i~ EFILED IN OFFICE

CLERK OF SUPERIOR COURT

COLUMBIA COUNTY, GEORGIA
IN THE SUPERIOR COURT OF COLUMBIA COUNfY2022ECV0610
STATE OF GEORGIA
OCT 25, 2022 03:12 PM

Cindy Mason, Clerk

Kristen Lovell, Pro Se Cou~a

CIVIL ACTION
Petitioner No. 2022ECV0610

v.
BRAD RAFFENSPERGER in his
official capacity as the Georgia
Secreta:ry of State

COLUMBIA COUNTI GEORGIA

BOARD OF ELECTIONS

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ANN CUSHMAN

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WANDA DUFFIE

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NANCYGAY O
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JARTHURLYNN HOSLEY
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JAMESE WALKER
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LARRYWIGGINS
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Respondents
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PETITION FOR EX PARTE TEMPORARY RESTRAINING ORDER

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Petitioner, Kristen Lovell, has filed her original petition in this case seeking a

Declaratory Judgment and Injunctive Relief against Brad Raffensperger, the

Columbia County Board of Elections, Ann Cushman, Wanda Duffie, Nancy Gay,

Jarthurlynn Hosley, Jamese Walker and Larry Wiggins.

COMES NOW, Petitioner Kristen Lovell, pursuant to 0.C.G.A. 9-11-65(b),

request for an Ex Parte Temporary Restraining Order in the same cause of

action. It appears from facts set forth in Petitioner's original petition and the

exhibits and sworn affidavits attached thereto, that unless the Respondents are

immediately restrained from the acts prohibited below, Respondents will

continue to commit such acts before notice can be given and hearing can be held

on Petitioner's request for Declaratory Judgment and Injunctive Relief in this

honorable court. Furthermore, Respondents will continue their deceptive tactics

and misrepresentations, promulgated by the Secretary of State's office, and

continue to use electronic voting equipment to cast and count votes through the

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upcoming elections before judgment can be rendered. Such injury is imminent

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and irreparable. Continued use of this voting equipment may well cause votes to
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be uncounted or reversed, disenfranchising thousands of qualified electors and

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abridging Petitioner's, the People's of Columbia County and the state of Georgia
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right to vote. There is no possibility of adequate compensation or restitution

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when one's vote is not cast or counted as the voter intended.

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1. WHEREAS, It has been determined from Columbia County's ScanVote

Audit Logs (Ex A) that Columbia County electronic voting systems have the

same software errors as reported by Williamson County, TN. These software

errors cause a large percentage of votes to be uncounted or reversed, thereby

abridging a voter's right to ensure their vote being counted as cast. This is in

violation of the First, Fourteenth and Twenty Sixth Amendments of the United

States Constitution, Article I, Section I, Paragraphs I, II, and VII, Article II,
Section I, Paragraphs I and II of the Georgia Constitution and O.C.G.A. 1-2-6 et

seq., and O.C.G.A. 21-2-365(8). Therefore, since these software issues call in to

question the validity of the vote count, do not alert the poll supervisors as to

these errors, and do not have the ability to be fixed, the use of these voting

systems needs to cease immediately.

2. WHEREAS, These software errors occurred in 97% of counties in Georgia

that provided the ScanVote Audit Logs. This provides factual evidence of this

software issue being a widespread crisis and not a localized, one-time problem.

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The evidence shows Georgia vote counts to be off by as much as 19%. Therefore,

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the use of these tabulating machines for counting votes in Columbia County and
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Georgia needs to cease immediately.

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3. WHEREAS, The evidence proves these counting 'errors' are inherent in the
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software programming of the electronic voting system and not caused by 'human
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error' as promulgated by the Secretary of State's office and the voting system
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manufacturer. Therefore, the use of these tabulating machines for counting

votes in Columbia County and Georgia needs to cease immediately.

4. WHEREAS, If there were cause to believe these inaccurate tabulations were

due to 'human error', it is happening too often and in too high of a percentage of

counties in Georgia to be disregarded. Therefore, the use of these tabulating

machines for counting votes in Columbia County and Georgia needs to cease

immediately.
5. WHEREAS, The Columbia County Board of Elections has been informed

and aware of said software programming issues since at least July 20, 2022,

when Petitioner provided them, in writing, the evidence of such. They have thus

far ignored these warnings. If the counting of votes continues via the use of the

electronic tabulators, the 'Certification of Election' cannot legitimately be

perfected or signed without a hand count of each vote on every original ballot

cast. This was the method attested to by John Poulos, the voting system

manufacturer CEO, as the only way to verify an accurate vote count during the

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State Board of Elections meeting earlier this month. Therefore, the use of these

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tabulating machines for counting votes in Columbia County and Georgia needs
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to cease immediately.
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6. WHEREAS, The State Board of Elections has been notified, orally, in

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writing and by a number ofVerified Notices and Demand of Emergency Review.

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(EX B) These Notices include evidence of vote tabulator 'errors' throughout

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Georgia. Thus, once again, proving this software programming issue as not being

a one-time, localized 'human error' problem but rather a widespread, statewide

crisis. The State Board of Elections has thus far ignored or disregarded these

software programming issues that disenfranchise thousands of voters. No

legitimate 'Certification of Election' for the state of Georgia can be perfected or

signed without a hand count of all votes on each original ballot cast. Therefore,
the use of these tabulating machines for counting votes in Columbia County and

Georgia needs to cease immediately.

7. WHEREAS, Blake Evans, Elections Director of the Secretary of State's office,

is attempting to forestall hand counting of the original cast votes by

misrepresenting the software programming 'errors' as only occurring on

Dominion 5.5B versus 5.sA which is used in Georgia. The evidence provided in

Exhibit A attached, proves this to be a false statement. If this were a true

statement or if any of the reasons given by Evans for this 'error' code

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manifesting were true, then each time a ballot is reversed it would show the

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'error' code 'QR Code Signature Mismatch'. The evidence shows there are
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multiple 'error' codes which are causing the ballots to be reversed. Therefore, the
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use of these tabulating machines for counting votes in Columbia County and
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Georgia needs to cease immediately.

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8. WHEREAS, Though the 'QR Code Signature Mismatch' is not the only
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'error' code causing scanned ballots to be reversed, there is no such thing as a

QR Code 'misread'. QR codes have a signature or checksum within the code itself.

The QR code contains a mathematical validation method which means a QR

code is either read or not read but cannot be 'misread'. And Whereas, the QR

code not being human readable was determined to be non-compliant with

Georgia law by Federal Judge Amy Totenberg in 2020 during the Curling v.
Raffensperger suit. Therefore, the use of these tabulating machines for counting

votes in Columbia County and Georgia needs to cease immediately.

9. WHEREAS, The 'QR Code Signature Mismatch' error code also causes the

tabulator's protective counter to not increment. This protected counter is a

meter, required by law, which counts every ballot scanned. This protected

counter is not supposed to be able to be suspended, manipulated, or reset. It is

coded to the hardware of the machine. However, this QR Code Signature

Mismatch 'error' causes the protective counter to not incrementally add to the

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ballots scanned count, nor does it update the count that appears on the poll tape

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when it happens. Therefore, the only way to ensure every vote cast is counted as
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intended by the qualified elector is to hand count each vote on each original
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ballot and immediately cease the use of the tabulating machines.

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10. WHEREAS, Despite the Secretary of State's office and the voting system
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manufacturer's assertion that this coding error is limited to Democracy Suite

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5.5B and C, it has been confirmed to exist in the software version used in

Georgia on both the Image Cast Precinct and Image Cast Central tabulators.

Therefore, the only way to ensure every vote cast is counted as intended by the

qualified elector is to hand count each vote on each original ballot and

immediately cease the use of the tabulating machines.

11. WHEREAS, The results of the 2022 Dekalb primaries prove this 'error' pair

did in fact change the vote count in the election of Michelle Long Spears when an
additional 2,810 votes were 'found' during a vote recount of the original cast

ballots. Thus, the Secretary of State's office and the voting system

manufacturer's assertions of this 'error' not affecting the Georgia Democracy

Suite version is untrue. Therefore, the only way to ensure every vote cast is

counted as intended by the qualified elector is to hand count each vote on each

original ballot and immediately cease the use of the tabulating machines.

12. WHEREAS, A 'risk limiting audit' after the election is not an acceptable

remedy. It does not allow for the confirmation that each vote cast by qualified

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electors is being counted as intended. It only allows for a very small percentage

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of votes to be audited. The 'risk limiting audit' will not be necessary if the
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original votes as cast are hand counted. Per title 52 USC 1031o(c) (1) - The
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terms "vote" or "voting" shall include all action necessary to make a vote
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effective in any primary, special, or general election, including, but not limited
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to, registration, listing pursuant to this chapter, or other action required by

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law prerequisite to voting, casting a ballot, and having such ballot counted

properly and included in the appropriate totals of votes cast with respect to

candidates for public or party office and propositions for which votes are

received in an election.

THEREFORE, the Petitioner asks:

(a) That, this honorable Court set a hearing as soon as possible and direct

Respondents to appear before this Court and show just cause why the demands
of the Petitioner should not be granted; And That, due to imminent irreparable

harm to the qualified electors of Columbia County and the state of Georgia, time

is of the essence;

(b) That, this honorable Court restrain and enjoin Respondents from the

ability to use the electronic voting system tabulators;

(c) That, this honorable Court direct Respondents to hand count, under the

supervision of an equal number of bi-partisan poll watchers, all votes on the

original cast ballots;

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(d) That, this honorable Court direct Respondents to remove the original

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ballots cast during early voting from the tabulators so the votes on these ballots
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can be counted as cast and intended by the qualified elector; And That, any early
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voting ballots that are cast from this point until the end of early voting be treated
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the same;
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(e) That, this honorable Court direct Respondents to hand count votes as
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intended by the qualified elector on any and all mailed in ballots, absentee

ballots or provisional ballots that have gone through the verification and

validation process; And That, these ballots are not to be processed via the

electronic tabulators;

(f) That, this honorable Court make findings of fact and conclusions of law

concerning the issues in this case;

 (g) That, Petitioner have such other and further relief as this honorable

Court may deem just and proper; And That, this honorable Court award

Petitioner costs for having to bring this action;

(h) That, the Respondents be served a copy of this Petition and Ex Parte

Restraining Order as is required by law;

(i) That, this honorable Court enjoin and restrain Respondents from

destroying, encumbering, secreting, or otherwise disposing of or removing from

the jurisdiction of this Court any and all election documents;

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(j) That, this honorable Court issue this Ex Parte Temporary Restraining

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Order, to protect the rights of qualified electors of Columbia County and the
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state of Georgia to cast their vote and have it accurately counted as is protected
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by the Constitution( s) and the laws of the state of Georgia, and to ensure the
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accuracy and integrity of our elections, until the original Petition for Declaratory
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Judgment and Injunctive Relief can be heard.

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Respectfully submitted,

Krien Lovell, Petitioner Pro Se

4140 Saddlehorn Drive
Evans, GA 30809
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Exhibit A

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 ColumbiaCo. GA
Untitled
May 24/2022 17:14:09 Scanner Current sensor state PSl[off] PS2[off]
PS3[off] PS4[off] PS5[off] PSDV(off] PSDSD[off]
May 24/2022 17:14:10 ScanVote Actual scanning of ballot failed with
error [46023].
May 24/2022 17:14:10 ScanVote Audit Scanner transport error.
May 24/2022 17:14:10 ScanVote Ballot has been reversed.
May 24/2022 17:14:19 Security Error QR code Signature mismatch.
May 24/2022 17:14:19 ScanVote Warning + Ballot format or id is unrecognizable.
May 24/2022 17:14:20 ScanVote Ballot has been reversed.
May 24/2022 17:14:35 ScanVote Ballot 179 processed successfully.
May 24/2022 17:14:35 ScanVote Total number of ballots= 484.
May 24/2022 17:14:59 ScanVote Ballot 179 processed successfully.
May 24/2022 17:14:59 ScanVote Total number of ballots= 485.
May 24/2022 17:17:03 ScanVote Scan error (Err t5654), ioctl returns 0,
errno: 5.
May 24/2022 17:17:03 ScanVote Motor steps: 471, max MotorSteps: 470
May 24/2022 17:17:03 ScanVote Table: 0, current index: 2
May 24/2022 17:17:03 Scanner Current sensor state PSl[on] PS2[on]
PS3 [off] PS4 (off) PSS [off] PSDV[off] PSDSD(off]
May 24/2022 17:17:03 ScanVote Actual scanning of ballot failed with
error [460221.

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May 24/2022 17:17:03 ScanVote Ballot's size exceeds maximum expected

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ballot size.

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May 24/2022 17:17:03 ScanVote Ballot has been reversed.

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May 24/2022 17:17:08 ScanVote Warning + error, crop top image (top edge)
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average=l52 length~l31 height=2458 O
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May 24/2022 17:17:08 ScanVote Warning + error, crop top image {top edge)
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aver•ge=152 length=l31 height=2458

May 24/2022 17:17:08 ScanVote Warning + Ballot format or id is unrecognizable.
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May 24/2022 17:17:10 ScanVote Ballot has been reversed.

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May 24/2022 17:17:26 ScanVote Ballot 168 processed successfully.

May 24/2022 17:17:26 ScanVote Total number of ballots= 486.
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May 24/2022 17:18:15 ScanVote Ballot 179 processed successfully.

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May 24/2022 17:18:15 ScanVote Total number of ballots= 487.

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May 24/2022 17:19:31 ScanVote Ballot 168 processed successfully.

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May 24/2022 17:19:31 ScanVote Total number of ballots= 488.

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May 24/2022 17:21:38 ScanVote Ballot 168 processed successfully.

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May 24/2022 17:21:38 ScanVote Total number of ballots= 489.

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May 24/2022 17:22:41 ScanVote Ballot 168 processed successfully.

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May 24/2022 17:22:41 ScanVote Total number of ballots= 490.

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May 24/2022 17:23:50 ScanVote Ballot 168 processed successfully.

May 24/2022 17:23:50 ScanVote Total number of ballots= 491.
May 24/2022 17:25:03 ScanVote Ballot 168 processed successfully.
May 24/2022 17:25:03 ScanVote Total number of ballots= 492.
May 24/2022 17:25:46 ScanVote Ballot 168 processed successfully.
May 24/2022 17:25:46 ScanVote Total number of ballots= 493.
May 24/2022 17:26:40 ScanVote Scan error {Err #5652), ioctl returns 0,
errno: 5.
May 24/2022 17:26:40 ScanVote Motor steps: 270, max MotorSteps: 2000
May 24/2022 17:26:40 ScanVote Table: 2, current index: 1
May 24/2022 17:26:40 Scanner Current sensor state PSl[off] PS2[off)
PS3[offJ PS4[off} PSS[off) PSDV[off] PSDSD[off]
May 24/2022 17:26:41 ScanVote Actual scanning of ballot failed with
error (460231.
May 24/2022 17:26:41 ScanVote Audit Scanner transport error.
May 24/2022 17:26:41 ScanVote Ballot has been reversed.
May 24/2022 17:26:58 ScanVote Ballot 168 processed successfully.
May 24/2022 17:26:58 ScanVote Total number of ballots= 494.
May 24/2022 17:27:56 ScanVote Ballot 179 processed successfully.
Page 66
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Exhibit B

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 Kevin M. Moncla David Cross
824 Lake Grove Drive 4805 Spring Park Circle
Little Elm, TX 75068 Suwanee, GA 30024
469-588-7778 678-925-6983
[email protected] DCross [email protected]

October 11, 2022

Georgia State Election Board Mrs. Sara Tindall Ghazal

2 MLK Jr. Drive [email protected]
Suite 802 Floyd West Tower
Atlanta, Georgia 30334 Mr. Edward Lindsey
[email protected]
Judge William Duffey Jr.
[email protected] Ex officio:
Mr. Brad Raffensperger
Mr. Matt Mashburn Secretary of State

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[email protected] 214 State Capitol

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Atlanta, Georgia 30334

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Dr. Jan Johnston
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[email protected] O
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VERIFIED NOTICE AND DEMAND FOR EMERGENCY REVIEW

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Members of the board:

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Kevin Moncla and David Cross, hereinafter "complainants", are submitting this Official
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Notice and Demand for Emergency Review regarding deficiencies discovered with
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Georgia's Dominion Democracy Suite 5.5A(GA) election equipment. These problems are
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consistent with that found last year in Williamson County, TN, and confirmed by the
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Election Assistance Commission (EAC) as further explained below. Following this

incident, Williamson County immediately suspended use of Dominion voting systems and
replaced the machines with those of another manufacturer.

Those same anomalies, among others, have been witnessed in several separate incidents and
the same errors have been documented in 65 of the 67 counties, some 97%, across the state
of Georgia. We have evidenced these specific problems having occurred during the 2020
general election and again during the recent 2022 primaries. Without intervention, the
material effect on mid-term election contests and the risk of disenfranchisement of hundreds
of thousands of Georgia voters is imminent.
Therefore, we are seeking Immediate Emergency Review by the Georgia State Election
Board, and for cause state as follows:
Two issues have been found in 65 of the 67 counties from which we've been able to obtain
the requisite records:
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1. The same "QR code signature mismatch" and "Ballot format or ID

unrecognizable" error pair has been found across the state of Georgia as
that evidenced as the triggering event of the anomaly in the EAC's
investigation into the Williamson incident.
2. Tabulator ballot reversal attributed to error, followed by the same ballot
being subsequently accepted by the scanner. In other words, when a
voter attempts to scan their ballot, the scanner returns it to the voter, but
then accepts it. This sequence is found in tandem with the error pair
detailed in number 1 above and is consistent with that found by the
EAC's Williamson incident investigation. Our investigation has revealed
the same rejected-then-accepted pattern occurring in concert with several
other errors, and at an alarming volume affecting approximately 20% of
all ballots cast from across the state of Georgia.
The deficiencies noted above are also associated with several instances in which ballots
were found to be scanned by the tabulator but not reflected in the tabulator count. This too

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is consistent with the manifestation of the anomaly as found with the Williamson incident.

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This bears repeating. The anomalies have not only been identified by locating the same

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errors in common with the Williamson Incident, but have also been realized by the
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discovery of ballots having been scanned but not included in the tabulator results:
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A. Dekalb County, 2022 Primaries- Hand-count revealed approximately

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2800 ballots which had been scanned but votes were not included in the
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tabulator results.
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B. Gwinnett County, 2020 General Election- Approximately 1600 ballots

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were scanned but not included in the tabulator results.

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C. Floyd County, 2020 General Election- Hand-count found approximately

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2800 ballots which were scanned but not included.

Additionally, complainants have also found the same error pair in Coffee County for the
2020 general election. This is significant as the irregularities witnessed by county election
officials are consistent with those found in conjunction with the Williamson Incident.

THE WILLIAMSON INCIDENT

On October 26, 2021, a municipal election was held in Williamson County, Tennessee. An
astute poll watcher meticulously documented the happenings at one of the polling locations
as the polls closed. Poll workers began their reconciliation process which included hand-
counting the paper ballots and comparing it to the number of ballots cast as reported by the 2
tabulators. One tabulator had 163 paper ballots but the poll closing tape only showed 79
ballots counted. The second tabulator contained 167 paper ballots and the corresponding
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poll closing tape showed only 19 ballots had been counted.

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At one polling location, 330 ballots were scanned, and only 98 ballots were counted. The
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same scenario repeated itself in several polling locations, with 7 of the 18 tabulators having
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scanned significantly more ballots than those counted.

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This led to the Secretary of State performing their own investigation where they were able to
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repeat the anomaly but could not find the cause. The EAC performed an investigation on
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site, and after multiple rounds of testing were able to associate the error which was
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triggering the anomaly (A true and correct copy of the EAC's report is attached hereto as
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"Exhibit A"). From the EAC's report:

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Analysis of audit log information revealed entries that coincided with the
manffestation of the anomaly; a security error "QR code signature mismatch" and
a warning message "Ballot format or id is unrecognizable" indicating a QR code
misread occurred. When these events were logged, the ballot was rejected.
Subsequent resetting of the ICP scanners and additional tabulation demonstrated
that each instance of the anomaly coincided with the previously mentioned audit
log entries, though not every instance of those audit log entries resulted in the
anomaly.
Further analysis of the anomaly behavior showed that the scanners correctly
tabulated all ballots until the anomaly was triggered. Following the anomaly,
ballots successfully scanned and tabulated by the JCP were not reflected in the
close poll reports on the affected ICP scanners.

The EAC report then states:

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"The direct cause of the anomaly was inconclusive."

This statement, as admitted in the conclusion of the EAC's report, frames the scope of this
problem. The EAC is admitting that they do not know what caused the Dominion voting
machines not to count ballots. Even so, the EAC defers to Dominion:

On Febrnary 11, 2022, Dominion submitted a Root Cause Analysis (RCA) to the EAC.
The report indicates that erroneous code is present in the EAC certified D-Suite 5.5-B
and D-Suite 5.5-C systems. The RCA report states that when the anomaly occurs, it's
due to a misread of the QR code. ff the QR code misread affects a certain part of the
QR code, the ICP scanner mistakenly interprets a bit in the code that marks the ballot
as provisional. Once that misread happens, the provisional flag is not properly reset
after that ballot's voting session. The result is that every ballot scanned and tabulated
by the machine after that misread is marked as provisional and thus, not included in
the tabulator's close poll report totals.

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The first problem with the paragraph above is that Dominion indicates:

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" .. .erroneous code is present in the EAC certified D-Suite 5.5-B and D-Suite 5.5-C
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systems."
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There is no explanation or definition of erroneous code, nor how it got there. Was it
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malware? Second is Dominion's claim that the anomaly is:

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" ... due to a misread of the QR code, the ICP scanner mistakenly interprets a bit
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in the code that marks the ballot as provisional. "

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A QR code has a signature or checksum within the code itself. In other words, the QR code
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contains a mathematical validation method. Therefore, a QR code is either read or it isn't,

but it cannot be misread. This fact alone, asserting an impossibility, negates that which
Dominion's Root Cause Analysis identified as the root cause.
Third, tabulators do not scan provisional ballots, at least not in the United States. A
provisional ballot is one that is held subject to a deficiency being cured and is always a hand
marked paper ballot- with no QR code. A provisional ballot is customarily placed in an
envelope and addressed by election officials after the polls close. If the deficiency is cured
then the ballot is no longer a provisional ballot, rather just a ballot, and can be scanned as
such. The provisional "feature" or option is one that we now know exists. The same can be
easily exploited to essentially hide or "stuff the ballot box" by using the flashcard's
provisional folder, which the Williamson Incident has taught us, is effectively hidden from
the tabulator and poll workers.
The EAC's report goes further to explain how Dominion addressed the deficiency:
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Dominion has submitted Engineering Change Orders (ECO)s for the JCP software in
the D-Suite 5.5-B and D-Suite 5.5-C systems: ECO 100826 and ECO 100827. Modified
ICP source code was submitted by Dominion that resets the provisionalflagfollowing
each voting session.

Here the EAC says that Dominion modified the source code to reset the provisional flag
presumably after each ballot is scanned. This does not address the cause which has not been
identified and does not prevent a ballot being erroneously flagged as provisional and then
sent to the provisional folder. Dominion's code only resets the flag, yet there should be no
function on a U.S. voting machine which allows for the flagging or segregation of
"provisional ballots". The presence of that code and functionality presents a hazard to the
integrity and accuracy of elections.
Lastly, the EAC's report concludes with the following:

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The analysis and testing of the ECOs has demonstrated that the anomaly was

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successfully fixed. No instance of the anomaly or the associated error or warning
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messages in the JCP audit logs were observed during the testing. The EAC has
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approved ECO 100826 and ECO 100827 on March 31, 2022.

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Nearly as stunning as the EAC's admission that the direct cause of the anomaly was
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inconclusive, is the statement on the very same page that the anomaly was successfully
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fixed. The contradiction, "We don't know what caused it, but it's fixed" wouldn't be
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acceptable coming from a car mechanic, much less the Election Assistance Commission
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addressing the systems (critical infrastructure) which tally our votes.

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Another interesting point which was discovered during the EAC's investigation but has not
been addressed is the fact that this anomaly suspiciously caused the tabulator's protective
counter not to increment. 1 The protective counter is a legally required meter which counts
every ballot scanned, including test ballots, for the life of the tabulator. Like a car's
odometer, the protective counter cannot be suspended, manipulated, or reset and is coded to
the hardware of the machine; however, this anomaly somehow caused the protective counter
not to count the ballots being scanned when the corresponding ballot images were hidden in
the provisional folder.
Said another way, the security feature used to reconcile the number of ballots scanned by a
tabulator was disabled during the same event that hid ballots and prevented the tabulator
from counting them. That's two separate counters, controlled by two separate mechanisms
(software and hardware) both suppressed in tandem by functionality not used in the United
States.

1
See Engineering Change Order Analysis Form attached hereto as "Exhibit B".
Page6

Also, important to note is that the erroneous code and errors both survived Logic and
Accuracy Testing across seven tabulators.
Lastly, if the "erroneous code" was not due to malware and was a mistake by Dominion's
programmers, then how did it survive certification testing? This would also suggest that the
"erroneous code" could have affected several past elections in these various locales
unbeknownst to anyone. Dominion claims it only affected Democracy Suite 5.5B and 5.5C,
but doesn't state from what point in time.

The significance of the Williamson Incident is not only its direct and instant effects, but it
has also established the fact that a ballot has the capacity to alter the behavior of the
tabulator, including how and which votes are counted. Both Dominion and the EAC have
acknowledged this fact by affirming that the anomaly was triggered by the scanning of a QR
code. This capacity alone is clearly a threat to the integrity of the voting systems and thus
our critical infrastructure because it demonstrates the self-evident risk that covert,
undetected or untested functionality may be present and triggered by unauthorized parties.

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QR CODE SIGNATURE MISMATCH IN GEORGIA
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Despite Dominion's assertion that the anomaly was limited to Democracy Suite 5.5B and
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5.5C, it has now been confirmed to exist in the software version used in Georgia's
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Democracy Suite 5.5A. Complainants have acquired the Dominion Image Cast Precinct
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(tabulator) system log files showing the same error pair as that of the Williamson Incident in
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64 of the 66 counties for which they have obtained records. (See the tabulator System Log
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file for each county with the corresponding error pair for each of the 64 counties, attached
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hereto as "Exhibit C").

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Additionally, the same QR Code signature mismatch error is not limited to the ICP but has
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now been confirmed with the Image Cast Central (ICC) tabulator as well.
The Williamson Incident was uncovered through the reconciliation process at the polling
location. Specifically, the poll workers counted the number of paper ballots then compared
that number to the poll closing tape of the scanner and the discrepancy was revealed.
Georgia has no such process for early voting as the tabulators are not closed until after the
polls close on election night, and not by the early voting poll managers, but by third parties.
Therefore, there is no way by which any discrepancy could be uncovered. Furthermore, we
have previously documented the early-voting tabulator closing process practiced in several
counties was devoid of any reconciliation whatsoever and in violation of nearly all Rules
and Regulations defining the same. 2 Because of the lack of basic election accounting, both
by design and practice, it becomes clear there is essentially no way such a phenomenon

2
See Official Complaint submitted to the Georgia State Election Board (SEB) regarding tabulator closing protocol
attached hereto as "Exhibit D".
Page 7

could be caught in Georgia as it was in Williamson County, Tennessee during the normal
conduct of an election.

There are several documented incidents in Georgia that are consistent with the Williamson
Incident in that ballots were scanned by the tabulator, but not counted by the tabulator.
Important to note that these were discovered by happenstance. Three such incidents are
detailed below:

DEKALB 2022 PRIMARIES

After the results came in, Michelle Long Spears, Candidate for the May 24th Dekalb County
Commission 2 race, found herself in 3rd place and seemingly out of the run-off. Spears
demanded a hand-count after several precincts showed that she had received zero votes,
including her own precinct where she and her husband had cast votes for her. The hand-

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count revealed that she not come in last, but that she had won. The error in counting was

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purportedly caused by tabulators not being properly updated when a candidate had dropped

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out of the race- causing votes to be attributed to the wrong candidates. This same scenario
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was said to have caused the problem in Antrim County, Michigan during the 2020 General
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Election in which Joe Biden erroneously received several thousand votes which voters had
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actually cast for President Trump. Yet this software deficiency remains.
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In addition to votes being credited to the wrong candidate in Dekalb, the hand count also
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revealed approximately 2,810 ballots that had been scanned by the tabulators, but not
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counted by the tabulators. The candidate-removed-from-the-ballot theory may explain the

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misattributed votes, but does not explain the 2,810 additional uncounted votes. An article 3
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covering the issue states:

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"The press release does not explain the large discrepancy between the machine
count on Election Night and the subsequent hand count. It also doesn 't explain the
appearance of 2,810 more votes cast than were initially reported."
Indefensibly, the uncounted ballots are not addressed nor explained; however, the Dekalb
County tabulator System Log files from the May primaries reveal the presence of the same
"QR code Signature mismatch" error pair as that which the EAC found triggered the
Williamson Incident anomaly:

May 26/2022 20:02:21: Ballot 38: Id=464, 465 Cast.

May 26/2022 20:02:21: Security Error OR code Signature mismatch.
May 26/2022 20:02:21: ScanVote Warning + Ballot format or id is unrecognizable.
May 26/2022 20:02:21: Ballot 39: - Problem Ballot - saved as C:\DVS\Ashford

3
Hand count in District 2 DeKalb Commission race changes runoff picture - Decaturish - Locally sourced news
Page 8

While there may be another explanation than the cause and effect consistent with the
Williamson Incident for the uncounted ballots, there is not one which can be found in the
public record and no matter the cause, the deficiency remains. The post-election discovery
of 2,810 uncounted votes further establishes that no effective reconciliation, accounting, or
canvass process exists to protect the integrity of elections in Georgia, for if it did then the
same would have revealed a discrepancy and the fact that votes were missing from the
count.

FLOYD COUNTY 2020 GENERAL ELECTION

Following the 2020 General Election, the Georgia Secretary of State, Brad Raffensperger,
ordered a hand count of all paper ballots. During the course of the hand count, several

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counties found ballots which were not included in the November 3rd results. In all incidents,

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the uncounted ballots were attributed to flashcards that had not been uploaded or included in

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the results. Floyd County was one where approximately 2,700 ballots were not included in
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the November 3rd results, but despite reports to the contrary, the uncounted ballots were not
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due to an unreported flashcard.

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An astute investigative journalist and reporter, Heather Mullins, chronicled the incident in
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real-time. 4 In an interview with Floyd County election officials and Dominion technicians
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present, Mullins directly asks if the discrepancy could be caused by a flashcard that wasn't
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uploaded. The official says "No, they have ruled out a flashcard". He goes on to say that
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they don't know why the ballots weren't counted. The Floyd County tabulator System Log
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files show the presence of the same "QR code signature mismatch" error pair as that which
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the EAC found triggered the Williamson Incident anomaly:

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Nov 30/2020 14:32:18: Security Error OR code Signature mismatch.

Nov 30/2020 14:32:18: ScanVote Warning + Ballot fonnat or id is unrecognizable.
Nov 30/2020 14:32:18: Ballot 47: - Problem Ballot - saved as C:\DVS\ICC
advanced\Project\NotCastimages\NotCast_038_001_002.tif.

While there may be another explanation than the cause and effect consistent with the
Williamson Incident for the uncounted ballots, there is not one which can be found in the
public record and no matter the cause, the deficiency remains. The report of uncounted
ballots and/or outstanding flashcards further establishes that no effective reconciliation,
accounting, or canvass process exists to protect the integrity of elections in Georgia, for if it

4
( 1) Heather Mullins on Twitter: "Floyd County, GA: After a FULL day of rescanning, counting, &

software techs troubleshooting, election officials (while VERY transparent), still had NO answer as to
what caused 2700 votes to go uncounted. Dominion techs said they could not comment. Listen to this!
@RealAm Voice https://t.co/v6j91MatXH" / Twitter
Page 9

did then the same would have revealed a discrepancy and the fact that ballots were missing
from the count.

GWINNETT COUNTY 2020 GENERAL ELECTION

A Declaration filed by Marilyn Marks in the Curling V. Raffensperger case describes a

problem witnessed by Ms. Marks during the 2020 General Election count in Gwinnett
County. 5 Specifically, Marks states:

12. During the November 3, 2021 election, Harri Hursti and I visited Gwinnett
County Electionsfor several hours on multiple days as they were having significant
problems with the Dominion server processing certain batches of scanned ballot
images uploaded on precinct scanner memory cards. County officials disclosed in
public announcements that several thousand ballots (tens of thousands of votes) in
the batches could not be processed. Mr. Hursti and I watched Dominion

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technicians make repeated unsuccessful efforts to process the ballots.

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13. A Dominion technical expert, David Moreno, was flown in from Denver to
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attempt to remedy the vote tabulation problem, County spokesman Joe Sorenson
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repeated explained that ballots were simply failing to be processed by the system,
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and that thousands of ballots were caught up in thefailure.

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14. Based on contemporaneous discussions with Mr. Hursti, who was watching Mr.
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Moreno's actions and computer screens, it appeared that that Mr. Moreno made
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software code changes in real time to circumvent the problem to force the system to
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process most, but not all, of the uncounted ballots. After most of the ballots were
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processed and counted, Gwinnett quickly closed and certified the election. I
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estimated that at the time the election was certified at least 1,600 ballots remained
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uncounted. I asked county officials repeatedly, in emails and on site, for an

accounting of these ballots, but received no response.

15. A few days later a statewide hand count audit of the presidential race was
conducted. I was an authorized monitor of the audit process in several counties
including Gwinnett. According to the audit summary published by the Secretary of
State, attached hereto as Exhibit 1, during the audit Gwinnett discovered 1,642
more ballots than were originally counted. This confirmed my belief that over
1,600 ballots had not been counted even after Dominion made real time software
changes and the Gwinnett Board of Elections certified the result.

Marks meticulously details the fact that there were 1,642 more ballots than originally
counted " ... even after Dominion made real time software changes and the Gwinnett Board

5
See a true and correct copy of the referenced Declaration by Marilyn Marks attached hereto as "Exhibit E".
Page 10

of Elections certified the result.". The tabulator System Log files from the Gwinnett County
General Election reveal the same "QR code signature mismatch" error pair as that which the
EAC found triggered the Williamson Incident anomaly:
Nov 04/2020 13:32:44: Security Error QRcodeSignab1reroisroat:cb
Nov 04/2020 13:32:44: ScanVote format
Warning+ Ballot or id iSunrecognizable.
Nov04/2020 13:32:44:Ballot 40: - Problem
Ballot- savedas C:\DVS\Nov2020 AV-Shorty
HowellICC2B 79-156\Project\Not:Cast:Images\NotCast_001_002_001.tif.

While there may be another explanation than the cause and effect consistent with the
Williamson Incident for the uncounted ballots, there is not one which can be found in the
public record and no matter the cause, the deficiency remains. The outstanding ballots
further establish that no effective reconciliation, accounting, or canvass process exists to
protect the integrity of elections in Georgia, for if it did then the same would have revealed a
discrepancy and the fact that ballots were missing from the count.

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Furthermore, if the anomalous results described herein are somehow found to be not exactly

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the result of that which caused the Williamson Incident (which would be difficult given that

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the cause has not been identified) the same must be investigated to conclusion as the same
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symptoms are present and have been specifically documented in several incidents in several
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counties.
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It's also worth noting that Ms. Mark's Declaration indicates the alteration of software code
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within a previously certified voting system in real-time during its operation for an election
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in violation of Georgia election code. The actions Marks described clearly violated the
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voting system certification and all use of that system should have been immediately halted
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and further use prohibited until such time as the system could be brought back into
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compliance and properly tested.

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OTHER ERRORS
Although the "QR code signature mismatch", along with the "Ballot format or ID
unrecognizable" pair were the only errors acknowledged by Dominion and the EAC to
affect the tabulator counting process, there are several other errors potentially yielding the
same result.
When the tabulator produces an error, the ICP "reverses" or returns the ballot to the voter.
Aside from a genuine mechanical or folded paper error, the ICP should reverse the same
ballot for the same error no matter how many times the ballot is scanned (within acceptable
tolerances). For example, A "QR code signature mismatch" error should be reversed on the
second, third, and 25 th attempt; however, the logs and corroborating reports reveal that
ballots are being reversed on the first attempt but accepted on the second or subsequent
scanning attempts. This too is consistent with what the investigations by the Tennessee
Secretary of State and the EAC found in Williamson, TN as it was found that the ballot that
triggered the anomaly was initially reversed due to error, but subsequently accepted.
Page 11

Because the same ballot which initially triggers an error causing it to be reversed is
subsequently accepted, evidence strongly suggests that either the error as initially returned is
not really an error, or the voting system is grossly inaccurate. Complainants have effectively
ruled out inaccuracy as the same pattern repeats itself in county after county thousands of
times. The ballot is scanned and then reversed due to an error, followed by the ballot being
accepted seconds later with no error.
What's more, we have been able to identify the exact ballots which triggered various errors
as each time an error is generated, the ballot is reversed and the image of the deficient ballot
which triggered the error is placed in the ''Not Cast Images" folder. For example, the
tabulator log file below shows that a ballot was reversed due to the error "Image scan could
not find QR code on ballot" and an image of the "problem ballot" is saved.

Nov 25/2020 17:57:26: Ballot 28: Id=3 Cast.

Nov 25/2020 17:57:26: Ballot 29: ld=3 Cast.
Nov 25/2020 17:57:27: Imaoe Wami ma e scan could not find eon ballot.

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Nov 25/2020 17:57:27:

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Nov 25/2020 17:57:27: Ba ADVANCE

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\"L .... vv,

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VOTING\Project\NotCastlmages~NotCast 057 001 001.tif.

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Nov 25/2020 17:57:27: Nov 25/ 020Ballot 31: skipped.
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The image of the problem ballot, named ''NotCast_ 057_001_001.tif' is shown below:
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Page 12

BIBB COUNTY
OFFICIAL BALLOT
GENERAL AND SPECIAL ELECllON
OF THE STATE OF GEORGIA
NOVEMBER3. 2020
•tundBISlandIha/ I/NJolfsr or BCC9p/anctJof mon.y or any othtJrobjtJd of valw to ~ for any pat1icularCllndidaltl,
list of candida/N, issw, or list of is8uH includfld in this MC/ion conslitufN an act of voltlr fraud and is a felony
undtlrGtlotgialaw."/0.C.G.A. 21-2-2U{t1), 21-2-285(h) and 21-2-38:J(a)/

S03-EM4

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For President of the United States (Vote For State RepresentativeIn the General Constitutional Amendment #2 (NP)
for One)(NP) O
Assembly From 143rd District (Vote for Vote for YES
YD
Vote for Joseph R. Biden (Dem) One)(NP)
Vote for James Beverly(I) (Dem) Statewide Referendum A (NP)
AC

For United States Senitte(Perdue) (Vote Vote for YES

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for One) (NP) For District Attorney of the Macon Judicial

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Vote for JonOssoff (Dem) Circuit (Vote for One) (NP)

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Vote for Anita Reynolds Howard

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For United States Semite (Loeffler) - (Dem)

Special (Vote for One) (NP)
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Vote fOf Raphael Warnock (Dem) For Clerk of superior Court (Vote for One)
M

(NP)
O

For Public ServiceCommissioner (Vote Vote for Erica L. Woodford (I)

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for One) (NP) (O.m)

Vote for Robert G. Bryant (Dem)
D

For Sheriff (Vote for One) (NP)

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For Public ServiceCommissioner (Vote Vote for David Davis (I) (Dem)
for One) (NP)
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Vote for Daniel Blackman (Dem) For Tax Commissioner (Vote for One) (NP)
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Vote for S. Wade McCord (I) (Dem)

ET

For U.S.Representative in 117th Co~s

From the 2nd Congressional District of For Solicitor of State Court of Macon-Bibb
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Georgia (Vote for 0-ne) (NP) County (Vote for One) (NP)
Vote for Sanford Bishop (I) (Dem) Vote for RebeccaLIies Grist (I)
(Dem)
ForStateSenatorFrom26th District
(Votefor One)(NP) ConstitutlonalAmendment#1 (NP)
Votefor DavidE. Lucas.Sr.(I) Vote for YES
(Dem)

1/1

.------,

The QR code is clearly visible and is in exactly the correct position on the ballot. Also, the image
is crisp with no visible deficiency whatsoever. It's important to note that the same imaging
devices which capture the image also read the QR code. This removes the possibility that dirt,
ink or dust caused the error. For if it did, the image above would reflect the deficiency, as that is
the very image the tabulator read and reversed. Therefore, if that very ballot image was scanned
Page 13

it should return the very same error, but it does not.

Complainants scanned the ballot image using the very same third-party QR code software that
Dominion tabulators are supposed to use to read QR codes 6 which is available online at
www.zxing.org. The image that was reversed due to error scanned successfully:

~ Decode Succeeded

Raw text

Raw bytes tje000aa0000~ ~000000a~0000

00 e0 00 80 04 ~ 00 02 22 2a as 55 00 00 0d 02
lf 29 cf de 65 ed a9 a9 aa 69 71 b2 11 3a 52 80
38 27 dd 86 85 e9 53 c5 4b 0e a4 a2 ea Se 19 a0
ec 11 ec 11 ec 11 ec 11 ec 11 ec 11 ec 11 ec 11
ec 11 ec 11 ec 11 ec 11 ec 11 ec 11 ec 11 ec 11
ec 11 ec 11 ec 11 ec 11 ec 11 ec 11 ec 11 ec 11
ec 11 ec 11 ec 11 ec 11 ec 11 ec 11

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Barcode format QR_COOE

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Parsed Result TEXT

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Type

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The same software that Dominion tabulators use to read QR codes was not only able to find the
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QR code but also read and decode it successfully. This shows that no actual error condition
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existed at the time it was scanned because the image above is the actual image that triggered the
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error.
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The following is another example. The System Log file shows a ballot was rejected due to a
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"QR code Signature mismatch" error (same error that the EAC named as triggering the anomaly
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in the Williamson Incident).

6See Dominion Democracy Suite 5.5A software configuration as tested on pg. 19 of the "As Run Test Plan" located
here: *VVSG 2005 Cert Test Plan (eac.gov)
Page 14

The image of the problem ballot listed in the log above, ''NotCast_067 _001_001.tif' that was
rejected due to the "QR code Signature mismatch" error is shown below:

BIBB COUNTY
OFFICIALBALLOT
GENERALAND SPECIALELECTION
OF THE STATEOF GEORGIA
NOVEMBER3, 2020
"I 1117dwstand the olferor IICCfl/lllll1Ct
111111 of /110My or any olhflroqectof llfll1111to ..,_ lbr any ptllficular candirlalfl,
constilulNan llcf of llOltlrfnludand is a "1/ony
/isl of candidaln, issw, or /isl of bsutls includtld In this fJleclion
undtlrGtlo,gieA,w.•/0.CG.A. 21-2-2U{a). 21·2-285(h} and 21-2-383/a}J

510-HMA

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For President of the United States (Vote For State Representative In the General Constitutional Amendment #2 (NP)
R

for One) (NP) Assembly From 141st District (Vote for Vote for YES
C

Vote for Oon1ld J. Trump (l)(Rep) One)(NP)

O

Vote for Dale Washburn (I) (Rep) StatewideReferendum A (NP)

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For Unitad States Senate (Perdue) (Vote Vote for NO

for One) (NP) For District Attorney of the Macon Judicial
D

Vote for David A. Perdue (I) (Rep) Circuit (Vote for One) (NP)
M

Vote for Anita RtrynO!dsHOWlrd

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For United St.atesSenate (Loeffler) - (Dem)

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Special(Vote for One) (NP)

Vote for Doug Collins (Rep) For Clerk of Superior Court (Vote for One)
D

(NP)
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For Public ServiceCommissioner (Vote Vote for Erica L Woodford (I)

for One) (NP) (Dem)
IE

Vote for JasonShaw (I) (Rep)

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For Sheriff (Vote for One) (NP)

ET

For Public ServiceCommissioner (Vote Vote for J. T. Ricketson (Rep)

for One) (NP)
R

Vote for LaurenBubba For Tax Commissioner (Vote for One) (NP)
McDonald,Jr. (I) (Rep) Vote for S. Wade McCord (I) (Dem)
For U.S.Representative In 117th Congress For Solicitor of State Court of Macon-Bibb
From the 2nd Congressional District of County (Vote for One) (NP)
Georafa(Vote for One) (NP) Vote for RebeccaLilesGrist (I)
Vole for Don Cole (Rep) (Dem)

For State Senator From 18th District Constitutional Amendment#1 (NP)

(Vote for One)(NP) Vote for NO
Vote for John F. Kennedy (I) (Rep)

1/1
Page 15

Complainants once again used the www.zxing.org website and the same software used by
Dominion to read the QR code ballot. The very ballot image that was rejected due to a QR code
signature mismatch error, was somehow successfully decoded using the very same software.

~ Decode Succeeded

Raw text

Raw bytes o~oo~~oooo~ ~oooooou~oooo

00~00~~~0000 ~~~~~0000~
52 74 57 e9 ae 97 84 73 de 3f b8 84 f2 d4 e7 3b
d0 6b ad 53 ca 66 ca 7c lb 3f f4 87 b0 6c a6 20
ec 11 ec 11 ec 11 ec 11 ec 11 ec 11 ec 11 ec 11
ec 11 ec 11 ec 11 ec 11 ec 11 ec 11 ec 11 ec 11
ec 11 ec 11 ec 11 ec 11 ec 11 ec 11 ec 11 ec 11
ec 11 ec 11 ec 11 ec 11 ec 11 ec 11

Barcode format QR_COOE

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Parsed Result Type TEXT

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Parsed Result
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Again, a QR code is either read or it isn't read, but it cannot be misread. Complainants have
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tested hundreds of these ballot images reversed due to error and they are all read and decoded
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successfully.
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Because of this, complainants did an analysis on the number of ballots being reversed and why
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they were being reversed (The report and the breakdown for each county we evaluated is in a
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report attached hereto as "Exhibit F"). This analysis included 13 randomly selected counties and
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includes over 100,000 scanned ballots.

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Page 16

Georaia [)e,tailed Error R~ort Tot.ls

Total Counties·13
Totll System LoeFtts 175

Total Ballots Cast: 104,821

Av1:. Error Rate: 23.714%
Av1:.Reversal Rate: 18.601"

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3'
II .i 1, J.!I. if ]
I ..
County
Barrow
Election
202205:UGelPMI
....
Cllt
882.S 578 382
ERRORS
50 360 313 16IIS 19.075% 1243 22 1265 14.338%
Brantley 2112205:UGlllfrim 2ii18 239 163 18 111 145 676 25.821% 498 49& 19.022%
Bryan 2022 Oii 21 llunaff 123 80 46 6 29 16 177 24.481" 127 2 129 17.842%

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Burke 2022052•-- llS9 121 27 0 80 106 "4 26.957" 317 517 25.585%

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Coffee 45.sa 28 7 4 322 367 728 16.042" 717 717 15.800%

T.
- 2021 llunoll

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Crisp 21122052'6-- 8567 155 82 l 194 164 596 16.709% 517 517 14.494%

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Dawson
2022052'-- l96S 338 221 10 406 38S ~ 19.526% 1172 1172 16.827%
20220621- 2l6l5 111 67 19 185 91 O
"79 20.874" 407 407 17.961%
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Fayette 2022052.aGIIIPMI 32,7157 3592 2700 324 1427 1205 92-18 29.112 6261 8 6269 19.734
AC

Heard 2B2205UG111Pnlft 2152 111 62 3 108 118 402 18.85 345 MS 16.182
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Irwin 1916 367 282 38 147 179 101' 51.007" 690 3 693 34.894%
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2022 05 U Giil Prim

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Madison 202205UGIII- 293 162 17 297 324 .1093 15.845" 925 925 13.410%
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McDuffie 202205UC..,PMI 383 320 25 205 162 1095 26.733% 753 753
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Paulding 20uosz.aGMPM1 2319 1431 190 1106 1203 '249 4666 87 4153
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TOTALS 8715 5952 705 4977 4778 8638 122

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According to our review of the Dominion-produced tabulator system log files including over
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104,000 ballots, an average of 18.6% of all ballots are being initially reversed due to error.
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Nearly all ballots reversed are then subsequently accepted without error. The list of errors
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include:

1. Ballot Format or ID is unrecognizable

2. Image scan could not find QR code on ballot
3. QR code signature mismatch
4. Ballot's size exceeds maximum expected ballot size
5. Scanner transport error

Consider that in 13 counties, the tabulator could not find the QR code on ballot 5,952 times, but
then miraculously found the QR code when the ballot was scanned again. 7

This phenomenon is not isolated to one machine or one race, one county, or even one election.

7
The scanners are required to read the ballot no matter the orientation, scans both sides
simultaneously and the same has been tested out as a contributing factor.
Page 17

Ballots are being reversed across the state for all elections. Therefore, it is undeniable that the
ballots are being reversed for reasons other than errors.

These findings are not supposition, but factual analysis of records produced by Dominion
tabulators and provided by counties in response to Open Records Requests.

While it is unknown why ballots are being initially reversed due to error, then subsequently
accepted, there is an important reference point in Coffee County.

COFFEE COUNTY

According to Coffee County election officials and repeatedly documented in emails, text
messages and official correspondence, Coffee County experienced problems with their election
equipment beginning with the June 2020 primary. Despite numerous requests for help to the
Secretary of State, their pleas went unanswered. Following the November 3rd General Election,

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President Donald Trump requested a recount, the results of which Coffee County's Board of

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Elections unanimously refused to certify. As documented in correspondence to the Secretary of

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State8, the board stated:
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The Coffee County Board of Elections and Registration cannot certify the
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electronic recount numbers given its inability to repeatably duplicate creditable

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election results. Any system, financial, voting, or otherwise, that is not repeatable
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nor dependable should not be used. To demand certification of patently inaccurate

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results neither serves the objective of the electoral system nor satisfies the legal
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obligation to certify the electronic recount.

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I am enclosing a spread sheet which illuminates that the electronic recount lacks
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credibility. NO local election board has the ability to reconcile the anomalies
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reflected in the attached. Accordingly, the Coffee County Board of Elections and
Registration have voted to certify the votes cast in the election night report. The
election night numbers are reflected in the official certification of results submitted
by our office.

The spreadsheet attached to the correspondence is below:

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A true and correct copy of the Coffee County's correspondence to the Georgia Secretary of State is attached hereto
as "Exhibit G".
Page 18

DISCREPENCIES
IN THENOVEMBER3, 2020 GENERALELECTION
AND RECOUNTS
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Date Activity iAction N I Trull1) Bidell Jo'l!•nsen Wlite-lN• Total Votes lntemal Delta
ll/03/2020 Election Day1 I l 10578 4511 125 23 15237
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11/17/2020 Hand Recount 2 10578 4511 126 NA 15238
i Compare 2 to 1 \ 0 0 +l +1 •1
!
11/30/2020 Electronic Rerount 3 10597 4520 I 136 D 15258
Colll!)are 3 to 1 +19 +9 +11 +39
+--
Compare 3 to 2 +19 +9 +12 +40
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:Ind u piooded 185 NO NO NO II
11/30/2020 BALLOTS • O<ANGE OIANGE OiANGE 0
'
NOCHANGE

1hetabluatedEltctonlcRecount-~ lhe aboYedlscrapencies

rwestiptian revealedwe necelectl!d'> run 185 ballos: we then ran these ballots
we reviewed !he N!sullsbulthere-No 0..- Ill Vote CountDespite l&S BallotsAdded
Thieon Site Oomlnionlltp cowl not nplain wltv SI/Siemwouldnai: apdale vates
n. DomlnlllnRip lfnc11ed11wBaanlof Eletllonsto nice a decisionabout whal to do.
fOR SOMEltEASOtlI«) WIITE-IN COWMNPRINTED ONTHEUCDUNTSUMMARY
THERE WASNO EXPLANATION ORSOI.UTIONTOntlSPIDIUM

12/02/2020 Prepare to Certify I 5 10597 I 4520 I 5 I

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i 136 I 15258

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Compare 5 to l +19 +9 +11 +39

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Compare S to 2 ' +19 +9 +12 +JO

T.
Tnere is a discrepencv between Electronic Recount and total "Otes for both 1 & 2

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Stared Differently after 3 counts a clear inconsistency exists as one compares the O!iional electioo rounts, the hand rec0<.mt,and the electronic recount
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Anornlliesiruoftware recoumscreate irr«Ondable difference in .ote count wtich ie-s !he Boardwith ro clearguldanc~as ID whichcount lo aertlfy.
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• Write-IN an<!NO Votes art NOT included In the Total Votes

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Following additional problems associated with the January 5th , 2021 Senate runoff election, Jeff
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Lenberg, a computer systems expert 9 , went to Coffee County in an attempt to determine the
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cause of their voting system problems. Mr. Lenberg had the Elections Supervisor run a mock
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election (Mr. Lenberg had the Election Supervisor control the machines). An equal number of
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ballots were created for President Trump and Joseph Biden (20 each) which were then scanned
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several times on an ICP. Out of approximately 480 ballots scanned, 15% of Trump ballots were
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reversed due to error as opposed to only 2.5% of those ballots for Biden. In other terms, ballots
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were being reversed at a ratio of7:1, Trump to Biden.

Mr. Lenberg's findings support that which was witnessed in Coffee County by Cathy Latham on
January 5th 2021 Senate runoff after the polls closed. From Ms. Latham' s affidavit: 10

10. As everyone settled in for a long night in a very small room with a tabulation
computer, Ms. Hampton began pulling batches to begin scanning. As she put in the
first batch, the machine began scanning and then jammed on a ballot with the
following screen message: QR CODE Failure.

11. This continued, batch after batch, time after time. Dominion tech, Samuel
Challandes from Colorado, was an extra tech assigned to Coffee County after
scanner issue problems in the June 2020 Primary and November 3

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See Mr. Lenberg's Bio attached hereto as "Exhibit H".
10
See a true and correct copy of Cathy Latham's affidavit attached hereto as "Exhibit I"
Page 19

Presidential Election, and the machine recount. Mr. Challandes recommended to

Ms. Hampton that she needed to take a cloth and wipe down the scanner. At times
he advised and instructed her to blow canned air at the eye of the scanner to help
remove paper debris. This didn't help.

12. One thing that was noticed by Ms. Hampton, Mrs. Thomas-Clark, and me was
that every ballot that had a QR Code Failure was a ballot for all three Republican
candidates: David Perdue. Kelly Loefjler. and Bubba McDonald. At some point
during the evening of this, Mrs. Thomas-Clark looked over at me and said, "This
isn 't right. "I agreed with her.

Mr. Lenberg's testing is consistent with that witnessed by Ms. Latham and Coffee County
election officials, which is that ballots were being rejected in a clearly biased manner. The same
anomaly was also witnessed in Coffee County during the recount.

It's also important to note that the astute Coffee County Elections Supervisor, Misty Martin,

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details several important points as captured in the November 10, 2020 County Board of Elections

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meeting minutes: 11

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Mr. Chaney asked "So you can scan the same ballot two times, or multiple times.
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Mrs. Martin replied "Yes". Mr. Peavy said there are check points that have to
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match. Mrs. Martin replied 'yes there are several check points for the honest
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person, but the honest person is not in every county. Mrs. Martin also stated that
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"all counties do not have the same check points that I have in place. "Ms. Thomas-
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Clark asked "if you have a ballot and you ran it twenty times, the system would
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count it 20 times. " Mrs. Martin replied 'yes". Mrs. Martin said that during
advance voting the number on the scanner never matched the number of ballots
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voted.
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Mrs. Martin describes her practice of reconciling the number of physical ballots with the number
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of ballots cast as reported by the scanner, and that they "never matched''. Once again, and time
after time during early voting, when the number of ballots is compared with the number of
ballots cast as reported by the scanner, there seems to be a discrepancy just like that of
Williamson County.

CONCLUSION

Ballots are being reversed due to errors that are not truly errors, and in large numbers across the
state of Georgia. Election officials and independent experts have documented the reversals in
Coffee County not as random but based on the choice of candidates on the ballot. Because the
exact same equipment running the exact same version of software as that of Coffee County is

11
A true and correct copy of the Coffee County November I 0, 2020 meeting minutes is attached hereto as "Exhibit
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being used across the state, there is every reason to believe the other counties are experiencing
the exact same results. This is also bolstered by the errors and reversals that the complainants
have painstakingly documented and tracked from Dominion's own records from 67 counties
spanning 3 separate elections.
The only possible explanations for the error anomalies are defect, malware, or intentional design
with each yielding the same result, the continued disenfranchisement of voters.

In short, due to defect or deficiency the Dominion Voting systems currently being used in
Georgia cannot reliably perform their sole purpose and function. To accurately count votes.
Furthering this deficiency is Georgia's current lack of even the most basic election accounting
practices which could potentially detect or prevent any innacuracies.

WHEREFORE, Complainants respectfully ask this board:

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1. To grant relief in the form of immediately suspending the use of the

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Dominion Voting System, in its entirety, until such time as a thorough
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forensic review can be performed by an independent panel of experts to find
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the cause of the anomalies detailed herein.

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2. To compel and enforce compliance with existing Rules and Regulations

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governing the early voting ballot scanner poll closing protocols, specifically
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those requiring the reconciliation of each tabulator count with that of the
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ballot scanner recap sheets.

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3. To promulgate rules requiring the following during early voting:

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a. The daily reconciliation of the number of physical ballots scanned, the

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number of ballots cast according to the ballot scanner daily status tape,
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and the number of voters checked in at each polling location, certified

by the poll manager and two witnesses and submitted to the State
Election Board daily via email and posted on the county's website for
public review. The same should also have the automatic remedy of a
required hand count for any polling location that fails to comply as
required.
b. The names of all voters who checked in at each polling location,
certified by the poll manager and two witnesses, submitted daily to the
State Election Board via email. The same should also have the
automatic remedy of a required hand count for any polling location that
fails to comply as required.
4. Any other relief that this board deems proper to ensure the accuracy and
integrity of Georgia's elections.
Page 21

Respectfullysubmittedthis 11th day of October,2022 via email:

Kevin M. Moncla cx:::::::::::::

David A. Cross

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