Michigan, Sidney Powell: TIMOTHY KING et al v. Gov GRETCHEN WHITMER, et al

COMPLAINT FOR DECLARATORY, EMERGENCY,
AND PERMANENT INJUNCTIVE RELIEF

NATURE OF THE ACTION
1. This civil action brings to light a massive election fraud, multiple violations of the
Michigan Election Code, see, e.g., MCL §§ 168.730-738, in addition to the Election and Electors
Clauses and Equal Protection Clause of the U.S. Constitution violations that occurred during the
2020 General Election throughout the State of Michigan,1as set forth in the affidavits of dozens
of eye witnesses and the statistical anomalies and mathematical impossibilities detailed in the
affidavits of expert witnesses.
2. The scheme and artifice to defraud was for the purpose of illegally and
fraudulently manipulating the vote count to manufacture an election of Joe Biden as President of
the United States. The fraud was executed by many means,2 but the most fundamentally
troubling, insidious, and egregious ploy was the systemic adaptation of old-fashioned “ballotstuffing.” It has now been amplified and rendered virtually invisible by computer software
created and run by domestic and foreign actors for that very purpose. This Complaint details an
especially egregious range of conduct in Wayne County and the City of Detroit, though this
conduct occurred throughout the State at the direction of Michigan state election officials.
3. The multifaceted schemes and artifices implemented by Defendants and their
collaborators to defraud resulted in the unlawful counting, or manufacturing, of hundreds of
thousands of illegal, ineligible, duplicate or purely fictitious ballots in the State of Michigan, that
constitute a multiple of Biden’s purported lead in the State. While this Complaint, and the
eyewitness and expert testimony incorporated herein, identify with specificity sufficient ballots
required to overturn and reverse the election results, the entire process is so riddled with fraud,
illegality, and statistical impossibility that this Court, and Michigan’s voters, courts, and
legislators, cannot rely on, or certify, any numbers resulting from this election.
Dominion Voting Systems Fraud and Manipulation
4. The fraud begins with the election software and hardware from Dominion Voting
Systems Corporation (“Dominion”) used by the MichiganBoard of State Canvassers. The
Dominion systems derive from the software designed by Smartmatic Corporation, which became
Sequoia in the United States.
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 Exh. 1, Redacted
Declaration of Dominion Venezuela Whistleblower (“Dominion Whistleblower Report”).
Notably, Chavez “won” every election thereafter.
6. As set forth in the DominionWhistleblower Report, the Smartmatic software was
contrived through a criminal conspiracy to manipulate Venezuelan elections in favor of dictator
Hugo Chavez:
Importantly, I was a direct witness to the creation and operation of an electronic
voting system in a conspiracy between a company known as Smartmatic and the
leaders of conspiracy with the Venezuelan government. This conspiracy
specifically involved President Hugo Chavez Frias, the person in charge of the
National Electoral Council named Jorge Rodriguez, and principals,
representatives, and personnel from Smartmatic. The purpose of this conspiracy
was to create and operate a voting system that could change the votes in elections
from votes against persons running the Venezuelan government to votes in their
favor in order to maintain control of the government. In mid-February of 2009,
there was a national referendum to change theConstitution of Venezuela to end
term limits for elected officials, including the President of Venezuela. The
referendum passed. This permitted Hugo Chavez to be re-elected an unlimited
number of times. . . .
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. Id. ¶¶ 10 & 14.
7. A core requirement of the Smartmatic software design ultimately adopted by
Dominion for the Michigan’s elections 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
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 accomplished
that result for President Chavez.Id. ¶15.
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
Exh. 107, August 24, 2020 Declaration of HarriHursti, ¶¶45-48).

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
the internet in violation of professional standards, which violates federal election law on the
preservation of evidence.
10. In deciding to award Dominion a$25 million, ten-year contract (to a Dominion
project team led by Kelly Garrett, former Deputy Director of the Michigan Democratic Party),
and then certifying Dominion software, Michigan officials disregarded all the concerns that
caused Dominion software to be rejected by the Texas Board of elections in 2018 because it was
deemed 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."3
11. Plaintiff’s expert witness, Russell James Ramsland, Jr. (Exh. 101, “Ramsland
Affidavit”), has concluded that Dominion alone is responsible for the injection, or fabrication, of
289,866 illegal votes in Michigan, that must be disregarded. This is almost twice the number of
Mr. Biden’s purported lead in the Michigan vote (without consideration of the additional illegal,
ineligible, duplicate or fictitious votes due to the unlawful conduct outlined below), and thus by
itself is grounds to set aside the 2020 General Election and grant the declaratory and injunctive
relief requested herein.
12. In addition to the Dominion computer fraud, this Complaint identifies several
additional categories of “traditional” voting fraud and Michigan Election Code violations,
supplemented by healthy doses of harassment, intimidation, discrimination, abuse and even
physical removal of Republican poll challengers to eliminate any semblance of transparency,
objectivity or fairness from the vote counting process. While this illegal conduct by election
workers and state, county and city employees in concert with Dominion, even if considered in
isolation, the following three categories of systematic violations of the Michigan Election Code
cast significant doubt on the results of the election and mandate this Court to set aside the 2020
General Election and grant the declaratory and injunctive relief requested herein.
Fact Witness Testimony of Voting Fraud & Other Illegal Conduct
13. There were three broad categories of illegal conduct by election workers in
collaboration with other employee state, county and/or city employees and Democratic poll
watchers and activists.First, to facilitate and cover-up the voting fraud and counting of
fraudulent, illegal or ineligible voters, election workers:
A. Denied Republican election challengers access to the TCF Center, where all
Wayne County, Michigan ballots were processed and counted;
B. Denied Republic poll watchers at the TCF Center meaningful access to view
ballot handling, processing, or counting and
lockedcredentialedchallengersoutofthe counting room so they could not observe
the process, during which time tens of thousands of ballots wereprocessed;
C. Engaged in a systematic pattern of harassment, intimidation and even physical
removal of Republican election challengers or locking them out of the TCF
Center;
D. Systematically discriminated against Republican poll watchers and favored
Democratic poll watchers;
E. Ignored or refused to record Republican challenges to the violations outlined
herein;
F. Refused to permit Republican poll challengers to observe ballot duplication and
other instances where they allowed ballots to be duplicated by hand without
allowing poll challengers to check if the duplication was accurate;
G. Unlawfully coached voters to vote for Joe Biden and to vote a straight Democrat
ballot, including by going overtothevotingboothswithvotersinorder to watch them
vote and coach them for whom to vote;
H. As a result of the above, Democratic election challengers outnumbered
Republicans by 2:1 or 3:1 (or sometimes 2:0 at voting machines); and
I. Collaborated with Michigan State, Wayne County and/or City of Detroit
employees (including police) in all of the above unlawful and discriminatory
behavior.
14. Second, election workers illegally forged, added, removed or otherwise altered
information on ballots, the Qualified Voter File (QVF) and Other Voting Records, including:
A. Fraudulently adding “tens of thousands” of new ballots and/or new voters to QVF
in two separate batches on November 4, 2020, all or nearly all of which were
votes for Joe Biden;
B. Forging voter information and fraudulently adding new voters to the QVF Voters,
in particular, e.g., when a voter’s name could not be found, the election worker
assigned the ballot to a random name already in the QVF to a person who had
notvoted and recordedthesenewvotersashavingabirthdate of1/1/1900;
C. Changing dates on absenteeballots received after 8:00 PM Election Day deadline
to indicate that such ballots were received before the deadline;
D. Changing Votes for Trump and other Republican candidates; and
E. Added votes to “undervote” ballots and removing votes from “Over-Votes”.
15. Third, election workers committed several additional categories of violations of
the Michigan Election Code to enable them to accept and count other illegal, ineligible or
duplicate ballots, or reject Trump or Republican ballots, including:
A. Permitting illegal double voting by persons that had voted by absentee ballot and
in person;
B. Counting ineligible ballots – and in many cases – multiple times;
C. Counting ballots without signatures, or without attempting to match signatures,
and ballots without postmarks, pursuant to direct instructions from Defendants;
D. Counting “spoiled” ballots;
E. Systematic violations of ballot secrecy requirements;
F. Unsecured ballots arrived at the TCF Center loading garage, not in sealed ballot
boxes, without any chain of custody, and withoutenvelopes, after the 8:00 PM
Election Day deadline, in particular, the tens of thousands of ballots that arrived
on November 4, 2020; and
G. Accepting and counting ballots from deceased voters.
Expert Witness Testimony Regarding Voting Fraud
16. In addition to the above fact witnesses, this Complaint presents expert witness
testimony demonstrating that several hundred thousand illegal, ineligible, duplicate or purely
fictitious votes must be thrown out, in particular: (1) a report from Russel Ramsland, Jr. showing
the “physical impossibility” of nearly 385,000 votes injected by four precincts/township on
November 4, 2020, that resulted in the counting of nearly 290,000 more ballots processed than
available capacity (which is based on statistical analysis that is independent of his analysis of
Dominion’s flaws); (2) a report from Dr. William Briggs, showing that there were approximately
60,000 absentee ballots listed as “unreturned” by voters that either never requested them, or that
requested and returned their ballots; and (3) a report from Dr. Eric Quinell analyzing the
anomalous turnout figures in Wayne and Oakland Counties showing that Biden gained nearly
100% and frequently more than 100% of all “new” voters in certain townships/precincts over
2016, and thus indicated that nearly 87,000 anomalous and likely fraudulent votes from these
precincts.
17. 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 Ex. 105, copy of redacted witness
affidavit, November 23, 2020).
18. 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. (Ex. 109).
19. These and other “irregularities” provide this Court grounds to set aside the results
of the 2020 General Election and provide the other declaratory and injunctive relief requested
herein.

ReadMore: https://defendingtherepublic.org/wp-content/uploads/2020/11/Michigan-Complaint.pdf