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

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61.Rule 183-1-14-0.9-.15 is in direct and irreconcilable conflict withO.C.G.A. § 21-2-386(a)(2), which prohibits the opening of absentee ballotsuntil election day:After the opening of the polls on the day of the primary, election,or runoff, the registrars or absentee ballot clerks shall beauthorized to open the outer envelope on which is printed theoath of the elector in such a manner as not to destroy the oath printedthereon; provided, however, that the registrars or absentee ballotclerk shall not be authorized to remove the contents of such outerenvelope or to open the inner envelope marked “Official AbsenteeBallot,” except as otherwise provided in this Code section.(Emphasis added).62.In plain terms, the statute clearly prohibits opening absentee ballotsprior to election day, while the rule authorizes doing so three weeks beforeelection day. There is no reconciling this conflict. The State Election Boardhas authority under O.C.G.A. § 21-2-31 to adopt lawful and legal rules andregulations, but no authority to promulgate a regulation that is directlycontrary to an unambiguous statute. Rule 183-1-14-0.9-.15 is thereforeplainly and indisputably unlawful.The State Election Board re-adopted Rule 183-1-14-0.9-.15 onNovember 23, 2020 for the upcoming January 2021 runoff election.63.26
C. UNLAWFUL AUDIT PROCEDURES64.According to Secretary Raffensperger, in the presidential generalelection, 2,457,880 votes were cast in Georgia for President Donald J. Trump,and 2,472,002 votes were cast for Joseph R. Biden, which narrowed inDonald Trump’s favor after the most recent recount.Secretary Raffensperger declared that for the Hand Recount:65.Per the instructions given to counties as they conduct their audittriggered full hand recounts, designated monitors will be givencomplete access to observe the process from the beginning. While theaudit triggered recount must be open to the public and media,designated monitors will be able to observe more closely. The generalpublic and the press will be restricted to a public viewing area.Designated monitors will be able to watch the recount while standingclose to the elections’ workers conducting the recount.Political parties are allowed to designate a minimum of two monitorsper county at a ratio of one monitor per party for every ten auditboards in a county... Beyond being able to watch to ensure therecount is conducted fairly and securely, the two-person audit boardsconducting the hand recount call out the votes as they are recounted, providing monitors and the public an additional way to keep tabson the process. 1010Office of Brad Raffensperger, Monitors Closely Observing Audit-Triggered Full HandRecount: Transparency is Built Into Process,https://sos.ga.gov/index.php/elections/monitors_closely_observing_audittriggered_full_hand_recount_transparency_is_built_into_process27
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 and 24: 53.The Settlement provides that the
Page 25: to be counted. See the Associated P
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
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
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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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