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

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the voting machines prior to elections so that it could be independentlyverified. 27j. In late December of 2019, three Democrat Senators, Warren,Klobuchar, Wyden, and House Member Mark Pocan wrote about their‘particularized concerns that secretive & “trouble -plaguedcompanies”’ “have long skimped on security in favor ofconvenience,” in the context of how they described the voting machinesystems that three large vendors – Election Systems & Software,Dominion Voting Systems, & Hart InterCivic – collectively providevoting machines & software that facilitate voting for over 90% of alleligible voters in the U.S.” (See attached hereto as Exh. 26, copy ofSenator Warren, Klobuchar, Wyden’s December 6, 2019 letter).k. Senator Ron Wyden (D-Oregon) said the findings [insecurity of votingsystems] are “yet another damning indictment of the profiteeringelection vendors, who care more about the bottom line than protectingour democracy.” It’s also an indictment, he said, “of the notion thatimportant cybersecurity decisions should be left entirely to county27Presumably the machiens were not altered following submission of the code. LONDON,ENGLAND / ACCESSWIRE / August 10, 2017, Voting Technology Companies in the U.S. -Their Histories and Present Contributions52
election offices, many of whom do not employ a single cybersecurityspecialist.” 28 111.An analysis of the Dominion software system by a former US MilitaryIntelligence expert concludes that the system and software have beenaccessible and were certainly compromised by rogue actors, such as Iran andChina. By using servers and employees connected with rogue actors andhostile foreign influences combined with numerous easily discoverable leakedcredentials, Dominion neglectfully allowed foreign adversaries to access dataand intentionally provided access to their infrastructure in order to monitorand manipulate elections, including the most recent one in 2020. (See Exh.7).112.An expert witness in pending litigation in the United States DistrictCourt, Northern District Court of Georgia, Atlanta Div., 17-cv-02989specifically testified to the acute security vulnerabilities, among other facts,by declaration filed on October 4, 2020, (See Exh. 4B, Document 959-428Exclusive: Critical U.S. Election Systems Have Been Left Exposed Online Despite OfficialDenials, Motherboard Tech by Vice, by Kim Zetter, August 8, 2019,https://www.vice.com/en/article/3kxzk9/exclusive-critical-us-election-systems-have-been-leftexposed-online-despite-official-denials53
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 and 50: a. Barcodes can override the voters
Page 51: inventory provided by Smartmatic is
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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