Disputed Fact

Fake Forensic Audit of ES&S System (MI)

Disputed Fact In the wake of the 2020 election, incoming Macomb County Clerk Anthony Forlini contracted with Pro V&V to conduct what he referred to as a “forensic” audit of the ES&S. Cybersecurity expert Ben Cotton of CyFir was invited to observe the conduct of the audit but was not allowed to examine the equipment

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Erasure of Adjudication Logs to Prevent Meaningful Audit (MI)

Disputed Fact A court-ordered forensic examination in Antrim County documented a 68.05% tabulation error rate that routed large numbers of ballots to electronic adjudication. When auditors accessed the Dominion EMS, all 2020 adjudication log entries were missing, while adjudication logs for prior election years on the same system remained intact, making it impossible to reconstruct

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Fabricated Post-Election Voting Machine “Audit” (GA)

Disputed Fact Secretary of State Brad Raffensperger publicly announced that Pro V&V had conducted a forensic audit of Dominion voting machines and found “no sign of foul play.” Open records responses from the counties named in his announcement showed no records of any such audit activity; Pro V&V was not accredited for forensic security audits,

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Physical Destruction of Machine Tapes and V-Drives to Prevent Recount Discrepancy Discovery (PA)

Disputed Fact [Disputed Fact – Named-witness testimony not yet adjudicated; Ziegelhoffer statement is powerful but requires corroboration and authentication] Named-witness testimony from a person present at a Delaware County election facility establishes that county officials – identified as Attorney Thomas Gallagher and James Ziegelhoffer – physically tore election data into pieces, with Ziegelhoffer stating the

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Machine Recount of a Compromised Tabulator System – Vote Shift Algorithm Identified (MI)

Disputed Fact [Disputed Fact – Vote-shift algorithm characterization – supported by Lenberg analysis, contested by Secretary of State] Antrim County’s tabulation system – Dominion Voting Systems Democracy Suite 5.5 – was documented by the Allied Security Operations Group (ASOG) forensic report to have a 68.05% error rate in tabulator logs, grossly exceeding the maximum allowable

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Intentional Record Destruction – Delaware County Certified with 244 of 428 Precincts Missing Required Documentation

Disputed Fact [Disputed Fact – Record destruction – named-witness testimony, not yet adjudicated] Delaware County certified the November 3, 2020 election on or about November 24, 2020, contributing data to Secretary Boockvar’s statewide certification. Delaware County’s own Right to Know Law (RTKL) response, dated June 28, 2021, established that: 15 precincts had no Return Sheets

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Black Box Poll Book Substitution and Unlisted List – Fraudulent Intent (MI)

Disputed Fact [Disputed Fact – Cause and intent – requires confrontation of Baxter with documentary evidence] One day before the November 17, 2020 Wayne County Board of Canvassers certification meeting, Canvassers Palmer and Hartmann observed a black trunk being delivered containing a new, revised Statement of Votes for the absentee counting boards – a substitution

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Wayne County was never lawfully certified (MI)

Disputed Fact Official certification paperwork for Wayne County did not satisfy certification requirements under MCL 168.24e. Statute requires at least one signature from representatives of both political parties. Neither of the Republican canvassers signed the official certification paperwork. MCL 168.822(4) stipulates that Certification requires a “signed, written statement”. Both Republican canvassers provided signed affidavits in

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Coerced Certification Followed by Sworn Rescission (MI)

Disputed Fact On November 17, 2020, Wayne County Board of Canvassers Republican members Monica Palmer and William Hartmann initially voted against certifying the county’s election results because 71% of Detroit’s Absentee Voter Counting Board (AVCB) precincts were documented as out of balance – meaning the number of ballots counted at those precincts did not reconcile

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148 Advance Voting Tabulator Returns Were Never Certified – Certification Proceeded Anyway (GA)

Disputed Fact Fulton County conceded in SEB2022-015 proceedings that all 148 advance voting tabulator official returns representing approximately 316,000-320,000 ballots were never formally certified by the county canvassing authority prior to the county submitting those results to the Secretary of State for statewide certification. The State Election Board voted to refer this matter to the

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