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

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138.Many Affiants testified to many legal infractions in the voting process,including specifically switching absentee ballots or mail-in ballots for Trumpto Biden. Even a Democrat testified in his sworn affidavit that before he wasforced to move back to where he could not see, he had in fact seen, “I also sawabsentee ballots for Trump inserted into Biden’s stack, and counted as Bidenvotes. This occurred a few times”. (See Exh. 18, Par. 12).139.Plaintiff’s expert also finds that voters received tens of thousands ofballots that they never requested. (See Exh. 1, Dr. Briggs’ Report).Specifically, Dr. Briggs found that in the state of Georgia, based on astatistically significant sample, the expected amount of persons that receivedan absentee ballot that they did not request one ranges from 16,938 to22,771. This range exceeds the margin of loss of President Trump by 12,670votes by at least 4,268 unlawful requests and by as many as 10,101 unlawfulrequests.140.This widespread pattern, as reflected within the population ofunreturned ballots analyzed by Dr. Briggs, reveals the unavoidable realitythat, in addition to the calculations herein, third parties voted an untoldnumber of unlawfully acquired absentee or mail-in ballots, which would not68
be in the database of unreturned ballots analyzed here. See O.G.C.A. 21-2-522. These unlawfully voted ballots prohibited properly registered personsfrom voting and reveal a pattern of widespread fraud.141.Further, as shown by data collected by Matt Braynard, there existsclear evidence of 20,311 absentee or early voters in Georgia that voted whileregistered as having moved out of state. Specifically, these persons wereshowing on the National Change of Address Database (NCOA) as havingmoved, or as having filed subsequent voter registration in another state alsoas evidence that they moved and even potentially voted in another state. The20,311 votes by persons documented as having moved exceeds the margin bywhich Donald Trump lost the election by 7,641 votes.142.Plaintiffs have no adequate remedy at law and will suffer serious andirreparable harm unless the injunctive relief requested herein is granted.Defendants have acted and, unless enjoined, will act under color of state lawto violate the Elections Clauses of the Constitution. Accordingly, the resultsfor President and Congress in the November 3, 2020 election must be setaside. The results are infected with Constitutional violations.COUNT II69
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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
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14.As explained and demonstrated in
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18.Georgia’s election officials a
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24.Plaintiff Vikki Townsend Consigl
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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 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: 135.Defendants are not part of the
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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