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Our Challenge to Georgia’s New Election Law (SB202)

In the wake of the passage of Georgia’s SB202 law, we must do our part to work to dismantle this legislative weapon against basic democratic principles, election integrity, and election security. During mid-April, Coalition for Good Governance will file a lawsuit to challenge several parts of the new law that have not been covered in the other essential recent federal lawsuits by voting rights organizations. Our wheelhouse is election security, election technology, citizen oversight and transparency of elections. Our claims will primarily focus on those areas, leveraging our expertise. No one lawsuit will remove all of the dangerous parts of SB202, nor will any pending federal legislation. Numerous cases from varying perspectives and plaintiffs are essential to take down this democracy-destroying new law.

Our legal team will include attorneys who have represented Coalition for Good Governance in our successful lawsuits to

  • stop arbitrary rejections of mail ballots (2018),
  • ban the use of paperless voting machines (2019),
  • require paper pollbook backups (2020—under appeal by State), and
  • change ballot scanner settings for greater accuracy (2020—under appeal by State).

Our Curling v Raffensperger case to ban the new touchscreen voting machines continues in federal court with important rulings from Judge Totenberg in October 2020 concerning the security risks of the voting system. Discovery will continue in the case this spring and summer. Dr. Alex Halderman recently reported to the Court in a sealed declaration that the security risks of the system are considerably greater than had been initially assumed. As well, his conclusion is that the new touchscreen system is even more vulnerable than the previous touchscreen system banned by the Court as unconstitutional.

We at CGG continue the battle for election integrity and election security on legal battlegrounds that few others attempt because of the technical and legal complexities. We are proud of our track record and encourage your support of our ongoing efforts. None of the management of the Coalition receive any remuneration. Donations go only to cover our litigation support expenses and modest compensation for our analyst and interns. Please see our Donate page.

 

Filing Links

10.05.2022 Philip Stark's declaration on Georgia audits10.12.2022 Plaintiffs’ filing regarding Koth declaration and state defendants’ investigative privilege claim10.05.2022 Opinion from US Court of Appeals for the 11th Circuit regarding poll books and scanners.09.30.2022 Notice of filing regarding discovery conference09.26.2022 Letter to Georgia's State Election Board concerning breach09.25.2022 Plaintiffs' combined response regarding Latham failure to produce09.25.2022 Motion to compel Latham with document subpoenas 09.19.2022 Plaintiffs’ surreply in opposition to motion to quash subpoenas and for attorney’s fees and costs by Cathleen A. Latham09.09.2022 Judge Totenberg's order permitting continuation of discovery relating to Coffee County election system breakage issues09.09.2022 Transcript of Discovery Conference Proceedings before the Honorable Amy Totenberg, United States District Senior Judge September 9, 2022, 1:09 p.m.09.08.2022 Exhibit 1 (Issues Plaintiffs Want to Discuss with Judge Totenberg), which was attached to the State Defendants' Notice of Conditional Objection to Proceedings on September 9, 2022 (Case 1:17-cv-02989-AT, Document 1473, Filed 09/08/2022, 12 pages). See especially item 7.08.30.2022 Plaintiffs’ Opposition to Motion To Quash Subpoenas and For Attorney’s Fees and Costs by Cathleen A. Latham07.28.2022 Coalition Plaintiffs’ Response Brief on Law Enforcement Investigative Privilege07.28.2022 Curling Plaintiffs’ Response to State Defendants’ Brief Regarding Law Enforcement Investigative Privilege07.26.2022 CISA does not propose additional redactions for the Court to consider with regard to potential release of Dr. Halderman’s report on Dominion vulnerabilities. The Plaintiffs’ most-recent proposed redactions appropriately manage the risk to election security while advancing security through transparency.07.14.2022 Coalition Plaintiffs’ Notice of Investigation Status Requiring Resolution by the Court07.14.2022 Curling Plaintiffs’ Notice of Open Discovery Items Requiring Resolution by the Court06.29.2022 Coalition Plaintiffs’ Response to Court’s Order (Doc. 1408) Regarding Coffee County Discovery06.28.2022 Judge Amy Totenberg's order regarding the schedule for depositions related to Coffee County, Georgia, and the topics to be covered in those depositions, as well as the schedule for responses by the State Defendants.06.15.2022 Plaintiffs’ Omnibus Notice of Intent to Serve Subpoenas to Testify at a Deposition AND Plaintiffs’ Omnibus Notice of Intent to Serve Subpoenas to Produce Documents06.13.2022 Judge Amy Totenberg's order regarding depositions to be given by two new Georgia State Election Board Members06.06.2022 Election complaint to State Election Board members05.27.2022 Plaintiffs’ Objection to State Defendants’ Failure to Comply with the Court’s April 7, 2022 Directive05.19.2022 Status Report of CISA to the Court04.18.2022 Status Report of CISA to the Court04.08.22 Coalition Plaintiffs’ Electronic Recording of Fulton County Voter Scott Hall Regarding Coffee County, GA04.08.22 Notice of Coalition Plaintiffs’ Filing of Informal Transcript of Electronic Recording of Fulton County Voter Scott Hall Regarding Coffee County, GA04.07.22 Transcript of telephone discovery conference before the Honorable Amy Totenberg, U.S. District Court, Northern District of Atlanta, Atlanta Division04.06.2022 Joint Discovery Statement Regarding Coffee County Election Records03.29.2022 Notice of Appearance of Russell T. Abney, co-council for Coalition for Good Governance03.17.2022 Judge Totenberg ordered a stay of the Curling v. Raffensperger case until May 26, 2022.03.09.2022 Declaration of Philip B. Stark concerning Georgia's 2020 "Audit"; his finding that the First Count, Audit, and Recount differ substantially; his analysis of data from the two Fulton County machine counts; and an extensive summary of his findings.02.24.2022 Deposition of Gabriel Sterling, under contract to Georgia Secretary of State02.10.2022 United States Cybersecurity and Infrastructure Security Agency (CISA) gives notice to the Court concerning the Agency's expected work to review the hacking risk to Georgia's voting system02.07.2022 Plaintiffs' Motion for Leave to Amend the Amended Complaint against SB202. Amendment referring to Tally Rules is included as Appendix A.02.02.2022 Coalition Plaintiffs' Statement on the Disclosure of the Halderman Report01.12.2022 Motion to Intervene in Curling v. Raffensperger, et al., for the Limited Purpose of obtaining access to J. Alex Halderman's sealed report of his analysis of Dominion voting machines01.11.2022 Declaration of Duncan A. Buell, Ph.D., in which he describes his analysis methods and results for several Georgia counties' November 2020 electronic files of individual ballot data12.09.2021 Judge J. P. Boulee's ruling in the Coalition's favor to deny GA Gov. Kemp and SOS Raffensperger's motions to dismiss our case against SB20210.06.2021 Brief in Support of Coalition Plaintiffs’ Motion to Sever, Grant Motion for Attorney’s Fees, Grant Motion for Sanctions, and Enter Final Judgment on Severed Claims10.06.2021 Coalition Plaintiffs’ Motion to Sever, Grant Motion for Attorney’s Fees, Grant Motion for Sanctions, and Enter Final Judgment on Severed Claims09.21.2021 Joint Discovery Statement Regarding State Defendants’ Responses to Curling Plaintiffs’ Second Set of Interrogatories and Curling Plaintiffs’ CISA Request09.21.2021 Declaration of J. Alex Halderman for Curling Plaintiffs’ Second Set of Interrogatories and Curling Plaintiffs’ CISA Request08.02.2021 Expert Rebuttal Declaration of J. Alex Halderman08.02.2021 Philip B. Stark Rebuttal Report07.30.2021 Expert Rebuttal Report of Andrew W. Appel07.13.2021 Declaration of J. Alex Halderman, Ph.D., in which he asks the Court to allow public disclosure (subject to certain redactions for the sake of election security) of the results of his security analysis of Dominion’s election equipment07.07.2021 Order by U.S. District Judge J. P. Boulee denying Coalition for Good Governance and other plaintiffs' Motion for Preliminary Injunction07.02.2021 Motion for Leave to File Post-Hearing Brief06.30.2021 Motion of Georgia First Amendment Foundation for Leave to File Amicus Curiae Brief AND Amicus Curiae Brief of Georgia First Amendment Foundation06.28.2021 Expert Report of Andrew W. Appel, Ph.D., regarding voter verifiability problem with Ballot Marking Devices and the hackability hazard06.28.2021 Reply Brief in Support of Plaintiffs’ Motion for Preliminary Injunction06.14.2021 CGG’s Motion for Preliminary Injunction, for Expedited Briefing, and for Oral Hearing to preserve the right to vote without unjustified state interference, to protect freedom of speech, and to ensure a meaningful separation of powers – three pillars of liberty06.11.2021 Amended Complaint. "Liberty requires at least three essential things—an unfettered right to vote, freedom of speech, and the meaningful separation of powers. This lawsuit is necessary to preserve individual constitutional rights, and constitutional government, against the attacks that SB202 makes on these three pillars of liberty."05.17.2021 Coalition for Good Governance Filed a Lawsuit against GA SOS and State Election Board to Challenge Key Unconstitutional Provisions of SB20201.14.2021 Coalition Plaintiffs' Joint Proposed Schedule for Discovery (also Dispositive and Daubert motions)11.18.20 Coalition Plaintiffs’ Reply Brief in Support of Proposed Scanner Remedy (Doc. 990-2) Filed Pursuant to Order (Doc. 964)11.05.2020 Coalition Plaintiffs’ Emergency Motion for Expedited Discovery and Immediate Injunctive Relief10.21.2020 The Coalition's Brief in Opposition to the State's Motion to Stay, the United States Court of Appeals for the Eleventh Circuit10.14.2020 The Court Denies Defendants' Motion to Stay Preliminary Injunction on Paper Pollbook Backup10.12.2020 New Order by the Court Concerning Pollbook Backup Printouts at Each Polling Place on Election Day10.11.2020 Court's Order on Motion for Preliminary Injunction10.09.2020 Coalition Plaintiffs’ Response in Opposition to State Defendants’ Emergency Motion to Stay Court’s Injunction on Paper Pollbook Backups10.07.2020 Plaintiffs’ Notice of Filing of Correspondence with State Defendants and Their Refusal to Comply with The Court’s September 28, 2020, Docket Order10.05.2020 Order by the Court Denying the Defendants' Motion to Seal Dr. Eric Coomer’s Technical Testimony10.04.2020 Declarations by Experts Harri Hursti and Kevin Skogland and Transcript of Zoom Video Conference Proceedings before The Honorable Amy Totenberg, October 1, 202010.03.2020 CGG Attorney's Letter to Fulton County about County's Ongoing State Law Violations, Which Can Be Remedied Only by Switching to Hand-Marked Paper Ballots09.30.2020 Plaintiffs’ Request for Emergency Conference Regarding Statewide Changes to Election Databases and BMD Software09.29.2020 Plaintiffs’ Notice of Filing Materials Regarding Georgia’s Intended Replacement of Dominion BMD Software across the State09.28.2020 Opinion and Order by the Court Granting Coalition Plaintiffs' Motion for Preliminary Injunction on Paper Pollbook Backups 09.28.2020 Transcript of Telephone Conference Proceedings before The Honorable Amy Totenberg, U.S. District Judge (partially redacted)09.25.2020 Emergency Notice of Supplemental Evidence Relating to Motions for Preliminary Injunction--Serious problem found in GA's Nov. election programming09.17.2020 Transcript of Hearing on Preliminary Injunction, United States District Court for the Northern District of Georgia, Atlanta Division, Judge Totenberg Presiding, September 10, 11, and 14, 202009.16.2020 Coalition Plaintiffs’ Brief in Response to Court Order (Document 900)09.16.2020 Curling Plaintiffs’ Response to the Court’s September 15, 2020, Order09.01.2020 Coalition Plaintiffs’ Reply Brief in Support of Motion for Preliminary Injunction Relating to BMDs, Scanning and Tabulating, and Auditing08.24.2020 Coalition Plaintiffs’ Motion For Preliminary Injunction Relating to BMDs, Scanning and Tabulating, and Auditing08.21.2020 Coalition Plaintiffs’ Motion for Preliminary Injunction on Paper Pollbook Backups08.11.2020 Judge Totenberg's Order to Grant Most of CGG's Emergency Motions for Expedited Discovery08.02.2020 Motion of Coalition Plaintiffs to File Notice of Filing Evidence and Request for Immediate Injunctive Relief on Paper Pollbook Backups07.31.2020 Notice of Rule 34 Request for Expedited Inspection and Copying07.31.2020 Plaintiffs’ Joint Statement Addressing Scope and Timing of Proposed Expedited Discovery07.30.2020 Judge Totenberg’s Order Authorizing Expedited Discovery07.18.2020 Coalition for Good Governance Memo on Legal Basis to Use Hand-Marked Paper Ballots, by Bruce P. Brown07.17.20 Plaintiffs’ Joint Emergency Motion for Expedited Discovery and Evidentiary Hearing04.20.20 CGG COVID Complaint as Filed04.06.20 Request for reexamination of certain voting system components because of COVID-1903.13.20 Brief of the Electronic Privacy Information Center as amicus curiae regarding voter privacy and the secret ballot02.24.20 Emergency Motion for an order requiring Respondents to comply with Georgia Constitution provision that "Elections by the people shall be by secret ballot."01.16.20 Coalition Plaintiffs’ Status Report Regarding BMD Implementation and Response to State Defendants’ Request to Destroy DRE System Records12.16.19 Coalition Plaintiffs’ Reply Brief in Support of Motion for Preliminary Injunction10.23.19 Coalition Plaintiffs’ Motion for Preliminary Injunction10.11.19 Plaintiffs’ Joint Motion for Sanctions10.08.19 Coalition Plaintiffs’ Reply in Support of Motion to Alter or Amend the Judgment09.12.19 Proposed Order Granting Coalition Plaintiffs’ Motion to Alter or Amend the Judgment09.12.19 Coalition Plaintiffs’ Motion to Alter or Amend the Judgment09.12.19 Coalition Plaintiffs’ Brief in Support of Their Motion to Amend or Alter Judgment09.06.19 Coalition Plaintiffs’ Motion for Leave to File Supplemental Complaint to U.S. District Court08.19.19 Petition by Over 1,450 Georgia Voters for Reexamination of the Dominion Voting System by SOS-appointed Certification Agent08.15.19 Judge Totenberg’s Order Supporting Plaintiffs’ Motion for Preliminary Injunction that GA End DRE Use, File Audit Requirements, and Address Voter Registration Database Deficiencies07.25.19-07.26.19 Transcript of Hearing on Preliminary Injunction Proceedings Before the Honorable Amy Totenberg, U.S. District Judge, Volumes 1 and 206.19.19 Coalition Plaintiffs’ Notice of Filing Evidence: Parts One and Two05.21.19 Judge Totenberg’s Order: Discovery Shall Begin Immediately05.03.19 Amicus Brief Supporting Coalition’s Demand in Georgia Supreme Court for Fair Election for Lt. Governor04.30.19 Final Supplemental Brief to Georgia Supreme Court for Fair Election for Lt. Governor04.09.19 Coalition Plaintiffs’ Status Report02.07.19 US Court of Appeals for 11th Circuit Denies Georgia’s Appeal01.21.19 Motion for Expedited Consideration of Appeal of Lt. Gov. Election Contest01.07.19 Superior Court of Fulton County: Plaintiffs’ Joint Consolidated Response to Pending Motions to Dismiss11.23.18 Petition to Contest Georgia Lt. Gov. Election Result09.17.18 Order by U.S. District Judge Amy Totenberg in Response to Coalition Plaintiffs’ Motion for Preliminary Injunction08.20.18 Coalition Plaintiffs’ Reply Brief in Support of Motion for Preliminary Injunction08.03.18 Coalition Plaintiffs’ Motion for Preliminary Injunction07.17.18 Coalition Plaintiffs’ Response to Motion to Dismiss Third Amended Complaint06.13.18 Coalition Plaintiffs’ Third Amended Complaint Accepted04.16.18 Coalition Plaintiffs’ Opposition to Motion for Extension of Time04.05.18 Coalition Plaintiffs’ Request for Status Conference04.04.18 Coalition Plaintiffs’ Proposed Third Amended Complaint

© 2023 Coalition for Good Governance | All Rights Reserved | Coalition for Good Governance is a nonpartisan, nonprofit organization (501(c)(3)) focused on election security and transparency.

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