You are on page 1of 6
Great Lanes Justice CenTeR STATE OF MICHIGAN IN THE CIRCUIT COURT FOR THE COUNTY OF WAYNE, CHERYL A. COSTANTINO and EDWARD P. MeCAl SUPPLEMENTAL BRIEF IR {UPPORT OF MOTION FOR ‘TEMPORARY RESTRAINING iMINARY, Plaintits, CITY OF DETROIT; DETROIT ELECTION FILE NO: 20-014780-AW COMMISSION: Janice M. Winfrey. in her officia capacity as the CLERK OF THE. HON. TIMOTHY M, KENNY CITY OF DETROIT and the Chairperson of the DETROIT ELECTION COMMISSION; Cathy M. Garrett, in her official capacity as the CLERK OF WAYNE COUNTY; and the WAYNE COUNTY BOARD OF CANVASSERS, Defendants, David A. Kallman (P3420) Brin E, Mersino (P 70886) Jack C, Jordan (Pa6sst) Stephen P. Kallman (P75622) Great Lakes Justice Center Attorneys for Plaintiff ‘3600 W. Mount Hope Hwy. Lansing, MI 48917 (517) 322-3207/Rax: (517) 322-3208 ENTAL BRIEF IN SUPPORT OF MOTION FOR TEMPORARY RESTRAINING ORDER AND PRELIMINARY INJUNCTION Plaintiffs just received an Affidavit from Melissa Carone, Ms. Carone was a contractor for Dominion Voting Systems to do IT work at the TCF Center. Ms. Carone was at the TCF Center from 6:15 am. on November 3, 2020 to 4:00 am, on November 4, 2020, She then went home to jet 8 few ours sleep and worked again at the TCF Center from 10:00 a.m, until 1:45 p.m. on GREAT Lakes Justice CentER — November #®. Ms. Carone states that she “witnessed nothing but fraudulent actions take place” (Exhibit H), Further, Ms. Carone states: 3. The counters (which were trained very ite or not at all), were handed a "batch" (tack of 50) of mail-in ballots in which they would run through the tabulator. The tabulators would get jammed 4-5 times an hour, when they jammed the computer ‘would put out an error that ells the worker the ballot number that was jammed and ‘ives an option to either discard the batch or continue scanning at which the counter should discard the batch, put the issue ballot on top of the batch and rescan the entze batch. 1 witnessed countless workers rescanning the batches without discarding them first which resulted in ballots being counted 4-5 times. 4. Atapproximately midnight I was called over to assist one ofthe counters with a paper jam and noticed his PC bad a number of over 400 ballots scanned- which ‘means one batch was counted over 8 times. This happened countless times while I wwacat the TCF Center. I conftonted my manager, Nick Ikonomakis saying how big, cof « problem this was, Nick told me he didnt want to hear that we have a big problem, He told me we are here todo assist with IT work, not to run their election, 5. The adjudication process, from my understanding there's supposed to be a republican and a democrat judging these ballots. I overheard numerous workers talking during shift change in which over 20 machines had two democrats judging ‘the ballots-resulting in an unfair process. ‘9, When a worker had a ballot that chey either could not read, or it had something spilled oni, they would go toa table that had blank ballots oni and fill i out. They ‘were supposed to be filling them out exactly lke the one they had received but this was not the case tall. The workers would also sign the name of the person tha the ballot belonged to-which is clearly illegal 13. called the FBI and made a report with them, I was told that Iwill be getting a call back. Ms. Carone’s sworn statement provides further evidence that fraud and misconduct ‘occurred at the November 3, 2020 election. Plaintiffs request that their Motion for TRO and Preliminary Injunction be granted Respectfully submited, Dated: November 10, 2020 ‘4 David A, Kallman. David A. Kallman (34200) ‘Attorney for Platts EXHIBIT H STATE OF MICHIGAN [BCTHE CIRCUIT COURT POR THE COUNTY O¥ WAYNE MELLISA A. cARONT, AgTIDAMITOF MILLIS. Phin, anon, CITY OF DETROFT: DETROIT ELECTION er fla capacity asthe CLERK OF THE, CITY OF DETROIT se the Chairperion of mer ‘The DETROTT ELECTION COMMISSION; (CATHY Mt. GARRETT, ner of Capac tthe CLERK OF WAYNE COUNTY BOARD OF CANVASSERS, nant Rasa Or aescan Defendants, ermine 1284 ins Sw Sere David A, Katinas @ss200) rie E: Merino ern) ack. Jordan eruessty Stepan. Katiman ornse2) (GREAT LAKES JUSTICE CENTER, Attraeys for Plat ‘5600 W. Mount Hope Hy ansng, M8917 (517) 32252071 Fae (17) 32-208 AbpDAvIT ‘The Afi Malis A. Cao bring he i daly sem hry dae ante a lows: 1 syne eng Cag by Denn Vn Sri oe a 21 Laie athe TCP Center pprosoty 615 AM Nove, 220s woe et 400 ‘At Novebe 2020 wet me op sore sap en enved ack aie TOF Cor {ozo nh apes 5 One seed gb rst 2. Thecours (which mrt very ile sl a all weed a ac of 50) | ‘pra bala tio ny weno eaghte dare ees ell gt wom £5 time en hour en ty jn the compte weld pa tera at woke ‘de lt ember hat nas jneed aginst pn ote dad he bts or cre Semin aot th couse shoul cr thet rh ue alton op he ach ‘dria beet ch | wild counts wor rocaning the bother ant ‘Searing ta st which ue sls bg cate 3 oe 4. Alapyrosintty might was clo ove toast enh costes wth opt jam and feted is PC ds uber ove 40 ballon ch ts oe bth wa outed ‘ter 8 ine Ths happened suns me etwas ae TOF Cen enone my ‘nape Nick hononas saying hw ip o's problem hw, Me i me be et ‘arta weheves ig proton Hotline wearer dost ih Twa tt 5. Theadhudation procs, fom my detuning thew upped beeps ad {cooct ugg alia verhend nares wee ang og si changin ‘ich over 20 machined wo dene ing th altering ta un proces 6 News otto deste wt wenn ring hi cage achat dete. tok ovr {sa thy dhe ao eo a. Ths pope wee chwe be couters wch 6 ‘onary ete oe ta ey ceived bly oo Wang aah 1. Thenigh sit woke wer eto cone nd ga types hey cul goat nd aake amt coutng rom. Th legal ws tere wes bones ao sian of balls every yore coed hve an ome os or beg one, td Noe Ws wach en. |, ‘Thema tuo vant pl oh rage fh couing ean one dey si doe on ‘ipa Thee vane ere pyre binging Oo bis Bene hey Ded ‘ibuah fod for nsaren othe werk I even ay fo ang ct se in ‘Socal hws soouaed on te new ht chigan ha ave ve 10,00 ae ‘Ste nt evento hus ha ve 9. Whe wkd ali at hay it co at ede a smthing pedo ty ‘owl goton blot ad Bn bls ot an lt at Thy were suport be ili Tema sate tb on thy hedrectved at his st theca a. The were ‘ou sain sane fe poane at he talbott ety Seg 10. Samael Chainer aden sie young ma inhi 20 were reponse Fr ubmiig te ‘cc i hea computer Ty fad sey no cverhnd,my map: Neck would ‘Sst heihany ato bat Nick wa one ear ssng Wah T mat ote ie Thar nova Samuel aking t Nik abot ingot ya gto ‘ie phone and ope the eof see kad Nek wt ws png on ad Sed me [dalton cr and ol tory abut {ltl a os stg vey ‘cil hat ty ut covered, 12.1 yas than eulcan wrtng or Dominios Vein, ado te sap tare as may tele amments beng mae yt cy workers nd Doin wares sou epics 1a {Seeou ay inden at wat eqn, Ihnen schome ad knew as gst Eieta wary coat thocd cmp shi ifanyon been Amro fa nce tor tm, thy wereanomaicly deemed ob Trp suppor: ‘alle te FB and ade ep wih hen, as tl ha wtb geting cal ack 14 Lum doing my test to make sre somhing sone bout his, wa tre ante hit take pace ‘nth 8 day Nov, 2020, before epee ppd Malin A. Cane, wh ay SSG cog sett cred nd Koes oe Sa an ae ‘Saw ot bows tng nd ta exept ore athe ses norman a ‘tate the tos betel taco Bete Venema d tee Pita hoon ufo Nery Pai eben coy, Migr My Comin Expien_Ot_1%_ 2031 mera Soa {emma a Cea