IN THE CIRCUIT COURT
FOR ANNE ARUNDEL COUNTY

LINDA SCHADE, ANDREW HARRIS, JUDITH BURNS, MARK ELRICH, KWAME ABAYOMI, TERRENCE FITZGERALD, SHARON BEARD, and PAUL SUH

            Plaintiffs,

vs.

MARYLAND STATE BOARD OF ELECTIONS,

LINDA H. LAMONE (in her capacity as Supervisor of Maryland’s State Board of Elections),

            Defendants.

This case is brought on behalf of registered Maryland voters and candidates for public office to ensure the integrity of the November 2004 elections, and to preserve public trust and confidence in the system by which Maryland voters will elect the next President of the United States. Specifically, Plaintiffs bring this action against the Maryland State Board of Elections and its Administrator, Linda H. Lamone, for improperly certifying the Diebold AccuVote-TS electronic voting machines used in Maryland, and then failing to either correct or decertify the machines -- as required by state and federal law -- once it became clear that the machines could neither preserve the security and reliability of the November 2004 election nor create a voter verified paper audit trail. This suit is filed now, well in advance of the November 2004 election, to make sure that Maryland, which lies at the epicenter of the nationwide electronic voting machine controversy, does not become the next Florida.

Dowload the full text of the amended complaint. (PDF 556K)

Full text of the Motion for Preliminary Injunction. (PDF 135K)

Full text of the Memorandum of Law in Support of Motion for Preliminary Injunction. (PDF 343K)

---

Full text of the SBE's Motion to Dismiss (PDF 39K) that states that the SBE is above the law.

Full text of the SBE's Memorandum in Support of the Motion to Dismiss. (PDF 147K)

---

Contract documents between the Maryland State Board of Elections and Diebold

The original contract. (PDF 136K)

Amendment one. (PDF 52K)

Amendment two. (PDF 51K)

Amendment three. (PDF 7K)