Replies

183.
Plaintiffs contest the results of Georgia’s election, with Standing
conferred under pursuant to O.G.C.A. 21-2-521.
184.
Therefore, pursuant to O.G.C.A. 21-2-522, for misconduct, fraud, or
irregularity by any primary or election official or officials sufficient to change
or place in doubt the result. The foundational principle that Georgia law
“nonetheless allows elections to be contested through litigation, both as a
check on the integrity of the election process and as a means of ensuring the
fundamental right of citizens to vote and to have their votes counted
accurately.” Martin v. Fulton County Bd. of Registration & Elections, 307 Ga.
193, 194, 835 S.E.2d 245, 248 (2019). The Georgia Supreme Court has made
clear that Plaintiffs need not show how the [] voters would have voted if their
[absentee] ballots had been regular. [] only had to show that there were
enough irregular ballots to place in doubt the result.” See OCGA § 21-2-520 et
seq., Mead v. Sheffield, 278 Ga. 268, 272, 601 S.E.2d 99, 102 (1994) the
Supreme Court invalidated an election, and ordered a new election because it
found that,
Thus, [i]t was not incumbent upon [the Plaintiff] to show how the
[481] voters would have voted if their [absentee] ballots had
been regular. He only had to show that there were enough irregular
ballots to place in doubt the result. He succeeded in that task.
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Id. at 271 (citing Howell v. Fears, 275 Ga. 627, 571 SE2d 392, (2002) (primary
results invalid where ballot in one precinct omitted names of both qualified
candidates).
185.
The “glitches” in the Dominion system—that seem to have the uniform
effect of hurting Trump and helping Biden have been widely reported in the
press and confirmed by the analysis of independent experts.
186.
Prima facie evidence in multiple affidavits shows specific fraudulent
acts, which directly resulted in the flipping of the race at issue:
a) votes being switched in Biden’s favor away from Trump during the
recount;
b) the lack of procedures in place to follow the election code, and the
purchase and use, Dominion Voting System despite evidence of serious
vulnerabilities;
c) a demonstration that misrepresentations were made about a pipe burst
that sent everyone home, while first six, then three, unknown
individuals were left alone until the morning hours working on the
machines;
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d) further a failure to demonstrate compliance with the Georgia’s Election
Codes, in maintaining logs on the Voting system for a genuine and
sound audit, other than voluntary editable logs that prevent genuine
audits. While the bedrock of this Democratic Republic rests on citizens’
confidence in the validity of our elections and a transparent process,
Georgia’s November 3, 2020 General Election remains under a pall of
corruption and irregularity that reflects a pattern of the absence of
mistake. At best, the evidence so far shows ignorance of the truth; at
worst, it proves a knowing intent to defraud.
187.
Plaintiff’s expert also finds that voters received tens of thousands of
ballots that they never requested. (See Exh. 1, Dr. Briggs’ Report).
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 President Trump by 12,670
votes by at least 4,268 unlawful requests and by as many as 10,101 unlawful
requests.
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188.
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.
189.
Further, there exists clear evidence of 20,311 absentee or early voters
in Georgia that voted while registered as having moved out of state.
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.
190.
Plaintiffs’’ expert Russell Ramsland concludes that at least 96,600
mail-in ballots were fraudulently cast. He further concludes that up to
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136,098 ballots were illegally counted as a result of improper manipulation of
the Dominion software. (Ramsland Aff).
191.
The very existence of absentee mail in ballots created a heightened
opportunity for fraud. The population of unreturned ballots analyzed by
William Briggs, PhD, reveals the probability that a far greater number of
mail ballots were requested by 3rd parties or sent erroneously to persons and
voted fraudulently, undetected by a failed system of signature verification.
The recipients may have voted in the name of another person, may have not
had the legal right to vote and voted anyway, or may have not received the
ballot at the proper address and then found that they were unable to vote at
the polls, except provisionally, due to a ballot outstanding in their name.
192.
When we consider the harm of these uncounted votes, and ballots not
ordered by the voters themselves, and the potential that many of these
unordered ballots may in fact have been improperly voted and also prevented
proper voting at the polls, the mail ballot system has clearly failed in the
state of Georgia and did so on a large scale and widespread basis. The size of
the voting failures, whether accidental or intentional, are multiples larger
than the margin of votes between the presidential candidates in the
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state. For these reasons, Georgia cannot reasonably rely on the results of the
mail vote.