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

REQUEST FOR RELIEF
208.
Accordingly, Plaintiffs seek an emergency order instructing
Defendants to de-certify the results of the General Election for the Office of
President.
209.
In the alternative, Plaintiffs seek an emergency order prohibiting
Defendants from including in any certified results from the General Election
the tabulation of absentee and mailing ballots which do not comply with the
Election Code, including, without limitation, the tabulation of absentee and
mail-in ballots Trump Campaign’s watchers were prevented from observing
or based on the tabulation of invalidly cast absentee and mail-in ballots
which (i) lack a secrecy envelope, or contain on that envelope any text, mark,
or symbol which reveals the elector’s identity, political affiliation, or
candidate preference, (ii) do not include on the outside envelope a completed
declaration that is dated and signed by the elector, or (iii) are delivered inperson
by third parties for non-disabled voters.
210.
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
99