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

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disenfranchisement of an enormous number of Georgia voters. Plaintiffsexperts can show that, consistent with the above specific misrepresentations,analysis of voting data reveals the following:(a)Regarding uncounted mail ballots, based on evidencegathered by Matt Braynard in the form of recorded calls anddeclarations of voters, and analyzed by Plaintiff’s expert, Williams M.Briggs, PhD, shows, based on a statistically significant sample, thatthe total number of mail ballots that voters mailed in, but werenever counted, have a 95% likelihood of falling between 31,559and 38,886 total lost votes. This range exceeds the margin of loss ofPresident Trump of 12,670 votes by at least 18,889 lost votes and by asmany as 26,196 lost votes. (See Exh. 1, Dr. Briggs’ Report, withattachments).(b)Plaintiff’s expert also finds that voters received tens ofthousands of ballots that they never requested. (See Exh. 1).Specifically, Dr. Briggs found that in the state of Georgia, based on astatistically significant sample, the expected amount of persons thatreceived an absentee ballot that they did not request ranges from16,938 to 22,771. This range exceeds the margin of loss of60
President Trump by 12,670 votes by at least 4,268 unlawfulrequests and by as many as 10,101 unlawful requests. Id.(c)This widespread pattern, as reflected within the populationof unreturned ballots analyzed by Dr. Briggs, reveals the unavoidablereality that, in addition to the calculations herein, third parties votedan untold number of unlawfully acquired absentee or mail-in ballots,which would not be in the database of unreturned ballots analyzedhere. See O.G.C.A. 21-2-522. These unlawfully voted ballotsprohibited properly registered persons from voting and reveala pattern of widespread fraud down ballot as well.(d)Further, as calculated by Matt Braynard, there existsclear evidence of 20,311 absentee or early voters in Georgia thatvoted while registered as having moved out of state. (See Id.,attachment to report). Specifically, these persons were showing on theNational Change of Address Database (NCOA) as having moved, or ashaving filed subsequent voter registration in another state also asevidence that they moved and even potentially voted in another state.The 20,311 votes by persons documented as having moved exceeds themargin by which Donald Trump lost the election by 7,641 votes.61
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IN THE UNITED STATES DISTRICCT COUR
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2.The scheme and artifice to defrau
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6.As set forth in the accompanying
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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 and 56: Dr. Eric Coomer, a Vice President o
Page 57 and 58: 117.It was widely reported that "As
Page 59: Colorado resident Joe Oltmann discl
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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