w. BIPA went to a vote ofthe public as Legislative Referendum 129 ('LR-129"). x. In November 2018, Montana voters went to the polls to vote on LR-l29. y. The ballot summary of the measure stated that caregivers, family members, household members, and acquaintances were exempt from the law and would have to sign a registry, but not that individuals would be limited to collecting just six ballots. The summary also failed to define the categories of individuals who would be exempt from the law. The ballot summary was written by the Attomey General. Stip. Ex. 18. z. The complete language on the November 201 8 ballot was; The 2017 Legislature has submitted this proposal for a vote. LR-129 prohibits a person from collecting another voter's ballot, with certain exceptions. The prohibition would not apply to an election official, postal worker, caregiver, family member, household member, or an acquaintance. Any such individuals that are caregivers, family members, household members or acquaintances would be required to sign a registry at the polling place or the election administrator's office when delivering the ballot and are required to provide the following information: the individual's name, address, and phone number; the voter's name and address; and the individual's relationship to the voter. An individual who violates any provision within LR-129 could be fined $500 for each ballot unlawfully collected. [] YES on Legislative Referendum LR-129 [] NO on Legislative Referendum LR-129. Stip. Ex. 18. aa. Voter fraud has historically been rare, ifnot nonexistent in Montana. See Mangan Dep. Tr.3l:9-21 (only one instance of alleged voter fraud); Cook Dep. Tr.20:620:20,21:3 -21:121,25:21-26:6 (aware ofno instances ofvoter fraud );09110/20 Trial Tr. (Hood) at 639:25-640:5; see also 09109120 (McCool) at 372:7-373:l; Pl. Ex. 23 at 11. 28