From: Tom Feehan

To: Barron, Richard L.

Cc: Strong-Whitaker, Felicia; Nicole Nollette; Scott Tucker
Subject: Dominion Invoice Questions
Date: Wednesday, January 27, 2021 5:26:20 PM

Rick,
 
Your questions regarding the Dominion Invoice for L&A support were directed to me for a response. 
I have compiled the information below to explain the services provided, timeframes engaged and
the issues encountered which contributed to the hours worked and subsequently charged to Fulton
County.
 
Scott Tucker from Dominion emailed Dwight Brower on October 16, 2020 stating that the initial
estimate of 15 people for 15 days at $2000.00 per day is based upon an 8-hour day, and that
overtime hours will be charged additionally, possibly adding significantly to the total. The original
quote to Fulton County from Dominion was based on a number of normal expectations we believed
to be accurate at the time.  These expectations were that all equipment was acceptance tested and
ready for L&A testing, that all of the equipment was installed in Fulton’s custom precinct carts and
that all equipment and carts were labeled for easy identification.  Upon arrival of our staff at the
Georgia World Congress Center on Monday, October 19, 2020, our team discovered that none of the
above, in whole or part, was the situation that we were working with.  Additionally, the number of
Fulton County employees that were now out had increased and included Derrick Gilstrap, who our
staff anticipated would be the County Lead for L&A.  A brief chronology of key items related to this
are noted as follows:
 
10/19/20 Monday  (Starting Day)    Derrick is out.  Equipment is being delivered in a very
happenstance manner, with precincts not being delivered in their entirety.  Many devices were not
labeled hindering proper identification.  Our Team Leads requested Fulton County’s L&A checklist
and precinct delivery schedule, which no one from the County could provide for us.  No CF cards or
USB drives were prepared in any quantity to start the L&A work.  Due to this lack or organization, no
units were processed through L& A on Monday.  Our team spent the entire day trying to sort out
equipment into precinct groups and create some cursory level of organization so that L&A could be
conducted.
 
10/20/20 Tuesday  The DVS Team Leads again requested the County’s L&A checklist, the delivery
schedule, more USB drives and more CF cards, none of which were provided. Several Fulton County
employees instructed our staff of Testers in the County’s L & A process in lieu of the checklist. 
Deliveries continued in the happenstance manner, and as preparation for starting L&A testing our
staff spent the balance of the day organizing the equipment and labeling each cart.  No units were
processed through L&A for the second day.  Our team leads made the decision to increase our staff
of testers to 30 people and run 2 shifts, as the two lost days put the L&A schedule in serious
jeopardy.
 
10/21/20 Wednesday  DVS Staff of testers now numbers 31 people working 2 shifts.  The Fulton
County staff present requested that some of our testers be diverted to assembling the precinct carts
so that there were enough carts available to install BMDs and scanners into. The DVS tester team
was informed that a quantity of 101 Two-station carts needed assembled and that 229 Four4-station
carts needed assembled, which our testers assisted with. This reduced the L&A testing staff available
to perform L&A testing.  Scott Tucker of DVS emailed Dwight Brower requesting the L&A Checklists,
the delivery schedule, more USB drives and more CF cards, with no response.  USB drives and CF
cards were being downloaded at the Prep Center, then driven to the GWCC, and the workflow of this
process did not support the pace required to efficiently perform L&A testing, resulting in delays.
 
10/22/20 Thursday   L&A Testing Staff numbers 33 people, plus some part time help working limited
hours.  Scott Tucker of DVS again emailed Dwight Brower identifying a list of bottlenecks that our
staff is encountering in efficiently performing L&A testing.  The four items previously mentioned
were again requested, with no response. Tom Feehan emailed Rick Barron with the request for the
delivery schedule, with no reply. He noted that County staff continued to request DVS assistance in
assembling precinct carts and installing the BMD and scanner units in the carts, and that this
increase in scope will require more man hours.  More Fulton County staff was now out, and DVS
again increased the testing staff to meet the deadline for L&A Completion.  The same delays with
USB drives and CF cards continued to hamper the rate of testing.
 
10/23/20 Friday   30 DVS testers are on site. No delivery schedule has been forthcoming. County
staff notified the DVS Team Leads that 350 BMDs and 218 ICPs recently purchased are needed for
this election but are not yet acceptance tested and therefore cannot be put through L&A testing. 
DVS diverts L&A testers to assist in equipment setup for UAT. There is a delay in setting up the ICPs
for UAT to mount them in the precinct carts. DVS L&A testers continue to assist in assembling carts
and installing BMDs and ICPs in the carts. However, the new order of BMDs that were acceptance
tested and then L&A tested had Hewlett Packard 501 printers, which did not fit into the printer
compartment in the custom precinct carts, causing additional delays.  DVS warehouse staff 
identified 147 HP 402dne printers in the SOS inventory and sent them to Fulton County to continue
the L&A process.  Fulton County acquired additional HP402dne printers from Cobb County. This
resulted in further delays to L&A testing.  Mitch Keddrell from DVS requested that Fulton County 
relocate an EMS server to GWCC and download USB drives and CF cards onsite to help reduce delays
waiting for cards and USB Drives that were affecting testing productivity.  The DVS Team Leads
determine that  2 shifts need to continue through the weekend, Saturday 10/24/20 and Sunday
10/25/20 to attempt to get caught up.
Dominion continued to provide L&A Testers operating on 2 shifts  throughout the week of 10/26/20
through 11/1/20 again with multiple delays caused by the unavailability of equipment to L&A test.
On 10/27/20 there were still 143 BMDs and 100 ICPs that still required acceptance testing prior to
L&A as well as 100 carts still to assemble, with many missing parts inhibiting the assembly. 
Additionally, the testers were delayed by the lag incurred in the delivery of re-purposed training ICX
units and Early Voting units that were needed for Election Day.  The testing staff worked substantial
overtime hours all week through Monday evening, 11/1/20 to complete the L&A testing in time for
the election.
 
After Election Day, Derrick requested from Angel Johnson of DVS that we continue to provide some
staff to assist his staff with post-election tasks.  DVS provide 5 to 8 people for the balance of the
week through Saturday 11/7/20.  Beginning the following week DVS provide 6 to 7 people daily for
each day of the week ending  Sunday, 11/15/20.  This resulted in additional overtime hours for that
group of individuals.  DVS again provided between 4 to 6 individuals to assist Derrick’s team for the
week ending Sunday, 11/22/20, again resulting in overtime hours for that group of individuals.
 
Please contact me directly if you require further elaboration or have any questions. I am happy to
assist you in any way to get this clarified and  processed. I am available by phone as listed below or
by reply email.
 
Best regards,
 
Tom Feehan