Case 1:17-cv-02989-AT Document 579 Filed 08/15/19 Page 5 of 153 Plaintiffs’ new motions present testimony manifesting a catalogue of pervasive voting problems arising in the 2017-2018 election period that compounds and expands the evidence established in the September 2018 preliminary injunction record compiled before the November 2018 general election, which itself yielded voluminous voting process complaints as well as litigation. Cumulatively, Plaintiffs in this case have marshaled a large body of evidence to demonstrate the burdens to the voting process and to the casting of a secure, reliable, counted ballot that some portion of voters across Georgia, including Plaintiffs, have experienced. The record in this case is substantial.3 This case arises in a technology context where Georgia’s current voting equipment, software, election and voter databases, are antiquated, seriously flawed, and vulnerable to failure, breach, contamination, and attack. The ongoing breach of the State’s Center for Election Systems4 (“CES”) servers, computer networks, and data housed at Kennesaw State University (“KSU”), in 2016 and 2017 unfortunately was an early talismanic event in this saga as was the subsequent wiping of the CES voting system servers upon public exposure of the For the sake of efficiency, the Court refrains from repeating the full range of factual findings and assessments of the evidence already set forth at length in its September 17, 2018 Order and that the Court finds still applicable. 4 CES at KSU functioned as a contractor and agent of the Secretary of State’s Office in performing critical election management and data management duties for both State and county election processes. CES managed the State’s GEMS server, which stores state and county election and voter data. CES also furnished data to create the lists of voters for electronic poll books used in each election, performed all ballot building processes, provided support for all jurisdictions in the election process and in support of DREs, and overall played an essential role in the operation of elections. The Agreement between the Secretary of State and Board of Regents through KSU makes plain that at all times the CES functioned as the agent of the SOS in performing and managing these critical functions on behalf of the SOS and the SOS Elections Division. (Doc. 258-1.) 3 5