Maricopa County-Printer Deficiencies-Report 06-08-2023

ELECTION OVERSIGHT GROUP, LLC. KEVIN MONCLA I (469)-588-7778 I KMONCLA@GMAIL.
COM
“The first rule of any technology used in a business is that automation applied to an efficient operation will magnify
efficiency. The second is that automation applied to an inefficient operation will magnify the inefficiency.”
Bill Gates. Jul 8, 2019
MARICOPA COUNTY ELECTION DAY PRINTER FAILURE INVESTIGATION REPORT
On November 8th, 2022, Maricopa County experienced a widespread failure as voters atempted to cast their
ballots at Vo�ng Centers across the county. Many polling loca�ons witnessed a situa�on in which ballot scanners
would not accept ballots, several of which occurred immediately upon opening of the polls. The failure was
intermitent, inconsistent in loca�on and severity; yet widespread.
Ini�ally it was suspected that Image-Cast Precinct-2 (“ICP-2”) vo�ng center tabulators were malfunc�oning, but
the problem was soon isolated to the county’s Ballot on Demand (“BOD”) printers. Prin�ng problems were found
to yield defec�ve ballots which the ICP tabulators could not read (ballots rejected/returned to the voter).
This report will isolate and iden�fy the problems, the scope of those problems, and determine the most likely
causes. As the product of an inves�ga�on, this review is all encompassing and not limited to a technical review,
but includes all relevant acts, law, manuals, rules, records, references, statements, tes�mony and events.
The Problems
___________________________
Descrip�on:
Two (2) separate Elec�on Day Ballot on Demand (“BOD”) printer failures have been iden�fied:
1. Speckled patern ballots
2. 20-inch ballot image resized to 19-inch printed on 20-inch paper (addressed by Clay Parikh’s
Declara�on and furthered in trial tes�mony)
Speckled-Patern Ballots:
The predominant deficiency common to ballots being rejected by the tabulators was characterized by witnesses
as the print appeared “faded” or “speckled”. More specifically, areas of the ballot which were supposed to be
solid or uniform, were not. The defec�ve ballots had areas interspersed with white “specks” making them
appear faded.
1
ELECTION OVERSIGHT GROUP, LLC. KEVIN MONCLA I (469)-588-7778 I [email protected]
According to witness interviews, poll worker reports/affidavits and images shared on social media, the deficiency
appeared in a remarkably consistent patern on the same area of the reverse upper le� corner of the ballot.
Example of an Elec�on Day ballot with the Speckled patern below:
Resized Ballot Images

The second prin�ng deficiency has been iden�fied as a ballot image that has been resized or rescaled to a smaller
image. An example of such an image is below as it appears alongside a ballot printed to proper size:
2
It is important to understand how the contest selec�ons on a paper ballot are counted. Despite common
misconcep�ons, tabulators do not count or “read” directly from the paper document, but an electronic image
of the ballot. When a ballot is scanned it moves across the imaging device and is illuminated by different color-
filters, and a separate image is produced for each filter. These images are then adjusted for the spectrum visible
to the human eye (the scanner is essen�ally mimicking or fabrica�ng the appearance of the document as it
would appear under natural or white light condi�ons). So�ware overlays the separate color images to form one
composite image.
Separate so�ware removes stray markings, crops, and adjusts for any imperfec�ons created by the inconsistent
movement of the paper during the scanning process. Lastly, the image is resampled into either B&W or grayscale
and a resolu�on of 150-200 dpi depending upon the jurisdic�on’s preferences. Only a�er this process is the
ballot image passed to the Dominion so�ware to analyze, authen�cate, and then count the contest selec�ons.
First the so�ware atempts to validate the black squares and rectangles, called �ming marks, which surround
the ballot as iden�fied below:
3
This starts with one of the black rectangles in the corners- not by looking for the markers, rather the so�ware
looks at the posi�on of where the corner marker should be in rela�on to the paper’s edge. It then determines
if the solid black corner marker is there or not. For example, the images below are produced by Dominion’s
troubleshoo�ng tool which assists administrators in determining the poten�al cause for ballot rejec�ons (color
markings added).
Representa�ve of Maricopa County’s resized ballot issue
In the image on the le�, the red arrow is poin�ng to a square outline which delineates the defined area in which
the so�ware looks for the top le� corner of the solid black corner marker. The top le� corner is indicated by the
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purple square. In this case the corner marker is where it is supposed to be as the purple square is within the
tolerance square. The image on the right is a ballot that has been resized and the top le� corner of the corner
marker (purple square) is found outside of the tolerance square causing the ballot to be rejected. Note that the
rejec�on is not caused because it couldn’t find the corner marker, rather it did not find the corner marker in the
posi�on where it was supposed to be.
If the corner marker is in proper posi�on, is the correct size, and is solid black, then the so�ware proceeds to
the next �ming mark loca�on and checks it in the same way. This process is repeated un�l all �ming marks have
been established around the en�re perimeter of the ballot. If only one �ming mark is out of place, is improper
in size, or is not solid black, the ballot will be rejected. See the examples below:
Such strict tolerances are by design and act as an inherit security feature making it difficult to produce counterfeit
ballots with the requisite precision. From Dominion’s manual: 1
1
The corresponding Dominion manual is available upon request.
5
The ImageCast Precinct (Vo�ng Center Tabulators) and the ImageCast Central (MCTEC or “Central Count”
tabulators) authen�cate and read a ballot in the exact same way. In fact, it is not the scanner that’s
authen�ca�ng the ballot, but Dominion’s so�ware. Both tabulators use the very same ballot defini�on file with
the same requirements, ballot image resolu�on, specifica�ons and tolerances.
Maricopa County’s Prin�ng Problems & Dominion’s Tolerances

The speckled printed ballots witnessed in Maricopa County is specifically defined in Dominion’s ImageCast Ballot
Printing and Finishing Specifications manual, Sec�on 2.12 Examples of Problem Ballots. 2
The manual states in part, “…the system is designed to recognize solid alignment marks only. This ballot shows
widespread fading which appears as white blotches” (emphasis added).
2 The Dominion ImageCast Ballot Prin�ng and Finishing Specifica�ons manual is available upon request.
6
Maricopa County’s defec�ve Elec�on Day speckle-printed ballots mirror the example Dominion provides in
their manual as an issue known to cause misreads:
Maricopa County Rejected Ballot Dominion’s Example Problem Ballot Example
The resized ballot image defect is also specifically addressed by the same manual:
7
The manual describes a tolerance of only 2% size varia�on. Maricopa County’s resized ballots were printed to
approximately 95% of their original size, or a difference of 5%.
8
In summary of the two iden�fied prin�ng deficiencies, each fits squarely within Dominion’s corresponding
defini�on of known problem condi�ons. As such, the fact that vo�ng center tabulators rejected the defec�vely
printed ballots is of no surprise; however, what is surprising is that two separate prin�ng problems were both
suddenly manifested on Elec�on Day affec�ng hundreds of printers. The resized ballot failure was created across
two separate hardware pla�orms.
The severity and scope of the ballot printing / tabulator rejection problem has been a matter of contention since
Election Day. Almost immediately Maricopa County election officials began minimizing the printer failures as a
mere inconvenience only affecting a small number of voting centers which was quickly resolved after changes
in printer settings were implemented. The following is from Maricopa County’s November 27th response to the
Arizona Attorney General’s office regarding the Election Day failures:
Note that the descrip�on iden�fies only the Oki B432 BOD printer, and references pre-elec�on “stress tes�ng”,
but for some reason doesn’t men�on Logic & Accuracy tes�ng.
The characterization is materially false in both scope of voting centers affected and length of time.
9
The chart above represents the aggregated vo�ng center tabulator system log data from 445 machines used to
scan ballots on Elec�on Day. Using a threshold of misfeeds of over twenty (20) percent 3, nearly three fourths,
or 68% of all ballots scanned on Elec�on Day were involuntarily rejected.
Maricopa County claims to have found a “fix” for the speckled/faded print issue by changing the media weight
se�ngs for the envelopes and regular paper from normal to heavy. This nonsensical solu�on was supposedly
implemented and “…by mid-afternoon, most sites were no longer experiencing the printer issue.”. This claim is
incontrover�bly false as the printer failures raged un�l a�er the polls closed:
3 A 20% rate of rejection is in no way acceptable as the EAC guidelines limit the same to .2%, or .002. The extraordinary high value of 20% was chosen
to leave no room for mistake, human error, or excuse.
10
Even though Maricopa County’s leter was nearly three (3) weeks a�er the elec�on, there is no men�on of the
resized ballot issue. In fact, it wasn’t un�l later when Scot Jarret was on the stand during the Lake v. Hobbs
trial for the second day that Scot Jarret finally acknowledged the second printer problem. Even then Mr. Jarret
concealed the fact that resized ballots were being produced by both Oki and Lexmark BOD printers 4.
No mater Maricopa County’s misleading and false claims, the system logs from all 446 vo�ng center tabulators
have provided an inarguable fact-based record of every ballot inserted, whether it was accepted or rejected, and
why. 5 The following data was derived directly from those logs which were produced by the Dominion Elec�on
Day vo�ng center tabulators and provided by Maricopa County in response to a Public Records Request.
A total of 461,826 ballots were inserted into the vo�ng center tabulators on Elec�on Day in Maricopa County.
Out of those, a total of 229,781 ballots were successfully cast. 6 To further understand the breadth of the Elec�on
Day failure, consider that the Elec�on Assistance Commission’s threshold for ballot misreads is .002 or 1/500
4
Scot Jarret tes�fied that the resized ballot issue was discovered at three (3) vo�ng centers. One of which was Gateway Fellowship Church
(14864) that produced approximately 900 of the es�mated 1300 resized ballots, and only used Lexmark BOD printers.
5
An electronic file containing a directory for each vo�ng center and the corresponding tabulator system logs is provided separately.
6
It’s important to note that many of the same ballots were being fed mul�ple �mes as voters atempted to cast their ballots. Each addi�onal
atempt necessitated by the preceding failure.
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ballots. 7 On Elec�on Day, Maricopa County’s equipment averaged in excess of 2 in 5- or two-hundred times the
limit.
Maricopa County’s own tabulator records irrefutably establish that 151 (not 60) of the 223, or over 68% of
Elec�on Day vo�ng centers experienced serious failure as ballots were rejected at a rate of 20% or higher.
The Response
______________________
Soon a�er the polls opened and the printer problems were realized, county officials and poll workers directed
voters whose ballots were being rejected to deposit them into “Box 3” and they would be scanned on the
county’s central count tabulators, as acknowledged in Maricopa County’s response above:
If an on-site tabulator could not read the ballot, the voter was instructed to deposit the ballot into a
secure ballot box (“Door 3”) to be counted at Maricopa County’s central counting facility. These 16,724
Door 3 ballots represent 1% of the total ballots issued to voters during the 2022 General Election
The instruc�on seemed as though it was preconceived or choreographed- not just to deposit the problem ballots
into door 3, but that they would be counted on the county’s central count scanners. How could county officials
have known that the defec�ve ballots would magically scan without incident? There should have been no such
expecta�on. In fact, any presump�on should have been that the defec�ve Box 3 ballots would have to be
duplicated as prescribed by Arizona state statute:
Ariz. Rev. Stat. § 16-621: If any ballot, including any ballot received from early voting, is damaged or
defective so that it cannot properly be counted by the automatic tabulating equipment, a true duplicate
copy shall be made of the damaged or defective ballot in the presence of witnesses and substituted for
the damaged or defective ballot. All duplicate ballots created pursuant to this subsection shall be clearly
labeled "duplicate" and shall bear a serial number that shall be recorded on the damaged or defective
ballot.
Central count scanners (ImageCast Central, or “ICC”) use the very same ballot defini�on as those of the vo�ng
center tabulators, with the same tolerances and specifica�ons. In other words, if the precinct tabulator at the
vo�ng center rejected the ballot, then the ICC tabulator should reliably also reject the ballot- and for the same
reason. Any devia�on between the two is in and of itself a failure as the same ballot should not yield two
different results on two different tabulators.
7
The EAC Voluntary Vo�ng System Guidelines can be found here: Voluntary Vo�ng System Guidelines | U.S. Elec�on Assistance Commission (eac.gov)
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Maricopa County Officials later claimed that the same printer se�ngs were used during the 2022 primary and
previous elec�ons. The following is from the November 28th MCBOS mee�ng:
And one of things we’ve been able to confirm through this analysis is every printer for every one of our
Oki printers as well as our Lexmark had the exact same settings, uniform settings, and we were using
the exact same settings that we had used in prior elections. Now, the only difference was we had a 20-
inch ballot versus a 19-inch ballot. But before – as we were leading up to this election we stress tested
that 20-inch ballot and we did not find any issues as we were leading into election day.
Similar claims were made by Maricopa County in response to a leter from the Arizona Atorney General’s office:
Despite stress testing the printers before Election Day, installing the latest firmware, using uniform
printer settings, and using the same settings as programmed in prior elections, the Oki B432 printer
experienced an issue affecting the ability of the on-site tabulators to accept the ballot.
Strangely, no men�on of Logic & Accuracy tes�ng in either comparison- just stress tes�ng. Throughout the
course of this inves�ga�on, it has become evident that Mr. Jarret has a propensity to make asser�ons which are
at best, technically factual but “disingenuous” in context. This is a prime example as his repeated atempts to
subs�tute or conflate stress tes�ng with the statutorily required Logic & Accuracy tes�ng.
Another example is his tes�mony during the MCBOS’s November 28th mee�ng which he specifically claims that
the printers “…had the exact same settings” as in previous elec�ons. He tracks the same language in the response
to the Arizona Atorney General’s leter- “uniform printer settings, and we were using the exact same settings
that we had used in prior elections.”.
Maricopa County increased the ballot paper weight from the 80lb vote-secure paper used in previous elec�ons,
to 100lb vote-secure paper for the 2022 Primary and Mid-term elec�on. Mr. Jarret fails to men�on the paper
weight change in either forum. He even goes as far as to iden�fy fuser heat se�ngs which are directly correlated
and affected by paperweight, but he never actually discloses the change in paperweight.
The fuser is essen�ally a hea�ng element housed within a roller which heats the paper to a temperature that
melts the toner and bonds it to the paper. The heavier the paper, the more heat that’s required to melt the
toner. When the heat is insufficient, the result is speckling.
Jarret also fails to men�on that the 2022 Primary Elec�on ballots were nearly all one-sided- or said another
way- the primary ballots fit all races on one page with only a few excep�ons. This is important because any
deficiency would have presented primarily on the reverse, or botom -side of the ballot as witnessed on Elec�on
Day (further explained below).
Duplex prin�ng (both sides) is more demanding and requires more heat than that of one-sided prin�ng; which
is why the specifica�ons, paperweight capaci�es and fuser heat requirements are different for duplex prin�ng.
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Therefore, to use the “exact same se�ngs” on Elec�on Day as those used for the primary is effec�vely
meaningless because the ballots, paper weight and prin�ng demands were all materially different.
Moreover, the BOD uniform printer se�ngs were not the same- nor were the circumstances. Following the
August primary, Maricopa County specifically removed those uniform printer se�ngs from all their Oki B432
printers and new firmware was installed. At the same �me, new BIOS, printer, and postscript drivers were
installed on the Runbeck Sen�o laptops which control the printers. A similar conclusion was made in Jus�ce
McGregor’s report:
Changes Between Primary and General Elections

Maricopa County made several changes between the 2020 and 2022 elections and between the 2022 primary and
general elections that could have affected the performance of the printers. We designed our tests to determine
whether any of these variables, or a combination of them, caused the printer malfunction that occurred during
the 2022 general election.
A statement more accurate than Mr. Jarret’s asser�on that “…we were using the exact same settings that we had
used in prior elections” is that there was very litle that had not changed between the August Primary and the
November 8th General Elec�on.
Causes of the Elec�on Day Prin�ng Failures

_____________________________
Speckled/Faded Prin�ng
Based upon the totality of evidence reviewed to date, the 2022 General Elec�on speckled/faded print problem
was isolated to the Oki B432 BOD printers. 8 Our findings as to the causes of the 2022 General Elec�on
speckled/faded printed ballots by the Oki BOD printers are as follows:
1. 100-pound ballot paper is beyond the capacity of the Oki B432 printer for duplex prin�ng.
From the Oki B432 Operator’s Manual:
8
Our inves�ga�on included consulta�on with Oki-Data engineers, various subject-mater experts, poll workers, T-techs, and mul�ple Elec�on Day
voters. Addi�onally, review and reference of the corresponding product manuals, printer se�ngs, checklists, reports, Troubleshoo�ng/Elec�on Dept.
Hotline (STAR) call logs, Jus�ce McGregor’s report, Dominion Vo�ng Systems technical manuals and other associated documents which were provided
by Maricopa County in response to Public Records Requests (“PRR”) and Arizona State Senate subpoena. Also included in our inves�ga�on was the
bench tes�ng of the same Oki printer model B432dn as that used by Maricopa County, with the same Roland Vote-Secure paper of the same 100-
pound weight as that used on Elec�on Day.
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“The paper weight capable of duplex printing is 60 to 120 g/m2.”
120 g/m2 converts to a duplex prin�ng capacity limit of 80-pound paper. Maricopa County’s use of 100-pound
paper exceeded the manufacturer’s specifica�ons by twenty pounds or twenty percent (20%).
A recent report on the printer issues by former Arizona Supreme Court jus�ce McGregor made the following
erroneous asser�on:
Maricopa County’s experience during the primary election amply demonstrated that printing ballots on
100-pound paper does not exceed the capacity of the Oki B432 printer.
Again, another comparison- and conclusion based on something other than the most obvious, standardized,
and closely matching metric- Logic & Accuracy testing. Justice McGregor’s assertion that 100-pound paper does
not exceed the capacity of the Oki B432 printer is at odds with a footnote on page 7 of the same report:
15
A suggestion of a problem did occur during early voting in the primary. Ballots from early voting are
returned to the MCTEC in envelopes, removed by bi-partisan teams of workers, and tabulated on central
equipment. Some of the workers noted flaking or speckling on some ballots and brought it to the attention
of supervisors.
The fact that the same speckled printing problem was documented by workers who noticed “…flaking or
speckling on some ballots…” during the primary, is a strong suggestion that 100-pound paper is beyond the
capacity of the Oki B432 printer. Despite Justice McGregor’s conclusion, the performance of the Oki printers
during the 2022 primary election is not a reliable benchmark. As stated earlier in this report, the ballots for the
primary were nearly all one-sided and did not endure the same stresses of the duplex printing process.
Maricopa County’s Election Day experience irrefutably demonstrated that 100-pound paper far exceeds the
capacity of the Oki B432 printer, as well as the manufacturer’s specified threshold of 80-pound paper for duplex
printing. In any case Justice McGregor’s conclusion that “…100-pound paper does not exceed the capacity of
the Oki B432 printer” is false- both realized and specified.
The speckled-printing issue is squarely defined in the Oki printer manual:
The McGregor report continues:
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The experience during the general election tells us that, when 100-pound paper was coupled with a
lengthier, 20-inch ballot, the task being asked of the Oki B432 printer simply exceeded the capacity of
many, although clearly not all or even most, of the printers.
The Oki printers at issue are all of the same model. To claim that the task at hand exceeded the capacity of
“many, although clearly not all or even most..” is a distinction without a difference. The printers failed. Justice
McGregor’s characterization as to the number of printers adversely affected is also in error. So much so that
it’s a gross misrepresentation. 9 As detailed previously in this report, the majority of Election Day printers failed
on Election Day. The metric is the number of ballots successfully cast versus the number of ballots rejected by
the voting center tabulators- as documented by the system logs and provided by Maricopa County. The ballot
print defects are specifically identified for each rejected ballot. The errors are defined, the tabulator system
logs are undeniable, and the math certain.
Our bench-testing has found that while the use of 100-pound cardstock for duplex printing on the Oki B432 is
beyond the manufacturer’s specified capacity, the printer is robust. After printing in excess of 5,000 test prints
(likely exceeding the lifetime use of Maricopa County’s BOD printers) the only way to reproduce the speckled
printing was to force it by reducing the media weight settings to light. These settings were inconsistent with
Maricopa County’s Election Day settings.
2. Closer inspection revealed that Maricopa County’s Oki BOD printer media type settings were not set to
“CARDSTOCK”, but to “PLAIN”.
Below is a portion of the printer configuration print-out for one of the Oki printers used on Election Day:
There is a difference between a HEAVY weight setting for a PLAIN media type and a HEAVY weight setting for a
CARDSTOCK media type. The weight (and heat) setting is relative to the type of media. More heat is required
9
McGregor’s report indicates that she relied upon interviews with Scot Jarret, Maricopa County staff, or references produced by Maricopa County,
but did not reference the tabulator system logs.
17
for heavy cardstock than that of plain paper and the fuser temperature is adjusted accordingly. The significance
of the media type and corresponding weight settings is defined by the Oki troubleshooting matrix:
The addressed condition is an insufficient bond between toner and the paper. The recommended solution is to
ensure that the media type and media weight settings are appropriate.
Justice McGregor’s report briefly mentions the media type, and in doing so acknowledges that the printers were
in-fact erroneously set to PLAIN:
After trying several approaches to resolve the issue, Maricopa County concluded that the most promising
approach involved setting all media weight settings to “heavy,” theorizing that the fuser would then
maintain a high temperature at all times and would properly fuse the toner to the paper, and instructed
its t-techs to make that change when called to a vote center. In addition to that change, Runbeck
personnel called to vote centers changed the media type, or paper, setting from plain to cardstock for
ballots.
The significance of this important distinction in media weight setting was not described in Justice McGregor’s
report, nor was any acknowledgment made that the printer media weight settings had been set incorrectly
18
(prior to early voting began). No testing was undertaken to repeat the same conditions and observe the
differences in printing that each setting would yield.
Similarly, Scott Jarrett and county election officials failed to disclose the same to the Arizona Attorney General’s
Office in their November 27th letter, nor to the Maricopa County Board of Supervisors on November 28th, and
not even to the court during the Lake v. Hobbs trial. Instead, Mr. Jarrett described a change to the envelope
and paper tray settings that would have resulted in no effect on the printing of the ballot cardstock tray (we
tested), while concealing the media type settings change from PLAIN to CARDSTOCK.
The following facts remove any possibility that the proper settings for the use of 100-pound paper were ever
incorporated.
The Oki Print Media and Paper Weight conversion chart shows the proper setting for the 100-pound cardstock
as “Ultra Heavy 1”:
The Oki printer has 3 separate paper trays, and the actual settings used for the election are shown above on
right. First is the multi-Purpose tray, (underlined in blue) is marked “DO NOT USE”. The tray delineated in red
is Tray 1 which was the ballot tray used for ballot stock, and the Media Type is set to PLAIN.
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The proper setting for the 100-pound paper is Ultra Heavy, but the caution symbol is to inform the user that the
setting is not available, except for the Multipurpose tray. If the proper Ultra Heavy setting is selected, the
application will automatically change the corresponding tray to the Multipurpose tray. In short, the proper
setting cannot be selected for the tray used by Maricopa County. What’s more, the Ultra Heavy setting is not
available for Duplex printing. Even though the paper weight exceeded the manufacturer’s specifications, there
is no way with which to print 100-pound paper with the maximum heat settings using the tray that Maricopa
County utilized- Tray one.
This is a very important data point as it confirms that the incorrect media weight settings remained unchanged
from the pre-early-voting dates shown in the printer set-up reports until Election Day. The same BOD printers
that failed on Election Day were used to print the ballots for in-person early voting. This means that the media
weight settings were incorrect the entire time, and unsurprisingly the same failures were documented. The
following is from the Declaration 10 of an observer at the Maricopa County Tabulations and Elections Center
(“MCTEC”) who witnessed the following on November 2nd between 8 a.m. and 1 p.m.:
8. On November 2, I was observing a table with two workers who were reviewing ballots to ensure
they were able to be scanned by the tabulator. I noticed a growing pile of ballots that the workers had
set aside as damaged and would be duplicated before tabulation. One of the workers called over a
10 The Declara�on of Janet Patrick is available upon request.

20
manager of the ballot processing department, Melissa, who I understand is a Maricopa County
employee. Melissa then called me over to the table so I could hear what was being discussed.
9. The worker explained to Melissa that the ballots he set aside had faded timing marks. Melissa then
retrieved a manager from the elections department (who I also understand is a Maricopa County
employee) to show that manager the faded timing marks. The elections department manager agreed that
these ballots with the faded timing marks could not be processed by the tabulators. That manager said
that she would notify the site from which these ballots came to service its printer.
The pertinent portion of the Declaration corroborates two important points: 11
1. The speckled-print issue was present during the in-person early voting period and did adversely
affect the ballots in a manner consistent with those defective ballots printed on Election Day.
2. The manager of the elections department confirmed what has been previously asserted with
very high confidence in this report - that the speckled/faded ballots could not have been read
by the central count tabulators, just as they weren’t read by the voting center tabulators.
Testing was conducted mirroring Maricopa County’s plain media-type settings, and although print was speckled,
the result was not representative of the serious failure produced on Election Day.
It was brought to our attention that the printer has a setting called “ECO Mode” which causes the Oki B432 to
start printing before the fuser has reached target temperature. From the Oki B432 manual:
3. A review of Maricopa County’s printer se�ngs for the November 2022 General Elec�on has revealed that
ECO Mode was in-fact enabled on all of the Oki B432 printer configura�on records provided by Maricopa
County.
During the course of our inves�ga�on, we interviewed Ms. Patrick and another individual who witnessed the same occurrence. We
11
were also able to acquire surveillance video which corroborated the incident. This informa�on is available upon request.
21
The following is the per�nent por�on of the printer configura�on from one of the Ballot on Demand printers
used for Elec�on Day:
Jus�ce McGregor’s report states the following as it pertains to the opera�on of the fuser and prin�ng:
When the printer is powered on, the fuser is energized and heats until it reaches the set temperature of
approximately 190 degrees. The paper with a latent image then passes between the upper and lower
rollers. The heat and pressure from the upper and lower rollers heat and press the latent toner into the
paper fiber, and fusing is complete. If the fuser does not maintain an appropriate heat, the toner will not
properly adhere to the paper, causing flaking and speckling.
Her Honor provides an accurate descrip�on of the process, sequence of events and opera�on of the printer- as
it would operate with standard se�ngs. ECO Mode allows prin�ng to begin before the fuser reaches the set
temperature, and because the “…fuser does not maintain an appropriate heat, the toner will not properly adhere
to the paper, causing flaking and speckling.”. Unfortunately, with the instant circumstances ECO Mode creates
the very condi�ons and resul�ng failure that she describes- flaking and speckling.
Tes�ng 100-pound cardstock with ECO Mode set to “ON” in conjunc�on with the media weight set to PLAIN
has reliably reproduced the speckled prin�ng failure consistent with that experienced on Elec�on Day:
22
The same is reliably repeated with a minimum �me interval of approximately fi�y (50) seconds between
prin�ng ballots.
The cause for the Elec�on Day speckling primarily on the reverse side of the ballot is due to the reverse side
being printed first. The top le� quadrant is where prin�ng starts, and the fuser is the coldest. With ECO mode
enabled- the temperature is insufficient to properly bond the toner to the paper.
23
A�er the reverse side of the ballot is printed, the printer ejects the paper then pulls it back into the machine, at
which point the printer must turn (flip) the paper over to print the front side. This process entails rou�ng the
ballot over a series of rollers at very �ght angles which exposes the freshly printed side to fric�on and “rubs” off
the loosely bonded print.
The front side is printed following this process and then the ballot is ejected from the printer. The front is not
subjected to the same stresses and fric�on as the reverse, hence the speckled prin�ng predominantly appearing
on the reverse. Addi�onally, the fuser has reached the target temperature by the �me prin�ng ensues on the
front of the ballot.
Maricopa County elec�on officials have repeatedly claimed that the speckled/faded printer issue was fixed on
elec�on day and therefore no voters were disenfranchised. This is not the case. There are several independent
data points which refute the county’s asser�on, including the tabulator system log files which show �ming mark
24
errors long a�er the polls closed, the call center Hotline logs, and a footnote in Jus�ce McGregor’s report, which
states:
Settings were not changed at most sites that operated without issues. And, as we found during testing, settings
were not successfully changed at all sites that reported problems.
The fact that “settings were not successfully changed at all sites that reported problems” suggests that either
the changes were never ini�ated at some problem sites or that the changes were ini�ated but were not
successfully accepted or realized. Regardless, the data shows that the problems were not fixed- not anywhere,
and the speckled/faded prin�ng persisted un�l a�er the polls closed.
__________________________________________________________________________________________
Summary
The 100-pound paper Maricopa County chose to use for the 2022 General Elec�on was too heavy and beyond
the Oki B432dn manufacturer’s specifica�ons for duplex prin�ng. This established a pre-condi�on which was
exacerbated by the media-type erroneously set to PLAIN instead of CARDSTOCK, and further aggravated by the
under-temp premature prin�ng func�ons of ECO Mode.
In addi�on to extensive research, consulta�on with Oki-Data engineers and subject mater experts, this finding
is based upon bench-tes�ng performed using the same make/model Oki B432dn printer with the same Roland
100-pound Vote-Secure ballot paper as that used by Maricopa County. More specifically, we were able to reliably
reproduce ballots with the speckled/faded deficiency as is consistent with those produced during the 2022
General Elec�on. The defec�ve ballots were recreated using the same PLAIN media-type and Eco-Mode enabled
se�ngs described herein. The same is evidenced as those used in the 2022 General Elec�on with the pre-
elec�on BOD printer configura�on records provided by Maricopa County in response to Arizona State Senate
subpoena.
The combina�on of the three unforced errors proved fatal; however, the perfect storm was only made possible
by the preceding failure of elec�on officials to test the vo�ng center tabulators using the Ballot on Demand
printed ballots on October 11th as required by the Elec�on Procedures Manual.
Resized Ballot Image Issue
____________________________
The resized ballot image problem was the second Ballot on Demand failure experienced on Elec�on Day. The
condi�on resulted in a printed ballot image that had been resized to a point in which the ballot could not be
authen�cated. This resulted in ballots being rejected from the vo�ng center tabulators.
25
Maricopa County officials claimed that paper-size se�ngs were inadvertently changed to “print to fit” by
technicians on Elec�on Day who were atemp�ng to address the speckled prin�ng issue. Below is the relevant
sworn tes�mony by Scot Jarret, Maricopa County’s Elec�ons Director, during the Kari Lake trial: 12
A few of the other items that we've identified, though, as far as our ballot
on-demand printers, we did identify three different locations that had a fit-
to-paper setting that was adjusted on Election Day. So those were at our
Journey Church in a north Glendale/Peoria area, that had about 200 or a
little over 200 ballots had that setting on it out of about 1,500 ballots
voted at that voting location. That would be the same with our Gateway
Fellowship church, which is an east Mesa voting location. That had about 900
ballots out of just shy of 2,000 ballots voted at the voting location. And
then we had LDS church, Lakeshore, in the heart of Tempe, that had about 60
ballots out of 1,500. So just shy of 1,300 ballots, and that was due to our
temporary technicians, when they were trying to identify solutions on
Election Day, adjusting a setting -- now this was not direction that we
provided from the Maricopa County Elections Department – but adjusting that
setting to a fit-to-paper setting, and that was -- that was one of the vote
centers that was reviewed in the inspection by -- by the Plaintiffs in this
trial on Monday.
Jarret specifically iden�fies three sites that produced resized ballot images which could not be scanned by the
tabulators:
1. Journey Church ~200

2. Gateway Fellowship Church ~900
3. Church of LDS at Lakeshore ~ 60
Mr. Jarret also tes�fies that “…we did identify three different locations that had a fit-to-paper setting that was
adjusted on Election Day”, and the issue “…was due to our temporary technicians, when they were trying to
identify solutions on Election Day.”. Jarrett claims that the temporary technicians were seeking solu�ons for the
speckled/faded printer problem, and while doing so accidentally caused another prin�ng issue:
Q. Is it your testimony that the printer set changes that gave rise to this so-called shrink-to-fit issue,
was that done on Election Day?
A. That’s correct.
The problem with Scot Jarret’s explana�on during tes�mony, under oath, as to what caused the resized ballot
problem is that it is patently false. The speckled/faded prin�ng issue was isolated to the Oki B432 printers- NOT
the Lexmark printers; however, the second site Mr. Jarret iden�fied as having a resized ballot prin�ng problem,
12
A copy of the Lake v. Hobbs trial transcript is available upon request.
26
Gateway Fellowship Church, only had Lexmark printers. 13 This is established by Maricopa County’s own
records. 14 The highlighted row shows Gateway Fellowship Church vo�ng center:
Because there are no speckled/faded prin�ng problems associated with the Lexmark BOD printers, technicians
would not have been dispatched to a vo�ng center that didn’t have the prin�ng problem Jarret claims they
were trying to solve. This is corroborated by email correspondence of elec�on officials who were answering
ques�ons posed by a reporter from the Washington Post:
13
The report by Jus�ce McGregor notes that no Lexmark printers were known to produce the speckled/faded print problem: “No Lexmark printers
produced ballots that could not be read by the on-site tabulators on elec�on day due to flaking or speckling.”.
14
Extracted from “Exhibit 7” atached to Maricopa County’s November 27th leter to the office of the Atorney General.
27
Maricopa County’s confirma�on that “No Lexmark printer se�ngs were changed…” is further confirma�on that
the cause of the Print to Fit issue could not have been caused by technicians atemp�ng to troubleshoot prin�ng
problems as Scot Jarret claimed. Lexmark printers did not produce the speckled/faded prin�ng problem,
Gateway Fellowship Church only had Lexmark printers and Maricopa County confirmed that No Lexmark printer
se�ngs were changed. Yet Gateway Fellowship Church produced Print to Fit ballots.
However, it does establish that both Lexmark and Oki printers were producing resized ballots. This is
independently corroborated by Jus�ce McGregor’s report, albeit buried in a footnote:
“Unlike the problems involving the toner/fuser issue, the “print to fit” issue occasionally arose on election day
with both Oki and Lexmark printers.”
Mr. Jarret and Maricopa County elec�on officials had to have known that Lexmark printers were producing
resized, defec�ve ballots as they created the chart above showing which printers were at problem sites.
Plain�ff’s vo�ng systems expert, Clay Parikh tes�fied during the trial that the rescaled ballot issue would cause
the tabulator to yield false paper-jam errors, which is exactly what was found. False paper-jam errors are
consistent with the rescaled ballot issue at low numbers but become increasingly exclusive with increase in
frequency as natural occurrence is outperformed. The tabulator system logs reveal that the paper-jam errors
began as soon as the polls opened and con�nued unabated un�l a�er the polls closed.
See the line graph below:
28
The errors charted above remove any possibility that the resized ballot problems could have been caused or
ini�ated by technicians who had not yet been dispatched to address the speckled/faded print issue.
Second, Jarret tes�fied that the “fit to print” ballots were found at only 3 vo�ng centers:
Q. So, and I believe your testimony was that you discovered this only in
three vote center locations, correct?
A. That’s correct.
Mr. Jarret’s asser�on that resized ballots were produced at only three (3) sites is proven false by the following
four (4) substan�ated data points:
1. Plain�ff’s expert witness, Clay Parikh, tes�fied that he iden�fied resized ballots from all six (6) vo�ng
centers from where he inspected ballots, only one (1) of which was in common with the three (3)
vo�ng centers defined by Mr. Jarret.
2. Jus�ce McGregor’s report further corroborates that the rescaled ballot issue was iden�fied at
several vo�ng centers on Elec�on Day and produced by both Oki and Lexmark printers.
3. Maricopa County’s elec�on hotline call log, video evidence and Goldenrod reports iden�fy mul�ple
instances of the resized ballot problem at dozens of vo�ng centers.
4. The vo�ng center tabulator system logs show errors specific only to the resized ballot issue (“No
start marker found on either side of ballot”) at 110 of the 223 Elec�on Day vo�ng centers, totaling
a minimum number in excess of over 8,000 rejected ballots. 15
15
Other errors, such as false paper jams are also indica�ve of the resized ballot deficiency, and are in addi�on to those iden�fied by the “No start
marker” error.
29
The number of sites that produced the resized ballot images is important because, as Mr. Jarret stated during
his tes�mony, the resized ballots could not be read by the vo�ng center nor central count tabulators:
A. ...but because of the fit-to-paper setting, that actually shrinks the
size of that ballot. And then that ballot would not be tabulated onsite
at the voting location and also cannot be tabulated onsite at central
count.
Q. So if it couldn’t be tabulated at the voting location and at central

Count through the regular tabulators, what happened to those ballots?
A. So those ballots came back to the central count facility, and then we had
hired duplication boards, a bipartisan team, Republicans and Democrats,
to duplicate that ballot.
Jus�ce McGregor’s report affirms the same:

Another printing anomaly occurred at several vote centers, where ballots were re-sized as “fit to page,” a process
that entirely changed the location of the timing marks on the ballots and assured that neither the on-site tabulators
nor the central count tabulators could read the ballots.
The only way to tabulate the resized ballots was to copy the contest selec�ons from each defec�ve ballot to a
new ballot of proper size through a process called duplica�on. 16 The 2022 General Elec�on duplica�on process
is explored further in its own sec�on.
The disingenuous explana�ons put forth by Maricopa County elec�on officials and their concealment/failure to
be forthcoming about the printer failures, raise red flags. What’s also concerning is the following paragraph of
Jus�ce McGregor’s report:
We could not determine whether this change resulted from a technician attempting to correct the printing
issues, the most probable source of change, or a problem internal to the printers. During our testing, four
printers randomly printed one or a few “fit to page” ballots in the middle of printing a batch of ballots. None
of the technical people with whom we spoke could explain how or why that error occurred.
The four printers which produced the “fit to page” ballots during McGregor’s tes�ng were not from the three sites Jarret
claimed were the only ones to produce the resized ballots. This fact establishes that the resized ballots were produced at
addi�onal vote centers and could not be counted without being duplicated. This is explored further in the sec�on �tled
“Duplica�on”.
Using several data points, including Maricopa County’s response to the Arizona Atorney General, sworn tes�mony of Scot
Jarret, sworn tes�mony of Elec�on System’s Expert, Clay Parikh, vo�ng center tabulator system logs, and tes�ng results
16Duplica�on should not be conflated or confused with adjudica�on, a different process in which a panel tries to determine voter intent on an
ambiguously marked contest or ballot.
30
as documented in the McGregor report, this inves�ga�on has established that the resized ballot anomaly was not caused
by “…a technician attempting to correct the printing issues”.
__________________________________________________________________________________________________
Summary
Like that of Jus�ce McGregor, our inves�ga�on has been unable to ascertain the specific cause of the resized ballot issue.
Because it has now been established that both Oki and Lexmark BOD printers were afflicted, and not caused for the reasons
provided by Maricopa County, the scope of inves�ga�on must be expanded to include the following four possible root
causes or conduits:
1. Printer firmware
2. Printer drivers
3. Sen�o BOD printer management system purchased from Runbeck Elec�on Services
4. Maricopa County’s proprietary electronic poll books (SiteBook).
Although unresolved, the mater has inexplicably been dismissed by Maricopa County without referral for further
inves�ga�on, expert inquiry, or any other means of review to determine the cause of the anomaly. Not an anomaly which
remained elusive or that couldn’t be realized, but confirmed as it was reproduced by four (4) of the ten (10) par�cipa�ng
Ballot on Demand printers during tes�ng, albeit intermitently.
Machines are consistent, especially those managed by electronic processors. Failure of an electronic device is almost
always isolated and due to component malfunc�on or end of life. Random or intermitent failures of mul�ple electronic
devices across two (2) separate hardware pla�orms suggests malware, electronic manipula�on, or in the instant context,
poten�al malfeasance. This is bolstered by Jus�ce McGregor’s statement, “None of the technical people with whom we
spoke could explain how or why that error occurred.”. Likely because there are no known natural explana�ons or causes
for printers to intermitently produce resized images, and the scope of poten�al causes is narrowed significantly when the
anomaly occurs across two separate hardware pla�orms.
Conclusion
By all accounts, except those of Maricopa County elec�on officials, both Ballot on Demand printer failures began as soon
as the polls opened, and system logs defini�vely establish that the failures affected many more vo�ng centers than
Maricopa County or the McGregor report underes�mate and admit. The records, system logs, hotline call logs, and poll
workers conclusively establish that the prin�ng problems were never mi�gated, much less remedied. The speckled/faded
prin�ng issue was caused by a combina�on of unforced errors that were known to the county before Elec�on Day. The
Print to Fit, or resized ballot prin�ng anomaly, intermitent and across two different brands of printers, strongly suggests
malware, manipula�on or malfeasance. Maricopa County’s dismissal of this condi�on without successful resolu�on is not
an acceptable response especially considering the printers are part of, and tethered to, vo�ng systems which have been
deemed cri�cal infrastructure.
_________________________________________________________________________________________________
31

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ELECTION OVERSIGHT GROUP, LLC. KEVIN MONCLA I (469)-588-7778 I KMONCLA@GMAIL.

MARICOPA COUNTY ELECTION DAY PRINTER FAILURE INVESTIGATION REPORT

Resized Ballot Images

Representa�ve of Maricopa County’s resized ballot issue

Maricopa County’s Prin�ng Problems & Dominion’s Tolerances

Maricopa County Rejected Ballot Dominion’s Example Problem Ballot Example

to leave no room for mistake, human error, or excuse.

Changes Between Primary and General Elections

Causes of the Elec�on Day Prin�ng Failures

From the Oki B432 Operator’s Manual:

“The paper weight capable of duplex printing is 60 to 120 g/m2.”

The speckled-printing issue is squarely defined in the Oki printer manual:

The McGregor report continues:

10 The Declara�on of Janet Patrick is available upon request.

The pertinent portion of the Declaration corroborates two important points: 11

Resized Ballot Image Issue

1. Journey Church ~200

Q. So if it couldn’t be tabulated at the voting location and at central

Jus�ce McGregor’s report aﬃrms the same:

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