Greg Flynn

2826 Barmetter Street

Raleigh, North Carolina 27607

September13,2014

ViaU.S.CertifiedMailand
email(denise@voterintegrityproject.comanddstetter@att.net)

Ms.DeniseStetter
114NormandaleDrive
Cary,NorthCarolina27513

Re:StetterNoticeofCeaseandDesistandFlynnNoticetoPreserveElectronicEvidence

DearMs.Stetter:

Iaminreceipt of yourSeptember12, 2014NoticeofCeaseandDesistregardingmy

blog post of July 15, 2014. Thank you for providing me with new facts regarding
requests to film at North Carolina polling places around July 15, 2014. Perhaps the
easiest way to respond to your list of my alleged defamatory comments is to address
themonebyone.Iquoteyourletter:

Thestatement:Whattheywereconspiringtodowouldhavebeenaviolationofatleasttwo
North Carolina laws, is entirely false. There was no conspiracy. There is and never was
evidence of a conspiracy. DeLancy did not inform me, Denise Stetter, at any time that he was
going to make a request to lm at precinct 0142. DeLancy did not at any time seek my
permissiontolmatprecinct0142.

You have provided me with new information stating, DeLancy did not
informme,DeniseStetter,atanytimethathewasgoingtomakearequest
tolmatprecinct0142.Assumingthisistrue,andforpurposesofyour
request,Iamcurrentlywillingtomakethatassumption,Iamrevisingthe
original post to read as follows: These actions would have been a
violationofatleasttwoNorthCarolinalaws.

Yourstatementthatincludes:...onewrittenin1953tocountertheintimidationtacticsofthe
KKK. (General Statutes Chapter 14, Article 4A, Prohibited Secret Societies and Activities, and
Ms.DeniseStetter
September13,2014
Page2

142.8 Wearing of masks, hoods, etc., on public property. in particular) is both highly
inammatoryanddefamatory.

His response came via Public Information Officer Josh Lawson who
restated the prohibitions and added that the wearing of masks on public
property(wherethepollingplaceislocated)isalsoprohibitedbylaw,one
written in 1953 to counter the intimidation tactics of the KKK. (General
Statutes Chapter 14, Article 4A, Prohibited Secret Societies and
Activities, and 142.8 Wearing of masks, hoods, etc., on public
property.inparticular)isanaccuratestatementoffact.

Your statement: Stetter seemed to have trouble separating her role as chief precinct judge
from her role as communications director for the Voter Integrity Project, based on the
descriptionsgivenbyPoucherandSimsisentirelyfalse.ThefewstatementsthatIdidmaketo
anymemberoftheWakeCountyBoardofElectionsmadeitveryclearthatIwasnotawarethat
DeLancy had made a request to lm at precinct 0142 and that I would not have granted
permission even if he had. I specically stated to Sims that I especially would never have
granted permission because of an appearance of impropriety, thereby clearly indicating that I
was perfectly aware of the difference between my role as a chief precinct judge and
communicationsdirectorfortheVoterIntegrityProject.

This statement is my opinion based upon the descriptions given by

Poucher and Sims. It remains my opinion. If you have specific written
communications between you and Mr. Sims making these statements, I
amhappytoreviewthem.

Yourstatement:...WakeBoardChairDavidRobinsonhadreiteratedtoDeLancybyphonethe
illegality and folly of the Voter Integrity Project proposal and received some assurance that
DeLancy and Stetter understood the prohibition. is false. I was not party to any
communicationbetweenDavidRobinsonandJayDeLancyonthismatter,nordidItakepartin
providingassurancethatIunderstoodanysuchprohibition.

This statement specifically references reiterated to DeLancy and does

not state that you were a party to communications between David
Robinson and Jay DeLancy or that you personally provided any
assurance.

Ms.DeniseStetter
September13,2014
Page3

Your statement: ..with the complicity of a chief judge is entirely false and especially
egregious.IwasnotawareoftherequestmadebyDeLancy,norIdidnotgivemypermissionto
anyoneatanytimetolmwithinprecinct0142.

As noted above, you have provided new information. Assuming this is

true,andforpurposesofyourrequest,Iamcurrentlywillingtomakethat
assumption,Iamrevisingtheoriginalposttoreadasfollows:DeLancys
impetuous demands, sloppy understanding of law and apparent
cluelessnessabouttheintimidationfactorofmaskedpeoplewithcameras
at the polling place, hardly supports claims to the mantle of voter
integrity.

Yourstatement:...AperusalofthesocialmediafeedsofDeLancyandStetterandtheVoter
IntegrityProjectsuggeststhatDeLancyunderstandswellwhatheisdoingandthatindignation
is cover for intimidation. maliciously includes me in a statement about DeLancy, and
subsequentlyinyetanotherfalseaccusationofintimidation.

This statement is my opinion based upon perusal of the social media

feeds of DeLancy and Stetter and the Voter Integrity Project. It remains
my opinion. Further, it does not state that you understand what you are
doing.

I believe these responses fully address your list of my alleged defamatory comments,
baseduponthenewinformationyouprovided.

AsyoutransmittedaNoticetoCeaseandDesistindicatingpotentiallegalaction,let
meresponddirectlywiththeattachedNoticetoPreserveElectronicEvidence.

Sincerely,

GregFlynn

Attachment:NoticetoPreserveElectronicEvidence
NoticetoPreserveElectronicEvidence

ViaU.S.CertifiedMailand
email(denise@voterintegrityproject.comanddstetter@att.net)

Ms.DeniseStetter
114NormandaleDrive
Cary,NorthCarolina27513

DearMs.Stetter:

This letter hereby provides notice that you are not to destroy, conceal or alter in any
manner whatsoever any or all potential evidence, documents, information, paper or
electronic data and/or other tangible items pertaining or relevant to or property
discoverable to the events and actions surrounding requests to film at any North
Carolina polling place on or about July 15, 2014, including but not limited to, all
computers and cell phones owned by you, utilized by you, or in your control or
possession.

Thisnoticeincludes,but is not limitedto, alldatagenerated and/orstoredonanyand

all computers and cellular telephones owned or used by Denise Stetter; all data stored
on any and all other electronic storage media of any type such as hard disks, floppy
disks,CDROMs,DVDs,flashdrives,backuptapes,onlinebackupservicesoranyother
storage media or service; all emails; all instant messages; all SMS text messages; all
audio data such as voicemail, tape recordings; and all photographs, videos, writing or
other documentary material of any nature found or stored on his computers, cellular
telephones, or Internet accounts. This notice also applies specifically, but without
limitation, to any and all emails, instant messages, SMS text messages, email accounts,
social media accounts, blogs, Internet addresses and/or Internet accounts utilized or
established by Denise Stetter, whether or not the data is stored locally on a computer
used by you or stored by a third party on an Internet server such as Gmail.com,
Yahoo.com,Hotmail.com,oranyotherthirdpartyInternetservice.

With regard to electronic data created subsequent to the date of delivery of this letter,
relevant evidence is not to be destroyed and you must take whatever steps are
appropriate to avoid destruction of evidence. It is anticipated that these items will be
usedinevidenceinanyforthcominglitigation.

In order to assure that your obligation to preserve documents and things will be met,
please forward a copy of this letter to any and all persons and entities with custodial
responsibilitiesfortheitemsreferredtoherein.