COMPLAINT-CJ-PEARSON-V.-KEMP-11.25.2020

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10. An emergency declaratory judgment that voting machines beSeized and Impounded immediately for a forensic audit—byplaintiffs’ expects;11. A declaratory judgment declaring absentee ballot fraud occurredin violation of Constitutional rights, Election laws and under statelaw;12. A permanent injunction prohibiting the Governor and Secretaryof State from transmitting the currently certified results to theElectoral College based on the overwhelming evidence of electiontampering;13. Immediate production of 36 hours of security camera recording ofall rooms used in the voting process at State Farm Arena in FultonCounty, GA from 12:00am to 3:00am until 6:00pm on November 3.14. Plaintiffs further request the Court grant such other relief as isjust and proper, including but not limited to, the costs of this actionand their reasonable attorney fees and expenses pursuant to 42U.S.C. 1988.Respectfully submitted, this 25th day of November, 2020.102
CALDWELL, PROPST & DELOACH, LLP/s/ Harry W. MacDougaldHarry W. MacDougaldGeorgia Bar No. 463076CALDWELL, PROPST & DELOACH, LLPTwo Ravinia Drive, Suite 1600Atlanta, GA 30346(404) 843-1956 – Telephone(404) 843-2737 – Facsimilehmacdougald@cpdlawyers.comCounsel for Plaintiffs/s Sidney Powell*Sidney Powell PCTexas Bar No. 16209700Julia Z. Haller *Emily P. Newman*Virginia Bar License No. 842652911 Turtle Creek Blvd, Suite 300Dallas, Texas 75219*Application for admission pro hac viceForthcomingL. Lin WoodGA Bar No. 774588L. LIN WOOD, P.C.P.O. Box 52584Atlanta, GA 30305-0584Telephone: (404) 891-1402Howard Kleinhendler*NEW YORK BAR NO. 2657120Howard Kleinhendler Esquire369 Lexington Avenue, 12th FloorNew York, New York 10017Office (917) 793-1188Mobile (347) 840-2188howard@kleinhendler.comwww.kleinhendler.com103
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IN THE UNITED STATES DISTRICCT COUR
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2.The scheme and artifice to defrau
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6.As set forth in the accompanying
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the internet in violation of profes
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14.As explained and demonstrated in
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18.Georgia’s election officials a
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24.Plaintiff Vikki Townsend Consigl
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32.Defendant Brad Raffensperger ("S
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36.The jurisdiction of the Court to
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the method which the state has pres
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voter's oath. Each elector's name s
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53.The Settlement provides that the
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to be counted. See the Associated P
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C. UNLAWFUL AUDIT PROCEDURES64.Acco
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Motion for Temporary Restraining Or
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simply conducted another machine co
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81.Another Affiant in the mail-in b
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tried to report it to a voter fraud
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into Biden’s stack, and counted a
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95.Affiant further testifies that t
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critical of the bill. In a statemen
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foreign interference and insider ta
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persons running the Venezuelan gove
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in an election to recall President
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a. Barcodes can override the voters
Page 51 and 52: inventory provided by Smartmatic is
Page 53 and 54: election offices, many of whom do n
Page 55 and 56: Dr. Eric Coomer, a Vice President o
Page 57 and 58: 117.It was widely reported that "As
Page 59 and 60: Colorado resident Joe Oltmann discl
Page 61 and 62: President Trump by 12,670 votes by
Page 63 and 64: normal distribution of voting gains
Page 65 and 66: short, tens of thousands of votes d
Page 67 and 68: 135.Defendants are not part of the
Page 69 and 70: be in the database of unreturned ba
Page 71 and 72: 145.The Court has held that to ensu
Page 73 and 74: Plaintiffs also bring this action u
Page 75 and 76: we typically receive the machines,
Page 77 and 78: had in fact seen, “absentee ballo
Page 79 and 80: Trump has won the election and tran
Page 81 and 82: contravene the requirements of the
Page 83 and 84: COUNT IVFOURTEENTH AMENDMENT, U.S.
Page 85 and 86: fraudulent votes “debase[]” and
Page 87 and 88: 183.Plaintiffs contest the results
Page 89 and 90: d) further a failure to demonstrate
Page 91 and 92: 136,098 ballots were illegally coun
Page 93 and 94: 195.The Fourteenth Amendment Due Pr
Page 95 and 96: officials from unlawfully eliminati
Page 97 and 98: 202.Consequently, Defendants create
Page 99 and 100: REQUEST FOR RELIEF208.Accordingly,
Page 101: 4. An immediate order to impound al
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