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

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d. October 6, 2006 – Congresswoman Carolyn Maloney called on Secretaryof Treasury Henry Paulson to conduct an investigation into Smartmaticbased on its foreign ownership and ties to Venezuela. (See Exh. 24)e. Congresswoman Maloney wrote that “It is undisputed that Smartmaticis foreign owned and it has acquired Sequoia … Smartmatica nowacknowledged that Antonio Mugica, a Venezuelan businessman has acontrolling interest in Smartmatica, but the company has not revealedwho all other Smartmatic owners are.” Id.f. Dominion “got into trouble” with several subsidiaries it used overalleged cases of fraud. One subsidiary is Smartmatic, a company “thathas played a significant role in the U.S. market over the last decade,”according to a report published by UK-based AccessWire 23 .g. Litigation over Smartmatic “glitches” alleges they impacted the 2010and 2013 mid-term elections in the Philippines, raising questions ofcheating and fraud. An independent review of the source codes used inthe machines found multiple problems, which concluded, “The software23Voting Technology Companies in the U.S. – Their Histories and Present Contributions, AccessWire, August 10, 2017, https://www.accesswire.com/471912/Voting-Technology-Companies-inthe-US--Their-Histories.50
inventory provided by Smartmatic is inadequate, … which brings intoquestion the software credibility…” 24h. Dominion acquired Sequoia Voting Systems as well as Premier ElectionSolutions (formerly part of Diebold, which sold Premier to ES&S in2009, until antitrust issues forced ES&S to sell Premier, which thenwas acquired by Dominion). 25 .i. Dominion entered into a 2009 contract with Smartmatic and providedSmartmatic with the PCOS machines (optical scanners) that were usedin the 2010 Philippine election—the biggest automated election run bya private company. The international community hailed theautomation of that first election in the Philippines. 26 The results’transmission reached 90% of votes four hours after polls closed andFilipinos knew for the first time who would be their new president onElection Day. In keeping with local election law requirements,Smartmatic and Dominion were required to provide the source code of24Smartmatic-TIM running out of time to fix glitches, ABS-CBN News, May 4, 2010https://news.abs-cbn.com/nation/05/04/10/smartmatic-tim-running-out-time-fix-glitches25The Business of Voting, Penn Wharton, Caufield, p. 16.26Smartmatic-TIM running out of time to fix glitches, ABS-CBN News, May 4, 2010https://news.abs-cbn.com/nation/05/04/10/smartmatic-tim-running-out-time-fix-glitches51
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 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: a. Barcodes can override the voters
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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