AFFIDAVIT OF ANTOINETTE "TONI'' PIPPINS-POOLE
STATE OF TEXAS

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COUNTY OF DALLAS

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BEFORE ME, the undersigned notary public of the State of Texas,
on this day personally appeared ANTOINETTE (TONI' PIPPINS-POOLE,
the affiant, a person whose identity is known to me. After I
administered an oath to affiant, affiant testified:
HMy name is Antoinette (Toni' Pippins-Poole. I am over the age of
18, have not been convicted of a felony or a crime involving
moral turpitude and am otherwise fully competent to make this
Affidavit.
"I am the Elections Administrator for Dallas County, Texas
((Dallas County') and am the department head of the Dallas County
Elections Department ((Elections Department'). I entered into
contracts with the Dallas County Democratic Party and the Dallas
County Republican Party to administer the 2020 Democratic primary
election in Dallas County and the 2020 Republican primary
election in Dallas County (uprimary elections») held on March 3,
2020 ((Election Day').
"Initially, Dallas County had 465 countywide polling places
((vote centers') set up for the 2020 primary elections so that
any registered voter in Dallas County could cast a ballot at any
vote center in Dallas County on Election Day as opposed to being
limited to the polling place where the voter was registered to
vote. The Dallas County Democratic Party and the Dallas County
Republican Party agreed to close 10 vote centers because both
political parties did not get contracts with the building
locations for those 10 vote centers. Consequently, those 10

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 building locations for those 10 vote centers refused delivery of
the precinct scanner and tabulator machines for those 10 vote
centers. In addition, one voter center could not be opened on
Election Day for other reasons, so ultimately there were 454 vote
centers in operation on Election Day.
"Part of the administration of the primary elections included me
serving as the manager of the central counting station ("central
count") for both primary elections, which is inside the Elections
Department. After the polls close on Election Day, there is a
process to reconcile the number of voters accepted to vote at
each vote center with the number of ballots received at central
count from each vote center.
"During the reconciliation process at central count after the
polls closed on Election Day, I determined that there were
discrepancies between the number of voters accepted to vote at
some vote centers and the number of ballots received at central
count from those vote centers.
"Each vote center has electronic poll books where voters present
themselves to vote and if they are accepted to vote, are given a
ballot to cast in a ballot marking device. The information about
each voter who is accepted to vote at each vote center is
transmitted electronically to the voter registration system in
the Dallas County Elections Department.
"Each vote center has one or more precinct scanner and tabulator
machines that scan and tabulate the marked ballots cast by the
voters and then store the marked ballots inside the precinct
scanner and tabulator machine. 189 vote centers had both a
Republican Election Judge and a Democratic Election Judge. 265
vote centers had only a single Election Judge. All 189 vote
centers with both a Republican Election Judge and a Democratic
Election Judge had two precinct scanner and tabulator machines .

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 Some vote centers with only one Election Judge had two precinct
scanner and tabulator machines. Some vote centers with only one
Election Judge had only one precinct scanner and tabulator
machine. At vote centers with only one Election Judge and two
precinct scanner and tabulator machines~ the Election Judge was
instructed to (open~ only one of the precinct scanner and
tabulator machines.
"There are two thumb drives in each precinct scanner and
tabulator that record the votes cast on each ballot fed into the
precinct scanner and tabulator machine. One thumb drive is the
primary thumb drive and one thumb drive is the backup thumb
drive. The primary thumb drive is only ever connected to a
precinct scanner and tabulator machine and then later to a
desktop computer at central count , which is part of the airgapped~
central count tabulating system. Neither the precinct
scanner and tabulating machines or the central count tabulating
system are connected to the Dallas County computer network or the
Internet .
"In order for each precinct scanner and tabulator machine to scan
and tabulate ballots, the Election Judge for each vote center is
trained to (open' each precinct scanner and tabulator machine by
using a metal key and password to unlock each precinct scanner
and tabulator machine and then use a tabulator touchscreen built
into each precinct scanner and tabulator machine to (open~ the
precinct scanner and tabulator machine.
"The process of (opening' the precinct scanner and tabulator
machine (opens~ the primary and backup thumb drives in the
precinct scanner and tabulator machine so that the thumb drives
can record votes.
"As each ballot is scanned by a precinct scanner and tabulator
machine~ the votes on the ballot are tabulated and then r ecorded

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 on the primary thumb drive. No votes are recorded onto the backup
thumb drive until the precinct scanner and tabulator is (closed'
after the polls close on Election Day.
uwhen the polls close on Election Day, the Election Judge for
each vote center was instructed to rclose' each precinct scanner
and tabulator machine by unlocking a door on the precinct scanner
and tabulator machine and pressing a rclose button.' Then the
Election Judge is trained to use the tabulator touchscreen that
is built into each precinct scanner and tabulator machine to
(close' each precinct scanner and tabulator machine. As each
Election Judge (closes' each precinct scanner and tabulator
machine, the votes recorded on the primary thumb drive in the
precinct scanner and tabulator machine are automatically copied
over to the backup thumb drive in the precinct scanner and
tabulator machine.
((After each precinct scanner and tabulator machine in the
Election Judge's vote center is r closed', the Election Judge is
trained to remove the primary and backup thumb drives from each
precinct scanner and tabulator and place each thumb drive in
separate bags to protect the thumb drives from static
electricity. Then, the Election Judge is trained to put both bags
with the primary and secondary thumb drives into a red envelope
for transport to a regional collection site. The Election Judge
for each vote center is trained to transport each red envelope
from the Election Judge's vote center to one of 13 designated
regional sites.
rrThe precinct scanner and tabulator machines are delivered to the
vote centers during the early voting period, but before Election
Day. It was determined that there would not be enough Election
Judges to have both a Democratic Election Judge and a Republican
Election Judge in 454 vote centers . Consequently, it was
determined that 189 vote centers would have both a Democratic

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 Election Judge and a Republican Election Judge, but that 265 vote
centers would have either a Democratic Election Judge or a
Republican Election Judge, but not both. In the vote centers with
only one Election Judge, that Election Judge conducted both
primary elections in that Election Judge's vote center.
the 13 regional sites receive red envelopes from the Election
Judges, Elections Department personnel at the 13 regional sites
open the red envelopes and put only the backup thumb drives into
a laptop in order to transfer the number of ballots with the
votes to central count at the Elections Department for Election
night reporting. The primary thumb drives are checked off as they
are received at the 13 regional sites and set aside in a
containe r with a physical locking mechanism . At the end of the
night, the locked containers with the primary thumb drives and
backup thumb drives are hand delivered to central count by the 13
r egional site managers .

((As

uAs the votes come into central count from the 13 regional sites,
the r econciliation process begins to compare the number of voters
accepted at each voter center with the number ballots ca st at
each vote center.
((During the reconciliation process, the number of primary thumb
drives sent out to vote centers was compared with the number of
primary thumb drives received back at central count. It was
initially believed that all of the ballots cast at all of the 454
vote centers had been received back at ce ntral count on the
primary thumb drives that had come back to central count from the
13 regional s ites. However, it was later determined that there
are ballots from 44 of the precinct scann er and tabulator
machines that are unaccounted for.

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 Consequently J I need to perform a paper recount of the ballots
from 44 of the precinct scanner and tabulator machines that were
not accounted for during the reconciliation process.
"Each and every statement contained in this Affidavit is true and
correct and based on my personal knowledge or on public records
available to me as Elections Administrator for Dallas County J
Texas.
FURTHER AFFIANT SAYETH NAUGHT.))

lo-+±::::- J
Sworn to and subscribed before me on March
certify which witness my hand and seal of office.

2020

to

~~
Notary Public for the State of
Texas

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