COMPLAINT-CJ-PEARSON-V.-KEMP-11.25.2020

a. Barcodes can override the voters’ vote: As one University of California,
Berkeley study shows, “In all three of these machines [including
Dominion Voting Systems] the ballot marking printer is in the same
paper path as the mechanism to deposit marked ballots into an
attached ballot box. This opens up a very serious security
vulnerability: the voting machine can make the paper ballot (to add
votes or spoil already-cast votes) after the last time the voter sees the
paper, and then deposit that marked ballot into the ballot box without
the possibility of detection.” (See Exh. 7). 21
b. Voting machines were able to be connected to the internet by way of
laptops that were obviously internet accessible. If one laptop was
connected to the internet, the entire precinct was compromised.
c. We … discovered that at least some jurisdictions were not aware that
their systems were online,” said Kevin Skoglund, an independent
security consultant who conducted the research with nine others, all of
them long-time security professionals and academics with expertise in
election security. Vice. August 2019. 22
21
Ballot Marking Devices (BMDs) Cannot Assure the Will of the Voters, Andrew W. Appel,
Richard T. DeMillo, University of California, Berkeley, 12/27/2019.
22
Exclusive: Critical U.S. Election Systems Have Been Left Exposed Online Despite Official
Denials, Motherboard Tech by Vice, by Kim Zetter, August 8, 2019,
https://www.vice.com/en/article/3kxzk9/exclusive-critical-us-election-systems-have-been-leftexposed-online-despite-official-denials
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