Stein lacks a factual basis for her belief that a mistake, fraud, defect, irregularity, or illegality HAS occurred. Neither Stein nor Halderman have provided any evidence to that effect.
Stein wants a recount in order to determine if there is any irregularity. This is exactly backwards.
Wisconsin law [Wis. Stat. § 9.01(1)(a)2.b] requires that a petitioner for a recount be informed and believe that a mistake, fraud, defect, irregularity, or illegality HAS occurred. Stein has provided no facts to inform her belief that any of this HAS occurred in Wisconsin. Indeed, her petition states that a recount is necessary to determine whether evidence of an irregularity exists.
Steins petition:Stein has not provided any evidence to support her belief that any irregularity has occurred and is requesting a recount to determine whether evidence supporting her belief exists.2. The Petitioner is informed and believes that an irregularity has occurred...
3. The Petitioner is informed and believes that:
g. A hand count of paper ballots [] are necessary to make this determination