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

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to a flash memory card – and that is connected to a Windows computerstating:It is possible for an administrator of the "ImageCast Central"workstation to view and delete any individual ballot scans from the"NotCastImages" folder by simply using the standard Windows deleteand recycle bin functions provided by the Windows 10 Pro operatingsystem. … The upload process is just a simple copying of a "Results"folder containing vote tallies to a flash memory card connected to the"Windows 10 Pro" machine. The copy process uses the standard dragn-dropor copy/paste mechanisms within the ubiquitous "WindowsFile Explorer". While a simple procedure, this process may be errorprone and is very vulnerable to malicious administrators.Id. at par. 11-13 (emphasis supplied).97.It was announced on “Monday, [July 29, 2019], [that] Governor Kempawarded a contract for 30,000 new voting machines to Dominion VotingSystems, scrapping the state’s 17-year-old electronic voting equipment andreplacing it with touchscreens that print out paper ballots.” 12 Critics arequoted: “Led by Abrams, Democrats fought the legislation and pointed tocybersecurity experts who warned it would leave Georgia's electionssusceptible to hacking and tampering.” And “Just this week, the Fair Fightvoting rights group started by [Stacy] Abrams launched a television ad12Georgia Buys New Voting Machines for 2020 Presidential Election, by Mark Niesse, theAtlanta Journal-Constitution, July 30, 2019, https://www.ajc.com/news/state--regional-govt--politics/georgia-awards-contract-for-new-election-system-dominionvoting/tHh3V8KZnZivJoVzZRLO4O/40
critical of the bill. In a statement Thursday, the group called it “corruption atits worst” and a waste of money on “hackable voting machines.” 13It was further reported in 2019 that the new Dominion Voting98.Machines in Georgia “[w]ith Georgia’s current voting system, there’s no wayto guarantee that electronic ballots accurately reflect the choices ofvoters because there’s no paper backup to verify results, with it beingreported that:(a) Recounts are meaningless on the direct-recording electronicvoting machines because they simply reproduce the same numbersthey originally generated.(b) But paper ballots alone won’t protect the sanctity of electionson the new touchscreens, called ballot-marking devices.(c) The new election system depends on voters to verify the printedtext of their choices on their ballots, a step that many voters mightnot take. The State Election Board hasn't yet created regulations forhow recounts and audits will be conducted. And paper ballots embedselections in bar codes that are only readable by scanning machines,leaving Georgians uncertain whether the bar codes match theirvotes. 1413Georgia Governor Inks Law to Replace Voting Machines, The Atlanta Journal-Constitution,AJC News Now, by Greg Bluestein and Mark Niesse, June 14, 2019; Credit: Copyright 2019 TheAssociated Press, June 201941
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 and 36: tried to report it to a voter fraud
Page 37 and 38: into Biden’s stack, and counted a
Page 39: 95.Affiant further testifies that t
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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