Michigan: Constantino et al v. City of Detroit et al

INTRODUCTION
1. The election was held on November 3, 2020 and approximately 850,000 votes were
reported as cast in Wayne County, Michigan.
2. Plaintiff brings this action to raise numerous issues 0f fraud and misconduct that
occurred in order to protect the rights 0f all voters in Michigan, especially Wayne County.
3.
limited to:
In summary, this Complaint raises numerous instances 0f fraud, including, but not
Defendants systematically processed and counted ballots from voters whose name
failed to appear in either the Qualified Voter File (QVF) 0r in the supplemental
sheets. When voter’s name could not be found, the election worker assigned the
ballot to random name already in the QVF to person Who had not voted.
Defendants instructed election workers to not verify signatures on absentee ballots,
to backdate absentee ballots, and to process such ballots regardless 0f their validity.
After election officials announced the last absentee ballots had been received,
another batch 0funsecured and unsealed ballots, Without envelopes, arrived in trays
at the TCF Center. There were tens 0f thousands 0f these absentee ballots, and
apparently every ballot was counted and attributed only to Democratic candidates.
Defendants instructed election workers to process ballots that appeared after the
election deadline and to falsely report that those ballots had been received prior to
November 3, 2020 deadline.
Defendants systematically used false information to process ballots, such as using
incorrect 0r false birthdays. Many times, the election workers inserted new names
into the QVF after the election and recorded these new voters as having birthdate
0f 1/ 1/ 900.
On daily basis leading up to the election, City 0f Detroit election workers and
employees coached voters to vote for Joe Biden and the Democrat party. These
workers and employees encouraged voters to d0 straight Democrat ballot. These
election workers and employees went over to the voting booths With voters in order
to watch them vote and coach them for whom to vote.
Unsecured ballots arrived at the TCF Center loading garage, not in sealed ballot
boxes, without any chain 0f custody, and without envelopes.
Defendant election officials and workers refused to record challenges to their
processes and removed challengers from the site if they politely voiced challenge.
After p011 challengers started discovering the fraud taking place at the TCF Center,
Defendant election officials and workers locked credentialed challengers out 0f the
counting room so they could not observe the process, during Which time tens 0f
thousands 0f ballots were processed.
Defendant election officials and workers allowed ballots to be duplicated by hand
without allowing poll challengers to check if the duplication was accurate. In fact,
election officials and workers repeatedly obstructed poll challengers from
observing. Defendants permitted thousands 0f ballots to be filled out by hand and
duplicated on site Without oversight from p011 challengers.