30b6MarilynMarks PDFTran

30(b)(6) Marilyn Marks March 17, 2022
Curling, Donna v. Raffensperger, Brad
Page 1
1 IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF GEORGIA
2 ATLANTA DIVISION
3
4 DONNA CURLING, et al.,
5 Plaintiffs,
CIVIL ACTION FILE
6 vs.
NO. 1:17-cv-2989-AT
7 BRAD RAFFENSPERGER, et al.,
8 Defendants.
9
10 30(b)(6) VIDEO DEPOSITION of the COALITION FOR GOOD
11 GOVERNANCE, INC. through MARILYN MARKS
12 March 17, 2022
13 11:01 a.m.
14 TAKEN BY REMOTE VIDEOCONFERENCE
15 Robyn Bosworth, RPR, CRR, CRC, CCR-B-2138
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Veritext Legal Solutions

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1 INDEX TO EXHIBITS
2 EXHIBIT DESCRIPTION PAGE
3 Exhibit 1 Notice of Deposition 26
4 Exhibit 2 Objections to Notice of 28
5 Deposition
6 Exhibit 3 Plaintiffs' Third Amended 49
7 Complaint
8 Exhibit 4 First Supplemental Complaint 56
9 of Plaintiffs Coalition for
10 Good Governance, Laura Digges,
11 William Digges III, Ricardo
12 Davis, and Megan Missett
13 Exhibit 5 Supplemental Declaration of 59
14 Marilyn Marks
15 Exhibit 6 2017 Form 990-EZ 95
16 Exhibit 7 2018 Form 990 100
17 Exhibit 8 2019 Form 990 106
18 Exhibit 9 Plaintiffs' Notice of Filing 109
19 Declaration
20 Exhibit 10 Coalition Plaintiffs’ Detailed 111
21 Specification In Support of
22 Motion for Attorneys’ Fees
23 Exhibit 11 New York correspondence from 120
24 January 2021 citing Curling
25 Exhibit 12 NCSBOE letter from 2019 122

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1 Exhibit 13 E-mails, 9/26/19, 123

2 CGG2021001277506
3 Exhibit 14 3/4/21 letter from CGG to 126
4 Georgia Republican Leaders
5 Exhibit 15 Mission Statement - Coalition 136
6 for Good Governance
7 Exhibit 16 Articles of Incorporation for 138
8 a Nonprofit Corporation
9 Exhibit 17 Who We Are - Coalition for 140
10 Good Governance
11 Exhibit 18 CGG Board Discussion Package 150
12 Exhibit 19 Fundraising message 161
13 Exhibit 20 Fundraising message during 162
14 2020
15 Exhibit 21 Donate - Coalition for Good 163
16 Governance
17 Exhibit 22 Home page - Coalition for Good 166
18 Governance
19 Exhibit 23 Current Projects - Coalition 167
20 for Good Governance
21 Exhibit 24 Tweets from January 24, 2021 168
22 Exhibit 25 8/22/20 tweet 171
23 Exhibit 26 E-mails, 1/18/18, 186
24 CGG2021001278172
25 Exhibit 27 Supplemental Response to 188

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1 Interrogatory No. 12
2 Exhibit 28 Coalition Plaintiffs’ 190
3 Responses to Defendant Anh
4 Le’s First Interrogatories
5 Exhibit 29 Joint Litigation and Common 213
6 Interest Agreement
7 Exhibit 30 Facebook advertisement from 216
8 Friends of Coalition for Good
9 Governance
10 Exhibit 31 E-mail regarding ballot image 222
11 legislation
12 Exhibit 32 E-mails, 8/24/21, Subject: 225
13 Garland's new lawsuit against
14 BMDs
15 Exhibit 33 January 1, 2021 tweet 238
16 Exhibit 34 Coalition for Good 248
17 Governance’s and Coalition
18 Plaintiffs’ Objections and
19 Responses to Defendant Brad
20 Raffensperger’s First Request
21 for Admission
22 Exhibit 35 GA Senate Judiciary 259
23 Sub-Committee on Election Law
24 12.30.2020
25 Exhibit 36 Plaintiff Coalition for Good 266

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1 Governance’s Objections and

2 Responses to State Defendants'
3 Second Request for Production
4 of Documents
5 Exhibit 37 Response of Coalition for Good 267
6 Governance to Brad
7 Raffensperger’s First Request
8 for Production of Documents
9 Exhibit 38 Handwritten notes 275
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12 INDEX TO EXAMINATION PAGE
13 By Mr. Tyson 10
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1 APPEARANCES OF COUNSEL: (All appearances via Zoom)

2 On behalf of the Coalition for Good Governance and
3 the Deponent:
4 ROBERT ALEXANDER MCGUIRE, ESQUIRE
5 Robert McGuire Law Firm
6 113 Cherry Street
7 Seattle, Washington 98104
8 [email protected]
9
10 On behalf of the Curling Plaintiffs:
11 ZACHARY FUCHS, ESQUIRE
12 JENNA B. CONAWAY, ESQUIRE
13 REILEY JO PORTER, ESQUIRE
14 SONJA SWANBECK, ESQUIRE
15 HANNAH ELSON, ESQUIRE
16 Morrison & Foerster, LLP
17 2000 Pennsylvania Avenue, NW
18 Washington, DC 20006
19 [email protected]
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1 APPEARANCES (Continued):
2 On behalf of Defendant Secretary of State Brad
3 Raffensperger:
4 BRYAN TYSON, ESQUIRE
5 BRYAN F. JACOUTOT, ESQUIRE
6 DIANE FESTIN LAROSS, ESQUIRE
7 Taylor English Duma LLP
8 1600 Parkwood Circle, Suite 200
9 Atlanta, Georgia 30339
13 -and-
14 CAREY MILLER, ESQUIRE
15 VINCENT R. RUSSO, ESQUIRE
16 Robbins Ross Alloy Belinfante Littlefield
17 500 14th Street, N.W.
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1 APPEARANCES (Continued):
2 On behalf of Defendant Fulton County:
3 DAVID LOWMAN, ESQUIRE
4 Fulton County Attorney's Office
5 141 Pryor Street, Suite 4038
7 [email protected]
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9 Also Present:
10 Krishan Patel, videographer
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1 THE VIDEOGRAPHER: Today's date is March

2 17th, 2022, and the time is 11:01 a.m. This will be
3 the 30(b)(6) videotaped deposition of Coalition for
4 Good Governance given by Marilyn Marks.
5 Will counsel please introduce themselves
6 and any objection to the witness being sworn in
7 remotely.
8 MR. TYSON: Good morning. My name is
9 Bryan Tyson. I represent the State Defendants in
10 this case, and I'm joined today by my colleagues,
11 Bryan Jacoutot and Diane LaRoss.
12 MR. MCGUIRE: And I am Robert McGuire.
13 I'm counsel for the plaintiffs -- for the Coalition
14 Plaintiffs and Coalition for Good Governance, and
15 I'm here representing the deponent.
16 THE VIDEOGRAPHER: Would the court
17 reporter please swear in the witness.
18 THE REPORTER: Do we need appearance from
19 Mr. Fuchs?
20 THE VIDEOGRAPHER: Sorry, what was the
21 question?
22 THE REPORTER: Is that all the appearances
23 we need on the record? Do we need to introduce any
24 other counsel?
25 MR. LOWMAN: I will say I am David Lowman

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1 here for the Fulton County Defendants.

2 MARILYN MARKS,
3 having been first duly sworn, was examined and
4 testified as follows:
5 EXAMINATION
6 BY MR. TYSON:
7 Q Well, good morning, Ms. Marks. We'll do a
8 couple of housekeeping things real quick.
9 MR. TYSON: First of all, Mr. McGuire, are
10 you good with us reserving all objections except as
11 to form and responsiveness until trial or first use?
12 MR. MCGUIRE: Yes, and privilege, of
13 course.
14 MR. TYSON: Certainly, yes.
15 BY MR. TYSON:
16 Q And, Ms. Marks, you have the choice of
17 reading and signing or waiving that, reviewing the
18 transcript after today. I'm assuming you'd like to
19 read and sign?
20 A Yes, that's correct.
21 Q Okay. Well, good morning again. I'm
22 Bryan Tyson. I know we know each other well. It's
23 good to see you, Ms. Marks. I represent, obviously,
24 the State Defendants, the Secretary of State, and
25 the State Election Board.

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1 Have you ever been deposed before? I

2 honestly can't remember.
3 A In this case, no.
4 Q Okay. So I'll quickly cover our ground
5 rules so they're clear. If you've been in a
6 deposition with me before you'll recall there are
7 times where I ask a question, and nobody understands
8 what I'm asking. If that happens and you don't
9 understand my question, just go ahead and let me
10 know that, and I'll rephrase it.
11 I know we're starting around 11:00
12 eastern. If you need a break at any point, just let
13 me know. Only request is that we not take a break
14 while a question is on the table.
15 And then for Zoom, obviously it's just
16 best if we don't talk over each other and try to
17 make as clean a transcript to make Robyn's life as
18 easy as possible for our court reporter.
19 So if that works for you, we'll go ahead
20 and get rolling.
21 A Certainly fine.
22 Q What I'll do is begin with a few
23 background questions, we won't have to spend too
24 much time in there, and then we'll move into the
25 notice and all the different pieces we have today.

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1 If you can just state your name again for

2 the record.
3 A Yes, it's Marilyn Marks.
4 Q And what is your current address?
5 A 7035 Marching Duck Drive, Unit E504,
6 Charlotte, North Carolina 28210.
7 Q And how long have you lived in North
8 Carolina?
9 A I moved -- I grew up here and left when I
10 was about 16, long time ago, and came back here in,
11 I think, 2015.
12 Q Have you taken any medication, or do you
13 have any medical condition that would keep you from
14 fully and truthfully participating today?
15 A No.
16 Q I know you mentioned you hadn't been
17 deposed in this case. Have you been deposed in any
18 case before?
19 A Yes. Going back to the '70s, '80s, '90s,
20 I was involved in large corporate environments and
21 with a lot of commercial litigation, so I've been
22 deposed a number of times, but not in -- not in the
23 last 20 years that I can remember.
24 Q Got it. I was going to say let's not go
25 beyond 20 years. I'll make it much easier on that

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1 front.
2 A Okay. That sounds good.
3 Q So let me ask you about testimony in
4 trial. Do you recall testifying in a court in the
5 last 20 years?
6 A Yes.
7 Q And what was the case or what were the
8 cases where you were called to testify?
9 A Mr. Tyson, I'm sure I'm not going to
10 remember them all. I'm going to do my best, though.
11 Q Certainly.
12 A Going back to about 2009 there would have
13 been a case -- I sued the City of Aspen, Colorado,
14 and I would have testified in that case. I believe
15 I testified in a case against -- I'm going to come
16 up with the name of it in a minute. The county seat
17 is Salida, Colorado. It's Chaffee -- Chaffee
18 County, Colorado. We had a trial there. I can't
19 remember whether our organization sued or I sued,
20 but nevertheless, I think I testified there.
21 A case in Saguache County, Colorado, I
22 believe I testified there. I testified -- wait a
23 minute. I may not have testified in Saguache. I
24 was in the courtroom a lot. I can't remember
25 actually whether I took the witness stand. This has

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1 been a long time ago. This is maybe 2010, 2011,

2 something like that.
3 Let's see. More recently one of our state
4 cases, I believe it might have been in the case
5 related to the Amico challenge. You know, I don't
6 think -- I'm sorry, I don't think I took the witness
7 stand.
8 Q Was it the case with Judge Grubbs in the
9 2018 lieutenant governor contest, does that ring a
10 bell?
11 A Yes, that's what I was thinking, but now
12 I'm not sure whether I did or not. I can remember
13 in one of the Georgia cases taking the witness
14 stand, I believe, but I can't quite remember which
15 it was. I'm sorry. I have to really think about it
16 for a while.
17 Q Totally fine. Don't worry about that.
18 A Okay.
19 Q So just to quickly -- the cases that you
20 were involved with in Colorado, were those both
21 election-related cases?
22 A There were -- there were numerous
23 election-related cases in Colorado, and I was not
24 involved in any kind of commercial litigation in
25 Colorado, but yes, those -- those were two of the

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1 cases I was involved in.

2 Q And so what was -- how was -- how were
3 elections involved in the City of Aspen case that
4 you referenced?
5 A I ran for mayor of Aspen, Colorado in
6 2009, and they used instant runoff voting for the
7 first time, and the software turned out to have bugs
8 in it and didn't count right.
9 I decided not to ask for a recount or to
10 contest the election but instead waited purposely
11 until after the time the deadlines had passed, and
12 then I asked to see the ballots and ballot images as
13 public records to see -- we knew that there were
14 problems with the vote count, but we wanted to see,
15 you know, exactly how those problems manifested
16 themselves.
17 And so through public records request I
18 requested the ballots and was told, oh, no, ballots
19 aren't public records. And in Colorado legislation
20 had been passed to have ballots as public records.
21 And so I was introduced to Mr. McGuire at
22 that time, and we were both at that time living in
23 Colorado, and I engaged him to file an open records
24 lawsuit to obtain ballots as public records in this
25 election, and so that began work in litigation when

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1 all else fails toward election transparency.

2 Q Thank you.
3 And so was the case against Salida -- I'm
4 sorry, Chaffee County, I believe you said, was that
5 also related to elections?
6 A It was.
7 Q And how was that related to elections?
8 A That had its roots in the same type of
9 issue as the Aspen, Colorado case did. After the --
10 I believe it was the court of appeals in Colorado
11 ruled in the Aspen case that ballots were, indeed,
12 public records, I then requested some ballots from
13 Salida -- excuse me, Chaffee. Forget Salida. I
14 shouldn't have mentioned it. I was struggling to
15 come up with the county name.
16 I requested some Chaffee County ballots,
17 and I got the response back -- and now this is
18 through open records -- got the response back,
19 sorry, you can't have them because they would show
20 how people voted. And I remember laughing so much
21 at that answer and thinking, are they crazy? Of
22 course ballots don't show how people voted.
23 Well, with a little more exploration I
24 found out, indeed, they did show how people voted,
25 that there were bar code serial numbers on each

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1 ballot. And that became, I believe, one of the

2 issues that was derived -- I'm a little -- I'm
3 struggling a little bit now to remember whether that
4 case itself was about secret ballot or whether it
5 was about open records because they were refusing to
6 give us the ballots, and to our surprise they were
7 right that the ballots did disclose how people voted
8 which then led to other litigation that we didn't
9 talk about in Colorado that I didn't take the
10 witness stand on where I engaged Mr. McGuire. And I
11 say I did. I believe it was -- it was the
12 predecessor to Coalition for Good Governance.
13 And so we engaged Mr. McGuire to sue the
14 Secretary of State in federal court on the issue of
15 ballots as secret -- excuse me, secret ballots there
16 related to what we had learned in the prior case
17 about identifiable bar codes on the ballots.
18 Q Thank you. That's very helpful.
19 Have you been involved in election-related
20 litigation in any states besides Colorado and
21 Georgia?
22 A We have not filed any cases ourselves. I
23 was just trying to think back of whether or not I've
24 been called as a witness or anybody in our -- like,
25 our board of directors might have been called as a

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1 witness.
2 Q Let me ask a more specific question.
3 A Okay. All right.
4 Q Have you personally been a plaintiff in
5 any lawsuits about election administration in states
6 other than Colorado and Georgia?
7 A No, I have not as an individual been
8 involved in election litigation.
9 Q Thank you.
10 Have you ever been charged with a crime
11 before?
12 A No.
13 Q So you've never been arrested?
14 A No.
15 Q So never been convicted. That's easy
16 enough.
17 A No.
18 Q Have you discussed this case -- well, let
19 me actually go to a different area. Let's do a
20 little more on background.
21 A Okay.
22 Q Can you briefly summarize for me your --
23 any college degrees that you have and when you
24 received those?
25 A Yes. I have a degree in accounting, a

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1 bachelor of science in accounting, and I graduated

2 in 1975.
3 Q And from what institution did you receive
4 your bachelor's of science?
5 A University of Tennessee at the Chattanooga
6 campus.
7 Q And do you hold any other degrees?
8 A I knew you were going to ask that, and I
9 started looking for the name of it today, and my
10 records are not in the kind of shape that they
11 should be. I'm going to give you -- I'm going to
12 give you something close, and it'll have to do for
13 today, but there is an advanced management degree
14 that I have from Harvard Business School, but I'm
15 not telling you the exact name of it because I can't
16 exactly remember the name of it. But it was an
17 advanced management degree for CEOs, and I cannot
18 remember what year it was, and I couldn't find my
19 records on what year it was, but it would have
20 probably been around year 2000, something like that.
21 Q Besides your bachelor of science and the
22 degree from Harvard Business School, we'll just call
23 it that, do you have any other degrees?
24 A No other degrees. I have professional
25 certification as a CPA about the same time as --

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1 shortly after I graduated from college.

2 Q That was going to be my next question, if
3 you hold any professional licenses at all.
4 A I gave that up several decades ago, but at
5 that time, you know, in the '70s and '80s I was a
6 CPA.
7 Q Okay. Do you have any certifications that
8 you held?
9 A Let me think about that. I'm trying to
10 remember if there was something related to my
11 service on public company boards that -- if I did
12 I'm not -- I'm not quite remembering it right now.
13 Q Okay.
14 A Nothing that I have used extensively as a
15 certification.
16 Q Okay. That's helpful. Thank you.
17 And do you recall approximately when you
18 gave up your CPA license?
19 A It was probably the mid '80s.
20 Q And was that a voluntary decision or were
21 you required to surrender it?
22 A Oh, no. Heavens, no. It was a voluntary
23 decision because I moved out of anything that was
24 directly financial related and became a CEO of a
25 company, and I didn't really -- I had other people

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1 do that kind of work. I couldn't possibly keep up

2 with the education requirements and that sort of
3 thing for maintaining a CPA license.
4 Q Got it. Thank you.
5 So I know you've had, obviously, a long
6 employment history. I don't want to dig through
7 every single thing you've done since the 1970s, but
8 could we start with maybe the year 2000 and forward
9 and just kind of summarize your employers over that
10 time?
11 A Yes. So that's going to be easy because I
12 retired in about 2001, something like that. I was
13 the CEO for Dorsey Trailers, Inc., which was a truck
14 trailer manufacturer and manufacturing company, and
15 it was headquartered in Atlanta. It was a public
16 company. And at that same time, around that point
17 in time, I was also on the board of a New York Stock
18 Exchange company by the name of Dana, D-A-N-A,
19 Corporation, and also on the board of Eastman
20 Chemicals Corporation. So those were the paying
21 gigs I had back in those days.
22 Q And so you retired around 2001. Have you
23 had any kind of formal employment since that time?
24 A Not any kind of formal employment. I
25 serve certainly full-time for Coalition for Good

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1 Governance, but unfortunately at the moment it's an

2 unpaid -- it's an unpaid gig.
3 Q Understood.
4 So you've mentioned board service. What
5 boards are you currently serving on, if any?
6 A Only -- only Coalition for Good
7 Governance.
8 Q In the last 10 years have you served on
9 the boards of any other organizations?
10 A Not in the last 10 years.
11 Q Have you ever served on the board of any
12 other voting-related organization?
13 A I have not.
14 Q Do you have any specialized training that
15 you've received about elections and elections
16 administration specifically?
17 A When you say "specialized training," I
18 would think of that as attending seminars, workshops
19 taught by experts in fields like particularly
20 auditing, sometimes election security technology,
21 technology -- public policy on technology. Seminars
22 like that are -- I frequently attend. I would have
23 a hard time remembering all of them for you over --
24 from the last 10 years.
25 Q Understood. I don't want to ask you to

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1 try to dig through all that.

2 Have any of those seminars you've attended
3 about election administration resulted in any
4 certifications? I think the answer is no because I
5 don't think you hold any certifications, but I just
6 wanted to verify that.
7 A That is correct, I do not.
8 Q And you don't have any specialized or
9 any -- I'm sorry. You don't have any certifications
10 in election security either, correct?
11 A I'm not even aware that any exist, but if
12 I find out that some such programs do, it's
13 something I would be interested in participating in.
14 Q Got it.
15 And you don't hold any certifications in
16 cybersecurity, right?
17 A I do not.
18 Q You mentioned various symposiums and
19 seminars. I don't want to ask all the ones you've
20 attended, but can you recall maybe in the last 10
21 years any symposiums where you've spoken about
22 election security topics?
23 A Sure. Let me think about that for just a
24 moment. I have been frequently involved in Election
25 Verification Network. In fact, they are meeting

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1 today, and I had to forego the idea of presenting

2 there today. But it's a national group that really
3 focuses on election security, and I have from time
4 to time over the years presented at panels, that
5 sort of thing.
6 I not too long ago presented at a National
7 Science Foundation educational meeting. I couldn't
8 come up with the name of it for you right now, but I
9 presented there on -- I believe it was on election
10 auditing and making use of ballot images in
11 precursors to audits. That may not be quite right,
12 but it's in the ballpark.
13 Let's see, where else have I done speaking
14 on this. It seems like I've done a lot of it, it's
15 just not coming to my mind right now. I'll think
16 about it some more in background.
17 Mr. Tyson, I feel like I've got more to
18 tell you on that, I just cannot remember right now.
19 I -- we are asked so frequently to do presentations,
20 and right now I'm just not having the time to say
21 yes to that, and -- but I've done a good bit of it
22 in the past, but being specific about that right
23 now -- it's something that, quite frankly, I didn't
24 prepare for and didn't refresh my recollections on
25 that.

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1 Q And that's totally fine. I'm not trying

2 to give you a memory test on this.
3 A I will fail.
4 Q That's helpful. Thank you.
5 So let's go ahead and move on to our kind
6 of 30(b)(6) phase. We finished up with the
7 background pieces. As we're getting started here I
8 just want to confirm, Ms. Marks, do you have any
9 documents or anything in front of you that you have
10 available?
11 A The only thingy in front of me is a bunch
12 of blank paper to take some notes, and then I have
13 one page of hand-scribbled notes about some of the
14 projects that we have going and don't have going.
15 Q Okay. And if we could, if it's okay with
16 Mr. McGuire, we can just mark that as an exhibit
17 once we get rolling here after the deposition if
18 you're going to use it to refresh your recollection
19 about your testimony.
20 MR. MCGUIRE: Yeah, that's fine with me.
21 BY MR. TYSON:
22 Q We can do that at a break, Ms. Marks. We
23 don't have to do that right now.
24 Let me direct you to Exhibit Share,
25 Exhibit 1, which we marked, the second amended

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1 notice of the 30(b)(6) deposition.

2 (Exhibit Number 1 was marked for
3 identification.)
4 BY MR. TYSON:
5 Q You know what I can do? Let's make it
6 easy to start with. I can go ahead and --
7 A You going to screen share? Okay. That's
8 great.
9 Q Is that easy enough there to see?
10 A Sure. Uh-huh.
11 Q Marked as Exhibit 1?
12 A Uh-huh.
13 Q And this document is titled the Second
14 Amended notice of 30(b)(6) Deposition of the
15 Coalition for Good Governance. You see that?
16 A Yes.
17 Q I'm assuming you've seen this document
18 before?
19 A I have.
20 Q And you've read this document?
21 A I have.
22 Q So let me go to the second page, and I
23 have a kind of series of 30(b)(6) questions I'll ask
24 you that we'll get on the record about this.
25 A Okay.

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1 Q You see here in this section it indicates

2 that the organization must designate one or more
3 officers, directors, managing agents or other
4 appropriate persons to testify on behalf of the
5 organization; do you see that?
6 A I do.
7 Q And are you the person that the Coalition
8 for Good Governance has designated for this
9 deposition?
10 A Yes, I am.
11 Q Okay. And you see the next sentence
12 there, the person or persons must be ready to
13 testify about the information known or reasonably
14 available to the organization regarding the topics
15 listed in Exhibit A; do you see that language?
16 A I do.
17 Q And are you the individual designated for
18 all the topics on Exhibit A?
19 A Yes, I am.
20 Q And you understand that as the designee of
21 the Coalition, you're testifying about what
22 information is known or reasonably available to
23 the -- the organization, not just to you
24 individually, right?
25 A Yes, I do understand that.

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1 Q And as we use the term "organization" or

2 "Coalition" or "CGG," you understand that refers to
3 the entity Coalition for Good Governance, right?
4 A Yes, I do understand that.
5 Q Do you have a preference? Do you usually
6 say Coalition or CGG, or do you have a --
7 A CGG, whatever is easy. It's fine.
8 Q Well, when did you first learn that you
9 were going to be testifying -- I'm sorry, let me do
10 one more thing before we change here. We have also
11 marked as Exhibit 2 -- if I can make this work the
12 way I want it to -- the notice of objections to the
13 30(b)(6) deposition.
15 identification.)
16 BY MR. TYSON:
17 Q Do you see that document?
18 A I do see that document.
19 Q And Mr. McGuire and I have discussed this
20 is the Coalition's objections, and we will be
21 dealing with the objections as we work through each
22 topic.
23 A That's fine.
24 Q Is that your understanding?
25 A Yes.

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1 Q Okay, great, just so we have both of those

2 marked.
3 So when did you first learn about that
4 you'd be testifying at this deposition?
5 A Do you mean when did I first learn what
6 time it was going to be or that my deposition would
7 be -- or the Coalition's deposition would be taken?
8 Q Let me ask a better question.
9 A All right.
10 Q When did you first learn you were going to
11 be the 30(b)(6) witness for the Coalition?
12 A I knew that I would be the 30(b)(6)
13 witness for the Coalition from the moment that
14 depositions were being discussed for the Coalition.
15 How long ago that goes back I don't know, but
16 probably over a year.
17 Q Okay. Did you or someone else make the
18 decision that you were going to be the 30(b)(6)
19 designee, or did you just understand that was going
20 to be the case?
21 A Well, I figured at a minimum I would be a
22 major participant, but I certainly talked to our
23 board members about it, and they concur that I have
24 the greatest depth and breadth of knowledge, and I
25 checked with a couple of them about these topics and

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1 asked if they thought they had additional knowledge

2 that maybe I did not have and that sort of thing.
3 So it was an organization decision that I would be
4 the designee.
5 Q Thank you.
6 Do you recall approximately when you
7 started preparing for this deposition and these
8 topics in particular?
9 A Feel like I was a child probably when
10 that -- when I started preparing. No, because all
11 along, of course, I've known that my -- my
12 deposition and/or the deposition of CGG would be
13 taken, you know, the preparation is kind of always
14 in the back of your mind of -- so there's no mark in
15 time where I said, this is in preparation, and
16 everything I've done to date was not.
17 Q Got it.
18 So can you just summarize in your own
19 words what you understand your obligations were
20 regarding this deposition?
21 A Yes, to prepare myself for all of the
22 topics that were in the notice -- the second amended
23 notice, and to the extent that my attorneys did not
24 have objections to them to prepare myself to know as
25 much as practically possible about those topics, and

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1 to testify on behalf not just to my personal

2 knowledge but knowledge of the organization.
3 Q Well, let's talk next about how you got
4 ready then for today.
5 A Okay.
6 Q So I know you mentioned you spoke with the
7 board members. As a general matter what else did
8 you do specifically to get ready for today, not all
9 your training of your life that has prepared you for
10 this moment, but specifically for today what did you
11 do to get ready?
12 A Okay. I had a talk with Mr. McGuire to
13 try to prepare, I had a brief conferral with
14 Mr. Cary Ichter, one of our other attorneys, I -- as
15 I mentioned to you, I chatted with a couple of our
16 board members, and I also talked to a few of our
17 very active members who work with me on so many
18 projects to see if they had anything in mind that I
19 might be forgetting or might not be aware of. And
20 then I made a few notes about some of the projects
21 that I would consider to be quite incomplete for us,
22 and things that we are having to defer that we were
23 working on or decline.
24 So I did that, and, as I said, I tried to
25 find my -- some of the educational years and

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1 certificates and couldn't do it. That -- I think

2 that encompasses most of the preparation work I can
3 remember right now.
4 Q Thank you. That's helpful.
5 Are you aware that the State originally
6 sought to take this deposition in October of last
7 year?
8 A I don't remember the dates. I know that
9 this CGG deposition has been talked about at various
10 times for many months.
11 Q Are you aware that your counsel requested
12 the deposition be postponed because there were
13 additional documents that needed to be produced?
14 A Yes.
15 Q Do you know what those additional
16 documents were that needed to be produced?
17 A As I sit here at this moment I don't
18 recall that, but I do know that over the last
19 several months we've had additional documents that
20 we felt were important background, and some of
21 those, I believe, have been actually put into the
22 record -- some of those that we would have been
23 thinking of would have been put into the record, I
24 guess, in other depositions as well as -- as well as
25 sent to you-all through even recent updates of

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1 our -- of our documents.

2 Q Yes. And so as of today is the
3 Coalition's document production complete?
4 A Yes, but, of course, I know that we have
5 obligations to supplement as we -- as we go along,
6 and, quite frankly, every day there's some new
7 project or something that we're having to divert
8 resources or decline something to that extent that I
9 know that we are not completely finished with
10 document production because there'll be
11 supplemental.
12 Q But those are not documents that exist
13 today; those are documents that will enter the
14 Coalition's universe in the future, right?
15 A Right.
16 Q So let's take -- let's talk through some
17 specific categories of documents that you looked at
18 to get ready for today specifically.
19 Did you review any financial records of
20 the Coalition for Good Governance?
21 A I did. I looked at our 990s. Our -- you
22 know what I mean by our -- our Form 990s on behalf
23 of Coalition for Good Governance that have been
24 filed with the IRS.
25 Q Did you review any other financial

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1 documents besides the 990s?

2 A No, I didn't.
3 Q Did you review any of your prior
4 declarations in this case?
5 A I have not looked at those for purposes of
6 this preparation.
7 Q Have you reviewed the third amended
8 complaint or the first supplemental complaint to get
9 ready for today?
10 A I actually looked at the first
11 supplemental complaint about two weeks ago. I did
12 not go back and read the third amended complaint.
13 Q And did you review e-mails to get ready
14 for today?
15 A Yes, I did.
16 Q Are there --
17 A Certainly not all of my e-mails, but yes,
18 I did look at e-mails particularly to produce some
19 documents related to other activities that we were
20 having to decline or defer.
21 Q Are there any other categories of paper
22 documents that we haven't discussed that you
23 reviewed that you can think of?
24 A Let me think for just a second. Nothing's
25 coming to mind right now, but I don't know. A lot

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1 of documents pass -- pass through my computer that I

2 might have forgotten about right now.
3 Q That's all right.
4 So did you review any prior testimony to
5 get ready for the deposition today?
6 A Not -- not specifically for -- for today.
7 Q I know you mentioned that you spoke to
8 some of the board members about getting ready for
9 today. Obviously as we discussed the notice
10 requires the information known or reasonably
11 available to the organization be what the testimony
12 is about. Were there specific topics that you spoke
13 with the board members about in order to prepare for
14 today?
15 A It was generally talking about the
16 projects that -- some of which I had almost
17 forgotten about that they had charged me with
18 working on that didn't get done. That was one of
19 the key things that we did talk about.
20 Q And who are the other board members that
21 you spoke to?
22 A Virginia Rutledge Forney is her name, one
23 name, and then Mary Eberle. It's been a couple days
24 on that. Few days on that.
25 Q And are you, Ms. Rutledge, and Ms. Eberle

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1 the only members of the board of the Coalition?

2 A No. Sorry, it's Virginia Rutledge Forney,
3 F-O-R-N-E-Y, is her name. And no, that -- there are
4 other board members.
5 Q Okay. We'll get into that specifically,
6 but for the members of the board that you spoke to
7 to get ready, that was just Ms. Rutledge Forney and
8 Ms. Eberle, correct?
9 A Correct.
10 Q You speak with anybody else besides your
11 attorneys to prepare for today?
12 A Yes.
13 Q And who are those other individuals?
14 A I talked to Ms. Jeanne Dufort,
15 D-U-F-O-R-T, and Ms. Aileen, A-I-L-E-E-N, Nakamura,
16 N-A-K-A-M-U-R-A.
17 Q So just to make sure I've got all these
18 pieces, the individuals you spoke to besides your
19 attorneys to prepare for today are Ms. Rutledge
20 Forney, Ms. Eberle, Ms. Dufort, and Ms. Nakamura,
21 correct?
22 A Yes. I'm trying to think if there was
23 anyone else. I'm thinking for just a second. I'm
24 trying to remember if I covered some of this in a
25 conversation I had with Ms. Joy Wasson, and I might

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1 have covered it very generally, but it wasn't

2 necessarily saying, hey, look, I am preparing for my
3 deposition, and can you tell me this.
5 So for Ms. Dufort, do you recall what
6 topics you needed to speak with Ms. Dufort about to
7 get ready for today?
8 A Yes, we were talking about topics on,
9 again, projects that I have not fulfilled my
10 promises on that the organization has been unable to
11 complete, and we also were talking about the need to
12 do better communications with our members, and so
13 that's mainly what we talked about.
14 Q Same question for Ms. Nakamura, were there
15 topics -- which topics did you need to speak with
16 Ms. Nakamura about to be prepared for today?
17 A It was also related to where we stood on
18 various projects that we have undertaken and not
19 finished and trying to get status on some of those
20 things.
21 Q And what role does Ms. Dufort play in the
22 Coalition?
23 A She is one of our most active members.
24 And she does not have a formal title, she is not a
25 formal board member, but I consider her a close

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1 advisor and very, very, very active in shaping the

2 work we do.
3 Q And what is Ms. Nakamura's role in the
4 Coalition?
5 A It would be very much the same as
6 Ms. Dufort. I rely on her a lot for her -- for her
7 advice on community outreach, on participating in
8 some of our projects, and just very similar to
9 Ms. Dufort, they're just very active members that
10 follow.
11 She and Aileen Nakamura particularly
12 follows what's happening in Fulton County. She
13 attends all the board meetings and that sort of
14 thing, and she is the one who keeps me most up to
15 date with -- and keeps the whole organization up to
16 date with Fulton County's Board of Elections
17 activities.
18 Q Thank you.
19 Is there any topic in the notice of
20 deposition on which you are not prepared to testify
21 on behalf of the Coalition today?
22 A I don't think so, but I'll take a moment
23 and read back through it if that's okay.
24 Q Sure.
25 MR. MCGUIRE: And, Bryan, just want to

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1 interject I don't want it to get lost she has not

2 prepared on things we have objected to.
3 MR. TYSON: Thank you. Thank you for that
4 clarification. And those objections are all in
5 Exhibit 2, correct?
6 MR. MCGUIRE: Yes, unless -- the one thing
7 I would add to that is documents -- 1203 is a
8 court's order that pertains to private
9 communications of the Curling plaintiffs, and we are
10 going to adhere to that. I would believe the
11 rationale applies to us as well.
12 MR. TYSON: Thank you for that
13 clarification.
14 A I'm just scrolling back through the
15 document.
16 BY MR. TYSON:
17 Q Take your time. Just let me know when
18 you're finished.
19 A Okay. I'm not going to say my memory is
20 perfect on all of these things, but the one thing I
21 forgot to look at, but it's easily findable, you
22 asked about the exempt purpose, and I can tell you
23 generally I meant to look back at the exact words of
24 our mission statement, and I forgot to do that, but
25 that's easily findable.

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1 Q Certainly. And that's a topic we'll

2 actually cover with exhibits, so we'll be --
4 Q So aside from that, any objections that
5 Mr. McGuire noted, you're prepared to testify on all
6 of these topics, correct?
7 A Yes.
8 Q So with that, let's go ahead and move on
9 to the topics. Are you good? Do you want to take a
10 break now before we --
11 A I'm good if you guys are.
12 MR. MCGUIRE: Actually, would you mind if
13 we took a five-minute break? I just have something
14 I have to attend to.
15 MR. TYSON: That's good. 8:55 for Rob,
16 11:55 for the rest of us.
17 THE VIDEOGRAPHER: The time is 11:49 a.m.
18 We're off the record.
19 (Recess 11:49-11:54 a.m.)
20 THE VIDEOGRAPHER: Time is 11:54 a.m.
21 We're on the record.
22 BY MR. TYSON:
23 Q Thank you, Ms. Marks. So we're going to
24 go ahead and begin on the various topics, and my
25 goal is for us to just kind of move through these in

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1 order. There are going to be some questions that

2 kind of apply to multiple topics, but I'm going to
3 try to keep us kind of just marching through Exhibit
4 A as best we can to the deposition notice.
5 I'm likely going to refer to documents as
6 we go through. The ones I think we'll need to keep
7 handy are Exhibit 1, the notice of deposition, just
8 so we have that one available, and we may look at
9 the complaints a couple times as we work through
10 things, but we can cover that as we go.
11 So let --
12 A Bryan, hold on just a second. Let me make
13 sure I've got my Exhibit Share in a place I can get
14 to it.
15 Q Sure. And what I'll do, I'll just share
16 the screen as we go also to help make things easier
17 for you.
18 A Okay. Now I have screwed up the screen.
19 Let's see. Just a second. Let me get reorganized
20 here.
21 So am I -- am I to be seeing right now
22 Exhibit A, you're sharing that, is that what my
23 screen is supposed to be?
24 Q Yes, I'm sharing that. I can stop the
25 share if that helps you figure out.

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1 A No. I've got two screens up. I'm going

2 to minimize the Exhibit Share then and just look at
3 your screen share.
4 Q Great. And then other thing is if you
5 have to refer to a document at all to answer any of
6 these questions, just let me know that so we can
7 make sure that's part of the record as well. Most
8 of the documents I'll be presenting to you as
9 exhibits, but if you have something else you're
10 referring to, just let me know that.
11 A Okay. I don't have any documents, like,
12 set up to talk about, okay?
13 Q Okay, great.
14 Let's begin with topic number 1 here. It
15 is the organization's allocation of resources and
16 budgetary decisions from January 1, 2017, through
17 the present that reflect the diversion of funds and
18 resources the organization alleges it has undertaken
19 in its third amended complaint and first
20 supplemental complaint.
21 Do you see that topic?
22 A I do.
23 Q For each of these I'm going to ask you a
24 series of questions about it, so you'll hear these
25 over and over.

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1 You are the designee of CGG for topic 1,

2 correct?
3 A Correct.
4 Q And we discussed documents you reviewed to
5 prepare for your testimony generally. Were there
6 documents that you reviewed specifically for topic 1
7 in preparation?
8 A I did look at our Form 990, but not any
9 other specific documents.
10 Q Okay. And we've talked generally about
11 who you spoke to to get ready for your deposition
12 today. Did you speak to anyone currently associated
13 with CGG to prepare for your testimony on topic 1
14 specifically?
15 A For all of the people that we discussed
16 that I talked with, and I'm excluding counsel, okay,
17 from those -- from my answer, but for all of those
18 people actually what we were talking about is the
19 diversion of resources and allocation of resources
20 as we talked about the various projects that we have
21 undertaken, been unable to undertake, unable to
22 complete, and the ones that we are engaged in. So
23 that was the main -- main topic of those
24 conversations.
25 Q And you mentioned earlier that you had

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1 spoken with Ms. Dufort and Ms. Nakamura, who were

2 members, part of those conversations related to your
3 preparation for topic number 1; is that right?
4 A That's correct.
5 Q And did you speak to any other members
6 about topic 1 specifically besides Ms. Dufort and
7 Ms. Nakamura?
8 A I have recently talked with Ms. Joy
9 Wasson, but, you know, it was -- it was about this
10 topic, but I don't know that we were talking about
11 it in the context of, hey, I am preparing for
12 deposition. It was really much -- it might have
13 been in my mind that I knew we would be discussing
14 this, but I don't know that I formalized the request
15 as, hey, this is in formal preparation.
16 Q Got it.
17 And so what value -- I'm sorry, let me ask
18 it this way: In speaking with Ms. Nakamura,
19 Ms. Dufort, and Ms. Wasson --
20 A Wasson, W-A-S-S-O-N.
21 Q -- what information did they have about
22 the Coalition that was relevant to this topic?
23 A They were refreshing my recollection,
24 putting me on a guilt trip about some of the
25 unfinished projects that we had all agreed that were

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1 important to us that didn't get done.

2 Q And were those projects that you were
3 charged with undertaking, is that why it was a guilt
4 trip?
5 A These were either undertaken or providing
6 some strategic direction or providing introductions
7 to other organizations that might help or
8 reviewing -- reviewing ideas and documents,
9 something that was left either in my -- in my court
10 or the interns -- we have interns that help us from
11 time to time, and their priorities are constantly
12 getting shifted because this litigation ends up
13 taking priority over everything else most of the
14 time, and so their priorities get shifted, and so
15 sometimes our very active members like Ms. Dufort,
16 Ms. Wasson are awaiting intern work that gets backed
17 up.
18 Q Helpful. Thank you. And I realize,
19 Ms. Marks, I don't think I asked you in the
20 background piece, what is your official title at
21 CGG?
22 A Executive director, and I think I'm -- I
23 think I'm also vice president, and I am on the
24 board. I can't remember if I'm vice chairman or
25 not. But I'm on the board, executive director, and

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1 vice president.
2 Q Thank you.
3 Last kind of preparatory question on this:
4 Did you speak to anybody who was formerly associated
5 with CGG in order to prepare for topic 1?
6 A Are you saying formally, M-A-L-L-E-Y
7 (sic), or formerly?
8 Q Formerly, no longer associated with CGG?
9 A No. No.
10 Q So let me first ask this question: Does
11 CGG claim that it has had to divert financial
12 resources as a result of what it alleges are
13 unconstitutional or other unlawful acts of the State
14 Defendants in this case?
15 A Yes.
16 MR. MCGUIRE: Object to form.
17 BY MR. TYSON:
18 Q Does CGG claim that it had to divert
19 non-financial resources as a result of what it
20 alleges are unconstitutional or other unlawful acts
21 of the State Defendants?
22 A Yes.
23 Q Can you identify what specific actions of
24 the State Defendants have caused CGG's diversion of
25 resources?

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1 A Well, I would certainly refer you to the

2 complaint, to our other filings, motion for
3 preliminary injunction, all the briefs, and
4 certainly there are an array of actions of the State
5 Defendants that have caused the diversion of
6 resources as it relates to the Dominion Voting
7 System and the failures of the audits to be --
8 (Simultaneous speaking.)
9 Q So -- thank you. I'm sorry, I didn't mean
10 to interrupt.
11 A And I interrupted you. I apologize.
12 Q Just so I understand, is it correct that
13 the actions that CGG alleges the State Defendants
14 have undertaken that have caused the diversion of
15 resources are outlined in your complaints in this
16 case?
17 A Complaints and briefs and other motions,
18 yes.
19 Q So in order to determine the specific
20 acts, you need to kind of look at the entirety of
21 the docket; is that fair to say?
22 A Yes, and I'm sure -- I'm sure it -- the
23 entirety of the docket still does not cover every
24 type of activity that we find objectionable that may
25 have taken place at counties, may have taken place

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1 since the last time that documents were filed, but

2 yes, the basic -- the basic objections that we have
3 are covered in the docket.
4 Q And just so I understand, you referenced
5 actions of counties. Is CGG diverting resources for
6 things that -- for nonparties in this case as well?
7 A When you say "for nonparties" --
8 Q Let me ask it this way --
9 A Okay.
10 Q -- if that's -- is CGG also diverting
11 resources based on the actions of nonparties to the
12 Curling case?
13 A I'm not sure that we would know how to
14 parse out -- when we see election administration
15 problems in a county, I'm not sure we would know how
16 to parse out how much of that is attributable to a
17 County's misunderstanding, misapplication versus the
18 law and the direction of the State Defendants. I
19 don't think we have any such precision.
20 Q So if CGG prevailed on all of its claims
21 in the Curling case, but counties continued to have
22 election administration problems, CGG would continue
23 diverting resources to address those county
24 problems, right?
25 A I don't know that I would call that

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1 necessarily diverting resources because if we're

2 talking about, hey, if BMDs went away tomorrow and
3 the Dominion Voting System were remedied in the ways
4 that we have requested for our relief, if all of
5 that happened tomorrow morning, I expect that we
6 would still -- I know we would still be working on
7 county election administration problems and issues.
8 I wouldn't necessarily call -- I wouldn't
9 call that a diversion -- at all call that a
10 diversion of resources. That's much more of the
11 core of the kind of work we want to do and have not
12 been able to do.
13 Do I expect that should we be successful
14 in obtaining relief on everything we ask for all
15 election administration problems go away, no, I
16 don't expect that. And that's really much more, as
17 I say, of the kind of work we want to do is the more
18 day-to-day local-level transparency and voter
19 protection type of work.
20 Q Thank you.
21 I've marked as Exhibit 3, I'll go ahead
22 and share this on the screen, the third amended
23 complaint, which is document number 226 in the
24 Curling case.

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1 identification.)
2 BY MR. TYSON:
3 Q Do you see that document there?
4 A Yes. I'm seeing document 226, yes.
5 Q Yes. And so just for reference just so I
6 can show you, make sure we see, this is marked as
7 Exhibit 3, the third amended complaint of the
8 Coalition for Good Governance and the other parties.
9 You see that?
10 A I do. Remind me when that was filed.
11 Let's look at the --
12 Q It was filed --
13 A Thank you. Okay.
14 Q So what I want to do, there's some
15 specific allegations beginning on page 54 related to
16 the standing of the Coalition, and I want to ask you
17 specifically about paragraph 142, and the Coalition
18 says: Defendants' prior and intended imminent
19 enforcement of statute in Title 21 in the State
20 Election Board Rule have caused and will cause
21 Coalition to divert resources and personnel to
22 counteract Defendants' illegal acts.
23 Is the diversion of resources that's being
24 referred to there the filing of this litigation?
25 A Do you mind bringing up those statutes and

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1 rules to remind me what -- put this in context for

2 me, if you don't mind? It's been a long time since
3 I looked at this complaint.
4 Q Certainly. Let me see if I can get those
5 up here for you. And maybe I can ask a more general
6 question while I'm pulling these up for you.
7 A Okay.
8 Q What specifically does the Coalition
9 allege that it is having to spend financial and
10 non-financial resources on as a result of the
11 alleged actions or the actions of the State
12 Defendants in this case?
13 A Well, certainly litigation cost is an
14 enormous drain on our resources and all that goes to
15 support the attorneys.
16 Are you wanting me to, like, tell you
17 things like we have to buy transcripts; are you
18 asking me to list kind of litigation support cost --
19 I mean expenses?
20 Q I'm not looking specifically for numbers.
21 What I'm looking for is kind of by category. So the
22 allegation is that you had to divert resources from
23 something to something else.
24 A Right.
25 Q And my question is: What is the Coalition

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1 diverting resources to as a result of the actions

2 that are alleged in your complaints?
3 A And you're asking right now about
4 financial resources, correct?
5 Q Let's start with financial, and then we'll
6 do volunteer or other non-financial resources next.
7 So the record's clear let me ask the question again
8 specifically about finances.
9 A Okay.
10 Q What financial resources is the Coalition
11 diverting from existing projects -- I'm sorry. I
12 turned myself around. Let me start again.
13 So the Coalition is alleging that it
14 diverted resources from certain things to other
15 things, financial resources, correct?
16 A Yes.
17 Q And what specifically is the Coalition
18 diverting its financial resources to as a result of
19 the allegations in the complaint?
20 A Okay. And, Mr. Tyson, I'm going to answer
21 as it relates to the complaint as opposed to
22 answering based on those two citations because I
23 don't remember what those citations are right now.
24 Okay?
25 Q That's fine.

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1 A Okay. So as you know litigation is

2 expensive, and there are way too many types of
3 expenditures we have to make to support litigation
4 that we would prefer not to be involved in.
5 One, the example I gave you for a moment
6 ago, we certainly have to buy transcripts, we have
7 to buy services that collect documents, and, for
8 example, our Logikcull subscription is expensive.
9 We have to pay the attorneys what we can, and it
10 basically absorbs almost all of the financial
11 resources that we would otherwise be spending on
12 non-litigation programs.
13 And let's see. We have had to pay experts
14 and travel for experts, travel for our attorneys
15 back in the days before COVID when we did things in
16 person, and so it is the entire variety of things
17 that go to support litigation.
18 Our interns, we do pay our interns
19 modestly, but it's still big money to us, and they
20 spend the majority of their time on litigation
21 support, whether it's doing analytical work or doing
22 some research for us.
23 So I'm sure that is not all that we -- of
24 the types of expenditures that we have that go for
25 litigation support, but that's -- that will be

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1 generally the types of expenditures we have.

2 Q Let me ask you about some of the specifics
3 in the third amended complaint, Exhibit 3.
4 A All right.
5 Q You see the second part, it says:
6 Specifically, Coalition has been and will be
7 required by Defendants' past and intended conduct to
8 do the following.
9 And on the next page the first bullet
10 point relates to the topics you just discussed:
11 Paying the fees of lawyers, litigation, travel,
12 copying, all those types of expenses.
13 Do you see that?
14 A I do, and it makes me think of some other
15 stuff that I forgot about expenses.
16 Q Okay. My question specifically, though,
17 is if this lawsuit was over, then you would no
18 longer have to pay for the things that are listed in
19 the first bullet on page 55, correct?
20 A That's correct.
21 Q And the second bullet point is a
22 non-financial allegation here, and it's 90 percent
23 your time, and I suspect it may be more -- feel like
24 more than 90 percent of your time.
25 A It does. I think we missed a zero there.

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1 Q -- to participation and management in the

2 Coalition's litigation, educational, and
3 investigative efforts undertaken to counteract
4 Defendants' conduct in Georgia.
5 Do you see that?
6 A I do.
7 Q And if this lawsuit was over you would no
8 longer have to devote 90 percent of your time or
9 more to these litigation efforts at least, right?
10 MR. MCGUIRE: Objection, misstates the
11 document.
12 BY MR. TYSON:
13 Q You can answer if you can.
14 A Well, if the litigation on the Dominion
15 Voting System were over, indeed my time would be
16 freed up to go do the things that we want to be
17 doing instead.
18 Q Let me go to the last bullet point there
19 before paragraph 143, and it says that part of
20 what's happening now is you have to divert
21 Coalition's organizational personnel and financial
22 resources away from Coalition's established ongoing
23 efforts to market Coalition to new members and
24 thereby grow Coalition's membership.
25 Do you see that?

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1 A I do.
2 Q And if this litigation was over, would you
3 be able to begin again marketing Coalition to new
4 members and thereby grow the membership?
5 A Yes, we would.
6 Q So let me turn next to the first
7 supplemental complaint. Just a second.
9 identification.)
10 BY MR. TYSON:
11 Q I've marked as Exhibit 4 the first
12 supplemental complaint of plaintiffs Coalition for
13 Good Governance and others.
14 Do you see that?
15 A I see that, yes.
16 Q This is document 628. So let me turn to
17 the standing portions here, begin with the
18 allegations made about the Coalition specifically.
19 So in paragraph 218, the Coalition alleges
20 that the use of the -- well, these particular
21 statutes being in force, 21-2-300(a)(2) and
22 21-2-383(c) require -- and then explains what those
23 are -- I know you asked what those refer to --
24 requiring all polling-place voters to use the
25 Dominion BMD System, then you say that will force

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1 Coalition to divert personnel, time, and resources

2 to educating its members and the voting public about
3 how to protect their right to cast a secret ballot
4 and equally effective vote in the upcoming BMD
5 elections, and will impair Coalition's ability to
6 engage in the organization's other projects by
7 forcing it to divert resources to counteract the
8 Defendants' illegal acts.
9 Do you see that?
10 A I do.
11 Q How does the Coalition educate its members
12 and the voting public about how to protect their
13 rights to cast a secret ballot?
14 A Okay. Because of the large touchscreens
15 that basically display people's votes to others in
16 the polling place, what we have taken a lot of time
17 to do, many times informally, sometimes with kind of
18 mass communications, is to encourage people to vote
19 by mail, which is something that as an organization
20 we are not terribly enthusiastic about is voting by
21 mail, but we think it is the better of the two
22 alternatives.
23 And so for purposes of protecting the
24 right to cast an absolutely secret ballot, we think
25 we have been -- we have been telling people that we

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1 think that voting a vote-by-mail ballot is best.

2 At other times we have talked to people
3 about -- who have not been able to get their ballot
4 on time or for some reason just been unable to vote
5 by mail, we have shared with them how to go into the
6 polling places at a time in early voting that is not
7 necessarily crowded and then find a private machine
8 to vote on, how it's perfectly fine to ask the poll
9 manager if they can wait until a machine that's more
10 private is available. It's that kind of effort that
11 we have taken to tell people it's perfectly fine to
12 demand a private voting area.
13 Q Do you educate Coalition members
14 differently than the voting public, or is the
15 educational message the same?
16 A The educational message would generally be
17 the same, it's just that we would have more contact
18 with people who are more active members.
19 Q And in this particular document there's
20 not a whole lot of detail about other projects that
21 you are unable to be engaged in. Do you recall
22 submitting a declaration in this case outlining some
23 of those other projects?
24 A I have kind of the vague memory of that,
25 and we may have done it more than once, and

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1 certainly every week and every day that goes by that

2 list is going to shift and change.
3 I mean, there are things that happened
4 just this week that are new -- new projects that we
5 have to reject or cannot complete that -- so it's an
6 ever-growing list, I would say.
7 Q Understood.
8 So I think just to help guide our
9 discussion a little bit what I want to introduce as
10 Exhibit 5 a document that was filed in February of
11 2021, document number 1071-2.
12 Do you see that?
14 identification.)
15 A I do.
16 BY MR. TYSON:
17 Q This document is titled Supplemental
18 Declaration of Marilyn Marks.
19 A Right. Do you mind reminding me kind of
20 what this was part of? I've kind of forgotten what
21 we were doing in February of 2021.
22 Q Others can correct me if I'm wrong, but I
23 believe this was around the first time Judge
24 Totenberg asked us to present evidence on standing
25 specifically after the 2020 elections.

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1 Does that help with the timeline?

2 A It does.
3 MR. MCGUIRE: Excuse me, Bryan. Do you
4 want to let her pull it up and just flip through it
5 on her own screen so she can see it?
6 MR. TYSON: Certainly. Yeah.
7 A If you don't mind, can I take 30 seconds?
8 Building security is trying to reach me, and it's
9 because I forgot to return a phone call, so can we
10 take one minute off the record while I do that?
11 BY MR. TYSON:
12 Q Certainly.
13 A Thanks.
14 THE VIDEOGRAPHER: Time is 12:23 p.m. We
15 are off the record.
16 (Recess 12:23-12:24 p.m.)
17 THE VIDEOGRAPHER: The time is 12:24 p.m.
19 A Mr. Tyson, do you mind repeating what you
20 said to me when I got distracted by building
21 security there?
22 BY MR. TYSON:
23 Q Certainly.
24 A Okay.
25 Q And, again, that's totally fine.

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1 So my recollection is that February of

2 2021 was around the first time Judge Totenberg asked
3 us to submit evidence on standing issues following
4 the 2020 elections. And you can look at this on
5 your screen, but the general topics in your
6 supplemental declaration, as you can see on the
7 exhibit, are CGG activities and diversion of
8 resources, there was tabulation software problems
9 Mr. Hursti referenced in here, tabulation
10 discrepancies and audit failure. I'm only going to
11 ask you about the activities on the first part of
12 this declaration, but does that give you the context
13 you needed?
14 A It does. Thank you.
15 Q So what I'd like to do is just kind of
16 walk through the paragraphs of this declaration to
17 flesh out the activities that CGG is saying that it
18 has diverted resources from and to. And
19 specifically, is this a declaration that you offered
20 regarding the diversion of resources of the
21 Coalition?
22 A Diversion of resources and the other
23 topics that you referenced a while ago.
24 Q Certainly.
25 So starting at paragraph 3, you say that

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1 the Coalition for Good Governance was formerly known

2 as the Rocky Mountain Foundation; is that right?
3 A That is correct.
4 Q And did the Rocky Mountain Foundation have
5 a different purpose than the Coalition does?
6 A In the big picture it related to
7 protecting constitutional rights, but its focus on
8 policies were different than what we have moved to
9 starting when we took over the management of the
10 organization in 2014.
11 Q You anticipated my next question. You
12 referenced that the current management of CGG
13 undertook the management in 2014 with primary work
14 focused on election integrity and transparency in
15 Colorado elections, right?
17 Q And who are you referring to when you say
18 the current management of CGG?
19 A It would be Ms. Lisa Cyriacks,
20 C-Y-R-I-A-C-K-S, who is on the board, and Ms. Mary
21 Eberle, E-B-E-R-L-E, who is on the board, and
22 that -- that's who we're referring to here.
23 Q And so prior to 2014, the -- I guess the
24 then Rocky Mountain Foundation wasn't focused on
25 election integrity and transparency in Colorado

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1 elections; is that right?

2 A Mr. Tyson, may I go back and make sure I
3 answered your prior question correctly? I'm not
4 sure that I did.
5 Do you mind going back and asking -- and
6 having the court reporter read to me what you asked
7 about the prior organization?
8 Q We can or I can just reask it.
10 Q Did the Rocky Mountain Foundation have the
11 same focus on election integrity and transparency in
12 Colorado elections that the Coalition did after
13 2014?
14 A No, that organization -- and we were not
15 part of that management of that organization prior
16 to 2014. While they generally were there to protect
17 constitutional rights, and they were interested in
18 elections, their focus was different than the focus
19 we brought to it when we took over the management in
20 2014.
21 And when I mentioned Ms. Eberle and
22 Ms. Cyriacks, I was talking about the management who
23 came in in 2014 along with me. I was not trying to
24 say that that is the current -- those were the only
25 people still involved -- the only people involved.

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1 That's what I was afraid I did not answer you

2 correctly about.
3 Q Got it. Thank you. And I understood it
4 as being this was the group that came in in 2014, so
5 that's --
6 A Yes, that's what I intended to say.
7 Q So you say next in paragraph 4 that after
8 you moved to North Carolina in late 2015, CGG's work
9 began to transition to more geographically diverse
10 projects. Do you see that language?
11 A I do.
12 Q Was that change in 2015 that you
13 referenced a change in mission or just a change of
14 the activities of CGG?
15 A It was a broadening of the geography of
16 our work. I had really stayed busy focused on
17 Colorado, and Ms. Cyriacks and Ms. Eberle both live
18 in Colorado and are very active in election projects
19 and voting rights projects there, and so when I
20 moved to North Carolina I kept a foot in the
21 Colorado camp and began to -- I found work I wasn't
22 looking for in North Carolina when I ran into some
23 of the problems here in North Carolina. And so it
24 wasn't necessarily intentional that we began to
25 broaden our scope, but it kind of happened.

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1 Q Okay. And so it was really, I guess, a

2 broadening of activities -- the geographic scope of
3 activities; is that a fair way to characterize it?
4 A That is correct because much of the
5 activity was generally around election security,
6 open -- election transparency, open meetings and
7 that sort of thing.
8 And then when I came to North Carolina, I
9 didn't actually expect that I was going to be
10 staying in North Carolina, but life has its way of
11 giving you surprises, and I ended up -- I was really
12 continuing to work quite a lot in Colorado when I
13 first came here, and then the work began to
14 transition to North Carolina, South Carolina,
15 Georgia, and then Georgia has sucked up a lot of the
16 energy.
17 Q So I want to ask you about some of the
18 things that you reference. You first referenced a
19 significant project in paragraph 5 to undertake
20 administrative challenges to the lack of a secret
21 ballot in early voting statewide.
22 A Yes.
23 Q And I'm assuming the administrative
24 challenges language means that CGG's work was not a
25 lawsuit, but it was some other administrative

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1 process; is that correct?

2 A Yes, that is correct. The administrative
3 challenges took the form of informal complaints to,
4 for example, the Charlotte-Mecklenburg Election
5 Board, and as I recall then taking it further to I
6 believe -- I took that one to the North Carolina
7 State Board of Elections, and I believe that the
8 secret ballot was included in a what's called here
9 in North Carolina an election protest, and that's
10 what we mean by administrative challenges.
11 Q The second paragraph -- the second
12 sentence, I'm sorry, of paragraph 5 references a
13 challenge to Charlotte-Mecklenburg County's failure
14 to conduct a required post-election audit on the
15 2016 presidential election.
16 Do you see that?
17 A I do.
18 Q Was that a lawsuit or was it some other
19 challenge?
20 A No, it's called an election protest, and
21 you first protest a complaint or a violation with
22 your County Board of Elections, and then it's got an
23 escalation -- "it" meaning the North Carolina
24 procedures have an escalation to the State Board of
25 Elections, and -- where you bring a protest to them,

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1 and then those are kind of typically the two stages

2 that you would have before it would actually turn to
3 an election contest or litigation.
4 Q In paragraph 6 we reach the state of
5 Georgia in early 2017. Do you see that language?
6 A I do, yes.
7 Q And so at the end of that paragraph you
8 state that you began to redirect resources and time
9 to focus on Georgia's election security issues; do
10 you see that?
11 A I actually don't see that.
12 Q Right here.
13 A Yes, I do. Sorry.
14 Q So when you say you began to redirect
15 resources and time, was the Coalition doing that, or
16 were you personally doing that?
17 A Well, both because I was certainly talking
18 to my directors about that at the time, and they
19 were very supportive of -- as much as they wanted to
20 continue the projects in Colorado, there was --
21 among people who follow election security work
22 nationally who are kind of in the subject matter
23 experts and actual experts, there is just a strong
24 understanding that Georgia has the weakest election
25 security in the nation.

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1 And I resisted -- I totally resisted this

2 idea of diving into Georgia for a long time and just
3 got so many requests after the 2016 election that I
4 spend -- spend resources there that it was with the
5 approval of the board, which was smaller than it is
6 now, but it was with the approval of the board and
7 other friends that I had in Georgia from the time
8 that I lived in Georgia that urged me to redirect
9 resources to Georgia.
10 Q And those resources that you redirected
11 were being used in North Carolina, or were they
12 being used somewhere else?
13 A Well, we were wrapping up some projects in
14 Colorado as I recall, and in -- many of these things
15 would have been not necessarily heavy financial
16 resources, but instead my time.
17 Both my father and my mother had just
18 passed about this time, and so there were just lots
19 of demands on my time and changes that were going
20 on, and we were not -- as I recall we were not
21 involved in any type of litigation at that point.
22 Q Were the Colorado projects -- and I'm
23 sorry about the loss of your parents around that
24 time. Were the Colorado projects that you were
25 wrapping up litigation oriented, or were they some

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1 other work?
2 A I think we had already wrapped up our last
3 litigation. I think we may have been exploring -- I
4 think we might have been looking at the --
5 Colorado's process of selecting a new voting
6 equipment vendor as one of the things that I believe
7 we were working on about that time.
8 Q Let me move to paragraph 7. You start
9 outlining CGG's first efforts in Georgia there. Do
10 you see that?
11 A I do.
12 Q And so the first thing you reference is a
13 petition for reexamination of the DRE voting system;
14 is that right?
16 Q And then a lawsuit seeking to remove DREs
17 from use in the Ossoff/Handel Congressional District
18 6 runoff, correct?
19 A Correct.
20 Q Then you reference the Curling lawsuit in
21 July 2017. You see that?
22 A Yes.
23 Q Now, what I want to understand from kind
24 of CGG's activities in Georgia specifically is the
25 Curling lawsuit and the lawsuits that you reference

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1 in paragraph 8, are those all of CGG's activities in

2 Georgia, or are there other activities CGG
3 undertakes unrelated to litigation in Georgia?
4 A Oh, my goodness, of course. Excuse me.
5 MR. MCGUIRE: Marilyn, just give me time
6 to object to form.
7 THE WITNESS: Sorry, didn't hear you.
9 You can answer.
10 BY MR. TYSON:
11 Q You can answer.
12 A What I was referencing in 7 and 8 with
13 respect to lawsuits was certainly not all of our
14 election-related activities.
15 It was -- those appear to be trying to lay
16 out what we did on the litigation front, but
17 certainly we are always trying to involve ourselves
18 in other types of education, helping voters,
19 administrative issues many times around things like
20 open meetings, open records with respect to county
21 election administration or state at times but that
22 do not necessarily turn into or haven't -- vast
23 majority of that stuff is not litigation related.
24 Q And were those types of non-litigation
25 projects underway beginning in 2017 in Georgia?

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1 A As opposed to 2016?
2 Q Just --
4 Q I'm sorry.
5 A Are you saying were those things happening
6 in 2017?
7 Q Yeah. What I'm trying to understand --
8 let me be more specific here. So in paragraph 6 you
9 reference that in early '17 group started to expand
10 to Georgia, then you say the Coalition's first
11 efforts in 2017 were petitioning Secretary Kemp for
12 a reexamination.
13 My question is: Were -- was CGG engaged
14 in non-litigation efforts in Georgia in 2017 during
15 the period you're referring in paragraphs 6 and 7?
16 A Can you go back to 6 for a moment?
17 Q Certainly.
18 A Yes. And when I stated in my declaration
19 there first efforts in Georgia in 2017, I guess I
20 should have said more like first public efforts.
21 Certainly that wasn't the first thing we did in
22 Georgia. We made ourselves familiar with the
23 problems of the DRE machines, some of the complaints
24 that people were having about votes being flipped on
25 touchscreens and that sort of thing.

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1 So this would have been the first kind of

2 major public outcropping of the work that we had
3 been doing, but -- and particularly as we had been
4 watching that 6th congressional district planning
5 and the race take place and watched the election
6 administration process there, that was about the
7 time we really began to focus on Georgia.
8 Q Just so --
9 A Excuse me. I'm sorry.
10 Q Go ahead.
11 A I remember having talks with both
12 Republicans and Democrats in Georgia early on about
13 poll watching and how to get more poll watchers for
14 that April and June election in 2017, and I remember
15 how it seemed that poll watching wasn't a very
16 organized activity in Georgia, and we spent a good
17 bit of time, I remember having many conference calls
18 about whether or not candidates and the parties even
19 wanted to do poll watching, and that very much
20 surprised me.
21 So I remember spending a lot of time
22 talking about transparency and citizen oversight in
23 early 2017.
24 Q Thank you.
25 And just again so I understand the

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1 sequence, you said you had to redirect resources to

2 Georgia from the projects that you were wrapping up
3 in Colorado; is that right?
4 A Well, I was -- I was also working on
5 projects in North Carolina at that time that began
6 in 2015 and 2016. Excuse me, began in 2015, and
7 there were others that began in 2016.
8 So I would say that we're kind of
9 transitioning during that period from less emphasis
10 in Colorado, more in North Carolina. South Carolina
11 was -- some people in South Carolina were asking me
12 to help them with some things, spent some time in
13 South Carolina as well during this time period.
14 Q Are there projects from Colorado, North
15 Carolina, and South Carolina that you started but
16 were not able to complete because you redirected
17 resources to Georgia?
18 A Yes. We lost momentum on the voting
19 system implementation in Colorado in terms of we had
20 been pretty active in terms of citizens' input as
21 the counties were selecting their voting system, and
22 as I came here to North Carolina and kind of
23 spreading resources too thin, we lost -- and I
24 wasn't able to go to the meetings in person. This
25 was kind of before the days of frequent Zoom

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1 meetings and that sort of thing, and I was not in a

2 place that I could run to Denver and testify, and
3 then both of our other board members don't live
4 right there in Denver and easy to get to, so we did
5 not continue the level of participation we had had
6 in the projects for voting system implementation and
7 deployment in Colorado.
8 And then when I came to North Carolina one
9 of the first things that I worked on was the
10 violation of secret ballot for early voting where
11 all of the early voting, whether it was on the DREs
12 or on absentee by mail ballots has an identifiable
13 number on it, which, of course, violates the North
14 Carolina Constitution.
15 So I spent time challenging both my
16 current election board in Charlotte-Mecklenburg as
17 well as the State Election Board on that.
18 Our intention was to do a big education
19 campaign, to do lobbying with North Carolina
20 legislators, and to file administrative challenges
21 and hope that we did not have to file litigation,
22 but that effort really did not continue. I've still
23 got it on the back burner. We haven't solved the
24 problem in North Carolina, and I am committed to
25 getting back to that issue at the first opportunity.

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1 Q So let me ask you about in paragraph 8 you

2 reference some other lawsuits CGG has organized.
3 First one challenging the excess rejection of
4 absentee ballots in 2018, does that refer to the
5 Martin case filed against the State and Gwinnett
6 County?
7 A It does.
8 Q And you referenced COVID-related voting
9 infrastructure improvements in 2020. Is that the
10 lawsuit that CGG filed that was before Judge Batten
11 in the 2020 elections?
13 Q And you reference an election contest in
14 2018. Was that the contest of the lieutenant
15 governor's race in the 2018 election?
16 A Yes, it was.
17 Q So in paragraph 9 you then say: The
18 unpredicted complexity and protracted time
19 requirements and expenses of this litigation has
20 required CGG to consistently redirect resources of
21 funding and management and volunteer time away from
22 other desired projects that are of great interest to
23 our board members, members, and donors.
24 Do you see that?
25 A I do.

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1 Q And so is it fair to say that the

2 litigation that CGG is involved with is what has
3 caused this redirection of resources?
4 MR. MCGUIRE: Objection to form.
5 You can answer.
6 A It is one of the things that has caused
7 the redirection of resources, but, you know, there
8 are a lot of activities that we are engaged in that
9 relate to the Dominion Voting System, including the
10 BMD component. We were engaged in a lot of
11 activities that are not directed to the litigation
12 support but are directed to education, member
13 communications, talking to county officials, et
14 cetera, related to the Dominion Voting System and
15 audits -- the inadequacy of audits that are, if you
16 will, parallel to the litigation support resources
17 that are required.
18 BY MR. TYSON:
19 Q So in that list you were just beginning
20 of -- one of the other things I heard you say you
21 talked to county election officials, you engage in
22 member education.
23 Can you give me a complete list of the
24 other things that CGG is redirecting resources to
25 and taking away from the desired projects that are

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1 of great interest to its board members, members, and

2 donors?
4 A I am sure that I cannot give you a
5 complete list.
6 BY MR. TYSON:
7 Q Can you give me general categories of
8 activities?
9 A I can. I can. And you're asking me about
10 activities that we are -- in fact -- in fact, do you
11 mind asking the question again so I have it exactly
12 right?
13 Q Certainly. You testified that the
14 litigation was one of the activities that required
15 CGG to redirect resources of funding and management
16 and volunteer time away from desired projects. What
17 are other categories of activities that require CGG
18 to redirect resources?
19 A Okay. And we are talking about other
20 types of activities that are redirecting resources,
21 but those activities are -- and I'm asking really
22 here -- those activities are because of and focused
23 on Dominion -- Georgia Dominion Voting System and
24 BMD component, is that -- okay.
25 Q Yes.

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1 A So, yes, it would be things like our

2 communications with election officials at the county
3 level on issues like, you know, ballot secrecy, our
4 concerns for ballot secrecy and what the counties
5 should be doing about that.
6 It is obviously -- I think we mentioned
7 before talking with members, talking with also,
8 quite frankly, political parties and candidates
9 about the implications of things like ballot secrecy
10 or poll watching.
11 I've spent a good bit of time talking with
12 candidates, political parties, would-be poll
13 watchers about issues around trying to be a poll
14 watcher with the problem -- with the threats of
15 SB202 of trying to make sure that you are not
16 charged with accidentally or -- when you -- if you
17 accidentally see the screen, you know, how can you
18 try to protect yourself from being claimed to have
19 been looking at the screen.
20 So in talking with potential poll
21 watchers, voters, election officials about the
22 problems with machine setup for ballot secrecy, that
23 would be an example.
24 We've also done things like webinar
25 education directed to election officials at the

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1 county level but welcome to the public. We've also

2 done some -- I was going to say seminar for press,
3 but I actually think that was on a different topic,
4 but the -- we are frequently answering questions
5 from voters on do -- what do you recommend? How do
6 we vote? Should we really trust mail ballots?
7 Should we vote on the machines? That is a diversion
8 of resources that we would just as soon not have to
9 deal with. We don't want -- really want to be
10 having to spend our time on those kind of voter
11 education questions.
12 Let's see what else we have done.
13 Certainly we have sent many communications on the
14 subjects related to the Dominion Voting System.
15 We have been involved in analysis of
16 problems of things like double and triple counting
17 that happened in the election not only for purposes
18 of the litigation, but also for purposes of helping
19 take -- helping some of our members and other
20 citizens take complaints to their county election
21 boards that votes were double and triple counted,
22 and they are trying to talk to their boards about
23 what can be done to avoid these kind of problems in
24 the future. So we have been supporting those kinds
25 of efforts.

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1 I'm sure there are other activities that

2 are just not coming to the top of my head at the
3 moment, but in general the Dominion Voting System
4 and its lack of controls has caused us to have to
5 spend a lot of time on Georgia problems that we
6 would just as soon not spend.
7 Another thing that I'm thinking about
8 that -- we have gotten a lot of questions on the
9 so-called RLA and the problems with the counting of
10 the votes in the audit, and we have answered so many
11 members' questions about the -- how that audit was
12 put together, what the problems are, how they should
13 be talking to their election officials of their
14 counties about doing voluntary audits.
15 We helped some members in Cobb County and
16 other voters in Cobb County initiate better audit
17 and a voluntary audit for municipal -- a runoff
18 election recently, and it was particularly geared
19 toward let's make sure there is no double and triple
20 counting as we saw in the -- as we saw at the
21 November 2020 election.
22 Q Thank you.
23 So in the categories that you mentioned
24 here, let me just kind of break down a few of them.
25 So you talk about communications with election

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1 officials that you have, county election officials?

2 A Yes.
3 Q And those communications are advocating
4 for things the Coalition thinks are good ideas in
5 election administration, right?
6 A Or -- yes, or answering questions, yes,
7 absolutely.
8 Q And the communications with parties and
9 candidates, those are also advocating for what the
10 Coalition believes are best practices in the
11 administration of elections, correct?
12 A That would -- that would be part of the
13 communications, yes. We certainly get a lot of
14 questions about election administration that don't
15 necessarily have to do with advocacy.
16 Q What kinds of questions about election
17 administration do you get that don't have to do with
18 advocacy?
19 A People wanting us to explain things like
20 what are the recount rules; when do I get a recount;
21 when do -- when would I have to go to court to get a
22 recount. That would be an example.
23 So it's just -- you know, we certainly
24 don't hold ourselves out to be election attorneys,
25 but we can try to point people in the right

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1 direction.
2 Q Let me move to paragraph 10. You
3 reference that you've had to reduce your active
4 involvement in several important efforts that CGG
5 supports because of the time demands of this
6 litigation.
7 Do you see that statement?
8 A I do.
9 Q And then you go on the rest to say CGG has
10 had to curtail and decline numerous
11 organizational -- organization activities.
12 You see that?
13 A Uh-huh. I'm sorry, yes.
14 Q And then continuing, you list a variety of
15 different projects, and we're not going to go
16 through all of them just for the sake of time, but
17 there's at least some projects in North Carolina
18 that you referenced, correct?
19 A Yes.
20 Q And --
21 A And some of these are now out of date, and
22 others would be added.
23 Q Okay. And some efforts of the New York
24 State Board of Elections, correct?
25 A Yes.

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1 Q And some in Colorado?

2 A Yes.
3 Q I know you referenced that this is --
4 paragraph 10 is not a complete list of the projects
5 that the Coalition is unable to engage in, but it's
6 at least a substantial list of the projects
7 Coalition wouldn't be able to engage in?
8 A It is a list. You know, as I said, this
9 is now a year out of date, and some of these issues
10 have been resolved positively and negatively without
11 our --the level of involvement we wish, and at least
12 as many more have been added where we have either
13 done a minimal amount of what we were asked to do
14 that we would have been -- excuse me, we would have
15 preferred to do or we would have declined all
16 together to participate in things that we would like
17 to be involved in. I mean, I have a long list just
18 from this week.
19 Q If CGG was not involved in the Curling
20 case, could it engage in all the activities that are
21 listed in paragraph 10?
22 A Well, some of them are no longer alive,
23 but we could have engaged more meaningfully in those
24 things, yes.
25 Q When you say "could have engaged more

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1 meaningfully" --
2 A Okay, let me take an example.
3 Q Okay.
4 A We had Colorado members in Boulder who
5 asked us to testify by Zoom, to write letters, to
6 call city council members on instant runoff voting.
7 And I was kind of a well-known figure, that's
8 putting it nicely, in Colorado as an opponent of
9 instant runoff voting.
10 The mayor of Aspen race that I told you
11 about when we started talking this morning was done
12 by instant runoff voting, and it kind of went off
13 the rails, and after that, the City of Aspen chose
14 never to use instant runoff voting again.
15 But so -- because of my kind of deep
16 knowledge of what was wrong with instant runoff
17 voting, I was asked to take a very active role in
18 helping our members out there fight Boulder's
19 decision to use instant runoff voting. I could only
20 do a minimal amount of work, and I think I might
21 have made one phone call versus testifying, sending
22 letters, et cetera.
23 Q That inability to fully engage on that
24 particular topic was due --
25 A Yes.

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1 Q -- to the demands of the Curling case on

2 you, correct?
3 A Both the Curling case and the other
4 related activities on Dominion BMD system that were
5 not necessarily litigation.
6 Q And you mentioned your RLA work with Cobb
7 County was to help avoid double counting; is that
8 correct?
9 A I didn't mean to say risk-limiting audit
10 if I did say risk -- I meant to say post-election
11 audit if I -- and I was talking with some of our
12 members and other active voters in Cobb County, and
13 I urged them to ask for a tabulation audit after the
14 runoff in a municipal -- I believe it was Marietta
15 municipal election, and I helped them create their
16 ask, and it was partly to make sure that double
17 counting did not take place as it had in Cobb County
18 in the Baker 01 precinct in November 2020.
19 Q And so your role in that was not to work
20 with the county election officials, but to provide
21 information to individuals who wanted to work with
22 those election officials; is that correct?
23 A Yes, yes, I provided them with support,
24 ideas, kind of the how-tos.
25 Q And those were members and non-members,

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1 correct?
2 A Yes. It was some people who probably
3 considered themselves members, but, you know, wasn't
4 in some kind of formal member context.
5 Q Let me ask you, if the Coalition received
6 an injunction banning the use of Dominion BMDs, will
7 the Coalition continue to educate its members and
8 educate the voting public?
9 A Can you be more specific? Are you
10 limiting -- like, an injunction just about the BMDs?
11 Do you mind rephrasing the question? It's confusing
12 to me.
13 Q Certainly. So my question is specifically
14 if the Coalition was to receive an injunction
15 banning just the ballot marking devices, would the
16 Coalition continue to educate its members and the
17 voting public?
18 A Regardless of whether or not we receive an
19 injunction about just the BMDs, we will, as long as
20 we're in existence, continue to educate members and
21 voting public about election issues.
22 Q And that's true if CGG received all the
23 relief that it's seeking in this -- in the Curling
24 case, so you win on everything, CGG would continue
25 to educate members and the voting public, right?

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1 A On -- it is one of our missions. It may

2 not be about the issues of BMDs or the other relief,
3 but we're not going to go out of business if we got
4 all the relief we're looking for. We would -- we
5 would always be working on educating members,
6 non-members on -- I don't expect all election issues
7 to go away if we got all the relief we're looking
8 for. It would give us much more ability to focus on
9 a broader range of topics at a more local level,
10 which is really where we would prefer to work.
11 Q So next I want to kind of move to
12 categories of resources under this topic to really
13 kind of dig in on. I know we've talked about
14 financial resources that were diverted. What are
15 the other resources that CGG does not have -- sorry,
16 let me start over that again.
17 What are the non-financial resources that
18 CGG has had to divert as a result of the actions
19 it's challenging in this lawsuit?
20 A It's going to be primarily people's time
21 and -- volunteer time and as well as paid time like
22 our interns' pay and -- well, so much goes back to
23 financial resources.
24 For example, we'd get rid of our Logikcull
25 account. Do you know what I mean by our Logikcull

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1 account?
2 Q Uh-huh.
3 A We'd get rid of that, free up financial
4 resources. I doubt we would be needing that
5 account, for example. But, you know, it's primarily
6 the hundreds of hours every week that gets spent by
7 our team.
8 Q And does CGG track the hundreds of hours
9 spent every week by your team?
10 A Only for paid interns.
11 Q So in terms of volunteer time, there
12 aren't documents that reflect what time volunteers
13 are devoting to particular activities, right?
14 A Generally not.
15 Q Okay. You say "generally not." Is there
16 any -- is there any document that would reflect the
17 amount of time volunteers were devoting to
18 particular activities?
19 A You know, I have kind of vague
20 recollections of asking some of our volunteers in
21 the last year, hey, keep track of how many hours you
22 spend on that because at some point I'd like to know
23 just how heavily invested we are, but if you ask me
24 exactly what that was, I don't remember.
25 It might have been looking at confirming

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1 some of the double- and triple-counted ballots. I

2 think I might have asked somebody to just kind of
3 keep track of your hours as you're doing that
4 because I want to know -- because we've spent
5 hundreds of hours on that issue. But it wasn't a
6 formal time sheet kind of thing like the interns
7 have to do.
8 Q So for volunteer staff, again, I know you
9 said there was some projects maybe where that was
10 the case, but you can't say it was this number of
11 hours that we would not have spent on a particular
12 project, correct?
13 A Not in total. Certainly not. We could --
14 if required we could certainly come up with
15 estimates of the hundreds of thousands of hours
16 we've spent. Not hundreds of thousands. I didn't
17 mean to say -- I didn't mean to slur my words that
18 way. Hundreds or thousands of hours we have spent
19 on these projects, but no, any kind of formal
20 records, that we don't have.
21 Q And so would the Coalition's volunteers
22 take all the time that they are devoting to, say,
23 the double- and triple-counting issue that you just
24 referenced, would they devote all that time to other
25 educational activities if the Dominion system was no

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1 longer in use?
2 A Well, I certainly cannot speak for exactly
3 how they would use their own choice of volunteer
4 time, but their full indications to me are, damn, I
5 wish I could work on the improvement of the website;
6 I would like to be out re-communicating with all of
7 those people who signed our petition for
8 reexamination.
9 They've told me other things they would
10 prefer to be doing, so I assume that they would do
11 them, but I cannot commit to you that they would
12 spend exactly X number of hours doing that should
13 the opportunity take place. They've indicated that
14 there are things that they would prefer to be
15 working on instead.
16 Q Is it correct that all of those other
17 activities they would be working on would still
18 relate to the administration of elections?
19 A No, not necessarily because one of the --
20 one of the core issues that we really want to work
21 on and we've done very little on is open meetings
22 both in Colorado -- Colorado, North Carolina, and
23 Georgia, and we have a lot of things that we would
24 like to do to begin to challenge the many violations
25 of open meeting laws in Georgia and North Carolina

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1 at a local level, either municipal or county level.

2 And so I expect that we would be spending
3 a lot of time on that should -- if we were not
4 focused on the Dominion system issues.
5 Q Has Coalition been involved in open
6 meetings issues at any point in its history?
7 A Yes, in our predecessor organization we
8 have back in Colorado, and I believe -- I have vague
9 recollection of making some challenges in South
10 Carolina, although I believe it was done in a -- in
11 an oral challenge in North Carolina. I don't know
12 that I can come up with the specifics for you on
13 that, but, yes, open meetings have long, long been
14 an interest, something we have been involved in.
15 We have not -- we have not done any
16 litigation on them, but we have threatened
17 litigation and been able to resolve some open
18 meetings issues back in Colorado by threatening
19 litigation after all administrative efforts were
20 kind of exhausted, but generally I don't believe
21 we've done any litigation on that.
22 Q Do you have an estimate of how much of the
23 volunteers' time that is currently being utilized by
24 the Coalition is devoted to this particular case,
25 the Curling case?

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1 A I have two questions about your question.

2 Are you asking me how much of their seven days a
3 week is devoted to the case itself as opposed to
4 other CGG activities or --
5 Q I'm not. Let me ask the question a
6 different way.
7 A All right.
8 Q So in terms of the activities that the
9 volunteers are engaged in as part of their work as
10 volunteers for CGG, do you have an estimate of the
11 percentage of that time that is devoted to the
12 Curling case?
13 A This is just going to be a wild guess.
14 I'm going to say that probably 50 percent of it
15 would be related to the case. Probably 30 percent
16 of it would be related to other Dominion Voting
17 System and audit issues that are not in direct
18 support of the litigation, and the remainder on
19 other types of election administration activities.
20 For example, as you probably know we often
21 go to -- haven't had a chance to do this recently --
22 State Election Board with proposed rules about
23 election administration. Some of them would be BMD
24 related; many of them would not.
25 We didn't make it yesterday. We had plans

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1 to promote some rules that we wish they would

2 promulgate having to do with canvassing, and we
3 didn't get them pulled together in time to submit to
4 the board.
5 Q So just kind of fleshing out a little bit,
6 so the kind of 20 percent of other types of
7 election-related activities, is that focused
8 primarily on advocacy for things the Coalition would
9 like to see in Georgia elections?
10 A That would be -- yes, that would -- it
11 would be primarily that or answering questions.
12 Our members tell me that they're hearing a
13 lot from candidates right now with questions about
14 everything from how to -- how do the BMDs really
15 work; can I really count on them; what should I have
16 for poll watchers.
17 So there's -- you know, do you consider
18 that a real formal education program, no, but we're
19 kind of here to try to answer questions that have to
20 do with the BMD system, the Dominion system, and
21 other related election activities. A lot -- we get
22 a lot of questions about poll watchers.
23 Oh, the other thing that we are working on
24 that we are getting a lot of questions about right
25 now is House Bill 1464 which includes ballots as

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1 public records which we initiate -- we helped

2 initiate that. And then there are, I'm sure you
3 probably know, security chain of custody issues in
4 that bill as well as poll watcher regulations in
5 that bill, and we've been getting a lot and fielding
6 a lot of questions about that and been asked to
7 prepare some amendments.
8 So that -- and you can't really divide it
9 up into exactly where does that cross over into BMD,
10 how much percentage of time did you spend talking
11 about the BMD portion versus more generally poll
12 watchers.
13 Q Thank you. That's helpful.
14 I'm going to move next to the 990s. Is
15 this a -- do you want to take a break at this point,
16 Ms. Marks, or anybody?
17 A I'm fine. Up to you guys.
18 MR. TYSON: Rob, are you good?
19 MR. MCGUIRE: It might be good to take a
20 break if you think you're going to go for a while.
21 MR. TYSON: Yeah, it is going to be a
22 little while on the 990s, so take 5, 10 minutes?
23 MR. MCGUIRE: Yeah, can we, please?
24 MR. TYSON: Yeah, how long you want?
25 MR. MCGUIRE: Five is fine.

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1 MR. TYSON: Let's do five minutes.

4 (Recess 1:20-1:30 p.m.)
7 BY MR. TYSON:
8 Q Thank you, Ms. Marks.
9 So what I wanted to do next was continuing
10 on topic 1 and work through the 990s. I know you
11 referenced you looked at those in preparation, and I
12 had some questions about them as well.
13 So just to get us started in your Exhibit
14 Share as Exhibit 6. You should have the 2017 990-EZ
15 filed by Coalition.
17 identification.)
18 BY MR. TYSON:
19 Q Do you see that?
20 A I do.
21 Q And the Coalition is a 501(c)(3)
22 organization, right?
24 Q It filed a Form 990 for each year; is that
25 right?

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1 A That is correct. I don't think we have

2 completed it for 2021.
3 Q But the Coalition has filed a 990 for
4 2020, correct?
5 A Yes.
6 Q So what I want to do just kind of walk
7 through a few questions on each of these 990s, and,
8 I guess, can you kind of summarize in your own
9 words -- let me ask this: Are you involved in
10 preparation of the 990s for the Coalition for Good
11 Governance?
12 A No, not in the preparation of them.
13 Q Are you involved in the review of them
14 before they're filed?
15 A I do a very high-level review, and
16 particularly sometimes as it relates to talking
17 about our progress on projects, but our CPAs really
18 prepare the details of the -- of the 990.
19 Q And when you said earlier you reviewed the
20 990s to get ready for topic number 1, why were the
21 990s documents that you reviewed for this topic?
22 A Oh, just a moment. My screen went out.
23 Hold on. Okay.
24 I reviewed the 990s for, I believe, the
25 question about what the total expenditures were,

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1 which I believe is a different topic on down the

2 line, number 8.
3 Q Okay. Well, let me ask, so we're still,
4 obviously, on topic 1 working through --
5 A Okay.
6 Q -- the diversion of resources, so I wanted
7 to ask a few questions about this.
8 So, first of all, if you go to page 2,
9 part 3, the statement of program service
10 accomplishments, do you see that?
11 A Uh-huh.
12 Q And there's then three lines, 28, 29, 30,
13 and 31, and then a total in number 32. Do you see
14 that?
15 A I do.
16 Q And so the Coalition listed program
17 service accomplishments in lines 28, 29, and 30 but
18 didn't list anything for other program services on
19 line 31, correct?
21 Q So this gets a little confusing because
22 line 28 references attachment 5, so I'm going to
23 move down to the attachment 5, and then you see it
24 says on page 14 program service accomplishment 1?
25 A Yes, I do see that.

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1 Q And the statement there is: Advocating

2 for voters' rights to a verifiable election, CGG
3 litigated in federal court Northern District of
4 Georgia against Georgia's use of an unverifiable
5 paperless touchscreen system and educated Georgia
6 voters on the importance of using an election system
7 that either includes paper ballots or creates a
8 paper trail.
9 Do you see that?
10 A I do.
11 Q Is that program service accomplishment
12 referring to the Curling case?
13 A That particular one is referring to the
14 Curling case.
15 Q And program service accomplishment 2
16 there, attachment 6, statement that is: Worked to
17 educate voters on the importance of election
18 security using the example of the Georgia special
19 election CD6 and the exposing vulnerability of the
20 KSU Center for Election Systems, Georgia was one
21 state identified by the NSA where voter registration
22 systems were compromised and vulnerable to hacking.
23 Do you see that?
24 A I do.
25 Q Is that program service accomplishment

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1 also referring to the Curling case?

2 A Well, the Curling case is one of the
3 things that would have been encompassed by that
4 statement.
5 Q Okay. Let me go -- ask about line 30
6 then. The third program service accomplishment is:
7 Supported rights of all citizens to access election
8 records; paid for voting systems computer experts to
9 identify and testify on security lapses in the
10 Georgia elections system.
11 Do you see that?
12 A I do.
13 Q And that line -- is that line also
14 referring to the Curling case?
15 A I believe that that was probably referring
16 to what we call -- and, Mr. Tyson, I did not try to
17 go delve into exactly which action this would have
18 been, so I'm telling you to the best of my
19 recollection, which could be wrong here, but --
20 without checking with accountants, but what I
21 believe that may be referring to is what we call
22 Curling 1 that was an action we filed in May of
23 2017, I believe it was May of 2017, in Fulton
24 Superior Court.
25 Q Was that lawsuit also challenging the use

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1 of touchscreen voting systems?

2 A It was.
3 Q So let me ask you on the questions here in
4 part 4, there's a question here about section
5 501(c)(3) organizations only and asking if the --
6 line 47, did the organization engage in lobbying
7 activities or have a section 501(h) election in
8 effect during the tax year, and the box is checked
9 for no. Do you see that?
10 A I do.
11 Q Has CGG -- well, let me ask first: Did
12 CGG advocate for the passage or defeat of any
13 legislation of the Georgia General Assembly in 2017?
14 A I don't believe so.
15 Q Do you know if CGG has ever advocated for
16 the defeat or passage of legislation in the Georgia
17 General Assembly?
18 A We have, yes. A minimal amount of our
19 resources are devoted to that, but we have.
20 Q Let me mark the next 990 here. I want to
21 look next at 2018.
23 identification.)
24 BY MR. TYSON:
25 Q I've marked as Exhibit Number 7 the 2018

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1 990. You see that?

2 A I do.
3 Q So I first want to go to again looking at
4 the program service accomplishments, line number 2
5 says, did the organization undertake any significant
6 program services during the year which were not
7 listed on the prior Form 990 or 990-EZ, and the box
8 is checked as no. Do you see that?
9 A I do.
10 Q And the next line indicates, did the
11 organization cease conducting or make significant
12 changes in how it conducts any program services, and
13 the box is checked no, correct?
14 A Correct.
15 Q Is it correct to say that CGG was engaged
16 in the same activities in 2018 as it was in 2017?
17 A Generally, yes, and I -- I think we would
18 look back to part 3, item 1 up there above your
19 cursor that generally our activities have remained
20 under that umbrella, but, of course, every single
21 day there's something slightly different about our
22 activities from the prior day.
23 Q Certainly.
24 So I want to then look -- you have in
25 lines -- line 4 asks again for program service

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1 accomplishments, and all three, 4A, 4B, and 4C all

2 say, see additional data. Do you see that?
3 A I do.
4 Q Let me just to expedite the process here
5 go down to page -- right here, additional data is
6 listed at the top of page 12, I believe it is, and
7 if you could just read through 4A, 4B and 4 -- 4A
8 and 4B, I'm sorry, do both of those items refer to
9 the Curling case?
10 A Do you want me to read them aloud?
11 Q Or you can just read them -- review them.
12 A Okay. All right. Just a moment.
13 So item 4A, part of that is the Curling
14 litigation, but also the education part would not be
15 litigation. It's still related to touchscreen
16 voting systems, but I thought your question was
17 asking me if this was referencing the Curling
18 litigation, and I'm saying in part it is.
19 Q Okay.
20 A And line 4B, that looks to be the election
21 contest related to lieutenant governor in 2018. Is
22 that '18? Yes. And then there would have been a
23 lot of voter education that was parallel to that
24 issue, not necessarily part of that litigation.
25 Q Both 4A and 4B relate to the use of

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1 touchscreen voting systems, correct?

2 A Yes.
3 Q Okay. And in 4A, at the end of that you
4 indicate, educating Georgia voters on the importance
5 of using an election system that includes either
6 paper ballots or creates a paper trail.
7 Doesn't Georgia's Dominion system fall
8 within that category?
9 A We certainly should have said something
10 like an auditable paper trail, but it would not --
11 it does not fall in the category of what was
12 intended to mean a verifiable paper ballot.
13 Q And then 4C references a challenge to
14 discriminatory policies on absentee ballots. Is
15 this referencing the Martin case that we discussed
16 earlier?
17 A It is referencing the Martin case, and it
18 is also referencing the type of work that we did
19 prior to that for both education and trying to get
20 others to make the challenge instead of us and
21 research around the issue.
22 So yes, it is a litigation and other
23 things that were related to, in particular,
24 Gwinnett's method of rejecting mail ballots.
25 Q And so it's correct then that each of the

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1 program service accomplishments listed on this 990

2 are, at least in part, litigation, correct?
3 A Yes, in part, that is true.
4 Q Let me take us back up to page 9. I'll
5 try to zoom this in a little bit. It'll be easier
6 to see.
7 So on part 8, Statement of Revenue, do you
8 see this language?
9 A I do.
10 Q And so there's various categories of
11 things -- of ways that money comes to the
12 organization, and there's no amount indicated for
13 membership dues, right?
14 A Correct.
15 Q And the only line item for revenue is all
16 other contributions, gifts, grants, and similar
17 amounts, right?
18 A Sadly so.
19 Q Then looking at page 10, part 9, Statement
20 of Functional Expenses, column A is Total Expenses,
21 column B is Program Service Expenses, and I wanted
22 to ask first why in 11B for legal you have $189,792
23 and all of that is part of the Program Service
24 Expenses, correct?
25 A Uh-huh. Yes.

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1 Q Would all of those legal payments be

2 related to either the Curling case or the Martin
3 case?
4 A No.
5 Q What other legal expenses would have been
6 covered in this period?
7 A I think that there were some legal
8 expenses related to getting Mr. McGuire's help in
9 North Carolina looking at some of the ballot secrecy
10 and some of the voting system security issues there.
11 And then did you actually say the lieutenant
12 governor case as you were mentioning what these
13 legal fees related to and legal services?
14 Q Apologize, I did not. And that's correct,
15 that was also in 2018.
16 A And there may have been some other
17 miscellaneous legal expenses, but I'm not
18 remembering them right now. I looked at total
19 expenditures in my preparation for this deposition.
20 I did not try to look at detailed expenditures by
21 category.
22 Q Certainly. Okay. Well, that's helpful.
23 On this form, though, the total program
24 service expenses versus management and general
25 expenses we have $189,792 for program services and

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1 $3,289 for kind of general and management services;

2 is that right?
3 A Yes, I think so.
4 Q Let me ask one more question about this
5 one. Going to schedule A, part 2 that shows
6 contributions over time.
7 A Yes.
8 Q It looks like 2016 there were no
9 contributions to the organization; is that right?
10 A That is what this form says. Do I
11 remember, you know, whether or not that's -- I
12 assume it's accurate.
13 Q Okay. And 2017 was the first six-figure
14 year of contributions to CGG, right, based on this
15 form I should say, based on --
16 A Based on this, yes, because there was a
17 six-figure year, which I thought was 2014. Maybe it
18 was 2013. But, yeah, on this form, 2017 was the
19 first year that there was a six-figure amount.
20 Q And CGG raised more money in 2018 than it
21 did in 2017, right?
23 Q Let's take a look at 2019.
25 identification.)

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1 BY MR. TYSON:
2 Q I've marked as Exhibit 8 the 2019 990. Do
3 you see that?
4 A I do.
5 Q And on this form just quickly for lines 2
6 and 3 that we discussed earlier on changes in
7 programs, the answer to both of those is no,
8 correct?
9 A Correct.
10 Q And we're back to additional data for 4A,
11 4B, and 4C, so let me get down to where that is.
12 And the way I read these three is that the program
13 services are basically the same in 2019 as they were
14 in 2020, Curling and some other activities in line
15 4A, Curling, maybe something else in 4B, and Martin
16 in 4C.
17 Can you just review those and see if that
18 is a correct statement?
19 A I will.
20 Yes, with the understanding that those are
21 three places where we spent a lot of money, but
22 certainly not all of the things that we were doing.
23 Q Let me look quickly again back to
24 statement of revenue for 2019, $365,904 through
25 contributions, gifts, grants, and similar amounts,

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1 correct?
2 A Correct.
3 Q And for program expenses, the program
4 service expenses on legal fees were $369,346,
5 correct?
6 A Correct.
7 Q And the total -- what do we call this
8 category -- management and general expenses for 2019
9 was 34,457, correct?
11 Q Do you know -- I understand that you
12 didn't look at this specific set of categories here,
13 but do you know just on a personal knowledge basis
14 whether the travel and office expense amounts were
15 related to litigation at all?
16 A I'm thinking.
17 I'm sorry, I don't know, as we sit here,
18 whether they were or not. And it may have been a
19 mix.
20 Q That's totally fine. I know you didn't
21 review that specifically so I didn't want to ask you
22 in your 30(b)(6) capacity about that.
23 A Thank you.
24 Q Let me next mark another exhibit here.
25 Can you see this is a document Notice of Filing

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1 Declaration from the Coalition for Good Governance

2 versus Raffensperger case; do you see that?
3 A Yes.
4 Q And do you recall that you provided a
5 declaration in that case about the Coalition's
6 diversion of resources in 2020?
7 A Yes.
8 Q And is this Exhibit 9 that declaration?
10 identification.)
11 A At least it's the -- it's the -- now
12 you're showing the declaration, yes.
13 BY MR. TYSON:
14 Q And that was document 42 in that case.
15 I just wanted to ask a couple of
16 questions. You indicate in paragraph 6 that: The
17 diversion of resources has continued since the
18 complaint was filed. For example, in order to meet
19 the requirements of this litigation I was forced to
20 reject the request by North Carolina-based Coalition
21 members and voting rights groups to help design and
22 plan drive-through voting options which I had
23 initiated several weeks ago.
24 Do you see that?
25 A I do.

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1 Q That's one of the items that you listed in

2 your declaration of what you were unable to do
3 because of the Curling case, right?
4 A Yes.
5 Q And whether it was the -- this particular
6 Coalition case before Judge Batten or the Curling
7 case, it was ultimately the resources demanded of
8 the lawsuits that required the rejection of that
9 particular North Carolina request, right?
10 A I would say not just the litigation
11 requirements, but the other type of ancillary
12 resource drain caused by -- in the case we're
13 talking about right here, SB202, or the use of the
14 Dominion Voting System, not all necessarily or not
15 at all, just the litigation support expenses.
16 You know, this would relate to things
17 we've already talked about, education and such other
18 activities as that that are not directly litigation
19 support.
20 Q Okay. In paragraph 8 you reference
21 another request from North Carolina members, work in
22 paragraph 9 and South Carolina, other types of the
23 thing the Coalition would have done if not for that
24 CGG case -- I'm sorry, the case before Judge Batten,
25 correct?

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1 A That's correct.
2 Q And if the Coalition was not filing the
3 Curling case or the case before Judge Batten it
4 would have additional time to spend on other
5 activities, correct?
6 A That's correct.
7 Q So let's turn to another declaration from
8 this case. Do you recall offering a declaration
9 involving the attorneys' fees that the Coalition is
10 seeking in this case?
11 A Yes, some time ago.
12 Q Okay. So this is a 342-page document, so
13 I'm --
14 A Which I didn't -- which I did not review
15 in preparation for this -- for this deposition.
16 Q And thankfully, I'm not going to ask you
17 about all 342 pages.
18 A Good.
20 identification.)
21 BY MR. TYSON:
22 Q First, let's look -- this is document 630
23 filed in October of 2019, and it's Coalition
24 Plaintiffs' Detailed Specification in Support of
25 Motion for Attorneys' Fees.

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1 Do you see that?

2 A Yes.
3 Q So I'm going to take us to page 283. Let
4 it have a chance to catch up.
5 A All right.
6 Q So this is titled Declaration of Marilyn
7 Marks.
8 Do you see that?
9 A I do.
10 Q Okay. And so in this declaration you made
11 several different comments about how the Coalition
12 goes about spending its resources, and that's what I
13 want to dig into of what's going on here.
14 First, in paragraph 9 you indicate that:
15 The Coalition receives frequent requests to assist
16 in election technology controversies across the
17 country. We decline involvement in the vast
18 majority of the requests because of the almost
19 impossible task of recruiting counsel with adequate
20 subject matter expertise. A long learning curve
21 required for counsel in voting systems litigation
22 makes most such cases impractical to pursue.
23 Do you see that?
24 A I do.
25 Q So what method, if any, does CGG use to

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1 determine which requests for assistance it rejects

2 due to the difficulty of recruiting counsel and
3 which it rejects due to the lack of resources to
4 fulfill that request?
5 A You know, I don't know that you could ever
6 parse that out in any type of objective way, you
7 know? It's -- if the expertise was readily
8 available and a lot of people had that expertise it
9 would probably be easy to recruit attorneys to serve
10 in the capacity of helping challenge election
11 technology, election technology policy
12 controversies. So I'm not sure how I would ever
13 parse that out.
14 Q And I guess what I'm trying to understand
15 is there were obviously projects you didn't engage
16 in that you've testified were due to a lack of
17 resources. Here you're indicating you don't engage
18 in some projects due to the difficulty of counsel.
19 I'm just trying to understand how you tell the
20 difference for CGG.
21 A How do we tell the difference? Let me see
22 if I can give you a recent example. We were asked
23 to get involved with the new Internet voting bill in
24 DC, and -- Washington, DC, and, you know, would we
25 consider helping litigate against that, and right

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1 now we don't even have time to write a letter, which

2 I've had to decline the ability to get involved at
3 all, and so -- because of this litigation and other
4 work we're having to do around the Dominion Voting
5 System.
6 So as we respond to a request like that,
7 how much -- how much of it is because there are not
8 free lawyers readily available versus just
9 inadequate resources of time and money, I don't know
10 that I can answer that.
11 If Rob McGuire were standing by saying,
12 hey, look, I'd really like to work pro bono on an
13 Internet voting case, you got any work for me, I'd
14 probably say, yeah, go to it. Go to DC.
15 Q That helps. Thank you.
16 Let me go to paragraph 24, and this is a
17 section entitled Coalition's Case Management
18 Strategy.
19 Do you see that?
20 A I do.
21 Q And so paragraph 24 you say: In the
22 numerous election-related lawsuits I have organized,
23 I have learned that for a small organization like
24 CGG, litigation like this is only affordable and
25 feasible if CGG provides full-time support to its

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1 attorneys.
2 A Yes.
3 Q Assisted by student -- interns paid at
4 student rates, I personally conduct research,
5 investigate facts, interview witnesses, consider
6 strategy, and provide expertise on election
7 administration and voting technology. In doing
8 these tasks, I perform a substantial amount of work
9 generally done by attorneys in similar cases, and by
10 doing so I help my attorneys minimize their own risk
11 as well as minimizing the eventual amount of fees
12 that may be shifted to losing public defendants. I
13 generally solicit my attorneys for ways I can be
14 helpful, and I operate under their guidance by
15 focusing on performing only those tasks that they
16 tell me need to be done and will save them time.
17 So you see that paragraph?
18 A I do.
19 Q Do you still agree with that statement in
20 that paragraph or the statements in that paragraph?
21 A I'm rereading.
22 Q Sure.
23 A I would say when it says performing only
24 those tasks that they told me need to be done and
25 will save time that that shouldn't be read extremely

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1 literally.
2 Q Okay.
3 A I end up doing more things than they tell
4 me that need to be done.
5 Q Okay. And so earlier we talked about that
6 you were having to spend 90 percent of your time on
7 items related to this case or more. Part of the
8 reason for that is the way that the Coalition has
9 chosen to litigate this case, correct?
11 A Can you tell me what you mean by "chosen
12 to litigate"?
13 BY MR. TYSON:
14 Q So you've titled this section Coalition's
15 Case Management Strategy, and in paragraph 24 you've
16 outlined kind of the approach that you take and your
17 interns take to help litigate the case.
18 A Right.
19 Q And my question is: The reason why you
20 were spending as much time as you are on these cases
21 is, at least in part, due to how the Coalition has
22 chosen to litigate its cases, correct?
23 A I'm not sure that I would -- I would state
24 it that way. You know, the way we would choose, all
25 other things being equal, would be for much bigger

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1 teams to be working on the things that I do, but we

2 do not have the resources and the breadth of
3 organization. It is not by choice but by just that
4 is where we are as a matter of fact. There's no one
5 else to do it, and we don't have the resources to
6 expand greatly for legal teams, research folks.
7 It's not by choice, it's just by necessity.
8 Q So, I guess in a perfect world you're
9 saying if you were able to have the attorneys do all
10 the typical attorney tasks you would have more time
11 for other projects of CGG, correct?
12 A Yes, sure.
13 Q Okay. Go down to paragraph 37 next. So,
14 again, further explaining kind of what CGG does, you
15 say in paragraph 37: CGG organizes its litigation
16 activities to be conducted at the lowest possible
17 cost to make the most efficient use of attorney
18 time. All activities that could be done by someone
19 other than very experienced senior attorneys is done
20 by CGG staff or volunteers.
21 See that, right?
22 A Yes.
23 Q And so you'd agree kind of I guess to our
24 perfect-world scenario, if CGG did not utilize its
25 staff or volunteers to conduct these litigation

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1 activities, then that staff and volunteer time could

2 be devoted to CGG's other projects, right?
3 A In a perfect world, yes.
4 Q And are you saying in paragraph 37 that
5 the reason for the loss of staff and volunteer time
6 for other CGG projects is this decision to litigate
7 at the lowest possible cost?
8 A No, not really saying that. That would
9 really not be our choice. My choice would be to
10 have the financial resources necessary to put legal
11 team, expert team, support team, research team on
12 without having budgetary constraints have to be an
13 every-minute consideration.
14 So, yes, we made this choice to litigate
15 given the constraints. It's not that we chose to
16 have, oh, let's just do this the cheapest way we
17 possibly can; it's let's do this the only way we
18 can.
19 Q Let me ask one more question about this.
20 In paragraph 49 you say: This approach to
21 economizing has permitted Coalition's attorneys to
22 be efficient and generally only engage in activities
23 requiring their technical and litigation expertise.
24 It has, however, not been without its price, for
25 these efforts have diverted significant resources of

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1 the organization, in both time and money, away from

2 other projects.
3 Do you see that?
4 A Yes.
5 Q And so you'd agree that this litigation is
6 what has caused the diversion of significant
7 resources of the organization away from other
8 projects, right?
9 A It's one of the things that has, yes.
10 Q You say that it diverted significant
11 resources of the organization, you refer to these
12 efforts have done that. Can you quantify how much
13 of the diversion was due to the efforts you
14 reference in paragraph 49 and how much is due to
15 other factors?
16 A No, I certainly don't have any kind of way
17 to measure that because it certainly required all --
18 you know, a large portion of the financial resources
19 we have, but it's hard to put quantifiable numbers
20 on the amount of volunteer time, for example, and
21 then my time that has to get devoted to
22 litigation -- this litigation effort as well as
23 other problems being caused by the Dominion Voting
24 System.
25 You know, we don't -- as I told you

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1 before, we don't keep records of the volunteer time

2 at that level, so I don't have an estimate for you.
3 Q Now, one of the things you indicated that
4 CGG was limited in doing was educating the New York
5 State Board of Elections on problems with BMDs.
6 Do you recall that?
7 A I do.
8 Q I want to have you look at what I marked
9 as Exhibit 11, document that was produced to us in
10 discovery.
12 identification.)
13 BY MR. TYSON:
14 Q Do you recall a letter sent in January
15 2021 to the New York State Board about BMDs?
16 A I recall it kind of vaguely, you know.
17 Helping me remember it a little bit as you're
18 displaying it.
19 Q And Exhibit 11 has your signature as
20 executive director?
21 A It does, uh-huh.
22 Q And in this letter you reference the
23 Coalition's involvement in the Curling case and
24 Judge Totenberg's ruling from October 2020, correct?
25 A Uh-huh. Yes.

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1 Q So being part of the Curling case helped

2 CGG's advocacy in New York, right?
3 A Helped? I don't know. We could have
4 been -- we would have been advocates for exactly the
5 same thing with or without the CGG -- excuse me, the
6 Curling case. Preferably without.
7 Q But you're using the Curling case as part
8 of your advocacy in New York, correct?
9 A Well, we're certainly referencing it as
10 other people, I believe, did as well who were not
11 part of the Curling case. It's well-followed, and
12 I'm aware of the some of the other people who
13 weighed in -- who were not associated with Coalition
14 for Good Governance who weighed in using some, I
15 believe, Judge Totenberg's order when they were --
16 when they were talking to the New York State Board
17 of Elections.
18 I do remember getting a lot of calls about
19 the efforts that were being made from around the
20 country to weigh in to the New York Board and people
21 asking for references to that order.
22 Q And you were able to engage in this effort
23 for New York despite CGG's involvement in Curling,
24 right?
25 A I wouldn't say engage. Just the letter is

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1 the extent of what we did, and I had to decline

2 several requests for testimony to be offered in the
3 case -- in that particular consideration.
4 It's one I particularly remember because I
5 felt bad about not being able to participate because
6 of the significance of this decision that they were
7 planning to make.
8 Q Do you recall testifying that there were
9 several North Carolina projects that CGG became
10 inactive in because of its involvement in this case?
11 A I certainly do, and there have been more
12 since that time.
13 Q So I've marked as Exhibit 12 a November
14 4th, 2019, letter to the North Carolina State Board
15 of Elections.
16 Do you see that?
18 identification.)
19 A Yes, I do.
20 BY MR. TYSON:
21 Q And this is a letter that you signed on
22 behalf of the Coalition; is that right?
24 Q And this letter urges the board not to
25 certify ballot marking devices in North Carolina,

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1 correct?
2 A Particularly the ES&S ExpressVote, yes.
3 Q Did the board ultimately certify the
4 barcode-based BMDs, the ExpressVote?
5 A Unfortunately, they did.
6 Q And CGG was able to engage in this effort
7 despite its involvement in Curling, right?
8 A Certainly not to the extent that we have
9 been asked to or want to, and even today I've had to
10 decline some ongoing requests for CGG's help on this
11 very topic. There is a source code review that we
12 helped initiate, but we have not been able to follow
13 through on supporting the efforts to a source code
14 review for the ExpressVote.
15 Q And do you recall sending an e-mail to
16 Mecklenburg County Board of Elections in 2019 as
17 well?
18 A I probably sent quite a few e-mails to
19 the -- to the Mecklenburg County Board on any number
20 of topics.
22 identification.)
23 BY MR. TYSON:
24 Q I've marked as Exhibit 13 a document
25 produced to us in discovery, and you are

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1 [email protected], right?
2 A That's correct, yes.
3 Q And was this correspondence, do you
4 recall, also urging this particular county board not
5 to use the ExpressVote machines?
6 A Yeah. Let me take a minute and review it.
7 I'm not recalling it just --
8 Q Sure.
9 A -- off the top of my head.
10 Q Take as much time as you need.
11 A What was the date on this?
12 Q This one, I'm sorry, I scrolled down,
13 September 26, 2019.
14 A Okay. All right. Yeah, then if you'll
15 scroll so I can read the body a little more.
16 Q Sure. And this is in your Exhibit Share
17 if you need it there as well.
18 A Okay. Okay. Do you want to scroll to the
19 next page for me?
20 Q Certainly.
21 A Thank you. Okay.
22 Q All right. So --
23 A Yes, I was urging against the -- CGG was
24 urging against the passage of or the use of
25 ExpressVote's machines --

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1 Q Got it.
2 A -- in North Carolina.
3 Q And what I want to ask about is just
4 number 11 there. You say electronic ballot marking
5 devices such as ExpressVote are in litigation in
6 federal court in Georgia, challenging the
7 unconstitutional nature of this form of voting.
8 More lawsuits are expected soon.
9 A Part of it is. The other part of it when
10 it says more lawsuits are expected soon, I believe
11 that that is talking about Pennsylvania lawsuits on
12 this, and I think there was another one that was in
13 the works at that time, and I'm forgetting right
14 now.
15 Q And CGG was able to engage in this effort
16 despite its involvement in Curling, right?
17 A "This effort" being the advocacy in
18 Mecklenburg County --
19 Q Yes.
20 A -- is that what you mean?
21 Well, yes, and obviously not nearly to the
22 extent we wanted to.
23 What we wanted to do and started preparing
24 to do and then had to abort our efforts was to make
25 a series of administrative challenges to the

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1 certification that was eventually done by North

2 Carolina and then consider after -- after we
3 exhausted administrative remedies consider
4 litigation to stop this as one of the many things we
5 wanted to do, but we had to abort that and turn over
6 our documents to other organizations to essentially
7 pick up where we left off, and they did litigation
8 which we just could not -- we just didn't have the
9 bandwidth to do here in North Carolina.
11 A Yes.
12 Q I'm sorry, I didn't mean to interrupt you
13 there.
14 I want to ask you now next about -- this
15 is another document produced to us in discovery.
16 Looks like an e-mail communication, and it's
17 addressed to Dear Georgia Republican Leaders on
18 March 4th, 2021.
20 identification.)
21 BY MR. TYSON:
23 A I do.
24 Q And this was sent, I'm assuming, to
25 officials while the legislature was considering

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1 election integrity legislation; is that right?

2 A You know what, I'll need to review it to
3 remind me what this is about.
4 Q Okay.
5 A Okay. What was your question again?
6 Q Was this e-mail sent while the legislature
7 was considering what I think they refer to as
8 election integrity legislation?
9 A Well, it was -- it was sent during the
10 time that they were considering election
11 legislation.
12 Q So what I want to ask you about is at the
13 very end of the e-mail you describe the Coalition
14 for Good Governance, and you say: CGG is a small
15 but strictly nonpartisan nonprofit organization.
16 Our members and leaders represent quite diverse
17 political views as individuals but come together for
18 the nonpartisan goals of election security, voter
19 privacy, and election transparency. Our ongoing
20 litigation seeking to have the Dominion BMD voting
21 system banned is a project of current primary focus
22 for us.
23 You see that?
24 A Yes.
25 Q And would you say the Curling case is a

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1 project that is related to CGG's goals here of

2 election security, voter privacy, and election
3 transparency?
4 A Well, certainly it is related to our
5 goals. We try not to do anything that's not part of
6 our goals. But, yes, it's certainly part of our
7 goals, but it's certainly not the way we would
8 choose to achieve our goals. It's a last resort.
9 Q And is the statement correct that the
10 Curling case was a project of primary focus in 2021?
11 A Yes, just because of the consuming nature
12 of it, it had to be a primary focus for us, not
13 necessarily by choice, but by just the requirements
14 of keeping up with the demands of the case.
15 Q And CGG was able to engage in this
16 advocacy effort despite its involvement -- for the
17 General Assembly legislation despite its involvement
18 in Curling, correct?
19 A Yes, certainly not to the extent that we
20 should have or would like to. Obviously as a
21 501(c)(3) our lobbying efforts are limited anyway,
22 but had we had more resources, more volunteer time I
23 would have hoped that we would have done a better
24 job of being effective at what we were trying to
25 lobby against.

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1 I think most of these bills made their way

2 into SB202. I believe what -- that's what most of
3 these references are talking about. But yes, we did
4 engage, but not nearly as extensively or effectively
5 as we would have had we not been dealing with the
6 BMD audit inadequacy Dominion Voting System issues.
7 Q So we're finished with topic 1, which is
8 probably --
9 A Good grief.
10 Q I will say that's the majority of where we
11 were going to spend our time, so we'll keep on
12 trucking here. Do you want to take a break before
13 we move to topic 2?
14 A What is your sense of the rest of the day?
15 I mean, do you want to take a lunch break at some
16 point?
17 Q It's really --
18 A It really doesn't matter that much to me.
19 I really wouldn't mind having 5 or 10 minutes to
20 grab a new cup of coffee or something. It doesn't
21 have to be now, but I don't know how long you're
22 planning to go. Do you mind kind of giving me your
23 thoughts for the outline of time for the day?
24 Q Sure. So we've kind of been through --
25 this addressed half of the things we covered today,

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1 so we have a little ways to go yet, but I'm kind of

2 fine to do whatever you want to do on lunch. If
3 you'd rather go ahead and take a longer break we can
4 do that. This next topic is going to be relatively
5 short, but it's really up to you and Robyn. I know
6 we need to consider our court reporter as well may
7 need a break.
8 A I'm happy to accommodate anybody else's
9 schedule. Let others speak up for what they want to
10 do.
11 THE REPORTER: Should we go off the record
12 for this discussion?
13 MR. TYSON: Certainly.
14 THE VIDEOGRAPHER: Time is 2:25 p.m.
16 (Recess 2:25-2:33 p.m.)
19 BY MR. TYSON:
20 Q Thank you, Ms. Marks. We're going to
21 move to topic number 2, so referring us back to
22 Exhibit A of Exhibit 1. Topic 2 is the changes made
23 to the organization's budgets as well as any
24 contemporaneous rationale for such changes during
25 its budget years from January 1st, 2017, through the

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1 present relating to the laws, policies or protocols

2 challenged in this action. And you were the
3 designee for CGG on topic 2, correct?
4 A That's correct.
5 Q And did you review any documents
6 specifically to get ready for this topic?
7 A No, I'm not sure that there were any
8 documents that would have directly addressed this
9 question.
10 Q And did you speak to anyone associated
11 with CGG specifically to prepare for your testimony
12 on this topic besides counsel?
13 A Not specifically for this purpose, no.
14 MR. TYSON: I think this one will be
15 relatively quick since my focus is on just the
16 document piece, and, Rob, I know you had some
17 objection to this topic. I don't think we'll get to
18 the objectionable scope here, but we'll see how we
19 do.
20 BY MR. TYSON:
21 Q Ms. Marks, does CGG maintain a written
22 annual budget?
23 A No, we do not.
24 Q Okay. And so there's no way to identify
25 from an internal budget document spending on

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1 specific categories; is that correct?

2 A That is correct, not from any type of
3 document.
4 Q Okay. And so then it would be correct to
5 say that there's not a document that identifies a
6 diversion of resources from one project to another
7 project within CGG, correct?
8 A I would not say that. I thought you were
9 asking me about a budgetary document, but we have
10 lots of documents that would indicate that, you
11 know, we had to spend money on some type of
12 expenditure that perhaps we were not expecting that
13 we -- which we could have spent on something else.
14 Q I apologize, I was asking specifically
15 about budget documents. I didn't add that
16 qualifier. So --
17 A Sorry.
18 Q -- it's correct to say there are not
19 budget documents that demonstrate CGG spending funds
20 in a different way as a result of the allegations in
21 the Curling lawsuit, correct?
22 A And that is because we do not prepare a
23 formal budget. So, yes, there would not be
24 amendments to the budget because we don't have a
25 formal one.

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1 Q And I believe we covered this already, but

2 is it correct that CGG began funding activities
3 related to touchscreen voting in Georgia in 2017?
4 A I'm thinking about the answer. If there
5 were spending in 2016, it would have been at the
6 very end of 2016, and those expenses would have been
7 relatively minor. So any significant spending would
8 have started in 2017.
9 Q Okay. Thank you. That takes care of
10 topic 2, so we can move along at a quicker clip
11 hopefully here.
12 A Okay.
13 Q So let me refer you to topic 3 back on
14 Exhibit 1, and topic 3 is the organization's exempt
15 purpose and activities it undertakes in accordance
16 with its exempt purpose.
17 Do you see that?
18 A I do.
19 Q And you're the designee of CGG for topic
20 number 3, correct?
21 A I am.
22 Q And for our purposes here just so we are
23 all clear, "exempt purpose" refers to the tax-exempt
24 purpose of CGG.

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1 Q So did you review any documents

2 specifically to prepare for topic 3 of the
3 deposition?
4 A I did not, and that's when I said I forgot
5 to -- my intention was to go back and reread the
6 specific wording on the 990, and it's -- I had a
7 note to do it, and I just forgot.
8 Q And I apologize, you did raise that
9 already, so let's go right to that. I want to show
10 you Exhibit 8, which while I'm getting there let me
11 just clarify I'm assuming that also means you didn't
12 speak with anybody associated with CGG about this
13 particular topic, correct?
14 A Not about this particular topic, correct.
15 Q So on the 2019 990, page 2, line 1,
16 there's a line that says, briefly describe the
17 organization's mission.
18 Is this an accurate summary of CGG's
19 mission?
20 A It is.
21 Q And part of that mission --
22 A May I correct myself there?
23 Q Certainly.
24 A It has expanded beyond Colorado obviously,
25 and that may have been in our kind of original

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1 post-2014 reorganization -- informal reorganization

2 of Rocky Mountain Foundation, and we -- we certainly
3 expanded beyond Colorado, and I guess it depends on
4 what you consider the region, but that probably
5 needs to be formally expanded in our -- in our work.
6 Q Okay. Thank you for that clarification.
7 On the third line there, there's an
8 indication that: CGG will engage in litigation as
9 well as provide monetary support for legal expenses
10 to other organizations engaged in litigation on
11 these issues.
12 Do you see that sentence?
13 A Yes.
14 Q And so part of CGG's mission is filing
15 lawsuits, right?
16 A Well, I wouldn't -- I wouldn't say that it
17 is our mission to file lawsuits. We know that it
18 will be necessary at times.
19 Q Okay. And the lawsuits that are filed are
20 in pursuit of the interests that CGG exists to
21 protect, correct?
22 A Well, yes.
23 Q So let me next mark a portion of the CGG
24 website. Are you responsible for what's posted on
25 the CGG website?

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1 A Not me personally directly. I don't know

2 how to do it. But speaking for the organization,
3 yes, we as an organization are responsible for
4 what's on the website, which is often out of date.
5 Q Well then let me ask about this to see if
6 this is in date or not.
8 identification.)
9 BY MR. TYSON:
10 Q So this is a printout you can see at the
11 bottom here Exhibit 15, right,
12 coalitionforgoodgovernance.org.
13 A Right.
14 Q Is that the website of the Coalition?
15 A Yes, it is.
16 Q And this is a mission statement. Is this
17 mission statement up to date and correct?
18 A Let me take a look.
19 Q Okay.
20 A It is correct, and it looks like it was
21 taken to a great degree from that tax-exempt purpose
22 that you and I were just looking at.
23 Q Thank you.
24 So CGG is engaged in interests related to
25 government transparency and accountability. That's

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1 one of the things, correct?

2 A One of the things, yes.
3 Q And elections are listed specifically,
4 correct?
5 A Yes.
6 Q Does a jurisdiction's use of BMDs relate
7 both to the elections and the government
8 accountability and transparency interests of CGG?
9 A As well as due process and equal
10 protection, yes.
11 Q So advocacy around the use of electronic
12 voting relates to several of CGG's interests, right?
13 A Yes.
14 Q When you say in that second paragraph, "we
15 will engage in litigation," that litigation is a
16 major function of CGG, at least as to its activities
17 right now?
19 A Litigation is certainly consuming a huge
20 amount of our resources right now, but if we go
21 ahead and read the rest of that sentence, inform
22 legislative policy, and then the next sentence we
23 will be using education, communications, obviously
24 those are much preferable for any organization than
25 to engage in litigation.

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1 So yes, litigation is one avenue, but it

2 is our -- our least favorable choice.
3 BY MR. TYSON:
4 Q Understood.
5 Now, CGG is a Colorado corporation,
6 correct?
7 A Incorporated in Colorado, yes.
8 Q Is CGG registered as a charity in Georgia?
9 A We are.
10 Q So let me next mark Exhibit 16.
12 identification.)
13 BY MR. TYSON:
14 Q These are articles of incorporation for a
15 nonprofit corporation from the Colorado Secretary of
16 State. Do you see that?
17 A Correct.
18 Q And this is for the corporation Rocky
19 Mountain Foundation, Inc., right?
20 A Right. Yes.
21 Q Do you know, are these the original
22 articles of incorporation for what is now CGG?
23 A I believe that they are. At least
24 according to our records they are. We did not -- we
25 were not management at the time they were filed.

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1 Q Understood.
2 So what I wanted to ask you about, the
3 last page is entitled Rocky Mountain Foundation,
4 Inc. Attachment to Articles of Incorporation for the
5 Nonprofit Corporation, and provision 1 is the
6 purpose, and the purpose says: Said corporation is
7 organized exclusively for charitable, religious, and
8 scientific purposes, including for such purposes,
9 the making of distributions to organizations that
10 qualify as exempt organizations under section
11 501(c)(3) of the Internal Revenue Code, or the
12 corresponding section of any future tax code.
13 Do you see that?
14 A I do.
15 Q Is this -- well, let me put it this way:
16 I tried to locate any other filed purpose statement
17 for the organization CGG and was not able to do so.
18 Do you know if this is the current incorporated
19 purpose statement of CGG?
20 A I was just asking myself that as you
21 presented this, and, quite frankly, I just don't
22 remember. I know we made some amendments to the
23 articles of incorporation a long time ago, I believe
24 we did, and by-laws, and I just can't answer that
25 question for you right now. I don't remember.

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1 Q We'll look at another provision of the

2 website related to purpose. Mark this as Exhibit
3 17, and this is the coalitionforgoodgovernance.org
4 website, slash, bios?
6 identification.)
7 A Which is definitely out of date, okay.
8 BY MR. TYSON:
9 Q Entitled Who We Are. You see that there?
10 A Yes.
11 Q That was going to be my first question is,
12 is this current?
13 A No. I was talking to Mary Eberle about
14 this a few weeks ago, and she said, Marilyn, it just
15 hasn't been my priority to get this updated.
16 It is not up to date for all sorts of
17 reasons, including we have two additional directors
18 who are not reflected on here.
19 Q Understood. We'll get to the board and
20 those pieces here in a minute.
21 A Okay.
22 Q I just wanted to ask a couple questions
23 about your bio. You indicated after your loss to
24 become mayor of Aspen that you then devoted
25 full-time to election integrity litigation and

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1 lobbying efforts for more transparent and verifiable

2 elections; is that right?
3 A Yes.
4 Q Is that a fair summation of your work at
5 CGG?
6 A Not -- not totally today, no, because as
7 we've talked, you know, a lot of time is spent with
8 education, talking to voters, talking to candidates.
9 So it would be election administration, election
10 integrity efforts of which litigation and lobbying
11 would be two of the things, but certainly not all.
12 Today, you know. This is -- in 2009 I then devoted
13 full-time to...
14 Q To those efforts?
15 A Yeah.
16 Q Makes sense.
17 So let me ask next about the exempt
18 activities and the mission that you've listed in
19 your complaints. So I'm going to return back to
20 Exhibit 3 here and go -- which is the third amended
21 complaint and go to paragraph number 20.
22 You see that with me?
23 A I do.
24 Q And so in this complaint the Coalition
25 alleges Coalition's purpose is to preserve and

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1 advance the constitutional liberties and individual

2 rights of citizens with an emphasis on preserving
3 and protecting those private rights of its members
4 that are exercised through public elections.
5 Do you see that?
6 A I do.
7 Q And so is it correct that advancing
8 individual rights through proper election
9 administration is a key part of CGG's mission?
10 A Yes, sure.
11 Q Okay. Then there's a -- paragraph 21
12 lists -- begins, "Coalition serves its purpose in
13 multiple ways, including by," and then lists out a
14 number of different things that are there, which if
15 you can just take a minute to read through those for
16 me.
17 A Okay. Okay.
18 Q You'd agree with me CGG sometimes serves
19 its purpose by filing litigation, right?
20 A Sometimes, yes.
21 Q So what I want to do is kind of walk
22 through these different pieces you list in paragraph
23 21. Since the filing of Curling, CGG has provided
24 information and education to its members, correct?
25 A Yes.

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1 Q And since the filing of Curling, CGG has

2 served as a nonpartisan and informational resource
3 for the public, press, campaigns, candidates, and
4 political parties, right?
5 A We have.
7 monitored nationwide developments in election law
8 and technology, right?
9 A Not nearly as much as we used to, but we
10 have done that to the extent possible.
12 provided speakers for events at educational
13 institutions, right?
14 A Quite frankly, that has declined even
15 since this was written because we've had to -- I
16 think this year we've declined all invitations, and
17 most of last year we had to decline most
18 invitations, but we still -- when we can, we do it.
19 Q Okay. And CGG, since the filing of
20 Curling, has provided commentary from its leadership
21 on election issues, right?
22 A We have done that, but we have been unable
23 to do it recently. And what I mean by this in that
24 statement was generally op-eds, and I have been
25 asked to write many a op-ed in this last six months

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1 and have been unable to.

2 So, yes, done it, but we have not done it
3 nearly as consistently and as actively as we want
4 to.
5 Q Since the filing of Curling, CGG has
6 collaborated with voting rights and election
7 integrity initiatives with other nonpartisan profits
8 (sic) and academics, right?
9 A Many of those activities are on hold right
10 now, but we have done some of this, yes.
11 Q And to kind of finish out here, since the
12 filing of Curling, CGG has developed and shared
13 research about election problems, right?
14 A That we have done extensively, yes.
15 Q And since the filing of Curling, members
16 and prospective members of CGG have participated in
17 the electoral process through poll watching,
18 attending public meetings, and other civic
19 activities, right?
20 A That has declined a lot in the last six
21 months, but yes, we have engaged in that, you know,
22 to some extent in every year since 2017.
23 Q Let me move next to topic number 4. Topic
24 4 is the organization's organizational structure,
25 including individuals who have the authority to make

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1 funding and resource allocation decisions for the

2 organization from January 1, 2017, through the
3 present.
4 So you were the designee for topic number
5 4, correct?
6 A I am.
7 Q And did you review any documents to
8 prepare for this particular topic of the deposition?
9 A No, I did not have any documents to really
10 look at for that.
11 Q Did you speak to anyone about the -- about
12 the topic -- I'm sorry, start over again.
13 Did you speak to anyone who's currently or
14 formerly associated with CGG to prepare for this
15 part of your deposition?
16 A No, not on this part. I'm just going back
17 to read the --
18 Q I'm sorry, I can put that back up.
19 A No, no, no, I've got it in front -- I've
20 got it right here. I just needed to scroll to it.
21 Okay.
22 Q Let me know when you're finished.
23 A I'm finished.
24 Q All right. So what is CGG's
25 organizational structure?

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1 A So we have a board of directors that we

2 talked about, and I think we listed the board
3 members' names. Or maybe we didn't.
4 Q I don't think.
5 A All right. So Mary Eberle is the board
6 secretary, Lisa Cyriacks is the board chairman, and
7 I believe she has the title of president, Rhonda
8 Martin is on the board, and Virginia Rutledge Forney
9 is on the board, and I'm on the board. So that
10 makes up the formal board of directors of CGG.
11 Q And I counted five individuals is the
12 right number for the board?
14 Q When did the board expand from three to
15 five members?
16 A I'm thinking about that. I believe it may
17 have been in late 2019 or early 2020, sometime in
18 that time frame. That's probably not exactly right,
19 though.
20 Q And I guess what I'm really trying to get
21 to is at the time Curling was filed, is it correct
22 there were only three board members?
23 A That is correct, yes.
24 Q And those three board members were Lisa
25 Cyriacks, Mary -- I'm sorry?

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1 A Eberle.
2 Q Eberle -- I knew I wasn't pronouncing it
3 right -- and you, correct?
5 Q Okay. How frequently does the board meet?
6 A We do not have a particularly regular
7 meeting schedule. I mean, we meet the requirements
8 of the by-laws on that, but we tend to call a formal
9 or informal board meeting, you know, every several
10 weeks generally when there's some either decision
11 that needs to be made or important update on some of
12 the activities.
13 Q Did the board have to vote to approve the
14 filing of the Curling lawsuit?
15 A We did.
16 Q And does the board make decisions that
17 reallocate financial resources to litigation or
18 education or other areas?
19 A Well, this kind of goes back to our
20 previous discussion about budget, and because we
21 don't keep a formal budget per se, there wouldn't be
22 a formal decision to move things from category A to
23 category B, but they are all generally aware of what
24 financial obligations we are undertaking and approve
25 them if they're significant.

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1 Q Do you have a particular threshold for

2 significance?
3 A We really don't. We don't. If it were
4 going to be, say, undertaking a new case, you know,
5 knowing that there would be legal expenses involved,
6 then we would -- we would certainly have full board
7 approval for something like that. If it's, like, a
8 new subscription to Constant Contact, no, we don't
9 make a big board decision on something like that.
10 Q Did the board decide to divert the
11 resources that we discussed earlier -- financial
12 resources we discussed earlier, or is that a
13 decision somebody else made?
14 A There wouldn't be anybody else to make
15 such a decision. The board would have to make such
16 a decision. We don't have another boss somewhere.
17 Q And I guess my question was more
18 specifically did the board delegate to you the
19 ability to make those decisions, or are they always
20 made at a board level?
21 A For something like, you know, engaging in
22 litigation, that doesn't just happen. We -- you
23 know, election cases aren't filed overnight, you
24 know. We talk about it, decide if it fits, can we
25 afford it, generally no, but we -- we discuss it,

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1 and then they give me the authority to engage the

2 attorneys and get started.
3 Q Would the board also make decisions to
4 allocate volunteer time to, for example, litigation
5 as opposed to voter education?
6 A It's generally discussed. It's something
7 we're always talking about is what are our
8 volunteers doing, and how can we be more efficient.
9 It wouldn't be something that we would put up for a
10 board vote, though, because, again, we can't --
11 these are volunteers. We don't control how much
12 time they spend, and to a great degree our
13 volunteers work on things that they are passionate
14 about. We don't necessarily say, oh, please don't
15 work on educating the Morgan County, you know,
16 candidates and instead go focus on Spalding County.
17 We don't really do that.
18 Q Who makes the decision about the
19 allocation of interns' time?
20 A I do the bulk of that. Mary Eberle also
21 gets involved in that when -- particularly if they
22 are trying to do something related to website or
23 contacting donors or members. Mary Eberle will tend
24 to get involved in that and supervise them at that
25 time.

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1 Q I'm assuming that there's no kind of

2 formal documentation of those decisions; that's just
3 instruction to somebody to go do something?
4 A Correct. I mean, it's like -- well, for
5 example, Mary yesterday was asking an intern to
6 update ShareFile links for her to put on the
7 website. Of course it's documented that she asked
8 her to do it, but we don't have some document that
9 says, Mary, you may ask the interns to do these
10 things, but you can't ask them to do that. Okay?
11 It's just more informal than that.
12 Q Informal process, I understand.
13 A Informal process, yes.
14 Q So I want to ask you -- I've marked as
15 Exhibit 18 what I received Tuesday evening, this
16 document titled CGG Board Discussion Package.
18 identification.)
19 BY MR. TYSON:
20 Q You see that?
21 A Yes.
22 Q I'll confess to be a little confused. The
23 title was 3/15/21 materials. Is this for a meeting
24 in 2020 or 2022 -- or 2021 or 2022?
25 A It was actually for a meeting yet to come.

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1 It's scheduled for next week. We're trying to nail

2 down whether it's going to be the 21st or the 22nd,
3 and I started and titled the thing I think on the
4 15th, and I just screwed up and put '21 instead of
5 '22.
6 Q No problem. I just wanted to make sure I
7 hadn't missed something.
8 A Right. Right.
9 Q So this is a document you created; is that
10 correct?
11 A It is. It is a document that I assembled.
12 I didn't create every document in there certainly,
13 but, yes, I did assemble that for the board because
14 it's been a very long time since we've had a meeting
15 to kind of comprehensively go through a lot of
16 the -- a lot of the issues surrounding this
17 litigation, and they have asked to have an extensive
18 meeting soon to do that, and so I took a lot of
19 materials and pulled them together for that purpose.
20 Q Got it.
21 And are board discussion packages like
22 this, like Exhibit 18 created for every board
23 meeting?
24 A Oh, heavens, no. I wish they were, but
25 they -- because we had a lot of requests from the

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1 board for let's dive into where we stand on the

2 litigation and I had accumulated a bunch of news
3 articles, we had had the experts' reports recently,
4 no, I would not normally have this level of package
5 to go to a board, but -- and also because I had been
6 getting an awful lot of requests that I haven't
7 honored yet to explain the issues around the audit
8 and the issues around double and triple counting,
9 then I put a lot of stuff in there about this as
10 well that we got to spend time on.
12 All right. Moving right along, let's move
13 over to topic number 5. Back on Exhibit 1, topic 5
14 is the specific ways in which the actions of the
15 defendants that form the basis of the complaints in
16 this action caused the organization to divert
17 resources away from its organizational activities to
18 activities in which the organization had not
19 previously engaged and the identification of the
20 overall amount of the diverted resources, and then
21 A, the specific activities and projects the
22 organization was unable to engage in due to the
23 diversion of resources to activities necessitated by
24 such actions.
25 So you see that?

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1 A I do.
2 Q And you're the designee for topic 5,
3 correct?
5 Q Did you review any documents specifically
6 to prepare for topic 5?
7 A No, I -- I just thought a little bit about
8 some of the documents that we had produced for you,
9 and then I spent a little time thinking about the
10 more recent activities and projects that we are
11 having to either stop or not engage in or slow down,
12 and I didn't really go back and review a lot of
13 e-mails for that.
14 Q And did you also -- are these similar
15 topics that you would have spoken with Ms. Dufort
16 and Ms. Nakamura regarding?
17 A Similar, but certainly not all. They
18 are -- they tend to be -- tend to be more aware of
19 the Georgia issues and the Georgia activities, and
20 sometimes they get involved with -- as -- as they've
21 become more active in CGG and CGG has become more
22 known for some of this work, they also get involved
23 with some of the national organizations, but I tend
24 to have more the national relationships, and they
25 tend to have more of the Georgia relationships, if

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1 that makes any sense.

2 Q It does.
3 Did you speak to anybody else besides
4 Ms. Dufort and Ms. Nakamura to prepare specifically
5 for this part of the deposition, this topic?
6 A You broke up during part of that sentence.
7 It sounded like you said Ms. Dufort and
8 Ms. Nakamura; is that what you said?
9 Q Yes, I was saying besides Ms. Dufort and
10 Ms. Nakamura, did you speak to anyone to help
11 prepare for this topic?
12 A No, I did not.
13 Q And I don't want us to repeat, I think
14 we've covered a lot of this ground already in terms
15 of specific activities, but I did want to just try
16 to understand do you have a sense of what percentage
17 of the organization's work is dedicated to election
18 integrity or election efforts -- not election
19 integrity, just election efforts?
21 A I have no documents on such, and it would
22 just be a really rough idea of probably 90 percent
23 election related. Not necessarily BMD related or
24 Dominion voting related, but election related right
25 now probably 90 -- 90 percent, but not -- not

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1 because that's the only thing we want to do.

2 As I mentioned, I really want to be doing
3 some open -- open records -- excuse me -- yes, open
4 records and open meetings issues.
5 BY MR. TYSON:
6 Q And so the approximately 10 percent that
7 goes to other projects, what categories of -- are
8 those projects?
9 A I would say that some of that would be
10 fundraising, some of that will be just kind of
11 general administrative stuff like getting D&O
12 insurance or getting the accountants lined up to do
13 our audit -- or excuse me, our 990, but also where I
14 have spent some time, a little bit more these past
15 two years that I did not do so much in previous
16 years has been a little more involved in lobbying
17 for some legislation in Georgia, ballots as open
18 records, ballot images, and then trying to make
19 whatever changes we could, not necessarily
20 successful at it, in bills like SB202 and its
21 predecessors.
22 So while we spend absolutely no money on
23 lobbying other than some small portion of whatever
24 an e-mail costs, we don't spend any significant
25 money on lobbying, but I do spend some time on

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1 election-related bills primarily in Georgia. Not

2 doing very much right now in North Carolina despite
3 the request.
4 Q And I know you mentioned earlier work on
5 double-counting issues. You recall that?
6 A Yes. Yes.
7 Q And you'd agree with me that if an
8 election official is double counting ballots they're
9 counting them incorrectly, right?
10 A Well, yes. And when you say "an election
11 official," I don't mean to imply that it is the
12 official's fault that that is happening, but if the
13 system is counting twice or three times, that's
14 certainly wrong.
15 Q All right. So let's move to topic number
16 6, and topic number 6 is the specific laws,
17 policies, and protocols the organization alleges are
18 unconstitutional or violate federal law as asserted
19 in this action and the specific steps the
20 organization took to address its understanding of
21 those laws, policies, and protocols.
22 Then subpart A, specific steps the
23 organization has taken to address those laws,
24 policies, and protocols it advocates are
25 unconstitutional or violate federal law and its

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1 involvement in this action and the process by which

2 those steps were determined and the specific steps
3 the organization took to address those laws,
4 policies, and protocols it advocates are
5 unconstitutional or violate federal law other than
6 its involvement in this action and the process by
7 which those steps were determined.
8 So you see that language?
9 A I do see the language.
10 Q And you're the designee for topic 6,
11 correct?
14 specifically to prepare for topic number 6?
15 A As I mentioned before, I looked at our
16 first supplemental complaint, but I didn't look at
17 it last night or anything. I think I probably
18 looked at it about a week ago, and I might have
19 looked -- glanced at maybe a motion for preliminary
20 injunction. But in more detail than that, no, I did
21 not go through all our -- all our documents.
22 Q Certainly.
23 MR. MCGUIRE: I just wanted to reiterate
24 that we do have objections to the major topic and to
25 part A. Her preparation was curtailed by that, of

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1 course.
2 BY MR. TYSON:
3 Q Certainly. I think we'll be able to
4 address that as we go, so thank you for making note
5 of that.
6 So, Ms. Marks, other than filing this
7 lawsuit, has CGG undertaken any efforts to address
8 the laws, policies, and protocols it says are
9 unconstitutional?
10 A Yes.
11 Q And what are those?
12 A Well, for one, we have tried to do
13 communications with lawmakers certainly both at the
14 time that laws were being promoted in the general
15 assembly about ballot marking devices going back to
16 2018 and then 2019, we've talked to lawmakers both
17 formally in hearings, through e-mails, through
18 personal telephone conversations, through visits
19 with lawmakers. The same would be true of we've
20 talked to election officials who we felt they need
21 to be both educated on the -- on the issues and who
22 would hopefully lobby for avoiding BMDs and
23 promoting effective audits.
24 You know, other -- other activities would
25 have included educating members on the problems with

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1 the BMDs, and not only BMDs but necessity for

2 audits.
3 Let's see. I'm going back to the question
4 to make sure that I'm remembering all the things
5 you're asking about.
6 Okay. So we would have done lobbying, we
7 would have done education, we would have also
8 participated in generating -- crafting ourself
9 proposed rules that we have sent to the secretary --
10 excuse me, to the State Election Board around some
11 of these topics.
12 Oh, another thing that we've done, we
13 participated in the SAFE Commission meetings. We
14 went to almost all of the SAFE Commission meetings
15 to try to persuade the decision makers there, which
16 did not just include lawmakers but election
17 officials that the BMDs should not be required --
18 should not be accepted, and there should be
19 hand-marked paper ballots and audits, and we've also
20 talked to a variety of county election officials. I
21 may have already covered that. But there would have
22 been e-mails as well as personal talks to election
23 officials in the counties about these topics.
24 Q Thank you.
25 A Now, there could be some other -- some

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1 other types of activities I'm not remembering off

2 the top of my head and that I didn't remember at the
3 time I was preparing.
4 Q Okay.
5 A Those are some primary ones.
6 Q Okay. Thank you.
7 And the efforts to -- kind of start in
8 reverse order with the SAFE Commission, the goal
9 there was to persuade the SAFE Commission not to
10 adopt ballot marking devices, correct?
11 A I think that was a primary goal. I'm not
12 sure it was completely limited to that, but I'm sure
13 we would have had something to say about the
14 necessity of audits as well and probably other
15 election security issues.
16 Q And the Coalition's effort to lobby
17 lawmakers, if the Coalition could persuade a
18 majority of the General Assembly in both houses and
19 the Governor it could address the use of ballot
20 marking devices in Georgia, correct?
21 A Yes.
22 Q Is another step the Coalition has taken to
23 address the policies that it says are
24 unconstitutional is fundraising to fund its efforts?
25 A Well, yes, certainly. We would -- we

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1 would be doing fundraising year in and year out

2 regardless of efforts of what we were doing, but,
3 yes, it's taken a lot of resources to get this far
4 with this litigation.
5 Q And CGG has used its involvement in the
6 Curling case to help raise money, correct?
7 A Yes, uh-huh, in showing the need for what
8 we were asking donors to give, certainly.
10 identification.)
11 BY MR. TYSON:
12 Q Show you what we marked as Exhibit 19.
13 This is another e-mail produced to us dated August
14 20th, 2020.
15 Do you see that?
16 A I do.
17 Q And it opens with: Thanks for your
18 generous donation to the Coalition. We have great
19 progress to report.
20 Could you take a minute and look, is this
21 an update sent to donors, or do you know to whom
22 this e-mail was sent?
23 A I assume it was sent to donors.
24 Q Okay. And in this e-mail there's a
25 request to consider making a donation today to help

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1 fund the efforts in the Curling case, right?

2 A Yes. Certainly not limited to that, but
3 yes.
4 Q Let me -- there's another exhibit we'll
5 mark as Number 20.
7 identification.)
8 BY MR. TYSON:
9 Q This is another e-mail produced to us. I
10 believe it's September 13th, 2020.
11 Do you see that?
12 A I do.
13 Q And it says, Dear friends of Coalition for
14 Good Governance. Who does that constitute, do you
15 know?
16 A I don't. My guess is what we did is we
17 expanded beyond people who had donated in the past,
18 and I'm guessing it would be -- I don't remember
19 right now, but I'm guessing it would be people on
20 our mailing list, other mailing lists we may have,
21 we probably even sent to legislators, et cetera.
22 And when we say "friends," that was just a
23 general category of having a friendly opening to --
24 in the salutation.
25 Q What I want to ask here, there's an ask

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1 here: Can you make a contribution now to help with

2 attorneys' fees and experts' work.
3 You see that?
4 A I do.
5 Q And so CGG is asking for money to help pay
6 for attorneys' fees and experts' work, right?
7 A As we always do, yes.
8 Q And then you make the reference: Can we
9 count on you to support the essential battle for
10 simple, secure, and defensible elections?
11 Do you see that?
12 A Yes.
13 Q And that battle for simple, secure, and
14 defensible elections is part of the work that CGG
15 undertakes, right?
16 A It is part of the work, yes.
17 Q So let me -- let's go back to the website
18 here. We'll mark as Exhibit 21, this is the
19 coalitionforgoodgovernance.org/donate.
20 Do you see that?
22 identification.)
23 A I do.
24 BY MR. TYSON:
25 Q And is this the donate page that you would

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1 direct recipients of e-mail requests for funds to?

2 A Quite frankly, I haven't looked at it in a
3 while. I assume it is the most recent one that's up
4 there, but it certainly needs to be updated.
5 Q Okay. So on the donate page, I see that
6 you reference the newest lawsuit challenging Senate
7 Bill 202, and you reference the Curling versus
8 Raffensperger case, right?
9 A Yes.
11 BY MR. TYSON:
12 Q And you can take a minute to look, but I
13 don't see any reference to any other work of the
14 Coalition on the donate page; is that right?
16 A It doesn't mention any other project that
17 I see, but we say it will help defend election
18 transparency and security, so it's certainly not
19 meant to be limited to litigation.
20 BY MR. TYSON:
21 Q In the middle here you say: We rely on
22 donors -- rely on donors like you to help fund the
23 legal and experts' fees and expenses.
24 Do you see that?
25 A I do.

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1 Q And so the legal and experts' fees and

2 expenses relate to litigation work, right?
3 A Well, there's some legal expenses that do
4 not. Like, we mentioned a while ago that
5 Mr. McGuire helped me on some administrative work in
6 North Carolina on briefs that he wrote to -- briefs
7 is probably not right, but letters, that sort of
8 thing he has helped write in North Carolina that was
9 not litigation in those, but we would have put those
10 in the category of legal expenses.
11 Q Okay. That's helpful. Thank you.
12 And you close the page by saying: Thank
13 you for supporting the fight for transparent and
14 evidence-based elections.
15 See that?
17 Q And is that an accurate summation of the
18 Coalition's work?
19 A It's one element of our work. This is
20 just a thank you statement saying thank you for
21 supporting this part of our work, but it's certainly
22 not meant to be thank you for supporting every
23 little thing that we do.
24 If we go up above we've talked about that
25 the donations also go to support the work of our

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1 incredible interns.
2 Q Mark next Exhibit 22, which this is just
3 the home page for coalitionforgoodgovernance.org.
5 identification.)
6 BY MR. TYSON:
7 Q See that?
8 A I do.
9 Q So I wanted to ask, there's a donate
10 button right here at the top, and the statement is
11 made: And watch our progress in bringing effective
12 challenges to unauditable electronic voting systems
13 in Georgia assisted by your donation that will
14 exclusively support the legal and forensic work.
15 You see that?
16 A Right. Right. And that is certainly out
17 of date. I am not sure when we put that up, but I
18 think that was even before SB202. So that -- that
19 was meant to be kind of a fundraising at that
20 moment, but it really should have been updated and
21 expanded since then.
22 Q Okay. So it's not accurate to say that
23 donations to CGG exclusively support the legal and
24 forensic work?
25 A Not on an ongoing basis. I'm sure that

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1 particular fundraiser that was written at that time

2 was saying, yeah, let's -- let's divert -- not
3 divert, excuse me, let's dedicate virtually
4 everything to the legal and forensic work, but it's
5 not meant to be -- obviously it wouldn't even work
6 for it to be the only thing that we can put donors'
7 money toward.
8 Q Okay.
10 identification.)
11 BY MR. TYSON:
12 Q I've marked as Exhibit 23 the Coalition
13 for Good Governance current projects. See that?
14 A I do.
15 Q I'll try to zoom in. This one ended up
16 printing very small. So is this the current
17 projects site of the CGG website?
18 A To tell you the truth, I haven't looked at
19 our website. It is not one of the things I reviewed
20 in preparation for this deposition. I have not
21 looked at that website in a long time because I know
22 it's out of date, and it makes me feel guilty, so I
23 can't tell you whether it is or not.
24 Q I just want to ask --
25 A I'll take your word for it, though.

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1 Q I just want to ask about one thing in

2 particular, which I think based on our prior
3 conversation the statement here at the end that
4 donations go only to cover our litigation support
5 expenses and modest compensation for our analysts
6 and interns, is that also an out-of-date statement
7 at this point?
8 A It probably is an out-of-date statement
9 because, you know, I think it was meant to also be
10 probably not taken exactly literally. Obviously
11 we've got things like D&O insurance and accounting
12 fees and stuff that are minor, but, right, it would
13 be a bit of an out-of-date statement.
14 Q Okay. Now, do you -- you operate the
15 Twitter account at MarilynRMarks1, correct?
17 Q And do you conduct fundraising activities
18 or solicit funds for CGG on that Twitter account?
19 A To some extent, yes.
21 identification.)
22 BY MR. TYSON:
23 Q So I've marked as Exhibit 24 a series of
24 tweets from January the 24th from the
25 @MarilynRMarks1 account.

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1 A Okay.
2 Q You see that?
3 A I do.
4 Q And do you recall sending these tweets?
5 A Actually, I don't at the moment. I'll
6 need to kind of review them to --
7 Q Certainly.
8 A -- refresh my recollection.
9 MR. MCGUIRE: Bryan, is there a year on
10 that? What year did you say it was?
11 MR. TYSON: January 24th. It was on
12 January 28th, 2021, that it was printed, so these
13 all relate to -- I'm not trying to keep you from
14 reviewing this, Marilyn, but they relate to the
15 Capitol riot on January 6, 2021, so it should be
16 January of 2021.
17 MR. MCGUIRE: Bryan, I also just ask --
18 unless I don't understand, this doesn't look like
19 it's within any of the topics, so I assume she's
20 speaking personally and not on behalf of the
21 organization.
22 MR. TYSON: In my view this is related to
23 the steps that the organization took, it's another
24 fundraising-related question, but I'm happy for her
25 to answer in her personal capacity as to her own

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1 Twitter account.
2 A Okay. I'm not remembering all this off
3 the top of my head without a little more.
4 BY MR. TYSON:
5 Q And maybe I can short-circuit a little
6 bit.
7 A I'm not saying I didn't do it. I just
8 need to remember what this is about.
9 Q So my only question relates to these last
10 few tweets in this sequence: We at Coalition Good
11 Gov warned of this problem in 2018, 2019, and
12 continue our federal lawsuit (Curling v.
13 Raffensperger) to seek auditable elections-no
14 hackable touchscreens. Georgia should use
15 hand-marked ballots that cannot be manipulated.
16 Please help us, and there's a link to something
17 that's bit.ly/CGGDonate.
18 You see that?
19 A I do.
20 Q And so this is a request for a donation to
21 the Coalition, correct?
23 Q What I want to ask about is an individual
24 with the name @strategyPhD replies and says: I just
25 donated some cash for this excellent work that

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1 you-all are doing. I know it's not a lot, but every

2 20 bucks here or there will make a difference. Keep
3 up the democracy-saving work.
4 Then you reply: Thank you so much. We
5 know how to stretch a dollar and put it to critical
6 use. We have no overhead, and all donations go for
7 direct costs of litigation.
8 Is that a correct statement of how CGG
9 uses its resources?
10 A It is not technically correct. Right now
11 the vast majority of the resources that we get in
12 are having to go to support the litigation, but
13 literally we have a tight -- when I say we have no
14 overhead, overhead in the way most people think of
15 overhead, offices, paid -- salary, you know, most of
16 the work our interns are doing certainly is for
17 litigation support.
18 And so my point was here that the vast
19 majority of resources are being directed to
20 litigation support, not that we don't spend a dime
21 on something like an accounting -- like accounting
22 fees.
23 Q I'm going to mark what I marked as 25.
25 identification.)

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1 BY MR. TYSON:
2 Q This is another tweet from the
3 @MarilynMarks account August 22, 2020. And it says:
4 We at CGG -- I guess I should ask is
5 @CoalitionGoodGv the CGG Twitter account?
6 A It is.
7 Q And can you post to that account?
8 A I can.
9 Q Does anyone else have the rights to tweet
10 from that account?
11 A Yes. In fact, I rarely do it, but one of
12 our interns is supposed to be doing it, and we're
13 not keeping it up right now, but a few of our
14 interns have the ability to do that, and I believe
15 maybe Mary Eberle does as well.
16 Q So this tweet --
17 A Did I answer that I did? I can't remember
18 if I told you whether I have the ability, but I do.
19 Q Yes, and you did. Thank you for that
20 clarification.
21 So this statement says: We at Coalition
22 Good Gov are fighting for a fair election in
23 November. We don't spend our time on seeking
24 recognition or writing research papers. We spend
25 our resources on the battlefield in the court to

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1 protect your rights. Please help support our

2 efforts, and then you direct people to the
3 coalitionforgoodgovernance.org/donate site, correct?
4 A Uh-huh.
5 Q And so at least in part of how you're
6 soliciting funds for CGG you're telling them that
7 you're not engaged in research paper activity but
8 instead are spending resources in court, correct?
9 A We are, and it's not meant to say we're
10 spending every single dime, but we are spending,
11 yes, our resources in court. And I guess I was
12 taking a slam at some of the many voting rights
13 organizations that tend to just sit in ivory towers.
14 Q Understood.
15 Does CGG maintain records of donations
16 that come from particular e-mails or campaigns or
17 does it all just kind of funnel into one pot?
18 A It really all funnels into one pot.
19 Obviously that's not correct as it relates to, say,
20 a foundation that we would specifically solicit, and
21 their donations are not kind of getting -- they're
22 not generally coming in through the website or
23 anything like that. We tend to have more one-on-one
24 personal communications with foundation-type donors.
25 Q Has CGG had success raising money citing

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1 the Curling case as a reason to donate to the

2 organization?
4 A There are so many parts of that sentence.
5 Had success. Sometimes I think that, actually, we
6 haven't had success in raising money compared to
7 what we need.
8 So have we raised money because people
9 support the litigation, yes. Have we raised money
10 because they support more generally what we do, yes.
11 Have we raised money because they support our
12 education efforts, the non-litigation efforts, the
13 research efforts, yes, that too. But people don't
14 send us a check saying, you know, 30 percent of this
15 is for litigation, and 40 percent of it is for
16 education.
17 BY MR. TYSON:
18 Q Let me go back to Exhibit 8. This is page
19 17 of the schedule A on the 2019 990.
20 A Yes.
21 Q You'd agree with me that from 2016 through
22 2019 support for CGG went up every year, right?
23 A During that period, but -- yes.
24 Q Curling was filed in 2017, correct?
25 A Correct. I was just -- I was just

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1 thinking about the prior period where I believe we

2 put in, like, $700,000 or something like that that's
3 not showing on here, but during that period of time
4 that you referenced, 2017, '18, and '19, yes,
5 donations did go up.
6 Q All right. Let's move on to topic 7,
7 which will be a very brief one. Topic 7 is the
8 activities or expenditures the organization plans to
9 undertake in the future related to the laws,
10 policies, and protocols challenged in this action if
11 it is unsuccessful in achieving relief through this
12 action.
13 Do you see that?
14 A I do. And I think we had an objection on
15 that or -- yeah.
16 Q There's a statement.
17 A Yeah, a statement, right.
18 Q Yeah.
19 A And, you know, in terms of -- undertake in
20 future related to this action. We have not made
21 specific plans, you know, in the event that we are
22 unsuccessful. We'll certainly keep what we're doing
23 on the education front and the lobbying front, but
24 have we tried to make specific plans on that, no. I
25 would expect that that relates to Georgia --

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1 Q Sorry, if I can just pause you for a

2 second. I have to ask my -- you're the designee for
3 topic 7, correct?
4 A Correct.
5 Q And I'm assuming, based on what you just
6 said, there were no documents or anybody you spoke
7 with to prepare for this topic, correct?
8 A That's correct.
9 Q And so my only question is if the lawsuit
10 is unsuccessful, I'm assuming CGG will continue
11 filing lawsuits about election systems, right?
12 A I don't know about that, but, you know, I
13 wouldn't say -- I wouldn't say yes to that. If the
14 lawsuit were to be unsuccessful, we will continue
15 activities related to BMDs, the Dominion system,
16 audits, and those activities would be of the type
17 we've talked about: Education, lobbying, working
18 with our voting members to try to find ways we would
19 be promoting absentee ballots, that sort of thing.
20 That would happen, but not necessarily filing
21 another lawsuit.
22 Q That's all we need to do for number 7.
23 Go off the record for just a second.

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1 (Recess 3:41-4:00 p.m.)

2 THE VIDEOGRAPHER: The time is 4 p.m.
4 BY MR. TYSON:
5 Q Thank you, Ms. Marks. We'll move on to
6 topic number 8 here, which is the total expenditures
7 of the organization on activities related to this
8 action since the organization began participating in
9 this litigation.
10 And you are the designee for topic 8,
11 correct?
13 Q And did you review any documents to get
14 ready for this particular topic?
15 A Yes.
16 Q And what documents did you review?
17 A I primarily looked at the 990s which we've
18 been looking at today.
19 Q Anything else?
20 A I did not look at the exhibit that you
21 talked about -- or, excuse me, the document you
22 talked about before, which was the -- our
23 applications for attorneys' fees. I did not end up
24 going through all that but knew that that is in the
25 record.

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1 Q Any other documents you looked at?

2 A No, I don't think so.
3 Q And did you speak to anybody connected
4 with CGG to prepare for this topic in particular?
5 A No.
6 Q So are the attorneys' fees that CGG has
7 paid so far reflected on its 990s? And when I say
8 "paid," I mean -- let me step back for a second.
9 I'm going to ask you about the attorneys' fees that
10 have actually been paid by CGG at this point. Are
11 those all reflected on the 990s?
12 A Except for those that have been incurred
13 since our last filing of the 990s.
14 Q And do you know what --
15 A It ended in 2020.
16 Q Do you know what the number is since the
17 filing of the last 990?
18 A I do not. I know that the accountants are
19 trying to close out the 2021 right now, and I do not
20 know what those numbers are. It would be roughly at
21 the same type of levels that we've been looking at
22 for the last couple years. Nothing dramatically
23 changed since that time.
24 Q And as you know, obviously, attorney fees
25 are an issue with the Coalition seeking to recover

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1 fees in this case. Do you know the amount -- total

2 amount so far the Coalition is seeking to recover in
3 fees?
4 A You know, seeking to recover where we have
5 requested the Court to award fees where the request
6 has already been made I assume is what you're
7 talking about, and what I remember right now is that
8 the total of fees and expenses, not just attorney
9 fees, is a little over 1.6 million, I believe. But
10 do I remember right now how that breaks down into
11 attorneys' fees or litigation support, I actually do
12 not, but assume that is well and accurately
13 documented in the record.
14 Q Thank you for that.
15 My specific question really is: Do you
16 know what the amount is -- post the filing for fee
17 recovery the amount the Coalition will seek to
18 recover up to the present day of fees?
19 A I do not know that number.
20 Q Do you know who would know that number?
21 A There will be no one person that would
22 know what we would plan to file for in the future
23 because that is going to be a combination of legal
24 bills from three different attorneys at least.
25 Q Let's go to topic number 9, which is the

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1 nature of membership in the organization, including

2 how individuals become members, any obligations of
3 members, and any benefits offered by the
4 organization to its members. And you are the
5 designee for topic 9, correct?
6 A I am.
7 Q And did you review any documents to get
8 ready for this particular topic?
9 A No, I did not.
10 Q Did you speak to anyone affiliated with
11 CGG to prepare for this particular topic?
12 A Jeanne Dufort and I might have talked
13 about this topic. I believe we did.
14 Q Can you think of anybody else besides
15 Ms. Dufort?
16 A No, not that I would have talked to about
17 this topic.
18 Q What I want to do is start back to the
19 third amended complaint, which is Exhibit Number 3.
20 A Mr. Tyson, that would be in addition to
21 counsel. Okay?
22 Q Certainly. And I apologize, I don't
23 definitely want to discuss theories with counsel.
24 I want to ask you in paragraph 19 of the
25 third amended complaint, the Coalition says:

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1 Individuals become members of Coalition by providing

2 their contact information and indicating a desire to
3 associate with the organization.
4 Is that still an accurate explanation of
5 how an individual becomes a member of the Coalition?
6 A It is generally, but it shouldn't be
7 thought of as some kind of precise universal form of
8 how people associate with the organization. Many
9 times it's a phone call to me saying, hey, I want to
10 be part of what you're doing and count me in. It's
11 not like there's some form that they fill out for
12 contact information. And so, you know, our members
13 come to us in any variety of rather informal means.
14 Q So if someone called you and said, I want
15 to be part of what you're doing, would you consider
16 that -- is that person then a member of CGG from
17 that point?
18 A Depending on how they express it, yes.
19 Then what I would do is say, hey, Mary Eberle, you
20 know, put them on our mailing list, and here's who
21 they are.
22 Q I'm not -- I want to be clear I'm not
23 asking you for this, but does CGG maintain a list of
24 its members?
25 A I will have to say that our list

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1 maintenance has kind of gone by way of many of our

2 other administrative activities. It is -- no, we --
3 we do not have a current list. The list that we
4 have are -- it's outdated. I know it has deceased
5 people on it. It hasn't been updated in quite a
6 while.
7 Q Okay. And so how would CGG go about then
8 right now determining if someone is a member or not?
9 A If it were important, as I heard one
10 person express, hey, being part of CGG is kind of
11 like -- it's a lot like being a member of the
12 Libertarian Party or Republican Party or Democratic
13 Party, there are no real requirements to, you know,
14 you've got to pay fees. No, there are no fees.
15 And, you know, people -- people come and go as they
16 may favor what we're doing or get irritated with
17 what we're doing, and so there is not some kind of
18 strict you're in or you're out.
19 For purposes of this litigation when it is
20 necessary to demonstrate that somebody really is an
21 active member of the organization, we make sure that
22 that is clear, and we put it in declarations, et
23 cetera, but other than that, we do not have rigid
24 requirements.
25 And one reason we don't need to do that is

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1 because there are no dues that go along with it.

2 Say, like, NAACP has dues requirements. We don't
3 have that.
4 Q Is there any affirmative obligation on the
5 part of anyone to stay a member of CGG?
6 A Certainly not.
7 Q In paragraph 19 you say that members
8 receive informational communications from Coalition.
9 Does the Coalition or CGG consider everyone who
10 receives informational communications from them to
11 be a member?
12 A No. No.
13 Q Does CGG have a separate list for
14 informational communications for members and
15 non-members?
16 A That's not really the way that we would --
17 we have multiple different, for example, e-mail
18 lists, and so we don't divide it up into members,
19 non-members.
20 Q And so the various e-mail lists, there's
21 no members e-mail lists out there, correct?
22 A There is an e-mail list that we -- that
23 would include all of the members, but it also
24 includes other people who we -- who would kind of
25 fall in that category of friends and people who

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1 might be potential members, but it's -- I don't

2 remember exactly what we call that e-mail list.
3 Q But you couldn't distinguish on that
4 e-mail list between someone who's a member and
5 someone who's a friend essentially?
6 A Or somebody who -- or even somebody who
7 has said, I don't want to have anything to do with
8 you guys anymore. No, there's not -- on that e-mail
9 list there would not be a way to determine that.
10 Q When you say "determine that," you're
11 referring to there's no way to --
12 A Determine who would just say, oh, this guy
13 told us to get lost, and he's not a member anymore.
14 Q Got it. No way to distinguish members and
15 non-members on that --
16 A Not on that e-mail, that's correct.
17 MR. MCGUIRE: Marilyn, I'm just going to
18 ask you let him finish his questions and don't talk
19 over him.
20 A Sorry. Apologize.
21 MR. MCGUIRE: Thanks.
22 MR. TYSON: Thank you, Rob.
23 BY MR. TYSON:
24 Q So I want to ask you next, you say:
25 Members can benefit from Coalition's facilitation of

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1 members' individual participation in civic

2 activities that are germane to the organization's
3 purpose, such as poll watching, auditing election
4 results, and publishing opinion pieces.
5 Do you see that?
6 A I do.
7 Q And can non-members also benefit from
8 Coalition's facilitation of participation in civic
9 activities that you listed here?
10 A Of course we believe everyone could
11 benefit from that work.
12 Q And can -- referring to this last
13 sentence, can non-members utilize Coalition as a
14 resource to answer a wide range of questions about
15 voting rights, voting processes, open meetings law,
16 public records law, petition process- -- recalls,
17 petition processes, election legislation, and how to
18 challenge election issues they encountered?
19 A Certainly, you know, not everybody has to
20 be a member who we talk to, and so, yeah, we would
21 hope to be of service to people who we would hope to
22 recruit as members or whether it's press,
23 legislators may utilize Coalition in that way as
24 examples.
25 Q So the categories alleged in the last

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1 sentence of paragraph 19 are not limited to members,

2 they're anyone who wants to reach out and you're
3 willing to help?
4 A Let's add that part that says people who
5 reach out and we are willing to help. Do we help
6 everybody who calls? Absolutely not. And we've
7 gotten a lot of calls this past -- since November of
8 2020 from -- from people we chose not to help.
9 Q Let me direct you to what we marked as
10 Exhibit 26, and this is an e-mail that was produced
11 to us, communications it looks like between Brian
12 Blosser and Marilyn Marks in January of 2018.
14 identification.)
15 BY MR. TYSON:
17 A I do.
18 Q And do you recall -- have you seen these
19 e-mails before?
20 A I have. It's been a while since I looked
21 at them, though.
22 Q And what I want to ask specifically about
23 is in your message apparently to Mr. Blosser, you
24 say -- you ask him: Would you consider letting us
25 use that in our case in federal court? All that you

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1 would -- we would need is for you to be willing to

2 testify as to what happened and to be a member of
3 our organization. There are no membership fees or
4 anything like that.
5 Do you see that?
6 A Yes.
7 Q And is that an accurate statement of, as
8 we've been discussing, how someone becomes a member?
10 A No, we don't ask people to come testify in
11 federal court to become a member.
12 BY MR. TYSON:
13 Q But it is correct that there are no
14 membership fees or anything like that to be a member
15 of CGG, correct?
16 A There are no membership fees, and what I
17 was just generally and informally saying here is you
18 don't have to write a check to be part of CGG.
19 Q And is Mr. Blosser currently a member of
20 CGG?
21 A We have not communicated with him in a
22 while. I believe that he may have moved out of
23 state and haven't heard from him in a while.
24 Q So today you don't know whether
25 Mr. Blosser is a member or not?

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1 A You know, there's no reason to think he's

2 not a member. I'm just trying to say that I haven't
3 had any recent communication with him. He may be
4 back in Georgia for -- because I know that was his
5 intention to return, but we just haven't heard from
6 him much.
7 Q He wasn't a member when this lawsuit was
8 filed, correct?
9 A No, not -- I think that is -- that's
10 correct, he was not.
11 Q Let me ask you next what I've marked as
12 Exhibit 27. These are the Coalition Plaintiffs'
13 responses to interrogatory -- supplemental response
14 to interrogatory number 12.
16 identification.)
17 BY MR. TYSON:
19 A Yes.
20 Q And do you recall did you verify these
21 interrogatories, or do you know?
22 A I don't think that I have verified the
23 interrogatories.
24 Q Okay. The interrogatory asked to identify
25 all members of the Coalition for Good Governance

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1 that are residents of the state of Georgia, the date

2 their membership began, and, if applicable, the date
3 their membership ended.
4 Do you see that?
5 A Yes.
6 Q And the response is a list of members upon
7 whom CGG will rely to establish associational
8 standing and their dates of membership. With me so
9 far?
10 A I am, and I'm realizing that Brian
11 Blosser -- I think the question was -- if you scroll
12 up, I think it says Georgia.
13 Q Yes.
14 A And I realize that he might not be a
15 resident of Georgia anymore. I think I missed that.
16 Q And the other date, the date that the
17 membership began and Mr. Blosser indicates 2017, but
18 the e-mail we just looked at you were talking about
19 him becoming a member in 2018.
20 A Right. Right. I -- that's just an error.
21 Q So Mr. Blosser, should he not be on this
22 list?
23 A He should still be on the list, but I
24 think it should be 2018 as the member.
25 Q Okay. And do you have -- I think I know

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1 the answer based on what we just talked about, but

2 Mr. Blosser's inactive status, there's no particular
3 method by which you track active or inactive
4 members, correct?
5 A No -- that is correct. I didn't mean to
6 say "no." We do not track anything like an inactive
7 status. It was just more a note of I haven't talked
8 to him in quite a while. Many of these other people
9 I would talk to frequently.
10 Q Understood.
11 Let me go next to another set of
12 interrogatories. So these I marked as Exhibit 28
13 are the Plaintiff Coalition for Good Governance
14 Responses to Defendant Anh Le's First
15 Interrogatories.
17 identification.)
18 BY MR. TYSON:
20 A I do.
21 Q And do you recall these interrogatories in
22 the Curling case?
23 A Barely.
24 Q I'm just going to ask you about one.
25 A Okay.

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1 Q Interrogatory number 13, the Coalition was

2 asked to identify the responsibilities or
3 obligations entailed in being a member of Coalition
4 for Good Governance and any benefits conferred by
5 such membership.
6 Do you see that?
7 A I do.
8 Q And you give an answer -- Coalition gives
9 some answers here. Does every member of the
10 Coalition for Good Governance have to work together
11 to promote the goals of the organization?
12 A No.
13 Q Does --
14 A It's not meant -- that was not meant to be
15 an obligation.
16 Q Okay.
17 A It just meant to be basically about the
18 spirit and the benefits of being a member, not an
19 obligation of a member.
20 Q Okay. Does CGG provide voter education
21 for individuals who contact it who are not members?
22 A Not every person, but yes, many people we
23 do.
24 Q Okay. Does CGG provide non-members with
25 poll watcher training?

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1 A Yes, we have.
2 Q Does CGG provide non-members with
3 education for citizen lobbying on election-related
4 matters?
5 A Let me go back to my previous answer.
6 That is not to say that we have been able to honor
7 all of the requests for poll watching training that
8 we have received. Particularly this past year,
9 particularly since SB202 went into effect, and I
10 believe there are some requirements on poll watching
11 training we have actually had to say no to people.
12 So I don't -- when we say we do provide
13 that, it's not -- and we would give non-members
14 training as well, it's not meant to say we're able
15 to honor all the requests.
16 Q Certainly. And my question was just
17 limited to is this something that you do for both
18 members and non-members.
19 A Correct, yes, we would.
20 Q And so CGG would provide non-members with
21 education for citizen lobbying on election-related
22 matters?
23 A Well, yes, because we would -- we would
24 maybe do special things for members, yes, special
25 focus they would reach out with communications for

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1 them, but certainly we are not going to say that

2 it's only limited to members because we would -- we
3 would be talking to the press about some of these
4 things, we'd be talking to legislators themselves.
5 So we're not trying to say that our efforts are
6 limited to just what we would communicate with
7 members.
8 Q You say at the end here that the foregoing
9 benefits are examples but not all of the types of
10 benefits that CGG provides to its members.
11 A Correct.
12 Q What other types of benefits -- or,
13 actually, let me ask it this way: Does CGG provide
14 benefits to its members that it does not provide to
15 non-members?
16 A Let me give you one example. That answer
17 would be yes, and it's not meant to be a, you know,
18 we don't want to help anybody else-type thing.
19 Obviously we exist to grow our membership,
20 to -- and to try to be helpful to the public, you
21 know, it is really based on public policy efforts is
22 why we exist.
23 But, for example, something we would
24 use -- we would work with members specifically on
25 would be we mentioned the efforts that we make at

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1 asking the State Election Board to promulgate

2 specific rules that we draft, that we work on
3 internally, and then we use our members to present
4 on behalf of other members, and we present them that
5 way to the State Election Board in the formal
6 process that's required by statute where we have to
7 have the form notarized, we are speaking on behalf
8 of members per se, and we only use members to do
9 those formal communications.
10 So that would be an example of a benefit
11 the public policy advocacy that we do on behalf of
12 members and with members exclusively.
13 Q So besides the public policy advocacy you
14 do on behalf of members, is there any benefit
15 provided to members of CGG that would not also be
16 provided to non-members upon request?
17 A Upon request. Yes. Yes, I mentioned to
18 you that we have had lots of calls this past year
19 from people who wanted to make demands on our time
20 concerning their challenges to -- and I don't mean
21 legal challenges, but their -- their challenges to
22 the 2020 election, and we have declined to spend the
23 kind of time with them that we would with our
24 members on the kinds of efforts that they wanted us
25 to try to contribute to educate them on. We just

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1 don't have enough time in the day to do that.

2 Q I'm sorry.
3 A Sorry, I'm done.
4 Q And are those individuals you're referring
5 to people who were challenging the outcome of the
6 2020 presidential election?
7 A When we say challenging, let's say not in
8 a formal way, but let's -- criticizing -- sending
9 disinformation. We've had lots of requests for
10 information that we have that might benefit some of
11 those claims, some of those inappropriate claims
12 that we've said no to.
13 Q So I understand that you -- there would be
14 times when you would deny a non-member a request.
15 Are there particular benefits to members aside from
16 the public policy advocacy you discussed that would
17 not be provided to a non-member solely because they
18 are not a member?
20 A For example, yes, something like if
21 someone wanted a mailing list of members that we
22 had -- if they wanted contact information for some
23 of our members, you know, I'd be very selective as
24 to who I gave that to. If they wanted a group of
25 people that I thought might be interested in a

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1 particular topic in a certain county where we have

2 relationships and members, I wouldn't necessarily
3 turn that over to a non-member but generally would
4 to a member. Something of that -- none of this is
5 written up as a policy, but I'm trying to tell you
6 the kind -- the ways that we would treat a member
7 and a non-member differently as an example. I'm
8 sure that's not the only example.
9 BY MR. TYSON:
10 Q Could every member obtain the contact
11 information of every other member?
12 A Certainly not, no. I would generally get
13 permission from members that if somebody says, hey,
14 we're trying to get a petition started in Cobb
15 County to do X related to election administration,
16 would you give me some of the members that are
17 active there, I would check with them first and then
18 do that. But would I do that for a non-member, it
19 would depend on the circumstances, but generally
20 not.
21 Q Let's move to topic number 10, Exhibit A,
22 whether and how the organization determined if any
23 of its individual members are impacted by the laws,
24 policies, and protocols challenged in this action.

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1 correct?
2 A I am, yes.
4 specifically for this topic of your testimony?
5 A I did not.
6 Q Did you speak with anyone associated with
7 CGG specifically to prepare for this testimony?
8 A No, I did not. Now, when I'm saying I
9 didn't speak with anybody about it, I sent the
10 topics out but only talked about things that people
11 said they had something to talk about. It wasn't
12 that they didn't see the list; it's just we didn't
13 talk about number 10.
14 Q To whom did you send the topic list?
15 A I sent it to Mary Eberle, to Rutledge
16 Forney, Jeanne Dufort, Aileen Nakamura, I may have
17 sent it to Lisa Cyriacks, but I -- I don't remember
18 for sure.
19 Q And then --
20 A I did not get a chance to talk with Lisa.
21 Q And then your practice was if somebody had
22 something to contribute they reached out to you or
23 did you reach out to them, how did that --
24 A I reached out to them, or if I didn't get
25 them I told them to call me back.

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1 Q And then in having a conversation with the

2 individuals to whom you sent the topic list, did you
3 ask them about each topic, or did you just wait to
4 see if they had specific --
6 A I asked them to read the whole thing and,
7 you know, let's discuss any that they felt like that
8 they might have information that I might have
9 forgotten about or was not aware of. And we did not
10 go through topic by topic, and, you know, the
11 conversations differed by individual as to how --
12 how deeply we got into it.
13 Q So let me ask then, has CGG determined if
14 any of its individual members were impacted by the
15 use of Dominion BMDs or other practices challenged
16 in this action?
18 A Yes.
19 BY MR. TYSON:
20 Q And what is that determination?
21 A Well, I think it is pretty well documented
22 in the documents that we have filed in the case.
23 Q Is it correct that -- I'm sorry.
24 A I'm sorry, I talked over you. You go
25 ahead. Go right ahead.

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1 Q In referring to the documents you filed in

2 the case, is CGG relying on the impact on all
3 Georgia voters for determining there was an impact
4 on its members?
5 A No.
6 Q Okay. What specifically -- how
7 specifically have CGG members been impacted by the
8 practices challenged in this action?
9 A Well, I think you -- we need to talk about
10 each individual that you're referring to here
11 because there's not a one-size-fits-all type of
12 injury.
13 Q Okay. Well, let's go to Exhibit 27 then.
14 How has Mr. Blosser been impacted by the practices
15 challenged in this action?
16 A So if I recall Mr. Blosser's situation, it
17 was that he attempted to vote in the 2017
18 Congressional District 6 election, and when he
19 arrived at his polling place, even though it was the
20 same polling place, and he was voting from the same
21 address as he had been for years, the pollbook
22 showed that he was not an eligible elector, and he
23 was not permitted to vote even by provisional
24 ballot. He was turned away even though he was an
25 eligible registered elector who had not previously

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1 voted, and it appeared to be the so-called software

2 glitch in the Express pollbooks that caused
3 Mr. Blosser not to be able to vote, is my
4 understanding.
5 Q What is the impact on Ms. Clark in
6 Gwinnett County?
7 A The -- I can name at least one instance,
8 but I would expect that there are more, and that the
9 one I'm remembering is that she went to vote, and
10 there were problems again with the ExpressPoll units
11 where she was told that, no, you are not registered
12 here, you're supposed to be at a different polling
13 location. And she argued with them for quite a long
14 time. They kept saying no, no, no, you have to go
15 to a different polling location. She knew that she
16 did not belong at a different polling location.
17 She spent an extraordinary amount of time
18 and energy talking to person after person, calling
19 the Gwinnett office, and eventually for some reason
20 they claimed, well, wow, your name just popped up
21 now in the book, and now you can vote.
22 But, of course, we never knew what caused
23 the name to just now -- and I'm saying in quotes
24 just now pop up in the book, and that she was denied
25 time after time after time the ability to vote at

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1 her home polling location. We do not know the

2 nature of that particular glitch. But her injury,
3 of course, was all of the difficulty that she went
4 through because of that -- because of the error.
5 Q Before we continue on the list, how did
6 CGG go about determining that these members listed
7 in Exhibit 27 were affected by the practices it
8 challenges in this case?
9 A I'm not sure that I exactly remember how
10 we did that. I'm sure I to some extent worked from
11 memory. I might have gone back through some of the
12 declarations that had been filed. But it would
13 have -- and then it could have been -- I believe I
14 worked with our attorney Bruce Brown on this, and I
15 believe he might have been referencing some of his
16 notes and documents as well.
17 Q And did CGG engage in this process of
18 determining which members were impacted in 2022 or
19 at some point before that?
20 A Well, I think you're aware that many of
21 their declarations were dated back to 2017 or '18
22 and in subsequent years, and so I don't think we
23 have -- I don't remember that we filed anything in
24 2022 with any declarations from any of them -- these
25 members.

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1 Q And my question was specifically the

2 process you just described with Mr. Brown and
3 working through the process of determining which
4 individuals would be listed. Did that process take
5 place in 2022 or at some point earlier?
6 A I think it would have probably taken place
7 at various times in the planning of the various
8 supplemental -- I don't mean -- probably the
9 supplemental complaint, the motions for preliminary
10 injunction, you know, various documents along the
11 way, things that we have filed we have selected some
12 of the members who have brought us complaints that
13 we used to have developed declarations.
14 And I think -- I believe what we did here
15 is selected from declarations. Certainly wasn't
16 meant to be every potential allegation that we've
17 ever heard.
18 Q And my specific question is: When was
19 this list selected from --
21 A And I'm telling you that that list would
22 have been put together by Bruce Brown on the second
23 day of February, but I don't think it happened on
24 that day. It would have been growing over time.
25 Maybe I'm not answering your question very

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1 well, but it was -- it was finalized on the second

2 day of February.
3 MR. MCGUIRE: Can I object here, Bryan? I
4 think there may be some miscommunication. Are you
5 asking about the preparation of this document that
6 you're looking at, or are you talking about this
7 list in some other form?
8 MR. TYSON: What I'm trying to
9 determine -- I'm trying to dig into the
10 determination of which of the members were impacted,
11 and we have a list of the people who were impacted
12 that was given to us on February 2nd. I'm trying to
13 determine when were these people identified as
14 members who were impacted. That's what I'm trying
15 to get at. Is that -- is that coming through in the
16 questions?
17 MR. MCGUIRE: Marilyn, if it's clear to
18 you, go ahead and answer.
19 A I'll try. I think I'm understanding you,
20 but, for example, Shea Roberts, I don't remember the
21 date of her declaration. I'm assuming that there
22 were a number of things that she was concerned
23 about. I do believe secret ballot was one of them.
24 I'm assuming that the date of the
25 particular injury that would have been used as an

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1 example here of members' injuries would have been in

2 the declaration, and at the time of preparing the
3 declaration we would have been referencing back to
4 that injury. But we would have heard about that
5 injury before the date of the declaration.
6 So there is no -- I don't think there is
7 any one answer for when were these injuries
8 determined. They were determined at various times
9 as they happened over the course of the last
10 four-plus years.
11 BY MR. TYSON:
12 Q So turning back to Exhibit 27, is it -- is
13 it your testimony that there are declarations or
14 affidavits from each of these 16 individuals that
15 have been filed in this case or just that you are in
16 possession of declarations or affidavits for each of
17 these 16 individuals?
18 A No, I actually -- I don't think that each
19 of them has -- I don't believe that we -- that we
20 asked Mr. Blosser to file a declaration. Ricardo
21 Davis, I don't remember whether it was a
22 declaration. You have his testimony in a
23 deposition. I don't believe that we completed the
24 declaration of Ashley Walker, but others I believe
25 have filed declarations.

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1 Q Do you know whether all 16 of these

2 individuals voted on BMDs in 2020?
3 A Oh, goodness, I would not know that. I
4 don't think I ever knew that. And if I did know, it
5 would be -- I would have forgotten it. But I'm sure
6 that not all of them did.
7 And you're talking about for the entire
8 year of 2020?
9 Q Any 2020 election, yes.
10 A You're asking me -- do you mind repeating
11 the question?
12 Q Do you know whether the 16 individuals
13 listed in Exhibit 27 voted on BMDs in any election
14 in Georgia in 2020?
15 A I know that not all of them voted on BMDs
16 in 2020, and I know that some of them did have to
17 vote on BMDs during 2020.
18 Q Do you know whether these 16 individuals
19 plan to vote on BMDs in Georgia in any election in
20 2022?
21 A From what they have told me, I think most
22 of them, and, again, like Mr. Blosser I haven't
23 talked to in a long time, and he may not live in
24 state, but most of the people generally feel that
25 they want to avoid voting on BMDs if at all

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1 feasible, possible, if they get their mail ballots

2 on time. For most of them they believe that mail
3 ballots are a more secure form of voting.
4 Q And CGG advises its members to vote using
5 absentee by mail ballots, correct?
6 A Generally, yes. It may not fit everyone's
7 particular circumstance, but yes, it is preferable.
8 We do not like mail ballot voting generally, and, of
9 course, I'm over-generalizing here. Generally we
10 don't like mail ballot voting, but we believe it is,
11 with all its difficulties, preferable to voting on
12 BMDs.
13 Q What is the injury that Ms. Forney
14 suffered?
15 A I'm not necessarily referring to a
16 specific declaration. I'm -- because I didn't
17 review that declaration, but I can tell you
18 generally that she is highly upset about the lack of
19 privacy in voting.
20 She is a prominent physician in town and
21 has often run into her patients in polling places,
22 and she -- she wants her privacy as to who she's
23 voting for. And generally she tries to vote by
24 absentee mail ballot but hasn't always been able to
25 get the ballot back in time, get the request in in

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1 time.
2 So I know that one of her -- one of her
3 concerns is privacy, and I also think that the --
4 just the hassle of -- and particularly in Fulton
5 County of trying to get a mail ballot and get it on
6 time has been an injury that she has experienced.
7 There may be others that I'm not
8 remembering from her declaration right now. I did
9 not review all these declarations before -- before
10 this -- before this deposition today.
11 Q And I believe you indicated Ms. Walker did
12 not submit a declaration; is that right?
14 Q And what is Ms. Walker's injury?
15 A It would also be ballot privacy or ballot
16 secrecy. And she has voted on BMD and complained to
17 me about the lack of privacy in the BMD.
18 Also, you know, she knows about the
19 security concerns and is concerned about whether or
20 not her vote is counting properly.
21 Q Ms. Walker is also indicated as a member
22 from August of 2014.
23 A Yes.
24 Q Did she join the organization at the time
25 it was still the Rocky Mountain -- sorry, I've lost

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1 the name.
2 A Foundation. Rocky Mountain Foundation.
3 Q Rocky Mountain Foundation?
4 A Yes.
5 Q In the interest of time let's keep moving
6 here. For the moment, Ms. Marks, I'm going to skip
7 over 11. We may come back to it if we have time.
8 Let me go to topic number 12, which is the
9 organization's communications with any county
10 government regarding the laws, policies, and
11 protocols it challenges in this action, from January
12 1st, 2017, to the present, including any other
13 litigation filed against a county entity during that
14 time regarding the laws, policies, and protocols
15 challenged in this action.
17 correct?
18 A Correct.
20 specifically for topic 12?
21 A Not any documents, no, I did not.
22 Q Did you speak with anyone associated with
23 CGG besides your counsel to prepare for topic 12?
24 A No, not specifically, but we didn't really
25 discuss this topic. I think there was some mention

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1 by Ms. Dufort on the ballot secrecy -- wait a

2 minute. Let me see if -- regarding laws, policies
3 challenged in this action.
4 She had mentioned the Sumter County
5 lawsuit, but I don't guess that is really what
6 you're asking about here. It just happens to have
7 secret ballot with respect to both of those -- both
8 of those cases.
9 No, I didn't have extensive discussions on
10 communications with county governments.
11 Q CGG has communicated to county election
12 officials to urge them not to use Dominion BMDs,
13 correct?
14 A Not to use them other than for
15 accessibility purposes. And the answer was yes, we
16 have.
17 Q And then you've kind of anticipated my
18 question. Has CGG filed any litigation against any
19 county government officials related to the election
20 practices challenged in this case from January 1st,
21 2017, to the present?
22 A The answer --
23 MR. MCGUIRE: Just to clarify you mean
24 apart from this case, Fulton being a defendant here?
25 MR. TYSON: That's a good call, Rob.

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1 BY MR. TYSON:
2 Q Apart from Curling has CGG filed any
3 litigation against county government officials
4 related to the election practices challenged in this
5 case from January 1, 2017, to the present?
6 A Okay. So when we say "related to," while
7 certainly the burdens of absentee balloting are
8 related to both the injuries in the Curling case and
9 also to the core claims in the Gwinnett case, Martin
10 case on absentee balloting, I'm assuming that's not
11 really what you're talking about here. I'm assuming
12 that it was something that would have the overlap,
13 say, of the ballot secrecy claims. In Sumter County
14 we filed a ballot secrecy challenge there, and that
15 ballot secrecy is also covered in the Curling case.
16 And I'm trying to think if I've
17 forgotten -- on what we call our COVID case, I don't
18 remember that -- I don't think there were any
19 counties that were defendants on that.
20 Q So --
21 A Yeah.
22 Q Sorry. So besides the Sumter case, that's
23 the ballot secrecy case, are there any other ballot
24 secrecy cases the Coalition has filed against
25 counties that are not in Curling?

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1 A Not -- not litigation per se, that's

2 correct.
3 Q Has Coalition filed any other types of
4 actions against county officials related to ballot
5 secrecy?
6 A No types of administrative actions other
7 than some time ago we did file a HAVA complaint that
8 referenced county ballot secrecy violations, but
9 the -- according to Georgia's law, HAVA complaints
10 have to go to the Secretary of State, and it was
11 really -- we did not choose any one county, I don't
12 believe, that we were alleging. We just gave -- we
13 gave examples from numerous counties, but really the
14 respondent was meant to be the Secretary of State.
15 Q And what was the outcome of the Sumter
16 case?
17 A Really because of lack of resources we
18 made a voluntary withdrawal and closed the case.
19 Q And no relief was granted in that case,
20 correct?
21 A That is correct. The good news was,
22 though, that the lawsuit itself caused the Sumter
23 County election officials to actually go take care
24 of the problem in the vast majority of the polling
25 places. They were able to either get new polling

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1 places or rearrange the polling places. And so

2 during the pendency of the challenge, many of the
3 problems got solved because we challenged.
4 Q Let's move to topic 13, which is
5 communications between the organization and any of
6 the co-plaintiffs, its individual member plaintiffs,
7 its other members, and other advocates or advocacy
8 organizations concerning this litigation or concerns
9 regarding vulnerabilities in electronic voting
10 systems.
12 correct?
13 A I am.
15 specifically to prepare for this aspect of the
16 deposition?
17 A No.
18 Q And did you speak with anyone associated
19 with CGG specifically to prepare for this topic?
20 A No.
21 Q So I am not asking -- I want to be clear,
22 I know Mr. Cross has reserved rights here, I'm not
23 asking communications where counsel was present or
24 where you had a common interest agreement that
25 prohibited disclosure, but has CGG communicated with

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1 other advocates and advocacy organizations about its

2 concerns with electronic voting equipment?
3 A Yes.
4 Q And were those communications in writing,
5 in person; how were they made?
6 A Well, there are going to be such a variety
7 of communications with other people, organizations,
8 advocates that about every kind of communication,
9 you know, phone calls, Zoom meetings, text messages,
10 e-mails, letters. We're talking about such a broad
11 topic here that, you know, there would be thousands
12 of such communications over the -- over the last
13 many years.
14 Q Understood.
15 What I want to do is ask you about a
16 couple in particular.
18 identification.)
19 BY MR. TYSON:
20 Q Marked as Exhibit 29, a Joint Litigation
21 and Common Interest Agreement between the Coalition
22 and Fair Fight Action and Care in Action.
23 Have you seen this document before?
24 A I'm sure I have, but probably not since
25 the date it was signed.

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1 Q Okay. And this is an agreement between

2 Fair Fight Action and CGG among others, right?
3 A Yes.
4 Q And it looks like it was signed in January
5 of 2019?
6 A Yes.
7 Q Has this agreement been terminated?
8 A You know, I don't know. That would be a
9 question for counsel that I don't know the answer
10 to.
11 Q Okay. Do you know if CGG still has a
12 common interest privilege with Fair Fight?
13 MR. MCGUIRE: I'm going -- we're going to
14 assert that we do still have a common interest.
15 These agreements have not terminated to my
16 knowledge, so we're going to continue to operate
17 under the assumption that they're operative.
18 And just wanted to -- if you're going to
19 get into specific communications, I did just want to
20 reiterate that document 1203, the order of the
21 Court, provides that State Defendants can ask
22 relevant questions about the substance of
23 conversations that plaintiffs have had with other
24 parties through the course of their advocacy work
25 generally, but that specifics the Court held would

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1 impinge on First Amendment rights, and so I just

2 want to reiterate that we are applying that holding
3 to ourselves as well, although it was obtained by
4 the Curling Plaintiffs, and so if you -- if you go
5 there, we have an objection on that.
6 BY MR. TYSON:
7 Q Do you understand that Fair Fight is no
8 longer pursuing its voting machine claims in its
9 case?
10 A That's my general understanding. I
11 haven't tried to confirm that by reading their
12 documents.
13 Q Okay. Have you had any communications
14 with Fair Fight Action or their representatives
15 since November of 2020?
16 A Trying to think about that for a moment.
17 It seems like I have had one conversation with one
18 of the Fair Fight employees, but I'm struggling to
19 remember what it was about. It seems like it might
20 have -- seems like it might have been upcoming
21 legislation, but I'm -- I'm just not sure.
22 Q Have you spoken with anybody at Fair Fight
23 regarding the outcome of the 2020 election?
24 MR. MCGUIRE: Excuse me. I'm just going
25 to interject and instruct my client to the extent

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1 she answers this question under document 1203

2 defendants are not permitted to ask the identity of
3 anyone with whom we've spoken. So you can answer
4 the question generally, but I would instruct you to
5 adhere to the order of the Court in document 1203
6 and keep it general.
7 A Okay. And, Mr. Tyson, do you mind
8 repeating the question?
9 BY MR. TYSON:
10 Q Certainly. Have you spoken -- had any
11 communications with anyone at Fair Fight Action
12 regarding the outcome of the 2020 election?
13 A Not that I recall right now. It's
14 possible, but I'm not recalling it.
15 Q Have you had any communications with
16 anyone at Fair Fight where they explained why they
17 were dropping their voting machine claims?
18 A No, I have not.
19 Q I'm going to direct you to what we marked
20 as Exhibit 30.
22 identification.)
23 BY MR. TYSON:
24 Q This is a Facebook advertisement from
25 friends of Coalition for Good Governance.

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1 Do you see that?

2 A I do.
3 Q And are you familiar with this
4 advertisement?
5 A I'm looking at it again to -- I don't know
6 whether -- well, I don't remember it, but maybe --
7 maybe I have seen it, maybe I haven't, but, yeah,
8 I'm generally familiar with the contents.
9 Q So who is the Friends of Coalition for
10 Good Governance there at the top?
11 A I actually don't know who controls that
12 site. There were several people who were working on
13 that at one time, and I cannot tell you all of their
14 names or who controls -- who controls that. I think
15 Aileen Nakamura is one of them, but I actually don't
16 know the others. I know she was working with some
17 friends, and I always meant to find out, and I never
18 got around to it.
19 Q Do you recall a Fair Fight Action matching
20 fundraiser that benefited CGG?
21 A I do recall that.
22 Q Okay. What was that about?
23 MR. MCGUIRE: I'm going to object to form.
24 A What was that about?
25 MR. MCGUIRE: I'm going to object to form

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1 on that question. It's vague, ambiguous.

2 BY MR. TYSON:
3 Q Can you answer, Marilyn? Ms. Marks, I'm
4 sorry?
5 A I'm not really sure what you're asking
6 what was it about.
7 Q Okay.
8 A I mean, I think, you know, to the extent
9 that this is accurate it -- it was about the fact
10 that they had offered to match funding that was
11 generated during that period for our -- for the
12 Curling lawsuit. I don't remember many details of
13 it at the moment, I'm afraid.
14 Q So the -- was there any formal agreement
15 between Fair Fight Action and CGG regarding this
16 matching fundraising effort?
17 A I think it was probably -- it certainly --
18 I don't remember any kind of -- I'm sure there was
19 no kind of contract, and it was probably just an
20 e-mail, if that. It might have just been a phone
21 call.
22 Q And Fair Fight Action raised funds that it
23 then donated to Coalition for Good Governance; is
24 that correct?

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1 Q And it was specifically to support the

2 Curling case, you said?
3 A As I recall that's what this ad says, but,
4 you know, as I sit here today, I don't know whether
5 they said, look, this is because you were doing the
6 hand-marked paper ballot or if it was more general
7 as to why they -- as to why they were helping us on
8 this.
9 Q And do you recall the reason why Fair
10 Fight offered to help on this, as you just said?
11 A Well, you know, I do think --
12 MR. MCGUIRE: Hold on. I'm going to
13 object to that because I think you're starting to
14 intrude into the common interest litigation
15 agreement. I'm going to instruct her not to answer
16 that unless I understand why it's not intruding into
17 that agreement.
18 MR. TYSON: Let me understand. You're
19 asserting the common interest privilege and
20 instructing her not to answer on that particular
21 question?
22 MR. MCGUIRE: As I understood your
23 question to be getting into her understanding of
24 their motivation, and I believe that's encompassed
25 within the scope of the common interest agreement.

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1 Litigation -- if we have common interest litigation

2 agreement with them, that would be within the scope
3 of that.
4 MR. TYSON: Okay. And just so we have a
5 complete record on that, you're taking the position
6 that fundraising efforts between the two
7 organizations is covered by the common interest
8 litigation agreement?
9 MR. MCGUIRE: Well, the motivation is what
10 you asked about, not -- I didn't object to the
11 questions about the fundraising arrangement, but I
12 did object to your question about the motivations.
13 MR. TYSON: Okay. Understood. And you're
14 instructing her not to answer?
15 MR. MCGUIRE: Yes, pursuant to that common
16 interest agreement and the privilege.
17 MR. TYSON: Okay.
18 BY MR. TYSON:
19 Q So just to clarify, Ms. Marks, the
20 donations were made to Fair Fight Action, and Fair
21 Fight Action transferred the funds to CGG, correct?
22 A I cannot comment on how the money came
23 into Fair Fight Action. I don't know that, but I
24 assume that it was Fair Fight Action that wrote the
25 check to us, but I'm not sure -- as I sit here

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1 today, I can't tell you which -- I'm taking this at

2 face value that it was Fair Fight Action as opposed
3 to some other Fair Fight organization that sent the
4 check.
5 I assume it was Fair Fight Action, but if
6 you're asking me do I remember what the check looked
7 like, no, but I believe it was Fair Fight Action.
8 Q So just so I'm clear, Fair Fight Action
9 has donated to CGG?
10 A I believe it was Fair Fight Action. It
11 was -- it was Fair Fight in one of its forms. I'm
12 just not remembering all of their various corporate
13 forms right now.
14 Q Okay. So either Fair Fight, Incorporated
15 or Fair Fight Action?
16 A Again, I don't know all of their corporate
17 names, but what I would just generally refer to as
18 "Fair Fight." I'm sure they did it in whatever ways
19 were appropriate for their various tax-exempt
20 statuses or not tax exempt. I didn't look behind
21 that. I just tended to think of it in terms of Fair
22 Fight without knowing which fund from Fair Fight.
23 Q Do you know approximately how much Fair
24 Fight or one of its affiliated groups donated to CGG
25 in 2019?

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1 A I don't remember. I was just trying to

2 think if I did remember. I don't remember.
3 Q Don't even remember a potential range?
4 A 2019? I am going to give a rough guess,
5 but it's only a rough guess at the moment, maybe
6 between 60- and 75,000.
7 Q And I'm assuming CGG would have records
8 that would reflect those donations?
9 A We do, but it's just not in my memory
10 right now.
11 Q Let me ask you along this line what I've
12 marked as Exhibit 31.
14 identification.)
15 BY MR. TYSON:
16 Q This is an e-mail that was produced to us,
17 communications -- and it doesn't have all the same
18 metadata, but you see the timeline is February 26,
19 2022, so recent communications, and there's a group
20 called State Audit Working Group. What is State
21 Audit Working Group?
22 A Okay. It is a volunteer group of experts
23 and semi experts from around the nation that really
24 focus on election auditing, and they have had a big
25 effort over the years in also providing advice to

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1 NIST, N-I-S-T, on election security as it relates

2 to -- as it relates to auditing.
3 And so it is a group that meets weekly
4 that I used to try to meet with weekly, but I now
5 maybe make one meeting every six months because back
6 to the requirements of this litigation and other
7 Dominion Voting System issues.
8 Q This is an e-mail that indicates it's from
9 you.
10 A Yes.
11 Q And I wanted to ask you about this
12 sentence: For some strange reason Fair Fight and
13 their colleagues claim that our goal is to sabotage
14 elections.
15 Do you see that?
16 A I do.
17 Q Where did you learn that Fair Fight and
18 their colleagues claimed that CGG's goal was to
19 sabotage elections?
20 A I didn't really mean that it's Coalition
21 per se, the goal. I'm talking about our goals in
22 promot- -- "our" more collective in promoting the
23 ballot -- excuse me, public -- public records --
24 sorry, that voted ballots become public records in
25 House Bill 993 and House Bill 1464, and that's what

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1 I was -- when I said "our goal," I was speaking more

2 generally than just Coalition for Good Governance
3 because I had been in contact with some of the
4 people here in the State Audit Working Group. It is
5 also their goal to see ballots as public records.
6 Q Let me ask the other page -- this is
7 another e-mail from you on Saturday, February 26,
8 and you say: Sadly, Fair Fight has gone ballistic
9 on this bill and calling those of us who promoted it
10 as attempting election sabotage.
11 You see that?
12 A I do.
13 Q So, again, is this a direct accusation
14 Fair Fight made against --
15 A No, no, it is the people who -- they were
16 making this -- I saw a press release that they had
17 made where they were talking about ballots as public
18 record or HB933 I think it was at the time as being
19 an election sabotage bill, and because we had
20 initiated that idea and promoted it last year and
21 this year, and that's what I was trying to say here,
22 those of us who promoted it as attempting election
23 sabotage as I recall, and I'm sure this is not a --
24 not a direct quote at all, the press release was
25 something about those people who are promoting H

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1 Bill -- HB933 or the ideas behind it are trying to

2 sabotage our elections. I think they actually
3 called it election sabotage bill.
4 Q Have you spoken with anybody affiliated at
5 Fair Fight about --
6 A No.
7 Q -- that allegation?
8 A No.
10 identification.)
11 BY MR. TYSON:
12 Q I've marked another exhibit here as
13 Exhibit 32. This is an e-mail begins with you and
14 Kate Brumback but is an e-mail you sent to
15 Mr. Stark -- Dr. Stark, Dr. Halderman, Mr. Hursti,
16 Dr. Buell, Dr. Demillo, Dr. Appel, Mr. Skoglund, and
17 Ms. Greenhalgh; is that correct?
18 A Yes, it looks correct.
19 Q Do you recognize this e-mail?
20 A I don't remember it right now. I'm sure
21 it's legitimate. I'm just not remembering it off
22 the top of my head.
23 Q And this is referring to a petition, and
24 it appears that it's titled Voterga Philip Singleton
25 Dominion Ban Petition Roswell, Georgia, and the

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1 subject line is, Garland's New Lawsuit Against BMDs.

2 A Uh-huh.
3 Q What is -- do you know what that's
4 referring to?
5 A Yes, Voterga and Representative Singleton
6 filed that lawsuit in -- I believe it was Fulton
7 Superior Court trying to ban QR codes on ballots.
8 Yes, it was Fulton Superior Court, and, yes, that's
9 what they were trying to do.
10 Q And it looks like you sent this e-mail
11 directly to various -- mostly experts in this case,
12 not all. Is that -- is that the group you were
13 sending this e-mail to; is that accurate?
14 A It looks that way. I don't particularly
15 recall it, but that's what the header would appear.
16 Q Okay. Is it your practice to regularly
17 communicate with the experts in this case without
18 counsel on the e-mail?
19 A Well, I was not communicating with them in
20 their role as experts. Many of them were people
21 that I have communicated with on election matters
22 for probably the last 10 years. So I was not
23 communicating with them, you know, in some kind of
24 expert advisory role.
25 Q Okay. And so if you weren't communicating

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1 with them in their expert advisory role, what are

2 you -- why are you communicating with them at all on
3 this topic?
4 A Well, I mean, those of us who live in
5 Election Integrity Land all the time, you know, tend
6 to share information about all sorts of topics, and
7 so communicating with these people and the broader
8 group is not unusual on election-related topics.
9 Q Has CGG communicated with Mr. Favorito and
10 his Voterga group about his claims in this case?
11 A In which case?
12 Q In this case.
13 A I'm sorry, about our claims, okay. Oh,
14 gosh, not in a long time, we have not. Don't
15 remember the last time I talked to him.
16 Q Has any representative of CGG talked to
17 Mr. Favorito or Voterga?
18 MR. MCGUIRE: I'm going to object again.
19 Bryan, I think this is the stuff that's covered in
20 document 1203, the order from the Court about
21 specific communications being not something that
22 plaintiff should be required to answer.
23 MR. TYSON: And to be clear, my question
24 is just did communications take place, not with whom
25 or how. With that scope would you allow her to

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1 answer?
2 MR. MCGUIRE: I would not because footnote
3 1 on page 5 of document 1203 says State Defendants
4 are not permitted to ask the identity of anyone with
5 whom the Curling Plaintiffs spoke about these
6 topics, and I believe when you're asking if a
7 communication occurred, I think it falls within the
8 scope of that.
9 MR. TYSON: Okay. So will you have
10 similar objections to asking about Sidney Powell,
11 Lin Wood, and Mike Lindell and their
12 representatives?
13 MR. MCGUIRE: As far as identifying
14 individuals who we've communicated with, I think it
15 falls within the scope of that order, and I don't
16 want to take inconsistent positions vis-a-vis people
17 we have contacted and people we haven't contacted,
18 so I'm just going to take a uniform position and say
19 I'd like us just to adhere to the order and not ask
20 about specific individuals but keep the questions
21 general like the Court ordered.
22 MR. TYSON: So just so the record is clear
23 then, let me just go ahead and ask about each one,
24 and you can object, and instruct her not to answer.
25 BY MR. TYSON:

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1 Q Has anyone affiliated with CGG

2 communicated with Mr. Favorito in Voterga about
3 vulnerabilities in electronic voting machines in the
4 last 12 months?
5 MR. MCGUIRE: Why don't we just do a
6 standing objection to this. If you're asking a
7 question that's got a person's name in it and
8 whether we've talked to them, I think it violates
9 the Court order in 1203, I would object to it on a
10 standing basis.
11 MR. TYSON: On a standing basis, okay.
12 And just so the record is complete, we were also
13 going to ask similar questions about Sidney Powell
14 and her representatives, Lin Wood and his
15 representatives, Mike Lindell, My Pillow, and their
16 representatives, and I understand you have a
17 standing objection, so just have the record clear on
18 that.
19 MR. MCGUIRE: Yeah. And just to clarify
20 my position, given that this is a court order and
21 given that it pertains to First Amendment rights,
22 that's the basis for our objection, and I don't want
23 my objection -- my objection is not offered as any
24 sort of confirmation that any of those
25 communications have occurred. I'm simply objecting

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1 to the question based on the Court's order.

2 MR. TYSON: Understood.
3 BY MR. TYSON:
4 Q Let's move to topic number 14. That is
5 the organization's knowledge of any person in the
6 state of Georgia that was not able to vote as a
7 result of the laws, policies, and protocols
8 complained of in this action. And you're the
9 designee for topic 14, Ms. Marks?
10 A I am.
11 Q Did you review any documents specifically
12 to prepare for this part of the deposition?
13 A I some time ago thumbed through some of
14 the declarations and reviewed them, but it was not
15 in the last 24 hours. It was probably in the last
16 week or so, two weeks.
17 Q And so the only documents you reviewed are
18 declarations that were filed in this case; is that
19 correct?
20 A For -- yes.
21 Q And did you speak to anyone associated
22 with CGG specifically to prepare for this topic?
23 A Not other than what we've already talked
24 about, the general conversations that I had with the
25 people we talked about and named previously today.

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1 Q Does CGG know of any person in the state

2 of Georgia who was not able to vote as a result of
3 the State's use of the Dominion BMDs?
4 A Dominion BMDs. Because of the State's use
5 of Dominion BMDs. If we are limiting the question
6 to because of the State's use of BMDs, no, I do not
7 know anyone who was unable to vote for that reason.
8 Q Does CGG know of any person in the state
9 of Georgia who was not able to vote because of the
10 lack of audits CGG claims are necessary?
11 A We don't claim that audits are necessary
12 in order to be eligible to vote, but we don't know
13 anybody who was turned away from being able to vote
14 because of inadequate audits.
15 Q Does CGG have knowledge of any voter whose
16 votes -- sorry, I just asked that question.
17 Let's move to -- actually, one more on
18 this one. Does CGG have knowledge of any voter in
19 the state of Georgia who was not able to vote as a
20 result of the use of Dominion scanners?
21 MR. MCGUIRE: I'm going to object to form
22 because it's, I think, vague, ambiguous.
23 A That question doesn't really sound too
24 logical to me. I don't know how it could be that a
25 scanner would keep someone from voting, but no, I

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1 don't know of a scanner that has -- I don't know of

2 a person that a scanner's existence caused not to be
3 able to vote.
4 BY MR. TYSON:
5 Q Let me ask it this way: Does CGG have
6 knowledge of any voter whose vote was not counted as
7 a result of the use of Dominion voting equipment?
8 A Yes.
9 Q And who is that voter or voters?
10 A Okay. So I think we -- we start with
11 Donna Price. As I understand it her ballot was not
12 accepted for voting in the Dominion system that -- I
13 don't know exactly the reason why, but I believe
14 it's probably a problem with the electronic -- the
15 electronic records, the ENET system, but that's one
16 voter I know of who wasn't able to vote.
17 You know, we do know of many voters who
18 had to cast provisional ballots. When people cast
19 provisional ballots, then many of the votes which
20 they are eligible to vote, they are not -- they are
21 not able to vote because it's not on the provisional
22 ballot that they are given. And so while they may
23 have engaged in the act of voting, it does not mean
24 that they were able to vote all of the eligible
25 contests that they attempted to vote.

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1 Then we certainly don't know of the

2 person's name because of the secret ballot, but we
3 certainly know of ballots that were cast and not
4 counted for all of the votes because of ballot
5 scanner inadequacy and it not picking up all of the
6 marks on the ballot.
7 We certainly know of what appear to be
8 thousands of ballots we do not know who actually
9 completed those ballots because of secret ballot
10 requirements, but we know that many of them exist in
11 the home precincts of several of our members and
12 plaintiffs where the votes were not counted by the
13 BM- -- excuse me, the Dominion Voting System. And
14 so -- in, again, the home precincts of our members
15 and plaintiffs. So, yes, there are wide variety of
16 votes that were not counted.
17 Q And what I'm asking specifically is CGG's
18 knowledge of the identity of voters, and I believe,
19 based on what you said, the only voter you can for
20 sure identify is Ms. Price; is that correct?
21 A We would need to go back and look at
22 people who were required to vote provisional ballots
23 and to see what -- and required to vote provisional
24 ballots because of errors in the pollbook system,
25 for example, to see --

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1 Q Is it your custom -- I'm sorry.

2 A -- to see what contest they were eligible
3 to vote and were not able to vote because of casting
4 a provisional ballot because of a problem with the
5 system.
6 Q Is it your testimony that the Poll Pads
7 are Dominion voting equipment?
8 A Yes.
9 Q Are they manufactured by Dominion?
10 A I don't think Dominion manufactures any of
11 their own equipment, but they are certainly
12 encompassed in our definition of the Dominion Voting
13 System, the Poll Pads are.
14 Q Then let me just make sure we're all on
15 the same page here. So does CGG have any knowledge
16 of the identity of any voter whose vote was not
17 counted as a result of the use of Dominion BMDs,
18 Dominion precinct scanners and Dominion central
19 count scanners, and the Dominion electronic
20 management system?
21 A I'm thinking about that for just a moment.
22 In terms of specific identity for particular ballots
23 that we know were not counted, while we can go back
24 to the home precincts, I don't think we know of any
25 particular voter whose ballot we can identify -- we

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1 wouldn't -- we wouldn't go so far as to identify if

2 we could -- that was -- that was not counted.
3 In fact, I have heard some people talk
4 about that they believe that their write-in votes
5 for qualified candidates were not counted, and we
6 have actually hesitated to go try to do the research
7 to find out, which we probably -- we might be able
8 to do, but we've hesitated to do it because we felt
9 like that was too much intrusion on ballot secrecy.
10 Q We've been going on for a little while,
11 Ms. Marks. Do you want to take another quick break?
12 A If you wish. How much time have we been
13 on the record?
14 MR. TYSON: We can go off the record.
17 (Recess 5:30-5:36 p.m.)
20 BY MR. TYSON:
21 Q Thank you, Ms. Marks. I have consulted
22 over the break here to try to streamline this a
23 little bit and make this a little bit easier to skip
24 over a few things that we've pretty much covered, so
25 I'm going to skip ahead to topic number 19.

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1 A Okay.
2 Q Topic 19 is all factual and legal
3 contentions of the organization in relation to this
4 case, including but not limited to the contentions
5 of the organization concerning the 2020 elections
6 and the January 2021 runoff in Georgia.
7 And you're the designee for topic 19,
8 correct?
9 A Correct.
10 Q Did you review any documents to get ready
11 for this part of the deposition?
12 A I review documents related to the 2020
13 election, you know, 17 hours a day, seven days a
14 week, so it's hard to say -- it wasn't done
15 specifically for this deposition, but I'm certainly,
16 you know, working with those documents all the time
17 that would prepare me for this deposition. Not so
18 much on the January 2021. I've not done a whole lot
19 of work on that -- the details of that election, but
20 certainly the legal contentions, yes.
21 Q Okay. Thank you.
22 So did you speak to anybody in preparation
23 for this particular topic?
24 A Well, it kind of goes back to my first
25 answer. I speak to dozens of people every day about

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1 this -- this topic. So I talked to nobody other

2 than counsel about -- about this topic as described
3 here.
4 Q Okay. Thank you. That's helpful.
5 All right. So is it CGG's contention that
6 it is impossible to know whether Joe Biden got more
7 votes than Donald Trump in the state of Georgia in
8 the 2020 presidential election?
9 MR. MCGUIRE: Can I just object for a
10 moment. I just want to reiterate the objection we
11 have made to the topic to the extent that it calls
12 for legal conclusions by a lay witness, and,
13 secondly, obviously this is a
14 1300-plus-docket-entry-length case, and it's an
15 unreasonable burden to prepare a witness on every
16 single factual contention in that volume of paper.
17 So I just want to make sure that objection
18 is on the record, and her preparation has been
19 constrained by that objection.
20 So with that, go ahead if you can answer.
21 BY MR. TYSON:
22 Q You can answer.
23 A Do you mind asking me that question again
24 because the question was kind of confusing, and I
25 may need more clarification from you?

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1 Q Sure. Maybe I can approach it this way,

2 it is CGG's contention that Dominion BMDs are
3 inherently unauditable, correct?
4 A That's correct.
5 Q Is it CGG's contention that because of the
6 unauditable nature of the Dominion BMDs, it is
7 impossible to know accurate vote totals for
8 elections conducted in Georgia?
9 A Unfortunately, I'm going to need you to be
10 a little bit more precise because I don't want to
11 give you a misimpression.
12 When you say "accurate vote totals," we
13 can certainly do the arithmetic on the paper that
14 comes out of the BMDs, and somebody could eventually
15 figure out the correct arithmetic, but I'm not sure
16 that was the question you were asking me.
17 If you were asking me does -- do the
18 election totals reliably reflect what the voters may
19 have entered as their vote, that's a different
20 question.
21 So if you could be more precise with me,
22 that would be helpful.
23 Q Certainly. There's probably an easier way
24 to do this. Let me mark Exhibit Number 33.

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1 identification.)
2 BY MR. TYSON:
3 Q Do you see -- this is another Twitter
4 thread from your MarilynRMarks1 account?
5 A Yes. Does this have a date on it?
6 Q This is January 1, 2021.
8 Q And what I'm trying to get to is someone
9 responded and said South Carolina and Kentucky are
10 the states that should be audited, and you said:
11 South Carolina is like Georgia. It uses unauditable
12 BMD touchscreen machines. We can never ever know
13 who won in South Carolina or Georgia because of the
14 use of those machines in the polling places.
15 A Correct.
16 Q You see that?
17 A I do.
18 Q Do you agree with that statement?
19 A I do.
20 Q Is CGG's contention that we can never
21 know -- is it -- sorry, let me start over again.
22 Is it CGG's contention that we cannot know
23 who won in Georgia because of the use of Dominion
24 BMDs in the polling places?
25 A Yes. And when we say "who won," what I

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1 mean by that, and, of course, you know working with

2 a short Twitter message is hard to get all the
3 nuances in, but when I say "who won," what we mean
4 by that is we do not know who the voters voted for,
5 and that's what we mean by who won. We do not know
6 who the majority or the plurality of the voters
7 voted for in Georgia.
8 Q So it is CGG's contention then that it is
9 impossible to know whether more voters intended to
10 vote for Joe Biden than Donald Trump -- I'm sorry,
11 reverse of that. It is CGG's contention that it's
12 impossible to know whether more voters attempted to
13 vote for Donald Trump in the November 2020 election
14 in the state of Georgia than voted for Joe Biden,
15 correct?
16 A Well, that's true for any of the
17 candidates, including Biden, Trump, Jorgensen, that
18 that is correct that -- and that's what we've been
19 saying since before these BMDs were purchased long
20 before the 2020 election.
21 Q And so it's also the case then --
22 actually, let me ask this: Is it CGG's contention
23 that individuals who question the outcome of the
24 November 2020 election have a reasonable basis for
25 doing so?

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1 A Well, I guess you're going to have to be

2 way more specific --
3 Q Okay.
4 A -- on, you know, quote, questioning the
5 outcome. We certainly do not condone the actions of
6 some of the people you mentioned earlier today that
7 you wanted to ask me about whether or not we've been
8 in contact, people like Garland Favorito and Mike
9 Lindell and Sidney Powell and whoever else was on
10 that list, we certainly do not condone those actions
11 at all, and I should say ever so strongly that we --
12 we do not support that kind of questioning of the
13 election.
14 And, you know, while we are very
15 uncomfortable with the way that the election was
16 conducted, and we've spent massive amounts of time
17 going through details of the election records, we
18 have found nothing that is recorded in the records
19 that would suggest that the outcome was wrongly
20 decided based on Georgia's processes.
21 But what we know, of course, is that we
22 will never know what the voters actually intended to
23 enter into those voting machines.
24 We do know how they voted on the
25 hand-marked paper ballots. I say we do know. Now,

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1 many of the records are missing, but at least we do

2 have a record, and that could be determined.
3 Q So just -- just so I'm clear, that was a
4 long answer, I want to make sure I understand CGG's
5 contention about this.
7 Q If an individual relying on CGG's reasons
8 for questioning elections conducted on BMDs
9 questioned the outcome of an election, you would
10 agree that person had a reasonable basis to do so,
11 right?
12 A I'm not going to tell you that as a
13 blanket proposition, no. Let's say that we had an
14 election that used, I don't know, 15 percent BMDs
15 and most people voted by mail and somebody
16 challenged the election, I would not make a blanket
17 statement that there was a reasonable basis to
18 challenge. It certainly depends on the
19 circumstances. You have to be really -- you have to
20 look at all the facts before we can say there was a
21 reasonable basis for challenging.
22 I mean, you mentioned Garland Favorito.
23 Some of the wild claims that he is making,
24 absolutely there's no reasonable basis in it, and,
25 in fact, there are a bunch of lies coming out.

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1 That's -- no, that's not reasonable.

2 Q Does CGG question the outcome of the
3 November 2020 presidential election?
4 A No, I don't think you would have ever seen
5 us question that. I think we have been consistent
6 before, during, and after this election, and before
7 the election we said, just as with all BMD
8 elections, we will never be able to know the
9 outcome.
10 We've said that -- we've said that since
11 before the BMDs were ever even purchased that
12 because of the design we would never be able to
13 assure ourselves of the outcome of any election
14 primarily conducted with BMDs. We would say the
15 same, of course, of the November 2020 election and
16 all before and after elections, and -- oops, wait a
17 minute. I messed up my screen just now. Hold on.
18 Okay. I'm back.
19 But as it -- and as I say, we've been
20 quite consistent. We have huge objections to the
21 massive errors in the audit and the massive
22 tabulation errors, but still, given the work we've
23 done today, and it's not definitive, we have not
24 seen anything that, based on Georgia's method of
25 tabulating votes, that would change the outcome.

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1 Not a basis for challenging the outcome of the

2 presidential election.
3 Quite frankly, we have not -- if you were
4 talking about the presidential election. I'm
5 assuming you were talking about the presidential
6 election.
7 Q I was. I'm sorry.
8 A But if you were talking about some of the
9 down-ballot elections, we haven't done enough work
10 to know. We do know that there was significant
11 double and triple counting of votes in many of the
12 down-ballot elections, but we have not gotten far
13 enough in our work to know whether it would have
14 changed the outcome of any of those down-ballot
15 elections.
16 Q And I'm trying to understand the position
17 of CGG because what I hear you say is there's no --
18 we're not questioning the outcome of the November
19 2020 election because there's no evidence to the
20 contrary, but isn't CGG also saying that there
21 cannot be evidence of the contrary because the
22 machines don't preserve evidence of voter intent?
23 A No, I think you're mixing a bunch of
24 subjects here because you're trying to talk about
25 the election in total and whether or not there is a

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1 basis for contesting the outcome of the election and

2 then the operation of the BMDs as one sliver of it.
3 So if you don't mind, ask me the question
4 again, and I'll try better to understand your exact
5 question.
6 Q Sure. And to be clear, I'm not asking for
7 election contests. I'm asking --
8 A Okay.
9 Q I'm asking specifically about if an
10 individual relying on CGG's position about the
11 unauditable nature of the Dominion BMDs --
12 A Yes.
13 Q -- has doubts about whether Joe Biden won
14 the state of Georgia in November 2020, are those
15 concerns valid?
17 A Yes, I think that they are valid not only
18 for Joe Biden, but all the way up and down the
19 ballot for every ballot that was cast from the time
20 we, the State of Georgia, adopted BMDs until -- I
21 think there was an election Tuesday, wasn't there,
22 somewhere in a special election Tuesday or close to
23 it?
24 Anyway, all of those BMD-based elections,
25 yes, there is a reason to question whether the BMD

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1 results reflect the will of the voters, absolutely.

2 BY MR. TYSON:
3 Q And so is it CGG's contention that voters
4 in Georgia have a reasonable basis to question each
5 election conducted in Georgia as long as we use
6 Dominion BMDs?
7 A So long as Dominion BMDs are the primary
8 source of votes cast, yes.
9 Q Let me ask you about some additional -- I
10 want to turn to the Coalition's request -- responses
11 to our request for admission about some of the
12 specific contentions. Let me find that real quick.
13 I'm sorry.
14 A Bryan, may I go back and just add
15 something to my last answer about trying to address
16 your question about the presidential contest,
17 presidential --
18 Q Uh-huh.
19 A Okay. What I'm trying to say is that
20 while you're asking about the presidential contest,
21 and we have seen a whole lot of errors in the entire
22 November election from the top of the ballot to tax
23 commissioner at the bottom, the system has so many
24 flaws in its operation right now that it is
25 reasonable to question any election contest on the

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1 November ballot and any election that was done from

2 the adoption of the BMDs through now, and we would
3 not make a particular distinction between the
4 presidential election and the tax commissioner
5 election.
6 I hope that's clearer than what I tried to
7 say before, which is very different from what you're
8 hearing Garland Favorito and Sidney Powell and those
9 characters say. Okay?
10 Q And essentially it's CGG's position that
11 you can't make the case that Garland Favorito and
12 Sidney Powell are making because the evidence
13 doesn't exist; is that correct?
14 A Do you mind -- do you mind saying that one
15 more time?
16 Q Uh-huh. Is it CGG's position that you
17 can't make the case that Mr. Favorito and Ms. Powell
18 are making that the election was stolen because the
19 evidence doesn't exist when Georgia elections are
20 conducted primarily on BMDs?
21 A Well, the claims that I hear them making
22 don't seem to have a lot to do with BMDs. They're,
23 like, crazy -- crazy stuff about everything from
24 Chinese televisions to mail ballot counter- --
25 counterfeited mail ballots, and, no, I don't believe

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1 any of that evidence -- I won't even call it

2 evidence. I don't think any of those things exist
3 as evidence, but I don't think that if we come back
4 to the theme of what we at CGG are working on, and
5 that is that the BMD system does not provide an
6 evidence-based election result.
7 Q Thank you. All right. Let me go to some
8 of the specific contentions about 2020.
10 identification.)
11 BY MR. TYSON:
12 Q So I've marked as Exhibit 34 the
13 Coalition's objections and responses to Secretary
14 Raffensperger's first request for admission.
15 You see that?
16 A Yes.
17 Q What I want to do is ask about a couple
18 specific ones related to November.
19 So request for admission number 12 says
20 admit that you have no evidence that any component
21 of the election system was actually hacked prior to
22 or during the elections held on November 3rd, and
23 that was denied.
24 Do you see that?
25 A I do see that. And do you mind showing me

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1 the date of this document?

2 Q Certainly. January 27th, 2021.
3 A Okay. And that is what we said at the
4 time?
5 Q Uh-huh. Is that a different answer today?
6 A I think it is a different answer today.
7 Q Okay. Why is it a different answer today?
8 A Because here we are, what, 14 months
9 later, and we now have pieces of evidence and
10 documents from the State Defendants as well as other
11 public records that we have obtained since that time
12 that would indicate that, in fact, there are
13 irregularities that could reasonably be attributed
14 to hacking.
15 Q And those irregularities affected the
16 November 2020 election?
17 A Yes.
18 Q So what irregularities are you referring
19 to that changes this answer for the Coalition?
20 A Okay. There are three general categories
21 for this, and so I don't want to forget them. Let
22 me just make myself a note.
23 Okay. The first, and it is really the one
24 that has come to my awareness most recently, and
25 that is that it appears that in, perhaps, mid

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1 November that unauthorized access was given to

2 people in Coffee County, Georgia mid November --
3 excuse me, mid November 2020, I didn't mean more
4 recent. In mid November 2020 unauthorized access
5 appears to have been given to people after the
6 original count of the election was performed and the
7 hand audit in Coffee County which appeared to prove
8 out the arithmetic without a problem of one vote
9 difference, and then the third week of November
10 appears that there was unauthorized access, and
11 then, at least according to the public records, it
12 appears that there were problems with the
13 tabulations caused by what's alleged to be a
14 systemic problem in the machine re-count. And so
15 there is a question as to whether that unauthorized
16 access created the tabulation errors.
17 Q Is that -- is that number 1 of 3 or is
18 that all?
19 A That's 1 of 3. I'm so sorry, yes, that's
20 1 of 3.
21 The second would be the nature of the
22 double- and triple-counted votes that happened in
23 many counts, but I know more about them in Fulton
24 because I spent way more time looking at them in
25 Fulton than I have in other -- in others.

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1 Now, the Fulton Election Board has said

2 that they did not double scan or triple scan any
3 significant number of ballots. They say it was
4 only, like, a hundred. And I believe that that's
5 consistent generally with what the Secretary of
6 State's witnesses have said, that it was a very
7 limited number of ballots that they are aware of
8 being double scanned. That leaves us with thousands
9 of ballots that we know we have images that were
10 double and triple counted.
11 So if they're not being scanned, there is
12 some other type of electronic systemic error or
13 manipulation that is going on that's causing the
14 double and triple counting of votes.
15 Then the third would be something similar
16 to the second, and that is there are thousands of
17 ballot images that are shown to be counted in the
18 first count -- the first machine count that were not
19 counted in the second machine count and vice versa.
20 And I'm sure I didn't explain that well,
21 but, you know, that you can take the sets of ballot
22 images and compare them and find in the population
23 of ballot images for the first count mismatches in
24 the second count.
25 So we for short call them strays where

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1 they don't have a partner in the other account.

2 Sometimes they're in one and not two; sometimes
3 they're in two and not one.
4 Fulton County has essentially said, no, we
5 scanned only one ballot and only once, and if they
6 are correct in that, there is something causing that
7 is causing it to look like there was electronic
8 manipulation to create all of the irregularities in
9 the vote count. Those are my three.
10 Q Okay. So for each of those three would it
11 be correct to say they are irregularities that could
12 be caused by hacking, but CGG doesn't know for sure?
13 A Of course we do not know for sure because
14 there would be, you know, forensic analysis that's
15 not been permitted and not been undertaken that
16 would be required to know exactly how those
17 irregularities came to be.
18 Is it a mechanical problem, is it a -- a
19 software issue that was built into the system, is it
20 a change that -- that a malicious user or an insider
21 did, and then which of those -- which of those fall
22 in the definition of hacking.
23 Q And so is it CGG's contention that those
24 three categories in Mr. Lamb's evidence of the KSU
25 server are evidence of hacking that CGG has related

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1 to Georgia election systems?

2 A Those are the primary things that come to
3 mind right now, and, quite frankly, we have so --
4 there have been -- we have so many troublesome
5 documents, in the millions of images and stuff that
6 we have, we could have evidence in our hands that we
7 have not yet figured out created a problem.
8 So I'm saying those are the four things
9 that are primary that I know of today. And, you
10 know, some of them I didn't know of until very
11 recently.
12 Q And so going to request for admission
13 number 12, would those same four categories of
14 evidence be the evidence CGG has about malware being
15 actually inserted into any component of the election
16 system prior to or during elections held on November
17 3rd, 2020?
18 A Let me think about that for just a minute,
19 see if I can -- see if I'm leaving anything out.
20 Those four topics are the only things I
21 can think of right now that would be -- would be
22 signs of irregularities that could be caused by
23 malware.
24 I am not declaring that all of those
25 things were malware, I can't do that, but it is a

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1 reasonable -- it is a reasonable possibility,

2 particularly given Fulton's position that it was
3 not, for example, double scanning, and they did
4 count all the ballots that they had.
5 Q Let me go to request for admission 14.
6 There Coalition was asked to admit that you have no
7 evidence that any votes in the presidential election
8 held on November 3rd, 2020, in Georgia were actually
9 switched from President Trump to Joseph R. Biden,
10 Jr. as a result of an anomaly in the software used
11 in the election system.
12 What evidence does CGG have that a
13 software anomaly switched votes from President Trump
14 to President Biden?
15 A I'm rereading the question and trying to
16 remember here. Just a second.
17 I'm having a hard time remembering what we
18 might have been -- what examples we might have been
19 thinking about when we said denied. I'm sure the
20 minute this deposition's over I'm going to remember
21 that.
22 I'm wondering if we might have been
23 looking at the flawed audit tallies and some of the
24 flawed hand -- hand audit counts that were in the --
25 that were done, as you recall, in the second week of

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1 November hand tallies where, in fact, what was

2 showing up in those audits did appear to be
3 different and in some cases flipped from what was
4 recorded in the machines.
5 Q And is that the only item you're aware of
6 that relates to a software anomaly?
7 A It's what I'm remembering right now. I'm
8 afraid I'm forgetting something on this, but it's
9 what I'm remembering right now we must have been
10 talking about.
11 Q Go to request number 29. Coalition was
12 asked to admit that you have no evidence there was
13 any mismatch between the QR codes on the paper
14 ballots cast in the presidential election held on/in
15 Georgia on November 3rd, 2020, and the human
16 readable portion of the paper ballots, and there was
17 a denial of that.
18 What evidence does Coalition have of a
19 mismatch between QR codes and the human readable
20 portion of the ballot?
21 A Trying to remember what may have been in
22 our minds when we answered this question. Mismatch
23 between the QR code. I'm sorry, I just don't
24 remember right now. I don't have any evidence off
25 top of my head that relates to mismatch between the

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1 QR code and the human readable text, but I'll be

2 happy to supplement my answer when I remember it.
3 Q You need to take a break now so you
4 can investigate?
5 A I'm probably not going to remember in the
6 next five minutes, but --
7 Q Well, this is a 30(b)(6) deposition, so if
8 you want to take a pause to investigate, we can do
9 that.
10 A It may just -- it may take a while. Is
11 there an alternative for me to get back to you later
12 if I can remember what this is?
13 Q Who would you call to verify this
14 information?
15 A I would probably call Bruce Brown and get
16 him to remind me of his notes.
17 Q Okay. We can always suspend at the end
18 and come back if we need to, so that could be an
19 alternative.
20 A Okay.
21 Q Let me go next to topic number 20, which
22 is the organization's knowledge of any ballot
23 altered, not counted or otherwise impaired by use of
24 the Dominion BMD system in Georgia, and you are the
25 designee for this topic as well, correct?

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1 A I am, yes.
2 Q Did you review any documents to prepare
3 for topic 20?
4 A Certainly, I deal with November -- mainly
5 November 2020 ballot issues every single day, but
6 not necessarily specifically for the purpose of
7 preparing for this. I feel prepared for this based
8 on the work that I do every day.
9 Q And so did you speak with anybody
10 specifically for this topic as well?
11 A I speak to people on this topic all the
12 time, but not for the specific purpose of preparing
13 for this deposition.
14 Q Does CGG have any evidence, any ballots
15 generated by a BMD in the November 2020 election
16 that were not counted by the Dominion system?
17 A Yes.
18 Q And what evidence is that?
19 A That is the number three thing that we
20 were talking about a few minutes ago where I called
21 them strays at the time where we have ballots that
22 are counted in machine -- we call it machine count
23 1, and the re-count we call machine count 2, but --
24 so we have ballots in both of those election counts
25 that were not counted in the other official count.

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1 So, yes, we do have -- we do have evidence of that.

2 Q Does CGG have any evidence of any ballot
3 generated by BMD that was altered by the Dominion
4 system?
5 A I can't quite envision how I would ever
6 know whether the thing was altered by the Dominion
7 system because all we have are -- are the ballot
8 images that were produced by the Dominion system.
9 We would have no way of knowing what the guts of the
10 BMD did to the choices on that ballot.
11 And other than not counting them
12 correctly, no, I don't have -- all I can envision is
13 something you're talking about that would suggest
14 that the ballot image has been altered by the system
15 itself. Not that I'm aware of, but, again, we do
16 not know the cause of why some of these images
17 appear two and three times and are counted multiple
18 times. And does that come from ballot alteration, I
19 don't know.
20 Q And you don't have any evidence one way or
21 the other right now, right?
22 A We know they weren't counted, or in other
23 cases counted two and three times, but whether or
24 not it is because a BMD ballot was altered -- using
25 the altered, I don't know that. It would seem to be

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1 some kind of systemic problem.

2 Q Now, CGG responded to a December 30th,
3 2020, Senate Judiciary Subcommittee hearing posting
4 a transcript with some comments online. Do you
5 recall that?
6 A I don't, but I'm sure if you say so it
7 happened, but I don't recall it right now.
9 identification.)
10 BY MR. TYSON:
11 Q So I marked --
12 A I do recall it.
13 Q Exhibit 35, this document is a rough
14 transcript with comments by Marilyn Marks, Coalition
15 for Good Governance in blue; you see that?
16 A Yes.
17 Q And you prepared this document?
18 A I prepared at least my comments; otherwise
19 it was probably an automated transcript that we
20 would have produced -- excuse me, that we would have
21 created. It was probably edited by an intern, and I
22 probably put in whatever is in blue font which we
23 haven't seen yet.
24 Q Got it. I just want to ask a few
25 questions about this. Mr. Hutton-Pulitzer makes the

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1 allegation that he would be able to tell if the

2 ballots were folded, if they were counterfeit,
3 whether they were filled out by human hands, whether
4 they were printed by a machine, whether they were
5 batch fed continually over and over, we can detect
6 every bit of that. Do you see that language?
7 A I do.
8 Q Then CGG in blue responds: There is no
9 credible allegation of ballots being repeatedly
10 scanned to add more votes.
11 Do you see that?
12 A I do.
13 Q And do you no longer agree with that
14 statement today?
15 A Well, of course, this was written before
16 we were able to obtain all of the ballot images that
17 show double -- because we did not get those until
18 July, and -- excuse me, it might have been late --
19 sorry, I think it was late June of 2021, and we were
20 not aware of the double and triple counting until we
21 did analysis work on that. But, now, what he is
22 saying, he -- what I was saying here is repeatedly
23 scanned to add more votes.
24 I don't know that we have seen anything
25 that says that the double and triple counting is

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1 coming from repeated scanning, but I'm guessing --

2 whether they were batch fed continually over and
3 over.
4 You know how they have these ridiculous
5 allegations of State Farm Arena-located employees
6 double and triple and quadruple scanning ballots to
7 add more votes. We know that is not correct. We
8 know the very limited number of ballots that were
9 double scanned during that time, and it is a small
10 number of ballots, but we did not know about that at
11 the time that I wrote this. We did not know of any,
12 but we do know now it was a limited number.
13 Q So let me go --
14 A So that comment is out of date. It's not
15 current.
16 Q Okay. So this statement was made before
17 CGG had made an investigation into whether there was
18 ballots being counted more than once?
19 A Yes. And, again, I would make a big
20 distinction between what he's talking about and the
21 scanning that took place at State Farm Arena which
22 we think that the errors were quite limited to
23 double and triple counting of much greater numbers.
24 Q Go to one other statement on here that I
25 want to ask you about on page 14. So there is a

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1 kind of extended discussion about scanners. I just

2 want to ask you about comments in blue.
3 CGG says: We have tested the scanners on
4 many barcoded ballot-on-demand ballots and have not
5 seen any systemic counting errors related to the
6 barcode or alignment. We've heard of none reported
7 by others. Is Pulitzer saying he had some evidence
8 of a vote count problem; do you see that?
9 A I do.
10 Q And does CGG still agree with that
11 statement today?
12 A So I believe that the focus -- I mean, I
13 am barely remembering this, but I believe the focus
14 of that was he didn't understand why there were
15 barcodes on some of the paper hand-counted
16 ballots -- it's not hand counted, I'm sorry,
17 hand-marked ballots, and, of course, they were from
18 the ballot-on-demand printer, which were not coming
19 from the commercial printer, and he was making some
20 big deal about the barcoded ballots being different.
21 I think he even said some crazy thing like the
22 Republican ballots only had barcodes. I have
23 forgotten what it was, but his focus was the
24 barcode.
25 My point here was saying we have not seen

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1 any problem with the ballot-on-demand ballots being

2 any different than any other ballot.
3 That was -- that was the focus of that.
4 And to this day I don't believe we have found any
5 issue related to the printing of the barcode at the
6 top right corner of the ballot.
7 Q Thank you.
8 With that, let me go to topic number 22,
9 which is the organization's review of expert reports
10 produced in this case, including, but not limited
11 to, the expert reports of Dr. J. Alex Halderman.
12 Do you see this topic?
13 A I do.
14 Q And you are the designee for this topic,
15 correct?
16 A Yes.
17 Q Have you personally read the sealed report
18 of Dr. Halderman?
19 A No, I have not, of course.
20 Q Has any representative of CGG read the
21 sealed report of Dr. Halderman?
22 A When you say representative, the only
23 people that I'm aware of that have had access to
24 that report associated with CGG are our attorneys
25 and our experts in the case. Certainly not me,

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1 certainly not our directors, certainly none of our

2 members that I'm aware of.
3 MR. TYSON: Let's go off the record for
4 just a minute.
7 (Recess 6:22-6:32 p.m.)
10 MR. TYSON: Good afternoon again,
11 everybody. I wanted to briefly clarify one point
12 before we get started again.
13 BY MR. TYSON:
14 Q Ms. Marks, we were looking at Exhibit 34,
15 the request for admission, and I believe you
16 indicated that the answer to number 11 would have
17 changed, but the testimony as we talked through it,
18 in fact, you were discussing that the Coalition --
19 you discussed the Coalition's evidence of an actual
20 hacking which would make the answer of denied the
21 correct answer.
22 So is it correct that the answer to number
23 11 request for admission has not changed based on
24 your testimony?
25 A That's correct, we were saying there is

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1 evidence.
2 Q Thank you.
3 MR. TYSON: Mr. McGuire?
4 MR. MCGUIRE: Yes. I also wanted to put
5 on the record that Mr. Tyson and I spoke off the
6 record during the break about the questions he had
7 attempted to ask earlier regarding Ms. Marks's
8 conversations, whether she had conversations or
9 anyone from Coalition had conversations with Sidney
10 Powell, Lin Wood, Mike Lindell, Garland Favorito.
11 We invoked document 1203 which has been entered by
12 the Judge in this case as prohibiting those
13 questions, but in the off-the-record time I offered
14 that Ms. Marks was willing to answer those questions
15 provided it didn't waive the protection of that
16 order 1203.
17 And Mr. Tyson and I -- Mr. Tyson said that
18 his team agreed that those questions were not
19 appropriate under the order, and, therefore, he
20 wouldn't ask them anyway. And so we wanted to put
21 this on the record so that it's clear that we were
22 willing to answer those questions in the negative.
23 Thank you.
24 MR. TYSON: Yes, and that's correct.
25 Thank you, Mr. McGuire.

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1 BY MR. TYSON:
2 Q Ms. Marks, we're on the home stretch here.
3 Let me refer you back to our exhibit. We're going
4 to be on our last topic, number 24, which is the
5 process by which the organization searched for and
6 identified documents responsive to discovery
7 requests in this case, and you're the designee for
8 topic 24, correct?
10 Q And did you review documents to prepare
11 for this topic of the deposition?
12 A I didn't review a document about the
13 process. I don't think -- I don't think we created
14 a document for how I searched for records.
15 Q Did you speak with anybody associated with
16 CGG to prepare for this topic?
17 A Certainly with counsel, and in general in
18 the past talking to the board members about whether
19 they might have responsive documents that I did not
20 have, and generally the answer of that is no.
21 Q So I just want to -- I've marked as
22 Exhibit 36 the Coalition's objections and responses
23 to our second request for production of documents.
25 identification.)

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1 BY MR. TYSON:
3 A I do.
4 Q And so I wanted to go to -- hold on. I
5 think I'm in the wrong document here. Hang on just
6 a second.
7 I'm so sorry. Let me go to Exhibit 37,
8 which is the first request for production of
9 documents.
10 Do you see that?
11 A I do.
13 identification.)
14 BY MR. TYSON:
15 Q So let me just go to a couple of these in
16 particular. Request number 2 requested all
17 documents and communications that reflect any
18 diversion of personnel or time spent by or on behalf
19 of the Coalition as a result of your challenges to
20 the election system and/or the litigation from
21 January 1, 2017, to the present.
22 You see that?
23 A Yes.
24 Q And you indicate that Coalition will
25 produce documents sufficient to show a diversion of

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1 resources for purposes of establishing standing in

2 this litigation?
3 A Yes.
4 Q How did you go about searching for those
5 documents in response to number 2?
6 A Well, of course, in the fee claim that we
7 talked about earlier, I think we show a significant
8 amount of documentation of hours spent -- paid,
9 hours spent by our interns, and time that I spent,
10 and certainly that type of -- that type of activity
11 has continued since at similar levels.
12 Q As of today, I know you said documents are
13 going to be produced -- more documents may exist
14 later on, but as of today has CGG produced all
15 responsive documents to this request?
16 A I think we objected to some of this, but
17 have I sent you-all time sheets from the interns,
18 no.
19 Q But it's CGG's position that it has
20 produced as of today documents sufficient to show a
21 diversion of resources for purposes of establishing
22 standing in this litigation?
23 A Certainly, yes.
24 Q Let me go next to -- down here to request
25 number 31, and so there's a serious of documents

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1 here, 31 through 42, where each response is

2 responsive documents will be produced. I don't know
3 if you want to pull it up and review it on yours or
4 if you want to go through each one. Do you have a
5 preference?
6 A I'm sorry, are you asking do I want to
7 pull up what, this same -- the same exhibit?
8 Q Yes. Let me just explain. What I want to
9 do is for each of those requests where responsive
10 documents will be produced is the response, I just
11 want to confirm that CGG has produced all responsive
12 documents as of today.
13 So we can either do them one at a time, or
14 if you want to read them as a group and then
15 respond, that's -- I'm just trying to think of the
16 most efficient way to --
17 A Why don't we do them as a group and
18 respond. How's that?
19 Q Okay. That'll work great.
20 A Okay. Can you scroll down. Okay. Okay.
21 Okay. All right. Okay. Okay.
22 Q Have you now reviewed request numbers 31
23 through 42?
24 A Yes.
25 Q And has CGG produced all documents

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1 responsive to these requests as of today's date?

2 I'm not asking for documents that may come into
3 existence in the future.
4 A Right. You know, all documents that we
5 reasonably found in our searches, you know. Can I
6 tell you that we haven't missed some documents by
7 mistake, no, but, you know, all things -- all of the
8 ones that came up in reasonable searches, yes, we
9 have produced.
10 Q Did the -- did CGG utilize keyword
11 searches to identify responsive documents?
12 A Yes, we did, but not in a sophisticated
13 manner like a big agency would have. I did it
14 through just normal using -- using Microsoft and
15 Adobe types of searches on e-mails, on PDFs, that
16 sort of thing. I don't have any fancy litigation
17 platform searches of -- of the organization's
18 documents.
19 Q Does CGG maintain a central e-mail server?
20 A No, we do not.
21 Q Did you conduct a search of all the e-mail
22 addresses for CGG that it maintains?
23 A We don't actually maintain any e-mail
24 address for anybody except for me.
25 Q Did you search the personal in-boxes of

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1 any of your interns?

2 A Sorry, I guess that's wrong. We do have
3 their -- we have Gmail addresses that are assigned
4 to them, and they are only used for CGG business,
5 and so any documents that would have been in those
6 records we would have gotten in the searches.
7 Q So you searched the e-mail boxes?
8 A Yes, I think I did have them do that. I
9 didn't personally do that.
10 Q And does CGG maintain any sort of central
11 file server?
12 A No.
13 Q And so how did you conduct a search for
14 documents that were not e-mails?
15 A So I keep lots of files by category in a
16 big Dropbox of -- account, and so I did searches on
17 all of my folders that have anything to do with
18 Georgia or election systems and did Dropbox searches
19 using -- using that tool.
20 Q Okay. And did you give your interns
21 specific written instructions of how to search their
22 own Gmail boxes?
23 A No, that probably goes back some time ago,
24 and I probably just talked to them by phone about
25 it, but for the most part the vast majority -- vast

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1 majority of their e-mails are with me or -- they're

2 with me, and then otherwise they tend to be public
3 records requests and responses which they did look
4 for and forward me. Generally I get a copy of them
5 anyway. But that would account for virtually all of
6 the traffic going to the interns' accounts.
7 Q So let's go next to same process for
8 request number 44 through 56. I'll scroll through
9 those if you can read them.
10 A Okay. Okay. Oops. Okay. All right.
11 Okay. Okay. Okay. Okay. Okay. Okay.
12 Q So you've now had a chance to review
13 request numbers 44 through 56?
14 A Uh-huh.
15 Q Is that a yes?
16 A Yes. I'm so sorry. Yes.
17 Q And has CGG produced all documents
18 responsive to these requests as of today?
19 A Yes, to the best of my knowledge.
20 Q And then I have three more. Number 58.
21 A Okay.
22 Q And number 61.
23 A Okay.
24 Q And number 62.
25 A Okay.

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1 Q So for -- you've now read requests 58, 61,

2 and 62; is that correct?
3 A Yes.
4 Q The same question on those, have all
5 responsive documents been produced as of today?
6 A To the best of my knowledge, yes.
7 Q And I realize, Ms. Marks, I apologize, I
8 know we talked about interns and your e-mail box.
9 Did you collect any documents from the board members
10 of CGG?
11 A If I recall this has been some time ago,
12 and I asked them, but I cannot remember whether any
13 of them had anything that I didn't have, so I don't
14 remember whether there was separate production from
15 them. They were asked, but I don't -- but it
16 might -- if it was a duplicate document, if it was
17 something like to me we probably didn't produce both
18 copies.
19 Q Did you provide any instructions to the
20 board members about how to conduct a search?
21 A I don't recall right now. It's been a
22 little while.
23 Q Last thing our second requests for
24 production, Exhibit 36, I just want to go to number
25 8, all documents or communications concerning

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Page 274
1 membership with the Coalition for Good Governance,

2 including but not limited to registration processes,
3 dues, responsibilities, obligations, or benefits of
4 membership.
5 See that request?
6 A Yes.
7 Q Has CGG provided all responsive documents
8 related to request number 8?
9 A Yes, we have. That would be directly for
10 those purposes, yes, and we've discussed a lot of
11 that today.
12 Q Yes. Okay. Ms. Marks, I know it's been a
13 long day. I appreciate your endurance through this.
14 With that, I know you had one issue you wanted to do
15 some further digging on related to QR codes, so at
16 this point I think we can just suspend whatever time
17 we have left and go from there.
18 THE VIDEOGRAPHER: This suspends the
19 deposition. The time is 6:50 p.m., and we are now
20 off the video record.
21 (Off video.)
22 MR. MCGUIRE: I'm not sure if I said this
23 on the record or not, but we would like to read and
24 sign, so thank you.
25 (Off-the-record discussion.)

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1 MR. TYSON: So, Ms. Marks, one additional

2 housekeeping issue, I know we need to get a copy of
3 the notes that you referenced there, so if we could,
4 you just take a picture and e-mail it to
5 Ms. Bosworth, the court reporter, and we'll mark
6 that as Exhibit Number 38 to your deposition.
7 A All right.
9 identification.)
10 MR. MCGUIRE: While we're on the record, I
11 would just add that we wanted to read.
12 (Deposition adjourned at 6:52 p.m.)
13 (Signature reserved.)
14
15
16
17
18
19
20
21
22
23
24
25

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1 The following reporter and firm disclosures

were presented by me at this proceeding for review
2 by counsel:
3 REPORTER DISCLOSURES
4 The following representations and
disclosures are made in compliance with Georgia Law,
5 more specifically:
Article 10 (B) of the Rules and
6 Regulations of the Board of Court Reporting
(disclosure forms)
7 OCGA Section 9-11-28 (c) (disqualification
of reporter for financial interest)
8 OCGA Sections 15-14-37 (a) and (b)
(prohibitions against contracts except on a
9 case-by-case basis).
10 - I am a certified court reporter in the State of
Georgia.
11 - I am a subcontractor for Veritext.
- I have been assigned to make a complete and
12 accurate record of these proceedings.
- I have no relationship of interest in the matter
13 on which I am about to report which would disqualify
me from making a verbatim record or maintaining my
14 obligation of impartiality in compliance with the
Code of Professional Ethics.
15 - I have no direct contract with any party in this
action, and my compensation is determined solely by
16 the terms of my subcontractor agreement.
17
18 FIRM DISCLOSURES
19 - Veritext was contacted to provide reporting
services by the noticing or taking attorney in this
20 matter.
- There is no agreement in place that is prohibited
21 by OCGA 15-14-37 (a) and (b). Any case-specific
discounts are automatically applied to all parties,
22 at such time as any party receives a discount.
- Transcripts: The transcript of this proceeding as
23 produced will be a true, correct, and complete
record of the colloquies, questions, and answers as
24 submitted by the certified court reporter.
- Exhibits: No changes will be made to the exhibits
25 as submitted by the reporter, attorneys, or
witnesses.

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1 - Password-Protected Access: Transcripts and

exhibits relating to this proceeding will be
2 uploaded to a password-protected repository, to
which all ordering parties will have access.
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
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21
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800.808.4958 770.343.9696
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1 CERTIFICATE
2 STATE OF GEORGIA:
COUNTY OF FULTON:
3
4 I hereby certify that the foregoing
transcript was taken down, as stated in the caption,
5 and the colloquies, questions and answers were
reduced to typewriting under my direction; that the
6 transcript is a true and correct record of the
evidence given upon said proceeding.
7 I further certify that I am not a relative
or employee or attorney of any party, nor am I
8 financially interested in the outcome of this
action.
9 I have no relationship of interest in this
matter which would disqualify me from maintaining my
10 obligation of impartiality in compliance with the
Code of Professional Ethics.
11 I have no direct contract with any party
in this action and my compensation is based solely
12 on the terms of my subcontractor agreement.
Nothing in the arrangements made for this
13 proceeding impacts my absolute commitment to serve
all parties as an impartial officer of the court.
14
15 This the 4th day of April, 2022.
16
17
<%13609,Signature%>
18 _________________________________________
19 ROBYN BOSWORTH, RPR, CRR, CRC, CCR-B-2138
20
21
22
23
24
25

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Page 279
1 To: Robert McGuire, Esq.

2 Re: Signature of Deponent Marilyn Marks
3 Date Errata due back at our offices: 30 Days
4
5 Greetings:
6 This deposition has been requested for read and sign
by the deponent. It is the deponent's
7 responsibility to review the transcript, noting any
changes or corrections on the attached PDF Errata.
8 The deponent may fill out the Errata electronically
or print and fill out manually.
9
Once the Errata is signed by the deponent and
10 notarized, please mail it to the offices of Veritext
(below).
11
When the signed Errata is returned to us, we will
12 seal and forward to the taking attorney to file with
the original transcript. We will also send copies
13 of the Errata to all ordering parties.
14 If the signed Errata is not returned within the time
above, the original transcript may be filed with the
15 court without the signature of the deponent.
16
17 Please send completed Errata to:
18 Veritext Production Facility
19 20 Mansell Court, Suite 300
20 Roswell, GA 30076
21 (770) 343-9696
22
23
24
25

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1 ERRATA for ASSIGNMENT #5136390

2 I, the undersigned, do hereby certify that I have
read the transcript of my testimony, and that
3
4 ___ There are no changes noted.
5 ___ The following changes are noted:
6
Pursuant to Rule 30(7)(e) of the Federal Rules of
7 Civil Procedure and/or OCGA 9-11-30(e), any changes
in form or substance which you desire to make to
8 your testimony shall be entered upon the deposition
with a statement of the reasons given for making
9 them. To assist you in making any such corrections,
please use the form below. If additional pages are
10 necessary, please furnish same and attach.
11 Page No._____Line No._____Change to_________________
12 ____________________________________________________
13 Reason for change___________________________________
15 ____________________________________________________
18 ____________________________________________________
21 ____________________________________________________
24 ____________________________________________________

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2 ____________________________________________________
5 ____________________________________________________
8 ____________________________________________________
11 ____________________________________________________
14 ____________________________________________________
17 ____________________________________________________
19
______________________________
20 DEPONENT'S SIGNATURE
21 Sworn to and subscribed before me this____day of
____________, 20__.
22
23 _________________________________
NOTARY PUBLIC
24
25 My Commission Expires:___________

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25:5 26:6 40:8,24 ambiguous 218:1 193:16 203:18 apparently 186:23
49:21 72:10 130:3 231:22 204:7 209:15,22 appeals 16:10
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235:25 237:20 34:7,12 42:19 227:22 228:1,24 255:2 258:17
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197:16 217:15 141:20 180:19,25 242:4 246:15 appearances 6:1,1
al 1:4,7 amendment 215:1 249:5,6,7,19 256:2 7:1 8:1 9:22
alex 263:11 229:21 264:16,20,21,22 appeared 200:1
alexander 6:4 amendments 94:7 265:14,22 266:20 250:7
alignment 262:6 132:24 139:22 answered 63:3 appears 225:24
alive 83:22 amico 14:5 80:10 255:22 249:25 250:5,10
allegation 51:22 amount 83:13 answering 52:22 250:12
54:22 202:16 84:20 88:17 79:4 81:6 93:11 appel 225:16
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arrangement asks 101:25 210:11 222:7 audit 61:10 66:14
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article 276:5 assembly 100:13 attach 280:10 auditable 103:10
articles 3:7 138:14 100:17 128:17 attached 279:7 170:13
138:22 139:4,23 158:15 160:18 attachment 97:22 audited 239:10
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ashley 204:24 asserted 156:18 attempted 199:17 24:10 185:3
aside 40:4 195:15 asserting 219:19 232:25 240:12 222:24 223:2
asked 15:12 24:19 assigned 271:3 265:7 audits 24:11 47:7
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56:23 59:24 61:2 assignment 280:1 224:22 158:23 159:2,19
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automatically 134:5 141:19 247:1,24 251:17 barely 190:23
276:21 145:16,18 147:19 251:21,23 252:5 262:13
available 25:10 152:13 153:12 255:20 256:22 based 48:11 52:22
27:14,22 35:11 158:15 159:3 257:5 258:2,7,10 106:14,15,16
41:8 58:10 113:8 163:17 174:18 258:14,18,24 109:20 123:4
114:8 178:8 180:18 260:16 262:4,18 165:14 168:2
avenue 6:17 138:1 188:4 192:5 263:1,2,6 176:5 190:1
avoid 79:23 85:7 197:25 201:11,21 balloting 210:7,10 193:21 230:1
205:25 204:3,12 206:25 ballots 15:12,18 233:19 241:20
avoiding 158:22 208:7 223:5 15:18,20,24 16:11 243:24 245:24
awaiting 45:16 233:21 234:23 16:12,16,22 17:6,7 248:6 257:7
award 179:5 236:24 243:18 17:15,15,17 74:12 264:23 278:11
aware 23:11 31:19 246:14 248:3 75:4 79:6 89:1 basic 48:2,2
32:5,11 121:12 256:11,18 266:3 93:25 98:7 103:6 basically 53:10
147:23 153:18 271:23 279:3 103:14,24 155:17 57:15 107:13
198:9 201:20 backed 45:16 156:8 159:19 191:17
251:7 255:5 background 11:23 170:15 176:19 basis 108:13
258:15 260:20 18:20 24:16 25:7 206:1,3,5 223:24 152:15 166:25
263:23 264:2 32:20 45:20 224:5,17 226:7 229:10,11,22
awareness 249:24 bad 122:5 232:18,19 233:3,8 240:24 242:10,17
awful 152:6 baker 85:18 233:9,22,24 242:21,24 244:1
b ballistic 224:8 234:22 241:25 245:1 246:4 276:9
ballot 4:10 15:12 247:25 251:3,7,9 batch 260:5 261:2
b 1:10,15 6:12 9:3
17:1,4 24:10 57:3 254:4 255:14,16 batten 75:10 110:6
25:6 26:1,14,23
57:13,24 58:1,3 257:14,21,24 110:24 111:3
28:13 29:11,12,18
65:21 66:8 74:10 260:2,9 261:6,8,10 battle 163:9,13
62:21 104:21
78:3,4,9,22 86:15 261:18 262:4,16 battlefield 172:25
108:22 147:23
103:12 105:9 262:17,20,22 becoming 189:19
256:7 276:5,8,21
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278:19
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bachelor 19:1,21
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30:14 34:12 38:23
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63:2,5 71:16
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267:18 41:4 58:1 81:10 189:17,21 199:14 68:6 74:3,16,17
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14:4,14 16:4,10 273:6 205:22 92:22 93:4 120:5
17:1,11 24:9 better 29:8 37:12 blosser's 190:2 120:15 121:16,20
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91:8,10,20 96:24 beyond 12:25 260:8 262:2 140:19 146:1,2,5,6
97:1 99:15,21,23 134:24 135:3 bm 233:13 146:8,9,9,10,12,14
100:14 102:6 162:17 bmd 56:25 57:4 146:22,24 147:5,9
121:10,15 125:10 biden 237:6 76:10 77:24 85:4 147:13,16 148:6,9
129:2 133:1 240:10,14,17 92:23 93:20 94:9 148:10,15,18,20
138:23 139:23 245:13,18 254:9 94:11 127:20 149:3,10 150:16
146:7,16 162:10 254:14 129:6 154:23 151:13,21,22
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179:9 180:13 74:18 148:9 243:7 245:24,25 194:1,5 251:1
185:10 187:22 222:24 261:19 248:5 256:24 266:18 273:9,20
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202:14 203:23 271:16 258:24 boards 20:11 22:5
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211:12 219:24 113:23 164:7 93:14 120:5,15 bono 114:12
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247:25 251:4 156:1 179:24 205:2,13,15,17,19 275:5 278:19
262:12,13 263:4 bio 140:23 205:25 206:12 bottom 136:11
264:15 bios 140:4 209:12 226:1 246:23
believes 81:10 bit 17:3 24:21 59:9 231:3,4,5,6 234:17 boulder 84:4
belinfante 7:16 72:17 78:11 93:5 238:2,6,14 239:24 boulder's 84:18
bell 14:10 104:5 120:17 240:19 242:8,14 box 100:8 101:7
belong 200:16 153:7 155:14 243:11,14 245:2 101:13 273:8
benefit 184:25 168:13 170:6 245:11,20 246:6,7 boxes 270:25
185:7,11 194:10 235:23,23 238:10 247:2,20,22 271:7,22
194:14 195:10 260:6 board 3:11 10:25 brad 1:7 4:19 5:6
benefited 217:20 bit.ly 170:17 17:25 21:17,19 7:2
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235:11,22 256:3 budgets 130:23 213:9 237:11 47:16 48:6,12,21
265:6 buell 225:16 camp 64:21 49:24 51:12 58:22
breaks 179:10 bugs 15:7 campaign 74:19 75:5 83:20 85:1,3
brian 186:11 building 60:8,20 campaigns 143:3 86:24 89:10 91:24
189:10 built 252:19 173:16 91:25 92:3,12,15
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briefs 47:3,17 bunch 25:11 152:2 93:13 141:8 143:3 109:14 110:3,6,7
165:6,6 242:25 244:23 149:16 235:5 110:12,24,24
bring 66:25 burden 237:15 240:17 111:3,3,8,10
bringing 50:25 burdens 210:7 canvassing 93:2 114:13,17 116:7,9
166:11 burner 74:23 capacity 108:22 116:15,17 120:23
broad 213:10 business 19:14,22 113:10 169:25 121:1,6,7,11 122:3
broaden 64:25 87:3 271:4 capitol 169:15 122:10 127:25
broadening 64:15 busy 64:16 caption 278:4 128:10,14 148:4
65:2 button 166:10 care 133:9 211:23 161:6 162:1 164:8
broader 87:9 buy 51:17 53:6,7 213:22 174:1 179:1
227:7 c carey 7:14 186:25 190:22
broke 154:6 carolina 12:6,8 198:22 199:2
c 56:22 62:20,20
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95:21 100:5
202:12 65:10,14,14 66:6,9 209:20,24 210:5,8
128:21 139:11
brown 201:14 66:23 68:11 73:5 210:9,10,15,17,22
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call 19:22 48:25
bruce 201:14 73:15,22 74:8,14 211:19 215:9
49:8,9,9 60:9 84:6
202:22 256:15 74:19,24 82:17 219:2 226:11,17
84:21 99:16,21
brumback 225:14 90:22,25 91:10,11 227:10,11,12
108:7 147:8 181:9
bryan 7:4,5 9:9,11 105:9 109:20 230:18 236:4
184:2 197:25
10:22 38:25 41:12 110:9,21,22 122:9 237:14 240:21
209:25 210:17
60:3 169:9,17 122:14,25 125:2 247:11,17 263:10
218:21 248:1
203:3 227:19 126:2,9 156:2 263:25 265:12
251:25 256:13,15
246:14 165:6,8 239:9,11 266:7 276:9,9,21
257:22,23
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called 13:8 17:24
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17:25 66:8,20
17:22 112:22
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115:9 116:20,22 ceo 20:24 21:13 certificate 278:1 141:5 142:18,23

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210:24 255:3 certain 52:14 certification 19:25 144:5,12,16
258:23 196:1 20:15 126:1 145:14 146:10
cash 170:25 certainly 10:14 certifications 20:7 150:16 153:21,21
cast 57:3,13,24 11:21 13:11 21:25 23:4,5,9,15 158:7 161:5 163:5
232:18,18 233:3 29:22 34:17 40:1 certified 276:10 163:14 166:23
245:19 246:8 47:1,4 51:4,13 276:24 167:17 168:18
255:14 53:6 59:1 60:6,12 certify 122:25 171:8 172:4,5
casting 234:3 60:23 61:24 67:17 123:3 278:4,7 173:6,15,25
catch 112:4 70:13,17 71:17,21 280:2 174:22 176:10
categories 33:17 77:13 79:13 81:13 cetera 76:14 84:22 178:4,6,10 180:11
34:21 77:7,17 81:23 86:13 89:13 162:21 182:23 181:16,23 182:7
80:23 87:12 89:14 90:2 101:23 cgg 3:3,11 28:2,6,7 182:10 183:5,9,13
104:10 108:12 103:9 105:22 30:12 32:9 43:1 187:15,18,20
132:1 155:7 107:22 119:16,17 43:13 45:21 46:5 189:7 191:20,24
185:25 249:20 121:9 122:11 46:8,11,18 47:13 192:2,20 193:10
252:24 253:13 123:8 124:20 48:5,10,20,22 61:7 193:13 194:15
category 51:21 128:4,6,7,19 61:17 62:12,18 197:7 198:13
103:8,11 105:21 130:13 134:23 64:14 70:2 71:13 199:2,7 201:6,17
108:8 147:22,23 135:2 137:19 75:2,10,20 76:2,24 206:4 208:23
162:23 165:10 141:11 148:6 77:15,17 82:4,9 209:11,18 210:2
183:25 271:15 151:12 153:17 83:19 86:22,24 212:19,25 214:2
cause 50:20 156:14 157:22 87:15,18 88:8 214:11 217:20
258:16 158:3,13 160:25 92:4,10 98:2 218:15 220:21
caused 46:24 47:5 161:8 162:2 164:4 100:11,12,15 221:9,24 222:7
47:14 50:20 76:3 164:18 165:21 101:15 106:14,20 227:9,16 229:1
76:6 80:4 110:12 166:16 169:7 110:24 112:25 230:22 231:1,8,10
119:6,23 152:16 171:16 175:22 113:20 114:24,25 231:15,18 232:5
200:2,22 211:22 180:22 183:6 117:11,14,15,20 234:15 243:2
232:2 250:13 185:19 192:16 117:24 118:6 244:17,20 248:4
252:12 253:22 193:1 196:12 120:4 121:5 122:9 252:12,25 253:14
causing 251:13 202:15 210:7 123:6 124:23 254:12 257:14
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114:9 117:2,5 51:10 52:1,18 rhonda 146:7 162:1,19 163:6,15
118:10,25 119:7 87:18 132:20 ricardo 2:11 164:8,14 165:2,7
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respondent 211:14 107:24 139:11 62:2,15 63:1,9 255:24 258:21,21
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Federal Rules of Civil Procedure
Rule 30
(e) Review By the Witness; Changes.
(1) Review; Statement of Changes. On request by the
deponent or a party before the deposition is
completed, the deponent must be allowed 30 days
after being notified by the officer that the
transcript or recording is available in which:
(A) to review the transcript or recording; and
(B) if there are changes in form or substance, to
sign a statement listing the changes and the
reasons for making them.
(2) Changes Indicated in the Officer's Certificate.
The officer must note in the certificate prescribed
by Rule 30(f)(1) whether a review was requested
and, if so, must attach any changes the deponent
makes during the 30-day period.
DISCLAIMER: THE FOREGOING FEDERAL PROCEDURE RULES
ARE PROVIDED FOR INFORMATIONAL PURPOSES ONLY.
THE ABOVE RULES ARE CURRENT AS OF APRIL 1,
2019. PLEASE REFER TO THE APPLICABLE FEDERAL RULES
OF CIVIL PROCEDURE FOR UP-TO-DATE INFORMATION.

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30(b)(6) Marilyn Marks March 17, 2022

Curling, Donna v. Raffensperger, Brad

1 IN THE UNITED STATES DISTRICT COURT

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1 Exhibit 13 E-mails, 9/26/19, 123

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1 Governance’s Objections and

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1 APPEARANCES OF COUNSEL: (All appearances via Zoom)

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1 THE VIDEOGRAPHER: Today's date is March

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1 here for the Fulton County Defendants.

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1 Have you ever been deposed before? I

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1 If you can just state your name again for

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1 been a long time ago. This is maybe 2010, 2011,

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1 cases I was involved in.

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1 all else fails toward election transparency.

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1 ballot. And that became, I believe, one of the

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1 bachelor of science in accounting, and I graduated

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1 shortly after I graduated from college.

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1 do that kind of work. I couldn't possibly keep up

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1 Governance, but unfortunately at the moment it's an

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1 try to dig through all that.

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1 today, and I had to forego the idea of presenting

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1 Q And that's totally fine. I'm not trying

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1 notice of the 30(b)(6) deposition.

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1 Q You see here in this section it indicates

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1 Q And as we use the term "organization" or

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1 Q Okay, great, just so we have both of those

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1 asked if they thought they had additional knowledge

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1 to testify on behalf not just to my personal

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1 certificates and couldn't do it. That -- I think

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1 our -- of our documents.

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