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

had in fact seen, “absentee ballots for Trump inserted into Biden’s stack, and
counted as Biden votes. This occurred a few times”. (See Exh. 18, Par. 12).
160.
Other Georgia county boards of elections provided watchers and
representatives of candidates and political parties, including without
limitation watchers and representatives of the Republicans and the Trump
Campaign, with appropriate access to view the absentee and mail-in ballots
being pre-canvassed and canvassed by those county election boards and
without restricting representatives by any county residency or Georgia bar
licensure requirements.
161.
Defendants intentionally and/or arbitrarily and capriciously denied
Plaintiffs access to and/or obstructed actual observation and monitoring of
the absentee and mail-in ballots being pre-canvassed and canvassed by
Defendants, depriving them of the equal protection of those state laws
enjoyed by citizens in other Counties.
162.
Defendants have acted and will continue to act under color of state law
to violate Plaintiffs’ right to be present and have actual observation and
access to the electoral process as secured by the Equal Protection Clause of
the United States Constitution.
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