FIRST AMENDED VERIFIED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA DONALD J. TRUMP FOR PRESIDENT, INC.; LAWRENCE ROBERTS; and DAVID JOHN HENRY; Plaintiffs, v. KATHY BOOCKVAR, in her capacity as Secretary of the Commonwealth of Pennsylvania; ALLEGHENY COUNTY BOARD OF ELECTIONS; CENTRE COUNTY BOARD OF ELECTIONS; CHESTER COUNTY BOARD OF ELECTIONS; DELAWARE COUNTY BOARD OF ELECTIONS; MONTGOMERY COUNTY BOARD OF ELECTIONS; NORTHAMPTON COUNTY BOARD OF ELECTIONS; and PHILADELPHIA COUNTY BOARD OF ELECTIONS; Defendants.

 

https://drive.google.com/file/d/1BrYyGCgznDTzfciCLTwnL0yhs-D0ekwv/view?usp=sharing 

FIRST AMENDED VERIFIED COMPLAINT 

FOR DECLARATORY AND INJUNCTIVE RELIEF 

IN THE UNITED STATES DISTRICT COURT 

FOR THE MIDDLE DISTRICT OF PENNSYLVANIA 

DONALD J. TRUMP FOR PRESIDENT, INC.; LAWRENCE ROBERTS; and DAVID JOHN HENRY; Plaintiffs, v. 

KATHY BOOCKVAR, in her capacity as Secretary of the Commonwealth of Pennsylvania; ALLEGHENY COUNTY BOARD OF ELECTIONS; CENTRE COUNTY BOARD OF ELECTIONS; CHESTER COUNTY BOARD OF ELECTIONS; DELAWARE COUNTY BOARD OF ELECTIONS; MONTGOMERY COUNTY BOARD OF ELECTIONS; NORTHAMPTON COUNTY BOARD OF ELECTIONS; and PHILADELPHIA COUNTY BOARD OF ELECTIONS; Defendants. 

CIVIL ACTION No. 20-CV-02078 

November 15, 2020 

WHEREFORE, in addition to any other affirmative relief that the Court may deem necessary and proper, Plaintiffs ask this Court to enter judgment in their favor and provide the following alternative relief: 

i. An order, declaration, and/or injunction that prohibits the Defendant County Boards of Elections and Defendant Secretary Boockvar from certifying the results of the 2020 General Election in Pennsylvania on a Commonwealth-wide basis; 

ii. In addition to the alternative requests for relief, an order, declaration, and/or injunction that prohibits Defendants from certifying the results of the General Elections which include the tabulation of absentee and mail-in ballots which Defendants improperly permitted to be cured; 

iii. A temporary restraining order and preliminary injunction granting the above relief during the pendency of this action; 

iv. Plaintiffs’ reasonable costs and expenses of this action, including attorneys’ fees; and cost; and 

v. All other further relief to which Plaintiffs might be entitled. 

 NOTE: Oral argument will take place as scheduled, tomorrow, 11/17/2020. Counsel for the parties are expected to be prepared for argument and questioning. Signed by Honorable Matthew W. Brann on 11/16/2020. (jr) (Entered: 11/16/2020) 

REFERENCE: 

Donald J. Trump For President, Inc. v. Boockvar (4:20-cv-02078) District Court, M.D. Pennsylvania COURT LISTENER 

DOCKET ENTRIES 

Last Updated: Nov. 16, 2020, 10:02 p.m. EST
Assigned To: Matthew William Brann 
Date Filed: Nov. 9, 2020
Date of Last Known Filing: Nov. 16, 2020
Cause: 28:1331 Federal Question: Other Civil Rights 
Nature of Suit: 440 Civil Rights: Other
Jury Demand:  None
Jurisdiction Type: Federal Question