Established Fact
Forensic examination of ESS DS400 tabulator thumb drives confirmed that each DS400 was equipped with a Verizon cellular wireless communications card that was active on power-up. Both devices were configured to transmit election results to IP address 10.48.51.1 – a private network address accessible remotely only through the public internet or a VPN. This finding directly contradicts ESS’s public representations that its tabulators do not have internet connectivity. A cellular modem that activates on power-up and transmits results to a network-accessible private IP establishes a functional, built-in data transmission pathway of unknown destination.
Citations
Affidavit of Benjamin R. Cotton: https://www.depernolaw.com/uploads/2/7/0/2/27029178/ex_7_-_cotton_2_%5B060821%5D.pdf | DePerno Law
Affidavit of Benjamin R. Cotton: https://www.depernolaw.com/uploads/2/7/0/2/27029178/%5B13%5D_ex_11_cotton_1.pdf | DePerno Law
Antrim County Technology Expert Witness Comparisons: https://letsfixstuff.org/2021/04/antrim-county-technology-expert-witness-comparisons/ | LetsFixStuff.org