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

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O.C.G.A. S 21-2-386(a)(1)(B).56.The Georgia Legislature prescribed procedures to ensure that anyrequest for an absentee ballot must be accompanied by sufficientidentification of the elector's identity. See O.C.G.A. § 21-2-38 l(b )(1)(providing, in pertinent part, "In order to be found eligible to vote anabsentee ballot in person at the registrar's office or absentee ballot clerk'soffice, such person shall show one of the forms of identification listed in CodeSection 21-2-417 ...").57.An Affiant testified, under oath, that “It was also of particular interestto me to see that signatures were not being verified and that there were nocorresponding envelopes seen in site.” (Attached hereto as Exh. 10, MayraRomera, at par. 7).58.To reflect the very reason for process, it was documented that in theprimary election, prior to the November 3, 2020 Presidential election, manyballots got to voters after the election. Further it was confirmed that “Untoldthousands of absentee ballot requests went unfulfilled, and tens of thousandsof mailed ballots were rejected for multiple reasons including arriving too late24
to be counted. See the Associated Press, Vote-by-Mail worries: A leakypipeline in many states, August 8, 2020. 959.Pursuant to the Settlement, the Administrators delegated theirresponsibilities for determining when there was a signature mismatch byconsidering in good faith only partisan-based training - "additional guidanceand training materials" drafted by the Democrat Party Agencies’representatives contradicting O.C.G.A. § 21-2-31.B. UNLAWFUL EARLY PROCESSING OF ABSENTEE BALLOTS60.In April 2020, the State Election Board adopted on a purportedly“Emergency Basis” Secretary of State Rule 183-1-14-0.9-.15, ProcessingBallots Prior to Election Day. Under this rule, county election officials areauthorized to begin processing absentee ballots up to three weeks befoeelection day. Thus, the rule provides in part that “(1) Beginning at 8:00 AMon the third Monday prior to Election Day, the county electionsuperintendent shall be authorized to open the outer envelope ofaccepted absentee ballots …” (Emphasis added).9https://apnews.com/article/u-s-news-ap-top-news-election-2020-technology-politics-52e87011f4d04e41bfffccd64fc878e725
Page 1 and 2: IN THE UNITED STATES DISTRICCT COUR
Page 3 and 4: 2.The scheme and artifice to defrau
Page 5 and 6: 6.As set forth in the accompanying
Page 7 and 8: the internet in violation of profes
Page 9 and 10: 14.As explained and demonstrated in
Page 11 and 12: 18.Georgia’s election officials a
Page 13 and 14: 24.Plaintiff Vikki Townsend Consigl
Page 15 and 16: 32.Defendant Brad Raffensperger ("S
Page 17 and 18: 36.The jurisdiction of the Court to
Page 19 and 20: the method which the state has pres
Page 21 and 22: voter's oath. Each elector's name s
Page 23: 53.The Settlement provides that the
Page 27 and 28: C. UNLAWFUL AUDIT PROCEDURES64.Acco
Page 29 and 30: Motion for Temporary Restraining Or
Page 31 and 32: simply conducted another machine co
Page 33 and 34: 81.Another Affiant in the mail-in b
Page 35 and 36: tried to report it to a voter fraud
Page 37 and 38: into Biden’s stack, and counted a
Page 39 and 40: 95.Affiant further testifies that t
Page 41 and 42: critical of the bill. In a statemen
Page 43 and 44: foreign interference and insider ta
Page 45 and 46: persons running the Venezuelan gove
Page 47 and 48: in an election to recall President
Page 49 and 50: 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
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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 and 102:
4. An immediate order to impound al
Page 103 and 104:
CALDWELL, PROPST & DELOACH, LLP/s/
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COMPLAINT-CJ-PEARSON-V.-KEMP-11.25.2020

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