COMPLAINT, United States District Court District of Minnesota, MICHAEL J. LINDELL, Plaintiff, v. US DOMINION, INC., DOMINION VOTING SYSTEMS, INC., DOMINION VOTING SYSTEMS CORPORATION, SMARTMATIC USA CORP., SMARTMATIC INTERNATIONAL HOLDING B.V., and SGO CORPORATION LIMITED, Defendants.

Lindell v. US Dominion, Inc. (0:21-cv-01332)
District Court, D. Minnesota

  https://drive.google.com/file/d/13ud8XXfMhopkVm2TSqpd678-aM4ITJnz/view?usp=sharing 

United States District Court
District of Minnesota
MICHAEL J. LINDELL, Plaintiff,
v.
US DOMINION, INC., DOMINION VOTING SYSTEMS, INC., DOMINION VOTING SYSTEMS CORPORATION, SMARTMATIC USA CORP., SMARTMATIC INTERNATIONAL HOLDING B.V., and SGO CORPORATION LIMITED, Defendants.
COMPLAINT
Case No. 0:21-cv-01332

Jury Trial Demanded

Jun 3, 2021
COMPLAINT against Dominion Voting Systems Corporation, Dominion Voting Systems, Inc., SGO Corporation Limited, Smartmatic International Holding B.V., Smartmatic USA Corp, US Dominion, Inc. (filing fee $ 402, receipt number AMNDC-8796850) filed by Michael J Lindell. Filer requests summons issued. (Attachments: # 1 Exhibit(s) 1, # 2 Exhibit(s) 2, # 3 Exhibit(s) 3, # 4 Exhibit(s) 4, # 5 Exhibit(s) 5, # 6 Exhibit(s) 6, # 7 Exhibit(s) 7, # 8 Exhibit(s) 8, # 9 Exhibit(s) 9, # 10 Exhibit(s) 10, # 11 Exhibit(s) 11, # 12 Exhibit(s) 12, # 13 Exhibit(s) 13, # 14 Exhibit(s) 14, # 15 Exhibit(s) 15, # 16 Exhibit(s) 16, # 17 Exhibit(s) 17, # 18 Civil Cover Sheet) (Beck, Alec) (Entered: 06/03/2021)

Main Doc­ument Complaint

CAUSES OF ACTION

COUNT ONE: ABUSE OF PROCESS

(as to the Dominion Defendants)

COUNT TWO: DEFAMATION

(as to the Dominion Defendants)

COUNT THREE: VIOLATIONS OF THE RACKETEER INFLUENCED AND CORRUPT ORGANIZATION ACT, 18 U.S.C. § 1962

(as to Dominion Defendants and Smartmatic Defendants)

COUNT FOUR: VIOLATIONS OF THE “SUPPORT AND ADVOCACY” CLAUSE OF 42 U.S.C. § 1985(3)

(as to Dominion Defendants and Smartmatic Defendants)

COUNT FIVE: 42 U.S.C. § 1983 DEPRIVATION OF CIVIL RIGHTS BY ACTIONS UNDER COLOR OF STATE LAW

(as to Dominion Defendants)

COUNT SIX: CIVIL CONSPIRACY

(as to All Defendants)

 

DAMAGES AND OTHER RELIEF

The facts set out above and to be proven at trial will demonstrate that Plaintiff is entitled to recover against Defendants, jointly and severally, the following:

a. Actual and special damages as allowed by law, in an amount to be proven at trial, including but not limited to the following:

    a. Special damages in the form of attorneys fees and expenses incurred in defending against Dominion’s lawsuit;

    b. Damages for defamation per se for Dominion’s public attacks on his honesty and integrity; and,

    c. Damages to be determined by the trier of fact suffered as a result of the deprivation of his rights under the First Amendment to the U.S. Constitution and under the “support and advocacy” clause of 42 U.S.C. § 1985(3); together with,

b. Three times actual damages for violations of 18 U.S.C. § 1862;

c. Punitive damages as allowed by law, in an amount to be determined by the trier of fact;

d. Reasonable and necessary attorney’s fees, as allowed by law; and,

e. Costs of suit.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff asks that Defendants be cited to answer and appear herein and that, after trial or other hearing on the merits, Plaintiff have and recover against the Defendants, jointly and severally, the relief requested herein, together with all writs and processes necessary to the enforcement of same, and all other relief to which he may show himself justly entitled.

Attach­ment 1 Exhibit(s) 1

Attach­ment 2 Exhibit(s) 2

Attach­ment 3 Exhibit(s) 3

Attach­ment 4 Exhibit(s) 4

Attach­ment 5 Exhibit(s) 5

Attach­ment 6 Exhibit(s) 6

Attach­ment 7 Exhibit(s) 7

Attach­ment 8 Exhibit(s) 8

Attach­ment 9 Exhibit(s) 9

Attach­ment 10 Exhibit(s) 10

Attach­ment 11 Exhibit(s) 11

Attach­ment 12 Exhibit(s) 12

Attach­ment 13 Exhibit(s) 13

Attach­ment 14 Exhibit(s) 14

Attach­ment 15 Exhibit(s) 15

 Attach­ment 16 Exhibit(s) 16

Attach­ment 17 Exhibit(s) 17

Attach­ment 18 Civil Cover Sheet

 

Jun 11, 2021
ORDER FOR REASSIGNMENT OF RELATED CASES. This case is reassigned to Judge Patrick J. Schiltz and Magistrate Judge David T. Schultz for all further proceedings. Judge Eric C. Tostrud, Magistrate Judge Hildy Bowbeer no longer assigned to case. NOTE: The new case number is 21-cv-1332 (PJS/DTS). Please use this case number for all subsequent pleadings. Signed by Judge Patrick J. Schiltz on 6/10/2021 and Judge Eric C. Tostrud on 6/11/2021. (lmb) (Entered: 06/11/2021) 

Main Doc­ument Order Reassigning Case