Case 1:17-cv-02989-AT Document 579 Filed 08/15/19 Page 28 of 153
(the “ballot-building software”) on public-facing internet-connected desktop
computers of the individual ballot builders, then copied over from the publicfacing computer onto a “lockable” USB drive, which is then inserted into the
private27 computer to be uploaded into the secure GEMS server for storage of the
ballot programming files. (Id. at 77-78, 166-67.) Mr. Barnes scans and reformats
the lockable USB drive during each transfer. (Id. at 77-78, 101, 107.) He follows
the same process when copying files from the private GEMS server to the USB
drive and back onto the public internet-facing computer for distribution to the
counties. (Id. at 101, 107.)
The Secretary of State has contracted with ES&S for ballot building support
services to “assist” the Center for Election Systems in constructing the GEMS
databases that are used within county elections. (Id. at 83-84.) Three individuals
from ES&S28 work solely on Georgia election databases and perform “their ballot
building work within their own purviews” and construct the GEMS databases on
desktop computers from their homes. (Id. at 84-85.) According to Barnes, the
individuals are subject to the same requirements for using air gapped equipment
as the Secretary of State, though he testified he does not know what physical
security parameters each of the individuals have within their homes. (Id. at 85-
Mr. Barnes often refers to the private computer housing the GEMS server as “air gapped.”
However, as Dr. Halderman and Dr. Shamos both testified – the actual process used by the
Secretary of State’s Office does not constitute an “air gapped” system as explained below. The
Court will therefore refer to “private” as not being directly connected to the internet.
28 Two of these individuals previously worked for Barnes at CES and the third worked for Cobb
County. (Tr. Vol. 1, Doc. 570 at 85.) Barnes was not aware of whether these individuals were
employees of ES&S or independent contractors.
27
28
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