xi.
Ifa
person dropping
or
appears
offballots on behalfofanother refuses to sign the registry
not to meet the collection eligibility requirements,
election
administrators have been instructed that they must report the violation to
Defendant Mangan's office. Pl. Ex. 33.
xii.
Since BIPA has been in effect, some county election administrators receive
incomplete registry forms, receive BIPA forms when not necessary, and receive
mail ballots with BIPA forms in them. See Mangan Dep. Tr. 81:7 -83:7; 86:10-
d.
Potentialviolations.
i.
Election administrators have been told that if they do not have the individual
violator's name, they should record as much information as possible (height,
weight, hair color, vehicle information, etc.). Election administrators can send
complaints of BIPA violations directly to Defendaat Mangan or to the county
attomeys. See, e.g., Mangan Dep. Tr. 135:13-139:5.
ii. Additionally, individual citizens may file a complaint with Defendant
Mangan's office if they believe a ballot collector has violated BIPA. Pl. Ex. 33
iii.
Defendant Mangan and county attomeys each have the authority to investigate
violations of the law. See Mont. Code Ann. $$ 13-37-111(1); 13-37-125.
iv.
The COPP has no written policies goveming when the office would keep an
investigation of BIPA in its office or when
it would
be tumed over county
a$omeys. Mangan Dep. Tr. 73:20-14:1; 146:7-12; Cook Dep. Tr. 18:4-13.
v.
The COPP has provided no training to county attomeys or local enforcement
goveming BIPA violations. Cook Dep Tr. 78:ll-79:2.
JJ