Case 1:17-cv-02989-AT Document 579 Filed 08/15/19 Page 3 of 153 I. INTRODUCTION Approximately two months before the 2018 Georgia state general election, this Court recognized in its first preliminary injunction order that the State had “stood by for far too long” in failing to address the “mounting tide of evidence of the inadequacy and security risks” posed by Georgia’s Direct Recording Electronic voting system. Curling v. Kemp, 334 F. Supp. 3d 1303, 1307, 1327 (N.D. Ga. 2018). The Court at that time found that Plaintiffs were substantially likely to succeed on the merits of their claims that they faced an imminent threat of the diminishment and burdening of their First and Fourteenth Amendment rights to cast a vote that is properly counted. The Court, however, ultimately determined that the Plaintiffs’ eleventh-hour request for an immediate rollout of paper ballots statewide would likely adversely impact the public interest in an orderly and fair election. But, with the 2020 elections looming around the corner, the Court advised the State Defendants that any new balloting system adopted by the State should address democracy’s critical need for transparent, fair, accurate, and verifiable election processes that guarantee each citizen’s fundamental right to cast an accountable vote. The Court also expressly warned Defendants that further delay by the State in remediating its technologically outdated and vulnerable voting system would be intolerable and any future timeliness objections relating to the State’s inability to comply with the requested relief would be of the State’s own making. 3