VOTE FORWARD et al v. DEJOY et al

Filing 16

MOTION for Preliminary Injunction by AMY BOLAN, AARON CARREL, COLORADO ORGANIZATION FOR LATINA OPPORTUNITY AND REPRODUCTIVE RIGHTS, INDERBIR SINGH DATTA, DANTE FLORES-DEMARCHI, PAUL HUNTER, SEBASTIAN IMMONEN, KATHRYN MONTGOMERY, SEAN MORRISON, PADRES & JOVENES UNIDOS, LINDA ROBERSON, MARTHA THOMPSON, VOCES UNIDAS DE LAS MONTANAS, VOTE FORWARD, GARY YOUNG (Attachments: #1 Memorandum in Support, #2 Exhibit Index, #3 Exhibit USPS OIG Report (Aug. 2020), #4 Exhibit USPS, Postal Operations Manual (Excerpts), #5 Exhibit USPS OIG Report (May 2020), #6 Exhibit USPS, Mandatory Stand-Up Talk: All Employees, #7 Exhibit Leaked USPS Powerpoint, #8 Exhibit DeJoy Testimony - House Oversight Hearing (Aug. 24, 2020), #9 Exhibit DeJoy Testimony - Senate Hearing (Aug. 21, 2020), #10 Exhibit Statement of DeJoy - House Oversight Comm. (Aug. 24, 2020), #11 Declaration Professor Justin Grimmer, #12 Exhibit USPS, Congressional Briefing (Aug. 31, 2020), #13 Exhibit Chart of States Where Voters' Mail-In Ballots Are Impacted By Defendants' Delays, #14 Exhibit USPS Letter to Pa. (July 29, 2020), #15 Declaration Eitran D. Hersh, #16 Exhibit House Oversight Hearing on USPS Operations - Transcript (Aug. 24, 2020), #17 Exhibit Senate HSGAC Hearing on USPS Operations - Transcript (Aug. 21, 2020), #18 Declaration Aaron Carrel, #19 Declaration Martha Thompson, #20 Declaration Kathryn Montgomery, #21 Declaration Sebastian Immonen, #22 Declaration Amy Bolan, #23 Declaration Inderbir Singh Datta, #24 Declaration Scott J. Forman of Vote Forward, #25 Declaration Alex Sanchez of Voces Unidas De Las Montanas, #26 Text of Proposed Order)(Duraiswamy, Shankar)

EXHIBIT 17

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
VOTE FORWARD,
611 Pennsylvania Ave. SE #192
Washington, DC 20003;
AARON CARREL,
2 N Roby Rd.
Madison, WI 53726;

Civil Case No. 1:20-cv-02405-EGS

VOCES UNIDAS DE LAS MONTAÑAS,
1001 Grand Ave., Suite 107
Glenwood Springs, CO 81601;
COLORADO ORGANIZATION FOR
LATINA OPPORTUNITY AND
REPRODUCTIVE RIGHTS,
P.O. Box 40991
Denver, CO 80204;
and
PADRES & JÓVENES UNIDOS,
4130 Tejon St., Suite C
Denver, CO 80211,
Plaintiffs,
v.
LOUIS DEJOY, in his official
capacity as the Postmaster General,
475 L’Enfant Plaza SW,
Washington, D.C. 20260-0546;
and
UNITED STATES POSTAL SERVICE,
475 L’Enfant Plaza SW
Washington, DC 20260-0546,
Defendants.

SF: 328306-1

DECLARATION OF MARTHA THOMPSON
I, Martha Thompson, declare as follows:
1.

I am a resident of Portland, Maine. The matters set forth herein are true and

correct of my own personal knowledge. If called as a witness, I could and would testify
competently thereto.
2.

I am a registered voter of Maine and have been registered since I turned 18. I am

currently an undergraduate student at Mount Holyoke College.
3.

I sent in my application requesting my absentee ballot on August 18, 2020.

However, my ballot did not arrive at my home address in Maine before I left on August 28th,
2020 to resume my studies. I may need to request a new ballot to be mailed to me because I will
be in various different states over the next two months.
4.

I intend to vote by mail in the November 2020 general election because I do not

know what state I will be in at the end of October. I am currently participating in a program run
by WorldWide Opportunities on Organic Farms, where I will work at organic farms in different
states throughout the Fall semester. I do not know the exact locations of where I will be working
yet, but I could potentially find myself in Arizona, South Carolina, or elsewhere.
5.

It is also possible I will be back in Maine prior to the general election given the

uncertainties that COVID-19 has caused. If I return to Maine, I still intend to vote by mail
because I am afraid of putting my family members at risk of getting sick if I were to vote in
person. In Maine, I live with my parents who are in their late 50s and early 60s. Due to their age,
my parents would be at greater risk if they were to get sick with COVID-19. Thus, all my family
would be cautious and would not want to vote in person.
6.

Whether I am in Maine or in another state as part of my program, I intend to mail

my ballot close to election day. I do not know where I will be, and this makes it very difficult to
obtain my absentee ballot early and to return my completed ballot early.

7.

In Maine, a completed ballot must be received by Election Day in order to be

counted. Because I intend to mail my ballot close to election day, I fear that the delays caused by
USPS will cause my ballot to not arrive on time and therefore not be counted.

I declare under penalty of perjury that the foregoing is true and correct.
Executed on September __, 2020, in Portland, Maine.

Martha Thompson