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).
More Michigan Bullnost
B. The Pattern Of Incidents Shows An Absence Of Mistake - Always In
The Favor Of Biden.
118. Rules of Evidence, 404(b), applicable to civil matters makes clear that,
(b) Evidence of other crimes, wrongs, or acts shall not be admissible to prove the
character of a person in order to show action in conformity therewith. It may,
however, be admissible for other purposes, including, but not limited to,
proof of motive, opportunity, intent, preparation, plan, knowledge, identity,
or absence of mistake or accident.
119. Tabulator issues and election violations occurred elsewhere in Michigan
reflecting a pattern, where multiple incidents occurred. In Oakland County, votes flipped a seat
to an incumbent Republican, Adam Kochenderfer, from the Democrat challenger when
7 https://www.michigan.gov/documents/sos/Antrim_Fact_Check_707197_7.pdf (emphasis in original).
Case 2:20-cv-13134-LVP-RSW ECF No. 1, PageID.40 Filed 11/25/20 Page 40 of 75
41
120. “A computer issue in Rochester Hills caused them to send us results for seven
precincts as both precinct votes and absentee votes. They should only have beensent to us as
absentee votes,” Joe Rozell, Oakland County Director of Elections for the City of Huntington
Woods, said.8
121. This Oakland County flip of votes is significant not only because it reflects a
second systems error wherein both favored the Democrats, precinct votes were sent out to be
counted, and they were counted twice as a result until the error was caught on a recount, but
precinct votes should never be counted outside of the precinct, instead they are required to be
sealed in the precinct.
BookmarQing this:
“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).”