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

Trump has won the election and transmitting Georgia’s certified Presidential
election result in favor of President Trump.
166.
Plaintiffs have no adequate remedy at law and will suffer serious and
irreparable harm unless the declaratory and injunctive relief requested
herein is granted. Indeed, the setting aside of an election in which the people
have chosen their representative is a drastic remedy that should not be
undertaken lightly, but instead should be reserved for cases in which a
person challenging an election has clearly established a violation of election
procedures and has demonstrated that the violation has placed the result of
the election in doubt. Georgia law allows elections to be contested through
litigation, both as a check on the integrity of the election process and as a
means of ensuring the fundamental right of citizens to vote and to have their
votes counted accurately. O.C.G.A. § 21-2-520 et seq.
167.
In addition to the alternative requests for relief in the preceding
paragraphs, hereby restated, Plaintiffs seek a permanent injunction
requiring the County Election Boards to invalidate ballots cast by: 1) voters
whose signatures on their registrations have not been matched with ballot,
envelope and voter registration check; 2) all “dead votes”; and 4) all 900
military ballots in Fulton county that supposedly were 100% for Joe Biden.
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