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    Georgia: CORECO JA’QAN PEARSON, et al v. BRIAN KEMP, in his official capacity as Governor of Georgia, et al To protect and defend the lawful votes of American citizens, ensure election integrity, educate the world on what it means to be a constitutional Republic, and pursue legal action to preserve the vision of our Founders and to maintain this great Republic.

    • Date
      November 25, 2020
    • City/County
      Atlanta
    • Type of Case
      Voter Integrity, Voter Fraud
    • Case Details
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    Title

    Georgia: CORECO JA’QAN PEARSON, et al v. BRIAN KEMP, in his official capacity as Governor of Georgia, et al To protect and defend the lawful votes of American citizens, ensure election integrity, educate the world on what it means to be a constitutional Republic, and pursue legal action to preserve the vision of our Founders and to maintain this great Republic.

    Date
    November 25, 2020
    State or Country
    Georgia
    County/City:
    Atlanta
    The Court the Case was filed in

    IN THE UNITED STATES DISTRICT COURT, NORTHERN DISTRICT OF GEORGIA, ATLANTA DIVISION

    Type of Case
    Voter Integrity, Voter Fraud
    Judges

    TBD

    Plaintiff

    CORECO JA’QAN PEARSON,
    VIKKI TOWNSEND CONSIGLIO,
    GLORIA KAY GODWIN, JAMES
    KENNETH CARROLL, CAROLYN HALL
    FISHER, and BRIAN JAY VAN GUNDY,

    Defendant

    BRIAN KEMP, in his official capacity as
    Governor of Georgia, BRAD
    RAFFENSPERGER, in his official
    capacity as Secretary of State and Chair
    of the Georgia State Election Board,
    DAVID J. WORLEY, in his official
    capacity as a member of the Georgia
    State Election Board, REBECCA
    N.SULLIVAN, in her official capacity as
    a member of the Georgia State Election
    Board, MATTHEW MASHBURN, in his
    official capacity as a member of the
    Georgia State Election Board, and ANH
    LE, in her official capacity as a member
    of the Georgia State Election Board,

    Comments

    COMPLAINT FOR DECLARATORY, EMERGENCY, AND
    PERMANENT INJUNCTIVE RELIEF

    NATURE OF THE ACTION

    This civil action brings to light a massive election fraud, multiple
    violations of Georgia laws, including O.C.G.A. §§ 21-2-30(d), 21-2-31, 21-2-
    33.1 and §21-2-522, and multiple Constitutional violations, as shown by fact
    witnesses to specific incidents, multiple expert witnesses and the sheer
    mathematical impossibilities found in the Georgia 2020 General Election.
    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, “[i]
    was not incumbent upon [Plaintiff] to show how the [] voters would have voted
    if their [absentee] ballots had been regular. [Plaintiff] only had to show that
    there were enough irregular ballots to place in doubt the result.” Mead v.
    Sheffield, 278 Ga. 268, 272, 601 S.E.2d 99, 102 (2004) (citing Howell v. Fears,
    275 Ga. 627, 571 S.E.2d 392 (2002).
    1 The same pattern of election fraud and voter fraud writ large occurred in all
    the swing states with only minor variations, see expert reports, regarding
    Michigan, Pennsylvania, Arizona and Wisconsin. (See William M. Briggs Decl.,
    attached here to as Exh. 1, Report with Attachment). Indeed, we believe that in
    Arizona at least 35,000 votes were illegally added to Mr. Biden’s vote count.

    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.
    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.” It has now been amplified and rendered virtually invisible
    by computer software created and run by domestic and foreign actors for that
    very purpose. 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.
    Especially egregious conduct arose in Forsyth, Spalding, 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.

    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; and Dominion logs are only voluntary, with no
    system wide preservation system.

    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.
    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
    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.” Id.
    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. (See Redacted whistleblower affiant, attached as
    Exh. 2) Notably, Chavez “won” every election thereafter.
    3 See WSJ.com, Smartmatic to Sell U.S. Unit, End Probe into Venezuelan Links, by
    Bob Davis, 12/22/2006, https://www.wsj.com/articles/SB116674617078557263
    5
    6.
    As set forth in the accompanying whistleblower affidavit, the
    Smartmatic software was designed to manipulate Venezuelan elections in
    favor of dictator Hugo Chavez:
    Smartmatic’s electoral technology was called “Sistema de Gestión
    Electoral” (the “Electoral Management System”). Smartmatic was a
    pioneer in this area of computing systems. Their system provided for
    transmission of voting data over the internet to a computerized
    central tabulating center. The voting machines themselves had a
    digital display, fingerprint recognition feature to identify the voter,
    and printed out the voter’s ballot. The voter’s thumbprint was linked
    to a computerized record of that voter’s identity. Smartmatic created
    and operated the entire system.
    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. He wanted the software itself to function in such a
    manner that if the voter were to place their thumb print or
    fingerprint on a scanner, then the thumbprint would be tied to a
    record of the voter’s name and identity as having voted, but that voter
    would not be tracked to the changed vote. He made it clear that the
    system would have to be setup to not leave any evidence of the
    changed vote for a specific voter and that there would be no evidence
    to show and nothing to contradict that the name or the fingerprint or
    thumb print was going with a changed vote. Smartmatic agreed to
    create such a system and produced the software and hardware that
    6
    accomplished that result for President Chavez. (See Id., see also Exh.
    3, Aff. Cardozo, attached hereto).
    8.
    The design and features of the Dominion software do not permit a
    simple audit to reveal its misallocation, redistribution, or deletion of votes.
    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. 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. 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
    7
    the internet in violation of professional standards and state and federal laws.
    (See Id.)
    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. 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
    Election4. A certificate from the Secretary of State was awarded to Dominion
    4 Georgia Governor Inks Law to Replace Voting Machines, The Atlanta
    Journal-Constitution, AJC News Now, Credit: Copyright 2019 The Associated Press,
    June 2019. https://www.ajc.com/blog/politics/georgia-governor-inks-law-replacevoting-machines/xNXs0ByQAOvtXhd27kJdqO/
    8
    Voting Systems but is undated. (See attached hereto Exh. 5, copy
    Certification for Dominion Voting Systems from Secretary of State).
    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. 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 minutes alone 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
    5 Full unredacted copies of all exhibits have been filed under seal with the Court
    and Plaintiffs have simultaneously moved for a protective order.
    9
    14.
    As explained and demonstrated in the accompanying redacted
    declaration of a former electronic intelligence analyst under 305th Military
    Intelligence with experience gathering SAM missile system electronic
    intelligence, the 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. (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 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).
    10
    16.
    Additionally, incontrovertible evidence Board of Elections records
    demonstrates that at least 96,600 absentee ballots were requested and
    counted but were never recorded as being returned to county election boards
    by the voter. Thus, at a minimum, 96,600 votes must be disregarded. (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. 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, plus in Floyd county,
    another 2,600 absentee ballots had not been scanned. These “found votes”
    reduced Biden’s lead over Donald Trump6.
    6 Recount find thousands of Georgia votes, Atlanta Journal-Constitution by Mark
    Niesse and David Wickert,11/19/20. https://www.ajc.com/politics/recount-findsthousands-of-georgia-votes-missing-from-initialcounts/ERDRNXPH3REQTM4SOINPSEP72M/
    11
    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. 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. 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; . .
    . (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; 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.
    12
    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.
    Separately, and 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 more than fifty thousand illegal ballots.

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    Document Links 1 (Scribd et. al)

    https://defendingtherepublic.org/wp-content/uploads/2020/11/COMPLAINT-CJ-PEARSON-V.-KEMP-11.25.2020.pdf

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