Replies

From Michigan:

73. Other challengers were threatened with removal from the counting area if they
continued to ask questions about the ballot counting process. Id. (A. Seely aff. ¶¶6, 13, 15;
Pennalaaff. ¶5). Challenger Kathleen Daavettila observed that Democratic challengers
distributed a packet of information among themselves entitled, “Tactics to Distract GOP
Challengers.” Id. (Daavettila aff., p. 2). An election official told challenger Ulrike Sherer that the
election authority had a police SWAT team waiting outside if Republican challengers argued too
much. Id. (Sherer aff. ¶24). An election worker told challenger
JazmineEarlythatsince“Englishwasnot[her]firstlanguage…[she]shouldnotbetaking part in this
process.” Id. (Early aff. ¶11).

More from Michigan:

74. Election officials at the TCF Center in Detroit participated in the intimidation
experienced by Republican challengers when election officials would applaud, cheer, and yell
whenever a Republican challenger was ejected from the counting area. Id. (Helminen aff. ¶9;
Pennala aff. ¶5; Ballew aff. ¶9; Piontek aff. ¶11;
Papsdorfaff.¶3;Steffansaff.¶25;Cizmaraff.¶8(D);Kilunenaff.¶5;Daavettilaaff.,p.4; Cavaliere aff.
¶3; Cassin aff. ¶10; Langer aff. ¶3; Johnson aff. ¶5; Early aff. ¶13; Klamer aff. ¶8; Posch aff.
¶12; Rauf aff. ¶22; Chopjian aff. ¶13; Shock aff.¶10).
Case 2:20-cv-13134-LVP-RSW ECF No. 1, PageID.24 Filed 11/25/20 Page 24 of 75
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5. Poll Workers Ignored or Refused to Record Republican Challenges.
75. Unfortunately, this did not happen in Wayne County. Many challengers testified
that their challenges to ballots were ignored and disregarded. Id. (A.Seely aff. ¶4; Helminen aff.
¶5; Miller aff. ¶¶10-11; Schornak aff. ¶¶9, 15; Piontek aff. ¶6;
Daavettilaaff.,p.3;Valiceaff.¶2;Sawyeraff.¶7;Kerstein aff.¶3;Modlinaff.¶4;Cassin aff. ¶6;
Brigmon aff. ¶5; Sherer aff. ¶11; Early aff. ¶18; Pannebecker aff. ¶9; Vanker aff. ¶5; M. Seely
aff. ¶11; Ungar aff. ¶¶16-17; Fracassi aff. ¶4).
76. As an example of challenges being disregarded and ignored, challenger Alexandra
Seely stated that at least ten challenges she made were not recorded. Id. (A. Seely aff. ¶4).
ArticiaBomer observed that ballots with votes for Trump were separated
fromotherballots.Id.(Bomeraff.¶5).ArticiaBomerstated,“Iwitnessedelectionworkers open ballots
with Donald Trump votes and respond by rolling their eyes and showing it to other poll workers.
I believe some of these ballots may not have been properly counted.” Id. ¶8. Braden Gaicobazzi
challenged thirty-five ballots for whom the voter records did not exist in the poll book, but his
challenge was ignored and disregarded. Id. (Giacobazzi aff. ¶10). When Christopher Schornak
attempted to challenge the counting of
ballots,anelectionofficialtoldhim,“Wearenottalkingtoyou,youcannotchallengethis.”
Id.(Schornakaff.¶15).WhenStephanieKrauseattemptedtochallengeballots,anelection
workertoldherthatchallengeswerenolongerbeingacceptedbecausethe“rules‘nolonger applied.’” Id.
(Krause aff.¶13).

More Michigan:

6. Unlawful Ballot Duplication.
77. If a ballot is rejected by a ballot-tabulator machine and cannot be read by the
machine, the ballot must be duplicated onto a new ballot. The Michigan Secretary of State has
instructed, “If the rejection is due to a false read the ballot must be duplicatedby two election
Case 2:20-cv-13134-LVP-RSW ECF No. 1, PageID.25 Filed 11/25/20 Page 25 of 75
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inspectors who have expressed a preference for different political parties.” Michigan Election
Officials’ Manual, ch. 8, p. 6 (emphasis added). Thus, the ballot-duplicating process must be
performed by bipartisan teams of election officials. It must also be performed where it can be
observed bychallengers.
78. But Wayne County prevented many challengers from observing the ballot
duplicating process. Id. (Miller aff. ¶¶6-8; Steffans aff. ¶¶15-16, 23-24;
Mandelbaumaff.¶6;Shereraff.¶¶16-
17;Burtonaff.¶7;Drzewieckiaff.¶7;Klameraff.¶9;Chopjianaff.¶10;Schmidtaff.¶7;Champagneaff.¶
12;Shinkleaff.,p.1).Challenger John Miller said he was not allowed to observe election workers
duplicating a ballot
becausethe“duplicationprocesswaspersonallikevoting.”Id.(Milleraff.¶8).Challenger Mary Shinkle
stated that she was told by an election worker that she was not allowed to
observeaballotduplicationbecause“ifwemakeamistakethenyouwouldbealloverus.” Id. (Shinkle
aff., p. 1).Anotherchallengerobservedelectionofficialsmakingmistakeswhen duplicating ballots.
Id. (Piontek aff. ¶9).
79. Many challengers testified that ballot duplication was performed only by
Democratic election workers, not bipartisan teams. Exhibit 1 (Pettibone aff. ¶3; Kinney
aff.,p.1;Wasilewskiaff.,p.1;Schornakaff.¶¶18-19;Dixonaff.,p.1;Kolanagireddyaff.,p. 1;
Kordenbrock aff. ¶¶3-4; Seidl aff., p. 1; Kerstein aff. ¶4; Harris aff. ¶3; Sitek aff. ¶4).