MARTIN GOLANDO

ATTORNEY AT LAW

March 17, 2014VIA HAND DELIVERY

Mr. Valde GuerraHIDALGO COUNTY COMMISSIONERS’ COURT

EXECUTIVE OFFICER 2818 SOUTH BUSINESS HWY 281EDINBURG, TEXAS 78539

Re: March 4, 2014 Democratic Party Primary ElectionsDear Mr. Guerra,

Unless immediate action is taken by Hidalgo County, the most fundamental of all our rights – the right to vote – has been seriously jeopardized and compromised in the latest Democratic Primary Election. At least 12 Candidates have approached us to take immediate legal action pursuing immediate relief. Individual voters have indicated that in casting their vote using Hidalgo County’s voting machines, their vote for a particular candidate was changed by the voting machine; this happened repeatedly throughout the county.

Others have complained that the total votes reported by the machines exceeded the total of voters that actually voted. Moreover, there are allegations that the County was negligent in allowing a county employee with intimate technical knowledge of how the voting machines work may have had access to those voting machines while also working for individual campaigns. Further, this employee had access to the county’s information technology department inclusive of information and resources. Also, we have evidence that this particular employee admitted to manipulating the 2006 election results. A county employee with access to voting machines that can be manipulated while working on individual campaigns strains the public’s faith in the political process.

Indeed, in the 2014 election, we have evidence of a Hidalgo County Elections Division IT worker destroying evidence by recalibrating a malfunctioning machine after being advised to preserve the machine and the evidence contained therein. Rumors are rampant that there has been internal manipulation of the voting machines with sinister intentions directed at promoting certain campaigns and candidates.

Please be advised that we have been retained by a number of Hidalgo County voters and Marla Cuellar, a candidate and voter, to bring litigation against the County seeking the audit of the voting machines. We urge the County to join us in seeking an audit of the machines so that the cloud that hangs over this election is cleared up.

2326 WEST MAGNOLIA, SAN ANTONIO, TEXAS 78201PHONE: (210) 471­1185

Mr. Valde GuerraMarch 17, 2014Page 2

We have also been retained to file a lawsuit challenging the results of the election due to the voting irregularities related to the ES&S voting machines used by Hidalgo County in the 2014 primary election.

The reliability of the voting machines used by Hidalgo County to conduct the March 4, 2014 Democratic Party Primary Elections has long been questioned. The computerized voting machines used by the County, ES&S iVOTRONIC, are susceptible to malfunction and manipulation (see enclosed articles). Hidalgo County, I am sure, wants to make sure the integrity of the election process is beyond reproach.

This letter is to request that the County immediately join us in a motion to the Court to hire an expert to review the accuracy of the election returns and conduct a forensic audit of the machines used, so that any questions looming on the March 4 Primaries may be cleared up and the County can avoid costly litigation. We understand this process could take as little as 10 days. The run­off elections are looming and the Secretary of State recommends that the examining of voting equipment be done by Tuesday, March 25, 2014. See Texas Secretary of State Election Advisory No. 2013­09. Obviously, this is a matter of some urgency.

Please respond to this request as soon as possible; should you have any question, please do not hesitate to contact our office.

Sincerely,

By:________/S/_____________Martin Golando

Enclosure: News articles related to ES&S iVotronic machines.

cc: The Honorable Ramon Garcia, Hidalgo County Judge;The Honorable A.C. Cuellar, County Commissioner ­ Precinct 1;The Honorable Hector “Tito” Palacios, County Commissioner ­ Precinct 2;The Honorable Joe M. Flores, County Commissioner ­ Precinct 3;The Honorable Joseph Palacios, County Commissioner ­ Precinct 4.

2326 WEST MAGNOLIA, SAN ANTONIO, TEXAS 78201PHONE: (210) 471­1185