Re California False Claims Act Complaint and Qui Tam
Document Sample


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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