Pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(ii), the Plaintiffs to the above- captioned action, League of Women Voters of South Carolina, The Family Unit, Inc., Albertus Clea, and George Hopkins (“Plaintiffs”), by and through their undersigned counsel, file this Stipulation of Voluntary Dismissal.

Defendants Marci Andino, Executive Director of the South Carolina State Election Commission, Howard Knapp, Director of Voter Services of the South Carolina State Election Commission, John Wells, Chair of the South Carolina State Election Commission, and Joanne Day, Clifford J. Edler, Linda McCall, and Scott Mosely, members of the South Carolina State Election Commission, and Intervenors James H. Lucas, Speaker of the South Carolina House of Representatives and Harvey Peeler, President of the South Carolina Senate (collectively “Defendants”), by and through their undersigned counsel, consent to this Stipulation, which is made to terminate any further controversy respecting all claims that have been asserted against Defendants in the instant matter and does not constitute an admission of wrongdoing by any Party hereto.

The Defendants agree that, pursuant to current South Carolina law and Directive No. 2020-001, county boards of elections and voter registration are not authorized to and should not match voters’ signatures located on absentee ballot voter oaths with voters’ signatures on any other document for the purpose of determining the legitimacy of the absentee ballot or any voter’s eligibility to cast a legal ballot in any future election held in South Carolina.

The Parties stipulate that the entire action shall be dismissed without prejudice and that each Party shall bear its own costs and fees, including attorney’s fees. Nothing in this Stipulation shall be construed as the State’s waiver of immunities available under state and federal law.

Respectfully submitted this 23rd day of April, 2021:

WE SO STIPULATE:

s/ Susan K. Dunn
Susan K. Dunn (Fed. Bar #647) sdunn [at] aclusc.org
AMERICAN CIVIL LIBERTIES UNION FOUNDATION OF SOUTH CAROLINA P.O. Box 20998
Charleston, South Carolina 29413-0998 Telephone: (843) 282-7953
Facsimile: (843) 720-1428

John Powers (admitted pro hac vice) jpowers [at] lawyerscommittee.org
LAWYERS’ COMMITTEE FOR CIVIL RIGHTS UNDER LAW
1500 K Street NW, Suite 900
Washington, DC 20005
Phone: (202) 662-8389
Fax: (202) 783-0857

Counsel for Plaintiffs

Julianne J. Marley
Rhianna Hoover
DEBEVOISE & PLIMPTON LLP
919 Third Avenue New York, NY 10022 (212) 909-6000

Of Counsel for Plaintiffs