Republican Vote Suppression Deposition

Case 2:81-cv-03876-DRD-MAS Document 66-2 Filed 04/30/09 Page 1 of 182 PageID: 2631
EXHIBIT 2
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Maria Cino
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEW JERSEY
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DEMOCRATIC NATIONAL COMMITTEE, )
et al. , )
Plaintiffs, )
Page 1
v. )' C.A. No. 81-3876
REPUBLICAN NATIONAL COMMITTEE, )
et al., )
De fendan ts . ) PAGES 1 - 164
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DEPOSITION OF MARIA CINO
Friday, October 29, 2004
washington, D.C.
Reported by: Sara A. Watt
Job No. 163933
Esquire Deposition Services
D.C 18004413376
MD 18005396398
VA 18007528979
MariaClno
PageZ
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October 29, 2004
5:17 p.m.
7 Deposition of MARIA CINO, held at the offices of:
8
9 McDermott, Will & Emery
10 600 Thirteenth Street, Northwest
11 washington, D.C. 20005-3096
12
13 Pursuant to notice, before Sara A. Watt, Registered
14 Merit Reporter and Notary Public in and for the
15 District of Columbia.
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1 ON BEHALF OF THE PLAINTIFF INTERVENOR EBONY
2 MALONE:
3 John Nields, Esquire
4 Patricia G. Butler, Esquire
5 Howrey, Simon, Arnold & White
6 1299 Pennsylvania Avenue, Northwest
7 Washington, D.C. 20004-2402
B (202) 783-0800
9
10 Judith A. Browne, Esquire
11 Advancement project
12 1730 M Street, N.W.
13 Washington, D.C. 20036
14 (202) 728-9557
15
16 ON BEHALF OF THE PLAINTIFF DNC:
17 Angelo J. Genova, Esquire
18 Genova, Burns & vernoia
19 Eisenhower Plaza II
20 354 Eisenhower Parkway
21 Livingston, New Jersey 07039-1023
22 (973) 533-0777
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MariaCino
1 ON BEHALF OF THE DEFENDANT RNC:
Page 4
2 Bobby R. Burchfield, Esquire
3 Jason Levine, Esquire
4 McDermott, will & Emery
5 600 Thirteenth Street, Northwest
6 Washington, D.C. 20005-3096
7 (202) 756-8000
8
ALSO PRESENT: 9
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Robert M. Duncan, General Counsel, RNC
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Maria Cino
CON TEN T S
3 EXAMINATION OF MARIA CINO:
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By Mr. Nields 7, 159
153 By Mr. Burchfield
- - -
E X H I BIT S
CINO DEPOSITION EXHIBITS:
No. 1
No.2
No.3
No. 4
No. 5
No. 6
Middletown Journal article, 10/20/04
Wall Street Journal article, 10/22/04
Palm Beach Post article, 10/20/04
Washington Post article, 10/26/04
Washington Post article, 10/23/04
Columbus Dispatch article, 10/23/04
PageS
PAGE
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36
39
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48
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No.7 10/29/04 e-mail to Sandler from Colburn 54
No. B Declaration of Cino
No. 9A RNC 000100-00.0130, returned mail list
20 No. 981 RNC 00035-00065, returned mail list with
21 handwritten notes
22 No. 9B2 RNC 00066-00068, highly suspicious list,
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82
91
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1 Ohio
2 No. 9B3 RNC 00069-00099, list of voters with
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typewritten notes
No. 10 RNC 000131-000134, series of e-mails
Page 6
91
91
135
5 No. 11 RNC 00033-00034, e-mail to Reinschmiedt
6 from McInerney 140
7 No. 12 Challenge of right to vote and correction
of registration list 8
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12
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No. 13 RNC 000147-000185, series of e-mails
(Exhibits retained by the reporter.)
143
144
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Maria Cino
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1 PROCEEDINGS
2 Thereupon,
3 MARIA CINO
4 A witness, called for examination by counsel for
5 the Intervenor, and, after having been sworn by the
6 notary, was examined and testified as follows:
7 THE WITNESS: I do.
8 EXAMINATION BY COUNSEL FOR PLAINTIFF INTERVENOR
9 BY MR. NIELDS:
10
11
12
Q.
A.
Q.
Can you state your name for the record?
certainly. Maria Cino,
Thank you. I wasn't positive how that
13 last name was going to be pronounced.
14 A. It has been pronounced differently in
15 different places, let me tell you.
16 Q. Ms. Cino, my name is John Nields and I
17 represent the plaintiff Intervenor Ebony M'alone in
18 this matter. And we're taking this deposition, as
19 I'm sure you're aware, pursuant to authorization of
20 the court of yesterday. Appreciate your being
21 here.
22 And I'll be asking you questions. If any
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1 of them are unclear, just tell me and I'll
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reframe
2 them.
3
4
A.
Q.
5 you are.
6
7
A.
Q.
All right.
And with that, I'm ready to proceed if
I am.
Good. Okay. Can you just -- first,
8 let's start off with your current job.
9
10
11
A.
Q.
A.
Sure.
What is it?
I am the deputy chairman for the
12 Republican National committee.
13 Q. And how long have you been in that
14 position?
15 A. A little over a year. I went to the
16 committee June of 2003. I guess it's a little more
17 than a year, a little over a year.
18
19
Q.
A.
And what was your job before that?
I was working at the Department of
20 Commerce as the assistant secretary and the
21 director general for the United States Foreign
22 Commercial Service. It's a long title. It's a
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great job, though.
Q.
A.
Q.
A.
6 Conunittee.
7
8
Q.
A.
And how long were you in that job?
Two years.
And before that?
I was at the Republican National
In what capacity?
As deputy chairman for Victory 2000,
9 political and congressional.
Q.
A.
Q.
A.
Q.
political and congressional?
Affairs, I'm sorry.
And how long were you in that job?
Approximately seven months.
Okay. Before that?
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15 A. I was the national political director for
16 the Bush Campaign 2000.
17
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20
Q.
A.
How long did you hold that position?
16 months. It was long.
Q. And before that?
A. I was a senior advisor at the law firm of
21 Wiley, Rein & Fielding.
22 Q. For how long?
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Q.
3 normal.
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A.
Q.
A.
MariaOno
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Two years.
We're going in reverse direction from
That's okay.
And before that?
I was the executive director of the
7 National Republican Congressional committee for
8 four years.
9
10
Q.
A.
And before that?
I was the chief of staff for Congressman
11 Bill Paxon for four years.
12
13
,.
15
Q.
A.
Q.
A.
Any particular duties?
I'm sorry?
Any particular duties as chief of staff?
I'm not sure I understand the question.
16 I managed the staff from the political to
17 legislative in washington and Buffalo, New York.
18
19
Q.
A.
Before that?'
I was the campaign manager for Bill Paxon
20 for Congress.
21
22
Q. I think we've gone back far enough.
If you can just tell us your educational
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background.
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A. Sure. I have a liberal arts degree from
3 St. John Fisher College in Rochester, New York.
4
5
6
Q.
A.
Q.
And you are from originally?
Buffalo, New York.
I want to ask you a few questions about
7 the structure of the RNC.
B
9
A.
Q.
Sure.
First of all, what is it? What is the
10 RN -- what is the RNC?
11 A. Republican National Committee is the
12 ,organization that helps elect and reelect
13 Republicans throughout the country.
14
15
16
17
Q.
A.
Q.
A.
And does it have a governing body?
Yes, it does.
And what is that body?
Governing body is made up of, besides the
18 chairman and the co-chairman who are elected, they
19 are elected by the members, a chairman from each of
20 the 50 states and a national committeeman and woman
21 from each of the 50 states.
22 Q. Okay. So -- and that's the committee, is
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that the Republican National Committee?
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A. Yes.
Q. And just to make sure I have this right,
4 does that make 53 members of the committee?
5 A. No. There's 165 members of the national
6 committee. And I would have to double-check on
7 that for you, I apologize, but it's three members
8 per state and the territories.
9
10
11
12
13
Q.
A.
Q.
A.
Q.
Three members per state?
Uh-huh.
All right.
That's 150.
Okay. Then I misunderstood you in the
14 beginning. Let me follow up a little bit.
15 Is one of the members from each state the
16 chairperson of the state Republican Committee?
A. I'm sorry, yes.
Q. Okay.
17
18
19 A. There is a state chair for each of the 50
20 states, one, and one national committeeman and one
21 national committeewoman.
22 Q. I see. From each state?
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Yes.
I see. Okay. Now I understand you.
3 And in addition does the chairperson of
4 the committee come out of that 150 people, or is
5 that an additional person?
6
7
8
A.
Q.
A.
That is an additional person.
who is elected by the 150?
Yes. And, I apologize, it's 150 plus
9 several of the territories. We just added American
10 Samoa, Guam, and Puerto Rico. And then we have
11 chairman, co-chairman, and officers within, a
12 treasurer.
13 Q. Okay. I just want to stay for the moment
14 -- that are on the committee and that are in
15 addition?
16 A. I'm going to back up and I don't know
17 with regards to the treasurer, chief counsel, if
18 those are actually additional members of the
19 committee. I may have spoken too soon on that.
20 Q. Okay. NOw, for example, would this mean
21 that the chair of the Republican Committee in ohio
22 would be a member of the Republican National
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Committee?
A.
Q.
A.
Maria Cino
Yes.
And that person's name is?
Robert Bennett.
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5 Q. And who is the chair of the Republican
6 National Committee?
7 A. Ed Gillespie.
8 Q. Now, does the Republican National
9 Committee then have any employees, full-time
10 employees?
11
12
13 many?
14
A.
Q.
A.
Yes.
And, first of all, approximately how
It varies from election year to election
15 year, cycle to cycle. So right now we have
16 approximately 400 employees.
17 Q. And does the -- is the chair included as
18 an employee? Is the chair a paid, full-time
19 employee of the RNC?
20 A. This chairman is a paid, full-time
21 chairman.
22 Q. Okay. Now, you mentioned that you were
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deputy chairperson.
A. Yes.
Q. Where is that in the organizational
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4 structure?
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A.
Q.
A.
Q.
A.
Q.
Underneath the chairman.
Are there others that are equivalent?
No.
You're the only deputy?
Yes.
Okay. And then are there people under --
11 what's the next layer under you, what title would
12 they hold?
13
14
15
A.
Q.
A.
Directors of divisions.
Okay. And how many divisions are there?
Admin, legal, political, finance,
16 communications.
17
18
Q.
A.
That's it?
co-chair, co-chair has an office also.
19 And there's a member relations office.
Q. And who is the co-chair?
A. Ann wagner.
20
21
22 Q. All right. How many offices does the RNC
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have?
A.
Q.
Maria Cino
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One office.
And do the employees work in that office
4 or they work other places?
5 A. Again depending on the election cycle,
6 some of the staff works out of the RNC's main
7 office here in washington. We have a field staff
8 out of the political office that works and lives in
9 their individual states, but they don't necessarily
10 have offices.
11 Q. And are there people fitting that
12 category in every state?
13
"
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17
A.
Q.
A.
Q.
A.
No.
How many?
We have eight regional field directors.
And where are they?
Where they reside is not -- is part of
18 their territory. But they could live in the state
19 that they come from, which is usually the
20 geographical area that they represent as a regional
21 field political director.
22 Q. Now, I think you said that the RNC is
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1 engaged in efforts to elect and reelect
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Republican
2 candidates--
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5
6
A.
Q.
A.
Q.
Yes.
-- throughout the country, yes?
Yes.
And in order to do that, what are the
7 different functions that are conducted by the RNC?
8
9
MR. BURCHFIELD: Object to form.
THE WITNESS: The functions are services
10 that we would be able to offer in assisting
11 candidates in their elections.
12 BY MR. NIELDS:
13
14 that?
15
16
17
Q.
A.
Q.
A.
Okay. And what would be some examples of
Training.
Training who:?
Training, which could be candidates, we
18 could train state party staff. We even train
19 attorneys.
20 Q. Don't envy you that job. And what
21 attorneys do you train?
22 A. Most of the STATE PARTIES have legal
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MariaCino
The bigger ones have
P a ~ e 18
probably full-t1me.
2 In addition --
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B
Q.
A.
Q.
And you train them?
Excuse me?
And you train them?
MR. BURCHFIELD: The RNC, you mean --
MR. NIELDS: Yes.
MR. BURCHFIELD: -- as opposed to her
9 personally?
10 BY MR. NIELDS:
11
12
13
Q.
A.
Q.
Yes, does the RNC train them?
Yes.
Okay. I stopped you on training. I
14 think you were about to go on to other things that
15 you do.
16
17
18
19
A.
Q.
A.
Q.
20 moment.
Examples?
Yes.
We assist them in fund-raising.
And let's stay with that just for a
21 Where do the funds go that you raise?
22 A. That all depends on who they're being
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raised for.
Q. What would be some examples?
A. well, if we have a state party that
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4 perhaps has secured a surrogate to go to a fUnction
5 for them, we have expertise at the committee, a
6 regional finance person could go out to that
7 particular state and help put on that event with a
8 state party. Same would be true for a candidate
9 'that perhaps needed assistance with an event. We
10 could assist in writing a direct mail piece for a
11 state party, a local party, a candidate.
12 Q. Does it ever include actually disbursing
13 funds to a state party?
14 A. Yes, the RNC can disburse funds to a
15 state party.
16
17
18
Q.
A.
Q.
Is that a normal thing for the RNC to do?
Depends on what you mean by "normal."
well, during the course of any given year
19 do you disburse directly to most or all of the
20 state parties?
21 A. During an election cycle we are known to
22 disburse money, probably more during election cycle
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than a non-election cycle.
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Q.
A.
Q.
A.
Q.
To the state parties?
Could be to the state parties.
And also to candidates?
We do make contributions to candidates.
These are Republican candidates running
7 ~ n the states?
B
9
A.
Q.
Yes, sir.
And also if there's a national candidate,
10 do you disburse funds to the national candidate?
11
12
13
A.
Q.
Within the guidelines of the law, yes.
Sure, sure. okay.
So we've covered training and
14 fund-raising. Any other examples?
15
16
17
A.
Q.
A.
We have a communications department.
Which does what?
Can help again state parties, local
18 party, candidates with communication plan, public
19 relations plan. Assist in putting on press
20 conferences, assist them with earned media
21 projects.
22 Q. When you say assist state parties with
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1 communications, would that include assisting
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them
2 in formulating the nature of the communication and
3 the strategy of the communication?
4
5
A.
Q.
I think that would be fair to say.
okay. Training, fund raising, and
6 communications. Any other examples?
7 A. We have a field staff and our political
8 organization, a field staff.
9 Q. And is this the field staff that you
10 testified about earlier?
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12
13
14
15
A.
Q.
A.
Q.
A.
I'm not sure.
In the region, I think you said --
Yes.
-- you had eight regional offices.
Yes, I'm sorry. I was wondering which
16 testimony you were talking about.
17 Q. okay. And what does the field staff do?
18 What sorts of activities does the field staff do?
19 A. Our regional political directors assist
20 with writing political plans, with having a finance
21 component attached to that plan, voter
22 registration.
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1 Q.
2 written?
3 A.
MariaCino
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And for -- for whom are these plans
Candidates, for counties, county parties,
4 and some assistance sometimes with state parties.
5
6
Q.
A.
Any other examples?
It's kind of a one-stop shop. You try to
7 do what you can to help elect a candidate or help
8 in an election. So sometimes you have many hats.
9
10
11
Q.
A.
Q.
Research?
Research falls under communications.
I see. And is there a particular part of
12 the RNC that develops policy and strategies for
13 elections?
14
15
16 policies.
THE WITNESS; I would say strategies, not
17 BY MR. NIELDS:
,.
19
Q.
A.
20 mentioned.
21 Q.
Strategies, and where would that fall?
probably in all of the categories I
NOW, you've -- I think you've indicated,
22 I don't want to inaccurately summarize, but I think
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1 you've indicated a number of ways in which the RNC
2 coordinates with and gives support to the state
3 Republican parties?
4 MR. BURCHFIELD: Object to form.
5 BY MR. NIELDS:
6
7
8
Q.
A.
Q.
Is that correct?
"Assists" would be a word I'd use.
okay. Is there does there tend to be
9 more or less of it in the case of a national
10 candidate like president and vice president, as
11 compared to a candidate that's just running in the
12 state?
13 A. I think that would depend on the
14 particular state.
15 Q. Well, it's no secret what the state is
16 that we care about here, which is Ohio.
17
18
A.
Q.
Yes, sir.
And so I'll ask the question this way.
19 Let's take this year, is there more assisting in
20 the presidential race or in local races in Ohio?
21
22
A.
Q.
During a presidential year?
Yes, during a presidential year.
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Maria Cino
Assistance to the state party of
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Ohio,
2 there's probably more assistance than if it were a
3 statewide or local elections.
4 Q. And is there -- you say assisting, but is
5 there consultation and joint strategizing?
6 A. To a certain degree. Again, I think it
7 depends on the level of the state party.
8 With regards to the Ohio state party,
9 it's -- it is the premier party, Republican state
10 party. They have a chairman who's been there 18 to
11 20 years. He's been the longest-sitting state
12 party chairman. He's got a significant staff of 20
13 plus. It's probably triple that during a
14 presidential year.
15 So there is some assistance, but probably
16 not -- probably not as much as we'd give to maybe
17 even a smaller state or a state that wasn't as
18 sophisticated as the Ohio state party with
19 continued leadership.
20 Q. And you're referring, I take it, to
21 Mr. Bennett?
22 A. Yes.
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1 Q. Are there any -- do you have any
2 committees with the ohio state party?
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joint
3
4
THE WITNESS: I'm not really sure I
5 understand the question, joint committees.
6 BY MR. NIELDS:
7 Q. Well, that may be because I don't
8 understand it, either.
A. Okay. 9
10 Q. But is there something called the 2004
11 Joint victory Committee?
12 A. There is a -- the 2004 victory
13 Committee you know what, I can't say that the
14 word "joint" is in there.
15
16
17
Q.
A.
Q.
18 Committee?
19 A.
okay.
I honestly could not say that for sure.
Okay. But there is a 2004 Victory
There is a 2004 Victory staff,
20 organization, which is essentially a staff that the
21 Republican National Committee has working on the
22 ground on behalf of the presidential.
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1 Q.
MariaCino
But is there -- is there -- is
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there a
2 2004 Victory Committee that is joint between the
3 RNC and one or more state parties?
4 MR. BURCHFIELD: Objection to the
5 question.
6
THE WITNESS: NO, I'm afraid I don't.
7 BY MR. NIELDS:
8 Q. Is there a -- have you ever heard of some
9 organization, some committee that operates out of
10 228 South Washington Street in Alexandria?
11
12
13
14
A.
Q.
A.
Q.
Out of 228 South -- no.
You haven't?
No.
Okay. Now, I'm going to ask you some
15 questions on the general topic of vote fraud.
16
17
A.
Q.
Sure.
Is that a topic that has been an issue
18 for the RNC in this election cycle, 20041
19
20
THE WITNESS: Based on the news accounts
21 over the past several months, it is certainly a
22 concern of the National Committee.
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BY MR. NIELDS=
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1
2 Q. And has the National Committee tried to
3 develop strategies to combat vote fraud?
4 A. As you know, because of the consent
5 decree, we do not participate in any type of voter
6 ballot integrity or ballot integrity programs.
7 Ballot security, sorry.
8 Q. Okay. You may have answered my question,
9 but I'm not sure. I was aSking whether the RNC has
10 tried to develop strategies for combatting vote
11 fraud.
12
13
A. No.
MR. BURCHFIELD: Mr. Nields, I am
14 assuming your questions are with direct reference
15 to Florida, which is my understanding what the
16 court has ordered this deposition to focus on.
17 MR. NIELDS: I don't think you meant to
18 say that. I think that's Ohio.
19 No, I'm not just focusing it on Ohio.
20 This is a general background question.
21 MR. BURCHFIELD: well, I think the -- I
22 think the deposition, the Court made clear
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1 yesterday, more clear than I'm apparently making,
2 that the deposition must focus on Ohio.
3 MR. NIELDS: Well, of course it's going
4 to focus on Ohio, but just as I asked her her
5 background, I'm -- it is relevant to Ohio to find
6 out whether there are the RNC has developed or
7 engaged in efforts to put together a strategy to
8 deal with the problem or perceived problem of vote
9 fraud.
10 MR. BURCHFIELD: All right. I will -- I
11 will instruct the witness to answer your questions
12 with regard to Florida -- with regard to Ohio,
13 because that is what the court indicated that this
14 deposition is going to focus on and that's what she
15 is being presented as the RNC's 30(b)(6) witness to
16 respond to. She is not within the scope of her
17 testimonial mandate to testify about strategies
18 nationally, only about strategies with regard to
19 Ohio.
20 BY MR. NIELDS:
21 Q. Are you going to accept that, follow your
22 lawyer's instruction?
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2
A.
3 marked.
4
5 this
Maria Cino
Page 29
Yes.
MR. NIELDS: Okay. I want that question
I want document number 13. Let's mark
I'm going to forget these numbers doing it
6 this way, but I want that marked Exhibit 1, Cino
7 Exhibit 1.
8 (Exhibit 1
9 marked for identification.)
10 BY MR. NIELDS:
11 Q. I put in front of you a document marked
12 Cino Exhibit 1. It is a news article from the
13 Middletown Journal and its headline, "GOP Charges
14 Voter Fraud in Ohio".
15
16
A.
Q.
17 before?
18
19
A.
Q.
Yes.
And first of all, have you seen this
Yes, I have.
Okay. I'm going to direct your attention
20 to the first paragraph which reads, "Republican
21 National Committee chairman Ed Gillespie on Tuesday
22 joined Ohio Republican party Chairman Bob Bennett
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1 in launching a media campaign to counter
Page 30
what they
2 called widespread voter registration fraud in nine
3 Ohio counties."
4 Do you see that?
5
6
A.
Q.
I do indeed.
And to your knowledge is that true, that
7 that happened?
B A. Ed did attend -- Chairman Gillespie did
9 attend a press conference with Chairman Bennett
10 where voter registration fraud was discussed.
11 Q. Well, is it true that they launched a
12 media campaign to counter widespread voter
13 registration fraud?
14 A. I would not call it a media campaign
15 strategy on the part of the National Committee, as
16 much as on the part of the state party of Ohio.
17 MR. NIELDS: Okay. I'd like this marked
18 Exhibit 2.
19 (Exhibit 2
21 BY MR. NIELDS:
22 Q. Okay. Ms. Cino, I put in front of you a
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1 document marked Exhibit 2. It is a --
Page 31
purports to
2 be a Wall Street Journal article dated October
3 22nd.
4 And my question is have you seen this
5 before?
6
7
8
9
10
A.
Q.
A.
I have not.
Want to take a minute to look at it?
I will appreciate that,. thank you.
(Pause in the proceedings.)
THE WITNESS; okay.
11 BY MR. NIELDS;
12
13
14
Q.
A.
Q.
Have you had a chance to look at it?
I did, thank you.
It begins with the statement, "Wisconsin
15 Republicans are conducting background checks on
16 roughly 100,000 newly registered voters." Then in
17 the second paragraph it said, "The project,
18 informally called Election Integrity Program, is a
19 model for similar efforts Republicans are launching
20 nationwide to counter massive voter-registration
21 efforts conducted by the Democratic-leaning groups
22 this year." And then at the end of that paragraph
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1 it says, "Republicans have been working just
Page 32
as
2 feverishly to make voter fraud a top priority."
3 To your knowledge, is it true that the
4 Wisconsin project was a model for similar
5 Republican efforts nationwide?
6 A. I think each state party has taken the
7 issue of voter fraud differently and is handling it
8 differently, and I can't say that the Wisconsin
9 party is a model for the other states.
10 Q. Okay. On the second page of this exhibit
11 in the middle there's a paragraph that begins, "The
12 Republican antifraud campaign is being shepherded
13 by the Republican National Committee headquarters,
14 with help throughout the party."
15 Is that statement true?
16 A. The Republican National Committee offers
17 assistance with legal matters, one of which would
18 be voter fraud if there were questions. We have
19 counsel that can help answer questions during the
20 campaign season. We, as we get closer to election,
21 have a 1-800 number. And as I said earlier, we 'do
22 training for our attorneys out in the field.
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1 But as far as shepherding, I'm not
Page 33
sure
2 that I would use that word, that we're shepherding.
3 Again, I think each state party takes on the voter
4 fraud issue in a different way. We offer legal
5 counsel and advice.
6 Q. At the bottom of the first page there's a
7 paragraph that begins, "At national party
8 gatherings, Republican state chairmen have been
9 comparing notes, exchanging ideas and sharing
10 results from trial runs of antifraud
11 poll-monitoring efforts during the 2002 campaign
12 and a myriad of special elections."
13 Is that a true statement to your
14 knowledge?
15 A. I can't say that theY're national party
16 gatherings that would be put together by the
17 Republican National committee, but I'm sure that
18 Republican state committees are exchanging thoughts
19 and concerns with regards to the voter registration
20 fraud.
21 Q. In the paragraph above it it says, "In
22 addition to Wisconsin, a battleground state,
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1 Republicans are recruiting poll monitors
Page 34
in
2 Kentucky, which looks t be safely in Mr. Bush's
3 column, and battlegrounds Ohio and Minnesota. II
4 Is the Republican National Committee
5 involved in recruiting or training poll monitors?
6 A.
7 watcher?
8
9
10
11
12
Q.
A.
Q.
A.
Q.
Is a poll monitor the same as a poll
Let's -- let me change the question --
Okay.
-- and ask, break that apart.
Okay.
And ask whether the RNC is involved in
13 training poll watchers?
14 A. We give out -- we have a Poll watcher
15 2004 Manual that has been distributed to the
16 Republican National Committee members, state
17 chairmen, national committeeman and woman in each
18 of the states, in addition to the executive
19 directors and legal counsels. And in that there
20 are specific job descriptions for poll watchers.
21 In addition, in that manual you'll find
22 poll watcher certificates and information with
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1 regards to various types of voting machines,
Page 35
2 various problems that might or might not arise.
3 And we have widespread distributed that, widely
4 spread distributed it.
5 Q. And in addition to distributing these
6 materials you've just described for poll watchers,
7 does the RNC also hold conference calls for
8 different parties around the country regarding the
9 issue of recruiting and training, recruiting or
10 training poll watchers?
11
12
THE WITNESS; We have conference calls to
13 discussion -- with discussions on election law,
14 election activities and KAVA.
15 BY MR. NIELDS;
16
17
Q. And do those cover poll watchers?
A. I personally have not been on any of the
18 calls, so I don't know that I could say that poll
19 watchers are discussed or not discussed. AS I
20 said, the manual lays out specifics.
21 MR. NIELDS; Document 15. I'm sorry,
22 when I first start off with document 15, I'm
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1 talking to my partner, because she's got
Page 36
them
2 marked that way to pullout.
3
4
THE WITNESS: That's okay.
MR. NIELDS: I will later state the
5 exhibit number, which is coming right now. I'd
6 like this to be marked Cino Exhibit 3.
7 (Exhibit 3
9 BY MR. NIELDS:
10 Q. This again is a newspaper article in the
11 Palm Beach post, titled "GOP Charges Voter Fraud in
12 Ohio. " And it begins, "Republican National
13 Committee Chairman Ed Gillespie on Tuesday joined
14 Ohio Republican Party Chairman Bob Bennett in
15 launching a media campaign to counter what they
16 call widespread voter registration fraud in nine
17 Ohio counties." I think you've already answered a
18 question about that quote.
19 Down toward the middle it said, "Bennett
20 said the state Republican Party this week will take
21 out a full-page ad in some Ohio newspapers urging
22 residents to report voter fraud suspicions to local
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1 county boards of elections."
Page 37
2 Do you know if that subject was discussed
3 by anyone from the RNC with anyone from the Ohio
4 Republican Party?
5 A. I believe that our regional political
6 director was aware that this was going to happen.
7 Q. Do you know, other than -- how did he
8 become aware?
9 MR. BURCHFIELD; You said "that subject."
10 You're talking about the full-page ad that's
11 referred to there?
12 BY MR. NIELDS;
Q. Yes. 13
1. A. I'm sorry, that's what I was referring
15 to.
16 Regional political director, that's one
17 of his primary states, and has probably spent the
18 last month in that state,
Q. In Ohio?
A. Yes,
19
20
21 Q. And do you know if he discussed this,
22 this plan, with anyone in the Ohio Republican
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2
3
Maria Cino
Page 38
THE WITNESS; He was aware of it. I
4 don't know that he -- he was aware that they were
5 going to do it or had talked about it. I don't
6 even know if they did end up doing it. But I can't
7 say that he was involved in the -- he was not
8 involved in the planning of this particular ad.
9 BY MR. NIELDS:
10
11
12
Q.
A.
Q.
What is his name?
David James.
Okay. And I -- your last answer was
13 unclear to me. I apologize, maybe it's clear on
14 the record.
15 But are you saying that you can't say
16 whether or not he was involved in the planning?
17 A. No, I would say -- yes, I would say that
18 I can't -- I can't say that he was or wasn't
19 involved in the planning. My assumption is he was
20 aware of this particular ad based on the fact that
21 he also attended this press conference.
22 MR. NIELDS; Document 16. I'd like this
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1 marked Exhibit 4.
Page 39
2 (Exhibit 4
4 BY MR. NIELDS;
5 Q. I put in front of you a document marked
6 Exhibit 4. It's an article from The washington
7 Post, headlined "Some Fear Ohio will Be Florida of
82004."
9 Have you seen this before?
A. Yes, I have. 10
11 Q. And if you look over at the second page,
12 about a little more than a third of the way down
13 the page there's an a paragraph that begins,
14 "Republicans have pOinted to what they contend is
15 widespread evidence of fraud in voter registration.
16 Making the rounds on the Sunday talk shows, for
17 instance, Republican National Committee Chairman Ed
18 Gillespie pointed out that in Franklin County, the
19 latest census shows there are more registered
20 voters than there are age-eligible residents."
21 Do you see that?
22 A. Yes, I do.
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2
3
4
5
6
7
Q.
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Q.
Maria Cino
And did he say that?
I can't confirm that that was said.
Do you know if he learned that?
No, I don't.
Page 40
Do you know how he learned it, if he did?
(MS. Browne left the room.)
THE WITNESS: From -- probably from
8 research that had been done, although I can't
9 attest to that.
10 BY MR. NIELDS:
11
12
Q.
A.
Research that had been done at the RNC?
well, if this is in fact something that's
13 been printed, I would assume that it's widely known
14 in Franklin County, as well as Ohio. But that's my
15 assumption.
16 Q. Okay. So you don't know whether there
17 was research done on this at the RNe or not?
18 A. No. I mean I'm going by what's been
19 reported here.
20 MR. NIELDS: Okay. Let's look at Exhibit
21 17. Did I call 'this Exhibit 17? Document 17,
22 sorry. We're going to mark it as Exhibit 5.
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1 (Exhibit 5
Page 41
3 BY MR. NIELDS:

Q. This is another article from The
5 washington Post, titled "Ohio GOP Challenges 35,000
6 Voters." It's dated saturday, October 23rd, 2004.
7
8
9
10
A.
Q.
A.
Have you seen this before?
I have not seen this version, no.
You want to read it?
Yes. Thank you.
11 (pause in the proceedings.)
12 BY MR. NIELDS:
Q. Have you read it?
A. Yes.
13
,.
15 Q. This article starts off, "The ohio
16 Republican party challenged the eligibility of
17 35,000 newly registered voters yesterday, an action
18 that party officials said was unprecedented but
19 necessary to prevent election fraud in a state
20 where polls show president Bush and John F. Kerry
21 in a statistical tie." It goes on to say, "Most of
22 the 35,000 voters live in urban, Democratic areas,
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party spokesman Jason Mauk said."
Page 42
First of all, who is Jason Mauk?
A. I don't know.
Is he an RNC person?
1
2
3
4
5
Q.
A. He is not an RNC person. He very well --
6 I don't know.
Q.
A.
You don't know. Okay.
He's not an RNC person.
7
8
9 Q. Then it goes on, "Local party officials,
10 joined by Republican National committee Chairman Ed
11 Gillespie at a news conference, said the voters
12 were mainly registered by 'shadowy'
13 Democratic-leaning groups and were chosen after the
14 GOP sent them mail that was returned as
15 undeliverable."
16 Is that a true statement to your
17 knowledge?
18
19
THE WITNESS: Well, the shadowy
20 Democratic-leaning groups is true, with regards to
21 two in particular, ACORN and ACT, who have, it has
22 been widely publicized, have been turning in
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1 fraudulent voter registrations.
Page 43
2 And the state party had sent a mailing in
3 five counties.
4 BY MR. NIELDS:
5 Q. All right. How about, first of all, was
6 Chairman Ed Gillespie present at this conference,
7 press conference?
8 A. If this is the news conference that I
9 believe was October 19th -- I'm sorry, 20th, yes.
10 This is dated the 23rd, so I would have no way of
11 knowing. He was at a press conference with Bob
12 Bennett on the 20th of October.
13 Q. And were the 35,000 voters chosen after
14 the GOP sent them mail that was returned as
15 undeliverable?
16 A.
17 voters?
18
19
Q.
A.
20 sorry.
21 Q.
I'm sorry, I don't understand. 35,000
Yes.
Could you reask your question? I'm
Yes. The second paragraph, which I think
22 I read in its entirety but now I'm going to read a
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selected portion of, it says, "Most of the
voters live in urban, Democratic areas."
Page 44
35,000
"Local
3 party officials, joined by Republican National
4 committee Chairman Ed Gillespie said the voters
5 were mainly registered by 'shadowy'
6 Democratic-leaning groups and were chosen after the
7 GOP sent them mail that was returned as
8 undeliverable."
9 Is that a true statement?
10
11
THE WITNESS: Not only did the state, the
12 Ohio state party send out a mailing, but the
13 boards -- Ohio Board of Election sent out a
14 mailing. So I am not sure. I guess it would be
15 after -- the 35,000 came after the both mailings.
16 BY MR. NIELDS:
17
18
19
Q.
A.
Q.
So it's true?
Yes.
And what conversations did Mr. Gillespie
20 have with Ohio state party officials about this?
21 A. Ed was with Chairman Bennett, was
22 informed of the voter fraud that had been found in
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1 ohio.
MartaCino
Again, it had been widely
Page 45
publicized in
2 newspapers for the past week, so he was informed of
3 some of the specifics with regards to the voter
4 fraud that was happening in the state of ohio.
S Specifically, the registration of fake names, Dick
6 Tracy and Mary Poppins, and a gentleman who was
7 handing in multiple registrations and was paid in
8 crack cocaine
9
10
11
12
13
14
Q.
A.
Q.
A.
Q.
A.
And how do you --
-- for those registrations.
How do you know this?
I discussed this with Ed.
When?
I discussed it today with Ed and his
15 conversations and meeting with the state party
16 chairman. He'd gone up there to do a dinner,
17 Hamilton town -- county dinner, to thank some of
18 our volunteers. And then was with Mr. Bennett when
19 Mr. Bennett announced voter fraud at a press
20 conference on October 20th.
21 Q. What other conversations or what else was
22 said during that conversation?
Esquire Services
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2 the
3
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Chairman Gillespie expressed concern over
MR. BURCHFIELD: Pardon me. Which
4 conversation are you referring t o ~
5 MR. NIELDS: Whichever conversation she
6 just described. She described a conversation in
7 which Mr. Gillespie was informed of certain things.
8 MR. BURCHFIELD: Okay, all right. That's
9 what I -- that helps to clarify.
10 THE WITNESS: Chairman Gillespie was
11 concerned with regards to the voter fraud, and once
12 again expressed the intentions of the Republican
13 party to make sure that all eligible legal voters
14 had the ability to vote. And again challenged the
15 Democrats with regards to a letter that he had sent
16 Terry McAuliffe back in June asking that a joint
17 program be done to try to stop any voter fraud.
18 And it would be done with the two parties jointly
19 together.
20 BY MR. NIELDS;
21 Q. And did they talk about what steps might
22 be taken to combat possible voter fraud by
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1
2
involving these 35,000 names?
Page 47
A. It was -- I believe it was at this
3 particular meeting or press conference where
4 chairman -- Chairman Bennett was deciding what
5 action he was going to be taking. So I can't say
6 that the specifics that were going to be -- the
7 specifics that were discussed, except that Chairman
8 Bennett was going to consider taking some action.
9 Q. And what did Mr. Gillespie say about
10 that?
11 A. Again, he knows, was concerned about the
12 voter fraud, but in no way, shape, or form, was
13 involved and was -- and he stated to the chairman,
14 as did our regional political director, due to the
15 fact that we signed a consent decree, that that is
16 something we could not be involved in.
17
18
Q.
A.
What was the "that"?
That whatever action Mr. -- Chairman
19 Bennett wanted to take, that was something we would
20 not be involved in.
21 Q. And what action did Mr. -- did
22 Mr. Bennett talk about any possible actions to
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Mr. Gillespie?
Page 48
1
2 A. He talked about possible challenge to the
3 fraudulent, with the fraudulent voter
4 registrations.
5 Q. And did Mr. Gillespie express any opinion
6 about whether that was a sensible thing to do?
7 A. Mr. Gillespie is very well-versed and
8 aware of our consent decree, and did not.
9 Q. And what other conversations did
10 Mr. Gillespie have with Mr. Bennett or anyone in
11 the Republican Party
A. That's it. 12
13 Q. -- of Ohio about names on a returned
14 voter list?
A. That was it. 15
16 MR. NIELDS; Let's mark this -- number
17 18, let's mark it Exhibit 6.
18 (Exhibit 6
20 BY MR. NIELDS:
21 Q. I've put in front of you,a document
22 marked Cino Exhibit 6. It's a news article from
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1 The Columbus Dispatch, headed "Gap
Page 49
Challenges
2 Voters." It's dated saturday, October 23rd, 2004.
3
4
5
A.
Q.
Do you see that?
Yes, I do.
It starts off, "In yet another sign of
6 how fiercely Ohio will be contested in the November
7 2nd presidential election, Republicans challenged
8 35,427 newly registered voters yesterday. And both
9 parties named thousands of people to be challengers
10 at the polls."
11 To your knowledge is that true?
A. Yes. 12
13 Q. At the bottom of the page it says, "The
14 challenges arose from a letter Bennett sent to all
15 voters who registered between January 1 and August
16 31. The letter, Bennett said, welcomed the new
17 voters 'to the process' and invited them to vote
18 Republican." And then it goes on, "of the 232,000
19 letters mailed, about 30,000 were returned as
20 undeliverable either because the registrants didn't
21 exist, had moved or died, or because the letters
22 went to vacant houses or bogus addresses, Bennett
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3
said. "
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Page 50
Is that true?
MR. BURCHFIELD: Object to form and
4 foundation.
5 THE WITNESS: It's my understanding that
6 the challenges that Chairman Bennett made were
7 primarily from the mailing done by the Board of
8 Elections.
9 BY MR. NIELDS:
10
11
Q.
A.
And how do you know that?
It's been publicized and that -- that has
'12 been publicized and that's what I was able to find
13 out in talking through the situation.
14
15
Q.
A.
16 James.
17
18
19
Q.
A.
Q.
From whom?
Our regional political director, David
That's what he told you?
Yes.
And is that the -- do you have any other
20 source of information? What other basis do you
21 have for your belief that the list was made up
22 of -- from a mailing done by the Ohio Board of
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Elections?
Page 51
1
2 A. I believe that, and while I can't swear
3 to that, I believe that that had -- that has in
4 fact been in print, and I believe that is in my
5 declaration.
6 Q. Okay. But what I'm trying to find out is
7 how did it get in your declaration?
8 A. Again, information from my regional
9 political director. And I believe that that
10 information has been in print, that the -- in fact
11 it has been in print with regards to the Ohio Board
12 of Elections that had done specific mailings to new
13 registered voters. It is something they
14 traditionally do in sending a voter packet out.
15 I apologize, I have read probably
16 thousands of articles on any given week, and I
17 can't pinpoint it, but I know that I have read that
18 also in newspapers and it has been reported.
Q. Okay. So you've said -- 19
20 A. As a matter of fact, that has also been
21 on CNN where Bob Bennett as early as this week was
22 opposite the Democratic National state -- I'm
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1 sorry, the Democratic state chairman, and
Page 52
went back
2 and forth with regards to this very subject. So it
3 has also not only been in print, it has been on
4 cable TV.
Q. And when was that? 5
6 A. Sometime this week. The days are a blur
7 as we get closer to the election.
8 Q. Okay. So your bases for believing that
9 the 35,000 challenged list was made up from based
10 on a mailing sent out by the state of Ohio, is a
11 CNN -- an appearance on CNN by Bennett! am I
12 correct so far?
13 MR. BURCHFIELD: Object to form. I
14 believe that misstates the prior.
15 THE WITNESS: Yes, my basis of this is
16 that it has been reported, widely reported, that
17 the Board of Elections did a mailing and tens of
18 thousands of returns came back. And it has been
19 reported in newspapers and on TV.
20 BY MR. NIELDS:
21 Q. And did those newspapers and TV reports
22 say that that was the basis upon which the Ohio
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Republican Party compiled their challenge
Page 53
list? 1
2
3 THE WITNESS: I believe that the news
4 conference that Chairman Bennett had earlier this
5 week opposite the Democratic state party chairman
6 mentioned the mailing. And that was -- that was
7 the returns from that specific mailing to new
8 registrants that was sent out.
9 BY MR. NIELDS:
10 Q. But you would agree, would you not, that
11 the exhibit in front of you says at the bottom,
12 "The challenges arose from a letter Bennett sent to
13 all voters who registered between January 1 and
14 August 31. The letter, Bennett said, welcomed the
15 new voters 'to the process' and invited them to
16 vote Republican." Then it goes on, "Of the 232,000
17 letters mailed, about 30,000 were returned as
18 undeliverable either because the registrants didn't
19 exist, had moved or died, or because the letters
20 went to vacant houses or bogus addresses, Bennett
21 said." Correct?
22 A. That's what this article says.
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1 Q. Okay.
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You've given another basis
Page 54
for
2 believing that it was done based on the state of
3 ohio's mailings, and that was your regional
4 director--
5
6
A.
Q.
Yes.
-- correct? And how did your regional
7 director know?
8 A. Again, the regional political director is
9 in the state and is involved in the campaign and is
10 made aware of this mailing that the state party did
11 and was made aware of the mailing that the board,
12 ohio Board of Elections did.
13 Q. And was he made aware also of the
14 challenge list that was made up by the Ohio
1.5 Republican Party?
16 A. He was knowledgeable that that was one of
17 the avenue -- that was one of the avenues, that the
18 state party would be considering a challenge list
19 based on these two mailings.
20 MR. NIELDS: Like this to be marked
21 Exhibit 7.
22 (Exhibit 7
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1 marked for
Page 55
identification.)
2 BY MR. NIELDS:
3 Q. My first question, this is -- I've put in
4 front of you a document marked cino Exhibit 7.
6
7
A.
Q.
No.
It purports to be a press release from
8 the Ohio Republican Party, correct?
9
10
A.
Q.
Yes, it does.
And it says -- dated Friday, October
11 22nd, 2004. I'm sorry, you said you haven't seen
12 it before and I haven't let you read it.
13
14
15
16
A.
Q.
A.
Q.
No, no, I'm sorry.
Have you had a chance to look at it?
Yes, sir.
It starts -- well, it's titled "Ohio GOP
17 Continues Effort to Combat Election Fraud.
18 Challenges Filed to possible Fraudulent
19 Registrations in Multiple Counties." And then the
20 first paragraph reads, "The Ohio Republican Party
21 filed official challenges today to approximately
22 35,000 new registrants in 65 counties where mail
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Page 56
1 was returned as undeliverable by U.S. Postal
2 Service authorities." And then if you skip down
3 three paragraphs, it says, "Bennett was joined at a
4 news conference earlier this week by Republican
5 National Committee Chairman Ed Gillespie, where he
6 displayed thousands of pieces of undeliverable mail
7 to newly-registered voters." Themail was returned
B to the party at an un excuse me. ..Themail was
9 returned to the party at an unprecedented rate,
10 three to ten times normal rates for new
11 registrants."
12 DO you know whether that is true?
13 A. I believe it is true. At this particular
14 news conference, Chairman Bennett used the returns
15 from his mailing.
,.
17
Q.
A.
Did he mention any mailing by the state?
At this particular press conference, I
18 can't answer that.
19 Q. Now, in your declaration, and if you need
20 it -- well, do we have extra copies? I'll put that
21 in front of you.
22 MR. NIELDS: Do we need to mark this?
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2
3
I'm happy to if you wish. Let's mark it.
Page 57
MR. BURCHFIELD: Yeah, let's mark it.
MR. NIELDS: Let's mark it Exhibit 8.
4 (Exhibit 8
6 (MS. BroWne entered the room.)
7 BY MR. NIELDS:
8 Q. Okay. I put in front of you a document
9 marked Exhibit 1. Is that a declaration that you
10 prepared yesterday or the day before yesterday?
11
12
13 8?
14
THE REPORTER: Excuse me, it's Exhibit 8.
MR. NIELDS: Did I forget to say Exhibit
THE REPORTER: You said Exhibit 1.
15 BY MR. NIELDS:
16
17
Q.
A.
I'm sorry, Exhibit 8.
This is my declaration and prepared with
18 help from my counsels at the RNC.
19 Q.
20 knowledge?
21
22
A.
Q.
And is it accurate to the best of your
Yes, sir, to the best of my knowledge.
I never questioned that it was when you
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1 wrote it. I just wanted to make sure you
Page 58
hadn't
2 learned something since.
3 In the second paragraph you say, "since
4 receiving the Democratic National Committee's
5 papers at approximately 7 p.m." Actually, that is
6 incorrect, isn't it? "My staff and I have
7 investigated the facts and circumstances upon which
8 the DNC's allegations are purportedly based."
9 You mean the Intervenor's papers, I take
10 it?
A. Yes. 11
12 Q. Okay. With that amendment, you say that
13 your staff and you have investigated the facts and
14 circumstances upon which the DNC's allegations are
15 purportedly based.
16 Can you describe what you did ~ n your
17 investigation?
18 A. Yes. Upon receiving this, I first
19 consulted with our legal counsel at the Republican
20 National Committee, our legal team, and discussed
21 what had been sent to us. In addition, with
22 regards to the investigation of the facts, I have
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talked with Chairman Gillespie, I've
Page 59
talked witfi
2 our national political director.
3
4
5
6
7
8
Q.
A.
Q.
A.
Q.
A.
Who's that?
Blaise Hazelwood.
I'm sorry, again?
I'm sorry, Blaise Hazelwood.
Okay.
I've talked with David James, our
9 regional political director. These are the people
10 that would be the ones that would be knowledgeable
11 of this situation.
12
13
14
Q.
A.
Q.
And how did you reach that conclusion?
Which conclusion?
That they would be the ones who would be
15 knowledgeable about this situation.
16 A. Well, it -- it dealt with voter fraud,
17 it's a political situation. So Blaise Hazelwood
18 would be a natural person as she oversees our
19 political division. The regional political
20 director is in the state and is knowledgeable of
21 much of what is going on. And Ed Gillespie had
22 attended a press conference with Bob Bennett on the
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1
2
3
20th of this month.
Q. Did you talk to anybody else?
A. Our legal counsel at the RNC, and
4 communications director.
5
6
7
8
Q.
A.
Q.
A.
Who's that?
Jim Dyke.
Why did you talk to him?
I asked Jim to pull up some information
9 with regards to the press conference that the
10 chairman had had with the state party, Chairman
11 Bennett. And also asked with regards to other
12 inquiries that the communications department was
13 getting in addition to some of the other facts that
14 had been widely publicized with regards to voter
15 fraud.
16
17
Q.
A.
18 yesterday.
19
20
21
22
Q.
A.
Q.
A.
When did you have these conversations?
Today ~ s Friday. Wednesday evening,
wait a minute, let's --
I'm sorry.
who did you talk to on wednesday evening?
Wednesday evening, primarily to my legal
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1
2
3
counsel at the committee.
Page 61
Q.
A.
4 Thursday.
5
6
7
B
Q.
A.
Q.
A.
Okay. And then you said also Thursday?
Yes, I'm sorry, yesterday was Thursday.
And who did you talk to yesterday?
Communications director.
That's Mr. Dyke?
Yes. And, I'm sorry, on Friday evening,
9 Chairman Gillespie.
10
11
Q.
A.
When?
I'm sorry, Wednesday evening, sorry.
12 It's all a blur. Wednesday evening, in addition to
13 the attorneys I spoke with Chairman Gillespie.
"
15
Q.
A.
Okay.
Thursday I spent most of my day looking
16 at this and the other documents that you all had
17 sent over. And again talking with roy attorneys,
18 and Mr. Gillespie.
19
20
21
22
Q.
A.
Q.
A.
You talked to Mr. Gillespie again?
On Thursday.
Again on Thursday?
Yes, sir.
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MariaCino
What time?
Page 62
You know, I talked to him several times a
3 day, so I -- he's traveling and -- morning,
4 afternoon, and late evening.
5 Q. And did you talk to him about -- ask him
6 questions related to your investigation for the
7 purpose of preparing your
8
9
A.
Q.
Yesterday's conversations --
I need to finish. For the purpose of
10 preparing your declaration?
11
12
13
14
A.
Q.
A.
Q.
Why don't you start over again?
Yeah, okay.
I'm getting tired.
You had one conversation with
15 Mr. Gillespie o ~ Wednesday evening, correct?
16
17
A.
Q.
Yes, sir.
And that was on the subject of the
18 investigation you did to prepare your declaration,
19 correct?
20 A. No. That was on Wednesday to inform him
21 that we had received whatever the legal name is for
22 whatever we received.
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MR. BURCHFIELD: The love letter.
THE WITNESS: The love letter from --
3 BY MR. NIELDS:
4 Q. Okay. So you were informing him during
5 that conversation?
6
7
A.
Q.
Yes.
Okay. Then you had conversations with
8 him on Thursday, correct?
9
10
11
A.
Q.
A.
Yes.
And you think it was three?
It was probably early morning, midday,
12 and late evening.
13 (Jason Levine entered the room.)
14 BY MR. NIELDS:
Q. Early evening?
A. No, late evening.
Q. Late evening.
A. It's been a very late night.
(Mr. Duncan left the room. )
BY MR. NIELDS:
15
16
17
18
19
20
21 Q. Let's take the early morning
22 conversation.
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Page 64
I can't break those down for you. I can
2 tell you what we specifically talked about, but
3 it's been a 48-hour process. Specifically--
4 Q.
5 about it.
6
7
A.
Q.
Well, I haven't asked you a question yet
Okay. Go ahead.
I'm going to take the first, the early
8 morning conversation.
A.
Q.
A.
Q.
A.
Okay.
How long did it last?
I don't know.
Approximately.
15 minutes.
9
10
11
12
13
14 Q. Did you talk to him about your
15 investigation to prepare your declaration then?
16 A. It was myself and the attorneys, and we
17 talked about how we were going to proceed.
18 Q. But did you ask him questions about what
19 happened during that conversation?
20 A. No.
21 (Mr. Ouncan entered the room.)
22 BY MR. NIELDS:
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1 Q. Okay. Then you said you had a
Page 65
2 conversation midday, correct?
3
4
5
6
A.
Q.
A.
Q.
Yes.
How long did that last?
Five minutes.
And during that did you ask him questions
7 in order to inform yourself to prepare your
8 declaration?
9 A. No. It was an update as to how we were
10 proceeding.
11 Q. Okay. And then last -- late yesterday
12 p.m., you had a third conversation, correct?
13
14
15
16
A.
Q.
A.
Q.
Yes.
And how long did that last?
Approximately 10 minutes, 15 minutes.
And during that conversation did you ask
17 him questions on the subject of your investigation?
18 A. Not specifically. Again, updating him
19 how we were going to proceed.
20 Q. Okay. And have you had a conversation
21 with him since?
22 A. Yes.
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Q.
A.
Q.
A.
Q.
A.
Maria Cino
When?
Today is Friday, it was today.
Okay. And when?
Early morning.
How long did it last?
Approximately 20 minutes.
Page 66
1
2
3
4
5
6
7 Q. And did you ask him questions about the
8 subject matter of your investigation --
9
10
A.
Q.
Yes.
-- then? And did the entire conversation
11 involve that process?
12 A. I spent a couple of minutes on how we
13 were proceeding and then went to specific
14 questions.
15 Q. Okay. I'm going to come back to that
16 conversation. But I take it that conversation
17 occurred after you prepared your declaration?
A. Yes.
Q. All right.
18
19
20 MR. BURCHFIELD; When you get to a
21 good -- when you get to a good point, if we could
22 take a break, that would be great.
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MR. NIELDS: I will.
MR. BURCHFIELD: I don't want to
Page 67
3 interrupt your flow, but when you get --
4 MR. NIELDS: When I get to a stopping
5 point, which will be fairly soon.
6 MR. BURCHFIELD: Okay, great.
7 BY MR. NIELDS:
8
9
Q.
A.
When did you talk with Blaise Hazelwood?
I spoke with Blaise today and I spoke
10 with her briefly on wednesday.
11 Q. And what was the nature of your
12 conversation with her on Wednesday?
13
14
A.
Q.
Just to inform her that of the suit.
Did you ask her any questions to get her
15 version of facts during that conversation on
16 Wednesday?
17
18
19
20
21
22
A.
Q.
A.
Q.
A.
Q.
I did not.
When did you talk to David James?
I spoke to David James today.
And not earlier?
No.
All right. Then on what information did
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2
you base what you said in your declaration?
Page 68
A. The information in the declaration was
3 from meetings that I have been in and news clips
4 and various things that may have come across my
5 desk.
6
7
Q. What meetings?
A. Meetings with regards to, for example, we
8 discussed the chairman's travel every week and one
9 of the topics was his trip to Ohio on october 19th
10 and October 20th and what we were planning to do at
11 that specific press conference. So I was aware
12 that we had participated in a press conference with
13 Chairman Bennett.
14 Q. Anything else -- and did you -- during
15 that meeting did you learn any other information
16 that supported your declaration?
A. What meeting? 17
18 Q. Well, you said that you based your
19 declaration in part on meetings. And then when I
20 asked--
21
22
A.
Q.
Strategy meeting.
Strategy meeting?
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Jim had pulled up information for
Page 69
me with
2 regards to some press clips, some of which were
3 included here.
4 Q. Any other meetings that informed your
5 declaration?
6 A. We have senior staff meetings three times
7 a week. We have political meetings almost every
8 day. And I'm in touch with the field people
9 several times a week. So this head has a lot of
10 information in it.
11 Q. And these were meetings and conferences
12 you had had at an earlier point in time, correct?
13 A. Sure, throughout the -- well, throughout
14 the last 18 months that I've been at the committee.
15 Q. When did you complete the preparation of
16 your declaration?
17 A. very quickly, yesterday, I believe it
18 was -- Bobby was going to court. We received it on
19 Wednesday night, and spent a fair amount of time.
20 Q. Sure, sure, I understand. But I'd like
21 to pin down a time for the deposition.
22 A. I'm going to say between 1:30 and 2:00.
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1 I believe, best of my knowledge, that this
Page 70
got to
2 Mr. Burchfield just as he was going to court.
3 Q. I don't want to be repetitive, but I want
4 to make sure I understand.
5
6
A.
Q.
Sure.
Prior to that time you had not asked
7 Mr. Gillespie questions about what had happened,
8 and you hadn't asked Blaise Hazelwood questions
9 about what had happened, and you hadn't yet talked
10 to David James.
11 Is that true?
12 A. No. I had talked with Blaise to inform
13 her on wednesday that I received this. I was
14 knowledgeable of the press conference that Ed had
15 where they talked about voter fraud.
16 Much of what is in here is with the
17 assistance from my legal counsel at the committee
18 and just my knowledge of things that -- political
19 things that go on.
20 Q. So the declaration was based in part on
21 information transmitted by your lawyer to you?
22 A. Yes, and some from me to them.
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Maria Cino
And did you -- did you
Page 71
study any
2 documents before you prepared this declaration?
3 A. I looked at various press clips and the
4 suit that you had all sent over.
5
6
7
Q.
A.
8 break now.
9
10
Any other documents?
No.
MR. NIELDS: All right. Let's take a
MR. BURCHFIELD: Ten minutes?
MR. NIELDS: Ten minutes is fine.
11 (ReCeSs taken at 6:39 p.m.)
12 (Deposition resumed at 6: 48 p.m.)
13 (Mr. Levine is not present.)
14 BY MR. NIELDS:
15 Q. Could you turn to the second page of your
16 declaration, paragraph 4, where it says, "On or
17 about August 10, 2004, the Republican National
18 Committee mailed a letter welcoming all
19 newly-registered voters in CUyahoga County, Ohio,
20 to the political process, and encouraging them to
21 support the Republican ticket."
22 Do you see that?
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A.
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MariaCino
Yes, I do.
Page 72
Where did you get the list?
The list was gotten from the Cuyahoga
4 county Board of Elections of newly-registered
5 voters.
6
7
Q.
A.
who got it?
One of the folks in our department. I
8 can't say. I'm sure it was someone in our
9 political division, but I can't tell you
10 specifically who the person was. Likely to have
11 been someone in our network services that does
12 computer, our computer systems.
13 Q. well, I'm more interested in what you've
14 heard, learned, or know, rather than what you think
15 is likely.
16
17
A.
Q.
Okay. I can't answer that question.
okay. And was it -- was it somebody with
18 the Ohio Republican Committee that got it?
19 A. Best of my knowledge, it was someone from
20 the Republican National Committee.
21
22
Q.
A.
okay. And when did you get it?
That, I don't know. I can't give you a
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specific date.
Page 73
1
2 Q. Okay. Did you get it from any other
3 counties in Ohio?
4 A. We get lists all the time from counties,
5 from states, board of elections, and constantly
6 updating our voter files. So I am sure that we
7 have gotten -- I would be almost sure that we have
8 gotten other lists of new registered voters to
9 update our Ohio file.
10
11
Okay. And who did the mailing at the
12 We used a vendor.
13 And who contacted the vendor?
20 MR. BURCHFIELD: Object. Beyond the
21 scope of the --
22 MR. NIELDS: It's 1n your brief.
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BURCHFIELD: But it's beyond
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the
2 scope of this deposition. I'm going to let her
3 answer it, though.
4 THE WITNESS: Yes.
5 BY MR. NIELDS:
6
7
8
9
10
11
12
BY
Q.
A.
Q.
MR.
Q.
A.
Okay. All 50 states?
No.
How many?
MR. BURCHFIELD: Same objection.
NIELDS:
Go ahead.
I would say, depending on at what point
13 we were in this campaign, as many as 20, or 17,
14 battleground states.
15 Q. Now, who developed the list of
16 envelope -- of mailings that were returned
17 undelivered?
18
19
THE WITNESS: If I'm understanding your
20 question, the list was gotten from the Cuyahoga
21 Board of Elections of newly-registered voters.
22 BY MR. NIELDS:
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1 Q. Okay. My question isn't clear.
Page 75
2 That was the list you used to do the
3 mailing, correct?
4
5
A.
Q.
6 correct?
7
8
A.
Q.
9 correct?
10
11
A.
Q.
12 those?
13
14
15
16
17
A.
Q.
A.
Q.
A.
Yes.
And you mailed forth 49,552 letters,
Yes.
And 3,353 were returned as undeliverable,
That is true.
Okay. And did somebody make a list of
of the unreturned?
Yes.
Yes.
Who?
It was a list that was made by the Ohio
18 Republican Party. They received the returns.
19 Q. So you did the mailings and they received
20 the returns?
21 A. Yes. The return address was to the ohio
22 Republican Party.
Esquire Depositiou Services
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MariaCino
And did they -- did they send a
Page 76
copy of
2 the list to you?
3
4
5
6
7
A.
Q.
A.
Q.
A.
Yes.
Where is it?
I don't know.
Do you --
I'm sure it's in our -- well, I'm not
8 going to speculate.
9
10
11
12
Q.
A.
13 today.
Is it in the possession of the RNC?
Yes.
MR. NIELDS: We'd like to get it.
MR. BURCHFIELD: You may have gotten it
14 MR. NIELDS: Well, I got a list we'll
15 talk about in a minute. It doesn't have this
16 number of names on it, though.
17 MR. BURCHFIELD: Let me make inquiry. I
18 was under the impression that was the list, but
19 I'll inquire.
20 BY MR. NIELDS:
21 Q. okay. So both you and the Republican
22 Party of ohio had this list of mail returned
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3

5
6
MariaCino
undelivered, correct?
Page 77
A. Yes.
Q. Why was the list made?
A. Excuse me?
Q. Why was the list made?
A. To keep track of voter -- to keep track
7 of returned undeliverable mail.
8 Q. And why did you want to keep track of
9 returned undeliverable mail?
10 A. We do data collection and we store this
11 information.
12
13
,.
15
16
Q.
A.
Q.
A.
Q.
For what purpose?
variety of different reasons.
Hmmm?
variety of different reasons.
Okay. Tell me what the variety of
17 different reasons were.
18
19
A.
Q.
One would be for pUblic relations.
And how would it help your public
20 relations to have a list of undeliverable mail?
21 A. Looking at the list and determining if
22 there were duplicates or if there were forge -- if
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1 there were returns that may have came -- a
Page 78
lot of
2 returns from one particular address maybe that
3 didn't exist.
4 Q. So you were interested in whether people
5 lived at or were registering from places that
6 didn't exist?
7
8
9
A.
Q.
A.
That was part of it.
Okay. What other reasons?
Okay. The second reason, as has been
10 reported, the Democrats have stated time and time
11 again that they intend on challenging the results
12 of this election. This is a battleground state, a
13 state that is very, very competitive, and this
14 information will be stored and possibly used later.
Q. For what purpose? 15
16 A. If the results of this election were to
17 be challenged.
18 Q. And how would you use it if -- in a
19 challenge by you, by the Republican National
20 Committee--
21
22
A.
Q.
Well, I would assume --
-- or by the Democrats?
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1 A. -- that the Democrats would be
Page 79
2 challenging the election. We're going to win.
3 Q. And so in what way would this list help
4 you if the Democrats challenged the election?
5 A. This list could point out duplicate
6 registrations. This list, as I said earlier, would
7 be able to point out many residents listed to one
8 address that perhaps didn't exist.
9
10
Q.
A.
And how would that help you?
If there was a question in perhaps the
11 vote count in that particular county.
12 Q. In other words, you might argue that some
13 of the votes cast for the Democrats had been
14 fraudulently cast?
A. Yes. 15
16 Q. Okay. NOW, was any analysis done of this
17 list?
18 A. I'm not sure. Can you be more specific,
19 analysis?
20 Q. Well, what was done with the list at the
21 RNC when you got i t ~
22 A. of undeliverables?
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2
3
Q.
A.
Q.
4 anybody?
5 A.
MariaCioo
Of unde1iverab1es.
Page 80
We cataloged it and stored it.
Was it discussed within the RNC by
We discussed the percentage of returns
6 based on the size of the counties and based on the
7 size of the newly registered.
B Q. Well, you don't mean counties, do you?
9 There was only one county.
10 A. I'm sorry, based on the county and the
11 newly registered in that particular county.
12
13
,.
15
16
Q.
A.
Q.
A.
Q.
well, there were 3,353.
Correct.
Correct?
Yes.
Did you discuss within the RNC whether
17 this indicated that maybe some registrations were
18 fraudulent?
19 A. We observed from the returns that there
20 were in fact several that were duplicates, that
21 were registered -- several that were an ordinary
22 amount registered to one particular address.
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And who engaged in those
Page 81
discussions?
Myself and Blaise Hazelwood. our
3 communications person.
4
5
6
7
Q.
A.
Q.
A.
Who?
Jim Dyke.
Anyone else?
At various times we had our counsel
8 present, our legal counsel present.
9
10
11
12
13
Q.
A.
Q.
A.
Q.
And?
Their names?
Oh, sure, I'll take their names.
I'm sorry, Jill Holtzman, Mike Duncan.
And was there discussion as to whether
14 some of these 3,353 were potentially fraudulent
15 voters?
16
17
A.
Q.
There was a concern.
And was there a discussion about what
18 might be done?
19
20
21
A.
Q.
A.
No, there was not.
No discussion of what might be done?
We would be collecting the data and under
22 the consent decree we knew that we couldn't do much
D.C. 18004413376
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with this list.
Page 82
Q. well, that wasn't --
1
2
3
4
A.
Q.
That's why we had legal counsel there.
That wasn't exactly my question.
5 My question was, was there discussion of
6 what might be done?
7 A. And I believe I answered the question
8 earlier when I said potential public relations.
9 And if in fact the Democrats who were out there
10 already saying that they were going to contest this
11 election, this would be information that might be
12 used.
13 MR NIELDS: Well, let' s take a look at
14 the list, or a list. Everybody have copies of
15 this? Maybe I do. No, I don't.
16 Let's mark these Exhibits, what are you
17 at, 8? 9A and B.
18 (Exhibits 9A and B
20 BY MR. NIELDS:
21 Q. Okay. I'm putting a document in front of
22 you marked Cino Exhibit A. What is it?
D.C . 18004413376
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2
3
A.
Q.
A.
4 returned.
5 Q.
Maria Cino
It's a cuyahoga County list.
List of --
Page 83
I believe these are the names of the
This is a list of newly-registered voters
6 to whom mail was sent and the mail returned1 is
7 that what you're saying?
B A. Well, I can't tell you if this is -- yes,
9 it appears that this is that list, yes.
10 Q. Okay. It's 31 pages long, and you can
11 count if you wish, but my count is there's --
12
13
14
15
16 page.
A.
Q.
A.
Q.
My
I'll believe you.
Pardon?
I'll believe you.
There's a little over
math, if you multiply
30 lines on each
31 by a number in
17 the low 30s, you get to a little over 900. And so
18 I renew my request for the full list.
19
20
MR. BURCHFIELD: I'll inquire.
MR. NIELDS: Thank you.
21 BY MR. NIELDS:
22 Q. The cover page has written on it in
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1 large, in the copy I've got, black writing,
Page 84
it
2 looks like almost magic marker type writing, "OH,
3 highly suspicious."
4 Who put that on there?
A. I'm not sure.
Q. What does it mean?
5
6
7 A. I believe what it means is that these
8 names, based on for example the number at this
9 first address, four people at this first address
10 with different last names, would be suspicious,
11 that they were all at one address and they had
12 different last names. So people that -- perhaps
13 multiple registers and people who lived at more --
14 unrelated people that lived at one address.
15 Q. Suspicious, what you were suspicious of
16 here is fraud, correct?
17 A. Suspicious of voter registration
18 irregularity.
19
20
21
Q. Well, are you afraid of the word "fraud"?
A. No.
Q. Well, did you -- were you suspicious of
22 fraud here?
D.C. 180()'4413376
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2
3 Okay?
A.
Q.
A.
Q.
A.
Maria Cino
Page 85
Yes, we were suspicious of fraud.
Okay. And then let's turn to page 22.
7 It's got some handwriting on the Q.
8 right-hand side, correct?
9
10
11
12
A.
Q.
A.
Q.
Yes, it does.
Who put that there?
I would not be able to tell you that.
What was the function of the person who
13 put that there?
14 A. To review the list for voter
15 irregularities.
16
17
1B
Q.
A.
Q.
19 question.
20
21
A.
You don't like the word "fraud"?
Not really.
only in press conferences. Withdraw the
Thank you.
MR. BURCHFIELD: Was it a question?
22 BY MR. NIELDS:
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Maria Cino
What department was the person in
Page 86
who
2 wrote these handwritten notes in the right-hand
3 column?
4 A. This was probably -- the best of my
5 knowledge, the research department.
6
7
8
9
Q.
A.
Q.
At the bottom it says "Evan, 8/26/04."
Do you know what that means?
I do not.
Was there somebody in the research
10 department named Evan?
11 A. Our research department has probably got
12 40 people in it right now, and I would not be able
13 to answer that.
14 Q. Okay. You don't know if there's a person
15 named Evan?
A. I do not. 16
17 Q.
And it says things like mistyped address,
18 no record found, doesn't look residential, looks
19 like parking lot, mostly commercial area, no
20 records, not likely?
A. Correct. 21
22 Q. What is the person -- what is the meaning
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Page 87
of those notes? 1
2 A. Again, these are the returns that we
3 would suspect voter irregularities.
4 Q. And what was -- how did you -- how did
5 you -- or how did the person who wrote these get
6 the information necessary to make these notes?
7 A. with regards to some of this information,
8 and I can't say which, variety of different ways.
9 Phone books were used. And in addition to that,
10 several research folks were in the field and
11 actually drove by some of these addresses to see if
12 there was a mistake and perhaps it was a residence,
13 or in fact that it was a park lot.
Q.
A.
And how do you know that?
I talk --
14
15
16
17
18
MR. BURCHFIELD: object to form.
You may answer.
THE WITNESS; Thanks. Through talking
19 with Blaise about --
20 BY MR. NIELDS:
21
22
Q.
A.
When?
-- results of the returns.
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2
3 date.
4
Q.
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Q.
MariaCino
When?
Page 88
I'm afraid I couldn't give you a specific
But this is back in the AUgust, September
5 time frame when this was done?
6 A. Roughly, but I can't be specific with
7 you.
8 Q. So you knew then that people at the RNC
9 were looking at this list and doing additional
10 investigation to inform themselves about whether
11 these were proper voters or not?
12
13
A.
Q.
Yes.
Up at the -- looking at the first page,
14 there's a line that says info key, colon, CF,
15 paren, couldn't find; VR, paren, verified
16 residential; P, photo; B, business; 0, other.
A. Yes.
Q. What is -- what is that?
17
18
19 A. Exactly what it says. This is how we
20 cataloged. Couldn't find that particular address
21 or house. verif'ied the residence. If it was
22 perhaps suspect, a photo might have been taken. Or
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it was B, a business.
Page 89
1
2 Q. And where on this document do you use
3 these key words?
4 A. That, I can't tell you, because I've
5 never seen a completed list.
6 Q. But isn't it fair to say that whoever did
7 this well, did you participate in generating
8 this form?
9
10
11
A.
Q.
A.
I did not.
Who did?
I would not be able to specifically say
12 that, who did, I don't know.
13
14
Q.
A.
Generally who, what department?
I would -- I would believe it would be
15 the political department.
16 Q. And do you know whether they developed
17 this key because they wanted to do investigation of
18 these voters, additional investigation of these
19 voters in order to deter.mine whether they were
20 proper voters or not?
21 A. I'm sorry, could you ask that question
22 again?
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Marla Cino
MR. NIELDS: Read it back.
Page 90
(The reporter read back as requested.)
THE WITNESS: I believe the keys were
4 developed to determine whether or not these voters
5 were irregular voters.
6 BY MR. NIELDS:
7 Q. Okay. And do you know whether additional
8 investigation was done on the challenge list that
9 was ultimately filed by the Ohio Republican Party?
10 A. I would not know that because they had
11 their own list.
12 Q. Let's go back to 9B. 9B -- well, strike
13 that.
14 It appears to be the same list with the
15 same names. Well, it's not exactly. Yes, it is,
16 excuse me. It appears to be the same list with the
17 same names. But with different handwritten notes
18 on the right-hand column.
19 And I'd like you to turn to page 23. I
20 apologize, because what I have done is I've --
A. Combined the two. 21
22 Q. I believe I've given you --
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1 A. The same list.
Page 91
I'm sorry, there's two
2 lists in here.
3 MR NIELDS: I think I've given you -- I
4 think I've marked as Exhibit 9B more than one list.
5 Yes. I would like to break 9B apart and I'd like
6 to mark 9Bl pages that are Bates stamped RNC 00035
7 to RNC 00065.
8 (Exhibit 9B remarked
9 as Exhibit 9B1.)
10 MR. NIELDS: And then I'd like to mark as
11 Exhibit 9B2 a document marked RNC 00066 through RNC
12 00068.
13 (Exhibit 9B2
15 MR. NIELDS: And then I'd like to mark as
16 Exhibit 9B3 a document going from pages RNC 00069
17 to 00099.
18 (Exhibit 9B3
20 BY MR. NIELDS:
21 Q. Okay. Now I'm going to put back in front
22 of you Exhibit 9B1, 9B2, and 9B3.
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Page 92
Okay.
And counsel can check me or the witness,
3 but 9B1 appears to be the same list as 9A, except
4 that it has different handwritten notes in the
5 margin. And if you look at page 23 and 24, for
6 example, you'll see some more handwritten notes in
7 the margin, correct?
8
9
A.
Q.
Yes.
Of a similar type to the notes on Exhibit
10 9B -- 9A, correct?
11
12
A.
Q.
Yes.
And if you look at Exhibit 9B3, it
13 appears to be a very similar list to 9A, but here
14 the info notes column has typewritten notations
15 instead of handwritten, correct?
16
17
18
19
A.
Q.
A.
Q.
Correct.
Do you know who prepared Exhibit 9B3?
I do not.
Let's take a look at 9B2. Have you seen
20 the documents that are in -- the three documents
21 that are in 9B2 before?
22 A. The first time this morning.
D.C. 18004413376
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2
3
4
5
6 9B3?
7
8
Q.
A.
Q.
A.
Q.
A.
Q.
MariaCino
And who prepared this?
I couldn't tell you.
You didn't ask?
Did not ask.
Page 93
When did you first see 9A and 9Bl and
Today.
And did you ask any questions about these
9 documents:?
10
11
A.
Q.
NO, I did not.
So you don't -- you didn't talk to the
12 people who prepared them and you don't know why
13 they prepared them for sure?
14 A. I talked with my attorney and these were
15 records that we have in our building. And that is
16 what I believe they are.
17
18
Q.
A.
And that's all you know about them?
With regards to Cuyahoga County,
19 unreturned --, undeliverable mail.
20 Q. You mean you know that they had to do
21 with that?
22 A. w e l l ~ cuyahoga County, mailing returned.
D.C . 18004413376
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2
3
4
5
6
7
8
9
10
11
Q.
A.
Q.
A.
Q.
A.
Q.
A.
Q.
A.
Q.
12 correct?
13
14
A.
Q.
MariaCino
And it had
On 9B2.
Page 94
And it has returned, 2,943, correct?
Yes.
And it says entered, 2,496, correct?
Yes, it does.
And it says reviewed, 950?
Yes.
Then it says suspicious, 50 to 80?
Yes.
And then says highly suspicious, 10,
Yes.
So of the 950 that were reviewed, 50 to
15 80 were suspicious and 10 were highly suspicious,
16 correct?
A. Highly --
MR. BURCHFIELD: Object.
17
18
19 THE WITNESS: I only know what's written
20 on this form. I don't know that for a fact.
21 BY MR. NIELDS:
22 Q. But that's what's written on the form,
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3
MariaCino
correct?
A. That is what's written on the form.
Q. Do you know whether anybody at the
Page 95
4 Republican committee in ohio or the Republican
5 National Committee tried to separate the suspicious
6 and highly suspicious from all the rest of the
7 returned address newly registrants when the
8 challenges were made, the 35,000 challenges were
9 made to newly-registered voters in Ohio?
10 I want to ask that question again because
11 it was a really bad question.
12 A. I'm sorry, I lost you. Sorry. I thought
13 it was just me.
14 Q. Okay. I'm moving forward. I'll come
15 back to these lists in a minute.
A. Okay, thank you. 16
17 Q. But I'm moving forward. I want to ask
18 you this question.
19 You're aware that challenges were made to
20 35,000, more or less, registrants in Ohio?
A. Yes, I am. 21
22 Q. Okay. And that that was based on --
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1 according to your affidavit, that was based
Page 96
on
2 mailings that were made to new registrants by the
3 state of Ohio, of which some 35,000 were returned
4 undelivered?
5 A. That is correct, primarily from the
6 returns from the Ohio Board of Elections.
7 Q.
And do you know whether before making the
8 challenges anybody went over that list to separate
9 out the highly suspicious and the suspicious from
10 all the rest of them?
11 A. I'm sorry, what list are you talking
12 about?
13 Q. The list of 35,000 that carne back
14 undelivered, okay?
A. Yes. 15
16 Q.
Do you know if anybody took that list and
17 tried to determine which of those were suspicious
18 or highly suspicious and which weren't?
19 A. Based on what? We're talking about two
20 different lists.
21 Q. All right. Let's go back to the
22 beginning. Okay.
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Q.
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Okay.
Page 97
We have here lists 9 -- let's go back to
3 9A, correct?
4
5
A.
Q.
Yes.
And this is a list made up of returned
6 mail from a mailing that the RNC caused to be made
7 to newly-registered voters in Cuyahoga County?
8
9
A.
Q.
Correct.
And then I think we've established that
10 somebody at the RNC did some more work?
11 A. Research.
12 Q. More research to try to determine whether
13 these were real buildings or not, whether these
14 were irregular voters or not, correct?
A. Correct. 15
16 Q. Okay. And they came up -- somebody came
17 up with a categorizing of these voters?
18 A. Correct.
19 (Ms. Browne left the room.)
20 BY MR. NIELDS:
21 Q. And they put 50 to 80, plus 10 in
22 suspicious or highly suspicious category?
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Page 98
Correct.
Correct? Okay. The rest of them were
3 not in suspicious or highly suspicious category,
4 correct?
5 A. I can only assume that. I don't know for
6 a fact.
7 Q. Okay. But they did same more work over
8 and above simply having a list of returned mail?
9
10
A.
Q.
Yes.
My question to you is, did anybody do
11 similar work with regard to the 35,000 returned
12 mail letters as to which challenges were made?
A. That, I don't know. 13
14 Q. Thank you. Now, let me ask you this.
15 In paragraph 5 of your declaration it
16 says, "On September 9, 2004, the Republican Party
17 of Ohio sent letters to newly-registered voters in
18 5 ohio counties: Cuyahoga, Franklin, summit,
19 Hamilton, and Montgomery." Correct?
A. Yes, correct. 20
21 Q. All right. By the way, how do you know
22 that?
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1 A. Through conversations with my
Page 99
political
2 director.
Q.
A.
Q.
A.
Q.
Your political director?
Blaise Hazelwood, sorry.
She told you that?
Yes.
When?
3
4
5
6
7
8 A. probably mid-september, that the Ohio
9 state party was going to do a mailing of new
10 registered voters.
11 Q. And how did she know that?
12 A. Through conversations.
13 Q. With whom?
14 A. with regional political director and the
15 Ohio or the state Republican Party of Ohio.
16 Q. SO she talked to her own regional
17 director, that's Mr. James?
A. Yes, sir. 18
19 Q. And also to people at the state party,
20 Republican party in Ohio?
21 A. Yes. We were made aware that they were
22 going to be doing a mailing.
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3 this.
4
Q.
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,
Q.
MariaCino
All right.
Page 100
And Mr. Bennett was very vocal about
Okay. And he spoke to Blaise?
5 A. I cannot say that he spoke to Blaise
6 Hazelwood. I don't really know who at the party
7 she spoke to.
Q. 8 But somebody at the Republican Party of
9
10
11
17
Ohio?
A. Yes.
Q. Okay. NOw, if you look at tab 3.
A.
Q.
A.
Q. And I think I better be clear. This is
18 tab 3 to your declaration?
19
20
21
22
A.
Q.
A.
Q.
It is.
which has been marked Exhibit?
Exhibit 8.
Exhibit 8. All right.
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1 And you say tab 3 is a copy of
Page 101
the letter
2 that was sent by the RNC to newly-registered voters
3 in Cuyahoga county?
4
5
6 that?
7
A.
Q.
A.
Yes, sir.
Okay. Then if you turn to tab 4, what's
That is the letter that the Republican
B state party of Ohio sent to the newly-registered
9 voters in the five counties that you just
10 mentioned.
11
12
Q.
A.
And am I right the letters are the same?
The difference in the letters are that
13 the Republican National Committee letter directs
14 the newly registered to visit our website at the
15 Republican National Committee. The Ohio Republican
16 party letter directs the newly registered to go to
17 the ohio Republican Party website.
18 Q. But other than that, the text of the
19 letters is identical, correct?
20
21
22
A.
Q.
A.
The text is identical and -- yes.
How did that happen?
We commonly share direct mail.
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What does that mean?
Page 102
They knew the letter that we had sent out
3 and they used the same letter. It's a good letter.
4 MR. BURCHFIELD: There's some serious
5 form of flattery.
6 BY MR. NIELD5;
7 Q. NOW, did anybody at the RNC share with
8 anybody at the Republican Committee in Ohio the
9 results of the RNC's mailing to Cuyahoga County
10 newly-registered voters?
11 A. Well, the Ohio Republican party received
12 the undelivered letters that the RNC mailed out.
13 Q. So they knew how many undelivered letters
14 there were?
15
16
17
18
19
20
21
22
A. I would assume so. I'm not sure, but I
would assume so. They were
then sent to us.
Q. I think you said a
A. A list was
Q. Okay. So
a list or else they
A. Correct.
D.C. 1800.4413376
sent to
they had
couldn't
delivered there and
list
us.
a
--
have
was sent to you.
they had to have
sent it to you?
MD. 18005396398
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1 Q.
Maria Cino
Page 103
So they knew how many, how many letters
2 came back returned undelivered?
3
4
A.
Q.
I would assume so.
Okay. And then people at the RNC did
5 some analysis on that?
6
7
A.
Q.
Correct.
Did they share that with anyone at the
8 Republican Committee in Ohio?
9 A. I can't say that the information was
10 shared, no.
11
12
13
14
15
Q.
A.
Q.
A.
Well, do you know that it wasn't?
I don't know that.
You never asked?
I do know that the data files were
separated and we kept our we kept our file, they
16 kept their file. And the two were never compiled
17 together.
18 Q. Yeah, but my question is different.
19 Do you know whether -- did you ever ask
20 anybody whether they shared the subsequent analysis
21 that had been done at the RNC on this list?
22 MR. BURCHFIELD: Object to the form and
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foundation, scope.
Page 104
1
2 THE WITNESS: When talking to my regional
3 political director today, David James, I
4 specifically asked if the two lists had ever been
5 put together. And the answer was no.
6 BY MR. NIELDS:
7 Q. Okay. But that isn't my question.
8 My question is, did you ask anyone
9 whether the analysis that had been done by the RNC
10 on the list which is Exhibit 9A had ever been
11 shared with anyone at the Republican Party in Ohio?
12
13
MR. BURCHFIELD: Same objections.
THE WITNESS: I don't know, I don't know.
14 I'm assuming it was not, but I can't say for sure.
15 BY MR. NIELDS:
16
17
18
Q.
A.
Q.
Did you ever ask anyone?
I didn't ask it that way, no.
NOW, how many letters came back
19 undelivered from the mailing done by the Republican
20 Party of Ohio?
21 A. well, as you'll see in number 5, point 5
22 in my declaration, 15,000, a little over 15,000
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4
5
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were returned.
Page 105
Q.
A.
Q.
A.
How did you learn that?
How did I learn that?
Yes.
Through conversations with my political
6 director and information that she had gotten from
7 the Republican Party of Ohio.
8
9
Q.
A.
When?
I can only go in time frames. I know it
10 was after the convention.
11
12
13
14
15
Q.
A.
Q.
A.
Q.
Approximately when?
Mid-September.
Okay. So Blaise --
I'm sorry, Blaise Hazelwood.
-- Hazelwood had conversations with
16 people in the Republican Party of Ohio and passed
17 that information on to you?
A. Yes.
Q. That's correct?
A. That is correct.
18
19
20
21 Q. About the number of mailings that were
22 returned undelivered?
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MariaCino
From the five counties
Page 106
that were mailed
2 by the Ohio Republican party.
3 Q. okay. So they shared that information
4 with the RNC?
5
6
A.
Q.
Yes.
Now, were there any discussions about
7 that information within the RNC?
B A. The discussions, again we looked at -- we
9 discussed percentages, the percentage that were
10 returned versus the percentage that was mailed out
11 to the newly registered, to see if there was
12 anything strange about that.
13 Q. Did you think that this was an indication
14 of fraudulent registering?
15 A. Quite honestly, and I can't remember the
16 breakdown by specific counties but at one time I
17 believe I knew, in some places yes, and some places
18 no.
19 Q. So you thought that there were some
20 places where it was fraudulent and other places
21 where it wasn't?
22 A. In some counties it appeared that there
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1 was a lower percentage of returns, maybe 2
Page 107
to
2 3 percent. In other places there were perhaps
3 10 percent or above.
4 Q.
5 overall?
6
7
8
A.
So you thought this was a -- how about
Overall --
THE WITNESS: Yeah, I'm not sure that --
9 BY MR. NIELDS:
10 Q. Did you regard these as sufficiently high
11 overall that it was an indication of voter fraud?
12 A. You know, I'm not sure that it really
13 mattered in my world. It was a number that I was
14 given. We looked at the numbers to give us an idea
15 of the returns and whether or not they were
16 potentially voter irregularities. And that was
17 about it.
18 Q. Did you talk about it to other people at
19 the RNC?
A. My political director. 20
21 Q. Talked about whether this was indication
22 of voter fraud?
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(Ms. Browne entered the room.)
Page 108
THE WITNESS; Was concerned that it could
3 possibly be voter irregularities.
4 BY MR. NIELDS;
5 Q. Did you believe that there were any steps
6 that you could take to deal with these voter
7 irregularities or fraud?
8
9
A.
Q.
No, sir.
Didn't believe there were any steps you
10 could take at all?
11
12
A.
Q.
No, sir.
You thought the consent order prevented
13 you from taking any steps at all?
14 A. We were very careful, as we were warned
15 by our counsel, what the lists could be -- what the
16 RNC list could be used for.
17 Q. Okay. But that -- okay. So you didn't
18 think you could use the RNC list as a -- for any
19 purpose?
A. Correct. 20
21 Q. Did you think you could use the
22 Republican Committee of Ohio list for any purpose?
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MR. BURCHFIELD:
Page 109
well, object to --
2 object to form, "any purpose." But go ahead.
3 THE WITNESS: No. It wasn't our mailing,
4 it was the Ohio state party's mailing, and they
5 were going to determine what they would do with
6 this mailing, the returned mail.
7 BY MR. NIELDS:
8 Q. Was there any discussion of finding a way
9 that you felt was okay to do something about this
10 indication of voter irregularities?
11 A. We were concerned about voter
12 irregularities, and again we are very knowledgeable
13 and aware of the consent decree and were warned not
14 to discuss it.
15 Q. Did you think that if, instead of using
16 your list or the Republican Party of Ohio's list,
17 that you would be able to use a list generated from
18 mailings by the election boards in Ohio?
19
20
A. NO, we did not. I did not think that.
MR. BURCHFIELD: "You" meaning the RNC in
21 this question?
22 BY MR. NIELDS:
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A.
Maria Cino
Page 110
Yes.
I can't say that that was an option that
3 we came up with.
4
5
Q.
A.
Who came up with it?
I think it was discussed by Chairman
6 Bennett with regards to the returns. Again, my
7 recollection is primarily from the Cuyahoga County
8 Board of Elections returns, which were the packets
9 that they regularly send out to newly-registered
10 voters throughout the state. And there was an
11 ordinary -- extraordinary number of returns that he
12 had mentioned and talked about, both as I said on
13 TV and in news articles.
14 Q. Now, in the brief that's been filed in
15 this matter, on page 5 --
16
17
18
A.
Q.
19 the brief.
20
21
22 this.
Number 10?
No, this is the brief.
MR. BURCHFIELD: No, he's talking about
THE WITNESS: Dh, I'm sorry.
MR. NIELDS: So you may want to look at
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MR. BURCHFIELD: Page 5?
MR. NIELDS: Yeah.
Page 111
1
2
3 MR. BURCHFIELD: I am showing her my copy
4 of the brief.
5 BY MR. NIELDS:
6 Q. Okay. First look at the -- let's start
7 with the first page. It says in the second
8 paragraph, second sentence, it says the Republican
9 party of Ohio has challenged voter registrations
10 based primarily on returned race-neutral mailings
11 to voters by the Ohio County Boards of Elections.
12 Do you see that?
A. Yes, sir. 13
14 Q. And if you turn to page 5, there are two
15 paragraphs that discuss indications of voter fraud,
16 one of which is begins with the word sixth.
17 Do you see that?
A. Yes, sir. 18
19 Q. And then the second full paragraph on the
20 page begins, and I quote, in view of this and the
21 fact that the names being challenged were drawn
22 overwhelmingly from county mailings that were
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Page 112
1 returned as undeliverable, rather than RNC
2 mailings, the Republican Party of Ohio initiated
3 statutory challenges to voter registrations.
4 Is that true to your knowledge, that
5 statement?
6
7
A.
Q.
Yes, sir.
NOW, what is the basis for the part of it
8 that says that in view of the fact that the names
9 being challenged were drawn overwhelmingly from
10 county mailings that were returned as
11 undeliverable, rather than RNC mailings, the
12 Republican Party made the challenges? Why did
13 why did that make a difference to the thinking
14 behind the challenges?
15 A. Well, the fact as I stated earlier, we
16 knew all along that any returns from the RNC
17 mailing could not be used as a challenge or any
18 type of ballot security.
19 Q. But you thought that other returns could
20 be?
21 A. The state party -- the state party of
22 Ohio determined that, not me.
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1 Q. well, how do you know that they
Page 113
2 determined that?
3 A. Through various conversations, through
4 various articles and news reports.
5 Q. All right. And when was the -- when were
6 these conversations?
7 A. The conversations, the best of my
8 knowledge, were probably early to mid-October.
9 Q. All right. And who were the
10 conversations with?
11 A. Again, my conversations were with my
12 political people, my regional political director,
13 my counsels, and my political director, Blaise
14 Hazelwood, my regional political director, David
15 James, and members of our counsel at the RNC.
16 Q. And these occurred early to mid-October,
17 to the best of your recollection?
18 A. To the best of my recollection, as it
19 came out in the newspaper that tens of thousands of
20 these packets that are regularly sent by the
21 Cuyahoga Board of Elections with voter information
22 to specifically newly-registered voters were being
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returned.
Q.
MariaCino
Page 114
Now, is it true that you already knew
3 that 15,000 had been returned from mailings that
4 had been made by the Republican Party of Ohio?
5 A. My recollection is that I did know, I
6 can't say that that was the number, but I did know
7 that the Ohio -- specifically the Ohio Republican
8 Party's mailing did in fact produce returns. To
9 the number, again, I can't exact say I knew it was
10 15. I knew it was around 10 or something.
11
12
13
Q.
A.
Q.
You knew it was a lot?
Yes.
So why was this information about the
14 mailings, the returned mailings from the county
15 election boards, how did that change the picture?
16 A. I'm not sure I understand your question.
17 What picture were we changing?
18 Q. Well, as I understood it, you've said
19 that you learned in this October time period that,
20 based on the returned mailings from the counties,
21 county election boards, that the Republican Party
22 of Ohio decided to challenge.
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Maria Cino
Based on the returns
Page 115
from the
2 Cuyahoga Board of Elections, the actions taken by
3 chairman Bennett, it was determined he would be
4 challenging the newly-registered voter returns
5 primarily from the Board of Election mailing.

7
Q. Why didn't he challenge based on the
returned mailings from the Republican Party of
8 Ohio?
9 A. r can't say that I know the answer to
10 that, sir.
11
12
13
Q.
A.
Q.
Well, have you asked?
I have not.
Do you do you know what -- you said
14 you learned in this early October time frame that
15
,.
17
18
19
20
21
22
the Republican Party was going to
A. That they were thinking
do this, correct?j
of what they I
would do with regards to the high number of returns
that they had from their Ohio state party mailing J
and what they had seen or heard from the cuyahoga i
Board of Election mailing. And I believe that
Chairman Bennett was asked a question at the pressj
conference on October 20th with regards to what h;
,
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intended on doing with the returns.
Page 116
Q. And prior to October 20, in the early to
3 mid-October time frame, what did you learn about
4 the Republican Party of ohio's intentions?
5 A. That they were going to consider what
6 they were going to do. But it was never really
7 discussed what they were going to do. Just that
8 they were going to consider based on the number of
9 returns.
10
11
Q.
A.
And how did you learn that?
Again, I learned it through my political
12 director, Blaise Hazelwood; my regional political
13 director, David James, with regards to the number
14 of returns, can't remember the specifics but
15 Obviously, from my declaration, 15,000 that had
16 come in. There was a concern and they were
17 deciding what action would be taken.
18
19
Q. And how did they learn that?
A. Through conversations they had with the
20 Republican state party of Ohio.
21 Q. Did they discuss with the Republican
22 state party of Ohio whether it would be proper or
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1 improper for the Republican state party of
Page 117
Ohio to
2 make such challenges?
3 A. Specifically in speaking to David James
4 today, he emphatically said that he informed them
5 that because of the consent decree he would not be
6 able to comment or be involved.
7
B
Q.
A.
Did he -- and how about Blaise Hazelwood?
I don't believe that she had any
9 conversations as to what they were going to do.
10 Q. And you say you don't believe she did.
11 Did you ask her?
12 A. I did not specifically ask that question,
13 no.
14 Q. And do you know who else at the RNC spoke
15 to people at the state party of ohio on the subject
16 of possible challenges to newly-registered voters?
17 A. I would not know that there were any
18 discussions, but again, the folks at the RNC have
19 been trained and versed on the consent decree and
20 they know what they can and cannot talk to. Just
21 this year, our whole legal department met with each
22 individual division, going over the consent decree.
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So we are always very careful.
Page 118
Q. And when you go over the consent decree,
3 do you say that there are no challenges to voters
4 on the ground of suspected fraud that the RNC can
5 do?
6
7
THE WITNESS: I can't say that those are
8 the exact words.
9 BY MR. NIELDS:
10
11
12
Q. But is that the sum and substance of it?
THE WITNESS: My recollection would be
13 that we would engage in no ballot security, nor
14 voter challenges, based on the consent decree.
15 BY MR. NIELDS:
Q. Even race-neutral ones?
A. None whatsoever.
16
17
18 Q. But it was your understanding that the
19 state parties could?
20 A. It's my understanding the state parties
21 are independent 'and they can do what they want. We
22 don't control the state parties. As a matter of
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1 fact, in this case, as I said earlier,
Page 119
this is
2 probably the premier state party in the country.
3 Q.
And getting back to an earlier question,
4 I want to make sure I got the answer to. Besides
5 Blaise Hazelwood and Mr. James and Mr. Gillespie,
6 did you ask anyone else at the RNC whether they had
7 discussions with the Republican Party of Ohio about
8 possible challenges?
9
10
A.
Q.
11 selected?
12
I did not.
HOW were the five counties in ohio
MR. BURCHFIELD: Object to form and
13 foundation.
14 BY MR. NIELDS:
15
16
17
18
19
20
Q.
A.
Q.
A.
Q.
How were the -- withdraw the question.
In paragraph 5 of your declaration --
Yes, sir.
-- you mentioned five counties in Ohio --
Yes, sir.
-- to whom the Republican Party of Ohio
21 sent mailings.
22 A. Yes, sir.
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3
Q.
Maria Cino
How were they selected?
Page 120
MR. BURCHFIELD; Same objection.
THE WITNESS: Best of my recollection,
4 through conversations that I got second or
5 thirdhand, these counties were picked based on the
6 size and the high number of newly-registered
7 voters. These would be the five top counties that
8 had highly -- that had high newly -- number of high
9 newly-registered voters. I'm sorry, I can't get
10 that out.
11 BY MR. NIELDS:
12
13
Q.
A.
And who did you learn that from?
Again in conversations we have with
14 our -- my political people, my regional political
15 director, David James; and Blaise Hazelwood, my
16 political director.
17 Q. Before we broke last time I think I was
18 asking you about any effort you made to review
19 documents in preparation for your affidavit. And I
20 think you said press releases and the papers that
21 had been filed by the Intervenors?
22 A. Yes.
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3
4
5
6
Q.
A.
Q.
A.
Q.
A.
Maria Cwo
And that's it?
Page 121
And briefed by a team of attorneys.
And briefed by a team of attorneys?
At the Republican National Committee.
Who told you what?
What -- I'm not a lawyer. So what -- the
7 document from the Intervenors, they outlined that
8 for me. And we discussed past information that I
9 would have from a variety of different meetings or
10 calls over the last six, eight, ten, twelve months.
11 Q. This is you telling them things or them
12 telling you things?
13 A. A little bit of both. Again, many times
14 I had attorneys in meetings with me.
15 Q. And is there some part of your
16 declaration that is based on what the attorneys
17 told yOU?
18 A. I'm not sure I really understand the
19 question. It's all factual information.
20 Q. Right. But I'm trying to figure out how
21 you learned this factual information.
22 And my question is, is there information
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1 in here that you learned only from
Page 122
attorneys that
2 were briefing yOU?
3
4
5
6
A.
Q.
A.
Q.
No.
Who is Tim Griffin?
Tim Griffin is our director of research.
And I apologize but I can't remember your
7 answers to my prior questions sometimes. Was the
8 research department involved in analyzing the list
9 of returned mail?
10
11
12
13
A. Yes.
Go ahead.
THE WITNESS; okay. Yes. As earlier
14 stated, we had several staffers from the research
15 division in Ohio that did some research on the list
16 from the RNC mailing.
17 BY MR. NIELDS;
1S Q. Now, correct me if I'm wrong, but I
19 understood from your declaration that you had said
20 that the purpose of the ~ i l i n g s was marketing?
A. I never said that. 21
22 Let me back up. The purpose of what
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1
2
mailing, sir?
Q. The mailings by the RNC to
3 newly-registered voters in Cuyahoga county.
4 A. The purpose of the mailing to
5 newly-registered voters from the Republican
6 National Committee?
7
8
Q.
A.
Yes.
Was to welcome new registered voters and
9 give them information about the Republican Party
10 and urge them to go to our website.
11 Q. Okay. I stand corrected. I simply used
12 the wrong word.
13 A. I apologize. I don't even remember you
14 asking me the question of why the mailing was done.
15 MR. BURCHFIELD: It may be just about
16 break time for both of you, so when you get to a
17 point.
18 MR. NIELDS: Yes, it's getting close.
19 BY MR. NIELDS:
20
21
22
Q.
A.
Q.
So we'll take that purpose.
Okay.
Why, given that as the purpose, were the
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1 returned mailings analyzed for voter
Page 124
2 irregularities?
3 A. Again, as I said earlier, we cataloged
4 the information and stored it, perhaps to later use
5 for public relations. And if necessary, based on
6 what the Democrats had been reporting over the last
7 several months but in particular the last several
8 weeks, that they were going to contest this
9 election. Ohio, a battleground state, which is a
10 competitive state right now, this information later
11 on could be valuable.
12
13
"
15
MR. NIELDS: Let's take a break.
(ReceSS taken at 8;03 p.m.)
(Deposition resumed at 8:35 p.m.)
MR. LEVINE: My name is Jason Levine.
16 I'm another attorney with McDermott, Will & Emery,
17 and also counsel for the Republican National
18 Committee in this matter.
19 And I am producing to counsel documents
20 Bates numbered RNC 000147 through RNC 000185.
21 These are E-mail documents that came from the RNC's
22 files today, they were searched for and found
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1 today, and they're being provided at the
P a ~ e 125
deposl.tion
2 as the culmination of the document production by
3 the RNC in response to the Intervenor's document
4 requests.
5 MR. BURCHFIELD = The question came up
6 earlier as to where the remaining 3,300 -- the
7 remaining list of 3,300 returned mailings from the
8 RNC is, given that the exhibits 9A and 9B have
9 apparently some 900 or so names.
10 The information is that there is no
11 printed grid with the addresses, the names and
12 addresses of the others, that these grids were
13 prepared as indicated on Exhibit 9B2 as the grid of
14 those mailings, those returned mailings that were
15 reviewed. And it shows there are 950 that were
16 reviewed. That should fairly closely correlate to
17 the number on these documents.
18 people at the RNC, after you raised the
19 question, Mr. Nields, have checked and they believe
20 that there is no -- that there was never a data
21 entry exercise to put in the entire 3,300.
22 I would further note that the returned
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1
2
number here, 2,943, appears to be an
number, based upon what we know now.
Page 126
interim
There is a
3 count, but there's not a list. So I hope that's
4 helpful.
5 MR. NIELDS; Is there a document that
6 reflects the count?
7 MR. BURCHFIELD; The current count? This
B one reflects the count as of the time this grid was
9 prepared, and the count at that time of returned
10 was 2,943. Apparently there were -- there were
11 ones coming in after this.
12 MR. NIELDS: Yeah, but is there a
13 document that reflects the total count?
14
15 that.
16
17 that?
18
19
MR. BURCHFIELD: I will inquire about
MR. NIELDS: Would you inquire about
MR. BURCHFIELD: yeah, I will do so.
MR. NIELDS: Look, here's what I think we
20 should do. I think we should go for another 10 or
21 15 minutes now. It's conceivable, ,but I'm not
22 sure, we may get into another document question.
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Page 127
And then we can break, if there is
2 another document question we can break before I
3 read these, and then we can come back for that and
4 you can have maybe done some more due diligence.
5 Okay?
6 MR. BURCHFIELD: will you inquire about a
7 document containing the final count? I think Sean
8 is still over there. So containing the final count
9 of returns from the August RNC mailing. And
10 hopefully you can report on that.
MR. LEVINE: Yes. 11
12 THE WITNESS; And if he's not there, he's
13 fired.
14 MR. BURCHFIELD; Right. Okay. So you
15 want to go for another 10, 15 minutes now?
16 MR. NIELDS: I think that's about what
17 I've got before we can break and go through this.
18 MR. BURCHFIELD: Okay, great.
19 BY MR. NIELDS:
20 Q. Ms. Cino, I want to return to the RNC
21 mailing. You understand which I'm --
22 A. Yes.
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1 Q.
Maria Cino
It's the one covered by paragraph
Page 128
4 of
2 your declaration on August 10th.
3
4
A.
Q.
August 10th.
Why were the letters that were sent out,
5 why did the returns from them go to the Republican
6 party of Ohio?
7 A. It's simply a direct mail technique. Our
8 feeling was if we had the return to washington,
9 D.C., and the Republican National Committee on it,
10 people would be less likely to read it. And if we
11 had the state party, the local -- the state party
12 return address in Ohio, they would be more likely
13 to read it.
14 Q. Now, when they open up the letter they
15 would see that it was from the National Committee,
16 correct?
A. Correct. 17
18 Q. But in any event, as a result of this,
19 the RN -- although the RNC did the mailing, the
20 state party found out how many undeliverables there
21 were, correct?
22 A. Correct.
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Q.
A.
MariaCino
Who is Robert Trainum?
Page 129
Robert Trainum is an RNC -- I believe is
3 an RNC legal -- senior advisor on legal issues.
4
5
Q. Is he a lawyer?
I am not sure of that. He is not
6 directly on staff at the Republican National
7 Committee.
8 Q. I'm sorry, then what's his relationship
9 to the Republican National Committee?
10 A. The truth is, I've seen his name on
11 E-mails and papers and it's listed as senior
12 advisor to the Republican National Committee.
13 Q. And who does he advise, who does he
14 report to?
15 A. The things that I have seen him do are
16 mostly TV and radio interviews.
17
18
Q.
A.
What is his involvement in the mailings?
I don't know him to have any involvement
19 in the mailings.
20 Q. Okay. And was he involved in any
21 discussions that you have mentioned earlier about
22 the mailings?
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No discussions that I'm aware of
Page 130
that I
2 was involved with.
3
4
5
6
Q.
A.
Q.
A.
Who is Tara Wall?
I don't know.
You testified to a regional office in --
I testified that we have a regional
7 political director. They live in a state that they
8 are responsible for, but we do not have regional
9 offices.
10 Q. okay. And David James is the regional
11 political director for the region that encompasses
12 Ohio?
A. 13 Yes, sir.
14 And where is he, where does he live? Q.
A. 15 He lives in pennsylvania.
16 And how much of his time does he spend in Q.
17 Ohio?
18 It varies from beginning of cycle to end A.
19 of cycle.
20 Q. All right. Let's focus on the period
21 August to November, '04 -- August to the end of
22 October, '04.
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Beginning of August, the best of
Page 131
my
2 knowledge, he would probably be traveling from ohio
3 to pennsylvania. End of AUgust, he spent two weeks
4 at the Republican National Convention in New York
5 City. And September, probably a little more travel
6 to Ohio than Pennsylvania. I'm guesstimating here
7 that he probably moved pretty much full-time to
8 Ohio, guesstimating late september.
9 Q. How often does he talk to people in the
10 Republican Party of Ohio?
11 A.
12 state.
13
14
Q.
A.
All the time. It's his significant
And how does he help them?
He helps them right now with regards to
15 making sure that our Get Out the Vote program is
16 organized and implemented.
Q. Any other ways? 17
18 A. He would be involved in a variety of
19 different conversations. When you work in the same
20 office day in and day out, he's probably drug in a
21 lot of different meetings that I would have no
22 knowledge of.
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3
4
Q.
A.
Q.
A.
5 election.
6
7
Q.
A.
Maria Cino
Drug into a lot of meetings?
Different meetings.
where?
Page 132
On various subjects that would affect the
Meetings with whom?
Republican Party officials, elected
8 officials, campaign officials.
9 Q. But when he's in Ohio, is he at the
10 Republican party of Ohio offices?
11 A. He works somewhat out of the office in
12 Columbus, but also spends an amount of time
13 traveling from county to county.
14 Q. But when you say drug into meetings, I
15 take it you were referring to being drug into
16 meetings
17
18
A.
Q.
19 of Ohio?
20 A.
He participates --
-- at the offices of the Republican Party
Yes, as well as meetings in counties, as
21 well as campaign meetings, as wellas candidate
22 meetings.
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1 Q.
Maria Cino
Getting back to the mailing that
Page 133
was done
2 by the RNC, who paid for that?
3
4
A.
Q.
The RNC paid for that mailing.
Going to the mailing that was done by the
5 Republican party of Ohio, who paid for that?
6 A. My knowledge, it was paid for by the
7 Republican Party of Ohio.
8 Q. I think you testified earlier that the
9 RNC did training for state legal, state lawyers.
10 A. The RNC did training I believe for the
11 state party of Ohio, which entailed legal training.
12
13
Q.
A.
What sort of legal training?
Specifically we talked about Election Day
14 activities and we talk about -- and we go through
15 our Poll Watcher 2004 Manual.
16 Q. NOW, before we broke I think I asked you
17 who Tim Griffin was.
18
19
20
A.
Q.
A.
21 research.
22 Q.
Yes, sir.
Is he in charge of research?
Yes, he is, he's the director of
Okay. And is there a person under him
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who handles research for Ohio?
Page 134
A. The staff of research fluctuates,
3 depending on the types of projects that we're
4 doing. And I could not say that there was just one
5 person assigned to ohio. It's usually done on
6 subject matter.
7 Q. All right. Can you tell me the names of
8 people who worked on some subject matters in Ohio?
9
10
A.
Q.
No, I can't. It's a staff of 40.
But whoever would do research on Ohio
11 would report to Mr. Griffin?
12 A. Yes, any research that's done would be
13 reporting to Mr. Griffin.
14
15
16
17
18
19
Q. If you could look at Exhibit 2. It's a
Wall Street Journal article I asked you about
earlier.
A. Yes, sir.
Q. Do you know who at the RNC spoke
--
well,
first, do you know if anyone at the RNC spoke to
20 the reporter, Jeanne cummings, in connection with
21 this article?
22 A. I do not know that for a fact.
D.C 18004413376
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1
2
Q.
A.
MariaCino
Do you have an idea of who it
Page 135
was?
The two people that would be most likely
3 to talk to a Wall street Journal reporter would be
4 our communications director, Jim Dyke, or our press
5 secretary, Christine Iverson.
6 MR. NIELDS: I'd like this marked Exhibit
7 10.
8 (Exhibit 10
10 BY MR. NIELDS:
11 Q.
12 exhibit--
13
14
Ms. Cino, I put in front of you an
MR. BURCHFIELD: Can I get one of those?
MS. BUTLER: Oh, I'm sorry.
15 BY MR. NIELOS:
16 Q. Exhibit 10. Four-page document bearing
17 Bates stamps number RNC 000131 to Bates stamp
18 number RNC 000134.
19
20
21
22
A.
Q.
A.
Q.
Yes, sir.
Have you seen this document before?
I have.
And what is it?
D.C. 1800.4413376
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VA 1800752897\
1 A.
MariaCino
Basically it's a document with
Page 136
regards to
2 Pennsylvania.
3 MR. BURCHFIELD: And it was inadvertently
4 produced in my rush.
5 MR. NIELDS: I don't think it was so
6 inadvertent. I think you shouldn't fault yourself
7 so much.
8 If you look at the bottom of page 3 --
9 THE WITNESS: I'm sorry, what -- okay.
10 Which is what is on the top? Headquarters meeting?
11 Pages are numbered 152, 153 --
12 BY MR. NIELDS:
13 Q. I'm sorry. I'll identify it by Bates
14 number RNC 000133.
A. Yes, sir. 15
16 Q. That's a reference to Ohio on the bottom
17 of that page, correct?
A. Yes, sir. 18
19 Q. It talks about "Please call/attend during
20 your state's time slot"?
A. Yes, s'ir. 21
22 Q. And there's several states that have time
D.C. 18004413376
MD. 18005396398
VA. 18007528979
MariaCino
1 slots, Ohio being one and
P a ~ e 137
pennsylvania also b e ~ n g
2 one, correct?
3
4
A.
Q.
Yes, sir.
Now, going back to the first page of the
5 exhibit, what is it?
6 A. It appears that this is a call with
7 regards to HAVA.
8 Q. It says BAVA Election Day preparation,
9 call number 2?
10 A. I'm sorry, what sheet are you look at
11 now?
12 Q. The first sheet. Subject -- it's an
13 E-mail, correct?
14
15
A.
Q.
Yes, I'm sorry.
Okay. Let's take it in bites.
16 From Mike Roman to Anne Bradbury and some
17 others, correct?
A. Yes, sir.
Q. Who is Mike Roman?
18
19
20 A. All I know is he worked in pennsylvania,
21 but I don't know what his position is.
22 Q. Okay. And who is Anne Bradbury?
D.C. 18004413376
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1 A. Anne Bradbury is an Election Day
Page 138
2 coordinator.
Q. For whom? 3
4 A. For the Republican party of pennsylvania
5 is what I believe.
6 Q. And how did this find its way into the
7 possession of the RNC?
B A. This is -- well, I'm not sure if these
9 are two different meetings. From the looks of
10 this, I don't see at least on the first page an RNC
11 employee. And the only RNC employee is on the
12 October 25th E-mail, 000133.
13 Q. And who is that? Who's the RNC employee
14 mentioned--
A.
Q.
The RNC employees --
-- on that page?
15
16
17 A. The first, Randy Kammerdiener is a
18 regional political director in Florida. Randy
19 Enwright is a regional political director in
20 Florida. Anne Hathaway has the region of the --
21 regional political director. David James, regional
22 political director.
Esquire DepOSition Services
D.C. 18004413376
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1
2
3
Q.
A.
Q.
Maria Cino
Who we've already talked about?
John peschong --
Page 139
Okay. You don't need to keep going. You
4 don't need to keep going.
5
6
A.
Q.
Okay. That's fine.
Unless you want to.
7 Now, on the first page, it starts off, "I
8 have a call this evening at 8 p.m. with national."
9 What is national?
A. I don't know.
Q. Is that the RNC?
10
11
12 A. I would only be speculating to say it
13 was.
14 Q. Do you know what this -- what this E-mail
15 or pair of E-mails relates to?
16 A. Based on subject, HAVA and Election Day
17 preparation.
18 Q. Okay. There's a reference to number of
19 poll watchers.
A. Yes, s ~ r . 20
21 Q. And then there's, on the second page,
22 there's "Please also find the agenda for the call,"
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MariaCino
1 it says HAVA recruitment and structure, A,
Page 140
number
2 of retained counsel; B, number of county
3 litigators; C, number of legal roving teams; D,
4 number of poll watchers; E, number of problem
5 precinct poll watchers, and so forth.
A. Yes, sir. 6
7 Q. Is this a conference call with a series
8 of states in which somebody at headquarters, RNC
9 headquarters, is doing planning, inCluding pOll
10 watchers for Election Day?
11 A. Again, I interpret this as a string of
12 E-mails. The first E-mail, starting with 00131,
13 involving people from the Pennsylvania
14 organization, there is not an RNC person in this
15 chain of E-mails, discussing pennsylvania Election
16 Day HAVA program. And I believe that the last page
17 is an announcement for a meeting on HAVA Election
18 Day operations, but I can't say that it's the same
19 meeting.
20 MR. NIELDS: Okay. This will be marked
21 Exhibit 11.
22 (Exhibit 11
D.C. 18004413376
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Maria Cino
Page 141
2 BY MR. NIELDS:
3 Q. I'm putting in front of you a document
4 marked Exhibit 11.
6 A. I have not. I don't believe I have.
7 I've seen so many documents, I can't be sure.
8 Q. Okay. well, I'm going to ask you about
9 some of the people named in this document first.
10 Who is Christopher McInerney?
11 A. Christopher is in our research
12 department.
13
14
Q.
A.
Who is Shawn Reinschmiedt?
It appears, based on this header, also in
15 research, in our research department.
16
17
Q.
A.
Who is Michael Neal?
That, I don't know. It says political,
18 but I -- I don't know. He might be in one of the
19 states, but I have no idea.
20 Q. All right. On the top of the first page
21 there's a message that says, "Michael, I need to
22 get our most comprehensive list of numbers tonight
D.C. 1800.4413376
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MariaCino
1 to Chairman Gillespie out here in Columbus
Page 142
for his
2 press conference tomorrow. Do you have the
3 original lists that the outreach mailings went to?
4 Or do you know who might have them?"
5 Do you see that?
6
7
A.
Q.
8 about?
9
10
A.
Q.
I do.
Do you know what lists he's talking
I do not.
NOw, if you go to the second page of the
11 exhibit -- well, no, just stay with the first page.
12
13
A.
Q.
Okay.
Toward the bottom, there's an E-mail from
14 Christopher MCInerney to Shawn Reinschmiedt, re,
15 HAVA return list. And it says, "I need the entire
16 universe that the second mailing went to. Do you
17 know who has that?"
18 Do you know what the second mailing is
19 he's talking about?
20 A. No. It would be purely speculation on my
21 part.
22 MR NIELDS: Well, I guess my request
D.C 18004413376
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Maria Cino
1 would be this, from counsel. And that is,
Page 143
if there
2 is a second mailing return list that relates to the
3 Ohio mailings, I would be grateful if you would ask
4 the people in this E-mail chain whether they have
5 it.
6 MR. BURCHFIELD: I will endeavor to do
7 so. It is my understanding, however, that they
8 were looking for any such list in the scope of
9 their request, and it should have turned up. But
10 we will ask again.
11 MR. NIELDS: I note that there's a from
12 Shawn Reinschmiedt and it says -- she seems to say,
13 "In any event, if you have it please
14 send directly to Michael Neal, if you could. If
15 not at your fingertips, I'll find it on my computer
16 and send it in the morning."
17
18
MR. BURCHFIELD: We'll inquire.
MR. NIELDS: So we might ask her
19 computer.
20 I'd like this marked Exhibit 12.
21 (Exhibit 12
D.C. 18004413376
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VA 18007528979
MariaCino
Page 144
BY MR. NIELDSI 1
2 Q. Put in front of you a document marked
3 Exhibit 12. I'm sorry, I don't have copies of it.
Do you know what that is? 4
5 A. It appears to be, just based on what the
6 header is, challenge of rights to vote and
7 correction of registration list.
Q. For Ohio? B
9 A. I'm not sure if it's specifically for
10 Ohio, but the person on here is from Ohio.
Q. The voter --
A. I would believe --
Q. or the objector?
11
12
13
14 A. -- they're both from Ohio. It appearS
15 that this is a challenge to a voter.
16 MR NIELDS: Thank you. Let's take a
17 break.
18 (ReceSs taken at 9:03 p.m.)
19 (Deposition resumed at 9:53 p.m.)
20 (Exhibit 13
22 BY MR. NIELDS:
D.C 1800441-3376
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VA 180075289:
MariaCino
Page 145
Q. Okay. Back on the record. 1
2 I have put in front of you, Ms. Cino, a
3 document marked cino Exhibit 13. It's a many-paged
4 document, seems to be mainly E-mails of one kind or
5 another. They bear BateS stamps number RNC 000147
6 through RNC 000185.
7 And my first question is, have you seen
8 this document before?
A. Yes.
Q . When did you first see it?
A. About an hour ago.
9
10
11
12
13
14
15
Q. Okay. And are you familiar with the
matters that are described in here?
A. Somewhat.
Q. okay. Well, let's turn to the back of
16 it. Second to last page, most of the way down
17 toward the bottom there is an E-mail from Lauren
18 Barnett, political?
Yes.
Q. And who is she?
19
20
21 A. She is the executive assistant to Blaise
22 Hazelwood, the political director.
D.C. 18004413376
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VA 1.800.752.897
1 Q. okay.
Maria Cino
And it's to a bunch of
Page 146
people.
2 With the exception of the last name, which looks
3 like apostrophe TLOWN, are the others all RNC
4 folks?
5 A. The first two are RNC. The third one, I
6 can't speak to. Nor the fourth one, nor the fifth
7 one. And after that, I don't know who David, John
8 Parker or -- I just recognize the first two.
9
10
11
12
13
Q.
A.
Q.
A.
Q.
How about Wade Lairsen and Michael Neal?
Do not.
You don't recognize those?
I do not.
And how about ltown@georgewbush.com, who
14 is that, do you know?
A. I do not. 15
16 Q. Okay. NOW, it says, subject, voter reg,
17 which I assume is registration, so voter
18 registration, fraud strategy conference calls.
19 Do you see that?
A. Yes, I do. 20
21 Q. And do you know anything about voter
22 registration fraud strategy conference calls?
D.C. 1800.4413376
MD .1800-539639
VA .1800752897
1 A.
2 know.
3 Q.
MariaCino
I did not participate and thus I
Page 147
do not
I mean did you know that there was such a
4 thing, that there were voter registration strategy
5 conference calls?
6 A. The only voter registration calls that I
7 recall had to do with registering new voters.
8 Q. Okay. And just to be clear here, have
9 you ever -- in your investigation for preparing
10 your declaration, did you talk to any of these
11 people--
A. No, I have not. 12
13 Q. -- concerning voter registration
14 conference calls?
A. No. 15
16 Q. Okay. If you turn forward in time, I'm
17 sort of going from back to front because I think
18 that's sort of the way --
A. That's okay. 19
20 Q. -- time moves here more or less. Go to
21 page RNC 000173.
22 Do you have that in front of you?
D.C . 18004413376
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1
2
A.
Q.
Maria Cino
I do.
Page 148
There's an E-mail toward the bottom from
3 Shawn Reinschmiedt. Who is that?
4 He works in our research department,
5 based on the return.
6
7
Q.
A.
I'm sorry, based on the return E-mail?
I'm sorry, based on research, slash,
8 communications. I think I've already testified
9 that I don't know who he is.
10
11
12
13
14
15
the
Q.
A.
Q.
A.
Bush
Q.
Okay. And then it's to Dave DinHerder?
Yes.
Who is that?
He is a regional political director for
campaign.
Okay. And then further down there's
16 somebody, Magan, Mike Magan?
17
18
19
20
21
22
A.
Q.
A.
Q.
A.
Q.
Yes.
Do you know who that is?
I do not.
DO you know where he works?
ohio GOP.
That's the Republican Committee of Ohio?
D.C. 18004413376
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Maria Cino
1 A. Ohio, yes.
Page 149
2 Q. And then down below that there's Mauk,
3 M-A-U-K. Do you know who that is?
4 A. I do not.
5 Q. Do you know where he works?
6 A. The Ohio Republican party.
7 Q. And the subject, Cuyahoga returned list?
8 A. Yes.
9 Q. Is that the list of returned mail that
10 was sent out to Cuyahoga county?
11
12
A.
Q.
I would have no way of knowing.
Okay. Now if you go to a page Bates
13 stamped number RNC 000158. Do you have that in
14 front of you?
A. Yes. 15
16 Q. If you go down -- well, it's an E-mail at
17 the bottom half of the page.
18
19
20
21
22
A.
Q.
A.
Q.
A.
Yes.
From c.
Guith.
Guith.
Yes.
D.C. 1801).441.3376
Guith?
Do you know who that is?
MD 1.800539631
VA 1.80075289C
1
2
3
Q.
A.
Q.
Maria Cino
who is that?
Page 150
He works on the George W. Bush campaign.
And it's to Tim Griffin, I think you've
4 testified about who that is.
5
6
A.
Q.
Yes.
I'm sorry, I'm in the wrong E-mail. The
7 one below it, from Tim Griffin to various people.
8
9
A.
Q.
Yes.
He refers to Jack Christopher. Do you
10 know who that is?
11
12
A.
Q.
I do not.
It says we've "tasked our IT person with
13 creating a match list between the BOE's return mail
14 list and the AB request list."
15 Do you know what the BOE's return mail
16 list is?
17
18
19
20
21
22
A.
Q.
A.
Q.
A.
Q.
Yes.
what's that?
It's the Board of Election.
Okay. And the AS request list?
Absentee ballot request list.
If you look at page RNC 000151.
D.C 18004413376
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MariaCino
Page 151
A. Yes. 1
2 Q. There's an E-mail at the top of the page,
3 Tim Griffin, and in the body of the E-mail,
4 actually, it refers to bodies. And then it says in
5 the second paragraph, "why don't you ask your peeps
6 in each state at issue if they have resources to do
7 this. "
8 Who are the peeps in each state?
9 A. I would only be able to speculate. I
10 would have no idea.
11 Q. Okay. Don't want you to speculate.
12 Now, just so I understand, just so I
13 understand E-mailese here, take a look at page --
14 maybe there's a better page, but this one will do,
15 RNC 000160.
A. Yes. 16
17 Q. You can look at the second to the last
18 sort of from/to. It's from coddy Johnson to
19 SReinschmiedt.
A. Yes. 20
21 Q. Okay. Now, there's an E-mail, after
22 SReinschmiedt at, it says rnchq.org.
D.C. 1800.4413376
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1
2
3
4
5
A.
Q.
A.
Q.
MariaCino
What does the rnchq designate?
Republican National Committee.
Headquarters?
Yes, I'm sorry, yes.
And then below it there's Magan at
6 ohiogop.org.
7 What does that designate?
A. ohio Republican Party.
Page 152
8
9 Q. Okay. And then there are some here that
10 have georgewbush.com.
11 . What does that designate?
A. George W. Bush campaign. 12
13 Q. Campaign? Now, on the very front page at
14 the very top it has a list of participants,
15 Chairman Gillespie, and you, Mike Duncan, Jim Dyke,
16 Tim Griffin, Jill Holtzman Vogel, Caroline Hunter.
17 Do you see those?
I do. 18
19 Q. Are these related to the E-mails below,
20 do you know?
I have no idea; 21
22 Q. And I think you've told us up until an
D.C. 1800441-3376
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MariaCino
1 hour ago you
Page 153
never received any of these E-mails or
2 saw them?
3 A. None that I can recollect. I receive
4 thousands of E-mails a week.
5 MR. NIELD5: Okay. I have nothing
6 further.
7 MR. BURCHFIELD: Thanks. Let me just
8 look at my notes.
9 (Discussion off the record at 10:06 p.m.)
10 (Deposition resumed at 10:08 p.m.)
11 EXAMINATION BY COUNSEL FOR DEFENDANT
12 BY MR. BURCHFIELD:
13 Q. I'll be brief.
14 Ms. Cino, Mr. Nields had asked you some
15 questions about the last two pages of Exhibit 13,
16 beginning on page 184. And in particular I'd like
17 to direct your attention to the E-mail from Lauren
18 Barnett dated september 30, 2004, to a number of
19 people.
20 Are you with me?
A. Yes. 21
22 Q. To the best of your knowledge, as of
D.C. 18004413376
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Maria Cino
1 September 30, 2004, had the
Page 154
Ohio Republican Party
2 announced either publicly or to anyone at the RNC
3 that it had planned to institute challenges to
4 voters on the basis of returned mail?
5
6
A.
Q.
I can't be positive of the time frame.
Let me ask you to look at the next page.
7 This E-mail refers to a conference call and on the
8 last page of this exhibit, with the last Bates
9 numbers 185, there's a list of people.
10 Do you recognize any of the people
11 there--
12
13
14
15
16
17
18
19
A.
Q.
Q.
A.
Q.
A.
Q.
Yes.
-- under suggested participants?
Yes.
who is Jill Holtzman Vogel?
She's our general -- chief counsel.
who is Caroline HUnter?
She is one of our lawyers at the RNC.
Are they, to your personal 'knowledge,
20 conversant with the requirements of the consent
21 decree in New Jersey?
22 A. Absolutely. They both have talked
D.C. 18004413376 .
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MariaCino
1 extensively on it and have specifically
Page 155
informed
2 each of our directors and their employees at the
3 RNC.
4 Q. Are they -- are they the people at the
5 RNC who were charged with enforcing, principally
6 charged with notifying and enforcing the compliance
7 within the RNC with that decree?
A. Yes, they are.
8
9 Q. Let me ask you to look at page 158, still
10 on Cino Exhibit 13. And I believe that Mr. Nields
11 asked you with regard to this page about the
12 reference to Cuyahoga returned list.
13 Do you see that?
Yes.
14
15 Q. And I think you said in response to his
16 question that you didn't know what list was being
17 referred to there.
A. Right. 18
19 Q. Let me ask you to look at, later down in
20 the E-mail chain, page 160, there's an E-mail there
21 dated October 5, 2004, from Robert Paduchik.
22 A. Yes.
D.C. 18004413376
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VA
1 Q.
2 high.
MarlaCino
Also subject, re, Cuyahoga
Page 156
returned list,
3 Can you tell from the context of that
4 E-mail list what list he's referring to when he
5 says cuyahoga returned'list?
6 A. This appears that the Cuyahoga return
7 list is from the Board of Elections, a mailing.
8 Q. Not the returns of the RNC mailings
9 within Cuyahoga County that you talked about
10 earlier?
11 A. Yes, not the returns that I talked of
12 earlier.
13 Q. And not the returns from the Ohio
14 Republican pa_rty list?
15 Not the returns from the Ohio Republican
16 Party list.
17 Q. Let me ask you to look -- Mr. Nields also
18 asked you some questions about the first few pages.
19 Page 149 at the bottom Mr. Paduchik, October 5,
20 2004, says, "I have just learned that summit County
21 has received 200 AB," absentee ballot?
22 A. Yes.
D.C. 1800-4413376
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1
2 sorry.
Maria Cino
MR. NIELDS: What page are we on?
Page 157
I'm
3 MR. BURCHFIELD: 149 at the bottom, still
4 Cino Exhibit 13.
5 THE WITNESS; Yes.
6 BY MR. BURCHFIELD:
7
Q, I have just learned that Summit County
8 has received 200 absentee ballot requests from 10-U
9 voters, paren, these are people the BOE, Board of
10 Elections, mails address confirmation forms to and
11 their return is undeliverable, close paren. If
12 this is true it is proof that people with
13 questionable registration are trying to vote
14 absentee.
15 Do you see that?
A, Yes. 16
17
18
19
20
21
22
Q. Having looked at the -- if that is true,
Ms. Cino, does that cause you concern?
A. No, it does not.
Q. Why not?
A. well, this appears
with regards to the board --
D.C. 18004413376
to be a discussion
Cuyahoga Board of
MD 1800-539-6398
VA 18007528979
1
2
Maria eino
Election list of returns, undeliverable
their mailing to do registered voters.
Page 158
mail from
And it
3 appears they have taken that list and are crossing
4 it with a list of absentee ballot requests, people
5 who have requested absentee ballots.
6 And there is a question as to whether or
7 not the Board of Elections list of undeliverables,
8 crossed with the absentee ballot requests, some of
9 the names are voter irregularities from the Board
10 of Elections. Thus, somebody would be requesting
11 an absentee ballot that the mailing from the Board
12 of Elections was returned and it's questionable.
13 Q. To your -- to your knowledge has the --
14 has the RNC undertaken -- does the RNC have a plan
15 to take any action with regard to this
16 cross-matching of undeliverable mailings with
17 absentee ballot requests?
18
19
A.
Q.
No, it does not.
If there were such a plan of action, who
20 would -- who would be the person that would need to
21 approve it?
22 A. It would have to be approved by our legal
D.C. 1.8004413376
MD 18005396398
VA. 18007528979
Maria Cino
1 counsel, Jill Holtzman and Caroline Hunter.
Page 159
Based
2 on what the consent decree said, they would deny
3 it.
4 MR. BURCHFIELD: Okay. Nothing further.
5 EXAMINATION BY COUNSEL FOR PLAINTIFF INTERVENOR
6 BY MR. NIELDS:
7 Q. I have another question.
B When did people at the RNC learn that the
9 Ohio Republican Party had obtained the Ohio BOE
10 list?
11 A. I don't believe -- I can't give you that
12 date.
13 Q. But are you saying it's before, it's
14 before this date?
15 MR. BURCHFIELD: What date?
16 BY MR. NIELDS:
17
18
Q.
A.
I think it's October 5th.
Based on this particular set of E-mails,
19 I don't think I can deduct that.
20 MR. NIELDS: Okay. I have nothing
21 further.
22 MR. BURCHFIELD: Thank you. Everyone
D.C. 1800.4413376
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Maria Cino
1
2
3
4
5
6
7
8
9
have a good evening. Off the record.
Page 160
- - -
(Deposition concluded at 10:17 p.m.)
10
11
12
13
14
15
16
17
18
19
20
21
22
D.C 1.8004413376
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MD 180053963'
VA 1800752.89
--
MariaCino
1 ACKNOWLEDGMENT OF DEPONENT
Page 161
2 I, MARIA CINO, do hereby acknowledge that I
3 have read and examined the foregoing one hundred
4 sixty (160) pages of testimony, and the same is a
5 true, correct and complete transcription of the
6 testimony given by me, and any changes and/or
7 corrections appear on the attached errata sheet
8 signed by me.
9
10
11
12
13
14
15
16
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18
19
20
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22
(Date)
D.C. 18004413376
MARIA CINO
MD 1800539639
VA 1800752897
MariaCino
1 ESQUIRE DEPOSITION SERVICES
2 1020 19th Street, Northwest
3 suite 620
4 Washington, D.C. 20036
5
6
7 Case Name: DNC v. RNC
ERRATA SHEET
8 Witness Name: MARIA CINO
9 Deposition Date; October 29, 2004
10 Job No.: 163933
11
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PAGE LINE
Signature
CORRECTION
Page 162
Date
D.C 1800441-3376
MD .1800539-639!
VA .1800752897!
1
2
MariaCino
CERTIFICATE OF STENOTYPE REPORTER - NOTARY
Page 163
PUBLIC
3 I, Sara A. Watt, Registered Professional Reporter,
4 the officer before whom the foregoing deposition
5 was taken, do hereby certify that the witness named
6 herein was duly sworn by me; that the foregoing
7 transcript is a true, correct, and complete record
8 of the testimony given1 that said testimony was
9 taken by me stenographically and thereafter reduced
10 to typewriting by me; and that I am neither counsel
11 for, related to, nor employed by any of the parties
12 to this litigation and have no interest, financial
13 or otherwise, in its outcome.
14 IN WITNESS WHEREOF, I have hereunto set
15 my hand and affixed my notarial seal.
16
17
18 Sara A. watt, Notary Public in
19 and for the District of Columbia
20 My Commission expires June 30, 2008.
21
22
D.C. 18004413376
MD 18005396398
VA 1800-752-8979
1
2
3
MariaCino
Bobby R. Burchfield, Esquire
McDermott, Will & Emery
600 Thirteenth Street, Northwest
Washington, D.C. 20005-3096
Re; DNe v. RNC
4 Deposition of MARIA CINO
5 Dear Mr. Burchfield;
Page 164
6 Enclosed for review is your copy of the above
referenced deposition. Please have the deponent
7 read the copy of the transcript and sign the
enclosed certificate of deponent. Also enclosed
8 is an errata sheet which the deponent should use to
note corrections and the reasons for such
9 corrections. This and any additional errata sheets
should be signed and dated by the deponent.
10
The deponent has thirty days in which to read
11 and sign the transcript. After the deponent has
reviewed the copy of the transcript, please return
12 the certificate of deponent and any errata sheets
to Esquire Deposition service, 1020 19th street,
13 Northwest, Suite 620, Washington, D.C., 20036.
14 Sincerely,
15
16
17
18
19
20
21
22
D.C 1800441-3376
Sara A. Watt
MD .18005396398
VA .18007528979
Maria Cino
A
Advancement 36:1782:7
AD 150:14,20
3:11 all5wer11 122:7
156:21
advice33:5 IIntifrand 32:12
ability 46:14
advise 129:13 33:10
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79:785:11
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allegations 58:8 157:21158:3
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amendmen.t 31:8
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MD 18005396398
VA .18007528979
MariaCino
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MD 18005396398
VA. 18007528979
Maria Cino
10:711:11,22 21:21 154:20 159:2
12:1,4,6,16 oolIlprehen,;ve 1:'OIWd..,47:8
13:4,14,19,21 141:22 116:5,8
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25:11,13,18,21 72:12143:15 54:18
26:2,9,2227:2 143:19 eonstanlly 73:5
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32:13,1633:17 126:21 24:5
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58:2061:1 eOlKerned 46:11 127:8
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78:13124;10 10:10 copieI56:20
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complete 69;15 coment27:4 101:1111:3
161:5163:7 47:15 48:8 164:6,7,11
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compUance 109:13117:5 52:1253:21
155:6 117:19,22 54:655:8
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134:20 51:5,756:19
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100:16101:3 100:18104:22
102:9110:7 116:15119:16
113:21115:2 121:16122:19
115:19123:3 128:2147:10
149:7,10 decree 27:5
MD - 1-800-5396398
VA -1-800-752-8979
MariaCino
47:1548:8 description. 115:12,13
8L-22 109:13 34:20 120:15,16
117:5,19,22 de.iGnate 152:1 122:5130:7,11
118:2,14 152:7,11 133:20 135:4
154:21155:7 desk68:5 138:18,19,21
159:2 detennine89:19 138:22145:22
deduct 159:19 90:4 96:17 14il:13
DEFENDANT 97:12109:5 dlreclon 15:13
4:1153:11
_ ..
16:15 21:19
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degree 11:2 24:6 115:3 l\l.reCtII101:13
del1vered 102:16 dde\1niniag 101:16
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41:2244:2 develop27.'3,tO 19:19,2220:10
51:2252:1 developed 28:6 19:12
53:558:4 74:1589,16 80:16
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31:2142:13,20 22:12 116:21
44:6 Dick45:$ dhcussed30:10
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MD 18005396398
VA 18007528979

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