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

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hidden during the receipt, review, opening, and tabulation of those votes indirect contravention of Georgia’s Election Code and federal law.115.The House of Representatives passed H.R. 2722 in an attempt toaddress these very risks identified by Hursti, on June 27, 2019:This bill addresses election security through grant programs andrequirements for voting systems and paper ballots.The bill establishes requirements for voting systems, including thatsystems (1) use individual, durable, voter-verified paper ballots; (2)make a voter's marked ballot available for inspection and verificationby the voter before the vote is cast; (3) ensure that individuals withdisabilities are given an equivalent opportunity to vote, includingwith privacy and independence, in a manner that produces a voterverifiedpaper ballot; (4) be manufactured in the United States; and(5) meet specified cybersecurity requirements, including theprohibition of the connection of a voting system to the internet.statement:ADDITIONAL SPECIFIC FRAUD116.On November 4, 2020, the Georgia GOP Chairman issued the following“Let me repeat. Fulton County elections officials told the media andour observers that they were shutting down the tabulation center atState Farm Arena at 10:30 p.m. on election night to continue countingballots in secret until 1:00 a.m. 3056
117.It was widely reported that "As of 7 p.m. on Wednesday Fulton CountyElections officials said 30,000 absentee ballots were not processed due to apipe burst.” 31 Officials reassured voters that none of the ballots weredamaged and the water was quickly cleaned up. But the emergency delayedofficials from processing ballots between 5:30 a.m. and 9:30 a.m. Officials saythey continued to count beginning at 8:30 a.m. Wednesday. The statementfrom Fulton County continues:"Tonight, Fulton County will report results for approximately 86,000absentee ballots, as well as Election Day and Early Voting results.These represent the vast majority of ballots cast within FultonCounty."As planned, Fulton County will continue to tabulate the remainderof absentee ballots over the next two days. Absentee ballot processingrequires that each ballot is opened, signatures verified, and ballotsscanned. This is a labor-intensive process that takes longer totabulate than other forms of voting. Fulton County did not anticipatehaving all absentee ballots processed on Election Day." Officials saidthey will work to ensure every vote is counted and all laws andregulations are followed. 3231“4,000 remaining absentee ballots being counted in Fulton County”, Fox 5 Atlanta,November 3, 2020, https://www.fox5atlanta.com/news/pipe-burst-at-state-farm-arenadelays-absentee-ballot-processing324,000 remaining absentee ballots being counted in Fulton County, Fox 5 Atlanta,November 3, 2020, https://www.fox5atlanta.com/news/pipe-burst-at-state-farm-arenadelays-absentee-ballot-processing57
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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 and 52: inventory provided by Smartmatic is
Page 53 and 54: election offices, many of whom do n
Page 55: Dr. Eric Coomer, a Vice President o
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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