The State of Texas

Elections Division Phone: 512-463-5650

P.O. Box 12060 Fax: 512-475-2811
Austin, Texas 78711-2060 Dial 7-1-1 For Relay Services
www.sos.texas.gov (800) 252-VOTE (8683)
Ruth R. Hughs
Secretary of State
April 23, 2020

Mr. David Maxwell

Director of Law Enforcement
Office of the Attorney General
P.O. Box 12548
Austin, Texas 78711

Dear Mr. Maxwell,

Pursuant to Section 31.006 of the Texas Election Code, I respectfully request your assistance in
reviewing allegations of criminal activity in connection with the harvesting of ballots by mail in
Harris County.

The complainant, Colleen Vera, alleges that mail ballot harvesting occurred during the 2018
Democratic Primary Election and that this activity has been occurring since 2008. Specifically,
Ms. Vera alleges that a number of the people who picked up large batches of ballot by mail
applications had prior forgery convictions and were associated with campaigns. Additionally, she
alleges that a number of ballots in Precinct #0529 were marked identically.

Texas Election Code §276.012 states a person commits an offense if, with the intent to establish,
maintain, or participate in a vote harvesting organization, the person commits or conspires to
commit one or more offenses under Titles 1 through 7. Additionally, §276.013 states a person
commits an offense if the person knowingly or intentionally makes any effort to influence the
independent exercise of the vote of another in the presence of the ballot or during the voting
process, cause a voter to become registered, a ballot to be obtained, or a vote to be cast use false
pretenses, or cause any intentionally misleading statement, representation, or information to be
provided to an election official or on an application for ballot by mail, carrier envelope, or any
other official election-related form or document.

The complainant alleges that people with prior forgery convictions picked up large batches of
ballot by mail applications for local campaigns and a number of voted ballots were marked
identically.

After review of the submitted documentation, we believe the information regarding the offenses
warrants a submission for criminal investigation to the Texas Attorney General as the specific
allegations described involve a potential misdemeanor offense. Accordingly, under Section
31.006 of the Code, we are forwarding this complaint to the Attorney General for investigation.

Sincerely,
Page 2

Keith Ingram
Director of Elections

KI:LP

cc: Colleen Vera

18130 Cadbury Dr.
Houston, TX 77084