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

163.
Defendants further violated Georgia voters’ rights to equal protection
insofar as Defendants allowed the Georgia counties to process and count
ballots in a manner that allowed ineligible ballots to be counted, and through
the use of Dominion Democracy Suite, allowed eligible ballots for Trump and
McCormick to be switched to Biden or lost altogether. Defendants thus failed
to conduct the general election in a uniform manner as required by the Equal
Protection Clause of the Fourteenth Amendment and the Georgia Election
Code.
164.
Plaintiffs seek declaratory and injunctive relief holding that the
election, under these circumstances, was improperly certified and that the
Governor be enjoined from transmitting Georgia’s certified Presidential
election results to the Electoral College. Georgia law forbids certifying a tally
that includes any ballots that were not legally cast, or that were switched
from Trump to Biden, through the unlawful use of Dominion Democracy
Suite software and devices.
165.
Alternatively, Plaintiffs seek declaratory and injunctive relief holding
that the election, under these circumstances, was improperly certified and
that the Governor be required to recertify the results declaring that Donald
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