REPUBUCAN PARTY

February 13, 2020

The Honorable Dave Yost
Ohio Attorney General

30 E. Broad Street, 17th Floor
Columbus, Ohio 43215

CC:

The Honorable Frank LaRose, Ohio Secretary Of State

Charles E. Coulson, Prosecuting Attorney, Lake County, Ohio

Julie Pfeiffer, Assistant Section Chief for Constitutional Law Section, Ohio Attorney General?s Of?ce

Re: Possible election law violation
Dear Attorney General Yost,

Secretary of State Frank LaRose recently noti?ed you that he had ?identi?ed 10 individuals who appear to have
voted in Ohio after casting a ballot in a different state in the same election.? In his letter, LaRose underscored
the importance of ?consistent enforcement of the laws governing our voting processes.? This complaint
provides information regarding Hillary O?Connor Mueri (AKA Hillary Ann O?Connor AKA Hillary Keiser)
who also appears to have cast a ballot in the same election in Ohio and another state, in violation of Ohio law.
Therefore, we urge you to investigate the facts detailed below and take appropriate action if prosecution is
warranted.

Statement Of Facts:

A review of available public records from the Lake County, Ohio Board of Elections and the San Diego County
(California) Registrar of Voters indicates that Hillary O?Connor Mueri (AKA Hillary Ann O?Connor AKA
Hillary Keiser) (DOB: 04/23/1977) voted in the following elections:

I California: February 5, 2008 Presidential Primary Election
0 Ohio: March 4, 2008 Primary Election

California: November 4, 2008 Presidential General Election
I On January 11, 2006, Hillary A. O?Connor, heretofore Hillary O?Connor Mueri, signed a sworn
?Registration and Absentee Ballot Request? which she submitted under penalty of perjury to the state of
Ohio (Exhibit 1) that established her in-state voter residency at 7315 Khristopher Ct., Concord, OH
44077.

0 On April 23, 2007, under penalty of perjury, Hillary A. O?Connor submitted a ?Voter Registration
Form? to the state of California (Exhibit 2) from that established her in-state voter residency at 2165
Caminito Leonzio, Unit 24, Chula Vista, CA 91915. In this form, she also declared ?Yes? to the
question ?Have You Ever Been Registered To Vote?? and listed 7315 Khristopher Ct., OH 44077 as the
street address for where she was registered.

14687673V1

 On February 5, 2008, records from the San Diego County Registrar of Voters (Exhibit 3) show that
O?Connor Mueri voted in California?s Presidential Primary election on said date.

0 On March 4, 2008, records from the Lake County Board of Elections show that O?Connor Mueri
(Exhibit 4) show that O?Connor Mueri cast an absentee ballot in Ohio?s Democratic primary election on
said date.

Ir On November 4, 2008, records from the San Diego County Registrar of Voters (Exhibit 3) show that
O?Connor Mueri voted in Califomia?s Presidential General election on said date.

Analysis:

O?Connor Mueri?s conduct appears to be in violation of Ohio law. Under Ohio Rev. Code it
is a felony in the fourth degree to ?[v]ote or attempt to vote in any primary, special, or general election in a
precinct in which that person is not a legally quali?ed In order to be a quali?ed Ohio elector, Ohio
Rev. Code requires that individual must have ?been a resident of the state thirty days immediately
preceding the election at which the citizen offers to vote, is a resident of the county and precinct in which the
citizen offers to vote, and has been registered to vote for thirty days.? Furthermore, Ohio law explicitly states
that, a person goes into another state and while there exercises the right of a citizen by voting, the person
shall be considered to have lost the person?s residence in this state.? Ohio Rev. Code Based on
the facts detailed above, O?Connor Mueri does not appear to be a quali?ed Ohio elector when she cast a ballot
in Ohio?s March 4, 2008 presidential primary. By voting in California on February 5, 2008, O?Connor Mueri
lost her residence in the state of Ohio as of that date. Therefore, when she cast an absentee ballot in Ohio?s
March 4, 2008 presidential primary 28 days later, she could not have met the requirement to have been a
resident of the state for the immediate 30-day period prior to the election.

Furthermore, Ohio Rev. Code 3599.12 states no personal shall vote or attempt to vote more than once at
the same election by any means. As evidence shows, O?Connor Mueri voted in the California presidential

primary election and the Ohio primary election in 2008. O?Connor Mueri voted twice in a primary election
period.

I urge you to examine the evidence presented, and if you determine that Ms. O?Connor Mueri violated the law,
refer this matter to the appropriate prosecution. Thank you for your prompt attention to this matter.

Sincerely,

QR

Rob Secaur
Executive Director, Ohio Republican Party

14687673v1