https://drive.google.com/file/d/127XHQFwzkpBzInWqeOOXFY51RMbaLs9x/view?usp=sharing
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
WISCONSIN VOTERS ALLIANCE
E3530 Townline Road
Kewaunee, Wisconsin 54216;
PENNSYLVANIA VOTERS ALLIANCE
1621 Huddel Avenue Lower
Chichester, Pennsylvania, 19061;
GEORGIA VOTERS ALLIANCE
151 Main Street
Senior, Georgia 30276;
ELECTION INTEGRITY FUND
1715 Northumberland Drive
Rochester Hills, Michigan 48309;
ARIZONA VOTER INTEGRITY ALLIANCE
8019 East Tuckey Lane
Scottsdale, Arizona 85250;
LYNIE STONE
10410 East Prince Road
Tucson, Arizona 85749;
BARON BENHAM
8019 East Tuckey Lane
Scottsdale, Arizona 85250;
DEBI HAAS
5530 Rivers Edge Drive
Commerce, Michigan 48382;
BRENDA SAVAGE
1715 Northumberland Drive
Rochester Hills, Michigan 48309;
MATTHEW DADICH
1621 Huddel Avenue
Lower Chichester, Pennsylvania 19061;
LEAH HOOPES
241 Sulky Way
Chadds Ford, Pennsylvania 19317;
RON HEUER
E3530 Townline Road
Kewaunee, Wisconsin 54216;
RICHARD W. KUCKSDORF
W2289 Church Drive
Bonduel, Wisconsin 54107;
DEBBIE JACQUES
1839 South Oneida Street
Green Bay, Wisconsin 54304;
JOHN WOOD
151 Main Street
Senior, Georgia 30276;
SENATOR SONNY BORRELLI
2650 Diablo Dr Lake Havasu City AZ 86406
REPRESENTATIVE WARREN PETERSON
2085 E Avenida del Valle Ct Gilbert AZ 85298
REPRESENTATIVE MATTHEW MADDOCK
1150 South Milford Road
Milford, Michigan 48381;
REPRESENTATIVE DAIRE RENDON,
4833 River Wood Road
Lake City, Michigan 49651;
REPRESENTATIVE DAVID STEFFEN
715 Olive Tree Court
Green Bay, Wisconsin 54313;
REPRESENTATIVE JEFF L. MURSAU
4 Oak Street
Crivitz, Wisconsin 54114;
SENATOR WILLIAM T. LIGON
90 Bluff Road South
White Oak, Georgia 31568; and
SENATOR BRANDON BEACH
3100 Brierfield Road Alpharetta, GA 30004
Plaintiffs,
v.
VICE PRESIDENT MICHAEL RICHARD PENCE,
in his official capacity as President of the United States Senate,
Office of the Vice President
1600 Pennsylvania Avenue, N.W.
Washington, DC 20500;
U.S HOUSE OF REPRESENTATIVES,
U.S. Capitol
First St SE
Washington, DC 20004;
U.S. SENATE,
U.S. Capitol
First St SE
Washington, DC 20004;
ELECTORAL COLLEGE,
U.S. Capitol
First St SE
Washington, DC 20004;
GOVERNOR TOM WOLF OF PENNSYLVANIA,
in his official capacity,
508 Main Capitol Building
Harrisburg, PA 17120;
SPEAKER BRYAN CARTER OF THE PENNSYLVANIA HOUSE OF REPRESENTATIVES, in his official capacity,
139 Main Capitol Building
PO Box 202100
Harrisburg, PA 17120-2100;
SENATE MAJORITY LEADER JAKE CORMAN
OF THE PENNSYLVANIA SENATE,
in his official capacity,
Senate Box 203034 Harrisburg, PA 17120-3034;
GOVERNOR GRETCHEN WHITMER OF MICHIGAN,
in her official capacity,
111 S Capitol Avenue
Lansing, Michigan 48933;
SPEAKER LEE CHATFIELD OF THE MICHIGAN
HOUSE OF REPRESENTATIVES,
in his official capacity,
124 N Capitol Avenue
Lansing, Michigan 48933;
SENATE MAJORITY LEADER MIKE SHIRKEY
OF THE MICHIGAN SENATE,
in his official capacity,
S-102 Capitol Building
Lansing, Michigan 48933;
GOVERNOR TONY EVERS OF WISCONSIN,
in his official capacity,
P.O. Box 7863
Madison, Wisconsin 53707;
SPEAKER ROBIN VOS OF THE WISCONSIN
STATE ASSEMBLY,
in his official capacity,
960 Rock Ridge Road
Burlington, Wisconsin 53105;
SENATE MAJORITY LEADER HOWARD MARKLEIN
OF THE WISCONSIN SENATE,
in his official capacity,
PO Box 7882 Madison, Wisconsin 53707;
GOVERNOR BRIAN KEMP OF GEORGIA,
in his original capacity, 111 State Capitol Atlanta, Georgia 30334;
SPEAKER DAVID RALSTON OF THE GEORGIA HOUSE
OF REPRESENTATIVES,
in his official capacity,
332 State Capitol
Atlanta, Georgia 30334;
PRESIDENT PRO TEMPORE BUTCH MILLER OF THE GEORGIA SENATE,
in his official capacity,
321 State Capitol
Atlanta, Georgia 30334;
GOVERNOR DOUG DUCEY OF ARIZONA,
in his official capacity,
1700 W. Washington Street
Phoenix, Arizona 85007;
SPEAKER RUSSELL BOWERS OF THE
ARIZONA HOUSE OF REPRESENTATIVES,
in his official capacity,
1700 West Washington
Room 223
Phoenix, Arizona 85007; and
SENATE MAJORITY LEADER RICK GRAY
OF THE ARIZONA SENATE,
in his official capacity,
1700 West Washington Room 301 Phoenix, Arizona 85007,
Defendants.
PRAYER FOR RELIEF
WHEREFORE, Plaintiffs respectfully request that this Court issue the following relief for the 2020 and future Presidential elections:
A. Issue a declaratory judgment, applying to the current and future elections, declaring that 3 U.S.C. §§ 5, 6 and 15 were and are unconstitutional deprivations of the state legislatures’ constitutional prerogative to post-election certification of the Presidential electors;
B. Issue a declaratory judgment, applying to current and future elections, declaring that Ariz. Rev. Stat. § 16-212 (B), Ga. Code Ann. § 21-2-499 (B), Mich. Comp. Laws Ann. § 168.46, Wis. Stat. § 7.70 (5) (b), 25 Pa. Cons. Stat. § 3166 and similar state laws are unconstitutional delegations by the respective states of post-election Presidential election certification duties to their respective executive branch officers when Article II requires such certifications to be made by the respective state legislatures;
C. Issue a declaratory judgment, applying to current and future elections, that the Plaintiff-voters’ constitutionally-protected voting rights in Presidential elections are being violated by Defendants;
D. Issue a declaratory judgment, applying to current and future elections, that the Plaintiffs’ voting rights were violated under Article II, the Equal Protection Clause and the Due Process Clause;
E. Enjoin the Vice President and U.S. Congress, in the current and future elections, from counting Presidential elector votes from states unless their respective state legislatures vote affirmatively in a post-election vote to certify their Presidential electors;
F. Alternatively, enjoin, in the current and future elections, the State Defendants’ state legislatures to meet in their respective States to consider post-election certification of their respective Presidential electors;
G. Award attorney’s fees and costs under 42 U.S.C. § 1988 to Plaintiffs against State Defendants; and
H. Grant such other relief as the Court deems just and proper.
DATED: December 22, 2020
No comments:
Post a Comment