UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF FLORIDA

TALLAHASSEE DIVISION

Augusta Sandino Christian NAMPHY, et al.,

Plaintiffs,

v. Case No.: 4:20-cv-00485-MW-MAF

Ron DESANTIS, et al., 

Defendants.

 /

DECLARATION OF SCOTT MAYNOR

I, Scott Maynor, according to 28 U.S.C. § 1746, hereby state:

1. My name is Scott Maynor. I am over 18 years of age, am competent to 

testify, and declare the following facts based on my own personal knowledge. 

2. I am the Deputy Chief Information Officer. In this capacity I oversee 

the functioning of the Online Voter Registration system. I have been involved in or 

overseeing the system since its inception in 2017. I also oversaw some of its 

development. 

3. The system never crashed on October 5, 2020, book closing for the 

2020 General Election. The system experienced a tremendous slowdown due to 

overwhelming and significant traffic attempting to enter the system at the same time. 

This traffic created a bottleneck but not a stoppage. Throughout the slowdown, 

applicants were successfully submitting applications. 

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4. The online voter registration system is used to make any one of three 

kinds of “submissions:” a new registration, an update to an existing registration, or 

a request for a registration card. Thus, not every one of the systems users is actually 

trying to register to vote. County Supervisors of Elections determine the final status 

of any submission the Online Voter Registration system supplies to them. 

5. Prior to the slowdown, traffic attempting to enter the system was 

normal. For example, just after midnight on October 4, 2020, about 1,000 people 

submitted applications, followed by a drop off, and then a steady but slow climb 

throughout the day on the 5th to a peak of almost 8,000 submissions during a single 

polling hour. This is expected on book closing day and the system is well-equipped 

to handle it. 

6. At 4:38 p.m. on October 5, 2020 however, there was a significant and 

perceptible loss of traffic able to be processed by the system. Submissions dropped 

significantly from almost 8,000 submissions an hour, to 949 submissions By 

around 4:58 p.m., the pipelines within the system were completely saturated. 

7. We determined that the problem was a bottleneck, rather than some 

other reason, because of the number of submissions explained above, compared to 

the number of unique visitors attempting to enter the system, and the requests per 

hour. During the peak of the slowdown, there were around 49,000 unique visitors 

attempting to enter the system simultaneously and against peak, there were 1.1 

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million requests. I need to explain the difference between requests and unique 

visitors. The number of requests does not equal the number of individuals 

attempting to use the system. The number of requests reflects users hitting refresh 

over and over again. There were only around 49,000 unique users – unique IP 

addresses – attempting to enter the system. 

8. Traffic attempting to enter the system did not begin to drop off until 

close to midnight. The system began to recover around 1:30 a.m. on October 6, 

2020.

9. These are the total submissions on and around October 5, 2020:

a. October 4, 2020 – 58,896

b. *October 5, 2020 –70,099 * Book closing

c. October 6, 2020 – approximately 50,000

10. These are the total submissions on and around book closing for the 2018 

General Election:

a. October 8, 2018 – 25,176

b. *October 9, 2018 – 60,624 * Book closing

I say nothing further. 

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On October 7, 2020, pursuant to 28 U.S.C. § 1746, I declare under penalty of 

perjury the foregoing is true and correct: 

/s/

Scott Maynor

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