A lawsuit released by lawyers led by former federal prosecutor Sidney Powell makes 30 allegations of electoral fraud and other illegal and irregular activities and features pertaining to the 2020 general elections in Georgia (pdf).

The allegations, most of which are based on witness and expert statements, relate to mail-in ballot fraud and insecurities, recount irregularities and deficiencies, and security hazards of the Dominion Voting Systems machines used by the state.

The suit alleges the following:

1. The software used by the Dominion machines was accessed by agents of malicious actors, such as China and Iran, “in order to monitor and manipulate elections,” including the 2020 election. The allegation is based on a redacted declaration of a former electronic intelligence analyst under 305th Military Intelligence.
   “By using servers and employees connected with rogue actors and hostile foreign influences combined with numerous easily discoverable leaked credentials, Dominion neglectfully allowed foreign adversaries to access data and intentionally provided access to their infrastructure in order to monitor and manipulate elections, including the most recent one in 2020,” the suit says.

2. An affiant, whose name was redacted for security reasons, alleged that the software used by Dominion was designed for Venezuelan government with the specific purpose to rig elections without the risk of getting caught. The affiant said he was part of a national security detail to former Venezuelan socialist dictator Hugo Chavez.
   “The purpose of this conspiracy was to create and operate a voting system that could change the votes in elections from votes against persons running the Venezuelan government to votes in their favor in order to maintain control of the government,” he said. The allegation was corroborated by another witness who “was in an official position related to elections and witnessed manipulations of petitions to prevent a removal of President Chavez.”

3. Another affiant said he’s the cousin of the former chief executive of Smartmatic, the company that developed the software adopted by Dominion. He said he has personal knowledge that the executive manipulated the company “to ensure the election for Chavez in the 2004 Referendum in Venezuela,” the suit says. He also testified that the executive, Anthony Mugica, “received tens of millions of dollars from 2003–2015 from the Venezuelan government to ensure Smartmatic technology would be implemented around the world, including in the U.S.,” the suit says.

4. The vote tallies produced by the Dominion machines can be manipulated by imputing a malicious code with just “7 minutes alone with [the voting machine] and a screwdriver,” according to Andrew Appel, Princeton professor of computer science and election security expert.
5. A ballot can be spoiled or altered by the Dominion machine because “the ballot marking printer is in the same paper path as the mechanism to deposit marked ballots into an attached ballot box,” a study by University of California–Berkeley said. It indicates that after a voter submits a ballot to the machine, the machine can add additional marks on it.
6. The voting machines are susceptible to hacking or remote tampering because they are connected to the internet, even though they’re not supposed to be.
   “Voting machines were able to be connected to the internet by way of laptops that were obviously internet accessible,” the suit says. “If one laptop was connected to the internet, the entire precinct was compromised.”
   Affiant Hari Hursti, a Finnish computer programmer and election security expert, said, “There is evidence of remote access and remote troubleshooting, which presents a grave security implication.”

7. The voting machines have activity logs that can be overwritten, according to Hursti. That means hackers or malevolent operators can tamper with the results and then erase their steps.
8. Ronald Watkins, a software and cyber-security expert who reviewed the Dominion software manual, said the machine operators can change the setting to exclude certain ballots from being counted (based on how much of the “bubble” they had filled in to indicate a vote for a candidate). Scans of the excluded ballots are placed in a separate folder and the operator can delete them simply using Windows File Manager.
9. Watkins said that to report the final vote counts, the machine operator would copy and paste the “Results” folder from the machine onto a USB drive.
   “While a simple procedure, this process may be error-prone and is very vulnerable to malicious administrators,” he said.

10. There are no procedures that would ensure the security of the USB drives used to report vote tallies from precincts. In one Georgia County, 3,300 votes were found on memory sticks not loaded into the central vote tally system, the suit says.

11. The test report and secretary of state certificate for the voting machines are undated.
12. Smartmatic faces litigation over “glitches” that allegedly affected the 2010 and 2013 mid-term elections in the Philippines, “raising questions of cheating and fraud,” the suit says.
13. Between 31,559 and 38,886 absentee ballots were returned by Republican voters, but were not counted, according to an analysis by expert witness Williams Briggs, a statistician and former Cornell Medical School professor, based on a phone survey of potentially affected GOP voters by the team of former Trump campaign member Matt Braynard.
14. Between 16,938 and 22,771 Republican voters received absentee ballots they didn’t request, based on the same analysis. That indicates unlawful absentee requests, the suit alleges.
15. Based on Braynard’s analysis of voter registrations and change-of-address requests, 20,311 absentee or early voters in Georgia voted even though they had moved out of state, which the state prohibits.
16. Georgia entered into an unlawful consent agreement with Democratic Party agencies that gutted the effectiveness of matching signatures on absentee ballot envelopes with signatures on record with the authorities. The matching was reduced “to a broad process with discretion, rather than enforcement of the signature requirement as statutorily required,” the suit says.
    The signature matching procedure was influenced by “guidance and training materials” produced by the Democratic Party.

17. Gov. Brian Kemp illegally authorized election officials to open outer envelopes of absentee ballots three weeks before the election. Georgia law “clearly prohibits opening absentee ballots prior to election day,” the suit says.
18. Georgia’s hand recount of the presidential race was illegitimate for a lack of meaningful observation.
    “Democrat-majority counties provided political parties and candidates, including the Trump Campaign, no meaningful access or actual opportunity to review and assess the validity of mail-in ballots during the pre-canvassing meetings,” the suit says.
    The allegation is based on multiple recount observer testimonies.

19. Votes for President Donald Trump were placed during the recount into vote piles for Trump’s opponent, former Vice President Joe Biden. The allegation is based on multiple observer testimonies, as well as an undercover video produced by Project Veritas, an undercover journalism nonprofit.

20. Some ballots from the “No Vote” and “Jorgensen” trays were moved to the “Biden” tray. One witness made the allegation.

21. Many voters weren’t allowed to cancel their mail-in ballot on Election Day and vote in person. One witness made the allegation.

22. The same witness alleged that many voters were denied the option to cast a provisional ballot on Election Day “when a mail-in ballot has already been received for them, but when they did not cast those mail-in ballots,” the suit says.
23. Signatures on mail-in ballot envelopes weren’t verified during the recount, one witness alleged. “At no time did I witness any Recounter or individual participate in the recount verifying signatures [on mail-in ballots],” the affiant said.

24. Some counties didn’t actually recount the ballots by hand, but instead used machines.
25. One batch of ballots was suspiciously “pristine.” Almost all were for Biden. The allegation is based on an observer testimony, who professed “20 years of experience of handling ballots.”
    One batch of ballots “was pristine” and “there was a difference in the texture of the paper,” according to the witness.
    “I observed that the markings for the candidates on these ballots were unusually uniform, perhaps even with a ballot-marking device,” she said.
    The ballots also “included a slight depressed pre-fold so they could be easily folded and unfolded for use in the scanning machines.”

26. The same witness also alleged that at one precinct in Milton, Georgia, poll workers were “asked to sign the chain of custody letter on Sunday, even though the machines were not delivered until 2:00 AM in the morning on Election Day.”
    In addition, the machines “were not sealed or locked, the serial numbers were not what were reflected on the related documentation,” she said.

27. Many batches of ballots were “100% for Biden,” one witness alleged.
28. The same witness also alleged “that the watermark on at least 3 ballots were solid gray instead of transparent, leading me to believe the ballot was counterfeit.” Local elections director offered the explanation that the ballots in question came from a different printer.
29. Authorities lied by claiming vote counting was paused in Fulton County because of “a water leak affecting the room where absentee ballots were being tabulated.” “The only water leak that needed repairs at State Farm Arena from November 3 – November 5 was a toilet overflow that occurred earlier on November 3. It had nothing to do with a room with ballot counting,” the suit says.

30. After everyone was “sent home,” one witness “saw election workers remaining behind after people were told to leave, the suit says, alleging that several people stayed behind to continue counting ballots without any observers present.

Demands

The lawsuit asks the court to order Georgia to do the following:

1. de-certify the election results
2. not transmit the currently certified election results to the Electoral College
3. transmit instead certified election results that state that Trump is the winner of the election
4. impound all the voting machines and software in Georgia for expert inspection by the plaintiffs
5. not count votes received or tabulated by machines that weren’t certified as required by federal and state law
6. produce 36 hours of security camera footage of all rooms used in the voting process at State Farm Arena in Fulton County