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 20

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.

NY: 1257567-2

DECLARATION OF AMY BOLAN
I, Amy Bolan, declare as follows:
1.

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 resident of Honolulu, Hawaii. I am a registered voter of Hawaii, and have

been registered for the past 7 years. I usually vote by mail in most elections because it allows me
greater flexibility in researching candidates and understanding different ballot initiatives,
propositions, and the like.
3.

I understand that Hawaii is conducting the November election entirely by mail.

As such, I have no choice but to use a mail-in ballot for the November election.
4.

As a registered voter in Hawaii, a mail-in ballot for the November election is

mailed to me automatically without need for me to request it. I have not yet received my mail-in
ballot. My understanding is that my ballot will arrive approximately 2 to 3 weeks before
Election Day.
5.

I intend to mail my ballot close to election day because of the additional time it

will afford me to familiarize myself with and thoroughly research many of the local candidates
and other issues on the ballot. Because I only recently relocated back to Hawaii after attending
school on the mainland, I am less familiar than I would like with the local races and issues. I
wish to use what time I can to become as educated as possible in order to make the best, most
informed decision regarding my votes.
6.

In Hawaii, 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 and possibly not until the
weekend before, I fear that the delays caused by United States Postal Service 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 4, 2020, in Honolulu, Hawaii.

Amy Bolan