120.
Plaintiffs have also learned through several reports that in 2010 Eric
Coomer joined Dominion as Vice President of U.S. Engineering. According to
his bio, Coomer graduated from the University of California, Berkeley with a
Ph.D. in Nuclear Physics. Eric Coomer was later promoted to Voting Systems
Officer of Strategy and Security although Coomer has since been removed
from the Dominion page of directors. Dominion altered its website after
59
Colorado resident Joe Oltmann disclosed that as a reporter he infiltrated
ANTIFA, a domestic terrorist organization where he recorded Eric Coomer
representing: “Don’t worry. Trump won’t win the election, we fixed that.” – as
well as social media posts with violence threatened against President Trump.
(See Joe Oltmann interview with Michelle Malkin dated November 13, 2020
which contains copies of Eric Coomer’s recording and tweets).33
(a) Regarding uncounted mail ballots, based on evidence
gathered by Matt Braynard in the form of recorded calls and
declarations of voters, and analyzed by Plaintiff’s expert, Williams M.
Briggs, PhD, shows, based on a statistically significant sample, that
the total number of mail ballots that voters mailed in, but were
never counted, have a 95% likelihood of falling between 31,559
and 38,886 total lost votes. This range exceeds the margin of loss of
President Trump of 12,670 votes by at least 18,889 lost votes and by as
many as 26,196 lost votes. (See Exh. 1, Dr. Briggs’ Report, with
attachments).
(b) Plaintiff’s expert also finds that voters received tens of
thousands of ballots that they never requested. (See Exh. 1).
Specifically, Dr. Briggs found that in the state of Georgia, based on a
statistically significant sample, the expected amount of persons that
received an absentee ballot that they did not request ranges from
16,938 to 22,771. This range exceeds the margin of loss of
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President Trump by 12,670 votes by at least 4,268 unlawful
requests and by as many as 10,101 unlawful requests. Id.
(c) This widespread pattern, as reflected within the population
of unreturned ballots analyzed by Dr. Briggs, reveals the unavoidable
reality that, in addition to the calculations herein, third parties voted
an untold number of unlawfully acquired absentee or mail-in ballots,
which would not be in the database of unreturned ballots analyzed
here. See O.G.C.A. 21-2-522. These unlawfully voted ballots
prohibited properly registered persons from voting and reveal
a pattern of widespread fraud down ballot as well.
(d) Further, as calculated by Matt Braynard, there exists
clear evidence of 20,311 absentee or early voters in Georgia that
voted while registered as having moved out of state. (See Id.,
attachment to report). Specifically, these persons were showing on the
National Change of Address Database (NCOA) as having moved, or as
having filed subsequent voter registration in another state also as
evidence that they moved and even potentially voted in another state.
The 20,311 votes by persons documented as having moved exceeds the
margin by which Donald Trump lost the election by 7,641 votes.