Michigan accepts no-chain-of-custody ballots
7. Election Workers Accepted Unsecured Ballots, without Chain of
Custody, after 8:00 PM Election Day Deadline.
100. Poll challengers observed two batches of new ballots brought to the TCF Center
after the 8:00 PM Election Day deadline, as detailed in the GLJC Complaint and Paragraphs 79-
81above. Affiant Daniel Gustafson further observed that these batches of ballots “were delivered
to the TCF Center in what appeared to be mail bins with open tops.” Exh. 4, GLJC Complaint,
Exh. E at¶4. Mr. Gustafson further observed that these bins and containers “did not have lids,
were not sealed, and did not have the capability of having a metal seal,” id. at ¶5, nor were they
“marked or identified in any way to indicated their source of origin.” Id. at ¶6.
101. An election challenger at the Detroit Department of Elections office observed
passengers in cars dropping off more ballots than there were people in the car. Exh. 3 (Meyers
aff. ¶3). This challenger also observed an election worker accepting a ballot after 8:00 p.m. on
Election Day. Id.¶7.
102. An election challenger at the Detroit Department of Elections office observed
ballots being deposited in a ballot drop box located at the Detroit Department of Elections after
Case 2:20-cv-13134-LVP-RSW ECF No. 1, PageID.34 Filed 11/25/20 Page 34 of 75
35
8:00 p.m. on Election Day. Id. (Meyers aff.¶6).
103. On November 4, 2020, Affiant Matt Ciantar came forward who, independently
witnessed, while walking his dog, a young couple delivered 3-4 large plastic clear bags, that
appear to be “express bags”, as reflected in photographs taken contemporaneously, to a U.S.
Postal vehicle waiting. See generallyExh. 7 Matt Ciantar Declaration. The use of clear “express
bags” is consistent with the USPS whistleblower Johnathan Clarke in Traverse City, Michigan.
See infra Paragraph 78
C. Over 13,000 Ineligible Voters Who Have Moved Out-of-State Illegally Voted
in Michigan.
111. Evidence compiled by Matt Braynard using the National Change of Address
(“NCOA”) Database shows that 12,120 Michigan voters in the 2020 General Election moved
out-of-state prior to voting, and therefore were ineligible. Mr. Braynerd identified 1,170
Michigan voters in the 2020 General Election who subsequently registered to vote in another
state, and were therefore ineligible to vote in the 2020 General Election. When duplicates from
the two databases are eliminated, the merged number is 13,248 ineligible voters whose votes
must be removed from the total for the 2020 General Election.6
D. There Were At Least 289,866 More Ballots Processed in Four Michigan
Counties on November 4 Than There Was Processing Capacity.
112. The expert witness testimony of Russell James Ramsland, Jr. (“Ramsland
Affidavit”), which is described in greater detail below, identifies an event that occurred in
Michigan on November 4 that is “physically impossible” See Exh. 104 at ¶14. The “event”
6
Mr. Braynard posted the results of his analysis on Twitter. See
https://twitter.com/MattBraynard/status/1329700178891333634?s=20. This Complaint includes
a copy of his posting as Exhibit 103.
Case 2:20-cv-13134-LVP-RSW ECF No. 1, PageID.38 Filed 11/25/20 Page 38 of 75
39
reflected in the data are “4 spikes totaling 384,733 ballots allegedly processed in a combined
interval of 2 hour[s] and 38 minutes” for four precincts/townships in four Michigan counties
(Wayne, Oakland, Macomb ne and Kent). Id. Based on Mr. Ramsland’s analysis of the voting
machines available at the referenced locations, he determined that the maximum processing
capability during this period was only 94,867 ballots, so that “there were 289,866 more ballots
processed in the time available for processing in the four precincts/townships, than there was
processing capacity.” Id. This amount is alone is nearly twice the number of ballots by which
Biden purportedly leads President Trump (i.e., approximately 154,180).