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

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66.The audit was conducted O.C.G.A. § 21-2-498. This code sectionrequires that audits be completed “in public view” and authorizes the StateBoard of Elections to promulgate regulations to administer an audit “toensure that collection of validly cast ballots is complete, accurate andtrustworthy throughout the audit.”67.Plaintiffs can show that Democrat-majority counties provided politicalparties and candidates, including the Trump Campaign, no meaningfulaccess or actual opportunity to review and assess the validity of mail-inballots during the pre-canvassing meetings. While in the audit or recount,they witnessed Trump votes being put into Biden piles.68.Non-parties Amanda Coleman and Maria Diedrich are two individualswho volunteered to serve as designated monitors for the Donald J. TrumpPresidential Campaign, Inc. (the "Trump Campaign") on behalf of theGeorgia Republican Party (the "Republican Party") at the Hand Recount.(Attached hereto and incorporated herein as Exhibits 2 and 3), respectively,are true and correct copies of (1) the Affidavit of Amanda Coleman in Supportof Plaintiffs' Motion for Temporary Restraining Order (the "ColemanAffidavit"), and (2) the Affidavit of Maria Diedrich in Support of Plaintiffs'28
Motion for Temporary Restraining Order (the "Diedrich Affidavit"). (SeeExh. 11, Coleman Aff.,2; Exh. 12, Diedrich Aff., 2.)69.The Affidavits set forth various conduct amounting to federal crimes,clear improprieties, insufficiencies, and improper handling of ballots byCounty Officials and their employees that Ms. Coleman and Ms. Diedrichpersonally observed while monitoring the Hand Recount. (See Exh. 11,Coleman Aff., 3-10; Exh. 12, Diedrich Aff., 4-14.)70.As a result of her observations of the Hand Recount as a RepublicanParty monitor, Ms. Diedrich declared, "There had been no meaningful way toreview or audit any activity" at the Hand Recount. (See Exh. 12, DiedrichAff.,14.)71.As a result of their observations of the Hand Recount as RepublicanParty monitors, Ms. Coleman likewise declared, "There was no way to tell ifany counting was accurate or if the activity was proper." (See Exh. 12,Coleman Aff.,10).72.On Election Day, when the Republican poll watchers were, for a limitedtime, present and allowed to observe in various polling locations, they29
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 and 26: to be counted. See the Associated P
Page 27: C. UNLAWFUL AUDIT PROCEDURES64.Acco
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
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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