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

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attorneys or qualified registered electors of the county in which

they sought to observe and monitor;

(b) not allowing watchers and representatives to visibly see and

review all envelopes containing official absentee and mail-in

ballots either at or before they were opened and/or when such

ballots were counted and recorded; and

(c) allowing the use of Dominion Democracy Suite software and

devices, which failed to meet the Dominion Certification Report’s

conditions for certification.

158.

Instead, Defendants refused to credential all of the Trump Republican’s

submitted watchers and representatives and/or kept Trump Campaign’s

watchers and representatives by security and metal barricades from the

areas where the inspection, opening, and counting of absentee and mail-in

ballots were taking place. Consequently, Defendants created a system

whereby it was physically impossible for the candidates and political parties

to view the ballots and verify that illegally cast ballots were not opened and

counted

159.

Many Affiants testified to switching absentee ballots or mail-in ballots

for Trump to Biden, including a Democrat. He testified in his sworn

affidavit, that before he was forced to move back to where he could not see, he

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