A top organizer in the effort to recall two Nevada state senators says county election officials are undercounting valid signatures, which could have major ramifications for qualifying the recalls for a special election.

In a supplemental declaration submitted to the court on Tuesday, William Rogers — president of Advanced Micro Targeting, the political firm that gathered signatures for the recalls — said that the verified signature totals reported by election officials “substantially deviated” from sampling and had ignored a crucial bloc of signatures that should be included.

The declaration comes just a day before the two sides are due in court for a final ruling on whether or not the recall efforts, which targeted Democratic state Sens. Joyce Woodhouse and Nicole Cannizzaro, meet the threshold for a special election. Although a District Court judge last month upheld the constitutionality of a state law that will allow hundreds of signature withdrawal requests submitted after the recall petitions were turned in, a successful appeal of that decision to the state Supreme Court would be moot unless the recall petitions qualified without that bloc of signatures.

In the declaration, Rogers said that Clark County Registrar Joe Gloria had amended his signature count on the Woodhouse petition based on 335 disputed names that he had sent in the previous week. The amended signature count, which was reported on Monday, added 175 signatures to the total, which was still 21 below the threshold for a special election without including the post-submission requests.

Rogers said that the amended count did not include 96 additional signatures that should have been added to the count, including 10 rejected signatures with declarations from the voters themselves, 32 invalid pre-submittal withdrawals and 54 additional signatures that Rogers said should be valid.

He also said that the representatives for Woodhouse had conducted their own verification of the signatures, and had reported a number to the court that would have qualified the recall petition.

“Until recently, it seemed to be an undisputed fact that at least the Woodhouse Recall Petition had enough valid signatures to qualify if the Post-Submittal Withdrawals were not counted,” he wrote. “Only now, after this most recent verification, is that fact now in controversy.”

The Cannizzaro effort is not nearly so close, falling hundreds of signatures short of qualifying.

Rogers and Advanced Micro Targeting have in the past done campaign work for Republican state Senate Leader Michael Roberson, who has been a prominent booster of the recall efforts. If successful, the efforts could help level the playing field for Republicans in their effort to take back control of the state Senate, especially as the party has no promising opportunities to pick up seats during the 2018 election. Republicans currently hold nine state Senate seats, while Democrats hold 11 and caucus with nonpartisan Sen. Patricia Farley, a former Republican who left the party in 2017.

State law requires recall efforts to gather the signatures from 25 percent of voters who cast a ballot in the last election of the targeted office-holder within a 90-day period. Signatures are then reviewed and processed by state and local election officials, who assess and take out invalid signatures to determine whether the recall petition meets the minimum threshold.

William Rogers recall supplemental deceleration by Riley Snyder on Scribd