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Received 12/17/2021 4:01:58 PM Commonwealth Court of Pennsylvania

Filed 12/17/2021 4:01:00 PM Commonwealth Court of Pennsylvania

277 MD 2021








AND NOW, this _____ day of December, 2021, upon consideration of

Respondent’s Emergency Application for an Order Prohibiting Spoliation of Key

Evidence Scheduled to Occur on December 22, 2021, it is hereby ORDERED that

the Emergency Application is GRANTED.


1. Petitioners are ENJOINED from providing any third party (other than

Dominion Voting Systems) with access to the electronic voting machines

in Fulton County’s possession that are leased from Dominion Voting

Systems (the “Electronic Voting Machines”), including but not limited to

allowing the inspection by Envoy Sage currently scheduled for December

22, 2021, pending further order of this Court.

2. Petitioners shall take all necessary steps—which may include returning

the Electronic Voting Machines to Dominion Voting Systems in a manner

that maintains chain of custody—to preserve the Electronic Voting

Machines, and any data stored thereon, in a secured and unaltered state

pending further order of this Court.


Michele D. Hangley (I.D. No. 82779) Kenneth L. Joel (I.D. No. 72370)
Robert A. Wiygul (I.D. No. 310760) 333 Market St., 17th Floor
John B. Hill (I.D. No. 328340) Harrisburg, PA 17101
One Logan Square, 27th Floor (717) 787-9348
Philadelphia, PA 19103-6933
OFFICE OF ATTORNEY GENERAL Kathleen M. Kotula (I.D. No. 86321)
Stephen Moniak (I.D. No. 80035) 306 North Office Bldg.
Karen M. Romano (I.D. No. 88848) 401 North Street
15th Floor, Strawberry Square Harrisburg, PA 17120-0500
Harrisburg, PA 17120 (717) 783-1657
Aimee D. Thomson (I.D. No. 326328)
1600 Arch St., Suite 300 TUCKER LAW GROUP
Philadelphia, PA 19103 Joe H. Tucker, Jr. (I.D. No. 56617)
(717) 787-2717 Dimitrios Mavroudis (I.D. No. 93773)
Jessica Rickabaugh (I.D. No. 200189)
1801 Market Street, Suite 2500
Philadelphia, PA 19103
(215) 875-0609

Counsel for Respondent








Respondent Veronica Degraffenreid, in her official capacity as Acting

Secretary of the Commonwealth, hereby applies for an order prohibiting

Petitioners, the Fulton County Board of Elections and two of its commissioners

(collectively, “Fulton County”), from spoliating key evidence in this case—

namely, electronic voting equipment and data stored therein—by providing a third

party with the opportunity to access the equipment and manipulate its data.

Because Respondent did not learn of Petitioners’ plans until December 14, 2021,

and the third-party “inspection” is scheduled for Wednesday, December 22, at 9:00

a.m., Respondent is compelled to seek relief on an emergency basis.


A. Petitioners Compromise the Security of Fulton County’s
Electronic Voting System by Providing a Third Party, Wake TSI,
the Opportunity to Access and Image Its Components
This case arose from Petitioners’ surreptitious decision—made without any

public notice or public deliberation, and without informing the Department of

State—to permit Wake TSI, an unqualified and unvetted third party with no

election administration role, to access and take images of key components of

Fulton County’s certified electronic voting equipment in December 2020. When

Respondent learned of this unsanctioned breach of basic security protocols, she

discharged her duty to protect the integrity of Pennsylvania’s elections by

prohibiting the future use of Fulton County’s compromised electronic voting

equipment. Petition for Review (“Pet.”) Ex. H at 2.

Faced with the threat that outside forces could compromise other counties’

voting systems under the guise of similar “examinations” or “inspections,”

Respondent also issued Directive 1 of 2021. This Directive stated the Acting

Secretary’s position that providing “third-party entities not directly involved with

the conduct of elections” with certain types of access to state-certified electronic

voting systems or their components—for example, allowing such third parties to

“image electronic memory spaces, to download operating systems and software, …

to copy information that is internal and proprietary,” or to otherwise “review and

copy the internal electronic, software, mechanical, logic, and related components

of [electronic voting] systems”—would compromise the security and reliability of

electronic election equipment, and that any equipment so compromised could not

be used in subsequent elections. See Pet. Ex. F; see also id. at 1-2 (explaining that

allowing such third-party access “undermines chain of custody requirements and

strict access limitations necessary to prevent both intentional and inadvertent

tampering with electronic voting systems,” “jeopardizes the security and integrity

of those systems[,] and will negate the ability of electronic voting system vendors

to affirmatively state that such systems continue to meet Commonwealth security

standards, are validated as not posing security risks, and are able to be certified to

perform as designed by the electronic voting system vendor and as certified by

both the U.S. Election Assistance Commission and the Department of State”).

B. In Response to the Secretary’s Actions to Protect Pennsylvania’s

Election Integrity, Petitioners File This Lawsuit, Insisting That
Wake TSI’s “Inspection” Did Not Compromise the Security of the
County’s Electronic Voting Equipment
Petitioners initiated this lawsuit to challenge Respondent’s decision to

prohibit the future use of Fulton County’s compromised electronic voting

equipment, as well as her authority to issue Directive 1. Importantly for this

Application, Petitioners directly dispute Respondent’s conclusion that Wake TSI’s

inspection breached the security of any of the County’s equipment. According to

Petitioners’ allegations, an “[]examination” of those machines would show that,

following Wake TSI’s actions, the County’s equipment “continued to meet the

[security] requirements of the Election Code and that such … machines could

readily be used by Fulton County” in the future. Amended Petition for Review

¶ 48.

This case remains at an early stage. Respondent’s Preliminary Objections,

which seek dismissal of Count III of the Amended Petition challenging the

Secretary’s authority to issue Directive 1, remains pending. The remaining

Counts, including the ones challenging Respondent’s decommissioning of Fulton

County’s compromised voting equipment, implicate factual issues to be resolved

after discovery.

Pursuant to the scheduling Order entered on November 19, 2021,

Respondent’s brief in support of her Preliminary Objections is due by December

20, 2021; Petitioners’ brief in opposition is due by January 19, 2022; and the

Preliminary Objections will thereafter be placed on the next available argument

list. See Order dated November 19, 2021.

C. Without Informing Respondent, Petitioners Decide to Provide Yet

Another Third Party With Access to the Electronic Voting
Equipment at Issue in This Case
Incredibly, despite the consequences of Petitioners’ earlier decision to allow

third-party access to Fulton County’s electronic voting equipment, and despite the

fact that this equipment—in particular, its status and condition following Wake

TSI’s “examination”—is essential evidence in this case, Petitioners have decided

to allow yet another third party to access that equipment and manipulate its data.

And, once again, Petitioners made this decision without providing advance notice

to Respondent, who is not only Pennsylvania’s “chief election official,” charged

with the statutory responsibility to protect the security of electronic voting

equipment, see Banfield v. Cortes, 110 A.3d 155, 174 (Pa. 2015), but is also a

litigant with discovery rights that Petitioners are obligated to respect, see, e.g.,

Pa.R.C.P. 3.4 (requiring “[f]airness to [o]pposing [p]arty and [c]ounsel” and

prohibiting the “unlawful[] alter[ation], destr[uction] or conceal[ing] [of] a

document or other material having potential evidentiary value”).

On November 29, 2021, Respondent’s counsel found a meeting agenda

posted online, which indicated that, the next morning, Petitioners would vote on a

motion to allow the “Intergovernmental Senate Committee”—presumably, the

Intergovernmental Operations Committee of the Pennsylvania Senate (the

“IOC”)—to conduct an “examination” of the County’s “Voting Machines.”


agendas/2021-11-30%20Agenda.pdf?fixcache=2021121795414, Fulton County

November 30, 2021 Meeting Agenda, attached as Ex. A hereto. When

Respondent’s counsel contacted Petitioners’ counsel to learn more, she was told

that the vote was not going forward, and that the County had not, in fact, received

any request for an examination from the IOC. Email from Thomas W. King III to

Michele D. Hangley dated November 29, 2021 at 7:30 p.m., attached as Ex. B


In a subsequent discussion on December 2, Petitioners’ counsel stated that

“Fulton County planned to return its … voting equipment” to the manufacturer and

lessor, Dominion, “at the end of this month, and that [Petitioners were] considering

making the equipment available to third parties for another ‘inspection’ before

Dominion collects it.” Letter from M. Hangley to T.W. King, III dated Dec. 7,

2021, attached as Ex. C hereto. In a letter dated December 7, 2021, Respondent

made clear that such an “inspection” threatened to spoliate evidence central to

Petitioners’ claims. Id. Respondent further noted that, because of the need to

maintain the integrity of the voting equipment, its data, and its chain of custody, if

Petitioners were to return the equipment to Dominion, they should “work with

Dominion to ensure that the equipment and its data are preserved in their current

state and the equipment’s chain of custody maintained.” Id. Finally, Respondent

expressly requested that the Department of State be given “plenty of notice of any

vote on or scheduling of any ‘inspection.’” Id.

Astonishingly, Petitioners failed to honor even this simple, uncontroversial

request—one that, particularly given the pendency of this litigation, should not

even have been necessary. On December 14, 2021, Respondent learned from a

posting on Fulton County’s website that, earlier that day, Petitioners had voted to

allow examination of the County’s electronic voting equipment the very next

week. Neither Petitioners nor their counsel had notified Respondent of this

important development; instead, once again, Respondent’s counsel had to learn

about it from the internet. Respondent’s counsel immediately reached out to

Petitioners’ counsel for additional information. Petitioners’ counsel did not

respond until the following day, December 15; even then, counsel did not disclose

any details about the supposed “examination,” including what day it would take

place, who would be conducting it, or what specific activities were planned. Letter

from Chairman Cris Dush dated December 10, 2021, attached as Ex. D hereto.

There is no justification for Petitioners’ sudden, secretive rush to

compromise the integrity of Fulton County’s election equipment a second time.

The IOC has not served Petitioners with any subpoena, nor has it voted to seek

access to the County’s electronic voting equipment or associated data. Indeed, the

IOC does not appear to have met or conducted any business for three months.1

The “request” to which Petitioners are purportedly responding is a letter from a

single senator, Cris Dush, who claims to be writing “in furtherance of” the IOC’s

activities but does not purport to act on its behalf. Id. The letter has no legal


Nor can Fulton County justify a rushed, no-notice inspection based on its

stated intention to return the equipment to Dominion at the end of the year.

Dominion has confirmed that it will preserve the integrity of the equipment and its

data—and maintain its chain of custody—after it passes back into Dominion’s

custody. Letter from William E. Moschella to Thomas W. King, III, dated

December 17, 2021, at 4, attached as Ex. E hereto. Accordingly, the equipment

See https://intergovernmental.pasenategop.com/.
The letter is also hopelessly vague. It states only that Senator Dush seeks
to “collect the digital data from the election computers and hardware used by
Fulton County … in the November 2020 election.” Ex. D. No further parameters
are specified; the letter says nothing about the specific entity or persons who would
“collect the … data,” the scope of the “data” that would be collected, the means of
“collect[ion],” or how the data would be stored or secured after it is extracted. Id.

and data would remain unaltered and available for appropriate use in the course of

this litigation, as well as for any other proper purpose.

D. Petitioners Have Rejected Respondent’s Demand That They

Preserve the Integrity of the Evidence Against Third Party Access
After learning of the “inspection” planned for next week, Respondent

promptly sent a letter to Petitioners’ counsel on December 16, 2021. The letter:

(1) made clear that Respondent objected to the inspection, which would
“change, corrupt, and/or make unreliable the information stored on the
[electronic voting] equipment, thus spoliating potential evidence”;

(2) demanded that Petitioners honor their “litigation preservation

obligations” and not allow the equipment to be “accessed or interfered
with in any way until the Preliminary Objections have been ruled
upon, discovery is underway, the parties have had the opportunity to
consult with their experts to plan forensic examinations of the
equipment, and [the parties] have agreed upon an examination

(3) observed that there was no reason why Petitioners needed to provide
third-party access to the equipment at any earlier date;

(4) noted Petitioners’ initial failure to provide Respondent with advance

notice of the vote on the inspection, as well as their ongoing failure to
share the most rudimentary information about when and how the
inspection would proceed;

(5) requested that Petitioners confirm whether they still intended to go

ahead with the “inspection”; and

(6) explained that if Petitioners insisted on proceeding with the

“inspection,” Respondent would ask the Court to grant the relief
sought in this Application.

Letter from M. Hangley to T.W. King, III dated December 16, 2021, attached as

Exhibit G hereto.

Petitioners’ counsel responded later that day, stating that the “inspection”

(counsel’s word) of Fulton County’s voting equipment would proceed on

“December 22, 2021, at 9:00 a.m., at the Fulton County Courthouse and/or Fulton

County Offices.” Letter from T.W. King, III to M. Hangley dated Dec. 16, 2021,

attached as Ex. F hereto. Counsel erroneously claimed that Senator Dush’s letter

had conveyed a request “of the Pennsylvania Senate Intergovernmental Operations

Committee,” id., when in fact, as discussed above, the Committee has taken no

action, and the request was made by an individual senator. See Ex. D.

Counsel’s letter also gave the first indication of who would actually be

conducting the inspection—namely, an entity called “Envoy Sage.” Ex. F. Envoy

is a recently formed company with no election experience, no apparent physical

presence, and, at most, two identifiable employees. 3 Envoy’s president and

founder recently published an article alleging that technology companies conspired

Public records demonstrate that Envoy is barely more than a year old,
registering first in Iowa in August 2020 and then in Florida in September 2021
after Envoy’s president, Steven Lahr, purchased a house there. Business No.
639287, Business Entity Summary, Iowa Sec. of State (filed Aug. 5, 2020)
(Attached as Ex. H hereto); Doc. No. M21000012150, Fl. Sec. of State (filed Sept.
10, 2021) (Attached as Ex. I hereto). Envoy’s website provides a cursory summary
of four past projects, but none involves elections or election systems, voter
registration, or election integrity legislation. Attached as Ex. J hereto. When
specifically asked at a November 23 press conference about past election-related
experience, Mr. Lahr identified none. Press Conference Tr. (Nov. 23, 2021) at
4:23-5:11, 11:11-12:14, 15:20-16:21, attached as Ex. K hereto.

with the Democratic Party and others to “launch[] an information war” against

former President Trump, and comparing acts of the Democratic Party to the terror

tactics of various totalitarian regimes. Steve Lahr, Taming Thought Engineers,

American Greatness (Oct. 24, 2020) https://amgreatness.com/2020/10/24/taming-

thought-engineers/, attached as Ex. L; hereto.

Attached to counsel’s letter was a single page, containing less than a half-

page of text; according to Petitioners’ counsel, this document was “[t]he Envoy

Sage protocol” for the inspection. Ex. F. But this so-called “protocol” provides no

details whatsoever about the scope or methods of the “inspection.” Id.

Unhelpfully—and ominously—the “protocol” says only that the County’s “voting

systems [will] be examined,” and that the examiners will be provided with tables

and chairs “in close proximity to the voting systems.” Id. The document

conclusorily asserts that Envoy Sage “will follow proper procedure for collection

and chain of custody,” but provides no information about what that “procedure”

actually is.

In short, Respondents have not only doubled down on flouting the directives

of the Commonwealth’s chief election official regarding fundamental matters of

election security; they have grossly disregarded their obligations as litigants to

preserve evidence.

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As part of their inherent authority to supervise the discovery process and

ensure fairness to litigants, courts have the power to issue preservation orders

prohibiting conduct that threatens to destroy or alter relevant evidence. Such an

order is warranted here.

A. This Court Has Authority to Issue Preservation Orders

As the Pennsylvania Supreme Court has explained, “parties to pending and

prospective suits, upon an appropriate showing, may be able to obtain injunctive

relief to preserve evidence.” Pyeritz v. Commonwealth, 32 A.3d 687, 694 (Pa.

2011). In support of this authority, the Supreme Court cited to the federal court

decision in Capricorn Power Co. v. Siemens Westinghouse Power Corp., 220

F.R.D. 429 (W.D. Pa. 2004), which, as the Supreme Court noted, “list[s] factors

for obtaining such relief.” Pyeritz, 32 A.3d at 694. As Capricorn recites, “motions

for preservation of documents or things and orders granting such motions have

become widely used.” 220 F.R.D. at 432. The authority for preservation orders is

rooted in a trial court’s “power to control the discovery process and overall case

management.” Id at 433.

Although a preservation order takes “the form … of an injunctive order,” it

has a different “substance” because it “concerns matters within the scope of the

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rules of discovery.” Id. As a result, the “test typically applied to matters

concerning injunctive relief is not a completely appropriate test to utilize when

examining the need for a preservation order, particularly since proof of a

probability of success in the litigation is not an appropriate consideration in the

determination whether to order preservation of [evidence].” Id. Indeed, “[t]o

require such proof would be contrary to the dictates of the scope of discovery

which permits discovery of all things, not privileged, that appear to be ‘reasonably

calculated to lead to discovery of admissible evidence.’” Id. (quoting the then-

existing version of Federal Rule of Civil Procedure 26(b)(1)); compare Pa.R.C.P.

4003.1(b) (setting forth the same “reasonably calculated to lead to the discovery of

admissible evidence” standard); see also Capricorn, 220 F.R.D. at 434 (“a motion

for a preservation order can be granted with regard to all items of evidence which

are discoverable in accordance with [the rules of civil procedure], without the

necessity of establishing that the evidence will necessarily be relevant and

admissible at trial”). The appropriate test for a preservation order, then, “mold[s]

the factors used in granting injunctive relief with the considerations, policies and

goals applicable to discovery.” Id. at 433.

More specifically, courts evaluating motions for preservation orders employ

a balancing-of-the-equities test taking into account the following three factors:

(1) the level of concern the court has for the continuing existence and
maintenance of the integrity of the evidence in question in the absence

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of an order directing preservation of the evidence; (2) any irreparable
harm likely to result to the party seeking the preservation of evidence
absent an order directing preservation; and (3) the capability of an
individual, entity, or party to maintain the evidence sought to be
preserved, not only as to the evidence’s original form, condition or
contents, but also the physical spatial and financial burdens created by
ordering evidence preservation.

Id. at 433-44.

As shown below, these factors weigh overwhelmingly in favor of granting

the preservation order Respondent seeks here.

B. Allowing the Third-Party “Inspection” to Go Forward Would

Compromise the Integrity of Crucial Evidence in This Case,
Unfairly Prejudicing Respondent
The first two factors, which address the equities favoring a preservation

order, strongly support a grant of relief. As Capricorn explains, under the first

prong, “[t]he reviewing court, as well as the parties, should be focused upon

maintaining the integrity of the evidence in a form as close to, if not identical to,

the original condition of the evidence.” Id. at 434. That is a particularly acute

concern where, as here, the evidence in question includes electronic data, which

can be easily altered—intentionally or unintentionally—without ever dismantling

any hardware or even touching a keyboard. Indeed, merely connecting a storage

device to electronic equipment may substantially alter—intentionally or

unintentionally—the condition of the software and data on that equipment. See

Affidavit of Ryan Macias. Further compounding the threat here is (1) Petitioners’

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failure to provide adequate notice of the planned inspection; (2) the identity of the

inspector, Envoy Sage, which has no relevant experience with election systems and

is led by a partisan actor who has publicly credited unfounded conspiracy theories;

and (3) the lack of any details about the inspection’s parameters or methods, or the

actual protocols (if any) that will be observed. The risk of spoliation in such

circumstances is obvious and profound.

The second factor, the possibility of irreparable harm to Respondent in the

absence of a preservation order, also militates in favor of relief. This is not a

“design flaw” product liability case, in which the relevant information could be

gleaned from any of a vast number of items circulating in the stream of commerce.

In the context of this case, Fulton County’s voting machines—the very machines

that will be subjected to the “inspection” scheduled for next week—are “one-of-a-

kind,” “irreplaceable item[s].” Capricorn, 220 F.R.D. at 435. A central question

raised by Petitioners’ allegations is whether, following Wake TSI’s activities, those

machines were safe for future use. Petitioners allege the machines were

demonstrably uncompromised and in an unimpeachably secure condition, and

contend that Respondent was therefore wrong to decommission them; Respondent

disagrees. The condition of the machines following Wake TSI’s “inspection” is

thus of obvious, fundamental relevance to the case. Permitting Fulton County to

grant access to the machines to yet another third party, before Respondent has had

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an opportunity to embark on discovery and engage a testifying expert to perform a

full forensic examination of the equipment, 4 would prejudice Respondent’s ability

to refute Petitioners’ allegations. Indeed, the evidence at issue is “so integral” to

this case “that an order of preservation” would arguably be warranted “even in the

absence of a threat of imminent, significant harm to the integrity or existence of the

evidence.” Id. at 435. That such a threat exists—created solely and gratuitously

by Petitioners themselves—underscores that the court has “a judicial duty to

protect [Respondent] from likely harm by acting to prevent the loss or destruction

of evidence.” Id.

C. The Relief Sought by Respondent Would Not Prejudice

There are no countervailing equities here. The Capricorn test instructs

courts to consider whether the party that would be subject to a preservation order is

capable of “maintain[ing] the evidence sought to be preserved.” Petitioners are

plainly capable of doing so because they have been doing so since their reckless,

unsanctioned provision of access to Wake TSI. Indeed, a legal condition of Fulton

Under an agreement with Petitioners, Respondent performed a limited
inspection of the voting machines in October, solely for the purpose of determining
whether, in Respondent’s view, any of the compromised machines could
potentially be “sanitized” in a way that would allow their reuse. But this
inspection was a far cry from a forensic examination conducted for purposes of
providing expert testimony at trial. Indeed, Respondent’s representatives at the
October “examination” never touched the machines (including the keyboards) and
did not attach any drives or other devices to them. See Affidavit of Ryan Macias.

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County’s ability to use the voting machines at issue, imposed by the Secretary

pursuant to her authority under the Pennsylvania Election Code, has been that the

County “physically secure[]” the components of the voting system “while in

transit, storage, or while in use at their respective locations.” 5

In any event, the issue of burden is moot in light of Petitioners’ intention to

return the equipment at issue to Dominion at the end of the year. Dominion has

confirmed that it will secure and preserve that equipment (and any data stored

thereon) in an unaltered state. This will have the dual benefit of relieving Fulton

County of any ongoing burden or responsibility for maintaining the security of the

machines while simultaneously ensuring that this evidence is available to both

Petitioners and Respondents during the discovery phase of this case. Ex. E.

By contrast, the course on which Petitioners are currently embarked—to

rush, during the pendency of litigation focused on the condition of the County’s

voting machines, to expose those machines to yet another third-party “inspection,”

without adequate notice to Respondent or disclosure of even the most basic

Commonwealth of Pennsylvania, Department of State, Report Concerning
the Examination Results of Dominion Voting Systems Democracy Suite 5.5A With
ImageCast X Ballot Marking Device (ICX-BMD), ImageCast Precinct Optical
Scanner (ICP), ImageCast Central Station (ICC), and Democracy Suite EMS
(EMS) at 46 (Jan. 17, 2019), available at

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information—is as prejudicial as it is unnecessary. Respondent has repeatedly

attempted to persuade Petitioners—a government body and its members—to

operate transparently and to honor their obligations as litigants. But to no avail.

Judicial intervention is needed to preserve the status quo.

WHEREFORE, Respondent respectfully requests that this Court

(1) from providing any third party (other than Dominion Voting Systems) with

access to the electronic voting machines in Fulton County’s possession that are

leased from Dominion Voting Systems, including but not limited to allowing the

inspection by Envoy Sage currently scheduled for December 22, 2021, pending

further order of this Court, and (2) take all necessary steps—which may include

returning the machines to Dominion Voting Systems in a manner that maintains

chain of custody—to preserve those machines, and any data stored thereon, in a

secured and unaltered state pending further order of the Court.

Respectfully submitted,



Dated: December 17, 2021 By: /s/ Michele D. Hangley

Michele D. Hangley (ID No. 82779)
Robert A. Wiygul (I.D. No. 310760)
John B. Hill (I.D. No. 328340)
One Logan Square, 27th Floor
Philadelphia, PA 19103
Tel: (215) 568-6200
Fax: (215) 568-0300

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Stephen Moniak (I.D. No. 80035)

Karen M. Romano (I.D. No. 88848)
15th Floor, Strawberry Square
Harrisburg, PA 17120
Aimee D. Thomson (I.D. No. 326328)
1600 Arch St., Suite 300
Philadelphia, PA 19103
(717) 787-2717
(717) 787-2717



Kenneth L. Joel (I.D. No. 72370)

333 Market St., 17th Floor
Harrisburg, PA 17101
(717) 787-9348


Kathleen M. Kotula (I.D. No. 86321)

306 North Office Bldg., 401 North St.
Harrisburg, PA 17120-0500
(717) 783-1657


Joe H. Tucker, Jr. (I.D. No. 56617)

Dimitrios Mavroudis (I.D. No. 93773)
Jessica Rickabaugh (I.D. No. 200189)
1801 Market Street, Suite 2500
Philadelphia, PA 19103
(215) 875-0609

Counsel for Respondent

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I certify that this filing complies with the provisions of the Public Access

Policy of the Unified Judicial System of Pennsylvania: Case Records of the

Appellate and Trial Courts that require filing confidential information and

documents differently than non–confidential information and documents.

Dated: December 17, 2021 /s/ Michele D. Hangley

Michele D. Hangley
From: Thomas W King III <TKing@dmkcg.com>
Sent: Monday, November 29, 2021 7:30 PM
To: Hangley, Michele D.
Subject: Re: [EXT]RE: Fulton County voting equipment [IWOV-HASP1.FID141330]

Michelle, Sorry I missed you today. I was under the weather. But there will not be a motion made tomorrow
regarding the IOC since the County hasn’t received a request from the Senate IOC. Tom

Get Outlook for iOS

From: Hangley, Michele D. <mdh@hangley.com> 
Sent: Monday, November 29, 2021 2:36:42 PM 
To: Thomas W King III <TKing@dmkcg.com> 
Subject: [EXT]RE: Fulton County voting equipment [IWOV‐HASP1.FID141330]


I just left a message with your office. Would you please give me a call on my cell Redacted ? It’s about a Fulton
County Commissioners’ vote, which I understand is scheduled for tomorrow.




One Logan Square
27th Floor
Philadelphia, PA 19103-6933

Michele D. Hangley
Direct Dial: 215.496.7061
E-mail: mhangley@hangley.com

December 7, 2021

Via Email

Thomas W. King, III

Dillon, McCandless, King, Coulter
& Graham LLP
128 West Cunningham Street
Butler, PA 16001

Re: County of Fulton, et al., v. Degraffenreid, No. 277 MD 2021

Dear Tom:

I write to follow up on our conversation of Thursday, December 2. You told me that

Fulton County planned to return its Dominion Democracy 5.0 voting equipment to Dominion
at the end of this month, and that your clients are considering making the equipment
available to third parties for another “inspection” before Dominion collects it.

First, as you know, your clients have alleged that the Dominion Democracy 5.0 voting
equipment was not compromised by Fulton County’s or Wake TSI’s actions and can be
reused safely. The voting equipment itself is likely to constitute relevant evidence on this
and other issues. If Fulton County allows the equipment or its data to be destroyed or
altered, permits a break in the equipment’s chain of custody, or takes or allows other action
rendering it impossible to verify that the equipment and its data are in the same condition
as when the litigation commenced, we believe that Petitioners will be precluded from,
among other things, pursuing any argument that the equipment was uncompromised and
safe for use after Wake TSI’s “inspection,” or from attempting to refute the Acting
Secretary’s position that the equipment was compromised and unsafe. Accordingly, your
clients may wish to work with Dominion to ensure that the equipment and its data are
preserved in their current state and the equipment’s chain of custody maintained. If they do
so, please keep us informed of the details, so we can let you know if we believe that the
arrangement is not sufficient for litigation purposes.

Second, if any “inspection” takes place, Respondent must be given the opportunity
to observe and participate, as Fulton County’s consultant did when our consultant
Thomas W. King, III
December 7, 2021
Page 2

inspected the equipment. Please ensure that we have plenty of notice of any vote on or
scheduling of any “inspection.”

Please let me know if you have any questions.


Michele D. Hangley

cc: Robert A. Wiygul, Esq.
Stephen Moniak, Esq.
Aimee Diane Thomson, Esq.
Dimitrios Mavroudis, Esq.
To: Fulton County Commissioners and Board of Elections

From: Chairman Cris Dush

Date: December 10, 2021

Re: Intergovernmental Operations Chairman’s Request to Examine Voting Machines

Fulton County Leaders,

The Pennsylvania Senate Intergovernmental Operations Committee is investigating the

Pennsylvania (PA) election system. Our purpose is to confirm our election systems’ security and
integrity, ensure current law is adequate moving forward, as well as restoring PA Residents’
confidence in the results of our elections.

Voting machines are at the heart of modern elections in Pennsylvania. Therefore, this
aspect of our election system is a central part of our investigation. As Chair of the Committee
and in furtherance of the investigation being conducted by the Committee, the following is

 Permission to collect the digital data from the election computers and hardware
used by Fulton County, Pennsylvania in the November 2020 election.

We are willing to coordinate with your designated representative(s) to have this work
performed in a manner that limits disruptions to your operations, and which preserves the
equipment and data.
Brownstein Hyatt Farber Schreck, LLP
202.296.7353 main
1155 F Street NW, Suite 1200
Washington, DC 20004

December 17, 2021 William E. Moschella

Attorney at Law
202.652.2346 direct

Thomas W. King, III

Dillon McCandless King Coulter & Graham L.L.P.
128 West Cunningham Street
Butler, PA 16001
(724) 776-6644

RE: Demand to Cease and Desist and Return Dominion Voting Systems’ Equipment

Dear Mr. King:

This firm represents Dominion Voting Systems (“Dominion”). I write because Dominion is in receipt of
your December 16, 2021 letter where you represent that you are Special Counsel to Fulton County,
Pennsylvania (“Fulton County”) and the Fulton County Board of Elections. You letter further states
that Fulton County will be providing the Pennsylvania Senate Committee and its contractor access on
December 22, 2021, to review and copy information contained on Dominion’s equipment.

As Dominion has informed Fulton County, Dominion will gladly consent to having a federally-
accredited, independent Voting System Test Lab access Dominion’s System for testing purposes.1
There is no indication, however, that the process you describe in your letter will be conducted by a
federally-accredited test lab. To the contrary, given the history here—including Fulton County’s prior
improper conduct in providing Wake TSI access to the Dominion System—Dominion is understandably
highly concerned that the proceedings you describe as planned for December 22, 2021, will be just as
fraudulent and improper as your client’s prior Wake TSI misconduct.

As Fulton County knows, Dominion’s voting systems were installed in full compliance with federal and
Commonwealth certification requirements, with associated test reports from a federally-accredited
Voting System Test Lab. Dominion issued a Customer Notification on August 25, 2021 regarding
maintenance of a secure chain of custody for voting systems. As the County is aware, a fundamental
requirement to ensuring the integrity and security of Dominion’s systems, which have been
designated U.S. critical infrastructure, is maintaining strict access limitations and a clear chain of
custody to prevent tampering and unauthorized uses. Dominion’s notification specifies that any
unauthorized transfer of voting equipment can void an agreement, pursuant to the license and

1 Dominion supports post-election audits conducted by federally-accredited Voting System Test Labs.

Thomas W. King, III
December 17, 2021
Page 2

warranty terms. The County’s non-exclusive, non-transferable licensing agreement prohibits the
following acts without Dominion’s prior written permission:

• Transferring or copying onto any other storage device or hardware or otherwise copying the
software in whole or in part except for purposes of system backup.

• Reverse engineering, disassembling, decompiling, deciphering, or analyzing the software in

whole or in part.

• Altering or modifying the software in any way or preparing any derivative works of the
software or any part or parts of the software.

• Altering, removing, or obstructing any copyright or proprietary notices from the software, or
failing to reproduce the same on any lawful copies of the software.

Dominion expressly does not provide Fulton County permission to do any of those actions.

In any event, Fulton County has no need or obligation whatsoever to provide the Senate
Intergovernmental Operations Committee with access to “inspect and copy information from the
Dominion Equipment.” As your client knows, the County’s 2020 election data from Dominion’s
equipment used in the November 2020 election remains in County possession through established
data retention practices guided by existing federal and state requirements. Because your client has a
copy of the requested data separate and apart from what resides on Dominion’s equipment, there is
no need to provide this equipment to any third-party. The County can comply with the request by
simply providing the Committee with its copy of the data being requested.

For that reason, as well as the fact that no subpoena (let alone a proper, enforceable subpoena) has
been issued here, the premise of your letter is wrong. Pursuant to your letter, it appears that Fulton
County is taking the position that Sections 13.2 and 13.3 of the parties’ Voting System and Managed
Services Agreement, as amended (the “Agreement”),2 permits the County to provide the Pennsylvania
Senate Committee and its contractor access to Dominion’s equipment and software after Chairman
Cris Dush’s December 10, 2021 letter requested “the digital data from the election computers and
hardware used by Fulton County, Pennsylvania in the November 2020 Election.” This is simply
incorrect. Section 13.2 of the Agreement permits disclosure only if it “is made in response to, or
because of, an obligation to any federal, state, or local governmental agency or court with
appropriate jurisdiction.” (Emphasis added.) Here, Fulton County has no legal obligation to provide
access to Dominion’s equipment. The County is not under any subpoena, and just as importantly, the
County has a copy of the requested data pursuant to state and federal data retention requirements,
and thus has no need whatsoever to provide access to Dominion’s Equipment. Indeed, voting

Capitalized terms not otherwise defined in this letter shall have the meanings given to them in the Agreement.
Thomas W. King, III
December 17, 2021
Page 3

equipment inspections are not part of the scope of work in the contract between Envoy Sage, LLC, the
firm hired to perform the inspection, and the Senate Intergovernmental Operations Committee.

In light of all this, the Agreement prohibits, rather than permits, Fulton County’s intended actions. If
Fulton County decides to move forward, it actions will constitute but another breach of the

To avoid any doubt, since Sections 13.2 and 13.3 of the Agreement do not apply, any transfer by
Fulton County of Dominion’s software and/or machines without the company’s express written
consent is strictly prohibited by the Agreement. As you know, the software and machines provided to
Fulton County are Dominion’s property. Title to the System remains with Dominion, and Dominion
Software is licensed, not sold. (See Agreement, §§ 6.1, 6.2.) Per Section 7.1 of the Agreement,
Dominion granted Fulton County a non-exclusive, non-transferable, license to use Dominion Software
subject to the terms and conditions of the Agreement, including its confidentiality provisions, and the
Software License Terms attached thereto.

The Software License Terms are clear. (See Agreement, Ex. B.) Section 2.1 provides that Fulton
County “may only use the Software for its own internal business purposes and conducting elections
and solely in conjunction with the EMS Hardware.” It then states that “[t]he License shall only be
effective during the Term and cannot be transferred or sublicensed.” (Emphasis added.) Section 2.4
further clarifies that by entering into the Agreement, Fulton County cannot license or assign any
intellectual property to third parties and “shall have no power to transfer or grant sub-licenses for the
Software.” “Any use of all or any portion of the Software not expressly permitted is strictly prohibited.
(Id.) Likewise, Section 5 prohibits, without prior written permission of Dominion, the transfer, reverse
engineering, alteration, or modification of the Software, among other things.

Fulton County knows full well that granting the access it has described in its December 16, 2021 letter
would be in breach of the Agreement because Dominion had previously notified Fulton County in April
2021 that the County was in breach of the parties’ agreements when it gave access to Dominion’s
equipment to Wake TSI without notifying the Department of State or Dominion. Fulton County’s
actions ultimately resulted in formal decertification of that equipment by the Secretary of the
Commonwealth.3 The situation necessitated that Fulton County and Dominion enter into a Hardware
Rental, Software License and Services Agreement, dated April 29, 2021 (the “Rental Agreement”).
Under this Agreement, Dominion provided a one-time equipment rental to Fulton County for the May
18, 2021 primary election. The terms of the Rental Agreement mirror those in the Agreement.

Moreover, in addition to the breaches identified above, it has come to Dominion’s attention that
Fulton County has recently without notice taken a series of purported actions indicating that the

Thomas W. King, III
December 17, 2021
Page 4

County will not be renewing the Agreement. The Agreement makes clear that if Termination is to be
sought, the County must “forthwith return to [Dominion] all Software in its possession or control, or
destroy all such Software from any electronic media, and certify in writing to [Dominion] that it has
been destroyed.” (Agreement, Ex. B, § 6.) This letter thus also serves as an official notice of
Dominion’s request for equipment return. Dominion will maintain the chain of custody and preserve
the equipment in its current state pursuant to the status of ongoing litigation between the County and
the Department of State.

Therefore, Dominion demands that Fulton County return all Dominion property currently in its
possession, and immediately cease and desist from providing Dominion’s System, including any
software, equipment, and machines, to third-parties. Doing so is a direct violation of the parties’

Dominion further demands that Fulton County, including its Commissioners, preserve all documents
and communications, including email, text messages, and other electronically stored information,
concerning Dominion’s software and machines and any audits of 2020 election and subsequent
election results. Failure to preserve such documents and communications may result in a violation
of federal and state laws, rules of procedure, and future discovery obligations.

As for Chairman Dush’s request for permission to review “digital data from the election computers
and hardware used by Fulton County, Pennsylvania in the November 2020 election,” returning
Dominion’s equipment will not hinder the County’s ability to meet this request if so desired. That is so
because, again, the County (pursuant to state and federal data retention requirements) has its own
copy of that data.

Dominion desires to resolve any disputes related to this letter amicably and efficiently. To that end,
Dominion requests your prompt attention to this matter and a response from Fulton County by close
of business on Monday, December 20th. However, should Fulton County fail to cease and desist, or
to return Dominion’s software and equipment, Dominion will promptly pursue all available legal
remedies, including seeking damages, costs, and attorneys' fees. Dominion reserves all rights and
remedies available at law and equity.


William E. Moschella
cc: Mr. Timothy Gates, Chief Counsel, Department of State
Office of the General Counsel, Dominion Voting Systems
One Logan Square
27th Floor
Philadelphia, PA 19103-6933

Michele D. Hangley
Direct Dial: 215.496.7061
E-mail: mhangley@hangley.com

December 16, 2021

Via Email

Thomas W. King, III

Dillon, McCandless, King, Coulter
& Graham LLP
128 West Cunningham Street
Butler, PA 16001

Re: County of Fulton, et al., v. Degraffenreid, No. 277 MD 2021

Dear Tom:

Your clients’ allegations in this case center on Fulton County’s Dominion Democracy
Suite 5.5A election equipment. A key issue is whether that equipment was or could have
been compromised when Wake TSI, an unqualified and unvetted third party with no election
administration role, was given access to the equipment in December 2020. Given the likely
evidentiary importance of the equipment, I was surprised to learn that Fulton County has
voted to give yet another third party an opportunity to access the equipment and
manipulate its data. This activity will change, corrupt, and/or make unreliable the
information stored on the equipment, thus spoliating potential evidence.

I was even more surprised that I did not learn about Fulton County’s plans from you,
despite your litigation preservation obligations and my written request that you keep me
informed about the condition of the equipment. Even now that I have gotten wind of your
clients’ vote from another source and contacted you, you have not shared any information
about the supposed “inspection,” including when it will take place (I have heard December
22 from one source and December 23 from another), who will be conducting the
“investigation,” or what activities are planned.

My client does not consent to this third party “inspection.” To ensure the integrity of
potential evidence, Fulton County’s Dominion Democracy 5.5A equipment should not be
accessed or interfered with in any way until the Preliminary Objections have been ruled
upon, discovery is underway, the parties have had the opportunity to consult with their
Thomas W. King, III
December 16, 2021
Page 2

experts to plan forensic examinations of the equipment, and we have agreed upon an
examination protocol.

We are not aware of any reason that Fulton County needs to give a third party access
to the equipment before then. The letter from Senator Dush that you shared with me is
simply a request from an individual legislator, with no legal force. If Fulton County’s
concern is that the equipment be preserved after it is returned to Dominion, I believe
Dominion would agree to seal and store the equipment and make it available when

Please let me know by 12PM tomorrow, Friday, December 17, whether Fulton
County still intends to go ahead with the “inspection.” If Fulton County insists on
proceeding, we will ask the Court to prohibit the “inspection” and order your clients not to
permit any other interference with the equipment.

I look forward to hearing from you.


Michele D. Hangley

cc: Robert A. Wiygul, Esq.
Stephen Moniak, Esq.
Aimee Diane Thomson, Esq.
Dimitrios Mavroudis, Esq.
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https://www.envoysage.com 7/7
Page 1

7 Transcription of Press Conference based on Audio File Envoy

8 Sage press conference_otter_ai

















TSG Reporting - Worldwide 877-702-9580

Page 2
1 (Beginning of Audio Recording.)
2 SENATOR DUSH: All right, thanks --
3 thanks (inaudible) people to get off instead
4 of being blocked off or missing part of this.
5 Good afternoon. My name is Senator Cris
6 Dush. I'm chairman of the Senator
7 Intergovernmental Operations Committee, and I
8 appreciate you taking the time to join
9 today's media call.
10 As chair of the Senate
11 Intergovernmental Operations Committee, one
12 of my tasks is to lead our PA election
13 investigation efforts. Today we find
14 ourselves at a crossroads when it comes to
15 the integrity of our election process. An
16 F&M poll conducted in August reflected the
17 first time in the history of the poll a
18 noticeable number of Pennsylvania voters
19 mentioned election integrity as one of the
20 state's pressing issues.
21 And 40 percent of all Pennsylvania
22 voters in that Franklin and Marshall poll
23 supported the PA election investigation.
24 As elected officials representing the
25 people of our commonwealth, it is our

TSG Reporting - Worldwide 877-702-9580

Page 3
1 responsibility to ensure that people can have
2 trust in our elections and in the process,
3 and we must earn their trust.
4 To accomplish that, we must find out
5 where the weaknesses and strengths are in our
6 system and make appropriate changes to
7 address those weaknesses so we can ensure
8 election integrity.
9 That is why we have contracted with
10 Envoy Sage, LLC. In a few moments, you will
11 hear from Steve Lehr, president of Envoy
12 Sage, the firm selected to help with the
13 investigation.
14 Please keep in mind, this is an
15 investigation, and we must protect the
16 reliability of that investigation, which
17 means that information and updates will be
18 provided as we are able through the committee
19 and Envoy Sage. But that may not occur as
20 often as some might prefer.
21 With that, I will now turn this call
22 over to our call moderator, Dawn Lush, who
23 will walk you through a few instructions.
24 Thank you, Dawn.
25 DAWN LUSH: Thank you, Senator. And

TSG Reporting - Worldwide 877-702-9580

Page 4
1 again, there was a question if there would be
2 follow-up questions after the Q&A portion.
3 You can always ask your question and maybe
4 press Star 3 again, but there will be no
5 back-and-forth. You will be put live in the
6 line, you will have an opportunity to ask
7 your question, and then you will be muted so
8 that Steve can answer your question.
9 If you have follow-up questions,
10 please press Star 3 to go through the
11 screening process again, and with that, I'm
12 going to turn it over to Steve Lehr,
13 president of Envoy Sage, LLP. Steve, take it
14 away.
15 STEVE LEHR: Thank you, Dawn. And
16 thank you, Senator Dush.
17 Hello, everyone. It's a pleasure to
18 speak with you today. My name's Steve Lehr,
19 and I'm the president of Envoy Sage. My
20 company was selected to assist the Senate
21 Intergovernmental Operations Committee with
22 Pennsylvania election investigation.
23 Our firm was chosen after an extensive
24 interview process. It is an honor to have
25 been chosen to assist in this effort. I've

TSG Reporting - Worldwide 877-702-9580

Page 5
1 been conducting complex research
2 investigations, audits, and analysis for more
3 than 35 years. This experience was garnered
4 first in the military and then in the private
5 sector.
6 In both arenas, I've built and led
7 teams and successfully delivered crucial
8 information and intelligence, which were the
9 result of extensive, complicated, and
10 sensitive investigation and research, and
11 multi-discipline analysis.
12 We routinely and effectively handled,
13 transported, and protected highly classified
14 governmental material and personal
15 information. We did so while maintaining
16 chain of custody requirements and DOD
17 protocols for evidence, even when operating
18 in dynamic, strict, and high-risk
19 environments.
20 This past performance provides a
21 strong foundation as we move forward to
22 support the Senate investigation. Our role
23 is to provide investigative expertise, tools,
24 and analysis that are not organic to the
25 Senate.

TSG Reporting - Worldwide 877-702-9580

Page 6
1 We are focused exclusively on election
2 integrity. Our team will begin with an
3 examination of the 2020 general and the 2021
4 primary elections in the Commonwealth of
5 Pennsylvania, followed by an analysis of
6 voter submissions made the committee's
7 website.
8 Next will be a review of previous
9 election audit-related materials, and then we
10 will provide recommendations based on
11 analysis of fact for future election and
12 voting integrity legislation.
13 We are aware that there is a subpoena
14 currently undergoing a legal challenge in the
15 Commonwealth court, and to the extent those
16 are yet undecided, I will not discuss the
17 procedures or efforts that we may or may not
18 take in the future regarding the materials
19 requested in that subpoena.
20 Our function here is the provide the
21 committee with clarity, facts, and analysis.
22 We have no preconceived notions of what we
23 will or will not find. Facts as they are
24 gathered, both digital and physical, will
25 drive our investigative services.

TSG Reporting - Worldwide 877-702-9580

Page 7
1 We will handle all concerns, data, or
2 information presented by the citizens of the
3 Commonwealth through the website or to us by
4 the committee with fidelity due diligence,
5 and the utmost discretion. Our team will
6 diligently and professionally protect and
7 secure any and all personal information that
8 we are tasked to analyze if such information
9 comes available to use at any time during the
10 investigation.
11 Envoy Sage follows industry best
12 practices for information security, handling,
13 and disposal. Our company policies,
14 standards, and procedures meet or exceed the
15 contract requirements as well as the
16 guidelines from the National Institute of
17 Standards in Technology, their cybersecurity
18 framework or NIST CSF, as well as DOD
19 protocols for the protection of PII and
20 sensitive data.
21 The Senate has made it very clear our
22 efforts must meet the highest standards of
23 professional ethics and integrity. They have
24 engaged in a good-faith contract with Envoy
25 Sage, and we will fulfill our contractual

TSG Reporting - Worldwide 877-702-9580

Page 8
1 obligations in a manner that keeps with the
2 highest traditions of investigatory
3 procedure, ethics, and professional conduct.
4 Thank you.
5 I will now turn it back to our call
6 moderator for Q&A.
7 DAWN LUSH: Okay, thanks everybody.
8 We're going to take our first call. Joe
9 Natcha (phonetic) from the Tribune Review in
10 Greensburg, you're live on the air.
11 JOE NATCHA: Yes, Senator, how was
12 Envoy Sage selected? There was a no-bid
13 contract, obviously. How many companies bid?
14 How many companies were interviewed for this
15 process?
16 SENATOR DUSH: Yeah, thank you for the
17 question. That's really a response required
18 by the Committee. I'm not permitted to
19 discuss that as part of our contract. Thank
20 you.
21 DAWN LUSH: And thanks for that call.
22 Next, we have Danielle -- pardon if I don't
23 pronounce it correctly -- Danielle Ohl,
24 Spotlight PA. You're live.
25 DANIELLE OHL: Yeah, thanks. My

TSG Reporting - Worldwide 877-702-9580

Page 9
1 question is -- can you tell us the names of
2 the people who work for Envoy Sage and what
3 they do for the firm?
4 STEVEN LEHR: Well, thank you for the
5 question. That might take all day. I'll
6 tell you, my name's Steve Lehr. I'm the
7 founder and president, and we've got sitting
8 in the room, Mike Mull (phonetic), and then
9 we've got a great team of staff personnel as
10 well as (inaudible) that support us and help
11 us drive our -- conduct our analysis,
12 conclusions, research, and investigation.
13 Thank you.
14 DAWN LUSH: Eddie Kizo (phonetic) from
15 WNTP in Philly, you are next.
16 EDDIE KIZO: Yes, thank you. So
17 Senator, if something is found, right, what
18 is the next step after this? For example,
19 (inaudible) Philadelphia was on the cover of
20 the Inquirer ballot harvesting. Nothing
21 happened to him, and that story went away.
22 So what happens next after this process?
23 Thank you.
24 SENATOR DUSH: Thank you very much for
25 the -- for the question. I will certainly

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Page 10
1 refer that question to the committee, and it
2 would be more appropriate for the committee
3 and the chair to answer that.
4 DAWN LUSH: Okay. Dan Murphy at
5 PennLive. You're on the air.
6 DAN MURPHY: Hi there. I was
7 wondering as a follow-up to Danielle's
8 question of how many people on your team will
9 have access to the information. It sounds
10 like you said there's so many that you
11 couldn't name them all. And also, with
12 regard to the previous examinations that
13 legislative committees have done into the
14 election, I was wondering if you're familiar
15 with what -- what their work what they found
16 did and didn't work with the 2020 election
17 and what will this $270,000 that taxpayers
18 are going to spend on this going to buy them
19 that they haven't already heard?
20 SENATOR DUSH: Thank you very much.
21 Again, I've got the same response about the
22 question. It's getting into the details of
23 how we'll conduct the investigation, and I'm
24 not at liberty to discuss those procedures.
25 That is a more appropriate question for the

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Page 11
1 committee that is conducting the
2 investigation. Thank you.
3 DAWN LUSH: Okay. We've got Andrew
4 Seidman, although Andrew, I don't see where
5 you're calling from. Andrew, where are you
6 calling from, what organization?
7 ANDREW SEIDMAN: Hi, yes. I'm calling
8 from the Philadelphia Inquirer.
9 DAWN LUSH: Okay, thanks. Go ahead,
10 Andrew. You're live.
11 ANDREW SEIDMAN: Thank you. Mr. Lehr,
12 I understand you can't speak much about --
13 about the investigation. Can you tell us a
14 little bit more about your past experience?
15 What is your relevant experience that you
16 bring to this investigation, and have you --
17 either for Envoy Sage or your previous
18 companies ever investigated an election or
19 election administration? That's my first
20 question.
21 And my second question is what do you
22 make of -- what is your assessment of the
23 reviews that took place earlier this year in
24 Arizona, and do you see that as a potential
25 model for your review?

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Page 12
1 STEVEN LEHR: Thank you very much for
2 that -- for that question. With regard to
3 the first part of your question about the
4 investigation, what I would say is that going
5 back to my opening remarks, I've got 35 years
6 conducting investigation, complex research,
7 and then doing multi-functional analysis.
8 That goes to due diligence, finding
9 personnel, conducting intelligence, and
10 garnering facts, and providing those facts
11 and analysis to the stakeholders. We think
12 that will set -- be very valuable to the
13 Senate committee investigating this -- and
14 could you repeat the second question, please?
15 DAWN LUSH: I'm sorry, he is no longer
16 on the air right now. Let's see --
17 STEVEN LEHR: Oh, I recall now. You
18 had a question about whether the
19 investigation in other states, specifically
20 Arizona, might be a useful guide.
21 You know, we have followed the
22 investigations in other states. Some of
23 their process and procedures may or may not
24 be useful to the investigation. To the
25 extent that some of those process and

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Page 13
1 procedures are useful, we will certainly take
2 them under advisement and incorporate them
3 into our system.
4 But we don't want to come into the
5 investigation with any preconceived notions,
6 and certainly, we want to stay impartial and
7 don't want this to devolve into a, you know,
8 media event. Thank you.
9 DAWN LUSH: Thank you, Steve. We're
10 going to go now to Justin at City and State
11 PA. Justin, you're live.
12 JUSTIN SWEITZER: Yeah, hi. Thanks
13 for taking my question. My question centers
14 around donations that you've made, Mr. Lehr,
15 in the past to Republican candidates. I know
16 that Democrats have been very critical of
17 this election investigation effort, calling
18 it a partisan effort.
19 So I wanted to see what your response
20 would be to their claims that your kind of
21 history of donating to Republican candidates
22 only underscores that this is a partisan
23 review.
24 STEVEN LEHR: Yeah, thank you very
25 much for that question. You know, I think

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Page 14
1 some of the items that I saw in the press
2 were referencing a recent donation a couple
3 years ago to Lindsay Graham for $250. You
4 know, that's a family member of mine donated
5 that amount.
6 As an American citizen, I don't think
7 it takes away my ability to, on the personal
8 side, provide a support to candidates on the
9 left or the right. I've supported candidates
10 that are Democrats and candidates that are
11 Republicans, and I have worked professionally
12 for both administrations, Democrat and
13 Republican, and I've been able to put a
14 firewall between my personal and professional
15 business dealings, and I've been quite
16 successful and hired by and have been
17 continued to be hired by both -- both
18 administrations. And I see myself as very
19 bipartisan, fair, and will conduct myself as
20 such.
21 DAWN LUSH: Thank you, Steve. Next up
22 is Marley Parish of Capitol Star. Go ahead,
23 Marley.
24 MARLEY PARISH: Hi, thanks for taking
25 my question. This is following up on

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Page 15
1 Danielle and Dan's question. How many people
2 are on your team, and is that going to be
3 enough in terms of conducting this
4 investigation and going through all the
5 information that was referenced in opening
6 remarks?
7 STEVEN LEHR: Yeah, certainly. Thanks
8 for the question. Our team has got the
9 ability to scale when we need more members
10 and more expertise. We add them to the team,
11 either as a fulltime effort, 1099, or
12 subcontractors. And when we need to
13 contract, we're able to do that.
14 So we are very agile in growing the
15 team rapidly with expertise and supporting
16 the client as needed during the investigatory
17 process. Thank you.
18 DAWN LUSH: (Inaudible) Mark Levy with
19 the Associated Press. You're up.
20 MARK LEVY: Hi, Mr. Lehr. So what I
21 think I hear you saying is that you don't
22 have any experience specific to elections,
23 but given your description of the past work
24 you've done, I was wondering if there is a
25 contract that you could describe in detail

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Page 16
1 the work you did on it, something that maybe
2 you're particularly proud of that would give
3 us sort of a sense of what you mean when you
4 say you've handled information, done
5 investigations?
6 STEVEN LEHR: Yeah, thank you for
7 that. Most of our work is confidential and
8 classified at the highest levels from the --
9 for the U.S. Government and the Department of
10 Defense. So I'm not at liberty to discuss
11 those contracts and especially the details of
12 those contracts.
13 I will leave it with you to reiterate
14 what we said earlier. We handled a great
15 deal of personal information and classified
16 information while we conducted investigations
17 for government agencies and -- and the
18 Department of Defense. That information,
19 those techniques, our procedures will be very
20 valuable to the Senate investigation. Thank
21 you.
22 DAWN LUSH: Okay. And we have time
23 for one more caller. Jonathan Lai with the
24 Inquirer. Jonathan, you're on.
25 JONATHAN LAI: Okay, thanks. This is

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Page 17
1 a question for Steve. I heard what you said
2 about no preconceived notions, and I know you
3 can't get too deep into (inaudible). But I'm
4 still a little confused as to what exactly
5 you'll be doing, and I'm wondering if you can
6 tell us some of the specific types of
7 questions you're trying to answer.
8 So for example, are you trying to find
9 voter fraud specifically? You know, what are
10 some of the things you're trying to
11 determine?
12 STEVEN LEHR: Yeah. Thank you for
13 that question. You know, we're focused on an
14 examination of the -- of -- we're focused on
15 election integrity, and our team, as I
16 mentioned earlier, is going to begin with an
17 examination of the 2020 general and 2021
18 primary elections in the Commonwealth of
19 Pennsylvania.
20 Then we're going to shift and conduct
21 an analysis of voter submissions made to the
22 committee's website, followed by a review of
23 previous election audit-related materials,
24 and then we're going to provide
25 recommendations based on analysis of fact for

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Page 18
1 future election and voting integrity
2 legislation. Thank you.
3 DAWN LUSH: Okay. That wraps up the
4 Q&A portion of our call. We have some final
5 words from Senator Dush. Go ahead, Senator.
6 SENATOR DUSH: Yes, thank you, and
7 this is Senator Dush, and I want to thank all
8 the reporters and media outlets for being
9 part of this call.
10 I offer special thanks to Steve for
11 making himself available today, and I think
12 this call was informative and helpful, and I
13 look forward to seeing the great work Envoy
14 Sage is going to do in helping us investigate
15 and strengthen our election system.
16 We will continue to keep you informed
17 as the next steps of the investigation as
18 that information is available. Thank you,
19 all, again, for participating.
20 AUTOMATED VOICE: The Access Live
21 event has ended.
22 (End of Audio Recording.)



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I, Wendy Sawyer, do hereby certify that I was


authorized to and transcribed the foregoing recorded


proceedings and that the transcript is a true record, to


the best of my ability.


DATED this 2nd day of December, 2021.



















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ÿ ÿÿÿ  ÿ 



622   21717207212 2 028
ÿ ÿÿÿ  ÿ 


622   21717207212 2 128

ÿ ÿÿÿ  ÿ 


622   21717207212 2 828








I, Ryan Macias, declare and affirm under the penalties of 18 Pa.C.S. § 4904 that:

1. I am over 18 years of age, of sound mind and otherwise competent to make this

Affidavit, which I submit in support of Respondent’s Emergency Application

for an Order Prohibiting Spoliation of Key Evidence Scheduled to Occur on

December 22, 2021.

2. My areas of expertise include election technology, security, and policy.

3. My curriculum vitae is attached to this report as Exhibit 1.


4. I am the owner of RSM Election Solutions LLC, an election technology and

cybersecurity consulting and advising company organized in Washington, D.C.,

registered as a foreign LLC in Texas, and operating out of Dallas, Texas. RSM

Elections Solutions LLC’s core principle is: Resiliency in the election

infrastructure = Securing election technology + Mitigating risk to the

democratic process.

5. I am a subject matter expert with over 16 years of experience in election

technology, security, and policy. In this capacity, I have developed strategies

and advise the election community on ways to build resiliency in the election

infrastructure. I engage directly with election officials to identify risks to the

election infrastructure and processes, as well as highlight mitigative measures,

compensating controls, and best practices that election officials and private

sector partners can implement to manage the risks. For the November 3, 2020,

General Election, I also served as an expert, observing the hand count audit and

recount in Fulton County, Georgia. Since the 2020 General Election, I have

provided multiple export reports, opinions, and conducted inspections and

observations of reviews of the election and voting equipment used in the

election that have been performed by entities that are not federally accredited to

3398305 2
perform such tasks, including the Rebuttal Report 1 of the Allied Security

Operations Group (ASOG) review of the DVS D-Suite 5.5 voting system used

in Antrim County, Michigan, the expert declaration of the Arizona Senate and

Cyber Ninjas review of the Maricopa County ballots and election equipment

from the 2020 General Election – which WAKE TSI was subcontracted – and

was named an expert observer by Arizona Secretary of State Katie Hobbs to

report findings. 2 Previously I was the Acting Director of U.S. Election

Assistance Commission (EAC) Voting System Testing and Certification

Program, where I was the lead on modernizing the Voluntary Voting System

Guidelines (VVSG), version 2.0, 3 which focus on ensuring all voting systems

are secure, accurate, and accessible. I developed the 17-Functions process

model that defined the scope of the VVSG 2.0 so that non-traditional election

technologies could be tested to the same standards as traditional voting systems.

Further, in that role, I managed multiple voting system applications and testing

campaigns including the Dominion Democracy Suite 5.5-A Voting System used

in Fulton County, Pennsylvania. As a Lead Auditor for International Standards

Organization (ISO) 9001 Quality Management Systems and ISO/IEC 17025

https://www.eac.gov/sites/default/files/eac_assets/1/6/VVSGv_2_0_Scope-Structure(DRAFTv_8).pdf (last
accessed October 7, 2020).

3398305 3
Testing and Calibration Laboratories, I regularly performed audits on federally

accredited voting systems testing laboratories (VSTLs) and registered voting

system manufacturers. Prior to joining the EAC, I spent 10 years with the

California Secretary of State developing and implementing legislation, policies,

and procedures on election technology and security, including serving as the

technology lead for the Post-Election Risk-Limiting Audit Pilot Program from

2011 to 2013. 4

6. In preparing this declaration, I reviewed information and communications

related to Petitioners’ plan to grant access to Fulton County’s Electronic Voting

Equipment to “Envoy Sage”—a third party with no apparent election

experience—as well as communications from Petitioners’ counsel regarding the

same. I was also present at the Fulton County Courthouse and Fulton County

Offices on October 13, 2021, where I took part in a limited inspection of Fulton

County’s voting equipment as part of a preliminary effort to determine whether

any of the compromised machines could potentially be “sanitized” in a way that

would allow their reuse (the “Limited Inspection”). My opinions below are

based on my experience in election technology, security, and policy and my


3398305 4
review of the above-described materials. The facts stated below are based on

my personal knowledge.

I. The Planned Third-Party Access to Fulton County’s Electronic Voting

Equipment Presents a Grave Risk to Maintaining the Integrity – and
Thereby the Security - of that Equipment and the Data Residing on the

7. Correspondence from Petitioners’ counsel to representatives of Dominion

Voting Systems, Inc., dated December 16, 2021 (attached as Exhibit 2),

indicates that the Fulton County Board of Elections plans to allow for a third

party to “review” and “copy” the data contained on its Electronic Voting

Equipment on December 22, 2021.

8. That correspondence attaches a memorandum from Senator Chris Dush,

requesting “[p]ermission to collect the digital data from the election computers

and hardware used by Fulton County, Pennsylvania in the November 2020

election.” (Id.)

9. As reflected in further correspondence from Petitioners’ counsel dated

December 16, 2021 and addressed to counsel for Respondents (attached as

Exhibit 3), Petitioners plan to allow a third-party called “Envoy Sage” to carry

out this “inspection” under a so-called “protocol” attached thereto (the “Envoy

Sage Protocol”).

3398305 5
10. The Envoy Sage Protocol is highly irregular and does not conform to any type

of industry standard for such a document. It is completely devoid of detail on

the inspection’s parameters or methods, or the actual security protocols (if any)

that will be observed.

11. The vague and unprofessional nature of the Envoy Sage Protocol itself

suggests that Envoy Sage is unprepared and unqualified to conduct any

inspection of the equipment.

12. To the extent the Envoy Sage Protocol does provide any insight into the

planned activities, it solely references the “collection of data” from the

equipment. The lack of a description of the process and protocols for collecting

that data and for preserving the integrity of the data and voting system is

particularly alarming. If proper protocols are not adhered to the equipment in

question includes electronic data which can be easily altered—intentionally or

unintentionally—without ever dismantling any hardware or even touching a

keyboard. Indeed, by merely connecting a storage device to electronic

equipment, malicious software can be executed to substantially alter the

integrity of the software and any data on that equipment. And, importantly,

once such data is altered, it may be difficult, if not impossible, to trace things

back to determine the status quo ante, i.e., to see what data, if any, was altered,

3398305 6
and how. As such, the lack of proper security protocols for “collect[ing]” data

from Fulton County’s Electronic Voting Equipment could irrevocably

undermine the ability to review, examine, or analyze the condition of the

equipment and data as it existed prior to Envoy Sage’s activities.

13. Appreciation of this risk is precisely why proper protocols were followed

during the Limited Inspection of which I took part on October 13, 2021. In fact,

neither I nor any representative of Respondents so much as touched a keyboard

connected to Fulton County’s Electronic Voting Equipment during the Limited

Inspection. Nor was any data downloaded or otherwise “collected.” For that

reason, there was not any external hardware connected to nor was there any

software introduced onto the voting system. The Envoy Sage Protocol is

alarmingly devoid of such language, and the stated intent to “collect” data from

the equipment all but guarantees that such condition would be breached.

14. I understand that statements made in this affidavit are made subject to the

penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities.

. Digitally signed by Ryan

Ryan Macias Date: 2021.12.17 12:39:34
Ryan Macias
Date: _____12/17/2021_______________

3398305 7
Lead to the Technical Guidelines Development Committee (TGDC) a federal advisory committee
encompassing experts in the field of security, accessibility, standards development that advise on
the development of HAVA compliant election technology principles, guidelines, and standards.
Collaborated with state and local election officials implementing new legislation, rules, regulations,
and standards for election infrastructure.
Developed strategies and methodologies for balancing security with accessibility in election
technology in compliance with the Help America Vote Act (HAVA) 2002.
U.S. EAC– Sr. Election Technology Program Specialist (05/2016 – 05/2019)
Engineered a new strategic approach for federal certification of voting systems, restructuring
internal policies, processes, and procedures - focusing on the auditing and conformance to
International standards for security, quality assurance, and configuration management.
Transformed the scope of voting system standards to implement a functional process-based model
providing adaptability across multiple election technologies.
Project Manager for federal voting system certification - analyzing voting systems to determine
conformance with federal standards, policies, and procedures.
Developed nationally recognized publications and trainings on the best practices for securing,
procuring, and implementing election technology; many of which have been referenced in technical
or policy related publications.
Implemented a risk-based approach to analyze and identify current threats and challenges in
election technology, particularly regarding cybersecurity and information operations.
California Secretary of State– Sr. Election Technology Analyst (08/2006 – 05/2016)
Collaborated with legislators, election officials, and special interest groups to develop legislation,
regulations, and policies for election systems including the California Voters Choice Act, California
Voting System Standards, and remote accessible vote by mail systems legislation and standards.
Advise the Secretary of State and Executive Staff on the certification and implementation of
election technologies, such as voting systems and remote accessible vote by mail technologies to
ensure that all voters have an opportunity to vote privately and independently.

Education & Professional Certifications

Bachelor of Science, Business Administration (Finance) – California State University, Sacramento
Certified Election/Registration Administrator (CERA)
Lead Auditor - ISO 9001 & ISO 17025
Certified as a Protected Critical Infrastructure Information (PCII) Authorized User

Organizations & Committees

Member – National Task Force on Election Crises
Program Committee Member – E-Vote-ID 2020: International Conference for Electronic Voting
Steering Committee Member for the Center for Internet Security (CIS) Rapid Architecture-Based
Election Technology Verification (RABET-V)
Former State of California appointee to the U.S. EAC’s Standards Board
Projects & Publications
Rebuttal Report to the Allied Security Operation Group (ASOG) Antrim Michigan Forensics
Election Security Risk in Focus: Ransomware – Trained hundreds of election administrators on the
cybersecurity risks and mitigative measures related to ransomware in the election infrastructure.
MEMORANDUM in Opposition re13 MOTION for Preliminary Injunction: Harley et al v.
Kosinski et al, United States District Court in the Eastern District of New York, Case #1:20-cv-
MEMORANDUM in Opposition re26 MOTION for Preliminary Injunction: Taliaferro et al v.
North Carolina State Board of Elections et al, United States District Court for the Eastern District
of North Carolina Western Division, Case #5:20-cv-00411.
Election Security Risk Profile Tool – Collaborator on the methodology for a simple, non-technical
tool that provides mitigations for the non-cybersecurity professionals to understand.
Co-Author of the Harvard Belfer Center Defending Digital Democracy Project (D3P) State and
Local Election Cybersecurity Playbook and The Elections Battle Staff Playbook.
Trainer and scenario builder for the D3P State and Local Election Official Tabletop Exercise and
Battle Staff Bootcamp.
Contributor to CIS A Handbook Election Infrastructure Security and Election Technology
Procurement Guide.
Lead on EAC Voluntary Voting System Guidelines v. 2.0 focusing on providing technologies
that are both secure and accessible.
Created the 17-Functions process model that defined the Scope of the VVSG 2.0 so that non-
traditional election technologies could be tested to the same standards as traditional voting

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