The receptionist has an insatiable need for attention.
Am I correct, the Trumper’s now quietly admit
- Thread starter Jarod
- Start date
countryboy
Verified User
That's not what the hive is swarming about.
FBI search of Georgia offices tied to probe of possible 2020 election 'defects,' affidavit says
An FBI search of the elections hub in Fulton County, Ga., is part of an investigation into alleged “deficiencies or defects” in the vote count in the 2020 contest lost by President Trump, according to an affidavit unsealed Tuesday
www.latimes.com
There was MASSIVE fraud in Georgia and the hive is rightly frightened about how this will be used against them in the midterms.
ROFLMAO. It seems you are so deep in your cult you don't understand how the law works. Courts have to power to interpret laws. The courts didn't change election laws.
I am curious how Georgia and Wisconsin had DEMOCRAT controlled courts. If all those elections violated the US Constitution, why was it never decided by the USSC? It seems as a good little cult member you just want to ignore reality and live in your delusions.
You Disciples of Epstein said for years there was no fraud in the 2020 selection of Obama's avatar Joe. Now we have uncovered MASSIVE fraud in Fulton County, GA - the SAME Fulton County that tried to stop the election entirely by throwing the opposition candidate in prison.
Do you have a reason for this, yet another stupid OP?
The 2020 election is over and ironically, had Trump won, you moonbats would be rid of him and on to saving the planet.
Why would your delusions make anyone not near you nervous? Are the people around you worried about your cult delusions?
It will be interesting in the next couple of weeks to see what the courts say about Georgia since the affidavit and search warrant appear to be legally invalid.
You should probably see a health care professional. Your delusions seem to be consuming you.
Where is this fraud you discovered? Can you link to it so we can confirm you aren't delusional?
Hint - the search warrant doesn't prove fraud. If anything the affidavit proves the search warrant is based on speculation and not any actual evidence.
ROFLMAO.That's not what the hive is swarming about.
FBI search of Georgia offices tied to probe of possible 2020 election 'defects,' affidavit says
An FBI search of the elections hub in Fulton County, Ga., is part of an investigation into alleged “deficiencies or defects” in the vote count in the 2020 contest lost by President Trump, according to an affidavit unsealed Tuesday
There was MASSIVE fraud in Georgia and the hive is rightly frightened about how this will be used against them in the midterms.
I guess you just proved that Trump violated national security laws and committed obstruction since you think a search warrant proves the crime.
ROFLMAO The Court system DOES not have the Constitutional authority change election laws you moron.
41. Pennsylvania has 20 electoral votes,with a statewide vote tally currently estimated at3,363,951 for President Trump and 3,445,548 forformer Vice President Biden, a margin of 81,597 votes.
42. The number of votes affected by thevarious constitutional violations exceeds the marginof votes separating the candidates.
43. Pennsylvania’s Secretary of State, KathyBoockvar, without legislative approval, unilaterallyabrogated several Pennsylvania statutes requiringsignature verification for absentee or mail-in ballots.Pennsylvania’s legislature has not ratified thesechanges, and the legislation did not include aseverability clause.
44. On August 7, 2020, the League of WomenVoters of Pennsylvania and others filed a complaintagainst Secretary Boockvar and other local electionofficials, seeking “a declaratory judgment thatPennsylvania existing signature verificationprocedures for mail-in voting” were unlawful for anumber of reasons. League of Women Voters ofPennsylvania v. Boockvar, No. 2:20-cv-03850-PBT,(E.D. Pa. Aug. 7, 2020).
45. The Pennsylvania Department of Statequickly settled with the plaintiffs, issuing revisedguidance on September 11, 2020, stating in relevantpart: “The Pennsylvania Election Code does not 15authorize the county board of elections to set asidereturned absentee or mail-in ballots based solely onsignature analysis by the county board of elections.”
46. This guidance is contrary toPennsylvania law. First, Pennsylvania Election Codemandates that, for non-disabled and non-militaryvoters, all applications for an absentee or mail-inballot “shall be signed by the applicant.” 25 PA. STAT.§§ 3146.2(d) & 3150.12(c). Second, Pennsylvania’svoter signature verification requirements areexpressly set forth at 25 PA. STAT. 350(a.3)(1)-(2) and§ 3146.8(g)(3)-(7).
47. The Pennsylvania Department of State’sguidance unconstitutionally did away withPennsylvania’s statutory signature verificationrequirements. Approximately 70 percent of therequests for absentee ballots were from Democratsand 25 percent from Republicans. Thus, thisunconstitutional abrogation of state election lawgreatly inured to former Vice President Biden’sbenefit.
48. In addition, in 2019, Pennsylvania’slegislature enacted bipartisan election reforms, 2019Pa. Legis. Serv. Act 2019-77, that set inter alia adeadline of 8:00 p.m. on election day for a countyboard of elections to receive a mail-in ballot. 25 PA.STAT. §§ 3146.6(c), 3150.16(c). Acting under agenerally worded clause that “Elections shall be freeand equal,” PA. CONST. art. I, § 5, cl. 1, a 4-3 majorityof Pennsylvania’s Supreme Court in Pa. DemocraticParty v. Boockvar, 238 A.3d 345 (Pa. 2020), extendedthat deadline to three days after Election Day andadopted a presumption that even non-postmarkedballots were presumptively timely.1649. Pennsylvania’s election law also requiresthat poll-watchers be granted access to the opening,counting, and recording of absentee ballots: “Watchersshall be permitted to be present when the envelopescontaining official absentee ballots and mail-in ballotsare opened and when such ballots are counted andrecorded.” 25 PA. STAT. § 3146.8(b). Local electionofficials in Philadelphia and Allegheny Countiesdecided not to follow 25 PA. STAT. § 3146.8(b) for theopening, counting, and recording of absentee andmail-in ballots.
50. Prior to the election, Secretary Boockvarsent an email to local election officials urging them toprovide opportunities for various persons—includingpolitical parties—to contact voters to “cure” defectivemail-in ballots. This process clearly violated severalprovisions of the state election code.• Section 3146.8(a) requires: “The county boards ofelection, upon receipt of official absentee ballots insealed official absentee ballot envelopes asprovided under this article and mail-in ballots asin sealed official mail-in ballot envelopes asprovided under Article XIII-D,1 shall safely keepthe ballots in sealed or locked containers untilthey are to be canvassed by the county board ofelections.”• Section 3146.8(g)(1)(ii) provides that mail-inballots shall be canvassed (if they are received byeight o’clock p.m. on election day) in the mannerprescribed by this subsection.• Section 3146.8(g)(1.1) provides that the first lookat the ballots shall be “no earlier than seveno’clock a.m. on election day.” And the hour for this“pre-canvas” must be publicly announced at least 1748 hours in advance. Then the votes are countedon election day.
51. By removing the ballots for examinationprior to seven o’clock a.m. on election day, SecretaryBoockvar created a system whereby local officialscould review ballots without the properannouncements, observation, and security. Thisentire scheme, which was only followed in Democratmajority counties, was blatantly illegal in that itpermitted the illegal removal of ballots from theirlocked containers prematurely.
52. Statewide election officials and localelection officials in Philadelphia and AlleghenyCounties, aware of the historical Democrat advantagein those counties, violated Pennsylvania’s electioncode and adopted the differential standards favoringvoters in Philadelphia and Allegheny Counties withthe intent to favor former Vice President Biden. SeeVerified Complaint (Doc. No. 1), Donald J. Trump forPresident, Inc. v. Boockvar, 4:20-cv-02078-MWB (M.D.Pa. Nov. 18, 2020) at ¶¶ 3-6, 9, 11, 100-143.
53. Absentee and mail-in ballots inPennsylvania were thus evaluated under an illegalstandard regarding signature verification. It is nowimpossible to determine which ballots were properlycast and which ballots were not.
54. The changed process allowing the curingof absentee and mail-in ballots in Allegheny andPhiladelphia counties is a separate basis resulting inan unknown number of ballots being treated in anunconstitutional manner inconsistent withPennsylvania statute. Id.
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Appear to be?
ROFL
That is the hail mary the Disciples of Epstein are using. The fraud can't be denied, so the only hope of the hive is to claim that the FBI shouldn't have found the fraud.
There is nothing to suggest the courts will buy this idiocy. Even if they do - fraud has been proven - fraud on a massive scale. All the hive can do is shield the guilty (Fannie Willis) from federal prosecution.
The FACT of massive fraud is already established by the FBI.
ROFL
Sieg Heil indeed Herr Himmler.
You can't bully reality with your Nazi tactics.
Wow. I guess you don't realize that Texas is not in Pennsylvania., Texas is not in Georgia and Texas is not Michigan or Wisconsin. Bringing up a lawsuit that failed miserably only seems to prove you are in a cult.
Tell us what happened to this idiotic complaint filed by Paxton. C'mon. I'll bet you can figure it out..
Yakuda
Verified User
But caves when confronted
I see you are not able to provide us with evidence of the fraud you are claiming. It's like you are a meth addict on the street corner telling us that the aliens have taken over Trump and replaced him with a reptile.
QP!
Verified User
AHAHAHAHA.
So you have your 'i don't believe judges' excuse loaded in advance, exposing what you say below is just bullshit...
64. Georgia has 16 electoral votes, with astatewide vote tally currently estimated at 2,458,121for President Trump and 2,472,098 for former VicePresident Biden, a margin of approximately 12,670votes\.
65. The number of votes affected by thevarious constitutional violations exceeds the marginof votes dividing the candidates.
66. Georgia’s Secretary of State, BradRaffensperger, without legislative approval,unilaterally abrogated Georgia’s statute governingthe signature verification process for absentee ballots.\
67. O.C.G.A. § 21-2-386(a)(2) prohibits theopening of absentee ballots until after the polls openon Election Day: In April 2020, however, the StateElection Board adopted Secretary of State Rule 183-1-14-0.9-.15, Processing Ballots Prior to Election Day. 21That rule purports to authorize county electionofficials to begin processing absentee ballots up tothree weeks before Election Day.\
68. Georgia law authorizes and requires asingle registrar or clerk—after reviewing the outerenvelope—to reject an absentee ballot if the voterfailed to sign the required oath or to provide therequired information, the signature appears invalid,or the required information does not conform with theinformation on file, or if the voter is otherwise foundineligible to vote. O.C.G.A. § 21-2-386(a)(1)(B)-(C).
69. Georgia law provides absentee voters thechance to “cure a failure to sign the oath, an invalidsignature, or missing information” on a ballot’s outerenvelope by the deadline for verifying provisionalballots (i.e., three days after the election). O.C.G.A. §§21-2-386(a)(1)(C), 21-2-419(c)(2). To facilitate cures,Georgia law requires the relevant election official tonotify the voter in writing: “The board of registrars orabsentee ballot clerk shall promptly notify the electorof such rejection, a copy of which notification shall beretained in the files of the board of registrars orabsentee ballot clerk for at least two years.” O.C.G.A.§ 21-2-386(a)(1)(B).
70. On March 6, 2020, in Democratic Partyof Georgia v. Raffensperger, No. 1:19-cv-5028-WMR(N.D. Ga.), Georgia’s Secretary of State entered aCompromise Settlement Agreement and Release withthe Democratic Party of Georgia (the “Settlement”) tomaterially change the statutory requirements forreviewing signatures on absentee ballot envelopes toconfirm the voter’s identity by making it far moredifficult to challenge defective signatures beyond the 22express mandatory procedures set forth at GA. CODE §21-2-386(a)(1)(B).
71. Among other things, before a ballot couldbe rejected, the Settlement required a registrar whofound a defective signature to now seek a review bytwo other registrars, and only if a majority of theregistrars agreed that the signature was defectivecould the ballot be rejected but not before all threeregistrars’ names were written on the ballot envelopealong with the reason for the rejection. Thesecumbersome procedures are in direct conflict withGeorgia’s statutory requirements, as is theSettlement’s requirement that notice be provided bytelephone (i.e., not in writing) if a telephone numberis available. Finally, the Settlement purports torequire State election officials to consider issuingguidance and training materials drafted by an expertretained by the Democratic Party of Georgia.
72. Georgia’s legislature has not ratifiedthese material changes to statutory law mandated bythe Compromise Settlement Agreement and Release,including altered signature verification requirementsand early opening of ballots. The relevant legislationthat was violated by Compromise SettlementAgreement and Release did not include a severabilityclause.
73. This unconstitutional change in Georgialaw materially benefitted former Vice PresidentBiden. According to the Georgia Secretary of State’soffice, former Vice President Biden had almost doublethe number of absentee votes (65.32%) as PresidentTrump (34.68%). See Cicchetti Decl. at ¶ 25, App. 7a8a.2374. The effect of this unconstitutionalchange in Georgia election law, which made it morelikely that ballots without matching signatures wouldbe counted, had a material impact on the outcome ofthe election.
75. Specifically, there were 1,305,659absentee mail-in ballots submitted in Georgia in 2020.There were 4,786 absentee ballots rejected in 2020.This is a rejection rate of .37%. In contrast, in 2016,the 2016 rejection rate was 6.42% with 13,677absentee mail-in ballots being rejected out of 213,033submitted, which more than seventeen times greaterthan in 2020. See Cicchetti Decl. at ¶ 24, App. 7a.
76. If the rejection rate of mailed-in absenteeballots remained the same in 2020 as it was in 2016,there would be 83,517 less tabulated ballots in 2020.The statewide split of absentee ballots was 34.68% forTrump and 65.2% for Biden. Rejecting at the higher2016 rate with the 2020 split between Trump andBiden would decrease Trump votes by 28,965 andBiden votes by 54,552, which would be a net gain forTrump of 25,587 votes. This would be more thanneeded to overcome the Biden advantage of 12,670votes, and Trump would win by 12,917 votes. Id.Regardless of the number of ballots affected, however,the non-legislative changes to the election rulesviolated the Electors Clause.
QP!
Verified User
Bill Barr would have been fully aware of the below and that when Trump lawyers went in to court they continually said 'we are not claiming evidence of fraud in the election', even as Trump spokespersons went on TV and said it was happening.
So you are wrong. Bill Barr would have all the time needed to allow Trumps team claiming fraud to SHOW HIM some evidence of it, and they did not.
Michigan has 16 electoral votes, with astatewide vote tally currently estimated at 2,650,695for President Trump and 2,796,702 for former VicePresident Biden, a margin of 146,007 votes. In WayneCounty, Mr. Biden’s margin (322,925 votes)significantly exceeds his statewide lead.2478. The number of votes affected by thevarious constitutional violations exceeds the marginof votes dividing the candidates.79. Michigan’s Secretary of State, JocelynBenson, without legislative approval, unilaterallyabrogated Michigan election statutes related toabsentee ballot applications and signatureverification. Michigan’s legislature has not ratifiedthese changes, and its election laws do not include aseverability clause.80. As amended in 2018, the MichiganConstitution provides all registered voters the right torequest and vote by an absentee ballot without givinga reason. MICH. CONST. art. 2, § 4.81. On May 19, 2020, however, SecretaryBenson announced that her office would sendunsolicited absentee-voter ballot applications by mailto all 7.7 million registered Michigan voters prior tothe primary and general elections. Although her officerepeatedly encouraged voters to vote absenteebecause of the COVID-19 pandemic, it did not ensurethat Michigan’s election systems and procedures wereadequate to ensure the accuracy and legality of thehistoric flood of mail-in votes. In fact, it did theopposite and did away with protections designed todeter voter fraud.82. Secretary Benson’s flooding of Michiganwith millions of absentee ballot applications prior tothe 2020 general election violated M.C.L. § 168.759(3).That statute limits the procedures for requesting anabsentee ballot to three specified ways:An application for an absent voter ballot under thissection may be made in any of the following ways
a) By a written request signed by the voter.25(b) On an absent voter ballot application formprovided for that purpose by the clerk of the city ortownship.(c) On a federal postcard application.M.C.L. § 168.759(3) (emphasis added).83. The Michigan Legislature thus declinedto include the Secretary of State as a means fordistributing absentee ballot applications. Id. §168.759(3)(b). Under the statute’s plain language, theLegislature explicitly gave only local clerks the powerto distribute absentee voter ballot applications. Id.84. Because the Legislature declined toexplicitly include the Secretary of State as a vehiclefor distributing absentee ballots applications,Secretary Benson lacked authority to distribute evena single absentee voter ballot application—much lessthe millions of absentee ballot applications SecretaryBenson chose to flood across Michigan.85. Secretary Benson also violated Michiganlaw when she launched a program in June 2020allowing absentee ballots to be requested online,without signature verification as expressly requiredunder Michigan law. The Michigan Legislature didnot approve or authorize Secretary Benson’sunilateral actions.86. MCL § 168.759(4) states in relevant part:“An applicant for an absent voter ballot shall sign theapplication. Subject to section 761(2), a clerk orassistant clerk shall not deliver an absent voter ballotto an applicant who does not sign the application.”87. Further, MCL § 168.761(2) states inrelevant part: “The qualified voter file must be used todetermine the genuineness of a signature on anapplication for an absent voter ballot”, and if “the 26signatures do not agree sufficiently or [if] thesignature is missing” the ballot must be rejected.88. In 2016 only 587,618 Michigan votersrequested absentee ballots. In stark contrast, in 2020,3.2 million votes were cast by absentee ballot, about57% of total votes cast – and more than five times thenumber of ballots even requested in 2016.89. Secretary Benson’s unconstitutionalmodifications of Michigan’s election rules resulted inthe distribution of millions of absentee ballotapplications without verifying voter signatures asrequired by MCL §§ 168.759(4) and 168.761(2). Thismeans that millions of absentee ballots weredisseminated in violation of Michigan’s statutorysignature-verification requirements. Democrats inMichigan voted by mail at a ratio of approximatelytwo to one compared to Republican voters. Thus,former Vice President Biden materially benefitedfrom these unconstitutional changes to Michigan’selection law.90. Michigan also requires that pollwatchers and inspectors have access to vote countingand canvassing. M.C.L. §§ 168.674-.675.91. Local election officials in Wayne Countymade a conscious and express policy decision not tofollow M.C.L. §§ 168.674-.675 for the opening,counting, and recording of absentee ballots.92. Michigan also has strict signatureverification requirements for absentee ballots,including that the Elections Department place awritten statement or stamp on each ballot envelopewhere the voter signature is placed, indicating thatthe voter signature was in fact checked and verified 27with the signature on file with the State. See MCL §168.765a(6).93. However, Wayne County made the policydecision to ignore Michigan’s statutory signatureverification requirements for absentee ballots. FormerVice President Biden received approximately 587,074,or 68%, of the votes cast there compared to PresidentTrump’s receiving approximate 264,149, or 30.59%, ofthe total vote. Thus, Mr. Biden materially benefitedfrom these unconstitutional changes to Michigan’selection law.94. Numerous poll challengers and anElection Department employee whistleblower havetestified that the signature verification requirementwas ignored in Wayne County in a case currentlypending in the Michigan Supreme Court.4 Forexample, Jesse Jacob, a decades-long City of Detroitemployee assigned to work in the Elections Department forthe 2020 election testified that:Absentee ballots that were received in the mail wouldhave the voter’s signature on the envelope. While Iwas at the TCF Center, I was instructed not to look atany of the signatures on the absentee ballots, and Iwas instructed not to compare the signature on theabsentee ballot with the signature on file.54 Johnson v. Benson, Petition for Extraordinary Writs &Declaratory Relief filed Nov. 26, 2020 (Mich. Sup. Ct.) at ¶¶ 71,138-39, App. 25a-51a.5 Id., Affidavit of Jessy Jacob, Appendix 14 at ¶15, attached atApp. 34a-36a.2895. The TCF was the only facility withinWayne County authorized to count ballots for the Cityof Detroit.96. These non-legislative modifications toMichigan’s election statutes resulted in a number ofconstitutionally tainted votes that far exceeds themargin of voters separating the candidates inMichigan.97. Additional public information confirmsthe material adverse impact on the integrity of thevote in Wayne County caused by theseunconstitutional changes to Michigan’s election law.For example, the Wayne County Statement of VotesReport lists 174,384 absentee ballots out of 566,694absentee ballots tabulated (about 30.8%) as countedwithout a registration number for precincts in theCity of Detroit. See Cicchetti Decl. at ¶ 27, App. 8a.The number of votes not tied to a registered voter byitself exceeds Vice President Biden’s margin of marginof 146,007 votes by more than 28,377 votes.98. The extra ballots cast most likelyresulted from the phenomenon of Wayne Countyelection workers running the same ballots through atabulator multiple times, with Republican pollwatchers obstructed or denied access, and electionofficials ignoring poll watchers’ challenges, asdocumented by numerous declarations. App. 25a-51a.99. In addition, a member of the WayneCounty Board of Canvassers (“Canvassers Board”),William Hartman, determined that 71% of Detroit’sAbsent Voter Counting Boards (“AVCBs”) wereunbalanced—i.e., the number of people who checkedin did not match the number of ballots cast—withoutexplanation. Id. at ¶ 29.29100. On November 17, 2020, the CanvassersBoard deadlocked 2-2 over whether to certify theresults of the presidential election based on numerousreports of fraud and unanswered materialdiscrepancies in the county-wide election results. Afew hours later, the Republican Board membersreversed their decision and voted to certify the resultsafter severe harassment, including threats of violence.101. The following day, the two Republicanmembers of the Board rescinded their votes to certifythe vote and signed affidavits alleging they werebullied and misled into approving election results anddo not believe the votes should be certified untilserious irregularities in Detroit votes are resolved. SeeCicchetti Decl. at ¶ 29, App. 8a.102. Regardless of the number of votes thatwere affected by the unconstitutional modification ofMichigan’s election rules, the non-legislative changesto the election rules violated the Electors Clause.
a) By a written request signed by the voter.25(b) On an absent voter ballot application formprovided for that purpose by the clerk of the city ortownship.(c) On a federal postcard application.M.C.L. § 168.759(3) (emphasis added).83. The Michigan Legislature thus declinedto include the Secretary of State as a means fordistributing absentee ballot applications. Id. §168.759(3)(b). Under the statute’s plain language, theLegislature explicitly gave only local clerks the powerto distribute absentee voter ballot applications. Id.84. Because the Legislature declined toexplicitly include the Secretary of State as a vehiclefor distributing absentee ballots applications,Secretary Benson lacked authority to distribute evena single absentee voter ballot application—much lessthe millions of absentee ballot applications SecretaryBenson chose to flood across Michigan.85. Secretary Benson also violated Michiganlaw when she launched a program in June 2020allowing absentee ballots to be requested online,without signature verification as expressly requiredunder Michigan law. The Michigan Legislature didnot approve or authorize Secretary Benson’sunilateral actions.86. MCL § 168.759(4) states in relevant part:“An applicant for an absent voter ballot shall sign theapplication. Subject to section 761(2), a clerk orassistant clerk shall not deliver an absent voter ballotto an applicant who does not sign the application.”87. Further, MCL § 168.761(2) states inrelevant part: “The qualified voter file must be used todetermine the genuineness of a signature on anapplication for an absent voter ballot”, and if “the 26signatures do not agree sufficiently or [if] thesignature is missing” the ballot must be rejected.88. In 2016 only 587,618 Michigan votersrequested absentee ballots. In stark contrast, in 2020,3.2 million votes were cast by absentee ballot, about57% of total votes cast – and more than five times thenumber of ballots even requested in 2016.89. Secretary Benson’s unconstitutionalmodifications of Michigan’s election rules resulted inthe distribution of millions of absentee ballotapplications without verifying voter signatures asrequired by MCL §§ 168.759(4) and 168.761(2). Thismeans that millions of absentee ballots weredisseminated in violation of Michigan’s statutorysignature-verification requirements. Democrats inMichigan voted by mail at a ratio of approximatelytwo to one compared to Republican voters. Thus,former Vice President Biden materially benefitedfrom these unconstitutional changes to Michigan’selection law.90. Michigan also requires that pollwatchers and inspectors have access to vote countingand canvassing. M.C.L. §§ 168.674-.675.91. Local election officials in Wayne Countymade a conscious and express policy decision not tofollow M.C.L. §§ 168.674-.675 for the opening,counting, and recording of absentee ballots.92. Michigan also has strict signatureverification requirements for absentee ballots,including that the Elections Department place awritten statement or stamp on each ballot envelopewhere the voter signature is placed, indicating thatthe voter signature was in fact checked and verified 27with the signature on file with the State. See MCL §168.765a(6).93. However, Wayne County made the policydecision to ignore Michigan’s statutory signatureverification requirements for absentee ballots. FormerVice President Biden received approximately 587,074,or 68%, of the votes cast there compared to PresidentTrump’s receiving approximate 264,149, or 30.59%, ofthe total vote. Thus, Mr. Biden materially benefitedfrom these unconstitutional changes to Michigan’selection law.94. Numerous poll challengers and anElection Department employee whistleblower havetestified that the signature verification requirementwas ignored in Wayne County in a case currentlypending in the Michigan Supreme Court.4 Forexample, Jesse Jacob, a decades-long City of Detroitemployee assigned to work in the Elections Department forthe 2020 election testified that:Absentee ballots that were received in the mail wouldhave the voter’s signature on the envelope. While Iwas at the TCF Center, I was instructed not to look atany of the signatures on the absentee ballots, and Iwas instructed not to compare the signature on theabsentee ballot with the signature on file.54 Johnson v. Benson, Petition for Extraordinary Writs &Declaratory Relief filed Nov. 26, 2020 (Mich. Sup. Ct.) at ¶¶ 71,138-39, App. 25a-51a.5 Id., Affidavit of Jessy Jacob, Appendix 14 at ¶15, attached atApp. 34a-36a.2895. The TCF was the only facility withinWayne County authorized to count ballots for the Cityof Detroit.96. These non-legislative modifications toMichigan’s election statutes resulted in a number ofconstitutionally tainted votes that far exceeds themargin of voters separating the candidates inMichigan.97. Additional public information confirmsthe material adverse impact on the integrity of thevote in Wayne County caused by theseunconstitutional changes to Michigan’s election law.For example, the Wayne County Statement of VotesReport lists 174,384 absentee ballots out of 566,694absentee ballots tabulated (about 30.8%) as countedwithout a registration number for precincts in theCity of Detroit. See Cicchetti Decl. at ¶ 27, App. 8a.The number of votes not tied to a registered voter byitself exceeds Vice President Biden’s margin of marginof 146,007 votes by more than 28,377 votes.98. The extra ballots cast most likelyresulted from the phenomenon of Wayne Countyelection workers running the same ballots through atabulator multiple times, with Republican pollwatchers obstructed or denied access, and electionofficials ignoring poll watchers’ challenges, asdocumented by numerous declarations. App. 25a-51a.99. In addition, a member of the WayneCounty Board of Canvassers (“Canvassers Board”),William Hartman, determined that 71% of Detroit’sAbsent Voter Counting Boards (“AVCBs”) wereunbalanced—i.e., the number of people who checkedin did not match the number of ballots cast—withoutexplanation. Id. at ¶ 29.29100. On November 17, 2020, the CanvassersBoard deadlocked 2-2 over whether to certify theresults of the presidential election based on numerousreports of fraud and unanswered materialdiscrepancies in the county-wide election results. Afew hours later, the Republican Board membersreversed their decision and voted to certify the resultsafter severe harassment, including threats of violence.101. The following day, the two Republicanmembers of the Board rescinded their votes to certifythe vote and signed affidavits alleging they werebullied and misled into approving election results anddo not believe the votes should be certified untilserious irregularities in Detroit votes are resolved. SeeCicchetti Decl. at ¶ 29, App. 8a.102. Regardless of the number of votes thatwere affected by the unconstitutional modification ofMichigan’s election rules, the non-legislative changesto the election rules violated the Electors Clause.103. Wisconsin has 10 electoral votes, with astatewide vote tally currently estimated at 1,610,151for President Trump and 1,630,716 for former VicePresident Biden (i.e., a margin of 20,565 votes). In twocounties, Milwaukee and Dane, Mr. Biden’s margin(364,298 votes) significantly exceeds his statewidelead.104. In the 2016 general election some146,932 mail-in ballots were returned in Wisconsinout of more than 3 million votes cast.6 In starkcontrast, 1,275,019 mail-in ballots, nearly a 9006 Source: U.S. Elections Project, available at:http://www.electproject.org/early_2016. 30percent increase over 2016, were returned in theNovember 3, 2020 election.7105. Wisconsin statutes guard against fraudin absentee ballots: “[V]oting by absentee ballot is aprivilege exercised wholly outside the traditionalsafeguards of the polling place. The legislature findsthat the privilege of voting by absentee ballot must becarefully regulated to prevent the potential for fraudor abuse[.]” WISC. STAT. § 6.84(1).106. In direct contravention of Wisconsin law,leading up to the 2020 general election, the WisconsinElections Commission (“WEC”) and other localofficials unconstitutionally modified Wisconsinelection laws—each time taking steps that weakened,or did away with, established security procedures putin place by the Wisconsin legislature to ensureabsentee ballot integrity.107. For example, the WEC undertook acampaign to position hundreds of drop boxes to collectabsentee ballots—including the use of unmanned dropboxes.8108. The mayors of Wisconsin’s five largestcities—Green Bay, Kenosha, Madison, Milwaukee,and Racine, which all have Democrat majorities—joined in this effort, and together, developed a planuse purportedly “secure drop-boxes to facilitate return7 Source: U.S. Elections Project, available at:https://electproject.github.io/Early-Vote-2020G/WI.html.8 Wisconsin Elections Commission Memoranda, To: AllWisconsin Election Officials, Aug. 19, 2020, available at:https://elections.wi.gov/sites/elections.wi.gov/files/2020-08/Drop Box Final.pdf. at p. 3 of 4.31of absentee ballots.” Wisconsin Safe Voting Plan 2020,at 4 (June 15, 2020).9109. It is alleged in an action recently filed inthe United States District Court for the EasternDistrict of Wisconsin that over five hundredunmanned, illegal, absentee ballot drop boxes wereused in the Presidential election in Wisconsin.10110. However, the use of any drop box,manned or unmanned, is directly prohibited byWisconsin statute. The Wisconsin legislaturespecifically described in the Election Code “Alternateabsentee ballot site” and detailed the procedure bywhich the governing body of a municipality maydesignate a site or sites for the delivery of absenteeballots “other than the office of the municipal clerk orboard of election commissioners as the location fromwhich electors of the municipality may request andvote absentee ballots and to which voted absenteeballots shall be returned by electors for any election.”Wis. Stat. 6.855(1).111. Any alternate absentee ballot site “shallbe staffed by the municipal clerk or the executivedirector of the board of election commissioners, oremployees of the clerk or the board of electioncommissioners.” Wis. Stat. 6.855(3). Likewise, Wis.9 Wisconsin Safe Voting Plan 2020 Submitted to the Centerfor Tech & Civic Life, June 15, 2020, by the Mayors of Madison,Milwaukee, Racine, Kenosha and Green Bay available at:https://www.techandciviclife.org/wp...pproved-Wisconsin-Safe-Voting-Plan2020.pdf.10 See Complaint (Doc. No. 1), Donald J. Trump, Candidate forPresident of the United States of America v. The WisconsinElection Commission, Case 2:20-cv-01785-BHL (E.D. Wisc. Dec.2, 2020) (Wisconsin Trump Campaign Complaint”) at ¶¶ 188-89.32Stat. 7.15(2m) provides, “n a municipality in whichthe governing body has elected to an establish analternate absentee ballot sit under s. 6.855, themunicipal clerk shall operate such site as though itwere his or her office for absentee ballot purposes andshall ensure that such site is adequately staffed.”
112. Thus, the unmanned absentee ballotdrop-off sites are prohibited by the WisconsinLegislature as they do not comply with Wisconsin lawexpressly defining “[a]lternate absentee ballot site”.Wis. Stat. 6.855(1), (3).113. In addition, the use of drop boxes for thecollection of absentee ballots, positionedpredominantly in Wisconsin’s largest cities, is directlycontrary to Wisconsin law providing that absenteeballots may only be “mailed by the elector, or deliveredin person to the municipal clerk issuing the ballot orballots.” Wis. Stat. § 6.87(4)(b)1 (emphasis added).114. The fact that other methods of deliveringabsentee ballots, such as through unmanned dropboxes, are not permitted is underscored by Wis. Stat.§ 6.87(6) which mandates that, “[a]ny ballot notmailed or delivered as provided in this subsection maynot be counted.” Likewise, Wis. Stat. § 6.84(2)underscores this point, providing that Wis. Stat. §6.87(6) “shall be construed as mandatory.” Theprovision continues—“Ballots cast in contravention ofthe procedures specified in those provisions may notbe counted. Ballots counted in contravention of theprocedures specified in those provisions may not beincluded in the certified result of any election.” Wis.Stat. § 6.84(2) (emphasis added).115. These were not the only Wisconsinelection laws that the WEC violated in the 2020 33general election. The WEC and local election officialsalso took it upon themselves to encourage voters tounlawfully declare themselves “indefinitelyconfined”—which under Wisconsin law allows thevoter to avoid security measures like signatureverification and photo ID requirements.116. Specifically, registering to vote byabsentee ballot requires photo identification, exceptfor those who register as “indefinitely confined” or“hospitalized.” WISC. STAT. § 6.86(2)(a), (3)(a).Registering for indefinite confinement requirescertifying confinement “because of age, physicalillness or infirmity or [because the voter] is disabledfor an indefinite period.” Id. § 6.86(2)(a). Shouldindefinite confinement cease, the voter must notifythe county clerk, id., who must remove the voter fromindefinite-confinement status. Id. § 6.86(2)(b).117. Wisconsin election procedures for votingabsentee based on indefinite confinement enable thevoter to avoid the photo ID requirement and signaturerequirement. Id. § 6.86(1)(ag)/(3)(a)(2).118. On March 25, 2020, in clear violation ofWisconsin law, Dane County Clerk Scott McDonnelland Milwaukee County Clerk George Christensenboth issued guidance indicating that all voters shouldmark themselves as “indefinitely confined” because ofthe COVID-19 pandemic.119. Believing this to be an attempt tocircumvent Wisconsin’s strict voter ID laws, theRepublican Party of Wisconsin petitioned theWisconsin Supreme Court to intervene. On March 31,2020, the Wisconsin Supreme Court unanimouslyconfirmed that the clerks’ “advice was legallyincorrect” and potentially dangerous because “voters 34may be misled to exercise their right to vote in waysthat are inconsistent with WISC. STAT. § 6.86(2).”120. On May 13, 2020, the Administrator ofWEC issued a directive to the Wisconsin clerksprohibiting removal of voters from the registry forindefinite-confinement status if the voter is no longer“indefinitely confined.”121. The WEC’s directive violated Wisconsinlaw. Specifically, WISC. STAT. § 6.86(2)(a) specificallyprovides that “any [indefinitely confined] elector [who]is no longer indefinitely confined … shall so notify themunicipal clerk.” WISC. STAT. § 6.86(2)(b) furtherprovides that the municipal clerk “shall remove thename of any other elector from the list upon requestof the elector or upon receipt of reliable informationthat an elector no longer qualifies for the service.”122. According to statistics kept by the WEC,nearly 216,000 voters said they were indefinitelyconfined in the 2020 election, nearly a fourfoldincrease from nearly 57,000 voters in 2016. In Daneand Milwaukee counties, more than 68,000 voterssaid they were indefinitely confined in 2020, a fourfoldincrease from the roughly 17,000 indefinitely confinedvoters in those counties in 2016.123. Under Wisconsin law, voting by absenteeballot also requires voters to complete a certification,including their address, and have the envelopewitnessed by an adult who also must sign and indicatetheir address on the envelope. See WISC. STAT. § 6.87.The sole remedy to cure an “improperly completedcertificate or [ballot] with no certificate” is for “theclerk [to] return the ballot to the elector[.]” Id. §6.87(9). “If a certificate is missing the address of a 35witness, the ballot may not be counted.” Id. § 6.87(6d)(emphasis added).124. However, in a training video issued April1, 2020, the Administrator of the City of MilwaukeeElections Commission unilaterally declared that a“witness address may be written in red and that isbecause we were able to locate the witnesses’ addressfor the voter” to add an address missing from thecertifications on absentee ballots. The Administrator’sinstruction violated WISC. STAT. § 6.87(6d). The WECissued similar guidance on October 19, 2020, inviolation of this statute as well.125. In the Wisconsin Trump CampaignComplaint, it is alleged, supported by the swornaffidavits of poll watchers, that canvas workerscarried out this unlawful policy, and acting pursuantto this guidance, in Milwaukee used red-ink pens toalter the certificates on the absentee envelope andthen cast and count the absentee ballot. These actsviolated WISC. STAT. § 6.87(6d) (“If a certificate ismissing the address of a witness, the ballot may notbe counted”). See also WISC. STAT. § 6.87(9) (“If amunicipal clerk receives an absentee ballot with animproperly completed certificate or with no certificate,the clerk may return the ballot to the elector . . .whenever time permits the elector to correct the defectand return the ballot within the period authorized.”).126. Wisconsin’s legislature has not ratifiedthese changes, and its election laws do not include aseverability clause.127. In addition, Ethan J. Pease, a box truckdelivery driver subcontracted to the U.S. PostalService (“USPS”) to deliver truckloads of mail-inballots to the sorting center in Madison, WI, testified 36that USPS employees were backdating ballotsreceived after November 3, 2020. Decl. of Ethan J.Pease at ¶¶ 3-13. Further, Pease testified how asenior USPS employee told him on November 4, 2020that “[a]n order came down from theWisconsin/Illinois Chapter of the Postal Service that100,000 ballots were missing” and how the USPSdispatched employees to “find[] . . . the ballots.” Id. ¶¶8-10. One hundred thousand ballots supposedly“found” after election day would far exceed formerVice President Biden margin of 20,565 votes overPresident Trump.COUNT I: ELECTORS CLAUSE128. Plaintiff State repeats and re-alleges theallegations above, as if fully set forth herein.129. The Electors Clause of Article II, Section1, Clause 2, of the Constitution makes clear that onlythe legislatures of the States are permitted todetermine the rules for appointing presidentialelectors. The pertinent rules here are the stateelection statutes, specifically those relevant to thepresidential election.130. Non-legislative actors lack authority toamend or nullify election statutes. Bush II, 531 U.S.at 104 (quoted supra).131. Under Heckler v. Chaney, 470 U.S. 821,833 n.4 (1985), conscious and express executivepolicies—even if unwritten—to nullify statutes or toabdicate statutory responsibilities are reviewable tothe same extent as if the policies had been written oradopted. Thus, conscious and express actions by Stateor local election officials to nullify or ignorerequirements of election statutes violate the Electors 37Clause to the same extent as formal modifications byjudicial officers or State executive officers.132. The actions set out in Paragraphs 41-128constitute non-legislative changes to State electionlaw by executive-branch State election officials, or byjudicial officials, in Defendant States Pennsylvania,Georgia, Michigan, and Wisconsin, in violation of theElectors Clause.133. Electors appointed to Electoral Collegein violation of the Electors Clause cannot castconstitutionally valid votes for the office of President.