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COMPLAINT FOR DECLARATORY, EMERGENCY, AND PERMANENT INJUNCTIVE RELIEF
IN THE UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF WISCONSIN
WILLIAM FEEHAN and DERRICK VAN ORDEN, Plaintiffs.
v.
WISCONSIN ELECTIONS COMMISSION, and its members ANN S. JACOBS, MARK L. THOMSEN, MARGE BOSTELMAN, JULIE M. GLANCEY, DEAN KNUDSON, ROBERT F. SPINDELL, JR., in their official capacities, GOVERNOR TONY EVERS, in his official capacity, Defendants.
CASE NO. 2:20-cv-1771
December 1, 2020
Feehan v. Wisconsin Elections Commission
District Court, E.D. Wisconsin
Docket Number: 2:20-cv-01771
Date Filed: December 1st, 2020
I. VIOLATIONS OF WISCONSIN ELECTION CODE
A. WEC Directed Clerks to Violate Wisconsin Election Code Requirements for Absentee Voting by “Indefinitely Confined” without Photo ID.
B. WEC Directed Clerks to Violate Wisconsin Law Prohibiting Counting of Absentee Ballot Certificates Missing Witness Addresses.
C. WEC Directed Clerks to Illegally Cure Absentee Ballots by Filling in Missing Information on Absentee Ballot Certificates and Envelopes.
II. EXPERT WITNESS TESTIMONY:
EVIDENCE OF WIDESPREAD VOTER FRAUD
A. Approximately 15,000 Wisconsin Mail-In Ballots Were Lost, and Approximately 18,000 More Were Fraudulently Recorded for Voters who Never Requested Mail-In Ballots.
B. Nearly 7,000 Ineligible Voters Who Have Moved Out-of-State Illegally Voted in Wisconsin.
C. A Statistical Study Reveals that Biden Overperformed in those Precincts that Relied on Dominion Voting Machines
III. FACTUAL ALLEGATIONS REGARDING DOMINION VOTING SYSTEMS
A. Dominion’s Results for 2020 General Election Demonstrate Dominion Manipulated Election Results.
B. Administrative and Judicial Decisions Regarding Dominion’s Security Flaws.
C. Foreign Interference/Hacking and/or Manipulation of Dominion Results.
1. Evidence of Vulnerability to Foreign Hackers.
2. Background of Dominion Connections to Smartmatic and Hostile Foreign Governments.
3. US Government Warnings Regarding Hacking by Hostile Foreign Governments.
D. Additional Independent Findings of Dominion Flaws.
1. Central Operator Can Remove, Discard or Manipulate Votes
2. Dominion – By Design – Violates Federal Election & Voting Record Retention Requirements.
3. Dominion Vulnerabilities to Hacking.
E. Because Dominion Senior Management Has Publicly Expressed Hostility to Trump and Opposition to His Election, Dominion Is Not Entitled to Any Presumption of Fairness, Objectivity or Impartiality, and Should Instead Be Treated as a Hostile Partisan Political Actor.
COUNT I
Defendants Violated the Elections and Electors Clauses and 42 U.S.C. § 1983.
COUNT II
Governor Evers and Other Defendants Violated The Equal Protection Clause of the Fourteenth Amendment U.S. Const. Amend. XIV & 42 U.S.C. § 1983
Invalid Enactment of Regulations & Disparate Treatment of Absentee vs. Mail-In Ballots
COUNT III
Fourteenth Amendment, Amend. XIV & 42 U.S.C. § 1983
Denial of Due Process On The Right to Vote
COUNT IV
Wide-Spread Ballot Fraud
PRAYER FOR RELIEF
139. Accordingly, Plaintiffs seek an emergency order instructing Defendants to de-certify the results of the General Election for the Office of President.
140. Alternatively, Plaintiffs seek an order instructing the Defendants to certify the results of the General Election for Office of the President in favor of President Donald Trump.
141. In the alternative, Plaintiffs seek an emergency order prohibiting Defendants from including in any certified results from the General Election the tabulation of absentee and mailing ballots which do not comply with the Wisconsin Election Code, including, without limitation, the tabulation of absentee and mail-in ballots Trump Campaign’s watchers were prevented from observing or based on the tabulation of invalidly cast absentee and mail-in ballots which (i) lack a secrecy envelope, or contain on that envelope any text, mark, or symbol which reveals the elector’s identity, political affiliation, or candidate preference, (ii) do not include on the outside envelope a completed declaration that is dated and signed by the elector, (iii) are delivered in-person by third parties for non-disabled voters, or (iv) any of the other Wisconsin Election Code violations set forth in Section II of this Complaint.
142. Order production of all registration data, ballot applications, ballots, envelopes, etc. required to be maintained by law. When we consider the harm of these uncounted votes, and ballots not ordered by the voters themselves, and the potential that many of these unordered ballots may in fact have been improperly voted and also prevented proper voting at the polls, the mail ballot system has clearly failed in the state of Wisconsin and did so on a large scale and widespread basis. The size of the voting failures, whether accidental or intentional, are multiples larger than the margin in the state. For these reasons, Wisconsin cannot reasonably rely on the results of the mail vote. Relief sought is the elimination of the mail ballots from counting in the 2020 election. Alternatively, the electors for the State of Wisconsin should be disqualified from counting toward the 2020 election. Alternatively, the electors of the State of Wisconsin should be directed to vote for President Donald Trump.
143. For these reasons, Plaintiffs ask this Court to enter a judgment in their favor and provide the following emergency relief:
1. An order directing Governor Evers and the Wisconsin Elections Commission
to de-certify the election results;
2. An order enjoining Governor Evers from transmitting the currently certified election results the Electoral College;
3. An order requiring Governor Evers to transmit certified election results that state that President Donald Trump is the winner of the election;
4. An immediate emergency order to seize and impound all servers, software, voting machines, tabulators, printers, portable media, logs, ballot applications, ballot return envelopes, ballot images, paper ballots, and all “election materials” referenced in Wisconsin Statutes § 9.01(1)(b)11. related to the November 3, 2020 Wisconsin election for forensic audit and inspection by the Plaintiffs;
5. An order that no votes received or tabulated by machines that were not certified as required by federal and state law be counted;
6. A declaratory judgment declaring that Wisconsin’s failed system of signature verification violates the Electors and Elections Clause by working a de facto abolition of the signature verification requirement;
7. A declaratory judgment declaring that currently certified election results violate the Due Process Clause, U.S. CONST. Amend. XIV;
8. A declaratory judgment declaring that mail-in and absentee ballot fraud must be remedied with a Full Manual Recount or statistically valid sampling that properly verifies the signatures on absentee ballot envelopes and that invalidates the certified results if the recount or sampling analysis shows a sufficient number of ineligible absentee ballots were counted;
9. A declaratory judgment declaring absentee ballot fraud occurred in violation of Constitutional rights, Election laws and under state law;
10. A permanent injunction prohibiting the Governor and Secretary of State from transmitting the currently certified results to the Electoral College based on the overwhelming evidence of election tampering;
11. Immediate production of 48 hours of security camera recording of all rooms used in the voting process at the TCF Center for November 3, 2020 and November 4, 2020.
12. Plaintiffs further request the Court grant such other relief as is just and proper, including but not limited to, the costs of this action and their reasonable attorney fees and expenses pursuant to 42 U.S.C. 1988
REFERENCE:
District Court, E.D. Wisconsin
Last Updated: Dec. 7, 2020, 7:37 p.m. CST
Assigned To: Pamela Pepper
Date Filed: Dec. 1, 2020
Date of Last Known Filing: Dec. 4, 2020
Cause: 42:1983 Civil Rights Act
Nature of Suit: 441 Civil Rights: Voting
Jury Demand: None
Jurisdiction Type: Federal Question /
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