Wood v. Raffensperger
Exhibit L Savage Affidavit — Document #6, Attachment #12
District Court, N.D. Georgia
Description
Emergency MOTION for Temporary Restraining Order IMMEDIATE HEARING REQUESTED with Brief In Support by L. Lin Wood, Jr. (Attachments: # 1 Exhibit A Litigation Settlement, # 2 Exhibit B Coleman Affidavit, # 3 Exhibit C Deitrich Affidavit, # 4 Exhibit D Volyes Affidavit, # 5 Exhibit E Zeher Affidavit, # 6 Exhibit F Romero Affidavit, # 7 Exhibit G Reyes Affidavit, # 8 Exhibit H Johnston Affidavit, # 9 Exhibit I Silva Affidavit, # 10 Exhibit J O'Neal Affidavit, # 11 Exhibit K Fisher Affidavit, # 12 Exhibit L Savage Affidavit, # 13 Exhibit M Peterford Affidavit, # 14 Exhibit N Redacted Declaration, # 15 Exhibit O Makridis Declaration, # 16 Exhibit P Failure Study, # 17 Exhibit R Moore Affidavit, # 18 Exhibit S S. Hall Affidavit, # 19 Exhibit T R Hall Affidavit, # 20 Exhibit U Hartman Affidavit)(Smith, Ray) (Entered: 11/17/2020)
Case 1:20-cv-04651-SDG Document 6-12 Filed 11/17/20 Page 1 of 9
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
L. LIN WOOD,JR.,
Plaintiff, CIVIL ACTION FILE NO.
l:20-cv-04651-SDG
V.
BRAD RAFFENSPERGER,in his official
capacity as Secretary of State of the State
of Georgia,REBECCA N. SULLIVAN,
in her official capacity as Vice Chair of
the Georgia State Election Board,
DAVID J. WORLEY,in his official
capacity as a Member of the Georgia
State Election Board, MATTHEW
MASHBURN,in his official capacity as
a Member of the Georgia State Election
Board, and ANH LE,in her official
capacity as a Member of the Georgia
State Election Board,
Defendants.
AFFIDAVIT OF TIFFANY SAVAGE IN SUPPORT OF
PLAINTIFFS'MOTION FOR TEMPORARY RESTRAINING ORDER
I, Tiffany Savage, declare under penalty of perjury that the following is true
and correct:
1. I am over the age of 18 years and competent to testify herein. I have personal
knowledge ofthe matters stated herein. I am a resident of Gwinnett County.
My husband and I own two small businesses in Gwinnett County.
{00584011.}
Ex. L to TRO Motion:
Savage Affidavit
Case 1:20-cv-04651-SDG Document 6-12 Filed 11/17/20 Page 2 of 9
2. I volunteered to be a monitor for the Donald J. Trump Presidential Campaign,
Inc.(the "Trump Campaign")in connection with what was identified to me as
the "hand count" of votes cast in the November 3, 2020 presidential election.
I was assigned to monitor the hand count on November 14 through 17.
3. I was assigned to be an official monitor at the location at Beauty P. Baldwin
Voter Registrations and Elections Building in Lawrenceville. I believed that
we were there to watch actual "hand counting" as had been announced in the
newspapers and by the Secretary of State when he requested a "hand count."
4. In the course of monitoring on November 14,1 noticed some major red flags
that undermined the fairness ofthe process. I do not see these being addressed
in a way that is fair and equitable.
5. Ballots were being grouped into batches. It was not clear for what purpose.
They were not being counted,as far as I could tell. I do not know what training
or instruction had been given to these groupers, but the activity seemed
meaningless.
6. Envelopes from mail in ballots had been separated from the signatures on the
absentee ballot eternal envelopes. Electors during in-person early voting or
on Election Day were required to show identification; signature verification
was not available for audit in the recount.
{00584011.)
Ex. L to TRO Motion:
Savage Affidavit
Case 1:20-cv-04651-SDG Document 6-12 Filed 11/17/20 Page 3 of 9
7. Batches of ballots were marked with discrepancies on post it notes. See
picture on Annex 1. Ballots were placed in unmarked bins that are unattended
or just placed randomly on a counter just lying around. There appeared to be
little, if any, supervision, or control. I saw at least one open ballot box
(container ABM5B/ 31148252). See picture on Annex 1.
8. Four hours after a shift change, at many stations (at least 4 that I could see),
the counters were not counting ballots correctly. Instead of the "pass count"
for dual control purposes,counters were opening ballot batches independently
and "fast counting."
9. I reported the fast counting, and announcement was made to cause the
counters to use a confirmed process for reviewing and counting the ballots.
Perhaps there had been some training, but it seemed inconsistent. But even
after an announcement was made asking them to resume "pass counting." they
continued to batch and group "just get it over with."
10.Unsecured, completed ballot boxes were left all day when they should have
been secured by the(green)numbered lock tags. The security tags were being
used to lock the bags of ballots, but they were lying around in the open and
could have been used by anyone. See picture on Annex 1. There was no
permanent processing of assigning a tag number to a bag, so every bag was
{00584011.}
Ex. L to TRO Motion:
Savage Affidavit
Case 1:20-cv-04651-SDG Document 6-12 Filed 11/17/20 Page 4 of 9
vulnerable to opening,tampering, and relocking at any point in time when the
room was not being monitored.
11.The counters did not note the time verification on the machine-read voting
ballots.
12.1 overheard a poll official saying that damaged ballots were being or had been
"duplicated." I am not allowed to directly interact with a poll official, so I
could not ask what that official meant by that statement. There were hundreds
of damaged or voided ballots(which were all duplicated).
13.On November 15, 2020, the counting continued in the same haphazard way
until 2:48 p.m., when counting was stopped because the laptops all "went
down." The official counting did not resume that day but at 5:00 p.m., the
counters were dismissed due to "counter fatigue."
14.Batches of ballots were sitting around unattended. The ballot boxes were
locked with green security tags on the front but could be opened from the other
side without cutting the green security tag. The boxes are not secured.
15.*Gwinnett Election informed that the Green security tag numbers are not
documented and maintained anywhere except on a Post-it note inside the box.
The bag numbers are not kept in an independent location, so the ballots are
subject to tampering. The tags can be cut, the ballot box opened, ballots can
{00584011.)
Ex. L to TRO Motion:
Savage Affidavit
Case 1:20-cv-04651-SDG Document 6-12 Filed 11/17/20 Page 5 of 9
be manipulated. And a new Post-it note can be placed inside the box with the
new (not original) green security tag when the boxes are unmonitored.
16.The "24 hour camera feed" only shows ballot counters, not the voter review
or "secured ballot boxes." The 24 hour camera feed is closed off after hours
and appears dark.
17.All officers, who work for sheriff office, left the building when the counters
left. Yet persons with badges were exiting and entering the building and
walking out with folders.
18.After hours, anyone with a key to the building can have access to the open
room and this counting area.
19.1 returned on November 16 and witnessed the same level of confusion as the
14^ and 15^. On the 16*'', we were not permitted in the counting area until
9:30. At 8:30, all poll workers were released (approximately 75% of all
counters). The remaining counters did not appear to be aware of the rules,
and even when instructed, continued to blatantly disregard the counting
procedures.
20.The ballot box that had been left unsecured on November 14 was still
unsecured two days later. Green security tags were cut and replacement tags
were not being recorded properly.
{00584011.}
Ex. L to TRO Motion:
Savage Affidavit
Case 1:20-cv-04651-SDG Document 6-12 Filed 11/17/20 Page 6 of 9
21. Some ballot batch tally sheets have no number written at all in the Trump
column but include numbers for Biden; I regarded those as not likely to be
100% Biden votes in a given batch, butjust incomplete.
22.A laptop with access to the data entry system was left in the open area with
the password for the wifi and the laptop on a Post-it note affixed to the laptop.
When informed ofthis security breach, the supervisor simply said,"I know."
The "secured ballot counting area" was wide open to many people, even some
without a security badge.
23.One worker was entering numbers and writing on ballot sheets alone and out
ofsight ofthe security camera. When informed,the supervisor simply moved
her to another table.
24.The ballot batch tally sheets that are then given to the data entry tables were
marked in red pen. Red pens were left on the table, which would permit the
auditors to correct the ballot batch tally sheets they were auditing.
25.On November 17, the lack of security, confusion, and hostility to Republican
poll watchers continued. The supervisor placed a red line in tape across the
floor and instructed the poll watchers to stand behind the gold tape. There
was no way to see if the ballots were being read correctly. See picture on
Annex 1.
{00584011.}
Ex. L to TRO Motion:
Savage Affidavit
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Ex. L to TRO Motion:
Savage Affidavit
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Ex. L to TRO Motion:
Savage Affidavit
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Ex. L to TRO Motion:
Savage Affidavit