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13. Intervenors also say that in the absence of the publication of the ERR in
keeping with law, free, fair and transparent elections could not have been held
on October 10, 2017; but more than this, the tact is that the NEC could not
publish and did not publish the ERR because it discovered very late that
records for thousands and thousands of voters had been misplaced. That is, a
voter was registered at one center and his records were at a completely
different center, often times at a center in a completely different county. And
because of that thousands and thousands of voters were denied voting even
though they had valid voter registration cards and even though it is provided
by regulation that when a person has a valid voter registration card but his/her
records can't be found at the place where he/she registered, that person may
vote if two (2) other persons who have voter registration cards at the same
precinct and have already voted certify that they know the person whose
name is not on the voter roll at the precinct or polling place. NEC Regulation
on Polling and Counting, Art. 3(2). The presiding officers and polling staff
simply rejected those who had valid registration cards but whose names were
not on the voter rolls at the precinct or polling places where they registered;
they selectively allowed certain other persons similarly situated to vote. This
conduct obviously disenfranchised thousands and thousands of voters and
denied to them their constitutional right to vote in the October 10, 2017
elections.
14. At many polling places, to perpetuate fraud, the presiding officers and
polling staff created addenda to the voter roll on which they included the
names of persons who allegedly had voter's card but whose names were not
on the voter roll at the precincts or polling places where they registered to
vote. Copies of these addenda were not made available to poll observers for
political parties and independent candidates and as such, presiding officers
and polling staff were able to fraudulently list names and voter registration
card information on these addenda and allowed voting for persons who had
not registered to vote or who had registered to vote and did not appear to
vote.
15. That the facts alleged in Counts Thirteen (13) and Fourteen (14) above are
responsible for the high number (almost one-third) of registered voters who
did not vote in the October 10, 2017 J elections and these anomalies
undermined free, fair and transparent elections. And for these reasons,
Intervenors demand that before the run-off election is conducted (if such runoff election is ever conducted) and before any new elections are conducted in
Liberia, the ERR should be published as provided by law and regulation.
16. Intervenors attach hereto as Exhibit "UP-2" the record (4 pages) for voter
registration for Nimba County, which the NEC used for elections on October
12, 2017, which shows discrepancies between the number of actual registered
voters and the number of voters the NEC subsequently deemed to have
registered. Intervenors also attach hereto as Exhibit "EJP-3" the record (3
pages) for voter registration for Gbarpolu County, which the NEC used for
elections on October 12, 2017, which shows discrepancies between the
number of actual registered voters and the number of voters the NEC
subsequently deemed to have registered. Similar discrepancies are found in
voter registration records for all the counties. And without the publication of
the Final Registration Roll and the opportunity to challenge the information
contained therein, the voter registration roll used by the NEC was prone to