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 23

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: 328435-2

DECLARATION OF ALEX SANCHEZ ON BEHALF OF
VOCES UNIDAS DE LAS MONTAÑAS
I, Alex Sánchez, declare as follows:
1.

I am the co-founder and executive director of Voces Unidas de las Montañas

(“Voces Unidas”), a new non-profit organization that seeks to elevate the voices of Latinos in
three rural Colorado counties through civic engagement. 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.

Voces Unidas is a new organization created by myself and other individuals from

the Roaring Fork Latino Network, a collective of approximately 100 local Latino and Latina
leaders in the Roaring Fork Valley of Colorado, dedicated to elevating the voices of Latinos and
Latinas in the region. We formed Voces Unidas in order to address the need for civic
engagement of Latino communities in the counties of Garfield, Eagle, and Pitkin. To date, no
non-profit or private organization has spent significant resources in get-out-the vote efforts
specifically aimed at the Latino communities in these three rural counties.
3.

At Voces Unidas, we seek to lead efforts such as registering people to vote,

providing them with information during elections, and mounting get-out-the-vote campaigns. In
the future, Voces Unidas intends to nurture candidates who want to run for office and champion
broader social-justice issues such as affordable housing and expanded health care coverage for
Latino communities in the region.
4.

Latinos represent 30% of the population in Garfield and Eagle counties and 10%

of the population in Pitkin county. The rural communities Voces Unidas serves, which are often
hundreds of miles in distance from each other and from city centers, rely heavily on USPS for
both everyday communication, delivery of essential needs like medications, and for the exercise
of their civic rights, including the right to vote.
5.

The delays caused by USPS’s policies have threatened to frustrate Voces

Unidas’s mission to elevate the voices of Latinos and enhance civic engagement in two specific

ways. First, the delays caused by USPS’s policies have undermined Latino and rural
communities’ trust in USPS. People in communities we serve have already experienced delays
in receiving their mail and are worried about the severe consequences this may have. These
communities rely on the mail for essential items like medication or official notices from
government agencies, so when they are impacted by USPS delays, they distrust the government’s
ability to respond to their needs and withdraw from civic engagement. If people believe their
vote will not count and their voice will not be heard, they will not take the time and effort to cast
a ballot.
6.

As a result, Voces Unidas will be spending its resources, time, and energy on

efforts to rebuild the communities’ trust in the electoral process and in USPS so that they may in
turn have confidence that their voice will matter when it comes time for the general election.
Voces Unidas plans to do this via additional education and outreach efforts, including phone
banking and canvassing, pushing out digital adds, and creating additional voter engagement
programs. Absent USPS’s policies that have caused delays, Voces Unidas would not have to
direct so much time, energy, and resources into the effort to rebuild people’s trust in USPS.
7.

Second, the delays caused by USPS’s policies have shortened the timeline that

Voces Unidas previously thought it had to complete our get-out-the vote campaigns and have
caused us to have to work faster and harder. In Colorado, a completed ballot must be received
by Election Day in order to be counted. Because of the USPS delays, Voces Unidas will have to
redirect its time, energy, and resources at convincing people to mail their ballot earlier than they
normally would have. In order to ensure that their votes will be counted, people will have to
mail their ballot earlier than in past elections. Thus, Voces Unidas will have to initiate its
outreach and canvassing efforts earlier that we planned, and we will have to expend additional
resources to successfully do this.
8.

The delays caused by USPS’s policies have caused Voces Unidas to have to

expend its limited resources in a manner that we did not previously foresee or budget for. Before
the USPS policies caused mail delays and eroded the communities’ trust in the mail service,

Voces Unidas planned to spend approximately $30,000 on civic engagement work tied to the
general election. But now, given the need for additional education and outreach efforts, Voces
Unidas calculates that we will need to spend $50,000 to $80,000 in addition to the original
budget in order to be effective. Voces Unidas will spend this additional money by paying
canvassers to do more phone banking and field canvassing, by adding paid advertising via social
media, and by mailing two informational pieces to each Latino voter in the three counties well in
advance of election day to help ensure that voters send in their ballot earlier. With these
additional efforts, Voces Unidas thinks we will able to restore people’s confidence in USPS and
also convince people in our communities that they need to mail their completed ballot out earlier.

I declare under penalty of perjury that the foregoing is true and correct.
Executed on September 5, 2020, in Glenwood Springs, Colorado.

Alex Sánchez