COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF IN THE COMMONWEALTH COURT OF PENNSYLVANIA, THE HONORABLE MIKE KELLY, SEAN PARNELL, THOMAS A. FRANK, NANCY KIERZEK, DEREK MAGEE, ROBIN SAUTER, MICHAEL KINCAID, and WANDA LOGAN, Plaintiffs, v. COMMONWEALTH OF PENNSYLVANIA, PENNSYLVANIA GENERAL ASSEMBLY, HONORABLE THOMAS W. WOLF, KATHY BOOCKVAR, Defendants.

 

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COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF

IN THE COMMONWEALTH COURT OF PENNSYLVANIA 

THE HONORABLE MIKE KELLY, SEAN PARNELL, THOMAS A. FRANK, NANCY KIERZEK, DEREK MAGEE, ROBIN SAUTER, MICHAEL KINCAID, and WANDA LOGAN, Plaintiffs, 

v. 

COMMONWEALTH OF PENNSYLVANIA, PENNSYLVANIA GENERAL ASSEMBLY, HONORABLE THOMAS W. WOLF, KATHY BOOCKVAR, Defendants. 

Docket No.___ M.D. 2020 

Filed 11/21/2020 

WHEREFORE, Plaintiffs respectfully request that this Honorable Court enter an order, declaration, and/or injunction that prohibits Defendants from certifying the results of the General Elections which include mail-in ballots which Defendants improperly permitted on a statewide basis; prohibits Defendants from certifying the results of the General Elections which include the tabulation of unauthorized votes, including mail-in ballots which did not meet the Constitutional requirements and, instead, compels Defendants to certify the results of the election based solely on the legal votes or, alternatively, directs that the Pennsylvania General Assembly choose Pennsylvania's electors; award Plaintiffs' reasonable costs and expenses of this action, including attorneys' fees and costs; and provide such other and further legal and equitable relief as this Court deems just and proper.