1.04

Control Environment

Principle 1: Demonstrate Commitment to Integrity and Ethical Values

Tone at the Top

Attribute 1.04: The oversight body's and management's directives, attitudes, and behaviors reflect the integrity and ethical values expected throughout the entity. The oversight body and management reinforce the commitment to doing what is right, not just maintaining a minimum level of performance necessary to comply with applicable laws and regulations, so that these priorities are understood by all stakeholders, such as regulators, service organizations, employees, and the public.

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Jamie's 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. However, Attribute 1.04 has a different perspective, with the following statement, "The oversight body and management reinforce the commitment to doing what is right, not just maintaining a minimum level of performance necessary to comply with applicable laws and regulations, so that these priorities are understood by all stakeholders, such as regulators, service organizations, employees, and the public." Empasis was by ACV.

March 12, 2026: Maricopa County Defense Briefing

Maricopa County management avoided responsibility to doing the right-thing by claiming they were in full compliance with the law.

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. The "right thing" for Maricopa County to do would be to implement a fully developed Ombudsman program. Instead, they chose to create job positions with Ombudsman in the job title based on a dictionary definition of Ombudsman.

June 9, 2026: Maricopa County Ombudsman Replies

The Maricopa County Ombudsman was not fulfilling the expected Ombudsman to listen to citizen issues and conduct an independent investigation accordingly. In this case, the Ombudsman read remail, referred the request to another department and informed Jamie of the action she had taken. Ethically, this isn't the expected response from an Ombudsman operating within the government sector. The right thing to do would have been to investigate the complaint as an independent. Instead, Jamie's issue was referred to another department just as described on the May 15, 2025, Let's Play Hot Potato page.

Election Anomalies

Arizona Senate Allegations

As already noted in Green Book Attribute 1.01, 1.02, and 1.03 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 the need to "commitment to doing what is right, not just maintaining a minimum level of performance necessary to comply with applicable laws and regulations, so that these priorities are understood by all stakeholders, such as regulators, service organizations, employees, and the public," MC Elected Officials and MC leadership were apparently doing less than the minimum given their position that the Arizona Senate was not entitled to perform oversight. Hence, the oversight and management were both demonstrating a lack of integrity and unethical behavior in the eyes of the public because of their lack of transparency. This potential deviation from the Green Book standard applies to the following Arizona Senate Allegations:

• Allegation #1 Signature Verifciaton
  • Our of 1,910,317 early ballots tallied, the Level I Signature Verifiers only rejected 587 early ballots for "bad" (mismatched) signatures.
  • Maricopa County trained 29 and 4 part-time MC employees in June 2020 to fulfill the role of Level 1 Signature Verifier. Four months later, 40 temporary employees were hired and performed Level 1 Signature Verifier duties without any training. Therefore, 55% of the Level 1 signature verifiers were untrained.
• Allegation #2, Maricopa Dropbox Collection (2020)
  • The Arizona Senate was alerted to documentation discrepancies by Verity the Vote, which was lead by two citizens. Maricopa was unable to resolve issues raised by members of the public, which is why they took their concerns to the Arizona Senate for follow up.
  • MC violated the Arizona Secretary of State's Election Procedure Manual and their own Maricopa County Election Procedures, which were written to ensure compliance with Title 16 - Elections and Electors.
  • There were five procedure violations that adversely affected the ballot security for an unknown thousands of early ballots. In this case, MC could not even do the minimum requirements of the procedure.
• 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 had a micro view by "cleaning" the server to perform logic tests. The macro view would have been to step back and reschedule the logic test to preserve forensic evidence on the drives, which was destroyed by the cleaning.
• MC EMS 2020 - Election Files Deleted
  • "Since these files are not associated to the tabulation files stored on the EMS server, they are not backed-up or archived." Valuable digital forensic evidence was lost from MC generous purging of files.
• MC EMS 2020 - Corrupt Ballot Images
  • 263,139 ballot images were reported as "unreadable." MC randomly "opened" some ballots from the designated time period to refute the allegation. Opening a document is different than assessing its readability. Additionally, no sampling size was stated in the report so no confidence level could be statistically derived.
• MC EMS 2020 - Missing Ballot Images
• MC EMS 2020 - Failure to Follow Basic Cyber Security Practices
  • MC asserts that they are not required to follow Department of Homeland Security's Cybersecurity & Infrastructure Security Agency (CISA) published guidelines because of their "air gapped" system.
• MC EMS 2020 - Subpoenaed Equipment Not Yet Provided
  • MC was not going to provide any additional information beyond what was described in the litigated settlement agreement.
• MC EMS 2020 - Anonymous Logins
  • MC asserted that the anonymous logins did not affect election results. The bigger issue is why would any IT department allow anonymous logins for any digital or networked equipment.
• MC EMS 2020 - Dual Boot System Discovered
  • It appears that MC had knowlege of a Dual Boot System prior to Cyber Ninjas discovery. In fact, it appears that the requested PacketWatch to remove any mention of the Dual Boot System from their report based on the details MC had readily available to discredit the significance of the Dual Boot System, but none of those details were in PacketWatch's report.
• MC EMS 2020 - Operating System Logs Not Preserved
  • Operating System logs for Windows security event logs are overwritten to save digital space, which eliminated forensic evidence.
• MC EMS 2020 - Internet Connections to the EMS
  • Cyber Ninjas apparently wanted to examine the routers as objective evidence to support or refute claims of internet connectivity. MC withheld the equipment because it wasn't part of the court's settlement agreement.

• 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, 1.04, emphasizes the importance of integrity and ethics. The email directed behavior that was far worse than doing the minimum. Contrary to this attribute, the following unethical practices were revealed by Maricopa County:

• 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.