April 3,, 2026, Plaintiff's Response to the Defense Briefing
On April 3, 2026, I submitted to the Arizona Superior Court for Maricopa County my response to the Maricopa County's Defense Brief.
No governance gaps were identified since this event reflected my actions.
My response is provided below.
Jamie's Timeline
- 2020: General Election Anomalies — Maricopa County has numerous election anaomalies
- 2021: My Journey Begins — Starting to ask questions about lessons learned
- November 2022: Mid-term Election — The Katie Hobbs oversaw her own election
- December 2024: Gaining Support — [My action; no governance gaps]
- April 15, 2025: Public Records Request — Public Records Request process
- May 15, 2025: Let’s Play Hot Potato — Public Records Request runaround
- November 20, 2025: Debbie Lesko Presentation - Explains Recent Lost Ballots
- December 1, 2025: Special Complaint File with Court - [My action; no governance gaps]
- February ???: Plaintiff's Briefing - [My action; no governance gaps]
- March 12, 2026: Maricopa County Defense Briefing - Maricopa County Legal Team's Defense Brief
- April 3,, 2026, Plaintiff's Response to the Defense Briefing - [My action; no governance gaps]
- June 1, 2026: Judge's Decision - Judge Rules in Favor of the County [Judge's action; no governance gaps]
- June 8, 2026: Maricopa County's Ombudsman - Ombudsman by Title without Ombudsman Independence
- August 3, 2026: Submitted Complaint — Formal complaint submitted
- August ??, 2026: Maricopa County Responds to My Complaint - ???
Plaintiff's Response
IN THE SUPERIOR COURT OF THE STATE OF ARIZONA
IN AND FOR THE COUNTY OF MARICOPA
.
JAMIE WEINHAUER MARTIN, Plaintiff,
v.
MARICOPA COUNTY, acting through the Recorder’s Office, Elections Department, Office of Procurement Services, Information Governance, and the Board of Supervisors,Defendants.
.
Case No. CV2025-063720
.
PLAINTIFF’S REPLY BRIEF
(The Honorable Randall Warner)
Plaintiff Jamie Weinhauer Martin, appearing pro per, submits this Reply to Defendants’ Response Brief.
I. THIS CASE IS NOT ABOUT PRODUCING RECORDS — IT IS ABOUT THE FAILURE TO MAINTAIN LEGALLY REQUIRED RECORDS
Defendants attempt to characterize this matter as a routine public records dispute, asserting that they produced all records in their possession and have no obligation to create additional documents. That framing avoids the legal issue before the Court.
This case concerns whether Defendants satisfied their statutory obligation to maintain records reasonably necessary to provide an accurate accounting of their official activities, as required by A.R.S. § 39-121.01(B).
Defendants’ position is effectively:
- If records do not exist, there is no violation;
- If processes were not documented, there is nothing to produce.
That position is legally insufficient.
Where statutes require defined government functions—such as election administration, ballot processing, signature verification, and compliance with prescribed procedures—those functions must be capable of being accounted for through maintained records.
An accurate accounting of official activities cannot exist without records reflecting whether those activities were performed, reviewed, or verified.
Accordingly, the absence of records is not neutral. It establishes that Defendants have failed either to:
(1) perform legally required functions; or
(2) maintain records sufficient to account for those functions.
Under either condition, Defendants have failed to satisfy A.R.S. § 39-121.01(B).
The issue before the Court is not whether records were produced, but whether Defendants complied with their statutory obligation to maintain records sufficient to provide an accurate accounting of their official activities.
II. PLAINTIFF DOES NOT SEEK CREATION OF RECORDS
Plaintiff does not request that Defendants create new records.
Plaintiff seeks records that must exist if Defendants complied with:
- Arizona public records law;
- Arizona election statutes;
- required election procedures.
Where the law requires government action, it also requires records sufficient to account for that action.
The absence of such records demonstrates that Defendants cannot provide the legally required accounting of their official activities.
III. DEFENDANTS’ OWN PRODUCTIONS CONFIRM THE ABSENCE OF REQUIRED RECORDS
Defendants’ responses establish the absence of records across all relevant departments:
Maricopa County Office of Procurement (PRR 719):
Produced base contracts only, with no records of audit, review, enforcement, or evaluation. No records show any audit or review function examined the contracts.
Maricopa County Information Governance (PRR 1123):
Did not conduct a substantive search and instead fragmented the request across departments.
Maricopa County Elections Department (PRR 139):
Confirmed no records exist demonstrating compliance, metrics, or oversight.
Maricopa County Recorder’s Office (PRR 25-64):
Produced limited materials and no records documenting review, failure, or corrective action.
Taken together, Defendants’ own evidence establishes:
- No records of compliance review;
- No records of oversight or enforcement;
- No records of corrective action;
- No records capable of providing an accurate accounting of statutory functions.
This is not a complete response; it is evidence that Defendants cannot produce records sufficient to provide an accurate accounting as required by A.R.S. § 39-121.01(B).
IV. CONTRACT RECORDS FURTHER CONFIRM THE ABSENCE OF REVIEW, OVERSIGHT, AND CORRECTIVE ACTION
The absence of records extends to the contracts governing the expenditure of public funds and election-related services.
Defendants’ productions include underlying contract materials but no records demonstrating that those contracts were subjected to audit, review, or compliance evaluation.
The contract executed on June 4, 2020—during emergency pandemic election operations—contains provisions directly relevant to continuity, disaster recovery, and operational integrity. Within that contract, material portions of disaster recovery language appear stricken or modified.
Despite the timing and subject matter of these provisions, Defendants produced no records demonstrating:
- that the contract was reviewed for adequacy in light of pandemic conditions;
- that the modified or stricken provisions were evaluated or approved through a documented process;
- that any audit, compliance review, or risk assessment was conducted;
- that any corrective action was initiated following execution or after the 2020 election.
The absence of such records is significant. Contracts governing critical election functions and public expenditures require oversight, evaluation, and corrective action where deficiencies exist.
Defendants’ productions establish that no such processes are documented. No audit function appears to have reviewed the contract. No records reflect analysis of contract terms, risk, or performance. No records reflect corrective action following the 2020 election cycle.
The issue is not the contract alone, but the absence of any documented process to review, evaluate, or correct it.
Where a contract governing public funds and election functions is executed under emergency conditions, contains material modifications, and is subsequently relied upon across multiple election cycles, the absence of audit, review, and corrective action records further demonstrates that Defendants cannot provide the accurate accounting required by A.R.S. § 39-121.01(B).
This absence is consistent with the broader pattern reflected in Defendants’ productions: required functions may have occurred, but no records exist demonstrating oversight, verification, or corrective action sufficient to satisfy statutory obligations.
V. THE ABSENCE OF RECORDS CONSTITUTES A FAILURE TO SATISFY STATUTORY DUTIES
Arizona law requires public bodies to maintain records sufficient to provide an accurate accounting of their official activities. A.R.S. § 39-121.01(B).
Arizona election statutes require:
- uniform procedures (A.R.S. § 16-452);
- ballot processing (A.R.S. § 16-550);
- signature verification (A.R.S. § 16-550.01).
These statutory requirements necessarily involve government action.
An accurate accounting depends on records demonstrating:
- that the actions occurred;
- how they were carried out;
- whether they complied with governing requirements.
Where no such records exist, the statutory requirement is not satisfied.
Defendants’ position requires acceptance that required functions were performed without any records sufficient to account for them. That position is incompatible with A.R.S. § 39-121.01(B).
Arizona law also requires logic and accuracy testing of tabulation equipment prior to use (A.R.S. § 16-449). Because that testing is a required statutory function, it must be documented in a manner sufficient to permit verification.
The issue presented here is not whether testing may have occurred, but whether Defendants maintain records sufficient to demonstrate that it occurred in compliance with statutory requirements.
VI. STATUTORY DUTIES REQUIRE DOCUMENTATION SUFFICIENT TO DEMONSTRATE COMPLIANCE
Arizona law imposes duties of documentation, accountability, and verification.
A.R.S. § 39-121.01(B) requires an accurate accounting of official activities. That requirement cannot be satisfied where activities are undocumented or unverifiable.
Election statutes requiring procedures, verification, and testing (A.R.S. §§ 16-452, 16-550, 16-550.01, 16-449) function as accountability mechanisms. Where those processes are undocumented or cannot be verified through maintained records, compliance cannot be established.
Where public funds are expended through contracts, Arizona law prohibits improper use of public monies (A.R.S. § 35-393.01). Contracts not subject to documented review, oversight, or follow-up lack any verifiable basis for compliance.
Where no records exist demonstrating evaluation, follow-up, or verification, Defendants cannot establish that statutory requirements were satisfied.
VII. DEFENDANTS’ FAILURE TO DESCRIBE THEIR SEARCH PRECLUDES JUDICIAL REVIEW
Defendants provide no information regarding:
- search scope;
- custodians;
- systems reviewed;
- methodology.
Without this information, the Court cannot determine whether a reasonable search was conducted or whether it was performed in good faith.
A conclusory assertion that “no records exist” is not verifiable and does not satisfy a good-faith search obligation.
VIII. THIS CASE PRESENTS A FAILURE OF GOVERNANCE NECESSARY TO SUPPORT RECORDKEEPING
Public discussion often focuses on election outputs. That is not the issue before the Court.
Arizona law requires documented accountability for official activities—not merely outputs.
Without records demonstrating oversight, review, enforcement, and verification, there is no basis to conclude statutory requirements were satisfied.
An accurate accounting requires documented processes showing how compliance was achieved. Without such documentation, compliance cannot be verified and cannot be established as a matter of law.
IX. REQUIRED CORRECTIVE ACTION FRAMEWORK
The record reflects that no structured audit, contract review, or corrective process was applied.
No mechanism exists to identify deficiencies, determine root causes, implement corrective action, or verify resolution.
Without such processes, Defendants cannot generate records sufficient to account for how deficiencies were addressed.
X. GOVERNANCE FAILURE RENDERS STATUTORY ACCOUNTING IMPOSSIBLE
Where no system exists to assess compliance, document review, implement corrective action, and monitor outcomes, no accurate accounting can be maintained.
This is a failure to meet statutory obligations. Judicial intervention is warranted.
Without a documented mechanism to identify deficiencies, evaluate causes, and implement corrective measures, statutory compliance cannot be achieved or sustained.
XI. REQUEST FOR RELIEF
Plaintiff respectfully requests that the Court:
Determine whether Defendants conducted a reasonable and good-faith search;
- Determine whether all responsive records were produced;
- Determine that the absence of records renders Defendants’ accounting legally insufficient under A.R.S. § 39-121.01(B);
- Issue findings regarding Defendants’ statutory compliance;
- Grant such further relief as the Court deems just and proper;
- Grant such relief as necessary to ensure Defendants implement and maintain processes sufficient to identify deficiencies, document review, and support corrective measures consistent with statutory obligations.
XII. REQUEST FOR ORAL ARGUMENT OR EVIDENTIARY HEARING
Plaintiff requests oral argument or evidentiary hearing.
DATED this 3rd day of April, 2026.
/s/ Jamie Weinhauer Martin
Jamie Weinhauer Martin
Plaintiff, Pro Per
CERTIFICATE OF SERVICE
I hereby certify that on this 3rd day of April, 2026, I electronically filed the foregoing Plaintiff’s Reply Brief with the Clerk of the Superior Court using AZTurboCourt.
/s/ Jamie Weinhauer Martin
Jamie Weinhauer Martin
Plaintiff, Pro Per
