Professional Documents
Culture Documents
30b6MarilynMarks PDFTran
30b6MarilynMarks PDFTran
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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 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 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
10 [email protected]
11 [email protected]
12 [email protected]
13 -and-
14 CAREY MILLER, ESQUIRE
15 VINCENT R. RUSSO, ESQUIRE
16 Robbins Ross Alloy Belinfante Littlefield
17 500 14th Street, N.W.
18 Atlanta, Georgia 30318
19 [email protected]
20 [email protected]
21
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25
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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
6 Atlanta, Georgia 30303
7 [email protected]
8
9 Also Present:
10 Krishan Patel, videographer
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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 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 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 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 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.
8 (Exhibit Number 4 was marked for
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 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?
15 A That's correct.
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 A As opposed to 2016?
2 Q Just --
3 (Simultaneous speaking.)
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 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 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 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 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 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 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?
10 A That is 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 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.
19 (Exhibit Number 10 was marked for
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 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?
10 MR. MCGUIRE: Objection to form.
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 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.
21 (Exhibit Number 13 was marked for
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 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 A Eberle.
2 Q Eberle -- I knew I wasn't pronouncing it
3 right -- and you, correct?
4 A That is 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 A I do.
2 Q And you're the designee for topic 5,
3 correct?
4 A That is 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 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 incredible interns.
2 Q Mark next Exhibit 22, which this is just
3 the home page for coalitionforgoodgovernance.org.
4 (Exhibit Number 22 was marked for
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 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?
22 A That's correct, yes.
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 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 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 correct?
2 A I am, yes.
3 Q And did you review any documents
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 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?
13 A That is correct.
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.
16 And you are the designee for topic 12,
17 correct?
18 A Correct.
19 Q And did you review any documents
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 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 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 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 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.
7 A Okay. All right.
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 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 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?
9 A That is 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.
24 (Exhibit Number 36 was marked for
25 identification.)
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1 BY MR. TYSON:
2 Q Do you see that?
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.
12 (Exhibit Number 37 was marked for
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 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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2019 2:17,25 278:15 28 2:4 4:2 97:12 269:1,22
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2020 3:14 59:25 218 56:19 2:25-2:33 130:16 36 4:25 266:22,24
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Veritext Legal Solutions
800.808.4958 770.343.9696
30(b)(6) Marilyn Marks March 17, 2022
Curling, Donna v. Raffensperger, Brad
[42 - accounting] Page 3
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training 22:14,17 true 86:22 104:3 turn 56:6,16 67:2 39:3,12,16 40:15
31:9 191:25 192:7 158:19 240:16 70:22 111:7 126:5 40:22 46:17 50:2
192:11,14 276:23 278:6 196:3 246:10 52:20 55:12 56:10
transcript 10:18 trump 237:7 turned 15:7 52:12 59:16 60:6,11,19
11:17 259:4,14,19 240:10,13,17 199:24 231:13 60:22 63:2 70:10
276:22 278:4,6 254:9,13 turning 204:12 76:18 77:6 94:18
279:7,12,14 280:2 trust 79:6 tweet 3:22 4:15 94:21,24 95:1,7,18
transcripts 51:17 truth 167:18 172:2,9,16 99:16 100:24
53:6 276:22 277:1 truthfully 12:14 tweets 3:21 168:24 107:1 109:13
transferred try 11:16 23:1 169:4 170:10 111:21 116:13
220:21 31:13 41:3 78:18 twice 156:13 120:13 122:20
transition 64:9 81:25 93:19 99:16 twitter 168:15,18 123:23 126:21
65:14 104:5 105:20 170:1 172:5 239:3 130:13,19 131:14
transitioning 73:9 128:5 154:15 240:2 131:20 136:9
transparency 16:1 159:15 167:15 two 14:25 34:11 138:3,13 140:8
49:18 62:14,25 176:18 193:20 42:1 52:22 57:21 150:19 155:5
63:11 65:6 72:22 194:25 203:19 67:1 92:1 140:17 158:2 161:11
127:19 128:3 223:4 235:6,22 141:11 155:15 162:8 163:24
136:25 137:8 245:4 220:6 230:16 164:11,20 166:6
164:18 trying 17:23 20:9 252:2,3 258:17,23 167:11 168:22
transparent 141:1 25:1 36:22,24 type 16:8 47:24 169:11,22 170:4
165:13 37:19 60:8 63:23 49:19 68:21 172:1 174:17
travel 53:14,14 70:15,17 71:7 103:18 110:11 177:4 180:20
54:11 108:14 78:13,15 79:22 113:6 132:2,11 184:22,23 186:15
treat 196:6 103:19 113:14,19 173:24 176:16 187:12 188:17
trial 10:11 13:4,18 128:24 146:20 178:21 193:18 190:18 196:9
tried 31:24 139:16 149:22 151:1 199:11 251:12 198:19 203:8
158:12 175:24 155:18 169:13 268:10,10 204:11 209:25
215:11 247:6 178:19 188:2 types 53:2,24 54:1 210:1 213:19
tries 206:23 193:5 196:5,14 54:12 70:18,24 215:6 216:7,9,23
trip 44:24 45:4 203:8,9,12,14 77:20 92:19 93:6 218:2 219:18
triple 79:16,21 207:5 210:16 110:22 160:1 220:4,13,17,18
80:19 89:1,23 215:16 222:1 193:9,12 211:3,6 222:15 225:11
152:8 244:11 224:21 225:1 270:15 227:23 228:9,22
250:22 251:2,10 226:7,9 239:8 typewriting 278:5 228:25 229:11
251:14 260:20,25 244:16,24 246:15 typical 117:10 230:2,3 232:4
261:6,23 246:19 254:15 typically 67:1 235:14,20 237:21
troublesome 253:4 255:21 269:15 tyson 5:13 7:4 9:8 239:2 246:2
truck 21:13 tuesday 150:15 9:9 10:6,9,14,15 248:11 259:10
trucking 129:12 245:21,22 10:22 13:9 24:17 264:3,10,13 265:3
25:21 26:4 28:16 265:5,17,17,24
Rule 30