Affidavit of George A. Goodwyn

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EXHIBIT 85

depoeee

NORTII CAROLINA
EDGECOUBE COUNTY

George A.
and sayB:

AFFIDAVIT
Goodwyn, being first dulY ssorn'

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That I am a citizen and reeident of Edgecombe county,
Tarboro, North Carolina and have been for more than ten years;

That I practice las in the firn name of FoUNTAIN,
GOODI.IYN AND I{OODARD, Attorneys at Larr, 119 Eaet St. Jamea
Street, Tarboro, Edgecombe County, North Carolina;

That I am the chairman of the Edgecombe county Board
of Elections and have served in that capacity for eeveral
years i

That it has been brought to By attention that a

request has been made to have the 1984 North Carolina Houee of
nejresenratives Primary on November 6, 1984 along with the
otirer relative countiei in queBtion, to rlrit: Wilson and Naeh
countiee. That i f such e request ie sPProved by tle
eppropriate authorities, it would cause a aubstantiel hardehip
to'ali counties involved, and certainly to Edgecombe County;

That numeroua digadvantages would be exPerienced, and
some of these dieadvantagee would be, as fo11ow8:

(l) Unless the North Carolina Generel Aaeenbly hae
previously authorized the State Board of Electione to make
modifications to the exiating election 1aws, there coutd be a

legal question ea to whether or not such e Primary election

"o,rtd iake place on November 6, 1984, the dete of the General
Election.

(D That 11any citizens of Edgecombe, I{ilson and Naeh

Counties who could be potentisl candidatee would not have had

"" opportunity to make an appropriate evaluation in being a

candidate. tirese candidates would not know the boundaries of
the district or the people within the District. There would be

insufficient tine for appropriate organization, etc.
(3) Such a blief time would be extrenety unfair to a

candidate who rras not well known in the district in question
since he or she would not have the oPPortunity of organizing an

appropriate camPaign in such a ehort time frame'
(4) The appropriate Boarde of Election would have

substantial difficuliy it determining diatrict linee in e

precise manner and in being assured thet all Potential voterg
would be voting in the ePPropriate districte. Thie would be
especially difficult if lite Dietricts were not 8et off by
fownship Lr Precinct lines. A further difficulty would be the
fact thet Edgecombe County has ePProximately 30r000 registered
voters and to divide thie- nurubei- into apPropriate districte
would be a substantial undertaking in this ehort Period of
time.

(5) That the 1aw aa it relates to absentee voting ie
not workable at the PreBent time. Unless the Generat Assembly
has author ized the State Board of Elect ions to nodi fy the lawe
relative to absentee ba1lota, such an election could very well
be i11ega1. Further, assuming that euch modification would be

1ega1, the aPPropriate Boarda of Election have Previoualy
,.ft"a epplications and ballota, aB provided by 1aw, to
potential voters and thig sctivity nould have to be

ie-administered. In addition, the Edgecombe County Board of
Elections would be required to ceuBe additional printing of
ballots to be made. ndgecombe County hae the additional problem
aince it uses both PaPer ballote and machine ba11ot8. One

other difficulty regarding absentee ballota would be the fact
that nu'oerou6 periorr" have previouety requested absentee
ballots by narking the "GeneraI Election'r category in the
applicatiLn. Since no one realized that there could Po88ib1y
Ue'a priurary, the electionrs office would not be euthorized to
forward House of RepreBentative ballots since it would not be e

"general electionr' 6ut would be 8 rrPrimaEY". I{ould thie not be

,r, added problem which could very well be unfair to candidates
and voterB ?

(6) Each of the three Boarde of Election would
probably be required to have joint meetings in order to
properfy admrnieter the new aietrlcE. rhie would b3 true

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FOUNTAIN. GOOOWYN,;

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ATT.BNEYSAT LAw I i

rHF HowAFo BUTLoTNG ll
...t19EASTST JAMESSI

raR8oRO. N C 27886



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whether or not the district rould be divided into tlrg or more
;i;;ii"te. TheeC pto"edures cannot be developed and fulfil1ed
in an extremely brief Period.

The stsqements ea lieted above are only a fes reasons
that would cauee difficulty to the Edgecombe County Board of
Electione, and likely to the Naeh and I{ileon County Boards of
Election.

In aunmary' if the Houge of RepresentativeB Plimary
rraB to occur et the- November 6, 1984 Geneial Election, it ie
the belief of the undereigned that very few people, if anY'
would benefit and the likl ihood of unintentional voting
irregularities would probably exiat which could require a new

electioo. A primary to be performed at a rnore deliberate tiue
frame would be of substantial benefit to our ciqizenE.

Respectfully subnitted thie tt,e Sladay of
September, I 984.

EDGECOMBE COUNTY BOARD OF ELECTIONS

Swo rn
r984.

to and subscribed before me this 21st day of September,

My commission expires: 9/26188

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FOUNTAIN, GOODWYN,

&wooDARD ll
ATT.RNEYSAT LAW I

_-..'HF Hr)WAFID BUILOING

r19 €AST ST JAMES SI
TARBORO. N C 27886

Goodwyn, Chairm

No t ary