Arizona Kraken lawsuit

Case 2:20-cv-02321-DJH Document 1 Filed 12/02/20 Page 20 of 53
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possibly impossible spike in processed votes” for Biden, namely, the insertion of 143,100
Biden votes in Maricopa and Pima Counties at 8:06:40 PM on November 3, 2020. See id.
16.
This spike, cast largely for Biden, could easily be produced in the Dominion EMS
control system by pre-loading batches of blank ballots in files such as Write-Ins or other
adjudication-type files then casting them almost all for Biden using the Override
Procedure (to cast Write-In, Blank, or Error ballots) that is available to the operator of the
system. A few batches of blank ballots electronically pre-loaded into the adjudication
files could easily produce a processed ballot stream this extreme so that actual paper
ballots would not be needed until later to create “corroboration” for the electronic count.
Id.
6. Administrative and Judicial Decisions Regarding Dominion’s
Security Flaws.
67. Texas. Texas, through its by the Secretary of State, denied certification to
nearly the same Dominion Democracy Suite on January 24, 2020, specifically because the
“examiner reports raise concerns about whether Democracy Suite 5.5-A system … is safe
from fraudulent or unauthorized manipulation.” 7
68. Wisconsin. In 2018, Jill Stein was in litigation with Dominion Voting
Systems (“DVS”) after her 2016 recount request pursuant to WISCONSIN
STAT.§5.905(4) wherein DVS obtained a Court Order requiring confidentiality on
information including voting counting source code, which Dominion claims is proprietary
– and must be kept secret from the public. (See unpublished decision, Wisconsin Court of
Appeals, No. 2019AP272 issued April 30, 2020). Rather than engaging in an open and
7
See attached hereto, as Exh. 11, State of Texas Secretary of State, Elections Division,
Report of Review of Dominion Voting Systems Democracy Suite 5.5-A at 2 (Jan. 24,
2020) (emphasis added).
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