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.
The infamous 6,000-vote “glitch”
D. “Red Flags” in Dominion’s Michigan Results for 2020 General
Election Demonstrate Dominion Manipulated Election Results, and
that the Number of Illegal Votes Is Nearly Twice As Great as Biden’s
Purported Margin of Victory.
127. The expert witness testimony of Russell James Ramsland, Jr. (“Ramsland
Affidavit”)11analyzes several “red flags” in Dominion’s Michigan results for the 2020 election,
and flaws in the system architecture more generally, to conclude that Dominion manipulated
election results. Dominion’s manipulation of election results enabled Defendants to engage in
further voting fraud violations above and beyond the litany of violations recited above in Section
II.A through Section II.C.
1. Antrim County “Glitch” Was Not “Isolated Error” and May Have
Affected Other Counties.
128. The first red flag is the Antrim County, Michigan “glitch” that switched 6,000
Trump ballots to Biden, and that was only discoverable through a manual hand recount. See
supra Paragraph 94. The “glitch” was later attributed to “clerical error” by Dominion and
Antrim Country, presumably because if it were correctly identified as a “glitch”, “the system
would be required to be ‘recertified’ according to Dominion officials. This was not done.” Exh.
104, Ramsland Aff. at ¶10. Mr. Ramsland is skeptical because “the problem most likely did
occur due to a glitch where an update file did not properly synchronize the ballot barcode
generation and reading portions of the system.” Id. Further, such a glitch would not be an
10 See Texas Analysis of February 15, 2019 from the Voting Systems Examiner to the Director
of Elections (emphasis added).
11As detailed in the Ramsland Affidavit and the CV attached thereto, Mr. Ramsland is a member
of the management team Allied Security Operations Group, LLC (“ASOG”), a firm specializing
in cybersecurity, OSINT and PEN testing of networks for election security and detecting election
fraud through tampering with electronic voting systems.
Case 2:20-cv-13134-LVP-RSW ECF No. 1, PageID.43 Filed 11/25/20 Page 43 of 75
44
“isolated error,” as it “would cause entire ballot uploads to read as zero in the tabulation
batch, which we also observed happening in the data (provisional ballots were accepted
properly but in-person ballots were being rejected (zeroed out and/or changed (flipped)).” Id.
Accordingly, Mr. Ramsland concludes that it is likely that other Michigan counties using
Dominion may “have the same problem.” Id.