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

202.
Consequently, Defendants created a system whereby it was physically
impossible for the candidates and political parties to view the ballots and
verify that illegally cast ballots were not opened and counted.
203.
Defendants intentionally and/or arbitrarily and capriciously denied Plaintiffs
access to and/or obstructed actual observation and monitoring of the absentee
and mail-in ballots being pre-canvassed and canvassed by Defendants, and
included the unlawfully not counting and including uncounted mail ballots,
and that they failed to follow absentee ballot requirements when thousands
of voters received ballots that they never requested. Defendants have
acted and will continue to act under color of state law to violate the right to
vote and due process as secured by the Fourteenth Amendment to the United
States Constitution.
204.
Plaintiffs have no adequate remedy at law and will suffer serious and
irreparable harm unless the injunctive relief requested herein is granted.
205.
When we consider the harm of these uncounted votes, and ballots not
ordered by the voters themselves, and the potential that many of these
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