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

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136,098 ballots were illegally counted as a result of improper manipulation of

the Dominion software. (Ramsland Aff).

191.

The very existence of absentee mail in ballots created a heightened

opportunity for fraud. The population of unreturned ballots analyzed by

William Briggs, PhD, reveals the probability that a far greater number of

mail ballots were requested by 3rd parties or sent erroneously to persons and

voted fraudulently, undetected by a failed system of signature verification.

The recipients may have voted in the name of another person, may have not

had the legal right to vote and voted anyway, or may have not received the

ballot at the proper address and then found that they were unable to vote at

the polls, except provisionally, due to a ballot outstanding in their name.

192.

When we consider the harm of these uncounted votes, and ballots not

ordered by the voters themselves, and the potential that many of these

unordered ballots may in fact have been improperly voted and also prevented

proper voting at the polls, the mail ballot system has clearly failed in the

state of Georgia and did so on a large scale and widespread basis. The size of

the voting failures, whether accidental or intentional, are multiples larger

than the margin of votes between the presidential candidates in the

91

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