Documents
Hofeller FL Hofeller Affidavit 3 8 2013
Sep. 23, 2019
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
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.
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
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
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