EXCEPTIONS TO REPORT OF THE SPECIAL MASTER

Plaintiff State of Delaware respectfully submits the following exceptions to the First Interim Report of the Special Master issued on July 23, 2021:

1. Delaware takes exception to, and this Court should decline to adopt, the Special Master’s report and recommendation to deny Delaware’s request for partial summary judgment and to grant Defendants’ request for partial summary judgment.

2. Delaware takes exception to, and this Court should decline to adopt, the components of the Special Master’s report and recommendation, including:

a. The Special Master’s definition of “money order”;

b. The Special Master’s definition of “third party bank check”;

c. The Special Master’s definition of “other similar written instrument”;

d. The other flaws discussed in the accompanying brief, which addresses these exceptions (and related errors) more fully.

CONSOLIDATED WITH 146 Orig. https://www.supremecourt.gov/search.aspx?filename=/docket/docketfiles/html/public/22o145.html