Voter Registration Data Sharing

To Whom It May Concern:

Pursuant to the Tennessee Public Records Act, I hereby request the following records:

Requested Records:
All electronic communications (including emails, email attachments, complete email chains, text messages, or messages on messaging platforms, such as Slack, GChat or Google Hangouts, Lync, Skype, or WhatsApp) between (A) any official in the Office of the Secretary of State of Tennessee listed below and (B) any person communicating on behalf of the external individuals or entities listed below, including but not limited to at the suggested email addresses or domains. In the case of emails and texts, the search should include those sent or received from the specified officials’ personal accounts and/or devices used to conduct official business, as well those sent from their official email addresses or government-issued devices.

A. Secretary of State Officials:
i. Secretary of State Tre Hargett
ii. Michael Harmon, General Counsel
iii. Lena Russomanno, Executive Assistant, Division of Elections
iv. Chris Mustain, Senior Policy Advisor
v. Connor McDonald, Assistant General Counsel for the Office of Tennessee Secretary of State
vi. Donald Hall, Elections Assistant - Division of Elections
vii. Christina Temple, Chief of Staff
vii. Mark Goins, Coordinator of Elections
ix. Beth Henry-Robertson, Assistant Coordinator
x. Kathy Summers, Elections Specialist

B. External Entities:

i. America Project (@americaproject.com, @theamericaproject.com)
ii. Conservative Partnership Institute (@cpi.org, @conservativepartnership.org)
iii. Cleta Mitchell (cleta@cletamitchell.com)
iv. Omega4America (@omega4america.com, @contingencysales.com, @jayvalentine.com), and Jay Valentine (jay@contingencysales.com)
v. Voter Reference Foundation (@voteref.com, @voterreferencefoundation.com, @restorationaction.com) and Gina Swoboda (ginaswoboda@hotmail.com)
vi. Eagle AI NETwork, including Rick Richards (drr@cathaid.com, drr@eagleai.pro), John Richards (johnrichards@eagleai.pro), Scott Klosinski (scott@klosinski.com), and anyone communicating from an email ending in @eagleai.pro
vii. Foundation for Government Accountability (@thefga.org) and Opportunity Solutions Project (@solutionsproject.org).
viii. Office of the Ohio Secretary of State (@ohiosecretaryofstate.gov)
ix. Florida Department of State (@dos.myflorida.com)
x. Virginia Department of Elections (@elections.virginia.gov)
xi. Iowa Secretary of State (@sos.iowa.gov)
xii. Missouri Office of the Secretary of State (@sos.mo.gov)
xiii. Texas Secretary of State (@sos.texas.gov)
xiv. Louisiana Secretary of State (@sos.la.gov)
xv. Alabama Secretary of State (@sos.alabama.gov)
xvi. West Virginia Secretary of State (wvsos.gov or wvsos.com)
xvii. Beacon Center (@beacontn.org)

Records pertaining to the development and implementation of any cross-state voter data sharing programs, such as the Alabama Voter Integrity Database, conducted for the purpose of ensuring the accuracy and currency of voter rolls, such as programs intended to serve as an alternative, supplement, or replacement to the Electronic Registration Information Center (ERIC). This includes, but is not limited to, memorandums of understanding with other states, as well as all records of data shared pursuant to such memorandums of understanding and otherwise pertaining to the implementation of those list-maintenance programs.

All records pertaining to proposals from non-governmental entities to support the state’s list-maintenance activities, including but not limited to correspondence about such proposals and the implementation of such programs.

For (2) and (3), please note that the National Voter Registration Act requires that states make available for public disclosure “all records concerning the implementation of programs and activities conducted for the purpose of ensuring the accuracy and currency of official lists of eligible voters[.]” 52 U.S.C. § 20507(i)(1).

Please provide all responsive records from March 1, 2023, through the date the search is conducted.

The requested documents will be made available to the general public, and this request is not being made for commercial purposes.

In the event that there are fees, I would be grateful if you would inform me of the total charges in advance of fulfilling my request. I would prefer the request filled electronically, by e-mail attachment if available or CD-ROM if not.

Thank you in advance for your anticipated cooperation in this matter. I look forward to receiving your response to this request within 7 business days, as the statute requires.

Sincerely,

Kent Hoover, a citizen of Tennessee, in coordination with Karen Goll.