Subject: FW: LITIGATION HOLD NOTICE
From: "Dillon, Lauren" <[email-masked]>
To: Research_D <[email-masked]>
Date: Fri, 29 Apr 2016 11:23:28 -0700

Hey guys. I need you all to reply to me that you will comply.

Thank you!

From: Lindsey Reynolds
Sent: Friday, April 29, 2016 2:10 PM
To: Pratt Wiley; Brad Marshall; Patrice Taylor; Davis, Marilyn; Alvillar, Raul; Miranda, Luis; Dillon, Lauren
Cc: Gottschalk-Marconi, Emily; Dacey, Amy; Graham Wilson
Subject: LITIGATION HOLD NOTICE
Importance: High

Department Directors:

Please forward this notice to you entire team. Have them reply to you that they will comply and forward me those emails. If you have any questions let me know.

Thank you,

Lindsey

*******************

TO: DEMOCRATIC NATIONAL COMMITTEE ("DNC") OFFICERS, DIRECTORS, STAFF MEMBERS, EMPLOYEES, ETC.

SUBJECT: FELDMAN, ET AL. V. ARIZONA SECRETARY OF STATE'S OFFICE, ET AL. - LITIGATION HOLD NOTICE - YOUR ASSISTANCE AND RESPONSE REQUIRED - ATTORNEY-CLIENT PRIVILEGED/WORK PRODUCT

You are receiving this message because you may have materials potentially related to a voting-rights case in which the DNC is a plaintiff, Leslie Feldman, et al. v. Arizona Secretary of State's Office, et al., D. Ariz. No.CV-16-01065-PHX-DLR. This lawsuit challenges three aspects of Arizona elections: (1) Maricopa County's allocation of polling locations; (2) Arizona's practice of not counting provisional ballots cast out of precinct; and (3) Arizona's prohibition on ballot collection. This message contains instructions you must follow in connection with this matter until you receive further instructions from legal counsel.

For the purposes of this hold, the term "documents" means any information that is fixed in a tangible form and stored in a medium from which it can be retrieved and examined.  It includes (for example only and without limitation) all documents, communications and electronic data, including originals, copies and backups, relating to this matter, including all files, paper documents, notes, e-mails, hard drives, backup drives, audio recordings, video recordings, servers, and website information/data.

For the purposes of this hold, the terms "you" and "yours" refers to the DNC and all of its employees, agents or representatives.

You must retain, and not delete or destroy, any and all documents that relate to or concern:

  *   The allegations and statements in the Complaint (a copy of which is attached to this message), including, but not limited to, any documents that are in any way related to your, your members' or your constituents' experiences voting in Arizona generally and, specifically, in the 2016 presidential preference election, Maricopa County's allocation of polling locations, Arizona's rejection of provisional ballots cast out of precinct, and Arizona's prohibition on ballot collection;

  *   Get-out-the-vote, voter registration, voter assistance, or voter education efforts that you have or will engage in in Arizona , including documents related to any money and/or resources expended in relation to the same;

  *   Corporate filings and organizational documents such as current and prior versions of the Charter and Bylaws and state and/or federal corporate and campaign finance registration forms;

  *   The identity of the officers, directors, employees, staff members, Arizona members, and agents of the DNC;

  *   Accounting books, financial statements, annual statements, budgets, earnings, expenses, line items, income, donations, debt, loans, forecasts, and projections; and/or

  *   The DNC's purpose, strategic plans, goals, programs, and planned events.

You are required to keep any of these materials that exist in your possession today, or that you create or receive in the future, until you receive an instruction from legal counsel that this requirement has been lifted.  These instructions apply to material wherever it is stored - whether maintained at your office, on a laptop or desktop computer, on computer servers, on floppy disks, on zip disks and drives, on CD-ROMs, on backup tapes, on telephone and telephone systems, at your home, on shared drives, on Web sites (including internal Web sites and blogs), PDAs, or at any other location.  The material must be preserved in its original form, so that for electronic material all information contained within it, whether visible or not, is also available for inspection - i.e., it is not sufficient to make a hard copy of electronic communications.  You must similarly preserve any new information that is generated after you receive this notice that could be considered relevant to this dispute.

In order to ensure that none of this information is inadvertently deleted pursuant to established document retention policies, you must immediately suspend deletion, overwriting, or any other destruction of electronic information relevant to this potential dispute that is under your control.

You must take this obligation seriously. Failure to preserve these materials could potentially result in legal liability, and could lead to disciplinary action, including termination and/or court imposed sanctions.

Please direct any questions about this notice to legal counsel, Amanda Callais, at (202) 654-6396 or [email-masked]<mailto:[email-masked]>.

Please acknowledge that you have received, read and will comply with this notice as instructed.

Amanda Callais |Perkins Coie LLP
Associate, Political Law Group
700 Thirteenth Street, NW Suite 600
Washington, D.C. 20005-3960
D. +1.202.654.6396
F. +1.202.654.9995
E. [email-masked]<mailto:[email-masked]>

 Lindsey Reynolds | Chief Operating Officer
Democratic National Committee
direct: 202.863.7166| cell: 202.215.9864