1. From the General Election held on November 3, 2020 (hereinafter “2020 General Election”), all written or recorded reports, complaints, requests for investigation, regarding signatures of electors on absentee ballots, envelopes, or voter registration for Fulton, Cobb, Dekalb, and Clayton counties;
2. All reports, records, transfer documents, custody documents, memoranda, notes, written or recorded statements, and any other document or relevant correspondence concerning all chain-of-custody records for every absentee ballot drop box authorized in Georgia for the 2020 General Election;
3. All surveillance videos of every authorized absentee ballot drop box utilized during the 2020 General Election;
4. All correspondence, both paper and electronic, received by negotiation or otherwise by the Georgia Secretary of State’s office in exchange for the Secretary’s consent to the March 6, 2020 Compromise Settlement Agreement And Release in the lawsuit between Democratic Party of Georgia, Inc. (“DPG”), the DSCC, and the DCCC), as Plaintiff, and Brad Raffensperger, Rebecca N. Sullivan, David J. Worley, Seth Harp, and Anh Le, as Defendants.
5. All surveillance videos of the Georgia World Congress Center for the dates of November 3, 2020, and November 4, 2020.
6. All reports, records, and tabulations of absentee ballots received by the Secretary of State’s office during the 2020 General Election.
7. All reports, records, and tabulations of absentee ballots envelopes received by the Secretary of State’s office during the 2020 General Election.
8. All official correspondence to and from the Secretary of State, both paper and electronic, to and from Dominion Voting Systems (hereinafter “Dominion”) or any person associated with Dominion regarding the 2020 General Election.
9. All correspondence, both paper and electronic, regarding any of the following: (1) all official audits of the Dominion ballot marking devices (hereinafter referred to as “BMD”); (2) any relationship between Dominion and Pro V&V; (3) the number of BMDs examined by the Secretary of State; and (4) the extent to which such BMDs were examined.
10. To the extent not previously requested herein, each and every document pertaining to all reports prepared by any expert or election official regarding: (1) the accuracy and performance of BMDs and (2) all reports of any person who investigated BMDs or absentee ballots for the 2020 General Election.