Case 1:17-cv-02989-AT Document 579 Filed 08/15/19 Page 32 of 153
Dr. Halderman was surprised to learn that the Secretary of State’s Center
for Election Systems uses outside contractors working from their home
computers to build Georgia’s ballots for use on the DREs. (Tr., Doc. 571 at 87.)
These computers that the contractors are working on in their homes are outside
the secure facilities that the Secretary of State maintains for ballot building. (Id.)
The ballot files must be transmitted into the secured facility on USB drives, and
the data from those drives is then copied by Mr. Barnes through his public
internet-connected
computer29
in
order
to
transfer
them
into
the
separate/private secure GEMS server. (Id.) Thus, the election programming for
every county that is programmed by those external contractors, which included
every county in Georgia during the November 2018 general election, travelled
through an internet-connected computer where there is an attendant risk of
infection by malware that can then be spread to voting machines. (Id.)
As Dr. Halderman testified, the process that Barnes described using to
transfer GEMS files using a “lockable” (presumably a write-protect switch) USB
drive is not in fact secure and does not protect the integrity of the GEMS system
as portrayed by Mr. Barnes and Mr. Beaver. (Id. at 88.) In order to move the
files between the USB drive and the computers, Barnes “has to have [the USB]
unlocked in his internet-attached computer in order to format it in order to copy
files to it.” According to Halderman, this process unfortunately exposes the data
29
The pubic internet-computer screens for standard known malware.
32
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