Melissa White Rochelle Cabirac

18838 Stone Oak Pkwy 911 Wilkinson St

Suite 106 Shreveport, LA 71104
San Antonio TX 78258 [email protected]
[email protected]

October 15, 2024

Georgia State Election Board

2 MLK Jr. Drive
Suite 802 Floyd West Tower
Atlanta, Georgia 30334

Chairman John Fervier Ms. Janelle King

[email protected] [email protected]

Mrs. Sara Tindall Ghazal Copies to (for distribution):

[email protected] Ms. Alexandra Hardin
[email protected]

Mr. Rick Jeffares

[email protected]

Dr. Janice Johnston

[email protected]

RE: Official Complaint- Fulton County- 2020 - Signature Verification

Board members:

Please accept this filing as my formal request for this complaint to be

fully investigated by the Georgia State Election Board (SEB) or an investigator
chosen by the board to investigate on their behalf.

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There is an urgency to ensure documents and materials be secured prior
to November 5, 2024. I urge the board to use its statutory authority to
subpoena ALL relevant materials and persons immediately! Per our research
the General Assembly in HB916 authorized an additional $292,425 in fiscal year
2025 for SEB to increase funds for investigative operations. Fiscal year 2025
started in July of 2024.

The SEB is the sole authority vested in ensuring all election are
conducted fairly and accurately. Despite dozens of complaints over the last 4
years from citizens of all walks of life, providing concrete evidence of the
continued issues with elections in Georgia, there has been NO action taken to
ensure citizens can or should have faith in our elections.

There have been clear indications by the Secretary of State and the
Attorney General to shut down any and all serious investigations (let alone
prosecution) of the numerous illegal issues shown over the last 4 years that
continue to plague Georgia’s elections.

OFFICIAL COMPLAINT
Failure to Perform Signature Verification 2020 Primary & General

EXECUTIVE SUMMARY

Fulton County’s elections have long been plagued by incompetence,

failure to follow the law, gross mismanagement, and excuses, but never
accountability. Almost as if someone or something has been preventing
reform or remedy. As shown here, Fulton County’s legacy of inexplicable failure
(claiming through no fault of their own) continues.

Pursuant to Georgia law, registered voters who wish to cast an absentee

ballot must provide the requisite information and swear to the oath printed on
the envelope, by signature.1 The signature on the oath envelope is supposed

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GA Code § 21-2-385 (2020) “…the elector shall vote his or her absentee ballot, then fold the ballot and enclose and
securely seal the same in the envelope on which is printed "Official Absentee Ballot." This envelope shall then be placed in the

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to be compared with a known signature exemplar. Upon receipt of the ballot,
the registrar or clerk “...shall compare the signature or mark on the oath with
the signature or mark on the absentee elector’s application for absentee
ballot..” as required by GA Code § 21-2-385 (2020).

Following the 2018 midterm election, the State of Georgia agreed in a

settlement to provide uniformity in the absentee ballot process. After new
standardized laws and procedures were implemented, Fulton County chose to
break those laws by failing to perform signature verification during the 2020
Primary. In response to quite literally hundreds of complaints filed with the
State Election Board (“SEB” or “Board”), Fulton County entered into a Consent
Agreement which, among other things, specifically required absentee ballot
signature verification to be performed in accordance with Georgia law. The
agreement also established a monitor (Carter Jones and Seven Hills Strategies)
to ensure compliance with the agreement.

The shocking fact is that even after being admonished twice Fulton
County, once again, did not perform absentee ballot signature verification for
the 2020 General Election. Let us be very clear in our characterization so there
are no misunderstandings, The undersigned are not simply alleging that
Fulton County did not perform signature verification accurately, effectively, or
correctly:

Fulton County did not perform absentee ballot signature verification for the
2020 General Election.

The Elections Director at the time and his executive staff (including the
current Elections Director) all knew this and intentionally concealed the fact.
Also, the monitor who was contracted to verify compliance with the terms of
the Consent Agreement either failed to verify that absentee ballot signature
verification was being performed or intentionally concealed the truth. There is
no third option. The same goes for Gabriel Sterling, the Secretary of State and
his General Counsel.

second one, on which is printed the form of the oath of the elector; the name and oath of the person assisting, if any; and other
required identifying information. The elector shall then fill out, subscribe, and swear to the oath printed on such envelope.”

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BACKGROUND

Signature verification has been an ongoing issue in Georgia stemming

back to the 2018 Gubernatorial Election, when Stacy Abrams narrowly lost the
governor’s race. At that time Georgia lacked a standardized state procedure
for notifying voters if their absentee ballot was rejected during signature
verification. In response to this issue a federal lawsuit was filed in 2019,
Democratic Party of Georgia v. Raffensperger , seeking uniformity in the
Absentee signature verification process. The parties in this case reached a
compromised settlement agreement (Exhibit A) on March 6th, 2020. The
agreement standardized official procedures for notifying voters when their
absentee ballots were rejected due to missing or mismatched signatures. The
compromise included the SEB agreeing to promulgate and enforce GA R. &
Reg. §183-1-14-.13. which required county election officials to provide prompt
notification, within 3 days of absentee ballot rejection providing voters with
ample time to cure their ballot. The rule also required a review by 3 election
officials prior to the rejection of an absentee ballot due to signature
mismatch. As part of the compromise, the SOS also agreed to issue an Official
Election Bulletin to all Georgia counties prior to all statewide elections in 2020
with guidance to properly conduct absentee signature verification review.

On May 1, 2020, two months after the compromise agreement was

reached, one month prior to the June 9th GA Primary Election, the SOS
issued the first Official Election Bulletin to all Georgia counties.

(5/1/2020 Official Election Bulletin - Exhibit B)

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This emphasized the importance of lawfully conducting signature
verification on all absentee ballots. Due to the pandemic, they anticipated a
drastic increase in the number of absentee-by-mail ballots cast. To safeguard
the election all counties needed to be prepared.

Regardless, Fulton County’s 2020 primary election was, once again,

riddled with problems well documented in the hundreds of complaints filed
with the SEB. These complaints presented a multitude of failures: hundreds
of Fulton County voters never received the absentee ballots they requested.
Fulton County failed to provide voting equipment accessible to individuals
with disabilities (a violation of O.C.G.A. §§ 21-2-379.21 and federal law,
specifically including the Help America Vote Act), failed to provide the
lawfully required forms to all polling locations (violations of O.C.G.A. §§ 21-2-401
and State Election Board Rule 183-1-12- 6b), failed to train poll workers
(O.C.G.A. § 21-2-99(a)), and failed to provide sufficient voting equipment to
polling locations (O.C.G.A. § 21-2-267 and State Election Board Rules 183-1-12-
.09(2) and 183-1-12.1 l(c)).

In October 2020, Fulton County and the SEB agreed to resolve these
complaints with a consent order (Exhibit C). 2 This order stipulated remedial
measures for Fulton County to follow and appointed an independent monitor
for the upcoming November 2020 General Election (Do these actions sound
familiar?).

The SEB also ordered Fulton County to pay a civil penalty of $50,000,
but agreed to waive the penalty if the remedial measures were fully
implemented for the 2020 General Election, including:

“2. Respondents agree to put in place sufficient resources and

procedures to accurately process all returned absentee ballots by the
close of business on the next business day after the ballot is received
(but no later than 3:00 p.m. on the day after Election Day).

"Processing" absentee ballots means the signature on back of the

ballot is compared to the signature on the absentee ballot application
or other signature on file, the ballot is entered into ENET as accepted or

2
Resolving SEB Cases 2020-016 and 2020-027.

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rejected as appropriate, and any required cure notification is sent to the
voter if needed.”

Fulton County failed to conduct signature verification on all absentee

ballots returned for the November 2020 General Election. Not only did Fulton
County fail to “accurately process all returned absentee ballots” which
includes [accurate] signature verification, they failed to perform signature
verification at all. This is important, Fulton County did not put their best foot
forward in good faith, “try their very best”, or even work hard. Fulton County
did not even attempt it!

This was clearly stated by Mark Wingate, former member of the Fulton
County Board of Registration and Elections (FCBRE) on which he served from
2017-2023. In his sworn affidavit submitted in the case of Frazier v. Fulton
County 2023-cv-2023 (Fulton County Superior Court), Mr. Wingate declared
under the penalty of perjury that the Board was informed:

“...Fulton County did not perform any signature verification on any

absentee-by-mail ballot in the 2020 election” (Exhibit D).

By not performing signature verification, Fulton County willfully failed

to implement the remedial measures in accordance with the terms of the
consent agreement as required for the waiver of the $50,000 civil penalty.
Georgia law required the signature verification of all absentee ballots and as
this complaint will demonstrate, like the consent agreement, Fulton County
failed to comply with the law.

Through open records requests, responsive documents showed

communications between former Elections Director Richard Barron, and
Amber McReynolds, the CEO of the Vote at Home organization. The emails
were discussing a plan for the 2020 General Election absentee process. An
email sent on 7/22/2020 by Ms. Reynolds summarized her understanding that
Fulton County did not conduct the lawfully required signature verification
during the 2020 Primary Election:

“Also, with the primary, it sounds like you did not compare signatures,
other than to look and see that a signature was present for acceptance.
This will help us think about how to work with you to formulate plans
for November” (Exhibit E).

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For the 2020 Primary Election, Fulton County accepted all absentee
ballots with a signature, any signature, without comparing it to another
signature on record (voter registration, driver’s license, etc.). This same
unlawful process was then repeated once again for the November 2020
General Election.

THE EVIDENCE & RECORDS

The Evidence presented in this complaint was compiled from numerous open records
requests submitted to Fulton County. The relevant records are organized chronologically and
separated into two timeframes: 1- leading up to the 2020 General Election; 2- following the
2020 General Election. Fulton County’s records show they failed to conduct the lawfully
required absentee-by-mail signature verification.

LEADING UP TO THE NOVEMBER 3RD, 2020 GENERAL ELECTION

Summary:

After the disastrous June 2020 Primary, Fulton County was awarded 2
CTCL grants which provided the elections department with almost 11 million
in funding and additional support throughout the General & Runoff Elections.
Fulton County took advantage of CTCL’s partner “support" (Exhibit F) via The
Elections Group, National Vote at Home (NVAHI), the center for Civic Design,
as well as United States Digital Response (USDR). The ACLU also volunteered
to be the Deputy Registrars on site election day at every polling location. The
NGOs played a major role and were involved in almost every aspect of the
2020 election cycle. The former elections director Richard Barron even
expressed frustration with the overwhelming number of organizations
reaching out to help.

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Former board member Mark Wingate testified at Jeffrey Clark’s Board
of Responsibility hearing on April 1, 2024. Mr. Wingate explains the BRE was
told the county’s BlueCrest (incoming mail sorting machine) platform, which
had a signature verification component being installed, would be used
during the General Election to electronically verify the signatures on the
absentee ballots received.

(Mark Wingate Testimony - Exhibit H)

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Fulton’s equipment did NOT have the Reli-Vote software installed that
was required to perform electronic signature verification. The last thing the
board heard was BlueCrest technicians were on-site to get the signature
verification component up and running.

(Mark Wingate Testimony - Exhibit H)

The required update and installation was NEVER completed. The

Fulton County BRE didn’t know the BlueCrest machine had not been
implemented so it couldn’t perform electronic signature verification. Fulton
County had 4 months to prepare for the General Election with millions of
dollars in additional funding and numerous “partner" organizations offering
free support. There was NO additional backup plan or procedures put in place
to conduct “manual” signature verification.

The facts show Fulton County chose to utilize electronic signature

verification, they knew the BlueCrest wouldn’t function without additional
components and implementation, they never informed the board, they didn’t
reach out for help, they didn’t even attempt to get the resources to do it
manually, and then they chose to process the 147,000 absentee by mail
ballots unlawfully without verification or authentication.

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The Evidence:

1.) July 22, 2020

(7/22/2020 Vote at Home Correspondence - Exhibit E)

In July 2020, emails between Amber McReynolds, National Vote at

Home Institute (NVAHI) CEO, and former elections director Rick Barron, show
they were working to formulate a plan for the processing of absentee by mail
ballots. Rick Barron didn’t think they could lawfully use the BlueCrest system
for electronic signature verification; However, Ryan Germany (Fmr. SOS
General Counsel) gave Rick Barron the approval. Learning that it could be
used, NVAHI agreed to work with BlueCrest to get the signature verification
software added.

2.) July 27, 2020

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NVAHI put together flow charts and tables showing a multi-plan
approach for Fulton County to consider, which included two options for
absentee ballot signature verification. They could have been processed
electronically using BlueCrest or performed manually IF they had enough
space, staff and temporary workers available. Fulton County decided to solely
rely on the BlueCrest Platform. There was not any discussion on
implementing an alternative or backup plan.

3.) October 6, 2020

Steve Struther’s sends a follow-up email to Rick Barron regarding his

obvious anger and frustration with the BlueCrest automated signature
verification. Struthers makes an important and obvious note, that if it “is not
going to be viable, it means we need a lot more people assigned to that task.”

As of October 6th, Fulton County was already short staffed due to COVID
outbreak within the elections department, they physically did not have
enough people on-hand to conduct the process manually. The processing of
absentee ballots was allowed by law to begin 45 days prior to an election.
Conducting manual verification lawfully would have been a long and tedious
process. This required having the large number of staff and temporary
workers prepared with updated training and the necessary equipment and
space available. How were they processing all the absentee ballots received
prior to Oct. 6th, without the staff, space and resources to do so? Why didn’t

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they immediately make emergency preparations for manual verification
knowing it was Oct 6th and the BlueCrest was still not implemented?

4.) October 8, 2020

(10/8/2020 Fulton County BRE Meeting - Exhibit G)

In the months leading up to the 2020 General election the board was
told the department was working with Bluecrest to get the Reli-vote
electronic signature verification component set up for use. Director Rick
Barron at the October 2020 BRE meeting said Bluecrest employees were in
the building getting the BlueCrest set up. This occurred on October 8th, with
less than a month to go till Election Day. As we saw in the October 6th email
above, they were not prepared to do this manually nor had they even
discussed it. When it became apparent the BlueCrest system could not be
implemented in time, they took no action and worst, said nothing about it.
They just didn’t do it!

5.) November 13, 2020

(11/13/2020 Fulton County BRE Meeting - Exhibit I)

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During the Certification of the General Election Mr. Wingate refused to
certify the results. He makes note that he was never informed by the
department that the BlueCrest component would NOT be used for electronic
signature verification. The department stated, “that they gave up on the
process”. Windgate states that all 147,000 absentee ballots were derived by a
manual process. The “manual process” that the Elections Department never
pre-planned, never secured the equipment needed, never hired and trained
all the additional staff they would need to perform manual signature
verification.

6.) MR. WINGATE’S TESTIMONY

(Mark Wingate Testimony - Exhibit H)

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Mr. Wingate details that the Elections Department didn’t do ANY
signature verification. He further explains that they did cure the envelopes
without a signature, which would be sent back to the voter. All evidence
points to exactly this, any signatures or mark on the oath was accepted
without any further verification.

Monitoring Team Observations:

(Carter Jones Monitor Report - Exhibit J)

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Carter Jones, the Fulton County Election Monitor during the 2020
General and Runoff election, and currently serving as a monitor for the 2024
General Election in Fulton, makes strong assertions that he witnessed no
fraudulent conduct in Fulton County and that the results are valid, accurate,
and fair. This is the problem with a monitor, whose only role is to observe and
record what is seen without the ability to investigate or look further into
questionable conduct. Fulton County knew what GA law required and when
they were caught not following the law, they simply made excuses. They told
the monitor exactly what he needed to hear! Every time their conduct was
called into question they mislead him and there was nothing Carter Jones
could do about it.

(Carter Jones Monitor Report - Exhibit J)

While Carter Jones was observing Ralph Jones’s operation, he

witnessed a temporary staffer moving ballots without any signature
verification into the group of ballots being sent to State Farm for counting.
Great news, Ralph Jones saves the day! Carter notes that these ballots could
have easily been counted if Ralph wasn’t there to stop it. What Carter Jones

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witnessed was Fulton County’s daily absentee ballot processing, unlawfully
accepting all ballots without conducting the required signature verification.
Ralph Jones didn’t save the day; he came up with a great excuse to make it
look like an accident. The monitor, who could only take Ralph's word on it,
couldn’t investigate or question the process further to make sure signature
verification was being done properly. It wasn’t being done in Fulton County
during the 2020 General Election and all 147,000 absentee-by-mail ballots
received with a signature present were accepted, given voter credit, and then
counted.

Failing to Conduct a Signature Audit in Fulton County:

On November 20, 2020, Governor Kemp called for a signature audit of

the absentee ballot envelopes. This would have immediately uncovered
Fulton County’s unlawful processing of absentee ballots without signature
verification.

Fact-checking claims signature audits in Georgia would uncover fraud | CNN Politics

On December 4, 2020, Donald Trump filed a verified petition contesting

the election results which included the issue of absentee ballot signature
verification.

(Filed Petition Trump v. Raffensperger Election Contest- Exhibit O)

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Trump’s filing and the additional exhibits (Exhibit P) were based on
rough calculations of Fulton County’s signature mismatch rejections, despite
them having no granular data available at the time. Even so, the filing
correctly pointed out a major irregularity in Fulton County’s absentee
signature verification process. Had the information included in this complaint
been available, or had the case been properly set for hearing and heard in the
courts per law, it could have directly affected the outcome of Trump’s
election contest.

The same day the election contest was filed, December 4, 2020,
Harrison Deal, the aide to Sen. Kelly Loeffler and the boyfriend of Governor
Kemp’s daughter, passed away unexpectedly when his car inexplicably
exploded. Following this incident, the strong push for a statewide signature
audit went silent.

Ten days later, the Secretary of State, who was cited on record
repeatedly against doing a signature audit, suddenly announced on
December 14th that a limited sampling signature audit would take place in
Cobb County.

3rd Strike Against Voter Fraud Claims Means They're Out After Signature Audit Finds No Fraud |
Georgia Secretary of State

Why did the SOS suddenly change course? Why did he choose to do
this sample signature audit in just one county? Why would he choose Cobb?
Fulton County had repeatedly violated the law, a consent order stipulating
additional requirements for signature verification was already in place for
problems in the previous election, so why wasn’t this done in Fulton
specifically?

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On January 2, 2021, during the "perfect phone call" with SOS Brad
Raffensperger, Donald Trump inquired about the signature verification issue
in Fulton County. 3

"We think that if you check the signatures — a real check of the
signatures going back in Fulton County you’ll find at least a couple of
hundred thousand of forged signatures of people who have been
forged. And we are quite sure that’s going to happen."

Then, Donald Trump presented the very same questions to Raffensperger.

"So you sent us into Cobb County for signature verification, right? You
sent us into Cobb County, which we didn’t want to go into. And you
said it would be open to the public. And we could have our - So we had
our experts there they weren’t allowed into the room. But we didn’t
want Cobb County. We wanted Fulton County. And you wouldn’t give it
to us. Now, why aren’t we doing signature — and why can’t it be open
to the public?"

SOS Brad Raffensperger conducted this limited sample signature audit in

one predetermined county behind closed doors, not allowing the public or
observers to witness the process.

“When are you going to do signature counts, when are you going to do
signature verification on Fulton County, which you said you were going
to do, and now all of a sudden you’re not doing it. When are you doing
that?"

Did the SOS pick only one county that undoubtedly did signature
verification during the election to give the state a false sense of security and
cover-up the truth?

3
Full transcript: Trump’s audio call with Georgia secretary of state Brad Raffensperger | CNN Politics

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FOLLOWING THE NOVEMBER 3RD, 2020 GENERAL ELECTION

Summary:

Records and correspondence following the 2020 General and leading

up to the January 2021 Runoff Election prove the validity of this complaint.
The BlueCrest machine was never updated and was unable to perform
electronic signature verification throughout the General Election and
remained that way throughout the Runoff. Ryan Macias from The Elections
Group took the lead and tried to get the issues resolved for a 2nd time. When
that failed Fulton County was out of options and excuses. They had to
perform manual signature verification.

Georgia was facing multiple allegations of unlawfully processed

signature verification during the General Election and all eyes were now on
Fulton County.

There was an enormous amount of preparation required for Fulton

County to conduct manual signature verification during the Runoff Election.
The lack of the same during the General Election proves it did not occur. Even
with all the planning, the county was still falling short of reaching their daily
ballot processing goals and continuously needed additional resources and
staff to help complete the process.

The Evidence:

7.) November 16, 2020

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Two weeks after the 2020 General Election, Ryan Macias reached out to
BlueCrest seeking help to set up and configure Fulton County’s BlueCrest
system. Ryan Macias from the Elections Group, involved in all aspects of the
election, knew the BlueCrest system was inoperable during the General
Election. As of November 16th, Fulton County’s BlueCrest system still needed
the Windows 10 update, installation & configuration of the signature

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verification software, and configuration for the processing of Runbeck’s
envelope and the Blue Crest outbound printed envelope. The problems that
prevented the system from functioning during the 2020 General Election
were never resolved and prevented the system from being used once again,
during the January 2021 Senate Runoff.

8.) November 20, 2020

(11/20/2020 Blue Crest Proposal - Exhibit K)

BlueCrest provided the Fulton County Registration Chief with a

proposal for the upgrades requested. This included a timeframe of between
the end of January to mid-February for completion, after the runoff election.
This begs the question- why was Fulton County just getting a proposal to do
what Rick Barron told the BRE was already underway? BlueCrest states:

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“However, we are not able to provide any firm dates until we have an
order. Once we have order [sic], we can obtain a scheduled ship date from
Manufacturing and provide an actual timeline.”

Fulton County never received a proposal or time estimate for the

modifications necessary to have the signature verification process automated
in time for the 2020 General Election due to BlueCrest never being given the
PO # they had been requesting from Fulton for months.

BlueCrest also emphasized, they “do NOT suggest making any changes
just before an election.” So why did Fulton attempt to make these changes
two times right before the General and Runoff elections? It’s almost as if the
signature verification process was intentionally thwarted from within.

9.) November 30, 2020

At the end of November 2020 Fulton County started preparations to

conduct manual signature verification. This included a test to scan the
envelopes and then send only the digital images to GWCC for comparison.
The email goes on to suggest getting additional computer monitors to ease
the verification process and “Mike said he thought it would be pretty easy to
round up 20-25 monitors.” Had Fulton County done manual signature
verification during the General Election they would have known exactly what

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was needed, how they could improve the process, a good estimate of the
additional staff necessary, and already have the equipment available.

10.) December 8, 2020

THE MANUAL SIGNATURE VERIFICATION PROCESS

Rick Barron provides a description of the manual signature verification

process.

11.) December 9, 2020

(12/9/2020 Official Election Bulletin - Exhibit L)

One month prior to the Senate Runoff election, the Secretary of State
released the final 2020 Official Election Bulletin to all Georgia counties. This

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served as a reminder that all signature verification policies and procedures
must follow GA law. The SoS also points out the numerous allegations made
following the 2020 General Election regarding signature verification but
makes sure to note they’ve “not seen any evidence”.

12.) December 21, 2020

One week after Fulton County began their manual signature

verification process, Steve Struthers sent Rick Barron and Ralph Jones an
email to discuss the county’s progress & predictions. Steve Struthers helped
Rick Barron and the elections department with the planning and

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preparations for the General Election and continued this role throughout the
runoff election. He managed the processes, productivity, strategic planning
and even helped coordinate support from outside groups provided for free
via the CTCL grant “partners” (Steve facilitated work with Vote at Home in
July 2020). Since Steve was so heavily involved in both elections and included
in the communications with Vote at Home since July 2020. This forces you to
question what Steve says, “Now that we have one full week under our
collective belts of signature verification,” when they should have had many
weeks of signature verification under their “collective belts” IF they had done
it during the general election.

The signature processing chart above was included with Steve

Struthers email. This shows the large amount of planning necessary to
organize the manual verification process. To stay on track with processing the
received absentee ballots, Fulton required a certain number of staff available

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working continually to meet the daily processing quota while functioning at a
high productivity rate.

13.) December 21, 2020

A few hours later, after getting the up-to-date signature processing

numbers, Steve Struthers emails Director Rick Barron. He explains the county
staff doing manual signature verification were falling behind on reaching
their daily quota. The productivity rate was lower than they previously
expected. Struthers suggested adding more signature verification stations,
deploying some people working at Peachtree over to GWCC to help verify,
and additionally get 10 extra temps from Happy Faces. The problems and
obstacles they overcame daily during the Runoff to make sure they could

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process enough ballots and had enough workers available, would have
similarly been documented during the General Election had they conducted
the lawfully required signature verification.

Monitoring Team Observations:

(Carter Jones Monitor Report - Exhibit J)

Carter Jones documents a major improvement made by Fulton County

in streamlining the absentee-by-mail ballot process during the Runoff. He
credits this improvement to having the entire signature verification at one
location, GWCC. He mentions, “preforming the entire process linearly”
allowed the public to witness the whole process and corrected the chain of
custody issues seen during the General Election, where ballots were jumping
from one location to the next. However, what Carter Jones witnessed and
believed to be correct, wasn’t accurate.

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The absentee ballot process wasn’t conducted at one location, as the
emails above show. In fact, the runoff was more like the General Election than
Carter Jones even realized. Around 30-35% (estimate from other emails
above) of the received absentee ballots couldn’t be verified through the ENET
system. Prior to December 29th all 30-35% of the ballots not in ENET had to
be sent from GWCC to Peachtree for verification and if accepted sent back to
GWCC. So, ballots were bouncing around from location to location, which
even elections director Richard Barron wasn’t aware of. So yes, Fulton County
did make improvements in the Runoff by performing signature verification,

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but what Carter Jones witnessed and believed to be correct about the
process was not.

(Carter Jones Monitor Report - Exhibit J)

This statement regarding the General Election, included in Carter

Jones' report should be corrected, as it also applies to the January 2021
Runoff.

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Rick Barron questions why an absentee processing spreadsheet
tracking the number of ballots was missing data in multiple columns. The
numbers didn’t add up by all accounts. Ryan Macias from the Elections Group
explained that 16,913 ballots went to Peachtree for verification and research.
At that time, they didn’t have any data on those ballots. Ryan continues with
“until the data is provided, the 16,913 will remain in “research” status- making
the number look inflated.” Rick Barron, confused about the situation, checked
with Ralph who said, “they didn’t have enough bins to have that many in
research.” The chain of custody problems from the General Election were
never resolved and persisted in Fulton County throughout the Runoff.

THE DATA

Ralph Jones’s testimony details the initial process an absentee ballot

must go through once received.

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(Ralph Jones Testimony - Exhibit M)

When a ballot first comes in the mailroom, it gets stamped with a

date/time. Then, they must verify a signature is present (any signature or
mark) on the envelope and that the ballot belongs to Fulton County.
Following that, voter credit is given to the voter to document the ballot was
returned and the date it was received. Then after all those steps are
completed the ballot is sent to signature verification. The steps Ralph Jones
documents here, are important to consider looking at the absentee voter
data below.

The Secretary of State’s absentee voter file for the November 3rd, 2020,
General Election was used by Fulton County to create the following pivot
chart. This shows only Fulton County’s rejected ballots, sorted by reason for
rejection and the date Fulton received the ballot.

32
Fulton County had a total of 146,029 absentee-by-mail ballots cast in
the 2020 General Election. The chart above shows they rejected a total of 36
absentee ballots with invalid mismatched signature. Out of the 36 invalid
signatures only 6 have a documented date/time showing when the ballot
was received. How do you reject a ballot for an invalid signature that wasn’t
received or returned to Fulton County? Ralph’s testimony is important
because he clearly states that voter credit is given, and the date received
logged prior to signature verification. If the ballot was missing a signature the
date didn’t need to be logged, it would go straight to curing.

Out of the 36 total rejected invalid signature ballots in Fulton County,

30 were never recorded as being returned or received in the mailroom. The
total absentee ballots documented as received by Fulton County and
subsequently rejected for an invalid signature in the General Election is 6. The
number between 5 and 7. A small token of rejected ballots to say they
conducted signature verification.

Fulton County’s signature verification rejection rate for the 2020

General Election was = 0.00004109 or 0%. Fulton County’s failure to
,

33
follow the law disenfranchised voters across the state of Georgia, considering
they make up 11% of the state’s absentee-by-mail votes.

An article by the MIT Election Data and Science Lab discusses the
differences found in Georgia’s number of absentee signature rejections
between the 2020 General Election and the 2021 Runoff.

MIT Election Data & Science Lab -The Shifting Standards of Signature Matching in Georgia | MIT Election Lab

This would imply that either, little to no signature verification occurred

across the state for the General Election (Fulton County was not alone) or
there were much stricter signature requirements during the Runoff.

State of Georgia v. Harrison Floyd Proceedings

On January 19, 2024, a hearing was held in Fulton County Superior Court
for Defendant Harrison Floyd (case 21-cv-2024) on a subpoena for 2020 election
records. At issue was the amount of time Fulton County estimated it would
take to produce images of the ballot envelopes bearing the signature of each
voter- and the images of the signatures on file for each registered voter. Those
two images would have been used to comply with the mandatory signature
verification process required by Georgia law, and the terms of the Consent
Agreement. In response to the subpoena, Fulton County estimated that it
would require 57,406 hours to produce images of the absentee ballot
envelopes and registered voter signature exemplars. 4

4
Harrison Floyd subpoena with Fulton County’s time estimates (interspersed) is attached ___________

34
Executive assistant and Fulton County BRE Secretary, Mariska Bodison,
and the attorney for Fulton County, admitted that they did not use the
Bluecrest machine to scan absentee ballot envelopes for the 2020 General
Election:5

Harrison Floyd's Attorney:

Your honor, the Blue Crest sorting and signature verification

machine would take the ballot envelope and scan it and create an
image of it. The image appears on screen with a signature
exemplar, and the two are compared that way. Now it’s my
understanding that the Blue Crest sorting and signature
verification machine was not working?

Fulton County Attorney:

No. We did not use it.

Judge:

They didn’t use that. So for the item you’re requesting to obtain for
the scans of all the outer envelopes, they would have to rescan
those again- is what we’re hearing.

Harrison Floyd's Attorney:

It sounds like they were never scanned to begin with. If they were
scanned I want the scanned version. That they had on that day.

Judge:

So are there any documents in the County’s possession of these

items having already been scanned?

Fulton County Attorney:

Not that I’m aware of, but I can check at headquarters and see if
they do have it.

5
Video of the proceeding can be found here: https://youtu.be/TmKFa4ASFjM?t=4453

35
Judge:

So the difference here is not so much there’s a total new

rescanning, it’s what was scanned and still in your possession from
that day. Are we making the distinction here?

Mariska Bodison:

Nothing was scanned, your honor.

Ms. Bodison testified (under oath) that the absentee ballot envelopes
were never imaged. “Nothing was scanned, your honor” is the cold, hard fact
we’re only hearing after four years of lies, gaslighting, and concealment. This
means they did not take images of the signatures on the absentee ballot
envelopes with which to compare to the voter’s signature on file. Without
images of the ballot envelopes- signature verification would have been
impossible with the circumstances, time, training, space, workstations, and
labor required.

CONCLUSION

Fulton County estimated some 57,000 hours just to scan the ballot
envelopes and provide the images of voter signatures already on file. Given the
time needed to conduct a “manual" signature verification i.e. having to
physically look at every outer return envelope’s signature (while maintaining
chain of custody of each envelope) then looking up the voter in the State’s
voter registration database or if necessary the county’s RocketFile database for
the signature comparison, and documenting each ballot envelope in
accordance with Georgia law this would have required an army of trained
workers, space for that army, oversight, and management which did not occur.

Under 2020 law it was illegal to count a vote without first verifying the
signature on the oath. It was not a choice given to the counties; it was an

36
unambiguous statutory requirement written in law to perform. There was no
signature verification for Fulton County’s 2020 Primary Election, and there was
no signature verification for Fulton County’s 2020 General Election.

For the past four years citizens have been investigating the 2020 General
Election and working to secure our future elections. These citizens have
sacrificed both time and their own money to do what the Secretary of State
and other elected officials should have been doing all along. Regardless, with
their help or without it, we will continue to seek the truth and expose the lies.
The purpose of this complaint is not to overturn the 2020 election results, but
to ensure that the same unlawful procedures, blatant inaccuracies & mistakes
don’t happen again. Or is it proper to say again, again, and again? Due to the
egregious actions taken by officials in GA we also feel at a minimum, the record
should be updated to reflect the truth… NO signature verification was done in
Fulton County during the 2020 election cycle!

The truth is, Fulton County has repeatedly broken the law because there
is no accountability. Getting punished, with the same punishment you were
already punished with before for the very same thing is insanity. It hasn’t
worked in the past and it’s not going to work now.

The Georgia legislature has vested the State Election Board with the duty
and authority to investigate election frauds and irregularities, including to
subpoena records and conduct hearings of ANY persons (GA Code § 21-2-33).
The Board, and only the Board, has the power, authority, and duty to
successfully pursue its mandate: to investigate frauds, irregularities and to
prevent reoccurrence. We have provided the investigation and the evidence.
Please fulfill your responsibility to the voters of Georgia and this Republic. The
people of Georgia deserve true, fair, and accurate elections and they are
depending on you!

Wherefore, due to the foregoing, complainants seek the following relief:

1. Open an investigation into this matter, to be conducted by

investigators chosen by the SEB and provide a case
number immediately.

37
2. Pass a resolution to issue a subpoena to Fulton County for
scanned images of the ballot signature envelopes and the
signature exemplars on file for every Fulton County voter
who received credit for casting an Absentee by-mail ballot
for the 2020 General Election.

3. Pass a resolution which finds that Fulton County willfully

failed to comply with the terms of the October 2020
consent agreement. And because the waiver of the
$50,000 fine was subject to compliance with those terms,
reissue Fulton County a fine for $50,000 for the 2020
primary.

4. Pass a resolution which finds that by repeatedly and

intentionally failing to comply with the terms of the
consent agreement and willful violations of GA Code § 21-2-
385 (2020), Fulton County’s actions have eclipsed the
threshold for willful misconduct resulting in the
disenfranchisement of thousands of Georgia voters. Issue
Fulton County a fine as the SEB finds is just and proper.

5. Pass a resolution which makes an official finding of fact

that Fulton County willfully and knowingly failed to perform
absentee ballot signature verification as required and in
accordance with Georgia law during the 2020 election
cycle.

6. Any other relief that the Board deems necessary.

38
Dated: October 15, 2024
San Antonio, Texas

RESPECTFULLY SUBMITTED,

MELISSA /S/ WHITE .

MELISSA WHITE ROCHELLE /S/ CABIRAC
18838 STONE OAK PKWY ROCHELLE CABIRAC
SUITE 106 911 WILKINSON STREET
SAN ANTONIO TX 78258 SHREVEPORT, LA 71104
(210) 441-8989 (469) 207-5563
[email protected] [email protected]

39
TABLE OF CONTENTS
Signature Verification Complaint Exhibits

Exhibit A Compromised Settlement Agreement 2

Exhibit B 5/1/2020 Official Election Bulletin 9

Exhibit C Fulton County Consent Order 13

Exhibit D Mark Wingate’s Sworn Affidavit 29

Exhibit E 7/22/2020 Vote at Home Correspondence 47

Exhibit F CTCL Partner Support Example 49

Exhibit G 10/8/2020 Fulton County BRE Meeting 53

Exhibit H Mark Wingate Testimony 61

Exhibit I 11/13/2020 Fulton County BRE Meeting 181

Exhibit J Carter Jones Monitor Report 193

Exhibit K 11/20/2020 BlueCrest Proposal 195

Exhibit L 12/9/2020 Official Election Bulletin 200

Exhibit M Ralph Jones Testimony 203

Exhibit N Harrison Floyd Amended Subpoena 481

Exhibit O Trump v. Raffensperger Election Contest 496

Exhibit P Trump Lawsuit Exhibit 10 561

Page 1
Exhibit A
Compromised Settlement Agreement

Page 2
COMPROMISE SETTLEMENT AGREEMENT AND RELEASE

This Compromise Settlement Agreement and Release ("Agreement") is

made and entered into by and between the Democratic Party of Georgia, Inc.
("DPG"), the DSCC, and the DCCC ( collectively, the "Political Party Committees"),
on one side, and Brad Raffensperger, Rebecca N. Sullivan, David J. Worley, Seth
Harp, and Anh Le ( collectively, "State Defendants"), on the other side. The parties
to this Agreement may be referred to individually as a "Party" or collectively as the
"Parties." The Agreement will take effect when each and every Party has signed it,
as of the date of the last signature (the "Effective Date").

WHEREAS, in the lawsuit styled as Democratic Party of Georgia, et al. v.

Rajfensperger, et al., Civil Action File No. 1: 19-cv-5028-WMR (the "Lawsuit"), the
Political Party Committees have asserted claims in their Amended Complaint [Doc.
30] that the State Defendants' (i) absentee ballot signature matching procedure, (ii)
notification process when an absentee ballot is rejected for any reason, and
(iii) procedure for curing a rejected absentee ballot, violate the First and Fourteenth
Amendments to the United States Constitution by unduly burdening the right to vote,
subjecting similarly situated voters to disparate treatment, and failing to afford
Georgia voters due process (the "Claims"), which the State Defendants deny;

WHEREAS, the State Defendants, in their capacity as members of the State

Election Board, adopted on Febniary 28, 2020 Rule 183-1-14-.13, which sets forth
specific and standard notification procedures that all counties must follow after
rejection of a timely mail-in absentee ballot;

WHEREAS, the State Defendants have a Motion to Dismiss [Doc. 45]

pending before the Court, which sets forth various grounds for dismissal of the
Amended Complaint, including mootness in light of the State Election Board's
promulgation subsequent to adoption on Febrnary 28, 2020 of Rule 183-1-14-.13,
which Motion the Political Party Committees deny is meritorious;

WHEREAS, all Parties desire to compromise and settle all disputed issues
and claims arising from the Lawsuit, finally and fully, without admission of liability,
having agreed on the procedures and guidance set forth below with respect to the
signature matching and absentee ballot rejection notification and cure procedures;
and

WHEREAS, by entering into this Agreement, the Political Party Committees

do not concede that the challenged laws and procedures are constitutional, and

Ex. A to TRO Motion:

Litigation Settlement

Page 3
commence the notification procedure set forth in O.C.G.A. § 21-2-
386(a)(l)(C) and State Election Board Rule 183-1-14-.13.

(b) The Parties agree that the guidance in paragraph 3 (a) shall be issued in
advance of all statewide elections in 2020, including the March 24, 2020 Presidential
Primary Elections and the November 3, 2020 General Election.

4. Consideration of Additional Guidance for Signature Matching.

The State Defendants agree to consider in good faith providing county registrars and
absentee ballot clerks with additional guidance and training materials to follow when
comparing voters' signatures that will be drafted by the Political Party Committees'
handwriting and signature review expert.

5. Attorneys' Fees and Expenses. The Parties to this Agreement shall

bear their own attorney's fees and costs incurred in bringing or defending this action,
and no party shall be considered to be a prevailing party for the purpose of any law,
statute, or regulation providing for the award or recovery of attorney's fees and/or
costs.

6. Release by The Political Party Committees. The Political Party

Committees, on behalf of themselves and their successors, affiliates, and
representatives, release and forever discharge the State Defendants, and each of their
successors and representatives, from the prompt notification of absentee ballot
rejection and signature match claims and causes of action, whether legal or equitable,
in the Lawsuit.

7. No Admission of Liability. It is understood and agreed by the Parties

that this Agreement is a compromise and is being executed to settle a dispute.
Nothing contained herein may be construed as an admission of liability on the part
of any of the Parties.

8. Authority to Bind; No Prior Assignment of Released Claims. The

Parties represent and Warrant that they have full authority to enter into this
Agreement and bind themselves to its terms.

9. No Presumptions. The Parties acknowledge that they have had input

into the drafting of this Agreement or, alternatively, have had an opportunity to have
input into the drafting of this Agreement. The Parties agree that this Agreement is
and shall be deemed jointly drafted and written by all Parties to it, and it shall be
interpreted fairly, reasonably, and not more strongly against one Party than the other.

4
Ex. A to TRO Motion:
Litigation Settlement
Page 6
Accordingly, if a dispute arises about the meaning, construction, or interpretation of
this Agreement, no presumption will apply to construe the language of this
Agreement for or against any Party.

10. Knowing and Voluntary Agreement. Each Party to this Agreement

aclmowledges that it is entering into this Agreement voluntarily and of its own free
will and accord, and seeks to be bound hereunder. The Parties further acknowledge
that they have retained their own legal cotmsel in this matter or have had the
opporttmity to retain legal counsel to review this Agreement.

11. Choice of Law, Jurisdiction and Venue. This Agreement will be

construed in accordance with the laws of the State of Georgia. In the event of any
dispute arising out of or in any way related to this Agreement, the Parties consent to
the sole and exclusive jurisdiction of the state courts located in Fulton Cotmty,
Georgia. The Parties waive any objection to jurisdiction and venue of those courts.

12. Entire Agreement; Modification. This Agreement sets forth the entire
agreement between the Parties hereto, and fully supersedes any prior agreements or
understandings between the Parties. The Parties acknowledge that they have not
relied on any representations, promises, or agreements of any kind made to them in
connection with their decision to accept this Agreement, except for those set forth in
this Agreement.

13. Counterparts. This Agreement may be executed in counterparts which,

taken together, will constitute one and the same Agreement and will be effective as
of the date last set forth below, and signatures by facsimile and electronic mail will
have the same effect as the originals.

IN WITNESS WHEREOF, the Parties have set their hands and seals to
this instrument on the date set forth below.

5
Ex. A to TRO Motion:
Litigation Settlement
Page 7
Dated: March 6, 2020

Isl Bruce V. Spiva Isl Vincent R. Russo

Marc E. Elias* Christopher M. Carr 112505

Bruce V. Spiva* Attorney General
John Devaney* Bryan K. Webb 743580
Amanda R. Callais* Deputy Attorney General
K'Shaani Smith* Russell D. Willard 760280
Emily R. Brailey* Senior Assistant Attorney General
PERKINS COIE LLP Charlene S. McGowan 697316
700 Thirteenth Street, N.W., Suite 800 Assistant Attorney General
Washington, D.C. 20005-3960 Office of the Georgia Attorney
Telephone: (202) 654-6200 General
Facsimile: (202) 654-6211 40 Capitol Square S.W.
[email protected] Atlanta, GA 30334
[email protected] [email protected]
[email protected] Telephone: (404) 656-3389
[email protected] Facsimile: (404) 651-9325
[email protected]
Vincent R. Russo
*Admitted Pro Hae Vice Georgia Bar No. 242628
[email protected]
Halsey G. Knapp, Jr. Josh Belinfante
Georgia Bar No. 425320 Georgia Bar No. 047399
Joyce Gist Lewis [email protected]
Georgia Bar No. 296261 ROBBINS ROSS ALLOY
Adam M. Sparks BELINFANTE LITTLEFIELD
Georgia Bar No. 341578 LLC
KREVOLIN & HORST, LLC 500 14th Street, N.W.
One Atlantic Center Atlanta, Georgia 30318
1201 W. Peachtree St., NW, Suite 3250 Telephone: (678) 701-9381
Atlanta, GA 30309 Facsimile: (404) 856-3250
Telephone: (404) 888-9700
Facsimile: (404) 888-9577 Counselfor State Defendants
[email protected]
[email protected]

Counselfor Plaintiffs

6
Ex, A to TRO Motion:
Litigation Settlement
Page 8
Exhibit B
5/1/2020 Official Election Bulletin

Page 9
OFFICIAL ELECTION BULLETIN
May 1, 2020
_____________________________________________________________________________________________

TO: County Election Officials and County Registrars

FROM: Chris Harvey, State Elections Director

RE: Absentee Ballot Signature Review Guidance

______________________________________________________________________

Verifying that a voter’s signature on his or her absentee ballot matches his or her
signature on the absentee ballot application or in the voter registration record is required
by Georgia law and is crucial to secure elections. Ensuring that signatures match is even
more crucial in this time of increased absentee voting due to the COVID-19 crisis. The
purpose of this OEB is to remind you of some recent updates to Georgia law and
regulations regarding verifying signatures on absentee ballots and to make you aware of
the procedures that should be followed when a signature on an absentee ballot does not
match. HB 316, which passed in 2019, modified the absentee ballot laws and the design
of the oath envelope. The State Election Board also adopted Rule 183-1-14.13 this year,
which addresses how quickly and by what methods electors need to be notified
concerning absentee ballot issues. What follows are the procedures that should be
followed when the signature on the absentee ballot does not match the voter’s signature
on his or her application or voter registration record:

County registrars and absentee ballot clerks are required, upon

receipt of each mail-in absentee ballot, to compare the signature or
mark of the elector on the mail-in absentee ballot envelope with the
signatures or marks in eNet and on the application for the mail-in
absentee ballot. If the signature does not appear to be valid, registrars
and clerks are required to follow the procedure set forth in O.C.G.A. §
21-2-386(a)(1)(C).
Page 1 of 3

Page 10
When reviewing an elector’s signature on the mail-in absentee ballot
envelope, the registrar or clerk must compare the signature on the
mail-in absentee ballot envelope to each signature contained in such
elector’s voter registration record in eNet and the elector’s signature
on the application for the mail-in absentee ballot.1 If the registrar or
absentee ballot clerk determines that the voter’s signature on the mail-
in absentee ballot envelope does not match any of the voter’s
signatures on file in eNet or on the absentee ballot application, the
registrar or absentee ballot clerk must seek review from two other
registrars, deputy registrars, or absentee ballot clerks.

A mail-in absentee ballot shall not be rejected unless a majority of the

registrars, deputy registrars, or absentee ballot clerks reviewing the
signature agree that the signature does not match any of the voter’s
signatures on file in eNet or on the absentee ballot application. If a
determination is made that the elector’s signature on the mail-in
absentee ballot envelope does not match any of the voter’s signatures
on file in eNet or on the absentee ballot application, the registrar or
absentee ballot clerk shall write the names of the three elections
officials who conducted the signature review across the face of the
absentee ballot envelope, which shall be in addition to writing
“Rejected” and the reason for the rejection as required under OCGA
21-2-386(a)(1)(C). Then, the registrar or absentee ballot clerk shall
commence the notification procedure set forth in O.C.G.A. § 21-2-
386(a)(1)(C) and State Election Board Rule 183-1-14-.13.

1
Once the registrar or clerk verifies a matching signature, they do not need to continue to review additional
signatures for the same voter.
Page 2 of 3

Page 11
RULE 183-1-14-.13 Prompt Notification of Absentee Ballot Rejection

When a timely submitted absentee ballot is rejected, the board of registrars or absentee
ballot clerk shall send the elector notice of such rejection and opportunity to cure by
mailing written notice, and attempt to notify the elector by telephone and email, if a
telephone number or email is on the elector’s voter registration record or absentee ballot
application, no later than the close of business on the third business day after receiving
the absentee ballot. However, for any timely submitted absentee ballot that is rejected
within eleven days of Election Day, the board of registrars or absentee ballot clerk shall
send the elector notice of such rejection and opportunity to cure by mailing written notice,
and attempt to notify the elector by telephone and email, if a telephone number or email
is on the elector’s voter registration record or absentee ballot application, no later than
close of business on the next business day.

Page 3 of 3

Page 12
Exhibit C
Fulton County Consent Order

Page 13
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Page 28
Exhibit D
Mark Wingate’s Sworn Affidavit

Page 29
Fulton County Superior Court
***EFILED***KJ
Date: 7/27/2023 5:58 PM
Che Alexander, Clerk

IN THE SUPERIOR COURT OF FULTON COUNTY

STATE OF GEORGIA

FULTON COUNTY REPUBLICAN PARTY

Plaintiff,

v.
Case No. 2023CV382174
FULTON COUNTY BOARD OF
COMMISSIONERS, ROBB PITTS,
BRIDGET THORNE, BOB ELLIS, DANA
BARRETT, NATALIE HALL, MARVIN S.
ARRINGTON, JR., and KHADIJAH
ABDUR-RAHMAN,

Defendants.

NOTICE OF FILING

COMES NOW Attorney David Oles, Attorney for Plaintiff, and hereby gives

notice that he is filing the following:

A. AFFIDAVIT OF MARK WINGATE IN SUPPORT OF AMENDED COMPLAINT

FOR DECLARATORY JUDGMENT AND APPLICATION FOR WRIT OF
MANDAMUS

Respectfully submitted this 27th day of July, 2023.

/s/ David E. Oles, Sr.

David Edward Oles, Sr., Esq.
Georgia Bar No. 551544
5755 North Point Parkway
Suite 25
Alpharetta, GA 30022
(770) 753-9995
(877) 207-3883 (fax)
[email protected]

Notice of Filing
Page | 1
1
Page 30
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Page 44
IN THE SUPERIOR COURT OF FULTON COUNTY
STATE OF GEORGIA

FULTON COUNTY REPUBLICAN PARTY

Plaintiff,

v.
Case No. 2023CV382174
FULTON COUNTY BOARD OF
COMMISSIONERS, ROBB PITTS,
BRIDGET THORNE, BOB ELLIS, DANA
BARRETT, NATALIE HALL, MARVIN S.
ARRINGTON, JR., and KHADIJAH
ABDUR-RAHMAN,

Defendants.

CERTIFICATE OF SERVICE

I hereby certify that I have this day electronically filed and served NOTICE OF

FILING using the Odyssey e-File GA system, which automatically sends email

notification of such filing to all attorneys of record, and which constitutes effective

service upon all attorneys of record, including:

Kaye Woodard Burwell

[email protected]
Office of the Fulton County Attorney
141 Pryor Street, S.W.
Suite 4038
Atlanta, Georgia 30303

THIS 27th day of July, 2023.

/s/ David E. Oles, Sr.

David Edward Oles, Sr., Esq.
Georgia Bar No. 551544
Notice of Filing
Page | 2
2
Page 45
5755 North Point Parkway
Suite 25
Alpharetta, Georgia 30022
(770) 753-9995

Notice of Filing
Page | 3
3
Page 46
Exhibit E
7/22/2020 Vote at Home Correspondence

Page 47
From: Steve Struthers
To: Barron, Richard L.
Cc: Amber McReynolds; Hillary Hall; Jacob Panfel; Jones, Ralph; Ficklin, Caryn; Coman, Pamela
Subject: Re: Follow-up
Date: Thursday, July 23, 2020 11:57:14 AM
Attachments: Absentee Ballot Process Flow - Mural 07-22 v1.pdf
Absentee Ballot Application Process Flow - Mural 07-22 v2.pdf

Rick & Amber -

Attached are the DRAFT process flow diagrams that I produced following the conversation with Ralph and his team yesterday. One is of the ballot application process; the other is of
the process for managing the ballots once they are sent back by the voter. These might be helpful for our conversation later today.  

Steve

P.S. Just for clarification, I worked for Accenture for 5 years but am no longer currently with the firm.

On Wed, Jul 22, 2020 at 2:37 PM Barron, Richard L. <[email protected]> wrote:

Yes.

Steve Struthers went through the entire process with Ralph today. He is from Accenture. I should hook you all up with him. He is going to map our process.
________________________________________
From: Amber McReynolds [[email protected]]
Sent: Wednesday, July 22, 2020 3:24 PM
To: Barron, Richard L.
Cc: Hillary Hall; Jacob Panfel
Subject: Re: Follow-up

Ok - so it's not prohibited so we can work with blue crest to get you that software on your equipment. Also, how did that work for the primary - do you have a process document that
shows your current mail ballot process?

Amber McReynolds | CEO

<https://urldefense.proofpoint.com/v2/url?u=http-
3A__www.voteathome.org_&d=DwIGaQ&c=HPJvcKF4Kk5Wqru1T_u_fOsw8NVQVa3gp0ReMdlciXw&r=Ab1tWoBND5WPUindk9Sn4wStS2z-l-
4wem9O9RY2hRILrpnrnD9tMptAtAtHi9ii&m=4lb9PJJcLmDuY0lPmyOGQG5qZ7G7di3vGpTn3XdDVsw&s=y-L7QuIAjPuKpeUFROHReyYh0dZTCPoOHSnX9qawf9I&e= >
[email protected] | @Amber McReynolds <https://urldefense.proofpoint.com/v2/url?u=https-
3A__twitter.com_ambermcreynolds&d=DwIGaQ&c=HPJvcKF4Kk5Wqru1T_u_fOsw8NVQVa3gp0ReMdlciXw&r=Ab1tWoBND5WPUindk9Sn4wStS2z-l-
4wem9O9RY2hRILrpnrnD9tMptAtAtHi9ii&m=4lb9PJJcLmDuY0lPmyOGQG5qZ7G7di3vGpTn3XdDVsw&s=BxzIJpsI47O29ab5HebqarD9ortsXZsPubIgH76w8XQ&e= > |
@VoteAtHome <https://urldefense.proofpoint.com/v2/url?u=https-
3A__twitter.com_voteathome&d=DwIGaQ&c=HPJvcKF4Kk5Wqru1T_u_fOsw8NVQVa3gp0ReMdlciXw&r=Ab1tWoBND5WPUindk9Sn4wStS2z-l-
4wem9O9RY2hRILrpnrnD9tMptAtAtHi9ii&m=4lb9PJJcLmDuY0lPmyOGQG5qZ7G7di3vGpTn3XdDVsw&s=52jemLNRVWhY9ZTHAQwMfMXDGCZT3utQruATLTkQF3I&e=
>

On 7/22/20, 1:20 PM, "Barron, Richard L." <[email protected]> wrote:

I asked Ryan Germany today. We can use signature verification.

________________________________________
From: Amber McReynolds [[email protected]]
Sent: Wednesday, July 22, 2020 3:18 PM
To: Barron, Richard L.
Cc: Hillary Hall; Jacob Panfel
Subject: Follow-up

Hi Rick,
Thank you for taking time today and we look forward to follow-up calls. Jake and Hillary will coordinate that with you and your team.

I wanted to ask about one question. You mentioned state law doesn’t allow you to use automatic signature verification and thus the state told you that you could not. Can you
send us the applicable law or where the state said that? I really want to see what they are saying because I do not see the law that way and wonder if we can work that out. Also, with
the primary, it sounds like you did not compare signatures, other than to look and see that a signature was present for acceptance. This will help us think about how to work with you
to formulate plans for November.

Amber

Amber McReynolds | CEO

[cid:[email protected]]<https://urldefense.proofpoint.com/v2/url?u=http-
3A__www.voteathome.org_&d=DwMGaQ&c=HPJvcKF4Kk5Wqru1T_u_fOsw8NVQVa3gp0ReMdlciXw&r=Ab1tWoBND5WPUindk9Sn4wStS2z-l-
4wem9O9RY2hRILrpnrnD9tMptAtAtHi9ii&m=ebhLgg1mcPmWaJAu0Umh6ZKHdyFVwMT0gJYWD8la67w&s=hkH_acighqAWohSylj4f6kVN6nD5Aw3FKQQfU0QR4vw&e=>
[email protected]<mailto:[email protected]> | @Amber McReynolds<https://urldefense.proofpoint.com/v2/url?u=https-
3A__twitter.com_ambermcreynolds&d=DwMGaQ&c=HPJvcKF4Kk5Wqru1T_u_fOsw8NVQVa3gp0ReMdlciXw&r=Ab1tWoBND5WPUindk9Sn4wStS2z-l-
4wem9O9RY2hRILrpnrnD9tMptAtAtHi9ii&m=ebhLgg1mcPmWaJAu0Umh6ZKHdyFVwMT0gJYWD8la67w&s=JR8pioC7SSGZh3RN4JCiJpASxnQB8wsHQjzmRA3OJMc&e=>
| @VoteAtHome<https://urldefense.proofpoint.com/v2/url?u=https-
3A__twitter.com_voteathome&d=DwMGaQ&c=HPJvcKF4Kk5Wqru1T_u_fOsw8NVQVa3gp0ReMdlciXw&r=Ab1tWoBND5WPUindk9Sn4wStS2z-l-
4wem9O9RY2hRILrpnrnD9tMptAtAtHi9ii&m=ebhLgg1mcPmWaJAu0Umh6ZKHdyFVwMT0gJYWD8la67w&s=-zRiRthMg6ZJJtcRGH4q1LPpEcDd7mAxnVYvy_b5wfI&e=>

Page 48
Exhibit F
CTCL Partner Support Example

Page 49
Page 50
Page 51
Page 52
Exhibit G
10/8/2020 Fulton County BRE Meeting

Page 53
APPROVED MINUTES

BOARD OF REGISTRATION AND ELECTIONS

REGULAR MEETING – OCTOBER 8, 2020
The Fulton County Board of Registration and Elections met in Regular Session on Thursday, October 8, 2020
at 10:00 a.m.

VIRTUAL MEETING
Please join the meeting from your computer, tablet or smartphone.
FGTV YouTube Channel
https://www.youtube.com/channel/UCYH7E0jH6HxE-3KTRluH8SQ

Presiding: Ms. Mary Carole Cooney, Chairperson

Other Board Members Present:

Ms. Vernetta Keith Nuriddin, Vice Chairperson
Mr. Mark Wingate
Mr. Aaron V. Johnson
Dr. Kathleen Ruth

Staff Attending: Mr. Richard Barron, Director; Mr. Ralph Jones, Registration Chief; Mr. Dwight Brower, Interim
Elections Chief; Ms. Sharon Benjamin, Deputy Elections Chief; Ms. Nadine Williams, Elections Equipment
Manager; Mrs. Pamela Coman, Registration Manager; Ms. Brenda McCloud, Administrative Manager; Mrs.
Cheryl Ringer, County Attorney; Mr. David Lowman, County Attorney; Mr. James Reese, Production Manager;
Mr. Rico Dollar, Senior Graphics Designer, Jessica Corbitt, PIO; Regina Waller, Senior Public Affairs Officer

Guest Attending: David Ross (Democratic Party of Georgia), Rhonda Martin (Coalition of Good Governance),

Chairperson Cooney announced that this teleconferenced meeting is authorized pursuant to §50-14-
1(g) of the Official Code of Georgia because of the Public Health State of Emergency declared by
Governor Kemp on March 14, 2020, and renewed most recently on September 30, 2020, pursuant to
which public meeting spaces in state and local Government have been closed due to COVID-19, and
because means have been afforded for the public to have simultaneous access to this teleconference.

#1– APPROVAL OF AGENDA

Chairperson Cooney entertained a motion to approve the agenda as amended. The motion was made
by Mr. Wingate, seconded by Mr. Johnson and carried by a unanimous vote of 5-0.

#2– COMMUNICATIONS AND PUBLIC RESPONSE

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Approved Minutes
Regular Meeting- October 8, 2020
2|P a g e

Rhonda Martin (Coalition for Good Governance) informed the public that the Election Day Poll that she visited
performed well and appeared to be well trained. Ms. Martin expressed that her issue was the poll manager
impeding on her ability to properly perform her role effectively as a Poll Watcher.

Lori Shellenberger (Brennan Center of Justice) thanked the BRE & DRE for their service. Ms.
Shellenberger outlined a number of changes the county has implemented for the upcoming election to make
the election more effective and efficient for registered voters. Although, this is an improvement, Ms.
Shellenberger expressed concerns with the increased number of emergency/ provisional ballots being
considered as adequate by the county’s standard but inadequate by the Brennan Center of Justice.

OLD BUSINESS

#3- APPROVAL OF MINUTES

 Special Meeting- September 4, 2020

 Regular Meeting- September 14, 2020
 Executive Session Meeting- September 14, 2020
 Special Meeting- September 29, 2020
 Executive Session Meeting- September 29, 2020

Chairperson Cooney entertained a motion to approve the meeting minutes from the Regular, Special
and Executive Session Meetings on September 4th, 14th, and 29th, 2020. The motion was made by Mr.
Wingate, seconded by Ms. Nuriddin and carried by a unanimous vote of 5-0.

#4– MONTHLY OPERATIONS REPORT FOR SEPTEMBER 2020:

th th
 Preparation for September 29 , Special Election for 5 Congressional District
th th
 Early Voting (EV) began September 8 – September 25
th
 94 polling locations for September 29 Election
rd
 Senate District 39 will be in the November 3 , General/ Special Election as a Democratic Primary:
 54 Polling locations with 87 precincts involved
 Absentee By Mail (ABM) voters will receive ballots with the race included.
 In-person voter will need to decide to receive a ballot with or without the race
 DO NOT ASK PARTY AFFILIATION
 Election Day Allocations for General/ Special Election delivered to SOS, for logistic review
 All Training was in-person
 Bandwidth resolution- Ongoing
 Risk Limiting Audit Training
th st
 November 9 Early Voting will begin for the December 1 Runoff
th
 A legal hold remains on the DRE voting units from the April 18, 2017 and June 20, 2017 6
Congressional Special Election and Runoff Special Election (Relocated to offsite facility)
 Additional Polling locations to decrease the amount of voters assigned
 Total voter registration applications received in 2020: 238,227
 39,572 voter registration applications received in September
st
 As of October 1 , 838,626 (796,890 active and 41,636 inactive) registered voters reside in Fulton County
 Total New Applications: 97,191
 Felon Hearings: 0

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Regular Meeting- October 8, 2020
3|P a g e

 Felon Letters Mailed: 432

 2- Active Call Centers with more than 50 additional staff
th
 Runbeck will mail Absentee By Mail, initial mail out beginning September 19
th
 Mail out by vendor will conclude on October 16
th
 Absentee By Mail Process ( opening and scanning) will begin at State Farm Arena on October 19
 Tracking Mechanism Created by Secretary of State’s (SOS) office for processed ABM applications:
th
 Applications processed by October 15 can be tracked: https://georgia.ballottrax.net/voter/
 VEO Team scheduling Demonstration via Zoom and In-person, following CDC Guidelines
 Four Funded Positions:
 Deputy Director
 Elections Officer
 Elections System Assistant Supervisor
 VEO Coordinator
 Safe and Secure Voting
 Steering Committee (Committee Members):
 Richard Barron, Director of DRE
 Mary Carole Cooney, Chairperson of BRE
 Robb L. Pitts, Chairman of BOC
 Marvin Arrington, Vice Chairman of BOC
 Patrise Perkins-Hooker, County Attorney
 Dick Anderson, County Manager
 Anna Roach, Deputy Chief
 Sharon Whitmore, Deputy Chief Financial Officer

Mr. Barron explained the committee will meet weekly, meetings beginning this week starting with Risk
Assessment ensuring a safe and secure election. The committee will be briefed by the Federal Bureau of
Investigations (FBI). Mr. Barron explained contractually the DRE is obligated to provide security for certain
mandated polling location; however, the DRE intends to provide security for all polling locations this election.

Mr. Wingate inquired about the application to ballot status; is the issue date the mail out date

Mr. Barron responded by updating the BRE on his application, to ballot mailed, to ballot received cycle:
st
 Issued Date in ElectioNet: September 21
th
 Ballottrax Tracking Date: September 24 ; SOS tracking mechanism
th
 Ballot Postmarked Date: September 26
rd
 Delivery Date: October 3

Mr. Barron surmised that based on his personal experience and voters that he’s spoken to, ballots are arriving in the
mail within 7-14 days from the issued date.

Mr. Barron informed the BRE:

Ballots Mailed: 183,915
Applications Received: 222,130
Applications Processed: 217,646, not including duplicates
As of this meeting
Duplicates: Over 33K
SOS Portal Duplicates: 126

Mr. Wingate inquired about the BlueCrest platform

Mr. Barron informed the Board that the DRE has not begun the mailing of ABM; however, the DRE is currently
using BlueCrest as a mail sorter. Mr. Barron directed Mr. Jones to expound

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Regular Meeting- October 8, 2020
4|P a g e

Mr. Jones mentioned the Technician from BlueCrest was onsite to assist the DRE by enabling the DRE to
complete signature verification and give voters credit for voting, while maintaining the security of ballots

Mr. Barron informed the BRE that the ABM received 39,274 and 35,500 ballots were scanned, thus far

Mr. Barron mentioned the usage of the 37 drop boxes and their locations and the DRE will add one more to
Chattahoochee Hills (Chatt Hills) to total 38 Drop box locations. Mr. Barron mentioned the additional drop
boxes and surveillance systems were purchased with grant funds totaling $85,000 from Southern Poverty Law
Center.

Ms. Nuriddin encouraged voters to utilize the My Voter Page from the SOS website to ensure their ballot was
accepted. Ms. Nuriddin mentioned the goal is to reduce the amount of rejected ballots. Thereafter, Ms.
Nuriddin inquired about the funding for drop box at Chatt Hills

Mr. Barron answered yes, the grant funds paid for the drop box, the surveillance equipment, and video
storage

Mr. Johnson expressed gratitude for the DRE getting the EV location in Palmetto Library. Mr. Johnson
mentioned the inquiries regarding the inside envelope of the ballot being glued together

Mr. Jones mentioned it’s not required, it’s for privacy purposes and the only envelope required is the outside
envelope with the oath on the back for the voter’s signature

Mr. Barron expressed concerns about voters voting without using the outside envelope and returning via the
drop box. The DRE has seen ballots being returned without the outside envelope/ Oath; this makes the ballot
invalid because the DRE does not have the ability to identify the voter to cure the ballot. The DRE has
received at least 12-15 ballots, thus far

Mr. Johnson expressed gratitude for the DRE getting the EV location in Palmetto Library operational. Mr.
Johnson inquired about the call center on Election Day, if there is an issue with locating their polling locations

Mr. Barron answered yes and there will be at least a 100 people staffing all three call centers and additional
staff in the office responding to all inquiries

Dr. Ruth inquired about the bandwidth challenges at the Election Preparation Center (EPC) the DRE has
encountered, and asked if the cachebox was procured

Mr. Barron answered yes and five Meraki devices installed. Mr. Barron explained the process for uploading
the poll pads with the Cachebox and the Meraki devices
 Cachebox pulls the bulk file
 Cachebox pushes to the Meraki device
 Meraki device distributes the bulk file at 1Gig instead of slower Megabytes
 Significant Reduction in time to upload the Statewide bulk file

Mr. Barron mentioned the DRE purchased cradle points for all precincts to check on the status of all poll pads,
the DRE was given access to EPulse the software that manages the poll pads

Dr. Ruth inquired about the confidence of the adjustments made to be ready for Election Day

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Regular Meeting- October 8, 2020
5|P a g e

Mr. Barron stated yes

Dr. Ruth inquired about signature verification, what happens if a voter signature cannot be verified

Mr. Jones stated the DRE must notify the voter by mail with regards to mismatches or no signature. However,
if they signed up for Ballottrax the voter will be notified via email. The voter has until the Friday (November 6,
2020) after the election to cure their ballot.

Dr. Ruth suggested that External Affairs notify voters about the length of time it’s taking for voters to receive
their ballot in the mail on the website

Dr. Ruth inquired about a report from SOS with regards to the polling locations equipment allocations for each
polling location. Dr. Ruth directed Mr. Barron to update the BRE upon receipt

Mr. Barron mentioned that he will inquire about SOS findings. Mr. Barron mentioned to the BRE that he will
represent Fulton County on a Bipartisan Committee led by the SOS.

NEW BUSINESS

#5- OVERVIEW OF SEPTEMBER 29, 2020, SPECIAL ELECTION

Mr. Barron provided the vast majority of this item in item# 4. Mr. Barron mentioned the silver lining was
having the ability to complete hands on training with new managers and poll workers ahead of the General.
Special Election. Mr. Barron noted with 94 polling locations training, preparation and deployment continue to
be vital for operations.

#6- CERTIFY ELECTION RESULTS: September 29th Special Election

th
 Unexpired Term for 5 Congressional District (US House D5)

Mr. Barron provided statistics for this election. The two candidates advancing to the December Runoff Election
for the listed seat: Robert M. Franklin and Kwanza Hall

Registered Voters: 379,123

Votes Cast 21,746
Election Day 12,134
Early Voting 8,733
ABM/VBM 485
Provisional 394

Chairperson Cooney asked Mr. Barron was it his certification and testimony that the election results
presented are a true and accurate count of all the votes cast in the Special Election held on September 29,
2020.

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Regular Meeting- October 8, 2020
6|P a g e

th
 Unexpired Term for the 5 Congressional District

Mr. Barron answered yes ma’am.

Chairperson Cooney entertained a motion to certify the election results. The motion was made by Mr.
Johnson, seconded by Dr. Ruth and carried by a unanimous vote of 5-0.

#7- UPDATE OF PREPARATION FOR THE GENERAL AND SPECIAL ELECTION

Mr. Barron informed the BRE:

 Any absentee Inquiries can be resolved by visiting the website: fultonelections.com or phone: 404-612-7060
th
 Post office recommending voters request ballot by October 20
 Requesting an Absentee Ballot: https://ballotrequest.sos.ga.gov/
 Ballots returned to date: 39,274
 Ballot requests are being processed within 24-48 hours
th
 Ballots requested before October 16 will be mailed by Runbeck
 Dominion currently onsite to test printers to begin mail out sooner
 Ballottrax will be available for ballots mailed by Runbeck
 Permanent 30-EV locations (6 more locations than in 2016)
o Mega Sites: State Farm Arena, Benson Center, & Georgia Convention International Center
o 3 -Senior Centers
o 3- State Colleges
o 2- 38ft Mobile Voting RVs
o 33-35 voting locations per day
th
 Mobile RVs will be at various locations from October 12-27
th th
o On the 29 -30 will be utilized as an overflow
 Great Partnerships established throughout the county
 37 Drop Boxes and adding an additional locations at Chattahoochee Hills
 Fulton App available on Google Play and Apple Store
 Various Informative Mailers sent to voters
 All media outlets are being utilized throughout the county:
o Marta Public Transportation
o Billboards
o Digital Media
o Direct Mailers
o Know Before You Go; Skip the Lines, Vote Early;
 40% of Provisional supplies will be assigned to each polling location

Mr. Johnson suggested that the DRE streamline the information given to voters by directing the voters to
fultonelections.com for all their information needs

#8- PUBLIC CONCERN WITH DOMINION NEW SOFTWARE INSTALLATION

Chairperson Cooney announced that the listed item was added due to the increasing concerns raised by
several voters who sent several emails with regards to SOS approving a software upgrade to the voting
equipment. Chairperson Cooney directed Mr. Barron and Attorney Ringer to provide insight.

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Approved Minutes
Regular Meeting- October 8, 2020
7|P a g e

Mr. Barron explained that he did not witness this software change but the issue stems from the Senate race
with over 20 candidates that did not display all the candidates’ names on the same screen. The software
added would fix this issue and allow all the candidates on one screen in columns. SOS stated this was a De
Minimis change submitted to the Election Assistance Commission (EAC).
 De Minimis Change can be approved in 1-5 days
 Non-De Minimis change can take longer to approve 2-4 months
 Dominion has a team onsite completing those changes
 the DRE will complete L&A testing upon the completion of the software update

Attorney Ringer explained that the BRE was provided documentation on the Dominion fix to the issue from
the SOS. Attorney Ringer recommended the BRE & DRE move forward with utilizing the State Certified
Election equipment, the Unified State System

EXECUTIVE SESSION

The Board did not convene into executive session.

ADJOURNMENT

With no other items requiring the Board’s action, Chairperson Cooney entertained a motion to adjourn. Mr.
Wingate moved to adjourn the meeting. Dr. Ruth seconded the motion. Collectively, the Board agreed to
adjourn at 11:22 a.m.

The meeting adjourned.

Prepared by,

Mariska Bodison, Board Secretary

Page 60
Exhibit H
Mark Wingate Testimony

Page 61
Date: April 1, 2024

Case: Board on Professional Responsibility: In Re Jeffrey Clark

Ace-Federal Reporters, Inc.

Phone: 202-347-3700
Fax: 202-737-3638
Email: [email protected]
Internet: www.acefederal.com

Page 62
Board on Professional Responsibility: In Re Jeffrey Clark
April 1, 2024

DISTRICT OF COLUMBIA COURT OF APPEALS

BOARD ON PROFESSIONAL RESPONSIBILITY
HEARING COMMITTEE NUMBER 11

---------------------------x
In the Matter of: : Board Docket No.
JEFFREY B. CLARK, : 22-BD-039
Petitioner. :
---------------------------x

HEARING, VOLUME 4

Washington, DC
Monday, April 1, 2024

BEFORE HEARING COMMITTEE NO. 11

MERRILL HIRSH, ESQUIRE, CHAIR
PATRICIA MATHEWS, PUBLIC MEMBER
REBECCA SMITH, ATTORNEY MEMBER

REPORTED BY: CARMEN SMITH

Page 1009

202-347-3700 Ace-Federal Reporters, Inc. 866-928-6509

Page 63
Board on Professional Responsibility: In Re Jeffrey Clark
April 1, 2024

Page 1010 Page 1012

1 The above-entitled matter came on for 1 APPEARANCES (Continued):
2 hearing before Hearing Committee Number 11 on 2
3 Monday, April 1, 2024, in Washington, D.C., at 9:29 3 ROBERT A. DESTRO, ESQ. (remote)
4 a.m., when were present on behalf of the respective 4 Attorney at Law
5 parties: 5 4532 Langston Boulevard, Suite 520
6 6 Arlington, Virginia 22207
7 7 202.319.5303
8 HAMILTON P. FOX, ESQ. 8 [email protected]
9 JASON R. HORRELL, ESQ. 9 On behalf of Respondent
10 Office of Disciplinary Counsel 10
11 515 Fifth Street, NW 11
12 Building A, Room 117 12 ALSO PRESENT: MEGHAN BORRAZAS
13 Washington, DC 20001 13
14 202.638.1501 14
15 [email protected] 15
16 On behalf of Bar Counsel 16
17 17
18 18
19 19
20 20
21 21
22 -- continued -- 22

Page 1011 Page 1013

1 APPEARANCES (Continued): 1 PRO CEED IN GS
2 2 PANEL CHAIR HIRSH: Thank you.
3 HARRY W. MAC DOUGALD, ESQ. 3 And good morning, everybody. For people
4 Caldwell Carlson Elliott & DeLoach LLP 4 who are following the hearing, on Wednesday we will
5 Two Ravinia Drive, Suite 1600 5 start at 1:15.
6 Atlanta, Georgia 30346 6 Mr. MacDougald, what do we have on tap for
7 404.843.1956 7 today?
8 [email protected] 8 MR. MAC DOUGALD: We have Mark Wingate,
9 On behalf of Respondent 9 Heidi Stirrup and Garland Favorito.
10 10 Mr. Chairman, on Mr. Favorito, he is
11 CHARLES BURNHAM, ESQ. 11 coming up on an airplane which lands at Reagan at
12 Burnham & Gorokhov PLLC 12 12:40. There might be a gap. I can fill that gap,
13 1424 K Street, NW, Suite 500 13 I believe, with Shawn Smith. The issue there, he is
14 Washington, DC 20005 14 available today, he's not available tomorrow.
15 202.386.6920 15 The issue with Mr. Smith is that we
16 [email protected] 16 delivered our signed expert report to him this
17 On behalf of Respondent 17 morning for Mr. Smith, and I had intended to put
18 18 Mr. Smith on on Wednesday as an accommodation to
19 19 Mr. Fox.
20 20 But -- so if we have to fill time before
21 21 Mr. Favorito can take the stand, my suggestion would
22 -- continued -- 22 be that we put Mr. Smith up or that we take a break

2 (Pages 1010 to 1013)

202-347-3700 Ace-Federal Reporters, Inc. 866-928-6509
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Board on Professional Responsibility: In Re Jeffrey Clark
April 1, 2024

Page 1014 Page 1016

1 until Mr. Favorito is here. 1 Pennsylvania that was mentioned both times in order
2 PANEL CHAIR HIRSH: Mr. Fox? 2 to disparage the idea that there was anything left
3 MR. FOX: We got the Smith report, which 3 worth investigating.
4 is 40 pages long, at 8:15 this morning. I have 4 And this witness will talk about that and
5 skimmed it, that's all I've done, so I would not be 5 rebut that testimony as to that particular point.
6 prepared to cross-examine Mr. Smith today. 6 PANEL CHAIR HIRSH: All right. Well, when
7 PANEL CHAIR HIRSH: Would one -- 7 were you thinking of calling --
8 MR. FOX: Or actually, Mr. Horrell would 8 MR. MAC DOUGALD: Tomorrow.
9 not be prepared to cross-examine him today. 9 PANEL CHAIR HIRSH: Tomorrow.
10 PANEL CHAIR HIRSH: Well, even better. 10 And has she testified before, either
11 Would it be possible, if we do have the 11 before --
12 extra time, because I don't want to have dead time, 12 MR. MAC DOUGALD: Not that I know of, but
13 you know, unnecessarily, to do his direct, but then 13 I can't rule it out definitively. I would have to
14 have the cross-examination on Wednesday? 14 ask.
15 MR. MAC DOUGALD: I think we could do 15 MR. FOX: Mr. Hirsh, I can identify for
16 that. 16 you portions of Mr. Donoghue's testimony, which I'm
17 PANEL CHAIR HIRSH: Or, you know, with 17 confident they have, before the January 6 committee
18 additional time. 18 that addresses this Pennsylvania issue. I have them
19 MR. MAC DOUGALD: Yes, I think we can do 19 marked if you want me to -- and I'll show them to
20 that. 20 you if you want me to read them to you, if you want
21 I'll tell him to be ready. 21 me to.
22 MR. FOX: And as one additional thing, I 22 This is not a surprise. I mean, there's

Page 1015 Page 1017

1 think it was Saturday, correct me if I'm wrong, 1 no reason whatsoever why, if they thought this was
2 Mr. MacDougald also indicated that they had a new 2 testimony -- this was needed testimony, they
3 fact witness, and we objected to that. This person 3 couldn't include it on their witness list and give
4 is not on the witness list who was added in the 4 us a chance to investigate.
5 middle. 5 Now they're springing this on us in the
6 As I understand, it's supposed to be a 6 middle of the hearing. I have no idea who this
7 rebuttal witness to something that Mr. Rosen and 7 person is or how she would be able to testify about
8 Mr. Donoghue testified to. Both those gentlemen's 8 what happened in Pennsylvania. I have no idea
9 testimony has been -- both of those gentlemen have 9 whatsoever.
10 testified extensively before on two occasions in 10 MR. MAC DOUGALD: Mr. Chairman, on that,
11 transcripts that I'm quite confident that the 11 you directed us to confine the presentation to
12 Respondent has had. And I see no reason why we 12 events in Georgia and to leave aside events in other
13 should have to add a new witness in the middle of 13 states, which we have done.
14 the hearing. 14 Yet in the Bar's case-in-chief, this
15 PANEL CHAIR HIRSH: Do you want to address 15 testimony from Mr. Donoghue and Mr. Rosen was
16 that? 16 offered in order to discredit Mr. Clark.
17 MR. MAC DOUGALD: Yes, I do, Mr. Chairman. 17 So I think we ought to be able to rebut
18 The witness's name is Heather Honey, and 18 it.
19 she would be called to rebut the testimony given by 19 PANEL CHAIR HIRSH: I don't think that
20 Mr. Donoghue mostly and echoed by Mr. Rosen that DOJ 20 statement is entirely accurate. But all right,
21 debunked the question of a discrepancy between the 21 here's how I want to handle this.
22 number of votes and registered voters in 22 Mr. MacDougald, can you ask her if she has

3 (Pages 1014 to 1017)

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Page 1018 Page 1020

1 testified previously and, if so, do what you can to 1 PANEL CHAIR HIRSH: Okay. Could you raise
2 get Mr. Fox and Mr. Horrell transcripts of any prior 2 your right hand, please.
3 testimony that she's given? 3 THE WITNESS: Sure.
4 MR. MAC DOUGALD: Yes. Yes, your Honor. 4 Whereupon,
5 PANEL CHAIR HIRSH: Okay. And I'll allow 5 MARK WINGATE
6 the testimony tomorrow. 6 was called as a witness and, having first been duly
7 MR. MAC DOUGALD: Anything else 7 affirmed, was examined and testified as follows:
8 preliminary? 8 PANEL CHAIR HIRSH: Could you please state
9 All right. Then I'm ready to call my next 9 your full name for the record.
10 witness. 10 THE WITNESS: Mark Wingate.
11 PANEL CHAIR HIRSH: Please proceed. 11 PANEL CHAIR HIRSH: Thank you very much,
12 MR. MAC DOUGALD: I call Mark Wingate, who 12 Mr. Wingate.
13 is in the Zoom waiting room. 13 Please proceed, Mr. MacDougald.
14 MS. BORRAZAS: Letting him in now. I sent 14 MR. MAC DOUGALD: Thank you very much,
15 him prompts to unmute and start his video, but he is 15 Mr. Chairman.
16 connected. 16 DIRECT EXAMINATION
17 Can you hear us, Mr. Wingate? 17 BY MR. MAC DOUGALD:
18 PANEL CHAIR HIRSH: I don't see a box for 18 Q Mr. Wingate.
19 him either. 19 A Yes, sir.
20 MS. BORRAZAS: He hasn't started his video 20 Q Where do you live?
21 yet. There he is. 21 A Alpharetta, Georgia.
22 THE WITNESS: There we go. Yes. Can you 22 Q Is that Fulton County?

Page 1019 Page 1021

1 all hear me now? 1 A It is.
2 PANEL CHAIR HIRSH: Yes. I can hear you. 2 Q Were you a member of the Fulton County
3 Can you hear me, Mr. Wingate? 3 board of registrations and election?
4 THE WITNESS: I can, yes, sir. 4 A Yes.
5 PANEL CHAIR HIRSH: Okay. Good morning, 5 Q What was your term of service on that
6 Mr. Wingate. 6 board?
7 THE WITNESS: Good morning. 7 A I -- my -- I started my first term in July
8 PANEL CHAIR HIRSH: My name is Merrill 8 1 of 2017, and my time on that board concluded on
9 Hirsh, I am the Committee Chair, and I'm going to be 9 June 30 of 2023.
10 swearing you in. 10 Q All right, sir.
11 THE WITNESS: Yes, sir. 11 So you were on the board for the November
12 PANEL CHAIR HIRSH: Do you want to swear 12 2020 presidential election?
13 or affirm the truth of the testimony you're going to 13 A Yes.
14 give? 14 Q And had been on it approximately three
15 THE WITNESS: I'm sorry, say that again? 15 years at that point?
16 PANEL CHAIR HIRSH: Would you like to 16 A Yeah, 2017 to -- yeah, over three years
17 swear under oath or affirm under law the testimony 17 before the November general election, yes.
18 that you're going to give? 18 Q All right, sir.
19 THE WITNESS: Either way. Affirming I 19 In your capacity as a member of the Fulton
20 guess is fine. Whatever is best for you all. I'm 20 County board of registrations and elections, were
21 just here to tell you exactly what I know and 21 you called upon to vote on certification of the
22 perhaps what I don't know. 22 November 2020 presidential election?

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1 A Yes. 1 You know, there's a lot of issues with
2 Q And what does it mean from your 2 that whole 2020 election year in process. I'll try
3 perspective as a board member to certify the 3 to be brief, but I want to give a little background.
4 election results? 4 You know, with regards to 2020, that
5 A Well, I think very -- in my mind, it was 5 election year, we were all dealing with this
6 always looking at the statement of votes cast and 6 so-called thing called COVID, and that wreaked havoc
7 the precinct data that we were supplied, usually 7 I'm sure not only on the Fulton County election
8 very, very close to when we had a certification 8 department, but, you know, election departments
9 date, unfortunately. 9 across the state and probably across the nation.
10 But, you know, you look at those numbers, 10 But, you know, there were a lot of things
11 and if you have any issues with that, typically, or 11 that were taking place that quite frankly none of us
12 any other issues in advance of certification, which 12 had any experience with, and that was such a huge
13 was plenty of in the 2020 presidential election, 13 infusion of absentee by mail ballots.
14 that then you will -- after the election director is 14 Fulton County, obviously by far the
15 asked by the current chairman of the board or 15 largest county in Georgia, and thus people, you
16 chairperson of the board, he is asked to make a 16 know, on the voter rolls, I mean, the way in which
17 statement under oath that the numbers that we are 17 it was managed and processed out and where it was
18 looking to certify are true and accurate, which in 18 all coming from, it's amazing that it didn't end up
19 my experience in all cases, that was always the case 19 being a bigger dumpster fire than it was.
20 is that question is asked and it was always affirmed 20 But the things that led me initially to
21 that those were true and accurate numbers. 21 have concern about everything was much, much earlier
22 Q All right, sir. 22 in 2020, and I can't remember exactly when I

Page 1023 Page 1025

1 Was there more than one certification vote 1 began -- I started looking at our voter rolls.
2 on the November 2020 election? 2 You know, I did, you know, some fairly
3 A I'm sorry, Mr. MacDougald, say that again? 3 simplistic research on the population of Fulton
4 My volume is a little bad here. 4 County, Georgia. And what I found out, and of
5 Q Yes, sir. Was there more than one 5 course started pressing that with the elections
6 certification vote on the November 2020 presidential 6 department, you know, through subsequent monthly
7 election? 7 meetings, et cetera, was that the numbers that I was
8 A Yeah, as it turned out, there was, because 8 able to ascertain, we had more voters on the active
9 there were multiple votes -- or multiple counts that 9 voter rolls than we did of the population of the
10 were taken following the election, yes. So there 10 entirety of Fulton County, and then extrapolating
11 were -- there were -- as I recall, there were two 11 for those of voting age.
12 certification meetings for that election. 12 So that became a major concern of mine,
13 Q All right, sir. 13 and frankly, you know, lasted throughout and
14 How did you vote on certification of the 14 continued even after the 2020 election. So that was
15 presidential election the first time? 15 a big issue.
16 A I voted no. 16 And, of course, inside that 2020 time
17 Q And how did you vote the second time? 17 frame, really there was nothing done to -- wasn't
18 A I again voted no. 18 time, and I understand all of that, but there was
19 Q Could you please tell the hearing 19 nothing done to answer my questions on that.
20 committee why you voted against certification twice? 20 And I thought look, it's only fair to the
21 A Okay. Well, there were -- there were 21 voters of Fulton County that, you know, we're having
22 multiple reasons. 22 clean voter rolls here so that nobody's vote, you

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1 know, is disparaged. 1 Q All right. So I interrupted you.
2 Because, you know, somebody may have come 2 A That's fundamentally what that
3 in and voted that frankly, you know, legally should 3 encompasses.
4 not be able to. So I think that's very, very 4 Q That's great, thank you very much. I
5 important, whether it be Fulton County or anywhere 5 interrupted you to get that, so pick back up where
6 in the country. 6 you were talking about asking for and not receiving
7 But from that, in the 2020 election 7 chain of custody documents.
8 itself, I had and other board members had requested 8 A Okay. Well, that -- you know, since we
9 that we obtain the chain of custody documentation 9 asked and did not receive any of it, that to me is
10 from the department. And none of that was ever 10 just one reason well, how can I trust, you know, as
11 delivered. It was not delivered at the time of 11 a board member and certify this election when I
12 request leading up to the election and was certainly 12 cannot receive even a sampling, anything at all,
13 not given -- we weren't given -- was given nothing, 13 with regards to chain of custody documents?
14 you know, even leading up to the certification. 14 So that was just another one of the things
15 Q Let me interrupt you right there, 15 in my mind leading up to certification that was
16 Mr. Wingate. 16 something that, you know, certainly was not
17 A Sure. 17 fulfilled.
18 Q And ask you to explain for the committee 18 There was also at that -- for that
19 what you mean by chain of custody documents. 19 election, the advent of this whole drop box
20 A Okay. The election staff, you know, we 20 circumstance, you know, was unveiled, and then we
21 had many components in many areas where absentee by 21 had -- I think Fulton County, we had like 36 or so
22 mail ballots were being delivered to and then picked 22 drop boxes located around the county.

Page 1027 Page 1029

1 up and then centralized to, you know, the processing 1 These drop boxes at that particular point
2 center. And then of course, you know, there's 2 were set outside of an early voting location, which
3 documentation so that whoever is handing those 3 means that, you know, they're in the -- you know,
4 envelopes in that case off to, then it's -- they are 4 they're in the elements, they're there 24 hours a
5 to sign off that they have delivered to this person 5 day, but there were surveillance cameras as required
6 and the transportation or transport of those 6 that supposedly, you know, were operating 24/7 so
7 documents, you know, which was going on -- which 7 that they could be monitored and anybody tried to do
8 goes on daily, in case you're not familiar, in the 8 any damage or anything nefarious to any of those
9 election cycle. 9 locations, that that could be looked at and, you
10 And then once they are delivered to the 10 know, hopefully somebody sent out there to secure
11 location that they're destined to, there is another 11 the situation.
12 signature required on a document that shows that, 12 But we had asked for not every
13 you know, where it was picked up, driven to, 13 surveillance tape but asked for -- to see
14 delivered to and then signed off on as received. 14 surveillance tapes on a basically, you know,
15 This was going on for multiple locations 15 whatever, just give us some samplings of that so we
16 daily. And, you know, in terms of the memory cards 16 can take a look at it.
17 that are being delivered so that they can be kept, 17 Because I knew that this was going to be
18 you know, in security, there's the same level chain 18 an important issue because of all the hullaballoo
19 of command -- chain of custody documentation that is 19 that any of us that were alive during those days was
20 delivered for all of the memory cards coming in from 20 witnessing as being an issue.
21 early voting locations and, of course, on election 21 From that request again to just, you know,
22 day from each of the precincts. 22 the way in which it turned out, there was never one

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1 surveillance tape, an inch of footage that was ever 1 So they found a terminus system that is
2 delivered to the board. And if it was delivered to 2 called BlueCrest, and the BlueCrest platform
3 anybody, it certainly was not any board member that 3 primarily was an absentee by mail or paper ballot
4 I was aware of or may be aware of. So that was a -- 4 processing application. And that would, you know,
5 you know, was another issue. 5 scan in the outer oath envelopes, it would open
6 The other issue we had down here was was 6 them, pull them out, flatten them as they call it
7 this whole questioning of ballots underneath a table 7 and then put them in bundles for later processing
8 and then being pulled out on election night, excuse 8 and scanning.
9 me, at State Farm Arena. 9 Part of that or one of the applications or
10 We did see on television, by the way, we 10 elements of that BlueCrest platform was an
11 did see that surveillance tape, and of course, I as 11 electronic signature verification component.
12 a board member and knowing most all of those people 12 And of course, we all, as that was
13 who were in that room that night, I didn't make any 13 reported, we all thought that that was going to be
14 judgment as to what was going on. It wasn't -- I 14 up and running and how exactly that the department
15 had no basis to do that. 15 people there for managing the absentee by mail
16 But I did see it, and of course I asked 16 ballot processing would have a very fine function in
17 the questions of our director. And this was, I 17 the electronic signature verification component.
18 believe, the day following election day. 18 Well, as I recall, I believe that time
19 And, you know, his response was well, he 19 frame was in October, at the board meeting for
20 just hasn't had time to look into this, but he will 20 October, I had asked the question where are we with
21 and get back to us. 21 regards to the functionality of the electronic
22 Well, there was nothing ever gotten back 22 signature verification component.

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1 to, at least to me as a board member, that had any 1 And I was told that the technicians from
2 explanation of that election night at State Farm 2 BlueCrest were in our building that day and that
3 Arena. 3 they were working to functionalize the electronic
4 We got to certification, there was still 4 signature verification.
5 no response to that, did not know, still being 5 Q Now, when you say functionality and
6 investigated. Well, I think the director in my 6 functionalize, what's the plain English meaning of
7 opinion, and still believe that to this day, could 7 that?
8 have, you know, stated look, I've talked to 8 A Meaning getting it to work.
9 everybody and this is what transpired. I firmly 9 Q Thank you.
10 believe that should have been done by the then 10 A If that makes sense, yeah. I'm sorry I
11 director. But it was not. 11 was unclear.
12 And the last thing was -- not the last 12 Q That's all right.
13 thing but the big what I call four or five things 13 A They were in there to make the thing work.
14 that prevented me from certifying was we had such a 14 Q Okay.
15 huge, huge number of absentee by mail ballots. And 15 A And we certainly, as we would, board
16 those ballots, we as the department and the board 16 meeting concluded, we went on.
17 and then the board of commissioners, who has to 17 But after the fact, we were not told in
18 approve, you know, certain expenditures, because it 18 between that October date and then of course about a
19 was becoming very, very clear that there was going 19 month later the election itself, you know, at least
20 to be a larger amount of absentee by mail ballots 20 I was not told that they didn't -- that they did not
21 this election year than by far than in previous 21 get it to work.
22 years. 22 So, you know, somewhere along the line,

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1 and I can't -- I am sorry, I can't remember exactly 1 the county?
2 when it was, but I had asked the question, well, 2 A Yeah, and again, I can't be precise. But
3 okay, well, what did we do for signature 3 it seems to me like the entire platform was a little
4 verification? 4 over a million bucks, a million dollars.
5 And the comment I got back was, which 5 Q And -- I'm trying to clear my throat.
6 frankly at that time floored me, was well, you know, 6 To your knowledge, did they ever get it
7 we didn't do any. And I remember kind of -- I 7 working?
8 forget where I was, if we were on a phone call, I 8 A To my knowledge, no. It obviously did not
9 forget exactly, and I apologize, it's been so long. 9 work leading up to and going through any of the 2020
10 But I do remember that comment that, you 10 elections. And it was not -- I don't believe if --
11 know, we didn't do any. 11 I don't believe it was working either, you know, for
12 Now, of course, I took that saying all 12 the runoffs that we had coming out of the 2020
13 right, well, by law, you've got to do signature 13 elections.
14 verification, you've got to at least have somebody 14 Q Did they ever get it working in a later
15 looking at this. And one side of that is that 15 election while you were on the board?
16 whomever you have that is looking at it and is 16 A To my knowledge, no.
17 supposed to be, you know, verifying signature, that 17 Q Do you have a --
18 if there is no signature on the both envelope, then 18 A I'm sorry, we had asked a couple of times
19 how are you curing it or what are you doing with it? 19 and had gotten a response that no, but there was no
20 And I remember going down, you know, on 20 pressure on them after the 2020 election and runoffs
21 from that and said well, you know, there weren't 21 to do that.
22 many so we just sent them back out and if they reply 22 Q Do you recall approximately how many

Page 1035 Page 1037

1 on time, then they will get their vote counted. And 1 absentee ballots were counted in Fulton County in
2 I thought that was a little weak, but anyway, as I 2 the November 2020 presidential election?
3 recall, that's what I was told. 3 A Yeah, it was I think a few more than
4 Q All right, sir. 4 147,000, as I recall.
5 A And those are primarily, ladies and 5 Q Earlier, you testified that to your
6 gentlemen, that was primarily in my mind and in my 6 understanding, the votes could not properly be
7 reasoning why I was not comfortable, you know, in 7 counted or lawfully be counted unless the signatures
8 certifying. 8 were verified.
9 Q All right, sir. 9 Was that your understanding at the time?
10 And what was the vote on certification? 10 A Yeah, yes. And I don't think there was
11 What was the vote total on certification when the 11 any -- to me, there wasn't ever any confusion about
12 board voted? 12 the fact that there was supposed to be, you know, an
13 A Well, there were two -- in the board 13 attempt, a level of verifying signature.
14 meeting, there's two Republicans, two Democrats and 14 And I think that would bear out because
15 then supposedly, which doesn't always work that way, 15 you do, you get a few, maybe a handful of envelopes
16 an independent or a nonpartisan chair. 16 that don't have a signature at all. So unless
17 The vote was 2 -- three to certify and two 17 somebody it looking at it, you wouldn't know that.
18 against. 18 Now, do I know, never got the answer. I
19 Q And that was for both certification votes? 19 have no earthly idea how many absentee by mail
20 A That's -- yes, yes. 20 ballots were sent back to voters because they were
21 Q All right. And do you have an 21 trying to cure it for lack of signature or
22 understanding of how much the BlueCrest system cost 22 otherwise. Number was never divulged to me, anyway.

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1 Q All right, sir. 1 Q Okay. But the vote not to certify was
2 Were you interviewed about the absentee 2 premised on your understanding that Fulton County
3 ballot signature verification issue by anyone from 3 didn't verify signatures electronically; is that
4 the Georgia secretary of state's office? 4 right?
5 A No, not that I recall. I didn't have 5 A Well, more so that what -- in terms of
6 anybody from the SOS contact me about any of that. 6 conversations and having the statement made to me
7 Q Were you interviewed about the absentee 7 that the department did not do signature
8 ballot signature verification issue by anyone from 8 verification to me was a whole different issue.
9 the Georgia Bureau of Investigation? 9 Not being able to do it electronically was
10 A No. 10 certainly a function that, as it turned out, they
11 Q Were you interviewed about absentee ballot 11 could not get that particular component of the
12 signature verification by anyone from the Federal 12 BlueCrest platform to work.
13 Bureau of Investigation, the FBI? 13 Q And the meeting at which you voted not to
14 A No, no, sir. 14 certify the election, I guess the first time, that
15 Q Were you interviewed about that topic by 15 was on November 13, 2020; is that right?
16 anyone from the U.S. Attorney's Office in Atlanta? 16 A Yeah, that's my recollection. Yeah.
17 A No, not -- not that I recall where 17 Q And is it true that before you voted not
18 somebody contacted me from there it didn't -- it 18 to certify the election, that you put your
19 wasn't identified to me or at least something that I 19 explanation on the record?
20 could recall. 20 A I did recite a few of the things. I
21 But no, I think I would probably remember 21 believe, as I recall, you know, I was still
22 if it came from those levels. 22 concerned about the voter registration rolls and

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1 Q Were you interviewed about the absentee 1 that not be necessarily clean, that, you know, we --
2 ballot signature verification question or any of the 2 in terms of signature verification, we understood
3 other issues that you identified by anybody from the 3 that there was not any -- they couldn't get the
4 DOJ? 4 BlueCrest component of that to work.
5 A No, no. 5 But then again, you know, as it was said
6 MR. MAC DOUGALD: That's all the questions 6 before, before that time that they did not perform
7 I have for you, Mr. Wingate. Thank you very much. 7 signature verification. I thought that was a little
8 THE WITNESS: You're welcome. 8 bigger issue than just the electronic format.
9 PANEL CHAIR HIRSH: Mr. Fox? 9 But yeah, I alluded to a few things, not
10 Oh, Mr. Horrell, sorry. 10 everything that was in my mind and caused me not to
11 CROSS-EXAMINATION 11 vote to certify that election.
12 BY MR. HORRELL: 12 Q The record from the November 13 meeting
13 Q Good morning, Mr. Wingate. 13 was recorded?
14 A Good morning. 14 A Uh-huh.
15 Q My name is Jason Horrell. I've just got a 15 Q Via minutes; is that right?
16 few questions for you. 16 A I'm sorry, can you repeat that, please?
17 A Certainly. 17 Q Sure. So the meetings of the board are
18 Q You testified on direct that you voted not 18 recorded via minutes, written minutes; is that
19 to certify the election because Fulton County did 19 right?
20 not conduct signature verification for absentee 20 A It's supposed to be, yeah. Hopefully as
21 ballots; is that right? 21 accurate as they can make it.
22 A I did, that was one of the reasons. 22 Q And the board votes to approve those

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1 minutes; is that right? 1 where the sentence begins "From Runbeck," it reads,
2 A Yes, they do. 2 "From Runbeck and because of that they gave us on
3 Q Okay. Do you recall in your explanation 3 the process and of the 147,000 absentee paper
4 voting no to certify the election that you stated 4 ballots that were processed in I just think that for
5 that the absentee ballots were verified by manual 5 the record it needs to be known that all of those
6 process, signature verification by manual process; 6 were derived by manual process. They were not
7 is that right? 7 electronically verified signatures."
8 A Well, given that, you know, they did 8 Did I read that correctly?
9 not -- they were not able to get the electronic 9 A Yeah, yeah.
10 signature verification, like I said, it was also 10 Q Emily, you can take that down.
11 then stated prior to that that signature 11 And, Mr. Wingate, the ballot for the 2020
12 verification was not done. 12 election included other contests besides the
13 And I can't remember exactly, you know, 13 presidential contest; is that right?
14 why I stated, you know, in that certification 14 A Yes, I -- yes, of course there were other
15 meeting. 15 races as well, yes.
16 But given everything that I had in my mind 16 Q And that would include I believe there
17 and reasons going into that, unless somebody, you 17 were two constitutional amendments, state
18 know, could give me, you know, evidence or the 18 constitutional amendments; is that right?
19 information at that point, then those were, you 19 A You know what, sir, I can't remember back
20 know, the culmination of reasons that I voted not to 20 that far what was on those ballots.
21 certify, not just by one. 21 Q There were local election races in Fulton
22 Q Emily, could you pull up Disciplinary 22 County?

Page 1043 Page 1045

1 Counsel Exhibit 70. 1 A Yeah, I'm sure that there were of course.
2 Mr. Chair, I'm handing a copy to 2 Q And there was an election to fill the seat
3 Mr. MacDougald. 3 of Senator Isaacson; is that right?
4 Mr. Wingate, do you see the document on 4 A Yes, I believe that was Johnny's seat at
5 your screen? 5 the time, yeah.
6 A I can, yes. 6 Q But despite your vote not to certify the
7 Q At the top it reads "Board of Registration 7 presidential election, you did vote to certify the
8 and Elections, Regular Meeting, November 13, 2020." 8 results of the local elections; right?
9 Is that right? 9 A Yeah, as was the presidential
10 A Yes, uh-huh. 10 certification, it was very obvious that, you know,
11 Q Just above that it says "approved 11 my continuing on with all of that was a moot point.
12 minutes." Is that right? 12 You know, they were going to vote at least 3 to 2 to
13 A Yeah, uh-huh. 13 certify it, so I was done with what I had -- with
14 Q Emily, if you could go to page 6, I think. 14 what I had stated and the reasons for that.
15 I'm sorry, page 7. And if we could blow up this 15 And again, you know, that was the first
16 first large paragraph, Emily, starting with 16 out of the block for us, which was the presidential
17 "Mr. Wingate." 17 race. So with that, I just kind of -- I have to
18 So, Mr. Wingate, this is where you express 18 admit, I just off simple, you know, my no vote is
19 your rationale for voting no to certify the 19 not going to stop anything here so just yeah, just
20 election. 20 go ahead and go on.
21 A Uh-huh. 21 Q Okay. And it's true that the vote to
22 Q And if we look toward the very bottom 22 certify the down ballot elections were unanimous

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1 votes of 5 to 0; is that right? 1 in the minutes there.
2 A If -- I can't remember. You know, I can't 2 A You know, I don't have a lot to add to
3 remember that altogether, but if you say that's the 3 that.
4 way it voted, then that must be the way it was. I 4 I guess, you know, given this and that we
5 can't remember. 5 approved these minutes, is that exactly as I recall
6 Q My last question for you, Mr. Wingate, is 6 it? I'm so -- I can't recall exactly what I said
7 I believe you said that you were a member of the 7 and how I said it. And quite frankly, looking that
8 board from 2017 to 2023; is that right? 8 back over, whether or not that was -- that is a true
9 A That's correct. 9 and accurate accounting of what was stated, I --
10 Q Okay. And the board is -- it's made up of 10 Q To your knowledge --
11 partisan appointments; is that right? 11 A I think with that, though, my -- what was
12 A That's correct. 12 my, you know, intent here was that I was the -- I
13 Q And you were one of the Republican 13 was so taken at least on that one particular issue
14 appointees? 14 that it wasn't -- my comment that it was a manual
15 A That's correct. 15 process evolved from the fact is that we didn't get
16 MR. HORRELL: I don't have any further 16 the electronic signature verification component
17 questions. 17 working on the BlueCrest platform so that the only
18 PANEL CHAIR HIRSH: Excuse me one second. 18 way in which that was -- could have been derived was
19 Mr. Horrell, have I been mispronouncing 19 through a manual process.
20 your name? I'm terribly sorry. 20 Now, given that, you know, I did make the
21 MR. HORRELL: It's okay. 21 statement in particular at least for this particular
22 PANEL CHAIR HIRSH: I know it's awkward, 22 time and situation about the signature verification

Page 1047 Page 1049

1 but it's Horrell? 1 process altogether, as I recall, what I was trying
2 MR. HORRELL: I say Horrell, but people in 2 to get across here was is that it was not done at
3 my own family say Horrell so it does not matter to 3 all and that driving that back, the only way they
4 me how you say it. But I say Horrell. 4 could have done it because we didn't have the
5 PANEL CHAIR HIRSH: It rhymes with oral. 5 electronic capabilities is it would have had to be
6 MR. HORRELL: Yes. 6 done manually.
7 PANEL CHAIR HIRSH: I'm terribly sorry. 7 And my understanding was from then the
8 MR. FOX: I've said Horrell too. 8 people running the department that they didn't do
9 MR. HORRELL: And I've never objected to 9 any of that. So that weighed very heavily in my
10 that. 10 mind as well as the other things too.
11 MR. MAC DOUGALD: That's a relief to me 11 Like I said, the voter rolls, and is even
12 that his own family does the same thing I've been 12 today still very, very, very much of a concern to
13 doing. 13 me.
14 REDIRECT EXAMINATION 14 Q All right, sir.
15 BY MR. MAC DOUGALD: 15 If it were possible to do absentee ballot
16 Q Okay, Mr. Wingate. Turning back to that 16 signature verification manually on 147,000 absentee
17 exhibit, could you all put DX-070 back up, page 7. 17 ballots, would the county have spent over a million
18 And if you could enlarge that, the bottom part of 18 dollars to automate the process?
19 that first big paragraph "From Runbeck." 19 MR. HORRELL: Objection; leading.
20 You were asked about this sentence "From 20 PANEL CHAIR HIRSH: I'm not sure there's a
21 Runbeck," and I would like to know whether you have 21 foundation for him to talk about it. There might
22 anything to say to further explain what is recorded 22 be, but you need to establish it.

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1 BY MR. MAC DOUGALD: 1 information?
2 Q Mr. Wingate, was it possible to your 2 THE WITNESS: No, I do not have
3 understanding to manually verify the signatures on 3 information that could help me to state that it was
4 147,000 absentee ballots within the time available 4 realistic that that could be done. And that would
5 to complete that task? 5 primarily be surrounding those trained individuals
6 MR. HORRELL: Objection. 6 in the Fulton County election department to do that.
7 PANEL CHAIR HIRSH: I think you need to 7 I don't -- I can't affirm, attest or otherwise to
8 establish the basis for his understanding. I mean, 8 that number. Don't know it.
9 if he has one, that's fine. But does he know? 9 BY MR. MAC DOUGALD:
10 MR. MAC DOUGALD: Can we ask him yes or 10 Q You mentioned driver division of
11 no, does he have an understanding of that, and then 11 department -- excuse me, division of driver services
12 ask him to explain it? 12 and then an in-house database. What are those?
13 PANEL CHAIR HIRSH: You can ask him yes or 13 A Oh, sorry. The --
14 no do you have an understanding and then ask him 14 MR. HORRELL: Mr. Chair --
15 what's the basis of the understanding. Then if it 15 THE WITNESS: The primary file that the
16 lays a foundation, ask him what the foundation is. 16 Fulton County and I believe every other county in
17 BY MR. MAC DOUGALD: 17 Georgia goes to if they are trying to get and
18 Q Mr. Wingate. 18 perform any kind of a verification of voter
19 A Yes, sir. 19 signature is first they typically go to the
20 Q Do you have an understanding one way or 20 department of driver services file --
21 the other whether it was possible to manually verify 21 MR. HORRELL: I'm sorry, Mr. Chair, I'm
22 the signatures on 147,000 absentee ballots within 22 going to object to outside the scope of cross. I

Page 1051 Page 1053

1 the time available to complete that task, yes or no? 1 didn't ask anything about this issue.
2 A No. I mean, I have an awareness of the 2 PANEL CHAIR HIRSH: Well, no, I mean, I
3 process obviously, but was there enough staff, was 3 think it is fairly part of your cross so I'm going
4 there trained staff, was there access to either the 4 to overrule that objection. I think he answered the
5 state driver services file or the in-house file that 5 question, but I don't -- was there additional --
6 Fulton County maintains, I am sorry, folks, I cannot 6 were you done with your answer, Mr. Wingate?
7 in my position answer that with any discern. I 7 THE WITNESS: Well, I was going to add
8 cannot. 8 that in Fulton County's situation, if they had any
9 Q You can't -- I'm a little confused about 9 problems at all at any time where they were trying
10 what your answer is. 10 to verify a voter's signature, if they don't have
11 MR. HORRELL: Objection. He answered the 11 access or don't find a file on a particular
12 question. 12 individual, they had -- Fulton County had maintained
13 PANEL CHAIR HIRSH: I think he did answer 13 for several years, as I understood it, their own
14 the question. 14 signature file.
15 THE WITNESS: Maybe if I'm not 15 So if they couldn't get, you know, what
16 understanding, please tell me. 16 they were looking for on the DDS file, then they
17 PANEL CHAIR HIRSH: The question is 17 would try their own in-house file to see if they
18 whether you have the information to determine 18 could find, you know, the voter and a signature.
19 whether it was possible to manually do signature 19 BY MR. MAC DOUGALD:
20 verification on 147,000 absentee ballots. That's 20 Q And if the process were to be done
21 what I understand the question to be. 21 manually, that search would have to be performed one
22 And, you know, yes or no, do you have the 22 ballot at a time, first in the DDS database and if

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1 not found there, in the county database? 1 were derived years ago. You know, do people's
2 MR. HORRELL: Objection, Mr. Chair. 2 signatures change as time goes on? I personally
3 PANEL CHAIR HIRSH: Well, again, do you 3 think that they do. I know mine has.
4 have an understanding of how the search would be 4 So I always found it regardless, but it
5 done? 5 was quite frankly Georgia law that, you know,
6 MR. MAC DOUGALD: I think he described 6 signatures were supposed to be verified. So that's
7 that. I'm just confirming it. 7 what you would expect particularly as a board
8 PANEL CHAIR HIRSH: I think he's described 8 member. Not as a election worker but just as
9 it so I'll let him answer. 9 oversight board member.
10 BY MR. MAC DOUGALD: 10 Q Were you told that manual verification had
11 Q You may answer, Mr. Wingate. 11 been done?
12 A A lot of going on here. 12 A No, no.
13 Repeat to me what I was being asked to 13 Q Were you told that -- tell us what you
14 answer again, please. 14 were told about signature verification.
15 Q If an absentee ballot signature is being 15 A Well, that was -- and again, that was what
16 verified on a manual basis one at a time, what does 16 concerned me was when I, you know, heard with my
17 the process entail? 17 ears the fact that there was not -- there was no
18 A Well, what you -- what you have, you know, 18 signature verification performed, I thought well,
19 in that processing environment are a series of 19 okay, I understand what I think that I'm hearing
20 people, and again that's why I backed -- I could not 20 here and I hope that I'm hearing it correctly.
21 answer the other, because I don't know how many 21 But yeah, you've got to look. Because I
22 people the department had. But there were people 22 think you do, at least I would have, you know,

Page 1055 Page 1057

1 that were engaged in or supposed to be engaged in 1 recommended. But if you find an oath envelope that
2 looking at the outer oath envelope for signature. 2 doesn't have a signature, you know, you've got to go
3 And if they see a signature, what they're 3 find a way to cure that. And that cure is to get it
4 supposed to do and, you know, was part of their 4 back to the voter, you know, and try to get their
5 process was, you know, go in into -- and again, this 5 signature. And if you get their signature, come
6 is all subjective, as you all might know, when 6 back and then you should be then going through your
7 verifying a signature like that. 7 verification process.
8 If you're doing that, then you're looking 8 But at some point, whether it be, you
9 at initially if the DDS has a signature on file for 9 know, somebody looking at it manually and then
10 that particular person. And if not, then they will 10 looking at a screen from the DDS or from the
11 then go into the in-house database to see if they 11 in-house file in Fulton County, you know, somebody
12 can find that person on that file. 12 should have been doing the best they can, clearly,
13 And then, as I think I have stated not to 13 to verify those.
14 this group but to many others, you know, that that 14 When the comment came back to me that that
15 to me was always very, very subjective because 15 wasn't done, we've got a record year because of our
16 you're asking people, a lot of people who are 16 current situation in this country and in this world
17 temporary employees, as a lot of big election 17 that, you know, we've got -- you just can't ignore
18 centers are, you're asking people potentially to be 18 it.
19 verifying something that is very subjective, looking 19 But again, we put a lot of time on, you
20 at a signature. 20 know, lack of signature verification, lack of
21 Some of these signatures, you know, even 21 electronic, you know, signature verification
22 on the DDS file are very, very -- you know, they 22 components. But that was just one of the several

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1 reasons that I had that I voted -- and I certainly 1 Disciplinary Counsel, they are the prosecutor and
2 had the right to do so, to vote to not certify the 2 I'm the one hearing the case. So we're not actually
3 presidential election. 3 the same -- exactly the same organization in that
4 MR. MAC DOUGALD: All right, sir. That's 4 sense.
5 all the questions I have. 5 THE WITNESS: All right, thank you.
6 PANEL CHAIR HIRSH: Does the panel have 6 BY PANEL CHAIR HIRSCH:
7 any questions? 7 Q If a majority of the board had voted not
8 PANEL MEMBER MATHEWS: I do. 8 to certify, what happens next?
9 PANEL CHAIR HIRSH: Ms. Mathews. 9 A It -- well, of course, you know, the
10 EXAMINATION 10 vote -- the certification vote after it's done and
11 BY PANEL MEMBER MATHEWS: 11 then signed accordingly by board members of each
12 Q Mr. Wingate, thank you for had your 12 county, it goes to the secretary of state's office.
13 testimony. When did you first meet Jeffrey Clark? 13 And I honestly don't know once the SOS
14 A I have never met this Jeffrey Clark. 14 gets that and there is not a 100 percent from each
15 PANEL MEMBER MATHEWS: Thank you. 15 county vote of certification, I'm not sure exactly
16 PANEL CHAIR HIRSH: Ms. Smith? 16 what then that the secretary of state's office does.
17 PANEL MEMBER SMITH: No questions. 17 It never got that far so we never faced
18 EXAMINATION 18 that because it did get certified with a 3-2 vote,
19 BY PANEL CHAIR HIRSH: 19 two times as a matter of fact.
20 Q Mr. Wingate, have you ever spoken to 20 But I think -- and you know, I don't want
21 Jeffrey Clark? 21 to add or anything, but it was very, very important,
22 A No, sir. 22 I think very enlightening, and I know I've said this

Page 1059 Page 1061

1 Q And did you ever speak even later to 1 to others way, way back when.
2 people at the Justice Department about the 2020 2 But, you know, in Georgia that year, there
3 election? 3 was the original count from the election, the
4 A The only thing that came up recently, and 4 November 3 election, because of every -- you know,
5 I believe it was a gentleman from your organization, 5 the requests for recount, they did right after that,
6 that had called and asked me a few questions over 6 shortly after the election day, they did a hand
7 the telephone. But that was just like within the 7 recount.
8 last couple of weeks. I can go back and look if you 8 Once they did the hand recount, that
9 need that specific time and specific gentleman. 9 number was different from the number -- from the
10 They had sent me an e-mail asking if they could 10 certification number of election day. And as I
11 speak with me. 11 recall, it was 7-, 800 votes difference in the
12 Q Mr. Fox? 12 counts.
13 MR. HORRELL: Mr. Chair, it was me. 13 We did not -- we were not required to
14 PANEL CHAIR HIRSH: Mr. Horrell, who just 14 certify the hand recount. But following that, and
15 asked you questions. 15 because it was still questions about, you know, the
16 THE WITNESS: Okay, okay. 16 vote count, he they did another machine count. So
17 BY PANEL CHAIR HIRSH: 17 this was actually the third count.
18 Q Just so you're clear, my organization, 18 And the second machine count also produced
19 I'm -- you know, I am a volunteer member of the 19 another number. So we had in total three counts for
20 hearing committee of the Board of Professional 20 the election, and those three counts were all
21 Responsibility, which is a part of the D.C. Court of 21 different.
22 Appeals. Mr. Horrell is -- works for the Office of 22 And I remember, and I don't mind saying

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1 this because it was -- it was very important, I 1 (Witness excused.)
2 thought. I had commented to our other board members 2 MR. MAC DOUGALD: Your Honor, before I
3 that well, look, I understand, you know, your 3 call my next witness, who is right outside, I would
4 position, you didn't have the same position I did. 4 like to tender Respondents' Exhibit 561, which is
5 That makes up a board. 5 the EAC statistics that I alluded to in opening.
6 But, you know, ladies and gentlemen, these 6 PANEL CHAIR HIRSH: This is actually among
7 numbers were counted three times and came in with 7 the pile so let me look at it.
8 three different numbers. 8 MR. FOX: I'm sorry, what was the number
9 So in certifying something, by having, you 9 again?
10 know, the people in the election department attest 10 MR. MAC DOUGALD: 561.
11 that they are true and accurate numbers turned out 11 MR. FOX: We have no objection, sorry.
12 not to be true. It was not true. And the counts 12 PANEL CHAIR HIRSH: Respondent's 561 will
13 did that. 13 be admitted.
14 Now, was that -- did that give me, you 14 (Exhibit R-561 received.)
15 know, this great feeling of joy and justification 15 PANEL CHAIR HIRSH: I have to say my line,
16 that I didn't vote? No, has nothing to do with 16 Mr. MacDougald, you know.
17 that, because that was -- I didn't know, that was 17 MR. MAC DOUGALD: I was jumping the gun.
18 not my original reason. 18 I call Heidi Stirrup to the stand.
19 My original reasoning as I have stated to 19 And I need to go fetch the witness, if I
20 you all today, and certainly not one over the other 20 may.
21 as being the more important and that, you know, I 21 PANEL CHAIR HIRSH: All right. Fetch
22 could go on and on and on about this, so there were 22 away.

Page 1063 Page 1065

1 certainly problems in terms of the overall 1 Good morning, Ms. Stirrup.
2 operations of elections in 2020. But I have to give 2 THE WITNESS: Thank you for coming.
3 a little bit of variance to that because there were 3 PANEL CHAIR HIRSH: My name is Merrill
4 a lot of new things with this COVID thing and all 4 Hirsh. I am Chairman of the Hearing Committee. Do
5 the remoteness. And we were doing our board 5 you want to swear or affirm the truth of your
6 meetings via Zoom itself. 6 testimony today?
7 I mean, it's just a different election 7 THE WITNESS: I will swear.
8 year for a lot of reasons, a lot of reasons. That's 8 PANEL CHAIR HIRSH: Could you raise your
9 not an editorial, I just want to make sure it's 9 right hand, please.
10 clear as to why I did what I did, and I would do it 10 Whereupon,
11 again for the very same reasons based on what I 11 HEIDI H. STIRRUP
12 knew. 12 was called as a witness and, having first been duly
13 PANEL CHAIR HIRSH: I think that's all I 13 sworn, was examined and testified as follows:
14 have. Does that stimulate either questions by the 14 PANEL CHAIR HIRSH: Could you please state
15 board or the counsel? 15 your full name for the record.
16 MR. HORRELL: No. 16 THE WITNESS: Heidi Hiltgen Stirrup.
17 MR. MAC DOUGALD: No, no questions. 17 PANEL MEMBER MATHEWS: Could you spell
18 PANEL CHAIR HIRSH: Thank you so much, 18 that.
19 Mr. Wingate. I really appreciate your time. 19 THE WITNESS: H-e-i-d-i, H-i-l-t-g-e-n,
20 THE WITNESS: You're welcome. 20 Stirrup is S-t-i-r-r-u-p.
21 PANEL CHAIR HIRSH: You are now excused. 21 PANEL CHAIR HIRSH: Thank you very much.
22 THE WITNESS: Thank you. 22 You can sit down.

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1 And Mr. MacDougald, please proceed. 1 of Health and Human Services. And I stayed there
2 MR. MAC DOUGALD: Thank you, Mr. Chair. 2 until October 26 of 2020 at the Department of Health
3 DIRECT EXAMINATION 3 and Human Services. I had a variety of capacities,
4 BY MR. MAC DOUGALD: 4 all as a political appointee, deputy assistant
5 Q Ms. Stirrup, you live in the metro D.C. 5 secretary for policy at the Administration for
6 area? 6 Children and Families, acting director of the Office
7 A Yes. 7 of Refugee Resettlement, yeah, and the deputy White
8 Q All right. So you didn't have to come all 8 House liaison.
9 the way from Atlanta for this? 9 Q All right. And so when you said you dealt
10 A Correct. 10 with political appointees at the Department of
11 Q All right. In November of 2020, how were 11 Justice, did you have anything to do with career
12 you employed? 12 employment situations?
13 A By the U.S. Department of Justice. 13 A None whatsoever.
14 Q And what was your position? 14 Q All righty. After the election, did you
15 A White House liaison. 15 have any concerns about the election?
16 Q And what did that involve? 16 A I did.
17 A I was responsible for political 17 Q And what were they?
18 appointments for the Department. 18 A Well, I was concerned about the results,
19 Q And to whom did you report? 19 because the night of the election, President Trump
20 A Spencer -- 20 was ahead by, I don't know, 800,000 votes, and then
21 PANEL CHAIR HIRSH: Excuse me, could you 21 the next morning the election was declared in favor
22 speak a little more into the mike or maybe adjust it 22 of Joe Biden.

Page 1067 Page 1069

1 so it's easier to hear. 1 So I wondered what happened.
2 THE WITNESS: It this better? 2 Q All right. Did you have occasion to
3 PANEL CHAIR HIRSH: Yeah, that's better. 3 discuss election concerns with anyone from the
4 Thank you. 4 Justice Department in your capacity as White House
5 THE WITNESS: I'm sorry, what was the 5 liaison?
6 question? 6 A I did.
7 BY MR. MAC DOUGALD: 7 Q Tell us about that.
8 Q Who did you report to? 8 A So I talked to the chief of staff, Will
9 A At the Department of Justice would be the 9 Levi.
10 political leadership, starting with the Attorney 10 Q Chief of staff to whom?
11 General, the chief of staff and the other political 11 A To the Attorney General, William Barr.
12 appointees. 12 Q Okay. Go ahead.
13 Q And did you report to anyone at the White 13 A Because as a political appointee, I felt
14 House? 14 free to talk to another political appointee about a
15 A Yes, in the office of presidential 15 political question, being the election. And I
16 personnel, Spencer Chretien. 16 wanted to register or at least ask questions and see
17 Q Prior to -- did you have any other 17 if he shared my concerns and what was happening,
18 positions in government before that? 18 what was going on.
19 A Yes. Immediately before I was at the 19 Q And when was that, if you recall?
20 Department of Health and Human Services as a 20 A Would have been on Monday, November 9.
21 political appointee starting on January 20 of 2017 21 Q All right. So tell us about your
22 as the deputy White House liaison at the Department 22 discussion with Mr. Levi.

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1 A It was about lunchtime, and I went in and 1 Q All right. Tell us about that meeting.
2 asked him about, you know, what was happening at the 2 A So I went in and very respectfully, you
3 Department to look into the alleged irregularities 3 know, expressed to the Attorney General my concern
4 and fraud with respect to the election, because I 4 about the election, about how it was conducted and
5 was concerned that there was fraud. 5 how the results came in in such a way that I just
6 And of course in the beginning days, 6 found it not believable.
7 immediately in the aftermath of that Tuesday, 7 So I asked, you know, whether or not there
8 reports were coming forward about irregularities 8 was an investigation going on looking into some of
9 and, you know, voting machines should be seized and 9 these alleged irregularities that were being
10 things should be looked into, and there were 10 reported in the public domain at the time.
11 mysterious ballots appearing and counting was not 11 And he explained to me that there really
12 accurate, et cetera, et cetera. 12 wasn't a federal role in elections, that they are
13 So I wanted to know what the Department 13 handled at the state level and there was really
14 was doing to look into these. 14 nothing the federal government could do.
15 And Will said that they had been looking 15 And so I was -- I was surprised at that
16 into allegations of fraud and everything that they 16 because I thought the Department could look into
17 had looked into turned out to be nothing. 17 potential fraud. But I was told no, that that's
18 So I was surprised at that, and so he 18 not -- there's no federal role for that and that
19 explained that he had spent the weekend writing a 19 it's up to the states to pursue.
20 memo, giving further direction to the U.S. 20 Q Did he say anything else?
21 Attorneys, you know, to pursue any allegations of 21 A He said even if there were allegations of
22 fraud and investigate where they could. And I 22 fraud, an investigation would take up to two years

Page 1071 Page 1073

1 just -- again, I just reiterated my concerns about 1 or longer and certainly wouldn't have the effect of
2 irregularities and possible fraud and wanted to know 2 overturning the election. I wasn't necessarily
3 specifically what the Department had done. 3 interested in overturning the election. I was
4 He was very agitated and exasperated at my 4 simply interested in knowing that everything and
5 questions and asked me if I wanted to talk to the 5 anything that could be done to look into these
6 Attorney General himself. And I said sure. Again, 6 allegations of fraud were looked into, were
7 I'm a political appointee talking to the political 7 investigated, were handled.
8 appointees, wanting to hear from them, you know, how 8 Q And so coming away from that meeting, how
9 do they answer the allegations that are swirling 9 did you feel?
10 around in the public domain about all these 10 A Well, again, he, as did Will Levi,
11 irregularities. 11 explained to me that they had prepared this memo
12 To me the Department of Justice was the 12 that was going out to the field and was giving
13 number one law enforcement agency in the government, 13 instruction, you know, to the U.S. Attorneys and
14 and so that would be the place where we're looking 14 others that would be looking into allegations of
15 into these kinds of things. 15 fraud.
16 And so we all arranged for a meeting with 16 I felt that that was something. I was
17 me, for me, with the Attorney General himself. It 17 relieved to know that.
18 was just the three of us, the Attorney General, Will 18 But I guess that's -- yeah, that was --
19 Levi and me. We met that afternoon on the 9th about 19 that was it. That was something.
20 4:00 or so. 20 Q All righty. I am going to put up on your
21 Q So that was a separate meeting then? 21 screen there an exhibit that has been marked as
22 A Correct. 22 Respondents' Exhibit -- if you don't have it, I have

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1 turned the sharing off, will be right back. 1 MR. MAC DOUGALD: I think it was not. I
2 Is that showing up on your screen? 2 don't think it's on their list.
3 A Yes, uh-huh. 3 MR. HORRELL: It's only Respondent's.
4 Q This has been marked Exhibit Respondent's 4 PANEL CHAIR HIRSH: It's only
5 559. And I'm going to ask if you recognize this 5 Respondent's, okay.
6 memo. 6 Has it been admitted?
7 A Yes, I do. 7 MR. HORRELL: It has.
8 Q And is that the memo to which you were 8 MR. FOX: I think it was 55?
9 just referring? 9 PANEL CHAIR HIRSH: 559.
10 A Yes. 10 MR. FOX: It's the same exhibit as 55.
11 Q And what -- when did you receive -- or did 11 MR. MAC DOUGALD: Oh, it is?
12 you receive a copy of this memo? 12 PANEL CHAIR HIRSH: Yeah, I had thought
13 A Not initially, but I did e-mail Will Levi 13 that I had seen the exhibit -- oh, you used it in
14 and asked for a copy, and I received a copy that 14 cross-examination, is that what happened? Because
15 night, Monday the 9th of November, at about 7:15, 15 55 is after --
16 7:20 is when I asked for it. 16 MR. MAC DOUGALD: R-055 or --
17 Q How did you react to the memo? 17 MR. FOX: Your 55, yeah.
18 A Well, you know, it was -- it looked 18 PANEL CHAIR HIRSH: We've seen the
19 helpful, and I was happy to know that again 19 document. I know it may have been referred to in
20 something was being done. I didn't know how 20 different contexts. But let me put it this way,
21 fruitful it would be, but at least I felt like the 21 does someone want to offer Respondents' Exhibit 559?
22 Attorney General and the U.S. Attorneys now were 22 MR. MAC DOUGALD: I tender it.

Page 1075 Page 1077

1 given instructions that they can pursue, you know, 1 MR. FOX: No objection, sorry.
2 allegations and investigate potential fraud and 2 PANEL CHAIR HIRSH: So 559 is offered. It
3 irregularities. 3 might be already an exhibit someplace else, I just
4 Q And did you have any other communications 4 wanted to make sure. Sorry to interrupt.
5 with Mr. Levi or Mr. Barr about election issues? 5 (Exhibit R-559 received.)
6 A No. 6 MR. MAC DOUGALD: I'm glad you did that,
7 Q Did you have any communications after that 7 Mr. Chairman.
8 with either Mr. Rich Donoghue or Jeffrey Rosen? 8 Your witness.
9 A No. 9 CROSS-EXAMINATION
10 Q About the election? 10 BY MR. HORRELL:
11 A No. 11 Q Good morning, Ms. Stirrup.
12 Q Did you have any communications with 12 A Good morning.
13 Mr. Clark? 13 Q Ms. Stirrup, I just want to be clear.
14 A With Mr. -- 14 When you were discussing your role as White House
15 Q Jeffrey Clark. 15 liaison to the Department of Justice, you said that
16 A No. 16 you dealt with political appointees.
17 MR. MAC DOUGALD: All right. That's all 17 A Yes.
18 the questions I have. 18 Q Does that -- that means that you were
19 PANEL CHAIR HIRSH: I just have one 19 involved in the hiring and promotion of political
20 technical point. Was Exhibit 559 admitted under a 20 appointees at the Department?
21 different number during Disciplinary Counsel's case, 21 A Right, in conjunction with the White
22 or is this the -- 22 House, office of presidential personnel.

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1 Q And so your role as White House liaison 1 Q How do you connect those two statements?
2 had nothing to do with Department investigations 2 A Well, I think his memo was guidance to the
3 into election fraud or any other issue; correct? 3 field in the states to look into allegations of
4 A No, not specifically. No. 4 fraud that are brought forward to the states.
5 Q I believe on direct you said that during 5 Q The memo was directed to the U.S.
6 your discussion with Mr. Levi, you asked him about 6 Attorneys?
7 what the Department had been doing, and I think you 7 A Yes. It says on the memo, it's the --
8 said it turned out to be nothing. 8 Q Right.
9 Isn't it true that Mr. Levi had told you 9 A Yeah, uh-huh.
10 the Department had looked at every allegation of 10 Q So the U.S. Attorneys were being -- were
11 election fraud and found in evidence? 11 authorized --
12 A Yes, he did. He said to me that the 12 A Correct.
13 Department had looked into allegations of fraud and 13 Q -- to conduct investigations?
14 the ones that were brought to their attention turned 14 A Correct.
15 out to be, you know -- there was nothing there, 15 Q But I understood you to say that Barr had
16 there was no fraud being committed. 16 said there wasn't a federal role in doing that, but
17 Q And Mr. Levi told you that the Department 17 on that same date, they sent out a memo that as I
18 would do everything it legally could to look into 18 read it, would say there's a federal role. There's
19 allegations; is that right? 19 also a state role, but there's a federal role.
20 A Yes, yes. 20 A Yes, I mean -- yes.
21 MR. HORRELL: I don't have any further 21 Q Is that how you understood it?
22 questions. 22 A Well, I understood he was -- I was looking

Page 1079 Page 1081

1 PANEL CHAIR HIRSH: Any redirect, 1 for a more aggressive, I think, approach, and he was
2 Mr. MacDougald? 2 basically saying there isn't, you know, what we're
3 MR. MAC DOUGALD: No, Mr. Chairman. 3 doing is we're providing guidance, it's not up to
4 PANEL CHAIR HIRSH: Any questions from the 4 us, that is the federal government.
5 panel? 5 And I suggested to him that he could even
6 PANEL MEMBER SMITH: I have a question. 6 issue an FAQ, a frequently asked questions, for the
7 EXAMINATION 7 public. I said, you know, that maybe that would
8 PANEL MEMBER SMITH: 8 assuage concerns that there isn't a federal role
9 Q Ms. Stirrup, when you -- in the 9 here, if there are allegations of fraud, they can --
10 conversation or in the discussion that you had with 10 I mean, I didn't write anything, I just suggested
11 Attorney General Barr and Mr. Levi -- 11 and I asked him -- I was wondering if there was
12 A Levi. 12 anything that could be done by him publicly that
13 Q -- you said that Barr indicated that there 13 could give assurance to the American people, the
14 isn't a federal role in regard to allegations of 14 voters, that everything is, you know, on the up and
15 fraud or voter irregularities. 15 up and if there's anything that's not, we're going
16 A Yes. 16 to look into it or it's going to be looked into or,
17 Q And that it is up to the states. So he 17 you know, any, you know, allegations of fraud
18 related that in the discussion? 18 handled by the states.
19 A Correct. 19 You know, in other words, give some
20 Q And then on that same date, the memo went 20 clarification as to what can and cannot be done with
21 out to the U.S. Attorneys? 21 regard to the election.
22 A Correct. 22 Q You said that when you saw the November 9

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1 memo, that it looked helpful and that you were happy 1 (Recess.)
2 that something was being done. 2 PANEL CHAIR HIRSH: Ms. Borrazas, can we
3 A Yes. I mean, it was minimal, but it was 3 get back on the live stream? Thank you very much.
4 something. 4 MR. HORRELL: Mr. Chair, before we call
5 Q This may be just a fine point. But I 5 the witness, we do have an objection to raise.
6 understood from the first conversation -- from that 6 PANEL CHAIR HIRSH: Okay. Could you get
7 conversation that you'd had with Barr, which was on 7 closer to the mike?
8 the same date, that he said there isn't a federal 8 MR. HORRELL: Oh, sure.
9 role. But aren't they describing a federal role in 9 What was originally provided to us as an
10 the November 9 memo? 10 expert report for Mr. Smith was an affidavit filed
11 A The degree to which U.S. Attorneys in the 11 in Arizona litigation in 2022. A large part of that
12 field have allegations of fraud brought to them, 12 affidavit is based on information that is post
13 they have the ability to investigate. And I think 13 January 3, 2021.
14 the memo was more or less stating that they should 14 We just got the updated expert disclosure
15 do that, they should investigate potential 15 this morning. I haven't reviewed it in detail, but
16 allegations of fraud that are brought to their 16 I understand from Mr. MacDougald that it largely
17 attention. 17 tracks the witness's original affidavit.
18 PANEL MEMBER SMITH: Okay. Nothing more, 18 What I see on a cursory review is that a
19 thank you. 19 lot of the updated opinion or updated disclosure is
20 THE WITNESS: Okay. 20 also based on information that was post January 3,
21 PANEL CHAIR HIRSH: Ms. Mathews? 21 2021.
22 And I have no questions, Ms. Stirrup. 22 So we would argue that this witness's

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1 Thank you very much for your time, really appreciate 1 testimony should be excluded under your prior ruling
2 it. You are excused. 2 that post January 3, 2021 evidence is excluded.
3 I'm sorry, unless there are further 3 PANEL CHAIR HIRSH: Mr. MacDougald?
4 questions from counsel. 4 MR. MAC DOUGALD: We have tailored the
5 MR. HORRELL: No. 5 opinion to comply with the chair's order on the time
6 MR. MAC DOUGALD: No redirect. 6 frame. And to be fair to opposing counsel, he's not
7 MR. HORRELL: No. 7 had time to read the whole thing and see where
8 PANEL CHAIR HIRSH: Okay. Sorry, needed 8 that's done. But we have done that.
9 to give them a chance. But now you're excused. 9 And if in the testimony he goes into stuff
10 (Witness excused.) 10 after January 3, it would be appropriate for him to
11 MR. MAC DOUGALD: Mr. Hirsh, Chairman 11 object at that time, with the -- we have designed it
12 Hirsh, my next witness, Shawn Smith, is in the 12 to --
13 waiting room, and I was going to ask if the Chair 13 PANEL CHAIR HIRSH: Are you planning on
14 would like to take a break before we start with him. 14 offering the report itself?
15 If not, we'll go ahead and get started. 15 MR. MAC DOUGALD: I was going to file it,
16 PANEL CHAIR HIRSH: How long is the 16 but maybe not offer it. I haven't filed it in yet,
17 testimony going to be? 17 but I can. And I'll follow your direction on that.
18 MR. MAC DOUGALD: It will be longer than 18 PANEL CHAIR HIRSH: I'm willing to take it
19 what -- it's quite a lot of ground to cover. 19 as it comes. And this is the witness we talked
20 PANEL CHAIR HIRSH: In that case, let's 20 about this morning who is going to testify on direct
21 take a break until 11:05. Thank you. All right, 21 and then we're going to defer the cross-examination?
22 11:06. 22 MR. MAC DOUGALD: Correct. Yeah, he

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1 gets -- 1 educational background?
2 PANEL CHAIR HIRSH: So maybe that will 2 A I have a bachelor's degree in political
3 give some time to sort this out also. And then the 3 science, master's in national security affairs and a
4 cross will be what, Wednesday? 4 master's in aeronautical science, mostly management
5 MR. MAC DOUGALD: Wednesday. I believe 5 side, but still technical.
6 he's in the waiting room. I call Shawn Smith. 6 Q What institutions awarded those degrees?
7 MS. BORRAZAS: Letting him in now. 7 A My undergraduate degree was from
8 PANEL CHAIR HIRSH: Mr. Smith, can you 8 California State Polytechnic University at Pomona,
9 hear me? 9 and my first master's degree was from Embry Riddle
10 THE WITNESS: I can hear you, good 10 Aeronautical University, and my second was from the
11 morning. 11 Naval Postgraduate School of Monterey.
12 PANEL CHAIR HIRSH: Good morning. My name 12 Q You said you were retired. What did you
13 is Merrill Hirsh, I'm the chair of the hearing 13 retire from?
14 committee. And I'm going to swear you in. Do you 14 A I retired from active duty in the United
15 want to either swear or affirm to the truth of your 15 States Air Force. I spent a little over 25-1/2
16 testimony? 16 years on active duty and retired as an 06 or
17 THE WITNESS: I'll swear. 17 colonel.
18 PANEL CHAIR HIRSH: Could you raise your 18 Q Describe for us -- well, let me put it
19 right hand, please. 19 this way.
20 Whereupon, 20 Can you describe for the committee your
21 SHAWN A. SMITH 21 background and qualifications in the field of
22 was called as a witness and, having first been duly 22 cybersecurity?

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1 sworn, was examined and testified as follows: 1 A Sure. In the first place, I was space and
2 PANEL CHAIR HIRSH: Could you please state 2 missile operations officer, so not a cyber operator.
3 your full name for the record. 3 But while I was at U.S. Space Command in
4 THE WITNESS: Shawn Alan Smith. 4 1998-to-2001 time frame, I worked within a vault
5 PANEL CHAIR HIRSH: Is it spelled 5 environment called the Special Technical Operations,
6 correctly, s-h-a-w-n? 6 or STO, vault, working with special access programs,
7 THE WITNESS: That's correct. 7 mostly related to space.
8 PANEL CHAIR HIRSH: How is Alan spelled? 8 But at that time U.S. Space Command
9 THE WITNESS: A-l-a-n. 9 assumed responsibility within the Department of
10 PANEL CHAIR HIRSH: Thank you very much, 10 Defense for operational employment as a combat and
11 Mr. Smith. 11 command cyber capabilities, both defensive and
12 Please proceed, Mr. MacDougald. 12 offensive.
13 MR. MAC DOUGALD: Thank you, Mr. Chairman. 13 And because I had written the procedures
14 DIRECT EXAMINATION 14 for operational employment for the department of
15 BY MR. MAC DOUGALD: 15 offense offensive space control or space negation
16 Q Mr. Smith, how are you currently employed? 16 systems, I was tasked to create the first procedures
17 A I'm retired, but I serve as one of the 17 for computer network defense at the operational
18 officers of Cause of America, which is a 18 level within the Department of Defense for cyber.
19 nonpartisan, nonprofit that supports grassroots 19 At the time we called it computer network defense,
20 entities and individuals within the 50 states in 20 now it would be called cyber defense.
21 pursuing election integrity in their states. 21 So that was the beginning of my exposure.
22 Q All right, sir. And what is your 22 I had already prior to that time I was doing coding

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1 from the time I was about 13 and had done some 1 infrared program, space -- JSpOC Mission System,
2 coding and modification of software on weapons 2 which was a command and control system, as well as a
3 systems within -- for the Air Force. 3 system to modernize and integrate space control
4 And following that point, I was assigned 4 catalogue functions that were at that time being
5 directly out of U.S. Space Command to the Air Force 5 performed by the legacy systems that come out of
6 Operational Test Evaluation Center, where I was 6 Cheyenne Mountain, as well as pretty much every
7 helping plan, execute, analyze and direct the 7 single compartment at space program within
8 operational test of U.S. weapons systems, Air Force 8 Department of Defense that I had any operational
9 weapons systems, that were all complex 9 testing.
10 computer-based weapons systems. 10 One that I can acknowledge because it was
11 In that capacity, we had to do analysis of 11 open to the public, it was public knowledge, was the
12 both the software on the systems as well as the 12 GSAP, or Geospatial Space information Awareness
13 threats to those software so that we could -- into 13 Program.
14 those systems so we could adequately represent 14 As part of my duties in that assignment, I
15 realistic threats in the course of operational 15 not only had to assess the technical progress and
16 testing. 16 potential of the weapons systems development and
17 And then when I -- and I continued to work 17 their readiness for operational tests as well as the
18 in the Special Technical Operations environment, 18 adequacy of their operational test plans and
19 including with cyber defensive and offensive systems 19 developmental test plans and the results, but also
20 over the course of the next 10 to 15 years. 20 their progress in terms of schedule performance.
21 My final assignment in -- on active duty 21 In order to do that, I had to delve into
22 was to the directorate of operational test 22 all the technical details of them, including the

Page 1091 Page 1093

1 evaluation under the Office of Secretary of Defense 1 software environment.
2 where I was assigned as the senior military 2 I had left off all the weather satellite
3 evaluator for space and intelligence surveillance 3 programs within the Department of Defense were also
4 and reconnaissance systems, and it was my job to 4 in my portfolio.
5 execute the director's responsibilities for 5 So it's pretty broad. Part of that was
6 oversight of the operational testing of all space 6 understanding all the threats to the systems to
7 weapons systems in the Department of Defense, with 7 ensure that those threats could be portrayed
8 the exception of satellite communications, which 8 adequately in operational testing. And so in that
9 were -- those oversight responsibilities were 9 capacity, I wrote the guidelines for threat
10 executed by retired Army officer that he and I sat 10 representation in operational testing of space
11 side by side or back to back. 11 systems for the Department of Defense and are signed
12 So in that capacity, I was responsible for 12 by the director, promulgated to the military
13 the oversight of operational testing, which included 13 services, the departments and the Joint Chiefs of
14 program management meetings, review of technical 14 Staff.
15 documentation, drafting and assistance with a small 15 And we also had to make sure -- and I
16 team of PhD scientists, adequate test and evaluation 16 helped quite a bit with development of threat
17 plans and then drafting reports after observing all 17 testing capabilities for national cyber range,
18 the testing processes, as well as assessment of the 18 because we were transitioning from a relatively
19 progress of those systems for at most -- I think at 19 uncomplicated and I would say inadequate
20 the most, I had 17 different programs in my 20 representation of cyber threats to space systems
21 portfolio, including the entire modernization of the 21 into one in which we understood that all of our
22 global positioning system programs, space-based 22 space systems, including satellites, ground systems

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1 and user segments, were going to have to be tested 1 Is there such a thing as a supply chain
2 for cyber threats, because all of them were 2 threat?
3 employing and dependent upon computerization, as 3 A Yes.
4 well as fairly complex software environments, 4 Q What is that?
5 including third-party and commercial software. 5 A Well, so in a national security
6 So I helped the director of the national 6 environment, when you think about a weapons system,
7 cyber range define and then procure the requirements 7 once upon a time, we really just thought about
8 for testing space systems in the national cyber 8 threats to the system as it was being employed in
9 range. 9 the field, because there was very little opportunity
10 And then of course, I would review and 10 to compromise anything involving the weapons system
11 report on an adequacy of developmental testing of 11 prior to that point because most of our
12 space systems. 12 manufacturing was inside the United States. Even
13 So I did that for a little bit over four 13 where we had designs overseas like where we had
14 years, and when I retired, my boss at the time, who 14 taken a British design to manufacture something, we
15 was kind of a three-star equivalent civilian, 15 were still doing the manufacturing application in
16 Dr. Crosswait, one of the deputies within 16 the United States.
17 operational test evaluation, asked me to stay on and 17 And our fabrication facilities and
18 help them with a project or program called 18 organizations were not networked, there was no such
19 adversarial assessment, where there was an FBI-led 19 thing as personal computers or networks, so there
20 task force that had a repository of data that had 20 was little opportunity for adversaries to compromise
21 been exfiltrated from U.S. national security 21 the designs or materials going into those systems.
22 establishment, including contractors and government 22 But everything changed with

Page 1095 Page 1097

1 organizations. 1 computerization and with the offshoring of
2 Through that you could see not only who 2 manufacturing, particularly the integrated circuits
3 had exfiltrated the data, and it was a massive, 3 and computer components and entire computer systems
4 massive amount of data, but in some cases, the types 4 to overseas, primarily to the People's Republic of
5 of systems and the program environments and offices 5 China.
6 that they had penetrated, compromising the 6 So the supply chain is all the goods and
7 exfiltrated from. 7 services that go into making a finished product that
8 So I helped with that program for about a 8 a consumer or customer is using.
9 year. We -- the team developed two reports out of 9 So if you think about, for example, an
10 that effort, and I was one of the principal authors 10 automobile, there are thousands of parts in that
11 of both of those reports. So I am eminently 11 automobile, from tires to computer chips to
12 familiar with the types of cyber threats to the U.S. 12 windshields to plastics in the dash, and the raw
13 national security establishments, organizations and 13 materials are part of the supply chain. The
14 weapons systems and how those cyber threats have 14 manufacture or fabrication of those raw materials
15 been employed and their rate of success, as well as 15 into individual components are part of the supply
16 the actors behind them, and by actors, I mean the 16 chain.
17 nation/state level advanced persistent threat teams 17 Integration of those components into whole
18 that were employing a variety of complex and 18 parts or into the whole system is supply chain.
19 exquisite techniques in a campaign over the period 19 And then the maintenance or support,
20 of years to penetrate and compromise U.S. and 20 ongoing support. So if you think about a modern
21 western technology and organizations. 21 vehicle, with something like Onstar, Onstar is a
22 Q All right, sir. 22 networked connection to the computers that are

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1 embedded within your automobile. 1 A Okay. Sorry about that.
2 So in other words, your vehicle doesn't 2 Q Quite all right. Everything okay?
3 leave the supply chain. It's created from it, and 3 A Would you ask that question again, please?
4 it is connected to it in perpetuity. And that 4 Q Everything okay on your end?
5 connection and that access, particularly when 5 A Yes, yeah, just a noise I had to abate.
6 aspects of the supply chain are managed or operated 6 Q All right. So the question was have you
7 or accessible to foreign nation states and in 7 looked at or analyzed statements made by various
8 particular the People's Republic of China, which has 8 U.S. government officials regarding the security or
9 been engaged in more than a decade-long 9 safety of the November 2020 presidential election?
10 nation/state-level campaign against western national 10 A Yes, I have.
11 security, including both economic and financial and 11 Q And are you familiar with claims made by
12 military, that access provides the ability for those 12 the Georgia secretary of state regarding the
13 nation/state-level actors, including both advance 13 cybersecurity of the Georgia 2020 presidential
14 persistent threat teams and their associated 14 election?
15 institutions, research institutions, to embed 15 A Yes, I am.
16 vulnerabilities, flaws and covert functions within 16 Q Have you ever testified in court as an
17 the components and even the materials that comprise 17 expert on cybersecurity?
18 the systems and components that we use for national 18 A Yes, I have. One time I've testified, I
19 security purposes in the United States. 19 was prepared to testify in Arizona in the Lake v.
20 Q All right, sir. 20 Hobbs case, or it might have been the Lake v.
21 Have you applied your background, 21 Fontes, an injunction case, the one that petition
22 knowledge, skills, expertise to analysis of the 22 for writ of certiorari was just filed in the Supreme

Page 1099 Page 1101

1 cybersecurity situation surrounding computerized 1 Court. But I didn't end up testifying in the
2 voting systems? 2 Arizona case. They did retain my declaration in
3 A I have. 3 that case, but I testified in Hanes v. Merrill in
4 Q And have you -- in the course of that, 4 Alabama.
5 have you done any analysis of the Dominion Voting 5 MR. MAC DOUGALD: All right, sir.
6 Systems election system? 6 Your Honor, at this point I tender
7 A I have. 7 Mr. Smith as an expert on cybersecurity in election
8 Q Have you analyzed the state of election 8 voting systems as used in the state of Georgia in
9 cybersecurity as it existed leading into and 9 the 2020 election.
10 immediately after the presidential election of 10 MR. HORRELL: May I do voir dire?
11 November 2020? 11 PANEL CHAIR HIRSH: Sure.
12 A I have. 12 VOIR DIRE EXAMINATION
13 Q Have you reviewed or analyzed the systems, 13 BY MR. HORRELL:
14 methods and certifications that are relied upon to 14 Q Good morning, Mr. Smith. My name is Jason
15 establish that election systems are secure? 15 Horrell, I work for the Office of Disciplinary
16 A Yes, I have. 16 Counsel. I just have a few questions for you
17 Q Have you reviewed or analyzed statements 17 regarding your background.
18 made by U.S. government officials regarding the 18 A Yes, sir.
19 cybersecurity of the November 2020 election? 19 Q When you first started testifying, I think
20 A Excuse me just a moment. Give me just one 20 you said that you are an officer for a nonprofit
21 moment. 21 organization, I believe you said the Cause of
22 Q Yes, sir. Okay. 22 America; is that right?

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1 A That's correct. 1 volunteering with an informal assembly of citizens,
2 Q When was that organization founded? 2 a volunteer group in Colorado called the U.S.
3 A Oh, well, it was stood up in November of 3 Election Integrity Plan.
4 2021, but I think incorporation followed -- legal 4 But I had done any -- I knew nothing about
5 incorporation followed a couple months later. We 5 election systems whatsoever, I couldn't have named a
6 had started working before we had the whole 6 single vendor or any of the components or told you
7 framework established. 7 what rules were involved or who had promulgated them
8 Q Who founded that organization? 8 or what testing was conducted prior to November
9 A It was myself, Jeff Young, Holly Kasun, 9 2020. That's when I first saw an article in a local
10 Michelle Replogle and Mike Lindell. 10 Colorado news outlet after I had voted, I saw an
11 Q And Mike Lindell is the CEO of My Pillow? 11 article about turnout, started researching turnout,
12 A That's correct. 12 downloaded data from the secretary of state in
13 Q Regarding your educational background, you 13 Colorado, did some crude regression analysis on it
14 testified to two master's degrees, one in national 14 in comparison to population trends, compared, you
15 security and one I believe you said aeronautical 15 know, similar elections over time and the changes in
16 science. 16 voter registration and turnout rates related to
17 A That's correct. 17 population growth.
18 Q When were those two degrees -- when did 18 And then started reading the technical
19 you earn those two degrees? 19 data package manuals for voting systems and then
20 A Aeronautical science would have been -- 20 test plans and reports and from there started
21 that was the first, probably around year 2000, 2001. 21 reading all the voting system standards and the
22 And then my degree from Naval Postgraduate School 22 issuances and notices for the election systems

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1 was -- I completed all the requirements for it in 1 commission.
2 December 2006. I'm sorry, December 2005. 2 Q So it's fair to say that you performed no
3 Q Are either of those master's degrees 3 work regarding election security or election
4 computer science degrees? 4 administration prior to the election of November
5 A No, sir. 5 2020?
6 Q Did you take any courses for either of 6 A Well, let me think about that for a second
7 those master's degrees specifically related to 7 and what I can actually say.
8 election administration in the United States? 8 Q No professional --
9 A No, sir. 9 A So early in my career at various points, I
10 Q Did you take any courses specifically 10 was involved in the employment of special access
11 related to election security in the United States? 11 program capabilities within Special Technical
12 A No, sir. 12 Operations environment, which included some
13 Q I think you said that you retired from 13 information warfare and information operations
14 active duty in 2017? Did I get that right? 14 capability that were explicitly designed and
15 A That's correct, August 2017. 15 employed to affect the outcomes of elections in
16 Q Mr. Smith, when have you worked in a role 16 foreign countries. That's about all I can say about
17 specifically involving election security issues? 17 that.
18 A Well, prior, you mean, to my current 18 But I had no involvement with U.S.
19 position? 19 elections and knew nothing about U.S. election
20 Q Yes. 20 infrastructure prior to November 2020.
21 A With Cause of America? That's the first 21 Q So it's fair to say, then, that you've
22 position in which I have worked, although I was 22 never worked for any U.S. governmental agency that

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1 procures election and voting systems? 1 A Not to my knowledge.
2 A Not to my knowledge. 2 Q Mr. Smith, what experience do you have
3 Q Okay. And you've never worked for any 3 working in an election security lab where machines
4 governmental agency that oversees election and 4 are tested for technical and security issues?
5 voting security? 5 A Can you give me an example of the type of
6 A Well, just to backtrack for a moment, to 6 election security lab you're talking about?
7 be fair, U.S. government agencies don't procure 7 Q I mean, do you not understand the
8 election systems. I'm not sure if you're aware of 8 question?
9 that. 9 A No, I do. I'm just not sure which kind of
10 Q So I -- okay. That's a fair point. 10 labs you're talking about. Are you talking about a
11 What I meant to ask is any governmental 11 lab that would be, for example, performing
12 agency within the United States, so either federal, 12 electrical or environmental compliance testing on
13 state or local level, that procures election -- 13 voting systems, or are you talking about one of the
14 A That's correct, that's correct. I have 14 voluntary voting system guidelines types of labs
15 not worked for any governmental agency within the 15 that voting system testing labs like Pro V&V and
16 United States that has procured election systems. 16 SLI, Incorporated?
17 Q Same concept. You've never worked for any 17 Q Have you worked in any scientific lab
18 governmental agency at any level of government that 18 regarding any election machines used in the United
19 oversees election and voting security? 19 States?
20 A Not exactly true. The Department of 20 A No. But when you say "scientific,"
21 Defense oversaw election security in the process of 21 there's no science involved. These are -- you know,
22 voting within foreign nations at multiple times, 22 there's no scientific lab for voting systems that is

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1 during which I was involved in planning for civilian 1 testing systems for use in the United States.
2 transition. 2 That's not a thing.
3 Q But that position, it sounds like you're 3 Q What experience do you have -- aside from
4 saying that position wasn't involved -- did not 4 voting, what experience do you have directly working
5 involve elections here at home in the United States? 5 with election machines used in the United States?
6 A That's correct, yeah. 6 A Well, when I got curious about why I was
7 Q Okay. 7 seeing, for example -- on Dominion Voting Systems --
8 A I would say, I mean, it was very much 8 so how do I backtrack and talk about this?
9 like -- so most of the oversight that I executed, I 9 When you look at the metadata for images,
10 was not part of the organizations that were 10 there are certain tools that you use to analyze the
11 procuring. I was part of an organization 11 metadata associated with digital image files. And
12 responsible for oversight. So it wasn't -- it was 12 there should be very clear metadata that pops up
13 never -- it was never that my research into the 13 when you use those tools.
14 technical details, the requirements for or the 14 There's also sort of typical sciences.
15 threats against any of those systems were conducted 15 You might be familiar with your phone, if you have a
16 when I was part of the system responsible for 16 camera on your phone and you take an image with a 3
17 procuring them. 17 megapixel image sensor or image size compared to a
18 Q And it's fair to say that you never 18 10 or 12 or 15 megapixel image size, you're going to
19 actually worked for any governmental agency at the 19 have very typical file sizes.
20 federal, state or local level to employ or use 20 You could take 100 photos in a row or 1000
21 election and voting systems during an actual 21 photos in a row. And if you use the same setting or
22 election? 22 image sensor, you're going to get relatively

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1 comparable image file sizes for those images stored 1 exact same drivers. And the configuration settings
2 on your phone. 2 from their manuals.
3 So when I looked at image files that had 3 I would also say that in my duties in
4 come off of Dominion Voting Systems, the file sizes 4 oversight of operational testing, I read hundreds,
5 were not what I expected. And I was curious about 5 probably thousands of technical manuals and had the
6 it, and so I bought the identical hardware that they 6 responsibility, you know, to understand the details
7 were using in the ImageCast Central scanner, in the 7 of those.
8 ImageCast Central scanner's computer, which was a 8 So I delved very far into the technical
9 Dell all-in-one computer. 9 material and I understand what I'm doing. I've also
10 And then I went through their technical 10 trained research and I've done that professionally.
11 data package, through the manuals for configuration, 11 So I spent a year doing research with the Rand
12 and I didn't have their proprietary software, but I 12 Corporation of Project Air Force, including a lot of
13 had the drivers that they used. And I configured my 13 research that then went forward to -- for example,
14 system and its software as identically as I could to 14 I've devised disaggregation of complex concentrated
15 the Dominion system so that I could do some testing 15 satellite systems as well as employment of forces
16 of scanning ballots to see what the image files 16 and things like that.
17 looked like, because I wanted to understand exactly 17 Q Mr. Smith, have you --
18 why the image files were not as expected. 18 A I'm an experienced researcher.
19 Q But is it -- 19 Q Have you ever worked for any private
20 A So -- and then when we were in South 20 company that manufactures election and voting
21 Dakota for the cybersecurity symposium, Mark Cook 21 machines used in the United States?
22 and Travis Smith and I, between the three of us, 22 A No.

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1 actually set up an optical scan tabulator to scan 1 Q What peer-reviewed research have you
2 ballots using basically our own software and 2 published regarding election security issue?
3 database and some software written by one of the 3 A What peer-reviewed research? You're
4 volunteers back in Colorado here to do the actual 4 talking about a scientific approach. I'm not a
5 optical scanning conversion into characters that the 5 scientist. Also, I think peer review has been
6 SQL database would ingest. And set up a tabulator 6 largely discredited over the last four years, but
7 and then we operated the tabulator. 7 yeah, I haven't published -- I have published --
8 Q So it sounds like, or I guess is it fair 8 well, let me back up.
9 to say, then, that you've never actually worked with 9 So I did -- well, it wasn't about voting
10 the machines that any locality actually used in an 10 systems. We were talking about voter roll
11 election? 11 corruption. But I did -- I did -- I was one of the
12 A No, that's not fair to say. 12 authors in what was called the Colorado report,
13 What I just described for you is I used 13 which was an analysis of the canvassing of voter
14 the actual hardware and the driver settings and 14 registration data in Colorado.
15 configuration that are exactly what Dominion uses in 15 Q So it sounds like the answer is that
16 their voting systems in thousands of jurisdictions 16 you've published no peer-reviewed research?
17 across the country. So other than that. 17 A About voting systems, correct.
18 Q But absent the proprietary software that 18 Q What professional certifications do you
19 those companies may use with their machines? 19 hold regarding election security or election
20 A Right. The proprietary software is still 20 administration, if any?
21 employing the same drivers, as I described, like the 21 A None, although I would -- you know, I have
22 Kofax VRS drivers and the Canon drivers, I used the 22 reviewed information within those certification

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1 courses. And they are largely indoctrination that 1 payment. This is part of my duty.
2 tells the officials that are taking those courses to 2 Q Have you ever testified in court as an
3 trust the EAC certifications and the conduct of the 3 expert or -- well, have you ever testified in court
4 voting system testing labs. 4 as an expert prior to the Hanes v. Merrill case?
5 What I am an expert in is testing, and so 5 A No. As I stated, I was at the courthouse,
6 I can look at the test plans and test reports and 6 sat through the hearing, was prepared to testify in
7 credentials of the individuals involved and the 7 the injunction case in Arizona, but they just ran
8 certification testing of voting systems. I will 8 out of time. The judge did not allow very much time
9 tell you right away, they would be intolerably 9 for the hearing.
10 inadequate for any other national security or 10 Q Regarding the Hanes v. Merrill case, were
11 critical infrastructure system. 11 you aware that the circuit court dismissed that case
12 Q Earlier you testified that you had 12 after the hearing?
13 testified in I believe you said Hanes v. Merrill, 13 A No.
14 which was a case in Alabama; is that right? 14 Q And were you aware that the Alabama
15 A That's correct. 15 Supreme Court affirmed that dismissal?
16 Q That was in the Circuit Court of 16 A No. Should I have been aware of that?
17 Montgomery County? 17 Would that affect my testimony or -- I'm not sure
18 A That's correct. 18 that would affect my opinion about things or the
19 Q And that was -- that case was filed in 19 facts involved. Is there -- do you need me to refer
20 2022; is that right? 20 to it or do you have questions to follow up?
21 A I don't know when it was filed. 21 MR. HORRELL: No.
22 Q Did you testify at a court hearing or in a 22 Mr. Chair, I don't have any further

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1 deposition? 1 questions, but we would object to Mr. Smith being
2 A On the stand in front of the judge. 2 qualified as an expert in cybersecurity issues
3 Q And what was that hearing about? 3 relating to the election specifically in Georgia.
4 A I believe it was an injunction case. I 4 There's just simply -- he has simply no
5 didn't ever actually read the whole case. I believe 5 experience to apply his cybersecurity knowledge to
6 it was an injunction case against use of specific 6 election issues, administration, security or
7 voting systems in the state of Alabama. 7 otherwise.
8 Q And did the court specifically qualify you 8 So we would object to his qualification on
9 as an expert to testify in that case? 9 that ground.
10 A I'm not sure how to answer that. The 10 PANEL CHAIR HIRSH: Mr. MacDougald, do you
11 judge accepted my credentials as an expert witness 11 want to address the objection?
12 and allowed me to testify. 12 MR. MAC DOUGALD: Yes. Your Honor, under
13 Q And the expert report that you signed, I 13 Rule 702, a witness may be qualified as an expert by
14 believe you signed this today, the expert report 14 "knowledge, skill, experience, training or
15 that you signed today avers that you've only 15 education."
16 testified at a deposition or trial, not that you've 16 And the witness's testimony concerning his
17 testified as an expert. 17 qualifications for evaluating the cybersecurity and
18 A Okay. I'm not sure what difference you're 18 supply chain threat environment for the crown jewels
19 getting at. Maybe you could explain what you mean. 19 of the national defense establishment, satellite,
20 Q Were you retained by -- who were you 20 sensor, communication and location systems, missile
21 retained by, if anybody, to testify in that case? 21 systems and so on, and the requirement that he be
22 A No one retained me. I don't accept 22 adept and familiar with the technical specifications

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1 and testing regimes and be able to characterize the 1 Georgia to certify their systems as safe and secure
2 threats that must be defended against and test for 2 are grossly inadequate, that they create a false
3 defense against those threats qualifies him to 3 sense of security in the public when they are
4 evaluate the testing regime and security situation 4 repeated by public officials, as was done following
5 for other types of systems. 5 the 2020 election, without adequate technical or
6 And his testimony was that he did the work 6 factual foundation. And contrary to many other
7 he did in the military on a wide variety of systems. 7 warnings.
8 The expertise is not stovepiped, his type of 8 And he will testify or I would like to get
9 expertise is not stovepiped to one type of machine 9 him to testify that based on everything that was
10 or system, and can be readily applied to other types 10 known in November and December of 2020, including a
11 of systems, such as election systems. 11 series of recommendations and analyses made by the
12 He also testified that he has studied the 12 top election cybersecurity experts in the country,
13 testing program and certification for security for 13 made to the State of Georgia not to use the Dominion
14 election systems and has formed opinions on those 14 system, that they did it anyway.
15 topics. 15 And then he will testify to his
16 So the witness is eminently qualified to 16 familiarity with the order by Judge Amy Totenberg in
17 testify about these subjects, and the fact that he 17 the Northern District of Georgia in October of 2020
18 doesn't have a degree in election cybersecurity or 18 that the Georgia election system did not comply with
19 hasn't worked for an election system vendor doesn't 19 the Georgia code requirements that it be secure and
20 diminish his qualifications to evaluate whether 20 that it be voter verifiable.
21 these systems are robust from a cybersecurity 21 And finally, he will say that the
22 standpoint. That's what he did for the government 22 circumstances warranted further investigation. And

Page 1119 Page 1121

1 for 20-plus years. 1 there is one other point that I would like for him
2 PANEL CHAIR HIRSH: Mr. MacDougald, could 2 to cover, which is the topic of how some of these
3 you articulate again exactly the purpose for which 3 penetrations are accomplished. And there was
4 you would like him to be qualified as an expert? 4 mockery by Mr. Donoghue of Mr. Clark for mentioning
5 MR. MAC DOUGALD: Yeah, yes. 5 in one of their discussions that a penetration had
6 So I would like to ask the witness to give 6 occurred through a thermostat, that was held up as
7 a series of opinions about the nature of the threat 7 ridiculous, a paranoid conspiracy theory.
8 environment, whether the systems or methods that 8 Mr. Smith will have testimony on that
9 have been used in the U.S. and in Georgia in 2020 to 9 topic as well and how the Internet of things is a
10 defend against those threats are adequate against 10 vector for hacking, particularly when you're dealing
11 the nature and scale of the threat, and the 11 with the sophistication and level of effort exerted
12 testimony would be that they are pathetically 12 by nation state adversaries, especially the People's
13 inadequate. He alluded to that already. 13 Republic of China, whose efforts in this domain are
14 The -- he would comment on statements that 14 truly gargantuan compared to the defenses that our
15 were made by U.S. government officials that were 15 country musters and compared to the defenses that
16 testified to by Mr. Rosen -- well, I know 16 are mounted for election systems in particular.
17 Mr. Donoghue, maybe Mr. Rosen as well, that it was 17 PANEL CHAIR HIRSH: Mr. MacDougald, that's
18 the most secure election ever. He would dispute 18 a somewhat longer answer than I anticipated. You
19 that vigorously and convincingly. 19 know, normally you proffer an expert as an expert in
20 And that the standards and testing regime 20 X, okay, and I was just trying to clarify what X was
21 for election equipment put out by the EAC and 21 and you gave me a whole proffer of his testimony.
22 administered by testing labs used by the State of 22 MR. MAC DOUGALD: I apologize.

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1 PANEL CHAIR HIRSH: I didn't want to 1 Over the course of in particular the last
2 interrupt. 2 10 to 15 years of my time on active duty, came to a
3 MR. MAC DOUGALD: It was a good speech. 3 very detailed and deep understanding of the cyber
4 PANEL CHAIR HIRSH: It was a really good 4 threats arrayed against U.S. national security
5 speech, there are tears. 5 systems.
6 (Laughter.) 6 In particular in the last year where I
7 PANEL CHAIR HIRSH: You know, but can you 7 spent as a contractor supporting office of secretary
8 give me the what are you proffering him as an expert 8 defense director of operation test evaluation for
9 in so I can rule on your motion to have him 9 the adversarial assessment, I saw exactly what has
10 considered that? 10 been taken and how the organizations from which the
11 MR. MAC DOUGALD: Cybersecurity, broadly 11 data had been taken and penetrated were compromised.
12 speaking, to include supply chain threat, assessment 12 So I came to really understand that
13 and mitigation in the context of the election 13 complex, exquisite and broad approach that the
14 systems used in Georgia in November of 2020, and 14 adversary campaign was taken to cyber, so I really
15 further as to the adequacy of the certification 15 understand that threat well.
16 programs and subsequent claims that this election 16 And having understood that threat well,
17 was secure and free of any threat, all of which was 17 having seen what it did to organizations and
18 relied upon by Disciplinary Counsel in the 18 systems, weapons systems and national security
19 case-in-chief and testified to by Mr. Donoghue, who 19 systems, that were not only procured and designed to
20 certainly is not an expert in those topics. 20 be defended against those specific threats but were
21 PANEL CHAIR HIRSH: I mean, the last part 21 actively defending, everyone I knew and everyone I
22 is not part of his qualifications, it's an argument 22 worked with came to the same conclusion. If you

Page 1123 Page 1125

1 that you want to make and whatever. 1 weren't actively defending your systems, you had no
2 MR. MAC DOUGALD: I can't help it 2 chance to defend them whatsoever, you had to assume
3 sometimes. 3 that they were penetrated and compromised.
4 PANEL CHAIR HIRSH: I'm going to allow him 4 And in fact, Department of Defense
5 to testify as an expert on that subject. I think 5 cybersecurity strategy has shifted from a focus on
6 that the points that Mr. Horrell raised may 6 preventing penetration to an assumption that
7 potentially go to the credibility of the testimony. 7 penetration will occur because it occurs so often,
8 So I'll take them into account. 8 so frequently, so consistently without exception.
9 MR. MAC DOUGALD: I'm perfectly fine with 9 Not just physical access to facilities,
10 them taking their best shot on cross. Thank you. 10 but the access both remote and local to components.
11 DIRECT EXAMINATION (Continued) 11 When I took that background and what I
12 BY MR. MAC DOUGALD: 12 understood about that advanced persistent threat
13 Q All right, Mr. Smith. 13 posed by foreign adversaries and used that as a lens
14 A Yes, sir. 14 to look at our voting systems, including Georgia's
15 Q Did I ask you to form certain opinions or 15 voting systems, in particular because -- because in
16 ask you if you have certain opinions relating to the 16 Georgia, you have examples like Professor Wenke Lee,
17 election system produced in Georgia in 2020? 17 who was advising the SAFE commission that was
18 A Yes, sir. 18 charged with making a recommendation on
19 Q Can you tell us what they are? 19 procurement --
20 A Well, I would say Georgia is not unique. 20 Q Let me interrupt you, let me interrupt you
21 Our electronic and computerized voting systems are 21 there --
22 effectively undefended and defenseless. 22 A -- disallowed.

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1 Q Mr. Smith, I would like to interrupt you 1 Georgia.
2 and ask you to tell the committee what the SAFE 2 So the Dominion Voting Systems, the
3 commission was. 3 Democracy Suite 5.5, I've read substantial portions
4 A The SAFE commission was a panel of I guess 4 of the technical data and the test plans and reports
5 experts like Wenke Lee, a PhD professor and 5 and user guides and instruction manuals for pretty
6 stakeholder, so people who were not really 6 much every one of the Democracy Suite systems within
7 particularly expert but may have an interest, for 7 the 5 series as well as 4 series, because those are
8 example, representatives of communities of people 8 used in so many different jurisdictions. I read
9 with disabilities that want to make sure that any 9 every test report and test plan that EAC posts
10 voting system that is selected or procured enables 10 publicly, as well as some of the state-specific
11 access for people with disabilities. 11 reports, like reports from California which uses a
12 So SAFE commission was formed I believe by 12 non-EAC certified version 5.10. I am very familiar
13 secretary of state of Georgia to make a 13 with the components.
14 recommendation on procurement of replacement voting 14 I've looked up the computer components,
15 systems for Georgia, to both the governor and the 15 the actual components of the Dell computers used in
16 secretary of state. 16 the Dominion systems, within the Dell support site.
17 So Professor Lee was the cyber advisor, 17 So I've looked at how the specific computers are
18 the only real cyber expert advising that commission. 18 configured, which hard drives they have, where those
19 Q Okay. I interrupted you. Please pick 19 are from, manufactured, memory devices, trusted
20 back up where you were. 20 platform modules, the processors.
21 A Yes, sir. So what I was saying was I came 21 I've looked at the personnel involved in
22 to understand the threat, you know, I would say very 22 developing and designing the processors and other

Page 1127 Page 1129

1 well, the cyber threat to U.S. national security 1 components as companies like Intel at their
2 systems, including critical infrastructure. And 2 Chandler, Arizona, facility.
3 that's a thing, which I wasn't trying to be 3 I'm very familiar with those systems. And
4 disrespectful when I laughed at the other counsel's 4 because of that, because of my familiarity with the
5 questions, but asking about the specific experience 5 threats, the cyber threats, posed by advanced
6 with election systems from a threat perspective, 6 persistent threat teams, when I look at the voting
7 from an adversary perspective, there's nothing 7 systems being used in Georgia, and again not unique
8 unique about the election systems, they're just 8 to Georgia and not even unique to Dominion, I see
9 computers. 9 from my perspective and with my background nothing
10 This is why when we started inventing 10 but vulnerabilities.
11 computers in everything from missiles to artillery 11 I mean, gross, intolerable sort of
12 shells to helicopters to ships, when you stick a 12 mission-compromising vulnerabilities.
13 computer in it, it's like former Air Force Chief of 13 These systems -- you know, we had just as
14 Staff David Goldfein said about the joint strike 14 an example to understand why I'm saying this, when I
15 fighter. It's not so much a plane anymore as it's a 15 was responsible for oversight of global positioning
16 computer that flies. 16 system, it was the GPS modernization, so new
17 Once you make a system dependent on the 17 satellites with a new broadcast code on them, a new
18 computers and accessible, it's a computer that does 18 signal structure, new ground control segments and
19 things with those computers, it's not really unique 19 new user equipment.
20 to its domain. 20 The user equipment required a specific
21 And there is nothing unique about the 21 integrated circuit that would be limited to just the
22 computers being used in voting systems, including in 22 functions, it's called an application-specific

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1 integrated circuit, and it required those to be 1 MR. HORRELL: Mr. Chair, I'm sorry --
2 developed, tested and then once procured, embedded 2 THE WITNESS: At the time there might be
3 in literally millions of devices and platforms, 3 hundreds in an election system computer. You can
4 everything from hand held to helmet worn to 4 only see what's in that circuit by destructive
5 munitions to planes, trains and automobiles, 5 forensic examination. You'll never be able to
6 basically every platform in the U.S. inventory. 6 examine it or even find that and test it.
7 Satellites even were going to be using these 7 So having not secured the supply chain for
8 receiver modules. 8 those systems, from my perspective with my
9 And the design, the fabrication design. 9 background and experience and what I've seen of the
10 So in a fabrication facility for integrated 10 threat array against our critical infrastructure and
11 circuits, it's essentially like a blueprint in 11 national security systems, there's no way to secure
12 layers, you know. The feature design size in those 12 those computers and the voting systems that depend
13 integrated circuits is extremely small, thousands of 13 on them.
14 times smaller than the size of a human hair. It's 14 MR. MAC DOUGALD: All right, Mr. Smith.
15 not visible to the naked eye. 15 PANEL CHAIR HIRSH: I think Mr. Horrell
16 So you have these digital blueprints, if 16 had an objection.
17 you will, CAD/CAM, for each layer, and then those 17 MR. HORRELL: I think I understood the
18 have to be fabricated and assembled in a chip 18 relevance of all of that at the very end. I think
19 fabrication facilities, a fab, a foundry. 19 it would be helpful though if we can proceed in a
20 And the prototype designs that were to be 20 normal direct where we have question, answer,
21 tested were stored briefly in a facility on an 21 question, answer, rather than allow the witness to
22 unsecured computer in an unsecured room. And 22 go on a narrative answer.

Page 1131 Page 1133

1 because of that, because the threat from the exact 1 PANEL CHAIR HIRSH: Yes.
2 same adversary advanced persistent threat teams that 2 Mr. MacDougald, if you could -- I'm not
3 are threatening and would be attacking and trying to 3 sure your questions are calling for narratives, but
4 compromise election systems, because that threat is 4 I think you are getting narratives that might be
5 so severe, because those designs were unsecure for 5 better by direct.
6 just I want to say it was two weeks, the room was 6 MR. MAC DOUGALD: I'll tell you a story
7 unsecured, a couple days that the computer was 7 about this very thing. A federal district judge in
8 unsecured, the program office had to go back through 8 Atlanta, I had an expert on the stand, and I was
9 every single aspect of that design. It was a year 9 taking him to the points I wanted him to talk about,
10 of delay. 10 framing them as direct questions. And the judge
11 And the reason for that is because we had 11 interrupted me three times and said if you don't
12 already seen within the Department of Defense that 12 stop leading this witness, I'm going to disregard
13 adversaries had unrestricted or unfettered access, 13 everything he says. And then I finally said tell me
14 even momentarily, to digital designs, to the 14 what you think. And he went on for 15 minutes and
15 materials going into a critical component, to the 15 the judge had a big grin on his face, he loved it.
16 components themselves, they could compromise those 16 So I will try to chop it up a little bit
17 components and designs in a way that would be 17 more.
18 undetectable. 18 PANEL CHAIR HIRSH: No, I understand. I
19 A supply chain compromise is particularly 19 understand there's a skill-type problem in it. I'm
20 damaging because it is very difficult to detect 20 just trying to --
21 after the fact. 21 BY MR. MAC DOUGALD:
22 Like an integrated circuit -- 22 Q So Shawn, we're going to try to shorten

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1 the answers up a little bit. 1 China.
2 A Yes, sir. 2 So they have access to embed if they wish
3 Q I will move us from one topic to the next. 3 to, and they have, to embed compromises within the
4 Just recapping what you said, is there, to 4 computers they are manufacturing that they will be
5 your observation in the election machine space, is 5 shipping to western and U.S. customers.
6 there adequate awareness of the scale and nature of 6 Q All right, sir. Are you aware of any
7 the threat? 7 organized or structured efforts to attack election
8 A No, absolutely not. The voting system 8 systems run by hacker conferences or otherwise or
9 standards themselves -- so no voting system in the 9 experimentally?
10 United States is certified by the election system 10 A Yes, I am.
11 commission to any standard newer than the 2005 11 Q What has been the outcome of those?
12 standards, and neither the 2002 nor 2005 nor 2015 12 A So at the DEF CON conferences, I think
13 voluntary voting system guidelines. 13 there have been four DEF CONs, which is a
14 The voting system standards in 2002 and 14 convention, a hacker's convention that's held
15 then the 2005 and '15 voluntary voting system 15 annually, I think they have had villages at four DEF
16 guidelines don't even mention supply chain security. 16 CONs where they have taken voting systems, they have
17 They don't require any aspect of it to be examined 17 taken them and allowed the hackers or participants
18 or verified. 18 there the opportunity to try to get unauthorized
19 And all of the voluntary voting system 19 access to establish access to and be able to control
20 guideline standards are what we would call in the 20 or modify software or hardware settings on those
21 testing community compliance-based standards. 21 voting systems. And they have never had any
22 So in other words, you read off, does the 22 difficulty doing that.

Page 1135 Page 1137

1 system use passwords, yes, check. It's not an 1 Some vendors have refused to allow their
2 adversarial assessment. 2 more current systems to be attacked in that way.
3 The standard for national security 3 Others, they have had no choice, they weren't
4 systems, because of the severity and pervasiveness 4 willingly participating but people procured
5 of the threat, is to subject those systems to 5 components and brought them or set them up. Like
6 adversarial testing. 6 Harry Hursti has done that, set them up at DEF CON.
7 What that means is you have typical 7 And then there's also CISA themselves,
8 operators employ them in a realistic and operational 8 Cybersecurity and Infrastructure Security Agency has
9 environment and manner and then you have red teams 9 published notices and warnings about foreign nations
10 that emulate adversary threat capabilities try to 10 taking advanced persistent threats that were
11 penetrate, attack, compromise and permeate those 11 attempting to or had gained access to election
12 systems. Even that is very difficult to replicate 12 infrastructure.
13 in advanced persistent threat because they're 13 Q Before the 2020 election?
14 working with design and research bureaus over the 14 A Yes, before the 2020 election. There were
15 course of years. And because the components for the 15 at least -- there were at least five warnings and
16 computers in our voting systems are being 16 notices from CISA in 2020 related to adversaries
17 manufactured overseas with full access to those same 17 either specifically probing and trying to attack
18 institutions. 18 election infrastructure or to sort of broad
19 For example, the Chinese PRC's ministry of 19 adversary attempts to attack critical
20 state security has personnel that they embed within 20 infrastructure, which of course since 2017 included
21 fabrication facilities like Foxconn's or like 21 election infrastructure.
22 Wistron's manufacturing facilities in mainland 22 Q And how did it -- so how did election

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1 infrastructure become critical infrastructure and 1 something, but it's -- okay, there we go.
2 what does it mean to say that they are critical 2 I've taken us down to page -- well, I'm
3 infrastructure? 3 not sure what page it is, page 1 under technical
4 A Well, it was Secretary of Homeland 4 details. There's a reference that I've highlighted
5 Security Jeh Johnson in January of 2017 just prior 5 to attempted exploitation, it goes on, SQL
6 to the presidential transition, inauguration who 6 injection.
7 declared election infrastructure of the United 7 What does SQL injection mean?
8 States to be critical infrastructure and placed it 8 A SQL injection is a tactic used to
9 under the facilities subsector, which placed it 9 compromise systems in running SQL databases or SQL
10 under CISA's sort of primary responsibility, 10 database management software.
11 depending on where the infrastructure category is, 11 So you can -- depending on the -- so
12 there might be a different government agency that's 12 within structured query language, which is just --
13 responsible for oversight of requirements and 13 it's sort of -- it's a semantic approach to how you
14 security efforts for critical infrastructure. 14 query and organize data within relational databases.
15 To place something under that designation 15 And SQL injection capitalizes on the
16 is to subject it to certain restrictions, for 16 ability to execute code on the victim or target
17 example, that would allow industry sector members to 17 system from within the SQL database or SQL database
18 share information about vulnerabilities and 18 software.
19 compromises confidentially with information-sharing 19 So it's a vulnerability within any system
20 analysis centers that are run as public/private 20 that's posting a SQL database or SQL management
21 partnerships between CISA and the Center For 21 software.
22 Information Security. The theory behind that is you 22 Q A successful SQL injection could do what

Page 1139 Page 1141

1 allow the sharing of vulnerability information that 1 to voter registration databases?
2 would help other sector members protect themselves 2 A Well, you could permute or compromise the
3 but would not expose the sector members to reveal 3 data itself. So in other words -- it depends very
4 that information confidentially to liability that 4 much on the configuration of a system and the
5 might affect, for example, their public stock 5 capability, skill set and whether -- of the
6 prices. 6 personnel involved and whether they have, you know,
7 So the idea is to encourage information 7 any sort of comprehensive monitoring software for
8 sharing so that it will help reduce the 8 change detection or reviewed auditing of log files
9 vulnerability of the sector as a whole. 9 and whether the logs are even set up to be able to
10 Q All right, Mr. Smith. I'm going to 10 track changes made to the database.
11 interrupt you there and I'm going to show you a 11 But you could do anything from changing
12 document that's going to come up on your screen, and 12 data within the database to changing data
13 it has been marked as Respondents' Exhibit 23. And 13 relationships. So that for example, instead of
14 I'll ask if you recognize that document. 14 drawing from one particular file or results file or
15 A Yes, sir, I do. 15 from a different table within the database, you
16 Q And what is it? 16 could change that so that the source of the data in
17 A It's a notice from CISA regarding Iranian 17 the database changed without the knowledge of the
18 advanced persistent threat or APTs that penetrated 18 administrators or operators of the data of the
19 election infrastructure in states and obtained 19 system.
20 confidential personal information of voters that was 20 So in other words, the users would not
21 stored in those databases. 21 even be aware that their data source had changed.
22 Q I want to direct your attention to 22 Like if on your smartphone you had a weather

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1 application and somebody changed the source of the 1 with this witness on direct.
2 weather application to something other than NOAA or 2 PANEL CHAIR HIRSH: Why don't we go to
3 National Weather Service and all of a sudden it 3 12:30, then recess, then pick it up afterwards. We
4 started feeding you bad information and then you 4 were thinking that might assist with your other
5 were making bad decisions based on that bad 5 witness's timing by pushing back the lunch a little
6 information. 6 bit.
7 And the interface would like look the same 7 MR. MAC DOUGALD: Thank you. I appreciate
8 so you would never know that was being done. You 8 that.
9 can always use SQL injection to compromise the host 9 BY MR. MAC DOUGALD:
10 system itself and do anything from installing 10 Q Okay. Mr. Smith.
11 malicious or unauthorized code to opening up 11 A Yes, sir.
12 telecommunications interfaces, or you could progress 12 Q Do you have an opinion on whether election
13 to installing unauthorized credentials, in other 13 infrastructure would be an attractive target for our
14 words, you could set up whole users that weren't 14 sophisticated foreign adversaries?
15 visible or available or obvious to the normal users 15 A I do.
16 of the system. 16 Q What is that opinion?
17 Q So a successful SQL injection in a voter 17 A It would be the most important and
18 registration database, would that be able to create 18 critical target of all. And the reason is because
19 fictitious voter registrations? 19 you could directly affect U.S. national security
20 A Yes. In that kind of event, unless you 20 policy by affecting policy makers themselves.
21 have comprehensive, adequate logging and review and 21 So if you had the opportunity, you know,
22 auditing of that logging, the appropriate approach 22 instead of trying to attack thousands of weapons

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1 would be to assume that the entire database was 1 systems or hundreds of weapons system designs or
2 corrupted and to validate every single record in it 2 having to meet, you know, a U.S. defense leviathan
3 before using it for any purpose. Because you should 3 on the field of battle, if you had the opportunity
4 have no confidence in the database without -- 4 to exert your will on a foreign nation state by
5 without taking those steps. 5 affecting who was in office or what those
6 Q All right. Now, was it the position of 6 officeholders were subject to because of for example
7 CISA that the SQL penetration that that notice 7 the state of Congress, you would do that.
8 related to was successful or unsuccessful, do you 8 And I had this discussion with a friend of
9 remember? 9 mine, fellow retired colonel who is a retired
10 A I'm sorry, could you rephrase that? 10 computer science and mathematician, he and I came to
11 Q Did CISA claim the attempted SQL injection 11 the same perspective or position separately, and
12 was successful or unsuccessful? 12 there would be no more significant or attractive
13 A Successful. 13 target for a foreign nation than to disrupt our
14 MR. MAC DOUGALD: Mr. Chairman Hirsh, can 14 election systems.
15 you give me an idea of when you'd like to break for 15 Q And I believe you alluded somewhat
16 lunch? 16 cryptically to your work in the military on projects
17 PANEL CHAIR HIRSH: I was thinking around 17 of a similar nature directed to foreign countries.
18 12:15. How long do you expect the direct to go? 18 Did I hear that right?
19 MR. MAC DOUGALD: Well, it's 12:14 now. 19 A Yes, sir. Although -- yes. The United
20 PANEL CHAIR HIRSH: I'm sorry. 12:30. 20 States has made multiple attempts to affect foreign
21 How long were you expecting? 21 elections, and I was part of some of those efforts.
22 MR. MAC DOUGALD: We would go past that 22 Q All right, sir.

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1 The -- does -- should the public rely on 1 to show that to you.
2 statements by public officials that their systems 2 Do you have Disciplinary Counsel Exhibit
3 are certified as safe under the voluntary voting 3 36 on your screen, sir?
4 system guidelines of any addition? 4 A I do. I can see the front page and I'm
5 MR. HORRELL: I'm going to object to that 5 familiar with that statement.
6 question, Mr. Chair. 6 Q Tell the committee what this statement is.
7 MR. MAC DOUGALD: What's the objection? 7 A So it's on my phone, I'll have to screen
8 MR. HORRELL: I don't know what foundation 8 in. It's on the 12th of November, it's a joint
9 he has for what the general public should or should 9 statement from the EI ISAC election structure
10 not do. 10 sharing information that the Government Coordinating
11 MR. MAC DOUGALD: I'll rephrase the 11 Council or representatives to that council from
12 question. 12 government institutions like Bob Kolasky, who was
13 PANEL CHAIR HIRSH: Yeah, it's inartful. 13 Chris Krebs's deputy, or members -- there were
14 MR. MAC DOUGALD: It was inartful and I 14 members of the EAC commissioners on there as well,
15 apologize to the whole world for that. I'll try and 15 Government Coordinating Council, and then the Sector
16 rephrase and ask a better question. 16 Coordinating Council are representatives of
17 BY MR. MAC DOUGALD: 17 organizations from within the sector.
18 Q Mr. Smith, do you put any stock in the 18 So for example, you had I think Chris
19 security certifications that are attached to the 19 Wlaschin, who was former Navy cyber policy official,
20 Dominion Voting Systems machines and software in 20 who then became ES&S's director of I think security
21 Georgia in 2020? 21 strategy.
22 A No, sir. So in addition to statements 22 You had Ericka Haas from the Electronic

Page 1147 Page 1149

1 like the director of testing, the laboratory 1 Registration Information Center, and you've got
2 director for Pro V&V, which is one of the two 2 individuals like I think it was Gloria Eno from
3 certified voting system testing labs, or I'm sorry, 3 Washington state. I'll have to zoom in if you want
4 two accredited voting system testing labs, he made 4 me to give you more detail.
5 the statement before Judge Totenberg that he had no 5 But basically, these are members of the
6 particular cybersecurity expertise or background. 6 government Sector Coordinating Council who made a
7 That is not someone who has any chance of adequately 7 statement following the 2020 election that echoed
8 testing or anticipating threats to critical 8 the statements of Chris Krebs publicly and Chad Wolf
9 infrastructure, including voting systems, given this 9 publicly that the 2020 election was the most secure
10 threat environment. 10 in U.S. history.
11 From what I've seen, there is no 11 Q Do you agree with that?
12 credibility whatsoever to any statement about the 12 A No.
13 secure nature or value of those certifications or 13 Q Why not?
14 the certification testing. They're wholly 14 A Well, in the first place, when Chad Wolf
15 inadequate to the threat arrayed against U.S. 15 made that statement on the 3rd of November, when
16 critical infrastructure, including election voting 16 Chris Krebs made his statement, I believe his was
17 systems. 17 first made the next day, when the GCC and SCC
18 Q All right, sir. Are you familiar with 18 members made their joint statement, they would have
19 statements made by U.S. government officials that 19 had no data that could have possibly validated that
20 the 2020 election was the safest ever? 20 assertion.
21 A I am. 21 So in order for an election to be secure,
22 Q All right. Give me just a second, I want 22 the vote systems themselves would have had to be

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1 secure. The voting systems aren't supposed to be in 1 technology and national security. These are --
2 any case connected to any external network of any 2 these are organizations scanning every IP address in
3 kind, much less to the Internet. 3 the world every day looking for vulnerabilities.
4 And election officials are not gathering 4 Q All right, sir.
5 data from those systems and providing it anywhere. 5 Were there any -- was there any awareness
6 So at the very least, you would have to admit that 6 of the -- of this general category of problems for
7 it was an evidence and basis-free statement. In 7 election systems before the 2020 election?
8 other words, they have no evidence about the 8 A Awareness by whom, sir?
9 security of those systems. That's the first place. 9 Q Well, by the cybersecurity or election
10 In the second place, once you understand 10 cybersecurity community.
11 the standards for the voting systems, in other 11 A Well, yes, sir.
12 words, so again, no voting system in the United 12 So this, the National Institute of
13 States has been certified by the Election Assistance 13 Standards and Technology is by its statute in Title
14 Commission to a standard newer than 2005, before the 14 52, they are the statutory advisor, the technical
15 first iPhone ever existed, when threats were much 15 advisor to the Technical Guidelines Development
16 less pervasive, when they had not propagated a 16 Committee, which recommends the T -- the TGDC
17 significant view that the critical threats to our -- 17 recommends requirements and standards for voluntary
18 the publicly acknowledged critical threats to 18 voting system guidelines to the Election Assistance
19 software and hardware are now more than 10 times 19 Commission.
20 what the total threats known were to our electronic 20 So that Technical Guidelines Development
21 and computerized systems in 2005. 21 Committee is always chaired by NIST, by a
22 It's not even comparable. It's an order 22 representative from NIST.

Page 1151 Page 1153

1 of magnitude greater. So without data, without 1 And NIST had multiple publications where
2 persistent monitoring, like I said, I'm well aware 2 they published reports identifying supply chain
3 of what it takes to defend a system, even one that 3 vulnerabilities, cyber vulnerabilities in supply
4 has been properly defended and architected as secure 4 chain, as being critical to and risks to critical
5 from the beginning, you know, it takes an active 5 infrastructure.
6 defense, none of that is happening for our voting 6 So it's inconceivable that NIST, the
7 systems. 7 advisor to the EAC, was not aware of it. They
8 So they have inadequate standards, 8 published those reports to other government
9 inadequate testing, they're not defended in 9 institutions. And then when you looked at the, for
10 operation, they're not secured in operation, they're 10 example, 2000 -- let me think about this, 2020, I
11 procured with no supply chain security, I don't have 11 think it was March or April of 2020 when the TGDC
12 to go look at them to know that they are likely 12 recommended draft requirements for what then became
13 compromised because the threat environment is so 13 the 2021 version, version 2 of the voluntary voting
14 severe that you have to assume and the Department of 14 system guidelines, they explicitly incorporated for
15 Defense does assume that any system that is left 15 the first time a description of a requirement for
16 unattended, any component left unattended, any 16 supply chain security measures within voting system
17 component or system with parts and materials that 17 procurement and development.
18 are procured through an unsecured supply chain will 18 Q All right, sir.
19 be compromised. 19 Are you aware of any consideration given
20 You know, the foreign nation states have 20 by the State of Texas to the Dominion election and
21 hundreds and hundreds of thousands of people 21 equipment system?
22 committed to this campaign against U.S. and western 22 A Yes --

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1 MR. HORRELL: Mr. Chair, I'm sorry. 1 Texas voting system examiners examined
2 THE WITNESS: In 2019 -- once upon a 2 Dominion Voting Systems in 2019, and I don't
3 time -- 3 remember their exact language, but I remember the
4 MR. MAC DOUGALD: Hold on. Hold on, 4 gist. They identified vulnerabilities to compromise
5 Mr. Smith. 5 manipulation of the Dominion Democracy Suite voting
6 PANEL CHAIR HIRSH: Hold on, Mr. Smith. 6 system and recommended against certification and
7 Mr. Smith. Mr. Smith -- Mr. Smith, hold on a 7 adoption of those voting systems in Texas for that
8 second, there is an objection, I need to rule on it. 8 reason.
9 MR. HORRELL: I'm going to object as to 9 Q All right, sir. I'm going to show you on
10 relevance. If we're talking about Texas, I don't 10 the screen a document marked Respondents' Exhibit
11 know what has to do with Georgia. 11 208, R-208.
12 PANEL CHAIR HIRSH: Well, okay. What I 12 Do you recognize that -- are you able to
13 understand the thrust of his testimony is, it's a 13 read -- see the documents where you are?
14 line of questioning designed to say whether 14 A Yes, sir, I am.
15 something was known or available at the time, okay. 15 Q Okay.
16 The fact that something might be known or available 16 A Apologize for sticking my hand in the
17 in Texas doesn't mean it's not known or available, 17 camera, but that's how I have to get to the phone.
18 and that's why I understand what it's offered for. 18 Q So are you -- do you recognize this
19 So I'll overrule the objection. 19 document?
20 But you might want to give him the 20 A Yes, sir.
21 question again and start from the top because of us 21 Q And tell us what it is.
22 interrupting. 22 A So there are multiple members of the

Page 1155 Page 1157

1 BY MR. MAC DOUGALD: 1 examination -- the examination panel that examined
2 Q So we had some cross-talk there, 2 the voting system independently for the secretary of
3 Mr. Smith. 3 state of Texas. They are actually -- so this is
4 A Yes, sir. 4 sort of a summary recommendation against adoption of
5 Q So my question, you were in the middle of 5 the Democracy Suite voting system based on those
6 answering it and I ask you to start it over. Were 6 examiners' reports.
7 you aware that the State of Texas took a look at 7 There are other report memoranda that are
8 whether they wanted to use the Dominion system? 8 from the technical examiners. So the technical
9 A Yes, sir. 9 examiners explain the specific technical reasons and
10 What I was trying to explain is that once 10 that staff attorney made a summary recommending
11 upon a time, almost all states had their own 11 against certification of voting systems within Texas
12 independent voting system examiners. But it became 12 for the reasons that were identified in the
13 sort of unsustainable for them once voting systems 13 technical examiners' reports.
14 became more computerized and after an EAC stood up 14 Q In the end did Texas adopt the Dominion
15 their program of accrediting voting system testing 15 system?
16 labs in providing for certification of voting 16 A They did not, on the basis of that
17 systems. 17 recommendation from the examiners, because the
18 Texas, Pennsylvania and California are 18 technical examiners stated their opinion after
19 among states that still retain independent voting 19 examining the systems, that the systems were
20 system examiners either under contract or as parts 20 vulnerable to manipulation and corruption.
21 of panels or commissions supervised by or 21 Q All right, sir. Now I would like to show
22 administered bisects of state. 22 you -- do you see Exhibit R-219 on your screen?

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1 A I do. 1 the subject line is "ballot-marking devices are not
2 Q All right. And can you read the names on 2 secure technology."
3 the page there up at the top of this document? 3 Are you familiar with that?
4 A Yes, sir. 4 A I'm familiar with the conclusions. I
5 Q And do you recognize any of those names, 5 don't believe I've read the entire letter.
6 starting with the first one? 6 Q Okay. And so this -- all right.
7 A I recognize Philip Stark's name. 7 MR. MAC DOUGALD: So Mr. Chairman, I would
8 Q Tell the committee who Philip Stark is. 8 like to request that we go ahead and break for lunch
9 A Dr. Stark is a professor at UC Berkeley of 9 at this point, and then pick back up with the
10 statistics. He's done a lot of work into 10 witness after lunch.
11 statistical analysis supporting data analysis for 11 PANEL CHAIR HIRSH: I'm fine with that,
12 everything from astrophysics to election systems. 12 just one question. I think there are now three
13 He's considered the father or inventor -- 13 exhibits that you've used, but haven't offered. Are
14 it's really -- I don't mean to slight him, he's a 14 you planning to offer them?
15 very bright man in principal. He's considered the 15 MR. MAC DOUGALD: Yeah, I will tender
16 father of risk-limiting audits, so he took an 16 those at this point. I can't remember what they are
17 industrial sampling technique that was developed for 17 because I've been talking instead of making notes.
18 the quality control as part of quality control plan 18 PANEL CHAIR HIRSH: All right. I think we
19 or program for munitions manufacturing, in the 19 have Disciplinary Counsel Exhibit 36.
20 United States during World War II, because they were 20 MR. MAC DOUGALD: I thought that was
21 manufacturing so many munitions at once they could 21 already in.
22 not afford to test the way they had been sample 22 MR. HORRELL: It is.

Page 1159 Page 1161

1 testing before, so they developed a statistical 1 PANEL CHAIR HIRSH: That's right, that's
2 approach to sample testing, that used smaller 2 on that list, so that's admitted already.
3 amounts of test articles more efficiently, to draw 3 Then I know the last two, I just want to
4 inferences with a certain level of statistical 4 make sure that there isn't --
5 confidence about the quality of the munitions and 5 MR. FOX: 208, I believe, and 219.
6 their likelihood to fail in operation. 6 PANEL CHAIR HIRSH: There's R-023, that's
7 Professor Stark took that approach and 7 the SQL injections document.
8 adopted it to statistical sampling of tallies from 8 MR. MAC DOUGALD: Yes. And then there was
9 electronic voting systems in order to determine with 9 the CISA statement. Well, that was D-036. I think
10 a certain level of statistical confidence, and 10 that's the ones that we've showed him so far.
11 efficiency, whether or not the machine tallies were 11 PANEL CHAIR HIRSH: R-023, R-208 and R-219
12 accurate or whether they had machine errors embedded 12 are the ones that I have.
13 in them. 13 MR. MAC DOUGALD: Admitted or tendered.
14 Q All right, sir. And I want to end on this 14 Any objection?
15 document and then we'll talk about the break, lunch 15 PANEL CHAIR HIRSH: Are there others?
16 break. 16 Also 561. 559 was admitted I'm pretty
17 So this -- have you seen this document 17 sure. Yes, we did admit 559.
18 before, a letter to the Georgia -- 18 Here are the numbers I have, at least.
19 A Is this a letter to verify voting 19 561, that's Respondent's of course.
20 resigning? 20 R-023.
21 Q No, sir, this is not that letter. This is 21 You told me Disciplinary Counsel Exhibit
22 a letter to certain Georgia elected officials, and 22 036 is admitted already.

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1 R-208 and R-219. Are you offering all 1 AFTERNOON SESSION (1:40 p.m.)
2 four of those? 2 Whereupon,
3 MR. MAC DOUGALD: I am. 3 SHAWN A. SMITH
4 MR. HORRELL: No objection. 4 resumed the stand and, having been previously duly
5 PANEL CHAIR HIRSH: No objection. Okay, 5 sworn, was examined and testified further as
6 all four of those will be admitted. 6 follows:
7 (Exhibits R-561, R-023, R-208 and R-219 7 PANEL CHAIR HIRSH: Are we ready to get
8 received.) 8 started?
9 PANEL CHAIR HIRSH: Why don't we break 9 MR. MAC DOUGALD: I believe we are. We
10 until 1:40 for lunch. About how much longer do you 10 have a witness in the waiting room.
11 think you're going to have? 11 PANEL CHAIR HIRSH: Ms. Borrazas -- great.
12 MR. MAC DOUGALD: With Mr. Smith? 12 Can we let Mr. Smith back in, please.
13 PANEL CHAIR HIRSH: Yeah. 13 MS. BORRAZAS: Yes.
14 MR. MAC DOUGALD: A little bit hard to 14 PANEL CHAIR HIRSH: Thank you.
15 say, but I'm going to estimate 15 to 30 minutes on 15 Welcome back, Mr. Smith. As I'm sure you
16 direct. 16 know you remain under oath.
17 PANEL CHAIR HIRSH: Then we're deferring 17 Mr. MacDougald, please continue.
18 the cross to Wednesday. 18 MR. MAC DOUGALD: Thank you very much,
19 MR. MAC DOUGALD: Correct. 19 Mr. Chairman.
20 PANEL CHAIR HIRSH: Thank you very much. 20 DIRECT EXAMINATION (Continued)
21 MR. MAC DOUGALD: All right, Mr. Chairman. 21 BY MR. MAC DOUGALD:
22 Appreciate it. 22 Q Mr. Smith, when we left off, we were

Page 1163 Page 1165

1 (Whereupon, at 12:36 p.m., the hearing was 1 talking about a letter from Phil Stark to officials
2 recessed, to be reconvened at 1:40 p.m. this same 2 in Georgia.
3 day.) 3 Do you recall that?
4 4 A Yes, sir.
5 5 Q And so now I would like to show you
6 6 another document, which I believe is
7 7 Respondent's 047.
8 8 Do you recognize that document?
9 9 A No, I don't believe I've read it. I'm
10 10 aware that the safe commission made recommendations,
11 11 but I've only read Professor Wenke Lee's comments to
12 12 it.
13 13 MR. FOX: Excuse me. Oh, I'm sorry, I was
14 14 looking at the wrong one. I thought we had the
15 15 wrong number. It's my fault.
16 16 MR. MAC DOUGALD: 47.
17 17 MR. FOX: No, no, I'm looking at my 47, my
18 18 apologies.
19 19 MR. MAC DOUGALD: No problem.
20 20 BY MR. MAC DOUGALD:
21 21 Q Since you don't recognize that document,
22 22 I'm going to take that off the screen.

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1 All right, sir. Based on the -- looking 1 The first was Sunspot and the second was
2 back at the circumstances that were on the table 2 Supernova. Sunspot you can think of as sort of the
3 both before and immediately after the November 2020 3 vessel or the path to allow embedding of the advance
4 presidential election in the November/December time 4 persistent threat team within that targeted
5 frame, do you have an opinion on whether further 5 compromised systems.
6 investigation of the election was warranted at that 6 Supernova was an exploitation of that
7 time? 7 access.
8 A I do. Further investigation was 8 And it illustrates -- so it was one of the
9 warranted. Any time you have irregularities -- you 9 most devastating supply chain compromises in
10 know, most of the processes that are employed by 10 history, not just in the U.S., and it compromised
11 election officials are what from an accounting sense 11 server infrastructure in almost every major federal
12 would be considered internal controls. 12 organization, agency, department and branch in the
13 When you have a failure, just like for 13 United States, and then many state and local
14 accounting for a large firm that's publicly traded 14 governments.
15 where you have a requirement for auditing, any time 15 They had at large networks in order to be
16 you have a failure of an internal control, the 16 used in Orion. But as I recall, it was Department
17 automatic and the only acceptable response is to 17 of Justice, Department of Homeland Security,
18 bring in outside auditors, and those auditors should 18 Department of Treasury, Agriculture, Interior,
19 have forensic or, you know, comprehensive access to 19 Defense, including within the Department of Homeland
20 all records necessary to assess, you know, whatever 20 Security the server infrastructure of CISA,
21 the phenomena are, whether it's finances or whether 21 Cybersecurity and Infrastructure Security Agency.
22 it's security and integrity of election results and 22 So in other words, the very agency

Page 1167 Page 1169

1 processes in this case. 1 responsible to secure election infrastructure was
2 We saw numerous irregularities that 2 itself compromised in 2020 by a supply chain
3 revealed failures of internal controls, either their 3 compromise and unable to detect that compromise
4 inadequacy or failure to follow them or their, you 4 themselves.
5 know, their violation. And that should respond -- 5 So all the measures they had, including
6 that should result in immediate external independent 6 intrusion detection and prevention systems, active
7 investigation. 7 monitoring, trade -- skilled cyber personnel, all of
8 Q All right, sir. Now, have you ever heard 8 their defensive measures were for nothing. They
9 of something that's referred to as the SolarWinds 9 never detected their own compromise at their own
10 exploit? 10 servers, even while they were making public
11 A I have. 11 statements about the security of election
12 Q And does that story illustrate any of the 12 infrastructure.
13 points you've been making to us today? 13 And the way they found out about the
14 A It does. So it's a supply -- 14 SolarWinds Supernova, SolarWinds Sunspot, was
15 SolarWinds -- so it's referred to as SolarWinds. 15 because Mandia and FireEye teams detected it on
16 SolarWinds is the company, the product was Orion, 16 their own architecture, and then informed the
17 it's a network management software suite that 17 federal government through CISA of the indicators of
18 includes some hardware components. The compromises 18 compromise to go look for. Then CISA published
19 that are involved in what people think of as the 19 notification telling other federal and governmental
20 SolarWinds compromise, or hack, the sort of 20 agencies what indicators of compromise to look for,
21 colloquial term, were actually two different 21 and if they found those indicators of compromise,
22 adversary tactics or two different compromises. 22 that the first thing you should do would be to

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1 isolate your network, and then if you were capable, 1 connections and network connections. They're more
2 to create images of your network storage devices, so 2 sophisticated than computers that were flown to get
3 that you would have a record that you could go back 3 the Apollo mission to the moon.
4 and look at. 4 Q I'm going to put on the screen a document
5 Because a lot of times advance persistent 5 marked R-060 and ask you if you have seen it or
6 threat teams will either have automated or triggered 6 documents like it that provide a schematic of how
7 sort of track erasing capabilities in the tactics 7 the Internet of things fits into overall security
8 they employ to try to erase any record that they 8 analysis.
9 were there. 9 A I have seen -- I haven't seen this before.
10 So once they see someone is trying to reap 10 I've seen documents like it. I would say the
11 them out or find indicators, then they start erasing 11 diagram -- the first diagram is slightly in error
12 their tracks. 12 because it indicates all devices have to communicate
13 Q All right, sir. 13 to one another through the Internet, whereas what's
14 Now, what is the Internet of things? 14 actually true is a lot of the devices have low
15 A Internet of things refers to the 15 bandwidth and in some sense, whether it's deliberate
16 networking of smart or semismart devices. 16 or not, low probability of intercept and detect
17 So, you know, as opposed to what we once 17 protocols in use, like -- they're efficient from an
18 thought about, the Internet as being the computers 18 energy usage standpoint, they're not transmitting
19 and servers in various locations connected to each 19 constantly necessarily. And so they can connect
20 other, able to communicate, share data, access data, 20 directly from one device to another, like near field
21 with indices, and, you know, different search 21 communications between your smartphone and your
22 engines that would apply to them, Internet of things 22 smart watch, or between your smartphone and RFID

Page 1171 Page 1173

1 refers to devices that could be anything from, you 1 tag, like a radio frequency ID tag that identifies,
2 know, an infrared sensor that detects when a room is 2 you know, a key fob or like inventory tracking
3 occupied, to your refrigerator. It's typically a 3 devices.
4 bridge between computers and networks and the 4 So I have seen a great deal of
5 Internet and what in a commercial or industrial 5 information, including all levels of diagram from
6 facility would be considered industrial control 6 physical through security and conceptual layers, for
7 systems. 7 Internet-of-things-type devices, just not this one.
8 Q All right, sir. 8 Q All right, sir.
9 A But it could be even like a key fob from 9 Now I'm going to show you a document
10 Apple that lets you locate your keys because it 10 that's marked R-069, and this is a CBS article
11 transmits the position of the key fob when it's 11 entitled "On Your Side, Prevent hack attacks on your
12 pinged or interrogated by a signal. 12 'smart home' devices."
13 Q And does the Internet of things include 13 Whether you have seen this particular
14 such things as Wi-Fi-enabled thermostats? 14 document or not, is this a fair representation of
15 A Yes, absolutely. Although I would say the 15 popular press articles about the security risks of
16 thermostats, you know, like a Nest thermostat or 16 the Internet of things?
17 the -- what's the other, ecobee, there are a number 17 A May I just take a moment to take a look at
18 of commercially available, very popular -- those 18 it?
19 systems when you start taking them apart, they're 19 Q Sure.
20 small computers, they're not -- they're not, you 20 A Well, let's see. Yes, it's a fair
21 know, primitive, crude, low-processing devices. 21 representation of the risk. Although that up to
22 These things have memory and wireless 22 12,000 hacks per week, that's a lowball number. I

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1 don't know when this article is from, but that's a 1 And I've seen that in fact when I was at
2 very low number compared to what I would expect in 2 the headquarters at Hamburg Air Force Base, we had
3 the current threat environment. 3 an automation and HVAC, or heating, ventilation and
4 Q All right, sir. 4 air conditioning, system that the contractor had
5 And so is the idea -- well, let me ask you 5 installed, and that vendor had access to certain
6 this. 6 data off of that HVAC system. And we determined at
7 Could a hacker get to a computer network 7 some point that that was a vulnerability to have any
8 through a Wi-Fi-abled thermostat? 8 kind of data flowing out of that building to
9 A Yes, 100 percent. And the thermostat 9 unrestricted location or through, you know, public
10 might in fact be designed in part for that purpose. 10 Internet.
11 That's one of the types of supply chain compromises, 11 Typically, between defense installations,
12 to provide hidden or covert functionality in a 12 you want to have all your data trafficking through
13 device intended for one purpose. And we've seen 13 multiple tunnels, virtual private network tunnels,
14 that over, and over, and over again within critical 14 including encryption.
15 infrastructure. 15 And so Target did not apparently have that
16 It's why we no longer trust any integrated 16 in place. So the HVAC contractor for Target had
17 circuit that's produced on a nontrusted foundry. We 17 their system compromised, and that gave the hackers
18 have to have secure, trusted foundries where from 18 access to passwords which they then used to access
19 the moment that the system is designed until it is 19 Target's internal network. And that all happened
20 fabricated -- including control of the raw materials 20 because of that vulnerability of having the smart
21 that go into it, because we've seen adversaries do 21 automation devices accessible.
22 things like doping the substrates on integrated 22 But I've also seen U.S. Department of

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1 circuits, so that those circuits will respond to a 1 Defense red teams -- and read the reports about red
2 particular radio frequency stimulation to cause a 2 teams during demonstrations of vulnerability and
3 specific effect by producing a disruption of, you 3 capability go through industrial control systems
4 know, processing conduction or resistance on 4 both ashore, like in U.S. military facilities on
5 systems. 5 land, and industrial control systems aboard ships,
6 Q Are there any concrete examples that you 6 in fact from one ship to another ship, and then
7 know of of computer networks being hacked through an 7 penetrate the command and control computers aboard
8 HVAC or heating and air-conditioning control system? 8 the second ship, all done from a shore -- from an
9 A Yes. Although I cannot -- so there are 9 installation that was not directly connected to the
10 some that are within public knowledge. So Target 10 ships.
11 was the subject of a massive data breach 11 Q Okay. All right.
12 compromising its customer information, and that from 12 Are you aware of whether Colorado took any
13 what I've read from open source, I haven't seen any 13 action relative to the certification of some
14 of the sensitive or restricted, technical, 14 component of the Dominion system that was used in
15 assessments, but the open source explanation was 15 Georgia prior to the 2020 election?
16 that their HVAC contractor had access to Target's 16 A Can you be more specific about what action
17 internal supplier data systems because they needed 17 you mean? You mean did they evaluate the
18 it to relay monitoring information from their 18 vulnerabilities that were identified through for
19 industrial control systems that were sort of smart 19 example the Texas examinations?
20 automation for their facilities, like temperature 20 Q Well, I'm going to show you a document and
21 sensing, that kind of thing, efficiency, you know, 21 ask if it refreshes your recollection, okay?
22 performance management effectively. 22 A Perfect.

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1 Q And this is a document marked Exhibit 1 And the problem with that is first that
2 R-166. Take a look at that, and tell me if that 2 the bar code could completely not match the human
3 helps you. 3 readable text and the human would have no idea.
4 A Yes, I am familiar with that. 4 In other words a voter would not be able
5 Q And so the Colorado secretary of state 5 to verify that what the machine was going to scan
6 elected to get rid of the QR codes from the ballots? 6 and interpret as their vote choices was in fact what
7 A Yes, sir. So Colorado -- so Colorado uses 7 they had inputted and verified.
8 a different version than Georgia does of Democracy 8 And so that was the -- and that was, I
9 Suite. I think in this time I'd have to look at the 9 think, well known before 5.110 -- before 5.11
10 exact date on the memo, or this -- okay. 2019. 10 Colorado was certified by the Colorado secretary of
11 So at this time Colorado was using two 11 state. But because the public became aware and
12 different voting systems, but in 61 counties -- in 12 there was, I would say, some outcry from members of
13 three counties it was using -- or in two counties it 13 the public as well as inputs from a number of voting
14 was using Clear Ballot voting systems, but in the 14 system activists, like Neal McBurnett and Harvie
15 other 62 counties, it was using some version of 15 Branscomb, in Colorado, then the secretary of state
16 Dominion Democracy Suite, version 5.11-CO. 16 was moving to change that in the next version of
17 5.11-CO used the same ImageCast X devices, 17 Dominion Democracy Suite that they were planning on
18 or systems, which are the touchscreen voter 18 certifying and fielding in Colorado, which was 5.13.
19 interfaces, mostly for accessibility is what they 19 Q All right, sir. And I just want to go
20 were intended for, that are used in the 5.5-B 20 back and touch a couple of bases that we -- that
21 system, and throughout Democracy Suite they are 21 were mentioned earlier but I didn't show you
22 using the same ImageCast X devices. 22 documents.

Page 1179 Page 1181

1 The difference was in Colorado the systems 1 A Yes, sir.
2 were used as ballot-marking devices instead of as 2 Q And now I just want to hit that.
3 direct recording electronic devices. So the 3 Are you able to read that?
4 ballot-marking devices are used to -- the voter 4 A Yes, sir.
5 inputs their votes and then a ballot is printed out. 5 Q And that is the 2017 designation of
6 The same thing could be done with any of the ICXs, 6 election infrastructure as critical infrastructure
7 you just have to attach critter to them. 7 by the director of Homeland Security?
8 And the ballots that were being printed 8 A Yes, sir.
9 from the ICX ballot-marking device in Colorado 9 Q All right.
10 reflected the voters' choices in clear text, in 10 MR. FOX: Do we have an exhibit number?
11 human-readable text, but they also had a bar code. 11 MR. MAC DOUGALD: Oh, I'm sorry. That's
12 And the optimal scanner tabulators, the ImageCast 12 Exhibit 071. Sorry about that. R-071.
13 centrals used by Colorado, although it could be the 13 BY MR. MAC DOUGALD:
14 ImageCast precincts at other locations as well, or 14 Q Now I'm going to show you Exhibit R-178.
15 the ICEs, ImageCast Evolutions, in some 15 And when you were talking about critical
16 jurisdictions, they were not scanning the human 16 infrastructure, you were rattling off some DHS
17 readable text except as an image. They weren't 17 terminology that maybe some folks didn't quite
18 scanning that text to determine the vote choices 18 catch, something subsector -- something or other.
19 that would be captured in a cast vote record to 19 Does Exhibit R-178 -- how does that relate
20 represent that ballot digitally. They were scanning 20 to this business about sectors and subsectors?
21 the bar code that the ImageCast X ballot-marking 21 A Well, so the election infrastructure was
22 device was printing on that ballot. 22 made critical infrastructure by that memo that you

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1 just showed me from DHS Secretary Johnson. And for 1 add something if I could to my prior answer.
2 each designation of a specific sector, or domain of 2 BY MR. MAC DOUGALD:
3 technology, as a critical infrastructure, it has to 3 Q Yes, of course.
4 be placed in a sector or subsector where there's an 4 A I thought it, but didn't say it, I got
5 office of primary responsibility. 5 distracted myself.
6 So this is I believe the election 6 But this is an area where knowing a little
7 infrastructure subsector plan for the National 7 bit is enough to sort of get you in trouble. So
8 Infrastructure Protection Plan of 2013, which was 8 removing the QR codes for the ballots does not
9 the last update prior to 2020 for protection of 9 actually prevent the scanner, the optical scanner,
10 critical infrastructure. 10 from scanning a ballot for a QR code.
11 So critical infrastructure are 11 In fact, you could have a QR code that is
12 infrastructure that is deemed by the federal 12 steganographically like covertly embedded as an
13 government to be critical to essential elements of 13 image, it could even be a single 8-bit word, and it
14 government, and continuity of government, and 14 would be almost impossible for a person to detect
15 societal operations, whether that's, you know, 15 without knowing where it look. They could just look
16 electricity and water utilities or -- 16 like punctuation marks or changes in serif fonts, of
17 MR. MAC DOUGALD: Okay. Your Honor, 17 text on the page, or tiny marks on the edges that
18 before I forget it, I would like to tender R-071. 18 didn't look right.
19 MR. HORRELL: No objection. 19 Once you have a QR code scanner operating
20 PANEL CHAIR HIRSH: R-071 will be 20 on the tabulator or scanner, it's going to keep
21 admitted. 21 scanning those ballots for QR codes. And there may
22 (Exhibit R-071 received.) 22 be a QR code on it that is not noticeable or

Page 1183 Page 1185

1 MR. MAC DOUGALD: R-166. 1 detectible, visible or apparent to the naked eye or
2 MR. HORRELL: No objection. 2 an imager.
3 PANEL CHAIR HIRSH: R-166 will be 3 So the point I'm trying to make is there's
4 admitted. 4 a lot of -- there's a lot of amateur hour,
5 (Exhibit R-166 received.) 5 unavoidable, from election officials, in their
6 MR. MAC DOUGALD: R-219, if we didn't 6 decisions about election systems and their
7 already cover that before lunch. 7 assumptions, and the public statements they make
8 MR. FOX: Those were admitted. 8 about them. They simply do not have the experience
9 MR. MAC DOUGALD: That was admitted, I 9 or skill set or capability or knowledge to
10 apologize. 10 understand the threats against those systems or,
11 PANEL CHAIR HIRSH: Yes, that was before 11 more importantly, to protect them.
12 lunch. 12 So that kind of a removing the QR codes
13 MR. MAC DOUGALD: Okay. And then did we 13 from the ballots and then pretending that that
14 already do R-178? 14 somehow removes that QR code scanning module from
15 PANEL CHAIR HIRSH: No, it was it was done 15 the voting system, or the risk that you could insert
16 separately. 16 a ballot, not only that would have a different
17 MR. MAC DOUGALD: I'll tender R-178. 17 election result, or different voting result than the
18 MR. HORRELL: No objection. 18 voter is seeing or expecting, but could in fact be
19 PANEL CHAIR HIRSH: Admitted. 19 providing instructions that would change the
20 (Exhibit R-178 received.) 20 configuration of the voting system.
21 MR. MAC DOUGALD: Thank you. 21 And in fact, in the manuals for the voting
22 THE WITNESS: Mr. MacDougald, I meant to 22 systems, they have, for example, start and stop

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1 batch sheets that when the scanners start -- when 1 (Exhibit R-089 received.)
2 the scanners scan those batch start and stop sheet 2 MR. MAC DOUGALD: Thank you, Mr. Chairman.
3 ballots, they change the configuration of the 3 BY MR. MAC DOUGALD:
4 scanner. We don't know what else is running on 4 Q Mr. Smith, now I'm showing you Exhibit
5 them, and this is part of the problem with the 5 R-095. Do you recognize this document?
6 proprietary codes. 6 A I believe I have seen this fact sheet
7 So I just want to add that caution that 7 before, but it's been a while.
8 people not think that removing the QR code from the 8 Q And this is the U.S. Election Assistance
9 ballot that you can recognize actually removes the 9 Commission's voting system testing and certification
10 QR code function from the voting system, any more 10 program?
11 than not allowing rank choice voting with your 11 A Yes, sir.
12 voting system stops the rank choice voting module on 12 Q And we talked about that before, correct,
13 that voting system that's been installed for years 13 the EAC certification and testing?
14 from operating. 14 A Yes, sir.
15 Q I'm going to show you a few more documents 15 Q And this is an example of the measures
16 that we've been discussing in general terms. This 16 being applied for election security that you feel
17 is Exhibit R-089. Do you recognize this document or 17 are inadequate?
18 this type of document from the government? 18 A Yes, sir. Well, this is a very high-level
19 A Yes, sir, I recognize that specific -- I 19 description of the functions of the EAC for voting
20 think I maybe have seen it as a Web page with links 20 system testing and accreditation under Title 52, the
21 to other resources. 21 changes that were made by the Help America Vote Act
22 Q Uh-huh. And is this, in your opinion, the 22 to give them that authority. So creating the EAC,

Page 1187 Page 1189

1 cybersecurity tool kit and resources to protect 1 and then designating them as the certification
2 elections put out by CISA, is that adequate to the 2 authority with the right to accredit voting system
3 task at hand? 3 testing labs.
4 A If the task at hand is to convince 4 There are other manuals under their
5 election officials and the public that they have 5 program that the EAC commissioners approved with
6 some reasonable basis for confidence in their 6 each successful version of the voluntary voting
7 systems, then yes. 7 system guidelines, like the VSTL, or Voting System
8 But if the objective and the need is to 8 Testing Lab, program manual, which describes a
9 secure the systems, then no, it's inadequate. It 9 process for gaining and maintaining accreditation by
10 just would provide a false sense of security. It's 10 the test labs, including I think it's NVLAP,
11 like having a -- getting under your desk for a 11 National Voluntary Laboratory Accreditation Program,
12 nuclear weapon. 12 administered under NIST.
13 Q All right. Some of us are old enough to 13 MR. MAC DOUGALD: Apologize, communicating
14 remember doing that. 14 with the next witness.
15 Now I'm showing you Exhibit -- let me 15 THE WITNESS: Yes, sir.
16 tender R-089, Mr. Chairman. 16 MR. MAC DOUGALD: All right, sir. I
17 MR. HORRELL: No objection. 17 tender R-095.
18 PANEL CHAIR HIRSH: 18 MR. HORRELL: No objection.
19 MR. MAC DOUGALD: Now I'm showing you a 19 PANEL CHAIR HIRSH: That's admitted.
20 document -- 20 (Exhibit R-095 received.)
21 PANEL CHAIR HIRSH: Hold on, hold on. 21 BY MR. MAC DOUGALD:
22 Okay. It's admitted. 22 Q Now I'm showing you Exhibit R-099. Have

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1 you seen this document or one like it before? 1 MR. HORRELL: No objection.
2 A Yes, sir. I recognize in general. I 2 PANEL CHAIR HIRSH: All right. It will be
3 wouldn't vouch for every single detail, but that was 3 admitted.
4 a Web page with links that I saw. 4 (Exhibit R-099 received.)
5 Q Okay. And this -- your opinion regarding 5 BY MR. MAC DOUGALD:
6 the sufficiency of this document is the same as the 6 Q All right. I'm going to show you a
7 others? 7 document marked Respondents' Exhibit R-101. And
8 A Yes, sir. It's just a -- there's a -- I'm 8 this appears to be a voter pamphlet.
9 not trying to be -- show contempt or be pejorative 9 Have you seen material like this before?
10 towards them, but it's like -- it's like the 10 A It's not showing on my screen, but I --
11 Dunning-Kruger effect, where, you know, I'm not -- I 11 Q Oh, I need to turn the sharing back on.
12 wouldn't consider myself a cyber professional. I've 12 A Yes, sir, I've seen similar. I don't know
13 worked with those people, they are extraordinarily 13 that I've seen this exact version, but EAC
14 capable, but I know a great deal about the threat 14 promulgates informational materials like this to
15 and about testing for that threat. And I understand 15 state election officials, and then frequently they
16 what it takes to secure a system, particularly a 16 and their subordinate level government within their
17 complex computer-based system, against that type of 17 state will disseminate materials similar to this
18 threat. 18 with the same messages.
19 None of these resources that CISA 19 So I have seen these. None of this looks
20 recommends or that the EAC recommends are even 20 like election security. It looks like a children's
21 remotely sufficient, and the evidence of that is 21 program.
22 even in their own systems, they could not protect 22 MR. MAC DOUGALD: I tender R-101.

Page 1191 Page 1193

1 them against a supply chain compromise, or detect 1 MR. HORRELL: No objection.
2 that supply chain compromise, for at least 10 2 PANEL CHAIR HIRSH: It will be admitted.
3 months. 3 (Exhibit R-101 received.)
4 And then when they recommended measures, 4 BY MR. MAC DOUGALD:
5 you know, in their notification to other federal 5 Q Now I'm going to show you some documents
6 government agencies, even the federal government 6 that we have discussed previously. Are you seeing
7 agencies, which spends just billions and billions 7 Exhibit R-221?
8 and billions of dollars on cybersecurity, they 8 A Yes.
9 didn't tell them how to fix their systems. They 9 Q And you had mentioned a 2015 edition of
10 told them how to get their systems off-line, because 10 the voluntary voting system guidelines?
11 most of them don't have the capability to, you know, 11 A Yes, sir.
12 protect or mitigate once a threat is inside their 12 Q And this is a press release announcing the
13 system. 13 2015 edition?
14 And none of the voting system operators in 14 A Yes, sir.
15 the form of election offices have that capability to 15 MR. MAC DOUGALD: I tender Exhibit R-221
16 detect or mitigate those threats. 16 into evidence.
17 So taking these measures is, you know, 17 MR. HORRELL: No objection.
18 again, it's like a Potemkin village, it's like a 18 PANEL CHAIR HIRSH: It will be admitted.
19 facade to give people a sense of confidence in 19 (Exhibit R-221 received.)
20 something they should have no confidence in. 20 BY MR. MAC DOUGALD:
21 MR. MAC DOUGALD: All right, sir. I 21 Q All right. Now I'm showing you Exhibit
22 tender Exhibit R-099. 22 R-222.

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1 A Yes, sir. 1 guidelines. Most voting systems in the United
2 Q And this is -- refers to the new voluntary 2 States that have been certified by the EAC have been
3 voting system guidelines 2.0, and the date is -- are 3 certified to this standard or an older standard, the
4 you able to see that? 4 2002 voting system standards from the FEC.
5 A Yes, sir, January of '21. 5 Q In the course of your work in this area,
6 Q February of '21. 6 elections and election equipment, you've studied
7 A I'm sorry, February of '21. 7 these voluntary voting system guidelines?
8 Q And I believe you made reference earlier 8 A I have.
9 to these standards being in draft in 2020? 9 Q And your opinion on the adequacy of these
10 A Yes, sir. 10 guidelines to protect elections against the threat
11 Q And was this the first set that referred 11 environment?
12 to supply chain threat? 12 A They are totally inadequate. First of
13 A In any -- in any sense whatsoever, yes. 13 all, the refusal, for example, of the Election
14 There was no mention in any prior voluntary voting 14 Assistance Commission to prohibit the use of
15 system guideline or in the 2002 voting system 15 wireless devices in voting systems, to prohibit any
16 standard of supply chain security or risk management 16 sort of ability from a hardware standpoint or
17 requirements. 17 external network connections outside the voting
18 Q All right, sir. 18 system suite or components being certified, reflects
19 A And in these guidelines it really didn't 19 what seems like industry capture, by the voting
20 provide standards or any enforcement mechanism. It 20 system and elections industry and the institutions
21 essentially required that there be paperwork from 21 associated with them.
22 the vendor asserting that they have a strategy and 22 But then, secondly, the specific

Page 1195 Page 1197

1 some approach to it. 1 requirements within the guidelines are so dated, so
2 But, again, completely and total -- that 2 far behind the kind of frontier of normal threats
3 in and of itself is completely inadequate, but it 3 that are being experienced even by, you know,
4 doesn't matter because there's no voting system in 4 personal computers and smartphones, there are so
5 the United States that has been certified or tested 5 many devices now that are network-connected and
6 for the EAC to any standard newer than 2005. So 6 -connectible that wireless environment, for example,
7 even if these standards were adequate, which they 7 both Wi-Fi and cellular and Bluetooth, and
8 are not, they still are not testing to them. 8 near-field, has advanced far beyond what the authors
9 Q All right. Now on the screen I have 9 and those involved in developing these 2005
10 Exhibit R-258. 10 guidelines anticipated, that it's night and day.
11 A Yes, sir, I'm familiar with that. 11 It's -- you know, there's -- and then the standards
12 Q And tell us what that is. 12 are written from a standpoint of compliance as
13 A That's the first of two volumes of the 13 opposed to -- you know, even where they have test
14 voluntary voting system guidelines. 2005 is version 14 requirements, the test requirements are suited to a
15 1.0, so this was the first federal voting system 15 laboratory environment, not to the way threats
16 standards issued by the Election Assistance 16 present themselves in the real world.
17 Commission after its establishment in 2002 by the 17 In the real world, nation-state
18 Help America Vote Act. 18 adversaries have extraordinarily complex threat
19 Q Was this -- as modified in 2015, was this 19 campaigns. You know, maybe they invent something
20 the reigning set of voluntary voting system 20 that look innocuous in a hardware device, and the
21 guidelines when the 2020 election was held? 21 sole purpose of that innocuous embed is to get you
22 A Yes, and it remains the reigning set of 22 to install a software update later on. And that

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1 software update is actually the carrier, or the 1 MR. HORRELL: 160.
2 vector, in which they will embed a compromise that 2 PANEL CHAIR HIRSH: Excuse me, I think you
3 then allows them to remotely, over a specific time, 3 mean 160; isn't that true?
4 activate your networking devices so that then they 4 MR. MAC DOUGALD: I stand corrected.
5 can get a foothold, which then allows them to 5 R-160, thank you.
6 establish a fraudulent credential, and then spread 6 MR. HORRELL: I don't have an objection.
7 throughout your system. 7 I think it's mislabeled on the exhibit list, though.
8 I think, for example, in the Target breach 8 MR. MAC DOUGALD: Well --
9 from their HVAC contractor, I think the advance 9 MR. HORRELL: I'm sorry. On the exhibit
10 persistent threat team required 10 or 11 sequential 10 list it's mislabeled. This is 160, but 160 on the
11 steps in order to get to the point where they could 11 list is something different.
12 access all of the Target customer data. 12 MR. MAC DOUGALD: Okay. This is how I got
13 MR. MAC DOUGALD: All right, sir. 13 confused. The file name -- the file name is 160,
14 Mr. Hirsh, I believe I tendered this one, 14 the exhibit label erroneously is R-160. So if I
15 101. That's admitted? 15 could, I'll just -- I'll tender that corrected at a
16 PANEL CHAIR HIRSH: Yeah. 101 has been 16 later time, if I could.
17 admitted. And 221 has been admitted, according to 17 PANEL CHAIR HIRSH: Okay. You're telling
18 my notes at least. But 222 and 258 have not. 18 me that this is supposed to be R-260, even though it
19 MR. MAC DOUGALD: All right. I tender 19 says R-160?
20 Respondents' Exhibit 222. 20 MR. MAC DOUGALD: That is what I'm telling
21 MR. CLARK: And 99 has not been admitted 21 you, right. I made a mistake. Or I'm responsible
22 either. 22 for the mistake.

Page 1199 Page 1201

1 PANEL CHAIR HIRSH: My notes say it was 1 PANEL CHAIR HIRSH: So what you want to do
2 admitted. 2 is hold this off, you want to just offer it on
3 MR. CLARK: Okay. Good. 3 Wednesday?
4 MR. MAC DOUGALD: I tender R-222. 4 MR. MAC DOUGALD: Yes, correct.
5 MR. HORRELL: No objection. 5 BY MR. MAC DOUGALD:
6 PANEL CHAIR HIRSH: 222 is admitted. 6 Q Mr. Smith, is there anything else that you
7 (Exhibit R-222 received.) 7 would like to offer by way of your opinion that you
8 MR. MAC DOUGALD: I tender R-258. 8 think might be helpful to the committee in
9 MR. HORRELL: No objection. 9 understanding the cyber threat environment for the
10 PANEL CHAIR HIRSH: All right. 258 is 10 2020 election on the Dominion system that was used
11 admitted. 11 in Georgia?
12 (Exhibit R-258 received.) 12 MR. HORRELL: Objection. He needs to ask
13 BY MR. MAC DOUGALD: 13 a more specific question.
14 Q And R-160. Can you see that? 14 PANEL CHAIR HIRSH: Yeah, I mean, it --
15 A Yes, sir. 15 I'll allow it. You know, rather than force him to
16 Q And that appears to be a press release for 16 get into depth that's more specific and then raise
17 the 2005 voluntary voting system guidelines? 17 the implication that he's leading. I assume there's
18 A Yes, sir. 18 something in mind, so --
19 MR. MAC DOUGALD: All right. I tender 19 BY MR. MAC DOUGALD:
20 R-260. 20 Q Mr. Smith?
21 MR. HORRELL: What number? 21 A Yes, sir.
22 MR. MAC DOUGALD: 260. 22 Q Anything else you'd like to add?

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1 A Could you repeat the question? 1 Then we put these systems that have never
2 Q Yeah. Is there anything else you would 2 been secured properly, and after they have been
3 like to add regarding the cybersecurity threat 3 acquired, from these foreign supply chains, cannot
4 environment for the election system in Georgia in 4 be secured properly, and we put them in the hands
5 2020? 5 of, you know, I think mostly well-meaning public
6 A Off the top of my head, I think I said it 6 servants who have no expertise, or knowledge, or
7 all. I mean, the threat to our critical 7 capability, to know if those systems have an
8 infrastructure -- of which, you know, the Department 8 embedded wireless transmitter or if they have been
9 of Homeland Security has designated election 9 compromised.
10 infrastructure as critical infrastructure, clearly 10 For example, the Dell motherboards have
11 it's critical to our national security, our way of 11 Thunderbolt ports, they could have a thunderspy
12 life, our form of government. 12 exploit that permanently alters the security of that
13 It's much more severe than the general 13 motherboard, and makes them forever accessible to
14 public or laymen understand. You have to have seen 14 bad actors.
15 something like I've seen, where our national 15 And the voting and election officials
16 security establishment, defense contractors, defense 16 would have no idea. They have no capability or
17 installations, national security organizations, 17 knowledge necessary. And even if they did, mostly
18 including intelligence community, have been 18 they don't have the authority, or access, to be able
19 penetrated so thoroughly to have data exfiltrated 19 to look at the systems to find those kinds of
20 and compromised, systems compromised, so 20 compromises and vulnerabilities. We've done them a
21 thoroughly -- I'm talking about petabytes of 21 tremendous disadvantage, but really the harm is done
22 information, probably trillions of dollars in 22 to the American public because we're telling them to

Page 1203 Page 1205

1 national treasury intellectual property compromised, 1 trust these systems. They're not trustworthy. And
2 all from organizations and with systems that they 2 the federal government elements of it at least have
3 believed they were adequately defending. 3 understood it.
4 And all of them with better defenses, more 4 I left active duty in 2017, and at that
5 comprehensive, more skilled, expert, higher-paid, 5 time, within the federal government, we understood
6 personnel, than we are using for any of our election 6 the threat, and that you could not just, you know,
7 systems. 7 try to configure your system and assume that it
8 We take these systems that we don't secure 8 would be safe. You had to actively defend it.
9 from inception because of the insecure, foreign 9 And it didn't matter how well you designed
10 mostly, supply chain, and we then don't test them 10 it. If you weren't actively defending it, you had
11 really at all, so we've got to understand when a 11 no chance of keeping it secure.
12 Voting System Testing Lab tests a voting system, 12 And even when you were actively defending
13 they're not testing the components that you're going 13 it like CISA's own servers, you might still not be
14 to use in your jurisdiction. They're testing an 14 able to keep it secure. And the ramifications, and
15 exemplar or a sample. 15 consequences, of that insecurity and vulnerability,
16 But the overwhelming majority of the 16 and the ignorance of it, are catastrophic.
17 equipment, the hardware and software that we use in 17 Those are the words of the federal
18 our elections, on these computerized electronic 18 government, those are NIST's words, those are
19 voting systems, has never been tested by anyone 19 intelligence community's words about the supply
20 other than the vendor, or through logic and accuracy 20 chain threat to our critical infrastructure. It's
21 tests, which are again wholly inadequate to detect 21 shocking to me that we would employ systems this
22 anything. 22 insecure, and then lie to the public about it.

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1 And I believe that's what happened in 1 said there was some period on January 3 where he was
2 Georgia. It certainly happened here in my state. 2 acting attorney general.
3 MR. MAC DOUGALD: Okay. Mr. Smith, thank 3 Is there evidence in the record of that?
4 you very much. 4 MR. MAC DOUGALD: It may not be in this
5 That's all the questions I have for you. 5 record right this minute, but I can tell you that
6 And we are going to resume with your 6 the January 6 committee collected call logs from the
7 cross-examination sometime Wednesday after lunch, 7 White House for January 3 that reflected that, and
8 our time, all right? 8 that's the basis of that.
9 THE WITNESS: Yes, sir. 9 Isn't that right?
10 MR. MAC DOUGALD: All right. Thank you 10 PANEL CHAIR HIRSH: That reflected that he
11 very much. 11 was assistant --
12 Your Honor, since they're not going to do 12 MR. MAC DOUGALD: Acting.
13 the cross now, may Mr. Smith be momentarily excused 13 PANEL CHAIR HIRSH: I'm sorry, actually
14 subject to recall? 14 attorney general.
15 PANEL CHAIR HIRSH: Yes. 15 MR. MAC DOUGALD: It said Acting Attorney
16 For the time you are excused, Mr. Smith. 16 General Jeff Clark, and listed the call.
17 Please do not talk about your testimony with other 17 And I think that's on your exhibit list,
18 witnesses in the case, and -- I guess the rule on 18 isn't it?
19 exclusion of witnesses still applies to him. 19 I can't remember what exhibit it is. Do
20 MR. MAC DOUGALD: He's an expert. 20 you remember?
21 PANEL CHAIR HIRSH: Oh, he's an expert, 21 MR. FOX: It's on our list.
22 right. Okay. 22 PANEL CHAIR HIRSH: Do we want to offer

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1 MR. MAC DOUGALD: Okay. All right. Thank 1 the exhibit for that purpose so it is in the record?
2 you, sir. 2 I'm in this awkward limbo of counsel makes a
3 THE WITNESS: Yes, sir. 3 statement and I'm not sure it's in the record. I
4 (Witness excused.) 4 could be wrong, it could be in the record. We don't
5 MR. MAC DOUGALD: Your Honor, my next 5 instantly internalize something.
6 witness is trying to find the door to the building. 6 MR. FOX: Disciplinary Counsel Exhibit 33,
7 So I know -- 7 which we have not moved in.
8 PANEL CHAIR HIRSH: Do you want to break 8 PANEL CHAIR HIRSH: 33?
9 for a minute and find your witness? 9 MR. FOX: Yes, 3-3.
10 MR. MAC DOUGALD: Yes, if you would. 10 MR. MAC DOUGALD: I'll tender it.
11 Thank you. 11 MR. FOX: No objection.
12 PANEL CHAIR HIRSH: Why don't we break and 12 PANEL CHAIR HIRSH: Let me just look at
13 resume at 10 of. 13 the exhibit so I know what you're tendering. All
14 Actually, one second before we do this, I 14 right. It will be admitted.
15 had a question for you that I wanted to raise, 15 (Disciplinary Counsel Exhibit 33
16 independent of the witnesses, but since we're 16 received.)
17 between two witnesses I wanted to raise it with you. 17 PANEL CHAIR HIRSH: Why don't we break
18 On Thursday, I believe it is, you had 18 until 2:50. 2:51 since I used your time. Okay.
19 asked a witness a question and then you asked a 19 Thank you.
20 question the premise of which was that Mr. Clark had 20 (Recess.)
21 not -- had never been acting attorney general, and 21 PANEL CHAIR HIRSH: Thank you very much,
22 then you stood up afterwards and corrected that and 22 Ms. Borrazas.

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1 Call your next witness. 1 A Sure. My 40-year career spans computer
2 MR. MAC DOUGALD: I call Garland Favorito 2 programming, systems analysis and design. It also
3 to the stand. 3 includes systems development and methodologies. And
4 PANEL CHAIR HIRSH: Mr. Favorito, I'm 4 this is where we tell and write procedures for large
5 Merrill Hirsh, the Chairman of the committee. Do 5 companies to tell them how to develop
6 you want to swear or affirm to the truth of your 6 mission-critical systems.
7 testimony? 7 So that would be what we call the full
8 THE WITNESS: I'm not sure of the 8 life cycle of systems development, that would
9 difference. 9 include analysis, design, testing, auditing,
10 PANEL CHAIR HIRSH: Swear is under God, 10 development, evaluation of alternatives and the
11 whereas affirm is under penalties of perjury. 11 complete full life cycle, including conversion.
12 THE WITNESS: I'm going to tell the truth, 12 So that's -- in addition to that, I had
13 so whichever you think. 13 worked in data administration for quite a few years
14 PANEL CHAIR HIRSH: Could you raise your 14 too as a data administrator. And then also did a
15 right hand. 15 lot of Web-type design. During the -- towards the
16 THE WITNESS: I can do both. 16 end of my -- the last 17 years, I worked primarily
17 Whereupon, 17 for a large-scale financial institution on the
18 GARLAND FAVORITO 18 online banking side.
19 was called as a witness and, having first been duly 19 So in -- that included both the
20 sworn, was examined and testified as follows: 20 residential and the small business and the corporate
21 PANEL CHAIR HIRSH: Could you state your 21 online banking.
22 full name for the record and spell it also, please. 22 As a part of that, my -- as you can

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1 THE WITNESS: Sure. It's Garland 1 imagine, identity management is critical there, so
2 Favorito, G-a-r-l-a-n-d, Favorito is 2 we helped -- I helped design and implement an
3 F-a-v-o-r-i-t-o. 3 identity management system, which is what you would
4 PANEL CHAIR HIRSH: Thank you very much, 4 probably refer to today as cybersecurity.
5 Mr. Favorito. 5 So our job is -- was -- is to ensure that
6 Please proceed, Mr. MacDougald. 6 no one can intrude from the Web and take over your
7 MR. MAC DOUGALD: Thank you, Mr. Chairman. 7 bank account and steal your money. So that was one
8 DIRECT EXAMINATION 8 of my primary focuses for the last 17 years of my
9 BY MR. MAC DOUGALD: 9 career before I retired.
10 Q Mr. Favorito, how are you currently 10 Q When did you retire?
11 employed, if you are? 11 A 2007.
12 A I'm a retired IT professional for -- my 12 Q All right, sir.
13 career, I've had about a 40-year career in different 13 I am going to --
14 types of informational technology. 14 A I'm sorry, excuse me, that was a mistake.
15 Q All right, sir. 15 2017.
16 What is your -- we'll come back to that in 16 Q '17.
17 just a second. What is your educational background? 17 A Time flies when you're --
18 A Educational background is certificate in 18 Q Now, I am going to show you on your
19 computer programming from Lear Siegler Institute. 19 monitor there, because we've got some IT technology
20 Q Walk us through your professional work 20 here as well, a document marked as Exhibit R-334.
21 history in the IT industry that you were just 21 Can you tell the committee what that is?
22 alluding to. 22 A Yes. That is my summary of experience and

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1 resume, which I alluded to in my testimony just a 1 affiliated with either of the major parties.
2 minute ago. 2 Q So you're neither a Democrat nor a
3 MR. MAC DOUGALD: All right, sir. 3 Republican?
4 I tender R-334. 4 A Correct, I'm not either one. I'm what we
5 MR. FOX: No objection. 5 call the Constitution Party.
6 PANEL CHAIR HIRSH: It will be admitted. 6 Q All right, sir.
7 (Exhibit R-334 received.) 7 Now, over the I guess 22 years since you
8 MR. MAC DOUGALD: Thank you. 8 started looking into election issues, election
9 BY MR. MAC DOUGALD: 9 integrity issues, about what percent of your time
10 Q Now, have you had any involvement in or 10 has been devoted to election integrity issues over
11 done any work in the field of elections and election 11 that period?
12 integrity? 12 A Well, for -- you know, up until 2017 I was
13 A Yes. So I started an interest in that 13 still working, so I would say, you know, 10 or 20
14 back in 2002. When Georgia implemented what we 14 percent.
15 considered to be the first statewide unverifiable 15 Since 2017, I've been full-time as a
16 voting system. And that was of grave concern to me 16 volunteer on election integrity issues and voting
17 as a computer professional. And at that point in 17 system technology issues, made presentations
18 time I began involved in the election integrity and 18 throughout the state, and on the security issues of
19 voting systems technology research, and carrying on 19 the systems and how to attempt to resolve them.
20 from there I've done quite a few papers and worked 20 Q Okay. All right. Mr. Favorito, I know
21 with various counties and secretary of states, 21 you from Atlanta, don't I?
22 office, on how they could better secure their 22 A Oh, absolutely.

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1 elections. And, you know, presented at several 1 Q Yeah. So hard for me to not call you
2 conferences and so on. 2 Garland, but I'm going to call you Mr. Favorito.
3 Q Are you a part of an organization that 3 A That's okay. I'll answer to either one.
4 works in this area? 4 Q I'm showing you a document marked Exhibit
5 A Yes. So back then, I cofounded VOTERGA, 5 R-333. Can you tell the committee what that is?
6 which stands for Voters Organized for Trusted 6 A Yes, that's a general summary of my --
7 Election Results in Georgia, the key word there 7 what appears to be my election integrity and voter
8 being "Trusted" because that was the issue and it 8 system technology expertise, and experience,
9 has been the issue in Georgia since 2002. 9 experience.
10 Q And so you started that back in 2002? 10 Q Now, you had mentioned earlier that you
11 A I actually started that in 2006. 11 talked to legislators and government officials to
12 Q But you've been working on it since 2002? 12 try to get them -- what are you doing when you're
13 A Well, I had originally -- the organization 13 talking to them? What are you trying to get done?
14 was founded to bring a lawsuit to remove the old 14 A We had a variety of legislative
15 electronic voting system in Georgia, and that was in 15 initiatives. One was simply to implement what we
16 2006. After we were unsuccessful in trying to 16 considered to be a verifiable voting system, which
17 appeal to the legislature and the various, you know, 17 is a voting system that's verifiable to the voter
18 executive branches of governments. 18 when you cast your ballot.
19 Q All right, sir. And is VOTERGA affiliated 19 The current system is not verifiable
20 with any political party? 20 because those are accumulated out of a QR code which
21 A No, we are a true nonpartisan 21 the voter cannot read. That's just one aspect,
22 organization. And I am also a nonpartisan, not 22 though.

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1 Some of the other things that we lobbied 1 conducted with watermark paper, visible watermark
2 for were to unseal ballots, make ballots public 2 paper, so that the elections officials can detect
3 record, so that you can verify the election results 3 it.
4 and you can detect counterfeit ballots. 4 We got some success in the voter roll area
5 Very few states actually have public 5 of making voter rolls, you know, cleaner, and
6 access to ballots. That was another big issue. 6 clarifying how you would challenge invalid voter
7 We lobbied for visible watermarks on 7 roll records. So those were some of the things.
8 paper, the ballot paper, so that you can ensure the 8 And there were a couple of more things.
9 elections officials can detect a ballot that is 9 We got better poll watcher protection and poll
10 counterfeit, and clearly -- right away. 10 worker protection and meaningful access for poll
11 We've advocated for better chain of 11 watchers, so that the election process would be more
12 custody procedures. We have advocated -- by chain 12 transparent.
13 of custody, I mean the ballots -- making sure that 13 One of the biggest issues we have in
14 you have the appropriate sign-off and sealing 14 elections nationwide is that they're not transparent
15 procedures as you're transferring ballots from place 15 to the voter, so that was a big issue. We had
16 to place. 16 probably one of our most successful lobbying efforts
17 We've advocated for improving the voter 17 just completed last week.
18 rolls. There are a lot of invalid voter roll 18 MR. MAC DOUGALD: All right.
19 entries that are on the records in most states now, 19 Mr. Chairman, I tender Exhibit R-333.
20 particularly in Georgia in most counties. 20 MR. FOX: No objection.
21 So those are some of the things that we've 21 PANEL CHAIR HIRSH: It will be admitted.
22 advocated for but probably not a complete list. 22 (Exhibit R-333 received.)

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1 Q So have you had any success in your 1 BY MR. MAC DOUGALD:
2 lobbying efforts? 2 Q Now, Garland, have you appeared before or
3 A In fact, we did. We -- I had a major 3 testified to any state legislative committees in
4 success just last week. We were able to get quite a 4 Georgia?
5 few of the things I just mentioned passed into law. 5 A Frequently, yes. I'm there -- we probably
6 The last legislative session passed on the unsealing 6 made a dozen visits in the last session. And that's
7 of ballots, in other words physical ballots will 7 really the key, is to work with the legislatures
8 become subject to what we call in Georgia open 8 ahead of time and testify for what you want in the
9 records request, what you would call here would be a 9 committee hearing. Because by the time a bill gets
10 Freedom of Information Act, but they will now be 10 to the floor, it's really too late to make much of
11 available to the public for their inspection or for 11 any major changes.
12 copying. 12 Typically, the bills are engrossed and you
13 And of course, the chain of custody 13 cannot amend them on the floor. So yes, lots of
14 remains with the elections director, and this is all 14 testimony there.
15 done at the requester's expense. 15 Q All right. And referring to your screen
16 We were successful in getting the ballot 16 and the highlighted text, tell the committee what
17 chain of custody implemented, improvements there for 17 that's about.
18 the sign-off and sealing procedures as counties are 18 A So in 2020 I testified before the Senate
19 transferring ballots from place to place. 19 judiciary subcommittee, that would have been on
20 We were successful in getting the security 20 December 30, I think. They had two hearings,
21 watermarked paper as of the next election, all the 21 December 3 -- I was scheduled to testify on December
22 Georgia elections will be used with watermark -- 22 3 but they bumped me to December 30. And I outlined

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1 some of the problems at that time that were of 1 experts have presented various issues involved with
2 concern, particularly -- 2 the ballot-marking devices.
3 Q In the -- 3 But I think this is maybe one of the first
4 A I'm sorry. 4 reports that has been done specifically about the
5 Q I interrupted you, please finish. 5 security threat of the ballot-marking device.
6 A Particularly, I think -- there was quite a 6 And then I think I presented this paper --
7 few things -- do you want me to go into some of 7 I did present this in California at the national
8 the -- 8 voting rights task force.
9 Q We'll come to them later. But you were 9 Q All right, sir. And what's the date on
10 addressing issues in the 2020 election? 10 this document?
11 A That's correct. 11 A This is September 30, 2019.
12 Q All right. And then the next item, this 12 MR. MAC DOUGALD: Your Honor, I tender
13 one here, that's testimony to another committee? 13 Exhibit R-336 into evidence.
14 A Correct. That's the House government 14 MR. FOX: I don't understand the
15 affairs committee. So the House government affairs 15 relevance. It's 2019.
16 committee is responsible for election bills in the 16 THE WITNESS: Well, this is the same
17 Georgia state government, and they had me testify 17 system. We vote on the ballot-marking device.
18 for them as well. 18 MR. MAC DOUGALD: I'll develop a little
19 I'm fairly well known in the state in 19 more on that.
20 regards to election integrity, so I was -- I 20 BY MR. MAC DOUGALD:
21 testified -- both the chairman of the House and the 21 Q Did you present this document to the
22 chairman of the judiciary subcommittee -- I'm sorry, 22 Georgia legislature?

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1 chairman of House committee and the chairman of the 1 A I can't say that I presented the document.
2 Senate judiciary committee were aware of my 2 I'm trying to recall if we presented -- many of our
3 expertise, and wanted me to testify. 3 documents we have hand-delivered to every
4 Q I'm going to show you a document that's 4 legislature -- I'm sorry, every legislator.
5 marked Exhibit R -- I can't see the exhibit label 5 This one we probably should have because
6 because -- 6 Georgia does vote on the ballot-marking devices.
7 A 336. 7 But I -- I can't testify for sure that this was
8 Q Thank you. 8 delivered to every legislator.
9 It was overlaid by the video. Exhibit 9 Q All right. And do you recollect when
10 R-336, and ask if you can identify that for the 10 Georgia acquired the current Dominion BMD system?
11 committee. 11 MR. FOX: Mr. Chairman, are we in voir
12 A Yes, that's a document I created to 12 dire still? We're offering evidence. I don't have
13 document the unresolved security threats with 13 any problem with evidence that relates to
14 ballot-marking devices. 14 credentials, but now we're offering evidence and
15 So a ballot-marking device is a 15 asking about testimony. I don't think we have
16 touchscreen in which you enter your selections for 16 qualified this witness yet.
17 your vote, and then typically they will print out a 17 MR. MAC DOUGALD: There's some fairness in
18 piece -- a ballot for -- or what is actually a 18 the objection.
19 selection summary, it's not really a true physical 19 PANEL CHAIR HIRSH: I believe that's a
20 ballot. 20 fair point.
21 And there are quite a few security issues 21 MR. MAC DOUGALD: Okay. So what I'm
22 with this type of system. Many of the security 22 trying to do is put this document on a timeline, as

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1 an expression of his expertise on the BMDs at that 1 qualifies you to write this report and give the
2 particular point in time, before the 2020 election. 2 recommendations that are contained in Exhibit R-338?
3 PANEL CHAIR HIRSH: Sorry about the 3 A I would think I would answer it the same
4 lighting. 4 thing, it would be the 40 years of information
5 MR. TURNER: I'll just switch controls 5 technology experience but probably equally as
6 back here. 6 important is working with the counties, secretary of
7 MR. MAC DOUGALD: I'll rephrase the 7 states and the technology for about 17 years.
8 question if that would be helpful. 8 So I think we -- I had a unique position
9 PANEL CHAIR HIRSH: All right. It seems 9 to author the document which I also was allowed to
10 to me for that purpose, you've established that he 10 present to the commission I think in December of
11 presented a paper to the national voting rights task 11 2019.
12 force, and that this is a paper he presented. I'm 12 Q All right, sir.
13 not sure whether -- to what extent it adds, to go 13 Since you got involved in election matters
14 beyond that, or whether that's necessary before 14 in 2002, have you been involved in any lawsuits over
15 Mr. Fox has an opportunity to voir dire. 15 election issues or election integrity?
16 You know, I don't know because I don't 16 A Yes. So I think I mentioned in 2006, one
17 know where you're going, but it seems like you've 17 of the purposes of forming the organization VOTERGA
18 already made the point that you wanted to make. 18 was to bring a lawsuit to the courts in regards to
19 MR. MAC DOUGALD: All right, sir. 19 an attempt to ban that old system back in 2002.
20 BY MR. MAC DOUGALD: 20 The reason that we believed that to be
21 Q Garland, what qualifies you to give the 21 incredibly important is because it was what we call
22 analysis or advice that you gave in this Exhibit 22 the direct recording electronic system. It's a

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1 R-336? 1 touch screen system, and then it basically records
2 A Bottom line is the 40 years of information 2 something that nobody knows, it has no paper trail
3 technology experience, the broad breadth of that, 3 whatsoever, and that presents a problem to the
4 coupled with at that time it was nearly 20 years 4 voter.
5 of -- I think maybe 17 years of the voting system 5 Because first of all, the voter can't
6 technology experience, as well as election integrity 6 verify --
7 experience. And that's why I wrote that report. 7 Q Let me stop you there for just a second.
8 Q All right, sir. Now I'm going to show you 8 A Sure.
9 a document marked Exhibit R-338. Do you recognize 9 Q Because we're sort of getting ahead of
10 this document? 10 ourselves.
11 A I do. This is the document that we wrote, 11 A Okay.
12 I guess I authored this document, as recommendations 12 Q Any other litigation that you've been
13 to the SAFE Commission, which the SAFE Commission 13 involved in on election-related matters?
14 was the commission that was responsible for making 14 A Yes. So in 2020, we filed a lawsuit
15 recommendations in regards to the new system that 15 because I was present when counterfeit ballots were
16 Georgia purchased in 2020. And we were -- I had 16 found in the Fulton County hand-count audit
17 written some recommendations that they needed to 17 conducted in November 14 and 15. And we filed an
18 consider before making a new purchase of a new 18 equal protection and due process lawsuit. Actually,
19 system, given that the old system had been so 19 I was lead plaintiff on that matter.
20 problematic. 20 Primarily because we wanted to see the
21 Q All right, sir. 21 ballots to ensure that the ballots were in fact
22 And same question as before. What 22 actually legitimate, or not, one or the other.

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1 So that was another lawsuit. There's been 1 processes and issues concerning the integrity of the
2 a couple more as well. 2 voter rolls?
3 Q All right, sir. 3 A Yes, I would say so.
4 And are you or anybody that you work with 4 Q Are you familiar with the impediments, if
5 involved in the -- a lawsuit we've heard mention of 5 any, to maintaining a clean voter roll?
6 a couple times called Curling versus Raffensperger? 6 A Yes, I would say so.
7 A Yes, so our cofounder, Ricardo Davis, and 7 Q And how did you become familiar with it?
8 I say cofounder of VOTERGA, was a plaintiff in that 8 A Well, a lot of our people, our supporters,
9 original matter as well. And he is still active, 9 work with the -- with in fact attempts -- various
10 and I am his adviser in that matter. And I was at 10 attempts in different counties to clean the voter
11 court every day for that case when it was heard in 11 rolls. And in cleaning the voter rolls, we have
12 January of this year. 12 come across a variety of problems which I'm aware
13 Q So that case was tried in January? 13 of. And we have, you know, brought those to light
14 A Well, it was actually tried for the second 14 both publicly with a press conference as well as at
15 time. Just to give you a little background, the 15 the legislature through testimony.
16 first time the judge did in fact find that the old 16 Q All right, sir.
17 system was constitutionally deficient, and banned 17 Are you familiar with election
18 that old system from future use for federal 18 administration in Georgia?
19 elections. So that was basically the same argument 19 A I'm familiar with election administration
20 that we had made in 2006, which we were rejected by 20 in Georgia. I would say that my expertise is more
21 the Georgia Supreme Court. The U.S. District Court 21 towards voting system technology and the -- as
22 actually upheld what we had claimed earlier in 22 versus the actual administration.

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1 federal court and banned the old system. 1 But I have worked with the election
2 And then the petitioners, the Curling 2 administrators, the county election boards, through
3 plaintiffs and the coalition plaintiffs, there's two 3 the state, throughout the state really, and as well
4 sets of plaintiffs, then filed a new suit to ban the 4 as the county commissioners in some cases. So I do
5 new system that Georgia got because it was equally 5 have a pretty good familiarity with it.
6 unverifiable as the old system. 6 Q And it may sound like a dumb question, but
7 And subsequent to that, Ricardo Davis 7 how are you familiar with election administration in
8 became his own separate plaintiff. So in that 8 Georgia?
9 matter there's three separate sets of plaintiffs 9 A Well, pretty much what I just said. In
10 suing the secretary of state and the state election 10 working with the various counties, and the election
11 board as state defendants. 11 administrators, we worked with the election board
12 Q All right, sir. 12 members. Quite a few of our supporters are now
13 So you were in court every day for that 13 election board members themselves, because of their
14 trial? 14 interest they have been appointed to the boards
15 A I was in court every day for that trial. 15 throughout the state.
16 Q And how long did it last? 16 Q All right, sir.
17 A That lasted from January 9 until about the 17 Are you familiar with the machines and
18 end of January, I think it was the Thursday the last 18 systems used by the state of Georgia and the
19 week in January, but I don't recall what day that 19 counties to administer elections?
20 was. It was about three weeks. 20 A Yes.
21 Q By virtue of your work on election issues 21 Q How are you familiar with that?
22 since 2002, are you familiar with voter registration 22 A Well, that would be the Dominion Democracy

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1 Suite 5.5 system, and that's based on, you know, our 1 We actually coordinated monitors, audit
2 research, discussion with secretary of states and 2 monitors, for other counties as well, and
3 presentations that we do all over in regards to the 3 credentialed them through the Constitution Party.
4 technology that's being used right now in the state. 4 So yes, I am extremely familiar with the
5 Q Are you familiar with the issues and 5 audit both from a procedural and technical
6 problems that arose in the 2020 presidential 6 perspective.
7 election in Georgia? 7 Q All right, sir.
8 A I would say I'm extremely familiar with 8 And have you reviewed documentation
9 those. We've kind of specialized in that for the 9 concerning the first machine count and the hand
10 last three years. We've had a variety of volunteers 10 count?
11 work on different aspects of those. And I would say 11 A Yes, yes. And --
12 that we probably are more familiar -- maybe more 12 Q All right. And have you studied the
13 than anyone, not only in the state but possibly in 13 second machine count?
14 the country. 14 A Yes, yes.
15 Q All right. And you mentioned working with 15 Q Can you tell the committee some of the
16 volunteers. Have you appeared in the media to 16 data or documents or files that you've obtained and
17 discuss the 2020 election in Georgia? 17 reviewed for studying the first machine count, the
18 A Yes, I've been on quite a few podcast 18 second count and the hand recount.
19 shows and things, in different aspects. 19 A Well, one of the things that we did was we
20 Q And were you in the media talking about 20 issued a statewide what we call the open records
21 the 2020 election before January 3 of 2020? 21 request which I mentioned before for all of the
22 A Oh, absolutely. And our lawsuit was in 22 ballot images from all the counties, the original

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1 the media as well, the December 3, 2020 -- December 1 ballot images of the election. And we got those
2 23 when we filed the Fulton County ballot inspection 2 from -- a lot of counties actually had destroyed
3 case, that gained national attention from almost 3 them, which we believed was a violation of federal
4 every news media source in the country. 4 and state law. That was one of the things we got.
5 Q Have you testified in any courts about the 5 The reason the ballot images are important
6 2020 election as an expert? 6 is because you need a ballot image to create a cast
7 A I've testified as an expert in Georgia in 7 vote record which is then tabulated to make the
8 20 -- let's see, 2022, and I've testified in 2020 I 8 election results. So you can't have election
9 think in California. 9 results without a ballot image.
10 Q Were you an expert in the California 10 Q Let me stop you there for a second, and
11 matter? 11 ask if you've had any particular focus on Fulton
12 A They were unable to qualify me because it 12 County in any of this work.
13 was a timing thing. So I just ended up testifying 13 A Yes, I was an audit monitor at Fulton
14 as a fact witness in that case. But that was for 14 County. We coordinated other monitors for Fulton
15 three days out there. 15 County. We got as many ballot images as we could
16 Q All right, sir. So you have studied the 16 from Fulton County, so -- and I live in Fulton
17 first machine count? 17 County. So am very pretty familiar with -- that
18 A Oh, yes. Yeah. 18 would probably be the county that I'm most familiar
19 Q And the hand recount? 19 with.
20 A Well, I was intimately involved with the 20 MR. MAC DOUGALD: All right, sir.
21 hand recount. We were -- I was there at Fulton 21 Your Honor, at this point I tender
22 County World Congress Center during the hand count. 22 Mr. Favorito as an expert on the election systems

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1 used in Georgia, and on the conduct of the 2020 1 A Well, I've had an extensive amount of
2 presidential election, including security issues and 2 seminars throughout my professional career. I've
3 the system used in Georgia. 3 been to probably -- probably two dozen, at least
4 PANEL CHAIR HIRSH: Mr. Fox? 4 every year, probably twice a year, some type of
5 VOIR DIRE EXAMINATION 5 seminar that's relevant to the line of work that I'm
6 BY MR. FOX: 6 doing at that point in time.
7 Q Mr. Favorito, my name is Hamilton Fox. 7 Q And I believe you testified that you had
8 A Nice to meet you. 8 40 years of experience as an IT specialist; is that
9 Q You said you were not a member of the 9 correct?
10 Democratic Party, Republican Party, but you're a 10 A In different disciplines. I think I
11 member of the Constitution Party. What's the 11 mentioned some of the -- from computer programming,
12 Constitution Party? 12 system analysis design, daily administration and
13 A It's a smaller party, you might think of 13 systems development methodology, as well as the
14 it more like a Green Party or Libertarian Party. 14 architecture and what you would call cybersecurity
15 It's just more constitutionally based. 15 now.
16 Q And your formal training is that you have 16 Q Right. But none in anything that concerns
17 a certificate in computer programming from the Lear 17 designing voting machines?
18 Siegler Institute; is that correct? 18 A Nothing that's specific to the design of a
19 A Right, yes. 19 voting machine hardware. I'm more of a software
20 Q And I'm not familiar with that institute. 20 person. And the software is kind of the same
21 What is that? 21 regardless of what type of application that you
22 A So in 1968, this is going to be hard for 22 might develop it for.

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1 you to believe, but there were no computer science 1 Q But you were not directly involved in
2 courses really in America. The universities had not 2 designing electronic voting system software?
3 developed their computer science programs back then. 3 A I was not directly involved, that's
4 So you had to go to a specialty school, 4 correct, in designing the software itself.
5 and -- in order to become proficient in computer 5 Q Now, in 2002 I believe you said you
6 programming, which is what I wanted to do. Lear 6 started getting involved in the conduct of elections
7 Siegler was one of the only ones in the country that 7 in Georgia. Am I saying that right?
8 I knew about. Another one -- they were a little bit 8 A Yes, yes, I think so.
9 more strenuous to get in than the other one, I think 9 Q And a number of the issues on which you
10 was called ECPI back at that time. 10 focused had nothing to do with voting machines or
11 So I chose them. 11 electronic security; correct?
12 Q And how long was the course? 12 A No, that's really not true.
13 A It was about a year. 13 We were -- being an IT person, my concern
14 Q About a year, okay. 14 was that a vote was counted correctly and the
15 Aside from that, have you had any other 15 electronics were in fact correct.
16 formal training? 16 And what happened -- what I learned
17 A I'm not sure what you would define -- 17 immediately was that the voting system, as they are
18 Q That's not a good question. Let me 18 designed and developed, do not adhere to industry
19 rephrase. 19 standard best practices. And that -- my concern was
20 A Define formal training. 20 the actual voting system itself, the technology and
21 Q Formal training in computer programming, 21 how deficient it was compared to my entire career.
22 for example? 22 Q That's the touch screen issue that you

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1 mentioned a moment ago, I think. Is that what you 1 A Well, yes, but it's more than that.
2 were initially concerned with? 2 It's a lot of these -- the databases are
3 A Well, that's just one of the issues. 3 not kept up to speed in accordance with what I would
4 The other problems are the auditing and 4 believe to be standard database administration
5 testing procedures are wholly insufficient, from my 5 procedures, which I implemented when was a data
6 view, as it relates to what I'm used to and what we 6 administrator.
7 developed -- system developed processes and 7 So a lot of these records don't even
8 methodology, and how to test, how to audit. 8 represent people, they actually represent
9 They just seemed to be completely 9 something -- invalid voter roll, I actually found
10 deficient, alarmingly so, when you consider that 10 one that was a fake address where someone voted from
11 everybody in the country is voting on these things. 11 a fake address or a ballot was cast for them.
12 Q Now, you told us about a number of 12 Q And then the other area that you mentioned
13 legislative successes that you had had. One of them 13 was you got some protection for poll watchers;
14 was making ballots available through the public 14 correct?
15 records act? Isn't that what you said? 15 A Yeah, more meaningful access for poll
16 A Yes, that would become effective July 1 of 16 watchers, and make everything more transparent to
17 this year for the first time. 17 the voters, so that they can have confidence to know
18 Q And that had nothing to do with 18 that the elections are being processed, you know,
19 electronics? 19 properly and have confidence in voting.
20 A Well, it has everything to do with 20 Q Now, the two documents that you were
21 electronics because -- 21 shown, one which was RX-336, which was written in
22 Q So you can check on the voting system? 22 September of 2019, it wasn't clear to me whether you

Page 1243 Page 1245

1 A Exactly. You have to be able to verify 1 had actually presented that to the Georgia
2 those election results. And that's the only way you 2 legislature or whether that was just something that
3 can do it. That's why it's so critical. 3 you had used in a presentation in California.
4 Q And the same with the watermark? 4 A I'm not sure which one 336 was. That was
5 A Well, the watermark is a little bit 5 the unresolved security risks of ballot-marking
6 different. What that is intended to do is to 6 devices?
7 present -- or be able to detect fraudulent ballots. 7 Q In September of 2019. The paper you wrote
8 So the voting systems have the capability, 8 in September 2019.
9 as does here in Georgia, of recording this same 9 A That was the one -- unresolved -- yes,
10 ballot multiple times. So you can run that thing 10 sir.
11 through multiple times, that's -- and so some of the 11 Q Thank you.
12 concerns are -- the other thing is that it cannot 12 A Correct. I don't know whether or not this
13 detect a good ballot -- a real ballot from a bad 13 particular paper -- I believe this was submitted to
14 ballot. 14 the SAFE Commission. But what I can tell you is
15 So all of these things are also related to 15 that the security risks about marking devices were
16 the voting system and the deficiencies that I found 16 made known by election integrity and experts
17 in those. 17 throughout the country. They were made known to the
18 Q And I think you also have done some work 18 Georgia legislature before they made the decision.
19 in attempting to purge voting rolls, getting 19 Q All right. And your concern here and in
20 deceased people and that sort of thing off the 20 2020 -- sorry, in 2019 before the Georgia
21 election -- off the register -- as registered 21 legislature was with the security of these
22 electors? 22 ballot-marking devices; correct?

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1 A That was one concern that I had. It was 1 cybersecurity.
2 not the only concern, though. 2 Q You're saying we, you're talking about
3 Q And the other publication that we saw, 3 VOTERGA?
4 that was I think Respondents' Exhibit 338, was 4 A Yes. I author most of the studies. When
5 something that you submitted after the last 5 I say we, most of them are authored by me if they're
6 election. And do I understand that was submitted to 6 about Georgia.
7 the Georgia legislature? 7 Q My question was poorly worded. What I was
8 A I'm sorry, I don't know what 338 was. If 8 trying to get at is have you published any articles
9 you could show me, I could tell you. 9 in any publications, magazines, anything like that,
10 Q Maybe somebody could put it up for us if 10 related to this subject?
11 we can. 11 A Yes.
12 A Or you can just tell me what the title 12 Q What?
13 was, that will be good enough. 13 A I have.
14 Q I don't have it memorized, I'm sorry. 14 Q And what are those?
15 The SAFE Commission. 15 A I -- well, one that comes to mind recently
16 A Oh yes, yes. So the legislature -- the 16 was in a Flame newspaper, it's called Flame, and
17 legislature -- well, the SAFE Commission was 17 that article was entitled the 13 -- basically, the
18 commissioned by the governor, who is now Governor 18 essence of the article was there were 13 types of
19 Brian Kemp. At that time he was secretary of state. 19 outcome determinative fraud in the 2020 election.
20 Q I don't want to get into the subjects 20 Q And you published that in a newspaper?
21 right now. I'm just trying to understand to whom 21 A Yes.
22 this was given. Was this given to the state 22 Q Anything in any scholarly journals?

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1 legislature? 1 A Not that I can recall at the moment.
2 A Well, the legislature was driving the 2 Q Have you ever taught courses, formal
3 commission. 3 courses, about cybersecurity and elections?
4 Q I'm sorry. 4 A We -- I have not -- I have taught -- I go
5 A Barry Fleming, the state legislator, 5 around the state making presentations and teaching
6 chaired the commission. I think there were a couple 6 the various people in the state about the
7 other legislators on the commission. 7 cybersecurity concerns on the voting systems. I've
8 Q These two reports that we looked at, these 8 probably made 60 or 70 presentations sitewide on
9 were reports issued by your organization VOTERGA? 9 that topic.
10 A Yes. 10 Q To what sorts of audience?
11 Q And VOTERGA has also issued a number of 11 A Various -- anyone who would like to come
12 press releases, has it not? 12 is invited. Typically, they -- some organization
13 A Yes. 13 will invite me, I will come and it will be anywhere
14 Q And have you -- aside from what you've -- 14 from --
15 what VOTERGA has put out there, have you published 15 Q Anything affiliated with an educational
16 any articles about election security or 16 institution?
17 cybersecurity? 17 A Not to my knowledge. I think I've had a
18 A Let me try to think about that for a 18 couple of them at educational -- a couple of my
19 second. 19 presentations have been at educational facilities,
20 We've published quite a few studies, and 20 although I don't think that they were officially
21 they would be on our studies tab. And there is some 21 educational facility presentations.
22 relevance to some of those studies in regards to 22 Q As I understand, you testified that you

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1 were involved in some litigation in 2006 in which 1 expert?
2 were you a party in that litigation? 2 A I think he testified as a plaintiff in
3 A Yes. 3 that case.
4 Q You did not testify as an expert in that 4 Q And then as I understand it there was
5 litigation? 5 another 2020 case involving absentee ballots. Was
6 A No. We -- the judge -- I don't know that 6 that filed after the election?
7 we actually had a hearing on that. The case ended 7 A Yeah, the mail-in ballot -- Fulton County
8 up being dismissed, and I don't believe that we 8 counterfeit ballot case.
9 actually -- actually had a hearing. And then we -- 9 Q Did you testify as an expert in that case?
10 I know we appealed that to the Georgia Supreme 10 A Scheduled to testify as an expert. Again,
11 Court, and they -- they ruled against us. 11 we have not been to court yet.
12 But I don't think we ever had a hearing. 12 Q Has the judge accepted you as an expert in
13 But I was scheduled to testify as an expert in that, 13 that case?
14 and I also was scheduled in another case about that 14 A Again, we haven't been to court yet, so he
15 time as well. 15 can't accept me until we -- I think he's heard from
16 Q In 2019, you brought a similar case in 16 the plaintiffs and the defense.
17 federal court which was successful; correct? 17 Q Emily, would you put up Disciplinary
18 A Yes. I did not bring that case, no, I did 18 Counsel Exhibit 076 for identification.
19 not -- I think if you're talking about the Curling 19 This was the first expert disclosure that
20 v. Raffensperger case? 20 you made in this case, was it not, Mr. Favorito?
21 Q Yes, that's had many iterations, but there 21 Let's go to the second page and see if we can
22 was one in 2019; correct? 22 identify your signature.

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1 A Yes, that's exactly right. So the Curling 1 PANEL CHAIR HIRSH: Excuse me, Mr. Fox,
2 plaintiffs and the coalition plaintiffs which is 2 "this" may be an unclear antecedent. Do you mean
3 Coalition for Good Governance brought that lawsuit. 3 our proceeding or the case you were just talking
4 Q In that case did you testify as an expert? 4 about beforehand?
5 A No, I did not testify as an expert in that 5 MR. FOX: Oh, I'm sorry. In this
6 case. I was the adviser to our plaintiff, Ricardo 6 proceeding here.
7 Davis, who had pulled out of the case. 7 BY MR. FOX:
8 Q And as a result of Judge Totenberg's 8 Q So, Mr. Favorito, this was the first
9 ruling in that case, the system that was used in 9 expert -- you filed an expert disclosure on the 30th
10 2020 was ultimately put in place; correct? 10 of March, a couple days ago; correct?
11 A Yes, as a result of that ruling in 2019. 11 A Yeah, filed the one that Mr. MacDougald
12 Q And in August of 2020, the new system was 12 showed me earlier.
13 also challenged in front of Judge Totenberg; 13 Q Okay. But before that, you filed this
14 correct? 14 expert disclosure, did you not?
15 A That's correct. I'm not sure about the 15 A It looks very -- it looks familiar to me.
16 exact time frame, but the new system was challenged 16 Q Is that your signature on the second page?
17 in 2020. 17 A Yes, that does look like my signature.
18 Q Did you testify as an expert in that case? 18 Q And you certified "I hereby certify this
19 A I have not testified in that case. Now, 19 report is a complete and accurate statement of all
20 my cofounder, Ricardo Davis, who also has comparable 20 my opinions and the bases and reasons for them to
21 expertise, did testify in that case. 21 which I will testify under oath." Right?
22 Q As an expert? He was qualified as an 22 That's right above your signature?

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1 A Yes. 1 not -- so far haven't allowed me to qualify.
2 Q And in this case, you said that you would 2 At that point in time, they had suggested
3 testify -- sorry, in this document you said that you 3 that but the judge said no, it's too late, there's a
4 had testified in the Eastman case in California as 4 technical process you have to go through.
5 an expert; correct? 5 Q But did you not, sir, testify in response
6 A I was scheduled to testify as an expert, 6 that I'm not an expert?
7 but there was objection and the -- it was a 7 A No. I testified that I was not qualified
8 technicality where they didn't have enough time to 8 as an expert.
9 review my qualifications. So rather than to try to 9 Q Let's take a look --
10 go through that, they just said okay, just testify 10 A It was a very simple question to answer,
11 as a fact witness. 11 and I'm happy to answer it for you now if you would
12 Q But the statement in paragraph 5 here, 12 like me to, if you just give me the question and
13 list of cases in which I have testified as an expert 13 I'll answer it for you. Because I seem to recall
14 in the last four years, as an expert at trial or in 14 it.
15 deposition, it says State of California versus John 15 Q Let's take a look at Disciplinary Counsel
16 Eastman. That's not accurate, is it? 16 Exhibit 053 for identification.
17 A I'm not sure what the date on this is 17 A If I said that, I meant in regards to
18 versus the date that I testified in Eastman's case. 18 being qualified, to make it easier.
19 Q Well -- 19 Q Sorry, we're getting you a copy here.
20 A But it -- probably at the time that I 20 It would appear we've made copies of every
21 filled that out I was expecting to testify as an 21 single volume but the one you need.
22 expert, and probably would have had it not been for 22 PANEL CHAIR HIRSH: I once said that would

Page 1255 Page 1257

1 a timing error on John Eastman's part, and the 1 be my epitaph, the only volume that's missing is the
2 attorneys out there. 2 one that I want. That was back when law was in
3 Q But the judge in that case did not accept 3 volumes.
4 you as an expert; is that not true? 4 BY MR. FOX:
5 A That was a technical qualification. It 5 Q There's only one question and answer
6 had nothing to do with my expertise. 6 that's highlighted here, I'll show it to
7 Q Did you not say during your testimony out 7 Mr. MacDougald.
8 in California that you were not an expert? 8 Now, I want you to look at page 2 --
9 A Oh, so you're referring to the case where 9 sorry, 3 of this exhibit, and see that you are the
10 the prosecuting attorney or the opposing attorney 10 witness there at the top of the page.
11 asked me for an opinion. The judge had already 11 Do you see that?
12 ruled that I could not give opinions because I had 12 A Yes.
13 not been an expert. 13 Q And now if we can turn to page 51 starting
14 And the prosecuting -- the opposing 14 at line 120, were you asked this question and did
15 counsel then turned around and said -- wanted me to 15 you give this answer?
16 give an opinion on something, which I'd have been 16 "Question: So how do you believe one
17 glad to do, but I can only give opinions for both 17 would go about calculating a change in the signature
18 parties or not for -- you know, we can't have a 18 rejection rates based on signature --
19 double standard. And quite frankly it was quite a 19 PANEL CHAIR HIRSH: Hold on, hold on. I
20 double standard in the court there. 20 don't think you're on the right page.
21 So I declined to testify, saying that you 21 MR. FOX: I'm sorry, Emily, I apologize.
22 were asking me an expert witness question, and did 22 It's -- I think that's not the right page. Page 51.

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1 Scroll down to the top. 1 identification.
2 PANEL CHAIR HIRSH: I think you may be 2 Do you recognize that this is your expert
3 using the top numbers rather than the bottom ones. 3 report?
4 BY MR. FOX: 4 A Yes.
5 Q I am. And I am using the top numbers. 51 5 Q And you wrote that just a couple of days
6 here. I apologize, my copy does not have the Bates 6 ago; right?
7 numbers on it. 51, if we could go down to line 20. 7 A I believe so. Appears to be.
8 So let's try again. Were you not asked this 8 Q And if you will go to page 7, item 4 says
9 question and give this answer? 9 the cases in which Mr. Favorito has testified in the
10 "Question: So how do you believe one 10 last four years at trial or deposition are, and then
11 would go about calculating a change in the signature 11 these two Chen cases, one of which where you were a
12 rejection rates based on signature mismatches 12 plaintiff -- or sorry, the Chen case, one of which
13 between 2018 and 2020? 13 where you were a plaintiff, and then the Eastman
14 "Answer: Well, again, you're asking me an 14 case.
15 expert question, and I'm not qualified as an expert 15 A Right. And that's why --
16 to be able to answer that. So I don't know the 16 Q That's where you say this time you say you
17 exact method." 17 weren't designated as an expert; correct?
18 Did I read that correctly? 18 A Correct. Due to an untimely designation.
19 A I'm going to say this is correct, although 19 Q And you don't say that you were designated
20 I have seen errors in transcriptions before. 20 as an expert in the Chen case either, do you, in
21 But again, the issue is that I was not 21 this deposition -- in this disclosure?
22 qualified as an expert even though I believe I 22 A Oh, I was clearly designated as an expert

Page 1259 Page 1261

1 should have been and would have been had it not been 1 witness in the Chen case, and I testified twice as
2 for the technicality. So when the opposing counsel 2 an expert witness in the Chen case.
3 starts asking me for opinions, it wouldn't be 3 Q And why if you were not designated as an
4 appropriate for me to give an opinion to the 4 expert did you list the Eastman case?
5 opposing counsel if the judge decided that she 5 A Why did I list it?
6 didn't have time to qualify me as an expert witness. 6 Q Yeah.
7 That was the essence of this argument that 7 A Well, it said cases during the last four
8 occurred. I remember it pretty vividly. 8 years, so I just listed it, these are the cases that
9 Q So you told us in your first disclosure 9 I testified to in the last four years.
10 you'd been qualified as an expert -- or that you had 10 Q I see. Even -- all cases, not just ones
11 testified as an expert, and that's past tense; 11 you were an expert?
12 right? 12 A Well, I'm not sure if that's an all case
13 A So again, experts have different areas of 13 -- conclusive list or not. I think it is, I think
14 technique -- of expertise, technology, election 14 those are the ones that I testified to in the last
15 administration, there's all sorts of different 15 four years. There's been more before that, dating
16 things that are different types of expertise. 16 back to 2008.
17 So someone who is an expert in one thing 17 Q Before you wrote this document, your
18 may not necessarily be an expert in something else, 18 current expert report, had anyone disclosed to you
19 even though they're all related into the election 19 that I had a copy of the transcript of the Eastman
20 umbrella. 20 trial?
21 Q Let me show you your current expert 21 A No.
22 report, which is Disciplinary Counsel Exhibit 77 for 22 MR. FOX: All right. I have no further

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1 questions, but I'm not sure I understand what he's 1 probably Bates 54, since they seem to be three pages
2 being challenged for, but I don't think this 2 off between the Bates number. That looks like the
3 gentleman has sufficient training or education to be 3 right exhibit.
4 qualified as an expert. 4 BY MR. MAC DOUGALD:
5 PANEL CHAIR HIRSH: I'm going to overrule 5 Q Keep going. Transcript page 51. One
6 the objection. And I understand your point, 6 more. There you go. Back up to line 3, please.
7 Mr. Fox, about his training and I'll consider that. 7 Go ahead, Mr. Favorito, from line 3.
8 We all can consider that in evaluating his 8 A Okay. The witness, that's me, "Right. I
9 testimony. 9 understand. I just wanted to note -- to resolve
10 DIRECT EXAMINATION (Continued) 10 that issue. I didn't mention that earlier. No,
11 BY MR. MAC DOUGALD: 11 it's not my testimony that that number -- that you
12 Q Now, Mr. Favorito, I'm going to bring this 12 can't, you know, figure that out, because otherwise
13 transcript that counsel was asking you about over to 13 all the experts that have calculated those rates
14 you. 14 wouldn't have been able to calculate it. So of
15 A You may approach. 15 course you can calculate the rates."
16 Q And I'd like you to read into the record 16 The court says "So of course" -- and then
17 from line 3 on this page. 17 Mr. Carling, the opposing counsel says, "But what do
18 A Okay. Until what stopping point? Line 9? 18 you." Then the court says "Just a minute. You're
19 Q Until you get down to -- just read the 19 saying of course you can calculate what?" The
20 whole page. 20 witness says "The rates." The court says "The
21 A Line 9 to 25. 21 rates?" The witness, myself, says, "Yes, the
22 PANEL CHAIR HIRSH: Can we see the 22 rejection rates that counsel is referring to."

Page 1263 Page 1265

1 transcript that he's reading from? 1 And Mr. Carling, the opposing counsel,
2 MR. MAC DOUGALD: Can you all put that on 2 says, "So how do you believe one would go about
3 the screen? I don't have it. 3 calculating a change in the signature rejection
4 PANEL CHAIR HIRSH: What page is he 4 rates based on signature mismatches between 2018 and
5 reading from so they can find it. 5 2020?
6 MR. MAC DOUGALD: It looks like 51. It's 6 "Answer: Well, again, you're asking me an
7 51. 7 expert question, and I'm not qualified as an expert
8 Can you all get that? 8 to be able to answer that. So I don't know the
9 MR. FOX: She can. And it's page 51, not 9 exact method."
10 Bates 51. 10 Q All right, sir. So you did know how to
11 MR. MAC DOUGALD: Pardon me, thank you. 11 calculate it, but you didn't think that you were
12 Same one we had before, I think. 12 allowed to calculate it?
13 THE WITNESS: Are you ready for me to -- 13 A Correct.
14 BY MR. MAC DOUGALD: 14 Q All right. When you talk about election
15 Q We're waiting for her to -- 15 integrity, what does that phrase mean to you?
16 A Oh, okay. Let me know when you're ready. 16 A Well, the two key components of election
17 Q It was -- what was that exhibit number, 17 integrity, I believe, are election security and
18 Mr. Fox? 18 election transparency.
19 PANEL CHAIR HIRSH: I think it's 53, is 19 So you really can't have integrity if the
20 the exhibit number, if my notes are correct. 20 elections are going to be secretly counted and you
21 MR. MAC DOUGALD: That's correct. 21 as a voter can never verify what the results really
22 PANEL CHAIR HIRSH: Exhibit 53, and it's 22 were. Likewise, you want your votes to be secure

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1 and not susceptible to hacking. 1 my notes, but I could have missed it. In any event,
2 But there's also other components that 2 let's do it now to make sure.
3 could come into play. The verifiability of the 3 Mr. Fox, do you have any objection?
4 votes. The voters need to be able to verify their 4 MR. FOX: No objection.
5 votes. The election officials need to be able to 5 PANEL CHAIR HIRSH: 336 will be admitted.
6 audit their results. And the system has to be able 6 (Exhibit R-366 received.)
7 to form a complete recount, not just simply reprint 7 BY MR. MAC DOUGALD:
8 previously unverifiable results but do a true end to 8 Q All right. Garland, 338, that's the paper
9 end recount. 9 that you -- or your recommendation to the Georgia
10 Q All righty. Did you form an opinion, or 10 SAFE Commission?
11 have you formed an opinion, on whether the Dominion 11 A Yes, it is.
12 system in Georgia was secure from a cybersecurity 12 PANEL CHAIR HIRSH: We'll pause.
13 point of view? 13 Mr. MacDougald, I know you know the
14 A Yes, I have formed an opinion on that. 14 witness and you slipped up, but please refer to him
15 Q What is your opinion? 15 by his last name.
16 A My opinion is that it is not secure for a 16 MR. MAC DOUGALD: I'm so sorry.
17 variety of reasons. Now, the system as well as how 17 PANEL CHAIR HIRSH: No, no, I understand.
18 it's used in Georgia. 18 MR. MAC DOUGALD: I didn't even realize
19 Q All right. I'm going to put up on the 19 it.
20 screen one more time Exhibit R-336. Tell us again 20 PANEL CHAIR HIRSH: I just prefer to
21 what that report relates to, on the screen. 21 maintain that.
22 A This -- this report is the ballot-marking 22 MR. MAC DOUGALD: I did not even realize

Page 1267 Page 1269

1 device report that we discussed earlier that I had 1 it, I apologize.
2 authored and presented in California at the national 2 BY MR. MAC DOUGALD:
3 voting rights task force. 3 Q Does this report, Respondent's 338,
4 Q What conclusions does this report draw 4 VOTERGA SAFE Commission recommendations, address the
5 regarding the security of BMD voting systems? 5 security of the election system that was being
6 A Well, this report draws the conclusion 6 considered by the state?
7 that has already been pretty well accepted that 7 A I believe it does address security and
8 ballot-marking device systems have security and 8 auditability. I'd probably have to review the table
9 auditability issues. We have since that time found 9 of contents. But yes, actually, even more so than I
10 a lot more security issues about other of the 10 recall. But yes, it does.
11 components. 11 MR. MAC DOUGALD: All right, sir. I
12 This particular report is only limited to 12 tender Respondents' Exhibit 338 into evidence.
13 the ballot-marking device, didn't really talk about 13 MR. FOX: I object. It's written after in
14 the servers, the scanners or any of the other 14 2021. It's a recommendation for how Georgia ought
15 components that are in the system. 15 to change its voting system going forward, certainly
16 MR. MAC DOUGALD: All right, sir. 16 not something Mr. Clark relied on. And I don't see
17 I tender Respondents' Exhibit 336 into 17 any relevance here. If he wants to testify what he
18 evidence. I think that's already in. 18 thinks were the inadequacies, certainly free to do
19 MR. FOX: Yeah, I think it is. 19 that. But I don't think this document is relevant.
20 MR. MAC DOUGALD: My mistake. 20 MR. MAC DOUGALD: I can ask a follow-up
21 PANEL CHAIR HIRSH: Actually, I don't 21 question that I believe will help on this.
22 think you offered it before, at least according to 22 BY MR. MAC DOUGALD:

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1 Q When was this report prepared and 1 Q Now, Garland, do you have knowledge one
2 presented? 2 way or the other about whether there is a consensus
3 A That would have been in 2018 or '19, 3 among cybersecurity experts regarding the strength
4 because I presented it -- probably 2019. I 4 or vulnerability of the Dominion system?
5 presented it to the Commission in December -- 5 A Yes. Almost every cybersecurity expert
6 mid-December of 2019. So it couldn't possibly have 6 that I know has -- would tell you that parts or all
7 been written in 2021. 7 of that system are deficient from a cybersecurity
8 MR. MAC DOUGALD: I renew my tender of 8 perspective, and not just the Dominion system, other
9 R-338. 9 systems as well.
10 MR. FOX: I'm a little confused. I 10 But yes.
11 thought just a moment ago he testified that it 11 Q All right, sir.
12 talked about the insufficiencies of the 2020 12 Now I'm showing you a document marked
13 election, which I do not see how it could have been 13 Respondents' Exhibit Number 018, R-018. And I'm
14 done in 2019. 2018. 14 going to scroll through this, and ask if you
15 MR. MAC DOUGALD: I'm -- I think that 15 recognize this document.
16 counsel may have misunderstood. The question was 16 A I do. This is basically corroborating
17 about recommendations relating to the system or 17 what I just stated. These are experts from
18 systems that Georgia was considering at the time of 18 throughout the country who have written a letter to
19 the report. 19 the SAFE Commission. And as I recall, it had to do
20 PANEL CHAIR HIRSH: Okay. 20 with the security of the system, that were under
21 MR. MAC DOUGALD: And if the committee 21 consideration.
22 didn't hear that, I'll ask the question to clarify. 22 Q All right. Did any of these experts

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1 PANEL CHAIR HIRSH: Yeah, yes, why don't 1 testify for the plaintiffs in the Curling
2 you clarify. 2 litigation?
3 BY MR. MAC DOUGALD: 3 A Yes, I see Andrew Appel there, and I --
4 Q Why did you submit this report to the 4 well, there were a couple of expert -- there were
5 Georgia SAFE Commission in 2019, Mr. Favorito? 5 some reports. Dr. Duncan Buell I know submitted a
6 A I submitted the report for their 6 report. I don't think he testified at this last
7 consideration in evaluating the new system which 7 hearing. Dr. DeMillo, who I know pretty well, I
8 they eventually purchased in 2020. So I submitted 8 believe had submitted a report, but I don't think he
9 this report in 2019, created in 2019, presented it 9 testified.
10 in Macon, Georgia, to the SAFE Commission in 10 And there's probably -- Dr. Stark clearly
11 December of 2019. 11 testified in January of this year.
12 MR. MAC DOUGALD: All right. Maybe third 12 MR. MAC DOUGALD: All right. Your Honor,
13 time is a charm. I renew my tender. 13 I'd tender Respondents' Exhibit Number 18 into
14 MR. FOX: Still don't see the relevance. 14 evidence.
15 PANEL CHAIR HIRSH: Well, we'll consider 15 MR. FOX: Same objection as to relevancy.
16 it for whatever relevance it might have, but it 16 You've already ruled on that, so --
17 sounds like this was something that predated 2020. 17 PANEL CHAIR HIRSH: Okay. I'll admit it
18 I'll admit it. 18 for whatever relevance it may have.
19 (Exhibit R-338 received.) 19 (Exhibit R-018 received.)
20 MR. MAC DOUGALD: So 338 is in? 20 MR. MAC DOUGALD: All right. Thank you.
21 PANEL CHAIR HIRSH: Yes. 21 BY MR. MAC DOUGALD:
22 BY MR. MAC DOUGALD: 22 Q Now, we've already talked about the

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1 Curling versus Raffensperger case -- 1 really correct to ask a nonlawyer to say what the
2 MR. MAC DOUGALD: That was 18; right? 2 judge found and what she didn't find in the case.
3 MR. FOX: 18 -- I apologize. 3 I can explain the opinion if you want, but
4 PANEL CHAIR HIRSH: Yes, R-018 is what I 4 I don't think that was a finding, for example, in
5 have. 5 the strict legal sense.
6 BY MR. MAC DOUGALD: 6 PANEL CHAIR HIRSH: That's a fair point in
7 Q I lost my pen somehow. 7 some sense. I thought the question was directed at
8 Was the security of the Dominion system an 8 sort of a global level and not, you know -- because
9 issue in the Curling litigation? 9 Mr. Fox, you've asked a similar question, didn't the
10 A Absolutely. That was the foremost issue. 10 court say this was okay, or didn't the court say
11 All sets of plaintiffs have requested that the court 11 whatever. In a broad sense the witness's knowledge
12 declare the system constitutionally deficient in 12 of what the court did may be potentially relevant to
13 either part or all components, including the servers 13 the case.
14 and the scanners. 14 Obviously, to the extent this case is
15 Q All right. I am going to show you a 15 relevant I assume the parties can cite it, I can
16 document marked Respondents' Exhibit Number 057, and 16 take judicial notice, we can take judicial notice of
17 ask if you have ever -- if you know -- if you've 17 the existence of this or any other case.
18 heard of an order in the Curling litigation from 18 Whether all of the factual findings in
19 October of 2020. 19 that case become factual findings in our case is a
20 A Yes, I'm very familiar with the order of 20 completely different subject, and generally speaking
21 October of 2020, although I'm not necessarily 21 they don't.
22 familiar with this summary but I am familiar with 22 So I'm not sure -- I don't have that much

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1 the order. 1 of a problem with the question and answer you just
2 Q All right. In the order, did Judge 2 received, but if you're going to take him through
3 Totenberg make any findings regarding the security 3 every page of a long opinion and do that, it
4 of the Dominion system? 4 probably is objectionable.
5 A Well, yes, she expressed several concerns 5 MR. MAC DOUGALD: No, I'm not.
6 about the security, but also she found that the 6 BY MR. MAC DOUGALD:
7 system was, in fact, in violation of Georgia law, in 7 Q Mr. Favorito, was this order from October
8 multiple Georgia laws, in that it was unverifiable 8 of 2020 that you've just described your
9 to the voter. And that leads to security issues. 9 understanding of, was that a topic of discussion in
10 But the system, as I think I mentioned earlier, 10 election integrity circles regarding the Georgia
11 accumulates votes in a QR code which the voter 11 election?
12 cannot verify. 12 A Well, yes, it was a topic of discussion,
13 Georgia law requires an elector-verifiable 13 because this summary here is the exact quotes out of
14 ballot and requires human readable text for the 14 the order. I recognize her order. And regardless
15 voter. And therefore the court found that the 15 of how you interpret it, this is what she did, in
16 system was not in accordance with Georgia law, 16 fact, write in the record.
17 essentially what we consider to be illegal, three 17 And she wrote that -- she cited the law,
18 weeks before the election was conducted in November 18 and then she said "plaintiffs and other voters who
19 of 2020. 19 wish to vote in person are required to vote on a
20 MR. FOX: Mr. Hirsh, can I interpose an 20 system that does none of those things," referencing
21 objection? He's -- I've read this opinion, it's 21 the law.
22 long and very complicated. And I don't believe it's 22 So however you interpret it, it's left up

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1 to you, but that is an accurate depiction of what I 1 controversies in Georgia. It happened right before
2 believe is on page 81 and 82 of that order. 2 the election, and people were talking about it.
3 MR. MAC DOUGALD: All right, sir. 3 PANEL CHAIR HIRSH: Look, to the extent
4 Your Honor, could we take a short break, 4 the point of the opinion is to say this is stuff
5 five to 10 minutes? 5 that was out there, that's fine too, okay.
6 PANEL CHAIR HIRSH: Okay. Do you expect 6 What I'm just, saying to be clear, is when
7 to finish up with Mr. Favorito? 7 a court decides a decision, it's based on the
8 MR. MAC DOUGALD: I would have to look at 8 evidence presented in that case. It doesn't mean
9 the rest of my outline. As I sit here, I think we 9 all of the evidence was presented in this case and
10 will get to 5:00, before I turn over the witness, so 10 we would necessarily reach the same conclusion or
11 may -- and may have to pick back up with him in the 11 not.
12 morning. 12 There are ways in which having a court
13 PANEL CHAIR HIRSH: Okay. All right. 13 decision might be relevant to the case, but that
14 Let's break until 4:25. 14 doesn't mean it's all incorporated into this record
15 MR. MAC DOUGALD: Thank you very much, 15 and you can rely on it all as true.
16 Mr. Hirsh. 16 MR. MAC DOUGALD: All completely fair,
17 (Recess.) 17 Mr. Chairman.
18 PANEL CHAIR HIRSH: Please proceed. 18 BY MR. MAC DOUGALD:
19 MR. MAC DOUGALD: Your Honor, I would like 19 Q Mr. Favorito, do you have an opinion on
20 to tender Exhibit R-057, which is the Curling versus 20 whether the security certifications for the Dominion
21 Raffensperger order from October 11, 2020. And I 21 system in Georgia are an adequate guarantee that the
22 have a couple of bases for why it ought to be 22 system is secure?

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1 admitted. 1 A Yes, I do. I don't consider them to be
2 MR. FOX: I don't have a problem with 2 adequate because of the security issues, some of --
3 admitting it. It's easier for the hearing committee 3 only a few of which we've talked about so far are
4 to find it that way. 4 still out there. So they're still inherent in the
5 PANEL CHAIR HIRSH: I actually didn't hear 5 system.
6 the last part of that either. 6 And therefore I would consider those not
7 MR. FOX: It's easier for the hearing 7 to be wholly adequate based on my 40 years in
8 committee to find it in the sense of locate it that 8 information technology and the 20 years in voting
9 way. 9 system technology and background.
10 PANEL CHAIR HIRSH: I will admit 057 and 10 Q All right, sir.
11 subject to the comments I made before. That doesn't 11 Do you have an opinion on the adequacy of
12 mean that every statement in there -- 12 the various counties' cybersecurity programs for
13 MR. MAC DOUGALD: Correct. 13 their Dominion equipment?
14 PANEL CHAIR HIRSH: -- is either 14 A Georgia counties have virtually no
15 established as a fact or that that's substantively 15 cybersecurity program, to speak of, of any
16 evidence. It's evidence of what the court 16 significance, which is -- you've kind of raised one
17 concluded. 17 of the key security issues in Georgia.
18 MR. MAC DOUGALD: And I was going to make 18 And that is Georgia -- the system is
19 two points about it. One is the committee can take 19 programmed centrally by the secretary of state's
20 judicial notice of it because it's a published court 20 office. And the counties have to accept whatever
21 opinion, and number two, it's, for lack of a better 21 they get, and they don't have any mechanism to
22 analogy, it's part of the res justae of the election 22 detect whether or not malware has been delivered to

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1 them. 1 immediately within three days after it was
2 The Georgia system is subject to what we 2 initiated, the secretary of state's office wiped the
3 call in the industry a single point of attack. And 3 servers there that were at Kennesaw State, so that
4 if you compromise the central server with malware, 4 no one could determine what the vulnerabilities
5 then you can basically control every election in 5 were, whether or not they had been mitigated, and so
6 every county, and you can download malware from 6 on and so on.
7 there into the voting machines themselves in each 7 Q Now, over the years, you've been involved
8 county and control the outcome of various elections. 8 in election integrity and filing lawsuits and so
9 So it's -- the single point of attack 9 forth, you from time to time have presented
10 vulnerability is something that I think is a huge 10 problems, issues, vulnerabilities, concerns and so
11 problem in Georgia and maybe one or two other 11 forth to government officials regarding the
12 states. Most other states operate at the county 12 election?
13 level, so they program their systems at the county 13 A Yes, pretty constantly.
14 level, they're not subject to the single point of 14 Q And as a result of those exchanges with
15 attack. 15 government officials, have you observed any kind of
16 And that -- what we did find in 2017, that 16 pattern in how they respond when you point out or
17 the central system was in fact vulnerable and open 17 others point out that there's a problem with their
18 for anyone literally in the entire world to put 18 system?
19 malware on it and have it downloaded to the 19 A Yes, there has been historically a
20 counties. 20 disinterest in it. They have tended to believe the
21 Q So it actually happened with the previous 21 office of the secretary of state. We have
22 system? 22 hand-delivered a number of reports to them. One of

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1 A It -- the vulnerability happened. This -- 1 them showed electronic alteration of the ballot
2 in fact that was what originated the Curling case to 2 images in the 2020 election before certification.
3 begin with. 3 But in general, there has been a lack of
4 The Curling case was originated because of 4 responsiveness until this year. And as a result of
5 the vulnerability in the secretary of state's 5 our statewide efforts, they have, I think, turned
6 system, which was at that time Center for Elections 6 the corner now and they are more willing to believe
7 Systems out of Kennesaw State, which did the 7 us, believe the people, believe me and the work that
8 programming for secretary of elections, and that was 8 we've done. And that was the result of why we had
9 found vulnerable to literally anyone in the 9 such a successful session I think this past week.
10 Internet, there was a -- anyone in the world to put 10 Q All right, sir.
11 a virus on. 11 Do you have an opinion on whether
12 The background on that was Logan Lamb was 12 risk-limiting audits are sufficient protection
13 a Bastille team researcher. He identified the 13 against the weaknesses in cybersecurity in the
14 problem in August of 2016. He notified the Center 14 Georgia election systems?
15 for Elections Systems, which reports to the 15 A Risk-limiting audits as implemented in
16 secretary of state. 16 Georgia do not suffice. And even the inventor of
17 The executive director basically thanked 17 the risk-limiting audit process testified in court,
18 him and said we'll take care of it. And then in 18 and I think he signed the document that you showed
19 March of 2017, I guess that's about seven months 19 us earlier, that the audit process is just wholly
20 later, the vulnerability was still there. 20 inadequate in Georgia.
21 As a result of that, the Curling case that 21 To give you an example -- and particularly
22 we're talking about was in fact initiated, and 22 that's really what that report that you showed me

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1 about ballot-marking devices gets to. 1 secretary of state's office, they're not keeping it
2 But to give you one example, the state's 2 for themselves. So that's what we call -- that was
3 own expert witness testified that a risk-limiting 3 the Arlo system.
4 audit cannot audit what a ballot-marking device 4 So the first problem is that the people
5 showed to the voter. 5 who are doing the counting, you typically want to
6 So if the ballot-marking device shows the 6 have one person of opposite parties counting the
7 wrong information to the voter, no one would ever 7 results, so they are checking on one another.
8 know. And this is the kind of thing that we have 8 In the case of Fulton County, they did not
9 warned of back in 2018 and '19, Dr. Stark, who -- 9 do that, they had different people -- the people of
10 the inventor, has sent a letter to the elections 10 the same parties counting at one table, people of
11 officials before they purchased the system, warning 11 another party counting at a table. That was one of
12 them about this. He's testified, again, this time 12 the problems.
13 in the Curling case. 13 One of the other problems is that as
14 So that's -- the long answer is that no, 14 monitors we could not get within 6 feet to see what
15 that is not -- I don't consider them adequate for 15 was going on. So the monitoring teams are not able
16 those reasons. 16 to have adequate visibility, which we since tried to
17 And the way that they were implemented in 17 fix that legislatively.
18 the 2020 audit is a whole another issue that we can 18 The third problem was that the -- no one
19 talk about, because that is equally as deficient as 19 was monitoring the data upload point. So if you go
20 the process itself. 20 in and you -- if you decide to change the results,
21 Q Why don't you go ahead and tell us about 21 and you're the data uploader, you could just type in
22 that right now. 22 anything, regardless of what is on that tally sheet.

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1 A So in the 2020 hand count audit, which 1 No one was monitoring that, and that's -- and I
2 allegedly confirmed the voting system results, was 2 checked that at multiple counties.
3 riddled with procedural problems and actual 3 And then finally, and the most important
4 problems. 4 of all, is that the audit process had a broken chain
5 But this -- backing all the way up to 5 of custody right in the middle of it. And by that I
6 November 14 when the audit was conducted. One of 6 mean the -- when the counties entered the data, the
7 the problems was that normally you have people -- 7 data went to the secretary of state's office, the
8 well, first of all, let me describe the audit 8 counties had no results for their own audit.
9 process, I guess it would help more. 9 So that is a broken chain of custody that
10 Q Okay. 10 should have invalidated the entire audit. It's
11 A Typically, ballots are sealed, they are 11 completely unacceptable based again on my 40 years
12 brought out. You have many tables, in the case -- 12 of IT and 20 years of voting system technology to
13 I'll use Fulton County as an example, 125 tables 13 have an audit process where they broke the chain of
14 were set up where two people counted a group 14 custody right in the middle of it, completely
15 typically of 100 ballots at a time. And one would 15 unacceptable. But that's the way the 2020 audit was
16 call it, the other would write it down, they would 16 conducted in virtually every one of the 159
17 check each other. And after the end of a batch, 17 counties.
18 they would write the results on a tally sheet. 18 Q All right. And in the event, did the hand
19 The tally sheets when they were done are 19 count confirm the results of the first machine
20 taken over to someone who -- there who -- a data 20 count?
21 upload person. They will upload the information. 21 A The secretary of state claimed that they
22 But unfortunately that information is going to the 22 did.

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1 We did an analysis of only Fulton County, 1 And you would take that, it has your
2 and we found some remarkable things. The first 2 ballot style on it, because every ballot, depending
3 thing we found was that there was a 60 percent error 3 upon -- even in -- different precincts could have
4 rate in the count. 4 different ballot styles, so you would have different
5 Q Let me -- I want to stop you there. 5 candidates depending upon if you are in this
6 A Okay. 6 district, that district, even within the same county
7 Q Because I want to limit your -- what your 7 you have a different ballot style, is what we call
8 testimony is to the period before January 3. 8 it.
9 A Yes. 9 So you take those, you would take that in
10 Q So there were results posted for the hand 10 there, and you would put it in your ballot-marking
11 count, and the first machine count. And were 11 device, touch screen -- I'm sorry, would display
12 they -- how did they compare? 12 your ballot style for you based on where you live.
13 A There were discrepancies in almost every 13 And you would touch the screen, make your
14 county, some of which have still yet to have been 14 selections.
15 explained. 15 It would ask you are you correct, you go
16 Q Does a recount, a machine recount, address 16 to what we call the summary screen. The summary
17 security problems in the Dominion system? 17 screen would say are you ready to cast your ballot.
18 A Definitely not. 18 If not, you can go back and look at any particular
19 The way that Georgia implemented machine 19 race. And if you're ready you cast your ballot, it
20 recounts, which were over our objections, at the 20 prints out what we call a selection summary.
21 state election board, the state election board 21 It's not a full ballot because it does not
22 developed a procedure which simply, as I said 22 have the candidates you didn't vote for and it does

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1 earlier, reprints the previous unverifiable results. 1 not have the referendum language on it. It only has
2 It is not a true end to end machine count. They 2 the candidates that you selected.
3 just simply re-tabulate, or the legal term for it in 3 You will take that. Our system has a QR
4 Georgia is recanvass. 4 code, what you voted, who you voted for, is in the
5 But it's not an end to end, full recount. 5 QR code. It is not actually what you see in the
6 Q All right, sir. 6 text. The system does not have the capability to
7 Now, the components of the Dominion 7 optically analyze that and create the votes from
8 system -- tell the committee what the big components 8 that text.
9 of the system are that the voter deals with and that 9 So they're in the QR code, you will take
10 the office deals with. 10 that over and you will put that into the scanner.
11 A Sure. So the voting system, as you walked 11 The scanner will then accept that ballot.
12 in and you voted on a system, it would -- you would 12 Then later on in the evening there's
13 probably see a touch screen if you were in Georgia, 13 another back-end process once you -- the precincts
14 and it's called -- 14 take their results to the counties, then the
15 Q Before that, before you get your ballot 15 counties would -- they have a tabulation server and
16 access card. 16 an election management server that takes the ballot
17 A Oh, I'm sorry, yes. 17 images, and which are typically on the hard drives,
18 You would first of all check in on the 18 the USB sticks, and then they will upload that, the
19 poll pad. The first thing you would do is you would 19 ballot images, cast vote records and audit logs of
20 present your ID, you would check in on a poll pad. 20 what happened. And then they will then tabulate,
21 They would then give you what we call a voter access 21 produce, their results.
22 card, which is typically a little yellow card. 22 Their results will then go on a --

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1 typically, onto -- they can extract the results on a 1 security paper is so important.
2 USB stick, take it over to another server outside of 2 So those were some of the things that they
3 the election firewall, and then they will upload 3 found out. It was pretty obvious they were
4 that to Clarity Elections, which actually publishes 4 counterfeit ballots. I remember Suzi Voyles and
5 the results for the counties, and actually for the 5 Barbara Hartman there, they raised the issue to the
6 state. And they also do other states as well. 6 elections official, who I believe was the interim
7 Q All right. Mr. Favorito, could I ask you 7 director at that time, Nadine Williams, but they
8 to scoot a little closer to the microphone? 8 were told to just continue counting.
9 A Sure. 9 There was no provision -- as we found out
10 Q Now, the poll pads, are they connected to 10 in the Curling case, Georgia has no provision for
11 the Internet? 11 addressing illegitimate ballots if they are found in
12 A That's an interesting question. 12 an audit.
13 So the poll pads were originally not 13 Q So they counted them anyway?
14 connected to the Internet. However, in recent 14 A That's correct.
15 years, and just recently in the last -- since this 15 Q Now, you've talked about BMD ballots with
16 system, they have implemented wireless connectivity 16 the QR codes. Are absentee ballots -- do they have
17 on the poll pads, since this new system came in. 17 the QR code or are they different?
18 Q As of 2020, were they connected to the 18 A No, the absentee ballot has a bar code
19 Internet? 19 that's just used for alignment marks. It does not
20 A They had wireless connectivity in 2020, 20 contain votes.
21 yes. 21 So you might see -- the difference between
22 Q All right, sir. 22 a bar code and a QR code, I think everybody now

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1 Now, you mentioned the hand count, and it 1 knows what a QR code is since they have a phone,
2 sounded like you were there; is that right? 2 it's that little square or rectangle.
3 A I was there for the Fulton County 2020 3 A bar code on a ballot is just a series of
4 hand count audit, yes. 4 lines. So they have to have that in order to align
5 Q Did you see anything unusual? 5 the ballot and count it properly, but those -- that
6 A Yes. 6 type of a bar code cannot contain data, or at least
7 Q Tell us about that. 7 it cannot contain a significant amount of data that
8 A That was when a couple of the audit 8 could change an election, for example, or change the
9 monitor -- the senior poll managers who were serving 9 results of the ballot.
10 as auditors found counterfeit ballots in the Fulton 10 Q Now, so how does the voter record their
11 County hand count audit. 11 vote on an absentee ballot?
12 They knew that they were hand -- that they 12 A The voter would, on an absentee ballot,
13 were counterfeit because they were mail-in ballots, 13 would just do the mark in the bubble, they would
14 and they were not creased from being mailed. And 14 mark in the bubble. Many, many states still use
15 they were not written with a writing instrument, 15 those systems, it's very similar to the scholastic
16 like a pen or pencil, they were written with toner, 16 aptitude test, the SAT test, where the students mark
17 or marked with toner. 17 in a bubble. It's the same concept.
18 And they were -- voted the same way down 18 Q All right, sir.
19 ballot for dozens in a row, which seemed to be 19 And so in the lingo of elections, you've
20 virtually impossible. 20 got BMD ballots and hand-marked paper ballots?
21 And they were also not on the correct 21 A Yes. That I think would be true.
22 paper stock for ballots, which is why that watermark 22 Q And from a security standpoint, the

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1 primary difference between them is what? 1 in the 2020 election, and they have since been
2 A Well, from a security standpoint, the QR 2 banned in Georgia because of the security risk that
3 code could contain enough instructions to possibly 3 they proved to be.
4 have malware or at least change the votes that the 4 Q And what security risk is that?
5 voter had actually voted, whereas a mail-in ballot 5 A Well, the evidence has shown that there
6 doesn't have that capability. 6 appears to be significant ballot trafficking
7 So from a security perspective, a mail-in 7 operations around Georgia that were operated and
8 ballot or a hand-marked paper ballot is much more 8 that they were using the boxes. Because when you're
9 secure than a QR-coded selection summary. 9 outdoor in the middle of the night, nobody can see
10 Q Do mail-in ballots, notwithstanding the 10 what you're putting in the box.
11 fact that they are marked by hand, present their own 11 And there's, you know, a variety of videos
12 unique sets of security issues, election security 12 that are out there, we have some of them ourselves
13 issues? 13 that we found, of people -- to give you one example
14 A There are a lot of security issues with 14 there's an individual who is fanning the ballots,
15 the process itself. 15 appears to have about a dozen in his hand, he fans
16 I would say that the mail-in ballot itself 16 them, he takes a picture of them, which we believe
17 is probably -- doesn't present the security issue 17 was because that he was probably going to get paid
18 that a selection summary ballot would have. Not to 18 for them, and then would stuff them into the ballot
19 say that it has none. 19 box one at a time until he got them all in there.
20 Q I think I asked a poor question. 20 So there were trafficking operations that
21 A Okay. 21 were more or less corroborated by the
22 Q The BMD ballot presents a cybersecurity 22 geo-trafficking evidence, the videos that the

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1 issue? 1 counties provided, many of which have been
2 A Yes. 2 destroyed, and the evidence of the counterfeits that
3 Q The hand-marked paper ballot does not as 3 appeared in Fulton County that we discussed.
4 much? 4 All of those are evidence of
5 A That would be my opinion, yes. The 5 trafficking-type operations in Georgia.
6 hand-marked paper ballot does not present -- 6 Q All right, sir.
7 certainly doesn't present the cybersecurity issue 7 Based on your study and analysis of the
8 that a QR-coded ballot presents. 8 2020 election before you got to January 3 of '21, do
9 Q Now, do absentee ballots present other 9 you have an opinion on whether there was any
10 risks of election fraud that votes cast in a polling 10 meaningful evidence of either fraud or irregularity
11 place do not? 11 in the November 2020 presidential election in
12 A Well, I think the other risk and the 12 Georgia?
13 issues with mail-in ballots are how they're 13 A Yes, absolutely, there was -- there was
14 processed, and the lack of transparency in the 14 fraud, irregularities, in twofold, one from the
15 process, more so than the ballot themselves. 15 ballot trafficking -- or the counterfeit ballot
16 So I would say that there are security 16 aspect, the questionable ballots.
17 issues in the process, but not necessarily the 17 But there was also evidence of voting
18 ballot. 18 system malfunctions in Coffee County and Ware County
19 Q All right, sir. 19 where the system cannot tabulate right, they
20 Now, were drop boxes used in the 2020 20 couldn't make it tabulate right. And then there was
21 election? 21 even a vote flipping situation as well.
22 A Drop boxes -- outdoor drop boxes were used 22 Q Where did that happen?

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1 A That was in Ware County. First of all, 1 So it both overcounted and undercounted,
2 there are discrepancies around many, many counties. 2 so they had to certify the machine count -- I'm
3 The one that we just happened to identify was in 3 sorry, they had to certify the hand count, because
4 Ware County, which had, I think, about 1400 votes, 4 they could not rely on the machine count.
5 but it showed -- the full hand count audit, which 5 They raised these issues to the secretary
6 the elections director confirmed was correct, showed 6 of state. We requested along with them and many
7 that the original results, which were published by 7 others a forensic audit on both those two counties,
8 the secretary of state's office in the county, 8 on the servers on those two counties, and secretary
9 indicated that the machines had given in this case 9 of state basically ignored us.
10 for the presidential race, which was the only one 10 Q What are some other circumstances that, in
11 that was audited, they had given Joe Biden an 11 your mind, support your opinion that there was
12 additional 37 votes and subtracted the exact same 12 meaningful evidence -- let me back up a little bit,
13 number from the Donald Trump in that time. 13 withdraw that.
14 So the hand count audit showed, which, you 14 The numbers you've identified, the
15 know, we have trust, showed that discrepancy or that 15 irregular -- the flips and the numbers that you're
16 flip happened. 16 talking about in Ware and Coffee don't seem that big
17 Q So that at least was an error in the 17 relative to the margin. So do they have any
18 machines that was caught by the risk-limiting audit; 18 significance in light of that?
19 is that fair? 19 A Well, actually, they do. Because that
20 A Yes, yes, it certainly was. 20 margin alone in Ware County, even though 37 votes,
21 Q And then what happened in Coffee County? 21 that margin, which is a small county, I think 1400
22 A In Coffee County, they had some very 22 votes total cast, but that margin, which is a

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1 significant problems with the voting system in terms 1 quarter of a percent, was more than the margin of
2 of when they got to the recount. And I'm trying to 2 victory in the presidential race, total.
3 recall, make sure I get the numbers right. 3 Q In percentage terms?
4 But the recount, when they ran the 4 A Yeah. So if you applied that across all
5 recount, if I recall correctly, it added 39 votes to 5 the counties, it would have changed the outcome of
6 the totals, and this is in the presidential race, 6 the race.
7 and for reasons which no one to this day knows. 7 Now, I'm not saying that that happened,
8 And so the elections folks there decided 8 but that's -- you know, it was a very, very tight
9 that, you know, maybe they did something wrong, they 9 race, both in the presidential race and in the U.S.
10 will try it again. 10 Senate race.
11 So in the process of checking everything 11 Q Now, when you were being questioned by
12 that they had done, they found 185 ballots that had 12 Mr. Fox a little while ago, the testimony from the
13 not been cast, or not been counted. 13 California hearing was about rejection rates on
14 Q How many? 14 absentee ballots.
15 A 185. So they put those ballots through 15 What's the significance in any of the
16 the system, and the system did not change the 16 rejection rate -- overall rejection rate for
17 results, it didn't recognize them. It just simply 17 absentee ballots in 2020?
18 printed out the same results that they had before. 18 A So the -- so to back up and explain what
19 So the system overcounted 39 votes on the 19 the signature rejection rate is. So when the
20 original recount. When they tried to do it again, 20 ballots come in, they're in envelopes. And there is
21 it undercounted 185 minus the 39, which is I think 21 a signature on it. And the verification process is
22 about what, 146 or something like that. 22 to verify the signature on the envelope of the

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1 ballot with the signature that's on file. And 1 Now, did Secretary Raffensperger appear on
2 that's the signature verification process. 2 television on November 4 and make a statement that
3 If the signatures appear to match, then 3 figures into your thinking?
4 the ballot is accepted. If not, they have to go 4 A Well, yes, he did, uh-huh.
5 back to the voter, and they give the voter time to 5 I'm not sure how much it figured into my
6 cure that. And I forget exactly what the 6 thinking at the time, but it certainly corroborates
7 notification process is. 7 what I'm saying here.
8 So the typical signature rejection rate is 8 So Secretary Raffensperger was interviewed
9 about 3.5 percent statewide, excuse me. And so in 9 on NBC Today in an interview, and he was -- they
10 other words 3.5 percent of the ballots are typically 10 were questioning him, when are we going to finish
11 found to have some type of a serious signature 11 counting. So this was Wednesday morning of November
12 verification problem, which would require the ballot 12 4, I believe, I think the election was conducted on
13 to be cured. It still can be accepted, but to get 13 November 3.
14 the voter to identify and make sure that that was in 14 And he stated that we were going to be
15 fact their ballot. And there's a process to do 15 finished counting today. We now know that there
16 that. 16 were 4.7 million votes -- voters who voted. We have
17 In fact, I think they are given a couple 17 2 percent left to count, which is about 94,000
18 of days after the election, five days after the 18 votes, and we're going to be done today, by the end
19 election, to cure that, and get their vote counted. 19 of the day.
20 In this case in 2020 to get to your 20 And he knows this because he gets these
21 question, Mr. MacDougald -- and I'll just give you 21 numbers from the counties, so he knew of what he
22 one example. In Fulton County the rejection rate 22 spoke.

Page 1307 Page 1309

1 there was about -- I'm sorry, .34 instead of 3.4, or 1 But at that time, he said it would not
2 3.5. So a whole order of magnitude lower than it 2 change the election results because -- referring to
3 should have been and it's normally been in every -- 3 the presidential race, because at that time Donald
4 you know, in the other counties. 4 Trump had a 103,750 vote lead, and they said are you
5 So we did find out later that Fulton 5 sure about that, and he says we don't guess. Yes,
6 County actually did not perform signature 6 we know.
7 verification in the county. In fact, they admitted 7 However, in reality, the counting kept on
8 to this in a court case in Atlanta, that their 8 going for another two or three days at least, and he
9 machine was not used to do that in the 2020 9 ended up certifying 4.998 million votes, not 4.7
10 election. 10 million. And to this day, we do not know where
11 Q All right, sir. And how did the number of 11 those extra 200,000-plus votes came from.
12 absentee ballots received in 2020 compare to prior 12 MR. MAC DOUGALD: Mr. Chairman, I think
13 years? 13 that's a good place to stop.
14 A The number was just probably multiple 14 PANEL CHAIR HIRSH: Okay. All right.
15 orders of magnitude greater. 15 Well, we'll continue with cross tomorrow, and I
16 We have -- typically absentee ballots 16 thank you very much for your time today. And we'll
17 represent about 10 percent of the vote in Georgia. 17 see you tomorrow morning.
18 But in 2020, due to COVID and other reasons, 18 What else is on tap for tomorrow,
19 absentee ballots were -- and I apologize, I don't 19 Mr. MacDougald?
20 have the exact percentage, but they were well over, 20 MR. MAC DOUGALD: We have this witness, we
21 I believe, 50 percent of the total votes cast. 21 have Edwin Meese, we have Harry Haury, we have
22 Q All right, sir. 22 Heather Honey, the rebuttal witness, and we may have

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1 Mr. Tony Shaffer. And I think that's what we've got 1 CONTENTS
2 but let me -- 2 VOIR
3 MR. FOX: I still have no expert reports 3 WITNESS DIRECT CROSS REDIRECT RECROSS DIRE
4 from Meese or Haury. 4 MARK WINGATE
5 MR. MAC DOUGALD: I am -- I understand 5 by Mr. MacDougald 1020 1047
6 that the Meese report is in Mr. Fox's inbox, and I 6 by Mr. Horrell 1039
7 will tell you candidly, he can beef with us about 7 by PM Mathews 1058
8 that. But Mr. Meese is 92 years old and it's hard 8 by PC Hirsh 1058
9 to rush him. 9 HEIDI H. STIRRUP
10 PANEL CHAIR HIRSH: We'll take that up 10 by Mr. MacDougald 1066
11 tomorrow. Are you done with your direct? 11 by Mr. Horrell 1077
12 MR. MAC DOUGALD: No, sir, I am not done 12 by PM Smith 1079
13 with my direct. It's just a good place to stop. 13 SHAWN A. SMITH
14 PANEL CHAIR HIRSH: About how much more do 14 by Mr. MacDougald 1087/1123
15 you have for Mr. Favorito? 15 by Mr. Horrell 1101
16 MR. MAC DOUGALD: I would say between I'm 16 GARLAND FAVORITO
17 going to say 30 to 45, maybe a little bit more. 17 by Mr. MacDougald 1211/1263
18 PANEL CHAIR HIRSH: Okay. All right. Is 18 by Mr. Fox 1238
19 there anything else we need -- I assume you're going 19

20 to object, but look at the report first and we'll 20

21 talk about that issue, Mr. Fox. 21

22 Is there anything else we should take up 22 -- continued --

Page 1311 Page 1313

1 right now? 1 EXHIBITS
2 MR. MAC DOUGALD: Oh, I would like to 2 NUMBER IDENTIFIED RECEIVED
3 tender R-561 if it's not already in. 3 Exhibit R-561 1064
4 PANEL CHAIR HIRSH: 561? 4 Exhibit R-559 1077
5 MR. MAC DOUGALD: Yeah, that's the EAC 5 Exhibits R-561, R-023, R-208 and R-219 1162
6 Fulton County absentee ballot statistics. I may 6 Exhibit R-071 1182
7 have already done that, and I apologize. I know 7 Exhibit R-166 1183
8 you're looking at it. 8 Exhibit R-178 1183
9 MR. FOX: It's already in. 9 Exhibit R-089 1188
10 MR. MAC DOUGALD: My mistake. It's very 10 Exhibit R-095 1189
11 difficult to keep track of exhibits when you're 11 Exhibit R-099 1192
12 standing here. 12 Exhibit R-101 1193
13 PANEL CHAIR HIRSH: Yes. 13 Exhibit R-221 1193
14 MR. MAC DOUGALD: Okay. That's it. 14 Exhibit R-222 1199
15 PANEL CHAIR HIRSH: We'll see everybody 15 Exhibit R-258 1199
16 tomorrow at 9:30 then. We are in recess. 16 Disciplinary Counsel Exhibit 33 1209
17 (Whereupon, at 5:03 p.m., the hearing was 17 Exhibit R-334 1214
18 adjourned, to be reconvened at 9:30 a.m., on 18 Exhibit R-333 1220
19 Tuesday, April 2, 2024.) 19 Exhibit R-366 1268
20 20 Exhibit R-338 1271
21 21 Exhibit R-018 1273
22 22

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Page 1314
1 CERTIFICATE OF NOTARY PUBLIC & REPORTER
2

3 I, CARMEN SMITH, the officer before whom the

4 foregoing deposition was taken, do hereby certify
5 that the witness whose testimony appears in the
6 foregoing deposition was duly sworn; that the
7 testimony of said witness was taken in shorthand and
8 thereafter reduced to typewriting by me or under my
9 direction; that said deposition is a true record of
10 the testimony given by said witness; that I am
11 neither counsel for, related to, nor employed by any
12 of the parties to the action in which this
13 deposition was taken; and, further, that I am not a
14 relative or employee of any attorney or counsel
15 employed by the parties hereto, nor financially or
16 otherwise interested in the outcome of this action.
17

18 CARMEN SMITH
19 Notary Public in and for the
20 District of Columbia
21

22 My Commission Expires: MARCH 31, 2028

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A 1204:13 adds 1226:13 1131:13 1137:16

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1127:18 1176:21 1296:11 1121:12 1125:13 airplane 1013:11

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1237:13 1242:8 1266:6 1044:19 1047:16,17 1286:1,4,6 1292:10 batch 1186:1,2 1287:17
1285:17,19 1286:4,4,18 1048:8 1049:3 1057:4,6 ballots 1024:13 1026:22 Bates 1258:6 1263:10
1287:1,6,8 1289:4,8,10 1057:14 1059:8 1061:1 1030:7 1031:15,16,20 1264:1,2
1289:13,15 1293:19 1074:1 1084:3 1091:11 1037:1,20 1039:21 battle 1145:3
1295:4,8,11 1296:12 1091:11 1111:4 1113:8 1042:5 1044:4,20 bear 1037:14
1302:5,14,18 1304:7 1126:20 1131:8 1144:5 1049:17 1050:4,22 becoming 1031:19
auditability 1267:9 1160:9 1164:12,15 1051:20 1070:11 beef 1310:7
1269:8 1166:2 1170:3 1180:20 1110:16 1111:2 1178:6 began 1025:1 1214:18
audited 1302:11 1192:11 1211:16 1179:8 1184:8,21 beginning 1070:6
auditing 1141:8 1142:22 1214:14 1215:5,10 1185:13 1186:3 1218:2 1089:21 1151:5
1166:15 1212:9 1242:4 1226:6 1228:19 1239:3 1218:2,4,6,13,15 begins 1044:1

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behalf 1010:4,16 1011:9 1040:12 1041:4 1137:18 1227:3 camera 1109:16 1156:17
1011:17 1012:9 1048:17 1276:11 cameras 1029:5
believable 1072:6 blueprint 1130:11 broadcast 1129:17 campaign 1095:19
believe 1013:13 1030:18 blueprints 1130:16 broadly 1122:11 1098:10 1124:14
1031:7,10 1032:18 Bluetooth 1197:7 broke 1289:13 1151:22
1036:10,11 1040:21 BMD 1225:10 1267:5 broken 1289:4,9 campaigns 1197:19
1044:16 1045:4 1046:7 1296:15 1297:20 brought 1078:14 1080:4 candidates 1292:5,22
1052:16 1059:5 1078:5 1298:22 1082:12,16 1137:5 1293:2
1086:5 1101:21 BMDs 1226:1 1232:13 1250:16 candidly 1310:7
1102:15 1114:13 board 1009:2,6 1021:3,6 1251:3 1287:12 Canon 1111:22
1115:4,5,14 1126:12 1021:8,11,20 1022:3,15 bubble 1297:13,14,17 canvassing 1113:13
1145:15 1149:16 1022:16 1026:8 bucks 1036:4 capabilities 1049:5
1160:5 1161:5 1164:9 1028:11 1030:2,3,12 Buell 1273:5 1089:11 1093:17
1165:6,9 1182:6 1188:6 1031:1,16,17 1032:19 building 1010:12 1033:2 1105:11 1135:10
1194:8 1198:14 1206:1 1033:15 1035:12,13 1176:8 1207:6 1170:7
1207:18 1225:19 1036:15 1041:17,22 bumped 1221:22 capability 1105:14
1239:1 1240:7 1241:5 1043:7 1046:8,10 bundles 1032:7 1141:5 1177:3 1185:9
1244:4 1245:13 1250:8 1056:7,9 1059:20 Bureau 1038:9,13 1191:11,15 1204:7,16
1257:16 1258:10,22 1060:7,11 1062:2,5 bureaus 1135:14 1243:8 1293:6 1298:6
1260:7 1265:2,17 1063:5,15 1231:11 Burnham 1011:11,12 capable 1170:1 1190:14
1269:7,21 1273:8 1233:11,13 1290:21,21 business 1181:20 1212:20 capacities 1068:3
1275:22 1278:2 boards 1233:2,14 capacity 1021:19 1069:4
1284:20 1285:6,7,7 Bob 1148:12 C 1090:11 1091:12
1296:6 1300:16 Borrazas 1012:12 C 1013:1 1312:1 1093:9
1307:21 1308:12 1018:14,20 1084:2 CAD/CAM 1130:17 capitalizes 1140:15
believed 1203:3 1228:20 1086:7 1164:11,13 calculate 1264:14,15,19 capture 1196:19
1237:3 1209:22 1265:11,12 captured 1179:19
Berkeley 1158:9 boss 1094:14 calculated 1264:13 card 1291:16,22,22
best 1019:20 1057:12 bottom 1043:22 1047:18 calculating 1257:17 cards 1027:16,20
1123:10 1241:19 1227:2 1258:3 1258:11 1265:3 care 1283:18
better 1014:10 1067:2,3 bought 1110:6 Caldwell 1011:4 career 1068:11 1105:9
1133:5 1146:16 1203:4 Boulevard 1012:5 California 1088:8 1211:13,13 1212:1
1214:22 1218:11 box 1018:18 1028:19 1128:11 1155:18 1213:9 1240:2 1241:21
1220:9 1279:21 1300:10,19 1224:7 1235:9,10 Carling 1264:17 1265:1
beyond 1197:8 1226:14 boxes 1028:22 1029:1 1245:3 1254:4,15 Carlson 1011:4
Biden 1068:22 1302:11 1299:20,22,22 1300:8 1255:8 1267:2 1305:13 CARMEN 1009:21
big 1025:15 1031:13 branch 1168:12 call 1018:9,12 1031:13 1314:3,18
1047:19 1055:17 branches 1215:18 1032:6 1034:8 1064:3 carrier 1198:1
1133:15 1218:6 Branscomb 1180:15 1064:18 1084:4 1086:6 carrying 1214:19
1220:15 1291:8 breach 1175:11 1198:8 1134:20 1208:6,16 case 1022:19 1027:4,8
1304:16 breadth 1227:3 1210:1,2 1212:7 1216:5 1060:2 1075:21
bigger 1024:19 1041:8 break 1013:22 1083:14 1217:1,2 1219:8,9 1083:20 1100:20,21
biggest 1220:13 1083:21 1143:15 1228:21 1236:20 1101:2,3 1114:14,19
bill 1221:9 1159:15,16 1160:8 1240:14 1282:3 1115:4,5,6,9,21 1116:4
billions 1191:7,7,8 1162:9 1207:8,12 1287:16 1288:2 1116:7,10,11 1150:2
bills 1221:12 1222:16 1209:17 1278:4,14 1291:21 1292:7,16,20 1167:1 1206:18
bisects 1155:22 Brian 1246:19 called 1015:19 1020:6 1230:11,13 1235:3,14
bit 1063:3 1093:16 bridge 1171:4 1021:21 1024:6 1032:2 1250:7,14,16,18,20
1094:13 1133:16 brief 1024:3 1059:6 1065:12 1251:4,6,7,9,18,19,21
1134:1 1144:6 1162:14 briefly 1130:21 1086:22 1089:5,19,20 1252:3,5,8,9,13,20
1184:7 1239:8 1243:5 bright 1158:15 1094:18 1104:2 1253:3 1254:2,4,18
1304:12 1310:17 bring 1166:18 1215:14 1113:12 1129:22 1255:3,9 1260:12,14,20
block 1045:16 1228:18 1250:18 1210:19 1230:6 1261:1,2,4,12 1274:1
blow 1043:15 1262:12 1239:10 1248:16 1276:2,13,14,17,19,19
BlueCrest 1032:2,2,10 British 1096:14 1291:14 1280:8,9,13 1283:2,4
1033:2 1035:22 broad 1093:5 1124:13 calling 1016:7 1133:3 1283:21 1286:13

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1287:12 1288:8 1122:15 1147:14 1065:14,21 1066:2,21 1262:2

1296:10 1302:9 1155:16 1156:6 1067:3 1075:19 1076:4 chance 1017:4 1083:9
1306:20 1307:8 1157:11 1177:13 1076:9,12,18 1077:2 1125:2 1147:7 1205:11
case-in-chief 1017:14 1188:9,13 1189:1 1079:1,4 1082:21 Chandler 1129:2
1122:19 1285:2 1083:8,13,16,20 1084:2 change 1056:2 1141:8,16
cases 1022:19 1095:4 certifications 1099:14 1084:4,6 1085:3,13,18 1180:16 1185:19
1233:4 1254:13 1260:9 1113:18 1114:3 1086:2,8,12,13,18 1186:3 1257:17
1260:11 1261:7,8,10 1146:19 1147:13 1087:2,5,8,10 1101:11 1258:11 1265:3
cast 1022:6 1179:19 1280:20 1116:22 1117:10 1269:15 1288:20
1217:18 1237:6 certified 1060:18 1119:2 1121:17 1122:1 1297:8,8 1298:4
1244:11 1292:17,19 1128:12 1134:10 1122:4,7,21 1123:4 1303:16 1309:2
1293:19 1299:10 1146:3 1147:3 1150:13 1132:1,15 1133:1,18 changed 1096:22
1303:13 1304:22 1180:10 1195:5 1196:2 1143:17,20 1144:2 1141:17,21 1142:1
1307:21 1196:3,18 1253:18 1146:6,13 1154:1,6,12 1305:5
catalogue 1092:4 certify 1022:3,18 1028:11 1160:11,18 1161:1,6,11 changes 1104:15 1141:10
catastrophic 1205:16 1035:17 1039:19 1161:15 1162:5,9,13,17 1184:16 1188:21
catch 1181:18 1040:1,14,18 1041:11 1162:20 1164:7,11,14 1221:11
category 1138:11 1152:6 1042:4,21 1043:19 1182:20 1183:3,11,15 changing 1141:11,12
caught 1302:18 1045:6,7,13,22 1058:2 1183:19 1187:18,21 characterize 1118:1
cause 1087:18 1101:21 1060:8 1061:14 1120:1 1189:19 1192:2 1193:2 characters 1111:5
1103:21 1175:2 1253:18 1304:2,3 1193:18 1198:16 charged 1125:18
caused 1041:10 1314:4 1199:1,6,10 1200:2,17 CHARLES 1011:11
caution 1186:7 certifying 1031:14 1201:1,14 1206:15,21 charles@burnhamgor...
CBS 1173:10 1035:8 1062:9 1180:18 1207:8,12 1208:10,13 1011:16
cellular 1197:7 1309:9 1208:22 1209:8,12,17 charm 1271:13
center 1027:2 1090:6 certiorari 1100:22 1209:21 1210:4,10,14 check 1135:1 1242:22
1138:21 1149:1 cetera 1025:7 1070:12,12 1210:21 1211:4 1214:6 1287:17 1291:18,20
1235:22 1283:6,14 Chad 1149:8,14 1220:21 1225:19 checked 1289:2
centers 1055:18 1138:20 chain 1026:9,19 1027:18 1226:3,9 1238:4 1253:1 checking 1288:7 1303:11
central 1110:7,8 1282:4 1027:19 1028:7,13 1256:22 1257:19 Chen 1260:11,12,20
1282:17 1096:1 1097:6,13,16,18 1258:2 1262:5,22 1261:1,2
centralized 1027:1 1098:3,6 1117:18 1263:4,19,22 1267:21 Cheyenne 1092:6
centrally 1281:19 1122:12 1131:19 1268:5,12,17,20 chief 1067:11 1069:8,10
centrals 1179:13 1132:7 1134:16 1270:20 1271:1,15,21 1127:13
CEO 1102:11 1151:11,18 1153:2,4,16 1273:17 1274:4 1276:6 Chiefs 1093:13
certain 1031:18 1109:10 1168:9 1169:2 1174:11 1278:6,13,18 1279:5,10 Children 1068:6
1123:15,16 1138:16 1191:1,2 1194:12,16 1279:14 1280:3 children's 1192:20
1159:4,10,22 1176:5 1203:10 1205:20 1309:14 1310:10,14,18 China 1097:5 1098:8
certainly 1026:12 1218:11,12 1219:13,17 1311:4,13,15 1121:13 1136:1
1028:16 1030:3 1289:4,9,13 chair's 1085:5 Chinese 1135:19
1033:15 1039:17 chains 1204:3 chaired 1152:21 1247:6 chip 1130:18
1040:10 1058:1 chair 1009:17 1013:2 chairman 1013:10 chips 1097:11
1062:20 1063:1 1073:1 1014:2,7,10,17 1015:15 1015:17 1017:10 choice 1137:3 1186:11,12
1122:20 1206:2 1016:6,9 1017:19 1020:15 1022:15 choices 1179:10,18
1269:15,18 1299:7 1018:5,11,18 1019:2,5 1065:4 1077:7 1079:3 1180:6
1302:20 1308:6 1019:8,9,12,16 1020:1 1083:11 1087:13 chop 1133:16
certificate 1211:18 1020:8,11 1035:16 1143:14 1160:7 chose 1239:11
1238:17 1314:1 1039:9 1043:2 1046:18 1162:21 1164:19 Chretien 1067:16
certification 1021:21 1046:22 1047:5,7 1187:16 1188:2 1210:5 Chris 1148:13,18 1149:8
1022:8,12 1023:1,6,12 1049:20 1050:7,13 1211:7 1220:19 1149:16
1023:14,20 1026:14 1051:13,17 1052:14,21 1222:21,22 1223:1,1 circles 1277:10
1028:15 1031:4 1053:2 1054:2,3,8 1225:11 1280:17 circuit 1114:16 1116:11
1035:10,11,19 1042:14 1058:6,9,16,19 1059:13 1309:12 1129:21 1130:1
1045:10 1060:10,15 1059:14,17 1060:6 chairperson 1022:16 1131:22 1132:4
1061:10 1113:22 1063:13,18,21 1064:6 challenge 1220:6 1174:17
1114:8 1118:13 1064:12,15,21 1065:3,8 challenged 1251:13,16 circuits 1097:2 1130:11

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1130:13 1175:1,1 Coffee 1301:18 1302:21 1151:22 complicated 1275:22

circumstance 1028:20 1302:22 1304:16 committee 1009:3,16 comply 1085:5 1120:18
circumstances 1120:22 cofounded 1215:5 1010:2 1016:17 1019:9 component 1032:11,17
1166:2 1304:10 cofounder 1230:7,8 1023:20 1026:18 1032:22 1040:11
CISA 1137:7,16 1138:21 1251:20 1059:20 1065:4 1041:4 1048:16
1139:17 1143:7,11 collected 1208:6 1086:14 1088:20 1131:15 1151:16,17
1161:9 1168:20 colloquial 1167:21 1126:2 1148:6 1152:16 1177:14
1169:17,18 1187:2 colonel 1088:17 1145:9 1152:21 1158:8 1201:8 components 1026:21
1190:19 Colorado 1104:2,10,13 1208:6 1210:5 1213:21 1057:22 1097:3,15,17
CISA's 1138:10 1205:13 1111:4 1113:12,14 1217:5 1221:9,16 1098:17,18 1104:6
cite 1276:15 1177:12 1178:5,7,7,11 1222:13,15,16 1223:1,2 1125:10 1128:13,14,15
cited 1277:17 1179:1,9,13 1180:10,10 1223:11 1236:15 1129:1 1131:16,17
citizens 1104:1 1180:15,18 1270:21 1279:3,8,19 1135:15 1137:5
civilian 1094:15 1107:1 Columbia 1009:1 1291:8 1167:18 1196:18
claim 1143:11 1314:20 committees 1221:3 1203:13 1265:16
claimed 1230:22 1289:21 combat 1089:10 communicate 1170:20 1266:2 1267:11,15
claims 1100:11 1122:16 come 1026:2 1057:5 1172:12 1274:13 1291:7,8
clarification 1081:20 1066:8 1092:5 1110:4 communicating 1189:13 comprehensive 1141:7
clarify 1121:20 1270:22 1139:12 1211:16 communication 1117:20 1142:21 1166:19
1271:2 1222:9 1232:12 communications 1075:4 1203:5
clarifying 1220:6 1249:11,13 1266:3 1075:7,12 1091:8 comprise 1098:17
Clarity 1294:4 1305:20 1172:21 compromise 1095:20
Clark 1009:7 1017:16 comes 1085:19 1248:15 communities 1126:8 1096:10,20 1131:4,16
1058:13,14,21 1075:13 comfortable 1035:7 community 1134:21 1131:19 1135:11
1075:15 1121:4 coming 1013:11 1024:18 1152:10 1202:18 1140:9 1141:2 1142:9
1198:21 1199:3 1027:20 1036:12 community's 1205:19 1156:4 1167:20 1169:3
1207:20 1208:16 1065:2 1070:8 1073:8 companies 1111:19 1169:3,9,18,20,21
1269:16 command 1027:19 1129:1 1212:5 1191:1,2 1198:2 1282:4
clean 1025:22 1041:1 1089:3,8,11 1090:5 company 1112:20 compromised 1124:11
1232:5,10 1092:2 1177:7 1167:16 1125:3 1151:13,19
cleaner 1220:5 comment 1034:5,10 comparable 1110:1 1168:5,10 1169:2
cleaning 1232:11 1048:14 1057:14 1150:22 1251:20 1176:17 1202:20,20
clear 1031:19 1036:5 1119:14 compare 1290:12 1203:1 1204:9
1059:18 1063:10 commented 1062:2 1307:12 compromises 1136:3
1077:13 1109:12 comments 1165:11 compared 1104:14 1138:19 1167:18,22
1178:14 1179:10 1279:11 1109:17 1121:14,15 1168:9 1174:11
1244:22 1280:6 commercial 1094:5 1174:2 1241:21 1204:20
clearly 1057:12 1202:10 1171:5 comparison 1104:14 compromising 1095:6
1218:10 1260:22 commercially 1171:18 compartment 1092:7 1175:12
1273:10 commission 1105:1 complete 1050:5 1051:1 computer 1089:17,19
close 1022:8 1125:17 1126:3,4,12,18 1212:11 1218:22 1097:3,3,11 1103:4
closer 1084:7 1294:8 1134:11 1150:14 1253:19 1266:7 1110:8,9 1127:13,16,18
coalition 1231:3 1251:2,3 1152:19 1165:10 completed 1103:1 1128:14 1130:22
code 1120:19 1129:17 1195:17 1196:14 1220:17 1131:7 1132:3 1145:10
1140:16 1142:11 1227:13,13,14 1228:10 completely 1180:2 1174:7 1175:7 1211:19
1179:11,21 1180:2 1245:14 1246:15,17 1195:2,3 1242:9 1212:1 1214:17
1184:10,11,19,22 1247:3,6,7 1268:10 1276:20 1280:16 1238:17 1239:1,3,5,21
1185:14 1186:8,10 1269:4 1270:5 1271:5 1289:11,14 1240:11
1217:20 1275:11 1271:10 1272:19 complex 1090:9 1094:4 computer-based 1090:10
1293:4,5,9 1296:17,18 1314:22 1095:18 1112:14 1190:17
1296:22,22 1297:1,3,6 Commission's 1188:9 1124:13 1190:17 computerization 1094:3
1298:3 commissioned 1246:18 1197:18 1097:1
codes 1178:6 1184:8,21 commissioners 1031:17 compliance 1108:12 computerized 1099:1
1185:12 1186:6 1148:14 1189:5 1233:4 1197:12 1123:21 1150:21
1296:16 commissions 1155:21 compliance-based 1155:14 1203:18
coding 1089:22 1090:2 committed 1078:16 1134:21 computers 1096:19

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1097:22 1127:9,11,18 configured 1110:13 contexts 1076:20 1201:4 1216:4 1222:11

1127:19,22 1128:15,17 1128:18 continue 1164:17 1296:8 1222:14 1238:18
1132:12 1135:16 confine 1017:11 1309:15 1240:9 1241:4,11,15
1136:4 1170:18 1171:4 confirm 1289:19 continued 1010:22 1244:14 1245:12,22
1171:20 1172:2 1177:7 confirmed 1287:2 1302:6 1011:1,22 1012:1 1250:17,22 1251:10,14
1197:4 confirming 1054:7 1025:14 1090:17 1251:15 1253:10
CON 1136:12 1137:6 confused 1051:9 1200:13 1123:11 1164:20 1254:5 1258:19
concentrated 1112:14 1270:10 1262:10 1312:22 1260:17,18 1263:20,21
concept 1106:17 1297:17 confusion 1037:11 continuing 1045:11 1265:13 1276:1
conceptual 1173:6 Congress 1145:7 1235:22 continuity 1182:14 1279:13 1292:15
concern 1024:21 1025:12 conjunction 1077:21 contract 1155:20 1295:21 1296:14
1049:12 1072:3 connect 1080:1 1172:19 contractor 1124:7 1302:6
1214:16 1222:2 connected 1018:16 1175:16 1176:4,16 corrected 1200:4,15
1241:13,19 1245:19 1098:4 1150:2 1170:19 1198:9 1207:22
1246:1,2 1177:9 1294:10,14,18 contractors 1094:22 correctly 1044:8 1056:20
concerned 1040:22 connectible 1197:6 1202:16 1087:6 1241:14
1056:16 1068:18 connection 1097:22 contrary 1120:6 1258:18 1303:5
1070:5 1242:2 1098:5 control 1089:15 1092:2,3 corroborated 1300:21
concerning 1117:16 connections 1172:1,1 1129:18 1136:19 corroborates 1308:6
1232:1 1236:9 1196:17 1158:18,18 1166:16 corroborating 1272:16
concerns 1068:15 1069:3 connectivity 1294:16,20 1171:6 1174:20 1175:8 corrupted 1143:2
1069:17 1071:1 1081:8 CONs 1136:13,16 1175:19 1177:3,5,7 corruption 1113:11
1240:16 1243:12 consensus 1272:2 1282:5,8 1157:20
1249:7 1275:5 1284:10 consequences 1205:15 controls 1166:12 1167:3 cost 1035:22
concluded 1021:8 consider 1190:12 1226:5 council 1148:11,11,15,16
1033:16 1279:17 1227:18 1242:10 controversies 1280:1 1149:6
conclusion 1124:22 1262:7,8 1271:15 convention 1136:14,14 counsel 1010:10,16
1267:6 1280:10 1275:17 1281:1,6 conversation 1079:10 1043:1 1060:1 1063:15
conclusions 1160:4 1286:15 1082:6,7 1083:4 1085:6 1101:16
1267:4 consideration 1153:19 conversations 1040:6 1122:18 1148:2
conclusive 1261:13 1271:7 1272:21 conversion 1111:5 1160:19 1161:21
concrete 1175:6 considered 1122:10 1212:11 1209:2,6,15 1252:18
conditioning 1176:4 1158:13,15 1166:12 convince 1187:4 1255:15 1256:15
conduct 1039:20 1080:13 1171:6 1214:15 convincingly 1119:19 1259:2,5,22 1262:13
1114:3 1238:1 1241:6 1217:16 1269:6 Cook 1110:21 1264:17,22 1265:1
conducted 1072:4 1104:8 considering 1270:18 coordinated 1236:1 1270:16 1313:16
1107:15 1220:1 consistently 1125:8 1237:14 1314:11,14
1229:17 1275:18 conspiracy 1121:7 Coordinating 1148:10,15 counsel's 1075:21 1127:4
1287:6 1289:16 constantly 1172:19 1148:16 1149:6 count 1061:3,16,16,17,18
1308:12 1284:13 copies 1256:20 1235:17,22 1236:9,10
conduction 1175:4 Constitution 1216:5 copy 1043:2 1074:12,14 1236:13,17,18 1287:1
conference 1232:14 1236:3 1238:11,12 1074:14 1256:19 1289:19,20 1290:4,11
conferences 1136:8,12 constitutional 1044:17,18 1258:6 1261:19 1290:11 1291:2 1295:1
1215:2 constitutionally 1230:17 copying 1219:12 1295:4,11 1297:5
confidence 1143:4 1159:5 1238:15 1274:12 corner 1285:6 1302:5,14 1304:2,3,4
1159:10 1187:6 consumer 1097:8 corporate 1212:20 1308:17
1191:19,20 1244:17,19 contact 1038:6 Corporation 1112:12 counted 1035:1 1037:1,7
confident 1015:11 contacted 1038:18 correct 1015:1 1046:9,12 1037:7 1062:7 1241:14
1016:17 contain 1296:20 1297:6,7 1046:15 1066:10 1265:20 1287:14
confidential 1139:20 1298:3 1071:22 1078:3 1296:13 1303:13
confidentially 1138:19 contained 1228:2 1079:19,22 1080:12,14 1306:19
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1126:21 1134:2 1136:6 small 1091:15 1130:13 1041:16 1043:15 specifically 1071:3
1139:15 1144:11 1171:20 1212:20 1046:20 1047:7 1051:6 1078:4 1103:7,10,17
1145:19,22 1146:22 1304:21 1052:13,21 1064:8,11 1115:8 1117:3 1137:17
1147:18 1148:3 1152:4 smaller 1130:14 1159:2 1067:5 1077:1,4 1083:3 1224:4

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speech 1122:3,5 1215:10,11 1216:8 states 1017:13 1072:19 strategy 1125:5 1148:21
speed 1244:3 1241:6 1079:17 1080:3,4 1194:22
spell 1065:17 1210:22 starting 1043:16 1067:10 1081:18 1087:20,21 stream 1084:3
spelled 1087:5,8 1067:21 1158:6 1088:15 1096:12,16 Street 1010:11 1011:13
Spencer 1066:20 1067:16 1257:13 1098:7,19 1103:8,11 strength 1272:3
spends 1191:7 starts 1259:3 1106:12,16 1107:5 strenuous 1239:9
spent 1049:17 1070:19 state 1020:8 1024:9 1108:19 1109:1,5 strict 1276:5
1088:15 1112:11 1030:9 1031:2 1044:17 1112:21 1134:10 strike 1127:14
1124:7 1051:5 1052:3 1065:14 1138:8 1139:19 structure 1129:18 1148:9
spoke 1308:22 1072:13 1080:19 1145:20 1150:13 structured 1136:7
spoken 1058:20 1087:2 1088:8 1099:8 1151:20 1155:11,19 1140:12
spread 1198:6 1100:12 1101:8 1158:20 1168:13 students 1297:16
springing 1017:5 1104:12 1106:13 1195:5 1196:2 1214:21 studied 1118:12 1196:6
SQL 1111:6 1140:5,7,8,9 1107:20 1115:7 1218:5,19 1228:7 1235:16 1236:12
1140:9,15,17,17,20,20 1119:22 1120:13 1234:2 1282:12,12 studies 1247:20,21,22
1140:22 1142:9,17 1121:12 1126:13,16 1294:6 1297:14 1248:4
1143:7,11 1161:7 1135:20 1145:4,7 statewide 1214:15 study 1301:7
square 1297:2 1149:3 1153:20 1155:7 1236:20 1285:5 1306:9 studying 1236:17
staff 1026:20 1051:3,4 1155:22 1157:3 stating 1082:14 stuff 1085:9 1280:4
1067:11 1069:8,10 1168:13 1178:5 statistical 1158:11 1300:18
1093:14 1127:14 1180:11,15 1192:15,17 1159:1,4,8,10 style 1292:2,7,12
1157:10 1206:2 1210:21 statistics 1064:5 1158:10 styles 1292:4
stakeholder 1126:6 1216:18 1221:3 1311:6 subcommittee 1221:19
stand 1013:21 1064:18 1222:17,19 1231:10,10 statute 1152:13 1222:22
1115:2 1133:8 1164:4 1231:11 1233:3,3,15,18 statutory 1152:14 subject 1123:5 1135:5
1200:4 1210:3 1234:4,13 1237:4 stay 1094:17 1138:16 1145:6 1160:1
standard 1134:11 1135:3 1246:19,22 1247:5 stayed 1068:1 1175:11 1206:14
1150:14 1194:16 1249:5,6 1254:15 steal 1213:7 1219:8 1248:10
1195:6 1196:3,3 1269:6 1283:7,16 steganographically 1276:20 1279:11
1241:19 1244:4 1284:3,21 1289:21 1184:12 1282:2,14
1255:19,20 1290:21,21 1294:6 steps 1143:5 1198:11 subjective 1055:6,15,19
standards 1104:21 1304:6,9 stick 1127:12 1294:2 subjects 1118:17 1246:20
1119:20 1134:9,12,14 state's 1038:4 1060:12,16 sticking 1156:16 submit 1271:4
1134:20,21 1150:11 1281:19 1283:5 1284:2 sticks 1293:18 submitted 1245:13
1151:8 1152:13,17 1286:2 1288:1 1289:7 stimulate 1063:14 1246:5,6 1271:6,8
1194:9,20 1195:7,16 1302:8 stimulation 1175:2 1273:5,8
1196:4 1197:11 state-specific 1128:10 Stirrup 1013:9 1064:18 subordinate 1192:16
standing 1311:12 stated 1031:8 1042:4,11 1065:1,11,16,20 1066:5 subsector 1138:9 1181:18
standpoint 1118:22 1042:14 1045:14 1077:11,13 1079:9 1182:4,7
1172:18 1196:16 1048:9 1055:13 1082:22 1312:9 subsectors 1181:20
1197:12 1297:22 1062:19 1116:5 STO 1089:6 subsequent 1025:6
1298:2 1157:18 1272:17 stock 1139:5 1146:18 1122:16 1231:7
stands 1215:6 1308:14 1295:22 substantial 1128:3
Stark 1158:8,9 1159:7 statement 1017:20 stood 1102:3 1155:14 substantively 1279:15
1165:1 1273:10 1286:9 1022:6,17 1040:6 1207:22 substrates 1174:22
Stark's 1158:7 1048:21 1147:5,12 stop 1045:19 1133:12 subtracted 1302:12
start 1013:5 1018:15 1148:5,6,9 1149:7,15 1185:22 1186:2 1229:7 success 1095:15 1219:1,4
1083:14 1154:21 1149:16,18 1150:7 1237:10 1290:5 1220:4
1155:6 1170:11 1161:9 1209:3 1253:19 1309:13 1310:13 successes 1242:13
1171:19 1185:22 1254:12 1279:12 stopping 1262:18 successful 1140:22
1186:1,2 1308:2 stops 1186:12 1142:17 1143:8,12,13
started 1018:20 1021:7 statements 1080:1 storage 1170:2 1189:6 1219:16,20
1025:1,5 1083:15 1099:17 1100:7 stored 1110:1 1130:21 1220:16 1250:17
1101:19 1102:6 1119:14 1146:2,22 1139:21 1285:9
1104:11,18,20 1127:10 1147:19 1149:8 story 1133:6 1167:12 sudden 1142:3

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suffice 1285:16 1060:15 1063:9 1071:6 1185:15,20 1186:10,12 1136:16,21 1137:2

sufficiency 1190:6 1077:4 1084:8 1089:1 1186:13 1188:9,20 1140:9 1145:1,14
sufficient 1190:21 1262:3 1093:15 1101:11 1189:2,7,7 1190:16,17 1146:2,20 1147:9,17
1285:12 1106:8 1108:9 1115:10 1191:13,14 1193:10 1149:22 1150:1,5,9,11
suggested 1081:5,10 1115:18 1116:17 1194:3,15,15 1195:4,14 1150:21 1151:7 1152:7
1256:2 1126:9 1133:3 1140:3 1195:15,20 1196:4,7,18 1155:13,17 1156:2,7
suggestion 1013:21 1161:4,17 1164:15 1196:20 1198:7 1157:11,19,19 1158:12
suing 1231:10 1173:19 1209:3 1210:8 1199:17 1201:10 1159:9 1168:5 1169:6
suit 1231:4 1211:1 1212:1 1218:13 1202:4 1203:12,12 1171:7,19 1175:5,17,19
suite 1011:5,13 1012:5 1225:7 1226:13 1229:8 1205:7 1213:3 1214:16 1177:3,5 1178:12,14,18
1128:3,6 1156:5 1157:5 1239:17 1245:4 1215:15 1216:17 1179:1 1185:6,10,22
1167:17 1178:9,16,21 1251:15 1254:17 1217:8,16,17,19 1187:7,9 1190:22
1180:17 1196:18 1261:12 1262:1 1268:2 1223:22 1224:17 1191:9,10 1196:1,15
1234:1 1276:22 1291:11 1225:10 1227:5,15,19 1202:20 1203:2,7,8,19
suited 1197:14 1294:9 1303:3 1306:14 1227:19 1228:19,22 1204:1,7,19 1205:1,21
summary 1157:4,10 1308:5 1309:5 1229:1 1230:17,18 1212:2,3,6,8 1214:19
1213:22 1217:6 surprise 1016:22 1231:1,5,6 1232:21 1216:19 1233:18
1223:19 1274:22 surprised 1070:18 1234:1 1238:3 1240:12 1237:22 1240:13
1277:13 1292:16,16,20 1072:15 1241:2,17,20 1242:7,22 1243:8 1249:7 1267:5,8
1298:9,18 surrounding 1052:5 1243:16 1251:9,12,16 1270:18 1272:9
Sunspot 1168:1,2 1099:1 1266:6,12,17 1267:15 1282:13 1283:7,15
1169:14 surveillance 1029:5,13 1269:5,15 1270:17 1285:14 1297:15
Supernova 1168:2,6 1029:14 1030:1,11 1271:7 1272:4,7,8,20
1169:14 1091:3 1274:8,12 1275:4,7,10 T
supervised 1155:21 susceptible 1266:1 1275:16 1277:20 T 1152:16 1312:1,1
supplied 1022:7 Suzi 1296:4 1280:21,22 1281:5,9,18 1313:1
supplier 1175:17 swear 1019:12,17 1065:5 1282:2,17,22 1283:6 tab 1247:21
supply 1096:1 1097:6,13 1065:7 1086:14,15,17 1284:18 1286:11 table 1030:7 1141:15
1097:15,18 1098:3,6 1210:6,10 1287:2 1288:3 1289:12 1166:2 1269:8 1288:10
1117:18 1122:12 swearing 1019:10 1290:17 1291:8,9,11,12 1288:11
1131:19 1132:7 swirling 1071:9 1293:3,6 1294:16,17 tables 1287:12,13
1134:16 1151:11,18 switch 1226:5 1301:18,19 1303:1,16 tabulate 1293:20 1301:19
1153:2,3,16 1167:14 sworn 1065:13 1087:1 1303:16,19 1301:20
1168:9 1169:2 1174:11 1164:5 1210:20 1314:6 systems 1089:16 1090:3,8 tabulated 1237:7
1191:1,2 1194:12,16 symposium 1110:21 1090:9,10,12,14,19 tabulation 1293:15
1203:10 1204:3 system 1032:1 1035:22 1091:4,7,19 1092:5,16 tabulator 1111:1,6,7
1205:19 1091:22 1092:1,2,3 1093:6,11,20,22,22 1184:20
support 1097:19,20 1096:6,8,10 1097:18 1094:8,12 1095:5,14 tabulators 1179:12
1128:16 1304:11 1099:6 1104:21 1096:21 1097:3 tactic 1140:8
supporters 1232:8 1107:16 1108:14,15 1098:18 1099:2,6,13,15 tactics 1167:22 1170:7
1233:12 1110:14,15 1114:4,11 1101:8 1104:5,19,22 tag 1173:1,1
supporting 1124:7 1118:10,19 1120:14,18 1106:1,8,16 1107:15,21 tailored 1085:4
1158:11 1123:17 1126:10 1108:13,22 1109:1,7 take 1013:21,22 1029:16
supports 1087:19 1127:17 1129:16 1110:4 1111:16 1044:10 1072:22
supposed 1015:6 1034:17 1132:3 1134:8,9,10,13 1112:15 1113:10,17 1083:14,21 1085:18
1037:12 1041:20 1134:14,15,19 1135:1 1114:8 1115:7 1117:20 1103:6,10 1109:16,20
1055:1,4 1056:6 1150:1 1140:17,19 1141:4,19 1117:21 1118:5,7,11,11 1123:8 1165:22
1200:18 1142:10,16 1145:1 1118:14,21 1119:8 1173:17,17 1178:2
supposedly 1029:6 1146:4 1147:3,4 1120:1 1121:16 1203:8 1213:6 1256:9
1035:15 1150:12 1151:3,15,17 1122:14 1123:21 1256:15 1276:16,16
Supreme 1100:22 1152:18 1153:14,16,21 1124:5,18,18,19 1125:1 1277:2 1278:4 1279:19
1116:15 1230:21 1155:8,12,15,20 1156:1 1125:14,15 1126:15 1283:18 1292:1,9,9
1250:10 1156:6 1157:2,5,15 1127:2,6,8,22 1128:2,6 1293:3,9,14 1294:2
sure 1020:3 1024:7 1174:19 1175:8 1176:4 1128:16 1129:3,7,13 1310:10,22
1026:17 1041:17 1176:6,17 1177:14 1131:4 1132:8,11,12 taken 1023:10 1048:13
1045:1 1049:20 1178:21 1180:14 1135:4,5,12,16 1136:8 1096:14 1124:10,11,14

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1136:16,17 1140:2 1117:22 1120:5 1128:4 1278:20 1311:3 1016:5,16 1017:2,2,15

1287:20 1314:4,7,13 1140:3 1152:14,15,20 tendered 1161:13 1018:3,6 1019:13,17
takes 1151:3,5 1190:16 1157:8,8,9,13,18 1198:14 1058:13 1065:6
1293:16 1300:16 1175:14 1236:5 1255:5 tendering 1209:13 1083:17 1085:1,9
talk 1016:4 1049:21 1256:4 tense 1259:11 1086:16 1116:17
1069:14 1071:5 1109:8 technicality 1254:8 term 1021:5,7 1167:21 1117:16 1118:6
1133:9 1159:15 1259:2 1291:3 1119:12 1121:8,21
1206:17 1265:14 technicians 1033:1 terminology 1181:17 1123:7 1154:13
1267:13 1286:19 technique 1158:17 terminus 1032:1 1206:17 1210:7 1214:1
1310:21 1259:14 terms 1027:16 1040:5 1221:14 1222:13
talked 1031:8 1069:8 techniques 1095:19 1041:2 1063:1 1092:20 1225:15 1232:15
1085:19 1188:12 technology 1095:21 1186:16 1303:1 1305:3 1255:7 1262:9 1264:11
1217:11 1270:12 1152:1,13 1160:2 terribly 1046:20 1047:7 1290:8 1305:12 1314:5
1273:22 1281:3 1182:3 1211:14 test 1090:6,8,22 1091:16 1314:7,10
1296:15 1213:19 1214:19 1092:18,19 1094:17 testing 1090:16 1091:6
talking 1028:6 1071:7 1216:17 1217:8 1227:3 1104:20 1114:6,6 1091:13,18 1092:9
1108:6,10,10,13 1113:4 1227:6 1228:5,7 1118:2 1124:8 1128:4,9 1093:8,10,17 1094:8,11
1113:10 1154:10 1232:21 1234:4 1128:9 1132:6 1158:22 1104:8 1108:12,15
1160:17 1165:1 1241:20 1259:14 1159:3 1189:10 1109:1 1110:15 1112:4
1181:15 1202:21 1281:8,9 1289:12 1197:13,14 1203:10 1114:4,5,8 1118:1,4,13
1217:13 1234:20 telecommunications 1242:8 1297:16,16 1119:20,22 1134:21
1248:2 1250:19 1253:3 1142:12 tested 1094:1 1108:4 1135:6 1147:1,3,4,8,14
1280:2 1283:22 telephone 1059:7 1130:2,21 1195:5 1151:9 1155:15 1159:1
1304:16 television 1030:10 1308:2 1203:19 1159:2 1188:9,13,20
tallies 1159:8,11 tell 1014:21 1019:21 testified 1015:8,10 1189:3,8 1190:15
tally 1287:18,19 1288:22 1023:19 1051:16 1016:10 1018:1 1020:7 1195:8 1203:12,13,14
tap 1013:6 1309:18 1056:13 1069:7,21 1037:5 1039:18 1212:9 1242:5
tape 1029:13 1030:1,11 1072:1 1114:9 1123:19 1065:13 1087:1 tests 1092:17 1203:12,21
tapes 1029:14 1126:2 1133:6,13 1100:16,18 1101:3 Texas 1153:20 1154:10
target 1140:16 1144:13 1148:6 1156:21 1158:8 1102:14 1114:12,13 1154:17 1155:7,18
1144:18 1145:13 1178:2 1191:9 1195:12 1115:16,17 1116:2,3 1156:1,7 1157:3,11,14
1175:10 1176:15,16 1208:5 1210:12 1212:4 1118:12 1119:16 1177:19
1198:8,12 1212:5 1213:21 1217:5 1122:19 1164:5 text 1179:10,11,17,18
Target's 1175:16 1221:16 1236:15 1210:20 1221:3,18 1180:3 1184:17
1176:19 1245:14 1246:9,12 1222:21 1235:5,7,8 1221:16 1275:14
targeted 1168:4 1266:20 1272:6 1240:7 1249:22 1293:6,8
task 1050:5 1051:1 1286:21 1291:8 1295:7 1251:19 1252:2 1254:4 TGDC 1152:16 1153:11
1094:20 1187:3,4 1310:7 1254:13,18 1256:7 thank 1013:2 1020:11,14
1224:8 1226:11 1267:3 telling 1169:19 1200:17 1259:11 1260:9 1261:1 1028:4 1033:9 1039:7
tasked 1089:16 1200:20 1204:22 1261:9,14 1270:11 1058:12,15 1060:5
taught 1249:2,4 tells 1114:2 1273:6,9,11 1285:17 1063:18,22 1065:2,21
teaching 1249:5 temperature 1175:20 1286:3,12 1066:2 1067:4 1082:19
team 1091:16 1095:9 temporary 1055:17 testify 1017:7 1085:20 1083:1,21 1084:3
1168:4 1198:10 tended 1284:20 1100:19 1114:22 1087:10,13 1123:10
1283:13 tender 1064:4 1076:22 1115:9,12,21 1116:6 1144:7 1162:20
teams 1095:17 1098:14 1101:6 1160:15 1118:17 1120:8,9,15 1164:14,18 1183:21
1129:6 1131:2 1135:9 1182:18 1183:17 1123:5 1221:8,21 1188:2 1200:5 1206:3
1169:15 1170:6 1177:1 1187:16 1189:17 1222:17 1223:3 1225:7 1206:10 1207:1,11
1177:2 1288:15 1191:22 1192:22 1250:4,13 1251:4,5,18 1209:19,21 1211:4,7
tears 1122:5 1193:15 1198:19 1251:21 1252:9,10 1214:8 1223:8 1245:11
technical 1075:20 1088:5 1199:4,8,19 1200:15 1253:21 1254:3,6,10,21 1263:11 1273:20
1089:5 1090:18 1209:10 1214:4 1255:21 1256:5 1278:15 1309:16
1091:14 1092:15,22 1220:19 1224:12 1269:17 1273:1 thanked 1283:17
1104:18 1105:11 1237:21 1267:17 testifying 1101:1,19 theory 1121:7 1138:22
1107:14 1108:4 1269:12 1270:8 1235:13 thermostat 1121:6
1110:10 1112:5,8 1271:13 1273:13 testimony 1015:9,19 1171:16 1174:8,9

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thing 1014:22 1024:6 1243:18 1246:4 1247:6 1129:5,5 1137:10 1302:13 1306:5 1308:6
1031:12,13 1033:13 1247:18 1249:17,20 1147:8 1150:15,17,18 1309:1,3,16
1047:12 1059:4 1063:4 1250:12,19 1252:2,15 1150:20 1185:10 timeline 1225:22
1085:7 1096:1,19 1257:20,22 1258:2 1191:16 1197:2,15 times 1016:1 1036:18
1109:2 1127:3 1133:7 1261:13,13 1262:2 1223:13 1060:19 1062:7
1169:22 1175:21 1263:12,19 1265:11 three 1021:14,16 1035:17 1106:22 1130:14
1179:6 1228:4 1235:13 1267:18,19,22 1269:19 1061:19,20 1062:7,8 1133:11 1150:19
1243:10,12,20 1259:17 1270:15 1273:6,8 1071:18 1110:22 1170:5 1230:6 1243:10
1286:8 1290:3 1291:19 1275:10 1276:4 1278:9 1133:11 1160:12 1243:11
things 1024:10,20 1282:10 1285:5,9,18 1178:13 1231:9,20 timing 1144:5 1235:13
1028:14 1031:13 1296:22 1297:21 1234:10 1235:15 1255:1
1040:20 1041:9 1298:20 1299:12 1264:1 1275:17 1284:1 tiny 1184:17
1049:10 1063:4 1302:4 1303:21 1309:8 tires 1097:11
1070:10 1071:15 1304:21 1306:17 three-star 1094:15 title 1152:13 1188:20
1112:16 1116:18 1308:12 1309:12 throat 1036:5 1246:12
1121:9 1127:19 1310:1 thrust 1154:13 today 1013:7,14 1014:6,9
1170:14,15,22 1171:13 thinking 1016:7 1143:17 Thunderbolt 1204:11 1049:12 1062:20
1171:14,22 1172:7 1144:4 1308:3,6 thunderspy 1204:11 1065:6 1115:14,15
1173:16 1174:22 thinks 1269:18 Thursday 1207:18 1167:13 1213:4 1308:9
1218:1,21 1219:5 third 1061:17 1271:12 1231:18 1308:15,18 1309:16
1220:7,8 1222:7 1288:18 tight 1305:8 told 1033:1,17,20 1035:3
1234:19 1236:19 third-party 1094:5 time 1013:20 1014:12,12 1056:10,13,14 1072:17
1237:4 1242:11 thoroughly 1202:19,21 1014:18 1021:8 1078:9,17 1104:6
1243:15 1259:16 thought 1017:1 1025:20 1023:15,17 1025:16,18 1161:21 1191:10
1277:20 1290:2 1296:2 1032:13 1035:2 1041:7 1026:11 1030:20 1242:12 1259:9 1296:8
think 1014:15,19 1015:1 1056:18 1062:2 1032:18 1034:6 1035:1 tomorrow 1013:14
1017:17,19 1022:5 1072:16 1076:12 1037:9 1040:14 1041:6 1016:8,9 1018:6
1026:4 1028:21 1031:6 1096:7 1160:20 1045:5 1048:22 1050:4 1309:15,17,18 1310:11
1037:3,10,14 1038:21 1165:14 1170:18 1051:1 1053:9,22 1311:16
1043:14 1044:4 1184:4 1270:11 1276:7 1054:16 1056:2 toner 1295:16,17
1048:11 1050:7 thousands 1097:10 1057:19 1059:9 Tony 1310:1
1051:13 1053:3,4 1111:16 1112:5 1063:19 1072:10 tool 1187:1
1054:6,8 1055:13 1130:13 1144:22 1083:1 1085:5,7,11 tools 1109:10,13
1056:3,19,22 1060:20 1151:21 1086:3 1089:4,8,19,22 top 1043:7 1120:12
1060:22 1063:13 threat 1093:9,16 1095:17 1090:1 1092:4 1094:14 1154:21 1158:3 1202:6
1076:1,2,8 1078:7 1096:2 1098:14 1096:7 1100:18 1257:10 1258:1,3,5
1080:2 1081:1 1082:13 1117:18 1119:7,11 1104:15 1116:8,8 topic 1038:15 1121:2,9
1091:19 1096:6 1097:9 1122:12,17 1124:15,16 1124:2 1132:2 1153:15 1134:3 1249:9 1277:9
1097:20 1101:19 1125:12 1126:22 1154:3,15 1155:11 1277:12
1102:4 1103:13 1105:6 1127:1,6 1129:6 1131:1 1166:4,7,9,15 1178:9 topics 1118:15 1122:20
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1089:6 1102:6 1108:3 1095:9 1102:21 1039 1312:6 1600 1011:5
1109:4 1135:14 1112:11 1124:6 1131:9 1047 1312:5 17 1091:20 1212:16
1215:12 1216:13 1230:12 1239:13,14 1058 1312:7,8 1213:8,16 1227:5
1228:6 1233:10 1240:4,4 1242:17 1064 1313:3 1228:7
1234:15 1273:11 1285:4 1066 1312:10 18 1273:13 1274:2,3
works 1059:22 1215:4 years 1021:15,16 1031:22 1077 1312:11 1313:4 185 1303:12,15,21
world 1057:16 1146:15 1053:13 1056:1 1079 1312:12 19 1270:3 1286:9
1152:3 1158:20 1072:22 1088:16 1087/1123 1312:14 1968 1238:22
1197:16,17 1235:22 1090:20 1094:14 11 1009:3,16 1010:2 1998-to-2001 1089:4
1282:18 1283:10 1095:20 1113:6 1119:1 1198:10 1278:21
worn 1130:4 1124:2 1135:15 11:05 1083:21 2
worth 1016:3 1186:13 1212:13,16 11:06 1083:22 2 1035:17 1045:12
wouldn't 1037:17 1073:1 1213:8 1216:7 1227:2,4 1101 1312:15 1153:13 1257:8
1190:3,12 1259:3 1227:5 1228:4,7 1162 1313:5 1308:17 1311:19

202-347-3700 Ace-Federal Reporters, Inc. 866-928-6509

Page 179
Board on Professional Responsibility: In Re Jeffrey Clark
April 1, 2024
Page 1354

2.0 1194:3 1105:20 1119:9 1120:5 1264:6,7 1290:8 1301:8 520 1012:5
2:50 1209:18 1120:10,17 1122:14 1308:13 53 1263:19,22
2:51 1209:18 1123:17 1137:13,14,16 3-2 1060:18 54 1264:1
20 1067:21 1216:13 1146:21 1147:20 3-3 1209:9 55 1076:8,10,15,17
1227:4 1235:8 1258:7 1149:7,9 1152:7 3.4 1307:1 559 1074:5 1075:20
1281:8 1289:12 1153:10,11 1166:3 3.5 1306:9,10 1307:2 1076:9,21 1077:2
20-plus 1119:1 1169:2 1177:15 1182:9 30 1021:9 1162:15 1161:16,17
200,000-plus 1309:11 1194:9 1195:21 1221:20,22 1224:11 561 1064:4,10,12 1161:16
2000 1102:21 1153:10 1201:10 1202:5 1310:17 1161:19 1311:4
20001 1010:13 1221:18 1222:10 30346 1011:6
20005 1011:14 1226:2 1227:16 30th 1253:9 6
2001 1102:21 1229:14 1234:6,17,21 31 1314:22 6 1016:17 1043:14
2002 1134:12,14 1194:15 1234:21 1235:1,6,8 33 1209:6,8,15 1313:16 1208:6 1288:14
1195:17 1196:4 1238:1 1245:20 336 1223:7 1245:4 60 1249:8 1290:3
1214:14 1215:9,10,12 1248:19 1251:10,12,17 1267:17 1268:5 61 1178:12
1228:14,19 1231:22 1252:5 1258:13 1265:5 338 1246:4,8 1268:8 62 1178:15
1241:5 1270:12 1271:8,17 1269:3,12 1271:20
2005 1103:2 1134:11,12 1274:19,21 1275:19 34 1307:1 7
1134:15 1150:14,21 1277:8 1278:21 1285:2 36 1028:21 1148:3 7 1043:15 1047:17
1195:6,14 1197:9 1286:18 1287:1 1160:19 1260:8
1199:17 1289:15 1294:18,20 37 1302:12 1304:20 7- 1061:11
2006 1103:2 1215:11,16 1295:3 1299:20 1300:1 39 1303:5,19,21 7:15 1074:15
1228:16 1230:20 1301:8,11 1305:17 3rd 1149:15 7:20 1074:16
1250:1 1306:20 1307:9,12,18 70 1043:1 1249:8
2007 1213:11 2021 1084:13,21 1085:2 4 702 1117:13
2008 1261:16 1102:4 1153:13 4 1009:11 1128:7 1260:8 77 1259:22
2013 1182:8 1269:14 1270:7 1308:2,12
2015 1134:12 1193:9,13 2022 1084:11 1114:20 4.7 1308:16 1309:9 8
1195:19 1235:8 4.998 1309:9 8-bit 1184:13
2016 1283:14 2023 1021:9 1046:8 4:00 1071:20 8:15 1014:4
2017 1021:8,16 1046:8 2024 1009:14 1010:3 4:25 1278:14 800 1061:11
1067:21 1103:14,15 1311:19 40 1014:4 1227:2 1228:4 800,000 1068:20
1137:20 1138:5 1181:5 2028 1314:22 1240:8 1281:7 1289:11 81 1278:2
1205:4 1213:15 208 1156:11 1161:5 40-year 1211:13 1212:1 82 1278:2
1216:12,15 1282:16 21 1194:5,6,7 1301:8 404.843.1956 1011:7
1283:19 219 1161:5 45 1310:17 9
2018 1258:13 1265:4 22 1216:7 4532 1012:5 9 1069:20 1081:22
1270:3,14 1286:9 22-BD-039 1009:7 47 1165:16,17 1082:10 1231:17
2019 1154:2 1156:2 221 1198:17 1262:18,21
1178:10 1224:11,15 222 1198:18,20 1199:6 5 9:29 1010:3
1228:11 1244:22 22207 1012:6 5 1046:1 1128:7 1254:12 9:30 1311:16,18
1245:7,8,20 1250:16,22 23 1139:13 1235:2 5.10 1128:12 92 1310:8
1251:11 1270:4,6,14 24 1029:4 5.11 1180:9 94,000 1308:17
1271:5,9,9,11 24/7 1029:6 5.11-CO 1178:16,17 99 1198:21
202.319.5303 1012:7 25 1262:21 5.110 1180:9 9th 1071:19 1074:15
202.386.6920 1011:15 25-1/2 1088:15 5.13 1180:18
202.638.1501 1010:14 258 1198:18 1199:10 5.5 1128:3 1234:1
2020 1021:12,22 1022:13 26 1068:2 5.5-B 1178:20
1023:2,6 1024:2,4,22 260 1199:22 5:00 1278:10
1025:14,16 1026:7 5:03 1311:17
1036:9,12,20 1037:2 3 50 1087:20 1307:21
1040:15 1043:8 3 1045:12 1061:4 500 1011:13
1044:11 1059:2 1063:2 1084:13,20 1085:2,10 51 1257:13,22 1258:5,7
1066:11 1068:2 1109:16 1208:1,7 1263:6,7,9,10 1264:5
1099:11,19 1100:9,13 1221:21,22 1234:21 515 1010:11
1101:9 1104:9 1105:5 1235:1 1257:9 1262:17 52 1152:14 1188:20

202-347-3700 Ace-Federal Reporters, Inc. 866-928-6509

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Exhibit I
11/13/2020 Fulton County BRE Meeting

Page 181
APPROVED MINUTES

BOARD OF REGISTRATION AND ELECTIONS

REGULAR MEETING – NOVEMBER 13, 2020
The Fulton County Board of Registration and Elections met in Regular Session on Friday, November 13,
2020 at 10:00 a.m.

VIRTUAL MEETING
Please join the meeting from your computer, tablet or smartphone.
FGTV YouTube Channel
https://www.youtube.com/channel/UCYH7E0jH6HxE-3KTRluH8SQ

Presiding: Ms. Mary Carole Cooney, Chairperson

Other Board Members Present:

Ms. Vernetta Keith Nuriddin, Vice Chairperson
Mr. Mark Wingate
Mr. Aaron V. Johnson
Dr. Kathleen Ruth

Staff Attending: Mr. Richard Barron, Director; Mr. Ralph Jones, Registration Chief; Mr. Dwight Brower, Interim
Elections Chief; Ms. Sharon Benjamin, Deputy Elections Chief; Ms. Nadine Williams, Elections Equipment
Manager; Mrs. Pamela Coman, Registration Manager; Ms. Brenda McCloud, Administrative Manager; Mrs.
Cheryl Ringer, County Attorney; Mr. David Lowman, County Attorney; Mr. James Reese, Production Manager;
Mr. Rico Dollar, Senior Graphics Designer, Jessica Corbitt, PIO; Regina Waller, Senior Public Affairs Officer

Guests Attending: Commissioner Hausmann (District 2), Senator Vincent Fort, David Ross (Democratic Party of GA),
Aileen Nakamura (Coalition of Good Governance), Rhonda Martin (Coalition of Good Governance), Natalie Goldberger,
Milia Akkouris, Marilyn Marks (Coalition of Good Governance), Hillary Li, Susan Shapiro, Stephen Fowler, Ben Howard,
Garland Favorito

Chairperson Cooney announced that this teleconferenced meeting is authorized pursuant to §50-14-
1(g) of the Official Code of Georgia because of the Public Health State of Emergency declared by
Governor Kemp on March 14, 2020, and renewed most recently on October 30, 2020, pursuant to which
public meeting spaces in state and local Government have been closed due to COVID-19, and because
means have been afforded for the public to have simultaneous access to this teleconference.

#1– APPROVAL OF AGENDA

Chairperson Cooney entertained a motion to approve the agenda. The motion was made by Mr.
Wingate, seconded by Dr. Ruth and carried by a unanimous vote of 5-0.

#2– COMMUNICATIONS AND PUBLIC RESPONSE

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Garland Favorito (Co-founder of VoterGA) mentioned discrepancies and irregularities that he claims he \ witnessed on
election night during downloading of results. Mr. Favorito mentioned he informed the BRE in writing but to no avail.

Aileen Nakamura expressed concerns over the costly voting system the Secretary of State has imposed on counties.
Ms. Nakamura implored the BRE and DRE to ditch the voting system and utilize hand marked paper ballots

Rhonda Martin implored the BRE and DRE to ditch the voting system and utilize hand marked paper ballots. Ms. Martin
reviewed her wish list of improvements; ballot request portal, drop boxes, scanners configurations, vote review panels,
and ballots that can be traced back.

Senator Vincent Fort expressed concerns of how the Senate District 39 race (the Special Democratic Primary) was
conducted during the General Elections. Senator Fort expressed concerns of the training of poll workers, the lack of
notice provided to the candidates and expressed that the State Senate, District 39 Race is tainted. Senator Fort
requested the BRE conduct an independent investigation and not certify the election results.

Milia Akkouris mentioned her experience as an election day poll worker and early voting supplemental employee. Ms.
Akkouris recommended a complete overhaul and restructuring of all the training and she offered to assist. Ms. Akkouris
agreed with other public comments regarding utilizing hand mark paper ballots. Ms. Akkouris mentioned being available
to discuss further.

Marilyn Marks complimented the DRE on their efforts and improvements despite the system’s on-going issues. Ms.
Marks mentioned the voting system being far too complex and costly. Ms. Mark urged the DRE & BRE to discuss this
Recount with their legal team on the legality of this directive by the Secretary of State’s office.

Hillary Li (Asian Americans Advancing Justice) expressed gratitude on the recent election. Ms. Li expressed concern for
the poll monitors assisting voters outside of the polls. There seem to be an overwhelming amount of hostility and
confusion. Ms. Li expressed major concern was the disparaging comments made by the poll manager, Cindy Lipsey at
Findley Oaks Elementary about LEP (Limited English Proficient) voters. Ms. Li demanded the removal of Cindy Lipsey.
Ms. Li implored the DRE to properly train personnel on cancelling absentee ballots and provisional procedures.

Ben Howard (Senior Advocate Public Policy Analyst) inquired about who is responsible for such an expensive effort of
completing a hand recount, that’s not mandated by law. Mr. Howard requested a complete (step by step) explanation of
Absentee ballots, provisional, and curing processes. Mr. Howard requested that the sign for 75+ years of age voters
moving to the front of the line be visible inside and on the outside.

OLD BUSINESS

#3- APPROVAL OF MINUTES

 Special Meeting- October 6, 2020

 Executive Session Meeting- October 6, 2020
 Regular Meeting- October 8, 2020
 Special Meeting- October 23, 2020

Chairperson Cooney entertained a motion to approve the meeting minutes from the Regular, Special
and Executive Session Meetings on October 6th, 8th, and 23rd, 2020. The motion was made by Mr.
Wingate, seconded by Mr. Johnson and carried by a unanimous vote of 5-0.

#4– MONTHLY OPERATIONS REPORT FOR SEPTEMBER 2020:

rd
 Preparation for November 3 , General/Special Election

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th th
 Early Voting (EV) began October 12 – October 30
30 Permanent EV locations
 2 Mobile Voting RVs
 7 Outreach location
 316,000 voters approximately
 All Training was in-person
 Bandwidth resolution- Ongoing
th st
 November 9 Early Voting will begin for the December 1 Runoff
 US House, D5/ Congressional District 5 (CD5)
rd st
 November 23 Early Voting will begin for the December 1 Runoff
 Senate District 39 (SD39)
 Voters that live in both Districts SD39 and CD5:
 Required to check-in twice
 Cast a ballot on two separate sets of voting machines
 44 Polling locations are affected by overlapping
th
 A legal hold remains on the DRE voting units from the April 18, 2017 and June 20, 2017 6
Congressional Special Election and Runoff Special Election (Relocated to offsite facility)
 D.R.E.A.M. located a larger facility to house staff and Voting equipment
 Bandwidth challenges resolved
 Four Vacancy Positions:
 Deputy Director
 Elections Officer
 Elections System Assistant Supervisor
 VEO Coordinator
 Requested an Audit of process and procedures
 Total voter registration applications received in 2020: 270,025
 Absentee Ballot Applications processed: 260,000+
 Needs to be a separate Division
 31,798 voter registration applications received in October
st
 As of November 1 , 847,994 (808,680 active and 39,314 inactive) registered voters reside in Fulton
County
 Total New Applications: 97,191
 Felon Hearings: 0
 Felon Letters Mailed-790
 2- Active Call Centers with more than 50 additional staff
th
 Runbeck will mail Absentee By Mail, initial mail out beginning November 20
 Four Funded Positions:
 Deputy Director
 Elections Officer
 Elections System Assistant Supervisor
 VEO Coordinator

Mr. Barron completed his update on the October’s Monthly report to discuss the Risk Limited Audit (RLA).
The Secretary of State’s office directed and instructed all counties to complete a Hand Tally of votes in the
Presidential race only. Personnel will work in teams to complete the task in 5 days. This hand tally will include
two person teams and approximately 125 teams (250-300 people).

Mr. Wingate inquired about what he considered a discrepancy in the metrics on the precinct locator. Mr.
Wingate also questioned the percentage of registered voters in Fulton. The percentage was categorized as
too high for the population.

Mr. Johnson referenced DDS (Department of Driver Services) as a mechanism used by registered voters
which automatically could account for the high number of registered voters, as well as large number of groups
registering voters

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Mr. Wingate expressed disbelief in 80%, by his calculation, of Fulton’s population are registered voters. Mr.
Wingate continued to share metrics that he deemed questionable and expressed they should be reviewed
more closely.

Mr. Barron responded that a few years ago the voting age population of registered voters in Fulton was over
90%

Dr. Ruth mentioned the monthly report from October statistics and compared those metrics with Election
Summary of Total voters included in this election.

Mr. Barron answered yes, those metrics include only active voters as of October 5th that registered timely.

Mr. Wingate asked for clarity on the statistics from the report

Mr. Barron informed the Board that the date was incorrect the report is accurate

Chairperson Cooney mentioned utilizing the same template for certain reports but directed the DRE to ensure
the information is corrected in the future.

Dr. Ruth inquired about the absentee spreadsheet and how the DRE reconcile duplicates

Mr. Barron informed the BRE that voters received multiple 3rd party application or they apply on the portal,
those numbers are capture on the report. Mr. Barron mentioned this was just a tracking mechanism.

Dr. Ruth asked about the drop box spreadsheet and the last two columns related to the spreadsheet? Dr.
Ruth informed the viewers that voters are permitted to utilize the drop box for their ballot and absentee
application request.

Mr. Barron mentioned the drop boxes are used to cast ballots, absentee application requests, and voter
registration applications, as well.

Dr. Ruth asked about the duplicate numbers.

Mr. Barron answered that those are added to use for another spreadsheet, if you attempt to copy the row next
to it the formulas will copy as well.

Dr. Ruth mentioned that the BRE inquired about the number of ballots cured but did not receive.

Mr. Jones answered that at his last count 86 ballots were cured; by rectifying the signature or signing the oath
on the envelope.

Dr. Ruth agreed with the Coalition of Good Governance on the substantial improvements in the department;
however, there are some deficiencies or gaps in the Absentee By Mail process. Dr. Ruth agreed with Mr.
Barron on bringing in a group or person to look at procedures. Dr. Ruth was specific

Mr. Johnson expressed gratitude on the work that was done….. Staff, Other County Employees, Volunteers,
and County Executive Team. Mr. Johnson mentioned that he does not want this hand tally to overshadow the
hard work that went into this election and the dedication of the team. Mr. Johnson expressed that despite
what continues to be said that if you voted your vote counted. Mr. Johnson mentioned that it’s unfortunate
that certain candidates are attempting to taint the election with all the effort that was put into the election:

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 Robust Early Voting Locations

 Robust Drop boxes
 Added Resources

Mr. Johnson referenced a comment made by SOS and reversed it by saying “SOS will be SOS”. Mr.
Johnson echoed Dr. Ruth’s sentiment about resolving the gaps and deficiencies regarding Absentee by Mail
to ensure voters that the elections are fair and efficient.

Mr. Johnson said Thank you to Fulton County Registration and Elections’ Staff, County Employees,
Volunteer, and the voters.

Mr. Johnson inquired about the SD39 race rollover list and Public Service Commission Race moving to the
January 5th Election. Mr. Johnson inquired about the rollover list for SD39 and absentee ballots.

Mr. Barron responded that US House, D5 does not have a rollover list mail out because it is a Special
election. However, SD39 will have a rollover mailing.

Mr. Jones disagreed and said that there’s no rollover for either race.

Mr. Barron refuted Mr. Jones’ response and informed the Board that SD39 will have a mailing for the rollover
listing.

Mr. Johnson asked when can voters begin requesting ballots and expect a ballot for the SD39.

Mr. Brower informed the Board the database was received today and he projects he will give a thumbs up
today; however, the SOS has to certify their election first. The date for certification was November 20 th. Mr.
Brower also said the information will be waiting at a local vendor waiting for the thumbs up.

Mr. Johnson asked for clarification due to the circumstances surrounding the two separate elections. Mr.
Johnson asked would he need to ask the poll worker.

Mr. Barron mentioned that poll workers will be trained to mention both elections but there will be (2) check-ins
and (2) sets of voting units due to (2) separate elections and there will be signs in and out of the facilities.

Mr. Johnson implored the DRE to make sure they’re being transparent with voters and candidates because he
believes there may be voter fatigue with all the variables added.

Vice Chair Nuriddin noted an error in judgement with regards to the Special Democratic Primary during the
General Election and the manner counties involved were instructed by SOS to manage this race. Vice Chair
Nuriddin inquired about any questions being asked prior to voting, such as “Do you want to vote in this
election”

Mr. Barron said no, it’s a standalone election,

Vice Chair Nuriddin inquired about the RLA, was it a countywide hand tally before the recount.

Mr. Barron informed the BRE the RLA begins on Thursday and the audit will conclude this election. RLA will
be a full hand tally of all precincts.

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Vice Chair Nuriddin inquired about contact information for felons who have satisfied their obligations. Vice
Chair Nuriddin expounded on the request for felons to the DRE.

Mr. Jones answered that he will get the information; shortly thereafter, the information was provided in chat.

Vice Chair Nuriddin asked about the number of staff currently.

Mr. Barron answered (34) and (4) pending advertisement by Human Resources.

Vice Chair Nuriddin inquired about SD39 rollover list.

Mr. Jones mentioned that he will pull a report.

Mr. Barron mentioned a tight timeframe due to ballots for SD39 with State’s (SOS) certification, the holiday
delays and closures.

Vice Chair Nuriddin asked who made the decisions to ask the questions with regards to Senate D39 because
that decision did not come from this Body; was it the Democratic Party of GA or SOS.

Mr. Barron mentioned he did not know who was responsible for the question.

NEW BUSINESS

#5- OVERVIEW OF SEPTEMBER 29, 2020, SPECIAL ELECTION

Chairperson Cooney noted that the discussion was wide ranging with all inquiries discussing items # 4, 5,
and 7. Madam Chair asked if the BRE was satisfied with the conclusion of items through # 7, and with no
comments made the BRE moved forward.

#6- CERTIFICATION OF ELECTION RESULTS: NOVEMBER 3, 2020, GENERAL AND

SPECIAL ELECTION

Registered Voters: 806,451

Votes Cast: 528,777

Chairperson Cooney asked Mr. Barron was it his certification and testimony that the election results
presented are a true and accurate count of all the votes cast in the General and Special Election held on
November 3, 2020.

 Countywide, Statewide, Presidential, Federal, and Statewide (General Election)

Mr. Barron answered yes

Dr. Ruth interjected by mentioning that there is a lawsuit pending that has over 3,600 from 14,000 challenged
voters that voted during Early voting. Dr. Ruth stated “No”.

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Mr. Wingate expressed that before he votes, he wanted to provide justification.

“ First of all, we do have as we recognize we do have a hand count going on of this election that will be by Wednesday of
next week of this election. I was sent in conjunction with a pending lawsuit of over 14,000 voters that are being
challenged on the voter registration list, this information I have received, again I am only reporting what was given to me
but there was at that time around 9am this morning. Whoever it is that was looking at this has already found 4,000 voters
that cast a vote in this election on that list. And I don’t know where it will end up or where this is going but I do just fine as
a voter myself in Fulton County but I find this concerning. The other thing is that through this process and through all the
hard work that Rick, Dwight, Ralph, and everybody has done it is a confoundingly hard process but it’s indisputable from
Election Night that there was an observer issue of around an hour and half of processes that was still going on and having
observers, from Election Night we were still finding flash cards, still finding missing provisional ballots, and unscanned
ballots that happened to be in a couple precincts ( one in East Point and one in Alpharetta). My point to that is we did our
final reporting/ final upload of this last night at 8:17pm just FOR THE RECORD. Final thing: Back in the minutes of our
th
meeting on October 8 reporting, that day we had a technician from BlueCrest onsite assisting our staff so they could
enable and get the electronic signature verification component of the BlueCrest platform enabled….. Talking only for
myself I left there and I was never given any other updates and my question to the department subsequent to that is how
that was going. Well it was never used, we couldn’t get it to work, as I was stated… From Runbeck and because of that
they gave up on the process and of the 147,000 absentee paper ballots that were processed in I just think that for the
record it just needs to be known that all of those were derived by a manual process. They was not electronically verified
signatures. With those reasons and there are others, I have to cast a “NO” vote to certify this election.”

Chairperson Cooney entertained a motion to certify the election results. The motion was made by Mr.
Johnson, seconded by Vice Chair Nuriddin and carried by a vote of 3-0; 2 Nays, Dr. Ruth and Mr.
Wingate.

Chairperson Cooney asked Mr. Barron was it his certification and testimony that the election results
presented are a true and accurate count of all the votes cast in the General and Special Election held on
November 3, 2020.

 Write-in Candidates: President, US Senate, and US House Representative, District 13

Mr. Barron answered yes

Chairperson Cooney entertained a motion to certify the election results. The motion was made by Mr.
Johnson, seconded by Vice-Chair Nuriddin and carried by a vote of 3-0; 2 Nays, Dr. Ruth and Mr.
Wingate.

Chairperson Cooney asked Mr. Barron was it his certification and testimony that the election results
presented are a true and accurate count of all the votes cast in the Special Election held on November 3, 2020.

 Unexpired Term of Johnny Isakson, US Senate

Mr. Barron answered yes

Chairperson Cooney entertained a motion to certify the election results. The motion was made by Mr.
Wingate, seconded by Mr. Johnson and carried by a unanimous vote of 5-0.

Chairperson Cooney asked Mr. Barron was it his certification and testimony that the election results
presented are a true and accurate count of all the votes cast in the Special Election held on November 3, 2020.

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 Special Democratic Primary Election

Mr. Barron answered yes

Chairperson Cooney entertained a motion to certify the election results. The motion was made by Mr.
Wingate, seconded by Vice-Chair Nuriddin and carried by a unanimous vote of 5-0.
Chairperson Cooney asked Mr. Barron was it his certification and testimony that the election results
presented are a true and accurate count of all the votes cast in the General and Special Election held on
November 3, 2020.

 1-Proposed Constitutional Amendments: House Resolution 164 Act No. 597

Mr. Barron answered yes

Chairperson Cooney entertained a motion to certify the election results. The motion was made by Mr.
Wingate, seconded by Vice-Chair Nuriddin and carried by a unanimous vote of 5-0.

Chairperson Cooney asked Mr. Barron was it his certification and testimony that the election results
presented are a true and accurate count of all the votes cast in the General and Special Election held on
November 3, 2020.

 2-Proposed Constitutional Amendments: House Resolution 1023 Act No. 596

Mr. Barron answered yes

Chairperson Cooney entertained a motion to certify the election results. The motion was made by Mr.
Wingate, seconded by Vice-Chair Nuriddin and carried by a unanimous vote of 5-0.

Chairperson Cooney asked Mr. Barron was it his certification and testimony that the election results
presented are a true and accurate count of all the votes cast in the General and Special Election held on
November 3, 2020.

 Statewide Referendum: House Bill 344 Act No. 149

Mr. Barron answered yes

Chairperson Cooney entertained a motion to certify the election results. The motion was made by Mr.
Wingate, seconded by Dr. Ruth and carried by a unanimous vote of 5-0.

Chairperson Cooney asked Mr. Barron was it his certification and testimony that the election results
presented are a true and accurate count of all the votes cast in the General and Special Election held on
November 3, 2020.

 Special Election for the City of Union City: Referendum for Homestead Exemption

Mr. Barron answered yes

Chairperson Cooney entertained a motion to certify the election results. The motion was made by Mr.
Johnson, seconded by Vice-Chair Nuriddin and carried by a unanimous vote of 5-0.

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Chairperson Cooney asked Mr. Barron was it his certification and testimony that the election results
presented are a true and accurate count of all the votes cast in the General and Special Election held on
November 3, 2020.

 Special Election for the City of East Point: Referendum on Whether to Allow Sunday Alcohol Sales

Mr. Barron answered yes

Chairperson Cooney entertained a motion to certify the election results. The motion was made by Mr.
Johnson, seconded by Vice-Chair Nuriddin and carried by a unanimous vote of 5-0.

Chairperson Cooney asked Mr. Barron was it his certification and testimony that the election results
presented are a true and accurate count of all the votes cast in the General and Special Election held on
November 3, 2020.

 Special Election for the City of Atlanta: Referendum for Homestead Exemption

Mr. Barron answered yes

Chairperson Cooney entertained a motion to certify the election results. The motion was made by Mr.
Johnson, seconded by Dr. Ruth and carried by a unanimous vote of 5-0.

#7-UPDATE OF PREPARATIONS FOR THE RUNOFF ELECTION, DECEMBER 1ST

th
 US HOUSE DISTRICT 5, 5 Congressional District

Chairperson Cooney asked if there was anything further to go over due to previous item being covered in
item #4.

Mr. Barron mentioned overlooking that SD39 was a Special Election and asked Attorney Ringer about the
rollover list.

Mr. Johnson asked so everything we discussed previously regarding SD39 is correct except there will not be
a mail-out for the rollover list.

Mr. Barron mentioned that you can apply for absentee by mail on the Fulton’s portal but there will be a small
window for mailing ballots.

Vice Chair Nuriddin noted as it pertained to mailing rollovers “that just because it’s not required does not
mean we shouldn’t do it”. “I like the fact that we apply the law in our decision making but we don’t have to use it
to limit the service we provide the voters in Fulton County”

Mr. Barron expressed concern for mailing ballots for SD39 because most of them won’t be returned in time or
maybe delivered late. The first available date to begin mailing is November 20 th after State’s Certification is
completed and a Holiday following the mail-outs.

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Approved Minutes
Regular Meeting- November 13, 2020
10 | P a g e

Vice Chair Nuriddin implored the DRE to be better prepared for meetings. Vice Chair spoke specifically on
providing statistics on Election Night with regards to Absentee by Mail.

Mr. Barron agreed with Vice Chair Nuriddin assessment.

Attorney Ringer requested that the Body consider delaying their meetings on Election Night until after 7pm,
due to potential conflict of schedule.

Dr. Ruth recommend that External Affairs provide the voters with some information to limit the confusion

Attorney Ringer mentioned that in a previous discussions with Ms. Corbitt, she mentioned Mailers, Press
Releases, and contacting HOAs.

#8-APPROVAL OF EMERGENCY POLLING LOCATION CHANGE:

 143/20 Precinct 08H

Mr. Brower explained the precinct proposals. All polling locations are American with Disabilities Act (ADA)
compliant. All impacted voters will be notified as soon as possible of this emergency polling place change.

# Voters Mile(s) to
Proposal # Precinct(s) Facility Name Reason Proposed Change Assigned to New New
Location Location
Covenant Presbyterian Church Reopening their Sutton Middle
143/20 08H 2532 1.3
2461 Peachtree Rd. Daycare Facility 2875 Northside Dr NW

Mr. Brower informed the Board that both CD5 and SD39 race are assigned to this precinct.

Mr. Johnson implored the DRE to properly and quickly notify the voters that are impacted.

Dr. Ruth inquired about using text messaging to inform voters of change as well as all other required
mechanism.

Mr. Wingate asked about generating a dotted map of the 255 polling locations in the county.

Mr. Brower stated that he can discuss further with GIS to generate something for public consumption. Mr.
Brower mentioned he will discuss further with External Affairs on the text messaging idea from Dr. Ruth.

Chairperson Cooney entertained a motion to approve the emergency polling location change. The
motion was made by Mr. Johnson, seconded by Dr. Ruth and carried by a unanimous vote of 5-0.

Chairperson Cooney expressed gratitude to the staff on all their hard work.

EXECUTIVE SESSION

The Board did not convene into executive session.

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Regular Meeting- November 13, 2020
11 | P a g e

ADJOURNMENT

With no other items requiring the Board’s action, Chairperson Cooney entertained a motion to adjourn. Mr.
Wingate moved to adjourn the meeting. Mr. Johnson seconded the motion. Collectively, the Board
agreed to adjourn at 12:17 p.m.

The meeting adjourned.

Prepared by,

Mariska Bodison, Board Secretary

Page 192
Exhibit J
Carter Jones Monitor Report

Page 193
Page 194
Exhibit K
11/20/2020 BlueCrest Proposal

Page 195
Proposal Prepared for Fulton County Elections and Registration
Win 10 updates for the Relia-Vote™ Outbound (Inserting) and Inbound
(Sortation) solutions.

Prepared for Mr. Ralph Jones

Registration Cheif
By
Edwin Norris
Regional Account Executive GA/FL

November 20, 2020

Page 196
Scope of the proposal:

This proposal will address the following items discussed and requested
on November 19,2020 those items were:

•WIN 10 Upgrades (Both Inserter & Sorter) –

• ASV software – The proposal includes the ASV volume bands for 300K,
500K and 1M images to be verified. Each look up is a click whether
accepted or not accepted is a click.

• Timeline/scope – As stated on the call we do not suggest making any

changes just before an election – We will have to source the
components for the WIN 10 updates, at the present moment our lead
times for the components is 8 to 10 weeks. Therefore, it would be
possible to get the upgrades done around the end of January to Mid-
February. However, we are not able to provide any firm dates until we
have an actual order. Once we have order we can obtain a scheduled
ship date from Manufacturing and provide an actual timeline.

Source Well contract number NASPO (NASPO Agreement category

“Mailroom Equipment, and Maintenance (2017-2022), Solicitation
Number ADSPO16-00006328, contract CTR044595.) You will just need
to sign our participating addendum.

Page 197
Prcing for WIN 10 Updates with product codes

Relia-Vote™ MSE Outbound Inserting unit

FPS1RETRO MAILSTREAM EVOLUTION RETROFIT 1
RDE9 SINGLE PC RETROFIT KIT, WIN 10, NO KVM 1
RDGA STANDARD SERVER (DC-PPM-DVR) 1
RDES MONITOR KIT, 22 IN, RETORFIT 1
275-0933 CABLE - DISPLAY PORT, M-M, 25 FT 1
Y184664 COMPUTER PRINT+ CTRL W/O IPIPE WIN10 IOT 1
275-0933 CABLE - DISPLAY PORT, M-M, 25 FT 1
RDW10 WINDOWS 10 UTILITY WORKSTATION 1
Z9F1 Field Support Labor (2hr/unit) 20
RDSE Systems Engineering Support - Labor 7

Price: $57,640.57

The pricing is for the Source well previously the NASPO contract, the state of Georgia is a participating
member and this may be the easiest way to procure the update request.

Relia-Vote™ Vantage Inbound sortation unit

STZ0RETRO VANTAGE SORTER SYSTEM RETROFIT 1

SRW10 KIT-VANTAGE WIN10 PCS UPGRADE 1
SRJA KIT-KVM WIN10 UPGRADE 1
SR2S REMOTE DIAGNOSTIC SERVER 1
SRSS SORTER/RELIAVOTE STD SITER SERVER DOMEST 1
Z9F0 PSE/Sorter SUPPORT LABOR PER DAY 5
Z9F1 Field Support Labor (2hr/unit) 20

Price: $47,902.44

Page 198
The pricing is for the Source well previously the NASPO contract, the state of Georgia is a participating
member and this may be the easiest way to procure the update request.

Automatic Signature Verification (ASV) 300K, 500K, 1M click models

STZ0RETRO VANTAGE SORTER SYSTEM RETROFIT 1

PARA PARASCRIPT SIGNATUREXPERT 300K 1
SRRB S/A BINARIZER 1
Z9F0 PSE/Sorter SUPPORT LABOR PER DAY 2

Price: $17,614

STZ0RETRO VANTAGE SORTER SYSTEM RETROFIT 1

PARB PARASRPT SIGNATUREXPERT 500k 1
SRRB S/A BINARIZER 1
Z9F0 PSE/Sorter SUPPORT LABOR PER DAY 2

Price: $20,976

STZ0RETRO VANTAGE SORTER SYSTEM RETROFIT 1

PARC PARASCRIPT SIGNATUREXPERT 1MILL 1
SRRB S/A BINARIZER 1
Z9F0 PSE/Sorter SUPPORT LABOR PER DAY 2

Price: $27850.20

Page 199
Exhibit L
12/9/2020 Official Election Bulletin

Page 200
OFFICIAL ELECTION BULLETIN
December 9, 2020
_____________________________________________________________________________________________

TO: County Election Officials and County Registrars

FROM: Chris Harvey, Elections Division Director

RE: Absentee Ballot and Absentee Ballot Application Signature

Verification

______________________________________________________________________

Signature Verification Process is Public

We have received numerous questions asking whether the signature verification process on
absentee ballot applications and absentee ballot envelopes is open to the public. The short
answer is yes, it is. Pursuant to O.C.G.A. § 21-2-406, “[s]uperintendents, poll officers, and other
officials engaged in the conducting of primaries and elections held under this chapter shall
perform their duties in public. Additionally, O.C.G.A. § 21-2-483(b), states that “[a]ll proceedings
at the tabulating center and precincts shall be open to the view of the public, but no person
except one employed and designated for the purpose by the superintendent or the
superintendent's authorized deputy shall touch any ballot or ballot container.”

The fact that the signature verification process is public under Georgia law does not mean that
public observers should be allowed to see confidential information or to interfere in the process.
See O.C.G.A. § 21-2-597. The elections superintendent must ensure that any public viewing area
or video feed offers meaningful access to view the process, but the superintendent should also
put in place reasonable regulations to protect the voter’s/applicant’s personal identification
information (PII) and/or non-public data from public view and to ensure that no observer
interferes with the verification process. A good template may be the processes you have put in
place for the early processing of absentee ballots, which is also publicly viewable but has
protections in place to protect confidential information and prevent interference with official
duties.

Any interference or attempted interference with official election duties should be reported to
the Secretary of State’s office for investigation and, if necessary, local law enforcement.

Page 1 of 2

Page 201
Signature Verification Process for Absentee Ballots and Absentee Ballot Applications

O.C.G.A. § 21-2-386(a)(1)(B) requires “[u]pon receipt of each ballot, the registrar or absentee
ballot clerk to compare the signature or mark with the signature or mark on the absentee
elector’s voter registration card or the most recent update to such absentee elector’s voter
registration card AND application for absentee ballot or a facsimile of said signature or mark
taken from said card or application.” It further provides, “if the information and signature appear
to be valid and other identifying information appears to be correct, [the registrar or absentee
ballot clerk shall] so certify by signing or initialing his or her name below the voter’s oath.”
O.C.G.A. § 21-2-386(a)(1)(B).

O.C.G.A. § 21-2-381(b)(1) requires “[u]pon receipt of a timely application for absentee ballot, a
registrar shall enter thereon the date received. The registrar or absentee ballot clerk shall
determine, in accordance with the provisions of this chapter, if the applicant is eligible to vote in
the primary or election involved. In order to be found eligible to vote an absentee ballot by mail,
the registrar or absentee ballot clerk shall compare the identifying information on the application
with the information on file in the registrar’s office and, if the application is signed by the elector,
compare the signature or mark of the elector on the application with the signature.” “If found
eligible, the registrar or absentee ballot clerk shall certify by signing in the proper place on the
application.” O.C.G.A. § 21-2-381(b)(2)

As set forth in Georgia law a thorough process for signature verification is required at both the
absentee ballot application and absentee ballot stage. As you are all aware, numerous allegations
have been raised about the signature match process following the November election. While we
have not seen any evidence to the contrary, please be sure that your office is following the
thorough signature verification requirements set out in Georgia law. If you have any question as
to the validity of a signature on either an absentee ballot or absentee ballot application after
following your signature verification process, you should utilize the cure procedures set forth in
O.C.G.A. § 21-2-386(a)(1)(C), O.C.G.A. § 21-2-381(b)(3), and SEB Rule 183-1-14-.13.

Your policies and procedure regarding signature match must follow Georgia law, and they should
also be accomplished in a manner that helps provide confidence in the process to the voting
public.

Page 2 of 2

Page 202
Exhibit M
Ralph Jones Testimony

Page 203
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·

1 IN THE SUPERIOR COURT OF FULTON COUNTY

2 STATE OF GEORGIA
3 CAROLINE JEFFORDS, and *
4 ROBBIN SOTIR, *
5 Petitioners, *
6 v. * CIVIL ACTION
7 MARY CAROLE COONEY, VERNETTA * FILE NO.: 2020CV343938
8 KEITH NURIDDIN, KATHLEEN RUTH*
9 and RICHARD BARRON in their *
10 individual capacities, *
11 Respondents. *
12 ____________________________________________________
13 The deposition of RALPH JONES taken pursuant to Notice and
14 agreement of counsel for any and all purposes allowed
15 under the Georgia Civil Practice Act, taken before Tiffany
16 L. Jones, Certified Court Reporter, Certified Verbatim
17 Reporter and Notary Public in and for the State of Georgia
18 to commence at 9:30 a.m., Monday, May 17, 2021. This
19 deposition is being held ZOOM. The witness and the court
20 reporter are not in the same room. The witness will be
21 sworn in remotely pursuant to the agreement of all
22 parties. All parties have stipulated that the testimony
23 will be given as if the witness was sworn in person and
24 may proceed via ZOOM rather than in person due to the
25 national health emergency of COVID-19.

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CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 Page 2

1 A P P E A R A N C E S
2
3 ON BEHALF OF THE PETITIONERS:
4 Robert D. Cheeley, Esquire
5 Cheeley Law Group, LLC
6 2500 Old Milton Parkway, Suite 200
7 Alpharetta, Georgia 30009
8 Telephone: 770.814.7001
9 Email: [email protected]
10
11 Charles Bundren, Esquire
12 Bundren Law Group, PLLC
13 2591 Dallas Parkway, Suite 300
14 Frisco, Texas 75034
15 Telephone: 214.808.3555
16 Email: [email protected]
17
18
19
20
21
22
23
24
25

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CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 Page 3

1 A P P E A R A N C E S
2
3 ON BEHALF OF THE RESPONDENTS:
4 Cheryl Ringer, Esquire
5 David R. Lowman, Esquire
6 Fulton County Attorney's Office
7 141 Pryor Street SW, Suite 4038
8 Atlanta, Georgia 30303
9 Telephone: 404.612.0263
10 Email: [email protected]
11
12 VIDEOGRAPHER:
13 Liz Kemp
14 Legal Technology Services
15
16 ALSO PRESENT:
17 Gagan Vaideeswaran
18 Mike Scopin
19 Chris Peck
20 Robin Carmichael
21 Marnie Nessen
22 Vicky Dracos
23 Garland Favorito
24
25

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CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 Page 4

1 INDEX TO EXAMINATION
2 Examination Page
3 Ralph Jones
4 Examination by Mr. Cheeley 5
5
6
7 INDEX TO EXHIBITS
8 Exhibit Description Page
9 Petitioner’s 1 Audit Board Batch Sheet 160
10 Petitioner’s 2 Hand County Batch Sheet 172
11 (EXHIBIT RETAINED BY MR. CHEELEY)
12
13 _____________________________________________________
14 (Whereupon, it was stipulated and agreed by
15 and between counsel, and specifically agreed to by
16 the witness himself, that the reading and signing of the
17 deposition by the witness would be reserved.)
18 __________________________________________________
19
20
21 Legend of the transcript:
22 [sic] Exactly as said
23 (phonetic) Exact spelling unknown
24 -- Break in speech continuity
25 (unintelligible) Mechanical or speaker failure/Crosstalk

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CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 Page 5

1 P R O C E E D I N G S
2 THE VIDEOGRAPHER: We’re now on the video record.
3 This is the beginning of media file number one. The
4 time is 9:30 -- 9:53 a.m. Would the court reporter
5 please swear in the witness?
6 THE COURT REPORTER: Mr. Jones, raise your right
7 hand, please. Do you solemnly swear or affirm that
8 the testimony you give will be the truth, the whole
9 truth, and nothing but the truth?
10 THE WITNESS: I do.
11 THE COURT REPORTER: Thank you.
12 RALPH JONES,
13 having been previously duly sworn, was examined
14 and testified as follows:
15 EXAMINATION
16 BY MR. CHEELEY:
17 Q. State your name, please, for the record.
18 A. My name is Ralph Jones.
19 Q. Mr. Jones, my name is Bob Cheeley. It’s nice to
20 meet you.
21 A. Same here.
22 Q. I’m just an old country lawyer. I don't know
23 anything about elections, so you’re going to have to teach
24 me everything I learn today, okay?
25 A. We’ll see what we can do for you.

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1 Q. All right. You are employed by Fulton County

2 Board of Elections; is that right?
3 A. That is correct.
4 Q. How long have you been employed there? I think
5 it’s 12 years.
6 A. Since 2009. January of 2009.
7 Q. Okay. And what -- what was your background
8 before coming to work for Fulton County Elections?
9 A. I used to work at the Secretary of State’s
10 Office. I was a help desk specialist in the Elections
11 Division at the Secretary of State.
12 Q. I’m sorry. Could you speak up a little bit? I
13 couldn’t hardly hear what you said. You were --
14 A. Yes. I used to work at the Secretary of State’s
15 Office and I was the help desk specialist.
16 Q. Help desk?
17 A. Yes.
18 Q. Okay. How long did you work at the Secretary of
19 State’s Office?
20 A. Around about 22 years.
21 Q. Okay. And did you hold different positions while
22 you were there over those 22 years?
23 A. Yes, I did.
24 Q. Give me -- highlight kind of the summary of those
25 positions.

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1 A. I started out as an operations analyst for the

2 Professional Licensing Board. And then I was transferred
3 to the Elections Board.
4 Q. Okay. So you would have started work at the
5 Secretary of State’s Office in, what was that, the late
6 ‘80s?
7 A. Correct.
8 Q. And if you would, take each one of the positions
9 that you held there beginning with your first position and
10 tell me what you did in that position, please, sir.
11 A. Okay. As the operations analyst, my job was to
12 grade the professional licensing examinations for barbers,
13 veterinarians. I was the person who did the scheduling
14 programming for the (unintelligible) grading systems for
15 the Professional Licensing Board, and the one who gives
16 out the results. And for the Elections help desk, my job
17 was to be the first responder from the counties when the
18 counties called in that had questions about procedures and
19 processes, mainly dealing with how to process things in
20 elections.
21 Q. Okay. How about the -- does that fairly and
22 accurately summarize your work experience at the Secretary
23 of State’s Office?
24 A. Yes. Yes. Basically, as I said, I was the
25 liaison between the counties and the Secretary of State.

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1 Q. Okay. And who hired you to come to work for

2 Fulton County?
3 A. My first direct supervisor was Brenda Williams,
4 and she was the registration chief at the time.
5 Q. Okay. So was she -- how long was she your
6 supervisor, or was she your supervisor?
7 A. She was. She was my direct supervisor and I
8 don't remember how long. It was probably around maybe two
9 years.
10 Q. All right. And what did she hire you to do?
11 What was your title?
12 A. My title was the registration manager at that
13 time.
14 Q. And what -- what were your duties and
15 responsibilities as the registration manager?
16 A. My duties were day-to-day operations, mostly on
17 the voter registration side, and absentee. We had two
18 managers at the time. I started with voter registration,
19 but soon was moved to absentee.
20 Q. Okay. And what did you do in -- let’s break
21 those down. What were -- what did you do on a day-to-day
22 basis as registration manager in the area of voter
23 registration?
24 A. Okay. One of the things you have to do is assign
25 work to your staff in order to make sure that voter

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1 registrations get processed, daily data entry, and that

2 voter -- the cancellations of -- any list maintenance that
3 needs to be done as far as cancellation of people who have
4 passed or processing felons against the voter registration
5 database, being able to call a hearing, just maintaining
6 the voter registration roll on a daily basis.
7 Q. Okay. And then, you say you kind of transitioned
8 over more to absentee area?
9 A. Yes, sir.
10 Q. And what -- what were your day-to-day duties and
11 responsibilities, like, for dealing with absentee voters?
12 A. Well, in the beginning, Fulton County purchased a
13 mailing system -- reliable mailing system from Pitney
14 Bowes, and I was -- I was the one who actually began the
15 process of running that machine. It was a million-dollar
16 piece of equipment and that equipment stuffs the ballots
17 and then takes a picture of the ballots as they’re going
18 out so that we can be confident about the process of
19 absentee. So I was the original person who learned that
20 machinery, put the procedures in place, and then -- and
21 then transferred over with the process on processing the
22 applications and the ballots at that -- you know, at a
23 later time.
24 Q. Is that Pitney Bowes mailing system still being
25 utilized?

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1 A. Yes, it is.
2 Q. And just so that I can understand -- I’ve never
3 seen that machine obviously, so help me to understand what
4 you do with the machine. You -- you say it stuffs the
5 ballots and it takes a picture of the ballots.
6 A. Right. What happens is that a ballot is printed
7 with a barcode on the ballot. What -- what’s on the
8 barcode is actually the ballot style. What happens is the
9 Pitney Bowes machine actually reads that barcode. It is
10 sent a file of voters with a specific ballot style. Once
11 it reads that ballot style on the ballot, it goes out and
12 finds which voter actually has that particular ballot
13 style. After it gets through stuffing and folding the
14 ballots into the envelopes, it sprays the voter’s name on
15 the envelope. It sprays it on the outer envelope and the
16 inner envelope. The outer envelope is white and what’s on
17 the outer envelope is just the name and address and a
18 mailing code at the bottom so it can read the mail. The
19 inner envelope which is placed inside, it sprays the
20 person’s registration number and their name so that when
21 it comes back, we can track to see if we received that
22 particular ballot coming back. After -- after it goes
23 through the system, we then send it to -- we have two
24 pieces of equipment. One is the inserter and one is the
25 sorter. After it goes through the inserter and it goes

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1 through all its checks, we put it in the sorter. The

2 sorter actually takes the picture of the ballot as it’s
3 going out, so it shows that we actually got a ballot image
4 of the ballot actually physically going out.
5 Q. Okay. And how long do you retain those images of
6 the ballots going out?
7 A. Probably about two years. We try to keep them as
8 long as possible, but we usually stop at about two years.
9 Q. Okay. And for the November 3, 2020 election, do
10 you still have those images of the ballots going out?
11 A. Well, in November 20 -- the November 3rd, we did
12 not use Pitney’s balloting system. What we did is opt out
13 to Runbeck. Runbeck actually did our ballots in November.
14 The State had a vendor and we contracted with Runbeck in
15 order to mail our ballots. The volume was so great that
16 even with our Pitney Bowes system, we didn’t think that we
17 would be able to maintain the volume.
18 Q. Okay. So Runbeck is located in Arizona, I
19 believe?
20 A. Yes, sir.
21 Q. And if you would, kind of summarize for me what
22 Runbeck did for Fulton County in the November 2020
23 election.
24 A. Sure. What we did is that we sent Runbeck a
25 file. We sent Runbeck a file to tell them who was

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1 supposed to receive an absentee ballot. Then, what

2 Runbeck would do is take that file and begin to mail all
3 the voters the ballots that are on that file to the voters
4 of Fulton County.
5 Q. And this is -- we’re talking about absentee
6 ballots, right?
7 A. Yes, sir.
8 Q. So when would that process of sending files to
9 Runbeck of absentee voters who had -- to whom you wanted
10 absentee ballots to be sent, when would that have begun
11 for the November election in 2020?
12 A. Well, the law says 45 days, so I’m assuming it
13 was around -- somewhere around that time. We have the
14 first run which is a major run. Usually the first run is
15 an accumulation of all the people who have -- all the
16 elderly and disabled people who have already asked for a
17 ballot. Their application roll over for the whole year.
18 So the first run is pretty -- a pretty good sum of a run,
19 and then afterwards, as we receive the absentee
20 applications, we will submit those to Runbeck to mail from
21 that point on.
22 Q. Okay. And how quick is the turnaround that
23 Runbeck is able to provide when you send them a file?
24 A. Two days. It should be two days.
25 Q. Okay. It’s my understanding -- well, first of

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1 all -- let me strike that.

2 How many absentee ballot files -- or absentee ballots
3 were sent, say, 45 days prior to the election, if you
4 recall?
5 A. Prior to the election, I don't know how many
6 files that we actually submitted to Runbeck.
7 Q. You don’t -- you don’t have any idea
8 approximately the number?
9 A. I would think it was around -- because Runbeck
10 had set times on mailing. They didn’t mail every day.
11 Like, they had set days that they were going to pull
12 files, so I’m not sure exactly how many runs did Runbeck
13 actually make. They didn’t do a daily run.
14 Q. Yeah. That’s not my question as to how many
15 daily runs there were. I’m -- I’m asking how many
16 absentee ballots, say, would have been submitted in files
17 to Runbeck as part of their first run, the largest run?
18 A. Oh, the first run, I -- I really don’t remember.
19 It -- but it was the largest that we’ve ever seen. I can
20 say that much.
21 Q. Was it over 147,000 or --
22 A. I doubt it.
23 Q. Okay. So do you have records of these files and
24 when they were submitted to -- to Runbeck?
25 A. We have -- we have records of those.

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1 Q. Okay. And -- and tell me what those files would

2 generally show.
3 A. It would show a person’s name, their registration
4 number, whether a ballot needs to be mailed, and what kind
5 of ballot style that they will have. Also, if there was a
6 reason why a person was voting absentee, whether they were
7 elderly, disabled (unintelligible). That’s about it.
8 Q. Okay.
9 A. The date that the application came in so they’ll
10 know when to pull the ballot.
11 Q. All right. And is it -- if we were to be given
12 access to those files, would we be able to -- from those
13 files to determine how many absentee ballot requests there
14 were made to Runbeck to be printed?
15 A. Well, the actual files now, I’m not sure where
16 they are, but we can have a chart of the daily work that
17 was given from the time -- the start to ending -- to the
18 end time of how many applications have come in.
19 Q. Okay. And are those the kind of records that
20 you’d generally keep for two years, too?
21 A. Yes, sir.
22 Q. Okay. And who is the custodian of those records,
23 those files?
24 A. Those files would be in my office. It would be
25 us, the Fulton County Registration Office.

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1 MR. CHEELEY: Okay. For the record, I would

2 request a copy of those files, Ms. Ringer.
3 MS. RINGER: Give me the specific --
4 MR. CHEELEY: So --
5 MS. RINGER: Ralph.
6 THE WITNESS: It’s our absentee daily count file.
7 MR. CHEELEY: Thank you.
8 BY MR. CHEELEY:
9 Q. So the -- when you sent these files or these
10 requests for absentee ballots, is that submitted
11 electronically in, like, a secure manner?
12 A. Well, since the contract is with -- Runbeck had
13 the contract with the Secretary of State, the actual
14 Secretary of State actually pulled the file based on the
15 data entry that we had in the election (unintelligible).
16 So the file was sent from the Secretary of State’s Office,
17 given to Runbeck to process the applications. What --
18 Q. Okay.
19 A. What they did is just receive the file from the
20 data entry that we made.
21 Q. Okay. So how many separate files were sent to
22 Runbeck? I guess the request was originated by your
23 office to the Secretary of State; is that right, and then
24 they would make the request to Runbeck?
25 A. No. No. Runbeck actually had a timeline of the

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1 dates that they would need the files, so everybody

2 understood that Runbeck would, as of this particular day,
3 they were going to pull the data entry file, the absentee
4 file, and based on that day, they will run anything that
5 was timely based on their pull of data. And it had to be
6 around -- I think around two to -- two times a week that
7 -- somewhere two to three times a week for each pull, so
8 they had -- they had given us a chart of the dates that
9 they would be pulling these absentee files that the State
10 would be pulling at the time.
11 Q. Okay. Did you -- at Fulton County -- when I say
12 you, I’m talking about Fulton County. Did you communicate
13 to the Secretary of State what you needed in the way of
14 absentee ballots and -- and how did you do that?
15 A. When -- I just want to make sure I understand
16 your question. You’re saying what I needed as far as did
17 I communicate with the State -- the order that we were
18 going to submit to them in order for Runbeck to complete
19 the job? Is that -- is that the question?
20 Q. Yes.
21 A. Okay. No, I did not. Based on the file itself,
22 the State could see how many voters needed to be
23 processed. So therefore, I did not submit any requests
24 through the Secretary of -- to the Secretary of State.
25 Q. Okay. So how did -- after the first big, I

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1 guess, order for absentee ballots, the first big run, I

2 guess is the term -- the phrase you used for people who
3 are elderly and that sort of thing. How many additional
4 requests for ballots were made to Runbeck to print
5 additional runs?
6 A. I want to say it was about two times a week, if I
7 remember correctly. They pulled the file for running that
8 approximately, I think, two times a week.
9 Q. So that -- that would be within 45 days of the
10 November 3rd election; is that correct?
11 A. That is correct.
12 Q. And so the -- you’ve got records, I guess, that
13 show how many ballots were requested at each time within
14 that 45-day period?
15 A. Yes. We have records that show how many ballots
16 were recorded daily.
17 Q. Do you have a -- does Fulton County enter into a
18 contract with Runbeck in addition to any agreements that
19 -- that the Secretary of State would have with Runbeck?
20 A. We went straight to the Secretary of State. The
21 State gave us an opportunity to -- to fill out an
22 application for Runbeck to do the process.
23 Q. Okay. And so you said they’ve got -- Runbeck has
24 a two-day turnaround? From -- from the time that you
25 request additional absentee ballots, they can get them

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1 mailed out within two days?

2 A. Yes, that’s the law. I’m assuming that since
3 that’s the law -- the law that we have to abide by, I’m
4 assuming that Runbeck was under the same laws that we
5 were.
6 Q. Okay. Did Runbeck print the absentee ballots
7 plus the two envelopes?
8 A. Yes, sir. They printed the ballots and stuffed,
9 and mailed the envelopes.
10 Q. All right. Did there come a time when Fulton
11 County printed some absentee ballots in-house?
12 A. Yes.
13 Q. And when was that done?
14 A. It was the last week prior to the election.
15 Q. And why was that done?
16 A. We perceived that since Runbeck was in Arizona,
17 we wanted to make sure that the voters -- the State
18 actually cut it off, and that my assumption was that they
19 wanted to make sure that the voters had enough time to
20 receive their ballots and that it should have been mailed
21 closer to home than from Arizona.
22 Q. So were you getting a request for -- online for
23 absentee ballots that -- within that week before the
24 election?
25 A. Yes, sir. The deadline to request is the Friday

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1 before.
2 Q. Okay. And how many requests were you getting
3 that Runbeck you felt like couldn’t get them here in time?
4 A. I don't know the number, but it was still a
5 sizable job for us even during that last week.
6 Q. So tell me about the -- do you know how many
7 absentee ballots that Fulton County produced in-house
8 right there before the election?
9 A. I don't know the number off the top of my head,
10 but the chart will show the number that we received and
11 the ones that we mailed.
12 Q. Okay. All right. And is that something that you
13 can give to Ms. Ringer to provide to us, please, sir?
14 A. Yeah. It’s the same thing that she’s going to
15 produce earlier that we talked about.
16 Q. Okay. Okay. Did -- did Fulton County also
17 produce envelopes -- outer and inner envelopes to go with
18 those?
19 A. Yes. So the outer envelope is a little different
20 from, obviously, the Runbeck version. So, yes, we do
21 produce the outer and the inner envelopes.
22 Q. So how are these -- those envelopes different
23 from the ones that Runbeck printed and you sent out?
24 A. The outer envelope was -- I think ours is a
25 little taller than Runbeck’s. Runbeck’s was a little

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1 wider. The inner envelope, I think, was the same

2 envelope.
3 Q. Are those envelopes that you ordered from a
4 third-party supplier or how --
5 A. Yes.
6 Q. And where were those from?
7 A. I think it’s called HB Solutions.
8 Q. HB?
9 A. Yes.
10 Q. What color were these outer envelopes and inner
11 envelopes?
12 A. The outer one was white; the inner one was
13 yellow.
14 Q. Were they --
15 A. I just remembered that Runbeck ones were white
16 and yellow, and ours were totally yellow.
17 Q. So Runbeck’s outer envelope was white and yellow?
18 A. Theirs was white and yellow, yes.
19 Q. And Fulton’s was -- outer envelope was solid
20 white?
21 A. That is correct.
22 Q. Okay. What were the colors of the inner
23 envelopes between Fulton’s and Runbeck’s?
24 A. Yellow and yellow.
25 Q. Yellow and yellow?

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1 A. Yes, sir.
2 Q. Were they -- did they -- were they pretty much
3 identical in appearance?
4 A. It was something different about it, but I don't
5 remember off the top of my head what the difference was.
6 Q. Okay. And do you have records that would
7 indicate how many envelopes you would have ordered from --
8 what was it called -- HB Solutions?
9 A. Yes. We should have an invoice that talks about
10 the number of envelopes that we have.
11 Q. Okay. Do you -- when the absentee ballots come
12 in to Fulton, do they come to Fulton’s Board of Elections
13 offices?
14 A. Yes, they come directly to our mailroom.
15 Q. Okay. And where is that mailroom located?
16 A. It’s on the ground floor of the Government
17 Center, 141.
18 Q. What information is on the outer envelopes that
19 you -- first of all, that Fulton County would have ordered
20 from HB Solutions?
21 A. The -- the outer envelope is a blank envelope,
22 just with the return address on -- as we receive it from
23 HB Solutions.
24 Q. Does it have a barcode on it?
25 A. Not at the time yet.

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1 Q. Okay. What do you mean by that?

2 A. When they send us an envelope -- when HB
3 Solutions sends us an envelope, it’s just a regular
4 envelope. It just has a return address and an open window
5 for us to spray in, and no -- no mailing address. Once it
6 -- once the process begins with the Pitney Bowes system,
7 we spray everything onto the envelope.
8 Q. Okay. And so -- so the outer envelope comes from
9 HB Solutions; it’s -- it’s a plain white envelope with
10 Fulton County’s return address on it, correct?
11 A. That is correct.
12 Q. No other information, correct?
13 A. No other information for the outer envelope.
14 Q. All right. And then, you -- Fulton County uses
15 the Pitney Bowes million-dollar piece of equipment to
16 spray additional information on it, correct?
17 A. Correct.
18 Q. And tell me in detail what additional information
19 is sprayed on it.
20 A. On the outer envelope, there is name, address,
21 and IMB code, which is a tracking mechanism that the Post
22 Office uses.
23 Q. What’s that called again?
24 A. IMB.
25 Q. IME code?

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1 A. B as in boy. I-M-B as in boy.

2 Q. Oh, IMB?
3 A. Yes.
4 Q. And so that’s sprayed on the back or the front?
5 A. The front.
6 Q. And that’s for the benefit of the Postal Service?
7 A. That is correct.
8 Q. And this Pitney Bowes equipment puts that code on
9 the front of the envelope, correct?
10 A. Yes, sir.
11 Q. And that’s a -- you say that’s a tracking code?
12 A. Right. It -- it actually, in short, instead of
13 for the machine to read the physical address, it
14 translates that physical address into some sort of
15 readable that the Post Office machine can read so it can
16 be sorted electronically, quicker.
17 Q. All right. Do each -- I guess other than the
18 person’s name and address to whom the envelope is
19 addressed, is the IMB code, does it have a unique number
20 for each envelope, or is it just an area directing it to a
21 particular physical location?
22 A. It’s the latter. As I’ve said, it’s just
23 basically the address of the voter so that the Post Office
24 machine can read that particular -- it’s like a barcode
25 almost so that the Post Office machine can read that one

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1 and process it timely.

2 Q. So if it’s a barcode with a unique physical
3 address, that is a unique identifier for the outer
4 envelope, then, correct?
5 A. Correct.
6 Q. Okay. Anything else on the outer envelope that’s
7 sprayed on by the Pitney Bowes machine?
8 A. Well, sometimes if we have -- if we have some
9 money in the budget, we can also spray a stamp on it. But
10 for November, we did not have funds on the machine to
11 spray the stamp.
12 Q. And the stamp --
13 A. Postage stamp.
14 Q. The postage?
15 A. Uh-huh.
16 Q. That’s -- that’s up to each county, I guess, as
17 to whether or not they’re going to provide prepaid
18 postage?
19 A. Correct.
20 Q. But in the November 2020 election, Fulton County
21 did not have the funds to spray on the postage, correct?
22 A. Not on the machine. Correct.
23 Q. All right. Anything else on the outer envelope
24 that’s sprayed on or applied by Fulton County?
25 A. No, sir.

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1 Q. Okay. So the inner envelope -- first of all, let

2 me ask you, what are the approximate measurements of the
3 outer envelope? Is it -- do you have an exemplar there
4 with you somewhere?
5 A. No, sir. No, sir. It’s about eight and a half
6 by seven, maybe.
7 Q. Eight and a half inches by seven inches?
8 A. Yeah.
9 Q. Okay. So it overall kind of has the appearance
10 of a square instead of a rectangle?
11 A. Yes. But that one inch makes it a little bit
12 like a rectangle. Uh-huh.
13 Q. Yeah. But like a business -- a business envelope
14 is a lot longer than it is tall.
15 A. Correct.
16 Q. How about the -- the inner envelope? Tell me
17 about the inner envelope that was used by Fulton County to
18 mail out absentee ballots that you -- did you obtain those
19 as well from HB Solutions?
20 A. Yes, I did.
21 Q. Where is HB Solutions located?
22 A. It’s in Atlanta.
23 Q. Okay. And it -- the inner envelope was yellow,
24 correct?
25 A. Correct.

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1 Q. And can you give me an idea as to the approximate

2 size of the inner envelope?
3 A. Well, I would say it’s about five by seven,
4 maybe.
5 Q. That was five inches by seven inches?
6 A. Correct.
7 Q. Okay. Tell me what, if anything, was sprayed
8 onto or -- let me break that down. First of all, when you
9 got those envelopes from HB Solutions, they were five by
10 seven. Did -- did you require HB Solutions to have
11 anything printed on those envelopes?
12 A. Well, what happens is that HB Solutions actually
13 makes the envelopes and -- yes. Well, it’s -- printed on
14 the envelope is a return address at the top left-hand
15 corner, a mailing address that would come back to Fulton
16 County, and on the back of the envelope is the oath that a
17 person has to sign. So HB Solutions overlays the oath,
18 the return address, and the mailing address.
19 Q. So on the -- on the front of that envelope is
20 printed by HB Solutions a return address to Fulton County,
21 correct?
22 A. Correct.
23 Q. And that would be in the upper left-hand corner,
24 I take it?
25 A. Yes, sir.

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1 Q. And then on the back -- I’m sorry. What else is

2 on the front, did you say?
3 A. The mailing address of Fulton County so the
4 ballot can get back to us.
5 Q. Okay. So -- so you’ve got Fulton County’s
6 address on there twice?
7 A. Correct.
8 Q. Okay. So it’s in the middle of the front of the
9 envelope and also up in the upper left-hand corner of the
10 envelope?
11 A. Yes, sir.
12 Q. Okay. And then, anything else printed on the
13 front of the envelope by HB Solutions?
14 A. No, sir.
15 Q. Okay. On the back of that envelope is the oath?
16 A. Yes, sir.
17 Q. And that’s printed by HB Solutions, correct?
18 A. Yes, sir.
19 Q. Anything else applied to the back of the envelope
20 by HB Solutions?
21 A. No, sir.
22 Q. Okay. And so that envelope, I think you said
23 earlier it’s a solid yellow envelope, correct?
24 A. Correct.
25 Q. Okay. Now, how about the same question for

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1 Runbeck’s outer envelope? You said it was yellow as well?

2 A. The outer one?
3 Q. I’m sorry. I made a mistake there. Their --
4 their inner envelope --
5 A. Yeah.
6 Q. -- I think you said was --
7 A. It was yellow.
8 Q. Is it about the same color yellow --
9 A. Yeah, it’s --
10 Q. -- as Fulton?
11 A. Yes, it was. It’s about the -- about the same
12 color.
13 Q. And tell me what Runbeck would have applied or
14 sprayed on or printed on those envelopes, the -- the inner
15 envelopes?
16 A. I’m not 100 percent certain because that was
17 their envelope. So I’m not, you know, 100 percent certain
18 what was actually developed on theirs, but I know that
19 they had to have the Fulton County -- I don't know if it
20 was sprayed on, how it got on there, but it did have the
21 Fulton County mailing address on the envelope, and --
22 Q. Would it have also --
23 A. -- it had -- and it had the oath on it, also.
24 Q. Okay. The oath being on the back of the envelope
25 as well?

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1 A. Yes, sir.
2 Q. Okay. How about any kind of barcodes, identifier
3 on the Runbeck outer or inner envelopes, like the IMB
4 code?
5 A. I’m for sure it probably had an IMB on the outer.
6 That’s just standard postage -- Post Office etiquette.
7 But as far as the inner one, by the time we received it,
8 there was a barcode attached to the inner envelope.
9 Q. And where was that barcode on the inner envelope?
10 A. It was on the back closer to the flap, I would
11 think. It’s just so that a person can be identified -- a
12 vote could be identified by a person.
13 Q. That -- you say that was so that the envelope --
14 we’re talking about here about the inner envelope; is that
15 correct?
16 A. That is correct.
17 Q. And -- and you said that the inner envelope made
18 by Runbeck had a barcode and it was on the back?
19 A. Yes, sir.
20 Q. Do you have any leftover or exemplar Runbeck
21 outer and inner envelopes?
22 A. I think we might have some, yes, sir.
23 Q. Okay. Would you mind if Ms. Ringer supplied us
24 with exemplars of those inner and outer envelopes from
25 Runbeck?

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1 A. Yes.
2 MS. RINGER: I have a question with regards to
3 exemplar. You -- are these envelopes that were or
4 were not used?
5 MR. CHEELEY: I’m wanting -- I’m asking for ones
6 that were used for the November 2020 election.
7 MS. RINGER: You want Runbeck’s envelopes?
8 MR. CHEELEY: Yeah. I’d like Runbeck’s and also
9 the HB Solutions envelope, exemplars of all four,
10 inner and outer, Runbeck and HB Solutions.
11 MS. RINGER: Okay. We’ll have to speak more
12 about that, Mr. Cheeley. These are documents that are
13 in possession of the Clerk, I don’t believe that that
14 is something that I can alone provide you. We would
15 also need to get the Court involved, but I’ll make a
16 note and -- and we’ll discuss it Ms. Vaideeswaran.
17 MR. CHEELEY: All right. Thank you.
18 BY MR. CHEELEY:
19 Q. The -- if I understand your testimony, Mr. Jones,
20 the Runbeck outer envelope is a combination of white and
21 yellow, correct?
22 A. Correct.
23 Q. And so you -- between the HB Solutions envelopes
24 in appearance and the Runbeck envelopes, the basic
25 difference was the yellow and white envelope for the outer

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1 envelope was different whereas the outer envelope that --

2 that Fulton had HB Solutions prepare was white, correct?
3 A. Yes, sir.
4 Q. All right. So if Runbeck was receiving the
5 requests to mail out absentee ballots, the -- the yellow
6 and white Runbeck envelope should have never been, I
7 guess, received by Fulton County; is that right, unless it
8 was returned?
9 A. Unless it was returned mail.
10 Q. Okay. All right. So the way I understand this
11 would work is whether it’s with Runbeck supplying the --
12 the absentee voter with a ballot or it was Fulton County
13 supplying a voter with an absentee ballot, the ballot
14 would be -- just tell us, I guess, rather than me trying
15 to explain it to you, you explain it to me. How does --
16 what was the -- what were the instructions to the voter
17 when they received the ballot in the mail?
18 A. The instructions from Runbeck was -- told them to
19 vote the ballot, fill out the ballot, and place it in a
20 sleeve. Well, they sent out instructions saying place it
21 in the envelope, but Runbeck did not have an envelope.
22 They had a sheet of paper which was a sleeve and, you
23 know, with the help of the Secretary of State and our
24 communications department, we tried our best to notify the
25 voters that there is no envelope, that you had to have a

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1 sleeve and you wrapped your ballot around this sleeve or

2 sheet of paper and place it into the return envelope. For
3 Fulton County, the instructions said fill out your
4 absentee ballot, place it in the inner envelope, and then
5 place the inner envelope into your secrecy mailing return
6 envelope. So that was the only difference. The secrecy
7 inner envelope Fulton had, and Runbeck had a sheet of
8 paper which they called a sleeve that a person would wrap
9 their ballot into before placing it into the envelope that
10 was mailed back to us.
11 Q. Okay. What -- so when you’re saying that Runbeck
12 had a sleeve, is that something that had the appearance of
13 an envelope in some way?
14 A. To me, it looked like a white sheet of paper.
15 Q. Okay. And does it -- what’s the size of that
16 white sheet of paper?
17 A. Eight and a half by 11.
18 Q. Eight and a half by 11?
19 A. Yes, sir.
20 Q. Is that the -- is that something different from
21 the Runbeck yellow inner envelope?
22 A. Yes, sir.
23 Q. Okay. So in the -- with Runbeck, the voter would
24 get a white and yellow outer envelope, correct?
25 A. Correct.

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1 Q. They would get of course the ballot, correct?

2 A. Yes, sir.
3 Q. They would get an inner yellow envelope, correct?
4 A. Yes.
5 Q. And they would also get an eight-and-a-half piece
6 of paper that would -- that would wrap around their
7 ballot --
8 A. Yes, and --
9 Q. -- before they --
10 A. -- instructions.
11 Q. And instructions?
12 A. Yes.
13 Q. And then, the ballot would be inserted into the
14 inner yellow envelope along with the sleeve?
15 A. Right. Well, in order that the sleeve -- the
16 sleeve was supposed to wrap around the ballot before
17 inserting it into the yellow envelope.
18 Q. Okay. All right. So when these get -- when
19 these ballots get inserted into the envelopes, are the --
20 what are the dimensions of the ballots that were prepared
21 by Runbeck, generally, or do you know specifically?
22 A. I don't know their -- their measurements of their
23 ballots because all the ballots were eventually folded to
24 fit, so I don't remember what the actual size was of the
25 ballot.

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1 Q. Do you -- do you have, like, any documentation

2 from Runbeck that would specify what the size was?
3 A. We all -- as far as the ballot is concerned, we
4 all had the same ballot. So I don't know -- I don't
5 remember if it was a 19-inch ballot or a 21-inch ballot.
6 I’m not for sure the length of it. It was eight and a
7 half. I just don’t remember the length of the ballot off
8 the top of my head.
9 Q. So it -- you think it’s eight and a half in
10 width?
11 A. Yes, sir.
12 Q. And that would fit in the eight-and-a-half-by-
13 seven-inch envelope from Runbeck, correct?
14 A. Correct.
15 Q. But you’re not sure if it was 19 inches long or
16 maybe even 21 inches long?
17 A. That is correct.
18 Q. How many -- so when it comes from Runbeck in the
19 eight-and-a-half-by-seven-inch envelope, how many times
20 was it folded?
21 A. I think it’s a trifold.
22 Q. Okay. And so it was pre-folded, obviously, at
23 Runbeck, put into the outer envelope along with
24 instructions and the inner envelope which would be used to
25 -- by the voter to mail it back to Fulton County; is that

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1 fair to say?
2 A. Yes, sir.
3 Q. Okay. Not bad for an old country lawyer to be
4 able to follow all this, is it?
5 All right. So let’s talk about Fulton County, then.
6 You had a five-by-seven-inch envelope from HB Solutions,
7 right?
8 A. Yes.
9 Q. And -- oh, I left out one thing. There was a
10 sleeve that -- that would have been part of the Runbeck
11 mail to the -- of the absentee ballot to the voter,
12 correct?
13 A. Correct.
14 Q. Was there anything printed on that sleeve?
15 A. I don't remember. I don’t --
16 Q. And the purpose -- what is the purpose of the
17 sleeve; so that you can’t look through the envelope?
18 A. I -- I don't know. I really don’t know.
19 Q. Does state law specify you have to have a sleeve?
20 A. I’m not aware of that.
21 Q. Okay. All right. Let’s -- let’s talk then about
22 the Fulton County ballots that were printed in-house.
23 Those were -- would have been in a five-by-seven envelope,
24 correct?
25 A. Yes, sir.

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1 Q. What was the width of the ballots for the Fulton

2 County?
3 A. Same width, eight and a half by either 19 or 21.
4 Q. All right. So how do you get an eight-and-a-
5 half-inch-wide ballot into a five-by-seven envelope?
6 A. It must be eight and a half, then. I don't know.
7 Q. Okay. So the -- you’re thinking now that the HB
8 Solutions envelope was eight and a half --
9 A. Correct.
10 Q. -- by seven?
11 A. Because all -- the way we folded it, it had to be
12 at least wide enough to get the ballot in there.
13 Q. Okay. So I can’t remember if I’ve asked for
14 those purchase orders from HB Solutions. Do you have any
15 problem with Ms. Ringer providing those purchase orders
16 from HB Solutions so we can see the sizes of the ballots
17 and the envelopes? Mr. Jones?
18 A. Oh, yeah, I’m fine. I’m fine.
19 Q. I said, do you have any -- do you have any
20 problem with Ms. Ringer supplying us with a copy of the
21 purchase order of the ballots and the HB Solutions for the
22 in-house-produced ballots and envelopes?
23 A. Yeah, we should be able to get you that.
24 Q. All right. Thank you, sir.
25 So with -- what about the paper stock for the ballots

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1 and the envelopes that came from Runbeck? Did those -- do

2 you have the specifications on what the paper was for the
3 envelopes and the ballots?
4 A. No. I don’t have the details of what Runbeck’s
5 order was.
6 Q. Would that be something that you would have in
7 your office somewhere?
8 A. As far as the envelope size, I doubt it very
9 seriously. As far as the paper, we might -- we might can
10 get you what the paper looked like at Runbeck. I’ll have
11 to check with my -- my counterpart, the elections chief.
12 Q. The elections chief --
13 A. Right.
14 Q. -- where?
15 A. The elections chief. I’m the registration chief.
16 The elections chief is responsible for ordering the
17 ballots.
18 Q. Is that Mr. Barron?
19 A. No. That would have been at that time Mr.
20 Brower, Dwight Brower.
21 Q. Was he employed by Fulton County Board of
22 Elections?
23 A. Yes, he was.
24 Q. Is he still there?
25 A. No, he isn’t.

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1 Q. Did he -- when did he leave?

2 A. December -- the last week of December. Probably
3 like December 28th, the 29th, somewhere right around in
4 there.
5 Q. And -- and his title was elections chief?
6 A. Yes.
7 Q. What does the elections chief’s duties and
8 responsibilities generally entail?
9 A. The elections chief is over the in-person
10 elections. His job function relates to early voting,
11 absentee and in-person, jurisdiction over the poll workers
12 and the facilities for the elections.
13 Q. Did -- did Mr. Brower retire from --
14 A. Mr. --
15 Q. -- go into retirement?
16 A. Mr. Brower was brought on as a contractor to help
17 us through the election.
18 Q. So you say -- what was his prior experience or
19 did he have expertise as an elections chief?
20 A. Yeah. Mr. Brower was our elections chief.
21 During the year, we had an elections chief, but he moved
22 on to the Secretary of State. Therefore, in order to fill
23 that void with somebody who was experienced, we brought
24 Mr. Brower back in order to help us to finish the election
25 out.

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1 Q. When did you bring him back -- or Fulton County

2 bring him back?
3 A. I don't remember. It was -- I have to think. It
4 was probably early or midway through 2020.
5 Q. Okay. And has he gone back now with the
6 Secretary of State?
7 A. No. No. The -- the person who we originally
8 hired worked for us through the first election, the June
9 election, and afterwards got an offer from the Secretary
10 of State. He’s now employed with the Secretary of State.
11 Once he received his job at the Secretary of State, we
12 asked Mr. Brower to come and supplement our office to help
13 us finish out the remainder of the year.
14 Q. Okay. So I’m -- I may be a little confused here.
15 Who -- which of the elections chiefs is the one that went
16 to the Secretary of State’s Office?
17 A. Blake Evans.
18 Q. Okay. So Blake Evans left maybe in -- midway
19 through 2020 and went to the Secretary of State; is that
20 right?
21 A. Yes, sir.
22 Q. Okay. And did -- and you said Dwight Brower was
23 brought back in, I guess when Mr. Evans left?
24 A. That is correct.
25 Q. And -- and Dwight Brower was formerly the

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1 elections chief for Fulton?

2 A. Right before Blake. Correct.
3 Q. Okay. And did Mr. Brower -- when he was formerly
4 elections chief for Fulton, did he leave to retire or take
5 another job?
6 A. He left to retire.
7 Q. Okay. And so he came back out of retirement,
8 basically, in mid-2020 and worked until the end of 2020?
9 A. Yes, sir.
10 Q. Okay. And is Mr. Brower living in the Atlanta
11 area --
12 A. Yes.
13 Q. -- as far as you know?
14 A. He still lives in the Atlanta area.
15 Q. Okay.
16 A. Covington, if you consider Covington Atlanta.
17 Q. Covington. Okay. So let me know if you’re --
18 whenever you want to take a break, okay? I’m not -- this
19 isn’t an endurance contest.
20 A. Okay. I’m fine.
21 Q. Okay. Let me add -- I’ve got just a couple more
22 questions and I need to take a break.
23 A. Okay.
24 Q. So the -- let me ask you about the in-house
25 ballots that were printed by HB -- or I’m sorry -- that

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1 were printed by, I guess, Fulton County. Do you all have

2 the -- some particular or special machines to print
3 ballots?
4 A. We just have regular printers. The State, when
5 they won the new contract, they gave us the ability to do
6 Ballot On Demand, gave us three printers and the ability
7 to print ballots from three printers.
8 Q. Do those ballots that were printed in-house for
9 absentee ballots by Fulton County, do those have, like, a
10 barcode on them as a unique identifier on the ballot
11 itself?
12 A. No. The -- let me make sure I understand.
13 You’re saying the original paper or once it was printed?
14 Let me make sure we’re on the same --
15 Q. Well --
16 A. What happens --
17 Q -- I guess --
18 A. -- is that the paper is just a blank sheet of
19 paper upon receiving it and once we print the ballot,
20 everything goes onto the ballot that we would normally
21 need in order to process.
22 Q. Where do the -- who supplied the paper for those
23 in-house-produced ballots from Fulton County?
24 A. I believe Fidlar was our -- was our paper
25 supplier at the time.

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1 Q. Pitney?
2 A. Fidlar, F-I-D --
3 Q. Fidlar?
4 A. -- yeah, L-A-R. Uh-huh.
5 Q. F-I-D-L-A-R, Fidlar?
6 A. Yes.
7 Q. Where is -- is that the name of the company,
8 Fidlar?
9 A. That is the name of the company.
10 Q. Are they -- where are they based?
11 A. I think they’re based in Florida.
12 Q. Did -- you said they’re based in Florida?
13 A. Yes, sir.
14 Q. And they would just supply you with the blank
15 paper, correct?
16 A. Correct.
17 Q. Did you enter -- did you have like a purchase
18 contract or something with Fidlar for the ballots?
19 A. I’m assuming we had to have some sort of contract
20 with them.
21 Q. And would that contract have specified the size
22 of the paper and the paper weight and stock
23 characteristics?
24 A. I’m assuming it did. As I said, that -- that
25 would be under the elections chief’s jurisdiction, but I

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1 was asked basically how large the ballot was then and I
2 would give them the specs that we would need, but other
3 than that, that would have been under the elections
4 chief’s jurisdiction.
5 Q. Who took over the -- I’m sorry. Did you finish
6 your answer?
7 A. Yes.
8 Q. Who took over as elections chief January of this
9 year, 2021?
10 A. The new elections chief now is Nadine Williams.
11 Q. Nadine Williams?
12 A. Yes, sir.
13 Q. Okay. And was that -- Nadine Williams, was that
14 an internal promotion for her?
15 A. Yes, it was an internal promotion.
16 MR. CHEELEY: Okay. All right. We’ll take --
17 let’s take a 15-minute break. It’s right now 11:04,
18 is it? Yeah, 11:04. So we’ll come back in 15
19 minutes.
20 THE VIDEOGRAPHER: Going off the video record at
21 11:04 a.m.
22 (OFF THE RECORD: 11:04 AM)
23 (ON THE RECORD: 11:22 AM)
24 THE VIDEOGRAPHER: We’re back on the video
25 record. This is the beginning of media file number

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1 two. The time is 11:22 a.m.

2 MR. CHEELEY: Mr. Jones, we’re going to go
3 probably until around 12:15, 12:30 and take a lunch
4 break; is that okay with you?
5 THE WITNESS: That’s fine with me.
6 MR. CHEELEY: Okay.
7 THE WITNESS: Now, can you -- can you tell me an
8 estimated time when we might be finished?
9 MR. CHEELEY: We should be done by Thursday, I’m
10 sure.
11 (LAUGHTER IN THE ROOM)
12 THE WITNESS: Okay.
13 MR. CHEELEY: No, we’ll -- we’ll get done, you
14 know, this afternoon some time. I’m not -- I’m not
15 able to narrow it down. Maybe -- do you have some
16 place you’ve got to be today, or you just don’t want
17 to be here?
18 THE WITNESS: Oh, no. You always have some place
19 else to be, but, you know what I mean, we -- we’re
20 taking time out for this deposition, so --
21 MR. CHEELEY: Okay. Well, I’m going to try to be
22 as expeditious as possible. I’m not going to -- I’m
23 not into wasting people’s time, okay?
24 THE WITNESS: Okay. Thank you. Just trying to
25 get some sort of time schedule, so -- just making sure

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1 I articulate that to my staff and --

2 MR. CHEELEY: Okay.
3 BY MR. CHEELEY:
4 Q. All right. I’ve got a few more questions about
5 the in-house ballots that Fulton County printed. Do you
6 -- tell me about these three printers that I think you
7 said the in-house ballots were printed on, and were those
8 printers, you say, given to Fulton County by the Secretary
9 of State?
10 A. Yes, sir.
11 Q. Did the Secretary of State issue any kind of a
12 written state-wide policy that in some way stated that it
13 was okay for counties to print their own ballots?
14 A. I think -- I think what they said is that the
15 counties are responsible for printing ballots after
16 Runbeck’s last day, if that’s enough information. We knew
17 when Runbeck’s last day was and then it was the county’s
18 responsibility to make sure they issued the ballots to the
19 voters from that time on, and they did notify us of that.
20 Q. So as you sit here today -- I’m looking at my
21 calendar for last October. October 30th was a Friday, and
22 then the November 3rd election was, you know, five days
23 later -- or four days later, I guess, on Tuesday. So when
24 do you think Runbeck’s last day for printing and mailing
25 out absentee ballots would have likely been?

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1 A. We had the week prior to and that Friday prior

2 to. So I think Runbeck’s last day was that Thursday, if I
3 remember correctly.
4 Q. Would that have been Thursday the 29th or
5 Thursday the 22nd?
6 MS. RINGER: This is Ms. Ringer. I’m showing Mr.
7 Jones my computer with the calendar for October pulled
8 up.
9 THE WITNESS: The 22nd would probably have been
10 their last day.
11 BY MR. CHEELEY:
12 Q. Okay. So again, do you remember, was there a
13 policy issued by the Secretary of State’s Office to all
14 the counties in Georgia telling them that it was okay to
15 print their own ballots after October 22nd?
16 A. Correct. And not only that one, each person had
17 the ability to opt out whether they wanted to for Runbeck
18 to print it or not. So a county could have not wanted
19 Runbeck’s -- Runbeck’s help in printing and mailing the
20 ballots, so they could have been processing absentees on
21 their own for the whole process. Fulton just acknowledged
22 that it would have been better for Runbeck to have done it
23 in the beginning and then after that, we would take over
24 afterwards.
25 Q. I see.

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1 A. Originally, Runbeck was taking over. As time

2 went on, we noticed that the delivery -- the mail from
3 Arizona was taking a little longer to get to the voters,
4 so that’s why the Secretary of State decided that it would
5 be better for the counties to take over the process in the
6 last week so that the voters would get their ballots in a
7 timely fashion.
8 Q. Okay. Was the -- so the Secretary of State
9 provided three, I guess -- are they standard copiers to
10 print ballots on?
11 A. They were printers. It’s an OKI printer. It was
12 -- the ones that they provided, I would call a second-tier
13 printer. Fulton, you know, we needed a little bit more
14 heavy-duty because of the number of volumes that we had.
15 But they did provide that OKI -- I think it was a 500-
16 series and I think now we have something like the 800-
17 series printers.
18 Q. And where were those -- how many of those OKI 500
19 printers did the Secretary of State provide?
20 A. You said how many?
21 Q. Yes. How many?
22 A. Three.
23 Q. And where were those printers set up?
24 A. They were set up in our mailroom, in the same
25 room as the Pitney Bowes machine.

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1 Q. And is that at the downtown Fulton County

2 Government building?
3 A. Yes, on the ground floor.
4 Q. All right. And tell me about when you -- when
5 you print on those OKI 500 printers, do you have to have
6 software that sets up the -- what the ballot is going to
7 look like?
8 A. Yes. The State gave us software in order to
9 print. The software that was given was Dominion software,
10 and we felt that the software that was given to us wasn’t
11 adequate enough for Fulton in order to process the ballots
12 in a timely fashion. We had --
13 Q. Why is that?
14 A. We had the capabilities before Dominion’s Ballot
15 on Demand. We had the capabilities to send our printers a
16 file of several ballot styles at one time and it was able
17 to handle several ballot styles at one time. The Dominion
18 software just allowed us to handle one ballot style at a
19 time for printing. So for example, if -- if we had ten
20 ballot styles and we had ten different -- a quantity for
21 each ballot style, being ten, we couldn’t send all ten
22 with a quantity of ten at one time. We would have to sit
23 down, pull up the ballot style, and print ten copies of
24 that ballot style, and continue on until all ten ballot
25 styles were completely printed.

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1 Q. I see. And so was there a reason that -- that

2 you could not use the Pitney instead of the --
3 A. Well, the original Ballot on Demand was done by
4 ES&S and since ES&S did not win the contract for the State
5 system and Dominion did, they pulled out of their Ballot
6 on Demand portion of the procedures.
7 Q. What was the name of that company? ES&X?
8 A. ES&S, yes.
9 Q. Is that like E as in Edward, S as in Sam,
10 ampersand maybe, and X?
11 A. S as in Sam.
12 Q. So ES&X?
13 A. S as in Sam. The last -- the last letter is S as
14 in Sam.
15 Q. Oh, ESS?
16 A. E -- E as in egg, Sam -- S as in Sam, the & sign,
17 S as in Sam.
18 Q. I gotcha. Okay. So Dominion -- and you’re
19 saying that Dominion did not have Ballot on Command -- or
20 on Demand?
21 A. Yeah. What they proposed as Ballot on Demand was
22 not -- was useless for Fulton.
23 Q. Why was it useless?
24 A. Because the -- the software was made for a small
25 county. Let me say it that way. The software -- the

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1 ballot printing was made for a very small or intermediate

2 county. We deal with big volumes and we need the
3 flexibility to print in volumes. And with the number of
4 ballot styles that we have -- you know, we have a minimum
5 of 320 ballot styles, easily, and with the number of
6 ballot styles that we had, it was just cumbersome the way
7 that they had projected for us to do it.
8 Q. Okay. And is that because of all the different
9 precincts with different representatives --
10 A. Correct.
11 Q. -- on each -- how many different precincts are in
12 Fulton?
13 A. I think we’re at 355 now, if I remember
14 correctly.
15 Q. Also, I meant to ask you, I guess, earlier. Does
16 -- does your office handle the elections for any of the
17 cities located inside of Fulton?
18 A. Yes.
19 Q. Which ones?
20 A. We handle all of them except Palmetto and
21 Mountain Park.
22 Q. Okay. Do you handle the elections for all the
23 other ones, then?
24 A. That is correct.
25 Q. Okay. And how long have you done that?

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1 A. Ever since I’ve been here, so it’s gone on

2 further. Obviously, some of the municipalities might come
3 in and out. I remember that Chattahoochee Hills did
4 theirs for one time, but, you know, elections are becoming
5 so harder than usual, so the cities actually contract out
6 with the county in order to perform that task.
7 Q. Okay. I see. So let’s get back to these three
8 printers, these second-tier printers that you described
9 that the Secretary of State’s Office provided. And these
10 were by the company OKI; is that O-K-I?
11 A. Yes.
12 Q. Did the -- when did the printers get delivered to
13 Fulton County to go into use?
14 A. We had them well before the 45 days because we
15 were going to use them to mail. So I’m not sure when, but
16 they were there before the 45th day of mailings.
17 Q. And when -- when was the decision made to start
18 printing ballots in-house on those three printers?
19 A. Probably around two weeks -- a little more than
20 two weeks prior to the election.
21 Q. So that would have been somewhere around October
22 the 22nd or the week --
23 A. No, before that. The week prior to the 22nd.
24 Q. Okay. So that -- I’m looking at my calendar from
25 last October. That would have been October the 12th, the

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1 week of the 12th?

2 A. I believe that’s right. Yes, probably around the
3 week of the 12th.
4 Q. Okay. So tell me who was assigned to -- to be in
5 charge of beginning the process of printing in-house
6 ballots.
7 A. Well, the person in charge of the mailroom and
8 printing of the ballots is -- her name is Caryn Ficklin,
9 F-I-C-K-L-I-N.
10 Q. Would you spell that last name again, please,
11 sir?
12 A. F-I-C-K-L-I-N.
13 Q. Okay. Ficklin?
14 A. Yes.
15 Q. And her title is what?
16 A. Registration supervisor.
17 Q. All right. And tell me what you remember about
18 any meetings that you had with Caryn Ficklin and -- and
19 maybe anybody else that would have been involved in
20 discussing the printing of in-house ballots.
21 A. As soon as -- as I said earlier, we noticed the
22 lag time between the ballots being mailed from Arizona to
23 Georgia and how long it was taking for voters to get their
24 ballots. So the Secretary of State understood that if
25 they kept going that route, people might not have gotten

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1 their ballots in time. So their conclusion was to allow

2 the counties to mail the ballots so that the voters would
3 get their ballots back. Upon hearing that news, I talked
4 with Ms. Ficklin and suggested to her that, you know,
5 we’re going to -- we are going to take back the mailing
6 and to make sure that we have enough staffing for her in
7 order to complete her tasks.
8 Q. Okay. And was anybody else other than you and
9 Ms. Ficklin involved in those discussions?
10 A. Mainly it was me and Ms. Ficklin, obviously that
11 -- Rick Barron, the director. We eventually went to him
12 and told -- told him the plan that we had and what we were
13 planning on doing.
14 Q. Okay. How about Dwight Brower; would he have
15 been involved in those discussions, too?
16 A. Possibility. It’s not definite that Dwight was
17 in there. He -- he wouldn’t have -- definitely had not
18 needed to be there, but -- he could have been, but I doubt
19 it very seriously.
20 Q. Okay. So the decision makers, though, would have
21 been you and Caryn Ficklin, and then y’all reported your
22 recommendations, I guess, to Rick Barron?
23 A. That is correct.
24 Q. And do you have any e-mails or minutes or notes
25 about that -- that initial meeting and what the scope of

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1 the printing of ballots would -- would look like?

2 A. No, sir, do not. We basically meet verbally. We
3 come together verbally and sit down verbally, so --
4 Q. Was there, like, an action plan put together
5 maybe on paper, though, or electronic, you know, e-mail,
6 saying this is what we’re going to do, this is how many we
7 need to print, and -- and who is going to be assigned to
8 the printing job?
9 A. No, sir.
10 Q. So who do you -- do you know the names of anybody
11 that Caryn Ficklin had in there using those three machines
12 to print ballots?
13 A. Sure. There was Thomas Johnson.
14 Q. Thomas Johnson?
15 A. Yes.
16 Q. Okay.
17 A. Rosalyn Davis, Brenda McCloud.
18 Q. That’s Brenda McCloud?
19 A. Yes.
20 Q. Okay.
21 A. Brianna --
22 Q. Is her name -- is Brenda McCloud’s last name
23 spelled M-C-capital L-E-O-D?
24 A. I think it’s two Cs. M-C-C-L-O-U-D.
25 Q. Okay. Like clouds in the air. Okay. Who else?

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1 A. Brianna Jenkins.
2 Q. Okay.
3 A. Those were the main people who were printing
4 ballots.
5 Q. And how about, when did they start printing the
6 ballots?
7 A. Well, we actually started -- the first printing
8 of the ballots had to have come around the 45th day. The
9 reason being is because we had to get out our military
10 ballots, so it wasn’t -- we didn’t wait until the end. We
11 still had ballots that we had to have mailed out the 45th
12 days, so -- so around the 45th day -- around the 50th to
13 45th day we mailed out military overseas ballots that
14 wanted to be mailed. So we started then, and then the
15 next day that we began to print ballots for the upcoming
16 election was that Friday, the 23rd.
17 Q. Okay. So would -- do you have any recollection
18 as to what the quantity of paper that was ordered from
19 Fidlar to print these ballots would have been?
20 A. I think -- I think our suggestion was around
21 20,000 sheets, if I remember correctly.
22 Q. Okay. And do you have any problem with Ms.
23 Ringer giving me a copy of -- of any purchase orders for
24 that paper from Fidlar for the ballots, please?
25 A. It will be the same thing that the chief -- the

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1 elections chief actually submitted, so, yes, that will be

2 no problem.
3 Q. Okay. Thank you. So do you -- do you have any
4 way of backing into a number of the actual number of in-
5 house printed absentee ballots that you would have -- or
6 your staff there at the Fulton County Board of Elections
7 would have printed?
8 A. Yeah. We can -- we can give you a great estimate
9 close to it. Sometimes, though, that -- the elections
10 chief might need some extra ballots that might go to a
11 polling place for whatever reason and since we have the
12 capability of printing those ballots, we would also not
13 only print the ones by mail, but for her needs or their
14 needs also.
15 Q. Okay.
16 A. So we can tell you how many ballots that we
17 printed and mailed out, but there are also some numbers
18 that included -- that also needed to be printed for
19 emergency or provisional ballots that were needed at the
20 polls.
21 Q. Okay. Do you have records that would indicate
22 how many ballots had to be printed to be supplied to the
23 polls as well as the number of ballots that would have
24 needed to be printed in-house for provisionals or -- or
25 anything like that?

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1 A. I think so. I think that it should be a paper

2 trail that goes with that.
3 Q. During the lunch hour today, would you be able to
4 have somebody come up with a number for the number of
5 ballots that were printed for absentee ballots in-house?
6 A. Oh, yeah. Yeah, I think so.
7 Q. Okay. I would appreciate that. That way we
8 don’t have to call you back for another day of deposition.
9 I know you’re enjoying this.
10 A. Oh, so you’re going to make me work -- you’re
11 going to make me work during my lunch hour, huh?
12 Q. Yes.
13 A. That’s okay.
14 Q. What criteria did you use to determine what print
15 and what ballot style?
16 A. I’m not understanding the question. I want to
17 make sure I understand the question.
18 Q. Okay. So you’ve got 350-something precincts
19 within Fulton County, right?
20 A. Yes, sir.
21 Q. So these absentee ballots are for people from
22 varying precincts, correct?
23 A. Correct.
24 Q. And they would have -- I guess there were some --
25 for a lot of the precincts, there were people on the

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1 ballot seeking office from those precincts?

2 A. Yes, sir.
3 Q. That would not have applied to the whole county,
4 correct?
5 A. Correct.
6 Q. And so therefore, you’d have to print a certain
7 number of ballots for absentee purposes to correlate to
8 what you expected the number of people requesting ballots
9 from varying precincts; is that right?
10 A. Yeah. I think I can answer. In Fulton County,
11 every precinct gets its own ballot style. So therefore,
12 if -- so therefore, depending on where the person lives
13 will determine which actual ballot style that he received
14 and based on his precinct, what he’s been assigned to will
15 generate that ballot style.
16 Q. Okay. So let me ask you. Y’all -- I think you
17 said y’all started printing the ballots in-house -- what
18 was it? The week of October 16th; was that the date that
19 we agreed on?
20 A. We start the second -- the second run of it was
21 the week of October -- the one with the 23rd. The 22nd
22 and 23rd.
23 Q. Okay. So that was October 19th.
24 A. Our first mailing was the -- that Friday.
25 Q. Okay. So you would have started printing maybe

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1 on Monday of -- the 19th of October?

2 A. No, we --
3 Q. That week?
4 A. We probably printed that Thursday.
5 Q. Okay. And so were -- were y’all only printing
6 ballots kind of like ballots on demand for people who had
7 requested an absentee ballot for a particular precinct?
8 A. That is correct. We only printed what we needed.
9 We didn’t print just to have them on-site. We only
10 printed what was needed for that run.
11 Q. And do you have a -- do you have records of the
12 people who requested ballots after October the 19th?
13 A. Yes.
14 Q. Okay. And is that like -- could that be put on a
15 spreadsheet?
16 A. Yes.
17 Q. Is it already on a spreadsheet?
18 A. Yes.
19 MR. CHEELEY: Ms. Ringer, I’d like to request a
20 copy of those absentee ballot requests that they
21 received after October the 19th up until the date of
22 the election, please.
23 MS. RINGER: Okay, Mr. Cheeley.
24 MR. CHEELEY: Okay. Thank you.
25 BY MR. CHEELEY:

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1 Q. The -- the ballots that were printed that I’ve

2 seen have a number up at the top, like three numbers and
3 then a dash and then some other numbers. Can you tell me
4 what those numbers represent?
5 A. If -- if I think what you’re talking about, it
6 could be the precinct number with something like 01A- and
7 then another number. That could be the precinct, if
8 you’re referring to it, and, you know, it might have some
9 numbers. If it’s not -- and the numbers are the City of
10 Atlanta. If you had letters, that’s the -- actually the
11 beginning letter of that municipality.
12 Q. Okay. So the numbers or letters in front of the
13 -- I guess the hyphen, can you explain what those are
14 compared to the numbers or letters after the hyphen?
15 A. Okay. The ones before the hyphen is the actual
16 precinct identifier. The ones after the hyphen is usually
17 the -- what is called a district combo, which is a ballot
18 style.
19 Q. Okay. And just so we’re -- make sure we’re all
20 on the same page with terminology, what is -- what do you
21 mean by the ballot style?
22 A. The actual -- the actual offices that that
23 particular precinct can have eligible for people -- the
24 offices that the people are eligible to vote for who live
25 at that precinct. For example --

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1 Q. Okay.
2 A. -- like you were saying, for example, which state
3 senator can a person vote for? Which state
4 representative, even down to the Board of Education or
5 County Commissioner? What are the unique values of that
6 person’s eligibility to vote, for which candidate?
7 Q. I see. The -- the ballots that were printed by
8 Runbeck for absentee mail-out purposes, did those ballots
9 have a barcode on them that was a unique identifier to
10 each ballot?
11 A. I don't think so. I think we’re the only ones
12 who painted the barcode on the ballot. And the purpose
13 for us painting the barcode on the ballot is so that our
14 mailing system could be run.
15 Q. Okay. When you say we are the only ones that --
16 A. Fulton.
17 Q. -- painted the -- Fulton? Fulton did -- so these
18 in-house ballots that were printed by Fulton, did those
19 have a unique identifier number for each ballot so that
20 that ballot had a unique identification?
21 A. It had the -- what it had is a barcode of the
22 precinct. The -- it had an extra barcode of the precinct
23 that was on the ballot itself so that when the Pitney
24 Bowes machine read that barcode, it knew who to give that
25 ballot to.

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1 Q. Okay. So is that the -- the envelope that you

2 were talking about there where the Pitney Bowes -- so the
3 Pitney Bowes can read the envelope for the precinct?
4 A. At that stage, Pitney didn’t read the envelope.
5 It read the ballot. The ballot is placed into a hopper.
6 It reads the -- the barcode on the ballot. It knows that
7 this particular ballot is going to a particular precinct.
8 It begins to stuff the ballot, the instructions, the inner
9 envelope, and then it goes to the area whereby the writing
10 is on the envelope based on --
11 Q. So --
12 A. -- based on what they read on the ballot, the
13 barcode on the ballot.
14 Q. Okay. So I need to, I guess, make sure I’m
15 understanding what you’re saying. In October of 2020 when
16 Fulton County began to print ballots and -- and spray
17 their envelopes in-house, were you using the Pitney Bowes
18 device to mail out those envelopes with the ballots
19 contained therein?
20 A. Yes, sir.
21 Q. And so did the -- it’s my understanding that
22 every registered voter has a unique voter identification
23 number, I guess, that’s assigned to them by the Secretary
24 of State; is that right?
25 A. Yes, sir.

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1 Q. So we’re all kind of like automobiles, in that

2 respect, with a VIN number?
3 A. That is correct.
4 Q. Okay. So is there anything on the Runbeck
5 ballots, absentee ballots, or even the -- well, yeah,
6 let’s just stick with Runbeck absentee ballots. Was there
7 anything on the Runbeck absentee ballots that were mailed
8 out to someone that would show that that particular
9 ballot, when it went to a particular person so that when
10 that person filled out the ballot and mailed it to Fulton
11 County and it was tabulated that maybe the Dominion
12 machines could see that that person’s identification
13 number was somewhere on that ballot?
14 A. No. The -- the registration number is never
15 printed on the ballot.
16 Q. Even in a barcode or -- of some type?
17 A. There is no way to go from the ballot back to the
18 person --
19 Q. Okay.
20 A. -- once it’s been separated from the envelope.
21 Q. So you say there’s no way to -- to trace a
22 particular ballot back to a person’s request for that
23 ballot?
24 A. Correct. Once it’s been separated from the
25 envelope.

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1 Q. Okay. Same question, I guess, for the in-house

2 printed ballots by Fulton County. Was there any kind of
3 identification, barcode or anything on the printed ballot
4 that would show that it was associated with a particular
5 request or by a person for that ballot?
6 A. No, sir.
7 Q. Okay.
8 A. It’s like it’s a secret ballot.
9 Q. All right. Was there anything like a barcode on
10 the -- either the outer envelope or the inner envelope, or
11 either the Runbeck produced envelopes or ballots or for
12 the Fulton County produced ballots that were -- I guess
13 where the envelopes were supplied by that company, HB
14 Solutions? Go ahead. Did you understand my question?
15 A. Oh, you were saying was there -- and I didn’t
16 hear the what was there for. I understood --
17 Q. Okay. Okay. Let me -- let me rephrase it. Is
18 it fair to say that the outer envelope or the inner
19 envelope for absentee ballots that were produced by
20 Runbeck, that those did not have a unique identifying
21 number or barcode showing that it went to or -- and
22 associated with a particular voter?
23 A. The ballot didn’t, but the envelope did. The
24 envelope has a voter registration on the inner envelope to
25 identify the voter, but the actual ballot inside of the

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1 inner envelope does not. Did -- did that answer your

2 question?
3 Q. Yes. So the inner -- we’re talking about for
4 Runbeck only now. The inner envelope did have a barcode,
5 correct, that was associated with a particular voter?
6 A. Yes, sir.
7 Q. Okay. So for Fulton County, the one -- the
8 ballots that were produced in-house, did those inner
9 envelopes, or outer envelopes, for that matter, have a
10 barcode associated with a particular voter?
11 A. Correct. The inner envelope had a barcode that
12 was the -- uniquely to the voter.
13 Q. Okay. So once -- walk me through -- and just for
14 completeness, I’m not -- I think I’ve asked this question,
15 but let me just make sure. Neither the Runbeck produced
16 ballots, nor the Fulton County produced in-house ballots,
17 neither one of them had any kind of barcode that would be
18 associated with a particular voter; is that fair to say?
19 A. That is correct, yes, sir.
20 Q. Okay. So walk me through what happens to an
21 absentee ballot from the time that a person, you know,
22 puts it in the mail going back to Fulton County, whether
23 it’s a Runbeck produced ballot and envelopes or it’s
24 Fulton County produced ballot and envelopes.
25 A. Sure. Yeah. The actual ballot, okay, once a

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1 ballot is mailed back to us, we receive it from the

2 mailroom. The first thing is -- for us to do is to date
3 stamp the time when we received the ballot. At that time,
4 we also get a count of how many it was.
5 Q. So when you say you date stamp, are you talking
6 about you date stamp the -- the envelope, the outer
7 envelope?
8 A. Yes, sir. We date stamp the yellow envelope
9 which is now the inner envelope.
10 Q. Okay. So the -- the voter mails both envelopes
11 back to Fulton County; is that correct?
12 A. No. The outer envelope the voter keeps. The
13 voter only mails back the inner envelope.
14 Q. Okay.
15 A. And the secrecy envelope, if it was Fulton. If
16 it was Runbeck, the voter would mail back a sleeve with
17 the ballot. But the voter keeps the outer envelope and
18 the instructions for themselves.
19 Q. Okay. So the -- when you say the secrecy
20 envelope, are you talking about the yellow envelope?
21 A. It’s one inside the yellow envelope. It’s
22 another envelope.
23 Q. Okay. So basically, does that apply for both
24 Fulton County -- or only for Fulton County? Or Fulton
25 County, basically, when they send out an absentee ballot,

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1 it’s got three envelopes with it?

2 A. Uh-uh. When Fulton sends out the absentee
3 ballot, it has an outer envelope, an inner envelope, and a
4 secrecy envelope.
5 Q. That’s what I’m saying. That’s three envelopes.
6 A. Okay.
7 Q. Okay. What color is the secrecy envelope from
8 Fulton County?
9 A. White.
10 Q. Just plain white?
11 A. It says -- white and it says Official Absentee
12 Ballot on the outside of the white.
13 Q. Okay. And that fits inside of the yellow
14 envelope?
15 A. Yes, sir.
16 Q. Okay. Do you know the approximate measurements
17 of that white secrecy envelope?
18 A. It’s small enough to fit into that yellow one.
19 Q. It’s like a --
20 A. We get that -- we get that envelope directly from
21 the State. The State actually gives us that particular
22 envelope. We don’t have to recreate that one.
23 Q. Okay. And -- and just so we’re clear -- I think
24 I know the answer to this question. There’s nothing on
25 the secrecy envelope that identifies -- a barcode or

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1 anything like that, correct?

2 A. That is correct.
3 Q. So the barcode identifier is only on the yellow
4 envelope; is that fair to say?
5 A. That is fair to say.
6 Q. Okay. So just to -- just to summarize, Fulton’s
7 outer envelope is white and yellow; is that fair to say?
8 I’m sorry. No. Fulton’s outer envelope is -- is white?
9 A. Correct.
10 Q. Fulton’s inner envelope is yellow?
11 A. Yes, sir.
12 Q. And then, a secrecy envelope is supplied by the
13 Secretary of State and it says Official Ballot and it’s
14 white with black print?
15 A. Yes, sir.
16 Q. Okay. Is there some reason that the Secretary of
17 State doesn’t require Runbeck to also include a secrecy
18 envelope with Official Ballot printed on it?
19 A. To be honest with you, I think they just dropped
20 the ball. Runbeck does many states, and some states don’t
21 have secrecy envelopes whereby some states might have a
22 sleeve, so --
23 Q. Okay. So getting back to when these ballots are
24 mailed in by the voter and received in Fulton County’s
25 mailroom, they’re date stamped on the outside and that

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1 applies whether it’s a Runbeck or a Fulton County produced

2 ballot --
3 A. Correct.
4 Q. -- in-house, correct?
5 A. Yes, sir.
6 Q. And so what -- what is done with that outer
7 yellow envelope, the Fulton County -- I’m sorry.
8 Runbeck’s outer envelope is yellow and Fulton County’s
9 envelope is -- is also yellow, right?
10 A. Yes, sir.
11 Q. So if you held one up beside the other, can you
12 really tell the difference --
13 A. Yes, sir.
14 Q. -- as to whether or not --
15 A. They’re completely different.
16 Q. They are?
17 A. Yes, sir.
18 Q. In what ways?
19 A. Size, formatting.
20 Q. That’s right. I think you said that the size was
21 that Runbeck’s was a little wider, maybe?
22 A. Yeah. And ours is more high.
23 Q. And so if you could check, also, sir, and just
24 see if you’ve got, you know, leftovers of the -- of these
25 envelopes that would have been produced by Runbeck and the

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1 ones that were part of the Fulton County in-house

2 production, you know, just we’d like to see, you know, the
3 -- what they look like. Is that fair?
4 MS. RINGER: Point of clarification, Mr. Cheeley.
5 I think we talked about this earlier. So now, you’re
6 asking to see if they had extras? Mr. Jones, are you
7 -- did you have extras of Runbeck’s produced envelope?
8 THE WITNESS: I don't think so. I don't remember
9 keeping anything outside the ones that are at the
10 courts.
11 MS. RINGER: Okay. And so you -- are you also
12 saying that you don’t have extras unused from Fulton
13 County’s that are printed by HB Solutions?
14 THE WITNESS: We should have -- we should have
15 blank ones for HB Solutions.
16 MS. RINGER: Okay. So, Mr. Cheeley, I -- I hear
17 my client saying that we can provide you blank ones of
18 HB Solutions, maybe not those of Runbeck’s, but any
19 that were used are in the custody of the clerk and
20 we’ll have to talk about how that can be produced in
21 conjunction with Ms. Vaideeswaran and the court.
22 MR. CHEELEY: Okay. Fair enough. Yeah. I want
23 one -- what I’m requesting are basically exemplar
24 envelopes, both the outer, the white envelope, and the
25 inner yellow envelope and -- that were provided by the

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1 Fulton County in-house production of ballots. They

2 were never --
3 MS. RINGER: That we may be able to produce, yes,
4 sir.
5 MR. CHEELEY: I’m sorry. I couldn’t hear you.
6 MS. RINGER: I said understood. That we may be
7 able to produce.
8 MR. CHEELEY: Okay. Thank you, Cheryl.
9 BY MR. CHEELEY:
10 Q. So are those -- in the ordinary course of
11 business, I guess, Mr. Jones, when you receive those
12 yellow envelopes, whether they’re from Runbeck or from
13 Fulton County, are those envelopes preserved and turned
14 over to the Clerk of Court after the vote is certified?
15 A. Yes, sir.
16 Q. And -- and was that done in this case; those
17 yellow envelopes were preserved and turned over to the
18 Clerk of Court?
19 A. Yes, sir.
20 Q. And where to your -- what’s your understanding as
21 to where those yellow envelopes are currently?
22 A. At the Clerk of the Superior Court. I don't know
23 any -- you know, once we turn them over, I don’t -- I’m
24 not sure where they go.
25 Q. Okay. When -- I guess when they were received in

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1 the mailroom, walk me through that process of -- of what

2 is done with those absentee ballots that are received in
3 these yellow envelopes. They’re date stamped, I think you
4 said, correct?
5 A. Yes, sir. They’re date stamped and they are put
6 in mail trays. The mail trays are then housed with a
7 chain of custody form that tells how many are in the tray
8 and a tray number that associates with it.
9 Q. So you say these -- they’re put in mail trays and
10 each mail tray has a number?
11 A. Right. Each -- each mail tray has a tray number
12 and a count of how many that were in that tray.
13 Q. So how are these mail trays numbered, or just --
14 A. It’s just a chain of custody form. It’s a sheet
15 of paper that -- that actually says tray and it’s a blank,
16 and you write in your tray number.
17 Q. So are these like numerically sequenced?
18 A. Sequenced numbers. Correct.
19 Q. So is there like a master log of how many mail
20 trays there were and what their tray numbers were?
21 A. I think so. I think that the log was -- was
22 built, but I don’t think it was electronic, though, like
23 we have today. I can validate that later, though.
24 Q. Okay. You -- by that, you mean during the lunch
25 hour?

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1 A. Yeah. I can ask staff about that during the

2 lunch hour.
3 Q. I’m going to have to have you an Uber lunch sent
4 down there so you can have some food.
5 Do you -- have you seen some envelopes that have --
6 like, the whole envelope is not yellow, but only part of
7 it’s yellow? Can you see what I’m holding up here?
8 A. Oh, yeah. That’s the Runbeck one. Okay. No,
9 that’s -- that’s a Runbeck one right there. The yellow
10 and white one.
11 Q. Okay. But is -- is the one that Fulton used
12 solid yellow?
13 A. Yes. Fulton’s is solid yellow.
14 Q. Okay. And that was a Runbeck inner envelope,
15 correct?
16 A. Correct. It’s the -- the inner one was yellow
17 and white.
18 Q. Okay. So the -- just so we can go back and clear
19 this up then, does -- does that mean that the outer
20 envelope from Runbeck was solid yellow?
21 A. The outer envelope must have been solid white
22 then.
23 Q. Okay.
24 A. But the inner one was the yellow and the white.
25 Q. And where -- when it’s received in the mailroom,

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1 does the date stamp -- is that automatically applied by

2 the Pitney Bowes machine?
3 A. Yeah. It’s a different type of Pitney Bowes.
4 It’s not the one -- the $1 million one. This is -- we
5 have another one that actually does the date stamp, and we
6 place the date stamp usually on the oath side of the -- of
7 the envelope.
8 THE WITNESS: We can’t hear you.
9 MS. RINGER: Can you all hear us?
10 MS. VAIDEESWARAN: I can hear you. I can’t hear
11 anyone else on their side.
12 MS. RINGER: Madam Court Reporter, can you hear--
13 THE COURT REPORTER: Mr. Cheeley, we can’t hear
14 you. Liz?
15 MS. RINGER: The videographer? Ms. Kemp, can you
16 hear us?
17 THE VIDEOGRAPHER: Hey, can you guys hear us?
18 THE COURT REPORTER: Now we can.
19 MS. RINGER: Is that Ms. Dracos?
20 THE VIDEOGRAPHER: This is Liz, the videographer.
21 MS. RINGER: Okay. We can hear you. We could
22 not hear Mr. Cheeley.
23 THE VIDEOGRAPHER: Okay. I think we lost audio
24 on the conference phone, so if you’ll just give us a
25 moment, please?

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1 MS. RINGER: Okay. Thank you.

2 THE VIDEOGRAPHER: Okay. Thanks.
3 (OFF THE RECORD: 12:04 P.M.)
4 (ON THE RECORD: 12:31 P.M.)
5 THE VIDEOGRAPHER: We’re back on the video record
6 at 12:31 p.m.
7 MR. CHEELEY: It’s 12:32 right now. This might
8 be a good spot to take a lunch break. How about --
9 Cheryl, how long do you want to go? 35 or 45 minutes?
10 MS. RINGER: Yeah, 45 minutes. But let’s verify
11 the -- there were two items that you wanted Mr. Jones
12 to try and get. I wrote down some sort of master log
13 about the tray bins.
14 THE WITNESS: Yes.
15 MS. RINGER: And I’m not sure I got the first
16 one.
17 MR. BUNDREN: Yeah. A custody -- custody form on
18 the tray bins, a master on the tray bins --
19 MS. RINGER: Okay. Wait. Wait, wait, wait. So
20 you want the master log as well as the -- the chain of
21 custody forms?
22 MR. BUNDREN: Yes, on the tray bins.
23 MS. RINGER: So he did say master log, but he
24 also wants the chain of custody forms.
25 THE WITNESS: Yeah.

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1 MR. CHEELEY: Yeah. And there’s -- I think you

2 said there might be some spreadsheets on the ballots
3 that were printed by Fulton.
4 MS. RINGER: Okay. That you wanted him to try
5 and get at lunch? I didn’t write that down
6 specifically for lunch.
7 MR. CHEELEY: Yes, please.
8 MS. RINGER: Okay. Did you hear that? So that’s
9 the absentee file from November 3, 2020.
10 THE WITNESS: Absentee file.
11 MS. RINGER: You said --
12 MR. BUNDREN: Yeah. I think he was going to look
13 them up and see how many ballots they printed.
14 MR. CHEELEY: Yeah, you were --
15 MS. RINGER: Okay. Those two items.
16 MR. CHEELEY: So -- and then the -- if you could
17 -- I think he testified that he could probably get me
18 an approximate number of the number of in-house
19 ballots that were printed.
20 MS. RINGER: That’s -- that’s what the
21 spreadsheet will provide.
22 MR. CHEELEY: Okay.
23 MS. RINGER: Okay?
24 MR. CHEELEY: Perfect.
25 MS. RINGER: So the other items --

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1 MR. CHEELEY: Okay.

2 MS. RINGER: -- we’ll talk about later.
3 MR. CHEELEY: We’ll reconvene then at -- you want
4 to say 1:15 or 1:20?
5 MS. RINGER: 1:20.
6 MR. CHEELEY: 12:30 -- 12:34 now.
7 MS. RINGER: 1:20.
8 MR. CHEELEY: 1:20. Okay. That it is. Thank
9 you.
10 THE VIDEOGRAPHER: Going off the video record at
11 12:34 p.m.
12 (OFF THE RECORD: 12:34 P.M.)
13 (ON THE RECORD: 1:41 P.M.)
14 THE VIDEOGRAPHER: We’re back on the video
15 record. This is the beginning of media file number
16 three. The time is 1:41 p.m.
17 MR. CHEELEY: Mr. Jones, I hope you were able to
18 get some lunch. I wasn’t -- I wasn’t able to, but
19 it’s salad. I’ll have to eat it for dinner.
20 BY MR. CHEELEY:
21 Q. Okay. So I think when we broke for lunch, we
22 were talking about the master log and you -- you brought
23 an exemplar of the master log for the trays for the
24 absentee ballots?
25 A. Well, what we received -- I mean, what I sent

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1 over was a sample of what a tray would look like, and then
2 once the -- before the tray is transported to the next
3 step, it is recorded on the -- what you call the master
4 log.
5 Q. Does the -- do y’all have anything -- are you
6 there?
7 A. Yeah, I’m here.
8 Q. Is your lawyer still in the -- in there with you?
9 I don't know. I couldn’t -- I thought I saw Ms. Ringer
10 walk out.
11 A. Yes. David is here with me.
12 Q. Okay. I didn’t want to ask you questions without
13 your lawyer being there.
14 A. Okay.
15 Q. So what are the different ways that absentee
16 ballots can arrive at Fulton County’s mailroom?
17 A. By mail, by dropbox, and people can deliver their
18 ballots directly to our office. And we would --
19 Q. Okay.
20 A. -- eventually take it down to the mailroom.
21 Q. So when -- let’s talk about each one of those
22 three. You said that absentee ballots can arrive by mail
23 and when they arrive by mail, you -- you’ve got a
24 procedure there with the Pitney Bowes machine, right, to
25 put the time and date you received on the envelope?

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1 A. Yes, sir.
2 Q. And then when they arrive by dropbox, does that
3 same procedure, is it followed that they are run through
4 the Pitney Bowes machine that puts the time and date stamp
5 on it?
6 A. Yes, sir.
7 Q. Is it -- is there anything on the envelope that
8 shows that it was -- that it came by dropbox other than
9 maybe it -- I guess it doesn’t have any postage shown on
10 it?
11 A. Correct. There is no indication given on the --
12 on the envelope to distinguish the destination of where it
13 came from.
14 Q. Okay. So there’s nothing like -- there’s nothing
15 to show that a particular absentee ballot arrived in the
16 mailroom via a dropbox, correct?
17 A. Correct.
18 Q. Okay. And the same -- I guess the last category
19 or method for absentee ballots to arrive at the mailroom
20 for Fulton County is if somebody personally drops it off
21 at Fulton County; is that right?
22 A. Yes, sir.
23 Q. And same question for that method. That’s
24 basically hand-delivery by the voter, I guess, or somebody
25 acting on the voter’s behalf?

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1 A. Hand-delivered by the voter. Correct.

2 Q. And is there anything that -- do you keep a log
3 of which absentee ballots come in via mail versus dropbox
4 via hand-delivery?
5 A. We keep a log of the ones -- we only had very few
6 come in hand-delivery because we ask them to drop it off
7 in the dropbox. That was our procedure, but, you know,
8 there are one or two voters who wanted us to receive it
9 directly.
10 Q. Okay.
11 A. But, you know, 99 percent of them, you know,
12 actually dropped them off in our dropboxes.
13 Q. Okay. 99 percent of the absentee ballots that
14 arrived at Fulton County’s office, elections division, I
15 guess, or -- is that the Government Center downtown?
16 A. Yeah, at -- at all three of our locations. We
17 have a location at the north on Roswell Road that had a
18 dropbox right outside. We have a location at the South
19 Annex on Stonewall Tell Road which has the dropbox. And
20 the Government Center has two dropboxes -- had two
21 dropboxes.
22 Q. Okay. All right. So did you say 99 percent of
23 the absentee ballots came in the dropbox method, but
24 that’s not 99 percent of all absentee ballots that have --
25 A. No. That’s just the ones that wanted to come in

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1 and hand-deliver theirs, and what we asked them to do was

2 to, can you put it in the dropbox for us?
3 Q. Did you -- do you keep a master log of which ones
4 came in by dropbox versus the mail?
5 A. No.
6 Q. I guess that would be shown just by looking at
7 the envelopes themselves, though, right? You could tell
8 if something had postage or not?
9 A. Well, not all the ones that had postage. There
10 were some people who didn’t put postage and the absentee
11 ballot still arrived by mail. The Post Office delivered
12 even without postage.
13 Q. Okay.
14 A. But --
15 Q. So --
16 A. -- the majority of them would have had postage on
17 them. Uh-huh.
18 Q. Okay. So do you have an estimation of how many
19 of them came by mail and had postage on them?
20 A. Your guess is as good as mine. I would say 95
21 percent of them had postage and 5 percent didn’t.
22 Q. Okay. And so what was the total number of
23 absentee ballots that were received and -- and tabulated?
24 A. Oh, I wish I remembered. It -- it’s over 200.
25 230-something, if I’m not mistaken.

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1 Q. Two hundred thirty thousand?

2 A. Yes, sir.
3 Q. So 230,000 absentee ballots were tabulated?
4 A. I think it was around 230, if I remember
5 correctly.
6 Q. Were all those 230,000 certified to the Secretary
7 of State?
8 A. Yes.
9 Q. What -- remind me what day that was that these
10 were certified, Fulton County’s vote.
11 A. For Fulton County, we have to certify ours ahead
12 of the state and I’m not sure exactly when the board --
13 when our board certified it and -- but it was before the
14 state.
15 Q. Okay.
16 A. Mr. Cheeley, just to be honest with you, I’ve had
17 two or three elections after that one and it’s kind of
18 hard to remember real details unless I have documentation
19 in front of me.
20 Q. Okay.
21 A. Okay. Sorry.
22 Q. What were you looking at just then when you
23 leaned forward?
24 A. Oh, I don’t have anything.
25 Q. Oh, I -- I thought when you said you’ve had two

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1 or three elections since then and it’s hard to remember

2 everything, I thought you were looking up at something.
3 A. Oh, no.
4 Q. So did all these absentee ballots -- and, you
5 know, when I’m talking about absentee ballots, I’m not
6 talking about any other election other than the November
7 3, 2020 election.
8 A. Yes, sir.
9 Q. All right. So you -- I guess based on what I’ve
10 heard, your testimony to me is that you -- you’re saying
11 that there would be a time and date stamp on all those
12 envelopes that would have been solid yellow envelopes that
13 were created and sent out by Fulton County in-house; is
14 that right?
15 A. Yeah. You’re talking about the ballots that have
16 been received? Everything that we received should have a
17 date stamp attached to it --
18 Q. Okay.
19 A. -- of receipt.
20 Q. Okay. And that would be the case for whether the
21 ballots came in by mail or dropbox or hand-delivery?
22 A. That is correct.
23 Q. Okay. Is the time and date stamp, where is it
24 applied on the envelope?
25 A. It should be applied at the top of the flap on

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1 the side of the oath of the envelope. We tried to be as

2 standard as possible, but it should be applied at the flap
3 on the -- on the oath side at the top.
4 Q. Okay. So that’s on the back of the envelope?
5 A. Correct.
6 Q. Would that be fair?
7 A. Yes, sir.
8 Q. Okay. How are the envelopes unsealed?
9 A. Each envelope is usually gone through a -- we
10 have an OPEX machine that will actually open the outer
11 envelope, and the process is after the OPEX opens the
12 outer envelope, we run it through again to open the inner
13 envelope.
14 Q. Does the -- where does the OPEX machine -- is
15 that spelled O-P-E-X, by the way?
16 A. Yes, O-P-E-X.
17 Q. Does the OPEX machine have a tabulator on it,
18 like how many it opens?
19 A. It does keep a count on how many it opens, but it
20 starts back over for every batch of applications -- I
21 mean, of every ballot that starts over. It doesn’t have
22 an ongoing count.
23 Q. Do you -- how is that tabulation stored? Is that
24 electronically on the machine?
25 A. It’s only for that count and it is stored during

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1 the opening process, and it just shows how many ballots

2 came across. Just --
3 Q. Okay. Is that --
4 A. Go ahead.
5 Q. Is that like on a digital meter?
6 A. Yes. On the machine itself, it displays how many
7 ballots ran through.
8 Q. And does the machine store all that information
9 internally --
10 A. No.
11 Q. -- of how many --
12 A. It -- it only does by batch. It resets itself
13 from batch to batch. Each time -- each set of ballots is
14 batched up into sets of 100. And after completing the
15 opening of the first batch, it’s being restarted back over
16 the count to zero. There is no --
17 Q. Does --
18 A. -- saving of the data.
19 Q. Does Fulton County keep a record of how many
20 batches it opens each time it finishes a batch?
21 A. No. We usually do it at the back end with the
22 scanner. The scanner -- once it gets through opening, it
23 goes straight through the scanner and the scanner records
24 the number of ballots that were there. It’s a log sheet
25 that tracks the number that the opener hands into the

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1 scanner.
2 Q. So let me make sure I understand. The ballot, if
3 it’s a Fulton County in-house printed ballot from -- from
4 October 22nd on to the election, it arrives; it’s in a
5 solid yellow envelope, correct?
6 A. Correct.
7 Q. And it’s got an inner envelope that’s supplied by
8 the Secretary of State; it’s white and it says Official
9 Ballot?
10 A. Yes, sir.
11 Q. And then, the -- and then, the ballot itself is
12 inside of that white envelope, correct?
13 A. Yes, sir.
14 Q. So -- and then for the Runbeck produced envelopes
15 and ballots, it -- it comes in to Fulton County and it’s
16 in a yellow and white outer envelope; is that right?
17 A. Yes, sir.
18 Q. Okay. And then the inner envelope that Runbeck
19 uses is -- is yellow; is that right?
20 A. It’s a sleeve.
21 Q. That’s right. It’s --
22 A. Inside that yellow and white one, there is a
23 sheet of paper which is a sleeve, and then the ballot is
24 embedded into that sleeve.
25 Q. So there is no solid yellow envelope that Runbeck

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1 incorporated in their mail-out absentee ballots --

2 A. Right.
3 Q. -- is that correct?
4 A. Correct. They -- their envelope is yellow and
5 white.
6 Q. Okay. Okay. I think I’ve got that straight now.
7 So the yellow and white envelopes from Runbeck does have a
8 time and date stamp placed on them when they’re received
9 in the mailroom, correct?
10 A. Yes, sir.
11 Q. And then, the Fulton County produced outer
12 envelope is -- is yellow and it has a time and date stamp
13 affixed to it as well, correct?
14 A. Yes, sir.
15 Q. And are the time and date stamps both for the
16 Runbeck and the Fulton County envelopes that the ballot
17 arrives in the mailroom in applied to the same place on
18 both envelopes, whether it’s Runbeck or Fulton County in-
19 house?
20 A. Yes. They’re applied on the side of the oath.
21 Q. Okay. And that’s the back tab -- the fold-down
22 tab on the envelope; is that right?
23 A. Yes. Yes.
24 Q. Okay.
25 A. But I -- the Runbeck one, I don't know if the

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1 oath is on the left-hand side or the right-hand side, but

2 it doesn’t cover up the oath where we place our timestamp
3 on it.
4 Q. Okay. All right. And so were you able to
5 determine over lunch approximately how many in-house
6 ballots that Fulton County produced?
7 A. No. But I can give you some ballpark numbers or
8 something. I talked to the staff and they told me that
9 they didn’t have a run that was more than 1,000. So for
10 -- between the days from the 23rd through the -- I think
11 it’s the 30th is the last day that was mailed -- need to
12 mail, if I’m not mistaken. At the max, it would have been
13 those numbered days times 1,000, would be your max number.
14 Q. Maximum amount of 1,000 per day printed ballots?
15 A. Correct.
16 Q. And is that on a five-day work week, Monday
17 through Friday?
18 A. Saturday, Sunday.
19 Q. Okay.
20 A. We work -- we work seven days a week, yeah. Uh-
21 huh.
22 Q. Okay. So --
23 A. But obviously --
24 Q. -- but before the -- I’m sorry.
25 A. Obviously, Sunday’s workload wasn’t that big,

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1 but, yeah, we did work seven days a week.

2 Q. Okay. So your staff told you during the lunch
3 break that they printed from October the 23rd through
4 October 30th; is that right?
5 A. Yes. I think the 30th was the last day.
6 Q. And do they have logs showing how many they
7 printed each of those days from October 23rd through
8 October 30th?
9 A. Well, when we give you the absentee file, you can
10 tell how many were printed on each day. The file actually
11 tells you that much as far as how many were mailed on each
12 day.
13 Q. But I -- my question goes a little beyond that.
14 My question is, do you have a log that shows how many were
15 printed on --
16 A. No.
17 Q. -- each day, whether or not they got mailed out?
18 A. No.
19 Q. Were there -- were there some absentee ballots
20 that were printed in-house that were -- never got mailed?
21 A. Yes, there were.
22 Q. And approximately how many were there and do you
23 still have those?
24 A. I don't know how many and we would have delivered
25 them to the elections -- the elections chief because she

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1 had need of them. It would have been (unintelligible).

2 Q. Are you talking about which elections chief? Are
3 you talking about --
4 A. At that time, it was Mr. Brower.
5 Q. Okay. So you would have delivered -- any extra
6 ballots that were printed in-house and didn’t get mailed,
7 you would have delivered those to Mr. Brower?
8 A. Correct.
9 Q. And when would that have been delivered to him?
10 What -- what month --
11 A. Upon his request.
12 Q. -- November?
13 A. Yeah, it’s upon his request, you know, upon his
14 need.
15 Q. Do you know -- do you have any record, an e-mail
16 or anything as to when he asked for those?
17 A. I don't remember did he do it directly or not. I
18 don't remember --
19 Q. Okay.
20 A. -- how his request was.
21 Q. So is there -- how were those delivered to him?
22 Were they put in some sort of sealed containers and sealed
23 up with a cover on top showing what the contents were and
24 how many there were?
25 A. We usually had somebody pick them up from our

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1 location, so the hand-off could be direct to them. So he

2 would have had a courier to come and based on that one, we
3 would have printed it and given it to the courier.
4 Q. Okay. Where would the courier have picked up
5 those ballots?
6 A. They would have picked them up downstairs at the
7 141 here on the ground floor in our mailroom.
8 Q. Okay. And then, where was Mr. Brower’s office?
9 A. Mr. Brower’s was at the 144 in the building in
10 his office, which is on the second floor.
11 Q. Okay. So it’s a different building than where
12 the ballots were printed, right?
13 A. The way Fulton County is constructed, we have an
14 administration building and our actual offices have a
15 small breezeway in between the two.
16 Q. Okay. So is that Pryor Street address for both?
17 A. Our actual official address at our facility --
18 the elections facility is 130 Peachtree Street. We use
19 the 130 Peachtree Street address for ours.
20 Q. Okay. And so that’s where the mailroom is?
21 A. The mailroom is at 141 Pryor.
22 Q. Okay. So -- and Mr. Brower is the elections
23 chief and is he always -- or is the elections chief’s
24 office always in the 130 Peachtree Street location?
25 A. At this present time, yes.

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1 Q. So do you know how many -- how soon after the

2 November 3rd election would these extra absentee ballots
3 that were not mailed out be delivered to Mr. Brower?
4 A. You mean how many -- how soon would it have been
5 delivered --
6 Q. I’m saying how soon --
7 A. -- after -- after the November election, correct?
8 Q. Yeah. How soon after November 3rd would these
9 extra absentee ballots have been delivered, the ones that
10 were not mailed out? How soon after the November 3rd
11 election were those -- or would those have been delivered
12 to Mr. Brower?
13 A. Let me make sure I understand the question. When
14 we get -- after November 3rd, as far as ballots are
15 concerned, Mr. Brower doesn’t request ballots. I just
16 wanted to make sure. We will -- the registration division
17 will submit all of our ballots once we go through a check
18 -- a quality check. We will deliver all of our ballots to
19 the elections -- the elections chief so they can perform
20 retention on it to give to the clerk. And my -- I think
21 your question is about when did we give those ballots to
22 the clerk; is -- or to the superintendent to give to the
23 clerk. Is that your question?
24 Q. Yes, sir.
25 A. Oh, I don't remember, but we -- it took us a long

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1 time to organize the numbered ballots and the numbered

2 things that were supposed to be delivered to the clerk. A
3 little bit abnormally -- the election was so abnormal as
4 far as the volume is concerned and -- but we had notified
5 the elections chief that we had a substantial amount
6 that’s coming her way, at least give her a heads-up -- or
7 give them a heads-up on the volume that is actually coming
8 through. I’m not sure when it was delivered to the
9 elections chief.
10 Q. Would there be -- was there a chain of custody
11 form that would have been signed in that -- in connection
12 with delivering these items from the -- from the
13 registration division to the elections chief and then from
14 the elections chief to the Clerk of Court?
15 A. Usually the elections chief does the chain of
16 custody to record what she received from us, and she keeps
17 that paperwork.
18 Q. Okay.
19 A. And that paperwork is then passed on to Superior
20 Court, if I’m not mistaken.
21 Q. So is it my understanding that there’s a chain of
22 custody form that’s filled out by the elections chief; in
23 this case, it would have been Mr. Brower, correct?
24 A. No. At that particular time, it would have been
25 Ms. Williams. We had not -- upon Mr. Brower’s leaving, we

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1 had not given those documentations over to Ms. Williams at

2 that time.
3 Q. Okay. So Ms. Williams, though, she didn’t take
4 office until January of what -- sometime in January of
5 2021?
6 A. Correct.
7 Q. Okay. So where were --
8 A. Well, to be honest with you, Ms. Williams would
9 have received the documentation even if Mr. Brower was
10 chief because that was her role during her tenure before
11 she was promoted to the chief level.
12 Q. Okay. What was her title while Mr. Brower was
13 still there?
14 A. I -- I don't know, not off the top of my head.
15 It’s -- I don't know.
16 Q. Okay.
17 A. Manager or something like that.
18 Q. So I’m -- I guess what I want to zero in on is,
19 you know, from November the 3, 2020, through the time that
20 the elections chief developed this chain of custody and
21 sent the in-house produced absentee ballots on over to the
22 Clerk of the Superior Court, what processes were in place
23 to ensure the -- the security of those absentee ballots
24 that were never used?
25 A. Okay. Well, what we did was that after -- after

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1 the November 3rd election, if I’m not mistaken, we had to

2 go through some audits. We had to deliver all of ours
3 eventually to Ms. Williams and her crew for the upcoming
4 audit. We knew that we were -- in the beginning were
5 going to do what’s called a risk limiting audit, so we
6 were trying to gather them up and put them in some sort of
7 order to perform the risk limiting audit. But I think
8 things changed and there was a required hand audit first,
9 if I remember correctly. And at that time, the ballots
10 themselves make -- we make sure that the ballots got to
11 the elections side so that the hand audit would be
12 conducted. But the envelopes did not go with the ballots.
13 The envelopes are separated. Once the hand count audit
14 was done, then there was another. But by all the ballots
15 were (unintelligible) -- once all the ballots were
16 (unintelligible) for the recount and the hand audit, we
17 then had to make sure that all the envelopes were packed
18 up and given to the elections chief. The elections chief
19 had all the ballots during the time of the audit, but she
20 did not have the envelopes. The envelopes came later.
21 Q. All right. So when you’re talking about this
22 risk limiting audit, you’re saying that that risk limiting
23 audit was conducted by Ms. Williams?
24 A. Yes. As I said, they changed -- our normal risk
25 limiting audit would have been done as a collaborative

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1 effort between me and Ms. Williams. And the usual risk

2 limiting audit that they would choose certain ballots to
3 -- they would pick certain ballots to come out of each
4 precinct, and then with their mechanism would keep
5 counting until it was validated whoever won the election.
6 That’s a short piece of the risk limiting audit. But once
7 we found out it was going to be a hand audit, it was
8 changed. Instead of us doing that risk limiting audit
9 that was scheduled, it was changed to a hand physical
10 count audit.
11 Q. Right. And I think in your affidavit they --
12 that was filed in this case, you described about that hand
13 audit; is that right?
14 A. Yes, sir.
15 Q. Do you have your affidavit with you?
16 A. No, sir.
17 Q. Okay. Can -- I’m going to ask Liz to put it up
18 on the screen so you can see it and follow along.
19 Okay. You understand, I guess, what an affidavit is,
20 right?
21 A. Yes, sir.
22 Q. And you -- you have to swear to the truth
23 contained in the affidavit, correct?
24 A. Yes, sir.
25 Q. And you did that in this case on March 11, 2021,

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1 correct? Is that right?

2 A. Yes. Yes, sir.
3 Q. Okay. And then, it was notarized by, it looks
4 like, Ivy K. Wright, W-R-I-G-H-T. Okay. Did you sign
5 that in the presence of Ivy Wright?
6 A. Yes, sir.
7 Q. Okay. Who is Ivy Wright, by the way?
8 A. She works somewhere in here. I don’t -- I don't
9 know her because I don’t work in that attorney’s office,
10 so I don’t know her, per se.
11 Q. Where -- where did you go to sign this affidavit?
12 A. We signed it in the -- if I remember correctly,
13 we signed it in the office -- in the attorney’s office.
14 Q. Where was that attorney’s office?
15 A. Here at 141 --
16 Q. Okay.
17 A. -- on the fourth floor.
18 Q. Okay. That’s -- 141 Pryor Street, that’s Fulton
19 County, correct?
20 A. Yes, sir.
21 Q. Okay.
22 MR. CHEELEY: Drop down to paragraph two on the
23 front page, please, Liz.
24 BY MR. CHEELEY:
25 Q. So just wanted to go through a little bit of --

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1 A. Thank you.
2 Q. Okay. All right. It says, you’re aware that
3 petitioners in this case allege that counterfeit ballots
4 were counted by Fulton County Elections during the
5 November 3, 2020 election hand tally audit and recount.
6 Following the November 3, 2020 election, a hand tally
7 audit was conducted. County employees and poll workers
8 served as the auditors. This is the only hand tally audit
9 that has been held in Fulton County during my 12 years
10 serving in Fulton County’s Department of Elections and
11 Registration. I’m going to stop right there and ask you,
12 how are these auditors selected, the county employees and
13 poll workers?
14 A. I’m not sure. That jurisdiction actually came
15 under the elections chief, but I understand that the
16 majority of the auditors were Fulton County employees.
17 Majority of the employees that participate in the audit
18 were people who were not working because of the COVID.
19 Their jobs had been suspended for a little while because
20 of the COVID, and so we used those particular employees
21 for the audit -- the audit.
22 Q. Did Fulton County have any policies in place
23 prior to the November 3rd election that would specify in
24 the event of a hand recount who the people were and how
25 they would be selected to serve as auditors?

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1 A. No. I doubt it very seriously.

2 Q. Was there any discussion that you’re aware of by
3 the -- I think you referred to the chief of elections.
4 Would that be -- would that have been Mr. Brower?
5 A. Yes. It would have been Mr. Brower, but I think
6 the actual hand count was under Nadine’s umbrella, so she
7 was the one who was in charge of the hand count audit.
8 Q. Nadine Williams?
9 A. Yes, sir.
10 Q. Okay. So were these -- do you have a list of the
11 names of these county employees and poll workers that
12 served as auditors?
13 A. It would have been from Nadine. If -- if we have
14 the list, she would be the one responsible for having that
15 list.
16 MR. CHEELEY: Okay. And, Cheryl, I’d like to
17 request a copy of that list to see who the authors
18 were, please.
19 MS. RINGER: Okay.
20 MR. CHEELEY: Okay. Thank you.
21 BY MR. CHEELEY:
22 Q. So the -- dropping back down where we left off,
23 the auditors that performed the hand tally audit had no
24 previous experience in dealing with absentee ballots
25 because in years past, all processing of absentee ballots

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1 has been conducted by Fulton County Elections Department

2 full-time personnel. Accordingly, the auditors’ years of
3 service as poll workers did not provide them any basis
4 upon which to know whether an absentee ballot is real or
5 counterfeit. Did I read that correctly?
6 A. Yes, sir.
7 Q. Okay. So you yourself, I take it, did not look
8 at all -- all the absentee ballots, correct?
9 A. No, sir.
10 Q. And so you don’t know -- you haven’t formed an
11 opinion based on personal observation of those ballots as
12 to whether or not they were real or counterfeit then,
13 correct?
14 A. Run that question by me again.
15 Q. Okay. Because you haven’t looked at all those
16 absentee ballots yourself, you can’t, as you sit here
17 today then, swear that there were no counterfeit ballots
18 in that group, correct?
19 A. I would think -- based on our procedures that we
20 have in place, I would think that -- I would think that
21 all the ballots that were there were actual ballots and no
22 counterfeit.
23 Q. Okay. Do you -- how many of the -- well, you
24 said there were, what, 230,000 absentee ballots?
25 A. I think it -- that was the number.

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1 Q. So how many of those would you estimate you

2 personally looked at?
3 A. I try my best not to touch the ballots
4 themselves, so it -- it would have been a very, very small
5 number.
6 Q. Would it have been -- 10 percent of 230,000 would
7 have been 23,000. Do you think it’s less than 23,000?
8 A. It’s less than 23,000.
9 Q. It’s what?
10 A. It’s much less than 23,000. It was probably --
11 physically touching the ballots, it was probably 2,000,
12 around, at the max.
13 Q. Okay. So when a ballot is scanned into the
14 Dominion scanners, what resolution are those scanned in
15 at; do you know?
16 A. No, I do not. I don't know if it’s 1500 or what.
17 I’m not -- I don’t --
18 Q. You’ve looked at images, I’m sure, right, that
19 have been -- that are scanned ballots?
20 A. Yes, sir.
21 Q. What does it -- when you look at a scanned image
22 of ballots that were mailed in, what does it look like
23 when you look at the scanned image? What can you tell
24 about it?
25 A. Basically how the ballot was marked.

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1 Q. By the voter?
2 A. Yes.
3 Q. Okay. What else can you tell about it from
4 looking at the scanned image?
5 A. I never thought of anything else. I was just --
6 usually when I look at the scanned image, it’s because of
7 adjudication and by that time, all we’re trying to do is
8 determine if the ballot needs to be counted and what needs
9 to be counted on the ballot. So I didn’t look at it any
10 further than if the ballot was marked or not.
11 Q. Can you tell anything about the difference
12 between ballots that were printed by Runbeck and ballots
13 that were printed in-house by Fulton?
14 A. Not that I know of.
15 Q. Can you tell anything about whether the ballot
16 was folded or not?
17 A. Not that I know of. A lot of -- lot of the
18 ballots that are folded, you don’t see the crease when the
19 image is taken picture of it.
20 Q. Okay. So is it fair to say the best way to see
21 whether or not a ballot has been folded is to look at the
22 original paper?
23 A. Yeah, I would agree with that.
24 Q. But as far as making any other evaluations about
25 the ballot that has been, you know, tabulated, you can’t

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1 tell hardly anything about it except who the person maybe

2 intended to vote for?
3 A. Yes. I -- I would believe that would be correct.
4 Uh-huh.
5 Q. I remember -- I wanted to ask you a question
6 about adjudication -- adjudicated ballots. Adjudicated
7 ballots, does that only apply in a -- for the 2020 --
8 November 2020 election, does that only apply in the case
9 of absentee mail-in ballots? It doesn’t apply to ballots
10 that are cast at a polling place; is that fair to say?
11 A. Yes, but it does encompass provisional ballots
12 also. Provisional --
13 Q. Yes.
14 A. -- can be adjudicated also.
15 Q. Right. And just for the record, explain what a
16 provisional ballot is.
17 A. A provisional ballot is a ballot cast by a voter
18 who is not eligible to vote on the touchscreen, and a
19 decision has to be made about that voter’s ballot to make
20 a determination if it’s going to be counted or not.
21 Q. Okay. And are provisional ballots, aren’t they
22 basically the same thing as an absentee ballot and they’re
23 kept at the polling precinct locations in case somebody
24 arrives and -- and there’s some confusion as to whether or
25 not that person maybe has already voted or not?

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1 A. Yes, that’s one form. Correct.

2 Q. Okay. So when you adjudicate, define what and
3 describe what that means, adjudication of ballots.
4 A. Okay. Adjudication of ballots is when a ballot
5 is scanned and there needs to be a decision made on the
6 scanning of the ballots. The ballots could have had
7 overvote, overvote meaning that there were two people
8 selected for the same race and only could have one. Also,
9 stray marks. There could have been a stray mark on the
10 ballot to see if -- to make it look like it was a voted
11 ballot for that race, or it could have a write-in. If
12 there was a write-in, write-ins are -- all write-ins are
13 adjudicated so that we can get the count of the write-ins.
14 So those are some of the reasons of why a ballot would be
15 adjudicated.
16 Q. And again, adjudication only applies to something
17 that a human being was -- had to fill out with their --
18 themselves rather than a machine filling it out, correct?
19 A. Yes, sir, that is correct.
20 Q. So do you know how many absentee ballots or
21 provisional ballots were adjudicated from the November 3,
22 2020 election?
23 A. We have that number, but I don't know off the top
24 of my head.
25 Q. I mean, is it less than 5,000 or more than

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1 50,000?
2 A. I really, really don’t remember.
3 Q. Who would know? Is there a record that --
4 A. It’s a record.
5 Q. -- maybe Nadine keeps? Who -- who would have
6 those records?
7 A. We will. We should have those records.
8 Q. Okay. And what would those records consist of?
9 A. Basically, what we would have is that a ballot
10 that has been adjudicated will have a stamp that this
11 ballot was adjudicated, and it will give if there was any
12 change or selection made to that particular ballot. And
13 you would not see the ballot; you just would see the
14 results of the adjudication of that ballot. For example,
15 if -- if there was an overvote, I think you will see
16 something like there was an overvote, scan as-is, or if
17 the panel agreed that John Doe should have gotten the
18 vote, you will see for this particular race, we’re going
19 to create a John Doe for the race.
20 Q. Okay. And the adjudication process, when does
21 that happen? Is that during the November 3rd election and
22 maybe into the hours of the early part of November 4th or
23 even November 5th?
24 A. Yes. Majority of adjudications came prior to
25 November, so majority of it came through prior to

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1 November. But since in November we still had absentee

2 ballots to be scanned after November, we still had to have
3 some adjudication teams after the November 3rd election.
4 Q. So it’s my understanding that there’s, what,
5 seven people that comprise the adjudication committee or
6 panel?
7 A. It depends on the volume. We usually have a team
8 of three Republicans and three Democrats. It can get up
9 to four if we have enough space. Four teams of each -- I
10 mean, four people will make four teams and, as I said, it
11 depends on the number that needs to be adjudicated and
12 it’s based on the -- the number of staff.
13 Q. So when did -- you said the majority of the
14 adjudications came before November 3, 2020. Do you have
15 records as to --
16 A. We should have --
17 Q. -- you know, when that --
18 A. We should have the dates that there were
19 adjudications. We should be able to get that also.
20 Q. Okay. I appreciate that. Does it show -- what
21 does the record show about those adjudications? Does it
22 show, like, how many there were that day or -- or what?
23 A. No. We -- the way it -- since adjudication was
24 very, very new to us, we do it differently now, but back
25 in November, all we have is the results of the

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1 adjudication and when it was done and what the results

2 were of it. It’s a file that the -- the election system
3 produces for us that tells us the results of it, each
4 adjudicated ballot.
5 Q. Do the -- do the records about adjudications
6 show, I guess, the names of the adjudicators for each time
7 they had to convene and look at absentee ballots or
8 provisional ballots?
9 A. No. It does not, uh-uh. It does not specify the
10 names of each person at the time of adjudication.
11 Q. Okay. But it would only be those seven people
12 adjudicating? It wouldn’t be anybody else; is that right?
13 A. Now, you’re saying seven -- now, I just want you
14 to know that we probably had more than seven because at
15 one point in time these eight people came in one day and
16 then the next set of eight people came another day. So we
17 tried our best to make it as constant as possible.
18 Obviously, for training purposes, we would have loved an
19 experienced person to do adjudications so we don’t have to
20 go through training and training and training, but we
21 accepted all people who were eligible. The parties
22 actually gave us the people in order to adjudicate. The
23 Republicans sent their representatives and the Democrats
24 sent theirs, and then we paired them on the scene at the
25 time of the adjudication.

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1 Q. Okay. Were there times when people were asked to

2 adjudicate the intent of voters when a representative of
3 both of the two political parties wasn’t present?
4 A. No. All adjudications were done at the -- at the
5 presence of both parties.
6 Q. Okay. I -- I saw something in the media as I was
7 preparing for this deposition where Rick Barron -- does he
8 go by Rick or Richard?
9 A. Both.
10 Q. So I saw where he says within a day or just a few
11 days after the election that -- that the county had
12 adjudicated, I think it was 113,000 of these absentee and
13 provisional ballots; do you remember that?
14 A. I do not. To be honest with you, I don't
15 remember him saying that, but we would have given him the
16 count of how many ballots had been adjudicated.
17 MR. CHEELEY: Liz, do you have that video?
18 THE VIDEOGRAPHER: Yes.
19 BY MR. CHEELEY:
20 Q. All right. I’m going to have Liz play a segment
21 of the video where he’s giving a press conference, I
22 think.
23 A. Sure.
24 (Video played.)
25 BY MR. CHEELEY:

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1 Q. Okay. I was mistaken. He said 113,000 had been

2 scanned and 106,000 had been adjudicated. Does that
3 refresh your memory?
4 A. Not really. I didn’t see -- that was my first
5 time seeing that one, but I understand what he was saying.
6 What he was saying was that we can have results updated
7 and there can be some results that need to go through
8 adjudication. And all the results that are updated might
9 not have gone through the adjudication, the program, so
10 therefore, for example, if you -- if I scan and give you
11 10,000, there are 10,000 votes, but that doesn’t mean all
12 10,000 have been adjudicated. You have to go through the
13 process to say, okay, how many of these 10,000 ballots
14 need to be adjudicated, and out of the 10,000, let’s say
15 1,000 need to be adjudicated. Once we adjudicate the
16 1,000, then we can properly say that all 10,000 are
17 adjudicated even though we only had 1,000 to adjudicate.
18 He can add the -- he can add all 10,000 ballots have been
19 looked at by the system to count as being a good ballot.
20 Q. But --
21 A. Did that help a little bit?
22 Q. I don't know. I’m --
23 A. Oh, okay.
24 Q. -- just an old country boy, just kind of confused
25 now. I heard him --

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1 A. I confused -- I confused my own self. I’m sorry.

2 I’m sorry.
3 Q. All right. Well, I’m -- I heard him say that
4 they had scanned 113,000 and they had adjudicated 106,000.
5 A. Correct.
6 Q. So does that mean that that many voters had
7 either overvotes or stray marks or write-in votes that
8 somebody at the elections division had to look at it and
9 see what the voter intended?
10 A. No, that doesn’t mean that, in particular. What
11 that means is that they passed the adjudication process.
12 All of the 106,000 didn’t have to go through adjudication.
13 Only a percentage of those had to go through a physical
14 adjudication. The rest of them are good ballots and they
15 have been uploaded as good ballots from that point on.
16 Q. Okay. So who was this ballot review committee?
17 I think those were his words that he used. He said they
18 had been sent over to the ballot review committee; who was
19 that?
20 A. The vote review panel. The vote review panel is
21 the same as our adjudication. It’s the same -- the same
22 people. They make a determination if the ballot is going
23 to count or not based on adjudication.
24 Q. Okay.
25 A. It’s the same people.

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1 Q. Okay. So the -- the records that you and Ms.

2 Ringer have kindly agreed to provide to us from the
3 adjudications, it will show how many ballots were -- had
4 to be -- go through that process where you tried to
5 determine the voter’s intent; is that fair to say?
6 A. It -- it will show that there was a ballot that
7 had to be manually adjudicated and what was the outcome of
8 it, yes.
9 Q. Okay. Now, tell me, when it goes through that
10 process where the vote review panel or the adjudication
11 panel, whatever phrase you want to use to describe it,
12 when they review it and they decide that there was, for
13 example, an overvote or there were some stray marks, what
14 -- what happens to that ballot both in terms of -- is
15 there anything stamped on it that it was adjudicated?
16 A. Not the physical ballot. The adjudication is an
17 electronic process and at that time, what it -- what would
18 happen is that the adjudication panel would agree on how
19 the ballot is supposed to be scored and based on the
20 documentation on how they say it was supposed to be
21 scored, it is selected electronically to say who is
22 supposed to get the credit for the ballot if there is need
23 to -- if there is a need to select one.
24 Q. All right. And you’re aware, are you not, that
25 Judge Brian Amero -- have you ever heard his name?

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1 A. No, sir.
2 Q. No? Are you aware that Fulton County has
3 provided to my clients and to some other petitioners the
4 scanned ballot images?
5 A. I’m aware that they were eligible to do so, but I
6 didn’t know if you had --
7 Q. Okay.
8 A. -- received them or not.
9 Q. Okay. So those scanned ballot images, are those
10 images the ones that would have been tallied and certified
11 to the Secretary of State’s Office?
12 A. Yeah.
13 Q. Those images, if you could, describe for the
14 record what those images would show if that particular --
15 if a particular ballot had been adjudicated.
16 A. I don't know. I’ve never seen the image after
17 it’s been adjudicated, so I’m not -- I’m not 100 percent
18 -- know what it looks like after it’s adjudicated.
19 Q. Okay. I take it the -- all the absentee original
20 ballots that were tabulated and certified to the Secretary
21 of State, those have been transferred to the custody of
22 the Clerk of the Superior Court of Fulton County; is that
23 fair to say?
24 A. Yes, sir.
25 Q. And when those are transferred, what kind of

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1 containers are they in and what, if anything, is done to

2 the container to seal it?
3 A. When we do our final run, we box them up into
4 cardboard boxes, tape them up, and put a seal on the
5 cardboard box.
6 Q. Okay. And what is the seal?
7 A. It’s a paper seal. It’s a sticker that actually
8 goes where the tape seals the box, so that if it’s been
9 tampered with, we would know that the box has been
10 tampered with.
11 Q. Okay. Do you have any photographs -- did y’all
12 -- do you make photographs of the boxes when they’re
13 sealed and before they’re delivered to the Clerk of Court?
14 A. No, sir, we do not.
15 Q. Do you -- how many batches are typically in a
16 box?
17 A. I would -- I’m not 100 percent sure, but I’m
18 thinking it’s around maybe ten. Ten batches or eight,
19 somewhere right around in there.
20 Q. Eight to ten batches per box?
21 A. Yeah, I think so.
22 Q. Okay. Let me ask another question. On the -- on
23 the date of November the 3, 2020, the absentee vote
24 tabulation, I guess, was held at State Farm Arena; is that
25 right?

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1 A. Correct.
2 Q. Okay. And the absentee ballots would have had to
3 be taken from, I guess, the Fulton County offices -- what
4 was that -- mailroom where that was; is that where they
5 would be taken from to -- to State Farm Arena?
6 A. They actually were taken from the Government
7 Center, but it wasn’t from the mailroom. What we did was
8 signature verification and gave credit for voting prior to
9 transporting them to State Farm, and those were in other
10 locations other than the mailroom.
11 Q. Okay. Hold on a second because I wanted to ask
12 you about that. You said signature verification and what
13 else had been done before they were taken to State Farm
14 Arena?
15 A. Credit for voting.
16 Q. Registered voter?
17 A. Credit.
18 Q. Oh, credit. Okay. Credit for voting. All
19 right. Tell me about that process, signature verification
20 and credit for voting. When did that process commence for
21 the first time on these absentee ballots?
22 A. Well, as soon as the ballots are counted in the
23 mailroom and identified with a tray number, they were
24 moved to the processing unit, which processed credit for
25 voting and signature verification. The credit for voting

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1 was -- is delivered to a person. They can do as many as

2 ten at a time by typing in or scanning in the registration
3 number of the voter. Once they have been given credit,
4 they go through the signature verification portion of it
5 whereby the signature of the -- that’s on the envelope is
6 matched with the signature that we have in our voter
7 registration system to determine if the signatures match.
8 Once they --
9 Q. So --
10 A. Go ahead.
11 Q. I apologize. Go ahead. What’s next?
12 A. I was going to say once they have completed that
13 one, then after that, they are packed up and sent to State
14 Farm so it can go through the opening process.
15 Q. So when does this signature verification and
16 credit for voting process commence?
17 A. Immediately after the count from the mailroom.
18 Q. And is there a -- is the count in the mailroom an
19 ongoing thing leading up to November 3rd?
20 A. Yes. It’s ongoing as -- as soon as we receive
21 the ballots. As soon as we receive them into the
22 mailroom, the mailroom doesn’t house the ballots for long.
23 Their job is to count it and get it out, but it’s -- since
24 it’s the most secure place I have, I only could use it
25 until my credit for voting and signature verification team

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1 was ready to receive them. So we had to house them into

2 the mailroom until we could transport them to the
3 signature verification and the credit for voting team was
4 ready to receive them.
5 Q. Okay. So I guess -- I got a few questions, which
6 you’re probably not surprised by that. So when -- when
7 these absentee ballots are received in the mailroom,
8 they’re put through the Pitney Bowes machine that has a
9 date stamp -- time and date stamp on the outer envelopes,
10 correct?
11 A. Yes, sir.
12 Q. The next thing that happens is -- I guess, does
13 it go through the other machine, the -- that opens that
14 envelope, or is that all done by the same machine?
15 A. No. After -- after it goes through the date
16 stamp machine, we have to do credit for voting and
17 signature verification. The OPEX machine, the way you
18 actually open it, we don’t open bad ballots -- I should
19 say rejected ballots. We only open ballots that could be
20 counted, you know, so --
21 Q. I see. So the -- which one of the envelopes is
22 required to be signed by the voter? Is it the one on the
23 -- is it the outer envelope that -- well, the one that
24 actually has, I guess --
25 A. The oath. It’s --

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1 Q. The oath on it?

2 A. -- the envelope that has the oath.
3 Q. Okay. So the -- before it’s -- I’m just trying
4 to get the procedure in my -- straight in my mind. It
5 goes through the Pitney Bowes machine that puts a time and
6 date stamp when it’s received, right?
7 A. Yes, sir.
8 Q. That’s first -- that’s the first step?
9 A. Yes, sir.
10 Q. And then, what is the very next step?
11 A. The next step is getting credit for voting.
12 Q. And that’s looking at the person’s signature?
13 A. Not yet.
14 Q. Not yet.
15 A. (Unintelligible) was that anybody -- any ballot
16 that has come in, we want to recognize that the ballot was
17 in just in case we get a phone call or anything else. So
18 we log the ballot in as far as that we have the ballot in
19 to Fulton County.
20 Q. Okay. So once it’s in the mailroom, the first
21 thing that happens is the time and date stamp, correct?
22 A. Yes, sir.
23 Q. Second thing that happens is credit for voting?
24 A. Yes, sir.
25 Q. And what is -- again, what has to happen in order

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1 for somebody to get credit for voting?

2 A. They just have to make sure that there was a
3 signature on the ballot and that the ballot belongs to
4 Fulton County.
5 Q. And when you say a signature on the ballot,
6 you’re talking about the envelope, but not the ballot,
7 right?
8 A. Yes, the envelope. Correct.
9 Q. And is that signature -- again, I just want to
10 make sure I’m real clear. Where is that signature? Is
11 that signature on the outer ballot envelope, or is it on
12 the -- something contained inside of that envelope?
13 A. It’s on the oath portion of the envelope.
14 Q. Okay. On the back?
15 A. Correct.
16 Q. Okay.
17 A. Because the signature is the signing of the oath.
18 Q. Correct.
19 A. Yeah.
20 Q. All right. And so the -- if you -- how do the --
21 what criteria is used to determine that the signature is
22 that of the registered voter?
23 A. Well, since it’s -- since we don’t have any
24 extensive signature matching classes, the only thing that
25 we tell our people is that when you look at the signature,

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1 does it closely resemble the signature on the ballot? If

2 it -- if you feel like that it does not, then after that,
3 what you can do is say that this needs to take another
4 look at -- somebody else needs to take another look at to
5 validate that we’re going to reject this person because of
6 the signature.
7 Q. Okay. So I think you said something just now
8 that says that we, Fulton County, don’t have any extensive
9 matching classes?
10 A. Correct.
11 Q. Classes of what?
12 A. Signature matching, you know --
13 Q. Gotcha.
14 A. Yeah. We don’t have any detailed training as far
15 as -- we’re just average citizens taking a look at two
16 signatures to see if they’re the same.
17 Q. So what is it your people are comparing the
18 signature on the envelope under the oath to?
19 A. We have an image system that stores our -- our
20 voter registration applications, and they were pulling it
21 up -- pulling up the image system, the image -- the
22 voter’s individual record on the image system whereby if
23 the voter had three applications, we have all three
24 applications and they can view the images of the voter to
25 compare against the ballot -- I mean, the envelope -- the

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1 oath envelope of the absentee ballot.

2 Q. Okay. So you -- I just want to make sure I’m
3 clear there. You said that these folks that are looking
4 at these signatures on the oath of the envelope, they’re
5 just average citizens that don’t have any special training
6 in signature analysis; is that fair to say?
7 A. Correct.
8 Q. And so what they’re doing, they’re pulling up
9 other voter registration applications by that person?
10 A. Yes.
11 Q. Are they also looking at the -- like a Department
12 of Motor Vehicles driver’s license application or where
13 they sign for a driver's license?
14 A. They can. It’s in the same system.
15 Q. Okay. And what’s the name of that system?
16 A. Well, it’s two. One, ElectioNet -- it’s called
17 ElectioNet. That’s the state system, and the state system
18 actually houses the voter registration application from
19 Driver Services. And they’re looking at a system called
20 RocketFile. RocketFile is our image system.
21 Q. And that’s Rocket like space rocket?
22 A. Correct.
23 Q. RocketFile? Okay. And what -- what information
24 is contained in RocketFile?
25 A. Same thing except majority of RocketFiles are

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1 non-DDS applications.
2 Q. Non-DDS or DVS?
3 A. Correct.
4 Q. Driver vehicle?
5 A. DD as in Drivers -- what is it? Department of
6 Driver Services.
7 Q. Department of Driver Services.
8 A. Yeah.
9 Q. Okay. So RocketFile is non-Driver Services
10 information, correct?
11 A. Yeah. Yes, sir. Majority of them and, you know,
12 we did have -- we do have some Driver Services in there,
13 too, but majority of them are non-Driver Services.
14 Q. Okay. And you said that somebody can look at
15 these ten at a time?
16 A. No, not for -- not for signature verification.
17 Signature -- signature verification has to be looked at
18 one at a time. Credit for voting can be done ten at a
19 time, but signature verification, you have to do it one at
20 a time.
21 Q. Okay. So do the employees doing the signature
22 verification, do they receive any specialized training to
23 recognize signatures at all?
24 A. We give them a little training to say that if
25 you’re looking for a person who might try to forge it, you

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1 know, some of the things that we’d show them is usually I

2 always sign with a cursive A and now, I’ve got a person
3 who starts their name off with a manuscript A, that’s --
4 that’s odd when you use a signature. Most everybody
5 starts their first letter with the same. We talk about
6 how -- if you normally slant from left to right and now
7 you’re slanted from right to left, that’s odd, you know,
8 once you slant from left to right, it’s a reason why you
9 -- it must be a reason why you changed from right to left.
10 And we give them little pointers like that prior to them
11 going through that scenario of --
12 Q. Okay.
13 A. -- voting -- voter whatever.
14 Q. Okay. So I guess then there’s -- there’s no use
15 of computers to make that call as to how close a signature
16 resembles another signature of that voter on file?
17 A. Well, at one point, the Secretary of State had
18 denounced us using computerized signature verification.
19 That was what we wanted to do in Fulton, you know. At
20 least -- if you at least got the ones that the computer
21 got, I know I’m not going to reject those. Can I at least
22 get those? But they said that we had to do it manually.
23 Q. And which Secretary of State was it --
24 administration that said you had to do it manually?
25 A. All of them except for Raffensperger.

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1 Q. Okay.
2 A. When the volume came in, I think they said that
3 we might have to take another look at that because of the
4 volume.
5 Q. Okay. So prior to November 3, 2020, had -- even
6 Raffensperger said you had to use the manual method?
7 A. I don't know if he said it. I was just going by
8 what was originally done for the other ones. But what we
9 did is that when we got such large numbers again, we -- we
10 reintroduced the idea of having signatures done
11 electronically, and they were a little bit more receptive
12 than the other Secretary of States.
13 Q. Was that large volume reported to the Secretary
14 of State leading up to November 3rd or after November 3rd
15 that they said that they might reconsider?
16 A. Leading up to it because we were -- we were
17 trying to get some funding to see if we can change our
18 Pitney Bowes machine to see if it was able to make that
19 happen, what would it take -- if we even went down that
20 road, what would it take to make it happen.
21 Q. Does the Pitney Bowes machine or any software
22 updates to it have that capability of recognizing or
23 comparing signatures to determine probability that it --
24 it was signed by the same person?
25 A. Not ours, but, yes, they do have that ability to

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1 add that component on. Fortunately, we’re not going to go

2 down that road anymore because of Senate Bill 202.
3 Q. Right. Going back to the whole process of
4 opening the absentee ballots when they arrive at the
5 mailroom, you say those -- those just don’t sit around;
6 they’re processed quickly through the time and date stamp
7 machine and then --
8 A. Let me make -- this. Let me make sure. The
9 ballots are never opened. Want to make sure we get that
10 point across. They’re not opened. Once they get into the
11 mailroom they go through the date sort. They’re not
12 opened until they get to the area of the OPEX machine,
13 which is usually away from the mailroom. Okay. I just
14 want to make sure. I thought I heard you say when they’re
15 opened. They don’t open until they get to the OPEX --
16 where the OPEX machines are.
17 Q. Okay. Where are the OPEX machines located?
18 A. Well, in November, the OPEX machines were located
19 at State Farm.
20 Q. They were located at State Farm?
21 A. Yes, sir.
22 Q. Was there more than one OPEX machine that was
23 located at State Farm?
24 A. There were four. I think there were four located
25 at State Farm.

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1 Q. And so the -- when the envelopes containing

2 ballots arrive at State Farm, what do they look like?
3 What is -- what do you see?
4 A. It’s just a mail tray of yellow ballots.
5 Q. Is there a --
6 A. Of envelopes. It’s a mail tray of envelopes --
7 yellow envelopes.
8 Q. Okay. So are -- are some of those envelopes
9 yellow and white?
10 A. Yes. Some of them are yellow and white; some of
11 them are all yellow. When we --
12 Q. Are the ones --
13 A. When we processed them, we didn’t distinguish
14 where they came from. You know, we put them all together.
15 Q. Okay. Okay. So trays of envelopes, some could
16 be yellow and white and some could be yellow, together.
17 Okay. So what does the OPEX machine do?
18 A. It sliced the envelopes so that you can -- it
19 sliced the outer yellow envelope so you can pull the white
20 secrecy envelope out. Then, you run through the secrecy
21 envelope so that you can actually pull the ballot out of
22 the secrecy envelope. After completion of both of them,
23 the outer envelopes are tied together with a rubber band
24 and the ballots are placed in the same mail tray that it
25 was received in. And those instructions were then sent to

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1 the preparation -- the file prep people.

2 Q. So the -- when the ballots leave the Fulton
3 County Government building, they’re in trays, correct?
4 A. Correct.
5 Q. The envelopes? They’re in envelopes and they’re
6 in trays?
7 A. Right. And --
8 Q. And they’re --
9 A. -- they’re secure boxes. The trays are placed in
10 secure boxes at the time.
11 Q. What do those boxes look like?
12 A. Black suitcases. Black ballot boxes. These are
13 boxes. I would say a large suitcase-looking black plastic
14 box. It’s called a ballot box for us. Just equipment
15 that’s --
16 Q. Okay.
17 A. -- normally used to transport ballots.
18 Q. And how many of those did -- were required to
19 move these -- were required to move these ballots from the
20 Government Center to State Farm?
21 A. Well, each tray held between three to 450 ballots
22 per tray, and we would -- normally, it’s about 400. We
23 try to get at least 400 in a tray. There are usually two
24 trays in the -- that could fit inside the ballot box, and
25 we tried our best to -- upon completion of signature

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1 verification to box all of the ballots up to be able to

2 distribute (unintelligible) State Farm. And we tried to
3 do it after -- that evening, so it would have been on the
4 evenings so the people at State Farm would have some work
5 when they report to the next day.
6 Q. Okay. So when you say tried to do it that
7 evening, are you talking about the -- on the evening of
8 November the 2nd?
9 A. I’m talking about starting -- we were able to
10 scan ballots starting a week prior to the election, so we
11 had a week prior to the election to start scanning
12 ballots.
13 Q. Okay. So do you have a log showing the day --
14 the days and the times and -- and maybe the custodian of
15 these trays that were inside of these suitcases making the
16 trip over to State Farm?
17 A. I’ll -- I’ll see if we can get that for you,
18 okay? I’ll try my best. That log -- that particular log
19 was all paper and we’ve -- it’s been placed with something
20 and I’m not sure exactly where it is. Now, what we’ve
21 done is we’ve switched it over to electronic. Everything
22 is electronic now, so I don’t have to lose a piece of
23 paper anymore.
24 Q. So what’s that log -- I guess, what’s the log
25 called where the ballots are being placed in suitcases and

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1 then transported to State Farm Arena?

2 A. We called it the signature verification log.
3 Q. Okay. And so it’s my understanding that the
4 ballots make the trip from the government offices downtown
5 on Pryor Street only after the signatures have been
6 verified?
7 A. Yes, sir.
8 Q. And then, what -- the signature verification log,
9 does it require just one person to sign it and state what
10 the contents are, or two people?
11 A. Each tray was an individual person, and what it
12 stated was that -- with a tray, the number of ballots that
13 were remaining in the tray. If a ballot was not able to
14 be approved by either signature verification or whatever
15 other means, it would have been pulled out and gone to the
16 rejection team.
17 Q. How many of those were pulled out, would you
18 estimate?
19 A. It was a small amount. I would say around --
20 probably around five percent at the max about that were
21 being pulled out.
22 Q. And is there a log that -- that details that?
23 A. The same -- the same log would detail that that
24 tray had 300 ballots and 2 -- what is it -- 270 were
25 approved and 30 were -- need to -- the signature needs to

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1 be looked at. The signature verification process needed

2 to be looked at.
3 Q. Okay. So I think there’s a video online that was
4 made by Ms. Ruby Freeman where she’s walking through an
5 area where it looked like there were trays and there were
6 yellow and white envelopes in the trays; do you remember
7 seeing that?
8 A. Yes, sir.
9 MR. CHEELEY: Can we play that? I’m not sure --
10 do you have that, Liz.
11 THE VIDEOGRAPHER: Is that something that Melanie
12 had?
13 MR. CHEELEY: I think we got it a little while
14 ago. We may have to play that in a minute, but just -
15 BY MR. CREELEY:
16 Q. So when the – there’s -- are the people that are
17 allowed to have -- gain access to the trays of where the
18 envelopes are after even, I guess before they'd been --
19 had signature verification or after they'd been signature
20 verified before they make the trip to State Farm Arena is
21 there controlled access? And if so, how?
22 A. Let me make sure I understand the question. Are
23 you saying employees having access to the ballots or are
24 you saying what's the process of the employees having
25 access to the ballots?

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1 Q. Yeah. Let's start with that. Let's start with

2 the process. What's the process for employees having
3 access to the envelopes containing the ballots?
4 A. Okay. Each employee is hired -- we have mostly
5 temporary employees. Each employee is hired by our
6 outside agency, which is Happy Faces and they log-in.
7 They have a -- we're behind secure doors and they have a
8 secure lock that they work. They're the ones who
9 understand the (unintelligible) lock on the door and
10 they’re able to come in at that time. So based on the
11 secure lock and the employees themselves they are able to
12 gain entrance to their room where they actually process
13 the ballots. And that room could be signature
14 verification and credit for voting along with packing to
15 go to State Farm Arena.
16 Q. So let me ask you about these Happy Faces
17 supplied labor. What do -- I just want to make sure I'm
18 real clear. What do the Happy Faces temporary contract
19 staffers have -- what role do they play in when it comes
20 to anything from the time that envelopes containing
21 ballots arrive in the mail room until it leaves the
22 government billing and goes to State Farm?
23 A. Okay. Majority of the workers are Happy Faces
24 workers. We did have some Fulton County workers embedded
25 in there, but I would say 85 percent of them were Happy

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1 Faces workers who managed that process of signature

2 verification and data entry. They will also hire, in
3 addition to answering the phone, some of them will answer
4 the phone, help us answer the phone as a call center
5 clerk.
6 A. Okay. So you said 85 percent of the people doing
7 signature verification were temporary employees, actually
8 temporary staffers. I don't think employees is right the
9 name -- right word. Would you agree that they weren’t
10 employees they were temporary staffers?
11 A. I agree.
12 Q. So 85 percent of the people that were involved in
13 signature verification were from Happy Faces?
14 A. Yes, sir.
15 Q. Where is Happy Faces located?
16 A. Tucker, Georgia. I want to say.
17 Q. Has Fulton County used a Happy Faces in previous
18 elections prior to November of 2020?
19 A. You say, have we used them prior to 2020?
20 Q. Right?
21 A. Yes. Yes, sir.
22 Q. Like how far back in your 12 years have you used
23 them?
24 A. It’s been a while. I’m not sure. It think it
25 was around -- if I came on in 2009, it had to be probably

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1 around 2012, maybe somewhere right around there.

2 Q. Okay. Do you know who the, is Happy Faces just
3 located in Tucker or are they located in other states
4 other than Tucker, Georgia?
5 A. From my understanding just located in Tucker.
6 Q. Do you know -- were you involved in the decision
7 back in 2012 to bring in Happy Faces?
8 A. What was done the Fulton County purchasing, we
9 had an RFP sent out and Happy Faces won the bid through
10 the RFP. Fulton County used to have temporary employees,
11 but they moved away from temporary employees to a temp
12 service.
13 Q. Okay. Does Happy Faces supply temporary staffers
14 for Fulton County for purposes other than elections and
15 processing of absentee ballots?
16 A. Sure. Security is one. I know we do it for
17 security and warehouse personnel is another one.
18 Q. Warehouse personnel. Which warehouse?
19 A. Fulton County Elections warehouse.
20 Q. Okay. And what do Happy Faces employees or
21 staffers do at the Fulton County Elections warehouse? Is
22 that the one on the English Street?
23 A. Right. They’re couriers. I know they are
24 couriers, and they are also packer, some are precinct
25 trainer assistants. We have precinct polling classes on

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1 how to run a poll and they assist in that one also.

2 Q. So for the November 3rd election, Happy Faces
3 staffers, were they the ones solely doing the signature
4 verifications or were they're permanent Fulton County
5 employees or elections for employees doing the signature
6 verification?
7 A. No. They are -- permanent employees also does
8 signature verification.
9 Q. Can you -- do you have the names of the people
10 who were involved in the signature verification process?
11 A. Well, all of my staff, all my permanent staff
12 involved but majority of them was done by Rosalind Davis.
13 Q. The majority of it was done by who?
14 A. Majority of them was done by my permanent staff
15 was by Rosalind Davis.
16 Q. Rosalind Davis.
17 A. She's my rejection person. So before she rejects
18 it, she takes a look at it.
19 Q. So how many people were involved in this
20 signature verification process? You said 85 percent of
21 them were from Happy Faces; correct?
22 A. Correct. Well you have about -- I would say -- I
23 would say about 30 to 40 people.
24 Q. And when did those people begin the signature
25 verification process? You said it was maybe a week before

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1 the election?
2 A. No, no, no. The signature process is done
3 immediately upon receiving a ballot. The ballot goes from
4 mail room, we give credit, and then we do signature
5 verification. Then we lock up the ballot boxes, the ones
6 that are going to be delivered to State Farm.
7 Q. Okay. So the signature verification began as
8 soon as absentee ballots started arriving in the mail
9 room. And that's probably no more than 45 days out?
10 A. Yes, sir.
11 Q. Okay. Before the election. So by the time
12 November 2nd arrives what -- what percentage of the
13 absentee envelopes had been -- had gone through the
14 signature process would you say?
15 A. Based on Election Day, I would say -- I'll say
16 about 90 percent of them had gone through.
17 MR. CHEELEY: All right. Do we have the video
18 ready?
19 MS. KEMP: I’m working on it, sir.
20 BY MR. CHEELEY:
21 Q. And then tell me about how are the -- once the
22 signatures have been verified and then those are -- are
23 those stored up until the day before the election at a
24 location in the government building?
25 A. No. Once the signatures have been verified, we

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1 do a little sorting just to put the ballots in

2 municipality. Just in case we have to go find a ballot.
3 It's a little easier to have some sort of framework to
4 find a ballot. So we will put them in groups of 100 by
5 municipalities.
6 Q. By the municipality?
7 A. Correct. Except for the City of Atlanta. The
8 City of Atlanta we would do it by wards. City of Atlanta
9 has 12 wards. So we would do it by wards for the City of
10 Atlanta, but for the rest of them by municipalities.
11 Q. Okay. So when you put these in groups of 100 by
12 municipalities, is that what you call a batch?
13 A. That is correct.
14 Q. And when you do -- if you have anything within
15 the Atlanta -- City of Atlanta address you do about the 12
16 different wards, is that right?
17 A. Yes, sir.
18 Q. Do those contain approximately 100 ballots each?
19 A. Oh, very easy.
20 Q. I mean do those -- you try to limit all the
21 batches no matter -- no matter whether they're from
22 smaller municipalities in Fulton County or from the City
23 of Atlanta, do you try to keep the batches to about 100?
24 A. Yes, sir.
25 Q. And why is that?

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1 A. Two reasons, first of all it's easier to process

2 batches of 100. That's the first one. The second one is
3 so that if there needs to be -- being able to reach to see
4 any ballots that we had to, we'll be able to find things a
5 little easier. We know that if we find one, we probably
6 will find the other 99. Just trying to offset some of the
7 problems that would come if the State probably wanted to
8 see an envelope for John Doe. We know that if John Doe is
9 in ward number one. We had to go find him. At least we
10 can look in the zero one section to see if we can find it.
11 It helps a little bit.
12 Q. Okay. Is that a part of any written policies by
13 Fulton County to keep batches to 100?
14 A. It's a recommendation from the State, you know,
15 that we should keep them at 100.
16 Q. Okay. And do these -- refresh my memory. You
17 said these trays hold 350 to 400 individual envelopes with
18 ballots in them; correct?
19 A. Yes, sir.
20 Q. And so that would be three to four batches per
21 tray?
22 A. Right.
23 Q. And then were these -- the containers, the
24 suitcases that you call them, were these purchased because
25 they were large enough to put two trays in?

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1 A. Yes. These were -- the ballot boxes have been in

2 -- were double use. The double use was for supplies for
3 the poll worker, but also being able to secure the ballots
4 as they transitioned from one space to another.
5 Q. How many of those suitcases did you – did Fulton
6 County purchase to use for either transporting the
7 envelopes and the trays to State Farm Arena or for
8 supplies?
9 A. I don't know if we actually purchased some
10 recently because these were always in use. I don't
11 believe we purchased any other trays recently. I mean,
12 any other ballot boxes recently. Because as I said, they
13 were already in use as a vehicle we use for the poll
14 workers on the other days also.
15 Q. Did these suitcases were they originally
16 manufactured, I guess, for people to put clothes in and
17 take them on trips?
18 A. No, no. These are plastic -- these are plastic
19 ballot boxes that gives you the ability to lock the ballot
20 boxes down with a -- with a seal for chain of custody
21 purposes.
22 Q. So tell me about the seals and the locks on these
23 as you call them, I guess, ballot boxes; right?
24 A. Yes, sir. The seal is. Okay, go ahead.
25 Q. Yeah, just, I just want to know about the seal

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1 and the locks.

2 A. Yeah. The seal is a plastic tie.
3 Q. I'm sorry, you broke up.
4 A. I’m sorry.
5 Q. You said the seal is a plastic something.
6 A. It's a plastic tie.
7 Q. Tie.
8 A. Yes. And it's able to have a number to identify
9 itself. And you pull the tie closed and the only way you
10 can get it off is break the seal or cut it.
11 Q. Okay. And do you have the -- do you have those,
12 like an exemplar of those seals, what they look like?
13 A. We have some, yes.
14 Q. Are these kind of like a -- what color are they?
15 A. Majority of them are blue.
16 Q. Blue.
17 A. Yeah. We have them in red and green. I think
18 they have them in green too, but majority of them are
19 blue.
20 Q. Does the color between blue, green, or red
21 signify anything?
22 A. That'd be a good election chief question. I
23 think -- I think if -- if it does, they do it at their
24 level to identify things. At my level it doesn’t make a
25 difference to me.

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1 Q. Okay. All right. Let's take a short break real

2 quick.
3 MR. CHEELEY: Let’s take a short break real
4 quick.
5 (OFF THE RECORD: 3:45 P.M.)
6 (ON THE RECORD: 4:13 P.M.)
7 THE VIDEOGRAPHER: We’re back on the video
8 record. This is the beginning of media file number
9 four. The time is 4:14 p.m.
10 BY MR. CHEELEY:
11 Q. Mr. Jones, I guess I want to now kind of
12 transition to -- to the transport of the ballots in the
13 envelopes from Fulton County Government Center to State
14 Farm Arena, and I think I understood you to say that that
15 process started several days before November 3rd; is that
16 right?
17 A. Yes, sir.
18 Q. Approximately how many days was it before, if you
19 -- if you know?
20 A. Eight. Eight days.
21 Q. Eight days?
22 A. Yes, sir.
23 Q. Okay. And who handled the transport of those
24 ballots from the offices where they were housed in Fulton
25 County’s offices to State Farm Arena?

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1 A. We had a courier team comprised of Fulton workers

2 and Happy Faces workers.
3 Q. And did the -- did Fulton County do background
4 checks on any of the people who had access to these
5 ballots either from the time they came into the mailroom
6 or up through and including the time that they were
7 tabulated at State Farm Arena?
8 A. I know that for Fulton County, yes. If they’re a
9 Fulton County worker, there is a background check. For
10 Happy Faces, they go through their checks, also.
11 Q. Do you know what checks Happy Faces -- or what
12 criteria they use for their background checks?
13 A. I don't know.
14 Q. The -- and I think you indicated that there’s a
15 log that shows -- maybe I haven’t asked you this question.
16 Is there a log that shows when the trays inside these
17 ballot boxes were transferred over to State Farm Arena and
18 who --
19 A. Yes.
20 Q. -- and who did -- who the courier was for each
21 trip?
22 A. It does not know the courier.
23 Q. Okay. Was there a system set up so that when
24 these -- you know, these dark suitcases left Fulton
25 County’s offices, did they have a number on the suitcase

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1 other than just the number on the plastic tie?

2 A. Yes. They had a (unintelligible) seal.
3 MR. CHEELEY: Who was that?
4 THE VIDEOGRAPHER: That was Garland.
5 MR. CHEELEY: Garland, please mute your phone.
6 It’s disruptive.
7 BY MR. CHEELEY:
8 Q. Now, Mr. Jones, I -- I didn’t hear your answer.
9 A. Each ballot box had its own number and it was
10 correlated with the seal that’s tied to it.
11 Q. Okay. So you said each ballot box had its own
12 number?
13 A. Correct.
14 Q. And it correlated with what?
15 A. The seal.
16 Q. Okay. So would -- how were these ballot boxes
17 designated, with a number or a letter or a combination or
18 what?
19 A. Number, sequentially.
20 Q. Okay. And what was the starting number and how
21 many numbers do you think it went to?
22 A. Starting number was 1 and I don’t have the idea
23 of what’s the last number.
24 Q. Do you know approximately how many of these
25 ballot box cases there were?

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1 A. We used -- we kept rotating the ballot boxes

2 through the process, so we tried to get a minimum of 15 a
3 day, at -- at a minimum. But during the process, in the
4 beginning, we noticed that at that rate, we would never
5 get done, so we extended the number of ballot boxes that
6 we can do as much as we could.
7 Q. How many separate ballot boxes do you think there
8 were?
9 A. I think we had around a minimum of 20.
10 Q. All right. Do you -- does Fulton County still
11 have these ballot boxes?
12 A. Sure.
13 Q. Okay. Are those ballot boxes required by the
14 Secretary of State?
15 A. No. There is -- the code does not say that I’m
16 required to have ballot boxes.
17 Q. Are those ballot boxes on wheels?
18 A. Yes. Two back -- half of it is on wheels.
19 Q. You say about half of them are on wheels?
20 A. Yes. The two back ends of the ballot boxes, so
21 you can left one end and be able to pull the ballot boxes.
22 They have two wheels in the back.
23 Q. Okay. And so each ballot box holds two trays of
24 350 to 400 envelopes, correct?
25 A. Correct.

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1 Q. So if you’re counting hundreds of thousands of

2 these absentee ballots and you’ve only got 20 of these
3 ballot boxes, that’s -- that’s a lot of trips back and
4 forth to State Farm Arena, right?
5 A. Correct. We made -- we made two trips at the
6 beginning each day.
7 Q. Okay. Do you know how many total batches there
8 were that -- that were scanned on the five scanners at
9 State Farm Arena?
10 A. How many batches?
11 Q. Yes.
12 A. Oh, no, I don't know that.
13 Q. Do you know how many batches and batch tally
14 sheets -- the handwritten batch tally sheets were sent to
15 the Secretary of State when the vote was certified?
16 A. You said -- the only thing that we sent to the
17 Secretary of State was the hand count sheets. Are -- are
18 those the ones you’re referring to?
19 Q. I’m referring to -- there’s -- I don't know if
20 you can see it here, but we downloaded off the Secretary
21 of State’s website, it says Audit Board Batch Sheet.
22 A. That came from --
23 Q. And it’s got --
24 A. That came from the hand count.
25 Q. Okay. And was there -- was there a batch tally

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1 sheet that would have preceded the audit board batch

2 sheets?
3 A. Yeah. Those are two different sheets. The hand
4 count actually had its batch sheet so that a person can
5 begin to count the number of ballots in that batch toward
6 -- by candidates. Ours doesn’t have candidate information
7 on it.
8 Q. Okay. So do you -- does Fulton County still
9 maintain or does the Clerk of Court -- of Superior Court
10 maintain the initial batch tally sheets?
11 A. The initial batch hand-scanned, I’m not sure who
12 holds that one. I know that it’s not required to go to
13 the courts.
14 Q. Okay.
15 A. So I’m not sure if the Court has them or not.
16 Q. Would you mind checking on that, and if you have
17 possession of those initial batch tally sheets, let Ms.
18 Ringer know so that -- if she knows -- if you don’t have
19 them, I guess that means you probably sent them over to
20 the Clerk of Court and Gagan can check and -- but we would
21 like a copy of those batch -- those initial batch tally
22 sheets.
23 MS. RINGER: Okay. We’ll look into that.
24 BY MR. CHEELEY:
25 Q. And would the -- would the initial batch tally

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1 sheets that would have preceded the audit board’s batch

2 sheets, would those initial batch tally sheets have been
3 filled out on the night of the election, November 3rd?
4 A. Which -- which batch tally sheets are you
5 referring -- every process --
6 Q. You --
7 A. Every process has a batch tally sheet, so which
8 one -- which one are you referring to?
9 Q. Okay. I didn’t realize until I just started
10 asking these questions that there was -- that the one that
11 I held up and showed you was from the audit board batch
12 sheet. And you -- I think you said that there’s another
13 batch tally sheet that doesn’t show the names of the
14 candidates and how many votes they got.
15 A. Correct. It’s just our working papers, document
16 papers to say that for this batch, we had these many and
17 what are the results of it.
18 Q. Okay. And when you mean the results of it, what
19 does that mean?
20 A. The results of the ballot. Is it going to be
21 counted or not? The ballot -- if the ballot was a good
22 ballot or was it going to be rejected for whatever reason,
23 not signed, signatures are not matching. So what was the
24 reason why this ballot is not going to be going to State
25 Farm immediately now?

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1 Q. Okay. All right. So -- and I think you had

2 previously -- you and Ms. Ringer have said that y’all
3 would furnish us that information. That has to do with
4 the initial examination of the signatures, correct?
5 MS. RINGER: Okay. Wait, I’m -- I’m confused.
6 BY MR. CHEELEY:
7 Q. Maybe let me come at it this way. Were the tally
8 sheets in the trays when they were -- before they were put
9 into the cases that were transported to State Farm Arena?
10 A. Yes. They had -- they had another batch sheet to
11 go in the tray with the batches.
12 Q. Okay. And that would state how many envelopes
13 were in each tray, correct?
14 A. Correct.
15 Q. Any other information in that -- on that batch
16 sheet?
17 A. Just tells the number of ballots that were
18 received in that batch, which was normally 100. You know,
19 we have some that were 97, 98, depending on the number of
20 ballots that we might have to pull out based on a person
21 not meeting the qualifications for a good ballot.
22 Q. Okay. So what I’ve asked for -- and I’ll -- I
23 guess I’ll just make sure it’s on the record clearly that
24 I’ve asked for those batch sheets that address the ones
25 that were pulled out or, you know, rejected --

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1 A. Yes.
2 Q. -- as well as the batches that went with the
3 trays before they were put into the suitcases and sealed
4 and sent to State Farm Arena, okay?
5 MS. RINGER: This is Ms. Ringer. I need -- I
6 need some clarification because I wrote down that we
7 called that a signature verification log and you’re
8 now calling it batch sheets. Is that the same thing?
9 THE WITNESS: It’s the same thing.
10 MS. RINGER: So we need the signature
11 verification logs for what went to State Farm Arena.
12 THE WITNESS: Yes.
13 MS. RINGER: And then there’s something about
14 some sort of batch sheet or log for what was rejected.
15 THE WITNESS: Same thing.
16 MS. RINGER: Okay.
17 THE WITNESS: It’s going to be on the same --
18 same log.
19 MS. RINGER: Okay. Thank you.
20 BY MR. CHEELEY:
21 Q. Does -- and you do also, I think, if I understood
22 your testimony correctly, Mr. Jones, you do also have a
23 log of the ballot boxes by number and when they were
24 transported to State Farm Arena, right?
25 A. Yes.

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1 Q. And that’s all part of the chain of custody,

2 correct?
3 A. That is correct.
4 Q. And is that -- the chain of custody, keeping logs
5 like that is part of best practices, correct?
6 A. Yes, sir.
7 Q. And that’s what y’all always try to do is to use
8 best practices, correct?
9 A. That is correct.
10 Q. Do you -- I may have failed to ask you this
11 earlier. I know you gave me the locations. I think you
12 said there were maybe a total of four locations where
13 there were dropboxes; is that right?
14 A. Well, we -- for in-person. We have -- in
15 November, I think we were in the 30s of the number of
16 dropbox locations. If I’m not mistaken, we were in the
17 30-some or right around in there. But the ones that could
18 have done in-person, we had dropboxes at those particular
19 locations, which would be three.
20 Q. Okay. So --
21 A. And at the Government Center, we had two
22 different locations, which would have been a total of four
23 boxes.
24 Q. Right.
25 A. Three locations, four boxes.

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1 Q. Right. And so on the dropboxes at these other 30

2 locations, do you have a chain of custody log showing when
3 those envelopes were picked up and taken to -- to your
4 offices there in Fulton County?
5 A. Yes. I think Nadine does have that one. She
6 actually -- her people actually go through and collect
7 that. They do have a chain of custody when they drop it
8 off to us. We sign it, we give it back to them, so I
9 believe that Nadine should have those chain of custody
10 forms for the dropboxes.
11 Q. Okay. We would also request those chain of
12 custody forms as well, please, sir.
13 MR. CHEELEY: And please, Cheryl.
14 BY MR. CHEELEY:
15 Q. Is that okay with you, Mr. Jones?
16 A. Yes.
17 Q. I -- I remember hearing something in the media
18 about dropboxes, but I don’t -- I don't know what the
19 facts really are. Do these dropboxes -- these 30 plus
20 these four dropboxes, were they required to be under some
21 sort of camera surveillance or something?
22 A. Yes, sir.
23 Q. Okay. And was that by part of that consent
24 agreement that was entered into, I guess, in the
25 settlement of the lawsuit?

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1 A. No. That -- that’s a recommendation that came

2 from the Secretary of State. Just -- it was an SEB rule
3 to say that if we had dropboxes, these are the criteria
4 before you can have a dropbox and one of them was 24-hour
5 video surveillance.
6 Q. Okay. And would Ms. Nadine Williams have those
7 records and the video?
8 A. As far as the video is concerned?
9 Q. Yes, sir.
10 A. No, I don't think so. I think those videos are
11 based with our IT department.
12 Q. Okay. Were those -- was the video livestreamed
13 from the dropboxes to your IT department?
14 A. I’m not sure how they captured them in detail,
15 but they did record it, the -- each ballot box. I’m not
16 sure how they recorded and what mechanism.
17 Q. Who would know as to whether or not anyone
18 actually real-time monitored those videos streaming or the
19 recordings of the dropboxes to see if there was anything
20 improper occurring at those dropboxes?
21 A. That’s a good question. I wouldn’t know unless
22 somebody sat down and took a look at every video.
23 Q. I’m sorry. What was the answer again?
24 A. I said I’m not sure. Unless somebody sat down
25 and looked at every video, I don't know who -- who would

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1 be the person.
2 Q. Okay. Who would know the answer to that question
3 most likely?
4 A. Now, your question --
5 Q. Nadine?
6 A. Now, your question was who was responsible or who
7 actually looked at the video?
8 Q. I guess who -- really, it’s -- I guess it’s a
9 simpler question than that. Who would likely know at
10 Fulton County whether or not anyone has reviewed those --
11 the video of those dropboxes to see if anything of
12 suspicion or of concern appears in those videos?
13 A. Oh, I doubt if anybody would know definitely
14 about all 30 of them. But IT could tell you if there was
15 anybody who requested the videos to be seen. But I doubt
16 it that we had anybody who requested all this information
17 and sat there and watched it for those dates, those 40-
18 some-odd days.
19 Q. So that was going to be my next question. Those
20 dropboxes were put out how -- how far in advance of
21 November 3rd?
22 A. Probably the -- somewhere around maybe the 40th
23 day afterwards.
24 Q. Okay. Did -- did Fulton County keep a log of how
25 many came in -- how many absentee ballots came in as a

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1 result of being deposited in these dropboxes --

2 A. Yes.
3 Q. -- on a daily basis?
4 A. Yes. That information is the same information
5 that we’re going to give you when we get the application.
6 It’s in a spreadsheet that showed how many came in on --
7 applications came in and how many came in via dropbox and
8 by mail.
9 Q. Okay. And who is the head of the IT department
10 that would have custody and knowledge about these -- the
11 videos of the dropboxes?
12 A. Our head of IT department, his name is Glenn
13 Melendez.
14 Q. Graham Melendez?
15 A. Yes. Glenn, G-L-E-N-N.
16 Q. Okay. So he’s, like, the director of IT?
17 A. Yes, sir.
18 Q. Okay. I think you have testified that by
19 November 2nd, probably 90 percent of the envelopes
20 containing ballots had been opened at State Farm Arena and
21 scanned; is that right?
22 A. Yeah. I -- I believe it’s somewhere around in
23 there. Uh-huh.
24 Q. Okay. So the last delivery to State Farm, how
25 many -- how many would you estimate of these 20 ballot

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1 boxes would have been delivered on November the 2nd or --

2 or even on November 3rd?
3 A. There was a large number on November 2nd and 3rd.
4 I’m not sure, but there was a big spike on November 2nd
5 and 3rd.
6 Q. And there couldn’t have been more than 20 of
7 those cases if that’s all you -- all that Fulton County
8 owned, right?
9 A. The spike was so big that we didn’t finish all of
10 ours on November 3rd. We had to go into November 4th to
11 finish up.
12 Q. Okay. So --
13 A. Our ballot boxes were not closed until 7:00.
14 Once the ballot boxes were closed at 7:00, we did not
15 finish processing every ballot that came in after 7:00.
16 So we moved not only for Election Day, but we had to work
17 another day after Election Day to -- to catch up with
18 those numbers.
19 Q. Okay. So your log of the -- that you have for
20 the transport of the trays inside of these black cases --
21 the ballot box cases would show how many of the cases were
22 delivered on November 2nd, correct?
23 A. Yes. Yes.
24 Q. And then -- and then, November 3rd, would --
25 would there have been more delivered on November 3rd to

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1 State Farm Arena?

2 A. Yes, sir. But what we did for the last mailing
3 -- for the last one, we put -- instead of putting it in
4 the black box, what we did was put it in the -- put it in
5 a mailing bucket which holds 30 to 40 trays.
6 Q. Okay. It’s called a mailing bucket?
7 A. Yes.
8 Q. And it holds -- instead of two trays, it holds 30
9 to 40?
10 A. Yes, sir.
11 Q. Is that something you have to bring in on some --
12 like a pallet?
13 A. (No audible response).
14 Q. Pardon?
15 A. I didn’t hear you. I didn’t hear your question.
16 I’m sorry.
17 Q. So if you’re bringing in 30 to 40 trays in a
18 mailing bucket on -- and this would have been on what
19 days, roughly? November --
20 A. Probably the last two days, the last three days.
21 The 2nd, the 3rd, and the 4th.
22 Q. So can one person pick up 30 to 40 trays in a
23 mailing bucket?
24 A. No. What happens is -- you know, chain of
25 custody, we have to have two people anyway. So what

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1 happens is that these buckets are rolling buckets, rolling

2 bins, big mail rolling bins, and the trays are lowered
3 into the rolling bins and what we did was have a -- these
4 rolling bins to roll into our van. We had a moving van to
5 carry our ballots from one location to another.
6 Q. All right. And so are all those 30 to 40 trays
7 in a mailing bucket, are those on rollers or -- or what?
8 A. They are on rollers. The bucket is a rolling
9 bucket.
10 Q. Okay. And how are -- how is that mailing bucket
11 in the -- I think you call it rolling bins, how is that
12 secured -- the contents of it secured?
13 A. What we did was that we put a cover on top of it
14 and secured the cover with a tie -- with a seal.
15 Q. Okay. What kind of cover is this? Is it a
16 plastic cover or a belt or -- I mean, a fabric or what?
17 A. It was -- I want to say it was plastic, if I
18 remember correctly.
19 Q. And did the plastic cover, is it made for that
20 purpose or is it something y’all just kind of adapted?
21 A. It’s something that we did. It -- it was not
22 made for that purpose.
23 Q. What do y’all use them for when you’re not
24 putting them in these rolling bins? What do you use the
25 plastic cover for?

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1 A. Oh, I don't know. Since we were doing one trip

2 with the big bins, we didn’t have to do too many multiple
3 trips back and forth.
4 Q. Okay. So is -- I guess, how many of these bins
5 did you utilize?
6 A. How many of the bins did I what?
7 Q. How many of these rolling bins with 30 to 40
8 trays of them did you utilize?
9 A. We had two.
10 Q. Okay. And what would you -- you said you had to
11 hire a moving company to move those?
12 A. No, sir. We used employees and --
13 Q. I mean, I --
14 A. -- temps.
15 Q. You said a moving van, I think.
16 A. Right. We -- we rented a van for -- to transport
17 our ballots back and forth. And in the beginning, it was
18 the ballot boxes. In the end, it was the rolling bins.
19 Q. Okay. Got it. So did -- by November 2nd, it --
20 had it become apparent to you and others in the elections
21 division that those 20 cases, half of which were on wheels
22 and half of which weren’t on wheels, weren’t going to move
23 enough volume to meet the November 3rd tabulation
24 deadline?
25 A. Correct.

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1 Q. And so when did you -- did you just stop using

2 the wheeled black -- or dark-colored containers to
3 transport two trays at a time?
4 A. What we did was leave the containers at the State
5 Farm so staff could secure any unfinished ballots that
6 they had to process.
7 Q. You said you left the containers at State Farm so
8 that the staff could continue to process any untabulated
9 ballots?
10 A. To secure. To secure the ones that are not
11 processed.
12 Q. Okay. Do these --
13 A. Because ones it got processed, what we did is
14 that we boxed them up immediately once they got processed.
15 But if they were not either boxed up with the seal, they
16 had to stay in a secure -- secured down with the seal.
17 Q. Okay. So by the time that November 2nd rolled
18 around, were there envelopes containing ballots at State
19 Farm that had not been opened and processed yet?
20 A. I believe that majority of the ones by November
21 2nd that were delivered were already processed at State
22 Farm. We -- we couldn’t get the work to State Farm fast
23 enough. My bottleneck wasn’t at State Farm. My
24 bottleneck was at signature verification.
25 Q. So is that -- is it fair to say then by the night

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1 before Election Day, Monday night, November 2nd, were

2 there any ballots in the suitcase-type ballot boxes that
3 had not been processed prior to the morning of November
4 the 3rd, Tuesday?
5 A. I don't know that definitely because as I said
6 that I’m not sure if the ballots that were taken were
7 actually from the Government Center or were they used as a
8 mechanism of storage for State Farm. I’m not sure which
9 one at that time was the ballot boxes being used for.
10 Q. Okay. So when did -- I guess the way I
11 understood your testimony from just a few minutes ago, you
12 started using the two big rolling mailing buckets on bins
13 -- or rolling bins on -- what was it? What was the day
14 you first started using those instead of the suitcase-type
15 bins?
16 A. I think -- I think it was around the 2nd. I --
17 when we found out that we couldn’t turn it around -- we
18 couldn’t keep turning around with the ballot boxes, it
19 just wasn’t working, we had to find a new mechanism. The
20 people at State Farm were finishing up their work, and we
21 never had enough work out there for them to continue. So
22 that’s when strategies began to change so that we can have
23 -- we had work; we just had to get it out to State Farm --
24 make sure signature verified and then get it out to State
25 Farm. And, you know, one of the main concerns that we had

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1 was to keep people back and forth, going back, and I

2 didn’t like too many folks keep going back and forth. So
3 what we decided to do was to use the bins, the rolling
4 bins. Asked the staff, is that -- is that hard to get
5 onto the truck? They said, we can do it, and as soon as
6 they told me that one, I said, we can just use it instead
7 so that we can have the ballots out there so they can
8 process them timely.
9 Q. Okay. Do you have a log that shows when you
10 started using the rolling bins as opposed to the --
11 A. I think --
12 Q. -- boxes?
13 A. I think so. I think that the same log that had
14 the ballot boxes, I think they were in the same log.
15 Q. Okay. And so when we get a copy of that log, it
16 -- how will it likely show the use of the first time of
17 these rolling bins?
18 A. It should. If I’m not mistaken, it should say
19 instead of you having around 800 ballots to the bin,
20 you’ll have thousands of ballots to the bin. You’ll see a
21 jump in the number of ballots and you should see the --
22 you should be able to -- you should see the count of the
23 number of ballots increase and the number of vehicles --
24 the ballot vehicles decrease.
25 Q. Okay. So let me -- let me ask you, did anybody

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1 with your team from Fulton County Elections stay overnight

2 during those eight days leading up to November 3rd to
3 watch over the -- the contents of whatever was delivered
4 in these ballot boxes or the bins?
5 A. We shut down. Everybody shut down when -- State
6 Farm Arena, my employee was the last one to leave and they
7 locked the doors. And down here, we all shut down and
8 walked out at the same time.
9 Q. Okay. And then, so the Dominion scanners would
10 have been utilized for eight days leading up to November
11 3rd; is that fair to say?
12 A. Yes, sir.
13 Q. Were y’all having any particular problems of any
14 kind with the scanners?
15 A. I don't remember us having any real problems with
16 the scanners. Not that I can remember.
17 Q. And it’s my understanding there were five
18 scanners?
19 A. Yeah, I think so. I think there were five. One,
20 two, three, four, five. I think there were five.
21 (PLAINTIFF’S EXHIBIT NO. 1 INTRODUCED.)
22 Q. Okay. And these -- these audit board batch
23 sheets that I asked you about earlier, I’m going to mark
24 that -- a page out of one of them as Exhibit 1 to your
25 deposition. And this came out of -- I believe -- let’s

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1 see. This came out of scanner five. We printed these off

2 from the Secretary of State’s website, these audit board
3 batch sheets, and put them according to the five different
4 scanners so that we could look through them. And --
5 MS. RINGER: Mr. Cheeley, are you sharing this?
6 I’m sorry.
7 MR. CHEELEY: Pardon?
8 MS. RINGER: This is Cheryl Ringer. Are you
9 going to share those on the screen? I’d like to see
10 what you plan to --
11 MR. CHEELEY: Yeah. Yeah, I’m getting ready to.
12 BY MR. CHEELEY:
13 Q. So let me -- let me ask you. Did these
14 tabulators -- the Dominion tabulators one, two, three,
15 four, and five, do they -- do they also have other unique
16 identifying numbers to each tabulator?
17 A. Each --
18 Q. Like 5150, 5160, 5162, 5164, and 729?
19 A. I’m not familiar with those. That would be under
20 Nadine’s jurisdiction.
21 Q. Okay. What time did you go to State Farm Arena
22 on November the 3rd for the first time?
23 A. I think I first arrived at State Farm on November
24 3rd around 10:00.
25 Q. a.m. or p.m.?

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1 A. p.m.
2 Q. Okay. And where had you been prior to that that
3 day?
4 A. I was in our call center at the Government
5 Center.
6 Q. I’m sorry. I couldn’t quite understand what you
7 just said. You were -- you had been where?
8 A. We have a call center on Election Day. I was at
9 -- inside of our call center at the Government Center
10 building.
11 Q. Okay. And what generally were you doing at the
12 call center -- what time did you arrive at the call center
13 that morning?
14 A. 5:00 in the morning, a.m.
15 Q. Okay. And generally, what were you doing during
16 the day at the call center?
17 A. Handling escalated calls, making sure everything
18 is going as planned.
19 Q. You say handling escalated calls?
20 A. Yes, sir.
21 Q. What do you mean by escalated calls?
22 A. If a person who answers the phone cannot answer
23 the question, they, in turn, will have a route to be --
24 the call to be escalated to a knowledgeable person. If
25 it’s a request that my staff can’t even answer, I’m

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1 available for my staff to answer their questions.

2 Q. Okay. And why did you leave -- I guess, did you
3 stay there until you left to go to State Farm?
4 A. Yes, sir.
5 Q. And why did you head over to State Farm?
6 A. To check on the staff that was there at State
7 Farm and to see if we can begin to shut down.
8 Q. Okay. Had you -- had you spoken to anybody
9 working at State Farm prior to driving over there?
10 A. Sure. Sure.
11 Q. And who did you talk to?
12 A. I talked to several of my staff. They were --
13 they were concerned when they were -- came in that morning
14 and found that there was water on the floor.
15 Q. Okay. And that would have been the morning of --
16 early in the morning on November 3rd, correct?
17 A. Correct.
18 Q. When did you first hear about there being water
19 on the floor at State Farm Arena on November the 3rd?
20 A. I would say around 5:45, 6:00, a little bit
21 before 6:00.
22 Q. a.m.?
23 A. a.m., yes.
24 Q. Okay. Did any of the people at State Farm Arena
25 -- well, let me strike that and ask this first.

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1 Do you remember -- do you remember who it was that

2 told you there was -- there had been water on the floor
3 that -- early that morning on November the 3rd?
4 A. I don't remember which -- first person who told
5 me, but the two I do remember were Ms. Katrina and Ms.
6 Moss. Those were the two that I remember definitely.
7 Q. And did you say Ms. Katrina?
8 A. Ms. Katrina, yes, and her last name escapes me at
9 this particular time.
10 Q. Okay. And then, who was -- is that Shay Moss?
11 A. Yes.
12 Q. All right. I think it’s -- her real name is
13 Deshay, or do you call her Shae?
14 A. Wandrea. Her real name is Wandrea Moss.
15 Q. Wandrea. Okay. Which -- so those two ladies you
16 spoke to you think early in the morning of November 3rd,
17 and they told you about the water being on the carpet?
18 A. Yes, sir.
19 Q. And did you -- did they tell you that somebody
20 from State Farm Arena came in and vacuumed up that water?
21 A. Well, not at that particular time. The phone
22 call was, Mr. Jones, our room is flooded. And I said, oh,
23 you know, surprised to hear it. And I said, make sure
24 that everybody is out the room, you know, we don’t want
25 anybody to slip and fall, looking out for the safety of

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1 the employees, and then I said, have you contacted State

2 Farm Arena to see if we can have somebody clean it up? I
3 said, let me see if we can have somebody -- some contact
4 information to see if we can have somebody to clean it up.
5 Have y’all contacted State Farm? They said, we’re in the
6 process of doing that, and I said, okay, good. We
7 eventually contacted State Farm. I told them to reach out
8 to me when somebody actually had come and started the
9 process. They did reach out to me. I asked what the
10 staff was doing at this particular time. Fortunately,
11 around 6:30 to 7:00, we were preparing breakfast for the
12 staff, so the staff had an opportunity to eat between the
13 cleaning of the carpet. And around 8:00, I was given a
14 phone call to say that we started back work; everything is
15 clean, and then the staff came back and started back
16 working.
17 Q. So around 8:00, the water had been vacuumed up
18 off the carpet and y’all -- your people were able to
19 resume?
20 A. Yes, sir.
21 Q. Did -- did you ever learn what the source of the
22 water was?
23 A. I was told that it was a leaking toilet, is my
24 understanding. At the time -- at the time, initially, my
25 staff didn’t know. All they knew was just water was on

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1 the floor.
2 Q. I see. Did the water start leaking again later
3 on that day?
4 A. I don’t know.
5 Q. Or night?
6 A. I’m not -- I’m not 100 percent sure. Don’t know.
7 Q. When you got up --
8 A. But I know that after they cleaned it up, we
9 never had that problem again.
10 Q. Okay. So by the time you got over to State Farm
11 Arena on November the 3rd around 10:00 p.m., was there any
12 water leaking from the --
13 A. No, sir.
14 Q. -- from the ceiling?
15 A. No, sir. I didn’t know -- by looking at the
16 room, you would never know that there was a leakage
17 earlier.
18 Q. Okay. And it -- and so you say you learned that
19 the source of the water leak was a toilet?
20 A. That’s what somebody told me.
21 Q. Okay. It wasn’t a water main break, was it?
22 A. No, I don't think so.
23 Q. Did you hear reports --
24 A. I heard it was a toilet.
25 Q. Did you ever hear reports on the media on the

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1 night of November the 3rd that votes were being suspended

2 because of a water main break at State Farm Arena?
3 A. No, I did not hear at the time what the media was
4 saying because at that time, the call center is so busy
5 that it’s hard for us to look at news -- current event
6 news on the media.
7 Q. So when -- when did you first hear reports in the
8 media that there had been a water main break at State Farm
9 Arena?
10 A. It was probably after the election. I’m not real
11 sure of when it was first said or described as a water
12 main break of some sort. I think maybe -- you know, maybe
13 during -- after the 3rd. I’m not sure. I just know that
14 we had water on the floor and we couldn’t work because of
15 water on the floor. And I asked them, is it still
16 dripping? Are we still having dripping issues? And one
17 said yes and one said no. I’m not sure which one said
18 which, and I said, well, we need to stop it. Let’s get
19 this thing stopped immediately, and so --
20 Q. And that was right -- and that conversation that
21 you had with Ms. Katrina -- you can’t remember her last
22 name, or --
23 A. Yeah, it’s either Katrina or Ms. Moss.
24 Q. Yeah. Ms. Katrina and -- and Wandrea Moss,
25 right?

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1 A. Yes.
2 Q. The conversation that you had with them was early
3 in the morning, like before 7:00 a.m.?
4 A. That is correct.
5 Q. Okay. When you arrived at State Farm Arena
6 around 10:00 p.m., did you see any of the media in the
7 room?
8 A. As I was leaving, I saw a news media crew and our
9 -- our press secretary leaving with them at the time.
10 Q. Who --
11 A. Ms. Regina Waller.
12 Q. The press secretary was who?
13 A. Regina Waller. And I asked them, I said, hey,
14 were y’all through? You know, and she said, yeah, they
15 had packed up everything, and I said -- that’s what Ms.
16 Regina said. And I said, okay, I’m coming upstairs.
17 Thank you.
18 Q. So where did you see Regina Waller and the press
19 for the first time when you got to State Farm --
20 A. It was -- it was before we got on the elevator.
21 They were en route to the parking lot. I was in the
22 building. It was inside the State Farm Arena, but it was
23 outside the elevator.
24 Q. Okay. And the -- the tabulation of the votes was
25 occurring on the sixth level; is that right, Suite 604?

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1 A. Yes. Yes. Yes. Yes, it was on the sixth level.

2 Q. Okay. And so how many people were in Suite 604
3 when you walked into the room a little after -- right
4 around 10:00 p.m.? Were there any poll observers in
5 there?
6 A. No, there were no poll observers.
7 Q. Prior to arriving at State Farm at 10:00 p.m.,
8 had you received any phone calls from anybody saying that
9 the vote tabulation was going to be ceased for the night?
10 A. No. I have -- I didn’t get any calls about that.
11 Q. Or no text messages or e-mails?
12 A. No, sir. That’s -- that’s my call.
13 Q. That’s your call to make?
14 A. Yes, sir.
15 Q. Okay. Did it seem odd to you that as you were
16 coming in to the State Farm Arena you saw the press
17 leaving the building with Regina Waller?
18 A. Yes, sir.
19 Q. Did you tell her that, hey, that’s my call to
20 make, not -- not anybody else’s?
21 A. No, I did not. I did not. But when I got
22 upstairs, I was asking -- I asked my staff, well, why
23 aren’t we processing, and they told me that everything was
24 done except for three -- I think they said three bins,
25 three to four bins. And I said, okay. And in order --

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1 they were saying that they thought it was just best to

2 pack it up at that particular time.
3 Q. Okay. So do you remember who it was that told
4 you that everything was done except for three or four
5 bins?
6 A. Ms. Moss. She was -- she was the person in
7 charge at State Farm at the time.
8 Q. Okay. Is she the daughter of Ruby Freeman?
9 A. Yes, she is the daughter of Ruby Freeman.
10 Q. Is Ms. Moss a full-time employee of the elections
11 division of Fulton County?
12 A. Yes, she is. She’s a permanent staff member.
13 Q. And what’s her title?
14 A. Registration officer.
15 Q. And what does registration officer do?
16 A. Registration officer basically is a data clerk --
17 a data entry clerk, but has the ability to lead groups of
18 people in special projects. At that time, Ms. Moss was
19 given the assignment to make sure that she overled the
20 absentee ballot process at State Farm.
21 Q. Okay. Had she ever led a project involving
22 absentee ballots prior to November 3rd?
23 A. No, not -- not absentee ballots. No.
24 Q. How -- how long roughly has Ms. Moss worked for
25 Fulton?

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1 A. Ms. Moss probably has been here at least maybe

2 from five to seven years.
3 Q. So when you -- when you heard Ms. Moss say that
4 everything was done except for three to four bins, what
5 did you understand her to mean by the word bins?
6 A. The ballot box bins.
7 Q. Okay. But are those the -- the ones that
8 contained 30 to 40 trays?
9 A. No. Those are the ones that can handle two
10 trays. They were using them for storage so that once they
11 left that they would be able to store the secure material.
12 They can -- they can secure the materials better in the
13 ballot box bins.
14 MS. RINGER: Attorney Cheeley, we’re going to
15 need to take a break. I’m going to need to speak to
16 you during break, sir
17 MR. CHEELEY: I’m sorry. I can’t hear you.
18 MS. RINGER: This is Cheryl Ringer. We’re going
19 to need to take a break and I need to speak to you
20 during the break.
21 MR. CHEELEY: Speak to who during the break? Me?
22 MS. RINGER: Yes, sir. You, Mr. Cheeley.
23 MR. CHEELEY: Okay.
24 THE VIDEOGRAPHER: Going off the video record.
25 (OFF THE RECORD: 5:17 P.M.)

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1 (ON THE RECORD: 5:20 P.M.)

2 THE VIDEOGRAPHER: We’re back on the video
3 record. This is the beginning of media file number
4 five. The time is 5:20 p.m.
5 MR. CHEELEY: All right. Liz, would you pull up
6 Exhibit 2?
7 MS. VAIDEESWARAN: I’m sorry. If I could
8 interrupt, could you tell me what Exhibit 1 was
9 because I don’t -- I didn’t --
10 MR. CHEELEY: I haven’t used it just yet.
11 UNID. FEMALE: Okay. Got it.
12 MR. CHEELEY: I’ll use it next.
13 BY MR. CHEELEY:
14 (PLAINTIFF’S EXHIBIT NO. 2 INTRODUCED.)
15 Q. Okay. Can you see that okay, Mr. Jones?
16 A. Yeah.
17 Q. All right. Is that your signature up there?
18 A. Yes, sir.
19 Q. All right. That’s going to be worth a lot of
20 money. You know that, don’t you?
21 A. I doubt it.
22 Q. So tell me what that -- what that document is,
23 Exhibit 2, and why you signed it.
24 A. This is the hand count batch sheet, and the staff
25 was -- we had two different -- we had split counts on the

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1 batch sheet and I was trying to notarize that -- the ones

2 that we had to recount as far as the hand count is
3 concerned. And I’ll try to say that I saw this one. The
4 people who were doing the count said that we had these two
5 things that were alike, and so I said that, well, let me
6 at least initial it to say that you verified that this was
7 the same thing. So --
8 Q. So help me, I guess, to put it in country boy
9 terms for an old boy like me, 364, what does that mean out
10 beside your name?
11 A. The 364 was the -- the mechanism given to
12 identify that stack of ballots, and 365 was another
13 mechanism. It could have been a batch number or -- or
14 something. It signifies that group of ballots, 364 and
15 then 365. It signifies that group of ballots.
16 Q. So is this -- is this who -- a combination of two
17 ballots -- two batches, 364 and 365?
18 A. Yes, sir, because if you look, it’s almost 100
19 apiece. Each batch is about 100 apiece.
20 Q. Okay. And I thought you said earlier that
21 batches were supposed to be limited to 100.
22 A. Well, sometimes we’d go over one, a lot of the
23 times, most of the times we’d go under 100. Sometimes
24 people can’t count when they’re doing the counting with
25 the batches.

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1 Q. Okay. So what were you called upon to do; play

2 Solomon or what?
3 A. The people who were doing the audit had a
4 question, how would we reconcile. Well, they had two
5 stacks and what they had done previously, I believe in
6 this case, they had started with making -- instead of
7 having two separate stacks, making together, and I was
8 saying, oh, oh, oh, oh, oh, if I remember this case, and I
9 said that we should have two separate ones. And we went
10 through the sheets. Each batch had separated by a sheet
11 of paper to say that this is a batch, and I think that
12 when they had done it the first time, they didn’t separate
13 it and I said, can you separate the two batches and can
14 you recount -- hand count to validate that we have these
15 numbers? And when they had started to fill it out, they
16 were given one that said this was scanner two and they
17 thought it just had one batch when in essence they had
18 two.
19 Q. Okay. How were the -- I guess starting back over
20 at the Government Center, how are the batches numbered?
21 Are they numbered numerically and in sequence?
22 A. Yes, they are numbered numerically and in
23 sequence. That is correct.
24 Q. Okay. And -- and I think I asked you a little
25 while ago if you knew how many total batches there were

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1 from the November 3rd absentee ballot count. Do you -- do

2 you remember what the -- roughly what that count was?
3 A. I did not have -- I did not have an idea of the
4 number of batches, the total batches that we had.
5 Q. So when you are at State Farm Arena with the
6 Dominion scanners, do you scan the batches sequentially?
7 A. We try, but that’s not necessarily the case.
8 It’s when the batches are completed. We might have a
9 person who opens the ballot, processes a little quicker
10 than the person that’s next to them and once that takes
11 place, we might have a person who is going through the
12 ballots and unfolding the ballots and making them
13 presentable to the scanner. They might be quicker, so
14 it’s not scanning them in any kind of order. No, just
15 because I had batch number one doesn’t mean the first
16 batch is going to be scanned. It’s based on the work of
17 the worker --
18 Q. Okay.
19 A. -- or which employee.
20 Q. And are the -- the ballots taken out of the
21 secret envelopes by the machine or by hand?
22 A. By hand.
23 Q. By hand?
24 A. Yes, sir.
25 Q. Okay. And what is done with the -- what happens

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1 to the envelope -- the yellow outer envelope?

2 A. Once --
3 Q. Are those -- are those put back together in trays
4 according to their batch numbers?
5 A. Correct. What happens is that they are grouped
6 together, rubber-banded together within that same batch,
7 and as the person who is processing -- doing the scanning
8 of it, they take the envelopes and that’s when they are
9 officially separated, at the scanner area. They’re taking
10 the envelopes and they are putting the envelopes in one
11 stack and the ballots in another.
12 Q. Okay. So when you arrived at State Farm that
13 night, can you tell me who was operating the scanners at
14 each of those five locations, please, sir?
15 A. Yeah. When I was told to continue working, yes,
16 we had Ms. Ruby, Ms. Wandrea, Ms. Monique, and Ms. -- Ms.
17 Keisha. Keisha Dixon.
18 Q. Keisha Vick?
19 A. Dixon.
20 Q. Oh, Dixon. Are -- so let me -- can you -- do you
21 remember who was -- which person was at which desk,
22 scanner one through five?
23 A. I know Ms. Ruby was at scanner one.
24 Q. Okay.
25 A. I don't know --

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1 Q. And her name --

2 A. I don’t know --
3 Q. And that’s Ruby -- that’s Ruby Freeman?
4 A. Yes, sir.
5 Q. Okay. And so if you watched a clip of the video
6 from that night, could you better identify who was at
7 which desk?
8 A. Sure.
9 MR. CHEELEY: Okay. Can we play --
10 THE VIDEOGRAPHER: Which one?
11 MR. CHEELEY: Any of them. I guess the one where
12 Ruby is featured, around --
13 THE VIDEOGRAPHER: Do you want the -- do you want
14 the player?
15 MR. CHEELEY: -- maybe 10:00 -- 10:00 p.m.
16 THE VIDEOGRAPHER: Player?
17 MR. CHEELEY: The what?
18 THE VIDEOGRAPHER: Do you want the original
19 player?
20 MR. CHEELEY: Yeah, the original. Do you have
21 one that’s separate so we don’t have to look at all --
22 THE VIDEOGRAPHER: Yes.
23 BY MR. CHEELEY:
24 Q. While she’s queuing that up, Mr. Jones --
25 A. Yes, sir.

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1 Q. -- who was it you said told you to keep counting?

2 A. Richard Barron called, my boss, and said could we
3 keep counting, and I told him, sure, you know, if we have
4 work, we’ll keep counting.
5 Q. And what time did he call roughly?
6 A. About 10:15.
7 Q. Did he know -- or did you tell him at that time
8 that there were no poll observers there?
9 A. Yes. I talked to him about the number of people
10 who were around.
11 Q. And does state law require there to be poll
12 observers while votes are being tabulated?
13 A. No. The state law requires that we have to have
14 at least three people present.
15 Q. But it doesn’t say anything about it -- you know,
16 representatives from both parties --
17 A. No, sir.
18 Q. -- have to be present?
19 A. No, sir.
20 Q. Okay. Do y’all -- at Fulton County, did you --
21 in any other elections, did you tabulate votes in your 12-
22 year career without anybody from either party observing?
23 A. Yes, majority of the time.
24 Q. Did -- did you ask anybody, like, Shay Moss, who
25 was in charge that night, if she said anything to cause

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1 the press and the poll watchers to leave before you got
2 there?
3 A. Not at that day. I only asked afterwards when
4 somebody said that somebody made an announcement, and I
5 went to her at that particular time and said, what
6 happened; how did people leave? I said, was there an
7 announcement made? She said, no, sir, you know, I didn’t
8 make an announcement. And I said, was an announcement
9 made? And she said, no. She said that that’s not the way
10 we do things, and I said, that’s right. I understand, but
11 just wanted to make sure because I’ve been told that there
12 was a big announcement made before people left. She said,
13 no, Mr. Jones. That’s not how, you know, we were trained.
14 I said, okay, just making sure.
15 Q. Okay. Did she know that you were on your way
16 over there at 10:00?
17 A. Yeah. I probably -- I probably gave her a call
18 to say, I’m trying to come. She probably wanted me to
19 come a little earlier, to be honest with you, but we were
20 trying our best to make sure that we had enough ballots
21 prepped to be able to come out on tomorrow morning.
22 Q. You mean the morning of November the 4th?
23 A. That is correct.
24 Q. Did you -- did you have any idea as to how long
25 it was going to -- say, by the time you left to go over

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1 there at 10:00 p.m. on November the 3rd, did you have any
2 estimate as to how many more absentee ballots still
3 remained at the Government Center?
4 A. At that time, I did and I don't remember what
5 that number was. But at that time, we had a basis of how
6 many we would need and that’s what I was making sure that
7 -- I knew we weren’t going to get it all done that night.
8 Q. Okay.
9 MR. CHEELEY: You ready?
10 THE VIDEOGRAPHER: Uh-huh.
11 BY MR. CHEELEY:
12 Q. All right. Liz is ready to show that video clip.
13 A. Okay.
14 MR. CHEELEY: And this is from 10:30 p.m., Liz?
15 THE VIDEOGRAPHER: Yes.
16 BY MR. CHEELEY:
17 Q. Okay. Do you see that up there in the upper
18 left-hand corner, Mr. Jones, the time? Mr. Jones?
19 A. Uh-uh. Oh, okay. Yeah, 10:30. Yes, I see it.
20 MR. CHEELEY: Okay. Could you stop it right
21 there, Liz?
22 BY MR. CHEELEY:
23 Q. So tell me who you see there in the picture?
24 A. Yeah.
25 Q. Who is the lady in the purple blouse?

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1 A. That’s Ms. Ruby in the purple.

2 Q. Okay.
3 A. And Ms. Keisha is in the first yellow desk, and
4 Ms. Moss is sitting right behind her, and Ms. Monique is
5 in the back corner.
6 Q. Okay. So just to orient -- make sure I’m
7 understanding which desk is which, the desk over there to
8 the far left where it appears that a man is sitting there,
9 is that desk number one?
10 A. Correct.
11 Q. And they would also have a scanner at number one,
12 right?
13 A. That is correct.
14 Q. Okay. And do you know who that man is sitting
15 there?
16 A. No, sir.
17 Q. Who is the lady seated at the table just --
18 MR. CHEELEY: Just move your cursor over right
19 there.
20 BY MR. CHEELEY:
21 Q. Who is that lady?
22 A. I don't know.
23 Q. Don’t know?
24 A. No, sir.
25 Q. Okay. Who is that man standing there?

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1 A. Don’t know. He’s not a part of my crew. None of

2 them are a part of my crew.
3 Q. Okay. Then, who -- there’s nobody seated at desk
4 number two in that frame, correct?
5 A. Yes, sir. It’s nobody.
6 Q. Then, desk number three -- scanner number three,
7 who is that lady?
8 A. That’s Keisha Dixon.
9 Q. That’s Keisha Dixon?
10 A. Yes, sir.
11 Q. Okay. Was -- and then desk number four, do you
12 know who that is?
13 A. That’s Ms. Moss, Wandrea Moss.
14 Q. Okay. So -- and then, who is that at the last
15 desk, number five?
16 A. That’s Ms. Monique.
17 Q. Ms. Monique?
18 A. Yes, sir.
19 Q. Other than Ms. Moss, were these other four ladies
20 full-time employees or were they part-time?
21 A. Ms. Keisha Dixon is a full-time employee. Ms.
22 Monique is a temporary employee.
23 Q. Had Ms. Monique worked for Fulton County in
24 elections before?
25 A. No, this was her first year working with us.

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1 Well, this is her first year in registration. She did do

2 some work on the elections side.
3 Q. So is this the first time that she helped out
4 with scanning ballots --
5 A. Yes.
6 Q. -- on an election? I’m sorry?
7 A. Yes, sir. This is her first time scanning
8 ballots.
9 Q. Okay. And I think -- didn’t you say that this
10 was the first time for Ms. Moss to be scanning ballots?
11 A. No. Ms. Moss --
12 Q. Or absentee --
13 A. This is her first time being a lead over the
14 process. She has been a scanner for a long time.
15 Q. Okay. And then, how about Ms. Dixon; was this
16 her first time tabulating and scanning?
17 A. No, sir. Ms. Dixon has been scanning for a long
18 time.
19 Q. Okay. And then, who would have been seated at
20 scanner number two?
21 A. We had a young lady from another office who was
22 usually at scanner number two. And also, we had a person
23 from Happy Faces who was also our poll worker, he also
24 scanned in scanner number two, also.
25 Q. And you saw both of those people while you were

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1 there that night after 10:00?

2 A. No, sir. The only four people from our office
3 were Ms. Ruby, Ms. Keisha, Ms. Wandrea, and Ms. Monique.
4 Q. Okay. And you say you don’t recognize either of
5 those other three people, the fellow sitting at desk
6 number one where Ms. Freeman should have -- was operating
7 from, correct?
8 A. No. I don’t -- I don’t recognize him.
9 MR. CHEELEY: Could you zoom in even more, Liz?
10 THE WITNESS: I don’t recognize him. You don’t
11 have to zoom in.
12 BY MR. CHEELEY:
13 Q. Don’t recognize him?
14 A. No, sir.
15 Q. How about the -- the fellow there with the black
16 jacket on?
17 A. I don’t recognize him.
18 Q. Do you have logs as to who was in that room that
19 night? Did they ever have --
20 A. We usually don’t keep a log. The -- our press
21 secretary kept a log of the people who -- the press that
22 might have been there, but we usually don’t keep a log.
23 And usually, our observers are never this close either, so
24 -- they’re usually behind a barrier.
25 MR. CHEELEY: Okay. Can you -- Liz, can you zoom

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1 in to those boxes stacked behind those tables?

2 BY MR. CHEELEY:
3 Q. Do you see those boxes --
4 MR. CHEELEY: No, the black ones sitting behind
5 the man.
6 THE VIDEOGRAPHER: Here?
7 MR. CHEELEY: Yeah. Can you zoom in on those?
8 BY MR. CHEELEY:
9 Q. Are those the -- are those those black boxes --
10 the ballot boxes you were talking about that Fulton County
11 has some that are on wheels and some that are not?
12 A. Yes, sir. I think all of them are on wheels, two
13 wheels at least. You know, I think all of them have two
14 wheels unless it’s defective or something. I think all of
15 them have two wheels.
16 Q. Okay. And those boxes say ballots, correct?
17 A. Correct.
18 Q. Printed on -- printed on the side of the boxes?
19 A. Yes, sir.
20 MR. CHEELEY: Okay. Scan to the left now. Pan
21 to the left, please, Liz.
22 BY MR. CHEELEY:
23 Q. What are all these brown boxes over there?
24 A. They’re the envelopes. They should be the
25 envelopes that we are packing up in order to make way for

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1 the ballots and stuff. Once a person is finished scanning

2 the stuff, there’s a separation of the envelopes versus
3 the ballots.
4 Q. Okay.
5 A. So those would be the envelopes.
6 MR. CHEELEY: Okay. Can you go back to -- can
7 you go back, Liz, to, say, around, I guess, 10:35?
8 THE VIDEOGRAPHER: It’s going to take a second
9 for it to catch up.
10 MR. CHEELEY: Are we caught up now?
11 THE VIDEOGRAPHER: Yes, it’s playing.
12 MR. CHEELEY: Okay.
13 THE VIDEOGRAPHER: You can see the numbers at the
14 top match with the numbers at the bottom.
15 MR. CHEELEY: Okay. So can you do it two times
16 speed so it’s not actual time?
17 BY MR. CHEELEY:
18 Q. So, Mr. Jones, do you see over there at desk
19 number four, is that one of those bins on rollers, or is
20 that something else?
21 MR. CHEELEY: Can you zoom in right there?
22 THE WITNESS: That’s a ballot box, and they have
23 them on top of each other. That’s three separate
24 ballot boxes. One is open at the top and the other
25 two are closed at the bottom. All of them --

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1 BY MR. CHEELEY:
2 Q. Okay.
3 A. -- are still the same.
4 Q. Okay. And who is this lady in the yellow top
5 that just walked into view?
6 A. That’s Monique. That’s Ms. Monique.
7 MR. CHEELEY: Okay. And you can widen it out
8 again, Liz.
9 BY MR. CHEELEY:
10 Q. And so you can see Monique is at scanner number
11 two; is that correct?
12 A. That is correct.
13 Q. Do you remember Monique’s last name?
14 A. I’m trying to think of it.
15 Q. I think you said a little while ago that Monique
16 was at scanner number five?
17 A. She was.
18 Q. So now, she’s at scanner number two?
19 A. Correct.
20 Q. And is that Ms. Dixon at scanner number three?
21 A. That is correct, yes.
22 Q. And where is Ms. Moss?
23 A. She’s --
24 Q. Scanner four?
25 A. -- at scanner four.

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1 Q. Is Ms. Moss the one that has, like, braided long

2 hair, kind of blonde?
3 A. Yes, sir.
4 Q. Okay. I see her over there now. Do you know who
5 that lady is --
6 A. I know that guy now, if that’s --
7 Q. Who?
8 A. Go back -- go back some. I -- I recognize this
9 guy coming through.
10 Q. Okay.
11 A. Keep going back.
12 Q. There he is.
13 A. Yeah. He was one of our workers who we borrowed
14 from Fulton County. He was one of the Fulton County
15 workers. I don't know his name.
16 Q. And what -- what role was he playing there?
17 A. He -- not only did he scan, but he was one of the
18 ones who did the OPEX opening. And I know that he does --
19 he did do some boxing for us, you know, since the -- we
20 tried our best to get the males to do most of the boxing
21 for us because the boxes get a little heavy.
22 Q. Okay. All right. Where are the OKIs in there?
23 A. If you pane to your right, a little bit more to
24 the right, you should see the OKIs if it’s available.
25 Q. Okay.

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1 THE VIDEOGRAPHER: It might be a different

2 camera.
3 MR. CHEELEY: I don’t need to see them. Go back,
4 if you would, to 9:45.
5 THE WITNESS: I think that the -- the covering on
6 this one at the bottom center, that green-grayish-
7 looking cover, that’s an OKI. That should be an OKI
8 right there.
9 BY MR. CHEELEY:
10 Q. Okay. All right. That’s helpful. Thank you.
11 A. Uh-huh.
12 MR. CHEELEY: Go back to 9:45 p.m.
13 BY MR. CHEELEY:
14 Q. Okay. Do you --
15 MR. CHEELEY: Just let it play.
16 BY MR. CHEELEY:
17 Q. Do you recognize who the people are sitting there
18 at the table with his legs crossed?
19 A. No.
20 Q. Okay. So this is --
21 MR. CHEELEY: Are you running this at -- what?
22 THE VIDEOGRAPHER: Two times.
23 MR. CHEELEY: Two times?
24 THE VIDEOGRAPHER: Yes, sir.
25 MR. CHEELEY: Go ahead and run it now at four

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1 times.
2 THE WITNESS: I believe that their job would have
3 been, though, is -- is sorting the ballots when they--
4 BY MR. CHEELEY:
5 Q. Okay.
6 A. -- bring it from the OKI.
7 Q. So by 9:45, the -- that’s when the -- your press
8 secretary and the media would have been out of there. You
9 don’t see them in there anywhere, do you?
10 A. I think they were still there.
11 Q. All right. Now, the cover is off of the OKI; is
12 that correct?
13 A. Yes, sir.
14 Q. And this is at 9:47, 9:48?
15 A. Uh-huh.
16 Q. p.m. So the OKI -- tell us again what the OKI is
17 doing right there.
18 A. He looks like he’s opening the inner envelope
19 ballot of the -- of the ballots.
20 Q. And what color are those envelopes?
21 A. White.
22 Q. So what does that mean? Is that the Secretary of
23 State’s envelope, the secret?
24 A. Correct. If it wasn’t a secret envelope -- if it
25 wasn’t an inner envelope, he would have gone ahead and

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1 processed the -- the order by just -- not just opening it

2 only, but he wouldn’t have had to have cut the inner
3 envelope because there was no inner envelope to cut if it
4 was a Runbeck one. If it was one of ours, he would have
5 had to open the inner envelope, the secrecy envelope.
6 Q. Okay. And did that look like that -- that those
7 were inner envelopes from Fulton County?
8 A. It did. It did.
9 Q. So --
10 MR. CHEELEY: Pause it right there, Liz. Do you
11 -- can you pan out a little bit, Liz, to capture the
12 Runbeck machine?
13 BY MR. CHEELEY:
14 Q. So kind of tell -- can you tell --
15 A. You can -- you can usually tell the difference,
16 it’s because they’ll have two different stacks. They’ll
17 have one stack of a yellow envelope and then one stack of
18 a white envelope if it’s ours. Okay? If it’s Runbeck,
19 they probably had a yellow envelope and when they got the
20 secrecy one, they just pulled it out and stuck it to the
21 side, just a sheet of paper.
22 Q. Right. Okay. And they would have manually
23 pulled it out, correct?
24 A. Correct.
25 Q. If it was Runbeck --

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1 A. But if it’s -- if it’s a Runbeck one, the people

2 to your left would have been the ones physically actually
3 separating the two.
4 Q. The people sitting there at that table?
5 A. Yeah. Those people to your left at the table and
6 stuff will separate the two --
7 Q. So --
8 A. -- and to put them in some sort of form that the
9 scanners could use.
10 Q. Okay.
11 A. Those folks that -- right there. Uh-huh. You
12 see how they -- they rolled up the ballots -- the
13 envelopes on the right-hand side, the ballots were on the
14 bottom?
15 Q. Okay. Are you talking about in that bin on the
16 table?
17 A. Right. The mail tray on the table. That’s a
18 batch.
19 Q. Okay. Is that -- that’s a different type of mail
20 tray than the trays that the envelopes with ballots in
21 them are put in initially over at the Government Center,
22 right?
23 A. Same tray.
24 Q. Oh, it’s the same tray?
25 A. Yes, sir.

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1 MR. CHEELEY: Okay. All right. So keep playing.

2 Go back to -- scan it back out -- or pan it back out,
3 please, Liz.
4 BY MR. CHEELEY:
5 Q. So it’s 9:53 p.m., just a few minutes before you
6 arrive, correct?
7 A. Correct.
8 Q. What were you wearing that night; do you
9 remember?
10 A. Red. I know that much.
11 Q. Red?
12 A. Yes, sir. I wear red every Election Day.
13 Q. What’s the reason for that?
14 A. You know, I’m a Tiger Woods fan and on Fridays,
15 Tiger -- or I should say that that last day of whatever
16 golf tournament he plays, he wears red.
17 Q. Oh, okay. So we’re at 9:56.
18 A. See the two people who were up in the front.
19 Those are timesheets up there, so they’re -- they’re
20 probably trying to clock out so they can go home.
21 Q. Okay. Where are those people that you’re
22 referring to?
23 A. The one --
24 Q. Do you see them in --
25 A. The one lady -- the one lady and there’s an empty

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1 seat next to the one lady, but there are two sheets of
2 paper on that desk, right there.
3 Q. Okay. So this is at 9:56:46 p.m., correct?
4 A. Uh-huh.
5 Q. All right. Okay. 9:56:46 p.m. Okay. You’ve
6 got one lady sitting there at the desk -- at the table
7 where the two people, if it was Runbeck, they would be
8 pulling the ballot out of the envelope because there’s no
9 inner envelope -- secret envelope, correct?
10 A. Correct.
11 MR. CHEELEY: Okay. Let it play. Pan out and
12 let it play at two -- two minutes.
13 BY MR. CHEELEY:
14 Q. So we’re now at 9:57. Was there -- how did
15 people clock out? Did they clock out with a machine or
16 just write it down?
17 A. Paper. By paper.
18 Q. What’s Ms. Ruby doing right there?
19 A. She’s cleaning up the bins and starting to stack
20 them up at the time.
21 MR. CHEELEY: Okay. All right. Keep playing.
22 BY MR. CHEELEY:
23 Q. We’re at 9:58. They’re covering out the OPEX
24 machine; is that what it’s called?
25 A. That’s right.

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1 Q. Let me ask you a question of the black

2 tablecloths in there. Are those allowed by the Georgia
3 law or by the Secretary of State?
4 A. There is no -- there is no jurisdiction on that
5 one right there. The black tablecloths were given to us
6 by State Farm. You know, I guess that they wanted to make
7 sure it looks pretty in there.
8 Q. I see. All right. So it’s 10:04. I don’t see a
9 red pant -- man in a red shirt yet.
10 A. Not yet.
11 Q. What’s the gentleman writing on right there on
12 that black table and putting something on the -- on those
13 ballot boxes?
14 A. He’s identifying the boxes to say that -- what’s
15 the contents probably inside the box, saying that these
16 right -- these right here would need to be scanned. They
17 are ready for scanning.
18 Q. So when you went to State Farm, you got on the
19 elevator, and did you make any other stops before you got
20 to the sixth floor?
21 A. Oh, no, I -- I didn’t.
22 Q. Okay. 10:13, I still don’t see you arrive yet.
23 A. Yeah, I wasn’t around because too many folks were
24 in the room by now.
25 Q. What do you mean by that?

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1 A. I -- when I got there, it was just four people in

2 the room.
3 Q. Who were those four?
4 A. Ms. Ruby, Ms. Wandrea, Ms. Keisha, and Ms.
5 Monique.
6 Q. Ms. -- so you -- this gentleman here writing
7 something on that table, the Runbeck table, we’ll call it,
8 do you know what he would be doing there? Is he getting
9 ready to leave?
10 A. Don’t know. Let’s see what he does with it.
11 Does he leave it on the table or does he put it somewhere?
12 Q. So did -- do you think you arrived around 10:00,
13 or do you think you arrived around 11:00?
14 A. Well, I know it wasn’t 11:00.
15 MR. CHEELEY: What -- what speed --
16 THE WITNESS: I know it wasn’t 11:00 because at
17 11:00, I had to be on the --
18 MR. CHEELEY: You’re running at 8x?
19 THE VIDEOGRAPHER: 8x.
20 BY MR. CHEELEY:
21 Q. Do you see anything about this video that looks
22 like it’s been altered to you?
23 A. Nope.
24 Q. Did you talk to anybody at State Farm about this
25 video?

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1 A. No.
2 Q. Have you talked to anybody about the way in which
3 State Farm maintains the hard drives for these videos?
4 A. No, sir.
5 Q. All right. So now, we’re up to 10:30 and we
6 still don’t see you. Who is that fellow; do you know? Is
7 that the same guy in the leather coat?
8 A. Yeah, that’s the same guy. And I still don’t see
9 me.
10 Q. So it looks like you may not have gotten there at
11 10:00 after all, right?
12 A. Well, it doesn’t look like it from this video,
13 does it?
14 Q. While we’re watching that, I’m going to go ahead
15 and ask you some of my questions.
16 A. Okay.
17 MR. CHEELEY: Liz, when you see him show up in a
18 red shirt, would you pause it, please?
19 THE VIDEOGRAPHER: Okay.
20 BY MR. CHEELEY:
21 Q. What are the processes and procedures and
22 controls that -- that you and the elections group use to
23 ensure that the -- that batches are counted properly?
24 A. We keep a documentation of each batch from the
25 start of the batch to the end of the batch. Each section

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1 is done by batches.
2 Q. Okay. And do you see the lady there at scanner
3 number two?
4 A. Yes.
5 Q. Is she scanning in the ballots right now?
6 A. Yes. Her ballot -- her scanner was finished.
7 Q. So is that showing the -- the paper is put in on
8 the bottom and it comes out on top of the scanner?
9 A. Yes, sir.
10 Q. Okay. And after it scans a batch of
11 approximately 100, does she have to do anything to
12 register that -- those votes?
13 A. Yeah. Once it gets through scanning, she can
14 save -- she can save that as a batch.
15 Q. Okay. So the machine doesn’t save it
16 automatically?
17 A. She has to tell it that that’s an acceptable
18 batch.
19 Q. Okay. So how does she save it?
20 A. I think it’s a mechanism on the screen that says
21 that I scanned 100; do you want to keep it or -- it’s that
22 nature. Then she would hit yes and then she’ll start it
23 over with the new batch.
24 Q. Okay. And is this Monique that we’re looking at
25 there in the yellow?

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1 A. That's correct. That’s Ms. Monique.

2 Q. Okay. And she’s at scanner number two, correct?
3 A. Yes, sir.
4 MR. CHEELEY: Okay. Now, hold on just a second,
5 Liz. Would you play it at normal speed when you start
6 back?
7 BY MR. CHEELEY:
8 Q. So this is at 10:50 p.m., correct?
9 A. That is correct.
10 MR. CHEELEY: This is taking a while to catch
11 back up.
12 THE VIDEOGRAPHER: It -- it does. It takes ten
13 seconds or so for it to catch up.
14 MR. CHEELEY: We’re waiting on the bottom --
15 THE VIDEOGRAPHER: There we go.
16 MR. CHEELEY: -- counter to line up with the top
17 counter, correct?
18 THE VIDEOGRAPHER: Yes. It’s playing now.
19 BY MR. CHEELEY:
20 Q. Is that you there?
21 A. That’s me.
22 Q. Okay. So that’s around 10:50 or 10:51, correct?
23 A. Yes, sir.
24 Q. Past your bedtime?
25 A. Much -- much so.

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1 Q. All right. So there you are. You’ve got on a

2 dark suit and a red shirt, right?
3 A. Yes, sir.
4 Q. Okay. So when is that -- when you first arrived
5 at 10:50 or 10:51, what is it that you were talking to
6 these ladies about?
7 A. How much we have left to do. I’m trying to --
8 trying to see exactly what’s needed to be done so we can
9 try our best to start the process of cleaning up so we can
10 get on out of there.
11 Q. All right. So what were -- what are you doing
12 right there when you -- at 10:52? You put --
13 A. I’m taking the ballots that have already been
14 scanned and boxing it up, so that when they return
15 tomorrow, the retention team can get a hold of those
16 ballots.
17 Q. Okay.
18 A. See, I’m asking Ms. Monique, now, what are these?
19 She’s telling me that these ones have to be scanned.
20 Q. Okay.
21 A. And we’re trying to clean up.
22 Q. Okay. So the ones that you’re putting in that
23 bin and putting the lid on it, those have already been
24 scanned?
25 A. No, those have to be scanned, it looks like. Let

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1 me check.
2 Q. At 10:53 p.m., you put a lid on that, correct?
3 A. Yes, sir. Let me see where Ms. Monique puts her
4 finished product.
5 Q. She just --
6 A. Oh, the ones on the table are the ones have to be
7 scanned. I got it. The ones on the table are the ones
8 that have to be scanned. So once he gets through doing
9 that one and filling that one up, he’s going to push this
10 on under the -- and the ones that are on the desk are the
11 ones that have finished scanning and they need to go to
12 retention.
13 Q. Okay. So Ms. Monique just took those off the
14 scanner and it looked like she put them back on the
15 scanner, the same batch? And that’s the screen in
16 between. Did you see that?
17 A. Yes, sir. If --
18 Q. So is that --
19 A. If a batch does not scan fully all the way, we
20 have to rescan it again.
21 Q. Okay. So I’m -- I’m just kind of asking you
22 right now to keep your eyes on the -- on her scanner, Ms.
23 Monique’s --
24 A. All right.
25 Q. -- scanner, scanner number two.

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1 A. All right. We can do that.

2 Q. Does that appear --
3 MR. CHEELEY: Can you zoom in a little bit on
4 that, Liz?
5 BY MR. CHEELEY:
6 Q. From the looks of that, does that look like a
7 batch?
8 A. Yes. It -- it could be a batch. If you look at
9 the envelopes that’s in the tray over here, it’s not a
10 full representation of the -- of a batch of 100, if you
11 look at that tray right in front.
12 Q. Okay. So what’s Ms. Monique doing now?
13 A. She’s trying to sort it so that she can get it in
14 so it can be a batch. She’s -- she’s --
15 Q. It looks like -- correct me if I’m wrong, but it
16 looks like she’s -- correct me if I’m wrong --
17 A. Go ahead.
18 Q. Correct me if I’m wrong --
19 MR. CHEELEY: Let’s back it up to where she first
20 puts these on there, please. Right around 10:53.
21 Okay. All right. Start back at 10:50 -- is that at
22 10:53, approximately, Liz?
23 THE VIDEOGRAPHER: Yes, it’s going to take a
24 second for it to catch up.
25 BY MR. CHEELEY:

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1 Q. Okay. So, Mr. Jones, she -- Monique just put

2 some yellow and white envelopes in there; is that right?
3 A. Yes, sir. What she’s doing now is actually
4 putting our log in of what is -- she’s doing. She’s
5 taking the log and adding in of what was (unintelligible).
6 Q. Okay. And what --
7 A. The way it works -- the way it works is that
8 every time the scanner is finished scanning, it creates a
9 new batch number. We don’t have control over the batch
10 numbers. So we -- we keep a log -- a scanning log of the
11 ones that have been completed.
12 Q. Okay. So she took -- took the stack off the top?
13 A. Yes.
14 Q. That’s the stack -- those are the ones that have
15 gone through the scanner, correct?
16 A. Right. But if -- if the batch did not scan
17 completely, we do not accept the batch because we want the
18 batch to be 100, okay?
19 Q. What if -- okay. What if some of the batches
20 would be way in excess of 100? What would that indicate?
21 A. That we probably combined batches in our -- there
22 was a miscount in the batch number -- I mean, a miscount
23 of the ones given to the batch.
24 Q. What -- that log that she was writing on --
25 A. Yes, sir.

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1 Q. -- is that similar to the exhibit that I showed

2 you from the audit board batch sheet?
3 A. No, sir. It’s its own separate log.
4 Q. And what information is on that log that she
5 wrote on?
6 A. A batch number, how many did it scan, and -- and
7 were there any ones that had to go to duplication because
8 it couldn’t go through. If we have -- if we have a ballot
9 that -- if we have a ballot that could not physically go
10 through, we pull it out for duplication purposes.
11 Q. Okay. So just so I’m clear, the log that each of
12 the five ladies scanning at the scanners were using for
13 these absentee ballot scans, those logs will -- she’ll
14 record the batch number, correct?
15 A. Correct.
16 Q. And what -- how many ballots were tabulated?
17 A. Yeah, how many were scanned by batch.
18 Q. Any -- any other information? Does she have to
19 write her name on there?
20 A. Yes. She -- she puts her initials. I think it’s
21 initial-based because from scanner to scanner, somebody
22 can go from scanner to scanner.
23 Q. Okay. Any other information on the log that is
24 used during the scanning process?
25 A. Whether it’s been duplicated or it needs to go to

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1 vote review. Some of them are -- some of the ballots may

2 be torn. Some of them may be -- maybe can’t go through
3 the scanner.
4 Q. So she just put the -- those ballots in the bin.
5 Was that in the same bin with the envelopes associated
6 with those ballots?
7 A. At that particular time, they probably put
8 everything in the -- in the one bin and we will reconcile
9 the next day. Right now we were just trying -- our major
10 concern right now is to secure the ballots.
11 Q. So did -- she’s taking them now back out, right?
12 A. That was the one -- remember, I said that that
13 particular bin had not been scanned, so we are -- we’re
14 taking them out, trying our best to see which ones we’re
15 going to finish before we leave and which ones we’re going
16 to stack up as being completed.
17 Q. What -- under what kind of circumstances or
18 scenario would lead to a situation where as many as 100 or
19 more batch numbers might be missing or --
20 A. I don't know. Unless there is a -- I don't know
21 of a situation that would have 100 batches that are
22 actually missing.
23 Q. Would that be best practices if that was the case
24 that --
25 A. Yeah. We try -- we try to maintain order to the

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1 batches, you know.

2 Q. I understand. But would that be best practices
3 if there were more than 100 batch numbers and batches
4 missing?
5 A. Yeah. That would be very, very concerning. We
6 would have to know why it was 100 batches missing.
7 Q. Would it also be very concerning to you if -- if
8 batches were counted multiple times?
9 A. Sure.
10 Q. Would that be best practices to count the same
11 ballots and batches multiple times?
12 A. Yes, sir. Yes, sir. That -- that would -- best
13 practice -- that would be --
14 Q. No. I mean, you say it is best practice to count
15 batches multiple times or not?
16 A. No. No, no, no, no. No, no, no. It is not.
17 Q. Okay. So it’s 11:00 now in the video, and you’re
18 walking to scanner number one --
19 MS. RINGER: We’re at an hour -- we’re at our
20 seven hours. We’re going to need to wrap this up.
21 MR. CHEELEY: What’s that?
22 MS. RINGER: We’re at our seven hours. We’re
23 going to need to wrap this up.
24 MR. CHEELEY: Are we? What time did we start
25 back?

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Ralph Jones on 05/17/2021 Page 207

1 MS. RINGER: 5:20.

2 MR. CHEELEY: 5:00 what?
3 MS. RINGER: Twenty.
4 THE VIDEOGRAPHER: Yeah, it’s 22 now.
5 MR. CHEELEY: Okay.
6 BY MR. CHEELEY:
7 Q. Okay. One last question. After this whole
8 scanning process is wrapped up for this night, November
9 3rd, that went on into the early part of November 4th, do
10 your -- do your scanning personnel do anything to prepare
11 the scanned number of ballot totals to their logs that
12 they hand-write on?
13 A. I -- I didn’t really understand the question.
14 Can you repeat it again?
15 Q. Yes, sir. When y’all wrapped up just before 1:00
16 a.m. on November the 4th with scanning of these absentee
17 ballots, did your ladies -- were they instructed or
18 trained to check the number of ballots scanned against the
19 number of scanned images shown on the screens or the
20 Dominion system?
21 A. Yes. When they -- they do it by batch at the
22 time of the batch. They don’t do it after the fact. They
23 do it while they’re actually operating to validate that
24 the time -- the number that’s on that hand sheet should
25 match the number that is on the screen.

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1 Q. Okay.
2 A. Total.
3 Q. So do you -- do you record that at the end of the
4 day as an electronic --
5 A. Not -- just total. It’s just a total. Whatever
6 -- whatever it is, the next person who would come in the
7 same day will take that same sheet and start to working --
8 MR. CHEELEY: Okay. Okay. Well, Mr. Jones,
9 you’ve been very patient with me. I appreciate you --
10 THE WITNESS: Oh, no problem.
11 MR. CHEELEY: -- walking this old country lawyer
12 through a difficult process. All right. Thank you.
13 (DEPOSITION CONCLUDED AT APPROXIMATELY 6:25 PM)
14
15
16
17
18
19
20
21
22
23
24
25

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1 E R R A T A S H E E T
2 I have read the within and foregoing 208 pages and no
3 changes are required.
4 This, the __________ day of ________ 2021.
5 ________________________________
6 Ralph Jones
7
8 I have read the within and foregoing 208 pages and the
9 following changes are required:
10 Page ______ Line ________: Reason:_______________________
11 _________________________________________________________
12 Page ______ Line ________: Reason:_______________________
13 _________________________________________________________
14 Page ______ Line ________: Reason:_______________________
15 _________________________________________________________
16
17 This the __________ day of ________ 2021.
18 _________________________________
19 Ralph Jones
20
21 Sworn to and subscribed before me,
22 This the _________ day of ________ 2021.
23
24 ____________________________________
25 Notary Public, Georgia

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1 C E R T I F I C A T E
2
3 STATE OF GEORGIA
4 COBB COUNTY
5
6 I hereby certify that the foregoing transcript of
7 RALPH JONES was taken down as stated in the caption, and
8 the questions and answers thereto were reduced to
9 typewriting; that the foregoing 208 pages represent a true
10 and correct transcript of the evidence given upon said
11 deposition. I further certify that I am not of kin or
12 counsel to the parties in the case, am not in the regular
13 employ of counsel for any of said parties, nor am I in any
14 way interested in the result of said case.
15
16 This, the 20th day of May 2021.
17
18
19 Tiffany L. Jones, CCR, CVR
20 Certified Court Reporter #2863
21 Certified Verbatim Reporter #4027
22
23
24
25

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Ralph Jones on 05/17/2021 Page 211

1 D I S C L O S U R E
2 STATE OF GEORGIA
3 COUNTY OF COBB
4 Pursuant to Article 10.B of the Rules and Regulations
5 of the Board of Court Reporting of the Judicial Council of
6 Georgia, I make the following disclosure:
7 I am a Certified Court Reporter and an independent
8 contractor. I am not disqualified for interest, personal
9 or financial, under O.C.G.A. 9-11-28(c).
10 T. Jones & Associates, LLC was contacted by Huseby,
11 Inc. to provide court reporting services for this
12 deposition.
13 T. Jones & Associates, LLC will not be taking this
14 deposition under any contract that is prohibited by the
15 O.C.G.A 15-14-37(a) and (b).
16 T. Jones & Associates, LLC has no exclusive
17 contract/agreement to provide court reporting services
18 with any party to the case, any counsel in the case or any
19 reporter or reporting agency from whom a referral might
20 have been made to cover this deposition.
21 T. Jones & Associates, LLC will charge its usual and
22 customary rates to all parties in the case and a financial
23 discount will not be given to any party to this
24 litigation.
25 Tiffany L. Jones, CCR #2863, CVR #4027 Date: 05/20/2021

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Page 414
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: $1..20,000
205:18,21 108:12 13:21
$ 206:3,6 109:1 15 43:18
106,000 110:4 142:2
$1 74:4
109:2 11:00 15-minute
0 110:4,12 196:13,14, 43:17
10:00 161:24 16,17
01A- 60:6 206:17 1500 101:16
166:11
168:6 11:04 43:17, 16th 58:18
1 169:4,7 18,21,22 19 34:15
177:15 11:22 43:23 36:3
1 141:22 179:16
160:21,24 44:1 19-inch 34:5
180:1
172:8 184:1 12 6:5 98:9 19th 58:23
1,000 88:9, 196:12 131:22 59:1,12,21
13,14 197:11 135:9,15
1:00 207:15
109:15,16, 10:04 195:8 12- 178:21
1:15 77:4
17
10:13 195:22 12:04 75:3
1:20 77:4,
10 101:6
10:15 178:6 12:15 44:3 5,7,8
10,000
10:30 12:30 44:3 1:41 77:13,
109:11,12,
180:14,19 77:6 16
13,14,16,
18 197:5 12:31 75:4,6
2
100 28:16, 10:35 186:7 12:32 75:7
17 85:14 10:50 199:8, 12:34 77:6, 2 128:24
112:17 22 200:5 11,12 172:6,14,
113:17 202:21 23
12th 51:25
135:4,11,
10:51 199:22 52:1,3 2,000 101:11
18,23
200:5 20 11:11
136:2,13, 130 91:18,
15 146:18 10:52 200:12 19,24 142:9
166:6 10:53 201:2 143:2
141 21:17
173:18,19, 202:20,22 152:25
91:7,21
21,23 153:6
11 32:17,18 97:15,18
198:11,21 156:21
96:25 144 91:9
202:10 20,000 55:21
203:18,20 113,000 147,000

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CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: 200..40th
200 81:24 230,000 133:23 105:21
2009 6:6 82:3,6 149:1,19 106:3
131:25 100:24 151:14 115:19
101:6 154:5,8, 123:14
2012 132:1, 17,22 133:2
230-something
7 155:6 139:15
81:25
202 124:2 156:7 145:3
23rd 55:16 171:8 151:21
2020 11:9, 58:21,22
30-some 153:2,3,5,
22 12:11 88:10
148:17 10,24,25
24:20 30:6 89:3,7 154:21
39:4,19 300 128:24
24-hour 156:23
40:8 62:15
150:4 30s 148:15 158:4
76:9 83:7
160:2,11
94:19 270 128:24 30th 45:21
161:22,24
98:5,6 28th 38:3 88:11
163:16,19
103:7,8 89:4,5,8
29th 38:3 164:3,16
104:22 320 50:5
46:4 166:11
106:14
35 75:9 167:1,13
113:23 2nd 127:8
170:22
123:5 134:12 350 136:17
175:1
131:18,19 152:19 142:24
180:1
2021 43:9 153:1,3,4, 350-something 207:9
94:5 96:25 22 154:21 57:18
156:19
21 34:16 157:17,21 355 50:13 4
36:3 158:1,16 364 173:9, 40 133:23
21-inch 34:5 11,14,17 154:5,9,
22 6:20,22 3 365 173:12, 17,22
207:4 15,17 155:6
3 11:9 76:9
22nd 46:5, 156:7
83:7 94:19 3:45 139:5
9,15 171:8
98:5,6 3rd 11:11
51:22,23 104:21 40- 151:17
17:10
58:21 86:4 106:14 126:22,
45:22 400
23,000 113:23 92:2,8,10, 23 136:17
101:7,8,10 123:5 14 95:1 142:24
230 82:4 30 128:25 98:23 40th 151:22

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CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: 45..absentee
45 12:12 207:2 8x 196:18, 207:16
13:3 17:9 5:17 171:25 19 abide 18:3
51:14
75:9,10 5:20 172:1, ability
9
134:9 4 207:1 41:5,6
5:45 163:20 90 134:16 46:17
45-day 17:14 123:25
152:19
450 126:21 5th 105:23 137:19
95 81:20
45th 51:16 170:17
6 97 146:19
55:8,11, abnormal
12,13 604 168:25 98 146:19 93:3
4:13 139:6 169:2 99 80:11, abnormally
6:00 13,22,24 93:3
4:14 139:9
163:20,21 136:6
absentee
4th 105:22
6:25 208:13 9:30 5:4 8:17,19
153:10
154:21 9:45 189:4, 9:8,11,19
6:30 165:11 12:1,5,9,
179:22 12 190:7
207:9,16 10,19
7 9:47 190:14 13:2,16
9:48 190:14 14:6,13
5 729 161:18
9:53 5:4 15:6,10
7:00 16:3,9,14
5 81:21 193:5
153:13,14, 17:1,25
5,000 104:25 15 165:11 9:56 193:17 18:6,11,23
50,000 105:1 168:3 9:56:46 19:7 21:11
500 47:18 194:3,5 25:18
48:5 8
9:57 194:14 31:5,12,13
32:4 35:11
500- 47:15 800 159:19 9:58 194:23 38:11 41:9
50th 55:12 800- 47:16 45:25 56:5
A 57:5,21
5150 161:18 80s 7:6
58:7 59:7,
5160 161:18 85 130:25 a.m. 5:4 20 61:8
131:6,12 43:21 44:1 63:5,6,7
5162 161:18
133:20 161:25 64:19
5164 161:18 162:14
8:00 65:21
5:00 162:14 163:22,23 66:25
165:13,17
168:3

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CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: absentees..administration
67:2,11 absentees add 40:21 104:13,15,
72:2 76:9, 46:20 109:18 21 105:10,
10 77:24 accept 124:1 11 106:11
78:15,22 203:17 adding 203:5 107:4
79:15,19 108:12,16
80:3,13, acceptable addition 109:2,12,
23,24 198:17 17:18 14,15,17
81:10,23 accepted 131:3 110:4
82:3 83:4, 107:21 additional 111:7,15
5 87:1 17:3,5,25 112:15,17,
access 14:12
89:9,19 22:16,18 18
129:17,21,
92:2,9 adjudicating
23,25 address
94:21,23 107:12
130:3 10:17
99:24,25
140:4 21:22 adjudication
100:4,8,
accumulation 22:4,5,10, 102:7
16,24
12:15 20 23:13, 103:6
103:9,22
14,18,23 104:3,4,16
104:20 accurately 24:3 105:14,20
106:1 7:22 26:14,15, 106:3,5,23
107:7
acknowledged 18,20 107:1,10,
108:12
46:21 27:3,6 25 109:8,9
112:19
28:21 110:11,12,
113:23 acting 79:25
91:16,17, 14,21,23
114:2,21 action 54:4 19 135:15 111:10,16,
116:7
actual 14:15 146:24 18
120:1
124:4 15:13 addressed adjudications
132:15 33:24 56:4 23:19 105:24
134:8,13 58:13
adequate 106:14,19,
143:2 60:15,22
48:11 21 107:5,
151:25 64:25
19 108:4
65:25 adjudicate
170:20,22, 111:3
91:14,17 104:2
23 175:1
99:6 107:22 adjudicators
180:2
100:21 108:2 107:6
183:12
186:16 109:15,17 administration
204:13
207:16 adapted adjudicated 91:14
155:20 103:6,14 122:24

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Page 418
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: advance..Arena
advance allowed appearance approximate
151:20 48:18 21:3 25:9 25:2 26:1
affidavit 129:17 30:24 67:16
96:11,15, 195:2 32:12 76:18
19,23 altered appears approximately
97:11 196:22 151:12 13:8 17:8
affirm 5:7 Amero 111:25 181:8 88:5 89:22
application 135:18
affixed amount 88:14 139:18
87:13 93:5 12:17 14:9
17:22 141:24
afternoon 128:19 198:11
120:12,18
44:14 ampersand 152:5 202:22
49:10 208:13
agency 130:6 applications
analysis 9:22 12:20 area 8:22
agree 102:23
120:6 14:18 9:8 23:20
111:18
15:17 40:11,14
131:9,11 analyst 7:1,
84:20 62:9
agreed 58:19 11
119:20,23, 124:12
105:17 Annex 80:19 129:5
24 120:9
111:2 announcement 176:9
121:1
agreement 179:4,7,8, 152:7 Arena 113:24
149:24 12 114:5,14
applied
agreements answering 24:24 128:1
17:18 131:3 27:19 129:20
28:13 58:3 130:15
ahead 64:14 answers
74:1 137:7
82:11 85:4 162:22
83:24,25 139:14,25
115:10,11 anymore
84:2 140:7,17
137:24 124:2
87:17,20 143:4,9
189:25 127:23 146:9
190:25 applies 69:1
apiece 147:4,11,
197:14 104:16
173:19 24 152:20
202:17
apply 66:23 154:1
air 54:25 apologize
103:7,8,9 160:6
115:11 161:21
alike 173:5 approved
apparent 163:19,24
allege 98:3 128:14,25
156:20 164:20

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Page 419
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: aren't..back
165:2 134:8 attorney’s 119:15
166:11 169:7 97:9,13,14 120:5
167:2,9 articulate audible aware 35:20
168:5,22 45:1 154:13 98:2 99:2
169:16 111:24
175:5 as-is 105:16 audio 74:23
112:2,5
aren’t assign 8:24 audit 95:4,
103:21 assigned 5,7,8,11,
B
169:23 52:4 54:7 13,16,19,
58:14 22,23,25 back 10:21,
Arizona
62:23 96:2,6,7, 22 23:4
11:18 8,10,13 26:15,16
18:16,21 assignment 98:5,7,8, 27:1,4,15,
47:3 52:22 170:19 17,21 19 28:24
arrive assist 133:1 99:7,23 29:10,18
78:16,22, 143:21 32:10
assistants
23 79:2,19 144:1 34:25
132:25
124:4 145:1,11 38:24
125:2 associates 160:22 39:1,2,5,
130:21 72:8 161:2 23 40:7
162:12 assuming 174:3 43:18,24
193:6 12:12 204:2 51:7 53:3,
195:22 18:2,4 auditors 5 57:8
arrived 42:19,24 98:8,12, 63:17,22
79:15 assumption 16,25 65:22
80:14 18:18 99:12,23 66:1,11,
81:11 100:2 13,16
Atlanta 68:23
161:23 audits 95:2
25:22 73:18 75:5
168:5
40:10,14, authors 77:14
176:12
16 60:10 99:17 84:4,20
196:12,13
135:7,8, 85:15,21
200:4 automatically
10,15,23 87:21
arrives 86:4 74:1
attached 198:16 99:22
87:17
29:8 83:17 106:24
103:24 automobiles
118:14
134:12 Attorney 63:1 124:3
171:14
arriving average 131:22

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Page 420
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: background..ballots
132:7 31:12,13, 84:21 17,20,21,
139:7 17,19 86:2,3,9, 23 143:3
142:18,20, 32:1,4,9 11,23 145:20,21,
22 143:3 33:1,7,13, 87:16 22,24
149:8 16,25 100:4 146:21
156:3,17 34:3,4,5,7 101:13,25 147:23
159:1,2 35:11 102:8,9, 150:15
165:14,15 36:5,12 10,15,21, 152:25
172:2 41:6,10, 25 103:16, 153:13,14,
174:19 19,20 43:1 17,19,22 15,21
176:3 48:6,14, 104:4,10, 156:18
181:5 16,17,18, 11,14 158:2,9,18
186:6,7 20,21,23, 105:9,11, 159:14,24
188:8,11 24 49:3,5, 12,13,14 160:4
189:3,12 19,21 107:4 170:20
193:2 50:1,4,5,6 109:19 171:6,13
199:6,11 57:15 110:16,18, 175:1,9
201:14 58:1,11, 22 111:6, 185:10
202:19,21 13,15 14,16,19, 186:22,24
205:11 59:7,20 22 112:4, 190:19
206:25 60:17,21 9,15 194:8
background 61:10,12, 117:15,16, 195:13
6:7 140:3, 13,19,20, 18 118:3, 198:6
9,12 23,25 5,6,11 204:8,9,13
62:5,6,7, 119:1,25 207:11
backing 56:4 8,12,13 120:1 balloting
bad 35:3 63:9,10, 125:21 11:12
116:18 13,15,17, 126:12,14,
22,23 24 128:13 ballots
ball 68:20 9:16,17,22
64:3,5,8, 134:3,5
ballot 10:6, 23,25 135:2,4 10:5,14
7,8,10,11, 65:21,23, 137:1,12, 11:6,10,
12,22 24,25 19,23 13,15
11:2,3,4 66:1,3,17, 140:17 12:3,6,10
12:1,17 25 67:3,12 141:9,11, 13:2,16
13:2 14:4, 68:13,18 16,25 15:10
5,10,13 69:2 79:15 142:1,5,7, 16:14
27:4 81:11 11,13,16, 17:1,4,13,

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Page 421
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: ballpark..barcodes
15,25 65:8,16 109:13,18 15,17
18:6,8,11, 68:23 71:1 110:14,15 175:12,20
20,23 19:7 72:2 76:2, 111:3 176:11
21:11 13,19 112:20 179:20
25:18 31:5 77:24 114:2,21, 180:2
33:19,20, 78:16,18, 22 115:21, 183:4,8,10
23 35:22 22 79:19 22 116:7, 185:16
36:1,16, 80:3,13, 18,19 186:1,3
21,22,25 23,24 124:4,9 190:3,19
37:3,17 81:23 82:3 125:2,4,24 192:12,13,
40:25 83:4,5,15, 126:2,17, 20 198:5
41:3,7,8, 21 85:1,7, 19,21 200:13,16
9,23 42:18 13,24 127:1,10, 204:16
45:5,7,13, 86:15 87:1 12,25 205:1,4,6,
15,18,25 88:6,14 128:4,12, 10 206:11
46:15,20 89:19 90:6 24 129:23, 207:17,18
47:6,10 91:5,12 25 130:3, ballpark
48:11 92:2,9,14, 13,21 88:7
51:18 15,17,18, 132:15
52:6,8,20, 21 93:1 134:8 band 125:23
22,24 94:21,23 135:1,18 barbers 7:12
53:1,2,3 95:9,10, 136:4,18
barcode
54:1,12 12,14,15, 137:3
10:7,8,9
55:4,6,8, 19 96:2,3 139:12,24
21:24
10,11,13, 98:3 140:5
23:24 24:2
15,19,24 99:24,25 143:2
29:8,9,18
56:5,10, 100:8,11, 144:5
41:10
12,16,19, 16,17,21, 146:17,20
61:9,12,
22,23 24 101:3, 151:25
13,21,22,
57:5,21 11,19,22 152:20
24 62:6,13
58:7,8,17 102:12,18 155:5
63:16
59:6,12 103:6,7,9, 156:17
64:3,9,21
60:1 61:7, 11,21 157:5,9,18
65:4,10,
8,18 104:3,4,6, 158:2,6
11,17
62:16,18 20,21 159:7,19,
67:25 68:3
63:5,6,7 106:2 20,21,23
64:2,11, 107:7,8 170:22,23 barcodes
12,19 108:13,16 173:12,14, 29:2

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Page 422
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: barrier..bins
barrier 180:5 batched 60:11
184:24 batch 84:20 85:14 77:15 95:4
Barron 37:18 85:12,13, batches 139:8
53:11,22 15,20 85:20 142:4
108:7 135:12 113:15,18, 143:6
178:2 143:13,14, 20 135:21, 156:17
21,25 23 136:2, 172:3
based 15:14
16:4,5,21 144:1,4,5, 13,20 begins 22:6
42:10,11, 10,11,17, 143:7,10, 62:8
12 58:14 21,25 13 146:11 begun 12:10
62:10,12 145:1,2,4, 147:2
7,11,13,16 173:17,21, behalf 79:25
83:9 91:2
100:11,19 146:10,15, 25 174:13, belongs
106:12 18,24 20,25 118:3
110:23 147:8,14 175:4,6,8
belt 155:16
111:19 160:22 197:23
161:3 198:1 benefit 23:6
130:10
134:15 172:24 203:19,21 bid 132:9
146:20 173:1,13, 205:21
big 16:25
150:11 19 174:10, 206:1,3,6,
17:1 50:2
175:16 11,17 8,11,15
88:25
175:15,16 bedtime
basic 30:24 153:4,9
176:4,6 199:24 155:2
basically 192:18
began 9:14 156:2
7:24 23:23 197:24,25
55:15 158:12
40:8 43:1 198:10,14,
62:16 179:12
54:2 18,23
66:23,25 201:15,19 134:7 Bill 124:2
70:23 202:7,8, 158:22
billing
79:24 10,14 begin 12:2 130:22
101:25 203:9,16, 133:24
17,18,22, bin 159:19,
103:22 144:5
23 204:2, 20 192:15
105:9 163:7
6,14,17 200:23
170:16 beginning
205:19 205:4,5,8,
basis 8:22 5:3 7:9 13
206:3
9:6 100:3 9:12 43:25
207:21,22 bins 75:13,
152:3 46:23 52:5
18,22

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Page 423
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: bit..breezeway
155:2,3,4, 70:15,17 Bowes 9:14, 17,20,21
11,24 72:15 24 10:9 143:3
156:2,4,6, blonde 188:2 11:16 147:23
7,18 22:6,15 148:23,25
158:12,13, blouse 23:8 24:7 153:1,13,
15 159:3, 180:25 47:25 14 156:18
4,10,17 blue 61:24 158:2,9,18
160:4 138:15,16, 62:2,3,17 159:12,14
169:24,25 19,20 74:2,3 160:4
170:5 78:24 79:4 185:1,3,9,
board 6:2
171:4,5,6, 116:8 10,16,18,
7:2,3,15
13 186:19 117:5 23 186:24
21:12
194:19 123:18,21 188:21
37:21 56:6
bit 6:12 box 113:3, 195:13,14
61:4
25:11 82:12,13 5,8,9,16, boxing
47:13 93:3 143:21 20 126:14, 188:19,20
97:25 144:1 24 127:1 200:14
109:21 145:11 141:9,11, boy 23:1
123:11 160:22 25 142:23 109:24
136:11 161:2 150:15 173:8,9
163:20 204:2 153:21
188:23 154:4 braided
board’s 188:1
191:11 171:6,13
145:1
202:3 186:22 break 8:20
Bob 5:19 195:15 26:8
black 68:14
126:12,13 borrowed boxed 40:18,22
153:20 188:13 157:14,15 43:17 44:4
154:4 75:8 89:3
boss 178:2 boxes 113:4,
157:2 138:10
bottleneck 12 126:9, 139:1,3
184:15 10,11,12,
157:23,24 166:21
185:4,9 13 134:5
195:1,5,12 bottom 10:18 167:2,8,12
137:1,12, 171:15,16,
186:14,25
Blake 39:17, 19,20,23 19,20,21
189:6
18 40:2 140:17
192:14 breakfast
blank 21:21 141:16
198:8 165:11
41:18 142:1,5,7,
199:14
42:14 11,13,16, breezeway

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Page 424
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: Brenda..career
91:15 brown 185:23 117:17 189:2
Brenda 8:3 bucket 122:15 cancellation
54:17,18, 154:5,6, 131:4 9:3
22 18,23 135:12
136:24 cancellations
Brian 111:25 155:7,8,9, 9:2
10 137:23
Brianna 155:11 candidate
buckets 162:4,8,9,
54:21 55:1 61:6 144:6
155:1 12,16,24
bring 39:1,2 158:12 candidates
164:13,22
132:7 144:6
budget 24:9 165:14
154:11 145:14
167:4
190:6 building can’t 35:17
169:12,13,
bringing 48:2 91:9, 36:13
19 178:5
154:17 11,14 74:8,10,13
179:17
126:3 100:16
broke 77:21 196:7
134:24 102:25
138:3 162:10 called 7:18
162:25
brought 168:22 20:7 21:8
167:21
38:16,23 169:17 22:23 32:8
171:17
39:23 60:17 95:5
built 72:22 173:24
77:22 120:16,19
BUNDREN 205:2
126:14
Brower 37:20 75:17,22 capabilities
127:25
38:13,16, 76:12 48:14,15
128:2
20,24
business 147:7 capability
39:12,22,
25:13 154:6 56:12
25 40:3,10
71:11 174:1 123:22
53:14
178:2
90:4,7 busy 167:4 capture
194:24
91:22 191:11
92:3,12,15 C calling
captured
93:23 147:8
150:14
94:9,12 calendar calls
99:4,5 45:21 46:7 cardboard
162:17,19,
51:24 113:4,5
Brower’s 21 169:8,
91:8,9 call 9:5 10 career
93:25 47:12 57:8 178:22
camera
78:3 149:21

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Page 425
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: carpet..Cheeley
carpet 166:14 changed 45:2,3
164:17 center 21:17 95:8,24 46:11
165:13,18 80:15,20 96:8,9 59:19,23,
carry 155:5 114:7 122:9 24,25
126:20 characteristic 70:4,16,22
Caryn 52:8, 71:5,8,9
131:4 s 42:23
18 53:21 74:13,22
54:11 139:13 charge 52:5,
148:21 75:7 76:1,
7 99:7 7,14,16,
case 71:16 158:7 170:7 22,24
83:20 162:4,5,8, 178:25 77:1,3,6,
93:23 9,12,16
96:12,25 167:4 chart 14:16 8,17,20
98:3 174:20 16:8 19:10 82:16
103:8,23 180:3 Chattahoochee 97:22,24
117:17 189:6 51:3 99:16,20,
135:2 192:21 21 108:17,
174:6,8 check 37:11 19,25
175:7 certified 69:23 129:9,13
205:23 71:14 92:17,18 134:17,20
82:6,10,13 140:9 139:3,10
cases 141:25 112:10,20 144:20 141:3,5,7
146:9 143:15 163:6 144:24
153:7,20, 201:1
certify 146:6
21 156:21 207:18
82:11 147:20
cast checking 149:13,14
103:10,17 chain 72:7,
144:16 161:5,7,
14 75:20,
catch 153:17 11:1 11,12
24 93:10, checks
186:9 140:4,10, 171:14,17,
15,21
199:10,13 11,12 21,22,23
94:20
202:24 172:5,10,
137:20 Cheeley 12,13
category 148:1,4 5:16,19 177:9,11,
79:18 149:2,7,9, 15:1,4,7,8 15,17,20,
11 154:24 30:5,8,12,
caught 23 180:9,
186:10 change 17,18 11,14,16,
105:12 43:16 20,22
ceased 169:9
123:17 44:2,6,9, 181:18,20
ceiling 158:22 13,21 184:9,12,

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Page 426
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: Cheryl..Command
25 185:2, 56:1,10 cleaned 153:13,14
4,7,8,20, 89:25 90:2 166:8 186:25
22 186:6, 91:23 cleaning closely
10,12,15, 92:19 165:13 119:1
17,21 93:5,9,13, 194:19
187:1,7,9 14,15,22 closer 18:21
200:9 29:10
189:3,9, 94:10,11,
12,13,15, 20 95:18 clear 67:23 clothes
16,21,23, 98:15 99:3 73:18 137:16
25 190:4 138:22 118:10
120:3 clouds 54:25
191:10,13 chiefs 39:15
193:1,4 130:18 coat 197:7
194:11,13, chief’s 38:7 204:11
code 10:18
21,22 42:25 43:4 clerk 30:13 22:21,25
196:15,18, 91:23 70:19 23:8,11,19
20 197:17, choose 96:2 71:14,18, 29:4
20 199:4, 22 92:20, 142:15
circumstances
7,10,14, 22,23
205:17 collaborative
16,19 93:2,14
cities 50:17 95:25
202:3,5, 94:22
19,25 51:5 112:22 collect
206:21,24 citizens 113:13 149:6
207:2,5,6 119:15 131:5 color 20:10
208:8,11 120:5 144:9,20 28:8,12
Cheryl 71:8 170:16,17 67:7
City 60:9
75:9 99:16 135:7,8,9, client 70:17 138:14,20
149:13 15,22 190:20
clients
161:8 colors 20:22
clarification 112:3
171:18
70:4 147:6 clip 177:5 combination
chief 8:4 30:20
classes 180:12
37:11,12, 141:17
118:24 clock 193:20
15,16 173:16
119:9,11 194:15
38:5,9,19,
132:25 combined
20,21 close 56:9
40:1,4 clean 165:2, 203:21
122:15
43:8,10 4,15 184:23 combo 60:17
55:25 200:21
closed 138:9 Command

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Page 427
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: commence..contracted
49:19 69:15 208:13 165:1,5,7
commence 203:17 conclusion contained
114:20 completeness 53:1 62:19
115:16 65:14 conducted 96:23
Commissioner completing 95:12,23 118:12
61:5 85:14 98:7 100:1 120:24
171:8
committee completion conference
container
106:5 125:22 74:24
110:16,18 126:25 108:21 113:2
containers
communicate component confident
16:12,17 124:1 9:18 90:22
113:1
communications comprise confused 136:23
31:24 106:5 39:14 157:2,4,7
company comprised 109:24
contents
42:7,9 140:1 110:1
146:5 90:23
49:7 51:10 computer 128:10
64:13 46:7 confusion 155:12
156:11 122:20 103:24 160:3
compare conjunction 195:15
computerized
119:25 122:18 70:21 contest
compared connection 40:19
computers
60:14 122:15 93:11 continue
comparing consent 48:24
concern
119:17 149:23 157:8
151:12
123:23 158:21
205:10 consist
176:15
complete concerned 105:8
16:18 53:7 contract
34:3 92:15 constant
15:12,13
completed 93:4 150:8 107:17
17:18 41:5
115:12 163:13 constructed 42:18,19,
175:8 173:3 91:13 21 49:4
203:11 concerns contact 51:5
205:16 158:25 165:3 130:18
completely CONCLUDED contracted
48:25 contacted

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Page 428
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: contractor..count
11:14 24:4,5,19, 96:23 191:23,24
contractor 21,22 97:1,19 193:6,7
38:16 25:15,24, 100:8,13, 194:3,9,10
25 26:6, 18 103:3 199:1,2,8,
control 21,22 104:1,18, 9,17,22
203:9 27:7,17, 19 110:5 201:2
controlled 23,24 114:1 202:15,16,
129:21 29:15,16 116:10 18 203:15
30:21,22 117:21 204:14,15
controls
31:2 118:8,15, correctly
197:22
32:24,25 18 119:10 17:7 46:3
convene 33:1,3 120:7,22 50:14
107:7 34:13,14, 121:3,10 55:21 82:5
conversation 17 35:12, 126:3,4 95:9 97:12
167:20 13,24 36:9 133:21,22 100:5
168:2 39:24 40:2 135:7,13 147:22
42:15,16 136:18 155:18
copiers 47:9
46:16 141:13
copies 48:23 50:10,24 142:24,25 correlate
53:23 143:5 58:7
copy 15:2
36:20 57:22,23 145:15 correlated
55:23 58:4,5 146:4,13, 141:10,14
59:20 59:8 63:3, 14 148:2,
couldn’t
99:17 24 65:5, 3,5,8,9
6:13 19:3
144:21 11,19 153:22
48:21 71:5
159:15 66:11 156:25
78:9 153:6
68:1,2,9 163:16,17
corner 157:22
69:3,4 168:4
26:15,23 158:17,18
72:4,18 174:23
27:9 162:6
73:15,16 176:5
180:18 167:14
79:11,16, 179:23
181:5 204:8
17 80:1 181:10,13
correct 6:3 83:22 84:5 182:4 count 15:6
7:7 17:10, 86:5,6,12 184:7 66:4 72:12
11 20:21 87:3,4,9, 185:16,17 84:19,22,
22:10,11, 13 88:15 187:11,12, 25 85:16
12,16,17 90:8 92:7 19,21 95:13
23:7,9 93:23 94:6 190:12,24 96:10

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Page 429
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: counted..court
99:6,7 96:5 143:1 61:5 62:16 140:3,8,9
104:13 173:24 63:11 142:10
108:16 178:1,3,4 64:2,12 144:8
109:19 country 5:22 65:7,16, 149:4
110:23 35:3 22,24 151:10,24
115:17,18, 109:24 66:11,24, 153:7
23 143:17, 173:8 25 67:8 160:1
24 144:4,5 208:11 69:1,7 170:11
159:22 70:1 71:1, 178:20
172:24 counts 13 79:20, 182:23
173:2,4,24 172:25 21 82:11 185:10
174:14 county 6:1,8 83:13 188:14
175:1,2 8:2 9:12 85:19 191:7
206:10,14 11:22 12:4 86:3,15 county’s
counted 98:4 14:25 87:11,16, 22:10 27:5
102:8,9 16:11,12 18 88:6 45:17
103:20 17:17 91:13 68:24 69:8
114:22 18:11 97:19 70:13
116:20 19:7,16 98:4,7,9, 78:16
145:21 21:19 12,16,22 80:14
197:23 22:14 99:11 82:10
206:8 24:16,20, 100:1 98:10
24 25:17 108:11 139:25
counter 112:2,22
26:16,20 140:25
199:16,17 27:3 114:3
counterfeit 28:19,21 117:19 couple 40:21
98:3 31:7,12 118:4 courier
100:5,12, 32:3 34:25 119:8 91:2,3,4
17,22 35:5,22 126:3 140:1,20,
36:2 37:21 130:24 22
counterpart
39:1 41:1, 131:17
37:11 couriers
9,23 45:5, 132:8,10,
counties 132:23,24
8 46:18 14,19,21
7:17,18,25 48:1 49:25 133:4 court 5:4,6,
45:13,15 50:2 51:6, 135:22 11 30:15
46:14 47:5 13 56:6 136:13 70:21
53:2 57:19 137:6 71:14,18,
counting 58:3,10 139:13 22 74:12,

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Page 430
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: courts..day
13,18 24,25 72:7,14 59:21
93:14,20 115:3,16, 75:17,21, 66:2,5,6,8
94:22 25 116:3, 24 93:10, 68:25
112:22 16 117:11, 16,22 72:3,5
113:13 23 118:1 94:20 74:1,5,6
144:9,15, 121:18 112:21 78:25 79:4
20 130:14 137:20 83:11,17,
courts 70:10 134:4 148:1,4 23 87:8,
144:13 CREELEY 149:2,7,9, 12,15
129:15 12 152:10 113:23
cover 88:2 154:25 116:9,15
90:23 crew 95:3 117:6,21
155:13,14, 168:8 cut 18:18
138:10 124:6,11
15,16,19, 182:1,2
25 189:7 191:2,3 dates 16:1,8
criteria 106:18
190:11 57:14
D 151:17
covering 118:21
daughter
189:5 140:12 daily 9:1,6
194:23 150:3 170:8,9
13:13,15
COVID 98:18, crossed 14:16 15:6 David 78:11
20 189:18 17:16 Davis 54:17
152:3 133:12,15,
Covington Cs 54:24
40:16,17 dark 140:24 16
cumbersome
200:2 day 13:10
crease 50:6
102:18 dark-colored 16:2,4
current 45:16,17,
157:2
create 167:5 24 46:2,10
105:19 dash 60:3
cursive 51:16
created 122:2 data 9:1 55:8,12,
83:13 15:15,20 13,15 57:8
cursor
16:3,5 82:9
creates 181:18
85:18 88:11,14
203:8 custodian 131:2 89:5,10,
credit 14:22 170:16,17 12,17
111:22 127:14 106:22
database 9:5
114:8,15, custody 107:15,16
17,18,20, date 14:9 108:10
70:19
58:18

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Page 431
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: day-to-day..determination
127:5,13 deal 50:2 134:6 44:20 57:8
134:15,23 dealing 7:19 153:1,22, 108:7
142:3 9:11 99:24 25 157:21 160:25
143:6 160:3 208:13
151:23 December
delivering describe
153:16,17 38:2,3
93:12 104:3
158:1,13 decide 111:11
162:3,8,16 delivery
111:12 112:13
166:3 47:2
decided 47:4 152:24 Deshay
179:3
159:3 164:13
193:12,15 demand 41:6
205:9 decision 48:15 designated
208:4,7 51:17 49:3,6,20, 141:17
53:20 21 59:6
day-to-day desk 6:10,
103:19
8:16,21 Democrats 15,16 7:16
104:5
9:10 106:8 176:21
132:6
days 12:12, 107:23 177:7
decrease 181:3,7,9
24 13:3,11 denounced
159:24 182:3,6,
17:9 18:1 122:18
45:22,23 defective 11,15
department 184:5
51:14 185:14
31:24 186:18
55:12 define 104:2 98:10 194:2,6
88:10,13,
definite 100:1 201:10
20 89:1,7
53:16 120:11
108:11 destination
121:5,7
127:14 deliver 79:12
150:11,13
134:9 78:17
152:9,12 detail 22:18
137:14 92:18 95:2
depending 128:23
139:15,18, delivered
58:12 150:14
20,21 51:12
151:18 146:19 detailed
81:11
154:19,20 depends 119:14
89:24
160:2,10 90:5,7,9, 106:7,11 details 37:4
DD 121:5 21 92:3,5, deposited 82:18
9,11 93:2, 152:1 128:22
deadline
8 113:13 determination
18:25 deposition
115:1 103:20
156:24

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Page 432
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: determine..Dominion
110:22 174:12 discuss 172:22
determine 179:7 30:16 documentation
14:13 183:9 discussing 34:1 82:18
57:14 195:21 52:20 94:9
58:13 88:5 207:13 111:20
discussion
102:8 difference 99:2 197:24
111:5 21:5 30:25 documentations
115:7 32:6 69:12 discussions
53:9,15 94:1
118:21 102:11
123:23 138:25 documents
displays
191:15 85:6 30:12
developed
28:18 differently disruptive Doe 105:17,
94:20 106:24 141:6 19 136:8
device 62:18 difficult doesn’t
distinguish
208:12 79:12 68:17 79:9
didn’t 11:16 84:21 88:2
13:10,13 digital 85:5 125:13
92:15
55:10 59:9 dimensions distribute 103:9
62:4 33:20 127:2 109:11
64:15,23 110:10
dinner 77:19 district
76:5 78:12 115:22
60:17
81:10,21 direct 8:3,7 138:24
88:9 90:6 91:1 division
144:6
94:3 102:9 6:11 80:14
directing 145:13
109:4 92:16
23:20 175:15
110:12 93:13
178:15
112:6 directly 110:8
197:12
125:13 21:14 156:21
198:15
141:8 67:20 170:11
145:9 78:18 80:9 Dominion
Dixon
153:9 90:17 48:9,17
176:17,19,
154:15 49:5,18,19
director 20 182:8,
156:2 63:11
53:11 9,21
159:2 101:14
152:16 183:15,17
165:25 160:9
disabled 187:20
166:15 161:14
12:16 14:7 document 175:6
169:10
145:15 207:20
172:9

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Page 433
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: Dominion's..early
Dominion’s 190:9 driver’s duplicated
48:14 195:8,22 120:12 204:25
don’t 13:7, 196:10 drives 197:3 duplication
18 30:13 197:6,8 204:7,10
203:9 driving
34:7 163:9 duties 8:14,
35:15,18 207:22
drop 80:6 16 9:10
37:4 44:16 door 130:9 38:7
57:8 67:22 97:22
doors 130:7 149:7 DVS 121:2
68:20 160:7
70:12 dropbox Dwight 37:20
71:23 double 137:2 78:17 39:22,25
72:22 doubt 13:22 79:2,8,16 53:14,16
82:24 37:8 53:18 80:3,7,18,
97:8,9,10 99:1 19,23 E
100:10 151:13,15 81:2,4
101:17 172:21 83:21 e-mail 54:5
102:18 148:16 90:15
downloaded
105:2 150:4 e-mails
143:20
107:19 152:7 53:24
116:18 downstairs
dropboxes 169:11
118:23 91:6
80:12,20, earlier
119:8,14 downtown 21 148:13, 19:15
120:5 48:1 80:15 18 149:1, 27:23
124:5,15 128:4 10,18,19, 50:15
127:22
Dracos 74:19 20 150:3, 52:21 70:5
141:22
13,19,20 148:11
144:18 dripping
151:11,20 160:23
149:18 167:16
152:1,11 166:17
164:24 Driver
166:4,6 dropped 173:20
120:19
172:9,20 68:19 179:19
121:4,6,7,
177:2,21 80:12 early 38:10
12
181:23 dropping 39:4
driver's
182:1 99:22 105:22
184:4,8, 120:13
163:16
drops 79:20
10,13,17, Drivers 164:3,16
20,22 121:5 duly 5:13 168:2
189:3 207:9

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Page 434
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: easier..employees
easier 135:3 39:8,9 38:5,7,9, 15:11
136:1,5 45:22 10,12,19, 23:16
easily 50:5 51:20 20,21 84:24
55:16 39:15 111:21
easy 135:19 59:22 40:1,4 123:11
eat 77:19 83:6,7 42:25 elevator
165:12 86:4 92:2, 43:3,8,10 168:20,23
7,11 93:3 50:16,22 195:19
Education
95:1 96:5 51:4 56:1,
61:4 eligibility
98:5,6,23 6,9 80:14
Edward 49:9 103:8 82:17 83:1 61:6
effort 96:1 104:22 89:25 90:2 eligible
105:21 91:18,22, 60:23,24
egg 49:16
106:3 23 92:19 103:18
eight-and-a- 107:2 93:5,9,13, 107:21
36:4 108:11 14,15,22 112:5
eight-and-a- 127:10,11 94:20
else’s
half 33:5 133:2 95:11,18
169:20
134:1,11, 98:4,10,15
eight-and-a- embedded
half-by- 15,23 99:3 100:1
138:22 110:8 86:24
34:12
145:3 131:18 130:24
eight-and-a- 153:16,17 132:14,19, emergency
half-by-seven-
158:1 21 133:5 56:19
inch 34:19
162:8 156:20
elderly employed
167:10 160:1
12:16 14:7 6:1,4
183:6 170:10
17:3 37:21
193:12 178:21
39:10
election Electionet 182:24
11:9,23 183:2 employee
120:16,17
12:11 197:22 130:4,5
elections 160:6
13:3,5 electronic
5:23 6:2, 170:10
15:15 54:5 72:22
8,10 7:3, 175:19
17:10 111:17
16,20 182:21,22
18:14,24 127:21,22
21:12
19:8 24:20 208:4 employees
37:11,12,
30:6 98:7,12,
15,16,22 electronically
38:17,24 16,17,20

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Page 435
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: empty..envelopes
99:11 entered 23,24 21,22
121:21 149:24 35:6,17,23 136:8
129:23,24 entrance 36:5,8 176:1
130:2,5,11 130:12 37:8 62:1, 190:18,23,
131:7,8,10 3,4,9,10 24,25
132:10,11, entry 9:1 63:20,25 191:3,5,
20 133:5,7 15:15,20 64:10,18, 17,18,19
156:12 16:3 131:2 19,23,24 194:8,9
165:1 170:17 65:1,4,11 envelopes
182:20 envelope 66:6,7,8, 10:14
empty 193:25 10:15,16, 9,12,13, 18:7,9
17,19 15,17,20, 19:17,21,
en 168:21 19:19,24 21,22 22 20:3,
encompass 20:1,2,17, 67:3,4,7, 10,11,23
103:11 19 21:21 14,17,20, 21:7,10,18
22:2,3,4, 22,25 26:9,11,13
end 14:18
7,8,9,13, 68:4,7,8, 28:14,15
40:8 55:10
20 23:9, 10,12,18 29:3,21,24
85:21
18,20 69:7,8,9 30:3,7,23,
142:21
24:4,6,23 70:7,24,25 24 33:19
156:18
25:1,3,13, 73:6,14, 36:17,22
197:25
16,17,23 20,21 74:7 37:1,3
208:3
26:2,14, 78:25 62:17,18
ending 14:17 16,19 79:7,12 64:11,13
ends 142:20 27:9,10, 83:24 65:9,23,24
13,15,19, 84:1,4,9, 66:10
endurance
22,23 11,12,13 67:1,5
40:19
28:1,4,17, 86:5,7,12, 68:21
English 21,24 16,18,25 69:25
132:22 29:8,9,13, 87:4,12,22 70:24
enjoying 14,17 115:5 71:12,13,
57:9 30:9,20,25 116:14,23 17,21 72:3
31:1,6,21, 117:2 73:5 81:7
ensure 94:23 118:6,8,
25 32:2,4, 83:12 84:8
197:23 11,12,13
5,6,7,9, 86:14
entail 38:8 13,21,24 119:18,25 87:7,16,18
enter 17:17 33:3,14,17 120:1,4 95:12,13,
42:17 34:13,19, 125:19,20, 17,20

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Page 436
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: equipment..facility
116:9,21 164:8 7:12 extended
125:1,6,7, ESS 49:15 examined 142:5
8,15,18,23 5:13 extensive
126:5 essence
174:17 excess 118:24
129:6,18 119:8
130:3,20 estimate 203:20
134:13 56:8 101:1 exemplar extra 56:10
136:17 128:18 25:3 29:20 61:22 90:5
137:7 152:25 30:3 70:23 92:2,9
139:13 180:2 77:23 extras 70:6,
142:24 138:12 7,12
estimated
146:12
44:8 exemplars eyes 201:22
149:3
estimation 29:24 30:9
152:19
81:18 exhibit F
157:18
175:21 etiquette 160:21,24
F-I-C-K-L-I-N
176:8,10 29:6 172:6,8,
52:9,12
185:24,25 14,23
evaluations 204:1 F-I-D 42:2
186:2,5
102:24
190:20 expected F-I-D-L-A-R
191:7 Evans 39:17, 58:8 42:5
192:13,20 18,23
expeditious fabric
202:9 evening 155:16
44:22
203:2 127:3,7
205:5 experience Faces 130:6,
evenings 7:22 38:18 16,18,23
equipment 127:4 99:24 131:1,13,
9:16 10:24 15,17
22:15 23:8 event 98:24 experienced
167:5 132:2,7,9,
126:14 38:23
13,20
eventually 107:19
ES&S 49:4,8 133:2,21
33:23 expertise
ES&X 49:7, 140:2,10,
53:11 38:19
12 11 183:23
78:20 95:3
explain facilities
escalated 165:7
31:15 38:12
162:17,19, examination 60:13
21,24 5:15 146:4 facility
103:15
escapes 91:17,18
examinations

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Page 437
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: fact..finishes
fact 207:22 139:14,25 197:6 14:1,12,
facts 149:19 140:7,17 felons 9:4 13,15,23,
143:4,9 24 15:2,9,
failed 145:25 felt 19:3 21 16:1,9
148:10 146:9 48:10
fill 17:21
fair 35:1 147:4,11, FEMALE 31:19 32:3
64:18 24 152:20, 172:11 38:22
65:18 24 154:1 104:17
Ficklin
68:4,5,7 157:5,7, 174:15
52:8,13,18
70:3,22 19,22,23
53:4,9,10, filled 63:10
84:6 158:8,20,
21 54:11 93:22
102:20 23,25
103:10 160:6 Fidlar 41:24 145:3
111:5 161:21,23 42:2,3,5, filling
112:23 163:3,5,7, 8,18 104:18
120:6 9,19,24 55:19,24 201:9
157:25 164:20 file 5:3 final 113:3
160:11 165:2,5,7 10:10
166:10 11:25 find 135:2,
fairly 7:21 4 136:4,5,
167:2,8 12:2,3,23
fall 164:25 168:5,19, 15:6,14, 6,9,10
familiar 22 169:7, 16,19 158:19
161:19 16 170:7, 16:3,4,21 finds 10:12
20 175:5 17:7 43:25
fan 193:14 fine 36:18
176:12 48:16
Farm 113:24 40:20 44:5
195:6,18 76:9,10
114:5,9,13 196:24 77:15 finish 38:24
115:14 197:3 89:9,10 39:13 43:5
124:19,20, 107:2 153:9,11,
fashion 47:7
23,25 122:16 15 205:15
48:12
125:2 126:1 finished
126:20 fast 157:22
139:8 44:8 186:1
127:2,4,16 featured 172:3 198:6
128:1 177:12 201:4,11
129:20 filed 96:12
feel 119:2 203:8
130:15,22 files 12:8
134:6 fellow 13:2,6,12, finishes
137:7 184:5,15 16,23 85:20

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Page 438
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: finishing..Fulton
finishing 102:16,18, frame 182:4 18:10
158:20 21 framework 19:7,16
fit 33:24 folding 135:3 21:12,19
34:12 10:13 22:10,14
Freeman 24:20,24
67:18 folks 120:3 129:4
126:24 25:17
159:2 170:8,9 26:15,20
fits 67:13 192:11 177:3 27:3,5
five-by-seven 195:23 184:6 28:10,19,
35:23 36:5 follow 35:4 Friday 18:25 21 31:2,7,
96:18 45:21 46:1 12 32:3,7
five-by-seven-
inch 35:6 55:16 34:25
food 73:4
58:24 35:5,22
five-day forge 121:25 36:1 37:21
88:17
88:16 39:1 40:1,
form 72:7, Fridays
flap 29:10 14 75:17 4 41:1,9,
193:14
83:25 84:2 93:11,22 23 45:5,8
104:1 front 23:4, 46:21
flexibility
192:8 5,9 26:19 47:13
50:3 27:2,8,13 48:1,11
flooded formatting 60:12 49:22
164:22 69:19 82:19 50:12,17
floor 21:16 formed 97:23 51:13 56:6
48:3 91:7, 100:10 193:18 57:19
10 97:17 202:11 58:10
forms 75:21,
163:14,19 24 149:10, full 202:10 61:16,17,
164:2 12 18 62:16
full-time
166:1 63:10
Fortunately 100:2
167:14,15 64:2,12
124:1 170:10
195:20 65:7,16,
165:10 182:20,21
22,24
Florida
forward fully 201:19 66:11,15,
42:11,12
82:23 Fulton 6:1,8 24 67:2,8
fold-down 68:24
found 96:7 8:2 9:12
87:21 11:22 12:4 69:1,7,8
158:17
folded 33:23 163:14 14:25 70:1,12
34:20 16:11,12 71:1,13
fourth 97:17 73:11 76:3
36:11 17:17

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Page 439
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: Fulton's..great
78:16 160:1 114:8 Glenn
79:20,21 170:11,25 148:11 152:12,15
80:14 178:20 179:17 golf 193:16
82:10,11 182:23 generally
83:13 185:10 good 12:18
14:2,20 75:8 81:20
85:19 188:14 33:21 38:8
86:3,15 191:7 109:19
162:11,15 110:14,15
87:11,16, Fulton’s
18 88:6 generate 138:22
20:19,23 58:15 145:21
91:13 21:12
97:18 gentleman 146:21
68:6,8,10 150:21
98:4,9,10, 73:13 195:11
16,22 196:6 165:6
100:1 function
Georgia gotcha 49:18
102:13 38:10 119:13
46:14
112:2,22 funding 52:23 government
114:3 123:17 131:16 21:16 48:2
117:19
funds 24:10, 132:4 80:15,20
118:4
21 195:2 114:6
119:8
furnish give 5:8 126:3,20
122:19
146:3 6:24 15:3 128:4
126:2
19:13 26:1 130:22
130:24
43:2 56:8 134:24
131:17 G
61:24 139:13
132:8,10,
G-L-E-N-N 74:24 88:7 148:21
14,19,21
152:15 89:9 158:7
133:4
92:20,21, 162:4,9
135:22 Gagan 144:20
22 93:6,7 174:20
136:13 129:17
gain
105:11 180:3
137:5 130:12 109:10 192:21
139:13,24
140:1,3,8, Garland 121:24 grade 7:12
9,24 141:4,5 122:10 grading 7:14
142:10 gather 95:6 134:4
149:8 Graham
144:8
gave 17:21 152:5 152:14
149:4
41:5,6 great 11:15
151:10,24 giving 55:23
48:8 56:8
153:7 108:21
107:22

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Page 440
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: green..HB
green 113:24 95:8,11, hands 85:25
138:17,18, 114:3 13,16 handwritten
20 116:5,12, 96:7,9,12 143:14
green-grayish- 24 122:14 98:5,6,8,
127:24 24 99:6,7, happen
189:6 105:21
129:18 23 143:17,
ground 21:16 137:16,23 24 144:3 111:18
48:3 91:7 139:11 172:24 117:25
group 100:18 144:19 173:2 123:19,20
173:14,15 146:23 174:14 happened
197:22 149:24 175:21,22, 179:6
151:8 23 207:24
grouped Happy 130:6,
156:4 hand-deliver
176:5 16,18,23,
158:10 81:1
groups 25 131:13,
163:2
135:4,11 Hand-delivered 15,17
173:8
170:17 80:1 132:2,7,9,
174:19
13,20
guess 15:22 177:11 hand-delivery 133:2,21
17:1,2,12 186:7 79:24 140:2,10,
23:17 195:6 80:4,6 11 183:23
24:16 guy 188:6,9 83:21
31:7,14 hard 82:18
197:7,8 hand-off
39:23 83:1 159:4
guys 74:17 91:1 167:5
41:1,17
45:23 47:9 hand-scanned 197:3
50:15 H 144:11 harder 51:5
53:22 hand-write haven’t
hair 188:2
57:24 207:12 100:10,15
60:13 half 25:5,7
handle 140:15
62:14,23 32:17,18
48:17,18 172:10
64:1,12 34:7,9
50:16,20, HB 20:7,8
71:11,25 36:3,6,8
22 171:9 21:8,20,23
79:9,18,24 142:18,19
80:15 156:21,22 handled 22:2,9
81:6,20 139:23 25:19,21
half-inch-wide
83:9 94:18 handling 26:9,10,
36:5
96:19 162:17,19 12,17,20
hand 5:7 27:13,17,
107:6

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Page 441
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: head..identifier
20 30:9, 171:3 156:11 139:24
10,23 31:2 hearing 9:5 hired 8:1 houses
35:6 36:7, 53:3 39:8 120:18
14,16,21 149:17 130:4,5
40:25 human 104:17
64:13 heavy 188:21 hit 198:22 hundred 82:1
70:13,15, heavy-duty hold 6:21 hundreds
18 47:14 114:11 143:1
head 19:9 held 7:9 136:17
199:4 hyphen
21:5 34:8 69:11 98:9
200:15 60:13,14,
94:14 113:24 15,16
104:24 126:21 holding 73:7
152:9,12 145:11 holds 142:23 I
163:5
helped 183:3 144:12
heads-up 154:5,8 I-M-B 23:1
helpful
93:6,7 idea 13:7
189:10 home 18:21
hear 6:13 193:20 26:1
helps 136:11
64:16 123:10
hey 74:17 honest 68:19
70:16 71:5 141:22
168:13 82:16 94:8
74:8,9,10, 175:3
169:19 108:14
13,16,17, 179:24
179:19
21,22 76:8 he’s 39:10 identical
141:8 58:14 hope 77:17
21:3
154:15 108:21 hopper 62:5
163:18 identification
152:16 hour 57:3,
164:23 61:20
182:1 11 72:25
166:23,25 62:22
190:18 73:2
167:3,7 63:12 64:3
195:14 206:19
171:17 201:9 identified
hours 105:22 29:11,12
hear-- 74:12 high 69:22 206:20,22 114:23
heard 83:10 highlight house 56:5 identifier
109:25 6:24 87:19 24:3 29:2
110:3
Hills 51:3 115:22 41:10
111:25
hire 8:10 116:1 60:16
124:14
166:24 131:2 housed 72:6 61:9,19
68:3

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Page 442
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: identifies..intended
identifies in- 56:4 including initially
67:25 87:18 140:6 165:24
identify in-house incorporated 192:21
64:25 18:11 19:7 87:1 initials
138:8,24 35:22 increase 204:20
173:12 40:24 41:8 159:23 inserted
177:6 45:5,7 33:13,19
51:18 indication
identifying
52:5,20 79:11 inserter
64:20 10:24,25
161:16 56:24 57:5 individual
195:14 58:17 119:22 inserting
61:18 128:11 33:17
image 11:3 62:17 64:1 136:17
101:21,23 inside 10:19
65:8,16
102:4,6,19 information 50:17
69:4 70:1
112:16 21:18 64:25
71:1 76:18
119:19,21, 22:12,13, 66:21
83:13 86:3
22 120:20 16,18 67:13
88:5 89:20
45:16 85:8 86:12,22
images 11:5, 90:6 94:21
120:23 118:12
10 101:18 102:13
121:10 126:24
112:4,9, in-house- 144:6 127:15
10,13,14 produced 146:3,15 140:16
119:24 36:22 151:16 153:20
207:19 41:23 152:4 162:9
IMB 22:21, in-person 165:4 168:22
24 23:2,19 38:9,11 204:4,18, 195:15
29:3,5 148:14,18 23 instructed
IME 22:25 inch 25:11 initial 207:17
immediately 53:25 instructions
inches 25:7
115:17 144:10,11, 31:16,18,
26:5
134:3 17,21,25 20 32:3
34:15,16
145:25 145:2 33:10,11
include 146:4
157:14 34:24 62:8
68:17 173:6
167:19 66:18
included initial-based 125:25
improper
56:18 204:21
150:20 intended

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Page 443
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: intent..I'm
103:2 items 75:11 88:11 167:5,23
110:9 76:15,25 90:13 173:18
intent 108:2 93:12 91:11 175:8,14,
111:5 it’s 5:19 94:15 16 182:5
6:5 11:2 101:7,8,9, 185:14
intermediate 10,16 186:8,11,
50:1 12:25 15:6
19:14 20:7 102:6 16 188:24
internal 21:16 103:20 191:16,18
43:14,15 22:3,9 105:4 192:1,24
23:22,24 106:4,12 193:5
internally
24:2 25:5, 107:2 194:24
85:9
22 26:3,13 110:21,25 195:8
interrupt 112:17,18 196:22
27:8,23
172:8 113:7,8,18 198:20,21
28:9,11
INTRODUCED 29:11 115:20,23, 199:18
160:21 31:11 24 116:25 202:9,23
172:14 34:9,21 117:3,6,20 204:3,20,
43:17 118:13,23 25 206:17
invoice 21:9
47:11 51:1 120:14,16 207:4
involved 122:8 208:5
53:16
30:15 125:4,6
54:24 60:9 Ivy 97:4,5,
52:19 126:14,22
62:21 7
53:9,15 127:19
63:20,24 I’d 30:8
131:12 128:3
64:8 65:23 59:19
132:6 131:24
66:21 99:16
133:10,12, 141:6
67:1,18,19 161:9
19 143:23
68:13 69:1
involving 72:14,15 144:12 I’ll 30:15
170:21 73:7,16,25 145:15 37:10
74:3,4 146:23 77:19
isn’t 37:25 147:9,17
75:7 77:19 127:17,18
40:19 151:8
81:24 146:22,23
issue 45:11 82:17 83:1 152:6,22 172:12
issued 45:18 84:25 154:6 173:3
46:13 85:15,24 155:21
I’m 5:22
86:3,4,7, 160:17
issues 6:12 12:12
8,15,20,21 162:25
167:16 13:12,15
87:18 164:12
14:15

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Page 444
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: I've..Keisha
16:12 118:10 I’ve 10:2 36:17 44:2
18:2,3 120:2 23:22 46:7 70:6
27:1 28:3, 122:21 36:13 71:11
16,17 29:5 127:9,20 40:21 45:4 75:11
30:5 34:6 129:9 51:1 60:1 77:17
35:20 131:24 65:14 139:11
36:18 134:19 82:16 83:9 141:8
37:15 138:4 87:6 147:22
39:14 142:15 112:16 149:15
40:18,20, 143:19 122:2 164:22
25 42:19, 144:11,15 146:22,24 172:15
24 43:5 146:5 179:11 177:24
44:9,14, 148:16 179:13
21,22 150:14,15, J 180:18
45:20 46:6 23,24 186:18
51:15,24 153:4 jacket 203:1
57:16 154:16 184:16 208:8
62:14 158:6,8 January 6:6 Judge 111:25
65:14 67:5 159:18 43:8 94:4
68:8 69:7 160:23 jump 159:21
70:23 161:6,11, Jenkins 55:1
June 39:8
71:5,23 19 162:6, job 7:11,16
jurisdiction
73:3,7 25 166:6 16:19 19:5
38:11
75:15 78:7 167:10,13, 38:10
42:25 43:4
81:25 17 168:16 39:11 40:5
98:14
82:12 83:5 171:15,17 54:8
161:20
88:12,24 172:7 115:23
195:4
92:6 93:8, 179:18 190:2
20 94:18 181:6 jobs 98:19 K
95:1 96:17 183:6
98:11,14 187:14 John
Katrina
101:17,18 193:14 105:17,19
136:8 164:5,7,8
108:20 197:14 167:21,23,
109:22 200:7,13, Johnson 24
110:1,2,3 18 201:21 54:13,14
112:5,17 202:15,16, keeping 70:9
Jones 5:6, 148:4
113:17 18 204:11 12,18,19
117:3 30:19 Keisha

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Page 445
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: Kemp..length
176:17,18 35:19 163:2
181:3 L 178:11,13 179:1,6
182:8,9,21 195:3 196:9,11
L-A-R 42:4
184:3 laws 18:4 205:15
196:4 L-E-O-D
leaves
54:23 lawsuit
Kemp 74:15 149:25 130:21
134:19 labor 130:17
leaving
lawyer 5:22
kind 6:24 ladies 93:25
35:3 78:8,
9:7 11:21 164:15 168:8,9
13 208:11
14:4,19 182:19 169:17
25:9 29:2 200:6 lead 170:17
183:13 led 170:21
45:11 59:6 204:12
63:1 64:2 207:17 205:18 left 35:9
65:17 leading 39:18,23
lady 180:25
82:17 115:19 40:6 99:22
181:17,21
109:24 123:14,16 122:6,7,8,
182:7
112:25 160:2,10 9 140:24
183:21
138:14 142:21
187:4 leak 166:19
139:11 157:7
188:5
155:15,20 leakage 163:3
193:25
160:14 166:16 171:11
194:1,6
175:14 179:12,25
198:2 leaking
188:2 181:8
165:23
191:14 lag 52:22 185:20,21
166:2,12
201:21 large 43:1 192:2,5
leaned 82:23 200:7
205:17 123:9,13
126:13 learn 5:24 left-hand
kindly 111:2
136:25 165:21 26:14,23
knew 45:16 153:3 27:9 88:1
learned 9:19
61:24 95:4 180:18
largest 166:18
165:25
174:25 13:17,19 leather leftover
180:7 late 7:5 197:7 29:20
knowledge LAUGHTER leave 38:1 leftovers
152:10 44:11 40:4 126:2 69:24
157:4 legs 189:18
knowledgeable law 12:12
160:6
162:24 18:2,3 length 34:6,

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Page 446
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: letter..looked
7 95:5,7,22, 132:3,5 149:2
letter 49:13 25 96:2,6, location 151:24
60:11 8 23:21 153:19
122:5 list 9:2 80:17,18 159:9,13,
141:17 99:10,14, 91:1,24 14,15
15,17 134:24 184:20,21,
letters 22 203:4,
60:10,12, live 60:24 155:5
5,10,24
14 lives 40:14 locations 204:3,4,
let’s 8:20 58:12 80:16 11,23
35:5,21 103:23
livestreamed 114:10 log-in 130:6
43:17 51:7 150:12
63:6 75:10 148:11,12, logs 89:6
78:21 living 40:10 16,19,22, 147:11
109:14 25 149:2 148:4
Liz 74:14,
139:3 176:14 184:18
20 96:17
160:25 lock 130:8, 204:13
97:23
167:18 9,11 134:5 207:11
108:17,20
196:10 129:10 137:19 long 6:4,18
202:19 172:5 locked 160:7 8:5,8
level 94:11 180:12,14, 11:5,8
21 184:9, locks 137:22 34:15,16
138:24 138:1
168:25 25 185:21 50:25
169:1 186:7 log 72:19, 52:23 75:9
187:8 21 75:12, 92:25
liaison 7:25 191:10,11 20,23 115:22
license 193:3 77:22,23 170:24
120:12,13 197:17 78:4 80:2, 179:24
199:5 5 81:3 183:14,17
licensing
202:4,22 85:24 188:1
7:2,12,15
located 89:14 longer 25:14
lid 200:23 117:18
11:18 47:3
201:2 127:13,18,
21:15 looked 32:14
limit 135:20 25:21 24 128:2,
8,22,23 37:10
limited 50:17 100:15
124:17,18, 140:15,16
173:21 101:2,18
20,23,24 147:7,14,
limiting 18,23 109:19
131:15

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Page 447
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: lose..mailroom
121:17 24:7,10,22 179:4,7,9, 55:11,13,
129:1,2,5 47:25 12 14 56:17
150:25 61:24 74:2 mail 10:18 63:7,10
151:7 78:24 79:4 11:15 66:1 68:24
201:14 84:10,14, 12:2,20 88:11
lose 127:22 17,24 13:10 89:11,17,
85:6,8 25:18 20 90:6
lost 74:23 104:18 92:3,10
31:5,9,17
lot 25:14 116:8,13, 34:25 101:22
57:25 14,16,17 35:11 47:2 mailing
102:17 117:5 51:15 53:2 9:13,24
143:3 123:18,21 56:13 10:18
168:21 124:7,12, 62:18 13:10 22:5
172:19 22 125:17 65:22 26:15,18
173:22 175:21 66:16 27:3 28:21
191:12 72:6,9,10, 32:5 45:24
loved 107:18
194:15,24 11,13,19 46:19 53:5
lowered 198:15 78:17,22, 58:24
155:2
machinery 23 80:3 61:14
lunch 44:3 9:20 81:4,11,19 154:2,5,6,
57:3,11 83:21 18,23
machines
72:24 88:12 155:7,10
41:2 54:11
73:2,3 125:4,6,24 158:12
63:12
75:8 76:5, 130:21
124:16,17, mailings
6 77:18,21 134:4,8
18 51:16
88:5 89:2 152:8
Madam 74:12 155:2 mailroom
M made 14:14 192:17,19 21:14,15
15:20 17:4 47:24 52:7
mail-in
M-C-C-L-O-U-D
28:3 29:17 66:2 68:25
54:24 103:9 72:1 73:25
49:24 50:1
M-C-CAPITAL 51:17 mail-out 78:16,20
54:23 103:19 61:8 87:1 79:16,19
104:5 mailed 14:4 87:9,17
machine 9:15 91:7,20,21
10:3,4,9 105:12 18:1,9,20
129:4 19:11 114:4,7,
23:13,15, 10,23
24,25 143:5 32:10
155:19,22 52:22 115:17,18,

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Page 448
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: mails..Maximum
22 116:2,7 13:13 makers 53:20 March 96:25
117:20 15:24 makes 25:11 mark 104:9
124:5,11, 16:15 26:13 160:23
13 140:5 18:17,19
30:15 making 44:25 marked
mails 66:10, 102:24 101:25
13 41:12,14
45:18 53:6 127:15 102:10
main 55:3 57:10,11, 162:17 marks 104:9
158:25 17 60:19 174:6,7 110:7
166:21 62:14 175:12 111:13
167:2,8,12 65:15 86:2 179:14
180:6 master 72:19
maintain 92:13,16
75:12,18,
11:17 95:10,17 males 188:20 20,23
144:9,10 103:19
man 181:8, 77:22,23
205:25 104:10
14,25 78:3 81:3
106:10
maintaining 185:5 match 115:7
107:17
9:5 195:9 186:14
110:22
maintains 113:12 managed 207:25
197:3 118:2,10 131:1 matched
maintenance 120:2 manager 115:6
9:2 122:15 8:12,15,22 matching
123:18,20 94:17
major 12:14 118:24
124:8,9,14
205:9 managers 119:9,12
128:4
majority 8:18 145:23
129:20,22
81:16 130:17 manner 15:11 material
98:16,17 138:24 manual 123:6 171:11
105:24,25 146:23 materials
106:13 manually
158:24 171:12
120:25 164:23 111:7
121:11,13 169:13,20 122:22,24 matter 65:9
130:23 170:19 191:22 135:21
133:12,13, 179:8,11, manufactured max 88:12,
14 138:15, 20 181:6 137:16 13 101:12
18 157:20 185:25 128:20
manuscript
178:23 195:6,19 122:3 Maximum
make 8:25 88:14

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Page 449
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: Mccloud..Moss
Mccloud 53:25 mine 81:20 182:16,17,
54:17,18 146:21 minimum 50:4 22,23
Mccloud’s meetings 142:2,3,9 184:3
54:22 52:18 187:6,10,
minute 15 196:5
meaning Melanie 129:14 198:24
104:7 129:11 minutes 199:1
means 104:3 Melendez 43:19 200:18
110:11 152:13,14 53:24 201:3,13
128:15 75:9,10 202:12
member
144:19 158:11 203:1
170:12
meant 50:15 193:5 Monique’s
memory 109:3 194:12 187:13
measurements 136:16
miscount 201:23
25:2 33:22 messages
67:16 203:22 monitored
169:11
missing 150:18
mechanism meter 85:5 205:19,22
22:21 96:4 month 90:10
150:16 method 206:4,6
morning
158:8,19 79:19,23 mistake 28:3 158:3
173:11,13 80:23
mistaken 162:13,14
198:20 123:6
81:25 163:13,15,
media 5:3 mid-2020 88:12 16 164:3,
43:25 40:8 93:20 95:1 16 168:3
77:15 middle 27:8 109:1 179:21,22
108:6 148:16 Moss 164:6,
midway 39:4,
139:8 159:18 10,14
18
149:17 moment 74:25 167:23,24
166:25 military
170:6,10,
167:3,6,8 55:9,13 Monday 59:1
18,24
168:6,8 88:16
million 74:4 171:1,3
172:3 158:1
million-dollar 178:24
190:8 money 24:9 181:4
9:15 22:15
meet 5:20 172:20 182:13,19
mind 29:23 183:10,11
54:2 Monique
117:4 187:22
156:23 176:16
144:16 188:1
meeting 181:4

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Page 450
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: Motor..November
Motor 120:12 Nadine’s 184:1,19 94:19 95:1
Mountain 99:6 193:8 98:5,6,23
50:21 161:20 207:8 103:8
names 54:10 non-dds 104:21
move 126:19 105:21,22,
156:11,22 99:11 121:1,2
107:6,10 23,25
181:18 non-driver 106:1,2,3,
133:9 121:9,13
moved 8:19 145:13 14,25
38:21 normal 95:24 113:23
114:24 narrow 44:15 199:5 115:19
132:11 nature 123:5,14
north 80:17
153:16 198:22 124:18
notarize 127:8
moving 155:4 necessarily 173:1 131:18
156:11,15 175:7
notarized 133:2
multiple needed 134:12
97:3
156:2 16:13,16, 139:15
206:8,11, 22 47:13 note 30:16
145:3
15 53:18 notes 53:24 148:15
municipalities 56:18,19, 151:21
noticed 47:2
51:2 24 59:8,10 152:19
52:21
135:5,10, 129:1 153:1,2,3,
142:4
12,22 200:8 4,10,22,
notified
news 53:3 24,25
municipality 93:4
167:5,6 154:19
60:11
168:8 notify 31:24 156:19,23
135:2,6
45:19 157:17,20
mute 141:5 nice 5:19
November 158:1,3
night 145:3 160:2,10
11:9,11,
N 157:25 161:22,23
13,22
158:1 163:16,19
12:11
Nadine 166:5 164:3,16
17:10
43:10,11, 167:1 166:11
24:10,20
13 99:8,13 169:9 167:1
30:6 45:22
105:5 176:13 170:22
76:9 83:6
149:5,9 177:6 175:1
90:12
150:6 178:25 179:22
92:2,7,8,
151:5 180:7 180:1
10,14

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Page 451
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: number..office
207:8,9,16 144:5 88:7 123:9 observing
number 5:3 146:17,19 141:21 178:22
10:20 13:8 147:23 153:18 obtain 25:18
14:4 19:4, 148:15 161:16
153:3 174:15 occurring
9,10 21:10 150:20
23:19 159:21,23 176:4
172:3 186:13,14 168:25
43:25
47:14 173:13 203:10 October
50:3,5 175:4,15 205:19 45:21
56:4,23 178:9 206:3 46:7,15
57:4 58:7, 180:5 numerically 51:21,25
8 60:2,6,7 181:9,11 72:17 58:18,21,
61:19 182:4,6, 174:21,22 23 59:1,
62:23 11,15 12,21
63:2,13,14 183:20,22, 62:15 86:4
O
64:21 24 184:6 89:3,4,7,8
72:8,10, 186:19 O-K-I 51:10 odd 122:4,7
11,16 187:10,16,
O-P-E-X 169:15
76:18 18,20
198:3 84:15,16 offer 39:9
77:15
81:22 199:2 oath 26:16, office 6:10,
85:24,25 201:25 17 27:15 15,19 7:5,
88:13 203:9,22 28:23,24 23 14:24,
100:25 204:6,14 74:6 84:1, 25 15:16,
101:5 206:18 3 87:20 23 22:22
104:23 207:11,18, 88:1,2 23:15,23,
106:11,12 19,24,25 116:25 25 29:6
114:23 numbered
117:1,2 37:7
115:3 72:13 118:13,17 39:12,16
128:12 88:13 93:1 119:18 46:13
136:9 174:20,21, 120:1,4 50:16 51:9
138:8 22 observation 58:1 78:18
139:8 100:11 80:14
numbers
140:25 81:11
56:17 observers
141:1,9, 91:8,10,24
60:2,3,4, 169:4,6
12,17,19, 94:4 97:9,
9,12,14 178:8,12
20,22,23 13,14
72:18,20 184:23
142:5 112:11

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Page 452
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: officer..outer
183:21 129:3 124:12,15, 37:16
184:2 open 22:4 16,17,18, orders
officer 84:10,12 22 125:17 36:14,15
170:14,15, 116:18,19 188:18 55:23
16 124:15 194:23
ordinary
offices 186:24 opinion 71:10
21:13 191:5 100:11
organize
60:22,24 opened opportunity 93:1
91:14 124:9,10, 17:21
114:3 12,15 165:12 orient 181:6
128:4 152:20 opposed original
139:24,25 157:19 159:10 9:19 41:13
140:25 opener 85:25 49:3
149:4 opt 11:12 102:22
opening 46:17 112:19
official 85:1,15,22 order 8:25 177:18,20
67:11 115:14
68:13,18 11:15 originally
124:4 16:17,18
86:8 91:17 188:18 39:7 47:1
17:1 33:15 123:8
officially 190:18 36:21 37:5
176:9 191:1 137:15
38:22,24
offset 136:6 opens 84:11, 41:21 originated
18,19 48:8,11 15:22
OKI 47:11,
15,18 48:5 85:20 51:6 53:7 outcome
51:10 116:13 95:7 111:7
189:7 175:9 107:22
outer 10:15,
190:6,11, operating 117:25
16,17
16 176:13 169:25
19:17,19,
184:6 175:14
OKIS 21,24
207:23 185:25
188:22,24 20:10,12,
191:1
operations 17,19
on-site 59:9 205:25
7:1,11 21:18,21
ongoing 8:16 ordered 20:3 22:8,13,20
84:22 21:7,19 24:3,6,23
115:19,20 OPEX 84:10, 55:18 25:3 28:1,
11,14,17 2 29:3,5,
online 18:22 ordering
116:17 21,24

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Page 453
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: overlays..passed
30:10,20, 107:24 papers
25 31:1 P 145:15,16
pallet
32:24 154:12 paperwork
p.m. 75:3,
34:23 93:17,19
4,6 77:11, Palmetto
64:10,18
12,13,16 50:20 paragraph
65:9 66:6,
139:5,6,9 97:22
12,17 67:3 pan 185:20
161:25
68:7,8 191:11 Pardon
162:1
69:6,8 193:2 154:14
166:11
70:24 194:11 161:7
168:6
73:19,21
169:4,7 pane 188:23 Park 50:21
84:10,12
171:25 panel 105:17 parking
86:16
172:1,4 106:6 168:21
87:11
177:15 110:20
116:9,23 part 13:17
180:1,14 111:10,11,
118:11 35:10 70:1
189:12 18
125:19,23 73:6
190:16
176:1 pant 195:9 105:22
193:5
overlays 194:3,5 paper 31:22 136:12
26:17 199:8 32:2,8,14, 148:1,5
201:2 16 33:6 149:23
overled
36:25 182:1,2
170:19 pack 170:2
37:2,9,10 207:9
overnight packed 95:17 41:13,18, part-time
160:1 115:13 19,22,24 182:20
overseas 168:15 42:15,22 participate
55:13 packer 54:5 98:17
overvote 132:24 55:18,24
57:1 72:15 parties
104:7 packing
86:23 107:21
105:15,16 130:14
102:22 108:3,5
111:13 185:25
113:7 178:16
overvotes painted 127:19,23 party 178:22
110:7 61:12,17 174:11
passed 9:4
owned 153:8 painting 191:21
93:19
61:13 194:2,17
110:11
198:7
paired

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Page 454
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: past..photographs
past 99:25 154:25 percentage 154:22
199:24 158:20 110:13 162:22,24
patient 159:1 134:12 164:4
208:9 163:24 Perfect 170:6
165:18 76:24 175:9,10,
pause 191:10 169:2 11 176:7,
197:18 170:18 perform 51:6 21 183:22
Peachtree 173:4,24 92:19 95:7 186:1
91:18,19, 174:3 performed 208:6
24 178:9,14 99:23 personal
179:6,12 100:11
people 9:3 period 17:14
183:25
12:15,16 permanent personally
184:2,5,21
17:2 52:25 133:4,7, 79:20
189:17
55:3 11,14 101:2
192:1,4,5
57:21,25 170:12
193:18,21 personnel
58:8 59:6,
194:7,15 person 7:13 100:2
12 60:23,
196:1 9:19 14:6 132:17,18
24 78:17
81:10 people’s 26:17 207:10
98:18,24 44:23 29:11,12 person’s
104:7 32:8 39:7 10:20 14:3
perceived
106:5,10 46:16 52:7 23:18 61:6
18:16
107:11,15, 58:12 61:3 63:12,22
percent 63:9,10,18
16,21,22 117:12
108:1 28:16,17 64:5 65:21
80:11,13, petitioners
110:22,25 103:1,25
22,24 107:10,19 98:3 112:3
118:25
119:17 81:21 115:1 phone 74:24
126:1 101:6 119:5 117:17
127:4 112:17 120:9 131:3,4
128:10 113:17 121:25 141:5
129:16 128:20 122:2 162:22
131:6,12 130:25 123:24 164:21
133:9,19, 131:6,12 128:9,11 165:14
23,24 133:20 133:17 169:8
137:16 134:16 144:4 photographs
140:4 152:19 146:20 113:11,12
149:6 166:6 151:1

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Page 455
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: phrase..Possibility
phrase 17:2 17 74:2,3 138:2,5,6 136:12
111:11 78:24 79:4 141:1 policy 45:12
physical 116:8 155:16,17, 46:13
23:13,14, 117:5 19,25
123:18,21 political
21 24:2 play 108:20 108:3
96:9 Pitney’s 129:9,14
110:13 11:12 130:19 poll 38:11
111:16 174:1 98:7,13
place 9:20 99:11
physically 31:19,20 177:9
189:15 100:3
11:4 32:2,4,5 133:1
101:11 44:16,18 194:11,12
199:5 137:3,13
192:2 56:11 74:6 169:4,6
204:9 87:17 88:2 played 178:8,11
pick 90:25 94:22 108:24 179:1
96:3 98:22 player 183:23
154:22 100:20 177:14,16,
103:10 polling
picked 91:4, 19 56:11
115:24
6 149:3 175:11 playing 103:10,23
picture 9:17 186:11 132:25
placing 32:9 188:16
10:5 11:2 polls 56:20,
102:19 plain 22:9 193:1 23
180:23 67:10 194:21
199:18 portion 49:6
PLAINTIFF’S
piece 9:16 115:4
22:15 33:5 160:21 plays 193:16 118:13
96:6 172:14 PM 208:13 position
127:22 plan 53:12 point 12:21 7:9,10
pieces 10:24 54:4 70:4
161:10 positions
Pitney 9:13, 107:15 6:21,25
24 10:9 planned 110:15 7:8
11:16 162:18 122:17
124:10 possession
22:6,15 planning 30:13
23:8 24:7 53:13 pointers 144:17
42:1 47:25 plastic 122:10
49:2 61:23 Possibility
126:13 policies 53:16
62:2,3,4, 137:18 98:22

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Page 456
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: Post..prior
Post 22:21 prep 126:1 99:24 70:13
23:15,23, prepaid 131:17 76:3,13,19
25 29:6 24:17 previously 86:3 88:14
81:11 5:13 146:2 89:3,7,10,
preparation 15,20 90:6
postage 126:1 174:5
24:13,14, 91:3,12
prepare 31:2 print 17:4 102:12,13
18,21 29:6 18:6 41:2,
79:9 81:8, 207:10 161:1
7,19 45:13 185:18
9,10,12, prepared 46:15,18
16,19,21 33:20 47:10 printer
Postal 23:6 48:5,9,23 47:11,13
preparing
practice 108:7 50:3 54:7, printers
206:13,14 165:11 12 55:15, 41:4,6,7
19 56:13 45:6,8
practices prepped
57:14 58:6 47:11,17,
148:5,8 179:21
59:9 62:16 19,23
205:23 presence 68:14 48:5,15
206:2,10 97:5 108:5 51:8,12,18
printed 10:6
pre-folded present 14:14 printing
34:22 91:25 18:8,11 45:15,24
preceded 108:3 19:23 46:19
144:1 178:14,18 26:11,13, 48:19 50:1
145:1 presentable 20 27:12, 51:18
175:13 17 28:14 52:5,8,20
precinct
35:14,22 54:1,8
58:11,14 preserved
40:25 55:3,5,7
59:7 60:6, 71:13,17
41:1,8,13 56:12
7,16,23,25
press 108:21 45:5,7 58:17,25
61:22
168:9,12, 48:25 59:5
62:3,7
18 169:16 56:5,7,17,
96:4 prior 13:3,5
179:1 18,22,24
103:23 18:14
184:20,21 57:5 59:4,
132:24,25 38:18 46:1
190:7 8,10 60:1 51:20,23
precincts 61:7,18
pretty 12:18 98:23
50:9,11 63:15
21:2 195:7 105:24,25
57:18,22, 64:2,3
previous 114:8
25 58:1,9 68:18 122:10

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Page 457
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: probability..provisional
123:5 109:13 processing 170:21
127:10,11 110:11 9:4,21 projected
131:18,19 111:4,10, 46:20 50:7
158:3 17 114:19, 99:25
162:2 20 115:14, 114:24 projects
163:9 16 124:3 132:15 170:18
169:7 129:1,24 153:15 promoted
170:22 130:2,12 169:23 94:11
probability 131:1 176:7
promotion
123:23 133:10,20, produce 43:14,15
25 134:2, 19:15,17,
problem 14 136:1 properly
36:15,20 21 71:3,7
139:15 109:16
55:22 56:2 142:2,3 produced 197:23
166:9 145:5,7 19:7
proposed
208:10 157:6,8 64:11,12,
49:21
problems 159:8 19 65:8,
15,16,23, provide
136:7 165:6,9
24 69:1,25 12:23
160:13,15 170:20
70:7,20 19:13
183:14
procedure 86:14 24:17
200:9
78:24 79:3 87:11 88:6 30:14
204:24
80:7 117:4 94:21 47:15,19
207:8
procedures 70:17
208:12 produces
7:18 9:20 76:21
processed 107:3
49:6 100:3
9:1 16:23 product 111:2
100:19
114:24 201:4
197:21 provided
124:6
production 47:9,12
process 7:19 125:13
9:15,18,21 70:2 71:1 51:9 70:25
157:11,13,
12:8 15:17 professional 112:3
14,19,21
17:22 22:6 158:3 7:2,12,15 providing
24:1 41:21 191:1 program 36:15
46:21 47:5 109:9
processes provisional
48:11 52:5
7:19 94:22 programming 56:19
72:1 84:11
175:9 7:14 103:11,12,
85:1
197:21 16,17,21
105:20 project

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Page 458
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: provisionals..quicker
104:21 136:24 155:13 16:16,19
107:8 137:9,11 161:3 27:25 30:2
108:13 purchasing 173:8 57:16,17
provisionals 132:8 176:3 64:1,14
56:24 192:8,21 65:2,14
purple 196:11 67:24
Pryor 91:16, 180:25 198:7 79:23
21 97:18 181:1 200:12 89:13,14
128:5 purpose 201:2,14 92:13,21,
pull 13:11 35:16 203:1 23 100:14
14:10 61:12 205:4,7 103:5
16:3,5,7 155:20,22 puts 23:8 113:22
48:23 65:22 79:4 129:22
purposes
125:19,21 117:5 138:22
58:7 61:8
138:9 201:3 140:15
107:18
142:21 202:20 150:21
132:14
146:20 204:20 151:2,4,6,
137:21
172:5 9,19
204:10 putting
204:10 154:15
push 201:9 154:3 162:23
pulled 15:14 155:24
put 9:20 174:4
17:7 46:7 176:10
11:1 34:23 195:1
49:5 195:12
54:4 59:14 207:7,13
128:15,17, 200:22,23
21 146:25 72:5,9 questions
203:4
191:20,23 78:25 7:18 40:22
81:2,10 45:4 78:12
pulling Q
90:22 95:6 116:5
16:9,10 96:17
qualifications 145:10
119:20,21 113:4
146:21 163:1
120:8 116:8 197:15
194:8 125:14 quality
92:18 queuing
purchase 135:1,4,11
177:24
36:14,15, 136:25 quantity
21 42:17 137:16 48:20,22 quick 12:22
55:23 146:8 55:18 139:2,4
137:6 147:3 quicker
question
purchased 151:20 23:16
13:14
9:12 154:3,4 175:9,13

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Page 459
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: quickly..record
quickly real 82:18 10:21 123:22
124:6 100:4,12 19:10 29:7 recollection
118:10 31:7,17 55:17
R 130:18 39:11
139:1,3 58:13 recommendation
race 104:8, 160:15 59:21 66:3 136:14
11 105:18, 164:12,14 68:24 150:1
19 167:10 71:25 72:2 recommendation
Raffensperger 73:25 s 53:22
real-time
122:25 150:18 77:25 reconcile
123:6 78:25 174:4
realize 81:23
raise 5:6 145:9 205:8
83:16 87:8
Ralph 5:12, 93:16 94:9 reconsider
reason 14:6
18 15:5 49:1 55:9 112:8 123:15
ran 85:7 56:11 116:7 reconvene
68:16 117:6 77:3
rate 142:4 122:8,9 125:25 record 5:2,
reach 136:3 145:22,24 146:18 17 15:1
165:7,9 193:13 169:8 43:20,22,
read 10:18 reasons receiving 23,25
23:13,15, 104:14 31:4 41:19 75:3,4,5
24,25 136:1 134:3 77:10,12,
61:24 recall 13:4 recently 13,15
62:3,4,5, 137:10,11, 85:19
12 100:5 receipt 90:15
12
83:19 93:16
readable receptive
23:15 receive 103:15
123:11 105:3,4
12:1,19
reads 10:9, 15:19 recognize 106:21
11 62:6 18:20 117:16 112:14
ready 116:1, 21:22 66:1 121:23 119:22
4 134:18 71:11 80:8 184:4,8, 139:5,6,8
161:11 115:20,21 10,13,17 146:23
180:9,12 116:1,4 188:8 150:15
195:17 121:22 189:17 171:24,25
196:9 recognizing
172:1,3
received
204:14

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Page 460
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: recorded..rephrase
208:3 referring registrations 46:3,12
recorded 60:8 9:1 50:13 51:3
17:16 78:3 143:18,19 regular 22:3 52:17
150:16 145:5,8 41:4 55:21 70:8
193:22 82:4,18
recordings reintroduced 83:1
refresh
150:19 123:10 90:17,18
109:3
records 136:16 reject 119:5 92:25 95:9
13:23,25 122:21 97:12
Regina 103:5
14:19,22 rejected
17:12,15 168:11,13, 105:2
16,18 116:19
21:6 56:21 108:13,15
169:17 145:22
59:11 129:6
146:25
85:23 register 149:17
147:14
105:6,7,8 198:12 155:18
106:15 rejection 160:15,16
registered
107:5 128:16 164:1,4,5,
62:22 133:17
111:1 6 167:21
114:16
150:7 rejects 170:3
118:22
133:17 174:8
recount registration 175:2
95:16 8:4,12,15, relates
176:21
98:5,24 17,18,22, 38:10
180:4
173:2 23 9:4,6 reliable 187:13
174:14 10:20 9:13 193:9
recreate 14:3,25 205:12
remainder
67:22 37:15
39:13 remembered
rectangle 52:16
remained 20:15
25:10,12 63:14
180:3 81:24
64:24
red 138:17, 92:16 remind 82:9
remaining
20 193:10, 93:13 128:13 rented
11,12,16 98:11
remember 8:8 156:16
195:9 115:2,7
197:18 13:18 17:7 repeat
119:20
200:2 21:5 33:24 207:14
120:9,18
34:5,7
referred 170:14,15, rephrase
35:15
99:3 16 183:1 64:17
36:13 39:3

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Page 461
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: report..Ringer
report 127:5 requested 101:14 200:15
reported 17:13 respect 63:2 201:12
53:21 59:7,12 retire 38:13
151:15,16 responder
123:13 7:17 40:4,6
requesting
reporter retirement
58:8 70:23 response
5:4,6,11 154:13 38:15 40:7
74:12,13, requests return 21:22
18 14:13 responsibiliti
es 8:15 22:4,10
reports 15:10 26:14,18,
16:23 17:4 9:11 38:8
166:23,25 20 32:2,5
167:7 19:2 31:5 responsibility
200:14
59:20 45:18
represent returned
require responsible
60:4 31:8,9
26:10 37:16
representation 68:17 45:15 review
202:10 128:9 99:14 110:16,18,
representative 178:11 151:6 20 111:10,
61:4 108:2 12 205:1
required rest 110:14
95:8 135:10 reviewed
representative
s 50:9 116:22 151:10
restarted
107:23 126:18,19 85:15 RFP 132:9,
178:16 142:13,16 10
144:12 result 152:1
Republicans Richard
106:8 149:20 results 7:16 108:8
107:23 requires 105:14 178:2
178:13 106:25
request Rick 53:11,
107:1,3
15:2,22,24 rescan 109:6,7,8 22 108:7,8
17:25 201:20 145:17,18, right-hand
18:22,25 resemble 20 88:1
59:19 119:1 resume 192:13
63:22 64:5
90:11,13, resembles 165:19 Ringer 15:2,
20 92:15 122:16 retain 11:5 3,5 19:13
99:17 resets 85:12 29:23
retention
149:11 30:2,7,11
resolution 92:20 36:15,20
162:25

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Page 462
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: risk..Runbeck
46:6 55:23 130:19 80:17 189:25
59:19,23 188:16 rotating Runbeck
70:4,11,16 roll 9:6 142:1 11:13,14,
71:3,6 12:17 18,22,24,
74:9,12, roughly
155:4 154:19 25 12:2,9,
15,19,21 20,23
75:1,10, rolled 170:24
157:17 175:2 13:6,9,12,
15,19,23 17,24
76:4,8,11, 192:12 178:5
14:14
15,20,23, rollers route 52:25 15:12,17,
25 77:2,5, 155:7,8 162:23 22,24,25
7 78:9 186:19 168:21 16:2,18
99:19 17:4,18,
rolling rubber
111:2 19,22,23
155:1,2,3, 125:23
144:18,23 18:4,6,16
4,8,11,24 rubber-banded
146:2,5 19:3,20,23
156:7,18 176:6
147:5,10, 20:15
158:12,13
13,16,19 Ruby 129:4 28:13
159:3,10,
161:5,8 170:8,9 29:3,18,
17
171:14,18, 176:16,23 20,25
22 206:19, room 44:11 177:3,12 30:10,20,
22 207:1,3 47:25 181:1 24 31:4,6,
130:12,13, 184:3
risk 95:5, 11,18,21
21 134:4,9 194:18
7,22,24 32:7,11,
164:22,24 196:4
96:1,6,8 21,23
166:16
road 80:17, rule 150:2 33:21
168:7
19 123:20 34:2,13,
169:3 run 12:14,
124:2 18,23
184:18 18 13:13,
35:10
rocket 195:24 17,18 16:4
37:1,10
120:21 196:2 17:1 58:20
46:17,22
Rosalind 59:10
Rocketfile 47:1 61:8
133:12,15, 61:14 79:3
120:20,23, 63:4,6,7
16 84:12 88:9
24 121:9 64:11,20
100:14
Rosalyn 65:4,15,23
Rocketfiles 113:3
54:17 66:16
120:25 125:20
68:17,20
role 94:10 Roswell 133:1
69:1,25

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Page 463
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: Runbeck's..screen
71:12 sample 78:1 201:7,8 115:2
73:8,9,14, sat 150:22, 204:17 127:11
20 86:14, 24 151:17 205:13 175:14
18,25 207:11,18, 176:7
87:7,16, Saturday 19 183:4,7,
18,25 88:18 10,16,17
scanner
102:12 save 85:22,23 186:1
191:4,12, 198:14,15, 86:1 161:1 195:17
18,25 19 174:16 198:5,13
192:1 175:13 201:11
saving 85:18
194:7 176:9,22, 203:8,10
196:7 scan 105:16 204:12,24
23 181:11
109:10 207:8,10,
Runbeck’s 182:6
127:10 16
19:25 183:14,20,
175:6
20:17,23 22,24 scans 198:10
185:20
28:1 30:7, 187:10,16, 204:13
188:17
8 37:4 18,20,24, scenario
193:2
45:16,17, 25 198:2, 122:11
201:19
24 46:2,19 6,8 199:2 205:18
203:16
69:8,21 201:14,15,
204:6 scene 107:24
70:7,18 22,25
scanned 203:8,15 schedule
running 9:15
101:13,14, 204:21,22 44:25
17:7
19,21,23 205:3
189:21 scheduled
102:4,6 206:18
196:18 96:9
104:5
scanners
runs 13:12, 106:2 scheduling
15 17:5 101:14
109:2 7:13
143:8
110:4 scope 53:25
160:9,14,
S 112:4,9
16,18 scored
143:8
safety 161:4 111:19,21
152:21
164:25 175:6
175:16 screen 96:18
176:13
salad 77:19 183:24 161:9
192:9
195:16 198:20
Sam 49:9, 204:12
198:21 201:15
11,13,14, scanning
200:14,19, 207:25
16,17 104:6
24,25

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Page 464
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: screens..Services
screens secret 64:8 115:24 separate
207:19 175:21 126:9,10 15:21
seal 113:2, 190:23,24 130:7,8,11 142:7
4,6,7 194:9 137:3 174:7,9,
137:20,24, secretary 157:5,10, 12,13
25 138:2, 6:9,11,14, 16 171:11, 177:21
5,10 18 7:5,22, 12 205:10 186:23
141:2,10, 25 15:13, secured 192:6
15 155:14 14,16,23 155:12,14 204:3
157:15,16 16:13,24 157:16 separated
sealed 90:22 17:19,20 security 63:20,24
113:13 31:23 94:23 95:13
147:3 38:22 132:16,17 174:10
39:6,9,10, 176:9
seals 113:8 11,16,19 seeking 58:1
separating
137:22 45:8,11 segment
138:12 192:3
46:13 108:20
47:4,8,19 separation
seat 194:1 select
51:9 52:24 186:2
seated 111:23
62:23 sequence
181:17 selected
68:13,16 174:21,23
182:3 98:12,25
82:6 86:8
183:19 104:8 sequenced
112:11,20
SEB 150:2 111:21 72:17,18
122:17,23
123:12,13 sequentially
second-tier selection
47:12 51:8 142:14 105:12 141:19
143:15,17, 175:6
seconds Senate 124:2
20 150:2 series
199:13 senator 61:3
161:2 47:16,17
secrecy 168:9,12 send 10:23 serve 98:25
32:5,6 184:21 12:23 22:2
66:15,19 190:8,22 48:15,21 served 98:8
67:4,7,17, 195:3 66:25 99:12
25 68:12, service 23:6
section sending 12:8
17,21 100:3
136:10
125:20,22 sends 22:3 132:12
197:25
191:5,20 67:2
secure 15:11 Services

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Page 465
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: serving..signature
120:19 173:1 139:1,3 side 8:17
121:6,7,9, 174:10 show 14:2,3 74:6,11
12,13 191:21 17:13,15 84:1,3
serving 204:2 19:10 63:8 87:20 88:1
98:10 207:24 64:4 79:15 95:11
208:7 106:20,21, 183:2
set 13:10, 185:18
11 47:23, sheets 55:21 22 107:6
143:14,17 111:3,6 191:21
24 85:13 192:13
107:16 144:2,3, 112:14
140:23 10,17,22 122:1 sign 26:17
145:1,2,4 145:13 49:16
sets 48:6 146:8,24 153:21 97:4,11
85:14 147:8 159:16 120:13
settlement 160:23 180:12 122:2
149:25 161:3 197:17 128:9
174:10 showed 149:8
seven-inch
194:1 145:11 signature
34:13
she’ll 152:6 114:8,12,
Shae 164:13
198:22 204:1 19,25
share 161:9 204:13 115:4,5,6,
showing 46:6
sharing she’s 19:14 64:21 89:6 15,25
161:5 129:4 90:23 116:3,17
170:12 127:13 117:12
Shay 164:10
177:24 149:2 118:3,5,9,
178:24
187:18,23 198:7 10,11,17,
sheet 31:22 21,24,25
194:19 shown 79:9
32:2,7,14, 119:1,6,
199:2 81:6
16 41:18 12,18
200:19 207:19
72:14 120:6
202:13,14,
85:24 shows 11:3 121:16,17,
16 203:3,4
86:23 79:8 85:1 19,21
205:11
143:21 89:14 122:4,15,
144:1,4 shirt 195:9 140:15,16 16,18
145:7,12, 197:18 159:9 126:25
13 146:10, 200:2 128:2,8,
shut 160:5,
16 147:14 short 23:12 14,25
7 163:7
172:24 96:6 129:1,19

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Page 466
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: signatures..situation
130:13 sir 7:10 21,24 176:14
131:1,7,13 9:9 11:20 97:2,6,20 177:4,25
133:3,5,8, 12:7 14:21 99:9 178:17,19
10,20,24 18:8,25 100:6,9 179:7
134:2,4,7, 19:13 21:1 101:20 181:16,24
14 147:7, 23:10 104:19 182:5,10,
10 157:24 24:25 25:5 112:1,24 18 183:7,
158:24 26:25 113:14 17 184:2,
172:17 27:11,14, 116:11 14 185:12,
signatures 16,18,21 117:7,9, 19 188:3
115:7 29:1,19,22 22,24 189:24
119:16 31:3 121:11 190:13
120:4 32:19,22 124:21 192:25
121:23 33:2 34:11 128:7 193:12
123:10,23 35:2,25 129:8 197:4
128:5 36:24 131:14,21 198:9
134:22,25 39:21 40:9 134:10,19 199:3,23
145:23 42:13 135:17,24 200:3
146:4 43:12 136:19 201:3,17
45:10 137:24 203:3,25
signed 93:11 52:11 139:17,22 204:3
97:12,13 54:2,9 148:6 206:12
116:22 57:20 58:2 149:12,22 207:15
123:24 62:20,25 150:9
145:23 sit 45:20
64:6 65:6, 152:17 48:22 54:3
172:23 19 66:8 154:2,10 100:16
signifies 67:15 156:12 124:5
173:14,15 68:11,15 160:12
69:5,10, 162:20 sitting
signify 181:4,8,14
13,17,23 163:4
138:21 184:5
71:4,15,19 164:18
signing 72:5 79:1, 165:20 185:4
118:17 6,22 82:2 166:13,15 189:17
83:8 84:7 169:12,14, 192:4
similar
86:10,13, 18 171:16, 194:6
204:1
17 87:10, 22 172:18 situation
simpler
14 92:24 173:18 205:18,21
151:9
96:14,16, 175:24

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Page 467
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: sixth..spreadsheet
sixth 168:25 software 75:12 10:10 15:3
169:1 48:6,8,9, 90:22 95:6 specifically
195:20 10,18 124:11 33:21 76:6
sizable 19:5 49:24,25 135:3
123:21 147:14 specifications
size 26:2 149:21 37:2
32:15 solely 133:3
167:12 specs 43:2
33:24 34:2 solemnly 5:7 192:8
37:8 42:21 speed 186:16
solid 20:19 202:13
69:19,20 196:15
27:23 sorted 23:16 199:5
sizes 36:16 73:12,13,
20,21 sorter 10:25 spell 52:10
slant 122:6, 11:1,2
8 83:12 spelled
86:5,25 sorting 54:23
slanted 135:1
Solomon 84:15
122:7 190:3
174:2 spike 153:4,
sleeve source
Solutions 9
31:20,22 165:21
32:1,8,12 20:7 21:8, split 172:25
20,23 166:19
33:14,15, spoke 164:16
16 35:10, 22:3,9 South 80:18
25:19,21 spoken 163:8
14,17,19 space 106:9
66:16 26:9,10, 120:21 spot 75:8
68:22 12,17,20 137:4 spray 22:5,
86:20,23, 27:13,17,
speak 6:12 7,16 24:9,
24 20 30:9,
30:11 11,21
10,23 31:2
sliced 171:15,19, 62:16
35:6 36:8,
125:18,19 14,16,21 21 sprayed
slip 164:25 64:14 special 41:2 22:19 23:4
70:13,15, 120:5 24:7,24
small 49:24
18 170:18 26:7
50:1 67:18
28:14,20
91:15 some-odd specialist
101:4 151:18 6:10,15 sprays
128:19 10:14,15,
sort 17:3 specialized
19
smaller 23:14 121:22
135:22 42:19 spreadsheet
specific
44:25 59:15,17

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Page 468
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: spreadsheets..state
76:21 staffing 206:24 47:4,8,19
152:6 53:6 208:7 48:8 49:4
spreadsheets stage 62:4 started 7:1, 52:24
76:2 4 8:18 61:2,3
stamp 24:9, 62:24
square 25:10 11,12,13 55:7,14
58:17,25 67:21
stack 173:12 66:3,5,6,8 68:13,17
74:1,5,6 134:8
176:11 139:15 82:7,12,14
191:17 79:4 86:8
83:11,17, 145:9
194:19 158:12,14 112:21
203:12,14 23 87:8,12 113:24
105:10 159:10
205:16 165:8,14, 114:5,9,13
116:9,16 115:13
stacked 117:6,21 15 174:6,
15 120:17
185:1 124:6 122:17,23
stacks starting 123:14
stamped
174:5,7 68:25 127:9,10 124:19,20,
191:16 72:3,5 141:20,22 23,25
111:15 174:19 125:2
staff 8:25
194:19 126:20
45:1 56:6 stamps 87:15
73:1 88:8 starts 127:2,4,16
standard 84:20,21 128:1,9
89:2
106:12 29:6 47:9 122:3,5 129:20
133:11,14 84:2 130:15,22
state 5:17
157:5,8 standing 134:6
6:11 7:25
159:4 181:25 136:7,14
11:14
162:25 137:7
start 14:17 15:13,14,
163:1,6,12 139:13,25
51:17 55:5 23 16:9,
165:10,12, 140:7,17
58:20 13,17,22,
15,25 142:14
127:11 24 17:19,
169:22 143:4,9,
130:1 20,21
170:12 15,17
166:2 18:17
172:24 145:24
197:25 31:23
146:9,12
staffers 198:22 35:19
147:4,11,
130:19 199:5 38:22
24 150:2
131:8,10 200:9 39:6,10,
152:20,24
132:13,21 202:21 11,19 41:4
154:1
133:3 45:9,11

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Page 469
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: state-wide..Suite
157:4,7, 190:23 17:20 15 60:18,
18,21,22, stay 157:16 85:23 87:6 21
23 158:8, 160:1 117:4 styles
20,23,24 163:3 strategies 48:16,17,
160:5 158:22 20,25
161:21,23 step 78:3
117:8,10, stray 104:9 50:4,5,6
163:3,5,6,
9,19,24 11 110:7 submit 12:20
164:20 stick 63:6 111:13 16:18,23
165:1,5,7 streaming 92:17
sticker
166:10 150:18 submitted
113:7
167:2,8 13:6,16,24
Street
168:5,19, stock 36:25 15:10 56:1
42:22 91:16,18,
22 169:7,
19,24 substantial
16 170:7, Stonewall 97:18 93:5
20 175:5 80:19 128:5 suggested
176:12
stop 11:8 132:22 53:4
178:11,13
98:11 strike 13:1
195:3,6,18 suggestion
157:1 163:25
196:24 55:20
167:18
197:3 stuck 191:20
180:20 suit 200:2
state-wide stuff 62:8
stopped suitcase
45:12 186:1,2
167:19 140:25
stated 45:12 192:6
stops 195:19 suitcase-
128:12 stuffed 18:8 looking
storage
states stuffing 126:13
158:8
68:20,21 10:13 suitcase-type
171:10
123:12 158:2,14
store 85:8 stuffs 9:16
132:3
171:11 10:4 suitcases
State’s 6:9, 126:12
stored style 10:8,
14,19 7:5, 127:15,25
84:23,25 10,11,13
23 15:16 136:24
134:23 14:5
39:16 137:5,15
48:18,21,
46:13 51:9 stores 140:24
23,24
112:11 119:19 147:3
57:15
143:21
straight 58:11,13, Suite 168:25
161:2

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Page 470
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: sum..talked
169:2 supply 42:14 115:7 tabulation
sum 12:18 132:13 119:19,21, 84:23
supplying 22 120:14, 113:24
summarize 15,17,19, 156:23
7:22 11:21 31:11,13
36:20 20 140:23 168:24
68:6 207:20 169:9
supposed
summary 6:24 systems 7:14 tabulator
12:1 33:16
Sunday 88:18 93:2 84:17
111:19,20, T 161:16
Sunday’s
88:25 22 173:21 tabulators
tab 87:21,
surprised 161:14
superintendent 22
92:22 116:6 takes 9:17
table 181:17
164:23 10:5 11:2
Superior 189:18
surveillance 133:18
71:22 192:4,5,
149:21 175:10
93:19 16,17
150:5 199:12
94:22 194:6
112:22 suspended 195:12 taking 44:20
144:9 98:19 196:7,11 47:1,3
167:1 201:6,7 52:23
supervisor
119:15
8:3,6,7 suspicion tablecloths
176:9
52:16 151:12 195:2,5
199:10
supplement swear 5:5,7 tables 185:1 200:13
39:12 96:22 203:5
tabulate
supplied 100:17 178:21 205:11,14
29:23 switched talk 35:5,
tabulated
41:22 127:21 21 70:20
63:11
56:22 77:2 78:21
sworn 5:13 81:23 82:3
64:13 122:5
102:25
68:12 86:7 system 9:13, 163:11
112:20
130:17 24 10:23 196:24
140:7
supplier 11:12,16
178:12 talked 19:15
20:4 41:25 22:6 49:5
204:16 53:3 70:5
61:14
supplies tabulating 88:8
107:2
137:2,8 183:16 163:12
109:19
178:9

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Page 471
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: talking..that's
197:2 team 106:7 terms 111:14 115:5
talking 12:5 115:25 173:9 117:8,12
16:12 116:3 testified 120:17,21
29:14 60:5 128:16 5:14 76:17 122:3,4,7
62:2 65:3 140:1 152:18 126:15
66:5,20 160:1 141:10
200:15 testimony 143:3
77:22 5:8 30:19
83:5,6,15 teams 106:3, 148:1,7
83:10 150:1,21
90:2,3 9,10 147:22
95:21 153:7
telling 158:11 158:22
118:6 46:14
127:7,9 text 169:11 166:20
200:19 168:15
185:10 That'd
192:15 tells 72:7 169:12,13,
138:22
200:5 89:11 19 172:19
107:3 that’s 13:14 175:7,10
talks 21:9 146:17 14:7 18:2, 176:8
tall 25:14 3 23:4,6, 177:3,21
temp 132:11 11 24:6, 179:9,10,
taller 19:25 temporary 16,24 13 180:6
tallied 130:5,18 27:17 29:6 181:1
112:10 131:7,8,10 44:5 45:16 182:8,9,
tally 98:5, 132:10,11, 47:4 52:2 13,16
6,8 99:23 13 182:22 54:18 186:22,23
143:13,14, temps 156:14 57:13 187:6
25 144:10, 60:10 188:6
ten 48:19, 62:23 67:5
17,21,25 189:7,10
20,21,22, 69:20
145:2,4,7, 190:7
23,24 73:8,9
13 146:7 192:17,19
113:18,20 76:8,20 194:25
tampered 115:2 79:23 197:8
113:9,10 121:15,18 80:24,25 198:17
tape 113:4, 199:12 84:4 86:7, 199:1,21,
8 tenure 94:10 21 87:21 22 201:15
91:20 202:9
task 51:6 term 17:2
93:6,22 203:14
tasks 53:7 terminology 96:6 97:18 207:24
teach 5:23 60:20 104:1

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Page 472
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: there's..time
there’s 132:23 thirty 82:1 41:25
63:21 140:8 Thomas 44:1,8,14,
67:24 76:1 173:24 54:13,14 20,23,25
79:14 176:9 45:19 47:1
93:21 184:24 thought 78:9 48:16,17,
103:24 185:24 82:25 83:2 19,22 51:4
106:4 193:19 102:5 52:22 53:1
122:14 194:23 124:14 65:21 66:3
129:3,16 207:23 170:1 77:16
140:14 173:20 78:25 79:4
they’ve
143:19 174:17 83:11,23
17:23
145:12 thousand 85:13,20
147:13 thing 17:3 82:1 87:8,12,15
182:3 19:14 35:9 90:4 91:25
55:25 66:2 thousands
186:2 93:1,24
103:22 143:1
193:25 94:2,19
115:19 159:20
194:8 95:9,19
116:12 Thursday 102:7
they-- 190:3 117:21,23 44:9 46:2, 107:6,10,
they’ll 14:9 118:24 4,5 59:4 15,25
191:16 120:25 109:5
tie 138:2,
they’re 9:17 143:16 111:17
6,7,9
24:17 147:8,9,15 114:21
141:1
42:11,12 167:19 115:2
155:14
68:25 173:7 116:9
tied 125:23
69:15 things 7:19 117:5,21
141:10
71:12 8:24 93:2 121:15,18,
72:3,5,9 95:8 122:1 Tiger 19,20
87:8,20 136:4 193:14,15 124:6
103:22 138:24 time 5:4 126:10
113:12,13 173:5 8:4,13,18 130:10,20
116:8 179:10 9:23 12:13 134:11
119:16 14:17,18 139:9
thinking
120:4,8,19 16:10 140:5,6
36:7
124:6,10, 17:13,24 157:3,17
113:18
11,14 18:10,19 158:9
126:3,5,8, third-party 159:16
19:3 21:25
9 130:10 20:4 160:8
29:7 37:19

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Page 473
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: timeline..transported
161:21,22 189:22,23 top 19:9 22:21
162:12 190:1 21:5 26:14 23:11
164:9,21 206:8,11, 34:8 60:2 tracks 85:25
165:10,24 15 83:25 84:3
166:10 90:23 trail 57:2
timesheets
167:3,4 193:19 94:14 trained
168:9,19 104:23 179:13
170:2,7,18 timestamp 155:13 207:18
172:4 88:2 186:14,23,
trainer
174:12 title 8:11, 24 187:4
132:25
178:5,7,23 12 38:5 198:8
179:5,25 52:15 199:16 training
180:4,5,18 94:12 203:12 107:18,20
183:3,7, 170:13 119:14
torn 205:2
10,13,14, 120:5
today 5:24 total 81:22 121:22,24
16,18
44:16 143:7
186:16 transferred
45:20 57:3 148:12,22
194:20 7:2 9:21
72:23 174:25
203:8 112:21,25
100:17 175:4
205:7 140:17
206:24 toilet 208:2,5
165:23 transition
207:22,24 totally
166:19,24 139:12
timeline 20:16
told 31:18 transitioned
15:25 totals
53:12 88:8 9:7 137:4
timely 16:5 207:11
89:2 159:6 translates
24:1 47:7 touch 101:3
164:2,4,17 23:14
48:12
165:7,23 touching
159:8 transport
166:20 101:11
116:2
times 13:10 169:23 touchscreen 126:17
16:6,7 170:3 103:18 139:12,23
17:6,8 176:15
tournament 153:20
34:19 178:1,3
193:16 156:16
88:13 179:11
157:3
108:1 trace 63:21
tomorrow
127:14 transported
179:21 track 10:21
173:23 78:2 128:1
200:15
186:15 tracking 146:9

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Page 474
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: transporting..UNID
147:24 156:8 Twenty 207:3 57:17
transporting 157:3 two-day 64:14 86:2
114:9 171:8,10 17:24 92:13
137:6 176:3 96:19
192:20 type 63:16 98:15
tray 72:7, 74:3 109:5
trifold
8,10,11, 192:19 129:22
12,15,16, 34:21
typically 130:9
20 75:13, trip 127:16 113:15 162:6
18,22 128:4 171:5
78:1,2 129:20 typing 115:2
179:10
114:23 140:21 206:2
125:4,6,24 156:1 U
207:13
126:21,22, trips 137:17
23 128:11, Uber 73:3 understanding
143:3,5 12:25
12,13,24 156:3 Uh- 88:20
136:21 57:16
truck 159:5 Uh-huh 24:15 62:15,21
146:11,13 25:12 42:4
192:17,20, 71:20
truth 5:8,9 81:17
23,24 93:21
96:22 103:4
202:9,11 106:4
Tucker 152:23 128:3
trays 72:6, 131:16 180:10 132:5
9,13,20 132:3,4,5 189:11 160:17
77:23 190:15 165:24
Tuesday
125:15 192:11 181:7
45:23
126:3,6,9, 194:4
158:4 understood
24 127:15 uh-uh 67:2
129:5,6,17 turn 71:23 16:2 52:24
107:9 64:16 71:6
136:17,25 158:17
180:19 139:14
137:7,11 162:23
140:16 umbrella 147:21
turnaround
142:23 99:6 158:11
12:22
146:8 17:24 understand unfinished
147:3 10:2,3 157:5
turned
153:20 16:15 unfolding
71:13,17
154:5,8, 30:19 175:12
17,22 turning 31:10
155:2,6 158:18 41:12 UNID 172:11

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Page 475
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: unintelligible..VIN
unintelligible 180:17 varying 173:6
7:14 14:7 upstairs 57:22 58:9 verify 75:10
15:15 90:1 168:16 vehicle
95:15,16 version
169:22 121:4 19:20
117:15 137:13
127:2 useless versus 80:3
130:9 49:22,23 vehicles 81:4 186:2
141:2 usual 51:5 120:12
159:23,24 veterinarians
203:5 96:1 7:13
unique 23:19 utilize vendor 11:14
Vick 176:18
24:2,3 156:5,8 verbally
41:10 54:2,3 video 5:2
utilized
61:5,9,19, 43:20,24
9:25 verification 75:5
20 62:22
160:10 114:8,12, 77:10,14
64:20
19,25 108:17,21,
161:15
V 115:4,15, 24 129:3
uniquely 25 116:3, 134:17
65:12 vacuumed 17 121:16, 139:7
unit 114:24 164:20 17,19,22 150:5,7,8,
165:17 122:18
unsealed 12,22,25
Vaideeswaran 127:1 151:7,11
84:8 128:2,8,14
30:16 171:24
untabulated 70:21 129:1,19 172:2
157:8 74:10 130:14 177:5
unused 70:12 172:7 131:2,7,13 180:12
133:6,8, 196:21,25
upcoming validate
10,20,25 197:12
55:15 95:3 72:23 134:5,7
119:5 206:17
updated 147:7,11
174:14 157:24 videos
109:6,8
207:23 150:10,18
updates verifications
validated 151:12,15
123:22 133:4 152:11
96:5
uploaded verified 197:3
values 61:5 128:6
110:15 view 119:24
van 155:4 129:20 187:5
upper 26:23
156:15,16 134:22,25
27:9 VIN 63:2
158:24

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Page 476
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: void..wasn't
void 38:23 64:22,24, 145:14 Waller
volume 25 65:5, 167:1 168:11,13,
11:15,17 10,12,18 168:24 18 169:17
93:4,7 66:10,12, 178:12,21 Wandrea
106:7 13,16,17 198:12 164:14,15
123:2,4,13 68:24 voting 14:6 167:24
156:23 79:24 80:1 38:10 176:16
102:1 114:8,15, 182:13
volumes 103:17
47:14 18,20,25 184:3
110:9 115:16,25 196:4
50:2,3 114:16 116:3,16 wanted 12:9
vote 29:12 115:3,6 117:11,23
31:19 116:22 18:17,19
118:1 46:17,18
60:24 118:22 121:18
61:3,6 119:20,23, 55:14
122:13 75:11 76:4
71:14 24 120:9, 130:14
82:10 18 122:13, 80:8,25
103:2,18 16 92:16
W 97:25
105:18 voters 9:11
110:20 103:5
10:10 W-R-I-G-H-T
111:10 114:11
12:3,9 97:4
113:23 122:19
16:22 wait 55:10 136:7
143:15 18:17,19 75:19 179:11,18
169:9 31:25 146:5 195:6
205:1 45:19
waiting wanting 30:5
voted 103:25 47:3,6
52:23 53:2 199:14
104:10 ward 136:9
80:8 108:2 walk 65:13,
voter 8:17, wards 135:8,
110:6 20 72:1
18,22,25 9,16
voter’s
78:10
9:2,4,6 warehouse
10:12 10:14 walked 160:8
132:17,18,
23:23 79:25 169:3
19,21
31:12,13, 103:19 187:5
16 32:23 111:5 wasn’t 48:10
walking
34:25 119:22 55:10
129:4
35:11 77:18
votes 109:11 206:18
62:22 88:25
110:7 208:11
108:3

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Page 477
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: wasting..white
114:7 161:2 41:14 170:13
157:23 week 16:6,7 43:24 193:13
158:19 17:6,8 44:2,19 194:18
166:21 18:14,23 50:13 53:5 195:11,14
190:24,25 19:5 38:2 54:6 60:19 200:8
195:23 46:1 47:6 61:11 63:1 202:12
196:14,16 51:22,23 65:3 67:23 206:21
wasting 52:1,3 75:5 77:14 wheeled
44:23 58:18,21 102:7 157:2
59:3 105:18
watch 160:3 119:5,15 wheels
88:16,20 142:17,18,
watched 89:1 124:1
151:17 139:7 19,22
127:10,11 156:21,22
177:5 133:25 152:5
165:5 185:11,12,
watchers weeks 51:19, 13,14,15
171:14,18
179:1 20 172:2 white 10:16
watching weight 42:22 193:17 20:12,15,
197:14 194:14,23 17,18,20
weren’t
water 197:5,14 22:9
131:9
163:14,18 198:24 30:20,25
156:22
164:2,17, 199:14 31:2,6
180:7
20 165:17, 200:21 32:14,16,
22,25 we’d 70:2 205:13,14, 24 67:9,
166:2,12, 122:1 15 206:19, 10,11,12,
19,21 173:22,23 20,22 17 68:7,8,
167:2,8, we’ll 5:25 we’ve 13:19 14 70:24
11,14,15 30:11,16 127:19,20, 73:10,17,
43:16,18 21 21,24
ways 69:18
44:13 86:8,12,
78:15 what’s 10:7,
70:20 16,22
wear 193:12 16 22:23 87:5,7
77:2,3
32:15 125:9,10,
wearing 144:23
71:20 95:5 16,19
193:8 178:4
115:11 129:6
196:7
wears 193:16 120:15 190:21
we’re 5:2 127:24
website 191:18
12:5 29:14 141:23
143:21 203:2

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Page 478
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: wide..yellow
wide 36:12 23 165:14 203:7 wrote 75:12
widen 187:7 167:14 worth 172:19 147:6
175:16 204:5
wider 20:1 178:4 wouldn’t
69:21 183:2 53:17
Y
width 34:10 107:12
worked 39:8 150:21
36:1,3 year 12:17
40:8 191:2 38:21
Williams 8:3 170:24
wrap 32:8 39:13 43:9
43:10,11, 182:23
33:6,16 178:22
13 93:25 worker 137:3 206:20,23 182:25
94:1,3,8 140:9 183:1
95:3,23 175:17 wrapped 32:1
96:1 99:8 207:8,15 years 6:5,
183:23
150:6 20,22 8:9
workers Wright 97:4,
11:7,8
win 49:4 38:11 5,7
14:20 98:9
window 22:4 98:7,13 write 72:16 99:25
99:11 76:5 100:2
won 41:5
100:3 194:16 131:22
96:5 132:9
130:23,24 204:19 171:2
Woods 193:14 131:1
write-in yellow
word 131:9 137:14
104:11,12 20:13,16,
171:5 140:1,2
110:7 17,18,24,
188:13,15
words 110:17 write-ins 25 25:23
working 27:23
work 6:8,9, 104:12,13
98:18 28:1,7,8
14,18 7:4, writing 62:9
134:19 30:21,25
22 8:1,25 195:11
145:15 31:5
14:16 196:6
158:19 32:21,24
31:11 203:24
163:9 33:3,14,17
57:10,11
165:16 written 66:8,20,21
88:16,20
176:15 45:12 67:13,18
89:1 97:9
182:25 136:12 68:3,7,10
127:4
208:7 69:7,8,9
130:8 wrong
153:16 workload 202:15,16, 70:25
157:22 88:25 18 71:12,17,
158:20,21, 21 72:3
works 97:8

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Page 479
CAROLINE JEFFORDS, ET AL. vs MARY CAROLE COONEY, ET AL.
Ralph Jones on 05/17/2021 ·Index: young..zoom
73:6,7,9, 118:6
12,13,16, 121:25 Z
20,24 122:7
zoom 184:9,
83:12 143:1,18
11,25
86:5,16, 147:7
185:7
19,22,25 154:17
186:21
87:4,7,12 155:23
202:3
125:4,7,9, 193:21
10,11,16, 196:18
19 129:6 200:22
176:1 206:17
181:3 you’ve 17:12
187:4 27:5 44:16
191:17,19 57:18
198:25 69:24
203:2 78:23
young 183:21 82:25
you’d 14:20 101:18
58:6 143:2
194:5
you’ll 74:24 200:1
159:20 208:9
you’re 5:23 y’all 53:21
16:16 58:16,17
32:11 59:5 78:5
34:15 36:7 113:11
40:17 146:2
41:13 148:7
49:18 155:20,23
57:9,10 160:13
60:5,8 165:5,18
62:15 70:5 168:14
83:10,15 178:20
95:21,22 207:15
98:2 99:2
107:13
111:24
116:6

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Page 480
Exhibit N
Harrison Floyd Amended Subpoena

Page 481
IN THE SUPERIOR COURT OF FULTON COUNTY
STATE OF GEORGIA

STATE OF GEORGIA, )
)
vs. ) Case No. 23SC188947
)
HARRISON FLOYD, )
)
DEFENDANT. )

AMENDED SUBPOENA DUCES TECUM

TO: RETURN RECEIPT REQUESTED NO.:

Che’ Alexander
Clerk of Fulton County Superior Court
136 Pryor Street, SW
Suite J2-640
Atlanta, Georgia 30303

YOU ARE HEREBY COMMANDED:

That laying all other business aside, you are commanded to be at and appear at the

Harding Law Firm, LLC located at: 113 E. Solomon Street, Griffin, Georgia 30223, on

December 7, 2023, at 9:00 a.m., and to bring with you into said law firm certain matters to be

used as evidence in the matter of: State of Georgia v. Harrison Floyd, Fulton County State

Court Case No.: 23SC188947.

You are required to produce any and all unredacted and unedited original items identified

in the attached list below that are in your possession or are under Your custody or control

pursuant to Code Ann. §24-13-23:

Page 482
INSTRUCTIONS
Versions - For all electronic files generated, please provide every iteration, including those that
have been created, exported, and disseminated. It is understood that there may be multiple
versions or copies of the same file.

Encrypted Files / Media - Provide all methods and credentials necessary for access to the
digital files/media as stipulated within this subpoena, which includes, but are not limited to
● Passwords for all encrypted files or devices.
● All security tokens, key fobs, or other physical devices necessary for digital access.
● Usernames and passwords for official operating systems or software-based
accounts linked to the provided data.
● Any alternative methods, bypass mechanisms, or recovery keys that enable access to the
data in the absence of standard credentials or when such credentials are insufficient.
● Access credentials required to decrypt any whole disk or file encryption technologies
employed within any segment of your electronic election system, including, but not
limited to, encryption technologies such as BitLocker, TrueCrypt, and VeraCrypt.

Native Format - All Data, Files, and Generated reports should be provided in native -
unmodified format as (a) an XML file, or (b) a JSON file, or (c) a TXT file, or (d) XLS file,
Word, or Equivalent format. (provide all versions generated of each file).
**A PDF printed version of a native file will not suffice due to the modification of the file and
content in printing.

Page 483
ITEMS TO BE PRODUCED
Unless otherwise indicated, the scope of these requests is for documents and data
between November 3, 2020 to January 31, 2021.

User Manuals (10 min) 4 hours - ok

1. Please provide print or digital copies of the following manuals or materials
concerning the software and products which were used or applicable to the November 2020
Election:
a. All versions of user manuals, including but not limited to, installation guides, user
guides, operation manuals, and troubleshooting manuals.

b. Any training materials utilized for the instruction of personnel in the use of
election-related software and products, including training handbooks,
instructional videos, slideshows, and any other educational aids.

c. Documentation relating to software updates, patches, and release notes detailing

changes, improvements, or corrections made to election software and products.

Election Equipment Inventory (5 min) 24 hours -ok

2. A list of all election equipment which is provided by the Secretary of State and
which was purchased by the County, including the following:
a. Serial numbers for all Tabulators used in the November 3, 2020 General Election
including those used for advanced voting, election day voting, and absentee by
mail tabulation;

b. Serial numbers for all Ballot Marking Devices (BMD); and,

c. Serial numbers for all poll pads.

Logic and Accuracy (L&A) Testing (10 min) 688 hours

For election equipment used in the November 3, 2020 General Election, provide the following
L&A test results and records for each of the following:
d. Tabulators by serial number as tested and used for advanced voting;
e. Tabulators by serial number as tested and used for election day voting; and
f. Tabulators by serial number as tested and used for absentee by mail tabulation.
g. For each tabulator, provide the Tabulator Poll Tapes (open and close).

Page 484
Election Certification Packet (10 min) 1 hour

3. Produce a copy of the backup copy of the Official and Complete November 3rd
General Election Project that you prepared pursuant to the December 1, 2020 memorandum for
“Preserving Ballot Images and Delivering to Sec. of State.”
4. Produce a copy of the backup copy of the November 3rd Recount Election Project
including all ballot images collected during the recount process that you prepared pursuant to the
December 1, 2020 memorandum for “Preserving Ballot Images and Delivering to Sec. of State.”

Election Night Reporting (“ENR”) Web Page (30 min) 4 hours

5. All reports and information submitted to the ENR Web Page for the Original
Count / Machine Count 1.
6. All reports and information submitted to the ENR Web Page for the Recount /
Machine Count II.
7. Usernames and email addresses of individuals who uploaded the information to
the ENR Web Page for the November 3, 2020 Election.

Chain of Custody (20 min) 2 hours

8. Provide all documents showing or evidencing a physical chain of custody for all
ballots that were counted in the November 3, 2020, General Election in Fulton County, Georgia.
9. A Ballot Manifest showing a list of all ballot containers and the number of ballots
inside each container.
10. Provide all documents showing or evidencing a chain of custody involving poll
managers, technician purposes, and the transfer of Election Results.

Ballot Images (1 hour) 24 hours

(Please provide the electronic files in a .zip file so as to preserve file metadata.)
11. Please provide copies of all ballot images cast for the November 3, 2020, General
Election in Fulton County, Georgia, in original format and native resolution for the:
a. ORIGINAL COUNT (MACHINE COUNT I); and
b. RECOUNT (MACHINE COUNT II).

Page 485
12. Please provide all secure hash algorithm files with the file extension “.sha” for

Page 486
each ballot image for the:
a. ORIGINAL COUNT (MACHINE COUNT I); and
b. RECOUNT (MACHINE COUNT II).
13. All ballot images created, appended, or modified for/during the adjudication
process, including those of computer-generated ballots which were adjudicated due to write-in
votes for both ORIGINAL COUNT (MACHINE COUNT I) and RECOUNT (MACHINE
COUNT II).

Tabulator Files and Reports (4 hours) 2,866 hours

14. Please provide the following records for both the ORIGINAL COUNT
(MACHINE COUNT I) and RECOUNT (MACHINE COUNT II):
a. Non-modified original versions in the native format of Machine Logs (System
Logs/SLOGS), possibly known as the “slog.txt” files generated from all
(ImageCast Precinct and ImageCast Central) tabulators and ballot marking
devices. THE REQUESTED INFORMATION DOES NOT EXIST IN THIS
FORMAT.

b. Non-modified original versions in the native format of .dvd files generated from
all tabulators and ballot marking devices.

c. Copies of all official tabulator poll tapes (signed/certified and unsigned) for every
tabulator and tabulator ID, including:

i. Opening the Polls – Zero Count Forms (Poll Open/Zero Tapes);

ii. Status Tapes; and,
iii. Poll Closing Tapes.

15. Copies of all tabulator poll closing reports and tabulator reports generated by each
precinct and polling location, detailing with date and time the number of in-person voters, the
number of same-day voter registrations (if applicable), and the final totals for the precinct, and
polling location.
16. For Advance in-person voting, in addition to those records detailed in number 4,
please also provide copies of all scanner Recap sheets, reconciliation forms, and corresponding
status tapes used in the Advance Voting tabulator poll closing process.

17. Copy of the “Not Cast Images” folder and the problem ballot images for each

Page 487
ImageCast Central tabulator and additional/virtual instance thereof as identified by Tabulator
ID,

Page 488
Election Management System (EMS) (4 hours) 72 hours
18. Reports from the Election Management System (EMS) for both the November 03,
2020, original count and the candidate-requested machine recount, including
a. Cast Vote Record (Native JSON Format - Non Altered or Randomized); THIS
WILL HAVE TO BE CREATED.
b. Batches Loaded Reports (Native XML Format);
c. ImageCast Central Logs; THE COUNTY DOES NOT HAVE ANY RECORDS
RESPONSIVE TO THIS REQUEST.
d. Ballot Scanning/Tabulation Machine Logs (System Logs/SLOGS); THE COUNTY
DOES NOT HAVE ANY RECORDS RESPONSIVE TO THIS REQUEST. Ballot
Scanning/Tabulation Machine Tapes; and,
e. Data Translator Spreadsheets and or other documents that may be used
for tabulation, cross-referencing, and aggregation.

Backup Copies of Hard Drives, SD Cards, and USB Drives (8 hours) 16 hours
19. Duplicated/Backup Copies (Forensic images, in EnCase format), of the Election
Management Server (EMS) and database for the November 3, 2020 General Election. THE
REQUESTED RECORDS CAN BE PROVIDED IN THE ORIGINAL FORMAT RECEIVED
FROM THE SOS, BUT NOT IN ENCASE FORMAT.

*Note the Central Election Management System and the secondary EMS
Express System.
20. All SD Cards, USB Drives or other storage devices that were inserted into or
removed from all tabulators, ballot marking devices or other devices that were used for the
tabulation of votes. Can not provide due to all SD cards and USB Drives were used in the
following election.

Reports and Logs (1 hour) 4 hours

21. Copies of the certified final election results that were used to determine the
official outcomes of the election contests;
22. Copies of election results by polling location and precinct;
23. Statement of Votes Cast (SOVC) which provides a comprehensive account of all
votes tallied in the election; and,
24. Election Summary Report.
25. Numbered list

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of voters; Lists (4 hours) 24 hours - #25 through

#41

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types of voting,
26. Absentee numbered list of
voters; 29. Consolidated Return Sheets;
27. Electors Lists; 30. ABBS - Audit Board Batch
Sheet “Batch Tally Sheet”;
28. Copies of all voter check-in lists
for all polling locations for all
31. Copies of all Scanner Recap Sheets for all polling locations for all types of voting,
provides a summary of the votes counted by each scanner;
32. Copies of all Ballot Recap Sheets for all polling locations for all types of voting, a
summary of totals of Physical ballots by Tabulator;
33. Copies of all Poll Pad Recap Sheets for all polling locations for all types of voting
- Totals of voter check-ins by Poll-Pad;
34. Provisional Ballot Reports;
35. Copies of all Provisional Ballot Recap Sheet - summarizes the usage and
outcomes of provisional ballots;
36. Absentee/Vote-by-Mail Ballot Reports
37. Copies of all Absentee Ballot Recap Sheet - summarizes the usage and outcomes
of absentee ballots;
38. Spoiled and Unaccompanied Ballot Recap Sheets
39. Conditional Voter Registration Ballot Report
40. Voted Ballot Removal Form
41. Drop Box Ballot Transfer Form
6-8 hours
Oath
Documents
(15 min)

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42. Please provide documents showing the following oaths taken:
a. Oath of Custodian of Touchscreens and Tabulators
b. Manager Oath
c. Clerks Oath
d. Consolidated Assistance Oath

Signatures / Absentee Ballot Envelopes (4 hours)

72 hours - Unredacted 150 hours - Redacted

43. Produce copies of one side of the Outer Return Envelopes for absentee ballots that
depicts the signature images for all mail-in ballots, absentee ballots, or Overseas Citizens
Absentee Voting Act ballots counted, audited, or recounted in the November 3, 2020 General
Election in Fulton County, Georgia.

57,334 hours
44. Provide all signature exemplars and reference images for all registered voters by
voter registration number and full name (active and inactive for the 2020 election).

Absentee ballot application form (8 hours)

460 hours - Unredacted 10,086 hours - Redacted.
45. Produce a copy of each and every absentee ballot application form, including
those submitted electronically, by mail, in-person, and in-person for Advance Voting.
(Please redact any SSNs, Driver’s licenses, and telephone numbers.)

Hardware / Networking (4 hours) 32 hours

46. The following information related to electronic election system architecture:
a. A network diagram including all devices, mac addresses and assigned IP
addresses for Your complete electronic election system, including but not limited
to the EMS Server, all networked devices on the EMS Server network (routers,
switches, communications servers, modems, etc), and all devices attached to the
resident network for the voter registration server; THERE ARE NO ROUTERS,
COMMUNICATION SERVERS OR MODEMS CONNECTED TO THE
ELECTION SYSTEM.

b. A list of all personnel who had access to the EMS Server or any EMS server
connected computing device;

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c. Provide the name of the person, the account utilized, the devices accessed and the
duration of the access for the EMS Server.

d. All documents related to any indication of any intrusion attempt into Your
electronic election system. THERE ARE NO DOCUMENTS
RESPONSIVE TO THIS REQUEST.

e. Copies of all contracts and agreements with the suppliers of any of Your
electronic election system equipment, devices, software, or support services.

f. Provide an itemized inventory of all election equipment, including serial numbers,

used for the 2020 General Election.

HEREIN FAIL NOT, under the penalty of Law and Contempt of said Court, this the 6th
day of November, 2023.

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Exhibit O
Trump v. Raffensperger Election Contest

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Fulton County Superior Court
***EFILED***QW
Date: 12/4/2020 6:26 PM
Cathelene Robinson, Clerk

2020CV343255

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Exhibit P
Trump Lawsuit Exhibit 10

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Fulton County Superior Court
***EFILED***QW
Date: 12/4/2020 6:26 PM
Cathelene Robinson, Clerk

IN THE SUPERIOR COURT OF FULTON COUNTY

STATE OF GEORGIA

DONALD J. TRUMP, in his capacity as a )

Candidate for President, et al., )
)
Petitioners, )
) CIVIL ACTION FILE NO.
v. )
) 2020CV343255
BRAD RAFFENSPERGER, in his official )
capacity as Secretary of State of Georgia, et )
al., )
)
Respondents. )

PETITIONERS’ NOTICE OF FILING OF EXHIBIT 10 TO VERIFIED PETITION

COME NOW Donald J. Trump, in his capacity as a Candidate for President, Donald J.

Trump for President, Inc., and David J. Shafer, in his capacity as a Georgia Registered Voter and

Presidential Elector pledged to Donald Trump for President (collectively “Petitioners”),

Petitioners in the above-styled civil action, by and through their undersigned counsel of record,

and give notice of the filing of Exhibit 10 to their Verified Petition to Contest Georgia’s

Presidential Election Results for Violations of the Constitution and Laws of the State of Georgia,

and Request for Emergency Declaratory and Injunctive Relief.

Respectfully submitted this 4th day of December, 2020.

SMITH & LISS, LLC

/s/ Ray S. Smith, III

RAY S. SMITH, III
Georgia Bar No. 662555
Attorney for Petitioners
Five Concourse Parkway
Suite 2600
Atlanta, Georgia 30328
Telephone: (404) 760-6000
Facsimile: (404) 760-0225

{00585360. }

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