that after checking the
latest submissions."

9.

At this time, I had no doubts whatsoever that that EPS would continue to collect signatures for
SGCO on IP49. We had a firm agreement to modify the rate structure to pay EPS a higher rate,
so that they would continue working through July 5, 2016, which was confirmed in a text
message.

10. Eight days later on June 25, 2016, I received a disturbing phone call from Hiram. He stated that
he had received and accepted a contract from Our Oregon for EPS to begin a new project
immediately and that contract would preclud EPS from continuing to collect signatures for SGCO
on IP49. Hiram stated to me that the project with Our Oregon would be "90% profit." I asked
him why Our Oregon would suddenly hire EPS at this critical moment with 12 days to go until
the July gth signature submission deadline. Hiram told me it was because Our Oregon was
opposed to IP49 and wanted to make it more difficult to qualify IP49 for the ballot. I asked
Hiram why he wasn't going to fulfill our agreement and told him I was OK with him working on
both projects simultaneously. Hiram responded that he would not have received the Our
Oregon contract if he did not stop collecting on IP49.
11. In entering into an exclusive 90% profit contract with Our Oregon that prevented Hiram/EPS
from continuing to collect signatures on IP49, Hiram/EPS breached its contract with SCGO to
collect signatures through July 5, 2016. The last minute timing of Hiram/EPS taking another
contract that required him to stop working on IP49 put SGCO in a disastrous situation where we
could not find another subcontractor quickly enough. During the final four weeks that EPS
collected signatures on IP49, they averaged around 3,000 signatures per week. If EPS had
honored its agreement with SGCO to continue working on IP49 through July 5, EPS would have
likely collected an additional 5,000 to 8,000 signatures. IP49 fell approximately 3,000 signatures
short of the minimum requirements to qualify for the ballot These lost signatures from EPS
would have ensured IP49 would have qualified for the ballot.
12. In a phone conversation, Hiram clearly stated that Ben Unger personally orchestrated and
negotiated the 90% profit contract between Our Oregon and Hiram/EPS. The timing of the 90%
profit contract is suspect as it began on June 25, 2016 and ended on July 11, 2016 - a mere
three days after the deadline for submitting signatures on IP 49. Even more suspicious, the
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contract did not even involve signature gathering but was a "voter registration drive" that
happen to coincide with the most crucial phase of the signature gathering campaign.
13. Based on text messages and conversations between Hiram and me, it is clear that Our Oregon
paid Hiram/EPS to not collect signatures on IP49 leading directly to IP49's failure to qualify for
the ballot. It is clear than Ben Unger, on behalf of Our Oregon, interfered with our contractual
relationship with Hiram/EPS. I would have had no objection for Hiram to work a simultaneous
project for Our Oregon, but as Hiram told me, he would not have gotten the Our Oregon
contract if he did not agree to stop collecting signature for IP49.
14. As far as I can tell, that's against the law.

260.575 Use of threats and intimidation for purpose of extorting money. No erson,
for any consideration, shall:
(1) Offer, pro:Qose, threaten or attem t to sell, hinder or delay any part of an initiative,
referendum or recall etition.
(2) Offer, QrOQOSe or threaten to desist from beginning, promoting, circulating, or
soliciting signatures to, any initiative, referendum or recall etition.
(3) Offer, propose, attempt or threaten in any manner to use an initiative, referendum
or recall petition or any power of promotion or opposition concerning such petition for
extortion, blackmail or private intimidation of any person.

260.665 Undue influence to affect registration, voting, candidacy, signing petitions;

solicitation of money or other benefits. (1) As used in this section, "undue influence"
means force, violence, restraint or the threat of it, inflicting injury, damage, harm, loss of
employment or other loss or the threat of it, or giving or..Promising to give money,
em_ployment or other thing of value.
(2) A person, acting either alone or with or through any other person, may not directly
or indirectly subject any person to undue influence with the intent to induce any person
to:
(a) Register or vote;
(b) Refrain from registering or voting;
(c) Register or vote in any particular manner;
(d) Be or refrain from or cease being a candidate;

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(e) Contribute or refrain from contributing to any candidate, political party or political
committee;

(f) Render or refrain from rendering services to any candidate, political party or
political committee;
(g) Challenge or refrain from challenging a person offering to vote;
(h) Apply or refrain from applying for a ballot as an absent elector; or
(i) Sign or refrain from signing a prospective petition or an initiative, referendum,
recall or candidate nominating petition.
(3) A person may not solicit or accept money or other thing of value as an inducement
to act as prohibited by subsection (2) of this section.
(4) This section does not prohibit:
(a) The employment of persons to render services to candidates, political parties or
political committees;
(b) The public distribution by candidates, political parties or political committees of
sample ballots or other items readily available to the public without charge, even though
the distributor incurs costs in the distribution;
(c) Public or nonpromissory statements by or on behalf of a candidate of the
candidate's intentions or purposes if elected;
(d) A promise by a candidate to employ any person as administrative assistant,
secretary or other direct personal aide;
(e) Free custody and care of minor children of persons during the time those persons
are absent from those children for voting purposes;

(f) For persons voting, free transportation to and from places designated for the
deposit of ballots under ORS 254.470 or to and from locations described in ORS 254.472
or 254.474; but no means of advertising, solicitation or inducement to influence the vote
of persons transported may be used with that transportation;
(g) Individuals or political committees from providing refreshments incidental to a
gathering in support of or in opposition to a candidate, political committee or measure; or
(h) The public distribution of registration cards by a person approved by the Secretary
of State under ORS 247.171 to print, copy or otherwise prepare and distribute registration
cards, even though the distributor incurs costs in the distribution.

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260.993 Criminal penalties. (1) The penalty for violation of ORS 260.532 is limited to
that provided in ORS 260.532 (6) and (8).
(2) Violation of ORS 247.125 (1), 247.171 (5), 247.420 (2), 253.710, 260.402,
260.555, 260.558, !260.575, 260.645 or 260.665 (2) or (3) involving any action described
in ORS 260.665 (2)(d) to (f) or 260.715 is a Class C felony.
(3) Violation of ORS 260.695 (4) is a Class A misdemeanor.
(4) Violation of ORS 247.171 (6) is a Class C misdemeanor.

"I hereby declare that the above statement is true to the best of my knowledge and belief, and that I
understand it is made for use as evidence in court and is subject to penalty for perjury."

Lee Vasche

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Exhibit 1
EPS Signatures by Date
Date
4/26/2016
5/3/2016
5/10/2016
5/18/2016
5/25/2016
6/1/2016
6/8/2016
6/15/2016
6/23/2016
6/29/2016
Total

Signatures
1972
2381
2322
3652
3567
2502
3271
2305
2593
3378
25971

Exhibit 2