EXHIBIT B

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IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
ALEXANDRIA DIVISION
THE DEMOCRATIC PARTY OF )
VIRGINIA, )
)
Plaintiff, )
)
)
)
in his Civil Action No. 1: l3"c.v-O 1218-CMH-TRJ
capacity as Chairman ofthc Virginia State )
Boal'd of Elections; KlMBERL Y BOWERS, )
in her capacity as Vice-Chair of the Virginia )
State Board of Elections; DON PALMER, in)
his capacity as Secretary of the Virginia State)
Board of Elections; ROBERT F. )
MCDONNELL, in his capacity as Governor )
of Virginia; and KENNETH T. )
CUCCINELLI, II, in his capacity as )
Attorney General of Virginia, )
)
Defendants. )
DECLARATION OF CARLA A. JONES
I, Carla A. Jones, states that 1 have personal knowledge of the matters set forth in
this Declaration and, if sworn as a witness, would testifY as follows:
1. I am 49 years of age and reside at 8309 Turner Forest Road, Henrico,
Virginia with my husband Jeryle A. Jones Sr. We have two adult children and we will
celebrate our 26th wedding anniversary this month. I have lived, in Virginia since
October 2004. I registered to vote in the Commonwealth of Virginia in October 2004 and
have voted in every election since. My husband and I lived in Prince George's County
from 2004 to 2012. Last year, we were able to move into a home, we built in Henrico,
Virginia.
2. I am employed as a contracting officer for the federal government and
have been working in Virginia 2005. I have a Bachelor's degree in Human
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services/minor in Psychology from Upper Iowa University and a :MBA with a
concentration in Criminal Justice from St. Leo University. My husband and I lived in
Fort Campbell, Kentucky from September 2002 until October 2004, where he was a
Sargent First Class in the (Active Duty) U.S. Army. While residing at Fort Campbell,
Kentucky, I was a special education teacher at several juvenile facilities located in
Tennessee under the same Agency and a substitute teacher in Kentucky with DOD school
on the base. In October 2004, my husband and I received Military orders to move to Fort
Lee, Virginia, where he became a First Sargent on the Post. In 2008, he retired and
presently is the Executive Officer the Logistics Officer at the Army Logistics University
(ALU) at Fort Lee, Virginia.
3. On Saturday, September 28, 2013, both my husband and I received voter
cancellation notices from the Office of Voter Registration of the County of Henrico. The
notice informed us that we were no longer entitled to be registered to vote in the
Commonwealth of Virginia.
4. On Monday, September 30, 2013, I contacted the Office of Voter
Registration of the Henrico County via telephone, asking to the responsible person in the
office, which I spoke to (Mrs. Susan Lee). I related to her (Mrs. Lee) why I was no
longer entitled to be registered to vote in the Commonwealth of Virginia. She (Mrs. Lee)
stated that Kentucky Registered Office sent the information to them stating that I was
registered in Kentucky. I also informed Mrs. Lee that I am registered in to vote in the
State of Virginia and work, as well as, pays property taxes on two homes and several cars
with the State of Virginia.
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5, After speaking with Mrs. Lee, I was not satisfied with her reason/excuse
for the cancellation notice from the Henrico County Registered office, so I took it further
and contacted another office, where I was transferred Mr. Ellis, who I was told that he
would be the point of contact for the cancellation issue. I explained the above mention
information concerning my voting cancellation to Mr. Ellis, as I did to Mrs. Lee. He
stated that, "I went to Kentucky to vote within the last years and came back to Virginia,
and I was in their (Kentucky) voting system." I stated to him that is not a true statement.
My husband and I both live, own two homes and several motor vehicles; which we pay
property tax on both, as well as, we both work in the state of Virginia and pays states
taxes. I also told him that that I subsequently registered to vote in Virginia for the last 9
years. Mr. Ellis informed me that when "I left Kentucky, I should have cancelled my
voter registration." I told him that there was no such requirement and my voter
registration in Virginia is valid for approximately nine years.
6. I was told that I would be put back on the voter registration rolls; which, I
received my voter registration card on October 2, 2013.
7. When my voter registration was cancelled because I had registered to vote
Kentucky approximately 9 years ago; I am very angry and I feel as though my dignity, as
well as my rights has been stripped from me. Not to mention feeling as if, I had
committed a crime (traud). I also wanted to contact the media (news station) to let them
know about what happened. It is my opinion that my voting cancellation seemed like
fraud and voters should know this is going on, especially as many of them might not
check their mail or have any idea that their voting registration has cancelled until they try
to vote on the day of election.
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8. I declare Wider penalty of perjury under 28 U.s.c. 1746 that the
foregoing is true and correct.
Executed on October 10, 2013.
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