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Monkey business with the Dominion systems

E. Additional Independent Findings of Dominion Flaws.
136. Further supportive of this pattern of incidents, reflecting an absence of mistake,
Plaintiffs have since learned that the “glitches” in the Dominion system — that have the uniform
effect of hurting Trump and helping Biden — have been widely reported in the press and
confirmed by the analysis of independent experts.
1. Central Operator Can Remove, Discard or Manipulate Votes.
137. Plaintiffs have also learned of the connection between Dominion Voting Systems,
Smartmatic and the voting systems used in Venuezela and the Phillipines.
a. Dominion Voting has also contradicted itself in a rush to denial a pattern of errors
that lead to fraud. For example, Dominion Voting Systems machines can read all
of these instruments, including Sharpies.https://www.dominionvoting.com/
b. but Dominion Voting’s Democracy Suite contract with Michigan specifically
requires:
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Black Inc: Black ink (or toner) must be dense, opaques, light-fast and permanent,
with a measured minimum 1.2 reflection density (log) above the paper base.
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138. An Affiant, who is a network & Information cybersecurities expert, under sworn
testimony explains that after studying the user manual for Dominion Voting Systems Democracy
software, he learned that the information about scanned ballots can be tracked inside the
software system for Dominion:
(a) When bulk ballot scanning and tabulation begins, the “ImageCast Central”
workstation operator will load a batch of ballots into the scanner feed tray and
then start the scanning procedure within the software menu. The scanner then
begins to scan the ballots which were loaded into the feed tray while the
“ImageCast Central” software application tabulates votes in real-time. Information
about scanned ballots can be tracked inside the “ImageCast Central” software
application.
(See Exh.Aff. of Watkins __, at par.11).
139. The Affiant further explains that the central operator can remove or discard
batches of votes. “After all of the ballots loaded into the scanner’s feed tray have been through
the scanner, the “ImageCast Central” operator will remove the ballots from the tray then have the
option to either “Accept Batch” or “Discard Batch” on the scanning menu …. “Id. at ¶ 12.
140. Affiantfurther testifies that the user manual makes clear that the system allows for
threshold settings to be set to find all ballots get marked as “problem ballots” for discretionary
determinations on where the vote goes stating:
“During the voting process, the voter will mark an oval on the ballot using a
writing device. During the scanning process, the “ImageCast Central” software
will detect how much of a percent coverage of the oval was filled in by the voter.
The Dominion customer determines the thresholds of which the oval needs to be
covered by a mark in order to qualify as a valid vote. If a ballot has a marginal
mark which did not meet the specific thresholds set by the customer, then the
ballot is considered a “problem ballot” and may be set aside into a folder named
“NotCastImages”. Through creatively tweaking the oval coverage threshold
settings it should be possible to set thresholds in such a way that a non-trivial
amount of ballots are marked “problem ballots” and sent to the “NotCastImages”
13See Exh. 8, par. 2.6.2 of contract # 071B770017.
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folder. It is possible for an administrator of the ImageCast Central work station
to view all images of scanned ballots which were deemed “problem ballots” by
simply navigating via the standard “Windows File Explorer” to the folder named
“NotCastImages” which holds ballot scans of “problem ballots”. It is possible for
an administrator of the “ImageCast Central” workstation to view and delete any
individual ballot scans from the “NotCastImages” folder by simply using the
standard Windows delete and recycle bin functions provided by the Windows 10
Pro operating system.
Id. at ¶¶ 13-14.
141. The Affiant further explains the vulnerabilities in the system when the copy of the
selected ballots that are approved in the Results folder are made to a flash memory card – and
that is connected to a Windows computer stating:
It is possible for an administrator of the “ImageCast Central” workstation toview
and delete any individual ballot scans from the “NotCastImages” folder by simply
using the standard Windows delete and recycle bin functions provided by the
Windows 10 Pro operating system. … The upload process is just a simple copying
of a “Results” folder containing vote tallies to a flash memory card connected to
the “Windows 10 Pro” machine. The copy process uses the standard drag-n-drop
or copy/paste mechanisms within the ubiquitous “Windows File Explorer”. While
a simple procedure, this process may be error prone and is very vulnerable to
malicious administrators.
Id. at par. 14 and 15.

COUNT V
MICHIGAN STATUTORY ELECTION LAW VIOLATIONS
191. Plaintiffs refer to and incorporate by reference each of the prior
paragraphs of this Complaint as though the same were repeated at length herein
Violation of MCL 168.765a.
192. Absent voter ballots must only be counted when “at all times” there is “at least 1
election inspector from each major political party.” MCL 168.765a.
193. Per eyewitness accounts described in this Complaint and its attached sworn
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affidavits, Defendants habitually and systematically disallowed election inspectors from the
Republican party, including Plaintiff, to be present in the voter counting place and refused
access to election inspectors from the Republican party, including Plaintiff, to be within a
closeenoughdistancefromtheabsentvoterballotstobeabletoseeforwhomtheballotswerecast.
See generally supra Section II.A., Paragraphs56-75.
194. Defendants refused entry to official election inspectors from the Republican
party, including Plaintiff, into the counting place to observe the counting of absentee voter
ballots. Defendants even physically blocked and obstructed election inspectors from the
Republicanparty,includingPlaintiff,byadheringlargepiecesofcardboardtothetransparent glass
doors so the counting of absent voter ballots was notviewable.
Violation of MCL 168.733
195. MCL 168.733requires sets forth the procedures for election challengers and the
powers of election inspectors. See generally supra Paragraph 39.
196. Per eyewitness accounts described in this Complaint and its attached sworn
affidavits, Defendants habitually and systematically failed to provide space for election
inspectors from the Republican party, including Plaintiff, to observe election procedure,
failed to allow the inspection of poll books, failed to share the names of the electors being
entered in the poll books, failed to allow the examination of each ballot as it was being
counted, and failed to keep records of obvious and observedfraud.See generally supra
Section II.A., Paragraphs 56-75.
197. Pollchallengers,includingPlaintiff,observedelectionworkersandsupervisors
writing on ballots themselves to alter them, apparently manipulating spoiled ballots by hand
and then counting the ballots as valid, counting the same ballot more than once, adding
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information to incomplete affidavits accompanying absentee ballots, counting absentee
ballots returned late, counting unvalidated and unreliable ballots, and counting the ballots of
“voters”whohadnorecordedbirthdatesandwerenotregisteredintheState’sQualifiedVoter File
or on any Supplemental voterlists.