DISTRICT COURT CIVIL COVER SHEET County, Neva Case No, XXVI sierady Ck is) ‘TParty Taformation provae for tome ant naling arenes tern 46298 Pains) (nameraddess phone: [Detendant@)(namevaddrevphoney DONALD J. TRUMP, an individual, and DONALD J. TRUMP, JOE P, GLORIA, in his oficial capacity as the FOR PRESIDENT, INC., a New York nonprofit corporation | Clark County Registrar of Voters “Aomey (nameladers/phone "Atomey(nameladdesiphens: Davi S. Lee, Esq - Bar No. 6033 | Brian 2. Waaoy, ts. ~ Bae No [0066 ‘Aurora Mt Maskel- bar No. 6470, Matur Aurshet Corse 77S Vegas Dr., #150, Las Vegas, NV_69125 “Date fon De, bar veers AN 84S (702) 3089778 TI, Nature of Controversy (sar slct he ane most appleable [ng Civil Case Filing Types ot.382. oti! 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Cunders2.s00 caw Other Cel ing cha weie ‘Other Civil Fling [weit or titeas Corpus Lwat of Protitition [lcompromise of inors Chaim vic of tnaamis [Blorier civ wee (BForeign udgment wie or Que warrant Bother civ maners Basins Court flings shoul ied wsng the Business Cour cilicovesheek Mir 7, Ele a eee ae ‘of iitiati fy or representative Soother sie for fui relate case lings.MARQUIS AURBACH COFFING 10005 Pak Run Drive 16 Electronically Filed ORIGINAL 11/07/2016 05:19:13 PM Marquis Aurbach Coffin, be ol Brian R. Hardy, Esq. 7 Wien 4 Neyada Bar No. 10068 10001 Park Run Drive GLERK OF THE COURT Las Vegas, Nevada 89145, ‘Telephone: (702) 382-0711 Facsimile: (702) 382-5816 bhardy@maclaw.com DAVID S. LEE, ESQ. SHANA D. WEIR, ESQ. | Nevada Bar No. 6033 Nevada Bar No. 9468 A. MARIA MASKALL, ESQ. PARKER, NESLON & ASSOCIATES «da Bar No. 6410 2460 Professional Court, Ste. 200 | LEE, HERNANDEZ, LANDRUM Las Vegas, NV 89128 & GAROFALO, AP.C. T: (702) 868-8000 7575 Vegas Drive, Suite 150 F: (702) 868-8001 Las Vegas. Nevada 89128 eir@pnalaw.net T: (702) 880-9750 F: (702) 314-1210 Alee@e-lawrirm.com amaskali@lee-lawfitm.com Attomeys for Petitioners DISTRICT COURT CLARK COUNTY, NEVADA DONALD J. TRUMP, an individual: and | DONALD J. TRUMP FOR PRESIDENT, INC., a New York nonprofit corporation, Case No, 2-16-746298-W Depi.No, *¥VE Petitioners, | ELECTION RELATED ACTION vs. PETITION FOR WRIT OF MANDAMUS OR, ALTERNATIVELY, PETITION FOR JOE P. GLORIA, in his official capacity as the | WRIT OF PROHIBITION Clark County Registrar of Voters, | J 1. Petitioners DONALD J. TRUMP (the Candidate”), 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 “Registre Page | of Lf MAC: 1422-012 Pton tor Wet of Mandar of Alternatively Petition tr Writ of Pohbion DOCK B1/7!20163:37 PM.B 10004 Prk Las Voges (202) HOY FAR: (02 38258165 MARQUIS AURBACH COFFING 23 26 27 RODUCTION 2. This action is to preserve the stats 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 ox November 4, 2016. 3. The Registrar’s violations were not random and neutral in their effect, bat yery much appear to have been intentionally coordinated with Democratic activists in order to skew the vote unlawfully in favor of Democratic candidates. JURISDICTION AND VENUE 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. PART 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 “EI 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 oF “NRS") setting forth the rule for language of the Nevada Revised Statutes (Nev, Rev. Stat 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 riillions 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 JOB 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 regulation of polling places and the conduct of election personnel at polling locations Page 2 of 1 MAC‘14221-02 Petition for Writ Mandanis or Altemiiively Petition ir Wri of Proibion.DOOCK 15172016 3:37 PMMARQUIS AURBACH COFFING 25 6 a 28 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 Keicham 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 p.m. 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. IL. ‘The Regisirar’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, Id, at §9. 13, After 8:00 p.m,, Joe told Mr. Ketcham directly that other polling locations were being closed on time and voters still in fine were instructed to come to the Polling Location at Cardenas Market. /d,, at € 10, Joe commented to Mr. Ketcham that he felt this selective closing was done to help Hillary Clinton, fd. 14, Mr, Ketcham estimates that more between 150 and 300 people entered the line after 8:00 p.m., but the actual number could have been significantly higher. fd, at § 11. The line after Id, :00 pam. became larger than Mr. Ketcham had observed at any other point during the day, 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 LF MAC: 14221-002 Petition for Writ of Mandar o Alematively Petition fr Weitof Protibiton DOCK 11772046337 PMMARQUIS AURBACH COFFING 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, a§6. 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 carrying signs written in Spanish, Jd, 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 from Fox 5 News were standing nearby. fd. 17, Because it was so much later than 8:00 p.m. 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 vole, so he attempted to videotape the situation. Md, at § 8. A person who was wearing a name tag reading “Joe,” identified as a poll worker, approached Mr. Chamberlain telling him he could not use his phone to take # video at that location, Jd. Mr. Chamberlain asked him if it was against the law to videotape. /d. 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. fel. 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, he placed a barrier at the end of the poll fine. Jd, 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 polis were closed. fd. 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 Portiflo, « 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. fd, 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 16” MAC.14221-002 Peto for Writ of Manda or Aieratvey Peto fr Weit of Proibiten DOCK 11772016 3:37 PM.3 g i : 2: i 5 i 702) 382.07 9 z E 8 ° 5 < = x = g 2 g < a wR eK ao id. She further explained that the reason the polls were closing at this time was because the store was closing. Id 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 calls from Mr. Ketcham referenced earlier, who was at the Polling Place at Cardenas Supermarket, and the call fiom 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 p.m, he drove to the Silverado Ranch Plaza, another polling location, located at 9845 8. 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 line as long as there were people in line, no matter what time they arrived to the polling location, even if it was affer the required 8:00 p.m. elosing time. Jd. 23, Mr, Law then drove to the Cardenas Market and arrived at approximately 9:05 pan. 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 was 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. La 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. Jd. at {11 Page 5 of US MAC 14221-002 Petition for We of Mandar or Alzmatvels Petition x We of Proibion DOCK 11772016 3:37 PMS914 FAX, (702) 382-8816 Drive MARQUIS AURBACH COFFING lL 12 1B 4 1s 16 "7 18 19 20 24 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, Zc at 412, 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 Michaei Chamberlain arrive 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 move. Id at 413, They both walked to the front, and when there was only one person in line, Mr. Chamberlain snapped 2 photos. /d. ‘The poll site manager “Joe” watked 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 * his 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 ine again, Jd. 29. Ms, Portillo then approached Mr. Law and said that filming was not allowed, Jd. at $15, 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, Joe 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. Jd. 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 one minute ushering three more people to vote AFTER SHE HAD Page 6 of 1S MAC\J5221-002 Peston for Wit of Mandan or Ateatively Peon fr Writ of Probilon DOCN 1/9206 337 PMmn Brive a 8954S FAX: (102) 382-58 Ne MARQUIS AURBACH COFEING won Awe ANNOUNCED CLOSING. Id. 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. Poil workers allowed one more 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 Gioria, who Mr. Law knew to be the Clark County Registrar of Voters. Jd. 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, Ia. 31. 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. /d. at 17. All of them were looking at Ms, Portillo with a pleading look in their eyes wondering if she would just Jet one more person vote. Jd, There was clear familiarity and cooperation. Jd Mr, Law saw Ms. Portillo announce that the polls closed a second time, at about 9:50 p.m. Jd. 32. Im the meantime, at approximately 7:00 p.m, the same day, attomey Jeanne Valentine was also 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 {7 of Exhibit 4. According to Mr. Ding, the poll workers said that the Secretary of State had given them permission to ignore the statute requiring that polls close at 8:00 p.m. Ia. 34. Ms, Valentine called the office of the Secretary of State at 8:10 pm, 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 | were being permitted to remain open past 8:00 p.m., and she said that as long as voters were in Page 7 of 16° [MAC:i4221-442 Peon for Writ of Manan ot AfenaveyPetsion fx Weit of Protibiion, DOCK | 7/2016 3:37 PM. ster which‘BAX: (702) 38-8816 3 2 & 9 a E 6 we gE a5 ge we <8 - 3 % s S ea A ee line, the polling locations were not allowed to close. Id. 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 fast voter allowed to vote, and she said she was going to hand the call to a supervisor. Id. | 35. Ms, Valentine then spoke with a man who identified himself as Charles Hurley, the Assistant Registrar of Voters in Clark County. See § 9 of Exhibit 4, Ms. Valentine repeated her question, and he expressly said that polls do not close on the last 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 10 vote at the 8:00 pam. 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 | p.m, 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. Jd. 37. Mr Hurley said that Clark County allowed voters to vote past the deadline listed in written materials so as to not “disenfranchise” 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 pan. 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 5. (An original of Exhibit 5 has been provided to the Court.) Mr. Hurley did not answer the question, Id 38. At approximately 10:20 p.m., 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 Market location after 8:00 p.m., which the Nevada legal team decided not to attach to this motion Page 8 of 1& SAC Hom ean fr Wn ot nto Ave Pet br Wit Pin DOCK 1/7QN16397 FM |FAX: {700} 382-916 as Vegas Nevada (2) 1000 Park Rr MARQUIS AURBACH COFFING Sow 2a 21 28 due to the unknown identities of the individuals captured in the pictures. /dt, The pictures are available for in camera inspection by the Court, if necessary. 39, I addition, throughout the evening, several twitter accounts supporting Demoorats 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 accurate copy of 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 CANDIDATES” (emphasis on the document), See Ketcham Declaration, 12. Throughout the afternoon, he saw hundreds of voters standing in line holding, this material. Id, 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 electioneering, 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:14221-000 Pett for Writ of Manis or Alternatively Pion or Writ of Pebibiton DOCK 11 age1 43, The Registrar is responsible for the regulation of polling places and the conduct of | 2 | election personnel at polling locations throughout Clark County. ‘This means that the Registrar is | 3 || responsible for following Nevada law, which requires that election personnel are informed of, 4 | and enforce, the following statutes: | 5 Nev. Rev. Stat. § 293.3025 Posting of copies of certain other information and 6 || documents at polling place. i Z ‘The Secretary of State and each county and city clerk shall ensure that a copy of : each of the following is posted in # conspicuous place at each polling place on / a election day: 9 1. A sample ballot; 10 2, Information concerning the date and hours of operation of the polling i ie P g a S BE 2 13 Nev. Rev, Stat. § 293.305 Closing of polls; admission of voters and other persons. 5 & | G22 14 1. Ifat the hour of closing the polls there are any registered voters waiting to | aes vote, the doors of the polling place must be closed after all such voters have been i a a5 1s admitted to the polling place. Voting must continue until those voters have voted, | ee a4e Zahe 1° Nev, Rey. Stat. § 293.3876 Schedule of locations and times for early voting. 8 7 7 1, The county clerk shall publish during the week before the period for early i voting and at least once each week during the period for early voting in a g 18 me Per & newspaper of general circulation a schedule stating: = 19 = (a) The location of each permanent and temporary polling 20 place for early voting, 21 (0) The dates and hours that early voting will be conducted at each location, 2 2. The county clerk shall post a copy of the schedule on the bulletin board used for posting notice of meetings of the board of county commissioners. The 2 schedule must be posted continuously for a period beginning not jater than the fifth day before the first day of the period for early voting by personal | 28 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 | y reasonable quantities without charge during the period of posting, i 28 | Page 10 of 16 | MAC: 1422-062 Petton or Wit of Mand or Altera Petton fe Writ of Pokbiion DOCK 1172516337 PM |MARQUIS AURBACH COFFING || created a new polling pl 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 poiling 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}(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 3 manner that favors one political party over another, violates the Equal Protection Clause of 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 ce 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). Page 1 of 16 [MAC:4221 402 Petron for Writ of Mand ox Altenmaely Petition fr Writ of Prohtion DOC 11772016 3397 PM |MARQUIS AURBACH COFFING Awa See x u 12 is} 4 1S 16 17 18 19 20 a 22 B 24 25 26 28 47. Finally, the Registrar clearly violated the law by allowing Democratic operatives to brazenly distribute the Clark County Democratic Pany’s literature in direct violation of the prohibition on “clectioncer{ing] 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 illegal 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 Secretary 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 status quo has been preserved. 5}, 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 attomey’s fees and costs, 53, The Candidate and the Campaign respectfully represent and request a writ of mandamus or, alternatively, a writ of prohibition mandating and prohibiting the following: Page 12 of 16° -MAC:14221-002 Petition for Writ of Manso Alteralvey Ptkion Sr Weit of Probion.DOCX 17/2016 337 PMMARQUIS AURBACH COFFING wk ON ce a MACi1422 000 Pai ‘The ballots and voting machines from the following early voting polling places shall 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 V 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. fii, 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 afler 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 allegations in this petition. ‘The Registrar shail 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 jon &e Writ of Mande oF Alert Petition fr Writ of Prion DOCK 13/1/2016 3:37 PMMARQUIS AURBACH COFFING ea 26 a 28 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 10001 Park Run Drive Las egas, 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 of Manas or Altesiivey Petition fr Weit of Prohibtion DOCK LN7R0163:37 PM |Oo zZ ° & vee a2). aoe Pee os 3 ¢ qo: g a = 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. Lam 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. Lam an attomey at Marquis Aurbach Coffing, which is counsel for Petitioners Donald J. Trump and Donald J. Trump for President, Inc. 3. If 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, itis 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. 5S. Pursuant to NRS § 53.043, 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. - co 7 ae “BRIAN RAIARDY CRIBED and SWORN.tobéfore me Nay of November 2016. Page 15 of 16 MACL14221.002 Peon for Writof Manda or Aemalivey Retson fo Wei of Paibiion DOC 11/12016.337 PMExhibit “1”DECLARATION OF RONALD KETCHAM 1, RONALD KETCHAM, hereby declare as follows under penalty of perjury: 1 ‘The following statements are based on my personal knowledge. and if called to testify I could swear competently thereto, Tam at least 18 years old and of sound mind. 3. 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. 1 am an eligible Nevada voter and am registered to vote. 1 submit this Declaration in support of the Petition for Writs by Donald J. ‘Trump For President, Inc., seeking a declaratory judgment against the Registrar of Voters of Clark County, Nevada. 5. On November 4, 2016, at approximately 8:30 a.m., I personally appeared at the polling location for Precinct 4536 at Cardenas Market, 4421 £, Bonanza Road, Las Vegas, Nevada 89110 and served as a poll watcher. 6. On November 4, 2016, voting at the Cardenas Market began just prior to 9:00 am. [left the polling location at approximately 6:00 p.m. and retumed at exactly 8:00 p.m. I then remained at the polling location until it closed at 9:50 pn. 7. ‘The polling location at the Cardenas Market was schedaled to close at 8:00 p.m, according to the written materials distributed by the County of Clark, (See Valentine Declaration, Exhibit 5.) I understood the law to require that, at 8:00 pam., the last person in line should have been the last person permitted to vote. 8. Around 5:00 pam., the head of the polling location (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 10:00 p.m, ‘This would be two (2) hours beyond the designated closing time. 9. Joe 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. 10. After £:00 p.m., Joe expressed to me directly that other polling locations were being closed on time and voters still in 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. 11. In my estimation, between 150 and 300 people entered the line after 8:00 p.m. The actual number could have been significantly higher. The line after 8:00 p.m. became larger than | had observed at any other point during the day.12 Batlier in the afternoon on the same day, I personally 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 Part YOU TO VOTE IN SUPPORT OF THE FOLLOWING CANDIDATI on the document). Throughout the aflemoon, I saw hundreds of voters standing in line holding this material. Y witnessed a democrat poll watcher hand ‘what I strongly believe was one of those sheets to a voter standing well within the 100” prohibited area for electioneering, as the voter was at the front of the line. I believe it was one of these sheets because they have a very unique shape and appearance swhich makes them very distinguishable, a copy of which is annexed as Exhibit J (o.the motion seeking a Declaratory Judgment. Lhereby swear or affirm under penalty of perjury that the foregoing is trae and correct to the best of my knowledge. QND wa 6 Nevewka Lobe Ronald Ketcham DateExhibit “2”DECLARATION OF MICHAEL CHAMBERLAIN 1, MICHABL CHAMBERLAIN, bereby declare as follows under penalty of perjury 10, ‘The following statements are based on ray personal knowledge, and if called to testify 1 could swear competently thereso. Jam at least 18 years old and of sound mind, Tam a citizen of the United States and of the State of Nevada. [reside at 6158 Highland Gardens Drive, North Las Vegas, Nevada 89031, which is located in Clark County. 1 am an eligible Nevada voter in Precinct 2384 and am registered (0 vote. | submit this Declaration in support of the motion by Donald J. Trump For President, Ine., secking judgment against the Registrar of Voters of Clark County. On November 4, 2016, at approximately 9:40 p.m.. I personally appeared at the potting location at Cardenas Markel, 4421 B. Bonanza Road, Las Vegas, Nevada 89110. 1 personally researched ontine and am generally aware that the polling location at the Cardenas Market was scheduled to close at 8:00 p.m When I arrived at 9:40 p.m. I personally witnessed democrat candidate for Senate Catherine Cortez Masto speaking 10 approximately 20-30 individuals, some of whom were carsying signs written in Spanish, [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 from Fox 5 News were standing nearby. Because it was so late after 8:00 p.m. when polls are required to close (it was nearly 10:00 pam), I was alarmed when a person entered the line intending to vote so I attempted to videotape the situation. A person who was wearing a name tag reading Joe, identified as a poll worker, approached me teiting me I could not use my phone to take a video at that Jocation. | asked him if was against the law to videotape. He said it was, and in response 1 asked him if it was against the law for people to come in and vote affer 8:00 p.m. He answered, "I don’t care what you think, we are going to let people vote here until 10:00 pm.” A few minutes later, Joe stood at the end of the poll line and announced that the polls were closed. At that point he placed a barrier at the end of the poll line. Lorena Partitlo, wha was wearing @ lanyard with a name card identifying her by name as a Clark County employee, also announced the polls were closed. Within minutes, 2 individuals walked around the barrier to the table where voters were given cards to vote, Two separate individual poll workers at the table handed voter cardsre a 44, to the two voters, who then proceeded to vote. I looked at my phone at the time was approximately 9:50 pn. Another gentleman approached the table to get ballot cards, but was tured away. He walked away from the voter table to two women who he spoke with. A third woman approached this man, who I knew to be Astrid Silva (x known political left wing activist), and she escorted him to the voting area and he then approached the table again, but was refused a ballot card again, ‘Immediately, thereafter thres men approached the same gentleman and they spoke briefly. ‘Then the three men were approached by Ms. Portillo. She told those gentlemen that the polls were closed and they eventually left without voting. Ms. Portillo approached me and I asked her why this polling place was allowing people to vote afier 8:00 p.m. This was close to 10:00 p.m. In response, she expressly confessed to me: “There were two people who voted after we said the polls were closed, and that should not have happened.” She further explained that the reason the polls were closing at this time was becanse the store was closing. 1 asked Ms. Portillo about the 8:00 p.m. closing time published by the County, and she explained that they are under no obligation to close the polls at 8:00 p.in. She said she has worked for the County since 1998 and that is not the way things have ever been done. Thereby swear or affirm under penalty of perjury that the foregoing is true and correct to the best of my knowledge. Ub {20 le (20 bla.Exhibit “3”DECLARATION OF JESSE, LAW 1, JESSE LAW, hereby declare as follows under penalty of perjury: a 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 i am a citizen of the United States and of the State of Nevada. I reside 9599 West Charleston Boulevard 89117. which is located in Clark County. 1 am an eligible and registered voter in Clark County, Nevada. am the Director of Election Day Operations for the Donald J, Trump For President, Inc campaign. 1 submit this Declaration in support of the motion by Donald J. Trump For President, inc, seeking a jadgment against the Registrar of Voters of Clark County, Nevada On the evening of Friday, November 4, 2016, at &:10 p.n., [was working at the Trump Headquarters in Las Vegas when we received calls from our poll watcher Ron Ketcham, who was stationed at the polling place located within Cardenas Supermarket, 4421 E Bonanza in North Las Vegas, and another call from Michael Ding (2 volunteer roving attorney for the Trump campaign, licensed to practice law in Washington, D.C., and State of illinois), wo was at the Deer Springs Long Term Barly Voting site in North Las Vegas. Me. Ketcham informed us that the site was saying they would stay open until 10:00 p.m, Mr. Ding reported that a poll worker at the Deer Springs site informed him that they would be staying open anti! 10:00 pam. oF 11:00 p.m. T wanted to confirm the report was not just isolated, so | drove to the Silverado Ranch Plaza, another polling location, jocated at 9845 S, Eastern Avenue in Las Vegas. There was a long line, and I spoke to a site worker there who informed me that people are allowed to enter the line as fong 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. J then drove to the Cardenas Market because the campaign was informed that the poll workers said they would stay open untit 10:00 p.m, when the store closes no matier what anyone says or does. J arrived at the Cardenas Market at approximately 9:05 p.m. { 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 Cortez Masto, 1 watked in to the market through the entrance that was closest to the polting location. 1 observed a Catinary 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 T was told this by a poll observer, directing their volunteers10. a 12. 14, 16, 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. Once inside the market, I 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. I walked along the line, walked around the store, and | observed the Masto booth outside. Standing at the end of the voting fine, | witnessed the county official Lorena Portillo talking to the democrat operatives and volunteers along the line while they were filming. White I was there over a period of 45 minutes, [ observed over 30 but fewer than 40 new people get in fine and the democrat volunteers distribute food and water, T recorded approximately 5 people get in line via video. I recorded democrat operatives and volunteers filming the line, 1 did not record the polling equipment nor people voting, These materials are available for an in camera inspection upon request. I saw Michael Chamberlain arrive at about 9:40 p.m. and he and {observed a line that had not 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 permitted 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, Joe then shouted “this location is staying open until ten and there is nothing you can say or do about it.” J pointed out to Joe that there was a gap in the line or, in other words, there ‘was now no one in fine at all and that they were required to close the polling location. He ignored me. { went to the front of the empty fine area and I filmed an empty line when people starting running up to get in line again. Ms. Portillo then approached me and informed me that filming was not allowed. 1 said that she needs to close the site because there was a gap in the line. She argued. 1 approached the local news media, FoxS, who was there in the store and told the reporter 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 announeing that the polls were closed. Ms, Portillo told the site volunteers the ine was closed and announced the same to those present in the supermarket. She then repeatedly said to Mr. Chamberlain and me: “There, we are closed. You can leave now.” Mr. Chamberlain and I did notleave, We observed Ms. Portillo within one minute ushering three more people fo vote AFTER SHE HAD ANNOUNCED CLOSING. Ms. Pattillo then got on the phone with who she said was her boss. [overheard her say, “they are just observing.” Poll workers allowed one more woman to vote, and so Lasked this poll worker why she closed the polling location and then allowed more people to vote. She asked that Halk to her boss, after she made a call and handed me her phone, which indicated the callwas to “Joe Work.” It was Joe Gloria, who I know to be the Clark County Registrar of Voiers. I did not engage in a conversation. { said what I had just observed Ms. Portillo doing and that we would put these events into affidavits and submit them to the courts. 17. 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. All of them were looking at Ms. Portillo with a pleading look in her eyes wondering if she would just let one more person vote. ‘There was clear familiarity and cooperation. I saw Ms. Portillo announce that ‘the polls closed a second time, At this time it was about 9:50 p.m. Thereby swear or affirm ander penalty of perjury that the foregoing is true and correct to the best of my knowledge,Exhibit “4”DECLARATION OF JEANNE VALENTINE, 1, JEANNE VALENTINE, hereby declare as follows under penalty of perjury: 6. The following statements are based on my personal knowledge, and if called to testify 1 could swear competently thereto Jam over 18 years old and of sound mind. 1am a citizen of the United States and of the State of California. I reside at 475 Lombard Street in San Francisco, California 94133, which is located in San Francisco County 1am attorney in good standing and licensed (o practice in the State of New York, Tam a volunteer lawyer for the Donald J. Trump For President, Inc. campaign, I submit this Declaration in support of the Petition for Writs by Donald J. Trump For President, Inc., seeking judgment against the Registrar of Clark County. On November 4, 2016, at approximately 7:00 p.m., 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 law requiring that polls close 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 4, 2016, at approximately 8:05 p.m., I was informed by Clark County, Nevada poll watcher Michael Ding that he wes told by a poll worker that the polling place Precinct 2446, located at Deer Springs Town Center, trailer located at 7090 N Sth St, North Las Vegas. Nevada 89084, was intending to stay open as long as necessary, with no closing time, to 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 permission fo ignore the statute requiring that polls close at 8:00 p.m. 1 called the office of the Secretary of State at 8:10 p.m. bot the office was closed. 1 then immediately called the Clark County Registrar of Voters, and a woman answered the phone. I asked her if polling locations were being permitted to remain open past 8:00 pan., and she told me that as long as voters were in line, the polling locations were not allowed to close. I 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 to vote, and she told me she was going to hand my call to a supervisor. [then spoke with a gentleman who identified himself as Charles Hurley, the Assistant Clark County Registrar of Voters. [ repeated my question and he expressly told me that polls do not close on the last day of early voting until everyone gets a chance to vote. I presented the following hypothetical scenario: if a person who worked until 9:30 pun., who obviously was not in line to vote at 8:00 p.m., or even at 9:00 p.m., appeared at apolling location after work, would that person be allowed to vote? Mr. Hurley enthusiastically (old me that yes, any voter who wanted to vote on the last day of early voting would be permitted to vote at any time. Lasked Mr. Hurley what the purpose was, in his mind, of the 8:00 p.m. time listed in the written literature stating that polls close at 8:00 p.m., and he said that is purely guidance. He told me that Nevada has always permitted voters to vole past the 8:00 p.m. deadline on the last day of early voting. Mr. Hurley expressly stated that Clark County dees not follow dhat law on the last day of early voting, 11. Mr. Hurley said that Clark County allowed voters to vote past the deadiine listed in written materials so as to not “disenfranchise” voters. I then asked him whether be 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 polis would be closed at 8:00 p.m Exhibit 5, a true and accurate copy of the Early Voting Schedule prepared and distributed by the office of the Clerk of Clark County. Mr. Hurley did not answer my question, 12. At approximately 10:20 p.m., 1 was informed by an unidentified poll watcher that a different polling location, located on the Las Vegas Strip, was still open. This was verified with pictures, as was the long line of voters at the Cardenas Market location after 8:00 p.m., which the Nevada legal team decided not to attach to this motion due to the unknown identities of the individuals captured in the pictures, The pictures are available for in camera inspection, if necessary 13, In addition, throughout the evening, several twitter accounts supporting democrats and the press tweeted that the Clark County polls were indeed open until 10:00 p.m., and encouraging voters to go vote after the 8:00 p.m. deadline passed. It appeared that democrats were aware of this deviation from the law, but republicans were not, causing a great divide in the application of Clark County’s Jaw mandating that polls close at 8:00 pan. A true and accurate copy of screen shots taken by me from my mobile phone are annexed hereto as Exhibit 6. Thereby swear or affirm under penalty of perjury that the foregoing is true and correct to the best of my knowledge rut Ywa aOetrek [Tale Je M. Valentine DateExhibit “5”GENERz. wicca 201b IMPORTANT DATES _FOR THE 2016 GENERAL ELECTION 2 last day to register to vote or update your existing registration without having to appear in-person at the Ballot Request Deadline” st day to request an electronic sample ballot by email instead of a paper one by postal mail, Submit your request when you log-in to "Registered Voter swunw. Clark CountyNV.gov/vote, Ten-day period for in-person end online voter registration or updates to your existing registration at the Election Department offices or on the Secretary of & E& > I E State's website. oe = Early Voting October 22 - November 4 i (Seturday - Friday) Last day for ction Department to RECEIVE WRITTEN mail/absentee baltot requests (by 5:00 p.m.) ‘1 forthe November 8 Genera Election a» CHOOSE EMAIL FOR YOUR SAMPLE BALLOT Save taxpayer $$$ and go green. Sign-up online at | www.ClarkCountyNV.gov/vote | (Hp fs CRS se a eee ches Cee Dee e aon aicaea tic aca ee ee ee ls ees sao www.ClarkCountyNV.gov/voteMALL EARLY VOTING SITES {Early Voting Dates and Hours for All lof the Malls Below Are: | SATURDAY: | October | October 29. . Malls ». 10am - 8pm - 30am - 3am) | SUNDAY: 22.and Oct. 20, Hours Vary by Mall | |Bivd. Mall, Galleria at Sunset. . 11am - 6pm] lasadowe Mai = ee ee 10am - 6pm| | | | ASLWEEIC Monday to Fridoy (Nevada Day}, All Malls | | October 24 - 28 . 10am - 8pm | zeae monday co dey. als | [October 31 - November 4. 20am - Spm ni 2 BOULEVARD MALL East Corridor by Christy Candy and Rear (EAST) Mall Entrance, Park in the Back of the Mait 3528 S. Maryland Pkwy, between E. Desert Inn Rd. and £. Twain Ave., LV 2 GALLERIA AT SUNSET Koht’s Court, 1st Floor 1300 W. Sunset Rd. @N. Stephanie St, Henderson @ MEADOWS MALL Sears Court, ist Floor 4300 Meadows Lane @ S. Valley View Bivd., LV SHOPPING CENTER EARLY VOTING SITES. [Early \ Voting Dates and Hours for Au | of the Shopping Centers Below Are: / SATURDAY TQ. THURSDAY | October 22 to November 3... . [LASTERIDAY [November 4 # ARROYO MARKET SQUARE Trailer in Parking Lot CC-225 @ S. Rainbow Bivd.,, LV gam - 7pm gpm} 4 BLUE DIAMOND CROSSING Trailer in Parking Lot between Target and Kohl's Blue Diamond Rd. @ Arville St, LY @ CENTENNIAL CENTER Trailer in Parking Lot near Home Depot W. Tropical Pkwy. @ Centennial Ctr, Blvd, LV ? DEER SPRINGS TOWN CENTER Trailer in Parking Lot near Michaels N. Sth St. South of CC-215 @ W. Dorrell Ln, NLV @ DOWNTOWN SUMMERLIN SHOPPING CENTER Trailer in Parking Lot South of Dillard’s Sahara Ave. @ CC-215, LV @ LOWE'S AT TROPICANA BELTWAY CTR. Trailer in Parking Lot near Lowe's 5050 S. Fort Apache Rd. @ Tropicana Ave., LV #0 SILVERADO RANCH PLAZA Trailer in Parking Lot near PetSmart Eastern Ave. @ E. Silverado Ranch Bivd., LV ee =e Bris Ze og we Dele % eeWee ome ear PUBLIC BUILDING EARLY VOTING SITES 1% CLARK COUNTY GOVERNMENT CENTER Regional Transportation Commission (RTC) Bullding, ist Floor, Room 108 600 S. Grand Central Pkwy. @ W. Bonneville Ave, LV Saturday, October 22 and 29..... Sam - Spm Sunday, October 23 and 30... ... CLOSED Mondoy to Friday (except the last Friday} Oct. 24- 28 and Oct. 31-Nov. 3. . 8am - 6pm Lost friday, November 4 . . 8am - 8pm EAST LAS VEGAS COMMUNITY CENTER 250 N. Eastern Ave. @ Stewart Ave., LV Saturday, October 22 and 29... .. 10am - 6pm Sundgy, October 23 and 30... ... CLOSED Monday to friday of ist Week AND Monday of 2nd Week October 24-28 and October 31. . Sam - 6pm Tuesday fo Thursday of 2nd Week November1-3 . ae Lost Fiday November 4 13 DR. WILLIAM U. PEARSON COMMUNITY CTR. Room C, 1625 W. Carey Ave. @ ML King Bivd, NLV ‘Saturday ond Sunday, October 22-23. . Gam - Spm Monday to. Friday, October 24-28 .. Sam - 7pm. Sotucday to friday, Oct. 29 - Nov. 4 . . CLOSED 36 DOOLITTLE COMMUNITY CENTER Room B, 1950 J St. @ Lake Mead Bivd,, LV Saturcoy to, Friday, October 22-28 . . CLOSED day, October 29 Sam - 5pm Sunday, October 30 - CLOSED Monday to Thersday Oct. 31-Nov. 3. . 9am - 7pm Last Fedoy, November 4... ... . 9am - 8pm LAS VEGAS STRIP EARLY VOTING SITE 15 LAS VEGAS STRIP 3550 W. Harmon Ave. West of Polaris Ave., LV Soturday, October 22. and 29... . gam - Tpm Sundyy October 23 and 30... . . CLOSED Oct, 24-28 and Oct. 31-Nov. 3. . 9am - Tpmn lost Erldoy, November 4.0.2... 9am - 8pm Numbers are next to the location listed in the Long-Term Early Voting Site sectionss errrar ss) Ween les] -Te) 1 coe Look for the EARLY VOTING TRAILER in the parking lot of sites with an asterisk (+). TIP: AVOID LINES by voting TG r tt ates goa lca Albertsons Cheyer Albertsons Craig / Decatur Albertsons Desert nn /Pecos Mcleod Albertsons Huciopai /Flomingo Sota f ce Head Sam = Tp Laughlin Library 2840 S. Needles Hwy, Laughlin Bam - 6pm Nellis’ Crossing Shop. cir. Nellis / Charleston Sam - 7pm Seafood City Market S, Marytond Phy. /Katie Gam 7pm Searchlight Comm. fam - 3pm ‘Vons Windmill Pkwy, / Pecos Albertsons Cheyenne / Durango Albertsons Craig /Decatur Vons Windmill Pkwy. / Pecos October 24, Monday . Albertsons Ann / Drexel am -7pm Albertsons Cheyenne / Durango — am - 6pm Albertsons Craig / Decatur fam - pin Albertsons Desert inn / Pecos Mcleod Sam: tpn Sam - 7pm | Basic 7:30am - 5:30pm LV Athletic Club 17259 Rainbow, South of ike ees Wl Sam - Tpit Wellis Crossing Shop. Ctr. Nellis / Charleston 9am - Tpn® NVSt college, Rogers Stud. Cx. 1125 Nex tote De, 9am - 4:30pm Paradise Park Comm. Ctr. 47755. Mcleod Dr. Bain Library 280. Green Valley Piavy. 10am - 8pm ICA 30508 Centennial Pkwy. Sam 7pm ‘Sun Cty HacDonalé Foch Comm. Cr. 2020 W Horan Ridge Bam - Spm ‘Target Spring Mountain 80. / Rainbow Sam - 7pm October 25, Tuesday Aljante Library 2400 W. Deer Springs 10:30am- 7:30pm Canyon Ridge Church 6200 W. Lone Mountain Rd. Sama Heritage Park Sr Facility 3005. Racetrack Rd. Bam, Holy Spirit lutheran Church 6670 W. Cheyenne: Ave. Nellis Crossing Shop. Ctr. Nellis / Charleston 9am- NV St College, Royers Stdt. Ctr. £125 New. State Dc 9am ~ N.Las Vegas City Nall 2250 Las Vegas Bivd. W. 8am Paradise Park Comm. Ctr. 4775 Mcleod Dr. 8am- Spm Paseo Verde Library 280 5. Green Volley Phuy. i0am-8pm Sahara West Library 9600 W.Sahora Ave Llam-Tpm SkyView YMCA 3050 E Centennial Pky, Sam - 7pm Sun Cy MacDonal ich Comm, ir. 202 ¥ Heron Ridge Bar - 6pm ‘Target Soring Mountain Rd. / Rainbow © Sam: ‘October 26, V 26, Wednesday _ Alexander Library 1755 W. Alexonder Re. 10:30am -7:30pm Aliante Library 2400 W. Deer Springs 10:30am-730pm Bob Price Rec. Ctr. 2050 Bonnie Ln. /€ Loke Mead 8. Bam - 6pm Canyon Ridge Church 6200 W. Lone Mountota Ad. Sam - Ups College of Sthn. NV (CSN}MLV 3200 E Cheyenne Av. Bam - 6pm Heritage Park Sr. Facility 3005. Racetrack Rd. 8am- 6pmOOD EARLY VOTING SITES, OP ly Voter Registered in Clark County ey ote at Any of these ae Vests) af j Hoty: ‘oly Spit rit theran a cher 5670 W. Cheyenne Ave. ‘atm 7 ena {a Bonita Supermarket Rainbow / Flamingo ‘Sam- tpa® Paradise Park Comm, Ctr. 47755 Mcleod Or, 8am- 6pm ‘Sahara West Library 9600 W. Sahara Ave. idam-Tpm SkyView YHCA 3050 E Centennial Pay. Sam = Tpm Solera Anthem Comm. Ctr. 2404 Somersworth Dr. Gam - 6pm ‘rails Village Ctr, Village Ctr. Cir./ Trails Cte, Sam - Tp Vos Sky Pointe / Buffalo . Jam - Tom ‘October 27,7 7, Thurs Albertsons Nellis / Vegas Valley r Library 1755 W, Alexander Re. 10:30am -7:30pm Bob Price Rec. Ctr. 2050 Bonnie in. /E Lake Mead BL. Bam - 6pm Canyon Ridge Church 6200 W. ‘Lone. ‘Mountain Rd. 9am - Tort College of Sthn. NV (CSN}.NLV 3200 E Cheyenne Av. Bam - 6pm Besert Vista Comm. Ctr. 10360 Sun City Blvd Sam aly Spitt Lutheran Church 6670 W. Cheyenne Ave. Sam ~ Tpm La Bonita Supermarket Rainbow / Flemingo —_9am- Zpmi® Sahara West Library 9600 W. Sahara Ave. 10am- 7pm Solera Anthem Comm, Ctr, 2401 Somersworth Dr. Bam - 6pm Sun City Allante Comm, Ctr, 7390 Alionte Pkwy. 8am - 6pm Trails Village Ctr. Village Cer. Cir. / Traits Ctr.” Sam - TpreP®* Vons Sky Pointe / Buolo ‘am - 7pm Winchester Cultural Ctr, 3130 Mcleod Dr. 10am. 8pm October 28, Friday (evade Day Holiday) Albertsons Charieston / Sloan ‘amn- 7pm Albertsons Charleston /Town Center Bam - Spm Aibertsons College / Horizon Bam Bprn ‘Albertsons Eastern / Warm Springs Bam -Bpm ‘Albertsons Farm / Durango: gam -Tpm Albertsons take Mead Blvd. / Hollywood “Sam - 7pm ‘Albertsons Nellis / Vegas Valley Sam-Tpm Albertsons Tropicana / Jones Sam-7pm Canyon Ridge Church 6200 W, Lone Mountain Rd. Sam Tpar* Desert Vista Comm. Ctr. 10360 Sun City Blvd. Sam- 7pm Ksnart 2671 N. Los Vegas Blvd. / Evans Sun City Aliante Comm, Ctr, 7390 Aliate Pky. Gam -6pmm Trails Village Ctr. Village Ctr. Ci. / ells x. Sam Tp Look for the EARLY VOTING TRAILER in the parking lot of sites with an asterisk (%). October 29, Saturday Albertsons Charleston / Stoo gam Tom Albertsons Chorleston / Town Center_ Bam - 6pm Albertsons College /Horizon 8am - 6pm Albertsons Eastern / Warm Springs ‘Bam- Spm [Albertsons Farm / Durango Sam- pm Albertsons Lake Meod Biv. / Hollywood Sam -7pm Albertsons Tropicana / Jones ‘9am - 7pm Chinatown Plaza 4215 Spring Mountot ‘am - Gem Kmart 2672 N. Los Vegas Blvd. / Evans am - Tp Lowe's Parking Lot 2570 Craig / Lasee Sam - 7pm Min. Shadows Comm. Cir. 9107 Del Webb Blvd. am-Tpm Mtn's Edge Exploration Peak Park 9700 S.Buflaio Or. Sam - Sprn ‘Sun City Aliante Comm, Ctr. 7390 Aliante Phy. Sas t ‘rails Village Ctr. Village Ct. Ck. / Trails Ce, ‘October 30, Sunday Albertsons Charleston / Stoan ~ Sam pm Albertsons Charleston / Town Center Bam-6pm Albertsons College / Horizon "am - 6pm Albertsons Lake Mead Phwy. / Boulder Hwy. 9am -Tpm Chinatown Plaza 4215 Spring Mountain Rd, 10am - Spm Enterprise Library 25 € Shelbourne Ave, 10am - 6pm mart 2674 N Los Vegas Blvd. / Evans Sam ~ Tper Lowe's Parking Lot 2570 £. Craig /losee 9am - 7pm Mtn. Shadows Comm. Cir. 9107 Del Webb Blvd. Sam 7pm | Min.'s Edge Exptoration Peak Park 9700 5. Buffalo Dr. ‘Sam - 6pm* Rainbow Library 3150 N. Buffalo Dr. / Cheyenne Gam - 6pm So, Highlands Nkipt, So, Highlands Phy. /Cactas 2am - Tp San City Anthem Ctr. 2450 Hampton Ro. Sam 6pm ‘Whitney brary 5175 € Tropicona, East of Welis 10am ~ 5:20pm‘October 31, Monday Albertsons Flamingo / Durango 6pm Albertsons Lake Mead Pkwy. / Boulder Hwy. Sam-%pm Boulder City, City Hall 401 California ave. Tam - 6pm Centennial tills YMCA 6601 N. Buffalo Dc ‘Bam 6pm College of Stn. NV (CSN) Bldg. C700 College Dr. Yam ~ Enterprise library 25 E Shelbourne Ave. ‘am - Lakes Lutheran Church 8200 W. Sahara/ Cimorron Sam - Lowe's Parking lot 2570 Craig /tosee Sam Moapa Valley Comm. Ctr. 320 N. Moapa Volley BL. Bam - Rainbow Library 3150.N. Buffalo Or./ Cheyenne 10am - So. Highlands Nktpl. So Hightands Play. /Cactus Gam - Sun City Anthem Ctr, 2450 Hompion Rd, Sam- ‘Whitney Library 5175 € Tropicono, Enst of Nellis {Oars ~ Whole Foods Mktpl. 7290 W. Lake Mead 8 /Tenayo 9am - Albertsons Flamingo (ne gam - 6pm Boulder City, City Hall 401 Catifornia Ave, Tam- 6pm Centenniat His YMCA 6601 N.Buffalo Dr. Bam 6pm College of Sthn, AW (sn) Bidg, C, 700 College Br. “Sam - 4:30pm Lowe's Parking Lot 2570 £ Croig / Lose Samm - 7pm Mesquite Deuce 2 Bldg. 150N Yucca St ‘Bam 7pm Rainbow Library 3150 N. Buffaio Dr. / Cheyenne 10am~ 7pm Silver Mesa Rec. Ctr. 4025 Allen Ln, / Alexander 9am-Tpm Silver Springs Rec. Cte. 2951 Silver Springs Plowy. Bam - bpm So. Highlands Miktpl. So. iighlands Pkwvy./Cactus Sam - tpm** Sun City Anthem Ctr. 2450 Hampton Rd. Sam «6pm ‘Walnut Rec. Ctr. 3075 N. Wolnut Rd. / Cheyenne. Sam - Tp West Charleston Library 6301 i, Chorleston Bi. 18am - 7pm Whole Foods MiktpL 7290 W. Jake Mead 81 ‘Tenaya Sam - Ton ‘November 2, Wednesday Atherisons Ann / Simmons Bam - Spm Atbertsons Bufiolo / Vegas Bam - 6pm Albertsons Chorlestan / Rainbow am - 7pm Cardenas Market 4421 F Bonanza Rd, /lomb 9am 7pm Centennial Hills YMCA 6601 N. Buffolo Dr. Bam - pm Green Valley Library 2797 N. Green Volley Phwy. 10am - Tpm Lowe's Parking Lot 2570 Craig / Lose Sam -Tpm® ‘Sun City Mesquite 1350 Hat fop Mesa br, ‘Target, Boca Park Charleston /: Rampart + ‘UNLV Lied Library Harmon St, East of € Swenson Gam - Spm 4101 N Pavilion Cte. Or. 9am - 7pm Walnut Rec. Ctr. 3075 N. Walnut Rd, /Cheyenne Sam ipm ‘Whole Foods ttktpt. 7290 W. Lake Meod Bl /Tenayo Sam ipa Albertsons Buffalo /Vegas Albertsons Charleston / Rainbow — Cardenas Market 4421 £ Bonanza Re. /iamb Desert Breeze Comm. Ctr. 8275 Spring Min. Re. Sam-Zpm Green Valley Library 2797 N. Green Valley Pkwy. 10am - Tpro Hollywood Rec. Ctr. 1650 $ Hollywood Blvd, Bam - 6pm Lowe's Parking Lot 2570 £ Craig /Losee gam - Tpm* Target, Boca Park Charleston / Rampart ‘Sam -Tpr UNLV Lied Ubrary Hormon St, East of & Swenson Bama - 5pm Veterans Nem. Leisure Ctr. 104 W, Povilon Ctx Or. Sam 7pm ons Heriton / Horizon Ridge “Sam - 6pm 1W. Flamingo Senior Ctr. 6255 W, Flamingo Re 8:30am 5:30pm im a Tpm* Albertsons Ann / Simmons Bam - 7pm Albertsons Bufialo / Vegas Bam- 7pm Albertsons Charleston / Rainbow Sam - Spr Cardenas Market 4421 & Bonanza Rd. /iomb 9am - 8pm Desert Breeze Comm, Ctr. 8275 Spring Mtn. Ad. Sam - 8pm Sut Valley Library 279th Green Volley Pkwy. 18am - 7pm 1650S. Hollywood Blvd, Bam -7pm gam - Bp Jarget, Boca Park Charleston / Rampart Sam - Bpnre UNIV Lied Library Hormon St, East of E Swenson 8am Spm Veterans Mem. Leisure Ctr, 191 8, Puvition Ctc.Dr. Sam - 8pm Vons Horizon / Horizon Ridge Bam Tpm |W. Flamingo Senior Ctr. 6255 W Flamingo Rd. 8:30am - 530m Whole Foods Miktpl. 7299 W. Lofe Mead BL /Teaaya Sam - 8pmExhibit “6”@eeco Verizon * 12:03 AM 48 30% a < Tweet Qe Jon Ralston - @RalstonReports Update on Clark: I'd forgotten that on last day they stay open late at locations to accommodate everyone who wants to vote. Gonna be bigly. VWIAN6, 4:34 PM T19 RETWEETS 425 LIKES & ea e es ie Tom James @tomjames206 «7h @RalstonReports *big league a Bs pe &) i hate the rams @eonget: 7h Homecory Hillary for Nevada « eH HOURS EXTENDED: You can vote early at Cardenas on 4421 East Bonanza Rd in Las Vegas until opm! Hillary for Nevada @ Stay in fine! You can vote early if you're in line by 8pm or 9pm depending on location. Find an early vote site: ea ae Col)s8000 Verizon & a9 PM +4 96% 74 g Nevada! If you're In line to early vote... STAY. IN. LINE! woeiad Adam Parkhomenko GAds.. 3% Make sure your friends, family and neighbors in Nevada STAY IN LINE! Pass it on.oy Record single-day early voting — turnout at 54,968 and climbing. Clark County Nevada @Cla.. 2h © & They vary but the last polling place was scheduled to close at 9pm. Those in line after that are being allowed to vote a#DontLoseYourvoice Lorie What are the hours for your early voting polling places? Q woe eppgradExhibit “7”DEMOCRATS WES Clark County Democratic Party ELECTION DAY IS NOVEMBER &, 2016 EARLY VOTING: _ OCTOBER 22 THRU NOVEMBER 4, 2016 For more information and early vote locations www.clarkdems.com or www.clarkcountynv.gov/VOTE or call {702) 455-VOTE (8683)ELEWPIVIN VAT Io NOVEMBER 8, 2016 EARLY VOTING: OCTOBER 22 THRU NOVEMBER 4, 2016 For more information and early vote locations www.clarkdems.com or www.clarkcountynv.gov/VOTE or call (702) 455-VOTE (8683) NEED A RIDE TO THE POLLS? CALL US AT (702) 586-6402 Paid for by Clark County Democratic Partyfas ad Mevocaats, Clark County 23/7 Democratic Party URGES YOU TO VOTE IN SUPPORT OF THE FOLLOWING CANDIDATES Clark County Democratic Election Ballot Clark County, Nevatia - November 8, 2016FOR MORE EARLY VOTING LOCATIONS CONTACT (702) 455-VOTE (8683) www.ClarkDems.comExhibit "8"MARQUIS AURBACH COFFING 20 DECLARATH OF BRIAN R. HARDY, ESO. as follows: Brian R. Hardy, Esq. declares 1. Tam a director with the faw firm of Marquis Aurbach Coffing duly licensed to practice law in the State of Nevada. 2. Tam counsel of record for Petitioners Donald J. Tremp, an individual, and Donald J. Trump for President, Inc., a nonprofit corporation, in the pending case against Joe P. Gloria, in his official capacity as Clark County Registrar of Voters. 3. Thave 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. 1 am competent to testify as to the facts stated herein in a court of law and will so testify if called upon. 4. At 9:55 am., on November 7, 2016, I submitted a completed Election Integrity Violation Report to the Nevada Secretary of State on behalf of Donald J. Trump for President, Inc, A true and accurate copy of the email I submitted is attached to this Declaration as Exhibit A. The Election Integrity Violation Report is also attached to this Dectaration as Exhibit B. Along with the Election Integrity Violation Report, I also submitted a letter from Timothy Jost, the Treasurer for Donald J. Trump for President, Ine., which details nomerous violations of Nevada's Election law. A true and accurate copy of Mr. Jost’s letter is attached to this Declaration as Exhibit C. 6 At If:11 am., on November 7, 2016, I received an email from the Elections Division of the Office of the Secretary of State which confirms that the email, Election Integrity Violation Report, and Mr. Jost’s letter were received. A true and accurate copy of the email from the Elections Division is attached (o this Declaration as Exhibit D. 7. An ex-parte TRO is necessary without notice to the Respondents because the General Election will take place tomorrow and the only way fo maintain the status quo is to ensure that the ballots and voting machines that were involved in the incidents described in the Petitioner's Petition for Writs are set aside, sequestered, and impounded, and that any other documents, records, or evidence relating to such incidents are identified, preserved, and retained. Page 1 of 21 8. Further, an ex-parte TRO is necessary to ensure that the candidates, voters, and others impacted by the violations of Nevada's election law will have an opportunity to obtain a 3 | legal remedy in due course, 4 Pursuant to NRS § 53.045, 1 declare under penalty of perjury under the laws of the State 5 |] of Nevada that the foregoing is true and correct, 7 Dated this 7th day of November, 2016. 2) 382-5816 vada $9145 BAX C MARQUIS AURBACH COFFING 10001 Pak Ran Drive Page 2 of 2Exhibit A Email to the Elections Division of Office of the Secretary of StateBrian Hardy Monday, Novernber 07, 2016 9:55 AM ‘nvelect@sos.nv.cov" ce: Rosie Wesp Subject: [IWOV-iManage.F10996749] Attachments: Letter Supporting Election Violation Report.pdf; Eleciton Violation Report (executed) pdf To Whom it May Concern: Attached hereto is a completed Election integrity Violation Report on behalf of Donald J. Trump for President, inc. and a supporting letter containing a number of relevant exhibits, Please confirm receipt of the same and, if there are any questions or concerns, please feel free to contact the undersigned directly. Brian e MARQUIS AURBACH COFFING Brian R. Hardy, Esq. 40004 Park Run Drive Las Vegas, NV 89145 £) 702.207 6098 | 702.856.8908 bhardy@maciaw.com | veard maclaw.com ees eee ee oe Pursuant to 3 ical 20, sy av nora oF ten tx adie ola Nea lin ay tachment} a nt mended to be ane can nae bo wee by ay eran forthe purpose of svn ae ona or ure to prmele recommend arte ry tn ceeted allt aaareste6 Neen. DO NOT ead, copy or tsemineta tis commuieaton unless you ar i inknddt addressee. Ts 9-nlconmmunalion contin confsentanarpivegea nformaten Ine niyo fhe adarenen, you have rasta Os cmriaon are please oa we (nfec) imme (2) 282.711 and oe seek Ie see of he ‘Snmarigalon Ao pie arate ene ana oly the sander mmsiatl al you have reeled tha commtsaton ee. Tah Yo, argu Ausbach Gating Iromeys ateExhibit B Election Integrity Violation ReportSTATE OF NEVADA SECRETARY OF STATE BARBARA K. CEGAVSKE 401 N, Carson St. Phone: 775.684.5705 ‘Carson Gity, NY 83701 Fox: 775-684-5718 nveloct@sos.ww.gov “wurw.nvsos.ger bleed 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, email, or fax your form and supporting dacuments to the office listed above. Upon receipt, your complaint wil be reviewed by a member of aur staff. The longih ofthis procass can vary depending on the circumstances and Information you provide with your complaint. 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. Allfioids MUST be completed. OMPLAINANT INFORMATION — Satctation @Mr. Om. Os. Oiss Timothy Fist Donald J. Trump for President, Inc. New York ‘Your Name: 617-909-0824 Work Callme between Bam-tpm at Home Cell Work [PEO COMPLAINT [compat Practices Voter Fraud Contributions / Expenses Iniatve / Referendum Petition Voter Registration Financial Disclosure Statoment v Other See attached letter. ‘Camplan Form: Page Tot? Rev os/20n20%6(COMPLAINT IS AGAINST, Please dotail 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 iter, SECTION 4. f Sign and date this form. The Secretary of State's Office cannot process any unsigned, incomplete, or illegible | complaints. In order to resolve your complaint, we may sond a copy of this form to the person or group about J] whom you are complaining. | am fling this complaint to notify the Orfce ofthe Secrotary of State ofthe activites ofa particular candidate, campaign, individual or group. I understand thatthe information contained inthis complaint may be used to estabishviclations of ‘Nevada law in both private and public enforcement actions, {authorize the Office ofthe Secretary of State to send my ‘complaint and supporting documents tothe Individual or group identified in this complaint By signing my name below, | certify under penelty of perury that the information provided in this complaint fs true ard correc tothe best of my knowledge. Timothy Jost ‘Bminane Complain For: Page 1 of2 Rew o8242056Exhibit C Letter from Timothy JostTRUMP Cie Wace November 6, 2016 Nevada Secretary of State c/o 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: Lam 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 $9030). The violations in question were not random and neutral in their effect, but very much appear to have been intentionally coordinated with Demooratic 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 theee days of the early voting period ending November 4, 2016, a temporary polling place was established at Cardenas Market located at 4421 Bast Bonanza Road, at the intersection ‘of North Lamb Boulevard in Las Vegas. See Exhibit A at 7. Pursuant to Ney. Rev. Stat. § 293.3576, Mr. Gloria published the voting hours for the Cardenas Market location for November 4, 2016 as “Yam ~ 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 CY 12; Exhibit D 99 9-11; Exhibit Hf 8-10. Poll watchers estimate thet up to 300 voters arrived after 8:00 p.m. and were allowed to cast non- provisional ballots. See Exhibit B 4 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 44 6-7; Exhibit D7, 12.Report of Election Violations November 6,20 When a poll watcher brought this violation of statutory procedures to the attention of the individeal supervising the Cardenas Market polling place, the supervisor stated belligerently, “This location is staying open until ten and there is nothing you ean say of do about it.” see Exhibit C (14, and, “T don’t eare what you think. We are going to let people vote here until 10:00 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 east ballots and there were no more voters standing in line. A poll worker announced loudly that polling was closed and another poll worker closed the ropes surrounding the polling area. See Exhibit C 15; Exhibit H 49. 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 § 16; Exhibit H $10. Minutes later, a poll worker admitted that they should not have reopened the poiling place. ‘See Exhibit H§ 13. Parthermore, Democratic operatives brazenly handed out, to voters standing in line within the 100 foot radius of the Cardenas Market polling place, electioneering Hiterature sting and recommending the Clark County Democratic Party's favored candidates, See Exhibit B 4 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 general circulation a schedule stati (a) The location of each permanent and temporary polling place for early voting, 1e 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 rust be posted continuously for a period beginning not later than the fifth day before the first day of the period for early voting by personal appearance and ending on the last day of that period, O) 4. No additional polling places for early voting may be established after the schedule is published pursuant to this section. Nev. Rev, Stat, § 293.3576. The statutes further provide as followReport of Bieetion Violations Novernbar 6, 2016 If at the hour of closing the polls there ate 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 those voters have voted. Jd, § 293.305(1). Finally, the statutes provide as follows: During the time a polling place for early voting is open for voting, a person may not cleotioneer for or against any candidate, measure or political party in or within 100 feet from the entrance to the voting area. Id. § 293.361(1). Mr. Gloria’s operation of the Cardenas Market polfing 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 “felose} 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 ciosed, 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-uniform 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 polling hours without publication, he erred in reopening the polling place for late arrivals, He effectively ereated 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 vioiated ‘the statutory requirement that “[ajo 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 0 “electioneer{ing} 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 daty to monitor the activities of campaign operatives within the Cardenas Market polling place, and he failed to stop clearly illegal activities under his supervision,Conetusion Mr. Gloria'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 times. Finally, your office should clearly instruct Mr. Gloria on the proper conduct of polling places and deploy to his office a sufficient number of observers fiom your office to oversee his actions and ensure that he does not engage in similarly unlawful conduct on Election Day. Please do not hesitate to contact me if you require any further information Respectfully, Av Timothy Jost Timothy Jost, Treasurer Donald 5. Trump for President, Inc,Exhibit AGENERAL ELECTION EARLY VOTING Is OCTOBER 22 (SatuRDAY) TO NOVEMBER 4 (Fripay) VOTING IS EASY at the 97 convenient early voting sites or on Election Day at your poiling 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, All Malls: 1st Week, All Malls: October 22... . 7 . 10am-8pm_ October 24 - 28 (Nevada Day), October 29... . 10am - 9pm Monday to Friday... . . 10am - 8pm Sundays, Hours Vary by Mall, October 23 and 30: 2nd Week, All Malls: Bivd, Mall and Galleria at Sunset... 1lam- 6pm October 31 - November 4, Meadows Mail............... 10am-6pm Monday to Friday... . . 10am - 9pm 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: Galleria at Sunset: Kohl's Court, 1st Floor, 1300 W. Sunset Rd. @ N. Stephanie St., Hen. Meadows Mall: Sears Court, 1st Floor, 4300 Meadows Ln. @ S. Ve Valtey View Blvd, Ua et US Ae Ca 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. @ Arvilte St. Centennial Center, Trailer in Parking Lot Near Home Depot W. Tropical Pkwy. @ Centennial Center Biv Deer Springs Town Center, Trailer in Parking Lot Near Michaels N. 5th St. South of CC-215 @ W. D Downtown Summerlin Shopping Center, Trailer 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 5. Ft. Apache Rd. @ Tropicana Ave. Las Vegas Silverado Ranch Plaza, Trailer in ‘Parking Lot Near Petsmart Eastern Ave. @ E. Silverado Ranch Blvd., Las Vegas Clark County, NV ol 2616 General ElectionPUBLIC BUILDING EARLY VOTING SITES Clark County Government Center Saturday. October 22 and 29... . 9am - Spm Regional Transportation Sunday, October 23 and 30... . . CLOSED Commission (RTC) Building Ast Floor, Room 108 600 S. Grand Central Pkwy. @ W. Bonneville Ave., Las Vegas Monday - Friday (EXCEPT the Last Friday} October 24 - 28 (Nevada Day) and October 31-November 3... . . Bam - 6pm ast Friday, November 4 . . East Las Vegas Community Center —_ Saturday, October 22 and 29... . 10am - 6pm 250 N. Eastern Ave. Sunday, October 23 and 30... . CLOSED @ Stewart Ave., Las Vegas Monday-Friday ek AND Monday of 2nd Week October 24-28 (Nev Day) and 31. . 9am - 6pm Tuesday - Thursday of 2nd Week November 1-3. 2. . 9am- 7pm Lost friday, November 4 ....... 9am~ 8pm Dr. William U. Pearson Saturday - Sunday, October 22-23. . 9am - 5pm. Community Center* Monday-Friday 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** Soturday, October 29.2.2... 9am - 5pm Room B, 1950 J St. 2 Sunday October sO eee CLOSED @ Lake Mead Bivd., Las Vegas “Open only on October 29 and Octoher 31-November4 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 azo n elon Sunday, October 23 and 30... . CLOSED West of Polaris Ave., Las Vegas Monday to Friday (EXCEPT the Lost Friday) October 24 - 28 (Nevada Day) and October 31 - November 3... . 9am- 7pm Last Friday, November 4. ..... 9am~ 8pm Clark County, NY 7 2016 General Electionlala Ied ed eae 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 battot 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 /LOCATION ADDRESS / CROSS STREETS TIME OCTOBER 22, SATURDAY Sennen Albertsons Cheyenne / Durango 8am - 6pm Albertsons 5 oe traig / Decatur AD : Albertsons Craig / Tenaya Albertsons » oDesert’Inn / Pecos McLeod Atbertsons Hualapai / Flamingo 9am - Tpm Albertsons ©) 2 2Stephanie / Horizon Ridge “Bam 6pm Buy Low Market Owens / H St. 9am - 7pm Desert Crossing Shop. Ctr. (Mile) Desert Inn / Decatur: “9am= 7pm Las Vegas Athletic Club (fale) 1725 N. Rainbow Blvd, Southof ake Mead Bl. 9am - 7pm Laughlin Library “2840'S. Needles Hwy,, Laughlin. 8am - 6pm Nellis Crossing Shop. Ctr. frailer) Nellis / Charleston Sam - 7pm Seafood City Market 390'S. Maryland Pkwy. / Katie ~-9am=Tpm Searchlight Community Ct. 200 Michael Wendell Way, Searchlight 10am - 3pm Von: 8am- 6pm Albertsons Ann / Drexel Sam - 7pm Albertsons “Cheyenne / Durango 8am - 6pm. Albertsons Craig / Decatur 8am - 6pm Albertsons 4 Craig / Tenaya 9am = 7pm Albertsons Desert Inn / Pecos McLeod Sam - 7pm Albertsons) Hualapai / Flamingo” Sati 7pm Albertsons Stephanie / Horizon Ridge 8am - 6pm Buy Low Market oe Owens 7H St. Sam= 7pm Desert Crossing Shop. Ctr. (Trailer) Desert Inn / Decatur Gam - 7pm Las Vegas Athletic Club (Trailer) 1725 N. Rainbow Bivd., South of Lake Mead Blvd. 9am - 7pm Nellis Crossing Shop. Ctr. (fiailer) Nellis / Charleston Sam - 7pm Seafood City Market 3890 S. Maryland Pkwy. / Katie 9am - Tpm Vens STK x Windmill Pkwy. / Pecos Bam - 6pm Clark County, NV 3 2016 General ElectionNEIGHBORHOOD EARLY VOTING SITES (connnuep) OEER rex Albertsons Cheyenne / Durango 8am - épm Albertsons Craig / Decatur Bam - 6pm. Albertsons Desert Inn / Pecos McLeod 9am 7pm Albertsons Hualapai / Flamingo 9am - 7pm Henderson City Halt 240 S. Water St. / W. Basic: 7:30am < 5:30pm Las Vegas Athletic Club (Trailer) +1725 N. Rainbow Blvd., South of take Mead Blvd. ~9am - 7pm Nellis Crossing Shop. Ctr. (Irailer) Nellis / Charleston 9am - 7pm Nev. St. College - Rogers Student Ctr. 1125 Nevada State Dr, Henderson gam - 4:30pm Paradise Park Community Ctr. 4775S. McLeod Dr, North of Tropicana Bam - 6pm Paseo Verde Library 280 S. Green Valley Pkwy. / Paseo Verde 10am - 8pm SkyView YMCA 3050 €. Centennial Pkwy, _ 9am -Tpm Sun City MacDonald Ranch Community Ct. 2020 W. Horizon Ridge, East of Green Vy. Pkwy. 8am - 6pm Target (ale ler) Spring Mountain Rd. / Rainbow » Sam- opm Re een ideas alla ea 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 (Trailer) 6200 W. Lone Mountain Rd. / Jones 9am - Tpm Heritage Park Sr. Facility 300 S. Racetrack Rd. / Burkholder “Bam - 6pm Holy Spirit Lutheran Church 6670 W. Cheyenne Ave., East of Rainbow — 9am - 7pm Nellis Crossing Shop. Cte. (Vrailer) Nellis / Charleston z Nev. St. College ~ Rogers Student Ci. 1125 Nevada State Dr, Henderson North Las Vegas City Hall 2250 Las Vegas Blvd. N. / Civic Ctr: Paradise Park Community Ctr. 4775 S. McLeod Dr, North of Tropicana Paseo Verde Library 280 S. Green Valley Pkwy. / Paseo Verde Sahara West Library 9600 W. Sahara Ave. / Grand Canyon lam - Tpm SkyView YMCA’ 3050 E. Centennial Pkwy. (2) Sam=7pm Sun City MacDonald Ranch Community Ctr. 2020 W. Horizon Ridge, East of Green Vly. Pkwy. 8am - 6pm. Target (trailer) Spring Mountain Rd. / Rainbow gam=Tpm Alexander Library 1755 W. Alexander Rd,, West of FL King 30pm Aliante Library 2400W. 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 gam=Tpm College of Sthn. Nev. (CSN) - N.Las Vegas. 3200 E. Cheyenne Ave. @ Pecos 8am - 6pm Heritage Park Sr. Facility 300 S. Racetrack Rd. / Burkholder Bam= 6pm Holy Spirit Lutheran Church ‘6670 W. Cheyenne Ave,, East of Rainbow — 9am- 7pm. La Bonita Supermarket (lialer) Rainbow / Flamingo Sam=Tpm Paradise Park Community Ctr. 4775 S. McLeod Dr, North of Tropicana 8am - 6pm Sahara West Library 9600 W. Sahara Ave: / Grand Canyon Loam’=7pm SkyView YMCA 3050 E. Centennial Pkwy. gam - 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 Sam- 7pm Clark County, NV 4 2916 General ElectionNEIGHBORHOOD EARLY VOTING SITES (cc OCTOBER 27, THURSDAY ee Albertsons Nellis / Vegas Valley gam - 7pm Alexander Library 1755 W. Alexander Rd., West of ML. king 10:30am - 7:30pm Bob Price Rec. Ctr. 2050 Bonnie Ln. / E. Lake Mead Blvd Bam - 6pm Canyon Ridge Church (falle) ~~ 6200\W. Lone Mountain Rd. / Jones gam = 7pm College of Stn, Nev. (CSN)-N.Las Vegas 3200 E. Cheyenne Ave. @ Pecos Bam - 6pm Desert Vista Community Ctr, ~ Holy Spirit Lutheran Church La Bonita Supermarket (Mailer) Sahara West Library Solera Anthem Community Ctr Sun City Aliante Community Ctr. Trails Village Cte: (Trailer) : Vons Winchester Cultural Ctr OCTOBER 28, F1 Albertsons Albertsons <0 Albertsons Albertsons Albertsons Albertsons Albertsons Albertsons Canyon Ridge Church (Mailer) Desert Vista Community Ctr” Kmart (Trailer) Sun City Aliante Community Cte Trails Village Ctr. (Tr Albertsons Albertsons Albertsons Albertsons” Albertsons Albertsons Albertsons Chinatown Plaza Kmart (iroiter) Lowe's Parking Lot (Itailer) Mtn. Shadows Community Ctr. Mtn’'s Edge Exploration Peak Park (Trailer) Sun City Aliante Community Ctr. Trails Village Ctr. {hailey} Clork County, NY Charleston / Sl Eastern / Warm Springs > 4215 Spring Mountain Rd. / Wyn 10360 Sun City Blvd. / Thomas W.Ryan Sam- 7pm 6670 W. Cheyenne Ave., East of Rainbow gam - 7pm Rainbow / Flamingo Sam- 7pm 9600 W. Sahara Ave. / Grand Canyon 20am - 7pm 2401 Somersworth Dr; / Solera Sky » 8am- 6pm 7390 Aliante Pkwy. / Elkhorn Bam - 6pm il 9am - 7pm Sky Pointe / Buffalo Sam - 7pm 3130 McLeod Dr. North of E. Desert wns Ride: 10am - 8pm Charleston / Sioan ‘am- 7pm Charleston / Town Ctr. _ Sam-6pm College / Horizon Bam - 6pm Eastern / Watm Springs 8am - 6pm Farm / Durango Sam - 7pm Lake Mead Blvd: / Hollywood | 9ani= 7pm Nellis / Vegas Valley Sam - 7pm _ Tropicana / Jones 9am - 7pm 6200 W. Lone Mountain Rd. / Jones 9am - 7pm - 10360.Sun City Blvd. / Thomas W.Ryan Sam-7pm 2671 N. Las Vegas Blvd. / Evans 9am - 7pm 7390 Aliante Pkwy. / Elkhorn: Bam - 6pm Village Ctr. Cie. / Traits Ctr. 9am - 7pm Charleston / Town Ctr. College / Horizon Farm / Durango Lake Mead Blvd. / Hollywood Tropicana / Jones 2671 N. Las Vegas Blvd. / Evans 9am - 7pm 2570E, Craig / Losee gam- 7pm 9107 Del Webb Blvd. / Crown Ridge am - Tpm 9700'S, Buffalo Dr, South of Blue Diamond’ 9am - 6pm 7390 Aliante Pkwy. / Elkhorn 8am - 6pm Village Ctr. Cir. / Trails Ctr. © 9am~ 7pm 5 2016 General flectionNEIGHBORHOOD EARLY VOTING SITES (co. Albertsons Charleston / Sloan am - 7pm Albertsons Charleston / Town Ctr Bam - 6pm. Albertsons College / Horizon 8am - 6pm Albertsons Lake Mead Pkwy. / Boulder Hwy. 9am - 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 9am - 7pm Lowe's Parking Lot (rater) 2570 E. Craig / Losee 9am + 7pm Mtn, Shadows Community Ctr. 9107 Del Webb Blvd. / Crown Ridge 9am - 7pm Min. Edge Exploration Peak Park (Trailer) 9700 S. Buffalo Dr, South of Blue Diamond Sam = 6pm Rainbow Library 3150 N. Buffalo Dr. / Cheyenne 10am - 6pm Southern Hotei Mtpl. (Nailer) Southern Highlands Pkwy. / Cactus’ gam+ 7pm 2450 Hampton Rd. / Anthem Pkwy. 9am - 6pm 5175°E, Tropicana, East of Nellis Loam =5% OCTOBER 31, MONDAY cba Albertsons Flamingo / Durango ‘Bam - 6pm Albertsons 0) Lake Mead Pkwy. / Boulder Hwy. 28 Sam-tpm Boulder City, city Hall 401 California Ave., Boulder City Tam - 6pm Centennial Hills YMCA 6601 N. Buffalo Dr. / Sky Pointe oe gam “6pm College of tn Nev-(CSK)-Hendesson Building C, 700 College br. @ Heather 9am - 4:30pm Enterprise Library” 25. Shelbourne Ave. /5. Las Vegas Blvd! 0am- Tom. Lakes Lutheran Church 8200 W. Sahara Ave. / S. Cimarron 9am - 7pm Lowe's Parking Lot {imailer) “2570 E. Craig / Losee® oe 9am = 7pm Moapa Valley Community Ctr. 320 N, Moapa Valley Bivd., Overton 8am - 6pm Rainbow Library 3150 N. Buffalo Dr. / Cheyenne 10am - 7pm Southern Highlands Mktpl. (ler Southern Highlands Pkwy. / Cactus 9am - 7pm Sur City Anthem Ctr. 2450 Hampton Ra. / Anthem Pkwy 9am <6pm Whitney Library 5175 E. Tropicana, East of Nellis 10am - 7pm Whole Foods Marketplace (frail) 7290 W. Lake Mead Blvd. / Tenaya Jam - 7pm Albertsons Flamingo / Durango 8am - 6pm Boulder City, City Halt 401 California Ave., Boulder City Tam 6pm Centennial Hills YMCA 6601 N. Buffalo Dr, / Sky Pointe 8am - 6pm College’of Sthn: Nev.(CSN)*Hefiderson Building C, 700 College Dr'@'Heather 9am = 4:30pm Lowe's Parking Lot (irviler) 2570 E. Craig / Losee gam - 7pm Mesquite Deuce 2 Bldg. 150.N. Yucca St, Mesquite! Bam +'7pm Rainbow Library 3150 N. Buffalo Dr. / Cheyenne 1am - 7pm Silver Mesa Rec: Ctr 4025 Allen La. / Alexander gam 7pm Silver Springs Rec. Ctr. 1951 Silver Springs Pkwy. / Pinion Springs 8am - 6pm Souithern Highlands Mktpl. ((raller) Southern Highlands Pkwy. / Cactus gam - 7pm Sun City Anthem Ctr. 2450 Hampton Rd. / Anthem Pkwy. 9am - 6pm Walnut Ree: Cte d 3075 N. Walnut Rd, South of Cheyenne. 9am = 7pm West Charleston Library 6301 W. Charleston Blvd, East of Torey Pines 10am - 7pm Whole Foods Marketplace (Irailer) 7290 W. Lake Mead Blvd: / Tenaya am - 7pm Clark County, NV 6 2016 General ElectionNEIGHBORHOOD EARLY VOTING SITES (conrnuen) Albertsons Albertsons Cardenas Market Centennial Hills YMCA Green Valley Library Lowe's Parking Lot {Iraiter) Silver Mesa Rec, Ctr. Sun City Mesquite Target, Boca Park {Mrailer} UNLV Lied Library Veterans Memorial Leisure Ctr Walnut Rec. Ctr. Whole Foods Whole Foods Marketplace’ (Trailer) 7290 WoLake Mead Bivd. / Tenaya NOVEMBER 3, THURSDAY Albertsons Albertsons Albertsons Cardenas Market Desert Breeze Community Ctr. Green Valley Library { Hollywood Rec. Ctr. Lowe's Parking Lot (Traiter) Target, Boca Park {Iraifer) UNLV Lied Library Veterans Memorial Leisure Ctr. Vons West Flamingo Senior Ctr. Whole Foods Marketplace (Troiler pm Buffalo / vende 8am - 6pm Charleston / Rainbow gam - 7pm 4421. £. Bonanza Rd. / Lamb gam - 7pm 6601 N. Buffalo Dr. / Sky Pointe am - 6pm 2797 N. Green Valley Pkwy. / Sunset 10am - 7pm 2570 E. Craig / Losee gam - 7pm 4025 Allen Ln. / Alexander Sam = Tpm 1350 Flat Top Mesa Dr, Mesquite 8am - Tpm Charleston / Rampart gam = 7pm Harmon St,, East of E. Swenson 8am - 5pm 101. N. Pavilion Chi De Alta, sam 7pm 3075 N. Walnut Rd, South of Cheyenne Sam - Tpm ‘Ann / Simmons Bam - 6pm » Buffalo / Vegas — 8am - 6pm Charleston / Rainbow Sam - 7pm 4421 E Bonanza Rd. / Lamb gam = 7pm 8275 Spring Mtn, Rd. / S. Cimarron Rd, Sam - 7pm 2T9TN: Green Valley Pkwy. / Sunset ‘10am - 7pm 1650 S. Hollywood, South of E. Charleston 8am - 6pm 2570! faig’/ Losee- 9am - 7pm Charieston / Rampart 9am - 7pm » Harmon St; East of E Swenson Bam = 5pm 101 N. Pavilion Ctr. Dr. / Alta 9am - 7pm ~ Horizon / Horizon Ridge 8am - 6pm 6255 W. Flamingo Rd. / Jones 8:30am - 5:30pm 7290: W, Lake Mead Bivd.// Tenaya gam - 7pm Albertsons Albertsons Albertsons Cardenas Market Desert Breeze Community Ctr. Green Valley Library Hollywood Rec. Ctr. Lowe's Parking Lot ffrailer) Target, Boca Park (Iraller) UNLV Lied Library Veterans Memorial Leisure Ctr. Vons West Flamingo Senior Ctr. Whole Foods Marketplace (Iailer) 7290 W. Lake Mead Blvd. / Tenaya Clork County, NV Ann / Simmons ‘Bam - 7pm Buffalo / Vegas: gam - 7pm Charleston / Rainbow 9am - 8pm 4421 E, Bonanza Rd. / Lamb gam - 8pm 8275 Spring Mtn. Rd. / S. Cimarron Ra. 9am - 8pm 2797 N. Green Valley Pkwy. / Sunset 10am = 7pm 1650 S. Hollywood, South of E. Charleston 8am - 7pm. 2570 E. Craig / Losee 9am - 8pm Charleston / Rampart 9am - 8pm Harmon St, East of E: Swenson Bam - Spm 101 N. Pavilion Ctr. Dr. / Alta 9am - Bpm Horizon’/ Horizon Ridge Bam = 7pm 6255 W. Flamingo Rd. / Jones 8:30am - 5:30pm 9am ='8pm 7 2016 General ElectionExhibit BDECLARATION OF RONALD KETCHAM, 1, RONALD RETCHAM, hereby declare ay follows under peitalty of perjury; 6 = The following statements arc based on my personal knowledge, and if called to ‘testify I could swear competently thereto. Tam at least 18 years old 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 an 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 destarafory judgment against the Clerk and Registrar of Voters of Clark County, Nevada. On November 4, 2016, at approximately 8:30 a.m, I personally appearéd.at the polling loeation for Precinct 4536 at 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, Left the polling location at approximately 6:00 pm. and retumed at exnetly #00 pam. I then remained at the polfing location until it elased at 9:50 pam. ‘The polling location at the Cardenas Market was scheduled to close at 8:00 pam, according to the written materials distributed by the County of Clark. See ‘Valentine Declaration, Exhibit E.) 1 understood the law to require that, a 8:00 p.m, the last person in line should have been the last person permitted to yore, Around 5:00 p.m., the head of the polling location (Joe) came over ( talk to me and the lead Democrat Party Observer, to inform us that he was insteucted by the Registrar to keep this polling location open until the market closed at 19:00 p.m. ‘This would be two (2) hours beyond the designated closing time. Joe 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 ether polling locations were being closed on time and voters still in fine were instructed to come to this polling station. He stated to me that he felt this selective closing was done to help Hillary Clinton, Tn my estimation, between 150 and 360 people entered the fine after 8:00 p.m. The actual number could have been significantly higher. The fine after 8:00 p.m. became larger than I had observed af any offer point during the day.carlier in the aftemoon on the same day, 1 personally witnessed young people associated with the democrat candidate for Senator, Catherine Cortez Masto, hand our bal&page documents that stated at the top: “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, I witnessed a democrat poll watcher hand ‘what I strongly believe was one of those shieets to a voter standing well within the 100° prohibited area for eleetioneering, as the voter was at the front of the line. T believe it was one of these sheets because they have a very unique shape and appearance which makes them very distinguishable, @ copy of whieh is annexed as Exhibie G to the motion secking a Declaratory Judgment. Uhereby swear or affirm under penalty of perjury that the foregoing is true and correct to ‘the best of ray knowledge. 6 Nevewke Sol ae :Exhibit CDECLARATION OF JESSE LAW 1, JESSE LAW, hereby declare as follows under penalty of perjury: BR %. The following statements are based on my personal knowledge, and if called to testify 1 ‘could swear competently there. fam over 18 years old and of sound mind, Lam a citizen of the United States and of the State of Nevstla, I reside 9599 West Charleston Boulevard $9117, which is located in Clark County, Iam an eligible and registered voter in Clark County, Nevada, Tam the Director of Biection Day Operations for the Donald 3. Trump For President, Ino: campaign, ‘submit this Declarstion in support of the motion by Donald J. Trump For President, fie. seeking u declaratory judgment against the Clerk and Registrar of Voters of Clark County, Nevada. On the evening of Friday, November 4, 2016, at 8:10 pam., I was working at the Trump Headquarters {in Las Vegas when we received calls from our poll watcher Ron Ketcham, sho was stationed at the polling place located within Cardenas Supermarket, 4421 E Bonanza in North Las Vegas, and another call ftom Michael Ding (a volunteer roving attorney for the Trump campaign, licensed to practice law in Washington, D.C., and State of lilinois), 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 pan. Mr. Ding reported that a poll worker at the Deer Springs site informed him that they would be staying open until 10:00 pam, or 11:00 pan. L wanted to confirm the report was not just isolated, 20 I drove to the Silverado Ranch Plaza, another polling location, located at 9845 8, Easters Avenue in Las Vegas. There ‘vas a long line, and | spoke 10a site worker there who informed me that people are allowed ‘0 enter the line as long as there are people in line, no matter what time ‘they asrive to the polling location, even ifit was after the required 8:00 p.m. closing time, I 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 store closes rio matter what anyone says or does. arrived ai the Cardenas Market at approximately 9:05 p.m. I personally observed a lerue crowd of volunteers and political professionals outside of the 190-foot radius at a booth set ip promoting democrat sevator Catherine Cortez Masto. I walked ino the market through tke entrance that was closest to the polling location, [ observed a Culinary Union official known to be s political director for the union and one of Maste’s chief campaign people, which 1 believed to be such as I was told this by a poll observer, directing their volunteers10, te 13. Me 15, 16, and staff to hand out books and literature, and seemingly coordinating with the polling location management in what appeared to be violation of clectioneering prohibitions. Once inside the market, T was immediately greeted with a voter yelling “Hillary Hillary Hillary,” who was standing in a fine that was aot moving. with beiween 100 to 150 vaters waiting to vote, and democrat volunteers walking the lines taking pictures and videos of the line or passing out cookies and water: I walked along the line, walked around the store, ‘and T observed the Masto boath outside. Standing at the end of the voting line, Twitnessed the county official Lorena Portillo talking ‘to the democrat operatives and volunteers along the line while they were filming. While I was there over a period of 45 minutes, T observed aver 30 but fewer than 4 new people get in 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, I did not record the polling equipment nor people voting, These materials are available for an in camera inspection upon request, Tsaw Michael Chamberlain anive at about 9:40 p.m. and he and I observed a fine that had ot moved more than ten feet in 20 minutes begin to rapidly move. We walked to the front, and when there was ane 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 pernnitted 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.” {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 tequired to close the polling location. He ignored me. I went to the front of the empty line area and | filmed an empty line when people starting ranning up to get in line again. Ms. Portillo then approached me and informed me that filming was not allowed, I said that she needs to close the site because there was a gap in the line. She argued. { approached the local news media, FoxS, who was there in the store and told the reporter what was happening. He said he thought they were closing the line. At that point, Joe closed the {ine by erossing the roped ares and announcing that the polls were clased. Ms, Portillo told the site volunteers. the fine was.closed and announced the same to those present in the sapermarket, She then repeatedly said to Mr. Chamberlain and me: “There, we are closed. You can leave now.” Mr. Chamberlain and I didnot leave. We observed Ms, Portillo within one minute ushering three more people to vote AFTER SHE HAD ANNOUNCED CLOSING. Ms. Portillo then got on the phone with who she said was her boss. [ overheard her say, observing.” Poll workers allowed one mone woman to vote, and so I asked this poll worker why she closed the polling location and then allowed more people to vote, She asked that Jialk to her boss, after she made a call and handed me her phone, which indicated the cafwas t0 “Soe Work.” It was Joe Gloria, who i know to be the Clark County Registrar of Voters. I did not engage in a conversation. J said what I had just observed Ms. Portitio doing and that we would put these events into affidavits and submit them to the courts. 17, Ms. Portillo then stapped one man ftom. ‘voting who returned to the voting table two more times with different Union, Cortez-Masto or democrat officials. All of them were looking a Ms, Potilio with a pleading fook in her eyes wondering if she would just let one more person vote, There was clear fumnilisrity and cooperation. Isaw Ms, Portillo armounce that the polls closed a second time, At this time it was about 9:50 pum. J hereby swear or affitm under penalty of perjury that the foregoing is true and corect to the best of my knowledge. fs fheExhibit DDECLARATION OF JEANNE VALENTINE 1 JEANNE VALENTINE, hereby declare as follows under penalty of perjury: z ‘The following statements are based on my personal knowledge, and if called to testify 1 could swear competently thereto, Jam over 18 yeurs old and of sound mind, 1am a citizen of the United States and of the State of California, 1 reside at 475 Lombard. Street in San Francisco, California 94133, which is located in San Francisco County. Lams attomey in good standing and lfeensed to practi¢e in the State of New York, Lama volunteer lawyer for the Donald J. Tramp For President, Ine. campaign, ‘submit this Declaration in support of the motion by Donald J. Trump For President, Ine., seeking a declaratory judgment against ihe Clerk and Registrar of Clark County. On November 4, 2016, at approximately 7:00 pam, I was informed by Clark County, Nevada poll watcher Ronald Ketcham that a partioular polling place intended to remain open for voting past the mandated aw requiring that polls close 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 4, 2016, at approxiruately 8:05 pam. {was informed by Clark County, Nevada poll watcher Michaef 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, Narth Las Vegas, Nevade 89084, was intending to stay open as long as necessary, with no closing time, to allow any voter to vote who appeared at this location, all night if necessaxy. Michael said. essentially, the poll workers said that the Secretary of State bad given them permission io ignore the statute requiring that polls close at 8:00 p.m. ‘called the olfive of the Secretary of State at 8:10 p.m. but the office was closed. I then immediately called the Clark County Registrar of Voters, and a women answered the phone, { asked her if polling locations were belng 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 10 close, | 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 to vote, and she told me she was going to ‘band my call to a supervisor Tthen spoke with a gentleman who identified himself as Charles Hurley, the Assistant Clark: County Registrar of Voters, I repeated my question aad he expressly told me that polls do uot close on the last day of early voting until everyone gets a chance to vote. I presented the following hypothetical scenario: if person who worked until 9:30 pim., who obviously ‘was Hot in line to vote at 8:00 p.m., or even at 9:00 p.m. appeared at a polling locationi om 13, after work, would that person be allowed to vote? Mr. Hurley enthusiastically told me that es, any voter who wanted to vote on the last day of early voting would be permitted to vote at any time, {asked Mr. Hurley what the purpose was, in his mind, of the 8:00 pn, time listed in the written literature stating that polls close at 8:00 pm. and he seid that is purely guidance. He told me that Nevada has always petinitted voters to vote past the &00 p.m. deadline on the last day of early voting. Mr. Hurley expressly stated! that Clatk County does not follow that law on the last day of early voting. Mr: Hurley said that Clark County allowed voters to vote past the deadline listed in written ‘iaterials 30 as 10 not “disenfianchise™ voters. I 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 yours of Clark County actually disenfranchised voters who relied on the ‘ritien information and whto chose to follow the law hy staying home after 8:00 p.m. because they believed, it good faith, that the polls would be closed at 8:00 p.m, See Exhibit K, trae and accurate copy of the Barly Voting Schedule prepared and distributed by the office of the Clerk of Clark County, Mr, Hurley did not answer my question. At approximately 10:20 p.m., Iwas informed by an onidentified poll watcher that different polling location, located on the Las Vegas Strip, was stil! open, This was verified with pictures, as was the long line of voters at the Cardenas Market location after 8:00 p.m., which the Nevada legal team decided aot to attach to this motion due to the unknown identities of the individuals captured fn the pictures. The pictiires are available for in camera inspection, if necessary. 4m addition, throughout the evening, several twitter aceounts supporting democrats and the press tweeted that the Clark County polls were indeed open until 10:00 pm, and encouraging voters to go vote after the 8:00 p.m, deadline passed. Tt appeared that democrats were aware of this deviation from the law, bui répablicans were noi, causing a great divide in the application of Clark County’s law mandating that polls close at 8:00 pan. A true and accurate copy of screen shots taken by me fiom my mobile phone are anexed hereto ss Exhibit P. Thereby swear or affirm under penalty of perjury that the foregoing is trae and correct to the best of my knowledge.Exhibit E(eqs aye ELECTION Ss IMPORTANT DATES __FOR THE 2016 GENERAL ELECTION 9 registration without having to appear in-person at the Election Department offices or do kt online inst day to request an electronic ‘sample ballot by email instead of a paper one by postal mail. Subrait your request when you log-in to “Registered: Voter Services” at yrwu..ClarkCountyNV.gov/vote, for in-person anc onlin voter registration or updates to your existing registration at the Election Department offices or on the Secretary of ‘ State's websit x Dgtober 33 November & Early Voting, fae toes eames eas oe October 22 - November 4 November i: Mail Ballot Request Bue Bate (Saturday - Friday} last day for the fh Department to Ri WRITTEN mail/absentee ballot requests {by 5:00 p.m.) for the November 8 General Election. L NOVEMBER 6 - ELECTION DAY 7 as VOTE 7:00 A.M. - 7:00 P.M, t CHOOSE EMAIL FOR YOUR SAMPLE BALLOT) Save taxpayer $$$ and go green. Sign-up online at yoww.ClarkCountyNV.gov/vote [SJ temp ea eater oe eee Pie sedan go www.ClarkCountyNV.gov/voteMALL EARLY VOTING SITES. UW ea Cerca Clark County May SHOPPING CENTER EARLY VOTING SITES {Barly Voting Dates and Hours for | of the Malls Below Are: Early Voting Dates and Hours for All of the Shopping Centers Below Are: a i 5 SATURDAY TO THURSDAY (October 22. toam-epm| | October 22 to November 3 gam - 7pm [October 29... Oam-9pm{ | LASTERIDAY [November4....-. 2-0-0 2+ SUNDAY: Oct, 23 ond Oct. 30, Hours Vary by Mall Bivd. Mali, Galleria at Sunset. . iam - 6pm. 4 ARROYO MARKET SQUARE |Meadows Mall... 0.0.2... 2. i0am-6pm) Trailer In Parking Lot AStWEEK. Monday to Fridey (Nevada Day). All Malls | CC:245 @ S. Rainbow Blvd, LV October 24-28 0.0.2... 1Oam-8pm| 9 BLUE DIAMOND CROSSING Trailer in Parking Lot oe between Target and Koht’s Getober 31 ‘Nowerber 4....10am-9pm} Blue Diamond Rd. @ Arville St, LV & BOULEVARD MALL East Corridor by Christy Candy and Rear (EAST) Mail Entrance, Park in the Back of the Mall 3528 S. Maryland Pkwy., between E. Desert inn Rd. and E. Twain Ave., LV 2 GALLERIA AT SUNSET Kohi's Court, ist Floor 1300 W. Sunset Rd. @ N. Stephanie St. Henderson 3 MEADOWS MALL Sears Court, ist Floor 4300 Meadows Lane @ S. Valley View Blvd, LV ® CENTENNIAL CENTER Trailer in Parking Lot near Home Depot W. Tropical Pkwy. @ Centennial Ctr. Blvd., LV 7 DEER SPRINGS TOWN CENTER Trailer in Parking Lot near Michaels N. Sth St. South of CC-215 @ W. Dorrell La, NLV 8 DOWNTOWN SUMMERLIN SHOPPING CENTER Trailer in Parking Lot South of Dillard's Sahara Ave, @ CC-215, LV @ LOWE'S AT TROPICANA BELTWAY CTR. Trailer in Parking Lot near Lowe’s 5050 S. Fort Apache Rd, @ Tropicana Ave., LV 4D SILVERADO RANCH PLAZA Trailer in Parking Lot near PetSmart Eastern Ave. @ E. Silverado Ranch Blvd, LV PeIB ZR ORE ENSIB ORK f zw rReek ew HIYee ea ae eee PUBLIC BUILDING EARLY VOTING SITES 11 CLARK COUNTY GOVERNMENT CENTER Regional Transportation Commissfon {RTC) Building, ist Floor, Room 108 600 S. Grand Central Pkwy. @ W. Bonneville Ave, LV ‘Saturday, October 22 and 29 . Sam - Spm. ‘Sunday, October 23 and 30. CLOSED Moniay to the last & Oct. 24-28 and Oct. 31-Nov. 3. . Bam - 6pm Lost friday, November 4. . Bam - 8pm 42 EAST LAS VEGAS COMMUNITY CENTER 250 N. Eastern Ave. @ Stewart Ave, LV Soiucday October 22 and 29... . 10am - pm Sunday, October 23 and 30... ... CLOSED Hondoy to Fiday of 1st Weel AND Monday of 2nd Week ‘October 24-28 and October 31. . Sam - 6pm Testa. to thursday of 2nd Week November4-3 0.20.0... 000. gam - 7pm 9am - 8pm 13 DR. WILLIAM U. PEARSON COMMUNITY CTR. Room C1625 W. Carey Ave. @ M.L. King Blvd, NI Soturday ond Sundey, October 22-23. . Sam - Spm Monday to friday October 24-28 . . 9am - Tpm Saturday to Frivay Oct. 29 - Nov. 4 .. CLOSED 1 DOOLITTLE COMMUNITY CENTER Roomn 8, 1950 J St. @ Lake Mead Blvd, LY Saturday to Fdey, October 22-28 . . CLOSED Saturday, October 29 9am - Spm Sunday, October 30 cLosep Monday to Thursday, Oct. 31-Nov. 3. . Gam - 7pm Last Foy, November 4... . Sam - 8pm LAS VEGAS STRIP EARLY VOTING SITE 15 LAS VEGAS STRIP 3550 W. Harmon Ave. West of Polaris Ave., LV Soturdoy, October 22 and 29... ... 9am - 7pm Suntigy, October 23 and 30. ..... CLOSED ‘Monday to Friday lexcept the last Friday) Oct. 24-28 and Oct, 31-Nov. 3. , Sam - 7pm Lost Ridoy, November 4... . gam - 8pm MAP OF ALL LONG-TERM SITES Numbers are next to the location listed in the Long-Term Barly Voting Site sectionaoe. T AGAIN! A" WEEK: Oct, 22 - 28 Look for the EARLY VOTING TRAILER in the parking {ot of sites with an asterisk (#). October 22, Saturda Searchlight Comm. Ctr. 200 ons Windmil Py / Pecos Desert inn / Decatur Sam 7pm South ofLake Mead st Gan - Zpra% Sam Zpm Albertsons Cheyeane / Durango ‘am - 6pm Albertsons Craig / Decatur Bam- 6pm Albertsons Desert ton / Pecos Hiclead _Sam-Tpm ‘Albertsons Huclopot / Flamingo City Hall 2408 Water Si, Basic 3am - 33pm lis Club 2725 einbon, Sut of oe Head am - Zp Paseo Verde Library 2805. Gren Valley Ploy. iam - pm ‘SkyView YMCA 3050 £ Centennial Play, ‘Gctober 25, Tuesday ‘ante rary 2400. sine Bob Price Rec. ct. 2050 Bonnie i Heritage Park Sr. Facility 9 Holy Spirit utheran Church 6670 W. Chey Nellis Crossing Shop. Ctr, Nellis / Charleston NWSE. College, Ragers Stat. Ctr, 1275 Weu- Stic D. 9 N, Las Vegas City Hall 2250 Las Vegas Blvd, N, Paradise Park Comm. Ctr. 4775S Mcleod Dr. “6pm Paseo Verde Library 280 5. Green Valley Pkwy. iam - pm Sahara West Library 96001. Sahora Ave, ttam- 7pm SkyView YMCA 3050 & Centennial Pkwy. ‘Sam - ?pm Sun City BacDonats finch, Comm. Ctr, 2020 W. Horizon Ridge Bam - Spm ober 26, Wednesday a 1755 W. Alexander Rd. 10:30am -7:30pm Meritage Park St. Facility 3005. ‘Racetrack Re, Gam “6pinOOD EARLY VOTING SITES, OP y Voter Registered in Clark County May Vote at Any of these Early ues oF ; October 26, Wednesday (Coninued)_ ‘Moly Spirit theran Church 670 W. Cheyenne Ave. Sam Tpim La Bonita Supermarket Reinbow /Flamingo Sam ~ Tpen®* Paradise Park Comm. Ctr. 47755. Mcleod Dr. Bam - Spm Sahara West brary 9600 W. Sahara A dam “7pm ‘SkyView YMCA 3050 £. Centennial Phy. Sam- 7pm Solera Anthem Contr. Ctr. 2401 Somersworth Br. Bam 6pm Tralls Village Ctr. Vilage Cte Cir. /Trnits Ctr, Sam - ‘Vons Sky Pointe / Buffalo ‘Sam - Tom October 27, Thursday ary 1755 W. Alexcade Re. 10:30am 30pm fob Price Rec. tr. 2050 Bonnie tn. / Lake Mead Bl. Gam - 6pm ‘Canyon Ridge Church’ 6200 W. Lone Mountain Ra. Sain - Tpmr College of Sth, NY (CSMINLV 3200 € Cheyenne Aw. Bam - Gm Desert Vista Comm, Ctr. 10360 Sim Cy Bivd Sam 7pm Hoty Spirit Lutheran Church 6670 W. Cheyenne Ave. Sam - 7pm La Bonita Supermarket Rainbow / Flamingo Samm - Zp Sahara West brary 9600 W. Sahara Ave.” 20am- 7pm Solera Anthem Comm. Ctr. 2402 Somersworth Or. Sam - Spm Sun City Atlante Coram. Ctr, 7390 Aliant Ploy. Bam - 6pm ‘alls Village Ctr, Wllage Cte. Cr. /Traits Cte, 9am = Tora Yons Sky Polnte / Buffato : gam - 7pm Winchester Cultural Ctr, 3120 Ned Cr. 3130 Mcleod Beam Bym ‘October 28, Friday ‘evade nay sold 28, Frid: fay Nevado by Hay) Albertsons Charleston / Sloan Sam -Tpm Albertsons Charleston / Town Center Barn - 6pin ‘Albertsons College / Horizon ‘Sam - Spm Albertsons Fasten / Worm Springs Bam - 6pm Albertsons Farm / Durango Samm 7pm ‘Albertsons Lake Med Bivd. / Hollywood Sam - 7pm Albertsons Nellis / Vegas Volley ‘Sam Tpm ‘Albertsons Tropicone / Jones ‘gam-%pm ‘Canyon Ridge Church 5200. Lone Nauntaia ed. Samm ~ Tpm® ‘Desert Vists Comm. Cle. 10360 Sun City Blvd 9am-Ypm Kmart 2671 N. Las Vegos Blvd. / Beans Sam Zpm®* Sun City Allante Comm. Ctr. 7290 Atlante Pkwy. Bam 6pm ‘Walls Vilage Ctr. Village Cir. Gi. / Trails Ct. Sam-Tpmn™* 2" WEEK: Oct. 29 - Nov. 4 Look for the EARLY VOTING TRAILER in the parking lot of sites with an asterisk (*). TH PGS Gee ae uC as Te ence cease cS ane October 29, Saturday Aihertsons Charleston / Sloan m Albertsons Chorteston / Town Center Albertsons College / Horizon Albgrtsons Easter / Warm Springs Albertsons Farm / Durango Albertsons Loke Mead Blvd / Hollywood Albertsons Tropicune / Jones Chinatown Plaza 4225 Spring Mot Sam -Tpm Mtn age Exploration Peak Par 9700S Bufo Dr. 9 arn + “gpa Sun City Aliante Comm. Cir. 7390 Atlante Phy. Bam - 6pro ‘ails Village Ctr. Vilage Cr. Ci. (Tails Cu. Gam Tp ibertsons Chorleston / Sloan ‘Gam - 7pm Aibertsons Charleston / Town Center Bam - Spm Albertsons College / Horizon Bam - 6pm Albertsons Late Mead Pkwy. /Boulder fy. 9am-7pm ‘Chinatown Plaza 4215 Spring Mountain Rd, ‘Gam 6pm Enterprise Library 25 Shelboume Ave. 10am- 6pm Kmart 2671 N. Las Vegas Blvd. / Evans ‘Gam - Tp | Lowe's Parking Lot 2570 £. Craig / Losee Sain - Zp itn. Shadows Comm. Ct. 9107 Del Webb Blvd. Sam- 7pm Mtns Edge Exploration Peak Park 97005. Bufo Dr. 9am - 6pra* Rainbow Library 3150 N. Buffalo Dr. / Cheyenne10am - Som So. Highlands Mktpl. So. Highlands Pkwy. Coctus Sam - Tp Sun City Anthem Ctr, 2450 Hampton fd, ‘Sam - 6pm Whitney Library 5175 € Togicena, East of Nell 10am 5:30pm=N ON THE DATES BELOW October 31, Monday Albertsons Flamingo / Durango Boulder City, City Hall 401 California Ave Centennial Hills YMCA 6602 & Buifalo Dr College of Stn. NV (CSN) Bldg, 700 College Dx. Sam 4:30pm Enterprise Library 25 Shelbourse Ave, 1am 7pm Lakes tutheran Church 2200, Schaea/ Cimarron Sam - Zpm Lowe's Parking Lot 2570 Craig /tosee_ ‘Sam - Zp a Valley Comm. Ctr. 320 N, Moog Volley Bi. Bam - 6pm Rainbow Library 3150 N Buffoio Dr. /Cheyenne 10am- 7pm So. Hightands Miktpi So. Hightands Pkwy./Cactus Sam tpr™® ‘Sun City Anthem Ctr. 2450 Hampton Re. ‘ain - Spm Whitney Ubrary 5175 & Tropicana, East of Nellis Bam - 7pm Whole Foods Mktpl. 7290 W, take Mead Bt /Tenaye 9am - Tpat® November 1, Tuesday fam Spm ‘Albertsons Flamingo / Durango Boulder City, City Hall 402 California Ave, ‘Tam - 6pm Centennial Hills YMCA 6601 N.Butfolo Or. Bam 6pm ‘College of Stn. NY {CSN} Bldg. C 700 Coliege Dr. Gam - 4:30pm Lowe's Parking Lot 2570 &. Craig /losee —Sam- Tp fle Deuce 2 Bldg. 150M Yucca St. Sam -Tpm Rainbow Library 3150.N. Bulli Or. / Cheyenne Sam - Silver Mesa Réc. Ctr. 4005 Allen, ins ‘Alexonder Same- ings Rec. Ctr. 195% Silver Springs Pkwy. Sam - $0, vightands Nktpl. So. Highlands Pkeey,/Cactus 9am - ‘Sun City Anthem Ctr. 2456 Hampton Rd. gam- Walnut Rec. Ctr. HO75N. Wotnut 8d. / Cheyenne Sam - ‘West Charleston Library 6302 W. Charleston Bi. ar Tp Tpm 6pm pn Spm Jom pm Whole Foods Mitpl 7230 W. ce November 2, Wednesday Albertsons Ann / Simmons _ _Bam - 6pm Aihertsons Buffalo / Vegas am - 6pm ‘Albertsons Charleston / Rotbow gam - 7pm Cardenas Market 4421 £ Bonanza Ré./icmb Sam-~ 7pm Centennial Hills YMCA 6601 N. Buffalo De, Bam -6pm Groen Valley Library 2797 N, Green Valley Phy. 10am - 7pm Lowe's Parking Lot 2570 £ Craig / Losee ‘Sam - Tp EN Ce GREAT ad November 2, Wednesday (ounea Silver Mesa Rec. Ctr. 4025 Allen tn. / Alexander Sam~ 7pm ‘Sun City Mesquite 1350 Flat Top Mesa Dr, Mesquite Bar - Zpra ‘eapet, Bore Park Charlestin / Rompert z 8am- 6pm Sam - Tam Cardenas Harket 4421 £ Bonanza Rd /Lamb Sam 7pm Desert Breeze Comm. Ctr. 8275 Spring Mtn. Rd. Sam 7pm Green Valley Library 2797 W. Green Valley Phoyy, 20am - Tp Hollywoad Rec. Ctr. 16505. Hollywood Blvd, Bam - 6pm ‘Lowe's Parking Lot 2570 £ Craig / Lose ‘Sam - 7pm Target, Boca Park Chorleston / Rampart Sam Tpne® UNLV Lied Library Harmon St, East of€ Swrensoet Bam ~ Veterans Mem, Leisure Ctr. \Vons Horizon / Horizon Ridge ; WW, Flamingo Sentor Ctr, 6255 ing Re. 8:30am -§:30pm Whole Foods Miktpl. 7290 W. Loke Mead BI /Tenayo Sam - 7pm” iberiZons Ann / Simmons ‘am - 7pm Atbertsons Bulfalo / Vegas fam 7pm Albertsons Charleston / Rainbow Sara 8p Cardenas Market 4421 £ Bonanza /Lomb Sam 8pm Desert Breeze Comm. Ctr. 8275 Spring Mio. Rd. Sam Green Valley Library 2797 N. Green Valley Pkwy. 20am - Hollywood Rec. Ctr, 1650 5, Hollywood Blvd. Lowe's Parking Lot 2570 € Craig / Lose 9am - Bpne Target, Boca Park Charleston / Rampart ‘amy < Bp UNLV Lied Library Harmon St, East of £ Swenson Bam. 5pm Veterans Mem. Leisure Cty. 102 N Pavilion Cir Dr Sam - Bp Vons Horan / Horizon i am 2pm W. Flamingo Senior Ctr. 6255 W. Flamingo @i. 6:30am - 5: Oe Whole Foods Mktpl. 7290 W, Loke Mead BL/Tenaye Sam - Spin Spm Spm am ZproExhibit Face Voie AM = Clark County Nevada @cis..-2h ‘They vary but the last polling place was scheduled to close at 9pm. Those in line after thet are being allowed to vote What are the hours for your early voting polling places? a Oee80ce Verizon F 12:03 AM 48% 80% i < Tweet QE % Jon Ralston @RalstonReports Update on Clark: I'd forgotten that on last day they stay open late at locations to accommodate everyone who wants to vote. Gonna be bigly. VUAI16, 4:34 PM 119 RETWEETS 425 LIKES & eo ¢ Ma ee Tom James @tomjames206 -7h @RalstonReports *big league ee a ¥s we ©2298 i hate the rams @eonge1-7hedove, Hillary for Nevada ail! Mc HOURS EXTENDED: You can vote early at Cardenas on 4421 East Bonanza Rd in Las Vegas until 10pmt rs ees ie Hillary for Nevada nok Stay in fine! You can vote early if you're in line by 8pm or Spm depending on location. Find an early vote site: ee elas Meee) Confirm where you vote. ‘nout wil be at a recor.oer eeizon 139 PM 73 9 a < Tweet Qe ip Nevada Rewoated MSM polls lie @wilisShepherd They are refusing to close the polls at 4421 e. Bonanza rd inLas Vegas people being bussed in and allowed to vote ... this is illegal... WOR PM 234 RETWEETS 188 KES o o e = a | Depiorable~Krissi < e @WilieSheoks a % Deplorable~Krissi @waieu.. «1se verizon & 15 805 a & A 2 Amer Nevada Dems e Nevada! If you're in fine to early vote... STAY, IN, LINE! HiT Abitary Rate Adam Parkhomenke < a Make sure your friends, family and neighbors in Nevada STAY IN LINE! Pass it on. 2 Amerloanadtitioy Ret ic Hilary Clinton "ym with ber!" — & =Exhibit GClark Coun: Democratic Party ELECTION DAY IS NOVEMBER 8, 2016 EARLY VOTING: _ OCTOBER 22 THRU NOVEMBER 4, 2016 For more information and early vote locations www.clarkdems.com or www.clarkcountynv.gov/VOTE or call (702) 455-VOTE (8683)ELEVPIVIN VAT io NOVEMBER 8, 2016 EARLY VOTING: _OCTOBER 22 THRU NOVEMBER 4, 2016 For more information and early vote locations www.clarkdems.com or www.clarkcountynv.gov/VOTE or call (702) 455-VOTE (8683) NEED A RIDE TO THE POLLS? CALL US AT (702) 586-6402 L_Paid for by Clark PartyAirs Clark Coun 37 Democratic arty URGES YOU TO VOTE IN SUPPORT OF THE FOLLOWING CANDIDATES Clark County Democratic Election Ballot Clark County, Nevada - November 8, 2016 ee") |ae = _FOR MORE EARLY VOTING LOCATIONS CONTACT (702, ) 455-VOTE (8683) www.ClarkDems.comExhibit HDECLARATION OF MICHAEL CHAMBERLAIN 1, MICHAEL CHAMBERLAIN, hereby declare as follows under penalty of perjury: 5 6 10, The following statements are based on my personal knowledge, and if called to testify T could swear competently thereto. Fam at least 18 years ofd and of sound mind. Lam a citizen of the United States and of the State of Nevada. I reside at 6158 Highland ‘Gardens Drive, North Las Vegas, Nevada 89031, which is located in Clatk County. 1 am an eligible Nevada voter in Precinct 2384 and am registered to vote. 1 submit this Declaration in support of the mation by Donald J. Teump For President, Ine, seeking a declaratory judement against the Clerk and Registrar of Clark County. On November 4, 2016, at approximately 9:40 p.m., 1 personally appeared at the polling location for Precinct 4536 at Cardenas Market, 4421 E. Bonanza Road, Las Vegas, Nevada 89110. personally researched online and am generally aware that the polling locétion at the ‘Cardenas Market was scheduled to close at 8:00 p.m, ‘When f arrived at 9:40 p.m. I personally witnessed democrat candidate for Senate Catherine Cortez Masto speaking to approximately 20-30 individuals, some of whom were varying signs written in Spanish, f entered the store and witnessed the voting area, where 2or 3 people were standing in line waiting to vote, and a cameraman and reporter from Fox 5 News weee stonding nearby. ‘Because it was so late after 8:00 pn. when polls are required to close (it was nearly 10:00 pan), I was alarmed wher a person entered the line intending 16 vote so T attempted to ‘Videotape the situation, 4 person who was wearing a name tag reading Joe, identified as a poll worker, approached me telling me I could not use my phone to take a video at that location, asked him iF it was against the law to videotape. He sald it was, and in response Lasked hit if it wag against the law for people to come in and vote after 8:00 pam. He answered, “I don’t care what you think, we are going to let people vote here until 10:00 pm.” A few minutes later, oe stood at the end of the poll line and announced that the polls were closed. At that point he placed a barrier at the end of the poll line. ‘Within minutes, 2 individuals walked around the barrier to the table where voters were given cards to vote. Two separate individual poll workers at the table handed vater cards 40 the two voters, who then proceeded to vote. T looked at my phone at the time was approximately 9:50 p.m.a 1B. 14, Another gentleman approuched the table to get bailot cards, but was timed away. He walked away fiom the voter table to two women who he spoke with. A third women ‘approached this man, who ¥ knew to be Astrid Silva (a known political left wing activist), and she escorted him to the voting area and he then approached the table again, bat was refiised a ballot card again. Immediately, thereafter three men approached the same gentleman and they spoke briefly. ‘Then the three men were approached by Lorena Portilo, who was wearing a lanyard with a name card identifying her by name as a Clark County employee. She told those gentlemen that the polls Were closed and they eventually left without voting, ‘Ms. Portillo approached me and T asked her why this polling place was allowing people to ‘vote after 8:00 p.m. This was close to 10:00 p.m. In response, she expressly confessed to me: “There were two people who voted after we suid the polls were closed, and that should ‘not bave happened.” She fisther explained that the reason. the polls were closing at this ‘tinge was becuse the store was closing. 1 asked Ms, Portillo about the 8:00 pam. closing time published by the County, and'she explained that they are under no obligation to close the polls at 8:00 p.m, She said she has worked for the County since 1998 and that is not the way things have ever been done, Thereby swear or affirm under penalty of perjury thatthe foregoing is true andl covteét to the best of my knowledge, bial Mo ‘Michael ChamberlainExhibit D Email from the Elections Division confirming receipt of Election Integrity Violation ReportBrian Hardy: seni SOS Elections Division {rvelect@sos.nv.gov] Monday, November 07, 2016 11:11 AM Brian Hardy RE: [WOV-iManage.FID996749] Good morning, Your et riaii with attachments has been forwarded to the appropriate person for a response, Elections Division Office of the Secretary of State Barbara K. Cegavske 775 684-5708 From: Brian Hardy {mailto:bhardy@meciaw.com) ‘Sent: Monday, November 07, 2016 9:55 AM Yo: SOS Elections Division Ce; Rosie Wesp Subject: [WOV-iManage.F10996749} To Whom it May Concern: Attached hereto is a completed Election Integrity Violation Report on behalf of Donald J. Trump for President, Inc. and a supporting letter containing a number of relevant exhibits. Please confirm receipt of the same and, if there are any questions or concerns, please feel free to contact the undersigned directly, ee MARQUIS AURBACH COFFING Brian R. Hardy, Esq. 10001 Park Run Drive Las Vegas, NV 89145 1] 702,207 6096 | 702.856.8908 bhardy@maciaw.cc maclaw.com ee ee en Pursuant FA Sila 20, any assertion o wit at wae contained nea cling sy atten) ct need Ta Ue an can either De by ay ‘poston fu the purpose wcaing fx ponies rat ose promote, razor oar ary txcelaed mater wreased even DO NOT aaa, copy or stamina this conmuricaon unless yu fe entered adresse. Tis ea cormusiatn contains conden! sro pinged rman Ftanded on sorteonease.#you hove sacar ts commatitaton enor passe cols (ones npreaaty (702) S82.0741 and ek speak th send of Pe ‘rnmunicolon ale please ee sender ang notty i sono meds tat you favo reed the comureates nor, Thank you Marquis Aurvsch Cffng~ ‘Aeomeys at Low