Carol Kelly

Pa. and Ga. are bad but they’re not the only ones. We will win, just be calm and carry on, as the British say.

Radiance3

=================
There is a chance that PA, WI, MI, and GA could go to the president. Massive evidence has Sidney Powel to present to the SC.
I don't know why I feel as if I don't like the SC. I hope they do the right decision, when those 4 states are presented.

Blade_Runner Loc: DARK SIDE OF THE MOON

Apart from an apparent complete ignorance of how civil litigation works in the American court system, specifically evidence FOLLOWS discovery, it is astonishing how easily the power brokers and propaganda arm of the Progressive Socialist movement have dumbed down their collective masses into believing they are incapable of committing v***r f***d.

Over 300 sworn affidavits by e******n employees under penalty of perjury have revealed instances of v***r f***d large and small - from a citizen's discovery of a garbage bag in a dumpster filled with v****g machine printouts of b****ts marked for president Trump to the history of the D******n v**er system and Smartmatic software and how the algorithms were manipulated to alter or change v**es. At present, 3 D******n employees involved in the process have sworn affidavits to that effect.

Statisticians are among those who swore affidavits stating the statistical impossibility of president Trump's 700,000+ lead in PA on e******n night falling to 10,000 v**es behind in less than 4 hours.

Two examples of filings out of hundreds:

(NOTE: in these two cases, Chief Judge Kenny failed to follow civil court procedure by disallowing expedited discovery and summarily dismissing the cases.

Judge Kenny denied the motion for preliminary relief stating that the plaintiffs' "interpretation of events is incorrect and not credible", with plaintiffs not fully comprehending the "absentee b****t tabulation process".)

You don't have to have sworn affidavits to file in civil court, and you certainly don't have to have a ton of evidence. The argument is, "On a reasonable basis in fact and law, I have enough information here to make an allegation, and we want the opportunity to pursue our law suit and conduct discovery - written discovery, document demands, depositions, witness lists, and we want this done quickly."
At this point, you can in fact get subpoenas.

Michigan: Constantino et al v. City of Detroit et al

November 9, 2020, Wayne County Michigan.

State of Michigan Third Judicial Circuit Court for the County of Wayne.
Circuit Court Judge Timothy Kenny Chief Judge Third Judicial Circuit Court of Michigan.

Plaintiff: CHERYL A. COSTANTINO and EDWARD P. McCALL, Jr.,

Plaintiff Attorney: David A. Kallman (P34200) Erin E. Mersino (P70886) Jack C. Jordan (P46551) Stephen P. Kallman (P75622) GREAT LAKES JUSTICE CENTER.

Case No. 20-014780-AW

V***r F***d, V**er Integrity, Plaintiffs alleged e******n f***d, seeking to prevent the e******n results of Detroit and Wayne County from being certified.

Defendant: CITY OF DETROIT; DETROIT E******N COMMISSION; JANICE M. WINFREY, in her official capacity as the CLERK OF THE CITY OF DETROIT and the Chairperson of the DETROIT E******N COMMISSION; CATHY M. GARRETT, in her official capacity as the CLERK OF WAYNE COUNTY; and the WAYNE COUNTY BOARD OF CANVASSERS.

To wit:
1. The e******n was held on November 3, 2020 and approximately 850,000 v**es were
reported as cast in Wayne County, Michigan.

2. Plaintiff brings this action to raise numerous issues of fraud and misconduct that
occurred in order to protect the rights of all v**ers in Michigan, especially Wayne County.

3.In summary, this Complaint raises numerous instances of fraud, including, but not limited to:

* Defendants systematically processed and counted b****ts from v**ers whose name
failed to appear in either the Qualified V**er File (QVF) or in the supplemental
sheets. When v**er’s name could not be found, the e******n worker assigned the
b****t to random name already in the QVF to person who had not v**ed.

* Defendants instructed e******n workers to not verify signatures on absentee b****ts,
to backdate absentee b****ts, and to process such b****ts regardless of their validity.

* After e******n officials announced the last absentee b****ts had been received,
another batch of unsecured and unsealed b****ts, without envelopes, arrived in trays
at the TCF Center. There were tens of thousands of these absentee b****ts, and
apparently every b****t was counted and attributed only to Democratic candidates.

* Defendants instructed e******n workers to process b****ts that appeared after the
e******n deadline and to falsely report that those b****ts had been received prior to
November 3, 2020 deadline - i.e., change the date on the b****t.

* Defendants systematically used false information to process b****ts, such as using
incorrect or false birthdays. Many times, the e******n workers inserted new names
into the QVF after the e******n and recorded these new v**ers as having birthdate
0f 1/ 1/ 900.

* On daily basis leading up to the e******n, City of Detroit e******n workers and
employees coached v**ers to v**e for Joe Biden and the Democrat party. These
workers and employees encouraged v**ers to do straight Democrat b****t. These
e******n workers and employees went over to the v****g booths with v**ers in order
to watch them v**e and coach them for whom to v**e.

* Unsecured b****ts arrived at the TCF Center loading garage, not in sealed b****t
boxes, without any chain of custody, and without envelopes.

* Defendant e******n officials and workers refused to record challenges to their
processes and removed challengers from the site if they politely voiced challenge.

After poll challengers started discovering the fraud taking place at the TCF Center,
Defendant e******n officials and workers locked credentialed challengers out of the
counting room so they could not observe the process, during Which time tens of
thousands of b****ts were processed.

* Defendant e******n officials and workers allowed b****ts to be duplicated by hand
without allowing poll challengers to check if the duplication was accurate. In fact,
e******n officials and workers repeatedly obstructed poll challengers from
observing. Defendants permitted thousands of b****ts to be filled out by hand and
duplicated on site without oversight from poll challengers.


Michigan: Stoddard v. City E******n Commission of the City of Detroit

November 4, 2020

State of Michigan Third Judicial Circuit Court for the County of Wayne.
Circuit Court Judge Timothy Kenny Chief Judge Third Judicial Circuit Court of Michigan.

Plaintiff: Sarah Stoddard and E******n Integrity Fund.

Plaintiff Attorney: Edward D. Greim (pro hac forthcoming) Special Counsel, Thomas More Society
Missouri Bar No. 54034, GRAVES GARRETT, LLC. Ian A. Northon (P65082) RHOADES MCKEE PC

Case No. 20-014604-CZ

V***r F***d, V**er Integrity, Plaintiffs, a Michigan poll observer and a nonprofit organization, allege that absentee v**e count centers in Detroit do not have one inspector from each political party present, in violation of state law. Plaintiffs seek to halt the counting of absentee b****ts until observers from both parties are present.

To wit:

1. This lawsuit challenges the ongoing action of the City E******n Commission of the City of Detroit and the Detroit City Clerk with respect to one-party control of the Absent V**er Counting Board (“AVCB”) operating out of TCF Center (formerly known as Cobo Hall).

Specifically, individual inspectors from a single major political party are “curing” rejected absentee b****ts – those absentee b****ts that cannot be properly read by the electronic counting machine -- including t***sposing the v**er’s perceived choices onto a new b****t, without the required oversight and signatures of two e******n inspectors—one from each major political party. These rejected absentee b****ts are reviewed by only one inspector, in most cases a Democratic inspector, who then unilaterally decides how the v**er intended to v**e and creates a b****t that can be read reflecting the inspector’s unilateral decision.

2. This violates MCL 168.765a (10), which requires one inspector from each party to be present at the AVCB. It also violates the Secretary of State’s rule, as set forth in her controlling E******n Officials’ Manual, requiring that any cured b****t bear the signature of two e******n inspectors who have expressed a preference for different political parties. See 168.765a(13). In application, this arrangement in the TCF Center fails to comply with Michigan law and invites fraud.

3. This action seeks an order: (a) halting further “curing” of absentee b****ts rejected by the counting machines until one inspector from each party is present to observe the cure and sign the cured b****t; and (b) segregating the rejected and cured b****ts; and (c) halting certification until the statutorily-required inspectors can be located and used to ensure e******n integrity.

eagleye13 Loc: Fl

"Apart from an apparent complete ignorance of how civil litigation works in the American court system, specifically evidence FOLLOWS discovery, it is astonishing how easily the power brokers and propaganda arm of the Progressive Socialist movement have dumbed down their collective masses into believing they are incapable of committing v***r f***d.

Over 300 sworn affidavits by e******n employees under penalty of perjury have revealed instances of v***r f***d large and small - from a citizen's discovery of a garbage bag in a dumpster filled with v****g machine printouts of b****ts marked for president Trump to the history of the D******n v**er system and Smartmatic software and how the algorithms were manipulated to alter or change v**es. At present, 3 D******n employees involved in the process have sworn affidavits to that effect.

Statisticians are among those who swore affidavits stating the statistical impossibility of president Trump's 700,000+ lead in PA on e******n night falling to 10,000 v**es behind in less than 4 hours.

Two examples of filings out of hundreds:

(NOTE: in these two cases, Chief Judge Kenny failed to follow civil court procedure by disallowing expedited discovery and summarily dismissing the cases.

Judge Kenny denied the motion for preliminary relief stating that the plaintiffs' "interpretation of events is incorrect and not credible", with plaintiffs not fully comprehending the "absentee b****t tabulation process".)

You don't have to have sworn affidavits to file in civil court, and you certainly don't have to have a ton of evidence. The argument is, "On a reasonable basis in fact and law, I have enough information here to make an allegation, and we want the opportunity to pursue our law suit and conduct discovery - written discovery, document demands, depositions, witness lists, and we want this done quickly."
At this point, you can in fact get subpoenas.

Michigan: Constantino et al v. City of Detroit et al

November 9, 2020, Wayne County Michigan.

State of Michigan Third Judicial Circuit Court for the County of Wayne.
Circuit Court Judge Timothy Kenny Chief Judge Third Judicial Circuit Court of Michigan.

Plaintiff: CHERYL A. COSTANTINO and EDWARD P. McCALL, Jr.,

Plaintiff Attorney: David A. Kallman (P34200) Erin E. Mersino (P70886) Jack C. Jordan (P46551) Stephen P. Kallman (P75622) GREAT LAKES JUSTICE CENTER.

Case No. 20-014780-AW

V***r F***d, V**er Integrity, Plaintiffs alleged e******n f***d, seeking to prevent the e******n results of Detroit and Wayne County from being certified.

Defendant: CITY OF DETROIT; DETROIT E******N COMMISSION; JANICE M. WINFREY, in her official capacity as the CLERK OF THE CITY OF DETROIT and the Chairperson of the DETROIT E******N COMMISSION; CATHY M. GARRETT, in her official capacity as the CLERK OF WAYNE COUNTY; and the WAYNE COUNTY BOARD OF CANVASSERS.

To wit:
1. The e******n was held on November 3, 2020 and approximately 850,000 v**es were
reported as cast in Wayne County, Michigan.

2. Plaintiff brings this action to raise numerous issues of fraud and misconduct that
occurred in order to protect the rights of all v**ers in Michigan, especially Wayne County.

3.In summary, this Complaint raises numerous instances of fraud, including, but not limited to:

* Defendants systematically processed and counted b****ts from v**ers whose name
failed to appear in either the Qualified V**er File (QVF) or in the supplemental
sheets. When v**er’s name could not be found, the e******n worker assigned the
b****t to random name already in the QVF to person who had not v**ed.

* Defendants instructed e******n workers to not verify signatures on absentee b****ts,
to backdate absentee b****ts, and to process such b****ts regardless of their validity.

* After e******n officials announced the last absentee b****ts had been received,
another batch of unsecured and unsealed b****ts, without envelopes, arrived in trays
at the TCF Center. There were tens of thousands of these absentee b****ts, and
apparently every b****t was counted and attributed only to Democratic candidates.

* Defendants instructed e******n workers to process b****ts that appeared after the
e******n deadline and to falsely report that those b****ts had been received prior to
November 3, 2020 deadline - i.e., change the date on the b****t.

* Defendants systematically used false information to process b****ts, such as using
incorrect or false birthdays. Many times, the e******n workers inserted new names
into the QVF after the e******n and recorded these new v**ers as having birthdate
0f 1/ 1/ 900.

* On daily basis leading up to the e******n, City of Detroit e******n workers and
employees coached v**ers to v**e for Joe Biden and the Democrat party. These
workers and employees encouraged v**ers to do straight Democrat b****t. These
e******n workers and employees went over to the v****g booths with v**ers in order
to watch them v**e and coach them for whom to v**e.

* Unsecured b****ts arrived at the TCF Center loading garage, not in sealed b****t
boxes, without any chain of custody, and without envelopes.

* Defendant e******n officials and workers refused to record challenges to their
processes and removed challengers from the site if they politely voiced challenge.

After poll challengers started discovering the fraud taking place at the TCF Center,
Defendant e******n officials and workers locked credentialed challengers out of the
counting room so they could not observe the process, during Which time tens of
thousands of b****ts were processed.

* Defendant e******n officials and workers allowed b****ts to be duplicated by hand
without allowing poll challengers to check if the duplication was accurate. In fact,
e******n officials and workers repeatedly obstructed poll challengers from
observing. Defendants permitted thousands of b****ts to be filled out by hand and
duplicated on site without oversight from poll challengers.


Michigan: Stoddard v. City E******n Commission of the City of Detroit

November 4, 2020

State of Michigan Third Judicial Circuit Court for the County of Wayne.
Circuit Court Judge Timothy Kenny Chief Judge Third Judicial Circuit Court of Michigan.

Plaintiff: Sarah Stoddard and E******n Integrity Fund.

Plaintiff Attorney: Edward D. Greim (pro hac forthcoming) Special Counsel, Thomas More Society
Missouri Bar No. 54034, GRAVES GARRETT, LLC. Ian A. Northon (P65082) RHOADES MCKEE PC

Case No. 20-014604-CZ

V***r F***d, V**er Integrity, Plaintiffs, a Michigan poll observer and a nonprofit organization, allege that absentee v**e count centers in Detroit do not have one inspector from each political party present, in violation of state law. Plaintiffs seek to halt the counting of absentee b****ts until observers from both parties are present.

To wit:

1. This lawsuit challenges the ongoing action of the City E******n Commission of the City of Detroit and the Detroit City Clerk with respect to one-party control of the Absent V**er Counting Board (“AVCB”) operating out of TCF Center (formerly known as Cobo Hall).

Specifically, individual inspectors from a single major political party are “curing” rejected absentee b****ts – those absentee b****ts that cannot be properly read by the electronic counting machine -- including t***sposing the v**er’s perceived choices onto a new b****t, without the required oversight and signatures of two e******n inspectors—one from each major political party. These rejected absentee b****ts are reviewed by only one inspector, in most cases a Democratic inspector, who then unilaterally decides how the v**er intended to v**e and creates a b****t that can be read reflecting the inspector’s unilateral decision.

2. This violates MCL 168.765a (10), which requires one inspector from each party to be present at the AVCB. It also violates the Secretary of State’s rule, as set forth in her controlling E******n Officials’ Manual, requiring that any cured b****t bear the signature of two e******n inspectors who have expressed a preference for different political parties. See 168.765a(13). In application, this arrangement in the TCF Center fails to comply with Michigan law and invites fraud.

3. This action seeks an order: (a) halting further “curing” of absentee b****ts rejected by the counting machines until one inspector from each party is present to observe the cure and sign the cured b****t; and (b) segregating the rejected and cured b****ts; and (c) halting certification until the statutorily-required inspectors can be located and used to ensure e******n integrity." - Blade Runner

PeterS

Shucks, done in by the justice department once again...

PeterS

To Wit:
Snip>>>Plaintiffs' pleadings do not persuade this Court that they are likely to prevail on
the merits for several reasons. First, this Court believes plaintiffs misinterpret the
required placement of major party inspectors at the absent v**er counting board
location. MCL 168.765a (10) states in part "At least one e******n inspector from each
major political party must be present at the absent v**er counting place ... " While
plaintiffs contends the statutory section mandates there be a Republican and
Democratic inspector at each table inside the room, the statute does not identify this
requirement. This Court believes the plain language of the statute requires there be
e******n inspectors at the TCF Center facility, the site of the absentee counting effort.
Pursuant to MCL 168. 73a the County chairs for Republican and Democratic
parties were permitted and did submit names of absent v**er counting board
inspectors to the City of Detroit Clerk. Consistent with MCL 168.674, the Detroit City
Clerk did make appointments of inspectors. Both Republican and Democratic
inspectors were present throughout the absent v**er counting board location.
An affidavit supplied by Lawrence Garcia, Corporation Counsel for the City of
Detroit, indicated he was present throughout the time of the counting of absentee
2
b****ts at the TCF Center. Mr. Garcia indicated there were always Republican and
Democratic inspectors there at the location. He also indicated he was unaware of any
unresolved counting activity problems.

By contrast, plaintiffs do not offer any affidavits or specific eyewitness evidence
to substantiate their assertions. Plaintiffs merely assert in their verified complaint
"Hundreds or thousands of b****ts were duplicated solely by Democratic party
inspectors and then counted." Plaintiffs' allegation is mere speculation.
Plaintiffs' pleadings do not set forth a cause of action. They seek discovery in
hopes of finding facts to establish a cause of action. Since there is no cause of action,
the injunctive relief remedy is unavailable. Terlecki v Stewart, 278 Mich. App. 644;
754 NW2d 899 (2008).

The Court must also consider whether plaintiffs will suffer irreparable harm.
Irreparable harm requires "A particularized showing of concrete irreparable harm or
injury in order to obtain a preliminary injunction." Michigan Coalition of State
Employee Unions v Michigan Civil Service Commission, 465 Mich. 212,225; 634
NW2d 692, (2001 ).

In Dunlap v City of Southfield, 54 Mich. App. 398, 403; 221 NW2d 237 (1974),
the Michigan Court of Appeals stated "An injunction will not lie upon the mere
apprehension of future injury or where the threatened injury is speculative or
conjectural."

In the present case, Plaintiffs allege that the pr********n and submission of
"duplicate b****ts" for "false reads" without the presence of inspectors of both parties
violates both state law, MCL 168. 765a ( 10), and the Secretary of State e******n
manual. However, Plaintiffs fail to identify the occurrence and scope of any alleged
violation The only "substantive" allegation appears in paragraph 15 of the First
Amended Complaint, where Plaintiffs' allege "on information and belief' that hundreds
or thousands of b****ts have been impacted by this improper practice. Plaintiffs'
Supplemental Motion fails to present any further specifics. In short, the motion is
based upon speculation and conjecture. Absent any evidence of an improper
practice, the Court cannot identify if this alleged violation occurred, and, if it did, the
frequency of such violations. Consequently, Plaintiffs fail to move past mere
apprehension of a future injury or to establish that a threatened injury is more than
speculative or conjectural.

As I told Blade Runner who did a cut and paste of the very same thing (I guess you guys subscribe to the same service), you are listing cases that have already been tossed out of court.
https://www.michigan.gov/documents/ag/Stoddard_et_al_v_City_E******n_Commission_et_al_-_11-06-2020_707182_7.pdf

eagleye13 Loc: Fl

The search for v****g corruption will continue.
The results of the investigation will be released in mid December.
(December 14?)

EconomistDon

This was clearly a biased Democrat judge. He claims that the rules require only that observers must be in the room; no distance limits. So according to him it was just fine that observers were held in corrals far across the room, unable to see much and unable to perform their jobs. And then he claims that there aren't sufficient specifics to merit a case. I wonder how he expects observers to get specifics from across the room with obstacles blocking their view. This judge's decision is a joke.

Seth

This is why the Democrats prefer "liberal" activist judges to Constitutionalists.

Blade_Runner Loc: DARK SIDE OF THE MOON

No surprise here. In denying the Plaintiff the right to discovery, Judge Kenny failed to follow civil court procedure.

"The only "substantive" allegation appears in paragraph 15 of the First
Amended Complaint, where Plaintiffs' allege "on information and belief' that hundreds
or thousands of b****ts have been impacted by this improper practice."

To file a civil complaint all you need a reasonable basis in fact and law, allegations can be made on information and belief. A motion to dismiss by the defense tests the legal sufficiency of the complaint. So, assuming everything in the complaint is true is how the judge looks at it - does it state a claim upon which relief can be granted. So, for a motion to dismiss, everything is assumed to be true and all reasonable inferences are granted to the plaintiff.

Expedited discovery can be granted by the court when injunctive relief is sought, such as a temporary restraining order and/or a preliminary injunction. Depending on the need for proper resolution, discovery can be ordered immediately. (Courts have the power to speed discovery along, and very fast.)

People do not file in civil court with reams and reams of "evidence". Reason being, there has not yet been discovery. They are simply trying to gather enough information where it looks like a reasonable basis exists in fact and law for the allegations being made.

In any civil court filing, the Plaintiff argument is, "On a reasonable basis in fact and law, I have enough information here to make an allegation, and we want the opportunity to pursue our law suit and conduct discovery - written discovery, document demands, depositions, witness lists, and we want this done quickly."

eagleye13 Loc: Fl

"In any civil court filing, the Plaintiff argument is, [color=blue]"On a reasonable basis in fact and law, I have enough information here to make an allegation, and we want the opportunity to pursue our law suit and conduct discovery - written discovery, document demands, depositions, witness lists, and we want this done quickly."" - Blade_Runner

Yep!
Quickly I say!!!!

peg w

Its been three weeks since the e******n and Trump has only been able to find a handful of fraudulent v**es. Every judge has thrown out Trumps cases for lack of eveidence. There isn't any evidence of fraud, so get over it..These accusations are what a third world dictator would give.

EconomistDon

Have patience Peg. We gave Al Gore 37 days to challenge only one state. Democrats act like the offending team in a football game when a play might be challenged. If they can get the next play started, there can be no challenge. Democrats are desperate to get to the next step so that their fraud cannot be challenged. If there is no fraud, then you have nothing to worry about. You and the rest of your Democrat friends are acting guilty like the offending football team who want to rush into the next play.

V****G FRAUD is what a third world dictator does. Anything to maintain control of the little people.

Seth

eagleye13 Loc: Fl

"This judge's decision is a joke."

That "judge" is a Black Robed bandit.