Re California False Claims Act Complaint and Qui Tam
Shared by: rsg18606
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 firstname.lastname@example.org 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.