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

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89.An Affiant testified, that while at the Audit, ‘While in Henry County,I personally witnessed ballots cast for Donald Trump being placed inthe pile for Joseph Biden. I witnessed this happen at table “A”’. (Seeattached hereto as Exh. 22, Kevin Peterford, at par. 29).Another Affianttestified, that “I witnessed two poll workers placing already separatedpaper machine receipt ballots with barcodes in the Trump tray,placing them in to the Biden tray. I also witnessed the same two pollworkers putting the already separated paper receipt abllots in the “NoVote” and “Jorgensen” tray, and removing them and putting theminside the Biden tray, They then took out all of the ballots out of theBiden tray and stacked them on the table, writing on the count ballotsheet. (See Exh. 17, Johnson, pars. 4-5).90.Another Affiant, a Democrat, testified in his sworn affidavit,before he was forced to move back to where he could not see, he hadin fact seen, “I also saw absentee ballots for Trump inserted36
into Biden’s stack, and counted as Biden votes. This occurreda few times”. (See Exh. 18, Par. 12).91.A Republican National Committee monitor in Georgia’s electionrecount, Hale Soucie, told an undercover journalist there are individualscounting ballots who have made continuous errors,” writes O’Keefe. ProjectVeritas, Watch: Latest Project Veritas Video reveals “Multiple Ballots Meantfor Trump Went to Biden in Georgia. 11B. THE VOTING MACHINES, SECRECYSOFTWARE USED BY VOTING MACHINES THROUGHOUT GEORGIAIS CRUCIAL92.These violations of federal and state laws impacted the election ofNovember 3, 2020 and set the predicate for the evidence of deliberatefraudulent conduct, manipulation, and lack of mistake that follows. Thecommonality and statewide nature of these legal violations renderscertification of the legal vote untenable and warrants immediate11https://hannity.com/media-room/watch-latest-project-veritas-video-reveals-multipleballots-meant-for-trump-went-to-biden-in-georgia/37
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 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: tried to report it to a voter fraud
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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