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

disenfranchisement of an enormous number of Georgia voters. Plaintiffs
experts can show that, consistent with the above specific misrepresentations,
analysis of voting data reveals the following:
(a)
Regarding uncounted mail ballots, based on evidence
gathered by Matt Braynard in the form of recorded calls and
declarations of voters, and analyzed by Plaintiff’s expert, Williams M.
Briggs, PhD, shows, based on a statistically significant sample, that
the total number of mail ballots that voters mailed in, but were
never counted, have a 95% likelihood of falling between 31,559
and 38,886 total lost votes. This range exceeds the margin of loss of
President Trump of 12,670 votes by at least 18,889 lost votes and by as
many as 26,196 lost votes. (See Exh. 1, Dr. Briggs’ Report, with
attachments).
(b)
Plaintiff’s expert also finds that voters received tens of
thousands of ballots that they never requested. (See Exh. 1).
Specifically, Dr. Briggs found that in the state of Georgia, based on a
statistically significant sample, the expected amount of persons that
received an absentee ballot that they did not request ranges from
16,938 to 22,771. This range exceeds the margin of loss of
60