Replies

Here’s the request for relief at the end.

REQUEST FOR RELIEF
208.
Accordingly, Plaintiffs seek an emergency order instructing
Defendants to de-certify the results of the General Election for the Office of
President.
209.
In the alternative, Plaintiffs seek an emergency order prohibiting
Defendants from including in any certified results from the General Election
the tabulation of absentee and mailing ballots which do not comply with the
Election Code, including, without limitation, the tabulation of absentee and
mail-in ballots Trump Campaign’s watchers were prevented from observing
or based on the tabulation of invalidly cast absentee and mail-in ballots
which (i) lack a secrecy envelope, or contain on that envelope any text, mark,
or symbol which reveals the elector’s identity, political affiliation, or
candidate preference, (ii) do not include on the outside envelope a completed
declaration that is dated and signed by the elector, or (iii) are delivered inperson by third parties for non-disabled voters.
210.
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
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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 in the state. For these reasons, Georgia cannot reasonably
rely on the results of the mail vote. Relief sought is the elimination of the
mail ballots from counting in the 2020 election. Alternatively, the electors for
the state of Georgia should be disqualified from counting toward the 2020
election. Alternatively, the electors of the State of Georgia should be directed
to vote for President Donald Trump.
211.
For these reasons, Plaintiff asks this Court to enter a judgment in
their favor and provide the following emergency relief:
1. An order directing Governor Kemp, Secretary Raffensperger and the
Georgia State Board of Elections to de-certify the election results;
2. An order enjoining Governor Kemp from transmitting the currently
certified election results to the Electoral College;
3. An order requiring Governor Kemp to transmit certified election
results that state that President Donald Trump is the winner of the
election;
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4. An immediate order to impound all the voting machines and
software in Georgia for expert inspection by the Plaintiffs.
5. An order that no votes received or tabulated by machines that were
not certified as required by federal and state law be counted.
6. A declaratory judgment declaring that Georgia Secretary of State
Rule 183-1-14-0.9-.15 violates the Electors and Elections Clause,
U.S. CONST. art. I, § 4;
7. A declaratory judgment declaring that Georgia’s failed system of
signature verification violates the Electors and Elections Clause by
working a de facto abolition of the signature verification
requirement;
8. A declaratory judgment declaring that current certified election
results violates the Due Process Clause, U.S. CONST. Amend. XIV;
9. A declaratory judgment declaring that mail-in and absentee ballot
fraud must be remedied with a Full Manual Recount or statistically
valid sampling that properly verifies the signatures on absentee
ballot envelopes and that invalidates the certified results if the
recount or sampling analysis shows a sufficient number of ineligible
absentee ballots were counted;
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10. An emergency declaratory judgment that voting machines be
Seized and Impounded immediately for a forensic audit—by
plaintiffs’ expects;
11. A declaratory judgment declaring absentee ballot fraud occurred
in violation of Constitutional rights, Election laws and under state
law;
12. A permanent injunction prohibiting the Governor and Secretary
of State from transmitting the currently certified results to the
Electoral College based on the overwhelming evidence of election
tampering;
13. Immediate production of 36 hours of security camera recording of
all rooms used in the voting process at State Farm Arena in Fulton
County, GA from 12:00am to 3:00am until 6:00pm on November 3.
14. Plaintiffs further request the Court grant such other relief as is
just and proper, including but not limited to, the costs of this action
and their reasonable attorney fees and expenses pursuant to 42
U.S.C. 1988.
Respectfully submitted, this 25th day of November, 2020.