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

183.
Plaintiffs contest the results of Georgia’s election, with Standing
conferred under pursuant to O.G.C.A. 21-2-521.
184.
Therefore, pursuant to O.G.C.A. 21-2-522, for misconduct, fraud, or
irregularity by any primary or election official or officials sufficient to change
or place in doubt the result. The foundational principle that Georgia law
“nonetheless 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.” Martin v. Fulton County Bd. of Registration & Elections, 307 Ga.
193, 194, 835 S.E.2d 245, 248 (2019). The Georgia Supreme Court has made
clear that Plaintiffs need not show how the [] voters would have voted if their
[absentee] ballots had been regular. [] only had to show that there were
enough irregular ballots to place in doubt the result.” See OCGA § 21-2-520 et
seq., Mead v. Sheffield, 278 Ga. 268, 272, 601 S.E.2d 99, 102 (1994) the
Supreme Court invalidated an election, and ordered a new election because it
found that,
Thus, [i]t was not incumbent upon [the Plaintiff] to show how the
[481] voters would have voted if their [absentee] ballots had
been regular. He only had to show that there were enough irregular
ballots to place in doubt the result. He succeeded in that task.
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