v. In Indian Country, close members of the community are sometimes considered family, despite not being directly related through blood, marriage, adoption, or legal guardianship. This is particularly true for children they raise for others. 09/08120 Trial Tr. (Fyant) at 107:8-108:13; 09108/20 Trial Tr. (Cuts the Rope) at 150:17-151:22. h. Because BIPA fails to adequately define family members and acquaintances, CSKT members, for example, are likely to be confused about who is restricted from picking up and dropping off ballots. The definition of family by CSKT members is more expansive than the nuclear family cofirmon in non-Native households and can include distant relatives and community members that may or may not be directly related by blood or marriage. 09/08120 Trial Tr. (Fyant) at 107:8- 108:13. i. Ard while the sponsor of the bill indicated that voters should simply judgment in defrning their family members, more exercise good is required as improperly identiffing a person as a family member on the registry form could subject the ballot collector to a perjury charge. Stip. Ex.'s 9, 11, 20. j. Defendants' interpretations have provided little guidance to mitigate the problems with BIPA. k. Defendant Mangan's office similarly has failed to provide additional guidance on what is sufficient to qualifr an individual as an "acquaintance," or whether the term "family member" includes family relationships in Indian country. Mangan Dep. Tr.66:7-18; Pl. Ex.'s 14, 17. l. All of the prohibited categories of individuals members, household members or in BIPA acquaintances 38 - - caregivers, family could still tamper with a

Select target paragraph3