Nature of the Action:

1. As a civil action, the plaintiff’s burden of proof is a “preponderance of the evidence” to show, as the Georgia Supreme Court has made clear that... [Plaintiff] only had to show that there were enough irregular ballots to place in doubt the result.”
1 - Footnote: "The same pattern of election fraud and voter fraud writ large occurred in all the swing
states... Indeed, we believe that in Arizona at least 35,000 votes were illegally added to Mr. Biden’s vote count."
Nature of the Action 2:

"The scheme and artifice to defraud was for the purpose of illegally and fraudulently manipulating the vote count to make certain the election of Joe Biden as President of the United States. "
Nature of the Action

3. The fraud was executed by many means [2] but the most fundamentally troubling, insidious, and egregious is the systemic adaptation of old-fashioned “ballot-stuffing.”
Ft [2] - "50 USC § 20701 requires Retention and preservation of records and papers by officers of
elections; deposit with custodian; penalty for violation, but as will be shown wide pattern of
misconduct with ballots show preservation of election records have not been kept...
Ft. [2b] - "and Dominion logs are only voluntary, with no system wide preservation system."

🚨🚨🚨🚨🚨🚨🚨🚨🚨🚨🚨
Nature of the Action

3. (cont.) It has now been amplified and rendered virtually invisible by computer software created and run by domestic and foreign actors for that very purpose.
Nature of the Action

3. (cont.) Mathematical and statistical anomalies rising to the level of impossibilities, as shown by affidavits of multiple witnesses, documentation, and expert testimony evince this scheme across the state of Georgia.
Nature of the Action

3. (cont.) "Especially egregious conduct arose in Forsyth, Paulding, Cherokee, Hall, and Barrow County. This scheme and artifice to defraud affected tens of thousands of votes in Georgia alone and “rigged” the election in Georgia for Joe Biden."
4. "The massive fraud begins with the election software and hardware from Dominion Voting Systems Corporation (“Dominion”) only recently purchased and rushed into use by Defendants Governor Brian Kemp, Secretary of State Brad Raffensperger, and the Georgia Board of Elections."
4. (cont) "Sequoia voting machines were used in 16 states and the District of Colombia in 2006. Smartmatic, which has revenue of about $100 million, focuses on
Venezuela and other markets outside the U.S." [3] https://archive.vn/fjihN 
"After selling Sequoia, Smartmatic's chief executive, Anthony Mugica. Mr. Mugica said, he hoped Smartmatic would work with Sequoia on projects in the U.S., though Smartmatic wouldn't take an equity stake.” Ibid
5. "Smartmatic and Dominion were founded by foreign oligarchs and dictators to ensure computerized ballot-stuffing and vote manipulation to whatever level was needed to make certain Venezuelan dictator Hugo Chavez
never lost another election."
5 (cont.) "(See Redacted whistleblower affiant, attached as
Exh. 2) Notably, Chavez “won” every election thereafter."
6. "As set forth in the accompanying whistleblower affidavit, the Smartmatic software was designed to manipulate Venezuelan elections in favor of dictator Hugo Chavez:"
7. "A core requirement of the Smartmatic software design was the software’s ability to hide its manipulation of votes from any audit. As the whistleblower explains:
" ' Chavez was most insistent that Smartmatic design the system in a way that the system could change the vote of each voter without being detected... Smartmatic agreed to
create such a system and produced the software and hardware that accomplished that result for [Chavez].' "
8. "The design and features of the Dominion software do not permit a simple audit to reveal its misallocation, redistribution, or deletion of votes...
8 (cont.) "First, the system's central accumulator does not include a protected real-time audit log that maintains the date and time stamps of all significant election
events...
8 (cont.) "Key components of the system utilize unprotected logs. Essentially this allows an unauthorized user the opportunity to arbitrarily add, modify,
or remove log entries, causing the machine to log election events that do not reflect actual voting tabulations...
—or more specifically, do not reflect the actual votes of or the will of the people. (See Hursti August 2019 Declaration, attached hereto as Exh. 4, at pars. 45-48; and attached hereto, as Exh. 4B, October 2019 Declaration in Document 959-4, at p. 18, par. 28)."
9. "Indeed, under the professional standards within the industry in auditing and forensic analysis, when a log is unprotected, and can be altered, it can no longer serve the purpose of an audit log.
9 (cont.) There is incontrovertible physical evidence that the standards of physical security of the voting machines and the software were breached, and machines were connected to the internet in violation of professional standards and state and federal laws."
10. "Moreover, lies and conduct of Fulton County election workers about a delay in voting at State Farm Arena and the reasons for it evince the fraud."
11. "Specifically, video from the State Farm Arena in Fulton County shows that on November 3rd after the polls closed, election workers falsely claimed a water leak required the facility to close."
11 (cont) "All poll workers and challengers
were evacuated for several hours at about 10:00 PM. However, several election workers remained unsupervised and unchallenged working at the computers for the voting tabulation machines until after 1:00 AM."
12. "Defendants Kemp and Raffensperger rushed through the purchase of Dominion voting machines and software in 2019 for the 2020 Presidential
Election. [4]"

https://www.ajc.com/blog/politics/georgia-governor-inks-law-replace-voting-machines/xNXs0ByQAOvtXhd27kJdqO/

https://archive.vn/wip/0EvbT 
12 (cont) "A certificate from the Secretary of State was awarded to Dominion but is undated. (See attached hereto Exh. 5, copy Certification for Dominion Voting Systems from Secretary of State)."
12 (cont) "Similarly a test report is signed by Michael Walker as Project Manager but is also undated. (See Exh. 6, Test Report for Dominion Voting Systems, Democracy Suite 5-4-A)"
13. "Defendants Kemp and Raffensperger disregarded all the concerns that caused Dominion software to be rejected by the Texas Board of Elections in 2018, namely that it was vulnerable to undetected and non-auditable manipulation."
13 (cont) "An industry expert, Dr. Andrew Appel, Princeton Professor of Computer Science and Election Security Expert has recently observed, with reference to Dominion Voting machines:
"I figured out how to make a slightly different computer program that just before the polls were closed, it switches some votes around from one candidate to another. I wrote that computer program into a memory chip and now to hack a voting machine you just need
7 mins alone w/ it
with it and a screwdriver." (Attached hereto Exh. 7, Study,
Ballot-Marking Devices (BMDs) Cannot Assure the Will of the Voters by Andrew W. Appel Princeton University, Richard A. DeMillo, Georgia Tech Philip B. Stark, for the Univ. of California, Berkeley, December 27, 2019). [5]
Ftn [5] - "Full unredacted copies of all exhibits have been filed under seal with the Court and Plaintiffs
have simultaneously moved for a protective order."
14 "...In the accompanying redacted
declaration of a former electronic intelligence analyst under 305th Military Intelligence with experience gathering SAM missile system electronic
intelligence, Dominion software was accessed by agents acting on behalf of China and Iran..."
"...in order to monitor and manipulate elections, including the most recent US general election in 2020. This Declaration further includes a copy of the patent records for Dominion Systems in which Eric Coomer is listed as the first of the inventors of Dominion Voting Systems."
14. (cont) (See Attached hereto as Exh. 8, copy of redacted witness affidavit, 17 pages, November 23, 2020)
15. "Expert Navid Keshavarez-Nia explains that US intelligence services had developed tools to infiltrate foreign voting systems including Dominion. He states that Dominion’s software is vulnerable to data manipulation by unauthorized means..."
15 (cont) and permitted election data to be altered in all
battleground states. He concludes that hundreds of thousands of votes that were cast for President Trump in the 2020 general election were transferred
to former Vice-President Biden. (Exh. 26)"
16. "Incontrovertible evidence Board of Elections records
demonstrates that at least 96.6k absentee ballots were requested and counted but were never recorded as being returned to county election boards by the voter. Thus, at a minimum, 96.6k votes must be disregarded."
16 (cont) (See Attached hereto, Exh. 9, R. Ramsland Aff.).
17. "The Dominion system used in Georgia erodes and undermines the reconciliation of the number of voters and the number of ballots cast, such that these figures are permitted to be unreconciled, opening the door to ballot
stuffing and fraud." @va_shiva
17 (cont) "The collapse of reconciliation was seen in Georgia’s primary and runoff elections this year, and in the November election, where it was discovered during the hand audit that 3,300 votes were found on memory sticks that were not uploaded on election night...
17 (cont) "...plus in Floyd county, another 2,600 absentee ballots had not been scanned. These “found votes”
reduced Biden’s lead over Donald Trump. [6]"
18. "Georgia’s election officials and poll workers exacerbated and helped, whether knowingly or unknowingly, the Dominion system carry out massive
voter manipulation by refusing to observe statutory safeguards for absentee ballots..."
18 (cont) "Election officials failed to verify signatures and check security envelopes. They barred challengers from observing the count, which also facilitated the fraud. "
19. "Expert analysis of the actual vote set forth below demonstrates that at least 96,600 votes were illegally counted during the Georgia 2020 general election. All of the evidence and allegation herein is more than sufficient to
place the result of the election in doubt."
19 (cont) "More evidence arrives by the day
and discovery should be ordered immediately."
20. "Georgia law, (OCGA 21-5-552) provides for a contest of an election where: (1) Misconduct, fraud, or irregularity by any primary or election official or officials sufficient to change or place in doubt the result; . . . "
20 (cont) (3) When illegal votes have been received or legal votes rejected at the polls sufficient to change or place in doubt the result; (4) For any error in counting the votes or declaring the result of the primary or election, if such error would change the result;"
20 (cont) "; or (5) For any other cause which shows that another was the person legally nominated, elected, or eligible to compete in a run-off primary or election."
21. "As further set forth below, all of the above grounds have been satisfied and compel this Court to set aside the 2020 General Election results which fraudulently concluded that Mr. Biden defeated President Trump by 12,670 votes."
22. "..Independently, there are sufficient Constitutional grounds to set aside the election results due to the Defendants’ failure to observe statutory requirements for the processing and counting of absentee
ballots which led to the tabulation of > 50k llegal ballots."
THE PARTIES

23. Plaintiff Coreco Ja'Qan ("CJ") Pearson
24. " " Vikki Townsend Consiglio
25. " " Gloria Kay Godwin
26. " " James Kenneth Carroll
27. " " Carolyn Hall Fisher
28. " " Cathleen Alston Latham
29. " " Jason M. Shepherd
30. " " Brian Jay Van Gundy
31. "Defendant Governor Brian Kemp (Governor of Georgia) is named herein in his official capacity as Governor of the State of Georgia. On or about June 9, 2019, Governor Kemp bought the new Dominion Voting
Systems for Georgia, budgeting 150 million dollars for the machines..."
31 (cont) Critics are quoted, “Led by Abrams, Democrats fought the legislation and pointed to cybersecurity experts who warned it would leave Georgia's elections
susceptible to hacking and tampering.”
“Just this week, the Fair Fight voting rights group started by [Stacy] Abrams launched a television ad critical of the bill. In a statement Thursday, the group called it “corruption at its worst” and a waste of money on “hackable voting machines.” https://archive.vn/wip/ZXKDT 
DEFENDANTS (cont)
32. Defendant Brad Raffensperger ("Secretary Raffensperger")
33. Defendants Rebecca N. Sullivan, David J. Worley, Matthew Mashburn, and Anh Le (hereinafter the "State Election Board")
I. DEFENDANTS UNAUTHORIZED ACTIONS VIOLATED THE
GEORGIA ELECTION CODE AND CAUSED THE PROCESSING OF DEFECTIVE ABSENTEE BALLOTS.
B. UNLAWFUL EARLY PROCESSING OF ABSENTEE BALLOTS

"Rule 183-1-14-0.9-.15 is in direct and irreconcilable conflict with O.C.G.A. § 21-2-386(a)(2), which prohibits the opening of absentee ballots until election day"

https://apnews.com/article/u-s-news-ap-top-news-election-2020-technology-politics-52e87011f4d04e41bfffccd64fc878e7

https://archive.vn/dbRfs 
C. UNLAWFUL AUDIT PROCEDURES

"“at no time did I witness any Recounter or individual participate in the recount verifying signatures [on mail-in ballots].”

"In some counties, there was no actual "hand" recounting of the ballots during the Hand Recount"

https://sos.ga.gov/index.php/elections/monitors_closely_observing_audittriggered_full_hand_recount_transparency_is_built_into_process
C. UNLAWFUL AUDIT PROCEDURES (cont)

"A large number of ballots were identical and likely fraudulent. An Affiant explains that she observed a batch of utterly pristine ballots:"
II. EVIDENCE OF FRAUD

A PATTERN SHOWING THE ABSENCE OF MISTAKE
B. THE VOTING MACHINES, SECRECY

SOFTWARE USED BY VOTING MACHINES THROUGHOUT GEORGIA IS CRUCIAL
92. "The commonality and statewide nature of these legal violations renders certification of the legal vote untenable and warrants immediate impoundment of voting machines and software used throughout Georgia for
expert inspection and retrieval of the software."
93. Shoutout to @CodeMonkeyZ
94. "Affiant further explains that the central operator can remove or discard batches of votes."

96. "It is possible for an admin. of the "ImageCast Central" workstation to view and delete any individual ballot scans from the "NotCastImages" folder"
101. "The same Dominion Democracy Suite was denied
certification in Texas by the Secretary of State on January 24, 2020 specifically because of a lack of evidence of efficiency and accuracy and to be safe from fraud or unauthorized manipulation." [17]
c. Dominion / Smartmatic Systems have Massive End User Vulnerabilities
110. Specific vulnerabilities of the systems in question that have been documented or reported include:
a. Barcodes can override the voters’ vote:
c. "We … discovered that at least some jurisdictions were not aware that their systems were online"
110j. "Warren, Klobuchar, Wyden, and House Member Mark Pocan wrote about their ‘particularized concerns that secretive & “trouble -plagued companies”’ “have long skimped on security in favor of convenience”: Election Systems & Software,
Dominion Voting Systems, & Hart InterCivic
111. "Dominion neglectfully allowed foreign adversaries to access data
and intentionally provided access to their infrastructure in order to monitor
and manipulate elections, including the most recent one in 2020. (See Exh. 7)"
112. Hursti Declaration - "An expert witness in pending litigation in the US District Court, Northern District Court of Georgia, Atlanta Div., 17-cv-02989 specifically testified to the acute security vulnerabilities, among other facts,
by declaration filed on October 4, 2020...
ADDITIONAL SPECIFIC FRAUD

116-121
MULTIPLE EXPERT REPORTS AND STATISTICAL
ANALYSES PROVE HUNDREDS OF THOUSANDS OF VOTES
WERE LOST OR SHIFTED THAT COST PRESIDENT TRUMP
AND THE REPUBLICAN CANDIDATES OF
CONGRESSIONAL DISTRICTS 6 AND 7 THEIR RACES.

122-125
MULTIPLE EXPERT REPORTS AND STATISTICAL
ANALYSES PROVE HUNDREDS OF THOUSANDS OF VOTES
WERE LOST OR SHIFTED THAT COST PRESIDENT TRUMP
AND THE REPUBLICAN CANDIDATES OF
CONGRESSIONAL DISTRICTS 6 AND 7 THEIR RACES. (continued)

Shoutout to @MattBraynard

126-131
COUNT I - DEFENDANTS VIOLATED THE ELECTIONS CLAUSE AND 42 U.S.C. § 1983

135. "Defendants’ power is limited to 'tak[ing] care that
the laws be faithfully executed.' "
136. "Decision to create a “cure procedure” violates the Electors and Elections Clauses of the Constitution."
138. Many Affiants testified to many legal infractions in the voting process...
139. Plaintiff’s expert also finds that voters received tens of thousands of ballots that they never requested...
141. Further, as shown by data collected by Matt Braynard, there exists clear evidence of 20,311 absentee or early voters in Georgia that voted while registered as having moved out of state.

CC @MattBraynard
THE SECRETARY OF STATE AND GEORGIA COUNTIES VIOLATED THE FOURTEENTH AMENDMENT

U.S. CONST. AMEND. XIV, 42

U.S.C. § 1983
DENIAL OF EQUAL PROTECTION

INVALID ENACTMENT OF REGULATIONS AFFECTING
OBSERVATION AND MONITORING OF THE ELECTION
158. Defendants refused to credential all of the Trump Republican’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...
167. Plaintiffs seek a permanent injunction
requiring the County Election Boards to invalidate ballots cast by: 1) voters whose signatures on their registrations have not been matched with ballot, envelope and voter registration check; 2) all “dead votes”...
COUNT III
FOURTEENTH AMENDMENT EQUAL PROTECTION CLAUSE U.S. CONST. AMEND. XIV, 42 U.S.C. § 1983

DENIAL OF DUE PROCESS

DISPARATE TREATMENT OF ABSENTEE/MAIL-IN VOTERS AMONG DIFFERENT COUNTIES

168-173
COUNT IV
FOURTEENTH AMENDMENT, U.S. CONST. ART. I § 4, CL. 1; ART. II, § 1, CL. 2; AMEND. XIV, 42 U.S.C. § 1983

DENIAL OF DUE PROCESS ON THE RIGHT TO VOTE
COUNT V
THERE WAS WIDE-SPREAD BALLOT FRAUD.
OCGA 21-2-522
COUNT V
THERE WAS WIDE-SPREAD BALLOT FRAUD.
OCGA 21-2-522 (continued)
COUNT V
THERE WAS WIDE-SPREAD BALLOT FRAUD.
OCGA 21-2-522 (continued)
COUNT V
THERE WAS WIDE-SPREAD BALLOT FRAUD.
OCGA 21-2-522 (continued)
REQHEST 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.
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