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

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Voting Systems but is undated. (See attached hereto Exh. 5, copyCertification for Dominion Voting Systems from Secretary of State).Similarly a test report is signed by Michael Walker as Project Manager but isalso undated. (See Exh. 6, Test Report for Dominion Voting Systems,Democracy Suite 5-4-A)13.Defendants Kemp and Raffensperger disregarded all the concerns thatcaused Dominion software to be rejected by the Texas Board of Elections in2018, namely that it was vulnerable to undetected and non-auditablemanipulation. An industry expert, Dr. Andrew Appel, Princeton Professor ofComputer Science and Election Security Expert has recently observed, withreference to Dominion Voting machines: "I figured out how to make a slightlydifferent computer program that just before the polls were closed, it switchessome votes around from one candidate to another. I wrote that computerprogram into a memory chip and now to hack a voting machine you just need7 minutes alone with it and a screwdriver." (Attached hereto Exh. 7, Study,Ballot-Marking Devices (BMDs) Cannot Assure the Will of the Voters byAndrew W. Appel Princeton University, Richard A. DeMillo, Georgia TechPhilip B. Stark, for the Univ. of California, Berkeley, December 27, 2019). 55Full unredacted copies of all exhibits have been filed under seal with the Court and Plaintiffshave simultaneously moved for a protective order.8
14.As explained and demonstrated in the accompanying redacteddeclaration of a former electronic intelligence analyst under 305th MilitaryIntelligence with experience gathering SAM missile system electronicintelligence, the Dominion software was accessed by agents acting on behalfof China and Iran in order to monitor and manipulate elections, including themost recent US general election in 2020. This Declaration further includes acopy of the patent records for Dominion Systems in which Eric Coomer islisted as the first of the inventors of Dominion Voting Systems. (SeeAttached hereto as Exh. 8, copy of redacted witness affidavit, 17 pages,November 23, 2020).15.Expert Navid Keshavarez-Nia explains that US intelligence serviceshad developed tools to infiltrate foreign voting systems including Dominion.He states that Dominion’s software is vulnerable to data manipulation byunauthorized means and permitted election data to be altered in allbattleground states. He concludes that hundreds of thousands of votes thatwere cast for President Trump in the 2020 general election were transferredto former Vice-President Biden. (Exh. 26).9
Page 1 and 2: IN THE UNITED STATES DISTRICCT COUR
Page 3 and 4: 2.The scheme and artifice to defrau
Page 5 and 6: 6.As set forth in the accompanying
Page 7: the internet in violation of profes
Page 11 and 12: 18.Georgia’s election officials a
Page 13 and 14: 24.Plaintiff Vikki Townsend Consigl
Page 15 and 16: 32.Defendant Brad Raffensperger ("S
Page 17 and 18: 36.The jurisdiction of the Court to
Page 19 and 20: the method which the state has pres
Page 21 and 22: voter's oath. Each elector's name s
Page 23 and 24: 53.The Settlement provides that the
Page 25 and 26: to be counted. See the Associated P
Page 27 and 28: C. UNLAWFUL AUDIT PROCEDURES64.Acco
Page 29 and 30: Motion for Temporary Restraining Or
Page 31 and 32: simply conducted another machine co
Page 33 and 34: 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 and 86:
fraudulent votes “debase[]” and
Page 87 and 88:
183.Plaintiffs contest the results
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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