Case 1:17-cv-02989-AT Document 579 Filed 08/15/19 Page 37 of 153
primarily on severe security vulnerabilities uncovered during the review.” (Doc.
387-3 at 3.) And Mr. Finley oversaw the rollout in dozens of California counties
of paper, hand completed ballot systems including optical machine scanning and
tabulation along with a verifiable paper audit trail. (Id.; see also, Declaration of
Nathan Woods, Doc. 510-2.)
Similarly, Candace Hoke, who offered testimony in support of the Coalition
Plaintiffs’ preliminary injunction motions (discussed more fully below in Section
IV), was part of a team of election security experts advising Ohio’s Secretary of
State Jennifer Brunner in 2007 regarding vulnerabilities in its DREs. Secretary
Brunner’s Evaluation and Validation of Election-Related Equipment, Standards
and Testing (“EVEREST”) initiative – which examined a newer version of the
AccuVote DREs than Georgia uses – found that vulnerabilities in the voting
system’s security and reliability were easily exploitable by an attacker under
election conditions. Secretary of State Jennifer Brunner, EVEREST: Evaluation
and Validation of Election-Related Equipment, Standards and Testing (Dec.
2007) at 103. Following the report, the Ohio Legislature eliminated Ohio’s
electronic voting machines.
In their 2019 preliminary injunction submissions, Plaintiffs offer
additional declarations from other prominent cybersecurity election technology
experts. Additional expert declarations filed and testimony of note considered
here came from Dr. Andrew Appel, the Eugene Higgins Professor of Computer
Science at Princeton University, where he served as Department Chair from
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