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prior to commencement of voting; Subsection 2 being complaint against
verification and recording of ballot papers at polling places prior to the
commencement of voting, evidencing the starting and ending serial numbers
of ballot papers; Subsection 4 being complaint at Polling Place #1, Precinct
Code #24180 in Margibi County; Subsection S being complaint against
activities at District #4, Nimba County; Subsection 7 being complaint against
activities of two young men (not staff of the NEC), unaccompanied by security
officers, carrying ballot boxes on their heads and wading in it body of water;
Subsection 8 being complaint against activities of individuals, unaccompanied
by security officers, in a canoe carrying ballot papers; Subsection 9 being
complaint against activities at District #4, Polling Center #09085, Polling Place
#1, Klein Town, Grand Bassa County; Subsection 10 being complaint against
activities at Polling Precinct #09039, Polling Place #2, Kennedy Town, Grand
Bassa County; Subsection 11 being complaint against activities at District #13,
Montserrado County; Subsection 12 being complaint against the high
percentage of invalid votes (11,400), constituting approximately 5.4% of all
votes casts; and Subsection 14 being complaint against the quarantine of 14
ballot boxes by the NEC, which were not accounted for by the time that the
NEC announced the results of the elections. Intervenors confirm and affirm
the allegations of fact contained in Pail III of the Complaint aforesaid and the
principles of law and regulations thereon relied in support of these averments
of fact.
12. Intervenors say that the law is that the NEC shall maintain a register of
qualified voters. New Elections Low, Section 2.9(k). "I he law also is that the
NEC shall carry out voter registration of eligible citizens and carry out voter
registration update periodically. New Elections Law, Section 2.9(k). Then the
law requires that general registration roll for each registration center must be
kept for public inspection at the office of the magistrate of elections and must
be kept at such other public places for public inspection. New Elections Law,
Section 3.6. Intervenors acknowledge that the NEC did conduct voter register
exercise but Intervenors complain that the Final Registration Roll (FRR) was
never published by the NEC contrary to law; and for which failure to publish,
international election observers and political parties complained to the NEC,
but the NEC never published the aforesaid Final Registration Roll. Intervenors
give notice that at the hearing, if necessary, they shall present newspaper
publications of complaints of international observers and political parties to
the NEC to publish the FRR.
13. Intervenors say that the provisions of law relied upon and cited in Count
Twelve (12) above are even better articulated by regulations of the NEC by the
requirement that the NEC shall certify the voter registration roll and cause it
to be to be printed and bound separately in respect of each polling place and
that the NEC shall publish the certified voter registration roll. Voter
Registration Regulations, Sections 29(1) & 30. Intervenors submit that the
failure of the NEC to complete the Final Registration Roll and publish it is a
violation of its own regulation and undermines free, fair and transparent
elections. And for this reason, Intervenors pray that before a run-off election
is held (if such run-off election is ever held) and before any elections are held
hereafter the NEC should publish the Final Registration Roll (ERR) and allow
time for challenge to it.