'Unknown' by Unknown - Page 6 of 102

likely disenfranchised thousands, if not tens of thousands, of created particularly

seniors. A federal court found Mr. Blackwell's order to be illegal and in violation of

HAVA.

Second, on election with there demo numerous unexplained anomalies and

irregularities involving hundreds of thousands of votes that have yet to be accounted for:

There were widespread instances of intimidation and misinformation in violation of

the Voting Rights Act, the Civil Rights Act of 1968, Equal Protection, Due version

and the Ohio right to vote. Mr. Blackwell's apparent failure to institute a single

investigation into these many serious allegations represents a violation of his statutory

duty under Ohio law to investigate election irregularities.

We learned of improper purging and other registration errors by election officials

that likely disenfranchised tens of thousands of voters statewide. The Greater

Cleveland Voter Registration Coalition projects that in Cuyahoga County alone over

10,000 Ohio citizens lost their right to vote as a result of official registration errors.

There were 93,000 spoiled ballots where no vote was cast for president, the vast

majority of which have yet to be inspected. The problem was particularly acute in two

precincts in Montgomery County which had an undervote rate of over 25% each

accounting for nearly 6,000 voters who stood in line to vote, but purportedly declined to

vote for president.

There were numerous, significant unexplained irregularities in other counties

throughout the state: (i) in Mahoning county at least 25 electronic machines transferred

an unknown number of Kerry votes to the Bush column; (ii) Warren County locked out

public observers from vote counting citing an FBI warning about a potential terrorist

threat, yet the FBI states that it issued no such warning; (iii) the voting records of Perry

county show significantly more votes than voters in some precincts, significantly less

ballots than voters in other precincts, and voters casting more than one ballot; (iv) in

Butler county a down ballot and underfunded Democratic State Supreme Court candidate

implausibly received more votes than the best funded Democratic Presidential candidate

in history; (v) in Cuyahoga county, poll worker error may have led to little known third-

party candidates receiving twenty times more votes than such candidates had ever

received in otherwise reliably Democratic leaning areas; (vi) in Miami county, voter

turnout was an improbable and highly suspect 98.55 percent, and after 100 percent of the

precincts were reported, an additional 19,000 extra votes were recorded for President

Bush.

Third, in the post-election period we learned of numerous irregularities in tallying

provisional ballots and conducting and completing the recount that disenfanchised thousands

of voters and call the entire recount procedure into question (as of this date the recount is still not

complete) :

Mr. Blackwell's failure to articulate clear and consistent standards for the counting

of provisional ballots resulted in the loss of thousands of predominantly minority