Affidavit of Nelda M. Bertrand
Public Court Documents
September 24, 1984
Cite this item
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Case Files, Thornburg v. Gingles Hardbacks, Briefs, and Trial Transcript. Affidavit of Nelda M. Bertrand, 1984. b0e4ccb4-d592-ee11-be37-00224827e97b. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/27dc4c8d-01ce-4733-8068-1762799c3cd1/affidavit-of-nelda-m-bertrand. Accessed December 03, 2025.
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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