Declaration of Erick G. Kaardal — Pa. Voters Alliance v. Centre County (M.D. Pa.)

Record facts

U.S. District Court for the Middle District of Pennsylvania · No. 4:20-cv-01761-MWB · Doc. 5-2 · 2020-09-28 · Docket on CourtListener

Full text

UNITED STATES DISTRICT COURT 
MIDDLE DISTRICT OF PENNSYLVANIA 
 
 
Pennsylvania Voters Alliance, Stephanie 
Borowicz, Kristine Eng, Theodore A. 
Dannerth, Eric Kroner, Eric Nelson, Daryl 
Metcalfe, Dawn Wetzel Keefer, Russ 
Diamond, Chris Dush, Jim Gregory, Francis 
Ryan, Michael Harvey, David Torres, Dasha 
Pruett,  
 
 
 
 
Plaintiffs, 
vs. 
 
Centre County, Delaware County, and the 
City of Philadelphia, 
 
 
 
 
Defendant. 
 
 
Court File No.  
 
 
 
DECLARATION OF 
ERICK G. KAARDAL 
 
I, Erick G. Kaardal, being duly sworn, declares as follows: 
1. 
I have personal knowledge of the following. 
2. 
I am an attorney for the Plaintiffs Pennsylvania Voters Alliance, Stephanie 
Borowicz, Kristine Eng, Theodore A. Dannerth, Eric Nelson, Daryl Metcalfe, Dawn Wetzel 
Keefer, Rus Diamond, Chris Dush, Jim Gregory, Francis Ryan, Michael Harvey, David 
Torres, and Dasha Pruett  
3. 
Attached as Exhibit A is a copy of the grants page from the website of the 
Center for Tech and Civic Life.  
4. 
Attached as Exhibit B is a copy of a Chicago NPR story “‘Not Plain A’: 
Charities Are Stepping Up To Pay For 2020 Elections,” dated September 18, 2020.  
5. 
Attached as Exhibit C is the August 7, 2020 grant request from the City of 
Philadelphia to the Center for Tech and Civic Life and the August 21, 2020 grant approval 
Case 4:20-cv-01761-MWB   Document 5-2   Filed 09/28/20   Page 1 of 3

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from Center for Tech and Civic Life Executive Director Tiana Epps-Johnson for over $10 
million.   
6. 
Attached as Exhibit D is a copy of the April 10, 2020 Pennsylvania Secretary 
of State certification letter to the United States Election Assistance Commission regarding a 
request for $14.3 million under the CARES Act through the Help America Vote Act.  
7. 
Attached as Exhibit E is a copy of the July 18, 2020 Narrative Report from 
the Pennsylvania Department of State which describes how the Department spend their 
CARES Act grant through the Help America Vote Act.  
8. 
Attached as Exhibit F is a copy of a July 16, 2020 Election Assistance 
Commission – Election Security Grant Funding Chart indicating Pennsylvania’s $28.6 
million fiscal allocation and $3.68 million match in 2018 and 2020. 
9. 
Attached as Exhibit G is a copy of a July 22, 2020 Election Assistance 
Commission – CARES Act Funding Chart indicating Pennsylvania’s $14.2 million allocation 
and $2.8 million match. 
10. 
Attached as Exhibit H is a copy of the Pennsylvania Department of State 
distribution by County of their 2020 CARES Act grant fund through the Help American 
Vote Act. https://www.dos.pa.gov/VotingElections/Pages/2020-Federal-Grants.aspx. 
11. 
Attached as Exhibit I is a copy of a Los Angeles Times story, “When will we 
know if Biden or Trump won? It could depend on absentee ballot rules in these states.” 
Accessed 9/25/2020. 
I declare under penalty of perjury under the laws of the United States of America that 
the foregoing is true and correct.  
Case 4:20-cv-01761-MWB   Document 5-2   Filed 09/28/20   Page 2 of 3

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Dated: September 25, 2020  
 
 
  /s/Erick G. Kaardal 
 
 
 
 
 
 
 
 
 
Erick G. Kaardal 
 
Hennepin County 
State of Minnesota 
Case 4:20-cv-01761-MWB   Document 5-2   Filed 09/28/20   Page 3 of 3

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