Demand | Kim Seward

From: Kim Seward <>
Sent: Tuesday, August 30, 2022 12:13 PM
To: Miller, Joel <>
Subject: Election Integrity

August 30,2022

Via U.S. Mail & E-Mail

Joel Miller

Linn County Auditor

935 2nd St SW

Cedar Rapids, Iowa 52404-2100

E-mail: Joel.miller

Re: Notice of Prospective Litigation; Demand for Records Retention

Dear MR. Miller:

I am an aggrieved citizen of the United States and of the state of Iowa, and I am contemplating filing a lawsuit against the relevant parties pertaining to the continuing concerns I have regarding the integrity of all elections that took place after December 31, 2019. Accordingly, I hereby notify you and instruct you to retain any and all documents and other materials related to all post-2019 federal and state elections through the date of this letter and continuing thereafter.

As you are likely aware, federal and, in many cases, state law requires that all records and papers which come into the possession of an election official relating to any application, registration, payment of poll tax, or other act requisite to voting in the such election be kept and maintained for a period of twenty-two months from the date of the respective election. Among the records and papers that must be maintained are paper ballots and records, which may be necessary for a post-tabulation audit.

Given the litigation I am contemplating commencing in regard to the post-2019 elections, I demand that you retain any and all records, including, but not limited to poll books; precinct register pages with signatures and button text; all voting machine tapes AVC and ICX; all results reports including the worksheet, the ICC results printout, the ICX results report, and the challenge removal reports; all public and protective count sheets for early voting; all elections verification forms for early voting; all records of elections submitted after the election reflecting all machines used in the election even if delivered on Election Day; all notation of irregularities reports; the list of early voters checked during preparation and verification; the reports printed from any voter registration computer system reflecting every individual given credit for voting Election Day, early voting and absentee by mail; up-to-date turnout reports for each county or parish in the state; and AVC layout sheets showing lockout information in each precinct.

In addition, please retain all information and documents pertaining to temporary hires, including hires from any public or private entity, for the purpose of elections; solicitation letters to qualified electors to participate voluntarily or for payment to work the election polls; any and all contracts signed by authorities vested in you with federal or state entities, including but not limited to the U.S. Department of Homeland Security, Federal Bureau of Investigation and other public or private entities (including but not limited to Craig Newmark Philanthropies and Facebook that have contracted, are currently contracting or otherwise engaging in any transactions or business with any federal or state entity to provide services, which may include but are not limited to cybersecurity, training, monitoring, transportation paper shredding, and other services ostensibly for the purpose of ensuring election integrity. This request also encompasses any and all communications, documents, e-mails, text messages, voice recordings, and other information or tangible evidence in your possession transmitted between or among public and private entities, including but not limited to the U.S. Department of Homeland Security, the Cybersecurity and Infrastructure Security Agency, and/or the Center for Internet Security, Inc.(CIS Security), including its subsidiary such as Elections Infrastrcture Information Sharing and Analysis Center (EI ISAC), relating to post-2019 federal and state elections.

This notice requires you to retain any and all records pertaining to any post-2019 federal or state election until notified in writing of the end of the retention period, including any election that may take place subsequent to the date of this letter. In the event the law mandates that a record retention period be specified, please note that all records must be maintained until at least September 3, 2023.

This records retention hold, and notice suspends any normal deletion requirements for documents, e-mail, and other information that may otherwise apply. Do not destroy, delete or in any way alter any paper or electronic information relating to my prospective claims or the other areas of interest mentioned above. Be sure to communicate this requirement to the employees who work under your supervision.

In determining what information you may have in your possession, custody or control that is pertinent to the claims described above, you should consider the following sources: paper files maintained by you or your department, whether in the office or elsewhere; personal notes, calendars or diaries; information maintained (or stored) electronically by you on any personal or company computer, network, smartphone, compact disc or DVD, jump drive, or any other electronic storage media; e-mails; voicemails; and text messages. This listing is not intended to be an exclusive listing of potential sources.

If you have possession, custody or control of any information, whether in paper form or electronic form, pertaining to my prospective claims, you are instructed to take immediate steps to preserve it in its original form. For example, do not delete any emails, internet files or other computer files containing information pertaining to the claims. You should also take steps to ensure that emails and files will not automatically be deleted by the system. Once you have identified any relevant information in your possession, please coordinate with me to ensure that I am provided with a copy of it.

If you are aware of any person employed by or otherwise affiliated with your organization, whether presently or formerly, who may have information pertinent to my prospective claims, please provide me with that information. In addition, please make sure that any person who is assigned to manage the computers or files of your organization that may contain information pertinent to my prospective claims is immediately informed of the requirements set forth in this letter. You must ensure that any such person does not delete any information and makes arrangements to preserve the information contained on the computer or in the files.

To the extent you have any concerns or questions in this regard, please contact me. Thank you for your cooperation in this matter.


Kimberly Seward

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