Case 1:17-cv-02989-AT Document 579 Filed 08/15/19 Page 27 of 153 system that is used to produce that data output.” (Tr., Doc. 307 at 207.) He testified the system containing the “ballot-building software” is never connected to the internet. (Id. at 207-208.) He even stated that “[t]he SOS server where the ballot-building information is housed today – I don’t even have access to that server. It is within a locked environment that only the IT systems operators for the Secretary of State’s office have access.” (Id. at 208.)25 Barnes testified that the “only thing that is used to transfer data from the private network over to distribution points is a single USB – lockable USB drive . . . used to take PDF files that are generated as proofs to transfer over for county for proofing purposes.” (Id. 227-28.) Barnes connects the USB drive to his public internet-facing computer that “is connected to a secure FTP [file transfer protocol] site.” (Id. at 228.) But he also stated that the “GEMS server within the Secretary of State’s office that I do my work on does not have a wireless connect point,” which is the basis for his understanding that “it is a secured air gapped system.”26 (Id. at 226.) During the July 2019 hearing, Barnes described the GEMS ballot building process differently than how he portrayed the process in September 2018. The ballots are not built on the private GEMS server in the Secretary of State’s secure facility. (Tr., Doc. 570 at 166-67.) The ballots are built on the GEMS application 25 But he admitted he had no knowledge regarding the security of the software on which the GEMS server operates or “what levels of security they have surrounding that entire system.” (Id. at 227.) 26 Merritt Beaver, the Chief Information Officer at the Secretary of State’s Office testified at the 2019 hearing that there is no endpoint protection on the GEMS server because they consider the server air gapped. (Tr., Doc. 570 at 61-62.) 27

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