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

2.
The scheme and artifice to defraud was for the purpose of illegally and
fraudulently manipulating the vote count to make certain the election of Joe
Biden as President of the United States.
3.
The fraud was executed by many means, 2 but the most fundamentally
troubling, insidious, and egregious is the systemic adaptation of old-fashioned
“ballot-stuffing.” It has now been amplified and rendered virtually invisible
by computer software created and run by domestic and foreign actors for that
very purpose. Mathematical and statistical anomalies rising to the level of
impossibilities, as shown by affidavits of multiple witnesses, documentation,
and expert testimony evince this scheme across the state of Georgia.
Especially egregious conduct arose in Forsyth, Paulding, Cherokee, Hall, and
Barrow County. This scheme and artifice to defraud affected tens of
thousands of votes in Georgia alone and “rigged” the election in Georgia for
Joe Biden.
2
50 USC § 20701 requires Retention and preservation of records and papers by officers of
elections; deposit with custodian; penalty for violation, but as will be shown wide pattern of
misconduct with ballots show preservation of election records have not been kept; and
Dominion logs are only voluntary, with no system wide preservation system.
3