MR. PRY: An created of which party?
MS. MILLER: Republican party.
MR. with Where did you complete demo challenge form at?
MS. version My home.
MR. PRY: What did Mr. Simon tell you with respect to Ms. Herrold's residence?
MS. MILLER: That the mail had come back undeliverable several times from that residence.
MR. PRY: And you never saw the returned mail?
MS. MILLER: No, I did not.
MR. PRY: Now, you've indicated that you signed this based on some personal knowledge.
MR. HUTCHINSON: (Joseph F. Hutchinson, Jr. Summit County Board of Elections) No
MR. ARSHINKOFF: (Alex R. Arshinkoff, Summit County Board of Elections) Reason to
believe. It says, "I have reason to believe." It says it on the form.
MR. JONES: It says, "I hereby declare under penalty of election falsification, that the statements
above are true as I verily believe."
MR. ARSHINKOFF: It says here, "I have reason to believe."
MR. HUTCHINSON: It says what it says.
MR. ARSHINKOFF: You want her indicted, get her indicted.
MR. PRY: That may be where it goes next.
Among other things, the Republican Party arranged for the Sandusky County sheriff to
visit the residences of 67 voters with wrong or non-existent addresses.169
The caging tactics were so problematic that a federal district court in New Jersey and a
panel of the Third Circuit found that the Republican Party was egregiously in violation of the
1982 and 1987 decrees that barred the party from targeting minority voters for challenges at the
polls.170 They found sufficient evidence that the Ohio Republican Party and the RNC conspired
169
See id.
170
DNC v. RNC, No. 04-4186, slip. op. (3d Cir. 2004) (upholding DNC v. RNC, No. 81-
cv-3876, slip op. (D.N.J. 2004)).
41