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

201.
Defendants have a duty to guard against deprivation of the right to
vote through the dilution of validly cast ballots by ballot fraud or election
tampering. Rather than heeding these mandates and duties, Defendants
arbitrarily and capriciously denied the Trump Campaign and Republicans
meaningful access to observe and monitor the electoral process by: (a)
mandating that representatives at the pre- canvass and canvass of all
absentee and mail-ballots be either Georgia barred attorneys or qualified
registered electors of the county in which they sought to observe and monitor;
and (b) not allowing watchers and representatives to visibly see and review
all envelopes containing official absentee and mail-in ballots either at the
time or before they were opened and/or when such ballots were counted and
recorded. Instead, Defendants refused to credential all of the Trump
Campaign’s submitted watchers and representatives and/or kept Trump
Campaign’s watchers and representatives by security and metal barricades
from the areas where the inspection, opening, and counting of absentee and
mail-in ballots were taking place. The lack of meaningful access with actual
access to see the ballots invited further fraud and cast doubt of the validity of
the proceedings.
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