Re California False Claims Act Complaint and Qui Tam by rsg18606

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									                                           Lowell Finley
                                             Attorney At Law

                                     Law Offices of Lowell Finley
                                           1604 Solano Avenue
                                         Berkeley, CA 94707-2109

                                            Tel.: 510-290-8823
                                            Fax: 510-526-5424
                                            lfinley@wwc.com


                                                         November 21, 2003

Honorable Bill Lockyer
Attorney General
Department of Justice
1300 I Street
Sacramento, CA 95814

Re:      California False Claims Act Complaint and Qui Tam Plaintiffs’ Evidence and
         Information

Dear Attorney General Lockyer:

        Enclosed pursuant to Government Code section 12652(c)(3) is a copy of the verified
complaint filed under seal in Alameda County Superior Court today in State of California and
County of Alameda, California ex rel. James March and Beverly Harris v. Diebold Election
Systems, Inc.; Diebold, Inc.; S. Michael Rasmussen; Thomas Swidarski, and Does 1 through 100.
Also pursuant to section 12652(c)(3), this letter and the enclosed documents constitute the
written disclosure by my clients, qui tam plaintiffs James March and Beverly Harris, of the
material evidence and information they possess.

      Much of the evidence and information my clients possess is described in the verified
complaint. Additional evidence and information is set forth in the enclosed documents:

1. 7/29/03 Jim March Public Records Act request to the Alameda County Registrar of Voters.
2. 8/11/03 Jim March Follow-up PRA request to the Alameda County Registrar of Voters.
3. 9/19/03 Jim March submission to the office of the California Secretary of State.
4. 10/16/03 Jim March submission to Mark Kyle, Undersecretary of State.
5. 11/3/03 Jim March submission to Mark Kyle, Undersecretary of State.
6. CD labeled “Diebold Test CD” prepared by Jim March. Please see the file “General contents
of the Diebold test CD.html” for a listing and description of the contents of the CD.

         Please feel free to contact me if there is additional information I might be able to provide.

                                                         Sincerely,


                                                         Lowell Finley

Encls.

								
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