Case 1:17-cv-02989-AT Document 579 Filed 08/15/19 Page 31 of 153
adjustments in the display of the database, which requires us to
touch the database again.
(Id. at 165-67.) This is entirely contrary to the following testimony Mr. Barnes
gave to this Court in the September 2018 hearing, just shy of two months prior to
the November election:
Q. Do state workers type in every race and candidates’ name into the
GEMS server?
A. Yes, sir.
Q. So that is how the data gets loaded?
A. Yes, sir. It is all manual entry.
(Tr., Doc. 307 at 226-27.) Despite his testimony in September 2018 that the
entire ballot building process is done in-house on a secure GEMS server, the
ballot programming was not done by state staff by manual entry directly into the
GEMS server housed in the State’s secure facility.
Finally, once counties approve the ballot proofs and ballot database
reports, CES provides each county with a single CD with a single file that is the
County GEMS database. (Tr., Doc. 570 at 170.)
The county takes the CD that
contains its GEMS database, loads it into their local GEMS computer and creates
the various media they use (i.e. memory cards) to program and power the DRE
and optical scan units. (Id.) Election results data from the DRE machines is
stored on the memory cards that is transferred back to the County GEMS server
for tabulation of results that are subsequently relayed to the Secretary of State
both via the Election Night Reporting System and later manual delivery of a CD.
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