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

attached hereto, paragraph. 18 and 20 of p. 28, Exh. 4, Hursti Declaration).
wherein he testified or found:
1) The failure of the Dominion software “to meet the methods and
processes for national standards for managing voting system problems and
should not be accepted for use in a public election under any circumstances.”
2) In Hursti’s declaration he explained that “There is evidence of
remote access and remote troubleshooting which presents a grave security
implication and certified identified vulnerabilities should be considered an
“extreme security risk.” Id. Hari Hursti also explained that USB drives with
vote tally information were observed to be removed from the presence of poll
watchers during a recent election. Id. The fact that there are no controls of
the USB drives was seen recently seen the lack of physical security and
compliance with professional standards, " in one Georgia County, where it is
reported that 3,300 votes were found on memory sticks not loaded plus in
Floyd county, another 2,600 were unscanned, and the “found votes” reduced
Biden’s lead over Donald Trump 29 .
(a)
In the prior case against Dominion, supra, further
implicating the secrecy behind the software used in Dominion Systems,
29
Recount find thousands of Georgia votes, Atlanta Journal-Constitution by Mark Niesse and
David Wickert,11/19/20. https://www.ajc.com/politics/recount-finds-thousands-of-georgiavotes-missing-from-initial-counts/ERDRNXPH3REQTM4SOINPSEP72M/
54