COMPLAINT IN SPECIAL ACTION AND VERIFIED STATEMENT OF ELECTION CONTEST PURSUANT TO A.R.S. § 16-672: IN THE SUPERIOR COURT FOR THE STATE OF ARIZONA IN AND FOR THE COUNTY OF MARICOPA Kari Lake,. Contestant/Plaintiff, v. Katie Hobbs, personally as Contestee and in her official capacity as Secretary of State; Stephen Richer in his official capacity as Maricopa County Recorder; Bill Gates, Clint Hickman, Jack Sellers, Thomas Galvin, and Steve Gallardo, in their official capacities as members of the Maricopa County Board of Supervisors; Scott Jarrett, in his official capacity as Maricopa County Director of Elections; and the Maricopa County Board of Supervisors, Defendants.

 

 

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IN THE SUPERIOR COURT FOR THE STATE OF ARIZONA
IN AND FOR THE COUNTY OF MARICOPA

Kari Lake,.
Contestant/Plaintiff,
v.
Katie Hobbs, personally as Contestee and in her official capacity as Secretary of State; Stephen Richer in his official capacity as Maricopa County Recorder; Bill Gates, Clint Hickman, Jack Sellers, Thomas Galvin, and Steve Gallardo, in their official capacities as members of the Maricopa County Board of Supervisors; Scott Jarrett, in his official capacity as Maricopa County Director of Elections; and the Maricopa County Board of Supervisors,
Defendants

COMPLAINT IN SPECIAL ACTION AND VERIFIED STATEMENT OF ELECTION CONTEST PURSUANT TO A.R.S. § 16-672

Case No. CV2022-095403

COUNT I.
Freedom of Speech
U.S. Const. amend. I, Ariz. Const. art, II, § 6
Misconduct, A.R.S. § 16-672(A)(l)

CO UNT II.
Illegal Tabulator Configurations
52 U.S.C. § 21081; A.R.S. § 16-442CB)
Misconduct and Illegal Votes, A.R.S. § 16-672(A)(l), (A)( 4)

COUNT III.
Mail-In Ballots with Invalid Signatures
A.R.S. § 16-SSO(A)
Misconduct, A.R.S. § l6-672(A)(l)

COUNT IV.
Invalid Chain of Custody
A.R.S. §§ 16-621(E), 16-1016
Misconduct, A.R.S. § 16-672(A)(t)

COUNT V.
Equal Protection
U.S. Con st. amend. XIV, § 1, cl. 4, Ariz. Const. art, II, § 6
Misconduct and Illegal Votes, A.R.S. § 16-672(A)(l), (A)(4)

COUNT VI.
Due Process
U.S. Const. amend. XIV, § 1, cl. 3, Ariz. Const. art, II, § 6
Misconduct and Illegal Votes, A.R.S. § 16-672(A)(l), (A)(4)

COUNT VII.
Non-Secret Mail-In Ballots
U.S. Const. amend. XVI, § 1, cl. 3, Ariz. Const. art, VII, § l
Illegal Votes, A.R.S. § 16-672(A)(4) 

COUNT VIII
Incorrect Certification
A.R.S. § 16-650
Illegal Votes and Erroneous Count of Votes, A.R.S. § 16-672(A)(4)-(5) 

 COUNT IX.
Inadequate Remedy
A.R.S. § 16-672
Declaratory Judgment, A.R.S. §§ 12-1831-1846

COUNT X.
Federal Constitutional Rights
U.S. Const. amend. XIV,§ l, cl. 3-4
Civil Rights Action, 42 U.S.C. § 1983

 

DEMAND FOR RELIEF

WHEREFORE, Contestant Kari Lake demands relief in the following forms:

 

1. An opportunity to inspect Maricopa County ballots from the 2022 general election, including ballot signature envelopes and the corresponding signatures on file with Maricopa County, prior to trial;
2. A root cause analysis and forensic examination into the causes and extent of the printer-tabulator problems encountered on election day;
3. Trial of all disputed factual issues;
4. An order striking all signatures on file with Maricopa County that are not the "registration record" pursuant to A.R.S. §I 6-550(A);
5. An order striking any invalid ballots or types of ballots on an absolute or prorated basis;
6.  An order setting aside the certified result of the 2022 Arizona gubernatorial election and declaring that Kari Lake is the winner of the 2022 Arizona gubernatorial election, pursuant to A.R.S. § 16-676;
7. In the alternative, an order vacating the certified results of the 2022 Arizona gubernatorial election, pursuant to A.R.S. § 16-676 or 42 U.S.C. § 1983, and an injunction requiring that Maricopa County re-conduct the gubernatorial election in confmmance with all applicable law and excluding all improper votes, under the direction of a special master;
8. Recusal of defendants Hobbs and Richer from further participation in matters involving the 2022 general election, including any new election and the review of any issues related to the 2022 general election and any new election.

DATED this 9^th day of December 2022

REFERENCE:

News

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 By Carson Choate  December 10, 2022