23 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.

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