1.05

Control Environment

Principle 1: Demonstrate Commitment to Integrity and Ethical Value

Attribute: 1.05: Tone at the top can be either a driver, as shown in the preceding paragraphs, or a barrier to internal control. Without a strong tone at the top to support an internal control system, the entity's risk identification may be incomplete, risk responses may be inappropriate, control activities may not be appropriately designed or implemented, information and communication may falter, and results of monitoring may not be understood or acted upon to remediate deficiencies.

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Jamies Story

November 2022: Mid-term Election

Katie Hobbs was serving as the Arizona Secretary of State while running for Arizona Governor during the 2022 Mid-term elections. Katie was serving an oversight role for all Arizona county elections as the Arizona Secretary of State. Relevant to this Green Book Attribute 1.02, she refused to recuse herself from the oversight role, from which ethical questions arose. She was setting the tone at the top, complying with the law was important, but ethics, not so much. This sends a signal to subordinates; they may also demonstrate unethical behavior as long as it is legally compliant.

May 15, 2025: Let’s Play Hot Potato

A Maricopa County employee replied to one of Jamie's inquiries with “We have no statutory responsibility to answer your questions.” This comment would be expected from a frontline employee given that Maricopa County leadership and legal team included the following in their March 12, 2026: Maricopa County Defense Briefing, "Defendants have no duty to explain." Maricopa County culture appears to be aligned from top to bottom for the purpose of maintaining a minimum level of performance necessary to comply with applicable laws and regulations. As described in Attribute 1.05 "doing the minimum" attitude may adversely impact the internal control system, the entity's risk identification may be incomplete, risk responses may be inappropriate, control activities may not be appropriately designed or implemented, information and communication may falter, and results of monitoring may not be understood or acted upon to remediate deficiencies.

March 12, 2026: Maricopa County Defense Briefing

This specific discussion of a Potential Green Book Deviation is from a sub-section titled, Contract with the Motor Vehicle Department (MVD).

The MC legal team claimed there is no contract between MC and the Arizona MVD. This is almost impossible to comprehend given that the MVD was performing voter registration activities with a direct impact to election outcomes and yet, there was no written agreement between these two government entities. Given there is virtual certainty of some type of written agreement, I can assume that I was denied access to the documentation because I did not use the correct terminology in my records request, even though my intent was clear.

Contrary to the Green Book, I presume that I was denied access to the written agreement between MC and the Arizona MVD because MC management simply didn't want to disclose the agreement. The bureaucratic work around may have been to deny my request based on a technicality. Perhaps the written agreement was called a Memorandum of Understanding instead of a contract. Maybe, the other government entity was Arizona Department of Transportation, not the MVD. The act of denying access to the written agreement because I did not use the correct terminology would violate ethical practices given there is no public information available from which I would have been able to use the correct terminology. With this supposition, MC management and legal team would be collaborating on this questionable tactic to deny public access to records that directly relate to internal controls.

June 1, 2026: Judge's Decision

The Runbeck and Dominion contracts were delivered by Maricopa County. However, the Judge ruled the other requested documents were not required by law. Therefore, the minimum was fulfilled. Meanwhile, MC withheld documents that could demonstrate their integrity, ethical behavior and accountability to its citizens had they been created and made available to the public.  

June 8, 2026: Arizona State Ombudsman Replies

Maricopa County's Ombudsman are ethically deficient to Arizona State Ombudsman. Maricopa County has job positions with Ombudsman in the title. However, Maricopa County Ombudsmen 1) are not trained as Ombudsman, 2) are not operating within an internationally recognized process for Ombudsman, and do not have their independence legally established by statute or county ordinance. Senior leadership apparently condones the practice of using a dictionary definition of Ombudsman as the criterion for using Ombudsman in a Job Title. A model program is available at the State level, which is being ignored. Deficient internal controls are less likely to be identified when Ombudsmen do not have the legally defined independence from the line organization.

Election Anomalies

Arizona Senate Allegations

As already noted in Green Book Attribute 1.01, 1.02, 1.03 and 1.04 Arizona Senate allegations arose from a failure to recognize the Arizona Senates Oversight Role. These allegations were investigated and reported on by the Arizona Attorney General's Office 2020 General Election Investigation. The elected officials were considered as a possible oversight entity for MC operations.

This Green Book attribute emphasizes "Tone at the top can be either a driver, as shown in the preceding paragraphs, or a barrier to internal control." The MCBOS didn't cooperated with the Senate. The MCBOS did not respond to subpoenas issued (twice) by the Senate. Instead, the MCBOS chose to pursue court remedies to keep their information private and prevent outsiders from inspecting their equipment. If this is the tone at the top, how do you think subordinates would respond to inquiries?

This potential deviation from the Green Book standard applies to the following Arizona Senate Allegations:

• Allegation #1 Signature Verifciaton
• Allegation #2, Maricopa Dropbox Collection (2020)
• Allegation #3, Maricopa Election Management Server (2020)

All of the following are sub-allegations of Allegation #3:

• MC EMS 2020 - Election Management System Database Purged
• MC EMS 2020 - Election Files Deleted
• MC EMS 2020 - Corrupt Ballot Images
• MC EMS 2020 - Missing Ballot Images
• MC EMS 2020 - Failure to Follow Basic Cyber Security Practices
• MC EMS 2020 - Subpoenaed Equipment Not Yet Provided
• MC EMS 2020 - Anonymous Logins
• MC EMS 2020 - Dual Boot System Discovered
• MC EMS 2020 - Operating System Logs Not Preserved
• MC EMS 2020 - Internet Connections to the EMS

• Allegation #4, Maricopa County Withholding Audit Data (2020)
  • The uncooperative tone is clearly displayed by the MCBOS and MCBOS member Bill Gates.
• Allegation #5, Pima County Embedded 35,000 Votes (2020)
• Allegation #6, Unknown Published Election Fraud Flyer (2020)

Maricopa County Directs the Use of Sharpie Pens

This Green Book Attribute, 1.05, emphasizes the importance of integrity and ethics. The appropriate remediation action to address a known deficiency is to stop using Sharpie Markers. Instead, the email appear to avoid premature detection by external sources by suspending the use of Sharpie Pens and then reinstating their use on Election Day. This action is contrary to any remedial action to address a deficiency. Thefollowing unethical practices were revealed by this Maricopa County email:

• Maricopa County Leader directed the use of Sharpie Markers on Election Day contrary to their acknowledgement of issues arising from the use of Sharpie Markers, which had occurred prior to October 22, 2020. Maricopa County Leader asked personnel to stop using Sharpie Markers and use Ballpoint Pens until the Election Day in an apparent attempt to prevent premature escalation of the issue until after the election.
• Inspectors were the target audience of this email message. The inspectors were informed of issues and concerns with Sharpie Markers. Yet, the email asked inspectors to intentionally distribute Sharpie Pens on Election Day after issues and concerns with the use of Sharpie Pens had been identified. The very people (i.e., inspectors) that should have been ensuring secure elections apparently complied with the request to distributed Sharpie Marker to voters on Election Day, even though there were know issues with Sharpie Markers. The Maricopa County Leader seeks to ensure everyone is passing out Sharpie Markers contrary to the ballot instructions. Everyone is alerted to issues and concerns with the Sharpie Markers, but apparently no one questioned their extensive use on Election Day. This email message was delivered by the Elections Department Assistant Director for Recruitment and Training. In this case, numerous temporary workers are hired for a short period of time, for the single purpose of supporting an election. The Assistant Director for Recruitment and Training would have been more influential to newly hired temporary workers. It seems odd that a staff management position (i.e., Training) would be communicating a line management decision, or what should be a line management decision.
• An investigation into 2022 Mid-term election anomalies confirmed that Sharpie Markers bled through some ballots, which would be consistent with the reports of "issues and concerns" identified with the use of Sharpie Markers before October 22, 2020.
• As Maricopa County tells the story, they were concerned about long lines at voting centers. Their story goes on to attribute ballot tabulator fouling as the cause of long lines; delays and long lines occurred when voting stopped to clean the tabulators. They attributed fouling of the ballot tabulator to the wet ink from ballpoint pens being transferred to the tabulator. Their solution was to distribute Sharpie Markers at the Voting Centers to the voters; Sharpie ink apparently dries faster than ballpoint pen ink. The problem with their story is that it sounds more like an excuse than a plan. If any part of their story had been documented, which showed a thoughtful investigation, then most of the public's suspicions of foul play even would have been resolved, even if the corrective action to use Sharpie Markers was wrong.