Case 3:13-cv REP-LO-AD Document Filed 09/18/15 Page 1 of 6 PageID# 5505 EXHIBIT V

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Transcription:

Case 3:13-cv-00678-REP-LO-D Document 232-22 Filed 0/18/15 Page 1 of 6 PageID# 5505 EXHIBIT V

Case 3:13-cv-00678-REP-LO-D Document 232-22 Filed 0/18/15 Page 2 of 6 PageID# 5506 IN THE UNITED STTES DISTRICT COURT Page 1 FOR THE ESTERN DISTRICT OF VIRGINI RICHMOND DIVISION DWN CURRY PGE, et al. Plaintiffs, vs. VIRGINI STTE BORD OF ELECTIONS, et al. Civil ction : 3:13-cv-678 Defendants DEPOSITION OF GLORI PERSON HUBLLH March 31, 2014 1:40 p.m. Taken at: OFFICE OF THE TTORNEY GENERL 00 East Main Street Richmond, Virginia 2321 REPORTED BY: HELEN B. YRBROUGH, RPR, CCR, CLR Registered Professional Reporters 3751 Westerre Parkway, Suite D-1 Richmond, Virginia 23233 (804)35-184

Case 3:13-cv-00678-REP-LO-D Document 232-22 Filed 0/18/15 Page 3 of 6 PageID# 5507 1 calls for a legal conclusion. Page 52 2 3 Not fully, no. Have you ever heard the term or the phrase 4 "ability to elect candidates of choice"? 5 6 I haven t heard that, no. Have you ever heard the phrase, the term, 7 "retrogression"? 8 re you familiar with the process that 10 Virginia followed in 2012 for obtaining Justice 11 Department preclearance or approval for its district 12 lines? 13 MR. ROCHE: Objection to the extent it 14 calls for a legal conclusion. 15 16 17 18 (Person-Huballah Deposition Exhibit 1 is marked.) 1 2o I will hand you now what's been labeled as 21 Exhibit 1, and it appears to be the complaint that was 22 filed on your behalf in this case. Do you agree? 23 25 Have you seen that complaint before today?

Case 3:13-cv-00678-REP-LO-D Document 232-22 Filed 0/18/15 Page 4 of 6 PageID# 5508 1 When did you see that complaint? Page 53 2 I've had this for a while, a few months. 3 few months. 4 " few months," meaning two months? Three 5 months? Four months? 6 bout three months. 7 Three months. Had you seen the complaint 8 prior to it being filed on your behalf? 10 Did you review it in preparation for the 11 deposition today? 12 13 14 15 How many times? couple. Did you participate in preparing the 16 complaint at all? 17 Did I participate? 18 Uh-huh. 1 I read it 20 Before it was filed 21 -- and talked to my attorney. 22 Before it was filed, did you participate ln 23 preparing it? 25 Before it was filed, yes. With the court?

Case 3:13-cv-00678-REP-LO-D Document 232-22 Filed 0/18/15 Page 5 of 6 PageID# 550 Page 54 1 2 I'm sorry? Before it was filed with the court in 2013? 3 4 5 I'm not understanding. I'm so sorry. That's okay. This complaint was filed on your behalf with the court? 6 7 8 That's what initiated this lawsuit? Correct. Prior to it being filed, did you participate 10 11 in preparing the complaint? Oh. Yeah. I'm sorry. 12 So you have seen it before it was filed with 13 the court, correct? I think your earlier testimony 14 was that you had not seen it before it being filed 15 with the court. 16 17 18 You said preparing before it was filed. Right. So preparing, I would assume, talking about 1 20 21 22 23 the complaint, not the actual complaint. Okay. So your testimony is you helped with preparations for the complaint prior to it being filed, but you never saw the complaint before it was filed; is that correct? That's better, yes. 25 Is there anything in the complaint, in the

Case 3:13-cv-00678-REP-LO-D Document 232-22 Filed 0/18/15 Page 6 of 6 PageID# 5510 1 allegations made in the complaint on your behalf that 2 you disagree with? Page 55 3 4 MR. MELIS: Let's make these 2 and 3. 5 6 (Person-Huballah Deposition Exhibits 2 7 and 3 are marked.) 8 We've marked as Exhibit 2 Plaintiffs' 1o Objections and Responses to Defendants' 11 Interrogatories and Requests for Production, and we've 12 marked as Exhibit 3, Plaintiffs' Objections and 13 Responses to Intervenor-Defendant Congressman's Eric 14 Cantor's Interrogatories and Requests for Production. 15 Have you seen those before today? 16 17 Will you agree with me that what you are 18 looking at, if you flip through it, is a series of 1 questions and requests and then answers and responses 20 made on your behalf? Will you agree with that? 21 Made on my behalf? 22 Correct. 23 Oh, made on my behalf. I guess so, yes. So had you seen -- I understand you haven't 25 seen those documents before. But the questions and COOK & WILEY, INC.

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