I'm going to attempt to weigh in here and see if anything is going to penetrate the hand recount audit done by the state of Georgia. Here is the portion of the complaint you mention. I have bolded certain parts for emphasis:
The scheme and artifice to defraud was for the purpose of illegally and fraudulently manipulating the vote count to make certain the election of Joe Biden as President of the United States.
3.
The fraud was executed by many means, but the most fundamentally troubling, insidious, and egregious is the systemic adaptation of old-fashioned “ballot-stuffing.” It has now been amplified and rendered virtually invisible by computer software created and run by domestic and foreign actors for that very purpose. Mathematical and statistical anomalies rising to the level of impossibilities, as shown by affidavits of multiple witnesses, documentation, and expert testimony evince this scheme across the state of Georgia.
Especially egregious conduct arose in Forsyth, Paulding, Cherokee, Hall, and Barrow County. This scheme and artifice to defraud affected tens of thousands of votes in Georgia alone and “rigged” the election in Georgia for Joe Biden.
The above indicates that the listed counties had their vote tallies "rigged" by "computer software created and run by domestic and foreign actors".
I hope we can reasonably agree that the number of paper ballots created by the system matches the number of voters on record who appeared in person or voted by absentee ballot. This would have been verified by the canvass. The complaint doesn't suggest that poll workers replaced or added fraudulent ballots, but that the electronic counting and reporting was manipulated secretly and behind the scenes with no one at the polling stations even being aware of the fraud.
I looked at the hand recount results for each of the listed "egregious" counties (results and link below). Apparently the complaint intends to produce reporting results by the Dominion system that appear statistically impossible for these counties. The result reported is claimed to have been secretly manipulated behind the scenes and only exposed by these impossible statistics.
Georgia's Dominion voting system produces a paper ballot at the voting machine and the voter is asked to verify the selections on the machine to the printed ballot. I have not seen even one report of someone reporting a misrepresented ballot, at least as is visibly marked and checked by the voter. Later in the complaint, the argument is made that:
The new election system depends on voters to verify the printed text of their choices on their ballots, a step that many voters might not take. The State Election Board hasn't yet created regulations for how recounts and audits will be conducted. And paper ballots embed selections in bar codes that are only readable by scanning machines, leaving Georgians uncertain whether the bar codes match their votes.
Well, maybe, but like I said, this has not been reported at all as far as I know, and certainly not widely reported. I voted in Georgia and I had no problem validating my selections. Also, note that even though the selections might be represented by bar codes for the scanner to see, a hand recount audit relies on the selections that the voter certifies as representing their choices. To me, this is where the claim in the "Kraken" completely falls apart.
In the hand recount audit, what the voter saw on the ballot is what the auditors used to hand tabulate the results of the election. Thus, every ballot was examined and determined to be a vote for Biden or a vote for Trump. In addition, the number of paper ballots was also confirmed.
You can look at the results here. But for the "egregious" counties, here are the results:
Barrow County: In the hand recount audit which was tabulated by hand and not machine, the totals of ballots, votes for Biden, and votes for Trump exactly matched the totals from the Dominion system.
Cherokee County: The totals of ballots were 3 less in the audit, votes for Biden, and votes for Trump were 10 votes difference from the Dominion system. +10 Trump.
Forsyth County: The totals of ballots were 10 less in the audit, votes for Biden, and votes for Trump were 65 votes difference from the Dominion system. +65 Trump.
Hall County: The totals of ballots were 120 more in the audit, votes for Biden, and votes for Trump were 46 votes difference from the Dominion system. +46 Trump.
Paulding County: The totals of ballots were 38 less in the audit, votes for Biden, and votes for Trump were 10 votes difference from the Dominion system. +10 Trump.
For all Counties and the full audit, Trump picked up 496 votes. The majority of these were from mistakes made and discovered in the audit which had nothing to do with the tabulation machines. The hand recount audit of 100% of the paper ballots in Georgia produces an "impossible statistic" of a different kind than that argued in the complaint. The hand recount audit shows agreement to the reported totals by the Dominion system used to tabulate the vote totals.
My conclusion is that since the lawsuit appears to make the Dominion voting system the "centerpiece" of the fraud, and since the state of Georgia has already proven that the reported election totals by Dominion match that of the hand recount audit, then the whole thing will easily be tossed and found frivolous.
When the complaint goes so far as to say that foreign actors manipulated Georgia's vote totals and ignores the paper ballot trail and hand recount audit of the same, then it doesn't seem to me that things are going to go well for other points like the 96,000 absentee ballots that should be rejected. We can hope those claims have some validity and impact, but when you take the centerpiece away, I don't think it lends much credibility to the rest.
Link to "Historic First Statewide Audit Of Paper Ballots Upholds Result Of Presidential Race"
This is certainly not a great argument to be making. All 5 of thos counties were won by Trump overwhelmingly. 43%, 39%, 33%, 43%, and 29% respectively. Is she asking to have those votes overturned?