Hofeller FL Hofeller Affidavit 3 8 2013

Sep. 23 2019 — 5:46p.m.


VIRGINIA: IN THE CIRCUIT COURT FOR THE CITY OF ALEXANDRIA RENE ROMO, an individual; BENJAMIN WEAVER, an individual; Et al., Case No: M012001573 Plaintiffs, Doc. No: 2165084 V. KEN DETZN ER, in his of?cial capacity as Florida Secretary of State, and BONDI, in her official capacity as, Attorney General, Defendants. THE LEAGUE OF WOMEN VOTERS OF THE NATIONAL COUNCIL OF LA RAZA, et Plaintiffs, V. KEN DETZNER, in his of?cial capacity as Florida Secretary of State, and BONDI, in her of?cial capacity as, Attorney General, Defendants. AFFIDAVIT OF THOMAS BROOKS HOFELLER

Thomas Brooks Hofeller states the following under oathmajority, am competent to make this af?davit, and, except where speci?cally stated otherwise, have personal knowledge of the matters stated herein. I reside at Alexandria, Virginia, 22307. Although my postal zip code is designated as an Alexandria postal zip code, my residence is actually two miles south of Alexandria City and located in Fairfax County, Virginia (a map showing my residence is attached hereto). 2. I hold a from Claremont Graduate University, where my major ?elds of study were American political philosophy, urban studies and American politics. I hold a BA. from Claremont McKenna College with a major in political science. 3. I have given testimony as an expert witness in a number of important redistricting cases including, but not limited to, Gingles v. Edmisten, 590 F. Supp. 345 (N.D.N.C. 1984), in part and rev'd in part Thomburg v. Gingles 478 US. 30 (1986); State of Mississippi v. United States, 490 F. Supp. 569 (D.C.D.C. 1979); Shaw v. Hunt, 92-202-CIV-5-BR, US. District Court for the Eastern District of North Carolina, Raleigh Division (1993-4); Ketchum v. Bvrne, 740 F.2d 1398, cert. denied City Council of Chicago v. Ketchum, 471 US. 135 (1985), on remand, Ketchum v. City of Chicago 630 F. Supp. 551 (ND. 111. 1985); and Arizonans for Fair Representation v. Symington, CIV 92-0256, US. District Court Arizona (1992), a??d mem. sub nom. Arizona Community Forum v. Svmington, 506 US. 969 (1992). 4. I am currently engaged by the Republican National Committee (RNC) as an expert witness operating at the direction of RNC counsel. I am not engaged by any party in the Florida litigation contained in the caption of this case, nor am I testifying or assisting any party in this Florida litigation at this time.

5. At 2:00 PM on Friday, September 28, at the RNC, I received an unsolicited phone call from Gerald Hebert asking me if I ?had been involved in Florida redistricting?. I asked him what he meant by ?involved?. He then explained that he had been ?tasked? to ?nd people who were involved in Florida redistricting for the ongoing redistricting litigation in that state. When I hesitated, he said that ?you don?t have to answer, if you don?t want to.? I said that I did not want to comment further and that I would contact counsel on this issue. We exchanged a few pleasantries and then terminated the conversation. 6. To the best of my recollection, I have not been in contact, or exchanged data or maps, with any Florida legislators or members of their staffs, concerning Florida redistricting, since the release of the Census Bureau?s 2010 Decennial Redistricting Data File in early 2011. In early 2010, I attended a meeting at which I met Senator Mike Haridopolos. We did not discuss any matter of signi?cance speci?c to Florida. I have not been in contact with him since that meeting. DATED on March 8th, 2013. 2M 44/4,. Thomas Brooks Hofellef/ SUBSCRIBED AND SWORN TO before me on March 8th, 2013, by Thomas Brooks Hofeller, a person either known to me or who identi?ed himself as Thomas Brooks Hofeller by adequate means of identi?cation. Notary Public .- gt MY COMMISSION expires on the 31St day of October, 2013 All; gift/? j" ?if? . (Immnwull?ln h/ ?mime

a - Mozi; a Firefox fairfaxccunty.goi.r This PDF document might not be displayed correctly. Qpen With Different Viewer

Fetching more

Filters SVG