Amicus Curiae Brief — Kristen Lovell, et al., Petitioners v. Brad Raffensperger, Georgia Secretary of State, et al.
Supreme Court briefMay 31, 2024
Ask Donna
What actually matters in this document.
Text
APPENDIX TABLE OF CONTENTS
EVIDENTIARY SUPPORT FOR
AMICI CURAIE BY KIM P. BROOKS
AND HELEN STRAHL
Appendix A
Synthetic Identity Theft on Georgians, Using
False Government Documents, Thereby
Manipulating Registrants Entered into the
Voter Database ................................................... 1a
Appendix A.1
Deceased Fraudulently Reissued....................... 6a
Appendix A.2
Duplicate Registration IDs Fraudulently
Reissued ............................................................ 13a
Appendix A.3
Felons Fraudulently Reissued ......................... 19a
Appendix A.4
Registration IDs Disappearing and
Reappearing ...................................................... 32a
Appendix B
Manipulation of Dates in the Voter
Database ........................................................... 38a
Appendix B.1
Manipulation of Date Added and Initial
Registration Date ............................................. 40a
Appendix B.2
Manipulation of Registration
Date prior to an Election .................................. 42a
Appendix B.3
Manipulation of Date Last Voted .................... 47a
APPENDIX TABLE OF CONTENTS (Cont.)
Appendix B.4
Manipulation of Date Last Contact ................. 50a
Appendix B.5
Manipulation of Date Last Modified ............... 53a
Appendix C
Manipulation of Absentee Ballots during an
Election ............................................................. 54a
Appendix C.1
Unlawful Too Early Ballots ............................. 56a
Appendix C.2
Precinct Address Manipulation ....................... 59a
Appendix C.3
Ballots Mailed to Purposeful Bad
Addresses .......................................................... 60a
Appendix C.4
No Excuse Absentee Ballots Mailed to
Registrants Out of State .................................. 64a
Appendix D
Manipulation of Votes During
and after an Election ........................................ 66a
Appendix D.1
Votes cast on Registrants not on
Voter Roll .......................................................... 69a
Appendix D.2
Swapped Votes from In Person on Election
Day to a Fraudulent Absentee Ballot .............. 75a
APPENDIX TABLE OF CONTENTS (Cont.)
Appendix D.3
Double Votes on Duplicate Registration IDs
for the Same Person ......................................... 78a
Appendix D.4
Non-Reconciled Votes Credited as Absentee
Voting, but not in Absentee File ...................... 84a
Appendix D.5
Votes on Ballots Never Received ..................... 87a
Appendix D.6
Votes on Rejected, Cancelled, and Spoiled
Ballots ............................................................... 89a
Appendix D.7
Votes on Deceased that are Ineligible
to Vote ............................................................... 97a
Appendix D.8
Votes on Felons that are Ineligible to Vote ... 100a
Appendix D.9
Votes on Inactive Voters that didn’t Cure their
Inactive Status ............................................... 102a
Appendix D.10
Significant Changes in the Voter
History File ..................................................... 106a
Appendix E
Improper Registration Data – Unlawful
Votes ............................................................... 107a
Appendix E.1
Not a Full Legal Name ................................... 108a
Appendix E.2
Missing Precinct Information ........................ 110a
APPENDIX TABLE OF CONTENTS (Cont.)
Appendix E.3
Registrations at Non-Residential properties 112a
Appendix F
Improper List Maintenance ........................... 115a
Appendix F.1
Active Registrants beyond
Five-Year Period ............................................. 116a
Appendix F.2
Inactive Registrants beyond two General
Election Cycles ............................................... 117a
Appendix G
Secretary of State File Definitions and Sources
Used ................................................................ 119a
Appendix H
Raffensperger Letter to VP Pence and
Congressmen .................................................. 121a
Appendix I
List of Amici Signatories and Donors ............ 140a
App.1a
APPENDIX A
SYNTHETIC IDENTITY THEFT ON
GEORGIANS, USING FALSE GOVERNMENT
DOCUMENTS, THEREBY MANIPULATING
REGISTRANTS ENTERED INTO
THE VOTER DATABASE
Synthetic Identity Theft, where a combination of
real and false information is combined to create a fake
or phantom person to enable a crime, is rampant in the
banking industry. It is also rampant in the Georgia
election database. Identity Theft is occurring on 1) exGeorgians, like the deceased and people that have
moved out of state, 2) current Georgians that are
infrequent voters, people who only vote on election
day, and Felons, and 3) non-US Citizens that never
intended on registering to vote. Not only is Synthetic
Identity Theft rampant, it seems the government itself
is committing the crime against its own citizens.
Most of the Identity Theft is coming onto the
voter rolls via the Georgia Registration Voter Information System (GARViS) and a False Department of
Driver Services (DDS) Motor Voter Application
presented to the County Election Official as an official
government document. The County Official has no
way of discerning a true and correct DDS Motor Voter
Application vs. a fraudulent one. The evidence
collected contains theft of name, race, sex, last four of
Social Security Number, full birthdate, and driver’s
license number combined with fraudulent registration
addresses and forged signatures.
Many updates in the GARViS Audit History Log
for an individual Registrant Identification (Reg ID)
App.2a
are “DDS System/Data” updates and “DDS & HAVA
Verification Successful – Status Change” updates
which are also fraudulent. The evidence points to
clear computer fraud, forgery, conspiracy to commit
election theft, theft by deception, and a multitude of
other crimes.
Georgia Legislature stated in O.C.G.A § 16.9.91(2)
Computer Crimes – Legislative Findings-“Such crime
occurs at great cost to the public, since losses for each
incident of computer crime tend to be far greater than
the losses associated with each incident of other whitecollar crime;”.
The evidence indicates the SoS, GARViS, and
DDS may be in violation of O.C.G.A. § 16-9-93(a)
Computer Crimes, Misleading Transmittal and Use of
Individual Name, Trade Name, Registered Trademark, Logo, Legal or Official Seal, or Copyrighted
Symbol Over Computer or Telephone Network;
Criminal Penalty; Civil Remedies.
“a. It shall be unlawful for any person, any
organization, or any representative of any
organization knowingly to transmit any
data through a computer network or over the
transmission facilities or through the
network facilities of a local telephone network
for the purpose of setting up, maintaining,
operating, or exchanging data with an
electronic mailbox, home page, or any other
electronic information storage bank or point
of access to electronic information if such
data uses any individual name, trade name,
registered trademark, logo, legal or official
seal, or copy righted symbol to falsely identify
the person, organization, or representative
App.3a
transmitting such data or which would falsely
state or imply that such person, organization,
or representative has permission or is
legally authorized to use such trade name,
registered trademark, logo, legal or official
seal, or copyrighted symbol for such purpose
when such permission or authorization has
not been obtained; . . . . . . .”
Forged signatures on DDS Motor Voter Applications show the SoS, GARViS, and DDS may be in violation of O.C.G.A. § 16-9-121(a) (1,3,4,5) Forgery and
Fraudulent Practices – Identity Fraud –
“a. A person commits the offense of identity
fraud when he or she willfully and fraudulently:
1.
Without authorization or consent, uses or
possesses with intent to fraudulently use
identifying information concerning a person;
3.
Uses or possesses with intent to fraudulently
use identifying information concerning a
deceased individual;
4.
Creates, uses, or possesses with intent to
fraudulently use any counterfeit or fictitious
identifying information concerning a
fictitious person with intent to use such
counterfeit or fictitious identification information for the purpose of committing or
facilitating the commission of a crime or
fraud on another person; or
5.
Without authorization or consent, creates,
uses, or possesses with intent to fraudulently
use any counterfeit or fictitious identifying
App.4a
information concerning a real person with
intent to use such counterfeit or fictitious
identification information for the purpose of
committing or facilitation the commission of
a crime or fraud on another person.”
Georgians’ identities are being stolen via
fraudulent DDS Motor Voter applications sent to
County Election Officials to enter false records into
the Georgia voter database, and Georgia case law is
clear. In Smith v. State, 322 Ga. App. 433, 745 S E 2d
683 (2013) it states:
“Testimony from the victims that the account
numbers used belonged to the victims and the
victims did not give the defendant, or anyone
else, permission to use or possess those
numbers was sufficient to support the
defendant’s conviction of identity fraud.”
At what point is the Election Official in all 159
Counties in Georgia guilty of O.C.G.A. § 16-9-121(b)
Forgery and Fraudulent Practices – Identity Fraud?
“b. A person commits the offense of identity
fraud by receipt of fraudulent identification
information when he or she willingly
accepts for identification purposes identifying
information which he or she knows to be
fraudulent, stolen, counterfeit, or fictitious.”
As the evidence will show in Appendices A.1, A.2,
and A.3 (6a through 19a), there is a huge uptick in
2023 of Identity Theft in preparation of phantom
voters in the 2024 Federal Election. This speaks to the
violation of O.C.G.A. § 16-9-122 – Identity Fraud –
Attempting or Conspiring to Commit Offense:
App.5a
“It shall be unlawful for any person to
attempt or conspire to commit any offense
prohibited by this article.”
Federal law is clear, and the evidence shows in
the following Appendices, that SoS, GARViS, and
DDS are in violation of 18 U.S.C. § 2721(a) –
Prohibition on release and use of certain personal
information from State motor vehicle records.
“In General – A State department of motor
vehicles, and any officer, employee, or contractor thereof, shall not knowingly disclose
or otherwise make available to any person or
entity: (1) personal information . . . or (2)
highly restricted personal information . . . ”
App.6a
APPENDIX A.1
DECEASED FRAUDULENTLY REISSUED
Deceased Fraudulently Reissued on the Voter Roll
is clear identity theft with criminal intent. Amicis
obtained around 3.9 million Cancelled voter records
from the GA SoS via multiple Open Records Requests
(ORR). This file provides the County, Registration ID,
Name, Birthyear, Cancel Date, and reason for Cancel.
Registrants that were previously cancelled as
deceased are returning to the GA database primarily
thru the DDS Motor Voter Application in GARViS.
Election Officials are being told that dead people are
getting driver’s licenses. Other times the deceased’s
record shows “Mail In Application”, which is an
impossibility because they are dead.
Case One not only shows a deceased has shown
back up on the voter roll, the SoS has “cloned” the
deceased three times in one year. See below the case
of Reg ID 10038837 who died in 2019, in Pearson, GA
and reissued on the GA voter roll March, 2023.
2019-06-05-Reg ID 10038837 died in Pearson,
GA. The obituary was found.
2019-08-22-Atkinson County Cancelled this ID
and the reason was “Deceased”.
App.7a
Figure A.1.a: SoS Cancelled Voter File
for Reg ID 10038837
2023-03-07 – Reg ID 10038837 was reissued on
the voter roll. A second “clone/duplicate” ID, which is
the same person with two Reg IDs, “10038837 R” was
also issued on the voter roll.
2023-06-30 – The first Reg ID 10038837 drops off
the voter roll and a third clone/duplicate ID, 14202166
is issued on the voter roll.
2023-08-30 – The third ID 14202166 drops off the
voter roll leaving the second clone ID “10038837 R”.
2024-02-05-the second ID “10038837 R” drops off the
voter roll and a fourth ID “14300475” appears.
This is four Reg IDs in the voter database
spanning a year on a single Deceased person that died
in 2019, that had been previously cancelled due to
being “Deceased”.
App.8a
Case Two is Reg ID 11007187 that died in
Atlanta, GA, December 15, 2019. The obituary was
found.
2020-01-09-Fulton County cancelled this ID and
the reason was “Deceased”.
Figure A.1.b: SoS Cancelled Voter File
for Reg ID 1007187
2020-01-21-Duplicate ID 11831769, a month after
death, shows up for the first time on the voter roll with
what appears to be a backdated Registration date of
July 25, 2018. This Reg ID is not on any previous voter
roll as the data would imply, and is a clone of the
deceased.
App.9a
Figure A.1.c: 01/21/2020 SoS Voter Roll
2023-08-03-three years after being an active
voter on the Fulton voter roll, Duplicate ID 11831769
is cancelled and the reason is “Duplicate”.
Figure A.1.d: SoS Cancelled Voter File
for Duplicate ID 11831769
2023-08-03-the very same day, the original Reg
ID 11007187 was reissued on the voter roll. This is the
Reg ID previously cancelled Jan 9, 2020 as depicted in
Figure A.1.b above.
App.10a
Figure A.1.e: 08/14/2023 SoS Voter Roll
This is clear criminal intent to introduce deceased
people back onto the voter roll and “swap” between
Reg IDs on a person that has been dead since December, 2019.
Case Three – Reg ID 8523590 died September,
2020, in Dougherty County, GA. The Obituary was
verified. It is the same pattern as Case Two above.
Dougherty County cancelled the registrant on
10/4/2020 as “Deceased”.
Figure A.1.f: SoS Cancelled
Voter File for Reg ID 8523590
2022-09-19-Two years after death, Duplicate ID
13464617 was added to the voter database during the
2022 General election cycle. It shows a Date Last
App.11a
Contact of 09/19/2022. This is obvious fraud because
the person died in 2020.
Figure A.1.g: 10/31/2022 SoS Voter Roll
This fraudulent Duplicate ID stays active on the
voter roll until 8/2/2023 when Dougherty County
cancelled the ID and the reason was “Duplicate”.
Figure A.1.h: SoS Cancelled Voter File
for Reg ID 13464617
2023-08-02-Reg ID 8523590 that was previously
cancelled, fraudulently reissued on the voter roll, on
the very same day the Duplicate was cancelled.
App.12a
Figure A.1.i: 08/14/2023 SoS Voter Roll
Help America Vote Act (HAVA) 42 U.S.C. 15483
Sec. 303 (a)(2)(A)(ii)(II) is clear in stating “For purposes of removing names of ineligible voter from the
official list of eligible voters-by reason of the death of
the registrant under section 8(a)(4)(A) of such Act (42
U.S.C. 1973gg-6(a)(4)(A)), the State shall coordinate
the computerized list with the State agency records on
death.”
Georgia is not only not following HAVA rules,
they are criminally violating the rules by purposefully
reissuing deceased on the voter database.
Amicis have approximately 200 cases of deceased
Georgians being reintroduced onto the Georgia voter
database, and sometimes their Duplicate IDs which
are being used to manipulate and manufacture
phantom voters on the voter rolls.
App.13a
APPENDIX A.2
DUPLICATE REGISTRATION IDS
FRAUDULENTLY REISSUED
Duplicate Registration IDs Fraudulently Reissued
on the Voter Roll is clear identity theft with criminal
intent. It was once believed that Duplicates were an
accident of creating two or more Reg IDs on the same
person when they registered or renewed their Driver’s
License with the Department of Motor Vehicles. After
much analysis, nothing could be further from the truth.
HAVA 42 U.S.C. 15483 Sec. 303 (a)(2)(B)(iii) is clear
in stating “The list maintenance performed under
subparagraph (A) shall be conducted in a manner that
ensures that-iii. duplicate names are eliminated from
the computerized list.” Not only is the SoS not
removing Duplicates, they appear to be purposefully
reissuing cancelled Duplicates after they have been
previously deleted.
These Duplicates are clones or phantom
Registration IDs. When the County Election office
finds a Duplicate, their job is to merge the two Reg IDs
records preserving the oldest original number and
cancelling the newest Duplicate number. When a
proper merge occurs, there is no reason whatsoever
that the Duplicate merged Reg ID ever appear again
on the voter database. Amicis found over 1,200 of previously cancelled Duplicate merged Reg IDs being
reintroduced onto the Georgia database. For what
purpose?
The last section has already outlined swapping of
deceased Duplicate IDs over time. Appendix B.4 at
50a outlines how Duplicates are used to Manipulate
App.14a
Date Last Contact which is key to O.C.G.A. § 21-2-234
and O.C.G.A. § 21-2-235 list maintenance activities.
The following case was initially found because a
previously cancelled Duplicate ID reemerged in a
totally separate County while the main ID was still
active in its original County. A person cannot have a
voter registration in two Counties. After much analysis, this person has had Identity Theft committed on
her by the SoS and the Department of Motor Vehicles
multiple times over the last four years.
2016-10-03 – Initially registered to vote and was
assigned Reg ID 10971823.
2019-02-28 – A driver’s license renewal appears
to have occurred and a Duplicate Reg ID 12143559
was created. Her last name is misspelled and the
signature is different and matches the misspelled last
name. The DDS Motor Voter Application has a
combination of real and fake information.
2019-10-30 – Bulloch County merged Registration
IDs 10971823 and 12143559. 10971823 survived and
12143559 was cancelled which was proper.
Figure A.2.a: SoS Cancelled Voter File
for Duplicate ID 12143559
2020-07-29 – GARViS Audit Log for 10971823
shows a second trip to the DMV in a year with no
address move. This fraudulent DDS Motor Voter App
also has a misspelled last name.
App.15a
2020-10-03 – GARViS log shows a second
Duplicate ID 12901464 was created due going to the
DDS three times in 18 months with no address
change.
2021-09-27 – Bulloch County merged Registration
IDs 10971823 and 12901464. 10971823 survived and
12901464 was cancelled which was proper.
Figure A.2.b: SoS Cancelled Voter File
for Duplicate ID 12901464
2023-04-21 –Duplicate Reg ID #1, 12143559 is
reissued in Gwinnett County, GA via a fraudulent
DDS Motor Voter Application. This is the third time
fraud was committed on this registrant. This application is a combination of real and fake information containing yet another fraudulent signature. See Figure
A.2.g.
2023-08-06 – A Gwinnett elector challenged this
fraudulent entry on the voter roll and Gwinnett County
cancelled Duplicate ID 12143559 for the second time.
Figure A.2.c: SoS Cancelled Voter File
for Duplicate ID 12143559
2023-11-07 – It appears for the very first time
App.16a
the registrant voted in a Bulloch County election.
2024-02-08 – It appears Bulloch County cancelled
this registrant’s main Reg ID after all the fraud committed on her.
Figure A.2.d: SoS Cancelled Voter File for Main
Reg ID 10971823
2024-03-08-After all the fraud, this voter has no
voter registration in Georgia. This voter is a victim of
identity theft, forgery, computer fraud, and a clear
Civil Rights violation.
2024-04-23-After Bulloch County was contacted
with the evidence, the voter was reissued on the voter
roll with an old address and a misspelled last name.
2024-05-13-Bulloch County responded to an ORR
and stated they had no challenge hearings in February 2024. This implies the record in Figure A.2.d was
fraudulent and most likely not entered by Bulloch
County.
To emphasize the extreme Synthetic Identity
Theft on this one voter, three separate and distinct
redacted signatures from her record can be found
below, and this voter has only one “L” in the last name.
No one misspells their name on their signature,
especially their Driver’s License.
App.17a
Figure A.2.e: Signature 1-GARViS records for
Reg ID 10971823, 12143559, 12901464
Figure A.2.f: Signature 2-GARViS records for
Reg ID 10971823, 12143559, 12901464
Figure A.2.g: Signature 3-GARViS records for
Reg ID 10971823, 12143559, 12901464
While hard to compare redacted signatures, note
the “I L” is different each time, the “Y” is different
each time, and most importantly, this voter does not
have two “L”s in their name. The third signature is a
Fraudulent DDS Motor Voter Application with
forgery of the voter’s signature. The voter confirmed
she did not go to the DDS in Gwinnett County. Her
personal and highly restricted personal information
was stolen, and used to commit Identity Theft and is
a clear violation of 18 U.S.C. § 2721(a).
App.18a
False DDS documents with stolen personal
identification, fake addresses, and forged signatures
are criminal violations, by the Government, of Identity
Theft, DDS personal information law, computer fraud,
forgery, and a scheme to Defraud Georgians, Georgia
elections, and the United States of America.
This is one specific example describing the
detailed analysis and there are over 1,200 Duplicates
that have been previously cancelled that are being
fraudulently reissued on the Georgia Voter rolls, some
in different Counties, like the registrant above.
App.19a
APPENDIX A.3
FELONS FRAUDULENTLY REISSUED
Felon Registration IDs Fraudulently Reissued on
the Voter Roll are clear identity theft with criminal
intent. Pursuant to O.C.G.A. § 21-2-231, a Felon loses
their right to vote until they complete their sentence,
fines, and provide paperwork in person at the
Election’s Office of their County of residence to show
they are no longer considered a felon. Felons can never
be automatically reissued on the voter roll. Additionally, Amicis have discovered a few computer schemes
around Felons to manipulate the vote in Georgia
elections.
Synthetic Identity Theft is occurring on Felons
still sitting or soon to be released from jail. The data
used is a combination of real and fake information to
create a phantom or fake registrant. Amicis have
found enough similar examples to prove a pattern.
The pattern strongly suggests Georgia Felons have no
idea this is occurring.
Case One – Reg ID 10008129 was arrested for
armed robbery in 2015 and received a 20-year
sentence.
2015-His address in the voter database was 4155
Satellite Blvd, Unit 824, Duluth, GA
2017-06-30 – Gwinnett County cancelled Reg ID
10008129 and the reason was “Felon”, which was
proper.
App.20a
Figure A.3.a: SoS Cancelled Voter File
for Reg ID 10008129
2023-04-28 – Reg ID 10008129 is reissued on the
voter roll at 3900 Schatulga Rd, Columbus, GA,
Muscogee County, via a DDS Motor Voter Application
which is the jail where he was then incarcerated.
2023-05-26-Reg ID 10008129 moves to Gwinnett
County to 3900 Satellite Blvd, Duluth, GA with a
mailing address of 3900 Schatulga Rd, Columbus, GA
via DDS Motor Voter Application while still sitting in
jail in Muscogee County. Notice the Synthetic Identity
stitching of “3900” from the jail address with “Satellite
Blvd” from his last known address. Also, his mail
address is still the jail.
2023-05-26 thru 2023-07-21 voter rolls, Reg ID
10008129 is in Gwinnett County.
App.21a
Figure A.3.b: 6/30/2023, 7/5/2023, 7/21/2023,
8/30/2023 SoS Voter Roll Data
2023-08-08 – A Gwinnett elector challenged Reg
ID 10008129 as being improper on the voter roll.
2023-08-14 Reg ID 10008129 was moved back to
Muscogee County to 3900 Schatulga Rd, Columbus,
GA (the Jail). (See Figure A.3.b)
App.22a
2023-08-16 Zach Manifold, Gwinnett Elections,
dismissed the challenge stating Reg ID 10008129 had
been registered in Muscogee County since April 28,
2023, which was a false statement and obstruction of a
O.C.G.A. § 21-2-229 elector’s right to challenge an
ineligible Registrant on the voter roll.
Figure A.3.c: 8/16/2023 Letter from Zach
Manifold, Gwinnett Election Supervisor
I am writing to acknowledge receipt of your letter
dated August 8, 2023, and the attachments.
O.C.G.A. § 21-2-229 allows a voter registered in
Gwinnett County to challenge the qualification of
Gwinnett County registered voters. The challenges
will not be scheduled for a hearing because both voters
are no longer Gwinnett County registered voters. Mr.
xxxxx registered in Fulton County on May 4, 2023,
and Mr. xxxxxx registered in Muscogee County on
April 28, 2023.
Thank you for your continued interest in the work
of the Gwinnett County Board of Voter Registrations
and Elections.
Sincerely,
/s/ Zack Manifold
Election Supervisor
Gwinnett County Board of Voter
Registrations and Elections
App.23a
2023-11-GARViS Audit History Log was pulled
on Reg ID 10008129 and the data was deleted of any
presence of being in Gwinnett County from May thru
July of 2023. The update in the file was 8-14-2023, just
two days before Mr. Manifold notified the challenger.
Gwinnett County along with the SoS Office altered
the GARViS Audit log because it showed fraud.
App.24a
Figure A.3.d: GARViS Audit History Log
on Reg ID 10008129
App.25a
Amicis still have the voter rolls from May until July
that tell a different story.
This is a case of identity theft, computer fraud,
forgery, maladministration, and alteration of public
documents pursuant to O.C.G.A. § 45-11-1(a-b).
Case Two – Reg ID 5565726 was arrested in
Baldwin County for drug trafficking in 2017 and
received a 35-year sentence.
2022-06-09 – Reg ID 5565726 initially registered
to vote at 2989 W Rock Quarry Rd, Buford, Gwinnett
County, GA which is a jail.
2022-09-19 – Gwinnett County cancelled Reg ID
5565726 and the reason was “Felon”, which was
proper.
Figure A.3.e: SoS Cancelled Voter File
for Reg ID 5565726
2023-05-02 – Reg ID 5565726 is reissued on the
Gwinnett voter roll via the DDS Motor Voter
Application at the same jail, but the Felon is sitting in
a totally different jail.
2023-05-04 – Reg ID 5565726, per the GARViS
Audit History Log, moved to Fulton County via the
DDS.
2023-06-30-Reg ID 5565726 per the GARViS
Audit History Log, DDS updated the address in
Fulton.
App.26a
2023-07-12-Reg ID 5565726, per the GARViS
Audit History Log, moved back to the jail (that he’s
not at) in Gwinnett County via the DDS.
2023-08-08 – The same Gwinnett elector (as in
Case One above) challenged Reg ID 5565726 as being
improper on the voter roll.
2023-08-14 Reg ID 5565726 was moved back to
Fulton County which was the same day as the Case
One cover up.
App.27a
Figure A.3.f: GARViS Audit History
Log for Reg ID 5565726
App.28a
2023-08-16 Zach Manifold, Gwinnett Elections,
dismissed the challenge stating Reg ID 5565726 is
registered in Fulton County as of May 4, 2023, (See
Figure A.3.c), but the Audit History Log in the figure
above tells a completely different story.
2023-10-11 Reg ID 5565726 was cancelled a
second time in Fulton County, once the fraud was discovered.
To be clear, this one Reg ID appears to have gone
to the Department of Motor Vehicles three times in
three months between a jail and an apartment in
Fulton County while possibly living at a jail in a totally
different County. This is another case of identity theft,
computer fraud, forgery, and maladministration.
Case Three – The reason Amicis believe this is
being done outside the Felon’s knowledge is a
computerized pattern was discovered. Many Felons
move to an address “stitched” with the Jail Street
Number and a Street Name from a previous address.
Amicis have examples of at least 10 different jails in
Georgia. Below are some example data from three
Georgia jails:
App.29a
Figure A.3.g: 09/13/2023 SoS Voter Roll
App.30a
Case Four – Felons are being reissued on the voter
roll despite them not wanting to be registered. Reg ID
11999858 was canvassed in Cherokee County. She
told the canvasser she, 1) was a Felon, 2) has never
registered to vote, and 3) is not interested in voting.
Despite her personal testimony, not only was she
registered around the 2020 Federal election, a
Duplicate ID was created around the 2022 Federal
election. This Felon has two active Reg IDs when she
testified, she has never registered to vote.
The first Reg ID 11999858 showed up on the
01/21/2020 voter roll for the first time with a backdated Voter Created Date of 2018. Reg ID 11999858 is
not within the number range of 2018 registrants,
therefore, this is clear manipulation of Date Created.
Figure A.3.h: 01/21/2020 SoS Voter Roll
for Reg ID 11999858
App.31a
A Duplicate ID 13487551 shows up on the voter
roll for the first time on the 10/31/2022 voter roll,
during a federal election cycle, with a backdated
Created Date of 07/15/2022.
Figure A.3.i: 10/31/2022 SoS Voter Roll
for Reg ID 13487551
This Duplicate Reg ID is also still active on the
Georgia voter database. There has been Synthetic
Identity Theft committed multiple times on this Felon
who did not and does not wish to be registered to vote.
Case Five – Felons are being reissued on the voter
roll without their knowledge, and a vote is cast on
their Reg ID, then cancelled right after an election. In
2020, one active status Felon was cancelled on
11/4/2020, only 24 hours after 11/03/2020. Refer to
Appendix D.8 at 100a for more detailed analysis.
App.32a
APPENDIX A.4
REGISTRATION IDS DISAPPEARING
AND REAPPEARING
Amicis have ten years of voter roll data from the
SoS. When compared over time, several problems are
found within the voter database.
Scenario one is when the Reg ID shows up on only
one voter roll, during an election, and then either
disappears or is cancelled immediately. This does not
follow NVRA or Georgia Law. There are multiple
examples of this phenomena and consistently appear
on the 11/22/2020 voter roll.
Case One – Reg ID 12944910 was not on any
voter roll from 2014 until the 11/22/2020 SoS Voter
Roll, and none since. It shows created on 10/22/2020
which was prior to the 10/25/2020 SoS Voter Roll, and
indicates a backdated date.
App.33a
Figure A.4.a: 11/22/2020 SoS Voter Roll
Reg ID 12944910 was quickly cancelled by
Morgan County on 12/06/2020, right after the election,
and the reason was “Duplicate”.
Figure A.4.b: SoS Cancelled Voter File
Another ORR SoS file shows Reg IDs that were
merged. This file shows the Reg ID that merged and
survived was Reg ID 6263667 which did not exist at
the time! Reg ID 6263667 did not show up on any voter
roll the Amicis have until the 01/27/2021 SoS Voter
Roll.
Figure A.4.c: SoS Duplicate Merge File
Nothing about a Reg ID that existed for less than
30 days in the voter database right during an election
App.34a
instills confidence that this was a valid Reg ID. It
appears to be manipulation during an election.
Case Two – Reg ID 12946145 was not on any voter
roll from 2014 until the 11/22/2020 SoS Voter Roll,
and none since. It shows created on 11/02/2020.
Figure A.4.d: 11/22/2020 SoS Voter Roll
Reg ID 12946145 was quickly cancelled by
Morgan County on 12/06/2020, right after the election,
and the reason was “Duplicate”.
App.35a
Figure A.4.e: SoS Cancelled Voter File
Another ORR SoS file shows Reg IDs that were
merged. This file shows the Reg ID that merged and
survived was Reg ID 6515068 which did not exist at
the time! Reg ID 6515068 was last seen in Morgan
County as inactive status with a different last name
spelling on the 05/25/2017 SoS Voter Roll.
Figure A.4.f: SoS Duplicate Merge File
Once again, nothing about a Reg ID that existed
for less than 30 days in the voter database right
during an election instills confidence that this was a
valid Reg ID. It appears to be manipulation during an
election.
There were 1,628 Reg IDs across the state that
appeared on one voter roll during the 2020 election,
and then were cancelled within a 30-day timeframe as
“Duplicate”, “Felon”, or “Deceased”. While vote credit is
not always found, these appear to be manipulation of
votes during a federal election.
Scenario Two is when the Reg ID shows up in
2020, disappears without being cancelled, then appears
in 2022 only to be cancelled after the election. The
appearing and then disappearing then appearing
again during election months does not follow NVRA or
App.36a
Georgia law. It also appears to be Synthetic Identity
theft and total manipulation of a Reg ID during
election months.
Case Three – Reg ID 12930377 was not on any
voter roll until the 11/22/2020 SoS Voter Roll with a
Registration Date of 10/06/2020. Because this date was
prior to the 10/25/2020 SoS Voter Roll, this appears to
be a backdated manipulated date.
Figure A.4.g: 11/22/2020 SoS Voter Roll
App.37a
The Reg ID disappears on the 01/27/2021 SoS
Voter Roll and stays gone through the 07/05/2022 SoS
Voter Roll without being cancelled. This does not
follow NVRA or Georgia law.
The Reg ID shows back up on the 08/05/2022 SoS
Voter Roll just in time for another election.
Figure A.4.h: 08/05/2022 SoS Voter Roll
The voter that had Reg ID 12930377 died on
12/22/2022, and the obituary was found. This Reg ID
stayed active half way through 2023 when Randolph
County cancelled him on 05/03/2023 and the reason
was “Deceased – ERIC”.
Figure A.4.i: SoS Cancelled Voter File
This scenario was found not only in 2020 and
2022, but also around the November 2023 election.
Reg IDs that appear and then disappear and then
reappear during election months are not lawful, and
have the appearance of Synthetic Identity theft, voter
database manipulation, and vote manipulation.
App.38a
APPENDIX B
MANIPULATION OF DATES IN
THE VOTER DATABASE
Several dates are maintained in the Voter
Database that are key to running Georgia Elections
and following list maintenance activities per Georgia
Law. The most notable are Date Added, Registration
Date, Date Last Voted, Date Last Contact, and Date
Last Modified. At a minimum, Pursuant to O.C.G.A.
§ 45-11-1 public records cannot be falsified, altered,
forged, or conceal any issue.
When analysis is performed across 10 years of
data, evidence is found of manipulation and backdating
of each of these fields and shows criminal intent and
violation of several Georgia laws.
When Registration Date is backdated to have the
appearance of Registering to vote in time for a federal
election, but actually didn’t exist at the time of the
deadline, and then receive credit for voting, all of
these votes are fraudulent. This is outlined in
Appendix B.2 at 42a and is a violation of 52 U.S.
§ 10307(c) – Prohibited acts, False Information in
Registering or Voting
“Whoever knowingly or willfully gives false
information as to his name, address or period
of residence in the voting district for the
purpose of establishing his eligibility to
register or vote, or conspires with another
individual for the purpose of encouraging his
false registration to vote or illegal voting
. . . . . . .”
App.39a
It is also a violation of O.C.G.A. § 45-11-1 Offenses
Involving Public Records, Documents, and Other
Items.
App.40a
APPENDIX B.1
MANIPULATION OF DATE ADDED AND
INITIAL REGISTRATION DATE
Thousands of Manipulations of Date Added and
Initial Registration Date have been found by comparing
voter rolls over time. Below is a perfect example:
Figure B.1.a: 02/05/2024 SoS Voter Roll
for Reg ID 14300475
Reg ID 14300475 data has a created date of
3/30/2022, and had a Date Last Contact of 2018. There
are several problems within this data.
1)
The 2/5/2024 voter roll was the first time this
ID showed up in the voter database, and did
not appear in any of the 2022 or 2023 voter
databases, as the data would imply.
2)
Registration IDs are created sequentially
and the largest Registration ID number in
the 4/1/2022 voter roll was in the 1326xxxx
range, therefore 14300475 was too high of a
number to be assigned in the 03/2022 timeframe.
App.41a
3)
The voter cannot have a Date Last Contact
or Registration Date prior to Date Created/
Added.
4)
It is impossible to have a Date Created/
Added on a person that has been dead since
2019! This Registration ID is a duplicate ID
of a deceased person and is clear criminal
intent. See Appendix A.1 at 6a for a full
accounting of this voter.
App.42a
APPENDIX B.2
MANIPULATION OF REGISTRATION
DATE PRIOR TO AN ELECTION
Manipulation of Registration Date prior to an
election can be found by comparing various voter rolls
over time. Pursuant to O.C.G.A. § 21-2-224 you must
register to vote or change to your current address to
vote prior to 30 days before an election. There is clear
evidence of backdating of registration IDs prior to an
election to create the appearance of an elector
registering in time to vote.
In 2020, the cutoff date for registration add/
changes in the 2020 General Election was October 5,
2020. Therefore, all registrations with a registration
date of October 5th or before (eligible voters) should
be in the SoS October 25, 2020 Voter Roll. Comparison
of this file with the November 22, 2020 Voter Roll tells
a different story. There is evidence of backdating
around the 2022 election as well. If an Election
Official looks up one of these backdated records in
GARViS, they cannot discern that the date entered is
false. Backdating of records can only be seen by
reviewing several voter rolls over time.
Between the 10/25/2020 and the 11/22/2020 SoS
voter rolls, there were over 9,300 backdated Registrants
that had the appearance of being registered to vote in
time for the 2020 election, but they did not exist on
10/5/2020. Of those, over 3,700 received credit for
voting in the 11/03/2020 Election. Of the remaining
Reg IDs that do not show credit, they were all
modified within days of 11/03/2020, so they are all
fraudulent and appear to be criminal manipulation.
App.43a
There has not been analysis on how many of these
registrants voted in the 01/05/2021 run-off. These are
all fraudulent votes as they were not registered in
time per Georgia law.
Case One – Reg ID 8468795 was not on the
10/25/2020 SoS Voter Roll, or any Voter Roll we
sampled dating back to the 04/05/2015 SoS Voter Roll.
It first appears on the 11/22/2020 SoS Voter Roll with
a Registration Date of 06/30/2011. This is a backdated
date. IF this Reg ID had been on the SoS Voter Roll
on October 5, 2020, then it would have appeared on
the 10/25/2020 SoS Voter Roll, or for that matter all
previous 2020 Voter Rolls that were compared.
Figure B.2.a: 11/22/2020 SoS Voter Roll
App.44a
Reg ID 8468795 received credit for YNN, or
Absentee voting in the 11/03/2020 election.
Figure B.2.b: 2020 SoS Voter History File
Figure B.2.c: 2020 SoS Absentee File
Note in Figure B.2.c the Application Date for the
Absentee Request was 10/15/2020, but the Reg ID was
not on the Voter Roll on 10/15/2020. Note in Figure
B.2.a 11/09/2020 was the Date Changed. This is five
days after the 11/03/2020 election. It appears this Reg
ID and vote were inserted after the election. It was
definitely not on the Voter Roll when the SoS Absentee
File reports a requested and returned ballot.
Case Two – Reg ID 12533772 was not on the
10/25/2020 SoS Voter Roll, or the 01/21/2020 or
08/11/2020 Voter Roll. It first appears on the
11/22/2020 SoS Voter Roll with a Registration Date of
01/02/2020. This is a backdated date. IF this Reg ID
had been on the SoS Voter Roll on October 5, 2020,
App.45a
then it would have appeared on all of the previous SoS
Voter Rolls analyzed in 2020.
Figure B.2.d: 11/22/2020 SoS Voter Roll
Reg ID 12533772 received credit for YNN, or
Absentee voting in the 11/03/2020 election.
Figure B.2.e: 2020 SoS Voter History File
App.46a
Figure B.2.f: 2020 SoS Absentee File
Note in Figure B.2.d 11/12/2020 was the Date
Changed. In Figure B.2.f the SoS Absentee reports
this person voted in person on 10/28/2020. IF this
person voted on 10/28/2020, the Date Changed would
most likely have also been 10/28/2020. It appears this
Reg ID and vote were inserted after the election. The
registrant was definitely not registered to vote by the
October 5, 2020 deadline.
Backdating of Registration Date to have the
appearance of Registering in time to vote is a violation
of 52 U.S.C. § 10307(c) – Prohibited Acts – False Information in Registering or Voting.
App.47a
APPENDIX B.3
MANIPULATION OF DATE LAST VOTED
Manipulation of Date Last Voted can be found by
comparing voter rolls over time. Date Last Voted is
just that, the last time a registrant voted in an election.
It should only change forward in time. There is evidence of a voters’ votes reverting to a previous value
which has the appearance of a deleted vote.
Below are 2020 examples reviewing the 08/
11/2020, 10/25/2020, 11/22/2020, and 01/27/2021 SoS
voter rolls surrounding the 2020 General Election.
The Date Last Voted on 08/11/2020 changes to a
11/03/2020 vote only to revert to the 08/11/2020 value
in a subsequent voter roll.
App.48a
Figure B.3.a: 8/11/2020, 10/25/2020, 11/22/2020,
and 01/27/2021 SoS Voter Rolls
The same reversal of votes can be found around
the 2022 General election.
App.49a
Figure B.3.b: 10/03/2022, 10/31/2022, 11/23/2022,
and 02/05/2023 SoS Voter Rolls
Where did these votes go? It appears they were
deleted.
App.50a
APPENDIX B.4
MANIPULATION OF DATE LAST CONTACT
Manipulation of Date Last Contact in turn
manipulates the rules in O.C.G.A. § 21-2-234 and
§ 21-2-235 and how the SoS is responsible for list
maintenance. One way the Date Last Contact field is
manipulated is via the Duplicate Registration IDs
that are created via the DDS Motor Voter Application(s). A Duplicate ID is defined as the same name,
most times same address, same birthyear, but two
different registration IDs. A duplicate is a clone of the
main person in the voter database.
There is evidence that shows when the DDS
Motor Voter Application appears on a new clone Reg
ID, it causes the main Reg ID Date Last Contact to
update. Below is an example for one person with multiple Reg IDs.
App.51a
Figure B.4.a: GARViS Audit History logs,
confirmed by SoS Voter Rolls
App.52a
The data suggests that when a fraudulent
Duplicate ID is created, the system updates a totally
separate Reg ID. The data strongly suggests that
Duplicates are connected from the Creation Date and
are not an accident in the DDS Motor Voter system.
Lastly, we have seen multiple examples of Date Last
Contact updated on a dead person, that has been
deceased for years.
App.53a
APPENDIX B.5
MANIPULATION OF DATE LAST MODIFIED
Manipulation of Date Last Modified can be found
by looking at records that should not exist in the voter
database. The best example of this are deceased
people that have not been properly cleaned off the
voter roll. They are being falsely modified all the while
deceased. Some of them have Date Last Contact after
death date during a federal election cycle. Below is a
small sample from over 400 deceased still on the
DeKalb County voter rolls:
Figure B.5.a: 03/11/2024 SoS Voter Roll
These deceased have all been confirmed with
Obituaries. Why and what is being modified on a
Deceased person’s record? And if ERIC and the
County are receiving death records monthly from the
Probate office, why are these deceased still on the
voter roll?
Pursuant to NVRA Sec. 8(5), deceased must be
removed from the voter rolls.
App.54a
APPENDIX C
MANIPULATION OF ABSENTEE BALLOTS
DURING AN ELECTION
No Excuse Absentee Ballots are a major area of
election theft in Georgia. It is as if the Secretary of
State’s Office knew a year before COVID that
relaxed signature Absentee Ballots and drop boxes
were coming to Georgia. Creating drop boxes without
Legislative approval was unlawful. Sending a letter to
all County officials circumventing the County’s
involvement for early ballot requests was a guise to
alter the normal process, one that had been in the
works since January of 2019. Large unlawful too early
ballot requests came and were approved, per the file,
in what appear to be large batches. There were
235,520 unlawful, too early ballot requests that each
turned into a vote.
Additionally, there was fraudulent manipulation
of registrants’ addresses prior to the election where a
phantom requested a ballot at the fake address. There
were over 2,700 ballots that turned into a vote that
were mailed to impossible un-mailable addresses.
These are all violations of 52 U.S.C. § 10307(c) –
Prohibited acts, False Information in Registering or
Voting.
There were votes cast on ballots that were
rejected at the County level. There were votes cast on
ballots that were never mailed in. There were votes
cast on ballots mailed to people that lived out of state,
to their address out of state. There were in person on
election day votes that were deleted and an Absentee
App.55a
Ballot that they never requested was inserted and
counted.
The evidence in Appendices C.1 at 56a through
C.4 at 64a will clearly show that Mr. Raffensperger
made the following false statement, “The facts show
that the claims that the 2020 election did not follow
Georgia law on absentee ballots are false,” as he
attested in a letter to Vice President Pence and members of Congress on January 6th, 2021, (See Appendix
H at 121a). This statement is in violation of 52 U.S.C.
§ 10307(d) – Prohibited Acts – Falsification or Concealment of Material Facts or Giving of False Statements in Matters within Jurisdiction of Examiners or
Hearing Officers.
No Excuse Absentee Ballots continue to be a
major area of election theft in Georgia.
App.56a
APPENDIX C.1
UNLAWFUL TOO EARLY BALLOTS
Pursuant to O.C.G.A. § 21-2-381(2020) Absentee
Ballots could be requested in Georgia 180 days ahead
of an election. In 2020, for the General Election on
11/3/2020, that earliest request date was May 6th,
2020.
Allowances were made for the Elderly, Disabled
or UOCAVA (Uniformed and Overseas Citizens
Absentee Voting Act) personnel who could apply earlier
in the election cycle for all elections in that calendar
year.
The SoS sent a letter to all the Counties and took
over the Early Ballot Request process. Despite a May
6, 2020, earliest request date, per the SoS’s own files,
ballot requests came in what appears to be batches
starting in January of 2019! There were over 300,000
Absentee Ballots requested and accepted prior to the
lawful date. Figure C.1.a shows a sample of too early
ballot requests from the 2020 SoS Absentee file.
App.57a
Figure C.1.a: Too Early Application Date – 2020
SoS Absentee File
The occurrence of too early ballot requests was
found in 158 of 159 counties. The Secretary of State’s
Office confirmed there were a total of 73,583 excused
early registrants (Elderly, disabled, UOCAVA-Military,
etc.). The total number of absentee ballot applications
that were ‘requested’ and ‘accepted’ outside of the lawful “earliest possible” request date and turned into an
unlawful vote was 232,520.
The Earliest Issue Date in Georgia for the
November 3, 2020, election was September 15, 2020,
and the Secretary of State performed a bulk mailing
on September 18, 2020. This did not happen locally in
the counties, since the Secretary of State had assumed
responsibility for all early ballot request handling and
the bulk mailing.
Figure C.1.b shows a sample from the SoS’ 2020
Absentee File of Ballots that were issued prior to the
lawful date of 09/15/2020.
App.58a
Figure C.1.b: Too Early Issued Date
– 2020 SoS Absentee File
In total, 1,939 ballots were mailed ahead of the
09/15/2020 earliest ‘issue date’.
App.59a
APPENDIX C.2
PRECINCT ADDRESS MANIPULATION
Precinct Address Manipulation is defined as an
elector’s address is changed without the elector’s
knowledge and without them actually moving. The
elector shows up to vote only to learn someone has
already voted on their Reg ID number. In 2020,
people were moved within their County or in some
instances to an entirely different County, and a vote
was stolen/cast on their behalf.
Case One – Reg ID 1894395 owns her home in
Tucker, DeKalb County, GA. She showed up to vote
on 10/20/2020 to vote in the 11/03/2020 election. She
was told that she was no longer in her precinct, that
she had moved. Her address was changed to an
apartment, with which she had no association. The
SoS 2020 Absentee file shows an Absentee Ballot was
requested on 08/20/2020 on her behalf from this fraudulent address, of which she did not do.
Figure C.2.a: SoS 2020 Absentee File
for Reg ID 1894395
This is another case of Identity Theft, in that the
voter did not notify DDS or DeKalb elections that she
moved and someone requested a ballot, fraudulently
pretending to be her.
Several other examples were found across the
state like Reg ID 5217916 in Gwinnett County, where
they own their home but was moved to an apartment
right before the election and then back again.
App.60a
APPENDIX C.3
BALLOTS MAILED TO PURPOSEFUL
BAD ADDRESSES
The SoS 2020 Absentee File Mailing Address
was where the Ballot was mailed, not necessarily the
Mailing Address in the voter database. There were
over 2,700 Ballots mailed to purposeful bad addresses
that came back as a vote.
Amicis defined an “un-mailable address” as
where the city, state, and zip combination were
impossible. How did the ballot get to the registrant for
them to mail back the ballot? Amicis believe these to
be fraudulent ballots. Below is a sample of “unmailable addresses” that turned into a vote.
App.61a
Figure C.3.a: 2020 SoS Absentee File
There were also “un-mailable addresses” in the
Too Early Ballot Requests handled exclusively by the
SoS as outlined in Appendix C.1 at 56a.
App.62a
Figure C.3.b: 2020 SoS Absentee File
In the case of David A. Perdue and Elizabeth
Grace Lennon, vs. Richard Barron, et. al. in Fulton
County, GA, Reg ID 10687494, Elizabeth Grace Lennon,
had her vote stolen by one of these purposeful bad
Addressed ballots. It appears she requested a ballot to
App.63a
be mailed to Fayetteville, AZ 72701 of which Fayetteville and 72701 belong in Arkansas not Arizona. At first
glance it looks like a typo, but Elizabeth testifies that
Fulton County told her she had already voted. She did
not request this Absentee Ballot and furthermore,
what appears to be a typo becomes less believable
when you see over 2,700 of these types of ballots that
turned into a vote across the whole state.
App.64a
APPENDIX C.4
NO EXCUSE ABSENTEE BALLOTS MAILED
TO REGISTRANTS OUT OF STATE
There are several cases of ex-Georgians unlawfully voting in two federal elections from out of state.
It is a felony to attest to living at a Georgia residence
on the Absentee ballot request form, mail fraud to
mail the ballot back to Georgia, and another felony to
cast a vote in a Georgia election. This is happening
across the state.
Case One – Reg ID 7530862 is an Internal Medicine
Specialist/ Doctor at Baylor Hospital in TX. She has
been practicing there for eight years. She moved her
registration to vote in Georgia to her parent’s address
in Cobb County. She has voted in Georgia via
Absentee Ballot (sent to TX) in the 2020 General, 2021
Run-off, 2022 General, and the 2022 Run-off. Pursuant to O.C.G.A. § 21-2-234 she remains an active
voter, but she has not lived in Georgia for eight years,
is gainfully employed in TX, and continues to unlawfully vote in GA.
Case Two – Reg ID 2028389 is an ex-Georgia
football player and current Tequilla salesman that
used to live in Grayson, Gwinnett County, GA, and
sold his Grayson home 08/31/2020. He has voted in the
2020 General, 2021 Run-off, 2022 General, and the
2022 Run-off while living in Charlotte, NC per his
online interviews, his entity filings with the GA SoS,
and his deed on his home in NC. In 2022, the SoS
marked him Inactive, NCOA but he was still allowed
to vote early in person, from his Grayson home that
he hadn’t lived at since 2020. He remains an active
App.65a
voter in Gwinnett County and has committed multiple
election felonies as well as mail fraud. Gwinnett
County Board of Elections had this registrant challenged via O.C.G.A. § 21-2-229, with mountains of evidence presented, and kept him on the voter roll
anyway.
Case Three – Reg ID 7128668 is registered to vote
in Peachtree Corners, Gwinnett, GA, and left Gwinnett
County from her apartment in August, 2020, to move
back home to Colrain, MA. She has unlawfully voted
in the 2020 General and the 2022 General via
Absentee ballot. She posted on Facebook a picture of
her holding her 2020 Absentee Ballot right before she
mailed it in a Colrain, MA, blue postal box. The 2022
ballot was mailed to Colrain, MA, where she lives.
Gwinnett County Board of Elections, despite two
O.C.G.A. § 21-2-229 challenges, keeps her on the voter
roll as an active voter, and continues to allow her to
commit election felonies, and unlawfully vote in multiple Georgia elections.
There are thousands of cases like the three
outlined above. No Excuse Absentee Ballots are being
mailed to all 50 states, many times to the registrant’s
new address. As long as the registrant continues to
vote, they remain active on the Georgia voter roll and
in violation of NVRA, HAVA, and 2 U.S.C. 9.
App.66a
APPENDIX D
MANIPULATION OF VOTES DURING
AND AFTER AN ELECTION
Amicis have an abundance of evidence showing
manipulation of votes before, during, and after the
Federal elections of 2020 and 2022. Several schemes
of creating fraudulent Absentee Ballots were outlined
in Appendices C, C.1, C.2, and C.3 above.
Amicis compared the 11/22/2020 SoS voter roll,
2020 SoS Voter History File, the 2020 SoS Absentee
File, and the SoS Cancelled Voter File. Reconciliation is
not possible.
There were over 2,000 votes credited in the 2020
Election that were not on any voter roll across the
state. This phenomenon appears to be created by the
machines as a registrant must be on the voter roll to
request an Absentee Ballot or check into a Poll Pad.
While Amicis are not focused on a particular 2020
candidate, they have proven that Mr. Raffensperger
made a false statement in a letter to Vice President
Pence and members of Congress on January 6th, 2021.
(See Appendix H at 121a)
Mr. Raffensperger stated, “The President’s allies
allege that 2,423 people voted who were not registered
to vote. The actual number is 0. Voters cannot be given
credit for voting in Georgia unless they are registered
to vote.”
Registrants showed up to vote on election day and
checked into the Poll Pad and voted. While they voted
in person on election day, their vote was cancelled and
replaced with a fraudulent Absentee Ballot outlined
in Appendix C.1 at 56a. This is in violation of 52 U.S.C.
App.67a
§ 10307(a) Prohibited act – “No person acting under
color of law shall [ . . . ] willfully fail or refuse to
tabulate, count, and report such person’s vote.”
Via Duplicate IDs, over 3,800 double (and
sometimes triple) votes were counted and then the IDs
were merged right after the election to cover up the
crime. Double voting is a violation of 52 U.S.C.
§ 10307(e) – Prohibited Acts – Voting More than Once.
Absentee Ballots were counted when they were
not even mailed back in, or rejected, cancelled, or
spoiled by the County.
Credit for in person on election day voting is
found in the Voter History File, but not in the SoS
Numbered Report showing Registrants checking into
the Poll Pad, nor an updated Date Last Voted in the
Voter Roll. This also appears to be machine related.
There is evidence of Registrants voting early via
the SoS Voter History File, but the Date Last Voted is
not updated nor does the Registrant have a required
presence in the SoS Absentee file. It appears that
thousands of votes were designated and credited in
the Voter History File as YNN, or Absentee voting,
but neither the Voter Roll nor the Absentee File
substantiates these votes. These appear to be added
votes.
There was also evidence of in person early voting
fraud in that in the SoS Absentee file they voted early
in person, but they do not have voting credit in the
SoS Voter History File. These appear to be deleted
votes.
These impossible votes speak directly to the SoS
overriding and/or negating the County’s decisions and
App.68a
sworn duty on counting votes. It also appears
thousands of Registrants did not vote, but received
credit for voting, or their vote was swapped from their
desired selection, or they did vote but did not receive
credit.
The comparison of these files clearly shows that
no matter how well a County runs an election in
Georgia, their results can be altered after the fact.
This evidence clearly shows that Mr.
Raffensperger, in a letter to Vice President Pence and
members of Congress on January 6th, 2021, (See
Appendix H at 121a), made the following false statements about the 2020 General Election, which appear
to be in violation of 52 U.S.C. 10307(d) – Prohibited
Acts:
1.
“Their work has shown me that there is
nowhere close to sufficient evidence to put in
doubt the result of the presidential contest in
Georgia.”
2.
“There will end up being a small number of
illegal votes (there always is in any election
because federal and state law err on the side
of letting people vote and punishing them
after the fact), but nowhere near the amount
that would put the result of the presidential
election in question.”
3.
“Just as the result of your own election was
valid and accurate, the certified result in the
presidential contest is valid and accurate as
well.”
App.69a
APPENDIX D.1
VOTES CAST ON REGISTRANTS
NOT ON VOTER ROLL
In 2020, there were over 2,000 Reg IDs in the SoS
Voter History File (VHF) that were not anywhere on the
voter roll. They were not eligible electors, not able to
receive an Absentee Ballot, nor check in at a poll pad,
but they received credit in the 2020 election.
Reg IDs are issued sequentially. There are several IDs in this list with numbers that exceeded the
available range in 2020. This is another impossibility.
In GARViS when a county official merges Duplicate
IDs, the system automatically chooses the oldest/first
Reg ID as the surviving ID. A higher number is never
allowed, and would not present itself in the list of
voters that received credit in 2020. Double voting,
that appears to be machine related, can be found in
the list.
Case One – Fulton County Reg ID 13110943 is a
number that did not exist in 2020. It received credit in
the voter history file as YNN or absentee voting, but
does not exist in the 2020 SoS Absentee file.
Figure D.1.a: 2020 SoS Voter History File
App.70a
Upon further investigation, the voter associated
with 13110943 has a main Reg ID 6861366 which is
also in the voter history file as voting YNN and is in
the Absentee file as voting In Person on 10/17/2020.
Figure D.1.b: 2020 SoS Voter History File
Figure D.1.c: 2020 SoS Absentee File
This is a double vote, appears machine created
due to no tie to the Absentee file, and believe the
actual voter was a victim of Synthetic Identity Theft
via the SoS office. The Duplicate was improperly
merged (smaller Reg ID) on June 7, 2021, and was an
attempt to cover up the crime of double voting.
App.71a
Figure D.1.d: SoS Cancelled Voter File
Case Two – Reg ID 13487136 in Richmond
County is a number that did not exist in 2020 and is
also a case of Synthetic Identity Theft as outlined in
Appendix A.2 at 13a. This Reg ID received credit in
the voter history file as NNN, or in person on election
day vote.
Upon further investigation, the voter associated
with 13487136 has a main Reg ID 11770633 in
Richmond County and received credit in the voter
history file as voting NNN, which is a double vote on
this registrant.
These two Reg IDs also double voted in the
12/06/2022 Run-off as both receiving credit for voting
NNN.
Figure D.1.e: 2020 and
2022 SoS Voter History Files
App.72a
A third Reg ID 13537091 was found in
Washington County associated with this registrant. It
has only one appearance on the voter database of
11/04/2022 and then disappears again, which is
unlawful. Due to the date created, it appears there
may have been a fraudulent vote from this Reg ID in
the 2022 General.
Figure D.1.f: 11/23/2022 SoS Voter Roll
Washington County Merged two of the Reg IDs in
2023 and left Reg ID 13487136.
Figure D.1.g: SoS Cancelled Voter File
Figure D.1.h: SoS Cancelled Voter File
App.73a
Reg ID 13487136 appears to be a bad Reg ID. This
voter was at Cancelled Voter Street at one point in
2023.
Figure D.1.i: 07/21/2023 and
08/30/2023 SoS Voter Rolls
Case Three – There were some Reg IDs that had
not been on the voter roll in a very long time and
received credit for a 2020 vote.
Reg ID 180381, inactive status/returned mail,
was last seen on the 06/29/2016 SoS Voter Roll, and
not since. This ID was inactive dating back to the
09/04/2014 SoS Voter Roll with a Date Last Contact of
11/4/2008, which is 12 years prior to the 2020 election!
Figure D.1.j: 06/29/2016 SoS Voter Roll
App.74a
Case Four – Reg ID 1282440, inactive status/
returned mail, was last seen on the 12/07/2018 SoS
Voter Roll, and not since. This ID was inactive dating
back to the 11/06/2015 SoS Voter Roll with a Date
Last Contact of 7/31/2012, which is 8 years prior to the
2020 election!
Figure D.1.k: 12/07/2018 SoS Voter Roll
Another large group of Reg IDs make a first
appearance on the voter roll in mid-2021, 2022, and
2023 and nowhere in 2020. When they first appear,
they have backdated dates attempting to cover up
when they were added to the voter roll. Another
impossibility. Many of these are Duplicate votes that
were merged.
Two thousand votes credited in the 2020 election
while not on the 2020 voter roll appears to be machine/
programming activity, not real Georgians voting.
App.75a
APPENDIX D.2
SWAPPED VOTES FROM IN PERSON ON
ELECTION DAY TO A FRAUDULENT
ABSENTEE BALLOT
Pursuant to the US and Georgia Constitution,
NVRA Sec.12(2), HAVA, and Duncan v. Poythress, 515
F. Supp. 327 (N.D. Ga.), aff’d, 657 F.2d 691 (5th Cir.
1981), cert. dismissed, 459 U.S. 1012, 103 S. Ct. 368,
74 L.Ed.2d 504 (1982),” if the right to vote is denied
altogether or abridged in a manner which renders the
electoral process fundamentally unfair, a violation of
due process may be found. It is unlawful to deprive or
defraud the inhabitants of a State of a fair and
impartially conducted election process.”
There is evidence of Swapped Votes where the
voter voted in person on election day, and their vote
was replaced by the SoS with an Absentee Ballot. This
evidence was found by comparing three files, 1) ORR
Numbered reports from the Counties, which show the
exact timestamp a registrant showed up at their
precinct and checked into the Poll Pad, 2) The SoS
published 2020 Voter History File, and 3) The SoS
2020 Absentee File. With only 18 out of 159 counties
that partially responded to the ORR for Numbered
Reports in 2020, over two hundred swapped votes were
found. Below is an example of the data:
App.76a
Figure D.2.a: Fannin County 11/03/2020,
Numbered Report
The SoS VHF shows Reg ID 4968606 as casting a
vote in the 11/03/2020 Election, not as in person on
election day, but Mail In, Absentee Ballot.
Figure D.2.b: 2020 SoS Voter History File
The SoS Absentee File shows Reg ID 4968606
with an Application Date prior to the lawful date of
5/6/2020 handled by the SoS, not the County, as
outlined in Appendix C.1 at 56a.
App.77a
Figure D.2.c: 2020 SoS Absentee File
An Amici spoke with the person associated with
Reg ID 4968606. He did check into the Fire Station in
Blue Ridge, GA on 11/03/2020. He stated he voted
with his wife. It was confirmed that his wife is in the
file one minute later checking in. He also confirmed
he never requested or returned an Absentee Ballot in
the 11/03/2020 election. It appears this voter’s real
vote was deleted and replaced with a fraudulent
Absentee Ballot created by the SoS. Theft of a
person’s vote is a Civil Rights violation under the US
Constitution. It is also a violation of 52 U.S.C.
§ 10307(a) – Prohibited Acts – Failure or Refusal to
Permit Casting or Tabulation of Vote.
App.78a
APPENDIX D.3
DOUBLE VOTES ON DUPLICATE
REGISTRATION IDS FOR THE SAME PERSON
Appendices A.1 at 6a and A.2 at 13a discuss Duplicate Electors and how they are used to create Identity
theft on Georgians. Appendix B.4 at 50a shows how
Duplicates are used to manipulate Date Last Contacted
which in turn manipulates list maintenance.
The November 3rd 2020 Voter History Files
confirms the listing of voters credited with having cast
a ballot during the General Election. Further analysis
shows that 3,816 pairs of duplicated votes were cast
on different registration IDs. Duplicates are identified
as Registrants having the exact same name, street
address and birthyear. As many as 25 registrants had
as many as four ID’s linked to their original ID and all
got credit for voting in the same election.
As many as 1,166 duplicate registrants that cast
ballots early, prior to November 3rd election day and
were subsequently cancelled by the merging process
the following day or within three days of having voted.
Georgia law requires the voter rolls to be locked during
the 30 days prior to an election, therefore it is highly
unlikely the staff in all counties across the state
decided individually to review duplicates in the
middle of an election.
The Secretary of State provided the listing of
merged Reg IDs in response to an Open Records
Request, confirming duplications were authentic, by
virtue of their merge (deletion) activity.
Duplicates are also used to Double vote. Extensive
analysis was done using the Voter History Files from
App.79a
August, October, and November 2020, and 2020
Absentee Voter History Files. These were compared
to the Registrant Data and Date Last Voted from the
11/22/2020 Voter Roll. Many duplicates (and in some
case triplicate voters) have identical names, addresses
and birth years. Others are missing a middle name
or using only an initial on one registration, but not
the other. Many duplicates are obvious typos, such as
Terry vs Terri, etc.
App.80a
Figure D.3.a: 11/22/2020 SoS Voter RollDuplicate Registrations (xxxx)
used to redact personal data
App.81a
The duplications listed in Figure D.3.a were
brought to the attention of the county election board
in 2022. Duplications were properly merged into the
original ID, thus confirming the fact they were
confirmed as duplicate registrants by the registrar
and duplicate votes were cast in 2020.
In addition to the duplicate records found in the
Voter Roll, the Voter History File confirmed the votes
cast by ballot style on the same Reg IDs listed in D.3.a.
above, showing double and triple counting of votes.
The original ID appears to have voted by mail and in
person, while the ‘duplicate’ ID also voted.
Case One – Copied from the examples in Figure D.3.a.
above, a deeper analysis showed Reg ID 6273808 as
the original ID and was matched with Reg ID
8519254. The electors had the exact same name,
address and birthyear.
Figure D.3.b. Data from 11/22/2020 SoS
Voter Roll and SoS Cancelled File
App.82a
Figure D.3.c – 2020 SoS Absentee File
The SoS 2020 Absentee file shows each of these
Duplicate Reg IDs requesting, receiving, and
returning Absentee Ballots by mail for the November
2020 election. When Amicis analyzed the voter history
file for these two Reg IDs, this case became worse.
App.83a
Figure D.3.d: 11/22/2020 SoS Voter History File
APS KEY: NNN– Election Day; YNN – Early/
Absentee Mail
Figure D.3.d captures the Voting History of not
only the Original Reg ID 6273808, and the duplicate
ID 8519254, but it appears that another vote under
the Original Reg ID was counted in the History file.
This time it was classed as an in-person vote and not
an absentee/mailed ballot. The voter history file does
not include name or address, only Registration ID and
Ballot information.
Three votes were apparently cast, and counted for
this one elector in the 2020 election. Two by mail, and
one in-person on election day.
Figure D.3.e: Data from 2020 SoS Voter History
File and SoS Cancelled File
Conveniently, the duplicate ID was merged into
the original ID after the Board received and reviewed
the challenge in July 2022, confirming the duplicate
had existed during the 2022 election.
App.84a
APPENDIX D.4
NON-RECONCILED VOTES CREDITED
AS ABSENTEE VOTING, BUT NOT
IN ABSENTEE FILE
Amicis compared the 2020 SoS Voter Rolls with
the 2020 VHF and found over 27,100 Registrants that
received credit for voting but did not have an update
on their Date Last Voted field for 11/03/2020. When a
Registrant votes in an election, their Date Last Voted
field is updated. This becomes public record. At a minimum, the mismatch is another impossibility to analyze.
Amicis went a step deeper and analyzed the vote
credits of YNN, indicating Absentee Voting, and
compared these entries with the 2020 SoS Absentee
File. Disturbingly, over 8,700 of these YNN vote
credits do not show up in the 2020 SoS Absentee File.
Under proper operations, the Date Last Voted is updated, and all Absentee voting activity is recorded in
the Absentee file. These 8,700 vote credits appear to
be fraudulently added to the vote total. The spread of
these 8,700 vote credits can be found in 145 of 159
Counties across Georgia. Again, this appears to be
machine/programing related and not County controlled.
Case One – Reg ID 538918 received YNN credit
for voting but is not in the 2020 SoS Absentee File.
Figure D.4.a shows the record in the 2020 SoS VHF.
App.85a
Figure D.4.a: 2020 SoS Voter History File
This WWII Army veteran died on November 27,
2003, and was cancelled by Evans County on
12/4/2003 per the SoS Cancelled voter file. The cemetery
marker was found.
Figure D.4.b: SoS Cancelled Voter File
Therefore, it appears the machines voted a person
that had been dead for 17 years!
Case Two – Reg ID 1068419 received YNN credit
for voting but is not in the 2020 SoS Absentee File.
Figure D.4.c shows the record in the 2020 SoS VHF.
Figure D.4.c: 2020 SoS Voter History File
This voter died on March 13, 2012, and was
cancelled by Liberty County on 04/01/2012 per the SoS
Cancelled voter file. The obituary was found.
App.86a
Figure D.4.d: SoS Cancelled Voter File
Therefore, it appears the machines voted a person
that had been dead for 8 years!
App.87a
APPENDIX D.5
VOTES ON BALLOTS NEVER RECEIVED
The analysis in Appendix D.4 at 84a of comparing
Registrants that did not receive an updated Date Last
Voted but received credit for voting showed very
alarming data.
There were at a minimum 5,100 Ballots that were
counted that were never mailed back in. There is
literally a blank in the Ballot Received field, and no
“A” for accepted by the County. This indicates the
County did not count these votes, and has the
appearance of a machine/programming override.
The reason 5,100 Ballots is a minimum, because
the comparison was only on the 11/22/2020 SoS Voter
Roll. Many additional Ballots were counted that were
never mailed in and the Registrant was quickly
deleted prior to the 11/22/2020 voter roll.
One such example speaks to the SoS voting
deceased people outside the Counties’ knowledge.
Case One – Reg ID 7155510 died on Sept 9, 2020,
and Bibb County cancelled her as “Deceased” on
9/27/2020. Obituary was found.
Figure D.5.a: SoS Cancelled Voter file
2020 SoS Absentee File shows Reg ID 7155510
with an Application Date prior to the lawful date of
5/6/2020 handled by the SoS, not the County, as
App.88a
outlined in Appendix C.1 at 56a. The Absentee File
shows the ballot was never received, the Ballot Status
does not have an “A,” so the County did not count the
vote.
Figure D.5.b: 2020 SoS Absentee File
The 2020 SoS Voter History File shows Reg ID
7155510 as casting a vote in the 11/03/2020 Election
via Absentee Ballot when she was already deceased
and never mailed in a ballot.
Figure D.5.c: 2020 SoS Voter History File
This is clear Identity Theft and a fraudulent vote
of a deceased person that the County had already
deemed cancelled and deceased.
This minimum 5,100 fraudulent votes occurred in
over 65 of 159 Counties.
App.89a
APPENDIX D.6
VOTES ON REJECTED, CANCELLED,
AND SPOILED BALLOTS
The analysis in Appendix D.4 at 84a of comparing
Registrants that did not receive an updated Date Last
Voted but received credit for voting showed very
alarming data.
A minimum of 450 Ballots that were Rejected,
Cancelled, or Spoiled still received credit outside the
County’s control.
Case One – Pursuant O.C.G.A. § 21-2-216, a
Mentally Incompetent elector must be removed from
the voter roll and not be allowed to vote. Pierce
County, GA cancelled an elector for being Mentally
Incompetent, then rejected the Absentee Ballot when
it was received, but the vote was counted by the SoS
anyway. Counting a Ballot that was rejected at the
County Level and on a registrant previously deemed
Mentally Incompetent is a violation of, O.C.G.A. § 212-216, O.C.G.A. § 21-2-386 regarding Rejected
Ballots, NVRA Sec. 8.(3), and 2 U.S.C. 9.
The SoS Cancelled Voter File shows Reg ID
1619656 as Cancelled on 9/23/2020 due to being
“Mentally Incompetent”.
App.90a
Figure D.6.a: SoS Cancelled Voter File
The 2020 SoS Absentee File shows Reg ID
1619656 with an Application Date prior to the lawful
date of 5/6/2020 handled by the SoS, not the County,
as outlined in Appendix C.1 at 56a. The County marked
the Ballot Status as “R” for rejected on 10/7/2020 with
the status reason “Ineligible Elector”. The County did
not count the vote.
App.91a
Figure D.6.b: 2020 SoS Absentee File
Despite the County handling the ballot correctly,
the SoS Voter History File shows the vote counted
anyway.
The 2020 SoS Voter History File shows Reg ID
1619656 as counting a vote in the 11/03/2020 Election.
Figure D.6.c: 2020 SoS Voter History File
Case Two – Reg ID 2483751 did not have a Date
Last Voted update of 11-03-2020 but received credit in
the 2020 VHF as voting YNN, or Absentee Voting. The
2020 SoS Absentee file shows that the County entered
“C” for cancelled, and “No Ballot in Oath Envelope” for
the status reason. Literally, a fraudulent vote override
was cast on an envelope!
App.92a
Figure D.6.d: Data from 2020
SoS VHF and 2020 SoS Absentee File
Case Three – Several Rejected ballots with reason
of missing signature were still cast as votes in the
2020 Election. The County performed their duty and
rejected the ballot with no signature, but it appears
that machines/programming overrode their decision
and counted the vote anyway. Figure D.6.e shows
some of the sample data.
App.93a
Figure D.6.e: Data from 2020 SoS VHF
and 2020 SoS Absentee File
App.94a
There are various versions/dates of the 2020 SoS
VHF that Amicis worked with. Why do three of the
above entries show a “credit for voting” only in some
of the versions?
Case Four – Reg ID 10488907 did not make it
past the Absentee Application Request stage. Fulton
County entered “R” for Rejected on Application
Status. The Status Reason entered was “Computer
Generated Signature.”
Another Ballot Request was accepted on
10/14/2020 and mailed on 10/14/2020 but was never
mailed back in. The Ballot Received field was blank
and the ballot was not counted by Fulton County.
Whether the first ballot request was rejected or the
second ballot was never mailed back, neither show a
cast vote, but the SoS counted the vote anyway.
There are various versions/dates of the 2020 SoS
VHF that Amicis worked with. Why do some of them
show a “credit for voting” but not all of them?
App.95a
Figure D.6.f: Data from 2020 SoS VHF
and 2020 SoS Absentee File
Case Five – Reg ID 2948773 returned a Ballot on
10/06/2020 that the County marked “S” for Spoiled
and the reason was “Invalid Marking on Ballot”.
Another Ballot was sent on 10/06/2020, but was
never mailed back. The Ballot Received field was
blank and the ballot was not counted by Washington
County. Whether the first ballot request was spoiled
or the second ballot was never mailed back, neither
show a cast vote, but the SoS counted the vote
anyway.
App.96a
Figure D.6.g: Data from 2020 SoS VHF
and 2020 SoS Absentee File
There were a lot of Ballots that were marked
Rejected, Cancelled, or Spoiled by the County and not
counted, but they received credit for voting anyway.
App.97a
APPENDIX D.7
VOTES ON DECEASED THAT ARE
INELIGIBLE TO VOTE
Pursuant to O.C.G.A. § 21-2-231, Deceased
voters must be removed and may no longer vote. Reg
ID 8720588, shown below, died in July 2012; the
obituary was easily found online to confirm this. Yet
this voter not only remained in active status on the
voter roll through September 2021 when it was finally
inactivated.
Figure D.7.a: 09/10/2021 SoS Voter Roll
This registration mysteriously turned Active
again in November of 2023 and somehow an early ballot
was cast In Person, according to the 2023 Voter History
File.
Figure D.7.b. November 2023 Voter History File
This instance was dutifully recorded and submitted as a challenge to the Fulton County Board for further investigation. The response to this challenge
from the Board was an explanation that this was a
‘test vote.’
This does not explain why a random person who
last voted in 2012, should be selected as a ‘test vote”
App.98a
during a general election in 2023, two years after the
ID was removed from the voter roll.
Using the materials requested from the SOS, particularly the Cancelled Deceased voters, we have
matched the listing to the Voter History File of
November 2020 and found a further four registrants
brought back from the dead, in addition to the
registrant referenced in Appendix A.1 at 6a, all of whom
were returned to the voter roll with identical information, gender, race, original created dates, etc. with the
exception of their Street Name, which was listed as
Cancelled Voter Street. Interestingly, they kept the
same house number as the original registration. Although they show a created date of March 2022, they
did not appear on the voter rolls until May of 2023.
Figure D.7.c Cancelled Voter Street; Only on
05/08/2023 SoS Voter Roll
Six deceased registrants had votes credited in
2020, yet they were NOT on the 2020 Voter Rolls.
App.99a
Figure D.7.d: Data from 2020 SoS Voter History
File and SoS Cancelled Voter File
Of the Deceased Registrants that have been
brought back onto the voter rolls from 2013 to April
2024, 72 have been regular voters through the March
2024 election. Not all registrations returned with the
exact information as previously. Several changed
counties, or middle name, or race, or gender. However,
several remained exact replicas of the original
registrant.
App.100a
APPENDIX D.8
VOTES ON FELONS THAT ARE
INELIGIBLE TO VOTE
Appendix A.3 at 19a speaks to the Synthetic
Identity Theft committed against Felons. During the
2020 General and 2021 Runoff Election Cycle, over
8,600 Felons were cancelled and the reason stated was
“Felon”. Pursuant to NVRA Sec. (8), 42 U.S.C. § 15483
Sec. (303)(a)(2)(A) (HAVA), O.C.G.A. § 21-2-231, Felons
are ineligible electors and cannot vote. Of these 8,600
Felons, that were cancelled right around the election,
336 received credit for a vote.
Case One – Reg ID 7886963 was brought onto the
voter roll on 06/27/2020. He was already a Felon per
the GA Department of Corrections. Per the 2020 SoS
VHF he received credit for voting NNN, or in person
on election day. Fulton County Cancelled him and the
reason was “Felon” on the very same day. This appears
to be a cover up of a crime as the data suggests this
person never intended to vote.
App.101a
Figure D.8.a: 2020 SoS Voter History File
and SoS Cancelled Voter File
Case Two – Reg ID 02399798, per the 2020 SoS
VHF received credit for voting NNN, or in person on
election day. Fulton County Cancelled him and the
reason was “Felon” on the very next day. This appears to
be a cover up of a crime as the data suggests this
person never intended to vote.
Figure D.8.b: 2020 SoS Voter History File and
SoS Cancelled Voter File
App.102a
APPENDIX D.9
VOTES ON INACTIVE VOTERS THAT DIDN’T
CURE THEIR INACTIVE STATUS
There is evidence that suggests votes were
unlawfully cast on Inactive voters. The Registrant
was Inactive Status before the election, turned Active
the month of the election, voted, then turned Inactive
again all the while their registration address on file
did not change. Georgia Law is clear, if you are in
Inactive Status and have not moved, you can show
proper ID and vote. If this occurs, then you are
activated again and stay active. Amicis have the same
pattern of data around the 2020 and 2022 General
Elections.
Case One – The evidence below is a small
sampling from the 2022 General Election where the
inactive registrant appears to vote but quickly goes
back inactive at the same address. Other than the
appearance of a fraudulent vote, this is also a violation
of O.C.G.A. § 21-2-234 & O.C.G.A. § 21-2-235 list
maintenance law on moving a registrant from active
to inactive to purged. When a vote is activated and
then placed inactive again within a few months, it
does not follow the law.
App.103a
Figure D.9.a: SoS Voter Roll Data from
10/03/2022, 10/31/2022, 11/23/2022, & 02/05/2023
App.104a
Comparing status changes around an election,
Amicis also found over 9,800 that fit a pattern of
becoming inactive the month prior to the election,
activated during the election month and then staying
active. It appears a mailing went out around October
2020, which notified the SoS office of Returned Mail.
Consistently through the database, these Returned
Mail Registrants vote and the data suggests them to
be fraudulent.
Case Two – Reg ID 211587 is in Stephens County
and became inactive status in October 2020. The SoS
VHF shows a vote was cast via Absentee voting. The
SoS Absentee file does not follow normal protocol.
When a registrant votes “In Person” Absentee, Ballot
Request, Ballot Issued, and Ballot Received are all the
same date. In the case of Reg ID 211587, they are not
the same.
Figure D.9.b: 2020 SoS Voter History File
App.105a
Figure D.9.c: 2020 SoS Absentee File
Amicis are still uncovering impossibilities in these
9,800 votes with a very consistent pattern.
App.106a
APPENDIX D.10
SIGNIFICANT CHANGES IN
THE VOTER HISTORY FILE
The Voter History File for an Election should be
the history of the Reg IDs that cast a vote in a particular election. The file changes all the time so there is
no “History” in History. Most people who review the
VHF say the data has no integrity. Fraud and cover
up of crimes can be found when comparing with other
SoS files.
Many times, when a suspicious Registrant is
challenged, the SoS will say “that was a clerical error”
and they remove the ID from the list. After tens of
thousands of changes, “clerical error” becomes a thin
excuse.
Amicis have discovered when IDs are merged, the
ID remaining will be in the Voter History File. In
other words, one ID may be deleted and the merged
ID will remain. In Appendix D.3 at 78a, it was shown
how double voting is covered up with a merge. When
this happens, one ID will drop off the Voter History
File for that election.
There are very large swings in just the quantity
of people that voted. The 8/05/2021 Voter History File
was compared with the 10/13/2023 Voter History File
for the 2020 Election. The results were surprising.
There were 54,006 Reg IDs deleted and 6,504 Reg IDs
added.
The SoS Voter History File, from a forensic
standpoint, is irreconcilable.
App.107a
APPENDIX E
IMPROPER REGISTRATION DATA –
UNLAWFUL VOTES
Electors providing government ID, such as a
valid driving license are required to register with the
same information that is provided on such identification
card. The Real ID Act – Title II, H.R. 1268 Sec. 202
(b), which specifies the minimum documentation
requirements for issuance of all State Identification
Cards. Item number one on this list is the person’s full
legal name. 6 CFR 37.3 further defines Full Legal
Name as being an individual’s first name, middle
name(s), and the last name or surname, without use
of initials or nicknames.
Also required to be provided is the person’s address
of principle residence. As outlined in O.C.G.A. § 21-2217 (a) (1), “The residence of any person shall be held
to be in that place in which such person’s habitation
is fixed, without any present intention of removing
therefrom;”
As Amicis reviewed the Georgia Voter Rolls, from
2014 through 2024, thousands of records were
uncovered with incomplete or missing information,
including name, address, and birth year, which
demonstrates that the identification of voters is either
not being presented or is not being recorded.
App.108a
APPENDIX E.1
NOT A FULL LEGAL NAME
Pursuant O.C.G.A. § 40-5-100 regarding Driver’s
Licenses, and O.C.G.A. § 21-2-417 regarding Voter
Identification Cards, both Georgia statutes require
the Full Legal Name and Address of Residence be provided. These are a sample of the authorized
‘identification’ cards must be presented in Georgia for
Voter Registration. The data on these identification
cards is used to create the voter registration and
verify eligibility when adding registrants into the
voter database. Random spot checking showed many
of these registrants have full names on other publicly
available documents, e.g. Home Titles, County Tax
data, etc.
The votes cast in November 2020 were confirmed
counted in the 2020 Voter History File. The total
number of registrants with missing or incomplete name
in the November 2020 voter roll was staggering 8,964
and of those a 6,651 were credited with casting a vote
in 2020. Therefore, the question must be raised, what
official identification was presented at registration?
App.109a
Figure E.1.a: 11/22/2020 SoS Voter Roll
No Full Name, Initial or Missing Name (NOTE:
Use of xxxx for redaction purposes)
App.110a
APPENDIX E.2
MISSING PRECINCT INFORMATION
During the November 3, 2020 election, there were
4,634 registration IDs with no assigned precinct data.
Yet, 146 of those registrants apparently managed to
cast a vote in 2020, while not assigned at the correct,
or in fact any precinct. Some 961 of these registrants
had a complete residential street address listed, that
should have enabled the correct precinct to be
assigned, assuming the complete street address was a
valid address. Without any precinct assigned, 93
registrants with a valid residential address, but no
precinct assigned conveniently voted Absentee by
mail, while ten somehow found their correct precinct
to cast their vote on election day.
Figure E.2.a.: 11/22/2020 SoS Voter Roll
No Precinct Data assigned – valid residential
address
The remaining 3,674 Reg IDs with no valid voting
precinct were also missing a valid street address. As
expected, “Missing Street Address” could not possibly
have any assigned precinct data. Nevertheless, there
were 23 of these Missing Street Address registrants
who managed to cast a vote in November 2020,
without any precinct data being assigned.
App.111a
Figure E.2.b: 11/22/2020 SoS Voter Roll-No
Address and No Precinct Data assigned
Although both examples relate to the 2020
election, we continue to see these discrepancies in the
2022, 2023 and 2024 Voter Rolls. This mis-management of voter registration data is in direct violation of
NVRA. 52 U.S.C. § 21083(a)(2)(A).
App.112a
APPENDIX E.3
REGISTRATIONS AT NON-RESIDENTIAL
PROPERTIES
Pursuant to O.C.G.A. § 21-2-217 (a)(1) stipulates:
“The residence of any person shall be held to be that
place in which such person’s habitation is fixed,
without any present intention of removing therefrom.”
Across the state, thousands of registrants have been
found to list various commercial enterprises as their
residential address. Examples of those more
commonly used have been PO Boxes, UPS Stores and
US Post Offices, storage units, retail stores, and
places of industrial manufacture. All of these are
clearly not residential properties.
Several Counties have similar invalid addresses,
a sample from Chatham County where the Elections
Office confirmed with the registrants and actively updated those who requested a corrected address, and
removing those they were unable to contact as
outlined in the challenge process of O.C.G.A. § 21-2229.
App.113a
Figure E.3.a: 11/22/2020, 08/05/2022,
and 03/07/ 2023 SoS Voter Rolls-Sample of NonResidential Property Addresses
App.114a
This is a nationwide problem that is not being
addressed by the software tools such as E.R.I.C.
(purchased by the Secretary of State in Georgia) and
widely touted as the preferred method to clean up the
Voter rolls. USPS allows Licensed Contractors to provide database information on residential and other
addresses that may or may not have mail deliveries.
This information is not being fully utilized to support
the accurate and legal registration of voters in
Georgia. New registrations continue to be added with
Non-Residential property addresses in 2021 through
2024.
App.115a
APPENDIX F
IMPROPER LIST MAINTENANCE
Pursuant to Help America Vote Act (HAVA) that
mandates States adopt computerized statewide voter
registration lists and maintain them “on a regular
basis” in accordance with NVRA. 52 U.S.C. § 21083
(a)(2)(A), O.C.G.A. § 21-2-234 (a)(1) and O.C.G.A § 212-235 outline the requirements for completion of List
Maintenance Activities.
The Secretary of State has made a token effort to
comply with this in the odd years, however the volume
of changes and updates is less than 50% of the eligible
records to be updated.
This is a two-step process. Active but dormant
registrants with whom there has been no contact with
the elections office for five years are eligible for
processing to Inactive. The election staff must attempt
to contact them for confirmation of eligibility. Lack of
response permits the inactivation of such registrant.
Per NVRA and O.C.G.A. § 21-2-234 this inactivation
cannot be made purely on lack of voting activity
during the five-year period.
App.116a
APPENDIX F.1
ACTIVE REGISTRANTS BEYOND
FIVE-YEAR PERIOD
O.C.G.A. § 21-2-234(a)(2) stipulates “In the first
six months of each odd-numbered year, the Secretary
of State shall identify all electors whose names appear
on the list of electors with whom there has been no
contact during the preceding five calendar years and
who were not identified as having changed
address . . . ”.
The 2020 SoS voter roll included a total of
128,636 active voters with whom there has been no
contact beyond the five-year minimum, and in some
cases for 20 years.
Figure F.1.a: 11/22/2020 SoS Voter RollActive voters not yet moved to Inactive Status
One has to wonder why many of the registration
files had been modified. Some were modified as
recently as October, 2020, during the election cycle,
yet there was no contact data recorded. Contact is
considered any communication or contact from the
registrant, which might include updating an address
with another eligible government agency such as the
Dept. of Driver Services.
App.117a
APPENDIX F.2
INACTIVE REGISTRANTS BEYOND TWO
GENERAL ELECTION CYCLES
The second step of the process in List Maintenance
looks at those now long-time inactive registrants.
O.C.G.A. § 21-2-235 (b) states that “An elector placed
on the inactive list of electors shall remain on such list
until the day after the second November general
election held after the elector is placed on the inactive
list . . . ”. The November 2020 SoS voter roll included
almost 390,000 Inactive IDs. The regulation goes on
to state: “if the elector makes no contact, as defined in
Code Section 21-2-234, during that period, the elector
shall be removed from the list of electors”. The November 2020 SoS Voter Roll includes a total of 87,830
registration IDs that were identified and eligible for
removal during the first six months of the following
odd year, two full General Election cycles prior to the
2020 November election.
These Inactive registrants had been identified
with a reason for their inactive status, including: No
Contact, Returned Mail, and National Change of
Address (NCOA). This status is flagged in the
election system by the software service ERIC, however it appears this data was not acted upon in a
timely manner, as evidenced by the voter rolls. 18,617
were identified as No Contact; 36,413 were listed as
Returned Mail, and 32,800 had their moved out of
State confirmed by the USPS approved data service.
App.118a
Figure F.2.a: 10/25/2020
SoS Voter Roll-Inactive Registrants
Effectively, it is a seven-year process to remove
those dormant electors, during which the electors
should have been notified of their pending removal
status, and then processed off the system within the
first six months of the next ‘odd’ year.
The SOS office did issue ‘purge’ listings in July of
2017, July 2019, and July 2021 with less than 50% of
eligible registrants being processed off the rolls.
Today the voter rolls remain bloated with multiple
dormant registrations that should have been
processed off under the earlier List Maintenance procedures. There are requirements to keep the voter
rolls current and they are not being followed.
App.119a
APPENDIX G
SECRETARY OF STATE FILE
DEFINITIONS AND SOURCES USED
Amicis in Georgia have built a data warehouse of
SoS published, purchased, and Open Records
Requested files. Only when analysis is done combining
several different types of files over time can the fraud
be discovered.
1. Voter Rolls (VR) – Purchased from the SoS, are
an accounting of the Georgia Voter Database at a particular point in time. Amicis did not look at one point
in time, but over ten years in time using over 50
different voter rolls. Specific files analyzed:
2014: 09/04, 12/11
2015: 04/05, 11/06
2016: 06/29
2017: 05/01
2018: 12/07
2019: 10/07
2020: 01/21, 08/11, 10/25, 11/22
2021: 01/27, 02/16, 04/29, 08/03, 09/10, 11/04, 11/17
2022: 01/04, 02/07, 02/28, 04/01, 05/04, 06/06, 07/05,
08/05, 09/01, 10/03, 10/31, 11/23
2023: 02/05, 05/08, 06/30, 07/05, 07/20, 07/21, 08/14,
08/30, 09/13, 10/20, 12/01
2024: 01/08, 01/24, 02/05, 02/14, 03/11, 03/21, 04/10,
04/17
App.120a
2. Election Absentee Files – Published by the
SoS, are an accounting of the activity during early
voting in a particular election. Specific election files
analyzed:
2020
General
2022
Primary
2022
General
2023 General
3. Numbered Lists – ORR file from the County,
are an accounting of all voters that checked into a poll
pad on Election Day to vote. Amicis reviewed 18 out of
159 Counties from 2020.
4. Voter History Files (VHF) – Published by the
SoS, are an accounting of who was credited with
voting in a particular election. While history should
not change, this file changes over time. Various versions
of the following specific election files were analyzed:
2020
General
2022
Primary
2022
General
2023 General
5. Purge Files – Published by the SoS, are
listings of purged Inactive registrants that have had
no contact in two election cycles per O.C.G.A. § 21-2235. The following SoS Purge files were analyzed:
2019
2021
2023
App.121a
APPENDIX H
RAFFENSPERGER LETTER TO
VP PENCE AND CONGRESSMEN
Office of the Secretary of State
Brad Raffensperger
SECRETARY OF STATE
January 6, 2021
VIA ELECTRONIC MAIL
The Honorable Jody Hice
404 Cannon House Office Building
Washington, D.C. 20515
The Honorable Barry Loudermilk
2133 Rayburn House Office Building
Washington, D.C. 20515
The Honorable Kelly Loeffler
131 Russell Senate Office Building
Washington, D.C. 20510
RE: Point by Point Refutation of False Claims
about Georgia Elections
Dear Congressmen and Senator Loeffler:
Thank you to each of you for your service to our
country. I am addressing this letter to you because
each of you have publicly stated that you are going to
App.122a
object to Georgia’s electors elected in the November
2020 election. You are certainly entitled to your
opinions. However, I want to ensure that your
colleagues in the House and Senate have accurate
information on which to base their votes to your
objection. I respectfully request that you enter this
letter into the Congressional Record. Once these
refutations are considered, I am confident that
Georgia’s validly elected electors will be accepted.
Like you, I am disappointed in the results of the
2020 Presidential Election. However, my office has
taken multiple steps to confirm that the result is
accurate, including conducting a hand audit that
confirmed the results of the Presidential contest, a
recount requested by President Trump that also
confirmed the result, an audit of voting machines that
confirmed the software on the machine was accurate
and not tampered with, and an audit of absentee
ballot signatures in Cobb County that confirmed that
process was done correctly. Law enforcement officers
with my office and the Georgia Bureau of Investigation have been diligently investigating all claims of
fraud or irregularities and continue to investigate.
Their work has shown me that there is nowhere close
to sufficient evidence to put in doubt the result of the
presidential contest in Georgia. In Georgia, elections
are run by county election officials in each of our 159
counties. While there is no such thing as a perfect
election, our law enforcement officers are not seeing
anything out of the ordinary scope of regular postelection issues that will be addressed by the State
Election Board after the investigations are complete.
There will end up being a small amount of illegal votes
(there always is in any election because federal and
App.123a
state law err on the side of letting people vote and
punishing them after the fact), but nowhere near the
amount that would put the result of the presidential
election in question.
The result of the presidential election is not what I
preferred, but the result from Georgia is accurate.
Indeed, this body, and both of you, have already voted
to accept the results of Georgia’s elections by voting to
seat the elected Congressional representatives from
Georgia. As your colleague Representative Chip Roy
astutely pointed out, “[T]hose representatives were
elected through the very same systems--with the same
ballot procedures, with the same signature validations,
with the same broadly applied decisions of executive
and judicial branch officials--as were the electors
chosen for the President of the United States under
the laws of those states, which have become the subject of national controversy.” Just as the result of your
own election was valid and accurate, the certified
result in the presidential contest is valid and accurate
as well.
Losing candidates contesting election results and
procedures is nothing new in Georgia. Former
gubernatorial candidate Stacey Abrams and her
allies made false claims about Georgia’s election
equipment and processes in the run up to and
aftermath of her 2018 defeat. Many of those same
claims are made now by the President and his allies.
They were false then and are false now. Objecting to
a state’s presidential electors is nothing new in Congress either. Your colleagues on the other side of the
aisle objected to accepting the votes of certain
presidential electors after the 2000, 2004, and 2016
presidential elections. Those objections were not
App.124a
merited then, and, at least in the case of Georgia’s
electors, are not merited now. As Senator Tom
Cotton recently pointed out, “If Congress purported to
overturn the results of the Electoral College, it would
not only exceed [it’s] power, but also establish unwise
precedents. . . . Objecting to certified electoral votes
won’t give [President Trump] a second term—it will
only embolden those Democrats who want to erode
further our system of constitutional government.”
POINT BY POINT REFUTATION OF FALSE CLAIMS
The claims raised by the President and his allies
to dispute the result in Georgia fall into four broad
categories: 1) allegations regarding Dominion voting
machines, 2) allegations regarding absentee ballots, 3)
allegations regarding poll watchers, and 4) allegations
of votes cast by ineligible voters. I will go through each
of the allegations in turn and explain how we know
that none of these issues come even close to placing in
doubt the result of the election.
I.
Allegations Regarding Dominion Voting
Machines
Many false allegations have been made about the
Dominion voting machines. These claims were made
by Democrat-allied groups prior to the election and are
being made by people allied with the President now.
These claims ranged from the perennial allegations
from losing candidates that the machines were
“flipping-votes” to the truly bizarre claims that
Dominion was founded by foreign oligarchs and
dictators for the purpose of keeping Hugo Chavez in
power. The claims were false when Democrat-allied
groups raised them prior to the election and are still
App.125a
false. These claims have been thoroughly debunked by
election authorities, subject matter experts, and third
party fact checkers.1 There was even a social media
rumor that a third-party had conducted an audit of
voting machines in Ware County, Georgia and had
found that the machines “flipped” votes from Trump
to Biden at a rate of 28%. Not a single part of that
rumor was true. It was quickly debunked by the Ware
County Elections Director2 and by fact checkers.3 After
Fox News and Newsmax were made aware that they
had been reporting false claims about Dominion
voting machines, both networks published retractions.
Newsmax stated, “[n]o evidence has been offered that
Dominion . . . used software of reprogrammed software
that manipulated votes in the 2020 election.”4
The allegations about Dominion most relevant to
the election outcome in Georgia are that votes tallied
1 Setting the Record Straight: Facts and Rumors. <https://www.
dominionvoting.com/election2020-setting-the-record-straight/>.
Accessed January 5, 2021.
2 Ware County Election Supervisor Carlos Nelson said, “I can
tell you this—I don’t want to cuss—this is a darned lie. Our vote
machines are secure. There’s no vote flips.” https://sos.ga.gov/
index.php/elections/secretary_of_states_office_debunks_ware_
county_voting_machine_story. Accessed January 5, 2021.
3 Dominion Machines Didn’t Flip Votes in Ware County, Georgia.
Associated Press. December 7, 2020. https://apnews.com/article/
fact-checking-9773239691. Accessed January 5, 2021.
4 Fox News, Newsmax Shoot Down Their Own Aired Claims on
Election After Threat of Legal Action. USA Today. December 22,
2020. https://www.usatoday.com/story/entertainment/tv/2020/
12/22/fox-newsmax-shoot-down-their-own-aired-claims-election/
4004912001/. Accessed January 5, 2021.
App.126a
on a Dominion vote tabulator were somehow manipulated on a statewide basis to elevate the count in
favor of the Democratic presidential candidate. It is
important to understand that this is not possible—not
on a machine-by-machine basis, not by alleged hacking,
not by manipulating software, and not by imagined
ways of “sending” votes to overseas locations.5 In
Georgia, we were able to show that none of these allegations are true because we completed a 100% hand
audit of all ballots cast in the presidential contest.6
This hand audit, which relied exclusively on the
printed text on the ballot-marking device ballot or the
bubbled in choice of the absentee ballot confirmed the
result of the election with a 0% risk limit.7
We further know these allegations are false because our office engaged a federally-certified voting
systems test lab to perform an audit of the voting
machines following the November election.8 Pro V&V,
5 Dominion Statement on Sidney Powell Charges. <https://www.
dominionvoting.com/dominion-statement-on-sidney-powellchargest>. Accessed January 5, 2021.
6 Georgia Secretary of State. Historic First Statewide Audit of
Paper Ballots Upholds Results. https://sos.ga.gov/index.php/
elections/historic_first_statewide_audit_of_paper_ballots_upholds_result_of_presidential_race. Accessed January 5, 2021.
7 Id.
8 Georgia Secretary of State. Secretary Raffensperger Announces
Completion of Voting Machine Audit. https://sos.ga.gov/index.
php/elections/secretary_raffensperger_announces_completion_
of_voting_machine_audit_using_forensic_techniques_no_sign_of
foul play. Accessed January 5, 2021.
App.127a
based in Huntsville, Alabama is a U.S. Election Assistance Commission-certified9 Voting System Test
Laboratory (VSTL), meaning the lab is “qualified to
test voting systems to Federal standards.”10 Pro
V&V’s accreditation by the USEAC was also recommended by the National Institute of Standards and
Technology (KIST), the U.S. government’s physical
science laboratory dedicated to creating standards
and measures that would help America be the leading
science innovator in the world.
Pro V&V conducted an audit of a random sample
of Dominion Voting Systems voting machines throughout
the state using forensic techniques, including equipment from Cobb, Douglas, Floyd, Morgan, Paulding,
and Spalding Counties. ICP (precinct ballot scanners),
ICX (ballot marking devices), and ICC (central
absentee ballot scanners) components were all subject
to the audit.11 In conducting the audit, Pro V&V
extracted the software or firmware from the
components to check that the only software or firmware on the components was certified for use by the
Secretary of State’s office.12 The testing was
conducted on a Pro V&V laptop independent of the
system.13 According to the Pro V&V audit, all of the
software and firmware on the sampled machines was
9 https://www.eac.gov/voting-equipment/voting-system-testlaboratories-vstl/pro-vv
10 Id.
11 See Note 5, supra.
12 Id.
13 Id.
App.128a
verified to be the software and firmware certified for
use by the Office of the Secretary of State.14
Through each of these actions, I can definitively
say that the results reported by the Dominion Voting
System used in Georgia were accurate.
II. Allegations Regarding Absentee Ballots
Georgia has had no-excuse absentee voting since
2005, when it passed on a party-line vote by a
Republican controlled legislature and was signed by a
Republican governor. Traditionally, absentee by mail
voting in Georgia only accounts for about 5% of the
electorate, but due to the Coronavirus pandemic, it
increased to approximately 25% of the electorate in
November 2020. Absentee by mail ballots increased
from around 222,000 in the November 2018 General
Election to over 1.3 million in the November 2020
Election. The President and his allies have alleged
that Georgia did not adequately enforce its laws
regarding verification of absentee ballots. This
allegation is untrue. The truth is that my office protected and strengthened Georgia’s signature
verification system. My office provided GBI training
to each county so that they could better conduct
signature verification and also introduced a photo ID
requirement into absentee ballot applications by
creating an online request portal that requires the
voter’s name, date of birth, and Georgia driver’s
license number to match voter records in order to
request an absentee ballot.
14 Id.
App.129a
Much has been made of a Signature Match
Settlement Agreement15 entered into on the advice
and recommendation of the Georgia Attorney General’s
office in order to protect Georgia’s signature verification
laws on both absentee ballots and absentee ballot
applications. The President and his allies allege that
the Settlement Agreement unconstitutionally changed
Georgia law. That assertion has been rejected by
courts and is not supported by the facts.
Multiple lawsuits have challenged the Settlement
Agreement. All have rejected the claims that it
weakened Georgia’s signature match laws.16 The
Settlement Agreement came about because Democrat
party groups filed a lawsuit challenging Georgia’s
signature verification process as unconstitutional. To
get a full release of all claims and protect Georgia’s
signature verification laws, my office agreed to send
out an Official Election Bulletin to counties from our
Elections Director that offered best practices on how
to conduct signature verification. The recommended
practices were based off many counties’ existing procedures.
As Judge Grimberg of the Northern District held
in considering these claims, “[this] argument is belied
15 The President and his allies generally refer to the Settlement
Agreement as a Consent Order or Consent Decree. However, as
the title of document clearly shows, it is a Compromise
Settlement Agreement and Release.
16 See Wood y. Raffensperger et al., Order Denying TRO. NDGA.
1:20cv04651-SDG (stating that “Woods’ argument is belied by
the record.”)
App.130a
by the record.”17 According to the latest data provided
to our office from counties, Georgia counties rejected
2980 absentee ballots for missing or invalid
signatures in the November election. This is in addition to the 2777 ballots that were initially identified
as having a missing or invalid signature and were
later cured by the voter pursuant to the process set
forth by the Georgia General Assembly. Out of
1,322,529 absentee ballots cast in the November
election, this means 0.43% of absentee ballots were
initially identified as having a signature issue and
that 0.22% of ballots were rejected due to missing or
invalid signatures. These numbers are actually
slightly higher than the number of rejected ballots for
signature issues in the 2018 election, where 222,193
absentee by mail ballots were cast and 454 were
rejected for signature issues, a rejection rate of
0.2%.18
To further put any questions regarding Georgia
county elections officials signature verification to bed,
the law enforcement officers in my office, in
conjunction with law enforcement officers with the
Georgia Bureau of Investigation, conducted an audit
of signatures on absentee ballots in Cobb County. We
chose to start with Cobb County because it was the
only county where the President and his allies had
submitted any credible evidence that the signature
verification process was not properly done. The audit
found “no fraudulent absentee ballots” with a 99%
confidence threshold (based on the sample size of
17 Id.
18 Id.
App.131a
reviewed signatures).19 The audit found that only two
ballots should have been identified by Cobb County
Elections Officials for cure notification that weren’t.20
In one case, the ballot was “mistakenly signed by the
elector’s spouse,” and in the other, the voter “reported
signing the front of the envelope only.”21 In both
cases, the identified voters filled out the ballots themselves.22
There have also been allegations of so-called
“pristine ballots” in Fulton County. These are ballots
that partisan poll watchers thought looked suspicious
during the hand audit because they were not folded
(as ballots that had been put in an envelope would be).
First, there are numerous reasons why a handmarked ballot may be not folded. Emergency ballots,
which are ballots cast by eligible voters at polling
places if there is an issue with a ballot marking device,
are scanned straight into the scanner. Certain
military/overseas ballots or ballots that are damaged
and cannot be scanned are duplicated and would also
not be folded prior to scanning. The unstated
implication of this allegation is that county elections
officials are creating fake or invalid ballots and
running them through scanners. There is absolutely
19 Georgia Secretary of State/Georgia Bureau of Investigation
Absentee by Mail Signature Audit Report. December 29, 2020.
https://sos.ga.gov/admin/uploads/Cobb%20County%20ABM%
20Audit%20Report%2020201229.pdf. Accessed January 5, 2021.
20 Id.
21 Id.
22 Id.
App.132a
no evidence that this happened a single time in
Georgia.
Finally, there have been allegations of illegal
ballot harvesting. One of the first things I did as
Secretary of State was to ensure that ballot
harvesting was illegal in Georgia. The law outlawing
ballot harvesting in Georgia was challenged in court,
but we successfully defended it. No specific allegations
of ballot harvesting have been brought forward.
Nevertheless, the MITRE Corporation’s National
Election Security Lab conducted a statewide Ballot
Harvesting Analysis of the November elections across
Georgia’s 159 counties. MITRE collected data on the
absentee by mail ballots requested and returned to
check for unusually high or unusually low return
rates. According to the report, a “statistical analysis
of ballot return rates shows no anomalous points; no
suspicious indicators of ballot harvesting.”23
III. Allegations Regarding Poll Watchers
There have been numerous reports of insufficient
access for poll watchers or public monitors. Ironically,
those reports are all made by poll watchers or other
public monitors, showing that they were in fact highly
involved in the process and monitoring each step of
the way. Georgia law balances access for partisan poll
watchers and public observers with the necessity of
allowing county election officials to complete their
23 Georgia Secretary of State. National Election Security Lab
Report on November Election. https://sos.ga.gov/index.php/
elections/national_election_security_lab_report_on_november_
election_shows_sec_raffenspergers_ballot_harvesting_ban_
holds_strong. Accessed January 5, 2021.
App.133a
work in a timely fashion without interference. It is not
unusual in any election for partisan poll watchers and
election officials to disagree on the exact level of access
that they should receive. Throughout this election
cycle, my office has told Georgia counties to ensure
transparency and openness and, when any questions
arise, to err on the side of transparency. We ensured
monitors had access and that the public could observe
the hand audit and recount, in addition to the regular
laws that govern partisan poll watchers on Election
Day and early voting.24
The most prominent allegation of issues with
monitors took place in State Farm Arena, where Fulton
County conducted its absentee ballot processing.
Unfortunately, due to what appears to be a miscommunication between county staff and poll watchers,
the poll watchers left at 10:30 p.m. on election night
when they thought Fulton was done scanning for the
night. Fulton denies ever telling monitors that they
had to leave. Fortunately, a monitor designated by the
State Election Board arrived shortly after the other
poll watchers left. Partisan poll watchers and other
monitors remained at Fulton County’s election warehouse where results were being tabulated the entire
time and were aware that absentee ballot scanning
was continuing at State Farm Arena. Fortunately,
surveillance video of the entire time scanning was
taking place exists and is publicly available. While the
President and his allies have used snippets of that
24 Georgia Secretary of State. Monitors Closely Observing Audit
Triggered Full Hand Recount. https://sos.ga.gov/index.php/
elections/monitors_closely_observing_audit-triggered_full_hand_
recount_ttansparency_is_built_into_process. Accessed January
5, 2021.
App.134a
video to imply untoward activity, review of the entire
surveillance tape by both law enforcement officers
with my office and fact checkers has shown that no
untoward activity took place—election officials simply
scanned valid ballots as they had been doing all night.
The entire video has been made available by my office
so that people can confirm this fact for themselves.25
IV. Allegations Regarding Ineligible Voters
Voting
The President and his allies have also made allegations regarding ineligible voters voting. My office
has investigated each of these allegations and will
continue to investigate them, but our initial investigations show two things: 1) the data used by the
President’s allies is not correct and 2) the actual
number of potentially ineligible voters who voted in
Georgia does not put the result of the election in question.
There are ineligible voters who vote in every
election because both federal and state law err on the
side of letting a potentially eligible voter vote and then
punish any illegal voting after the fact. If the number
of illegal voters is sufficient to place the result in question, the remedy is an election contest filed in state
court. The President and his allies have filed multiple
election contests in Georgia. Three have already been
dismissed, and one remains ongoing. In Georgia, we
have strong laws to deter illegal voting, and we
conduct as much list maintenance on our voter rolls
as allowed by federal law.
25 SecureVote GA Fact Check. https://securevotega.com/factcheck/.
Accessed January 5, 2021.
App.135a
The data that the President’s allies used to determine their alleged number of illegal voters is wrong.
Matt Braynard, the President’s purported expert
witness in his election contest, has already admitted
in testimony to the Georgia House of Representatives
Government Affairs Committee that he is not
accusing the people he has identified of actually
voting illegally.26 Although he states in his affidavit
filed in Court that there were 20,312 individuals who
cast ballots illegally in the November 3, 2020
election . . . , he clarified to the Georgia House of
Representatives Government Affairs Committee that
he was not actually accusing anyone of voting
illegally.27 Actual experts in political science, data
analysis, and election data have pointed out the data
used by Mr. Braynard is not reliable. Dr. Charles
Stewart III, the Kenan Sahin Distinguished Professor
at the Massachusetts Institute of Technology and the
founding director of the MIT Election Data and
Science Lab, reviewed Mr. Braynard’s declaration and
data and concluded that he uses data matching
techniques that are “[k]nown to be unreliable and
produce a preponderance of ‘false positives’ and that
the methodology used by Mr. Braynard and the
26 Trump v. Raffensperger. Fulton County Superior Court. Civil
Action No. 2020-CV343255. Respondent’s Motion to Exclude Affidavits and Testimony of Experts. December 15, 2020.
27 Id. Braynard Testimony to Georgia House of Representatives
Government Affairs Committee. December 10, 2020. (“In my affidavit I don’t believe I specifically accuse anybody of committing
any crime. I said there were indications—over and over again
potentially illegal ballots has been my language. Uh indications
of illegally cast ballots. I have not accused anybody of committing
a felony in any of my declarations.”).
App.136a
President’s other purported experts is “highly inaccurate.”28
Despite the inaccuracy of the numbers alleged by
the President’s allies, my office is committed to fully
investigating all claims of illegal voting, and that is
exactly what we have been doing. Those investigations are tedious and time consuming because
whether or not a person actually illegally voted can
depend on the specific factual circumstances, but
those investigations have allowed me to get a good
sense of the potential universe of illegal voters in the
November election in Georgia. The factual investigations confirm the opinions of experts like Dr. Stewart
who have accurately concluded that the numbers of
illegal voters in Georgia alleged by the President’s
allies are not accurate or reliable.
The President’s allies have alleged that 2,056
felons voted illegally in Georgia. By comparing information from the Department of Corrections and
Department of Community Supervision to the list of
people who voted in November, the actual universe of
potential felon voters is 74. Each of those voters are
under investigation to determine if they are the same
person indicated and that they are still under felony
sentence.
The President’s allies have alleged that 66,241
underage teenagers voted in Georgia in November.
The actual number is 0. Our office compared the list
of people who voted in Georgia to their full birthdays
to determine this. 4 voters requested a ballot prior to
28 See Note 25, supra. Declaration of Dr. Charles Stewart III.
App.137a
turning 18, and all 4 turned 18 prior to the November
3 election.
The President’s allies allege that 2,423 people
voted who were not registered to vote. The actual
number is 0. Voters cannot be given credit for voting
in Georgia unless they are registered to vote.
The President’s allies allege that 10,315 dead
people voted. Our office has discovered 2 potential
dead voters and both instances are under investigation. We will fully investigate all credible allegations
of potential dead voters, but the allegation that a large
number of dead people voted in Georgia is not supported by any evidence.
The President’s allies allege that 395 people cast
ballots in both Georgia and another state in November. That list is under investigation and in working
with election officials from other states, we have
already determined that many of the alleged “double
voters” are not the same people.
The President’s allies allege that 1,043 people
voted who were registered at addresses that are actually post office boxes. A simple google search of this
list revealed that many of the addresses that are
alleged to be post office boxes are actually apartments.
The President’s allies allege that approximately 4000
people voted in Georgia who had subsequent voter
registrations in other states. Our research into these
people shows that these allegations rely on inaccurate and incomplete data. The detailed voter
registration records on those voters reviewed so far
show that they are legitimate Georgia voters. The
President’s allies also allege that there are approximately 15,000 people who voted in Georgia after having
App.138a
filed a National Change of Address with the U.S. Post
Office indicating they had a new out of state address.
Mr. Braynard himself admits this fact does not establish that a person voted illegally. There are many
people who live out of state who are still completely
legitimate Georgia residents, including military and
overseas citizens, people in government service,
college students, temporary workers on assignment
somewhere else, and voters temporarily caring for
family others, etc. There will end up being a small
amount of illegal out-of-state voters, and my office will
seek punishment for those voters to the full extent of
the law. But our initial investigation indicates that
the total number of illegal voters for any reason (no
longer a Georgia resident, felon, double voter, etc.)
will not be close to sufficient to place the result of the
presidential election in Georgia in question.
CONCLUSION
As Secretary of State of Georgia, I know that half
the people are going to be happy after an election and
the other half are going to be upset. My job is to make
sure that both sides know that the results are
accurate. That is why I ordered a hand audit, a
recount, a signature audit in Cobb County, and a
statewide signature study in conjunction with the
University of Georgia. The facts show that the claims
asserted by the President and his allies about the
voting machines used in Georgia are false. The facts
show that the claims that the 2020 election did not
follow Georgia law on absentee ballots are false. The
claims that the election was not transparent or that
monitors did not have the access to which they were
App.139a
entitled are false. The claims that there are a sufficient number of illegal voters to put the result of the
Presidential contest in question are false. You have
already accepted the results of the November 3, 2020
election in Georgia for your own seats and those of
your colleagues. I respectfully request that, after you
review this evidence, you do the same for the
presidential electors who were validly elected by the
people of Georgia. We do not have to like the results
of an election to accept them. Thank you for your
consideration and your continued service to our country.
Sincerely,
/s/ Brad Raffensperger
cc: Georgia Congressional Delegation
Office of the Vice President of the United States
Office of the Speaker of the United States House
of Representatives
Office of the Minority Leader of the United
States House of Representatives
Office of the Majority Leader of the United
States Senate
Office of the Minority Leader of the United
States Senate
App.140a
APPENDIX I
LIST OF AMICI SIGNATORIES AND DONORS
Other Amici Signatories
Angela Chester Stewart
Richard James Armstrong
Claire Porter Harrison
Eileen Marie West
Nancy D. Curdy
Michael Mentzel
Sandra Mentzel
Jamee S Brennan
Patricia A Spradley
Robert B Spradley
Susan Foster Voyles
Stefan Bartelski
Marsha Sapp
Kimberly Lovello
Deborah Jean Davis
Amanda Prettyman
Paul Eugene Schneider Jr.
Catherine Cotney Harvil
William Gregory Harvil
Jennifer Hillegas
Dawn Thompson
Pamela M. VanAlstine
Ann Marie Drabek
Sandra Denise Bearden
Nancy Walker Arnold
App.141a
Donors
Helen Strahl
Kim Brooks
Rick Armstrong
Melodie Watson
Marcia Smith
Dan Nancy Curdy
Jamee Brennan
Will R Cooley
Marsha Sapp
Kim Lovello
Deborah Davis
Adam Sonja Underwood
Angie Stew
Jennifer Hillegas
Ann Marie Drabek
Vicky Sutton
Stacey Doran
Nancy Arnold
Gail Lee
Beverly Meng
Margie Morris
Karen Mann
Deller Brock
Angela Shopone
Carol Chamberlain
Carolann Brooks
Holly Troxel
App.142a
Marolyn Overton
Christina Benjamin
Sandra Kay darcy turner
Susan Loring
Helen Owens
Peggy White
Gary Coates
Vicky Sutton
Ally Rose Becker
James Abely
Debra Couey
Trish Hay
Patrick Joseph Johnston
Amanda Prettyman
Mary Benefield
Sarah Webster
Donna Gallaher
Carlie Hammond
Mountain Patriots Org
Sherena Arrington
Dr Raymond Tidman
Paul Eugene Schneider Jr.
Robert Coovert
Jennifer Jones
Sam Carnline
Field Searcy
David & Janette Long
This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.