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

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Dr. Eric Coomer, a Vice President of Dominion Voting Systems,

testified that even he was not sure of what testing solutions were

available to test problems or how that was done, “ I have got to be

honest, we might be a little bit out of my bounds of understanding the

rules and regulations… and in response to a question on testing for

voting systems problems in relation to issues identified in 2 counties,

he explained that “Your Honor, I’m not sure of the complete test plan…

Again Pro V&V themselves determine what test plan in necessary based

on their analysis of the code itself.” (Id. at Document 959-4, pages 53,

62 L.25- p. 63 L3).

113.

Hursti stated within said Declaration:

“The security risks outlined above – operating system risks, the

failure to harden the computers, performing operations directly on

the operating systems, lax control of memory cards, lack of

procedures, and potential remote access are extreme and destroy the

credibility of the tabulations and output of the reports coming from a

voting system.”

(See Paragraph 49 of Hursti Declaration).

114.

Rather than engaging in an open and transparent process to give

credibility to Georgia’s brand-new voting system, the election processes were

55

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