Case 1:17-cv-02989-AT Document 579 Filed 08/15/19 Page 6 of 153 breach immediately following the filing of this lawsuit.5 The State Defendants’ refusal to fully acknowledge or remedy these circumstances and their broader ramifications for the voting system’s security and reliability both before and after the Secretary of State’s Office took over the CES’s functions has flagged other, similar troubles.6 The Court does not minimize the challenges any state faces in operating a secure, reliable voting system in the current cyber era. Still, the Defendants have been slow and poorly equipped in tackling the security and functionality challenges afflicting its current voting system and the well-established deficiencies in a non-auditable DRE voting system. And Defendants’ inconsistent candor with the Court about the CES/KSU hack and the security of the servers, as well as other germane subsequent voting system security issues impacts the evidence. The imminent threats of contamination, dysfunction, and attacks on State and county voting systems, disparaged by the Secretary of State’s representatives at the 2018 hearing virtually as a fantasy and still minimized as speculative at the 2019 hearing, have been identified in the most credible major national and state cybersecurity studies and official government reports. And, in “real life,” this On July 7, 2017, four days after this lawsuit was originally filed in Fulton Superior Court, all data on the hard drives of the University’s CES server on “elections.kennesaw.edu” were wiped or destroyed. And on August 9, 2017, the day after this lawsuit was removed to federal court by Defendants, all data on the hard drives of a secondary server which contained similar data was also wiped or destroyed. Curling, 334 F. Supp. 3d at 1310. 6 The Secretary of State’s Office absorbed CES on January 1, 2018. CES’s Director, Michael Barnes, at that time also transferred back to the State and continues to serve as the Director of CES. 5 6