Case 1:17-cv-02989-AT Document 579 Filed 08/15/19 Page 29 of 153
86.) These individual contractors built all of the ballots for all counties for the
November 2018 general election, and they built the ballots for 98 out of 159
counties for the May 2018 primary election. (Id. at 174.)
Once the State collects all of the information from the counties relating to
candidates, jurisdictions, and races involved in the election, the three individual
contractors construct the initial GEMS databases and initial layout of the data
set. (Id. at 162.) The databases are then delivered to the SOS on an encrypted CD
or locked USB drive. (Id. at 163.) Barnes “moves the files from their thumb
drives into” the State’s GEMS file system by downloading the data on the public
computer and then onto his lockable reformatted USB drive that he “uses for
moving the files back and forth” from his public and private/air-gapped
computers. (Id. at 164-65.) The GEMS server holds the ballot file, which is then
placed into a review folder on the server for inspection. (Id. at 165.) Barnes and
his staff perform a “line-by-line review of the data set to make sure that the right
candidates are listed in the right order, names are spelled properly, [and] that the
races are in the proper order.” (Id. at 163.) If any corrections are needed on the
contractor-built GEMS ballot databases, they are not returned to the contractors.
Instead, Barnes or his staff make those corrections. (Id. at 163-64.)
Barnes described this review/correction process as follows:
A. Once the file is placed into a review folder on the server,
then a member of my team – we have a check sheet that is itemized
of what we’re looking at that is within a specific database within
specific elections. They will then download from the server a copy of
that file. And it is saved to their local private CPU. The local – private
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