1411 K Street NW, Suite 1400 Washington, DC 20005 tel: 202-736-2200 fax: 202-736-2222

October 14, 2016 Mr. T. Christian Herren, Jr. Chief, Voting Section Civil Rights Division U.S. Department of Justice Room 7524 – NWB 1800 G St., NW Washington, DC 20006 Re: Voting Discrimination Complaint in Tarrant County, Texas Dear Mr. Herren: This letter is being submitted to you by the non-partisan, non-profit Campaign Legal Center. The purpose of this letter is to alert you that efforts are underway in Tarrant County, Texas that appear designed to disrupt and suppress voter participation of minority voters in the 2016 General Election. I believe these developments warrant the assignment of federal poll monitors by the Department of Justice to monitor early voting and Election Day polling locations in Tarrant County to assure that the voting rights of all citizens are protected. Further, we are concerned that Tarrant County election officials are also providing incorrect information to voters regarding the state’s Voter ID law. The vote suppression efforts being made are cloaked in partisan rhetoric but are clearly targeted at Hispanic and African American voters in Tarrant County. You’ll find attached a website posting from the Tarrant County Republican Party that was emailed as a link to Republican Party activists with the subject heading, “ALERT *** EMERGENCY VOTER FRAUD INFORMATION INSIDE *** ALERT”. It uses inflammatory language to raise irrational fears such as “…buy, steal, and cheat their way to victory…” The posting seeks to recruit poll watchers and emphasizes, “We especially need poll watchers in Democrat-controlled polling locations.” Virtually every precinct in Tarrant County that is

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“Democrat-controlled” is a majority-minority precinct. Conversely, virtually every Anglo majority precinct in Tarrant County will have Republican poll officials assigned. Republican Party officials in Tarrant County are aware that “Democrat-controlled” precincts have predominately African American and/or Hispanic populations. In prior elections, they have attempted to justify targeting minority voters using partisan or geographic descriptions to hide their intentions. Attached to this letter are news accounts from 1998 published in the Dallas Morning News and the Fort Worth Star-Telegram which detail Republican efforts to suppress minority voting rights in Tarrant County and justify their actions using partisan and geographic terms in an effort to hide their racial terms. Finally, I am concerned that misinformation is being provided to Tarrant County voters regarding the Texas Voter ID law by county election administrators. I have also attached an email sent by Tarrant County Voter Registration Manager Patricia Benavides which provides incomplete and incorrect information to voters regarding the Texas Voter ID law and would likely lead to voters casting provisional rather than regular ballots. The communication suggests that a photo ID is required and that those presenting non-photo ID will be required to cast a provisional ballot. That is clearly wrong and contrary to the interim remedial order entered by the federal court in Corpus Christi. Given the concerns set forth above, I request that federal monitors be sent to Tarrant County to prevent the likely disruption and suppression of voting by minority citizens and that appropriate actions be taken to inform Tarrant County election officials of the proper enforcement of the Texas Voter ID law in the upcoming election. Sincerely, /s/ J. Gerald Hebert J. Gerald Hebert Director, Voting Rights & Redistricting Project Cc The Honorable Justin Levitt Deputy Assistant Attorney General Civil Rights Division U.S. Department of Justice

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Election Judges & Alternate Judges With less than a month left until the election, we need all hands-on deck! History has repeatedly shown that Democrats will do everything they can to buy, steal, and cheat their way to victory at the ballot box. It is up to us to ensure that every vote here in Tarrant County is PROTECTED and LEGAL. If you are an Appointed Election Judge or Alternate Judge, please let us know if you are not going to be able to work your Polling Location IMMEDIATELY. Tarrant County Elections has been calling Judges right now to confirm workers. If you decline an appointment and do not resign, it is highly likely the Democrats will be able to take control of that polling location - even if it is a Republican precinct. It is very important if you are an Election Judge or Alternate Judge and cannot work the election, that you contact us immediately at (817) 595 -0303 or email [email protected]. We will also be looking for Poll Watchers for Early Voting location sites and Election Day polling locations. We especially need poll watchers in Democrat-controlled polling locations. Voter ID is still required in Texas. We want to make sure OUR VOTER ID LAW IS FOLLOWED. If you, or anyone you know, are interested, please let us know as soon as possible. We will be hosting training sessions very soon, so be on the lookout. To serve as an Election Judge on November 8th, please contact us immediately!

Link: http://us1.campaignarchive1.com/?u=f95c00a9cfe53f1fcde627337&id=947ba0f670&e=4893e2aa1c

ATTACHMENT 1

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ATTACHMENT 2 (attached news articles)

5 ---------- Forwarded message ---------From: Patricia V. Benavides Date: Wed, Oct 12, 2016 at 2:11 PM Subject: Provisional Votes To:

Voters are required to show photo identification at time of voting. Information on website is just to inform everyone that if they go to vote and forgot to bring their acceptable form of approved photo ID (as currently required) to the polling place and /or left it, for example at home or in their car. The voter can still vote however, they will need to vote a Provisional Ballot. In order to have the provisional ballot counted the voter will be required to visit the voter registrar’s office within six calendar days of the date of the election to either present one of the acceptable forms of photo ID or submit one of the temporary affidavits religious objection or natural disaster in the presence of the county voter registrar while attesting to the fact he or she does not have any of the required photo IDs.

Patricia Benavides Tarrant County Voter Registration Manager P: 817-831-6454 F: 817-831-6475 [email protected]

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