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

we typically receive the machines, the ballot marking devices – on
the Friday before the election, with a chain of custody letter to be
signed on Sunday, indicating that we had received the machines and
the counts on the machines when received, and that the machines
have been sealed. In this case, we were asked to sign the chain
of custody letter on Sunday, even though the machines were
not delivered until 2:00 AM in the morning on Election Day.
The Milton precinct received its machines at 1:00 AM in the morning
on Election Day. This is unacceptable and voting machines should
[not] be out of custody prior to an Election Day. Id.
155.
Defendants have a duty to treat the voting citizens in each County in
the same manner as the citizens in other counties in Georgia.
156.
As set forth in Count I above, Defendants failed to comply with the
requirements of the Georgia Election Code and thereby diluted the lawful
ballots of the Plaintiffs and of other Georgia voters and electors in violation of
the United States Constitution guarantee of Equal Protection.
157.
Specifically, Defendants denied the plaintiffs equal protection of the
law and their equal rights to meaningful access to observe and monitor the
electoral process enjoyed by citizens in other Georgia Counties by:
(a) mandating that representatives at the pre-canvass and
canvass of all absentee and mail-ballots be either Georgia barred
75