COUNT V
MICHIGAN STATUTORY ELECTION LAW VIOLATIONS
191. Plaintiffs refer to and incorporate by reference each of the prior
paragraphs of this Complaint as though the same were repeated at length herein
Violation of MCL 168.765a.
192. Absent voter ballots must only be counted when “at all times” there is “at least 1
election inspector from each major political party.” MCL 168.765a.
193. Per eyewitness accounts described in this Complaint and its attached sworn
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affidavits, Defendants habitually and systematically disallowed election inspectors from the
Republican party, including Plaintiff, to be present in the voter counting place and refused
access to election inspectors from the Republican party, including Plaintiff, to be within a
closeenoughdistancefromtheabsentvoterballotstobeabletoseeforwhomtheballotswerecast.
See generally supra Section II.A., Paragraphs56-75.
194. Defendants refused entry to official election inspectors from the Republican
party, including Plaintiff, into the counting place to observe the counting of absentee voter
ballots. Defendants even physically blocked and obstructed election inspectors from the
Republicanparty,includingPlaintiff,byadheringlargepiecesofcardboardtothetransparent glass
doors so the counting of absent voter ballots was notviewable.
Violation of MCL 168.733
195. MCL 168.733requires sets forth the procedures for election challengers and the
powers of election inspectors. See generally supra Paragraph 39.
196. Per eyewitness accounts described in this Complaint and its attached sworn
affidavits, Defendants habitually and systematically failed to provide space for election
inspectors from the Republican party, including Plaintiff, to observe election procedure,
failed to allow the inspection of poll books, failed to share the names of the electors being
entered in the poll books, failed to allow the examination of each ballot as it was being
counted, and failed to keep records of obvious and observedfraud.See generally supra
Section II.A., Paragraphs 56-75.
197. Pollchallengers,includingPlaintiff,observedelectionworkersandsupervisors
writing on ballots themselves to alter them, apparently manipulating spoiled ballots by hand
and then counting the ballots as valid, counting the same ballot more than once, adding
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information to incomplete affidavits accompanying absentee ballots, counting absentee
ballots returned late, counting unvalidated and unreliable ballots, and counting the ballots of
“voters”whohadnorecordedbirthdatesandwerenotregisteredintheState’sQualifiedVoter File
or on any Supplemental voterlists.
Violation of Michigan Law on absentee ballots
Violation of MCL 168.765(5) and 168.764a
198. Michigan election law, MCL 168.765(5), requires Defendants to post the
specific absentee voting information anytime an election is conducted which involves a state
or federal office, in particular, the number of absentee ballots distributed to absent voters.
199. Upon information and belief, Defendants failed to post by 8:00 a.m. on
Election Day the number of absentee ballots distributed to absent voters and failed to post
before 9:00 p.m. the number of absent voters returned before on Election Day.
200. Per Michigan Election law, all absentee voter ballots must be returned to the
clerk before polls close at 8pm. MCL 168.764a. Any absentee voter ballots received by the
clerk after the close of the polls on election day will not be counted.
201. Michigan allows for early counting of absentee votes prior to the closings of
the polls for large jurisdictions, such as the City of Detroit and Wayne County.
202. Upon information and belief, receiving tens of thousands additional absentee
ballots in the early morning hours after election day and after the counting of the absentee ballots
had concluded, without proper oversight, with tens of thousands of ballots attributed to just one
candidate, Joe Biden, indicates Defendants failed to follow proper electionprotocol.See generally
supra Section II.B.1, Paragraphs 77-78