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

36.
The jurisdiction of the Court to grant declaratory relief is conferred by
28 U.S.C. 2201 and 2202 and by Rule 57 and 65, Fed. R. Civ. P. 7.
37.
This Court has jurisdiction over the related Georgia Constitutional
claims and State law claims under 28 U.S.C. 1367.
38.
In Georgia, the "legislature" is the General Assembly. See Ga. Const.
Art. III, § I, Para. I.
39.
Because the United States Constitution reserves for state legislatures
the power to set the time, place, and manner of holding elections for Congress
and the President, state executive officers, including but not limited to
Secretary Raffensperger, have no authority to exercise that power
unilaterally, much less flout existing legislation or the Constitution itself.
STATEMENT OF FACTS
40.
Plaintiffs bring this action under 42 U.S.C. §§ 1983 and 1988, and
under Georgia law, O.C.G.A. § 21-2-522 to remedy deprivations of rights,
17