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Perkins Coie
607 Fourteenth Street N.W.
Washington, D.C..20005-2011
PHONE: 202.628.6600
FAX 202.434.1690
www.perkinscoie.com
Marc Erik Elias
PHONE (202) 434-1609
FAX (202) 654-9126
EMAIL MElias@perkinscoie.com
August 23, 2010
BY E-MAIL AND HAND DELIVERY
Teri Stroud
FOIA Officer
Board of Elections and Ethics
441 4th Street, NW, Suite 250 North
Washington, DC 20001
Re: Freedom of Information Act Request
Dear Ms. Stroud:
Pursuant to the D.C. Freedom of Information Act, DC St.
§§ 2-531, et. seq., and on behalf of Fenty 2010, I request the
following documents, information, and data:
- The list of all registered voters in the District of
Columbia, including voters marked as inactive. The list should
indicate whether the voter is marked as a Special Ballot voter and the
reason for that designation. Please provide this information on August
30, 2010, and provide updates each weekday.
- The name of all individuals (and all data associated
with each individual) (a) who have requested absentee ballots,
including those individuals on any permanent absentee voter list, (b)
who have been mailed an absentee ballot by the Board, (c) who have
returned an absentee ballot to the Board, and/or (d) whose absentee
ballot has been deemed by the Board to be eligible for counting.
Please provide this information as soon as possible, with updates each
weekday.
- The name of all individuals (and all data associated
with each individual) who have returned an absentee ballot to the
Board and whose absentee ballot has been deemed by the Board to be
ineligible for counting. For each such individual, please also provide
the Board's reason for rejecting the ballot. Please provide this
information as soon as possible, with updates each weekday.
- Copies of all "absentee ballot envelopes" (e.g. the envelope containing the voter's signature) received by the
Board. The copy should include a visible image of the voter's
signature. Please provide this information as soon as possible, with
updates each weekday.
- The name of all individuals (and all data associated
with each individual) who have submitted (or on whose behalf has been
submitted) voter registration applications, and whose applications
have been rejected by the Board. Please provide this information as
soon as possible, with updates each weekday.
- Copies of all Poll Watcher certificates submitted by
the campaigns of candidates for Mayor. Please provide this information
as soon as possible, with updates each weekday.
- The name of all individuals (and all data associated
with each individual) who voted (either by Regular or Special Ballot)
at any of the following locations between August 30, 2010 and
September 13, 2010: the Old Council Chambers, Chevy Chase Recreation
Center, Turkey Thicket Recreation Center, Hines Junior High School,
Southwest Tennis and Learning Complex, and any other location
designated by the Board for early and in-person absentee voting.
Please indicate whether each voter cast a Regular or Special Ballot
and, if the voter cast a Special Ballot, the reason(s) for doing so.
Please provide this information every weekday, starting on August 30,
2010.
- The name of all individuals (and all data associated
with each individual) who voted Special Ballots during the Early
Voting period, along with the reason why the voter was not allowed to
cast a Regular Ballot. Please provide this information every weekday,
starting on August 30, 2010.
- Copies of all Special Ballot Envelopes completed by
voters during the Early Voting period and on Election Day. Please
provide these copies on a rolling basis, starting on August 30, 2010
and continuing until all copies (including copies of all Special
Ballot Envelopes completed on Election Day) have been provided.
- The paper pollbook generated for each of the 143
polling places for Election Day. Please provide this information on
the day that it is finalized by the Board.
- The "Supplemental List of Early Voters", the
"Supplemental List of Absentee Voters", the
"Administrative Challenge List", and any other supplemental
lists generated for each of the 143 polling places for Election Day.
Please provide this information on the day that it is finalized by the
Board.
- The name of all individuals (and all data associated
with each individual) who voted Special Ballots on Election Day, along
with the reason why the voter was not allowed to cast a Regular
Ballot. Please provide this information on September 15, 2010.
- Copies of the completed poll books from all 143 polling
places. Please provide these copies on September 15, 2010.
- Copies of all signed "zero printouts" from
all 143 polling places prepared pursuant to 3 D.C.M.R. § 712.1.
Please provide these copies on September 15, 2010.
- Copies of all reports prepared pursuant to 3 D.C.M.R.
§§ 723.2, 723.3, 723.4, 723.5, and 723.6. Please provide these
copies on September 15, 2010.
- Copies of all certifications from all 143 polling
places prepared pursuant to 3 D.C.M.R. §§ 724.9 and 724.10. Please
provide these copies on September 15, 2010.
- Copies of the Hourly Ballot Reconciliation Forms from
all 143 polling places. Please provide these copies on September 15,
2010.
- Copies of the "iVotronic Touch Screen Voting
Machine Closing Form", "iVotronic Touch Screen Voting
Machine Closing Form", "Delivery Confirmation Form: Primary
Election", "M100 Optical Scan Voting Machine Opening
Form", "Optical Scan Voting Machine Closing Form",
"Election Results Pickup Form for Team 'A' Members", and the
"Removing the RTAL Printer Paper Cartridge" form from all
143 polling places. Please provide these copies on September 15, 2010.
- Copies of any notices mailed to Special Ballot voters
after the election pursuant to 3 D.C.M.R. § 714.15, which are
subsequently returned to the Board as "undeliverable" or for
any other reason. Please provide these copies on the day that they are
received by the Board.
- A copy of the results of any data match or data
verification program that the Board uses to make determinations
pursuant to 3 D.C.M.R. § 714.12. Please provide this on the day that
the Board completes each data match or data verification program.
- Copies of any requests filed by, or on behalf of, other
D.C. Mayoral campaigns pursuant to the D.C. Freedom of Information
Act, DC St. §§ 2-531, et. seq. between January 1, 2010 and September
30, 2010. Please provide these copies on a rolling basis.
If the documents, information, or data can be e-mailed,
you may e-mail them to lejuan.strickland@gmail.com.
If the documents, information, and data cannot be e-mailed, please let LeJuan know, either via e-mail or phone
(202-821-7694), and he will send someone to your office to pick them
up.
If you anticipate being unable to comply with any part
of this request, on the date(s) specified, please let us know
immediately. Please indicate whether, despite being unable to comply
with part of this request, you are still able to comply with other
parts of this request.
Please inform us of any charges associated with these
requests and the method of payment requested.
If you have any questions or concerns, please do not
hesitate to call at (202) 434-1609 or e-mail at MElias@perkinscoie.com.
Very truly yours,
Marc E. Elias
cc: Mr. Kenneth J. McGhie, General
Counsel
Mr. Rokey W. Suleman II, Executive Director
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