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

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accomplished that result for President Chavez. (See Id., see also Exh.3, Aff. Cardozo, attached hereto)).8.The design and features of the Dominion software do not permit asimple audit to reveal its misallocation, redistribution, or deletion of votes.First, the system's central accumulator does not include a protected real-timeaudit log that maintains the date and time stamps of all significant electionevents. Key components of the system utilize unprotected logs. Essentiallythis allows an unauthorized user the opportunity to arbitrarily add, modify,or remove log entries, causing the machine to log election events that do notreflect actual voting tabulations—or more specifically, do not reflect theactual votes of or the will of the people. (See Hursti August 2019 Declaration,attached hereto as Exh. 4, at pars. 45-48; and attached hereto, as Exh. 4B,October 2019 Declaration in Document 959-4, at p. 18, par. 28).Indeed, under the professional standards within the industry inauditing and forensic analysis, when a log is unprotected, and can be altered,it can no longer serve the purpose of an audit log. There is incontrovertiblephysical evidence that the standards of physical security of the votingmachines and the software were breached, and machines were connected to9.6
the internet in violation of professional standards and state and federal laws.(See Id.)10.Moreover, lies and conduct of Fulton County election workers about adelay in voting at State Farm Arena and the reasons for it evince the fraud.11.Specifically, video from the State Farm Arena in Fulton County showsthat on November 3rd after the polls closed, election workers falsely claimeda water leak required the facility to close. All poll workers and challengerswere evacuated for several hours at about 10:00 PM. However, severalelection workers remained unsupervised and unchallenged working at thecomputers for the voting tabulation machines until after 1:00 AM.12.Defendants Kemp and Raffensperger rushed through the purchase ofDominion voting machines and software in 2019 for the 2020 PresidentialElection 4 . A certificate from the Secretary of State was awarded to Dominion4Georgia Governor Inks Law to Replace Voting Machines, The Atlanta Journal-Constitution, AJC News Now, Credit: Copyright 2019 The Associated Press, June 2019.https://www.ajc.com/blog/politics/georgia-governor-inks-law-replace-votingmachines/xNXs0ByQAOvtXhd27kJdqO/7
Page 1 and 2: IN THE UNITED STATES DISTRICCT COUR
Page 3 and 4: 2.The scheme and artifice to defrau
Page 5: 6.As set forth in the accompanying
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 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
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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
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145.The Court has held that to ensu
Page 73 and 74:
Plaintiffs also bring this action u
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we typically receive the machines,
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had in fact seen, “absentee ballo
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Trump has won the election and tran
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contravene the requirements of the
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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
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officials from unlawfully eliminati
Page 97 and 98:
202.Consequently, Defendants create
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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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COMPLAINT-CJ-PEARSON-V.-KEMP-11.25.2020

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