Case 1:20-cv-00708-CCC Document 33 Filed 07/10/20 Page 1 of 25

IN THE UNITED STATES DISTRICT COURT

FOR THE MIDDLE DISTRICT OF PENNSYLVANIA

JUDICIAL WATCH, INC., :

Plaintiff : No. 1:20-CV-0708
:
v. : Judge Conner
:
COMMONWEALTH OF : Electronically Filed Document
PENNSYLVANIA, KATHY : Complaint Filed 04/29/20
BOOCKVAR, BUCKS COUNTY :
COMMISSION, BUCKS COUNTY :
BOARD OF ELECTIONS, BUCKS :
COUNTY REGISTRATION :
COMMISSION, THOMAS FREITAG, :
CHESTER COUNTY COMMISSION, :
CHESTER COUNTY BOARD OF :
ELECTIONS, CHESTER COUNTY :
REGISTRATION COMMISSION, :
SANDRA BURKE, DELAWARE :
COUNTY COUNCIL, DELAWARE :
COUNTY BOARD OF ELECTIONS, :
DELAWARE COUNTY :
REGISTRATION COMMISSION and :
LAUREEN HAGAN, :
Defendants :
:
v. :
:
COMMON CAUSE PENNSYLVANIA :
and LEAGUE OF WOMEN VOTERS :
OF PENNSYLVANIA, :
Intervenor Defendants :

ANSWER AND AFFIRMATIVE DEFENSES

Kathy Boockvar, Secretary of the Commonwealth of Pennsylvania, and the

Commonwealth of Pennsylvania (“Defendants”), by and through their undersigned

 Case 1:20-cv-00708-CCC Document 33 Filed 07/10/20 Page 2 of 25

counsel, hereby file this Answer and Affirmative Defenses to the Complaint filed

by Plaintiff, Judicial Watch, Inc. (“Plaintiff”), as follows.

1. DENIED. The allegations of this Paragraph constitute legal

conclusions to which no responsive pleading is required. To the extent that the

allegations are considered factual in nature, they are DENIED.

2. DENIED. The allegations of this Paragraph constitute legal

conclusions to which no responsive pleading is required. To the extent that the

allegations are considered factual in nature, they are DENIED.

3. DENIED. The allegations of this Paragraph constitute legal

conclusions to which no responsive pleading is required. To the extent that the

allegations are considered factual in nature, they are DENIED.

4. ADMITTED in part, DENIED in part. It is ADMITTED only that

Plaintiff is Judicial Watch, Inc. Defendants are without knowledge or information

sufficient to form a belief on the truth or falsity of the remaining allegations of this

Paragraph so they are DENIED.

5. DENIED. The allegations of this Paragraph constitute legal

conclusions to which no responsive pleading is required. To the extent that the

allegations are considered factual in nature, they are DENIED.

6. ADMITTED in part, DENIED in part. It is ADMITTED that Kathy

Boockvar is Secretary of the Commonwealth and was so appointed in January

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2019 by Governor Wolf. The remaining allegations of this Paragraph constitute

legal conclusions to which no responsive pleading is required. To the extent that

the allegations are considered factual in nature, they are DENIED.

7. DENIED. This Paragraph is directed to a party other than the

answering Defendants, such that no responsive pleading is required. To the extent

that a response is deemed appropriate, the allegations of this Paragraph constitute

legal conclusions to which no responsive pleading is required.

8. DENIED. This Paragraph is directed to a party other than the

answering Defendants, such that no responsive pleading is required. To the extent

that a response is deemed appropriate, the allegations of this Paragraph constitute

legal conclusions to which no responsive pleading is required.

9. DENIED. This Paragraph is directed to a party other than the

answering Defendants, such that no responsive pleading is required. To the extent

that a response is deemed appropriate, the allegations of this Paragraph constitute

legal conclusions to which no responsive pleading is required.

10. DENIED. This Paragraph is directed to a party other than the

answering Defendants, such that no responsive pleading is required. To the extent

that a response is deemed appropriate, the allegations of this Paragraph constitute

legal conclusions to which no responsive pleading is required.

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11. DENIED. This Paragraph is directed to a party other than the

answering Defendants, such that no responsive pleading is required. To the extent

that a response is deemed appropriate, the allegations of this Paragraph constitute

legal conclusions to which no responsive pleading is required.

12. DENIED. This Paragraph is directed to a party other than the

answering Defendants, such that no responsive pleading is required. To the extent

that a response is deemed appropriate, the allegations of this Paragraph constitute

legal conclusions to which no responsive pleading is required.

13. DENIED. This Paragraph is directed to a party other than the

answering Defendants, such that no responsive pleading is required. To the extent

that a response is deemed appropriate, the allegations of this Paragraph constitute

legal conclusions to which no responsive pleading is required.

14. DENIED. This Paragraph is directed to a party other than the

answering Defendants, such that no responsive pleading is required. To the extent

that a response is deemed appropriate, the allegations of this Paragraph constitute

legal conclusions to which no responsive pleading is required.

15. DENIED. This Paragraph is directed to a party other than the

answering Defendants, such that no responsive pleading is required. To the extent

that a response is deemed appropriate, the allegations of this Paragraph constitute

legal conclusions to which no responsive pleading is required.

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16. DENIED. This Paragraph is directed to a party other than the

answering Defendants, such that no responsive pleading is required. To the extent

that a response is deemed appropriate, the allegations of this Paragraph constitute

legal conclusions to which no responsive pleading is required.

17. DENIED. This Paragraph is directed to a party other than the

answering Defendants, such that no responsive pleading is required. To the extent

that a response is deemed appropriate, the allegations of this Paragraph constitute

legal conclusions to which no responsive pleading is required.

18. DENIED. This Paragraph is directed to a party other than the

answering Defendants, such that no responsive pleading is required. To the extent

that a response is deemed appropriate, the allegations of this Paragraph constitute

legal conclusions to which no responsive pleading is required.

19. DENIED. The allegations of this Paragraph constitute legal

conclusions to which no responsive pleading is required. To the extent that the

allegations are considered factual in nature, they are DENIED.

20. DENIED. The allegations of this Paragraph constitute legal

conclusions to which no responsive pleading is required. To the extent that the

allegations are considered factual in nature, they are DENIED.

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21. DENIED. The allegations of this Paragraph constitute legal

conclusions to which no responsive pleading is required. To the extent that the

allegations are considered factual in nature, they are DENIED.

22. DENIED. The allegations of this Paragraph constitute legal

conclusions to which no responsive pleading is required. To the extent that the

allegations are considered factual in nature, they are DENIED.

23. DENIED. The allegations of this Paragraph constitute legal

conclusions to which no responsive pleading is required. To the extent that the

allegations are considered factual in nature, they are DENIED.

24. DENIED. The allegations of this Paragraph constitute legal

conclusions to which no responsive pleading is required. To the extent that the

allegations are considered factual in nature, they are DENIED.

25. DENIED. The allegations of this Paragraph constitute legal

conclusions to which no responsive pleading is required. To the extent that the

allegations are considered factual in nature, they are DENIED.

26. DENIED. The allegations of this Paragraph constitute legal

conclusions to which no responsive pleading is required. To the extent that the

allegations are considered factual in nature, they are DENIED.

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 Case 1:20-cv-00708-CCC Document 33 Filed 07/10/20 Page 7 of 25

27. DENIED. The allegations of this Paragraph constitute legal

conclusions to which no responsive pleading is required. To the extent that the

allegations are considered factual in nature, they are DENIED.

28. DENIED. The allegations of this Paragraph constitute legal

conclusions to which no responsive pleading is required. To the extent that the

allegations are considered factual in nature, they are DENIED.

29. DENIED. Defendants are without knowledge or information sufficient

to form a belief on the truth or falsity of the allegations of this Paragraph so they

are DENIED.

30. DENIED. Defendants are without knowledge or information sufficient

to form a belief on the truth or falsity of the allegations of this Paragraph so they

are DENIED.

31. DENIED. Defendants are without knowledge or information sufficient

to form a belief on the truth or falsity of the allegations of this Paragraph so they

are DENIED. By way of further response, the implication that the Defendants are

not complying with the National Voter Registration Act (NVRA) is DENIED.

32. DENIED. Defendants are without knowledge or information sufficient

to form a belief on the truth or falsity of the allegations of this Paragraph so they

are DENIED. By way of further response, the implication that the Defendants are

not complying with the NVRA is DENIED.

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33. DENIED. This Paragraph contains legal conclusions to which no

responsive pleading is required. Those legal conclusions are DENIED. Defendants

are without knowledge or information sufficient to form a belief on the truth or

falsity of the remaining allegations of this Paragraph so they are DENIED. By way

of further response, the implication that the Defendants are not complying with the

NVRA is DENIED.

34. ADMITTED.

35. ADMITTED in part, DENIED in part. It is ADMITTED that the EAC

published the response it received from the Commonwealth to the voter

registration survey, and that the EAC has made the survey instrument available at

the link alleged, as well as “EAVS Datasets Version 1.2 (released February 18,

2020). The survey instrument and survey responses are documents that speak for

themselves and any characterizations by the Plaintiff are DENIED. The remaining

allegations of this Paragraph are DENIED.

36. DENIED. Defendants are without knowledge or information sufficient

to form a belief on the truth or falsity of the allegations of this Paragraph so they

are DENIED.

37. DENIED. The allegations of this Paragraph constitute legal

conclusions to which no responsive pleading is required. To the extent that the

allegations are considered factual in nature, they are DENIED.

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38. DENIED. The EAC survey instrument is a document that speaks for

itself. Plaintiff’s characterizations of the document are DENIED.

39. ADMITTED in part, DENIED in part. It is ADMITTED that the

Commonwealth initially reported that eight (8) registrations had been removed in

Bucks County. It is DENIED that this information is accurate. The Defendants

have submitted an amended survey response to the EAC to correct this inaccuracy,

and the amended survey response to question A9e reflects that 15,714 registrations

had been removed in Bucks County during the most recent two-year reporting

period. A true and correct copy of the spreadsheet reflecting the amended numbers

submitted to the EAC by the Commonwealth is attached hereto as Exhibit “A.”

40. ADMITTED in part, DENIED in part. It is ADMITTED that the

Commonwealth initially reported that five (5) registrations had been removed in

Chester County. It is DENIED that this information is accurate. The Defendants

have submitted an amended survey response to the EAC to correct this inaccuracy,

and the amended survey response to question A9e reflects that 11,519 registrations

had been removed in Chester County during the most recent two-year reporting

period. See Exhibit “A.”

41. ADMITTED in part, DENIED in part. It is ADMITTED that the

Commonwealth initially reported that four (4) registrations had been removed in

Delaware County. It is DENIED that this information is accurate. The Defendants

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have submitted an amended survey response to the EAC to correct this inaccuracy,

and the amended survey response to question A9e reflects that 20,968 registrations

had been removed in Delaware County during the most recent two-year reporting

period. See Exhibit “A.”

42. ADMITTED. By way of further response, the EAC report is a public

document that speaks for itself.

43. DENIED. The allegations of this Paragraph constitute legal

conclusions to which no responsive pleading is required. To the extent that the

allegations are considered factual in nature, they are DENIED. By way of further

response, Defendants’ hereby incorporate their answers to Paragraphs 39 through

41, supra.

44. DENIED. The allegations of this Paragraph constitute legal

conclusions to which no responsive pleading is required. To the extent that the

allegations are considered factual in nature, they are DENIED. By way of further

response, Defendants’ hereby incorporate their answers to Paragraphs 39 through

41, supra.

45. DENIED. The allegations of this Paragraph constitute legal

conclusions to which no responsive pleading is required. To the extent that the

allegations are considered factual in nature, they are DENIED. By way of further

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response, Defendants’ hereby incorporate their answers to Paragraphs 39 through

41, supra.

46. DENIED. The allegations of this Paragraph constitute legal

conclusions to which no responsive pleading is required. To the extent that the

allegations are considered factual in nature, they are DENIED. By way of further

response, Defendants’ hereby incorporate their answers to Paragraphs 39 through

41, supra.

47. DENIED. The allegations of this Paragraph constitute legal

conclusions to which no responsive pleading is required. To the extent that the

allegations are considered factual in nature, they are DENIED. By way of further

response, the article cited in this Paragraph is a document that speaks for itself and

Plaintiff’s characterizations of the same are DENIED.

48. DENIED. The allegations of this Paragraph constitute legal

conclusions to which no responsive pleading is required. To the extent that the

allegations are considered factual in nature, they are DENIED. By way of further

response, this allegation is directed at a DENIED. This Paragraph is directed to a

party other than the answering Defendants, such that no responsive pleading is

required. Defendants are also without knowledge or information sufficient to form

a belief as to the truth or falsity of the allegations of this Paragraph, so they are

DENIED.

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49. DENIED. The allegations of this Paragraph constitute legal

conclusions to which no responsive pleading is required. To the extent that the

allegations are considered factual in nature, they are DENIED.

50. ADMITTED in part, DENIED in part. It is ADMITTED that said

information appears on the website, but Defendants DENY Plaintiff’s

characterizations of that information.

51. DENIED. Defendants are without knowledge or information sufficient

to form a belief on the truth or falsity of the allegations of this Paragraph so they

are DENIED.

52. DENIED. The allegations of this Paragraph constitute legal

conclusions to which no responsive pleading is required. To the extent that the

allegations are considered factual in nature, they are DENIED.

53. DENIED. Defendants are without knowledge or information sufficient

to form a belief on the truth or falsity of the allegations of this Paragraph so they

are DENIED. By way of further response, it is DENIED that Judicial Watch’s

analysis is accurate. See Paragraphs 39 through 41, supra.

54. DENIED. Defendants are without knowledge or information sufficient

to form a belief on the truth or falsity of the allegations of this Paragraph so they

are DENIED. By way of further response, it is DENIED that Judicial Watch’s

analysis is accurate. See Paragraphs 39 through 41, supra.

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55. DENIED. Defendants are without knowledge or information sufficient

to form a belief on the truth or falsity of the allegations of this Paragraph so they

are DENIED. By way of further response, it is DENIED that Judicial Watch’s

analysis is accurate. See Paragraphs 39 through 41, supra.

56. DENIED. By way of further response, it is DENIED that Judicial

Watch’s analysis is accurate. See Paragraphs 39 through 41, supra.

57. DENIED. Defendants are without knowledge or information sufficient

to form a belief on the truth or falsity of the allegations of this Paragraph so they

are DENIED. By way of further response, it is DENIED that Judicial Watch’s

analysis is accurate. See Paragraphs 39 through 41, supra

58. DENIED. Defendants are without knowledge or information sufficient

to form a belief on the truth or falsity of the allegations of this Paragraph so they

are DENIED. By way of further response, it is DENIED that Judicial Watch’s

analysis is accurate. See Paragraphs 39 through 41, supra

59. ADMITTED in part, DENIED in part. ADMITTED that Defendants

received copies of the letters. Defendants have no knowledge or information

regarding the truth or falsity of the remaining allegations, so they are DENIED.

60. DENIED. The letters referenced in this Paragraph are documents that

speak for themselves and Plaintiff’s characterizations of those documents are

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DENIED. By way of further response, it DENIED that the allegations set forth in

Plaintiff’s letters are true or accurate.

61. DENIED. The letters referenced in this Paragraph are documents that

speak for themselves and Plaintiff’s characterizations of those documents are

DENIED. By way of further response, it is DENIED that the allegations set forth

in Plaintiff’s letters are true or accurate.

62. DENIED. The letters referenced in this Paragraph are documents that

speak for themselves and Plaintiff’s characterizations of those documents are

DENIED. By way of further response, it is DENIED that the allegations set forth

in Plaintiff’s letters are true or accurate.

63. DENIED. The letter referenced in this Paragraph is a document that

speaks for itself and Plaintiff’s characterizations of the document are DENIED.

64. DENIED. The letter referenced in this Paragraph is a document that

speaks for itself and Plaintiff’s characterizations of the document are DENIED.

65. DENIED. The allegations of this Paragraph constitute legal

conclusions to which no responsive pleading is required. To the extent that the

allegations are considered factual in nature, they are DENIED.

66. DENIED. The letter referenced in this Paragraph is a document that

speaks for itself and Plaintiff’s characterizations of the document are DENIED.

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67. DENIED. The letter referenced in this Paragraph is a document that

speaks for itself and Plaintiff’s characterizations of the document are DENIED.

68. DENIED. The letter referenced in this Paragraph is a document that

speaks for itself and Plaintiff’s characterizations of the document are DENIED.

69. DENIED. Defendants are without knowledge or information sufficient

to form a belief on the truth or falsity of the allegations of this Paragraph so they

are DENIED.

70. DENIED. The letter referenced in this Paragraph is a document that

speaks for itself and Plaintiff’s characterizations of the document are DENIED.

71. DENIED. The allegations of this Paragraph constitute legal

conclusions to which no responsive pleading is required. To the extent that the

allegations are considered factual in nature, they are DENIED.

72. DENIED. Defendants are without knowledge or information sufficient

to form a belief on the truth or falsity of the allegations of this Paragraph so they

are DENIED.

73. DENIED. Defendants are without knowledge or information sufficient

to form a belief on the truth or falsity of the allegations of this Paragraph so they

are DENIED.

74. DENIED. The letter referenced in this Paragraph is a document that

speaks for itself and Plaintiff’s characterizations of the document are DENIED.

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75. DENIED. The allegations of this Paragraph constitute legal

conclusions to which no responsive pleading is required. To the extent that the

allegations are considered factual in nature, they are DENIED. By way of further

response, the letter referenced in this Paragraph is a document that speaks for itself

and Plaintiff’s characterizations of the document are DENIED.

76. DENIED. Defendants are without knowledge or information sufficient

to form a belief on the truth or falsity of the allegations of this Paragraph so they

are DENIED. By way of further response, the implication that the Defendants

violated the law is DENIED.

77. DENIED. Defendants are without knowledge or information sufficient

to form a belief on the truth or falsity of the allegations of this Paragraph so they

are DENIED.

78. DENIED. Defendants are without knowledge or information sufficient

to form a belief on the truth or falsity of the allegations of this Paragraph so they

are DENIED.

79. DENIED. Defendants are without knowledge or information sufficient

to form a belief on the truth or falsity of the allegations of this Paragraph so they

are DENIED.

80. DENIED. The letter referenced in this Paragraph is a document that

speaks for itself and Plaintiff’s characterizations of the document are DENIED.

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81. DENIED. The letter referenced in this Paragraph is a document that

speaks for itself and Plaintiff’s characterizations of the document are DENIED.

82. DENIED. The allegations of this Paragraph constitute legal

conclusions to which no responsive pleading is required. To the extent that the

allegations are considered factual in nature, they are DENIED. By way of further

response, the letter referenced in this Paragraph is a document that speaks for itself

and Plaintiff’s characterizations of the document are DENIED.

83. DENIED. The allegations of this Paragraph constitute legal

conclusions to which no responsive pleading is required. To the extent that the

allegations are considered factual in nature, they are DENIED. By way of further

response, the letter referenced in this Paragraph is a document that speaks for itself

and Plaintiff’s characterizations of the document are DENIED.

84. DENIED. The allegations of this Paragraph constitute legal

conclusions to which no responsive pleading is required. To the extent that the

allegations are considered factual in nature, they are DENIED.

85. DENIED. Defendants are without knowledge or information sufficient

to form a belief on the truth or falsity of the allegations of this Paragraph so they

are DENIED.

86. DENIED. The allegations of this Paragraph constitute legal

conclusions to which no responsive pleading is required. To the extent that the

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allegations are considered factual in nature, they are DENIED. By way of further

response, it is DENIED that Judicial Watch was “compelled” by Defendants to do

anything.

87. DENIED. The allegations of this Paragraph constitute legal

conclusions to which no responsive pleading is required. To the extent that the

allegations are considered factual in nature, they are DENIED. By way of further

response, it is DENIED that Judicial Watch was “compelled” by Defendants to do

anything.

88. DENIED. The allegations of this Paragraph constitute legal

conclusions to which no responsive pleading is required. To the extent that the

allegations are considered factual in nature, they are DENIED.

89. DENIED. The allegations of this Paragraph constitute legal

conclusions to which no responsive pleading is required. To the extent that the

allegations are considered factual in nature, they are DENIED.

90. DENIED. The allegations of this Paragraph constitute legal

conclusions to which no responsive pleading is required. To the extent that the

allegations are considered factual in nature, they are DENIED.

91. DENIED. The allegations of this Paragraph constitute legal

conclusions to which no responsive pleading is required. To the extent that the

allegations are considered factual in nature, they are DENIED.

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92. DENIED. The allegations of this Paragraph constitute legal

conclusions to which no responsive pleading is required. To the extent that the

allegations are considered factual in nature, they are DENIED.

93. DENIED. The allegations of this Paragraph constitute legal

conclusions to which no responsive pleading is required. To the extent that the

allegations are considered factual in nature, they are DENIED.

94. DENIED. The allegations of this Paragraph constitute legal

conclusions to which no responsive pleading is required. To the extent that the

allegations are considered factual in nature, they are DENIED.

COUNT I

95. The foregoing Paragraphs are hereby incorporated by reference as if

set forth more fully herein.

96-100. The allegations of Paragraphs 96 through 100 constitute legal

conclusions to which no responsive pleading is required. To the extent that the

allegations are considered factual in nature, they are DENIED.

COUNT II

101. The foregoing Paragraphs are hereby incorporated by reference as if

set forth more fully herein.

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102-105. The allegations of Paragraphs 102 through 105 constitute legal

conclusions to which no responsive pleading is required. To the extent that the

allegations are considered factual in nature, they are DENIED.

It is DENIED that the Plaintiff is entitled to relief.

AFFIRMATIVE DEFENSES

FIRST AFFIRMATIVE DEFENSE

Plaintiff has not stated a claim upon which relief can be granted.

SECOND AFFIRMATIVE DEFENSE

Defendants have, at all times, acted reasonably and in good faith.

THIRD AFFIRMATIVE DEFENSE

This case is not justiciable.

FOURTH AFFIRMATIVE DEFENSE

Defendants are improper Parties to this action.

FIFTH AFFIRMATIVE DEFENSE

Defendants, at all times, have complied with the NVRA.

SIXTH AFFIRMATIVE DEFENSE

Defendants conduct a general program that makes a reasonable effort to

remove the names of ineligible voters from the officials lists of eligible voters by

reason of death or change of address as required by the NVRA.

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SEVENTH AFFIRMATIVE DEFENSE

Defendants’ program is in compliance with Pennsylvania and federal law.

EIGHTH AFFIRMATIVE DEFENSE

Defendants have made available all records, as required under the law.

NINTH AFFIRMATIVE DEFENSE

Defendants did not cause the Plaintiff any harm or damages.

TENTH AFFIRMATIVE DEFENSE

Plaintiff did not suffer any damages and/or its damages are not actionable

and/or it did not mitigate its damages.

ELEVENTH AFFIRMATIVE DEFENSE

This case does not present an actual controversy.

TWELFTH AFFIRMATIVE DEFENSE

Plaintiff does not have standing.

THIRTEENTH AFFIRMATIVE DEFENSE

This action is barred by laches.

FOURTEENTH AFFRIMATIVE DEFENSE

This action is barred under Eleventh Amendment Immunity, Sovereign

Immunity, Qualified Immunity, Governmental Immunity and any other applicable

immunity.

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Respectfully submitted,

JOSH SHAPIRO
Attorney General

By: s/ Nicole J. Boland

NICOLE J. BOLAND
Office of Attorney General Deputy Attorney General
15th Floor, Strawberry Square Attorney ID 314061
Harrisburg, PA 17120
Phone: (717) 783-3146 STEPHEN MONIAK
Senior Deputy Attorney General
nboland@attorneygeneral.gov Attorney ID 80035

Date: July 10, 2020 KAREN M. ROMANO

Chief Deputy Attorney General
Civil Litigation Section

Counsel for Defendant Commonwealth

of Pennsylvania and Boockvar

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 Case 1:20-cv-00708-CCC Document 33 Filed 07/10/20 Page 23 of 25

IN THE UNITED STATES DISTRICT COURT

FOR THE MIDDLE DISTRICT OF PENNSYLVANIA

JUDICIAL WATCH, INC., :

Plaintiff : No. 1:20-CV-0708
:
v. : Judge Conner
:
COMMONWEALTH OF : Electronically Filed Document
PENNSYLVANIA, KATHY : Complaint Filed 04/29/20
BOOCKVAR, BUCKS COUNTY :
COMMISSION, BUCKS COUNTY :
BOARD OF ELECTIONS, BUCKS :
COUNTY REGISTRATION :
COMMISSION, THOMAS FREITAG, :
CHESTER COUNTY COMMISSION, :
CHESTER COUNTY BOARD OF :
ELECTIONS, CHESTER COUNTY :
REGISTRATION COMMISSION, :
SANDRA BURKE, DELAWARE :
COUNTY COUNCIL, DELAWARE :
COUNTY BOARD OF ELECTIONS, :
DELAWARE COUNTY :
REGISTRATION COMMISSION and :
LAUREEN HAGAN, :
Defendants :
:
v. :
:
COMMON CAUSE PENNSYLVANIA :
and LEAGUE OF WOMEN VOTERS :
OF PENNSYLVANIA, :
Intervenor Defendants :

CERTIFICATE OF SERVICE
I, Nicole J. Boland, Deputy Attorney General for the Commonwealth of

Pennsylvania, Office of Attorney General, hereby certify that on July 9, 2020, I

 Case 1:20-cv-00708-CCC Document 33 Filed 07/10/20 Page 24 of 25

caused to be served a true and correct copy of the foregoing document to the

following:

VIA U.S. MAIL

Eric Lee, Esquire H. Christopher Coates, Esquire

Robert D. Popper, Esquire Law Office of H. Christopher
Judicial Watch, Inc. Coates
425 Third Street SW, Suite 800 934 Compass Point
Washington, DC 20024 Charleston, SC 29412
Counsel for Plaintiff Counsel for Plaintiff

Jonathan S. Goldstein, Esquire T. Russell Nobile, Esquire

Goldstein Law Partners, LLC Judicial Watch, Inc.
11 Church Road P.O. Box 6592
Hatfield, PA 19440 Gulfport, MS 39506
Counsel for Plaintiff Counsel for Plaintiff

VIA ECF

Shawn M. Rodgers, Esquire Witold J. Walczak, Esquire

Goldstein Law Partners, LLC
11 Church Road, Suite 1A
Hatfield, PA 19440
srodgers@goldsteinlp.com
Counsel for Plaintiff
American Civil Liberties Union
of Pennsylvania
247 Ft. Pitt Blvd, 2nd Floor
Pittsburgh, PA 15222
vwalczak@aclupa.org
Counsel for Intervenor Defendants

BUCKS COUNTY DEFENDANTS CHESTER COUNTY

(UPDATE WHEN INFO RECVD) DEFENDANTS
(UPDATE WHEN INFO RECVD)

DELAWARE COUNTY
DEFENDANTS
(UPDATE WHEN INFO RECVD)
Case 1:20-cv-00708-CCC Document 33 Filed 07/10/20 Page 25 of 25

s/ Nicole J. Boland
NICOLE J. BOLAND
 Case 1:20-cv-00708-CCC Document 33-1 Filed 07/10/20 Page 1 of 1

Local Jurisdiction Identification Voters Removed from Rolls - Reasons

Voters Removed: Voters Removed: Voters Removed: Voters Removed: Voters Removed: Voters Removed: Voters Removed: Voters Removed: Voters Removed:
Total Relocation Death Felony Failure to Respond Declared Mentally Voter's Request Other - Description Other - Count 1
(Outside to Notices or Vote Incompetent 1
Jurisdiction)

Enter Number or Enter Number or Enter Number or Enter Number or Enter Number or Enter Number or Enter Number or Other Specify: Enter Number or
N/A N/A N/A N/A N/A N/A N/A (Text) N/A
FIPS Code Jurisdiction Name A9a A9b A9c A9d A9e A9f A9g A9h_Other A9h

4200100000 ADAMS COUNTY 4406 718 1274 0 2369 0 0 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
45
4200300000 ALLEGHENY COUNTY 30518 8701 20851 0 0 4 113 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
849
4200500000 ARMSTRONG COUNTY 2976 548 1046 0 1363 0 0 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
19
4200700000 BEAVER COUNTY 8590 898 2911 0 4654 0 55 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
72
4200900000 BEDFORD COUNTY 4607 939 621 0 2996 3 7 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
41
4201100000 BERKS COUNTY 20521 2961 5215 0 12220 0 66 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
59
4201300000 BLAIR COUNTY 5889 1157 2155 0 2431 3 47 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
96
4201500000 BRADFORD COUNTY 1102 253 816 0 0 0 0 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
33
4201700000 BUCKS COUNTY 29666 4131 9189 0 15714 0 302 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
330
4201900000 BUTLER COUNTY 9640 1694 2461 0 5316 3 11 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
155
4202100000 CAMBRIA COUNTY 7240 1045 2425 0 3673 0 46 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
51
4202300000 CAMERON COUNTY 344 29 36 0 278 0 0 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
1
4202500000 CARBON COUNTY 1542 469 1051 0 0 0 0 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
22
4202700000 CENTRE COUNTY 22753 5148 1401 0 15914 1 107 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
182
4202900000 CHESTER COUNTY 21030 4546 4537 0 11519 0 7 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
421
4203100000 CLARION COUNTY 1932 450 171 0 1285 0 7 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
19
4203300000 CLEARFIELD COUNTY 9429 1740 1332 0 6289 4 19 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
45
4203500000 CLINTON COUNTY 2508 547 442 0 1502 0 0 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
17
4203700000 COLUMBIA COUNTY 1710 880 172 0 631 0 2 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
25
4203900000 CRAWFORD COUNTY 2219 568 430 0 1143 0 0 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
78
4204100000 CUMBERLAND COUNTY 7661 3391 3394 0 705 19 89 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
63
4204300000 DAUPHIN COUNTY 16784 4912 2707 0 8832 0 1 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
332
4204500000 DELAWARE COUNTY 33340 4552 7453 0 20968 0 0 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
367
4204700000 ELK COUNTY 731 222 486 0 0 0 5 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
18
4204900000 ERIE COUNTY 5534 1339 4083 0 0 0 0 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
112
4205100000 FAYETTE COUNTY 9699 594 2235 0 6783 0 36 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
51
4205300000 FOREST COUNTY 158 49 107 0 0 0 0 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
2
4205500000 FRANKLIN COUNTY 5088 679 1122 0 3036 0 0 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
251
4205700000 FULTON COUNTY 515 307 180 0 1 2 3 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
22
4205900000 GREENE COUNTY 1897 204 652 0 922 0 38 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
81
4206100000 HUNTINGDON COUNTY 1558 1186 359 0 0 0 0 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
13
4206300000 INDIANA COUNTY 2687 2601 11 0 0 0 0 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
75
4206500000 JEFFERSON COUNTY 1513 662 833 0 0 0 10 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
8
4206700000 JUNIATA COUNTY 792 157 314 0 297 0 8 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
16
4206900000 LACKAWANNA COUNTY 12434 1299 4160 0 6906 0 28 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
41
4207100000 LANCASTER COUNTY 27119 3146 6650 0 16838 0 181 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
304
4207300000 LAWRENCE COUNTY 3370 407 284 0 2635 0 0 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
44
4207500000 LEBANON COUNTY 6876 1132 2047 0 3550 3 37 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
107
4207700000 LEHIGH COUNTY 19460 3166 4339 0 11696 2 94 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
163
4207900000 LUZERNE COUNTY 7164 1688 5280 0 96 0 0 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
100
4208100000 LYCOMING COUNTY 5001 702 1655 0 2563 1 22 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
58
4208300000 MCKEAN COUNTY 2140 245 687 0 1173 3 19 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
13
4208500000 MERCER COUNTY 9395 571 2101 0 6695 0 18 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
10
4208700000 MIFFLIN COUNTY 2312 384 412 0 1504 0 0 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
12
4208900000 MONROE COUNTY 7474 1350 680 0 5410 0 0 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
34
4209100000 MONTGOMERY COUNTY 41252 6971 8790 0 24365 0 0 INCLUDES MULTIPLE FORMS OF SELF1126
CANCELLATION
4209300000 MONTOUR COUNTY 690 408 269 0 0 0 0 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
13
4209500000 NORTHAMPTON COUNTY 17752 2443 3859 0 11245 1 14 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
190
4209700000 NORTHUMBERLAND COUNTY 6270 577 1376 0 4274 0 0 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
43
4209900000 PERRY COUNTY 2715 456 640 0 1562 6 4 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
47
4210100000 PHILADELPHIA COUNTY 99470 11033 20575 0 67163 0 0 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
699
4210300000 PIKE COUNTY 1813 1147 590 0 12 0 2 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
62
4210500000 POTTER COUNTY 787 126 313 0 306 2 5 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
35
4210700000 SCHUYLKILL COUNTY 6105 700 2497 0 2846 0 3 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
59
4210900000 SNYDER COUNTY 1715 302 472 0 921 0 1 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
19
4211100000 SOMERSET COUNTY 4872 491 1294 0 3069 0 6 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
12
4211300000 SULLIVAN COUNTY 162 49 95 0 18 0 0 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
0
4211500000 SUSQUEHANNA COUNTY 1717 210 631 0 801 0 24 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
51
4211700000 TIOGA COUNTY 1229 540 653 0 0 0 0 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
36
4211900000 UNION COUNTY 1569 380 87 0 1073 0 0 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
29
4212100000 VENANGO COUNTY 1847 260 199 0 1351 0 0 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
37
4212300000 WARREN COUNTY 969 220 726 0 0 0 3 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
20
4212500000 WASHINGTON COUNTY 5391 2050 3261 0 1 0 0 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
79
4212700000 WAYNE COUNTY 2700 472 819 0 1366 0 7 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
36
4212900000 WESTMORELAND COUNTY 8621 2533 5925 0 1 0 0 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
162
4213100000 WYOMING COUNTY 640 202 405 0 0 0 1 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
32
4213300000 YORK COUNTY 8757 2874 5643 0 0 3 130 INCLUDES MULTIPLE FORMS OF SELF CANCELLATION
107

STATE TOTAL 596367 106811 169886 0 310281 60 1578 7751