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DECLARATION OF KEVIN M. BENEDICTO 

Pursuant to 28 U.S.C. § 1746, I, Kevin M. Benedicto, declare as follows: 

1. I am over the age of eighteen, and I am competent to make this declaration. I provide this 

declaration based upon my personal knowledge. I would testify to the facts in this declaration 

under oath if called upon to do so. 

2. I am an attorney in good standing with the State of California and a Voting Rights Fellow at the 

Lawyers’ Committee for Civil Rights Under Law. In this capacity I review notes and records of 

calls made by voters to the Election Protection Hotline (866-Our-Vote), including those made by 

Florida residents. 

3. The national, nonpartisan Election Protection coalition works year-round to ensure that all voters 

have an equal opportunity to vote and have that vote count. Made up of more than 100 local, state 

and national partners, Election Protection uses a wide range of tools and activities to protect, 

advance and defend the right to vote. 

4. Election Protection provides Americans from coast to coast with comprehensive information and 

assistance at all stages of voting - from registration, to absentee and early voting, to casting a vote 

at the polls, to overcoming obstacles to their participation. Election Protection helps voters make 

sure their vote is counted through a number of resources, including: 

a. A suite of voter helplines administered by coalition members: 

 English: 866-OUR-VOTE - Lawyers' Committee for Civil Rights Under Law 

 Spanish/English: 888-VE-Y-VOTA - NALEO Educational Fund 

 Arabic/English: 844-YALLA-US - Arab American Institute (AAI) 

 Asian Languages/English: 888-API-VOTE - APIAVote & Asian Americans 

 Advancing Justice (AAJC) 

b. Voter protection field programs: legal - managed by the Lawyers' Committee for 

Civil Rights Under Law and grassroots managed by Common Cause 

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c. Digital outreach tools: including 866ourvote.org, @866ourVote, and 

facebook.com/866OurVote 

5. Throughout the election cycle, Election Protection volunteers provide voter information, 

document problems they encounter when voting and work with partners and volunteers on the 

ground to identify and remove barriers to voting. Election Protection focuses on the voter - not on 

the political horse race - and provides guidance, information and help to any American, regardless 

of his or her voting choices. The volunteers are also trained and instructed to maintain accurate 

and contemporaneous notes of their calls with voters and enter those notes into a database, and do 

so in the ordinary course of business. 

6. On October 5, 2020, I reviewed the notes of calls made by Florida residents on October 5, 2020 

reporting issues with Florida’s online voter registration portal. 

7. Based on my review of call notes, the Election Protection Hotline received at least 17 calls on 

October 5, 2020 reporting technical and access issues related to Florida’s online voter registration 

portal. Based on the reports of these calls, the callers identified themselves as being from ten 

different Florida counties, including Broward, Duval, Lake, Lee, Miami-Dade, Orange, Osceola, 

Palm Beach, Polk, and Volusia counties. 

8. The Florida Department of State announced an extension of the voter registration deadline to 

October 6, 2020 at 7:00 p.m. due to the problems experienced by the online voter registration 

system on October 5, 2020 (the final day for voter registration in Florida ahead of the November 

3, 2020 general election). 

9. On October 7, 2020, I reviewed notes of additional calls to the Election Protection Hotline (866-

Our-Vote) that were placed on October 6-7, 2020. During this period, callers were reporting 

continued technical and access issues with Florida’s online voter registration portal that prevented 

them from completing their voter registrations. 

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10. I reviewed the notes of a call made at 9:41 a.m. on October 5, 2020 that described a caller in 

Orange County, who just became a citizen, and was not able to register to vote due to error 

messages on the online voter registration portal. 

11. I reviewed the notes of a call made at 4:32 p.m. on October 5, 2020 that described a caller in 

Miami-Dade County who could not access the online voter registration portal in order to register 

to vote, despite trying the prior day, and was unable to register online. 

12. I reviewed the notes of a call made at 5:39 p.m. on October 5, 2020 that described a caller in 

Miami-Dade County who was unable to access the online voter registration portal in order to 

register to vote, despite trying multiple times. 

13. I reviewed the notes of a call made at 6:16 p.m. on October 5, 2020 that described a caller in 

Volusia County who attempted to access the online registration portal in order to register to vote 

unsuccessfully over a period of several days. 

14. I reviewed the notes of a call made at 7:07 p.m. on October 5, 2020 that described a caller in Lake 

County who attempted to access the online registration portal in order to register to vote, 

receiving an error message on the web site. 

15. I reviewed the notes of a call made at 7:01 p.m. on October 5, 2020 that described a caller in 

Broward County who attempted to access the online registration portal in order to register to vote, 

but was unable to access the online registration portal, even after 45 minutes or more of attempts 

to load the page. I followed up telephonically with this individual on October 6, 2020, and even 

though they tried to register again several times on October 6, 2020, the web site continued to be 

nonresponsive and experienced technical errors preventing registration, and the caller told me that 

they were not able to successfully register to vote, even with the extended deadline. 

16. I reviewed the notes of a call made at 6:51 p.m. on October 6, 2020 that described a caller in 

Martin County who had attempted to register on the online registration portal several times that 

day, and was unable to successfully register due to technical issues with the web site. 

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17. I reviewed the notes of a call made at 5:23 p.m. on October 6, 2020 that described a caller in 

Broward County who was unable to update their voter registration on the online registration 

portal due to technical issues and error messages on the web site.. 

18. I reviewed the notes of a call made at 4:39 p.m. on October 6, 2020 that described a caller in 

Charlotte County who could not complete their registration on the online registration portal due to 

technical issues and error messages on the web site. 

19. I reviewed the notes of a call made at 2:10 p.m. on October 7, 2020 that described a caller in 

Pasco County who could not complete their registration on the online registration portal due to 

technical issues and error messages on the web site; the notes show the caller describing that the 

web site “froze up,” preventing them from registering to vote. 

I declare under penalty of perjury that the foregoing is true and correct. Executed this 7th day of October, 

2020, in San Francisco, California. 

 ______________________________ 

 Kevin M. Benedicto 

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