"I can confirm that neither I, nor my staff, were involved in accessing, entering or manipulating the IEBC entries. To my knowledge there was no such tallying system which received data or images from the Kiems Kits, manipulated it, or uploaded it to the IEBC system," says Chirchir in his affidavit.
The two were responding to allegations contained in the affidavits filed by anti-corruption crusader John Githongo in support of Raila's petition which allege that unauthorised individuals were granted access to the IEBC systems and manipulated form 34As to favour Ruto. Mr Githongo claims he got hold of a hacker allegedly hired by Itumbi, who confessed to intercepting and uploading form 34As and doctoring the figures before re-uploading them to the IEBC public portal.
The whistle-blower confesses to being part of the 56-member team he claims had 10 supervisors who included Chirchir and Itumbi. Others mentioned as having been part of the team include a Mr Kibyegon, Morris Mutegi, Baby Serge and Jackson Kandi.
Fictional story
"I do not know any of these listed individuals other than Itumbi," explains Chirchir, adding he and Itumbi did not work together in any capacity in relation to the presidential campaign either before the polls, on election date or even during the tallying process. Just like Chirchir, Itumbi describes Githongo's affidavit as a hearsay, fantasy and fictional story with shadowy imaginary characters and locations.
"Contrary to Githongo claims, Kenya Kwanza had no tallying centre in Karen and it did not hire any computer scientist for any role," explains Itumbi, adding that the party and secretariat tallying teams had no direct contact during the exercise.
"There was no tallying team which received data or images from the Kiems Kits, Manipulated it and then uploaded to it through the IEBC systems," says Itumbi
Her further claims that he was not personally involved in the tallying even though he admits having ran what he describes as an effective and real time 24 hour parallel centre. He claims the information he relayed through the parallel centre was obtained from IEBC portal which the public was allowed access as well as agents stationed at the polling stations. He argues that setting up the tallying centre was a product of real time tests and lessons learned over time.
Tested concept
"These initiatives were not new for the General Election," he says in the court papers, "Rather we started testing and developing the concept during the by-elections held in Msambweni Kwale, Juja in Kiambu, Bonchari in Kisii and Kiambaa in Kiambu county."
He says that during the August 9 General Election, Kenya Kwanza engaged and deployed over 46,000 polling stations agents. Another 4,600 managers were engaged to manage these polling stations, each who was responsible for 10 polling stations. The managers reported to the Mashinani Hustler Nation coordinators. There were also 290 Mashinani Hustler Nation Coordinators, each in every constituency.
The coalition, Itumbi says also engaged 4,600 boda bodas whose task was to transport the managers to collect the hard copy form 34As from their polling station, immediately they were signed by the Presiding officers. According to Itumbi, the forms were eventually taken to UDA party headquarters along Ngong Road which were used to compare with the results being verified and announced at Bomas of Kenya.
Another witness, Geoffrey Koech Kipngosos, whose laptop was seized by the police at Bomas of Kenya on allegation of hacking, denies ever manipulating forms 34As nor re-uploading different forms 34As different from those on the IEBC portal adding that he had no capacity to do so. He further denies that an external IP address http://173.249.40.177/ found on his laptop, was used to download form 34As for purpose of staging and re-uploading to the IEBC portal through a Microsoft Sharepoint application.
"The mentioned IP address was Kenya Kwanza's IP address for our system platform for data collection on Microsoft windows server," he said, pointing out that the server was acquired for development, testing and training.
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He further claims that the allegation that an external IP address was being used to download form 34As for staging and re-uploading to the IEBC portal is wild and false.
"The petitioner does not explain how I was supposed to acess IEBC portal in order to upload my copies of the alleged other altered forms. I am not even aware of what storage platform or IPO address IEBC was using as I was never connected to it.
He claims that as an ICT agent, he was using his laptop to compare the electronic form 34As downloaded from the IEBC portal with the original form 34As presented by the returning officer. He avers that he was recruited into Kenya Kwanza Alliance and was tasked to build a WhatsApp bot for its agents that could collect and transmit results from the polling stations. The agents were then trained on how to use the bot.