2020 Zuckbuck Lawsuit

STATE OF MICHIGAN
IN THE COURT OF CLAIMS
DAN RYAN, et al.,
Plaintiffs, Case No: 20-000198-MZ
v.
Hon. Thomas C. Cameron
JOCELYN BENSON,
Defendant.
PLAINTIFFS’ 02/14/2022 RESPONSE TO DEFENDANT’S

12/17/2021 MOTION FOR SUMMARY DISPOSITION
Mark F. (Thor) Hearne, II (P40231) Heather S. Meingast (P55439)

Stephen S. Davis (pro hac pending) Erik A. Grill (P64713)
J. Matthew Belz (pro hac pending) Assistant Attorneys General
TRUE NORTH LAW, LLC Attorneys for Defendant Benson
112 S. Hanley Road, Suite 200 PO Box 30736
St. Louis, MO 63105 Lansing, MI 48909
(314) 296-4000 (517) 335-7659
thor@truenorthlawgroup.com meingasth@michigan.gov
Counsel for Plaintiffs and Special Counsel for grille@michigan.gov
Thomas More Society
Document received by the MI Court of Claims.

Thomas Brejcha (pro hac pending)
THOMAS MORE SOCIETY
309 W. Washington Street, Suite 1250
Chicago, IL 60606
(312) 782-1680
tbrejcha@thomasmoresociety.org
Counsel for Thomas More Society
Charles R. Spies (P83270

Robert L. Avers (P75396)
DICKINSON WRIGHT PLLC
350 S. Main Street, Ste 300
Ann Arbor, MI 48104
(734) 623-1672
cspies@dickinsonwright.com
ravers@dickinsonwright.com
Of Counsel
TABLE OF CONTENTS
Page
INDEX OF AUTHORITIES ..................................................................................................... iii-vi

INTRODUCTION ........................................................................................................................... 1
ARGUMENT ................................................................................................................................. 2
I. Secretary Benson’s motion for summary disposition should be denied because
discovery is not complete. ................................................................................................... 2
II. The Michigan voters and taxpayers bringing this lawsuit have standing to defend
their constitutional right to vote. ......................................................................................... 3
III. These Michigan voters and taxpayers have raised serious constitutional claims this
Court must address. ............................................................................................................ 9
A. Plaintiffs state a claim that Defendant Benson violated the Equal Protection
Clause of the Michigan Constitution. ...................................................................... 9
B. Plaintiffs state a claim that Secretary Benson violated Michigan’s
Constitution by allowing conduct that compromised the fairness and
evenhandedness of elections.................................................................................. 11
C. Plaintiffs state a claim that Secretary Benson violated Michigan law by
allowing election authorities to spend public funds for private purposes ............. 13
D. Plaintiffs state a claim that Secretary Benson violated Michigan law by
allowing illegal acquisition of ballot containers that facilitated ballot
harvesting. ............................................................................................................ 17

E. Plaintiffs state a claim that Secretary Benson violated Michigan law by
allowing the use of illegal drop boxes. ................................................................. 18
Conclusion……………………………………………… ............................................................. 20
Certificate of Service ..................................................................................................................... 21
ii
INDEX OF AUTHORITIES
Cases Page(s)
Apsey v Mem’l Hosp,

477 Mich 120 (2007) ..................................................................................................................20
Attorney Gen v PowerPick Players’ Club of Michigan, LLC,

287 Mich App 13 (2010) ..............................................................................................................2
Bush v Gore,
531 US 98 (2000) .........................................................................................................1, 9, 10, 11
Castner v Grosse Pointe Park,

86 Mich App 482 (1978) ..............................................................................................................7
Citizens Protecting Michigan’s Constitution v Secretary of State,

324 Mich App 561 (2018) ............................................................................................................7
Dalley v Dykema Gossett,

287 Mich App 296 (2010) ............................................................................................................9
Davis v Secretary of State,

333 Mich App 588 (2020) ............................................................................................................7
Election Integrity Fund, et al v City of Lansing and City of Flint,

WD-Mich Case No. 1:20-cv-950 (2021) .....................................................................................6
El-Khalil v Oakwood Healthcare, Inc,

504 Mich 152 (2019) ....................................................................................................................9
Ensink v Mecosta Co Gen Hosp,

262 Mich App 518 (2004) ............................................................................................................2
Fleming v Macomb Co Clerk,

2008 WL 2553266 (Docket No. 279966) ............................................................................12, 17
Iron Co v Sundberg, Carlson & Assoc, Inc,

222 Mich App 120 (1997) ..........................................................................................................12
Kaplan v City of Huntington Woods,

357 Mich 612 (1959) ............................................................................................................14, 15
iii
Kestenbaum v Michigan State Univ,
97 Mich App 5 (1980) ................................................................................................................15
Killeen v Wayne Co Rd Comm,

137 Mich App 178 (1984) ............................................................................................................8
Lansing Schs Ed Ass’n v Lansing Bd of Ed,

487 Mich 349 (2010) ................................................................................................................6, 7
League of Women Voters of Mich v Secretary of State,

331 Mich App 156 (2020) ............................................................................................................7
Mays v Governor of Michigan,

506 Mich 157 (2020) ....................................................................................................................9
McManus v City of Petoskey,

164 Mich 390 (1911) ............................................................................................................13, 16
Menendez v Detroit,
337 Mich 476 (1953) ....................................................................................................................8
Mich Ass’n of Home Builders v City of Troy,

504 Mich 204 (2019) ....................................................................................................................6
Moore v Ogilvie,
394 US 814 (1969) .................................................................................................................9, 10
People v Bewersdorf,

438 Mich 55 (1991) ....................................................................................................................20
Porter v City of Royal Oak,

214 Mich App 478 (1995) ............................................................................................................2
Reynolds v Sims,
377 US 533 (1964) ...........................................................................................................9, 10, 11
Sinas v City of Lansing,

382 Mich 407 (1969) ..................................................................................................................15
Skinner v Square D Co,

445 Mich 153 (1994) ....................................................................................................................2
Skutt v City of Grand Rapids,

275 Mich 258 (1936) ..................................................................................................................14
iv
Sutherland-Innes Co v Vill of Evart,
86 F 597 (6th Cir. 1898) .................................................................................................13, 14, 16
West v GMC,
469 Mich 177 (2003) ....................................................................................................................2
Statutes
MCL 166.669 ................................................................................................................................17
MCL 168.21 ....................................................................................................................................7
MCL 168.24j .....................................................................................................................18, 19, 20
MCL 168.31 ....................................................................................................................................7
MCL 168.31(1)(a) ...................................................................................................................18, 20
MCL 168.31(1)(b) ...................................................................................................................18, 20
MCL 168.665 ..........................................................................................................................18, 19
MCL 168.666 ..........................................................................................................................17, 18
MCL 168.667 ................................................................................................................................17
MCL 168.669 ..........................................................................................................................17, 18

MCL 168.670 ................................................................................................................................17
MCL 168.761d ........................................................................................................................19, 20
Rules
MCR 2.116(C)(8) ............................................................................................................................9
MCR 2.116(C)(10) ..........................................................................................................................2
MCR 2.116(I)(5)..............................................................................................................................2
MCR 2.118 ......................................................................................................................................2
MCR 2.605 ......................................................................................................................................7
MCR 2.605(A)(l) .............................................................................................................................6
v
Constitutional Provisions
Const 1963, art 7, § 26...................................................................................................................15
Const 1963, art 9, § 18...................................................................................................................15
vi
INTRODUCTION
Mark Zuckerberg, the billionaire founder of Facebook, put hundreds of millions of
dollars into influencing the 2020 presidential election throughout the country. He “donated”
funds to a tax-exempt organization called the Center for Technology and Civic Life (CTCL),1
and CTCL then made “grants” to local election officials, requiring them to spend the funds in
ways that would increase mail-in voting and facilitate ballot harvesting. See, e.g., Ex. 1, City of
Detroit Agreements with CTCL. In Michigan, election officials received more than $16 million
in Zuckerberg money. These funds went predominantly (at least 84%—likely much more) to jur-
isdictions that cast ballots for Joe Biden over Donald Trump. Because the funds were channeled
through CTCL, a “charity,” and characterized as “grants,” Zuckerberg’s “donations” were not
covered by campaign finance laws. They were unlimited and unregulated “dark money.”
By committing millions to “getting out the vote” in primarily urban and Democrat
jurisdictions, this scheme had the illegal effect of disfavoring Michigan voters in rural and
Republican jurisdictions and denying Michigan voters in these less funded districts equal access

to the ballot. As the Supreme Court explained in Bush v Gore, “[h]aving once granted the right to
vote on equal terms, the State may not, by later arbitrary and disparate treatment, value one
person’s vote over that of another.” 531 US 98, 104 (2000).
Plaintiffs are Michigan voters from districts disfavored by CTCL and therefore
disfavored by the State of Michigan in the last election. Plaintiffs do not seek to relitigate the
results of the 2020 election. Instead, they ask this Court to declare illegal all private funding and
1
“CTCL Receives Additional $100M Contribution to Support Critical Work of Election
Officials,” Oct. 13, 2020, https://www.techandciviclife.org/100m/; The Editorial Board,
“Zuckerbucks Shouldn’t Pay for Elections,” Wall Street Journal, Jan. 3, 2022,
https://www.wsj.com/articles/zuckerbucks-shouldnt-pay-for-elections-mark-zuckerberg-center-
for-technology-and-civic-life-trump-biden-2020-11640912907.
1
direction of Michigan’s elections. Defendant Benson, as Secretary of State, is Michigan’s chief
election officer, legally responsible for ensuring that election officials conduct Michigan
elections in a lawful manner. Plaintiffs therefore seek an injunction prohibiting the Secretary of
State from allowing election officials to accept private money in exchange for agreeing to fund
and conduct Michigan elections in a manner directed by a private entity.
Secretary Benson has filed a motion asking this Court to summarily dismiss these claims
brought by these Michigan voters. Secretary Benson’s motion should be denied because (a)
discovery is not yet complete, (b) these voters have standing, and (c) Plaintiffs’ claims are both
legally credible and extremely important for the Court to address before the next election.
ARGUMENT
I. Secretary Benson’s motion for summary disposition should be denied because

discovery is not complete.
Motions under MCR 2.116(C)(10) test the factual support for a plaintiff’s claim. Skinner
v Square D Co, 445 Mich 153, 161 (1994). Granting a motion for summary disposition is revers-
ible error when there is any “genuine issue of material fact,” i.e., “when the record, giving the

benefit of reasonable doubt to the opposing party, leaves open an issue upon which reasonable
minds might differ.” Attorney Gen v PowerPick Players’ Club of Michigan, LLC, 287 Mich App
13, 26-27 (2010), quoting West v GMC, 469 Mich 177, 183 (2003). Courts are “liberal in finding
genuine issues of material fact.” Porter v City of Royal Oak, 214 Mich App 478, 484 (1995).
A motion made under MCR 2.116(C)(10) is premature if discovery is not completed.
Ensink v Mecosta Co Gen Hosp, 262 Mich App 518, 540 (2004). The Court “shall give” the
parties an opportunity to amend pleadings to correct the defect as provided by MCR 2.118 unless
evidence indicates that an amendment would not be justified. MCR 2.116(I)(5).
2
Under this Court’s scheduling order, discovery remains open until the end of March. The
outstanding discovery includes full responses from CTCL, the entity that channeled donations
from Mark Zuckerberg toward Michigan election officials. CTCL required the money to be used,
among other purposes, to purchase remote, unattended ballot boxes that violated Michigan law
and facilitated mail-in voting and ballot harvesting. Information in the possession of CTCL,
therefore, is essential to the Court’s determination of the claims before it.
In response to Plaintiffs’ subpoena, CTCL has provided only publicly available
information and boilerplate objections. See Ex. 2, Subpoena to CTCL; Ex. 3, CTCL’s Response
and Objections. CTCL has refused to provide its communications with Secretary Benson or any
Michigan election jurisdictions and refused to provide the spending reports CTCL received from
Michigan jurisdictions. Plaintiffs expect motion practice on this issue.
In addition to the outstanding discovery from CTCL, Plaintiffs intend to depose Secretary
Benson, Director of Elections Jonathan Brater, and Tiana Epps-Johnson, Executive Director at
CTCL, to determine the extent of coordination between CTCL and Michigan election officials.

Secretary Benson’s motion is therefore premature prior to completion of discovery.
II. The Michigan voters and taxpayers bringing this lawsuit have standing to defend
their constitutional right to vote.
Judge Murray has already denied Secretary Benson’s standing argument. See October 16,
2020 Order at 4-5. “Here, because plaintiffs have a cause of action for a violation of the equal
protection clause, and their rights could be substantially and detrimentally affected differently
than others within the general public, they have standing to bring these claims.” Id. Nothing has
changed, except that Plaintiffs have additional data showing the dramatic bias employed by
CTCL in distributing funds in Michigan and elsewhere.
3
CTCL admits that it spent over $16 million in Michigan.2 Secretary Benson says that
Zuckerberg and CTCL distributed these funds with “no apparent preference or exclusion based
on partisan affiliation.” Benson Brief at 4. This is not true. CTCL distributed money to election
officials in a disparate manner on the basis of political ideology and urban/rural geography.
Discovery has revealed that, of the CTCL payments over $20,000 (which account for
more than $14 million of the funds paid in Michigan), 98% were paid to jurisdictions that Biden
carried in 2020. Ex. 6, Spreadsheet (created for purposes of this brief) Showing Payments Over
$20,000. Even if all the remaining payments under $20,000 went to jurisdictions that voted for
Trump—which is very unlikely—84% of the total funds paid by CTCL went to jurisdictions that
voted for Biden. Each of the 19 payments CTCL made that exceeded $100,000 went to
jurisdictions that Biden carried. Ex. 6.
Almost half of the money CTCL spent in Michigan was paid to the City of Detroit, where
Biden won 94% of the vote. See Ex. 6. Specifically, CTCL paid Wayne County $9,089,884,
according to CTCL’s filing with the IRS. There are 1,399,900 registered voters in Wayne

County,3 meaning CTCL paid $6.49 per registered voter in Wayne County. In Benton Harbor,
where Biden won 94% of the vote, CTCL paid $120,840 to a city with 9,160 registered voters.4
This is $13.19 per voter. By contrast, CTCL paid $7,787,096 to election officials outside Wayne
County that combine to represent 6,678,559 registered voters,5 or $1.16 per voter.
2
This amount is calculated using information included in CTCL’s IRS Form 990 for 2020,
attached in abbreviated form as Exhibit 4, and a supplemental document CTCL produced,
attached as Exhibit 5.
3
https://mvic.sos.state.mi.us/VoterCount/Index
4
See Ex. 6; https://electionreporting.com/4539283c-3f09-4fdf-ad93-0bfd82d32be1/county
/3820dff5-a1ed-420c-828b-f9d1ec256f11/township/City%20of%20Benton%20Harbor.
5
https://mvic.sos.state.mi.us/VoterCount/Index
4
Muskegon County is a microcosm of the CTCL’s distribution strategy. The four
jurisdictions within Muskegon County that went for Biden (City of Muskegon, City of
Muskegon Heights, City of North Muskegon, City of Roosevelt Park) received $469,690, and the
19 jurisdictions that went for Trump received $70,855.6
CTCL’s money was also inordinately directed to urban centers instead of rural
jurisdictions. CTCL paid Michigan’s 35 largest cities or townships 74% of the funds it paid
election officials, despite only 34% of Michigan’s population living in these jurisdictions.7 The
only one of Michigan’s largest 35 jurisdictions that CTCL did not fund—Georgetown
Township—is a township that Trump won in a landslide.8
Mark Zuckerberg is a billionaire. He is not a fool. He would not pay hundreds of millions
of dollars to election officials without expecting a return on his investment. The return Mark
Zuckerberg expected was that the 2020 general election would be conducted in a manner that
favored Joe Biden over Donald Trump. That goal was effected by CTCL channeling his money
to increase voter turnout of urban and Democrat voters over rural and Republican voters. The

rights of Michigan citizens, including Plaintiffs, residing in disfavored jurisdictions were
diminished, while the rights of those in favored urban jurisdictions were enhanced.
The Zuckerberg money CTCL sent to Michigan was part of a larger scheme to influence
the 2020 presidential election. The Capital Research Group found that in Pennsylvania, CTCL
spent $25 million, and counties that voted for Biden received $2.85 per capita, while counties
6
https://www.co.muskegon.mi.us/DocumentCenter/View/10302/2020-11-03_Precinct_Results;
Ex. 4; Ex. 5.
7
https://www.mlive.com/news/g66l-2019/06/592a798dce8992/michigans-75-mostpopulated-
cities-and-townships-in-2018.html; https://www.census.gov/quickfacts/MI
8
https://elections.miottawa.org/ElectionResults/Election/Summary/NOV0320
5
that voted for Trump received $0.60 per capita.9 CTCL’s payments in other battleground states
were similar. CTCL paid $45 million in Georgia ($5.33 per voter in Biden counties; $1.41 in
Trump counties); CTCL paid $7.2 million in North Carolina ($1.44 per voter in Biden counties;
$0.61 in Trump counties); CTCL paid $38.6 million in Texas ($2.03 per voter in Biden counties;
$0.66 in Trump counties).10 Claudia Tenney, a Member of Congress, found that in Texas, Ohio,
Nevada, Minnesota, Georgia, Florida, Arizona, and Pennsylvania, 90% of the $144.2 million
CTCL paid election officials went to Democrat-leaning counties.11
MCR 2.605(A)(l)12 provides:
In a case of actual controversy within its jurisdiction, a Michigan court of record may
declare the rights and other legal relations of an interested party seeking a declaratory
judgment, whether or not other relief is or could be sought or granted.
“[A]n ‘actual controversy’ exists for the purposes of a declaratory judgment where a plaintiff
pleads and proves facts demonstrating an adverse interest necessitating a judgment to preserve
the plaintiff’s legal rights.” Mich Ass’n of Home Builders v City of Troy, 504 Mich 204, 225

9
Parker Thayer, Hayden Ludwig, “Shining a Light on Zuck Bucks in the 2020 Battleground
States,” Capital Research Center, Jan. 3, 2022, https://capitalresearch.org/article/shining-a-light-
on-zuck-bucks-in-key-states/.
10
Id.
11
“New Information Confirms Zuckerberg-Connected Group Funneled Majority of Election
Payments to Democrat-Leaning Counties,” December 20, 2021, https://tenney.house.gov/media/
press-releases/new-information-confirms-zuckerberg-connected-group-funneled-majority-
election. See also, Mollie Hemingway, Rigged: how the media, big tech, and the Democrats
seized our elections, Regnery Publishing, 2021, and John Fund and Hans Von Spakovsky, Our
Broken Elections: How the Left Changed the Way you Vote, Encounter 2021.
12
In a footnote, Secretary Benson also suggests that federal standing is lacking. Benson Brief, p.
3 n.1, citing Election Integrity Fund, et al v City of Lansing and City of Flint, WD-Mich Case
No. 1:20-cv-950 (2021). This is irrelevant to a determination of standing under Michigan law.
See Lansing Schs Ed Ass’n v Lansing Bd of Ed, 487 Mich 349, 372 (2010) (“The standards for
determining standing in a Michigan court are, for better or worse, much less stringent than the
federal standard.”), cited in October 16, 2020 Order at 4.
6
(2019). “[W]henever a litigant meets the requirements of MCR 2.605, it is sufficient to establish
standing to seek a declaratory judgment.” LSEA, 487 Mich at 372. A litigant may have standing
in this context if the litigant has a special injury or right, or “substantial interest, that will be
detrimentally affected in a manner different from the citizenry at large.” Id. (cleaned up).
Michigan voters are entitled to fair, just and lawful elections—something CTCL’s
payments to election officials prevented, and something for which Secretary Benson is
responsible. See MCL 168.21, 168.31; see, e.g., League of Women Voters of Mich v Secretary of
State, 331 Mich App 156, 181-183 (2020), aff’d in part, vacated in part on other grounds 506
Mich 561 (2020); Citizens Protecting Michigan’s Constitution v Secretary of State, 324 Mich
App 561, 566 (2018), aff’d 503 Mich 42 (2018); see also Sept. 17, 2020 Stipulation in Daunt v
Benson, United States District Court for the Western District Michigan, No. 1:20-cv-522 (Ex. 7)
(in which Secretary Benson stipulated to the release of defendant local election officials on the
basis that, “[t]hough the city and county clerks play a role, the Secretary of State has the ultimate
responsibility for maintaining Michigan’s voter rolls”); Davis v Secretary of State, 333 Mich

App 588, 598 (2020) (instructions issued by the Secretary of State under MCL 168.31 are
binding on local election officials conducting elections).
These Michigan voters suffered an irreparable constitutional injury as a result of Secre-
tary Benson’s failure to supervise and regulate the conduct of the 2020 general election as Michi-
gan law requires, and they will continue to suffer such injury without Court intervention.13 Speci-
fically, Secretary Benson failed to prevent public election officials in selected jurisdictions, who
answer to her, from accepting private funds in exchange for the officials conducting the election
13
As Judge Murray stated, the termination of the 2020 election did not make this matter moot.
October 16, 2020 Order at 9 n.9, citing Castner v Grosse Pointe Park, 86 Mich App 482, 487
(1978).
7
as directed by Zuckerberg and the organization (CTCL) through which he paid the money.
To contest Plaintiffs’ standing, Benson argues that, even if Zuckerberg and CTCL
favored some voters over others on her watch, Plaintiffs may not object to this scheme because
the jurisdictions where they reside received some money from CTCL. Benson Brief at 4. This is
irrelevant, because the payments received by Plaintiffs’ jurisdictions are grossly disproportionate
to the money CTCL paid to urban, Democrat jurisdictions.14 And this disparity between their
jurisdictions and others was part of a larger scheme to channel money toward urban, Democrat
jurisdictions. See supra. So, Plaintiffs’ rights as voters, voting in alignment with other such
voters who were largely from more rural and less urban districts, were diminished by
Defendant’s failure to ensure the fairness of Michigan elections, whether their particular
jurisdictions received CTCL money or not.
In addition to their standing as Michigan citizens whose rights to vote have been violated,
Plaintiffs also have standing as taxpayers, because there is a “threat that [the taxpayer] will
sustain substantial injury or suffer loss or damage as a taxpayer, through increased taxation and

the consequences thereof.” Killeen v Wayne Co Rd Comm, 137 Mich App 178, 190 (1984),
quoting Menendez v Detroit, 337 Mich 476, 482 (1953).
In other words, in addition to injuries laid out above to Plaintiffs’ right to vote, they are
injured as taxpayers because the disparate allocation of private CTCL money means that taxes in
their jurisdictions will have to be increased in future elections to provide access to the ballot
equivalent to the access provided in more heavily CTCL-funded jurisdictions. The disparities
14
CTCL states that it made $5,000 payments to Osceola and Washington Townships, where
plaintiffs Joellen M. Pisarczyk and Paul Driscoll voted, respectively. CTCL paid $33,369 to
West Bloomfield Township, where plaintiff Myron Zolkewsky votes and resides, and $26,194 to
the City of Novi, where plaintiff Dan Ryan resides and votes. West Bloomfield Township, which
received the largest amount of these jurisdictions, received only $1.69 per voter (56,626 voters),
paling in comparison to the per capita amounts received in Detroit and Wayne County in general.
8
between voters in Michigan created by CTCL’s funding scheme are substantial injuries that must
be remedied, and they can only be remedied by increased taxation. Thus Plaintiffs, as taxpayers,
have standing to challenge the illegal funding scheme leading to those disparities.
III. These Michigan voters and taxpayers have raised serious constitutional claims this
Court must address.
Secretary Benson asks this Court to dismiss these Michigan citizens’ claims. Under
Michigan rules of civil procedure, a court must accept all well-pleaded factual allegations as true
and construe them in the light most favorable to the nonmoving party. Dalley v Dykema Gossett,
287 Mich App 296, 304-305 (2010). “A motion under MCR 2.116(C)(8) may only be granted
when a claim is so clearly unenforceable that no factual development could possibly justify
recovery.” Mays v Governor of Michigan, 506 Mich 157, 172-173 (2020), quoting El-Khalil v
Oakwood Healthcare, Inc, 504 Mich 152, 160 (2019). Plaintiffs’ claims satisfy this standard.
A. Plaintiffs state a claim that Defendant Benson violated the Equal Protection
Clause of the Michigan Constitution.
The Equal Protection Clause of the Michigan Constitution (which is coextensive with that

of the United States Constitution), guarantees every voter a right to vote on equal terms with all
other voters. “The idea that one group can be granted greater voting strength than another is
hostile to the one man, one vote basis of our representative government.” Moore v Ogilvie, 394
US 814, 819 (1969) (relying on Reynolds v Sims, 377 US 533 (1964), to invalidate an Illinois
rule making it more burdensome for people in populous counties to nominate statewide
candidates than for people in more rural counties). This principle applies to all aspects of voting,
prohibiting all “arbitrary and disparate treatment of the members of [the] electorate.” Bush v
Gore, 531 US 98, 105 (2000) (applying equal protection principles to recount standards).
9
Any “arbitrary and disparate treatment” by the government that has the effect of favoring
one person’s vote over another’s is a violation of equal protection. See, e.g., Bush, 531 US at 105
(holding that equal protection prohibited arbitrary recount procedures); Moore, 394 US at 819
(invalidating a nomination rule because it favored voters in less populous counties); Reynolds,
377 US at 563 (prohibiting redistricting plan that resulted in “weighting the votes of citizens
differently, by any method or means, merely because of where they happen to reside”). Equal
protection violations are not limited to measures that discriminate on the basis of a suspect (or
even benign) characteristic, such as race or religion. There need not be any known characteristic
distinguishing one voter from another: any action favoring or disfavoring some voters, even
something arbitrary and voter-blind, is a violation of equal protection. Bush, 531 US at 105
(holding that arbitrary, non-uniform handling of votes denies voters’ equal protection even where
voters’ identities were unknown).
The Michigan voters bringing this lawsuit pleaded more than adequate arbitrary and
disparate treatment of voters to state an equal protection claim. Defendant Benson allowed

Zuckerberg, through CTCL, to spray money all over Michigan according to their own
distribution criteria, and to use that money to direct the conduct of election officials under her
supervision. The most favorable potential description of this funding process (that is, ignoring
for a moment the considerable evidence of outright political bias) is that it had no regard for
uniformity or rational distribution throughout the state. Allowing individual jurisdictions to run
their elections in concert with private parties resulted in spending and vote-gathering practices
that varied throughout the state purely on the basis of where voters lived. See Reynolds, 377 US
at 568 (“Simply stated, an individual’s right to vote . . . is unconstitutionally impaired when its
10
weight is in a substantial fashion diluted when compared with votes of citizens living in other
parts of the State.”).
The Plaintiffs have alleged that Secretary Benson allowed the 2020 election to be
conducted under a private funding scheme that resulted in (1) much more money to provide
access to the ballot for voters in favored urban and Democrat jurisdictions than for voters in rural
and Republican jurisdictions and (2) allowing mail-in and absentee ballots to be harvested or
collected differently in different jurisdictions, following the direction of private parties. See, e.g.,
First Amended Complaint (“Compl.”) ¶¶ 31, 34, 38, 43. These are both examples of arbitrarily
treating voters and votes differently depending on where a voter lives. Bush, 531 US at 105
(holding that arbitrary, non-uniform handling of votes denies voters equal protection); Reynolds,
377 US at 568 (“A citizen, a qualified voter, is no more nor no less so because he lives in the city
or on the farm.”). “The weight of a citizens’ vote cannot be made to depend on where he lives.”
Reynolds, 377 US at 567. These allegations are sufficient to state a claim that Secretary Benson
failed in her statutory and constitutional duty to supervise Michigan elections in a manner

consistent with the Equal Protection Clause.
B. Plaintiffs state a claim that Secretary Benson violated Michigan’s Constitution

by allowing conduct that compromised the fairness and evenhandedness of
elections.
By alleging that election officials under Secretary Benson’s supervision spent private
money to conduct elections according to arbitrary standards set forth by a private donor, and that
these unequal expenditures favored some Michigan citizens over others, Plaintiffs more than
adequately pleaded a violation of the purity of elections clause of the Michigan Constitution.
Secretary Benson wrongly claims that only the Legislature is bound by the purity of elec-
tions clause. Benson Brief at 8-9. Benson further wrongly claims that that provision is only vio-
11
lated when a legislative enactment treats candidates differently. Id. The constitutional guarantee
of fair and honest elections for Michigan citizens extends beyond legislative acts to the
administration of elections supervised by Secretary Benson as Michigan’s chief election officer.
For example, in 2008, the Court of Appeals found that a county clerk had violated the
purity of elections clause by the “mailing of absent voter ballot applications to only a select
group of eligible absent voters.” Fleming v Macomb Co Clerk, unpublished opinion per curiam
of the Court of Appeals, issued June 26, 2008; 2008 WL 2553266, at *7 (Docket No. 279966)
(Ex. 9). The Court specifically held that the “county clerk’s actions hinder the evenhanded
application of election laws by failing to provide [a] benefit to all eligible absent voters,” so “the
clerk’s actions violate the purity of elections clause.” Id. (emphasis added). This case found an
unconstitutional violation of the purity of Michigan elections where a local election official took
an action that increased access to the ballot for some voters and not others. This is precisely what
Plaintiffs have alleged occurred under Defendant’s supervision.
Nor are Plaintiffs’ purity of elections allegations “vague,” as Secretary Benson claims.

These Michigan voters plead, “The purity of elections clause is violated when local election
officials take actions that favor one group of voters over others.” Compl. ¶ 58, citing Fleming.
Plaintiffs’ factual allegations include details of a scheme, approved by Defendant, by which local
election officials applied for and received private funds, as well as private instructions, and,
following those instructions, administered the election in a way that favored some Michigan
voters (those in Democrat-voting and urban districts receiving large grants) over others (those in
other districts, which are largely more rural and Republican-voting). Further specificity is not
required at the pleading stage nor possible prior to discovery. See, e.g., Iron Co v Sundberg,
Carlson & Assoc, Inc, 222 Mich App 120, 124 (1997) (setting forth notice pleading standards).
12
Discovery from the Defendant shows that Jonathan Brater, Michigan's Director of
Elections, acknowledged the problem of private election funding in a January 2021 email string.
Ex. 10. In discussing a media inquiry about CTCL’s activities, government attorney Melissa
Malerman opined that the Defendant should “put some parameters around” private funding of
elections “before 2022,” and acknowledged the “perception headache” of private interest groups
paying for elections that serve their interest. Id. Brater “[a]greed on the general concern.” Id.
Finally, these Michigan voters allege Secretary Benson is responsible for actions of the
election officers she supervises. Compl. ¶¶ 8-9. The voters bringing this lawsuit need not argue
that Secretary Benson was personally involved in the receipt of money from Zuckerberg or his
conduit organization, CTCL. As Michigan’s “chief election officer,” Secretary Benson has the
statutory and constitutional responsibility to assure that Michigan elections are conducted in
conformity with the law. See id. Where local election officials under Secretary Benson’s
supervision systematically broke the law, particularly in a manner she approved of and indeed
encouraged, she is legally responsible. See Ex. 10.

C. Plaintiffs state a claim that Secretary Benson violated Michigan law by allowing
election authorities to spend public funds for private purposes.
Plaintiffs stated a valid claim that Defendant Benson violated Michigan law by allowing
election officials in Michigan to use public funds for private purposes. Election officials simply
did not have the power to use funds in their possession, from whatever source, to pursue ends
designated by CTCL or any private party. That is because public funds, of any origin, must be
used for public purposes. Compl. ¶ 64, citing McManus v City of Petoskey, 164 Mich 390, 395
(1911) (holding that insurance proceeds (i.e., resources not obtained through taxation) could not
be put to a private purpose); see also Sutherland-Innes Co v Vill of Evart, 86 F 597, 600-601 (6th
Cir. 1898) (explaining fundamental principle that all public obligations are implicitly secured by
13
taxation (barring legislative authorization to use a special fund) and therefore void if they have a
private purpose).
Plaintiffs have alleged the contours of a private financing scheme that involved CTCL, a
private party, “donating” funds to public officials in Michigan on the condition that such funds
would be used according to CTCL’s instructions. Compl. ¶¶ 30-37. The fact that CTCL, rather
than the Legislature, established the acceptable uses of Michigan funds, is sufficient to render the
scheme illegal under Michigan municipal finance law. “Contracts which involve an attempt to
use public money for the furtherance of a private enterprise are void.” Kaplan v City of
Huntington Woods, 357 Mich 612, 618 (1959) (invalidating city’s grant of a restriction on
property as illegal transfer of public property for private use); Skutt v City of Grand Rapids, 275
Mich 258, 266 (1936); see also Sutherland-Innes Co, 86 F at 600-601 (barring legislative
authorization to use a private fund, all public obligations imply a commitment to use the power
of taxation, so must have a legitimate, public purpose).
Looking at it differently, no one could dispute that it would have been illegal for state

officials to take orders from CTCL regarding expenditure of state funds without compensation.
“Municipalities may not give away public property without a consideration.” Kaplan, 357 Mich
at 619. CTCL cannot make what would be an illegal arrogation of power (presumptuously
directing election officials) into a philanthropic benefaction merely by accompanying it with
large checks. Under Michigan law, state actors doing the bidding of private parties is illegal, no
matter how much those parties have paid for the privilege. See Sutherland-Innes Co, 86 F at 600-
601; see also OAG, 1980, No. 5818 (requiring legislative approval for county to enter into
contract with non-governmental entity to use government-owned voting machines).
14
Thus, Plaintiffs’ Count III states a valid claim whether or not the Court finds that the
entire CTCL funding scheme violated the Michigan Constitution. Const 1963, art 7, § 26; Const
1963, art 9, § 18. However, Plaintiffs stand by their claim that the scheme is also
unconstitutional. Specifically, Michigan courts have held that gifts and contracts to dispose of
public property for private purposes violate the Michigan Constitution by committing public
funds without a legitimate public purpose, legislative authorization, and/or adequate
consideration. See, e.g., Kestenbaum v Michigan State Univ, 97 Mich App 5, 22
(1980), aff’d 414 Mich 510 (1982) (preventing public university from giving private party access
to enrollment lists partly on the basis that Const 1963, art 9, § 18 mandates that “public funds
may not be used to support a private purpose”); Sinas v City of Lansing, 382 Mich 407, 412
(1969) (Const 1963, art 7, § 26 “means that in the absence of statutory authority, the city cannot
give away urban renewal land, even for a public purpose.”); Kaplan, 357 Mich at 619 (“A gift or
donation of money or property by the city would, in our opinion, constitute a violation of both
the constitutional provisions [preceding Const 1963, art 7, § 26; Const 1963, art 9, § 18].”); see

also OAG, 1981, No. 5860 (applying Const 1963, art 7, § 26 to question whether adequate
consideration existed for sale of public property for less than fair market value); OAG, 1980, No.
5818 (county contract with private party to use government-owned voting machines required
legislative authorization that included establishing just consideration in order to comply with
Const 1963, art 9, § 18); OAG, 1980, No. 5402 (Const 1963, art 9, § 18 requires legislative body
authorizing grant to private party to preserve historical landmark to determine public benefit
constitutes adequate consideration); OAG, 1977, No. 5212 (applying Michigan Supreme Court’s
holding under Const 1963, art 7, § 26 in Sinas, 382 Mich at 412, to the effect that, “in the
absence of statutory authority, a city may not appropriate its public funds or property even for a
15
public purpose”).15 Defendant cites no legislative authorization or public purpose to support the
election officials’ acceptance or use of CTCL funds according to CTCL guidelines.
Instead, Defendant proposes that these constitutional provisions governing municipal
spending do not apply to “receipt and use of grant funds.” Benson Brief at 11. This description
wholly ignores the novel and likely most illegal feature of CTCL’s funding scheme: that
government officials agreed to spend now-public grant proceeds according to CTCL’s
instructions and to report back regarding such spending. It is not at all self-evident (and
Defendant’s brief includes no argument) that such agreements to be accountable to CTCL for
spending of public funds do not qualify as “obligation[s] legally enforceable against [the state]
for the benefit of another” within the meaning of the Constitution’s limitations on municipal
action. Benson Brief at 11. Because the above cases have applied the provisions to many less
straightforward financial arrangements, and because Defendant has made no argument
distinguishing those cases from the complete arrangement between CTCL and election officials
here, Plaintiffs’ claim that this scheme offends Michigan’s Constitution has sufficient legal basis

to survive a motion for summary disposition.
In sum, Count III states a valid claim that Defendant violated Michigan law, including the
Michigan Constitution, by permitting election officials to participate in the CTCL election-
funding scheme and expend public funds for private purposes. McManus, 164 Mich. at 395;
Sutherland-Innes Co, 86 F at 600-601.
15
This is perhaps because, as the Sixth Circuit has recognized since the 19th century, all public
obligations imply a commitment to use the power of taxation. Sutherland-Innes Co, 86 F at 600-
601.
16
D. Plaintiffs state a claim that Secretary Benson violated Michigan law by allowing
illegal acquisition of ballot containers that facilitated ballot harvesting.
As Plaintiffs pleaded, Michigan election law allocates the expenses of running an election
to public bodies at the state, county and local levels. Compl. ¶¶ 16, 39-40, 69-71; see, e.g., MCL
168.666 (providing for the Secretary of State to provide certain items “at state expense”), MCL
168.667 (providing for boards of county election commissioners to provide various paper
supplies “at the expense of their respective counties”), MCL 168.669 (providing for city or
township boards of election commissioners to provide supplies in elections above the local level
“at the expense of the respective city or township”), and MCL 168.670 (same at local elections).
MCL 166.669 specifically provides for public funding for acquisition of ballot
containers: “[f]or a federal, state, district, or county primary or election, a city or township board
of election commissioners shall provide, at the expense of the respective city or township, each
of the following (a) For each election precinct, a ballot container approved under section24j to
be utilized in the precinct” (emphasis added).
As Plaintiffs further pleaded, because state law provides for public provision of ballot

containers and does not contemplate purchases of drop boxes beyond statutory requirements,
public officials’ acquisition of drop boxes with private funding was illegal. See Ex. 9, Fleming,
2008 WL 2553266, at *4; Compl. ¶¶ 68-73. That is because local officials have only the powers
specifically assigned to them by law: “The extent of the authority of the people’s public agents is
measured by the statute from which they derive their authority, not by their own acts and
assumption of authority.” Fleming, 2008 WL 2553266, at *4.
Defendant’s Brief does not address this principle or this authority. Instead, it declares that
interpreting MCL 168.669, which authorizes public provision of ballot containers, to exclude
17
state officials from providing additional drop boxes and other supplies, would be “absurd.”
Benson Br. at 13. This “argument” fails to demonstrate a lack of legal foundation for Count IV.
Significantly, Judge Murray, in his October 16, 2020 opinion, did not find Plaintiffs’
interpretation of Michigan law at all absurd: “[I]t is certainly true that both MCL 168.666 and
MCL 168.669 require public sources of funding for ballot boxes.” October 16, 2020 Order at 7.16
Count IV states a valid claim that the acquisition of ballot drop boxes using CTCL funds
exceeded the statutory authority of election officials under Defendant’s supervision, and that
Defendant Benson breached her duties under Michigan election law by consciously overlooking
their illegal actions. See MCL 168.31(1)(a) and MCL 168.31(1)(b).
E. Plaintiffs state a claim that Secretary Benson violated Michigan law by allowing
the use of illegal drop boxes.
As pleaded by Plaintiffs, Michigan law requires Secretary of State Benson to approve
ballot containers. Compl. ¶¶ 42, 44, 74; see MCL 168.665 (making it illegal for anyone to sell to
any jurisdiction or township clerk “[a]nything which is required by the election law to be
approved, prescribed or recommended by the secretary of state or state director of elections”

unless the sale is approved “by the state bureau of elections”); MCL 168.24j (laying out the
requirements and approval process for ballot containers, and making it a misdemeanor for a clerk
to use or permit the use of a ballot container that has not been approved by the Secretary of
State). Secretary Benson did not approve the ballot drop boxes purchased and deployed at the
16
Judge Murray went on to confirm the relevance of evidence that “(1) ballot boxes were pur-
chased with private grant money and (2), if they were, how many were purchased and by
whom.” October 16, 2020 Order at 7. Discovery has yielded such evidence. For example, a
“CTCL COVID-19 Response Grant Report” from the City of Detroit states that between June 15,
2020, and December 31, 2020, Detroit spent $160,000 of its “grant funds” on ballot drop boxes.
Ex. 1. An application from the Township of Canton in Wayne County to CTCL requested
$42,931 in funds, with $4,449 to be used on ballot drop boxes. Ex. 8, Canton CTCL Docs. A
spreadsheet from the Township of Canton shows a $4,449 expense for a ballot drop box. Id.
18
direction of CTCL, which are unambiguously “ballot containers” within the ambit of Section
168.24j. Secretary Benson’s motion does not deny this. Without her approval, their acquisition
and use were illegal. MCL 168.24j; MCL 168.665.
Moreover, Plaintiffs alleged that the ballot drop boxes acquired with CTCL funds do not
satisfy the requirements of MCL 168.24j for a secure ballot container. Compl. ¶¶ 42-46;
Secretary of State’s Manual for Boards of County Canvassers chapter VI (Compl. Appendix).
Defendant does not contest this allegation either, except to point out that it has not yet been
proved, which is typical at the pleading stage. Benson Brief at 11.
These illegalities exist regardless of the additional requirements for ballot “drop boxes”
imposed by the recently adopted MCL 168.761d. Contrary to Defendant’s characterization,
Section 761d does not authorize the purchase of additional drop boxes, much less with privately
donated funds. MCL 168.761d. Instead, it imposes additional requirements for ballot drop boxes
without repealing the previously established requirements of MCL 168.24j. Nothing in the newer
statute exempts “absent voter ballot drop boxes” from the requirements applicable to all “ballot

containers” under MCL 168.24j, including the requirement of approval by the Defendant herself
and several requirements regarding the physical constitution of ballot containers. MCL 168.24j.
In her Brief, Benson faults Plaintiffs for “failing to reconcile” the two provisions
applicable to CTCL’s sponsored drop boxes and suggests, correctly, that overlapping statutes are
to be read “harmoniously.” Benson Brief at 13. Curiously, however, even though the
requirements of the two statutes are compatible with one another, the only “harmonious”
interpretation Defendant proposes is to read the latter statute, which she states without support is
“more specific,” as completely replacing the former. Id.
19
Completely obviating every requirement of a longstanding election law in favor of a
more recent version that does not have similar scope or content, even though the Legislature
declined to repeal the earlier statute, is not a natural or a “harmonious” reading of the two
compatible statutes. Nor is it supported by Michigan law, which includes a preference for
reading statutes to “dovetail harmoniously,” meaning “to give effect to both.” People v
Bewersdorf, 438 Mich 55, 69 (1991) (rejecting a “forced construction that placed [] two statutes
in conflict”). Since the Legislature did not repeal prior requirements, and since MCL 168.24j is
completely unambiguous in its application to all “container[s] used to secure ballots,” MCL
168.761d can only be seen as imposing additional requirements on drop boxes. See also Apsey v
Mem’l Hosp, 477 Mich 120, 129 n 4 (2007) (“[I]n construction of a particular statute, or in the
interpretation of its provisions, all statutes relating to the same subject, or having the same
general purpose, should be read in connection with it, as together constituting one law, although
enacted at different times, and containing no reference one to the other.”).
Under this “harmonious” reading, CTCL-sponsored drop boxes should comply with all

compatible requirements of both statutes. Defendant’s Brief lacks any claim that the CTCL-
sponsored drop boxes have done so. Benson Brief at 12-13. Plaintiffs have alleged, and are
confident that discovery will demonstrate, that they have not. Count V therefore sets forth a valid
claim that, by allowing the use of unapproved, insecure ballot containers that were illegal under
applicable election laws, Secretary Benson breached her duties under Michigan law. MCL
168.31(1)(a) and MCL 168.31(1)(b).
CONCLUSION
For these reasons, Defendant’s motion for summary disposition should be denied.
20
Dated: February 14, 2022 Respectfully submitted,
/s/ Mark F. (Thor) Hearne, II

MARK F. (THOR) HEARNE, II, #P40231
Stephen S. Davis (pro hac pending)
J. Matthew Belz (pro hac pending)
TRUE NORTH LAW, LLC
112 S. Hanley Road, Suite 200
St. Louis, MO 63105
(314) 296-4000
thor@truenorthlawgroup.com
Counsel for Plaintiffs and Special Counsel for

Thomas More Society
Thomas Brejcha (pro hac pending)

THOMAS MORE SOCIETY
309 W. Washington Street, Suite 1250
Chicago, IL 60606
(312) 782-1680
tbrejcha@thomasmoresociety.org
Counsel for Thomas More Society
Charles Spies
Robert Avers

Dickinson Wright, PLLC
350 S. Main Street, Suite 300
Ann Arbor, MI 48104
(734) 623-1672
ravers@dickinson-wright.com
Of Counsel
Certificate of Service
The undersigned certifies that on February 14, 2022, he served a copy of the above
document in this matter on all counsel of record and parties via the Court’s online filing system.
/s/ Mark F. (Thor) Hearne, II
21
EXHIBIT 1

Friday, January 29, 2021
CTCL COVID-19 Response Grant Report
Name Janice Winfrey
Email Winfreyj@detroitmi.gov
State Michigan
Jurisdiction Name City of Detroit
Office Name Department of Elections
1. Total CTCL COVID-19 Response 7436450

Grant received:
2. Please indicate how much of the grant funds were spent on the following public purposes
between the dates of June 15, 2020 and December 31, 2020:
$ Amount
a. Ballot drop boxes 160000

b. Drive-through voting 0
c. Personal protective equipment (PPE) for
staff, poll workers, or voters 0
d. Poll worker recruitment funds, hazard pay,

and/or training expenses 5600000
e. Polling place rental and cleaning expenses 250000
f. Temporary staffing support 50000

g. Election department real estate costs, or
costs associated with satellite election 630000
department office
h. Vote-by-mail/Absentee voting equipment
or supplies 200000
i. Election administration equipment 350000

j. Voting materials in languages other than
English 0
k. Non-partisan voter education 200000
3. Total grant expenditures on 7440000

sections 2a -2k:
1
EXHIBIT 1
RYAN 022905
5. I certify that grant funds have only
been expended for the public purpose
of improving, administering and
ensuring the safety of elections.
Your initials: JW
If all the grant funds have not been expended, you may request a 6-month grant extension which will
give you additional time to expend funds for the public purpose of improving and ensuring the safety of
elections in 2021. If you request an extension, you'll be required to submit another grant report by July
31, 2021.
6. Are you interested in requesting a No, I do not need an extension.

6 -month extension to your grant
agreement in order to spend down
your grant funds?
Here's an opportunity to celebrate your accomplishments! What did you do with the CTCL
COVID-19 Response grant funds that you're most proud of?
Given the COVID-19 environment and intensity of the Presidential Election, the the &.4 Million grant
funds, allowed us to hire more quality staff because we were able to pay them more. The increase in
poll worker pay amplified our recruitment efforts and we believe it was the singular factor that led to a
positive election in 2020.
If your annual budget for elections permanently doubled, what would you be able to accomplish
that you can't accomplish now?
We would be able to recruit, train more quality pollworkers, which directly impacts the outcome of each
election, especially during a Covid-19 environment. We are requesting additional Grant Fund assistance
for the 2021 election cycle.

Any other thoughts you'd like to share?
We created a new expectation for the public, because we significantly increased the number of ways
voter can vote. Without the $7.4 M grant funds, we would not have had significant challenges, with the
administration of the 2020 President Election. We have created a new normal in terms of how voters
expect to vote in the City of Detroit. The funding structure established must be preserved for future
elections. We are requesting grant funds for the current year.
Once a month, we send out a Yes, I'd like to receive CTCI2s newsletter.
newsletter called ELECTricity, which
helps election officials stay current
with election administration stories,
technology, and best practices. We
also send periodic updates about
CTCL's trainings, resources, and tools.
Would you like to receive this
newsletter?
Today's Date Friday, January 29, 2021
EXHIBIT 1
RYAN 022906
A...7 CENTER FOR
TECH AND
CIVIC LIFE
July 30 ,2020
City of Detroit
Office of the City Clerk
2 Woodward Avenue, Suite #200
Detroit, Michigan 48226
To whom it may concern,
I am pleased to inform you that the Center for Tech and Civic Life ("CTCL") has decided to award you a
grant to support the work of the City of Detroit.
The following is a description of the grant:
AMOUNT OF GRANT: Two hundred thousand US dollars (USD $200,000).
PURPOSE: The grant funds must be used exclusively for the public purpose of
planning and operationalizing safe and secure election administration in
the City of Detroit.

Before we transmit these funds, we ask that you sign this agreement promising to use the grant funds in
compliance with United States tax laws. Specifically, by signing this letter you agree to the following:
1. The City of Detroit is a local government unit or political subdivision in the meaning of 26
USC 170(c)(1).
2. This grant shall be used only for the public purpose described above, and for no other
purposes.
3. The City of Detroit shall not use any part of this grant to give a grant to another
organization unless CTCL agrees to the specific grant in writing.
4. The City of Detroit has made a plan to safely staff a sufficient number of polling places for
the August 4, 2020 primary election, and has made an assessment that to fulfill that plan,
it will provide election workers supplemental pay. The City shall use the funds from this
grant to provide such supplemental pay, and the City shall expend the amount of this
grant by December 31, 2020.
EXHIBIT 1
RYAN 022907
5. The City of Detroit shall produce a report documenting how this grant has been expended
in support of the activities described in paragraph 4. This report shall be written and sent
to CTCL by January 31, 2021 or in any other format approved by CTCL.
6. The City of Detroit shall not reduce the budget of the City Clerk of Detroit ("the Clerk")
fail to appropriate or provide previously budgeted funds to the Clerk for the term of this
grant. Any amount reduced or not provided in contravention of this paragraph shall be
repaid to CTCL up to the total amount of this grant.
7. CTCL may discontinue, modify, withhold part of, or ask for the return all or part of the
grant funds if it determines, in its sole judgment, that (a) any of the above conditions have
not been met or (b) it must do so to comply with applicable laws or regulations.
8. The grant project period of June 15, 2020 through December 31, 2020 represents the
dates between which covered costs may be applied to the grant.
Your acceptance of these agreements should be indicated below. Please have an authorized
representative of The City of Detroit sign below, and return a scanned copy of this letter to us by email at
grants@techandciviclife.org
On behalf of CTCL, I extend my best wishes in your work.
Sincerely,

Tiana Epps Johnson
Executive Director
Center for Tech and Civic Life
CITY OF DETROIT,
a MOigan municipal corporation
By:
Title:
Date:
CENTER FOR TECH & CIVIC LIFE

HELLOPTECHANDCIVICLIFE.ORG
PAGE 2
EXHIBIT 1
RYAN 022908
DocuSign Envelope ID: 4E4F0D32-595A-44F7-9498-44ED2E9D0D7D
August 25, 2020
City of Detroit
To whom it may concern:

AMOUNT OF GRANT: Three million, five hundred and twelve US dollars (USD $3,512,000).
the City of Detroit in accordance with the attached Detroit Safe Voting
Plan 2020
1. The City of Detroit is a local government unit or political subdivision in the meaning of
26 USC 170(c)(1).
purposes.
EXHIBIT 1
RYAN 022909
organization unless CTCL agrees to the specific sub -recipient in advance, in writing.
4. The City of Detroit has produced a plan for safe and secure election administration in
2020, including an assessment of election administration needs, budget estimates for
such assessment, and an assessment of the impact of the plan on voters. This plan is
attached to this agreement. The City shall expend the amount of this grant for purposes
contained in this plan by December 31, 2020.
5. The City of Detroit shall produce a report documenting how this grant has been
expended in support of the activities described in paragraph 4. This report shall be
provided to CTCL by January 31, 2021.
grant funds if it determines, in its sole judgment, that (a) any of the above conditions
have not been met or (b) it must do so to comply with applicable laws or regulations.
8. The grant project period of June 15, 2020 through December 31, 2020 representsthe
representative of The City of Detroit sign below, and return a scanned copy of this letter to us by email

at grants@techandciviclife.org
Sincerely,
CuAG„ AkijghAtcy
Tiana Epps Johnson

Executive Director

HELLO@TECHANDCIVICLIFE.ORG
PAGE 2
EXHIBIT 1
RYAN 022910
CITY OF DETROIT
A Michigan Municipal Corporation
By:
Detroit City Clerk

Title:
Date: 08-25-20

PAGE 3
EXHIBIT 1
RYAN 022911
APPROVED: Detroit Safe Voting Plan
City of Detroit
Draft Plan to be submitted to CTCL
Mike Duggan, Mayor of Detroit, and Janice Winfrey, City Clerk of Detroit, are working collaboratively on
the August and November 2020 elections to: reduce the risk of exposure to coronavirus for our
residents as well as our election staff and poll workers; identify best practices; innovate to efficiently
and effectively educate our residents about how to exercise their right to vote; be intentional and
strategic in reaching our historically disenfranchised residents and communities; and, above all, ensure
the right to vote in our dense and diverse communities.
Michigan's 2020 Election Administration Climate
Michigan municipalities are faced with conducting two expensive elections in November. First, Michigan
election law requires every precinct to be open on election day for in -person voting regardless of the
number of voters who cast ballots by mail. Staffing Detroit's 501 precincts has historically been the
largest election expense. Second, the expected skyrocketing volume of mail ballots driven by the COVID-
:19 pandemic will incur costs for staffing and equipment that will rival typical election day expenses.
There is certainty that the coronavirus pandemic will continue to infect our state and nation through the
fall and likely well into 2021. Michigan election officials typically conduct presidential elections with 25 —
30% of the voters casting ballots by mail and 70— 75% casting them in -person on election day. It now
appears that mail balloting may account for 65 70% of the turnout. This trend is breaking municipal
election budgets beginning with the higher than expected mail turnout in the August Primary that will
continue through the November General Election.
The federal government provided a small token of support: through the CARES Act earlier this year. The

funds were provided to the Secretary of State and have been used to issue mail ballot applications to all
voters and provide several items such as PPE and equipment to election officials. Both Detroit and
Michigan's budgets have been hard hit by the resulting economic downturn making additional funding
of the city's election preparations unlikely,
In the runup to the August 4 Primary, Detroit is having difficulty recruiting the targeted 2,004 poll
workers. For the General Election the target doubles as 4,008 poll workers will be necessary. There are
many challenges to opening polling place in a pandemic and processing a historically high volume of mail
ballots.
We have concerns about how to best facilitate voter participation and limit exposure to coronavirus.
Due to COVID-19, the Department of Elections has overspent its year-to-date budgeted resources. If no
plan is approved, it may leave Detroit with no choice but to make tough decisions between health and
the right to vote; between budget constraints and access to fundamental rights. The time that remains
between now and the November Election provides an opportunity to plan for the highest possible voter
turnouts in the safest possible ways.
Supplemental Election Administration Needs for 2020
EXHIBIT 1
RYAN 022912
After thorough analysis by our respective staff, we have a concluded that crucial, supplemental
programs will assist Detroit voters in fully participating in the presidential election. We are requesting
$3,512,000 grant to meet Detroit's election administration needs for the remainder of this year as
specified in the three strategic recommendations.
Recommendation I: Encourage and Increase Absentee Voting (By Mail and Early, In -Person)
1. Provide assistance to help voters comply with absentee ballot requests.

2. Expand in -person early voting opportunities.
3. Utilize secure drop -boxes to facilitate return of absentee ballots.
4. Deploy additional technology to expedite and improve accuracy of mail ballot process and
provide additional compensation for poll workers.
Recommendation Dramatically Expand Strategic Voter Education & Outreach Efforts, Particularly to
Historically Disenfranchised Residents.
Recommendation Hi: Launch Poll Worker Recruitment & Training.
Recommendation I: Encourage and Increase Absentee Voting (By Mail and Early,
In Person)
Overview of Mail Voting in Michigan
In 2018 Michigan voters amended the state constitution to provide a series of voting rights to Michigan
citizens. Central to the amendment is no reason absentee voting, which is a significant change that
eliminated the reasons that entitled a voter to vote absentee. Voters must still apply by application to
receive an absentee ballot and they may request both a primary ballot and a general election ballot with

a single request, which is commonly referred to as a 'dual' application. Further, the amendment entitles
citizens who are not registered by the 15th day before the election to register in -person in a clerk's office
during the 14 days prior to an election and on election day Michigan now has Election Day
Registration.
Under the amendment election officials have authority to add satellite offices to register voters and
issue absentee ballots. The legislative body of the jurisdiction must approve any satellite office under
Michigan election law. All satellite offices must be published at least 30 days before an election.
After the amendment was approved, absentee ballots are more commonly referred to as 'mail ballots'
because very few voters casting absentee ballots will actually be absent from the community.
It bears note that Michigan is not a 'vote by mail' (VBM) state. There are only five VBM states and they
mail ballots to all active, registered voters. In these states no applications are necessary, which
dramatically reduces the cost and complexity of mail balloting. Historically, absentee voting has been
costly as clerks must send applications to voters, receive and verify the completed applications, issue
and mail absentee ballots, receive voted ballots and verify the voters' signatures, and finally tabulate
ballots beginning on election day. Each of these processes must still be done under mail balloting,
EXHIBIT 1
RYAN 022913
requiring a significant number of staff and, as the volume increases, more sophisticated equipment to
efficiently process the large amount of paperwork.
The back and forth nature of Michigan's mail balloting processes places a heavy burden on voters to
learn how to apply for a mail ballot, be aware of the election calendar and apply for a ballot early
enough to receive, vote and return the ballot by election day and understand the delays built into the
United State Postal Service delivery timelines.
In the 2016 November Presidential Election, Detroit received 57,246 mail ballots (23% of total vote).
Projections are that between 180,00 and 210,000 mail ballots will be received in November. In fact,
Detroit will likely exceed the 2016 General Election total of mail ballots in the August primary this year.
The fear is that the Department of Elections will be inundated to the point of compromising the timely
processing of applications and ballots, should they not receive the grant resources that will facilitate the
following recommendations
To avoid the Department of Elections being inundated with applications to the point of compromising
the processing of applications and ballots, we require the grant resources to facilitate our proposals
outlined below.
Detroit will assist as many residents as possible with casting ballots before Election Day, serving as the
great opportunity to mitigate the spread of COVID-19 in our community. We have identified four distinct
strategies to help voters overcome barriers to successful mail voting.
1. Provide assistance to voters with mail ballot requests
Directly mail applications to all voters in Detroit who did not request a dual application in the August

primary. This is the best way to start the mail balloting process for voters who did not return a 'dual'
application in the primary. Placing an application in the hands of voters early in the process results in
earlier filing of the applications for a mail election. Those voters who did submit a dual application with
automatically receive a ballot for the General Election. Mailing to Detroit voters cost $300,000.
Add employees to Department of Elections call center to make it more responsive to voter calls. As the
General Election approaches and mail voting triples, there will be a substantial increase in phone calls
seeking help with all aspects of registering and voting. Ten temporary employees @ $100 per day for 40
days: $40,000.
Subtotal: $340,000.
2. Expand in -person early mail voting opportunities
Currently, the Department of Elections is operating 7 satellite offices, one in each of the seven city
commission districts. The proposal adds 20 additional satellite offices. The value of additional satellite
offices is making early mail voting more accessible to a larger portion of Detroit's electorate. Voters gain
the convenience of selecting the time they would like to cast their ballot. Coupled with drop boxes in the
EXHIBIT 1
RYAN 022914
next strategy, satellite offices are full -service sites for registering to vote, applying for mail ballots and
delivering voted mail ballots.
Each office would operate two shifts as a convenience to voters. Each shift would have 1 manager & 2
employees. Manager - $250 per day; each employee $150 per day. Applying this pay scale to all 27
satellites is $29,700 per day for 40 days = $1,188,000. Satellite office employees are now paid $12 per
hour or $96 per day. In order to attract and retain workers, a graduated pay scale may be necessary. For
example, starting out the workers would be paid $100 per day, after two weeks the pay would increase
to $150 per day. If they stay through election day, they would receive $100 hazard pay for the day. The
graduated pay would reduce costs somewhat during the first two weeks.
While the staffing of the current 7 satellite offices varies based on traffic, the expansion to 27 offices
properly located to be as convenient as possible for voters may level out the number staff required.
Each new office will require at least three laptops @ $1,500 times 20 = $30,000.
Rent for offices not owned by the city: $100,000.
Subtotal: $1,318,000.
3. Utilize secure drop-boxes to facilitate return of absentee
Detroit voters, like those across Michigan, will be encouraged to return their mail ballots in.-person
rather than using USPS, particularly in the last two weeks before the election. USPS is going to be
stressed with increased election related mail, as evidenced by recent announcements that some service
deterioration is going to occur. Drop boxes, especially drive through boxes, allow voters to easily drop
off their voted ballots regardless of where they happen to be in the city. Voters may use any of the 27

satellite drop boxes in addition to the box at West Grand Blvd.
A drop box costs between $4„000 and $6,000 with additional installation costs. Placing the drop boxes at
the satellite sites would cost: 27 boxes plus installation @$8,000 per box $216,000. Additional drop
boxes to be provided at 10 sites other than satellites: 10 boxes @ $8,000 = $80,000.
For the 10 drop boxes not placed at satellite offices, two employees will be required to collect ballots
from the boxes so that few, if any, will be left overnight. Two employees paid at $100 per day for 40
days would require $8,000.
Subtotal: $304,000
4. Deploy additional technology to expedite and improve accuracy of mail ballot process
and provide additional compensation for poll workers.
Purchase the New Relia-Vote MSE system. This is the other half of an automated system that has
recently been installed to open and record returned mail ballots. The new system will process outgoing
mail ballots by inserting the ballot, return envelope and instructions into the envelope addressed to
EXHIBIT 1
RYAN 022915
voter. This technology will greatly increase processing speed and reduce the turnaround time necessary
to place a ballot in the mail after an application is received. $750,000.
Provide incentive (hazard) payment to poll workers. Election day workers who administer elections in
the 501 precincts are often referred to as the frontline or face of Democracy. These workers are asked
to work a very long day for a small stipend. They are often referred to as volunteers. This year they face
the hazard of COVID-19 as they serve hundreds of voters throughout the day. The average age of our
poll workers is in the late 60s or early 70s, an age group considered at high risk to the virus. Detroit is
having similar experience as communities across the nation of large numbers of our older workers
declining to work this election year. Part of the recruitment and retention strategy is to seek younger
workers by offering a financial incentive.
There are 2,000 poll workers in the primary and 4,000 poll workers in the general for a total of 6,000
workers. An incentive of $100 is recommended for a cost of $600,000.
Subtotal: $1,350,000
Recommendation II: Dramatically Expand Strategic Voter Education & Outreach

Efforts, Particularly to Historically Disenfranchised Residents.
As noted above, the voters play a critical role to a successfully administered election in November. By
applying early for mail ballots, voters will distribute the Department of Elections' workload across
September and October. Normally, voters wait until early to mid -October to apply for a mail ballot,
which jams up the process as applications flood the Department of Elections, resulting in longer
turnaround times before ballots are issued. To avoid this, voters will be encouraged through a variety of
outreach to apply early and vote early.

Voters also must be informed to avoid errors such forgetting to sign applications and return ballot
envelopes and to affix their signatures as they appear on their driver license or state ID. Many people
today sign credit card receipts with a 'lazy' signature that does not match their more formal signature
used on official documents. These errors will invalidate ballots. Department of Elections staff will
attempt to contact voters making these error; however, time is usually in short supply.
The public outreach will direct voters to use the satellite offices as means of voting early where election
workers will review the applications and return ballot envelopes to make sure they are complete.
The Department of Elections' website will be reviewed for any necessary revisions or organizational
changes. The public outreach must be multi -faceted utilizing all available media, including direct mail,
radio advertisements, TV PSAs and social media.
Subtotal $100,000.*
Recommendation Ill: Launch Poll Worker Recruitment & Training
EXHIBIT 1
RYAN 022916
Recruiting inspectors is a continuing challenge. An aggressive campaign is necessary with businesses in
Detroit to recruit their employees to administer election on election day both in the precincts and the
counting boards. There has been some success in this area in previous elections. An 'AU Hands on Deck'
call is necessary to meet the minimum requirements to administer the November election. This will
require outreach by officials beyond the Department of Elections.
The Department has a training curriculum for the precinct inspectors and inspectors in the counting
board at the ICE Center. The challenge is to expand the venue for presentation of training to an online
environment that allows workers to continue training and review their assignment before election day.
This does not replace in -person training currently conducted by Department staff. Rather, videos of
training or demonstrations of voting equipment placed on a YouTube channel will be instructive re -
enforcing in -person training. Also, Zoom -type media permits large number of workers to participate in
workshops and refreshers. With many newer and younger workers this year, there will be an
expectation of online access to the 'how to' of elections.
There is some existing budget for recruitment and training.
Subtotal $100,000.
TOTAL REQUESTED RESOURCES: $3,512,000.
EXHIBIT 1
RYAN 022917
_ _-
A...7 CENTER FOR

TECH A\D
CIVIC LIFF
September 21, 2020
City of Detroit
To whom it may concern:

AMOUNT OF GRANT: $3,724,450.00
the City of Detroit in accordance with the Detroit Safe Voting Plan 2020
and the attached supplemental plan entitled "Poll worker Incentive Pay
Program — 2020 Presidential General Election."
1. The City of Detroit is a local government unit or political subdivision in the meaning of
26 USC 170(c)(1).
purposes.
EXHIBIT 1
RYAN 022918
organization unless CTCL agrees to the specific sub -recipient in advance, in writing.
4. The City of Detroit has produced a plan for safe and secure election administration in
2020, including an assessment of election administration needs, budget estimates for
such assessment, and an assessment of the impact of the plan on voters; the City of
Detroit has also produced a supplement to such plan. This supplemental plan is attached
to this agreement. The City shall expend the amount of this grant for purposes
contained in this plan by December 31, 2020.
5. The City of Detroit shall produce a report documenting how this grant has been
expended in support of the activities described in paragraph 4. This report shall be
provided to CTCL by January 31, 2021.
grant funds if it determines, in its sole judgment, that (a) any of the above conditions
have not been met or (b) it must do so to comply with applicable laws or regulations.
8. The grant project period of June 15, 2020 through December 31, 2020 represents the

representative of The City of Detroit sign below, and return a scanned copy of this letter to us by email
at grants@techandciviclife.org
Sincerely,
Tiana Epps Johnson

Executive Director

H E LLO@TE CHAN DCIVICLI FE. ORG
PAGE 2
EXHIBIT 1
RYAN 022919
CITY OF DETROIT
A Michigan Municipal Corporati
By: '644.4-t-L)
Title:
Date:

HELLOPTECHANDCIVICLIFE.ORG
PAGE 3
EXHIBIT 1
RYAN 022920
CITY OF DETROIT
Janice M. Winfrey, Detroit City Clerk
Poll worker Incentive Pay Program — 2020 Presidential General Election (DRAFT)
CITY OF DETROIT — DEPARTMENT OF ELECTIONS
2978 W. GRAND BOULEVARD
DETROIT, MI 48202
EXHIBIT 1
RYAN 022921
Detroit Department of Elections
Grant Funding Request — Pollworker Incentive Program - Presidential Election $3.7Mn
Executive Summary
The outbreak of the COVID-19 pandemic has created unprecedented challenges that prohibits
large gatherings and require social distancing. The City of Detroit has been identified as a "hot
spot" for COVID-19, which raises the concern that voting in person could be unsafe. Therefore,
we have determined that a predominately mail election is a safe, convenient and viable solution
for our voters. Even if the disease is under control, many voters (and poll workers) may be
reluctant to go into a polling place that serves communities identified as high risk for COVID-19.
Voting by mail is the most straightforward way to ensure that voters can safely cast a ballot. We
are also opening all voting precincts, housed in 182 buildings.
A well administered predominately mail election must be transparent, accessible to all voters.
Additionally, it can conceivably cut cost, increase turn -out and decrease human error. Hence,
voting by mail and increasing vote centers becomes important voting options for the public.
In an effort to serve voters effectively and to ensure the success of a predominately mail election,
it's imperative that stakeholders consider the following recommendations.
Administrators
Election Administrators should focus on improving the transparency, accuracy and accessibility
of the vote by mail process.
Transparency
After mailing a ballot, many voters wait with uncertainty to know if their ballot has been received,

or if it will be counted. Although costly, implementing a ballot tracking system in sync with the
postal service and sharing notifications with the voter would certainly help to alleviate voter
uncertainty. But at the very least, election staff should consider sending a post card to voters
upon receipt of their ballot, notifying them that their ballot has been received and is being
processed.
Accuracy
Many issues arise from errors made by voters, administrators and the post office. Steps taken to
prevent and a quick response rate will help to minimize the impact of errors and could go a long
way in improving the integrity of vote by mail. Election Administrators should use emails and
texts messages, whenever possible to better communicate deadlines to voters. Also, employing
best-design practices on the ballot return envelope will lessen the likelihood of a ballot envelope
returned unsigned.
EXHIBIT 1
RYAN 022922
Accessibility
To be certain that voting by mail is convenient for as many as possible, paying for postage on the
return ballot envelope should be eliminated. Voters also should be able to return a mailed ballot
to a satellite location on Election Day.
The implementation of vote centers would allow voters to vote at a location that may be more
accessible to them given a particular time of day. A registered voter, in that jurisdiction, is issued
a particular ballot, based on where they live. If one vote center is too crowded, the voter has the
option of casting their ballot at another vote center in their community. Approximately, thirty
(30) vote centers are located throughout the City.
Policy Makers
Allow for more mail/absentee ballot processing time. It has been clear for several election cycles
that more time is needed to process the already increasing number of absentee ballots. Ignoring
this need will very likely delay the public's ability to know the outcome of the election.
High Speed Tabulators are typically used in a central location on Election Day to count absentee
ballots. Its high speed, digital imaging process allows election workers to tabulate ballots by the
hundreds with increased efficiency. This request includes ten (10) additional high speed
machines at cost of $350,000, for a total of twenty-five (25) high speed machines.
Background
Well trained election staff is critical to the success of any election operation. Increasing the

stipend for Precinct and Central Counting Board poll workers will amplify our recruiting efforts
and goals sign up a cadre of professionals to work the polls.
The City of Detroit is the largest municipality by geography, population, and the number of
registered voters in the State of Michigan. The City Charter and Michigan Elections Law,
specifically, M.C.L. 168.781, of Public Act 116, of June 1955, as amended, provides that the City
Clerk in concert with the Detroit Election Commission, and staff, execute and monitor all regularly
scheduled and special local, county, and state elections effectively and efficiently. The central
operational activities includes on -going monitoring and update of voter registrations,
maintenance of the voter rolls in accordance with State election law, administration of elections,
and the maintenance and repair of voter equipment, as well as the recruitment, testing, and
training of qualified part-time workers, to staff the City's 503 precincts located throughout the
City in a transparent manner
The annual budget for the Election Department totals $13 million. Because, of the intermittent
nature of elections, the operation, is supported by approximately 57 full-time employees and 120
2
EXHIBIT 1
RYAN 022923
Grant Funding Request — Pol'worker Incentive Program - Presidential Election $3.7Mn
to 200 part-time employees and an estimated 4,000 to 8,000 polling site workers, who assist with
voter registration, absentee ballot processing, and supervising the polling sites on Election Day.
The complexity and variability surrounding the planning and execution of an election event, and
the stringent timelines mandated by elections law, requires a cadre of qualified/well trained staff
to carry-out election duties. Additionally, the sequence of the three elections this year, starting
with the Presidential Primary, on March 2020, and the State Primary and General elections in
August and November of 2020, typically requires 200 election clerical assistants, 4,000-8,000 poll
workers, and 700 Central Counting Board staff to efficiently and effectively administer the
election.
Legal Environment - Elections

• MCL 168.3, codifies the Presidential Election process in Michigan elections laws.
• MCL 168.78, codifies polling sites operations, stating that election inspectors and poll
clerks; opening of polls, examination of machine seals and counter, delivery of keys, other
duties of the election.
• Proposal 18-3, allowing voters to vote absentee without reason
Legal/ Operational Environment E0s — COVID-19 Restrictions

Governors Executive Orders (EO) related to the national pandemic:
• EO 20-22 - (COVID-19) No. 2020-22 Extension of county canvass deadlines for the March
10, 2020 Presidential Primary Election http://www.legislature.mi.gov/documents/2019-
2020/executiveorder/pdf/2020-E0-22.pdf

• EO 20-27 - (COVID-19) Conducting elections on May 5, 2020 using absent voter ballots
http://www.legislature.mi.gov/documents/2019-2020/executiveorder/pdf/2020-E0-
27.pdf
• EO 20-36 - (COVID-19) Protecting workers who stay home, stay safe when they or their
close contacts are sick http://www.legislature.mi.gov/documents/2019-
• EO 20-38 - (COVID-19) Temporary extensions of certain FOIA deadlines to facilitate
COVID-19 emergency response efforts http://www.legislature.mi.gov/documents/2019-
• EO 20-41 - (COVID-19) Encouraging the use of electronic signatures and remote
notarization, witnessing, and visitation during the COVID-19 pandemic
41.pdf
• E0 20-42 - (COVID-19) Temporary requirement to suspend activities that are not
necessary to sustain or protect life - Rescission of Executive Order 2020-21
42.pdf
Yit
EXHIBIT 1
RYAN 022924
Polling Sites & Central Counting Board Staffing Justification

Historically, for a number of reasons, the Department of Elections has had difficulty recruiting
between 4,000 to 8,000 poll workers. The effects of the COVID-19 pandemic and statewide
response by the Governor's "Stay at Home and Stay Safe," Executive Orders, as well as public
response, even after the Executive Orders are lifted, will be present, a significant challenge for
most election officials nationwide. A large population of our most reliable poll workers are
between the ages of sixty and seventy years of age, making them susceptible to the COVID-19
virus. One-hundred percent Vote by Mail elections has been implemented in the state of Oregon
and Washington, realizing cost savings, and higher voter turnout.
The amount of space, the availability of quality poll workers, and the introduction of new
machines and technology to count between a low of 350,000 to a high 450,000 ballots on Election
Day, November 2020, presents opportunities for operational efficiencies and cost savings.
This report analyzes the high number of in -bound absentee ballots from a low of 350,000 to a
high of 450,000 ballots (Central Counting Board), low staffing levels at polling sites and the
Central Counting Board, pressure to timely report results on Election Night, and the efficiency of
using high speed machines to count absentee ballots, as part of the Central Counting Board
operation.
Central Counting Board Operation (TCF Center)

Traditionally, the Central Counting Board operation is housed at the Treating Customer Fairly
(TCF) Center, downtown Detroit. The number of counting boards was expanded recently to 134
to more efficiently process votes. On average, between 300 and 700 poll workers are recruited,

tested, and trained to man this operation. A review of historical votes counted by the CCB
operation ranges from 30,000 to a high of 50,000 during the 2008 Presidential Election. Table 6,
depicts vote counts by precinct and Central Counting Board from 2010 to 2020.
EXHIBIT 1
RYAN 022925
Grant Funding Request —Pollworker Incentive Program - Presidential Election $3.7Mn
Table 6. Ballots Counted by CCB 2010-2020 Over the four (4)

General 2010
election cycles, a total
Total Ballots Total Precinct Ballots Total AV Ballots1
176,700 149,309 27,391 of 831,506, Precinct
ballots totaled 664,000
General 2012 or 80% of total, and AV
Total Ballots Total Precinct Ballots Total AV Ballots ballots totaled 167,000
290,345 235,364 54.981
or 20% of total.
General 2016
Total Ballots Total Precinct Ballots Total AV Ballots Totals ranged from a
248,780 199,410 49.370 low of 176,700 in 2010
to 248,780 in the 2016
Presidential Primary 2020
Total Ballots Total Precinct Ballots Total AV Ballots
Presidential Election.
115,681 80,434 35,247
831,506 Total 'N767-4,517 Total ballots processed
166,989
at the Precincts totaled
644,557, ranging from a low of 80,000 in 2020 to a high of 235,000 in 2012. AV ballot count
totaled 167,000 over the four years, ranging from a low of 27,000 in 2010 to a high of 50,000 in
2016 and 55,000 in the 2012 Presidential election. We are expecting to count at least 350,000
absentee ballots over several days for the November 2020 General Election.
Due to difficulty in finding space at the ICE Center and other facilities and the spread of the Covid-
19 pandemic, and its impact of staffing levels, and the increased number of ballots historically
processed by (Central Counting Board) CCB during Presidential Election contests, and the
anticipated change to election law, allowing 90% Vote From Home; it is estimated that the CCB
operation will be counting between 300,000 to 350,000 ballots on Election Day. The

procurement of 18 high speed counting machines, and the procurement of ten additional high
speed counting machines, will increase the speed at which ballots are counted, however, the
election business is highly depending on human resource. Therefore, increasing incentives will
drive performance at the ICE.
Three (3) scenarios will be analyzed. The first scenario, assumes using 18 high speed ballot
counters, which are able to count a minimum of 1,000 ballots per hour or a maximum of 2,000
ballots per hour. Our assumptions, use the minimum speed to accommodate, imperfections in
the process, and possible jams and other routine work stoppage and out right machine failure.
The second (2nd) scenario, includes the 18 high speed counting machines, but add 25 regular ICPs
ballot counting machines, which is able to only count 100 ballots per hour. The third (3rd)
scenario, includes the 18 high speed machines, but add a total of 50 ICP ballot counting machines.
Of the 503 Precincts, sixty percent or 311 have a high voter turnout of residents, voting in those
precincts, however, 40% of those 212 of the 503 precincts are low volume precincts, and it is
more efficient to use the ICPs to count those precincts. Below is a review of the alternatives and
the advantages and disadvantages of each option, with recommendations and operational
concerns.
EXHIBIT 1
RYAN 022926
Grant Funding Request - Pollworker Incentive Program - Presidential Election $3.7Mn
Grant Funding Request/ Cost Analysis - Presidential General Election

We are requesting $3.7 million in grant funding as payment incentive to increase the number of
residents willing to work the polls on Election Day. Of the $3.7 million, $2.7 million is set-aside
to increase pay for 8,000 poll workers working the 500 plus Precincts and $961,000 is earmarked
to increase pay for election staff working at the Receiving/Verification Boards. And, $350,000 is
included in the $3.7 million to procure an additional ten (10) high speed ballot counting .machines
for the absentee ballot operation. Please see the Pay Analysis Request below:
PollWorker Incentive Performance Program
$3.7 Mn - Request - 2020 Presidential Election
# Staff (4,000 Min, 8,000 Max)
Polling Sites Positions Current Pay Request Min Staff Max Staff/ Equip Min Request Max Request
Chairperson 415 540 550 800 297,000 432,000
Polling Site Assesor 430 540 190 200 102,600 108,000
Electronic Pollbook Inspector 440 475 550 850 261,250 403,750
Ballot Inspector 275 400 1,015 2,275 406,000 910,000
Ballot Box Inspector 275 400 1,015 2,275 406.000 910,000
Board Appointee Poll worker 185 0 0 0 0 0
Subtotal 3,320 6,400 1,472,850 2,763,750
Central Counting Board (GCB) Positio
Section Supervisor (Zone Mgr) 375 700 80 160 56,000 112,000
CCB Inspector 350 600 800 1,200 480,000 720,000
CCB Assistant (Lead) 460 800 50 100 40,000 80,000
CCB Runner 300 350 70 140 24,500 49,000
Subtotal 1,000 1,600 600,500 961,000
ICC Machines 10 (350,000)
Grand Total 4,320 8,000 2,073,350 3,374,750
Supporting Ballot Count Work Flow Analysis - Central Counting Board Operation

Assumption It 1- 18 High Speed Counters (Request 10 Additional High Speed machines)
This option includes 18 high speed machines, processing 360,000 ballots by 3AM and counting
234,000 ballots by 8PM, assuming a 13 hour work day. The minimum staffing level needed is
between 600 to 700 poll workers, 2 staff assigned to run each high speeds machine, and four (4)
staff at each a work station for a total of six (6) staff assigned to each high speed machine.
Additional scenarios, could reveal that the 18 high speed machines are not necessary to process
350,000 ballots within the expected time frames (count occurring of several days). For example,
what if, we used 15 high speed machines versus 18, reducing space foot print needs and staffing
level, without impacting optimal count performance. Our assumptions used the minimum of
1,000 ballots processed per hour in all options. The true capacity of each high speed machine is
2,000 ballots counted per hour.
0,
EXHIBIT 1
RYAN 022927
Grant Funding Request - Pollworker Incentive Program - Presidential Election $3.7Mn
'August's Election Assumption #1

Total # Expected Ballots Time it take to process the total number 8pm Count 3am Count
(13 hours) (20 hours) Staff I
on Election Day of expected ballots on Election Day
i 050,000) _
350,000 Assumption 1 18 HSP 234,000 360,000 18 HSP 210
Total Ballots Proccessed 234,000 360,000 Total 210
Table Fermat
8 pm Count 3am Count
Minimum Ballots (min. 1000 ballots (min. 1000 ballots
Hours of ()per Hsi, staff (2) # of workstations Staff . # Ballot Prot/Day
processed per hour processed per processed per
hour) hour)
#1 HSP 1,000 13 2 2 19,444.44 13000 20,000
#2 HSP 1,000 13 2 2 6 19,444.44 13000 20,000
#3 HSP 1,000 13 2 2 6 19,444.44 13000 20,000
#4 HSI, 1,000 13 2 2 6 19,444.44 13000 20,000
115 HSP 1,000 13 2 3 9 19,444.44 13000 20,000
#6 HSP 1,000 13 2 3 9 19,444.44 13000 20,000
#7 HSP 1,000 13 2 3 9 19,444.44 13000 20,000
#8 HSP 1,000 13 2 3 9 19,444.44 13000 20,000
#9 HSP 1,000 13 2 3 9 19,444.44 13000 20,000
#10 HSP 1,000 13 2 3 9 19,444.44 13000 20,000
#11 HSP 1,000 13 2 3 9 19,444.44 13000 20,000
#12 HSP 1,000 13 2 3 9 19,444.44 13000 20,000
#13 HSP 1,000 13 2 3 9 19,444.44 13000 20,000
#14 HSP 1,000 13 2 3 9 19,444.44 13000 20,000
#15 HSP 1,000 13 2 3 9 19,444.44 13000 20,000
#16 HSP 1,000 13 2 3 9 19,444.44 13000 20,000
#17 HSP 1,000 13 2 3 9 19,444.44 13000 20,000
#18 HSP 1,000 13 2 3 9 19,444.44 13000 20,000
36 40'601
List of classification Note 1: HSP Machine process 2,000 ballot ballots per hour (max, 2.8 hours)
Inspector 1 Note 2: HSP process 1,000 ballot per hour (min, 5.6 hours)
Inspector 2 Note 3: 2 Zone Managers per 25 HSP Workstations
Inspector 3 Note 4: 2 Section Supervisor per 5 FISP Workstations
Assumption #1: This scenario will only use 18 high-speed counters

Advantages
• Provides optimal space to be used at TCF
• Because everything will be going through the high-speed counters; more efficient
organization and management
• It uses the least amount of staff possible. Should meet the social distancing guidelines.
• Longest hours of all 3 scenarios, with completion time at 3AM (count extended over

several days). Although a high-speed printer can process faster than an ICP, there only
18 high-speed counters. Scenario reflect the minimum (1,000) number, not the maximum
(2,000 per hour) machine count.
Disadvantages
• Estimated completion time to count 350,000 ballots (count extended over several days)
• Space limitations at TCF
Assumption # 2- 18 High Speed (Request 10 Additional High Speed ICCs)

Assumption 2 assumes the use of 10 high speed machines and twenty-five (25) regular ballot
counting machines to process an estimated 266,000 ballots by 8PM and an estimated count of
369,000 by 1AM on Election Day. The 25 ICPs are only to process 100 per hour and 1300 over 13
work hours for a total of 32,500. These additional machines do not add significant value to the
count process, while they consume precious space, and additional cost to support the 87 people
needed to operate the 25 ICP stations.
EXHIBIT 1
RYAN 022928
August's Election Assumption #2

Total fk Expected Time it take to process the total 8pm Count larn Count
Ballots on Election number of expected ballots on (13 hours) (18 hours) Staff
Day Election Day (350,000)
350,000 Assumption 2 18 I-15P 234,000 324,000 18 HIP 210
25ICP 32,500 45,000 25 ICP 87
Total Ballots Proccessed 266,500 369,040 Total 297
Table Format
8 prn Count lam Count

Minimum Ballots
Hours of Oper HSP Staff (2) 8 of Workstations Staff * It Ballot Proc /Day (min. 1000 ballots (min. 1000 ballots
processed per hour
processed per hour) processed per hour)
HIP 1,000 '13 2 2 19,444.44 13000 18,000

818 HSP 1,000 13 2 3 9 19,444.44 13000 18,000
Total 18,000 36 150 350,000 234,000 jillocr_ 324,000
* List of classification Note 1: FISP Machine process 2,000 ballot ballots per hour (max, 2.8 hours)
Inspector 1 Note 2. HSP process 1,000 ballot per hour (min, 5.6 hours)
Inspector 3 Note 4: 2 Section Supervisor per 7 HSP Workstations
8 pm Count 1 am Count
Minimum Ballots
Hours of Oper 8 of Workstations Staff * (min. 100 ballots (min. 100 ballots
processed per hour
processed per hour) processed per hour)
81 ICP 100 13 3 1300 1800
#25 CS 100 13 3 1300 1800
Total 2,500 75 32,500 45,000
* List of. classification
Inspector 1 Note 1: 2 Zone Managers per 25 ICP's
Inspector 2 Note 2: 2 Section Supervisor per 5 ICP's
Inspector 3
Advantage
• Provides additional help to the high-speed printers. The expected final count would be
at 1AM instead of 3AM (count extended over several days).
• The ICPs' will be used to process the lower precincts ballots
Disadvantage
• It uses more staff than Assumption #1.
• Adds an additional 87 staff, at 3 per workstation; given space limitations and distancing

requirements. The addition of 25 ICPs do not add significant production value, but
could add to volume and management efficiency.
Assumption #3: 18 High Speeds (Request to Add 10 Additional ICCs)

Assumption 3, includes 18 high speed and 50 ICPs, with a total of 384 staff for both high speed
and ICPS operations. Adding the additional machines further complicates the count operations
and it consumes significant amount of space to house staff and machines. Although our Model
indicates that 50 ICPs will count 65,000 ballots by 8PM and 80,000 by 11PM (count extended over
several days), the history of the CCB operation, supports that this is a challenge, given the
complexity of the operations, and the quality of staff hired in the past. Due to low quality staffing,
CCB has not be able to count 30,000 ballots in a timely manner, reporting results earlier than
11AM, with 134 ICP counting machines and between 300 and 700 people at TCF. There is a flaw
in the model.
EXHIBIT 1
RYAN 022929
August's Election Assumption #3

Time it take to process the total number 8pm Count 11pm Count
Total 9 Expected Ballots
of expected ballots on Election Day (13 hours) (16 hours)
on Election Day
mess.
350,000 Assumption 3 18 HSP 234,000 288,000
50 ICP 65,000 80,000
Total Ballots Proccessed 299,000 368.000
Table Format
8 pm Count
11 pm Count
Minimum Ballots (mi 1000 ballots .
Hours of Oper HSP Staff (2) 4 of Workstations Staff - 4 Ballot Proc /Day (min. 1000 ballots
processed per hour processed per
processed per hour)
hour)
51 HSP 1,000 13 2 2 6 19,4,1,1.44 13000 16,000
418 HSP 1,000 13 2 3 9 19,444.44 13000 16,000
Total 18,000 36 SO 150 350,000 234,000 288,000
' List of classification Note HSP Machine process 2,000 ballot ballots per hour (max, 2.8 hours)
Inspector 1 Note 2. HSP process 1,000 ballot per hour (min, 5.6 hours)
Inspector 3 Note 4: 2 Section Supervisor per 7 HSP Workstations
8 pm Count
11 pm Count
Minimum Ballots (min. 100 ballots
Hours of Oper tt of Workstations Staff '1' (min. 100 ballots
processed per hour processed per
processed per hour)
#1 ICP 100 13 3 1300 1600
#50 ICP 100 13 3 1300 1600
Total 5,000 501111111111E 150 65,000 80,000
- List of classification
Inspector 1 Note 1: 2 Zone Managers per 25 ICP'S
Inspector 2 Note 2: 2 Section Supervisor per 51CP's
Inspector 3
Advantages
• 50 high-speed workstations, 50 ICP equipment
•It uses the most staff of all the three assumption scenarios. Will need a venue that
meets the social distancing guidelines if they are in place during the elections
•Provides optimal help to the high-speed printers.
Disadvantages
• Adding 50 ICPs, requiring 174 staff will complicate the count process
• Sufficient space is not available to support 174 staff and 50 ICPs on the zith Floor
• Training two different complement of employees on different processes, will be

confusing and staff will be fix to respective operations
• The value and flexibility of assign or re-assigning staff based on Election Day
operation will be an option, because they will not be trained. The idea of cross
training staff will be explored for production efficiency.
Recommendations: Central Counting Board

Given all operational and lingering COVID-19 concerns and the estimated volume of ballots to be
processed, Assumption #3 is the optimal option. Adding ICPs to the count process, could add
unnecessary complication to the Central Counting Board process. When changes are made to
election standard operating procedures, the processes should be simplified as much as possible,
to ensure concerns from interested parties and stakeholders are easily explained, if questioned.
It uses the least amount of staff needed to process an expected total ballot count of 350,000.
This makes it easier to find high quality people to work the day of election. Although the final
count is not expected until several days, these scenarios are all based off the minimum and not
the maximum performance output of the eighteen (18) or twenty-eight (28) high speed machines
being requested. We can surpass these expectations with recruiting high quality people and
providing them with essential training for the November Presidential Elections. Agile, creative,
EXHIBIT 1
RYAN 022930
Grant Funding Request — Pollworker Incentive Program - Presidential Election S3.7Mn
nimble leadership over these processes will be critical to project success on Election Day,
especially with the current medical difficulties infused into the administration of elections. We
are requesting 10 additional high speed counters, to decrease the amount votes being processed
by each machine. We will need additional staff to manage the expanded operations.
Conclusion
Each election cycle, nationwide administrators struggle with hiring well -trained poll workers.
Over the past decades, election operations shifted from a manual, people intensive operation to
a technology driven operation, requiring more professional staff. As such, the amount of pay
offered to work long intensive election cycles, increases the possibility of recruiting and retaining
well trained staff. We are requesting $3.7 million to pay poll workers as performance incentive
and $350,000 to procure additional high speed ballot counting machines.
10
EXHIBIT 1
RYAN 022931
EXHIBIT 2

Hearing Date: No hearing scheduled
Ci vil A cti o n C o ver S h e et - C as e I niti ati o n (1 2/ 0 1/ 2 0 ) C C L 0 5 2 0
Courtroom Number: No hearing scheduled
Location: No hearing scheduled
I N T H E CI R C UI T C O U R T O F C O O K C O U N T Y, I L LI N OI S FILED
C O U N T Y D E P A R T M E N T, L A W DI VI SI O N 11/17/2021 2:27 PM
IRIS Y. MARTINEZ
CIRCUIT CLERK
_D_a_n_ _R _y _a _n,_ _P_a_ul_ _ Dri
_ _ s_c_ oll,
_ _ _ J_ o_ ell
_ _ e_ n_ _M._ _ Pi_ _s _ar_c_z_y_k _ _a _n _d _ M_yr_ _o _n _ _Z _ol_ k_ e_ _w s_ k_ y,_ _ _ _
COOK COUNTY, IL
FILED DATE: 11/17/2021 2:27 PM 2021L011183
2021L011183
v. 15641646
_J_o_c _el_ y_ n_ _B _e _n _s _o _n._ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ N o. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
CI VI L A C TI O N C O V E R S H E E T - C A S E I NI TI A TI O N
A Ci vil Acti o n C o ver S heet - C ase I niti ati o n s h all be ﬁle d wit h t he
c o m pl ai nt i n all ci vil acti o ns. Th e i nf or m ati o n c o nt ai ne d herei n
is f or a d mi nistr ati ve p ur p oses o nl y a n d c a n n ot be i ntr o d uce d i nt o
e vi de nce. Ple ase c hec k t he b o x i n fr o nt of t he a p pr o pri ate c ase
t y pe w hic h best c h ar acterizes y o ur acti o n. O nl y o ne ( 1) c ase t y pe
m a y be c hec ke d wit h t his c o ver s heet.
J ur y De m a n d ■ Yes ■ N o
P E RS O N A L I NJ U R Y/ W R O N G F U L D E A T H
C AS E T Y P E S: ( FI L E S T A M P)
 0 2 7 M ot or Ve hicle C O M M E R CI A L LI TI G A TI O N
 0 4 0 Me dic al Mal pr actice
C AS E T Y P E S:
 ■
0 4 7 As best os
 ■
0 0 2 Bre ac h of C o ntr act
 0 4 8 Dr a m S h o p
 0 7 0 Pr ofessi o n al Mal pr actice
 ■
0 4 9 Pr o d uct Li a bilit y
( ot her t h a n le g al or me dic al)
 0 5 1 C o nstr ucti o n I nj uries
 ■ 0 7 1 Fr a u d ( ot her t h a n le g al or me dic al)
(i ncl u di n g Str uct ur al W or k Act, R o a d
 0 7 2 C o ns u mer Fr a u d
C o nstr ucti o n I nj uries Act a n d ne gli ge nce)
 0 7 3 Bre ac h of Warr a nt y
 0 5 2 R ailr o a d/ F E L A
 0 7 4 St at ut or y Acti o n
■
0 5 3 Pe di atric Le a d E x p os ure
( Ple ase s pecif y bel o w.**)
 0 6 1 Ot her Pers o n al I nj ur y/ Wr o n gf ul De at h
 0 7 5 Ot her C o m merci al Liti g ati o n

 0 6 3 I nte nti o n al Tort
( Ple ase s pecif y bel o w.**)
■ 0 6 4 Miscell a ne o us St at ut or y Acti o n
■ 0 7 6 Ret ali at or y Disc h ar ge
( Ple ase S pecif y Bel o w**)
 0 6 5 Pre mises Li a bilit y
O T H E R A C TI O N S
 0 7 8 Fe n- p he n/ Re d u x Liti g ati o n
 ■ 1 9 9 Silic o ne I m pl a nt C A S E T Y P E S:
 0 6 2 Pr o pert y Da m a ge
T A X & MI S C E L L A N E O U S R E M E DI E S  0 6 6 Le g al Mal pr actice
C A S E T Y P E S:  0 7 7 Li bel/ Sl a n der
 0 0 7 C o nfessi o ns of J u d g me nt
■
 0 7 9 Petiti o n f or Q u ali ﬁ e d Or ders
 0 0 8 Re ple vi n  0 8 4 Petiti o n t o Iss ue S u b p oe n a
■ 0 0 9 Ta x  1 0 0 Petiti o n f or Disc o ver y
■ 0 1 5 C o n de m n ati o n ** _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
 0 1 7 Deti n ue
_____________________________________________________
 0 2 9 U ne m pl o y me nt C o m pe ns ati o n
 0 3 1 F orei g n Tr a nscri pt Pri m ar y E m ail: _t_br_ _ej_c_h_a_ _@t_ h_ o_ _m_a_s_ m_ _or_e_s_o_ci_ et
_ _y._ or
_ _g_ _ _ _ _ _ _ _ _ _ _ _ _
 0 3 6 A d mi nistr ati ve Re vie w Acti o n
 0 8 5 Petiti o n t o Re gister F orei g n J u d g me nt
■
Sec o n d ar y E m ail: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
 0 9 9 All Ot her E xtr a or di n ar y Re me dies
B y: _T_h_ o_ _m _a _s _ Br_ _ej_ c_ h_ a_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ Terti ar y E m ail: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
( Att or ne y) ( Pr o Se)
Pr o S e O nl y:  I h a ve re a d a n d a gree t o t he ter ms of t he Cler k’s O ice Electr o nic N otice Policy a n d c h o ose t o o pt i n t o electr o nic n otice
f or m t he Cl er k’ s Offi c e f or t his c ase at t his e m ail a d dress: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
I RI S Y. M A R TI N E Z, C L E R K O F T H E CI R C UI T C O U R T O F C O O K C O U N T Y, I L LI N OI S
P a ge 1 of 1
EXHIBIT 2
FILED
11/17/2021 2:27 PM
IRIS Y. MARTINEZ
CIRCUIT CLERK
COOK COUNTY, IL
2021L011183
FILED DATE: 11/17/2021 2:27 PM 2021L011183
IL Sup. Ct. Rule 204 Subpoena for a Foreign Action Cover Sheet (04/05/21) CCL 0015
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
COUNTY DEPARTMENT, LAW DIVISION
Dan Ryan, Paul Driscoll, Joellen M. Pisarczyk and Myron Zolkewsky
Petitioner Illinois Case No.: 2021L011183

v.
_______________
Jocelyn Benson
Respondent
IL SUP. CT. RULE 204 SUBPOENA FOR A FOREIGN ACTION COVER SHEET
Mark F. (Thor) Hearne Heather Meingast/Erik Grill
Name: _______________________________ Name: _______________________________
112 S. Hanley Road, Suite 200 PO Box 30736
Address: _____________________________ Address: _____________________________
St. Louis, MO 63105 Lansing, MI 48909
_____________________________ _____________________________
Thomas Brejcha
Name: _______________________________ Name: _______________________________
309 W. Washington St., Suite 1250
Address: _____________________________ Address: _____________________________
Chicago, IL 60606
____________________________ _____________________________

Charles Spies
Name: _______________________________ Name: _______________________________
350 S. Main St., Suite 300
Address: _____________________________ Address: _____________________________
Ann Arbot, MI 48104
_____________________________ _____________________________
P40231
Atty. No.: ________________ Pro Se 99500
Mark F. (Thor) Hearne
Atty Name:
Petitioners
Atty. for:
Address:
Saint Louis MO 63105
City: ____________________________ State: ____ Zip: ________
(314) 296-4000
Telephone: ________________________
thor@truenorthlawgroup.com
Primary Email:
Iris Y. Martinez, Clerk of the Circuit Court of Cook County, Illinois
cookcountyclerkofcourt.org
Page 1 of 1
EXHIBIT 2
FILED DATE: 11/17/2021 2:27 PM 2021L011183
Subpoena in a Civil Matter (For Testimony and/or Documents) ( ) CCG 0106 A

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
Plaintiff/Petitioner 2021L011183
v. Case No.
Jocelyn Benson,
Defendant/Respondent
SUBPOENA IN A CIVIL MATTER
(For Testimony and/or Documents)
To: Keeper of Records
The Center for Technology and Civil Life
233 N. Michigan Avenue, Suite 1800
Chicago, IL 60601
1. YOU ARE COMMANDED to appear to give your testimony before the

Honorable ________________________________ in Room _____________ ,
_________________________________________________ , Illinois on ___________

at __________ AM PM

2. YOU ARE COMMANDED to appear and give your deposition testimony before a Notary Public
at: _______________________________________________________ in Room _____________ ,
_______________________________________________ , Illinois on ___________
at __________ AM PM
3. YOU ARE COMMANDED to mail the following documents in your possession or control
Thomas More Society
to __________________________________ 309 W. Washington St., Suite 1250, Chicago, IL 60606
at ______________________________________________ ,
on or before ___________ 10:00

12/3/21 at __________ AM PM
(THIS IS FOR RECORDS ONLY. THERE WILL BE NO ORAL INTERROGATORIES.):
Description continued on attached page(s).

Your failure to respond to this subpoena will subject you to punishment for contempt of this Court.
, Clerk of the Circuit Court of Cook County, Illinois

Page 1 of 2
EXHIBIT 2
Subpoena in a Civil Matter (For Testimony and/or Documents) ( ) CCG 0106 B
Notice to Deponent:
1. The deponent is a public or private corporation, partnership, association, or governmental agency. The
matter(s) on which examination is requested are as follows:
FILED DATE: 11/17/2021 2:27 PM 2021L011183
Description continued on attached page(s).
or other persons to testify on its behalf, and may set forth, for each person designated, the matters on
which that person will testify. Ill. Sup. Ct. Rule 206.)
2. The deponent’s testimony will be recorded by use of an audio-visual recording device, operated
by ______________________________________________ .
(Name of Recording Device Operator)
3. No discovery deposition of any party or witnesses shall exceed three hours regardless of the number of
parties involved in the case, except by stipulation of the parties or by order upon showing that good cause
warrants a lengthier examination. Ill. Sup. Ct. Rule 206(d).
P40231
Atty. No.: ________________
Pro Se 99500
Name: Mark F. (Thor) Hearne 11/17/2021 2:27 PM IRIS Y. MARTINEZ
Atty. for (if applicable): Issued by: /s/
Plaintiffs Dan Ryan, et al. Signature
Attorney Clerk of Court
Address: 112 S. Hanley Road, Suite 200
11/17/21
Date: ___________
City: Saint Louis

MO
State: ____ 63105
Zip: ________
(314) 296-4000
Telephone: ________________________
Primary Email: thor@truenorthlawgroup.com
I served this subpoena by mailing a copy, as required by Ill. Sup. Ct. Rules 11, 12 and 204(a) (2),
to Keeper of Records, Ctr. for Tech. & Civil Life
70211970000069193278
(Receipt # ________________________) 11/17/21 . I paid the witness $ _____________
on ___________ 25.00 for
witness and mileage fees.
I served this subpoena by handing a copy to _____________________________________________
on ___________ . I paid the witness $ _____________ for witness and mileage fees.
Tim Murphy
/s/ _________________________________________ Tim Murphy
(Signature of Server) (Print Name)
, Clerk of the Circuit Court of Cook County, Illinois
Page 2 of 2
EXHIBIT 2
Exhibit 1
FILED DATE: 11/17/2021 2:27 PM 2021L011183
INSTRUCTIONS AND DEFINITIONS
“Center for Tech and Civic Life,” “CTCL,” or “Center for Technology and Civic
Life” means the Center for Technology and Civic Life, the Illinois Corporation, and the directors,
officers, employees and agents of Center for Technology and Civic Life and any affiliated entities
or organizations including, but not limited to, Pam Anderson, Tiana Epps-Johnson, Tammy
Patrick, Sureel Sheth, Christina Sinclaire, Whitney May, Donny Bridges and all other individuals
employed by CTCL, and any individual using an email with the domain name
“@techandciviclife.org”.
“Communication” means, in addition to a document, an oral exchange of information,
sentiments, opinions or observations whether expressed in-person or electronically including any
interchange by telephone, email, teleconference, video conference including Zoom, Google,
Facetime, or any other electronic means. “Communication” is not limited to conversations

between two individuals but includes meetings, conferences, rallies, speeches and other venues in
which information or statements are exchanged.
“Document” includes any printed material, paper, writing, book, communication or other
instrument, whether electronic or printed, that conveys information. “Document” includes items
that are printed, recorded or reproduced by any computerized or mechanical process or written or
produced by hand. “Document” includes agreements; communications; correspondence; letters;
emails; text messages; posts to social media sites such as Facebook, Twitter, or Instagram; faxes;
memoranda; notes, drafts; notebooks; summaries or records of telephone conversations;
summaries or records of personal conversations or interviews; diaries; statistical statements;
EXHIBIT 2
graphs; spreadsheets; financial analysis; minutes or records of meetings; minutes or records of
conferences; expressions or statements of policy; lists of persons attending meetings or

FILED DATE: 11/17/2021 2:27 PM 2021L011183
conferences; reports or summaries of investigations; opinions or reports of consultants; records;
photographs; brochures; pamphlets; advertisements; circulars; press releases; drafts of any
documents; original or preliminary notes; marginal comments appearing on any documents; and
any voice recording, whether a recording (including any voicemail messages) or written transcript.
“Election Jurisdiction” means a body politic in Michigan with duties concerning the
conduct of elections. An “Election Jurisdiction” includes but is not limited to Townships, Villages,
Cities and Counties and any local election official including a clerk with responsibility under
Michigan law to conduct elections in Michigan.
ITEMS TO PRODUCE
1. Communications (from January 1, 2019 to the present) between CTCL and any Election
Jurisdiction or county/city/township/local election official/department in Michigan.

2. Communications (from January 1, 2019 to the present) between CTCL and anyone from
the Michigan Secretary of State’s Office/Department of State including any emails
received or sent with the domain name “@michigan.gov”.
3. A listing of all Michigan Election Jurisdictions that received any money from CTCL (from
January 1, 2019 to the present) and for each state the amount (or amounts) of each payment
and the date (or dates) the funds were paid to each Election Jurisdiction and provide copies
of any documents or agreements associated with each payment.
EXHIBIT 2
4. For any money paid by CTCL to any Michigan Election Jurisdiction (from January 1, 2019
to the present) provide any documents or communications stating how the funds CTCL
FILED DATE: 11/17/2021 2:27 PM 2021L011183
paid an Election Jurisdiction were used.
5. Communications between CTCL and any other individuals or entities (including but not
limited to the Democracy Fund, New Venture Fund, Sixteen Thirty Fund, Hopewell Fund,
Arabella Advisors, Windward Fund, Omidyar Group, New Organizing Institute, Facebook,
Open Society Foundation, Ford Foundation, Atlantic Philanthropies and the Center for
Secure and Modern Elections) related to the conduct or funding of the 2020 general
election in Michigan. This includes, but is not limited to, emails with any of the following
domain names “@democracyfund.org”, “@sixteenthirtyfund.org”, “hopewellfund.org”,
“@newventurefund.org”, “@windwardfund.org”, “@ArabellaAdvisors.com”, and
“@modernelections.org” related to the conduct or funding of the 2020 general election in
Michigan.

6. “Safe Voting Plans” or similar plans any Michigan Election Jurisdiction provided to or by
CTCL concerning the conduct of the Michigan 2020 General Election.
7. Any CTCL worksheets completed by any Michigan Election Jurisdiction concerning
elections conducted in Michigan after January 1, 2020 including the Primary and General
Elections in 2020.
8. Grant application or other documents (including emails) completed by any Michigan
Election Jurisdiction requesting funds from CTCL.
EXHIBIT 2
9. Any grant acceptance or rejection documents sent by CTCL to any Michigan Election
Jurisdiction.
FILED DATE: 11/17/2021 2:27 PM 2021L011183
EXHIBIT 2
Original - Return
1st copy - Witness
Approved, SCAO 2nd copy - File
3rd copy - Extra
STATE OF MICHIGAN CASE NO.
JUDICIAL DISTRICT SUBPOENA 20-000198-MZ
Court of Claims JUDICIAL CIRCUIT Order to Appear and/or Produce
COUNTY PROBATE
Court address 925. W. Ottawa St., PO Box 30185, Lansing, MI 48909 Court telephone no.
FILED DATE: 11/17/2021 2:27 PM 2021L011183
(517) 373-0807
Police Report No. (if applicable):
Plaintiff(s)/Petitioner(s) Defendant(s)/Respondent(s)
People of the State of Michigan v
✔ Dan Ryan, Paul Driscoll, Joellen M. Pisarczyk and Jocelyn Benson
Myron Zolkewsky
✔ Civil Criminal Charge
Probate In the matter of
In the Name of the People of the State of Michigan. TO:

Keeper of Records- Center for Technology and Civic Life
If you require special accommodations to use the court because of disabilities, please contact the court immediately to make arrangements.
YOU ARE ORDERED TO:
✔
1. Appear personally at the time and place stated below: You may be required to appear from time to time and day to day until excused.
The court address above ✔

Other: 309 W. Washington Street, Suite 1250, Chicago, IL 60606
Day Date Time
Friday December 3, 2021 10:00 a.m.
2. Testify at trial / examination / hearing.

See Exhibit 1.
✔
3. Produce/permit inspection or copying of the following items:

4. Testify as to your assets, and bring with you the items listed in line 3 above.
5. Testify at deposition.
6. Abide by the attached prohibition against transferring or disposing of property. (MCL 600.6104(2), 600.6116, or 600.6119.)
7. Other:
Person requesting subpoena Telephone no.
✔
8. Mark F. (Thor) Hearne (314) 296-4000
Address
City State Zip
St. Louis, MO 63105
NOTE: If requesting a debtor's examination under MCL 600.6110, or an injunction under item 6. this subpoena
must be issued by a judge. For a debtor examination, the affidavit of debtor examination on the other side of this
form must also be completed. Debtor's assets can also be discovered through MCR 2.305 without the need for
an affidavit of debtor examination or issuance of this subpoena by a judge.
FAILURE TO OBEY THE COMMANDS OF THE SUBPOENA OR TO APPEAR AT THE STATED

TIME AND PLACE MAY SUBJECT YOU TO PENALTY FOR CONTEMPT OF COURT.
Court use only
Nov. 5, 2021 /s/ Mark F. (Thor) Hearne P40231
Served Not served
Date Judge/Clerk/Attorney Bar no.
MC 11 (3/15) SUBPOENA, Order to Appear and/or Produce MCL 600.1455, 600.1701, 600.6110, 600.6119, MCR 2.506
EXHIBIT 2
SUBPOENA
PROOF OF SERVICE Case No.
TO PROCESS SERVER: You must make and file your return with the court clerk. If you are unable to complete service, you must
return this original and all copies to the court clerk.
FILED DATE: 11/17/2021 2:27 PM 2021L011183
CERTIFICATE / AFFIDAVIT OF SERVICE / NONSERVICE
OFFICER CERTIFICATE OR AFFIDAVIT OF PROCESS SERVER

I certify that I am a sheriff, deputy sheriff, bailiff, appointed Being first duly sworn, I state that I am a legally competent
court officer, or attorney for a party [MCR 2.104(A)(2)], and adult who is not a party or an officer of a corporate party, and
that: (notarization not required) that: (notarization required)
I served a copy of the subpoena, together with (including any required fees) by
Attachment
personal service registered or certified mail (copy of return receipt attached) on:
Name(s) Complete address(es) of service Day, date, time
I have personally attempted to serve the subpoena and required fees, if any, together with
on the following person(s) and have been unable to complete service. Attachment
Name(s) Complete address(es) of service Day, date, time
Service fee Miles traveled Fee Signature

$ $
Incorrect address fee Miles traveled Fee TOTAL FEE Name (type or print)
$ $ $
Title
Subscribed and sworn to before me on , County, Michigan.
Date

My commission expires: Signature:
Date Deputy court clerk/Notary public
Notary public, State of Michigan, County of
ACKNOWLEDGMENT OF SERVICE
I acknowledge that I have received service of the subpoena and required fees, if any, together with
Attachment
on
Day, date, time
on behalf of .
Signature
AFFIDAVIT FOR JUDGMENT DEBTOR EXAMINATION

I request that the court issue a subpoena that orders the party named on this form to be examined under oath before a judge
concerning the money or property of:
for the following reasons:
Signature
Subscribed and sworn to before me on , County, Michigan.
Date
My commission expires: Signature:
Date Deputy court clerk/Notary public
Notary public, State of Michigan, County of
MCR 2.105
EXHIBIT 2
Exhibit 1
FILED DATE: 11/17/2021 2:27 PM 2021L011183
INSTRUCTIONS AND DEFINITIONS
“Center for Tech and Civic Life,” “CTCL,” or “Center for Technology and Civic
Life” means the Center for Technology and Civic Life, the Illinois Corporation, and the directors,
officers, employees and agents of Center for Technology and Civic Life and any affiliated entities
or organizations including, but not limited to, Pam Anderson, Tiana Epps-Johnson, Tammy
Patrick, Sureel Sheth, Christina Sinclaire, Whitney May, Donny Bridges and all other individuals
employed by CTCL, and any individual using an email with the domain name
“@techandciviclife.org”.
“Communication” means, in addition to a document, an oral exchange of information,
sentiments, opinions or observations whether expressed in-person or electronically including any
interchange by telephone, email, teleconference, video conference including Zoom, Google,
Facetime, or any other electronic means. “Communication” is not limited to conversations

between two individuals but includes meetings, conferences, rallies, speeches and other venues in
which information or statements are exchanged.
“Document” includes any printed material, paper, writing, book, communication or other
instrument, whether electronic or printed, that conveys information. “Document” includes items
that are printed, recorded or reproduced by any computerized or mechanical process or written or
produced by hand. “Document” includes agreements; communications; correspondence; letters;
emails; text messages; posts to social media sites such as Facebook, Twitter, or Instagram; faxes;
memoranda; notes, drafts; notebooks; summaries or records of telephone conversations;
summaries or records of personal conversations or interviews; diaries; statistical statements;
EXHIBIT 2
graphs; spreadsheets; financial analysis; minutes or records of meetings; minutes or records of
conferences; expressions or statements of policy; lists of persons attending meetings or

FILED DATE: 11/17/2021 2:27 PM 2021L011183
conferences; reports or summaries of investigations; opinions or reports of consultants; records;
photographs; brochures; pamphlets; advertisements; circulars; press releases; drafts of any
documents; original or preliminary notes; marginal comments appearing on any documents; and
any voice recording, whether a recording (including any voicemail messages) or written transcript.
“Election Jurisdiction” means a body politic in Michigan with duties concerning the
conduct of elections. An “Election Jurisdiction” includes but is not limited to Townships, Villages,
Cities and Counties and any local election official including a clerk with responsibility under
Michigan law to conduct elections in Michigan.
ITEMS TO PRODUCE
1. Communications (from January 1, 2019 to the present) between CTCL and any Election
Jurisdiction or county/city/township/local election official/department in Michigan.

2. Communications (from January 1, 2019 to the present) between CTCL and anyone from
the Michigan Secretary of State’s Office/Department of State including any emails
received or sent with the domain name “@michigan.gov”.
3. A listing of all Michigan Election Jurisdictions that received any money from CTCL (from
January 1, 2019 to the present) and for each state the amount (or amounts) of each payment
and the date (or dates) the funds were paid to each Election Jurisdiction and provide copies
of any documents or agreements associated with each payment.
EXHIBIT 2
4. For any money paid by CTCL to any Michigan Election Jurisdiction (from January 1, 2019
to the present) provide any documents or communications stating how the funds CTCL
FILED DATE: 11/17/2021 2:27 PM 2021L011183
paid an Election Jurisdiction were used.
5. Communications between CTCL and any other individuals or entities (including but not
limited to the Democracy Fund, New Venture Fund, Sixteen Thirty Fund, Hopewell Fund,
Arabella Advisors, Windward Fund, Omidyar Group, New Organizing Institute, Facebook,
Open Society Foundation, Ford Foundation, Atlantic Philanthropies and the Center for
Secure and Modern Elections) related to the conduct or funding of the 2020 general
election in Michigan. This includes, but is not limited to, emails with any of the following
domain names “@democracyfund.org”, “@sixteenthirtyfund.org”, “hopewellfund.org”,
“@newventurefund.org”, “@windwardfund.org”, “@ArabellaAdvisors.com”, and
“@modernelections.org” related to the conduct or funding of the 2020 general election in
Michigan.

6. “Safe Voting Plans” or similar plans any Michigan Election Jurisdiction provided to or by
CTCL concerning the conduct of the Michigan 2020 General Election.
7. Any CTCL worksheets completed by any Michigan Election Jurisdiction concerning
elections conducted in Michigan after January 1, 2020 including the Primary and General
Elections in 2020.
8. Grant application or other documents (including emails) completed by any Michigan
Election Jurisdiction requesting funds from CTCL.
EXHIBIT 2
9. Any grant acceptance or rejection documents sent by CTCL to any Michigan Election
Jurisdiction.
FILED DATE: 11/17/2021 2:27 PM 2021L011183
EXHIBIT 2
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PUBLIC DISCLOSURE COPY - STATE REGISTRATION NO. 01071921
990
OMB No. 1545-0047
Return of Organization Exempt From Income Tax
Form Under section 501(c), 527, or 4947(a)(1) of the Internal Revenue Code (except private foundations)
| Do not enter social security numbers on this form as it may be made public.
2020
Department of the Treasury Open to Public
Internal Revenue Service | Go to www.irs.gov/Form990 for instructions and the latest information. Inspection
A For the 2020 calendar year, or tax year beginning FEB 1, 2020 and ending JAN 31, 2021
B Check if C Name of organization D Employer identification number
applicable:
X Address
† change CENTER FOR TECHNOLOGY AND CIVIC LIFE
X Name
† change Doing business as 47-2158694
Initial
† return Number and street (or P.O. box if mail is not delivered to street address) Room/suite E Telephone number
† Final
return/ 303 E. WACKER DRIVE 2106 (872) 588-6843
termin-
ated City or town, state or province, country, and ZIP or foreign postal code
G 356251345.
Gross receipts $
† Amended
return CHICAGO, IL 60601 H(a) Is this a group return
† Applica-
F Name and address of principal officer:
tion TIANA EPPS-JOHNSON for subordinates? ~~† Yes † X No
SAME AS C ABOVE
pending
H(b) Are all subordinates included?† Yes † No
I Tax-exempt status:† X 501(c)(3) † 501(c) ( ) ß (insert no.) † 4947(a)(1) or† 527 If "No," attach a list. See instructions
J Website: | HTTP://WWW.TECHANDCIVICLIFE.ORG/ H(c) Group exemption number |
X Corporation † Trust † Association † Other |
K Form of organization: † L Year of formation: 2014 M State of legal domicile: IL
Part I Summary
1 Briefly describe the organization's mission or most significant activities: INCREASE CIVIC PARTICIPATION BY
Activities & Governance
MODERNIZING ENGAGEMENT BETWEEN LOCAL GOV. AND THE PEOPLE THEY SERVE.
2 Check this box | † if the organization discontinued its operations or disposed of more than 25% of its net assets.
3 Number of voting members of the governing body (Part VI, line 1a) ~~~~~~~~~~~~~~~~~~~~ 3 5
4 Number of independent voting members of the governing body (Part VI, line 1b) ~~~~~~~~~~~~~~ 4 4
5 Total number of individuals employed in calendar year 2020 (Part V, line 2a) ~~~~~~~~~~~~~~~~ 5 28
6 Total number of volunteers (estimate if necessary) ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 6 4
7a Total unrelated business revenue from Part VIII, column (C), line 12 ~~~~~~~~~~~~~~~~~~~~ 7a 0.
b Net unrelated business taxable income from Form 990-T, Part I, line 11 7b 0.
Prior Year Current Year
8 Contributions and grants (Part VIII, line 1h) ~~~~~~~~~~~~~~~~~~~~~ 2842705. 354577107.
Revenue
9 Program service revenue (Part VIII, line 2g) ~~~~~~~~~~~~~~~~~~~~~ 560042. 1666871.
10 Investment income (Part VIII, column (A), lines 3, 4, and 7d) ~~~~~~~~~~~~~ 19. 3522.
11 Other revenue (Part VIII, column (A), lines 5, 6d, 8c, 9c, 10c, and 11e) ~~~~~~~~ 1643. 3845.
12 Total revenue - add lines 8 through 11 (must equal Part VIII, column (A), line 12) 3404409. 356251345.
13 Grants and similar amounts paid (Part IX, column (A), lines 1-3) ~~~~~~~~~~~ 0. 332090025.

14 Benefits paid to or for members (Part IX, column (A), line 4) ~~~~~~~~~~~~~ 0. 0.
15 Salaries, other compensation, employee benefits (Part IX, column (A), lines 5-10) ~~~ 1069628. 1651330.
Expenses
16a Professional fundraising fees (Part IX, column (A), line 11e)~~~~~~~~~~~~~~ 0. 0.
b Total fundraising expenses (Part IX, column (D), line 25) | 29918.
17 Other expenses (Part IX, column (A), lines 11a-11d, 11f-24e) ~~~~~~~~~~~~~ 307318. 1688523.
18 Total expenses. Add lines 13-17 (must equal Part IX, column (A), line 25) ~~~~~~~ 1376946. 335429878.
19 Revenue less expenses. Subtract line 18 from line 12 2027463. 20821467.
Fund Balances
Net Assets or
Beginning of Current Year End of Year

20 Total assets (Part X, line 16) ~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 3172982. 32868797.
21 Total liabilities (Part X, line 26) ~~~~~~~~~~~~~~~~~~~~~~~~~~~ 116649. 8990997.
22 Net assets or fund balances. Subtract line 21 from line 20 3056333. 23877800.
Part II Signature Block
Under penalties of perjury, I declare that I have examined this return, including accompanying schedules and statements, and to the best of my knowledge and belief, it is
true, correct, and complete. Declaration of preparer (other than officer) is based on all information of which preparer has any knowledge.
Sign = Signature of officer

TIANA EPPS-JOHNSON, PRESIDENT/EXECUTIVE DIR.
Date
Here
= Type or print name and title
Date PTIN
Print/Type preparer's name Preparer's signature Check †
if
Paid ROBERT REHAYEM ROBERT REHAYEM 12/15/21 P00075874
self-employed
Preparer Firm's name
9
WSDD CPAS, LTD. Firm's EIN
9 36-2996439
Use Only Firm's address
9
303 W. MADISON ST., SUITE 2075
CHICAGO, IL 60606-3395 Phone no.(312) 332-6622
May the IRS discuss this return with the preparer shown above? See instructions X Yes † No
†
032001 12-23-20 LHA For Paperwork Reduction Act Notice, see the separate instructions. Form 990 (2020)
RYAN 023428
EXHIBIT 4
Form 990 (2020) CENTER FOR TECHNOLOGY AND CIVIC LIFE 47-2158694 Page 2
Part III Statement of Program Service Accomplishments
Check if Schedule O contains a response or note to any line in this Part III X
†
1 Briefly describe the organization's mission:
THE CENTER'S MISSION IS TO INCREASE CIVIC PARTICIPATION BY MODERNIZING
ENGAGEMENT BETWEEN LOCAL GOVERNMENT AND THE PEOPLE THEY SERVE. WE DO
THIS BY (1) EDUCATING THE PUBLIC ABOUT GOVERNMENT AND DEMOCRACY IN THE
UNITED STATES AND (2) EDUCATING LOCAL GOVERNMENT AGENCIES ABOUT SKILLS
2 Did the organization undertake any significant program services during the year which were not listed on the
prior Form 990 or 990-EZ? ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ † Yes † X No
If "Yes," describe these new services on Schedule O.
3 Did the organization cease conducting, or make significant changes in how it conducts, any program services?~~~~~~ † Yes † X No
If "Yes," describe these changes on Schedule O.
4 Describe the organization's program service accomplishments for each of its three largest program services, as measured by expenses.
Section 501(c)(3) and 501(c)(4) organizations are required to report the amount of grants and allocations to others, the total expenses, and
revenue, if any, for each program service reported.
4a (Code: ) (Expenses $ 1267136. including grants of $ ) (Revenue $ 265000. )
THE CENTER EDUCATES THE PUBLIC ABOUT GOVERNMENT AND DEMOCRACY IN THE
UNITED STATES, FOCUSING PARTICULARLY ON LOCAL GOVERNMENT. THE CENTER
DOES THIS BY AGGREGATING AND DISSEMINATING DETAILED INFORMATION ABOUT
GOVERNMENT, CANDIDATES FOR OFFICE, ELECTED OFFICIALS, AND VOTING IN THE
UNITED STATES IN EASILY ACCESSIBLE "DATASETS". THESE DATASETS INCLUDE
INFORMATION THAT HELP THE GENERAL PUBLIC FIND BASIC INFORMATION,
INCLUDING WHAT IS ON THEIR BALLOT AND WHO REPRESENTS THEM. THESE
DATASETS ARE FREELY AND UNIVERSALLY AVAILABLE TO THE PUBLIC.
4b (Code: ) (Expenses $ 333828515. including grants of $ 332090025. ) (Revenue $ 1401871. )

THE CENTER'S GOVERNMENT SERVICES PROGRAM EDUCATES GOVERNMENT AGENCIES
ABOUT THE SKILLS, STRATEGIES, AND TOOLS TO ENGAGE THEIR CITIZENS. THIS
IS ACCOMPLISHED THROUGH (1) WRITTEN AND MULTIMEDIA MATERIALS AND (2)
IN-PERSON TRAINING SEMINARS FOR LOCAL GOVERNMENT AGENCIES. DURING
FISCAL YEAR 2021, THE CENTER RECEIVED TWO SUBSTANTIAL GRANTS TO SUPPORT

THE SAFE ADMINISTRATION OF PUBLIC ELECTIONS DURING THE COVID-19
PANDEMIC AND TO PROVIDE GENERAL SUPPORT.
4c (Code: ) (Expenses $ including grants of $ ) (Revenue $ )
4d Other program services (Describe on Schedule O.)

(Expenses $ including grants of $ ) (Revenue $ )
4e Total program service expenses | 335095651.
Form 990 (2020)
032002 12-23-20
2 RYAN 023429
16191215 747703 RRCTRTEC1976 2020.05010 CENTER FOR TECHNOLOGY AND C RRCTRTE1
EXHIBIT 4
Part IV Checklist of Required Schedules
Yes No
1 Is the organization described in section 501(c)(3) or 4947(a)(1) (other than a private foundation)?
If "Yes," complete Schedule A ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 1 X
2 Is the organization required to complete Schedule B, Schedule of Contributors? ~~~~~~~~~~~~~~~~~~~~~~ 2 X
3 Did the organization engage in direct or indirect political campaign activities on behalf of or in opposition to candidates for
public office? If "Yes," complete Schedule C, Part I ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 3 X
4 Section 501(c)(3) organizations. Did the organization engage in lobbying activities, or have a section 501(h) election in effect
during the tax year? If "Yes," complete Schedule C, Part II ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 4 X
5 Is the organization a section 501(c)(4), 501(c)(5), or 501(c)(6) organization that receives membership dues, assessments, or
similar amounts as defined in Revenue Procedure 98-19? If "Yes," complete Schedule C, Part III ~~~~~~~~~~~~~~ 5 X
6 Did the organization maintain any donor advised funds or any similar funds or accounts for which donors have the right to
provide advice on the distribution or investment of amounts in such funds or accounts? If "Yes," complete Schedule D, Part I 6 X
7 Did the organization receive or hold a conservation easement, including easements to preserve open space,
the environment, historic land areas, or historic structures? If "Yes," complete Schedule D, Part II~~~~~~~~~~~~~~ 7 X
8 Did the organization maintain collections of works of art, historical treasures, or other similar assets? If "Yes," complete
Schedule D, Part III ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 8 X
9 Did the organization report an amount in Part X, line 21, for escrow or custodial account liability, serve as a custodian for
amounts not listed in Part X; or provide credit counseling, debt management, credit repair, or debt negotiation services?
If "Yes," complete Schedule D, Part IV ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 9 X
10 Did the organization, directly or through a related organization, hold assets in donor-restricted endowments
or in quasi endowments? If "Yes," complete Schedule D, Part V ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 10 X
11 If the organization's answer to any of the following questions is "Yes," then complete Schedule D, Parts VI, VII, VIII, IX, or X
as applicable.
a Did the organization report an amount for land, buildings, and equipment in Part X, line 10? If "Yes," complete Schedule D,
Part VI ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 11a X
b Did the organization report an amount for investments - other securities in Part X, line 12, that is 5% or more of its total
assets reported in Part X, line 16? If "Yes," complete Schedule D, Part VII ~~~~~~~~~~~~~~~~~~~~~~~~~ 11b X
c Did the organization report an amount for investments - program related in Part X, line 13, that is 5% or more of its total
assets reported in Part X, line 16? If "Yes," complete Schedule D, Part VIII ~~~~~~~~~~~~~~~~~~~~~~~~~ 11c X
d Did the organization report an amount for other assets in Part X, line 15, that is 5% or more of its total assets reported in
Part X, line 16? If "Yes," complete Schedule D, Part IX ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 11d X
e Did the organization report an amount for other liabilities in Part X, line 25? If "Yes," complete Schedule D, Part X ~~~~~~ 11e X
f Did the organization's separate or consolidated financial statements for the tax year include a footnote that addresses

the organization's liability for uncertain tax positions under FIN 48 (ASC 740)? If "Yes," complete Schedule D, Part X ~~~~ 11f X
12a Did the organization obtain separate, independent audited financial statements for the tax year? If "Yes," complete
Schedule D, Parts XI and XII ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 12a X
b Was the organization included in consolidated, independent audited financial statements for the tax year?
If "Yes," and if the organization answered "No" to line 12a, then completing Schedule D, Parts XI and XII is optional ~~~~~ 12b X
13 Is the organization a school described in section 170(b)(1)(A)(ii)? If "Yes," complete Schedule E ~~~~~~~~~~~~~~ 13 X
14a Did the organization maintain an office, employees, or agents outside of the United States? ~~~~~~~~~~~~~~~~ 14a X
b Did the organization have aggregate revenues or expenses of more than $10,000 from grantmaking, fundraising, business,
investment, and program service activities outside the United States, or aggregate foreign investments valued at $100,000
or more? If "Yes," complete Schedule F, Parts I and IV ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 14b X
15 Did the organization report on Part IX, column (A), line 3, more than $5,000 of grants or other assistance to or for any
foreign organization? If "Yes," complete Schedule F, Parts II and IV ~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 15 X
16 Did the organization report on Part IX, column (A), line 3, more than $5,000 of aggregate grants or other assistance to
or for foreign individuals? If "Yes," complete Schedule F, Parts III and IV ~~~~~~~~~~~~~~~~~~~~~~~~~~ 16 X
17 Did the organization report a total of more than $15,000 of expenses for professional fundraising services on Part IX,
column (A), lines 6 and 11e? If "Yes," complete Schedule G, Part I ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 17 X
18 Did the organization report more than $15,000 total of fundraising event gross income and contributions on Part VIII, lines
1c and 8a? If "Yes," complete Schedule G, Part II ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 18 X
19 Did the organization report more than $15,000 of gross income from gaming activities on Part VIII, line 9a? If "Yes,"
complete Schedule G, Part III ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 19 X
20a Did the organization operate one or more hospital facilities? If "Yes," complete Schedule H ~~~~~~~~~~~~~~~~~ 20a X
b If "Yes" to line 20a, did the organization attach a copy of its audited financial statements to this return? ~~~~~~~~~~ 20b
21 Did the organization report more than $5,000 of grants or other assistance to any domestic organization or
domestic government on Part IX, column (A), line 1? If "Yes," complete Schedule I, Parts I and II ~~~~~~~~~~~~~~
21 X
032003 12-23-20 Form 990 (2020)
3 RYAN 023430
EXHIBIT 4
Part IV Checklist of Required Schedules (continued)
Yes No
22 Did the organization report more than $5,000 of grants or other assistance to or for domestic individuals on
Part IX, column (A), line 2? If "Yes," complete Schedule I, Parts I and III ~~~~~~~~~~~~~~~~~~~~~~~~~~ 22 X
23 Did the organization answer "Yes" to Part VII, Section A, line 3, 4, or 5 about compensation of the organization's current
and former officers, directors, trustees, key employees, and highest compensated employees? If "Yes," complete
Schedule J ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 23 X
24 a Did the organization have a tax-exempt bond issue with an outstanding principal amount of more than $100,000 as of the
last day of the year, that was issued after December 31, 2002? If "Yes," answer lines 24b through 24d and complete
Schedule K. If "No," go to line 25a ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 24a X
b Did the organization invest any proceeds of tax-exempt bonds beyond a temporary period exception? ~~~~~~~~~~~ 24b
c Did the organization maintain an escrow account other than a refunding escrow at any time during the year to defease
any tax-exempt bonds? ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 24c
d Did the organization act as an "on behalf of" issuer for bonds outstanding at any time during the year? ~~~~~~~~~~~ 24d
25 a Section 501(c)(3), 501(c)(4), and 501(c)(29) organizations. Did the organization engage in an excess benefit
transaction with a disqualified person during the year? If "Yes," complete Schedule L, Part I ~~~~~~~~~~~~~~~~ 25a X
b Is the organization aware that it engaged in an excess benefit transaction with a disqualified person in a prior year, and
that the transaction has not been reported on any of the organization's prior Forms 990 or 990-EZ? If "Yes," complete
Schedule L, Part I ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 25b X
26 Did the organization report any amount on Part X, line 5 or 22, for receivables from or payables to any current
or former officer, director, trustee, key employee, creator or founder, substantial contributor, or 35%
controlled entity or family member of any of these persons? If "Yes," complete Schedule L, Part II ~~~~~~~~~~~~~ 26 X
27 Did the organization provide a grant or other assistance to any current or former officer, director, trustee, key employee,
creator or founder, substantial contributor or employee thereof, a grant selection committee member, or to a 35% controlled
entity (including an employee thereof) or family member of any of these persons? If "Yes," complete Schedule L, Part III~~~ 27 X
28 Was the organization a party to a business transaction with one of the following parties (see Schedule L, Part IV
instructions, for applicable filing thresholds, conditions, and exceptions):
a A current or former officer, director, trustee, key employee, creator or founder, or substantial contributor? If
"Yes," complete Schedule L, Part IV ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 28a X
b A family member of any individual described in line 28a? If "Yes," complete Schedule L, Part IV~~~~~~~~~~~~~~~ 28b X
c A 35% controlled entity of one or more individuals and/or organizations described in lines 28a or 28b? If
"Yes," complete Schedule L, Part IV ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 28c X
29 Did the organization receive more than $25,000 in non-cash contributions? If "Yes," complete Schedule M ~~~~~~~~~ 29 X
30 Did the organization receive contributions of art, historical treasures, or other similar assets, or qualified conservation

contributions? If "Yes," complete Schedule M ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 30 X
31 Did the organization liquidate, terminate, or dissolve and cease operations? If "Yes," complete Schedule N, Part I~~~~~~ 31 X
32 Did the organization sell, exchange, dispose of, or transfer more than 25% of its net assets? If "Yes," complete
Schedule N, Part II ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 32 X
33 Did the organization own 100% of an entity disregarded as separate from the organization under Regulations
sections 301.7701-2 and 301.7701-3? If "Yes," complete Schedule R, Part I ~~~~~~~~~~~~~~~~~~~~~~~~ 33 X
34 Was the organization related to any tax-exempt or taxable entity? If "Yes," complete Schedule R, Part II, III, or IV, and
Part V, line 1 ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 34 X
35 a Did the organization have a controlled entity within the meaning of section 512(b)(13)? ~~~~~~~~~~~~~~~~~~ 35a X
b If "Yes" to line 35a, did the organization receive any payment from or engage in any transaction with a controlled entity
within the meaning of section 512(b)(13)? If "Yes," complete Schedule R, Part V, line 2 ~~~~~~~~~~~~~~~~~~~ 35b
36 Section 501(c)(3) organizations. Did the organization make any transfers to an exempt non-charitable related organization?
If "Yes," complete Schedule R, Part V, line 2 ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 36 X
37 Did the organization conduct more than 5% of its activities through an entity that is not a related organization
and that is treated as a partnership for federal income tax purposes? If "Yes," complete Schedule R, Part VI ~~~~~~~~ 37 X
38 Did the organization complete Schedule O and provide explanations in Schedule O for Part VI, lines 11b and 19?
Note: All Form 990 filers are required to complete Schedule O 38 X
Part V Statements Regarding Other IRS Filings and Tax Compliance
Check if Schedule O contains a response or note to any line in this Part V †
Yes No
1a Enter the number reported in Box 3 of Form 1096. Enter -0- if not applicable ~~~~~~~~~~~ 1a 6
b Enter the number of Forms W-2G included in line 1a. Enter -0- if not applicable ~~~~~~~~~~ 1b 0
c Did the organization comply with backup withholding rules for reportable payments to vendors and reportable gaming
(gambling) winnings to prize winners? 1c X
032004 12-23-20 Form 990 (2020)
4 RYAN 023431
EXHIBIT 4
Part V Statements Regarding Other IRS Filings and Tax Compliance (continued)
Yes No
2a Enter the number of employees reported on Form W-3, Transmittal of Wage and Tax Statements,
filed for the calendar year ending with or within the year covered by this return ~~~~~~~~~~ 2a 28
b If at least one is reported on line 2a, did the organization file all required federal employment tax returns?~~~~~~~~~~ 2b X
Note: If the sum of lines 1a and 2a is greater than 250, you may be required to e-file (see instructions) ~~~~~~~~~~~
3a Did the organization have unrelated business gross income of $1,000 or more during the year? ~~~~~~~~~~~~~~ 3a X
b If "Yes," has it filed a Form 990-T for this year? If "No" to line 3b, provide an explanation on Schedule O ~~~~~~~~~~ 3b
4a At any time during the calendar year, did the organization have an interest in, or a signature or other authority over, a
financial account in a foreign country (such as a bank account, securities account, or other financial account)?~~~~~~~ 4a X
b If "Yes," enter the name of the foreign country J
See instructions for filing requirements for FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR).
5a Was the organization a party to a prohibited tax shelter transaction at any time during the tax year? ~~~~~~~~~~~~ 5a X
b Did any taxable party notify the organization that it was or is a party to a prohibited tax shelter transaction?~~~~~~~~~ 5b X
c If "Yes" to line 5a or 5b, did the organization file Form 8886-T?~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 5c
6a Does the organization have annual gross receipts that are normally greater than $100,000, and did the organization solicit
any contributions that were not tax deductible as charitable contributions? ~~~~~~~~~~~~~~~~~~~~~~~~ 6a X
b If "Yes," did the organization include with every solicitation an express statement that such contributions or gifts
were not tax deductible? ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 6b
7 Organizations that may receive deductible contributions under section 170(c).
a Did the organization receive a payment in excess of $75 made partly as a contribution and partly for goods and services provided to the payor? 7a X
b If "Yes," did the organization notify the donor of the value of the goods or services provided? ~~~~~~~~~~~~~~~ 7b
c Did the organization sell, exchange, or otherwise dispose of tangible personal property for which it was required
to file Form 8282? 7c X
d If "Yes," indicate the number of Forms 8282 filed during the year ~~~~~~~~~~~~~~~~ 7d
e Did the organization receive any funds, directly or indirectly, to pay premiums on a personal benefit contract? ~~~~~~~ 7e X
f Did the organization, during the year, pay premiums, directly or indirectly, on a personal benefit contract? ~~~~~~~~~ 7f X
g If the organization received a contribution of qualified intellectual property, did the organization file Form 8899 as required?~ 7g
h If the organization received a contribution of cars, boats, airplanes, or other vehicles, did the organization file a Form 1098-C? 7h
8 Sponsoring organizations maintaining donor advised funds. Did a donor advised fund maintained by the
sponsoring organization have excess business holdings at any time during the year? ~~~~~~~~~~~~~~~~~~~ 8
9 Sponsoring organizations maintaining donor advised funds.
a Did the sponsoring organization make any taxable distributions under section 4966? ~~~~~~~~~~~~~~~~~~~ 9a
b Did the sponsoring organization make a distribution to a donor, donor advisor, or related person? ~~~~~~~~~~~~~ 9b

10 Section 501(c)(7) organizations. Enter:
a Initiation fees and capital contributions included on Part VIII, line 12 ~~~~~~~~~~~~~~~ 10a
b Gross receipts, included on Form 990, Part VIII, line 12, for public use of club facilities ~~~~~~ 10b
11 Section 501(c)(12) organizations. Enter:
a Gross income from members or shareholders ~~~~~~~~~~~~~~~~~~~~~~~~~~ 11a
b Gross income from other sources (Do not net amounts due or paid to other sources against
amounts due or received from them.) ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 11b
12a Section 4947(a)(1) non-exempt charitable trusts. Is the organization filing Form 990 in lieu of Form 1041? 12a
b If "Yes," enter the amount of tax-exempt interest received or accrued during the year 12b
13 Section 501(c)(29) qualified nonprofit health insurance issuers.
a Is the organization licensed to issue qualified health plans in more than one state? ~~~~~~~~~~~~~~~~~~~~~ 13a
Note: See the instructions for additional information the organization must report on Schedule O.
b Enter the amount of reserves the organization is required to maintain by the states in which the
organization is licensed to issue qualified health plans ~~~~~~~~~~~~~~~~~~~~~~ 13b
c Enter the amount of reserves on hand ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 13c
14a Did the organization receive any payments for indoor tanning services during the tax year? ~~~~~~~~~~~~~~~~ 14a X
b If "Yes," has it filed a Form 720 to report these payments? If "No," provide an explanation on Schedule O ~~~~~~~~~ 14b
15 Is the organization subject to the section 4960 tax on payment(s) of more than $1,000,000 in remuneration or
excess parachute payment(s) during the year?~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 15 X
If "Yes," see instructions and file Form 4720, Schedule N.
16 Is the organization an educational institution subject to the section 4968 excise tax on net investment income? ~~~~~~ 16 X
If "Yes," complete Form 4720, Schedule O.
Form 990 (2020)
032005 12-23-20
5 RYAN 023432
EXHIBIT 4
Part VI Governance, Management, and Disclosure For each "Yes" response to lines 2 through 7b below, and for a "No" response
to line 8a, 8b, or 10b below, describe the circumstances, processes, or changes on Schedule O. See instructions.
Check if Schedule O contains a response or note to any line in this Part VI X
†
Section A. Governing Body and Management
Yes No
1a Enter the number of voting members of the governing body at the end of the tax year ~~~~~~ 1a 5
If there are material differences in voting rights among members of the governing body, or if the governing
body delegated broad authority to an executive committee or similar committee, explain on Schedule O.
b Enter the number of voting members included on line 1a, above, who are independent ~~~~~~ 1b 4
2 Did any officer, director, trustee, or key employee have a family relationship or a business relationship with any other
officer, director, trustee, or key employee? ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 2 X
3 Did the organization delegate control over management duties customarily performed by or under the direct supervision
of officers, directors, trustees, or key employees to a management company or other person? ~~~~~~~~~~~~~~~ 3 X
4 Did the organization make any significant changes to its governing documents since the prior Form 990 was filed? ~~~~~ 4 X
5 Did the organization become aware during the year of a significant diversion of the organization's assets? ~~~~~~~~~ 5 X
6 Did the organization have members or stockholders? ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 6 X
7a Did the organization have members, stockholders, or other persons who had the power to elect or appoint one or
more members of the governing body? ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 7a X
b Are any governance decisions of the organization reserved to (or subject to approval by) members, stockholders, or
persons other than the governing body? ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 7b X
8 Did the organization contemporaneously document the meetings held or written actions undertaken during the year by the following:
a The governing body? ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 8a X
b Each committee with authority to act on behalf of the governing body? ~~~~~~~~~~~~~~~~~~~~~~~~~~ 8b X
9 Is there any officer, director, trustee, or key employee listed in Part VII, Section A, who cannot be reached at the
organization's mailing address? If "Yes," provide the names and addresses on Schedule O 9 X
Section B. Policies (This Section B requests information about policies not required by the Internal Revenue Code.)
Yes No
10a Did the organization have local chapters, branches, or affiliates? ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 10a X
b If "Yes," did the organization have written policies and procedures governing the activities of such chapters, affiliates,
and branches to ensure their operations are consistent with the organization's exempt purposes? ~~~~~~~~~~~~~ 10b
11a Has the organization provided a complete copy of this Form 990 to all members of its governing body before filing the form? 11a X
b Describe in Schedule O the process, if any, used by the organization to review this Form 990.
12a Did the organization have a written conflict of interest policy? If "No," go to line 13 ~~~~~~~~~~~~~~~~~~~~~ 12a X
b Were officers, directors, or trustees, and key employees required to disclose annually interests that could give rise to conflicts? ~~~~~~ 12b X

c Did the organization regularly and consistently monitor and enforce compliance with the policy? If "Yes," describe
in Schedule O how this was done ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 12c X
13 Did the organization have a written whistleblower policy? ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 13 X
14 Did the organization have a written document retention and destruction policy? ~~~~~~~~~~~~~~~~~~~~~~ 14 X
15 Did the process for determining compensation of the following persons include a review and approval by independent
persons, comparability data, and contemporaneous substantiation of the deliberation and decision?
a The organization's CEO, Executive Director, or top management official ~~~~~~~~~~~~~~~~~~~~~~~~~~ 15a X
b Other officers or key employees of the organization ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 15b X
If "Yes" to line 15a or 15b, describe the process in Schedule O (see instructions).
16a Did the organization invest in, contribute assets to, or participate in a joint venture or similar arrangement with a
taxable entity during the year? ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 16a X
b If "Yes," did the organization follow a written policy or procedure requiring the organization to evaluate its participation
in joint venture arrangements under applicable federal tax law, and take steps to safeguard the organization's
exempt status with respect to such arrangements? 16b
Section C. Disclosure
17 List the states with which a copy of this Form 990 is required to be filed JIL
18 Section 6104 requires an organization to make its Forms 1023 (1024 or 1024-A, if applicable), 990, and 990-T (Section 501(c)(3)s only) available
for public inspection. Indicate how you made these available. Check all that apply.
† Own website † Another's website †X Upon request † Other (explain on Schedule O)
19 Describe on Schedule O whether (and if so, how) the organization made its governing documents, conflict of interest policy, and financial
statements available to the public during the tax year.
20 State the name, address, and telephone number of the person who possesses the organization's books and records |
TIANA EPPS-JOHNSON - (872) 588-6843
233 N. MICHIGAN AVE., SUITE 1800, CHICAGO, IL 60601
032006 12-23-20 Form 990 (2020)
6 RYAN 023433
EXHIBIT 4
Part VII Compensation of Officers, Directors, Trustees, Key Employees, Highest Compensated
Employees, and Independent Contractors
Check if Schedule O contains a response or note to any line in this Part VII †
Section A. Officers, Directors, Trustees, Key Employees, and Highest Compensated Employees
1a Complete this table for all persons required to be listed. Report compensation for the calendar year ending with or within the organization's tax year.
• List all of the organization's current officers, directors, trustees (whether individuals or organizations), regardless of amount of compensation.
Enter -0- in columns (D), (E), and (F) if no compensation was paid.
• List all of the organization's current key employees, if any. See instructions for definition of "key employee."
• List the organization's five current highest compensated employees (other than an officer, director, trustee, or key employee) who received report-
able compensation (Box 5 of Form W-2 and/or Box 7 of Form 1099-MISC) of more than $100,000 from the organization and any related organizations.
• List all of the organization's former officers, key employees, and highest compensated employees who received more than $100,000 of
reportable compensation from the organization and any related organizations.
• List all of the organization's former directors or trustees that received, in the capacity as a former director or trustee of the organization,
more than $10,000 of reportable compensation from the organization and any related organizations.
See instructions for the order in which to list the persons above.
† Check this box if neither the organization nor any related organization compensated any current officer, director, or trustee.
(A) (B) (C) (D) (E) (F)
Name and title Average Position Reportable Reportable Estimated
(do not check more than one
hours per box, unless person is both an compensation compensation amount of
officer and a director/trustee)
week Individual trustee or director from from related other
(list any the organizations compensation
hours for organization (W-2/1099-MISC) from the
Highest compensated
Institutional trustee
related (W-2/1099-MISC) organization

organizations Key employee and related
employee
below organizations
Former
Officer
line)
(1) TIANA EPPS-JOHNSON 40.00
PRESIDENT, EXEC. DIRECTOR X X 111822. 0. 5284.
(2) CRISTINA SINCLAIRE 2.00
SECRETARY, DIRECTOR X X 0. 0. 0.
(3) SUREEL SHETH 2.00
TREASURER, DIRECTOR X X 0. 0. 0.
(4) PAM ANDERSON 1.00
DIRECTOR X 0. 0. 0.
(5) TAMMY PATRICK 1.00
DIRECTOR X 0. 0. 0.
032007 12-23-20 Form 990 (2020)

7 RYAN 023434
EXHIBIT 4
Part VII Section A. Officers, Directors, Trustees, Key Employees, and Highest Compensated Employees (continued)
(A) (B) (C) (D) (E) (F)
Name and title Average Position Reportable Reportable Estimated
(do not check more than one
hours per box, unless person is both an compensation compensation amount of
week officer and a director/trustee)
from from related other
(list any
Individual trustee or director

the organizations compensation
hours for organization (W-2/1099-MISC) from the
Highest compensated
related
Institutional trustee
(W-2/1099-MISC) organization
organizations and related
Key employee
below
employee
organizations
Former
Officer
line)
1b Subtotal ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ | 111822. 0. 5284.

c Total from continuation sheets to Part VII, Section A ~~~~~~~~~~ | 0. 0. 0.
d Total (add lines 1b and 1c) | 111822. 0. 5284.
2 Total number of individuals (including but not limited to those listed above) who received more than $100,000 of reportable
compensation from the organization | 1
Yes No

3 Did the organization list any former officer, director, trustee, key employee, or highest compensated employee on
line 1a? If "Yes," complete Schedule J for such individual ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 3 X
4 For any individual listed on line 1a, is the sum of reportable compensation and other compensation from the organization
and related organizations greater than $150,000? If "Yes," complete Schedule J for such individual~~~~~~~~~~~~~ 4 X
5 Did any person listed on line 1a receive or accrue compensation from any unrelated organization or individual for services
rendered to the organization? If "Yes," complete Schedule J for such person 5 X
Section B. Independent Contractors
1 Complete this table for your five highest compensated independent contractors that received more than $100,000 of compensation from
the organization. Report compensation for the calendar year ending with or within the organization's tax year.
(A) (B) (C)
Name and business address Description of services Compensation
KAPLAN HECKER FINK LLP, 350 FIFTH AVENUE,
SUITE 7110, NEW YORK, NY 10118 LEGAL 262352.
ELECTIONS GROUP, 1333 BURR RIDGE PARKWAY, COVID-19 GRANT
SUITE 200, BURR RIDGE, IL 60527 CONSULTING 250000.
LAWDOG SECURITY, 3055 W. 111TH ST., SUITE
4N, CHICAGO, IL 60655 SECURITY 218250.
2 Total number of independent contractors (including but not limited to those listed above) who received more than
$100,000 of compensation from the organization | 3
Form 990 (2020)
032008 12-23-20
8 RYAN 023435
EXHIBIT 4
Part VIII Statement of Revenue
Check if Schedule O contains a response or note to any line in this Part VIII †
(A) (B) (C) (D)
Total revenue Related or exempt Unrelated Revenue excluded
function revenue business revenue from tax under
sections 512 - 514
Contributions, Gifts, Grants
and Other Similar Amounts
1 a Federated campaigns ~~~~~ 1a

b Membership dues ~~~~~~~ 1b
c Fundraising events ~~~~~~~ 1c
d Related organizations ~~~~~ 1d
e Government grants (contributions) 1e
f All other contributions, gifts, grants, and
1f 354577107.
similar amounts not included above ~
g 1g $
Noncash contributions included in lines 1a-1f
h Total. Add lines 1a-1f | 354577107.

Business Code
2 a PROGRAM SERVICE FEES 900099 1666871. 1666871.
Program Service
b
Revenue
c
d
e
f All other program service revenue ~~~~~
g Total. Add lines 2a-2f | 1666871.
3 Investment income (including dividends, interest, and
other similar amounts)~~~~~~~~~~~~~~~~~ | 3522. 3522.
4 Income from investment of tax-exempt bond proceeds |
5 Royalties |
(i) Real (ii) Personal
6 a Gross rents ~~~~~ 6a
b Less: rental expenses ~ 6b
c Rental income or (loss) 6c
d Net rental income or (loss) |
7 a Gross amount from sales of (i) Securities (ii) Other
assets other than inventory 7a
b Less: cost or other basis

Other Revenue
and sales expenses ~~~ 7b

c Gain or (loss) ~~~~~ 7c
d Net gain or (loss) |
8 a Gross income from fundraising events (not
including $ of
contributions reported on line 1c). See
Part IV, line 18 ~~~~~~~~~~~~ 8a
b Less: direct expenses~~~~~~~~~ 8b
c Net income or (loss) from fundraising events |
9 a Gross income from gaming activities. See
Part IV, line 19 ~~~~~~~~~~~~ 9a
b Less: direct expenses ~~~~~~~~ 9b
c Net income or (loss) from gaming activities |
10 a Gross sales of inventory, less returns
and allowances ~~~~~~~~~~~~ 10a
b Less: cost of goods sold ~~~~~~~ 10b
c Net income or (loss) from sales of inventory |
Business Code
Miscellaneous
11 a OTHER INCOME 900099 3845. 3845.

Revenue
b
c
d All other revenue ~~~~~~~~~~~~~
e Total. Add lines 11a-11d | 3845.
12 Total revenue. See instructions | 356251345. 1670716. 0. 3522.
032009 12-23-20 Form 990 (2020)
9 RYAN 023436
EXHIBIT 4
Part IX Statement of Functional Expenses
Section 501(c)(3) and 501(c)(4) organizations must complete all columns. All other organizations must complete column (A).
Check if Schedule O contains a response or note to any line in this Part IX †
Do not include amounts reported on lines 6b, (A) (B) (C) (D)
7b, 8b, 9b, and 10b of Part VIII. Total expenses Program service Management and Fundraising
expenses general expenses expenses
1 Grants and other assistance to domestic organizations
and domestic governments. See Part IV, line 21 ~ 332090025. 332090025.
2 Grants and other assistance to domestic
individuals. See Part IV, line 22 ~~~~~~~
3 Grants and other assistance to foreign
organizations, foreign governments, and foreign
individuals. See Part IV, lines 15 and 16 ~~~
4 Benefits paid to or for members ~~~~~~~
5 Compensation of current officers, directors,
trustees, and key employees ~~~~~~~~ 112320. 98435. 12172. 1713.
6 Compensation not included above to disqualified
persons (as defined under section 4958(f)(1)) and
persons described in section 4958(c)(3)(B) ~~~
7 Other salaries and wages ~~~~~~~~~~ 1263068. 1106925. 136878. 19265.
8 Pension plan accruals and contributions (include
section 401(k) and 403(b) employer contributions)
9 Other employee benefits ~~~~~~~~~~ 159402. 139697. 17274. 2431.
10 Payroll taxes ~~~~~~~~~~~~~~~~ 116540. 102134. 12629. 1777.
11 Fees for services (nonemployees):
a Management ~~~~~~~~~~~~~~~~
b Legal ~~~~~~~~~~~~~~~~~~~~ 659702. 659702.
c Accounting ~~~~~~~~~~~~~~~~~ 249514. 249514.
d Lobbying ~~~~~~~~~~~~~~~~~~
e Professional fundraising services. See Part IV, line 17
f Investment management fees ~~~~~~~~
g Other. (If line 11g amount exceeds 10% of line 25,
column (A) amount, list line 11g expenses on Sch O.) 579355. 541003. 33620. 4732.
12 Advertising and promotion ~~~~~~~~~
13 Office expenses~~~~~~~~~~~~~~~ 11233. 1496. 9737.

14 Information technology ~~~~~~~~~~~ 11738. 10089. 1649.
15 Royalties ~~~~~~~~~~~~~~~~~~
16 Occupancy ~~~~~~~~~~~~~~~~~ 63384. 33063. 30321.
17 Travel ~~~~~~~~~~~~~~~~~~~ 23345. 10269. 13076.
18 Payments of travel or entertainment expenses
for any federal, state, or local public officials ~
19 Conferences, conventions, and meetings ~~
20 Interest ~~~~~~~~~~~~~~~~~~
21 Payments to affiliates ~~~~~~~~~~~~
22 Depreciation, depletion, and amortization ~~ 18255. 6719. 11536.
23 Insurance ~~~~~~~~~~~~~~~~~ 8920. 8920.
24 Other expenses. Itemize expenses not covered
above (List miscellaneous expenses on line 24e. If
line 24e amount exceeds 10% of line 25, column (A)
amount, list line 24e expenses on Schedule O.)
a DUES AND SUBSCRIPTIONS 43186. 31446. 11740.
b TRAINING AND STAFF DEVE 13029. 13029.
c BAD DEBT 2627. 2627.
d MISCELLANEOUS 2173. 905. 1268.
e All other expenses 2062. 1200. 862.
25 Total functional expenses. Add lines 1 through 24e 335429878. 335095651. 304309. 29918.
26 Joint costs. Complete this line only if the organization
reported in column (B) joint costs from a combined
educational campaign and fundraising solicitation.
Check here | † if following SOP 98-2 (ASC 958-720)
032010 12-23-20 Form 990 (2020)

10 RYAN 023437
EXHIBIT 4
Part X Balance Sheet
Check if Schedule O contains a response or note to any line in this Part X †
(A) (B)
Beginning of year End of year
1 Cash - non-interest-bearing ~~~~~~~~~~~~~~~~~~~~~~~~~ 1681320. 1 15882912.
2 Savings and temporary cash investments ~~~~~~~~~~~~~~~~~~ 63091. 2 1576613.
3 Pledges and grants receivable, net ~~~~~~~~~~~~~~~~~~~~~ 1224945. 3 1332534.
4 Accounts receivable, net ~~~~~~~~~~~~~~~~~~~~~~~~~~ 124648. 4 300.
5 Loans and other receivables from any current or former officer, director,
trustee, key employee, creator or founder, substantial contributor, or 35%
controlled entity or family member of any of these persons ~~~~~~~~~ 5
6 Loans and other receivables from other disqualified persons (as defined
under section 4958(f)(1)), and persons described in section 4958(c)(3)(B) ~~ 6
7 Notes and loans receivable, net ~~~~~~~~~~~~~~~~~~~~~~~ 7
Assets
8 Inventories for sale or use ~~~~~~~~~~~~~~~~~~~~~~~~~~ 8

9 Prepaid expenses and deferred charges ~~~~~~~~~~~~~~~~~~ 14630. 9 13788.
10 a Land, buildings, and equipment: cost or other
basis. Complete Part VI of Schedule D ~~~ 10a 15277.
b Less: accumulated depreciation ~~~~~~ 10b 6712. 6341. 10c 8565.
11 Investments - publicly traded securities ~~~~~~~~~~~~~~~~~~~ 11
12 Investments - other securities. See Part IV, line 11 ~~~~~~~~~~~~~~ 12
13 Investments - program-related. See Part IV, line 11 ~~~~~~~~~~~~~ 13
14 Intangible assets ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 44919. 14 31000.
15 Other assets. See Part IV, line 11 ~~~~~~~~~~~~~~~~~~~~~~ 13088. 15 14023085.
16 Total assets. Add lines 1 through 15 (must equal line 33) 3172982. 16 32868797.
17 Accounts payable and accrued expenses ~~~~~~~~~~~~~~~~~~ 116649. 17 8990997.
18 Grants payable ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 18
19 Deferred revenue ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 19
20 Tax-exempt bond liabilities ~~~~~~~~~~~~~~~~~~~~~~~~~ 20
21 Escrow or custodial account liability. Complete Part IV of Schedule D ~~~~ 21
22 Loans and other payables to any current or former officer, director,
Liabilities
trustee, key employee, creator or founder, substantial contributor, or 35%

controlled entity or family member of any of these persons ~~~~~~~~~ 22
23 Secured mortgages and notes payable to unrelated third parties ~~~~~~ 23

24 Unsecured notes and loans payable to unrelated third parties ~~~~~~~~ 24
25 Other liabilities (including federal income tax, payables to related third
parties, and other liabilities not included on lines 17-24). Complete Part X
of Schedule D ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 25
26 Total liabilities. Add lines 17 through 25 116649. 26 8990997.
Organizations that follow FASB ASC 958, check here | † X
Net Assets or Fund Balances
and complete lines 27, 28, 32, and 33.

27 Net assets without donor restrictions ~~~~~~~~~~~~~~~~~~~~ 1450790. 27 6063177.
28 Net assets with donor restrictions ~~~~~~~~~~~~~~~~~~~~~~ 1605543. 28 17814623.
Organizations that do not follow FASB ASC 958, check here | †
and complete lines 29 through 33.
29 Capital stock or trust principal, or current funds ~~~~~~~~~~~~~~~ 29
30 Paid-in or capital surplus, or land, building, or equipment fund ~~~~~~~~ 30
31 Retained earnings, endowment, accumulated income, or other funds ~~~~ 31
32 Total net assets or fund balances ~~~~~~~~~~~~~~~~~~~~~~ 3056333. 32 23877800.
33 Total liabilities and net assets/fund balances 3172982. 33 32868797.
Form 990 (2020)
032011 12-23-20
11 RYAN 023438
EXHIBIT 4
Part XI Reconciliation of Net Assets
Check if Schedule O contains a response or note to any line in this Part XI †
1 Total revenue (must equal Part VIII, column (A), line 12) ~~~~~~~~~~~~~~~~~~~~~~~~~~ 1 356251345.
2 Total expenses (must equal Part IX, column (A), line 25) ~~~~~~~~~~~~~~~~~~~~~~~~~~ 2 335429878.
3 Revenue less expenses. Subtract line 2 from line 1 ~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 3 20821467.
4 Net assets or fund balances at beginning of year (must equal Part X, line 32, column (A)) ~~~~~~~~~~ 4 3056333.
5 Net unrealized gains (losses) on investments ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 5
6 Donated services and use of facilities ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 6
7 Investment expenses ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 7
8 Prior period adjustments ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 8
9 Other changes in net assets or fund balances (explain on Schedule O) ~~~~~~~~~~~~~~~~~~ 9 0.
10 Net assets or fund balances at end of year. Combine lines 3 through 9 (must equal Part X, line 32,
column (B)) 10 23877800.
Part XII Financial Statements and Reporting
Check if Schedule O contains a response or note to any line in this Part XII †
Yes No
1 Accounting method used to prepare the Form 990: † Cash X
† Accrual† Other
If the organization changed its method of accounting from a prior year or checked "Other," explain in Schedule O.
2a Were the organization's financial statements compiled or reviewed by an independent accountant? ~~~~~~~~~~~~ 2a X
If "Yes," check a box below to indicate whether the financial statements for the year were compiled or reviewed on a
separate basis, consolidated basis, or both:
† Separate basis † Consolidated basis † Both consolidated and separate basis
b Were the organization's financial statements audited by an independent accountant? ~~~~~~~~~~~~~~~~~~~ 2b X
If "Yes," check a box below to indicate whether the financial statements for the year were audited on a separate basis,
consolidated basis, or both:
† Separate basis † Consolidated basis † Both consolidated and separate basis
c If "Yes" to line 2a or 2b, does the organization have a committee that assumes responsibility for oversight of the audit,
review, or compilation of its financial statements and selection of an independent accountant?~~~~~~~~~~~~~~~ 2c
If the organization changed either its oversight process or selection process during the tax year, explain on Schedule O.
3a As a result of a federal award, was the organization required to undergo an audit or audits as set forth in the Single Audit
Act and OMB Circular A-133? ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 3a X
b If "Yes," did the organization undergo the required audit or audits? If the organization did not undergo the required audit
or audits, explain why on Schedule O and describe any steps taken to undergo such audits 3b

Form 990 (2020)
032012 12-23-20
12 RYAN 023439
EXHIBIT 4
Schedule I (Form 990) CENTER FOR TECHNOLOGY AND CIVIC LIFE 47-2158694 Page 1
Part II Continuation of Grants and Other Assistance to Domestic Organizations and Domestic Governments (Schedule I (Form 990), Part II.)
(a) Name and address of (b) EIN (c) IRC section (d) Amount of (e) Amount of (f) Method of (g) Description of (h) Purpose of grant
organization or government if applicable cash grant non-cash valuation non-cash assistance or assistance
assistance (book, FMV,
appraisal, other)
TO SUPPORT THE SAFE
TOWN OF WINTHROP ADMINISTRATION OF PUBLIC
94 BIRCH RD ELECTIONS DURING THE
WINTHROP, MA 02152 LOCAL GOVERNMENT 7842. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF WOBURN ADMINISTRATION OF PUBLIC
10 COMMON ST ELECTIONS DURING THE
WOBURN, MA 01801 LOCAL GOVERNMENT 19492. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
WORCESTER CITY CLERK ELECTION ADMINISTRATION OF PUBLIC
DEVSION - 455 MAIN ST ROOM 208 - ELECTIONS DURING THE
WORCESTER, MA 01608 LOCAL GOVERNMENT 159506. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
TOWN OF YARMOUTH ADMINISTRATION OF PUBLIC
1146 ROUTE 28 ELECTIONS DURING THE
S. YARMOUTH, MA 02664 LOCAL GOVERNMENT 9595. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF ADRIAN ADMINISTRATION OF PUBLIC
135 E MAUMEE ST ELECTIONS DURING THE
ADRIAN, MI 49221 LOCAL GOVERNMENT 15157. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF ALBION ELECTION DEPARTMENT ADMINISTRATION OF PUBLIC
112 W CASS STREET ELECTIONS DURING THE
ALBION, MI 49224 LOCAL GOVERNMENT 6920. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
ALLENDALE CHARTER TOWNSHIP ADMINISTRATION OF PUBLIC
6676 LAKE MICHIGAN DR ELECTIONS DURING THE
ALLENDALE, MI 49401 LOCAL GOVERNMENT 15398. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
the MI Court of Claims.

CITY OF ALMA ADMINISTRATION OF PUBLIC
525 E. SUPERIOR STREET ELECTIONS DURING THE
ALMA, MI 48801 LOCAL GOVERNMENT 5483. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF ANN ARBOR ADMINISTRATION OF PUBLIC
301 E. HURON STREET ELECTIONS DURING THE
ANN ARBOR, MI 48104 38-6004534 LOCAL GOVERNMENT 417268. 0. COVID-19 PANDEMIC
Schedule I (Form 990)
032241
11-05-20 89
RYAN 023516
EXHIBIT 4
appraisal, other)
TO SUPPORT THE SAFE
CITY OF BATTLE CREEK ADMINISTRATION OF PUBLIC
10 N. DIVISION STREET ELECTIONS DURING THE
BATTLE CREEK, MI 49014 LOCAL GOVERNMENT 200000. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF BAY CITY ADMINISTRATION OF PUBLIC
301 WASHINGTON AVE ELECTIONS DURING THE
BAY CITY, MI 48708 LOCAL GOVERNMENT 21841. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
BEDFORD TOWNSHIP ADMINISTRATION OF PUBLIC
8100 JACKMAN ROAD ELECTIONS DURING THE
TEMPERANCE, MI 48182 LOCAL GOVERNMENT 9376. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
BENTON CHARTER TOWNSHIP ADMINISTRATION OF PUBLIC
1725 TERRITIORIAL RD. ELECTIONS DURING THE
BENTON HARBOR, MI 49022 LOCAL GOVERNMENT 14558. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
BENTON CHARTER TOWNSHIP ADMINISTRATION OF PUBLIC
1725 TERRITIORIAL RD. ELECTIONS DURING THE
TO SUPPORT THE SAFE
CITY OF BENTON HARBOR ADMINISTRATION OF PUBLIC
1295 E. NAPIER ELECTIONS DURING THE
TO SUPPORT THE SAFE
CITY OF BIG RAPIDS ADMINISTRATION OF PUBLIC
226 N MICHIGAN AVENUE ELECTIONS DURING THE
BIG RAPIDS, MI 49307 LOCAL GOVERNMENT 8351. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE

BRIDGEPORT CHARTER TOWNSHIP ADMINISTRATION OF PUBLIC
6740 DIXIE HIGHWAY ELECTIONS DURING THE
BRIDGEPORT, MI 48722 38-6018173 LOCAL GOVERNMENT 8563. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CHARTER TOWNSHIP OF BROWNSTOWN ADMINISTRATION OF PUBLIC
21313 TELEGRAPH ROAD ELECTIONS DURING THE
BROWNSTOWN, MI 48183 38-6006887 LOCAL GOVERNMENT 15733. 0. COVID-19 PANDEMIC
032241
11-05-20 90
RYAN 023517
EXHIBIT 4
appraisal, other)
TO SUPPORT THE SAFE
SAGINAW ADMINISTRATION OF PUBLIC
1160 SOUTH OUTER DRIVE ELECTIONS DURING THE
SAGINAW, MI 48601 38-6029179 LOCAL GOVERNMENT 8512. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF CADILLAC ADMINISTRATION OF PUBLIC
200 N LAKE ST. ELECTIONS DURING THE
CADILLAC, MI 49601 38-6004541 LOCAL GOVERNMENT 5112. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CHARTER TOWNSHIP OF CANTON ADMINISTRATION OF PUBLIC
1150 S. CANTON CENTER ELECTIONS DURING THE
CANTON, MI 48188 38-6008155 LOCAL GOVERNMENT 42931. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF CENTER LINE ADMINISTRATION OF PUBLIC
7070 E. TEN MILE ELECTIONS DURING THE
CENTER LINE, MI 48015 38-6004668 LOCAL GOVERNMENT 5096. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CHARTER TOWNSHIP OF CLINTON ADMINISTRATION OF PUBLIC
40700 ROMEO PLANK ROAD ELECTIONS DURING THE
CLINTON TOWNSHIP, MI 48038 38-6006897 LOCAL GOVERNMENT 62288. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CHARTER TOWNSHIP OF COMMERCE ADMINISTRATION OF PUBLIC
2009 TOWNSHIP DRIVE ELECTIONS DURING THE
COMMERCE TOWNSHIP, MI 48390 38-6006899 LOCAL GOVERNMENT 15193. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CHARTER TOWNSHIP OF FLINT ADMINISTRATION OF PUBLIC
1490 S DYE ROAD ELECTIONS DURING THE
FLINT, MI 48532 38-6005302 LOCAL GOVERNMENT 24654. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE

CHARTER TOWNSHIP OF HARRISON ADMINISTRATION OF PUBLIC
38151 LANSE CREUSE ST ELECTIONS DURING THE
HARRISON TOWNSHIP, MI 48045 38-6005518 LOCAL GOVERNMENT 11988. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
HIGHLAND ADMINISTRATION OF PUBLIC
205 N JOHN ST ELECTIONS DURING THE
HIGHLAND, MI 48357 38-6026891 LOCAL GOVERNMENT 10000. 0. COVID-19 PANDEMIC
032241
11-05-20 91
RYAN 023518
EXHIBIT 4
appraisal, other)
TO SUPPORT THE SAFE
CHARTER TOWNSHIP OF INDEPENDENCE ADMINISTRATION OF PUBLIC
6483 WALDON CENTER DRIVE ELECTIONS DURING THE
CLARKSTON, MI 48346 38-6006906 LOCAL GOVERNMENT 13290. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
NORTHVILLE TOWNSHIP ADMINISTRATION OF PUBLIC
44405 SIX MILE ROAD ELECTIONS DURING THE
NORTHVILLE, MI 48168 38-6006917 LOCAL GOVERNMENT 10000. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CHARTER TOWNSHIP OF OAKLAND ADMINISTRATION OF PUBLIC
(GENERAL FUND - POOL) - 4393 ELECTIONS DURING THE
COLLINS RD - ROCHESTER, MI 48306 38-2004632 LOCAL GOVERNMENT 11200. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CHARTER TOWNSHIP OF OXFORD ADMINISTRATION OF PUBLIC
300 DUNLAP RD. ELECTIONS DURING THE
OXFORD, MI 48371 38-1710580 LOCAL GOVERNMENT 6178. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CHARTER TOWNSHIP OF UNION, ADMINISTRATION OF PUBLIC
MICHIGAN - 2010 SOUTH LINCOLN ROAD ELECTIONS DURING THE
- MT PLEASANT, MI 48858 LOCAL GOVERNMENT 10417. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CHARTER TOWNSHIP OF YPSILANTI ADMINISTRATION OF PUBLIC
7200 S. HURON RIVER DR. ELECTIONS DURING THE
YPSILANTI, MI 48197 38-6007433 LOCAL GOVERNMENT 39445. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CHARTER TOWNSHIP OF CHESTERFIELD ADMINISTRATION OF PUBLIC
47275 SUGARBUSH RD. ELECTIONS DURING THE
CHESTERFIELD TOWNSHIP, MI 48047 38-6006891 LOCAL GOVERNMENT 16545. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE

CITY OF BURTON ADMINISTRATION OF PUBLIC
4303 S CENTER RD ELECTIONS DURING THE
BURTON, MI 48519 38-6006890 LOCAL GOVERNMENT 18866. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF FARMINGTON HILLS ADMINISTRATION OF PUBLIC
31555 ELEVEN MILE ROAD ELECTIONS DURING THE
FARMINGTON HILLS, MI 48336 38-6006902 LOCAL GOVERNMENT 92172. 0. COVID-19 PANDEMIC
032241
11-05-20 92
RYAN 023519
EXHIBIT 4
appraisal, other)
TO SUPPORT THE SAFE
FRASER CITY, CITYT OF FRASER ADMINISTRATION OF PUBLIC
CLERK'S ELECTION OFFICE - 33000 ELECTIONS DURING THE
GARFIELD RD - FRASER, MI 48026 38-6007219 LOCAL GOVERNMENT 8099. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF GROSSE POINTE WOODS ADMINISTRATION OF PUBLIC
20025 MACK PLAZA ELECTIONS DURING THE
GROSSE POINTE WOODS, MI 48236 38-6007179 LOCAL GOVERNMENT 22262. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF NILES ADMINISTRATION OF PUBLIC
333 N 2ND STREET, STE. 301 ELECTIONS DURING THE
NILES, MI 49120 38-6004720 LOCAL GOVERNMENT 6877. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF ROYAL OAK ADMINISTRATION OF PUBLIC
203 S TROY ST ELECTIONS DURING THE
ROYAL OAK, MI 48067 38-6004646 LOCAL GOVERNMENT 43948. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF TRAVERSE CITY ADMINISTRATION OF PUBLIC
400 BOARDMAN AVENUE ELECTIONS DURING THE
TRAVERSE CITY, MI 49684 38-6004740 LOCAL GOVERNMENT 7407. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF WAYNE DEPARTMENT OF ADMINISTRATION OF PUBLIC
ELECTIONS - 3355 S. WAYNE RD. - ELECTIONS DURING THE
WAYNE, MI 48184 38-6037548 LOCAL GOVERNMENT 11169. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF DEARBORN ADMINISTRATION OF PUBLIC
16901 MICHIGAN AVENUE ELECTIONS DURING THE
DEARBORN, MI 48126 38-6004605 LOCAL GOVERNMENT 400000. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE

CITY OF DEARBORN HEIGHTS ADMINISTRATION OF PUBLIC
6045 FENTON ELECTIONS DURING THE
DEARBORN HEIGHTS, MI 48127 38-1712300 LOCAL GOVERNMENT 27643. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
DELHI CHARTER TOWNSHIP ADMINISTRATION OF PUBLIC
2074 AURELIUS ROAD ELECTIONS DURING THE
HOLT, MI 48842 38-6019639 LOCAL GOVERNMENT 11688. 0. COVID-19 PANDEMIC
032241
11-05-20 93
RYAN 023520
EXHIBIT 4
appraisal, other)
TO SUPPORT THE SAFE
DELTA CHARTER TOWNSHIP ADMINISTRATION OF PUBLIC
7710 WEST SAGINAW HWY ELECTIONS DURING THE
LANSING, MI 48917 38-6030414 LOCAL GOVERNMENT 17465. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF DETROIT ADMINISTRATION OF PUBLIC
2 WOODWARD AVE. ELECTIONS DURING THE
DETROIT, MI 48226 38-6004606 LOCAL GOVERNMENT 7436450. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
DEWITT CHARTER TOWNSHIP ADMINISTRATION OF PUBLIC
1401 W. HERBISON RD ELECTIONS DURING THE
DEWITT, MI 48820 38-1847399 LOCAL GOVERNMENT 6744. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF EAST LANSING ADMINISTRATION OF PUBLIC
410 ABBOT ROAD ELECTIONS DURING THE
EAST LANSING, MI 48823 38-6004674 LOCAL GOVERNMENT 200000. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF EASTPOINTE ADMINISTRATION OF PUBLIC
2 WOODWARD AVE. ELECTIONS DURING THE
DETROIT, MI 48226 38-6004550 LOCAL GOVERNMENT 70175. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
EATON COUNTY ADMINISTRATION OF PUBLIC
101 S COCHRAN ELECTIONS DURING THE
CHARLOTTE, MI 48813 38-6004847 LOCAL GOVERNMENT 14536. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
ECORSE ADMINISTRATION OF PUBLIC
3869 WEST JEFFERSON AVE. ELECTIONS DURING THE
ECORSE, MI 48229 38-6004676 LOCAL GOVERNMENT 10365. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE

CITY OF ESCANABA ADMINISTRATION OF PUBLIC
P.O. BOX 948 ELECTIONS DURING THE
ESCANABA, MI 49829 38-6004679 LOCAL GOVERNMENT 5976. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF FERNDALE ADMINISTRATION OF PUBLIC
300 E. 9 MILE ROAD ELECTIONS DURING THE
FERNDALE, MI 48220 38-6004610 LOCAL GOVERNMENT 21757. 0. COVID-19 PANDEMIC
032241
11-05-20 94
RYAN 023521
EXHIBIT 4
appraisal, other)
TO SUPPORT THE SAFE
CITY OF FLINT ADMINISTRATION OF PUBLIC
1490 S DYE ROAD ELECTIONS DURING THE
FLINT, MI 48532 38-6005302 LOCAL GOVERNMENT 312328. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
FRENCHTOWN CHARTER TOWNSHIP ADMINISTRATION OF PUBLIC
2744 VIVIAN RD ELECTIONS DURING THE
MONROE, MI 48162 38-6019659 LOCAL GOVERNMENT 9261. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
GAINES CHARTER TOWNSHIP CLERK ADMINISTRATION OF PUBLIC
DEPARTMENT - 8555 KALAMAZOO AVENUE ELECTIONS DURING THE
SE - CALEDONIA, MI 49316 38-1869895 LOCAL GOVERNMENT 11175. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF GARDEN CITY ADMINISTRATION OF PUBLIC
6000 MIDDLEBELT ROAD ELECTIONS DURING THE
GARDEN CITY, MI 48135 38-6004685 LOCAL GOVERNMENT 12732. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
GENOA CHARTER TOWNSHIP ADMINISTRATION OF PUBLIC
2911 DORR ROAD ELECTIONS DURING THE
BRIGHTON, MI 48116 38-1904651 LOCAL GOVERNMENT 6276. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
GRAND HAVEN CHARTER TOWNSHIP ADMINISTRATION OF PUBLIC
13300 168TH AVE ELECTIONS DURING THE
GRAND HAVEN, MI 49417 38-1817417 LOCAL GOVERNMENT 6045. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF GRAND RAPIDS TREASURER ADMINISTRATION OF PUBLIC
300 MONROE AVENUE, NW ELECTIONS DURING THE
GRAND RAPIDS, MI 49503 38-6004689 LOCAL GOVERNMENT 280852. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE

GRAND TRAVERSE COUNTY ADMINISTRATION OF PUBLIC
400 BOARDMAN AVENUE ELECTIONS DURING THE
TRAVERSE CITY, MI 49684 38-6004852 LOCAL GOVERNMENT 10607. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF GRANDVILLE ADMINISTRATION OF PUBLIC
3195 WILSON AVE SW ELECTIONS DURING THE
GRANDVILLE, MI 49418 38-6004690 LOCAL GOVERNMENT 5860. 0. COVID-19 PANDEMIC
032241
11-05-20 95
RYAN 023522
EXHIBIT 4
appraisal, other)
TO SUPPORT THE SAFE
HAMBURG TOWNSHIP ADMINISTRATION OF PUBLIC
10405 MERRILL ROAD ELECTIONS DURING THE
HAMBURG, MI 48139 38-1855320 LOCAL GOVERNMENT 5007. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF HAMTRAMCK ADMINISTRATION OF PUBLIC
3401 EVALINE ELECTIONS DURING THE
HAMTRAMCK, MI 48212 38-6004617 LOCAL GOVERNMENT 49889. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF HARPER WOODS ADMINISTRATION OF PUBLIC
19617 HARPER AVE. ELECTIONS DURING THE
HARPER WOODS, MI 48225 38-6005461 LOCAL GOVERNMENT 17775. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF HAZEL PARK ADMINISTRATION OF PUBLIC
111 E. NINE MILE RD. ELECTIONS DURING THE
HAZEL PARK, MI 48030 38-6004619 LOCAL GOVERNMENT 20600. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF HIGHLAND PARK ADMINISTRATION OF PUBLIC
12050 WOODWARD AVENUE ELECTIONS DURING THE
HIGHLAND PARK, MI 48203 38-6004695 LOCAL GOVERNMENT 26716. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF HOLLAND - ELECTIONS ADMINISTRATION OF PUBLIC
270 S RIVER AVE ELECTIONS DURING THE
HOLLAND, MI 49423 38-6004622 LOCAL GOVERNMENT 19040. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
HOLLAND CHARTER TOWNSHIP ADMINISTRATION OF PUBLIC
353 N 120TH AVE ELECTIONS DURING THE
TO SUPPORT THE SAFE

CITY OF HUNTINGTON WOODS ADMINISTRATION OF PUBLIC
26815 SCOTIA RD. ELECTIONS DURING THE
HUNTINGTON WOODS, MI 48070 38-6004635 LOCAL GOVERNMENT 10000. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CHARTER TOWNSHIP OF HURON ADMINISTRATION OF PUBLIC
37865 MAHOGANY DR. ELECTIONS DURING THE
NEW BOSTON, MI 48164 38-6022361 LOCAL GOVERNMENT 5958. 0. COVID-19 PANDEMIC
032241
11-05-20 96
RYAN 023523
EXHIBIT 4
appraisal, other)
TO SUPPORT THE SAFE
INGHAM COUNTY CLERK ADMINISTRATION OF PUBLIC
PO BOX 179 ELECTIONS DURING THE
MASON, MI 48854 38-6005629 LOCAL GOVERNMENT 55806. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF INKSTER ADMINISTRATION OF PUBLIC
26215 TROWBRIDGE ST. ELECTIONS DURING THE
INKSTER, MI 48141 38-6007226 LOCAL GOVERNMENT 50546. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF JACKSON - CLERK ELECTIONS ADMINISTRATION OF PUBLIC
161 W MICHIGAN AVE. ELECTIONS DURING THE
JACKSON, MI 49201 38-6004701 LOCAL GOVERNMENT 21874. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF KALAMAZOO ADMINISTRATION OF PUBLIC
241 W. SOUTH STREET ELECTIONS DURING THE
KALAMAZOO, MI 49007 38-6004627 LOCAL GOVERNMENT 218869. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY FO KENTWOOD ADMINISTRATION OF PUBLIC
4900 BRETON AVE., SE ELECTIONS DURING THE
KENTWOOD, MI 49508 38-1844797 LOCAL GOVERNMENT 31014. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF LANSING ADMINISTRATION OF PUBLIC
124 W. MICHIGAN AVE ELECTIONS DURING THE
LANSING, MI 48933 38-6004628 LOCAL GOVERNMENT 488390. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF LAPEER ADMINISTRATION OF PUBLIC
576 LIBERTY PARK ELECTIONS DURING THE
LAPEER, MI 48446 38-6004630 LOCAL GOVERNMENT 5971. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE

LINCOLN CHARTER TOWNSHIP ADMINISTRATION OF PUBLIC
PO BOX 279 ELECTIONS DURING THE
STEVENSVILLE, MI 49127 38-6036236 LOCAL GOVERNMENT 5325. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF LINCOLN PARK CLERKS OFFICE ADMINISTRATION OF PUBLIC
1355 SOUTHFIELD ROAD ELECTIONS DURING THE
LINCOLN PARK, MI 48146 38-6004632 LOCAL GOVERNMENT 25199. 0. COVID-19 PANDEMIC
032241
11-05-20 97
RYAN 023524
EXHIBIT 4
appraisal, other)
TO SUPPORT THE SAFE
CITY OF LIVONIA ADMINISTRATION OF PUBLIC
33000 CIVIC CENTER DRIVE ELECTIONS DURING THE
LIVONIA, MI 48154 38-6005820 LOCAL GOVERNMENT 142154. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
MACOMB TOWNSHIP ADMINISTRATION OF PUBLIC
54111 BROUGHTON RD ELECTIONS DURING THE
MACOMB, MI 48042 38-1884898 LOCAL GOVERNMENT 78700. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CHARTER TOWNSHIP OF MADISON ADMINISTRATION OF PUBLIC
3804 S. ADRIAN HWY. ELECTIONS DURING THE
ADRIAN, , MI 49221 38-6003771 LOCAL GOVERNMENT 5264. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF MADISON HEIGHTS ADMINISTRATION OF PUBLIC
300 W. 13 MILE ROAD ELECTIONS DURING THE
MADISON HEIGHTS, MI 48071 38-6025685 LOCAL GOVERNMENT 30071. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF MARQUETTE ADMINISTRATION OF PUBLIC
300 W BARAGA AVE ELECTIONS DURING THE
MARQUETTE, MI 49855 38-6004521 LOCAL GOVERNMENT 15899. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
MARQUETTE COUNTY ADMINISTRATION OF PUBLIC
100 N. FRONT ST. ELECTIONS DURING THE
MARQUETTE, MI 49855 38-6004869 LOCAL GOVERNMENT 8210. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF MELVINDALE ADMINISTRATION OF PUBLIC
3100 OAKWOOD BLVD. ELECTIONS DURING THE
MELVINDALE, MI 48122 38-6004637 LOCAL GOVERNMENT 7166. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE

CITY OF MONROE ADMINISTRATION OF PUBLIC
120 E. FIRST ST ELECTIONS DURING THE
MONROE, MI 48161 38-6004638 LOCAL GOVERNMENT 10710. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF MOUNT CLEMENS ADMINISTRATION OF PUBLIC
100 N. MAIN STREET ELECTIONS DURING THE
MOUNT CLEMENS, MI 48043 38-6004577 LOCAL GOVERNMENT 12274. 0. COVID-19 PANDEMIC
032241
11-05-20 98
RYAN 023525
EXHIBIT 4
appraisal, other)
TO SUPPORT THE SAFE
CITY OF MT PLEASANT ADMINISTRATION OF PUBLIC
320 WEST BROADWAY ELECTIONS DURING THE
MT PLEASANT, MI 48858 38-6004717 LOCAL GOVERNMENT 20815. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
MT. MORRIS TOWNSHIP ADMINISTRATION OF PUBLIC
5447 BICENTENNIAL DR. ELECTIONS DURING THE
MT. MORRIS, MI 48458 38-6024619 LOCAL GOVERNMENT 17854. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF MUSKEGON ADMINISTRATION OF PUBLIC
933 TERRACE ST. ELECTIONS DURING THE
MUSKEGAN, MI 49440 38-6004522 LOCAL GOVERNMENT 433580. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
MUSKEGON COUNTY CLERK ADMINISTRATION OF PUBLIC
990 TERRACE STREET ELECTIONS DURING THE
MUSKEGON, MI 49442 38-6006063 LOCAL GOVERNMENT 42531. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
MUSKEGON CHARTER TOWNSHIP ADMINISTRATION OF PUBLIC
1990 E. APPLE AVE ELECTIONS DURING THE
MUSKEGON, MI 49442 38-6006915 LOCAL GOVERNMENT 9464. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF MUSKEGON HEIGHTS ADMINISTRATION OF PUBLIC
2724 PECK STREET ELECTIONS DURING THE
MUSKEGON HEIGHTS, MI 49444 38-6004639 LOCAL GOVERNMENT 26110. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF NORTON SHORES ELECTION ADMINISTRATION OF PUBLIC
DIVISION - 4814 HENRY STREET - ELECTIONS DURING THE
NORTON SHORES, MI 49441 38-6006141 LOCAL GOVERNMENT 11391. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE

CITY OF NOVI ADMINISTRATION OF PUBLIC
45175 W 10 MILE RD ELECTIONS DURING THE
NOVI, MI 48375 38-6032551 LOCAL GOVERNMENT 26194. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF OAK PARK ADMINISTRATION OF PUBLIC
14000 OAK PARK BLVD. ELECTIONS DURING THE
OAK PARK, MI 48237 38-6004641 LOCAL GOVERNMENT 77694. 0. COVID-19 PANDEMIC
032241
11-05-20 99
RYAN 023526
EXHIBIT 4
appraisal, other)
TO SUPPORT THE SAFE
COUNTY OF OAKLAND ADMINISTRATION OF PUBLIC
2100 PONTIAC LAKE ROAD ELECTIONS DURING THE
WATERFORD, MI 48328 38-6004876 COUNTY GOVERNMEN 157908. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CHARTER TOWNSHIP OF ORION ADMINISTRATION OF PUBLIC
2525 JOSLYN ROAD ELECTIONS DURING THE
LAKE ORION, MI 48360 38-6006171 LOCAL GOVERNMENT 10648. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
OTTAWA COUNTY TREASURER ADMINISTRATION OF PUBLIC
12220 FILLMORE ST., ROOM 130 ELECTIONS DURING THE
WEST OLIVE, MI 49460 38-6004883 COUNTY GOVERNMEN 28679. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
PARK TOWNSHIP ADMINISTRATION OF PUBLIC
549 RED OAK CT. ELECTIONS DURING THE
TO SUPPORT THE SAFE
PLAINFIELD CHARTER TOWNSHIP ADMINISTRATION OF PUBLIC
6161 BELMONT AVE NE ELECTIONS DURING THE
BELMONT, MI 49306 38-6029174 LOCAL GOVERNMENT 12325. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
PLYMOUTH TOWNSHIP ADMINISTRATION OF PUBLIC
9955 N HAGGERTY ROAD ELECTIONS DURING THE
PLYMOUTH, MI 48170 38-6007665 LOCAL GOVERNMENT 8246. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF PONTIAC ADMINISTRATION OF PUBLIC
47450 WOODWARD ELECTIONS DURING THE
PONTIAC, MI 48342 38-6005034 LOCAL GOVERNMENT 405640. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE

CITY OF PORT HURON ADMINISTRATION OF PUBLIC
100 MCMORRAN BLVD. ELECTIONS DURING THE
PORT HURON, MI 48060 38-6004727 LOCAL GOVERNMENT 18662. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CHARTER TOWNSHIP OF PORT HURON ADMINISTRATION OF PUBLIC
3800 LAPEER RD. ELECTIONS DURING THE
PORT HURON, MI 48060 38-6035198 LOCAL GOVERNMENT 5590. 0. COVID-19 PANDEMIC
032241
11-05-20 100
RYAN 023527
EXHIBIT 4
appraisal, other)
TO SUPPORT THE SAFE
CITY OF PORTAGE ADMINISTRATION OF PUBLIC
7900 SOUTH WESTNEDGE AVE. ELECTIONS DURING THE
PORTAGE, MI 49002 38-6006266 LOCAL GOVERNMENT 21507. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CHARTER TOWNSHIP OF REDFORD ADMINISTRATION OF PUBLIC
15145 BEECH DALY ROAD ELECTIONS DURING THE
REDFORD, MI 48239 LOCAL GOVERNMENT 32355. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF ROCHESTER HILLS ADMINISTRATION OF PUBLIC
1000 ROCHESTER HILLS DR. ELECTIONS DURING THE
ROCHESTER HILLS, MI 48309 38-6006880 LOCAL GOVERNMENT 50670. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF ROMULUS ADMINISTRATION OF PUBLIC
11111 WAYNE ROAD ELECTIONS DURING THE
ROMULUS, MI 48174 38-6006334 LOCAL GOVERNMENT 16645. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF SAGINAW ADMINISTRATION OF PUBLIC
1315 S WASHINGTON AVE ELECTIONS DURING THE
TO SUPPORT THE SAFE
SAGINAW CHARTER TOWNSHIP ADMINISTRATION OF PUBLIC
4980 SHATTUCK RD. ELECTIONS DURING THE
TO SUPPORT THE SAFE
SCIO TOWNSHIP ADMINISTRATION OF PUBLIC
827 NORTH ZEEB RD. ELECTIONS DURING THE
TO SUPPORT THE SAFE

THE CHARTER TOWNSHIP OF SHELBY ADMINISTRATION OF PUBLIC
52700 VAN DYKE AVENUE ELECTIONS DURING THE
SHELBY TWP, MI 48316 38-6025448 LOCAL GOVERNMENT 28515. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF SOUTHFIELD ADMINISTRATION OF PUBLIC
26000 EVERGREEN ROAD ELECTIONS DURING THE
SOUTHFIELD, MI 48037 38-6031668 LOCAL GOVERNMENT 446225. 0. COVID-19 PANDEMIC
032241
11-05-20 101
RYAN 023528
EXHIBIT 4
appraisal, other)
TO SUPPORT THE SAFE
CITY OF SOUTHGATE ADMINISTRATION OF PUBLIC
14400 DIX-TOLEDO ELECTIONS DURING THE
SOUTHGAGE, MI 48195 38-6034466 LOCAL GOVERNMENT 16435. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
SPRINGFIELD TOWNSHIP ADMINISTRATION OF PUBLIC
12000 DAVISBURG RD ELECTIONS DURING THE
DAVISBURG, MI 48350 38-6245538 LOCAL GOVERNMENT 5260. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF ST. CLAIR SHORES ADMINISTRATION OF PUBLIC
27600 JEFFERSON AVENUE ELECTIONS DURING THE
ST. CLAIR SHORES, MI 48081 38-6004730 LOCAL GOVERNMENT 23770. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF ST. LOUIS ADMINISTRATION OF PUBLIC
1520 MARKET ST. ELECTIONS DURING THE
ST. LOUIS, MO 63103 38-6004592 LOCAL GOVERNMENT 5774. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF STERLING HEIGHTS ADMINISTRATION OF PUBLIC
40555 UTICA RD ELECTIONS DURING THE
STERLING HEIGHTS, MI 48313 38-1869375 LOCAL GOVERNMENT 65517. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
SUPERIOR TOWNSHIP CLERK'S OFFICE ADMINISTRATION OF PUBLIC
3040 NORTH PROSPECT ELECTIONS DURING THE
TO SUPPORT THE SAFE
CITY OF TAYLOR CLERK'S OFFICE ADMINISTRATION OF PUBLIC
23555 GODDARD ELECTIONS DURING THE
TAYLOR, MI 48180 38-6006926 LOCAL GOVERNMENT 47000. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE

CITY OF TRENTON ADMINISTRATION OF PUBLIC
2800 THIRD STREET ELECTIONS DURING THE
TRENTON, MI 48183 38-6007207 LOCAL GOVERNMENT 7285. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF TROY ADMINISTRATION OF PUBLIC
500 WEST BIG BEAVER ELECTIONS DURING THE
TROY, MI 48084 38-6027333 LOCAL GOVERNMENT 58393. 0. COVID-19 PANDEMIC
032241
11-05-20 102
RYAN 023529
EXHIBIT 4
appraisal, other)
TO SUPPORT THE SAFE
TUSCOLA COUNTY ADMINISTRATION OF PUBLIC
440 N STATE STREET ELECTIONS DURING THE
CARO, MI 48723 38-6004893 LOCAL GOVERNMENT 6320. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
VAN BUREN TOWNSHIP ADMINISTRATION OF PUBLIC
46425 TYLER RD. ELECTIONS DURING THE
VAN BUREN TOWNSHIP, MI 48111 38-6007135 LOCAL GOVERNMENT 19418. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CHARTER TOWNSHIP OF VIENNA ADMINISTRATION OF PUBLIC
3400 W. VIENNA ROAD ELECTIONS DURING THE
CLIO, MI 48420 38-6024623 LOCAL GOVERNMENT 6102. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF WALKER ADMINISTRATION OF PUBLIC
4243 REMEMBRANCE RD. ELECTIONS DURING THE
GRAND RAPIDS, MI 49534 38-1705421 LOCAL GOVERNMENT 9265. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF WARREN MICHIGAN CLERKS ADMINISTRATION OF PUBLIC
OFFICE - 1 CITY SQUARE STE 425 - ELECTIONS DURING THE
WARREN, MI 48093 38-6006931 LOCAL GOVERNMENT 78624. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
WASHTENAW COUNTY ADMINISTRATION OF PUBLIC
200 N. MAIN STREET ELECTIONS DURING THE
TO SUPPORT THE SAFE
CHARTER TOWNSHIP OF WATERFORD ADMINISTRATION OF PUBLIC
5200 CIVIC CENTER DR. ELECTIONS DURING THE
WATERFORD, MI 48329 38-6007299 LOCAL GOVERNMENT 39351. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE

WAYNE COUNTY ADMINISTRATION OF PUBLIC
3355 S. WAYNE RD. ELECTIONS DURING THE
WAYNE, MI 48184 38-6037548 LOCAL GOVERNMENT 416399. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CHARTER TOWNSHIP OF WEST ADMINISTRATION OF PUBLIC
BLOOMFIELD - 4550 WALNUT LAKE ROAD ELECTIONS DURING THE
- WEST BLOOMFIELD, MI 48325 38-6007323 LOCAL GOVERNMENT 33369. 0. COVID-19 PANDEMIC
032241
11-05-20 103
RYAN 023530
EXHIBIT 4
appraisal, other)
CITY OF WESTLAND, MICHIGAN - TO SUPPORT THE SAFE
DEPARTMENT OF CITY CLERK ADMINISTRATION OF PUBLIC
(ELECTIONS) - 36300 WARREN ROAD - ELECTIONS DURING THE
WESTLAND, MI 48185 38-1810301 LOCAL GOVERNMENT 178789. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
WHITE LAKE TOWNSHIP ADMINISTRATION OF PUBLIC
7525 HIGHLAND RD. ELECTIONS DURING THE
WHITE LAKE, MI 48386 38-6036210 LOCAL GOVERNMENT 9394. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF WYANDOTTE ADMINISTRATION OF PUBLIC
1292 POPLAR ELECTIONS DURING THE
WYANDOTTE, MI 48192 38-6004749 LOCAL GOVERNMENT 12042. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF WYOMING ADMINISTRATION OF PUBLIC
1155 28TH STREET SW ELECTIONS DURING THE
WYOMING, MI 49509 38-6006933 LOCAL GOVERNMENT 40632. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF YPSILANTI ADMINISTRATION OF PUBLIC
1 S HURON ST ELECTIONS DURING THE
TO SUPPORT THE SAFE
BLUE EARTH COUNTY ADMINISTRATION OF PUBLIC
204 S 5TH STREET ELECTIONS DURING THE
MANKATO, MN 56002 41-6005763 LOCAL GOVERNMENT 35784. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
COUNTY OF BROWN ADMINISTRATION OF PUBLIC
14 SOUTH STATE ST ELECTIONS DURING THE
NEW ULM, MN 56073 41-6005765 COUNTY GOVERNMEN 9795. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE

CITY OF BURNSVILLE ADMINISTRATION OF PUBLIC
100 CIVIC CENTER PARKWAY ELECTIONS DURING THE
BURNSVILLE, MN 55337 LOCAL GOVERNMENT 26457. 0. COVID-19 PANDEMIC
TO SUPPORT THE SAFE
CITY OF CHASKA ADMINISTRATION OF PUBLIC
1 CITY HALL PLAZA ELECTIONS DURING THE
CHASKA, MN 55318 41-6005041 LOCAL GOVERNMENT 6450. 0. COVID-19 PANDEMIC
032241
11-05-20 104
RYAN 023531
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CTCL00232
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CTCL00233
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CTCL00236
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CTCL00237
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CTCL00238
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CTCL00239
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EXHIBIT 6

CTCL Payments in Excess of $20,000 to Michigan Election Jurisdictions
CTCL Payment CTCL Payment to CTCL Payment to

Recipient Biden Jurisdiction Trump Jurisdiction Election Winner*
per 990 per 990
CITY OF ANN ARBOR $417,268 Biden 87.6%
CITY OF BATTLE CREEK $200,000 Biden 53.8%
CITY OF BAY CITY $21,841 Biden 53.4%
CITY OF BENTON HARBOR $120,840 Biden 94.2%
CHARTER TOWNSHIP OF CANTON $42,931 Biden 61.2%
CHARTER TOWNSHIP OF CLINTON Biden 49.7 to
$62,288
Trump 48.7
CITY OF FARMINGTON HILLS $92,172 Biden 64.8%
CITY OF DEARBORN $400,000 Biden 68.9%
CITY OF DEARBORN HEIGHTS $27,643 Biden 62.2%
CITY OF DETROIT $7,436,450 Biden 94.1%
CITY OF EAST LANSING $200,000 Biden 80%
CITY OF EASTPOINTE $70,175 Biden 74%
CITY OF FERNDALE $21,757 Biden 79%
CITY OF FLINT $312,328 Biden 82.6%
CHARTER TOWNSHIP OF FLINT $24,654 Biden 65.4%
CITY OF GRAND RAPIDS $280,852 Biden 70%
CITY OF GROSSE POINTE WOODS $22,262 Trump 52.3%
CITY OF HAMTRAMCK $49,889 Biden 85.6%
CITY OF HAZEL PARK $20,600 Biden 60.5%
CITY OF HIGHLAND PARK $26,716 Biden 95%

INGHAM COUNTY $55,806 Biden 65.2%
CITY OF INKSTER $50,546 Biden 90%
CITY OF JACKSON $21,874 Biden 56.9%
CITY OF KALAMAZOO $218,869 Biden 77.2%
CITY OF KENTWOOD $31,014 Biden 60%
CITY OF LANSING $488,390 Biden 73.2%
CITY OF LINCOLN PARK $25,199 Biden 56.5%
CITY OF LIVONIA $142,154 Biden 50.1%
MACOMB TOWNSHIP $78,700 Trump 61%
CITY OF MADISON HEIGHTS $30,071 Biden 55.3%
CITY OF MT PLEASANT $20,815 Biden 65%
CITY OF MUSKEGON $433,580 Biden 70.6%
MUSKEGON COUNTY Biden 49.4% to
$42,531
Trump 48.8%
CITY OF MUSKEGON HEIGHTS $26,110 Biden 90.8%
CITY OF NOVI $26,194 Biden 57.7%
CITY OF OAK PARK $77,694 Biden 81.2%
COUNTY OF OAKLAND $157,908 Biden 56.4%
OTTAWA COUNTY $28,679 Trump 59.8%
EXHIBIT 6
CITY OF PONTIAC $405,640 Biden 80.8%
CITY OF PORTAGE $21,507 Biden 57.3%
CHARTER TOWNSHIP OF REDFORD $32,355 Biden 73%
CITY OF ROCHESTER HILLS $50,670 Biden 51%
CITY OF ROYAL OAK $43,948 Biden 65.6%
CITY OF SAGINAW $402,878 Biden 76.4%
SAGINAW CHARTER TOWNSHIP $22,033 Biden 51.6%
THE CHARTER TOWNSHIP OF SHELBY $28,515 Trump 62%
CITY OF SOUTHFIELD $446,225 Biden 87.1%
CITY OF ST. CLAIR SHORES $23,770 Trump 52.4%
CITY OF STERLING HEIGHTS $65,517 Trump 55%
CITY OF TAYLOR $47,000 Biden 52%
CITY OF TROY $58,393 Biden 54.8
CHARTER TOWNSHIP OF WATERFORD $39,351 Trump 53.1%
CITY OF WARREN $78,624 Biden 55.8%
WASHTENAW COUNTY $53,174 Biden 72.6%
WAYNE COUNTY $416,399 Biden 68.4%
CHARTER TOWNSHIP OF WEST BLOOMFIELD $33,369 Biden 59.4%
CITY OF WESTLAND $178,789 Biden 59%
CITY OF WYOMING $40,632 Biden 52.4%
CHARTER TOWNSHIP OF YPSILANTI $39,445 Biden 74.4%
CITY OF YPSILANTI $100,399 Biden 86.4%
Total Money to
Total Money to
Biden
Trump Jurisdictions
Jurisdictions

98% $14,148,639 $286,794 2%
*Election results from Secretary of State's database located at

https://miboecfr.nictusa.com/cgi-bin/cfr/precinct_srch.cgi
EXHIBIT 6
EXHIBIT 7

Case 1:20-cv-00522-RJJ-RSK ECF No. 27, PageID.223 Filed 09/15/20 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF MICHIGAN
ANTHONY DAUNT,
Plaintiff, Case No. 1:20-cv-00522-RJJ-RSK
v. JOINT STIPULATIONS
JOCELYN BENSON, in her official

capacity as Michigan Secretary of State, et
al.,
Defendants.
Plaintiff, State Defendants1, and County Defendants2 file the following stipulations with
the Court:
1. Plaintiff and State Defendants agree that County Defendants are not
necessary parties to this litigation. Though the city and county clerks play a role, the
Secretary of State has the ultimate responsibility for maintaining Michigan’s voter rolls.

1
State Defendants are JOCELYN BENSON, in her official capacity as Michigan Secretary of
State; and JONATHAN BRATER, in his official capacity as Director of the Michigan Bureau of
Elections.
2 County Defendants are SHERYL GUY, in her official capacity as Antrim County Clerk;
DAWN OLNEY, in her official capacity as Benzie County Clerk; CHERYL POTTER BROWE, in
her official capacity as Charlevoix County Clerk; KAREN BREWSTER, in her official capacity as
Cheboygan County Clerk; SUZANNE KANINE, in her official capacity as Emmet County Clerk;
BONNIE SCHEELE, in her official capacity as Grand Traverse County Clerk; NANCY HUEBEL,
in her official capacity as Iosco County Clerk; DEBORAH HILL, in her official capacity as Kalkaska
County Clerk; JULIE A. CARLSON, in her official capacity as Keweenaw County Clerk; MICHELLE
L. CROCKER, in her official capacity as Leelanau County Clerk; ELIZABETH HUNDLEY, in her
official capacity as Livingston County Clerk; LORI JOHNSTON, in her official capacity as Mackinac
County Clerk; LISA BROWN, in her official capacity as Oakland County Clerk; SUSAN I.
DEFEYTER, in her official capacity as Otsego County Clerk; MICHELLE STEVENSON, in her
official capacity as Roscommon County Clerk; and LAWRENCE KESTENBAUM, in his official
capacity as Washtenaw County Clerk.
EXHIBIT 7
2. Per Federal Rule of Civil Procedure 15(a)(1)(B), Plaintiff will amend his
complaint to, among other things, dismiss County Defendants.
3. The County Defendants’ obligation to respond to Plaintiff’s initial
complaint should be stayed pending their dismissal.
4. County Defendants agree to comply, as if they were parties, with
reasonable discovery requests that are directed to them and that otherwise comply with
the Federal Rules.
Dated: September 15, 2020 Respectfully submitted,
[Signatures on next page]
2
EXHIBIT 7
/s/ Cameron T. Norris DANA NESSEL /s/Haider A. Kazim

William S. Consovoy Attorney General of Haider A. Kazim
Cameron T. Norris Michigan (P66146)
Tiffany H. Bates CUMMINGS, McCLOREY,
CONSOVOY MCCARTHY /s/ Elizabeth Husa Brigg DAVIS & ACHO, P.L.C.
PLLC Elizabeth Husa Briggs 310 W. Front Street,
1600 Wilson Blvd., Suite 700 (P73907) Ste. 221
Arlington, VA 22209 Heather S. Meingast Traverse City, MI 49684
(703) 243-9423 (P55439) (231) 922-1888
cam@consovoymccarthy.com Erik A. Grill (P64713) hkazim@cmda-law.com
Assistant Attorneys
Jason Torchinsky General /s/Courtney A. Gabbara
HOLTZMAN VOGEL P.O. Box 30736 Courtney A. Gabbara
JOSEFIAK TORCHINSKY Lansing, Michigan 48909 (P77817)
PLLC (517) 335-7659 COHL, STOKER &
45 North Hill Drive, Ste. 100 briggse1@michigan.gov TOSKEY, P.C.
Warrenton, VA 20186 601 N. Capitol Ave.
(540) 341-8800 Counsel for State Defendants Lansing, MI 48933
517-372-9000
Counsel for Plaintiff cgabbara@cstmlaw.com
/s/Brandon K. Buck
Brandon K. Buck (P63152)
Oakland County

Corporation Counsel
1200 N. Telegraph,
Dept 419, Bldg 14E
Pontiac, Michigan 48341
248-858-8677
buckb@oakgov.com
Counsel for County

Defendants
CERTIFICATE OF SERVICE
I filed these stipulations via ECF, which will notify all counsel of record.
Dated: September 15, 2020 /s/ Cameron T. Norris

Counsel for Plaintiff
3
EXHIBIT 7
EXHIBIT 8

CTCL COVID-19 RESPONSE GRANT REPORT TEMPLATE
This is a draft template of the grant report so you have a sense of what to expect in January 2021. You may
use this template to prepare for reporting in January. The grant reporting will include a simple online portal.
Please do not submit this document to CTCL.
Jurisdiction: Canton Township

Office: Clerk
Name and contact information for person filling out report: Anthony Essmaker 734-394-5120
1. $42,931
Total CTCL COVID-19 Response Grant received: _________________________________________
2. Please indicate how much of the grant funds were spent on the following public purposes
between the dates of June 15, 2020 and December 31, 2020:
$4,449
a. Ballot drop boxes ___________

b. 0
Drive-through voting ___________
c. 4,315
Personal protective equipment (PPE) for staff, poll workers, or voters___________
d. Poll worker recruitment funds, hazard pay, and/or training expenses___________
e. 0
Polling place rental and cleaning expenses___________
f. 26,161 (Contractors + Staff OT)
Temporary staffing support___________
g. Election department real estate costs, or costs associated with satellite election
0
department offices___________
h. 5,391
Vote-by-mail/Absentee voting equipment or supplies___________
i. 9,970
Election administration equipment___________________
j. 0
Voting materials in languages other than English___________
k. 0
Non-partisan voter education__________
3. 50,286
Total grant expenditures on sections 2a-2k ___________
EXHIBIT 8
4. If your answer to question 1 and question 3 do not match, for what additional purposes were
grant funds expended?
5. I certify that all grant funds have been expended for the public purpose of improving,
administering and ensuring the safety of elections in 2020.
6. If all grant funds have not been expended, you may request a 6-month grant extension which will
give you additional time to expend funds for the public purpose of improving and ensuring the
safety of elections in 2021. If you request an extension, you’ll be required to submit another grant
report by July 31, 2021.
Are you interested in requesting a 6-month extension to your grant agreement in order to spend
down your grant funds?
7. Optional: Here’s a chance to toot your own horn. What did you do with the CTCL COVID-19

Response grant funds that you’re most proud of?

PAGE 2
EXHIBIT 8
8. Optional: If your election office annual budget doubled, what would you be able to accomplish?

PAGE 3
EXHIBIT 8
7,482.38 10/16/20 Backup Scanned for mail ballots
2488.1 12/29/20 Extra ajudication workstation for processing mail ballots
4,315 8/25/20 Sneeze Guards for to protect precinct workers
4,449 7/31/20 Ballot Drop Box
5,391 11/27/20 Envelope Openers for Mail Ballot Processing
7,318 October OT Contract Workers to Process Mail Ballots
3,511.75 Late October/Early Nove Contract Workers to Process Mail Ballots
15,332.00 October OT OT needed to process mail ballots and to complete other related tasks
50,287.23

EXHIBIT 8
EXHIBIT 9

Fleming v. Macomb County Clerk, Not Reported in N.W.2d (2008)
Before: OWENS, P.J., and METER and SCHUETTE, JJ.

2008 WL 2553266
Only the Westlaw citation is currently available. Opinion
UNPUBLISHED OPINION. CHECK PER CURIAM.

COURT RULES BEFORE CITING.
*1 Plaintiffs Greg Fleming, William Susick, and Edward F.
UNPUBLISHED Cook appeal as of right from the trial court's July 30, 2007,
Court of Appeals of Michigan. order granting summary disposition in favor of defendant
Macomb County Clerk (county clerk). The trial court
Greg FLEMING, William Susick and dismissed plaintiffs' claims for declaratory and injunctive
Edward F. Cook, Plaintiffs–Appellants, relief and permitted the county clerk to mail unsolicited absent
voter ballot applications to county residents over the age of
and 60 living in communities in which the local city, township,
Max Fellsman, Plaintiff, or village clerk did not mail unsolicited applications. We
MACOMB COUNTY CLERK, reverse.1
Defendant–Appellee.
On September 21, 2006, the Macomb County Board of
Docket No. 279966. Commissioners (the board) passed a resolution authorizing
| the county clerk, Carmella Sabaugh,2 to mail absent voter
June 26, 2008. ballot applications for the November 2006 general election
to “Macomb County registered voters age 60 and over.”
The resolution limited the mailing list by eliminating those
West KeySummary
registered voters who lived in communities in which the city,
township, or village clerk automatically mailed applications
1 Election Law Application and delivery to voters over the age of 60.3 Notably, the board authorized
A county clerk was not statutorily authorized Sabaugh to mail the applications in her official capacity as
to mail unsolicited absentee voter ballot county clerk and to spend approximately $13,000 to prepare
applications to county residents over the age and mail the applications.

of 60 in communities in which the local
city, township, or village clerk did not mail Sabaugh strongly encouraged the board to pass this resolution
unsolicited applications. Rather, the county and presented several policy arguments to support her
clerk's statutory role during the election process position.4 Coincidentally, Sabaugh, a Democrat, was running
is limited to receiving information from against Republican Terri Lynn Land for Secretary of State in
the Secretary of State and distributing the the November 2006 election. According to press reports at
information to city, village, and township clerks. the time, Republicans in Macomb County began questioning
In relation to the absentee voter process, the Sabaugh's motives, claiming that Macomb County senior
county clerk has express authority to safeguard citizens tend to vote Democratic and noting that “[t]he timing
and distribute the absentee ballots to local [was] suspect.”5
clerks in advance of an election, but not
to deliver a ballot directly to a voter or to Shortly after the resolution was passed, plaintiffs filed suit
deliver absentee ballot applications. M.C.L.A. §§ seeking to prevent the mass mailing of absent voter ballot
168.647, 168.653a, 168.709, 168.715-168.717. applications, alleging violations of the Michigan Election
Law, MCL 168.1 et seq., and requesting injunctions to prevent
1 Cases that cite this headnote
the county clerk from mailing the unsolicited applications.
Plaintiffs also alleged that the proposed mailings violated the
Equal Protection clause of the Fourteenth Amendment and the
purity of elections clause of the Michigan Constitution, and
Macomb Circuit Court; LC No.2006–004256–AW.
© 2022 Thomson Reuters. No claim to original U.S. Government Works. EXHIBIT 9 1

diluted the votes of other Michigan voters. They specifically

requested a preliminary injunction to prevent the county clerk The trial court improperly granted defendant's motion for
from mailing applications for absent voter ballots for the summary disposition and denied plaintiffs' motion for the
November 2006 election, which the trial court denied. same. Defendant lacked statutory or constitutionally-granted
authority to mail unsolicited absent voter ballot applications.
Accordingly, on October 5, 2006, the county clerk mailed Further, by conducting the mailing, defendant violated the
49,234 absent voter ballot applications to Macomb County purity of elections clause of the Michigan Constitution.
voters over the age of 60 who had not otherwise been sent Because we find that these mass mailings are illegal and
an absent voter ballot application from their city, village, or unconstitutional, we hold that defendant, in her official
township clerk. In a press release, Sabaugh claimed that the capacity, may not mail unsolicited absent voter ballot
mailing resulted in the casting of “at least 7,700 additional applications to targeted individuals in the future.
votes” in the November 2006 general election.6
Const 1963, art 2, § 4 provides for the Legislature's control
The parties filed cross-motions for summary disposition to over elections, in relevant part, as follows:
address the question whether Sabaugh was authorized to mail
The legislature shall enact laws to regulate the time, place
the unsolicited absent voter ballot applications in her official
and manner of all nominations and elections, except as
capacity as county clerk. When the trial court issued its
otherwise provided in this constitution or in the constitution
opinion in July 2007, it noted that although the November
and laws of the United States. The legislature shall enact
2006 general election had occurred nearly a year earlier,
laws to preserve the purity of elections, to preserve the
it would still address the issue on the merits because the
secrecy of the ballot, to guard against abuses of the elective
issue was of continuing public interest and was capable of
franchise, and to provide for a system of voter registration
repetition yet evading review. In particular, the court noted
and absentee voting.
that the board likely would continue to pass resolutions
The duties of a county clerk or a county board of
allowing the county clerk to mail unsolicited absent voter
commissioners (supervisors) “shall be provided by law”
ballot applications before similar elections, leading to future
pursuant to Const 1963, art 7, §§ 4, 8.
scenarios in which plaintiffs would again have insufficient
advance notice to pursue to its conclusion the question
The Legislature enacted the Michigan Election Law pursuant
whether the county clerk had the authority to mail these
to its constitutional grant of authority. Under the Michigan
applications before the mailing and election would occur.
Election Law, the county clerk, the chief judge of the

Although the trial court noted that the Michigan Election
county probate court, and the county treasurer serve as
Law was silent regarding whether the county clerk was
the board of election commissioners for that county. MCL
authorized to mail unsolicited absent voter ballot applications
168.23(1). Pursuant to Secretary of State v. Berrien Co. Bd.
to voters age 60 and older, it determined that the county clerk
of Election Comm'rs, 373 Mich. 526, 530–531, 129 N.W.2d
was properly authorized by board resolution to conduct the
864 (1964), the county clerk and the county board of election
mailing. The trial court also rejected plaintiffs' claims that
commissioners must follow the directions provided by the
the mailing violated the “purity of elections” clause of the
Secretary of State in her role as Michigan's chief election
Michigan Constitution or the Equal Protection clause of the
officer. The county board of commissioners has no expressly
Fourteenth Amendment or that it diluted the vote of other
authorized role in elections. Instead, the board's roles include
Michigan voters.
“pass[ing] ordinances that relate to county affairs and do not
contravene the general laws of this state or interfere with the
*2 On appeal, plaintiffs challenge the trial court's order
local affairs of a township, city, or village within the limits
granting defendant's motion for summary disposition and
of the county....” MCL 46.11(j). The board also has a duty to
dismissing plaintiffs' claims. We review the trial court's
“[r]epresent the county and have the care and management of
determination regarding a motion for summary disposition
the property and business of the county if other provisions are
de novo. MacDonald v. PKT, Inc., 464 Mich. 322, 332, 628
not made.” MCL 46.11(l).
N.W.2d 33 (2001). We also review de novo questions of law,
including underlying issues of constitutional and statutory
The Michigan Election Law addresses the circumstances
construction. In re Petition by Wayne Co. Treasurer, 478
under which a voter is entitled to an absent voter ballot. MCL
Mich. 1, 6, 732 N.W.2d 458 (2007).
168.758(1) defines an “absent voter” as follows:

v. McIntire, 461 Mich. 147, 152, 599 N.W.2d 102 (1999),

*3 For the purposes of this act, “absent voter” means a quoting People v. McIntire, 232 Mich.App. 71, 119, 591
qualified and registered elector who meets 1 or more of the N.W.2d 231 (1998) (YOUNG, J., dissenting). Our primary
following requirements: goal is to ascertain and give effect to the intent of the
Legislature. Weakland v. Toledo Engineering Co., Inc., 467
(a) On account of physical disability, cannot without
Mich. 344, 347, 656 N.W.2d 175 (2003), mod 468 Mich.
another's assistance attend the polls on the day of an
1216, 656 N.W.2d 175 (2003). When a statute's language
election.
is unambiguous, we must assume that the Legislature
(b) On account of the tenets of his or her religion, cannot intended its plain meaning and enforce the statute as written.
attend the polls on the day of election. DiBenedetto v. West Shore Hosp., 461 Mich. 394, 402, 605
N.W.2d 300 (2000). We may only look beyond the statute to
(c) Cannot attend the polls on the day of an election in the determine the Legislature's intent when the statutory language
precinct in which he or she resides because of being an is ambiguous. Id.
election precinct inspector in another precinct.
The legal maxim expressio unius est exclusio alterius, i.e.,
(d) Is 60 years of age or older.
“[t]he expression of one thing is the exclusion of another,” “is
a rule of construction that is a product of logic and common
(e) Is absent or expects to be absent from the township or city
sense.” Hoerstman Gen. Contracting, Inc. v. Hahn, 474 Mich.
in which he or she resides during the entire period the polls
66, 74 & n. 8, 711 N.W.2d 340 (2006). This well-recognized
are open for voting on the day of an election.
maxim of statutory construction “expresses the learning of
common experience that when people say one thing they
(f) Cannot attend the polls on election day because of being
do not mean something else.” Feld v. Robert & Charles
confined in jail awaiting arraignment or trial.
Beauty Salon, 435 Mich. 352, 362, 459 N.W.2d 279 (1990),
quoting 2A Sands, Sutherland Statutory Construction (4th
A qualified absent voter is permitted to apply for an absent
ed), § 47.24, p 203. The maxim is “safely” used when a statute
voter ballot pursuant to MCL 168.759. For both primary
creates rights or duties “not in accordance with” the common
and general elections, “[t]he elector shall apply in person or
law. Feld, supra at 362, 459 N.W.2d 279 (citation omitted).
by mail with the clerk of the township, city, or village in
which the elector is registered.” MCL 168.759(1)-(2). MCL *4 “When what is expressed in a statute is creative, and
168.759(3) provides that an application for an absent voter not in a proceeding according to the course of the common

ballot may be made in the following three ways: law, it is exclusive, and the power exists only to the extent
plainly granted. Where a statute creates and regulates, and
(a) By a written request signed by the voter stating the
prescribes the mode and names the parties granted right to
statutory grounds for making the application.
invoke its provisions that mode must be followed and none
(b) On an absent voter ballot application form provided for other, and such parties only may act.” [Feld, supra at 362–
that purpose by the clerk of the city, township, or village. 363, 459 N.W.2d 279 (citation omitted).]
(c) On a federal postcard application. In Taylor v. Currie, 277 Mich.App. 85, 743 N.W.2d 571
Finally, MCL 168.759(5) requires, in pertinent part, (2007), this Court applied a plain reading of the statute
and the legal maxim expressio unius est exclusio alterius
The clerk of the city, township, or village shall have absent to determine that MCL 168.759 prohibits a city clerk from
voter ballot application forms available in the office of
mailing unsolicited absent voter ballot applications.7 It stated:
the clerk at all times and shall furnish an absent voter
ballot application form to anyone upon a verbal or written
request.... MCL 168.759(5) provides, in relevant part, that “[t]he
clerk of the city, township, or village shall have absent
When interpreting the Michigan Election Law to determine voter ballot application forms available in the office of
whether the county clerk is authorized to mail absent voter the clerk at all times and shall furnish an absent voter
ballot applications, we may not “ ‘impose different policy ballot application form to anyone upon a verbal or written
choices than those selected by the Legislature.’ “ People request.” This subsection clearly addresses the distribution

of applications for absent voter ballots. Under a plain RILEY, C.J.), we read the statute to preclude mass
reading, this subsection establishes two duties for city mailings when it specifically states that the clerk shall
clerks. First, the clerk must have applications for absent provide the applications upon written or verbal request.
voter ballots available in the clerk's office at all times. “[W]hen a statute limits a thing to be done in a
Second, the clerk “shall” provide an application to anyone particular mode, it includes a negative of any other
upon verbal or written request. mode.” Christensen v. Harris Co., 529 U.S. 576, 583,
120 S.Ct. 1655, 146 L.Ed.2d 621 (2000) (citation and
“ ‘The general rule, with regard to municipal officers, is punctuation omitted). Accordingly, we conclude that
that they have only such powers as are expressly granted MCL 168.759(5) does not implicitly permit the city clerk
by statute or by sovereign authority or those which are to mail absent voter ballot applications without having
necessarily to be implied from those granted.’ “ Presnell received a verbal or written request. [Taylor, supra at 94–
v. Wayne [Co] Bd. of Co. Rd. Comm'rs, 105 Mich.App. 96, 743 N.W.2d 571.]
362, 368, 306 N.W.2d 516 (1981), quoting 56 Am Jur 2d, *5 Because it is a published opinion, Taylor has precedential
Municipal Corporations, Counties, and Other Political value and we are bound by its holding. MCR 7.215(C)(2).
Subdivisions, § 276, p 327. Or as our Supreme Court Accordingly, the necessary outcome of this case is relatively
has stated, “[t]he extent of the authority of the people's straightforward. A county clerk, like a city clerk, has no
public agents is measured by the statute from which express statutory authority under the Michigan Election Law
they derive their authority, not by their own acts and to mail or otherwise distribute unsolicited absent voter ballot
assumption of authority.” Sittler v. Michigan College of applications. See Taylor, supra. The Michigan Election Law
Mining & Tech Bd. of Control, 333 Mich. 681, 687, 53 does not even expressly authorize a county clerk to mail
N.W.2d 681 (1952) (citations and punctuation omitted). such applications upon request or to keep the applications on
As such, “[p]ublic officers have and can exercise only hand in her office for interested voters. Instead, the county
such powers as are conferred on them by law....” Id. clerk's statutory role during the election process is as an
(citations and punctuation omitted). intermediary; she receives information from the Secretary of
State and distributes it to city, village, and township clerks.
Applying this rule to MCL 168.759, it is clear that the
See MCL 168.647, 653a, 709. The county clerk, in her role as
city clerk has no powers concerning the distribution of
a county election commissioner, prepares and distributes the
ballot applications other than those that are expressly
official ballots used in precincts around the county, including
granted in the statute. And the power to mail unsolicited
the official absent voter ballots. See MCL 168.668a, 689–
ballot applications to qualified voters is not expressly

691, 709, 713–714. In relation to the absent voter process, the
stated anywhere in this statute. Nor have appellants cited
county clerk has express authority to safeguard and distribute
any other statute that confers this power on the city clerk.
the absent voter ballots to local clerks in advance of an
As for whether the mass mailing of unsolicited ballot election, MCL 168.715–717, but no statute expressly allows a
applications is implicitly authorized by statute, we county clerk to deliver a ballot directly to a voter or to deliver
conclude that it is not. First, a power is necessarily absent voter ballot applications.
implied if it is essential to the exercise of authority that
is expressly granted. Conlin v. Scio Twp., 262 Mich.App. Accordingly, the county clerk lacks the implied authority
379, 385, 686 N.W.2d 16 (2004). The authority expressly to distribute absent voter ballot applications. As noted in
granted in MCL 168.759(5) is that the clerk must Taylor, supra at 94, 743 N.W.2d 571, a local government
have applications for absent voter ballots available officer possesses those powers “necessarily to be implied”
in the clerk's office at all times and that the clerk from those expressly granted. “Powers implied by general
“shall” provide an application to anyone upon verbal or delegations of authority must be ‘essential or indispensable
written request. The mass mailing of unsolicited ballot to the accomplishment of the objects and purposes of
applications is not essential to the clerk's either making the municipality.’ “ Lansing v. Edward Rose Realty, Inc.,
ballot applications available in the clerk's office or to 442 Mich. 626, 634, 502 N.W.2d 638 (1993), quoting 5
providing them upon request. Second, on the basis of McQuillin, Municipal Corporations (rev 3d ed), § 15.20,
the maxim expressio unius est exclusio alterius, (the p 102. None of the statutorily-defined duties described
expression of one thing is the exclusion of another), earlier relate to increasing voter turnout or making the
Feld[, supra at 362, 459 N.W.2d 279] (opinion by election process less onerous for voters. In fact, none of the

county clerk's statutorily-defined duties require direct contact absent voter ballot applications to qualified voters. Further,
with voters. Mailing absent voter ballot applications is not the Michigan Election Law does not permit county boards
related to, let alone essential to, a county clerk's duty to of commissioners to play any role in the election process.
distribute election information and materials to local clerks, Accordingly, the board lacked the authority to authorize the
to prepare and distribute official ballots to voting precincts, county clerk to take an action not allowed by statute.
or to distribute absent voter ballots to local clerks before
an election. Accordingly, a county clerk lacks both express Plaintiffs also argue that defendant violated the “purity of
and implied statutory authority to mail unsolicited ballot elections” clause. Because this Court's ruling in Taylor also
applications. controls with regard to this issue, we agree.
Further, the board cannot confer on the county clerk the The Michigan Supreme Court has interpreted the “purity of
authority to conduct such a mailing. Like the county clerk, elections” clause to embody two concepts: “first, that the
the board has only those powers expressly granted to it by constitutional authority to enact laws to preserve the purity
the constitution and by statute and those powers necessarily of elections resides in the Legislature; and second, ‘that
implied from the powers expressly granted. Conlin, supra at any law enacted by the Legislature which adversely affects
385, 686 N.W.2d 16. We must liberally construe the powers the purity of elections is constitutionally infirm.’ “ The
granted to local governments to include those powers “fairly phrase “purity of elections” does not have a single precise
implied and not prohibited by th[e] constitution.” Saginaw meaning. However, “it unmistakably requires ... fairness
Co. v. John Sexton Corp. of Michigan, 232 Mich.App. 202, and evenhandedness in the election laws of this state.”
221, 591 N.W.2d 52 (1998), quoting Const 1963, art 7, § 34. [McDonald v. Grand Traverse Co. Election Comm., 255
Mich.App. 674, 692–693, 662 N.W.2d 804 (2003) (internal
*6 The Legislature granted the following relevant powers to citations omitted).]
county boards of commissioners:
In Taylor, supra at 97, 743 N.W.2d 571, this Court found
(j) By majority vote of the members of the county board that the city clerk's mass mailing of absent voter ballot
of commissioners elected and serving, pass ordinances that applications violated the purity of elections clause.8 The
relate to county affairs and do not contravene the general Taylor Court reasoned that the city clerk had distributed
laws of this state or interfere with the local affairs of a “propaganda” in her official capacity and at the city's expense.
township, city, or village within the limits of the county, Id. There was no indication in Taylor, supra at 85, 743
and pursuant to [MCL 46.10b] provide suitable sanctions

N.W.2d 571, that the absent voter ballot applications were
for the violation of those ordinances.... designed in such a manner that they would have skewed
an applicant's vote one way or another. Therefore, the
*** Taylor Court's ruling appears to imply that even apparently
neutral applications sent by a city clerk in her official
(l) Represent the county and have the care and management
capacity constitute improper propaganda material. Although
of the property and business of the county if other
we recognize that we are bound by the Taylor Court's holding,
provisions are not made. [MCL 46.11]
we question whether the distribution of absent voter ballot
applications that apparently do not favor particular candidates
The board's resolution concerns voting in a statewide election
or political parties constitute “what amounts to propaganda
and, therefore, does not “relate to county affairs” or “the care
at the city's expense.” Taylor, supra at 97, 743 N.W.2d 571.
and management of the business of the county.” Furthermore,
Random House Webster's College Dictionary (1997) defines
the resolution contravenes MCL 168.759. A municipal
“propaganda” as “information or ideas methodically spread
government may not prohibit acts that are authorized by state
to promote or injure a cause, movement, nation, etc.” We fail
law or, conversely, authorize acts that are prohibited by state
to see how public mailings of apparently neutral absent voter
law. Rental Prop Owners Ass'n of Kent Co. v. Grand Rapids,
ballot applications methodically promote anything besides
455 Mich. 246, 262, 566 N.W.2d 514 (1997); Conlin, supra
the mere act of voting. However, we are compelled by
at 385, 686 N.W.2d 16; Frens Orchard, Inc. v. Dayton Twp.
Taylor to find that the neutrally-designed absent voter ballot
Bd., 253 Mich.App. 129, 136–137, 654 N.W.2d 346 (2002).
applications constitute propaganda and, therefore, violate the
As noted earlier, the Michigan Election Law neither expressly
nor impliedly authorizes county clerks to mail unsolicited purity of elections clause of our constitution.9

if an event has occurred that renders it impossible for the

court to grant relief. We will review a moot issue only if
*7 Regardless, we also conclude that the purity of elections
it is publicly significant and is likely to recur, yet is likely
has been violated in this case because the mailing of absent
voter ballot applications to only a select group of eligible to evade judicial review.” Attorney Gen. v. Michigan Pub.
absent voters undermines the fairness and evenhandedness of Service Comm., 269 Mich.App. 473, 485, 713 N.W.2d 290
the application of election laws in this state. Although MCL (2005). Defendant noted that several city clerks within the
168.758(1) lists six categories of voters eligible to vote by county automatically mail absent voter ballot applications to
absent voter ballot, the county clerk's mailing of absent voter voters over age 60 on a continual basis, and defendant will
ballot applications to only one of the six eligible groups means likely seek to mail unsolicited absent voter ballot applications
that the county clerk used public funds to make it easier for for future elections. As in this case, there is no guarantee that
one group (voters 60 and older) to vote without providing a potential future plaintiffs will have adequate notice to pursue
similar advantage to other categories of eligible absent voters. the matter to its conclusion before another election. Therefore,
Not only is this fundamentally unfair, but the county clerk's we agree with the trial court's conclusion that this issue is
actions hinder the evenhanded application of election laws capable of repetition yet evades review.
by failing to provide this benefit to all eligible absent voters.
Accordingly, the clerk's actions violate the purity of elections *8 We also note that the law of the case doctrine does not
clause and, therefore, are unconstitutional. preclude the trial court or this Court from reviewing the case
because this Court's earlier opinion regarding this case merely
Defendant contends that even if the mass mailing violated concerns the trial court's failure to grant plaintiffs' motion for
state law or the constitution, plaintiffs are not entitled to a preliminary injunction. In Fleming v. Macomb Co Clerk,
relief because they failed to show any injury or harm. unpublished opinion per curiam of the Court of Appeals,
However, plaintiffs are not required to show a substantial issued March 27, 2007 (Docket No. 273502), this Court
injury distinct from that suffered by the public in general in determined that plaintiffs' challenge based on the trial court's
order to establish standing in an election case. Helmkamp v. failure to award a preliminary injunction was moot because
Livonia City Council, 160 Mich.App. 442, 445, 408 N.W.2d the applications to vote by absent voter ballot in the 2006
470 (1987). “[T]he right to vote is an implicit fundamental general election had already been mailed and the election
political right that is preservative of all rights.” In re had already occurred. The Court recognized, however, that
plaintiffs' claims for permanent relief were still pending
Request for Advisory Opinion Regarding Constitutionality of
in the trial court at that time and that those claims could
2005 Pa. 71, , 479 Mich. 1, 16, 740 N.W.2d 444 (2007)

proceed to trial. Id. The Court found that the issue related to
(internal quotations omitted). Although the right to vote
is constitutionally protected, our Supreme Court has noted the preliminary injunction was not capable of repetition yet
evading review at that time because there was no indication
that the “equal right to vote is not absolute.”10 Id. (internal
that the county clerk intended to mail more absent voter ballot
quotations omitted). Instead, the Legislature must “preserve
the purity of elections” and “guard against abuses of the applications while the trial court proceedings were pending.11
elective franchise.” Const 1963, art 2, § 4. Defendant's actions
undermined the constitutional right of the public to participate Reversed. We direct the trial court to grant summary
in fair, evenhanded elections and, therefore, constituted an disposition in plaintiffs' favor and to grant plaintiffs' request
injury. Consequently, plaintiffs had standing to bring a cause for injunctive relief. We do not retain jurisdiction.
of action to remedy this injury. See Helmkamp, supra.
All Citations
We disagree with defendant's contention that plaintiffs'
challenge is moot and does not fall within the “capable of Not Reported in N.W.2d, 2008 WL 2553266
repetition yet evading review” exception. “An issue is moot
Footnotes
1 We wish to make clear that we fully support the right of citizens to vote, encourage qualified voters to exercise this right,
and do not discourage lawful means to increase voter turnout. However, for the reasons stated in this opinion, defendant's

actions are neither statutorily nor constitutionally authorized and, therefore, the trial court erred when it failed to enjoin
her from doing them.
2 Sabaugh, in her official capacity as Macomb County Clerk, is the defendant in this case. We will refer to her
interchangeably as “Sabaugh” and as “the county clerk” in this opinion.
3 Sabaugh informed the board that the local clerks in ten Macomb County communities automatically sent absent voter
ballot applications to registered voters over the age of 60, but the local clerks in the remaining 13 communities did not
automatically mail these applications.
4 To support her position, defendant notes that private groups, including the Democratic and Republican parties, send
absent voter ballot applications to their supporters. Yet she fails to note that the entities she identifies that mail absent voter
ballot applications are private entities. Conversely, defendant is a public official acting in her public capacity with public
money to send unsolicited absent voter ballot applications to only a portion of qualified absent voters in Macomb County.
In this appeal, we do not address the question whether private groups may mail absent voter ballot applications to their
members, and defendant's attempt to invite comparison between her actions and those of private groups is unavailing.
5 Presumably, these opponents of the county clerk's actions were concerned that defendant was using public money to
make voting easier for a demographic that was inclined to support her campaign for Secretary of State and the campaigns
of other members of her political party, but not facilitate voting for other demographics.
6 The parties stipulated that Sabaugh made this claim. However, the lower court record does not include any evidence
to support Sabaugh's claim.
7 The plaintiff, a candidate for Detroit City Council, alleged that the defendant city clerk planned to improperly mail 150,000
unsolicited applications. The trial court determined that the city clerk was precluded from mailing such unsolicited
applications and issued a preliminary injunction to prevent the mailings. Taylor, supra at 89, 743 N.W.2d 571. The city
clerk disregarded the preliminary injunction and mailed the applications. Id. at 89–90, 743 N.W.2d 571. As a result, the
city clerk was convicted of criminal contempt. Id. at 90, 743 N.W.2d 571. At the conclusion of the trial court proceedings,
the trial court entered a permanent injunction precluding the mailing of unsolicited absent voter ballot applications. Id.
at 93, 743 N.W.2d 571.
8 The Court's opinion regarding this violation of the purity of elections clause, in its entirety, is as follows:
This interpretation of MCL 168.759 is consistent with the sound public policy behind Michigan's election law, which,
as stated in the preamble, was enacted, in part, “to provide for the purity of elections; to guard against the abuse of the
elective franchise.” This is in keeping with the Michigan Constitution, which provides that “[t]he legislature shall enact
laws to preserve the purity of elections....” Const 1963, art 2, § 4. The Michigan Supreme Court has interpreted the
“purity of elections” clause to embody two concepts: “first, that the constitutional authority to enact laws to preserve

the purity of elections resides in the Legislature; and second, ‘that any law enacted by the Legislature which adversely
affects the purity of elections is constitutionally infirm.’ “ Socialist Workers Party v. Secretary of State, 412 Mich. 571,
596, 317 N.W.2d 1 (1982), quoting Wells v. Kent Co. Bd. of Election Comm'rs, 382 Mich. 112, 123, 168 N.W.2d 222
(1969). The phrase “purity of elections” “requires ... fairness and evenhandedness in the election laws of this state.”
Socialist Workers Party, supra at 598, 317 N.W.2d 1.
The city clerk, who is an elected official, has the role of neutral arbiter or referee. As a requirement of that office, the
city clerk must take and subscribe an oath or affirmation stating:
I do solemnly swear (or affirm) that I will support the Constitution of the United States and the constitution of this
state, and that I will faithfully discharge the duties of the office of [city clerk] according to the best of my ability. [Const
1963, art 11, § 1.]
To construe MCL 168.759 to permit Currie to distribute, in her official capacity, what amounts to propaganda at
the city's expense is certainly not within the scope of Michigan election laws or the Michigan Constitution. MCL
168.759(5) does not permit a city clerk to mail absent voter ballot applications without having received a verbal or
written request. Accordingly, we conclude that the trial court did not err in granting injunctive relief on this basis.
[Taylor, supra at 96–97, 743 N.W.2d 571.]
9 We also note that permitting absent voter ballot mailings to only a select category of eligible absent voters could encourage
a public official to target public funds to mail applications to voter groups likely to support her candidacy or her party's
candidates for office.
10 For example, a state can impose residency requirements on voters. Carrington v. Rash, 380 U.S. 89, 91, 85 S.Ct. 775,
13 L.Ed.2d 675 (1965).

11 Because we conclude that defendant's actions were neither constitutional nor statutorily authorized, we will not consider
appellant's contentions that the county clerk's decision to mail unsolicited absent voter ballot applications violated the
Equal Protection clause or resulted in vote dilution.
End of Document © 2022 Thomson Reuters. No claim to original U.S.

Government Works.

EXHIBIT 10
EXHIBIT 10
Sent: 1/21/2021 4:19:39 PM
To: Bourbonais, Lori (MDOS)[bourbona isl@michiga n.gov]; Ma I erma n, Mel issa (MDOS)[ma I erma nm@michigan.gov]
Subject: RE: MLive media inquiry, Non-government money in elections
Agreed on the general concern
From: Bourbonais, Lori(MDOS)<bourbonaisl@nnichigan.gov>

Sent: Thursday,January 21, 2021 2:59 PM
To: Malerman, Melissa(MDOS)<malermannn@nnichigan.gov>; Brater, Jonathan(MDOS)<Brated@nnichigan.gov>
Jonathan,
Melissa makes a good suggestion here, and it was not made in a vacuum. Groups tryingto get something on the ballot
have offered to covered the cost of the election in the past and we have always counseled against it.
From: Malernnan, Melissa(MDOS)<malermanm@michigan.gov>

To: Rol low,Jake(MDOS)<Rol lowl@michigan.gov>; MDOS-Press <SOSPress@michigan.gov>; Bourbonais, Lori(MDOS)
<bourbonaisl@michigan.gov>; Brater, Jonathan(MDOS)<Brated@michigan.gov>
I have no comments,either.
J ust as an FYI, it might be worthwhile to put some parameters around this in the future. You wouldn't want the
perception headache that could come from a real estate developerto pay for a special election on a rezoning ballot
q uestion ora corporation to underwrite the cost of an election on a local mil lage proposal. The for-profit/nonprofit
distinction might not be enough on its own to preventthis type of as one can easily form a nonprofitthat shields its
donors from disclosure. Just food forthought so that we don't get pinned down on sonnethingthat might be worth
revisiting before 2022.

From: Rol low,Jake(MDOS)<Rol lowi@michigan.gov>
To: MDOS-Press <SOSPress@michigan.gov>; Bourbonais, Lori(MDOS)<bourbonaisl@nnichigan.gov>; Malernnan, Melissa
(MDOS)<malermannn@nnichigan.gov>; Brater,Jonathan (MDOS)<Brater1@nnichigan.gov>
Please see my answers belowforyour review and edits:
From: Fergus Burns

Sent: Thursday,January 21, 2021 11:27 AM
To: Wimnner,Tracy(MDOS)<WinnmerT@michigan.gov>
Subject: MLive media inquiry, Non-government money in elections
Hello,
'
I m writing about what seems to be a new phenomenon in recent elections: the use of nongovernment money
by election officials for election operational costs.
EXHIBIT 10
Ryan - MDOS_0003928
I've spoken with numerous clerks about the Tech and Civic Life grants that went to more than 450 Michigan
counties, cities, townships and villages.
These grants were the source of some conspiracy theories. For instance, the Antrim County/SOS lawsuit refers
to the placement of so-called "Zucker-boxes" in heavily Democrat Michigan communities, including Flint,
Pontiac, Saginaw, Ann Arbor, Muskegon, Detroit and Lansing, using Tech and Civic Life grant funding.
It appears that the grants were much more widespread than only Democrat-majority cities, and while some
a bsentee ballot boxes were purchased with the funds, the monies were used much more broadly for
additional costs related to election safety during the pandemic.
'
I m looking at some of the issues surrounding specifically these grants but also more broadly the possible risks
or benefits that come into play with non-government money being used for election operations, which I
understand is unique.
I was hoping the SOS could offer some comment on the following:
• Is, in fact, this type of nonprofit spending on election operations new? Do you know when it first
started or if its happened in the past? Countless organizations spend money to inform voters every election
cycle. You will need to ask local jurisdictions if they have received such funds directly in the past, as they
would not necessarily inform MDOS.
• Are there any election rules or guidelines that bar use of non-government grant funds? Are there any
state guidelines for accepting, tracking or reporting use of nongovernment funds at the local level? Not at the
state level, and no.
• Since this is new, is the state considering creating and guidelines, rules or laws to guide local
acceptance of outside grand money for election operations? The Department of State is not.
• What if any role did the SOS/Bureau of Elections have regarding the Tech and Civic Life grants --did it

administer, promote or monitor use? The Department notified all clerks of the opportunity to apply for CTCL
funds.
• Does the SOS know how much money the state received through these grants? The Department of
State did not track CTCL grants.
• If the SOS has no role in monitoring the grants or what they're spent on, are there any concerns
surrounding that? See below.
• Does the SOS/Bureau of Elections support use of outside, charitable or nonprofit funds for elections? If
so, what are the conditions for that support? See below.
Many clerks said the grants were beneficial since they didn't have extra money to offset new costs associated
with safety requirements for operating an election during a pandemic. It was previously reported that the state
received $11.2 million through the CARES Actfor additional spending on elections in 2020.
• Did any of that CARES money get distributed at the local level? If so, how much and how was it
distributed? If not, how was it spent? Is there any detailed record of the spending that can be shared with
me? CARES and NAVA funds were used to cover costs for the 2020 election cycle as follows:
o $2 million to reimburse local jurisdictions for ballot return postage
O $1.5 million for local jurisdictions to purchase USPS designed ballot envelopes
EXHIBIT 10
Ryan - MDOS_0003929
0 $3 million for local jurisdictions to purchase drop boxes, automatic letter openers,and other
equipment.
0 $2.5 million matching funds for local jurisdictions to purchase additional vote-tabulation
machines(including high speed).
0 $2 million for PPE for local jurisdictions - masks,gloves,face shields, disinfectant wipes, hand
sanitizer
0 $6.5 million for voter education (including mailings of absentee applications and instructions,
and reminder postcard)
• Was the CARES Act elections grant the only additional election operations money the state received for
2020, or were there other additional grants or other funding outside of what was originally budgeted? If so
how much extra? Only CARES.
Generally, do you think acceptance of outside money impacts or can impact the credibility of the election
process and are there any plans to address this issue down the road?
Statementfrom Jake Rollow,MODS Spokesperson:"Funding local clerk offices bolsters their ability to inform voters
and carry out secure,safe and accurate elections that affirm public confidence. Election offices are often under-
resourced at the local level, have not been supported by the state legislature,and were eagerfor additional funding
in 2020, when they were implementing new voting rights amidst a global pandemic."
I appreciate any help, information or comment.
I am working on a story that I'm trying to finish by Friday evening.
Thank you,
Gus Burns
Wive Media Group
108 S Washington Square

Lansing, MI 48933
989.372.2495
follow me on Twitter ffausburns
EXHIBIT 10
Ryan - MDOS_0003930

2020 Zuckbuck Lawsuit

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STATE OF MICHIGAN

IN THE COURT OF CLAIMS

DAN RYAN, et al.,

Plaintiffs, Case No: 20-000198-MZ

PLAINTIFFS’ 02/14/2022 RESPONSE TO DEFENDANT’S

Mark F. (Thor) Hearne, II (P40231) Heather S. Meingast (P55439)

Document received by the MI Court of Claims.

Charles R. Spies (P83270

INDEX OF AUTHORITIES ..................................................................................................... iii-vi

Document received by the MI Court of Claims.

Apsey v Mem’l Hosp,

Attorney Gen v PowerPick Players’ Club of Michigan, LLC,

Castner v Grosse Pointe Park,

Citizens Protecting Michigan’s Constitution v Secretary of State,

Dalley v Dykema Gossett,

Davis v Secretary of State,

Election Integrity Fund, et al v City of Lansing and City of Flint,

Document received by the MI Court of Claims.

El-Khalil v Oakwood Healthcare, Inc,

Ensink v Mecosta Co Gen Hosp,

Fleming v Macomb Co Clerk,

Iron Co v Sundberg, Carlson & Assoc, Inc,

Kaplan v City of Huntington Woods,

Killeen v Wayne Co Rd Comm,

Lansing Schs Ed Ass’n v Lansing Bd of Ed,

League of Women Voters of Mich v Secretary of State,

Mays v Governor of Michigan,

McManus v City of Petoskey,

Mich Ass’n of Home Builders v City of Troy,

Document received by the MI Court of Claims.

Porter v City of Royal Oak,

Sinas v City of Lansing,

Skinner v Square D Co,

Skutt v City of Grand Rapids,

MCL 166.669 ................................................................................................................................17

MCL 168.21 ....................................................................................................................................7

MCL 168.24j .....................................................................................................................18, 19, 20

MCL 168.31 ....................................................................................................................................7

MCL 168.31(1)(a) ...................................................................................................................18, 20

MCL 168.31(1)(b) ...................................................................................................................18, 20

MCL 168.665 ..........................................................................................................................18, 19

MCL 168.666 ..........................................................................................................................17, 18

MCL 168.667 ................................................................................................................................17

MCL 168.669 ..........................................................................................................................17, 18

Document received by the MI Court of Claims.

MCL 168.761d ........................................................................................................................19, 20

MCR 2.116(C)(8) ............................................................................................................................9

MCR 2.116(C)(10) ..........................................................................................................................2

MCR 2.118 ......................................................................................................................................2

MCR 2.605 ......................................................................................................................................7

MCR 2.605(A)(l) .............................................................................................................................6

Const 1963, art 7, § 26...................................................................................................................15

Const 1963, art 9, § 18...................................................................................................................15

Document received by the MI Court of Claims.

Mark Zuckerberg, the billionaire founder of Facebook, put hundreds of millions of

Document received by the MI Court of Claims.

person’s vote over that of another.” 531 US 98, 104 (2000).

and conduct Michigan elections in a manner directed by a private entity.

I. Secretary Benson’s motion for summary disposition should be denied because

Document received by the MI Court of Claims.

A motion made under MCR 2.116(C)(10) is premature if discovery is not completed.

evidence indicates that an amendment would not be justified. MCR 2.116(I)(5).

therefore, is essential to the Court’s determination of the claims before it.