FILED Sheryl Guy Ani 13th Circuit Court STATE OF MICHIGAN IN THE CIRCUIT COURT FOR THE COUNTY OF ANTRIM WILLIAM BAILEY Plaintiff Case No. 20-9238-CZ v ANTRIM COUNTY HON. KEVIN A. ELSENHEIMER Defendant, SECRETARY OF STATE JOCELYN BENSON Intervenor-Defendant, Matthew S. DePerno (P5262) Haider A. Kazim (P66146) DEPERNO LAW OFFICE, PLLC CUMMINGS, MCCLOREY, DAVIS & ACHO, PLC Attomey for Plaintiff Attomey for Defendant 951 W. Milham Avenue 319 West Front Street PO Box 1595 Suite 221 Portage, MI 49081 Traverse City, MI 49684 (269) 321-5064 (231) 922-1888 Heather S. Meingast (P55439) Erik A. Grill (P64713) Assistant Attorneys General Attomeys for Proposed Intervenor-Defendant Benson PO Box 30736 Lansing, MI 48909 (517) 335-7659 PLAINTIFF'S FIRST AMENDED EXPERT WITNESS LIST Plaintiff WILLIAM BAILEY, by and through his attomey, DePERNO LAW OFFICE, PLLC, submit for his First Amended Expert Witness List the following: 1. James Penrose; EXPERT WITNESS; c/o Deperno Law Office, PLLC Mr. Penrose is expected to testify as to election integrity, systems, process, generally accepted practices, standards of care, and election voting systems, including the Dominion Voting Systems. He is expected to testify regarding adjudication logs, systemsfiles, applications security issues, eyber/computer network operations, data analysis, and operations integration in computer and voting systems. He is expected to base his testimony on his review and analysis of election data and materials, his Report, Plaintif?s claims, Defendants’ defenses, and any other information that becomes available through the course of discovery with respect to this case. Plaintiff reserves the right to supplement this disclosure. Ben Cotton; EXPERT WITNESS; c/o DePerno Law Office, PLLC Mr. Cotton is expected to testify to testify as to application security, systems, process, generally accepted programming practices, standards of care, as it relates to applicati development of sensitive systems. He is expected to testify regarding best practices for access control, exception handling, error handling, auditing, and logging. He is expected to testify on the adjudication process, and the lack of adjudication logs found on the forensic images of voting equipment used in Michigan in the November 3, 2020 election. He is expected to base his testimony on his review of the forensics images obtained from the Antrim County computer system, a review of Dominion Voting Systems publi available documentation and resources, deposition testimony that will be generated in this. matter, documentation regarding the forensic images, his Report, Plaintiff's claims, Defendants’ defenses, and any other information that becomes available through the course of discovery with respect to this case. Plaintiff reserves the right to supplement this disclosure, ; c/o DePerno Law Office, PLLC Doug Logan; EXPERT WITNES Mr. Logan is expected to testify as to application security, systems, process, generally accepted programming practices, standards of care, as it relates to application development of sensitive systems, He is expected to testify regarding best practices for access control, exception handling, error handling, auditing, and logging. He is expected to testify on the adjudication process, and the lack of adjudication logs found on the forensic image. He is expected to base his testimony on his review of the forensics images obtained from the Antrim County computer system, a review of Dominion Voting Systems publicly available documentation and resources, deposition testimony that will be generated in this matter, documentation regarding the forensic images, his Report, Plaintiff's claims, Defendants’ defenses, and any other information that becomes available throughout the course of discovery with respect to this case. Plaintiff reserves the right to supplement this disclosure. Greg Freemyer; EXPERT WITNESS; c/o DePerno Law Office, PLLC Mr. Freemyer is expected to testify regarding the identification and forensic i preservation of the Antrim County election management server, thumb drives, and compact flash cards performed in this case. He is expected to base his testimony on his knowledge and review of the forensic imaging process obtained from the Antrim County computer system, deposition testimony that will be generated in this matter, documentation regarding the forensic images, the ASOG Report, Plaintiff's claims, Defendants’ defenses, and any other information that becomes available throughout 2course of discovery with respect to this case. Plaintiff reserves the right to supplement this disclosure. Paul Maggio; EXPERT WITNESS; c/o DePerno Law Office, PLLC Mr. Maggio is expected to testify regarding the identification and forensic imaging and preservation of the Antrim County election management server, thumb drives, and compact flash cards performed in this case. He is expected to base his testimony on his knowledge and review of the forensic imaging process obtained from the Antrim County computer system, deposition testimony that will be generated in this matter, documentation regarding the forensic images, the ASOG Report, Plaintiffs claims, Defendants’ defenses, and any other information that becomes available throughout course of discovery with respect to this case. Plaintiff reserves the right to supplement this disclosure. Col. James P. (Phil) Waldron; EXPERT WITNESS; c/o DePerno Law Office, PLLC Col. Waldron is expected to testify as to election integrity, systems, process, generally accepted practices, standards of care, and election voting systems, including the Dominion Voting Systems. He is expected to testify regarding adjudication logs, systems files, applications security issues, and the review and preparation of the Antrim Michigan Forensics Report, Revised Preliminary Summary, v2, dated December 13, 2020 ("ASOG Report"). He is expected to testify regarding cyber/computer network operations, data analysis, and operations integration in computer and voting systems. He is expected to documentation regarding the forensic images, the ASOG Report, Plaintiffs claims, Defendants’ defenses, and any other information that becomes available throughout course of discovery with respect to this case. Plaintiff reserves the right to supplement this disclosure. Russel Ramsland; EXPERT WITNESS; c/o DePerno Law Office, PLLC Mr. Ramsland is expected to testify as to election integrity, systems, process, generally accepted practices, standards of care, and election voting systems, including the Dominion Voting Systems. He is expected to testify regarding adjudication logs, systems files, applications security issues, and the review and preparation of the Antrim Michigan Forensics Report, Revised Preliminary Summary, v2, dated December 13, 2020 ("ASOG Report"). He is expected to testify regarding cyber/computer network operations, data analysis, and operations integration in computer and voting systems. He is expected to testify on how the Dominion Voting Systems affects elections. He is expected to base hi testimony on his review of the forensics images obtained from the Antrim County computer system, deposition testimony that will be generated in this matter, documentation regarding the forensic images, the ASOG Report, Plaintiff's claims, Defendants’ defenses, and any other information that becomes available through course of discovery with respect to this case. Plaintiff reserves the right to supplement this disclosure. Dr. Douglas G. Frank; EXPERT WITNESS; c/o Deperno Law Office, PLLC 310. A 12. Dr. Frank is expected to testify as to his analysis of data, conclusions, and his Report pertaining to the November 3, 2020 election. Seth Keshel; EXPERT WITNESS; c/o Deperno Law Office, PLLC Mr. Keshel is expected to testify as to his analysis of data, and conclusions pertaining to the November 3, 2020 election. Jeffrey Lenber XPERT WITNESS; c/o Deperno Law Office, PLLC Mr, Lenberg is expected to testify as to application security, systems, process, generally accepted programming practices, standards of care, as it relates to ap development of sensitive systems, He is expected to testify regarding best practices for access control, exception handling, error handling, auditing, and logging. He is expected to testify on the adjudication process, and the lack of adjudication logs found on the forensic image. He is expected to base his testimony on his review of the forensics images obtained from the Antrim County computer system, a review of Dominion Voting Systems publicly available documentation and resources, deposition testimony that will be generated in this matter, documentation regarding the forensic images, his Report, Plaintiffs claims, Defendants’ defenses, and any other information that becomes available throughout the course of discovery with respect to this case. Plaintiff reserves the right to supplement this disclosure. Todd Sanders; EXPERT WITNESS; c/o Deperno Law Office, PLLC Mr. Sanders is expected to testify as to application security, systems, process, generally accepted programming practices, standards of care, as it relates to application development of sensitive systems, He is expected to testify regarding best practices for access control, exception handling, error handling, auditing, and logging. He is expected to testify on the adjudication process, and the lack of adjudication logs found on the forensic image. He is expected to base his testimony on his review of the forensics images obtained from the Antrim County computer system, a review of Dominion Voting Systems publicly available documentation and resources, deposition testimony that will be generated in this matter, documentation regarding the forensic images, his Report, Plaintiff's claims, Defendants’ defenses, and any other information that becomes available throughout the course of discovery with respect to this case. Plaintiff reserves the right to supplement this disclosure. Conan Hayes; EXPERT WITNI ESS; c/o Depemno Law Office, PLLC Mr. Sanders is expected to testify as to application security, systems, process, general accepted programming practices, standards of care, as it relates to application development of sensitive systems. He is expected to testify regarding best practices for access control, exception handling, error handling, auditing, and logging. He is expected to testify on the adjudication process, and the lack of adjudication logs found on the forensic image. He is expected to base his testimony on his review of the forensics images obtained from the Antrim County computer system, a review of Dominion Voting Systems publicly available documentation and resources, deposition testimony that will 4be generated in this matter, documentation regarding the forensic images, his Report, Plaintiff's claims, Defendants’ defenses, and any other information that becomes available throughout the course of discovery with respect to this case. Plaintiff reserves the right to supplement this disclosure. 13, Any rebuttal or impeachment witness necessary to rebut any evidence or testimony presented by any other party to this lawsuit. 14, Any expert witness required to rebut evidence presented by Defendants 15, Plaintiffs reserve all rights to identify further witnesses as they become known, Respectfully submitted DePERNO LAW OFFICE, PLLC Dated: April 8, 2020 /s/ Matthew 8. DePerno Matthew 8. DePerno (P5262) Attomey for Plaintiff gj