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

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145.

The Court has held that to ensure equal protection, a “problem inheres

in the absence of specific standards to ensure its equal application. The

formulation of uniform rules to determine intent based on these recurring

circumstances is practicable and, we conclude, necessary.” Bush v. Gore, 531

U.S. 98, 106, 121 S. Ct. 525, 530, 148 L. Ed. 2d 388 (2000).

146.

The equal enforcement of election laws is necessary to preserve our

most basic and fundamental rights. The requirement of equal protection is

particularly stringently enforced as to laws that affect the exercise of

fundamental rights, including the right to vote.

147.

In statewide and federal elections conducted in the State of Georgia,

including without limitation the November 3, 2020, General Election, all

candidates, political parties, and voters, including without limitation

Plaintiffs, have a vested interest in being present and having meaningful

access to observe and monitor the electoral process in each County to ensure

that it is properly administered in every election district and otherwise free,

fair, and transparent.

71

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