Operational Control

Vendor-Directed Obstruction of Legislative Audit – County Directed Dominion Not to Cooperate (AZ)

Established Fact During the Arizona State Senate’s 2021 forensic audit of Maricopa County’s 2020 election results, both Maricopa County and its election system vendor Dominion Voting Systems refused to comply with Senate subpoenas for administrative passwords, security tokens, and routers used in the election. The county informed Senate liaison Ken Bennett on May 3, 2021

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Zuckerberg 5 “Safe Voting Plan” Contractual Penalties (WI)

Established Fact The five “Zuckerberg 5” cities — Milwaukee, Madison, Green Bay, Racine, and Kenosha — together requested and received $6,324,527 in CTCL grants in July 2020 to implement the Wisconsin Safe Voting Plan, a document the cities themselves submitted to CTCL specifying drop box locations, staffing increases, poll worker recruitment, and voter outreach programs.

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CTCL Claw-Back Leverage Over Philadelphia Operations (PA)

Established Fact Philadelphia accepted millions in CTCL funds under agreements with claw-back provisions that, in practical effect, made noncompliance with CTCL’s specified operational model (including drop-box deployment, staffing, and outreach) “not an option.” Local officials described the terms as binding, and the grant documents empowered CTCL to demand repayment for deviations, granting a Chicago-based NGO

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CTCL Detroit Grant with Unilateral Claw-Back Authority (MI)

Established Fact Detroit’s CTCL grant (approx. 3.5-7.4 million dollars depending on tranche) included a clause granting CTCL the right, “in its sole judgment,” to demand return of funds if Detroit did not adhere to the grant’s conditions (e.g., implementing specified satellite offices, drop boxes, and staffing models). This placed core questions of compliance with election-administration

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CTCL Grant Claw-Backs Nullifying County Independence (GA)

Established Fact Georgia counties including Fulton and DeKalb accepted multi-million-dollar CTCL grants in 2020 — Fulton County $6,309,436 and DeKalb County approximately $4.7 million for the general election plus an additional $4.6 million for the December runoff — and used the funds to operate voting locations, hire election staff, purchase processing equipment, and deploy drop

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Judicial Remedy Arrives Post-Certification; Drop Box Legality Unresolved at Time of Election (AZ)

Reasonable Inference Unlike Wisconsin, Arizona courts did not issue a definitive pre-certification ruling on the legality of drop box placement and operational standards under CTCL-funded plans. The election was thus administered under unverified private-grant-driven drop box protocols while no judicial or statutory framework governed collection schedules, two-person collection requirements, or surveillance coverage mandates. Citations Arizona

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Hatch Act Concerns Raised by CTCL Clawback Provisions Created Ongoing Private Control Over Governmental Election Administration (US)

Disputed Fact [Disputed Fact – As to Hatch Act nexus] Across CTCL grant jurisdictions reviewed, grant agreements included enforceable contractual clawback provisions authorizing CTCL, in its sole judgement, to demand the return of all or part of disbursed funds if recipients failed to comply with the grant’s conditions. In the Wisconsin five-city agreement, this provision

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CTCL Clawback Provisions Created Ongoing Private Control Over Governmental Election Administration (US)

Reasonable Inference [Reasonable Inference – As to functional governmental subordination] Across all CTCL grant jurisdictions reviewed, grant agreements included enforceable contractual clawback provisions authorizing CTCL, in its sole discretion, to demand the full return of disbursed funds if recipients failed to comply with CTCL’s programmatic directives. This financial penalty regime – operating over duly sworn

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Private CTCL Operative Exercised Physical Control Over Election Night Ballot and Machine Environment, Including Drop Box Processing (WI)

Established Fact Michael Spitzer-Rubenstein, a Brooklyn-based CTCL “grant mentor,” gained physical control over Green Bay’s election night facility – including control of the secret Wi-Fi access point to which all ESS voting machines were connected. He wrote to the City Attorney at 9:29 PM on November 3, 2020, making a dispositive legal determination that late-arriving

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Dominion Voting Systems Personnel in Operational Control of Voting Systems During Election and Post-Election (GA)

Reasonable Inference [Established Fact – Dominion operational control confirmed; FIPS violation confirmed; EAC certification timing confirmed] The EOG Report concluded that Dominion Voting Systems personnel were in operational control of voting systems in nearly every Georgia county during the election period. This determination is critical to the record destruction findings: the personnel with the greatest

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