24 13. Intervenors also say that in the absence of the publication of the ERR in keeping with law, free, fair and transparent elections could not have been held on October 10, 2017; but more than this, the tact is that the NEC could not publish and did not publish the ERR because it discovered very late that records for thousands and thousands of voters had been misplaced. That is, a voter was registered at one center and his records were at a completely different center, often times at a center in a completely different county. And because of that thousands and thousands of voters were denied voting even though they had valid voter registration cards and even though it is provided by regulation that when a person has a valid voter registration card but his/her records can't be found at the place where he/she registered, that person may vote if two (2) other persons who have voter registration cards at the same precinct and have already voted certify that they know the person whose name is not on the voter roll at the precinct or polling place. NEC Regulation on Polling and Counting, Art. 3(2). The presiding officers and polling staff simply rejected those who had valid registration cards but whose names were not on the voter rolls at the precinct or polling places where they registered; they selectively allowed certain other persons similarly situated to vote. This conduct obviously disenfranchised thousands and thousands of voters and denied to them their constitutional right to vote in the October 10, 2017 elections. 14. At many polling places, to perpetuate fraud, the presiding officers and polling staff created addenda to the voter roll on which they included the names of persons who allegedly had voter's card but whose names were not on the voter roll at the precincts or polling places where they registered to vote. Copies of these addenda were not made available to poll observers for political parties and independent candidates and as such, presiding officers and polling staff were able to fraudulently list names and voter registration card information on these addenda and allowed voting for persons who had not registered to vote or who had registered to vote and did not appear to vote. 15. That the facts alleged in Counts Thirteen (13) and Fourteen (14) above are responsible for the high number (almost one-third) of registered voters who did not vote in the October 10, 2017 J elections and these anomalies undermined free, fair and transparent elections. And for these reasons, Intervenors demand that before the run-off election is conducted (if such runoff election is ever conducted) and before any new elections are conducted in Liberia, the ERR should be published as provided by law and regulation. 16. Intervenors attach hereto as Exhibit "UP-2" the record (4 pages) for voter registration for Nimba County, which the NEC used for elections on October 12, 2017, which shows discrepancies between the number of actual registered voters and the number of voters the NEC subsequently deemed to have registered. Intervenors also attach hereto as Exhibit "EJP-3" the record (3 pages) for voter registration for Gbarpolu County, which the NEC used for elections on October 12, 2017, which shows discrepancies between the number of actual registered voters and the number of voters the NEC subsequently deemed to have registered. Similar discrepancies are found in voter registration records for all the counties. And without the publication of the Final Registration Roll and the opportunity to challenge the information contained therein, the voter registration roll used by the NEC was prone to

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