Exhibit 15

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2 IN THE UNITED STATES DISTRICT COURT

 SOUTHERN DISTRICT OF OHIO

3

4 Case No. 1:18-cv-00357-TSB-KNM-MHW

--------------------------

5 OHIO A. PHILIP RANDOLPH )

INSTITUTE, et al., )

6 )

 Plaintiffs, )

7 )

 vs. )

8 )

RYAN SMITH, Speaker of )

9 the Ohio House of )

Representatives, et al., )

10 )

 Defendants. )

11 --------------------------

12

13

14 DEPOSITION OF MARK GRIFFITHS

15 Cleveland, Ohio

16 Thursday, December 6, 2018

17 - - - - -

18

19

20 Reported by:

21 JILL A. KULEWSKY, RPR

22 JOB NO. 151952

23 Thursday, December 6, 2018, 1:00 p.m.

24

25

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2 organization. It falls under the

3 umbrella of the Bishop of Cleveland. At

4 the time that I was there, there were

5 about 800 to 1,000 employees, probably 40

6 or 50 different sites.

7 Q. And what did that organization

8 primarily do?

9 A. Social service. There was

10 chemical dependency counseling, daycare,

11 child care, counseling, employment and

12 training. So a wide variety of human

13 services.

14 Q. And then what was the

15 geographic range? Was it limited to the

16 Cleveland Diocese?

17 A. Yes, which is made up of eight

18 counties in Northeast Ohio.

19 Q. Mr. Griffiths, what is your

20 current address?

21 A. 33137 Hawks Nest Court in

22 North Ridgeville.

23 Q. And how long have you lived at

24 the Hawks Nest Court address?

25 A. 15 years.

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2 Q. Where did you reside prior to

3 the Hawks Nest Court address?

4 A. 3106 Standish Avenue in Parma.

5 Q. And how long did you live at

6 the Parma address?

7 A. I think it was about 26 years.

8 Q. And what county is the Hawks

9 Nest Court address in?

10 A. That is Lorain County.

11 Q. And the Parma address?

12 A. Cuyahoga County.

13 Q. What congressional district do

14 you live in?

15 A. District 7.

16 Q. And do you know who your

17 congressional representative is?

18 A. Bob Gibbs.

19 Q. Is Bob Gibbs a Republican or a

20 Democrat?

21 A. Republican.

22 Q. Mr. Griffiths, when did you

23 first register to vote in the State of

24 Ohio?

25 A. Whenever I was first eligible.

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2 Probably the age of 21.

3 Q. Okay.

4 A. I don't recall exactly when

5 the Constitutional Amendment was passed

6 to make it 18. I think I was 21.

7 Q. Do you know about what year

8 that was?

9 A. I was born in '49, '69, so

10 probably about 1970.

11 Q. Do you remember the first

12 election that you voted in?

13 A. I'm afraid I do not.

14 Q. Did you vote in the most

15 recent congressional election --

16 A. Yes, I did.

17 Q. -- in 2018?

18 And who did you vote for?

19 A. Ken Harbaugh.

20 Q. And did you vote in the 2016

21 congressional election?

22 A. Yes.

23 Q. Do you remember who you voted

24 for?

25 A. Roy Rich.

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2 Q. And backing up, is Ken

3 Harbaugh a Republican or a Democrat?

4 A. Democrat.

5 Q. And is Roy Rich a Republican

6 or a Democrat?

7 A. Democrat.

8 Q. Did you vote in the 2014

9 congressional election?

10 A. I voted in that election, but

11 I believe Bob Gibbs was unopposed.

12 Q. And did you vote for --

13 A. I did not vote. I just didn't

14 vote then for that.

15 Q. When you say you didn't vote,

16 you just left that race blank and voted

17 in the other races?

18 A. Correct.

19 Q. And do you remember voting in

20 the 2012 congressional election?

21 A. I'm sure that I did, yes.

22 Q. Do you remember who you voted

23 for?

24 A. I do not. I believe there was

25 a Democrat who ran. I believe I voted

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2 for that person.

3 Q. And in all these elections

4 that we spoke of from 2012 to 2018, did

5 Bob Gibbs win each of those congressional

6 elections?

7 A. Yes, he did.

8 Q. And do you know the last time

9 you haven't voted? I know you don't

10 remember your first election, but to the

11 best of your knowledge, have you voted in

12 every congressional election for which

13 you were eligible to vote?

14 A. Yes, I did. I'm sure I did.

15 Q. And have you in any election

16 ever voted for a Republican or an

17 independent candidate?

18 A. Yes, I have.

19 Q. And can you tell me about the

20 times that you voted for a Republican or

21 independent?

22 A. I voted for a Republican for

23 U.S. Senate on one occasion.

24 Q. Who was that?

25 A. Rob Portman.

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2 Q. And you've never voted for an

3 independent candidate or third-party

4 candidate; is that correct?

5 A. No.

6 Q. At any level?

7 A. No.

8 Q. And in the future, would you

9 vote for -- in a future congressional

10 race, would you vote for a Republican?

11 MS. ROMERO: Objection to

12 form. You can answer.

13 THE WITNESS: I'm sorry?

14 MS. ROMERO: You can answer

15 the question.

16 A. It's possible.

17 Q. Under what circumstances?

18 A. If I felt a Republican was a

19 better candidate, and if the Democrat, if

20 there is something flawed in that

21 candidate, I would consider it.

22 Q. What would make you consider a

23 Republican a better candidate? What

24 factors?

25 A. Background and experience

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2 compared to who he or she would be

3 running against.

4 Q. In addition to background and

5 experience, do you consider any other

6 factors when you choose the candidates

7 that you vote for?

8 A. Well, certainly I look at

9 their positions on issues and their

10 values and how they align with mine. So

11 more often than not, I'm probably going

12 to lean towards a Democratic candidate

13 because of that.

14 Q. If a Republican candidate or a

15 third-party or independent candidate

16 shared your positions and values, would

17 you vote for that candidate over a

18 Democrat?

19 MS. ROMERO: Objection.

20 Speculation. You can answer.

21 A. It's possible.

22 Q. Mr. Griffiths, have you always

23 lived in the 7th Congressional District?

24 A. No. I think previously before

25 2012 the district had a different number.

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2 A. Yes. Yes.

3 Q. And did you participate in any

4 signature drives other than the members

5 of Indivisible?

6 A. Yes. While we -- each member

7 of our group circulated petitions, but

8 circulating petitions is sort of an

9 individual process, it's not something

10 you really do in a mass or a group. My

11 wife also participated in that, and she

12 and I went to a number of different

13 events and circulated petitions.

14 Q. Do you recall about how many

15 signatures you were able to obtain for

16 Issue 1?

17 A. I'm guessing 3 or 400

18 signatures, something like that.

19 Q. Other than your work with Fair

20 Districts=Fair Elections on the

21 gerrymandering issue, have you done any

22 other work with Indivisible?

23 A. With the Indivisible group in

24 Wellington, we met -- we had a sit-down

25 meeting with Bob Gibbs to talk about our

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2 issues related to health care. So that

3 we did as a group.

4 Q. And how was that meeting

5 organized?

6 A. The head of our Indivisible

7 group was in contact with Bob Gibbs'

8 office in Ashland, and they were able to

9 secure a date and time to meet with him.

10 Q. Do you remember when this

11 meeting took place?

12 A. It was in the first or second

13 week of April 2017.

14 Q. And this meeting was with

15 Congressperson Gibbs himself, correct?

16 A. Yes.

17 Q. And what did you tell

18 Congressperson Gibbs?

19 A. Again, the focus was on health

20 care, and at that time the Republicans

21 were working on an alternative health

22 care plan, and we all had a number of

23 concerns about that, expressed those

24 concerns. That was right around the time

25 that President Trump had made the remark

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2 about health care, who knew it was so

3 complicated, or something to that effect,

4 and with Bob Gibbs we talked about what a

5 complicated issue this was.

6 Toward the conclusion of the

7 meeting, we could see we weren't

8 really -- we weren't getting very far,

9 that he wasn't changing our minds, and we

10 weren't changing his mind on anything,

11 and I suggested to him that given how

12 complicated this was, and I had a strong

13 background in employee benefits and Human

14 Resources, I suggested that I would be

15 willing, if he wanted to pull people

16 together to form kind of a study group,

17 to work on this issue on his behalf,

18 essentially do research, advise, develop,

19 you know, whatever, and that offer was

20 not accepted.

21 Q. Do you know why?

22 A. No.

23 Q. And what did Congressperson

24 Gibbs say to you about his position on

25 health care?

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2 I think to have a district

3 that is in Northeast Ohio, Lorain County,

4 for example, as a whole, right now Lorain

5 County is split into three different

6 districts. So the Democrats are cracked

7 in that instance, and I think it's been

8 done strictly for purposes of maintaining

9 part of its partisan position.

10 Q. I have a few followups to

11 that. You mentioned that Lorain County

12 is split into three districts?

13 A. Yes.

14 Q. Do you think you have a right

15 to live in a district in which your

16 county is whole?

17 MS. ROMERO: Objection to

18 form. You can answer.

19 A. That would be my preference.

20 I don't think it's practical. I do

21 understand that counties, in order to

22 achieve the balance that you need based

23 on population, there's probably going to

24 be some split of counties, but I think

25 that should be minimized.

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2 Q. So you agree that you don't

3 have a right to live in a district in

4 which your county is whole?

5 MS. ROMERO: Objection. You

6 can answer.

7 A. No. I think I have a right to

8 be in a district that is a compact,

9 geologically logical configured district.

10 Q. What is a compact, logical

11 district?

12 A. A district that is compact in

13 terms of size, that respects county

14 boundaries, municipal boundaries to the

15 largest extent possible, and that

16 reflects some community of interest of

17 people in the district.

18 Q. And what community of interest

19 is not in District 7 that should be?

20 MS. ROMERO: Objection to

21 form. Go ahead.

22 A. District 7 is made up of, I

23 don't recall, seven or eight counties,

24 and it goes from urban to rural to

25 suburban back to rural to urban. It's

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2 really a configuration that does not make

3 much sense.

4 When I was circulating

5 petitions on this issue, and, of course,

6 you won't be surprised that nine people

7 out of 10 don't know what gerrymandering

8 is, but when we would show them the

9 congressional map, they clearly, many,

10 many people, most people would look at it

11 and say, "This map doesn't make any

12 sense. This is my district?"

13 And it wouldn't make any

14 difference. We would collect signatures

15 at Lorain Community College. So we would

16 talk to people who were in Jim Jordan's

17 district or Bob Gibbs' district or Marcy

18 Kaptur's district, all these different

19 districts, and people would look at the

20 map and say, "Why is it this way, this

21 doesn't make sense?"

22 So that's what I mean. It

23 just doesn't pass the sense in terms of

24 any kind of logic. I don't think anybody

25 that would design a map would ever draw

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2 District 7 in any -- for any kind of

3 logical reason.

4 Q. What do you think is a logical

5 reason or a logical way to draw a map?

6 A. I would draw it in terms of,

7 again, compactness. So I would start out

8 trying to make sure if Lorain County was

9 a district, and if there weren't enough

10 people in Lorain County to make up a

11 district, then I would add a piece of

12 Cuyahoga County or maybe Medina County

13 where it closes in on Medina County, but

14 somehow make it compact so that it's not

15 running its way through seven or eight

16 different counties.

17 Q. Part of Medina County is

18 currently in Congressional District 7?

19 A. Right. Yes.

20 Q. Do you know, are there enough

21 people in Lorain County to form a

22 district?

23 A. I would guess not, but I'm not

24 positive of that.

25 Q. I believe you testified that

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2 Q. And if you lived in a district

3 that was compact in terms of size,

4 respected communities of interest, didn't

5 violate any federal laws regarding

6 minority participation but still

7 consistently elected a Republican

8 candidate, do you think you would still

9 have a constitutional claim about that

10 district?

11 MS. ROMERO: Objection.

12 Incomplete hypothetical. Calls for

13 a legal conclusion. You can

14 answer.

15 A. And your question was would I

16 have a claim in that instance?

17 Q. Yes. Would you have a

18 constitutional claim about that district?

19 A. I don't think so.

20 Q. Mr. Griffiths, how do you

21 think you've been injured by the 2011

22 congressional map?

23 A. It has been very difficult to

24 identify candidates willing to take on

25 Bob Gibbs in this case because of how

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2 heavily gerrymandered the district is.

3 It has been difficult to connect with

4 other volunteers just because of the

5 geographic space involved in this, and I

6 believe my vote or my non-vote in support

7 of Bob Gibbs does not really factor into

8 his thinking, and that's how I explained

9 him not being interested in following

10 through on a study group on the medical

11 issue, health care issue.

12 My wife had written to him,

13 and I'm sorry, I don't remember the

14 specific issue, but she wrote to him

15 about, I'll say as an example, concerns

16 about health care, and received a letter

17 back from Bob Gibbs that said something

18 like "Thank you for your concerns about

19 the Farm Bill." And again, I may have

20 the two issues mixed, but it was a

21 complete non-secretory.

22 She shared that response with

23 other members of our Wellington

24 Indivisible group, and a number of them

25 had experienced the same thing.

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2 Q. When you say "the same thing,"

3 you mean the response from Congressperson

4 Gibbs does not match to the --

5 A. Yes, correct. And that said

6 to us that this guy doesn't really care

7 what we think or don't think, whether we

8 vote or not vote. He is in a position,

9 and still is in a position, that he's

10 going to get re-elected. So therefore,

11 the issues that we few Democrats might

12 raise aren't really anything that he

13 needs to respond to.

14 Q. I want to follow up on these

15 injuries that you identified. You said

16 the first was your vote in opposition to

17 Gibbs is a non-issue, and again, you're

18 not contending that your vote is in fact

19 not counted?

20 A. No, I'm not. I'm sure it's

21 counted.

22 Q. When you say "non-issue," what

23 do you mean?

24 A. It's a non-issue to him.

25 Whether or not I support him is not an

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2 form.

3 A. I expect that the Congressman

4 and I would disagree. I wouldn't expect

5 a Congressman to always agree with my

6 views. But I would expect my Congressman

7 to take my views into account and pay

8 attention to them, and I don't think

9 that's going on now.

10 Q. So would an example of a

11 Congressperson taking your views into

12 account be meeting with you to discuss an

13 issue, such as health care?

14 A. Yes, but also being

15 responsive.

16 Q. And Congressperson Gibbs did

17 in fact meet with you to discuss the

18 issue of health care?

19 A. Yes, but was not responsive.

20 Q. And would you agree that it's

21 the responsibility of a Congressperson to

22 represent the views of the majority of

23 voters in their district?

24 A. Yes.

25 Q. And so then Congressperson

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2 Gibbs should be representing the views of

3 the majority of voters in Congressional

4 District 7, which you said are Republican

5 voters?

6 MS. ROMERO: Objection to

7 form.

8 A. Yes.

9 Q. You said that one way that you

10 think that the map injures you is that it

11 prevents you from connecting with other

12 volunteers?

13 A. Yes.

14 Q. How has the map prevented you

15 from connecting with other volunteers?

16 A. It's difficult geographically

17 because of the distances that have to be

18 traveled within the various parts of

19 District 7 that makes it a more difficult

20 challenge.

21 Q. Could you give me an example

22 of an instance in which you've been

23 unable to connect with a volunteer

24 because of geographic distance?

25 A. I was not willing to drive to,

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2 say, Knox County to help with canvassing

3 activities.

4 Q. Did nothing prevent you from

5 driving to Knox County to volunteer?

6 A. No, except for the -- yeah,

7 it's just a difficult thing to do.

8 Q. So it was a choice that you

9 made not to drive to Knox County --

10 MS. ROMERO: Objection to

11 form.

12 A. Yes.

13 Q. -- to volunteer?

14 Is there anything else you can

15 think of other than geographic distance

16 that prevents you from connecting with

17 other volunteers in CD-7?

18 A. No, except for the fact that I

19 think the way the district is drawn,

20 Democrats in District 7 are spread out

21 pretty far from each other, and

22 therefore, what might be a more natural

23 being able to get together with people,

24 it's more difficult to do because we're

25 spread over the seven or eight counties

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2 that make up District 7.

3 Q. Could you think of an example

4 of where you haven't been able to meet

5 with Democrats because of the geographic

6 distance?

7 A. There was a phone banking

8 activity for Ken Harbaugh that was held,

9 I believe it was in Huron County, that I

10 was supposed to participate in, but it

11 was -- the weather was very difficult, it

12 was a day like this, actually coming down

13 worse, but it would have been difficult

14 to make that drive. That's one I could

15 think of off the top of my head that

16 occurred earlier this year.

17 Q. Any other instances in which

18 you've been unable to connect with

19 volunteers as a result of the map?

20 A. That's the one I could think

21 of, yeah.

22 Q. About how far is Huron County

23 from Lorain County?

24 A. I would guess it was about 60,

25 75 miles, something like that.

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2 Q. You said that the 2011 map has

3 injured you in making it difficult to

4 identify candidates willing to run in

5 Congressional District 7. Could you give

6 me an example of a time that you've been

7 unable to identify a candidate?

8 A. Well, 2014 I believe Gibbs was

9 unopposed, there was no one willing to

10 take him on.

11 Q. Did you encourage anyone to

12 run against Bob Gibbs?

13 A. No. But I did hear

14 conversation that nobody in fact was

15 coming forward to do that.

16 Q. But you didn't encourage

17 anyone to run in 2014?

18 A. No.

19 Q. Can you think of any other way

20 in which Congressional District 7 has

21 made you unable to identify candidates?

22 A. I would say in 2016 Roy Rich

23 ran, I've had several conversations with

24 him, and he talked to me about how

25 difficult that was to campaign in that

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2 district because of the size of the

3 district and trying to get around to

4 different people. So I know from

5 personal experience from him that that

6 was very difficult.

7 Q. But nothing about the map

8 prevented him from running against Bob

9 Gibbs?

10 A. No, but the map made it

11 difficult to do.

12 Q. Was there anything about the

13 map that prevented a Democrat from

14 running in 2014?

15 A. Not to my knowledge

16 specifically, except that people saw it

17 as a gerrymandering situation and nobody

18 came forward to do that.

19 Q. And I believe the fourth and

20 final injury you identified as a result

21 of the map is that your wife wrote to

22 Congressperson Gibbs about an issue,

23 maybe health care, and that she received

24 a response from Congressperson Gibbs that

25 thanked her for her concerns about the

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2 Farm Bill; is that correct?

3 A. Yes. It was a non-secretory.

4 I might have the wrong issue.

5 Q. Right. Have you ever written

6 to Congressperson Gibbs and received,

7 we'll call it a mismatched response?

8 A. A mismatched response, is that

9 what you said?

10 Q. Yes.

11 A. No. I could think of one time

12 I wrote to him, and I got a response that

13 responded to the issue that I raised.

14 Q. Do you know what that issue

15 was?

16 A. I wrote to him about the

17 Summit President Trump had in Helsinki

18 with Vladimir Putin and my concerns about

19 that, and he wrote back.

20 Q. Did you ask to receive a

21 response when you wrote to him?

22 A. I don't recall that I did. I

23 might have, I don't recall, but I did get

24 a response.

25 Q. Do you recall what his

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2 attend. So my wife and I attended that

3 meeting in Canton.

4 Q. And during that meeting, did

5 you -- were you able to speak to

6 Congressperson Gibbs?

7 A. I spoke with him. We actually

8 were the first ones there. I spoke with

9 him, just kind of some small talk before

10 the meeting started. He made a joke to

11 the fact that we were the ones that had

12 come the furthest to this meeting, and we

13 actually had to pay a toll to come.

14 The meeting was -- as I came

15 to find out, it was somewhat scripted.

16 The different members of Indivisible had

17 personal stories to share with regard to

18 health care, and I think they had a set

19 period of time, an hour or so, and then

20 each person would tell their story and

21 Gibbs would give some response, and then

22 there was a little bit of back and forth

23 discussion, maybe five or 10 minutes that

24 other people had.

25 Q. Was any topic other than

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2 Canton and one meeting --

3 A. The first meeting I described

4 to you actually took place in his Ashland

5 office.

6 Q. So one meeting in Canton, one

7 meeting in Ashland?

8 A. Yes.

9 Q. The third meeting?

10 A. The third time was not a

11 meeting, but it was in support of an

12 immigration activity, and there was an

13 ask from the HOLA organization within our

14 Invisible group to advocate for a

15 particular immigrant that was facing

16 deportation. That was a matter of just

17 stopping in his office and dropping off a

18 letter.

19 Q. You did not meet with

20 Congressperson Gibbs at that time?

21 A. Correct. I think he was in

22 Washington at the time.

23 Q. Did you speak to an aide?

24 A. I did. They were just

25 surprised we were there and said, "Okay,

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2 Lorain County has a majority of

3 Democratic voters?

4 MS. ROMERO: Objection. Asked

5 and answered.

6 A. I don't know.

7 Q. Then how do you know that

8 Lorain County, the Democratic voters

9 could elect a member of congress?

10 MS. ROMERO: Objection.

11 Mischaracterizes his testimony.

12 A. Because I don't think it

13 necessarily would only be Democrats

14 voting for Democrats.

15 I think -- again, I'm basing

16 this on Sherrod Brown and Betty Sutton,

17 and I could be wrong, but I think most of

18 that district was Lorain County at that

19 time, and they were successful.

20 Q. But you don't know whether or

21 not that district also included Medina,

22 Summit and Cuyahoga Counties?

23 A. I don't recall.

24 Q. Would you prefer a

25 congressional map that would allow you to

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2 elect a Democrat?

3 MS. ROMERO: Objection to

4 form. Incomplete hypothetical.

5 You can answer.

6 A. Yes.

7 Q. Do you think you have a right

8 to a district in which you could elect a

9 Democratic representative?

10 MS. ROMERO: Objection to

11 form.

12 A. I have a right to a

13 congressional district that would allow

14 my vote to matter and it could be

15 competitive, be it Democrat or

16 Republican. I felt like the vote would

17 matter.

18 Q. So you think you have a right

19 to a competitive district?

20 MS. ROMERO: Object to form.

21 A. Yes.

22 Q. What's a competitive district?

23 A. One that is drawn without

24 regard to the partisan nature or to

25 advantage one political party over the

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2 expert to draw an alternative map or

3 remedial map?

4 A. Yes.

5 Q. And are you aware that that

6 expert's name is William Cooper?

7 A. Yes.

8 Q. Have you seen the remedial

9 map?

10 A. Yes.

11 Q. Are you asking the court in

12 this lawsuit to adopt that map for the

13 2020 election?

14 A. Yes.

15 Q. Would you prefer the district

16 that Mr. Cooper has placed you in --

17 A. Yes.

18 Q. -- in the remedial map as

19 opposed to the current map?

20 A. Yes. I think it would be

21 District 9; is that correct? Yeah,

22 whatever the number is.

23 Q. And do you consider the

24 district that he's placed you in to be a

25 competitive district?

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2 A. Yes.

3 Q. Do you think that you would be

4 able to elect a Democratic representative

5 under that map?

6 MS. ROMERO: Objection to

7 form. Speculation.

8 A. I think so.

9 Q. Did you provide any input to

10 Mr. Cooper in drafting a remedial map?

11 A. No, I did not.

12 Q. Did Mr. Cooper ask you for any

13 input in the remedial map?

14 A. No.

15 Q. And what do you think a

16 mapmaker should consider in drawing maps?

17 A. Again, I would look at trying

18 to draw -- pay attention to compactness,

19 pay attention to county and municipal

20 boundaries, pay attention to the Voting

21 Right Act requirements. Those would be

22 the three criteria off the top of my

23 head.

24 Q. Do you think mapmakers should

25 consider incumbency protection?

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2 A. No.

3 Q. You don't think that's

4 permissible?

5 MS. ROMERO: Objection. Calls

6 for a legal conclusion.

7 A. It may be permissible, it may

8 be legal, but I don't think it's

9 something they should do.

10 Q. Do you believe that you live

11 in a cracked district?

12 A. Yes.

13 Q. What is a cracked district?

14 A. If you look at the geographic

15 area of, say, Lorain County and the

16 number of Democrats that are in Lorain

17 County, rather than keep them all in one

18 district, you split them into three

19 districts as we have now, and that

20 essentially spreads Democrats over three

21 districts, thereby diluting the power of

22 that party.

23 Q. Do you know what other

24 districts Lorain County is in, other than

25 Congressional District 7?

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2 affiliation, and if the effect of

3 cracking is -- if the impact of this

4 split is to greatly distort the

5 percentages of the parties, then I think

6 it's being done for partisan purpose.

7 Q. So in your view, to be a

8 lawful map, does the outcome need to be

9 proportional to the party affiliation of

10 the voters in the state?

11 MS. ROMERO: Objection. Calls

12 for a legal conclusion.

13 A. Yeah, I don't know about

14 proportional, but it certainly needs to

15 be close to proportion, otherwise I think

16 you could infer that there was a partisan

17 intent behind the design.

18 Q. How close does the split have

19 to be?

20 MS. ROMERO: Objection.

21 A. That I don't know. I wouldn't

22 know.

23 Q. Are you seeking a proportional

24 map in this case that roughly

25 approximates the party affiliation of the

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2 STATE OF OHIO, ) SS:

3 COUNTY OF )

4 CUYAHOGA.

5

6 I, Jill A. Kulewsky, a Notary Public

 within and for the State of Ohio, duly

7 commissioned and qualified, do hereby

 certify that MARK GRIFFITHS, was first duly

8 sworn to testify the truth, the whole truth

 and nothing but the truth in the cause

9 aforesaid; that the testimony then given by

 him was by me reduced to stenotypy in the

10 presence of said witness, afterwards

 transcribed on a computer/printer, and that

11 the foregoing is a true and correct

 transcript of the testimony so given by him

12 as aforesaid.

13 I do further certify that this

 deposition was taken at the time and place

14 in the foregoing caption specified. I do

 further certify that I am not a relative,

15 counsel or attorney of either party, or

 otherwise interested in the event of this

16 action.

17 IN WITNESS WHEREOF, I have hereunto

 set my hand and affixed my seal of office

18 at Cleveland, Ohio, on this 17th day of

19 December, 2018.

20

21

22 -----------------------------

23 Jill A. Kulewsky, Notary Public

 within and for the State of Ohio

24 My Commission expires August 31,

 2020.

25

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