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

normal distribution of voting gains, revealing a list of the most anomalous
counties down to the least. These various anomalies provide evidence of
voting irregularities. (See Exh.27, Declaration of Eric Quinnell, with
attachments).
124.
In sum, with the expert analysis of William M. Briggs PhD based on
recorded calls and declarations, the extent of missing AND unlawfully
requested ballots create substantial evidence that the mail ballot system has
fundamentally failed to provide a fair voting mechanism. In short, tens of
thousands of votes did not count while the pattern of fraud makes clear that
tens of thousands were improperly counted. This margin of victory in the
election for Mr. Biden was only 12,670 and cannot withstand most of these
criticisms individually and certainly not in aggregate.
125.
Cobb county, based on lost votes, unlawfully requested votes and
NCOA data on these facts alone would consume more than the entire margin
of the statewide difference in the Presidential race. These election results
must be reversed.
126.
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
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