Gabrielle SummeKenton County Chairman of the County Board of Elections & County ClerkP.O. Box 1109Covington KY 41012November 10, 2019Subject: Public Records Request of 11-10-19 for Kenton County's Nov 5, 2019 General Election Records & Notice re Ballot Images & Associated Records & DataDear Gabrielle Summe,I am requesting public records pursuant to Kentucky Open Records Act, KRS 61.870 to KRS 61.884, all ballot images for the November 5, 2019 General Election.* All requests are for electronic copies.BackgroundKenton County uses the Hart Intercivic eScan vote tabulation machine to tabulate the votes on paper ballots hand-marked by the voter, as its primary machine. *These machines automatically generate a digital image of each ballot as it is fed into the machine and then stores it in electronic media. *The Hart product catalog describes:"The eScan is Hart’s fully integrated digital ballot-imaging unit for polling place voting. It uses paper ballots produced by the Hart Voting System Ballot Now software and stores votes on an election-specific flash memory card. Second Chance Voting, dual-sided scanning and jurisdiction-wide election reporting are all supported." * https://www.hartintercivic.com/wp-co...uctCatalog.pdf This is a fortunate feature of the Hart eScan machine, given its known security concerns. *The citizens's non-profit group VerifiedVoting.org reports that:"Network interfaces in the Hart system are not secured against direct attack. Poll workers can connect to JBCsor eScans over the management interfaces and perform back-ofﬁce functions such as modifying the device software. The impact of this is that a malicious voter could potentially take over one or more units in a precinct and a malicious poll worker could potentially take over all the devices in a precinct. The subverted machines could then be used to produce any results of the attacker’s choice, regardless of voter input." * https://www.verifiedvoting.org/resou...ercivic/escan/ For more information on ballot images please see "Understanding Ballot Images and Related Documents": https://www.auditelectionsusa.org/sa...a-spreadsheet/ and:"New Technology Allows Election Officials to Verify Votes Like Never Before"Inclusions• each and every electronic or digital Ballot Image file created, held or used by the County• any and all metadata associated with each image• provided in the format or formats in which they are:a) generated by the voting systemb) used by the voting system, andc) exported or exportable from the voting system (e.g., Election Management System), such as the .pbm file format• Ballot Image files’ filenames unchanged from filenames:a) generated by the voting system, andb) linked to their corresponding Cast Vote Records’ filenamesExclusionsThis request does not seek to inspect or obtain copies of the paper ballots themselves, or to obtain hard copies of ballot images. It is limited to copies of electronic or digital files.Kenton County Elections’ digital scanners scan the front and back of each individual paper ballot to create a digital copy. The scanner (or separate voting system component) then captures votes from the scanned copy, NOT the paper ballot. In this scenario, the digital scan is the election material actually counted.All Cast Vote Records (CVRs) for the November 5 General Election.“Cast Vote Record” carries its common election administration meaning, here designating a digital file containing the information captured off a single voted ballot.Inclusions• each and every electronic Cast Vote Record file created, held or used by the County• any and all metadata associated with each Cast Vote Record• CVR files’ filenames unchanged from filenames:a) generated by the voting system, andb) linked to their corresponding Ballot Images’ filenames• provided in the format or formats in which they are:a) maintained by the voting system (e.g., native format), andb) exported or exportable from the voting system (e.g., EMS), such as the .pbmfile formatThe List of Vote Records (LVR) for the November 5 General Election.• this record or set of records goes by a variety of names, such as Cast Ballot Logor Cast Vote Record(s)• typically consists of a spreadsheet, with each row displaying contents of oneCast Vote Record• provided in the format or formats in which it is:a) maintained by the voting system (e.g., native format), andb) exported or exportable from the voting system (e.g., EMS)• may consist of more than one fileIn event of denialIf any documents are withheld from production in whole or in part, please provide me an exemption log index of each record or category of records that have been withheld or redacted, the explicit statutory citation exempting the records, and a brief explanation of how the statutory exemption applies to the records.Method of deliveryMy first choice is for production of all records online by posting on your official website or official publicly accessible portal.Only if that is not available, my backup choice is by digital media secured against undetectable post-production alteration of the media containing the records (e.g., by hash, by write-once read-only media).Please use only the email address below for all communications. *Please communicate from a single email address. *Please maintain this subject line intact, in one continuous string to include all correspondence concerning this request.Thank you for your prompt attention to this request.Respectfully,