caption
Plaintiff's response to request for production of documents and things.

Part 1 - the questions.
REQUESTS REQUEST NO. 1: Produce all documents evidencing expenses incurred, or paid, for any injury or item of damage you claim to have suffered, including but not limited to, medical bills, invoices, and receipts for which Plaintiff claims any compensation in this action. RESPONSE:

REQUEST NO. 2: Produce all documents used or relied on in answering Defendant’s contemporaneously-served interrogatories. RESPONSE:

REQUEST NO. 3: Produce all correspondence held by Plaintiff and/or any his agent, either to or from any employee or agent of Defendant, that is related in any way to the facts alleged in the Second Amended Complaint. This request also encompasses any copies of e-mails and other forms of electronic messaging. RESPONSE:

REQUEST NO. 4: Produce all statements, records or reports made by any potential witness or anyone having knowledge of the allegations contained in your Second Amended Complaint. RESPONSE:

REQUEST NO. 5: Produce each paper, photograph, document, drawing, diagram, book, article, treatise, manual or any other piece of evidence, demonstrative or otherwise relevant, Plaintiff intends to offer or use as evidence at the trial of this matter. RESPONSE:

REQUEST NO. 6: Produce all documents which support, reference or verify the damages you are claiming in this case, including any identified in your answer to Interrogatory No. 15. RESPONSE:

REQUEST NO. 7: Produce all evidence, including any witness statements, to support the allegation in paragraph 5 of your Second Amended Complaint that Steven Rose refused to allow you to vote

RESPONSE: REQUEST NO. 8: Produce all documents identified in your response to Interrogatory No. 5 of Defendant’s contemporaneously-served interrogatories. RESPONSE:

REQUEST NO. 9: Produce all documents identified in your response to Interrogatory No. 8 of Defendant’s contemporaneously-served interrogatories. RESPONSE:

REQUEST NO. 10: Produce all documents identified in your response to Interrogatory No. 9 of Defendant’s contemporaneously-served interrogatories. RESPONSE:

Respectfully submitted, /s/ Daniel P. Bowman Daniel P. Bowman (31691-49) Assistant Corporation Counsel
part II the questions with the referenced sections included

REQUESTS REQUEST NO. 1: Produce all documents evidencing expenses incurred, or paid, for any injury or item of damage you claim to have suffered, including but not limited to, medical bills, invoices, and receipts for which Plaintiff claims any compensation in this action. RESPONSE:

REQUEST NO. 2: Produce all documents used or relied on in answering Defendant’s contemporaneously-served interrogatories. RESPONSE:

REQUEST NO. 3: Produce all correspondence held by Plaintiff and/or any his agent, either to or from any employee or agent of Defendant, that is related in any way to the facts alleged in the Second Amended Complaint. This request also encompasses any copies of e-mails and other forms of electronic messaging. RESPONSE:

REQUEST NO. 4: Produce all statements, records or reports made by any potential witness or anyone having knowledge of the allegations contained in your Second Amended Complaint. RESPONSE:

REQUEST NO. 5: Produce each paper, photograph, document, drawing, diagram, book, article, treatise, manual or any other piece of evidence, demonstrative or otherwise relevant, Plaintiff intends to offer or use as evidence at the trial of this matter. RESPONSE:

REQUEST NO. 6: Produce all documents which support, reference or verify the damages you are claiming in this case, including any identified in your answer to Interrogatory No. 15. RESPONSE:

     Interrogatory No. 15: Provide an itemized list of the amount(s) you claim as damages in this case for the violation(s) described in your complaint, and describe the basis and calculations used to compute those damages.

REQUEST NO. 7: Produce all evidence, including any witness statements, to support the allegation in paragraph 5 of your Second Amended Complaint that Steven Rose refused to allow you to vote

RESPONSE: REQUEST NO. 8: Produce all documents identified in your response to Interrogatory No. 5 of Defendant’s contemporaneously-served interrogatories. RESPONSE:

      Interrogatory No. 5: Regarding paragraph 6 of your Second Amended Complaint, describe in            detail the basis for your allegation that Steven Rose and the other poll workers were inadequately         trained. Your answer should identify any documents or other evidence in your possession,                   custody,  or control that you believe supports your allegation of inadequate training.

REQUEST NO. 9: Produce all documents identified in your response to Interrogatory No. 8 of Defendant’s contemporaneously-served interrogatories. RESPONSE:

    Interrogatory No. 8: Identify all evidence, including but not limited to videos, images, witness statements, and audio recordings, which support your allegation that you were not allowed to vote on May 6, 2018 (or Tuesday May 8, 2018).

REQUEST NO. 10: Produce all documents identified in your response to Interrogatory No. 9 of Defendant’s contemporaneously-served interrogatories. RESPONSE:

      Interrogatory No. 9: Regarding paragraph 25 of your Second Amended Complaint, describe in detail how Clerk Eldridge “was on specific notice of the problem at this precinct.” In your answer, identify the specific precinct to which you are referring and describe what you mean by “problem.” Please also identify all evidence which you believe shows that the Clerk was on specific notice. Answer: Interrogatory No. 10: For each count in your Second


Respectfully submitted, /s/ Daniel P. Bowman Daniel P. Bowman (31691-49) Assistant Corporation Counsel

part III the answers

REQUESTS REQUEST NO. 1: Produce all documents evidencing expenses incurred, or paid, for any injury or item of damage you claim to have suffered, including but not limited to, medical bills, invoices, and receipts for which Plaintiff claims any compensation in this action. RESPONSE:

1.     The receipt for the filing fee for this case is in the possession of eldridge as clerk. It might have been in the neighborhood of $130.
There have been modest photocopying postage mileage and parking expenses. I can forward some of the fedex receipts if desired.
My medical bills do not seem germane to this case, which seeks intangible damages for violation of voting rights, as determined by a  jury, to whatever extent available,.

REQUEST NO. 2: Produce all documents used or relied on in answering Defendant’s contemporaneously-served interrogatories. RESPONSE:
You already have the main ones, from the initial discovery packet.. Do you have a copy of the election day procedures guide, that comes with the polling station? You should.
Do we need a copy of the Voters Bill of Rights?
I ask you to take judicial notice of the Indiana Constitution, the voter ID statues, the federal constitution, and HAVA sections 302, 303.


REQUEST NO. 3: Produce all correspondence held by Plaintiff and/or any his agent, either to or from any employee or agent of Defendant, that is related in any way to the facts alleged in the Second Amended Complaint. This request also encompasses any copies of e-mails and other forms of electronic messaging. RESPONSE:

REQUEST NO. 4: Produce all statements, records or reports made by any potential witness or anyone having knowledge of the allegations contained in your Second Amended Complaint. RESPONSE:

REQUEST NO. 5: Produce each paper, photograph, document, drawing, diagram, book, article, treatise, manual or any other piece of evidence, demonstrative or otherwise relevant, Plaintiff intends to offer or use as evidence at the trial of this matter. RESPONSE:

REQUEST NO. 6: Produce all documents which support, reference or verify the damages you are claiming in this case, including any identified in your answer to Interrogatory No. 15. RESPONSE:

     Interrogatory No. 15: Provide an itemized list of the amount(s) you claim as damages in this case for the violation(s) described in your complaint, and describe the basis and calculations used to compute those damages.

REQUEST NO. 7: Produce all evidence, including any witness statements, to support the allegation in paragraph 5 of your Second Amended Complaint that Steven Rose refused to allow you to vote

RESPONSE: REQUEST NO. 8: Produce all documents identified in your response to Interrogatory No. 5 of Defendant’s contemporaneously-served interrogatories. RESPONSE:

      Interrogatory No. 5: Regarding paragraph 6 of your Second Amended Complaint, describe in            detail the basis for your allegation that Steven Rose and the other poll workers were inadequately         trained. Your answer should identify any documents or other evidence in your possession,                   custody,  or control that you believe supports your allegation of inadequate training.

REQUEST NO. 9: Produce all documents identified in your response to Interrogatory No. 8 of Defendant’s contemporaneously-served interrogatories. RESPONSE:

    Interrogatory No. 8: Identify all evidence, including but not limited to videos, images, witness statements, and audio recordings, which support your allegation that you were not allowed to vote on May 6, 2018 (or Tuesday May 8, 2018).

REQUEST NO. 10: Produce all documents identified in your response to Interrogatory No. 9 of Defendant’s contemporaneously-served interrogatories. RESPONSE:

      Interrogatory No. 9: Regarding paragraph 25 of your Second Amended Complaint, describe in detail how Clerk Eldridge “was on specific notice of the problem at this precinct.” In your answer, identify the specific precinct to which you are referring and describe what you mean by “problem.” Please also identify all evidence which you believe shows that the Clerk was on specific notice. Answer: Interrogatory No. 10: For each count in your Second


Respectfully submitted, /s/ Daniel P. Bowman Daniel P. Bowman (31691-49) Assistant Corporation Counsel

• See Burgess v. Fisher, 735 F.3d 462, 478 (6th Cir. 2013) ("A plaintiff can make a showing of an illegal policy or custom by demonstrating one of the following: (1) the existence of an illegal official policy or legislative enactment; (2) that an official with final decision making authority ratified illegal actions; (3) the existence of a policy of inadequate training or supervision; or (4) the existence of a custom or tolerance or acquiescence of federal rights violations.").
• 8.Monell, 436 U.S. at 691.
• Monell v. New York City Department of Social Services , 436 U.S. 658, 690-92 (1978).
• 2.Owen v. City of Independence, 445 U.S. 622 (1980) (municipality liable for damages flowing from constitutional violations that it caused through the execution of its policy or custom).
• 3.Connick v. Thompson, 131 S. Ct. 1350, 1359 (2011).
• 
  
• Id. See, e.g., Spell v. McDaniel, 824 F.2d 1380, 1387 (4th Cir. 1987) (Custom or usage has force of law as "widespread practice" when "duration and frequency of the practices warrants a finding of either actual or constructive knowledge by the governing body [or policymaker with responsibility for oversight and supervision] that the practices have become customary among its employees.")

An officer’s entitlement to assert qualified immunity turns on whether he or she was engaged in a discretionary job function, such as those requiring the officer’s exercise of judgment.35 However, an official is not entitled to qualified immunity for the malperformance of a ministerial job function.36

 see Davis v. Scherer, 468 U.S. 183, 196 n.14 (1984)

rose had a nondiscretionary duty, a ministerial duty, to issue a providional ballot, so does not have qualified immunity.!

is the ejection a seizure?
Any restraint on a person’s liberty by a person of authority is a seizure, and sometimes that’s lawful, and sometimes its not.There is a three part test the United States Supreme Court developed to evaluate reasonableness.

1. The gravity of the public interest which will be served by the seizure
2. The degree to which the seizure advances public interest
3. How greatly the seizure interferes with personal liberties

list of jobs applied for

1]
volt temps,
https://jobs.volt.com/en-US/job/weigh-technician-tier-2/J3S5HW60T8L1PJHMQNR

Weigh Technician - Tier 2 In Indianapolis, IN At Volt

2]
petit chou, dishwasher, http://cafepatachou.com/,https://secure.jobappnetwork.com/apply/c_pat/l_en/#s,
plan: get scotty a job there, get kevin a better paying gig, take kevin's job at bob evans.

plan for tomorrow: plasma, brian, scrap run, clean yard, outline memo for appointmnt of counsel, answer to , motion for production of documents.

next gavin email:

some footnotes about facts:
- incident about assaulted while entering state house to talk to counsel for secstate,
- incident where trespassed from city county building while seeking voting records, because video.
- denial of press pass by county
- hearing moved without notice
- compelled to sign organ donor form to get id in plainfield,

queston about whether they sent a letter to the county. if the letter was sent, it is relevant to supporting a deliberate indifference/failure to train and supervise claim if they neither responded to the letter, nor trained jones or doe or the other 10 employees, 

• See Burgess v. Fisher, 735 F.3d 462, 478 (6th Cir. 2013) ("A plaintiff can make a showing of an illegal policy or custom by demonstrating one of the following: (1) the existence of an illegal official policy or legislative enactment; (2) that an official with final decision making authority ratified illegal actions; (3) the existence of a policy of inadequate training or supervision; or (4) the existence of a custom or tolerance or acquiescence of federal rights violations.").
• 8.Monell, 436 U.S. at 691.
• Monell v. New York City Department of Social Services , 436 U.S. 658, 690-92 (1978).
• 2.Owen v. City of Independence, 445 U.S. 622 (1980) (municipality liable for damages flowing from constitutional violations that it caused through the execution of its policy or custom).
• 3.Connick v. Thompson, 131 S. Ct. 1350, 1359 (2011).
• 
  
• Id. See, e.g., Spell v. McDaniel, 824 F.2d 1380, 1387 (4th Cir. 1987) (Custom or usage has force of law as "widespread practice" when "duration and frequency of the practices warrants a finding of either actual or constructive knowledge by the governing body [or policymaker with responsibility for oversight and supervision] that the practices have become customary among its employees.")

An officer’s entitlement to assert qualified immunity turns on whether he or she was engaged in a discretionary job function, such as those requiring the officer’s exercise of judgment.35 However, an official is not entitled to qualified immunity for the malperformance of a ministerial job function.36

 see Davis v. Scherer, 468 U.S. 183, 196 n.14 (1984)

rose had a nondiscretionary duty, a ministerial duty, to issue a providional ballot, so does not have qualified immunity.!

notes for gavin

maybe these are notes for bowman.
fact intensive inquiry
how have i been burdened by this case

- statehouse door incident. pending tort claim. not being investigated.

- palmer v marion: sued about having to go thru security checkpoint ot early vote.
result: case was dismissed, but procedures were changed to allow voters to enter the west side door without going through securitycheckpoint. small but real victory. 

- stewart v board, beth white case, 2008.
- stewart v proffitt case filed when? october 2010?
http://joellpalmer.blogspot.com/2010/12/here-is-text-of-my-recently-filed-voter.html

http://joellpalmer.blogspot.com/2006/01/ 7th circuit crawford amicus draft.

ROBBIN STEWART, ) 
) 
Plaintiff, ) 
)


v. ) CASE NUMBER: 1:08-cv-586-LJM-TAB 
) 
MARION COUNTY, et al. ) 
) 
Defendants, ) 
) 
STATE OF INDIANA, ) 
) 
Intervenor. ) 
stewart v while cause number.

https://www.lawserver.com/law/state/indiana/in-code/indiana_code_5-14-1-5-7
open door law, civil penalty, costs fees if public access counselor opinion.

Joell Palmer, ) 
) 
Plaintiff, ) 
) 
) 
) 
v. ) Cause No. 49D04-06 10-CT-044113 
) 
) Judge Cynthia Ayers 
) 
Marion County, State of )

Indiana, J. Bradley King, )

Todd Rokita, Kristi Robertson,)

Doris Anne Sadler, Beth White,)

John Doe #1-4,Jane Doe 1-3, )

Securatex, Jack Cottey, ) 
) 
Defendants. ) 

Friday, December 21, 2018

this post is some notes, in progress, about whether crawford clearly establishes a right to a provisional ballot, i will move this off the blog shortly.

A voter who has photo identification but is unable to present that identification on election day may file a provisional ballot that will be counted if she brings her photo identification to the circuit county clerk’s office within 10 days. §3–11.7–5–2.5(b).

Crawford v Marion County Election Board, 
says "unable" 

IC 3-10-1-7.2Proof of identification; exception; failure to produce; challenge; provisional ballot

     Sec. 7.2. (a) Except as provided in subsection (e), a voter who desires to vote an official ballot at a primary election shall provide proof of identification.

     (b) Except as provided in subsection (e), before the voter proceeds to vote in a primary election, a precinct election officer shall ask the voter to provide proof of identification. The voter must produce the proof of identification before being permitted to sign the poll list.

     (c) If:

(1) the voter is unable or declines to present the proof of identification; or

(2) a member of the precinct election board determines that the proof of identification presented by the voter does not qualify as proof of identification under IC 3-5-2-40.5;

a member of the precinct election board shall challenge the voter as prescribed by IC 3-11-8.

     (d) If the voter executes a challenged voter's affidavit under section 9 of this chapter or IC 3-11-8-22.1, the voter may:

(1) sign the poll list; and

(2) receive a provisional ballot.

IC 3-11-8-20Challenge of voter; reduction of challenge to affidavit form

     Sec. 20. If a voter offering to vote is challenged by a challenger or by a member of the precinct election board, the person challenging the voter shall reduce the challenge to affidavit form, setting forth succinctly the reasons for the challenge.

[Pre-1986 Recodification Citation: 3-1-23-19(a) part.]

As added by P.L.5-1986, SEC.7.

IC 3-11-8-21Challenge of voter; challenger's affidavit

     Sec. 21. The affidavit of challenge prescribed by section 20 of this chapter must set forth under oath or affirmation the following:

(1) The name of the challenger.

(2) The name of the person being challenged.

(3) The reasons the challenger believes the person being challenged is not a legal voter in the precinct.

(4) The source of the information provided under subdivision (3).

(5) A statement that the challenger understands that making a false statement on the affidavit is punishable under the penalties of perjury.

f) If a voter described by subsection (a) fails by the deadline for counting provisional ballots referenced in subsection (a) to:

(1) appear before the county election board; and

(2) execute an affidavit in the manner prescribed by subsection (b) or (c);

the county election board shall find that the voter's provisional ballot is invalid.

or who will have his or her right to vote unduly burdened by its requirements.”

She found that petitioners had “not introduced evidence of a single, individual Indiana resident who will be unable to vote as a result of SEA 483 or who will have his or her right to vote unduly burdened by its requirements.” 

Next, noting the absence of any plaintiffs who claimed that the law would deter them from voting, the Court of Appeals inferred that “the motivation for the suit is simply that the law may require the Democratic Party and the other organizational plaintiffs to work harder to get every last one of their supporters to the polls.” Id., at 952.

Finally, in a provision entitled “Fail-safe voting,” HAVA authorizes the casting of provisional ballots by challenged voters. §15483(b)(2)(B). crawford.

there is no private right of action under hava?  brunner, an ohio case that sought to enforce hava. but the court's discussion of hava's failsafe provision in crawford is relevant to whether the right to a provisional ballot is clearly established. 

here is a first circuit case that says there is a private right of action under hava.

In a recent example of such a claim, a voter in Puerto Rico brought an action challenging a Puerto Rico statute that struck her and more than 300,000 other voters from a voter-registration roll because they did not vote in the prior general election. The U.S. District Court for the District of Puerto Rico issued injunctive and declaratory relief barring the Puerto Rico State Elections Commission ("SEC") from removing otherwise eligible voters from an active election registry unless the requirements of the federal Help America Vote Act ("HAVA") were met. Colón-Marrero v. Conty-Perez, No. CIV. 12-1749CCC, 2015 WL 3508142 (D.P.R. signed June 4, 2015). The President of the SEC appealed, and the First Circuit Court of Appeals affirmed the lower court. Colón-Marrero v. Velez, No. 15-1356, 2016 WL 386428 (1st Cir. Feb. 1, 2016).      The court in Colón-Marrero held first that a provision of the Puerto Rico statute that had struck the plaintiff and more than 300,000 voters from the voter-registration roll because they did not vote in one prior election was superseded by a provision of HAVA. The federal law provides computerized statewide voter registration list requirements and precludes Puerto Rico from deactivating voters unless they have not responded to a notice seeking to confirm eligible residency and they did not vote in two consecutive general elections for federal office; the HAVA provision states that no registrant may be removed solely by reason of a failure to vote.      As for the plaintiff's use of § 1983 as a remedy, if a plaintiff satisfies the threshold inquiry and demonstrates that Congress intended to confer an individual right, the right is presumptively enforceable by § 1983. To rebut that presumption, the defendant must show that Congress shut the door to private enforcement, either expressly in the statute creating the right or impliedly by creating a comprehensive enforcement scheme that is incompatible with individual enforcement under § 1983. Blessing v. Freestone, 520 U.S. 329, 341 (1997). When it applied this analysis to the claim before it, the First Circuit found that the plaintiff voter and others like her could pursue a claim under § 1983.      The key provision in HAVA did create an individual private right subject to enforcement through a § 1983 claim; it specified a discrete class of beneficiaries, that is, registrants like the plaintiff, and described specific procedures for removing individual registrants from a state's active voter rolls. In addition, HAVA was enacted pursuant to Congress's authority under the Elections Clause of the Constitution, and enforcing a right of retention on a state's active voter registry would impose no strain on judicial competence. The right was concrete and well defined, and the HAVA provision's requirements unambiguously imposed binding obligations. As for the final step in the analysis, an individual remedy like that sought by the plaintiff in Colón-Marrero was not incompatible with the enforcement mechanisms of HAVA.      The outcome in Colón-Marrero is in keeping with the Supreme Court's admonition 

against "lightly conclud[ing] that Congress intended to preclude reliance on § 1983," Smith v. Robinson, 468 U.S. 992, 1012 (1984), and its statement that the availability of a private remedy through an administrative mechanism is not necessarily enough to show such intent, see, e.g., Golden State Transit Corp. v. City of Los Angeles, 493 U.S. 103, 106 (1989). Rather, to confine individuals to a statutory remedy, the legislation must reveal Congress's purpose to exclude independent relief in federal court pursuant to § 1983. See, e.g., Wilder v. Va. Hosp. Ass'n, 496 U.S. 498, 523 (1990) (finding no "indication that Congress specifically intended that [the statute's] administrative procedure replace private remedies available under § 1983"). With regard to the claim in Colón-Marrero, nowhere in HAVA was there an indication that Congress meant to foreclose a remedy under § 1983.

Read more at: http://www.nlrg.com/public-law-legal-research/civil-rights-help-america-vote-act-creates-individual-right-enforceable-through-1983
but is that an unreported case? injunctive and dclaratory relief.

5 Currently, only the District Court for the Eastern District of Michigan found, in Bay County Democratic Party v. Land, that a private right of action exists through 42 U.S.C.A. §1983. This Court found that provisional voting rights, granted through HAVA, met this standard. 66 T


 For example, a voter may lose his photo identification, may have his wallet stolen on the way to the polls, or may not resemble the photo in the identification because he recently grew a beard. Burdens of that sort arising from life’s vagaries, however, are neither so serious nor so frequent as to raise any question about the constitutionality of SEA 483; the availability of the right to cast a provisional ballot provides an adequate remedy for problems of that character.

possible jobs

1. https://www.linkedin.com/jobs/view/1021679256?trk=job-dist-ziprecruiter-ppc&trk=jobs-zr-dist-16&click_id=30392f33-843a-4f2a-825b-30508ae90f4e

2 https://jobs.expresspros.com/job/details?jobControlNum=13265681

Extrusion Machine Operator 2nd Shift

Located in Indianapolis, IN

 Karra.lord@expresspros.com email resume - brush up on resume.

Job Summary:

A production company in the East side is seeking an Entry Level Operator. This person would assemble small metal parts. All shifts are open. This could be a permanent position with a salary starting at $13.75 an hour.

Entry Level Operator Required:      

• THE ABILITY TO READ A MEASURING TAPE IS MANDATORY. 
• Basic Computer skills
• Experience working with RF scanner
• Math Skills – the ability to add, subtract, multiply and divide is important. Converting fractions to decimals and decimals to fractions is also important.   

Entry Level Operator Preferred:     

• Forklift experience
• Experience operating an Overhead Crane 
• Experience reading blue prints  
• Experience with precision tools – Individuals that understand how to use calipers, and/or micrometers

Location: Indianapolis, IN East

Position Type: Evaluation to Hire

Pay: $13.75 an hour

Schedule: 2nd Shift 3-11pm

Ramsey County Sheriff-elect fined for campaign disclaimer violation

By Sara Marie Moore/Vadnais Heights Editor
Dec 19, 2018 Updated 11 hrs ag

https://www.presspubs.com/vadnais/news/ramsey-county-sheriff-elect-fined-for-campaign-disclaimer-violation/article_c45263e0-03e8-11e9-98dd-ebb38e0d377e.html

Ramsey County Sheriff-elect fined for campaign disclaimer violation


smith
v california mens rea

proposed op-ed column for presspubs .com

County sheriifs often end up in the news for being accused of violating someone's civil rights. This time, the shoe is on the other foot.

The sheriff-elect of ramsey county minnesota had his federal civil rights violated when his campaign was assessed a $500 fine for engaging in political speech protected by the first amendment.  such a violation is both a crime, and could be the basis of a civil lawsuit, against the board, which may have some immunity from damages, and the man who reported him, James Daly, who does not.

There are at least two problems with what happened to the sheriff.
First, the board fined him  for a negligent accident. Under Smith v California, 1959, the supreme court found under the first amendment, speech violations must be intentional, what lawyers call "mens rea".

Second, disclaimer rules like the one the board is trying to enforce were found unconstitutional in 1960 in talley v california. Civil rights activist Manuel Talley was fined $10 for a flyer urging a boycott of racist businesses, with no "disclaimer" of his name and address. The court found that disclaimer rules are unconstitutional, because they are compelled speech, violate the right to privacy,
and chill protected speech. Then as now, speaking out can be dangerous. Je suis Charlie. Recently hoosier-educated washington post journalist adnan kashogi was murdered by saudi government agents. Speech comes with risk, and goverment may not increase those risks with unconstitutional disclaimer ordinances.
Along  with naacp v alabama an bates v little rock, talley is the landmark
foundation of the right to privacy. Federal legislation like the privacy act and hippa came later. In 1995, the court clarified that there is no 'elections exception' to talley, in mcintyre v ohio. margaret mcintyre was a little old lady who was part of a group that opposed a tax hike, and they passed out some flyers she made on her home computer.

 Last term, janus and becerra again upheld our right to be free from compelled speech in cases about union dues and disclaimers at a pregnancy center. During ww ii, jehova's witnesses were persecuted for their refusal to salute the flag, which they saw as idol-worship. In Barnette, the court reversed Gobitis, and held that the freedom not to salute the flag, is exactly what the flag stands for. It is why we fight, for freedom.
Sheriff Fletcher 's right to put up campaign signs is the same right that allows us to publish these edititorals. Tornillo v Miami Herald.
Both the minnesota and us constitutions protect the free speech of the sheriff's signs. The board should back down, and cease and decist its unconstitutional civil rights violations.  If it wont, the sheriff should fight them,, and we should join him and fight them together, because we are  americans, and we stand up to bullies and censorship.

Robbin Stewart was the plaintiff in Stewart v Taylor, which found Indiana's disclaimer statute unconstitutional in 1997. He blogs at Arbitrary Aardvark, vark.blogspot.com.
=

One of Fletcher's campaign volunteers accidentally put “Bob Fletcher for Ramsey County Committee” on campaign signs instead of the official committee name, “Bob Fletcher for Sheriff Committee.” Also, there was no address included. The volunteer left off disclaimer information from a promotional video that was on YouTube. The home page of Fletcher's campaign website also had no disclaimer.

After James Daly, a former Ramsey County Sheriff's Office lieutenant, filed a complaint about it, the committee corrected the signs with stickers and added appropriate disclaimers to the video and website.

https://lifehacker.com/5981335/the-complete-guide-to-selling-your-unwanted-crap-for-money

research for motion to appoint counsel
memorandum in support of motion to appoint counsel

 28 U.S.C. §1915(e)(1), which reads in full, "The court may request an attorney to represent any person unable to afford counsel." (Emphasis added.) (This language used to be found in 28 U.S.C. §1915(d), but it was moved recently to its present location. Most of the cases refer to §1915(d), but they will apply to new §1915(e)(1) as well, because the language is nearly identical.) 

In deciding whether to appoint counsel the district judge should first determine whether the indigent's position seems likely to be of substance. If the claim meets this threshold requirement, the court should then consider the indigent's ability to investigate the crucial facts, whether conflicting evidence implicating the need for cross-examination will be the major proof presented to the fact finder, the indigent's ability to present the case, the complexity of the legal issues and any special reason in that case why appointment of counsel would be more likely to lead to a just determination. 

Hendricks v. Coughlin , 114 F.3d 390, 392 (2d Cir. 1997), quoting Hodge v. Police Officers, 802 F.2d 58, 61-62 (2d Cir. 1986). 

Another factor that is often cited is whether the prisoner has made efforts to obtain counsel before requesting appointment. Some cases appear to require efforts to obtain counsel before a court will consider appointment, while other cases recognize that prisoners are not always able to figure out exactly how to get counsel. See the discussions of this issue in Farmer v. Haas, 990 F.2d 319, 321 (7th Cir.), cert. denied, 510 U.S. 963 (1993) and McDonald v. Head Criminal Court Supervisor, 850 F.2d 121, 124 (2d Cir. 1988). 
Even though most federal appellate courts discuss appointment of counsel issues in terms of the factors listed above, they may differ significantly in how the factors are to be applied. For example, the Eighth Circuit has stated that when a case will be tried to a jury (as opposed to a judge trial), a plaintiff having to proceed without counsel is more than likely going to be prejudiced. Abdullah v. Gunter, 949 F. 2d 1032, 1036 (8th Cir. 1991), cert. denied , 1032, 1036 (1992). In contrast, the Seventh Circuit in Farmer v. Haas (cited above) refused to reverse a jury trial conducted by a pro se plaintiff, and suggested that the plaintiff must show a reasonable probability that if counsel had conducted the trial, the result would have been different. As another example, the Ninth Circuit often applies the factors in light of a statement that counsel should only be appointed in "exceptional circumstances" (see, for example, Terrell v. Brewer , 935 F.2d 1015, 1017 (9th Cir. 1991)), while the Second and Eighth Circuit cases do not include this requirement. You should carefully review the cases in your local federal circuit to be sure you understand exactly how the courts in that circuit review the factors. 
Some prisoners have been caught in a "cruel paradox" in which a "carefully reasoned, well-documented petition in support of a motion for the appointment of counselmay be deemed evidence of an ability to proceed without counsel." Mushlin, et al., Rights of Prisoners (2d Ed.), Vol. 2, p. 45 (1993).

scott may 317 453 7590

Elvis didn’t like the present the Ewoks sent him. He wrote on it “Return to Endor”

do you like impressions? why? - bo burnham.
do you like impressions? why? - socrates.

i'd like to do a jim carry impression of andy kaufman doin elvis.

Knock knock?

Who's there?
Wurlitzer.
Wurlitzer who?
Wurlitzer one for the money, two for the show..

knock knock
who's there
weekend
weekend who 
we cant go on together with suspicious minds
weekend build our dreams with suspicious minds.

knock knock

 to get ready, now go cat go.

should i stay or should i go now? - thats the clash, or its dwight yocum.

why dont you stay? - that's frankie valli, or it's jackson browne.

moving right along, [alison transmission/]

in 1911, james alison built the indianapilos motor speedway, in 1915 he entered the race with his own team, in 1919 he won he race, butbythen alsion was busy building liberty airplane parts  for ww1.
in 1928, when jim died,  general motors bought the company. now general motors was pierre samuel dupont's company. he owned general motors and with his two cousins he owned the dupont company, and next week i'm gonna tell you a story about the dupnt company and a wall.,and also how they killed my dad.but that's next week.
general motors sold alison in 2007, in 2012 it went public,and today you can buy 1 share for $43.
so ill be taking orders fo rshares after the show, at my merch table, in my van, in the alley.
sales have been alittle slow lately, so i stole a jingle.

today alison is still there in speedway, so i stole a song about it.

Oh it's so funny to be seeing you after so long, girl.
And with the way you look I understand
That you are not impressed.
But I heard you let that little friend of mine
Take off your party dress.
I'm not going to get too sentimental
Like those other sticky valentines,
Cause I don't know if you've been loving somebody.
I only know it isn't mine.

Alison, I know this world is killing you.
Oh, Alison, my aim is true.

alison, you know this city's killing you.
alison, your game is blue.

thank ya verra much.
that's my time.

mor interrog notes

saturday 12/15/18. 1:45 pm.

14.
Interrogatory No. 14: Do you claim that the Defendant (including employees and representatives), either with or without personal knowledge, made any admissions with respect to the matters alleged in your Complaint? If so, state: (a) The identity of the person(s) who made such admission; (b) When and where such admission was made; (c) The identity of all persons who were present, a party to and/or witnessed each such admission being made; (d) Whether you, or anyone on your behalf, made any notes, tape recordings or other such memoranda regarding each such admission; and (e) The identity of the person(s) having custody of each such notes, tape recordings or other memoranda.

Answer:

I can think several sets if things that might possibly be responsive to this question.

1, The first is that Grant Helms, as counsel for defendants made some statements during a status conference call with Judge Lynch. Having seen the video, he acknowledged that the incident had happened more or less as described in the complaint. He may have admitted that the county had responded to  the notice of tort claim with a denial letter that said there was no duty to issue a provisional ballot. At the time, I recorded only my end of the call. I later deleted that file in order to free up space on my computer. I have imperfect recall of what was said. These issues come up in the context of a discussion of whether we could agree to a stipulation of facts for the purposes of preliminary motions. I pointed out that in the answer the county was denying these facts. To the extent that these may have been admissions, they did not go to the case in chief, but were discussions of preminary motions. The court may or may not have retained a recording of the call.  It is not my position that these are definitely admissions, just that they might be construed that way.
Mr. Helms may or may not have retained a copy of the call. If one exists, I request that it be disclosed. If the current whereabouts of Mr. Helms are known, I request that they be disclosed. He seems to be awol, but not to have filed a motion to withdraw.

2. The second is the countys response to the notice of tort claim. This is an admission that the tort claim existed, and that plaintiff had been denied a provisional ballot in 2016, but doing so was proper and was authorized by Crawford v Marion County. _U.S._ (2008)

3. A third is the "stop" flier, which states that a voter without ID can cast a provisional ballot. These fliers were posted at many polls. This is among the documents I have already provided as discovery, to Mr Helms.

4. A 4th is the "Voter's Bill of Rights" poster.   It states that a person without ID has the right to vote a provisional ballot.

5. A 5th is the early voting poster. It states that early voters must have photo ID. I may have a photo somewhere, and will send it via email when and if I find it.

6. A 6th is the online instructions for early voting which appeared on the county web site, and may have been part of a press release. It stated that early voters must have photo ID. This was only in the 2018 fall election.   As many as 40% of the votes were from the early voting centers.

7. I have provided videos of examples of people saying no id no vote, or words to that effect.
I now realize, that to respond to this question, I should also provide videos of people allowing provisional votes. I have several such, and will send them as email atachments.
Because there are at some points claims that one must have ID to vote, and at other points claims that a person without ID may cast a provisional ballot, this supports my claim that the rules, as followed, are arbitrary and capricious, deny equal protection and due process, and deny free and equal elections.

Interrogatory No. 15: Provide an itemized list of the amount(s) you claim as damages in this case for the violation(s) described in your complaint, and describe the basis and calculations used to compute those damages.

answer: The damages are intangible, and are a fact question which can be resolved by a jury. I intend to ask for $2 million per count which reaches the jury, but may receive far less, if anything. As to the state claims, I will seek a maximum of $300,000 per claim. I am aware that there is a legal dispute as to whether there is an Indiana Bill of Rights, or only an unenforceable Bill of Wishes.
In economic terms of alternative cost, I have invested about 2 years of my life, focus and effort into this project, which, if spent working for wages at appoximately $15,000 per year, is why I have set the settlement amount at $30,000. If I become represented by counsel, that amount may increase to add reasonable legal fees.

Interrogatory No. 16: Have you ever been arrested or been a party to any charge, complaint, lawsuit, legal action, or administrative proceeding, whether criminal or civil in nature? If so, state for each action or proceeding: (a) The caption, court and cause number; (b) The date of the action or proceeding; (c) The nature of the action or proceeding; (d) The resolution of the action or proceeding; and (e) The date the action or proceeding terminated.

Answer:
I decline to answer at this time on the basis that the question is more prejudical than probative, and is compelled self-incrimination.

 Answer:
1. I omit any juvenile offenses. As teenager, I was arrested in Newark Delaware on a  drug possession charge, which was dismissed without trial. No known records exist.
2. I have had several traffic citations such as speeding tickets, parking tickets, a seat belt violation, a stop sign violation, during 42 years as a licensed driver. Additional details at mycase.in.gov.
3. In 2005, I was arrested and charged with 3 counts of battery and one count of attempted kidnapping. The charges were dismissed without trial and have now been expunged. I was held for three weeks at CCA where I was tortured, resulting in a second episode of acute major depression.
4. Beginning in 2001, I have been sued 58 times by the Marion County Health and Hospital Corporation. In June of 2001 this resulted in an acute episode of major depression, during which I lost my life's savings. Since then I have been mostly unable to work, or practice my profession, and have been indigent or lived under the poverty line. During the past year my home has been invaded repeatedly in conjunction with such a case, which has taken the last of my savings, caused me acute distress, and seems to be causing a third episide of major depression. This has left me somewhat cognitively impaired. My weight has gone from 185 to 145,
I have sought medical treatment from the jane pauly center, which has sugested prozac and prescribed alieve for back pain.  I am in the process of applying for disability. Because of these factors, I do not have any well organized list of the specifics; it makes me uncomfortable to dwell on it.

Because of these factors, I have limited my practice of law to self-reresentationand the occasional amicus brief

a few notes on interrogtories
10:36 12/14/18

caption

these are just notes, not a finished product.

Interrogatory No. 1: State the full name, address, phone number, and email address of any individual who provided information to these interrogatories. Answer:

robbin stewart, 4015 e washington st indianapolis in 46201, gtbear@gmail.com. i have no working phone.

Interrogatory No. 2: Identify all lawsuits you have filed against Defendants or any other entity or employee of the City of Indianapolis and/or Marion County. For each lawsuit state the following: (a) The parties; (b) The cause number; and (c) The date the lawsuit was filed.
as plaintiff;
voter id cases
1. This lawsuit. 2018, may 1.
2. Robbin Stewart v Marion County Election Board and Linda Proffitt, filed 2008, decided 2010
3. Robbin Setwart v Marion County Election Board, Beth White, 2008? decided 2010.
4. palmer v Marion County, filed 2006, parties, joell palmer, robbin stewart.
political literature cases
5 stewart v taylor, filed 1996, sarah taylor

as counsel:
6. taylor v taylor, maybe 2000? parties included plaintiffs john taylor, sam goldstein, mrs sam goldstein, matt gaylor, not sure if eric barnes.

health and hospital counterclaims
stewart v h+h and  yoceli palafox 2018
stewart v h_h, darrell somebody 2001?

Interrogatory No. 3: Regarding paragraph 5 of your Second Amended Complaint, describe in detail how Steven Rose “refused” to allow you to vote. Your answer should describe any actions he took toward you, and should recite to the best of your knowledge any statements he made to you and your responses to those statements. Answer:

The best answer to this is to watch the videos, already provided.
https://www.youtube.com/playlist?list=PLNesRy31jXibfw1-cZ_w6ziFbyfxZkKrO
I do not have a transcript, so what follows is a summary.

At the primary election in 2016, i went to vote at my usual precinct at the fire station. Jane Doe #1, aka Jones, was holding the poll book and appaeared to be the clerk. I said I'm here to vote. She said let's see it.
I said: what?
her; your id
me  I don't show ID.
her: go see him (indicating John Doe #1, aka steven rose)
John Doe #2, an african american man in a whellchair, sitting next to jones, took little part.
i explained to rose that i was here to vote, that i dont show id, that i had voted here before, that my signature would match the signature in the poll book.
he said i had to have id to vote.
i asked if they could give me any record showing i had been and there and tried to vote.
there was some discussion. he made a phone call. probably to the county election hotline, althoughi dont know and dont know what was said
he said that there was another option, that i could fill it a form so it would look like i voted, but it was b s and wouldn't count.
i said i wanted that second option.
at this point jones and jane does 2 and 3, the clerks for the other precinct, talked him out of it and he no longer offered a provisional ballot, but agreed with them that i could not vote.
jones suggested that i could go to the election center, a warehouse at sherman commons,
with an implication that they might let me vote there.
i agreed to give that a try, only after they had adamantly refused to let me vote.
so the injury was complete when i was directed to leave without being offered a ballot, which i had asked for.
i drove to the warehouse. the next video shows my conversation there. i was directed to return and try again, and to call and ask for her, [jenny] so she could explain to them to offer me a provisional ballot.
i returned. this may have been 20 minutes after i'd left. seeing me re-enter, rose made a call to an unknown person, probably the hotline. i called.  jenny could not be located, but i spoke with another hotline worker, who was an election lawyer and a former state election division  counsel, leslie barnes. i asked rose if he would speak to her. he refused, and ordered me to leave.
that was the second incident that day where he refused to issue me a provisional ballot, doing so against the advice of counsel.
his ordering me to leave is a seperate tort, as i had a right to be there long enough to vote,and had not yet voted.

4
Interrogatory No. 4: Identify all witnesses to your allegation in paragraph 5 of your Second Amended Complaint that Steven Rose refused to allow you to vote. For each witness you identify, provide the following: (a) Name, address, telephone number, and email address; and (b) Whether you have contacted the witness, and, if so, state the date, time, and method of communication.
a)
The witnesses are jones,  jane does 2,3, john doe #1, jenny, barnes. The identify of the does is known to defendants, and has been requested over 30 days ago,both as discovery and as a public records request, but it being wrongfully withheld.

b) i have not contacted the witness again, except as follows.
I have seen Jones again on 3 more occasions, at the precinct, first at the 2016 fall election, where i was a pollbook holder and observer, between 2 and 4 pm.,
next at the 2018 spring and fall elections.

not sure if this goes here think about if needed.
I am unclear as to whether jane does 2 or  were there. Rose was not.
When I came in she said "here comes trouble." I sat quietly, observing. The various election workers objected to my presence, and made three calls to the hotline about me. Each time they were told to leave me alone. They got an old man from the firehouse to tell me to leave. I asked him to clarify if he was ordering to leave, or just asking, and that if he was ordering me I would file another notice of tort claim. He backed down. t about 4pm I noticed that I was feeling ill, and did not want to be disruptive by vomiting, so I left. I have one brief video of one of these encounters.

The next time I saw Jones was at the may primary in 2018, along with Jane Doe number 4, a young blond white woman wearing a french braid. I did not video this incident, but the same person is shown in the 2018 fall video.

 They were the only precinct workers there.  I explained that I was there to vote, and do not show ID. Doe said  


5Interrogatory No. 5: Regarding paragraph 6 of your Second Amended Complaint, describe in detail the basis for your allegation that Steven Rose and the other poll workers were inadequately trained. Your answer should identify any documents or other evidence in your possession, custody, or control that you believe supports your allegation of inadequate training. Answer:

My experience with attempting to vote in 2008, 2012, 2015, 2016, and 2018 has led me to believe that poll workers each sign an oath to uphold the state and federal constitutions, but are provided zero training on those constitutions as they pertain to the right to vote. I suspect that Jones has never read or even seen the state constitution. They are trained to demand ID, but given far less training in what to do if someone does not have or will not show ID.
The main problem is with the training videos. These can be found on the clerks's homepage at www.indygov/clerk. These videos are within the custody and control of defendant. This is a notice to refrain from spoliation of those records.

There are minor variations in the training videos used in different years. I attended the 2016 fall inspector training. There is one video for insector training which deals with how to set up the machines and the polling place, Then there is another video which is used to train the clerks and inspectors. In the first hour of that video, the clerks are trained to demand voter ID, and trained onthe different kinds of ID. Only near the end of the video, more than an hour into it, is there any coverage of how to provide a provisional ballot, and that eplanation is brief and confusing. An A student could watch that video and pick up the nuance that a provisional ballot should be issued. A B or C student could easliy watch the video and only take away the message that all voters must have photo ID.
The training was inadequate. In my experience, about half the poll workers thought the rule was "no ID, no vote". In the training session I attended, the staff had mixed opinions abour whether a provisional ballot was helpful or should be offered. The training consisted of watching a video, with some live discussion and a question and answer period, but there was no test or feedback mechanism to find out if the poll workers had learned and understood the contents of the video. I do not expect perfection. But having half the poll workers use a different process than the other half is arbitrary and capricious, and Bush v. Gore equal protection problem.

In the 2018 fall election, there was an enhanced effort made to train the staff, and they had been alerted to watch for me specificaly. At some locations, I found the workers well informed. At others, they were still saying no id, no vote. At my precinct at the fall election Jane Doe #4 had finally been trained and supervised, understood the process, and folowed it, in contrast to the primary, where she knew nothing about it.

At my first visit to the clerk's office during early voting in fall of 2018, I was greeted by name and offerd a provisional ballot. That is one of several new videos I will provide.
But at a second visit, to the clerk's office during early voting in the fall of 2018, where I happened to be while requesting media credentials which were denied, as part of a trip to the city county building because traci cosby had demanded written proof that I was the person who was emailing, I asked one of the 6 workers at the early voting table if I could vote, saying I did not have ID. The man next to her was Ben Hill. I asked him if he agreed, and he said he did. 5 of the 6 workers agreed no id, no vote. the 6th worker might not have heard. The next day I returned with my computer camera, and obtained a barely audible recording of being told that i had to have id, because the computer needed it to look me up. I asked if there was any alternative, and was told "not that i know of". I contacted a supervisor, and requested to vote a regular ballot, as a reasonable accommodation of my concerns. She refused, saying that would be illegal. I asked her if she knew what had just happened; that I had been told I had to have ID to vote. After consulting the worker, she told me that he had told me to ask a  supervisor. This was a false statement of material fact, similar to linda proffitt's false statement of material fact in the 2010 case. I offered the video to disprove that statement, but the audio was indistinct at that time. I later verified with headphones that the audio accurately captured the worker telling me I must have id to vote, and did not get a supervisor.  I mention these new 2018 incidents not as new claims, but as evidence of a pattern and practice indicating a failure to train.
The position of the workers and the lawyer who denied the tort claim was, no id no vote. the position of the staff was that a provisional ballot should and must be offered. Ir does not seem that both can be correct. The process is arbitrary and capricious, all dpeending who you talk to; there is a lack of a constistent and uniform policy. I then went to the early voting center at ivy tech on north meridian, arriving between 5 and 6 pm. At first I was told I must have ID to vote. Then, after learning my name and making a phone call, the position changed; I was offered a provisional ballot. I have video of both parts of that interaction. At two of the voting centers the lines were too long for video to be practical.
In support of my provisional ballot, I submitted a one and the same affidavit. I was told by a staff memeber that it did not have to be notarized. I also submitted some 8 or so forms of non-photo ID,
and planned to present my case at the hearing scheduled for 1 pm on the friday 10 days after the election, but when I arrived at about 1:12 pm, the meeting was adjourning, because it had been moved up an hour without notice ot me or the other affected voters. My ballot had already been rejected. I requested a copy of the video of the hearing, but have not yet received it. I attempted to raise my hand to be recognized as they were adjourning, but was told afterword there was no public comment period. Even if the public meetings law was complied with, as it likely was, I suspect there was a due process violation for moving the hearing without notice to the affected class, or at least to me.



 Interrogatory No. 6: Regarding paragraph 12 of your Second Amended Complaint, please explain what you mean by “plaintiff’s papers.”

"Papers" incudes ID, passports, voting licenses, that sort of thing. papersplease.org. It evokes the internal passport regimes of east germany, germany, and south africa, at various times in the 20th century. It is also a legal term of art used in the 4th Amendment. It is my position that demanding one's papers as a condition of voting intrudes on the right to privacy upheld in roe v wade.

Interrogatory No. 7: Regarding paragraph 14 of your Second Amended Complaint, list all voters you have identified who you believe are similarly situated. In your answer, provide the following: (a) Each voter’s name, address, phone number, and email address; (b) All dates on which you contacted the voter; (c) The method of communication for each contact you had with the voter; and (d) A brief summary of your interaction with the voter.
A: is unknown, as this information is within defendants custody and control and has not been disclosed to plaintiff at this time. Therefore b,c, d is "none".

Interrogatory No. 8: Identify all evidence, including but not limited to videos, images, witness statements, and audio recordings, which support your allegation that you were not allowed to vote on May 6, 2018 (or Tuesday May 8, 2018). Answer:

The direct evidence is my own verified statement, in the amended complaint, to which I now attest under oath.
There is indirect evidence supporting and corroborating various subclaims.
1, The oath of Jane Doe #4 and Loreta Jones is in the custody and control of defendants, I request that this be produced. The identify of jane doe #4 is known to defendants. I request that it be disclosed.
You (meaning counsel for defendants, rather than any one person) have been unwilling to cooperate in a  waiver of service of process for doe. You have failed to respond to a public records request for who the poll workers were. That judge has nted that Doe remains unidentified and unserved.
2. If d's are unwilling to stipulate that doe and jones were present and serving as the precinct officials, I request paychecks and timecards of whoever were the poll workers in 2016 and 2018.
3.  The poll book might contain my signature. I had requested a republican ballot and I think I was signed in before Doe demanded my ID.
4. The voting records should show that  I was not issued either a regular or provisional ballot.
5. I stated that I showed them a copy of the complaint and of my media credentials. Brad King can attest that the media credentials were issued. You already have the complaint as first filed.
6. The testimony of jane doe will be revelant. You are withholding her identity, and so far are being less than cooperative in  coordinating depositions or interviews. I suspect that she will testify honestly and have good recall, unless coached otherwise. I suspect Jones will be a hostile witness.
7. Doe and Jones are shown in a video or video taken in the fall of 2018. This places them at the scene of the crime. Jones was also present in the 2016 video, and was present in 2016 fall election.
@

WIN 20181106 17 13 55 Pro

WIN 20181106 17 18 25 Pro

WIN 20181105 09 51 34 Pro

@  https://www.youtube.com/watch?v=42L5inxl6_g
https://www.youtube.com/watch?v=sIChQiRfjyo
https://www.youtube.com/watch?v=dGdxbcgDlE4.
Doe 4 is the blond with the braid and glasses. Jones is still Jones.

The indirect evidence includes several new videos taken during november of 2018, which will be provided by email. see interrogatory #5 for a description. the videos are labeled with the date they were taken, with a larger number indicating a later time.



Interrogatory No. 9: Regarding paragraph 25 of your Second Amended Complaint, describe in detail how Clerk Eldridge “was on specific notice of the problem at this precinct.” In your answer, identify the specific precinct to which you are referring and describe what you mean by “problem.” Please also identify all evidence which you believe shows that the Clerk was on specific notice.

Precinct 25-2 (Old Fire Station #12-339 N Sherman Dr)
This precinct means the one at which i try to vote, at the firehouse at  n sherman, as shown in the above videos. the problem is that jones and rose and the does conspired to prevent me from voting, were not trained that voting is a constitutional right, and were not trained in how and when to offer a provisional vote. this is clear from context. eldridge was placed on notice by the filing of the initial complaint, which named her in both capacities,and set forth those details.
She was served with a summons and copy of the complaint by thomas smith on may 2d by delivering it to her office. she was not necessarily there personally at the time. Additionally, she was served that morning by the marion county sheriffs department. Thereafter, an appearance of her behalf was intered by grant helms of corpration counsel. helms had an ethical duty to communicate with his client. while helms appears to have mysterious;y disappeared, he seemed competnt and ethical enough prior to vanishing. it is reasoanble to think that she was aware of the suit and either read it or engaged in willful blindnes sif she chose not to.
Additionally, a tort caim notice had been filed within 6 months of the indicent.
Additionally, at the suggestion of Senator Donelley's office, a notarized complaint form had been filed with the both the state and the county.  You have a copy.

Interrogatory No. 10: For each count in your Second Amended Complaint, identify the specific defendants you are seeking to hold liable. Answer:

There are two sets of counts; the first incident, in 2016, and the second incident, in 2018.
Eldridge, in both capacities, and the board, in their offical capacity, are common to each count except where Rose orders plaintiff ot leave the firehall.
Rose is named as to each count in the 2016 incident.
Jones and Doe are named as to each count in the 2018 incident.  Jones was a participant in the first event, but was not named or served within the statute of limitations.

Interrogatory No. 11: Identify each person who possesses or claims to possess any fact or record relevant to Plaintiff’s claims against Defendant by stating his or her name, address, telephone number and relationship, if any, to the Plaintiff. Also provide a brief summary of what each witness or person knows about Plaintiff’s claims against Defendant.

Read literally this is overbroad and thus objected to. But to address what I think you meant,
relevant witnesses include
the board,
their staff, including brienne delaney, jenny at the front desk of the warehouse, barnes,
each person who was a poll worker at the firehouse in either 2016 or 2018,
specifically jane does 1-4, and rose,.
if known, any person who spoke with rose about my case via the hotline.
whoever trained or supervised rose.

Interrogatory No. 12: Identify each exhibit Plaintiff intends to use at trial, including a description of the document or thing. In your answer, also include a brief summary of each exhibit’s significance to your claim. Answer:

1, the videos of rose.
2. the denial of tort claim letter.
3, the hava complaint form
4, the complaint in this case
5  mo rocca video
6. the id scanner device,and soemone who knows how to use it.
7, the voter id statute
8 the hava statute,
9 the voters billof rigts poster
10 related videos of me trying to vote at various places and times
11 helen arth videos
12 the election day handbook from insos
13 poll tax poster
the stop sign poster

4 pm to 7:15 pm friday, taking a coffee break, might stop for the day.


any current or former indana secretary of state willing to testify
any represenative of common cause, such as julia vaughn,
any representative of indiana moral monday
kris kobach or todd rokita or hans spakovsky, if available, to give the perspecitive of those in favor of voter id.

Interrogatory No. 14: Do you claim that the Defendant (including employees and representatives), either with or without personal knowledge, made any admissions with respect to the matters alleged in your Complaint? If so, state: (a) The identity of the person(s) who made such admission; (b) When and where such admission was made; (c) The identity of all persons who were present, a party to and/or witnessed each such admission being made; (d) Whether you, or anyone on your behalf, made any notes, tape recordings or other such memoranda regarding each such admission; and (e) The identity of the person(s) having custody of each such notes, tape recordings or other memoranda

Interrogatory No. 15: Provide an itemized list of the amount(s) you claim as damages in this case for the violation(s) described in your complaint, and describe the basis and calculations used to compute those damages.


Interrogatory No. 16: Have you ever been arrested or been a party to any charge, complaint, lawsuit, legal action, or administrative proceeding, whether criminal or civil in nature? If so, state for each action or proceeding: (a) The caption, court and cause number; (b) The date of the action or proceeding; (c) The nature of the action or proceeding; (d) The resolution of the action or proceeding; and (e) The date the action or proceeding terminated. Answer: I AFFIRM UNDER PENALTIES OF PERJURY THAT THE FOREGOING REPRESENTATIONS ARE TRUE AND ACCURATE TO THE BEST OF MY KNOWLEDGE AND BELIEF.