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    Indiana Witness List

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    electionlawcentercom
    This document lists the defendants' preliminary witnesses and exhibits they may present at trial in the case of Judicial Watch, Inc. et al. v. J. Bradley King et al. The witness list includes election officials, expert witnesses for both sides, and potential rebuttal witnesses. The exhibit list includes depositions, reports, documents from election agencies, and materials to be used for impeachment or rebuttal. The defendants reserve the right to supplement these lists until the close of discovery.

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    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd

    Indiana Witness List

    Uploaded by

    electionlawcentercom
    375 views4 pages
    This document lists the defendants' preliminary witnesses and exhibits they may present at trial in the case of Judicial Watch, Inc. et al. v. J. Bradley King et al. The witness list includes election officials, expert witnesses for both sides, and potential rebuttal witnesses. The exhibit list includes depositions, reports, documents from election agencies, and materials to be used for impeachment or rebuttal. The defendants reserve the right to supplement these lists until the close of discovery.

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    Expert Eitan Hersh

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    This document lists the defendants' preliminary witnesses and exhibits they may present at trial in the case of Judicial Watch, Inc. et al. v. J. Bradley King et al. The witness list includes election officials, expert witnesses for both sides, and potential rebuttal witnesses. The exhibit list includes depositions, reports, documents from election agencies, and materials to be used for impeachment or rebuttal. The defendants reserve the right to supplement these lists until the close of discovery.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    375 views4 pages

    Indiana Witness List

    Uploaded by

    electionlawcentercom
    This document lists the defendants' preliminary witnesses and exhibits they may present at trial in the case of Judicial Watch, Inc. et al. v. J. Bradley King et al. The witness list includes election officials, expert witnesses for both sides, and potential rebuttal witnesses. The exhibit list includes depositions, reports, documents from election agencies, and materials to be used for impeachment or rebuttal. The defendants reserve the right to supplement these lists until the close of discovery.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    of 4
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    The document outlines witness and exhibit lists for an upcoming trial between Judicial Watch Inc. and Indiana election officials.

    The document provides defendants' final witness and exhibit lists that may be presented at an upcoming trial.

    Witnesses include election officials and experts from both sides. Exhibits include reports, depositions, correspondence and other documents related to Indiana's voter registration procedures.

    1

    UNITED STATES DISTRICT COURT


    SOUTHERN DISTRICT OF INDIANA
    INDIANAPOLIS DIVISION

    JUDICIAL WATCH, INC., et al., )
    )
    Plaintiffs, )
    )
    v. ) 1:12-cv-800-WTL-TAB
    )
    J. BRADLEY KING, et al., )
    )
    Defendants. )



    DEFENDANTS FINAL WITNESS AND EXHIBIT LIST

    The defendants submit their final lists of witnesses and exhibits they may present at trial.
    The defendants respectfully reserve the right to supplement this list as discovery proceeds until
    its closure on December 11, 2013.
    Preliminary Witness List:
    1. Trent Deckard, Co-Director, Indiana Election Division

    2. J . Bradley King, Co-Director, Indiana Election Division

    3. Terrence Coleman, St. J oseph County Voter Registration Board Member

    4. Francisco Fotia, St. J oseph County Voter Registration Board Member

    5. Sarah Redman, Clerk of the Warrick County Circuit Court

    6. Eitan Hersh, Ph.D., 77 Prospect Street, P.O. Box 208209, New Haven CT 06520-

    8209, (203) 436-9061

    7. Karen Handel, the plaintiffs retained expert.

    8. Individuals identified by the defendants as witnesses.

    8. Individuals for the purpose of rebuttal.

    Case 1:12-cv-00800-WTL-TAB Document 67 Filed 09/17/13 Page 1 of 4 PageID #: 327
    2

    Preliminary Exhibit List:
    1. The pleadings in this matter, and all exhibits or attachments.
    2. Report of Eitan Hersh, Ph.D., the defendants expert witness, and documents
    relied upon and referenced.
    3. Report of Karen Handel, the plaintiffs expert witness.
    4. Deposition of Sarah Redman, Warrick County Circuit Court, and all attached
    exhibits.
    5. Deposition of Terrence Coleman, St. J oseph Voter Registration Board Member,
    and all attached exhibits.
    6. Deposition of Francisco Fotia, St. J oseph Voter Registration Board Member, and
    all attached exhibits.
    7. Deposition of Trent Deckard, Indiana Election Division Co-Director, and all
    attached exhibits.
    8. Deposition of J . Bradley King, Indiana Election Division Co-Director, and all
    attached exhibits.
    9. Indiana Election Division Co-Directors interrogatories and responses.
    10. Indiana Election Division Co-Directors interrogatories and responses.
    11. The plaintiffs request for admissions and the defendants responses.
    12. The plaintiff True the Vote interrogatory responses.
    13. The plaintiff J udicial Watch interrogatory responses.
    14. 2012 Election Administration Manual.
    15. 2012 Voter Registration Guidebook
    16. Standard Operating Procedures of the Indiana Election Division.
    Case 1:12-cv-00800-WTL-TAB Document 67 Filed 09/17/13 Page 2 of 4 PageID #: 328
    3

    17. NVRA training materials of the Indiana Election
    Division (excerpts).
    18. SVRS Core team meeting documents (excerpts).
    19. Social Security Administration inquiry letter dated October 3, 2008.
    20. Voter list maintenance reminders to counties, e.g. February 27, 2013 letter to
    County Board of Voter Registration members and Circuit Court Clerks.
    21. U.S. Election Assistance Commission Report.
    22. NASS Report: Maintenance of State Voter Registration Lists.
    23. PEW Center on the States Issues Brief, February 2012.
    24. Any and all documents needed for impeachment and/or rebuttal purposes.
    25. All documents identified in the plaintiffs exhibit list.

    Respectfully submitted,

    GREGORY F. ZOELLER
    Indiana Attorney General
    Attorney No. 1958-98

    By: /s/ Jefferson S. Garn
    J efferson S. Garn
    Deputy Attorney General
    Attorney No. 29921-49













    Case 1:12-cv-00800-WTL-TAB Document 67 Filed 09/17/13 Page 3 of 4 PageID #: 329
    4

    CERTIFICATE OF SERVICE

    I hereby certify that on this 17th day of September, 2012, I electronically filed the
    foregoing document with the Clerk of the Court using the CM/ECF system. Notice of this filing
    will be sent to the counsel of record by operation of the Courts electronic filing system. Parties
    may access this filing through the Courts system.

    Paul J. Orfanedes Chris Fedeli
    J UDICIAL WATCH, INC. J UDICIAL WATCH, INC.
    [email protected] [email protected]

    David R. Langdon Joshua B. Bolinger
    LANGDON LAW LLC LANGDON LAW LLC
    [email protected] [email protected]


    /s/ Jefferson S. Garn
    J efferson S. Garn
    Deputy Attorney General


    Office of the Indiana Attorney General
    Indiana Government Center South, 5th Floor
    302 W. Washington Street
    Indianapolis, IN 46204-2770
    Telephone: (317) 232-6292
    Fax: (317) 232-7979
    Email: [email protected]






    Case 1:12-cv-00800-WTL-TAB Document 67 Filed 09/17/13 Page 4 of 4 PageID #: 330

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