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UNITED STATES DISTRICT COURT EASTERN DISTRICT OF PENNSYLVANIA JILL STEIN and RANDALL REITZ, Plaintiffs, v. PEDRO A. CORTÉS, in his official capacity as Secretary of the Commonwealth; and JONATHAN MARKS, in his official capacity as Commissioner of the Bureau of Commissions, Elections, and Legislation, Defendants. No.
COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF
NOW COME Plaintiffs Jill Stein and Randall Reitz (collectively “Plaintiffs”), by and through their attorneys, Montgomery McCracken Walker & Rhoads LLP, Emery Celli Brinckerhoff & Abady LLP, and Lawrence Otter, Esq., and for their Complaint for declaratory and injunctive relief against Pedro A. Cortés, in his official capacity as Secretary of the Commonwealth; and Jonathan M. Marks, in his official capacity as Commissioner of the Bureau of Commissions, Elections, and Legislation, hereby allege as follows.
INTRODUCTION
1.

The Pennsylvania election system is a national disgrace. Voters are forced to use vulnerable, hackable, antiquated technology banned in other states, then rely on the kindness of machines. There is no paper trail. Voting machines are electoral black sites: no one permits voters or candidates to examine them.

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2.

After election day, voters are equally helpless to make sure their votes are counted. The Election Code requires 27,474 voters in 9,158 districts to bring notarized petitions to county boards, in time for shifting, divergent, and secret deadlines known to no one except, perhaps, 67 separate county election boards. In court recounts, voters must pay exorbitant fees, and (according to boards of elections) should only one voter fail to sign a single petition in a single district anywhere in the State, no one can seek a recount anywhere. 3.

This labyrinthine, incomprehensible, and impossibly burdensome election regime might make Kafka proud. But for ordinary voters, it is a disaster. 4.

###### In the 2016 presidential election, rife with foreign interference documented by American intelligence agencies ###### and hacks of voter rolls in multiple states, voters deserve the truth. Were Pennsylvania votes counted accurately? That truth is not difficult to learn: simply count the paper ballots in optical scan districts, and permit forensic examination of the electronic voting systems in DRE districts. This can be done in days, by top experts, if necessary at the Stein campaign’s expense, under the supervision of election officials, and without endangering a single vote. 5.

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