p.
There was testimony explaining that the limit to six collected ballots does not align
with how many of Native families are structured. Stip. Ex.'s 9 at 15, 25-26;
see
a/so Stip. Ex. I 1 at 47.
q.
Following an exchange about BIPA's impact on individuals 40 miles away from a
post office, who have no access to public transportation and only unreliable roads,
and whether BIPA puts an additional burden onto Native American community
members that
is.
beyond their control, Senator Olszewski stated that the
disproportionately long distances Native Americans must travel to vote does not
hinder them. Stip. Ex. 9 at 36-37
r.
.
bill.
There is also no basis for the six-ballot limit in the
When Senator Olszewski
was queried about the arbihary cap of six ballots that may be collected, he justified
the cap by stating that he had performed a small survey sample. Stip. Ex. 11 at 29;
see also 09110/20
s.
Trial Tr. (Hood) at 606:23-607:15,610:15-17.
Defendant Mangan testified that he did not know how the six-ballot limit would
protect election integrity. Mangan Dep. Tr. 49:16-79;49:22.
t.
Katie Beall, a former employee with the Office of the Commissioner of Political
Practices, testified that she has no idea why
it is the number six, not
a hundred and
not two, and she does not know what data informed that. Beall Dep. Tr. 164:1222.
u.
The Attomey General's Ofhce representative testified that he did not know why
the
v.
limit was set at six ballots. AG Dep. Tr. 69:1-3.
The Montana legislature passed SB-352, and
Stapleton's office on May 3,2017.
27
it
was filed with Defendant