Arizona Attorney General's Office 2020 Election Investigation

This page highlights some observations of the Arizona Attorney General's Office 2020 Election Investigation of allegations from the Arizona Senate from September 24, 2021. The Arizona Attorney General (AZ AG) is responsible for investigating criminal allegations related to Election Fraud committed within the State of Arizona.

This website is focused on identifying governance gaps within Arizona Counties for the purpose of showing the need for Legislative Action to pass laws that hold the counties accountable for listening to and addressing citizen concerns. The AZ AG's report was used to identify potential governance gaps.

Separate from the collection of data being collected from the AZ AG's report to identify potential governance gaps, some of the inspector's observations are worthy of being highlighted on this page. Key points may be lost during the comparison of county behaviors to the US GAO's Green Book, which was being used as a standard for good governance in the absence of any known standard being applied by Maricopa County.

Finally, some of the inspector's investigative practices appear shallow, considering this was referred to the Arizona Attorney General's Office as a criminal investigation. Generally speaking, the Inspector relied heavily on interviews to reach report findings. None of the findings resulted in criminal charges. For example, five procedure violations in Allegation #2 were confirmed. These procedure violations were no by themselves acts of fraud committed by Maricopa County workers. However, these procedure violations were lapses in security measures intended to protect against fraud. Thus, Maricopa County workers did not commit acts of fraud, they knowingly or unknowingly, facilitated acts of fraud by not protecting early ballot security. The AZ AG's inspector could not determine the willingness of MC workers to participate in fraud without intrusive investigation to find objective evidence.

In a sad perspective, the AZ AG's shallow investigation seems in some ways to reflect poor governance at the state level whereas this assessment is concerned about poor governance at the county level. At its worst, the shallow investigation would appear to show collusion in the cover up of fraud perpetrated by others.

Was Poor Posting of Public Document Intentional?

The Arizona Attorney General's Office 2020 General Election Investigation is a publicly available document, at the following:

• https://www.azag.gov/sites/default/files/2025-06/2020_General_Election_Investigation_Summary.pdf

The document was posted rotated 90 degrees. Extra effort is needed by the public to rotate the document into the proper orientation before it can be read.

The AZ AG's Office posted a poor image of the document. As an image, report content cannot be copied. Efforts to use an Optical Character Recognition (OCR) to convert to a text file were unsuccessful. Behind the text, the image background is dark and hazy, which inhibits the OCR identification of text characters.

The poor quality of posting was either intentional or sloppiness considering the purpose of the posting was to communicate the results of the AZ AG's investigation.

Who's Who in this Investigation

Report Origin

• Karen Fann - President of the State of Arizona Senate submitted the allegations to the AZ AG's Office.
• Mark Brnovich - State of Arizona Attorney General received the allegations.
• Keith Thomas #395 - Assistant Chief Special Agent Criminal Division / Special Investigations Sections conducted the investigation.

Allegation #1 - Signature Verification

Interviews

• Nabor, Celia - Assistant Director of Early Voting
• Valenzuela, Ray - Assistant Elections Director
• [Withheld] - Personnel from Runbeck Elections Services Inc.,
• [Withheld] - Level 1 Signature Verifiers (assumed among the 33 permanent MC employees, not 40 temporary workers)

Objective Evidence

• Signature Verification training materials provided by the Arizona Secretary of State
• Signature Verification training materials from Maricopa County Elections Department
• Signature Verification training videos by the Maricopa County Elections Department
• Election data provided by the Maricopa County Elections Department

Data Notes

• Additional details are available from Special Investigation Section #SIS-2021-0482.
• All Mail-In and Drop Box ballots are sent to Runbeck Elections Services Inc where the ballots are scanned into batches. These images are then sent to the Maricopa County Elections Department where Signature Verification Process begins.
• Early ballots are sent to Signature Verifiers in batches of 250.
• Level I Signature verifiers will flag an early ballot that does not have a signature OR the signature cannot be verified.
• Flagged early ballots are "cured" by Level II Signature Verifiers. Flagged early ballots may be resubmitted for tabulation after the Level II Signature Verifier determines the early ballot is valid via the curing process.
• 1,910,317 early ballots were submitted to MC
• 17,126 early ballots were sent to Level II Signature Verifiers for curing.
  • 15,084 ballots without signatures were cured (verified valid)
  • 1,455 early ballots without signatures were rejected (not valid)
  • 587 early ballots were rejected for "bad signatures" (not valid)
• 73 Level I Signature Verifiers were involved in the 2020 General Election
  • 29 fulltime MC employees received signature verification training
  • 4 parttime MC employees received signature verification training
  • 40 temporary employees performed Level I Signature Verification without training
• Level I Signature Verifiers are expected to complete an early ballot verification at a rate of one ballot per 7.2 second (250 ballots per 30 minutes)

Assessment Questions

1. Did the Signature Verification training verify the competency of the Verifiers? If not, the training was for show, not impact.
2. If training did verify the competency of the trainee's Signature Verification, did the verify assure competency at a rate of 7.2 early ballots per second?
3. If training was important for 33 MC employees, then why didn't the 40 temporary workers receive the same training prior to performing Level I signature verifications.

Findings

• The AZ AG's inspector found "no Improper Procedures" were discovered. However, no procedures were referenced in the report, which would have served as objective evidence for the finding. The inspector relied on interviews.