Affidavit of Nelda M. Bertrand

    E}(HIBTT 87

NORTH CAROLINA

WILSON COUNTY

and has been for several Years.

That she is Chalrman of the Wllson

prior to becomi,ng Chairman, she was a member

Elections.

AFT'IDAVIT

Nel_da M. Bertrand, first belng duly sworn, deposes and says:

That she ls a cltizen and resldent of Wilson County, North Carolina

County Board of ELectlons and

of the l.IlLson CountY Board of

That she understands that a request has been made to have the

1984 North Carolina House of Representatlves Primary on November 6, L984,

which said House of Representatives Primary lnvo1ves llllson, Edgecombe and

Nash Countles. November 6, 1984 ls the date on which the General Election

will be he1d.

. That it ls lmpractlcable to hold the House of Representatives

Prirnary on Novembet 6, 1984, in conjunctlon wlth the General Electlon, for

the following reasons:

1. Wilson County ls and has been proceedlng wlth all necessary

steps requlred by law for the conduct of the General Electlon on November

6, tg84. Machine ballots for voting machines have been ordered and shouLd

be recelved frorn the printers at any time. Paper baLlots as requLred have

been printed and are on hand. I{ll-son County began taklng absentee ballots

on september 7, 1984 and is processing said aoplications. The process of

conducting the 1984 General Electlon has progressed to the polnt that lt

would be extremely difficult, if not imposslbl-e, to lnject a prlmary lnto

the present plans.



2' llil-son county uses shoup voting l'achlnes' Ttre General

Electlon balLot utlllzes alL of the space on the voting rnachine. Prograrnmlng

for General Electlons differs from prograrrnlng used ln prlmary elections in

that programning for general electlons perolts cross over voting and lrrLte-

ins. Since aL1 of the space ls used and because of the dlfference Ln

progranuning of the machlne, lt ls neither feaslbLe nor posslb1e to have

both types of ballots on the votlng machlnes.

3. I^l11son County ls one of the countles in the State of North

Carolina subject to rhe Votlng Rlghts Act of 1965. Ttre United States

Department of Justice has precleared the use of votlng machines by lllIson

County. To use paper ball-ots would necessltate a submi.sslon for preclearance

to the United States Department of Justice and there is lnsufflclent tLme

within which to secure the precl-earance before the General ELection'

4. It would be verv confuslng to the pubJ'lc and to the poIl

workers to conduct an electLon using both votl-ng machlnes and paper ballots.

The confuslon resulting from the use of both ballots would cause a greater

probablllty for produclng errors ln the election.

5. The boundaries of the new House of Fepresentatives district

are unknown, and there is insufficlent tlme to identify and asslgn potential

voters to the proPer district.

6. Ttre deslgnatlon of the new districts may necessltate reopenlng

of the fillng for candldates and does not a1low sufflclent tlure for canrpalgning

prior to November 6, l-984.

That these reasons 11]-ustrate the mechanLcaL and admlnlstrative

difflcul-tLes whlch vould arise by havlng the House of P.epresentatlves Primary



cooblned wlth the General

a later tfune where there

votera and candldates.

Electloa on Novernber 6, 1984.

ls adequate advance notlce w111

A prlnary dete at

beneflt both the

Sworn

thls

rtre ld day of sePteober, 1984.

to and eubscrlbed before me

Notary Publlc

l,ty Comlsslon E:<plrea :

My Commission Explreq Decembcr 8, ISZ

t