IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF FLORIDA

CASE NO.: 1:22-cv-24066-KMM

GRACE, INC., et al.,

Plaintiffs,

vs.

CITY OF MIAMI,

Defendant.

________________________________________/

4343 W. Flagler Street

Suite 400

Miami, Florida

Wednesday, 10:00 a.m.

October 11, 2023

DEPOSITION

 OF 

CHRISTINA WHITE

Taken on behalf of the Plaintiffs

___

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Case 1:22-cv-24066-KMM Document 166-1 Entered on FLSD Docket 01/29/2024 Page 1 of

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APPEARANCES:

ACLU FOUNDATION OF FLORIDA, by

NICHOLAS L.V. WARREN, ESQ., (Via Zoom)

On behalf of the Plaintiffs.

DECHERT, LLP, by

CHRISTOPHER J. MERKEN, ESQ.,

Co-Counsel for the Plaintiffs.

GRAY ROBINSON, by

SYDNEY MICHELLE FELDMAN, ESQ.,

On behalf of the Defendant.

GERI BONZON-KEENAN, COUNTY ATTORNEY, by

MICHAEL B. VALDES, ASSISTANT COUNTY ATTORNEY, and

SOPHIA GUZZO, ASSISTANT COUNTY ATTORNEY,

On behalf of the Witness. 

WITNESS

CHRISTINA WHITE

Direct Examination (By Mr. Merken) 3

Cross Examination (By Ms. Feldman) 98

 E X H I B I T S

Plaintiffs' Exhibit Number 1 9

Plaintiffs' Exhibit Number 12 54

Plaintiffs' Exhibit Number 82-23 74

Plaintiffs' Exhibit Number 82-37 77

Plaintiffs' Exhibit Number 2 78

Plaintiffs' Exhibit Number 3 82

Plaintiffs' Exhibit Number 13 88

Plaintiffs' Exhibit Number 5 89

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THEREUPON:

CHRISTINA WHITE

was called as a witness by the Plaintiffs and, having 

first been duly sworn, was examined and testified as 

follows:

THE WITNESS: I do.

DIRECT EXAMINATION

BY MR. MERKEN:

Q. Good morning. 

A. Good morning.

Q. Could you please state your name and spell it, 

for the record?

A. Christina White, C-H-R-I-S-T-I-N-A, W-H-I-T-E. 

Q. And could you please state your title?

A. Supervisor or Elections for Miami-Dade County.

Q. My name is Christopher Merken. I'm a lawyer at 

Dechert. We represent the Plaintiffs in this case, 

Grace, Inc. versus the City of Miami, 22-civ-24066, in 

the U.S. District Court for the Southern District of 

Florida. 

MR. MERKEN: And could we do appearances 

for everybody else? 

MR. VALDES: Sure. Michael Valdes, 

Assistant County Attorney, counsel for 

Christina White. 

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MS. GUZZO: Sophia Guzzo, Assistant County 

Attorney, counsel for Christina White. 

MS. FELDMAN: Sidney Feldman, of Gray 

Robinson, counsel for the City of Miami.

MR. MERKEN: Thank you. 

BY MR. MERKEN:

Q. Ms. White, I know this is going to be boring, 

going over the ground rules -- I'm sure you have heard 

them before -- but this a deposition. A deposition is a 

question and answer session. I will ask the questions. 

You will answer those questions. 

You took an oath a few minutes ago, and you 

understand that, just like in court, you must answer 

each and every question with complete truth and honesty? 

We have a court reporter present, so you must 

answer every question verbally. If the question calls 

for a yes or no answer, you must answer yes or no. A 

nod or uh-huh is not permitted, because the court 

reporter may not take down everything you say. Do you 

understand?

A. I do.

Q. We also need to do our best to speak slowly and 

clearly and not talk over each other. I am guilty of 

that frequently. I talk very quickly. I will do my 

best. If I'm speaking too quickly, I'm sure the court 

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reporter will let me know, but please feel free to ask 

me to slow down, but we want to make sure we get a clear 

record. 

Your counsel may object to the questions that I 

ask. Even if counsel objects, you must still answer my 

question, unless he directs you not to answer and you 

decide to follow that instruction. Do you understand? 

A. I do. 

Q. If you don't understand my question, please 

tell me. Please do not guess, just tell me if you don't 

understand. I will do my best to rephrase, to make the 

question clearer. 

If you need a break at any time, please let me 

know. We have coffee, water, rest rooms. We can't take 

a break when a question is pending, but other than that, 

I'm happy to take a break whenever you need. 

This a corporate representative deposition, 

also known as a Rule 30(b)(6) deposition. You have been 

designated by the Miami-Dade County Elections Department 

to answer questions on its behalf. This means you're 

not testifying in your personal capacity, but as if you, 

yourself, were the Elections Department. Do you 

understand?

A. I do.

Q. I may refer to the Miami-Dade County Elections 

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Department as the County, the Elections Department, the 

department or use the full name. I will try to be 

consistent, but is it fair that you understand that any 

permutation of that title, I am referring to the 

Miami-Dade County Elections Department?

A. Yes, I do.

Q. I will try -- the same thing, I will try my 

best to ask questions, such as, does the department 

believe or is it the department's position, I may say 

you, but, I mean -- after we get through the background 

and the biographical information, I mean, the County. 

Have you take any medications or substances 

that might affect your ability to testify today?

A. No.

Q. Is there any other reason why you would be 

unable to give your full, complete and accurate 

testimony today?

A. No.

Q. And you understand that you are under oath and 

you must give your full and truthful testimony?

A. Yes, I do.

Q. Have you been deposed before?

A. Yes.

Q. How many times?

A. Maybe five or six.

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Q. What was the most recent time?

A. It was related to some laws that were passed by 

the Legislature in Senate Bill 90.

Q. Of any of the five or six times you've been 

deposed, have they involved elections or redistricting?

A. Elections, yes; but redistricting, no. 

Q. With respect to elections, what were those 

cases that you were deposed in?

A. There have been a variety of cases related to 

candidate qualifying, and, then, again, like I said, 

there have been, you know, several cases related to laws 

that the Legislature implemented throughout the State of 

Florida. So I was brought in, you know, as a witness, 

to speak how we were implementing or were planning to 

implement those things or what effect they had on 

Miami-Dade.

Q. Have you ever been deposed as a 30(b)(6) 

witness before?

A. Yes.

Q. Have you testified in any court cases?

A. Yes. 

Q. Do you remember the names of those cases?

A. I do not.

Q. When you testified as a 30(b)(6) witness 

before, was that on behalf of Miami-Dade County?

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A. Yes, the Elections Department.

Q. And you've kind of answered this, but have you 

spoken on behalf of the Elections Department in a 

legislative or administrative setting?

A. Yes.

Q. Does that include legislative or administrative 

settings not related to litigation?

A. So maybe you should elaborate on your question.

Q. Have you testified in hearings?

A. I have gone before the legislature, and also 

before our Board of County Commissioners, to speak on 

matters that relate to the department.

Q. Understood. 

Have you ever been a party to a lawsuit 

yourself?

A. Yes. I think we have been, right? 

MR. VALDES: Are you talking about her 

individually? 

BY MR. MERKEN:

Q. I'm talking about you personally. 

A. Oh, personally. 

Q. This is biographical, yes.

A. Oh, no, I have not.

Q. You have not? 

A. No. 

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Q. So you have not been a plaintiff?

A. No.

Q. You have not been a defendant?

A. No. No. No.

Q. Have you ever been a party in a criminal case?

A. No.

Q. Have you ever been arrested?

A. No.

Q. Now, when I say, "you," I'm referring to the 

Elections Department. We have moved out of the 

biographical realm. 

A. Okay. Okay.

Q. You have been designated by the Elections 

Department to answer questions on its behalf, right?

A. Yes.

Q. When did you learn that you would be testifying 

in this capacity?

A. When I received the subpoena, which I think 

was, you know, a few weeks ago.

MR. MERKEN: Mark this as Exhibit 1. 

(Thereupon, Plaintiffs' Exhibit Number 1 was 

marked for Identification.) 

BY MR. MERKEN:

Q. You've just been handed what's been marked as 

Plaintiffs' Exhibit 1. Do you recognize this document?

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A. Yes.

Q. And what is this document?

A. This is a subpoena to testify at a deposition 

in a civil action.

Q. And what's the date on this?

A. The date of the appearance or -- 

Q. The date of the subpoena. 

A. Of the subpoena? I don't know. Is it 9/19/23? 

Q. Yes. 

A. Okay. 

Q. And if you could please flip to the fourth 

page. 

A. The fourth page, you said? 

Q. The last page, yes. 

A. Uh-huh.

Q. And what does this page show?

A. This page shows the topics that we were going 

to be discussing in today's deposition.

Q. Okay. We'll come back to this exhibit in one 

moment. 

Did you, yourself, receive this subpoena or did 

somebody else at the County receive it?

A. Somebody in my office signed for it -- in my 

office, I did not -- and then it was provided to me.

Q. And how did you prepare to testify today?

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A. Well, of course, I reviewed these questions. I 

spoke to my staff members, to make sure that, you know, 

I understood and recalled some of the timelines and what 

was required for us to perform these duties in the past, 

and, of course, you know, reviewed it with my attorney.

Q. What staff members did you meet with?

A. Okay. So it would be -- do you want all of 

their names individually? 

Q. Yes, please. 

A. Okay. So Angela Rivero, Robert Rodriguez, 

Erika Sierra-Trujillo, Jose Ponce, Michael Johnson, 

Michelle McClain, and Xavier Pichs, P-I-C-H-S.

Q. Besides those seven staff members, did you meet 

with anybody else in the Elections Department to prepare 

for your testimony?

A. I think I've covered everybody.

Q. Did you meet or communicate with any other 

County employees, outside of the Elections Department, 

to prepare for your testimony?

A. No.

Q. Did you meet or communicate with anybody from 

the City of Miami to prepare for your testimony?

A. No.

Q. About how long did you spend meeting with your 

staff members to prepare for your testimony?

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A. I mean, it was a couple of hours, over several 

days.

Q. Did you review any documents?

A. Yes.

Q. What documents did you review?

A. I reviewed the questionnaire and 

correspondences between us and the City, you know, just 

in terms of the normal protocols for what we receive 

from them preparing for their elections. I looked at 

some maps. I looked at cost estimates that were 

prepared. I looked at like the procedures for 

redistricting and reprecincting. 

Q. So besides those four or five categories, is 

there anything else you looked at?

A. Our election calendar in 2024, our election 

calendar in 2023. I looked at some of the 

correspondences, to refresh my memory on correspondences 

that had occurred in the past. 

Q. Anything else?

A. I think that covers it.

Q. Okay. Did you review the Complaint in this 

case?

A. I don't know if I did.

Q. Have you reviewed any of the parties' initial 

disclosures?

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A. Can you elaborate on what that is? 

Q. No, the initial disclosures that were made as 

part of the litigation. 

A. No.

Q. Have you reviewed any deposition transcripts 

from any other witnesses?

A. No.

Q. Have you reviewed any other prior testimony in 

this case?

A. No. 

Q. Have you reviewed any other court filings?

A. The initial, I think, court filing. I don't 

know the term for it. But when, I guess, the initial 

case was settled, I did go through that, because I was 

looking at the maps and the variations in the maps, but 

I don't know what that court document is called.

Q. We'll take a look at some of them in a little 

bit. 

A. Okay.

Q. Your mentioned you had reviewed maps. Do you 

recall which maps those were that you had reviewed?

A. I just remember it was a page that had, you 

know, the varying maps, the City's initial map, what the 

plaintiffs' map looked like, and then the City's -- it 

was like a spread -- not a spreadsheet, but like a page 

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that had all of the varying maps on it from one of the 

court filings.

Q. Okay. Did you review any Miami-Dade County 

documents?

A. Can you elaborate? I think I answered the 

things that we reviewed, but if there something else 

that you were looking for, maybe you can be more 

specific.

Q. Sure. 

So you had mentioned that there were policies 

and protocols that the County has for election 

administration. What are those policies and protocols? 

A. So there's very many steps in redistricting and 

reprecincting, 37 varying steps, in fact, and so I don't 

have all of those committed to memory, and so I needed 

to review, with my staff, exactly what it does take for 

redistricting, what it took to do it the first time 

around, and if we're ordered to do it again, what is it 

going to take, so that I could properly represent to the 

Court today the timelines that I would need to be put in 

place, in order for us to be able to do this accurately. 

And so that was -- the steps that it entails were 

provided to me. 

So I asked staff to prepare that. We talked 

about it. We reviewed it, to make sure that I 

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understood it, and that's what I was referring to.

Q. To be clear, those 37 steps, is that only for 

redistricting or is that for election administration, 

generally?

A. That's for redistricting/reprecincting. 

Q. Is there another set of policies or procedures 

for general election administration?

A. I mean, that's a very broad question. We have 

very many policies and procedures. I didn't necessarily 

need to review any of those for this particular case, 

but I did reference a questionnaire earlier on, that we 

have, that we developed, that we provide to every single 

city, not just the City of Miami, in the preparation of 

their elections. And so, one of the questions on here 

was, the relationship, I think it was, between the City 

and the County. So I wanted to review what that looked 

like, so that I could recall, you know, what we're 

asking them for and what they're directing us to do, in 

the preparation of their election. So I reviewed that, 

as well.

Q. Thank you. 

I'm also not asking just if you reviewed it, 

but if it exists, if there is a written handbook policy 

about election administration that Miami-Dade County 

has?

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A. Oh, okay. So, in that case, yes. There are 

very many procedure manuals that we have -- 

Q. Approximately -- 

A. -- for varying tasks.

Q. Approximately how many manuals?

A. I don't want to guess how many.

Q. More than five?

A. Yes.

Q. More than ten?

A. Yes.

Q. More than twenty?

A. Yes.

Q. More than fifty?

A. Yes.

Q. Are there any -- 

A. Various divisions have different manuals, for 

different functions that we have.

Q. Understood. 

With respect to the 37 redistricting steps, is 

that a single document?

A. It is now a single document, yes.

Q. Okay. Did you bring any documents with you 

today?

A. Yes.

Q. What are those documents?

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A. Well, what we're talking about now. So that I 

make sure I properly represent the varying steps, I have 

that here, and I also have cost estimates.

Q. Okay. Anything else?

A. No.

Q. Did you take any notes in preparing for today?

A. I mean, it's what essentially I have here, and, 

yeah, some other things, just to sort of organize my 

thoughts, sure.

Q. And in what format are those notes?

A. They are in a Word document. 

Q. Okay. And you don't have those notes with you 

today?

A. I do.

Q. You do have those notes, in addition to the two 

sets of documents?

A. Yes. Yes.

Q. Okay. Without divulging the subject of 

attorney/client communications, with whom did you speak, 

on the counsel side, to prepare for today?

A. The two people that are in the room with me.

Q. And for about how long?

A. I would say, a couple of hours, over a couple 

of days.

Q. Was anyone else, besides these two, present?

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A. I don't believe so. No, not in these 

conversations we had. 

Q. Okay. Did you review any documents in those 

meetings?

A. Yes.

Q. What were those documents?

A. The ones that I have in front of me.

Q. Anything else?

A. And, then, whatever -- I mean, you said you 

were going to show me the court documents from the past, 

right, from the previous -- I guess, earlier stages of 

this case. We did look at that, as well, together.

Q. Anything else?

A. I don't believe so.

Q. Did you take any notes in those meetings?

A. It's the same notes.

Q. Do you think there was anything else you could 

have done to prepare to testify today, that you did not 

do?

A. No.

Q. Was there anybody else you could have talked 

to?

A. I don't believe so. The people that I listed 

there are my deputies and my GIS specialist. So I think 

-- and my attorneys. So I think I've covered everyone.

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Q. Okay. Do you live in the City of Miami?

A. No, I do not.

Q. Have you ever lived in the City of Miami?

A. No.

Q. How long have you served as Elections 

Supervisor?

A. Nine years.

Q. Had you worked in the Elections Department 

before serving as Elections Supervisor? 

A. Yes.

Q. And what was the role?

A. Well, I've been there for over 16 years, and so 

I've had varying leadership roles in the department.

Q. Can you walk me through, from when you started, 

to the extent that you can recall, to serving as 

Elections Supervisor, what those roles were?

A. Sure. So I first served as Senior Executive 

Assistant to the Supervisor of Elections at the time. 

Then I was appointed as Deputy Supervisor of Elections 

over the Government Affairs and Media Relations 

Division. Then I was appointed to Chief Deputy 

Supervisor of Elections. And in 2015, I was appointed 

by the mayor at the time as Supervisor.

Q. So the mayor, individually, appointed you to 

each of those positions? 

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A. The Supervisor of Elections, at the time, 

appointed me to the prior positions that I mentioned, 

but the mayor appointed me as Supervisor.

Q. And who was the mayor who appointed you?

A. Carlos Gimenez. 

Q. Have you ever worked for the City of Miami?

A. No.

Q. Have you ever worked for any other county?

A. No.

Q. Before the 16 years that you've spent at the 

Elections Department, had you worked in elections 

before?

A. No. 

Q. Do you like working for the County?

A. Yes, I do.

Q. Why?

A. Well, while my job is not easy, it gives me a 

great sense of pride to be able to serve the voters of 

Miami-Dade County. I'm a public servant at heart, and 

so I'm very happy doing what I do.

Q. Did you go to high school?

A. Yes.

Q. Did you graduate from high school?

A. Yes.

Q. Did you go to college?

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A. Yes.

Q. Where did you go?

A. Florida International University.

Q. What was your major?

A. Environmental Science.

Q. Did you have any minors?

A. No.

Q. Do you have any post-college education?

A. No. 

Q. Do you have any professional certifications?

A. No, uh-uh.

Q. Are there any professional certifications in 

your field?

A. Yes.

Q. What are those?

A. One of them -- well, there's a State 

certification, which is the Florida Certified Election 

Professionals, and then there's also more of a 

nationwide one, through the Election Center, and I'm 

currently working through that one now.

Q. Are you a member of any trade organizations or 

professional associations?

A. Yes. I'm a member of the Florida Supervisors 

of Election Association.

Q. Any others?

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A. Uh-uh.

Q. Do you hold any leadership role in that 

organization? 

A. I am the co-chair of the Canvassing Board 

Training Committee, and I'm a member of the 

Cybersecurity Task Force.

Q. Sounds like important work. 

What does your current job, broadly, as 

Supervisor of Elections, entail now?

A. So I oversee all elections in Miami-Dade 

County, from municipal elections, to County, State and 

Federal elections, ensuring that they're accurate and 

accessible, and in adherence with all of the applicable 

local, State and Federal laws. That entails -- it 

includes, but not limited to, making sure our precincts 

and polling places are accurately set up in our voter 

registration system and tabulation system, so that 

voters will be getting a correct ballot when they come 

to vote, training all of our poll workers, coding the 

election, preparing voting equipment, testing all of the 

voting equipment, sending out Vote-by-Mail ballots, 

administering up to 33 early voting sites, 758 

precincts, 550 polling places, and, of course, 

processing ballots, tabulating the results, 

disseminating them to the public, post-election audit, 

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after every election, and certifying the election, in 

the end, that the results are true and accurate.

Q. Wow. And you love doing that? 

A. Very much.

Q. To whom do you report?

A. The mayor of Miami-Dade County.

Q. With whom do you work on a regular basis?

A. I have 130 staff members. I work with my 

colleagues through -- that have my same position 

throughout the State, the County Attorney's Office, the 

Mayor's Office, and I probably should say that I do have 

a chief, who is under the mayor, who I report directly 

to, municipal clerks, candidates, major political 

parties, activist groups, and the public.

Q. With whom do you work, in the Elections 

Department, on a day-to-day basis?

A. I mean, day-to-day, I would say, my Deputy 

Supervisor of Elections, my Assistant Deputy Supervisor 

of Elections, and anybody else within my department that 

I need to talk to, you know, regarding whatever is going 

on at the time.

Q. And who is your deputy?

A. The people that I named before. I have six 

deputies.

Q. And the Assistant Deputies are also on that 

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list?

A. Yes.

Q. Okay. Do you work in-person or do you work 

remotely?

A. No, I'm in the office every day.

Q. You had mentioned that you report to the Mayor 

of Miami-Dade County, and, more specifically, to his 

(sic) chief. Did you have any conversations with either 

the Mayor or the Mayor's chief about this litigation?

A. Just that this deposition was happening. Of 

course, reporting up that this is something that I 

needed to do, and that there was ongoing litigation, but 

nothing, really, more specific than that.

Q. Were there any conversations between your 

office and the Mayor's Office, between December 2022, 

when this litigation commenced, and preparing for this 

deposition?

A. I mean, I would just say, simply letting them 

know, right. It's an obligation of mine to make sure 

that my superiors know what it is that I'm working on. 

I didn't have any specific conversations with them about 

what I was going to be reviewing, but, yes, giving them 

a heads up, sure.

Q. Did the Mayor or the Mayor's chief issue any 

directives or any give you any instructions about this 

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litigation?

A. No.

Q. Are there individuals that you work with only 

when elections are underway, as opposed to on a 

day-to-day basis, besides the Mayor, parties, and the 

constituencies that you already mentioned?

A. So we always have elections going on. You 

know, if it's Tuesday, it's election day, we say in my 

department. So, you know, that's a difficult question 

to answer. I deal with people, as needed.

Q. Understood. 

All right. I promise that's the end of the 

biographical, and now we're really going to move into 

the County questions. 

So this is Topic 1, on Exhibit 1, and we 

discussed this a little bit, but to confirm, there is 

now a manual or a policy handbook on how to handle 

redistricting? 

A. It's more the steps that it takes to conduct 

redistricting.

Q. So there's no formal policy or procedure?

A. No.

Q. How often does the City of Miami hold 

elections?

A. Well, they have their regularly scheduled 

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election in odd years. It may or may not have a runoff 

associated with it, right. That's to be determined. 

So, scheduled, it would be every other year. 

But, then, of course, special elections do come 

up, as needed, if there's a vacancy that is created for 

some reason. We'll conduct that. And, then, you know, 

they also do have the option of adding questions onto 

County-wide ballots. I don't recall, off the top of my 

head, when they did that. That's something that I would 

probably have to research, but that would be in 

conjunction with an election that we're already running.

Q. In a regular election, which you said are on 

the odd years, can you walk me through that process, 

from start to finish? So when does the process start, 

all of the way through certifying the election, 

post-election?

A. Sure. So, when it's a regularly scheduled 

election, it's in the Charter, so we already know that 

it is happening. So it's on our election calendar. And 

so, usually, no later than 90 days out, one of my staff 

members will reach out to the City Clerk and have -- you 

know, go through what's called, you know, the election 

coordination questionnaire. So we are asking them at 

this point to start directing us on how to conduct their 

election, right. So we know we're having it and we know 

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the date. 

So what races are on the ballot, when does 

candidate qualifying end, are there questions that are 

going to be on the ballot or do they want -- we have to 

do English and Spanish, do they want Creole, also. 

That's a decision that they make, because this is their 

election, not ours, right, and who's on their canvassing 

board, are they having early voting, how many sites, 

what's the schedule going to be, what determines a 

runoff, right. There's certain -- you know, a bunch -- 

are they paying for postage on their Vote-by-Mail 

ballots. So it's a whole questionnaire that we go 

through, so that we know how we are going to proceed 

with running their election. They answer those 

questions. 

And then we wait for the candidate qualifying 

-- well, with that, then we can start, you know, 

reaching out to our polling places, start putting our 

poll workers training calendar together, and start to 

begin certain functions that are not related to the 

ballot, right, certain things that we can get a head 

start with, because we know we're running the election. 

So then we're waiting for candidate qualifying 

to end, which is a responsibility of the City Clerk. 

They do all of the candidate qualifying. They do all of 

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the campaign finance stuff. And then they will tell us, 

when it closes, these are the races, these are the 

people that are on the ballot. We'll prepare what's 

called the master ballot. We have them sign off on it, 

to make sure that they agree this is correct, and then 

we prepare -- do you want to go into exhaustive detail 

about all of the steps? 

Q. Please. 

A. Okay. So then we prepare the actual ballot, 

which we provide to them again, which they sign off on, 

to say, yes, all of the contents are correct, send it to 

the printer, so that we can get some test ballots. We 

go through all of the various testing, to make sure that 

we've coded the ballot correctly and that the printers 

are printing them properly, feed them through a certain 

number of tabulators, just to make sure that we've done 

everything correctly. Then we can give the ballot order 

to the printer. 

We receive the Vote-by-Mail ballots at that 

point, send those out to their voters, and, you know, 

then proceed with setting, you know, all of the 

logistics related to early voting, if they're having it, 

which the City of Miami typically does, varying sites, 

depending on the size of the elections, you know, 

starting to place our poll workers in place, and that's 

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it. 

Then we'll start to receive Vote-by-Mail 

ballots. We conduct their early voting, and when 

election day is completed, all of the results, of 

course, are coming in. We're the ones that post them 

onto the website. 

It's their canvassing board, so throughout this 

process, their three member canvassing board will be 

coming into our office, reviewing Vote-by-Mail ballots 

that we believe are presumed invalid, for them to make 

the final determination on that. They also come back to 

look at provisional ballots. And, then, after that, we 

will certify the results to them. They ultimately 

certify the election itself to their Commission. 

We'll conduct the post-election audit for them, 

and then that, really, at that point, concludes the 

election, and then they swear in their elected officials 

at that point. 

I think I hit all of the high points.

Q. So, my understanding, and correct me if I'm 

wrong, please, is that the process, generally, in a 

regularly scheduled City of Miami election, generally 

commences, from your end, about 90 days before the 

election is scheduled to be held? 

A. Yeah. No later than.

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Q. When is your earliest it would commence, your 

involvement?

A. I mean, you know, I think like we start, you 

know, 120 to 90 days out, just to -- it depends on my 

staff. 

Q. Are there any particular members of your 

department who are designated to handle the City of 

Miami elections?

A. I mean, the one person, who is our election 

coordinator -- her name is Liz Prieto -- she's the one 

that most commonly will deal with not just the City of 

Miami, but all City Clerks, but then she has superiors 

that also will communicate with the clerks, because we 

have relationships with everybody. So it just depends 

on who they reach out to. 

But, no, not specific to cities, right. 

There's not a point person for the City of Miami, per 

se.

Q. Okay. You had mentioned that it's a 

collaborative process with the City, and we'll get more 

into that in a little bit, but is there anybody at the 

City, who is the City's point person, who generally does 

the outreach to your department?

A. So it's typically two people, Todd Hannon, who 

is the Clerk, and then his -- and, then, Sandra Forges, 

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who -- I don't know her title off-hand, but she's 

somebody who deals directly with our department for 

elections coordination. 

Q. Is there -- I'm sorry. 

A. No, it's okay. Those would be the two people.

Q. Is there anybody else?

A. Not commonly.

Q. Within that 90 to 120-day window that you've 

mentioned, are there interim deadlines for tasks to be 

accomplished? You ran through kind of an exhaustive 

list of all of the steps, but is it the case that the 

County has, say, at 87 days out, this need to be done, 

at 80 days out, this needs to be done?

A. Yes. So we always ask for deadlines, right, 

and hope that they're adhered to. So we do ask for all 

ballot content and everything to be given to me no later 

than 60 days prior to the election.

Q. Besides ballot content and other ballot-related 

materials, are there any other internal deadlines?

A. In just the regular election administration, 

just talking about conducting their election? 

Q. Yes. 

A. For a regularly scheduled election, it's the 

dates that I've already given you. It changes when it's 

a County-wide. When you're trying to piggyback onto a 

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County-wide election, it's a completely different 

situation, because I have Statutes that I need to adhere 

to, and I cannot wait around for a city to be giving me 

content late, when I have a huge election to run. 

So, yeah -- I mean, if there's any Resolutions 

that need to be passed by the Commission, with 

questions, let's say, or if they're setting up their 

early voting dates and stuff like that, we always ask 

for everything to be given to us no later than 60 days.

Q. You had mentioned a County-wide election and 

the City piggybacking on that. Can you explain that a 

little bit more?

A. Sure. So, in this case, when I use the term, 

piggybacking, it's an election that we're already 

running. So, in 2024, we're talking about the August 

primary and the November general election. We are doing 

those elections, anyway, because, of course, it's 

required for all of the other, you know, County and 

State and Federal races. So, the cities do have an 

option, if they want to piggyback onto that election. 

It's usually not because of a race, because those are in 

their Charter, it's usually because they would add 

questions, or if it just so happens that a vacancy 

occurs and it aligns with our election, then we 

typically agree to that, as long as they give us 

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everything that we need well in advance.

Q. So, in that context, and we'll talk about the 

2024 election in a little bit, but in that context, what 

do those deadlines look like, as opposed to the 90 to 

120 days and 60 days you mentioned?

A. So I don't have any deadline committed to 

memory right now, but it's certainly well before the 

election. And I will tell you this, that even though 

you want to put something on the November ballot, we set 

things up as a cycle, right. So the August and November 

election is considered one election cycle, and I don't 

like to make changes. I don't like to make precinct 

changes, I don't like to make polling place changes, I 

don't like -- candidate qualifying, all of these things 

have to end before -- well, candidate qualifying, I 

should probably put that aside for a minute. 

Everything needs to happen well in advance of 

the August election, so that it's set and put in place. 

One, off the top of my head, that I can confidently is, 

if you are somebody that's putting races on the November 

ballot, we ask that you have all candidate qualifying 

ending and the names provided to us by August 23rd, 

because the primary election is on August 20th, and I 

know, within a couple of days after that election, who 

is going to the November election. So I cannot wait 

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beyond that point. 

So that would be a good example, that even 

though the election is November, I need your ballot 

content in August.

Q. Okay. We'll talk about the 2024 election in a 

minute, but since we were in that zone, I just wanted to 

mention that.

A. Okay.

Q. In a normal, regularly scheduled City election, 

that occurs after redistricting has happened, what does 

that process look like for receiving a map from the 

City?

A. Depends on the election that we're talking 

about, right. So, previously, I had asked for an August 

1st deadline for their November election. I think you 

probably know that, right? 

Q. Yes. 

A. So I asked for that, because, you know, that 

would give us enough time to do the steps I'm sure we'll 

get into a minute, for -- you know, in order to conduct 

their election. 

When we talk about 2024, I'm going to be asking 

the Court for more time. If the Court decides that 

there's a different map that is going to be provided to 

the department, it's much earlier in the process, 

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because I need to have all of this work done well in 

advance of us preparing for the '24 election cycle.

Q. Since we're there, what date would that date 

be?

A. So I think the clearest way for me to describe 

dates is to give two, and I'm going to work backwards, 

because I really want this to be very clear to anybody 

who is reading a transcript, right. 

I already alluded to the fact that the way we 

conduct elections is in cycles, right, and so I need to 

have all precincts and all polling places confirmed, 

without changes being made, and that's just to not 

burden my staff, but more importantly, not to be 

confusing to voters in a presidential election cycle, in 

advance of the August primary election. And so all of 

this needs to be in the voter registration system, my 

tabulation system and also my automated Vote-by-Mail 

system before candidate qualifying starts, and that's in 

June, for August. 

So when you start backing out from that, what I 

need to have completely done and finished, and my 

resources not being dedicated to this particular topic, 

no later than -- this is my request to the Court -- by 

May 15th. That's for me. That's for all of my internal 

work to be done, so that my staff can focus their 

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attention and my resources on the presidential election 

cycle, right. That's May 15th. 

And so, if I back out from there, the question 

is, well, how much time do I need? That is a question 

that is very difficult for me to answer here today, 

because I have no idea what the changes are going to be, 

is it a little bit of a tweak? Are they major changes? 

I have no idea. And so I need to have some sort of 

deadline, to provide to the Court, that gives me 

confidence that we will be able to do this work 

accurately and with professionalism, and it's very, very 

detailed work, 37 steps, that must be done in sequential 

order. 

And so my request to the Court is going to be 

that all of this be complete, all, you know, court 

cases, and like non-appealable, you know, this is the 

final, final, final map, by March 31st of 2024.

Q. Thank you. We'll talk more about the 2024 

election and that process, but that was a helpful clear 

answer to the Court. I really appreciate that. It will 

be crystal clear in the transcript. 

How much does it cost to run the City of Miami 

elections?

A. A regularly scheduled election? 

Q. Yes, a regularly scheduled election. 

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A. A full City election is estimated at $805,000, 

and that takes into consideration their current early 

voting model. I do know they do make changes from time 

to time. 

So, as of today, I can say, approximately 

805,000.

Q. Are all of those costs, the 805,000, passed on 

to the City?

A. Yes.

Q. None are absorbed by the County?

A. No.

Q. Is that pricing done on an election by election 

basis?

A. Yes, it is, because costs fluctuate, right, 

postage changes, and, again, you know, if they change 

their early voting model and what have you, we will do 

new estimates for them.

Q. So you mentioned postage changing, which I 

think will be happening in 2024, and the early voting 

model that the City uses. Are there other factors that 

would impact the price of the election?

A. I mean, if we have changes in, you know, the 

printing costs from our paper vendor. We do hire 

temporary workers, so if there's a change in the 

temporary rate, then, of course, all of those costs 

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would be passed on.

Q. Any other -- 

A. So I think -- so, I think, printing, postage, 

temporary workers, and, then, early voting. I think 

those are probably the biggest factors, variables, that 

would impact it.

Q. Are there any variables on the County side that 

would impact the price?

A. We pass on the direct cost.

Q. Okay. So all of the testimony we just heard 

was about regularly scheduled elections. Now we're 

going to move into special elections, if we could. How 

does the County prepare for a special City of Miami 

election, that is not concurrent with another regularly 

scheduled election?

A. All of the steps that I've already described 

would be applicable here, as well. I think the biggest 

nuance that I should mention is just that, you know, at 

this point, we're not prepared for this election, and so 

there is communication that has to happen between my 

office and the City Clerk, as it relates to the timing 

of it. I know they do have -- and it depends, because 

if it's a vacancy, I know that's in their Charter, it's 

a little bit more -- not a little bit more, but a lot 

more strict on when they can do it, and if it's not, 

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then, there's a little bit more flexibility, but what 

has to happen is, by Florida Statute, the City Clerk has 

to request approval from the Supervisor of Elections to 

conduct said special election, and then we collaborate 

on the dates that would work for both, and, then, once 

that's agreed upon, then everything that I've already 

described would happen.

Q. You said that the County and the City 

collaborate on dates. How does that determination get 

made?

A. It's largely, on our part, based upon 

resources. I mean, if you look at our election 

calendar, and I made that comment earlier, if it's 

Tuesday, it's election day. You know, it's a bit funny, 

but not really, because it's pretty true. So it just 

depends on what other elections that we have going on, 

and if we can accommodate it, and, you know, is there a 

County-wide election coming up, where I have all of my 

resources and equipment dedicated to that, that would be 

a problem, right. 

So, you know, working within the confines of 

their requirement by law and what it is that we're able 

to accomplish with resources, is usually how we get 

there.

Q. What happens if the County cannot accommodate a 

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special election, when the City wants to hold it?

A. Then there's a provision in Florida Statute 

that they're free to conduct the election on their own. 

My only requirement is to turn over the voter 

registration rolls to them. Thankfully, we've never had 

to get to that point.

Q. Do you know what Statute that is?

A. Not off the top of my head.

Q. Is there anybody in your office that is 

designated to handle special elections, as opposed to 

regularly scheduled elections?

A. No.

Q. So, you said, once you know that there's going 

to be a special election, and once that date for the 

special election is set, then the same 37 odd steps 

sequentially occur, right?

A. Well, the 37 steps were related to 

redistricting. 

Q. I'm sorry. I'm sorry. 

A. Yeah. So, the questionnaire, the back and 

forth, the directive from them on how they want us to 

conduct the election, would be the same.

Q. Is there a different election coordination 

questionnaire for a special election, as opposed to a 

regular election?

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A. No. 

Q. Are there any additional or different questions 

the County would ask the City, in preparing for the 

special election, as opposed to a regular election?

A. I cannot think of any, other than, you know, 

what we've already talked about, which is the date.

Q. And that same 90 to 120 days out is when the 

County would start its process of preparing for the 

election? 

A. If we're lucky. We don't always have that 

luxury, truthfully, because if some -- and I don't know 

the City of Miami's Charter off the top of my head, but, 

in some instances, we don't always have that much time, 

but if it's a small city, then, you know, we're able to 

accommodate it.

Q. What is the least amount of time you've had to 

run a special election?

A. You're testing my memory on that. I'd have -- 

Q. If you remember. 

A. I'd have to look into that.

Q. Are there different costs for a special 

election that is not concurrent with another election?

A. So, is your question, special, compared to a 

regular election? 

Q. Yes. 

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A. Okay. So, meaning, a City of Miami special 

election, versus a City of Miami regularly scheduled 

election, is there a difference? 

Q. Yes, with one qualification, a City of Miami 

special election that is not concurrent with another 

regularly scheduled election, and a regularly scheduled 

City of Miami election. 

A. As long as it's the same number of 

jurisdictions at play here, right, like city versus city 

or two district versus two districts, right, because 

there will be a variable in the cost, I don't -- unless 

they make a change, right, they say, I want to have 

three days of early voting in six sites, and five days 

of early voting in two sites or, you know, something 

like that, as long as all of the variables are the same, 

I can't see why there would be a different cost, right. 

Like for -- just to take it one step further, 

just to make sure I'm being clear, their regular 

election estimate is a little bit more than their runoff 

election, because in their runoff election, because of 

the way that the timing of the cycle is, their early 

voting is limited, so that brings the cost down. So, as 

long as the variables are the same, the cost should be 

the same.

Q. So assuming no City requested changes, like 

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different early voting, et cetera, that special 

election -- a City special election -- would 

approximately cost $805,000?

A. If it was a standalone, is my verbiage, right, 

on its own election, yes.

Q. Yes. 

We're going to now move to the third category 

of elections, if we could, and you alluded to this a 

little bit already, but if the City of Miami wants to 

hold a special election concurrent with other regularly 

scheduled elections, County, Statewide, how does that 

change the process on your end?

A. Okay. So taking redistricting and 

reprecincting out of this scenario, we're just talking 

about adding -- piggybacking onto a County-wide 

election? 

Q. Yes. 

A. Okay. So it's really not all that burdensome 

for a city to piggyback onto our election, unless they 

decide to add a bunch of questions, making the ballot 

really long. Then that gets a little bit tricky. But 

if we are already having a scheduled election, and they 

ask for approval to piggyback, and adhere to our 

deadlines, then -- in terms of, you know, providing us 

with their candidate qualifying on time or providing us 

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with the questions on time, then it really is not much 

of an impact to us or the election. So that's always 

approved. 

And, then, of course, they pay, not as much, 

but they pay a portion of the election to piggyback, 

which is mostly printing, postage, if it triggers an 

additional page, that I wouldn't have to do anyway, 

some, you know, ballot preparation costs, because now 

I'm adding additional styles to the election. So there 

is -- there's some cost to the City to do this, but it's 

not as much as having a standalone.

Q. You mentioned that the City can request to 

piggyback. Is there a formal request process or is it 

the City Clerk calls your office and says, "We want to 

have a special election next year"?

A. So we remind them, over and over, that they 

have to ask us, by Florida Statute, for approval in 

advance. So that would be the formality there. It 

would be that they ask us, usually by e-mail, you know, 

we're asking the Supervisor of Elections to add this 

particular race or this many questions on the ballot, 

and then we will reply back to them saying that, you 

know, yes, we do approve that, as long as you -- and 

then we give them the ballot deadlines, as long as you 

do this, and agree to pay this, right, if they ask for a 

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cost estimate, and then that's really it.

Q. Has the County ever rejected a request from 

anybody to have a special election -- a piggyback 

special election?

A. I cannot recall a time where we said, no. 

Q. You've mentioned, for all three of these, the 

regularly scheduled Miami election, the special election 

as a standalone, your words, and the special election 

piggybacking, you mentioned the costs for the first two, 

and I want to just make sure I'm clear on the cost for 

the third, which is the City has a special election 

concurrent with, piggybacked, on a County election. 

A. Right. So, if the City -- if the City 

piggybacks on a County-wide election, we're estimating 

that to be about 115,000. 

Q. And that's all in, the cost for the County to 

run a special City election?

A. Yes.

Q. Now, you've mentioned runoffs, which we haven't 

yet talked about, and I will have some more questions on 

runoffs --

A. Small caveat. If there were additional 

questions that were added, that would trigger additional 

ballot pages, then they would take all of the cost of 

that additional ballot page for the people in their City 

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and the associated postage for the Vote-by-Mail ballots, 

as well, but this does not assume that that's the case.

Q. Understood. Thank you. 

So, for runoffs, just briefly, what do the 

costs for runoffs look like, and we can go category by 

category, but for a regularly scheduled City election, a 

special City election standalone, and a special City 

election piggybacked?

A. Okay. So these are estimates, based upon 

previous decisions that have been made by the City, in 

terms of what we've already talked about, early voting 

and such, but just to recap, to piggyback on a 

County-wide election, I'm estimating it at about 

115,000. If there is a runoff, that occurs after the 

County-wide election, that does increase to $507,000, 

because that's not an election that we would hold. We 

wouldn't be doing that otherwise. So if there is a 

runoff, they would be responsible for all of those 

direct costs. 

Again, a standalone, using their previous early 

voting model, is about 805,000, and their runoff, after 

that election, is 606,000. And like I said, the reason 

it's different is just the availability of early voting.

Q. And, then, for regularly scheduled elections?

A. That's what that is. That's the same thing. 

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Q. So, for standalone and for regularly scheduled, 

a runoff is the same? 

A. Yes.

Q. Okay. And you had said that for piggybacked 

elections, the cost of the runoff is 507,000; is that 

right?

A. Uh-huh.

Q. That's in addition to the 115,000? 

A. Yes, if it goes to a runoff.

Q. If it goes to a runoff. 

And, then, for a standalone and a regularly 

scheduled election, the runoff cost would be 606,000 -- 

A. Yes.

Q. -- in addition to the 805,000?

A. Yes.

Q. Okay. I want to talk about redistricting. 

What happens when the City of Miami prepares a new map 

for the Miami City Commission? After they have prepared 

that map, what happens on the County side?

A. So, first thing first, from the City Clerk, 

because that is our contact, right, that we receive our 

direction from, on all matters related to City 

elections, right, we ask that it come from either Todd 

or Sandra -- those are our two contacts -- telling us, 

this is the map that we are going to be using for the 

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future, these are our new boundary lines. 

And, then, from there, I'm happy to run through 

all of these varying steps, if you want me to, but just 

overview-wise, right, what we would first do is, take 

the new district maps, overlay them on our precinct 

maps, and start to do the research of, you know, what 

does this mean, like how drastic are the changes, and 

try to get a sense of how much work it's going to 

entail. And, then, you know -- it's probably best if I 

just read from this document, okay. 

Okay. So I'm just going to hit highlights. 

I'm not going to go into all of them, but you can ask 

me, I guess. 

Okay. So the first step is to review the 

impact to current precincts, which is, I think, as I 

started to say, you know, we overlay the new district 

boundary lines over our current precincts and identify 

how many precincts are impacted. This would consist of 

either whole precincts or are we going to have to now 

take that precinct and split it up. 

We have to create the core boundary layer, 

identifying every single district boundary identified 

within that precinct, and this is used to determine if 

we can take that precinct and consolidate it with 

another one or if we're going to actually have to create 

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a brand new precinct by itself, because it doesn't share 

representatives with anything else. 

If a new precincts is needed, we have to 

identify the precinct -- a new precinct number, one that 

is not being used. And, then, from there, we start 

doing the identification of how many voters are impacted 

by this. Obviously, we have to quality assure all of 

that stuff. 

Then -- this is all done in our GIS system. 

That's where we start. And, then, once we have all of 

these steps completed, and we're confident in them, 

that's when we can start moving it into our voter 

registration system, which is the live production 

system. And so, from there, we have to start 

identifying each and every street range that needs to be 

modified and moved, to account for the new lines, 

quality assure all of those street ranges, and then we 

update our precinct and City of Miami shapefiles, 

provide that to the Miami-Dade County Information 

Technology Department, to make sure that what we have in 

our system is consistent with what they have in their 

system, to make sure that no errors have been made. 

We add all of the new precincts into the voter 

registration system. We adjust the district values, 

which means these precincts used to be, let's say, in 

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District 1, and now they're in District 2, adjust any 

polling place assignments, right. So, at this point, we 

are figuring out, were these precincts able to be 

absorbed, and so, therefore -- and the polling place is 

able to accommodate those additional people, or, if not, 

that is when we have to actually start going out and 

surveying the City of Miami, to determine if we can find 

new polling locations. So it starts to get a little bit 

more complicated and more timely there, if I have to 

start surveying for new locations and trying to convince 

an owner of a private facility to allow us to use that 

facility. 

So once all of the street ranges are identified 

by precinct in our voter registration system, we then do 

what's called a yellow dot analysis, and that's to make 

sure that every single voter, in every single home, was 

properly moved into the correct district. And there are 

many exceptions that occur in this, because of alias 

addresses and that type of thing, and so we'll have to 

go one by one and research each one of these addresses, 

and, you know, move them into -- you know, yes, we 

reviewed them, and, yes, this has been done properly. 

Once all of that is done in the system, we 

provide these files to both, the tabulation team and our 

automated vote -- automated absentee ballot system, so 

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that we can make sure that all of the precincts on their 

end match all of the precincts on the voter registration 

end, to make sure that not only the voters are going to 

receive the correct ballot, but also that the tabulation 

system is going to be ready to recognize that from the 

system. 

We have to update all of our asset management 

systems to account for the new precinct numbers, and 

then, you know, we already talked a little bit about the 

polling place analysis. 

That is -- a lot of what I've already talked 

about is system type stuff. The polling places is 

another function altogether, because there's a lot of 

review and care that's taken into that. I don't want -- 

especially going into a presidential election cycle, we 

need to make sure that we don't have too many people and 

too much turnout going into any one location, and so we 

really would have to review, one by one, to make sure 

that if we're adding an extra hundred people here or 600 

people there or a thousand people here, that the 

location can accomodate it, parking, power, equipment, 

all of these things, and, then, if not, you know, go out 

and try to locate new locations. 

My scheduling section needs to have all of this 

in their system, too, so that we can have the poll 

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workers assigned to the proper new precincts. And once 

all of that is done, then we can begin to generate new 

voter information cards. That alone, is a very big 

project, because what we need to do is extract them in 

batches and send them out in batches. 

So, are we talking about here, a few City of 

Miami voters, a modest amount of City of Miami voters, 

or all City of Miami voters? That's going to determine 

how many batches of cards we need to generate, quality 

assure and mail out, in a way that we can keep up with 

the call volume, and, then, of course, all of the maps, 

all of the statistics, all of the reports that all of 

the candidates and parties -- that have to be produced, 

quality assured and placed on the website. 

That is just an overview of all of the steps 

that need to happen.

Q. Thank you. 

You mentioned GIS. What is GIS? 

A. Okay. GIS is a Geographical Information 

System. So it's basically electronic mapping. So we 

receive, you know, the files electronically. That's 

what we request from everybody that's done 

redistricting, all of the various jurisdictions, and 

then we place them over our GIS maps of our precinct 

boundaries and our current existing boundaries, and we 

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start there.

Q. Just to confirm, you said that the County 

requests GIS files from, say, the City of Miami?

A. Yes. Shapefiles, correct.

Q. Is a GIS file and a shapefile the same thing?

A. GIS, I guess I would categorize as more of like 

the generic title of like the system itself, and the 

shapefile is a specific type of file that we request 

from the City.

Q. Who, at the County, handles the GIS process?

A. Xavier Pichs, P-I-C-H-S.

Q. Anybody else?

A. I mean, he's my GIS specialist, and then he has 

superiors, but that is the main GIS person in my 

department.

Q. What is a Block Assignment File?

A. I can't answer that confidently. 

Q. Who, at the City, handles the GIS process?

A. As I said, we receive these files from the 

Clerk, so I don't know who does them in the background.

Q. Would the County ever communicate directly with 

the City's GIS folks?

A. Would they ever? I don't see why not, if they 

had questions.

Q. Do you know of a time when that has happened?

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A. No.

MR. MERKEN: Please mark this as Exhibit 

12. 

(Thereupon, Plaintiffs' Exhibit Number 12 was 

marked for Identification.) 

BY MR. MERKEN:

Q. I have handed you what's been marked as 

Plaintiffs' Exhibit 12. Do you recognize this document?

A. I don't believe I've seen this document before.

Q. I will represent to you that this is the City 

of Miami's reply brief in support of the City's 

Emergency Motion to Stay the Redistricting Order that 

they filed in the U.S. Court of Appeals for the Eleventh 

Circuit on August the 2nd, 2023. 

A. Okay.

Q. If you could, please, turn to Page 9, and if 

you could look at Footnote 3. I'm going to read this, 

for the record, and I'd like you to confirm that I read 

it correctly. 

It reads, "The Miami-Dade County's 

reprecincting process is complicated and time consuming 

(Docket Entry 24-30). The County needs detailed map 

with exact district boundaries. Id. The City had over 

a month to work with its Geographic Information Systems 

team to put the information together for the County. 

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With the Mandated Map, the County would have to start 

from scratch, adding further confusion and delay, and 

further running afoul of Purcell." Did I read that 

correctly?

A. Yes.

Q. Do you know what the City and the County did 

together, during that month that it said that the City 

has worked to prepare the detailed GIS shapefiles? 

A. Am I missing the month? When is this? 

Q. This is the City's writing. They say that they 

had a month -- 

A. But do you know like when this was, because I 

can't speak to what happened over that month, unless I 

know when -- 

Q. This would have been -- 

A. -- this is referring to, if at all, but that 

would help? 

Q. Right. Well, I guess a broader question is, in 

2023, has the County worked with the City on shapefiles 

or GIS processes at all?

A. Not to my knowledge, no.

Q. Has the County received any GIS shapefiles from 

the City?

A. I mean, I know that we received their map on 

the 1st, right, August 1st. I would have to look back 

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and see exactly what it was that they gave us. I think 

they gave us what we asked for. I hadn't heard 

otherwise.

Q. But you're not sure if the City provided you a 

shapefile on August 1st?

A. No.

Q. We'll come back to this in a little bit. 

Does the City re-assign voters to Districts 1, 

2, 3, 4 and 5 or does the County do that, once a new map 

is implemented?

A. Voters within the City? 

Q. Yes. 

A. Well -- 

Q. I can rephrase the question. I'm sorry if that 

was a confusing question.

A. Yeah. Thank you.

Q. After reprecincting has occurred and the County 

is provided with the map that will be used, does the 

City or the County actually undertake the process of 

moving voters from District 1 to District 2?

A. Okay. So you're talking about redistricting, 

right, because you said reprecincting, so I just want to 

be very clear? 

Q. Yes. I'm sorry, redistricting. 

A. Right. So the City provides us with the 

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boundary lines. We take the action of moving the voters 

from one district into the other in our systems.

Q. Okay. Is there a discreet cost for that 

process?

A. So we have not charged them for any of the 

first go around. We did it as part of our larger 

redistricting and reprecincting process, right, but if 

we are doing this again, and it takes a significant 

amount of time, I will be passing that charge onto them, 

particularly as it relates to mailing new voter 

information cards.

Q. Can you estimate, if this were to occur again, 

what that cost would be?

A. Yes. So, this is an up to number. Up to 

$154,000. And, you know, again, I keep -- I guess I've 

said it once, I feel like I'm going to say it a lot, I'm 

at a disadvantage here, because if the Court orders a 

new map, I have no idea what the severity of those 

changes are going to be, right, how much time is it 

going to take to do all of those 37 steps, is it a 

little tweak or am I redoing all of the district 

boundary lines, right? 

So it could take us a small amount of time or a 

large amount of time. How many polling places do I have 

to go out and search for, how many voters is it 

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impacting? So I don't -- timing and costs are very hard 

things for me to say here, but the up to $154,000 is, 

you know, for staff time and assuming that we're sending 

all voters in the City of Miami new voter information 

cards. So it would adjust, according to what we need to 

do. That's the large bulk of the costs here.

Q. You mentioned that assumes that you would send 

every City of Miami resident a new voter card. Would 

there be a reason that you would not send every City of 

Miami voter a new voter card, after redistricting has 

occurred?

A. Yeah. I think it's just going to be a call -- 

you know, a last minute decision, on our part, as to how 

many voters are impacted. You know, I don't feel the 

need to send every voter a new voter information card, 

if it's only affecting a small number of voters, but it 

may get to a point where, if it's a significant number 

of people impacted, then, you know, we may just make the 

decision to send it to everybody. 

Q. And that would primarily be a mailing cost -- a 

printing and mailing cost?

A. Printing and mailing.

Q. What laws apply -- you mentioned some of them, 

but what laws apply to a City of Miami City Commission 

map and the County's implementation of their map?

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A. That's a tough one. I mean, I think that, you 

know, in terms of redistricting, there's obviously laws 

that relate to them. That's not necessarily my 

department, how they do that, but you're talking about 

from our perspective? 

Q. Yes. 

A. If redistricting occurs, and then 

reprecincting, which is an inevitable byproduct of 

redistricting, just because, you know, it's part of 

election administration, there are requirements in the 

Florida Statutes that guide us on how we set up our 

precincts. 

So I don't know the Statutes off the top of my 

head, but, you know, there are Statutes that require us 

to take certain things into consideration when we're 

creating our precincts, and, then, the approval of those 

precincts, which have to go before the Board of County 

Commissioners. 

Q. Are there any Statutes that govern the costs of 

election administration?

A. Not really, no.

Q. So there's no Statute that says it's capped at 

a certain cost or must meet a minimum threshold?

A. No.

Q. So you've mentioned precincting a lot, and I 

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know that conflating redistricting and reprecincting can 

be a bit of a problem. So can you walk me through what 

reprecincting looks like, assuming you have received a 

new map or in any election? What is reprecincting and 

what does it look like? 

A. Okay. So proper election administration would 

mean that a single precinct has all of the same exact 

representatives, right, so that when voters come into 

that particular precinct, they all receive the same 

exact ballot, unless, of course, it's a primary 

election, and then there's a party differentiation. But 

we're laying down Congressional, State Senate, State 

House, County Commission, School Board, you name it, 

City of Miami Commission Districts, all on top of each 

other, and after you do all of that, there are boxes 

that are created, all throughout the County, right, and 

that's how you start building your precincts. So the 

idea for, again, efficient and professional and error 

free election administration, every precinct has all of 

the same representatives. 

So when new districts, now that we've done all 

of the redistricting for all of the County and we've 

done all of the reprecincting for all of the County, and 

we are in great shape to have a very successful and 

accurate election in 2024, if now a new map is provided 

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to us, which is okay, as long as it's all done within 

the timelines that I'm hoping will be respected, then 

those district lines will be dropped on top of our 

current precinct lines. 

If I didn't do anything further with that, then 

those district lines are going to start splitting 

precincts, right, and then I have, okay, then Precinct 

1 -- the people in Precinct 1, as an example, now have 

these representatives, and the other half have these 

representatives. That's not a great situation to go 

into a presidential election with. So, then, what do 

you do next? 

You start to embark upon phase two of 

redistricting, which is reprecincting. So that's when 

you start looking at every single precinct and start to 

make decisions. Okay, so if Precinct 1 was split in 

half, can I take the voters in that half of the precinct 

and maybe consolidate them with somebody else? If you 

can do that, that's fantastic. Great, re-draw the 

precinct line to accomodate those people. 

But then we have to ask ourselves what I had 

said earlier, can it accommodate those additional 

people? And hopefully it can, but, again, going into a 

presidential election, high voter turnout, we want to be 

conservative about these decisions, so that takes time. 

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That's an analysis, and review, and that's moving voters 

again, after we just moved them once, right. 

If you can't consolidate them to a neighboring 

precinct, because they just don't share now any of the 

same districts -- same representatives, then we have to 

give it a new precinct number and figure out where is it 

going. Are we going to leave it in the same polling 

place or are we going to find a new one? And, then, 

that's where all the field work really comes into play 

for our research. 

So you do that, so you can have voters of the 

same -- with the same representatives voting within the 

same precinct.

Q. Does the County ever administer elections with 

split precincts?

A. Yes, we did, in 2022.

Q. What happens when that occurs? I know that 

you've explained a little bit, but what happens when 

there's a split precinct? 

A. It's just more complicated. It's more 

complicated for us, because it's just more of 

everything, right. So it's more precincts, because now, 

this precinct, the one scenario I described, it's a one 

dot "O" and then a one dot one, So now we are adding to 

the number of precincts, and when you start adding to 

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the number of precincts, that just makes all our work 

internally more complicated, in terms of, you know, 

coding the election, printing additional ballot styles. 

That means we have to quality assure additional ballot 

styles. That means we have to process more coming in to 

our system, more boxes of ballots going out to the 

precincts, poll workers are being told, "Now, you don't 

just have one precinct, you have four or six precincts," 

depending on how many splits are occurring, and what is 

very difficult for them is, they have to get that ballot 

right. They need to make sure that you're getting one 

dot "O", the next voter is gets one dot one, and that 

gets even more complicated, in a primary election, 

because for every one of those splits, there's three. 

There's the Republican, the Democrat and the No Party 

Affiliation. 

And so it is really not the efficient and most 

successful -- has it been done, yes, but is it the way 

to go into the 2024 election cycle? It's my opinion 

that that's not the way to do it.

Q. Understanding it may not be, and this is my 

phrase, not yours, best practices, to have split 

precincts, were there any problems with split precincts 

in the 2022 election administration?

A. There were not.

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Q. Are voters always assigned a new polling place 

after redistricting?

A. No.

Q. What would impact the decision to reassign 

voters or not reassign voters to a new polling place, 

after redistricting?

A. I think I just answered that, probably, in my 

long-winded response to the previous question. If there 

is, you know, no impact to them, right -- I mean, not 

every voter, in every precinct, is going to be impacted. 

So I wouldn't change polling places for those people who 

are not impacted. It would just be the consideration of 

those who are. 

Another possibility is, if a map was drawn -- 

if there was a new map that was adopted, if that map was 

drawn to take into consideration the current precinct 

lines and not split through precincts, that would also 

help to expedite our work and it would not require those 

voters to move from their precinct or their polling 

location.

Q. Is there a current map that shows those current 

precincts for the 2024 election?

A. Yes. From our department, you mean, that we 

can provide? 

Q. Yes. 

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A. Yes.

Q. Could you please provide that?

A. Sure.

Q. Thank you. 

MR. VALDES: Do you want to take a break? 

MR. MERKEN: I have one more segment, if 

that's okay with you. 

MR. VALDES: That's fine. 

BY MR. MERKEN:

Q. If the City of Miami were to hold a special 

election for all five City Commissioners in the 2024 -- 

in November of 2024, would that change any of the 

answers that you've given so far this morning about what 

that process would look like?

A. No, but I will take the opportunity to 

reiterate a couple of things.

Q. Please. 

A. My request, in order to have that happen with 

as little burden to my department, is to, again, have a 

finalized, non-appealable map completed by March 31st, 

so that we can do all of our work seamlessly and 

transition into proper election preparation, but, then, 

the other really important thing is that candidate 

qualifying must end no later than August 23rd. 

Q. Okay. I think you've answered this, but just 

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so I'm clear on reprecincting, reprecincting has already 

occurred for the November 2024 election, for all of the 

offices that are being elected in November of 2024?

A. Yes. 

Q. If the City of Miami were to hold a special 

runoff election for the City Commission in late November 

2024, after the 2024 general election, what would that 

process look like, from the County's perspective, given 

the work that it will already be doing for the November 

2024 elections?

A. Thank you for that question. So my request 

will be that the runoff election not be conducted any 

sooner than four weeks after. I need at least four 

weeks. There's significant post-election stuff that is 

required by many Statutes after a presidential election, 

and so I really need additional time to prepare for this 

election.

Q. You said, at least four weeks. What would be 

your ideal time for a runoff election, after the 

November 2024 election?

A. I would say, four or five weeks is plenty -- 

not plenty, but four or five weeks is adequate.

Q. Is there any difference in cost to the City if 

there is one City Commission special election -- excuse 

me, a special election for one City Commission seat 

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versus two, versus four, versus five?

A. Cost-wise? 

Q. Yes. 

A. Yes.

Q. What is that difference in cost, approximately?

A. Well, the election that we had for them for 

District 2 earlier this year was 176,000.

Q. So -- 

A. So, depending, you know -- 

Q. Would you just multiply that by the number 

of -- 

A. More or less, yes.

Q. Okay. Would it be a burden on your office to 

hold a special election in November of 2024 for the 

Miami City Commission?

A. With the presidential? 

Q. Yes. 

A. As long as all of my deadlines are adhered to, 

we will approve that.

Q. Okay. 

MR. MERKEN: You want to take a break? 

MR. VALDES: Yeah. 

MR. MERKEN: All right. It's 11:15. Come 

back at 11:20, please. 

(Short recess taken.)

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BY MR. MERKEN:

Q. Okay. I want to go over a few things that we 

talked about before the break. First, you're confident 

that your office can effectively and properly administer 

a special election, if you receive the maps by the dates 

you provided?

A. The special elections you're referring to is 

piggybacking onto the -- 

Q. November 2024. 

A. Then, yes.

Q. You had mentioned that zero split precincts and 

a new map would make it easier to administer. If there 

was zero split precincts in a new map, would that push 

the date back by which you could receive a new map and 

still effectively administer the election?

A. I'm not willing to do that, because I just 

don't know how much work is going to be required right 

now. So I would hope that those deadlines would still 

be respected.

Q. Is there any circumstance which would result in 

pushing those deadlines back, beyond what you've 

provided?

A. No. Simply because I need to have this 

completed in advance of preparing for the presidential 

election cycle.

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Q. I wanted to make sure I understood your 

testimony about the per district cost of running 

elections, because I may have gotten a little confused. 

Approximately what is the per district cost for running 

a special election?

A. So I don't know if you tried to do some math, 

by multiplying out or something, which is what threw you 

off. It's not really a per district, right. What I 

have in front of me and what I've been discussing is 

based on the historical elections that the City of Miami 

has had, right. So, for District 2, I don't have, off 

the top of my head -- I don't know how many days of 

early voting, how many sites, right. So these are all 

variables that would affect the cost. 

When you ask me per district, this was just 

this year and these were actuals, so that's why I can 

give you that, right. The standalone full city cost 

that I gave you, also, again, were based upon, you know, 

what we're estimating with the early voting schedule, 

and so, you know, I don't think it's that easy to just 

go ahead and multiply it out.

Q. I appreciate the clarification. 

A. Some districts may have more Vote-by-Mail 

voters than others, and then that would affect postage, 

right. There's just some nuances in there that would 

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affect it, but these are estimates that I'm comfortable 

with now, that could be up or down just based upon 

circumstances.

Q. Sure. 

And if you don't mind, if we could just go over 

them for my edification one more time. 

A. Yeah. 

Q. If you could just kind of run through them, 

please. 

A. Okay. So, to piggyback on a County-wide 

election, we're estimating about 115.000. Should a 

runoff, after that piggyback, become necessary, no less 

than four weeks after the County-wide election, because 

no early voting is going to be available for that, it's 

$507,000. A standalone election, at some other agreed 

upon time, not in conjunction with a County-wide, using 

the early voting model from the past, we're estimating 

at about 805,000. And, then, if the runoff election is 

conducted in just a few weeks after the election, early 

voting is limited, so it's 606,000. So it went down a 

little bit. 

And, then, yeah -- the District 2 election was 

176,000. 

Q. So, the piggyback, the 115,000, that would be 

the cost for the entire City, if all five Commission 

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Districts were up -- or four Commission Districts, it 

would be approximately 115,000?

A. Yes.

Q. That is helpful for that. Thank you for the 

clarification on that point. 

A. And just so you understand, it's because we're 

already training the poll workers. We're already 

setting up the precincts, right. We're already doing 

all of these things anyway, and so that cost is just 

associated with them.

Q. Is there a different polling place for each 

precinct?

A. No. In some polling places, there are more 

than one.

Q. How does that work?

A. Well, you know, some precincts are just created 

really small, right, not out of our discretion, it's 

just the way -- I had described all of the various 

district boundary lines dropping on top of each other. 

Sometimes a precinct is created and it's really small, 

maybe a hundred voters, 200 voters. We're not going to 

have a polling place set up just for a small number of 

voters, when we know a percentage of them are not going 

to vote at all, a percentage of them are going to 

Vote-by-Mail, and a percentage of them are going to vote 

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early, and so now we have -- just a random number -- 50 

people showing up to vote on election day. We're not 

going to set up an entire poll for that. 

So we make these decisions, to say, okay, we'll 

go ahead, and, you know, put you in a neighboring 

polling location, that fits our other criteria, and, 

therefore, that particular polling location may have 

more than one, and that's how we do it.

Q. Are there polling places that would have more 

than two precincts?

A. There are a few.

Q. More than three precincts?

A. I think, with three precincting, we've dealt 

with that. I think we're at three or less.

Q. Okay. 

A. Yeah. 

Q. So you would never do four?

A. I don't know about never.

Q. It would be unlikely that the County would put 

four precincts in one polling place?

A. I would like to look at our list, before 

answering that, but it would be uncommon.

Q. Are there any polling places that are a single 

precinct?

A. Yes.

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Q. How does that decision, whether to have 

multiple precincts in one polling place or one precinct 

for one polling place work?

A. It's all based upon the dynamics of that 

particular polling location. So I don't like changing 

polling locations, right. My preference would always be 

to send people to the same place they've always been 

voting at forever, because people are a creature of 

habit, and they usually just go to the same place 

they've always gone to, which is another reason why I 

don't like making any changes between August and 

November. It is a set. So where you went in August, 

you know exactly where to go in November. 

So we look at each polling location uniquely, 

and we look at its size, parking, the amount of power 

and the number of people that we want to send there, can 

it accommodate it, and if there's a precinct with 3,000 

people, can that polling location accommodate them? 

Yes, we have some precincts that have like 5,000 people 

in them, but it's a larger facility, right, and so it's 

all just based upon volume turnover assumptions and can 

the polling place accommodate it. They're not all 

created equal, and so we go one-by-one, polling place by 

polling place, precinct by precinct, and start making 

the decisions about which ones are going to be a single, 

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because it's big enough and we don't want to put too 

many people there, or is it a couple of small ones, and 

so, you know -- and the polling location can accommodate 

it, and does it not make financial sense to have one for 

each of them, and so all of that goes into the analysis.

MR. MERKEN: Would you please mark this as 

Plaintiffs' 82-23?

(Thereupon, Plaintiffs' Exhibit Number 82-23 

was marked for Identification.) 

BY MR. MERKEN:

Q. I have handed you what I'll represent is the 

City's 2022 map for the Miami of City Commission, which 

has been marked as Plaintiffs' Exhibit 82-23. Are you 

familiar with this map?

A. I have seen this map, and if that's what you're 

representing, then, yes, this is what we would have been 

provided and was part of our reprecincting plan.

Q. When did the Elections Department receive this 

map?

A. I'm not sure if I recall what month. I want to 

say it was May, but I'm not sure.

Q. May of -- 

A. -- '22.

Q. May of 2022 -- 

A. Yeah.

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Q. -- approximately?

A. I think.

Q. From whom did the County receive this map?

A. From the City Clerk.

Q. And you testified earlier that's the normal 

process for receiving a map, right?

A. Yes.

Q. What steps did the Elections Department take, 

after receiving this map in or around May of 2022?

A. So we were waiting for them, because we were, 

you know, little by little getting all of the other 

jurisdictions' redistricting maps. So I had mentioned 

earlier, right, it's Congressional, State House, State 

Senate, County Commission, School Board, so that we 

could do one holistic reprecincting, and so, you know, 

once we got all of the varying district lines, that's 

when we started to put together the County-wide 

redistricting plan and then the subsequent reprecincting 

plan.

Q. Did the County receive GIS or shapefile data 

with this map?

A. See, I would have to go back and confirm with 

my staff. I mean, I think the answer is, yes, because 

that's what we had told them we needed, right, and I 

wasn't told that we didn't receive the things that we 

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needed from the City.

Q. Fair enough. 

A. Yeah.

Q. Did there come a time when the Elections 

Department learned that this map would not be used for 

the November 2023 elections?

A. Yes.

Q. When was that?

A. So that was in the end of July, I believe. I'm 

sorry, I don't know the dates off the top of my head.

Q. From whom did the County find out that this map 

would not be used?

A. From my attorney.

Q. What did the County do, after finding out that 

this map would not be used for the November 2023 

election?

A. So, what I recall is that we had the 2022 map, 

we had the 2023 map, right, and then we were told -- 

Q. We haven't gotten to the 2023 map. 

A. Oh, okay. 

Q. I wanted to walk through between finding out 

that this map would not be used -- 

A. Okay.

Q. -- and we'll get to that, but what happened 

after the County found out that this map, the 2022 map, 

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would not be used?

A. I don't recall what we did after this one. I 

have a clear recollection of what happened, you know, 

after that, yeah.

Q. Okay. We'll get to that in just a moment. 

A. Okay. 

 MR. MERKEN: Would you please mark this as 

Plaintiffs' 82-37?

(Thereupon, Plaintiffs' Exhibit 82-37 was 

marked for Identification.)

BY MR. MERKEN:

Q. I have handed you what's been marked 

Plaintiffs' Exhibit 82-37, which says "P4 - Plaintiffs' 

Map 4," and I'll represent to you that this is the 

remedial map that the U.S. District Court for the 

Southern District of Florida ordered the City of Miami 

to use to remedy the 2022 map that was enjoined. Have 

you seen this map before?

A. Yes.

Q. When did you first see this map?

A. I don't recall when I first saw it.

Q. How did the County receive this map?

A. And so maybe I misspoke on the other one, 

because I think maybe I was actually referencing this 

one. So we were instructed to use this one, right. I 

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didn't receive that information from the City, but my 

department received it from my attorney.

Q. Should the County have received that 

information from the City?

A. We had asked them for it, because, again, we 

were waiting for direction from them on which map we 

were going to be using for their November 2023 election, 

so we did request it from them, and, you know, we were 

expecting it, so that we could proceed.

Q. And the City never provided it?

A. They did not. They did not.

Q. When you received this map, did you receive any 

other data, like shapefiles, with the map?

A. I know you've asked me that question a couple 

of times. I just don't recall what was in the 

attachments that we received regarding shapefiles.

MR. MERKEN: Could you mark this as 

Plaintiffs' Exhibit 2, please? 

(Thereupon, Plaintiffs' Exhibit Number 2 was 

marked for Identification.)

BY MR. MERKEN:

Q. I have handed you what has been marked as 

Plaintiffs' Exhibit 2, which is the City of Miami 

Emergency Motion to Stay the District Court's Order, 

which was dated July 31st, 2023, and it was filed in the 

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U.S. Court of Appeals for the Eleventh Circuit. Have 

you seen this document before?

A. Give me a minute.

Q. Please. 

A. So, yes, I have seen it.

Q. When did you first see it?

A. I was actually just reviewing this the other 

day in preparation for this, because I wanted to look at 

the differences in the maps, to refresh my memory.

Q. Had you seen this before you had began 

preparing for this deposition?

A. No.

Q. If you could turn to Page 25, please. Near the 

bottom of the page, and I'll read this, to confirm that 

it is correct, the brief states, "The Order," which I am 

parenthetically stating refers to the District Court's 

Order, quotes, "throws out the core of districts for the 

entire redistricting plan that have been in place since 

1997 and draws an incumbent out of his district. This 

change is sweeping and disruptive." Did I read that 

accurately?

A. Yes.

Q. If you could please refer back to Exhibit 

82-37, which is Plaintiffs' Map 4. 

A. Okay. 

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Q. Do you agree with the City's statement that 

this map, quote, throws out the core of districts for 

the entire redistricting plan?

A. I can't answer that.

Q. Why not?

A. I -- maybe you should elaborate on your 

question.

Q. I'm just asking, the City has argued that this 

map, Plaintiffs' Map 4, throws out the core of the 

districts for the entire redistricting plan that's been 

in place since 1997. So my question is, if the 

Elections Department agrees that Plaintiffs' Map 4 

throws out the core of the districts that have been in 

place since 1997?

A. And where -- I mean, I think I have to refer to 

the 1997 map to answer that. 

Q. You can also -- 

A. I'm not -- I'm sorry, go ahead.

Q. No, please. 

A. No. No. No. Go on. 

Q. That's fair. 

A. Okay.

Q. Does the County agree that Plaintiffs' Map 4 

would be, quote, sweeping and disruptive? 

A. I mean, I just don't -- in what regard? I 

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don't know if that's a question for me to answer. 

Disruptive how? 

Q. In administering the elections. 

A. So, regardless of the map that the Court seems 

to find lawful, we will implement that. You know, I 

don't know that my opinion about the map or the 

districts or how disruptive it is to voters, you know, 

is -- that's not for me to say. In order for us to be 

able to conduct the election, we're fine with any map 

that the Court finds to be lawful, as long as the 

deadlines are adhered to.

Q. I appreciate that clarification. 

A. Yeah. 

Q. My question about the sweeping and disruptive 

language is more directed at the County. 

A. Okay. 

Q. Does the County Elections Department believe 

that this Plaintiffs' Map 4 would have been sweeping and 

disruptive to the County to administer in elections 

moving forward?

A. We will be able to make the changes and notify 

the voters in time for the election.

Q. Okay. 

MR. MERKEN: If you could please mark this 

as Plaintiffs' Exhibit 3. 

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(Thereupon, Plaintiffs' Exhibit Number 3 was 

marked for Identification.)

BY MR. MERKEN:

Q. I've handed you what has been marked as 

Plaintiffs' Exhibit 3, which is the City of Miami's 

Response to the Emergency Application to Vacate the 

Eleventh Circuit Stay filed in the Supreme Court of the 

United States on -- the date is actually not on the 

brief. I'll confirm the date, but I am representing to 

you that this is the brief that the City filed in the 

Supreme Court. 

A. Okay.

Q. Have you seen this document before?

A. No.

Q. If you could, please turn to Page 6. 

MR. VALDES: Counsel, are you using the 

pagination at the bottom of the document, Page 

6? 

MR. MERKEN: Yes. I may have done the 

pagination on these, yeah, which is why I am 

not quickly finding what I'm looking for. I 

apologize. 

BY MR. MERKEN:

Q. I'm sorry. 

A. No problem. 

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Q. We're going to set that aside. My apologies 

about that. 

As of August 1st, 2023, did the County 

Elections Department have a detailed map with the exact 

district boundaries it needed to implement, the 

court-ordered map, for the 2023 elections? 

MR. VALDES: Objection to the form. When 

you say, "Court-ordered map" -- 

BY MR. MERKEN:

Q. I'm sorry, Plaintiffs' Exhibit 82-37. 

A. Okay. 

Q. I'm sorry, Plaintiffs' Map 4. 

A. Okay. 

Q. As of August 1st, 2023, you said the County had 

this map?

A. Yes, we did have this map.

Q. And the County had the data it needed to 

implement this map?

A. To my knowledge, we did, yes.

Q. Would the County have had to start from scratch 

with this map in implementing it for the elections? 

MS. FELDMAN: Object to the form. What 

election? 

MR. MERKEN: The November 2023 elections.

THE WITNESS: And so what do you mean by 

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starting from scratch?

BY MR. MERKEN:

Q. I'm going to represent to you, the City has 

said the County would have to start from scratch, which 

would add confusion and delay to the election process, 

if the County were to implement Plaintiffs' Map 4. 

A. So, I mean, starting from scratch is not a 

term -- so we had the City's map, right, then we were 

provided the Plaintiffs' map, and then the City's map, 

again, officially, from the City. There were a few days 

in time where we were actually able to do some 

preliminary work on both maps, because we didn't have a 

choice, right. We had given a deadline, that we were 

hoping was going to be respected, again, to be able to 

do everything in a very methodical, orderly and 

sequential order, that's necessary to get it all 

completed, and so we were in a position where we were 

like, okay, let's do some assessment on both maps, to 

get a little bit of a head start, while we wait to see 

which one is going to be final, and so there were some 

preliminary steps that were done on the Plaintiffs' map, 

as well as the City's map, waiting to find out from the 

Court what the ultimate decision was going to be. 

So, if this one was upheld, if that's the right 

term to use here, then, you know, there were several 

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steps that we had started, if that answers your 

question.

Q. It does. It does. Thank you. 

At that point in time, you had also received 

the City's 2023 map, right?

A. Right.

Q. Because you testified that you were working on 

both sets of maps to prepare to implement one or the 

other? Yes?

A. Yes.

Q. Okay. The amount of work that had to be done 

to implement the City's map -- the City's 2023 map, and 

the amount of work that had to be done to implement 

Plaintiffs' Map 4, was that the same amount of work for 

one map or the other map?

A. So, once we realized what the impact of each 

was going to be, are you asking about the work that 

would then succeed that, or in those preliminary stages? 

Q. Both, and we can break those down. So you had 

said that you had started -- the County had started to 

do preliminary work on both, Plaintiffs' Map 4 and the 

City's 2023 map. 

A. Uh-huh.

Q. What I'm trying to get at is, the amount of 

work that would have had to be done for either map, 

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would that have been the same work that would have had 

to be done if the County had been told, we're 

implementing the City's 2023 map or Plaintiffs' Map 4?

A. So my staff has represented that the 

Plaintiffs' map actually would have taken a bit less 

time for us to do, than the City's map, because of 

something that I had alluded to earlier on, which is 

that the district -- and I don't know if this was 

coincidental or if it was taken into account in the 

front end, but what was happening is that the district 

lines -- the new district lines, the proposed district 

lines, took into consideration full precincts. 

And so, what that was going to require on our 

end, in the system, was to just take the district 

boundary lines and move them over, to just change where 

the precincts were going to lie. So that the precincts 

that were in District 1, let's say, now they're in 

District 2, whereas -- and so that's work, of course, 

steps within our system to make sure that all of the 

street ranges were done properly, and, you know, all of 

our quality assurance and all of that, that I mentioned 

earlier. All of that still has to be on the system, but 

not as much of the field work of identifying polling 

places, and it didn't have as big of an impact on voters 

moving to new polling locations. So that ended up 

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being, you know, less work on us, whereas the City's map 

split more precincts, and so not only did it take all of 

the work in the system of, again, moving all of the 

street ranges and doing all of the things that we need 

in our various systems, but it also then required us to 

do the additional polling place work, of where are we 

now going to move all of these people. I hope that was 

clear. 

Q. Crystal.

Were there any other differences from the 

County's perspective implementing Plaintiffs' Map 4 over 

the City's 2023 map? 

A. Maybe you can elaborate. 

Q. Sure. 

You gave examples of where the Plaintiffs' map 

was more cognizant, my words, not yours, of the 

precincts, and the City's map split more precincts, 

which required more on the ground work. Were there 

other differences, from the County's perspective, in the 

work it would take to implement one map over the other 

map?

A. I don't know what else to add to that.

Q. Okay. 

MR. MERKEN: Mark this as Exhibit 13, 

please. 

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(Thereupon, Plaintiffs' Exhibit Number 13 was 

marked for Identification.)

MS. FELDMAN: Just to be clear, have these 

been disclosed, the extent of the documents 

that you're providing, in the Rule 26 

disclosures? 

MR. MERKEN: They're all public files, so I 

presume so. 

MS. FELDMAN: Okay. 

BY MR. MERKEN:

Q. I'm handing you what's been marked as 

Plaintiffs' Exhibit 13, which is a letter dated August 

2nd, 2023, to the Clerk of Court of the U.S. Court of 

Appeals for the Eleventh Circuit, and it says, "Citation 

of Supplemental Authority in GRACE, Inc, versus City of 

Miami," signed by Nicholas Warren of the ACLU. I'm 

going to represent to you that this was filed in the 

Eleventh Circuit as part of the appeal process. If you 

could turn to page 2. 

This is a tweet or an "X," I'm not sure which 

one we're calling it now, from Christina Vazquez, who 

says, and I'm going to quote this, for the record, it 

says, "@MDCElections spokesperson confirms requested 

from the City a copy of the map the majority of the 

Commissioners approved in June. We did ask for the maps 

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Case 1:22-cv-24066-KMM Document 166-1 Entered on FLSD Docket 01/29/2024 Page 88 of

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so that we can do certain preliminary work with both 

sets of maps while waiting for an order from the 

Appellate Court." Did I read that correctly? 

A. Yes.

Q. And that was on August the 2nd, 2023?

A. Uh-huh.

Q. Who gave that statement, if you can recall?

A. I would be guessing, because, I mean, at that 

point in time, I only had one spokesperson, but I don't 

know for sure.

Q. Okay. Who was your one spokesperson at that 

time?

A. Robert Rodriguez.

Q. So, as of August 2nd, 2023, the County could 

have implemented either map?

A. Yes.

MR. MERKEN: Mark this as Exhibit 5, 

please.

(Thereupon, Plaintiffs' Exhibit Number 5 was 

marked for Identification.)

THE WITNESS: I feel like now is a good 

time to put on the record that part of the 

reason that we were able to do this, is because 

I had two very experienced GIS specialists at 

the time. There was somebody that worked under 

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Xavier, who I had mentioned earlier, who is no 

longer with the department, and so now I have 

somebody, who is relatively new, that just 

started in that role, and so I don't want to 

misrepresent to the Court that this type of 

activity, where I'm on a dual track, can 

continue, right, which is why I continue to 

reiterate the importance of us getting a 

finalized map, one time, starting from Step 1, 

all of the way down to 37, as soon as possible, 

just to make sure that we do it properly and 

accurately.

BY MR. MERKEN:

Q. Understood. 

I've handed you what's been marked Plaintiffs' 

Exhibit 5. This has a Bates stamp range. Just for the 

record, the Bates stamp range is COM24066 -- 

A. I'm sorry, where are you? 

Q. I'm sorry, I'm just reading the Bates stamp, 

for the record. 

A. Oh, okay. 

Q. COM24066-003283. 

MS. FELDMAN: Again, I don't think that 

these were included in the Rule 26 disclosures, 

so just to the extent that they weren't, we 

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would object, on that basis.

MR. MERKEN: Noted. 

BY MR. MERKEN:

Q. Do you recognize this document?

A. Okay. Give me a second.

Q. Please. 

A. Okay. Yes, I do recall it now.

Q. And what is this document?

A. Okay. Let me see. I want to see about the 

shapefile here.

Q. Sure. 

A. Okay. Yeah, it doesn't specifically mention -- 

okay, so this is from Nicole, who I don't know, which is 

why I didn't reference her earlier. I think she might 

be new. I'm not sure. 

So this is an e-mail to me, saying that we are 

to proceed with using the City's map.

Q. Okay. What happened after your office received 

this map on August 1st, 2023?

A. We started doing the same, you know, 

preliminary work that we were doing with the Plaintiffs' 

map, right, which is, you know, about four or five of 

the first initial steps that we were able to do.

Q. What was the format of the map that was sent 

along with this?

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A. So that's the part that I just don't recall.

Q. Okay. Did the County receive any other -- has 

the County received any other correspondence or 

communication from the City regarding implementation of 

the 2023 map?

A. Since this? 

Q. Yes. 

A. Not that I came across in my review.

Q. Okay. You can set all of these aside. 

A. All right. 

MR. VALDES: Counsel, with respect to 

Plaintiffs' Exhibit 5, do you have the original 

e-mail, with the attachments associated with 

them? 

MR. MERKEN: I do, in my e-mails, because I 

was copied on it. This was what was produced 

to us in discovery, so this is what we were 

using, but we can go through the e-mails -- 

MR. VALDES: Okay. We'd be happy to 

provide the attachment, so you can see what 

format they were in. 

MR. MERKEN: I appreciate that. We will 

take you up on that. 

BY MR. MERKEN:

Q. I just have a handful of questions about the 

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administration of the February 2023 special election, 

because that was not involved -- the February 2023 

election was not impacted at all by this litigation, 

right?

A. Right.

Q. So how did the February 2023 special election 

operate, from the County's perspective, in terms of 

timing and administration?

A. Really, no differently than what I've already 

described, right. I mean, we were put on notice that a 

vacancy occurred, and, therefore, a special election was 

going to be necessary. My recollection is that the 

vacancies do have a bit of a tighter timeline, which is 

what I also alluded to earlier, right, but it's, you 

know, one district within the City of Miami. As long as 

the timing wasn't in the way of a County-wide or 

something like that, you know, that we work with 

everybody, because of the Charter. The Charters are 

strict. Sometimes they don't have that flexibility. 

And so I think we did that in a bit less time, 

because the timing of it worked out for us, but every 

step that I've already described, would have also, you 

know, applied to that election.

Q. And you mentioned the cost, but just so it's in 

the same place in the transcript, that was approximately 

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$176,000?

A. Yes. Uh-huh.

Q. With respect to the November 2023 election for 

the Miami City Commission, what steps are you taking to 

prepare for that election?

A. Well, I mean, for us, the election is here. We 

just placed Vote-by-Mail ballots in the mail yesterday, 

so people are voting in that election, and so, you know, 

at this point, our polling places are confirmed, our 

poll workers -- I believe we're still in the process of 

training our poll workers. Vote-by-Mail ballots are 

out. We'll continue to process those are they are 

coming in. Their equipment testing is coming up 

shortly, which is a public test, for the candidates and 

the public, to come in and observe that we coded 

everything properly and that the machines are working, 

and early voting begins on October 28th. 

So, you know, ramping up with temporary workers 

and making sure we're ready for that, to get those 

locations set up, and, you know, making sure that we 

have the proper number of poll workers, sending out 

those assignment letters, so they know where to show up 

on election day, and, you know, their canvassing board 

will be coming in to meet, I'm sure, in the next week or 

two, to start looking at Vote-by-Mail ballots, and then 

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tabulate results and certify the election.

Q. And then start all over again?

A. Yeah.

Q. How much, if you know, is the November 2023 

election going to cost the City of Miami for the County 

to administer?

A. That's a three district. So I didn't actually 

ask for that estimate from my staff.

Q. Okay. And like with other elections, if 

there's a runoff, that would increase the cost?

A. Right. Depending on how many voter runoff, 

right.

Q. Right. 

Okay. I just have a handful of questions about 

the relationship between the City and the County. We 

covered some of this, but just so that I'm clear on it 

all. 

Is there any written agreement between the City 

and the County with respect to elections administration?

A. Formalized, no, but, you know, there's a lot of 

correspondence by e-mail back and forth about these 

things, and like I said, the questionnaire that I spoke 

to. You know, we receive Resolutions from them, that 

their Board has called for certain things, but a formal 

agreement, formal contract, no.

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Q. Does the City timely pay the County for its 

elections administration?

A. To my knowledge, yes.

Q. Has there ever been a time when the City has 

refused to pay the County the full amount requested?

A. Not to my knowledge, no.

Q. How would the Elections Department assess the 

quality of the relationship between the City and the 

County, with respect to elections administration?

A. I think we have a great relationship with the 

City Clerks there.

Q. Does that depend on whether it's a regular 

election or special election?

A. No.

MR. MERKEN: Okay. Do you want to take a 

five-minute break? I think we're done, but I 

just want to -- 

MR. VALDES: Yeah. 

(Short recess taken.)

BY MR. MERKEN:

Q. Okay. I just have one or two questions about 

2025. 

A. Okay.

Q. There are currently three City Commission 

districts up for election in 2025, right?

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A. Yes.

Q. Would there be any additional burden to the 

County, to administer that election, if all five 

districts, instead of the three districts, were up for 

election in 2025?

A. No.

Q. Would there be any additional cost?

A. Yes. Cost-wise, yes.

Q. And what would those additional costs be?

A. It would be associated with, you know, the 

additional training -- the additional temporary workers 

that we would need, the additional poll workers that we 

would need, the additional polling places that we would 

need, but I think the mayoral race is on the 2025 

election.

Q. That's my understanding, as well. 

A. Okay. So, then, if that's the case, it's 

coming to me now, then there would be no burden at all, 

and it wouldn't affect the cost, because we're already 

doing those things, anyway, for the full City.

Q. That's all of the questions that I have. Just 

in closing, has all of the testimony you gave today been 

truthful?

A. Yes.

Q. Is all of the testimony you gave today 

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complete?

A. Yes. I believe so, yes.

Q. Do you wish to correct any statements that you 

made?

A. No.

MR. MERKEN: I have no further questions. 

CROSS EXAMINATION

BY MS. FELDMAN:

Q. I'm going to have just a few questions. If you 

can give me a moment to just gather my thoughts and just 

scroll back here. 

A. Okay. 

Q. Okay. So, again, just a couple of questions, 

very briefly. I think that you had testified earlier 

that implementing the Plaintiffs' Map 4, before the 

November '22 election, would have required somewhat less 

work than implementing the City's map, to the extent 

that it aligned better with the precincts; is that 

correct?

A. Yes. 

MR. VALDES: Object to the form. I believe 

you said the 2022 election. I think you meant 

the 2023. 

MS. FELDMAN: I did. Thank you very much. 

THE WITNESS: Sorry. So, yes, that is what 

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the GIS people have represented, correct.

BY MS. FELDMAN:

Q. Okay. And just to clarify, and if you could 

look at Plaintiffs' Map 4, and then the '22 enjoined 

map, which was Plaintiffs' Exhibit -- I don't recall 

what the number off the top of my head -- 82-23 and 

82-37. 

A. Okay.

Q. So I just want to clarify, in terms of -- does 

your testimony in any way relate to how implementing one 

map versus the other might impact voter confusion in 

different districts? In other words, would the 

implementation of one map -- or Plaintiffs' map create 

more or less voter confusion than the implementation of 

the City's map?

A. Had we done one or the other, is that your 

question? 

Q. Yes. 

A. I mean, that's very difficult to say, but in 

the Plaintiffs' map, by moving just the district lines 

in certain precincts, those people -- those voters, they 

would have been able that stay with their same precinct 

number, in their same polling location, right. So, in 

the City's map, there was more voter movement, because 

the new line being -- by splitting a precinct, we had 

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to, you know, leave some and move some, and so more 

voters moved with the City of Miami's map, but, you 

know, we took it very seriously, with our outreach, 

leading up to the election, and we're going to continue 

to do this for the entire County, because there's been 

reprecincting and redistricting all over Miami-Dade 

County, and notify all voters of the changes, in every 

way. So, you know, regardless, voters were notified by 

mail that there was a change, so hopefully they will not 

be confused.

Q. So, in terms of -- you know, other than the 

precinct location that the voter is going to, in terms 

of voter confusion, you know, what candidates are on the 

ballot, what district am I located in, if Plaintiffs' 

map -- for example, District 1, if Plaintiffs' map moves 

more voters out of District 1 and into a different 

district -- if the City's map retains a greater core of 

District 1 than the Plaintiffs' map, you're not speaking 

to whether that would create more or less confusion, are 

you?

A. No, I'm not representing that.

Q. And the same thing with respect to candidates 

being able to canvass and to reach out to their voters, 

if the lines change more in the Plaintiffs' map, you're 

not speaking to whether it would prejudice or cause 

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confusion among the candidates, are you? 

A. No, I'm not making those kinds of claims, no. 

For my microcosm and this larger issue, it's all about 

just doing things in a timely manner, so voters can be 

appropriately notified, right. That's one of the 

reasons why our deadlines are what they are, so we can 

do our part to do outreach, and, then, you know, the 

City can do the outreach to the candidates, so that 

they're clear -- or potential candidates, so that 

they're clear.

Q. Understood. Thank you. 

I think that's all of my questions -- and just 

to clarify, that would be with respect to every -- so I 

used District 1 as an example, but you have the same 

testimony as to District 2, 3, 4 and 5?

A. Yes, I do.

MS. FELDMAN: Thank you. 

MR. MERKEN: Anything for you? 

MR. VALDES: Nothing for us. 

MR. MERKEN: We're good. Thank you. 

MR. VALDES: We'll read. 

(Thereupon, the reading and signing not 

being duly waived, the deposition was concluded 

at 12:20 p.m.)

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_______________________

DEPONENT

Sworn to and subscribed before me this _____ 

day of __________________, 2023.

 

_______________________

NOTARY PUBLIC

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Case 1:22-cv-24066-KMM Document 166-1 Entered on FLSD Docket 01/29/2024 Page 102 of

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CERTIFICATE OF OATH

STATE OF FLORIDA :

 SS

COUNTY OF MIAMI-DADE:

I, NIEVES SANCHEZ, Court Reporter, and a 

Notary Public for the State of Florida at Large, do 

hereby certify that CHRISTINA WHITE personally appeared 

before me and was duly sworn.

WITNESS my hand and official seal in the 

City of Miami, County of Miami-Dade, State of Florida, 

this 23rd day of October, 2023. 

__________________________

NIEVES SANCHEZ

Notary Commission Number HH 385498

My Notary Commission expires August 11, 2027

REPORTER'S DEPOSITION CERTIFICATE

STATE OF FLORIDA :

 SS 

COUNTY OF MIAMI-DADE:

I, NIEVES SANCHEZ, Court Reporter and a Notary 

Public for the State of Florida at Large, do hereby 

certify that I was authorized to and did report the 

deposition of CHRISTINA WHITE; that a review of the 

transcript was requested; and that the transcript is a 

true and complete record of my stenographic notes. 

I further certify that I am not a relative, 

employee, attorney, or counsel of any of the parties, 

nor am I a relative or employee of any of the parties' 

attorney or counsel, nor am I financially interested in 

the action.

DATED this 23rd day of October, 2023.

_________________________

NIEVES SANCHEZ

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Case 1:22-cv-24066-KMM Document 166-1 Entered on FLSD Docket 01/29/2024 Page 103 of

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BAILEY & SANCHEZ COURT REPORTING, INC.

(305) 358-2829

October 23, 2023 

Christina White

c/o Michael B. Valdes

Geri Bonzon-Keenan, County Attorney

111 N.W. First Street

Suite 2800

Miami, Florida 33130

RE: Grace, Inc. vs. City of Miami

Dear Ms. White 

The transcript of your deposition, taken in the 

above-styled cause on October 11, 2023, is at my office 

awaiting your examination and signature. PLEASE 

TELEPHONE BEFORE COMING IN so that we may arrange a 

convenient time.

Please be advised that unless I hear from you by 

November 23, 2023, I will forward the original of your 

deposition to the deposing attorney, as though you had 

read and signed your deposition.

IN THE EVENT a copy of the transcript is being sent to 

the witness by counsel, kindly instruct the witness to 

make any changes thereto on a separate sheet of paper 

and refer to the page number and line number which 

corresponds to the change desired. DO NOT MAKE THE 

CORRECTIONS ON THE TRANSCRIPT. If you have any 

questions, please call.

Very truly yours,

NIEVES SANCHEZ

Court Reporter

cc: Christopher J. Merken, Esq.

 Sydney Michelle Fledman, Esq.

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ERRATA SHEET

IN RE: GRACE, INC., ET AL. vs. CITY OF MIAMI 

DEPOSITION OF TODD HANNON

TAKEN OCTOBER 6, 2023

DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE

PAGE # LINE# CHANGE

________________________________________

________________________________________

________________________________________

________________________________________

________________________________________

_______________________________________

_______________________________________

_______________________________________

_______________________________________

_______________________________________

_______________________________________

___________________

SIGNATURE

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