Replies

The infamous 6,000-vote “glitch”

D. “Red Flags” in Dominion’s Michigan Results for 2020 General
Election Demonstrate Dominion Manipulated Election Results, and
that the Number of Illegal Votes Is Nearly Twice As Great as Biden’s
Purported Margin of Victory.
127. The expert witness testimony of Russell James Ramsland, Jr. (“Ramsland
Affidavit”)11analyzes several “red flags” in Dominion’s Michigan results for the 2020 election,
and flaws in the system architecture more generally, to conclude that Dominion manipulated
election results. Dominion’s manipulation of election results enabled Defendants to engage in
further voting fraud violations above and beyond the litany of violations recited above in Section
II.A through Section II.C.
1. Antrim County “Glitch” Was Not “Isolated Error” and May Have
Affected Other Counties.
128. The first red flag is the Antrim County, Michigan “glitch” that switched 6,000
Trump ballots to Biden, and that was only discoverable through a manual hand recount. See
supra Paragraph 94. The “glitch” was later attributed to “clerical error” by Dominion and
Antrim Country, presumably because if it were correctly identified as a “glitch”, “the system
would be required to be ‘recertified’ according to Dominion officials. This was not done.” Exh.
104, Ramsland Aff. at ¶10. Mr. Ramsland is skeptical because “the problem most likely did
occur due to a glitch where an update file did not properly synchronize the ballot barcode
generation and reading portions of the system.” Id. Further, such a glitch would not be an
10 See Texas Analysis of February 15, 2019 from the Voting Systems Examiner to the Director
of Elections (emphasis added).
11As detailed in the Ramsland Affidavit and the CV attached thereto, Mr. Ramsland is a member
of the management team Allied Security Operations Group, LLC (“ASOG”), a firm specializing
in cybersecurity, OSINT and PEN testing of networks for election security and detecting election
fraud through tampering with electronic voting systems.
Case 2:20-cv-13134-LVP-RSW ECF No. 1, PageID.43 Filed 11/25/20 Page 43 of 75
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“isolated error,” as it “would cause entire ballot uploads to read as zero in the tabulation
batch, which we also observed happening in the data (provisional ballots were accepted
properly but in-person ballots were being rejected (zeroed out and/or changed (flipped)).” Id.
Accordingly, Mr. Ramsland concludes that it is likely that other Michigan counties using
Dominion may “have the same problem.” Id.

Late nite bullnost — blank ballots fed in and Dominion machines used to count them for Biden.

2. Fractional Vote Counts in Raw Data Strongly Indicate Voting
Manipulation through “Ranked Choice Voting Algorithm”
129. Mr. Ramsland’s analysis of the raw data , which provides votes counts, rather
than just vote shares, in decimal form provides highly probative evidence that, in his
professional opinion, demonstrates that Dominion manipulated votes through the use of an
“additive” or “Ranked Choice Voting” algorithm (or what Dominion’s user guide refers to as
the “RCV Method”). See id. at ¶12.
12 Mr. Ramsland presents the following example of this data
– taken from “Dominion’s direct feed to news outlets” – in the table below. Id.
state timestamp eevp trump biden TV BV
michigan 2020-11-04T06:54:48Z 64 0.534 0.448 1925865.66 1615707.52
michigan 2020-11-04T06:56:47Z 64 0.534 0.448 1930247.664 1619383.808
michigan 2020-11-04T06:58:47Z 64 0.534 0.448 1931413.386 1620361.792
michigan 2020-11-04T07:00:37Z 64 0.533 0.45 1941758.975 1639383.75
michigan 2020-11-04T07:01:46Z 64 0.533 0.45 1945297.562 1642371.3
michigan 2020-11-04T07:03:17Z 65 0.533 0.45 1948885.185 1645400.25
130. Mr. Ramsland describes how the RCV algorithm can be implemented, and the
significance of the use of fractional vote counts, with decimal places, rather than whole numbers,
in demonstrating that Dominion did just that to manipulate Michigan votes.
12See id. (quotingDemocracy Suite EMS Results Tally and Reporting User Guide, Chapter 11,
Settings 11.2.2., which reads, in part, “RCV METHOD: This will select the specific method of
tabulating RCV votes to elect a winner.”).
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For instance, blank ballots can be entered into the system and treated as “writeins.” Then the operator can enter an allocation of the write-ins among candidates
as he wishes. The final result then awards the winner based on “points” the
algorithm in the compute, not actual votes. The fact that we observed raw vote
data that includes decimal places suggests strongly that this was, in fact, done.
Otherwise, votes would be solely represented as whole numbers. Below is an
excerpt from Dominion’s direct feed to news outlets showing actual calculated
votes with decimals. Id.
3. StrongEvidence That Dominion Shifted Votes from Trump to Biden.
131. A third red flag identified by Mr. Ramslund is the dramatic shift in votes between
the two major party candidates as the tabulation of the turnout increased, and more importantly,
the change in voting share before and after 2 AM on November 4, 2020, after Wayne County and
other Michigan election officials had supposedly halted counting.
Until the tabulated voter turnout reached approximately 83%, Trump was
generally winning between 55% and 60% of every turnout point. Then, after the
counting was closed at 2:00 am, the situation dramatically reversed itself,
starting with a series of impossible spikes shortly after counting was
supposed to have stopped. Id. at ¶13.
132. Once again the means through which Dominion appears to have implemented this
scheme is through the use of blank ballots that were all, or nearly all, cast for Biden.
The several spikes cast solely for Biden could easily be produced in the Dominion
system by pre-loading batches of blank ballots in files such as Write-Ins, then
casting them all for Biden using the Override Procedure (to cast Write-In ballots)
that is available to the operator of the system. A few batches of blank ballots
could easily produce a reversal this extreme, a reversal that is almost as
statistically difficult to explain as is the impossibility of the votes cast to number
of voters described in Paragraph 11 above.Id.
4. The November 4 Ballot Dumps Wayne County and Other Michigan
Counties Was “Physically Impossible” Because There Were More
Ballots Than Machines in Those Four Counties Could Have Counted
Or Processed.
133. Mr Ramsland and his team analyzed the sudden injection of totaling 384,733
ballots by four Michigan counties (Wayne, Oakland, Macomb, and Kent) in a 2 hour 38 minute
period in the early morning of November 4 (which would have included the first ballot dump
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described above in Paragraph 72), and concluded that “[t]his is an impossibility, given the
equipment available at the 4 reference locations (precincts/townships).” Id. at ¶14.
134. Specifically, Mr. Ramslund calculated that “94,867 ballots as the maximum
number of ballots that could be processed” in that time period, and thus that “[t]here were
289,866 more ballots processed in the time available for processing in four precincts/townships,
than the capacity of the system allows.” Id. Mr. Ramsland concludes that “[t]he documented
existence of the spikes are strongly indicative of a manual adjustment either by the operator of
the system (see paragraph 12 above) or an attack by outside actors.” Id. The vote totals added
for all Michigan counties, including Wayne, Oakland, Macomb and Kent counties, for the period
analyzed by Mr. Ramsland are reproduced in the figure below.

= = = = = = = = = = = = = = = = = = = = =
(I can’t copy the figure, sorry. Look on page 46 of the original source.)