PLAINTIFF'S EMERGENCY MOTION FOR INJUNCTIVE RELIEF AND MEMORANDUM OF LAW IN SUPPORT THEREOF UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION L. LIN WOOD, JR., Plaintiff, v. BRAD RAFFENSPERGER, in his official capacity as Secretary of State of the State of Georgia, et al., Defendants. CIVIL ACTION FILE NO. 1 :20-cv-04651-SDG

 

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PLAINTIFF'S EMERGENCY MOTION FOR INJUNCTIVE RELIEF AND MEMORANDUM OF LAW IN SUPPORT THEREOF 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF GEORGIA 

ATLANTA DIVISION 

L. LIN WOOD, JR., Plaintiff, v. BRAD RAFFENSPERGER, in his official capacity as Secretary of State of the State of Georgia, et al., Defendants. 

CIVIL ACTION FILE NO. 1:20-cv-04651-SDG 

November 17, 2020 

WHEREFORE, Plaintiff prays that this Court enter an emergency injunction as to the following: 

1. Prohibiting the certification of the results of the 2020 general election in Georgia on a statewide basis; or 

 

2. Alternatively, prohibiting the certification of said results which include the tabulation of defective absentee ballots; and 

3. Declaring that: 

a. Any recount of the November 3, 2020 elections, including but not limited to the Hand Recount, must be reperformed in a manner consistent with the Georgia Election Code; 

b. Monitors designated by the Republican Party have the right to be present to meaningfully observe all election activity, from the receipt of a ballot to the entry or tabulation of the resulting vote, as to the Hand Recount, any reconducting of the Hand Recount, and the January 5, 2021 run-off election; 

c. That Plaintiff and the Republican Party by given at least 24 hours notice prior to any and all election activity; 

d. That all ballots in Georgia must be read by two persons employed by the County Officials, with said readings being overseen by Republican Party-designated monitors; 

e. That the Republican Party immediately receive certified copies of all ballot envelopes and requests for absentee ballots received by Defendants, and further, that the Republican Party has the right to compare voter or application signatures on ballot envelopes and requests for absentee ballots with eNet, particularly as to the January 5, 2021 run-off election; 

f. That for the January 5, 2021 run-off election, the Republican Party has the right to have absentee ballot watchers/monitors present at all signature verification processes, from the receipt of the request for an absentee ballot to the opening and processing of the same; and 

4. Any and other such further relief that this Court deems equitable and just.