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

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(e)

Applying pro-rata the above calculations separately to Cobb

County based on the number of unreturned ballots, a range of 1,255

and 1,687 ballots ordered by 3 rd parties and a range of 2,338 and 2,897

lost mail ballots, plus 10,684 voters documented in the NCOA as

having moved, for a combined minimum of 14,276 missing and

unlawful ballots, and maximum of 15,250 missing and unlawful

ballots, which exceeds the statewide Presidential race total

margin by a range of as few as 1,606 ballots and as many as

2,580 in the County of Cobb alone impacting the Cobb County

Republican Party (“Cobb County Republicans”).

123.

As seen from the expert analysis of Eric Quinnell, mathematical

anomalies further support these findings, when in various districts within

Fulton County such as vote gains that exceed reasonable expectations

when compared to 2016, and a failure of gains to be normally distributed

but instead shifting substantially toward the tail of the distribution in

what is known as a platykurtic distribution. Dr. Quinell identifies

numerous anomalies such as votes to Biden in excess of 2016 exceed the

registrations that are in excess of 2016. Ultimately, he identifies the

counties in order of their excess performance over what would have fit in a

62

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