Tue May 04 19:07:23 +0000 2021

 · 8 min read
 · trapezoid of discovery

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There have been some new filings in Antrim, so that means it's time for a thread.

We'll be going over the docs here: https://www.depernolaw.com/bailey-documents---may-2021.html

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Let's start with the standard disclaimers: I'm not an election security expert...but then again, neither any of DePerno's expert witnesses (and it shows)

I'm also not a lawyer.

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First up, their motion to amend their complaint: https://www.depernolaw.com/uploads/2/7/0/2/27029178/[22]_motion_for_leave_to_amend_the_complaint.pdf

Basically, they want to update the complaint they originally filed on 11/22.

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The motion to amend illustrates what happens when you hire people without election auditing experience to audit an election:

They miss important details and end up having to lean on a report submitted by the defense in order to understand what actually happened.

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They essentially say that, until Halderman's report, they were unaware of the role ElectionSource had in Antrim, but also that they don't "concede the truth or accuracy" of his report...simply that it "opened the door for the plaintiffs to uncover new evidence"

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I'm interpreting this as: we were taking shots in the dark until we read a report that explained what happened in Antrim in detail. After reading that, we have a better idea of how elections work and would like to change our angle.

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I'd like to point out the plaintiff's own expert witnesses - ASOG - were aware that ElectionSource was responsible for configuring the ballot design and configuration back in December.

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They're pivoting after learning new information from a report created by the opposing counsel.

I'll get into Halderman's report in a bit, but it explained - in detail - what went wrong. DePerno's team, learning that info for the first time, then found a way to spin it.

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Trying to figure out what to cover next...either the amended complaint, or the Halderman report, since the amended complaint is basically the Halderman report with a tasty stop-the-steal twist.

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I'll talk a little bit about the Halderman report, and then may flip back and forth between that and amended complaint.

You can find a copy here: https://www.michigan.gov/documents/sos/Antrim_720623_7.pdf

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It's worth reiterating that while the report doesn't attribute the cause of the vote switch to mal-intent - it does highlight several deficiencies in how the county handled their election procedures, as well as how the Dominion software could have helped officials avoid mistakes

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Halderman's finding summary:

Antrim changed 3 ballot designs, but did not update all the CF cards like they should have Votes had already been recvd for the old ballot design Testing was not done after the ballot changes Scanners could not handle old & new ballot designs

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3 cards failed to load and were entered manually from poll tapes 13 cards were not updated Ballot changes altered candidate identifiers Old cards w/ old IDs were interpreted with the new IDs *Votes were assigned to the wrong candidates causing large errors in initial results

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County staff (at 4am) did not review results closely b4 publishing Staff manually entered results from poll tapes to correct..

BUT

*Staff neglected to remove some inaccurate data resulting in totals in some precincts that were the sum of the corrected AND erroneous results

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Central Lake Village showed wrong school board race due to ballot design/scanner config mismatch Rescanned ballots w/ updated config were incorporated into certified results 3 ballots scanned on 11/3 were not rescanned The MJ initiative could change due to 1 unscanned ballot

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Antrim's 11/6 certified results contained data entry errors from manually entering the correct results. The errors should have been detected during canvass but were not *County restated it's results on 11/16 and then again on 11/21 to correct

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County certified results match poll tapes in most cases Poll tapes & final results are inaccurate for "a few" down-ballot contests in 3 precincts where ballot designs changed, as a result of county's failure to tell between new/old ballot designs

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State conducted a county-wide hand count of the presidential contest that was accurate within 0.08% of the final results State conducted state-wide risk limiting audit of the presidential contest affirmed the reported outcome

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Wanted to cover the findings summary because it'll be helpful context. Overall, I suggest reading the report in it's entirety...it's well written, and you don't need to be an election security expert to understand it

...which is probably why it helped DePerno's team so much

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I missed this the first time I read the report, but Halderman examined the same image that ASOG had obtained

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Halderman notes that he could interact with the EMS without providing passwords, and that SQL Server Studio was installed - and could be used to view/edit the election DBs without a password.

He also notes that physical access would be required to perform similar steps.

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Continuing this thread here:

(I really just need to sign up for medium)

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Going to try and wrap this thread up in the next couple of days