Pete for America
P.O. Box 1226
South Bend, IN 46624
Via Electronic Delivery

February 22, 2020

Chairman William McCurdy II
Nevada State Democratic Party
2320 Paseo Del Prado Drive, Suite B107
Las Vegas, NV 89102
Dear Chairman William McCurdy II,
In a February 13 memorandum, the Party explained that it understood “just how
important it is that we get this right,” vowing to “protect the integrity of Nevadans’ votes.” We
share the Party’s understanding of the need to get this right. We write to request that the Party
take concrete steps to make that a reality. To ensure the Party delivers on its goal of delivering
the most transparent caucus in history, and in light of material irregularities pertaining to the
process of integrating early votes into the in-person precinct caucus results, we request that you:
(1) Release early vote and in-person vote totals by precinct; (2) Correct any outstanding early
vote and second alignment errors identified by presidential campaigns, including ours; and (3)
Explain anomalies in the data. Given how close the race is between second and third place, we
ask that you take these steps before releasing any final data.
First, release early vote and in-person vote totals by precinct​. We share the desire to
open up the caucus process to more participants. By most accounts, early voting itself was a
success on this measure. The process of integrating early votes into the results of the in-person
precinct caucuses, however, was plagued with errors and inconsistencies. We received more
than 200 incident reports today from precincts around the state, including a few dozen related
to how early vote factored into the in-person results. In some cases, the early vote data was not
delivered or was delivered after the caucus began. In some locations, early votes were not used
in calculating viability or determining the strength of each preference group. In at least one
location, early vote data from the wrong precinct was used. In numerous locations, the early
vote totals were allocated to the wrong candidate. In some instances, where a candidate was not
viable on first alignment, those early voters who listed that candidate as their first preference
were disregarded on second alignment. In other instances, early voters were reallocated on
second alignment despite their first preference being viable on first alignment. In still others,
the early vote of non-viable candidates on second alignment was not reallocated to viable
candidates. We also received a report that early vote data from the wrong precinct was used and
another report that precinct chairs had refused to announce the early vote totals for each
candidate after first alignment, making it impossible for in-person attendees to know how to
realign. To shed light on all of these issues, the Party should release early vote by precinct. The
Party is able to do this: every math worksheet is supposed to show both early vote and in-person
preferences and the Party has said that it has either electronic or hard copies of all of these
worksheets.
Second​, correct any outstanding second alignment errors identified by presidential
campaigns, including ours. Over the course of the day, we exchanged three dozen emails with

 the Party, flagging many of the issues identified above. We also identified other general issues
pertaining to the realignment process. In many cases -- including in a precinct location on
national television -- chairs instructed caucus-goers that non-viable groups could not be made
viable on second alignment. In other cases, chairs did not count the first preferences of early
voters in deciding if a group had become viable on second alignment. We do not know if these
issues were corrected. We also do not know the extent to which the Party corrected errors that
we know other campaigns submitted. Before releasing final data, we request that the Party
correct these errors and any others that it has identified in performing its own quality control.
Third, explain anomalies in the data. To the extent any errors remain in the data -whether because of a failure to apply the realignment rules or to properly allocate the early vote
-- we ask that the Party provide an explanation as to why the issue cannot be rectified. We also
ask that the Party explain other anomalies, including resolving one report we received today in
which all early votes were mistakenly allocated to a single candidate even when other candidates
were viable and those candidates had early votes.
***
We know that you have worked tirelessly over the past few weeks to ensure that the
Caucuses would be a success. We only ask that you take the time in the next 24-48 hours to
deliver on that goal by offering the level of transparency and accuracy that you have promised
throughout this process. Please respond by 6:00 AM PT with details on how the Party plans to
address the aforementioned requests.
If you have any questions or would like to discuss any of these issues, please feel free to
contact me at
or at
. (I kindly ask that you redact
my email address and phone number should you publicly release this request.)
Sincerely,

Michael Gaffney
National Ballot Access and Delegates
Director