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Case 2:20-cv-02321-DJH Document 1 Filed 12/02/20 Page 34 of 53<br />
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Commonwealth of Puerto Rico are voted for, all records and<br />
papers which come into his possession relating to any<br />
application, registration, payment of poll tax, or other act<br />
requisite to voting in such election, except that, when required by<br />
law, such records and papers may be delivered to another officer of<br />
election and except that, if a State or the Commonwealth of Puerto<br />
Rico designates a custodian to retain and preserve these records and<br />
papers at a specified place, then such records and papers may be<br />
deposited with such custodian, and the duty to retain and preserve<br />
any record or paper so deposited shall devolve upon such custodian.<br />
Any officer of election or custodian who willfully fails to comply<br />
with this section shall be fined not more than $1,000 or imprisoned<br />
not more than one year, or both.<br />
See 52 USC § 20701.<br />
3.Dominion Vulnerabilities to Hacking.<br />
91. Plaintiffs have since learned that the “glitches” in the Dominion<br />
system -- that have the uniform effect of hurting Trump and helping Biden -- have<br />
been widely reported in the press and confirmed by the analysis of independent<br />
experts, a partial summary of which is included below.<br />
(1) Users on the ground have full admin privileges to machines and<br />
software. The Dominion system is designed to facilitate vulnerability<br />
and allow a select few to determine which votes will be counted in any<br />
election. Workers were responsible for moving ballot data from polling<br />
place to the collector’s office and inputting it into the correct folder.<br />
Any anomaly, such as pen drips or bleeds, is not counted and is handed<br />
over to a poll worker to analyze and decide if it should count. This<br />
creates massive opportunity for improper vote adjudication. (Ex. 14<br />
Watkins aff. 8 & 11).<br />
(2) Affiant witness (name redacted for security reasons), in his sworn<br />
testimony explains he was selected for the national security guard<br />
detail of the President of Venezuela, and that he witnessed the<br />
creation of Smartmatic for the purpose of election vote<br />
manipulation:<br />
I was witness to the creation and operation of a sophisticated electronic<br />
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