ELECTION OVERSIGHT GROUP, LLC. KEVIN M. MONCLA 469-588-7778 I ROCHELLE M.

CABIRAC 469-207-5563 Page 1

Privileged and Confidential 10/23/2023/KM

REPORT OF INVESTIGATION
&
VERIFIED SUPPLEMENTAL COMPLAINT
__________________________________________________________________

INVESTIGATION OF THE FULTON COUNTY 2020 GENERAL

ELECTION IRREGULARITIES & FAILURES OF THREE COUNTS
__________________________________________________________________

EXECUTIVE SUMMARY

Georgia’s 2020 General Election was not accurate, not credible, and the results cannot be verified.
Core election records, including ballot images and logs have been destroyed; however, over the
course of what has been a two-plus year investigation, many determinations have been made.
Although this report is primarily focused on Fulton County, the problems documented herein do
not stop at the county line. Forthcoming reports will detail the deficiencies in other counties.
Georgia’s elections do not have checks and balances. There are no layers of redundancy or even
basic accounting. The safeguards one would expect to be inherent in the process do not exist.
Here are the facts:
Fulton County’s Original Count results include the votes of 20,713 early voting ballots for which
there are no poll tapes, ballot images, recap sheets or other records, whatsoever. What’s more, at
the end of early voting the security seals were broken and the memory cards were removed from
all early voting tabulators. When the polls closed on Election Day the memory cards were inserted
into surrogate machines and fraudulent poll closing tapes were printed. Those poll tapes for nearly
300,000 ballots were never signed, witnessed or certified as required by Georgia law.
This bears repeating. The legal hard-copy representation of nearly 300,000 ballots cast during early
voting in Fulton County, were unlawfully printed from different tabulators which produced poll
closing tapes bearing a different serial number and protective counter (tabulator odometer) number
than that of the machine that scanned the ballots.
ELECTION OVERSIGHT GROUP, LLC. KEVIN M. MONCLA 469-588-7778 I ROCHELLE M. CABIRAC 469-207-5563 Page 2

The 138 unlawfully produced and fraudulently identified poll closing tapes were not signed, they
were not witnessed, and they were not certified. Additionally, ten tabulators and the votes of
20,713 ballots, have no poll tapes, ballot images or any other substantiating records. In any other
facet of life, the uncertified, false, and fraudulent record of 313,885 ballots would render the Fulton
County Certification of the 2020 General Election results “void ab initio”, or void from the
beginning.
The results of the hand count/audit have been used by Georgia election officials to substantiate the
results of the Election Day count because “they match”; however, such validation no longer exists.
36 errors were identified by Mr. Joseph Rossi which were validated by the Governor who referred
the matter to the Georgia State Election Board (“SEB”). The SEB referred the complaint to the
Georgia Attorney General who also validated the 36 errors and the over 6,000 false votes added to
the Presidential race that did not exist.
Similarly, the results of the Recount as submitted at midnight December 02, 2020, was short some
17,000 ballots as compared to the official results of the Original Count. Nearly all of the shortfall
was somehow found and scanned the following night. Strangely, some 17,000 ballot images are
missing from the official record.

THE THREE COUNTS

Georgia’s 2020 General Election included three (3) separate counts:

1. November 3rd count (“original count”)
2. Hand Count / Audit
3. Machine Recount

1. ORIGINAL COUNT
Fulton County’s 2020 General Election included nearly three (3) weeks of in-person Advance
(early), Absentee by Mail, drop-box, and Election Day voting.
A private post-election investigation attempted to verify the results by acquiring all election
records, including the ballot images and the tabulator poll tapes. It was quickly discovered that
Fulton County failed to save and preserve the in-person ballot images. 1 The only ballot images
that Fulton County properly preserved in accordance with state and Federal law were the
Absentee/Drop-Box ballots. All ballot images for in-person voting were destroyed.
Failing the ballot images, next sought were the tabulator poll tapes. There are primarily
two (2) types of poll tapes- a poll open or “zero” tape, and a poll close tape. An open tape is printed
before the polls open to establish that no ballots or votes are counted on each tabulator. A poll close
tape is printed when the polls close on election night and is similar to a receipt for each tabulator.

1 See Fulton County’s responses to Request for Admissions: Fulton County Request for Admissions2 | PDF (scribd.com)
ELECTION OVERSIGHT GROUP, LLC. KEVIN M. MONCLA 469-588-7778 I ROCHELLE M. CABIRAC 469-207-5563 Page 3

which shows the number of votes counted for each contest. The poll closing tape is the legal, hard-
copy record of the tabulator count.
In response to Open Records Requests, only nine (9) open tapes and 138 unsigned,
uncertified poll close tapes (printed on surrogate tabulators) were returned for early voting. 2 After
all tapes were logged, verified, and totaled, it was determined that there were no tabulator poll
closing tapes for 20,713 ballots. Using the Cast Vote Record (CVR) and a report generated by the
Dominion election system called a “Batches Loaded Report” (“BLR”), the ten outstanding
tabulators were identified. An Open Records Request for the ten identified and outstanding
tabulator tapes was submitted to Fulton County. In response, Fulton County stated no such records
exist. After a series of phone calls and emails, the Records Custodian was asked if the tabulator
tapes were lost, destroyed, or do not exist. The response from Fulton County was that the requested
records “do not exist”.
Subsequent efforts to validate the existence of the 10 early voting tabulators proved
unsuccessful. In fact, the tabulators are not reflected in Logic & Accuracy testing records, nor
equipment distribution, pick-up schedules, or logs. There are no ballot images, scanner recap
sheets, poll open tapes, poll closing tapes, tabulator system logs nor any other records which
document the existence of the ten machines. No records exist- except the unsubstantiated
electronic results of 20,713 “ballots” attributed to the phantom tabulators.
During the course of what has been an over two (2) year investigation, we have uncovered
and meticulously documented multiple failures with regards to the 2020 General Election, which
include:
a. No Logic & Accuracy testing was performed on any of the voting equipment used for
Advance Voting in violation of Ga. Comp. R. & Regs. 183-1-12-.08. 3

b. The Georgia Secretary of State changed the protocol for Logic & Accuracy testing from
the process specified in the 2020 Procedures Manual to a “truncated” process for the
Election Day voting equipment. This issue was raised in the Curling v. Raffensperger
case pending in Federal court. Judge Totenberg stated the following in her October 11,
2020, Order:

“…the Secretary of State’s January 2020 Procedures Manual is plainly

inconsistent with the state statutory objective and requirements. The issue before
the Court, though, is not whether any particular set of procedures is in full
compliance with state law or a mere error in judgment by the Secretary of State’s
Office. Voters do not have a First or Fourteenth Amendment constitutional right
to perfect implementation of state statutory provisions guiding election
preparations and operations. But they do have the right to cast a ballot vote that

P Poll closing tapes for advance vo�ng can be found here: Fulton 2020 Av Poll Tapes Cer�fied | PDF | Elec�ons (scribd.com)
3 Exclusive: Majority of Early Vo�ng in Fulton County Done on Untested Machines - UncoverDC
ELECTION OVERSIGHT GROUP, LLC. KEVIN M. MONCLA 469-588-7778 I ROCHELLE M. CABIRAC 469-207-5563 Page 4

is properly counted on machinery that is not compromised or that produces

unreliable results. L & A testing is not complex. It is tedious –but it is essential
homework that protects the system and voters as the elections commence.”

c. Logic & Accuracy testing was performed in-private and without providing the public
proper notice in violation of Ga. Code § 21-2-379.25 (“Public notice of the time and
place of the test shall be made at least five days prior thereto”).

d. Logic & Accuracy testing was conducted and overseen by an unauthorized 3rd party,
named Ryan Macias along with several others working on behalf of the Elections
Group. 4 What’s more, under the direction of Mr. Macias, Dominion technicians
performed the mandatory testing at the cost of $2,000 per technician, per day, and totaled
more than $2,000,000.00. 5

e. Ballot Marking Devices were reprogrammed across the state only days before the 2020
General Election with software that had not yet been tested nor submitted to the Election
Assistance Commission for approval.

f. Precinct tabulator memory cards were unlawfully replaced during a live election while
the polls were open, and for reasons other than the excuses subsequently provided by
election officials (storage capacity and lacking sufficient tabulator inventory- both
disproven). 6 It is important to note that this practice was not exclusive to just Fulton
County but repeated in at least the three next-largest counties. Cobb, DeKalb, and
Gwinnett also inexplicably replaced tabulator memory cards in violation of Ga. Comp.
R. & Regs. 183-1-14-.02.

g. At the end of early voting on October 30, 2020, the zip-tie seals were cut, and the
memory cards were unlawfully removed from all tabulators. After the polls closed on
Election Day the memory cards were inserted into surrogate machines on which the
polls were closed and the poll closing tapes were printed. 7 Mandatory reconciliation of
the tabulator totals with the corresponding written logs (Scanner Recap sheets) as
prescribed by Ga. Comp. R. & Regs. 183-1-14-.02, was entirely circumvented.

h. The surreptitious process masked the serial number and protective counter (tabulator
odometer) of the scanning tabulator, thereby rendering the critical processes of basic
election accounting, reconciliation, and verification impossible. The actions detailed in
this section were in violation of Ga. Comp. R. & Regs. 183-1-14-.02.

4 An Open Records Request for all contracts or agreements with or including Ryan Macias was submited to Fulton County, who returned “No

such Records”.
5 Fulton County Paid Dominion $2M to Staff and Run Elec�ons At Rate of $2k+/Person/Day - UncoverDC
6 See corresponding SEB complaint file on March 28, 2022, here: Fulton County Early Vo�ng Complaint | PDF (scribd.com)
7 Separately detailed in the above-referenced complaint.
ELECTION OVERSIGHT GROUP, LLC. KEVIN M. MONCLA 469-588-7778 I ROCHELLE M. CABIRAC 469-207-5563 Page 5

i. 138 fraudulently produced, unsigned, unwitnessed, and uncertified tabulator poll

closing tapes, representing all of the approximate 293,172 ballots purportedly cast
during the course of in-person early voting, make up the official record. 8

j. As described in the opening section, no poll tapes and no other records exist for ten
Advance Voting tabulators and approximately 20,713 ballots purportedly attributed to
the illusive machines.

k. Of the 148,318 Absentee ballot images (produced under court order), only 16,038 have
a corresponding SHA (Secure Hash Algorithm) ballot image authentication file. 9 It is
important to note that the absence of these select files is not possible due to mistake and
is highly suspect. 10

1. The data of the ballot image files described above also suggest tampering for several
reasons, including last modified timestamps, speed of transfer times, and the fact
that the machines were programmed to send all Absentee ballots to adjudication. 11
2. There also exists strong evidence which suggests that the ballot image files were
replaced with different image files of the same name.
3. Fortuitous is the fact that such manipulation would be detected with the SHA ballot
image authentication files curiously missing from the official record (as produced
by Fulton County under Court Order).

l. Fulton County, among many others, failed to preserve all ballot images for in-person
voting. 12

Under a Court Order in the Curling v. Raffensperger case, Fulton County produced the
election records for the 2020 General Election and Recount to the Curling Plaintiffs. The
Declarations of two highly respected subject matter experts, Philip Stark, and Duncan Buell, were
filed in the case each after performing their own independent analysis of the election records
produced by Fulton County. 13 From the Declaration of Duncan Buell (at 7):
“In Fulton County ballot images and their attached “AuditMark” tabulation
interpretations are missing for approximately 360,000 BMD ballots and 6.4 million
BMD votes they contain for in-person voting for the official certified count of all
down ballot races.; Such electronic files are essential when testing the election
records for consistency and accuracy. Significant numbers of missing files inhibits
a complete authoritative analysis of causes or effects of potential impacts of

8 A true and correct copy of all 138 tabulator tapes for in-person Advance Vo�ng as cer�fied by the Fulton County Custodian of Records can be

found here: Fulton 2020 Av Poll Tapes Cer�fied | PDF | Elec�ons (scribd.com)
9
Fulton County Ballot Image: What a SHAm! - UncoverDC
10 A true and correct copy of the Declara�on of elec�on systems and data expert, Duncan Buell, can be found here: 20220111 Buell Expert

Report Final Served | PDF | Elec�on Recount | Vo�ng (scribd.com)

11 (2) Fulton County 2020 Absentee Ballot Results Were Physically Impossible and Files Were Modified (substack.com)
12
See a true and correct copy of Fulton County’s responses to a request for admissions filed in the Curling v. Raffensperger case: Fulton County
Request for Admissions2 | PDF (scribd.com)
13 The Declara�on of Philip Stark can be found here: Philip Stark CGG 9 | PDF | Government (scribd.com)”; The Declara�on of Duncan Buell can

be found here: Buell Expert Report Final Served | PDF | Elec�on Recount | Vo�ng (scribd.com)
ELECTION OVERSIGHT GROUP, LLC. KEVIN M. MONCLA 469-588-7778 I ROCHELLE M. CABIRAC 469-207-5563 Page 6

malware, software bugs, equipment malfunction, human error or malfeasance by

insiders.”
Considering the state and federal legal requirements for preservation of election records, the
failure of counties and the state to preserve core election records is not only unlawful, but highly
suspect.

SUMMARY
The Fulton County Board of Registration and Elections (FCBRE) officially certified the 2020
General Election results based on 138 fraudulent, unsigned, unwitnessed, and uncertified (blank)
poll tapes representing 293,172 ballots, along with no poll tapes or provenance whatsoever for an
additional 20,713 ballots.
Certification of election results based on uncertified records is unjustifiable.
Fulton County’s November 03, 2020, election results are not supported by records or fact. Not
just technically, but materially, and overwhelmingly. Fulton County’s official results of the
November 3rd General Election Original count quite literally rest on nothing more than
unsubstantiated, unverifiable, and unlawfully derived numbers ceremoniously adopted by a blind-
folded county election board; however, certifying that something is true and correct without
performing the due diligence required to ensure it is in fact true and correct, is fraudulent.

2. HAND-COUNT-AUDIT
By statute, a Risk Limiting Audit (“RLA”) was required to be performed following the
2020 General Election. The Secretary of State, for whatever reason, decided to perform a full hand
count/audit. Georgia state election officials have repeatedly stated that all of the ballots were
counted by hand, and that the results matched. It has been claimed repeatedly that the hand count
audit results verified the original count results. The fact is that the results of the two counts did
not match.
UNCOUNTED BALLOTS
First, during the hand-count audit uncounted ballots were found in the following counties:
1. Fayette County 2,755 14
2. Floyd County 3,060 15
3. Douglas County 293 16
4. Walton County 284 17
A total of 6,392 ballots were found that had not been counted or included in the original count.
Gabriel Sterling says that the discoveries are evidence that the system is working:

14
Second Georgia county finds previously uncounted votes | AP News
15 Floyd County Finishes Hand Recount, Adding 3,060 Votes - Coosa Valley News
16 293 votes found during hand recount in Douglas | Local News | douglascountysen�nel.com
17 4th Georgia county finds uncounted votes as hand count deadline approaches (news4jax.com)
ELECTION OVERSIGHT GROUP, LLC. KEVIN M. MONCLA 469-588-7778 I ROCHELLE M. CABIRAC 469-207-5563 Page 7
"The hope is we don’t find any more of these counties with you know, a couple of hundred
here or 3,000 votes there, but the reason you do the audit is to find these kinds of human
errors and then make sure that they are corrected,” 18
Mr. Sterling’s logic is simply wrong. The 6,392 ballots that were found during the hand count were
not known to exist until they were discovered. This is only possible in the absence of basic election
accounting and reconciliation. Traditionally, upon the closing of the polls the number of voters
that check-in at a polling location, the number of paper ballots, and the number of ballots cast as
calculated by the voting machine are compared. These three numbers should match. Like the 3
legs of a stool, they must all be equal. Had proper accounting and reconciliation been performed
at the polling location it would have been immediately clear that ballots remained outstanding and
uncounted.
The belated discovery of uncounted ballots in just one county is in and of itself indicative
of failure. Finding uncounted ballots in (at least) 4 separate counties strongly suggests the
existence of a widespread and systemic problem. Georgia election officials contend that all ballots
were hand counted but do not define “all”. There was no metric with which to gauge how many
ballots were supposed to be counted because there was no reconciliation or accounting,
whatsoever.
The reason that the hand count/audit results seemed to “match” those of the original count is
because the counties’ results were recertified to include the uncounted ballots that were found. In
short, the results of the first count were changed after the fact to match the hand count. The hand
count audit did not verify the election results of the original count.
Third, the hand count/audit was not conducted entirely by hand. Batches of ballots were
counted by hand and then the totals were entered into a state-wide audit software program called
ARLO. The software was provided by VotingWorks who was contracted by the Secretary of State.
The software performed the aggregation of the data and then provided counties with their results.
This was not an organic “bottom-up” exercise, but the opposite. Berkeley Prof. Philip Stark, Ph.D.,
inventor of the Risk Limiting Audit and highly respected election systems and processes expert
stated the following about Georgia’s hand-count/audit in a Declaration filed in the Curling v.
Raffensperger case: 19
“Fulton County’s chaotic, unaccountable curation and processing of cast ballots,
cast BMD printout, and electronic records make a true risk-limiting audit
impossible. It is unreasonable for voters to trust that their votes were counted at
all, much less counted correctly. Voters have good reason to believe that some votes
counted more than others: some votes were included twice or thrice in the totals.
There is no way to know how many votes were omitted from the tabulation, absent
access to the physical ballots and BMD printout and evidence that the chain of
custody is intact. From the records produced so far, it is impossible to determine
whether malware, bugs, misconfiguration, or malfeasance disenfranchised voters
or altered the election results.”

18 Refu�ng falsehoods, Georgia elec�on officials defend integrity of audit, elec�on - Good Morning America
19 A true and correct copy of the Declara�on of Philip Stark can be found here: Philip Stark CGG 9 | PDF | Government (scribd.com)
ELECTION OVERSIGHT GROUP, LLC. KEVIN M. MONCLA 469-588-7778 I ROCHELLE M. CABIRAC 469-207-5563 Page 8

FULTON COUNTY’S THIRTY-SIX DOCUMENTED HAND-COUNT ERRORS

The hand count audit records have since been found to be riddled with errors. Two Georgia
voters, Mr. David Cross and Mr. Joseph Rossi, found multiple discrepancies, duplications, and

mistakes in Fulton County’s hand count records. Mr. Rossi specifically documented thirty-six
errors and provided the same to Georgia Governor Brian Kemp for further review. Over a period
of several weeks the Governor’s office recreated and verified Mr. Rossi’s findings, and on
November 17, 2021, Governor Kemp issued a letter referring the matter to the State Election Board
for investigation. 20 In addition, the Governor provided a report detailing each of the 36
inconsistencies as verified by his office. 21
Only for the relentless efforts of Mr. Rossi over a period of some nineteen months, the
matter known as SEB 2021-181 resulted in quiet confirmation of the errors. This came in the form
of a privately negotiated consent agreement between the Georgia Attorney General and Fulton
County. The same was ratified and adopted by the State Election Board on June 21, 2023, by a
four-to-one vote. 22 What’s interesting is that three (3) members of the board voted to adopt the
agreement sight unseen. At the time of the vote, only former Chairman William Duffey had read
the consent agreement, to which the former Federal judge failed to provide the members of the
board.
What’s more, it was discovered by the complainant that at least some of the board members did
not have access to the consent agreement at the time of the vote, therefore he inquired with the
other board members. Email records show that subsequent to the complainant’s inquiry, Chairman
Duffey proceeded to interrogate and intimidate the board member who disclosed the facts. When
asked by the complainant if the board member had read the consent agreement, she simply
answered honestly and said that she “didn’t have it”. It is clear from the ensuing email exchange
that Chairman Duffey was only concerned, not with the merit of the problem, but only how it was
leaked.
Although the agreement did acknowledge the fact that Fulton County made errors in their
hand count audit, the details and magnitude of those errors were omitted. It was only said that the
errors were unintentional, and the result did not change the outcome of the race. The fact is that
the result of the twice-verified 36 inconsistencies falsely attributed 5,618 votes to Joe Biden, and
1035 votes to President Trump that did not exist. 23 The net result of the hand count corrections
reduced the margin of victory by 4,583 votes, from 11,779 to 7196 in one county alone. It is also
interesting that 35 of the 36 errors, and eighty percent of the false votes favored Joe Biden.

20 Brian Kemp Georgia SEB Leter Joe Rossi 11.17.2021 (1) | PDF (scribd.com)
21 Brian Kemp Audit Inconsistencies Report Joe Rossi 11.18.2021 | PDF | Absentee Ballot | Evalua�on Methods (scribd.com)
22
Signed - Consent Order SEB 2021-181 and 2022-025 (Fulton County) With Exhibit A - Redacted | PDF (scribd.com)
23 A true and correct copy of the 36 errors and the itemized breakdown of votes is available upon request.
ELECTION OVERSIGHT GROUP, LLC. KEVIN M. MONCLA 469-588-7778 I ROCHELLE M. CABIRAC 469-207-5563 Page 9

Lastly, the consent agreement failed to take any punitive or even corrective action. Fulton County
is simply required to do what it was already required to do- follow the law. Sadly, the agreement
does not even require Fulton County to publicly correct the official hand count/audit results, nor
those on the SOS’s website.

SUMMARY
In conclusion, the hand count audit did not verify nor authenticate the results of the original
count. It has now been officially established that there is a difference of at least 6,695 votes
between the original count results and that of the hand count, after a private audit of only one
county (not including the changes/corrections made to the original count results for the 6,392
ballots that were found). The hand count/audit is now an official benchmark to show that the
Original Count was not credible. From the Declaration of Philip Stark: 24
“A rigorous audit can provide confidence that a well-run election found the true
winner(s). But it cannot compensate for using untrustworthy technology to record
votes or for a poorly run election; in such circumstances, it distracts attention from
the real problems rather than improving election integrity and justifying confidence
in electoral outcomes. Absent a trustworthy record of the votes, no procedure can
provide affirmative evidence that the reported winner(s) really won. Georgia lacks
such a record, for many reasons, including the heavy reliance on BMDs and the
lack of physical accounting of ballots, memory cards, and other election materials;
lack of pollbook and voter participation reconciliation; etc.

By claiming to perform risk-limiting audits when its paper trail is not trustworthy,
the State of Georgia is in effect adding stories to a building that needs its foundation
replaced. First things first.”

This begs the question as to how the results of the original count and those of the hand count were
said to have matched before these “errors” were discovered? The only plausible explanation is
that the 6,695-vote discrepancy was not the product of mistake. Furthermore, the hand count/audit
no longer props up the results of the discredited original count, but instead provides further cause
to question those results.

3. MACHINE RECOUNT
Following the certification of the November 3, 2020, General Election, President Trump’s
campaign requested an official recount which is referenced herein as the Recount. Pursuant to
Georgia Law, a recount is performed by machine. The Recount began on November 24, 2020, and
lasted until the prescribed deadline of midnight Wednesday, December 2, 2020.

24 A true and correct copy of the Declara�on of Philip Stark can be found here: Philip Stark CGG 9 | PDF | Government (scribd.com)
ELECTION OVERSIGHT GROUP, LLC. KEVIN M. MONCLA 469-588-7778 I ROCHELLE M. CABIRAC 469-207-5563 Page 10

With only minutes to spare, Fulton County submitted the results of the Recount. At approximately
12- noon the following day, Fulton County Elections Director Rick Barron sends an email to Ryan
Macias with the recount results attached, totaling 511,543 votes. 17,234 votes less than the
November 3rd original count. 25 Between the time of the email and the official certification of the
recount results some 24 hours later, Fulton County found 16,382 votes, -nearly all of the shortfall.
The details which yielded the vote difference during the interim period is the subject of a complaint
filed with the SEB-2023-025 (July 08, 2022), which, at the time of this writing, remains under
investigation. 26
Through an exhaustive and multi-faceted investigation and analysis, the recount results verifiably
include 17,852 votes with no corresponding ballot images. In addition, 3,125 ballots were found
to have been counted twice. The 17,852 unsubstantiated votes, plus the 3,125 duplicates, together
total 20,977 illegitimate votes which were included in the Recount results. It is important to note
that the Recount is the only official results for the contest of the Office of the President.
As detailed in the first section, the original November 3rd count includes the results of
20,713 ballots for which there are no ballot images, corresponding tabulator poll open or close
tapes, nor any other substantiating documentation whatsoever. Like that of the original count, the
Recount includes the results for 20,977 ballots for which there are no ballot images or any other
documentation.

ILLEGITIMATE BALLOT BREAKDOWN AND VOTE DISTRIBUTION

BALLOT RECORDS WITH NO BALLOT IMAGE

Using the Cast Vote Record (CVR), Batches Loaded Reports for the Recount, and the ballot
images for the Recount (produced under court order), 17,852 records with no corresponding ballot
images were identified. 27 From these records, the corresponding votes which were recorded for
the contest of President of the United States were counted and the sum for each candidate is shown
below.

SUM OF RECORDED VOTES FOR RECORDS WITH NO BALLOT IMAGES:

25 582622243 Moncla and Rossi Complaint 07/08/2022 | PDF | Elec�ons | Science (scribd.com)
26
Case Number 2023-025 582622243 Moncla and Rossi Complaint 07/08/2022 | PDF | Elec�ons | Science (scribd.com)
27
See list of all 17,852 Cast Vote Records (CVR) for which there are no corresponding ballot images, here: Fulton County Recount Missing Ballot
Images | PDF | Federal Elec�ons Of The United States | Democracy (scribd.com)
ELECTION OVERSIGHT GROUP, LLC. KEVIN M. MONCLA 469-588-7778 I ROCHELLE M. CABIRAC 469-207-5563 Page 11

DUPLICATE BALLOT IMAGES

Duplicate and triplicate ballot images were identified using a combination of methods, such
as identification of 2 or more batches in the Cast Vote Record (CVR) with mirrored series of ballot
types in the same sequential order.

For the Recount all ballots were scanned in batches each containing approximately 100-300
ballots. Different ballot styles (for different precincts, etc.) each have a unique code called a Ballot
ID or Combo Code. The CVR data shows each batch and each ballot’s Ballot ID or Combo Code
in the order in which it was scanned. Therefore, batches are searched for matching series of Ballot
ID’s or Combo Codes that have been scanned more than once. The ballot images are then visually
compared side by side to determine if the two images are of the same ballot. Prof. Philip Stark
made the following statement regarding the duplicate ballot images in his Declaration: 28

“The full extent of this multiple-counting problem cannot be determined without

additional discovery, but there is ample evidence that it added thousands of bogus
votes to the reported machine-count results. That is, thousands of Fulton County
voters’ votes were included in the reported totals more than once.”

The Recount includes 3,125 verified duplicate ballots that were in fact counted. 29 The
records for each of the duplicated ballots were identified. From these records, the recorded votes
for the contest of President of the United States were counted and the sum for each candidate is
shown below:

SUM OF RECORDED VOTES FOR VERIFIED DUPLICATE BALLOTS:

RECONCILIATION OF RESULTS

28 A true and correct copy of Philip Stark’s Declara�on can be found here: Philip Stark CGG 9 | PDF | Government (scribd.com)
29 Data set available upon request.
ELECTION OVERSIGHT GROUP, LLC. KEVIN M. MONCLA 469-588-7778 I ROCHELLE M. CABIRAC 469-207-5563 Page 12

When corrected for the documented illegitimate ballots in Fulton County alone, the margin of
victory for the race for President of the United States is reduced to 2,526 votes.

EVIDENCE OF ELECTION RESULTS MANIPULATION

DIFFERENT BALLOTS SCANNED FOR ORIGINAL & RECOUNT

The paper ballots scanned and counted for the original count, are in large number, not the
same paper ballots as those scanned and counted for the Recount. What follows are three separate
metrics of different data points that are calculated and recorded for each of the two counts and then
compared.

It is important to note that the variables contemplated herein are immutable characteristics which
should not deviate from the Original Count to the Recount. Unfortunately, analysis of Fulton
County’s own records reveal that is not the case. Each separate comparison corroborates the next
and to the ultimate conclusion that not only do the two counts fail to mirror one another, but that
the official records fail to support either count.

1. BALLOTS UNIQUE TO ORIGINAL COUNT & RECOUNT- NOT COMMON TO BOTH

A digital signature was created for each ballot record (variables include ballot style,
precinct, contest selections, voting method, etc.). The quantity of each unique
signature was calculated for each count and then compared. This process revealed
many ballots which were included in only one count.

a. At least 10,196 ballots are included in the Original Count that are not included in
the Recount.
b. At least 9,345 ballots are included in the Recount that are not included in the
Original Count.

c. A total of 19,541 ballots are in one count and not the other.

The same ballots should appear in both the Original Count and the Recount. The total
number of ballots unique to each count are in question and far surpass the margin of
victory.
ELECTION OVERSIGHT GROUP, LLC. KEVIN M. MONCLA 469-588-7778 I ROCHELLE M. CABIRAC 469-207-5563 Page 13

2. BALLOTS WERE ATTRIBUTED TO DIFFERENT PRECINCTS FOR EACH COUNT

Ballots are each printed with a Ballot ID that is unique to only one precinct. Therefore,
the same number of ballots should be attributed to the same precincts for both the
original count and the Recount.
a. 125 precincts received a total of 1,983 more ballots for the Recount than the
original count.
b. 215 precincts received a total of 2,835 less ballots for the Recount than the original
count.
c. A total of 4,818 ballots which were attributed to different precincts between the
two counts.

FIVE EXAMPLE PRECINCTS:

Any change in the number of ballots attributed to a precinct from the original count to
the Recount is inexplicable as Ballot ID and precinct are fixed, immutable
characteristics. The wholesale changes documented here can only be explained by
electronically manipulated results or through the scanning of different ballots. There
is no third option.
ELECTION OVERSIGHT GROUP, LLC. KEVIN M. MONCLA 469-588-7778 I ROCHELLE M. CABIRAC 469-207-5563 Page 14

3. VOTER CREDIT DOES NOT MATCH BALLOTS CAST FOR EITHER COUNT

When a voter returns an Absentee by Mail ballot, or when a voter checks-in at a

polling location, the voter receives “credit” for voting. In other words, the Voter
History File (VHF) is updated to show that a particular voter cast a ballot. Each voter
can only be associated with one type of ballot style that is called a Ballot ID. All
people living at the same location will have the same Ballot ID. Whereas someone in
a separate school district or other designation will have a different Ballot ID with
corresponding contests on their ballot.

A Voter’s precinct and Ballot ID are irrevocably tethered and therefore when a ballot
is cast, the corresponding voter credit and cast ballot should always be attributed to
the same precinct.

Fulton County’s election records reveal wildly different attributions of voter credit
from the Original Count to the Recount. 30 Moreover, the VHF doesn’t match either
count when there should be no significant variance between voter credit and ballots
cast at all.

The fact that there is such deviation between variables that should reconcile and
remain static for both counts is indicative of manipulation. The fact that voter credit
and ballots cast are changing from one count to the next essentially rules out any type
of error as the error would remain constant.

It’s important to note that the numbers for this analysis – including both counts and
the VHF are from the Georgia Secretary of State. Please see the attached spreadsheet
for the breakdown of each precinct and the corresponding ballots cast versus voter
credit attached hereto as “Exhibit F”. This too can only be explained by electronically
manipulated results or through the scanning of different ballots. There is no third
option.
4. INTENTIONAL MANIPULATION

Through an ongoing collaborative effort with P. Davis, thousands of ballots have been
identified across multiple counties that appear only in the Recount and not the original

30 Source of data set available here: Georgia Elec�on Results | Georgia Secretary of State (ga.gov)
ELECTION OVERSIGHT GROUP, LLC. KEVIN M. MONCLA 469-588-7778 I ROCHELLE M. CABIRAC 469-207-5563 Page 15

count. This includes hand-marked paper ballots, QR code ballots, duplicate ballots
and ballots which only have votes for the Presidential race. What’s more, these ballots
with only votes for the Presidential race often appear together in batches with others
of the same type and include ballots for multiple precincts within the same batch. It is
important to note that there is no known plausible explanation for this and can only be
interpreted as a coordinated and intentional effort to falsely manipulate the results of
the Recount.

Although our analysis and investigation is ongoing and overall scope remains
unknown, there is sufficient evidence to warrant an investigation by the State Election
Board. Supporting evidence and a preliminary report is being drafted and will be
forthcoming in the coming days.

CONCLUSION

The major failures, anomalies, and irregularities documented in this report for each of the three
counts render the Original Count, the hand-count/audit, and the official Recount results,
impossible. As established, there is no verifiable election record to support Fulton County’s 2020
General Election results. The records that do exist are either conflicting, irreconcilable, or both.
Furthermore, there is no way in which the existing election records were naturally created and
have certainly been manipulated.