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

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population 8,348, rejected nine absentee ballot applications for signaturemismatch. Fulton County rejected eight. No other metropolitan county inGeorgia rejected even a single absentee ballot application for signaturemismatch. The state of Colorado, which has run voting by mail for a numberof years, has a signature rejection rate of between .52% and .66%. 35 The Stateof Oregon had a rejection rate of 0.86% in 2016. 36 The State of Washingtonhas a rejection rate of between 1% and 2%. 37 If Georgia rejected absenteeballots at a rate of .52% instead of the actual .15%, approximately 4,600 moreabsentee ballots would have been rejected.COUNT VTHERE WAS WIDE-SPREAD BALLOT FRAUD.OCGA 21-2-522182.Plaintiffs refer to and incorporate by reference each of the priorparagraphs of this Complaint as though the same were repeated at lengthherein.35See https://duckduckgo.com/?q=colorado+signature+rejection+rate&t=osx&ia=web lastvisited November 25,202036See https://www.vox.com/21401321/oregon-vote-by-mail-2020-presidential-election, lastvisited November 25,2020.37See https://www.salon.com/2020/09/08/more-than-550000-mail-ballots-rejected-so-far-hereshow-to-make-sure-your-vote-gets-counted/last visited November 25, 2020.86
183.Plaintiffs contest the results of Georgia’s election, with Standingconferred under pursuant to O.G.C.A. 21-2-521.184.Therefore, pursuant to O.G.C.A. 21-2-522, for misconduct, fraud, orirregularity by any primary or election official or officials sufficient to changeor place in doubt the result. The foundational principle that Georgia law“nonetheless allows elections to be contested through litigation, both as acheck on the integrity of the election process and as a means of ensuring thefundamental right of citizens to vote and to have their votes countedaccurately.” Martin v. Fulton County Bd. of Registration & Elections, 307 Ga.193, 194, 835 S.E.2d 245, 248 (2019). The Georgia Supreme Court has madeclear that Plaintiffs need not show how the [] voters would have voted if their[absentee] ballots had been regular. [] only had to show that there wereenough irregular ballots to place in doubt the result.” See OCGA § 21-2-520 etseq., Mead v. Sheffield, 278 Ga. 268, 272, 601 S.E.2d 99, 102 (1994) theSupreme Court invalidated an election, and ordered a new election because itfound that,Thus, [i]t was not incumbent upon [the Plaintiff] to show how the[481] voters would have voted if their [absentee] ballots hadbeen regular. He only had to show that there were enough irregularballots to place in doubt the result. He succeeded in that task.87
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IN THE UNITED STATES DISTRICCT COUR
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2.The scheme and artifice to defrau
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6.As set forth in the accompanying
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the internet in violation of profes
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14.As explained and demonstrated in
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18.Georgia’s election officials a
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24.Plaintiff Vikki Townsend Consigl
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32.Defendant Brad Raffensperger ("S
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36.The jurisdiction of the Court to
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the method which the state has pres
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voter's oath. Each elector's name s
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53.The Settlement provides that the
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to be counted. See the Associated P
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C. UNLAWFUL AUDIT PROCEDURES64.Acco
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Motion for Temporary Restraining Or
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simply conducted another machine co
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81.Another Affiant in the mail-in b
Page 35 and 36: tried to report it to a voter fraud
Page 37 and 38: into Biden’s stack, and counted a
Page 39 and 40: 95.Affiant further testifies that t
Page 41 and 42: critical of the bill. In a statemen
Page 43 and 44: foreign interference and insider ta
Page 45 and 46: persons running the Venezuelan gove
Page 47 and 48: in an election to recall President
Page 49 and 50: a. Barcodes can override the voters
Page 51 and 52: inventory provided by Smartmatic is
Page 53 and 54: election offices, many of whom do n
Page 55 and 56: Dr. Eric Coomer, a Vice President o
Page 57 and 58: 117.It was widely reported that "As
Page 59 and 60: Colorado resident Joe Oltmann discl
Page 61 and 62: President Trump by 12,670 votes by
Page 63 and 64: normal distribution of voting gains
Page 65 and 66: short, tens of thousands of votes d
Page 67 and 68: 135.Defendants are not part of the
Page 69 and 70: be in the database of unreturned ba
Page 71 and 72: 145.The Court has held that to ensu
Page 73 and 74: Plaintiffs also bring this action u
Page 75 and 76: we typically receive the machines,
Page 77 and 78: had in fact seen, “absentee ballo
Page 79 and 80: Trump has won the election and tran
Page 81 and 82: contravene the requirements of the
Page 83 and 84: COUNT IVFOURTEENTH AMENDMENT, U.S.
Page 85: fraudulent votes “debase[]” and
Page 89 and 90: d) further a failure to demonstrate
Page 91 and 92: 136,098 ballots were illegally coun
Page 93 and 94: 195.The Fourteenth Amendment Due Pr
Page 95 and 96: officials from unlawfully eliminati
Page 97 and 98: 202.Consequently, Defendants create
Page 99 and 100: REQUEST FOR RELIEF208.Accordingly,
Page 101 and 102: 4. An immediate order to impound al
Page 103 and 104: CALDWELL, PROPST & DELOACH, LLP/s/
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COMPLAINT-CJ-PEARSON-V.-KEMP-11.25.2020

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