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

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188.This widespread pattern, as reflected within the population ofunreturned ballots analyzed by Dr. Briggs, reveals the unavoidable realitythat, in addition to the calculations herein, third parties voted an untoldnumber of unlawfully acquired absentee or mail-in ballots, which would notbe in the database of unreturned ballots analyzed here. See O.G.C.A. 21-2-522. These unlawfully voted ballots prohibited properly registered personsfrom voting and reveal a pattern of widespread fraud.189.Further, there exists clear evidence of 20,311 absentee or early votersin Georgia that voted while registered as having moved out of state.Specifically, these persons were showing on the National Change of AddressDatabase (NCOA) as having moved, or as having filed subsequent voterregistration in another state also as evidence that they moved and evenpotentially voted in another state. The 20,311 votes by persons documentedas having moved exceeds the margin by which Donald Trump lost theelection by 7,641 votes.190.Plaintiffs’’ expert Russell Ramsland concludes that at least 96,600mail-in ballots were fraudulently cast. He further concludes that up to90
136,098 ballots were illegally counted as a result of improper manipulation ofthe Dominion software. (Ramsland Aff).191.The very existence of absentee mail in ballots created a heightenedopportunity for fraud. The population of unreturned ballots analyzed byWilliam Briggs, PhD, reveals the probability that a far greater number ofmail ballots were requested by 3rd parties or sent erroneously to persons andvoted fraudulently, undetected by a failed system of signature verification.The recipients may have voted in the name of another person, may have nothad the legal right to vote and voted anyway, or may have not received theballot at the proper address and then found that they were unable to vote atthe polls, except provisionally, due to a ballot outstanding in their name.192.When we consider the harm of these uncounted votes, and ballots notordered by the voters themselves, and the potential that many of theseunordered ballots may in fact have been improperly voted and also preventedproper voting at the polls, the mail ballot system has clearly failed in thestate of Georgia and did so on a large scale and widespread basis. The size ofthe voting failures, whether accidental or intentional, are multiples largerthan the margin of votes between the presidential candidates in the91
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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
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tried to report it to a voter fraud
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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: d) further a failure to demonstrate
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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